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.

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                                                                      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

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                                                                      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:

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                                          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

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                        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

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                                                         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

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                                                                      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.

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                                                                      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.

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                                               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

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       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

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                                                                      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.

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                                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

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                                                                     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.

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               APPENDIX B





DATA COLLECTION AND RECORDING PROCEDURES

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                                                                        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.

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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.

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                                                                   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".

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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.

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                                                                    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

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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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-------
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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(
-------
                                   Vul- 47-
4 /
                         January 7, VYA2  / Rules and  Refutations
                                                                                                                         7
-------
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

-------