INSPECTION AND MAINTENANCE
A GUIDE FOR IMPLEMENTATION
ENVIRONMENTAL PROTECTION AGENCY
ROUGH DRAFT
Do not cite or quote.
Strategies and A1r Standards Division
Research Triangle Park, N. C.
February 25, 1974
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INSPECTION AND MAINTENANCE
A GUIDE FOR IMPLEMENTATION
ENVIRONMENTAL PROTECTION AGENCY
Strategies and Air Standards Division
Research Triangle Park, N. C.
February 25, 1974
TCP-1
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DOCUMENT STATUS
This document is being circulated within EPA for critical
review and comment only and should not be cited or quoted. It
is a draft and therefore, does not reflect official EPA policy.
Mention of companies or product names does not constitute
endorsement by EPA.
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TABLE OF CONTENTS
Chapter I Introduction
Legislative Review
Air Quality Criteria, Standards, and Pollutants 1-3
Extent of the Problem 1-7
References 1-9
Chapter II Inspection and Maintenance Programs
Description of Inspection and Maintenance Programs II-l
Instrumentation and Equipment 11-12
Effectiveness of Inspection and Maintenance Programs 11-13
Cost of Inspection and Maintenance Strategies 11-22
Factors in Choosing an Inspection and Maintenance Strategy 11-27
References 11-29
Chapter III Legal Authority
Enabling Legislation III-3
Rules and Regulations III-4
References 111-8
Chapter IV Implementation
Agencies Involved IV-1
Implementation Schedule IV-5
Federal Assistance IV-10
Training IV-14
Potential Problems Associated with Inspection and IV-19
Maintenance Programs
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Chapter V Monitoring and Reporting
Monitoring V-l
Reporting V-8
Public Acceptance V-ll
Chapter VI Federal and State Programs Related to Inspection
and Maintenance
Programs Sponsored by the Federal Government VI-1
Programs Sponsored by State and Municipal Governments VI-5
References VI-8
Appendix A Environmental Protection Agency Regional Offices
Appendix B Glossary
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Table 1
LIST OF TABLES
Summary of National Air Quality Standards for Motor
Vehicle Related Pollutants
Table 2-1 Engine Parameter Inspection
Table 2-2 New Jersey Approved Manufacturers of Low Cost Infrared
Analyzers Suitable for Use in Repair Garages
Table 2-3 Initial Reductions in Pollutants With Major Inspection
Strategies
Table 2-4 Reductions in Polluting Emissions to the Atmosphere from
a Vehicle Population Subjected to Emission Inspection
Table 2-5 New Jersey Idle Inspection Standards
Table 2-6 Costs of Equipment for Emission Inspection
Table 2-7 Inspection Station Cost Estimates
Table 2-8 State of California Total Program Costs
Table V-l Inspection and Maintenance Emission Data
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LIST OF FIGURES
Figure 2-1 Derivation of Emission Standards from Cumulative Distri-
bution of Emissions
Figure IV-1 Implementation of State Owned Inspection Lanes (Idle or
Loaded Mode Tests)
Figure IV-2 Implementation of Idle Inspection at Licensed Garages
Figure V-l Vehicle Emission Inspection - Idle Method
Figure V-2 Vehicle Emission Inspection - Loaded Method
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CHAPTER I
INTRODUCTION
The purpose of this document is to provide guidance to applicable
Federal, State, and local agencies on how to implement.and monitor an
inspection and maintenance program for motor vehicles. Before begin-
ning discussion of the various aspects of an inspection and maintenance
program however, it would perhaps be helpful to review briefly the
evolution of the fight against air pollution, with emphasis on motor
vehicle pollution abatement.
A brief legislative review provides an insight into the impor-
tance which legislators have increasingly attached to motor vehicle
control over the past decade. A discussion of air quality criteria
and standards gives an overview of the basic relationship between
criteria and standards. A discussion of pollutant characteristics is
included to give the reader an understanding of the types of pollutants
emitted by motor vehicles. Finally, a discussion of the extent of
motor vehicle pollution highlights the need for control and how this
control can be accomplished.
Legislative Review
The U.S. Congress first responded to growing public concern over
declining air quality in 1955 with legislation authorizing a Federal
program of air pollution research and technical assistance to State and
local governments (PL 84-159). This legislation established a policy,
retained in all subsequent legislation, that State and local governments
have fundamental responsibility for local air pollution control with
the Federal Government providing leadership and support.
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The first congressional efforts to bring vehicle emissions under
control were initiated in 1961 with public law 86-493. This legislation
authorized the'Public Health Service to conduct a study of pollution
caused by vehicles and to report the results to Congress. An amendment
to this law (PL 87-761} authorized vehicle studies on a continuing basis.
As a result of this legislation, significant progress was made toward
achieving an understanding of the air pollution problem and developing
methods for air pollution control. By 1973, however, it became apparent
that the progress in scientific understanding was not being translated
into improved air quality, primarily because State and local governments
had neither the resources nor the authority to adequately cope with the
problem.
Results of early studies authorized by Congress indicated that
motor vehicles were contributing significantly to overall air pollution
levels. Consequently, Congress passed an amendment to the Clean Air
Act in 1965 authorizing the Department of Health, Education, and Welfare
to set emission standards for motor vehicles. Initial standards per-
taining to crankcase and tailpipe emissions from gasoline-powered
motor vehicles became effective in the 1968 model year. The most recent
Federal legislation, the Clean Air Amendments of 1970, impact directly
on transprotation systems in addition to individual motor vehicles
through such provisions as: requiring State implementation plans to
include land-use and transportation controls where necessary, and setting
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new motor vehicle emission standards to be effective in model year
1975* for carbon monoxide and hydrocarbons and in model year 1976* for
oxides of nitrogen. While these new motor vehicle emission standards
are a Federal responsibility, States have the responsibility to control,
regulate, or restrict the use, operation, or movement of registered or
licensed motor vehicles where necessary.
Air Quality Criteria, Standards, And Pollutants
Air Quality Criteria
The 1967 amendments to the Clean Air Act required the Department
of Health, Education, and Welfare to publish air quality criteria judged
to be requisite for the protection of public health and welfare. Air
quality criteria are an expression of the scientific knowledge of the
relationship between various concentrations of pollutants in the air
and their effect on man and his environment. Criteria are descriptive
in that they describe the effects that have been observed to occur when
the concentration of a pollutant in the air has reached or exceeded a
specific level for a specific period of time. Such criteria provide the
most realistic basis that we presently have for determining to what point
pollution levels must be reduced if we are to protect public health and
welfare.
As scientific knowledge grows, air quality criteria will have to
be reviewed and, in all probability, revised. The Congress has made it
* Required compliance with these emission standards has been delayed
until 1976 for carbon monoxide and hydrocarbons and. until 1977 for
oxides of nitrogen.
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clear, however, that we are expected, without delay, to make the most
effective use of the knowledge we now have.
Air Quality Standards
The 1970 amendments to the Clean Air Act required the Environmental
Protection Agency (EPA) to promulgate national air quality standards for
each air pollutant for which air quality criteria have been issued. Air
quality standards are prescriptive. They prescribe pollutant exposures or
levels of effect that should not be exceeded in a specified geographic area.
Air quality standards for motor vehicle related pollutants are pro-
vided in Table I.
Table I
Summary of National Air Quality Standards
For Motor Vehicle Related Pollutants
Averaging Primary & Secondary
Pollutant Time Standards
CO 8 - Hour* 10 mg/m3 (9ppm)
1 - Hour* 40 mg/m3 (35ppm)
NO- Annual 100 yg/m3 (O.OSppm)
(Arithmetic Mean)
Photochemical 1 - Hour* 160 jig/m3 (O.OSppm)
Oxidants
Hydrocarbons 3 - Hour* 160 yg/m3 (0.24ppm)
(Non-Methane)
*Not to be exceeded more than once per year.
NOTE: The hydrocarbon standard is a guide to developing State imple-
mentation plans to achieve the oxidant standard. The hydrocarbon
standard does not have to be met if the oxidant standard is met.
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Air quality standards are set at two levels, primary and secondary.
Primary standards establish how clean the air must be to safeguard
human health. Secondary standards establish how clean the air must
be to prevent damage to clothes, buildings, metals, vegetation, animals,
etc. As shown in Table I, primary and secondary standards for motor
vehicle related pollutants are the same, which means that the levels
set for each pollutant are sufficient to protect both health and welfare.
The above standards are "national" in that they apply to all 50
States, the District of Columbia, and three U. S. territories. These
political jurisdictions have until mid-1975 (1977 in some cases) to meet
the standards.
Pollutant Characteristics
The air pollutants discussed below are often called the motor
vehicle related pollutants. This is because first, that they are emitted
by motor vehicles, and secondly, because the amounts of these pollutants
emitted by motor vehicles constitute a major portion of the total of
such pollutants emitted by all sources.
1. Carbon monoxide: Carbon monoxide is the most widely distributed
and the most commonly occurring air pollutant. ' Total emissions of
carbon monoxide to the atmosphere exceed those of all other pollutants
combined. Most atmospheric carbon monoxide is produced by the incomplete
combustion of carbonaceous materials such as fuels for vehicles, space
heating, and industrial processing. Man's activities are, therefore,
largely responsible for carbon monoxide contamination.
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The introduction of the internal combustion engine for transportation
and the development of a number of technological processes which produce
carbon monoxide have greatly increased atmospheric concentrations. Tfcans-
portation activities represent the largest source category. Concern has
now broadened from the acute and often lethal effects of high concentrations
of the gas to encompass as well those effects that may occur as a result of
considerably longer exposures to much lower concentrations.
2. Nitrogen oxides: Of the various oxides of nitrogen, the most
important as air pollutants are nitric oxide and nitrogen dioxide. The
term nitrogen oxides usually refers to either or both of these two substances.
Nitric oxide and a comparatively small amount of nitrogen dioxide are
formed under high temperature conditions such as those that accompany the
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burning of fossil fuels. ' They are emitted to the atmosphere from
automobile exhaust, furnace stacks, incinerators, and vents from certain
chemical processes. These substances are also important in air pollution
control becuase they are involved in .photochemical reactions in the atmosphere.
Mobile sources are the largest single source category, contributing
over 40 percent of all man-made nitrogen dioxide in the United States. '
The next largest source is electric power generation which is responsible
for nearly 20 percent of all man-made nitrogen dioxide.
3. Photochemical oxidants: As initiated by sunlight, a series of
complex atmospheric reactions between hydrocarbons and oxides of nitrogen
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lead to the formation of new substances, among which are ozone and oxidants/ '
These substances are chemical entities detrimental to^ biological systems
and destructive to certain materials. The complexity of the atmospheric
reaction has led to differences in interpretation of experimental results
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by researchers These differences relate to the degree of reactivity of
various hydrocarbons and the effects of reactivity over a period of time.
The Division of Chemistry and Physics of the National Environmental Research
Center is conducting research in these and other areas.
4. Hydrocarbons: Hydrocarbons are important in air pollution con-
trol, not because of their direct effects, but because of their role in
photochemical reactions. Hydrocarbon emissions originate primarily from
the inefficient combustion of volatile fuels and from their use as process
raw materials. It was estimated that the transportation source category
contributed 52 percent of the nationwide hydrocarbon emissions in 1968. '
Organic solvent was the second largest source category, contributing about
27 percent, and industrial processes was third, contributing 14 percent.
Extent of the Problem
Taken individually, the automobile appears to be a very minor air
pollution offender. The amount of hydrocarbons, carbon monoxide, and
nitrogen oxides emitted by a single automobile are small compared to
industrial sources. However, the sheer numbers of automobiles operating
daily cause serious air pollution problems in many metropolitan areas. For
example, there were approximately four million vehicles, including trucks,
in Los Angeles County in 1970, ' or one vehicle for every two people in
the County. If the present growth trend continues,.there will be approxi-
mately six million vehicles in Los Angeles County by 1990. One and on-
half million vehicles were driven about 35 million miles in the Greater
Houston area in 1971, and over one billion gallons of gasoline and diesel
fuel were consumed in the process. ' These kinds of statistics make it
obvious that vehicle pollution must be controlled.
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Transportation control measures are of two basic types.
Measures such as bus/carpool lanes and parking restrictions are
intended to encourage the use of more efficient modes of travel, i.e.,
buses and carpools, instead of the single passenger motor vehicle.
As a result of a shift to more efficient travel modes, vehicles miles of
travel (VMT) are reduced and the pollutants emitted are reduced. Measures
such as retrofits and inspection and maintenance are intended to reduce
the quantity of pollutants emitted by motor vehicles. The latter of these
measures, inspection and maintenance, is required either by the State or
EPA in most of the metropolitan areas which now require transportation
controls.
An inspection and maintenance program by itself is a control measure
which can facilitate substantial reductions in automobile exhaust emis-
sions. In addition, an inspection and maintenance program can mean much more
to a program to reduce automotive emissions, since it is a corner stone
for an effective mobile source control program. For example, an inspection
and maintenance -program is basic to any retrofit program which may be
implemented. Furthermore, it is vital to the implementation of the warranty,
recall, and anti-tampering provisions of the Clean Air Act. These programs
will assure that the emission reductions achievable by the Federal Motor
Vehicle Control Program are actually attained by vehicles in use.
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References
1. Air Quality Criteria for Carbon Monoxide (AP-62). U. S. Department
of Health, Education, and Welfare, National Air Pollution Control
Administration, Washington, D. C., March 1970.
