Document J3kn4wXj5RdLjv1x59nXykg2X

EPA OECA Air Enforcement Division INSPECTION REPORT Metadata Inspection Date(s): Media: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Importer Contact: FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: Facility Representatives: EPA Inspectors: State Inspector(s): Other Inspector(s): Title: Author: Subject: Keywords: EPA Lead Inspector Signature/Date Supervisor Signature/Date 03/21/2023 Air Title II Mobile Sources Yamagin Tsusho Company Limited Freeport TX CBP Hold Lot 801 Navigation Blvd. Freeport TX 77541 9461 Charleville Blvd Ste. 229 Beverly Hills CA 90212-3017 Los Angeles, CA Rika Vaughn rikavaughn@att.net 310-498-4465 N/A N/A N/A N/A N/A Patrick Croucher Robert Rodriguez, Jr. Leticia Allenburg {name} Mario Jorquera {name} {name} {name} {name} Brian Chodrow Kenni Sue Rosoff CBPO CBPO SCBPO {title} OECA/OCE/AED 2242A {affiliation/mailcode} {affiliation/mailcode} {affiliation/mailcode} {affiliation/mailcode} NHTSA CBP CTAC (713) 677-9854 (832) 250-5548 (832) 758-2833 {phone no.} 202-564-1079 {phone no.} {phone no.} {phone no.} {phone no.} 202-366-9765 202-815-1414 Yamagin Tsusho Company Limited minitruck inspection in Freeport, TX Mario Jorquera Inspection Report Inspection of claimed nonroad minitrucks at CBP Facility Mario Jorquera MARIO {Inspector name} JORQUERA Digitally signed by MARIO JORQUERA Date: 2023.06.09 17:29:57 -04'00' Date Mark Palermo {Supervisor name} Date Yamagin Minitruck (Freeport TX) Inspection Inspection Date 03/21/2023 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA HQ Air Enforcement Division, Vehicle and Engine Branch inspector Mario Jorquera was asked by National Highway Traffic Safety Administration (NHTSA) investigator Brian Chodrow to assist him in inspecting some 30 Kei-type minitrucks that were imported into the port of Freeport, TX. Both EPA and NHTSA regulations require that vehicles such as Kei trucks, which have all of the features necessary for operation on public highways, be limited to 25 miles per hour in order to be considered non-road or low-speed vehicles and thus be eligible for importation. Kei vehicles do not comply with either EPA or NHTSA regulations for motor vehicles suitable for highway use. The purpose of the inspection was to determine if the minitrucks were, in fact, incapable of exceeding 25 mph. For EPA, the purpose was also to determine if those minitrucks newer than Model Year 2002 were certified and had the required EPA Emission Control Information (ECI) labels. FACILITY DESCRIPTION The inspection was conducted at a U.S. Customs and Border Protection (CBP) facility at the port, consisting of an office building and a large fenced asphalt parking lot in which CBP had blocked off and set up a 1/4 mile runway with traffic cones so that the minitrucks could be driven and tested safely. All of the minitrucks were parked alongside the edge of the parking lot. One CBP officer observed the entire testing process. Section II - OBSERVATIONS At 9:15 am, the team, consisting of EPA inspector Jorquera, NHTSA inspector Chodrow and assisted by CBP CTAC Agricultural Specialist K. Sue Rosoff commenced inspections of the minitrucks. There were 9 new minitrucks, all 2022 Daihatsu HiJets with roof carriers. All of these vehicles were imported by Lucas Jackson Imports LLC. Checking for the EPA ECI label required removing a plate in the truck bed fastened with 6 bolts. Upon removal, the engine was observed to have in place an EPA ECI label issued to Mini Truck Certifications LLC, with the Model Year being 2022 and the engine family name of NMITS.6582D2. The label was observed to meet EPA label requirements and contained the correct information for the vehicles in question. Inspectors Jorquera and Chodrow drove several of these vehicles, and none of them exceeded 25 mph. All were governed by an electronic limiter that cut off fuel to the fuel pump when the speed on the speedometer exceeded 40 kph. Another 28 trucks also imported by Lucas Jackson LLC were all older than 21 years, so were not required to be EPA-certified or speed limited. However, they were still required to be speed limited to meet the NHTSA 25-year requirement. All of them had steel blocker plates welded onto the transmission tunnel that effectively prevented the transmission lever from being moved to any gear other than first and reverse. The result was that none of these vehicles that could be driven could exceed 25 mph. Some of these vehicles had dead batteries and could not be driven, so they were pushed aside. 2 Yamagin Minitruck (Freeport TX) Inspection Inspection Date 03/21/2023 A third batch of vehicles with model years between 2003 and 2022 were imported by G&R Imports. All of these vehicles had the same 2022 EPA certification label as the new Daihatsu Hijets and all were either equipped with the electronic governor or the shift lever block plates. None of the ones that could be driven exceeded 25 mph. The others had dead batteries. At 1:45 pm, inspectors Jorquera, Chodrow and Rosoff held a Closing Conference with CBP officers Croucher, Rodriguez and Allenburg and presented their findings. EPA noted that none of the minitrucks inspected had obvious issues with compliance, but that some review of records back at the office would be necessary to make certain of that. NHTSA had some concerns and inspector Chodrow said he would be sending a letter to CBP detailing those concerns. Section III - AREAS OF CONCERN All of the vehicles that EPA examined at this facility that were newer than 21-years-old had the required EPA Emission Control Information labels and all engine family names checked out with EPA's database. All vehicles inspected had the appropriate emission control components and speed limiters. However, EPA inspector Jorquera is concerned that the speed limiters may be easy to remove or bypass, and also that the used vehicles had 2022 ECI labels, something that seemed suspicious. Section IV - FOLLOW UP EPA inspector Jorquera will follow up with discussions with OTAQ to determine the appropriate certification requirements for all trucks that were examined. 3