United States       Office of Air
        Environmenta1 Protection and Radiation
        Agency           Washington. DC 20460
Scr.tamber ,987
        Air	

EPA    Motor  Vehicle  Tampering
         Survey -  1986

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United States Environmental Protection Agency

         Office of Air and Radiation
    MOTOR VEHICLE TAMPERING SURVEY - 1986

                September 1987
    FIELD OPERATIONS AND SUPPORT DIVISION
           OFFICE OF MOBILE SOURCES
               Washington, D.C.

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\
              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            WASHINGTON, B.C. 20460
                                 OCT  -5
                                                               OFFICE OF
                                                            AIR AND RADIATION
             1986 Motor Vehicle Tampering  Survey Report
             Al Mannato, Chief
             Regional/State/Local Coordination  Section
             Regional Librarians
MEMORANDUM

SUBJECT:

FROM:
TO:
       Two cfop-i-es—ofTThe Field Operations  and  Support  Division
  1986 Tampering Survey are enclosed  for  inclusion  to  your
  library's periodical section.  A  limited supply of  these
  reports are available, so please  retain  these  as  permanent
  copies and direct any specific inquiries to  your  Region's Air
  Management division, or have them write  to:

            U.S. EPA
            Office of Air And Radiation  (EN-397F)
            Regional/State/Local Coordination  Section
            401 M Street S.W.
            Washington, D.C.  20460

       Verbal inquiries can be directed to Paul  Argyropoulos at
  202-475-8839 those areas within Regions  I, III, V and  IX, by
  Deanna hughes at 202-475-8837 for those  areas  within Regions
  II, IV, VI, and X, and by Dean Ross at  202-382-2947  for  those
  areas within Regions VII and VIII.
                                                  OCT U 1987

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                      TABLE OF CONTENTS


EXECUTIVE SUMMARY  	  1

  Introduction	  1
  Conclusions  	  3

BACKGROUND  	  9

SURVEY METHODS	 11

  Site Descriptions  	 13

RESULTS  	 19

  Vehicle Tampering  	 19
    Site and Aggregate Totals 	 19
    Tampering Trends 1978-1986 	 21
    Types of Tampering 	 26
    Vehicle Characteristics and Tampering 	 26
      Manufacturer  	 29
      Vehicle Type  	 29
      Vehicle Age	 31
    Impact of I/M and Antitampering Programs 	 39
    Tampering Trends for Selected Sites  	 40
    Correlation Between Tampering and Idle Emissions 	 44

  Fuel Switching 	 49
    Fuel Switching Indicators and Overlap . . .	 49
    Fuel Switching Trends 	 52
    Fuel Switching by Vehicle Type 	 55
    Catalyst Tampering and Fuel Switching 	 55
    Gasoline Lead Concentrations 	 60

APPENDICIES

    A.  Relevant Portions of Clean Air Act 	 62
    B.  Survey and Data Recording Procedures 	 63
    C.  Emission Cutpoint for I/M Areas  	 77
                             -i-

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                       LIST OF FIGURES
 1.  Component specific tampering:
     1982-1986 surveys  	   4

 2.  Overall and catalyst tampering by vehicle model
     year - 1986 survey  	  7

 3.  Breakdown of surveyed vehicles by condition and
     extent of tampering 	  20

 4.  Tampering rates by manufacturer: 1986 survey	30

 5.  Comparison of LOT and LDV tampering in the 1982-1986
     surveys	  32

 6.  Cumulative tampering prevalence as a function of
     vehicle age for the 1982-1986 surveys	  37

 7.  Cumulative catalyst tampering rates as a function
     of vehicle age for the 1982-1986 surveys ...	  38

 8.  Distribution of survey sample among tampering,  fuel
     switching, and idle test categories	..45

 9.  Overlap of fuel switching indicators among unleaded
     vehicles - 1986 survey	  51

10.  Overlap of catalyst tampering and fuel switching
     among catalyst-equipped vehicles - 1986 survey 	  57

11.  Overlap of indicators used by ATPs to detect missing/
     damaged catalysts-1986 survey	  59

12.  Lead concentrations in leaded fuel sampled from
     misfueled vehicles	  61
                             -11-

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                        LIST OF TABLES
 1.   Tampering Prevalence by Vehicle Type for
     Critical Control Components 	,	   7

 2.   1986 Tampering Survey Summary 	  22

 3.   Trends in Vehicle Condition Classification 	  23

 4.  - Comparison of EGR System Tampering to Overall
     Tampering in the 1982-1986 Surveys	  25

 5.   Comparison of 1986 Survey Sample to Actual
     Nationwide Vehicle Fleet 	  25

 6.   Prevalence of Tampering by Component and Survey
     Year	  27

 7.   Component-Specific Tampering Rates (percent) by
     Survey Location - 1986 Survey 	  28

 8.   Tampering Prevalence (and Sample Size) by Model
     Year and Vehicle Age at Time of Survey 	  33

 9.   Percentage of Catalyst Removal (and Sample Size)
     among Catalyst-Equipped Vehicles by Model Year
     and Vehicle Age at Time of Survey 	  34

10.   Tampering Prevalence among Vehicles and Components
     Covered by Three Antitampering Programs for the
     1983-1986 Surveys 	  42

11.   Comparison of Tampering among Missouri Vehicles
     (I/M + ATP) and Illinois Vehicles (non-I/M)
     Surveyed in St. Louis, MO and East St. Louis, IL
     in 1986	  42

12.   Idle Test Failure Rates (percent) by
     Pollutant and Vehicle Condition 	  47
                            -111-

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13.   Mean Idle Emissions by Vehicle Condition 	  47

14.   Fuel Switching Rates among Unleaded Vehicles by
     Site and Indicator - 1986 Survey 	  53

15.   Fuel Switching Rates among Unleaded Vehicles by
     Indicator and Survey Year 	  54

16.   Combined Tampering and Fuel Switching - 1986 Survey .  56

17.   Percentage of Fuel Switching Indicators by Vehicle
     Type	  57
                             -iv-

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                      EXECUTIVE SUMMARY


                         INTRODUCTION

     Under the direction of the Field Operations and Support

Division (FOSD) of the Environmental Protection Agency (EPA),

contract personnel from Colorado State University (CSU)

conducted a survey of light-duty motor vehicle tampering in

15 cities between April and September, 1986.  The areas surveyed

and the total number of vehicles inspected are listed below.
St. Louis, MO         413
East St. Louis, IL    551
Jacksonville, FL      477
Orlando, FL           575
Houston, TX           507
Memphis, TN           580
Pittsburgh, PA        504
Richmond, VA          500
Hartford, CT
Camden, NJ
Covington, KY
Seattle, WA
Los Angeles, CA
Tucson, AZ
Baton Rouge, LA
428
498
500
504
505
499
500
                                 TOTAL
          7,541 vehicles
The objectives of this survey were:

     1. To make local measurements of the types and extent of
        tampering and fuel switching.

     2. To extend and update the knowledge gained from earlier
        surveys on:

        a. The rates of overall and component-specific
           tampering and fuel switching.

        b. The distribution of tampering by vehicle age,
           type, manufacturer, and other variables of
           interest.

        c. The relationship between tampering and vehicle
           idle emissions.

        d. The effect of vehicle inspection and maintenance
           (I/M) programs and antitamper ing programs (ATPs)
           on tampering and fuel switching.

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                             — 2—


     To achieve these objectives,  the inspection teams

visually examined emission control devices and measured the

idle hydrocarbon (HC) and carbon monoxide (CO) emissions of

each vehicle.  To provide information on fuel switching, the

inspectors sampled gasoline from the tanks of vehicles  (for

later laboratory lead analysis), tested for lead deposits in

tailpipes using Plumbtesmo® test paper, and checked the

integrity of the fuel filler inlet restrictors.   Four cate-

gories were used to summarize the condition of the inspected

vehicles:

     1. Tampered - at least one control device removed or
        rendered inoperative

     2. Arguably Tampered - possible but not clear-cut
        tampering (i.e., may have resulted from either
        tampering or malmaintenance)

     3. Malfunctioning

     4. Okay - all control devices present and apparently
        operating properly

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.

     While the data from a survey such as this seem to invite

inferences regarding program effectiveness,  trends, etc., this

approach can easily lead to incorrect conclusions.  The sample

size is reasonably adequate for evaluating tampering prevalence

in any particular site,  but the sampling of sites is neither

large nor random.  Simple comparisons of  tampering by site

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across control program categories, for example, can overlook



a variety of confounding factors.  These may include geographi-



cal variability, fleet age structure and vehicle mix, variations



in program maturity, coverage, history, and management, and



the interactions among these factors.  Straightforward



experimental control of these variables, difficult to achieve



under the best of circumstances, becomes impossible in a



situation where site selection is driven by programmatic



considerations unrelated to the experimental questions.






                         CONCLUSIONS



     In this study the vehicles surveyed were classified as



follows:  tampered - 20%; arguably tampered - 25%; malfunc-



tioning - 1%; okay - 54% (overall survey averages).  This



gross classification, while useful for some comparisons,  is



less informative concerning the emissions impact of tampering



than an examination of component-specific rates.  The



percentage of tampered vehicles (20%) is the same as was



found in the 1985 survey.



     Component-specific tampering for selected critical



components is shown in Figure 1.  The results shown have not



been weighted to compensate for I/M program representation;



these rates probably underestimate the actual nationwide rates.

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Component or SystQm
Catalytic Converter
 Evaporative  System
    Air Pump  System
   Inlet Restrictor
         PCV  System
         EGR System
                     ////////////////////A 82
                                Tamponing  (%)
              1982


              1983


              1984


              1985


              1986
                                                          J 132
        •Change In classification of evaporative system tampering.
         hava been 42 using prior classification mathad.
Tampering rate would
         Figure  1.    ComponQnt-spgcific tamporing:
                       1982 -  1986 surveys.

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Tampering with evaporative and air pump systems has increased

since 1985, while the rates for other components have remained

unchanged.  The increase  in evaporative system tampering,

however, is the result of a change in the classification metho-

dology in the 1986 survey, as will be discussed later in the

report.  Evaporative system tampering would have been 4% using

the methodology from earlier surveys.

     ,The catalytic converter removal rate for the 1986 survey

was 5% .overall.  Catalytic converter removal increases HC and

CO emissions by an average of 475%, and 425%, respectively.1

For vehicles equipped with three-way converters, substantial

increases in NOX emissions would also be expected to occur.

     The air pump system was the most frequently tampered

system (8%) .  This is the first survey is which air pump

tampering was the most prevalent form of tampering.


Fuel Switching

     Fuel switching,  defined as the presence of any of the .

three indicators^, was found in 9% of the unleaded vehicles in

the 1986 survey. , The pattern of overlap among the three misfueling
1  The emissions increases mentioned in this report are from a
study of three-way catalyst vehicles presented in Anti-Tampering
and Anti-Misfueling Programs to Reduce In-Use Emissions from
Motor Vehicles, EPA-AA-TTS-83-10,  December 31, 1983.

2  The three fuel switching indicators are: a tampered fuel
filler inlet restrictor,  a positive Plumbtesmo® tailpipe test,
or a gasoline lead concentration of more than 0.05 gram per
gallon.

