cvsa level vi 2007 annual report final - csg midwest · the commercial vehicle safety alliance...

COMMERCIAL VEHICLE SAFETY ALLIANCE LEVEL VI PROGRAM 2007 ANNUAL

INSPECTION REPORT – FOR INSPECTIONS IN CY 2006

January 2008

For information concerning this report contact Commercial Vehicle Safety Alliance

1101 17th Street, N.W., Suite 803 Washington, DC 20036 Phone: (202) 775-1623 Fax: (202) 775-1624

www.cvsa.org

http://www.cvsa.org/

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Introduction The Commercial Vehicle Safety Alliance (CVSA), an international not-for-profit organization comprised of local, state, provincial, territorial and federal motor carrier safety officials and industry representatives from the United States, Canada, and Mexico. CVSA’s mission is to promote commercial motor vehicle safety and security by providing leadership to enforcement, industry and policy makers. In addition, CVSA has several hundred associate members who are committed to helping the Alliance achieve its goals; uniformity, compatibility and reciprocity of commercial vehicle inspections, and enforcement activities throughout North America by individuals dedicated to highway safety and security. This is accomplished by establishing effective transportation safety standards for motor carriers, drivers, vehicles and inspectors through compliance, education, training and enforcement programs. 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, the U.S. Department of Energy (DOE), Canadian Transport Officials and more than 500 associate industry members. CVSA serves as a critical, central point for bringing state/provincial officials together with the truck/bus industries and federal governments in a unique discussion and problem-solving exchange of ideas. Member agencies sign a Memorandum of Understanding (MOU) and recognize and agree to uniform inspection standards and procedures as developed by CVSA. One of the MOU’s significant elements is a reciprocity agreement between members to honor inspections conducted by other member agencies authorized to affix the CVSA decal. The CVSA/DOE Cooperative Agreement In 1986, the DOE Office of Civilian Radioactive Waste Management (OCRWM) and CVSA entered into a cooperative agreement to develop inspection standards for transporting radioactive materials. This standard became known as the Enhanced North American Standard 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 CVSA/DOE Cooperative Agreement Interim Report was published in October 2002, which updated the program’s progress to that point. In 1997, the DOE Waste Isolation Pilot Plant (WIPP) and CVSA entered into a cooperative agreement to provide CVSA Level VI inpsection program training to inspectors, the enforcement community, and WIPP carrier drivers. In 2004, CVSA and WIPP began a multiyear program to keep interested parties updated on the progress of the CVSA Level VI inspection program with a focus on DOE radioactive waste shipments.

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At that time the only radioactive materials shipments receiving a CVSA Level VI inspection were those shipped by DOE. There was no regulation for a Level VI inspection of other radioactive material shipments. CVSA Level VI Annual Report This is the fourth CVSA Level VI Program Annual Inspection Report (CY 2006 Report). All previous and current reports may be found on CVSA’s website at www.cvsa.org. Once on the website, select “Programs” at the top of the page then select the “North American Standard (NAS) Level VI Inspection Program” link and click on “CVSA/WIPP Update and Reports.” This report reviews data from CVSA Level VI inspection forms for shipments during calendar year (CY) 2006 and some 4th quarter CY 2005 inspection forms not reviewed in the CY 2005 report. In addition, this report presents information on Level VI inspections for both the DOE Waste Isolation Pilot Plant (WIPP) and other, non-WIPP shipments. One state, Georgia, had its first reported inspection during CY 2006 for WIPP. For non-WIPP shipments Maryland, Massachusetts, Michigan, Missouri, New Jersey, New York, Ohio, Tennessee, and Virginia are all new states that provided inspection forms for review in this report. HRCQ Radioactive Material Shipments Effective January 1, 2005, the U.S. Department of Transportation required all vehicles and carriers transporting Highway Route Control Quantities (HRCQ) of radioactive material to pass a CVSA Level VI Inspection, prior to the shipment being allowed to travel in the U.S. All HRCQ radioactive material shipments entering into the U.S. must also pass the CVSA Level VI Inspection either at the shipment’s point of origin or when the shipment enters the U.S. As a result of this new regulation, CVSA began to receive a large number of inspection forms for CVSA Level VI inspections of other radioactive waste shipments. Many of these inspections were for shipments either originating outside the U.S. or the destinations of these shipments were outside the U.S. These shipments and therefore inspections involved different trucking companies, vehicles and drivers as compared to the shipments for WIPP. In this report and future reports CVSA will compare Level VI inspections for DOE WIPP shipments to other types of shipments (non-WIPP shipments). En Route Inspections CVSA guidelines and training to members is that a shipment inspected to the “defect free” level at origin need not be re-inspected to the same degree while en route. Some states have laws or statutes that require all radioactive material shipments to be inspected and/or escorted. Previous reports suggested that en route states with these laws choose to complete one of the other CVSA level inspections and randomly inspect to the CVSA Level VI inspection standard instead of the practice of completing a full CVSA Level VI

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inspection on each shipment. The implementation of this suggestion occurred during the time frame of this report. Two states that previously conducted full CVSA Level VI inspections on all en route shipments completed CVSA Level VI, Level II and Level III inspections. CVSA Level II and Level III Inspections A CVSA Level II inspection (also known as the Walk-Around Driver/Vehicle Inspection) includes an examination of the items specified under the North American Standard Inspection but does not require physically getting under the vehicle to inspect. At a minimum, Level II inspections must include examination of: driver’s license; medical examiner’s certificate and Skill Performance Evaluation Certificate (if applicable); alcohol and drugs; driver’s record of duty status as required; hours of service; seat belt; vehicle inspection report (if applicable); brake systems; coupling devices; exhaust systems; frame; fuel systems; lighting devices (turn signals, brake lamps, tail lamps, head lamps and lamps/flags on projecting loads); safe loading; steering mechanism; suspension; tires; van and open-top trailer bodies; wheels and rims; windshield wipers; emergency exits on buses, and Hazardous Materials (HM) requirements as applicable. HM required inspection items are inspected by certified HM inspectors. The CVSA Level III inspection (or Driver/Credential Inspection) includes at a minimum an examination of the driver’s license; medical examiner’s certificate and Skill Performance Evaluation Certificate; driver’s record of duty status; hours of service; seat belt; vehicle inspection report; and HM requirements. Tables in the Report The following tables are the same tables used in previous reports in order to maintain consistency. Once a state is added to the table it is never removed for the reason that from one year to the next a state may or may not have an inspection. In this year’s report, for WIPP shipments, there are three states with no reported inspections. They are California, Nevada and Illinois. These states are listed in the tables because of previous shipments and for the potential of shipments in the future. In the case of Illinois, non-WIPP inspections were completed and those numbers are located in the non-WIPP tables. One other change in the tables is the separation of the Washington and Oregon inspections. Inspection numbers continue to increase in Oregon and to be consistent each state with inspections will be listed separately. Number of Shipments Table 1 identifies the number and type of inspections by state for WIPP shipments. A total of 2,174 state inspection forms were received from the states during this time period. The largest number of point of origin inspections occurred in Idaho with 797 while the largest number of en route inspections occurred in Colorado with 707.

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The number of inspections per month continues to increase. In the first annual report there was an average of about 72 inspections forms per month. That number has grown to just more than 181 forms per month in this annual report for WIPP shipments.

Table 1. WIPP Shipments: Number and type of inspections by state (January 1, 2006 – December 31, 2006)

State Point of Origin En Route TotalCalifornia 0 0 0Colorado 0 707 707Georgia 0 1 1Idaho 797 0 797Illinois 0 0 0Nevada 0 0 0New Mexico 106 332 438Oregon 0 14 14South Carolina 139 0 139Washington 78 0 78Total Number of Inspections 1120 1054 2174

Number of Shipments – Non-WIPP Table 2 identifies the number and type of inspections by state for non-WIPP shipments. A total of 200 CVSA Level VI inspection forms were received from the states during this time period.

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Table 2. Non-WIPP Shipments: Number and type of inspections by state (January 1, 2006 – December 31, 2006)

State Point of Origin En Route Point of Destination Total

Colorado 0 1 0 1Idaho 3 0 0 3Illinois 0 70 0 70Maryland 5 1 0 6Massachusetts 2 0 0 2Michigan 11 0 0 11Missouri 2 1 0 3New Jersey 1 0 0 1New Mexico 0 24 0 24New York 0 30 0 30Ohio 17 7 0 24South Carolina 8 0 15 23Tennessee 0 1 0 1Virginia 1 0 0 1Total Number of Inspections 50 135 15 200

Number of Violations Tables 3 (WIPP shipments) and 4 (non-WIPP shipments) identify the number and type of violations found by state. The first column displays the number of inspections that identified violations and the second column displays the number of violations identified during those inspections. The other columns display the number of non out-of-service violations and out-of-service violations. Table 3 includes a total of 220 inspections identifying 267 violations during this annual report time frame. Of those 267 violations 87 were out-of-service violations (32 CVSA Level I out-of-service violations and 55 CVSA Level VI out-of-service violations). Table 4 includes a total of 47 inspections identifying 69 violations during this time frame. Of those 69 violations, 16 were out-of-service violations (15 CVSA Level I out-of-service violations and 1 CVSA Level VI out-of-service violation).

