Document MMw8vJwmeqJdN1YMeGQwaVKk9

Clean Air Act Title II: Tampering Inspection INSPECTION REPORT Version: 3/27/2019 Attached please find the United States Environmental Protection Agency's (EPA's) inspection report of your inspected facility and/or any vehicles/engines identified therein. EPA is providing this report as a matter of agency policy and will contact you again only if needed. Without making a determination that your business or organization is a small business, EPA is also providing you with a link to this Small Business Resources Information Sheet (https://www.epa.gov/compliance/small-business-resourcesinformation-sheet) which provides an array of resources to help small businesses understand and comply with federal and state environmental laws. Inspection Information Inspection Number: R8_CAA_20240730_LECORTZ_01_AUTONATION Inspection Date(s): July 30, 2024 Regulatory Program(s): 40 C.F.R. Parts 85, 86, and 1068 EPA Region/Program EPA Region 8, Enforcement and Compliance Assurance Division, Air and Conducting Inspection: Toxics Enforcement Branch Company Name: AutoNation USA Denver 104 Facility Name: AutoNation USA Denver 104 Facility Physical Location: (street address, building/unit #) (city, state, zip code) 759 W 104th Ave Northglenn, CO 80234 Inspection Report Revision History Revision # Revision Date Reason for Revision Colin LeCortz Field Inspector Name Scott Patefield Name of Approving Official Inspector and Approval Branch Manager Title Signature 7/31/2024 Date SCOTT PATEFIELD Date: 2024.08.01 14:58:15 -06'00' Digitally signed by SCOTT PATEFIELD Signature Date U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 1 of 7 Clean Air Act Title II: Tampering Inspection Version: 3/27/2019 U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 2 of 7 Clean Air Act Title II: Tampering Inspection Version: 3/27/2019 FACILITY INSPECTION WORKSHEET (Supplemental notes or narrative format may be used as preferred). General Inspection Information Facility Name: AutoNation USA Denver 104 Inspection Date 7/30/2024 Facility Address: 759 W 104th Ave, Northglenn, CO 80234 Arrival/Departure Time Inspection Number/ID: 9:00 AM 10:05 AM R8_CAA_20240730_LECORTZ_01_ AUTONATION Primary Facility Representative & Title: Facility Contact Phone/Email: Ian Merten, General Manager Ian Merten MERTENI@autonation.com 720-923-1120 Inspector(s): Colin LeCortz (EPA) Paul Darrah (CDPHE) Raymond Elick (CDPHE) Brad Shakeshaft (CDPHE) Time Inspector Presented Credentials: Permission to Enter Facility Granted? If Yes, by whom? If No, explain. Photographer Name: 9:10 AM Yes No Yes, Ian Compliance Assistance Reference Materials Provided to Facility SBREFA Form Memo 1A Exhaust Repair Guidelines Tampering Brochure Engine Switch Fact Sheet Other: Anti-Tampering Fact Sheet & Regulation Colin LeCortz IMG_1155-IMG_1158 Photograph Range: On July 30, 2024, inspectors from the U.S. Environmental Protection Agency Region 8 (EPA) and Colorado Department of Public Health and Environment (CDPHE) conducted a Clean Air Act Title II Motor Vehicle Emissions inspection at AutoNation USA Denver 104 (AutoNation). Notes (e.g. compliance actions taken by facility, purchased samples, other relevant background, etc.): AutoNation is a dealership that buys and sells new and used cars. AutoNation's general manager provided information to the inspectors about the operation of purchasing vehicles that may have emission controls removed. AutoNation conducts a 125-point mechanical inspection on incoming vehicles to be sold and confirmed verbally that no vehicles are sold in Colorado if the vehicle comes in as a trade-in with tampered emissions components. Depending on the initial review of a vehicle AutoNation may not conduct a 125-point mechanical inspection if obvious defects are visible (See Compliance Assistance below). The inspectors received the 125point inspection check sheet and confirmed that exhaust system and muffler(s), catalytic converter, and emission equipment operation and vacuum hoses were present on the sheets to be reviewed by technicians per vehicle. On a case-by-case basis a vehicle will either be repaired to original equipment manufacturer (OEM) factory controls or will be sent to AutoNation Auto Auction located in Houston, Texas (Auto Auction). AutoNation sells approximately 100 vehicles per month, with about 5 being diesel. AutoNation has approximately 4 technicians and 11 salespersons. A facility walkthrough occurred at 9:22 am. Inspectors reviewed the inventory and U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 