^ "A iaa» % ^ PRO"^ Office of Air and Radiation Motor Vehicle Tampering Survey -1988 May 1989 \ u \ Field Operations and Support Division Office of Mobile Sources Washington, D.C. ------- ei 53S » PRO^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 JUN 16 060 OFFICE OF AIR AND RADIATION MEMORANDUM SUBJECT: 1988 Motor Vehicle Tampering Survey Report FROM: Al Manna to, Chief Regional/State/Local lS<55r5frfa16ron Section TO: Regional Librarians Two copies of the Field Operations and Support Division 1988 Tampering Survey are attached for inclusion in your library's periodical section. A limited .supply of these reports are available, so please retain these as permanent copies and direct any specific inquiries to your Region's Air Management division, or have them write to: U.S. EPA Office of Air and Radiation (EN-397F) Regional/State/Local Coordination Section 401 M Street S.W. Washington, DC 20460 Verbal inquiries can be directed to Paul Argyropoulos at 202- 475-8839 for those areas within Regions I, III, V and IX; to Bonnie Crystall at 202-475-8837 for those areas within Regions II, IV, VII, and VIII; and to Dean Ross at 202-382-2947 for those areas within Regions VI and X. Attachment ------- TABLE OF CONTENTS EXECUTIVE SUMMARY 1 Introduction 1 Conclusions 2 BACKGROUND 6 SURVEY METHODS 7 Site Descriptions 8 RESULTS 13 Vehicle Tampering 13 Site and Aggregate Totals 13 Types of Tampering 13 Vehicle Characteristics and Tampering 16 Manufacturer 16 Vehicle Type 17 Vehicle Age 19 Impact of I/M and Antitampering Programs 21 Tampering Trends for Selected Sites 23 Correlation Between Tampering and Idle Emissions 31 Fuel Switching 34 Fuel Switching Indicators and Overlap 34 Fuel Switching Trends 36 Fuel Switching by Vehicle Type 38 Fuel Switching and Catalyst Tampering 39 Gasoline Lead Concentrations 41 APPENDIXES A. Relevant Portions of Clean Air Act 43 B. Survey and Data Recording Procedures 43 C. Emission Cutpoints for I/M Areas 49 - i - ------- LIST OF FIGURES 1. Tampering rates for selected components by program type 4 2. (a) Overall tampering by vehicle age for vehicles not covered by l/M and/or antitampering programs 5 (b) Comparison of catalyst tampering by vehicle age between vehicles covered and not covered by a catalyst inspection program 5 3. Breakdown of surveyed vehicles by condition and extent of tampering (Percentages do not add up to 100% because of rounding error) 14 4. Tampering rates by manufacturer: 1988 survey 18 5. Classification of 1988 survey sites by program type (and model year coverage), with the resulting tampering and fuel switching rates for each program type 22 6. (a)-(f) Comparisons of component-specific tampering rates by model year between vehicles covered and not covered by ATPs 27 - 29 (a) Catalytic Converter 27 (b) Inlet Restrictor . 27 (c) Air Pump System 28 (d) Evaporative System 28 (e) PCV System 29 (f) EGR System 29 7. Comparison of overall component-specific tampering rates among vehicles covered and not covered by ATPs (summary of Figures 6(a)-(f)) 30 8. Distribution of unleaded vehicles surveyed among tampering, misfueling, and idle test categories 32 9. (a) Overlap of fuel switching indicators among misfueled vehicles for which Jill three indicators were inspected 35 (b) Breakdown of misfueled vehicles in 9(a) by prevalence of each indicator combination 35 10. Overlap of catalyst tampering and fuel switching among catalyst-equipped vehicles -1988 survey 39 11. (a) Overlap of indicators used by ATPs to detect missing/damaged catalysts. Only includes vehicles for which all three indicators were inspected and are not covered by an ATP with plumbtesmo testing 40 (b) Breakdown of vehicles in 11(a) by prevalence of each indicator combination 40 12. Distribution of lead concentrations in leaded fuel sampled from fuel switched vehicles: 1984 - 88. Percentages based on all fuel switched vehicles, including those using unleaded fuel ( < 0.05 gpg.) 42 - ii - ------- LIST OF TABLES 1. 1988 Tampering Survey Summary : 15 2. Prevalence of Tampering by Component 16 3. Component-Specific Tampering Rates (P ercent) by Survey Location -1988 Survey 17 4. Tampering Percentage (and Sample Size) by Model Year and Vehicle Age at Time of Survey 20 5. Percentage of Catalyst Removal (and Sample Size) among Catalyst-Equipped Vehicles by Model Year and Vehicle Age at Time of Survey. 20 6. Comparison of 1988 Survey Sample to Actual Nationwide Vehicle Fleet 23 7. Tampering Prevalence among Vehicles and Components Covered by Antitampering Programs in ATP-only Areas Surveyed between 1983 -1988 24 8. Tampering Prevalence among Vehicles and Components Covered by Antitampering Programs in I/M + ATP Areas Surveyed between 1983 -1988 25 9. Idle Test Failure Rates (Percent) by Pollutant and Vehicle Condition 33 10. Mean Idle Emissions for Tampered and Okay Vehicles Within Each Program Type 33 11. Fuel Switching Rates among Unleaded Vehicles by Site and Indicator: 1988 Survey 36 12. Combined Tampering and Fuel Switching Rates -1988 Survey 37 13. Prevalence of Fuel Switching Indicators by Program Type 38 14. Prevalence of Fuel Switching Indicators by Vehicle Type 38 - iii - ------- EXECUTIVE SUMMARY INTRODUCTION Under the direction of the Field Operations and Support Division (FOSD) of the Environmental Protection Agency (EPA), contract personnel from Colorado State University (CSU) conducted a survey of light-duty motor vehicle tampering in 15 cities between March and August, 1988. The areas surveyed and the number of vehicles inspected per site are listed below. TUcson, AZ 424 San Antonio, TX 533 Phoenix, AZ 450 Columbia, SC 505 Stockton, CA 500 New York, NY 406 Baton Rouge, LA 523 New Jersey 520 Houston, TX 550 Birmingham, AT- 500 El Paso, TX 515 Orlando, FL 500 Albuquerque, NM 500 Medford, OR 328 Oklahoma City, OK 505 TOTAL 7,259 vehicles The objectives of this survey were: 1. To make local measurements of the types and extent of tampering and fuel switching. 2. To extend and update the knowledge gained from earlier surveys on: a. The effect of vehicle inspection and maintenance (I/M) programs and antitampering programs (ATPs) on tampering and fuel switching. b. The relationship between tampering and vehicle idle emissions. c. The distribution of tampering by vehicle age, type, manufacturer, and other variables of interest. To achieve these objectives, the inspection teams visually examined emission control devices and measured the idle hydrocarbon (HC) and carbon monoxide (CO) emissions of each vehicle. To provide information on fuel switching, the inspectors sampled gasoline from the tanks of vehicles (for later laboratory lead analysis), tested for lead deposits in tailpipes using Plumbtesmo test paper, and checked the integrity of the fuel filler inlet restrictors. Four categories were used to summarize the condition of the inspected vehicles: 1. Tampered - at least one control device removed or rendered inoperative 2. Arguably Tampered - possible but not clear-cut tampering (i.e., may have resulted from either tampering or malmaintenance) 3. Malfunctioning 4. Okay - all control devices present and apparently operating properly ------- Motor Vehicle Tampering Survey -1988 Page 2 These brief but thorough inspections were performed with the consent of the vehicle owners in a variety of settings more fully detailed elsewhere in this report. The site selection in recent tampering surveys has been based more on the need to evaluate control program effectiveness than the desire to methodically sample the U.S. vehicle population. In the 1988 survey, for example, only the 1975 -1983 model year vehicles surveyed in New York were covered by an I/M-only program. These vehicles comprised only 2% of the survey, compared to the 10% of the vehicles nationwide which are subject to such programs. The lack of any true I/M-only sites in the 1988 survey makes it inappropriate to use this survey as representative of the nationwide vehicle population. Rather, the 1988 survey sample is an appropriate tool for evaluating tamper- ing prevalence at any particular site, and for evaluating control program effectiveness where "before" and "after" data exist. This report will refrain from comparing the overall 1988 survey results with prior surveys because of the overrepresentation of control programs in the survey sample. CONCLUSIONS Tampering among vehicles not covered by I/M and/or anti- tampering programs was 23%, compared to 17% and 16% for those vehicles covered by ATP-only and I/M + ATP, respectively. Such comparisons between program categories should be made carefully, since some of the control programs cover only newer model years of vehicles, which historically have lower tampering rates than the older vehicles not covered by the control programs. Because of the large variation in program types and coverages, the vehicles are classified based on the program restrictions within each site. In Oklahoma City, for example, only the 1979 and newer vehicles are covered by the area's antitampering program; the 1975 -1978 vehicles are thus classified as "non-I/M". The survey results reveal a disparity in how effectively control programs reduce certain kinds of tampering. Antitampering programs with catalyst and inlet restrictor inspections have generally been very effective in reducing tampering with these com- ponents. When antitampering programs include inspections of various underhood components, however, tampering with these components has in general declined only slightly or not at all. Overall, underhood components had higher tampering rates than that found for the catalytic converter, with the air pump being the single most tampered component (11% of equipped vehicles). These trends will be investigated more thoroughly later in this report. ------- Motor Vehicle Tampering Survey -1988 Page 3 Fuel-Related Tampering The prevalence of vehicles with missing or damaged catalytic converters within each program type is depicted in Figure 1. A vehicle can be considered to have a missing or inoperative catalyst if the converter has been removed, the inlet restrictor is tampered, or the plumbtesmo test is positive. (These three criteria are used by many antitampering programs.) A missing or damaged converter can increase HC and CO emissions by an average of 475% and 425%, respectively.1 For vehicles equipped with three-way con- verters, substantial increases in NOx emissions would also be expected. In addition, converter tampering on trucks was found to be greater than on automobiles (7% vs. 4%). Fuel switching, defined as the presence of any of three specific indicators , was found in 10% of the unleaded vehicles not covered by I/M and/or ATPs in the 1988 survey. Fuel switching among vehicles in ATP-only and I/M + ATP areas was 5% and 4%, respectively. The pattern of overlap among the three misfueling indicators is discussed in detail later in this report. While the emissions impact of fuel switching depends upon its duration and certain vehicle characteristics, emission increases of 475% for HC and 425% for CO can easily occur. Catalyst Tampering and Vehicle Aee The probability that a vehicle has been tampered with is clearly related to its age, as has been shown in previous surveys. This is evident in Figure 2(a), which depicts overall tampering as a function of vehicle age for those vehicles not covered by I/M and/or antitampering programs. Figure 2(b) compares the impact of vehicle age on catalyst tampering among vehicles covered and not covered by converter inspection programs. Overall, converter tampering is much lower on vehicles covered by converter inspection programs than on vehicles not covered by such programs (1% vs. 7%), and the effective- ness of inspection programs is particularly noticeable among the oldest vehicles surveyed (vehicles that are most likely to be tampered with). 