EPA-AA-TEB-511-8 0-6
              EPA Evaluation of the "W/A WAAG-Injection System"
This document  contains  several pages which  may  not reproduce well.   Any
questions concerning the legibility of  these  pages  should  be  directed to:
Merrill W. Korth,  Emission Control Technology Division, Office of  Mobile
Source  Air  Pollution  Control,  Environmental  Protection  Agency,  2565
Plymouth Road, Ann Arbor, MI  48105, (313) 668-4299 or FTS  374-8299
                                October 1980
                         Test and Evaluation Branch
                    Emission Control Technology Division
               Office of Mobile  Source Air Pollution Control
                    U.S. Environmental  Protection Agency

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EPA  Evaluation  of "W/A  WAAG-Injection System"  under  Section 511  of the
Motor Vehicle Information and Cost Savings Act

The  following  is a summary  of  the information  on  the  device as supplied
by the Applicant and the resulting EPA analysis and conclusions.

1.  Marketing Identification of the Device:
Trade Names:
    "Waag Power-Jector
    "Power-Jector

Marketing names:
    "W/A Waag-Injection System"
    ^'Water/Alcohol Waag-Injection System"
    "Waag Water/Alcohol Fuel.Injection System"

Trade Mark:

    "There is no  trade mark,  but  this  logo will be used on all literature
    and packaging."
    "There  is  only  one model  and  the  unit number  on  Instructions  and
    Warranty are purchase order numbers assigned by us."

2.  Inventor of the device and patents:
    a)   Norman E. Waag, U. S. Patent No. 3987774
         3110 Broadview Rd.
         Cleveland, OH  44109
    Approved October 26, 1976

    b)   "Exhibit  "A"  is  a  copy  of the patent"   (Attachment A  of  this
         evaluation).

3.  Manufacturer of the Device:
    Engineered Fuel Systems, Inc.
    Colony Plaza - Suite 1220
    6451 North Federal Highway
    Fort Lauderdale, FL  33308

4.  Manufacturing Organization Principals:
    Lome A. Cameron, Jr. , President
    Alex C. Cameron, Secretary

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5.  Marketing Organization in U. S. /Identity of Applicant:
    Engineered Fuel Systems, Inc.
    Colony Plaza - Suite 1220
    6451 North Federal Highway
    Fort Lauderdale,  FL  33308

6.  Identification of Applying Organization Principals:
    Lome A. Cameron, Jr. , President
    M. Aynslee Cameron, Vice President and Treasurer
    Alex C. Cameron,  Secretary

7.  Description of Device (as supplied by Applicant):

    a) "Purpose of the Device:

         1.  Increase engine efficiency
         2.  Increase life of the internal combustion engine
         3.  Prevent  contamination of the engine caused  by carbon
         4.  Prevent  "Dieseling"
         5.  Increase the effective Horsepower
         6.  Increase octane number up to as much as ten numbers higher
         7.  Reduce "Blow-By"
         8.  Increase life of oil
         9.  Reduce emissions of CC>2 and NOx
         10. Increase gas mileage"

    b)   Theory of Operation:  (numbers  contained  in  the  following  de-
         scription refer to patent diagram-Attachment B)

         "Exhibit  "C"  is a detailed drawing of  this  device,"  (Attachment
         B of this evaluation).

         "In operation,  the apparatus  of  the  invention  begins  to function
         when the  operator  starts the  engine  and  the  supplementary  fuel
         such as  water/alcohol  is  contained  in reservoir  1.   It may  be
         seen that the  engine immediately creates  a vacuum in  its  intake
         manifold   and  an  exhaust  gas pressure  varies  with  the  torque
         requirements of the engine."

         "The apparatus  of the  invention  has  a fluid  passage  connection
         to said  manifold  and it  uses said vacuum  and exhaust  gas.   It
         provides  a  vacuum passage  tube  19 and 20 conecting the  intake
         manifold   21   with  the  vacuum  chamber 12 and  an  exhaust  gas
         passage tube  3 connecting the exhaust  manifold  5  with  the  fuel
         reservoir 1."

