EPA-AA-TEB-511-81-15
EPA Evaluation of the Treis Emulsifier Device Under
Section 511"of "the Motor Vehicle Information
and Cost Savings Act
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, Environmental Protection Agency, Office of Mobile
Source Air Pollution Control, Emission Control Technology Division, 2565
Plymouth Road, Ann Arbor, MI 48105, (313) 668-4299 or FTS 374-8299.
by
Thomas J. Penninga
July, 1981
Test and Evaluation Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
U.S. Environmental Protection Agency
-------
EPA-AA-TEB-511-81-15
6560-26
ENVIRONMENTAL PROTECTION AGENCY
[40 CFR Part 610]
[FRL
FUEL ECONOMY RETROFIT DEVICES
Announcement of Fuel Economy Retrofit Device Evaluation
for "Treis Emulsifier"
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice of Fuel Economy Retrofit Device Evaluation.
SUMMARY; This document announces the conclusions of the EPA evaluation
of the "Treis Emulsifier" device under provisions of Section
511 of the Motor Vehicle Information and Cost Savings Act.
-------
BACKGROUND INFORMATION: Section 511(b)(l) and Section 511(c) of the
Motor Vehicle Information and Cost Savings Act (15 U.S.C. 2011(b))
requires that:
(b)(l) "Upon application of any manufacturer of a retrofit device (or
prototype thereof), upon the request of the Federal Trade Commission
pursuant to subsection (a)r or upon his own motion, the EPA Administrator
shall evaluate, in accordance with rules prescribed under subsection (d),
any retrofit device to determine whether the retrofit device increases
fuel economy and to determine whether the representations (if any) made
with respect to such retrofit devices are accurate."
(c) "The EPA Administrator shall publish in the Federal Register a
summary of the results of all tests conducted under this section,
together with the EPA Administrator's conclusions as to -
(1) the effect of any retrofit device on fuel economy;
(2) the effect of any such device on emissions of air
pollutants; and
(3) any other information which the Administrator determines to
be relevant in evaluating such device."
EPA published final regulations establishing procedures for
conducting fuel economy retrofit device evaluations on March 23, 1979
[44 FPv 17946].
-------
ORIGIN OF REQUEST FOR .EVALUATION: On February 17, 1981, the EPA received
a request from Treis International for evaluation of a fuel saving device
termed "Treis Emulsifier". This Device is designed to generate a
gasoline, water-alcohol emulsion. The water is in finite droplet form,
evenly dispersed throughout the gasoline and is claimed to prevent
premature ignition or knock, and allow a more complete combustion. This
is claimed to result in improved fuel economy, torque, and engine life.
Availability of Evaluation Report; An evaluation has been made and the
results are described completely in a report entitled: "EPA Evaluation
of the Treis Emulisfier Device Under Section 511 of the Motor Vehicle
Information and Cost Savings Act," report number EPA-AA-TEB-511-81-15
consisting of 35 pages including all attachments.
Copies of this report may be obtained from the National Technical
Information Service by using the above report number. Address requests
to:
National Technical Information Service
U.S. Department of Commerce
Springfield, VA 22161
Phone: Federal Telecommunications System (FTS) 737-4650
Commercial 703-487-4650
-------
Summary of Evaluation
EPA fully considered all of the information submitted by the Device
manufacturer in the Application. The evaluation of the "Treis
Emulsifier" device was based on that information. Additional information
and test data was requested of the Applicant. No response to this
request was received.. Without the requested information, a thorough
evaluation of the device cannot be made. Most importantly, the
application did not describe the actual "Treis Emulsifier" device. Thus,
an analysis of the feasibility of the device is not possible.
The test data submitted with the application raises many questions but
does not indicate a significant fuel economy improvement. The testing
performed is contradictory and inconclusive. The test procedures used
are not designed to indicate improvements in exhaust emission levels and
urban fuel economy. The test procedures and test vehicles used do not
agree with the installation instructions submitted with the application.
The Applicant was requested to submit additional information concerning
the testing data. No response was received by EPA.
Therefore, there is no technical basis to support any claims for a fuel
economy or emission improvement due to the use of the "Treis Emulsifier".
-------
FOR FURTHER INFORMATION CONTACT: Merrill W. Korth, Emission Control
Technology Division, Office of Mobile Source Air Pollution Control,
Environmental Protection Agency, 2565 Plymouth Road, Ann Arbor, Michigan
48105, 313-668-4299.
Date Edward F. Tuerk
Acting Assistant Administrator
for Air, Noise, and Radiation
-------
EPA Evaluation of the Treis Emulsifier 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;
Treis Emulsifier
Model A (for engines rated 15 mpg or better by EPA)
Model B (for engines rated 10-15 mpg by EPA)
Model C (for engines rated 10 mpg or less by EPA)
2. Inventor of the Device and Patents:
A. Inventor;
Paul R. Goudy, Jr.
2016 East Wood Place
Shorewood, WI 53211
B. Patent; Pending
3. Manufacturer of the Device;
Model Specialities, Inc.
300 E. Oak Street
Oak Creek, WI 53154
4. Manufacturing Organization Principals;
Arthur Gavlitta - President
Frank Ramon - Vice President
Stanley Lancar - Secretary/Treasurer
5. Marketing Organization in U.S. making Application;
Treis International
20700 Miles
Cleveland, OH 44128
6. Applying Organization Principals;
Ken Landis - President
Paul Goudy - Vice President
Bruce Landis - Vice President
7. Description of Device;
A. Purpose of the Device (as supplied by Applicant);
"To increase gas mileage and prolong engine life through more
efficient combustion."
-------
EPA Evaluation of the Treis Emulsifier 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:
Treis Emulsifier
Model A (for engines rated 15 mpg or better by EPA)
Model B (for engines rated 10-15 mpg by EPA)
Model C (for engines rated 10 mpg or less by EPA)
2. Inventor of the Device and Patents:
A. Inventor:
Paul R. Goudy, Jr.
2016 East Wood Place
Shorewood, WI 53211
B. Patent: Pending
3. Manufacturer of the Device;
Model Specialities, Inc.
300 E. Oak Street
Oak Creek, WI 53154
4. Manufacturing Organization Principals;
Arthur Gavlitta - President
Frank Ramon - Vice President
Stanley Lancar - Secretary/Treasurer
5. Marketing Organization in U.S. making Application;
Treis International
20700 Miles
Cleveland, OH 44128
6. Applying Organization Principals;
Ken Landis - President
Paul Goudy - Vice President
Bruce Landis - Vice President
7. Description of Device;
A. Purpose of the Device (as supplied by Applicant):
"To increase gas mileage and prolong engine life through more
efficient combustion."
-------
B. Theory of Operation (as supplied by Applicant);
"The device generates a gasoline, water-alcohol emulsion
(water-alcohol less than .5% by volume). The water in finite
droplet form, evenly dispersed throughout the gasoline, performs
the following functions:
1. Elevates the apparent ignition temperature of gasoline:
The ability of water to absorb large amounts of heat (in
comparison to gasoline) allows it to cool the gasoline during
compression, thus preventing premature ignition or knock.
The heat absorption of the water is greatly enhanced by its
physical form since it's dispersed in droplets, not as a
monomolecular vapor. This difference between the Treis device
and available vapor injectors allows the use of much smaller
percentages of water to accomplish the same cooling effect.
The difference is evident when one considers that the Treis
device requires "heat of vaporization" to be absorbed in the
combustion chamber to transform water droplets to water vapor.
2. More Complete Combustion:
The water droplets expand rapidly as they change to the vapor
state. This expansion (explosion) causes the gasoline
surrounding each droplet to be rapidly dispersed and thus a
more even dispersion (vaporization) of gasoline is accomplished
with the addition of water. The net result is an increase in
the exposed gasoline surface available for combustion. More
complete burning follows.
NOTE: This point (#2) is more applicable to carbureted
automobiles where fuel tends to be dispersed in generally
larger droplets than fuel injected autos.
3. Increased Torque:
The effects of #1 and #2 together tend to produce an even
(generally circular) flame front which by eliminating spiked
flame patterns (associated with knock) prolongs the burning
process in the combustion chamber. Peak pressures are produced
later than normal (at or near mid-stroke of the crankshaft) and
therefore torque is increased.
4. Cleaner Combustion Chamber:
Point #1 necessarily produces this result. Extended engine
life is expected, therefore, due to cleaner rings and valves.
