EPA-AA-TEB-511-81-14

                                                PB81-226706
EPA Evaluation of the Platinum Gasaver  Device under Section 511
     of the Motor Vehicle Information and Cost Savings Act
                              by

                        John C.  Shelton
                           May,  1981
                  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  the Platinum  Gasaver  Device 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;

    PLATINUM GASAVER Trade Mark

2.  Inventor of the Device and Patents;

    A. Inventor

       "A patent application  is  filed and is  pending.   The owner of  the
       patent rights is"

          Joel Robinson
          501 Washington Street
          Brookline, MA  02146

    B. Patent

       Until  the  U.S.  Patent  Office  acts  on  the  patent  application,
       Pegusus  Enterprises  declines  to  submit  this data  to  protect  the
       patent rights.

3.  Manufacturer of the Device:
    National Fuelsaver Corporation
    667 Washington Street
    Brookline,  MA  02146

4.  Manufacturing Organization Principals;

    "Not Applicable."

5.  Marketing Organization in U.S. making Application:

    Pegusus Enterprises
    6835 North Algonquin Avenue
    Chicago, 1L  60646

6.  Applying Organization Principals;

    President:          Jacek Helenowski

7.  Description of Device;

    A. Purpose of the Device (as supplied by Applicant):

       "The purpose of the device  is  to  improve mileage at least  20%  and
       to cut down on harmful polluting emissions."

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    B. Theory of Operation (as supplied by Applicant);

       "The Platinum  Gasaver process operates  on the  chemical  principal
       of  having platinum  present  where  fuel  is  burned.   The  process
       introduces  microscopic  quantities  of  platinum  into  the  engine
       along with the fuel and air while the  vehicle is driven.   With the
       platinum present in the combustion  chamber  of the engine,  a higher
       percentage of  each gallon of fuel  will  be burned, resulting  in a
       significant increase in miles per gallon."

       "Since the platinum injection system coats the engine  surfaces in
       a gradual process,  it is important to  be  aware  that your vehicle
       may  have to  be  driven  up  to  1,800 miles  before  the  platinum
       process becomes fully  effective."   See Attachment B  for additional
       information.

    C. Detailed Description of Construction (as supplied by Applicant);

       For detailed description  of  construction see packing contents and
       installation instructions, Attachment B.

8. Applicability of the Device (as supplied by Applicant);

    "Is applicable  to all automobiles and/or  all trucks with or without
    turbocharger,  fuel-injection  or  carburetor.   It  works   with  both
    leaded and  unleaded fuel  and  is complementary  with any  improvement
    gained by improved lubrication."

    The different model numbers are:

    SU-1  for gasoline powered automobiles that average  9 m.p.g.  or above
          before the device is installed.

    SU-2  for diesel  powered automobiles  that average  9 m.p.g.   or above
          before the device is installed.

    SU-3  for diesel  powered automobiles   that  average 6-8 m.p.g.  before
          the device is installed.

    SU-4  for diesel  powered trucks that  average 6-8  m.p.g.  before  the
          device is installed.

    SU-5  for diesel  powered  trucks that  average  5 m.p.g.  before  the
          device is installed.

9.  Costs (as supplied by Applicant):

    A 24,000 mile  supply of  the  platinum  costs $119  - and includes  the
    equipment for  two vehicles at no  extra cost.   A 12,000 mile  supply
    costs $69 - and includes the equipment  for one car at no extra cost.

10. Device Installation  - Tools and Expertise Required (as supplied  by
    Applicant);

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    A. Complete installation instructions are contained in Attachment B.

    B. Only simple hand tools are required for installation.

11. Device Operation (as supplied by Applicant):

    "Once  the  device  is installed  the  operator  must  add  a  bottle  of
    Gasaver concentrate every 6,000 miles.

12. Maintenance (claimed):
    None

13. Effects on Vehicle Emissions (non-regulated) (claimed);

    "At the absolute most, less  than  1/4  of one gram of platinum  will  be
    admitted to the atmosphere during one year (12,000 miles) of driving."

14. Effects on Vehicle Safety (claimed);

    This  device  does  not endanger  the  automobile  or  its occupants  or
    persons or property in close proximity to the automobile.

15. Test  Results  (Regulated  Emissions and  Fuel Economy)   (submitted  by
    Applicant);

    A. A  fleet  of  fifteen 1980  Chevrolet station wagons  with  305  cubic
       inch V-8  engines  were  tested  both  without  and  with  the  Gasaver
       Device installed.  The results are summarized  in Attachment  B.

    B. A Hyster Lift Truck (NASA 095675)  was  evaluated  in  August 1979 for
       total  hydrocarbons  and  fuel  economy.   The  results  of   this
       evaluation are included in Attachment C.

16. Discussion

    EPA corresponded several times (see Attachments A through  E) with the
    Applicant in  an attempt  to obtain  valid  test  data.    The  Applicant
    chose  not  to   provide   the  required valid  test  data  (!)  and  so
    informed  EPA  by  telephone  on  March 19,  1981.   EPA  had  previously
    notified  the  Applicant   that   EPA  was  obligated   to  complete  the
    evaluation  based  on  the   information  available  and   publish  the
    results.   The  requirement  for  completing  the  evaluation was  again
    discussed and the Applicant concurred.

17. Conclusions
    EPA  fully  considered  all  of  the   information   submitted   by  the
    Applicant.  The  evaluation of  the  "Platinum  Gasaver"  was  based  on
    that information.   The Applicant  did not  submit  any  valid  data  to
    support the  claims for increased  fuel economy  and lower  emissions.
    The Applicant  was advised  by letter  on several  occasions of  EPA's
    requirement that  Applicant's  submit  valid  test  data following the

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proper  EPA test  procedures^'.   Based  on  the  information  provided
by the Applicant, there  was  no technical basis to  support  any claims
for  a  fuel  economy  improvement  or  emission  reduction  with  the
"Platinum Gasaver".
   From EPA 511 Application test policy documents:

   Test Results (Regulated Emissions and Fuel Economy);
   Provide all test  information which is available on the  effects of
   the device on vehicle emissions and fuel economy.

   The Federal Test Procedure (40 CFR Part 86) is the  only  test which
   is recognized by  the  U.S.  Environmental Protection Agency  for the
   evaluation of vehicle emissions.  The  Federal Test Procedure and
   the Highway Fuel Economy Test  (40 CFR Part 600)  are the  only tests
   which  are normally   recognized  by  the  U.S.  EPA  for  evaluating
   vehicle   fuel   economy.    Data  which   have   been  collected  in
   accordance  with   other   standardized    fuel   economy   measuring
   procedures (e.g.  Society of Automotive  Engineers)  are  acceptable
   as supplemental data to the Federal Test  Procedure  and  Highway
   Fuel Economy  Data will  be  used, if  provided, in  the  preliminary
   evaluation  of  the  device.    Data  are  required  from  the  test
   vehicle(s) in both baseline  (all parameters set  to manufacturer's
   specifications)  and modified forms (with device installed).

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                            List  of Attachments

Attachment A              Copy of  December  17,  1980  letter  from  EPA to
                          Pegusus   Enterprises   containing   information
                          describing  the  process   to  apply  for  an  EPA
                          evaluation of a device.

Attachment B              Copy of  January  21,   1981  letter  from  EPA to
                          Pegusus  Enterprises  returning a  device  which
                          was received without an  application for  evalua-
                          tion.

Attachment C              Copy of  February  1,   1981  letter  from  Pegusus
                          Enterprises  with  an incomplete application for
                          evaluation of  device.   The application  did not
                          contain any valid test data.

