Document b5Xm99y68ap2d1O6KJ4KmyrkO

United States Environmental Protection Agency Region 7 Enforcement and Compliance Assurance Division Air Branch Inspection Report Unannounced Partial Compliance Evaluation Durham School Services 1401 W 4th Ave Hutchinson, Kansas 67501 Inspection Date(s): April 16-17, 2024 Charlotte Papp, Inspector, ECAD, Air Branch Authorized for Release by: Tracey Casburn, Air Branch Chief, ECAD 11201 Renner Boulevard Lenexa, Kansas 66219 Page 1 of 7 CONTENTS INSPECTION OVERVIEW .................................................................................................................. 3 INSPECTION OBJECTIVE .............................................................................................................. 3 FACILITY CONTACT INFORMATION ............................................................................................. 3 FACILITY OVERVIEW .................................................................................................................... 3 FIELD ACTIVITIES SUMMARY....................................................................................................... 4 Measurement and/or Sampling Activities .............................................................................. 5 TABLES Table 1. PROJECT TEAM MEMBERS ................................................................................................ 3 Table 2. FACILITY CONTACT INFORMATION ................................................................................... 3 Table 3. APPLICABLE PERMIT CONDITIONS, REGULATIONS AND STANDARDS .............................. 3 Table 4. FIELD MEASUREMENT ACTIVITIES .................................................................................... 5 Table 5. VEHICLE INSPECTION SUMMARY ...................................................................................... 6 APPENDICES A - Confidential Business Information Form (1 page) B - Receipt for Documents (4 pages) C - Field Photographs (149 pages) This Contents page shows all the sections contained in this report and provides a clear indication of the end of this report. Page 2 of 7 INSPECTION OVERVIEW INSPECTION OBJECTIVE The objective of the partial compliance evaluation (PCE) inspection was to determine compliance of the facility with the Clean Air Act (CAA), specifically those requirements listed in Table 3 below. Table 1 lists the inspection team members. Team Member Lead Inspector Charlotte Papp Avery Bowers Table 1. PROJECT TEAM MEMBERS Organization EPA Region 7, ECAD, Air Branch EPA Region 7, ECAD, Air Branch Project Role Project manager (PM) Field team member FACILITY CONTACT INFORMATION Table 2 lists the primary facility contacts in order of contact during the inspection. Table 2. FACILITY CONTACT INFORMATION Name, Title Phone No. Email Address Mike Simmons, General Manager 620-665-6595 msimmons@durhamschoolservices.com Philip McPherson, Region Maintenance Manager TXMidwest 480-238-2027 Philip.mcpherson@nellc.com Archer Blaton, Mechanic FACILITY OVERVIEW Durham School Services owns and operates a fleet of charter busses. According to Plant Manager Mike Simmons, the facility in Hutchinson houses approximately 30 vehicles, some of which are diesel engines, and some are gasoline. The primary client is the local school district. The drivers execute approximately 20 routes, 2-3 times per day. According to Mr. Simmons, the facility has an in-house mechanic, Archer Blaton, who deals with most maintenance and repair. The facility will occasionally use local service shops/dealerships for more in-depth or specialized repairs. The facility is subject to the following regulations and standards subject to review during this inspection (Table 3): Table 3. APPLICABLE PERMIT CONDITIONS, REGULATIONS AND STANDARDS 42 U.S.C. Sec. 7522(a)(3)(b) Prohibited Acts Page 3 of 7 FIELD ACTIVITIES SUMMARY We arrived at the facility on April 16, 2024, at 12:24 p.m. and completed a drive by surveillance inspection. While waiting for the facility contacts to be available, the inspection team went into the fleet yard and counted 7 short busses and 23 long busses parked in the lot. We made entry at the front office and I introduced myself and members of the inspection team, presented my credentials, and provided my business card to Mr. Simmons. I conducted