United States
             Environmental Protection
             Agency
            Office of Air
            and Radiation
            Washington, DC20460
August 1984

             Air
&EPA
Motor Vehicle Tampering
Survey  — 1983

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

        OFFICE OF AIR AND RADIATION
    MOTOR VEHICLE TAMPERING  SURVEY  -  1983
                July  1984
      Second printing, October,  1984
  FIELD OPERATIONS AND SUPPORT DIVISION
       OFFICE OF MOBILE SOURCES
           Washington, D. C.

-------
                        TABLE OF CONTENTS


 Introduction  	 p.  1

 Summary of findings	p.  3


                             Results

 Site  and aggregate results	p.  9

 Trends—Houston  and Phoenix	p. 11

 Types of tampering	p. 13

 Tampering and  vehicle age	p. 15

 Effects  of I/M on tampering	p. 19

 Effects  of tampering on idle test failure rates	p. 21

 Fuel-related tampering	p. 24

 Truck rates	p. 29

 Manufacturer-specific rates	~	—	—	 p. 30



                            Appendices

 Appendix A:  Relevant portions of the Clean Air Act	p.  A-l

 Appendix B:  Inspection and data recording procedures 	 p.  B-l

 Appendix C:  Classification of component condition 	 p.  C-l

 Appendix D:  Fuel sample collection and labeling procedures 	 p.  D-l

Appendix E:  Method of application of plumbtesmo 	 p.  E-l

Appendix F:  Field quality control/assurance —	 p.  F-l

Appendix G:  Form for recording refusals —————	p.  G-l

Appendix H:  Tampering and fuel switching by site	p.  H-l


                             Figures
Prevalence of emission control system tampering
   by year of survey

-------
 Overall and catalyst tampering prevalence by model 	 p.   7
    year of vehicle

 Figure 1: Condition of Surveyed vehicles	p.  10

 Figure 2: Extent of tampering among vehicles with 	 p.  10
    at least one tampered component

 Figure 3: Houston in longitudinal perspective	———•— p.  12

 Figure 4: Phoenix in longitudinal perspective 	 p.  12

 Figure 5: Distribution of survey sample  among tampering,  --—-- p.  22
    fuel switching,  and idle test categories

 Overlap of fuel switching indicators  ———	—.,-,..-- p^  27

 Overlap of catalyst tampering and fuel switching	__—-— p.  28

 Lead  concentrations of leaded fuel  sampled from	p.  29
    unleaded vehicles

 Tampering prevalence by manufacturer  ———	p.  30
                              Tables

Truck and car  tampering.rates by component/system	p.   7

Overall  vehicle classification  by  site  	 p.  11

Prevalence of  arguable tampering by component and survey year - p.  13

Table 1: Prevalence of tampering by component and survey year - p.  14

Table 2: Percent tampered and sample size by model year and 	 p.  16
   vehicle age at time of survey

Table 3: Prevalence of catalyst removal and sample size by 	 p.  17
   model year  and vehicle age at time of survey

Table 4: Tampering/fuel switching prevalence in I/M and 	 p.  20
   non-I/M areas

Idle test failure rates by pollutant and. vehicle condition 	 p.  23

Mean idle emissions	~~	 p.  24

Table 5: Fuel  switching rates for current survey by site 	 p.  26
   and indicator

-------
                                INTRODUCTION






      Under the direction of  the Field Operations and Support  Division (FOSD)




 of the EPA,  personnel  of both the  EPA National  Enforcement  Investigations




 Center (NEIC) and FOSD conducted a survey of  light  duty  motor vehicle tamper-




 ing at six U.S.  urban  areas  from September through  December of  1983.  The




 areas surveyed and total number of vehicles inspected are presented below:






       Area inspected                Number  of  inspections




       Cook Co.,  IL                         268




       Sedgwick Co., KA                     290




       Houston, TX                          374




       Denver,  CO                           332




       Los  Angeles,  CA                       270




       Phoenix, AZ                          297






      Motor vehicle  emissions  in urbanized  areas account  for nearly 90% of the




 total carbon monoxide  (CO) and  airborne lead, over  50% of the hydrocarbons




 (HC),  and  nearly 40% of  the oxides  of nitrogen  (NOx)  emitted  to the atmosphere.




As a  result, a major focus of the nation's effort to  achieve compliance with




clean air  standards has  been  the control of emissions from mobile sources.




In order to meet  required emission standards,  vehicle manufacturers have,




since  1968, installed  a  variety of  control devices  on new vehicles.




     The 1977 amendments to the Clean Air Act (sections 203(a)(3)(A) and (B),




found in Appendix A) make it illegal for automobile dealers, repair and




service facilities, and fleet operators to disconnect or render inoperative




emission control  devices or elements of design.  The  FOSD is responsible for




enforcing the tampering provisions of this Act.




      In order to  determine the pattern and incidence  of tampering and fuel

-------
                                                                    p. 2
                                                      1      2      3
 switching,  a series of  surveys were  conducted  in  1978 ,  1979  ,  1981 , and
     4
 1982 .  These  surveys were conducted by the Mobile Source Enforcement Division

 (FOSD's predecessor organization), an expert automotive  consultant, and NEIC.

 Consistent  inspection procedures were used in  all of  these surveys to permit

 comparisons and  identification of trends.


 1983 Survey Objectives

     In addition to the general focus of earlier surveys on identification of

 trends in rates  and types of tampering, the 1983 survey  is a principal measure-

 ment tool in an  Agency program by which credit may be granted on State Imple-

 mentation Plans  (SIPs) for state and local measures to reduce emissions due

 to tampering and fuel switching.  Data from the survey are used in a computer

 model (MOBILES)  along with engineering test results,  to estimate both the

 emission loading impact of these behaviors and the reductions that may be

 achieved by various control program configurations.   Sites for  the survey

 were chosen in light of the need for data on specific areas considering

 programs, as well as the continuing need to monitor the general level and

 distribution of  tampering and fuel switching in the nation.

     Within resource limitations, the survey was designed to:

  1. Make local  measurements of type and extent of tampering and fuel switching
     for SIP credit purposes
1 Motor Vehicle Tampering Survey (1978), U.S. Environmental Protection
  Agency, Mobile Source Enforcement Division, November 1978.

2 Motor Vehicle Tampering Survey (1979), U.S. Environmental Protection
  Agency, National Enforcement Investigations Center, May 1980,
  EPA-330/1-80-001.

3 Motor Vehicle Tampering Survey - 1981, Chattanooga, Tennessee and
  Houston, Texas, U.S. Environmental Protection Agency, National
  Enforcement Investigations Center, March 1982, EPA-330/1-82-001.

4 Motor Vehicle Tampering Survey - 1982, U.S. Environmental Protection
  Agency, National Enforcement Investigations Center, April 1983,
  EPA-330/1-83-001.

-------
                                                                     p.  3
   2.  Extend and update the knowledge gained from earlier  surveys  on:

      a.  Rates of overall  and  component-specific  tampering and  fuel  switching

      b.  Distribution of tampering by age and mileage of vehicle,  manufacturer,
         and other variables of  interest

      c.  The effects of tampering on vehicle idle emissions

      d.  The effect of vehicle inspection and maintenance  (I/M) programs  and
         anti-tampering programs on tampering and fuel switching behavior


      In  order to achieve  these  objectives,  inspection teams visually examined

 emission control devices  and  performed measurements  of idle CO and  HC  emissions.

 To provide  information on fuel  switching, inspectors  sampled gasoline  from the

 tanks of vehicles (for later  laboratory  analysis for  lead), tested  for lead

 deposits in tailpipes  using Plumbtesmo®  test  paper, and checked the integrity

 of the fuel filler inlet  restrictor.  These brief but thorough inspections

 were performed with the consent of  the vehicle owners in  a variety  of  settings

 more fully  detailed elsewhere in this report.
                           SUMMARY OF FINDINGS
     The proportion of sampled vehicles with at  least  one  tampered  component

is up significantly from that of any prior survey—26% compared with  17% in
                                                                        1
1982 and similar rates in the other two large surveys  of 1978 and 1979.  For
1 Since these surveys were all different regarding sites, age distribution,
  and truck proportion, caution must be exercised in making direct
  comparisons.