1 The emissions increases mentioned in this report are from a study of three-way catalyst vehicles presented in Anti-Tampcring and Anti-Mlsfuellng Programs to Reduce In-Ust Emissions from Motor Vehicles. EPA-AA-TTS-83-10, December 31,1983. 2 The three fuel switching indicators are: a tampered fuel filler inlet restrictor, a positive Plumbtesmo tailpipe test, or a gasoline lead concentration of more than O.QS gram per gallon. ------- Motor Vehicle Tampering Survey -1988 Page 4 Component Catalytic Converter 2% ™ 1% Inlet Restrictor Positive Plumbtesmo 0% Tampering (%) non — l/M ATP — only l/M + ATP Figure 1. Tampering rates for selected components by program type. ------- Motor Vehicle Tampering Survey -1988 Page 5 Vehicle Age (years) (a) Catalyst Tampering (%) 30 Vehicles Not Covered Vehicles Covered --O-- 6 7 8 9 10 Vehicle Age (years) (b) Figure 2(a). Overall tampering by vehicle age for vehicles not covered by I/M and/or antitampering programs. 2(b). Comparison of catalyst tampering by vehicle age between vehicles covered and not covered by a catalyst inspection program. ------- Motor Vehicle Tampering Survey -1988 Page 6 BACKGROUND EPA estimates that motor vehicle emissions nationwide account for 58% of the total carbon monoxide (CO), 38% of the airborne lead, 27% of the hydrocarbons (HC), and 34% of the oxides of nitrogen (NOx) emitted into the atmosphere.3 As a result, a major focus of the nation's efforts to achieve compliance with clean air standards has been the control of emissions from mobile sources. The first pollution control devices were installed on vehicles in 1962, and most light- duty vehicles manufactured since 1968 have been equipped with a variety of emission control devices to meet required emissions standards. The 1977 amendments to the Clean Air Act (sections 203(a)(3)(A) and (B), found in Appendix A) make it illegal for automobile dealers, repair and service facilities, and fleet operators to disconnect or render inoperative emission control devices or elements of design. Regulations issued under section 211(c) of the Act (40 CFR Part 80) prohibit retailers and wholesale purchaser-consumers from introducing or allowing the introduc- tion of leaded gasoline into vehicles labeled "unleaded gasoline only". The EPA's Field Operations and Support Division (FOSD), formerly the Mobile Source Enforcement Division (MSED), is responsible for enforcing the tampering and misfueling provisions of the Act. Before 1978, the EPA had data suggesting that tampering with emission control devices and misfueling of "unleaded only" vehicles with leaded gasoline were occurring. Variability in the inspection procedures, however, prevented an accurate assessment of the nature and extent of the tampering. As a result, the Agency began conducting nationwide tampering surveys of light-duty motor vehicles in 1978 to determine the rates and types of tampering and fuel switching. These annual surveys have been conducted either by FOSD directly or by EPA's National Enforcement Investigations Center (NEIC) under the direction of FOSD. Consistent inspection procedures were used throughout these surveys to permit comparisons and identification of trends. The uses for the tampering surveys have evolved since the first survey was con- ducted in 1978. Since 1983, the tampering survey results for some locations have been used to calculate credits for State Implementation Plans (SIPs), the measures taken by State and local governments to achieve ambient air quality standards by reducing mobile source emissions. Data from the surveys is also used in the default database for the Agency's mobile source computer model (MOBILE4) to estimate both the emissions loading impact and the reductions that may be achieved by various control programs. Comparing survey results before and after implementation of a control program is an excellent method for evaluating program effectiveness. Sites for the surveys are chosen in light of the need for data on specific areas either currently operating or considering programs, as well as the continuing need to monitor the types and extent of tampering and fuel switching nationwide. 3 National Air Pollutant Emission Estimates, 1940-1986, EPA-450/4-87-024, January, 1988. ------- Motor Vehicle Tampering Survey -1988 Page 7 SURVEY METHODS The 1988 tampering survey was conducted for FOSD by the National Center for Vehicle Emissions Control and Safety at Colorado State University (CSU). Ap- proximately 400 to 600 vehicles were inspected in each of 15 cities between March and August, 1988, and the entire survey includes 7,259 vehicles. The mix of vehicles inspected was assumed to be a self-weighting sample, and no attempt was made to force the sample into matching the national vehicle mix. Each inspection team consisted of at least four members: three CSU personnel, one or two EPA representatives, and frequently a State or local agency representative. The CSU personnel, assisted by the State or local person, performed the actual inspec- tions, while the EPA representative(s) monitored the survey. Each vehicle inspection included the following: 1. Basic vehicle identification data recorded (year, make, model); 2. All emission control systems checked; 3. Idle HC and CO emissions measured; 4. Fuel sample collected from unleaded-only vehicles for lead analysis; 5. Tailpipe tested for lead deposits using Plumbtesmo® 4 test paper; and 6. Integrity of fuel inlet restrictor checked. Three changes have been made in the survey methodology for 1988. The two separate variables for the oxygen sensor and the rest of the computer system have been consolidated into a single variable representing the entire computer system. Similarly, the two variables for the EGR system (the control valve and sensor) have been combined into a single EGR system variable. Finally, the 1988 survey is the Erst survey in which gasoline samples were taken from both leaded and unleaded vehicles. The results from the leaded vehicles will be discussed separately in this report, and were not used to calculate any fuel switching rates among the unleaded vehicles. The inspections and recording procedures are fully detailed in Appendix B. The survey data base has been reviewed by CSU and EPA to ensure its accuracy, and has been offered to the major automotive manufacturers to review the classification and reporting of their respective vehicles. The tampering survey included only 1975 and newer light-duty cars and trucks fueled with gasoline. For the purposes of the tampering surveys, a vehicle is considered to be "unleaded" if a dash label, tank label, or filler inlet restrictor is observed at the time of the inspection, or if the emission control label indicates an unleaded fuel requirement (Le., catalyst-equipped). A vehicle's designation as "unleaded" or "leaded" may be changed upon subsequent review of the data. Fuel switching rates are thus based only on the population of unleaded vehicles surveyed. Similarly, tampering rates for specific components are based only on the vehicles originally equipped with the component. 4 Plumbtesmo* is a registered trademark, and appears hereafter without the"®". It is manufactured by Macheiy-Nagel, Durcn, W. Germany, and marketed by Gallard-Schlesinger Chemical Corp., Carle Place, New York. ------- Motor Vehicle Tampering Survey -1988 Page 8 The inspections were performed with the consent of the vehicle owners at either roadside pullovers or inspection stations. The survey was designed to minimize the refusal rate of potential survey participants. A high refusal rate increases the uncertainty in the data gathered, since individuals who have tampered with or misfueled their vehicles are less likely to allow their vehicles to be surveyed. The overall refusal rate was very low (3%), however, and only two survey sites had refusal rates over 5%. A brief description of each survey site follows. Unless otherwise noted, the survey locations within a given city were changed daily. SITE DESCRIPTIONS Tbscon, AZ I/M + ATP Dates: March 14 -18,1988 Vehicles Surveyed: 424 Fuel Samples: 355 Refusal Rate: 0% Phoenix, AZ I/M + ATP Dates: March 21 - 25,1988 Vehicles Surveyed: 450 Fuel Samples: 388 Refusal Rate: 0% The Ibcson and Phoenix surveys were conducted at each city's centralized inspec- tion stations. Three different stations were used in Tbcson, while five different stations were used in Phoenix. The antitampering programs in Phoenix and Tucson include a Plumbtesmo test and inspection of the catalytic converter, air injection system, and inlet restrictor on all 1975 and newer vehicles. Stockton, CA Non-I/M Dates: March 28 - April 1,1988 Vehicles Surveyed: 500 Fuel Samples: 388 Refusal Rate: 1% Roadside pullovers were conducted with the assistance of the California Highway Patrol. While Stockton was a non-I/M area at the time of the survey, a decentralized biennial I/M + ATP was instituted on April 1,1988. ------- Motor Vehicle Tampering Survey -1988 Page 9 Baton Rouge, LA ATP-only Dates: April 11-15,1988 Vehicles Surveyed: 523 Fuel Samples: 447 Refusal Rate: 8% Roadside pullovers were conducted with the assistance of the Louisiana State Police. Survey locations were the same as in the 1985 and 