2. Air Quality Criteria for Nitrogen Oxides (AP-84), Environmental
Protection Agency, Air Pollution Control Office, Washington, D. C.,
January 1971.
3. Control Techniques for Nitrogen Oxide Emissions from Stationary Sources
(AP-67), U. S. Department of Health, Education and Welfare, National
Air Pollution Control Administration, Washington, D. C., March 1970.
4. Air Quality for Photochemical Oxidants (AP-63), U. S. Department
of Health, Education, and Welfare National Air Pollution Control Admin-
istration, Washington, D. C., March 1970.
5. Air Quality Criteria for Hydrocarbons (AP-64), U. S. Department of
Health, Education, and Welfare, National Air Pollution Control
Administration, Washington, D. C., March 1970.
6. Transportation Control Strategy Development for the Metropolitan
Los Angeles Region, APTD-1372, EPA, December, 1972.
7. Transportation Control Strategy Development for the Greater Houston
Area. APTD-1373, EPA, December, 1972.
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CHAPTER II
INSPECTION AND MAINTENANCE PROGRAMS
Inspection and maintenance covers a variety of strategies for
reducing air polluting emissions fron light-duty motor vehicles
currently in use by establishing procedures that will assure their
continued proper maintenance by the motorist. Most of the approaches
have two distinct phases: an inspection phase, in which motorists
arc required to periodically present their vehicle for examination;
and a maintenance phase, in which vehicles failing to meet the passing
requirement of the examination must be taken to a garage for maintenance
to bring them back into compliance.
Description of Inspection and Maintenance Programs
There are three classifications which cover the major alternate
approaches to inspection and maintenance, emission inspection, engine
parameter inspection, and mandatory maintenance. Emission inspection
involves sampling the exhaust gases from the vehicle being examined
and passing them through suitable analytical instrumentation to measure
the quantities of air polluting compounds they contain. If the concen-
trations of these compounds all fall below the standards set by the
rppronriate agency, the vehicle passes the examination. If the concen-
trations of any pollutant are above the standard, the vehicle fails.
Vehicles failing the test must then be adjusted or repaired to bring
the emissions into compliance. Following the maintenance, it would
normally be required that the vehicle be resubmitted for an emission
test to determine that it is in compliance.
Engine parameter inspection involves the examination of critical
engine components and adjustments to determine whether thr engine is
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functioning according to the manufacturer's specifications. If the
vehicle failer7 to fall within the tolerances set by the State agency
it would bo required to undergo needed adjustments or repairs to
brinn it within the tolerances. If the required maintenance were
performed by a certified mechanic there would be no necessity for
returning the vehicle for reinspeotion.
Mandatorv maintenance avoids the inspection phase entirely. Here
the vehicle must periodically undergo specified maintenance procedures
bv ar authorized garage. The maintenance procedures are1 designed to
correct or avoid the most frequent types of emission-related malfunctions
of "vehicles of a particular make, model, and year of manufacture.
Before discussing the various inspection and maintenance programs,
it is perhaps worthwhile to discuss the alternate ways in which a
state, county, or municipal agency might structure an inspection and
maintenance system.
Operational Configuration
The broad configurations of inspection and maintenance programs are:
1. Publicly operated lane system
2. Privately operated lane system
3. Licensed garage system
In the publicly operated lane system, the inspection function is
performed directly by the appropriate government agency in publicly
owned and operated facilities set up for inspection of motor vehicles.
The facilities may be exclusively devoted to emission testing or
include other types of required inspection such as vehicle safety.
In a privately operated lane system, the testing would be performed
by a private organization under contract to the appropriate government
agency. The facility might either be publicly owned or the property of
the licensee.
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In the licensed garage system the testing is performed by existing
private service or repair agencies within the repair and maintenance
industry. The facility is certified, licensed, and controlled by the
appropriate government agency.
Generally, it is assumed that any needed repair, adjustment, or
maintenance would be done by private service garages and dealerships.
In the case of the licensed garage system described above, the garage
performing the inspection would be in a position to do the required
work to bring the vehicle into compliance.
Emission Inspection
The two major considerations in performing an emission inspection
are the emission measurement itself and the vehicle operating condition
during the measurement.
Analysis of Vehicle Exhaust Gases; The air pollutants in auto-
motive exhaust of concern in inspection and maintenance are hydrocarbons,
carbon monoxide, and nitrogen oxides.
Hydrocarbons may be measured by either of two methods: infrared
absorption or flame ionization detection. Infrared instruments work
by measuring the infrared energy absorbed by the hydrocarbons in the
sample gas. Hydrocarbons absorb only at specific infrared frequencies.
F.y measuring just the energy absorbed at these frequencies, the instru-
ment will sense only the hydrocarbons in the sample gas.
Flame ionization detection depends on the fact that hydrocarbons
introduced into a sample gas generate electrons in a hydrogen flame
which can be detected as an electric current by applying a voltage
across the flame.
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Presence of carbon monoxide is determined by infrared absorption.
In this case the instrument is set to respond to the particular
frequencies of infrared radiation absorbed by carbon monoxide. It is
therefore, not affected by the hydrocarbons present in the gas since
they absorb in a different region of the infrared spectrum.
Nitrogen oxides are really two gases, nitric oxide (NO) and nitrogen
dioxide (NO ). The nitrogen oxides in exhaust gas freshly sampled
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from an engine are almost entirely nitric oxide. However, if the sample
stands for more than a minute as is the case in some sampling methods,
oxygen present in the exhaust will oxidize a portion of the nitric oxide
converting it to nitrogen dioxide. This tendency for the nitric oxide
to convert to nitrogen dioxide complicates the measurement of nitrogen
oxides. Nitric oxide can be determined by infrared absorption. However,
since water absorbs infrared radiation fairly strongly in the nitric
oxide absorption region, the gas must be first passed through a
dessicant to remove all water.
Nitrogen dioxide can be measured by ultraviolet light absorption,
but the method lacks sensitivity. When the infrared and ultraviolet
absorption instruments are used the individual concentrations are
summed to give the total concentration of nitrogen oxides.
In recent years chemiluminescent instruments have become available
for nitrogen oxide measurement. They depend upon the fact that when
nitric oxide is mixed with ozone, the nitric oxide rapidly converts
to nitrogen dioxide emitting light in proportion to the concentration
of nitric oxide present. The emitted light is measured with a photo-
nultiplier tube. To make the instrument measure total nitrogen oxides
the sample qa.s is first passed through a stainless steel or molybdenum
tube at high temperature to decompose any nitrogen dioxide present
back to nitric oxide. By this procedure all the nitrogen oxides are
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present as nitric oxide as they pass into the ozone reaction chamber.
This method requires a means of generating ozone and careful control
of pressures. There may also be interference from carbon monoxide
under certain operating conditions. The chcmiluminescent method is specific
in the Federal motor vehicle certification regulations for measuring exhaust from
gasoline powered engines.
Fxhaust gases contain about 15 percent water and varying levels
of particulate matter. At room temperature the water will condense in
sample lines and within the instruments. This condensation along with
particulate matter will quickly cause an analytical instrument to
Iria Ifunction or give erroneous readings. It is therefore customary to
provide a water trap to condense excess water and a filter to remove
the particulate matter. For delicate research grade instrumentation
commonly used in the Federal test procedure for new vehicle certification,
elaborate refrigerated condensing systems and high efficiency fiber glass
filters are used. For the simplest instrument used by garage mechanics
for diagnostic tests, simple ambiqnt temperature knockout traps and
ceramic filters will do the job.
The sampling system in its simplest configuration is a hand held
metal probe attached to the instrument system with flexible tubing.
A gas pump pulls gas through the probe, the clean-up system and the
analytical instrument. Set up this way the measurement system measures
the concentrations of the pollutant compounds in the exhaust. Typically
the concentration is expressed as volume percent for the carbon monoxide
and parts per million by volume for the hydrocarbons and nitrogen oxides.
If it is desired to make emission measurements which will correlate
more closely with results that would be obtained by the Federal certifi-
cation procedure and provide the same units of grams/mile, a constant
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vo]unc sampling systen xvould be used. This .system hn the effect of
weighting emissions at each driving condition by the flow rate of
exhaust eras at that condition. It automatically weights and averages
the emissions collected over changing operating conditions. It also allow
correct comparison of emissions from different engine sizes. Although
this procedure would provide the most accurate results, these systems
are oeneral.ly large and expensive and only feasible whore a Targe number
of vehicles are to be processed" By each system.
Vehcile Preconditioning; Pre-conditioning of the vehicle is
important in achieving repeatable anc1 meanincful results. In tie
Federal test procedure, the vehicle mist stare1 inoperative for at
least twelve hours within a specified range of arbient temperatures
before the engine is started and the emission measurement begun. This
procedure is called a cold start, and brings into play the effect of
cboko setting on emissions.
An alternate, referred to as a hot start, is to start the test
with the vehicle at or near its normal operating temperatures. For
in-use vehicle emission inspection both these procedures require more
time than is normally available. Since it is not reasonable to reouire
the car to stand for 12 hours until inspected, some variation of hot
tost preconditioning is necessary. In the case of an idle test, several
seconds of running at higher speeds in neutral will help clear the
engine. This conditioning can be helpful if vehicles have been standing
in an inspection line idling for some time before the start of the test.
When a loaded mode test is used, there can be some short running at a
higher speed under load.
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Vehicle Operating Modes; The choice of the mode or modes of
operation over which the sample is taken determines how closely the
emissions measured by the inspection procedure correspond to or
correlate with the emissions to the atmosphere from vehicles in normal
use. They also determine the amount of diagnostic information the test
will provide in the case of a vehicle failing the inspection test.
An operating mode is a period of operation over which the vehicle
is either running at a constant speed or undergoing an acceleration
or deceleration. A constant speed or cruise mode would be defined by
the speed and the time interval over which it was maintained. Idle is a
constant speed mode of zero speed. An acceleration or deceleration mode,
called transient modes, could be typified by the speed of the vehicle
at the start and end of the mode and the time interval between the two
speeds.
An inspection may consist of sampling exhaust gases at one or more
nodes. Up to a point, the greater the number of modes examined, the
better the correlation with emissions to the atmosphere and the more
diagnostic information available.
The idle mode is commonly referred to as a no-load mode since there
is little or no resistance to the running of the engine. All other
modes are considered loaded since the wind, rolling friction, and engine
friction all put a load on the engine. To simulate the action on the
engine of running on the road a chassis dynamometer is used.
A chassis dynamometer consists of a pair of parallel rollers which
support the rear wheels of the vehicle under test. The car can then
be placed in gear and the rear wheels driven on the rollers while
the vehicle stands in place. Adjustable, heavy inertial weights are
attached to the rollers to resist changes in speed, thus simulating the
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weiaht of the vehicle. Also, a power absorption unit is usually attached
to the rollers to resist their rotation and thus simulate wind and
other resistances to the motion of a vehicle. With a chassis dynamometer,
it is possible to fully simulate thp engine behavior for a vehicle
on the road while the vehicle stands in place - a great convenience for
emission testing.
An idle mode inspection test is the simplest emission inspection
that can be performed. It requires the simplest instrument system and
needs no dynamometer. Pass or fail can be indicated by lights on the
instrument set to activate at the fall points. The inspector need only
indicate which pollutants were above the standard. There is no need to
indicate how far above since there is little or no diagnostic content
in this information. The test should be completed in two minutes in a
licensed garage inspection and under a minute in a lane inspection.
Loaded mode emission tests with a dynamometer allow for a variety
of test cycles. One of the well known test cycles is the Clayton Key
node test. In this test emissions are measured under each of three
successive constant speed modes, 50 mph, 30 mph, and idle. The power
absorption is set proportional to the third power of the road speed giving
a high loading of 30 horse power at 50 mph. Under this condition the
vehicle is at a higher load than would be experienced in level road
operation. The high engine loading is said to provide better diagnostic
information than a normal load. Fail limits can be set for each of
the conditions or a linear combination of them. In any event, the
readings at all three conditions should be given to the vehicle owner
on a card so that thp mechanic can use them in performing the needed
maintenance. An example of how the mechanic might use this informaiton
is as follows: a normal hydrocarbon level at idle and a too high level
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at high speed points to electrical problems. The reverse would indicate
incorrect adjustment of carburetor at idle. Alternatively, a card
indicating the probably faults may be supplied.
Since only cruising speeds are used, the dynamometer for a key mode
test does not require inertial weights. The result is a substantial
reduction equipment in cost and elimination of th need to set inertia
weight for each vehicle.
The driving cycle may also involve transient operating modes. An
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example is the so called ACID cyclev ' in which the emissions are
measured while the vehicle is accelerated at a constant rate to 30 mph,
held at 30 mph, decelerated at a constant rate to idle, and held at
idle for a specified time. This cycle was designed to operate with a
constant volume sampler. Because the loading is not as severe as with
the key mode, it may not be as valuable a diagnostic tool. The ACID cycle
requires a dynamometer with both power absorption and inertial weights so
that it responds properly to the acceleration and deceleration modes. Use
of inertial weights increases the costs substantially.
Engine Parameter Inspection
The second major alternate strategy for inspection and maintenance
is the inspection of selected engine parameters for departure from
manufacturers' specifications. Only those parameters need be inspected
which have an impact on vehicle emissions. Table 2-1 shows the significant
(3)
parameters identified in one study v ' influencing carbon monoxide and
hydrocarbon emissions for precatalytic emission control systems.
