Audit of the Enhanced I/M Program in Maine


           United States
           Environmental Protection
           Agency
Office of Air and Radiation EPA-AA-EPSD-I/M-94-8
Office of Mobile Sources       August 1994
Ann Arbor, Michigan 48105
           Air
vvEPA   Audit  of  the  Enhanced
           I/M  Program   in  Maine

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Executive Summary

On August 9, 10, and 11, 1994, a four person EPA audit team from the National
Vehicle and Fuels Emission Laboratory in Ann Arbor, Michigan, conducted a brief audit of
the Maine Car Test Program. The purpose of this audit was not to conduct a
comprehensive or in-depth review of every aspect of the program but, rather, to evaluate
the technical and organizational aspects of the program. The Maine inspection program is
the first to employ IM240, evaporative system purge, and evaporative system pressure tests
on a network-wide basis. The Maine Car Test program was found to be technically well
designed and implemented. Minor technical problems were observed, however, none are
likely to result in false test failures.

The major area that needs to be addressed at this time is public interface, especially
revising the test report and other information provided to motorists that fail the test. Minor
refinements are needed in the testing process, and procedures for suspending evaporative
system tests when pattern failure problems are encountered are needed Additional
informational training for the repair industry would be useful in helping insure efficient and
effective communications and repairs, although the data on retest pass rates to date do not
indicate a major problem with repair effectiveness.
Introduction

From August 9-11, 1994, a four person EPA audit team from the National Vehicle
and Fuels Emission Laboratory in Ann Arbor, Michigan, conducted a brief audit of the
Maine Car Test Program. The purpose of this audit was not to conduct a comprehensive or
in-depth review of every aspect of the program but, rather, to evaluate the technical and
organizational aspects of the program. The Maine inspection program is the first to employ
IM240, evaporative system purge, and evaporative system pressure tests on a network-
wide basis. These tests are being implemented in enhanced I/M programs throughout the
country and Maine's experience will help those that follow to refine the design and
operation of the enhanced I/M tests. The audit team visited four stations in the seven
station network: Westbrook, Kennebunk, Lewiston, and Topsham. The first three of
these stations are the largest volume stations in the system. The audit team focused on
observing the testing process, monitoring inspector performance, assessing equipment and
quality control, and evaluating the overall system.

General Description of the Test Process

The testing process in the Maine program uses a three position system that begins
when the motorist pulls into the lane. At the first position, an inspector greets the motorist
and obtains basic information and the vehicle registration. This information is used to call
up the pre-existing vehicle record, if available, or to create a new record for the vehicle.
The inspector determines whether this vehicle is scheduled for an inspection and, if not,
asks the motorist if he or she would like a voluntary test. If the information collection is
occurring in the lane (as opposed to outside the lane in the queue, when other cars occupy
the test positions in the lane) the vehicle is turned off and, on 1981 and newer vehicles,
another inspector prepares the vehicle for pressure testing by removing the vent lines from
the evaporative canister under the hood and attaching a pressure test hose and for the purge
test by connecting two purge hoses between the canister and the engine. A swinging arm is
then brought into position in front of the car and the pressure test system is attached to the
pressure test hose. Once attached, the inspector presses a button and the pressure test

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proceeds automatically. When the test is completed, a light automatically illuminates to
notify the inspector.

Once the pressure test is completed, the hood is lowered (but not closed) and the
vehicle is moved to the second position in the lane where the IM240 and the evaporative
purge tests are performed. With one inspector driving the vehicle and another inspector
assisting, the vehicle is positioned on the dynamometer. While still running, the vehicle is
prepped by one or two inspectors for the IM240 test:

• chock blocks are placed in front of the non-drive wheel tires

• for some front wheel drive cars, straps are attached to the front of the vehicle

• the cooling fan is positioned in front of the vehicle

• the purge meter (mounted on the cooling fan) is attached to the purge test hoses

• the sample funnel is attached to the tail pipe, and

• the test control console is hooked onto the steering wheel.

Once prepared, the inspector sits in the driver's seat and runs the IM240 and the
evaporative system purge test. Maine employs fast-pass software so the test may last as
little as 30 seconds or as long as 240 seconds. Once the IM240 is complete, the vehicle is
deprepped and moved to the final position at which point the motorist resumes control of
the vehicle, is given the test report and a brochure, and is advised of the test results. At this
point, the motorist may be referred to the customer service office for more assistance.

Over the course of the three day visit the audit team observed this testing process at
all four of the test stations visited. In most respects, inspectors followed the test
procedures established by EPA and the State. There were several relatively minor
deviations observed during the audit, that are unlikely to have any major impacts but do
need to be addressed:

• In some stations, vehicle hoods were not left fully open during the IM240.
Opening the hood during the transient test is important to simulate normal air
flow cooling during the test. The effect on emissions of failing to open the
hood is likely negligible, however, it is important to prevent vehicles from
overheating.

• At one station, the sampling system was routinely removed from the tailpipe
prior to the end of the test due to the mistaken belief that the final deceleration
did not contribute to the test results. Pulling the sampling system off early is
unlikely to result in false failures, however, there are some types of emission
related malfunctions that might not be detected.

