ML25177D055
| ML25177D055 | |
| Person / Time | |
|---|---|
| Site: | 15000017 |
| Issue date: | 07/02/2025 |
| From: | Michelle Simmons NRC/RGN-IV/DRSS/MLB |
| To: | Eddins W Alliance Engineering Group |
| Everett S | |
| References | |
| IR 2025002 | |
| Download: ML25177D055 (1) | |
See also: IR 015000042/2025002
Text
July 02, 2025
Wayne Eddins, Radiation Safety Officer
Alliance Engineering Group, Inc.
200 Mustang Cove
Taylor, TX 76574
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.
W. Eddins
2
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
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
/RA/
/RA/
/RA/
DATE
06/30/25
07/01/25
07/02/25
Enclosure
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.
2
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