United States
Environmental Protection
Agency
Office of Air and Radiation
(ANR-443)
Washington, DC 20460
May 1996
Air
\vEPA Mobile Source Air Pollution
Control Measure
Recommendations for Cairo, Egypt
Prepared by
Eugene J. Tierney
Nyaneba Nkrumah
Christopher Polovick
-------
AEPA
United States
Environmental Protection
Agency
Office of Air and Radiation
(ANR-443)
Washington, DC 20460
May 1996
Air
Mobile Source Air Pollution
Control Measure
Recommendations for Cairo, Egypt
Prepared by
Eugene J. Tierney
Nyaneba Nkrumah
Christopher Polovick
-------
Table of Contents
Executive Summary i
I. Introduction 1
II. Lead Phase-Out 2
III. New Vehicle Emission Standards 5
IV. Fuel Volatility Control 8
V. Inspection and Maintenance 10
A. Introduction 10
B. Network Type 10
C. Program Management 11
D. Test Type, Emission Standards, and Phase-In 13
E, Onboard Diagnostic Systems 14
F. Waivers 15
G. Compliance Enforcement 16
H. Inspector Training and Certification 18
I. Repair Technician Training and Certification 19
J. Quality Control 20
K. Quality Assurance 20
L. Public Awareness 22
M. Smoking Vehicle Enforcement 22
VI. Stage I Vapor Control 25
Appendices
Assessment of the Executive Regulations A
Summary of U.S. New Vehicle Standards B
Summary of European New Vehicle Standards C
Lead Phase Down Information D
Background Information on Fuel Volatility Control E
Requests for Proposals F
Centralized I7M Program Regulations G
Decentralized I/M Program Regulations H
Idle Test Specification I
Exhaust Analysis Equipment Specification J
Calibrations, Adjustments and Quality Control Procedures K
IM240 Test Specification L
Public Awareness Materials M
Examples of Newsletters N
Examples of Enforcement Actions O
Light-Duty Diesel Inspections P
Heavy Duty Diesel Inspection Procedure Q
Stage I Vapor Control Information R
-------
Executive Summary
Mobile Source Air Pollution Control Measure
Recommendations for Cairo, Egypt
The following is a summary of the key recommendations made in this report, in order of
priority. We believe that implementation of an I/M program is the lowest priority for Cairo, Each
of these recommendations is discussed in detail in the full report.
Leaded Gasoline Phase Out
• We recommend that the supply of unleaded gasoline be increased as quickly as possible.
• We strongly and urgently recommend that the price of unleaded gasoline be set lower than that
of leaded gasoline to encourage motorists to use unleaded fuel and to discourage misfueling.
• We recommend that leaded gasoline be phased out as quickly as possible and that the amount
of lead in leaded gasoline be reduced to the lowest level practical given refining capacity.
• We recommend that the GOE stop the routine practice of removing catalytic converters from
imported vehicles and that catalyst equipped vehicles be required to use unleaded fuel.
New Vehicle Emission Standards
• We recommend that the GOE adopt U.S. new vehicle standards as soon as unleaded gasoline
supplies and distribution can be increased sufficiently to service catalyst equipped vehicles.
• We recommend that the GOE eliminate import tariffs on all non-luxury vehicles so as to
encourage purchase of new, clean cars.
• We recommend an increase in the price of gasoline to offset lost tariff revenues and to provide
incentives for vehicle maintenance, fewer vehicle kilometers traveled, and fleet turnover.
• We recommend that the GOE promulgate regulations that bar tampering with emission control
devices and putting leaded fuel into catalyst equipped vehicles.
• We recommend that the GOE explore means to accelerate the fleet turnover process, including
the use of registration fees, pollution taxes, vehicle scrappage programs, and the like.
* We recommend that the GOE (continue to) bar import of used vehicles and engines.
Fuel Volatility Control
• We recommend that Egypt lower the volatility of gasoline to 6.8 psi Reid Vapor Pressure, as
soon as the refining changes can be made to achieve this level.
Stage I Vapor Control
• We recommend that Egypt install Stage I vapor controls as quickly as possible.
Inspection/Maintenance
• We recommend that Egypt implement a hybrid I/M program in Greater Cairo for both gasoline
and diesel powered vehicles.
-------
I. Introduction
The U.S. Environmental Protection Agency (EPA) was asked to assist the U.S. Agency
for International Development (USAID) and the Government of Egypt (GOE), in conformance
with the USAID/Egypt Sector Policy Reform II Program, to review the GOE's air emission
regulations and make recommendations for the implementation of a motor vehicle
inspection/maintenance (I/M) program and other mobile source air pollution control measures.
We performed a two-phased analysis. The objectives of Phase One were to: evaluate the
executive regulations; create an inventory of mobile source emissions for Cairo; estimate vehicle
emission rates; analyze alternate I/M scenarios and estimate the emission reduction impact of these
program designs; and, analyze the emission reduction impact of fuel volatility control and the
introduction of new car standards. We presented these results along with its conclusions and
recommendations to the GOE and USAID during a visit to Cairo in March 1996.
This report presents the Phase Two analysis and consists of detailed recommendations for
mobile source pollution control and a refined plan for the implementation of the I/M program in
Greater Cairo. It also addresses the implementation of a wide-ranging mobile source pollution
control program. These recommendations will be presented at a policy workshop in Cairo in the
fall of 1996.
While the bulk of this report discusses the refined plan for the implementation of an I/M
program, this certainly does not reflect what we believe should be the first priority for air pollution
control in Cairo. We were asked to provide technical expertise on I/M and propose a plan for an
appropriate program for Cairo. This is detailed in Section V of this report. However, we have
shown that I/M represents the least effective of the air pollution control strategies analyzed. The
adoption of stringent new car certification standards and the production and distribution of cleaner
fuels will do far more to improve Cairo's air quality in the long term. In fact, we concluded that
1/M will not result in a net decrease in air pollution in Cairo, because growth will quickly overcome
any benefit. Only by redirecting growth into low emission modes can air pollution actually decline
or even remain stable.
Section II of the report offers an analysis of gasoline lead phase-out. We consider this to
be the single most important mobile source air pollution control measure Egypt can adopt given the
high levels of lead found in the Egyptian population and the devastating health consequences lead
has on humans. Getting lead out of gasoline, or at least having an adequate supply of unleaded
gasoline, is the essential first step in solving other mobile source air pollution problems. Section
III expands on the conclusion that new car standards offer the single greatest source of reductions
in volatile organic compounds (VOCs), carbon monoxide (CO), and oxides of nitrogen (NOx),
particulate matter and carbon dioxide. The adoption of new vehicle certification standards,
especially U.S. standards, will dramatically improve air quality in Cairo with regard to these
pollutants or precursors. Controlling fuel volatility is discussed in Section IV, which may be the
easiest measure to implement. Section V provides our recommendations for an I/M program.
Finally, Section VI discusses Stage I vapor control, strictly speaking not a mobile source air
pollution control measure, but an important measure that will help control ozone in Cairo.
This report is limited in scope with regard to mobile source pollution control measures.
Our charge was to focus on I/M and address other measures as time allowed. Thus, our reports do
not address the particulate matter problem in any great detail, despite the apparently severe PM10
problem in Cairo. The lack of time and data limited the range of control options considered. For
example, we did not discuss NOx control, beyond the impact of new vehicle standards. We did
try to focus on big impact measures that have been shown to be effective as well as economically
feasible. Given the expected growth in Cairo and the apparent severity of the air pollution
problem, additional measures will be needed to bring pollution levels down to acceptable levels.
Page 1 Introduction
-------
II. Lead Phase-Out
Introduction
Adding lead to gasoline is an inexpensive way to boost the octane rating but very costly in
terms of environmental impact. The most commonly used additive is tetraethyl lead. EPA
estimates that 75% of this lead is emitted from the combustion process as paniculate matter, with
half being quite small (0.25 micron), making it more susceptible to absorption in lung tissue. The
remainder of the lead is deposited in the engine and the exhaust system, causing accelerated
deterioration on the engine. Most of these deposits are eventually flaked off into the environment
and washed into waterways and soils. There they can get into the food and water supplies.
Cairo's lead pollution problems are exacerbated by the lead smelting industry, a major
contributor of airborne lead emissions. The public health effects of the high levels of
environmental lead have been well documented in Cairo; child development is severely impacted
and certain adult health conditions such as hypertension are exacerbated. The dire social,
economic, and environmental consequences for Egypt are being addressed in the Lead Exposure
Abatement Plan and the Cairo Air Improvement Project.
As discussed in the Phase I report, the phase-out of lead and the introduction of unleaded
fuel to the gasoline supply is critical to the success of the mobile source air pollution program in
Cairo. As clean, modern technology, catalyst-equipped vehicles become a greater proportion of
the Cairo vehicle population, unleaded fuel must be made available for their use. We recommend
that the Government of Egypt (GOE) stop the routine practice of removing catalytic converters
from imported vehicles and require catalyst equipped vehicles to use unleaded fuel. Naturally, the
supply and distribution of unleaded gasoline must substantially increase before this is practical. In
keeping with this, it is vital that the price of unleaded gasoline be set lower than that of leaded
gasoline, at least by a few piasters. Besides damaging the entire engine system, lead fouls and
disables both the oxygen sensor and the catalytic converter, components critical to the emissions
control of these vehicles, thereby causing emissions of HC, CO and NOx to increase to levels as
high or higher than that of uncontrolled vehicles. Vehicle owners will readily purchase unleaded
fuel to protect their engines and emission control systems only if there is a price advantage.