an opening conference during which I explained that the purpose of the visit was to conduct an inspection to determine compliance with the CAA, specifically with CAA section 203(a)(3) defeat device and tampering provisions. I explained that after asking for some general business information, I would inspect several vehicles, as well as request associated maintenance and repair records. I explained to Mr. Simmons that the facility would have an opportunity to make a claim of business confidentiality at the end of the inspection and provided him with a Confidential Business Information (CBI) form. Mr. Simmons did not make a claim of confidentiality (Appendix A). We began inspecting Vehicle 1 at approximately 1:09 p.m. and concluded at 1:50 p.m. We broke for lunch shortly after and remained away while the busses were performing their afternoon school routes. We returned to the facility at 4:21 p.m. and began inspecting Vehicle 2 at 4:33 p.m. We concluded the Vehicle 2 inspection at 5:13 p.m. and left the facility for the day. The following day, April 17, 2024, we arrived onsite at 8:34 a.m. We began inspecting Vehicle 3. Mr. Simmons escorted us to the vehicle, gave us the keys, then returned to his office while we completed the inspection of the vehicle. Vehicle 3 inspection was completed at 9:30 a.m. We began the Vehicle 4 inspection at 9:37 a.m. and concluded at 10:34 a.m. The Vehicle 5 inspection began at 10:50 a.m. and concluded at 11:49 a.m. The Vehicle 6 inspection was only an OBD scan. It began at 12:03 p.m. and concluded at 12:14 p.m. At 12:23 p.m. we returned to the office to discuss record keeping with Mr. Simmons. We agreed on April 19th, 2024, for remaining records to be sent to me via email. I conducted a closing conference with Mr. Simmons at 12:33 p.m. I provided the facility with copies of Receipt for Documents (Attachment B), and a small business resource information sheet. We departed the facility shortly thereafter. Page 4 of 7 Measurement and/or Sampling Activities We conducted OBD scans of 6 vehicles during the onsite inspection. Table 4 summarizes field measurement and field sampling activities. All environmental measurement activities were performed in accordance with the EPA OnBoard Diagnostic Data Acquisition Standard Operating Procedure. Table 4 summarizes field measurement activities. Table 4. FIELD MEASUREMENT ACTIVITIES Location Identifier Date(s) and Time Method and/or Procedure1, and Equipment Vehicle 1 4/16/2024 1:34 p.m. Method/EPA Procedure: OBD Data Acquisition Procedure Equipment: Blue Point Pocket iQ2, Model EEHD186030, Serial No. 03683 Vehicle 2 4/16/2024 4:57 p.m. Method/EPA Procedure: OBD Data Acquisition Procedure Equipment: Blue Point Pocket iQ2, Model EEHD186030, Serial No. 03683 Vehicle 3 4/17/2024 9:15 a.m. Method/EPA Procedure: OBD Data Acquisition Procedure Equipment: Blue Point Pocket iQ2, Model EEHD186030, Serial No. 03683 Vehicle 4 4/17/2024 10:18 a.m. Method/EPA Procedure: OBD Data Acquisition Procedure Equipment: Blue Point Pocket iQ2, Model EEHD186030, Serial No. 03683 Vehicle 5 4/17/2024 11:33 a.m. Method/EPA Procedure: OBD Data Acquisition Procedure Equipment: Blue Point Pocket iQ2, Model EEHD186030, Serial No. 03683 Vehicle 6 4/17/2024 12:03 p.m. Method/EPA Procedure: OBD Data Acquisition Procedure Equipment: Blue Point Pocket iQ2, Model EEHD186030, Serial No. 03683 1 The current version of each procedure, at the time of the investigation, was followed. Measurer Name Charlotte Papp Charlotte Papp Charlotte Papp Charlotte Papp Charlotte Papp Charlotte Papp INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS Ambient weather, site conditions, and field activities were documented in the field records. All photographs are attached as Appendix C. I made the following observations during the inspection. I discussed all observations with facility representatives during the closeout meeting unless otherwise noted in the observation description. These observations are not final compliance determinations. The EPA Region 7 Air Branch case review team will make the final compliance determinations based on its review of this report and other technical, regulatory, and facility information. Page 5 of 7 None of the 6 vehicles inspected showed obvious signs of tampering, or installation of defeat devices. A summary of the vehicle inspections is bellow in Table 5. Vehicle Identifier Vehicle 1 Vehicle 2 Vehicle 3 Vehicle 4 Vehicle 5 Vehicle 6 VIN 4UZABRDT5CCBN1859 1GB6G5BLXE1213487 4DRLWTAN3LB087240 1GB6G5BL9E1210967 4DRBUC8N2HB651561 4DRBUC9PXRB029289 Table 5. VEHICLE INSPECTION SUMMARY Photo Range Date(s) and Time Observations 4-23 4/16/2024 EGR, DOC/OC, DPF/PTOX, SCR appeared to be present and 1:09 p.m. not tampered 24-50 4/16/2024 4:33 p.m. DOC/OC, DPF/PTOX, SCR appeared to be present and not tampered. EGR was not visible from inspector vantage point. 