Note that an infrared analyzer is used in measuring the idle
adjustments. Here the instrument is being used as an air-fuel ratio
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meter rather than as an emission measurement device. With the adoption
of devices for controlling nitrogen oxides and catalytic devices to meet
1975 and later standards, additional parameters will have to be added to
those in Table 2-1.
A check of the subsystems in Table 2-1 represents an extensive and
costly inspection. Depending upon the extent of emission reduction ex-
pected from inspection and maintenance, a less extensive system might be
substituted.
Failure limits would be established based on manufacturers speci-
fications, but his does not guarantee identifying all the high emitters.
However, the engine parameter inspection strategy specifically identifies
the maintenance to be done. It in effect combines inspection and diagnosis.
This also means that the car need not be reinspected if the repair is by
a certified garage.
Mandatory Maintenance
Mandatory maintenance eliminates the inspection step by simply
requiring that certain replacements and adjustments be made to the engine
periodically. This can include replacement of spark plugs, points and
condenser, air cleaner filter, catalyst, etc. and adjusting timing, air
fuel ratio, air pump belt tension, etc. In the area of adjustments,
manufacturer tolerances would still have to be followed so that mandatory
maintenance does not eliminate the inspection phase but rather, makes
it an integral part of the maintenance. In effect, the certified mechanic
who does the maintenance is also the inspector. While this is a simplifying
step, it may result in more maintenance than is needed to achieve the
desired control of emissions from the in-use vehicle population.
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TABLE 2-1
Enoine Parameter
Equipment
Subsystem Engine Parameter Requirements
Idle Adjustments % Idle CO IR CO Analyzer
RPM, Timing Tachometer, Timing
Light
Secondary Ignition Plugs, Wires Electronic Engine
Distributor Analyzer
Induction Air Cleaner Air Cleaner Tester
PCV Valve Pressure Gauge
Air Injection Air Floy/meter
System
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Instrumentation and Equipment
The necessary technology for conducting vehicle inspections and
required maintenance has reached a point where a State has a full range
of alternate systems to choose from without the necessity of sponsoring
an extensive development effort. The scientific instrument, computer,
dynamometer, and garage service industries have participated in various
inspection and maintenance programs over the last seven years and have
developed a substantial capability.
The following companies have been involved in the design and
manufacture of emission test systems (not to be confused with manufac-
turers of individual system components) for inspection and maintenance
programs and may be consulted on the overall system design:
1. Automotive Environmental Systems, Inc.
2. Beckman Instruments, Inc.
3. The Bendix Corp., Environmental Science Div.
4. Horiba Instruments, Inc.
5. Interteck Corp.
6. Olson Laboratories
7. Sun Electric Corporation
-8. Scott Research Laboratories, Inc.
The need for low cost infrared analyzers for measuring carbon
monoxide and hydrocarbons that would be suitable for use in idle emission
inspection and by repair garages has spurred a major and successful effort
by the instrument industry to develop practical instruments. Consequently,
there are a large number of good instruments now available. Table 2-2
lists the infrared instruments currently approved by New Jersey for use in
repair garages. These same instruments would be suitable for inspection
in a licensed garage inspection system.
11-12
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Effectiveness of Inspection and Maintenance Programs
So many factors enter into determininq the effectiveness of the
programs which have been discussed that is is difficult at tho present
timo to mako an accurate assessment. The information we have from
the various studies of this question is summarized in this section.
Relative Effectiveness of Principal Programs
The three main programs are compared in Table 2-3 on the basis of
reductions in emissions obtained immediately following required
(4)
maintenance . The data shown for the exhaust emissions inspection
are a combination of results obtained using idle and a loaded mode
inspection tests. The data show that it is possible to achieve
significant reduction in hydrocarbons and carbon monoxide in rejected
vehicles which have been serviced for each of the three general
programs. Notice that there is no significant improvement in
for the pre-1972 vehicles tested in the case of nitrogen oxides.
This situation can be expected to change as vehicles with nitrogen
oxides controls become prevalent.
Comparisons are made of initial reductions immediately following
maintenance both for the vehicles that were serviced am? the total fleet
(serviced and unserviced). The latter measure is a better indicator
of reductions in emissions to the atmosphere.
11-13
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Table 2-2
New Jersey Approved
Manufacturers of Low Cost Infrared
Analyzers Suitable For Use
in Repair Garages
Supplier
Model
Allen Electric Company
Emission Analyzer Model # „
23-060 Series and 23-070 Series
American Motors Corp.*
AMserv Model #23-067 Series
and 23-077 Series
American Parts Company
Powerreody Infrared HCKO Analyzer
Model #370-400
Atlas
Exhaust Emission Tester Model
#340
Autoscan, Inc.
CO and HC Analyzer Model Nos.
710 and 4030
Barnes Engineering Co.
Emission Analyzer Model #8335
Beckman Instrument Company
HC/CO Vehicle Emissions Analyzer
Model #590
Chrysler Corporation*
Technician Service Equipment
Program. Model Nos. DCE*75,
23-066 Series and 23-076 Series
Ford Motor Corporation*
Rotunda Equipment Program
Rotunda Analyzer Model Nos.
BRE-42-730 and BRE-42-731
Kal-Equip
HC/co Infrared Emissions
Analyzer Model #4094-C
Marquette Manufacturing Corp.
Emissions Analyzers Model Nos,
42-151 and 42-153
NAPA Balkamp
Infrared HC/CO Emissions
Analyzer Model #14-4787
11-14
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Table 2-2 (cont'd.)
Supplier
Model
Horiba Instruments Ltd.
Engine Exhaust Analyzer
Models CSM-300 and Mexa-300
Peerless
Infrared Exhaust Gas Tester
Model #600
Stewart-Warner
Infrared Gas Analyzer
Model #3160-A
Sun Electric Corporation
Sun EET-910, U-912, U-912-I
and EPA-75 Exhaust Emission
Testers
Womaco-Yanaco
Exhaust Gas Analyzer Model# EIR-101
Available only to New Car Dealers of the company.
11-15
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Table 2-3 Initial Reductions in Pollutants
With Major Inspection Strategies
(Pre 1972 Vehicles)
I/M Strategy %
Vehicles
Serviced
Exhaust Emission Inspections
Loaded Test
Idle Test
Engine Parameter Inspection
Mandatory Maintenance
30%
30%
95%
100%
Initial Reduction in Mean Exhaust Emissions
From Serviced Vehicles From Total Fleet
HC
50%
45%
11%
15%
CO
41%
38%
6.5%
U%
NO
0
0
0
0
HC
27%
22%
10%
15%
cp_
19%
16%
6%
11%
NO
0
0
0
0
-------
Looking at the reductions in the serviced vehicles only,
it appears that exhaust emission inspection is substantially
more effective than the other two programs. However, in the
case of the exhaust emission inspection only the high emitters
were serviced and as seen in the table, this constituted only
30 percent of the vehicles. Since the engine paramenter inspection
and mandatory maintenance resulted in servicing nearly the total
fleets, half of whom may have had little need for servicing from
an emission point of view, the average reduction per vehicle appeared
lower. When the three programs are compared on a total fleet
basis the results for each were roughly comparable.
Reductions in Emissions to the Atmosphere
Before data such as that shown in Table 2-3 can be trans-
lated into reductions in emissions to the atmosphere it is nec-
essary to account for the deterioration of the emissions of a.npwiw
serviced vehicle as the vehicle detunes during subsequent use.
Unfortunately, there is an absence of good experimental data
on this point. Deterioration rate varies widely in character
and level from one vehicle to the next and even within a given
vehicle. The data available suggest that the simple assumption
of a linear deterioration rate over a period of a year is not
grossly in error. On this basis, the figures in Table 2-4 were
developed to show the percentage reductions in emissions to the
atmosphere from a vehicle population subjected to annual vehicle emis-
sion inspection.
•11-17
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Table 2-4
Reductions in Polluting Emissions to the Atmosphere from
a Vehicle Population Subjected to Emission Inspection
Percent Initial
Failure Rate 10 20 30 40 50
Idle Inspection
Hydroe'ai-Bons 6* *% 10* 11*
Carbon monoxide 3* 6* 3* 9%
Loaded Mode Inspection
Hydrocarbons 8* 11* 13* 14* 15*
Carbon monoxide 4* 7* 9* 11* 12*
SOUPCE: 38 PR Part 51, Appendix N, June 8, 1973
These are the figures given in Appendix N of the "Requirements
for Preparation, Adoption and Submittal of Implementation Plans"
(Federal Register, Vol. 38, No. 110 Part III). Information similar
to that shown in Table 2-4 is not available at the present time for
emission parameter inspection and mandatory maintenance.
The initial failure rate is shown here as an index of the
severity of the emission standard which would be set to achieve the levels
of reductions in emissions shown.
Establishing Pass/Fail Standards
Table 2-4 can be used as a basis for establishing emission standards
for an emission inspection program. It is first determined what percentage
reduction in emissions for carbon monoxide and hydrocarbons will be achieved
with the inspection and maintenance program. This consideration is part of
the overall transportation plan. Once this figure is established and a
11-18
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•H
•P
Cfl
Figure 2-1
Derivation of Emission Standard
From Cumulative Distribution of Emissions
80
60
20
Emission
Standard
Exhaust Emission Level
decision made as to whether an idle inspection or Uoded mode inspection
will be used, Table 2-4 can be consulted to determine what initial failure
rates for hydrocarbon and carbon monoxide are needed to obtain the desired
reductions in emissions. It will then be necessary to run an experimental
program to define tho dictribution •of-tgmtsstori"TWgl5'BT the-yfchtc-le
poptri-at4en. '-ry-cmiiuia-o-nre .ai.s^n-DUTM-0ft.or tne Kind snown in Mgure Z-~
then constructefi.
11-19
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Given the needed rejection rate the standard can then be set.
Figure ?-] illustrates the emission standard corresponding to an
initial rejection rate of 20 percent.
It needs to be emphasized again that initial failure rate is
not a prime consideration in setting the standard but only an
intermediary between Table 2-4 and Figure 2-1 to get from the
required reductions in the atmosphere to the emission standard which
v.'il] achieve that reduction.
While this procedure can be applied to the population as a
v;hole, it is probably fairer to distinguish between vehicles
according to whether they have emission controls and according
to the sophistication of the emission control. This follows
because fundamentally an emission inspection program is trying to
assure a vehicle is properly maintained and not emitting pollutants
in excess of its original design intention.
New Jersey for example, whose idle inspection program became
fully operational on February 1, 1974, has segregated vehicles
into three classes and developed the following standards.
Note that these standards become more stringent over the next
year. An advantage of starting with less stringent standards and
tightening them is that it gives both the public and the repair
industry an opportunity to become accustomed to the system before
the standards come into full force.
11-20
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table 2-5
New Jersey Idle Inspection Standards
Effective Effective Effective
Feb. 1, 1974 July 1,. 1974 July 1, 1975
Vehicle M§del Year
CO HC CO HC CO HC
_ (%} (ppm) (#r (ppm) (%) (ppm)
•Pre 1968 10.0 1600 -8.5 1400 7.5 1200
1968 - 1969 8.0 800 7.0 700 5.0 600
1970 - 1974 6.0 600 5-0 500 4.0 400
Estimated Failure Rate 12-15$ 25$ 35$
11-21
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Cost of Inspection and Maintenance Strategies
overall costs of putting an inspection and maintenance program
into operation will vary markedly from one situation to another.
Some of the specific costs can be pinpointed with reasonable
accuracy. This section describes estimated costs on several
bases to givei/ an appreciation of the nature of costs that will
be faced.
Costs Pe r_Veh 1 c le Inspected
7* useful view of overall costs that will have wide applicabi-
lity is to place their on a per car inspected basis. Annual emission
inspection in State operated lanes will cost about $2.00 per vehicle.
Where the tests can he incorporated into existing state safety
inspection lares, costs can be still lover. In the case of licensed
garages, costs have been estimated in the range of $3.00 to $6.00 per
vehicle for an idle emission inspection. Perforning an extensive
enaine parameter inspection in a licensed garage will cost approxi-
mately $P.OO. per vehicle.
Repair costs for an average car failing an emission or engine
narameter inspection will be $20.00 to $30.00. An extensive mandatory
maintenance program could cost up to $60.00 per vehicle.
Ccv?ts_ of Instruments and Equipment for Emission Inspection
T^s has been discussed, instrumentation and equipment for emission
inspection can vary widely from simple visual instrumentation1to fully
?iu tor a ted systems. Table 2-6 shows the price range for systems that
can ho "ner1 with idle and loaded mode inspection programs. The
specific systems shown do not cover al] the possibilities. For example,
OP a State lane there may be a desire to add a municomputer 'for some
aclr'co automation. This could easily raise the price an additional
S]ofonn.