EPA studies show that leaded fuel has both negative and positive impacts on older
combustion engines. In the U.S., up until the early 1970's, most cylinder heads were made of
cast iron, with the valve seats ground directly into head. As noted previously, lead lubricates these
valve seats and prevents premature wear or recession, particularly for heavy duty vehicles and
those operated at high speeds and high loads for long periods of time. The lack of lead lubrication
can lead to leaking valves, loss of compression, poor performance and significant increases in HC
emissions. With the advent of unleaded fuels in the U.S., manufacturers began to harden or
surface the seats to prevent such wear. It is not within the scope of this study to determine what
percentage of the Cairo vehicle population has cast iron heads or what the typical operating modes
of vehicles are in Cairo; i.e., we cannot estimate the fraction of vehicles that would be affected by
total elimination of lead in gasoline. The age of the fleet indicates that a significant fraction of
vehicles on the road are likely to have cast iron heads, but this may be offset by the flat terrain and
the apparent low average speeds.
Lead also has deleterious effects on vehicle engines. It has been shown to cause corrosion,
deposits, and lead fouling of spark plugs and other components, leading to greater repair and
maintenance costs and higher emissions of other pollutants over the long term.
Efforts are currently being made to reduce the levels of lead additives in Egypt, and we
encourage the continuation of this approach until no lead is added to gasoline at all. The last
reported average lead content for the Cairo gasoline supply is 0.15 grams per liter (about 0.57
Page 2 Lead Phase-Down
-------
g/gallon). We recommend that Egypt continue to reduce the amount of lead in leaded gasoline as
refining capacity allows to the lowest possible level and that as quickly as possible, leaded gasoline
be eliminated altogether. While some vehicles may be adversely affected by the complete
elimination of lead, we believe that these impacts are offset by the health and economic benefits of
the eliminating mobile source lead from the environment. Furthermore, vehicles most dependent
on lead are likely to be among the oldest and highest emitting vehicles in the fleet. Their
accelerated removal from the vehicle population will be an added benefit. We also recommend that
the supply and distribution of unleaded gasoline be increased as quickly as possible and the price
of unleaded be set lower than the price of leaded in order to discourage misfueling of catalyst
equipped vehicles. It is important to do this in advance of the introduction of catalyst equipped
vehicles so that the culture of lower priced unleaded fuel is developed.
Costs
One of the primary technological issues to consider with the lead phase-out is how to
replace the octane lost through the removal of lead. The initial phase of the phase-down should
have relatively little impact on the loss of octane. Lead provides the greatest octane boost at low
levels. For example, data shows that the first 0.13 grams per liter lead contributes as much octane
as the next 0.53 grams per liter. The marginal cost of producing octane rises with the amount of
octane produced. Other components can be added to boost the octane but at a higher cost to
refiners. Unleaded or low lead fuel can also cost more to produce as more energy is used in the
refining process and additional equipment is installed. However, the cost of producing regular
unleaded fuel with 87 octane will be less than the cost of producing low lead 89 octane gasoline.
This is because 89 octane leaded gasoline must be boosted to over 88 octane before the lead is
added to boost it to 89 octane. Total cost estimates for U.S. refiners during the lead phase down in
the mid to late 1980's ranged from 22 to 85 cents per octane-barrel (to raise the octane of a barrel
of gasoline by one point). It is not within the scope of this study to determine what these costs
would be for Cairo.
Another consideration for how the lead phase-out is handled is the degree to which the
current distribution system can handle multiple fuels. It is important that unleaded fuel not be
contaminated by transporting it in pipes, tanks, and trucks that carry leaded fuel. Thus, Egypt may
want to begin the process of complete conversion of parts of the fuel supply system to unleaded,
rather than duel fueling, which would raise the cost. For example, gasoline service stations in
more affluent areas of the city of Cairo, where more catalyst-equipped new vehicles are likely to
refuel, could be completely converted to unleaded gasoline first, followed by eventual conversion
of all stations.
Depending on the quality of the crude oil to be refined, the current operating refinery
technology and design, and the desired output, any number of options can be implemented to
increase low lead and unleaded fuel octane. Fluid catalytic cracking units, isomerization units,
alkylation units and increased severity reformers can raise octane through improved refining
processes. As with lowered RVP fuel, octane can also be boosted through blending processes
which add components like MMT, MTBE, alcohols, toluene, xylene or alkalytes. More analysis
must be done to determine which components are best suited for Cairo. For instance, some data
shows that MMT may have adverse effects on hydrocarbon emissions, while alcohols can
introduce extra moisture.
Benefits
The environmental, economic and social benefits of reducing and eliminating lead in Cairo
would be significant but largely incalculable in the scope of this study. We do know, however,
that lowered lead emissions will have important public health benefits, such as improved child
development and reduced hypertension in adults. These changes alone could have tremendous
Page 3 Lead Phase-Down
-------
economic and social benefits for Egypt in terms of the cognitive ability of its work force and the
health of its citizens.
Further benefits would be achieved by reductions of other pollutants such as HC, CO and
NOx, and the resulting ozone. These benefits will occur when emissions are not increased due to
lead fouled catalysts and oxygen sensors on new vehicles. These increases have been estimated to
be a factor of up to eight times greater because of lead fouling. Catalysts have been shown to
oxidize up to 90% of unburned HC in the exhaust. Fouling of the oxygen sensor also has a
significant impact on the efficiency of the combustion process leading to further increases HC or
CO depending on whether the fuel/air mixture is overly lean or rich. Furthermore, with the
introduction of unleaded fuel, motorists should not be allowed to remove the catalysts on new
vehicles, thereby saving the emissions that would be removed over the vehicle's lifetime by the
catalyst.
Ozone is formed when volatile organic compounds (also referred to as hydrocarbons) react
with sunlight in the atmosphere. It has been shown to cause a number of chronic respiratory
problems such as asthma and other health effects. Ozone has also been shown to cause significant
agricultural losses as it inhibits photosynthesis which reduces plant growth, yield and quality.
Carbon monoxide reduces the oxygen carrying capacity of the bloodstream, thereby causing
cardiovascular problems, anemia, and fetal development problems. NOx reacts in the atmosphere
to cause visibility problems and material damage, and in sufficiently high levels can damage human
health directly.
The reduction of lead will further reduce other harmful contaminants such as ethylene
dibromide (EDB), a gasoline additive associated with lead use (called a scavenger, it prevents
excessive lead deposits), and a suspected carcinogen. Benzene, a known leukemogen, will also be
reduced as one of the HC components reduced through emissions controls. This is particularly
important if additional benzene has been added to boost octane.
Benefits of unleaded and low leaded gasoline will also accrue in terms of savings on
regular vehicle maintenance, fuel economy, and engine durability. These savings will translate into
significant economic and environmental benefits, which again cannot be calculated in this study.
In terms of vehicle maintenance, savings are based on less frequent replacement of the exhaust
system (leaded exhaust is more acidic and therefore more corrosive of the system), and the spark
plugs (easily corroded and fouled with lead). Reduced levels of lead will also extend the intervals
between oil changes, as lead deposits lead to corrosion of internal engine surfaces which ultimately
accumulate as debris in the oil. These particles can reduce overall engine durability and actually
cause further engine damage such as ring, cam and lifter wear which impacts performance and
increase emissions.
Fuel economy savings are achieved in three ways: the increased energy content of denser
gasoline (through the increased reforming and isomerization to replace lost octane), and the
reduced fouling of oxygen sensors and spark plugs. Deterioration of these components leads to
inefficient combustion and increased emissions, as discussed previously. Properly functioning
combustion systems which run on denser fuel will have lower overall levels of emissions.
Page 4 Lead Phase-Down
-------
III. New Vehicle Emission Standards
Introduction
As discussed in the Phase I report, we strongly believe that the implementation of stringent,
new vehicle certification standards is essential to the long term improvement of air quality in Cairo.
We have shown that while the proposed I/M program will itself achieve measurable emissions
reductions, the growth in VKT will quickly overcome these benefits. The effects of a large
population of old-technology vehicles not being replaced with cleaner new-technology vehicles,
combined with the regular removal of catalytic converters on imports, and lead fouling of other
critical components leads to a continuous growth in vehicle emissions.
Stringent new vehicle standards combined with other program elements such as unleaded
gasoline and lowered RVP, and improved testing and repair will lead to the greatest reductions in
overall emissions for Cairo over the long term. The Phase I study showed that these elements
would combine to reduce HC and CO by about half and NOx by a third after ten years, as
compared to I/M which by itself will cause no actual decrease in emissions from current levels.
Appropriate Clean Car Standards
The U.S. new vehicle certification and enforcement program has been proven effective
over the past 20 years. The results have been dramatic. Despite very high growth in vehicle usage
and distances traveled, the carbon monoxide pollution problem is nearly entirely gone and the
ozone problem has been declining. New vehicle emission standards have been tightened such that
motor vehicle technology has been revolutionized to meet requirements. In the U.S. for instance, a
new light duty, gasoline fueled vehicle of today is permitted to emit less than 5% of the HC and
CO, and only 25% the NOx allowed 30 years ago. The most recent development that we
anticipate will further revolutionize in-use vehicle performance is onboard diagnostic (OBD)
systems. These systems are required on all 1996 and newer light duty vehicles and trucks in the
U.S. and they must turn on a dash-board malfunction light if any system failure would cause
emissions to increase substantially above standards. We anticipate that this system will cause new
technology vehicles to perform even better in-use and will vastly simplify diagnosis and
maintenance of malfunctioning vehicles (Section V includes further discussion of this technology)
Any vehicle offered for sale in the U.S., domestic or import, must be certified to meet the
standards promulgated by the U.S. EPA (with the exception of vehicles sold in California, which
must be certified by the California Air Resources Board). Each standard represents the maximum
allowable limits for the problem pollutants CO, HC, NOx and particulates for different vehicle and
fuel types. Appendices B and C detail the U.S. and European standards respectively. The
standards vary considerably in terms of vehicle classification, measured units and test type.
