1. SRS TCAP Preliminary Results & Lessons Learned
Kevin Coley, DSL
Lead, Hazardous Materials Transportation
CTMA 2017
May 25, 2017

2. TCAP Preliminary Results & Lessons Learned
Transportation Compliance Assessment Program (TCAP) was conducted at SRS from May 8 – 11, 2017
Three contractors assessed:
M&O Contractor – Savannah River Nuclear Solutions (SRNS)
Liquid Waste Contractor – Savannah River Remediation (SRR)
Security Contractor – Centerra – SRS

3. Assessment Team TCAP Preliminary Results & Lessons Learned Checklist #
Scope
TCAP Assessor 1
General Management of Transportation and Packaging Programs
Prakash Kunjeer 2
Hazardous & Radioactive Materials Packaging
Mark Hawk 3
Hazardous & Radioactive Materials Shipper
Tammy Pressnell 4
Transportation Management Operations
Randy Dillon 5
Motor Carrier Operations 6
On-Site Railroad Operations 7
Emergency Response
Ellen Edge 8
Hazmat Employee Training 9
Transportation Security Plan

4. TCAP Preliminary Results & Lessons Learned
SRNS and SRR follow SRNS procedures and policies for all packaging and transportation activities; therefore, some of the discussion and findings will be repeated in both contractor reports but addressed in the SRNS close out presentation.
PERFORMANCE CRITERIA
Best Practices: Activities and practices that demonstrate gains in effectiveness and/or efficiency in the areas of safety, compliance, cost and/or mission milestones. These practices may be shared with other sites as lessons learned and opportunities for improvement.
Findings: Concerns that are categorized based on the severity level as defined below, and require corrective active actions.
Level 1 - Practices and/or procedures that are considered to pose an imminent danger or significant safety hazard to workers, the public or the environment. The lead DOE site representative is authorized to issue a “stop work” order for these conditions

5. TCAP Preliminary Results & Lessons Learned – Performance Criteria
Level 2 - Practices and/or procedures that are considered to be in violation of federal regulations, DOE Orders, or other applicable regulatory and policy requirements. These findings indicate a systemic issue or that a management system is not in control.
Level 3 - Practices and/or procedures that are considered to be in violation of federal regulations, DOE Orders, or other applicable regulatory and policy requirements; but where it can be demonstrated that a systemic issue does not exist, or that management systems are in control.
Observation: Practices and/or procedures that are not considered to be in violation of federal regulations, DOE Orders, or other applicable regulatory and policy requirements; however, if no remedial actions are taken could potentially result in a violation.
Opportunity for Improvement: Operational improvements suggested by subject matter experts (SMEs) or the TCAP Team based on recognized practices at other DOE sites or in the private sector that could be used to assist the contractor in enhancing its packaging and transportation (P&T) operations. Adopting such suggestions is at the sole discretion of the site or contractor.

6. TCAP Preliminary Results & Lessons Learned – Results
Best Management Practices
SRNS uses Specification to cover design, fabrication, assembly, inspection, test and delivery of metal containers Types IP-1 and IP-2.  The uniqueness of the specification is that it is structured to provide variances in box design features and options that are communicated to the supplier and an attachment features a template which is completed for each box order which is made as an attachment to the requisition/purchase order.
SRNS has a strong P&T Services team with exceptional attention to regulatory compliance and DOT hazmat shipping processes. The team demonstrated a process that effectively covered the identification, classification, control, communicate, and containment process.

7. TCAP Preliminary Results & Lessons Learned – Results
Best Management Practices
Each position has a series of training qualifications that are assigned to it.  Employees receive notices at 30, 60, and 90 days before their training deadlines.  Documentation for training is sent to a central records center.  The records center was able to pull hard-copy files in two hours or less.  Online training history for each employee are accessible to everyone with a SRNS login.

8. TCAP Preliminary Results & Lessons Learned – Findings
Checklist 1 – General Management of Transportation & Packaging Programs
Level 2:
Roles and responsibilities are defined less than adequate in some of the procedures reviewed.  (i.e. receipt inspections, motor carrier operations, hazmat training)
Checklist 4 – Transportation Management Operations
Shipment Procedures-Inbound:   SRNS Procedure D4 TA-108, requires that inbound shipments received, are inspected for damages or loss and evidence of leakage.  Three claim files were reviewed for completeness. One of the claims was for Claim Number in the amount of$17,   Claim number in the amount of  $ and Claim Number in the amount of $10, All three claims were denied by the carrier due to the inbound receipt/bill of lading contained no notation of damage upon receipt.  Pictures contained in the files showed evidence of obvious damage but due to no notation on the delivery documents, there was no way to prove that the damage occurred during shipment.

9. TCAP Preliminary Results & Lessons Learned – Findings
Checklist 5 – Motor Carrier Operations
Level 2:
49 CFR (a). An employer shall prepare and maintain a summary of the results of its alcohol and controlled substances testing programs performed under this part during the previous calendar year,  when requested by the Secretary of Transportation,  any DOT agency,  or any State or Local officials with regulatory authority over the employer or any of its drivers. The required amount of controlled substance testing for 2015 based on 144 Drivers was 72. The number of random tests performed was 70  which fell 2 tests short of meeting the minimum.

10. TCAP Preliminary Results & Lessons Learned – Findings
Checklist 5 – Motor Carrier Operations
Level 2:
49 CFR (e) states that " A Service agent (e.g., Consortium/third party administrator as defined in 49 CFR ) may prepare the MIS report on behalf of the employer.  However, a company official (e.g., Designated Employer Representative) must certify the accuracy and completeness of the MIS report, no matter who prepares it."  The MIS report from 2015 was not signed and dated to certify the accuracy and completeness.
Currently no report for 2016 has been prepared as of this writing.  SRNS designated a new Designated Employer Representative (DER) on March 15, 2017 and working on getting a 2016 report completed and certified.  However, due to workload she has not been able to complete and certify the report.

11. TCAP Preliminary Results & Lessons Learned – Findings
Checklist 5 – Motor Carrier Operations
Level 2:
49 CFR (B) (4) Condition, location, and mounting states "The fire extinguisher(s) must be filled and located so that it is readily accessible for use.  The extinguisher(s) must be securely mounted to prevent sliding, rolling, or vertical movement relative to the motor vehicle."  The Fire Extinguisher in vehicle number G K was not secure and the mounting device would not securely latch around the extinguisher.
Checklist 8 – Hazmat Employee Training
For the online HazMat training, the recordkeeping requirements for 49 CFR (d) in that the Qualification Report does not explicitly include:
a description, copy, or the location of the training materials used to meet the requirements in paragraph (a) of this section
The name and address of the person providing the training
Certification that the hazmat employee has been trained and tested, as required by this subpart.
Corrected on the Spot (COS)

12. TCAP Preliminary Results & Lessons Learned – Results
The following subject areas did not have findings:
Checklist 2 – Hazardous & Radioactive Materials Packaging
Checklist 3 – Hazardous Material Shippers
Checklist 7 – Transportation Emergency Response
Checklist 9 – Transportation Security Plan
The following subject areas was still being reviewed at the time of the Close-Out
Checklist 6 – On-Site Railroad Operations

13. TCAP Preliminary Results & Lessons Learned - Questions