Attachemnt D              Copy  of   March  11,  1981 letter  from  EPA  to
                          Pegusus   Enterprises   containing   an   initial
                          review of  the  application.   This  letter  again
                          notified    the   Applicant   EPA  would   require
                          additional   data/information  to   process   the
                          application.

Attachment E              Copy  of   March  11,  1981 letter  from  EPA  to
                          Pegusus Enterprises detailing  the type  of valid
                          test data  required  before  EPA  could test  the
                          device.

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                                                              Attachment A
December 17, 1980
hCri*JaesstefS'e-letrovskfc
Pegtisus Enterprises
6833 Horth Algonquin Ave,
Chicago, IL  6064&

Dear !ir. Helenowskl:

This letter is in response to your inquiry of 12/17/30 regarding an EPA evalu-
ation of the Platinum Gasaver.  The Environmental Protection Agency is charged
by  Congressional  raandate  to  evaluate  fuel  economy  and  emission  control
devices.   Vhile the  EPA does  not  actually  "approve"  such devices,  it  does
conduct evaluations for  the purpose of increasing the comraon knowledge in the
area.   For this  reason, the  outcome  of  any  testing  by EPA  beconres public
information.  It is this information which may be cited although no claims can
be  made  that  any EFA findings constitute  "approval"  of  the. device or systeia.

Enclosed  with this latter  is a  packet  of materials which  you will  need to
apply  for  an EPA  evaluation  of  your  device.  This packet consists  of 1) an
application format, 2)  a document entitled "EPA Retrofit and Emission Control
Device Evaluation Test Policy" and 3) a copy of the applicable Federal Regula-
tions.

In  order  for  the EPA to conduct an evaluation of your device, we must have an
application.   Once you  have reviewed  all the  documents  in the  packet,  you
should  prepare  an application  in  accordance  with  the guidelines   of  the
application fpraat.   A  critical part of the application is the substantiating
test data.  The required test results will have to be obtained at a laboratory
of  your  choice.   Such testing would be conducted  at  your expense.  A  list of
laboratories  which are  known  to have the equipisent  and  personnel to perform
acceptable  tests has  been included in the enclosed packet.  If you desire, we
can assist you in  the development of a satisfactory test plan.

There  are,   however,   several   aspects  concerning  tasting  at  an  outside
laboratory which I would like to bring to your attention at this tine:

     Hiniimura  Test  Requirements  -  Although  different  types  of  devices  may
     require  a  more  complex  test plan,  the  cdninum we  require involves two
     vehicles and  two test sequencea run in duplicate.  The vehicles should be
     selected from those listed in Table  1;  if possible.   Each vehicle is to
     be  set to manufacturer's tune-up specifications for  the baseline tests.

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The teats are conducted in a "back-to-back" manner,  once with the vehicle
in baseline condition and again with the device installed with no vehicle
adjustments between  tests.   If installation of the device also  involves
some  adjustments,  e.g.  timing,  fuel-air mixture,  choke  or  idle  speed,
another  test  sequence  with only  these adjustments  should  be  inserted
between the first  and  last.  Also as a  minimum,  the  test sequence shall
consist of  a hot-start LA-4 portion  (bags  1  and 2) of  the  Federal Test
Procedure  (FTP) and  a  Highway Fuel Economy Test  (KPET).  The details of
these  tests  are   contained  in  the  enclosed  packet.   Although  only  a
hot-start  FTP  is  required  to  minimize   the  costs   to  you,  you  ars
encouraged to have the entire cold-start test performed since any testing
and evaluation performed by EPA will be based on the complete FT? and you
isay; :wish-, to- know how a  vehicle  with  your device  performs; .over this
official  test.   As  a final  requirement,  the  personnel of  the  outside
laboratory you  select should  perform every element  of your  test  plan.
This  includes  preparation of the test vehicle,  adjustment of parameters
and installation of the device.

Submission  of  data  —  We require  that  all test  data obtained  from  the
outside  laboratories relative  to  your  application  be submitted  to  us.
This  includes any results you have which were declared void or invalid by
the  laboratory.   We also  ask that you  notify us of  the  laboratory you
have  chosen,  when  testing is  scheduled to begin,  what testa  you have
decided  to conduct,  allow  us  to  maintain  contact with  the laboratory
during  the  course of  the  testing,  and  allow the  test laboratory  to
directly answer any questions at any time about the test progr-ara.

Cost  of  the Testing - The  cost of the minimum  test  plan (two vehicles,
two  test   sequences  in  duplicate)  described above  should  be  less than
$2000  per  vehicle and less  than $4000  for the total test at any  of the
laboratories on the  list.  You will have to contact then individually to
obtain their latest prices.

Outcome of the Tests  - Although it  is  impossible  to accurately predict
the  overall  worth of  a device  from  a small amount of  testing,  we have
established  some   guidelines  which will help  you determine  whether the
test  results  with your  device should  be  considered  encouraging.   These
values have  been chosen  to assure both of us  that a  real  difference in
fuel  economy  exists and  that  we are not seeing only  the variability in
the  results.   The  table  below presents the minimum number  of cars that
need  to  be  tested  for  varying  degrees   of   fuel  economy  improvement
assuming  a  typical  amount of  variability  in  fuel  economy  measurement.
For a minimum test plan which  was  conducted  on a fleet of two cars, the
average improvement  should be at least 8%.  If at least an 8% difference
in  average  fuel  economy  can  be  shown, then  we  would  be  able  to say
statistically  at   the  80%  confidence  level  that  there  is  a  real
improvement.  Similarly,  we would  expect a minimum of 5% improvement for
a fleet of 5 vehicles.  Te^t results which display a significant increase
in emission levels should be reason for concern.

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           Minimum Fuel Economy Improvements versus  Size  of  Test Fleet

             gleet Size         Average Improvement  Required

                 28%
                 3                           7%
                 4                           6%
                 5                           5%
                10                           4%
                25                           22

Once we receive your application, it will be reviewed to  determine if it meets
the requirements  listed In the format.  If yonr application  ia not/complete,
we  will ask you- to submit  further .information or  data.   After "any missing
Information has been submitted, your application will be  reconsidered and once
it roeets our requirements, you vd.ll be advised of  our decision whether or not
EPA will perform  any confirmatory testing.  Any EPA testing will be performed
at  no cost.- to  you and you  will  be given the opportunity  to  concur with our
test  plan.   Once  this  testing is complete, an evaluation report will be writ-
ten.  If no further testing is required, the report will be written solely on
the basis of the test data submitted and our engineering  analysis.

Despite the current backlog and increasing number  of inquiries regarding fuel
economy device  evaluations,  the EPA intends to process your application in as
expeditious  a manner as possible.  We have established a goal of twelve weeks
from  the receipt  of a complete application to the  announcement of our report.
The attainment  of  this objective requires very precise  scheduling  and we are
depending on the  applicant to respond promptly to  any questions or to submit
any requested data.  Failure to respond in a  tinely manner will unduly delay
the  process.   In  the  extreme  case, we  may  consider lack of response  as  a
wichdrawl of the application.

I hope  the  information above and that contained in the enclosed documents will
aid you in  the  preparation of an acceptable application for an EPA evaluation
of  your device.  I will be  your  contact  with EPA  during this process and any
subsequent  EPA  evaluation.  My address is EPA, Motor Vehicle Eraission Labora-
tory, 2565  Plyicouth Road,  Ami Arbor, Michigan, 48105.  The  telephone number is
(313)   663-4299.   Please contact tne if you have any questions or.require any
further information.

