EPA-AA-TSS-I/M-87-3
            EPA AUDITS OF STATE AND LOCAL
           INSPECTION/MAINTENANCE  PROGRAMS:
               FEDERAL  FISCAL YEAR 1986
                         By:

                John M. Cabaniss, Jr.

                   Jeffrey A. Houk
This  paper  was  presented  at  the  Air  Pollution  Control
Association  Specialty  Meeting  in  Windsor,  Ontario,  on
March 24, 1987.
               Technical Support Staff
         Emission  Control  Technology  Division
               Office  of Mobile  Sources
             Office of Air and Radiation
        U. S. Environmental Protection Agency

-------
Abstract

     EPA AUDITS OF STATE AND LOCAL INSPECTION/MAINTENANCE PROGRAMS:
     FEDERAL FISCAL YEAR 1986
     J.M. Cabaniss, J.A. Houk
     U.S. Environmental Protection Agency,  Ann Arbor,  MI 48105


     This paper  reviews  the  results of  EPA's I/M program  audits
during  Federal  fiscal  year  1986   (FY86).   EPA  performed  eleven
initial  program  audits  and  eight   follow-up  audits  during  FY86.
The paper highlights  design elements that  have proven  successful
in these programs,  and  discusses  the applicability of those design
elements to  other  I/M  programs.    The  paper  also  summarizes  the
progress  that  has  been  made  in  resolving  operating  problems
identified in FY86 and earlier years.
                              -2-

-------
                 EPA AUDITS OF STATE AND LOCAL
                INSPECTION/MAINTENANCE PROGRAMS:
                    FEDERAL FISCAL YEAR 1986
1.0  INTRODUCTION/BACKGROUND

     As a result of  the  Clean Air Act Amendments of  1977,  many
motor  vehicle  inspection  and maintenance  (I/M)  programs  have
been   implemented   across   the   country.    I/M  programs   are
currently  operating  in  fifty-nine  urban  areas  in  thirty-one
States   and  the   District   of   Columbia   (see   Table   1).
Approximately   fifty  million   vehicles  undergo   inspections
annually in these programs.

     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 to:   (1)  ensure that
statutory and State  Implementation Plan  (SIP)  requirements  are
being  met;  (2)  assist in developing  an  acceptable  level of  I/M
program  quality;  (3)  document  the  achievements,  shortcomings,
and  needs  of  the various   I/M programs; (4)  identify  programs
needing further  technical  support or other assistance;  and  (5)
identify technical  issues  common  to  all  or many  programs which
need further investigation.

     After  consultations  among  officials  of  the  State  and
Territorial  Air   Pollution  Program  Administrators   and  the
Association   of    Local    Air    Pollution    Control   Officers
(STAPPA/ALAPCO),  EPA's  Office  of  Air  Quality  Planning  and
Standards (OAQPS),  and EPA's Office  of Mobile  Sources (OMS), it
was  decided that the best  approach for developing the I/M audit
program  would  be  to add  an  I/M  element  to  the National  Air
Audit  System  (NAAS)  in  federal  FY1985.   This  necessitated  the
development  of  the   national    I/M  audit   guidelines   during
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)   and  the  National
Air Audit System Guidance  Manual  for FY86/87  (EPA-450/2-85/008;
December, 1985).

     EPA  started  the  I/M  audit  program  in  FY1984  when eight
pilot  audits  were  conducted  during  the  spring  and  summer  of
1984.   (See Table  2  for  the FY1984-85  audit  schedule.)   The
eight pilot audits  were used  to  test auditing  concepts   intended
for  use  in  the  formal I/M  audit  guidelines as  well  as  to get a
start  on  the  task  of  auditing  the  then twenty-five operating
I/M  programs.   As   displayed  in  Table  2,  the  FY1984  I/M audit
schedule was designed to cover a  cross-section  of program types
in order  to properly test  the audit  concepts.   The  majority of

                              -3-

-------
                             Table 1
                     Operating I/M Programs
                        as  of  March,  1987
  Location

