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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