         "The  various  functions  performed by  said  apparatus  under  the
         operator's control include the following:

         Charging  the Fuel Chamber

         The supplementary fuel is brought  to the fuel  chamber  11 for  use
         and consists  of charging the  said  fuel chamber 11 with supple-

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                           -3-

mentary fuel from said  reservoir  1.   This  is  accomplished as the
vacuum  in  the vacuum chamber  12  builds up sufficiently  high to
overcome  the  pump  spring 18  of  the  diaphragm  pump  and  thus
causes  the  diaphragm  to  depress  into  the  vacuum  chamber 12.
This action of the  diaphragm 13  creates a  vacuum in the adjacent
fuel chamber 11  and which  will be overcome as  said vacuum draws
a  charge  of supplementary  fuel  into  the  said  chamber  from the
reservoir 1  through the fuel  outlet 7  and  fuel  passage  15 and
thereon  through  the  fuel  inlet  check valve  14.   The  exhaust
pressure in the  reservoir  1 is available to  aid the flow of said
fuel into  said fuel chamber 11.   During said operation  the fuel
outlet check valve  16 remains closed."

"After the  said  fuel  chamber 11  has  been charged  the  said sup-
plementary  fuel  is  discharged  therefrom to the engine carburetor
as follows:

For High Torque Requirements

When the  vacuum  from the  intake manifold 21  is  reduced during
periods of  high  torque  requirements  with  part  or  open throttle
valve conditions, pump  spring  18  overcomes the reduced vacuum in
the  vacuum  chamber 12  urging  said  diaphragm  13 against  the
supplementary  fuel  charge  in  the  fuel  chamber  11  closing inlet
check  valve  14  and  forcing  said   supplementary  fuel  through
outlet  check  valve 16  through  tube  passage  17 through shut-off
solenoid  30 through  tube  passage  35   to metering  jet   37  and
nozzle  36   and   finally  into   carburetor  throat  and thereon  to
venturi 40.

For Low Torque Requirements

When  the  operator has increased   the engine RPM  the  vacuum
decreases and the pump  spring  18  thereby forces the diaphragm 13
to  the  end of  its  stroke,  the  exhaust  manifold  5 builds  up
sending exhaust  gas pressure  through exhaust gas  passage  tube  3
into reservoir  1,  pressurizing   supplementary  fuel  therein and
urging  said  supplementary  fuel through reservoir  outlet  tube  7
through inlet  fuel  passage tube  15 forcing inlet  check  valve 14
open  to permit  pressurized  supplementary  fuel  to  enter  fuel
chamber 11  and thereon  through outlet check valve 16 and thereon
to said carburetor.

The  operator may  then  set  the  throttle  valve  for steady RPM
operation and  obtain  substantially  the  same result aided  by the
supply of  supplementary fuel  resulting  from  the  dominant  use of
the exhaust gas pressure.

For Variable Torque Requirements

When the operator  has a variable  engine  RPM requirement  with  a
variable torque  requirement  with or  without  a  variable throttle
valve  setting  requirment,   the  apparatus  of  the  invention will
immediately  supply  the  supplementary  fuel  to  the engine  car-

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                                    T4-

         buretor  as  the  engine  transmits  a  dominant  vacuum  and/or  a
         dominant  exhaust  gas  condition  to  the  diaphragm and  metering
         apparatus of the invention.

         During  deceleration or  idling  the invention  becomes  inactive
         because the vacuum and exhaust  gas  conditions are  minimal  and it
         is  imperative  that  no  supplemental  fuel  be  injected  at  such
         times.

         Applicant's  apparatus   is   therefore  unique  in   the  manner  of
         delivering supplementary fuel  to the  carburetor  of an  internal
         combustion engine  in its  use  of the  above atmospheric  pressure
         received  from  the  engine's exhaust  manifold  and  the use  of  the
         less  than  atmospheric  pressure   or   partial  vacuum  pressure
         received  from  the  engine's  intake  manifold  when  each  said
         pressure is in dominance in the respective manifold.

