EPA-AA-TEB-511-81-28
                 EPA Evaluation of the Glynn-50 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


                               John C.  Shelton
                                 August 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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6560-26
                     ENVIRONMENTAL PROTECTION AGENCY
                            [40 CFR Part 610]
                           [FRL
                      FUEL ECONOMY RETROFIT DEVICES
         Announcement of Fuel Economy Retrofit Device Evaluation




                             for  "Glynn-50"
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 "Glynn-50" device under provisions of  Section  511  of  the




          Motor Vehicle Information and Cost Savings Act.

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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),  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 FR 17946].

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ORIGIN  OF  REQUEST FOR EVALUATION;   On  June 2, 1981,  the EPA  received  a




request  from the  Hopkins-Glynn  Corp.  for  evaluation of  a fuel  saving




device known as the  "Glynn-50".   This device is claimed  to reduce exhaust




emissions and save fuel.









Availability of Evaluation Report;  An evaluation  has been made  and  the




results  are  described completely in a  report entitled:    "EPA  Evaluation




of the Glynn-50 Device Under Section 511  of the Motor Vehicle  Information




and  Cost Savings  Act,"  report  number  EPA-AA-TEB-511-81-28  consisting  of




22 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 his  application.   The  device description and  supporting




text  indicated  that  the  device   should  improve  combustion  efficiency.




However, no test data was submitted with the application.

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While thorough mixing of  fuel  and air and even distribution will  enhance

the combustion process,  there is no evidence that the use  of the Glynn-50

device  will result  in  any  improvements over  an  unmodified induction

system.  The use  of smaller jets  in  the carburetor will  tend to  enlean

the mixture but may cause driveability problems in some vehicles.   Based

on EPA's experience  with  similar devices, there is  no  reason to  support

any claims  for  improvements  in fuel economy or  exhaust emissions due  to

the use of the Glynn-50.



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                                   Kathleen Bennett
                                       Assistant Administrator
                                       for Air, Noise, and  Radiation

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EPA Evaluation  of  the "Glynn-50" 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;

    Glynn-50

2.  Inventor of the Device and Patents:

    A. Inventor

       Mr. Percy Glynn
       R.D. #1
       3041 Briner  Road
       Middletown,  PA  17057

    B. Patent

       Applicant stated  "The  necessary papers  are  being  filed  by   our
       patent attorney."

3.  Manufacturer of the Device:
    The Hopkins-Glynn Corp.
    140 South Main Street
    Madisonville, KY  42431

4.  Manufacturing Organization Principals;

    Mr. Barney Q. Hopkins - President
    Mr. Percy Glynn - Vice President
    Mr. Jerry F. Wilbur,  Jr. - Treasurer
    Mr. Curtis D. McCoy,  Jr. - Secretary

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

    The Hopkins-Glynn Corp.
    140 South Main Street
    Madisonville, KY  42431

6.  Applying Organization Principals:

    Mr. Barney Q. Hopkins - President
    Mr. Percy Glynn - Vice President
    Mr. Jerry F. Wilbur,  Jr. - Treasurer
    Mr. Curtis D. McCoy,  Jr. - Secretary

7.  Description of Device;

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

       "The primary purpose  of  the device is  fuel  economy and it  should
       produce lower exhaust emissions."

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

       "The  theory  of  operation  is  a  venturi  box   fits   under   the
       carburetor with  two  heat sources which  vaporizes  the fuel  better
       and the carburetor jet is reduced  in size and a fuel regulator  to
       prevent over supply  of fuel.  As  the fuel  goes  down the  venturi
       the  fuel  becomes  more  combustive  by  better  vaporization   and
       expansion  of  air  and  gasoline  because  of   the  heat  sources.
       Thereby  reducing  the   amount   of   fuel  requirement,   which   is
       accomplished by reducing the size of  the  jet and  the fuel  pressure
       regulator eliminates excessive pressure."

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

       See attached sketch "A" (Attachment B).

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

    "The device is applicable to all carbureted  gas powered vehicles with
    very minor adaptions."

9.  Costs (as supplied by Applicant);

    Not supplied.

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

    (a)   "Remove  the  carburetor  and  install  the  device between   the
          carburetor and manifold;  cut  the gas line and  install  the fuel
          regulator;  install smaller jet.

    (b)   "Applies to all carbureted gas powered vehicles.

    (c)   "The  tools  required  are  1/2" wrench,  screwdriver,  small pipe
          cutter and 9/16 wrench.

