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COMMERCIAL VEHICLE SAFETY ALLIANCE/ U.S. DEPARTMENT OF ENERGY UPDATE ON WIPP SHIPMENTS

April 2005

For information concerning this report contact Commercial Vehicle Safety Alliance

1101 17P

thP Street, N.W., Suite 803

Washington, DC 20036 Phone: (202) 775-1623 Fax: (202) 775-1624

HTUwww.cvsa.orgUTH

Introduction The Commercial Vehicle Safety Alliance (CVSA), a nonprofit organization of federal, state, and provincial government agencies and representatives from private industry in the United States, Canada and Mexico, is dedicated to improving commercial vehicle safety. The Alliance is comprised of all 50 states, two U.S. territories, twelve Canadian provinces and territories and Mexico. The member agencies include state police, highway patrols, public service and utility commissions, departments of transportation, motor vehicle and public safety departments, Canadian provincial governments, the Mexican government and supporting groups such as the U.S. Department of Transportation (DOT), the U.S. Department of Energy (DOE), Canadian Transport Officials and more than 500 associate industry members. CVSA serves as the major focal point for bringing state/provincial officials together with the truck/bus industries and federal governments in a unique discussion and problem-solving interchange. Member agencies sign a Memorandum of Understanding (MOU) and recognize and agree to uniform inspection standards and procedures as developed by CVSA. One of MOU’s significant elements is a reciprocity agreement to honor inspections conducted by member agencies that are authorized to affix the CVSA decal. The CVSA/DOE Cooperative Agreement In 1986, the DOE Office of Civilian Radioactive Waste Management (OCRWM) asked CVSA to enter into a cooperative agreement to develop inspection standards for transporting radioactive materials. This standard became known as the Enhanced North American Standard (ENAS) Inspection for Radioactive Materials or CVSA Level VI inspection program. OCRWM extended the agreement to conduct a pilot study to evaluate the soundness of the procedures, develop training curricula, conduct training, perform inspections and generate statistical data on the inspections. A final report on this phase of the Cooperative Agreement, including the Pilot Study, was issued in October 1999. The Cooperative Agreement continues to be extended and funded by DOE to provide inspector and industry training, compile and analyze inspection data and continue the CVSA Level VI inspection program. CVSA/DOE Cooperative Agreement Interim Report and Updates After three years, the CVSA/DOE Cooperative Agreement Interim Report (Interim Report) was published in October 2002. This Interim Report updated the progress of the program through September 2002 and it may be obtained from CVSA’s website at www.cvsa.org. An in-depth analysis of the Interim Report’s data on the Waste Isolation Pilot Plant (WIPP) was completed in April 2004. This analysis, titled CVSA/DOE Cooperative

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Agreement Interim Report – Update on WIPP Shipments (April 2004) also may be obtained from CVSA’s website. CVSA and DOE made a decision to update the program’s progress based on feedback that an update was desired. This report reviews data from October 1, 2002 to December 31, 2004. Number of Shipments Table 1 identifies the number and type of inspections by state. A total of 3,980 state inspection forms were received from the states during this time period. The largest number of point of origin inspections occurred in Colorado with 1,179 while the largest number of en route inspections occurred in New Mexico with 1,829.

Table 1. WIPP Shipments: Number and type of inspections by state (October 1, 2002 – December 31, 2004)

State Point of Origin

En Route Total

Colorado 1,179 271 1,450 Idaho 149 149 Illinois 8 8 New Mexico 43 1829 1872 South Carolina 435 435 Washington/Oregon 66 66 Total Number of Inspections

1880 2100 3980

Number of Violations Table 2 identifies the number and type of violations found by state. The first column shows the number of inspections identifying violations and the second column shows the number of violations identified during those inspections. The other columns show the number of out-of-service violations and how many were not out-of-service violations. A total of 262 inspections identified 302 violations during this time frame. Of those 302 violations 51 were CVSA Level I out-of-service violations and 52 were CVSA Level VI out-of-service violations.

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Table 2. WIPP Shipments: Number and type of violation found listed by state and type of inspection (October 1, 2002 – December 31, 2004)

Out-of-Service Violations

State/Type of Inspection

No. of UInspectionsU Identifying Violations

No. of UViolationsU

Identified

NOT Out-of-Service Violations Level I Level VI Total

UColoradoU Point of Origin 60 65 29 19 17 36 En Route 44 50 36 10 4 14 UIdahoU Point of Origin 49 63 52 4 7 11 UIllinoisU Point of Origin 4 4 1 2 1 3 UNew MexicoU Point of Origin 6 6 4 1 1 2 En Route 79 90 62 13 15 28 USouth CarolinaU Point of Origin 15 18 15 2 1 3 UWashington/OregonU Point of Origin 5 6 0 0 6 6 Total 262 302 199 51 52 103

Percentage of Inspections with No Violations and Violations Table 3 shows the percentage of inspections having no violations or violations listed by state and type of inspection. The highest percentages of violations are for point of origin inspections in Illinois and Idaho in which 50% and 32.89%, respectively, of those inspections found a violation. The lowest percentage of violations is for point of origin inspections in South Carolina in which only 3.45% of those inspections found a violation. New Mexico completed the most en route inspections and 95.68% of those inspections had no violations. Colorado completed the most point of origin inspections and 94.91% of those inspections had no violations.

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Table 3: WIPP Shipments: Percentage of inspections having no violation or violations listed by state and type of inspection

(October 1, 2002 – December 31, 2004)

State/Type of Inspection Number of Inspections NO Violations Violations

UColoradoU Point of Origin 1,179 94.91% 5.09% En Route 271 83.76% 16.24% UIdahoU Point of Origin 149 67.11% 32.89% UIllinoisU Point of Origin 8 50.00% 50.00% UNew MexicoU Point of Origin 43 86.05% 13.95% En Route 1,829 95.68% 4.32% USouth CarolinaU Point of Origin 435 96.55% 3.45% UWashington/OregonU Point of Origin 66 92.42% 7.58% Percentage of Point of Origin and En Route Inspections with No Violations and Violations Table 4 shows the overall percentage of inspections having no violations and violations at the point of origin and en route. One goal of the CVSA Level VI inspection program is to find any violation during the point of origin inspection. During this time period point of origin inspections found the most violations.