Region I

Connecticut
Massachusetts
Rhode Island

Region II

New Jersey
New York

Region III

District of
  Columbia
Delaware
Maryland
Pennsylvania
Virginia
Region IV

Georgia
Kentucky
  Louisville
  Cincinnati
     Suburbs
North Carolina
  Charlotte
  Raleigh
Tennessee
  Memphis
  Nashville
Start Date
    1/83
    4/83
    1/79
    2/74
    1/82
    1/83

    1/83
    2/84
    6/84
   12/81
                  Start Date
Region V

Illinois
Indiana
Michigan
Wisconsin
    4/82

    1/84

    9/86

   12/82
   11/86

    8/83
    1/85
    5/86
    6/84
   12/85
    4/84
  Location        	

Region VI

Louisiana            9/85
Oklahoma
  Tulsa              1/86
  Oklahoma City      1/87
Texas
  Houston            7/84
  Dallas/Ft. Worth   1/86
  El Paso            1/86

Region VII

Missouri             1/84
Region VIII

Colorado             1/82
Utah
  Salt Lake City     4/84
  Davis County       4/84
  Provo              7/86
Region IX

Arizona              1/77
California
  South Coast        3/84
  Fresno            10/84
  Bakersfield        1/86
Nevada
  Las Vegas         10/83
  Reno              10/83

Region X
Alaska
  Anchorage          7/85
  Fairbanks          7/85
Idaho                8/84
Oregon
  Portland           7/75
  Medford            1/86
Washington
  Seattle            1/82
  Spokane            7/85
                               -4-

-------
the ten  FY1985  I/M audits involved decentralized programs  (six
of  eight).   All  of  the   programs,  except  the  Texas  (Harris
County) program, had been  in  operation  for at  least  one  year  at
the time of the audits.

     In  addition  to  the   initial  audits  performed  in  FY1985,
follow-up  I/M   audits  were conducted  in  several States  which
were  audited  in  FY1984.    The  follow-up  audits   focused  on
specific aspects of the programs  where  problems were identified
or which could not be  fully evaluated during the  previous  audit
visits.
     The  FY84-85
measures
programs.
        I/M program
by  which  EPA  would
 These include:
        audits
        made apparent
   judge  the
                                           several  key
                                    success   of   these
     1)   High  vehicle  owner  compliance  with  the  inspection
          requirement.    Any  lack  of  participation  in  an  I/M
          program   directly   reduces   the  possible   emission
          reduction  benefit  of   the  program.    In  addition,  as
          many  vehicle  owners  who   avoid   inspection  do  so
          because   they   know   their  vehicles  would   require
          repair,  the   program   emission   reduction  benefit  is
          reduced further.
     2)
     3)
A failure  rate  which  meets  design projections
                                       For
an  I/M  program  to   function  as  designed,  vehicles
which exceed the  appropriate  emissions  standards must
be    failed    and    repaired    properly.     Allowing
high-emitting vehicles  to  escape repair  also  reduces
the emission reduction benefit of the program.

A  low waiver rate.   Waiver  provisions exist  in most
I/M  program  regulations   to  protect  vehicle  owners
from  excessive  repair  costs.   However,   the  emission
reductions of vehicles  not repaired  to  pass  program
cutpoints are lower  than  those  for  vehicles which can
be  repaired  to  pass.   In  some  cases,  reviews  of I/M
program data indicate that  no  reductions  are achieved
on waived vehicles.
     4)   Adequate   analyzer   quality   control.    Inaccurate
          equipment  can  cause vehicles  to  be passed  or  failed
          improperly.    Accurate   analyzers   are   especially
          important  for inspection  of  newer  vehicles,  which are
          subject  to  tighter  emission  standards  and  may  be
     5)
          eligible for warranty coverage.
Effective
data
analysis.
                       	     Effective    use   of
high-quality inspection data is  vital  for  I/M program
management.     Summaries    of    important    program
statistics  (failure  rate,  waiver  rate,   etc.)  are
extremely  useful  in identifying problem stations and
inspectors.  In addition,  overall  summaries  allow for
evaluation of the success of the program as a whole.
                               -5-