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                              -6-






indicators is discussed in detail later in this report.  While



the emissions impact of fuel switching depends upon its duration



and certain vehicle characteristics,  emission increases of 475%



for HC and 425% for CO can easily occur.





Age of Vehicle



     The probability that a vehicle has been tampered with is



clearly related to its age, as has been shown in previous



surveys.  This is evident in Figure 2,  which shows the rates



by model year for both overall tampering  and catalyst removal.



These age-specific rates are investigated more thoroughly later



in this report•





Vehicle Types



     The tampering rates for light-duty trucks were equal to



or higher than for automobiles in every tampering category,  as -



shown in Table 1.  Overall tampering  with trucks was the same



as for automobiles (20%), marking the first time overall truck



tampering has not exceeded overall automobile tampering.  This



trend is discussed in greater detail  later in this report.



Converter tampering on trucks remained much greater than on



automobiles (9% vs 5%) and fuel switching among trucks was



greater as well (11% vs 8%).

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                        -7-
                                                        Dvorall Tampering


                                                       Cotalyvt Toaparlng
                                                           --0--
1986  1985  1884  1883  1882 1881  1880  1878  1878  1877 1978  1875
                    Vahlcla Modal Yaor
    Figure 2.  Ovarall and catalyst  tampering  by
                vehicle modal year -  1986 survey.
                        TABLE 1

      Tampering  Prevalence by Vehicle Type for
            Critical Control Components

                               Tampering Rate (%)
Component /System
Catalytic Converter
Filler Neck Restrictor
Air Pump System
PCV System
Evaporative Control
System
EGR System
OVERALL
Trucks
9
8
10
5
8
7
20
Cars
5
7
8
5
5
7
20
Overall
5
7
8
5
6
7
20
Fuel  Switching
11
8

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                               -8-



  I/M Programs  and  Tampering



       Tampering  in non-I/M sites surveyed was 24%, while



  tampering  in  ATP-only,  I/M-only, and  I/M + ATP  sites  were



  20%,  18%,  and 17%,  respectively.  Fuel switching was  likewise



.  greater, in non-I/M areas  (12%)  than in ATP-only, I/M-only,



  and I/M +  ATP areas (8%, 8%, 6%, respectively).  Such



  comparisons across program categories should be made  very



  carefully,  since  the number of  sites per program category



  is  small enough that site-specific factors other than program



  type  may greatly  influence tampering prevalence.  In  addition,



  the classification of  sites into program categories is



  necessarily somewhat rough.  The antitampering  program in



  Baton Rouge,  for  example, only  covers 1980 and  newer  vehicles.



  New Jersey's  antitampering program, which was being phased



  in  over a  16  month period, only covered 1982 and newer vehicles .



  at  the time of  the survey.  Because of restricted program



  coverage aimed  at newer vehicles (those less likely to be



  tampered with because  of warranty status and age) the impact



  of  newly implemented programs may not be observable for



  several years.  The effectiveness of control programs in



  deterring  tampering among components and model  years  covered



  by  each specific  program will be investigated later in this



  report.

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                           BACKGROUND



     Motor vehicle emissions in urban areas account for nearly



90% of the total carbon monoxide  (CO) and airborne lead, over



30% of the hydrocarbons (HC), and nearly 40% of the oxides of



nitrogen  (NOX) emitted into the atmosphere.  As a result, a major



focus of  the nation's efforts to achieve compliance with clean



air standards has been the control of emissions from mobile



sources.  The first pollution control devices were installed on



vehicles  in 1962, and most light-duty vehicles manufactured



since 1968 have been equipped with a variety of emission control



devices to meet required emissions standards.



     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.   Regulations issued under section



211(c) of the Act (40 CFR Part 80) prohibit retailers and



wholesale purchaser-consumers from introducing or allowing the



introduction of leaded gasoline into vehicles labeled "unleaded



gasoline only".  The EPA's Field Operations and Support Division



(FOSD),  formerly the Mobile Source Enforcement Division (MSED),



is responsible for enforcing the tampering and misfueling



provisions of the Act.

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                              -10-



     Before 1978, the EPA had data -suggesting that tampering



with emission control devices and misfueling of "unleaded only"



vehicles with leaded gasoline was occurring.  Variability in



the inspection procedures,  however,  prevented an accurate



assessment of the nature and extent of the tampering.  As a



result, the Agency began conducting nationwide tampering



surveys of light-duty motor vehicles in 1978 to determine the



rates and types of tampering and fuel switching.  These



annual surveys have been conducted either by FOSD directly or



by EPA's National Enforcement Investigations Center (NEIC)



under the direction of FOSD.  Consistent inspection procedures



were used throughout these surveys to permit comparisons and



identification of trends.



     :The uses for the tampering surveys have evolved since the



first survey was conducted in 1978.  Since 1983, the tampering



survey results for some locations have been used to calculate



credits for State Implementation Plans (SIPs), the measures



taken by State and local governments to achieve ambient air



quality standards by reducing mobile source emissions.  Data



from the surveys is also used in the default database for the



Agency's mobile source computer model (MOBILES) to estimate



both the emissions loading impact and the reductions that may



be achieved by various control programs.  Sites for the surveys



are chosen in light of the need for data on specific areas



either currently operating or considering programs, as well as



the continuing need to monitor the types and extent of tampering



and fuel switching nationwide.

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                             -11-

                        SURVEY METHODS

     The 1986 tampering survey was conducted for FOSD by the

National Center for Vehicle Emissions Control and Safety at

Colorado State University (CSU).  Approximately 400 to 600

vehicles were inspected in each of 15 cities between April

and September, 1986, and the entire survey includes 7,541

vehicles.  The mix of vehicles inspected was assumed to be a

self-weighting sample, and no attempt was made to approximate

the national vehicle mix.

     Each inspection team consisted of at least four members:

three CSU personnel, one or two EPA representatives, and fre-

quently a state or local agency representative.  The CSU

personnel, assisted by the state or local person, performed

the actual inspections,  while the EPA representative(s)

supervised the survey.  Each vehicle inspection included the

following:

     1.  basic vehicle identification data recorded (year,
         make, model)

     2.  all emission control systems checked

     3.  idle HC and CO emissions measured

     4.  fuel sample collected from unleaded-only vehicles for
         lead analysi s

     5.  tailpipe tested for lead deposits using Plumbtesmo®-'-
         test paper

     6.  integrity of fuel inlet restrictor checked
1  Plumbtesmo® is a registered trademark, and appears hereafter
without the ®.  It is manufactured by Machery-Nagel, Duren, W.
Germany, and marketed by Gallard-Schlesinger Chemical Corp.,
Carle Place, New York.

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                             - 12-





     Th e inspection procedures used were consistent with



those of previous surveys,  except for one change made in the



classification methodology for evaporative system tampering.



In prior surveys a vehicle with a unsealed air cleaner was



coded as malfunctioning for the evaporative system.  In 1986



an unsealed air cleaner was receded as tampering to reflect



the deliberate nature of this condition.  As a result,



evaporative system tampering in 1986 was significantly higher



than it would have been if the coding system from earlier



surveys was used.  The inspection and recording procedures.



are detailed in Appendix B.



     The survey database has been reviewed by CSU and EPA to



ensure its accuracy,  and has been offered to the major



automotive manufacturers to review the classification and



reporting of their respective vehicles.



     The tampering survey included only 1975 and newer



light-duty cars and trucks fueled with gasoline.  For the



purposes of the tampering surveys,  a vehicle is considered



to be "unleaded" if a dash label, tank label, or filler inlet



restrictor is observed at the time of the inspection, or if



the emission control  label indicates an unleaded fuel



requirement (i.e.,  catalyst-equipped).  A vehicle's designation



as "unleaded" or "leaded" may be changed upon subsequent

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                               -13-


 review of the data.   Fuel switching rates are thus based

 only on the population of unleaded vehicles  surveyed.

 Similarly,  tampering rates for specific components are based

 only on the vehicles originally equipped with the  component.

      The inspections were performed with the consent of the

 vehicle owners at  either  roadside  pullovers  or inspection

 stations.  The survey was designed to minimize the refusal

 rate of potential  survey  participants.   A high refusal rate

 increases the uncertainty in the data gathered,  since

 individuals who have tampered with or misfueled  their vehicles

 are less likely to allow  their vehicles to be surveyed.  The

 overall refusal rate was  very low  (4%),  however, and no

 survey sites had a refusal rate over 10%.  A brief description

 of  each survey site  follows.   Unless otherwise noted,  the

.survey., sites within  a given city were changed daily.

 St.  Louis,  Missouri  - I/M + ATP

 Dates:                April 14 - 18,  1986
 Vehicles Surveyed:        413
 Fuel Samples:             338
 Refusal Rate:              10%

      The St. Louis Police Department provided officers to

 stop potential survey participants,  and the  inspectors solicited

 permission  to conduct the inspections.   The  decentralized I/M

 program includes a catalytic converter inspection  on 1981 and

 later vehicles, and  air pump,  PCV,  and  EGR inspections on all

 vehicles.

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                             -14-

East St. Louis, Illinois - non-I/M

Dates:.               April 21 - 25,  1986
Vehicles Surveyed:       551
Fuel Samples:    .        392
Refusal Rate:  '            5%

     Roadside pullovers were conducted with the help of the

Illinois State Police.  Inspection locations included East

St. Louis (two days),  Washington Park (2 days), and Alorton.


Jacksonville, Florida - non-I/M

Dates:               May 5-9, 1986
Vehicles Surveyed:       477
Fuel Samples:            426
Refusal Rate:              3%


Orlando, Florida - non-I/M

Dates:               May 12 - 16, 1986
Vehicles Surveyed:       575
Fuel Samples:            475
Refusal Rate:              4%

     Roadside pullovers were conducted with the assistance

of the Florida State Police in both Jacksonville and Orlando.


Houston, Texas - ATP-Only

Dates:               May 19 - 23, 1986
Vehicles Surveyed:       507
Fuel Samples:            422
Refusal Rate:              7%

     The Texas Department of Public Safety provided officers

to assist with the roadside pullovers.  Inspection locations

included Houston (three days),  La Porte, and South Houston.

The decentralized antitampering program includes Plumbtesmo

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                             -15-

testing and  inspection of the catalytic converters and inlet

restrictors  on 1980 and newer vehicles, and inspection of the

PCV, air pump, EGR, and evaporative systems on 1968 and later

vehicles.


Memphis, Tennessee - I/M-only

Dates:               June 2 - 6, 1986
Vehicles Surveyed:       580
Fuel Samples:            464
Refusal Rate:              1%

     The survey was conducted each day at the downtown centralized

inspection station in Memphis.  .The inspection team set up

and conducted the survey while vehicles were undergoing the

emissions and safety inspection.  The I/M program in Memphis

covers all model years of light duty vehicles.


Pittsburgh,  Pennsylvania - I/M-only

Dates:               June 16 - 20, 1986
Vehicles. Surveyed:       504
Fuel Samples:            401
Refusal Rate:              4%

     The Pittsburgh survey .was ^conducted us.ing roadside

pullovers in the townships.of Penn Hills, Moon, Ross, Shaler,

and Robinson with the help of the local law enforcement

officers in  these municipalities.  Pittsburgh's decentralized

I/M program  covers 1968 and newer vehicles.