® Registered trademark; appears hereafter without the ®.  Manufactured
  by Macherey-Nagel, Duren, W. Germany; marketed by Gallard-Schlesinger
  Chemical Corp., Carle Place, New York.

-------
                                                                    p. 4
areas with and without I/M programs  these overall rates were 24% and 29%

respectively.  The  rate of arguable  tampering,  30%, is down from the 38% seen

in the  1982 survey, while the malfunctioning rate increased from 1.2%

to 3% in this survey.

     The component-specific rates for this survey are of considerable

interest, since  they show significant increases in tampering with certain

critical components.  Some of this information is presented graphically

below.
1 There were two I/M areas in the survey—Denver, CO, and Phoenix, AZ.
  Denver, in addition to its conventional idle emissions program, conducts
  a tampering check on later model vehicles.  Because of its different
  certification standards and unique control program history, Los Angeles
  is not considered either an I/M area or non-I/M area, but is included
  in overall rates.

-------
                                                                     p.  5
 The rate of catalytic converter tampering shows a monotonlc pattern of  increase

 over the five surveys,  and is  sharply up in 1983—a  59%  increase  to seven

 percent of the vehicles surveyed.   A portion of this increase may be due to

 the increased age of the  vehicles  surveyed.   Areas without  I/M programs had

 a ten percent rate,  while areas with these programs  held the rate to a  still-

 substantial five percent.   Removal of the catalytic  converter brings about

 an average increase  of  475% for HC and  425% for CO.  For the three-way con-

 verters on more recent  models,  removal may increase  NOx  by  an average of 300%.
                        2
      Tampering with  PCV  and evaporative  systems,  especially the  latter,

 mirrors the pattern  of  increase seen for  other  components.   Evaporative

 tampering  more than  tripled from the  level measured  in the  1982 survey, and

 PCV tampering doubled.  The increases in  tampering with  these HC  control

 systems  is  particularly puzzling, given the  absence  of benefits to  the vehicle

 owner associated with their removal or disablement.   There  was more evapora-

 tive  system tampering in I/M areas  (7%) than in  non-I/M  areas (4%),  but the

 reverse is  true for  PCV systems—the  rate is slightly higher in non-I/M areas.

      EGR  system tampering, long the  most prevalent  form of  tampering in

 these surveys, is exceeded  in  1983  only  by  fuel  switching.  The rate is up

 from  1982 by  33% to  13%.  The I/M areas sampled  had  a slightly lower EGR

 tampering  rate than  the non-I/M areas—12%  as opposed to 15%.  The  impact

 of EGR  tampering is  on NOx  emissions, which  may  increase by an average of 175%.

      Air pump  system tampering  (not  shown)  increased by  over seventy percent
1 This and other emissions increases mentioned in the report originate in
  the data for 3-way catalyst vehicles presented in Anti-Tampering and Anti-
  Misfueling Programs to Reduce In-Use Emissions From Motor Vehicles,
  EPA-AA-TSS-83-10, December 31, 1983.

2 PCV: Positive crankcase ventilation

3 EGR: Exhaust gas recirculation

-------
                                                                    p. 6
 to  an eight  percent level  in  1983.  The  specific  I/M areas in the sample

 actually  have a higher  rate of  air pump  system  tampering (9%) than non-I/M

 areas (7%).   Air pump disablement affects primarily HC and CO emissions,

 bringing  about increases of 200% and  800% respectively.

 Fuel  switching

      Where fuel switching  is  defined  by  the presence of any of three indica-

 tors  ,  the rate is  higher  than  that of the 1982 survey—a 32% increase to

 14%.   I/M areas had a fuel switching  rate of 12%, while the rate was 17% in

 non-I/M areas.   The pattern of  overlap among the  three indicators is discussed

 at  some length in the fuel-related tampering section of this report.  While the

 effects of fuel switching vary  depending upon its duration and a number of vehi-

 cle characteristics, increases  of 475% for HC and 325% for CO can easily occur.


Age of vehicle

     As has been the case with  past surveys, there is a clear relationship

between a vehicle's  age and the probability that it has been tampered with.

This  is evident  in  the graph  on the following page which shows the rates by

model year for  both overall tampering and catalyst removal.  Substantial

fluctuations  in  age-specific  rates should be expected for very old and very

new vehicles  because of small sample sizes for those model years.  These

age-specific  rates are considered in longitudinal perspective over the several

surveys in the  section of this  report on tampering and vehicle age.
  Indicators used are the presence of leaded fuel in the tank, a positive
  Plumbtesmo test for tailpipe lead deposits, or a tampered filler inlet
  restrictor.  These criteria are used, of course, only with vehicles certified
  on unleaded fuel.

-------
                                                                    p. 7
                    OVERALL AND CATALYST TAMPERING
                 PREVALENCE BY  MODEL YEAR OF VEHICLE
                   82    81    80   79   78    77    76
                   VEHICLE MODEL YEAR IN  1983 SURVEY
                                                                ANY
                                                             COMPONENT

                                                             CATALYTIC
                                                             CONVERTER
75
Truck rates

     Rates of all types of tampering tend to be higher for light-duty trucks

than for passenger cars as shown below.
Tampering category
Overall
Catalytic converter
Air pump system
Evaporative system
PCV
EGR system
Fuel switching
Trucks
30%
12
9
7
7
16
22
Cars
24%
6
7
5
5
12
12
Total sample
26%
7
7
5
5
13
14

-------
                                                                    p. 8
The difference in fuel-related tampering is particularly striking—both cata-




lyst removal and fuel switching are approximately twice as prevalent for




light—duty trucks as for passenger cars.






I/M programs and tampering



     As indicated above, tampering rates in the survey areas with I/M pro-




grams were lower than in areas without programs.  The differences, however,




were less pronounced than in previous surveys and echo the findings of the




1982 survey in New Jersey.  Idle test failure rates of vehicles with different




types of tampering are discussed in a later section on this topic.  These




differences by program status should be interpreted cautiously, since only




two I/M sites were included and these differed considerably from each other.






Remainder of the report




     The sections of the report that follow primarily develop in greater




detail the topics touched upon in this summary.  The survey history and




methods are explained in more detail, and results are broken out on a site-by-



site basis.  In addition, certain topics of more specialized interest




are discussed.

-------
                                                                    p. 9






                                  RESULTS




      The detailed results  of  this year's  survey are presented in this section.




 Topics  include the tampering  rates  for  individual  sites,  trends for sites




 previously  sampled,  the various  types of  tampering, tampering as related to




 vehicle age,  the effect of I/M programs on  tampering,  fuel-related tampering,




 truck tampering,  and manufacturer-specific  tampering.






 SITE  AND AGGREGATE RESULTS




      The vehicles inspected in this survey  have been classified into the same




 four  categories established by previous surveys:   tampered, arguably tampered,




 malfunctioning,  and  okay.  Each  vehicle is  classified according to the most




 severe  state  of any  one component.  Thus  a  vehicle lacking the catalytic




 converter with which its configuration was  certified is classified as




 "tampered", regardless of  the  condition of  the other components.  If the most




 severe  state  of a vehicle  is,  for example,  a missing limiter cap, then that




 vehicle is  classified as "arguably  tampered".  If  a malfunctioning component




 is the  most severe condition of  any of the  components, then the vehicle is




 classified  as malfunctioning.  A vehicle  is classified as "okay" only if




 none  of  its inspected emission control components  exhibit any of the negative




 conditions  discussed above.  Criteria for classification of vehicles are




 presented in  Appendix B.




     As mentioned in the summary of findings, the  overall tampering rates




 are sharply up from  the 1982 survey results—a 53% increase in the percentage




with at  least one tampered component.  More than half of the vehicles




 surveyed  displayed some form of  malfunction, arguable  tampering, or clear




 tampering of  emission control  system components.   Figure  1 shows the distri-




bution of survey  vehicles among  the general categories.