-------
                            Table 2

                  FY1984-85 I/M Audit Schedule
     Location
Connecticut
Massachusetts
Colorado
Arizona
District of Columbia
Virginia
Memphis, TN
New Jersey
Nevada
New York
Georgia
Missouri
Delaware
North Carolina
Texas

Oregon
Wisconsin
Indiana
Dates
5/14 -
5/16 -
5/21 -
5/23 -
ia 6/04 -
6/06 -
6/27 -
7/10 -
10/15 -
12/10 -
1/22 -
3/04 -
3/07 -
3/18 -
3/26 -
4/02 -
4/15 -
7/08 -
8/06 -
5/16/84
5/18/84
5/23/84
5/25/84
6/06/84
6/08/84
6/29/84
7/13/84
10/19/84
12/14/84
1/25/85
3/07/85
3/08/85
3/22/85
3/27/85
4/04/85
4/19/85
7/10/85
8/08/85
                                             Program
                                              Type*
                                                CC
                                                DC
                                                DM
                                                CC
                                                CG
                                                DM
                                                CG
                                                CG/DM
                                                DM'
                                                DC
                                                DM
                                                DM
                                                CG
                                                DM
                                                DT

                                                CG
                                                CC
                                                CC
Follow-up audits:

District of Columbia
Texas
Colorado
                    5/11 -  5/12/85
                    8/26 -  8/30/85
                    9/24 -  9/25/85
CG
DT
DM
*CC
 CG
 DM
 DC
 DT
centralized, contractor
centralized, government-run
decentralized with manual analyzers
decentralized with computerized analyzers
decentralized tampering only
                               -6-

-------
     The  FY86  I/M program  audits (Table  3)  differed  somewhat
from  those  in  the  previous  two  fiscal  years.    EPA  teams
generally  remained on-site  longer,   to  visit  more  inspection
stations  and  evaluate the  performance of  additional  auditors.
EPA  personnel  also  spent  more   time  during  audits  examining
inspection  forms  in  stations  and reviewing  data with  program
officials.  Two additional areas of concern were noted:

     1)   Success of  overall  quality  assurance  efforts.   Fiscal
          problems  in some  States  led  to  I/M  program  budget
          cuts.   This in  turn  led  to  staff  cutbacks,  longer
          periods  of  time  between  audits, and  less time  (and
          attention)  spent   in   stations.   Previously   noted
          quality  assurance  deficiencies   continue  to  appear,
          including   lack  of  useful   program  data   and   a
          reluctance    to    aggressively    enforce    program
          regulations.    Many   programs   continue  to   lack   a
          meaningful covert auditing program.

     2)   Performance of  tampering  inspections  in decentralized
          programs.   Many  decentralized   programs   include   a
          requirement  for  some  type  of  tampering  inspection,
          and  some  rely  totally  on  tampering   inspections  to
          meet  the minimum emission  reduction  requirement  for
          SIP  approval.    However,   observation of   tampering
          inspections  during  EPA  audits   show   that  many  are
          performed  in  a  cursory  manner,  and  inspectors  often
          have  difficulty performing  a  complete inspection  or
          locating specific components when requested to  do  so
          by an  auditor.   In  addition,  roadside surveys show in
          some areas that tampering  rates  remain high even with
          an  inspection   program  in  place.   Vehicles often  go
          uninspected during covert audits.
2.0  SUCCESSFUL DESIGN ELEMENTS OF I/M PROGRAMS

     In  the  course of auditing 29  I/M  programs  during FY84-86,
EPA has  identified many  features  of program  design  that  have
resulted  in  more effective  and more  smoothly  running programs.
The remainder of  this  paper gives a  brief overview  of  some of
these  design features.   Examples  are given where  I/M programs
have reported success with  these design  elements,  or where they
have made changes to correct operating problems.
3.0  ENFORCEMENT MECHANISMS

     Registration  enforcement  has   generally  proven  the  most
effective  means  of maintaining  high rates of owner  compliance
with  inspection  requirements.    In  fact,  several  areas  have
adopted  registration  enforcement mechanisms  after  experiencing
problems  with   sticker   enforcement,   including  Colorado  and
Georgia.  Programs which  used registration enforcement from the
onset of the  I/M program  have reported little or no  decline in
registration  volume   due  to  owners  seeking   to   avoid  the
inspection requirement.