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Table 3. WIPP Shipments: Number and type of violations found listed by state and

type of inspection (January 1, 2006 – December 31, 2006)

NAS Level VI TotalCalifornia Point of Origin 0 0 0 0 0 0

Colorado Point of Origin 0 0 0 0 0 0 En Route 93 109 86 6 17 23

Georgia En Route 1 1 0 0 1 1

Idaho Point of Origin 101 127 78 17 32 49

Illinois Point of Origin 0 0 0 0 0 0

Nevada Point of Origin 0 0 0 0 0 0

New Mexico Point of Origin 4 4 3 1 0 1 En Route 15 18 10 7 1 8

Oregon En Route 0 0 0 0 0 0

South Carolina Point of Origin 4 6 3 0 3 3

Washington Point of Origin 2 2 0 1 1 2Total 220 267 180 32 55 87

State/Type of Inspection

Number of Inspections Identifying Violations

Number of Violations Identified

NOT Out-of-Service Violations

Out-of-Service Violations

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Table 4. Non-WIPP Shipments: Number and type of violations found listed by state and type of inspection (January 1, 2006 – December 31, 2006)

NAS Level VI TotalColorado En Route 0 0 0 0 0 0

Idaho Point of Origin 2 5 3 2 0 2

Illinois En Route 12 15 8 7 0 7

Maryland En Route 0 0 0 0 0 0 Point of Origin 2 0 0 0 0 0

Massachusetts Point of Origin 0 0 0 0 0 0

Michigan Point of Origin 0 0 0 0 0 0

Missouri En Route 0 2 2 0 0 0 Point of Origin 0 0 0 0 0 0

New Jersey Point of Origin 1 3 2 1 0 1

New Mexico En Route 4 5 4 0 1 1

New York En Route 10 14 11 3 0 3

Ohio En Route 3 5 3 2 0 2 Point of Origin 5 7 7 0 0 0

South CarolinaDestination 6 10 10 0 0 0 Point of Origin 0 0 0 0 0 0

Tennessee En Route 1 1 1 0 0 0

Virginia Point of Origin 1 2 2 0 0 0Total 47 69 53 15 1 16

Number of Violations Identified

NOT Out-of-Service Violations

Out-of-Service ViolationsState/Type of Inspection

Number of Inspections Identifying Violations

Percentage of Inspections with No Violations and Violations Tables 5 and 6 identify the percentage of inspections having no violations or violations, listed by state and type of inspection for WIPP and non-WIPP shipments, respectively. The highest percentage of violations in Table 5 is for en route inspections in Georgia. However this is based on only one en route inspection conducted by Georgia in CY 2006. The next highest percentage of violations for en route inspections occurred in Colorado

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with 13.15%. In Idaho 12.67 percent of the point of origin inspections found violations. The lowest percentage of violations is for en route inspections in Oregon in which no inspections found violations. In the third annual report it is stated that the percentages of inspections with no violations found for almost all states increased over time, meaning fewer and fewer inspections were finding violations. This is again the case. For example, Colorado saw an increase in the percent of en route inspections finding no violations from 85.18 percent in the third annual report to 86.85 percent for this annual report. The following chart shows the percentages of inspections with no violations over the last three annual reports for states with inspections included in all three reports. Table 6 shows that there tends to be higher percentages of inspections finding violations for the non-WIPP shipments

Chart 1. WIPP Shipments: Percentage of inspections with no violations found for states with inspections included in all of the last three annual reports

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Table 5: WIPP Shipments: Percentage of inspections having no violations or violations listed by state and type of inspection

(January 1, 2006 – December 31, 2006) State/Type of Inspection Number of Inspections No Violations Violations

California Point of Origin 0 0.00% 0.00%

Colorado Point of Origin 0 0.00% 0.00% En Route 707 86.85% 13.15%

Georgia En Route 1 0.00% 100.00%

Idaho Point of Origin 797 87.33% 12.67%

Illinois Point of Origin 0 0.00% 0.00%

Nevada Point of Origin 0 0.00% 0.00%

New Mexico Point of Origin 106 96.23% 3.77% En Route 332 95.48% 4.52%

Oregon En Route 14 100.0% 0.00%

South Carolina Point of Origin 139 97.12% 2.88%

Washington Point of Origin 78 97.44% 2.56%

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Table 6: Non-WIPP Shipments: Percentage of inspections having no violations or violations listed by state and type of inspection

(January 1, 2006 – December 31, 2006) State/Type of Inspection Number of Inspections No Violations Violations

Colorado En Route 1 100.00% 0.00%

Idaho Point of Origin 3 33.33% 66.67%

Illinois En Route 70 82.86% 17.14%

Maryland En Route 1 100.00% 0.00% Point of Origin 5 60.00% 40.00%

Massachusetts Point of Origin 2 100.00% 0.00%

Michigan Point of Origin 11 100.00% 0.00%

Missouri En Route 1 100.00% 0.00% Point of Origin 2 100.00% 0.00%

New Jersey Point of Origin 1 0.0% 100.0%

New Mexico En Route 24 83.33% 16.67%

New York En Route 30 66.67% 33.33%

Ohio En Route 7 57.14% 42.86% Point of Origin 17 70.59% 29.41%

South Carolina Point of Destination 15 60.00% 40.00% Point of Origin 8 100.00% 0.00%

Tennessee En Route 1 0.00% 100.00%

Virginia Point of Origin 1 0.00% 100.00%

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Percentage of Point of Origin and En Route Inspections with No Violations and Violations Table 7 and Table 8 show the overall percentage of inspections having no violations and violations at the point of origin and en route for WIPP and non-WIPP shipments, respectively. Again percentages are higher (double for POO and En Route) for the non-WIPP shipments

Table 7. WIPP Shipments: Percentage of point of origin and en route inspections with no violation and with violations

(January 1, 2006 – December 31, 2006) Inspection Location Number of Inspections NO Violations Violations

Point of Origin 1120 90.09% 9.91%En Route 1054 89.66% 10.34%

Table 8. Non-WIPP Shipments: Percentage of point of origin, en route and point of destination inspections with no violation and with violations

(January 1, 2006 – December 31, 2006) Inspection Location Number of Inspections NO Violations Violations

Point of Origin 50 78.00% 22.00%En Route 135 77.78% 22.22%Point of Destination 15 60% 40% Comparison with Non-WIPP Shipments and Federal Motor Carrier Safety Administration Data Table 9 is the comparison of WIPP and non-WIPP CVSA Level VI inspections. Non-WIPP inspections have almost double the driver and vehicle out-of-service violations as compared to WIPP inspections. Tables 9 and 10 present a comparison of CVSA Level VI inspection information to data for the same period from the Federal Motor Carrier Safety Administration (FMCSA). Of the 220 WIPP inspections that found violations, 81 inspections found Level I or Level VI out-of-service violations. Three of the 81 inspections found driver out-of-service violations for a driver out-of-service rate of 0.14 percent. Seventy-eight of the inspections found vehicle out-of-service violations for a vehicle out-of-service rate of 3.59 percent. It is CVSA’s belief that DOE, WIPP, the states, the carriers, and other interested parties should be commended that for eight and a half years the continued hard work and dedication that goes into the WIPP shipping program and inspections continues to show signs of progress and improvement. It is important to keep up this dedication to continue making the WIPP shipping campaign as safe as possible.

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Table 9. WIPP Shipments: Comparison with Non-WIPP shipments

Inspection Activity Number Percent Level I OOS Percent Level VI OOS PercentNumber of Inspections 2,174With no Violations 1,954 89.88%With Violations 220 10.12%Driver OOS* Rate 3 0.14% 0.14% 0.00%Vehicle OOS Rate 78 3.59% 1.29% 2.30%

CVSA Level VI Inspection Data for WIPP Shipments (January 1, 2006 – December 31, 2006)

Inspection Activity Number Percent Level I OOS Percent Level VI OOS PercentNumber of Inspections 200With no Violations 153 76.50%With Violations 47 23.50%Driver OOS Rate 1 0.50% 0.50% 0.00%Vehicle OOS Rate 14 7.00% 6.50% 0.50%

CVSA Level VI Inspection Data for Non-WIPP Shipments (January 1, 2006 – December 31, 2006)

*OOS = Out-of-Service

Table 10. FMCSA inspection data

Inspection Activity Number Percent Inspection Activity Number PercentNumber of Inspections 3,329,442 Number of Inspections 191,369With no Violations 937,968 28.17% With no Violations 156,201 81.62%With Violations 2,391,474 71.83% With Violations 35,168 18.38%Driver OOS** Rate 225,531 † 7.08%Vehicle OOS Rate 551,587 † 22.89%

FMCSA Roadside Inspection Data for the Year 2006*

FMCSA HAZMAT Inspection Data for the Year 2006*

OOS Rate 5.29%10,126

† The number of inspections is a combination of some Driver, some Vehicle and some combination of both. The OOS Rates are for only those types of inspections. *Data Source: FMCSA Motor Carrier Management Information System (MCMIS) March 23, 2007 data snapshot **OOS = Out-of-Service Overall CVSA Level VI Program – WIPP Shipments Table 11 is a summary of the Level VI inspection program for WIPP shipments through December 31, 2006. Since March 24, 1999, there have been 11,058 CVSA Level VI inspections analyzed. Of these inspections, 91.64 percent found no violations, a slight decrease from the 92.06 percent in the third annual report. The combined Level I and Level VI out-of-service rate for vehicles decreased from 2.62 percent in the third annual report to 2.11% for this report. Driver out-of-service also continues to drop (from 0.10 in the second annual report to 0.09 percent in the third annual report to 0.07 percent in this report). With the addition of the 2006 Level VI inspection data, the number of inspections with Level I out-of-service violations continues to be less than 1 percent for the entire

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program. Most notable is that the percentage of Level I out-of-service violations continues to decrease. Adding this report’s data to the entire program, the Level I out-of service rate for drivers decreased from 0.08 percent (stated in the CY 2005 Report) to 0.06 percent and the Level I out-of-service rate for vehicles decreased from 0.82 percent (stated in the CY 2005 Report) to 0.66 percent.