C. Detailed Description of Construction (as supplied by Applicant):
1. Construction:
"See schematic drawing enclosed. The device was designed to
withstand at least 300 psi." (NOTE: No schematic drawings
were enclosed with the 511 Application.)
-------
2. Operation:
"The device acts as an open ended water trap. It traps slugs
of water (added to gas tank), disperses the water throughout
the device and then allows the gasoline to scrub the water out
of the device, thus forming an emulsion.
The invention relates to the addition of an additive, such as a
mixture of water and alcohol, to the fuel of an engine. The
additive is added upstream of the engine carburetor or fuel
injectors. According to the invention a mixing apparatus
schematically depicted in the accompanying drawings mixes the
fuel and the additive to form a long lasting emulsion.
Preferably, the mixer is of the type known as a static or
motionless mixer to minimize the amount of energy used to
effect mixing. The emulsion has a leaning effect enabling
advancement of the spark before top dead center, an amount that
improves fuel economy."
8. Applicability of the Device (as supplied by Applicant);
"The device is applicable to all gasoline powered automobiles.
Sizing: See part #2 "Marketing Identification".
NOTE: The device has not been tested on diesels, however, it is
expected that if applied to diesels the results would be:
a. Increased mpg
b. Increased torque
c. Cleaner engine internals
d. Quieter operation
e. Reduction in particulate emissions"
9. Costs (as supplied by Applicant);
No information was supplied in the application.
10. Device Installation - Tools and Expertise Required (as supplied by
Applicant);
"The device should be installed in the fuel-line following the fuel
system bypass (back to tank), but before the carburetor or the fuel
injectors. The device has 1/4" female pipe threads and therefore can
be easily mated to any fuel-line using standard fittings available at
auto parts stores.
NOTE: The device does require disconnecting the fuel-line at the
carburetor, therefore, it is suggested that, a) the battery be
disconnected prior to installation, b) the engine be cold and, c) a
qualified mechanic perform the installation."
11. Device Operation (as supplied by Applicant);
"After installation, 1/2 pint of 45% alcohol to 55% distilled water
should be added to the gas tank. The car should be driven for
100-200 miles and then the initial spark advance should be set
-------
10
between 12 and 15 B.T.D.C. No further water should be added until
engine knock is heard upon acceleration. At that time, an additional
1/2 pint of mix should be added. Repeat as required to prevent
engine knock."
12. Maintenance (claimed);
"None; except adding water."
13. Effects on Vehicle Emissions (non-regulated) (claimed);
"None"
14. Effects on Vehicle Safety (claimed):
"Reduces chance of fire in carburetor and intake manifold through
reduced volatility of gasoline."
15. Test Results (Regulated Emissions and Fuel Economy) (submitted by
Applicant);
The applicant submitted data was in three parts, which are described
below:
a. Bendix Corporation Data:
The Bendix data consists of 9 tests which, based on mileage
calculations, appear to be Highway Fuel Economy Tests. The data
indicates that standard dilute emission measurements were taken.
In addition, fuel and water consumption were measured. The tests
were run for varied spark timing and water consumption settings.
The test vehicle was a 1979 Buick Regal with an 231 CID, V-6
engine. A summary of the test data is given below. Actual test
data sheets are enclosed as an attachment.
Test No. HC CO
NOx
Fuel
Economy
MPG Timing
1
2*
3
4
5
6
7
8
9**
•
1.
1.
•
•
1.
•
1.
•
773
425
570
898
984
175
891
024
036
2.
2.
1.
2.
1.
1.
1.
1.
*
938
622
793
184
513
457
934
343
033
1.
JL •
i.
A. •
i.
i.
i.
i.
i.
205
142
495
263
693
542
215
648
493
21.
21.
23.
22.
25.
25.
23.
25.
25.
996
315
946
646
167
665
667
378
932
Mfg.
Mfg.
Mfg.
Mfr.
Mfr.
Mfr.
Mfr.
Mfr.
Mfr.
Spec.
Spec.
Spec.
Spec.
Spec.
Spec.
Spec.
Spec.
Spec.
+ 10°
+ 10°
+ 10°
+ 10°
Water
Consumption
0
36 ml.
15 ml.
0
0
10 ml. (50% Ethanol)
0
10 ml. (50% Ethanol)
20 ml. (50% Ethanol)
Fuel
Consumption
(grams)
1319.7
1368.8
1233.17
1303.8
1186.88
1134.00
1238.33
1163.2
1151.5
* noted as in doubt due to equipment malfunction
** catalyst added
-------
11
b. Second Set of Data
This data is prefaced by a letter to the applicant from the
inventor which describes HFET data taken by an "EPA approved
laboratory" which is not named. Twelve HFET tests were run. Both
engine-out and catalyst-out measurements were taken. Measurements
of water/alcohol mixture consumed were also made. Several
attachments listed on the prefacing letter were not included in
the application. One of the attachments presents data taken
previously at Systems Control, Inc. (SCI). SCI has since been
recognized as a laboratory capable of performing appropriate
tests. The SCI data also indicates several attachments describing
the data which were not included in the application. A summary of
the catalytic converter output data follows:
Test No
10
11
12
21
22
23
31
32
33
34
41
42
<
HC
.113
.092
.049
.135
.033
.028
.075
2.411
.019
.023
.023
.032
»ms/mi
CO
5.227
3.383
1.954
4.081
1.553
1.012
2.200
63.654
.627
.744
1.126
1.104
NOx
1.409
1.584
1.622
1.553
1.119
1.645
1.612
.938
1.047
1.706
1.788
1.703
Fuel Consumed/ H20
MPG per mile in ml.
21.478
21.380
20.423
21.300
27.239
19.956
20.607
19.114
30.574
18.948
19.666
19.222
123.6
120.1
128.6
133.2
132.3
135.1
138.9
113.2
133.3
143.5
137.4
139.5
0
13
21
12
75
63
35
40
42
40
31
58
% Water
in Fuel
_
.8
1.2
.7
4.1
3.4
1.8
2.5
2.3
2.0
1.6
3.0
% Alcohol
in Water
_
-
10
10
20
5
5
-
-
_
-
-
A copy of the test data is attached.
c. The SCI - Environmental Engineering Division Data
The SCI data consists of a baseline FTP and HFET sequence followed
by an HFET run with the device. The SCI data summary discusses
"Due to some problems with the device; it was decided not to run
the full FTP". Therefore, only single HFET results are available
for comparison. The tests were run on a 1978 Buick Regal. Six
attachments noted in the SCI summary which presented the actual
exhaust emission results were not included in the application. A
summary of the test data is shown below. The SCI data is attached.
Test Type HC
1975 FTP
HFET
HFET
.70
.13
.08
gram/mile
CO
9.5
2.5
.88
NOx MPG Comments
1.4 17.0 Baseline
1.6 22.4 Baseline
1.13 22.4 with Device
16. Testing by EPA:
No testing was performed by EPA. Until the additional requested
information was supplied by the applicant, planning a confirmatory
-------
12
test program was not possible.
17 . Analysis
A. Description of the Device:
The purpose and theory of operation of the device were described
on the Application. The device itself was never described since
the noted attachments were not included with the application. A
letter was sent to the Applicant on March 14, 1981, requesting the
missing information. The letter also requested information
regarding the test data, the device operation, and presented a
test plan which would demonstrate the effect of installing the
Treis Emulsifier. A copy of the letter is attached. The amount
of water-alcohol consumed - less than 0.5% by volume - is much
less than required by most available water injection systems to
prevent engine auto-ignition. A calculation assuming steady state
flow, adiabatic flame temperature, and stoichiometric air fuel
ratio indicates that the .5% liquid water added to the fuel will
lower the adiabatic flame temperature less than 5.0°F. Such a
small benefit will not significantly influence auto-ignition
characteristics of an engine. The fact that the emulsified water
is a liquid state instead of a vaporized state will increase its
ability to absorb heat. As noted above, however, the net heat
absorbtion of .5% t^O (liquid) by volume is very low.
The description of the device also indicates that vaporization of
the liquid droplets increases vaporization of the gasoline.
Because gasoline vaporizes at lower temperatures and higher
pressures than water it is not apparent why vaporization of
gasoline would be improved by introduction of water droplets. The
claims for increased torque, cleaner combustion chamber, and
extended engine life are based on lower combustion chamber
temperature and better vaporization. No data was submitted to
demonstrate increased torque, cleaner combustion chamber, and
extended engine life. Therefore, no analysis of the validity of
these claims can be made.