1986 surveys. The decentral- ized antitampering program in Baton Rouge includes a Plumbtesmo test and inspection of all emission control devices on 1980 and newer vehicles. Houston, TX ATP-only Dates: April 18 - 22,1988 Vehicles Surveyed: 550 Fuel Samples: 393 Refusal Rate: 2% El Paso, TX I/M + ATP Dates: May 2-6,1988 Vehicles Surveyed: 515 Fuel Samples: 356 Refusal Rate: 1% San Antonio, TX Non-I/M Dates: May 23 - 27,1988 Vehicles Surveyed: 533 Fuel Samples: 421 Refusal Rate: 5% Roadside pullovers in El Paso, Houston, and San Antonio were conducted with the assistance of the Texas Department of Public Safety. The decentralized antitamper- ing program in Houston and El Paso includes Plumbtesmo testing and inspection of the catalytic converter and inlet restrictor on 1980 and newer vehicles, and inspection of the PCV, evaporative, air pump, and EGR systems on 1968 and later vehicles. El Paso also has an I/M program for checking tailpipe CO emissions. ------- Motor Vehicle Tampering Survey -1988 Page 10 Albuquerque, NM Non-I/M Dates: May 9 - 13,1988 Vehicles Surveyed: 500 Fuel Samples: 355 Refusal Rate: 2% The Albuquerque survey was conducted with the assistance of the New Mexico State Police. Albuquerque was a non-I/M area at the time of the survey, but implemented anl/M + ATP in September 1988. Albuquerque also had an I/M program from January, 1983 to March, 1984. Oklahoma City, OK ATP-only Dates: May 16 - 20,1988 Vehicles Surveyed: 505 Fuel Samples: 423 Refusal Rate: 5% The Oklahoma City survey was conducted in Oklahoma City (two days), Edmond, Norman, and Midwest City. The Oklahoma Highway Patrol and the local law enforce- ment offices in these municipalities assisted with the roadside pullovers. Oklahoma City's decentralized antitampering program includes a check of all emission control com- ponents and Plumbtesmo testing on 1979 and newer vehicles. Columbia, SC Non-I/M Dates: June 6 -10,1988 Vehicles Surveyed: 505 Fuel Samples: 368 Refusal Rate: 2% Officers from the Columbia Police Department assisted with the roadside pullovers. ------- Motor Vehicle Tampering Survey -1988 Page 11 New York, NY I/M + ATP Dates: July 11-15,1988 Vehicles Surveyed: 406 Fuel Samples: 332 Refusal Rate: 13% Roadside pullovers were conducted in Manhattan with the assistance of the New York Police Department. New York's decentralized I/M + ATP includes an annual inspection of all emission control components on 1984 and newer vehicles. The high refusal rate for this highly urban site was not unexpected. New Jersey I/M + ATP Dates: July 18 - 22,1988 Vehicles Surveyed: 520 Fuel Samples: 387 Refusal Rate: 1% Roadside pullovers were conducted in Trenton, Bordentown, Freehold, and Eatontown with the assistance of local law enforcement officers in these municipalities. The survey was also conducted one day at the state inspection station in Hightstown. New Jersey's statewide centralized I/M + ATP includes an annual catalyst inspection of 1975 and newer vehicles. Birmingham, AL Non-I/M Dates: July 25 - 28,1988 Vehicles Surveyed: 500 Fuel Samples: 397 Refusal Rate: 3% Roadside pullovers were conducted with the help of the Alabama State Police and the Homewood City Police. Inspection locations included Birmingham (three days) and Homewood. ------- Motor Vehicle Tampering Survey -1988 Page 12 Orlando, FL Non-I/M Dates: August 1-5,1988 Vehicles Surveyed: 500 Fuel Samples: 373 Refusal Rate: 3% Roadside pullovers were conducted in Orlando (four days) and Edgewood with the assistance of the Florida Highway Patrol. Medford, OR I/M + ATP Dates: August 23 - 26,1988 Vehicles Surveyed: 328 Fuel Samples: 218 Refusal Rate: 0% The Medford survey was conducted at the state-run inspection station in Medford for four days. Medford's antitampering program includes biennial inspection of all emission control devices on 1975 and later vehicles. ------- Motor Vehicle Tampering Survey -1988 Page 13 RESULTS A. VEHICLE TAMPERING 1. Site and Aggregate Totals The vehicles surveyed have been classified into four categories established by previous surveys: tampered, arguably tampered, malfunctioning, and okay. Each vehicle was classified by the worst state of any component in the vehicle. For example, a vehicle would be classified as "tampered" if any one component had been tampered, even if all other components were functioning properly. A vehicle classified as "okay" must have all observed components functioning properly.5 The criteria used for component clas- sification are presented in Appendix B. This overall tampering rate is useful only as a rough indicator of the emissions impact of a tampering problem, since the different components making up the rate may have widely varying emissions implications. The proportion of inspected vehicles with at least one tampered component was 19%. One-third of the surveyed vehicles displayed some form of malfunction, arguable tampering, or clear tampering of emission control components. The specific distribution of surveyed vehicles among these categories is depicted in Figure 3. The frequency distribution of tampering instances for those vehicles classified as "tampered" is also shown in Figure 3. Forty-six percent of the tampered vehicles had multiple components tampered, and 13% had four or more instances of tampering. Ibble 1 summarizes the 1988 survey data by site. As in previous surveys, the overall tampering in 1988 varied considerably from site to site. This can be attributed to the variety of program configurations among the cities surveyed and to geographic differen- ces. Ihble 1 also contains the refusal rate at each survey site. The overall refusal rate for the survey was very low (3%), and only two survey sites had refusal rates exceeding 5%. 2. Types offampering The tampering rates for all emission control components and systems surveyed in 1988 are presented in Ihble 2. The component-specific tampering rates for the 1988 survey are presented by survey site in Tkble 3. Only those vehicles originally equipped with a particular component are considered when computing the tampering rate for that component. The site-specific tampering rates listed in Ibbles 1 and 3 are for all vehicles surveyed at each location, including out-of-state vehicles and other vehicles possibly not covered by any local inspection program. The tampering rates for only vehicles covered by local control programs will be examined later in this report. 5 An "okay* vehicle, however, may still be classified as fuel switched (see section B.I., Fuel Switching Indicators and Overlap of this report). ------- Motor Vehicle Tampering Survey -1988 Page 14 Condition of Number of Tampered Surveyed Vehicles Components Figure 3. Breakdown of surveyed vehicles by condition and extent of tampering. (Percentages do not add up to 100& because of rounding error.) ------- Motor Vehicle Tampering Survey -1988 Page 15 Table 1 1988 Tampering Survey Summary Number of Tampering Misfueling Survey Refusal Survey Location Vehicles Rate (%) Rate (%) Type* Rate (%) Tuscon, AZ 424 21 5 C 0 Phoenix, AZ 450 22 5 C 0 Stockton, CA 500 21 11 R 1 Baton Rouge, LA 523 21 7 R 8 Houston, TX 550 17 4 R 2 El Paso, TX 515 20 6 R 1 Albuquerque, NM 500 20 6 R 2 Oklahoma City, OK 505 20 10 R 5 San Antonio, TX 533 26 10 R 5 Columbia, SC 505 20 8 R 2 New York, NY 406 15 2 R 13 New Jersey 520 9 1 R, C 1 Birmingham, AL 500 18 6 R 3 Orlando, FL 500 21 8 R 3 Medford, OR 328 12 5 C 0 OVERALL 7,259 19 6 - 3 *R = roadside pullovers, C = centralized inspection stations Ibble 2 shows that air pump system tampering remains the single most common type (11% of equipped vehicles). Tampering with PCV and evaporative systems also show no evidence of subsiding. Also of interest is the slight but measurable tampering found with the oxygen sensor and computer control system. Because of the difficulty in inspecting the oxygen sensors (no determination could be made on 86 vehicles), tamper- ing with this component could be as high as 3% if all of the uninspected oxygen sensors were tampered with. Oxygen sensor tampering is of considerable interest because of the dramatic emissions increases which result from its disablement -- an average increase of 445% for HC and 1,242% for CO.6 As the vehicle fleet equipped with oxygen sensors and computers ages, tampering with these relatively new devices may increase. 6 Antltamnf ring and Antl.\fkfi»-lin? Programs fa Rerfm-e fn.fke Fmi-reinns from Motor Vehicles. EPA-AA-TTS-83-10, December 31,1983. ------- Motor Vehicle Tampering Survey -1988 Page 16 Table 2 Prevalence of Tampering by Component Component/System Tampering Rate (%) Catalytic Converter 5 Filler Neck Restrictor 6 Air Pump System 11 Air Pump Belt 8 Air Pump/Valve 7 Aspirator* 2 PCV System 6 Evaporative Control System 6 EGR System 7 Heated Air Intake 3 Oxygen Sensor and Computer System 1 * Vehicles with aspirated air systems are not equipped with other listed air- injection components, nor do conventional systems include aspirators. Tbble 3 shows the wide variation in tampering from site to site for any given component. Air pump system tampering for example, ranged from 3% in New Jersey to 18% in Orlando. This range is partly due to the effectiveness of I/M and antitampering programs (as will be discussed later in this report), geographic location, and socioeconomic background. 