                              -7-

-------
                            Table 3

                   FY1986  I/M Audit Schedule
    Location

Salt Lake County,  UT
Davis County,  UT
Nashville, TN
Maryland
California
Seattle, WA
Louisville, KY
Pennsylvania
Idaho
Fairbanks, AK
Anchorage, AK

Follow-up audits:

Georgia
Houston, TX
Salt Lake County,
Davis County, UT
New York
Memphis, TN
Massachusetts
Connecticut
UT
           Dates
       10/07
       10/09
       11/05
       11/19
        1/27
        2/24
        3/04
        3/10
        3/18
        8/20
        8/25
       10/09/85
       10/10/85
       11/07/85
       11/21/85
        2/06/86
        2/28/86
        2/07/86
        3/13/86
        3/21/86
        8/22/86
        8/27/86
1/29 -  1/30/86
6/11 -  6/12/86
4/28 -  5/02/86
   5/29/86
   5/29/86
   6/11/86
6/16 -  6/18/86
7/07 -  7/11/86
9/23 -  9/25/86
Program
  Type

   DM
   DM
   CC
   CC
   DC
   CC
   CC
   DC
   DM
   DC
   DC
   DM
   DM
   DT
   DM
   DM
   DC
   CG
   DC
   CC
*CC = centralized, contractor-run
 CG = centralized, government-run
 DM = decentralized with manual analyzers
 DC = decentralized with computer analyzers
 DT = decentralized tampering only
                               -8-

-------
     Sticker   enforcement   mechanisms    can   be    successful,
however.    For   example,  Texas,  Louisiana,  Massachusetts,  and
Pennsylvania  all   report  high  compliance  rates.    One  factor
contributing to the  success  of these programs is  the  fact that
these areas all have statewide safety inspection programs  which
had  been   in  operation for  several years  before  emission  (or
tampering)   inspections  began.   Authorizing  police  agencies  to
cite  parked vehicles,  and  keeping  collected fines   in  local
coffers,   may  contribute   to  aggressive  enforcement   and  low
non-compliance rates in some  areas.

     A few  areas have  adopted  effective  "data-link"  enforcement
mechanisms.  Data-link  enforcement  systems consist  of  matching
lists   of    vehicles   subject   to   inspection   (most   often
registration   data)   with   inspection   data.    Penalties  for
noncomplying vehicle owners  which make  this system  effective
include:    suspension  of vehicle registration, court summonses,
and  fines.  Boise,  Idaho,   Louisville,  Kentucky,  and  Maryland
have implemented effective data-link enforcement systems.
4.0  FAILURE RATES

     The  reported  program  failure  rate  is  one  of   the  most
important  indicators  of  the  success  of  program  operation.
Centralized   programs,    and    decentralized    programs   with
computerized  analyzers,  have  traditionally  reported  failure
rates  close  to   what   would  be  expected  for  a  given set  of
cutpoints.  This has not been the  case  in  decentralized, manual
analyzer  programs,  where  the  manual  nature  of  the  equipment
does not  allow  for control  over the inspection  procedure  (See
Table 4).

     The  State   of  Colorado,   for   example,   has  experienced
serious problems  with  inspector  performance,  leading  to  a  very
low failure rate.   An  overall  failure  rate of 7.9% was reported
for  1986,  although  voluntary  emissions  inspections  at  the
Denver  area  Emissions  Technical Centers  consistently resulted
in  failure  rates  over  30%.   The Colorado Department  of Health
has estimated that  manual  design elements, improper inspections
and waivers had   led to  a  30%  loss  of  program benefit.   In  an
effort  to eliminate improper  inspection  procedures,  the  State
adopted  a  requirement  for  computerized  analyzers,   to  take
effect  in July 1987.   In  response  to  the 1984  EPA  audit,  and
due to  problems with  aging equipment,  New Jersey also switched
to   a   requirement   for    computerized   analyzers   in   the
decentralized  inspection  stations.  New  York  is  currently  in
the process of making this  changeover.
5.0  WAIVER PROVISIONS