Richmond, Virginia - ATP-only

Dates:               June 23 - 27, 1986
Vehicles Surveyed:       500
Fuel Samples:            395
Refusal Rate:              4%

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                             -16-

     The Richmond survey was conducted using roadside pullovers

with the assistance of the Virginia State Police.  Richmond

has an antitampering inspection incorporated into its annual

safety inspection program.


Hartford, Connecticut - I/M-only

Dates:               July 7 - 11, 1986
Vehicles Surveyed:       428
Fuel Samples:            341
Refusal Rate:              7%

     The Hartford Police Department assisted with the roadside

pullovers.  Hartford's centralized I/M program covers 1968

and newer vehicles.


Camden, New Jersey - I/M + ATP

Dates:               July 14 - 18,  1986
Vehicles Surveyed:       498
Fuel Samples:            394
Refusal Rate:              8%

     The New Jersey Police Department assisted with the

roadside pullovers.  New Jersey's I/M program dates back to

1974,  and the antitampering inspection is being phased in to

cover 1975 and newer vehicles by May 1987.  At the time of

the survey the ATP included a catalytic converter and inlet

restrictor check on 1982 and newer vehicles.


Covington, Kentucky — non-I/M

Dates:               July 21 - 25,  1986
Vehicles Surveyed:       500
Fuel Samples:            403
Refusal Rate:              4%

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                             -17-

     The Covington survey was conducted in Boone County (two

days), Campbell County, and Kenton County (two days).  The

respective County Police Departments assisted with the road-

side pullovers.  Covington was a non-I/M area at the time of

the survey, but implemented a decentralized ATP-only in

September 1986.


Seattle, Washington - I/M-only

Dates:               August 12 -16, 1986
Vehicles Surveyed:       504
Fuel Samples:            311
Refusal Rate:              3%

     The survey was conducted at five centralized I/M stations

in the metropolitan Seattle area.  Seattle's I/M program

covers all vehicles in the most recent 13 model years.


Los Angeles, California— I/M + ATP

Dates:               August 25 - 29,  1986
Vehicles Surveyed:       505
Fuel Samples:            373
Refusal Rate:              3%

     The California Highway Patrol provided officers to assist

with the roadside pullovers.  The decentralized I/M + ATP

includes inspection of the catalytic converter, air pump,

PCV, EGR, and evaporative systems on all vehicles.


Tucson, Arizona - I/M-only

Dates:               September 8-12, 1986
Vehicles Surveyed:       499
Fuel Samples:            382
Refusal Rate:              1%

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                             -18-

     Th e Tucson survey was conducted at three centralized I/M

stations.  Tucson was  an I/M-only area at the time of the

survey, but added an ATP covering 1975 and newer vehicles in

January 1987.


Baton Rouge, Louisiana - ATP-only

Dates:               September 15 - 19, 1986
Vehicles Surveyed:       500
Fuel Samples:             451
Refusal Rate:               4%

     The Baton Rouge survey was conducted using roadside

pullovers with the assistance of the Louisiana State Police.

Survey locations were  the same as in the 1985 survey.  The

decentralized ATP was  implemented in September 1985, and

includes a check of the converter,  inlet restrictor, and

Plumbtesmo test on 1980 and newer model year vehicles.

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                             -19-

                            RESLJLTS

A. VEHICLE TAMPERING

1. Site and Aggregate Totals

     The vehicles surveyed have been classified into four

categories established by previous surveys: tampered,

arguably tampered, malfunctioning, and okay.  Each vehicle

was classified by the worst state of any component in the

vehicle.  For example, a vehicle would be classified as

"tampered" if any one component had been tampered, even if

all other components were functioning properly.  A vehicle

classified as "okay" must have all observed components

functioning properly!.  ^^e criteria used for component

classification are presented in Appendix B.  This overall

tampering rate is useful only as a rough indicator of the

emissions impact of a tampering problem, since the different

components making up the rate may have widely varying emissions

implications.

     The proportion of inspected vehicles with at least one

tampered component was 20%.  Nearly half of the vehicles

surveyed (46%) displayed some form of malfunction, arguable

tampering, or clear tampering of emission control components.

The specific distribution of surveyed vehicles among these

categories is depicted in Figure 3.
1  An "okay" vehicle, however, may still be classified as
fuel switched (see section 3.1., Fuel Switching Indicators
and Overlap of this report).

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Malfunctioning
    (1%)
                     Arguably Tampered
                          (25%)
                                  Tampered
                                   (20%)
       Okay
       (54%)
four or more  (15%)
three (10%)

-two (21%)
                                                          -one  (54%)
                      O
    Condition of Surveyed Vehicles     Number of Tampered Components
 Figure  3.    Breakdown  of surveyed vehicles by  condition  and
              extent of  tampering.

-------
                            -21-



     The frequency distribution of tampering instances for



those vehicles classified as "tampered" is also shown in



Figure 3.  Forty-six percent of the tampered vehicles had



multiple components tampered,  and 15% had four or more



instances of tampering.



     Table 2 summarizes the 1986 survey data by site.  As



in previous surveys, the overall tampering in 1986 varies



considerably from site to site.  This can be attributed



to the variety of program configurations among the cities



surveyed and to geographic differences.



     Table 2 also contains the refusal rate at each survey



site.  The overall refusal rate for the survey was very



low (4%), and only one survey site (St. Louis) had a refusal



rate equal to or exceeding 10%.  The actual tampering rate



in St. Louis may thus be higher than is reported here,



since individuals who tamper with or misfuel their vehicles



are less likely to allow their vehicles to be surveyed.






2.  Tampering Trends 1978-1986



     Table 3 shows the overall rates found in each of the



eight tampering surveys.  Overall tampering and arguable



tampering generally appear to be decreasing,  and the percent



of properly maintained vehicles has been steadily increasing,



The decrease in overall tampering can be examined more



carefully by separating NOx-related tampering (EGR system

-------
                                -22-
Survey
Location
             TABLE 2

  1986 Tampering Survey Summary

Number of  Tampering  Misfueling  Survey   Refusal
Vehicles   Rate (%)   Ra^e^J^j	  Type*    Rate (%)
St. Louis, MO

East St. Louis, MO

Jacksonville, FL

Orlando, FL

Houston, TX

Memphis, TN

Pittsburgh, PA

Ri chmond,  VA

Hartford,  CT

Camden, NJ

Covington, KY

Seattle, WA

Los Angeles, CA

Tucson, AZ

Baton Rouge, LA
413
0 551
477
575
507
580
504
500
428
498
500
504
505
499
500
15
23
21
26
24
21
12
14
13
19
24
18
15
25
23
4
8
9
15
9
14
4
5
5
6
15
4
6
10
10
R
R
R
R
R
C
R
R
R
R
R
C
R
C
R
10
5
3
4
7
1
4
4
7
8
4
3
3
1
4
OVERALL
 7,541
20
  *R = roadside pullovers, C = centralized I/M stations

-------
                           -2.3-
                          TABLE 3

         Trends in Vehicle Condition Classification
Survey
Year
1978
1979
1981*
1982
1983
1984
1985
1986
Tampered
19
18
14
17
25
22
20
20
Arguably
Tamper ed(%)
48
47
45
38
30
29
27
25
Malfunctioning
2
2
3
1
3
4
1
1
Oka;
31
33
38
44
42
46
52
54
*Because the 1981 survey involved only two sites and a very
 limited sample size, these results may exhibit more variance
 than the other larger surveys.

-------
                             -24-
tampering) from HC- and CO-related tampering.  Table 4
shows that HC- and CO-related tampering have in fact remained
relatively constant since 1983.   EGR tampering, however,
has declined markedly since 1983.
     Direct comparisons between survey years should be made
carefully, since they do not take into account differences
among"; surveys in site .selection, vehicle age, and car/truck
distributions.'  More importantly, because of the 1986
survey's specific goals, it greatly overrepresents the portion
of the national vehicle fleet under local control programs
(see Table 5).  Areas with control programs comprised 72% of
the survey sample, while only approximately 41% of the national
vehicle fleet were under such programs.
     This discrepancy can be corrected to some degree by
applying a weighting factor to the tampering rates found
under each program type.   The 1986 tampering rate weighted  '
for program representation is 21%.  The 1986 weighted tampering
rate can be compared to the weighted rates from the 1985, 1984,
1983, and 1982 surveys (21%, 26%, 28% and 19%, respectively.)
Applying weighting factors to the 1981 and earlier surveys
would be difficult, since some surveys contained no I/M
areas.   The use of weighting factors here also does not account
for differences in program coverage between sites.  For the
sake of clarity, only the actual, unweighted rates found
during the surveys will be reported.

-------
                            -25-
                           TABLE 4

   Comparison of EGR System Tampering to Overall Tampering
                   in the 1982-1986 Surveys

                            Tampering (%)  by Survey Year

Tampering Category          1982  1983   1984  1985  1986

Overall Tampering            17%   25%    22%   20%   20%

Overall Tampering (excluding
  EGR System Tampering)       10*   19*    16*   17    17

EGR System Tampering         10    13     10     7     7

EGR System-only Tampering**   76      4     3     3

 * Tampering with idle stop solenoid and vacuum spark retard
   were also excluded since these components were not inspected
   in 1985 and later surveys.

** Vehicles with EGR system tampering and  no other tampering.
                           TABLE 5

   Comparison of 1986 Survey Sample to Actual Nationwide
                       Vehicle Fleet
Program Percentage within
Type Survey Sample (%)
non-I/M
I/M-only
I/M + ATP
ATP-only
28
33
19
20
Approx . Percentage of
Nationwide Fleet (%)*
59
14
21
6
   *Based on 1986 population data gathered from EPA Regional
    and State contacts.

-------
                            - ,'. O -
3.  Types of Tampering



     The tampering rates \or specific emission control



components and systems for the surveys conducted since 1982



are presented in Table 6.   The component-specific tampering



rates for the 1986 survey are presented by survey site in



Table 7.  Only those  vehicles originally equipped with a



particular component  are considered when computing the



tampering rate for that component.



     Table 6 shows that tampering with the major emission



control components has generally remained unchanged from the



1985 survey.  Air pump system tampering has been gradually



increasing since 1982,  and EGR system and catalytic converter



tampering have been decreasing since 1983.



     Table 7 shows the wide variation in tampering from site



to site for any given component.  Catalytic converter removal,



for example, ranged from 1% in Los  Angeles and Hartford to



11% in Covington and  Orlando.  This range is partly due to



the effectiveness of  I/M and antitamper ing programs (as



will be discussed later in this report), geographic location,



and socioeconomic background.






4.  Vehicle Characteristics and Tampering



     The next section of this report investigates the impact



on tampering of three vehicle characteristics: manufacturer,



vehicle type (car or  truck),  and age.