     The frequency distribution  of tampering instances for those vehicles

-------
                              FIGURE 1

                CONDITION OF SURVEYED VEHICLES
                                                           p.  10
TAMPERED
  26%
                                                   MALFUNCTIONING
                                                         3%
                                        ARGUABLY
                                        TAMPERED
                                          30%
                              FIGURE 2

              EXTENT  OF TAMPERING AMONG VEHICLES
             WITH  AT  LEAST ONE TAMPERED COMPONENT
                                    ONE
                                 COMPONENT
                                    48%
           TWO
        COMPONENTS
           31Z
                                                 FOUR OR MORE
                                                  COMPONENTS
                                                      101
  THREE
COMPONENTS
    11Z

-------
                                                                     p.  11
 classified as "tampered" is presented in Figure 2.   A majority of  the




 tampered vehicles have multiple  components  tampered,  and  ten  percent of




 them have four or more instances of tampering.




      The vehicle condition classifications  are  broken out by  site  below.




 With the exceptions of Houston at the high  end  and  Los Angeles at  the  low,




 the overall tampering rates show relatively little  variation  from  site to




 site.  The high rate in Phoenix  is especially interesting in  light of  the




 area's  long-standing I/M program.






                     OVERALL VEHICLE CLASSIFICATION  BY SITE
Site
Chicago, IL
Denver , CO
Houston, TX
Los Angeles, CA
Phoenix, AZ
Sedgwick Co., KA
Entire survey
Tampered
27%
23
34
16
27
24
26
Arguably
tampered
42%
24
24
26
39
27
30
Malfunctioning
2%
2
4
3
1
4
3
Okay
29%
51
39
54
33
46
42
TRENDS - HOUSTON AND PHOENIX




     Only two sites included in this year's survey have been covered in prior




tampering surveys.  Houston has been studied in each survey conducted, and




Phoenix was studied earlier in the 1979 survey.  The trends for these sites




are presented graphically in Figure 3 and Figure 4.  A general upward




trend for Houston is evident from the chart, with a sharp increase in the




rates for this year's survey.  The Phoenix rates have obviously increased

-------
                                                            p.  12
  40


  35


o30
UJ
0£

125


"~20


  15
UJ
ca
UJ
  in
  AtJ


   5



   0
                        FIGURE 3
                        HOUSTON
Overall


«




|
j
I
I
I
a
»
<
«
i
i
*
»
i
t
»
I
1
1
k





Catalyst

Rnfl






Air
Tni.

i
t
t
>
f
t
^
i
f
0 1
in



EGR

1 ;
. : —n
nl




                                                      1978
1979

D
1981

S
1982


1983
                      YEAR OF SURVEY
                        FIGURE 4
                        PHOENIX
                                                     1979
                                                     1983
                       YEAR OF SURVEY

-------
                                                                     p.  13
 markedly from those of the 1979 survey.  The two sets of data on Phoenix are

 quite comparable with regard to vehicle procurement method and refusal  rates

 (inspection lanes and high refusal) but this survey examines  an older fleet,

 and the sample is more heavily weighted with trucks.   Recent  surveys in

 Houston prior to this one had very high refusal rates which may partially

 account for the sharp increases in rates.


 TYPES OF TAMPERING

      The incidence of tampering with specific emission control components

 and systems for the various  survey years is  presented in Table 1.  Only

 those vehicles  originally equipped with a particular  component are considered

 when computing  the tampering or arguable tampering  rate for that component.

      While  some component-specific trends were discussed in the summary,

 attention is again directed  to the increases in tampering  with catalytic

 converter,  PCV  system,  and evaporative  control system.   Most  of the

 component-specific rates  are higher in  1983  than for  previous surveys.

      Information on arguable  tampering  similar to that  presented in Table 1

 is  shown below:

      PREVALENCE  OF ARGUABLE TAMPERING BY COMPONENT  AND  SURVEY YEAR
Component
Limiter cap
Fuel tank cap
Tank label
Dash label
Heated air intake
1978
65%*
0
5
1
9
1979
62%
1
4
1
8
1981
83%
1
4
0
9
1982
54%
2
4
1
6
1983
54%
3
9
1
14
* Prevalence percentages in this report have usually been rounded to whole
  numbers.  As a result, some of the retrospective numbers will differ
  slightly from what was presented in earlier reports.

-------
                                                                     p. 14
                                  Table  1

              PREVALENCE  OF TAMPERING BY  COMPONENT AND SURVEY YEAR
Component /System
EGR* system
EGR control valve
EGR sensor
Air pump system
Air pump belt
Air pump/valve
Aspirator**
Catalytic converter
PCV* system
Vacuum spark retard
Idle stop solenoid
Heated air intake
Evaporative control
system
Filler neck restrictor
1978
13%
12
5
7
6
3
***
1
3
11
1
1
3

3
1979
10%
5
7
5
4
2
2
1
3
2
1
1
2

4
1981
5%
5
5
4
4
4
0
4
2
1
0
0
2

6
1982
10%
7
7
5
5
4
1
4
3
0
0
1
2

6
1983
13%
9
12
7
7
3
1
7
5
1
1
, ****
5

7
   * EGR: exhaust gas recirculation
     PCV: positive crankcase ventilation

  ** Vehicles with aspirated air systems are not equipped with other listed
     air-injection components, nor do conventional systems include aspirators.

 *** Aspirators were not checked during the 1978 survey.

**** As indicated in Appendix C, some codes for this component result in the
     conclusion that tampering has occurred, while others lead to a conclusion
     of arguable tampering.

-------
                                                                      p.  15
 Perhaps the most interesting finding among the arguable tampering  components




 is the prevalence of  tank label removal,  which parallels  the  increase in




 fuel switching activity otherwise indicated in this  survey.






 TAMPERING AND VEHICLE AGE




      Table 2 presents information on the  relation  between vehicle  age and




 the prevalence of tampering for the  current survey and  previous  surveys




 extending back to 1978.   In the same basic format, catalyst tampering infor-




 mation as related to  age is shown in Table 3.   The most immediately evident




 conclusion from these tables  is  that the  likelihood  of  a  vehicle's having




 been tampered with at some point in  its life increases  with age.   In just




 the 1983  survey data,  this  conclusion is  supported by examining  the top




 diagonal  of Table 2 which shows  an almost monotonic  increase  from  seven




 percent tampering among  vehicles  in  their first year to 55% tampering among




 the few nine-year-old 1975  vehicles  sampled in the survey.  Table  3 on




 catalyst  tampering shows  a .similar,  though less pronounced, increase on the




 diagonal  from 1% tampered among  first-year vehicles  to  12% among those in




 their  eighth year (that  percentage was almost  doubled in  the  ninth year, but




with a small sample size).  This  approach to reading the  table has the distinct




advantage  of comparing data that were all collected  at  one time  and in one




set of locations.   Using the  diagonal approach, we cannot, however, entirely




disentangle  the  effects of age from  effects  attributable  to model-year-specific




differences  in  performance and tamper-proneness that might lead  to different




tampering prevalence.