3. Vehicle Characteristics and Tampering The next section of this report investigates the inter-relationship between tamper- ing and three vehicle characteristics: manufacturer, vehicle type (car or truck), and age. Manufacturer. Figure 4 presents the 1988 tampering rates for each major manufacturer. The smaller foreign manufacturers have been combined into two groups, Other European and Other Asian. Vehicle tampering was higher among vehicles of domestic manufacture than among those of foreign manufacture. Overall, tampering with domestically manufactured vehicles was more then twice that found for the foreign manufactured vehicles (23% vs. 9%). A number of factors might explain the difference in tampering prevalence among manufacturers. Differences in design may make some vehicles more tamper-prone than others. Changing market share history results in different age distributions for vehicles of different makes, and vehicle age is clearly related to tampering prevalence. Tampering rates seem to vary with geographic location and socioeconomic background, so the owner demographics for different makes may affect the likelihood of tampering. ------- Motor Vehicle Tampering Survey -1988 Page 17 Table 3 Component-Specific Tampering Rates (%) by Survey Location 1988 Survey Survey Catalytic Inlet Air Pump PCY EGR Evaporative Any Location Converter Restrictor System System System System Component Tucson, AZ 1 3 6 9 9 5 21 Phoenix, AZ 2 5 13 9 10 8 22 Stockton, CA 3 10 10 5 7 5 21 Baton Rouge, LA 7 6 11 8 8 6 21 Houston, TX 4 4 10 5 8 6 17 El Paso, TX 5 5 11 6 7 10 20 Albuquerque, NM 5 6 14 4 10 7 20 Oklahoma City, OK 7 9 8 5 6 6 20 San Antonio, TX 8 10 13 7 8 7 26 Columbia, SC 6 8 12 6 8 7 20 New York, NY 3 2 8 6 5 5 15 New Jersey 1 1 3 3 3 2 9 Birmingham, AL 7 6 16 5 7 5 18 Orlando, FL 8 9 18 6 7 6 21 Medford, OR 0 3 4 2 7 2 12 OVERALL 5 6 11 6 7 6 19 Vehicle Type. The overall tampering prevalence for light-duty trucks (LDTs) was 21%, compared to 19% for automobiles (LDVs). Since the 1986 tampering survey, the tampering rates for cars and trucks have basically been the same, and the discrepancy between car and truck tampering decreased steadily in surveys prior to 1986. While the overall tampering rate is less meaningful than the rates for individual components, even the component-specific truck rates tend to converge upon the usually lower automobile rates. As was mentioned earlier, the most critical components (e.g., catalytic converters) are still tampered with more frequently on trucks. Many factors may be contributing to the convergence in car and truck tampering. Since most of the vehicles surveyed in 1988 were subject to control programs, the relative car and truck tampering rates may reflect increased emphasis on truck tampering detection by the inspection programs. Also, the proportion of imported trucks within the total truck population surveyed has increased from 15% to 26% between 1982 and 1988, with many of the smaller trucks being utilized as cars. Since imported vehicles are tampered with much less frequently than domestic vehicles, the increase in imported ------- Motor Vehicle Tampering Survey -1988 Page 18 Ford General Motors Volkswagen Chrysler/AMC Other European Other Asian Toyota Mazda ' Nissan Honda 23% 25% Tampering (%) Figure 4. Tampering by Manufacturer: 1988 Survey. ------- Motor Vehicle Tampering Survey -1988 Page 19 trucks within the truck population surveyed may be contributing to the lower truck tampering prevalence. Vehicle. Age.. Tbble 4 relates vehicle age and model year with tampering prevalence for the 1978-1988 surveys. Catalytic converter removal rates are similarly related to vehicle age and model year in Ihble 5. The results from any given survey are entered diagonally in each table. The results in Tables 4 and 5 indicate that vehicle tampering increases directly with vehicle age. Examining Tbble 4 diagonally (by survey) shows that tampering increases consistently with vehicle age in each survey conducted. In the 1988 survey, for example, the tampering rate increases from 1% for first year (1988) vehicles to 62% among the 1975 model year vehicles surveyed. Ihble 5 shows a similar, though less pronounced, increase in catalyst removal. The catalyst tampering rate remains negligible for the first five years of a vehicle's life, and then increases thereafter. This delay in catalyst tampering is understandable, since the emission control components on all new vehicles are warranted for 5 years/50,000 miles by the manufacturer, providing an incentive to maintain the catalysts on vehicles still under warranty. A similar delay in overall tampering is abbreviated in Thble 4, but becomes more evident when only non-I/M vehicles are examined (Figure 2 (a)). Examin- ing these tables in this manner has the advantage of comparing data collected during one survey in one set of locations, but ignores the possible effects of model year differences (i.e., technology), geography, or program coverage on tampering. 1\vo additional ways of analyzing Tables 4 and 5 address the impact of model year on tampering rates. Analyzing these Tables horizontally (holding the model year con- stant) provides a look at the tampering rates over time for the vehicles of a particular model year. This approach shows the same distinct increase in tampering with vehicle age for all model years since 1975. (The 1974 and 1973 data sets are too small to permit any conclusions.) Interestingly, overall tampering with post-1980 model year vehicles appears to be less than that for pre-1981 model year vehicles when both groups of vehicles were new (less than five years old), but the tampering rates for these groups converge with increasing vehicle age. In Tbble 4, for example, overall tampering with 1981 and 1979 model year vehicles during their first year of use was 2% and 6%, respectively. By their eighth year of use, however, the tampering rates for the 1981 and 1979 model year vehicles were nearly the same — 34% and 36%, respectively. Tables 4 and 5 can also be examined vertically (holding vehicle age constant), which provides a look at the tampering rates for different model year vehicles of the same age. This approach permits a crude examination of trends in tampering adjusted for vehicle age. Examining Ihble 4 vertically, for example, shows a decrease in overall tampering from the 1978 survey to the 1988 survey for vehicles in each of their first five years of use. This decrease in overall tampering appears to lessen in the later years of a vehicle's life. A similar vertical analysis of Ibble 5 does not show any clear pattern or trend in age-specific catalyst tampering. ------- Motor Vehicle Tampering Survey -1988 Page 20 Thble4 Tampering Percentage (and Sample Size) by Model Year and Vehicle Age at Time of Survey Year of Vehicle Life Model Year 1st M 3ri 4th 5th 6th 7lh 8th 9th 10th 11th 12th 13th 14th 1988 1(524) 1987 1(627) 1(832) 1986 1(757) 2(1058) 3(915) 1985 2(816) 3(1130) 3(972) 6(855) 1984 1(462) 2(1001) 5(1018) 7(908) 8(765) 1983 7(182) 4(471) 6(710) 7(706) 10(633) 15(532) 1982 1(250) 4(226) 7(466) 9(621) 11(574) 19(525) 21(506) 1981 2(57) 7(448) 13(206) 15(458) 11(607) 19(560) 26(501) 34(479) 1980 5(63) 9(454) 15(211) 18(516) 25(564) 25(556) 28(472) 32(419) 1979 6(371) 9(59) 18(477) 31(288) 28(503) 37(673) 36(699) 42(555) 44(464) 1978 7(298) 14(502) 15(79) 21(430) 39(238) 34(559) 37(562) 50(548) 49(443) 55(404) 1977 10(457) 15(476) 21(66) 26(316) 44(190) 41(408) 48(452) 48(465) 49(356) 54(265) 1976 18(395) 19(374) 29(52) 26(317) 40(171) 39(385) 49(369) 53(318) 60(219) 61(179) 1975 22(274) 22(271) 32(22) 37(183) 55(89) 46(197) 54(194) 60(198) 65(103) 62(113) 1974 33(276) 27(242) 1973 32(253) 36(251) Table 5 Percentage of Catalyst RemovaI(and Sample Size) among Catalyst-equipped Vehicles by Model Year and Vehicle Age at Time of Survey Year of Vehicle Life Model Year 1st 2nd 3rd 4th 5th 6th 7th 8th 9th 10th 11th 12th 13th 14th 1988 0(521) 1987 0(627) 0(810) 1986 0(757) 0(1058) 0(887) 1985 0(808) 1(1128) 0(972) 1(818) 1984 0(462) 0(978) 1(1018) 1(908) 1(726) 1983 1(179) 2(471) 0(686) 1(706) 1(633) 2(505) 1982 0(250) 1(225) 2(465) 2(597) 1(574) 3(525) 3(466) 1981 0(57) 2(441) 5(204) 6(457) 3(567) 5(552) 7(499) 9(421) 1980 2(61) 2(428) 3(200) 6(487) 6(522) 7(528) 8(440) 9(346) 1979 0(326) 4(55) 6(429) 12(252) 10(455) 12(572) 12(638) 13(505) 13(376) 1978 0(291) 0(445) 0(71) 4(362) 8(213) 8(486) 10(472) 10(466) 15(394) 13(312) 1977 1(417) 1(417) 2(59) 2(271) 11(166) 14(357) 17(379) 19(409) 11(320) 19(212) 1976 2(377) 2(305) 10(48) 6(257) 12(139) 12(314) 15(291) 20(276) 19(184) 15(137) 1975 2(242) 2(204) 26(19) 12(139) 23(75) 16(174) 21(130) 23(167) 25(77) 14(72) ------- Motor Vehicle Tampering Survey -1988 Page 21 The comparisons made in the two preceding paragraphs involve observations made in different survey locations during different years, and are affected by the site selection in each survey. An increasing percentage of the 1981 and newer vehicles in recent surveys have been covered by antitampering programs, which could contribute to the lower tampering found among newer vehicles. The impact of improved technology on tampering can be more accurately assessed by examining only vehicles from non-I/M areas (Figure2(a». The data in Figure 2(a) suggest that tampering with new technology vehicles that are no longer covered by new car or emissions warranties (i.e., post-1981 vehicles that are six to eight years old) is consistent with tampering among older technology vehicles (pre-1981 — over eight years old). 4. Impact of I/M and Antitampering Programs Inspection and maintenance (I/M) programs require vehicles to meet specific idle emission standards. Vehicles registered in areas with these programs are required to be periodically tested to assure that they comply with the specific idle emission cutpoints established by these jurisdictions. In addition to reducing emission levels by stimulating better owner maintenance, I/M programs may deter some tampering with emission control components. Data from previous surveys has tended to support this proposition, since tampering in I/M areas has historically been lower than in non-I/M areas. Many local areas have also instituted antitampering programs (ATPs), which involve periodic vehicle inspections to check the integrity of specific emission control components. Antitampering programs vary greatly in the components inspected and the vehicle model years covered, so that a vehicle or component which would be inspected in one program area might not be inspected in a different program area. Successful antitampering programs should reduce existing tampering and deter future tampering with the components and model years covered by the program. Classifying the survey areas into program types is made difficult by the consider- able variation in control programs. For example, New York City's antitampering program includes inspection of all emission control devices, but only on 1984 and newer vehicles (1983 and older vehicles are covered by an I/M-only program). New Jersey's antitamper- ing program covers 1975 and newer vehicles, but only includes inspection of the catalyst. In order to minimize the impact of these variations in program types and model year coverages, the vehicles in the 1988 survey can be classified by the model year restrictions applicable in the program areas surveyed. These classifications, and the resulting tampering and fuel switching rates for each program type, are shown in Figure 5. Since New York's antitampering program only covers 1984 and newer vehicles, for example, only those model year vehicles are classified as "I/M + ATP"; the 1975-1983 vehicles surveyed in New York are classified as "I/M-only". This method of