Inspection Report: Department of Home Affairs, Sydney Container Examination Facility, Port Botany, R22/02912

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 F0125. 

The scope of the inspection included an assessment of the Department of Home Affairs performance at the Sydney Container Examination Facility (CEF) against the Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews and a physical inspection of the facility.

Background

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 F0125 authorises operation of a 6/9 MeV particle accelerator at the Sydney 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))

Observations

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 Sydney CEF continues to reflect the principles of the POC in its controls, behaviours, and management system. 

The actions taken to address the three areas for improvement from the last inspection in March 2020 regarding update of the security plan, verification of training records and worker knowledge of radiation risks were reviewed and found to be appropriate.

The following key observations were made: 

Performance reporting verification

Quarterly reports since the last inspection in 2020 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 F0125.  No radiological events have been reported since the last inspection. This is not considered unusual for a facility of this nature. 

The minutes of the last four Regional Management Review Meetings and the last Container and Cargo Management Quality Management System (CCMQMS) Management Review Meeting (at senior executive level) held in December 2021 were reviewed and discussed at the time of the inspection. These meetings review information from all the Department’s sites including work health and safety events, tracking of corrective actions, effectiveness of implementation of actions, recommendations from internal and external audits, dose surveys and security issues etc. 

Evidence of completion of a sample of actions recommended from the analysis of event trends recorded in the CMQMS December 2021 minutes were reviewed for the Sydney site and it was concluded that these had been effectively implemented. These included implementing improved procedures around the management of unknown substances which includes the detection of unexpected radiation in a package. 

The completion of recommended improvement actions against the ANSI/HPS N43.3-2008 code made during a dose survey completed by an external provider in 2019 were reviewed at the time of the inspection and no issues raised. 

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 accelerator to provide ongoing inspection testing and maintenance for radiation safety and operationality. These are defined in maintenance plans. The last two maintenance plans (2020-2021 and 2021-2022) 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 access the facility. 

The quarterly and annual maintenance reports were reviewed since the last inspection in 2020 and no issues raised. 

Configuration management

Inspectors discussed the area for improvement which had been raised at the last Brisbane and Fremantle CEF inspections related to documentation of the change management process across all the facilities, including the Sydney CEF. It was noted that this has now been addressed by an update to procedure.

Training

The training requirements for staff 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. In addition, external approved suppliers are engaged for radiation courses as required. 

The training records for the Sydney CEF Site Radiation Safety Officer (SRSO), deputy SRSO 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. 

A revised radiation safety training course XRU1 X-ray & Radiation Awareness E-Learning was noted which aims to improve/maintain staff risk awareness of radiation.

Security

The most recent security plan was reviewed by the ARPANSA Principal Security Advisor, and no issues raised. The plan had been updated as part of an area for improvement from the 2020 ARPANSA inspection. At the time of the inspection, it was noted that no security incidents had been reported at the Sydney facility since the last ARPANSA inspection, but a system remains in place for management of such incidents. 

Radiation protection

The Department has, since 2020 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 the accelerator is modified or moved) radiation surveys to the frequency laid out in the Radiation Safety Management Plan.

The most recent radiation survey for the CEF was reviewed with no significant issues raised. Surveys are conducted periodically in line with ANSI/HPS/N43.3.2008 and after any modifications.  Nuctech also conducts leakage surveys as part of the quarterly and yearly maintenance. The ARPANSA inspectors reviewed the results and raised no issues. 

The annual calibration status of the RadEye Personal Radiation Detector devices was examined during the physical site inspection and found compliant. 
Signage at the entrance and corridors to the CEF was viewed and found to be in line with ANSI/HPS/N43.3.2008.

Emergency preparedness & response

The Department engages an external contractor (Hendry) to assist in developing its emergency plan and to coordinate emergency response training activities and drills. Records of the last emergency exercise and the last Emergency Planning Committee meeting (both February 2022) were examined and it was noted that many of the actions such as increasing the number of trained wardens on site had already been implemented. 

As part of the induction program, all employees are familiarised with the plan. It contains an emergency manual that outlines procedures for 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. Likely radiation related emergency scenarios are captured under the suspicious package sections. The plan is currently under review as part of routine update. 

Evidence of maintenance conducted on the emergency systems such as the fire systems, public address system, checks on evacuation routes and exits, was examined and all required checks found to be complete as of the time of the inspection. 

Event protection

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. 

Findings

The licence holder was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions.