Inspection report: Department of Home Affairs, Fremantle (R22/01211)

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 F0155. 

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

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 F0155 authorises operation of a 6 MeV particle accelerator at the Fremantle 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 Fremantle CEF continues to reflect the principles of the POC 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 common to all the Department’s CEF licences. 
The actions taken to address the two areas for improvement from the last inspection in 2019 regarding update of the radiation safety management plan and update of signage to reflect requirements of ANSI/HPS N43.3-2008 were reviewed and it was concluded these have been completed. 

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 F0155.  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 Regional Management Review Meeting held in December 2021 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 Fremantle site and it was concluded that these had been effectively implemented. These included implementing targeted tool-box talks and further supervisor checks when commencing shifts. 

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. The radiation compliance register was viewed and the scheduled dose surveys were concluded to be in line with the requirements of the Radiation Safety Management Plan. 

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 (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 2019 and no issues raised. The Covid-19 pandemic has not interrupted the scheduled preventative or corrective maintenance taking place at the Fremantle CEF.  This was demonstrated through the reports provided and review of the contractor incident log and all maintenance was found to have been appropriately recorded.

Configuration management

Inspectors discussed the change management process employed at the facility. 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 change management procedures are always used when making changes to plant, equipment, operating processes and management arrangements.

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 Fremantle CEF Site Radiation Safety Officer (SRSO), deputy SRSO were examined and no issues raised. In addition, the site training register was reviewed which demonstrated that staff operating the CEFs had been trained in accordance with TI-1956. 

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. 

Security

The security plan was reviewed by the inspectors and no significant issues raised. At the time of the inspection, it was noted that no security incidents had been reported at the Fremantle facility since the last ARPANSA inspection, but a system was in place for management of such incidents. 

Radiation protection

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 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 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 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 its emergency plan and to coordinate emergency response training activities and drills. 
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. 

The Fremantle 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. The next physical exercise has been scheduled for February 2022. 

Only one incident which involved an evacuation of the facility has been recorded since the last inspection. Records of this were viewed and found to be in line with the emergency plan requirements and no issues raised. 

The log for 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. 

The inspection revealed the following area for improvement:

1. 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 improvement action will be taken in a timely manner.