-------
                             -27-


                           TABLE 6

     Prevalence of Tampering by Component and Survey Year
  Component/System

  Catalytic Converter

  Filler Neck
  Restrictor

  Air Pump System
   Air Pump Belt
   Air Pump/Valve

  Aspirator*

  PCV System

  Evaporative
  Control System

  EGR System
   EGR Control Valve
   EGR Sensor

  Heated Air Intake

  Vacuum Spark
  Retard

  Idle Stop
  Solenoid

  Oxygen Sensor
1982
  Survey Year

1983    1984   1985
                        **
1981
4%
6
5
5
4
1
3
2
10
7
7
1
0
7%
7
7
7
3
1
5
5
13
9
12
1
1
7%
10
7
7
4
1
2
3
10
7
6
1
5
5%
7
7
4
6
2
5
4
7
6
4
1
**
5%

8
7
5
2
5
5***
7
6
5
2
**
                               **
 **
  *Vehicles with aspirated air systems are not equipped with
   other listed air-injection components,  nor do conventional
   systems include aspirators.

 **Component not checked during survey.

***Change in tampering classification system in 1986.
   Evaporative system tampering would have been 4% using the
   prior classification method.

-------
                                                       TABLE 7

                    Component-Specific Tampering Rates (Percent) by Survey Location - 1986 Survey



                                                Emission Control Component or System
Survey
Location
St. Louis, MO
East St. Louis, IL
Jacksonvi 1 le , FL
Orlando, FL
Houston, TX
Memphis, TN
Pittsburgh, PA
Richmond, VA
Hartford, CT
Camden, NJ
Covington, KY
Seattle, WA
Los Angeles, CA
Tucson, AZ
Baton Rouge, LA
Catalytic
Converter
2
6
8
11
6
8
3
2
1
4
11
3
1
3
8
Inlet
Restrictor
3
7
7
14
7
12
2
4
3
6
12
4
5
6
9
Air Pump
System
3
10
10
14
8
8
4
7
7
10
11
8
6
10
9
PCV
System
4
5
4
4
7
4
3
4
3
6
3
3
3
11
6
EGR
System
4
9
6
13
9
5
3
5
3
8
10
9
5
9
11
Evaporative
System
4
7
6
7
8
4
3
5
2
4
7
5
5
8
8
Any
Component
15
23
21
26
24
21
12
14
13
19
24
18
15
25
23
                                                                                                                  I
                                                                                                                  NJ
                                                                                                                  00
                                                                                                                  I
OVERALL
8
20

-------
                            -29-



     Manufacturer.  Figure 4 presents the 1986 tampering



rates for each major manufacturer.  Separate tampering rates



are listed for each manufacturer with more than 100 vehicles



in the survey.  The remaining foreign manufacturers have been



combined into two groups, Other European and Other Asian.



With the exception of Volkswagen, vehicle tampering was



higher among vehicles of domestic manufacture than among



those of foreign manufacture.  Overall, tampering with domes-



tically manufactured vehicles was twice that found for the



foreign manufactured vehicles (22% vs. 11%).



     A number of factors might explain the discrepancy in



tampering among manufacturers.   Differences in design may



make some vehicles more tamper-prone than others.  Changing



market share history results in different age distributions



for vehicles of different makes, and vehicle age is clearly



related to tampering prevalence.  Tampering rates probably



vary with geographic location and socioeconomic background,



so the owner demographics for different makes may affect the



likelihood of tampering.



     Vehicle Type.  The overall tampering prevalence for



light-duty trucks (LDTs) was the same as for automobiles



(LDVs), as was mentioned previously (Table 1).   While the



tampering rate for each emissions component on trucks was .



equal to or greater than on passenger cars (as in previous



surveys) the 1986 survey is the first in which overall

-------
  1
  t
                         -30-
                                    33%
  1
  1
  1
       Ford
       H Amsricnn Mntors h
       -I  Gensral Motors
                    21%
-H    Chrysler
                   20%
      Ma?da
                13%
        I  Dther Eurgpean  I
                        10%
        I	Ut.hBr Asian
   Tampering  (%)
                           26%
                                 25%
Figure  4.    Tamponing by  Manufacturer:
              1986 Survey.

-------
                            -31-





tampering with trucks and cars was the same.  Figure 5 shows



that the discrepancy between car and truck tampering has



been decreasing for the past five years.



     One factor that may be contributing to the convergence



in car and truck tampering is the increasing sales of imported



trucks.  Between 1982 and 1986 the proportion of imported



trucks within the total truck population surveyed has increased



from 10% to 15%.   Since imported vehicles are tampered with



much less frequently than domestic vehicles, the increase in



imported trucks within the truck population surveyed may be



contributing to the lower truck tampering prevalence.  Another



contributing factor may be the delayed impact of closed loop



technology on truck tampering relative to car tampering.



Closed loop technology first became widespread on trucks in



1983, while it had been widely used on cars since 1981.   Any



tampering deterrence from closed loop technology should thus



be evident on cars first, and then later on trucks.



     Vehicle Age.   Table 8 relates vehicle age and model



year with tampering prevalence for the 1978-1986 surveys.



Catalytic converter removal rates are similarly related to



vehicle age and model year in Table 9.  The results from



any given survey  are entered diagonally in each table.



     The results in Tables 8 and 9 indicate that vehicle



tampering increases directly with vehicle age.   Examining



Table 8 diagonally (by survey) shows that tampering increases

-------
                          -32-
Tampering  (%)
     35
     30
     25
     20
     15
     10
      0
          1982     1983    1984     1985    1986
                      Survey Year
                                                  LDV

                                                  LOT
Figure  5.   Comparison  of LDV and LOT  tamponing
            in  tho 1982 - 1986  surveys.

-------
                                                       TABLE 8


                Tampering Percentage (and Sample Size) by Model Year and Vehicle Age at Time of Survey
                                                 Year of Vehicle Li £e


Madel                                    .                ;             ;
Year     First   Second   Third   Fourth   Fifth    Sixth    Seventh  Eighth   Ninth    Tenth    Eleventh  Twelfth


1986     1(757)


1985     2(816)  3(1130)


1984     1(462)  2(1001)  5(1018)


1983     7(182)''* 4(471)   6(710)   7(706)                                                                         i,
                                                                                                                  u>

1982     1(250)  4(226)   7(466)   9(621)  11(574)


1981     2(57)   7(448)  13(206)  15(458)  11(607)  19(560)


1980             5(63)    9(454)  15(211)  18(516)  25(564)  25(556)


1979  '   6(371)           9(59)   18(477)  31(288)  28(503)  37(673)  36(699)


1978     7(298) 14(502)           15(79)   21(430)  39(238)  34(559)  37(562)  50(548)


1977            10(457)  15(476)           21(66)   26(316)  44(190)  41(408)  48(452)  48(465)


iy76                     18(395)  19(374)           29(52)   26(317)  40(171)  39(385)  49(369)  53(318)


1975               .               22(274)  22(271)           32(22)   37(183)  55(89) ,  46(197)  54(194)  60(198)


1974                                       33(276)  27(242)


1973                                                32(253)  36(251)

-------
                                                      TABLE 9

                                 Percentage of Catalyst Removal (and Sample Size)
                 among Catalyst-equipped Vehicles by Model Year and Vehicle Age at Time of Survey
Model
Year
1986
1985
1984 .
1983
1982
1981
1980
1979
1978
1977
1976
1975
First
0(757)*
0(808)
0(462)
1(179)
0(250)
0(57)

0(326)
0(291)



Second

1(1128)
0(978)
2(471)
1(225)
2(441)
2(61)

0(445)
1(417)


Third


1(1018)
0(686)
2(465)
5(204)
2(428)
4(55)

1(417)
2(377)

Fourth


1(706)
2(597)
6(457)
3(200)
6(429)
0(71)

2(305)
2(242)
Year of Vehicle Life
Fifth Sixth Seventh Eighth Ninth Tenth Eleventh Twelfth


i
u>
4-
1
1(574)
3(567) 5(552)
6(487) 6(522) 7(528)
12(252) 10(455) 12(572) 12(638)
4(362) 8(213) 8(486) 10(472) 10(466)
2(59) 2(271) 11(166) 14(357) 17(379) 19(409)
10(48) 6(257) 12(139) 12(314) 15(291) 20(276)
2(204) 26(19) 12(139) 23(75) 16(174) 21(1.30) 23(16 /)
*Tampering rates have been rounded to the nearest whole percent.   A zero does not necessarily indicate a total
 absence of tampering, but rather a level of tampering that rounded to zero.

-------
                             -35-





coasistently with vehicle age in each survey conducted.  In



the 1986 survey, for example/ the tampering rate increases



from 1% for first year (1986) vehicles to 60% among the 1975



model year vehicles surveyed.  Table 9 shows a similar,



though less pronounced, increase in catalyst removal.  Examin-



ing these tables in this manner has the advantage of comparing



data collected daring one survey in one set of locations, but



Ignores the possible effects of model year differences (i.e.,



technology) on tampering.



     Two additional ways of analyzing Tables 8 and 9 address



the impact of model year on tampering rates.  Analyzing the



tables horizontally (holding the model year constant) provides



a look at the tampering rates over time for the vehicles of



a particular model year.   This approach shows the same distinct



increase in tampering with vehicle age for all model years



since 1975.  (The 1974 and 1973 data sets are too small to



permit any conclusions.)  For example, the tampering incidence



for 1978 vehicles increased from 7% in their first year to



50% by the ninth year of use.  The degree of overall tampering



among very old vehicles (ninth through twelfth years of usage)



appears to remain fairly constant at approximately 50% of the



vehicles surveyed.  A similar examination of Table 9 suggests



that converter removal continues to increase among these very



old vehicles.  More data from future surveys may be necessary



to discern any trend  in tampering among these older vehicles.

-------
                             -36-
Analyzing Tables 8 and 9  horizontally combines observations
made from different survey  sites at  different  times and
should be undertaken cautiously.
     The influence of vehicle age  on tampering can be more
clearly seen when the data  in Tables 8 and 9 is presented
graphically.   Figures 6 and 7 plot overall and catalyst
tampering, respectively,  as a function of vehicle age for
the 1982-1986 surveys.  This is  equivalent to  the diagonal
method of analysis used  for Tables 8 and 9 that was outlined
previously.   Figure 6 demonstrates that the relationship
between tampering rate and  vehicle age is not  only linear,
but has remained nearly constant over the five most recent
surveys.  The strong correlation is obvious despite the
different sizes, vehicle  compositions,  and locations of'the
surveys.  In Figure 7 the catalyst tampering rate remains
negligible for the first  two to  three years of a vehicle's
life, and then increases  thereafter.  This delay in catalyst
tampering is understandable,  since the emission control
components on all new vehicles are warranted for 5 years/50,000
miles by the manufacturer,  providing an incentive to maintain
the catalysts on vehicles still  under warranty.  A similar
delay in overall tampering  would also be expected, but is
not readily apparent in  Figure 6.