Sincerely,
Merrill W. Korth,
Device Evaluation Coordinator
Emission Control Technology Division

Enclosure*

ECTD: TSB *gOUTHicd:X239i25&5Ply»»athgd rArvsArberM4 3105 j 12/17 /80

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                                                                               10
         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                               „ „                Attachment B
                        ANN ARBOR,  MICHIGAN  48105
                                                                   OFFICE OF
                                                             AIR. NOISE AND RADIATION
January 21, 1981
Mr. Jack M. Helenowski, President
Pegusus Enterprises
6835 North Algonquin Avenue
Chicago, IL  60646

Dear Mr. Helenowski:

On  December  17, 1980, I sent  to you a package of information  describing  the
process by which you  could apply for  an EPA evaluation of your  device,  the
Platinum Gasaver."^ Shortly  thereafter,  I received pne of your  devices in  the
mail; but  as  yet,  I have not received an application for evaluation from you.

In  order  for  the EPA to conduct an evaluation of your device,  we must have an
application prepared According  to the application format as described in  the
information I sent to  you on  December  17.   EPA is not taking  any action on
your device at this time.                                         • •  :-

Your device is being returned to you.  If EPA evaluates your device at a later
date, there will be no problem in procuring the necessary units for our tests.

Please  let me know  if you plan  to apply for an EPA evaluation.

Sincerely,



Merrill W. Korth
Senior  Project Manager
Test and Evaluation Branch

cc:  P. Hutchins

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PEGUSIIS   ENTERPRISES  MA™. GROUP
                                                             6835 NORTH ALGONQUIN AVENUE

                                                                    CHICAGO. ILLINOIS  80848
              16 December 1980
              Environmental Protection Agency
              Attn: Fuel Economy Evaluation Branch
              2565 Plymouth Road
              Ann Arbor/ Michigan 48105
              Gentlemen:

              Included  you  will  find a "Gasaver" device   (the   included
              model  is designed to work optimally in  an  automobile  which
              averages 15 mpg) for which I have distribution  rights  in  the
              greater  Chicago  area  to  include   sales  to   the   Federal
              Government/  its agencies/  and departments.  As  the  attached
              articles  from  Design  News/  Easy  Reader/  and The  Boston
              Phoenix  describe the process through which this device   can
              attain  approximately a 20% mileage  increase  on  a multitude
              of fuels/ I will not attempt to repeat the  same  facts  to  you
              in  this  letter.  What I do desire  is to have   the   process
              tested by your field and laboratory  facilities  so that I  may
              eventually  market  this  device  to  the  General    Service
              Administration  and  the Defence Procurement   Agency.  I   am
              confident  that your evaluation will prove  the  claims  found
              in the attached articles to be valid.

              I  have taken the liberty of also asking the  U.S. Army Tank
              and  Automobile  Command in Warren/   Michigan to conduct  a
              similar test,  but of course all my  future  prospects  depend
              upon  your  agency's evaluation of my product's  worth  as  a
              fuel saving device and non-pollutant.

              Included also is a copy of my manufacturer's  basic statement
              of our product's goals and success in obtaining  these  goals.
              I  would also like to point out that this process is already
              being  used  by the Armed Forces of  the State of Israel   to
              extend  the  range  of  their  Armoured  Wheeled and  Track
              Vehicles as well as their low performance  aircraft/  namely
              helicopters.   Both  Martin  Marietta  Corporation   and   the
              Transportation   Management  Corporation  have   tested   our
              product with very encouraging results.

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PEGBSUS    ENTERPRISES  MARK™* GROUP
                                                          6835  NORTH  ALGONQUIN AVENUE

                                                                 CHICAGO. ILLINOIS 60648
            You  will  find me readi ly avai lable to answer any  quesx-ions
            or  to provide additional supplies should  your tests require
            the  same.   I  may be reached by writing   at  the  following
            address:

                 Pegusus Enterprises
                 Marketing Group
                 P.O.  Box 59126
                 Chicago, Illinois 60659

            or by telephoning (312)  775-9359
                             (312)  774-0763
                             (312)  774-0784
            Sincerely,
            Jacek M. Helenowski
            President
            Pegusus Enterprises
            JMH/tkh

            Incl: 5 Articles

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                                                                              13
                 NATIONAL FUELSAVER CORP.
A.

B.

C.

D.

E.
  3.
  4.
           PACKING CONTENTS and INSTALLATION  INSTRUCTIONS
  1    GASAVER INSTRUMENT
  1    Small plastic "T" connector
  1    12 ounce bottle of GASAVER SOLUTION  (This 12 ounce bottle contains
      the same amount of platinum, 6,000 miles worth, that is contained in
      each of the 1 ounce bottles of GASAVER  CONCENTRATE. )
  1    1 ounce  bottle of GASAVER CONCENTRATE
  1    Plastic,  self-locking, releasable, strap
  1    6 foot length of rubber tubing
  1    Funnel
                                 	B
 GASAVER INSTRUMENT
 HORIZONTAL OPENING
 GASAVER TUBING
 "T"CONNECTOR
 VACUUM LINE OF VEHICLE
Pour the 12 ounce bottle of GASAVER SOLUTION into the GASAVER INSTRUMENT
very slowly to avoid spilling.  (The horizontal opening "B" looks like it is closed.
It is open to a diameter of less than 1/200 inch, which is proper. )
Find a safe and convenient location for the GASAVER INSTRUMENT under the hood
of your car.  Keep it away from the hot parts of the engine and exhaust.  Also avoid
sharp metal corners and the battery. Usually there is a suitable spot behind a headlight.
Secure the GASAVER INSTRUMENT.  We have provided a self-locking strap.
Locate a rubber vaccum line leading out of the base of the carburetor.  Usually the
one:to the choke or the air cleaner  is best.  Cut this tubing at a convenient spot and
insert two legs  of the plastic "T".
Connect one end of the GASAVER TUBING to the third leg of the "T", and the other
end to the Horizontal opening "B" on the instrument.
Race engine slightly to see bubbling in the GASAVER SOLUTION.  A bubbling rate
of 7 to 15 bubbles per 10 seconds is best.  If bubbling rate is  otherwise contact  your
supplier.
Your platinum GASAVER is now fully operational, although it may take from 200 to 1,800
miles to become fully effective.  After each 6,000 miles of driving the platinum
GASAVER SOLUTION will be down  only one  ounce, but all the platinum will have been
used.  Therefore,  after  each 6,000 miles of driving it is necessary to add one ounce
of platinum GASAVER CONCENTRATE  to the instrument to  keep  this process
operational.

                      DISTRIBUTED  BY:
                      PEGUSUS ENTERPRISES
                      Marketing Group
                      P.O. Box 59126
                      Chicago, Illinois 60659

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                      PLATINUM GASAVER TEST RESULTS
                                                                                    14
VEHICLE
NUMBER
59
63
53
51
56
64
60
55
68
50
62
66
57
54
65
AVERAGE
MILES PER
GALLON
WITHOUT
GASAVER
12.0
11.3
14. 1
13.0
12-'2 j
9.6
13.3
9.8
14.3
10.8
14. 1
15.8
14.4
13.1
12.9
12.7
- MILES PER
GALLON
WITH
GASAVER
17.8
16.6
20.7 .,;
18.8 j:
17. 1 .:
13.3
17.9
13.1
18.4
13.9
17.6
17.5
15.9
14. 0 ;
11.3 "./
16.3
PER CENT
IMPROVEMENT
WITH
GASAVER
48.3%
46. 9%
.46. 8%
44. 6%
40. 2%
38. 5%
34. 6%
33.7%
28.7%
28.7%
24. 8%
10.8%
10.4%
6. 9%
-12.4%
28.3%
Installation of the PLATINUM GASAVER, manufactured by NATIONAL FUELSAVER
CORPORATION of Brookline,  Massachusetts, was performed on 4/22/80 on the above
numbered fifteen 1980 Chevrolet station wagons with 305 cubic inch V-8 engines (odometer
readings between 15,070 and 38,784), owned and operated by TRANSPORTATION
MANAGEMENT CORPORATION of Medford, Massachusetts.