Negotiations are currently underway to harmonize these standards and create one unified
international standard. However, it could be years before this ambitious goal is achieved.
Currently, vehicles are imported into Egypt that meet U.S. or European new vehicle
standards, but due to the lack of unleaded gasoline, catalytic converters are removed. In addition,
the use of leaded gasoline fouls the oxygen sensor and other parts of the engine so that the benefits
of the technology are being lost. So, despite the fact that Egyptian new vehicle buyers are already
paying for the emission controls, the benefits to them and society are lost. We recommend that the
supply of unleaded gasoline be increased as quickly as possible and that tampering with imported
vehicles be made illegal and stopped when the supply is sufficient.
In addition, we recommend that the GOE adopt U.S. new vehicle standards as soon as is
feasible. The European Countries have a wide variety of standards that Egypt could choose from
in addition to the U.S. standards, but we do not recommend doing so. We believe that the
Page 5 New Vehicle Emission Standards
-------
advantages of OBD in terms of ultimate cost savings and improved performance make the U.S.
standards a better choice. Nevertheless, if the GOE feels a broader array of options are needed,
then further analysis of which of the European standards should be adopted. In any case, we
recommend that Egypt adopt the U.S. certificate, even if a weaker standard is adopted based on
European certification.
Policy Measures
The impact of new vehicle standards on air quality is a function of the rate at which new
technology vehicles will replace old technology vehicles in the Cairo fleet. Given the economic
situation in Egypt, we believe consideration needs to be given to various policy measures that will
provide incentives to vehicle owners to buy new vehicles and to retire old vehicles.
We understand that duties or tariffs on imported vehicles are currently upwards of 100%.
Naturally, the higher price that results from such tariffs cause demand for new vehicles to be lower
than it would be otherwise. Thus, we recommend that the GOE eliminate import tariffs on all non-
luxury vehicles. To offset the loss in revenue that results, we recommend an increase in the price
of gasoline. This would further add to air quality benefit by encouraging owners of existing
vehicles to better maintain them for fuel economy, to use them less, and to upgrade to a more
efficient vehicle in the future.
In principle, once Egypt adopts stringent new vehicle standards for all imported vehicles,
and these standards are enforced, total emissions should begin to drop immediately. As these new
vehicles enter the fleet they will likely replace newer and middle aged vehicles owned by the more
affluent. Those vehicles will typically lose relative value as the market shifts more towards less
expensive, new imports. Then those vehicles will become available and relatively more affordable
to owners of even older and dirtier vehicles. The result of this ongoing cycle is fleet turnover; the
oldest, least valuable, and often dirtiest vehicles are replaced by relatively cleaner vehicles. The
worst vehicles are then hopefully scrapped. Over time, as more clean vehicles enter the market, the
average levels of emissions will be reduced as newer, cleaner vehicles become a greater proportion
of the vehicle fleet. At least this is the process in the U.S. and other affluent countries. Our
observation and discussions with many a taxi driver indicate that length of vehicle ownership in
Egypt is much longer and that turn over rates are much lower than in affluent countries.
We recommend that the GOE explore means to accelerate the fleet turnover process. There
are a variety of measures to do this. One approach is to increase the cost of older vehicle
ownership. This can be done by making the annual registration fee a function of age. The older
the vehicle the higher the fee. This neglects, of course, the fact that not all old vehicles are equal
when it comes to pollution. Another approach would be to set the fee based on a combination of
age and emission rates. However, the idle emission test contemplated for Egypt is not accurate
enough to provide discrete information on the relative pollution rates from vehicles in the fleet. A
third approach would be to modify the first approach by establishing the age based registration fee,
but then allow a lower fee if a motorist shows through and IM240 test that the emission rates on
the vehicle are lower than expected. This would require, of course, additional IM240 test capacity
than is envisioned for the I/M program discussed in Section V. A fourth approach is to raise the
cost of gasoline. This has three impacts: it reduces vehicle kilometers traveled, it encourages
maintenance to reduce fuel consumption (which will generally reduce emissions as well), and it
encourages scrappage of older vehicles. Fifth, vehicle scrappage programs, in which the GOE
would actually buy old high emitting vehicles and scrap them, would help remove gross emitters
from the fleet. This approach is also discussed in Section V as a mitigation measure for low
income vehicle owners faced with the high cost of repairing gross emitters.
As discussed previously, it is absolutely crucial that unleaded fuel be made available for use
in new vehicles so that there is no fouling of critical emissions components. We recommend that
Page 6 New Vehicle Emission Standards
-------
the GOE promulgate regulations that bar tampering with emission control devices and putting
leaded fuel into catalyst equipped vehicles. Furthermore, unleaded fuel should be sold at prices
lower than leaded fuel so that there is no economic incentive to misfuel these vehicles. Even
vehicle owners not required to fuel their cars with unleaded are likely to switch from leaded,
resulting in further lead reductions.
Page 7 New Vehicle Emission Standards
-------
IV. Fuel Volatility Control
Introduction
Evaporative emissions are a major source of VOCs from motor vehicles. Evaporative
emissions occur when gasoline forms into a vapor and escapes from the vehicle either while
running or resting or during refueling. Evaporative emissions are directly influenced by the
volatility of the gasoline and ambient temperature. The higher the volatility and temperature, the
higher the evaporative emission rates, and vice-versa. It is clear, however, that high volatility is
not needed for good vehicle engine performance. Given the year-round high temperature in Cairo,
and the lack of evaporative emission control systems on vehicles, evaporative VOC emissions may
be the largest source in the City. We recommend that Egypt lower the RVP of gasoline to 6.8 psi,
as soon as the refining changes can be made to achieve this level.
The processes used to lower RVP will result in extra refinery costs in the processing and
blending of the fuel. The most cost effective method is simply to not add the extra butane normally
added to boost octane and fuel volume, or to further debutanize the fuel. EPA estimates that 20%
to 40% of butane added to fuel will evaporate and never make it to the combustion process.
Depending on the level of butane present in the fuel, special debutanizing equipment may needed to
lower fuel below 8.0 psi RVP. In order to lower levels further to 7.0 and possibly 6.8 psi, most
of the butanes and some of the.pentanes have to be removed by operating the fractionators to cut
deeper. Additional debutanizers and depentanizers may need to be installed as well. There are two
negative impacts of such processes which will increase costs further: lowered octane levels and
reduced fuel volume.
Octane is a measure of a fuel's ability to resist premature auto-ignition, better known as
knocking. To make up for the lost octane, refiners would have to add methyl tertiary butyl ether
(MTBE), methanol, ethanol or other high octane, low "RVP components such as toluene, xylene,
and alkalyte. Refiners could also increase reformer severity or move to fluidized catalytic cracking
catalysts which produce higher octane. To make up for lost volume, refiners would need to
increase refinery capacity utilization.
Economic Costs and Benefits
The cost associated with RVP reduction measures in the U.S. add an estimated 1 to 6 cents
(U.S. dollars) to each gallon of fuel produced. This cost is based on the cost of retooling the
refining process to include debutanizers and depentanizers, to add extra butane storage facilities,
and to increase refinery capacity utilization. Part of this cost can be offset at the refinery as the
butane which would normally have to be sold, could be used as a feed stock for MTBE production
or as a fuel for other refinery processes.
EPA estimates the increased fuel cost to consumers, of a low-RVP program operating
during the 5 warm months each year, to be about $15 over a vehicle's lifetime. Year-round
measures in Cairo should then only increase costs to less than $35 per vehicle lifetime.
These costs would be offset to a large degree by the savings associated with the increased
fuel economy of a more energy-dense fuel (estimated at up to a 0.5% increase) and by the saving
of fuel normally lost to evaporation. EPA estimates these savings to be over $6 per vehicle
lifetime, resulting in a total net cost of about $8. For Cairo, this would translate to a total net cost
of less than $20 per vehicle lifetime. The total cost effectiveness of RVP control has been
estimated to range from $200 to $600 per ton of VOC reduced.
Page 8 Fuel Volatility Control
-------
Environmental Costs and Benefits
Lowered RVP fuel will have an immediate and dramatic effect on air quality in Cairo.
Volatile organic compounds (VOCs) which cause ground level ozone will be reduced by the
significant levels described in the Phase I report. Additionally, VOC reductions will be achieved
from all gasoline powered vehicles of all ages, many of which might not normally be subject to
I/M. Further reductions will be achieved from gasoline-related stationary sources and at fuel
transfer locations. Other pollutants associated with gasoline combustion, such as CO and NOx,
will be reduced as the improved fuel economy of low RVP fuel means less fuel will be consumed.
There is insufficient data to estimate each of these benefits.
The removal of butanes and the blending of new components raises a number of concerns
on the environmental or public health impact of low RVP fuel. Debutanization will leave a
relatively greater concentration of benzene (a known carcinogen) and other aromatics. The loss of
octane would require the addition of other components, as noted previously, some of which have
questionable carcinogenic linkages. EPA studies do show that while exposure to mobile source
emissions can be linked to incidence of human cancers, RVP control will not have any significant
impact in this regard. Each of these issues are cause for further study.
Page 9 Fuel Volatility Control
-------
V. Inspection and Maintenance
A. Introduction
In our Phase I report, we discussed the benefits and costs of alternative I/M program
designs. In this report, we will make specific recommendations for implementation of the Vehicle
Emission Testing and Tune-up Program, hereafter referred to as the I/M program. We also
performed an assessment of the Executive Regulations, which is included in Appendix A. Our
approach used the report, "Technical Analysis, Vehicle Emission Testing and Tune-up Program,
Cairo Air Improvement Project, Annex C," written by Dr. Gerald Gallagher, Ph.D., as a starting
point. We also made use of the data collected in the pilot study performed by Dr. Taha El Shafei of
Mirage.
