IR 015000042/2025002
| ML25177D055 | |
| Person / Time | |
|---|---|
| Site: | 15000017, 015000042 |
| Issue date: | 07/02/2025 |
| From: | Michelle Simmons NRC/RGN-IV/DRSS/MLB |
| To: | Eddins W Alliance Engineering Group |
| Everett S | |
| References | |
| IR 2025002 | |
| Preceding documents: |
|
| Download: ML25177D055 (1) | |
Text
July 02, 2025
SUBJECT:
ALLIANCE ENGINEERING GROUP, INC. - INSPECTION REPORT 150-00042/2025-002 AND NOTICE OF VIOLATION
Dear Wayne Eddins:
This letter refers to the in office review conducted on January 9, 2025 for Alliance Engineering Group, Inc., (Inspection Report No(s). 150-00042/2025-002) regarding the failure to request NRC approval of reciprocity prior to performing licensed activities in areas of exclusive Federal jurisdiction. The enclosed report presents the results of this in-office review. The preliminary findings of this in-office review were discussed with you on January 10, 2025. A final exit briefing was conducted telephonically with you on June 13, 2025.
Based on the results of this in-office review, the NRC has determined that one Severity Level IV violation of NRC requirements occurred involving the failure to file a complete initial application for reciprocity prior to working in exclusive Federal jurisdiction for calendar year 2025. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs web site at (http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html). The violation is cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding it are described in detail in the subject Notice. The violation is being cited in the Notice because it was identified by the NRC during a review of records submitted by Alliance Engineering Group, Inc.
In accordance with the NRC Enforcement Policy, the failure to file an NRC Form 241 prior to engaging in licensed activities in NRC jurisdiction is normally categorized as a Severity Level III violation. The NRC Enforcement Policy includes Severity Level IV violations when certain criteria are met. You met all four of the criteria in Section 6.9.d.14 to be characterized as a Severity Level IV violation.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. You can find the Information Notice on the NRC website at: https://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1996/in96028.html. Information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance will be (was) achieved should be addressed. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure(s), and your response, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction.
Sincerely, Michelle R. Simmons, Branch Chief Materials Licensing Branch Division of Radiological Safety and Security Docket No. 150-00042 License No. 10 CFR 150.20 Enclosure(s): Notice of Violation Signed by Simmons, Michelle on 07/02/25
ML25177D055 SUNSI Review By: SJE Publicly Available Non-Publicly Available Non-Sensitive Sensitive OFFICE HP:DRSS/MLB C:DRSS/MIB C:DRSS/MLB NAME SEverett LRoldanOtero MSimmons SIGNATURE
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DATE 06/30/25 07/01/25 07/02/25
Enclosure NOTICE OF VIOLATION Alliance Engineering Group, Inc Docket No. 150-00042 Taylor, Texas License No. 10 CFR 150.20 During an NRC in-office review conducted on January 9, 2025, one violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
10 CFR 150.20(a)(1) requires, in part, that any person who holds a specific license from an Agreement State is granted a general NRC license to conduct the same activity in non-agreement states subject to the provisions of 10 CFR 150.20(b).
10 CFR 150.20(b)(1) requires, in part, that any person engaging in activities in an area of exclusive Federal jurisdiction under the general license provisions of 10 CFR 150.20 shall, at least 3 days before engaging in each activity for the first time in a calendar year, file a submittal containing an NRC Form 241, Report of Proposed Activities in Non-Agreement States, a copy of its Agreement State specific license, and the appropriate fee with the Regional Administrator of the appropriate NRC regional office.
Contrary to the above, on January 7 and January 8, 2025, Alliance Engineering Group, Inc.,
a licensee of the State of Texas, engaged in activities in a non-agreement state without filing a submittal containing an NRC Form 241, a copy of its Agreement State specific license, and the appropriate fee with the Regional Administrator of the NRC Regional Office at least 3 days before engaging in each activity for the first time in a calendar year. Specifically, Alliance Engineering Group, Inc., performed work on January 7,2025 and January 8, 2025, but did not submit an NRC Form 241, a copy of its Agreement State radioactive materials license, and the appropriate fee until January 8, 2025. Since the licensed material was used in exclusive Federal jurisdiction on January 7, 2025 and January 8, 2025, the licensee was required to provide this information to the NRC 3 days prior to the start of the new calendar year, which was January 4, 2025.
This is a Severity Level IV violation.
Pursuant to the provisions of 10 CFR 2.201, Alliance Engineering Group, Inc., is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, Region IV, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation; Inspection Report 150-00042/2025-002 and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level; (2)
the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued requiring information as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Your response will be made available electronically for public inspection in the NRC Public Document Room or in the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary], or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,
explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within 2 working days of receipt.
Dated this 2nd day of July 2025