The "Miles par gallon with GASAVER" column shows the improvement starting on 5/9/80,
by which date each of the cars had been fully initialized with the platinum process.   The
test period ended on 5/26/80.  These test results are purely a function of miles travelled
and fuel consumed.  Other variables which may have influenced this study have not been
defined.

We,  the undersigned, officers of the two corporations  (Transportation Management Corp.
of Medford, Mass,  and National FuelSaver Corp. of Brookline,  Mass.) participating in the
above study do hereby attest to the accuracy of the data contained herein and do agree that
it may b«* made available for public dissemination, but only in its entirety.
    ay  «* mae avaa

    t+£+^S     S^~
Richard ZimrnernnaJn,  President
Transportation jfamagement Corp.
     G. bonig)i C.P.A. ,  V. P. & Controller
Trinspormtion Management Corp.
                                             o^
                                             ra
           Gordon, Fleet Manager
                                            Date:  June 18»  198°
National FuelSaver Corp. ,  667 Washington St., Brookline, Mass.  02146 TEL: 617/731-4444

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                                                                               15

                NATIONAL  FUELSAVER CORP.
                   667 VVASHiNGTON ST. 8ROOKLINE. MASS 02146 • TEL. 617/731-4444

Response to the nationalpublicity on our platinum GASAVER process has been
overwhelming.  It is currently in use or. thousands of vehicles across the country
with a success rate of better than 90%.                       '            •

The GASAVER operates, on the same^chemical principle that oil refineries use to
reduce their  fuel consumption dramatically - having platinum present where fuel
is burned. Combustion is much more complete and the oil companies are saving
billions of dollars annually.

We have adapted this principle to the  automotive engine.  Our process introduces
microscopic  quantities of platinum into  the engine along with the fuel and air while
you drive. With the platinum present in the combustion chamber of your car,  a
higher percentage of each gallon of fuel will be burned,  resulting in a significant
increase in miles  per gallon.

Enclosed with this letter are reprints from the EASY READER (Southern California),
the BOSTON  PHOENIX, and DESIGN NEWS (a national  engineering magazine).  These
articles  describe the GASAVER platinum process.  As you can see the equipment has
been improved and simplified so that  installation  time should not exceed fifteen minutes.

The GASAVER is highly effective on all types of vehicles - domestic or foreign, old
or  new.  It is the only platinum  technology that works with leaded or unleaded  gasoline,
or diesel fuel.   The GASAVER process  has not yet received the authorization of any
auto maker for new car use.  Therefore, if your  car is still under warranty, bo sure
to consult your dealer to insure  that the installation of'the GASAVER will not jeopardize
your warranty in any way.   It is also  important to be aware that your vehicle may have
to be driven up to 1,800 miles before  the platinum process becomes fully effective.

The vast majority of our customers are  getting 3 to 4 more miles per gallon.  A few
are getting as much as 6 to 8 more miles per gallon.  And a small group are not
saving at all; in which case we" refund thei-r-_money.  We are constantly working to
perfect our process.  Therefore, we  ask our customers to help us improve our process
by  reporting  back to us on their experience with the platinum GASAVER.

A 24,000 mile  supply of the platinum  costs $119. - and includes the equipment  for two
vehicles at no extra cost.  (A 12,000  mile supply costs $69. - and includes the equipment
for one car at no extra cost. )  Also included is an unconditional money-back guarantee.
If you would like to improve your gas mileage by  20 to  30%,  simply mail  us your check
or  Mastercharge or VISA information, or call us with your charge card information
or  C.O. D. instructions.  We pay all  shipping charges.

Should you require further information on our platinum GASAVER for engines  or on
our platinum FUELSAVER for industrial boilers, please call us.

                                                Sincerely,


                                                 ¥^
Mass, users add 5% tax.                         Jot:l Robinson, \Technical Director

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niiu QESicn msas

Metering device  'replaces'  catalytic  converter
Platinum solution simultaneously reduces fuel consumption and pollutants
David J. Bak, East Coast Editor
                                                                   16
Brookline,  MA—in  light  of  the
ever-threatening  energy crisis  and
ongoing battle against pollution, the
catalytic converter seems to offer
mixed blessings. True, it cuts down
on  pollution, but due to the added
backpressure  it  introduces  in the
car's exhaust line, it also lowers gas
mileage. And since  the  platinum
catalyst  is  deactivated in a  lead
environment,  more  expensive
unleaded gases must  be used.
  An improvement over the catalyt-
ic converter lies in a simple metering
device  invented  by Joel  Robinson,
technical director of  National Fuel-
Saver Corp. Although it operates on
the same chemistry as  the catalytic
converter,  the new device reduces
both  pollution and  fuel  consump-
tion.  Furthermore, it allows the use
of  either  leaded  or  unleaded
gasoline.
  Called the "Gasaver".  the device
is  similar  to  the unit  invented for
 furnace applications (See  Design
News, 5-8-78,  p.  82).  Its major
component is  a cylinder  partially
filled with a nonflammable, proprie-
tary platinum solution. Penetrating
the top of the cylinder is a tube open
to the atmosphere  and extending
into  the  solution.  A  brass  globe
yalve  and additional tubing.connect
the air space  in  the  top of  the
cylinder to the intake manifold.
  When the globe valve is cracked
open, the engine manifold draws a
portion  of  its  air   from   the
atmosphere  through the  catalytic
solution.  The platinum entrained in
the air bubbles  mixes with the gas,
causing more complete combustion.
By reducing the  amount  of  un-
burned  hydrocarbons and carbon
monoxide,  more BTUs  are drawn
from the same gallon of fuel and less
pollutants are emitted.
   According to Robinson, the unit
increases the number of miles per
gallon by about 20%, while prelimi-
nary estimates of the solution's cost
                                           ATMOSPHERE-
                                           GLOBE
                                           VALVE
                                  TO INTAKE
                                  MANIFOLD~l/N
                                  AIR SPACE-
                                  IN TOP OF
                                  CYLINDER
                                  AIR BUBBLES-
                                  WITH ENTRAINED
                                  PLATINUM
                                  MOLECULES
                                       PROPRIETARY	'
                                       PLATINUM SOLUTION
 Simple in construction, gas saving device consists of cylinder, globe valve, tubing and
 solution.
run about  4 to  5%  of the new
reduced gasoline  bill. Finally, be-
cause the physical quantities are so
small, less platinum will probably be
used in the lifetime of an automobile
equipped with a "Gasaver".
Additional details . . .  Contact Joel
Robinson,  National  FuelSaver
Corp., 667 Washington St., Brock-
line, MA 02146, 617-731-4444.