This report covers a range of critical program decisions that U.S. AID and Egyptian
Environmental Affairs Agency (EEAA) will need to make in the near future. The fundamental
question of network type is the most important structural question but other issues such as
enforcement are vital to the effectiveness of the I/M program.
B . Network Type
The experience with I/M over the past 20 years has shown that network type can have a
profound influence on the success of an I/M program. There are three basic options: centralized,
decentralized, or hybrid. A centralized network consists of a small number of high-volume
stations that only do testing. A decentralized network consists of a large number of low volume
stations that may do both testing and repair. A hybrid program incorporates both high-volume,
test-only stations, as well as low-volume repair and retest stations.
The centralized network is the least expensive approach. Centralized networks can achieve
significant economies of scale in terms of inspector training, quality control, equipment purchase,
facility utilization rates, and so on. As a result, centralized testing generally costs about half as
much as decentralized testing. Decentralized testing, on the other hand, offers the advantage of
linking the test to the repair process. The repair technician can use the emission analyzer to check
the effectiveness of the repairs performed and make additional repairs if needed to meet standards.
Decentralized networks facilitate the maturation of the repair industry, providing a profit incentive
for acquiring the skills needed to perform emission-related repairs. This advantage is particularly
important in areas in which the repair industry is not well developed, which seems to be the case in
Egypt. The hybrid approach combines the best of both network types. The standard approach is
for all initial tests to be conducted at high-volume test-only stations. Most repairs and retests are
performed at decentralized, test-and-repair stations. The hybrid approach achieves the economies
and quality control for the bulk of the testing - the initial test, while also stimulating the repair
industry by allowing repair shops to perform official retests. This approach also minimizes
inconvenience in two ways: the 65% of motorists that will pass the initial test get rapid, efficient,
and objective testing in the centralized format and then are done. Most of the motorists that fail the
initial test avoid the inconvenience of returning to the centralized test station after repair for a retest.
We recommend that Egypt implement a hybrid program in Greater Cairo. We also
recommend that a single contractor be hired to run centralized stations and to oversee and support
the decentralized stations. The details on the capacity needs of the program were discussed in our
previous report, entitled "Mobile Source Emissions in Cairo, Egypt and Impact of Control
Measures." The findings with regard to the hybrid network are excerpted in Table 1 below.
We estimate that approximately 9 high-throughput, 4-lane stations designed and
constructed by a single contractor specifically for the purpose of production-line testing will
provide sufficient capacity to test the nearly 720,000 vehicles subject to the I/M program in greater
Page 10 Inspection and Maintenance
-------
Cairo. Modification of existing facilities is conceivable if sufficient queuing space, lane length,
and other features are available and cost-effective. We did not attempt to assess the potential
infrastructure in Cairo for this purpose. In addition to performing all initial tests, centralized
facilities should perform retests on about 20% of the failed vehicles (about 7.7% of the fleet) for
the purposes of quality control, dispute resolution, and data collection. We also estimate that
approximately 80 low throughput, repair-and-retest stations will be needed to perform retesting on
the other 27% of vehicles that will fail the initial test annually.
Table 1
Estimated Capacity Needs of a Hybrid Test Network in Cairo
Hybrid Network
Facilities
Number of Lanes
Number of Stations
Annual Test Volume
Initial Tests Per Lane
Retests Per Lane
Total Tests Per Lane
Tests Per Lane Per Day
Tests Per Lane Per Hour
Inspection Labor
Hours Per Day
Inspectors Per Lane
Total Number of Inspectors
Oversight
Annual Number of Audits
Number of Full Audit Days
Centralized
Test-only
35
9
20,504
1,563
22,067
81
9
9
3
70
105
35
Decentralized
Repair and
Retest
80
80
0
6,250
6,250
23
3
6
2
500
240
80
C. Program Management
There are a several approaches to managing the I/M program in Egypt. The most
successful approach used in the U.S. is where the government agency in charge contracts out for
the testing services and carefully oversees contractor performance. To achieve the best results, a
detailed, performance-based, Request for Proposals (RFP) is issued and the bidder with the best
combination of relevant experience, technical proficiency, network design and capacity, program
features, and low cost is selected. We recommend that this approach be used in Cairo as well.
Appendix F contains examples of RFPs used by states in the U.S. for this purpose. Note that the
Texas RFP, which is included in the Appendix, required the prime contractor to sub-contract to
independent small, businesses in Texas that would actually own and operate the test stations. The
prime contractor constructed and equipped the facilities, trained the sub-contractor employees, and
oversaw the network. While this approach adds cost it also provides a mechanism for local
business involvement in the program. Other mechanisms can be used to ensure local business
participation as well, such as awarding extra points in the bid evaluation criteria for the use of local
businesses for various aspects of the project.
Page 11
Inspection and Maintenance
-------
The contractor should be required to build enough centralized test facilities to provide
convenient and economical testing services to Egyptian vehicle owners. This role should include
finding and securing conveniently located sites for centralized test stations (either existing facilities
or vacant property), determining the number of facilities needed, determining the number and
configuration of lanes in each facility, and designing, installing, and maintaining the hardware and
software needed for testing. By placing the responsibility on the contractor for designing the
network, the contractor can then be held responsible if problems arise with the capacity of the
system or the integrity of the hardware and software.
The contractor should also be required to manage program operations. This approach
avoids the need for EEAA to hire and train the many employees to perform this function. This role
should include hiring, training, and supervising personnel; conducting all centralized test
operations; collecting test fees from vehicle owners; collecting and analyzing test data;
maintaining quality results through statistical process control of all testing processes; and,
reporting to EEAA on the results of testing, the cost of the program, the benefits achieved, and
recommendations for future changes to the program.
The contractor should also be required to select, upgrade, equip, and audit decentralized
retest facilities. The RFP should specify that the contractor create a fair and open process for the
selection of retest facilities, including establishing written criteria for qualification as a retest
facility. One problem that may arise is that some potential retest facilities do not have adequate
infrastructure to conduct testing. The contractor could be responsible for assisting candidate
stations in evaluating their needs with regard to electrical capacity, physical structure, and
telephone lines needed to conduct testing. To reduce the cost of retest facility equipment, the
contractor should be required to provide and maintain the analyzers used for retests. The retest
facility owner should pay for the maintenance so as to provide an incentive to properly care for
these machines. The contractor should also supply retest facilities with official test certificates,
calibration gases (at cost), and any other consumable items related to the testing function. The
contractor should also collect data from retest facilities, preferably through computer modem
communications, and prepare the data for analysis and conduct routine analyses for EEAA. The
contractor should be responsible for auditing repair-and-retest facilities, including both covert
audits and overt audits, and reporting the findings to EEAA for action as needed.
In order to operate effectively, repair and retest facilities will need both trained repair
technicians and trained inspectors, which may or may not be the same person. Inspector training
needs to cover the need for the program, use of the analyzer, and conduct of official retests. In
terms of repair technician training, the contractor should be responsible for assisting automotive
training and vocational schools to upgrade their curricula to cover emission-related functions. This
should include providing a course curriculum on emission diagnosis and repair and training
Automotive Training Center and Vocation School trainers in the new curriculum. The contractor
should also provide emission analyzers, tools needed for diagnosis and repair of I/M failures, and
reference materials to a select number of vocational schools and training centers so as to infuse a
few key schools with the capabilities needed to service the demand for emission related training.
Finally, the contractor should locate, design, construct and operate a research/training
facility. The facility should include at least one IM240 test lane for the purposes of collecting
accurate information on transient mass emissions of vehicles in Cairo. The contractor will need to
hire and train personnel to conduct testing and to recruit vehicles for IM240 testing. In addition to
the IM240 lanes, the facility should include one standard test lane to provide for inspector training
and classroom space for inspector and repair technician training. The facility should be staffed by
master repair technicians to assist in-field repair technicians with particular problems, to provide
special training programs, to disseminate repair information, and to act as a resource for repair
technicians. Finally, these master technicians could certify automotive repair technicians through
the use of standardized tests.
Page 12 Inspection and Maintenance
-------
The EEAA role in the program should consist of oversight of the testing contractor,
coordination of the enforcement program, and enforcement of the smoking vehicle requirements.
We recommend that the GOE provide EEAA the resources and staff needed to direct contractor
operations, audit test facilities both overtly and covertly (or this could be a separate contract),
review contractor reports and data analyses, and direct contractor operations as needed. EEAA will
also need to manage air pollution program policy with regard to the I/M program. This would
include periodically revising motor vehicle emission standards and other program features, and
analyzing program impacts and adjusting program requirements for continuous improvement. To
this end the contractor should be required to supply EEAA at least one if not several terminals from
which EEAA staff can access the I/M database to conduct specialized analyses.
EEAA should also coordinate enforcement of the I/M requirement. This issues is discussed
further in the section on enforcement. Likewise, EEAA should be involved in the enforcement of
smoking vehicle rules. This is also discussed in a separate section below.
D. Test Type, Emission Standards, and Phase-In
The vehicle fleet in Cairo is primarily composed of vehicles without any emission controls.
The exact nature of the fleet is unknown and it should be one of the priorities of the technical
center, discussed in the previous section, to collect data on the nature of engine and emission
control technology in the Cairo fleet. Based on this assumption, we recommend the use of an idle
test. Appendix I contains the recommended test procedure for the idle test.
The emission standards contained in the Executive Regulations are 7% at idle for carbon
monoxide and 1000 ppm at idle for hydrocarbons. Based on the data collected in the pilot study
performed by Mirage, we estimate that these standards will yield an initial failure rate of
approximately 35%. Given this, we believe that these standards are practical and realistic. This
level of failure is typical of U.S. inspection programs for similar technology vehicles. These
standards will yield substantial reductions in the emissions of carbon monoxide (about 20%-35%
depending on network type) and smaller reductions in exhaust hydrocarbons (about 5-10%).