11-22
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Table 2-6
Cost of Equipment for Emission Inspection
Idle Emission Inspection
Infrared Hydrocarbon/Carbon Monoxide Instrument
(Simple meter readout with pass/fail lights)
$ 1,800
Loaded Vehicle Emission Inspection
Loaded constant speed modes (Key modes)
Simple instrumentation for HC/CO
Dynamometer with power absorption
*Ventilation and exhaust disposal unit
3,000
5,000
$ 4.000
$ 12,000
Constant speed Acceleration and Deceleration Modes
Simple instrumentation
Dynamometer with power absorption and inertia
weights (direct drive)
*Ventilation and exhaust disposal unit
3,000
21,000
4.000
$ 28,000
'$" 67,000
Fully automated system
Accurate instrumentation
" • ~~- - v r
Automatic Data Treatment N
C\IS System
Dynamometer with power absorption and inertia weighty
*Ventilation and exhaust disposal unit
Repair Garage Instruments for Carbon Monoxide and Hydrocarbons $600 - $1,500
*The ventilation and exhaust disposal unit is considered optional. However,
since this unit protects inspectors and/or the general public from objects
that could be thrown by a dynamometer, the State may consider its use desirable.
'11-23
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Co^-.t of .•» State_ Opera ted Inspection Lane
^ablo 2-7 shows estirptes of the investment and annual operating
cosf> of State operated inspection lanes using the idle and Key
Mor> jnsrpctions. For both methods it was assumed thr-t processing
-- s^ ~--~—. _ _ . —=
/cf p-m'ssion data was semi-autor.nted/ It is seen that the equipment
^*f^*
\cor,t for thi* Key Mode" is about rouble that of the idle inspection wji
i the automated data handling is addojfl. Without the addition of this
featnrr, tlie cost is about seven-fold greater for the Key M0<:1e- Tnc
rrcc7oninant operating cost is labor which is seen to be the same for
both methods. Note, however, the distinctly higher capacity of
the idle inspection lane vhirh will lead to lower costs on a per
vnhicle tested basis.
Total Program Costs
Total costs for a State maintenance and inspection program would
also include costs for training, program planning, initial qualifi-
cation and rertification of the inspection facilities, maintenance
and depreciation of the facilities, and the overall program adminis-
tration and enforcement requirements.
-*n analysis of cost has been performed for the State of California
(4)
and can serve as a general guide. The total program costs are
summarized in Table 2-8. The testing capacity of the system is based
on a yearly inspection of a total population of ten million vehicles.
11-24
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Table 2-7
Inspection Station Cost Estimates
Cost Element Station Type
Idle Mode Key Mode
Investment Costs 1 lane 2 lane 1 lane 2 lane
Inspection Equipment* $11,200 $22,400 $20,000 $40,000
Administration 1,000 1,700 1,000 1,700
Site Acquisition >,
($2/sq. ft.) 14,380 20,000 21,800 3J©,220
Construction
($8/sq. ft.) 10,960 16,320 16,320 24,480
Total $37,540 $60,420 $59,120 $ 96,400
Operating Cost (1st year)
Personnel Salaries $22,000 $44,000 $22,000 $44,000
Supplies &
Maintenance 1,748 3,186 2,216 3,994
Total $23,748 $47,186 $24,216 $47,994
Annual Capacities of Inspection Lanes: Idle Mode - 32,000 vehicles/lane
Key Mode - 25,000 vehicles/lane
*The inspection equipment costs have been updated from th-e
original' reference to allow for higher cost of the absorption
dynamometer.
11-25
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Table 2-8
State of California
Total Program Costs*
(Thousands of Dollars)
Cost Element Idle Mode Key Mode
Investment Costs
Site Acquisition & Construction 7,117 12,445
Equipment & Installation 4,090 6,270
Planning & Training 112 193
Qualification f* Certification 745 912
TOTAL 12,064 19,820
Operating Cost (1st year)
Salaries of Inspection Personnel 6,635 6,648
Salaries of Administrative
Personnel 631 981
Equipment Maintenance &
Depreciation 1,214 1,473
Facility Maintenance &
Depreciation 256 516
Program Administrative Costs 1.243 1,301
TOTAL 9,979 10,919
*Estimated for California vehicle population (10 million)
11-26
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Factors In Choosing An Inspection And Maintenance Strateqv
Three major alternate approaches to an inspection and maintenance
program have been considered. There are possible variations of
these programs and combinations of them that have not been
considered here. The EPA and industry sponsored APRAC CAPE-13
(3)
program explored a number of programs experimentally and developed
a cost/benefit analysis computer program which could he helpful in
deciding which program vas most suited to a given regional problem.
It is clear, however, from the material which has been presented
in this chapter that the emission inspection schemes are less costly
than pure engine parameter inspection or mandatory maintenance programs,
and appear equally effective in reducing emissions from the population
as a whole. The emission inspection gives the added satisfaction of
identifying the high emitters and concentrating the maintenance
action on them.
The chief problem with emission inspection procedures is that while
they identifv the high emitters, they do not specifically idertify the
cau^e of high emission values, ^his throws a substantial burden on
the repair mechanic who at present is not trained in identifying and
correcting the malfunctions or maladjustments leading to high emission.
In fact, extensive studies have shown that mechanics are onlycbout
(3)
50 percent effective in diagnosing and correctino emission problems.
(4)
Furthermore, they often over repair and adjust in their efforts.
How severe this probler may be will not be knotvn with certainty
until enission inspection is fully implemented in the field. Clearly,
where the emission inspection program is adopted, consideration needs
to be given to proper training of mechanics and providing them with
diagnostic information whore feasible.
11-27
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fjome States have been considering providing training for
inspectors and mechanics through conmunity colleges. The automobile-
;ind oil coir-panics are aware of the problem and arc beginning to provide
training to dealer garaacs and service stations.
The loaded mode emission tost does provide limited diagnostic
information. However this benefit needs to be balanced in a
specific situation against the added complexity and cost over ar idle
inspection test. It nay also be true that vehicles failing a simple
idle test ray ho brought back into compliance more easily. Certainly
the mechanic would he greatly aided, by the use of low cost CO/IIC
instruments which would allow him to directly verify the effect of
his corrective actions or. the idle emissions.
operational configuration is another major consideration. Will
State ovnesd or franchisee5 inspection lanes be used, or will the
inspection bo done in licensed, privately owned garages? The
decision, in many cases will already be made if the State has set up
n safety inspection program. In this case it would be a simplification
if tho inspection could be included in the sequence of safety tests.
new .Terscv, for example, has 38 State owned safety inspection stations
and ad dec1 its idle emission test at the beginning of the lane.
Pennsylvania, on the other hand, employs licensed, privately owned
garages for its safety program. Should it deride on an idle emission]
"inspection it would appear reasonable to add the test to the safety '
inspection tests now performed in the licensed
should the State decide on a more elaborate loaded mode test, it
would be necessary to construct State owned or franchised lane Gw&vlfr^
, l 1 -/ -
systems olaced strategically around the State. *-"H.'T
11-28
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REFERENCES
1. Cline, E.L. and Tinkham L.., "A Realistic Vehicle Emission
Inspection System," Clayton Manufacturing Company, Air Pollution Control
Association Paper No. 68-152.
2. Elston, J. C., Andreatch, A. J. and Mislosk, L. J., "Reduction
of Exhaust Pollutants through Automotive Inspection Requirements--The New
Jersey REPAIR Project," International Clean Air Conference on Air Pollution,
Washington, D. C., February 1971.
3. TRW Systems Group, "The Economic Effectiveness of Mandatory
Engine Maintenance for Reducing Vehicle Exhaust Emissions," APRAC Project
Number CAPE-13, Coordinating Research Council, 30 Rockefeller Plaza, New
York, New York, Final Report, July 1972.
4. "Control Strategies for In-Use Vehicles," U. S. Environmental
Protection Agency, MSAPC, November 1972.
11-29
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CHAPTER III
LEGAL AUTHORITY
The 1970 amendments to the Clean Air Act give EPA the necessary
legal authority for carrying out pollution abatement at the Federal
level. EPA has direct authority to set automobile emission standards
and require automobile manufacturers to meet these standards. Thus,
Federal authority preempts all other state and local authority with regard
to "new car" emission levels. However, this preemption may be waived by
the Administrator, after notice and opportunity for public hearing, for
any State which has adopted emission standards (cbher than crankcase
standards) for new motor vehicles prior to March 30, 1966, unless the
State does not require emission standards more stringent than Federal
standards.^ The Clean Air Act intended that other transportation controls
be implemented, monitored, and enforced by state agencies. However, if
a state fails to provide the transportation controls that are considered
necessary for achieving air quality standards, EPA has the authority to
require a state to provide such transportation controls. Here again, the
responsibility for implementing, monitoring, and enforcing transportation
controls would be placed on the state, and the state must have or obtain the
necessary legal authority to comply.
The legal authority for an inspection and maintenance program should
be held by the state for best results, especially if the program encompasses
a large number of vehicles spread over a wide geographical area. The
training requirements, administrative and enforcement procedures, and the
financial requirements for facilities, equipment, and salaries are normally
III-l
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such that in most cases local agencies may hesitate to implement an
inspection and maintenance program unless a substantial number of
vehicles would be covered by the program. Some local agencies such as
those in Chicago, New York, and Washington, D. C. are planning inspection
and maintenance programs. In these cities, large numbers of vehicles
in relatively small geographical areas will be subject to inspection and
maintenance.
Although the state agency may have the responsibility for carrying
out an inspection and maintenance program, the state may authorize local
agencies to carry out certain portions of the program such as testing,
compliance certification, performing maintenance, and enforcement. But
this does not relieve the primary agency of the ultimate responsibility
for the program's operation. The state may also delegate authority for
certain portions of a program by licensing private businesses. The state
agency would, in all likelihood, want to establish certification, licensing,
and bonding of private repair facilities if they are involved in the in-
spection and maintenance program. This would ensure that sufficient equip-
ment, qualified personnel, and adequate facilities were available for
operating the program.
Effective control of an inspection and maintenance program requires
adequate legal authority under which enforcement actions can be effected.
The legal authority may be divided into two major parts, state enabling
legislation and the rules and regulations of the individual air pollution
control agencies within any state.
III-2
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State Enabling Legislation
Sound enabling legislation at the state level is an essential pre-
requisite in establishing the legal and administrative framework necessary
to organize, staff and fund, provide procedures for the passage of rules
and regulations, and to authorize enforcement actions. Imperfections in
any enabling provision may cause delays and even failures in implementing
a control program. Enabling legislation which identifies specific
authority to be exercised by the agency responsible for the inspection
and maintenance program will be more likely to withstand challenges in court,
Some essential provisions include:
1. Adequate authority to adopt rules and regulations concerning:
a. Requirements for periodic inspection (should specify the
type of inspection such as emission, parameter, etc.).
b. Establishment of fees for providing the inspection service.
c. Withholding vehicle registration for those vehicles which
do not satisfactorily complete the inspection, or which do not comply
with an applicable variance.
d. Prohibition of tampering.
2. Provisions for providing adequate funds for implementing, moni-
toring, and enforcing the inspection and maintenance program, if allowed
by the State's constitution.
3. Adequate authority to obtain pertinent data and information,
and require periodic reporting of emission information.
4. Authority to make emission reports and information available
for public inspection.
5. Authority to compel compliance with rules and regulations
III-3
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supported by civil or criminal penalties.
6. Provisions for injunctive relief where deemed necessary.
Rules and Regulations
Regulations which specifically limit emissions of pollutants to
the atmosphere are of paramount concern in an inspection and maintenance
program. The nature and extent of emission control regulations are
primarily determined by the air quality problem. The preparation and
application of emission regulations requires knowledge of the polluting
characteristics of motor vehicles, and the type of program to be imple-
mented. This is especially important in documenting violations by
the enforcement personnel for the purpose of legal actions. Inadequate
understanding in concepts and applications can result in the loss of
court decisions, thus weakening the entire enforcement operation. Rules
and regulations are generally comprised of the following:
1. Test Procedures: These regulations specify the type of test to
be required, i.e., idle, loaded, parameter, and how often vehicle owners
or operators must submit their vehicles for inspection. Additional test
procedure requirements are also desirable.
a. Idle - procedures could include the type of measurement equip-
ment to be used and the engine revolutions per minute (rmp) at which
vehicles would be tested.
b.. Loaded - procedures for this type inspection are more complex
than for an idle inspection and thus, would require more information.
An agency could include such information as the modes through which
vehicles will be operated, stabilization time for each mode if required,
appropriate equipment operation, and emission measurement procedures.
III-4
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c. Parameter - procedures could include the particular engine
parameters that would require testing and the criteria for determining
the need for maintenance or component replacement.
2. Emission Limitations: These establish the rate of emission
above which a violation or test failure occurs. There may be one emission
limit applicable to all vehicles subject to the prokjram, or several
limits based on vehicle age.
3. Equipment Design Standards: These are a class of regulations
which specify permissible features, specifications, or standards relating
to the design of equipment or the prescribed use of equipment. The
necessity for these type regulations is more prevalent for an inspection
and maintenance program in which private businesses participate in the
inspection and/or maintenance operation.
III-5
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4. Prohibition of Use or Operation: This type of regulation pro-
hibits the use or operation of motor vehicles which have emission rates
in excess of the standards. Upon failure of a vehicle to meet the standard,
the owner or operator of the vehicle is usually allowed some period of
time in which to bring the vehicle in to compliance. There is usually a
requirement for a retest of failed vehicles or certification to be pro-
duced by the owner/operator that proper corrective maintenance has been
performed on his vehicle.
5. Vehicle Registration: This type of regulation prohibits the
registration of vehicles which fail to comply with applicable emission
limits or a variance.
6. Inspection Fees: A State would normally desire to establish an
inspection fee which would cover the cost of performing inspections,
whether or not inspections are performed by the State, or licensed private
businesses.