                                                                     Small In size, "Gasaver" easily fits into any
                                                                     open space in engine compartment.
                                    Editor's Note: During a recent, well-
                                    deserved vacation, ! had a chance to
                                    test the "Gasaver" in my own car. On
                                    the open highway up to Canada, I ran
                                    two separate mileage tests without the
                                    device, averaging 28 miles/gal. Coming
                                    home I used  the instrument to get a
                                    steady 32 miles/gal—a 14% increase.
                                    Subsequent tests have yielded readings
                                    up to 34 miles/gal.' This is consistent
                                    with Robinson's claim that once the
                                    valve surfaces become coated with a
                                    layer of  platinum molecules,  mileage
                                    readings should increase by about 20%.
                                    Due to the minute quantities of platinum
                                    being metered  into  the engine,  this
                                    process takes a while. This is the reason
                                    for the slightly lower initial.readings.
                              Reprinted from DESIGN NEWS January 8, 1979
                                 © 1979 by CAHNERS PUBLISHING COMPANY

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           Volume IX, Number 49
                                                      Reflections
                                                 from the South Bay
                                                                                                              August 16.1979
          Rick  Danko   •    Fireside Theater    *    Volleyball     •-   Writing, Photo Contest

          Believe  it  or  not:  a  fuel  saver  that   really  works
                                                 'LABORATORY TEST  RESULTS
                                                              YMf/iy-*
                                                               2L4&3
                                            MPO    |
                                                                                                                   21%
                                                                                                                   n%
by Frank Wicks

  "The biggest problem in  our business is the 10,000 people out
there who are selling water-injection systems." Joel Robinson says
of the fuel-saving industry.
  Robinson,  a  Massachusetts resi-
dent and inventor of a legitimate
fuel-saving device called, appropri-
ately  enough,   "Gasaver,"  com-
plains that the gimmick-type gas-
saving  devices  that  are  on  the
market make it difficult for those
who make genuine breakthroughs
in this field.
  "There are  101  water-injection
systems around,  but they're  all
phonies. Can you tell me why water
would help combustion? Water puts
fire out; it doesn't help it to burn
better," Robinson says.
  Another gas-saving  gimmick that
recently surfaced involved  a man
who claimed that for  10 dollars he
would  install a device  which,  he
said, would increase mileage by 25
percent. Unfortunately, it  turned
out that all he would do was attach
a rubber cord to the gas pedal and
anchor it below the dashboard, thus
making it  more difficult to press
down the accelerator.
  It's not  too  difficult  to  believe
Robinson when he says,  "When-
ever we  start  talking to  anyone
about our method, we have to give
them 10 minutes to stop laughing
before we  can explain  why  it
works."
  Actually, the Gasaver operates on
a  principle  long   recognized  by
chemists and engineers. However,
it   wasn't   until   recently  that
Robinson's  invention  made  it
possible to successfully apply  this
principle to the automobile.
  When gasoline is burned in the
standard  internal-combustion  en-
gine, usually only about 70 percent
of  it  will  burn effectively.   The
remaining 30 percent, which is lost,
contains two basic items:  hydro-
carbons (gas vapor that did  not
burn), and carbon monoxide  (par-
tially burned gasoline).
  In 1974,  automobile manufactur-
ers  began  installing catalytic  con-
verters on all new cars. The catalytic
converter,  working on  the  same
principle as  Robinson's Gasaver,
burns the hydrocarbons and carbon
monoxide  by bringing  them   into
contact with platinum at combus-
tion temperatures.
  This  process  promotes a  more
thorough  and  complete burning,
thus producing  fewer  pollutants.
Unfortunately, this process  takes
place outside of the engine, and the
energy produced is lost; actually, it
robs the engine  of energy because
of the "backpressure" it produces.
  Gasaver's West Coast distributor,
Jack  Leopold   of  Torrance,  ex-
plained how the Gasaver works.
"The  Gasaver injects  a platinum
vapor directly into the engine where
the  catalytic action of  the platinum
promotes faster and more complete
combustion — with 15 to 25 percent
savings in gasoline.
  Robinson  added,   "We're   not
doing  anything  new  chemically;
we're simply changing the location
of where the process occurs."
  The  platinum-injection  system
coats the engine surfaces in a grad-
ual process. The longer the process
is continued, the less energy is lost
in the exhaust. Although results can
be seen almost immediately,  Leo-
pold says the process won't reach
its full capacity until  after., about
1800 miles.
  Robinson, a graduate of Boston
University as an industrial  engineer
who has successfully  applied the
catalytic process to oil-burning fur-
naces in industrial facilities,  says
chemists have been trying  to intro-
duce platinum into the engine for
years.
  "Theoretically,"  he says, "there
are three ways to use the platinum.
One is to paint the surfaces with  it
like they do with the catalytic con-
verter. However, it is not possible to
coat engine parts.  The second way
is to add it to gas, but the  chemists
haven't figured how to do  that yet.
In  our method, we bring the  plati-
num into the engine with the incom-
ing air.
  "If either of the first two  methods
were possible, it would demand the
use of unleaded gas. Lead imme-
diately destroys the effect of  plati-
num, and that's why catalytic con-
verters need unleaded gas. But our
process  can be retrofitted to old
cars and can use leaded gas."
  Dr. Herbert Kaesz, professor of
chemistry at UCLA, confirmed the
fact that the Gasaver is based on es-
tahlished chemical principles.  "The
idea is a sound one.  I'm  just  sur-
prised that they are the only ones on
the market with it  ... I'm going to
put one  on my car."
  New  that a gallon  of  gas  has
reached  a  dollar  in  price,  the
Gasaver might seem like a logical re-
placement for the catalytic  con-
verter.  Enough  of  the solution to
last for 24,000 miles sells  for  $119.
                                                                                                                      si
                                                                                                                   UETT"«
However,  neither  Robinson  nor
Leopold profess any desire in chal-
lenging the powers that be.
  "We are not  at all interested  in
giving the auto  companies, the oil
companies, or the platinum  com-
panies that kind of fight. They like
the catalytic converter, and we're
too small  to get into that kind  of
competition," Robinson explained.
  Robinson  says that while the
general public may be hesitant to try
out the device, those people in the
technical community have been his
best customers.  "So far, most  of
our customers have been engineers'
because they understand the prin-
ciples behind it."
  On a recent trip to San Francisco,
Easy Reader staff member Robert
Triptow took the opportunity to test
the  Gasaver  on  his  1966 Volks-
wagen Bug.
  Driving an unloaded car up High-
way 5 without the device; he used
two tankfuls of gas and averaged 27
miles per gallon.
  On his return trip, Triptow took
the  longer route down  Highway
101. With the device attached and
"the car loaded with belongings  he
had picked up,  he used just under
two tankfuls and averaged 32 miles
per gallon.              ""     ~~
  Although  his  mileage  increased
by  over 18  percent,  according  to
Gasaver's promoters,  his  future
mileage should increase even more
as  the engine parts gradually  be-
come  coated  with the  platinum
molecules.
  Further- information  concerning
the   Gasaver   product   may   be
obtained  by• contacting National
FuelSavef Corp., 667 Washington
Street, Brookline, Mass. 02146, Tel:
617/731-4444..