Oxides of nitrogen may increase as a result of the program.
We recommend that, in addition to the tailpipe emission test, that all vehicles be inspected
for the gasoline cap on the fuel inlet. If the gas cap is missing or does not fit properly, then the
vehicle should be failed and the owner required to purchase a new gas cap. While missing gas
caps are not common, this check is easy and quick and will help reduce evaporative emissions. .
Since Egyptian motorists have never experienced any type of periodic inspection program
prior to this time, it is important to introduce the I/M program before the requirement to comply
goes into full effect. We recommend that the program operate in a voluntary mode for at least one
month, if not more. This will give the contractor and the inspectors time to get used to the job and
to work out any start-up problems in the operation of test equipment and facilities. Some states in
the U.S. have also used mandatory test/voluntary repair phases to introduce the program. Under
this approach motorists are required to come in for testing but do not have to get repairs.
Typically, this phase lasts for one complete test cycle, in the case of Cairo, for one year.
The other phase-in issue relates to the emission standards. As stated above, the emission
standards in the Executive Regulations for "in-use" vehicles are fine for the first test cycle (year).
We recommend that, based on data collected over the first 6 months of the program, the second test
cycle standards be adjusted to achieve two objectives: increase the failure rates for high
hydrocarbon emitters, if necessary at the expense of carbon monoxide failures, and to maintain a
35% failure rate. The reason for this is that the CO standard is more stringent in its effect than the
HC standard. Our analysis of the Mirage data indicates that about 17% of the cars will fail for HC
and 25% will fail for both (note that these figures are not additive, some cars fail for both). Given
Page 13 Inspection and Maintenance
-------
the warm climate in Cairo, the ozone problem is probably the more serious problem, making HC
control of at least equal importance. Once adequate data from the program are available, the
emission standards can be calibrated to achieve parity between HC and CO. The standards should
also be stratified by age and possibly vehicle type (car versus truck). Another consideration would
be to stratify the standards by technology if a clear technological pattern exists in the fleet. For
example, fuel injected vehicles may be able to meet tighter standards than carbureted vehicles.
Similarly, computer-controlled, closed-loop vehicles may be able to meet tighter standards than
open-loop vehicles.
As discussed in Appendix A, the standards for new vehicles are inadequate. We
recommend that new light duty car and truck idle emission standards be lowered to 1% CO and
200 ppm HC. Vehicles imported into Egypt that otherwise meet U.S. or European new vehicle
standards, except that catalytic converters are removed, will be able to meet these standards.
Vehicles meeting these standards can be waived from the testing requirement for the first four to
six years of the vehicle's life, since new vehicles that meet U.S. or European certification
standards tend to fail at very low rates up to about 4-6 years old. Vehicles either imported into
Egypt or manufactured in Egypt that do not meet U.S. or European certification standards should
be tested prior to sale at the test-only stations.
"In-use" standards for these vehicles should also be based on data collected after
introduction of the requirement. It is unlikely that the 1 % CO/200 ppm standard will be feasible
once these vehicles are fueled and operated with leaded gasoline for some time. We strongly
recommend, as discussed previously in this report, that the price of unleaded gasoline be set lower
than that of leaded gasoline to encourage motorists to use the unleaded fuel. New car owners
would be especially prone to use unleaded because it reduces engine wear and tear and associated
maintenance costs. Again, data collected during the first 6 months of the program will allow
EEAA to set standards appropriate to the actual mix of technology that exists in the Cairo fleet.
E. Onboard Diagnostic Systems
In the last two decades, there have been considerable emission control technology
developments on the part of the U.S vehicle manufacturers and federal government to produce
vehicles with lower emissions. However, although manufacturers have achieved significant
reductions in the emissions of properly functioning, new vehicles, in-use deterioration is still a
major problem. Emission related malfunctions do not always cause an outward indication of a
problem, for example in the form of poor driving performance or large decreases in fuel economy.
As a result, emission related failures usually go unnoticed and are not repaired.
A newly required technology on new vehicles in the U.S., is an onboard diagnostic (OBD)
system which is a technology that monitors emission-related components for malfunctions or
deterioration which would cause vehicles to fail emission standards. The on-board diagnostic
system will be capable of identifying catalyst deterioration, engine misfire, oxygen sensor
deterioration, and any other deterioration or malfunction within the power train which could cause
emission increases greater or exceeding the certification standard by about 150%. When the OBD
system detects such failures, a malfunction indicator light (MIL), located in the dashboard of 1996
and newer cars, will be illuminated. The MIL must remain illuminated during all periods of engine
operation until the trouble codes stored in the on-board computer are cleared by a repair technician
or after repeated revaluation by the OBD system fails to detect a reoccurrence of the problem.
Codes indicating the likely problem will be stored in the vehicle's on board computer for ready
access by technicians, enabling proper diagnosis and repair. OBD systems allow an inspector to
scan for stored malfunction codes at the time of the I/M test by simply attaching a computerized
scan tool to the standardized plug provided on all OBD equipped vehicles. '
The test procedure for OBD is very simple, quick, reliable, and inexpensive, compared to
Page 14 Inspection and Maintenance
-------
tailpipe emission testing, visual checks, or functional tests. After establishing that a vehicle is
equipped with the OBD system, a standardized plug is inserted into the dashboard and the scan tool
computer interrogates the vehicle's computer to retrieve and record any trouble codes that are
stored. An automatic pass/fail decision is made in seconds based on the findings.
As a replacement for idle emission testing, OBD checks are a superior alternative both in
terms of cost and capability (note that it is not clear whether OBD checks will be as good or better
than IM240 testing). In addition to being less expensive a testing mechanism, the stored codes
give repair technicians specific information on the nature of the problem with the vehicle, which
should substantially reduce the time and cost of diagnosing the problem. Thus, we recommend
that Egypt adopt standards requiring OBD systems new cars and that OBD checks be done in lieu
of idle emission tests on these cars.
F. Waivers
Most vehicles that fail the tailpipe emission test can be repaired with adjustments to the
carburetor, replacement of spark plugs, or the like. Some vehicles, however, will require major
engine repairs, such as a complete overhaul, a valve or ring job, etc. in order for emission levels to
be brought into compliance. These repairs can be very expensive and, if looked at in terms of
marginal cost per kilogram of emission reduction, they are not cost-effective. Nevertheless, some
states in the U.S. have chosen to require motorists to repair or scrap such vehicles. Other states
have allowed motorists that spend a certain amount of money on emission related repairs to operate
a vehicle even if it does not meet emission standards. While this approach mitigates the economic
impact of the program, it also reduces the emission reduction benefits. Waivers both help and hurt
public acceptance of the program. Waivers pacify those who would otherwise have to pay a large
sum of money for repair. Motorists that do pay for repairs or pass the initial test resent the fact that
other vehicles are not required to comply.
We do not recommend the use of waivers in the Cairo I/M program. The air pollution
problem is severe enough that high emitting vehicles should not be tolerated. In order for such a
policy to be practical, however, mitigating measures might be necessary. There are three
measures, one or all of which could be used. The first measure would be to give vehicle owners
faced with high repair costs more time to get repairs made, so that they can save the money needed.
This measure focuses on the potential economic hardship that high repair costs could impose.
Often times, the repairs could be made once enough money was saved to make them. The second
measure would be to provide repair cost subsidies to low income motorists faced with high repair
costs. The research/training facility staff would make the determination as to which vehicles are
worth repairing, whether owners were eligible for a subsidy, and how much money would be
granted. The third measure would be to provide cash incentives to scrap such vehicles. A
scrappage program has the advantage of getting older, high-emitting vehicles off the road all
together. Eligibility requirements for the scrappage program should include all of the conditions
discussed below for getting a waiver. In addition, the vehicle should be driveable and registered in
the Cairo area for some time (to prevent the influx of scrappage-eligible vehicles from other parts
of Egypt). It is essential, of course, that vehicles purchased in the scrappage program actually be
retired from the fleet. The scrappage incentive and the repair subsidy could be financed through a
higher test fee in the I/M program.
If EEAA decides to employ a waiver system, then careful management of the issuance of
waivers is needed to achieve low waivers rates and prevent abuse of the system. No more than 5%
of failed vehicles should be given waivers; beyond this, the I/M program looses its cost-
effectiveness. Waivers should only be issued at the research/training facility. Strict eligibility
criteria should be established for waivers. Those criteria should include: proof that a certified
repair technician has performed only emission related repairs and that the required amount of
money was spent. The basis for each waiver should be carefully documented to reduce the
Page 15 Inspection and Maintenance
-------
opportunity for fraud. Waivers should only be valid.for one year. The vehicle should be inspected
by a trained technician at the research facility to determine that claimed repairs were actually made
and that there are no other reasonably priced repairs available to bring the vehicle into compliance.
G . Compliance Enforcement
Introduction
Compliance enforcement is the system put into place to insure that vehicle owners actually
bring vehicles to a test station to get tested and then get repairs and retests if they fail. This is a
most critical element of the program and also a most difficult one. If the compliance enforcement
mechanism is not very effective, then motorists faced with the cost of repairs will simply not get
tested. Obviously, this defeats the whole purpose of the program. Testing clean cars does not
change anything; only repairing or removing high emitting vehicles reduces fleet-wide emissions.
There are three compliance enforcement systems: registration denial, windshield stickers,
and record matching. These three systems vary in effectiveness and cost. They will be discussed
in some detail in the following sub-sections. We recommend that Egypt employ a combined
system consisting of record matching and registration denial, with the latter method being the
primary enforcement mechanism and record matching being a back-up measure. The reasons for
this will be discussed below.
