UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT AND LEGAL COUNSEL
EPA-330/1-83-001
MOTOR VEHICLE TAMPERING SURVEY - 1982
April 1983
Larry Walz
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
1982 SURVEY OBJECTIVES 2
CONCLUSIONS 4
TECHNICAL ANALYSIS
BACKGROUND 6
SURVEY METHODS 8
RESULTS 13
SITE AND AGGREGATE RESULTS 13
TYPES OF TAMPERING 16
EFFECTS OF I/M ON TAMPERING RATES 19
EFFECTS OF TAMPERING ON EMISSIONS 20
TAMPERING BY VEHICLE AGE 22
TAMPERING RATES BY VEHICLE MANUFACTURER 22
TRUCK TAMPERING 22
FUEL-RELATED TAMPERING 26
ADD-ON AND NON-STOCK EQUIPMENT 30
APPENDICES
A SECTIONS 203(a)(3)(A) AND 203(a)(3)(B) OF THE CLEAN AIR ACT
B DATA COLLECTION AND RECORDING PROCEDURES
TABLES
1 Vehicle Status by Aggregate, Site, and Year of Survey .... 14
2 Rates of Tampering by Component 17
3 Rates of Arguable Tampering by Component 18
4 Mean Idle Emissions of Tampered, Arguably Tampered, and
Okay Vehicles 21
5 Percent Tampered and Sample Size by Model Year and Vehicle
Age at Time of Survey 23
6 Percent Catalyst Removed and Sample and Sample Size by Model
Year and Vehicle Age at Time of Survey 24
7 Comparison of 1978, 1979, 1981, and 1982 Tampering Data
by Vehicle Manufacturer 25
8 Fuel Switching Rate for 1982 Survey by Site and Indicator . . 28
FIGURES
1 Comparison of Tampering Rates for Systems by Surveys .... 15
2 Comparison of Multiple Indicators 29
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EXECUTIVE SUMMARY
INTRODUCTION
CONCLUSIONS
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INTRODUCTION
At the request of the EPA Field Operations and Support Division (FOSD),
the National Enforcement Investigations Center (NEIC) conducted a motor ve-
hicle tampering survey at 10 locations within the United States from April
through October 1982. The locations surveyed and number of vehicles inspec-
ted are as follows:
South Dade County, Florida 309 vehicles
Baton Rouge, Louisiana 183 vehicles
Houston, Texas 293 vehicles
Tulsa, Oklahoma 282 vehicles
Several locations, New Jersey 290 vehicles
Several locations, Rhode Island 324 vehicles
Minneapolis, Minnesota 307 vehicles
Seattle, Washington 312 vehicles
Portland, Oregon 310 vehicles
Las Vegas, Nevada 275 vehicles
Because motor vehicle emissions in urbanized areas account for nearly
90% of the total carbon monoxide and airborne lead, over one-half of the
hydrocarbons, and nearly 40% of the nitrogen oxides emitted to the atmos-
phere, a significant part of the Nation's effort to achieve clean air stan-
dards has been directed toward controlling motor vehicle emissions. Auto-
mobile manufacturers have installed control devices on new vehicles since
1968 to control these emissions.
The 1977 amendments to the Clean Air Act (Sections 203(a)(3)(A) and
(B), Appendix A) make it illegal for automobile dealers, repair and service
facilities, and fleet operators to disconnect or modify emission control
devices or elements of design. The FOSD is responsible for enforcing the
tampering provisions of this Act.
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In order to determine the rate of tampering and fuel switching on a
nationwide basis, surveys were conducted in 1978*, 1979**, and 1981***.
These surveys were conducted by the Mobile Source Enforcement Division
(MSED - FOSD's predecessor organization), an expert automotive consultant,
and NEIC. Consistent inspection procedures were used during all of these
surveys so statistical comparisons could be made.
1982 SURVEY OBJECTIVES
Ten sites were selected throughout the United States to represent geo-
graphic diversity. Four of the sites previously inspected were repeated in
order to provide a comparison of data to the previous surveys and to update
current trends for tampering and fuel switching in these areas.
The following is a list of objectives of this survey:
1. Update previously collected tampering data;
2. Determine current tampering trends for —
a. The most prevalent types of tampering,
b. The effects of tampering on vehicle emissions,
c. The amount of tampering by vehicle age and manufacturer;
3. Determine the extent of fuel switching.
In order to achieve these objectives, a visual inspection was made of
the emission control devices on each vehicle. Additionally, hydrocarbon
and carbon monoxide idle emissions were measured, and gasoline samples taken
from vehicles requiring unleaded fuel. Also, tailpipe deposits of vehicles
requiring unleaded fuel were tested for the presence of lead using Plumb-
tesmo test paper.
* Motor Vehicle Tampering Survey (1978), U.S. Environmental Protection
Agency, Mobile Source Enforcement Division, November 1978
** Motor Vehicle Tampering Survey (1979), U.S. Environmental Protection
Agency, National Enforcement Investigations Center, May 1980,
EPA-330/1-80-001
*** Motor Vehicle Tampering Survey - 1981, Chattanooga, Tennessee and
Houston, Texas, U.S. Environmental Protection Agency, National Enforce-
ment Investigations Center, March 1982, EPA-330/1-82-001
® Registered trademark; appears hereafter without the ®. Manufactured
by Macherey-Nogel, Duren, W. Germany; marketed by Gallard-Schlesinger
Chemical Corp., Carle Place, New York.
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Four mutually exclusive categories were used to classify all of the
inspected vehicles. They were as follows:
1. Tampered (at least one control device removed or rendered
inoperative);
2. Arguably tampered (potential but not clear-cut tampering);
3. Malfunctioning;
4. Okay (all control devices present and apparently operating
properly).
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CONCLUSIONS
The overall tampering rate for 1982 has not changed significantly from
the previous surveys. These results are shown below. As will be noted
later, the results are not subject to exact comparison but reflect the gen-
eral trends.
Tampering
Category
Tampered
Arguably tampered
Malfunctioning
Okay
1978 Survey
(%)
18.9
48.4
2.0
30.7
1979 Survey
(%)
18.0
46.5
2.2
33.3
1981 Survey*
(%)
14.3
45.4
2.5
37.8
1982 Survey
(%)
16.7
38.4
1.2
43.7
* Because the 1981 survey involved only two sites and a very limited sam-
ple size, results may be expected to exhibit more error variance than
the three larger surveys.
In 1982, the most prevalent form of tampering continued to be with the
EGR system. However, both filler neck restrictor tampering, and catalyst
removal have greatly increased since 1978. Limiter cap tampering was the
most common type of arguable tampering.
This survey showed that there was a relationship between tampering
rates and idle emissions. The vehicles judged 'okay' emitted approximately
one-fourth the CO and one-third the HC of those where tampering had occurred.
The okay vehicles are more likely to pass an inspection maintenance (I/M)
test than tampered vehicles.
Older vehicles were found to have higher tampering rates than those of
a newer model year. Tampering was found on nearly one-third of the vehi-
cles in their eighth year of existence.
A comparison of tampering by manufacturers showed that AMC had the
highest tampering rate (27.2%), and that vehicles of Japanese origin had the
lowest (3.9%).