classification does not take into consideration the components inspected by each program, a , program's effectiveness, or the frequency of inspection. Any comparisons between program types (e.g., I/M + ATP vs. non-I/M) should thus be made carefully. ------- Motor Vehicle Tampering Survey -1988 Page 22 Nori—l/M Albuquerque, NM Birmingham, AL Columbia, SC Orlando, FL San Antonio, TX Stockton, CA Baton Rouge, LA (1975-1979) Oklahoma City, OK (1975—1978) ATP —only Baton Rouge, LA (1980+) Houston, TX Oklahoma City, OK (1979+) l/M + ATP El Paso, TX Medford, OR New Jersey New York, NY (1984 + ) Phoenix, AZ Tucson, AZ l/M —only New York, NY 1975-1983) Note: Program covers all model years surveyed unless otherwise indicated. Program Type - ¦ 1 — I 30% 20% 10% 0% 0% 5% 10% 15% Tampering (%) Fuel Switching (%) *the l/M—only rates have been excluded because they are not representative of l/M—only areas nationwide Figure 5 Classification of 1988 survey sites by program type (and model year coverage), with the resulting tampering and fuel switching rates for each program type. I ------- Motor Vehicle Tampering Survey -1988 Page 23 Table 6 Comparison of 1988 Survey Sample to Actual Nationwide Vehicle Fleet Program Type non-I/M I/M-only I/M + ATP ATP-only Percentage within Survey Sample (%) Approximate Percentage of Nationwide Fleet (%)* 43 2 34 21 58 12 20 10 •From County Population Estimates: July 1.1987 and 1986. U.S. Department of Commerce - Bureau of the Census, September, 1988. Another factor affecting comparisons in Figure 5 is the overrepresentation in the survey sample of areas with some kind of control program. This is a deliberate feature of the survey's design, as was discussed earlier, and focuses attention on evaluating the effectiveness of specific individual programs, liable 6 compares the proportion of the 1988 survey sample and the national vehicle fleet under control programs. Because of the need to evaluate control program effectiveness, the survey overrepresents the portion of the national vehicle fleet under control programs. Vehicles covered by an I/M + ATP or an ATP-only comprised 55% of the survey sample, while only approximately 30% of the national vehicle fleet were under such programs. Of even greater significance regarding survey representation, the surveyed vehicles covered by an I/M-only program consist only of the 1983 and older vehicles in New York City, comprising only 2% of the survey sample. The I/M-only rates have thus been excluded from Figure 5 since they are not representative of I/M-only areas nationwide. The impact of I/M and antitampering programs in specific locations can be examined by comparing the 1988 survey data with that from earlier surveys. Com- parisons made between surveys widely spaced in time, however, must take into con- sideration the differences in average vehicle age in each survey. The average odometer reading per vehicle surveyed in 1988, for example, is over 20% greater than it was in 1983. Since vehicle mileage correlates with vehicle age, which is directly related to tampering prevalence, a significant increase in tampering might be expected to have occurred between 1983 and 1988, even if all other factors remained constant (car/truck distribu- tion, owner demographics, etc.). Inferences regarding program effects should thus be made with this in mind. Ibbles 7 and 8 present tampering data for the three ATP-only and six I/M + ATP sites surveyed, respectively. Because of the large number of programs represented in Ibbles 7 and 8, only a few representative comparisons will be discussed in this report. Detailed analysis of each program's effectiveness is beyond the scope of this report. The comparisons made in these Tables have been limited to the specific components and vehicle model years covered by each antitampering program actually in operation during the 1988 survey. In some instances this reduces the sample size substantially. The tampering data listed in Ibbles 7 and 8 were compiled only for surveyed vehicles included S. Tampering TVends for Selected Sites ------- Motor Vehicle Tampering Survey -1988 Page 24 Table 7 Tampering Prevalence among Vehicles and Components Covered by Antitampering Programs in ATP-only Areas Surveyed between 1983 - 1988 Tampering Prevalence (%) by Survey Year Survey Location Component and (Program Start Date) Model Year Covered 1983 1984 1985 1986 1987 .1988 Baton Rouge, LA Catalyst 80 + . 4 3 1 (1/86) Inlet Restrictor 80 + - 3 1 - 2 Pos. Plumbtesmo 80 + - 5 2 - 0 PCV System 80 + - 2 3 - 6 Evap. System 80 + - 3 3 - 3 Air Pump System 80 + - 6 4 - 7 EGR System 80 + 4 4 5 Houston, TX Catalyst 80 + 6 1 3 1 1 (7/84) Inlet Restrictor 80 + 1 0 2 1 0 Pos. Plumbtesmo 80 + 8 2 2 1 1 PCV System 75 + 9 4 7 7 6 Evap. System 75 + 8 4 7 8 5 Air Pump System 75 + 9 6 8 6 10 EGR System 75 + 19 9 9 8 7 Oklahoma City, OK Catalyst 79 + 3 (1/87) Inlet Restrictor 79 + - - - - 4 Pos. Plumbtesmo 79 + - - - - 2 PCV System 79 + - - - - 3 Evap. System 79 + - - - - 4 Air Pump System 79 + - - - - 6 EGR System 79 + 4 ------- Motor Vehicle Tampering Survey -1988 Page 25 Table 8 Tampering Prevalence among Vehicles and Components Covered by Antitampering Programs in I/M + ATP Areas Surveyed between 1983 - 1988 Tampering Prevalence (%) by Survey Year Survey Location Component and (Program Start Date) Model Year Covered 1983 1984 1985 1986 1987 1988 El Paso, TX Catalyst 80 + - 3 - - 2 2 (1/86) Inlet Restrictor 80 + - 3 - - 1 2 Pos. Plumbtesmo 80 + - 6 - - 1 1 PCV System 75 + - 7 - - 8 5 - Evap. System 75 + - 5 - - 7 10 Air Pump System 75 + - 17 - - 9 12 EGR System 75 + - 11 - - 9 5 New Jersey, varied locations Catalyst 75 + - 5 - 5 4 1 (I/M-2/74, ATP-12/85) Medford, OR Catalyst 75 + - - - - - 0 (1/86) Inlet Restrictor 75 + - - - - - 2 PCV System 75 + - - - - - 2 Evap. System 75 + - - - - - 1 Air Pump System 75 + - - - - - 4 EGR System 75 + - - - - - 6 New York, NY Catalyst 84+ - 0* 0 - - 0 (I/M-l/81, ATP-1/86) Inlet Restrictor 84 + - 0 0 - - 0 PCV System 84+ - 0 1 - - 4 Evap. System 84+ - 0 2 - - 1 Air Pump System 84 + - 0 0 - - 0 EGR System 84 + - 0 0 - - 1 Phoenix, AZ Catalyst 75 + 7 - - - - 2 (I/M-l/77, ATP-1/87) Inlet Restrictor 75 + 13 - - - - 5 Pos. Plumbtesmo 75 + 12 - - - - 1 Air Pump System 75 + 13 - - - - 12 Tucson, AZ Catalyst 75 + - - - 3 - 1 (I/M-l/77, ATP-1/87) Inlet Restrictor 75 + - - - 6 - 2 Pos. Plumbtesmo 75 + - - - 6 - 1 Air Pump System 75 + - - - 10 - 6 *Thc rates listed for the New York survey in 1984 should not be considered representative because of the small number of 1984 model year vehicles surveyed that year. ------- Motor Vehicle Tampering Survey -1988 Page 26 within the local program jurisdiction. The Houston tampering rates listed, for example, are for Harris County vehicles only. Any non-Harris County vehicles surveyed were excluded from this analysis. The data in Tbble 7 suggest that the ATPs in Houston and Baton Rouge have helped lower catalyst tampering and misfueling rates (Le., plumbtesmo, inlet restrictor). Tampering with underhood components, however, has not declined appreciably. A similar pattern is apparent in liable 8, where I/M + ATP programs have been generally effective in reducing catalyst tampering and misfueling, but much less so in reducing under- hood tampering. This disparity in program effectiveness can be clearly seen in Figures 6(a)-(f), where tampering rates by model year for the major components covered by inspection programs (either ATP-only or I/M + ATP) are compared to tampering rates for the same components on vehicles that were not covered by inspection programs. Catalyst and inlet restrictor tampering (Figs. 6(a) and (b), respectively) are much lower on vehicles covered by converter and inlet inspection programs than on vehicles not covered by such inspections. Air pump system tampering (Fig. 6(c)) is moderately lower in areas with air pump inspections than in areas without such inspections, but air pump tampering on older vehicles is still over 20% in areas that inspect air pumps. Areas with inspection programs for other underhood components (e.g., PCV, EGR, and evaporative systems) do not have appreciably lower tampering rates for these components (Figs. 6(d)-(f)). The PCV and evaporative system rates are noteworthy because these two systems control crankcase and evaporative HC emissions, respectively — emissions which the catalytic converter does not control. The overall tampering rates for the data presented in Figs. 6(a)-(f) are shown in Figure 7. This weakness in inspecting underhood components may be partly due to the nature of decentralized inspection programs. Of the eight survey sites listed in Table 7 and 8 that inspect underhood components, only three (Medford, Phoenix, and TUcson) are centralized programs, which have historically been more effective than decentralized programs in reducing tampering. Detecting underhood tampering is more complex and requires more training than converter and inlet restrictor inspection. The level of inspector training needed to implement an effective anti-tampering program is more easily attained when vehicle inspections are conducted at a few centralized stations than at many decentralized locations. ------- Motor Vehicle Tampering Survey -1988 Page 27 Tampering (%) 30 25 20 15 10 Covered by a Program Not Covered by a Program 88 87 86 85 84 83 82 81 80 79 78 77 76 75 Model Year (a) Catalytic Converter Tampering (%) 40 30 20 10 Covered by a Program Not Covered by a Program 88 87 86 85 84 83 82 81 80 79 78 77 76 75 Model Year (b) Inlet Restrictor Figure 6 Comparisons of component-specific tampering rates by model year (a—f) among vehicles both covered and not covered by ATPs. ------- Motor Vehicle Tampering Survey -1988 Page 28 Tampering (%) 70 60 50 40 30 20 10 J I I I Covered by a Program Not Covered by a Program 88 87 86 85 84 83 82 81 80 79 78 77 76 75 Model Year (c) Air Pump System Tampering (%) 35 I l I .. I I I Covered by a Program Not Covered by a Program 88 87 86 85 84 83 82 81 80 79 78 77 76 75 Model Year (d) Evaporative System ------- Motor Vehicle Tampering Survey -1988 Page 29 Tampering (%) 30 25 20 15 10 i i i i Covered by a Program Not Covered by a Program 88 87 86 85 84 83 82 81 80 79 78 77 76 75 Model Year (e) PCV System Tampering (%) 35 30 25 20 15 10 ----r l l L Covered by a Program Not Covered by a Program 88 87 86 85 84 83 82 81 80 79 78 77 76 75 Model Year (f) EGR Systems ------- Motor Vehicle Tampering Survey -1988 Page 30 Component/ System Catalytic Converter Inlet Restrictor Air Pump System Evaporative System