The Chief Counsel found that Smith's NDT Services, Inc., committed four violations of the HMR, including offering in transportation and transporting in commerce a hazardous material, Radioactive material, special form, n.o.s., 7, UN 2974, (1) while failing to use the required protective overpack, thereby creating an unauthorized packaging; (2) without holding a valid NRC approval certificate; (3) when hazmat employees were not trained as required and records of training were not created and retained; and (4) without preparing the correct hazmat shipping paper. The Order assessed a civil penalty of $12,050 after making minor reductions for the company's small size, financial condition and corrective actions.