7. Variance: It may occur that some motor vehicles cannot be brought
into compliance with emission standards. This may be caused by peculiar
engine design or operating characteristics. In these cases, the air
pollution control agency may wish to exempt such vehicles from the require-
ment to comply with the emission standards. An automatic exemption may
be included for antique and/or classic vehicles.
8. Tampering: To be effective, emission control devices must be
in good working order. A regulation to prevent intentional tampering
or adjustments to devices or components required by Federal or State law
may be desirable. Appropriate penalties should be included in the regu-
III-6
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lation for discouraging such tampering.
9. Powers: These are a group of supporting regulations enacted
to establish right of entry, police powers, and requirements for
submission of information on pollutant emissions.
III-7
-------
References
1. National Emission Standards Act, Part A, Section 209, Environmental
Protection Agency, Washington, D. C., December 1970.
III-8
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CHAPTER IV. IMPLEMENTATION
Agencies Involved
The purpose of this section is to discuss the area of interagency
relationships as it applies to implementation of an inspection and
maintenance program. Several types of agency relationships that already
exist or are likely to exist are presented and the benefits and problems
of each type discussed.
The reason that interagency relations are important is that develop-
ment and implementation of an inspection and maintenance program includes
a broad range of activities such as development of program procedures,
equipment, procurement, vehicle inspection, enforcement, training of
inspectors and mechanics, monitoring results, and handling consumer
complaints or problems. Usually one agency does not have the resources
or authority to carry out all these tasks without the cooperation or
assistance of other agencies. Therefore, it is important to have good
working relations among all the agencies involved.
The legislation authorizing the inspection and maintenance program
is an important factor in determining which agencies are involved. In
some cases one agency is given total responsibility. It is then up to
that agency to obtain cooperation and assistance from other agencies as
necessary during development, implementation, and monitoring of the
inspection and maintenance program. In other cases the legislation
specified several agencies and the particular area of responsibility
IV-1
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of each agency. The particular agencies specified in the legislation are
determined by factors such as the existence of a State vehicle safety
inspection program, current structure of governmental agencies, and the
legislators' ideas of the most workable arrangement.
Several examples of existing inspection and maintenance programs
will help illustrate which agencies can be involved and how these
agencies relate to each other in the area of inspection and maintenance.
The first example is the program in New Jersey which involves the fol-
lowing four agencies:
' The Department of Environmental Protection
• The Division of Motor Vehicles
• The Department of Educations
• The Office of Consumer Affairs
Mew Jersey had an existing State vehicle safety inspection program
administered by the Division of Motor Vehicles to which the emission
inspection could easily be added. Therefore, the legislation authorizing
the inspection and maintenance program called for the Division of Motor
Vehicles to work with the Department of Environmental Protection. The
Department of Environmental Protection had the responsibility to develop
the inspection and maintenance program, provide technical assistance,
and monitor the results. The Department of Motor Vehicles does the
actual inspection and handles enforcement through the vehicle registration
procedure. Two other State agencies are becoming involved in certain
aspects of the inspection and maintenance program. The Department of
IV-2
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Environmental Protection is working with the Department of Education
to investigate ways to train mechanics in the auto service industry
to repair autos that have failed the emission inspection. The Office
of Consumer Affairs has become involved in investigating cases where
consumers have problems getting their vehicles repaired properly.
This type of interaction can present both problems and benefits.
One advantage is that the resources and experience of several agencies
can be brought to bear on the new program. Hopefully this will allow
the various parts of the program to be carried out in an expeditious
manner since each part is being handled by the most experienced agency.
On the other hand, more coordination and cooperation are required by the
primary agency to see that all parts of the program are properly carried
out.
Many of the States which will require inspection and maintenance
programs have existing vehicle safety inspection programs. In most cases
the agency currently responsible for the safety inspection will also be
involved to some extent with the inspection and maintenance program.
The particular agency responsible for the safety inspection varies con-
siderably between States. Some examples include the Registrar of Motor
Vehicles in Massachusetts, the Secretary of Revenue in Pennsylvania, the
Administrator of the Vehicle Inspection Department in Indiana, and the
Superintendent of the State Highway Patrol in Ohio.
An example of a local inspection and maintenance program in an
area which requires a safety inspection of commercial vehicles only is
IV-3
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the City of Chicago. A City ordinance authorizes the Department of
Environmental Control to carry out the inspection and maintenance
program. The Department of Environmental Control handles the entire
program including technical development and vehicle inspection. In
the future the Department of Environmental Contrbl may become involved
in garage certification.
In California the Bureau of Automotive Repair in the Department of
Consumer Affairs has the responsibility of regulating all auto repair
garages. Beginning in January 1974 the Bureau of Automotive Repair was
given the responsibility to develop an inspection and maintenance program
for southern California including technical development, inspection, and
certification of repair garages. An idle mode test was incorporated
into the random spot safety inspection conducted by the Highway Patrol.
This random spot inspection is expected to be converted to a lane type
inspection.
The primary advantage of having all responsibility in one agency is
that the overall program can be controlled by one agency. Presumably,
this would allow for tighter managerial control of the program. However,
one disadvantage is that expertise must be developed in several areas
which are somewhat unrelated to the primary objective of reducing
emissions from vehicles.
In all cases the agency with primary responsibility for the inspection
and maintenance program must see that all aspects of the program including
technical development, inspection, enforcement, monitoring, auto
IV-4
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maintenance, inspector and mechanic training, public relations, and
consumer protection are developed. In addition contact should be
maintained with the Environmental Protection Agency through the
appropriate Regional Offices (see Appendix A).
Implementation Schedule
In this section the factors leading to implementation and their
timing will be discussed. Generalized implementation schedules will
be presented as models and the assumptions explained. The models
illustrate the required steps and their time dependence. The variables
affecting the implementation schedule and how these variables may differ
between States will be discussed. Examples from State agency experience
will be used to illustrate certain points.
The bar charts (Figures 1 and 2) show the estimated time period for
implementation of inspection and maintenance programs. Figure 1 is for
a State owned program with either an idle or loaded mode inspection.
Figure 2 is for an idle inspection at licensed garages. The estimated
time required for a State owned program is 26 months for an idle test and
29 months for a loaded mode test. For a State licensed idle test program
the time required is about 26 months. These time estimates include the
IV-5
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first year cycle necessary to phase in the program to cover the vehicle
population.
Some of the assumptions made to construct these model implementation
schedules should be pointed out. The first assumption which can be seen
from the charts is that the lead time begins at the point in time when
both legal authority and funding arrangements exist. The time required
to obtain legal authority and to make the necessary funding arrangements
can be a critical factor in the total time required for implementation.
In some cases it may be possible to begin the planning, the pilot program,
and parts of the training program before legal authority has been granted.
The problem of obtaining legal authority and adequate funding will be
discussed further in Chapter IV, Part 5. A second assumption is that no
facilities or pilot programs are available to build on. In some cases
the inspection and maintenance programs may be incorporated into existing
safety inspection stations. This would reduce the time required for
the facilities acquisition step. -An existing, pilot plant program
could reduce the time required to evaluate and select test equipment
and procedures. In addition, the staff would have some
experience that would speed development of the program. Another assumption
made in developing the model implementation schedules is that only an^idle
test program would be considered for States with State licensed garages.
It is unlikely that an adequate number of private garages would invest in
the more expensive testing equipment necessary for a loaded mode emission
inspection under a State licensed program, if such a program is used, the
IV-8
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time required for implementation would be longer than shown in the model.
For each specific case there will probably be factors that will in-
crease or decrease the lead time from that shown in the models. Some of
these have been pointed out in the above discussion of assumptions.
Additional factors and problems actually encountered by State agencies
will be presented below.
The current status of a State safety program can have an effect on
the time required to implement and inspection and maintenance program.
For example, a planned State owned program could be implemented faster
in a State with an existing State owned safety program since the existing
stations could be expanded to incorporate the emission testing. Likewise
a State licensed inspection and maintenance program could be implemented
faster in a State with an existing State licensed safety program.
The experience of State or local agencies which have begun inspection
and maintenance programs supports the estimates shown in Figure 1 and 2.
Since each program went through a somewhat different development process,
IV-9
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the exact timing of the various parts of the program differ. However,
in general they support the time period shown in the charts. The primary
comments relating to lead time include the following:
1. Obtaining legal authority can be a long drawn out process and
thus a major time delay.
2. In some States locating sites for State owned facilities can
cause time delays because of land procurement procedures.
3. In order to assure smooth implementation, considerable effort
must be made to maintain interagency cooperation in cases where
more than one agency has responsibility for parts of the
inspection and maintenance program.
FEDERAL ASSISTANCE
The EPA is committed to assisting air pollution control agencies in
various ways. Technical assistance in developing implementation plans
has been provided to many States in the past several years and will
continue through EPA's Regional Offices. States have also received
financial assistance through the grants program. Technical and financial
assistance relating specifically to inspection and maintenance programs
are discussed in more detail in the following pages.
Technical Assistance
Federal technical assistance for inspection and maintenance programs
through EPA will be available in several forms. The appropriate channel
for obtaining technical information or assistance in the area of inspection
IV-10
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and maintenance is through the EPA Regional Offices Csee Appendix A).
The various forms of technical support that are planned at this time
are itemized and discussed below.
1. A periodic newsletter will be published to report on recent in-
spection and maintenance developments in State or local agency
experience, EPA demonstration contracts, and other studies.
The main points of information will be discussed in the newsletter
with references given for those interested in a more detailed dis-
cussion on the subject. The newsletter will serve as an outlet
for information on other automobile related subjects such as
retrofit devices, engine tampering, and fuel economy. The first
issue should be available by June 1974.
2. The Emission Control Technology Division is evaluating objec-
tives for an inspection and maintenance evaluation program.
By requiring mandatory maintenance for those vehicles which
have emissions higher than allowable, inspection and mainte-
nance effectiveness can be determined, the service industry's
capability to handle the required maintenance can be evaluated,
maintenance costs can be determined, and public reaction to
inspection and maintenance can be sampled. While these data
are very important, the success of the evaluation program will
depend on the willingness of State agencies to operate an
inspection and maintenance program according to the program
requi rements.
IV-11
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3. Planning is underway for a seminar sponsored by EPA for State
and local officials on the subject of inspection and maintenance
programs. The seminar will provide a forum for EPA to dispense
recent information and for State and local officials to share
their experience and information.
4. The document "Control Strategies for In-Use Vehicles" will be
reissued with more emphasis on aspects of implementation and with
recently developed information not contained in the first edition.
The new information will include a discussion of an evaluation
procedure for retrofit devices, high altitude emission inspection,
and State agency experience with specific problems encountered in
implementing their inspection and maintenance programs.
5. A team of EPA technical experts will be available to handle re-
quests for information or assistance on technical matters relating
to inspection and maintenance. The kind of assistance that this
team of experts could provide would include technical review of
State inspection and'maintenance plans, recommendations on instru-
mentation and other testing equipment, assistance in mechanic
training programs, testimony on technical questions at public
hearings, and on-site visits to evaluate technical problems
with the inspection and maintenance program. Requests for
technical assistance should go through the EPA Regional Offices.
6. Several specific reports and studies related to inspection and
IV-12
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maintenance are discussed in Chapter VI.
Funding Assistance
Acquiring adequate funding is an important factor in the develop-
ment of an inspection and maintenance program. Funding an inspection and
maintenance program is basically the responsibility of the State, and/or
local agencies.
In general funds are required for two purposes; (1) to provide
capital to start up the program, and (2) to operate and maintain the pro-
gram once it has been started. The amount of the first item will depend
on three factors; (1) the type of program (State owned lanes or State
licensed garages), (2) the type of emissions test (idle or loaded mode) and
(3) whether the emissions test is added to an existing safety inspection
or set up independently. The initial capital can be acquired through
several mechanisms such as issuing bonds or borrowing from the State's
general fund. In any case an inspection fee can be charged to cover both
the operating and maintenance costs and to pay off the initial investment.
Oregon's system is an example of this method of financing, that is, borrow-
ing the initial capital from the State's general fund and setting the in-
spection fee at a level to cover the operating costs and to pay back the
initial capital.
The additional cost an air pollution control agency will incur when
setting up an inspection and maintenance program may be included in
the agency's operating budget. As
IV-13
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part of the agency budget the inspection and maintenance program costs
would be eligible for matching funds through EPA's grant program to
support air pollution control agencies. However, since EPA's agency grant
funds are not expected to increase, this funding mechanism will not be able
to provide substantial support. Further information concerning program
grants can be obtained from the EPA Regional Offices.
As mentioned in the following section on training, Federal funds can
be obtained for inspector and/or mechanic training. The EPA Regional Offices
have available some Manpower Development and Training Act (MDTA) funds for
training of technician level people. Several State and local agencies in
Colorado, Oregon, and Texas have already used or proposed to use
this mechanism to obtain funds for training of inspectors and/or mechanics
necessary to carry out the inspection and maintenance programs. Interested
agencies should contact the manpower development officer in their EPA
Regional Office.
Training
An adequate supply of trained inspectors and maintenance mechanics is
necessary in order to successfully implement an inspection and maintenance
program. This section will examine the importance of inspector and mechanic
training, the steps that the primary inspection and maintenance agency
should take to assure a supply of trained personnel,and some examples of
what is being done in the area of inspector and mechanic training.
