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.