Document rpwo341vpJqjzkxyzpxM1nv4G

EPA OECA Air Enforcement Division INSPECTION REPORT 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: Facility Contact: 03/06/2023- 03/07/2023 Air Title II Mobile Sources Ritchie Brothers Auctioneers Ritchie Brothers Auctioneers - Fort Worth Texas 6050 Azle Ave., Lake Worth, Texas 76135 6050 Azle Ave., Lake Worth, Texas 76135 Tarrant County Kolby Worthy Regional Operations Manager FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: Facility Representatives: N/A N/A N/A N/A Kolby Worthy Regional Operations Manager 817-238-5865 Metadata EPA Inspectors: State Inspector(s): Other Inspector(s): Title: Author: Subject: Keywords: EPA Lead Inspector Signature/Date Supervisor Signature/Date Mario Jorquera Victor Aguilar {name} {name} {name} {name} {name} OECA/OCE/AED/VEEB OECA/OCE/AED/VEEB {affiliation/mailcode} {affiliation/mailcode} {affiliation/mailcode} {affiliation/mailcode} {affiliation/mailcode} 202-564-1079 202-564-9679 {phone no.} {phone no.} {phone no.} {phone no.} {phone no.} Ritchie Brothers Auctioneers Inspection; Fort Worth, TX Victor Aguilar Inspection of Potentially Imported Vehicles and Engines at an Auction House Inspection Report of Vehicle and Engine Goods at an Auction House VICTOR AGUILAR {Inspector name} MARK PALERMO {Supervisor name} Digitally signed by VICTOR AGUILAR Date: 2023.06.12 09:28:14 -04'00' Digitally signed by MARK PALERMO Date: 2023.09.26 14:35:12 -04'00' Date Date Ritchie Brothers Auctioneers/ Ritchie Brothers Auctioneers - Fort Worth Texas Inspection Date: 03/06/2023- 03/07/2023 Ritchie Brothers Auctioneers/ Ritchie Brothers Auctioneers - Fort Worth Texas Inspection Date: 03/06/2023- 03/07/2023 Section I - INTRODUCTION PURPOSE OF THE INSPECTION On March 6, 2023, EPA HQ Air Enforcement Division, Vehicle and Engine Branch inspectors Mario Jorquera and Victor Aguilar arrived on the premises of Ritchie Brothers Auctioneers in Lake Worth, Texas for an unannounced inspection of their facility which specializes in auctioning off heavy duty pieces of construction and agricultural equipment and engines. We entered the main office at 1:56pm and Mario asked a person at the front desk to speak with the person in charge. The person asked what this was regarding, and Mario explained that we were with the EPA's Vehicle and Engine Branch and that we were there to conduct Clean Air Act Title II inspections on some of the products present in their auction yard. A few minutes later Kolby Worthy, the Regional Operations Manager of that facility greeted us. Mario and Victor showed Mr. Worthy our inspector credentials and explained that we were at his facility to inspect some of their pieces of equipment on the auction yard, to check for compliance with the Clean Air Act. FACILITY DESCRIPTION The facility where we met Mr. Kolby Worthy was the main office building of the Ritchie Brothers Auctioneers Fort Worth site and is where all the employee's offices are, as well as the main customer reception area. The main office building is adjacent to the auction yard, which is where the company stores thousands of pieces of equipment and vehicles, which will eventually be auctioned off to the public. At the time of our visit there was one person interacting with customers at the main desk and several people in their own private offices. There were also several people present at the auction yard, taking inventory of the products and preparing them for the upcoming auction. The facility operates 5 days a week from 8:00am to 5:00pm. Section II - OBSERVATIONS Mr. Worthy gave consent to the EPA inspectors to conduct our inspections and also provided Mario and Victor with his Ritchie Brothers business card. Afterwards, Mr. Worthy escorted us to the auction yard and asked what kind of equipment we were interested in looking at. Inspector Victor Aguilar mentioned that we were interested in looking at a couple of pieces of equipment that we found advertised online, but that we were also interested in inspecting other pieces of equipment that looked interesting or suspicious. A special emphasis was placed on products for which we did not recognize the name of the manufacturer of and newer pieces of equipment. Mario also explained to Mr. Worthy how EPA VEEB inspectors typically conducted our inspections of vehicles and engines, including taking pictures of the equipment from several perspectives, opening the engine compartment, and taking pictures of the engine, any Emission Control Information labels, and any visible emission controls. Ritchie Brothers Auctioneers/ Ritchie Brothers Auctioneers - Fort Worth Texas Inspection Date: 03/06/2023- 03/07/2023 Inspection 5 - An inspection of the undercarriage of the 2019 Ford F450 diesel pickup truck revealed that all the after-treatment systems were removed and replaced with a straight pipe. EPA inspectors may ask