         Having  thus  described  this  invention  in  such  full,  clear,
         concise and exact  terms  as  to  enable  any person  skilled  in  the
         art to  which  it  pertains  to  make and use  the  same,  and  having
         set  forth  the best mode  contemplated  of  carrying  out  this
         invention, I  state  that  the  subject  matter  which  I  regard  as
         being my  invention  is  particularly pointed  out   and  distinctly
         claimed   in   what   is   claimed,   for  being  understood   that
         equivalents or modifications  of, or substitutions for,  parts of
         the above specifically described embodiment of  the invention  may
         be made without departing  from  the  scope  of the invention  as  set
         forth in which is  claimed."
8. Applicability of the Device (claimed):
    "The  Water/Alcohol  WAAG-Injection   System  is  applicable   to   all
    internal combustion engines  with the exception of:

         a) The Wankel Rotary Engine
         b) All two-stroke engines that mix gasoline and oil
         c) All diesel engines for the present time pending final
            engineering tests.
         d) All aircraft engines."

9.  Device Installation, Tools and Expertise Required (claimed):
         Installation of  the  W/A WAAG-Injection System  can only  be  done
         by authorized  trained   dealers  of the  device.   Exhibit  D,  (At-
         tachment  C  of  this evaluation)   was  the  initial  installation
         description  provided  by  the  Applicant.   The  Applicant,  sub-
         sequent to  EPA evaluation  commencement  (July,  1980),  submitted
         the  revised  instructions  provided  as  Attachment  J   of  this
         evaluation.   In these  revised instructions, mention  is  made  of
         sophisticated  engine  diagnostic equipment  and  distributor  test
         machines;  however, no requirements for the  dealer  to  obtain  such
         equipment  are mandated.

10. Device Operation (claimed):
         a) "Fill  tank or  reservoir  regularly with  1/2 gallon of water

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                                    -5-
         and 1/2 gallon of alcohol plus one capful of inhibitor.
         b) Please see Exhibit "D" (Attachment C)

11. Device Maintenance (claimed):
         a)  "Keep water  and  alcohol plus  Inhibitor  tank  or  reservoir
         filled.
         b)  Clean out  filter  at  (E)  as  shown  on Installation  Instruc-
         tions, Part A - Page 4, using 9/16" wrench to loosen fitting.
         c)  If  necessary  blow  out  metering jet  (K)  as shown  on  Instal-
         lation Instructions, Part A - Page 4 with air pressure.
         d) No particular  skills are required."

12. Effects on Vehicle Emissions (non-regulated)  (claimed):
    "The Water/Alcohol  WAAG-Injection  System while operating,  functioning
    properly or malfunctioning will  not  cause  a  vehicle to  emit  into  the
    ambient  air  any  substance  other than  pollutants  regulated  by  EPA
    (hydrocarbons,  carbon  monoxide,  and  oxides  of  nitrogen,  or  normal
    atmospheric conditions constituents,  such  as  carbon dioxide,  or water
    vapor) in a quantity differing  from  that emitted in the  operation of
    the vehicle without the device."

13. Effects on Vehicle Safety (claimed):
    "The Water/Alcohol  WAAG-Injection  System while operating,  functioning
    properly or malfunctioning will  not result   in  any unsafe  condition
    endangering  the  motor  vehicle,   its  occupants,  other  persons,   or
    property in close proximity to the vehicle."

14. Test  Results   -  Regulated  Emissions and  Fuel  Economy   (submitted  by
Applicant:
         a) Automotive Exhaust Emission and Fuel  Economy Test Report
         Olson Engineering, Inc.
         Huntington Beach,  CA  (Attachment D)

         Project 6193
         Complete  test 1973 Plymouth Duster
         Car selected by California Air Resources Board

         b) California Air Resources Board
         Haagen-Smit Laboratory
         Project 2V7908-1973 Plymouth Valient
         Car owned by State of California
         Emissions Tests Completed (Attachment  E)

         Fuel Economy Test  incomplete:
         The engine was not properly
         cleaned and complete tests
         may be rerun.

         c) California Air  Resources Board
         Haagen-Smit Laboratory
         Project 2V908-1974 Ambassador
         Car owned by State of California
         Emissions Tests completed (Attachment  F)

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                                    -6-
         Fuel Economy test incomplete:
         The engine was not properly
         cleaned and complete tests
         may be rerun.

