DIBP - Perth, WA & MV - Controlled Apparatus - S0092 21-22 Sept 2017

UNCLASSIFIED Inspection report

Licence Holder: DIBP - Perth, WA & MV - Controlled Licence Number: S0092 apparatus - S0092 21-22 Sept 2017

Dates of inspection: 21 - 22 September 2017 Sites Inspected: Perth, WA & Merchant Vessel Ocean Shield Report No: R17/10489

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 1999 (the Regulations), and conditions of the Source Licence S0092.

The scope of the inspection included an assessment of the DIBP - Perth, WA & MV - Controlled apparatus - S0092 21-22 Sept 2017’s performance at Perth sites and Merchant Vessel (MV) Ocean Shield against the Source Performance Objectives and Criteria. The inspection consisted of a review of records, interviews, and physical inspection of sources.

1. Background

DIBP is licensed under section 33 of the Act to deal with controlled apparatus including medical, baggage inspection x-ray units and laser products. Border force operations in Perth include customs operations at ports and airports. This includes a number of fixed and portable units for baggage and parcel inspection, and first defender chemical detection and identification units which contain a class 3B laser. The MV Ocean Shield is a border force vessel which includes an on-board medical facility containing a mobile general (plain film) radiographic unit. The unit was not currently used operationally, but was fully functional and could be utilised at short notice where an operational need is identified.

The main applicable codes and standard for these sources are the Revised Statement On Cabinet X-ray Equipment For Examination Of Letters, Packages, Baggage, Freight And Other Articles For Security, Quality Control And Other Purposes (1987) (RHS21) Code of Practice for Radiation Protection in the Medical Applications of Ionizing Radiation (2008) (RPS14) for medical sources.

2. Observations

In general, the radiation protection measures were found to be satisfactory at both the Perth sites and on-board the MV Ocean Shield. In some cases, however, there appeared to be room for improvement with respect to inventory management and documentation.

Performance Reporting Verification

The details of the baggage inspection x-ray units and chemical detection units were consistent with the corresponding entries in the SIW. However, the location of the units in some cases required updating.

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These changes included one unit that was recorded as being in Canberra but was physically located in Perth and one a mobile (vehicle based) unit which was currently garaged at a different location than the one recorded in the SIW.

DIBP is required to fulfil its reporting commitments to ARPANSA by submission of quarterly reports in the approved format within 28 days of the end of the quarter. The report included information about compliance for the reporting period and that plans and arrangements had been reviewed in accordance with the requirements.

Configuration Control

Onsite procedures and work instructions were readily available. However, the organisation’s Radiation Management Plan (RMP) did not reference these or include provisions on all activities carried out. For example, while some medical sources were covered, the medical uses of the source on-board ship was not adequately covered. Schedule A, section A1 of RPS14 includes a list of requirements that must be met by either being covered in the RMP or in referenced documents.

Inspection, Testing, and Maintenance

Copies of recent maintenance/service reports were provided for each machine. These reports were issued by the supplier of the x-ray unit using staff who hold current local (WA) radiation licences. The service reports provided indicate that regular, at least annual, servicing of the units occurs. These service reports include the results of the radiation monitoring and confirm that checks included functioning of the interlocks were performed without issue. Where evidence of repairs was observed, radiation surveys had also been conducted following these repairs.

Records were provided showing the medical unit had recently been compliance tested to WA standards using appropriate personnel. No issues were identified in the report. The on-board procedures also contained routine QA tests which appear not to have been conducted as the unit was not in operational use.

Training

DIBP must ensure that personnel using controlled apparatus have received appropriate training in radiation safety and use/operation.

For baggage and laser sources, during the inspection records were provided of all authorised officers which included dates of course attendance or when the refresher course was required. These courses are internally delivered. Following successful completion of the baggage scanner use and safety training, individual users are issued with a unique login. This ensures that only trained and authorised persons can use the x-ray units.

For the medical unit there was recognition of the need for specialist training prior to using the equipment, particularly amongst the medical staff (GP Doctor). However, the equipment has not been used and there were no staff who were trained to use the equipment. Staff informed the inspector that if the equipment needed to be used the contractor who provides medical services would supply suitably

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Radiation Protection

All baggage scanners are fitted with indicator lights, labels, and warning signs in accordance with RHS21. Shielding consists of a flexible curtain or fixed metal shielding which was consistent with the use of the units, that is for cargo scanners to which access is restricted to DIBP staff. Recent survey results demonstrated the shielding was effective in controlling scatter. Observations of all x-ray unit showed that the units were in a satisfactory condition, including the flexible curtain shielding at the entry/exit ports where applicable. Emergency stop buttons were also fitted at these ports and at the control panel. Operation of several emergency stop mechanisms was tested during the inspection and worked satisfactorily.

It is a requirement that staff be able to observe entry and exit of baggage scanners. This is typically through placement of the operator to one side. However, on the truck mounted and pallet scanner units this is not possible, and as such a video camera and monitor system is used for these units.

For the medical unit, PPE in the form of lead gowns were observed and were being stored appropriately. Signage in accordance with RPS 14 was observed including warning signage and exposure marking on the unit.

Security and access control

Access control was maintained for each baggage scanner through the use of a key and user logins. Keys are removed when the unit is not in operation to prevent unauthorised use. The laser units were stored in a locked lab which was also the primary place where they are used. These units require a login that is known to trained staff. The medical unit was stored within the secure medical section of the ship. The unit was secured to the floor through a restraining device which prevents movement at sea.

3. 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 areas for improvement:

1. Documentation: The Radiation Management Plan (RMP) did not include all activities and dealings which may be undertaken with controlled apparatus and cover all relevant sections of RPS14 Schedule A1. 2. Inventory Control: Source Inventory Workbook (SIW) did not always include accurate location information.

It is expected that improvement actions be taken in a timely manner.

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