ML20135G715
| 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
NRC FORM 591M PART 3 U.S. NUCLEAR REGULATORY COMMISSION
(07-2012)
10 CFR 2.201 Docket File Information
SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION
1. LICENSEE/LOCATION INSPECTED: 2. NRC/REGIONAL OFFICE
Stingray Pressure Pumping, LLC Region III
42739 National Road U. S. Nuclear Regulatory Commission
Belmont, OH 43718 2443 Warrenville Road, Suite 210
Lisle, IL 60532-4352
REPORT NUMBER(S) 2020001
3. DOCKET NUMBER(S) 4. LICENSE NUMBER(S) 5. DATE(S) OF INSPECTION
01/08/2020, with in-office
150-00034 OH-31210990019
review through 04/24/2020
6. INSPECTION PROCEDURES USED 7. INSPECTION FOCUS AREAS
87124 03.01, 03,06, and 03.07
SUPPLEMENTAL INSPECTION INFORMATION
1. PROGRAM CODE(S) 2. PRIORITY 3. LICENSEE CONTACT 4. TELEPHONE NUMBER
03121 5 Jamie Schrock, Acting RSO (405) 403-5113
Main Office Inspection Next Inspection Date: No Change
Field Office Inspection Remote telephonic in-office review only
Temporary Job Site Inspection
PROGRAM SCOPE
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)
NRC FORM 591M PART 3 (07-2012)
NRC FORM 591M PART 3 U.S. NUCLEAR REGULATORY COMMISSION
(07-2012)
10 CFR 2.201 Docket File Information
SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION
1. LICENSEE/LOCATION INSPECTED: 2. NRC/REGIONAL OFFICE
Stingray Pressure Pumping, LLC Region III
42739 National Road U. S. Nuclear Regulatory Commission
Belmont, OH 43718 2443 Warrenville Road, Suite 210
Lisle, IL 60532-4352
REPORT NUMBER(S) 2020001
3. DOCKET NUMBER(S) 4. LICENSE NUMBER(S) 5. DATE(S) OF INSPECTION
01/08/2020, with in-office
150-00034 OH-31210990019
review through 04/24/2020
6. INSPECTION PROCEDURES USED 7. INSPECTION FOCUS AREAS
87124 03.01, 03,06, and 03.07
SUPPLEMENTAL INSPECTION INFORMATION
1. PROGRAM CODE(S) 2. PRIORITY 3. LICENSEE CONTACT 4. TELEPHONE NUMBER
03121 5 Jamie Schrock, Acting RSO (405) 403-5113
Main Office Inspection Next Inspection Date: No Change
Field Office Inspection Remote telephonic in-office review only
Temporary Job Site Inspection
PROGRAM SCOPE
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.
NRC FORM 591M PART 3 (07-2012)
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,
Please see attached signed 591M form.
Thanks,
Jamie
From: O'Dowd, Dennis [1]
Sent: Tuesday, May 12, 2020 8:22 AM
To: Jamie Schrock <jschrock@stingraypp.com>
Subject: [External] Transmittal of Inspection Report Form 591M and Request for Signature/Date and Return
[**EXTERNAL EMAIL**]
Mr. Jamie Schrock
Electronics Supervisor, RSO
Stingray Pressure Pumping
10920 NW 10th Yukon, OK 73099
Dear Mr. Schrock:
Please find attached a Form 591M (Parts 1 and 2), Safety Inspection Report and Compliance Inspection, signed by me
and Mr. Michael Kunowski, Chief, Materials Inspection Branch, Division of Nuclear Materials Safety, U.S. Nuclear
Regulatory Commission (NRC), Region III, issued in response to our inoffice review of the circumstances regarding
certain activities that were conducted in NRC jurisdiction, specifically, in West Virginia, a nonAgreement State, for
several days at the beginning of January 2020, prior to Stingray Pressure Pumpings filing for reciprocity under Title 10,
Code of Federal Regulations (CFR), Section 150.20.
An exit meeting was conducted by telephone with you on April 24, 2020, to discuss the findings. The enclosed Form
591M (Parts 1 and 2) inspection report presents the results of the inoffice review.
Based on the results of this inoffice review, the NRC has determined that a Severity Level IV violation of NRC
requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The NRC is citing
the violation in the enclosed Form 591M because the violation was not identified by you, the licensee, but brought to
your attention by officials at the site. The NRC has concluded that information regarding the reason for the violation,
the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full
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compliance will be achieved is already adequately addressed in the narrative on the form, and therefore, no response is
requested.
At this time, I ask that that the row entitled, Licensees Representative be completed, either by you, or by your senior
management at your Ohio District Office, to include the printed name, signature, and date, and return to me via email
the scanned pages 1 & 2 of the completed Form 591M with name, signature and date added. This documents your
commitments that corrective actions have been or will be performed as described in the citation.
Should you have any questions regarding this or any other related matter, please feel free to contact me at the
telephone number below. Thank you very much for your cooperation during this inoffice review.
Dennis P. ODowd
Health Physicist
Materials Inspection Branch
Division of Nuclear Materials Safety
U.S. Nuclear Regulatory Commission
2443 Warrenville Road
Lisle, IL 60532
dennis.o'dowd@nrc.gov
630.829.9573 (office)
630.515.1259 (fax)
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