     Waiver  systems  are   managed   with  varying   degrees  of
success.    The  best  systems  are  characterized  by  stringent
requirements   for   obtaining   a   waiver,   and  strict   State
oversight.   One example of  a well-designed waiver system is the
system  in  effect  in El  Paso,  Texas.   To  receive  a  waiver,

                               -Q-

-------
                            Table 4
     REPORTED EMISSION TEST FAILURE RATES  IN  I/M PROGRAMS*
CENTRALIZED  (CC)
                   Arizona               20.2
                   Connecticut           17.2
                   Delaware              13.7
                   Kentucky              15.7
                   Maryland              14.6
                   Memphis, TN            8.1
                   Nashville, TN         24.5
                   New Jersey            26.1
                   Oregon                24.0
                   Washington, D.C.      18.4
                   Washington            19.0
                   Wisconsin             15.3
DECENTRALIZED
  Computerized Analyzers  (DC)

                   Alaska
                     Anchorage           15.7 %
                     Fairbanks           19.4
                   California            27.7
                   Michigan              15.8
                   New York**             5.1
                   Pennsylvania          17.6
  Manual Analyzers  (DM)
                   Georgia                6.6 %
                   Idaho                  9.8
                   Missouri               6.7
                   North Carolina         5.6
                   Nevada
                     Clark County         9 . 5
                     Washoe County       11.0
                   Utah
                     Davis County         8.7
                     Salt Lake County    10.0
                   Virginia               2.3
*  For all model years, including  light duty  trucks.

** New York's analyzers are only partially computerized
                              -10-

-------
vehicles  must  go  through  a  low-emission  tune-up  sequence,
receive all  warranty  repairs,  and  any necessary  repairs  not
covered by  warranty up  to a  $200 cost  limit.   In  subsequent
years,  the cost  limit  rises to $400.   Waivers  are  only  issued
by  the   Department   of  Public   Safety,   which  oversees  the
inspection program.

     There are ways  of  maintaining administrative  control over
a waiver  system  without direct State  issuance of waivers.  One
option is to  monitor waivers  through data  analysis.   Mechanics
who  issue  a   higher  than  average  number  of  waivers  can  be
targeted   for   auditor   attention   and   perhaps   additional
training.    The  Salt  Lake  County,  Utah  data  handling  system
produces  a  monthly  "improper  waiver"   report,   which  lists
vehicles  that   were   issued  a   waiver   without   meeting  the
appropriate  requirements  by  station  and  mechanic.   Another
method of limiting  the  number of  waivers administratively is to
increase the amount of paperwork required  of  vehicle owners and
mechanics to  better  ensure adherence  to waiver  provisions; for
example,  use  of  detailed  application  forms,   and  requiring
complete  repair   documentation.    Pennsylvania  reports  success
with the  use  of  such  forms,  and Salt  Lake County,  Utah  has
adopted a similar system.

     The  effectiveness  of  repairs   sought  in  the  course  of
obtaining  a  waiver  may be  supported by  a  requirement  for  a
minimum emission  reduction.   A reduction  requirement of  10-20%
provides  a  tangible  improvement   in  idle  emissions of  waived
vehicles,   and ensures  that  vehicles  in which  emissions become
worse by improper repairs are not given waivers.

     Repair  effectiveness  may  also  be  improved   by  providing
emission-related  training   to mechanics  in  the  program  area.
This can  be scheduled  as  part  of an  inspector  recertification
course,  or  offered  on  a  voluntary  basis  through  a  local
community  college  or   vocational  center.    In  some  programs,
repair  facilities employing  mechanics  who have  received this
training  can  be  advertised  as  "certified"  repair facilities.
Alternatively,  stations  identified   through  data   analysis  as
reporting  the  lowest   retest emission  levels  or  the   lowest
waiver  rates  can  be  publicized  as  having the   best   repair
records.   The Louisville,  Kentucky  program collects  data  on
repairs performed, waiver  rates,  and  repair cost,   and regularly
publishes a repair facility report.

