ML19296F380
| ML19296F380 | |
| Person / Time | |
|---|---|
| Issue date: | 08/08/1980 |
| From: | Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19296F381 | List: |
| References | |
| REF-SSINS-6100, REF-SSINS-SSINS-6 NUDOCS 8010210231 | |
| Download: ML19296F380 (1) | |
Text
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SSINS: 6100 qv" AUG 8 1980 MEMORANDUM FOR:
A. B. Davis, Chief, FFMS Branch,' Region III FROM:
Leo B. Higginbotham, Assistant Director, Division of FFMSI
SUBJECT:
IML TRANSFER OF Tc-99m COSES BETWEEN LICENSED NRC FACILITIES (AITS F03017780)
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The enclosed ELD interpretation on " routine transfer of Tc-99m doses between licensees was discussed with Carl Paperiello of your staff j
en 8/6/80.
We understand from reviewing the IA8. that was to be issued on 8/7/80, that IML would discontinue all transfers and deliveries of Tc-99m doses from facilities that are not licensed for distribution by the NRC under Part 32.
Leo B. Higginbotham Assistant Director Division of FFMSI
Enclosure:
As Stated e
CONTACT:
T. Remsen
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%~j May 8, 1980 MEMORN.'DUM FOR: Tang Remsen, IE FROM:
Richard G. Bachmann, OELD
SUBJECT:
ROUTINE TRANSFER OF Tc-99m BETWEEN NRC-LICENSED FACILITIES This is in response to your memorandum to Jim Lieberman dated April 18, 1980. You requested our opinion on whether a hospital, licensed under 10 CFR 35.14 as a group medical licensee, is authorized to routinely transfer Tc-99m to other hospitals also licensed under 10 CFR 35.14.
Your memo raises two issues:
1.
Is it an item of noncompliance when a group medical licensee transfers by-product material to another licensee?
2.
Is it an item of noncompliance when a group medical licensee receives the material from another group medical licensee?
For item 1, 10 CFR 30.41 _is controlling. This section pennits "any licen'ae" to transfer by-product materi~al to authorized recipient. The transferor is obligated only to verify the recipient is authorized to possess the type, fonn and quantity of the particular material. As long as the receiving hospital's license contains this authorization, the transferring hospital is in compliance.
For item 2, 10 CFR 35.14 restricts the medical group licensee to suppliers licensed under section 32.72 or the Agreement State equivalent. Although the regulations do not specifically state, an exception may be inserted in the license permitting re-ceipt of material from a section 35.14 licensee. Absent such an exception, the recipient will be in noncompliance with NRC regulations requiring a supplier to be licensed under section 32'72.
Should you have any further question on this matter, clease call me.
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1 chard G. Bachmann Attorney Rulemaking and Enforcement Division cc:
Guy Cunningham, ELD c?qoe o) 'ff9@aM3,1