B. Applicability of the Device;
Without a description of the device, no analysis of the
applicability of the device can be made.
C. Device Installation:
Without a description of the device, no analysis of the device
installation instructions can be made.
D. Device Operation;
The operational instructions raised several questions which were
not answered by the applicant. Most importantly, what about
vehicles with manufacturer basic ignition timing specifications
above 12°-15° B.T.D.C.? The adjustments required to retard the
-------
13
timing to 12°-15° B.T.D.C. would definitely be in the direction to
reduce fuel economy. The instructions do not indicate a course of
action if "engine knock" is not heard upon acceleration.
The operational instructions do not appear to be applicable to all
of the vehicles for which the device is sold. The instructions as
submitted will result in many confused customers.
E. Device Maintenance:
No analysis of the device maintenance statements can be made
without a complete device description.
F. Effects on Vehicle Emissions (non-regulated);
No analysis of the device's impact on unregulated emissions can be
made without additional information.
G. Effects on Vehicle Safety:
Without a complete description of the device, an analysis of the
safety aspects of the device can not be made.
H. Test Results Supplied by Applicant;
The submitted data was run at three different laboratories.
Bendix Laboratory Data
The data is summarized above and enclosed as an attachment. The
testing has several problems which reduce it's ability to
demonstrate the effect of the "Treis Emulsifier".
1. The test vehicle was a 1979 Buick Regal (V-6, 231 CID engine) with
only 111 miles at the beginning of testing, and 249 miles at the
end. Vehicle emissions and fuel economy are known to be very
unstable during the first several hundred miles. Most vehicle
manufacturers accumulate a mimimum of 4000 miles before emission or
fuel economy testing is attempted. Improvements in fuel economy and
emissions are expected as engine friction is reduced, piston rings
seat, and valve sealing improves. Readings taken at 100 miles have
limited applicability to in-use vehicles.
2. The test procedure used in the Bendix testing appears to be a
Highway Fuel Economy Test (HFET) which is used to determine highway
fuel economy. The emissions of vehicles are measured in a different
test - the Federal Test Procedure (FTP). The HFET emission numbers
cannot be correlated to FTP (urban) emission levels. The fuel
economy improvement noted on the HFET cycles again have limited
applicability to urban driving. Because the HFET test was used, the
Bendix data does not indicate how the "Treis Emulsifier" would
improve vehicle emissions as compared to emission standards or how
the device would improve urban fuel economy. In addition, the HFET
tests run by Bendix Corporation do not appear to have been correct.
According to the data, nine HFET sequences were run. Each HFET cycle
-------
14
should consist of a preconditioning cycle and a sample cycle with a
total mileage of about 20.4 miles. The Bendix data indicated that
13,8 miles were put on the car between the first and the last test.
Assuming the odometer readings were taken at the beginning of the
HFJET test, nine HFET tests would require a minimum of 163 miles.
Therefore, it appears that Bendix did not follow the Federal Register
specified HFET test requirements. This problem again reduces the
comparability of the Bendix data to other HFET and FTP test results.
3. The Bendix data, except for Test #9, appears to be run without the
catalyst installed. Since most in-use vehicles do have catalysts,
the non-catalyst emission data is not really relevent to what effect
the Treis Emulsifier would have on emission levels.
4. It appears that the operational instructions supplied in the
application were not followed during the Bendix testing.
a. The volume of water/alcohol mix is stated in the device
description to be less than .5% by volume. Assuming a gasoline
density of 6.138 Ibs./gallon, the percentage of water by volume
contained in the fuel used in Bendix Test Numbers 2, 3, 6, 8, and
9 were 3.58%, 1.65%, 1.209% 1.209%, and 2.36%. Therefore, the
amount of fluid consumed during the testing was significantly
above the upper maximum described in the applications.
b. The application device operation instructions indicate that
after device installation, 100-200 miles should be driven, after
which the timing should be adjusted. The Bendix data indicates
111 miles on the odometer at the beginning of testing and 249
miles at the end of testing. During the 138 miles, the vehicle
•was apparently altered from stock condition by addition of the
device three times. Therefore, the 100-200 miles requirement
could not have been followed during the Bendix testing.
c. The application specifies that the initial spark timing should
be set between 12° and 15° B.T.D.C. The Bendix data indicates
that testing was performed at manufacturer's specification and at
manufacturer's specifications plus 10°. A search of manufacturer
basic timing specification for 1979 Buick Regal 231 CID, V-6
engines indicate that 15° B.T.D.C. is the normal specification.
The Bendix testing at manufacturers timing specifications appear
to be in compliance with the application operating instructions
but the Bendix testing at "MFR. SPEC. + 10°" would be at 25°
B.T.D.C., which is significantly different than what would result
from following the operating instructions. Therefore, the Bendix
testing with the "MFR. SPEC. + 10°" is not really applicable to
the "Treis Emulsifier" as described in the application.
5. The results of combining like tests in the Bendix data to
calculate the average fuel economy improvement are given below:
-------
15
# of Tests
3
1*
1
2
1**
HC
.854
1.570
.984
1.099
N/A
CO
2.252
1.793
1.513
1.400
N/A
NOx
1.228
1.495
1.693
1.595
1.493
MPG
Carbon
Balance
22.77
23.946
25.167
25.522
25.932
Fuel
Consumed
Gravimetric Comment
1287.3
1233.17
1186.9
1148.6
1151.5
*left out questionable data due to equipment malfunction.
**CATALYST ADDED
Baseline
15 ml of water
consumed
(+) 10° Timing
(+) 10° and
10 ml added
(+) 10° and
20 ml added
Comparison of Bendix Data
Comparison
Treis Emulsifier using
15 ml. of water with
mfr. spec, timing
Treis Emulsifier using
10 ml. of water with
timing advanced 10°
Treis Emulsifier using
20 ml. of water with
timing advanced 10°
HC
CO
NOx
MPG
(+)83.84% (-)23.77%
Fuel
Consumed
(+)4.02%
(+)11.69% (-) 7.49% (-) 5.79% (+)1.41% (+)3.32%
N/A
N/A
(+)3.04% (+)2.98%
The cover letter on the Bendix data combines the fuel economy
benefit of "Treis Emulsifier" and that of advancing the timing
10°. To analyze the "Treis Emulsifier", these two changes must be
separated. When this is done, the improvements in fuel economy
due to the "Treis Emulsifier" are shown to be from 1.41% to
5.16%. The emission results are varied on HC, but do show a
consistent reduction in CO and NOx.
These averages do not indicate the scatter found in the data.
Taking the three baseline tests as an indication of the testing
accuracy, the following Coefficients of Variation are found.
HC
CO
NOx
Coefficient of Variation
8.22% 22.22% 2.53%
MPG
3.70%
Fuel
Consumed
3.35%
These calculations indicate that the variability of testing would
mask improvements in fuel economy less than 3.70%.
-------
16
The improvement in fuel economy noted for Treis Emulsifier
compared to these numbers, is not very significant.
In summary, the Bendix data has several problems which preclude
its ability to demonstrate the effect of the Treis Emulsifier.
The testing itself was not applicable to the Treis Emulsifier
since the operating instructions were not followed.
B. Second Set of Data
The analysis of this data will focus only on the converter out
emissions. There are again several problems with this test data.
They are:
1. The HFET testing procedure was used. This procedure is, as
noted above in the Bendix data analysis, not applicable to
emission standards or urban fuel economy.
2. The amount of water consumed during the test is tabulated in
the test result summary above. The volume consumed is
considerably higher than the .5% volume specified in the
application. The applicability of the data to the Treis
Emulsifier data submitted in the application is thus in question.
3. One test in particular seems to be in error. Test #32 shows
extremely high HC and CO and extremely low carbon balance fuel
economy. The fuel consumed, however, shows much higher than
normal fuel economy. An equipment malfunction or a serious
transcriptional error is the only explanation for this data.
4. The scatter of the data is very bad. The carbon balance fuel
economy varies from 18.95 to 30.57 mpg for apparently equivalent
tests. The NOx, HC, C02 reading are not quite that scattered
but do not allow very meaningful analysis. There appears to be no
correlation between emissions and the amount of liquid consumed.
5. The "fuel consumed" values and the carbon balance fuel economy
values do not appear to agree. The "fuel consumed" values
demonstrate a severe fuel economy penalty for those tests where
water/alcohol mixtures were used (up to 16.1% penalty). The
carbon balance fuel economy data show an increase in fuel economy
for two tests (26.82% and 42.35%). Other tests show a similar
lack of correlation between apparent duplicate measurements.