IV-14
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Trained inspectors must be available before the program can become
operational, and trained mechanics are required to properly repair the
rejected vehicles. The kind of training and magnitude of the training
program required would depend on whether the inspection and maintenance
system is State owned or Stated licensed, and whether an idle or loaded
mode inspection test is used. In State owned systems the inspection
function is separate from the maintenance function which allows separate
training programs to be developed. Generally the professional staff
together with the instrument vendors can put together the necessary
training program for inspectors. The training program for a loaded
mode test would be more extensive than the training program for an
idle test, but both of the training programs for inspectors are rela-
tively simple. The main objective is to train the inspectors to
operate and maintain the Instruments, perform the test, and make the
proper record of the test results. The main factor determining the
magnitude of the inspector training program will be the size of
inspection and maintenance program. For example, New Jersey has about 69
inspection lanes with one emission inspector per lane. Other States with
a larger number of lanes will require a substantial number of inspectors.
IV-15
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For example, Arizona's proposed plan calls for 511 employees most of
whom are inspectors.
In a State licensed system the personnel at each station should be
capable of performing both the inspection and the maintenance functions.
Therefore, the training program should be directed towards the maintenance
function as well as the inspection function. The degree to which the
inspection and maintenance agency can become involved in training of
mechanics under either type of inspection and maintenance system will
depend on several factors including legal authority, personnel and funding
capabilities, the level of expertise in the local auto service industry,
and their initiative.
The agency responsible for the inspection and maintenance program
should decide early in the planning process the role it will have in the
training program. In some States an agency, other than the implementing
agency, may be better equipped to handle the training program, for example,
the Department of Education. The particular legislation under which the
agency operates may specify the agency's role in the training process.
Another factor to consider is the level of expertise in the local auto
service industry and the existence of private education program.
Several oil companies have training courses for their dealers. Garages
may decide to prepare themselves for future inspection and maintenance
business by obtaining the necessary training for their employees.
In any case the primary inspection and maintenance agency should assess
the need for mechanic training and take whatever measures are necessary
to prepare the auto service industry for handling emission repairs.
IV-16
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EPA is involved in two aspects of the mechanic training area which
can be useful to the State or local agencies responsible for inspection
and maintenance programs. One is In providing Manpower Development and
Training Act funds for inspector and for mechanic training. Several States
are using or plan to use the funds to set up training programs in their
States. The Denver, Colorado program i£jm_ example of this type of program.
A contract was awarded to Colorado State University to develop a training
program and to train 60 persons. This training program is directed at
training auto mechanic instructors and teachers who will then go back to
their technical institutes, junior colleges, or other place of employment
to teach the working level mechanics. The multiplier effect of this method
will help spread the knowledge faster than training the working level
mechanics directly. A similar training grant for certified auto teachers
has been awarded to the University to expand the training program started
under the first contract. EPA expects to gain training materials and
methods from the work carried out under these contracts. These materials
and methods can then be made available to others as training packages.
Agencies interested in using Manpower Development and Training Act funds
for mechanic training programs should contact the manpower officer in
their EPA Regional Office.
The Control Programs Development Division of EPA in Durham, N. C. is
currently working on projects to develop training programs for inspectors
IV-17
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and mechanics. One program with materials has been devleoped and will be
tested in the Denver mechanics training program mentioned above. Once
the materials and methods are tested and approved, the training package
will be available for others. Further study is being given to the need
for developing other training packages for people involved with Inspection
and maintenance at other levels such as supervisors.
Because of the importance of having well trained inspectors and
mechanics on the outcome of any inspection and maintenance program, the
primary agency should assess the training needs for its program and make
sure that the necessary training is provided. Who runs the training pro-
gram and how extensive it is will depend on the factors discussed above.
The primary agency will ultimately be responsible for the success of the
inspection and maintenance program, and therefore should make a special
effort to develop adequate training for inspectors and mechanics.
IV-18
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Potential Problems Associated with Inspection/
Maintenance Programs
A variety of approaches can be followed in implementing an inspection/
maintenance program. The program can be state owned and operated or
licensed to private garages; the inspection can be made while the
vehicle is at idle or under"simulated driving conditions; annual or semi-
annual inspections can be required, etc. With all of these approaches,
implementing an automobile inspection/maintenance program may result in
a number of problems which should be considered early in the planning
process of such a program. These problems fall into the following general
areas:
1. Legislative or statutory requirements
2. Organizational impediments
3. Funding or budgetary restrictions
4. Labor supply or skill shortages
5. Lack of public support
6. Lack of data
7. Equipment and facility procurement
8. Determination of Rejection Rate
9. Certification of mechanics
The discussion to follow will provide an explanation of some of the specific
problems associated with implementing inspection/maintenance program.
LEGISLATIVE OR STATUTORY REQUIREMENTS
The implementation of an inspection/maintenance program requires
statutory authority for its development and operation. Acquiring this
IV-19
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authority necessitates formal approval by the State Legislature for a
State opeEated program. This is not necessarily true for a program
established by a local agency. In many instances this approval is given
in two phases - the first phase being for a pilot or demonstration, the
latter for the actual program to be implemeneted. As an example, in
Colorado, the legal authority for a pilot program was already included
as a part of the Colorado Clean Air Act; once the results of the pilot
are available, the necessary legal authority for the implementation of
mandatory inspection and maintenance must be acquired. In Arizona, the
State Legislature approved in 1972 the construction and operation of a
prototype inspection facility; a report containing emission test data,
inspection station network studies, and specific recommendations regarding
how a statewide mandatory inspection system should be implemented has
been completed and will go to the State Legislature in 1974. In many
cases the State legislative body has only minimal technical knowledge
and little understanding of the actual requirements necessary for attain-
ing the air quality standards. The purpose of the transportation plan
in helping attain these standards and the necessity for implementing an
I/M program must be appropriately presented to the legislators so that
their approval will be forthcoming. Adequate agency preparation may
require many months of work to construct a logical, understandable proposal
Getting the necessary statutory authority can be a time consuming
task in implementing an I/M program. This situation necessitates early
IV-20
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action on legislative approval. However, States may be able to use
an EPA promulgated inspection and maintenance requirement as the
authority to act in implementing a program and thus, avoid time
del ays.
ORGANIZATIONAL IMPEDIMENTS
As was discussed earlier, the implementation of an inspection and
maintenance program may involve several State or local agencies. Cooperation
between these agencies is essential if the program is to operate successfully.
Having specific agency responsibilities delineated in the legislative
authority will aid in avoiding controversy over assignment of duties and
enforcement of the program.
FUNDING OR BUDGETARY RESTRAINTS
Once the legal authority for establishing a mandatory inspection and
maintenance program is acquired, an additional task which may pose problems
remains before actually implementing the program. This task consists of
getting adequate funding to operate the program. In many States, convincing
the legislature to fund such a program requires more effort and time than
getting the legal authrotiy. State legislators may be reluctant to fund
such a program in one area of the State, or the State may not feel adequate
funds are available for such a program. Time delays of a year or more
may be experienced in getting necessary appropriations, which would extend
the start-up date of the program. If funding provisions are included in
IV-21
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the enabling legislation, such as that suggested in Chapter IHi significant
delays can be avoided.
Location of Federal sources of funding (discussed earlier) may ease
this problem somewhat. Although some Federal funding may be available,
it is the responsibility of the State to provide the funds necessary to
implement an inspection/maintenance program.
LABOR SUPPLY OR SKILL SHORTAGES
The successful implementation of an inspection/maintenance program
requires sufficient qualified staff to operate all phases of the program.
Due to the procedure for hiring personnel utilized by many state and local
government agencies, the hiring of competent staff to aid in implementing
an inspection/maintenance program may pose problems. In many cases, finding
the qualified personnel is simple, but getting them on the job may take
three to twelve months due to local government hiring mechanisms. In a
state operated inspection program, both inspectors to actually perform the
inspection and qualified staff to calibrate the equipment and verify the
accuracy of the inspection results must be employed. In Arizona, approximately
500 people must be employed to operate the state inspection/maintenance
program being considered.
In the case of state operated inspection programs individuals with
general skills may be hired as inspectors and trained to perform the in-
spections. Also under a state operated inspection/maintenance program,
the mechanics in the individual garages who perform the required maintenance
will require some training in repairing or tuning engines to achieve
IV-Z2
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emission reductions; the development of diagnostic skills in correcting
emission deficiencies is also essential for accurate, cost effective
repairs. Development of training programs for these mechanics and for
the inspectors should be considered an integral part of the inspection/
maintenance planning process and should be included as a necessary step
in implementation of the program.
In a licensed inspection/maintenance program, the training of
mechanics and inspectors to administer the inspection and perform necessary
maintenance is equally as important as in a state system. This training
of mechanics may lead to a certification program for mechanics who complete
a specific amount of training for correcting automotive emission problems.
Currently in Colorado, where a licensed system is being considered, the
EPA is funding a pilot program for the training of mechanics in both
diagnosing emission problems and making corrective adjustments.
In some instances, getting legislative approval and funding for training
mechanics and inspectors has posed problems. It becomes apparent, however,
that lack of trained staff could bring an inspection/maintenance program
to a standstill or lead to adverse public reaction. The overall effectiveness
of such a program hinges on the ability of those operating the system to
complete the inspections accurately and to perform the maintenance adequately
and efficiently. Therefore, training of mechanics and inspectors and timely
hiring of personnel are essential in getting the inspection program underway.
LACK OF PUBLIC SUPPORT
Gaining public support for a motor vehicle inspection and maintenance
program may be one of the more difficult problems associated with implementing
IV-23
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such a program. In areas where the public is in favor of an I/M program,
legislative approval is much easier to acquire. For example, in Arizona,
the Speaker of the House has been strongly in favor of the I/M program for
Phoenix-Tucson; he has ellicited great public support for this measure. As
a result, the measure will in all likelihood gain legislative approval this
year. A public information program is under consideration in Colorado to
get the public acquainted with the inspection/maintenance program.
One of the prime reasons for the public concern stems from the fact
that individuals fear being overcharged for mandatory maintenance or paying
excessive fees for simple tune-up functions. To prevent these events from
occurring, some States are attempting to develop detailed diagnostic
techniques for use by mechanics in detecting deficiencies. For example
in Arizona an innovative diagnostic tool may be employed. If an auto fails
the motor vehicle inspection, the driver may take the car to another lane
where an electronic device will identify where his problem lies, the driver
then goes to his garage and has the specific deficiency corrected. Other
States are setting up a detailed checklist of items which may cause specific
deficiencies so that diagnosis of problems can be handled more efficiently.
Proper training of mechanics will also aid in avoiding unnecessary maintenance
work.
As an added preventive measure, the public should have some simple means
to make complaints regarding the inspection he undergoes or the maintenance
he has performed in a garage. A "hot line" for making complaints or suggestions
or a return card to report problems would provide the individual with a
readily available means of making known to the proper agency officials
IV-24
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his specific situation. The New Jersey Department of Environmental
Protection is considering a similar means of monitoring complaints.
LACK OF DATA REGARDING INSPECTION/MAINTENANCE PROGRAMS
Another area of concern in establishing an inspection/maintenance
program is the gathering of adequate data upon which to base a decision
relative to the type of program to implement and the emission reduction
to be achieved. All of the data currently available on pilot projects
or research studies in this area were obtained from tests on automobiles.
The data are not directly applicable to medium-duty vehicles, heavy-duty
vehicles, diesels, turbines or light-duty trucks. Furthermore, most of
the vehicles used in the completed studies have been pre-1970 vehicles and
none have been equipped with advanced control systems which will be a
major factor in the total mobile source pollution levels at the time that
the inspection/maintenance programs are expected to be implemented.
Some areas are undertaking pilot or demonstration inspection/maintenance
programs on a small scale to provide actual data for decision making relative
to the type of inspection to utilize, the operation and enforcement of the
program, the kind of results to expect, and the costs. Some States may
be hesitant to undertake an inspection and maintenance program without
much more background data than is now available. Nevertheless, States
must gather what information is available and proceed with implementation
in order to meet compliance dates.
IV-25
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One specific area where lack of data is posing a problem is in
determining the rate of deterioration of the vehicle to before-maintenance
emission levels. The emission reductions attributed to inspection/
maintenance are those recorded immediately after the vehicle maintenance
phase of such a program. If the vehicles are allowed to deteriorate to
their pre-tuned emissions level before they are re-inspected and re-tuned,
the time averaged emissions will be considerably less than those measured
initially. Since definitive data on the shape and period of the deterioration
curve is not available, a straight line deterioration to the pre-tuned
condition in one year has been used for estimating purposes. This approach
was used in Appendix N of the Requirements for Preparation, Adoption and
Submittal of Implementation Plans (40 CFR 51). The result of this assump-
tion is that the time-averaged emissions reductions are one half of the
initial reductions achieved. Actual test data will be necessary to determine
what actual average deterioration rates will be.
EQUIPMENT AND FACILITY PROCUREMENT
Procurement of emission inspection equipment may pose some problem in
implementing an inspection/maintenance program due to the purchasing pro-
cedures employed in State and local government agencies. At present, there
appears to be no problem regarding adequate supply of the necessary testing^
equipment from the various manufacturers. The problem maCjTdesirejas a result
of lengthy procurement process encountered in many state an'd"Tbcal agencies.
IV-26
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For example, the State of Arizona estimates it will require 12 months
to procure the necessary equipment for the inspection phase of the state-
owned program. Much of this time is required to process the orders for
the equipment.