Windshield Sticker Enforcement
This enforcement mechanism consists of placing a plastic sticker in the windshield to show
that a vehicle is in compliance. Enforcement occurs when a police officer identifies a vehicle that
has either no sticker or an expired sticker. The vehicle would then be impounded or a traffic ticket
would be issued and the motorist would pay a fine and be required to complete the testing process.
Failed vehicles are issued a sticker that indicates the vehicle has been tested and failed and is in the
process of getting repairs. The failed vehicle sticker should be easily distinguished from regular
stickers by making a contrasting bright color for example. It is important that stickers be easily
spotted and readily identified as being out of date. This is usually accomplished through a
combination of sticker color (a different one for each calendar year) and the number of the month
that the sticker expires. This high visibility increases the opportunity for police and other
enforcement officers to spot a non-complying vehicle.
Sticker enforcement has historically performed badly in the U.S. and we do not
recommend its use in Egypt. The sticker system relies solely on police efforts to stop and ticket
motorists only because they did not complete the testing process. Thus, the police must be
convinced that the program is worthwhile and it is worth their time to enforce it. That is not
always an easy task. Another problem is counterfeit and stolen stickers. These are both significant
problems in the places in the U.S. that use sticker enforcement. Obviously, there is also a cost
associated with stickers. They must be produced and distributed and carefully handled to prevent
unauthorized distribution. This adds another layer to the auditing and oversight requirements of
the program.
Another problem that reduces policy incentives to enforce is that it is difficult to determine
if a car is without a sticker is required to be tested. For example, a motorist visiting from
Alexandria would not have a sticker and could be mistakenly accosted. When the police realize this
problem, it tends to reduce willingness to enforce the program.
Registration Denial
Registration denial works by rejecting an application for initial registration or re-registration
Page 16 Inspection and Maintenance
-------
of a vehicle that does not have a certificate of compliance (or a waiver, if allowed). This system
tends to work very well in the U.S. for several reasons. First, the police can tell by looking at the
license plate on a car whether the registration is current. When a vehicle owner registers a vehicle a
tab is issued that indicates the year of expiration of the license plate. The license plate already has a
tab indicating the month of registration (generally the birth date of the owner). So, it is obvious by
looking at any license plate whether the registration is current. Second, the police are more willing
to enforce vehicle registration requirements because registration fees generate revenue for local
government, the registration system provides a mechanism for dealing with stolen vehicles, and
similar law and order functions appealing to police. Third, the police are no longer enforcing the
air pollution requirement but rather the vehicle registration requirement. This is an important
difference since the police do not need to be convinced of the efficacy or the necessity of the I/M
program. Fourth, the vehicle registration office makes the determination about whether a vehicle is
required to have a certificate of compliance. This shifts the burden from the police, making it
easier for them to focus on the single problem of registration compliance.
Our observation in Cairo is that license plates do not currently have tabs put on them
indicating when the registration of the vehicle expires. These tabs should be required in the future
so that police can make the proper distinction between registered and unregistered vehicles,
In order for registration denial enforcement to work properly, a test schedule must be
adopted that clearly determines when a vehicle is required to be tested. We recommend that
motorists be required to be tested by the date of the expiration of the vehicle registration. The
motorist should be required to present a certificate of compliance to the registration clerk at the time
of registration. (A preferred alternative is to have the computer system in the I/M program
automatically update the Traffic Authority computer system indicating that the vehicle is in
compliance. This avoids the problems of counterfeiting and simply losing the certificate. We
realize however, that it may be some time before the Traffic Authority has fully automated the
registration system.) Since the certificate of compliance is a valuable document, measures need to
be taken to prevent fraud, counterfeiting, and graft. The registration clerk should retain the
certificate of compliance and attach it to the registration form that is placed in the Traffic Authority
files for future auditing. The certificate should also clearly identify the vehicle and the owner so
that certificate switching cannot occur. Similarly, it is important that the vehicle be properly
identified when it arrives at the test station so that a clean vehicle is not used in place of the vehicle
for which a certificate of compliance is needed. Checking the license plate alone is not enough
since it is easy enough to temporarily move a license plate from one car to another. The vehicle
registration should be checked as well, to make sure license plate and vehicle match.
Record Matching
Since Egypt allows motorists to register vehicles for up to three years at once, the
registration denial system will not be fully effective for vehicles that take advantage of this option.
While it is apparently not frequently used, the three year registration could become more popular if
it were seen as a way to avoid inspection. Thus, we recommend that record matching be used as a
backup to registration denial.
Record matching works by matching vehicle registration records with I/M records. In this
case, this would only need to be done for vehicles that acquire three year registrations. We
recommend that the Traffic Authority send EEAA a list every six months, preferably on computer
disk, of the vehicles that obtain a three year registration. EEAA's contractor should use this list to
notify 3-year registrants in advance of the test anniversary that they are required to come in and get
tested by the anniversary date. Then the contractor should monitor the test station activity for these
vehicles and send a follow-up notice to vehicle owners that fail to get tested. This second notice
would warn the vehicle owner that failure to get tested will result in enforcement action. We
recommend that the vehicle owner be given 30 days to comply, after which a fine be imposed and
Page 17 Inspection and Maintenance
-------
the three year registration be revoked. Vehicle owners that do not get tested at the first or second
anniversary should also be denied three year registrations in the future. There are two ways to
impose the fine and revoke the registration. The quick way is for the police to go to the vehicle
owner's residence and remove the license plate from the vehicle and issue a fine. The slow but
cheaper way would be to send the vehicle owner a notice indicating that the vehicle registration has
been suspended and if the vehicle is found operating on the road, it will be impounded. The police
would be given lists of vehicle license plates that have been suspended so they can watch out for
them. If the vehicle is never caught on the road, then when it is due to be reregistered at the three-
year point the motorist would then pay a fine and only be allowed a one-year registration. This
second option has the disadvantage of letting a potentially high emitting vehicle operate for some
time on the roads and may promote avoidance of the registration system altogether.
Quality Assurance
There are additional safeguards needed to insure that the enforcement mechanism works in
practice. Motorists will look for ways to avoid compliance. It is essential, therefore, for the
enforcement system to prevent avoidance to the extent possible. There are several strategies that
need to be employed. First, vehicle owners must be prevented from avoiding testing through
manipulation of the title or registration system. For example, in the event that diesel vehicles are
not tested (see discussion later in this report) vehicle owners should not be allowed to declare that
the vehicle is diesel powered without some proof or verification that this is so. This could be done
by requiring diesel vehicles to be checked at the centralized test facilities and then granted a diesel
verification form. This would be a one-time exercise. Another issue relates to title transfer. One
possible way to avoid annual testing is to transfer the title of the vehicle, or in other words, to sell
the vehicle. To avoid this manipulation, all vehicles should be required to be tested prior to sale.
Second, any change in registration address from the I/M area to a non-I/M area should be verified
through some other means. By changing the address on the registration, say to a relative's address
in another city, the vehicle owner can avoid inspection even though the vehicle will still be operated
in Cairo. Requiring proof of the move such as employment information, home ownership or rental
information, or similar documentation that the owner has actually moved is necessary.
Since registration clerks will be in the position of deciding whether to issue a registration to
a particular motorist, safeguards are needed to prevent and detect corruption of this function. We
recommend that EEAA or the Traffic Authority regularly audit the records kept by registration
clerks to insure that a valid certificate of compliance accompany each registration record.
Procedures for disciplining, retraining, or removing registration personnel who deviate from
protocols need to be established.
Care needs to be taken to prevent the theft or improper issuance of certificates of
compliance. These documents should be kept in secure locations, serially numbered, and tracked
and audited routinely. Repair and retest stations should be held liable for missing documents by
assessing monetary fines reflecting the "street value" of a certificate.
Finally, the effectiveness of the enforcement system needs to be measured on an ongoing
basis. Random roadside pullovers of a statistically significant sample of vehicles to determine
compliance is probably the best mechanism for achieving this.
H. Inspector Training and Certification
There are two types of training critical to the success of the I/M program: inspector training
and repair technician training. Inspectors and repair technicians are both on the front line in the I/M
process. Inspectors not only conduct the tailpipe emission test, they serve a wide variety of
functions. For example, inspectors are the first primary contact with the program's customers.
How motorists react to a program will depend in part on the professional behavior of the inspector
Page 18 Inspection and Maintenance
-------
and the inspector's ability to perform the test and answer questions and handle problems. Thus,
inspector training and certification is an extremely important feature of any I/M program,
We recommend that all vehicle inspectors receive formal class room and hands-on training.
Inspectors should also be issued certificates that permit them to perform testing. These certificates
should be revoked or suspended in the event an inspector fails to perform the job correctly.
Inspector training should include more than how to insert a probe into the tailpipe. We recommend
that the training course cover:
a) Air pollution causes and health effects,
b) The purpose, function and goals of the inspection program,
c) Inspection regulations and procedures,
d) Technical details of the test procedure and the rationale for the design,
e Test equipment operation, calibration and maintenance,
f) Quality control procedures and their purpose, and
g) Safety and health issues related to the inspection process.
In order to complete the training requirement, a trainee should pass a certain percentage of a
written test covering all aspects of the program. In the U.S, this figure is 80%. In addition, a
hands-on test should be administered in which the trainee demonstrates, without assistance, the
ability to conduct a proper inspection, to utilize equipment, and to follow other procedures.
Inability to properly conduct the test should result in retraining. Completion of inspector training
and passing required tests should be a condition of certification. We also recommend that
inspector certificates be valid for no more than 2 years, at which point refresher training and testing
should be required prior to renewal.