Table 4. WIPP Shipments: Percentage of point of origin and en route inspections with no violation and with violations

(October 1, 2002 – December 31, 2004)

Inspection Location Number of Inspections

NO Violations Violations

Point of Origin 1,880 92.61% 7.39%

En Route 2,100 94.14% 5.86%

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Understanding Differences between CVSA Level I and CVSA Level VI Inspections The April 2004 report discussed the difference between CVSA Level I and Level VI inspection violations. Even after that discussion, misinformation still exits. Some still believe a CVSA Level VI violation is the more serious violation found during a CVSA Level VI inspection, which is not the case. A CVSA Level I violation is the more serious violation found during a CVSA Level VI inspection. CVSA Level I violations are critical violations known to contribute to accidents. The importance of identifying CVSA Level VI violations is to hold the vehicle and driver to a higher standard, which includes a shipment being “defect free” before leaving the point of origin. An example of the difference in the seriousness of a violation is in the following brake example. The CVSA Level I inspection standard states that if 20% or more of the brakes on the vehicle or combination are out of adjustment, the vehicle is placed out of service. Under a CVSA Level VI inspection, if any brakes are out of adjustment, the vehicle is placed out of service. It is only reasonable to assume that a vehicle with 10 brakes that has two (20%) brakes out of adjustment has a more critical or higher chance of causing an accident compared to the same vehicle having any one brake out of adjustment. The desire by all involved in the WIPP shipping program is to help the public know and understand that much is done to make sure WIPP trucks are safe. For this reason, the dedicated WIPP vehicles and drivers are held to a higher inspection standard at the point of origin. Comparison with Federal Motor Carrier Safety Administration Data Table 5 presents a comparison of CVSA Level VI inspection information reported under the WIPP transportation program from October 1, 2002 through December 30, 2004. When compared to the FMCSA data, the WIPP shipments are considerably safer. Of the 262 WIPP inspections that detected violations, 95 inspections found Level I or Level VI out-of-service violations. Three of the 95 inspections found driver out-of-service violations for a driver out-of-service rate of 0.08%, and 92 of the inspections found vehicle out-of-service violations for a vehicle out-of-service rate of 2.34%. In comparing these out-of-service rates for CVSA Level VI inspections of WIPP shipments to those published by FMCSA in Table 5, it may be concluded that vehicles and drivers subject to point of origin CVSA Level VI inspection criteria are significantly safer than other HAZMAT carriers and other motor carriers traversing the nation’s highways. The CVSA Level VI inspection program assures the motoring public that the vehicles and drivers transporting select radioactive materials are the safest motor carriers on the nation’s highways.

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Table 5. WIPP Shipments: Comparison with FMCSA inspection data FMCSA Roadside Inspection Data for the Year 2003*

FMCSA HAZMAT Inspection Data for the Year 2003*

CVSA Level VI Inspection Data for WIPP Shipments (October 1, 2002 – December 31, 2004)

Inspection Activity

Number Percent Inspection Activity

Number Percent Inspection Activity

Number Percent Level I OOS

Percent

Level VI OOS

PercentNumber of Inspections

3,008,788 Number of Inspections

181,462 Number of Inspections

3,980

With no Violations

811,816 26.98% With no Violations

148,317 81.73% With no Violations

3,718 93.42%

With Violations

2,196,972 73.02% With Violations

33,145 18.27% With Violations

262 6.58%

Driver OOS** Rate

6.77% (Level I

OOS)

Driver OOS Rate

3.18% (Level I OOS)

Driver OOS Rate

0.08% 0.08% 0.00%

Vehicle OOS Rate

22.90% (Level I

OOS)

Vehicle OOS Rate

17.92% (Level I OOS)

Vehicle OOS Rate

2.34% 1.08%

*Data Source: FMCSA Motor Carrier Management Information System December 23, 2004 data snapshot

1.26%

** OOS = Out-of-Service Other Information Other information discovered during the analysis may be of interest:

• The average amount of time for each inspection was one hour and seven minutes. • The data review and report are based on the inspection forms received from the

states by Battelle/CVSA for the period October 1, 2002 – December 31, 2004. Overall CVSA Level VI Program – WIPP Shipments Table 6 is a summary of the Level VI inspections and violations found since the commencement of the WIPP shipments (March 24, 1999) through December 31, 2004. Since March 24, 1999, there have been 6,950 CVSA Level VI inspections analyzed. Of these inspections, almost 93% found no violation. The CVSA inspection program continues to find fewer violations and even fewer out-of-service violations. The Level I and Level VI combined out-of-service rate for vehicles is 2.5% and 0.1% for drivers. Most notable for the WIPP shipments is that less than 1% of inspections, for both vehicle and driver, find CVSA Level I out-of-service violations (that is, the more serious violations). The vehicle and driver combined percentage is also less than 1%. This continued improvement is attributed to the importance DOE and the carriers place on keeping the dedicated equipment maintained and using dedicated high-quality drivers.

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Table 6. Review of entire CVSA Level VI Inspections for WIPP shipments CVSA Level VI Inspection Data for WIPP Shipments

(March 24, 1999 – December 31, 2004) Inspection Activity

Number Percent Level I OOS Percent

Level VI OOS Percent

Number of Inspections

6,950

With no Violations

6,437 92.62%

With Violations 513 7.38%

Driver OOS* Rate

0.10% 0.10% 0.00%

Vehicle OOS Rate

2.50% 0.83% 1.67%

*OOS = Out-of-Service Conclusion The continued ultimate goal of the CVSA Level VI inspection program is the safe and uneventful shipments of radioactive materials from origin to destination. The states, carriers and DOE can be proud of the continued excellent safety program during this period that keeps driver and vehicle out-of-service rates very low. Low out-of-service rates help lead to a low number of incidents. In this time period, one non-chargeable accident and one near miss occurred for the WIPP shipments. The 93.42% of inspections during this time period with no violations shows the determination by the states, carriers, and DOE to continue to improve this program. WIPP shipments continue to be one of the safest commercial truck shipments today. As the data show, the higher percentage of found violations occurs at the point of origin; however, before the shipments leave they must be “defect free.” This high level of safety should continue to be expected and should continue with point of origin CVSA Level VI inspections. In addition, the security risk to the WIPP shipments should be considered with respect to the number of times and the length of time each shipment is stopped en route. CVSA guidelines to its member states are that a shipment inspected to the “defect free” level at origin does not need to be re-inspected to the same degree while en route. Some states are required (either by law or other mandate) to inspect each shipment that enters their states. For these en route states, instead of completing a CVSA Level VI inspection on each shipment, they could choose to complete one of the other CVSA Level inspections and randomly inspect to the CVSA Level VI inspection standard.

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APPENDIX

A

Tractor Violations (arranged by license plate)

Inspection Location Date Violation ID Citation Level VI NAS Violation Description

Tractor 04351 WYRaton New Mexico POE 10/14/2002 393.207F Axle 3, right side, audible air leak rt steel tubing to air bag (at clamp).Rocky Flats 9/10/2003 393.83 X Engine compartment exhaust leak-vehicle fixed at site.

Tractor 04352 WYRaton New Mexico POE 1/27/2003 393.83(g) X Exhaust leak under truck cab and/or sleeper, leak was on tight side of engine at clamp at point forward of the

driver/sleeper compartment.

Tractor 07139 WYRocky Flats 5/29/2003 393.83(g) X Exhaust leak at flex pipe

Tractor 07811 WYRocky Flats 12/12/2002 399.3 X Audible air leak form tractor hose left side suspension - Fixed on scene.Raton New Mexico POE 9/16/2003 393.83(e) X Exhaust leak under cab at 2 locations.