     Two alternative ways to  read the tables,  vertically  and horizontally,




incur  the difficulties of comparing  across  surveys.  The  effects of time and




geographic location become tied up with the  primary  interests in changing

-------
Model
Year
                                                    Table 2

           TAMPERING PREVALENCE AND SAMPLE SIZE BY MODEL YEAR AND VEHICLE AGE AT TIME OF SURVEY
                                                  Year of Vehicle Life
 First
 Second
Third
Fourth
Fifth
Sixth
Seventh    Eighth
Ninth
1983

1982

1981

1980

1979

1978

1977

1976

1975

1974

1973
7%(182)

1(25)

2(57)



6(371)

7(298)
 4%(226)

 7(448)

 5(63)



14(502)

10(457)
13%(206)

 9(454)

 9(59)



15(476)

18(395)
15%(211)

18(477)

15(79)



19(374)

22(274)
31%(288)

21(430)

21(66)



22(271)

33(276)
39%(238)

26(316)

29(52)



27(242)

32(253)
                                                                   44%(190)

                                                                   26(317)

                                                                   32(33)



                                                                   36(251)
                                                                   40%(171)

                                                                   37(183)
                                                                  55%(89)
                                                                                            •o

-------
                                                    Table 3
        PREVALENCE OF CATALYST REMOVAL AND SAMPLE SIZE BY MODEL YEAR AND VEHICLE AGE AT TIME OF SURVEY
Model
Year
                                                   Year of Vehicle Life
First
Second
Third
Fourth
Fifth
Sixth
Seventh    Eighth
Ninth
1983

1982

1981

1980

1979

1978

1977

1976

1975
0(250)*

0  (57)



0(326)

0(291)
1%(225)

2(441)

2 (61)



0(445)

1(417)
5%(204)

2(428)

4 (55)



1(417)

2(377)
3%(200)

6(429)

0 (71)



2(305)

2(242)
12%(252)

 4(362)    8%(213)

 2  (59)    2(271)

          10(48)

 2(204)
                                                                  11%(166)

                                                                   6(257)    12%(139)

                                                                  26(19)     12(139)
                                                                             23%(75)
 * Tampering  rates  have  been rounded to the nearest whole percent.  A zero does  not necessarily
  indicate the  total absence of  tampering,  but  rather a  level of tampering that rounded to zero.

-------
                                                                     p.  18
 technology (for vertical comparisons) and vehicle age (for horizontal com-




 parisons).




      Using the horizontal approach  to Table  2  we  see  a  definite  and




 monotonic increase with age throughout the table  for  all model years  except




 the pre-catalyst 1974  models.   The  1978 model  year, for example, displayed




 a seven percent tampering rate when it was first  examined in the 1978 survey.




 The current survey indicates that 39% of  the vehicles of the same model year




 (approximately six years old at the time  of  the 1983  survey) display  some




 form of tampering.  As mentioned above, this conclusion involves comparing




 observations  made  at different groupings  of  sites  and at different times,




 but the conclusion that  tampering prevalence increases  with  age  is nonethe-




 less  a  firm one.




      Vertical comparisons  of different  model years (and thus, generally,




 across  technologies) hold  the  age of  the  vehicle  constant.   For  example,




 thirteen percent of the  three-year-old  1981 vehicles seen in the current




 survey  had some tampering.  This is compared with data  from  the  1978  survey




 on  1976 vehicles which were about three years  old and had an 18% tampering




 prevalence.   Such  vertical  comparisons  in these tables  clearly reflect both




 any differences attributable to  changing  technology and changes  in general




 tampering  behavior over  time.  The  differing site  composition of the  surveys




 is an obvious  confounding factor when the  tables are read vertically.  The




 table on overall tampering shows no clearly discernible pattern—no sharp




 decrease in overall tampering attributable to  the introduction of closed-loop




 emission control systems in 1981.  This conclusion is reinforced by a similar




vertical reading of Table 3 on catalyst tampei^ns.  The table certainly does




not support the proposition of a prophylactic  effect of the  post-1980




technology.

-------
                                                                    p. 19
EFFECTS OF  INSPECTION AND MAINTENANCE ON TAMPERING




      Inspection  and maintenance (I/M) areas require vehicles to meet specific




idle  emission  standards.  Vehicles registered in these areas are required to




be periodically  tested to assure that they comply with the specific idle




emission cut-points established by these jurisdictions.  In addition to




reducing emission levels by stimulating better owner maintenance, these




I/M programs have generally been perceived to deter tampering with emission




control components.  Data from previous surveys have tended to support this




perception, since I/M area tampering rates have indeed been lower than non-I/M




rates.




     The 1983 motor vehicle tampering survey has incorporated two I/M sites




(Denver and Phoenix) and three Non-I/M sites (Chicago; Sedgwick County,




Kansas; and Houston).   Los Angeles, CA. was the sixth site to be inspected,




but cannot be legitimately classified as either an I/M or a non-I/M site




and is thus excluded from this particular analysis.




       Tampering rate differences.  A comparison was made of the overall




  tampering levels in I/M and non-I/M sites.   This rate is 29% for the non-




  I/M areas and 24% for the I/M areas.  The difference for cars only is more




  pronounced—29% in non-I/M areas compared with 22% in I/M areas.  Table 4




  presents the component or system-specific rates for I/M and non-I/M areas




  differentiated by vehicle type.




       These rates are  significantly  lower in the I/M areas for some major




  components.  In particular, catalytic converter tampering for cars in I/M




  areas is 3% as compared with the 10% non-I/M rate for cars.  Likewise, the




  rate of  tampering with cars' EGR systems in trie I/M areas is 10%, but 15%




  in the non-I/M areas.   Evaporative  system rates for cars reverse this

-------
                                               Table 4
            TAMPERING/FUEL SWITCHING PREVALENCE IN I/M AND NON-I/M AREAS BY VEHICLE TYPE
I/M areas
Tampering
Category cars trucks
At least one 22% 36%
component
tampered
Catalytic 3 16
converter
Air pump 7 15
system
Evaporative * 6 9
control system
PCV system * 54
EGR system * 10 21
Fuel Switched 9 25
Non-I/M areas Phoenix Denver
cars trucks cars trucks cars trucks
.29% 28% 23% 44% 21% 30%


10 12 3 25 38

79 8 23 69

46 5 12 77

5 10 84 25
15 15 5 19 15 23
15 23 9 39 9 13
* Since these systems do not control tailpipe emissions of pollutants covered in I/M programs,

   it can be logically argued that I/M areas should not differ from other areas with

   regard to the rates of tampering with these systems.
to
o

-------
                                                                     p.  21
 pattern, with higher rates in the areas covered by I/M programs.




      The truck rates reverse the pattern of differences seen for  cars, with




 I/M areas having higher rates on all of the tabled components except  the




 PCV system.  These higher I/M truck rates,  except for PCV and EGR systems,




 are attributable mostly to the rates for the Phoenix trucks  which,  as Table




 4 indicates,  are strikingly high.   Differences  in age distribution  between




 the Phoenix sample and the rest of the  survey can partially  account for  the




 higher Phoenix truck rates.   The presence of only two I/M sites in  the




 survey and the somewhat unusual nature  of the Phoenix data point  to a need




 for caution in drawing any conclusions  regarding  differences  attributable




 to  I/M programs.









 EFFECTS OF TAMPERING ON IDLE  TEST  FAILURE RATES




      As mentioned in the previous  section,  vehicles  which are subject to an




 I/M program must  meet specific  idle  emission cutpoints.  To assess  the




 effects tampering and fuel switching may have on  idle failure rates,  idle




 emissions  of vehicles  have been tested  against the cutpoints  established by




 the I/M programs  where they were sampled.   Vehicles  in the non-I/M  sites were




 tested  against  the cutpoints  specified  by the New Jersey I/M  program.




     The results  of  the idle  tests performed on survey vehicles are presented




 in  Figure  5 for vehicles in the  various tampering and fuel switching  cate-




gories.  Only eight percent of  the survey vehicles free of tampering  and




fuel switching failed an idle test, while slightly more than  half of  the




tampered and fuel switched vehicles failed  that test.   Certainly these




results indicate  that a substantially larger  proportion of tampered and  fuel




switched vehicles than  intact vehicles  fail  an idle  test at typical I/M

-------
                                            FIGURE  5

                          DISTRIBUTION OF SURVEY SAMPLE AMONG  TAMPERING,
                             FUEL SWITCHING, AND IDLE TEST  CATEGORIES
                                            Entire survey
                                               sample
                                                 100%
        Okay

        42%
                             Arguably
                             tampered
                               30%
                                              Tampered
                                                26%
Not fuel
switched
  96%
 Fuel  *
switched
Not fuel
switched
Not fuel
switched
62%


   Fuel
  switched

    38%
                                    Pass
                                    61%
                                                                                    39%
Pass
47%
                                                                                   Fail
                                                                                   53%
      These vehicles  do not have any mechanical tampering, but may be fuel switched  as  indicated by
      lead in  their fuel  tanks or a positive tailpipe test for lead.
                                                                                                             NJ
                                                                                                             NJ

-------
                                                                     p.  23
 outpoints.  It must be noted, though, that almost half of these vehicles with

 compromised emission control systems passed the idle test.   Failure  rates on

 specific pollutants are presented below.