    (d)   "No equipment necessary to check proper installation.

    (e)   "No adjustments necessary.

    (f)   "The average mechanical skill is necessary."

11. Device Operation (as supplied by Applicant);

    "No instructions are necessary  which pertain to  its usage."

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                                 8

12. Maintenance (claimed);

    "Maintenance is not necessary."

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

    "Less  fuel  is  used therefore  less  emission and  pollutants  should
    result."

14. Effects on Vehicle Safety (claimed):

    "The device will not cause any unsafe condition."

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

    The  applicant  stated  that Automotive  Testing  Laboratories  of  East
    Liberty, Ohio would test on June  8 and  9,  1981  and the results would
    promptly be furnished to EPA.  To our knowledge, this testing was not
    performed and no test results have been  supplied to  EPA.

16. Analysis

    A. Description of the Device;

       The  device  is  judged  to  be  inadequately   described.    A  brief
       description is  contained  under Section 8, Description of Device,
       of the application (Attachment B).

    B. Applicability of the Device;

       As  stated  in  the  application,  the  device   is  applicable   to
       gasoline-powered vehicles equipped with  carburetors.

    C. Costs:
       Not supplied.

    D.  Device Installation - Tools and Expertise  Required;

       A skilled mechanic  with ordinary tools should  be able to  install
       the  device,  although  complications  could   arise   due  to   the
       alteration of carburetor linkages.  In  some cases, the additional
       height of the carburetor could also prevent the hood from  closing
       properly.

    E.  Device Operation:

       The instructions were  incomplete and no  mention was made  of  any
       operating instructions being required.

    F.  Device Maintenance:
       The device does not appear to require  maintenance.

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    G. Effects on Vehicle Emissions (non-regulated);

       The device is claimed  to lower emissions, but  no  data to  support
       these claims were ever submitted.

    H. Effects on Vehicle Safety:

       One  safety  problem that might arise  is  leakage  of  fuel  if the
       pressure regulator is not installed or secured properly.  There is
       also  the  problem  that  the  throttle linkage may  not   operate
       correctly.

    I. Test Results Supplied by Applicant;

       The applicant did not  submit any  test  data in accordance with the
       Federal  Test  Procedure  or  the  Highway  Fuel  Economy  Test.   The
       requirement for test data following  these procedures  is stated in
       the application test policy  documents  that  EPA sends  to potential
       applicants*.  The applicant  did state that Automotive Testing Labs
       of East Liberty,  Ohio  would  test  the device on June  8  and 9 1981
       and  the  results  would  promptly  be  furnished  to  EPA.    To our
       knowledge, this  testing was  not performed.

17.  Conclusions
    While  thorough  mixing  of  fuel  and  air  and even  distribution will
    enhance the combustion process,  there is  no  evidence that the use  of
    the  Glynn-50  device  will  result   in  any  improvements  over   an
    unmodified  induction  system.    The  use  of  smaller  jets  in  the
    carburetor will tend to enlean the mixture but may cause  driveability
    problems in  some  vehicles.  Based on EPA's  experience  with similar
    devices, there is no reason to support any claims for improvements  in
    fuel economy or exhaust emissions due  to the  use  of the Glynn-50.
 *  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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                                 10


                           List of Attachments

Attachment A              Letter,  EPA to  Mr.   Hopkins  of  Hopkins-Glynn
                          Corp. January 6,  1981.

Attachment B              511 application  from  Mr.  Hopkins to  EPA,  June
                          2,  1981.

Attachment C              Letter, EPA to Mr.  Hopkins, June 30, 1981.

Attachment D              Letter, EPA to Mr.  Hopkins, July 22, 1981.

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                                                                Attachment A
                                      11
January  6,  1981
Mr. Barney Q. Hopkins
T4~tf South Main  Street
Madisonville, KY   42431

Dear  Mr. Hopkins;

This  letter  is  in  response  to  your  inquiry  of  1/5/81  regarding  an  EPA
evaluation  of  your device.   The  Environmental Protection Agency is churned by
Congressional  mandate to  evaluate  fuel  economy and emission control  devices.
While ttoffi  EPA  does not  actually  "approve"  cuch  devices,  it does  conduct
evaluations!  for the  purpose, of  Increasing  the common knowledge in  the  area.
For this reason, the outcome of any testing  by CPA becotses public information.
It is this information which may be cited although no claims can be rade that
any EPA findings constitute "approval" of  the device or system.