    "Note:     We  (the  Applicant)  have  been   advised   by   Ron  Wagner,
              C.A.R.B. Engineer  in charge of  these tests,  that we  have-
              been  recommended  for  an exemption  under  California  State
              Law to  VC27156.   Although  we  have   not  received  official
              documentation,   we  nave  been  told   it  only   awaits   the
              Director's signature."

         d) Society of Automotive Engineers
         Paper 214 - R.I.  Potter, June  11, 1948  (Attachment G)

         e) Society of Automotive Engineers
         Paper 215 - C.H.  Van Hartesveldt, June  il,  1948  (Attachment H)

         f) Statements from individuals
         relating actual experience with
         the W/A WAAG-Injection System.  (Attachment I)

15.  Information Gathered by EPA:
    A detailed  report  of  the test  data gathered by the EPA  is  reflected
    in EPA  report,  EPA-AA-TEB-81-2, "Emissions  and Fuel  Economy  Effects
    of the W/A  WAAG-Injection  System"  provided  as Attachment  K.   A brief
    description of this testing effort  is  provided  below:

    a) A  1979  Chevrolet  Nova was  tested according to  the  Federal  Test
    Procedure (FTP) and  the  Highway Fuel Economy  Test Procecure  (HFET).
    A  total  of  seven   FTP's   and  five  HFET's  were   used  for  this
    evaluation.    Tests were  conducted  in  three  configurations,  using
    commercially available, unleaded  fuel;  1) "Baseline"  configuration  -
    vehicle   tuned   to   vehicle   manufacturer's    specifications,    2)
    "Parameters  Adjusted"  configuration   -   vehicle  tuned  to   vehicle
    manufacturer's specifications except  for  additional  8° spark  advance
    and with .003  in. smaller  carburetor  jets  installed per  agreement
    with Engineered  Fuel  Systems  personnel,  and   3)  "Device  Installed"
    configuration -  vehicles  tuned as  in  (2) and with  device  opera-
    tional.   Device  manufacturer   specified  mileage  accumulation  (1000
    miles   and/or  4   gallons  or  water/alcohol  consumed)  was  performed
    according to  the  Automobile  Manufacturer's  Association (AMA)  driving
    schedule  after  "parameters  adjusted" testing  and prior to  "device
    installed" testing per device manufacturer's instructions i.e.  after
    "parameters adjusted" testing,  engine design parameters were reset to
    vehicle  manufacturer's  specifications  and  specified   mileage   was
    accumulated  with   device  operational.   These   exhaust  emissions  and
    fuel economy test data are detailed in Attachment K.   The vehicle was
    also driven on-the-road to assess  vehicle operational  characteristics
    with the device installed.

    b) A 1977  Dodge Aspen was tested  with  those procedures  and  in those
    configurations  cited   in   15.a)  above.   A  noted  exception  in  the
    "parameters adjusted" and  "device  installed" configurations was  that

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                                -7-
vehicle  driveability   limitations   permitted  the   installation  of
carburetor  jets  only  .002  in.  smaller  than those  supplied by  tne
vehicle manufacturer  as  standard equipment.  A  total of  seven  FTP's
and  seven  HFET's were  performed.  These  test data  are  detailed  in
Attachment K.  The results from  this vehicle  were  not included in the
general  conclusions  because  of a  substantial   shift  in  emissions
(apparently  vehicle  induced)  between  the -"parameters  adjusted"  and
"device installed" tests.

c)  A 1978  Mercury  Zephyr  was  tested  with  those procedures and  in
those configurations  cited  in  15.a)  above.  A  total of  seven  FTP's
and  seven  HFET's were used  for  his  evaluation.   These  test  data are
detailed in Attachment K.

d)  A 1979  Ford  Granada  was tested  in two supplemental  programs.   A
summary of the procedures used for each supplemental program follows:

     1.  First Supplemental Program (See Attachment K)

          a.  All  vehicle  pre-test   adjustments  were  performed  by
              representatives of the  Applicant.