Table 11. Review of entire CVSA Level VI Inspections for WIPP shipments

Inspection Activity Number Percent Level I OOS Percent Level VI OOS PercentNumber of Inspections 11,058With no Violations 10,133 91.64%With Violations 925 8.36%Driver OOS* Rate 0.07% 0.06% 0.01%Vehicle OOS Rate 2.11% 0.66% 1.45%

CVSA Level VI Inspection Data for WIPP Shipments (March 24, 1999 – December 31, 2006)

*OOS = Out-of-Service

En Route CVSA Level II and Level III Inspections As discussed earlier two states, New Mexico and Colorado which previously conducted full CVSA Level VI inspections on all en route shipments, completed CVSA Level VI, Level II and Level III inspections in CY 2006. New Mexico completed 457 Level II inspections and fourteen of those inspections found a violation. Four of the violations were out-of-service violations. Colorado completed 200 CVSA Level II and Level III inspections: 180 were CVSA Level III inspections, and 20 were Level II inspections. Of those 200 inspections, five found violations. None of those violations were out-of-service violations. Conclusion The ultimate goal of the CVSA Level VI inspection program is and will continue to be the safe and uneventful shipments of radioactive materials from origin to destination. The states, carriers, and DOE can be proud of their continued safety program excellence during this period as supported by the overall reduction of the out-of-service rates. The program should continue to strive for low out-of-service rates, which ultimately lead to a low number of incidents. WIPP shipments continue to be one of the safest commercial truck shipments today.

APPENDIX

A

Tractor Violations (arranged by license plate)

Inspection Location Date Violation ID Level I Level VI Citation Violation Description

Tractor 09395 WYFt. Collins Colorado POE 10/22/2006 393.45(d) X Brake connections with leaks/constrictions--emergency side glad-hand leaking air- fixed on site.

Tractor 09396 WYRichland Washington 5/16/2006 393.75(s)(3) X Tire-flat and/or audible air leak/ under 50% air pressure/ axle 3 left outside.

Ft. Collins Colorado POE 8/6/2006 393.75(b) X Tire-front tread depth less than 4/32 of inch --axle #1 drivers side tire measured less than 4/32" two places same inside groove.

Loving Inspection Site 9/16/2006 393.9H X Inoperable head lamps R side low beam.

Tractor 09697 WYINL 1/6/2006 393.46( b) X Brake connections with leaks/constrictions - audible air leak from relay valve above, left, and forward

of axle 2 when brakes applied - repaired by driver.

INL 2/8/2006 393.33 Improper wiring installations, wire worn to expose core on left headlight wiring harness. Repaired at scene.

Ft. Collins Colorado POE 8/11/2006 393.83(f) Improper exhaust system repair (6" crack by weld under sleeper by y).

Out-of-Service

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Tractor 09608 WYINL 2/20/2006 393.83(g) X Exhaust leak under truck cab and/or sleeper (Repaired on Scene)LANL 5/20/2006 393.53© Visual indicator on push rod of brake chamber defective.

Tractor 09610 WYINL 2/4/2006 392.2 Local Laws (general) No Idaho Hazardous Waste Permit on Vehicle.

393.47 X Contaminated brake lining on left side axle 3. (fixed on site)396.5 Left side axle 3 wheel seal leaking. (fixed on site)

Tractor 09611 WYINL 2/10/2006 396.3A1B X Brakes (general) - audible air leak from air valve located above and to the rear of axle 3 when brakes

applied - fixed by driver.INL 7/18/2006 393.93(b) Damaged seat belt - driver's seat belt frayed - replaced and truck released.

Ft. Collins Colorado POE 8/4/2006 393.45(d) X Brake connections with leaks/constrictions-- Connection with chamber axle #1 passenger side leaking air.

Ft. Collins Colorado POE 8/23/2006 395.45(d) Brake connections with leaks/quick release valve leaking between axle 2 and 3 with service brakes applied; tractor.

Tractor 09613 WYFt. Collins Colorado POE 2/22/2006 393.83(g) Exhaust leak under truck cab and/or sleeper. Right side under passenger area at flex to elbow.

Repaired at FT. Collins POE.LANL 6/30/2006 393.201 Loose deck plate behind sleeper right side.

3/6/2006INL

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Tractor 09614 WYINL 1/23/2006 393.28 Improper or no wiring protection as required. (Wiring harness protective sheathing coming from

Tractor to Trailer is cut by the plug exposing the interior wiring.)LANL 5/24/2006 393.67 X Fuel leak at fuel filter.

Tractor 09615 WYINL 3/30/2006 396.3A1B X Brakes (general)-truck audible air leak from relay valve, right side between axles 2 and 3.

Tractor 09616 WYFt. Collins Colorado POE 5/5/2006 393.45(b)(2) Brake hose/tubing chaffing one hose right upper axle 2.Buckhead Georgia 6/26/2006 393.203(e) X Front bumper damaged - Does not meet Level VI out-of-service criteria.

Tractor 38738 MOFt. Collins Colorado POE 3/2/2006 393.45(a)(4) Brake hose or tubing chaffing, Red and blue air line to trailer air supply with flat spot near spring

guard. Allowed to replace at home terminal.Ft. Collins Colorado POE 4/20/2006 395.95(a) Unsecured fire extinguisher, inside tool box left side sleeper.

Ft. Collins Colorado POE 9/27/2006 393.45(b)(2) Brake hose/tubing chaffing; Axle 2 left side brake hose damaged through outer covering (rub on drive shaft).

Out-of-Service

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Tractor 41522 MOINL 7/24/2006 393.9(a) Rear license plate lamp on tractor inoperative.Ft. Collins Colorado POE 11/8/2006 393.19 X Right rear tractor with inoperative turn signal, repaired on site.

Tractor 41834 MOINL 2/11/2006 393.83(g) X Exhaust leak under truck cab and/or sleeper - leak at clamp forward of "Y" under sleeper - repaired by

driver.INL 2/26/2006 393.9 Tractor rear license plant lamp not white.Ft. Collins Colorado POE 3/5/2006 393.24(b) Non-compliance with headlamp requirements, LEFT SIDE HEADLAMP INOPERABLE.Ft. Collins Colorado POE 5/14/2006 393.201(d) Frame accessories improperly attached - catwalk on rear of cab loose - one corner.

Ft. Collins Colorado POE 5/31/2006 396.3(a)(1) Inspection/repair and maintenance parts and accessories, left side fender over driver axles with securement bolt missing from fender, repaired on site.

INL 7/8/2006 396.5(b) Oil and/or grease leak axle 2 right inside.

Tractor 42181 MOFt. Collins Colorado POE 3/6/2006 393.201(d) Frame accessories improperly attached -- catwalk has one bolt looseFt. Collins Colorado POE 4/12/2006 393.75(a)(3) X Tire-flat and/or audible air leak, Axle #2, left outside tire with audible air leaking from sidewall.Ft. Collins Colorado POE 6/12/2006 393.47(a) Inadequate brakes for safe stopping -- axle #1 drivers side lower lining has vertical crack.INL 7/27/2006 396.3A1T Tires (general) screw in tire removed/fixed on scene.

INL 10/2/2006 393.83(g) X Exhaust leak under truck cab and/or sleeper. Leaking on second clamp from manifold. Repaired on Scene.

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Tractor 43193 MOFt. Collins Colorado POE 3/2/2006 393.24(b) Non-compliance with headlamp requirements, Low beam inoperable, right side.

393.47(d) Insufficient brake linings--axle #1 drivers side pad cracked less than 1".393.95(f) No/insufficient warning devices -- warning devices are out of the box.

Ft. Collins Colorado POE 7/16/2006 396.5(b) Old and or grease leak, oil leaking and dripping on pavement from axle #2 differential.

Tractor 43197 MOINL 1/21/2006 393.47 X Axle 1, left wheel seal leaking onto lower brake linings and pads with fresh oil and drips visible.

Ft. Collins Colorado POE 3/22/2006 396.3(a)(1) X Inspection/repair and maintenance parts and accessories, red glad hand with improper leaking at connection. Repaired at site.

Ft. Collins Colorado POE 4/1/2006 396.3A1B Brakes (general)--quick release valve leaking air when brakes are applied in front of axle #1.

Ft. Collins Colorado POE 5/7/2006 393.45(a)(4) X X Brake house/tubing kinking,(Red) emergency air hose to trailer supply, pinched, kinked, restricting air flow to trailer service brakes.

Ft. Collins Colorado POE 9/6/2006 393.47 Inadequate brake lining for safe stopping, brake lining with crack axle #1 left side lower lining with 1-3/8" crack.

Raton New Mexico POE 9/6/2006 393.47(a) Inadequate brakes for safe stopping (Axle 1 left side brake lining has a crack approximately 1 3/8" long.)

INL 12/1/2006 393.9(a) X No/defective turn/hazard lamp as required.

Out-of-Service

Ft. Collins Colorado POE 6/11/2006

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Tractor 43480 MOINL 2/24/2006 393.32 Improper electrical connections- not latched- rear of cab- corrected on site.