I. Repair Technician Training and Certification
Repair technician training and certification is a vital element of the I/M program. The
importance of technician training cannot be over-emphasized. The proficiency of repair technicians
will determine the extent to which lasting repairs are made on vehicles that fail the test. There are
two ways to meet the I/M requirement: to fix the vehicle so that it passes the test or to repair the
vehicle so that it has low emissions and good performance. The I/M program must strive to
achieve the latter goal. It is easy enough for a repair technician to lean out the carburetor on a car
so that it will pass an emission test. Unfortunately, such repairs are often quickly undone since
simply leaning out the carburetor may result in poor vehicle performance (stalling, lack of power,
etc.). This is where training and certification come into play.
Measuring exhaust emissions is only the first step. Identifying faults and performing
competent repairs is the essence of the process leading to properly tuned, low emitting, fuel
efficient vehicles. Identifying emission related repairs is not just related to driveability and herein
lies the complexity. Currently, a typical vehicle owner wants the car to perform well but does not
care about or even think about emissions - unless they are visible. Vehicle owners do like good
fuel economy, however, and to the extent these two preferences can be linked, so much the better.
In any case, low emission performance is not something customers come into repair shops looking
for. As a result, the training, tools, and resources needed to properly diagnose and repair emission
related failures is absent from the market in Cairo, except as it relates to driveability.
We recommend that the first actions taken to establish and I/M program in Cairo is to begin
the process of getting sufficient numbers of repair technicians trained in the proper diagnosis and
repair of vehicles that fail the I/M test. We recommend that the contractor work with vocational
schools in Cairo to upgrade the training programs, curricula, and equipment on hand so that these
schools are capable of providing the kinds of training needed. In-service training programs as.well
as vocational training should be available. Training should include all of the topics listed for
Page 19 Inspection and Maintenance
-------
inspectors above but with the addition of detailed understanding of engine technology, emission
formation, diagnosis and repair.
As discussed above, the research/training center should serve as a resource for repair
technicians. When they have a vehicle they cannot diagnose or repair correctly, the center should
have staff available to provide assistance either over the phone or in person at the center. The
center should also be responsible for regularly informing repair facilities of changes in the
inspection program, training course schedules, common problems being found with particular
engine families, diagnostic tips, and other information that would facilitate the proper repair of
vehicles. The training center should also certify repair technicians. Certification should consist of
both a written test and a hands on demonstration of repair techniques (using a timing light, gapping
a spark plug, adjusting idle speed properly, etc.). Only repairs performed by certified technicians
should qualify for a waiver.
J. Quality Control
Quality control is an essential component of any I/M program because it ensures that
emission measurement equipment is calibrated and maintained properly, and that inspection,
calibration records, and control charts are accurately created, recorded, and maintained. We
recommend that EEAA adopt the quality control procedures in Appendix K for maintaining the
analytical equipment. This section will discuss other quality control functions not covered in the
Appendix. In general, alternatives or exceptions to the procedures or frequencies stated in
Appendix K should be allowed after a demonstration, including control chart analysis, of
equivalent performance.
Preventive maintenance on all inspection equipment is necessary to ensure accurate and
repeatable operation. We recommend that the contractor develop written procedures for both
centralized and decentralized stations.
Measures should be taken to maintain the security of all documents by which compliance
with the inspection requirement is established including inspection certificates, waiver certificates,
license plates, and license tabs. Compliance documents should be counterfeit resistant. Such
measures as the use of special fonts, water marks, ultra-violet inks, encoded magnetic strips,
unique bar-coded identifiers, and difficult to acquire materials may be used to accomplish this. All
inspection certificates, waiver certificates, and stickers should be printed with a unique serial
number and an official program seal. Measures shall be taken to ensure that compliance documents
cannot be stolen or removed without being damaged. This will foil attempts to remove license
plate tabs, for example.
Written procedures should be established for personnel engaged in I/M document handling
and processing, such as those involved in waiver processing and inspectors. The records and
performance of these personnel should be audited,
K. Quality Assurance
An ongoing quality assurance program is necessary to discover, correct, and prevent fraud,
waste, and abuse and to determine whether procedures are being followed, are adequate, whether
equipment is measuring accurately, and whether other problems might exist which would impede
program performance. The quality assurance and quality control procedures should be periodically
evaluated to assess their effectiveness and relevance in achieving program goals. There are three
basic audit functions that need to carried out: performance audits, equipment audits, and record
audits. Each of these is discussed below.
Performance audits should be conducted on a regular basis to determine whether inspectors
Page 20 Inspection and Maintenance
-------
are correctly performing all tests and other required functions. Performance audits include overt
and covert audits. A covert audit is performed when a vehicle is set to fail the emission test,
brought to the test station by a person pretending to be a regular customer, a test is purchased, and
the results analyzed after the fact. All the while, the test station personnel are not aware or should
not be aware of the fact that an audit is being performed. An overt audit is very different. It is
done with full awareness of the station personnel.
All performance audits should be based upon written procedures and the results should be
reported using either electronic or written forms and retained in inspector and station history files.
Performance audits should be conducted on a routine basis and based on suspicion that inspectors
might be violating regulations as a result of audits, data analysis, or consumer complaints.
Overt audits should be performed at least twice per year for each lane or test bay and should
include a review of document security, a check to see that required record keeping practices are
being followed, and observation and written evaluation of each inspector's ability to properly
perform an inspection.
Covert audits should include remote visual observation of inspector performance, using
binoculars or video cameras, if needed; site visits at least once per year per station using covert
vehicles set to fail the emission test; and, at least one covert vehicle visit per decentralized station
per year including the purchase of repairs and subsequent retesting to check on repair proficiency.
A vehicle recruitment program might be useful to accomplish this task. Another approach for
mitigating the impact of high cost repairs on low income motorists would be to trade use of their
vehicle for a short while for covert auditing purposes in return for free repairs.
Station and inspector records should be reviewed or screened at least monthly to assess
station performance and identify problems that may indicate potential fraud or incompetence. Such
review should include software-based, computerized analysis to identify statistical inconsistencies,
unusual patterns, and other discrepancies; visits to inspection stations to review records not already
covered in the electronic analysis (if any); and comprehensive accounting for all official forms that
can be used to demonstrate compliance with the program.
During overt site visits, auditors should conduct quality control evaluations of the test
equipment, including a gas audit of the analyzers using gases of known concentrations at least as
accurate as those required for regular equipment quality control and comparing these concentrations
to actual readings. Analyzers should also be checked for tampering, worn instrumentation,
blocked filters, leaks, and other conditions that would impede accurate sampling. The gas bottles
used for calibration purposes should be checked to see that they are properly labeled, within the
relevant tolerances, and of sufficient supply.
Obviously, all of the functions discussed above require auditors that have been formally
trained and knowledgeable in the entire program operation. In order to maintain an effective audit
program, auditors should themselves be audited at least once per year. This will help insure that
the audits are being properly performed. Training of auditors should include:
(i) The use of analyzers;
(ii) Program rules and regulations;
(iii) The basics of air pollution control;
(iv) Basic principles of motor vehicle engine repair, related to emission performance;
(v) Emission control systems;
(vi) Evidence gathering;
(vii) State administrative procedures laws;
(viii) Quality assurance practices; and
(ix) Covert audit procedures.
Page 21 Inspection and Maintenance
-------
L. Public Awareness
An effective public awareness campaign is absolutely fundamental to the success of any
I/M program. Because of the nature of I/M and its potential impacts upon the motoring public, the
program's acceptance is necessary for full public support and participation. We recommend that
public awareness efforts start early and be sustained throughout the life of the program.
A good campaign will teach the public about the air quality issues in greater Cairo, the
requirements of Law 4, the role of the motor vehicle in the air pollution problem, the need for and
benefits of a vehicle inspection program, how to maintain a vehicle in a low-emission condition,
and how to find a qualified repair technician. Other than the obvious public health benefits of
cleaner running vehicles, the public should also be educated on the economic benefits of the
program. The fuel savings from I/M repairs, estimated in the U.S. at 6-10% on average, can often
more than compensate the vehicle owner for the cost of the test and repairs. Additionally, a
regularly maintained vehicle will perform better and last longer.
The public should also be made aware of the I/M program's operational aspects. Station
locations, hours of operation, advantageous test times with short wait times, vehicle
preconditioning (warm-up before testing), test cost, objectives and procedures, and waiver
procedures should be understood by the program participants.
Groups other than motorists which might also be affected by I/M should also be addressed
in any public awareness campaign. Motor vehicle dealers and repair businesses, fleet operators,
governmental and nongovernmental organizations, educational institutions, trade associations,
community groups and news media organizations must all be informed of their role in I/M and how
the program will impact upon their affairs. For instance, repair technicians and repair facility
operators should be made aware of the business opportunity which the program represents, and
how to capitalize on it by seeking improved training in automotive diagnosis and repair, and
investing in improved repair equipment and facilities. Acceptance and participation from this
segment of society is vital for the success of the program.
Every media outlet should be used in the awareness and education campaign. Since
educating the public about basic issues takes time, efforts should begin immediately to start a
campaign on basic air pollution causes and effects and the options available to control it. Efforts
should be focused on an aggressive campaign in the months before the program startup and in its
first few months of operation, on the rationale for the program and its workings. Obvious outlets
include the traditional media of radio, television and newspapers. Advertisements and promotions
should be designed to catch the public's attention, while brochures, newsletters, seminars and
special awareness events can be used for more detailed dissemination information . Appendix M
provides a few examples of written outreach materials used in the U.S. and Canada.
Nontraditional methods to achieve public awareness might also be explored which are more
appropriate for Egyptian society.
