ML20011E904
| ML20011E904 | |
| Person / Time | |
|---|---|
| Issue date: | 03/22/1989 |
| From: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| To: | Davis A, Ebneter S, Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20011E902 | List: |
| References | |
| FOIA-90-34 EGM-89-03, EGM-89-3, NUDOCS 9002230011 | |
| Download: ML20011E904 (1) | |
Text
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NAR-221969
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i EGM 89 03 MEMORANDUM FOR:
William T. Russell, Regional Administrator, RI Stewart D. Ebneter, Regional Administrator, Ril A. Bert Davis, Regional Administrator, Rlll Robert D. Martin, Regional Administratur, RlY John B. Martin, Regional Administrator, RV FROM:
James Lieberman,. Director Office of Enforcement
SUBJECT:
CLASSIFICATION OF MOBlLE NUCLEAR MEDICINE SERVICE LICENSEES FOR PURPOSE OF ENFORCEMENT The purpose of this Enforcement Guidance Memorandum is to provide guidance in classifying mobile nuclear medicine services for purposes of applying Table 1A Base Civil Penalties of the Enforcement Policy.
1 j
-A mobile nuclear medicine service does not fit the definition of a medical
-institution as stated in 10 CFR 35.2.
However, the hazards involved with this licensed activity are at least equal to, if not greater than, an "in house" i
nuclear medicine service at a hospital. An increased hazard in this type of licensed activity can be attributed to the licensee's transportation of milli-curie amounts of technetium-99m from one medical institution to another in the service of its clientele.
Therefore, notwithstanding the definition in 10 CFR q
' 35.2, it is appropri6te that this licensed activity shoulo be classified as being equal to a medical institution under category n of Table IA.
I-Please contact me or Jenny Johansen if you have any questions on this matter.
Original 811ned By Jmes Ueberman James Lieberman, Director Office of Enforcement cc:
H. Thompson, DEDS L. Chanoler, OGC R. Cunningham, NMSS R. Bernero, NMSS E
DISTRIBUTION
-0Lieberman, OE Regional Counsel RI', Ril, Rlli, RIV, RV Enforcement Coordinators
)
RI, RII, Rlli, RIV,
'0E Staff JJohansen, OE EGM Book
~ Day File l
g22fg1900215 p7 UNNERSTA90-34 PDR
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