• At one station, the pressure and purge tests were skipped if the inspector
observed that the vent line or purge lines were "brittle." As far as we could tell,
these vehicles were not failed and required to get new hoses. EPA believes it is
best to test these vehicles, however, if hoses are too brittle for the vehicle to be
tested then it should fail.

• Vehicles were not always restarted right after the pressure test. EPA guidance
requires a minimum of 30 seconds of engine operation after restart prior to the
IM240. Minimizing the length of time the engine is shut off is important to
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keep the vehicle in a fully warmed up condition. This will become more
important when the weather gets colder.

The audit team also noted that the State's instructions to the contractor do not seem
to include a comprehensive visual inspection of the evaporative canister. This check is part
of the credit for the pressure test. A visual check of the evaporative canister needs to be
performed and must include an assessment of the canister and the hose connections.
Obviously tampered or damaged canisters or obviously missing or misrouted hoses must
result in test failure.

There are several other recommendations that the State should consider in terms of
how the test is run and which tests are employed:

• Suspend evaporative pressure or purge tests for problem vehicles such as Ford
Broncos. EPA has approved alternative pressure and purge tests that should
alleviate many of the problems that Maine has encountered. These tests will not
be ready for use for approximately 6 months.

• Use fast-pass only when there are vehicles waiting in line to be tested. The
fast-pass results only predict the final test outcome; they do not provide an
accurate, absolute measure of the vehicle's condition. When time allows,
completing the full test will provide the motorist and the State with more
accurate information about the vehicle's emission rates.

• Check tire pressure when there are no lines. While the audit team did not notice
any vehicles with low tire pressure being tested, we also did not observe any
tire inflation occurring, which is required when low tire pressure is observed.
It is often difficult to visually detect low tire pressure. Inflating tires to
recommended tire sidewall pressure when there is no time pressure in the lane
will yield important benefits: fuel economy will improve, emission rates may
be reduced, and a more accurate test result will be insured.

The audit team did not note any other problems with the performance of the test but
some potential problems are difficult to spot during overt observations. Inspectors should
be reminded to:

• Verify vehicle operating temperature by checking the temperature gauge

• Check drive wheel tires for inflation and safety conditions

• Turn off all accessories during the IM240

Physical Structure and Equipment

Maine's contractor, Systems Control, Inc. has done an outstanding job in designing
and deploying the IM240 testing system. The equipment is well designed in most respects
and it appears to meet the specifications established in EPA guidance. The pressure test
arm is very convenient to use - it swings into position and back out of the way with ease.
The monitors and controls for the emission test are intuitive and practical. The equipment
provides excellent feedback to the driver on the degree to which the trace is being followed.
A possible problem observed in one case is that the software did not seem to identify the
fact that the emission sample was lost after the sample funnel fell out of the tailpipe. An
inspector noticed the problem and alerted the driver and the test was aborted. In another
case, the sample funnel kept collapsing when the inspector tried to attach it to the tailpipe.
The technical staff indicated that they were aware of the problem and plan to increase the

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rigidity of the funnel. The purge equipment is mounted directly on the cooling fan, which
is manually placed in front of the vehicle very easily and easily retracted after the test. The
vehicle restraint system - which is also not automatic - is more cumbersome to deploy and,
in two cases, inspectors did not remove chock blocks or straps prior to moving the vehicle
to the third position. (The vehicles were not apparently damaged in these cases.) The
layout of the lane is designed to minimize noise levels - blowers are placed near the ceiling
in insulated boxes. Enclosed booths are provided along with fenced areas for observing
tests to insure the safety and comfort of motorists. In general, the physical structure and
the equipment meets EPA's expectations of how an effective system is designed and
deployed.

Public Interface

The audit team observed the testing process from beginning to end in as many cases
as possible. By necessity, inspectors must interact with motorists in order to conduct the
test process. From the initial greeting to the final results, the audit team observed that
inspectors acted courteously and helpfully. Even in cases where a customer was upset
about failing the test or some other problem, the inspectors maintained their composure and
performed their roles in a responsible manner. EPA does recommend one procedural
change that is used in other centralized I7M programs.

• Inspectors should provide motorists with only a very brief verbal report on the
results of the test and then refer motorists that have additional questions or
would like assistance to the customer service office.

This will help increase throughput and insure that motorists are given consistent, accurate
and comprehensive information. The audit team noticed that testing was frequently delayed
because one member of the three-person team was occupied answering a motorist's
questions in the third position. This does not seem to be an efficient use of the inspector's
time. The training required to insure optimum responses to the wide variety of questions or
potentially difficult situations is probably too much to ask of this type of position. In
keeping with this, a system needs to be devised (e.g., a buzzer or light) such that when
motorists do enter the customer service office, a customer service agent can respond
promptly if they are not already present at the desk.