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Fuel switching*, overall, was 10.6%. Non-I/M areas had a rate of
15.1%, while areas which employed an I/M program showed a rate of 6.2%.
The overall tampering rate was 16.7%. Non-I/M areas had a rate of
19.8%, while areas which employed an I/M program showed a rate of 13.9%.
The component-specific tampering rates were also significantly higher in
non-I/M areas than in I/M areas. These results are shown below.
TAMPERING RATES - 1982
Tampering
Category
Overall
Catalytic converter
Inlet restrictor
Air pump system
EGR system
Overall
(%)
16.7
4.37
5.90
4.55
9.83
I/M
(%)
13.9
1.71
3.13
2.29
10.14
Non-I/M
(%)
19.8
7.07
8.73
7.15
9.4
The overall tampering rate for trucks was 25.1%. The component-
specific tampering rates were also generally higher for trucks.
The incidence of add-on and non-stock equipment was very low during
the 1982 survey (only four instances detected).
A vehicle was judged to be fuel switched if the Plumbtesmo test was
positive, there was >.05 g/gallon lead in the gasoline, or the filler
restrictor was tampered with.
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TECHNICAL ANALYSIS
BACKGROUND
SURVEY METHODS
RESULTS
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BACKGROUND
Before 1978, the Mobile Source Enforcement Division (now FOSD) had
data suggesting that tampering with emission control devices was occurring.
However, due to the variability of the inspection procedures employed, an
accurate assessment of the nature and extent of the tampering could not be
made. Because of this, MSED decided in 1978 to conduct tampering surveys
on a national level which employed consistent inspection procedures.
The objectives of the 1978 survey were to determine the following:
1. The rate of tampering on a national level;
2. The common types of tampering;
3. If a relationship existed between tampering and idle emissions.
This survey was conducted from May through August 1978, under the di-
rection of MSED, by an expert consultant with assistance provided by the
National Enforcement Investigations Center (NEIC). The results of this
survey showed that, of the 1,953 vehicles inspected in the States*, 19%
showed tampering, 48% showed arguable tampering, 2% showed control device
malfunctions, and 31% showed no visible signs of tampering or malfunction-
ing. The most prevalent type of tampering observed was EGR system tamper-
ing. The idle emissions, which were measured during the inspection, were
higher from tampered vehicles than from vehicles which showed no signs of
tampering.
In order to remain abreast of the tampering rates, MSED requested that
NEIC conduct a second nationwide tampering survey during 1979. The follow-
ing were additional objectives to those of the 1978 survey:
1. Compare the tampering rates in areas with inspection and mainten-
ance regulations (I/M areas) with those having no inspection and
maintenance regulations (non-I/M areas).
* Delaware, Maine, Tennessee, Texas, Virginia, and Washington
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2. Check for sampling bias* that may have occurred because of volun-
tary participation.
This survey was conducted from June through November 1979 by NEIC. In eight
states**, 2,499 vehicles were inspected; 18% showed tampering, 46% showed
arguable tampering, 2% showed control device malfunction, and 33% showed no
tampering. As was the case in the 1978 survey, the most common type of
tampering was with the EGR system, and the idle emissions were higher from
tampered vehicles than from untampered vehicles. This survey also showed
that tampering rates from I/M areas were lower than from non-I/M areas, and
that rates were higher in areas where the inspection was mandatory rather
than voluntary.
In September 1981, FOSD requested that NEIC perform inspections in
Tennessee and Texas to determine the following:
1. The current rate of tampering in Chattanooga, Tennessee, and Hous-
ton, Texas in order to ascertain the effectiveness of the antitam-
pering program in Houston;
2. Current trends in those two cities for —
a. The most prevelant type of tampering;
b. The effects of tampering on vehicle emissions;
c. The amount of tampering by vehicle age and manufacturer
3. The extent of fuel switching;
4. The prevalence of add-on and non-stock equipment installations
which could affect emissions.
The results of this survey, which was of limited scope, showed that the
most prevalent forms of tampering were filler neck and EGR tampering. There
was a relationship between tampering and idle emissions, and tampering rates
increased as the vehicles aged.
In 1982, FOSD requested that NEIC perform the survey which is memori-
alized in this report.
* Because participation was voluntary, drivers who knowingly tampered
with their vehicles may have avoided the inspection.
** Arizona, Delaware, Minnesota, New Jersey, Tennessee, Texas, Vermont,
and Virginia
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8
SURVEY METHODS
A goal of inspecting 300 vehicles in each location was established in
order to provide a broad enough database so that the data would be mean-
ingful. All inspections were voluntary; however, selection methods varied
and could have influenced the participation rates. The mix of vehicles
that came to the inspection sites was assumed to be a self-weighting sample,
and no attempt was made to approximate the national vehicle mix.
The inspection teams consisted of two to five inspectors, depending on
the locations of the inspections. Two inspectors were used at inspection
stations, and five at locations where road stops were made. A designated
team leader was responsible for data and sample collection.
Each vehicle inspection included checking all emission control sys-
tems, recording basic data about the vehicle including the addition of cer-
tain after-market parts, measuring HC and CO emissions, obtaining a fuel
sample, and using Plumbtesmo paper to check for lead deposits in the tail-
pipes of vehicles requiring unleaded fuel*. The inspections focused on
1975 and newer light-duty vehicles fueled with gasoline. This included
both passenger cars and light-duty trucks. The condition of each emission
control device was determined and recorded on the inspection form in the
field. Categorization of the results was not made at the time of the in-
spection; however, this was determined by evaluating the recorded data sub-
sequent to the surveys. Detailed inspection and recording procedures are
contained in Appendix B.
The location, dates, number of vehicles inspected, number of fuel sam-
ples analyzed, refusal rates, tampering rates, description of each site,
and procedures used to obtain vehicles for inspection follow.
* The Plwabtesmo paper test was not used for the Oregon survey due to fail-
ure of the test media.
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South Dade County, Florida - Road Stop
Non-I/M
Dates: April 12-16, 1982
Vehicles inspected: 309
Fuel samples: 276
Refusal rate: <1%
Tampering rate: 22.3%
The Florida Highway Patrol provided an officer to conduct a stop of
vehicles, and the inspectors solicited voluntary permission to conduct the
inspections. Locations for the road stops were changed daily in order to
obtain a representative sample of the area.
Baton Rouge, Louisiana - Private Garage Inspection
Non-I/M
Dates: April 19-24, 1982
Vehicles inspected: 183
Fuel samples: 154
Refusal rate: 15%
Tampering rate: 25.1%
The Louisiana State Police did not have the manpower to dedicate the
services of an officer full time for the inspection, so they made arrange-
ments with two private garages to conduct the inspections in conjunction
with State safety inspections. Because of heavy rain during the inspection
period, turnout for the safety inspection was lower than predicted, and the
goal of 300 cars inspected was not achieved.
Houston, Texas - Private Garage Inspection
I/M
Dates: April 26-30, 1982
Vehicles inspected: 293
Fuel samples: 289
Refusal rate: 22%
Tampering rate: 17.7%
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10
The Texas Department of Public Safety will not assist with roadside
inspections; however, they did obtain permission from two private garages
to conduct inspections in conjunction with the required State safety
inspections.