In the case of testing facilities, a franchise inspection/maintenance
system presents no problem as individual garages will be inspected and
approved to administer the inspection. No serious facility problems are
anticipated in States where, the emission inspection is to be completed
in parallel with a State operated inspection program. If new facilities
must be purchased and constructed for the inspection/maintenance program,
considerable time must be allowed in the State's plan to allow for acquiring
sites, designing inspection stations, construction of stations, etc. This
may pose a serious time delay.
DETERMINATION OF REJECTION RATE
The potential for initial emission reductions as a result of an
inspection/maintenance program will depend upon the accuracy of the
inspection procedure and the level at which emission standards are set.
The level of the emission standards determines what the inspection
rejection rate will be. This rejection rate may pose problems if it is
extremely high as large numbers of vehicles are likely to fail. This
may lead to adverse public reaction. Of course, the more stringent the
emission standards and the higher the rejection rate, the greater the
emission reduction allowed for this strategy will be.
IV-27
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One means of initially avoiding the problems of an extremely high
rejection rate is to set emission standards at a fairly high level for
the initial year and reduce the allowable emissions each year. In this
way, the more restrictive standards would be achieved over a period of
several years, but people would gradually become accustomed to the
corresponding higher rejection rates.
CERTIFICATION OF MECHANICS
If training of mechanics to corfcect emission deficiencies is provided
by a State or local agency as part of an inspection/maintenance program,
some consideration may be given to certification or licensing of these
mechanics. This would provide consumers with some assurance that the
mechanic has had adequate training to perform the maintenance required to
pass the vehicle inspection. In a state operated program, the mechanics
doing the necessary maintenance might receive a certification or license
if they complete the training being provided or pass a qualifying test.
In a licensed inspection/maintenance program, state certification
of the garage as having the necessary facilities and equipment to perform
emission inspections and required maintenance is essential. In addition,
assurance that the garage has the qualified staff to complete the inspections
and perform the maintenance must be provided. Certification of the
individual mechanics as being capable of performing emission repairs may
IV-28
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be a part of this assurance that the garage has qualified staff to
perform necessary inspection and maintenance.
The certification or licensing of mechanics participating in
inspection maintenance programs may pose potential problems with regard
to implementation and monitoring of the certification program. This
would require additional work on the part of the agency operating the
inspection/maintenance program. The certification might create an adverse
reaction among mechanics unless training could be provided on an equal
basis to all. The certification does, however, serve as a consumer protection
measure and provide the operating agency with a lever to insure that if
quality maintenance work is not done, certification will be revoked. The
type of certification or licensing procedure to be followed depends on
the specific inspection/maintenance program under consideration.
IV-29
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CHAPTER V
MONITORING AND REPORTING
Monitoring
Once an inspection and maintenance program has been implemented, it
is essential that the program be monitored and information reported to
Federal, State, and local agencies as appropriate. As noted in Chapter II,
emission reductions achieved through an inspection and maintenance program
can range up to 15 percent for hydrocarbons and up to 12 percent for carbon
monoxide, depending on the initial rejection rate, and the type of program
selected. I ^^rf^Dy|Depo§/s i bl e to detect thjfrse reductions through measurements
in air qualit^rjtfherefore, t& determine the effectiveness of a program and the
adequacy of operating and maintenance procedures, data must be collected
at the inspection station. The data collected should be sufficient, as a
minimum, to allow determination of the actual pass/reject rate and the
amount by which emissions are being reduced from the vehicle population.
Rejection Rate
The rejection rate can be easily determined. All that is required is
that the inspector be given a signal as to whether a vehicle's emissions
are above or below the established emission limitation. Such a signal is
normally designed into testing equipment, either through a dial indicator
which shows the actual pollutant concentration measured, or through a
simple lighting system which is triggered when the measured concentration
is either above or below the standard. Usually both such signal methods
are available on testing equipment, it will be necessary to record pass/
fail information for future analysis and reporting. This can easily be
done at the time the inspection takes place by having the inspector (or
V-l
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other appropriate person) record the desired information. Figures V-l
and V-2 provide an example of a format for recording pertinent vehicle
information. Of course, data collection forms can be designed for
recording the type and amount of data desired.
The rejection rate can provide very useful information. It can
indicate whether or not the operation of all inspection stations are
V-2
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FIGURE V-l
VEHICLE EMISSION INSPECTION - IDLE METHOD
VEHICLE INFORMATION
Year
Make
Model
No. of Cylinders_
Serial No.
Engine Displacement cubic inches
Carburetor:
Barrel, or Other
(F.I. Etc.)
Transmission: Automatic Manual No. of Shifts_
Date Odometer Reading
EMISSION INFORMATION
VEHICLE
YEAR
ALL
•
1967
AND
BEFORE
1968
AND
LATER
SUBJECT
ENGINE RFM
-CO-
CARBON MONOXIDE
-HC-
HYDROCARBONS
-CO-
CARBON MONOXIDE
-HC-
HYDROCARBONS
IDLE
Max. Mfrs. Specs + 100
Max. 9.0%
Max. 1200 PPM
Max. 7.0%
Max. 600 PPM
OPEN THROTTLE
2400 +.100
Max. 9.0%
Max. 1200 PPM
Max. 7.0%
Max. 600 PPM
V-3
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VEHICLE EMISSION INSPECTION - LOADED METHOD
VEHICLE INFORMATION
Year
Make
Model
No. of Cylinders
Serial No.
Engine Displacement cubic inches
Carburetor:
Barrel, or Other
(F.I. Etc.)
Transmission: Automatic Manual
Date Odometer Reading
No. of Shifts
EMISSION INFORMATION
VEHICLE
YEAR
1967
AMD
BEFORE
1968
AND
LATER
POLLUTANT
-rC-
CARBON MONOXIDE
-HC-
HYDROCARBONS
-CO-
CARBON MONOXIDE
-HC-
HYDROCARBONS
IDLE
Max. 9.0%
Max. 1200 PPM
Max. 7.0%
Max. 600 PPM
LOW CRUISE
Max. 5.5%
Max. 900 PPM
Max. 4.25%
Max. 450 PPM
HIGH CRUISE
Max. 4.5S
Max. 900 PPM
Max. 3.75%
Max. 450 PPM
V-4
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consistent. Too high or too low a rejection rate can mean that a station
is not following proper testing procedures, equipment is not functioning
properly, vehicles tested at a particular station are above or below
average emitters, or a combination of these causes. The first two of
these causes can be corrected through proper program management. The
third cause is an additional indicator itself.
If proper procedures are being followed and equipment is functioning
as it should, then a high or low rejection rate may reflect the adequacy
of maintenance being performed on the vehicles. This is especially true
when vehicles are retested after being rejected. The adequacy of main-
tenance can also be determined in other ways.
If rejected vehicles are required to undergo a retest before being
allowed to operate, the number of times a vehicle returns for retest will
indicate that corrective maintenance is either good or poor. A vehicle
owner who is required to have repeated maintenance on his vehicle will not
undergo the cost and inconvenience long before complaining to the testing
officials. If a high percentage of rejected vehicles pass on the first
retest, then this is an indication that corrective maintenance is being
properly diagnosed and performed. Regardless of whether the indication
is that maintenance is good or poor, the agency should investigate to
determine the cause. If maintenance is good, the diagnosis and treatment
methods used can be passed on to other maintenance facilities, incorporated
into a certification program, and/or used in mechanic training programs.
If the maintenance is poor, the agency will want to correct the situation,
for the maintenance function is critical to the success of the inspection
and maintenance program.
V-5
-------
Emission Reduction
The emission reduction from a vehicle population is the key indicator
that nn inspection and maintenance program is achieving the desired success
(see Figure V-l and V-2 for an example method of data collection). The
most accurate method of quantifying emission reductions is through surveil-
lance using the Federal test procedure. However, sufficient estimates of
emission reductions can be obtained by measuring pollutant concentrations
in exhaust gases using an idle mode or loaded test. An agency may wish
to record, summarize, and analyze pollutant concentrations from each vehicle
test. This procedure would provide the most accurate results. However,
if an agency lacks sufficient manpower or data processing facilities, a
portion of the vehicle population can be sampled at various intervals to
provide sufficiently accurate estimates of emission reductions. Of course,
the accuracy of these data will be affected by the size of the sample, and
its representativeness of the population, and the type of emission test
conducted (idle mode tests provide the least accurate results). Proper
statistical procedures should be used to determine the sample size and
vehicle mix (age and weight class) of the sample. New Jersey is instituting
such a monitoring system for their idle inspection and maintenance program.
A surveillance team is maintained in the field to visit each inspec-
tion station once a month. During these visits, testing equipment is
calibrated, and for a period of two hours, concentrations of carbon monoxide
and hydrocarbons from a sample of from 50 to 60 vehicles are recorded. The
vehicle year, make, and model, any test problems encountered, and whether
a vehicle is being retested are also recorded. Data on about 2,500
vehicles are obtained per quarter. A computer program provides a distri-
bution of pollutant concentration by vehicle age, weight class, and by
make and model. Rejection rates are also computed. Through study of
V-6
-------
these data, trends can be observed and the overall effectiveness of
the program determined.
State Operated vs. State Licensed Programs
The above discussion of the surveillance team concept applies most
appropriately to a State operated program where there are a limited
number of inspection stations located over a relatively small geographical
area, and where a large volume of vehicles are tested at each station.
The surveillance team concept would not be practical for a State licensed
inspection and maintenance program where there would be a low rate of
inspection at a large number of stations spread over a wide geographical
area. Licensed stations must be required to report rejection rate and
emissions data either to the licensing agency or other appropriate agency.
This requirement could be part of the licensing agreement.
Licensed facilities would normally perform maintenance as well as
vehicle testing. Thus, it would be relatively easy for the "before" and
"after" emission data to be collected on rejected vehicles. Some problems
may be encountered in collecting these data if a majority of owners of
rejected vehicles elect to have maintenance and retesting done other than
where the initial test was conducted. This may occur if it becomes common
knowledge that maintenance at a particular licensed station is poor.
An additional step in the monitoring system can be included to
survey the testing and maintenance functions of licensed stations. This
can be accomplished through direct calibration of testing equipment by
agency personnel at periodic intervals, and through calibrated vehicles
with known maladjustments.
V-7
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Reporting
Operation of an inspection and maintenance program will involve
reporting information to various levels of State and local agencies and
EPA. Development of data collection and analysis procedures and design
of the information reporting mechanism should be carried out early in
program development phase to insure that information flow both vertically
and horizontally through the managing and/Or participating agencies is
smooth.
State and Local Agency Reporting Requirements
The State and local agency reporting requirements will vary in de-
tail and content between States and according to the type of inspection
and maintenance program implemented. As suggested by the discussion on
monitoring, reporting requirements for a State owned and operated program
would be somewhat more simplified than for a program operated through State
licensed inspection and maintenance facilities. This primarily results
from the requirement to report information "internally" between and through
State and local agencies who, in all probability, already have established
lines of communication. In addition, there would probably be more control
over agency personnel as regards collecting and analyzing data and sub-
mitting reports in a timely manner.
For licensed facilities, reporting requirements must be levied on
private businesses. Thus, control over the accuracy of data collection
and timely submittal would be limited. Of course, the owner of a facility
whose success depended primarily on operating under a license in good
standing, would probably be more prudent in fulfilling reporting require-
ments. Data reporting for inspection and maintenance programs which, are
V-8
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incorporated with existing safety inspection programs should be less
complicated if some form of reporting exists where owners and operators
are already in the habit of collecting and submitting information.
Federal Reporting Requirements
There are two separate cases in which a State and/or local agency
may be required to submit data to EPA. If a State has an approved imple-
mentation plan which contains an inspection and maintenance program,
emission data generated by the program, along with other emission and
air quality data must be submitted to EPA, through the appropriate
Regional Office (See Appendix A), in the semiannual report required
by EPA regulations (38 FR Part 51, Section 51.7, Para. (B)).
If a State is required to implement, operate, and enforce an inspec-
tion and maintenance program, the State must submit vehicle emission data
resulting from the program on a quarterly or semiannual basis in accordance
with the promulgated reporting requirements. These data must be submitted in
the format prescribed by Appendix M to 38 FR Part 51, which is shown here as
Table V-l. The time periods in the first column represent the quarter or
semiannual period for which the data are being reported. The subregion can
represent an inspection station at which data are collected, a county in which
i
data are collected, or any other geographical area which is specifically
defined. The choice of subregion selection belongs to the State or local
agency. Emission data collected while the inspection and maintenance
program is operating are entered in the second column opposite the
appropriate time period and subregion. Vehicle emissions that would
have occurred had the program not been in operation are entered in a
similar manner in the third column.
V-9
-------
States required to implement an inspection and maintenance program
must submit actual per vehicle emission data to EPA. Analysis of these
data will indicate the effectiveness of the inspection and maintenance
program, and will also assist EPA in handling the warranty and recall
provisions of the Clean Air Act.
Emission data are submitted quarterly or semi annually for that
period only. At the end of a calendar year, data are summarized for all
quarters or seminannual periods during which data were collected, and
this summary is also submitted. Thus, at the end of a calendar year,
the reporting agency will submit two reports, one covering the last
quarter or semiannual period for the year, and one summary for the year.