       IDLE TEST FAILURE RATES BY POLLUTANT AND VEHICLE CONDITION
Okay
3%
HC
Arguably
Tampered tampered Cat. /Fuel*
26% 17% 30%
CO
Arguably
Okay Tampered Tampered Cat. /Fuel*
6% 19% 11% 14%
 * Vehicles in this category  either  have  their catalyst  removed or have
   at  least one of  the  three  indicators of fuel switching.
      In  general I/M sites  continue  to maintain  lower  idle  test  failure rates

than  non-I/M sites—17% for I/M compared with 32% for non-I/M.  The overall

survey rate  was 24%.  The  two  I/M areas included differed  considerably in

their failure rates-the rate for  Phoenix was 20%, as compared with

Denver's  14% rate.

      The  table on the following page presents the mean idle emission

levels for tampered and intact vehicles by  type of  area.   The idle test mean

for tampered vehicles is sharply  higher than that for intact ones.  Also the

means for non-I/M areas are higher  than for I/M areas.  The effect of the

I/M programs,  independent of differences in tampering rates, may be seen in

an examination of the "okay" levels, where  the  non-I/M HC  level is more than

double that  for the I/M areas.  The difference  is similar  for CO—0.7% for

non-I/M versus  0.4% for I/M.

-------
                                                                    p. 24
                              MEAN IDLE  EMISSIONS
HC(ppm)
Area
Entire survey
I/M areas
Non-I/M areas
Tampered
297.0
187.3
378.7
Okay
51.5
36.1
75.8
C0(%)
Tampered
2.5
1.8
2.9
Okay
0.5
0.4
0.7
FUEL-RELATED TAMPERING




     Multiple  indicators.  While a simple definition of fuel switching is




possible,  a single  indicator  for detection  of  this activity is very likely to




underestimate  its prevalence.  For instance, a vehicle which was repeatedly




improperly fueled with  leaded gasoline during  a  gasoline shortage may have a




deactivated catalytic converter, but due to proper subsequent fuel use may




have little detectable  lead in its fuel tank.  This situation may also




characterize the "occasional" user of leaded fuel.




     In order  to obtain a better picture of fuel switching, this survey




includes three indicators which, singly and in combination, may provide more




adequate information than any one measure by itself.  The indicators include




fuel filler inlet restrictor  tampering, a positive Plumbtesmo test for lead




deposits in the tailpipe, and the presence of more than 0.05 gram per gallon




of lead in  the gasoline.  While the presence of  lead in the fuel provides a




very strong indication  of switching, its absence does not indicate that




switching has not occurred in the past.  Likewise, but for different reasons,




the other  two measures  individually also present the problem of incorrect




negative findings where switching has actually occurred.  A vehicle with an




untampered  fuel filler  inlet  restrictor may have been fueled at a leaded

-------
                                                                    p. 25
 pump with a small sized nozzle or  with a  funnel  or similar  device.  The




 tailpipe lead test, due to  the difficulties of field administration, may




 fail to indicate the  presence of lead, and older vehicles may  have had their




 tailpipes replaced since they were operated on leaded  fuel.  The error in




 these measures,  then,  is always in the direction of underestimating the




 proportion of catalysts exposed to leaded  fuel.




      Fuel switching rates.   Of the vehicles requiring  unleaded fuel, 14% were




 identified as fuel switched by at  least one of the indicators  discussed above.




 Table 5 displays the  rates  found for  individual  indicators  as  well as the




 composite rates  for I/M and non-I/M areas.




      While fuel  switching rates have  increased somewhat  from those of the




 1982 survey,  both in general and for  the individual indicators, the most




 striking information in the table  is  the rates for I/M areas.   While the




 1982 survey examined different  sites  and comparisons are thus  difficult, each




 of  these 1983 rates is  approximately  double the  corresponding  1982 rates.




      Indicator overlap.  The survey results seem to show less  overlap than one




 might  expect  among these three indicators  of  the same  phenomenon.  The Venn




 diagram below illustrates this.  The  incomplete  overlap tends  to lend credence




 to  the position  that these  measures reflect different  aspects  of fuel switching




 activity.




      Since incorrect positive  indications  are extremely rare for these




measures,  the percentage of vehicles  with  at  least one positive indicator




 seems most reasonable as a  minimum estimate of the fuel switching rate in these




 cities.   Reasons  for the real  rate possibly being higher include the negative




 bias of  the field-administered  plumbtesmo  tailpipe test and the bias always




associated with  refusal to  participate in  a non-compulsory  survey.




The  latter bias has been kept  relatively low  in  this survey since all but

-------
                                                                     p.  26
                               Table  5




         FUEL SWITCHING RATES FOR CURRENT  SURVEY BY SITE AND INDICATOR
Percent with at Percent with
least one positive leaded fuel
Site indicator in tank
Chicago
Sedgwick Co., KA
Houston
All non-I/M
Denver
Phoenix
All I/M
Los Angeles*
All sites
18%
13
19
17
10
15
12
5
14
Non-I/M sites
9%
7
8
8
I/M sites
5
7
6
2
7
Percent with Percent with
tampered filler positive
restrictor tailpipe test
9%
6
9
8
4
12
8
3
7
13%
10
13
12
6
12
9
3
10
* Los Angeles is considered to be neither I/M nor non-I/M.

-------
                                                                     p.  27
 one of the sites involved roadside pullovers with their associated lower

 refusal rates.
                                 OVERLAP OF

                          FUEL SWITCHING INDICATORS
                    Positive
                   plumbtesmo
                  (167 cars total)
       Leaded fuel
         in tank
 22\(115 cars total)
cars
                                 Tampered
                              filler restrictor
                                (128 cars total
                  1751 total
                vehicles requiring
               unleaded fuel
     Catalyst tampering and fuel switching.  While  there may  be  a  variety  of

reasons why consumers and mechanics remove catalytic  converters, some  of this

motivation is obviously tied up with fuel switching.  The data from this

survey provide  little basis for inference regarding direction of causation

or the temporal ordering of these events in  the vehicle's life,  but it is  .

possible from the survey to at least examine the  extent to which these type%

of abuse occur  in conjunction.  Of the catalyst-equipped vehicles  in the

survey sample 16% were either catalyst-tampered or  fuel switched.   Thirteen

percent of the  vehicles in the I/M areas surveyed,  and 21% of the  catalyst

-------
                                                                     p. 28



 vehicles in non-I/M areas had one or both of these conditions.   The overlap


 between the conditions can be seen in the illustration below.
                        OVERLAP OF CATALYST TAMPERING
                              AND FUEL SWITCHING
                                                    Fuel
                                                  Switching
                                                   (222 total)
  Catalyst
 Tamperi ng
(119 total)
Vehicles with catalyst  tampering exclusive  of  fuel  switching were relatively


uncommon in  this sample—more than 60% of the  catalyst tampered vehicles also


were fuel  switched.  On the other hand,  fuel switching is by no means always


accompanied  by catalyst removal.  Sixty-seven  percent of the fuel switched


vehicles still had their catalysts.


     Gasoline  lead concentrations.  About half of the vehicles indicated to


be fuel switched by one of the three indicators had only trace amounts


(less than .02 gram per gallon) of lead  in  their fuel when inspected.  These


vehicles, then, were identified as fuel  switched by a tampered filler restrictor


and/or a positive plumbtesmo test for prior lead use.  The chart on the


following page presents the lead concentrations in the fuel of sampled


vehicles with  more than 0.05 gram per gallon in their gasoline.

-------
           O LU
           LU =}
           O Lu
          CD .-i




          S£ CO
          LU LU
          O _J


          LU l—l
40



35



30'



25-



20-



15- •







 5-



 0.