          b.  The test procedures and configurations  were  the same  as
              those  cited  in 15.a) above.  Two Hot  Start  LA-4  tests
              (first  1372   seconds  of   the   FTP   starting   with   a
              warmed-up   stabilized   vehicle)   per   FTP/HFET   test
              sequence were added.

          c.  The 1000  mile (and/or  4 gallons  of mixture  consumed)
              "clean-out" procedure was  deleted with the  consent  of
              the Applicant to expedite testing.

          d.  The "device  installed"  configuration  adjustments  were
              performed by  representatives  of the  Applicant  (as  they
              would  perform  them  in  the  field)   with EPA  personnel
              observing.    Adjustments   performed   included:  1)   NO
              change in  carburetor main  jet size,  2)  modification  to
              both  the  centrifugal  and  vacuum   advance  distributor
              curves and 3)  advancing  the basic ignition  timing  from
              nominal  (8° BTDC) to 10°  BTDC.

          e.  A  total  of  six  FTP's,  six  HFET's  and ten Hot  LA-4's
              were conducted for consideration in this evaluation.

     2.  Second Supplemental Program (See Attachment K)

          a.  The Hot  LA-4  test  procedure  was  primarily  used for  this
              phase  of  the  evaluation.   The  test configurations  were
              the same as those  cited in  15.a)  above  with the following
              exceptions  for  distri-butor  advance curve  and  ignition
              timing.

                    1) Mean  Distributor - set to  vehicle manufacturer's
                    nominal specificatons

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                                    -8-
                            a) Baseline - nominal ignition timing (8° BTDC)
                            b)  Parameters Adjusted  -  nominal +4°  initial
                            timing
                            c) Device Installed - nominal +4° initial timing

                        2)  EPA-Modified   Distributor   -  set  to   maximum
                        vehicle manufacturer's production tolerance limit
                            a)  Parameters Adjusted  -  nominal  +2°  initial
                            timing
                            b) Device Installed - nominal +2° initial timing

                        3)  WAAG-Modified  Distributor   -  set  by  represen-
                        tatives of  the  Applicant  for the First Supplemental
                        Program
                            a)  Parameters Adjusted  -  nominal +2°  initial
                            timing
                            b) Device Installed - nominal +2° initial timing
              Sixteen  Hot  LA-4 tests  were  conducted   for  this  portion  of
              this evaluation.

              b.  Water/Alcohol  flow  rates   were  measured  during  vehicle
              operation according to the following driving cycles:
                  1) FTP
                  2) HFET
                  3) AMA
                  4) LA-4
                  5) Modified  LA-4  (acceleration   rates   of  5.0  mph/sec
                  rather than standard 3.3 mph/sec)

              These  measurements  were  conducted at  both 3500  Ib.  IVi  and
              4000 Ib. IW dynamometer  settings and with both a "yellow"  and
              a "blue" injection pump spring.

e)  Society  of  Automotive  Engineers  (SAE)  paper  #690018,   "Inlet  Manifold
Water Injection for Control of Nitrogen Oxides - Theory and Experiment."

f) Report #ADA  00332,  Contract  #DDA D05-72-C-0053,  "Water  Induction  Studies
in a Military Spark Ignition Engine."

g)  Taylor  and  Taylor;  Copyright 1961;  "The Internal  Combustion  Engine,";
Chapter 6, "Effects of Operating Variables on Detonation".

h)  Edward  Obert;  Copyright  1973;  "Internal  Combustion  Engines  and  Air
Pollution"; Chapter 9, "Knock and the Engine Variables".

i)  Charles  Fayette  Taylor;  Volume  1;  Copyright  1966; "The  Internal-Com-
bustion Engine  in Theory  and  Practice";  Chapter  12,  "The  Performance  of
Unsupercharged Engines"

j)  Charles  Fayette  Taylor;  Volume  2;  Copyright  1968; "The  Internal-Com-
bustion  Engine   in   Theory  and   Practice";  Chapter   2,   "Combustion   in
Spark-Ignition Engines II: Detonation and Preignition".

k)  Henein  and  Patterson;   Copyright   1972;   "Emissions   from  Combustion
Engines".