Ft. Collins Colorado POE 7/24/2006 393.75(a)(3) X Tire flat and or audible air leak, axle #5 passenger side inside dual has leak tire is low and has bolt stuck in tire.

INL 9/22/2006 172.205 Hazardous waste ,manifest not as required (need to use continuation sheet as required.)

Tractor 93795 MORaton New Mexico POE 12/12/2006 396.5(b)

Oil and Leak (left side of engine compartment power steering reservoir low pressure hose leaking around clamp. Power steering fluid leaking and dripping to ground.

Tractor 93796 MOFt. Collins Colorado POE 2/6/2006 393.45(a)(4) Brake hose/tubing kinking, Red (emergency), air hose to trailer supply, pinched, kinked, twisted,

restricting air flow to trailer service brakes.

INL 4/3/2006 393.83(g) X Exhaust leak under truck cab and/or sleeper (leaking from bottom exhaust clamp on flex coming from exhaust manifold.) repaired at scene.

Ft. Collins Colorado POE 5/3/2006 393.47(d) X X Insufficient brake linings, axle #3 left side upper front split lining with 2"+ crack.

Ft. Collins Colorado POE 9/18/2006 393.45(b)(2) Brake hose/tubing chaffing and/or kinking, Left axle 3 broken air line separator rubbing on steel braid line.

INL 12/6/2006 393.11 No/defective light devices/ref/projected - no red and white reflective tape installed on rear of truck mud flaps/fenders as required - corrected on scene.

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Tractor 93797 MOFt. Collins Colorado POE 2/6/2006 393.95(a) Unsecured fire extinguisher, inside driver side tool box.

INL 2/10/2006 397.101(d) X No written route plan - RAM - Driver not able to produce a copy of highway rout plan for transporting HRCQ - inspector gave inspector's copy to driver.

INL 3/23/2006 393.11TL Reflective sheeting missing across top of rear right mud flap on rear of tractor.INL 5/5/2006 393.9(a) Inoperable required lamp over cab right side id lamp inoperable.INL 6/30/2006 396.3(a)(1) Fifth wheel plate air hose for jaws broken - fixed on site- (orange 1/8" hose approx.)INL 8/25/2006 396.3(a)(1) X Exhaust leak on right side forward of cab. Fixed on site.

Tractor 93798 MOFt. Collins Colorado POE 12/28/2005 393.95(a) Unsecured fire extinguisher, inside tool box below bunk.Ft. Collins Colorado POE 7/7/2006 393.47(d) Insufficient brake linings -- axle #1 drivers side lower lining has 1 1/4" crack.Ft. Collins Colorado POE 7/24/2006 393.47(d) Insufficient brake linings - axle #1 drivers side lower lining has a 1 1/4" crack.INL 8/14/2006 396.3(a)(1) Inspection/repair and maintenance and accessories - radiator leaking fluid on front rights side.LANL 9/15/2006 393.201 Cracked bracket left side fire extinguisher bracket approximately 1".

INL 12/1/2006 393.28 Improper or no wiring protection as required-left side undercarriage, bottom of frame, open ended wire needs to be plugged/capped (repaired at scene)

Tractor 93799 MO

Out-of-Service

Page 4 of 5

INL 1/31/2006 393.25(f) X Stop lamp violations - right and left rear stop lamps inoperable on tractor.

Ft. Collins Colorado POE 3/6/2006 393.25(b) Lamps are not visible as required, TOP LEFT "ID" MARKER LAMP INOPERABLE. TOP LEFT CAB.

INL 4/4/2006 393.75(b) X Passenger side steer tire- front tread depth less than 4/32 of inch. (repaired on site.)INL 6/19/2006 393.9(a) Inoperable required lamp - clearance lamp on top of cab, 2nd in from left inoperable.Ft. Collins Colorado POE 7/1/2006 396.5(b) Oil and/or grease leak--oil leaking from axle #3 differential.

393.28 Improper or no wiring protection as required left rear of cab at/to white light.393.28 Improper or no wiring protection uncapped plug under left frame rails.

Ft. Collins Colorado POE 8/21/2006 393.45(d) Brake connections with leaks/quick release valve at axle 2 leaking with service brakes applied; tractor.

172.202(b) Basic description broken by insert of additional information.172.205 Hazardous waste manifest not as required-additional information added in outside areas.

Tractor 99854 MOFt. Collins Colorado POE 12/28/2005 393.9T Inoperable tail lamp, Left rear tractor inoperable.INL 1/22/2006 393.83(g) X Exhaust leak under truck cab and/or sleeper --- Repaired at scene.

Ft. Collins Colorado POE 1/23/2006 396.3(a)(1) Inspection/repair and maintenance parts and accessories/underside of tractor coated with green fluid (appears to be anti-freeze), also on both sides linings axle 2.

Ft. Collins Colorado POE 5/10/2006 393.203(c ) Hood not securely fastened, hood latch not properly secure, left and right side.

INL 6/9/2006 393.207(a) X Axle positioning parts defective/missing/loose - axle 2 right side front spring alignment bold loose - washer spins freely - repaired.

393.78 Windshield washers inoperative393.11 No/defective lighting devices/top right clearance lamp inoperable tractor

393.45(d) Brake connections with leaks/quick release valve at axle 2 leaking with service brakes applied; tractor.

INL 10/16/2006 392.2 Local laws (general)- Carrier's annual hazardous waste permit expired 10-11-06 - Verified expired through Inkom POE.


INL 10/12/2006

INL 7/28/2006

Page 4 of 5


Tractor 99883 MOINL 1/5/2006 393.207(a) X Axle positioning parts defective/missing - axle 2 left side front leaf spring retaining bolt loose - washer

spins freely by hand - tightened by driver.INL 3/24/2006 393.11TL Right rear mud flap on rear of tractor missing reflective sheeting across the top.

Ft. Collins Colorado POE 5/15/2006 393.47(a) X X Inadequate brakes fro safe stopping, 1/38" crack in axle #1 left side brake lining forward lining verified by driver.

Ft. Collins Colorado POE 8/21/2006 393.55(d)(1) ABS Malf circ/signl mfg>2/97, sgl CMV mfg>2/9/; trailer ABS malfunction indicator lamp in cab not operable.

Tractor 99891 MOINL 2/20/2006 396.5 Power steering unite leaking fluid. (seal just in front of steering u-joint.)

Ft. Collins Colorado POE 6/9/2006 393.47(d) Insufficient brake linings--axle #1 passenger side top lining segment has 1" long crack in brake lining.

INL 7/8/2006 393.28 Improper or no wiring protection as required. Exposed wire end without covered protection, left side by air tank, Driver Taped electrical end@ inspection.

INL 12/14/2006 396.3(a)(1) Air line supplying air to fifth wheel slider cracked allowing air to escape.

Tractor 99898 MOFt Collins Colorado POE 1/7/2006 393 203 (c ) Hood not securely fastened, Hood latch not properly secure. Left and right side, un latched, repaired

Out-of-Service

Page 5 of 5

Ft. Collins Colorado POE 1/7/2006 393.203 (c ) on site.

INL 7/1/2006 393.45(d) Brake connections with leaks/constrictions - air leak from relay valve forward and above axle 2 - shown to driver.

Ft. Collins Colorado POE 7/12/2006 393.78 Windshield wipers inoperative defective, washer fluid not as required, not working during inspection.

Tractor A44035 MOFt. Collins Colorado POE 9/26/2006 393.95(a) Unsecured firs extinguisher/corrected at scene.Ft. Collins Colorado POE 11/8/2006 393.25(f) X Stop lamp violations, right rear trailer with stop lamp inoperable, repaired on site.

Page 5 of 5

APPENDIX

B

Trailer Violations (arranged by license plate)


Trailer E201205 USINL 2/11/2006 393.104(f)(3) X Loose/unfastened tiedown - TRUPACT #200, Left front tiedown loose.

393.110(d) X Large/odd-shaped cargo not adequately secured. Gap between the locking plate and compression plate exceeds 0.10" on 1st cask left rear.

393.110(d) X Large/odd-shaped cargo not adequately secured. Cam handle locking pin is missing 2nd Cask left rear.

Trailer E201206 USRaton New Mexico POE 9/13/2006 393.9(a) Inoperable required lamp (License plate lamp at rear of trailer is inoperable)

Ft. Collins Colorado POE 10/3/2006 393.48(a) Defective brakes, Jam-nut loose on push-rod, chaffing against mounting bracket of brake chamber, not allowing full release of brakes.

Trailer E201207 USINL 1/25/2006 396.3(a)(1)

Inspection/repair and maintenance parts and accessories seal leak at axle 4 left tide hub oil in the add indication mark.

Out-of-Service

Savannah River Site 5/16/2006

Page 1 of 6

Trailer E201208 USSavannah River Site 4/3/2006 393.55(d)(3) ABS malf indctr conec from towed CMV mfg>2/01 lamp inoperable right rear trailer.

Trailer E201209 USLoving Inspection Site 7/12/2006 396.3(a)(1)

Inspection/repair and maintenance parts and accessories - Axle 5 LT fender mounting bracket broken.