                          LEAD CONCENTRATIONS OF LEADED FUEL

                           SAMPLED FROM UNLEADED VEHICLES
                                                                     p.  29
                                       71
                                                               /
                                 /
                      CTk
                      O
                      ir>
                      o
                          Ot
           o
           o
                                          CT>   O*t
o
o
CM
O
O
O
O
O
o
o
o
o
o
                                                       oo
o
o
CO
    o
 I   O
o   o
o
CT>   i-i
                              GRAMS OF LEAD PER GALLON
Truck rates



     As indicated  previously,  the prevalence of tampering for light duty



trucks is higher than  that  for passenger cars.  The table on page 7 shows



the substantial differences in the rates.  Each emission component for the



light duty trucks  tends  to  have a higher prevalence of tampering than do the



cars.  Catalyst and filler  inlet restrictor tampering among trucks is double



the amount for cars.   Fuel  switching also tends to be considerably higher for



trucks—227, compared with 12%  for cars.

-------
                                                                     p.  30
 Manufacturer—specific rates




      As in most previous surveys,  tampering prevalence  in this  survey  is




 higher for domestic than for foreign manufacturers,  with vehicles  of Japanese




 manufacturers having the lowest  rates.   Among domestic  makers,  AMC and Ford




 have the highest prevalence at  35%,  followed by GM and  Chrysler at 26% and




 25% respectively.  These rates are shown in the graph below.
   40-.



   35-•



.9  30- -



   25- •



   20- •



   15-
               o:
               UJ
               o
               01
                 10-



                  5-




                  0-
                         TAMPERING PREVALENCE BY MANUFACTURER
V

/

/

/

/
                                V
/
V
/
/
/
/
                    /
                    /
                    /
                              /
                              /
                              /
                              /
x
/
/
/
/
/
                         GM   FORD    CHRY    AMC  EUROP.  JAPAN.


                         MANUFACTURER OR MFGR.  GROUPING
     Manufacturer differences in overall tampering may be due  to a variety of




factors including but not limited to manufacture.-specific tamper-proneness.




Market share history gives rise to differences in age distribution among

-------
                                                                 p. 31
vehicles of different makes, and age is clearly related to tampering prevalence.




Additionally, certain types of vehicles (trucks, for instance) are more likely




to be subjected to tampering than others, and thus makers with production




concentrated in these types can be expected to experience higher rates.

-------
                                                                          A - 1
                              APPENDIX A




                RELEVANT PORTIONS OF THE CLEAN AIR ACT









Section 203(a)(3):   The following acts and the causing thereof are prohibited —






    (A)  for any person to remove or render inoperative any  device  or  element  of




    design installed on or in a motor vehicle or motor vehicle engine  in compli-




    ance with regulations  under this title  prior to its sale and delivery to




    the ultimate purchaser, or for any manufacturer or dealer knowingly to




    remove or render inoperative any such device or element  of design  after




    such sale and delivery to the ultimate  purchaser;  or






    (B)  for any person engaged in the business of repairing,  servicing,  selling,




    leasing, or trading motor vehicles or motor vehicle engines, or who operates




    a fleet of motor vehicles,  knowingly  to remove or  render inoperative  any




    device or element of design installed on or in a motor vehicle  or  motor




    vehicle engine in compliance with regulations under this title  following its




    sale and delivery to the ultimate purchaser.

-------
                                                                      B -  1
                             APPENDIX B
              INSPECTION AND DATA RECORDING PROCEDURES

     The  inspection  teams consisted of five inspectors.  A designated team

 leader was  responsible for data and sample collection.  Each vehicle in-

 spection  included checking all emission control systems, recording basic

 data about  the vehicle including the addition of certain after-market parts,

 measuring HC  and CO  emissions at idle, obtaining a fuel sample, and using

 Plumbtesmo  paper to  check for lead deposits in the vehicle tailpipes.  The

 inspections focused  on 1975 and newer light-duty vehicles fueled with gaso-

 line.  This included both passenger cars and light-duty trucks.  The condi-

 tion of each  emission control device was determined and recorded on the

 inspection  forms in the field.  Categorization of  the results was not made

 at the time of the inspection—rather this was determined by evaluating the

 recorded data subsequent to the surveys.

     Below  is a listing of the sites, the inspection dates, the number

of vehicles inspected, the procedures used to obtain vehicles for

inspection, and the refusal rates.


        Cook County, Illinois

        Method of vehicle procurement:    Roadside pullover
        Dates of inspections:             Sept. 12 - Sept. 15, 1983
        Number of vehicles inspected:     268
        Refusal rate:                     1%

        Sedgwick County, Kansas

        Method of vehicle procurement:    Roadside pullover
        Dates of inspections:             Sept. 19 - Sept. 23, 1983
        Number of vehicles inspected:     290
        Refusal rate:                     9%

-------
                                                                            B - 2
             Houston, Texas

             Method of vehicle procurement:
             Dates of inspections:
             Number of vehicles inspected:
             Refusal rate:
Roadside pullover
Sept.  26 - Oct.  1,  1983
374
             Denver,  Colorado

             Method of  vehicle  procurement:
             Dates of inspections:
             Number of  vehicles inspected:
             Refusal  rate:
Roadside pullover
Oct. 3 - Oct. 7, 1983
332
3%
             Los Angeles, California

             Method of vehicle procurement:
             Dates of inspections:
             Number of vehicles inspected:
             Refusal rate:
Roadside pullover
Nov. 28 - Dec. 2, 1983
270
4%
            Phoenix, Arizona

            Method of vehicle procurement:
            Dates of inspections:
            Number of vehicles inspected:
            Refusal rate:
I/M inspection station
Dec. 5 - Dec. 9, 1983
297
26%
                        DATA RECORDING FORMS
     The forms on the following two pages were used for  recording  the survey

data in the field.  The forms are of the forced choice variety to  assure

consistency in coding.  They are designed to facilitate  direct data entry.

-------
                                TAMPERING SURVEY - PART A
Column ft

    1  ID Number I  I  I  I  I

    5  Odometer (Thou.) I  I  I  I

    8  Dash Label
       0 - Not orig. equipped
       1 - Functioning properly
       7 - Missing item

    9  Make I  I  I  I  I

    13 Model I  I  I  I  I

    17 Model Year III

    19 Vehicle Type
       1 - Car
       2 - Truck(includes vans)

    20 License Plate(State)  III

    22 Displacement  /  /  /  /  /
        (cubic inches or liters)

 ** NOTE:  If engine fam. is  missing  or  il-
    legible write "missing"  in item  26  and
    copy all but the last 6  digits of the
    VIN in item 37. DO NOT COPY SERIAL
    NUMBER PORTION OF VIN.

    26 Engine Family
    I   I   I  I  I  I  I  I  I   I   I  I
    37  VIN (if  engine fam.  info  not  avail.)
    I   I   I   I   I   I   I   I  I  I  I   I   I  I

    50  Originally  Catalyst  Equipped
       (from  sticker  under  hood  or driver's
       door post)
       1 - Yes
       2 - No
       3 — Can't tell (no sticker  or  not
          readable)

    51  Idle HC   /   /   III  (in  PPM)
Column
    55 Idle CO I  I  I  I  I  (in %)
       (to 1/10 percent)

    59  Plumbtesmo
        P - Positive
        N - Negative

    60  Tank Cap
        1 - Functioning properly
        7 - Missing Item
        9 - Malfunctioning

    61  Tank Label
        0 - Not orig.  equipped
        1 - Functioning properly
        7 - Missing item

    62  Filler Neck Restrictor
        0 - Not orig.  equipped
        1 - Functioning properly
        4 - Mech.  disc, (widened)
        7 - Missing item
    63  Catalytic Converter
        0 - Not  orig.  equipped
        1 - Functioning properly
        7 - Missing item
        9 - Malfunctioning

    64  Exhaust  System
        P - Original equipment
        N - Non-stock

    65  Exhaust  System Integrity
        1 - Functioning properly
            (no  obvious leaks)
        9 - Malfunctioning
            (leaks evident)

    66  Oxygen Sensor
        0 - Not  orig.  equipped
        1 - Functioning properly
        2 - Electrical disconnect
        4 - Mech.  disc, (unscrewed)
        7 - Missing item
      Inspector's Initials
     Date  /   /   /   /   /   /  /   /   /
          Day      Mon.     Yr.