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                                                                                                                   18
                                              jTHE BOSTON PHOENIX, SECTION FOUR, AUTOMOTIVE, FEBRUARY 19,  1980
Relocating    the    catalyst
 Putting  the  platinum  before  the  carb
by Paul D. Lehrman
  Every so often, another miracle gadget that promises to cut
your gasoline bills in half shows up in the back pages of your
favorite picture magazine or flashes a toll-free number at you
during Rhoda  reruns. These expensive  toys eventually get
dumped onto the -front pages of Consumer Reports, where they
are invariably characterized as useless, so it's nice to find a com-
pany that not only considers that kind of marketing "cheap," but
also makes a product that  gives every indication that it can
deliver.
  Using platinum as a catalyst for increased efficiency in com-
bustion is no longer a revolutionary idea, but applications of the
principle that will save consumers money seem to be farthest from
the minds of those who run major oil companies and automobile
manufacturers. However, for Joel Robinson,  Technical Director
of National FuelSaver Corporation,  it's the first thing.
  The product that Robinson and his tiny staff have developed,
which is called the Gasaver, is a simple system that comprises a
special plastic jar, a T-connector, six feet of 5/16 inch hose, 'a
12-ounce bottle of platinum solution that gets poured into the jar,
and a one-ounce bottle of concentrated solution to "recharge" the
system after about 5000 miles.  Its purpose is to introduce
platinum into your car's engine in such a way that the metal coats
the cylinders and pistons, allowing your engine to burn fuel more
completely and efficiently. If Robinson's figures are right, soon
after his system is installed in an  automobile,  its polluting
emissions are reduced by better than 10 percent and gas mileage is
improved by 15 to 25 percent.
  Robinson,  who' received a bachelor's  degree  in industrial
engineering from BU in 1964, has been working on his system for
two-and-a-half years. His early professional experience included
working  as a manufacturer's representative overseas, selling fuel
additives that were designed to improve the  efficiency of refin-
eries, steamship and other heavy-industry boilers. The chemicals
he sold were expensive, and the process by which they were intro-
duced and maintained in the systems was difficult and costly. He
looked around for ways to improve the situation, and during a
phone conversation with a friend who was a  chemist  for Exxon,
heard the word "platinum." "From that point on," he says, "I was
on my own."
  After proving that the platinum injection process worked on
boilers as well as engines, Robinson decided, to concentrate his
attentions in the automotive world and developed the Gasaver
system. The first prototype had been built in April of 1978. The
following January,  a trade magazine published a description of
the system and some preliminary test 'results that  confirmed
Robinson's claim of 20 percent mileage improvement. He subse-
quently received some 2000 inquiries from engineers and mechan-
ics all over the country. Out of that group, he managed to talk 500
into spending .540 each on a 20,000-mile supply of the platinum
solution, with the hardware lent at no charge. With these first 500
customers. National  FuelSaver was able  to start its first
production run, in April of '79.
  Gasaver is now in 'its  third production model; as Robinson
makes improvements in the hardware, he replaces all the units in
the field. Improvements have been made in the solution, too,
which at first tended to freeze at temperatures below 25 degrees
Fahrenheit. Changes incorporated last October have solved this
problem.
  The chemical principle behind Robinson's system is simple and,
in application, far from unique. The plastic container that holds
the platinum solution is strapped inside the engine .compartment
wherever practical. The bottle has an air-intake port and an outlet
with a hose coming from it, which the user  splices into any
vacuum-line that feeds all the engine's cylinders. The vacuum in
the line sucks air through the plastic bottle, causing it to percolate
through the platinum solution and exit through the hose  as air
carrying minute bits of the platinum compound. From there, the
air is passed into the engine block where it coats the cylinder head
and pistons. It doesn't stay there forever, so it has to be replen-
ished at a measured rate.
  Once inside the engine, the catalytic action  of the platinum
reduces the heat and time necessary for the gasoline to burn itself
completely down to carbon dioxide and water. Given that the
time that the gasoline has in the cylinder and the temperature of
the engine are both unchanged, the result is less carbon monoxide
and unbumed hydrocarbon residue and more power per unit of
fuel.
  Why haven't others thought of this? Well, others have, but for
different uses. The catalytic converter, a muffler coated  inside
with platinum, has been compulsory on all new cars since 1975; it
is another application of the same technology. The converter is
designed to reduce hydrocarbon emissions by causing unburned
gasoline to burn before it can be carried into the atmosphere  as
exhaust. However, because the converter does its thing after the
engine does its, the energy (heat  and pressure) produced in it is
wasted, while the engine  is actually forced to work harder  to
counteract the back-pressure that the burning and expanding
gases produce in the exhaust system. The catalytic converter will
work only in the presence of unleaded fuel,  as lead passing
through the exhaust deactivates the platinum in the  muffler.
Unleaded fuel is more expensive and energy-consuming  to
produce and it yields fewer BTUs per gallon than regular leaded
gasoline. Robinson's Gasaver will work in the presence of leaded
gasoline.  Robinson  also  maintains that his  system uses the
precious metal much more efficiently,  and that the amount of
platinum a catalytic converter uses up in 40,000 or 50,000 miles
will keep the Gasaver going for 150,000 miles.
  Finally,' scientists  at the Brookhaven National  Laboratory
reportedly developed a technique for coating engine parts  them-
selves with platinum during manufacture and brought the idea to
General Motors.  The platinum was not self-replenishing,  -how-
ever, and the report  is that it all disappeared after 100 miles of
engine use.
                (Continued on back page)

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 Page 2
  Other companies have made attempts at dissolving the plati-
 num in the gasoline itself, but Robinson claims that it just will not
 work — that his consultants have concluded the substances are
 simply incompatible. The Gasaver solution is the first successful
 attempt at injecting platinum into the air stream. The makeup  of
 the solution itself is still a  well-kept secret, as the  patent is still
 pending.
  Since his  first production run, last April, Robinson has sold
 about 3,000 Gasaver systems at the retail level, getting the mes-
 sage across"by way of magazine, articles and advertisements  in
 alternative-energy and trade magazines. He refuses to advertise
 on UHF television, maintaining that it would render his product
 indistinguishable from others he says don't work and  that  it
 wouldn't be an effective way to get potential customers to trust
 him.
  To wholesalers, however, business has been even better; his
 figures indicate that nearly  40QQjunits. have been sold.
   Felix Turley of Hyde Park owns two  Dodge vans. Even after
 numerous trips to his dealer, he was getting only eight miles per
 gallon out of his new one, a '79 with a small V-8 engine, though
 the EPA sticker said he should be getting 14. He heard Robinson
 discuss Gasaver last spring on  a radio talk show, and  subse-
 quently visited National FuelSaver's Brookline office.
  With Robinson's unit installed, Turley's van delivered just
 under 13 mpg, an increase of nearly 60 percent, until the day he
FuelSaver's Joel Robinson at work
                                                                          opened his engine compartment and discovered that the jar was
                                                                          gone. "I didn't support it on the bottom — just had it strapped to
                                                                          the sides — and I guess it just jostled its way out," he said. 'The
                                                                          hose and the top of the thing were still there, but the rest of the jar
                                                                          and all  the solution were lying on a street somewhere." He went
                                                                          back to the company to buy another  unit, but when Robinson
                                                                          looked at his file, he told Turley to keep his money and go home
                                                                          and wait for the  mail; Robinson had just taken delivery  of a
                                                                          production run of an improved version of the bottle, and had sent
                                                                          one out along with a 5000-mile platinum  supply to every one of
                                                                          his customers.
                                                                            On February 1  of this  year Robinson was forced by the  sky-
                                                                          rocketing cost of  all precious metals, to  raise  the price of the
                                                                          Gasaver. 24 thousand miles worth of the solution now costs $119.
                                                                          The company gives a money-back, no-questions-asked guarantee,
                                                                          and still lends the equipment free. A quick calculation shows that
                                                                          in a car that gets 15 mpg, at 51.30 a gallon, the 20 percent saving
                                                                          that Robinson considers average works out to  a net savings of
                                                                          better than S297 over 24,000 miles.  And that's if the price of
                                                                          gasoline doesn't go up.

                                                                            The Gasaver is available directly from the factory as well  as
                                                                          from distributors and dealers throughout  the country.

                                                                            For more information contact:  National FuelSaver Corp.t 667
                                                                          Washington St., Brookline, Mass. 02146.  Tel. 617/731-4444.
a Gasaver device

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                                                            Attachment C

                                                                        20

PEGUSUS   ENTERPRISES MARKETING GROUP
                                                   8835 NORTH ALGONQUIN AVENUE

                                                         CHICAGO. ILLINOIS 00646
        Pebuary  1,  1981
      MR. MERRILL  W.  KORTH,
      DEVICE EVALUATION COORDINATOR
      EMISSION  CONTROL TECHNOLOGY DIVISION
            Dear Mr.  Korth

          Here  is  tjje  official a-p-p-t-ication format under Section 511
          for the
-------
                                                                   21

PEGUSUS   EITERPRISES
                                                   6830 NORTH ALGONQUIN AVENUE

                                                         CHICAGO, ILLINOIS 6OBA6
           Identification of Organization Making Application:

           SEE  ABOVE
                   I
           Identification of Applying Organization's Principals:

           Jacek  Helenowski  -- President
           The  above mentioned wil^represent the organization
           in communications^with the EPA.