-------
rin
60

50

40

30

20
10
0
9 (%): S

>- 0
o 4
..&•£•••
f O 0
1" ° A § a
-/ N, Off
a
[ -O ; • i
So
t- * n
* a °
0 °
1 ° A A
O * H u
A. 1®1 , ,- ' , , , ii • ii

urvey Year
1982
*
1983
O
1984
a
1985
A
1986
O
t
>
01 234 56 7 8 9 10 11 12 13
          Vehicle  Age (years)

Figure 6.   Cumulative tampering  prevalence as a

           function  of vehicle age for the

           1982 - 1986 surveys.
                                                                     i
                                                                     U)
                                                                     -J
                                                                     I

-------
Catalyst Tampering (%)
         60 n	-^	^—
        50
         40
        30
        20
         10
         :0

                               b
                               A
                               
-------
                            -39-



     Tables 8 and 9 can also be analyzed vertically (holding



vehicle age constant), which provides a look at the tampering



rates £or different model year vehicles of the same age.



This approach suggests that improvements in automotive



technology, such as closed loop emission control systems,



may affect overall tampering rates.  For example, vehicle



tampering among 1977 model year vehicles surveyed in



their third year of usage was at 18%.  By contrast/ only 5%



of the 1984 model year vehicles in their third year of



usage were tampered.  A similar vertical analysis of Table



8, however, fails to show a clear pattern or trend in



age-specific catalyst tampering.  Vertical analysis of



Tables 8 and 9 introduces the same variability as the



horizontal analysis.





5.  Impact of I/M and Antitamperinq Programs



     Inspection and maintenance (I/M) programs require vehicles



to meet specific idle emission standards.  Vehicles registered



in areas with these programs are required to be periodically



tested to assure that they comply with the specific idle



emission cutpoints established by these jurisdictions.   In



addition to reducing emission levels by stimulating better



owner maintenance, I/M programs may deter some tampering with



emission control components.  Data from previous surveys has



tended to support this proposition, since tampering in I/M



areas has historically been lower than in non-I/M areas.

-------
                             -40-



     Some I/M areas have also instituted antitampering



programs (ATPs),  which involve  periodic  vehicle inspections



to check the integrity of specific emission control components.



Antitampering programs vary  greatly in  the  components inspected



and the vehicle model years  covered,  so that a vehicle or



component which would be inspected in one program area might



not be inspected in a different program area.   Successful



antitampering programs should reduce  existing  tampering and



deter future tampering with  the components  and model years



covered by the program.



     The sites surveyed in 1986 can be  classified very



generally as four non-I/M areas, five I/M-only areas, three



I/M + ATP areas,  and three ATP-only areas.   Such classification



is based solely on the presence or absence  of  a control



program at the time the area was surveyed,  and does not take



into consideration variations in program coverage or



effectiveness.   Any comparisons between  program types (i.e.,



I/M-only vs. non-I/M) should thus be made carefully.





6.  Tampering Trends for Selected  Sites



     The impact of I/M and antitampering programs in specific



locations can be examined by comparing  the  1986 survey data



with that from earlier surveys.  Comparisons made between



surveys widely spaced in time,  however,  must take into con-



sideration the differences in average vehicle  age in each

-------
                             -41-
survey.  The average miles traveled per vehicle surveyed in
1986, for example, is one third greater than it was in
1983.  Since vehicle age is directly related to tampering
prevalence, a significant increase in tampering might be
expected to have occurred between 1983 and 1986, if all
other factors remained constant (car/truck distribution,
owner demographics, etc.).  Inferences regarding program
effects should thus be made with this in mind.
     Table 10 presents tampering data for three sites -
Camden, Houston, and Baton Rouge.  The comparisons made in
this table have been limited to the specific components and
vehicle model years covered by each antitampering program as
of the 1986 survey.  The tampering data listed in Table 10
were compiled only for surveyed vehicles included within the
local program jurisdiction.  The Houston tampering data,
for example, are for Harris County vehicles only.  Any non-
Harris County vehicles surveyed were excluded from this
analysis.
     It is difficult to determine from Table 10 whether or
not New Jersey's recently implemented antitampering program
has had any impact on converter and inlet restrictor tampering
found on 1982 and newer vehicles, since the incidence of
tampering on these vehicles was already negligible.  As of
May 1, 1987, New Jersey's antitampering program expanded to
1975 and newer vehicles, and future surveys will examine the
program's effectiveness against older vehicles having a higher
tampering prevalence.

-------
                                    -42-

                                  TABLE 10

         Tampering Prevalence among Vehicles and Components Covered
              by Three Antitampering Programs for  the 1983-1986
                             Tampering Surveys


                                                Tampering Prevalence (%)
                        Component and                by Survey Year
Survey Location      Model Years Covered       1983     1984    1985    1986

Camden, NJ         Catalytic Converter 82+      -        1%      -       0%*
                   Inlet Restrictor,    82+      -        1       -       0*

Houston, TX        Catalytic Converter 80+      6        -       1*      3*
                   Inlet Restrictor    80+      1        -       0*      2*
                   Positive Plumbtesmo 80+      7        -       2*      2*
                   PCV System          75+      9        -       4*      7*
                   Evaporative System  75+**    8        -       4*      7*
                   Air Pump System     75+      9        -       6*      8*

Baton Rouge, LA    Catalytic Converter 80+      -        -       4       3*
                   Inlet Restrictor    80+      -        -       31*
                   PCV System          80+                      2       3*
                   Evaporative System  80+**                    3       3*
                   EGR System          80+      -        -       4       4*
                   Air Pump System     80+              -       6       4*

* survey was conducted after ATP had been implemented.

^classification of evaporative system tampering changed in 1986 survey.
  Evaporative system tampering in Houston and Baton Rouge would have been
  5% and 2%, respectively, using the prior coding  method.
                                  TABLE 11

               Comparison of Tampering among Missouri Vehicles
            (I/M + ATP)  and Illinois Vehicles (non-I/M)  Surveyed
              in St.  Louis, MO and East St.  Louis,  IL in 1986

                                         Tampering  (%) by State of
                                            Vehicle Registration
                  Component and
                Model Years Covered       Missouri     Illinois
             Catalytic Converter  81+         0%           2%

             Air Pump System      75+         4            10

             EGR System           75+         4             9

             PCV System           75+         4             6

-------
                             -43-



     The tampering data for vehicles covered by Houston's



ATP-only suggest that this program was less effective in



its second year of operation than in its first.  Catalyst



and fuel-related tampering decreased sharply in 1985, after



one year of program operation, and underhood components



covered by the program had moderately reduced rates.  Tampering



seemed to have rebounded in 1986, however, particularly for



the underhood components.   Baton Rouge's ATP-only has been



partially effective in its first year of operation, since



tampering with 3 of the 6  components covered showed weak



declines between the 1985 survey (before program implemen-



tation) and the 1986 survey (one year after program imple-



mentation).  The other three components either did not



change or actually showed  higher tampering.



     Table 11 examines the difference in tampering found in



St. Louis, MO and East St.  Louis, IL.  In Table 11 the



vehicles surveyed at these two sites have been classified by



state of registration rather than location surveyed, since a



number of Missouri vehicles were surveyed in Illinois and



vice versa.  Also the tampering rates were determined for



the model year and components covered by Missouri's I/M + ATP



to examine the Missouri program's effectiveness.   Table 11



shows a dramatic difference in tampering among vehicles in



close geographic proximity but under different control programs.



Part of this difference is probably due to the different

-------
                             -44-
socioeconomic makeup of  the two cities  surveyed,  but the
presence of an I/M  + ATP  in Missouri  is  no  doubt  a contributing
factor to the lower tampering rates.

7.   Correlation between Tampering  and Idle  Emissions
     As was mentioned previously,  vehicles  which  are subject
to an I/M program must meet specific  idle emissions cutpoints.
To assess the relationship between tampering and  fuel switch-
ing and idle failure rates, the idle  emissions from vehicles
have been tested against  the cutpoints  established by the
I/M program where they were sampled.  Vehicles in non-I/M
areas were tested against the cutpoints specified by the tfew
Jersey I/M program.   The  cutpoints for  each I/M area are
listed in Appendix  C.
     The results of the idle tests are  presented  in Figure 8
cor vehicles in the various tampering and  fuel switching
categories.  Only 17% of  the surveyed vehicles that were free
of tampering and fuel switching failed  an  idle test, while
62% of the tampered and fuel switched vehicles failed that
test.  These results indicate that a  substantially larger
proportion of tampered and fuel switched vehicles than of
okay vehicles fail  an idle test at typical  I/M cutpoints.
This is partly due  to the tendency for  tampered vehicles to
have misadjusted carburetors, since 77% of  the tampered
vehicles with conventional carburetors  also had missing

-------
                                Figure  8
        Distribution of  Survey  Sample Among  Tampering*,
            FUQ! Switching,  and Idle  Test  Categories
                              EntirQ survoy
                                  sample
                                   100%
            Okay
             54%
                      Arguably
                       tamponed
                         25%
      Not fuel
      switched
        99%
       Fuel
     switched
       1%
      Pass
      83%
Fail
17%
                                          Tamponed
                                            20%
                                                                          Ul
                                                                          I
               Not fuel
               switched
                 98%
Pass
73%
Fail
27%
                    Fuel
                   switched
                   	2%
Pass
59%
Fail
41%
Pass
38%
Fail
62%
*excludes malfunctioning vehicles (1% of total)

-------
                            -46-






sealed plugs or limiter caps.   It should be noted drovr- Figure




9, however,  that 38% of the  tampered and fuel  switciUid vehicles




were still able to pass the  idle test.




     Table 12 shows the percentage of vehicles that failed




the idle emissions test for  each vehicle condition.  The




failure rates are listed for the entire  survey,  as well as




in two model year groupings  representing "old" technology




(1975-1980)  and "new" technology (1981+) vehicles.  "New"




technology signifies closed  loop emissions control, which




came into widespread usage in 1981 model year  vehicles.




     The overall percentage  of tampered  vehicles exceeding I/M




cutpoints for HC emissions was nearly three times greater




than for okay vehicles (41%  vs 14%). Over five times as




many tampered vehicles exceeded CO cutpoints as did okay




vehicles (44% vs 9%).  The majority (60%) of the vehicles




that either  had been fuel switched or had their catalysts




removed also exceeded HC or  CO limits.   Conversely, 40% of




the vehicles with missing catalysts or classified as fuel




switched were still able to  pass an idle emissions test.  As




in previous  surveys, a significant number of arguably tampered




vehicles also produced excess idle emissions.   Since the




majority of  arguable tampering involves  idle speed limiter




caps and sealed plugs, the high failure  rate demonstrates




the adverse  idle emissions impact of improperly adjusted




carburetors.

-------
                             -47-
                           TABLE 12

        Idle Test Failure Rates (Percent) by Pollutant
                    and Vehicle Condition
                   Failure Rate (%) by Pollutant
                      for Model Years listed
Vehicle
Condition
Okay
Arguably
Tampered
Tampered
1975-80
HC CO
22
34
44
14
37
49
1981+
HC CO
13
20
29
8
21
27
HC
14
29
41
Overall
CO HC or CO
9
31
44
17
42
57
Cat. Removed
or Misfueled      44   48     38   40     43   47      60
                           TABLE 13

           Mean Idle Emissions by Vehicle Condition
Prgram
Type
non-I/M
I/M*
ATP-only
HC emi ssions(ppm)
Tampered Okay
402.6 51.4
280.2
328.9
51.5
45.2
CO emissions(%)
Tampered Okay
3.5 0.4
2.4
2.8
0.3
0.4
    OVERALL           346.1      50.6       2.9      0.3

    *  category includes any program where idle emissions are
       checked, including I/M + ATP areas.

