On April 2, 2001, a Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $5,500 was issued for a Severity Level III problem involving a willful failure to notify the NRC prior to conducting industrial radiography operations in offshore waters (i.e., failure to file NRC Form 241) and a willful failure to obtain an exemption from the NRC for the use of pipeliner radiography devices in offshore waters.