           Description of Device:

           a. Purpose of the device:
               To  improve mileage at least 20% and to cut down
               on  harmful  polluting emissions.

           b. Theory of Operation:

             See articles sent 16.Dec.80

           c. Detailed Description of Construction and Operation.

             See articles sent 16.Dec.80

           Applicability of the device;

           Is applicable to all automobiles and/or all trucks with
           or without turbocharger,  fuel-injection or carburator. It
           works  with both leaded  and unleaded  fuel and is complementary
           with any improvement gained by improved lubrication.

           The  different model numbers are:

           SU-1   for gasoline powered automobiles that average 9m.p.g.
                  or above before  the device is installed.

           SU-2   for diesel powered automobiles that average 9m,.p.g.
                  or above before  the device is installed


           SU-3   for gasoline powered   trucks     that average 6-8 m.p.g
                  before the device  is installed

           SU-4   for diesel powered trucks that average 6-8 m.p.g.
                  before the device  is installed

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                                                                       22

PEGUSUS   ENTERPRISES MARKET.KG GROUP
                                                   6835 NORTH ALGONQUIN AVENUE

                                                         CHICAGO. IL.L.INOIS SO646
              SU-5   for  diesel powered trucks that average 5 m.p.g.
                    before  the..device is  installed

       10.     Device Installation:

                    One  full page of the  articles sent 16.Dec.80 explained
                    the  installation procedure.

       11.     Device Operation:
                   Once  device is installed the operator must add
                   every 6,000 miles one  bottle of   GASAVER CONCENTRATE.

       12.     Device Maintenance:

                   NONE

       13.     Effects on Vehicle Emissions(non-regulated)

                   At the absolute most less than % of one gram
                   of Platinum will be admitted to the atmosphere
                   during one  year  (12,000 miles) of driving.

       14.     Effects on Vehicle Safety:

                   This  device does not endanger the automobile
                   or its occupants or persons or property in
                   close proximity to the automobile.
              Test  Results:
       15.
              See  articles  sent  16.Dec.80
              In  addition to  the  articles mentioned above  I
              have included in this  application a copy of  the
              results  of -the- Martin  Marietta Corp. which tested
              the  device  for  113  hours  to obtain fewer hydrocarbons
              emitted  and fuel savings  of.34.7%.
       Sincerely,
       Jacek  Helenowski
       President
       Pegusus  Enterprises

       Enclosure:  2

-------
                                      i.N K.AKJ -v;v\ - r'.i
                                                                                 	23-..

131
Test for Total
Willie Jarricek
Hydrocarbons
•
••ODIl
Off.*.
3663
'0»ll I
i5 — wu ** / y /
V ^

       KC output  from  Kyster Lift Truck (NASA 095575)
i0-"'
fy3C**34, OCCl*






O'U (U'O

• ll«'-». f>V.
CuuIlK ^e I tUf
\
f •

r— 5
i ..i
1 — i mi«
1 - ! K»;T1
r~r
! _ I

        Total  hydrocarbon 58.0 pptf AV at start of. test.

        Total  hydrocarbon 51.5 pprn AV after 113 hours use time.
         0.98 hours/gallon start of test.

         1.32 hours/gallon average after 113 hours use time,


         34.7 % Savings."          \   •
          R.
                  \7uO-l6
                   JL..Q.
                Liry :.;;
                                                                   OfiCl.
                          3726

-------
                                                                                24
                                                                       Attachment  D
          UNITED STATES  ENVIRONMENTAL PROTECTION  AGENCY
  j
..J                       ANN ARBOR. MICHIGAN  48105

-------
                                                                            25
During our  review of your submission, we  also noticed a magazine  adver-
tisement which  stated,  "This product  is marketed with  the authority  of
the EPA".  Such a  statement is not based on  fact  since EPA  has  not  autho-
rized or approved  the  Platinum Gasaver.   I  suggest  that  your  delete  any
such references  to EPA from your  advertising  until  after  our  evaluation
has been completed.  If you have any questions or require  further  infor-
mation, please contact me.

Sincerely
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch

Enclosures

cc.  J. Shelton

-------
                                                                 Attachment E
March 11, 1981
f'sr. Jack Ilelenowski, President
Pagusus Enterprises
6835 North Algonquin Avenue
Chicago, IL  60646

Duar Mr. Kelenowaki: '

Although  you have  already  applied  for  an  EPA  evaluation of  the  Pla it
Gasaver, I  am enclosing a complete set of our policy documents to assure that
there is a  clear understanding of the EPA requirements for private laboratory
data.   A  separate  letter  is  also  enclosed,  discussing  our  preliminary
evaluation  of  your  application.   The  Environmental  Protection  Agency  is
charged by  Congessional rnandate to evaluate fuel economy and emission control
devices.   While  the  EPA does  not actually  "approve"  such devices,  it does
conduct evaluations  for the purpose of increasing the comn»n knowledge in the
area.   For  this  reason,  the  outcome  of any  testing  by EPA  becomes- public
information.  It is this information which may be cited although no claims can
be made  that any EPA findings  constitute "approval"  of the device or system.

Enclosed with this  letter  is  a  packet  of snaterials  which you will  need to
apply  for  an EPA evaluation of  your device.  This packet  consists  of 1) an
application  format,  2)  a document entitled "EPA Retrofit and Emission Control
Device  Evaluation  Test  Policy"   and  3)  a  copy of  the  applicable  Federal
Regulations.                                                          •

In order  for the EPA to conduct an evaluation of your device, we cms t have an
application.   Once  you have reviewed  all the  documents  in the  packet, you
should  prepare  an  application  in  accordance  with  the  guidelines   of  the
application  format.   A  critical part of  the application is the substantiating.
test data.  The required test results will have to be obtained at a laboratory
of your  choice.   Such testing would  be  conducted at  your expense.  A  list of
laboratories  x^hich are  known  to have the equipment  and  personnel  to  perform
acceptable  tests  has been included in the enclosed packet.  If you desire, we
can assist in the development of a satisfactory test plan.                -    -

Once we receive your application,  it will be reviewed to determine if it meets
the  requirements lieted in the fornat.   If  so, you  will be  advised  of our
decision whether or not  EPA will perfora any  confirmatory testing.   Any EPA
testing  will be  performed  at  no  cost  to  you, and  you  will be  given the
opportunity  to  concur with our test plan.  Once  this testing is complete, an
evalation  report  will   be  written  solely  on  the   basis  of  the  test data
submitted and our engineering analysis.
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                                                                                    27
There  are,  however,   several   aspects  concerning  testing  at  an  outside
laboratory which I would like to bring to your attention at this time:

     Minimum  Teat  Requirements -  Although  different  types  of devices  may
     require a  more complex  test  plan, the  minimum we require involves  two
     vehicles and two test sequences run in duplicate.  The vehicles should be
     selected from  those  listed in Table 1;  if  possible.   Each vehicle is to
     be  set  to  manufacturer's tune-up specifications for  the  baseline tests.