6. No information was supplied by the applicant as to the
laboratory which performed the testing. The laboratory is simply
described in the application as "an EPA approved Laboratory". The
EPA does not approve laboratories. No information on the vehicle
tested, the ignition timing, or device installation was supplied.
7. This test data does not demonstrate if the Treis Emulsifier
works as claimed. No conclusions on fuel economy are possible
because of the problems noted above. There does appear to be a
reduction in HFET HC and CO. The HFET NOx values appear to rise
slightly.
-------
17
C. The SCI Laboratory Data
The SCI data is tabulated above and is included as an attachment.
The SCI data is included as an attachment to the "other"
laboratory data covered in Part B. The baseline FTP cannot be
compared as no FTP measurements were taken with the device
installed. The SCI cover letter notes several problems that were
encountered which might have interfered with running a full 1975
FTP Cold Start Emission Test. No explanation as to the nature of
these problems was included in the application. Clarification of
this point was requested in the EPA March 16, 1981 letter to the
Applicant. The results then are two HFET tests. There were
several problems noted with this test data:
1. Once again, HFET tests were run which, as noted above, have
little value in comparison of emission levels or urban fuel
economy.
2. Only one test was run in each configuration. Thus, no
evaluation of test-to-test variability could be made.
3. The results indicate identical fuel economy - 22.4 mpg for both
"baseline" and "with device" configuration. Thus, the data
indicates then, no improvement in fuel economy due to the Treis
Emulsifier.
4. The SCI letter notes five attachments include actual test data
printouts. The five attachments were not included in the
application.
5. No description of the test vehicle, the device used, the timing
specifications, or the 100-200 miles required accumulation was
included.
The conclusion to be drawn from this data is that two HFET's
did indicate a reduction in HC and CO while fuel economy
remained constant. The testing does not verify the claims made
about the "Treis Emulsifier". Additional testing is required.
I. EPA Testing of the Treis Emulsifier
Because the Applicant submitted insufficient test data, a test
plan was developed which, when complete, would demonstrate the
results of installing a Treis Emulsifier. This plan was included
in the March 16, 1981 letter. No response was received. Because
EPA testing is used strictly in a confirmatory role, no EPA
testing was performed. Several other devices tested by EPA have
introduced water or water/alcohol mixture into the combustion
chambers. In sufficient quantities, such additives can extend the
detonation limits of the engine which, in turn, allows
modifications which can improve fuel economy. The Treis
Emulsifier introduces less than .5% mixture by volume. The EPA
testing on other devices noticed no change in fuel economy for
such small amounts of additives. Therefore, it is unlikely that
-------
18
the .5% additive addition for the Treis Emulsifier will impact
vehicle emissions or fuel economy.
18. Conclusions
The applicant submitted insufficient test data to prove that the
"Treis Emulsifier" would improve fuel economy. The majority of the test
data submitted was not applicable to the device described in the
application. EPA testing of similar devices has failed to show a fuel
economy benefit. Therefore, it is unlikely that installation of the
Treis Emulsifier would result in a fuel economy benefit. No conclusions
concerning effect on safety or unregulated emissions can be made.
-------
19
List of Attachments
Attachment A "Bendix Corporation" Data.
Attachment B "Other Laboratory" Data.
Attachment C "SCI Laboratories" Data.
Attachemnt D March 14 1981 EPA letter from Charles Gray to Applicant,
-------
Attachment A
June027, 1979
Mr. Ken Landis
Treis International
2179 South Belvoir
Cleveland, Ohio 44118
Dear Ken, -
Enclosed you will find copies of the test data as received from the emissions
labs of the Bendix Corporation located at 900 West Kaple Road, Troy, Michigan
48084. Additionally, .you will find fuel consultation, water consumption and i-jne
change data listed at,the bbjttom of each test document. All but one test have
been validated as accurate. Testvf2 - Bendix £9062002, is in doubt because of
an equipment malfunction, however, it is included for completeness.
The data shows that use of the device produced an EPA mileage increase of 12%
(compare test #4 - Bendix #9062104 with test #8 - Bendix #9062208). This was
also confirmed by an actual fuel consumption reduction of 12%.
Further analysis indicates that the mixture dispersed by the device operates in
the following manner:
1. It effectively cleans the combustion chamber. This accounts for approx-
imately 50% of the total benefit and produces a residual effect when the
water is not added.
2. It raises the octane rating of the fuel and thus allows tune changes
(spark advance) that would not be possible with current available low
octane gasoline. This accounts for approximately 35% of the total benefit.
3. The mixture produces more thorough atomization during the compression
stroke and thus more complete combustion results. This provides the
remaining 15% of the total benefit.
The principles of operation as listed above show why the device will have a
varying effect on different engines depending on their displacement, cleanliness,
and compression ratios. Since the vehicle tested (a 1979 Buick Regal 231 V-6)
had only 100 miles on it, cleaning was pointless, thus it is expected that the
results shown are minimums.
Ken, with the exception of minor metering development, the device is ready to
go to market. It will certainly be improved in the future, but currently, it is
sufficiently developed to produce a measurable mileage increase of 10 to 30%.
At your convenience, I would be pleased to explain the tests and conclusions in
further detail.
Sincerely,
Paul R. Goudy, Jr.
-------
T
EMISSION TEST HE POUT NtlHTU-CE
ECONNOMY HUN
tiAiU. JiAW.DATA . .. .
V()LUMI£= 4160.
HH= 6H.OOO ..
AUSOLUTE HUMiUiTy= /5.00000
_CU2_iiAMHLE= I *.*,
C02 AMl3IfcNT= 0.060
HI; . SAMHLH= 122.040
HC AML)ItNT= 6.690
CU...SAMRLE=
CO AMUIENT
4. b'J
AMUIbNT
0.300
..6/2U/.7yT.lMEr-.-_4iiiUP.M — TEST..1
CELL= N
()D()METEH= I 11 .O
COMMENTS
BASE LINE
VOLUME-
TU
1NEHTIA= J500.0
A/J 12.3
60.0
NOX ************** fiHAtyS ««B«n-m«ni««»M ******** 0|j.'./Ml *****H»HH MHG
COHK f' HC CO NOX C02 HC CO NOX ECONOMY
._.. ..1.000 ..O.ab3 7.m'< •jii.iion 12.34" 4L'»".2/« 0.7'/3 2^iL3a I . 20'j _ ->\
FUEL CONSUMPTION
1319.7 GRAMS
•-WATER-CONSUMPTION 0—
SPARK ADVANCE
MFG. SPEC.
-------
EMISSION TEST HtHOHl.JIUU.TH.CEU 0/20/7^TIME=__5.i.3UPM - TEST-2-- —
ECUNNOMV HUN
HAW DATA ... . . .
VOLUME3 4157.
...HH = 55.000 .. _.. •.
AbSOLUTE IIUMIL)1TY= 54.00000
_.'... CU2 SAMHLfc= .. . .l.yUU
C02 AMBIENT" O.U50
HC SAMPLE= 223.210 __ 1
HC AMbIENT= 9.530
CO SAMHLE= 212.230 .._ - _-_... _... - -
' CO AMbIENT= 5.340
NOA AMbIENT= 6.370 "'
HUN#= 906.20.0.2 CAIM= HEGAI UHEHATJ1R= Tli DHIVFl<= UM _ -'••"-^ "_••••• .__.;
CELL- N OUOMEfEH= 125.0 INEHT1A= 3500.0 HP A/I 12.3 60.0
COMMENTS "~ " """"• "" :•-'
TEST NO, TWO . A-
WATEH
y.OLUME5.4_L57. TFMPFI>ATU»P= 75. P»FSSIII«1****_URS/M!_..**.******.* ^>G 5
C(JHH K HC CO NOX C02 HC CO NOX ECONOMY I
__L^J21i 2.622_ 1 .J/J2 .-.2.1.3.1-5- ? to
. • * 10
- F.UEL. CONSUMPTION .. 1368.8-GRAMS
•"- WATER CONSUM'PTION " " "36 ""ml """."
SPARK ADVANCE MFG. SPEC.
-------
J.
• -
EMISSION TEST
ECONNOMY HUN
NDKTH
-------
«••*!