Tulsa, Oklahoma - Private Garage Inspection
Non-I/M
Dates: May 3-7, 1982
Vehicles inspected: 282
Fuel samples: 246
Refusal rate: 3%
Tampering rate: 19.5%
Because the Oklahoma Highway Patrol and Tulsa Police Department, due
to manpower shortages, declined to conduct roadstops, the Tulsa City-County
Health Department arranged for inspections to be conducted at a chain of
auto lubrication stations which were conducting safety inspections. The
inspection locations were changed throughout the survey period in order to
adequately sample the area.
New Jersey - Road Stops
I/M
Dates: July 19-23, 1982
Vehicles inspected: 290
Fuel samples: 220
Refusal rate: 5%
Tampering rate: 15.9%
Road stops were conducted in the southern portions of New Jersey by
the New Jersey Department of Transportation. Locations were changed four
times throughout the week to provide more adequate coverage of that part of
the State.
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11
Rhode Island - Road Stops
I/M
Dates: July 26-30, 1982
Vehicles inspected: 324
Fuel samples: 261
Refusal rate; 8%
Tampering rate: 16.0%
Road stops were conducted by local law enforcement officers of munici-
palities in the Providence, Rhode Island area. Inspection locations were
changed daily and included the towns of Providence (2 days at different
locations each day), New Port, Westerly, and Woonsocket.
Minneapolis, Minnesota - Road Stops
Non-I/M
Dates: August 2-6, 1982
Vehicles inspected: 307
Fuel samples: 251
Refusal rate: 3%
Tampering rate: 16.3%
Road stops were conducted by the Minnesota State Patrol at three loca-
tions in the Minneapolis-St. Paul, Minnesota area.
Seattle, Washington - State Inspection Stations
I/M
Dates: September 14-17, 1982
Vehicles inspected: 312
Fuel samples: 229
Refusal rate: 22%
Tampering rate: 11.2%
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12
Inspections were conducted at the Renton inspection station which per-
forms I/M inspections under contract to the State of Washington. Hydro-
carbon and carbon monoxide emission values were obtained from the State
inspection rather than duplicate the measurement already made.
Portland, Oregon
I/M
Dates: September 21-24, 1982
Vehicles inspected: 310
Fuel samples: 232
Refusal rate: 4%
Tampering rate: 9.7%
Inspections were conducted at two State I/M inspection stations within
the city of Portland.
Las Vegas, Nevada - Service Station/Parking Lot
I/M
Dates: September 27-October 1, 1982
Vehicles inspected: 275
Fuel samples: 244
Refusal rate: 44%
Tampering rate: 17.1%
Inspections were made at service stations conducting inspections on
the first day of the inspection period. However, due to a lack of response,
the location was changed to the Nevada Department of Motor Vehicle Registra-
tion parking lot where participation was solicited from vehicle owners who
had completed their business inside and, in some cases, were in a hurry.
This may have accounted, in part, for the high refusal rate.
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13
RESULTS*
SITE AND AGGREGATE RESULTS
The vehicles were classified into one of four categories (tampered,
arguably tampered, malfunctioning, and okay) based on the results of the
inspection. Because each vehicle inspected had various components which
could be tampered with, the vehicle was classified by the worst state of
any component in the vehicle. For example, if any one component was
"arguably tampered" and all of the other components were functioning pro-
perly, the entire vehicle was classified as "arguably tampered". A vehicle
classified as "okay" must have all observed components functioning
properly.
Results for each 1982 inspection site and for all vehicles are listed
in Table 1. A comparison of tampering rates for the major HC/CO-related
control systems for the 1978, 1979, 1981, and 1982 surveys is shown in
Figure 1.
Trends - Houston, Texas - 1978-1982
Houston, Texas was selected as a survey site during 1982 because it
had been surveyed during the previous three surveys, and a comparison could
be made of these data. A comparison of the data collected during the 1978,
1979, 1981, and 1982 surveys is presented on page 16.
* Computer printouts of the data used to produce the tables and figures in
this section are on file at NEIC and FOSD.
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14
Table 1
VEHICLE STATUS BY AGGREGATE, SITE, AND YEAR OF SURVEY*
Site and
Survey Year
Aggregate - 1982
Florida
1982
Louisiana
1982
Texas
1978
1979
1981
1982
Oklahoma
1982
New Jersey
1979
1982
Rhode Island
1982
Minnesota
1979
1982
Washington
1978
1982
Oregon
1982
Nevada
1982
No. of
Vehicles
2,885
309
183
218
236
209
293
282
318
290
324
300
307
306
312
310
275
Tampered
16.7
22.3
25.1
22.2
22.5
9.6
17.7
19.5
11.0
15.9
16.0
13.3
16.3
15.7
11.2
9.7
17.1
Arguably
Tampered
38.4
26.5
34.4
59.7
50.4
46.9
36.9
35.5
51.6
41.0
32.4
38.7
29.3
41.8
51.9
51.9
42.9
Malfunctioning
1.2
1.0
0.5
1.4
1.7
1.4
2.7
4.3
2.8
0
2.2
2.0
0
2.0
0.3
0.6
0.7
Okay
43.7
52.2
39.9
16.7
25.4
42.1
42.7
41.1
34.6
43.1
49.4
46.0
50.4
40.5
36.7
37.7
43.7
Only sites included in the 1982 survey are presented in this table.
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AIR INJECTION
SYSTEM
CATALYTIC
CONVERTER
FILLER INLET
RESTRICTOR
•£ DATA NOT AVAILABLE FOR THIS YEAR FOR ENTIRE SYSTEM
o
QC
oc
o
oc
LU
Q-
78 79 81 82
78 79 81 82
78 79 81 82
FIGURE 1. COMPARISON OF TAMPERING RATES FOR SYSTEMS BY SURVEYS
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16
COMPARISON OF 1978, 1979, 1981, and 1982 RESULTS
HOUSTON, TEXAS
Vehicle Status
Tampered (%)
Arguably tampered (%)
Malfunctioning (%)
Okay (%)
1978
22.2
59.7
1.4
16.7
1979
22.5
50.4
1.7
25.4
1981
9.6
46.9
1.4
42.1
1982
17.7
36.9
2.7
42.7
As the above comparison shows, the proportion of vehicles judged to be
okay, or have all observed components functioning properly, more than doubled
from 1978 to 1982. Because the 1978 and 1979 surveys included 1973 and
1974 model year cars, and the 1981 and 1982 included only 1975 and newer,
this comparison may be somewhat biased as earlier vintage cars may have a
higher potential for being tampered with. Major technological changes in
emission control equipment occurred in the 1975 model year. These compon-
ents did not exist in earlier model years.
TYPES OF TAMPERING
Because there are many different emission control devices which can be
tampered with, it is necessary to identify these devices.
As shown in Tables 2 and 3, EGR system tampering was the most preva-
lent followed by filler neck restrictor tampering. Limiter cap tampering
was the most prevalent form of arguable tampering for the 1982 survey.
