# NRC ORDER – ORDER
> **EA-18-033** · ORDER · Issued 2018-09-27 · Materials Licensees
## Action
- **EA Number:** EA-18-033
- **Licensee:** ORDER
- **Category:** Materials Licensees
- **Action type:** ORDER
- **Date issued:** 2018-09-27
## Description

On September 27, 2018, the NRC issued a Confirmatory Order to Harman International Industries, Inc. (Harman) confirming commitments reached as part of an alternative dispute resolution (ADR) mediation session. The session was associated with three apparent violations identified during an NRC records review: (1) initially transferring, for sale or distribution, lamps containing krypton-85 without an NRC license for such activity pursuant to 10 CFR sections 30.3(a), 30.15(a)(8)(iv), and 32.14; (2) possession of material (krypton-85) without an NRC license for such activity pursuant to 10 CFR 30.3; and (3) importing material (krypton-85) into the United States without an NRC or an Agreement State license for possession of the material containing byproduct material pursuant to 10 CFR 110.5, 110.9a, 110.20(a), and 110.27(a). The licensee agreed to take a number of actions, in addition to steps already taken, including but not limited to: (1) maintain the position of Compliance Manager. This role is in addition to the RSO for the license; (2) maintain its established New Product Introduction/Product Lifecycle Management (NPI/PLM) process; (3) issue a letter from the Compliance Manager to the President, Vice Presidents, and the Directors who report to the Vice President for Operations and Procurement, to ensure awareness of the violations and actions taken; (4) issue a communication to foreign suppliers of lighting products to Harman to promote awareness of the NRC requirements; (5) conduct training for the participants in the NPI/PLM process; (6) continue to conduct training for all employees handling radioactive material; (7) perform an annual audit to ensure compliance with NRC requirements beginning in calendar year 2020; and (8) conduct an audit using an independent third-party consultant to evaluate compliance with NRC requirement. Additionally, Harman agrees to pay a civil penalty of $7,250 (half the base for a Severity Level III problem). In consideration of the co

## Source
- [Full enforcement letter (PDF)](https://www.nrc.gov/docs/ML1824/ML18241A222.pdf)
- [NRC Materials Licensees index](https://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/materials/)
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