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 G NRC/IE
To:
References
IN-87-018, NUDOCS 8704080015
Download: ML031140517 (5)

--ss m-* ^SSINS No.: 6835IN 87-18UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF INSPECTION AND ENFORCEMENTWASHINGTON, D.C. 20555April 8, 1987IE INFORMATION NOTICE NO. 87-18: UNAUTHORIZED SERVICE ON TELETHERAPY UNITSBY 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 noncompliancewith their NRC teletherapy licenses should "in-house" or contract maintenancepersonnel be used to service or repair the licensees' teletherapy equipment.It is expected that recipients will review the information for applicability totheir facilities and take actions to preclude a similar problem from occurringat their facilities. However, suggestions contained in this information noticedo not constitute NRC requirements; therefore, no specific actions or writtenresponse is required.

Description of Circumstances

During recent inspections of teletherapy licensees, NRC staff discovered thatsome licensees are using unlicensed, "in-house" engineers, electricians, ormaintenance personnel to perform maintenance or repair on teletherapy equipment.On one occasion, an NRC licensee allowed an unlicensed, "in-house" staffmember to repair a valve in the pneumatic systems used to return the cobalt-60source drawer to the shielded position in a teletherapy unit manufactured byAtomic Energy of Canada, Limited (AECL).Other examples where maintenance or repair operations were performed byunlicensed, "in-house" staff follow:a. An NRC licensee performed service work on the cord reel assembly for thefield defining light of an AECL Theratron 80 unit. NRC inspection findingsconcluded that this repair was the most likely cause for the unit'ssource drawer sticking in the exposed position, resulting in unnecessaryexposure to two therapy technologists and the patient.b. Two NRC licensees were found to be in noncompliance with their licenseswhen it was determined that the licensees had disassembled and repairedpneumatic lines and valves.8704080015 ZA IN 87-18April 8, 1987 c. Reports have been received from licensees and teletherapy equipmentmanufacturers describing instances where NRC licensees' maintenance staffhave replaced or repaired interlocks to teletherapy room doors. Thesedevices 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., replacementof radiation beam guide lights which indicate source exposure, switcheswhich activate or terminate radiation exposure, and therapy treatmenttimers. These devices are considered a part of teletherapy unit's safetymechanisms.e. Reports have been received from teletherapy equipment manufacturers andteletherapy service companies of cases where NRC licensees' staff haveremoved 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 licensecondition printed below. Consequently, the use of an unlicensed individualto 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 specificallylicensed by the Commission or an Agreement State to perform suchservices:a. Installation, relocation, or removal of teletherapy unitscontaining sources.b. Source exchange.c. Any maintenance or repair operation on a teletherapy unitinvolving work on the source drawer, the shutter, or othermechanism that could expose the source, reduce the shieldingaround the source, or compromise the safety of the unit andresult in increased radiation levels.Not only is the maintenance described above in the license condition requiredto be done by persons specifically licensed to perform such services, butservicing and maintenance at 5-year intervals also is required to be performedby persons with a specific license pursuant to 10 CFR 35.26.The NRC staff has determined that service by individuals who are unqualifiedand lack specific knowledge of the associated radiation hazards of the deviceposes a significant risk to the health and safety of individuals performing theactual repairs, patients receiving treatment, teletherapy staff technologists,and the general public in unrestricted areas adjoining the teletherapy facilit IN 87-April , 1987 Licensees authorized to possess and use teletherapy equipment containingcobalt-60 or cesium-137 should be aware of their responsibility to ensurecompliance with 10 CFR 35.26 and the standard license condition. Licenseeswho desire to have these operations performed by qualified "in-house" staffmembers who are not authorized by the NRC or an Agreement State must requestan amendment to their license.No written response is required by this information notice. If you havequestions regarding this matter, please contact the Regional Administratorof the appropriate NRC regional office or this office.James G. Partlow, DirectorDivision of Inspection ProgramsOffice of Inspection and EnforcementTechnical Contacts: J. Metzger, IE(301) 492-4947H. Karagiannis,(301) 492-9655IE

Attachment:

List of Recently Issued IE Information Notices(* see previous concurrence)PSAS:IEDGable3/10/87*OC :SMPB:IE :SMPB:IE :C:SMPB:IE :DD:DI:IE : DEPER IE :D:DI:IENAME :JMetzger :HKaragiannis:GSjoblom :RSpessard :SSch z :tJor an :JPartlowDATE :3/ /87sjr :3/ /87 :3/ /87 :3/ /87 : /87 7 :3/ /87s _4 w * .@ -tAttachment 1IN 87-18April 8, 1987LIST OF RECENTLY ISSUEDIE INFORMATION NOTICESInformation Date ofNotice No. Subject Issue Issued to87-1787-1687-1587-14Response Time of ScramInstrument Volume LevelDetectorsDegradation of Static "O"Ring Pressure SwitchesComplaince with the PostingRequirements of Subsection223b of the Atomic EnergyAct of 1954, as AmendedActuation of Fire Sup-pression System CausingInoperability of Safety-Related Ventilation Equipment4/7/874/2/873/25/873/23/87All GE BWR facilitiesholding an OP or CPAll LWR facilitiesholding an OL or CPAll power reactorfacilities holdinga CP and all firmssupplying componentsor services to suchfacilitiesAll power reactorfacilities holdingan OL or CP86-106 Sup. 2Feedwater Line Break3/18/87All power reactorfacilities holdingan OL or CP87-13Potential for High Radiation 2/24/87Fields Following Loss ofWater from Fuel PoolAll power reactorfacilities holdingan OL or CP exceptFort St. Vrain.86-106 Sup. 1Feedwater Line Break2/13/87All power reactorfacilities holdingan OL or CP87-1287-1187-10Potential Problems With 2/13/87Metal Clad Circuit Breakers,General Electric Type AKF-2-25Enclosure of Vital Equipment 2/13/87Within Designated VitalAreasPotential for Water Hammer 2/11/87During Restart of ResidualHeat Removal PumpsAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll BWR facilitiesholding an OL or CPOL = Operating LicenseCP = Construction Permit IN 87-March , 1987 Licensees authorized to possess and use teletherapy equipment containingcobalt-60 or cesium-137 should be aware of their responsibility to ensurecompliance with 10 CFR 35.26 and the standard licensed condition. Licenseeswho desire to have these operations performed by qualified "in-house" staffmembers who are not authorized by the NRC or an Agreement State must requestan amendment to their license.No written response is required by this information notice. If you havequestions regarding this matter, please contact the Regional Administratorof the appropriate NRC regional office or this office.James G. Partlow, DirectorDivision of Inspection ProgramsOffice of Inspection and EnforcementTechnical Contacts: J. Metzger, IE(301) 492-4947H. Karagiannis, IE(301) 492-9655

Attachment:

List of Recently Issued IE Information Notices(* see previous concurrence)PSAS:IE rx sDGable3/10/87* 7/87OFC :SMPB:IE :SMPB:IE :C:SMPB :DI:IE 5QD:DEPERAE :D: EP 9IE :fNAME .: : er aHKrag;nis: G : RSan :S p z .M in '-_ -------- ---------DATE :3//t/87sjr:3/1 J/87