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NRC NOV – NOV (SL III, IV)

EA-21-102 · NOV · Severity SLIII · Issued 2021-11-26 · Materials Licensees

Action

EA Number
EA-21-102
Licensee
NOV (SL III, IV)
Category
Materials Licensees
Action type
NOV
Severity level
SLIII
Date issued
2021-11-26

Description

On November 26, 2021, the NRC issued a Notice of Violation to BRL-NDT Services, LLC for three violations. The violations consist of a Severity Level (SL) III problem associated with two (A+B) related violations and one SL IV violation (C). Based on the information develop during the inspection and the information provided by the licensee in response to the inspection report dated September 15, 2021, the NRC determined that three violations of NRC requirements occurred. The violations include: (A) permitting an individual who had not completed qualification requirements to act as a radiographer’s assistant contrary to Title 10 of the Code of Federal Regulations (10 CFR) 10 CFR 34.43(c), (B) performing radiographic operations without two qualified individuals present contrary to 10 CFR 34.41(a), and (C) failing to conduct an inspection program of the job performance of a radiographer during an actual industrial radiographic operation every 6 months contrary to 10 CFR 34.43(e)(1). The NRC considers Violations A and B to be significant violations because the failure to have a fully qualified radiographer’s assistant and the failure to have two qualified individuals present during industrial radiographic operations could have resulted in an overexposure to the radiographers or a member of the public. Therefore, these violations are categorized collectively in accordance with the NRC Enforcement Policy Section 6.3.c as a Severity Level III problem. Violation C was issued as a Severity Level IV violation in accordance with NRC Enforcement Policy 6.3.d.3.

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