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                                    -9-


1)  State  of California  Air Resources Board  (CARB),  Executive  Order  D-91,
"WAAG Enterprises, W/A WAAG Injection System". (Attachment L)

m)  Verbal  discussions with  Ron  Wagonner,  California  Air Resources  Board,
between 8-14-80 and 9-11-80, regarding CARB Executive Order D-91.

n)  State  of California  Air Resources Board  Staff Report;  March 13,  1974;
"Evaluation of  the Tetrahedron  Associates,  Inc.,  'Powerjector1  Device  for
Exemption from the Prohibitions  of  Section  27156  of the Motor Vehicle  Code"
(Attachment M)
                                                                  «
o)  State of California Air  Resources  Board  Staff  Report; December 13,  1974;
"Evaluation  of  the  Tetrahedron  Associates,  Inc.,   "Water-Motive  Demand
Injector'  Device  for  Exemption  from  the Prohibitions  of Section  27156  of
the Motor Vehicle Code" (Attachment N)

16.      Analysis:

    a)  Description  of  Device:   The description  of the  device originally
    provided by  the Applicant  was  found  to  deviate from  the  actual  device
    submitted  for testing.   When  informed  of the discrepancy, Mr.  Lome
    Cameron,  Jr.   of  Engineered  Fuel  Systems,   Inc.,   indicated  that  the
    description contained in the  511  Evaluation request was  only applicable
    to boats.  He  stated that  all  references to  any connection of the  W/A
    WAAG-Injection System  to  the exhaust manifold  should  be  deleted.   Only
    the device  connection  to the  intake  manifold is appropriate  for  auto-
    mobile applications.

    The  device  tested  included  provisions  for   a  water/alcohol mixture
    low-level warning  light which was not  included in  the  original  device
    description.   This  provision was  not used during  this  evaluation  and
    does not in any way bear on the results.

    b)  Applicability of the Device:  The applicability requirements  stated
    in  the  application  appear  to  be  correct,   however,  the  installation
    instructions  do  not  specifically address  fuel  injected and  variable
    venturi  fuel  delivery  systems.  For  these  cases,  conventional  car-
    buretor  jets  do  . not  exist  and  therefore,  should  be  specifically
    exempted from fuel delivery system modifications.

    c)   Device   Installaion:     The   original    installation   instructions
    submitted by the Applicant do not provide adequate  guidance  in  the area
    of  carburetor jet  replacement.  The replacement  of those  components
    requires  specific  knowledge   relative  to   the  construction  of  the
    carburetor and is considered  beyond the "minor  knowledge  of  the engine"
    level.

    Subsequent  to  511  Evaluation  Application   submittal,   the  Applicant
    revised  the  device  installation  procedures.   The  revision  requires
    installation by an authorized device  dealer who has received at least 4
    hours  of   training   in  the   installation   procedure.    Other   major
    differences  in  the two  sets  of installation  instructions are  provided
    in Attachment K.

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                                    -10-


    Further,  the  WAAG  Dealer  Manual  (Attachment  J),  which  contains  the
    revised   installation   instructions   and    technical   and   marketing
    information, includes  the following passages  as  technical  guidance  to
    the dealer:

         Item #8  "Eliminate heat sensors  in  the  line  from the vacuum spark
                  advance  to  the  carburetor.   Also  in cars with  two hoses
                  from the  distributor,  eliminate the retard  line (on some
                  Ford models)."

         Item #12 Referring to  the  EGR valve, "Although we  cannot tell you
                  to block it off, we  suggest you use  your own judgement as
                  that valve  should be checked each time  water  and alcohol
                  is  added.  The   EGR valve  is  not   to   be  considered  a
                  successful part of the emissions system."

    If authorized dealers  perform the  Applicant  suggested  modifications,  it
    could be  regarded  as tampering  and is  subject  to  the  legal liabilities
    afforded under Section 203 of the Clean Air Act.

