EPA-AA-TSS-I/M-85-09 EPA AUDITS OF STATE AND LOCAL INSPECTION/MAINTENANCE PROGRAMS By: Philip A. Lorang Jane A. Armstrong John M. Cabaniss, Jr. This paper was presented, at 78th Annual Meeting and Exhibition of the Air Pollution .Control Association in Detroit, Michigan, on June 18, 1985. Technical Support Staff Emission Control Technology Division Office of Mobile Sources Office of Air and Radiation U. S. Environmental Protection Agency ------- -2- Abstract EPA AUDITS OF STATE AND LOCAL INSPECTION/MAINTENANCE PROGRAMS P.A.Lorang, J.A. Armstrong, J.M.Cabaniss U.S.Environmental Protection Agency, Ann Arbor,MI 48105 Many State and local agencies have implemented vehicle emissions I/M programs in the last few years. EPA began to audit these programs in federal FY1984. The audit process for I/M was developed in conjunction with STAPPA/ALAPCO; the I/M audit became part of the National Air Audit System in FY1985. Results of the I/M audits indicate that (1) enforcement is a problem in some programs with sticker based enforcement; (2) low reported failure rates are a problem in many decentralized programs, especially those that -use manual analyzers, and in some centralized, government run programs; (3) high waiver rates are a problem in some programs, both centralized and decentralized; (4) analyzer quality assurance ranges from excellent in centralized, contractor programs to marginal in decentralized programs with manual analyzers and in some centralized government run programs; (5) data analyses are not being effectively used in most programs to monitor and improve program performance and the performance of individual inspection stations; (6) the quality of I/M repairs is a problem, to some extent, in every program audited. EPA believes that the resolution of these problems generally rests with each State/local I/M program developing an overall I/M quality assurance program to ensure that problems are identified and resolved in a timely manner. . ------- -4- As a direct result of. the survey/workshop and related comments received from State and local officials, EPA's Office of Mobile Sources (QMS) decided early in 1984 that there was a definite need for a national I/M audit system and national I/M audit guidelines. EPA and State and local agencies could use such an audit program (1) to ensure that statutory and State Implementation Plan (SIP) requirements are being met; (2) to assist in developing an acceptable level of I/M program guality; (3) to account for the achievements, shortcomings, and needs of the various I/M programs; (4) to identify programs needing further technical support or other assistance; and (5) to identify technical issues common to all or many programs which need further investigation. At the time that QMS made this decision, EPA's Office of Air Quality Planning and Standards (OAQPS) was in the midst of a cooperative effort with the State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Officials (ALAPCO) to develop and implement the National Air Audit System (NAAS). The NAAS was being developed to serve generally the same desired objectives for the air guality . management programs across the country. In NAAS, the EPA Regional Offices are responsible for conducting the individual audits and. issuing related audit reports, and OAQPS is responsible for assembling national audit results and issuing an annual national audit report. After consultations among officials of STAPPA/ALAPCO, OAQPS, and OMS, it was decided that the best approach for developing the I/M audit program would be to add an I/M element to NAAS in federal FY1985. This necessitated the development of the national I/M audit guidelines during federal FY1984. In keeping with the NAAS process, a STAPPA/ALAPCO I/M subcommittee was formed to work with OMS in developing the national I/M audit guidelines. With the help of STAPPA/ALAPCO and I/M officials around the country who served as reviewers, the I/M audit guidelines were developed on schedule and appear as Chapter 6 of the National Air Audit System Guidance Manual for FY85 (EPA-450/2-84-008; December, 1984). The I/M audit guidelines were developed in conformance with generally accepted government auditing standards as contained in the report: "Standards for Audit of Governmental Organizations, Programs, Activities, and Functions," (U.S. General Accounting Office, 1981 Revision). ------- -6- The FY1985 I/M audit schedule appears in Table 3. The majority of the FY1985 I/M audits will involve decentralized programs (six of eight). All of the programs, except the Texas (Harris County) program, will have been in operation for at least one year at the time of the audits. In the case of Texas, the program will have been in operation only nine months. The Texas program was originally included in the FY1985 audit schedule because of its planned implementation date of April 1984. Although, program start-up slipped to July 1984, it was decided to keep Texas in the FY1985 schedule because of its special characteristics. The Texas I/M program is the only I/M program implemented to date which relies exclusively on the inspection and repair of tampered and otherwise defective emission control system components rather than basing the determination of the need for maintenance on emissions short tests. Table 3 FY1985 I/M Audit Schedule Program Location Pates Type* Nevada 10/15 - 10/19/84 C New York 12/10 - 12/14/84 D Georgia 1/22 - 1/25/85 C Missouri 3/04 - 3/08/85 C Delaware 3/07 - 3/08/85 B North Carolina 3/18 - 3/22/85 C Texas 3/26 - 3/27/85 C 4/02 - 4/04/85 Oregon . 