Trailer E201211 USFt. Collins Colorado POE 12/29/2005 172.406(f) Label obscured by marking or attachment, TRUPACT #156, with illegible labels at left and right sides,

indicating activity, (tbq,) Also TRUPACT #129 at right side.INL 2/24/2006 393.9 Inoperable lamp (other than head/tail) - right side marker light

Trailer E201213 USINL 2/10/2006 393.110(d) X Large/odd-shaped cargo not adeq. Secured - left front tiedown on TRUPACT-II #184 Loose -

measures >0.100" w/drivers gage - tightened by driver.Ft. Collins Colorado POE 6/23/2006 393.48(a) X Inoperative/defective brakes Jam nut hitting brake chamber holder.

Trailer E201214 USINL 1/16/2006 393.9

Inoperable lamp (other than head/tail) - left side lamp inoperable, lamp flashed when signal activated. Lamp does not stay on when all lights are on.

Trailer E201215 USINL 6/22/2006 393.106(b) X Tie down violation, TP179 no-go gauge violation left rear side.

Page 1 of 6


Trailer E201216 USINL 1/5/2006 392.9(a)(2) X Failing to secure vehicle equipment - trailer mounted spare tire not secure - restraining bar missing -

replaced by driver.INL 5/1/2006 393.104(f)(3) X Loose/unfastened tiedown - out of adjustment U-bolt left front 138 cask corrected on scene.

393.45(d) X Service glad-hand has audible air leak when brakes applied.393.110(d) X Front Trupact rear tiedown on driver side too tight.

Trailer E201217 USINL 10/28/2006 ??03.28

Pigtail electrical connection between truck and trailer, prongs possible loose causing lights on trailer to not work/flicker. Repaired on scene so lights work.

Trailer E201218 USFt. Collins Colorado POE 5/31/2006 393.75(c ) X X Tire-other tread depth less than 2/32 of inch, axle #5 left inside tire, trailer.

INL 10/13/2006 172.310(a) Gross weight on package marked as 12,802 lbs on left package side 13,802 lbs on right side - Shipping paper state 13,802 lbs for Trupact 501 (corrected on scene)

Trailer E201219USLarge/odd-shaped care not adequately secure tie down locking device not installed as required

Out-of-Service

INL 8/8/2006

Page 2 of 6

Ft. Collins Colorado POE 12/28/2005 393.110(d) Large/odd-shaped care not adequately secure , tie down locking device not installed as required trupact #149 at left front installed at edge of lock nut.

Ft. Collins Colorado POE 4/11/2006 172.403(a) Cask #507 with CSI label deteriorated bottom side of label missing.

Trailer E201220 USFt. Collins Colorado POE 4/19/2006 393.75 (c ) Tire-other tread depth less than 2/32 of inch, axle #4 left inside tire.

393.110(d) X Trupact tie down too loose, exceeds 0.100 on trupact # 150 front left tiedown. Repaired at scene.

393.110(d) X Trupact tie down too loose, exceeds 0.100 on trupact # 141 rear right tiedown. Repaired at scene.

Trailer E201221 USINL 2/27/2006 393.75(a)(1) X Tire-ply or belt material exposed, axle 4 right outside tire separated and exposing frayed cords in

sidewall.

INL 6/9/2006 393.110(d) X Large/odd shaped cargo not adeq. Secured - gap between compression block and plate >0.1000" as measured with drivers go/no-go gage on trupact-II #137 right front.

172.304(a)(1) Package marking not durable, English or print-- package marking weight/mass of cargo damaged rear passenger side cast.

393.203(b) X Cab/body improperly secured to frame--rear drivers side fender on trailer has loose bolt and moves with hand pressure.

Trailer E201222 USINL 2/5/2006 393.100(a) X No or improper load securement 1 required tie down out of adjustment. Repaired at inspection

location.Raton New Mexico POE 10/22/2006 393.9(a) X Inoperable required lamp; left turn signal inoperable n trailer.

INL 5/2/2006


Page 2 of 6


Trailer E201223 USFt. Collins Colorado POE 7/26/2006 393.110(d) Large/odd shaped cargo not adequately secured, cask #150 left front tie-down assembly with loose

secondary securement at the forked locking plate, lock plate shaft bent.INL 12/8/2006 393.104(b) X Damaged securement tiedown bolt; Cask 169 right front anchor bolt bent. Replaced by driver.

Trailer E201226 USINL 2/14/2006 393.110(d) X Large/odd-shaped cargo not adeq. Secured.

Raton New Mexico POE 3/29/2006 396.3(a)(1) Inspection/repair and maintenances parts and accessories (between axle 4 & 5 1 out of 4 bolts is missing on air reservoir tank.)

Raton New Mexico POE 4/22/2006 393.50 X Inadequate reservoir for air/vacuum brakes (Air reservoir between axle 4-5 is missing both fasteners on right side and is separated from it attachment point.

Ft. Collins Colorado POE 7/12/2006 393.110(d) X Large odd shaped cargo not adequately secured, trupac-II #208 with tiedown locking device not as required, not properly attached, secured off locking plate, adjustment nut repaired on site.

Trailer E201227 US393.25(f) Stop lamp violations -right side inoperable393.25(f) X Stop lamp violations -left side inoperable

Out-of-Service

SC 28 Aiken County 9/13/2006

Page 3 of 6

Trailer E201228 US393.9(a) X Inoperable required lamp - Right brake lamp rear most vehicle.393.9(a) X Inoperable required lamp - Left brake lamp rear most vehicle.

Trailer E201229USINL 4/28/2006 393.104(f)(3) X Loose/unfastened tiedown - TRUPACT #145, right front tiedown.

Trailer E201231 USFt. Collins Colorado POE 12/28/2005 393.110(d) X Large/odd-shaped cargo not adequately secured. TRUPACT #504 @ left front position, with loose tie-

down assy. Not secured as required. Repaired on site.393.9(a) X Inoperable required lamp, right rear turn signal.393.19 No/defective turn/hazard lamp as required; right rear hazard lamp inoperative.

Trailer E201232 USINL 2/7/2006 393.45 X Brake tubing and hose adequacy audible air at blue air tubing near glad hand.

Trailer E201233 USFt. Collins Colorado POE 4/25/2006 396.3(a)(1)

Inspection/repair and maintenance parts and accessories, Trailer fender support bracket mounting cracked or broken, left extreme rear axle #5.

Trailer E201235 USLoving Inspection Site 10/6/2006 396.3A1B X Brakes; audible air leak at brake chamber axle 4 right broken connection.

Loving Inspection Site 5/9/2006

Raton New Mexico POE 4/19/2006

Page 3 of 6


Trailer E201237 USINL 1/6/2006 393.110(d) X Large/odd-shaped cargo not adequately secured - right rear tiedown on cask #159 loose as

measured with driver's "go/no-go" gag - tightened by driver.

Ft. Collins Colorado POE 6/5/2006 396.3(a)(1) Inspection/repair and maintenance parts and accessories, Axle #5 left side with cracked front fender mount, cracked rear fender mount, in danger of separation, fixed on site.

Trailer E201238 USINL 2/9/2006 393.110(d) X Large/odd-shaped cargo not adequately secured - front right tie down on trupact #150 too tight.Savannah River Site 4/18/2006 393.55(d)(3) ABS malf indctr conec from towed CMV mfg>2/01 left side rear of trailer inoperable.

Trailer E28240 US396.5(b) Oil leak from hub seal, axle 4 right.396.3(a)(1) One of three fasteners loose on hubometer, axle 4 right.

Loving Inspection Site 8/22/2006 396.3(a)(1) Inspection/repair and maintenance parts and accessories, axle 4 right 1 of 3 hubometer fasteners loose.

393.19 X No/defective turn/hazard lamp as required, rear tractor with inoperable turn signals, left and right sides, repaired on site.

393 25(f) X Stop lamp violations left and right tractor at rear with inoperable stop lamps repaired on site

Out-of-Service

Loving Inspection Site 6/14/2006


Page 4 of 6

393.25(f) X Stop lamp violations, left and right tractor at rear with inoperable stop lamps, repaired on site.

Trailer E201242 USLoving Inspection Site 10/3/2006 393.110(d) X

Large/odd-shaped cargo not adequately secured - The gap between the compression block and the compression plate exceeds 0.100"

Trailer E201243 USFt. Collins Colorado POE 5/1/2006 396.3(a)(1) Inspection/repair and maintenance parts and accessories, trailer fender support cracked or broken at

weld for gusset, axle #5 left side.

Ft. Collins Colorado POE 5/10/2006 396.3(a)(1) Inspection/repair and maintenance parts and accessories, trailer fender mounting cracked or broken at gusset end, left rear at axle #5.

Trailer E201244 USINL 6/5/2006 393.102(a) X Tie down 158 right rear loose. Repaired at location.

INL 7/17/2006 393.110(d) X Large/odd shaped cargo not adequately secured, last tiedown right side gauge will not seat to shoulder.

Trailer E201247 USINL 7/27/2006 393.104(f)(3) X Loose/unfastened tiedown. Two of four tiedowns loose on Trupact 515 (Right forward and left rear).

Corrected at scene.

Ft. Collins Colorado POE 7/28/2006 393.110(d) Large/odd-shaped cargo not adequately secured. Cask # 515 right front tie-down assembly, with loose secondary securement at the forked locking plate, lock plate shaft bent.

Page 4 of 6


Trailer E28248 USINL 1/31/2006 393.25(f) X Stop lamp violations - right and left stop lamps on trailer inoperable.Ft. Collins Colorado POE 4/30/2006 393.47(d) Insufficient brake linings - 1/4" x 1/4" rock chip axle #5 passenger side upper ling segment.

