ML20135G715

Stingray Pressure Pumping, Llc., NRC Form 591M Parts 1, 2, & 3, Inspection Report 15000034/2020001(DNMS)

ML20135G715
Person / Time
Site:	15000034
Issue date:	01/08/2020
From:	O'Dowd D NRC/RGN-III
To:	Schrock J Stingray Pressure Pumping
References
IR 2020001
Download: ML20135G715 (6)

See also: IR 015000034/2020001

Text

U.S. NUCLEAR REGULATORY COMMISSION

NRC FORM 591M PART 3

(07-2012)

10 CFR 2.201

Docket File Information

SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION

1. LICENSEE/LOCATION INSPECTED:

2. NRC/REGIONAL OFFICE

REPORT NUMBER(S)

3. DOCKET NUMBER(S)

4. LICENSE NUMBER(S)

5. DATE(S) OF INSPECTION

SUPPLEMENTAL INSPECTION INFORMATION

1. PROGRAM CODE(S)

2. PRIORITY

3. LICENSEE CONTACT

4. TELEPHONE NUMBER

Main Office Inspection

Next Inspection Date:

Field Office Inspection

Temporary Job Site Inspection

PROGRAM SCOPE

6. INSPECTION PROCEDURES USED

7. INSPECTION FOCUS AREAS

NRC FORM 591M PART 3 (07-2012)

Region III

U. S. Nuclear Regulatory Commission

2443 Warrenville Road, Suite 210

Lisle, IL 60532-4352

2020001

150-00034

OH-31210990019

Stingray Pressure Pumping, LLC

42739 National Road

Belmont, OH 43718

This was an in-office review of an oilfield services company authorized to possess Cs-137 in Thermo Scientific SGD-O

Model 5190 and 5192 Series gauges at its facility in Belmont, Ohio, and at temporary job sites anywhere within the State

of Ohio. During the period of the in-office review, the individual named on the license as RSO left employment with the

company (in April 2020), and was replaced by an Acting RSO, who also serves as the RSO under the company's

radioactive materials license issued by the State of Oklahoma. The licensee has submitted an amendment request to the

Ohio Radiation Control Program (RCP) for this individual to be the new RSO. In addition, the individual currently

named on the Ohio materials license as Assistant RSO remains in that position.

On January 8, 2020, the inspector was contacted by the licensee's Radiation Safety Officer (RSO) with a request for

reciprocity, and informing the NRC that work had been conducted during the previous days prior to the call. During

telephonic conversation with this inspector, the RSO explained that he had prepared the paperwork at the end of the year,

but due to a sudden and unexpected emergency medical situation involving a family member, had failed to submit the

paperwork prior to his attending to the situation. Due to the situation, the RSO was out of the office over the course of

several weeks. He notified the NRC upon his return, realizing that licensed activities had already commenced prior to

his return. Although the licensee did have an Assistant RSO who carried out the duties and functions of RSO while the

RSO was away, so as to ensure that licensed activities were conducted safely, the Assistant RSO, as well as company

management, was not made aware that NRC Form 241 reciprocity notification had not been submitted to the NRC

Region III office for authorization to work under reciprocity into calendar year 2020. The company had previously

worked under reciprocity in NRC jurisdiction, specifically, in West Virginia, a non-Agreement State, in calendar year

2019, up to December 31, 2019.

(cont'd. on next page)

87124

03.01, 03,06, and 03.07

03121

5

Jamie Schrock, Acting RSO

(405) 403-5113

No Change

Remote telephonic in-office review only

01/08/2020, with in-office

review through 04/24/2020

U.S. NUCLEAR REGULATORY COMMISSION

NRC FORM 591M PART 3

(07-2012)

10 CFR 2.201

Docket File Information

SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION

1. LICENSEE/LOCATION INSPECTED:

2. NRC/REGIONAL OFFICE

REPORT NUMBER(S)

3. DOCKET NUMBER(S)

4. LICENSE NUMBER(S)

5. DATE(S) OF INSPECTION

SUPPLEMENTAL INSPECTION INFORMATION

1. PROGRAM CODE(S)

2. PRIORITY

3. LICENSEE CONTACT

4. TELEPHONE NUMBER

Main Office Inspection

Next Inspection Date:

Field Office Inspection

Temporary Job Site Inspection

PROGRAM SCOPE

6. INSPECTION PROCEDURES USED

7. INSPECTION FOCUS AREAS

NRC FORM 591M PART 3 (07-2012)

Region III

U. S. Nuclear Regulatory Commission

2443 Warrenville Road, Suite 210

Lisle, IL 60532-4352

2020001

OH-31210990019

01/08/2020, with in-office

review through 04/24/2020

Stingray Pressure Pumping, LLC

42739 National Road

Belmont, OH 43718

As immediate corrective action, the licensee filed a properly completed NRC Form 241, "Report of Proposed Activities

in Non-Agreement States," with the NRC Region III office, for the previous 6 days through January 27, 2020.