4/15 - 4/19/85 B *B - centralized, government-run C = decentralized D = decentralized with computerized analyzers ------- -8- 3.0 Audit Process for I/M Programs As embodied in the NAAS, the I/M audit process contains four elements: 1. Audit preparation. 2. Audit visit. 3. Development of the audit report •. 4. Audit follow-up. The preparation for the audit allows the auditors to familiarize themselves with the design and operations of the program under review and to identify those particular aspects of the program which may need special emphasis during the audit visit. Proper preparation will allow the auditors to establish priorities for various audit activities in order to make efficient use of the limited time available during the audit visit. It will also reduce the State/local resources needed to cooperate with EPA in the audit and the disruption of the I/M program itself. The auditors assigned to perform the audit must collectively possess as much knowledge as possible about the operations of I/M programs in general and about the specific details of the program under review. The goal of audit preparation is to learn the basic design of the I/M program, to identify as much as possible about the operating characteristics of the program, and to determine as much as possible about the potential strengths and weaknesses of the program. To accomplish this, EPA auditors assemble and review documentation on the program to be audited including (1) program rules and regulations, (2) operating manuals or procedures, (3) operating reports, (4) documentation of previous audits or investigations, and (5) routine correspondence to and from program officials, citizens, and other interested parties. To facilitate audit preparation, the I/M audit guidelines include an I/M program questionnaire which contains questions covering the relevant aspects of an I/M program. The audit visit is for the purpose of verifying and documenting whether the program is being properly administered, operated, and enforced according to established laws, rules and regulations, and procedural requirements in .the SIP. Additionally, the audit visit allows a better evaluation of program effectiveness and efficiency. The audit visit is planned and coordinated with State/local agencies in order to minimize the level of intrusion and disruption of normal program activities and to make the best use of both EPA and ------- -10- EPA staff will plan follow-up activities as necessary to encourage and assist State or local implementation of the improvements discussed in the audit report. In cases where deficiencies must be corrected, follow-up audit visits may be necessary after corrective actions have been implemented. ------- -12- Another problem area in some programs was sticker accountability. EPA auditors found that some programs have very thorough sticker accountability procedures while others do not. In order to ensure the proper disposition of stickers, State/local agencies need to confirm that each approval sticker has a matching inspection record showing passing results. (This same confirmation is needed in non-sticker programs for approval certificates, except where the approval certificates and official inspection reports are printed automatically by machine.) This confirmation is accomplished in some current programs by correlating sticker serial numbers to inspection reports and then reviewing inspection records, sticker records, and sticker supplies during audits. In programs with automated data collection, sticker serial numbers can be easily recorded in the inspection report and reviewed through routine data analysis. Because of the potential for data loss in some of these systems, State/local agencies need to be cautious about totally relying on the automatic records. 