1
J
•
i. _____
-
EM I 1313 I OH TEST HEWMLJHafflLCEL
tCONNOMY KUN
a/2±/.lalIM£=__6UJi'M
..... .TEST .A
bAO! HAW DATA
VOLUME" 4170.
|
.FUEL. CONSUMPTION..
WATER-CONSUMPTION'
SPARK ADVANCE
..13_Q.3.,.8_.GBAMS.
0
MFG. SPEC.
-------
EMISSION TEST HE POUT. _Nl)UTH_C.ELL _6/2.L/7.i>T.IME?_.Jill.2dKM - .TEST 5
ECONNOMY KUN
liAi/.L-HAH DATA
VOLUMb"= 4IV4.
Kri= 57.000
ABSOLUTE HUMIDITY*5 bO.UUUUU
C02 AMbiENT= 0.040
hC...SAMPLli= ... I1J3.23U
HC AMUIENT= O.V20
.CO SAMPLb= ..Mi
CO AMliltNT*" I .OOU
J^OX..aAMHLE= ....... Uii.62U.
NOX AMUltNT= 0.30U
TH
CELL= N ()DOMETl:IJ= 215.0 INEK'fIA= 3bUO.O HP A/I 12.3 60.0
COMMENTS
06-21 -7V TEJi.T_JiOJ_.IUHEJ:
UAiili-LING
. .YULUMH" 4194. TI-MPliKATUUEs 7.b... _.!JJ?liS^UIiH=. - V.tiU.
******.********.iJUAi& WH."!»:•««• ••"•I"" ******.»* CJ»fj/Ml ******»««u
COKK H HC CO NOX C02 HC CO NOX ECONOMY
JJAU1. .0.8^5... U.B73 U).()74 m.^ol I JJ_336__3!i5S. iiVJ Q..ytt4 U5J.3—-U
FUEL CONSUMPTION 1186.88 GRAMS
WATER-CONSUMPTION
SPARK ADVANCE " MFG. SPEC. + 10°
-------
EMISSION TEST KPfOuT N»»TH C.Plt ______ 6/2 J/.7VIiMEE_l.tj .42PM
ECONNOMY HUN
TEST. 6 ___________________
UAOl.JlAH..DA'1'A . .. .......
VULUML= 4205.
___ «H= 57.000 . .
ABSOLUTE HUMIDITY =
_ CU2_SAI4HLE= __
50.00000
C02 AMbIENT= 0.050
HC....SAMHLE-? _____ 1 B
HC AMbIHNT= 15.650
„ C(L SAMPLE? _____ L.L5^a7lJ
CO AMUIHNT= 2.320
___ MflX SAMP] F= ____ 77.U/1U
NOX AM13IENT
0.500
RUNtf= V06?|06
CELL= N
()DOMhTHK= 225.0
a TH
DHtVF»= TR
INE»TIA= 3500.0
HP A/I 12.3
60.0
COMMENTS
_____________ 06-2 1-7V THST NO. HOUR
(PM)
WITH WATEK
V()LUMt-:
. : NOX
COHK K
BAG.L._.. U . tl«5. _U ..t
HC
**t
-------
n
EMISSION TI-ST nt-;p()UT MOUTH rpn
ECONNOMY KUN
ft/??/WTUi-:= 4tiiPM
J£E£T_2 ______
UAH I KAH DATA . ._
VOLUME= 4223.
HH= 56.000.
ABSOLUTE HUMIDITY"
bU.00000
C02 AMUIENT"
--HC SAMPLE?
HC AMBIENT-
_CU..SAMi>LE=
CO AMUIENT=
_MA_.iJAM>JLE-=. ..
NOX AMUIENT=
O.OtJO
I^U __
10.0'JO
1.640
61 -OH"
0.340
tf,= 9002207_...CAM=._ HHUAL__
CELL= N OUOMETEK= N/A
I1»IVFH=
INI£HTIA= 3500.0
HP A/ 1 12.3
60.0
COMMENTS
06-22-7V THST NO. (1NP OK THF HAY
UASE-LINE
VOLUUE= 4223.
NOX
COHH
************** G
H HC CO
NOX
CO2
HC
CO
NOX
ECONOMY
FUEL CONSUMPTION
1238.33 GRAMS
-WATER-GONSUMP-T-I-ON
SPARK ADVANCE
MFG. SPEC.
-------
-THS-V-
T
EMISSION TEST HEPOHT...NUHIH_aLLL.
ECONNOMY HUN
TEST 8
UACJ_HAH-.DA1A ....... _
VULUME= 4235.
_____ KH=._. .. 52.UUU ......
ABSOLUTE HUMIUITY= 46.0UOUO
C02 AMBIENT
HC SAMPLE=.
HC AMBIENT=
C.O..SAMHLE= .
CO AMU1ENT=
U.UiiO
.. 16 I .740 __
I I.46U
. 1U4.9VU __
I.6UU
NOX AMBIENT
0.30U
Kh'fiAL
CELL= N
"coMMENrs
ODOMETbl<= N/A
()PFKAT()»g TH
IHE«T1A= 35UU.O
HP A/I 12.3
60.0
.. 06-22-7V TEi5
WITH WATEH AND ALCOHOL (50/bU) SPAHK ADVAMCEi 10 DEGHEES ABOVE MANUFACTURE
NOX ._..
COHH H
HC
..._BAGL U.ddU.. . .U.H7ii IU.4H6
CO
V ******* *n»i*«a imnHnnan ni?S/MI *********
NOX C02 HC CO NOX
.64H_
MPG
ECONOMY
Ni
.00
FUEL CONSUMPTION
-WATER-CONSUMPTION-
1163.2 GRAMS
10 nrl— t50%-ETHYE-ALC.)
SPARK ADVANCE
MFG. SPEC. + 10°
-------
A
JL. _..
V
b"Mlib ION TUST HbVUHT NOKTH CPU,
bCONNOMY KUN
6/2J/'/V'l'[MI-= Lit MAM
TEST 9
IMG I HAN DATA
. VOLUMb= 4237 .
__ KH= 70.000
ABSOLUTE HUM1DITY
___ £02 S
6U. 00000
C02 AMUIENT=
HC SAMHLt=
HC AMHJEMT=
CO SAMK>Lli=
CO AMUIIiNT=
NOX 15AM|'Lb=
NOX AMU1ENT=
0.040
/.200
3.U30 ...
1.410
oy.. iuu._
0.320
yOo22IO CAIW= IUJ1CK ()HEHATOI<= Di-W 1)L(1VEI?=
CELL= N OL}OMLTbt<=" 2~4V. 1ME»'HA= "31JOO. Ill1 A/1 12.3 60. ^
COMMENTS " " '. '. ..,-••-'
WAFER &' ALCOffoL~ ~" "^
yi)Ly.Mb= 4237. . TEMPEI?A.T,U..KE= J4......W
-------
Attachment B
30
Karch 19, 1979
Mr. Kenneth J. Landis .
Treis International
C/O Allied Decals, Inc.
20700 Miles Avenue •
Cleveland, Ohio 44128
Dear Ken, ' •
During the week of February 5, 1979, a series of Highway Fuel Economy Tests
(HFET) were performed by an EPA approved laboratory in accordance with
Federal Test Procedures (FTP).
The information gathered (Attachment 2) during the tests not only confirmed
previous infra-red exhaust analyses (Attachment 3) , earlier HFETs (Attach-
ment 3), and 3,000 miles of on road testing, but it also determined the
operational parameters of mixing water in gasoline using the Treis Process.
The data was analyzed graphically with adjustments being made to allow for
the type of mixer in use during each experiment. No' modifications or
adjustments were made to the automobile under test with the exception of
bypassing its fuel pump and replacing it with a Holley 110 gph electric
pump.
The results of the aforementioned analysis show that the addition of 1.5%
to 2.5% water (by volume) to gasoline can be accomplished economically,
reducing hydrocarbon (HC) and carbon monoxide (CO) emissions 55% and 60%,
respectively, while increasing mileage by at least 10%. In addition, no
adverse effect was shown on oxides of nitrogen (NOx).
A summary of the analysis follows.
1. Hydrocarbons. A reduction of HC emissions was found to be dependent
on the amount .of water added and the type of mixer used (Attachment 1,
Figure 1). An optimal amount of water was found to effect the great-
est HC reduction (approximately 2% by volume). This reduction was
accomplished'without a corresponding increase in NOx levels, and thus,
can be attributed to an increase in ignition efficiency. (If the
mixture were leaned instead, NOx would rise.) An adjustment was made
to the data to compensate for mixer type, the results are shown in
Attachment 1, Figure 2. Data variance was reduced and thus it is
concluded that mixer type also plays a significant role in HC reduction.
