Document N2EaeDL22L3KYqpaV3w0N2B1Q

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_20250127_LECORTZ_01_DDD Inspection Date(s): January 27, 2025 Regulatory Program(s): 40 C.F.R. Parts 85, 86, and 1068 EPA Region/Program Conducting Inspection: Company Name: Facility Name: EPA Region 8, Enforcement and Compliance Assurance Division, Air and Toxics Enforcement Branch Dooley's Diabolical Diesel Dooley's Diabolical Diesel Facility Physical Location: (street address, building/unit #) (city, state, zip code) 2012 13th St S Great Falls, MT 59405 Inspection Report Revision History Revision # Revision Date Reason for Revision Colin LeCortz Field Inspector Name Scott Patefield Name of Approving Official Inspector and Approval Manager Title Signature 1/28/2024 Date SCOTT PATEFIELD Date: 2025.02.05 15:10:52 -07'00' Digitally signed by SCOTT PATEFIELD Signature Date U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 1 of 5 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: Dooley's Diabolical Diesel Facility Address: 2012 13th St S, Great Falls, MT 59405 Primary Facility Representative & Title: Facility Contact Phone/Email: Time Inspector Presented Credentials: Permission to Enter Facility Granted? If Yes, by whom? If No, explain. Casey Dooley, owner Casey Dooley dooleysdiesel@gmail.com 3:12 PM Yes No Yes, Casey Dooley Inspection Date Arrival/Departure Time Inspection Number/ID: 1/27/2025 2:40 PM 4:05 PM R8_CAA_20250127_LECORTZ_01_DDD Colin LeCortz (EPA) Inspector(s): Bob Gallagher (EPA) Compliance Assistance Reference Materials Provided to Facility SBREFA Form Exhaust Repair Guidelines Memo 1A Tampering Brochure Engine Switch Fact Sheet Other: Anti-Tampering Fact Sheet & Regulation Photographer Name: Colin LeCortz Photograph Range: IMG_0091 through IMG_0103 Dooley's Diabolical Diesel (DDD) is a general repair service shop for primarily diesel vehicles. The owner provided both verbal and electronic service record descriptions, upon request. These records were provided onsite, although the date of the work orders were not clear when the vehicles work commenced- discussed more below. DDD works on approximately 10 vehicles per week, and primarily works on the engine (heads), transmissions and injectors, as well as front end work according to facility employee and owner. According to DDD, tuning occurs at DDD, and the facility uses an AE Tools laptop for scanning vehicles, uploading tunes such as to adjust gas volumes if larger fuel tanks are installed or flashing ECM's back to stock/OEM specifications. Additionally, DDD verbally discussed with EPA inspectors that tampering does not occur at the facility. EPA inspected the exhaust and engine components of vehicles at DDD, and noted vehicles that required additional follow-up or showed potential signs of emissions tampering (post combustion controls removed). DDD provided work orders and documentation upon request for vehicles that were noted as having emissions control removed during the onsite walkthrough, and work orders did not specifically discuss tampering or the removal of emission controls. Notes (e.g. compliance actions taken by facility, purchased samples, other relevant background, etc.): At the end of the Facility walkthrough, EPA inspectors observed a Chrysler emission controls (post combustion) on the side of the building on the outside (see photo log below), discussed below in the Areas of Concern. The part number on the emissions control may be associated with a Ram 1500 catalytic converter/oxidation catalyst. EPA inspectors did not see a Ram 1500 on the lot. DDD told EPA employees that sometimes other shops may illegally drop off trash in that location. Areas of Concern: The EPA reviewed work orders for vehicles noted in the Vehicles Inspected/ Observed table below that were observed having potential tampering of original equipment emission components. Generally, the work orders contained enough information to determine that tampering did not occur at the Facility. However, in Documents Requested, EPA inspectors reviewed two work orders for a vehicle in the service bay and vehicle in the lot that was dated (Schedule/ Promise Date) 6 months earlier than the date of inspection, and could not be determined if the work order was timely. The Repair Order # on 3 of the 4 service records were numbered as "000000." Therefore, it is unclear if DDD is filling out service records appropriately for EPA inspectors to be able to determine work conducted and timeliness of the work orders. Although the work order service date was unclear, the vehicle engine in the service bay was being torn down and EPA inspectors did not note additional areas of concern such as tampered emissions components in the shop. The other vehicles in the lot were there for front end work according to DDD (turbo's, CV axle service, cylinder heads, air intake). EPA suggests the facility maintain clear records for ease of use by mechanics. Multiple vehicles on the DDD lot had components at the time of inspection that defeated emission components from the manufacturer. See Photo Log and Vehicles Inspected/Observed below. However, according to DDD the tampering did not occur at the facility. One of the work orders included "Relearn Procedure." While this feature for tuning can be used for manufacture specified transmission service, this feature may also be used after other