ML20236T797
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DEC 31 1986 MEMORANDUM FOR:
Glen Sjoblom, Chief, Safeguards and Materials Program Branch, IE FROM:
- W. L. Axelson, Chief . Nuclear Materials Safety
, and. Safeguards Branch, Region III
SUBJECT:
INPUT.FOR STAFF RESPONSE TO DECEMBER 16, 1986 COMMISSION REQUEST:
OVERSIGHT MEDICAL MISADMINISTRATION - NEED FOR IMPROV To aid your staff in responding to the pertirient questions raised by the Commission, we have prepared an analysis and recommendation to Question No. 2 "What or' additional inspection measures are needed, including improvement in the regulations program?
frequency of HRC inspections of Part 35 licensees?"Should there be changes 1 with improved inspection techniques. Our analysis deals only examined by NMSS. Improved licensing techniques-are being We have made the following breakdown of licensees which possess combinations of Groups IV, V, VI or teletherapy type programs. These licensees would all have the potential for a serious therapeutic misadministration. We have subdivided this breakdown with and without Illinois licensees (the latest we hear is Illinois will be an Agreement State at the end of March 1987).
- 1. Region III Licenses (w/ Illinois) 34MedicalInstitutionsBroad(Priority 2) 477 Medical Institutions Group (Priority 3) 13 Medical Private Practice (Priority 3)
Total - 524
- 2. Region III Licenses (w/o' Illinois) 23 Medical Institutions Broad (Priority 2) 355 Medical Institutions Group (Priority 3) 12 Medical Private Practice (Priority 3).
Total - 390 8712020099 871201
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1 Glen Sjoblom 2
DEC 31 1960
- 3. Teletherapy Only (w/ Illinois) 173 Licenses (Priority 3).
- 4. Teletherapy Only (w/o Illinois) i 126 Licenses'(Priority.3)
We recommend the following changes in inspection frequencies: '
1.- Change Medical Broad to Priority 1
, '2. Change Medical Private Practice to Priority 2 3.
Change2Medical Teletherapy to Priority 1 (first year), then to a Priority We. feel that more regulatory attention is needed for the Broad Type medical licenses loads. primarily because.these type licensees usually have large patient are all Broad Type licenses all of which experienced therapeuticF '
misadministration within the last two years. It appears that we should conduct patient safety. more frequent inspections of these large programs to better ensure On the other hand, we also feel more regulatory attention is needed for the Private Practice licenses primarily because these programs are usually small with few qualified staff technologist or dosimetrists. Accordingly, these type licensees could be prone to error due to lack of staffing to check QA operations.
Finally, in light of possib'a new QA/QC requirements (Orders) for all teletherapy year should be type licoses, we feel increased inspection effort for the first required.
Orders within a reasonable time frame. Currently, 01E policy requires us to follow up on changed to Priority I for the first year.Therefore, these licenses should be Our analysis of these changes show minor staff increased effort for our
.per recommendations year (.2 FTE). for Broad Type and. Private Practice, about 20 extra inspections )
annual teletherapy inspections, about 90 extra inspectionsHowever, signii This analysis assumes no inspections of Illinois licensees.per year (.9 FTE).
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o Glen Sjoblom 3 DEC 31 1986 In summary, our region could absorb this additional effort, about 1.1 FTE, because of the extra inspection resources made available from Illinois becoming an Agreement State.
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. L. xe ory, Chief Nuclear Materials Safety and Safeguards Branch ,
cc: V. Miller, NMSS bec: D. J. Sreniawski D. G. Wiedeman B. S. Mallett i
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