    Additionally,  neither   the  original  nor   the   revised   installation
    instructions specifically prohibit the device  from being  connected  to
    the vacuum  source  for the exhaust gas  recirculation (EGR)  valve.  When
    advised of  this  fact,  Mr. Lome  Cameron  indicated  that the  EGR vacuum
    hose could  not  be used  due to  insufficient  vacuum.   He also indicated
    that such a coupling  could seriously  impair  the  effectiveness  of the
    EGR valve  operation.  It is therefore, recommended  that future instal-
    lation  instructions  specifically  prohibit  such a  coupling  to  the  EGR
    vacuum source.

    During the  period  of the evaluation test program,  it  is estimated that
    the average device  installation time for a "trained mechanic" was from
    2-3  hours.    This   estimate   assumes   that   all  replacement   parts
    (carburetor jets, gaskets,  if required, etc)  are  immediately accessible
    and does  not include  the time   spent  "troubleshooting" the  vehicle  to
    assure  that it  is  properly  tuned to  vehicle manufacturer's  specifi-
    cations.

d)   Device Maintenance:  The  maintenance  requirements  specified  in  the
application appear  to be  correct.    However,  Item  #6  of  the WAAG  Dealer
Manual  (Attachment  J),  "Customer Service  Instructions", pertains to engine
troubleshooting and  assumes  the ultimate  purchaser  has the knowledge  of  a
trained  mechanic.    Additionally,    these   instructions  do  not  include
directions for  the  owner to inspection of  all hoses  for wear/deterioration
and  leaks,  both  vacuum  and water/alcohol mixture  on a  periodic  basis.
Further,  since  the  consumption  rate  of  water/alcohol  is  vital   to  the
control  of NOx emissions,  the  owner  should  be  advised  in the  service
instructions to monitor  this  rate and notify his  dealer if the  consumption
rate does not comply with Applicant  recommendations.

The  Customer  Service  Instructions  recommend  that  the  vehicle  not  be
operated    for   more   than   100   miles   without    the   solution   of
water-alcohol-inhibitor.   However,   no provisions  are  made for  low-level
indicator testing.

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e)   Effects  on Vehicle  Emissions  (non-regulated):   Non-regulated  emission
levels  were  not  assessed  as  part  of  this  evaluation.   Since  the  device
injects  a  mixture  of  water   and  alcohol,   the  potential  for  increased
aldehyde formation as part of the combustion process may exist.

f)   Safety of  the Device:   If  for  some  reason  the device  malfunctions  or
the  operator  allows  the  water/alcohol  mixture  to  become depleted  when
traveling  in a  remote  area,  the  increased   spark  advance  and  carburetor
enleanment associated with  the  device  could cause serious engine  damage
from prolonged  severe knock.  Examples  of  potential damage  are  perforated
pistons and burned valves.

Although  the likelihood  of such  an occurence  is remote,  the  possibility
does exist   and  the  ultimate  purchaser  of the  W/A WAAG-Injection  System
should  be  made aware  of the potential  dangers  and  warned to be  alert  to
excessive engine  knock.   It is  recommended  that  the  Applicant develop a
method  of  detecting  water/alcohol  mixture   flow  and  provide  a  warning
device, other  than  listening for engine knock,  to alert the operator  to a
device malfunction.

g)  Test Results supplied by the Applicant:

    1)  Vehicle exhaust  emissions and fuel economy  data  obtained according
    to EPA test  procedures were collected  at  Olson  Engineering,  Inc.  (OEI)
    and were submitted  by  the  Applicant.  These  data are  deemed  insuffi-
    cient  to  substantiate   the  Applicant's  claims  because  only one  test
    sequence  (1  FTP  and 1  HFET)  per  condition  (1 test   sequence  in  the
    "baseline" configuration and  1  test  sequnce in  the  "device  installed"
    configuration) were performed on one vehicle.
                                                      •
    Based on information obtained from the OEI  test  report provided  by the
    Applicant and  from the California Air  Resources  Board  (GARB) regarding
    the testing  conducted by OEI,  it was  determined that  maintenance  was
    performed  on  the  carburetor  of the Olson  test  vehicle between  test
    sequences  and  that  the  spark plugs had  also been changed  between  the
    test  sequences.   There  was  also a  question  of the appropriateness  of
    the  inertia  and  road  load  horsepower  settings   used  to  properly
    represent the test vehicle.   Further, the  method  used  to purge  the test
    vehicle  engine of  deposit  build-up deviated  from that  specified  in  the
    Applicant's 511 Evaluation Application  (subsequent  information  provided
    by  the   Applicant  appears  to  encompass  the  procedure  used by  Olson
    Engineering).