Ft. Collins Colorado POE 5/8/2006 393.47(d) Insufficient brake linings, 1/4"x1/4" void in lining, axle #5 right upper lining segment, also several smaller voids.

INL 7/17/2006 393.47(d) X Insufficient brake linings, axle 5 right brake lining has a void over 1/16" and a crake approximately 1/2"

Trailer E201250 USFt. Collins Colorado POE 3/24/2006 393.110(d) X Large/odd-shaped cargo not adeq. Secured -- rear drivers side tiedown drivers side gap less than,

070".

Richland Washington 7/25/2006 393.110(d) X Trupact-II Package Tie Down Assembly/Compression securement plate less than 0.070 gap spacing.

Trailer E28098 USFt. Collins Colorado POE 1/6/2006 392.9

Driver load securement, Spare tire not properly secured, in danger of separation. Rear support bracket with broken weld, at mounting to spare tire wheel.

Out-of-Service

Page 5 of 6

Trailer E28266 USINL 8/8/2006 393.110(d) X Front Trupact right side rear tiedown to loose. Large end of go no go gauge slides through.

Trailer E28275 USFt. Collins Colorado POE 7/25/2006 393.55(e)

abs ALL OTHER CMV'S mfg >2/98 AIR BRAKE SYSTEM, ABS Malfunction indicator lamp does not work; trailer.

Trailer E28276 USFt. Collins Colorado POE 2/6/2006 393.25(b) Lamps are not visible as required, Right rear side marker lamp inoperable.INL 7/10/2006 393.110(d) Tie down on right side front Trupact too tight, less than 0.070

Trailer E28277 USINL 1/20/2006 172.310(b) RAM package not marked "Type B (U)" - TRUPACT 511 marked once with "TYPE B" and twice with

"TYPE B U" but no with "TYPE B(U)" as required corrected on site.393.110(d) X Large/odd shaped cargo not adequately secured.393.110(d) X Large/odd shaped cargo not adequately secured.

Ft. Collins Colorado POE 8/8/2006 393.47(d) Insufficient brake linings, Axle #5 right side, lower lining with multiple cracks (3), in lining, allowed to continue to home shop for evaluation and repair.

INL 7/16/2006

Page 5 of 6


Trailer E28278 USINL 1/4/2006 393.110(d) X Large/odd-shaped cargo not adeq. Secured (measured with driver go-nogo gauge, driver repaired @

inspection.)INL 1/28/2006 393.110(d) X tiedown right forward side cask 158 too tight - fixed on site.

Ft. Collins Colorado POE 5/7/2006 172.516(c )(6) Placard damaged, deteriorated, or obscured, Rear "HRCQ" placard not as required, lower left corner missing.

INL 6/2/2006 396.3(a)(1) Inspection/repair and maintenance parts and accessories oil seal leaking from axle 5 right causing low old level.

Trailer E28280 USINL 1/7/2006 393.110(d) X Large/odd shaped cargo not adeq. Secured - right front tiedown loose when measured with driver's

"go/no-go" gage - tightened by driver.

Ft. Collins Colorado POE 1/8/2006 393.25(e) Lamp not steady burning, Side marker(s) inoperable, left front trailer inoperable, repaired on site.

Ft. Collins Colorado POE 4/20/2006 393.25(b) Lamps are not visible as required, Left front amberside maker lamp malfunctioning, intermittent strobing.

Ft. Collins Colorado POE 7/24/2006 172.403(a) RAM Label requirement had 5417 tbq on drivers side should have been .05417

T il E28282 US

Out-of-Service

Page 6 of 6

Trailer E28282 USFt. Collins Colorado POE 9/6/2006 396.3(a)(1) X X

Inspection/repair and maintenance parts and accessories, air leaking from brake chamber when brakes applied, bent securement bolt allowing air to escape, axle #4 left side.

Trailer E28283 USFt. Collins Colorado POE 12/14/2005 396.3(a)(1) Inspection/repair and maintenance parts and accessories, Trailer fender mount cracked, axle #5 left

side.INL 7/7/2006 396.5(b) Oil and/or grease leak axle 4 left side hub, inside.

Ft. Collins Colorado POE 8/15/2006 393.110(d) X X Large/odd shaped cargo not adequately secured, tiedown locking device @ Trupact @510 left, rear with locking plate improperly installed (not installed at all).

Trailer E28284 USINL 5/14/2006 393.104(f)(3) X

Loose/unfastened tiedown. Cask 515 left front securement device loose. Large end of go/no go easily placed in gap. Repaired at scene.

Trailer E28286 USINL 7/7/2006 393.9(a) Left rear side marker lamp on trailer inoperable.

Ft. Collins Colorado POE 7/17/2006 393.110(d) X Large/odd shaped cargo not adequately secured at middle of tiedown gap exceeded .100" no go gauge goes into tiedown device.

Page 6 of 6

APPENDIX

C

Driver Violations


Driver 0002 NMINL 2/27/2006 395.8 Log violation (general/form and manner), NO CITY/STATE annotated on stop at 1245 on

022206. Only showed "WIPP"

Ft. Collins Colorado POE 5/3/2006 395.8 Log violations (general/form and manner). Must log city and state where duty status changes occur. 5/2/06 no state logged for green river, UT.

395.8(e) False report of drivers record of duty status - co-driver recorded time spent out of sleeper as sleeper time from 1000 to about 1115 hours on 6-9-06

395.8(f)(1)) Drivers record of duty status not current - co-driver's log shows his status as in sleeper on 6-9-06 at 1330 when out of truck assisting driver with inspection.

Ft. Collins Colorado POE 6/17/2006 395.3(a)(2) Drove .75 hours over 14 hours on 06/16/2006 through 06/16/2006, after being on duty more than 1 hrs, 15.75 total hours.

Driver 0711 NMINL 6/1/2006 395.8 Log violation need total miles driving listed on log book for 5/19/06.

INL 6/9/2006

Out-of-Service

Page 1 of 5

Driver 0730 NMFt. Collins Colorado POE 3/4/2006 395.8

Log violation, Must log city and state where duty status changes occur. Or nearest town/city and state. Cannot only show "WIPP" for location. 3/2/6

Driver 0789 TXFt. Collins Colorado POE 12/8/2006 395.8

Log violation, inaccurate log entry. Co-driver not logging "on duty" time for badgeing processes, per driver. 7:30 to approximately 7.45-8:00 on 12/7/6.

Driver 0884 NMFt. Collins Colorado POE 9/8/2006 395.8 Log violation (general/form and manner)-- driver has 2 days dated 9-7-06.

Driver 0908 NMINL 8/1/2006 395.8 Log violations (general/form and manner), did not sign log page for 072706.

Driver 1254 NMFt. Collins Colorado POE 8/27/2006 395.8 Log violation (general/form and manner)--miss dating Augusts log pages as Junes.

Driver 1680 NMFt. Collins Colorado POE 2/19/2006 395.8 Log violation (general/form and manner). 02/14/06. Drive time shown by both 1330-1500.

Driver 1710 FL INL 1/6/2006 395.8 Log violation (general/form and manner) - driver dated 1-5-06 log sheet as 1-3-06.

Page 1 of 5


Driver 2240 FLINL 1/6/2006 395.8 Log violation (general/form and manner) - co-driver failed to sign 1-5-06 log sheet.

Driver 3446 NMFt. Collins Colorado POE 5/14/2006 395.8(k)(2) X X Driver failing to retain previous 7 days logs - driver only has log pages for 5-9 to today does not

have 5-7. 5-8

INL 7/30/2006 395.8Log violation (general/form and manner) did not log change of duty status location when coming on duty not driving n 073006 at 0700

Driver 3885 TNINL 1/4/2006 395.8 Log violation (general/form and manner) Total mileage not recorded on 01-03-06

Driver 3930 NMFt. Collins Colorado POE 7/6/2006 395.8

Log violations, Inaccurate log entry, driver must draw line indicating starting time and ending time for all duty status entries, none for 6.30.06. See 395.8(h)(1).

Out-of-Service

Page 2 of 5

Driver 4249 NMINL 12/28/2005 395.8(f)(1) Drivers record of duty status not correct - co-drivers last entry for 12-28-05 shows status in

"SLEEPER" but actually out of sleeper assisting with inspection.

INL 7/14/2006 395.8 Log violation (general/form and manner) on 071406 at 0300 logged safety check in "Malad, Ut", no such place, should be Malad, Id.

Driver 4532 NMINL 7/30/2006 395.8 Log violation (general/form and manner) logged on 072406 at 1130 a stop at "mm112 rest area,

CO", no nearest city shown. Same issue on 30th at 0300.INL 12/14/2006 395.8 Log violation (general/form and manner) no mileage annotated on 120806.

Driver 4859 NMFt. Collins Colorado POE 5/8/2006 396.9(d)(2)

Failure to correct defects, inspection on 4/30 with same violations as noted on this inspection must comply with repairs before next dispatched. See attached.

Driver 5617 NMINL 9/23/2006 395.8 Log violation (general/form and manner) 9/18/6 Mileage not recorded in log book.

Driver 5741 NMRaton New Mexico POE 2/4/2006 395.3(a)(2) 14 Hour rule violation (Property) from 11:15 a.m. to 11:30 a.m. on 2/04/2006.

Ft. Collins Colorado POE 5/31/2006 395.8Log violation (general/form and manner), Co-driver not in compliance with regs, must draw line in appropriate duty status as required.