     Many  States have  had  problems   with high  waiver   rates,
usually due to lenient  requirements.   High waiver  rates usually
appear  in  areas   requiring   an   engine  parameter  adjustment
procedure,  or setting  a  low cost  limit (for example,  $25 for
pre-1981  vehicles and  $50  for  1981  and  newer  vehicles)  for
required repairs.  Several  programs  have tightened their waiver
requirements   recently,    including   Arizona,   Colorado,   and
Louisville,  Kentucky.

                              -11-

-------
6.0  DATA ANALYSIS

     The  FY84-85  audits   revealed  serious  data   processing
shortfalls in most programs.  The  programs  audited in FY86  were
generally  found   to  have  more  successfully  implemented  data
analysis systems.

     Data  collection  is  easiest  in  centralized  programs  with
on-line   emission  analyzers.     In   decentralized   programs,
computerized  analyzers  greatly   simplify   data   handling   for
inspectors  and  program  managers  by  storing  keyboard-entered
inspection data  on cassettes for  later transfer  onto  computer
tape.  A  few decentralized  programs  also  have had  some  success
with  inspection   forms  designed  to  be   read  by  an  optical
scanner.   Data  loss  due  to  soiled  or  improperly  filled-out
forms can be high in  this  type  of  system;  however, some smaller
I/M  programs  return  unreadable   forms  or  forms  with errors  to
inspection  stations  for   copying  or  correction.    The  Utah
County,  Utah  I/M  program  takes this  approach  and   reports  an
unusable form rate of  less than  1%.

     Many   I/M    programs   have   excellent   capabilities   for
analyzing the data they collect.   Reports  of failure  rates  by
model  year  are  useful in determining whether  the  stringency of
the  cutpoints  is  fairly  consistent  throughout   the  range  of
years  tested, or  if  the cutpoints  for  any given model  year (or
model year group)  are  too  tight or  too lenient.   In addition,
reports   of   failure  rate   by  emission   level   (i.e.,   what
percentage of  vehicles  would fail  at  a  given  cutpoint)  have
been  extremely  useful  to  EPA   and  State  and Local  agencies.
Reports of failure rate by pollutant have also  proven useful to
program  managers   in  determining  whether  cutpoints have  been
selected   properly   (officials   in    areas   experiencing   CO
violations only,   for example, often do  not  wish to fail a large
percentage of vehicles for HC alone).

     Reports of  waiver  rates and   calculation  of   average  idle
emission  reductions on waived vehicles  are  useful  in evaluating
the  effectiveness of  the  repair   requirements  for  any  given
model  year  or model  year  group.   Analysis  of  waiver  rate  by
pollutant  is helpful   in   determining  the  appropriateness  of
specific   repair   sequences   (the   so-called   "five-parameter
adjustments");  Colorado,  among  other  States,  has   found  that
engine  adjustments  alone are somewhat  effective in reducing CO
emissions but have less impact  on HC  emissions.   Colorado has
recently  supplemented   the  adjustment  requirements   with  a
minimum   repair    expenditure,    and   increased   the   repair
expenditure requirement for 1981 and newer vehicles as well.

     Most  useful   to   I/M   program  managers,  especially  in
decentralized programs,  are  reports  of  program  statistics  by
station  and  by  inspector.   Reports of  failure  rates by station
and  inspector, in conjunction with  information  on  the  average
model  year  mix  of  vehicles  inspected  by  each station,  can be