Table V-l
Inspection and Maintenance Emission Data
(Specify Pollutant Here)
With Without
Control Measure Control Measure
Time Period 1
Sub region 1
Sub region 2
Sub region 3
Time Period 2
Sub region 1
Sub region 2
Sub region 3
V-10
-------
As mentioned previously, dissatisfaction with poor maintenance and
high costs can be expected to surface through motorists' compliants.
An effective procedure for soliciting and receiving such complaints, and
following up with solutions to legitimate problems can greatly enhance
the effectiveness of the entire program.
V-12
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Chanter VI
Federal and State Programs Related
to Inspection/Maintenance
Over the past seven years, a variety of programs on
inspection and maintenance programs have been sponsored hy
Fedrral am" State governments, and a number of new programs have
heen starter! recently. This chapter wil] summarize pertinent
proaror.s, past and present.
Programs Sponsored by the Federal Government
Fast Program^
In order to collect information for use by the States in
establishing inspection and maintenance programs, several
experimental studies have been conducted over the past four years.
The results of those studies have been made available to the
States and other Interested agencies through the Federal Register,
(1)
a Control Strategies document, the reports of the Coordinating
(2)
research Council APP7-C CAPE 13-68 committee , and various
contacts between FPA personnel and State and local pollution
control aqencJes.
Tps/^J^ Program; The purpose of this program conducted at
F.PA in Ypsilanti, Michigan and Los Angeles, California was to
r"oterrine the r'eareo of correlation between the emissions durino
scvrra] rf tbo romp'on inspection cycles and those during the 1975
Federal Tent Procedure which is considered to be the only test
th^t is capable of predicting air duality effects from vehicle
VI-1
-------
emissions. In addition, the study provided data on the cost and
effectiveness of mandatory maintenance programs.
Short Cycle Study:*3' The purpose of the Short Cycle Study was to
evaluate the costs and effectiveness of idle tests and the Clayton Key-
mode procedure. A full report of the study including a comparison of the
Key mode test, the idle test, and Federal Short Cycle test and the 7-mode
test will be available in the near future.
High Altitude Study/4) This study, sponsored by the EPA Region VIII
Office, compares the costs and effectiveness of idle and keymode testing
at high altitudes. The results of the testing which was conducted in
Denver, Colorado are in general agreement with those obtained in other
studies at low altitudes.
Cape 13-68 Study. ' The primary purpose of this Coordinating Re-
search Council Inc. study was to develop a computer model which could
be used to predict the air quality effects of various inspection and
maintenance procedures. In support Of the computer model, experimental
studies were conducted to quantify typical values of many of the parameters
involved in the computation. Among the parameters studied were:
1. Effect of parameter adjustment on emissions,
2. Inspection station costs,
3. Demographic data on Los.Angeles and Detroit,
4. Emission baseline data on Los Angeles and Detroit,
5. Engine parameter data on Los Angeles and Detroit,
6. Typical repair costs,
7. Parameter and emission deterioration rates,
8. Service industry diagnostic and repair effectiveness, and
9. Emission measuring instruments comparison.
VI-2
-------
The results of this three year study are now available in a multi-
volume report from CRC at Thirty Rockefeller Plaza, New York, New York 10020.
Evaluation of Post '74 Prototypes: The purpose of this task is to
obtain information on-the applicability of present short cycle (e.g. steady
state, idle, and keymode) tests to post-1974 light-duty vehicles. Proto-
type versions of post-1974 light-duty vehicles will be subjected to the
1975 Federal test procedure and additional short cycle tests. Particular
attention will be paid to the applicability of the cycles, instruments, and
procedures to these vehicles.
Programs Sponsored by State and Municipal Governments
Arizona
Two pilot emission inspection stations capable of running loaded mode
tests are being set up. One station will be in Phoenix and the other in
Tucson. The State is also experimenting with an instrument for diagnosing
malfunctions leading to high emissions. A State wide inspection and main-
tenance program is planned eventually.
California
The State Bureau of Automotive Repair is presently running an inten-
sive program to certify hydrocarbon-carbon monoxide instruments for
repair garages. These will be required in all Class A garages by July,
1974. The California Highway Patrol presently spot checks vehicles,
with an idle test as part of their random sample safety inspection pro-
gram. Vehicles which fail are sent to Class A garages for correction.
A new State law requires a loaded mode test and will result in an inten-
sive development program.
VI-3
-------
T'T Bureau of Automotive Fepair 3 K planninrr to establish a
pilot inspection station in Riverside County to run loaded mode
p^iif^-ion t.pst.s. Vehicles von Id ho tested once a voar. If a
vehicle foiled the test, it v/ill be referred to a a certified and
licensed Clriss A garage for needed repair. A vehicle will not
have to return for a second inspection after the repair has been
made. Idle emission tests vil] be performed randomly by the
Ilighwav Patrol as nart of its on-the-road safety inspection prooram.
If a vehicle fails this test at any time, it must go back to a
Class * onrane for repair. California plans to first spread
tho pronrar to the counties of southern California after the
completion of the pilot pr iran and then to the entire State.
Colorado
The state has rur a proqram to determine the effect of altitude
on enissjor.s and at what operatina conditions vehicles should be
set to ir,inim.ize emissions.
Illinois
The citv of Chicano has set up low budget emission inspection
s tat Jons. The procfram is in a data gathering phase at present.
Little is being done by way of maintenance and rrpair. There is
sore interest in spreading the program to all of Cook County.
;.'ew Jersey
MJ three safety inspection facilities have been performing
an idle test for carbon monoxide and hydrocarbons since July, 1973.
Tnpair and retestina of rejected vehicles was voluntary. Beginning
in February ]974, rejecter! vehicles must be repaired and retestec1
until they pass inspection. TTie State has a continuing program
VI-4
-------
to certify instruments for measuring hydrocarbons and carbon monoxide
for use by garages and dealers. The present standards fail about 10 percent
of the vehicles which are tested. More stringent standards will be
adopted within a year. The State is developing a loaded mode CVS test
for mass emission measurement to eventually replace the idle test currently
used. In the past the State conducted extensive programs on emissions
from used vehicles, studying effectiveness of short cycles, and effective-
ness of repair in reducing emissions.
New York
The State is operating a pilot program for upstate cities employing
mobile inspection units. They collect emission data primarily in
shopping centers. Several thousand vehicles have been tested so far.
New York City has an active development program for trucks and buses.
This is the only research program now being run on inspection and main-
tenance of heavy-duty vehicles.
Oregon
The State legislature appropriated one million dollors for an
inspection and maintenance program which will be used to set up and
operate prototype inspection stations. The State currently favors a
loaded mode emission test.
Washington, D. C.
The District has one inspection lane with a dynamometer and
analyzer for conducting loaded mode tests. Additional lanes will
be equipped by March, 1974. They are collecting only emission
data now. No maintenance program has as yet been established.
VI-5
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PEFFRF.NCFS
1. 'Control Strategies for In-Uso Vehicles," U.S.
rnvironnertal Prctpction Agency, MSAPC, November, 1972.
2. TPIT pwstems Croup/Scott research Laboratories, APFAC
Prnn^ct CAPF 13-68,"A Study of the Feasibility of
f'flp
-------
APPENDIX A
ENVIRONMENTAL PROTECTION AGENCY
REGIONAL OFFICES
REGION
STATES/TERRITORIES
Environmental Protection Agency
Region I
John F. Kennedy Federal Bldg.
Boston, Massachusetts 02203
Environmental Protection Agency
Region II
26 Federal Plaza
New York, New York 10007
Environmental Protection Agency
Region III
Curtis Bldg., 6th & Walnut Sts.
Philadelphia, Pennsylvania 19106
Environmental Protection Agency
Region IV
1421 Peachtree Street
Atlanta, Georgia 30304
Environmental Protection Agency
Region V
1 North Wacker Drive
Chicago, Illinois 60606
Environmental Protection Agency
Region VI
1600 Patterson Street
Dallas, Texas 75201
Environmental Protection Agency
Region VII
Kansas City, Missouri 64108
Environmental Protection Agency
Region VIII
Lincoln Tower Bldg.
1860 Lincoln Street
Denver, Colorado 80203
Connecticut, Maine,
Massachusetts, New Hampshire,
Rhode Island, Vermont
New Jersey, New York,
Puerto Rico, Virgin Islands
Delaware, Maryland,
Pennsylvania, Virginia,
West Virginia
Alabama, Florida, Georgia,
Kentucky, Mississippi,
North Carolina, South Carolina,
Tennessee
Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin
Arkansas, Louisiana,
New Mexico, Oklahoma,
Texas
Iowa, Kansas, Missouri,
Nebraska
Colorado, Montana,
North Dakota, South Dakota,
Utah, Wyoming
A-l
-------
REGION STATES/TERRITORIES
Environmental Protection Agency American Samoa, Arizona,
Region IX California, Guam, Hawaii,
TOO California Street Nevada
San Francisco, California 94111
Environmental Protection Agency Alaska, Idaho, Oregon,
Region X Washington
1200 Sixth Avenue
Seattle, Washington 98108
A-2
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APPENDIX B
GLOSSARY
1. Inspection and Maintenancne Program - A program to reduce emissions
from in-use vehicles through identifying vehicles that need emissions
control related maintenance and requiring that maintenance be performed.
2. Emission Inspection Program - An inspection and maintenance program
in which each vehicle is subjected at specified intervals to a test of
its emissions under specified conditions. The emission levels are
compared with a standard established for the vehicle class. If the
emissions are higher than the standard, the vehicle is failed and must
be adjusted or repaired to bring its emissions into compliance with the
standard.
3. Loaded Mode Test - An emission inspection program which measures
the exhaust emissions from a motor vehicle operating under simulated
road load on a chassis dynamometer.
4. Idle Test - An emission inspection program which measures the exhaust
emission from a motor vehicle operating at idle. (No motion of the rear
wheels). A vehicle with an automatic transmission may be in drive gear
with brakes applied or in neutral gear.
5. Key Mode Test - A loaded mode test in which exhaust emissions are
measured at high and low cruise speeds and at idle. The cruise speeds
and dynamometer power absorption settings vary with the weight class of
the vehicle. The dynamometer loading in the high cruise range is higher
than normal load in order to more effectively expose malfunctions leading
to high emissions.
B-l
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6. Light-Duty Vehicle - A motor vehicle designed for highway use of
less than 6000 pounds gross vehicle weight. Further distinctions are
sometimes made between light duty automobiles and light duty trucks
such as pickup trucks.
7. Chassis Dynamometer - A machine equipped with two parallel rollers
which support the rear wheels of a motor vehicle. When positioned on
the dynamometer the vehicle may be "driven" to simulate the loadings the
engine would experience when the vehicle is operated on the road. A
power absorption unit is connected to the rollers to simulate the
loading from the various sources of fluid and mechanical friction present
during road operation. Weights can also be coupled to the rollers to
simulate the inertia! effects of vehicle mass during acceleration and
deceleration.
8. Positive Crankcase Ventilation - A system designed to return blow-
by gases from the crankcase of the engine to the intake manifold so that
the gases are burned in the engine. Blow-by gas is unburned fuel/air
mixture which leaks past the piston rings into the crankcase during the
compression and ignition cycles of the engine. Without positive crank-
case ventilation these gases, which are rich in hydrocarbons, escape
to the atmosphere.
9. Transportation Control Strategy - The sum total of all transportation
control measures used in an area to reduce emissions of air pollutants
from transportation sources.
10. Transportation Control Measure - Any measure that is directed toward
reducing emissions of air pollutants from transportation sources. Examples
of measures include reducing vehicle use, changing traffic flow patterns,
B-2
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decreasing emissions from individual vehicles, through inspection and
maintenance or retrofit, and altering existing modal split patterns
(e.g. getting people to use buses or car pools instead of individual
cars).
11. Vehicle Emissions Standard - A specific emission limit allowed for
a class of vehicles. The standard is normally expressed in terms of
maximum allowable concentrations of pollutants (e.g. parts per million).
However, a standard could also be expressed in terms of mass emissions
per unit of time or distance traveled (e.g. grams per mile).
12. Initial Failure Rate - The percentage of vehicles rejected because
of excessive emissions of a single pollutant during the first inspection
cycle of an inspection and maintenance program. (If inspection is con-
ducted on more than one pollutant, the total failure rate may be higher
than the failure rates of any single pollutant,)
13. Mandatory Maintenance Program - A special case of an inspection and
maintenance program which requires each vehicle, regardless of its emis-
sion level or mechanical condition, to have specific maintenance operations
performed at specified intervals. There is no inspection phase to deter-
mine what maintenance is necessary. The appropriate maintenance is explicit-
ly specified for each type of vehicle.
14. Parameter Inspection Program - An inspection and maintenance program
in which each vehicle is subjected to a sequence of diagnostic tests which
evaluate the mechanical condition of various emission related systems or
components and determine if malfunctions or maladjustments are present.
Vehicles showing measurements outside acceptable tolerance ranges are
failed and required to have corrective maintenance performed.
B-3
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15. Rejection Rate - The percentage of total vehicles tested in an
inspection/maintenance program in a given time period that fail inspec-
tion and are required to have maintenance performed.
16. Heavy-Duty Vehicle - Any motor vehicle designed for highway use
which has a gross vehicle weight of more than 6000 pounds and less than
10,000 pounds.
17. Medium-Duty Vehicle - Any motor vehicle designed for highway use
which has a gross vehicle weight of more than 6000 pounds and less than
10,000 pounds.
B-4
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