The rates shown in these tables are a comparison of the percentage of
vehicles exhibiting a certain type of tampering among vehicles equipped
with the particular control device. For example, 67.7% of those vehicles
equipped with limiter caps had them tampered with. Since some vehicles are
not equipped with limiter caps, it is not correct to conclude that 67.7% of
all of the vehicles had limiter caps tampered with.
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17
Table 2
RATES OF TAMPERING BY COMPONENT
Component
EGR* system
EGR control valve
EGR sensor
Air injection system
Air pump belt
Air pump control valve
Air pump
Aspirator**
Catalytic converter
PCV*
Vacuum spark retard
Idle stop solenoid
Heated intake
ECS* storage
Filler neck restrictor
1978
Rate (%)
13.0
11.9
5.3
6.6
5.7
2.9
3.2
***
1.2
3.3
10.5
0.7
0.8
2.6
3.4
1979
Rate (%)
9.9
4.6
7.1
4.5
2.1
2.2
2.4
1.2
2.7
1.6
0.6
1.1
2.4
3.8
1981
Rate (%)
5.4
4.9
4.9
4.1
3.1
3.6
3.1
0
3.5
1.5
0.6
0
0
2.0
6.4
1982
Rate (%)
9.8
7.4
6.5
4.6
4.7
2.9
3.1
0.8
4.4
2.5
0.2
.1
0.5
1.5
5.9
* EGR: exhaust gas recirculation
PCV: positive crankcase ventilation
ECS: evaporative control system
** Vehicles with aspirated air systems are not equipped with other
listed air-injection components, nor do conventional systems include
aspirators.
*** Aspirators were not checked during the 1978 survey.
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18
Table 3
RATES OF ARGUABLE TAMPERING BY COMPONENT
Component
Limiter cap
ECS* tank cap
Tank label
Dash label
Heated intake
1978
Rate (%)
65.0
0.3
5.2
0.6
8.5
1979
Rate (%)
62.1
0.6
4.4
0.7
8.0
1981
Rate (%)
82.5
0.8
4.0
0.3
9.0
1982
Rate (%)
53.5**
1.7
3.8
0.7
6.1
* ECS: evaporative control system
** This overall rate can be divided into sealed carburetors,
for which the rate is 6.8%, and conventional carburetors
originally equipped with caps, for which the rate is 74.9%.
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19
The drop in the rate of EGR tampering seen in the 1981 survey was not
seen in the 1982 survey. The 9.8% seen in 1982 closely reflects the 1978
and 1979 surveys (13.0 and 9.9%, respectively) versus 5.4% in 1981. A pos-
sible explanation is that the 5.4% in 1981 is representative of a limited
survey of only two locations and only 399 cars.
EFFECTS OF I/M ON TAMPERING RATES
Ten sites were surveyed — five in non-I/M areas and five in I/M areas.
The results of this survey show an overall tampering rate of 16.7%. The
tampering rates in non-I/M and I/M areas were 19.8% and 13.9%, respectively.
The breakdown between non-I/M and I/M areas is almost identical to the
results in 1979 when the overall tampering rates were 19.7% and 13.2%,
respectively. The primary reason that the overall tampering rate in the
1982 survey is lower than previous national surveys is the inclusion of
five I/M areas. The site specific tampering rates are as follows:
Site 1982 Tampering (%)
(Non-I/M)
Florida
Louisiana
Minnesota
Oklahoma
Texas
Average3
(I/M)
New Jersey
Oregon
Rhode Island
Nevada
Washington
Average
22.3
25.1
16.3
19.5
17.7
19.8
15.9
9.7
16.0
17.1
11.2
13.9
The component-specific tampering rates were also significantly higher
in non-I/M areas than in I/M areas (see table, page 5). The following
table shows the effect of model years on catalyst removal in I/M and non-
I/M areas.
a Averages are computed from totals from non-I/M and I/M areas, respectively.
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20
PERCENT TAMPERED CATALYST - 1982 SURVEY
I/M
Number
of LDV*
Model Vehicles (%)
1975
1976
1977
1978
1979
1980
1981
1982
*
**
69
118
140
178
170
176
162
119
light-duty
light-duty
5.
2.
3.
1.
0.
0.
1.
0.
cars
trucks
EFFECTS OF TAMPERING
8
5
6
1
0
6
2
0
ON
Number
of
Vehicles
5
6
14
13
47
24
22
18
EMISSIONS
LOT**
(.%
0.
0.
0.
7.
4.
4.
4.
0.
;)
0
0
0
7
3
2
5
0
Number
of
Vehicles
58
101
111
153
153
194
201
98
Non-I/M
LDV*
(%)
17.
5.
9.
5.
3.
2.
1.
1.
2
9
0
2
3
6
5
0
Number
of
Vehicles
6
12
6
18
54
34
56
15
LOT**
(%)
33.3
41.7
83.3
27.8
33.3
8.8
7.1
0.0
In order to ascertain the effect of tampering on idle emissions, the
mean idle emissions were calculated for the three categories of vehicles
(okay, tampered, and arguably tampered) for the model years 1975-1982.
These results [Table 4] show that the vehicles judged 'okay1 generally had
much lower emissions than tampered or arguably tampered vehicles. With
only two exceptions, mean idle scores of the tampered group exceeded those
of the okay group for each model year and each pollutant.
Table 4 shows that the mean idle scores for 'okay' vehicles are lower
than tampered vehicles. The table following shows the actual effect of the
New Jersey I/M outpoints on the vehicles in the 1982 survey. This table
indicates that tampered vehicles are more likely to fail an idle test than
okay or arguably tampered vehicles.
-------
21
Table 4
MEAN IDLE EMISSIONS OF TAMPERED, ARGUABLY TAMPERED, AND OKAY VEHICLES
Model Year
75
76
77
78
79
80
81
82
Okay
1.88
1.27
1.87
1.21
1.04
0.43
0.24
0.19
Mean Idle CO
Tampered
2.81
2.83
2.42
2.73
1.98
1.96
1.07
0.03
(%)
Arguably
Tampered
2.08
2.36
2.14
2.29
1.25
0.76
0.95
0.56
Okay
361
152
255
152
140
62
57
33
Mean Idle HC
Tampered
306
276
357
298
256
216
204
50
(%)
Arguably
Tampered
225
299
252
240
140
77
62
48
Wt-Average 0.59 2.39 1.80 89 283 202
-------
22
FAILURE RATES ON VEHICLE STATUS AND CATALYST REMOVED
OR FUEL SWITCHED VEHICLES FOR IDLE HC AND CO
ACCORDING TO NEW JERSEY CUTPOINTS
HC CO
Arguably Arguably
Okay Tampered Tampered Cat/Fuel* Okay Tampered Tampered Cat/Fuel
7.70 30.98 22.11 34.59 7.78 36.17 26.08 32.19
* Vehicles in this category either have their catalyst removed or have
at least one of the three indicators of fuel switching.
TAMPERING BY VEHICLE AGE
As shown in Table 5, the overall tampering rate increases as the vehi-
cle ages, with the tampering rate climbing to over one-third of the cars by
the eighth year of vehicle life. These data tend to substantiate the re-
sults of the 1978, 1979, and 1981 surveys, which are also shown in Table 5.
