Information Notice No. 87-18: Unauthorized Service on Teletherapy Units by Nonlicensed Maintenance Personnel
SSINS No.: 6835
IN 87-18
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
April 8, 1987
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
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IN 87-18
April 8, 1987
Page 2 of 3
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.
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IN 87-18
April 8, 1987
Page 3 of 3
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
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