Ritchie Brothers for the seller and or importer information of this piece of equipment in a follow up action. Inspection 6 - EPA inspectors were unable to locate the Emission Control Information label on the engine or anywhere else in the engine compartment of the 2012 Dodge Ram 5500 diesel pickup truck. EPA proceeded to inspect the undercarriage of the pickup truck and observed a straight pipe installed, instead of after-treatment emission controls. It is known that Dodge Ram Diesel Pickup trucks of this model type and model year were manufactured with after-treatment systems installed. EPA inspectors may ask Ritchie Brothers for the seller and or importer information of this piece of equipment in a follow up action. Inspection 7 - An inspection of the undercarriage of the 2011 Dodge Ram 3500 diesel pickup truck revealed that all the after-treatment systems were removed and replaced with a straight pipe. EPA inspectors may ask Ritchie Brothers for the seller and or importer information of this piece of equipment in a follow up action. Inspection 8 - An inspection of the undercarriage of the 2010 Ford F350 diesel pickup truck and revealed that the after-treatment systems were removed and replaced with a straight pipe. EPA inspectors may ask Ritchie Brothers for the seller and or importer information of this piece of equipment in a follow up action. Inspection 1A (Day 2) - EPA inspectors observed that the mini excavators had an EPA seal attached to the side of the equipment, which is unusual because the US EPA does not endorse products. Mr. Worthy commented that these kinds of Chinese made mini excavators have just recently started coming into his auction site and that he dislikes them because he doesn't believe the engine installed in them is strong enough to perform the tasks of an excavator. Inspection 1 (Day 2) - EPA inspectors were unable to locate any after-treatment system emission controls on the 2020 XCMG Excavator and could not take a legible picture of the ECI label because it was in an inaccessible part of the engine. EPA inspectors may ask Ritchie Brothers for the seller and or importer information of this piece of equipment in a follow up action. Inspection 2 (Day 2) - It is unclear whether the diesel engine in the 2022 mini excavator could comply with 2022 non-road EPA emission standards without an after-treatment system. EPA will check with Kubota to confirm that this is their engine and EPA inspectors may ask Ritchie Brothers for the seller and or importer information of this piece of equipment in a follow up action. Inspection 3 (Day 2) - EPA inspectors observed that the mini excavators had an EPA seal attached to the side of the equipment, which is unusual because the US EPA does not endorse products. Inspection 3A/4 (Day 2) - It is unclear if the 2019 non-road diesel engine in the Telehandler could comply with 2019 non-road EPA emission standards without an after-treatment system. Inspection 5 (Day 2) - EPA inspectors reviewed the ECI label on the Cummins engine in the 2018 XCMG roller and noticed that the engine family name was "323". This is not a valid engine family name. EPA will check with Cummins to confirm the compliance status of this engine and EPA inspectors may ask Ritchie Brothers Auctioneers/ Ritchie Brothers Auctioneers - Fort Worth Texas Inspection Date: 03/06/2023- 03/07/2023 Ritchie Brothers for the seller and or importer information of this piece of equipment in a follow up action. Inspection 6 (Day 2) - Upon review of the ECI label on the Cummins engine in the 2017 XCMG roller, EPA inspectors noticed that it was a 2011 engine which was installed in the used piece of equipment. This may explain why the EPA inspectors did not observe any after-treatment systems installed in engine. EPA will check with Cummins to confirm the compliance status of this engine and EPA inspectors may ask Ritchie Brothers for the seller and or importer information of this piece of equipment in a follow up action. Inspection 19 (Day 2) - While inspecting the remote lawn mower, EPA inspectors were able to locate and remove the ECI label, without destroying the label itself. EPA inspectors will contact the engine manufacturer, Chongqing Dajiang Power Equipment, and notify them of their peeling labels. Section IV - FOLLOW UP EPA will be requesting additional information on the equipment cited above for which the inspectors found possible concerns. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 320 photos taken on 3/7/23 with the Cannon camera (IMG_0735IMG_1058.JPG); 81 photos taken on 3/6/23 with the Nikon camera (DSCN1527DSCN1607) Appendix 2 - CBI Claim Document signed by Regional Operations Manager at Ritchie Brothers Auctioneers - Fort Worth Texas, Kolby Worthy on 3/07/2023 Appendix 3 - 208 Preservation Letter, date of receipt 3/07/2023, signed by EPA inspector Mario Jorquera