Tractor 07812 WYRaton New Mexico POE 7/16/2003 393.45(a)(4) Brake hose chafing on bracket axle #2 left side.

Tractor 07965 WYRocky Flats 5/15/2003 396.3a1 Fender over axle #3 loose (right side) repaired on inspection.

Tractor 09396 WYLoving Inspection Site 5/11/2004 393.83(e) VW Minor exhaust leak at flex pipe in engine compartment.

Tractor 09607 WY393.75(a)(3) X #3 Axle LS outer tire flat.393.9 RS lower fog light out.

Tractor 09609 WYRocky Flats 9/23/2004 396.3(a)(1) X Audible air leak on fitting, air reservoir, right side, top fitting to hose.

Tractor 09610 WYHanford Site 8/25/2004 393.83G X Exhaust leak.Rocky Flats 9/21/2004 393.207(f) X Air suspension pressure loss (leaking at top fitting) axle #2 left side).

Out-of-Service

Rocky Flats 10/26/2004

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Tractor 09613 WYLoving Inspection Site 4/3/2004 396.3(a)(1) Very slight air leak at equalizer axle 3.Rocky Flats 10/15/2004 393.45 Air leak at coupling - Fixed at scene

Tractor 09616 WYFt. Collins Colorado POE 7/30/2004 393.45(a)(4) Brake hose/tubing chaffing, Axle #2 & #3 Right side.Ft. Collins Colorado POE 8/20/2004 393.45(a)(4) Brake hose/tubing chafing, Axle #2 right side.Savannah River Site 8/30/2004 390.21(a) US DOT number is incorrect. Number displayed is 1064158; should be 064158.

Tractor 14812 WYINEEL 10/6/2002 393.9 Truck rear license plate lamp inoperable.

Tractor 14814 WY396.3(a)(1) X Service side glad hand connection to trailer is leaking air at connection.396.3(a)(1) X Trailer parking brake valve (red button) in cab has an audible air leak when brakes are released.

Tractor 1U0257 OKFt. Collins Colorado POE 10/7/2002 396.3(a)(1) X X Inspection/repair and maintenance air leak at emergency side connection.Ft. Collins Colorado POE 10/13/2002 396.3(a)(1) X X Emergency glad hand connections - audible leak.Savannah River Site 2/12/2003 396.5(b) Oil leak location: left rear of oil pan possible gasket.Savannah River Site 3/3/2003 396.5(b) Oil leak at or near oil filter.INEEL 6/3/2003 392.2 Local laws (general) - Proper paper work (registration for truck and haz/mat endorsement and hazardous waste

permit for Idaho) not carried on vehicle.Ft. Collins Colorado POE 1/17/2004 393.209(e) Power steering violations, fluid seeping/leaking from resv./gear box from fittings or gaskets.

Tractor 1VL136 OKFt. Collins Colorado POE 9/28/2002 396.3(a)(1) X Leaking air at Red glad hand connection (repaired on site).INEEL 4/29/2003 396.5 Dripping oil leak from input seal to steer wheel box.LANL 5/6/2003 393.201(d) Loose bolt at fender bracket left side by axle 2.INEEL 5/13/2003 393.9H X Left low beam headlamp inop. (repaired at scene.)

393.209(e) Power steering violations, fluid leaking from resv./gear box from fittings or gaskets.393.48 X X Oil soaked brake lining into brake drum from power steering leak.

Tractor 1VL144 OKINEEL 10/8/2002 396.3A1B Brakes (general) loose hose clamp axle 2 right side.Loving Inspection Site 11/12/2002 392.2 Local laws (general) Insurance Card Expired.Ft. Collins Colorado POE 8/27/2003 393.207(a) X X Axle positioning parts defective, Loose spring hanger at frame mounting, axle #1 left side steer, (x2).Rocky Flats 10/31/2003 393.209(d) X Steering system interference

Ft. Collins Colorado POE 5/14/2003

9/28/2002

Out-of-Service

INEEL

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Tractor 1VQ262 OKSavannah River Site 8/13/2002 396.5B Oil leak - seal transfer case 2nd axle.

392.2 Local laws (general) Insurance Card Expired on 11/01/02396.5(b) Oil and/or grease leak slight oil leak on oil pan at rear of pan by bolts

Tractor 1VQ263 OKFt. Collins Colorado POE 10/3/2002 393.70 X X Lower coupler bolts missing from left and right side, in combination with cross member located under fifth wheel

Tractor 1VQ264 OKLoving Inspection Site 9/24/2002 393.3(a)(1) Two three inch cracks on fender skirt axle 3 right.INEEL 10/5/2002 392.2 No hazardous waste permit for Idaho.

396.5B Oil leak right rear of oil pan - right side engine block396.5B Oil leak at outline bottom of transmission

Tractor 1VQ265 OKINEEL 9/24/2002 392.2 Current copy of Idaho hazardous materials endorsement not carried.Savannah River Site 8/23/2002 396.3(a)(1) Inspection/repair and maintenance right side of transmission two lines chaffing on tractor frameLoving Inspection Site 3/1/2003 396.5 Excessive oil leaks right side of engine block.Raton New Mexico POE 8/22/2003 396.3(a) Inspection, repair, and maintenance/ oil leak around filter box right side of engine compartment.Savannah River Site 10/1/2003 396.5(b) Fluid leaking from power steering hose. (Repaired on site by Carl's Road Service).Loving Inspection Site 10/9/2003 393.60(b) Damaged windshield on passenger side, 1 1/2 inch chip.Ft. Collins Colorado POE 1/14/2004 393.207(a) X X Axle positioning parts defective. Loose spring hanger at frame mounting. Axle #1 left side steer.

Tractor 1VQ982 OKLoving Inspection Site 11/5/2002 392.2 Expired Insurance Card.INEEL 2/12/2003 392.2 Idaho hazardous material endorsement not carried.Loving Inspection Site 3/1/2003 396.5 Oil leak by pan and oil filterLoving Inspection Site 4/1/2003 393.83(f) Improper exhaust system repair exhaust leak next to engine on right side first clamp.Ft. Collins Colorado POE 4/25/2003 393.207(a) X X Axle positioning parts defective, loose spring hanger at frame mounting. (axle 1 left)INEEL 5/1/2003 393.83(g) X Exhaust leak under cab on right side of engine at clamp.LANL 6/3/2003 393.95F Fire extinguisher not properly secured.

393.201(d) Frame accessories not bolted/riveted securely, Left and right side fenders over drive axles loose at mounting.393.43(a) Improper tractor protection valve, when trailer valve (red), "popped", caused tractor valve (yellow) to activate,

not as required. Yellow valve must stay engaged.Loving Inspection Site 7/26/2003 396.17 Annual inspection expired 6/03.Rocky Flats 11/3/2003 393.28 Improper or no wiring protection as required.Raton New Mexico POE 11/12/2003 396.3(a)(1) X Mismatched brake chambers on axle 5. Left side c-30 right side long stroke 30.Raton New Mexico POE 12/13/2003 393.207(a) X Left front spring rear hanger with lower bolt loose causing washer to be loose.