-------
                              -48-



     The effectiveness of idle emissions testing on "new"



technology vehicles can also be seen in Table 12.   The data in



Table 12 actually minimizes  the impact of "new"  technology



because "old" technology trucks manufactured after 1980 have



been included in the "new"  technology category due to the



model year split.  As was found in  the 1985  survey, idle emissions



testing is more effective in identifying tampering on 1980



and older vehicles than on  1981  and newer vehicles.  For example,



49% of the tampered "old" technology vehicles exceeded CO



cutpoints compared to 27% of the tampered "new"  technology



vehicles.  This suggests that idle  emissions testing may not



be an effective strategy for identifying tampering and fuel



switching among "new" technology vehicles,  since many vehicles



with closed loop systems are able to produce low idle emissions



even with tampered emission  control devices.



     The mean idle emissions for tampered and okay vehicles are



presented in Table 13 by program type.  Vehicles from Baton



Rouge are considered to be ATP-only for model years 1980 and



newer, while vehicles from model years 1975-1979 are classified



as non-l/M (following the program coverage in the area).  The



vehicles surveyed in Memphis are classified  as I/M for CO



emissions but as non-I/M for HC emissions because the I/M



program effectively has no  cutpoints for HC  (see Appendix C).



Also areas with I/M or I/M + ATP have been combined in Table 13.

-------
                             -49-






     The mean  idle emissions from tampered vehicles were



considerably greater than from properly maintained vehicles



(Table 13).  Overall, HC emissions from tampered vehicles were



nearly seven times greater on average than from okay vehicles,



while CO emissions were nearly 10 times greater.  Tampered



vehicles from  areas with I/M programs had the lowest average



HC and CO emissions, while tampered vehicles from areas with



ATP-only had slightly higher average emissions.  The slightly



higher idle emissions from vehicles in ATP-only areas is not



surprising, since these vehicles have not been tuned to pass



I/M cutpoints.






B. FUEL SWITCHING



1.  Fuel Switching Indicators and Overlap






     Fuel switching is more easily defined than measured,



since no single indicator can accurately determine its preva-



lence.  Since  1981 the surveys have used a combination of



three indicators to measure fuel switching more accurately:



a tampered fuel filler inlet restrictor, a positive Plumbtesmo



test for lead  deposits in the tailpipe, and a gasoline lead



concentration  of more than 0.05 grain per gallon (gpg) •  Of



these three indicators,  only a tampered inlet restrictor is



also considered tampering, and as such is used to calculate



both tampering and fuel  switching rates.  Since false positive



indications should be extremely rare for these measures, the



percentage of  vehicles with at least one positive indicator



is a reasonable minimum estimate of fuel switching.

-------
                             -50-






     The presence of any of these  three indicators suggests



that a given vehicle has been misfueled;  their  absence,  how-



ever, does not rule it out.  For example,  fuel  samples could



only be obtained from 81% of the .unleaded  vehicles surveyed,



limiting the scope of this variable.   A vehicle misfueled  .



repeatedly with leaded gasoline  may also have little detect-



able lead in its fuel tank due to  subsequent proper fueling.



Similarly, a vehicle with an untampered fuel filler inlet



restrictor may have been fueled  at a  leaded pump equipped



with a smaller nozzle, or by using a  funnel or  similar device,



The tailpipe lead test, due to the difficulties of field



administration,  may also fail to identify  misfueling,  and



older vehicles may have had their  tailpipes replaced since



last operated on leaded fuel. As  the lead phasedown program



is lowering lead levels in leaded  gasoline, the incidence of



false negative Plumbtesmo results  may be increasing.  The



uncertainty in these measures,  then,  is always  toward under-



estimating the number of vehicles  misfueled.   .-   .,



     The limitations of the fuel switching indicators can be



seen in their incomplete overlap.  The results  from these



indicators would be expected to  overlap significantly, since



they are three indicators of the same phenomenon.   This has



not held true, however, in the 1986 survey or in previous



surveys.  The Venn diagram (Figure 9)  illustrates  the degree



of overlap in the misfueling indicators for all unleaded

-------
                                      .-51-
      Positiva Pluvfatoano
         (278 Total)
      Landed Fual  in Tank
         (255 Total)
                                                         Tanperad Inlat
                                                           Rastrlctnr
                                                           (441 Total)
               Tampered Inlat Only,
                   (37X)
           PlumbtosBO » Gas
                <3X)
              Plunfatacnio » Inlat
                  (HZ)
                         Cos » Inlat
                           (2X)
Loaded COB Only
    (11X)
                                                         PluntatacBO Only
                                                            (6X)
Thraa Indicatare
   (30X)
Figure  9.    Overlap  of fuel  switching  indicators  among
                unleaded vehicles  -  1986  survey.

-------
                             -52-






vehicles surveyed in 1986 in which data  for  all three indicators




were recorded.   For example,  only  72%  of  the vehicles having




leaded fuel in their tank also registered a  positive Plumbtesmo




test.  Additionally, only 41% of the vehicles with tampered




inlet restrictors actually had leaded  gasoline in their




tanks at the time of the survey.   The  incomplete overlap




reflects the limitations of each  indicator as well as the




different aspects of fuel switching each  indicator identifies.




     Figure 9 also shows that 80%  of the  fuel switched vehicles




had a tampered inlet restrictor, making  it the most frequently




observed indicator of fuel switching.  A positive Plumbtesmo




result was observed on 50% of the  fuel switched vehicles,




while leaded fuel was found in the tanks  of  46% of the fuel




switched vehicles sampled.   An antitampering program consisting




of an inlet restrictor inspection  and  a  Plumbtesmo test




would have detected fuel switching in  89% of the fuel switched




vehicles surveyed in 1986.






2.  Fuel Switching Trends






     Of the vehicles requiring unleaded  fuel, 9% were




identified as misfueled by at least one  of the indicators




discussed above.  The fuel switching  incidence by survey site




is listed in Table 14.  Table 15  compares the prevalence of




each fuel switching indicator in the 1986 survey with previous




surveys.  The data in Table 15 suggest a general pattern of

-------
Survey
Locati?'
East St. Louis, 1L

Jacksonville, FL

Orlando, FL

Covington, KY



Memphis, TN

Pittsburgh, PA

Hartford, CT

Seattle, WA

Tucson. AZ



St. Louis, MO

Camden, NJ

Los Angeles, CA



Houston, TX

Richmond, VA

Baton Rouge, LA

-53-
TABLE 14


Switching Rates Among Unleaded Vehicles By
Site and Indicator - 1986 Survey
Leaded
Fuel in
Tank (%)
5
5
8
9
7
3
3
2 " .
3
2
2
1
6
2
6
Tampered
Inlet
Restrictor (%)
Non-I/M Areas
7
7
14
12
I /M- only Areas
12
2
4
4
6
I/M + ATP Areas
3
6
5
ATP-Only Areas
7
4
9
Positive
Plumb tesmo
(%)
4
5
8
10
7
2
1
2
6
1
2
1
5
3
7
Overall Fuel
Switching (%)
8
9
15
15
14
4
5
4
10
4
6
6
9
5
10
AIL SITES

-------
                                -54-
                           TABLE  15

         Fuel Switching >Rates  Among  Unleaded Vehicles
                 by Indicator  and Survey  Year

Survey  Leaded Fuel  Tampered  Inlet   Positive       Overall Fuel
Year	  in Tank(%)    Restrictor(%)    Plumbtesmo(%)   Switching (%)

                                                          4

                                                         10

                                                         16

                                                         11

                                                         14

                                                         14

                                                          9

                                                          9

*?lumbtesmo test not used.
1978
1979
1931
1982
1983
1984
1985
1986
4
10
7
6
7
8
5
5
3
4
6
6
7
10
7
7
*
*
8
7
10
9
5
4

-------
                             -55-



decline in fuel switching.  Since such a pattern could result



from the selection of sites surveyed this year, strong con-



clusions must await the data from subsequent surveys.



     Table 16 presents the combined tampering and fuel switching



rates for the 1986 survey.  The percentage of unleaded vehicles



that were tampered or fuel switched was 20%, and the percentage



of unleaded vehicles with missing or damaged converters was 10%.



Table 16 thus suggests that half of all tampering and fuel



switching is composed of vehicles in the catalyst removed or



fuel switched category.  Since these conditions have the



largest emissions impact, this indicates the very serious



nature of most tampering.






3.  Fuel Switching by Vehicle Type






     The prevalence of each fuel switching indicator by



vehicle type is presented in Table 17.  Overall fuel switching



among t-rucks was higher than for passenger cars (11% vs.  8%)



and the prevalence of each indicator was also greater among



trucks.






4.  Fuel Switching and Catalyst Tampering






     Consumers and mechanics remove catalytic converters for



a number of reasons, but much of their motivation is related



to fuel switching.  The vehicle owner may remove the catalytic



converter either prior to misfueling,  or after some misfueling

-------
                                    -56-




                                  TABLE 16




            Combined Tampering and Fuel Switching - 1986 Survey
                       Catalyst-equipped vehicles
                           Unleaded Vehicles
Survey
Location
East St. Louis, IL
Jacksonville, FL
Orlando, FL
Covington, KY
with catalysts removed or
that were fuel switched (%)
Non-I/M Areas
10
12
19
18
either tampered o
fuel switched (%)
23
22
27
25
Memphis, TN



Pittsburgh, PA



Hartford, CT



Seattle, WA



Tucson, AZ










St. Louis, MO



Camdem, NJ



Los Angeles, CA







Houston, TX



Richmond, VA



Baton Rouge, LA
                                      I/M-only Areas
16



 6



 6



 6



11
         I/M + ATP Areas
 5



 9



 7








11



 6



13
ATP-only Areas
                       22



                       13



                       14



                       16



                       26
16



19



16








25



15



25
TOTAL
10%
                        21%

-------
                                     -57-

                                   Table 17

          Prevalence of Fuel Switching Indicators by Vehicle Type
   Fuel Switching Indicator
   Tampered Inlet Restrictor
   Positive Plumbtesmo
   Leaded Fuel  in Tank
   Overall Fuel Switching
Percent  Fuel Switching by Vehicle Type
     LDV                 LOT
      7

      4

      4

      8
 8

 8

 7

11
Catalyst Tampering
    (336 Total)
                      Fu«l Switching
                        (543 Total)
Figure  10.   Overlap of  catalyst tampering and fuel switching
              among catalyst-equipped vehicles  - 1986 survey.

-------
                             -58-




if the vehicle's driveability has been adversely affected by a




catalyst damaged from the  repeated misfueling.   The data from




this survey cannot be used to distinguish between these two




situations, but can be used to examine the extent to which




these types of abuse occur in conjunction.




     Figure 10 depicts the degree of  overlap between catalyst




removal and fuel switching.  Vehicles with catalyst tampering




exclusive of fuel switching were  relatively uncommon — only




38% of the catalyst tampered vehicles were not  fuel switched.