Page 2 of 5


Driver 5985 NMINL 9/19/2006 395.3(a)(2) 14 Hour rule violation (property)- on 9/15 drove total on 1.25 hrs in violation. 0030 hrs to 0100

hrs and 0145 hrs to 0230 hrs.

Driver 6095 NMINL 2/8/2006 395.8 Log violation (general/form and manner) 020306 at 1800, fail to put nearest city.

INL 4/1/2006 395.8(f)(1) Drivers record of duty status not current - co-driver logged in sleeper on 3-1-06 from 1000 hours but has been out talking with other drivers.

INL 4/25/2006 392.2 Driver's license mutilated (license broke in half) in violation of Idaho code 49-331 (1).

INL 6/11/2006 392.2 X Driver's license mutilated (license broke in half) in violation of Idaho code 49-331 (1). Verbally warned on 2/22/06. Written up on 4/25/06.

Driver 6425 NMINL 7/14/2006 395.8 Log violation (General/Form and manner) 070906 at 0600, logged stop at Fort Collins Port with

no state, 2230, logged WIPP for stop, improper location ID.

Driver 6447 NM

Out-of-Service

Page 3 of 5

Driver 6447 NM

INL 8/1/2006 395.8Log violation (general/form and manner) 072806 at 1715, logged stop in "Cortex NM" actually stopped in Cortes, CO.

Ft. Collins Colorado POE 10/3/2006 395.8 Log violation, Inaccurate log entry, logging "off duty" in a 24 hr period, must log "on duty" days separate from "off duty" days.

Driver 6891 NMINL 1/7/2006 395.8(k)(2)

Driver failing to retain previous 7 days logs - driver not able to produce log sheet for 12-31-05.

Driver 7025 NMINL 1/22/2006 395.8 Log violation (general/form and manner) Total miles driving for 1/19/06 not noted on log.

395.3(a)(1) 11 hour rule violations (Property in violation on 2/14/06 from 11:45-12:45, 13:00-13:30, 15:45-16:30, 16:45-19:00, & 19:15 hours until 21:00 hours.

395.3(a)(2) 11 hour rule violations (Property in violation on 2/14/06 from 08:45-11:00, 11:15-12:45, 13:00-13:30, 15:45-16:30, 16:45-19:00, & 19:15 thru 21:00 hours.

INL 6/9/2006 395.8(e) False report of drivers record of duty status - Driver recorded time spent out of sleeper as sleeper time from 1000 to about 1115 hours on 6-9-06

Driver 7203 NM

INL 7/14/2006 395.8 Log violation (general/form and manner) on 71206 did not fill in co-driver, sign, or total hours.Ft. Collins Colorado POE 10/6/2006 395.8 Log violation (general/form and manner)--fails to record city and state where change of duty

status occurs on 10-2-06 @ 4:30 pm

INL 2/20/2006

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Driver 7289 NMINL 9/25/2006 395.3(a)(2) 14 Hour rule violation (property) on 091906 at 1015 to 1030.

Driver7395 TX395.3(a)(2) 14 Hour rule violation (Property) on 022706 at 1715 to 1745

395.8 Log violation (general form and manner), change of duty status not in compliance with 395.8( c) choices 1, 2 or 3, no nearest city, on 022406 at 0600

395.8 Log violation (general form and manner), change of duty status not in compliance with 395.8( c) choices 1, 2 or 3, no nearest city, on 022406 at 0600 and 0930

395.8 Log violation, inaccurate log entry, log entries for 4/18/06, 4/19/06, not legible on grid entries. Entries must be legible - see 395.8(f)(2)

398..8(f)(1)Log book not current, last entry at Little America, WY - Driving on 04/25/2006, at time of this inspection, co-driver in sleeper.

Driver 7561 NMFt. Collins Colorado POE 7/31/2006 395.8(f)(1) Log book not current, last entry at Rawlins, WY 21:45 on 07/30/2006, logged driving while actual

activities in sleeper driver log driving from Rawlins to CO POE

Out-of-Service

INL 2/28/2006


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activities in sleeper, driver log driving from Rawlins to CO. POE.INL 10/8/2006 395.8 Log violation (general/form and manner) 10/3/06 mileage not recorded in log book.

Driver 7881 NMFt. Collins Colorado POE 5/31/2006 395.8 Log violation, inaccurate log entry, driver logging "on duty" days with "off duty" days, only

multiple "off duty" allowed on one log entry. "on duty" 1 sheet.

INL 7/30/2006 395.8 Log violation (general/form and manner) 072306 logged stop at 0300 as "ID POE, ID" no nearest city shown.

Driver 8147 NMINL 2/4/2006 383.21(a) Has more than 1 drivers license (Alabama, New Mexico)Ft. Collins Colorado POE 2/19/2006 395.8 Log violation (general/form and manner). 02/14/06. Drive time shown by both 1330-1500.

INL 8/8/2006 395.8Co-driver logbook shows driving time from 0945 until 1230 when he went into the sleeper. Time logged incorrectly should have been on duty not driving.

Driver 8293 NMINL 7/14/2006 395.8 Log violation (general/form and manner) 7/10/06 24 hour break down not logged on right side of

log book.

Ft. Collins Colorado POE 10/3/2006 395.8 Log violation, Inaccurate log entry, logging "off duty" when "on duty" status for 9/21/06, in a 24 hr period, must show "on duty" days separate from "off duty" days.

Driver 8524 NMINL 4/28/2006 395.8

Log Violation (genera/form and manner) mileage not recorded in log for 4/21/06 (shows driving 2.25 hrs.)

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Driver 8880 TX395.8 Log violation, inaccurate log entry, co-driver logs two days of incomplete entries for 2/25/06,

then indicates "off duty" for the same, 2/25 through 3/3/06.

395.8Log violation, inaccurate log entry, co-driver does not list city, state, village per definition of 395.8 - change of duty status, cannot log just "INL, ID"

Driver 8956 AZINL 4/21/2006 383.51(a) X

Driving a CMV (CDL) while disqualified - Arizona CDL medical suspension, effect 4/19/2006 (CDL reinstate 4-21-06)

INL 5/2/2006 395.8 Log violation (general/form and manner). Fail to annotate mileage on 4/28/06.INL 7/1/2006 383.51(a) X Disqualified co-driver - Co-driver's license status shows "canceled" through AZ.

Driver 9058 NMFt. Collins Colorado POE 4/19/2006 397.101(e)(2) Copy of training record/route (RAM) HRCQ training certificate does not reflect new CDL number

from NM. But old CDL info. For Tenn.

INL 4/24/2006 383.21(a) Operating a CMV with more than 1 driver license, drivers license # 3568 still valid in Tennessee as well as his New Mexico driver's license


Out-of-Service

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( ) as well as his New Mexico driver s license.

Driver 9120 NMFt. Collins Colorado POE 10/17/2006 395.8 Log violation, Inaccurate log entry, Co-driver logging off duty when driver in operation of CMV,

10/15/06, 19:45 to 22:00 and 22:15 to 12:00 Midnight.INL 12/14/2006 395.8 Log violation (general/form and manner) mileage not logged 12/07/06.

Driver 9155 NMFt. Collins Colorado POE 4/19/2006 397.101(e)(2)

Copy of training record/route (RAM) HRCQ training certificate does not reflect new CDL number from NM. But old CDL info. For Tenn.

Driver 9366 TXFt. Collins Colorado POE 6/14/2006 395.8

Log violation (general/form and manner), must log city and state where duty status changes occur, missing state indication at "crescent junction" (UT).

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APPENDIX

D

Non-WIPP Tractor Violations (arranged by license plate)


Tractor 60877 MOMARSHALL I-70 W/B, IL 4/9/2006 396.3(a)(1) X X

Inspection/repair and maintenance parts and accessories (air hose disconnected at firewall).

Tractor 88735 MOElizabeth City, Union, NJ 7/20/2006 385.415(a)(1) Failure to have HM safety permit (or number) in vehicle (carrier faxed same to driver this date)

Elizabeth City, Union, NJ 7/20/2006 393.45 X Right steering axle brake hose-cracked/split through outer reinforcement ply.

Tractor 95272 MOPORTSMOUTH MARINE TERMINAL, VA 12/3/2006 393.9(a) Inoperable required lamp - right clearance lamp inop.

DIV 1 GREEN SCALES - SOUTH, TN 12/4/2006 393.9(a) Inoperable required lamp. 1 of 5 cab lights inoperable.

Out-of-Service

Page 1 of 2

Tractor 95359 MOCHAMPLAIN (US CUSTOMS), NY 4/18/2006 390.21(b)

Carrier name and USDOT reqd; not displayed- displaying USDOT #513601 and AATCO as carrier name.

Tractor 95386 MOSAN JON MCSS, NM 11/2/2006 393.45(b)(2) Brake hoses on axle 2 left side from brake chamber to relay valve are chaffing on each other.

SAN JON MCSS, NM 11/2/2006 393.75(a) Axle 2 left inside tire is low, has 52 lbs of pressure.

Tractor 97406 MOMARSHALL I-70 W/B, IL 1/24/2006 393.95(a) X Discharged fire extinguisher, exterior fire extinguisher shows discharged.

Tractor 98217-HY TNBARNWELL WASTE DISPOSAL SITE, SC 10/5/2006 385.415(a)(1)

Violation of HM safety permit. No level VI pre-trip inspection conducted at point of origin. 385.415(b)(1)

Tractor 99848 MOSRS, SC 6/29/2006 396.5(b) Oil and/or grease leak location 3rd axle drive shaft into hog head, seal leaking.