Also, the catalyst removal rate increases as the vehicle age increases. As
shown in Table 6, the removal rate increased from 0% in the first year of
vehicle life to 11.5% in the eighth year of vehicle life.
TAMPERING RATES BY VEHICLE MANUFACTURER
A comparison was made by vehicle manufacturer for the 1978, 1979, 1981,
and 1982 surveys [Table 7], As during the previous surveys, AMC had the
highest tampering rate during the 1982 survey (27.2%) with vehicles of Japa-
nese manufacture having the lowest (3.9%).
TRUCK TAMPERING
The 1982 survey contained 419 light-duty trucks. The overall and
component-specific tampering rates for trucks were very high. The results
are as follows:
-------
Table 5
PERCENT TAMPERED AND SAMPLE SIZE BY MODEL YEAR AND VEHICLE AGE AT TIME OF SURVEY
Model
Year First
1982 1.2(250)
1981 1.8(57)
1980
1979 5.5(371)
1978 7.4(298)
1977
1976
1975
1974
1973
Year of Vehicle
Second Third Fourth
6.5(448)
4.8(63) 8.8(454)
8.5(59) 18.0(477)
13.8(502) 15.2(79) 21
10.1(457) 14.9(476) 21
17.7(395) 19.0(374)
22.3(274) 21
32
Life
Fifth
.4(430)
.2(66)
.7(271)
.6(276)
Sixth Seventh Eighth
26.3(316)
28.8(52) 25.9(317)
31.8(22) 36.6(183)
27.4(242)
32.0(253) 35.6(251)
IX)
CO
-------
Table 6
PERCENT CATALYST REMOVED AND SAMPLE SIZE BY MODEL YEAR
AND VEHICLE AGE AT TIME OF SURVEY
Model
Year
1982
1981
1980
1979
1978
1977
1976
1975
First
0.40(250)
0(57)
0(326)
0(291)
Second
2.3(441)
1.6(61)
0.45(445)
0.72(417)
Third
2.3(428)
3.6(55)
1.2(417)
1.6(377)
Year
Fourth
5.9(429)
0(71)
2.3(305)
1.6(242)
of Vehicle Life
Fifth Sixth Seventh
4.4(362)
1.7(59) 7.4(271)
10.4(48) 5.9(257)
2.0(204) 26.3(19)
Eighth
11.5(139)
PO
-------
Table 7
COMPARISON OF 1978, 1979, 1981, and 1982 TAMPERING DATA BY VEHICLE MANUFACTURER
1978
Manufacturer
CMC
Ford
Chrysler
AMC
European
Japanese
Aggregate
% Tampered
19.9
20.4
19.8
32.3
13.5
7.4
17.7*
No. Vehicles
Inspected
894
496
237
65
89
203
1,984
1979
% Tampered
17.1
20.8
24.3
24.4
14.78
5.7
18.3
No. Vehicles
Inspected
1,121
557
375
78
115
224
2,490
1981
% Tampered
12.2
25.0
12.5
33.3
8.3
0
14.3
No. Vehicles
Inspected
221
85
40
6
12
38
399
1982
% Tampered
18.1
19.4
22.5
27.2
15.7
3.9
16.7
No. Vehicles
Inspected
1,228
634
320
103
115
485
2,885
* This rate is different from value reported in 1978 report (18.9%) because certain data points were judged to be invalid
and were deleted.
K)
Ul
-------
26
TRUCK TAMPERING (%)
1982 SURVEY
Catalyst
Air pump system
Filler inlet
Overal 1
Overal 1
13.3
7.6
13.5
25.1
I/M
3.3
1.8
6.2
16.4
Non-I/M
20.7
12.6
19.1
32.2
FUEL-RELATED TAMPERING
Multiple indicators. While a simple definition of fuel switching is
possible, a single indicator for detection of this activity is very likely
to underestimate its prevalence. For instance, a vehicle which was repeat-
edly improperly fueled with leaded gasoline during a gasoline shortage may
have a deactivated catalytic converter, but due to proper subsequent fuel
use, may have little detectable lead in its fuel tank. This situation may
also characterize the "occasional" user of leaded fuel.
In order to obtain a better picture of fuel switching, this survey
includes three indicators which, singly and in combination, may provide
more adequate information than any one measure by itself. The indicators
include fuel filler inlet restrictor tampering, a Plumbtesmo test for lead
deposits in the tailpipe, and the presence of more than .05 g/gallon of
lead in the gasoline. While the presence of lead in the fuel provides a
very strong indication of switching, its absence does not indicate that
switching has not occurred in the past. Likewise, but for different rea-
sons, the other two measures individually also present the problem of in-
correct negative findings where switching has actually occurred. A vehicle
with an untampered fuel filler inlet restrictor may have been fueled with a
funnel or similar device. The tailpipe lead test, due to the difficulties
of field administration, may fail to indicate the presence of lead, and
older vehicles may have had their tailpipes replaced since they were oper-
ated on leaded fuel. The error in these measures, then, is always in the
direction of underestimating the proportion of catalysts damaged through
exposure to improper fuel.
-------
27
Fuel switching rates. Of the vehicles requiring unleaded fuel, 10.6%
were identified as fuel switched by at least one of the indicators discussed
above. Table 8 displays the rates found for individual indicators as well
as the composite rates for I/M and non-I/M.
Indicator overlap. The survey results seem to show less overlap than
one might expect among these three indicators of the same phenomenon [Fig-
ure 2]. This tends to lend credence to the position that these measures
reflect different aspects of fuel switching activity.
Since incorrect positive indications are extremely rare for these mea-
sures, the percentage of vehicles with at least one positive indicator seems
most reasonable as a minimum estimate of the fuel switching rate in these
cities. Reasons for the real rate possibly being higher include the nega-
tive bias of the hastily field-administered Plumbtesmo tailpipe test and
the bias always associated with refusal to participate in a non-compulsory
survey. The nature and possible magnitude of this bias was discussed in
the report on the 1979 tampering survey.
Fuel-switching Rate
Site (%)
Florida
Louisiana
Minnesota
Oklahoma
Texas
Average*
New Jersey
Oregon**
Rhode Island
Nevada
Washington
Average*
Non-I/M
19.23
12.50
9.76
18.60
15.03
15.14
I/M
11.40
1.57
3.72
10.42
3.85
6.18
* Averages are computed from totals
from Non-I/M and IM areas, respec-
tively.
** Plumbtesmo indicator not used during
this inspection due to failure of
the test paper; actual rates may be
higher.