Raton New Mexico POE 10/12/2002

Loving Inspection Site 11/2/2002


Out-of-Service

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Tractor 1VZ908 OKRaton New Mexico POE 10/19/2002 393.248 X Left low beam headlight inoperativeLoving Inspection Site 2/18/2003 396.5(b) Oil and/or grease leak on oil pan.INEEL 4/10/2003 392.2 Local laws (general) No current Haz. Waste permit for Idaho (purchased and faxed from Inkom POE, prior to

leaving site.)Loving Inspection Site 4/22/2003 396.5 Excessive oil leaks.INEEL 5/8/2003 393.11TL TT lwr rr mud flaps retro sht/reflex mfg>7/97 - truck tractor, right side rear mud flap missing reflective tapeArgone National Laboratory 7/17/2003 393.45(a) Chafing are hose - axle #1 left plastic tie rubbing on fiber hose ties closest to chamber.Ft. Collins Colorado POE 7/18/2003 396.3(a)(1) Inspection/repair and maintenance, Left front, tractor drive axle fender, with broken securement bolt.Raton New Mexico POE 7/18/2003 396.3(a)(1) Inspection/repair and maintenance/ Axle #2 L/S front fender bolt missing fender loose.

Tractor 1XX244 OKINEEL 10/1/2002 396.3a1 X RED air tube with air leak at connectionRaton New Mexico POE 10/21/2002 393.83E X X Exhaust leak below engine, right side at exhaust pipe couplingRaton New Mexico POE 6/21/2003 393.24(b) X Non-compliance with headlamp requirements (right headlamp is inoperable on low beam).Loving Inspection Site 9/13/2003 393.9 X Lamps required to operate tractor.

Tractor 2CC395 OKFt. Collins Colorado POE 5/30/2003 393.45(a)(4) Brake hose/tubing chaffing and/or kinking/axle 2 left side/ on front top left side of differential/ shown to driver.

Tractor 2CC407 OKSavannah River Site 11/25/2002 393.205c X 2nd axle right side 1 of 10 wheel fasteners loose.Rocky Flats 10/28/2003 393.45(a)(4) X Brake hose/tubing chaffing and/or kinking (axle #3 r/s) air leak at fitting.

Tractor 38738 MORaton New Mexico POE 4/12/2004 393.83(g) X Exhaust leak under driver compartment at a clamp.

Tractor 41834 MORaton New Mexico POE 8/23/2004 393.45(a)(4) Brake hose/tubing chaffing and/or kinking (secondary blue brake tubing chaffing on hanger at rear of cab).INEEL 9/19/2004 393.32 Improper electrical connections - truck to trailer electrical pigtail detachable connection at truck end not properly

latched - corrected by driver.

Tractor 43193 MORaton New Mexico POE 3/16/2004 396.3(a)(1) X Inspection/repair and maint parts and accessories (1 fastener on left rear fender is missing causing fender to

contact left rear tire.)

Out-of-Service

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Tractor 43480 MORaton New Mexico POE 3/16/2004 396.3(a)(1) X Inspection/repair and maint parts and accessories (Audible air leak at brake hose connection to relay valve at

axle 3 on right side.INEEL 3/25/2004 107.620(b) No copy of US DOT HM registration number.Ft. Collins Colorado POE 7/10/2004 396.5(b) Oil and/or grease leak. Oil dripping on pavement from under axle #2 differential area.

Tractor 43978 MORocky Flats 3/22/2004 393.207 Air hose to air bag leaking at coupling (Driver fixes on scene-coupling not leaking).

393.19 X Turn signal lights not working on tractor.393.9 X Headlights not working.

Rocky Flats 6/30/2004 393.83(h) Exhaust system not securely fastened (one loose clamp).Raton New Mexico POE 8/26/2004 393.95(a) No/discharge/unsecured fire extinguisher (Fire extinguisher under sleeper compartment was not properly

secured in holder at the time of inspection).

Tractor 93795 MOINEEL 4/24/2003 393.209(d) Steering system components; 1/16 inch free play at front ball joint on drag link.LANL 8/26/2003 393.45 Air leak at relay valve about axle 2 middle.Argone National Laboratory 10/14/2003 393.83(g) X X Exhaust leak under truck cab and/or sleeper: At clap at elbow pipe from engine and at clamp connecting

straight pipe to flex pipe under passenger side of cab.Rocky Flats 5/13/2004 393.83(g) X Exhaust leak under truck cab and/or sleeper.

Tractor 93796 MOFt. Collins Colorado POE 5/28/2003 393.45(a)(4) Brake hose/tubing chaffing and/or kinking; axle 3 right side with service side airline to chamber kinked.Raton New Mexico POE 5/28/2003 393.203(e) Cab front bumper missing/unsecured/protrude 1 of 8 mounting bolts loose and 1 nut missing in front bumper.Ft. Collins Colorado POE 6/28/2003 393.45(a)(4) Brake hose kinking, axle #3, left and right side with pinched service hose to brake chamber, @plastic hose

separator.Hanford Site 9/23/2003 393.75 X Axle 3 R-O 30 PSIArgone National Laboratory 10/14/2003 393.83(g) X Exhaust leak under truck cab and/or sleeper.Ft. Collins Colorado POE 1/17/2004 393.209(e) Power steering violations, fluid seeping/leaking from resv./gear box from fittings or gaskets.Raton New Mexico POE 1/29/2004 393.24(b) X Left headlamp inoperative on low beam.INEEL 7/8/2004 396.11 Driver vehicle inspection report - post trip inspection not documented for 7-7-04Rocky Flats 8/9/2004 393.75(f) Tire-load weight rating/under inflated (AXLE #3 left side) 40 PSI.Ft. Collins Colorado POE 11/10/2004 393.209(e) Power steering violations, Fluid leaking from resv./gear box from fittings, hoses or gaskets.

Tractor 93797 MOFt. Collins Colorado POE 5/31/2003 396.3(a)(1) Inspection/repair and maintenance, cracked weld at left side rear trailer center fender mount.Rocky Flats 3/24/2004 393.45 Air leak at coupling on glad hand hose (Driver tightened coupling on site).Ft. Collins Colorado POE 6/11/2004 393.45 Brake hose/tubing chaffing, Axle #2 left side.GALLUP 8/28/2004 396.3(a)(1) Axle 3 left side wheel seal leaking.


