ML19037A079
| ML19037A079 | |
| Person / Time | |
|---|---|
| Issue date: | 02/08/2019 |
| From: | White A Office of Nuclear Material Safety and Safeguards |
| To: | State of VT |
| Shared Package | |
| ML19037A060 | List: |
| References | |
| Download: ML19037A079 (16) | |
Text
State of Vermont Department of Health Radioactive Materials Program Procedure 3.1, Revision 0 Management of Allegations Prepared By:
Date:
Reviewed By:
Date:
Approved By:
Date:
Effective Date:
Revision Date Description of Changes 0
Radioactive Materials Program Procedure 3.1, Revision 0 Management of Allegations Table of Contents 1.0 PURPOSE 1.1 Applicability 1.2 References 1.3 Files 1.4 Definitions 2.0 RESPONSIBILITIES 2.1 Radioactive Materials Program Staff 2.2 Radiological Health Specialist 2.3 Radioactive Materials Program Manager (RMPM) 2.4 Radiation Control Program Director (RCPD) 3.0 PROCEDURE 3.1 Initial Contact 3.2 Disclosure of Alleger's Identity 3.3 Controlling Allegations 3.4 Referral of Allegations to Licensee 3.5 Investigations 3.6 Close Out 3.7 Coordinating with Other Agencies 4.0 ATTACHMENTS TO RMPP 3.1 3.1-1 Initial Contact Log 3.1-2 Nondisclosure Statement 3.1-3 Allegation Screening Form 3.1-4 Confidential Information and Files 3.1-5 Acknowledgement Letter to Alleger
Management of Allegations 1.0 PURPOSE 1.1 Applicability This procedure is to ensure that any allegation made against a licensee is properly addressed and to provide guidance to protect the identity of the alleger. Actions taken in response to an allegation include investigation, documentation, and enforcement, as appropriate. If, at any time, the need for criminal investigatory capacity is required, (for example thefts and/or terrorist activity, as described in Section 3.1.2) contact the Local Law Enforcement Agency (LLEA) and/or the Vermont State Police and/or other state and federal agencies such as the U.S.
Federal Bureau of Investigation (FBI), as appropriate. The FBI should be notified if an event involves the possibility of theft or terrorist activities. The Vermont Department of Health (Department) shall promptly notify the Nuclear Regulatory Commission (NRC) Operations Center (301-819-5100) after contacting the appropriate LLEA and/or FBI in cases involving actual or attempted theft, sabotage, or diversion of radioactive materials as indicated in Appendix G of SA-300.
1.2 References 1.2.1 NRC Management Directive 8.8, "Management of Allegations."
1.2.2 NRC Inspection Manual Chapter 2800 Materials Inspection Program.
1.2.3 SA-300, Reporting Material Events.
1.2.4 Vermont Radioactive Materials Rule.
1.3 Files 1.3.1 All allegation-related documentation is to be maintained in a secured allegation file (AF) in the Radioactive Materials Program.
1.3.2 Allegation files are padlocked secured when not in use and access is controlled and limited to Radioactive Materials Program Staff who are actively using the particular case file. Electronic allegation files shall be limited to RMP staff required to address the allegation and authorized access to the electronically secured space.
1.4 Definitions
1.4.1 Agency
The Radioactive Materials Program (RMP) of the Vermont Department of Health (Department).
1.4.2 Allegation
A declaration, statement, or assertion of impropriety or inadequacy associated with Radioactive Materials Program (RMP)
Commented [OF1]: NRC comment 39 Commented [SJ2R1]: We recommend referencing section 3.1.2, which provides a more detailed description of criminal investigatory capacity, for clarity.
Commented [OF3]: NRC comment 40 Commented [SJ4]: Sometimes VT uses the acronym and sometimes it uses full termrecommend choosing one for consistency Commented [SJ5]: VTs response to Comment 40 states that All documents are maintained only electronically where only Radioactive Materials Program staff have access. The highlighted language, however, makes it seem like the files are still