Policy on Licensed Material Security Violations

Applicable NRC Regulations include 10 CFR 20.1801 and 20.1802

  • The Authorized User (AU) is responsible for securing from unauthorized removal or access all licensed materials under his/her authorization.
  • If the AU allows an individual access to any of his/her licensed materials, he/she is required to train this supervised individual in their security responsibilities, and the AU is responsible for the acts and omissions of the supervised individual.
  • If the licensed material is found unsecured, the following steps should be taken:
    • immediately re-establish security for the licensed material;
    • inform the AU and the supervised individuals that licensed materials were found unsecured; and,
    • the AU will be required within three days to provide the Radiation Safety Officer (RSO) their inventory of licensed materials, including radioactive wastes, to determine total activity per isotope on hand, and identify if any licensed materials are missing.
  • The Radiation Safety staff will determine the significance of the security violation by evaluating the inventory of unsecured licensed material as compared to 10 CFR 20 Appendic C values, and if licensed materials were missing whether notification to the NRC is required under 10 CFR 20.2201.
  • The AU will be required to submit to the Radiation Safety Committee (RSC) a formal written response determining the root cause of the violation, immediate corrective actions, and long-term corrective actions. The timing required for the AU's response will be determined on a case-by-case basis, but will be required no later than as a response to the AU's next inspection.
  • The Radiation Safety staff will re-inspect the AU's location as often as the RSO or RSC deem necessary, but at least within one month from identification of the security violation. The RSO and RSC can give consideration to whether the AU or supervised individual reported the incident and the AU's dedication and timeliness in taking corrective actions. 

Approved by the Radiation Safety Committee on October 10, 2019.


Page last updated on November 1, 2019.