IE Circular No. 80-19. Noncompliance with License Requirements for Medical Licensees
CR80019 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 August 18, 1980 MEMORANDUM FOR: B. H. Grier, Director, Region I J. P. O'Reilly, Director, Region II J. G. Keppler, Director, Region III K. V. Seyfrit, Director, Region IV R. H. Engelken, Director, Region V FROM: J. H. Sniezek, Director, Division of Fuel Facility and Materials Safety Inspection, IE SUBJECT: IE CIRCULAR NO. 80-19. NONCOMPLIANCE WITH LICENSE REQUIREMENTS FOR MEDICAL LICENSEES The subject circular is enclosed for issuance on August 26, 1980. The circular should be issued to all medical licensees. A draft copy of the transmittal letter, removable labels, and licensee address printout are also enclosed. J. H. Sniezek, Director Division of Fuel Facility and Materials Safety Inspection Office of Inspection and Enforcement Enclosures: 1. Draft transmittal letter 2. IE Circular No. 80-19 3. Addressee labels (removable) 4. Licensee address printout CONTACT: J. R. Metzger, IE 49-28188 . (Draft transmittal letter for Circular 80-19 to each medical licensee) IE Circular No. 80-19: NONCOMPLIANCE WITH LICENSE REQUIREMENTS FOR MEDICAL LICENSEES Addressee: The enclosed Circular 80-19, is forwarded for your information. If there are any questions related to the suggested actions, please contact this office. Sincerely, Signature (Regional Director) Enclosures: 1. IE Circular No. 80-19 2. Recently issued IE Circulars . SSINS No.: 6830 Accession No.: 305050070 IEC 80-19 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 August 26 ,1980 IE Circular No. 80-19: NONCOMPLIANCE WITH LICENSE REQUIREMENTS FOR MEDICAL LICENSEES Description of Circumstances: The NRC inspection program is uncovering many items of noncompliance at medical facilities indicating that employees are not familiar with the requirements that are conditions for issuance of the license. The major causes include the following: (1) The application for licenses is often prepared by an outside consultant with no one at the facility being thoroughly familiar with the license conditions or other details of the license application. (2) Employees of medical facilities do not realize that many commitments made in the license application actually become part of the license by reference in a stated license condition. The applications and supporting letters incorporated as requirements are identified by date in this condition to the license. This is known as a "tie-down" condition. That is, the license is issued by the NRC under the conditions stated therein, and compliance with all of those conditions is required. An important example of the "tie-down" condition includes the operating and radiological safety procedures submitted with the application. The license is issued under the condition that the procedures tendered with the application will be used and followed. (3) Employees of medical facilities are not being instructed in the applicable provisions of Commission regulations and licenses for protection of personnel from exposures to radiation or radioactive materials in accordance with Section 19.12 of Part 19, Title 10, Code of Federal Regulations. Notice to Licensees: Both management and involved employees of medical facilities must be aware of and comply with all license conditions. The following actions are recommended: (1) Assure that a representative of management understands the commitments being made in the applications and contained in the license as finally issued. (2) Assure that existing and new employees are instructed in and are familiar with all applicable conditions of the license, including the details of applicable documents, such as procedures that are incorporated by condition into the license. . IEC 80-19 August 26, 1980 Page 2 of 2 (3) Assure that all employees are instructed in application changes each time the license is amended. (4) Assure that copies of the NRC regulations and copies of the license, as well as documents incorporated into the license by reference, are posted and/or are made available to employee accordance with Section 19.11 of Part 19, Title 10, Code of Federal Regulations. No written response to this Circular is required. If you require additional information regarding this subject, please contact this office.
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