Fuel switching, however,  is not always accompanied by catalyst




removal, since 62% of the  fuel switched vehicles still had




their catalysts.




     Figure 11 examines the relationship between converter




tampering and two of the three misfueling indicators (positive




Plumbtesuio and tampered inlet restrictor) .   Only vehicles in




which all three of these parameters were inspected are included




in Figure 11.   These three criteria have been incorporated




into a number of antitampering programs,  such as in Houston




and Baton Rouge, to determine if  a converter is  missing or




damaged.  A vehicle failing the Plumbtesmo test  or inlet




restrictor inspection in these programs would have to have




its converter replaced.

-------
                                         -59-
      Poeitive Pluwbtaemo
         (303 total)
         Missing Catalytic
            Cnnvartar
            (367 Total)
                                                          Tampered Inlat
                                                           Restrictor
                                                           (471 total)
             Tampered Inlat Only
                  (262)
            Plumfataona * Cat.
                (22)

                  Cat. » Inlat
                    (90
                                                 Converter Only
                                                    (202)
                                                          lunfatocae Only
                                                             (72)
                                                     All
Three Indicators
  (242)
                      Inlat » Pluafatacmo
                           (122)

Figure  11.    Overlap of  indicators  used  by ATPs to  detect
                  missing/damaged catalysts -  1986  survey.

-------
                             -60-




     Figure 11 shows the value of these  programmatic criteria




in detecting missing or damaged converters.   A simple inspection




of the converter for example,  would only catch 55% of the




vehicles with missing or damaged converters.   Inspecting




both the converter and inlet restrictor,  however,  would




detect 93% of these vehicles.   The usefulness of Plumbtesmo




as an indicator may be declining with the advent of lead




phasedown, since only 7% of  the vehicles  in  Figure 11 failed




for Plumbtesmo only.  In 1984, prior to  lead phasedown, 17%




of the vehicles failing one  of these programmatic criteria




failed for Plumbtesmo only.






5.   Gasoline Lead Concentrations






     Of the vehicles identified as misfueled by any of the




three misfueling indicators,  52% had only trace amounts of




lead (less than 0.05 gpg) in their gasoline  when inspected.




These vehicles, then, were identified as  fuel switched by a




tampered filler restrictor and/or a positive Plumbtesmo




test.  Figure 12 presents the  distribution of lead concen-




trations of 0.05 gpg or more in misfueled vehicles.  The




impact of lead phasedown can be dramatically seen when




Figure 12 is compared to similar data from the 1984 and 1985




surveys.  In the 1984 survey 39% of the  misfueled vehicles




had a gasoline lead concentration in excess  of 1.0 gpg/




compared to 1% in 1985 and 1986.   The distribution of lead




concentrations in 1986 is centered on the 0.2-0.4 gpg range,




compared to 0.4-0.6 gpg in 1985 and 1.0+  gpg in 1984.

-------
                          -61-
Percentage of Mlcfueiad Vahlclas
       15
       10
                   10Z   10Z
           92
                             7X
VTA VTA
                                                       JZ
                                                      Y7A
                  Gasoline Lead Concentration (grams/gallon)
   Figure 12.   Lead concentrations in  leaded fuel
                 sampled  from  misfueled  vehicles.

-------
                             -62-


                          APP6NDIX 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 compliance 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
     •~N

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.

-------
                             -63-



                          APPENDIX B





             SURVEY AND DATA RECORDING PROCEDURES



1.  Explanation of Survey Forms



     The forms on the following pages were used for recording



the survey data in the field.  The forms were forced choice to



ensure coding consistency, and were designed to facilitate



direct data entry.  The following codes were used to record



data for the major system components on the data sheets:



 0 - Not originally equipped      8 - Misadjusted item



 1 - Functioning properly         9 - Malfunctioning



 2 - Electrical disconnect        A - Stock equipment



 3 - Vacuum disconnect            B - Non-stock



 4 - Mechanical disconnect        D - Add on equipment



 5 - Incorrectly routed hose      Y - Yes



 6 - Disconnect/Modification      Z - No



 7 - Missing item





     Additional codes were used for those components which



could not be classified into the above categories.  If a



determination could not be made about a given component's



condition, the variable was left blank.  A brief description



of each data entry follows.

-------
1986  TAMPERING  SURVEY  -  PART  A  (UNDERHOOD)
                                                 30
    13


N 0










4
Y R


(

*
i
12
MOI
                           10 NUMBER
                           I/M  3TICKER(datas
                               of  last Inspection)

                           DISPLACEMENT (cubic
                                 Inches or  liters)

                                                  40
HEATED AIR INTAKE   43

      ft- Mot orig. equipped

      1- Funct. properly

      3- Vacuum disconnect

      IT* Mech. disconnect

      7- Missing  item
         (stovepipe hose)
      9- Kalfunct. item
         (vac. override)
      B* Hon-stock(custom  A A
         air cleaner)
PCV SYSTEM
      ]_-Funct. properly
ASPIRATED  AIR
INJECTION  SYSTEM
       ft- Mot orlg.  equipped
          (If conventional
          system or none)
       1- Funct. properly

       l\- M«ch. disconnect

       7- Missing Item

       9- Malfunctioning


AIR PUMP  BELT
          (if Aspir., code  "0")

       ft- Mot orlg. equip.
                                                                                                                  48  CARBURATOR TYPE
                                                                                                                              $- Sealed

                                                                                                                              F- Fuel Injection

                                                                                                                              A- Stock

                                                                                                                                - Mon-stock
                                                                 D
                                                                                                                    49
       **NOTE:  If engine fan. Is missing
        or Illegible,  copy sll but the
        last 6 digits  of the VIM.  DO
        NOT COPY SERIAL NUMBER PORTION
        Of VIH.

 15   ENGINE FAMILY
                                                  41
26   VIN
                (If engine family not  available)
                                             36

 37  ORIGINALLY  CATALYST EQUIPPED?
             FROM STICKER UNDER HOOD OR
             DRIVER'S  DOOR POST                    42

             Y-Tes

             2- No

             X- Can't  tell (no sticker,
                not readable, or not mentioned)

  38   AIR  CLEANER

             A- Stock

             B- Non-Stock

             7- Missing Item
                                                            3-Vacuum disconnect

                                                            {{-Mech. disconnect
                                                              (fresh air hose)
                                                            /-Missing Item

                                                            9-Malfunct. Item
                                                              (collapsed hose)
                                                            g-Non-stock (Inc. fuel
                                                              economy devices)
TURBOCHARGER
      0- Mot orlg. equipped

      A- Stock

      B- Non-stock

      D- Add-on
                                                                                                                    50
                                     1- Funct.  properly

                                     7- Missing Item

                                     &- Mlsadjustcd Item
                                        (loose)

                           45  AIR PUMP  SYSTEM (Incl. valve)

                                     0- Mot orlg. equipped (If
                                        aspirated or none)
                                     1- Funct.  properly
                                                                                                                     51
                                                      EVAP.  CONTROL
                                                      SYSTEM
                                                            1-Funct. properly
                                                                                48
D
                                                            5-Vacuum discon.
                                                              (carb. line)       • ^f
                                                            /{-Mech.  discon.
                                                              (tank  line)
                                                            5-Incorr. routed hose

                                                            5-Dlsconnect/Modiflcatlon
                                                              (air cleaner unsealed)
                                                            7-Mlssing Item

                                                            9-Malfunct. Item
                                                              (or cannlster cracked)
      4- Mech. disc, (other
         than belt  removal)
      7- Missing Item

      9- Malfunctioning
         (frozen)

EXHAUST  MANIFOLD
      A- Stock

      B- Mon-stock
OXYGEN SENSOR

       DO- Not orlg. equipped      52

       1- Functioning properly

       2- Electrical disconnect

       1|- Mech. disc, (unscrewed)

       7- Missing  itea


         00 DOT MM WI1MOUT M»»lttlO» 0' *
                                   LIMITER CAPS
                                    ~~"~1   0- Mot orlg. equipped
                                             (fuel  injection)
                                    	   ].- Funct. properly

                                          t|- Mech.  disconnect
                                             (tabs  broken or bent)
                                          7- Missing  item

                                          8- Misadjusted (sealed
                                             plugs  removed)
                                    EGR CONTROL VALVE

                                          Q-Not orlg. equipped

                                          1-Funct.  properly

                                          3-Vacuun disconnect

                                          l|-Mech. disconnect

                                          /-Missing  Item

                                          9-Malfunct. Item(explain)
                                                                   D
                                                                    EGR  SENSOR
                                                                           (coolant, back-pressure, etc.)

                                                                           ft- Not orlg. equipped

                                                                           1- Funct. properly

                                                                           3~ Vacuum disconnect

                                                                           £. Xncorr.  routed hose

                                                                           7- Missing  itea


                                                                    COMPUTER  SYSTEM
                                                                    A RELATED  SENSORS


                                                                           ft- Hot orig.  equipped

                                                                           1- Funct. properly

                                                                           5- OUconnecJ/Modllloallos
                                                                                                                             «' •«"*""•
                                                                                    (explain)

                                                                                       r •

-------
      1986 TAMPERING  SURVEY  -  PART  B (REAR)




               J  ID  NUMBER
MAKE
(write out)

MODEL
(write out)
              12
13  VEHICLE TYPE

         C- Car

         J- Truck (includes vans)
14
            LICENSE PLATE
            (Scace)
            25
                               26  DASH  LABEL

                                    0- Not orig. equipped
                                    1- Funct. properly
                                      (present)
                                    7- Missing item
                                          31 TANK LABEL

                                                0- Mot orig. equipped
                                                                 1- Funcc. properly
                                                                    (present)
                                                                 7- Missing Item
CATALYTIC CONVERTER

 0- Not orig. equipped

 3.- Funct. properly
   (present)
 7- Missing item
             28  EXHAUST SYSTEM

                  /\- Stock

                  U- Non-Stock
16
20
23





i
i
22




19
IDLE HC
(PPM)
IDLE CO
tt)

ODOMETER
(Thou.)
dv

30

                               29   EXHAUST SYSTEM
                                    INTEGRITY
                                    1- Funct. properly
                                      (no obvious leaks)
                                    9- Malfunctioning
                                      (leaks evident)

                               30   TANK CAP
                                    1- Funct. properly

                                    7- Missing item

                                    9- Malfunctioning
                                       (loose,or unsealed)
    FILLER NECK
32  RESTRICTOR
      0- Not orig. equipped

      1- Funct. properly

      l\- Mech. disc, (widened)

      7- Missing Item

33   PLUMBTESMO

      P- Positive

      H- Negative

34   FUEL SAMPLE

      Y- Yes

      Z- No

        leave blank
                                           35
                                                                                              i
                                                                                              CTi
                                                                                              Ul
                                                                                              I
                                                                                FUEL DATA
                                                                             38
                                                  DO NOT U>« WITHOUT PlftUUIION Of THI OtHCl Of HflltMCM. 0«VIIOMUJNT i THAUHDO

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                             -66-




Fbrro A -. Underhood






  1-4  ID Number - Vehicles  are numbered sequentially as



       they are inspected.   This number is preceded by a



       site identifying letter.