Hydrocarbon emissions are a good measure of ignition efficiency,
therefore a low-grains per mile figure is essential for high mileage
and minimum polution.
-------
December 29, 1978 V 31
Page two
Mr. Ken Landis
Treis International 2179 S. Belvoir
Cleveland, Ohio 44118
1. The exhaust emission improvement on the Highway
Fuel Economy Test, although not directly comparable
to the 1975 FTP Gold start procedure, was
approximately 38% for the HC constituents and
65% for the CO constituent. NOX increased 25%
and fuel economy remained unchanged. Due to the ^^ —
repeatability of the test procedure, these results
could change significantly from test to test. From
past experience, HC can vary by 16%, CO by 10%,
NOX and fuel economy by 7%.
2. The direction of HC, CO, and NOX are all consistent
with recognized engine phenomenon. As combustion
becomes more efficient, HC and CO are reduced and
NOX is increased. The fact that this vehicle used
a catalytic converter clouds this somewhat, however,
the changes seen were rather dramatic.
Attachment 1 gives the baseline exhaust emission results and
fuel economy for the 1975 FTP. Attachment 2 gives the fuel
economy results for the Baseline Highway Fuel Economy test.
Attachment 3 gives the exhaust emission results in grams/mile
for the Baseline Highway Fuel Economy test.
Attachment 4 gives the fuel economy results for the vehicle in
the modified condition for the Highway Fuel Economy test.
Attachment 5 gives the exhaust emission results in grams/mile
for the modified Highway Fuel Economy test.
Attachment 6 gives a approximate summary of charges to perform
the tests and service to date, you will receive an exact figure
within two weeks.
Thank you for the opportunity to serve you. You will receive
a refund check from Systems Control, Inc. If we can be of
further service, don't hesitate to call on us.
Sincerely,
Joseph M. Gall
Director, Livonia Operations
cc: Paul
J. Harkins
J. Randall
C. Mathers
D. Orrin
-------
Note: All water percentages by weight.
; ' 32
*C •"• » •/• IC»r*v#*«tf f
-------
T E - DATA
j km
D«te
T.^l(5)T..p2£5)Av.r.g.(5) UC(1)
j IXCIXC - OUT
J
: 10 2/07 838
11 .2/07 »Z1
I n
21
i "
j "
1 »
»'
! 33
1 "
i 41
i 4i
.
2/07
2/08
2/08
2/08
2/09
2/09
2/09
2/09
2/10
2/10
*
• COHVtm* -
10 2/07
1 11 2/07
| £
!":
i 22
i • •
s »
©
32
'( 33
i J*
41
1 «
2/07
-2/08
2/08
2/08
2/09
2/09
2/09
2/09
2/10
2/10
804
SI 7
868
782
809
655
813
826
834
809
OUT
838
821
' 804
817
868
: 872
. . • 80?
655
813
826
834
809
779
860
906
868
889
847
851
783
847
855
855
851
779
860
906
868
889
847
851
783
847
855
855
851
809
841
855
843
879
860
830
719
830
841
845
830
809
841
855
843
879
860
830
719
830
841
845
830
.914
.802
.536
.767
.406
.387
2.182
2.716
.278
.428
.401
.508
.113
.092
.049
.135
.033
.028
.075
2.411
.019
.023
.023
.032
co(1>
11.261
8.698
5.615
8.563
3.633
20.083
4.120
63.738
2.733
3.659
4.171
3.979
5.227
3.383
1.954
4.081
1.553
1.012
. 2.200
63.654
.627
.744
1.126
1.104
«,<"
2.046
1.977
2.000
1.932
1.326
1.774
.860
1.224
1.196
1.939
2.007
1.948
1.557
1.717
1.817
1.757
• 1.218
1.791
1.743
. 1.007
1.117
1.818
«
1.897
1.833
KOxCCl)
1.852
1.825
1.735
1.708
1.718
1.630
.795
1.140
1.122
1.820
1.893
1.810
1.409
1.584
1.612
1.553
1.119
1.645
1.612
.938
1.047
1.706
1.788
1.703
C02U)
392.5
398.9
424.0
400.5
318.6
412.3
416.0
356.1
285.6
461.1
443.3
453.6
404.7
409.5
431.3
409.8
323.3
443.1
427.0
356.7
289.2
467.2
449.5
459.9
Hilts
10.08
10.09
10.10
10.12
10.13
10.14
10.26
10.33
10.27 '.
10.24
10.31
10.21
10.08
10.09 .
•10.10
10.12 •
10.13
10.14
10.26
10.33
10.27
10.24
10.31
10.21
KTG(I>
21.485
21.383
20.426'
21.314
27.229
19.943
20.669
19.090
30.328
18.956
19.673
19.225
21.478
21.380
20.423
21.300
27.239
19.956.
20.607
19.114
30.574
18.948
19.666
19.222
t
ru.i(4)
1245.9
1212
1299
1348
1340
1370
1425
1169
1369
1469
1417
1424
1245.9
1212
1299
1348
1340
1370
1425
1169
1369
1469
1417
1424
Mel/H
123.6
120.1
128.6
133.2
132.3
135.1
138.9
113.2
133.3
143.5
137.4
139.5
123.6
120.1
128.6
133.2
132.3
135.1
138.9
113.2
133.3
143.5
137.4
139.5
' / 7 (6) (7) (8)
(3) (3) XII2°/ *"2°/ 1A1/ tA1' Klx "V»lvt
RZ0 HjO/M Wt Yol Uiter Vc Zle»«nt* Tumi
13
21
12
75
63
35
40
. :'42 ".
40
31
58
13
21
12
75
63
3J
40
42
40
31 '
58
1.29
2.08
1.19
7.40
6.21
3.41
3.87
4.09
3.91
•-3. 01
5.68
1.29
2.03
1.19
7.40
6.21
3.41
3.87
4.09
3.91
3.01
5.68
1.1
1.6
.9
5.6
4.6
2.5
3.4
3.1
2.7
2.2
4.1
-.1.1
. 1.6
.9
5.6
4.6
2.5
3.4
3.1
2.7
2.2
4.1
.8
1.2
.7- 10 .09
4.1 10 .36
3.4 20 .92
1.8 3 .13
2.5 5 .17
2.3
2.0.
1.6
3.0
.8
1.2
.7 10 .09
4.1 10 .56
• 3.4 20 .92
1.8 5 .13
2.5 5 . .17
2.3
2.0
1.6
3.0
8
8
1Z
12
12
18
1Z
'18
12
18
18
8 UJ
8
12
12
12
18
1Z
18
12
18
18
2
3
3
5
5
4
4
4
4
i
5
2
3
3
5
5
4
*
4
4
4
5
(1) Crw> ptr Bllt (r«d«rtl Tett Procedure, Km)
(2). CilcuUttd WC • 2421/[.866(HC) + .429 (CO) + .273 (C02)]
(3) HjO In ml ipproxlnit'elr • {rial t
(4) Crtni (denitcy 6.177 lb/t»l or .74 gr.n.M)
()) Degrctt 7 veeturid /ran exhtgii nentfold
(() (HlO/fucl) X 100 (Approximate; «ieuned al 1120 » jr»mj)
(1) [H}0 X .74 gr«n«/nll X 100 (Approxlnite. Ko correction for
Fuel ttfperiture, or prenuce.)
(8) |I Al/V«(cr] X [X Il20/vt.|
Attachment 2
-------
May 2, 1978
• 34
Infra-Red Exhaust Analysis
-03
D
INSPECTION REPORT
EXHAUST EMISSION LEVELS
-ySS? ~?zjx*
i^.f-t-t' *&S3D
No Water
<»•'•...>>•/
'Ms
fl
D
INSPECTION REPORT
EXHAUST EMISSION LEVELS
rm HC N^
HYDROCARBON
'•.'
*
•»*•!
CAR90H MONOXIDE
TACI HI*O**CJ AT 7400 •MM A*O AT K>lt IVM
O P«« ra LJ m« y< J^CO *^« tJs*._ 4f m. C
« > •»«• ____/£Q »^M Mf KM,| »»^_____Q* O,. *.fc
.
