SRS TCAP Preliminary Results & Lessons Learned

TCAP 2017

Kevin Coley, DSLLead, Hazardous Materials Transportation

CTMA 2017May 25, 2017

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

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TCAP Preliminary Results & Lessons Learned

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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 Randy Dillon

6 On-Site Railroad Operations Randy Dillon

7 Emergency Response Ellen Edge

8 Hazmat Employee Training Ellen Edge

9 Transportation Security Plan Mark Hawk

Assessment Team

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

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TCAP Preliminary Results & Lessons Learned – Performance Criteria

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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.

TCAP Preliminary Results & Lessons Learned – Results

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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.

TCAP Preliminary Results & Lessons Learned – Results

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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.

TCAP Preliminary Results & Lessons Learned – Findings

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Checklist 1 – General Management of Transportation & Packaging ProgramsLevel 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 OperationsLevel 2:Shipment Procedures-Inbound: SRNS Procedure D4 TA-108, 5.1.8 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 248658 in the amount of$17,313.50. Claim number 155352 in the amount of $531.90 and Claim Number 205641 in the amount of $10,938.43. 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.

TCAP Preliminary Results & Lessons Learned – Findings

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Checklist 5 – Motor Carrier OperationsLevel 2:49 CFR 382.403 (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.

TCAP Preliminary Results & Lessons Learned – Findings

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Checklist 5 – Motor Carrier OperationsLevel 2:49 CFR 382.403 (e) states that " A Service agent (e.g., Consortium/third party administrator as defined in 49 CFR 382.107) 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.

TCAP Preliminary Results & Lessons Learned – Findings

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Checklist 5 – Motor Carrier OperationsLevel 2:49 CFR 393.95 (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 G82 0153K was not secure and the mounting device would not securely latch around the extinguisher.

Checklist 8 – Hazmat Employee TrainingLevel 2:For the online HazMat training, the recordkeeping requirements for 49 CFR 172.704(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)

TCAP Preliminary Results & Lessons Learned – Results

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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

TCAP Preliminary Results & Lessons Learned - Questions

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