M. Smoking Vehicle Enforcement
Introduction
In addition to the gaseous pollutants HC, CO and NOx, an effective clean air program
should target reductions of particulate emissions as well. Particulates can be any of a number of
solid and liquid substances suspended in the exhaust stream such as sulfur, oil, aerosols, unburned
hydrocarbons and other components, including oxides of nitrogen. In sufficient quantities these
particles may appear to the naked eye as smoke in the vehicle exhaust"
Particulates are of concern because of the public health impacts associated with their
Page 22 Inspection and Maintenance
-------
presence in the atmosphere. Particulates, especially the smallest particles of less than 10 microns
in diameter (PM-10), have been shown to cause or worsen respiratory conditions, such as asthma
and certain cancers, which cause death. Particulates also have a variety of adverse environmental
effects on water quality and agriculture.
Paniculate emissions in the U.S. are largely created by heavy-duty diesel vehicles operating
under high loads. EPA does regulate emissions of new diesels (see the emission standards
summary included in the Phase 1 report). While HC and CO emissions tend to be stable among
diesel vehicles in use, particulars emissions tend to increase, especially if tampering occurs.
High concentrations of sulfur in diesel fuel can also increase smoke emissions. Sulfur
levels are dependent upon the "sweetness" of the crude oil (the less sulfur, the sweeter) and the
refining process itself. We know that the Middle East does supply sweet crude but we did not
investigate the quality of Egypt's oil supply and its refining methods. The U.S. has successfully
lowered sulfur levels in its diesel fuel supply using certain refining processes such as
hydrodesulpherization. We recommend that more research be done on the level of sulfur in
Egyptian diesel fuel and that appropriate measures be implemented to reduce the particulate
emissions associated with high sulfur content, as needed.
Unlike diesels, smoking exhaust from a gasoline engine is indicative of far more serious
maintenance problems. Smoke can be caused by any combination of problems such as rich fuel to
air mixtures, poor timing, fouled ignition systems, or deteriorated and damaged mechanical
systems. In addition to the increased particulate emissions, smoking vehicles are likely to also emit
high levels of other problem pollutants such as HC, CO and NOx. In many cases a vehicle
running under these conditions will perform so poorly or cease to run such that the owner will be
forced to seek repair. In other cases, a vehicle may continue to run and emit high levels of
pollutants. It is these vehicles which must be targeted for testing and repair.
The Executive Regulations include a smoke standard for in-use vehicles of 65% opacity or
equivalent at maximum acceleration, and for new (1995) vehicle of 50% opacity or equivalent at
maximum acceleration. These standards are applied across the board to all "...machines, engines,
or vehicles that emit exhaust..."
In order to effectively test light-duty diesel vehicles in an l/M program for particulates,
dynamometers are needed to exert a load on the vehicle during the test. Exhaust opacity can then
be measured and vehicles with excessive exhaust opacity can then be required to obtain repairs. It
was unclear to us what fraction of the light-duty passenger car and truck fleet in Cairo is in fact
diesel powered. We recommend that a better assessment of the diesel fleet be made and
consideration be given to instituting annual exhaust opacity tests for light-duty diesel vehicles. A
draft light-duty diesel vehicle test procedure is included in Appendix P. The Society of Automotive
Engineers has developed the Snap-Acceleration Smoke Test Procedure for Heavy Duty Diesel
Powered Vehicles which is included in Appendix Q. This test does not use a dynamometer to test
heavy-duty diesel vehicles. We recommend that the snap acceleration test be conducted at least
annually on diesel buses and trucks owned by the Government of Egypt and on privately owned
heavy-duty diesel vehicles.
In addition to periodic testing, on the road testing might be used to ensure that vehicles
remain in compliance. A range of roadside testing procedures could be used which require
relatively little technical skill by the enforcement authority. The test procedure is similar for most
of the available technologies. Typically the vehicle operator is asked to leave the vehicle in park or
neutral. Then a series of "snap" or quick accelerations are performed while the smoke level is
measured by some device.
The simplest smoke measurement technology is the Ringleman chart, a visual device with
Page 23 Inspection and Maintenance
-------
which the tester compares smoke color to a graded scale. The tester looks through a hole in the
center of the chart and selects the color grade that most closely resembles the smoke. In principle,
the darker the smoke, the more severe the pollution. However, this procedure has its drawbacks.
It has been shown to be unfair because of the subjective nature of the measurement. Different
testers may "see" different grades of smoke color during the same test. Results can also vary
depending on the size of the smoke plume, the ambient light, humidity, the background, and other
factors. This may lead to both false passes and failures.
More effective smoke testing can be done with opacity meters which measure the opacity of
the full exhaust plume as it exits the tailpipe. The typical unit consists of a light source and a
detector which are placed on opposite sides of the exhaust plume at the end of the exhaust pipe. A
beam of light is projected through the plume and measured by the detector. Because the darkness
or opacity of the plume correlates with the density of particles in the exhaust, the darker (more
particulate-laden) smoke will scatter and absorb more of the light beam. The unit will register and
record the measurement in terms of percent opacity. For instance, 10% opacity is relatively clean
compared to a smoke plume which has 50% or 60% opacity and which is quite dirty. No light
would be detected in 100% opacity smoke.
An alternative to on-road test that is sometimes used in the U.S. is a smoking vehicle hot
line. This consists of a toll-free telephone number that anyone can call to report a smoking vehicle.
With the license plate number, the owner can be contacted and called in for an opacity test.
Assessment and Recommendations
We believe the Executive Regulation on opacity is reasonable for heavy duty diesel vehicles
like trucks and buses, but it is insufficient for gasoline fueled vehicles and light-duty diesel cars
and trucks. We recommend that smoke standards be revised to include separate standards based
on vehicle type and fuel type.
Consistent with recommendations in the section on lead phase-out and new vehicle
standards, we recommend that Egypt adopt the paniculate standards promulgated by EPA and the
European Community.
There are three basic options for enforcing smoking vehicle requirements for in-use
vehicles: periodic testing, onroad testing, or a combination of the two. The choices depend also
on whether the vehicle is diesel powered or gasoline powered.
Since all gasoline powered vehicles are already due to participate in an annual 1/M program,
we recommend that these vehicles be screened for smoke as the first step in the testing process.
Any vehicle that is fully wanned up and visibly smoking at idle should be rejected from testing.
This is standard practice among I/M programs in the U.S. It is especially important to do this since
smoky exhaust will foul the emission analyzers used to measure HC and CO.
Page 24 Inspection and Maintenance
-------
VI. Stage I Vapor Control
Raw gasoline is one source of volatile organic compound (hydrocarbon) emissions that
contribute to ozone formation. As previously discussed under Fuel Volatility Control, gasoline can
escape from a vehicle during operation or while resting. Gasoline can also escape into the
atmosphere when it is being loaded and unloaded during the various stages of its transportation
from the refinery to the vehicle which it fuels. Stage I vapor control refers to the technology used
to control gasoline releases in the wholesale operation, storage, and transport of gasoline from bulk
terminal, to tank truck, to service station. Gasoline is usually delivered to terminal storage tanks
by pipeline with no emissions, but that assumption should be evaluated in the case of Egypt.
Assuming no emissions in transport from the refinery to bulk terminal, the problem starts
when a delivery truck goes to a bulk terminal to fill up and the gasoline being loaded displaces the
vapors in the delivery truck tank and thereby forces the vapors into the air. The amount of
emissions depends on the type of loading: splash loading from the top creates much turbulence
during loading and is associated with very high emissions. Top submerged loading using an
extended fill pipe to admit gasoline below the liquid level in the tank can reduce turbulence by
about 60%.
Gasoline emissions are again generated when VOC vapors in the underground storage tank
at a service station are displaced to the atmosphere by the gasoline being loaded into it from the
delivery truck. As with other loading losses, the quantity of the service station tank loading loss
depends on several variables including the quantity of the liquid transferred, the size and length of
the fill pipe, the method of filling, the tank configuration and the gasoline temperature, vapor
pressure and composition.
Emissions from underground tank filling operations at service stations can be reduced
significantly (by about 95%) through the use of a vapor balance system. Tank trucks are now
required to be vapor tight so that once loaded, gasoline emissions do not occur during transport.
The system requires an extra hose to attach the delivery truck to the underground storage tank or
the terminal. This extra hose is used to capture the vapor and transfer it to the source of the
gasoline. Liquid gasoline displaces a nearly equal volume of partially saturated gasoline vapors.
The vapor is vented through a pipe and flexible hose connected to a vapor collections system (i.e.,
a manifold pipe) on the delivery truck. Liquid transfer creates a slight pressure in the storage tanks
and a slight vacuum in the truck tank. These pressure differences effectively cause the transfer of
displaced vapor to the truck. Any excess vapor is released through the vapor vent line. So, when
the delivery truck is unloading gasoline into the underground storage tank at a service station, it is
simultaneously removing the vapor in the underground tank through the secondary hose. The
vapor goes into the delivery truck tank and is thus recaptured. When the delivery truck returns to
the gasoline terminal for a new load of gasoline, a similar process occurs. The vapors in the
delivery truck are transferred to the terminal storage tank, at which point they can be condensed
into liquid and incorporated into the fuel supply system.
For the vapor balance system to be effective, it is important that delivery truck drivers
follow the proper procedures and actually connect the secondary hose during tank filling and that
there are no leaks in the system or the tank truck which reduce vacuum in the truck or inhibit vapor
transfer. It is also important that the gasoline be discharged below the surface in storage tanks.
Appendix R contains additional detailed information on Stage I vapor control. We
recommend that Egypt install Stage I vapor controls as quickly as possible. We also recommend
that Egypt explore the question of Stage n vapor controls. Stage II captures vapor coming out of
the vehicle's gas tank as it is being refueled. The degree to which this would be effective on a fleet
that does not have evaporative emission controls in wide spread use is the key question to pursue.
Page 25 Stage I Vapor Control
------- |