    2)   The  data obtained  at CARB indicated that the device did not produce
    a  statistically  significant  improvement   in the  fuel  economy  of  the
    vehicles  tested.   The  engine "clean-out" procedures  used  at OEI  were
    also used by CARB.   These data  were  deemed unacceptable for  use  in this
    evaluation  because  the  Applicant  indicated  in  the  511  Evaluation
    Application that  the engines of  the vehicles tested  at CARB were  not
    properly cleaned.  It is assumed by  the EPA  that this  indication  on the
    part of the Applicant is a direct  result  of  the "clean-out"  methodology
    used in  previous  testing and thereby invalidates both  the  OEI  and CARB
    data.   It  should  be  noted that  the  alternate method of  engine  deposit

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                                    -12-
    clean-out  used  by both  OEI and  CARB  is no  longer  recommended  by  the
    device manufacturer  as  a total clean out procedure.   The  1000 miles of
    operation  with   the  system operational  is  recommended  as  a  minimum
    procedure even if preliminary clean out procedures are used.

    The  data  collected  at  CARB was  also  deemed unacceptable  because  the
    vehicles  used  were  not  considered   to  have  representative  emission
    control hardware  and replicate testing  in  each test  configuration  was
    not  performed.   Without  replicate  testing,  the  variability associated
    with  the  test   facility  can  not   be  assessed  and  may  mask  the
    effectiveness of the device.

    3)   The  test fuel used  by OEI and CARB,  on at  least  one vehicle,  has
    high octane  characteristics.   The octane number  of  a  fuel  governs  the
    amount of  spark  advance tolerated by a given engine.   Since the octane
    number  of  the   fuel  is  critical  to  the   effectiveness  of  the  W/A
    WAAG-Injection System,  due to  the  engine  design  parameter adjustments
    made in  conjunction with  its  use,  a  fuel  with  an  octane  number  more
    representative of  commercial  fuel should have  been  used  in  testing by
    both  OEI   and  CARB.   Such a  practice  would  have  provided  a  better
    assessment of the potential or  effectiveness  of the  device while in use
    by the ultimate  purchaser.

    4)  Results  of testing  at Automotive  Testing Laboratories  in Ohio could
    not be evaluated due to  the Applicant's  assertion that the test vehicle
    had not been properly "baselined" by the contractor.

h)  Information Gathered by EPA:
    Both  the  dynamometer   testing  and   subjective  on-road  evaluations
    conducted  by  the EPA are  discussed  in detail  in Attachment  K.   Since
    this document presents  an  indepth analysis of the effort  put  forth by
    EPA, a duplicate presentation is not provided.

17.  Conclusions

In summary, throughout all  three phases of  the  testwork  reported on the W/A
WAAG-Injection System,  significant  increases  were  found  in  fuel  economy;
however  corresponding  increases were found in  regulated emissions,  both as
measured from the vehicle manufacturer's specifications.

It should  be  noted  that although  the fuel economy  increases  observed were
statistically  significant  under   controlled   laboratory   conditions,   the
magnitudes  of  these  increases  were   small.   The  magnitudes   of   the
corresponding  and also  statistically  significant  increases  in  regulated
emissions were larger and require further development to  eliminate.

When  the  vehicles were evaluated  on  the  road, no  significant driveability
problems were found.

The observed  changes  in  fuel economy and emissions  for  the vehicles tested
were primarily a result of the engine design parameter adjustments.

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                                    -13-


Throughout  the  approximately  one  year  period encompassed  by  the  testing
reported  herein,  the Applicant  expended  considerable  efforts  and  private
resources in the acquisition of  test  vehicles  an  in contracted testing with
a  private laboratory,  in  an  effort  to  provide  EPA with  technical  infor-
mation  concerning  the  effects  of  the  W/A WAAG-Injection  System on  fuel
economy and emissions.

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