ML19206B410
| ML19206B410 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/05/1979 |
| From: | Podolak E NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Parsont M NRC OFFICE OF STANDARDS DEVELOPMENT |
| Shared Package | |
| ML19206B405 | List: |
| References | |
| NUDOCS 7905100034 | |
| Download: ML19206B410 (1) | |
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t f)nC FOnMDG3 U. S. fdUCLE AR AE GULA10H Y COMMISSION FOR USE Of PiiOCE'SSING UNIT SUGGLSTION NUVOL R 7403 Pd RC M 4154 EM"LOYEE SUGGESTION OATc ntCtivEo INS TRUCTIONS: Prepare this ictm leg hly (preferabt.t type vritten) and submit 3 copics to your supervisor.
- 1. NAME OF SUGGESTER
- 2. POSITION TITLE 3 GRADE Edward M. Podolak, Jr.
Health Physicist h o
jd 14 G.' GU/Ea 'lSOW M(f f~
- 4. OF FICC - OlVISICN - BR ANCH - SECTION
- 5. BUILO(NG j ROOM NO.
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OSD-SHSS-RHSB NL 207
- 7. DESCRIBE THE PHEEEN T SITUATtON, CONDITION, ME THCD, ETC., WHICH YOU BE LIEVE SH OULD 85 CHANGE D OR IMPROVE D.
(Continue on reverse if necessary)
My understanding of the present NRC enforcement system is that the licensee is faced with civil penalties and ultimately loss of a license.
This enforcement system does not regularly reach down to the person who is actually responsible for the violation of the NRC regulations.
C. DESCRIBE YOUR SUGCESTloN. fit you tel:es e the su; estion wott save marpover orir.sterial,impove methods. simplify work.p event accidents, she specifsc detsits at out the s31;ngs an empic>ementL Contiave on reverse of necessay).
I suggest that NRC bolster its enforcement system by seeking legislative authority to prosecute for a felony the individual (s) who is(are) personally responsible for serious violations of URC regulations.
This is part of the enforcerrent sy stem of the Food and Drug Administration and it works very well as a deterrent to individuals who contemplate violating FDA law.
I recall that there was one case where everyone in a chain of cc=and at a particular company was convicted of a feloay, even though the president of the company was on a yacht in the Carribean at the time of the violation.
The key to the FDA enforcement system is that the inspectors take great care to establish who has real authority and responsibility within a firm.
I believe that the threat to individuals of a felony conviction will iCprove compliant'hNRC regulations and make people think twice before violating' our regulations to "please the boss" or "please the company" or for personal gain.
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D. I hereby agree that the use of this sag';estion by the United States sba!! not forrn the ba.is ggk.[f/ //..l.f[/ k [
of a further clairn cf aay r.ature upon the DATE-4/6'/79
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United States by rne, rr.y heirs, or anigns' SIGN A TU RE OF COSUGG LO T E H in/ Jrey)
DATE:
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m SIGP. A I U D Lf4 Sid r'E fiV ISOR' THANK YOU FOR YOUR SUGGESTIO*L 11 wi:1 be Caf efully corsidered by these who hw f unctional 7 -
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C respor nbility in the area of your svystwn, and you f
will tre Afvivd of the actMn taken. Your interest GAT L GUGGE S J WN HE CEIVE D DATC
- A CK SGWLE DGUEN T in [rnproving NRC operations is apprecoted.
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NBC F Of'M 363 (2-1C)