     The tests are conducted in a "back-to-back" manner, once with the  vehicle
     in baseline condition and again with the device installed with no  vehicle
     adjustments  between  tests.   If installation of  the device also involves
     some  adjustments,  e.g.  timing,  fuel-air mixture,  choke or  idle speed,
     another  test  sequence  with only  these  adjustments  should  be inserted
     between the  first  and last.  Also as  a  minimum, the  test sequence shall
     consist of  a hot-start LA-4 portion  (bags  1 and 2)  of  the Federal Test
     Procedure  (FTP) and  a Highway Fuel Economy  Test (HFET).   The details of
     these  tests  are   contained in  the  enclosed  packet.   Although  only  a
     hot-start  FTP  is  required  to  minimize  the  costs  to  you,   you  are
     encouraged to have the entire cold-start test performed since any  testing
     and evaluation performed by EPA will be based on the complete FTP  and you
     nay  wish   to  know how  a  vehicle  with  your  device  performs  over this
     official  test.  As  a  final  requirement,  the personnel of  the  outside
     laboratory  you select  should  perform every element  of  your  test  plan.
     This  includes  preparation of the test vehicle,  adjustment of parameters
     and installation of the device.

     Submission  of Data  - We  require  that all  test ciata obtained from  the
     outside laboratories  in support  of your application  be  submitted to us.
     This  includes  any  results you have which were declared void or invalid by
     the  laboratory.   We  also  ask that you  notify  us of the laboratory you
     have  chosen,  when testing is  scheduled to begin,  what  tests you have
     decided  to  conduct,  allow  us  to  maintain contact  with  the laboratory
     during  the  course of  the  testing,  and  allow the  test  laboratory  to
     directly answer any questions at any tine about  the test program.

     Cost  of the Testing  -  The cost  of the  mininmra  test  plan (two vehicles,
     two  test  sequences  in  duplicate)  described  above  should be  less than
     $2000 per  vehicle and  less  than  $4000 for the  total  test  at any of the
     laboratories on'the  list.  You will huwe to contact  then individually to
     obtain  their latest prices.

     Outcome  of  the Tests - Although it  is  impossible to accurately predict
     the  overall worth of a device  frow  a  small  amount  of  testing,  we have
     established  some  guidelines  which xd.ll  help  you determine  whether the
     test  results with your device should  be considered  encouraging.  These
     values  have been  chosen  to assure both of  us  that a real difference in.
     fuel  economy  exists  and  that we are not seeing only the variability in
     the  results.  The  table  below presents  the minimum  number of cars that
     need  to  be  tested   for  varying  degrees  of   fuel   economy  improvement
     assuming  a  typical  amount of variability  in  fuel  econcciy measurement.

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                                                                                   28
     For a minlKura  teat  plan  which was conducted on  a  fleet of  two  cars,  the
     average improvement should be  at  least 3%.   If at  least an  3% difference
     in  average  fuel  economy can  be  shown,  then we  would be  able to  say
     3tastically at the 802 confidence  level that there  is a real  improvement.

     Similarly, we- would expect a minimum of 5% improvement  for  a fleet of  5
     vehicles.   Test results  which  display  a significant  Increase in emission
     levels should be reason for concern.

          Miniuuia Fuel Econoroy Improvements  versus  Size  of Test Fleet

          Fleet Size                   Average Improvecent Required
               2                                  37.
               3                                  7%
               4                                  6%
               5                                  SZ
              10                                  4%
              25                                  2%

Once we receive your application,  it will  be reviewed  to determine if it meets
the requirements  listed  in the format.  If your application is  not  complete,
we  will ask you  to suboit  further information or data.  After  any missing
ir.furination fcas been submitted, your application will  be reconsidered and once
it neets our requirements,  you will be ndvised of our decision  whether or not
EPA will perform  any confirmatory testing.   Any E?A testing will be  performed
at no  cost to  you  and you will  be given the opportunity  to concur with our
test  plan.  Once  this  testing  is complete, an  evaluation report will  be
written.  If no further testing is required, the report  will be  written solely
on the basis of the test data submitted and our engineering analysis.

Despite  the current  backlog and increasing nunber of  inquiries  regarding fuel
economy  device  evaluations,  the EPA intends to process  your application in as
expeditious a  manner  as  possible.  We have established  a goal of twelve weeks
from the receipt  of a complete application to the announcement  of our report.
The attainment  of  this objective  requires very  precise scheduling and we are
depending on the  applicant to respond promptly  to  any  questions or  to subrait
any requested  data.   Failure  to respond in a  tinely  manner will unduly delay
the  process.    In  the extreme  case, we  may  consider  lack of  response  as  a
withdrawal of the application.

I hope  the information above and that contained in the enclosed  documents will
aid you  in  the preparation of an acceptable application for an  EPA evaluation
of your device.   I will be your  contact  with EFA during this process and any
subsequent  EPA  evaluation.   Ify  address  is  EPA,  Motor  Vehicle   Emission
Laboratory,  2565 Plynouth  Road,  Ann  Arbor,  Michigan,  43105.   The   telephone
nunber  is  (313)  663-4200. . Please contact tre  if you have any questions or
require  any further information.
         i-
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Rrgnch

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                                   Table 1

                 Suggested Test Vehicle Engines for 511 Applicants

The following engines are suggested as suitable candidates for the application
of  a  511  process  or  device.   These  engines  represent  over  50%  of  the
powerplants built by the manufacturer of interest.  By choosing one or more of
these engines, the  applicant  is assured that the process/device is applicable
to a representative  portion  of the fleet for the model year of interest.   The
ease of obtaining a test vehicle is also enhanced because of the popularity of
these engines.  Any  make  or  model produced by  the  manufacturer may be chosen
if  equipped  with  a  suggested  engine  and  an  automatic transmission.   The
following list of  suggested  engines is broken  down by year and manufacturer.
The  ranking of the  engines  for  any  given manufacturer  is  by sales  volume.
                                                           29
1979 Model Year

General Motors
  350 CID V8
  305 CID V8
  301 CID V8

Chrysler Corp.
  225 CID L6
  318 CID V8

Ford Motor Co.
  302 CID V8
  140 CID L4
1978 Model Year

General Motors
  305 CID V8
  350 CID V8
  231 CID V6

Chrysler Corp.
  318 CID V8
  225 CID L6

Ford Motor Co.
  351 CID V8
  302 CID V8
  200 CID L6
1977 Model Year

General Motors
  350 CID V8
  305 CID V8
Chrysler Corp.
  318 CID V8
  225 CID L6

Ford Motor Co.
  302 CID V8
  351 CID V8
  400 CID V8
1976 Model Year

General Motors
  350 CID V8
  305 CID V8
Chrysler Corp.
  225 CID L6
  318 CID V8

Ford Motor Co.
  351 CID V8
  140 CID L4
  250 CID L6
American Motors
  258 CID L6
  232 CID L6
American Motors
  258 CID L6
American Motors
  258 CID L6
American Motors
  258 CID L6
     1975 Model Year

     General Motors
       350 CID V8
       400 CID V8

     Chrysler Corp.
       225 CID L6
       318 CID V8

     Ford Motor Co.
       351 CID V8
       250 CID L6
       302 CID V8
        1974 Model Year

        General Motors
         350 CID V8
        Chrysler Corp.
         225 CID L6
         318 CID V8

        Ford Motor Co,
         140 CID L4
         351 CID V8
         400 CID V8
        1973 Model Year

        General Motors
         350 CID V8
        Chrysler Corp.
         318 CID V8
         225 CID L6

        Ford Motor Co.
         351 CID V8
         400 CID V8
         122 CID L4
     American Motors
       258 CID L6
       232 CID L6
        American Motors
         258 CID L6
         232 CID L6
        American Motors
         258 CID L6
         232 CID L6

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