                              -12-

-------
used  to  pinpoint  inspectors  who  are  reporting  a  lower  than
average  failure  rate,  and who  may  be performing  inspections
improperly.   This  information  is useful in  both  tampering  and
emissions    programs.     Reports     of    waiver    rate    by
inspector/mechanic may  be used  to identify  mechanics who  are
waiving vehicles at a higher  than  average  rate,  indicating that
they may be waiving vehicles  improperly or may need  additional
repair training.   Individual vehicles which  have  been passed or
waived  improperly can  be  brought  to  the  attention  of  the
responsible inspectors;  Utah County,  Utah  I/M officials require
inspectors to recall  these vehicles  to  the station  and process
them properly,  or  face  suspension.   Reports  of   repair  cost  by
station  can  be  useful   in identifying  stations  which may  be
unfairly overcharging for repairs  or performing  unneeded work,
as  well   as  stations  which  are  improperly  passing  vehicles
rather  than  performing  necessary  repairs.    These  types  of
summaries  of  station  performance  can   be  useful  to  auditors
during station  visits to point  out possible  problem areas,  and
to enable station personnel to compare  their  performance to the
performance of the I/M program as a whole.
7.0  INSPECTION STATION AUDITING PROCEDURES

     An important part  of  each EPA audit is an  evaluation  of a
program's  station  audit   and  surveillance  efforts.   A  strong
quality  assurance  program  is essential  to  ensure  that  the
program  is  operating  as  intended  and  that program  objectives
are being met.

     EPA audits have  shown that  most station auditors  do their
jobs well.   Most  are  conscientious, well-organized,  and have a
good rapport  with the  station personnel with  whom  they work.
Most programs appear  adequately  staffed, although  some States
have  experienced  cutbacks  recently due  to  budget  problems.
Nearly   all   programs  have  established   standardized  audit
procedures,  and  some programs periodically  rotate  auditors  to
different sections of  the  I/M area.  These measures help ensure
that  all  of  the stations  in  the  I/M  program  are  treated
consistently.

     Consistent   follow-up   on    problems   identified   during
stations visits  is  vital.   Several I/M programs  have  adopted
penalty  schedules,  standardizing  the  penalties  for  various
offenses.  A  quick process  for  closing stations  or  suspending
inspectors in violation of  program regulations  permits program
officials  to  retain  control   over   station   and   inspector
performance.

     Covert   auditing   is   an    extremely   useful   tool   in
decentralized  programs   for  learning  how  well   inspection
stations are  performing and for  providing  a basis  for action
against  bad   operators.    Although  most   programs   do  some
undercover  work,   few  have  organized   programs  capable  of

                              -13-

-------
visiting each station at  least  once per year.  The  best  systems
are those in which used  cars  are  obtained periodically and sent
to stations in a maladjusted  or  tampered  condition.   Part-time
or temporary  personnel often  operate the  vehicles,   and  funds
are provided  to  cover the  cost  of  inspection fees.   Colorado
uses   a   fleet  of  several  vehicles,   and  performed  over  1800
covert audits at  1350 stations  in  1986, resulting  in  nearly 300
enforcement actions.
8.0  CONCLUSION

     At this time, almost  all  operating  I/M programs  have  been
audited by  EPA.   EPA is encouraged  by the results  of  the  FY86
audits and  by the  generally  successful  implementation of  I/M
programs,    although   some    areas   continue  to   have   serious
operating  problems.   Substantial progress has been made in  some
of  these  areas toward  correcting operating deficiencies.   The
solutions   to  most   problems  are  well   known   and   have  been
successfully  implemented  by  many   I/M  programs,  as  outlined
above.  EPA is  confident   that  the  quality  of  I/M  programs
nationwide  will  improve  as more areas  identify problems  and
adopt design enhancements to address them.

     EPA's  program   of   auditing  I/M  programs   is  an  ongoing
process.   The  first  cycle  of  audits was basically completed in
FY86, and future audits  will be directed toward  evaluating  the
few  remaining  new  programs  and following up on  States' efforts
to correct problems  already  identified.  EPA also  plans to  work
with  STAPPA/ALAPCO  during  FY87  to  develop  revised  I/M  audit
guidelines for FY88  and FY89.

     I/M programs are  a major part of  most  areas'  strategies
for  reaching attainment  and  assuring maintenance of  the ambient
ozone  and  carbon monoxide  standards.    I/M will  play  an  even
greater role  as  some  areas look  at  additional  strategies  to
deal with  intractable ozone  and CO  problems.  The audit process
will  continue  to  play  an  important  role  in  achieving  the
greatest possible environmental benefit from I/M.
                              -14-

-------