Out-of-Service

Page 5 of 6


Tractor 93798 MOArgone National Laboratory 7/24/2003 393.83(g) X Exhaust leak under sleeper berth/driver compartment.Raton New Mexico POE 11/1/2003 393.201(d) Frame accessories not bolted/riveted securely (1 frame cross member fastener loose under sleeper

compartment, 1 of 10 on cross member.Hanford Site 1/21/2004 393.25(b) X Right tail light inop.Ft. Collins Colorado POE 9/19/2004 396.3(a)(1) Inspection/repair and maint parts and accessories, Air leaking upon brake application @ right rear, under cab at

brass fitting to aluminum valve.Raton New Mexico POE 9/19/2004 396.3(a)(1) Inspection/repair and maint parts and accessories (Audible air leak at valve under sleeper compartment when

the brakes are applied.

Tractor 93799 MOLoving Inspection Site 5/15/2003 393.24(b) VW High beam head lamp inoperable drivers side.LANL 7/8/2003 393.95a VW Unsecured fire extinguisher.Rocky Flats 11/20/2003 Expired insurance card 11/1/03 : Valid proof produced prior to departure.Rocky Flats 5/26/2004 393.207(f) X Air leak at valve.Rocky Flats 8/16/2004 393.47 Inadequate brake lining for safe stopping ( 1/4" crack in lining axle #2 right side).Ft. Collins Colorado POE 9/20/2004 393.207( c) Leaf spring assembly defective, Loose U-bolt at leaf spring assay from spring hanger. Axle #2 left side.

Tractor 99891 MORocky Flats 8/17/2004 393.20 No/improper mounting of clearance lamps (right front light out).

Tractor 99891 MORocky Flats 12/17/2003 393.9H X Inoperable head lamps (left low beam headlamp inoperative).

396.3(a)(1) Inspection/repair and maint parts & accessories left fender rear right bolt loose.396.3(a)(1) Inspection/repair and maint parts & accessories right fender rear left side loose bolt.396.3(a)(1) Leaking Anti-Freeze from radiator (bottom).

Rocky Flats 4/20/2004 395.3 Co-Driver 14 hr violation 4-17-04 0715 to 0815 hrs.INEEL 6/17/2004 393.45(a)(4) Brake hose/tubing chaffing right side axle 3 brake can hose(s) chaffing fixed on scene.

GALLUP 1/8/2004

Out-of-Service

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APPENDIX

B

Trailer Violations (arranged by license plate)


Trailer E201205 USRocky Flats 4/8/2003 396.3(a)(1) X Audible air leak at fitting.

Trailer E201207 USRaton New Mexico POE 8/19/2004 393.201(d) Frame accessories not bolted/riveted securely, (Right rear fender bracket has two loose fasteners).

Trailer E201208 USRocky Flats 2/18/2003 172.203(D)(4) Activity of labels inaccurate - replaced with correct labels.Rocky Flats 4/9/2003 396.3(a)(1) X Audible air leak at a proper fitting.

Trailer E201210 USRaton New Mexico POE 9/4/2003 393.100(a) X The gap between the trailer locking plate and the compression plate exceeds the required gap on 2 tie down

assemblies measured with the gap device. No. 1 trupact right side rear and no. 2 trupact left side front.Rocky Flats 11/5/2004 393.100(a) No or improper load securement (locking pin clip will not engage or close fully).

Trailer E201212 USSavannah River Site 7/14/2004 393.75(a)(4) X Right inside tire on axle four (4) cut next to rim exposing steel belt material.

Trailer E201214 USRocky Flats 10/6/2003 393.40 #5 R.R. Axel Jam nut loose.

Trailer E201216 USRocky Flats 11/5/2003 396.3(a)(1) X Audible air leak at fitting axle #5 r/s.Rocky Flats 1/9/2004 393.100(a) X No or improper load securement (#2 Trupact, left front tie down loose.)Raton New Mexico POE 1/9/2004 396.3(a)(1) X Service line has an audible leak at other than a proper connection.Raton New Mexico POE 3/10/2004 393.104(f)(3) X Loose/unfastened tie down. One of four securement devices loose on Trupact #205.Raton New Mexico POE 7/28/2004 393.201(d) Frame accessories not bolted/riveted securely, (Left rear fender bracket has 2 fasteners loose).

Trailer E201217 USFt. Collins Colorado POE 10/3/2003 393.100(e) Improper securement of intermodal containers, FMCSR 393.106(B), 393.100(E), 393.104(C), 392.9(a)(1).

CASK #180 right, #151 right w. loose u-bolts at anchor points.Rocky Flats 12/17/2003 393.100(a) X No or improper load securement - right rear tie down loose on #2 an #3 trupact.

Trailer E201219 USRaton New Mexico POE 1/14/2004 396.3(a)(1) Inspection/repair and maint parts and accessories (right rear fender on trailer has 1 of 4 fasteners loose).

Out-of-Service

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Trailer E201220 USLANL 6/11/2003 393.100 VW X 1 of 2 twist locks not properly latched no go tool slides between u-bolt at last trupact #179 front right side slides

between upper/lower u-bolt plate.Savannah River Site 11/29/2004 393.104(f)(3) X Loose/unfastened tie down. (1 of 12 cask tie downs loose.)

Trailer E201221 USLoving Inspection Site 8/23/2003 393.11 Right rear side marker lamp missing.Rocky Flats 12/10/2003 392.9 X Front left tie down load securement.Rocky Flats 11/8/2004 393.100(e) X Container 156; right side; rear; Trupact II-package tie down; Compression plate exceeds 0.100" (393.100(d)).

Trailer E201222 USRocky Flats 11/15/2003 393.100(a) X No or improper load securement (middle trupact, left front tie down loose).Rocky Flats 12/15/2003 393.100(a) X No or improper load securement loose tie down on trupact #3.Raton New Mexico POE 3/18/2004 393.104(f)(3) X Loose/ unfastened tie down. 1 of 4 tie downs on Trupact #205 is loose and exceeds measurement using the

gage.

Trailer E201223 USRaton New Mexico POE 2/26/2004 396.3(a)(1) X Inspection/repair and maint parts and accessories (Tubing with an audible air leak at other than a proper

connection at emergency side air tubing to trailer.)

Trailer E201224 USFt. Collins Colorado POE 6/28/2003 396.3(a)(1) Inspection/repair and maintenance, Left rear trailer fender, loose at front mounting to trailer frame, (x2 bolts).

Trailer E201225 USRaton New Mexico POE 3/17/2004 393.9 Inoperable lamp (other than head/tail) License plate lamp inoperable.Raton New Mexico POE 8/10/2004 393.9 VW Inoperable lamp (other than head/tail); License plate lamp not working.

Trailer E201226 USRocky Flats 4/1/2004 392.9 Tie down loose - Driver tightened on scene.

Trailer E201233 USRocky Flats 9/29/2004 396.3A1B X Brakes (general) (Audible air leak axle #4 far right side, fitting in frame.)

Trailer E201236 USRaton New Mexico POE 11/18/2004 396.3(a)(1) Inspection/repair and maint parts and accessories (Axle 5 right side brake chamber spring cage bolt is missing

the nut to properly secure it to chamber.