-------
Table 8
FUEL SWITCHING RATE FOR 1982 SURVEY BY SITE AND INDICATOR
Percent with Percent with Percent with Percent with
at Least One >.05 g/gallon Tampered Positive
Positive Indicator Lead in Gasoline Filler Restrictor Tailpipe Test
Non-I/M
Texas
Florida
Oklahoma
Minnesota
Louisiana
Average non-I/Ma
15.03
19.23
18.60
9.76
12.50
15.14
6.64
10.49
11.24
7.41
7.14
8.65
I/M
9.44
9.09
12.79
4.38
8.33
8.73
10.14
15.73
13.18
6.06
10.12
11.04
New Jersey
Rhode Island
Seattle
Las Vegas
Oregon
Average I/Ma
Average (all sites)3
11.40
3.72
3.85
10.42
1.57
6.18
10.58
8.09
1.69
1.54
6.18
1.57
3.80
6.18
4.78
2.36
2.31
6.18
0
3.13
5.88
7.35
2.03
.77
5.02
(no test)
3.06
6.98
a Averages are computed from totals from non-I/M and I/M areas, respectively.
ro
OD
-------
POSITIVE
PLUMBTESMO £
>0.05 g/gal
163 CARS TOTAL
184 CARS TOTAL
TAMPERED FILLER RESTRICTOR
I 155 CARS TOTAL
VEHICLES REQUIRING UNLEADED FUEL (2637 TOTAL)
FIGURE 2 COMPARISON OF MULTIPLE INDICATORS
-------
30
As can be seen, the fuel-switching rates for the non-I/M areas are
more than double the rates for the I/M areas.
ADD-ON AND NON-STOCK EQUIPMENT
Because add-on and non-stock equipment are available which could affect
emissions, each vehicle was checked for the installation of these devices.
This equipment includes turbochargers, non-stock air cleaners, intake and
exhaust manifolds, distributors, exhaust systems, and various alleged fuel-
saving devices. During the 1982 survey, the addition of such equipment was
recorded in only four of the 2,885 vehicles surveyed.
-------
APPENDICES
A SECTIONS 203(a)(3)(A) AND 203(a)(3)(B) OF THE CLEAN AIR ACT
B DATA COLLECTION AND RECORDING PROCEDURES
-------
APPENDIX A
SECTIONS 203(a)(3)(A) AND 203(a)(3)(B) OF THE CLEAN AIR ACT
-------
A-l
"Section 203(a)(3): The following acts and the causing thereof are
prohibited --
(A) for any person to remove 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 this title prior to its
sale and delivery to the ultimate purchaser, or for any manufacturer
or dealer knowingly to remove or render inoperative any such device or
element of design after such sale and delivery to the ultimate pur-
chaser; or
(B) for any person engaged in the business of repairing, servicing,
selling, leasing, or trading motor vehicles or motor vehicle engines,
or who operates a fleet of motor vehicles, knowingly to remove or ren-
der inoperative any device or element of design installed on or in a
motor vehicle or motor vehicle engine in compliance with regulations
under this title following its sale and delivery to the ultimate
purchaser.
-------
APPENDIX B
DATA COLLECTION AND RECORDING PROCEDURES
-------
3-1
DATA COLLECTION AND RECORDING PROCEDURES
The following data will be recorded on the data sheet shown as Figure A-l.
a. Date
b. Vehicle identifying survey number - Vehicles shall be numbered
sequentially as they are inspected, and this number, shall be
preceded by a site identifying letter.
c. Odometer mileage (in thousands).
d. Air cleaner, intake manifold, and exhaust manifold - if these
parts are original equipment a "P" is coded. If these parts
are aftermarket or non-stock a "6" is coded.
e. Model year - obtained from underhood emission label.
f. Make
g. Model
h. Exhaust system and distributor are coded "P" or "6" as explained
above under item d.
i. Turbocharger may be coded "P", "6", "A", or "0". The "A" is
used to indicate add-on equipment and the "0" for not equipped.
j. Carburetor - In column 30 a "P" is used to indicate that the
carburetor is a production unit (original equipment). If fuel
t
injection is used, then a "F" is recorded. If the carburetor
has been replaced with a non-stock unit, then a "6" is recorded
and if the carburetor is a sealed unit (without limiter caps),
an "S" is recorded. In column 31 indicate the number of
barrels for carburetors or an "I" for fuel injection.
k. Engine family/CID (cubic inch displacement) as recorded from
the underhood emission label.
-------
B-2 2
1. PCV (positive crankcase ventilation) line may be coded "P" or "A1
The "A" is used to indicate add-on equipment. Particular
attention should be paid to fuel economy devices installed in
the PCV line.
m. The category "other" may be coded "A" or "P" and is used to
designate other add-on equipment such as fuel line devices
added on to reduce fuel consumption.
The following codes, will be used to record data on the data sheet shown
as Figure A-2.
0 - Not equipped
1 - Item is functioning properly
2 - Electrical disconnect
3 - Vacuum disconnect
4 - Mechanical disconnect
5 - Incorrectly routed hose
6 - Non-stock equipment
7 - Missing item
8 - Mi sadjusted item
9 - Malfunctioning item
N* - Negative
Y* - Positive
*To be used in column 75 to designate the results of the Plumbtesmo
paper.
-------
3
B-3
The codes are designed so that the inspector can objectively record the
condition of the device and not have to make an "on the spot" judgement
with respect to tampering.
The following items will be inspected and the results recorded on Figure A-2.
a. Idle stop solenoid - This solenoid provides an idle stop for
maintaining idle speeds to the higher speeds needed to minimize CO
emissions. On some vehicles, it is used to close the throttle and
thus prevent run-on when the engine ignition is turned off. On
vehicles with air conditioning, it is used for increasing engine
idle speed to compensate for a decrease in idle speed when the air
conditoner is engaged.
With the air conditioner on, (or in non-air conditioned vehicles)
the solenoid should activate and contact the throttle linkage.
With the air conditioner turned off, there should be a small gap
between the solenoid stop and the throttle linkage.
The idle stop solenoid will be coded as follows:
0 - Not equipped
1 - Functioning properly
2 - Electrical disconnect
7 - Missing item
9 - Malfunctioning - If the gap between the solenoid and the
throttle plate is incorrect.
b. Heated air intake - Provides warm air to the carburetor during cold
engine operation. The heated air intake will be coded as follows:
0 - Not equipped
1 - Functioning properly
3 - Vacuum disconnect - If the vacuum line to the vacuum override
motor is missing or disconnected.
-------
4 - Mechanical disconnect - When the stovepipe is missing, dis-
connected or deteriorated. Also when the air cleaner has been
unsealed, i.e., inverted air cleaner lid, oversized filter
element, or holes punched into air cleaner.
6 - Non-stock equipment - Custom air cleaner.
7 - Missing item - Missing stovepipe hose
9 - Malfunctioning item - Problems with the vacuum override motor.
c. Limiter caps - Plastic caps on idle mixture screws designed to
limit carburetor adjustments. Limiter caps will be coded as follows;
0 - Not equipped
1 - Functioning properly
4 - Mechanical disconnect - Tabs broken or bent
7 - Missing item
8 - Misadjusted item (sealed plugs have been removed)
d. Positive crankcase ventilation system - A typical configuration for
a V-8 engine consists of the PCV valve connected to a valve cover
and then connected to the carburetor by a vacuum line. The other
part of the system has a fresh air tube running from the air cleaner
to the other valve cover. The PCV will be coded as follows:
0 - Not equipped
1 - Functioning properly
3 - Vacuum disconnect - When the line between the PCV valve and
the carburetor is disconnected
4 - Mechanical disconnect - When the fresh air tube between the
valve cover and the air cleaner is disconnected or removed.