  5-8  Month and year of last I/M inspection (left blank



       if vehicle is licensed in non-I/M area).






 9-12  Displacement - as recorded on the underhood emission



       label.






13r-l4  Vehicle Model year






15^-25  Engine  Family - as recorded on the underhood emission



       label.






26-36  Non-serial number portion of VIN - as recorded on the



       driver's side of the  dash under the windshield or the



       driver's door post.   The VIN is recorded  only if the



       engine  family can not be determined.






   37  Originally Catalyst Equipped - as recorded on the



       underhood emission label or the driver's  door post.






   38  Air Cleaner - is coded 'A',  'B1,  or '7'.

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                          -67-



39  Heated Air Intake - provides warm air to the carburetor



    during cold engine operation.  The heated air intake



    is coded  '0',  '!', '3',  '4', '7' (stovepipe hose),



    '9' (vacuum override), or 'B1 (custom air cleaner).
40  Positive Crankcase Ventilation (PCV) system - prevents



    crankcase emissions by purging the crarikcase of blow-



    by gases which leak between the piston rings and the



    cylinder wall in the combustion chamber under high



    pressures.  The PCV system is coded  '!',  '3', '4'



    (fresh air hose),  '7',  '9', or 'B1 (includes fuel



    economy devices).






41  Turbocharger - coded 'O1, 'A', 'B1, or 'D'.






42  Evaporative Control System (ECS)  - controls vapors



    from the fuel tank and  carburetor.  Some systems have



    two lines: from the fuel tank to the canister, and



    from the canister  to the carburetor or air cleaner



    (for purging the canister).  Other systems have a



    third line connected to the carburetor.  The ECS is



    coded '!', '3' (carburetor line),  '4'  (tank line),



    '5', '6' (air cleaner unsealed),  '7', or '9' (cracked



    hose or canister).






    Air Injection System -  extends the combustion process



    into the engine's  exhaust system by injecting fresh



    air into the exhaust ports, lowering exhaust emissions



    while still maintaining proper vehicle performance.

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                          -68-






    Two types of air injection  systems are currently used.




    One type uses a belt-driven air pump to direct air




    through a control valve and into the exhaust manifold.




    The other type is a Pulse Air Injection Reaction




    (PAIR) system, which uses an aspirator commonly




    located in the air cleaner  to supply air to the exhaust




    manifold.






43  PAIR - coded '0' (if air pump system or none), '!',




    '4' ,   '7', or '9' .






44  Air Pump Belt - is coded '0' (if PAIR or none), '!',




    '7',  or '8' (loose belt).






45  Air Pump System - for the purposes of this variable,




    consists of the air pump and control valve and is




    coded '0' (if a PAIR or none),  '!',  '4' (other than




    belt removal),  '7', or '9'(frozen pump).






46  Exhaust Manifold - coded 'A' or 'B1.






47  Oxygen Sensor - Controls the air-fuel mixture going



    into the engine of vehicles equipped with three-way




    catalytic converters.  The  sensor is coded '0', 'I1,




    '2',  '4' (unscrewed), or '7'.

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                          -69-




48  Carburetor Type - is coded 'S' (sealed plugs covering




    mixture adjustment), 'F1  (fuel injection).  'A',




    or '8'.






49  Limiter Caps - plastic caps on the idle mixture screws




    to limit carburetor adjustments.  The limiter caps




    are coded '0', '!',  '4'  (tabs broken or bent),  '7',




    or '8' (sealed plugs removed).






    Exhaust Gas Recirculation (EGR)  System - directs a




    portion of the exhaust gases back into the cylinders




    to reduce NOX emissions  in the exhaust gas.   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.






50  EGR Control Valve -  coded '0', 'I1,  '3', '4', '?',




    or '9' .






51  EGR Sensor - coded '0',  'I1,  '3',  '5', ' 7 ' .






52  Computer Systems and Related Sensors - computerized



    engine and emissions control system which receives




    input from various sensors for engine condition




    information, and constantly adjusts the air/fuel




    ratio, distributor,  and  emissions devices for optimum




    economy,  driveability, and emissions.   The  system

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                             -70-





       is coded '0',  '!',  or  '61.   This  variable  includes the



       entire computer system except for the oxygen sensor,



       which is coded separately  (see  variable  #47, Form A).





Form B - Rear





  1-4  ID Number - Same as on Form A.





  5-8  Make





 9-12  Model





   13  Vehicle Type - coded as follows:  C =  car,  T = truck





14-15  License Plate - State  abbreviation





16-19  Exhaust gas HC concentration (in  ppm)  at curb idle.





20-22  Exhaust gas CO concentration (in  percent)  at curb idle,





23-25  Odometer - mileage  in  thousands





   26  Dash Label - displays  the  fuel  required and is coded



       '0'{for leaded vehicles),  'I1,  or '7'.





   27  Catalytic Converter -  oxidizes  the HC and CO to water



       and C02 in the exhaust gas.   Later model catalysts



       also reduce oxides  of  nitrogen.   The  converter is



       coded '0', 'I1, or  '71 (entire  catalyst canister



       removed).

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                          -71-






28  Exhaust System - if as originally equipped an 'A1  is coded




    If non-stock a "B1  is coded.






29  Exhaust System Integrity - the condition of the exhaust




    system is coded 'I1 (no obvious leaks) or  '9' (leaks




    evident).






30  Tank Cap - seals the fuel tank during normal operating




    conditions and is coded  'I1,  '?', or  '9' (loose cap).






31  Tank Label - displays required fuel and is coded '0'




    (for leaded vehicles), '!', or '7'.






32  Filler Neck Inlet Restrictor - The restrictor is




    designed to prevent the introduction of leaded fuel




    into a vehicle requiring unleaded fuel.  It is coded




    '0' (for leaded vehicles),  '!', '4' (widened), or '7'.






33  Plumbtesmo - Plumbtesmo paper is  used to check for the




    presence of lead in vehicle exhaust pipes.  A positive




   J.ndication is coded as 'P1 and a  negative as 'N'.






34  Fuel Sample - indicates if inspector was able to obtain




    fuel sample for later lead analysis ('Y' or 'Z').

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                               -72-


2.  Classification Of Component Conditions

     The  table below was  used to classify  the various  system

components  as tampered  (T),  arguably tampered (A),  or

malfunctioning (M).  Only those codes which  are applicable

to a given  component are  listed.  Codes  for  'not originally

equipped1 and 'functioning properly' are not included  in

this table.   Refer to Appendix B, Part 1 for an explanation

of the codes.



                    	Codes from forms A and B

   Component/system




   Dash Label

   Tank Cap

   Tank Label

   Filler Neck  Restrictor

   Catalytic Converter

   Oxygen Sensor

   PCV System

   Heated Air Intake

   Evaporative Control
    System

   Aspirated Air                     T               T          M
    Injection System

   Air Pump Belt                                    T     M
   T = tampered
   A = arguably tampered
   M = malfunctioning
| 2 3 | 4 | 5 | 6 | 7 | 8
A
A
A
or T T •
T
T T T
T T T
T A A
rp wi rri rn fri
9 | B
M
M T
M T
M

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                               -73-
                                       Codes from forms A and B
Component/system     |2|3|4|5|6|7|8|9|B
Air Pump System




BGR Control Valve



EGR Sensor
T
T T
T T
T
T
T
M
M


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                              -74-






3.   Fuel Sample Collection and Labeling Procedures






     A fuel sample was taken from each vehicle requiring




unleaded fuel.  These samples were collected in two-ounce




bottles with a hand-operated fuel pump.  Once the sample was




drawn, the fuel was replaced with an equivalent amount of




unleaded fuel if the driver requested, and the pump was flushed




with unleaded fuel.




     Each bottle was identified with an adhesive label that




had the vehicle identifying survey number on it.  The vehicle




identifying number was the first entry on the data forms




described in Part 1 of Appendix B.  The bottles were packed,




labeled, and shipped to EPA's Motor Vehicle Emissions Laboratory




in Ann Arbor according to the shipper's requirements.

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                              -75-


4.  Plumbtesmo Application

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 to remove soot deposits

     which might mask the color change.

2)   Moisten the Plumbtesmo paper with distilled water and

     immediately* press firmly against the surface to be tested

     for approximately thirty seconds.  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 approximately 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.  Subsequently

     handling a clean test paper may cause contamination.

3)   After removing the test paper,  determine whether a color

     change has occurred.   Red or pink coloration indicates

     the presence of lead.

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                              -76-






5.  Field Quality Control/Assurance






     Reference and calibration gases  were  used to ensure the




accuracy of the emissions analyzer.   Horiba gases certified by




RTF 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 were certified by the manufacturer and the RTF reference




gases.  Their approximate compositions were:




     8% CO




     1560 ppm HC (Hexane equivalent)








     4% CO




     827 ppm HC (Hexane equivalent)








     1.6% CO




     320 ppm HC (Hexane equivalent)

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                              -77-

                           APPENDIX C

               EMISSION CUTPOINTS FOR I/M AREAS


The table below lists the emission cutpoints used in 1986 by

the I/M areas covered in the 1986 tampering survey.   The cut-

points for pre-1975 vehicles are not included, since these

vehicles were not surveyed.
Survey Site

St. Louis, MO



Memphis, TN



Pittsburgh, PA



Hartford, CT



Camden, NJ


Seattle, WA
Model Year

1975-79
  1980
  1981 +

1975-79
  1980+
  1981+

1975-79
  1980
  1981 +

1976-79
  1980
  1981+

1975-80
  1981+
Emissions Cutpoints
 CO (%)    HC (ppm)
  6.0
  3.0
  1.2

  8.5
  6.5
  3.0

  4.0
  3.0
  1.2

  3.0
  2.5
  1.2

  3.0
  1.2
1975-78             3.0
1979+(no CC)        3.0
1979+(CC, 4 cyl.)    2.0
1979+(CC, 6-8 cyl.) 1.5
 600
 300
 220

1990
1990
1990

 400
 300
 220

 300
 275
 220

 300
 220

 800
 600
 300
 300
KEY:  CC = catalytic converter (all types),  CYL. = cylinder,
      OC = oxidation catalytic converter, AI = air injection,
      TWC = three way catalytic converter.

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                              -78-
Survey Site

Los Angeles,  CA
Tucson,  AZ
Model Year         	

1975-79(no CC)       3.
1975-79(OC, no AI)  4
1975-79(OC, AI)     1.
1975-79(TWC)        1
1980+(no CC)        2,
1980+(OC, no AI)    2
1980+(OC, AI)       1.
1980+(TWC)          1

1975-78(4 cyl.)     2.2
1975-78(6-8 cyl.)   2.0
1979 (4 cyl.)       2.2
1979 (6-8 cyl.)     2.0
1980+               1.2
Emissions Cutpoints
 CO (%)    HC  (ppm)
    5
    5
    5
    5
    5
    5
    2
    0
200
250
150
100
150
150
150
100

250
250
220
220
220
KEY:  CC = catalytic converter (all types), CYL. = cylinder,
     -'OC -'oxidation catalytic converter,  AI = air injection,
      TWC = three way catalytic converter.

-------