tuning that could be used to defeat emission controls- EPA is noting this for informational purposes at this time. U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 2 of 5 Clean Air Act Title II: Tampering Inspection Version: 3/27/2019 Compliance Assistance: The EPA would recommend that DDD maintain an intake form, checklist or more informative work orders for all vehicles to note which have emission control components removed prior to working on vehicles, among other inclusions such as vehicle condition and general notes. The EPA will continue to work with the Facility, conduct unannounced follow-up inspections, and provide resources where requested to ensure compliance with federal regulations. DDD discussed the interest in building race vehicles, as well as requesting regulatory clarity of federal rules. EPA inspectors attached the EPA Tampering Policy: The EPA Enforcement Policy on Vehicle and Engine Tampering and Aftermarket Defeat Devices under the Clean Air Act Memo which includes plain language regulatory summaries with the transmittal of this inspection report. EPA inspectors are offering to further discuss federal regulations with DDD upon request. Facility Business Activities Description/Observations Types of Services (types and brands of parts that are manufactured or sold, types of shop (check all that apply) services provided, etc.) Manufactures (hardware or aftermarket parts software) Estimated Throughput (e.g., sales per month, installs per week) Sells aftermarket (including drop part sales shipments) EPA Inspector LeCortz and the facility owner walked the facility shop and Approximately 10 vehicles grounds noting emission control equipment that had been removed from certain repaired or serviced in total Service shop vehicles. The owner supplied verbal and electronic information that this was not per week. a product of vehicle tampering at the facility. Fleet Other: Personnel Interviewed Name Casey Dooley Title/Position Owner Tracer Nitz Employee Contact Info. (e.g., email, phone number) dooleysdiesel@gmail.com Interviewed by (Last name of Inspector) LeCortz NA LeCortz U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 3 of 5 Clean Air Act Title II: Tampering Inspection Documents Requested Version: 3/27/2019 Document(s) Document(s) Provided Will Provide After Inspection Status Document(s) Denied Other (see notes) Onsite review of records Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Document(s) Denied Other (see notes) Document(s) Denied Other (see notes) Document(s) Denied Other (see notes) Vehicles Inspected/Observed License Plate (State + last three digits) or Vehicle Make and Model EPA Engine Family MT: PUL. Ram 3500 NA (outside) Appearance of Tampering (Yes/No/TBD) Yes OBD Data Obtained? (Yes/No) No MT: DJM. GMC Sierra HD NA Yes No MT: 2-20. Chevrolet NA Silverado GMC Sierra and Chevrolet NA 3500 LTZ/Z71 Yes No Yes No Notes/Comments DDD was able to provide access to the facility and all service records upon request. However, two of the work orders provided for the vehicle located in the service bay was dated 6 months earlier (schedule/promise date) than the date of inspection, and could not be determined if the work order was timely. Additionally, Repair Order # for 3 of the 4 work orders requested by EPA are numbered "000000." See areas of concern above. Observations (e.g., Who Performed Apparent Tampering?)1 Emissions Delete (post-combustion control), straight pipe, potential O2 sensor wiring was observed to be unplugged Emissions Delete (post-combustion control), straight pipe, potential O2 sensor wiring was observed to be unplugged Emissions Delete (post-combustion control), straight pipe, potential O2 sensor wiring was observed to be unplugged Emissions Delete (post-combustion control), straight pipe, potential O2 sensor wiring was observed to be unplugged 1 DDD provided substantial information to determine that emissions tampering observed did not occur at the facility at the time of inspection. U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 4 of 5 Clean Air Act Title II: Tampering Inspection Version: 3/27/2019 APPENDIX A: Photo Log File Name(jpg) IMG_0091 IMG_0092 IMG_0093 IMG_0094 IMG_0095 IMG_0096 IMG_0097 IMG_0098 IMG_0099 IMG_0100 IMG_0101 IMG_0102 IMG_0103 Description Photographer AE Tools laptop that is used for tuning. Vehicle, Ram 3500 being worked on in bay. DDD discussed that an EGR failed on this vehicle. Inspectors did not see the EGR in the service bay. Work order for vehicle in bay. Owner provided information regarding parts used. Ram 3500 (outside) that has a straight pipe, deleted. Ram 3500 (outside) that has a straight pipe, deleted. GMC Sierra HD that has a straight pipe, deleted GMC Sierra HD that has a straight pipe, deleted Chevrolet Silverado that has a straight pipe, deleted. Chevrolet Silverado that has a straight pipe, deleted. GMC Sierra and Chevrolet that each have straight pipe, deleted Chrysler post combustion emission controls. Removed from vehicle and located on the side of the service shop. Chrysler post combustion emission controls. Removed from vehicle and located on the side of the service shop. C. LeCortz C. LeCortz C. LeCortz C. LeCortz C. LeCortz C. LeCortz C. LeCortz C. LeCortz C. LeCortz C. LeCortz C. LeCortz C. LeCortz C. LeCortz U.S. EPA On-Highway Tampering Inspection Guide | October 2016 Page 5 of 5