51-75 4/17/2024 8:44 a.m. EGR, DOC/OC, DPF/PTOX, SCR appeared to be present and not tampered. I used an endoscopic camera in the tailpipe and saw potential catalytic material 76-101 4/17/2024 9:37 a.m. DOC/OC, DPF/PTOX, SCR appeared to be present and not tampered. EGR was not visible from inspector vantage point. 102-138 4/17/2024 EGR, DPF/PTOX, SCR appeared to be present and not 10:51 a.m. tampered 139-142 4/17/2024 OBD Scan only 12:03 p.m. Potential Finding 1: Inconsistent data from OBD scans Observation Summary: Certain data points taken during vehicle inspections were not consistent with a functioning exhaust aftertreatment system. Citation: 42 U.S.C. Sec. 7522(a)(3)(b) Evidence: OBD Scan Data Description of Observation: While reviewing OBD data collected during the vehicle inspections, I observed several data points that are suggestive of a tampered vehicle exhaust treatment system. Some examples include: - DPF differential pressure at a constant 0 reported value or inlet and outlet pressure values do not equal differential pressure - Active fault codes relating to reductant tank temperature and NOx sensors - Average reagent consumption 0.0 gal/hr - Exhaust temperatures above normal operating range Further investigation into this matter should be considered. Potential Finding 2: Incongruent amount of DEF usage Observation Summary: The facility seems to use too little DEF fluid for the miles driven on diesel vehicles Citation: 42 U.S.C. Sec. 7522(a)(3)(b) Evidence: DEF purchase records, driving/mileage records Description of Observation: Page 6 of 7 Potential Finding 2: Incongruent amount of DEF usage According to the document titled "DEF Purchases 12 month record.xlsx" sent by the facility, Durham School Services has purchased 150 gallons of DEF on 5/20/23, and an additional 200 gallons on 1/30/2024. According to the driving logs provided, the fleet has consumed a total of 13,235.8 gallons of diesel fuel from approximately 4/1/2023 to 4/12/2024. However, many entries in the driving logs list a vehicle traveling a considerable number of miles with no fuel used. The total number of miles driven in the same time period is 166,132.6 miles, which would assume a fuel efficiency of 12.55 mpg. According to the OBD data, a more reasonable approximation is 8 mpg. Using this figure, an estimated fuel usage would be 20,766.58 gallons. EPA uses the approximation of 50 gallons of fuel per 1 gallon of DEF used in typical driving situations. Assuming the fleet used 20,766 gallons of fuel from 4/1/2023 to 4/12/2024, we would expect them to have used 415 gallons of DEF. However, purchase records show only 350 gallons purchased. To be more concise, if we assume all 150 gallons of DEF were consumed between 5/20/2023 and 1/30/2024 when more DEF was purchased, we would expect to have 7,500 gallons of fuel consumed, or 60,000 miles collectively driven. Looking through the drive logs, the total miles driven from 7/1/2023 to 12/30/2023 was 76,551 miles. Even with a narrower time frame, the amount of DEF purchased and/or consumed seems to be too little for the miles driven of the vehicles. Another document titled "Fuel Cost past 12 months.docx" is a table of figures for each month March 2023 to March 2024. It is unclear if these values are the total gallons of fuel purchased, or the total dollar amount spent on fuel. If they are total gallons of diesel fuel, it would indicate that from 6/1/2023 to 12/30/2023, the facility used 45,577 gallons of fuel, and thus would need approximately 911 gallons of DEF. Assuming it is instead $45,577 spent on diesel fuel, with an assumed cost of $3.50 per gallon, that would amount to 13,022 gallons of fuel and 260 gallons of DEF. Further investigation into this issue is warranted. End of report. Page 7 of 7