Corrective actions to prevent future violations included improved communications internally within the company's

District Office in Ohio, as well as communications among all of the company's District Offices. The licensee utilized a

bulletin board in all of its District Offices indicating where work under reciprocity was being conducted. Also posted

were reminders to file all required documents with the NRC. In addition, a notice was issued company-wide by the

company's Ohio District Manager reminding supervising staff, RSOs, and Assistant RSOs to track all reciprocity

activities, including required filings, more carefully.

In addition to the telephone conference on January 8, 2020, and several subsequent telephone conversations with the

RSO, the Ohio Radiation Control Program, and the current Acting RSO, the inspector performed additional in-office

review, including review of all documentation relevant to this case.

An exit meeting was conducted by telephone on April 24, 2020.

This violation is considered a Severity Level IV violation because (1) the licensed activity is designated as NRC

Priority 5 as identified in NRC Manual Chapter 2800; (2) the licensee has not previously violated the requirement; (3)

the facts of the specific case would not have resulted in the NRC conducting an onsite inspection; and (4) the

circumstances of the case generally include the failure to provide an initial Form 241 for work of very limited scope

and single occurrence of a few days within NRC jurisdiction.

87124

03.01, 03,06, and 03.07

03121

5

Jamie Schrock, Acting RSO

(405) 403-5113

No Change

Remote telephonic in-office review only

150-00034

1

O'Dowd, Dennis

From:

Jamie Schrock <jschrock@stingraypp.com>

Sent:

Tuesday, May 12, 2020 9:45 AM

To:

O'Dowd, Dennis

Subject:

[External_Sender] RE: [External] Transmittal of Inspection Report Form 591M and Request for

Signature/Date and Return

Attachments:

Stingray 591M Signed.pdf

Follow Up Flag:

Follow up

Flag Status:

Flagged

Mr.ODowd,

Pleaseseeattachedsigned591Mform.

Thanks,

Jamie

From:O'Dowd,Dennis[1]

Sent:Tuesday,May12,20208:22AM

To:JamieSchrock<jschrock@stingraypp.com>

Subject:[External]TransmittalofInspectionReportForm591MandRequestforSignature/DateandReturn

[**EXTERNAL EMAIL**]

Mr.JamieSchrock

ElectronicsSupervisor,RSO

StingrayPressurePumping

10920NW10thYukon,OK73099

DearMr.Schrock:

PleasefindattachedaForm591M(Parts1and2),SafetyInspectionReportandComplianceInspection,signedbyme

andMr.MichaelKunowski,Chief,MaterialsInspectionBranch,DivisionofNuclearMaterialsSafety,U.S.Nuclear

RegulatoryCommission(NRC),RegionIII,issuedinresponsetoourinofficereviewofthecircumstancesregarding

certainactivitiesthatwereconductedinNRCjurisdiction,specifically,inWestVirginia,anonAgreementState,for

severaldaysatthebeginningofJanuary2020,priortoStingrayPressurePumpingsfilingforreciprocityunderTitle10,

CodeofFederalRegulations(CFR),Section150.20.

AnexitmeetingwasconductedbytelephonewithyouonApril24,2020,todiscussthefindings.TheenclosedForm

591M(Parts1and2)inspectionreportpresentstheresultsoftheinofficereview.

Basedontheresultsofthisinofficereview,theNRChasdeterminedthataSeverityLevelIVviolationofNRC

requirementsoccurred.TheviolationwasevaluatedinaccordancewiththeNRCEnforcementPolicy.TheNRCisciting

theviolationintheenclosedForm591Mbecausetheviolationwasnotidentifiedbyyou,thelicensee,butbroughtto

yourattentionbyofficialsatthesite.TheNRChasconcludedthatinformationregardingthereasonfortheviolation,

thecorrectiveactionstakenandplannedtocorrecttheviolationandpreventrecurrence,andthedatewhenfull

2

compliancewillbeachievedisalreadyadequatelyaddressedinthenarrativeontheform,andtherefore,noresponseis

requested.

Atthistime,Iaskthatthattherowentitled,LicenseesRepresentativebecompleted,eitherbyyou,orbyyoursenior

managementatyourOhioDistrictOffice,toincludetheprintedname,signature,anddate,andreturntomeviaemail

thescannedpages1&2ofthecompletedForm591Mwithname,signatureanddateadded.Thisdocumentsyour

commitmentsthatcorrectiveactionshavebeenorwillbeperformedasdescribedinthecitation.

Shouldyouhaveanyquestionsregardingthisoranyotherrelatedmatter,pleasefeelfreetocontactmeatthe

telephonenumberbelow.Thankyouverymuchforyourcooperationduringthisinofficereview.

DennisP.ODowd

HealthPhysicist

MaterialsInspectionBranch

DivisionofNuclearMaterialsSafety

U.S.NuclearRegulatoryCommission

2443WarrenvilleRoad

Lisle,IL60532

dennis.o'dowd@nrc.gov

630.829.9573(office)

630.515.1259(fax)