Trailer E201241 USLoving Inspection Site 1/20/2004 396.3(a)(1) Axle 4 right, hubometer loose.

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Page 2 of 7


Trailer E201243 USRocky Flats 4/26/2004 393.45 Glad hand leaking - was fixed on site.

Trailer E201244 USRocky Flats 1/12/2004 393.100(a) X 303.100(d) Compression plate exceeds maximum tolerance.Rocky Flats 2/9/2004 393.100 X No or improper load securement (loose tie down on left front corner of Trupact #181).Rocky Flats 8/18/2004 393.100 X No or improper laid securement (Trupact #183, left front tie down loose, moves side to side 1/4").

Trailer E201245 USHanford Site 6/24/2003 172.301(a) X Improper ID# on non-bulk pkgs 168 &179, both displayed ID # UN2982.Loving Inspection Site 9/13/2003 393.9 X Lamps required to operate trailer.Rocky Flats 10/28/2003 393.100(a) X No or improper load securement (compression plate gap not within tolerances).Rocky Flats 2/6/2004 393.100(a) X No or improper load securement (right front tie down loose on Trupact #171).

Trailer E201246 USRocky Flats 10/28/2003 393.102(a) X Improper securement syst (tie down assemblies) loose tie down on trupact.Raton New Mexico POE 7/26/2004 393.75(a)(4) X Tire-cut exposing ply and/or belt material (Axle 4 left outside tire has a cut in the sidewall approximately 8" long

and 1 1/12" deep).Rocky Flats 8/16/2004 172.208 Hazardous waste manifest not as required (Trupact #205 does not contain a true waste.)

Trailer E201247 USRocky Flats 5/11/2004 393.207(f) Air suspension pressure loss (air leak at leveling valve).

Trailer E201248 USRaton New Mexico POE 11/18/2003 393.45 X Brake tubing and hose adequacy, audible air leak from hole in service side brake hose to trailer.Raton New Mexico POE 9/8/2004 393.201(d) VW Frame accessories not bolted/ riveted securely; Fender bracket fastener loose, one of two bolts , left side above

axle 5.Loving Inspection Site 10/28/2004 393.9 Inoperable lamp -side marker lamps & I.D. lamps.

Trailer E201249 USRocky Flats 11/12/2003 392.9 Tie loose 2nd on right side (driver tightened up on scene).Rocky Flats 7/7/2004 177.823 No T.I. entry on right label of Trupact II 145 / Violation corrected prior to completion of inspection.

Trailer E22825 US393.45(a)(4) Brake hose to brake canister on axle 5 left is chafed in support grommet.393.45(a)(4) Brake hose to axle 5 right spring brake is chafed.

Trailer E22827 USSavannah River Site 8/20/2002 393.45(a)(4) Brake hose/tubing chaffing 4th axle right side.

Out-of-Service

INEEL 9/19/2002

Page 3 of 7


Trailer E22829 USLANL 12/6/2002 396.3A1 X Audible air leak, axle 5, right side brake chamber tubing, emergency side.

Trailer E22830 USSavannah River Site 9/23/2002 393.45(a)(4) Brake host/tubing chaffing 4th and 5th axle air line from relay valve chaffing on air reservoir tank.INEEL 10/18/2002 393.28(A)6 Right side marker light wire on the trailer runs through the metal frame unprotected ( the old grommet has been

damaged.)

Trailer E22831 USINEEL 10/9/2002 172.507 RAM highway route controlled quantity solid black border broken in tow places - upper left and upper right

Trailer E22833 USINEEL 9/24/2002 393.33 Trailer wire for license plate lamp passes thru metal hole, hole not protected by grommet.

Trailer E22834 USINEEL 10/11/2002 393.45(a)(4) Brake hose chafed in grommet to axle 5 right spring brake.Raton New Mexico POE 10/12/2002 393.207 Shock bushings worn bottom side right and left axle #4.

Trailer E22837 USINEEL 9/22/2002 396.5(b) Trailer, front axle, right side brake pad contaminated with grease, grease on lining edge, wheel seal wet, not

dripping.INEEL 10/1/2002 396.5B X Right side axle 4 wheel seal leaking contamination brake lining.Raton New Mexico POE 1/22/2003 393.9 X Right rear turn signal.

Trailer E22838 USRocky Flats 12/3/2002 393.45 Slight leak at fitting - Fixed.

Trailer E22840 USLoving Inspection Site 10/31/2002 393.17(D) Right rear clearance lamp missing.

Trailer E28094 USINEEL 9/19/2002 393.55(e) ABS malfunct lamps towed cmv mfg>2/98mfg<2/09 (repaired).Rocky Flats 11/5/2003 393.100(a) X Compression plate out of tolerance, exceeds .100" (corrected).

Out-of-Service

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Trailer E28099 USFt. Collins Colorado POE 5/2/2003 393.11 No/defective lighting devices/left and right front and rear side marker lamps inop rear ID lamps inop; license

plate lamp inop; trailer.Raton New Mexico POE 5/19/2004 172.504(a) X Vehicle not placarded as required (Required HWY Route Controlled Quantity placard is missing on rear of

trailer).393.100(e) Improper securement of intermodal containers, Trupact #162 with loose cam-lock left front, gap is correct.393.25(b) Lamps are not visible as required, right front trailer marker lamp inop.

Trailer E28198 USRaton New Mexico POE 6/18/2004 393.104(f)(3) X Left rear tie down on rear trupact is loose at the time of inspection.

Trailer E28199 USFt. Collins Colorado POE 10/16/2002 396.3(a)(1) Inspection/repair and maintenance, cross sub-frame assembly above tandems, axle #4 with cracked weld

Trailer E28200 US393.75(c.) X X Tire-other tread depth less than 2/32 of inch, Axle #5 right inside tire with a 6"x3" area with no tread.393.75(c.) X X Tire-other tread depth less than 2/32 of inch, Axle #5 right outside tire with a 6"x3" area with no tread.

Trailer E28257 USFt. Collins Colorado POE 9/22/2002 396.3(a) Inspection, repair, and maintenance, right rear trailer fender mounting with cracked and broken weld at center

mounting to trailer frame. 1 of 3 cracked/broken.393.19 Hazard lamp inop; Left side at rear of trailer (fixed).393.19 X Turn lamp inop; Left side at rear of trailer (fixed).

Trailer E28258 USINEEL 10/13/2002 396.3(a)(1) Inspection/repair and maintenance nail in tread axle 4 left outside tire.INEEL 5/27/2003 393.9 Side marker lamp inop; Right side at center of trailer (fixed).Raton New Mexico POE 6/26/2003 396.3(a)(1) X Inspection/repair and maintenance (Audible air leak at a brake chamber at axle 4 on the left side).INEEL 6/28/2003 393.100(a) X No or improper load securement, in excess of 0.100" between locking plate and compression plate.