7 - Missing item - When the entire system has been removed.
'/
e. Evaporative control system - Controls vapors from the fuel tank and
carburetor. Some systems have two lines, one from the fuel tank to
the canister, and one from the canister to the carburetor or air
cleaner to air purge the canister. Other systems have a third
line, usually connected to the carburetor. The ECS will be coded
as follows:
-------
0 - Not equipped B_5
1 - Functioning properly
3 - Vacuum disconnect-Line from canister to carburetor or air cleaner discon-
nected-
4 - Mechanical disconnect-Line from fuel tank to canister disconnected.
5 - Incorrectly routed hose
7 - Missing item
9 - Malfunctioning 'item - When the purge line is connected to the
air cleaner and the air cleaner is unsealed.
f. Tank cap - Part of the evaporative system, the tank cap seals vn'th
the filler neck to maintain a closed system. Tank caps will be
coded as follows:
1 - Functioning properly
7 - Missing item
9 - Malfunctioning item - Tank cap not sealing properly
g. Air injection system - Consists of an air pump driven by a belt
connected to the crankshaft pulley. The pump directs air through a
control valve and lines connected to the exhaust manifold. An air
injection system may also consist of an aspirator located in the
air cleaner that supplies air to the exhaust manifold. The air
injection system is broken down into three parts which are coded as
fol1ows:
Air pump
0 - Not equipped /
1 - Functioning properly
4 - Mechanical disconnect
7 - Missing item
9 - Malfunctioning
Air pump belt
0 - Not equipped
1 - Functioning properly
7 - Missing item
8 - Misadjusted item - Loose pump belt
. Note: If the vehicle is equipped with an aspirator, the air pump
belt is coded "0".
-------
B-6 °
Air pump control valve
0 - Not equipped
1 - Functioning properly
3 - Vacuum disconnect
4 - Mechanical disconnect
7 - Missing item
9 - Malfunctioning item
h. Exhaust gas recirculation (EGR) system - The standard configuration
consists of a vacuum line from the carburetor to a sensor (used to
detect temperature to activate the EGR valve), and another vacuum
line from the sensor to the EGR valve. Some systems have multiple
sensors and thus additional vacuum lines. The system directs a
portion of the exhaust gases back into the cylinders for the
control of oxides of nitrogen. This is one system where a func-
tional check will be performed.
Non-sealed EGR valve functional will consist of:
1. Visually inspecting to see if the valve, sensor(s) and hoses
are in place.
2. If the system is intact, revving the engine and checking
visually or by touch the EGR valve stem movement.
3. If the stem fails to move, pulling off the vacuum line to the
valve and checking for vacuum while the engine is revved. If
vacuum occurs, the valve is not functioning and the hose
nipple on the valve will be checked for blockage. If vacuum
does not occur, the line will be checked for blockage. If it
is not blocked-, a hand vacuum pump will be connected to the
sensor outlet and the engine revved. If a vacuum is obtained,
the sensor is functional. If no vacuum is obtained, the line
from the sensor to the carburetor will be checked for vacuum
while the engine is revved. If this line has vacuum, then the
sensor is not functioning and will be checked for a plugged
port.
-------
7 B-7
4. Some systems have a vacuum delay valve. If the EGR valve is
not functioning, checking the delay valve for plugs and that
it is not installed backwards.
Sealed EGR valve functional check will consist of:
1. Visually inspecting the system.
2. Disconnecting the vacuum hose to the EGR valve. The hand
vacuum pump will be connected to the valve and vacuum applied
with the engine running. If idle speed drops with the appli-
cation of vacuum, the valve is good. The vacuum pump should
then be inserted into the line leading to the valve's vacuum
source. The engine will be revved to determine if vacuum is
available. If vacuum is not available, the sensors and hosing
are checked using the same procedures described for the non-
sealed unit.
The EGR control valve and sensor are coded as follows:
EGR control valve
0 - Not equipped
1 - Functioning properly
3 - Vacuum disconnect - Disconnect, removed or plugged vacuum line
7 - Missing item (entire valve removed)
9 - Malfunctioning item
EGR sensor
0 - Not equipped
1 - Functioning properly
3 - Vacuum disconnect
5 - Incorrectly routed hose
7 - Missing item
9 - Malfunctioning item
-------
B-8 b 8
'i. Catalytic converter - Oxidizes the CO and HC to water and C02 in
the exhaust gases. The converter will be coded as follows:
0 - Not equipped
1 - Functioning properly
7 - Missing item (catalyst removed from cannister or entire
cannister removed)
9 - Malfunctioning item - High temperature discoloration usually
light blue.
j. Dash and tank labels - will be coded as follows:
0 - Not equipped
1 - Functioning properly
7 - Missing item
k. Filler neck inlet restrictor (unleaded vehicles only) - The restrictor
is designed to prevent the introduction of leaded fuel into a
vehicle requiring unleaded fuel. It will be coded as follows:
0 - Not equipped
1 - Functioning properly
4 - Mechanical disconnect - Widened to fit a leaded filler nozzle
7 - Missing item
1. Vacuum spark-retard - Adjusts the timing as RPM changes. It works
on manifold vacuum which is a function of RPM. The vacuum spark
retard will be coded as follows:
0 - Not equipped
1 - Functioning properly
2 - Electrical disconnect
3 - Vacuum disconnect - Any removed, plugged, or disconnected
vacuum 1ine
-------
4 - Mechanical disconnect
5 - Incorrectly routed hose
7 - Missing item
9 - Malfunctioning item
m. Tampering source - Drivers will be asked who services their vehicle.
The following codes shall be used to explain their answers:
K - Don't know
0 - Owner or non-mechanic
D - Dealer
M - Mechanic
n. HC in ppm and CO in percent with the engine at curb idle.
o. Plumbtesmo - Plumbtesmo paper is used to check for the presence of
lead in vehicle exhaust pipes. A positive indication will be coded
as "Y" and a negative as "N".
The data sheet shown as Figure A-3 will be used to keep an accurate
record of those not participating. All forms will be numbered and
handled according to the NEIC document control procedures.
-------
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7 - Hi c.s ing I 'cor,1.
3 - J-iised jus ted I Lciii
9 - J-'icilf nnct ioni.na Item
ti - Negative
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B-12
Location
I ililll '. A-J
MOTOR VEHICLE TAMPERING SURVEY
RECORD OF l!OM-PART[CIPATIi!G VFJIICIJ'S
Date
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B-13
ATTACHMENT B
FUEL SAMPLE COLLECTION AND LABELING PROCEDURES
A fuel sample will be taken from each vehicle requiring unleaded
fuel. These samples will be collected in 4 ounce bottles with a hand
fuel pump. Once the sample is drawn, the fuel will be replaced with an
equivalent amount of unleaded fuel if the driver requests and the pump
will be flushed with unleaded fuel.
Each bottle will be identified with a stick-on label that has the
vehicle identifying survey number on it. The vehicle identifying survey
number is the first entry on data forms described in Attachment A.