Tractor L352288-3 PQMARSHALL I-70 W/B, IL 12/18/2006 173.427(a)(iv) no instructions for exclusive use pkg LSA

Page 1 of 2


Tractor PP3447 ONSAN JON MCSS, NM 4/5/2006 393.83(g) X Exhaust leak under sleeper right side at the flex pipe.MARSHALL I-70 W/B, IL 10/26/2006 173.427(a)(iv) No instructions for exclusive use pkd LSA.

Tractor PP7404 ONKIRKWOOD (NB),NY 8/16/2006 393.45(b)(2) Brake hose chafing on decking between tractor and trailer-service side supply.

Tractor PP9373 ONMARSHALL I-70 W/B, IL 10/26/2006 173.427(a)(iv) No instructions for exclusive use pkd LSA.

Tractor PP9374 ONMARSHALL I-70 W/B, IL 10/26/2006 173.427(a)(iv) No instructions for exclusive use pkd LSA.

Tractor PZ8054 ONORLEANS (WELLESLEY ISLAND), NY 7/6/2006 393.45(b)(2)

Axle 1 left side brake - hose- outer braided cloth wrapping chaffed through to braided wire sheath.

Out-of-Service

Page 2 of 2

Tractor PZ8055 ONSAN JON MCSS, NM 11/22/2006 396.5 Oil leak at the bottom of the engine.

Page 2 of 2

Non-WIPP Trailer Violations (arranged by license plate)


Trailer 864221 MOElizabeth City, Union, NJ 7/20/2006 396.3(a)(1) Axle 4- left side shock absorber bent/brokenBAUSH AND LOMB, SC 7/21/2006 396.3(a)(1) 4TH Axle left side shock absorber is bent/broken.

Trailer C7731R ON393.45(b)(2) brake hoses chafing on frame cross member above axle 4 - axle 4 service and emergency side.392.9(a)(2) X Unsecured dunnage - 4 x 4 wood board completed unsecured on left side of flatbed trailer body.

Trailer E22818 USWEST JEFFERSON, OH 11/28/2005 393.55(e) ABS Malfunction lamps towed CMV mfg.2/98mfg<2/09

Trailer ESS125 USWEST JEFFERSON, OH 12/20/2005 393.55(e) ABS Malfunction lamps towed CMV mfg.2/98mfg<2/09

Out-of-Service

KIRKWOOD (NB),NY 8/16/2006

Page 1 of 3

SRS, SC 12/21/2005 393.55(e) ABS Malfunction lamps towed CMV mfg>2/98mfg<2/09

Trailer FT04440 CA

INL, ID 7/30/2006 393.207(a) XAxle positioning parts defective/missing. (Right side axle 5 on trailer has rear bottom airbag securement bolt loose-backed out approximately 1/4 inch.)

Trailer FT04443 CA396.3A1BA Brake(s) out of adjustment -see chart above (Adjusted on scene)396.301BA X Brake(s) out of adjustment - see chart above (20% o/s criteria met) adjusted on scene.396.3A1BA Brake(s) out of adjustment -see chart above (Adjusted on scene)396.3A1BA Brake(s) out of adjustment -see chart above (Adjusted on scene)

Trailer FT43280 CA393.104(f)(4)

Tiedowns outside rubrails left side strap that secure tire outside of run rail, and box outside of rub rail.

396.3(a)(1)Inspection/repair and maintenance parts and accessories between 3rd and 4th axle location 1 st air reservoir tank relay valve in tank loose.

172.403(f) RAM package 2 labels on opposite sides (2 of 2 yellow II labels missing.172.403(f) RAM package 2 labels on opposite sides (2 of 2 fissile labels missing)172.301(a) No shipping name or ID# on non-bulk

SRS, SC 8/25/2006

SRS, SC 6/29/2006

INL, ID 7/30/2006

Page 1 of 3


Trailer HR82285 ORC4W Foristell, MO 10/19/2006 393.45A4 LT # 4 axle - Two brake hose rubbing on slack adjustor.

Trailer HR82288 ORC4W Foristell, MO 10/19/2006 393.45A4 Axle 4, right side, brake hose rubbing (chaffing) on slack adjuster.

Trailer PN6205 MO396.3A1BA X X Brake(s) our of adjustment - see chart above.

396.3(a)(1) X XInspection/repair and maintenance parts and accessories (axle 5 l outer tire tread cut by loose tarp wench.)

Trailer PP0712 MOMARSHALL I-70 W/B, IL 11/7/2006 393.75(a)(4) X X Tire-cut exposing ply and/or belt material, #4 axle right outside tire.

Trailer PP0786 MOMARSHALL I-70 W/B IL 4/9/2006 393 9(a) X Inoperable lamp, left rear identification light is inoperable.

MARSHALL I-70 W/B, IL 3/28/2006

Out-of-Service

Page 2 of 3

MARSHALL I-70 W/B, IL 4/9/2006 393.9(a) X Inoperable lamp, left rear identification light is inoperable.

Trailer PP0792 MO177.804 Failed to comply with FMSCSR while transporting HM393.126 X No/improper intermodal container securement (* all 4 latching devices not secured as required.

Trailer PP0799 MOMARSHALL I-70 W/B, IL 3/9/2006 172.504(a) X Vehicle not placarded as required (HRCQ side placards on casks which is not a bulk package.)

Trailer PP0807 MOCHANPLAIN PORT OF ENTRY, NY 12/12/2006 393.9(a) Inoperable required lamp - right side upper marker lamp out, fixed roadside.

Trailer PP1019 MOCONNEAUT SCALES, OH 8/29/2005 393.126(b) X Damaged/missing tiedown/securement device, no secondary means of securement.

Trailer PP1115 MO

MARSHALL I-70 W/B, IL 3/9/2006 172.504(a) XImproper highway route control placard on left and right side of non-bulk cask. Front and rear highway route control placard displayed on freight container.

ASHLAND SCALES, OH 8/27/2005

Page 2 of 3


Trailer PT49948 SC393.55(e) ABS Malfunction lamps towed CMV mfg.2/98mfg<2/09393.104(a) Inadequate/damaged securement device/system.

WEST JEFFERSON, OH 12/12/2005 395.55(e) ABS Malfunction lamps towed CMV mfg.2/98mfg<2/09

Trailer RP68315-2 PQ392.2W X Overweight on axle - designated highway393.126(b) X X Damaged/missing tiedown/securement device (rear two locking pins not lockable freely moved)

Trailer X65418 ONKIRKWOOD (NB),NY 6/8/2006 393.104(f)(3) Loose/unfastened tiedown - chain from left rear corner of trailer to right rear top of load loose.GALLUP PORT - ENFORECEMENT, NM 11/8/2006 393.9(a) Inoperable required lamp - License plate lamp.

MARSHALL I-70 W/B, IL 11/18/2006 172.403(g) Failed to label RAM properly, 2 casks on trailer, 3 labels total on cask, 2 labels on cask are for the cask, a third label on the cask is for the total on the truck.

393.104(f)(3) Loose/unfastened tiedown - right front chain loose.392.9(a)(2) X Unsecured dunnage - 4x4 wood board completely unsecured on deck between containers.KIRKWOOD (NB),NY 12/28/2006

MARSHALL I-70 W/B, IL 12/18/2006

WEST JEFFERSON, OH 11/7/2005

Out-of-Service

Page 3 of 3Page 3 of 3

Non-WIPP Driver Violations


Driver 00604 ON

KIRKWOOD (NB),NY 8/16/2006 391.15(a) X XDriving a CMV while disqualified- privileges suspended on 01/11/1993 - failed to answer summons - T/Groveland Livingston County

KIRKWOOD (NB),NY 11/28/2006 395.8 Log violation (general/form and manner) - not listing shipping doc. Manifest # or shipper and commodity as required.

Driver 10604 ONKIRKWOOD (NB),NY 12/22/2005 395.3(a)(2) 14 Hour rule violation (property) - all driving time after 7:15 pm until 9:0 pm on 12/16/2005

Driver 11008 ONKIRKWOOD (NB),NY 6/23/2006 395.8 Log violation (general/form and manner) failed to list city/state CODS 6/22 8:30 PM

Out-of-Service Violation

Page 1 of 1

Driver 21741 MOPORTSMOUTH MARINE TERMINAL, VA 12/3/2006 395.3(a)(1) 11 hour rule violation (property) on 11/28/06 drove from 1915 until 215 hrs.

Driver 26447 NMWEST JEFFERSON, OH 11/7/2005 395.8

Log violation (general/form and manner) - Co-driver incorrectly dated November 4th, 5th & 6th as October 4th, 5th & 6th.

Driver 55617 NMWEST JEFFERSON, OH 11/7/2005 383.23(a)(2) Operating a CMV without a CDL

Driver 60631 ONPREBLE SCALES, OH 10/17/2005 395.3(a)(2) 14 Hour rule violation (property) *19.5 hours on-duty (ONT-MI)

Driver 60822 ONKIRKWOOD (NB),NY 6/23/2006 395.8 Log violation (general/form and manner) no commodity listed.

Driver 70606 ONPREBLE SCALES, OH 10/17/2005 395.3(a)(2) 14 Hour rule violation (property) *39.75 hours 10/11/05-10/13/05 ONT-WI

Driver 72435 OKSRS, SC 8/18/2006 392.2 Local laws (general) (improper tag/registered to a different year truck with a different vin number)

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