PCV System EGR System 8% Tampering (%) Component not cvrd. by ATP inspection Component covered by ATP inspection 13% Figure 7. Comparison of component-specific tampering rates among vehicles both covered and not covered by ATPs. ------- Motor Vehicle Tampering Survey -1988 Page 31 d. Correlation between Tampering and Idle Emissions As was mentioned previously, vehicles which are subject to an I/M program must meet specific idle emissions cutpoints. To assess the relationship between tampering and fuel switching and idle failure rates, the idle emissions from unleaded vehicles have been tested against the cutpoints established by the I/M program where they were sampled. Vehicles in non- I/M and ATP-only areas were tested against the cutpoints specified by the New Jersey I/M program. The cutpoints for each I/M area are listed in Appendix C. The results of the idle tests are presented in Figure 8 for vehicles in the various tampering and fuel switching categories. The failure rates for fuel switched vehicles that were arguably tampered with or otherwise okay are based upon very small samples and may be unreliable. The results in Figure 8 indicate that a substantially larger proportion of tampered and fuel switched vehicles than of okay vehicles fail an idle test at typical I/M cutpoints. For example, only 16% of the unleaded vehicles surveyed that were free of tampering and fuel switching failed an idle test, while 64% of the tampered and fuel switched vehicles failed that test. It should be noted from Figure 8, however, that 36% of the tampered and fuel switched vehicles were still able to pass an idle test. Ihble 9 shows the percentage of vehicles that failed the idle emissions test for each vehicle condition. The failure rates are listed for the entire survey, as well as in two model year groupings representing "old" technology (1975 - 1980) and "new" technology (1981 + ) vehicles. "New" technology includes closed loop emissions control, which came into widespread usage in 1981 model year vehicles. The overall percentage of tampered vehicles exceeding I/M cutpoints for HC emissions was over three times greater than for okay vehicles (42% vs. 12%). Over four times as many tampered vehicles exceeded CO cutpoints as did okay vehicles (45% vs. 10%). The majority (65%) of the vehicles that either had been fuel switched or had their catalysts removed also exceeded HC or CO limits. Conversely, 35% of the vehicles with missing catalysts or classified as fuel switched were still able to pass an idle emissions test. A significant number of arguably tampered vehicles also produced excess idle emissions. The effectiveness of idle emissions testing on "new" technology vehicles can also . be seen in Tkble 9. The data in Tbble 9 actually underestimate the impact of "new" technology because "old" technology trucks manufactured after 1980 have been included in the "new" technology category due to the model year split. As was found in previous surveys, idle emissions testing is more effective in identifying tampering on 1980 and older vehicles than on 1981 and newer vehicles. For example, 52% of the tampered "old" technology vehicles exceeded CO cutpoints compared to 34% of the tampered "new" technology vehicles. This suggests that idle emissions testing may not be an effective strategy for identifying tampering and fuel switching among "new" technology vehicles, since many vehicles with closed loop systems are able to produce low idle emissions even with tampered emission control devices. ------- Figure 8 Distribution of unleaded vehicles surveyed among tampering*, misfueiing, and idle test categories. ~Excludes malfunctioning vehicles (2% of total). ------- Motor Vehicle Tampering Survey -1988 Page 33 Table 9 Idle Test Failure Rates (Percent) by Pollutant and Vehicle Condition Vehicle Condition Okay Arguably Tampered Tampered Catalyst Removed or Misfueled The mean idle emissions for tampered and okay vehicles are presented in Table 10 by program type. The classification of survey sites is the same as was described in Figure 5, with two alterations. The data from El Paso is listed in a separate category (I/M (CO only)) because El Paso's program has no HC cutpoints. The remaining I/M and I/M + ATP sites have been combined into the "I/M" category. The mean idle emissions from tampered vehicles were considerably greater than from untampered vehicles (Table 10). Overall, HC and CO emissions from tampered vehicles were over five times greater on average than from okay vehicles. Untampered vehicles in El Paso (which doesn't have HC cutpoints) had higher average HC and CO emissions than vehicles in the other areas surveyed, suggesting that El Paso's program with CO-only cutpoints may be having little impact on reducing HC or CO emissions. Table 10 Mean Idle Emissions for Tampered and Okay Vehicles Within Each Program Type HC emissions (ppm) CO emissions (%) Progran Type Tampered Okay Tampered Okay non-I/M 360 63 3.0 0.5 I/M* 275 71 1.9 0.4 I/M (CO- 427 96 3.3 0.6 only)** ATP-only 375 45 23 0.4 OVERALL 346 64 2.7 0.5 * Includes any program where idle emissions are checked, including I/M+ATP areas. * * Consists of vehicles surveyed in El Paso, where only CO emissions are checked. Failure Rate (%) by Pollutant for the Model Years listed 1975-80 1981 + Entire Survey (1975 + ) HC CO HC CO HC CO HC or CO 34 32 9 8 12 10 16 40 39 15 17 27 26 35 49 52 31 34 42 45 59 48 50 43 48 46 50 65 ------- Motor Vehicle Tampering Survey -1988 Page 34 B. FUEL SWITCHING 1. Fuel Switching Indicators and Overlap Fuel switching is more easily defined than measured, since no single indicator can completely characterize its prevalence. Since 1981 the surveys have used a combination of three indicators to measure fuel switching more accurately: a tampered fuel filler inlet restrictor, a positive Plumbtesmo test for lead deposits in the tailpipe, and a gasoline lead concentration of more than 0.05 gram per gallon (gpg). Of these three indicators, only a tampered inlet restrictor is also considered tampering, and as such is used to calculate both tampering and fuel switching rates. Since false positive indications should be extremely rare for these measures, the percentage of vehicles with at least one positive indicator is a reasonable minimum estimate of fuel switching. Measuring fuel switching is somewhat unusual because two of the three indicators (positive plumbtesmo and leaded fuel in the tank) disappear with a series of subsequent proper fuelings. Positive Plumbtesmo results disappear slowly, while leaded gasoline is quickly diluted with subsequent tanks of unleaded fuel. A vehicle which has one or both of these transient indicators, however, has recently used or is currently using leaded gasoline. The presence of a tampered inlet restrictor provides no information about the immediacy of the fuel switching. A fuel switching rate derived from the two transient indicators would thus measure how many vehicles have recently used leaded gasoline, while all three indicators together provide a more accurate indication of long-term fuel switching behavior with its associated catalyst destruction and elevated emissions. The presence of any of these three indicators suggests that a given vehicle has been misfueled; their absence, however, does not rule it out. For example, fuel samples could only be obtained from 75% of the unleaded vehicles surveyed, limiting the scope of this variable. A vehicle with an untampered fuel filler inlet restrictor may also have been fueled at a leaded pump equipped with a smaller nozzle, or by using a funnel or similar device. The tailpipe lead test may also fail to identify misfueling, particularly if older vehicles have had their tailpipes replaced since last operated on leaded fuel. As the lead phasedown program has lowered lead levels in leaded gasoline, the incidence of false negative Plumbtesmo results may be increasing. The uncertainty in these measures, then, is always toward underestimating the number of vehicles misfueled. The limitations of the fuel switching indicators can be seen in their incomplete overlap. The Venn diagram (Figure 9(a)) illustrates the degree of overlap in the misfueling indicators for all unleaded vehicles surveyed in 1988 where data for all three indicators were recorded. Figure 9(b) shows the percentage of the misfueled vehicles with each combination of the three misfueling indicators. For example, only 18% of the misfueled vehicles exhibited all three indicators. While 68% of the vehicles having leaded fuel in their tank also registered a positive Plumbtesmo test, only 28% of the vehicles with tampered inlet restrictors actually had leaded gasoline in their tanks at the time of the survey. The incomplete overlap reflects the limitations of each indicator as well as the different aspects of fuel switching each indicator identifies. The relationship between positive Plumbtesmo results and leaded fuel in the tank can be examined by using the data from the leaded vehicles surveyed. The overlap of these two indicators among leaded vehicles was considerable, with 80% of the leaded vehicles that were using leaded gasoline also having a positive Plumbtesmo test. The greater overlap for leaded vehicles would be expected, since they should have a longer ------- Motor Vehicle Tampering Survey -1988 Page 35 Positive Plumbtesmo (139 Tota Leaded Fuel in Tank f 107 Total) Tampered Inlet Restrictor (334 Total) (a) Tampered Inlet Only (54%) Plumbtesmo + Gas (1%) Plumbtesmo + Inlet (11%) Leaded Gas Only (3%) Plumbtesmo Only (6%) All Three Indicators (18%) (b) Gas + Inlet (6%) Figure 9(a). Overlap of fuel switching indicators among raisfueled vehicles for which all three indicators were inspected. 9(b). Breakdown of misfueled vehicles in 9(a) by prevalence of each indicator combination. ------- Motor Vehicle Tampering Survey -1988 Page 36 history of consistent leaded gasoline use. These results do suggest that Plumbtesmo is still an effective indicator of prolonged use of leaded gasoline, even after the 90% reduction in gasoline lead levels mandated by lead phasedown. Figure 9(b) also shows that 90% of the fuel switched vehicles had a tampered inlet restrictor, making it by far the most frequently observed indicator of fuel switching. A positive Plumbtesmo result was observed on 36% of the fuel switched vehicles, while leaded fuel was found in the tanks of 28% of the fuel switched vehicles sampled. An antitampering program consisting of an inlet restrictor inspection and a Plumbtesmo test would have detected fuel switching in 97% of the vehicles identified as fuel switched by the 1988 survey. 