-------
Col.  #

  1  ID number  I   I   I   I   I

  5  Air  Cleaner
      P - Orig. equip.
      6 - Non-stock
 6  Exhaust Manifold
     P - Orig. equip.
     6 - Non-stock

 7  Intake Manifold
     P - Orig. equip
     6 - Non-stock

 8  Distributor
     P - Orig. equip.
     6 - Non-stock

 9  Turbocharger
     0 - Not orig. equipped
     P - Original equipment
     6 - Non-stock
     A - Add-on

10  Carburetor Type
     P - Orig. equip.
         (non sealed.)
     S - Sealed carb.
     F - Fuel injection
         used
     6 - Non-stock carb

11  Carburetor barrels
     0 - Not orig. equipped
     1
     2
     4

12  Limiter Caps
     0 - Not orig. equipped
         (fuel injection)
     1 - Funct.  properly
     4 - Mech. disconnect
         (tabs broken or bent)
     7 - Missing item
     8 - Misadjusted (sealed
         plugs removed)
                                   TAMPERING SURVEY - PART B
Col. #

 13  PCV system
      0 - Not orig.  equipped
      1 - Funct.  properly
      3 — Vacuum  disconnect
      4 - Mech. disconnnect
          (fresh  air hose)
      6 - Non-stock  (Incl.  fuel
          economy devices)
      7 - Missing item

 14  Idle Stop Solenoid
      0 - Not orig.  equipped
      1 - Funct.  properly
      2 - Elect,  disconnect
      7 - Missing item
      9 - Malfunctioning

 15  Heated  Air Intake
      0 - Not orig.  equipped
      1 - Funct.  properly
      3 - Vacuum  disconnect
      4 - Mech. disconnect
      6 - Non-stock  (custom
          air cleaner)
      7 - Missing item
          (stovepipe hose)
      9 - Malfunct.  item
          (Vac. override)

 16  Evap. Control System
      0 - Not orig.  equipped
      1 - Funct.  properly
      3 - Vacuum  discon.
          (Carb.  line)
      4 - Mech. discon.
          (tank line)
      5 - Incorr.  routed hose
      7 - Missing item
      9 - Malfunct.  item (air
          cleaner unsealed)

 17  Aspirated Air Injection
     System
      0 - Not orig.  equipped
          (if conventional
          system  or  none)
      1 - Funct.  properly
      4 - Mech. disconnect
      7 - Missing item
      9 - Malfunctioning
Col. #

18  Air Pump Belt (if Aspir.,
    code "0")
     0 - Not orig. equipped
     1 - Funct. properly
     7 - Missing item
     8 - Misadjusted item
         (loose)

19  Air Pump System(incl valve)
     0 - Not orig. equipped(if
         aspirated or none)
     1 - Funct. properly
     4 - Mech. disc, (other
         than belt removal)
     7 - Missing item
     9 - Malfunctioning

20  EGR Control Valve
     0 - Not orig. equipped
     1 - Funct. properly
     3 - Vacuum disconnect
     7 - Missing item
     9 - Malfunct. item

21  EGR Sensor
     0 - Not orig. equipped
     1 - Funct. properly
     3 - Vacuum disconnect
     5 - Incorrect hose
         routing
     7 - Missing item
     9 - Malfunct. item

22  Vacuum Spark Retard
     0 - Not orig. equipped
     1 - Funct. properly
     2 - Elect, disconnect
     3 - Vacuum disconnect
               Inspector's initials
                            Date /////////
                                                                  Mon.    Day
                                                 Yr.

-------
                                                                           B - 5
      The  following codes were used  to record data for the major system




 components  on  the data sheets shown on pages B - 1 & B - 2.






          0 -  Not originally equipped




          1 -  Functioning properly




          2 -  Electrical disconnect




          3 -  Vacuum disconnect




          4 -  Mechanical disconnect




          5 -  Incorrect routed hose




          6 -  Non-stock




          7 -  Missing item




          8 -  Misadjusted item




          9 -  Malfunctioning






      Additional codes were used for those components which could not be




classified  into the  above categories.






a).   ID Number -  Vehicles are numbered sequentially as they are inspected.  This




      number is preceded by a site identifying letter.






b).   Odometer  - mileage in thousands






c).   Dash label - displays the required fuel and will be coded  'O1, '!' or  '7'.






d).  Make






e).  Model






f).  Model year - supplied by underhood emission label.

-------
                                                                           B - 6
 g).  Vehicle type - coded as follows:

           1 - car
           2 - truck


 h).  License plate (State)


 i).  Displacement - as  recorded by  the underhood emission label.


 j).  Engine family - as recorded  by the underhood emission label.


 k).  Non-serial  number  portion of VIN - as recorded from the passenger side of

      dash  under  windshield or driver's door post.  Recorded only if engine

      family cannot be determined.


 1).   Originally  catalyst equipped - as recorded by the underhood emission label

      or driver's  door panel.


 m).   Idle HC in ppm and CO in percent with the engine at curb idle.


 n).   Plumbtesmo  - Plumbtesmo paper  is used to check for the presence of lead in

      vehicle exhaust  pipes.  A positive indication is coded as  'P' and a negative

      as 'n1.


 o).  Tank cap - seals the fuel tank during normal operating conditions and will

      be coded  '!',  '?' or '9'.


 p).  Tank label -  displays required fuel and will be coded  '0', 'I1 or '7'.


 q).   Filler neck  inlet  restrictor (unleaded vehicles only).  The restrictor is

     designed to prevent the introduction of leaded fuel into a vehicle requiring

     unleaded fuel.   It will be coded  '0', flf, '4'(widened) or '7'.


r).  Catalytic converter - oxidizes the HC and CO to water and C02 in the exhaust

-------
                                                                           B -  7
      gases.  Later model catalysts also convert oxides of  nitrogen.   The  converter




      will be coded  'O1,  'I1,  '?'  (catalyst  removed  from cannister or entire




      cannister removed),  or '9'  (high temperature discoloration,  usually  light




      blue.






 s).   Exhaust system - if  originally  equipped a  'Pf is  coded.  If  non-stock an 'N1




      is  coded.






 t).   Exhaust system integrity - the  condition of  the exhaust system is




      coded  as follows:   'I1  (no obvious  leaks)  and  '9*  (leaks evident).






 u).   Oxygen sensor -  controls the air-fuel  mixture going  into the engine.




      Primary purpose is to work with 3-way catalytic converters.  The oxygen




      sensor will be coded   'O1, '!',  '2', '3' (unscrewed)  and '7'.






 v).   Inspector's initials -  quality  assurance measure.






 w).   Date






 x).   ID number - same as  (a).






     The codes below are used to record data for  components y through D.






          0 - Not  originally equipped




          P - Original equipment




          6 - Aftermarket or non-stock




          A - Add-on equipment




          S - Sealed carburetor




          F - Fuel injection used






y).  Air cleaner,  exhaust manifold,  intake manifold and  distributor - will be




     coded  'P1 or  '6'.

-------
                                                                           B - 8
 z).  Turbocharger -will be coded '0',  'P',  '6'  or  'A'.




 A).  Carburetor type -will be  coded   'P1,  'F1,  '6'  or  'S1.






 B).  Carburetor barrels - is coded '0'  or  the  actual number of barrels  (1,2,



      3 or 4).






 C).  Limiter caps - plastic caps  on idle mixture screws designed to limit carbure-




      tor  adjustments.    The limiter cap is coded '0',  '!',  '4' (tabs broken




      or bent),  '7*  or  '8*  (sealed plugs removed).






 D).  Positive  crankcase ventilation system—prevents  crankcase emissions by




      purging the  crankcase  of blow-by gases which leak between the piston rings



      and  the cylinder wall  in the combustion chamber when high pressures are




      developed  during the compression and power strokes.  The PCV system is




      coded  '0',  'I1,  '31,  '4' (fresh air hose),  '6f  (includes fuel economy devices)




      or '7'.