•• Tf
Water
December 27, 1978
HC
FTP .70 gr/M
CO
9.5 gr/M
NOx
1.4 gr/M
MPG
17.0
HFET .13 gr/M
2.5 gr/M
1.6 gr/K
22.4
HFET .08 gr/M
Water
.88 gr/M
2.13 gr/M
22.4
January 13, 1979 Infra-Red Exhaust Analysis
•-S-- 7-KIisH CRUISE
?:-.I'-"I 'ENGINE TO TE':T S~'EE~'
IO £r;.-.--.vr cccr/:.
~ ' "
TIflU-G AD'J&iCE
C-. 0 DEG
VOLTS " O.'OP VOLTS
No Water '.
Ol
<
I
o
• -o
O!
SL^ 2001 CO^='LJTER 5120515
512^0515 Q
O—
•-.BrJHG Ef^IHE-TO. TEST S-EEO't- y '-: -
O w ^.4-r. J.r/V:J '.vl. ;'•
Water
-------
35
1SS4 IDT meet jtdj. it »ll altitudes Gasoline HOT E.ap. S g/Test (SHED) by Daxign
1935 HOT NO, std. 75V. below 1973 Gasoline HOT level lsa) Gasoline Truck Evap. 2 {/Test (SHEO): by Design lor HOT
1SS4 IDT meet stds. at »ll altitudes
isas HOT NO, ltd. 75% below 1973 Gasoline HOT level
CALIFORNIA
1978 LOT Stdi. Inctudi Dissel
Car End-of-Lin> TeiU apply through 8500* GVW
Fuel Filler Specs, (or Vapor Recovery— tit pan. car
Gasoline HOT E»p. S g/Test (SHED) by Daiign
Gasoline Truck Evap. ? j/Tesl (SHED); by Dasign lor HOT
Hightr optionit NOx Stdi. (or 100.000 mi. Cert.
Listed req'U. fTrucij. < BSOO* GVW) lubject to Fad. Vlm»r.
Restrictions on Allowable Maintenance; "Fixed" Idle Mixture.
HFET NO* Std. 2.0 x FTP Std.
assenger C
Cxhtuit
ErrdnloAi
I!
MC
CO
NO,
Trap
SHEO
C-.rtc.«
ar
1MO
No Conaol
75 H7"
104
M
4.1
to an
4.1 op*n
i
:x::
•X*"
:•:•:•
X'l*.
.*-•.*
is«e
IMC*)
1970
,m,
1970 FTP (T»l';>-c«> Concl
276 ppm
i»
.- Upom
• 23 pp/n
iiliif
CA»
CA4gam
iS:
.;,*.
>x:
Xv
i
1977
W73
1874
U72 FTT pom ICVSI
)A
CAJJ
»
-WW
. J
, I , .
:-x-:\v:-:%v:-:-x-:vKvx-»:wK-:-x-:v>>>:-:vx-:-:-x-
VxSWffiSKftXjiSjiJJ-JSSJSji^Xfftix-iWSJ'K:
1
si
x*x
X-M
vX
1S76
11T71
1971
iseo
1H1
1I7S FTP pom ICVS)
li
CAOi
u
CA*.0
3.1
13
CA>>1
1C
CA1.0
CAIi
k- Z
Illillllililllllilll
WxW;X:
•
^1
CA 3f
1J>
CA»0
2.0
CA1JO
CA J>"
CAOur1
1JO-
CAOpl'
^•xXxXvXjxiXxX:
CAJ
•Unaonlrotlcd Ev»p. 50.6 p/Twl - 4.3 gpm
NOTES:
FTP - Federal Ten Procedure
ppm - parts per million
gpm M grams/mile
CVS - constant volume sampler (true mess meas.)
CA msans Calilornij only
GVW » Gross Vehicle V/eight. IW - Inenie Wt
HFET - Highyyay Fuel Economy Test
'1977 (only) Cars sold in specified High Altitude Counties req'd. to meet
stds at High Atouda
•Non-CH. Std.; -41 total HC w/CH. correction is optional lor 1580
'Possible 2 yr. waiver to 7 gpm
'Possible waiver to 1.5 gpm tor innovative technology or d«asal
•CA option to 1931 Fed. CO/NO* stds.: 7.0/0.7 — must carry over
to '62- Selection of '81 Fed. option requires 7.0/0.4 for '82. CA
CO/NOx tor '83: 7.0/0.4.
Equivalent Tast Results lor difterint test procedure [besed on
1970-71 cars, not applicable to pre-control cars):
1970 FTP 1972 FT." 1975 FTP
HC
CO
NO,
2.2 tpm
23 gpm
4.0 ypm
4.6 gpm
47 gpm
tO gpm
4.1 gpm
34 cpm-
6.2 (pm
ADDITIONAL CAR REQUIREMENTS
1978 No CranVcest Emissions Allowed Tampering by Service Industry,
Dealers, etc. Prohibited Fuel Filler Must Exclude Leaded Fuel Nozzles
(Catatysl Veh.) Exhaust Standards Apply to Diesel w/Test Modi!. As-
semly Line Test Requirement —> SEA
1S31 Possible High Attitude Stds. — to represent same */• reduction as sea
level req'ts.
1334 AD cars meet sids. at all altitudes
CALIFORNIA — IN ADDITION TO FED. CAR REQTS.
1978 HC Subject to CH. Correction
End-of-Line Exhaust Tast
Fuel Filler Specs, tor Vapor Recovery
Individual Veh. Delay till 1932 possible depending on extent of body
changes.
1SSO Gasoline Car Exh. Stds. apply to Diesels Higher optional NOx
Slds. lor 100.000 mi. Cert.
AH listed req'U. subject to Federal Wa'rver: Restrictions on
Allowable Maintenance: ~Fued~ Idle Mirtura fisquirad; HFET NOx
Std. 1.33 X HP Std.
^
GM NATIONWIDE PRODUCTION-WEIGHTED
AVERAGE FUEL ECONOMY
EPA Driving Schedule— 55% CITY/45% Highway
Modal
Yo.r
1974 Adual
1975 Actual
197S Actual
1977 Actual
1978 Forecast
GM
Av»r>;e
12.0
15.4
18.7
17.8
110
P»s*ang*r Cm
Cumulative
Improvemefft
over 1974
28%
39%
58%
light DutvTncVi
lUniltr S.SOO t CVWH1
CM
Average
"pg
1U
14.4
15.9
17.0
17.0
Cumulative
Improvement
o«ar 1974
28%
41%
51%
51%
ENERGY ACT
Modal
Year
Passenger Can
.
. npj
13
19
20
22
2<
25
27
27.5
Cumulative
Improvernant
over 1974
50%
58V.
• 67%
83%
100%
116%
125%
129%
light Duty Tracks
None
•17.2 (0-6000 tbs.) (2WD)
•IS (0-8500 IDS.) (2WO)
•18 |»8SOO Ibs.) C2WD)
1978
1979
1963
1S3I
1962
1933
19S4
1985
•4WO (15.8 mpg II37S); 14.0 mpg (1S80); 15.5 mpg (1S31)
Ponahiis:
• 15 per 1/10 mpg below app1i:able tuel economy standard (set above}!
total model year production.
(Financial credit givan tor etceeding standard vMch may bl applied back
one modal year and any excess may ba applied forward one model year;
credh usable only in elm or category ot au*.omobi!i whera it was aimed.)
• Jl.OOC per automobile lor violation ol ft* labeling provisions ot the law.
• {10.000 par day lor any person violating provisions ol the law other than
the.average lunl economy standards.
-------
»~JV— fii 36 Attachment C
ENVIRONMENTAL ENGINEERING
DIVISION
December 29, 1978
Mr. Ken Landis
Treis International
2179 S. Belvoir
Cleveland, Ohio 44118
Dear Mr. Landis:
SCI was contracted to procure, tune and test a vehicle to
verify the potential of your device to influence the vehicles
exhaust emissions and/or fuel economy for the recognized EPA
required test schedule. Due to some problems with the device,
it was decided not to run the full EPA Cold Urban Driving
cycle (FTP) , but use the EPA Highway Fuel Economy Test (HWFET)
to generate the most usable data.
A 1978 Buick Regal \vTas located and brought to the Laboratory;
tuned and tested in the production or baseline configuration.