2. Fuel Switching TV-ends Table 11 Fuel Switching Rates among Unleaded Vehicles by Site and Indicator 1988 Survey Survey Location Leaded Tampered Positive Overall Fuel Fuel in Inlet Plumbtesmo Switching Tank (%) Restrictor (%) (%) (%) "IUcson, AZ 1 3 2 5 Phoenix, AZ 0 5 1 5 Stockton, CA 1 10 1 11 Baton Rouge, LA 3 6 3 7 Houston, TX 1 4 2 4 El Paso, TX 2 5 2 6 Albuquerque, NM 3 6 4 6 Oklahoma City, OK 5 9 4 10 San Antonio, TX 4 10 4 10 Columbia, SC 4 8 4 8 New York, NY 0 2 1 2 New Jersey 0 1 1 1 Birmingham, AL 2 6 2 6 Orlando, FL 2 9 3 8 Medford, OR 1 3 2 5 ALL SITES 2 6 2 6 Of the vehicles requiring unleaded fuel, 6% were identified as misfueled by at least one of the indicators discussed above. The fuel switching incidence by survey site is listed in Table 11. The data in Ibble 11 again show that inlet restrictor tampering is easily the most prevalent indicator of misfueling. This is not surprising, since inlet tampering is the most persistent indicator of past misfueling, even when the vehicle has been properly fueled for some time. ------- Motor Vehicle Tampering Survey -1988 Page 37 Table 12 Combined Tampering and Fuel Switching 1988 Survey Survey Location Catalyst-equipped vehicles with catalysts removed or that were fuel switched (%) Unleaded Vehicles either tampered or fuel switched (%) TUcson, AZ 6 22 Phoenix, AZ 6 22 Stockton, CA 12 22 Baton Rouge, LA 8 21 Houston, TX 4 17 El Paso, TX 8 21 Albuquerque, NM 6 20 Oklahoma City, OK 11 20 San Antonio, TX 12 26 Columbia, SC 9 20 New York, NY 4 15 New Jersey 2 8 Birmingham, AT, 7 18 Orlando, FL 10 21 Medford, OR 3 12 ALL SITES 8 19 Thble 12 presents the combined tampering and fuel switching rates for the 1988 survey. The percentage of unleaded vehicles that were tampered or fuel switched was 19%, and the percentage of unleaded vehicles with missing or damaged converters was 8%. Ihble 12 thus suggests that over 40% of all tampering and fuel switching is composed of vehicles in the catalyst removed or fuel switched category. Since these conditions have the largest emissions impact, this indicates the very serious nature of much tampering. ------- Motor Vehicle Tampering Survey -1988 Page 38 Table 13 Prevalence of Fuel Switching Indicators by Program Type Percentage by Program Type Fuel Switching Indicator non-I/M ATP-only I/M + ATP Tampered Inlet Restrictor 9 2 2 Positive Plumbtesmo 4 1 1 Leaded Fuel in Tank 3 1 0 Overall Fuel Switching 10 3 3 Ibble 13 presents the prevalence of each fuel switching indicator by program type. The classification of survey sites is the same as was described in Figure 5, with two alterations. For this analysis the 1975 -1979 model year vehicles surveyed in Houston were reclassified from "ATP-only" to "non-I/M" because Houston's program does not inspect the fuel switching indicators for these model years. The same model years of vehicles surveyed in El Paso are also not inspected with regard to these fuel switching indicators but are still covered by the I/M test; thus the 1975 -1979 El Paso vehicles were reclassified from "I/M + ATP" to "I/M-only." Tbble 13 shows that the prevalence of each fuel switching indicator was considerably greater in the non-I/M areas than in the ATP-only or I/M + ATP areas. (The I/M-only rates are not included in Thble 13 because of their lack of validity, as was discussed earlier.) 3. Fuel Switching hv Vehicle TVpe Table 14 Prevalence of Fuel Switching Indicators by Vehicle Type Percent Fuel Switching by Vehicle Type Fuel Switching Indicator LDV LDT Tampered Inlet Restrictor 5 7 Positive Plumbtesmo 2 4 Leaded Fuel in Tank 2 3 Overall Fuel Switching 6 8 The prevalence of each fuel switching indicator by vehicle type is presented in Thble 14. Overall fuel switching among trucks was slightly higher than for passenger cars (8% vs. 6%) and the prevalence of each indicator was higher in trucks as well. ------- Motor Vehicle Tampering Survey -1988 Page 39 4. Fuel Switching and Catalyst Tampering Consumers and mechanics remove catalytic converters for a number of reasons, but some of their motivation may be related to fuel switching. The vehicle owner may remove the catalytic converter either prior to misfueling, or after some misfueling if the vehicle's driveability has been adversely affected by a catalyst damaged from the repeated misfueling. The data from this survey cannot be used to distinguish between these two situations, but can be used to examine the extent to which these types of abuse ~ occur in conjunction. Figure 10 depicts the degree of overlap between catalyst removal and fuel switch- ing. Vehicles with catalyst tampering exclusive of fuel switching were relatively uncom- mon — only 40% of the catalyst tampered vehicles were not fuel switched. Fuel switching, however, is not always accompanied by catalyst removal, since the majority (57%) of the fuel switched vehicles still had their catalysts. Figures 11(a) and (b) examine the relationship between converter tampering and two of the three misfueling indicators (positive Plumbtesmo and tampered inlet restric- tor). Only vehicles that have been subject to an ATP with Plumbtesmo testing and in which all three of these parameters were inspected are included in these figures. These three parameters have been incorporated into a number of antitampering programs to determine if a converter is missing or damaged. A vehicle failing the Plumbtesmo test or inlet restrictor inspection in some of these programs (e.g., Texas) is required to have its converter replaced. Figure 10 Overlap of catalyst tampering and fuel switching among catalyst-equipped vehicles - 1988 survey. ------- Motor Vehicle Tampering Survey -1988 Page 40 Positive Plumbtesmo (129 Total) Missing Catalytic Converter (269 Total) Tampered Inlet Restrictor (317 Total) (a) Tampered Inlet Only (27%) Plumbtesmo + Cat. (<1%) Cat. + Inlet (20%) Catalyst Only (23%) Plumbtesmo Only (4%) All Three Indicators (18%) ^ Inlet + Plumbtesmo (7%) Figure 11(a) Overlap of indicators used by ATPs to detect missing/damaged catalysts. Only includes vehicles for which all three indicators were inspected and are not covered by an ATP with plumbtesmo testing. Figure 11(b) Breakdown of vehicles in 11(a) by prevalence of each indicator combination. ------- Motor Vehicle Tampering Survey -1988 Page 41 Figure 11(a) shows the value of these programmatic criteria in detecting missing or lead-poisoned converters. A simple inspection of the converter, for example, would catch 62% of the vehicles with missing or lead-poisoned converters. Inspecting both the converter and inlet restrictor, however, would detect 96% of these vehicles. The usefulness of Plumbtesmo in detecting damaged converters appears to be limited, since only 4% of the vehicles in Figure 11(b) failed for Plumbtesmo only. In 1984, prior to the sharp declines in gasoline lead levels, 17% of the vehicles failing one of these program- v matic criteria failed for Plumbtesmo only. Plumbtesmo may still be effective, however, in deterring fuel switching. 5. Gasoline Lead Concentrations Of the vehicles identified as misfueled by any of the three misfueling indicators, 72% had only trace amounts of lead (less than 0.05 gpg) in their gasoline when inspected. These vehicles, then, were identified as fuel switched by a tampered inlet restrictor and/or a positive Plumbtesmo test. Figure 12 presents the distribution of lead concentra- tions of 0.05 gpg or more in misfueled vehicles for the 1984 -1988 surveys. The impact of lead phasedown can be dramatically seen in Figure 12. Not only has the overall prevalence of leaded gas in unleaded vehicles declined (as shown by the decreasing overall height of the bars), but the distribution of lead concentrations in the leaded gasoline has shifted dramatically. In the 1988 survey, for example, less than 1% of the misfueled vehicles had a gasoline lead concentration of 0.2 gpg or higher, compared to 17% in 1987 and 53% in 1984. As was mentioned earlier, the 1988 survey was the first in which gasoline samples were taken from leaded vehicles as well as unleaded vehicles. A significant percentage (28%) of the leaded vehicles were using unleaded gasoline at the time they were surveyed, either by the vehicle owner's choice or because service stations were marketing "leaded" gasoline that actually contained less than 0.05 gpg of lead. The distribution of lead concentrations among the remaining 72% is consistent with the distribution of lead concentrations found in the misfueled unleaded vehicles. While this would be expected, it also suggests that the addition of concentrated lead additives to the gas tank by consumers is not widespread. ------- Motor Vehicle Tampering Survey -1988 Page 42 Percentage of Misfueled Vehicles 100 lead concentration range (gpg.) j7"] 1.000+ gpg [2] 0.800 - 0.999 || 0.600 - 0.799 3 0.400 - 0 599 U 0.200 - 0 399 Q 0.100 - 0 199 ¦ 0.050 - 0 099 1984 1985 1986 1987 Survey Year 1988 Figure 12 Distribution of lead concentrations in leaded fuel sampled from fuel switched vehicles: 1984 - 88 surveys. Percentages based on all fuel switched vehicles, including those using unleaded fuel (<0.05 gpg). -f ------- Motor Vehicle Tampering Survey -1988 Page 43 APPENDIX A RELEVANT PORTIONS OF THE CLEAN AIR ACT 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 purchaser; 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 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 following its sale and delivery to the ultimate purchaser. The forms on the following pages were used for recording the survey data in the field. The forms were forced choice to ensure coding consistency, and were designed to facilitate direct data entry. The following codes were used to record data for the major system components on the data sheets: APPENDIX B SURVEY AND DATA RECORDING PROCEDURES 1. Explanation of Survey Forms 0 - Not originally equipped 1 - Functioning properly 2 - Electrical disconnect 3 - Vacuum disconnect 4 - Mechanical disconnect 5 - Incorrectly routed hose 6 - Disconnect/Modification 7 - Missing item 8 - Misadjusted item 9 - Malfunctioning A - Stock equipment B - Non-stock D - Add on equipment Y-Yes Z-No Additional codes were used for those components which could not be classified into the above categories. If a determination could not be made about a given component's condition, the variable was left blank. A brief description of each data entry follows. ------- Motor Vehicle Tampering Survey -1988 Page 44 Form A - Underhood 1-4 ID Number - Vehicles are numbered sequentially as they are inspected. This num- ber is preceded by a site identifying number 5-8 Month and year of last I/M inspection (left blank if vehicle is licensed in non-I/M area). 