Prior to shipment from the field, a sample tag with the same
identifying number will be attached to each bottle. The bottles will be
packaged, labeled, and shipped to the NEIC Chemistry Branch according to
shippers requirements and the NEIC Policy and Procedures Manual.
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6-14
ATTACHMENT C
INSTRUCTIONS FOR USING PLUMBTESHO TEST PAPER
Plumbtesmo test paper can be used to determine the presence of lead
and lead salts on' surfaces. To test for the presence of lead, the paper
is moistened with distilled water and pressed firmly for 10 to 20 seconds
against the surface to be tested. The presence of lead is indicated
when the paper turns from light yellow to pink or dark violet.
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B-15
ATTACHMENT D
FIELD QUALITY CONTROL/ASSURANCE
Reference and calibration gases will be used to assure the accuracy
of the emissions measuring instruments. Horiba gases certified by RTF
will be used as reference gases. Two cylinders of reference gas will be
used to validate the accuracy of the calibration gases before they are
taken to the field on each survey.
Three calibration gases (Horiba) will be used. These gases will be
a mixture of CO and HC in nitrogen and will be used to check the instrument
at least three times daily. These calibration gases are certified by
the manufacturer and the RTP reference gases. Their approximate con-
centration is:
18% CO
1560 ppm HC (Hexane equivalent)
4% CO
827 ppm HC (Hexane equivalent)
• 1.6% CO
320 ppm HC (Hexane equivalent)
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ATTACHMENT E
Federal Register / Vol. 47, No. 4 / Thursday, lanuary 7, 1982 / Rules and Regulations
(Section llfl(d) and Section 301(
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Vul- 47-
4 /
January 7, VYA2 / Rules and Refutations
7
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B-18
Federal Register / Vol. 47, Mo. 4 / Thursday, January 7, 1982 / Rules and Regulations
2.4 The addition of the quaternary
ammonium sail improves response and
increases the stability 01" the alkyl iodide
complex.
3. Scruple Handling and Preservation. 3.1
Samples should be collected and stored in
cont3:ners which will protect them from
changes in the lead content of the gasoline
such iis from loss of volatile fractions of the
g-isul'ne by evaporation or leaching of the
leud intn the container or cap.
3 2 If samples have been refrigerated they
should be brought to room temperature prior
to analysis.
4. Apparatus. 4.1 AutoAnalyzer system
corsi>lmg of:
4.1.1 Sampler 20/hr cam, 30/hr cam.
4 1.2 Proportioning pump.
4.1 3 Lead in gas manifold.
4.1.4 Disposable test fub»s.
4.15 Two 2-liter and one 0.5 liter
Erler.Tieyer solvent displacement flasks.
Alternatively, high pressure liquid
chromatography (HPLC) or syringe pumps
may be used.
4 2 " Atomic Absorption Spectroscopy
(AAS) De'ector System consisting oh
4.2.1 Atomic absorption spectrometer.
4.2.2 10" strip chart recorder.
42.3 Lead hollow cathode lamp or
electrcdeless discharge lamp (EDL).
5. r.eugenls. 5.1 Ahquat 336/MIBK
soloiion (10% v/v): Dissolve and dilute 100 ml
(38.0 ?) of Aiiquat 336 (Aldnch Chemical Co,
Milwaukee, Wisconsin) with MIBK (Burdick
& Jackson Lab., Inc., Muskegon. Michigan) to
one li'er.
5.2 Ahquat 333/iso-octane solution (1% v/
v)- Dissolve and dilute 10 ml (8.8 g) of Alquat
335 (reagent 5.1) with iso-octane to one liter.
5.3 Iodine solution (S'X w/v): Dissolve and
dilule 3.0 g iodine crj sials (American
Chemical Society) with toluene (Burdick &
jackscn Lab.. Inc.. Muskegon, Michigan) to
ICO ml.
5.4 Iodine working solution (0 247J w/v):
Dilute 3 ml of reagent 5.3 to 100 ml with
toluppe.
5 5 Methyl isobutyl ketone (MIBK) (4-
methlyl-2-pentanone).
56 Certified unleaded gasoline (Phillips
Chemical Co- Borger, Texas) or iso-octane
(Burdick & Jackson Lab, Inc., Muskegon,
Mich'gan).
6. Calibration Standards. 6.1 Stock 5.0 g
Pb/sal Standard:
Dissolve 0.4433 gram of lead chloride
(PbC!.) previously dried at 105"C for 3 hours
in 2HO m' if 10^ v/v Ahquat 336/MIBK
solution ('--aijent 5.1) in a 250 ml volumetric
flajk. Dilut" to vol'ime with reagent 5.1 and
store in an amber bottle.
6 2 Intermediat? 1 0 g Pb/gal Standard:
Fipri 50 ml of the 5 0 g Pb/r;al standard into
a 230 -n! \olumr-tnc flask and dilute to
vclu-ne with a 1% v/v Aliquat 336/iso-octane
soi.ilion ,'r"dgen( 5 2). S'ore m an amber
bottla
63 \Vorking002.0.05.0.10g Pb/gal
Pi pat 2 0. 5 0, and 10.0 ml of the 1 0 g Pb/gal
solution to ICO ml volumetric flasks. Add 5 ml
of a ITS Aliquat 336/iso-octane solution to
each flask. Dilute to volume with iso-octane.
These solutions contain 0.02. 0.05, and 0.10 g
Pb/gal in a 0.05-4 Aliquat 336/iso-octane
solution.
7. AAS fnstninnentul Conditions. 7.1 Lead
hollow cathode lamp.
7.2 Wavelength: 203.3 nm.
7.3 Slit:
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Fed oral Resistor / Vol. 47, No. -I / Thru '.lay, January 7. 1982 / Rules and Regulations 7FJ7
• i^TI-i . _ji _ - -n ___ • . I-J-_.-|-TT. " i ___ . "_ - — i. _ i ___ m. ITILL TJLJ -- ir- i — r - ------ 1- -|_- _ -- -'-, _ rjTiL-LJ ___ in i in,« _ Lr^rr _ T _ i ___ r~ __ airmiri ari-iT ___ Jia_. »ji
B- 19
10 2.1 The an i! vis ot Ndtional Bureau of
Standards (NDS) ''-'id in reference fuel of
known com.enlri'ions in ,1 sin.qle laboratory
has resulted in found \ allies deviating from
the true value for 11 determinations of 0 (XJ22
g P'o/gal by an average of 0 SB'S with a
standard deviation of 6 3K>, for !5
determinations of 0 0519 g Pb.'sal by nn
average of —1.1 j with a standdiQ deviation
of 5 80. ar.d for 7 determinations of 0.0723 g
Fb/yal by an .'iverage of 3.5",i with a standrird
deviation of 4 3"j.
10 2.2 Twenty-three analyses of blind
reference sdmoles in a single laboratory (U S.
EPA. RTP. N C ) have resulted m found
values differing ::om the true value by an
average of — 0 CC09 5 Pb/gal with a standard
deviation ofOC04. '
10 2.3 In a single laboratory, the average
percent recovery of 1C8 spikes made to
samples was lOl'-'i with a standard deviation
BIU.ING CODE 65SO-:»-M
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