E).   Idle stop  solenoid - provides an idle stop for maintaining idle speeds at




      higher rpm levels  and  prevents the throttle plate from fully closing during




      deceleration in order  to minimize CO emissions.  The idle stop solenoid




     will be coded  '0',  '!', '2',  '7' or '9'.






F).  Heated air intake - provides warm air to the carburetor during cold




      engine operation.  The heated air intake will be coded '0', 'I1, '3', '4',




      '6' (custom  air cleaner),  '7* (stovepipe hose),  '9f (Vacuum override).






G).  Evaporative  control system - controls vapors from the fuel tank and



     carburetor.  Some systems have two lines, one from the fuel tank to the




     canister,  and one from the canister to the carburetor or air cleaner to air




     purge the  canister.

-------
                                                                           B - 9
      Other systems have  a  third  line, usually  connected to the carburetor.  The




      ECS  is coded '0',  '1',  '3'  (carburetor  line),  '4' (tank line),  '5',  '?'




      or  '9' (air cleaner unsealed).






H).  The  Air  Injection System keeps the exhaust emission levels within the specif-




      ied  limits  and still  maintains proper vehicle performance characteristics




      by extending the combustion process into the engine's exhaust system through




      the  injection of fresh air  into the exhaust ports.  The air injection system




      consists of  an air pump driven by a belt connected to the crankshaft pulley.




     The  pump directs air  through a control valve and lines connected to the




     exhaust manifold.  An air injection system may also consist of an aspirator




     located in the air cleaner that supplies air to the exhaust manifold.






     a),  aspirated air injection system - is coded '0' (if conventional




          system  or none), '!',  '4', '71 or  '9'.




     b).  air pump  belt (if Aspirated coded '0' )—is coded 'O1, 'I1, '71 or




           '8' (loose).




     c).  air pump  system - for the purpose of this report, consists of the air pump




          and the air pump valve and is coded '0' (is aspirated or none),




           'I1, '4'(other than belt removal),  '7' or '9'.






I).  Exhaust gas  recirculation system directs a portion of the exhaust gases back




     into the cylinders to reduce the amount  of NOx in the exhaust gases.  The




     standard EGR configuration consists of a vacuum line from the carburetor to




     a sensor (used to detect engine operating temperature to activate the EGR




     valve), and another vacuum line from the sensor to the EGR valve.






     a).   EGR control valve—is coded '0',  'I1, '3', '7'  or '91.

-------
                                                                           B - 10
     b).  EGR sensor - is coded '0', 'I1, '3', '5', '7' or '9'.






J).  Vacuum Spark Retard — retarding the spark during idle delays ignition within




     the combustion chamber and increases the exhaust temperature thereby prolong-




     ing the combustion process and reducing HC emissions.  Vacuum spark retard



     is coded '0', '!', '2' or '31.

-------
                                                                        C - 1

                          APPENDIX C

               CLASSIFICATION OF COMPONENT CONDITIONS

The table below is used to classify the various system components as 'tampered1,

'arguably tampered', or 'malfunctioning'.  Only those codes which are eligible

for use with a given component are listed.  Codes for 'not orginally equipped'

and 'functioning properly' are not included in this table.  Refer to page B - 4

for an explanation of the codes.

                                                 Codes from form
Component/system | 2 | 3 | 4
Dash Label
Tank Cap
Tank Label
Filler Neck Restrictor T
Catalyst Converter
Oxygen Sensor T T
PCV System . T T
Idle Stop Solenoid T
Heated Air Intake T A
Evaporative Control System T T
Aspirated Air Injection
System T
Air Pump Belt
Air Pump System T
EGR Control Valve T
EGR Sensor T
Vacuum Spark Retard T T
5 | 6 | 7 | 9 |
A
A
A
T
T M
T
T T
T M
T A M
T T M
T M
T
T M
T M
T T

    T =  tampered
    A =  arguably tampered
    M =  malfunctioning

-------
                                                                           D - 1




                            APPENDIX D




             FUEL  SAMPLE COLLECTION AND LABELING PROCEDURES
     A fuel sample  is  taken from each vehicle requiring unleaded fuel.




These samples are collected in 4 ounce bottles with a hand fuel pump.  Once




the sample is drawn, the fuel is replaced with an equivalent amount of




unleaded fuel if the driver requests, and the pump is flushed with unleaded



fuel.




     Each bottle is identified with a stick-on label that has the vehicle




identifying survey number on it.  The vehicle identifying survey number is the




first entry on data forms described in Attachment A.




     Prior to shipment from the field, a sample tag with the same identifying




number is attached to each bottle.  The bottles are packaged, labeled,



and shipped to the NEIC Chemistry Branch according to the shippers requirements




and the NEIC Policy and Procedures Manual.

-------
                                                                       E - 1
                        APPENDIX E

              METHOD OF APPLICATION OF PLUMBTESMO

1)  Clean a portion of the inside of the tailpipe large enough for the

    test paper by wiping it out with a paper towel or cloth.  This may be

    necessary in order to wipe away soot deposits which might mask the

    color change.

2)  Moisten the PLUMBTESMO with distilled water and immediately* press

    firmly for approximately thirty seconds against the surface to be

    tested.  If the tailpipe is hot you may wish to clamp the test paper

    in the tailpipe using a clean clamp.

    *Note;  The PLUMBTESMO paper must be applied during the time that the
            paper is yellow for the reaction to take place.  After approx-
            imately 15 seconds the yellow color disappears and the paper
            is no longer effective.  Excess water also interferes with
            the reaction.

    Care must be taken to avoid contamination of the test paper.  If a

    person has recently handled a test paper with a positive reaction, some

    lead or reactive chemical may have been transferred to their fingers.

    Handling a subsequent clean test paper may cause contamination.

3)  After removing the test paper,  wait approximately thirty seconds to

    make a determination.  A color change to red or pink splotches

    indicates the presence of lead.

-------
                                                                           F -  1




                                APPENDIX F




                       FIELD QUALITY CONTROL/ASSURANCE






     Reference and  calibration gases were used to assure the accuracy of the




emissions measuring instrument.  Horiba gases certified by RTP were used as




reference gases.  Two  cylinders of reference gas were used to validate the




accuracy of the calibration gases before they were taken to the field on each




survey.




     Three calibration gases (Horiba) were used.  These gases were a mixture




of CO and HC in nitrogen and were used to check the instrument at least three




times daily.  These calibration gases are certified by the manufacturer and the




RTP reference gases.  Their approximate concentration is:






          8% CO




          1560 ppm HC (Hexane equivalent)








          4% CO




          827 ppm HC (Hexane equivalent)









          1.6% CO




          320 ppm HC (Hexane equivalent)

-------
                                                                           G -  1
Location
                        APPENDIX G




               MOTOR VEHICLE TAMPERING SURVEY




            RECORD OF NON-PARTICIPATING VEHICLES







                                        Date
TIME
MAKE
MODEL
YEAR
REASON

-------
                                            Appendix H

                1983 tampering and fuel switching rates — by site and I/M program status
Tampering  Category
                 Sedgwick     Los                       I/M   Non-I/M   All
Chicago  Denver  County,KA  Angeles  Phoenix  Houston  areas   areas*  sites
At least one component
tampered
Catalytic converter
Filler restrictor
PCV system
Evaporative control
system
Air pump system **
E<3* system
Fuel switching categories
Any of three
indicators ***
Habitual (leaded fuel
or tampered filler)
* Los Angeles rates are

27%

15
10
4
1

7
12

18

13

23%

4
4
3
7

6
17

10

7

not included in

** Does not include aspirated

systems .
24%

7
6
4
2

10
14

13

9

the non-I/M


16% 27%

1 7
4 13
2 7
4 6

7 11
6 8

5 15

4 13

category.


34% 24% 29% 26%

9 5 10 7
9 887
9 565
8 745

9 977
19 12 15 13

19 12 17 14

13 10 12 10


a
i
*** Indicators include the presence of leaded fuel in the tank, a tampered fuel filler
     restrictor, and a positive plumbtesmo tailpipe test for lead deposits.

-------