Information Notice 1987-18, Unauthorized Service on Teletherapy Units by Nonlicensed Maintenance Personnel

Unauthorized Service on Teletherapy Units by Nonlicensed Maintenance Personnel
	ML031140517
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	04/08/1987
From:	Partlow J; NRC/IE
To:	;
References
	IN-87-018, NUDOCS 8704080015
	Download: ML031140517 (5)
	v • d • e

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SSINS No.: 6835 IN 87-18 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D.C. 20555 April 8, 1987 IE INFORMATION NOTICE NO. 87-18: UNAUTHORIZED SERVICE ON TELETHERAPY UNITS

BY NONLICENSED MAINTENANCE PERSONNEL

Addressees

All NRC licensees authorized to use radioactive material in teletherapy units.

Purpose

This notice is provided to alert recipients that they may be in noncompliance

with their NRC teletherapy licenses should "in-house" or contract maintenance

personnel be used to service or repair the licensees' teletherapy equipment.

It is expected that recipients will review the information for applicability to

their facilities and take actions to preclude a similar problem from occurring

at their facilities. However, suggestions contained in this information notice

do not constitute NRC requirements; therefore, no specific actions or written

response is required.

Description of Circumstances

During recent inspections of teletherapy licensees, NRC staff discovered that

some licensees are using unlicensed, "in-house" engineers, electricians, or

maintenance personnel to perform maintenance or repair on teletherapy equipment.

On one occasion, an NRC licensee allowed an unlicensed, "in-house" staff

member to repair a valve in the pneumatic systems used to return the cobalt-60

source drawer to the shielded position in a teletherapy unit manufactured by

Atomic Energy of Canada, Limited (AECL).

Other examples where maintenance or repair operations were performed by

unlicensed, "in-house" staff follow:

a. An NRC licensee performed service work on the cord reel assembly for the

field defining light of an AECL Theratron 80 unit. NRC inspection findings

concluded that this repair was the most likely cause for the unit's

source drawer sticking in the exposed position, resulting in unnecessary

exposure to two therapy technologists and the patient.

b. Two NRC licensees were found to be in noncompliance with their licenses

when it was determined that the licensees had disassembled and repaired

pneumatic lines and valves.

8704080015 ZA

IN 87-18 April 8, 1987 c. Reports have been received from licensees and teletherapy equipment

manufacturers describing instances where NRC licensees' maintenance staff

have replaced or repaired interlocks to teletherapy room doors. These

devices are considered a part of the teletherapy unit's safety mechanism.

d. Reports have been received concerning NRC licensees performing "in-house"

maintenance and repair upon teletherapy control panels, e.g., replacement

of radiation beam guide lights which indicate source exposure, switches

which activate or terminate radiation exposure, and therapy treatment

timers. These devices are considered a part of teletherapy unit's safety

mechanisms.

e. Reports have been received from teletherapy equipment manufacturers and

teletherapy service companies of cases where NRC licensees' staff have

removed safety-related components for "in-house" repair or replacement, e.g., treatment timers, relays, and circuit boards.

Discussion:

The NRC considers such repairs as an operation defined in the standard license

condition printed below. Consequently, the use of an unlicensed individual

to perform certain operations is in noncompliance with this condition.

The standard license condition for all teletherapy use specifically states:

The following shall be performed only by persons specifically

licensed by the Commission or an Agreement State to perform such

services:

a. Installation, relocation, or removal of teletherapy units

containing sources.

b. Source exchange.

c. Any maintenance or repair operation on a teletherapy unit

involving work on the source drawer, the shutter, or other

mechanism that could expose the source, reduce the shielding

around the source, or compromise the safety of the unit and

result in increased radiation levels.

Not only is the maintenance described above in the license condition required

to be done by persons specifically licensed to perform such services, but

servicing and maintenance at 5-year intervals also is required to be performed

by persons with a specific license pursuant to 10 CFR 35.26.

The NRC staff has determined that service by individuals who are unqualified

and lack specific knowledge of the associated radiation hazards of the device

poses a significant risk to the health and safety of individuals performing the

actual repairs, patients receiving treatment, teletherapy staff technologists, and the general public in unrestricted areas adjoining the teletherapy facility.

IN 87- April , 1987 Licensees authorized to possess and use teletherapy equipment containing

cobalt-60 or cesium-137 should be aware of their responsibility to ensure

compliance with 10 CFR 35.26 and the standard license condition. Licensees

who desire to have these operations performed by qualified "in-house" staff

members who are not authorized by the NRC or an Agreement State must request

an amendment to their license.

No written response is required by this information notice. If you have

questions regarding this matter, please contact the Regional Administrator

of the appropriate NRC regional office or this office.

James G. Partlow, Director

Division of Inspection Programs

Office of Inspection and Enforcement

Technical Contacts: J. Metzger, IE

(301) 492-4947 H. Karagiannis, IE

(301) 492-9655 Attachment: List of Recently Issued IE Information Notices

(* see previous concurrence)

PSAS:IE

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Attachment 1 IN 87-18 April 8, 1987 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information Date of

Notice No. Subject Issue Issued to

87-17 Response Time of Scram 4/7/87 All GE BWR facilities

Instrument Volume Level holding an OP or CP

Detectors

87-16 Degradation of Static "O" 4/2/87 All LWR facilities

Ring Pressure Switches holding an OL or CP

87-15 Complaince with the Posting 3/25/87 All power reactor

Requirements of Subsection facilities holding

223b of the Atomic Energy a CP and all firms

Act of 1954, as Amended supplying components

or services to such

facilities

87-14 Actuation of Fire Sup- 3/23/87 All power reactor

pression System Causing facilities holding

Inoperability of Safety- an OL or CP

Related Ventilation Equipment

86-106 Sup. 2 Feedwater Line Break 3/18/87 All power reactor

facilities holding

an OL or CP

87-13 Potential for High Radiation 2/24/87 All power reactor

Fields Following Loss of facilities holding

Water from Fuel Pool an OL or CP except

Fort St. Vrain.86-106 Sup. 1 Feedwater Line Break 2/13/87 All power reactor

facilities holding

an OL or CP

87-12 Potential Problems With 2/13/87 All power reactor

Metal Clad Circuit Breakers, facilities holding

General Electric Type AKF-2-25 an OL or CP

87-11 Enclosure of Vital Equipment 2/13/87 All power reactor

Within Designated Vital facilities holding

Areas an OL or CP

87-10 Potential for Water Hammer 2/11/87 All BWR facilities

During Restart of Residual holding an OL or CP

Heat Removal Pumps

OL = Operating License

CP = Construction Permit

IN 87- March , 1987 Licensees authorized to possess and use teletherapy equipment containing