The other major interface with the public is the test report. This is one area where
major changes need to be implemented right away. The audit team found the report to be
confusing and the information in conflict with the intent of EPA guidance. It should be
noted that EPA's guidance was not absolutely clear in this respect. EPA plans to make
changes to clarify its intent. The following changes should be made to the test report:

• The composite emission standard should always be the only standard printed on
the test report for each pollutant, regardless of the decision process used to
determine pass/fail status. While the logic being used for determining the
overall test result is correct, the report is confusing. Two standards are being
printed now - the composite standard or the fast pass standard, and the phase 2
standard. This is very confusing - especially when a vehicle fails only the
composite or only the phase 2 standard. When a vehicle fails only one, then the
overall result is a pass. The fact that the printout says "Fail" for one of them
implies a failure for that pollutant overall.

• Current practice is to print the fast-pass standard instead of the composite
standard if the vehicle is fast-passed. This is even more confusing since
vehicles of the same class appear to be subject to different standards. The

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potential for this type of confusion was highlighted in a recent newspaper report
in which it was inferred that one vehicle was tested at different standards at
different stations. The fast pass standards should be viewed as subsets of the
composite score since they are derived from the composite standard. As above,
only the composite standard should be printed on the test report.

Two emission scores are also being reported for hydrocarbons and carbon
monoxide, and the score reported is a function of the decision process used to determine
pass/fail status. This is also confusing to motorists. The emission scores reported should
be as follows:

• If the vehicle passes the composite standard, report only the composite emission
score.

• If the vehicle fails the composite standard, report only the composite emission
score.

• If the vehicle fails the composite standard but passes the phase 2 standard,
report only the phase 2 results.

• If the vehicle fast passes, report the gram per mile emission rate for the test.

Another essential element of successful public interface is providing motorists that
fail the test with information on what to do. The State and the contractor have produced an
excellent brochure providing motorists with general information on how to respond to a test
failure. At this time, however, that brochure, the test report, and verbal information is all
that is provided to motorists. EPA's I/M rule requires that motorists also be provided with
a list of repair facilities. This list must include all facilities that have performed repairs on
one or more vehicles that failed the I/M test. The list may be segmented in various ways,
including groupings of certified facilities and non-certified facilities. Naturally, at the start
of the program, the list will be in a rapidly evolving state as more and more repair facilities
become involved in the program. In addition to merely listing the facilities, EPA rules also
require that the list include information on the success of stations that repair vehicles.
Again, that information will take some time to accumulate and EPA does not expect such
information to be reported in the first few months of a program.

• Give every failing motorist a list of repair facilities that are certified or have
conducted repairs on vehicles that failed a test. Conversations with the Maine
Department of Environment's I/M staff indicate that such a list is now available
and will be distributed.

EPA's I/M rule also requires that repair technicians be provided with software
generated diagnostic information when vehicles fail the test. The minimum that EPA
intended was that motorists be given second-by-second emission results if they failed the
test. This information could be passed on to repair technicians to use in the diagnostic
process. The State is planning to provide this information to repair technicians via an
electronic interface service. The printed information should also be provided so that the
information is readily available to all technicians.

• Print out second-by-second trace information and give it to failing motorists.

Effective maintenance is the key to a successful I/M program. The State has taken
commendable steps to establish training and certification programs for repair technicians.
The Maine Central Technical College provides testing and training courses that relate

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directly to the inspection program. The State and the contractor have also produced a series
of newsletters that have been sent to repair facilities throughout the seven county region.
Nevertheless, the audit team got the impression that some in the repair industry did not
have a full understanding of the nature of the I/M tests being performed, general
information on why the were necessary and what they were intended to find, information
on how to interpret the results and other program specific information.

• EPA recommends that the State institute a series of brief repair technician
training sessions to provide information about the program and how it works
(i.e., not training on repairing vehicles, per se; Maine is already providing such
a program). One of EPA's grantees has developed a training course that serves
this purpose.

Failure Rates

The audit team reviewed data on the pass and fail rates for the first month of the
program. The overall failure rate is 21%. The by-model-year failure rates track very
closely with the failure rates predicted by EPA based on the standards being used. The
audit team also looked at retest failure rates. Among vehicles that got repaired and returned
to the test station for a retest, about 62% passed the retest. This rate is essentially the same
as that experienced in other (basic) test-only I/M programs. This indicates that, in the
majority of cases, repair technicians are able to repair the vehicle on the first try. EPA was
concerned that in an area that has never had an I/M program and one that starts with
enhanced I/M, unusual problems could be experienced with repair effectiveness. This does
not seem to be the case; the repair community seems to be as capable as other I/M areas in
fixing failed vehicles.

Summary and Conclusions

The Maine Car Test program is technically well designed and implemented. We
conclude that Maine has successfully implemented the IM240, purge and pressure tests in
mass production in a networked system. This system has been developed and tested by
EPA over the last five years. Given that this is the first full-scale, enhanced IM240
program, the few technical problems noted in this audit are an indication of the outstanding
job done by the Maine Department of Environment and its contractor, Systems Control.
This is not to say, however, that there are no problems that need to be addressed. The
technical problems, however, are minor.

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