Trailer E28259 USINEEL 3/31/2003 393.20 Left front marker lamp on trailer inoperative (fixed on scene).INEEL 5/18/2004 172.400(a) Package/containment not labeled as required labels switched on packages.INEEL 9/19/2004 172.205 Hazardous waste manifest not as required. Uniform hazardous waste manifest document number did not match

the number recorded on each casks label.

Trailer E28266 USRaton New Mexico POE 5/13/2004 396.3(a)(1) Inspection/repair and maint parts and accessories (rear placard bracket has 1 fastener loose).Raton New Mexico POE 7/21/2004 393.9 Inoperable lamp (other than head/tail) License plate lamp at rear of trailer is inoperable.Raton New Mexico POE 9/2/2004 396.3(a)(1) Inspection/repair and maint parts and accessories (Rear placard bracket of trailer has 1 of 3 bolts loose.)

INEEL 4/24/2003


Out-of-Service


Page 5 of 7


Trailer E28271 USFt. Collins Colorado POE 8/12/2004 396.3A1T Tires (general), Axle #5 left outside tire with nail in tread pattern, no leaking of any air.

Trailer E28272 USFt. Collins Colorado POE 4/30/2004 393.207(f) X X Air suspension pressure loss, No air supplied to air bag suspension trailer.INEEL 5/13/2004 172.403(a) Trupact 136 not labeled properly. Had Yellow III labels, Yellow II required and listed on the manifestFt. Collins Colorado POE 7/7/2004 393.100(e) Improper securement of intermodal containers, Trupact #170 at right rear position with loose cam-lock, gap is

correct.Raton New Mexico POE 8/3/2004 396.3(a)(1) VW Inspection/repair and maint parts & accessories; Hubometer on axle 4, right side loose (mounting bolts loose).

393.9 Inoperable lamp (other than head/tail)-trailer left front, clearance, lamp inop. Light flickers on and off when wires bumped.

396.3A1T Tires (general)-trailer rear axle right side, inside tire, metal bolt in tire removed bolt, not leaking air.

Trailer E28275 USLoving Inspection Site 9/11/2003 393.75(a)(1) 2 inch cut in sidewall of tire, axle 4 right, outside tire.Rocky Flats 1/8/2004 393.100(a) X No or improper load securement (Trupact #141 left side less than 7/100").Rocky Flats 5/12/2004 393.100(a) X No or improper load securement (loose tie down Trupact 131, right rear).Ft. Collins Colorado POE 6/29/2004 393.45(a)(4) Brake hose/tubing chaffing, Axle #5, right side at two places.

393.100(a) X Trupact-II tie down assemblies (3 of 8 assemblies exceeded .100" between locking plate and the compression plate. (2 rear) and 1-rf first container.)

393.20 Left side front marker lamp on trailer inoperative.

Trailer E28276 USFt. Collins Colorado POE 6/2/2004 172.303(a) HM marking on package, Not matching on shipping papers, cask #186 reading fissile material NOS 7 UN 2918,

shipping papers read, fissile excepted NOS 7 UN 2982.

Trailer E28277 USLoving Inspection Site 3/18/2003 396.3(a)(1) Missing fastener axle 5 right side on hub meter bracket.Ft. Collins Colorado POE 11/8/2004 393.47 Inadequate brake lining for safe stopping, Axle #5 left side with approx. 1/4" SQ. lining piece missing in upper

brake lining.

Trailer E28278 USFt. Collins Colorado POE 5/9/2003 393.19 X No/defective turn/hazard lamp as required; left rear inop; trailer.Ft. Collins Colorado POE 6/30/2004 393.47 Inadequate brake lining for safe stopping, Axle #4 left side, with 3/8" chunk/crack in upper crake lining.

Out-of-Service

9/17/2004

INEEL 9/20/2004

INEEL

Page 6 of 7


Trailer E28279 US393.100(d) X Gap between trailer locking plant and compression plates exceeding measurement on 3 of 12 tie downs for

trupacts.393.100(d) X Gap between trailer locking plant and compression plates exceeding measurement on 3 of 12 tie downs for

trupacts.Loving Inspection Site 4/12/2003 396.3(a)(1) VW Axle 4 right 1 of 3 fasteners missing on hubometer.Hanford Site 9/23/2003 393.102 X Excessive clearance at compression plate.Ft. Collins Colorado POE 9/24/2003 393.100(e) Improper securement of intermodal containers, Keeper pin not engaged CASK #175, Right side rear keeper pin

not properly engaged repaired on site.Rocky Flats 2/6/2004 393.100(a) X No or improper load securement (right front tie down loose on Trupact #125).Raton New Mexico POE 2/6/2004 172.406(a)(1) Label placement not as required (Trupact #193 is missing the right side label and left side label is damaged.)

393.11 No/defective lighting devices/ref/projected (ID lamps at rear of trailer inop at time of inspection repaired at scene).

393.11 No/defective lighting devices/ref/projected (License plate lamp inop at time of inspection repaired at scene).393.11 No/defective lighting devices/ref/projected (All front & rear side marker lamp inop at time of inspection repaired

at scene).

Trailer E28280 USFt. Collins Colorado POE 6/13/2003 393.75(a) X X Flat tire, axle #5 left inside trailer.Hanford Site 10/21/2003 393.100D X Gap exceeds 0.100 inch/ with go/no.

Trailer E28282 USRaton New Mexico POE 7/23/2004 393.104(f)(3) X Loose/unfastened tie down. Left side rear tie down loose on trupact #205.

Trailer E28284 USRaton New Mexico POE 6/26/2004 393.9 Inoperable lamp (other than head/tail) license plate lamp.INEEL 7/9/2004 393.100(a) X Front right tie down on cask 183 not adequately secured. 393.100(D) (393.100(d), repaired.Raton New Mexico POE 7/30/2004 393.201(d) Frame accessories not bolted/riveted securely (Left rear fender bracket has 2 loose fasteners).

Trailer E28286 USRocky Flats 12/1/2003 393.75(A)(1) X #4 Axle inside left tire split in treat 2-3" steel casing showing. (tire changed on scene (Rocky) - 12-1-03 - 1015

HRS no defects).

Trailer E28287 USINEEL 10/9/2002 396.3(a) Leak at seal hub-axle 4 right inside seal.Raton New Mexico POE 6/4/2004 393.104(f)(3) X Trupact container #166 left rear tie down assembly loose. (Gap between the trailer locking plate and the

compression plate exceeds 0.100) 1 of 4 loose.

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Page 7 of 7

APPENDIX

C

Driver Violations Inspection Location Date Violation ID Citation Level VI NAS Violation Description

Driver 0319 NMINEEL 9/29/2002 395.8 Log violation (general/form and manner)- failed to log status change from sleeper in Little America, WY during

purchase at store on 9-29-02.

Driver 0531 NMFt. Collins Colorado POE 6/20/2003 395.8 Log violation (general/form and manner) Co-Driver log sleeper berth in FT. Bridger, WY while in passenger

seat, at time of this insp. Must log "On duty not driving."

