ML20127C415
| ML20127C415 | |
| Person / Time | |
|---|---|
| Issue date: | 11/28/1984 |
| From: | Metzger J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Cobb L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20127A504 | List: |
| References | |
| FOIA-85-69 NUDOCS 8501210299 | |
| Download: ML20127C415 (3) | |
Text
ong UNITED STATES
-8
,5(j g , j 3 .E NUCLEAR REGULATORY COMMISSION e WASHINGTON. D. C. 20555 o - e t c j# November 28, 1984 MEMORANDUM FOR: Leonard I. Cobb, Chief Safeguards and Materials Programs Branch, IE FROM: Jack R. Metzger, Staff member Safeguards and Materials Programs Branch, IE
SUBJECT:
OBSERVATIONS THAT WERE FOUND MOST EFFECTIVE DURING THE CONDUCT OF MEDICAL INS'ECTIONS AS A RESULT OF INSPECTOR ACCOMPANIMENT
- 1. Interview technicians to determine their knowledge of nuclear medicine through training, certification, Reg. Guide 10.8, the license, and NRC regulations.
2.a. Ask technicians about their daily routine and, if practical, have them run through a simple procedure such as a dose calibrator constancy check, or ask them how waste is handled, how incoming packages are handled, or how security is maintained; e.g., locked labs.
- b. Inquire of technicians about how surveys are conducted (fixed and removable) contamination and radiation); e.g., how they use and read their instruments, how wipes are taken and counted and how they interpret the results. Also inquire about limitations of various detection instruments.
- 3. Conduct independent surveys of' labs, radioactive material storage areas and waste storage areas. Survey for compliance with 20.105(b). These surveys should be cursory, not lengthy, or until the inspector is reasonably satisfied that no serious hazard exists.
- 4. Ask to see the sealed sources used for the dose calibrator checks (except linearity) and determine if they are properly shielded. Examine records of leak tests.
- 5. Check records of constancy checks. Note the time they were done or ask the technician when they are done (they should be done at the first of the day, not at the end).
- 6. Check all records of linearity and accuracy checks since the previous inspection; check all dosimetry results.
- 7. Randomly check records of receipt and transfer, radioactive material inventory, surveys of incoming packages, laboratories, injection areas, etc.
Most of the more recent records should be checked and more randomly for older records.
nquire about how waste is handled - held for decay to background? how
.flong?,surveyedbeforerelease?
c Examine records and note the dates of
- olding waste before release.
1 g
- 9. Inquire about the use of trash cans, their locations and whether labeled if they might contain radioactive material.
- 10. For teletherapy inspections observe the operation of warning lights, -
mirrors to observe patients outside of the treatment rooms and check interlocks (if no patients are being treated - for all inspections there should be no interference with patient treatment.) Examine records of teletherapy calibration, output verifications. Inquire if there have been source hangups and what procedures were used to get l patients out to correct or repair the unit. l
- 11. Examine postings, labelling, Form 3's, and posting of license, etc. or a notice where they may be examined.
- 12. Determine if licensees have a copy of the license, Parts 19, 20, and 35.
During interviews, try to determine if the technicians understand the requirement of these documents.
- 13. Examine records of tests for molybdenum break-through if the license uses generators. If possible, watch a test being conducted.
- 14. For institutions that do therapy, check records of inventory and policy for accounting for and storing of needles, seeds, etc.
- 15. Many medical licensees have consultants on retainers to calibrate instruments, conduct surveys and a variety of other jobs, including advise on record keeping. Inquire of the licensees if they understand what the consultant is actually doing (several violations can occur because of consultant mismanagement or poor advice to the licensee).
- 16. Finally, use tact and diplomacy and maintain control over the inspection.
During the exit interview, explain precisely the findings so there is no misunderstanding.
//
Jack
'M R. Mdtzger, Staff member Safeguards and Materials Programs Branch, IE t
- e j
- m. ., .s ENCL 0SURE 5 COMMENTS ON INSPECTION PROGRAM FOR MEDICAL LICENSEES
.