2. Reported failure rates - EPA auditors found reported failure rates as high as 35 percent and as low as 2 percent. Reported failure rates were consistently much lower than (less that half) the designed failure rates in decentralized programs. (One exception was a decentralized program with computerized analyzers.) Also, there were low failure rates reported in one government run, centralized program. The contractor, centralized programs all had reported failure rates in the designed range. There are several reasons for the low failure rates. In a few cases, the failure rates are low because the I/M cutpoints are too lenient. However, most of the problems with low reported failure rates, especially in decentralized programs, are caused by either pre-inspection repairs, cheating by inspectors, or some combination of these two factors. EPA believes that a strong inspection station surveillance program is needed to ensure proper station performance. This surveillance program should include regular station audits, spot checks with unmarked vehicles, and the ability to gauge and track station performance through data analyses. Spot checks with unmarked vehicles set to' fail inspection, should be considered an indispensable part of the oversight function in a decentralized program, particularly a program with manual analyzers. ------- -14- Analyzer quality assurance - EPA auditors found quite a variation in analyzer quality assurance among the audited programs. In the centralized, contractor programs, analyzer quality assurance was excellent. However, in decentralized programs with manual analyzers and in some centralized, government run programs, analyzer quality assurance was marginal. These problems were caused by several factors: a. Lack of a comprehensive program of preventive and corrective maintenance. b. Lack of thorough audit/surveillance activities for inspection stations. c.. In some cases, existing analyzers are rather old. Data analyses - EPA auditors found that, with only a few exceptions, I/M programs are failing to effectively use available program data to monitor and take steps to improve program performance and performance of individual inspection stations. Of the programs audited, only one had routine and timely data analyses which included more than failure rates by model year and a few other overall statistics. In cases where inspection data are collected manually, there are a number of problems which prevent, or at least limit, the collection of accurate data. In some cases, records are illegible and therefore unusable. A more serious problem, and one that is more difficult to resolve, is that in many cases inspectors do not correctly record data. EPA auditors found that manually collected data records often contain easily identified patterns of record keeping (or other) abuses. In most cases, however, the State/local agencies tend to categorize the problem as inevitably poor record keeping practices rather than attempting to resolve them. While true record keeping abuses of themselves may not be serious, there is no way to analyze the data to distinquish between record keeping errors and more serious infractions, such as falsification of test results in order to improperly pass a vehicle with high emissions or to avoid inspecting a vehicle at all. By screening inspection data, agency field investigators should be able to identify questionable transactions or problem stations. Therefore, EPA considers emphasis on collecting and analyzing valid data to be a high priority. In cases where data are collected automatically, the data are generally available to program officials, although there have been problems with data loss in some cases. The problem in these cases tends to be an inability to use ------- -16- 5.0 Conclusion EPA believes that the resolution to the problems in operating I/M programs generally rests with each State/local I/M program developing an overall I/M guality assurance program to ensure that problems are identified and resolved in a timely manner. Through such systems, program managers need to track: 1. The level of non-compliance among vehicle owners. This is particularly important in non-registration enforcement systems. However, even registration enforcement is not necessarily exempt from problems. 2. The performance of inspection stations to make sure that vehicles are receiving fair, equitable, and accurate inspections. This involves inspection station audit and surveillance activities as well as tracking performance through data analysis. The latter is possible only if accurate data are collected. 3. The performance of the program itself. Program data need to be summarized and analyzed to ensure that cutpoints, failure rates, waiver rates, and other program statistics are within acceptable limits. 4. The guality of repairs. Quality repairs .are the backbone of I/M. Program data need to be reviewed to ensure that vehicles are not being improperly or incorrectly repaired. Retest failure rates and comparisons of before- and after-repair emissions levels can be useful indicators to assess the guality of I/M repairs. Identifying operating problems is as important first step in providing guality I/M programs. The results of completed audits ' are already- being used by State/local agencies and EPA to improve I/M programs. EPA believes that the I/M audit system and guidelines will continue to be a dynamic process for achieving environmental results. ------- |