3 of 7 Clean Air Act Title II: Tampering Inspection Version: 3/27/2019 selected 4 vehicles to inspect, discussed further below under Vehicles Inspected/Observed. One 2009 Ford F-250 (see photo log IMG_1155-IMG_1158) had emission components removed and was configured with a straight pipe, EGR block-off plate, and did not have a code for check engine light according to inspection records provided by AutoNation, therefore additionally the computer can be presumed to be re-coded to operate the vehicle without emission controls. AutoNation provided records for the 2009 Ford F-250 documenting that the emission control equipment was missing or tampered. AutoNation planned to send this vehicle to Auto Auction without re-installing OEM factory emission controls. The EPA Inspector called AutoNation later in the day, at 2:30 PM on July 30, 2024, to further discuss the transfer of vehicles to AutoNation Auto Auction in Houston, Texas. The AutoNation general manager described the process as trailering the vehicles to Auto Auction that are not sold at AutoNation. The vehicle is then sold at auction, where AutoNation receives funds from the sale (see Areas of Concern below). Compliance Assistance: EPA would advise all incoming vehicles to have documented deficiencies listed instead of subjectively conducting pre-owned inspections. Areas of Concern: EPA has concerns that AutoNation is selling or offering to sell parts or components intended for use with a motor vehicle where a principal effect of the part or component is to bypass, defeat, or render inoperative any device or element of design installed on or in a motor vehicle or motor vehicle engine in compliance with regulations under Title II of the Clean Air Act, and where the person knows or should know that such part or component is being offered for sale or installed for such use or put to such use (See Clean Air Act Section 203(a)(3)(B). For example, AutoNation described that the 2009 Ford F-250 described above will be sent, as-is, to Auto Auction without the reinstallation of OEM emission controls. The Auction House is providing funds to AutoNation based on the sale of a vehicle brought by AutoNation. Inspector LeCortz initially did not discuss this topic during the onsite inspection however after further conversations with AutoNation via phone EPA is citing this as an Area of Concern. Facility Business Activities Types of Services (check all that apply) Manufactures aftermarket parts (hardware or software) Description/Observations (types and brands of parts that are manufactured or sold, types of shop services provided, etc.) Estimated Throughput (e.g., sales per month, installs per week) U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 4 of 7 Clean Air Act Title II: Tampering Inspection Sells aftermarket part sales (including drop shipments) Version: 3/27/2019 Service shop Fleet AutoNation sells new and used vehicles, primarily 100 vehicles per passenger vehicles (sedan, SUV, truck). month Other: Dealership (approximately 5 diesels sold per month) Personnel Interviewed Name Ian Merten Title/Position General Manager Contact Info. (e.g., email, phone number) 720-923-1120 Interviewed by (Last name of Inspector) LeCortz Documents Requested Document(s) 125-Point Inspection Check Sheet, 2009 Ford F-250 Intake Form. Status Document(s) Document(s) Denied Provided Other (see notes) Will Provide After Inspection Document(s) Document(s) Denied Provided Other (see notes) Will Provide After Inspection Notes/Comments Documents provided upon request. U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 5 of 7 Clean Air Act Title II: Tampering Inspection Version: 3/27/2019 Vehicles Inspected/Observed VIN (last 4 digits) or Vehicle Make and EPA Model, License Plate Engine (Last 3 digits) Family 2016 Ram 2500 - Appearance of Tampering (Yes/No/TBD) No OBD Data Obtained? (Yes/No) No Observations (e.g., Who Performed Apparent Tampering?) 2012 Ram 2500 - No No 2010 Ford F-350 - No Yes 2009 Ford F-250 No No Straight pipes and disconnected sensors, EGR block off plate, no CEL APPENDIX A: Photo Log File Name (jpg) Description Ford F-250 Post Combustion Emissions Deleted Photographer LeCortz IMG_1155 Ford F-250 side profile LeCortz IMG_1156 IMG_1157 EGR block off plate U.S. EPA On-Highway Tampering Inspection Guide | October 2016 LeCortz Page 6 of 7 Clean Air Act Title II: Tampering Inspection Version: 3/27/2019 Disconnected exhaust wiring LeCortz IMG_1158 U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 7 of 7