Driver 0824 COINEEL 6/1/2004 395.8 Driver failed to list the Co-Drivers name on 5-31-04.

Driver 1254 NMFt. Collins Colorado POE 6/17/2004 395.8 Log violation (general/form and manner) Co-Driver miss-logging unit numbers on 6/16/04.

Driver 2753 NMFt. Collins Colorado POE 5/28/2003 395.8 Log violation (general/form and manner) inaccurate entry/05-25-03/logged off duty from 1100 to 1200 hrs/co-

driver on duty and driving during same time period.

Driver 3726 NMSavannah River Site 3/3/2003 391.43(g) Improper medical examiner's certificate (medical examiner's certificate is not signed by the medical examiner

and the certificate does not bear the driver's name.)

Driver 3881 CORaton New Mexico POE 11/21/2003 395.3(a)(2) 15 Hour rule violation, in violation from 445 am to 600am on 11-21-02. 1.25 hours.

Driver 4231 NMINEEL 10/1/2002 395.8 Log violation (general/form and manner) fail to list change of duty location on 09-29-02 at 2359.Savannah River Site 11/4/2002 395.8 Failure to submit original record of duty status reports to carrier within 13 days.INEEL 5/1/2003 395.8 General logbook violation - On 4-30-03 the driver failed to total his hours.

Driver 4256 TXSavannah River Site 11/29/2004 392.43(g) Improper medical examiner's certificate (Has medical examiners number but no issuing state).

Driver 5106 NMRocky Flats 1/12/2004 395.8(f)(1) Drivers record of duty status not current (driver failed to total hours on 1/8/04 and 1/6/04).

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Driver 5741 NMFt. Collins Colorado POE 8/15/2003 392.2 Local laws (general), State law violation, 42-20-403, (N.M.T. 10) Motor vehicles transporting RAM shall

operate with headlights on at all times.395.3(a)(1) Drove 14 hours on 01/14/2004 (11 hour rule).395.3(a)(2) 14 hour rule violation (only took 1 eight hour split on 011404, drove at 12:00 hrs.)395.3(a)(1) 11 Hour rule violation from 11:00 p.m. to 3:00 p.m. and 3:30 p.m. to 5:30 p.m. on 1/14/04 (Co-driver).395.3(a)(2) 14 hour rule violation from 2:30 p.m. to 5:30 p.m. on 1/14/04 (Co-driver).

Driver 5985 NMINEEL 3/15/2004 395.8 Log Violation (general/form and manner) fail to show city on change of duty status. Showing milepost and

state nearest city in description mission 3/14/04.

Driver 6667 NMSavannah River Site 8/1/2003 383.23(a)(2) Operating a CMV without a CDL note verified by home state.

391.43(g) Improper medical examiner's certificate - medical examiners license issuing state not recorded on medical card.

392.2 Local laws (general) - driver failed to produce current hazardous waste permit.

Driver 6985 NMFt. Collins Colorado POE 6/17/2004 395.8(e) X X False report of drivers record of duty status, logging "Off duty/sleeper" while Co-Driver is driving, 7:45am-

8:30am, 6/16/04. Log "off duty" 00:01-10:00am @ loading facility.

Driver 7016 NMINEEL 6/27/2003 395.8 Log violation - the Co-driver failed to total his miles driven on 6-26-03.INEEL 7/8/2004 391.43(g) Improper medical examiner's certificate - medical examiners license issuing state not recorded on medical

card.

Driver 7289 NMRocky Flats 7/9/2004 395.8 Log violation (general/form and manner)(On 7/7/04 hours not totaled correctly. Should show 2.75 hours off

duty, and 14 hrs, sleeper).INEEL 9/19/2004 391.43(g) Improper medical examiner's certificate - co-driver's medical card does not have medical examiner's license

issuing state recorded.Savannah River Site 11/1/2004 395.3(a)(2) 14 Hour rule violation (property) drove 1.25 hrs over 14hrs.

Driver 7449 NM395.8 Log Violation (general/form and manner) ( No totaled miles at end of day 5-12-2004).395.8 Log Violation (general/form and manner) ( No driver certification on day 5-12-2004).395.8 Log Violation (general/form and manner) ( No totaled hours at right side of grid on day 5-12-2004).

5/19/2004Raton New Mexico POE

Out-of-Service



INEEL 7/8/2004

Page 2 of 3


Driver 7561 NMRocky Flats 10/1/2003 395.8 Violation of 10 hr rule 9-24 at 18:15 hrs.

Driver 7831 NMINEEL 10/4/2002 392.2 Driver fail to carry CDL (got photocopy).

395.8 General Logbook - On 10-12-02 the Co-Drivers last entry was at 10 PM in sleeper berth.395.8D(5) Driver failed to sign and certify logbook page on 10-11-02.

Driver 7881 NMINEEL 10/4/2002 392.2 Co-Driver fail to carry CDL.Raton New Mexico POE 10/5/2002 392.2 Driver did not have CDL in immediate possession. Drivers license was confirmed through home state.Savannah River Site 11/22/2002 392.2 Local laws (general). No registration or any paperwork for trailer.INEEL 9/21/2004 391.43(g) Improper medical examiner's certificate - medical examiner's license issuing state not recorded on medical

card.

Driver 8076 NMINEEL 10/18/2002 395.8D(9) General Logbook - on 10-16-02 the Co-Driver failed to list the name of his Co- Driver.

Driver 8101 NMRocky Flats 12/10/2004 395.3 14 HR Violation 12-8-04 0300-0345 HRS.

Driver 8880 TXINEEL 10/18/2002 395.8 General logbook - On 10-13-02 the driver shows no duty status.INEEL 4/10/2003 395.8 Log violation miles driving not shown on 04/03/03 corrected on site.Rocky Flats 8/11/2004 395.8 Log violation (general/form and manner)(8/10/04 hours not totaled correctly, 30 hour day).Savannah River Site 11/29/2004 392.43(g) Improper medical examiner's certificate (Has medical examiners number but no issuing state).

Driver 8956 AZINEEL 6/29/2004 383.51 X Driving a CMV (CDL) while disqualified - Driver showing a disqualified status in Arizona for medical

qualifications. Has a valid medical card with him.

Driver 9120 NMINEEL 7/10/2003 396.11 Driver vehicle inspection report 7/9/03 not completed.

395.3(a)(1) X X Drove 13 hours on 10/28/2003 (co driver).395.3(a)(2) X Drove 1.25 hours over 15 hours on 10/28/2003 through 10/28/2003 (co-driver).

Driver 9986 NMFt. Collins Colorado POE 8/27/2003 397.3 State/local laws ordinances regulations, 42-20-403 (N.M.T.10) Motor vehicles transporting RAM shall operate

with headlights on at all times.

10/28/2003

INEEL 10/18/2002

Rocky Flats

Out-of-Service

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