The test results run December 27, 1978 are:
1975 Cold Emission Test (FTP)
MPG Hydrocarbons Carbon Monoxide Oxides of Nitrogen
(HC) (CO) (NOX)
17.0 .70 gr/mi 9.5 gr/mi 1.4 gr/mi
Highway Fuel Economy Test (HWFET)
22.4 .13 gr/mi 2.5 gr/mi 1.6 gr/mi
The device was installed on the vehicle, but several problems
were encountered which might have interferred with running the
full 1975 FTP Cold Start Emission Test. It was decided to run
a Highway Fuel Economy Test (HWFET) due to its less severe
testing requirements.
The results for this test run December 28, 1978 are:
MPG HC CO NOX
22.4 .08 gr/rai .88 gr/mi 2.13 gr/mi
The conclusions that can be drawn from these two tests are
encouraging.
i.,INC O 11665 LEVAN ROAD VJ LIVONIA, MICHIGAN 48150 B C313) 59J-OOU
-------
Attachment D
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
. ANN ARBOR. MICHIGAN 48105 •
OFFICE OF
March 16, 1981 AIR. NOISE AND RADIATION
Mr. Kenneth J. Landis, President
Treis International .
20700 Miles
Cleveland, OH 44128 :
.... ,.... . . .
Dear Mr. Landis: •• .: - . v •.'•>':''• r/v.-.v "• .; . ; '• " ' '-'.;-' : • - • "/•', 1"",'. ; '.
The EPA has received your February. 17, 1981 application for evaluation of
the Treis Emulsifier under Section 511 of the Motor Vehicle Information
and Cost Savings Act. A preliminary review of your application has been
made. This review has raised' several questions about the device and the
supporting test information. In addition, the supporting test data does
not indicate the results of installing the Treis Emulsifier on the aver-
age in-use vehicle. In order to determine the effect of the device on
in-use vehicles, a test plan has been assembled which when completed will
indicate to EPA the feasibility of your device.
Please answer the following questions about the information submitted on
your application: i
a. Please send a copy of the patent application including the device
description and data supporting these claims. Please indicate
the patent application number. . ..':...'.
b. The description of the Treis Emulsifier indicates enclosed sche-
matic drawings. No drawings of the device were included with the
application. Please submit the missing schematics.
c. The method of emulsification of water is not clear. Perhaps the
missing schematic drawings will clarify the operation of the
device. It is not understood if the alcohol-water additive, is
added seperately upstream at the carburetor or if the alcohol-
water additive is trapped and then added.
d. The device operation instructions raised several questions:
1). What type of alcohol should be used?
2). What about the late model cars with manufacturer basic igni-
tion specifications of 12°-15° B.T.D.C.?
3). What if engine knock is not heard upon acceleration?
4). Please send the installation/operation brochure supplied to
the consumer with the device. ••.'..••
5). What should be "repeated as required "to prevent engine knock?
-------
38
e. The vehicle maintenance section indicates only water should be
added. Does the alcohol-water mix switch to a just water after
break in? If so, how does the water get to the carburetor with-
out alcohol to hydrate the water?
e. The questions regarding the submitted test data are divided into
three parts:
1. Bendix Laboratory Data
(a). The car had only 100 total miles at the time of the
baseline tests. Vehicular emissions and fuel economy
are not stabilized at 100 miles. EPA requires 4000
miles on certification vehicles to ensure stabilized
emissions. This fact puts into question the results of
the Bendix vehicle testing. « . '
(b). The test procedure used was apparently the Highway Fuel
Economy Test Procedure. This test sequence, is used to
determine fuel economy in highway type driving. The
emissions during the HFET have not been related to air
quality and do not necessarily indicate the emissions
during driving the FTP. :
(c). The Bendix data indicates a 6.2% improvement in fuel
economy due to the water emulsification and 8.6% due to
timing advance. The fuel economy gains due to in-
creasing the basic timing 10° cannot be attributed to
the Treis Emulsifier. "• •"
(d). The Bendix data other than test #9 were apparently run
without a catalyst. The indicated emission changes due
to the Treis Emulsifier cannot be related to present
catalyst-equipped vehicles.
(e). Please indicate how water consumption was measured.
(f). Please indicate manufacturer basic timing specification.
(g). The vehicle mileage indicates that the operational
instructions in the 511 were not followed. In particu-
lar 100-200 miles were not put on the vehicle with the
device installed. Please indicate why you feel this
data is applicable. : '
2. The Other Laboratory Data
(a). What is meant by "type of mixer"? .
(b). How was the amount of water and water/alcohol mixture
used measured?
(c). Please indicate which tests #31-HC on Attachment 3 is
in question. .
-------
39
(d). The same problems of applicability of HEFT data to
in-use urban emission standards exist as within the
Bendix data. ,
(e). What is heading"Mix Elements" in Attachment 2?
(f). Please identify vehicle used for this testing. Include
odometer, engine type, fuel used, etc.
(g). There are several questionable data points which indi-
cate a problem with the analysis of the exhaust gas.
(1). The fuel used does not compare with the Carbon
Balance fuel economy numbers. Test numbers #22
and #33 show increases in fuel consumed over
baseline (1369 and 1340 grams vs. 1246 grams),
but the 'carbon balance data shows fuel consump-
tion ^reduction (30.574 and 27.239 vs. 2l'.478
mpg). ^Please explain this inconsistency. , .
(2). Test #32 shows abnormally high CO which is not at
all reduced by the converter. This appears to
inconsistent with other data which showed a sig-
nificant reduction in CO through the converter.
Please explain this apparent anomilie.
(3). Other than the two tests #22 and #33, no improve-
ment in the carbon balance fuel economy was
noted. These two tests were not repeatable as
noted by similar condition tests #23 and #32
which both showed a significant decrease in fuel
economy. Please explain the large (60%) differ-
ence in fuel economy.
(h). Please indicate the name of the Laboratory
3. The SCI Laboratory Data
(a). Please indicate the problems encountered which might
have interferred with running the full 1975 Cold Start
Emission Test.
. . '.' • - i • • • .' '• - ' - - :.
(b). Please describe the 1978 Buick Regal as to engine type,
weight, test fuel, mileage, etc. Is this the same
vehicle as tested at Bendix?
(c). Please include Attachments 1, 2, 3, 4 and 5 to the SCI
report. . .•'.''••
(d).. The results indicate a reduction in HC and CO, an
increase in-NOx, and no change in fuel economy. This
data does not agree with the other data which indicated
a change in fuel economy. Please address this apparent
inconsistency. . ,
-------
Further testing is required to demonstrate the feasibility of the Treis
Emulsifier as a fuel economy improver. In accordance with FR Vol. 44,
Part 610.30(a), a test plan has been designed to demonstrate the validity
of the claims made for the device. Completion of the following test
•program will allow EPA to satisfactorily evaluate your device:
a. A minimum -of two vehicles should be tested using a test sequence
consisting of a hot-start LA-4 portion (bags 1 and 2) of the
Federal Test Procedure (FTP) and a Highway Fuel Economy Test
(HFET). Although only the 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 may wish to know
how a vehicle with your device performs over this official test.
b. The laboratory doing the testing must be selected from the list
of EPA recognized laboratories (attached). :.
c. 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 device installa-
tion. : . : .
d. The installations and operational instructions given in your 511
Application must be followed exactly.
e. A minimum of two vehicles should be tested in duplicate in each
test configurations. Select the vehicle from the attached table
#1. Select a maximum of one pre-1975 vehicle.'. Any test vehicle
should have a minimum of 4000 odometer miles.
f. All test data obtained from the outside laboratory in support of
your application should be submitted to us including void or
invalid tests.
g. Notify us of the laboratory you have chosen, when testing is
scheduled to begin, what test you have decided to conduct, and
maintain contact with us during the laboratory testing.
h. The devices used on this testing must be production models of the
Treis Emulsifier. ' ,
These tests must be run at your expense. Upon completion and transmittal
of the EPA data, along with the requested information noted above, an
evaluation of your device will be made including any confirmatory EPA
testing considered necessary. If such confirmatory testing is required
you will be contacted for your approval of our in-house test plan. Any
testing at EPA will be at the expense of the U.S. Government. In order
-------
41
to expedite the processing of your application, we must require that the
requested information and test data be submitted by April 28, 1981. If
you have any questions concerning this matter, please contact me at
313-668-4299.
Sincerely,
tY""u_-i^v^_o
Merrill W. Korth, Device Evaluation-Coordinator
Test and Evaluation Branch
Enclose: .
1. Lab List -:
2. Table 1 - . •'•
. Penninga
511 File (Treis Emulsifier)
------- |