9-12 Manufacturer of vehicle 13-23 Engine Family - as recorded on the underhood emission label. 24-34 Non-serial number portion of VIN - as recorded on the driver's side of the dash under the windshield or the driver's door post. The VIN is recorded only if the engine family can not be determined. 35-38 Displacement - as recorded on the underhood emission label. 39-40 Vehicle Model Year 41 Originally Catalyst Equipped - as recorded on the underhood emission label or the driver's door post. 42 Engine Status - is coded 'Y' if the engine is the one originally installed in the vehicle and is coded 'Z' if the vehicle: has a different gasoline engine than was originally equipped, was originally equipped with a diesel engine and currently has a gasoline engine, was converted to operate on a fuel other than gasoline or diesel fuel (i.e., propane), or is a "gray market" imported vehicle. 43 Air Cleaner - is coded 'A', 'B', or T. 44 Heated Air Intake - provides warm air to the carburetor during cold engine opera- tion. The heated air intake is coded '0', '1', '3', '4', T (stovepipe hose), '9' (vacuum override), or 'B' (custom air cleaner). 45 Positive Crankcase Ventilation (PCV) system - prevents crank case emissions by purg- ing the crankcase of blow-by gases which leak between the piston rings and the cylinder wall in the combustion chamber under high pressures. The PCV system is coded T, 3', '4' (fresh air hose), T, '9', or 'B' (includes fuel economy devices). 46 Turbocharger - coded '0', 'A', 'B', or 'D\ 47 Evaporative Control System (ECS) - controls vapors from the fuel tank and car- buretor. Some systems have two lines: from the fuel tank to the canister, and from the canister to the carburetor or air cleaner (for purging the canister). Other systems have a third line connected to the carburetor. The ECS is coded T, *3' (carburetor line), '4' (tank line), '5', '6' (air cleaner unsealed), T, or '9' (cracked hose or canister). ------- Motor Vehicle Tampering Survey -1988 Page 45 Air Injection System - extends the combustion process into the engine's exhaust system by injecting fresh air into the exhaust ports, lowering exhaust emissions while still maintaining proper vehicle performance. Two types of air injection systems are currently used. One type uses a belt-driven air pump to direct air through a control valve and into the exhaust manifold. The other type is a Pulse Air Injection Reaction (PAIR) system, which uses an aspirator commonly located in the air cleaner to supply air to the exhaust manifold. 48 Aspirated Air Injection System (PAIR) - coded '0' (if air pump system or none), '1', '4', T, or '9\ 49 Air Pump Belt - is coded '0' (if PAIR or none), '1', T, or '8' (loose belt). 50 Air Pump System - for the purposes of this variable, consists of the air pump and con- trol valve and is coded '0' (if a PAIR or none), '1', '4' (other than belt removal), T, or '9'(frozen pump). 51 Exhaust Manifold - coded 'A' or 'B'. 52 Oxygen and Related Sensors • The oxygen sensor controls the air-fuel mixture going into the engine of vehicles equipped with three-way catalytic converters. A vehicle's computerized engine and emissions control system receives input from various sensors for engine condition information, and constantly adjusts the air/fuel ratio, distributor, and emissions devices for optimum economy, driveability, and emissions. These sensors are coded '0', '1', '2', '4' (unscrewed), '6', or T. 53 Carburetor Type - is coded 'F (fuel injected), 'A' (stock carbureted), or 'B' (non- stock carbureted). 54 Exhaust Gas Recirculation (EGR) System - directs a portion of the exhaust gases back into the cylinders to reduce NOx emissions in the exhaust gas. The stand- ard EGR configuration consists of a vacuum line from the carburetor to a sensor (used to detect engine operating temperature to activate the EGR valve), and another vacuum line from the sensor to the EGR valve. The EGR system is coded '0', T, '2', '3', '4', '5', T, or '9'. ------- Motor Vehicle Tampering Survey -1988 Page 46 Form B - Rear 1-4 ID Number - Same as on Form A. 5-8 Make 9-12 Model 13 Vehicle Type - coded as follows: C = car, T = truck 14-15 License Plate - State abbreviation 16-19 Program Jurisdiction - the city or county of the vehicle's registration is entered (if the vehicle is covered by a control program). 20-23 Exhaust gas HC concentration (in ppm) at curb idle. 24-26 Exhaust gas CO concentration (in percent) at curb idle. 27-29 Odometer - mileage in thousands 30 Dash Label - displays the fuel required and is coded 'O'(for leaded vehicles), '1', or '7'. 31 Catalytic Converter - oxidizes the HC and CO to water and C02 in the exhaust gas. Later model catalysts also reduce oxides of nitrogen. The converter is coded '0', '1', T (entire catalyst canister removed), or 'B' (aftermarket catalyst present). 32 Exhaust System - if as originally equipped an 'A' is coded. If non-stock a "B' is coded. 33 Exhaust System Integrity - the condition of the exhaust system is coded '1' (no ob- vious leaks) or '9' (leaks evident). 34 Tank Cap - seals the fuel tank during normal operating conditions and is coded '1', T, or '9' (loose cap). A separate entry is made to indicate whether the tank cap is stock or non-stock ('A' or 'B'). 35 Tank Cap Origin - is coded 'A' if the tank cap is a stock cap. The cap is coded 'B' if it is non-stock. 36 Tank Label - displays required fuel and is coded '0' (for leaded vehicles), '1', or 37 Filler Neck Restrictor • The restrictor is designed to prevent the introduction of leaded fuel into a vehicle requiring unleaded fuel. It is coded '0' (for leaded vehicles), '1', '4' (widened), '6' (nozzle adaptor present), 'T, or 'B' (non-stock inlet restrictor-functioning properly). 38 Plumbtesmo - Plumbtesmo paper is used to check for the presence of lead in vehicle exhaust pipes. A positive indication is coded as 'P' and a negative as 'N\ 39 Fuel Sample - indicates if inspector was able to obtain fuel sample for later lead analysis ('V or 'Z'). ------- Motor Vehicle Tampering Survey -1988 Page 47 2. Classification of Component Conditions The table below was used to classify the various system components as tampered (T), arguably tampered (A), or malfunctioning (M). Only those codes which are applicable to a given component are listed. Codes for 'not originally equipped' and 'functioning properly1 are not included in this table. Refer to Appendix B, Part 1 for an explanation of the codes. Codes from forms A and B Component/system 23456789B Dash Label A Tank Cap A M Tank Label A Filler Neck Restrictor T T T Catalytic Converter T Oxygen and Related Sensors T T T T PCV System T T T M T Heated Air Intake T A A M T Evaporative Control System T T T T T M Aspirated Air Injection System T T M Air Pump Belt T M Air Pump System T T M EGR System T T T T T M T = Tampered A = Arguably tampered M = Malfunctioning ------- Motor Vehicle Tampering Survey-1988 Page 48 3. Fuel Sample Collection and Labeling Procedures An attempt was made to take a fuel sample from each vehicle surveyed. These samples were collected in two-ounce bottles with a hand-operated fuel pump. Once the sample was drawn, the fuel was replaced with an equivalent amount of unleaded fuel if the driver requested, and the pump was flushed with unleaded fuel. Each bottle was identified with an adhesive label that had the vehicle identifying survey number on it. The vehicle identifying number was the first entry on the data forms described in Part 1 of Appendix B. The bottles were packed, labeled, and shipped to EPA's Motor Vehicle Emissions Laboratory in Ann Arbor according to the shipper's requirements. 4. Plumbtesmo Application 1) Clean a portion of the inside of the tailpipe large enough for the test paper by wiping it out with a paper towel or cloth. This may be necessary to remove soot deposits which might mask the color change. 2) Moisten the Plumbtesmo paper with distilled water and immediately* press firmly against the surface to be tested for approximately thirty seconds. If the tailpipe is hot you may wish to clamp the test paper in the tailpipe using a clean clamp. •Note The Plumbtesmo paper must be applied during the time that the paper is yellow for the reaction to take place. After approximately 15 seconds the yellow color disappears and the paper is no longer effective. Excess water also interferes with the reaction. Care must be taken to avoid contamination of the test paper. If a person has recently handled a test paper with a positive reaction, some lead or reactive chemical may have been transferred to their fingers. Subsequently handling a clean test paper may cause con- tamination. 3) After removing the test paper, determine whether a color change has occurred. Red or pink coloration indicates the presence of lead. 5. Field Quality Control Reference and calibration gases were used to ensure the accuracy of the emissions analyzer. Horiba gases certified by RTP were used as reference gases. Two cylinders of reference gas were used to validate the accuracy of the calibration gases before they were taken to the field on each survey. Two calibration gases (Horiba) were used. These gases were a mixture of CO and HC in nitrogen and were used to check the instrument at least three times daily. These calibration gases were certified by the manufacturer and the RTP reference gases. Their approximate compositions were: 8% CO 1560 ppm HC (Hexane equivalent) 1.6% CO 320 ppm HC (Hexane equivalent) ------- Motor Vehicle Tampering Survey -1988 420-R-89-100 Page 49 APPENDIX C EMISSION OUTPOINTS FOR I/M AREAS The table below lists the emission cutpoints used in 1988 by the I/M areas covered in the 1988 tampering survey. The cutpoints for pre-1975 vehicles are not included, since these vehicles were not surveyed. Survey Site Model Year Emissions Cutpoints CO (%) HC (ppm) El Paso, TX 1975-77 1978 1979 1980 1981 + 7.5 6.5 6.0 4.0 1.2 Tucson/Phoenix, AZ 1975-78 (4 cyl.) 2.2 250 1975-78 (6-8 cyl.) 2.0 250 1979 (4 cyl.) 2.2 220 1979 (6-8 cyl.) 2.0 220 1980+ (all) 1.2 220 New York, NY 1975-78 3.5 400 1979-80 2.5 300 1981 + 1.2 220 New Jersey 1975-80 3.0 300 1981 + 1.2 220 Medford, OR 1975-80 (no CC) 25 250 1975-80 (CC) 0.5 175 1981 + 0.5 175 KEY: CC = catalytic converter (all types), CYL. = cylinder ------- |