Enclosed  with  this  letter  is  a  packet of  materials which  you will  need to
apply for an  EPA  evaluation of  your device.   This packet corslets of  1) nn
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 must have an
application.   Once  you have reviewed all  Jthe documents  In the  packet,  you
should  prepare an  application  in  accordance  with   the guidelines  of  the
application format.   & critic*!  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  yomr expense.  A list of
laboratories which arc  known  to hav* the equipment and  personnel  to  perform
acceptable  tests has been  included in ti«* enclosed packet.  If you desire, we
con assist  in  the  development of  a  satisfactory test plan.

There are,  however,  several   aspects   concerning  testing  at  an  outside
laboratory  whleh I would  like te  bring to your attention at this
      Minimum ttest  Re«pj!r«a*ent8  -  Although different  types  of  devices  may
      requlra a siora  complex t«st  plan,  the minimum we  require  involves two
      vehicles and two test saaxiene«s ruo  in duplicate.   The vehicles should be
      selected  from those  listed  in  Table 1; if possible.   Each  vehicle is to
     vfefi. ifit -to nauiwf eetttrjQC '.«, j^tac-tiB BD«clficatiou8 for  the  baseline testa.

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                               12
Tho 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  teet  sequence  with only  these  adjustments should  bo inserted
between the first  and last.  Also as a  minimun,  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  (EFET).   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 tflll be based on the complete FTP and you
may 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  frora the
outside laboratories  in support  of  your application be  submitted  to us.
This includes any results you have which w.ere declared void or invalid by
the laboratory.   We  also  ask  that  you  notify us of  the laboratory you
have  choeen,  rjhen  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, ond  allow the test  laboratory  to
directly answer any questions at any time about the  test  program.

Coot  of  the Testing  -  The  cost  of  the minimum  teet plan (two vehicles,
two test  sequences  in  duplicate)   described  above  should be  leos 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 them Individually to
obtain tbelr latest prices.

Outcome of  the Teats - Although it.  is  impossible  to  accurately predict
the overall  worth  of a device  from a small amount of  testing, ve have
established  some  guidelines which  will  help  you determine  whether the
test  reoults  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 raeasurecent.
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  en 8« difference
in  average  fuel  economy  can  be  shown, then  we would  be able  to eay
stastically at the 80% confidence level that there is n real improvement.
Similarly, we would  expect a minimum of  5% Improvement  for a fleet of 5
vehicles.  Test resulte which  dioplay a significant increase in rmienion
levels should be reason for concern.

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                                   13
                  Fuel Hcosxay TRproveoetstB  versus  Size of  Test Fleet

          Float Si go                   Avcraflo lynrpverosnt  Required
              T~   "                              32
               3                                   n
               4                                  62
               5                                  32
              10                                  42
              25                                  2%

Onco us receive your application.  It will  be reviewed  to dotercine if it. cuetr.
tha requlTeoonto  listed  in the  forcat.   If  your application  is not c crap late,
we  will aok  you  to eufcsdt  further information or data.   After  ar;y  nice in;;
Inforrcation has been submitted,  your application will  be reconsidered and once
it  fltteto  our requirenonfco, you  will fca  ariviauc! of  our do cl a ion whether or not
EPA will  per fora  any corsfirEatosry  testing.   Any CTA testing will he perforr-ed
at  no  cost  to  you and  you  will be piven the opportunity  to  concur uith our
Coat  plan.   Once  thle  lest Ing  is coiaplate, an  evaluation  report trill  b«
vritten.  If no further  testing  is required, ttie report Hill be written r-olcly
on the baoic of tho troinptly to Qay  questions or to nubudf.
ony requeateid data.  Failure to  r«aopon<3 in  &  tituoly  mannur will unduly delay
the  process.   In the  estretna  caoe,  WQ  ray  consider  lack  o.f response  as  a
withdrawal of the application.
I hopo the information abovo end  thag  container!  ia tho endowed 
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                                                      Attachment B

                                   14


                                                    June 2, 1981
                                                    140 S. Main St.
                                                    Madisonville, KY
                                                    42431


Mr. Merrill W. Korth
Environmental Protection Agency
Motor Vehicle Emmission Laboratory
2565 Plymouth Road
Ann Arbor, Michigan
48105

Dear Mr. Korth:

     Please consider this letter our application to the EPA to evaluate
our fuel economy retrofit device, as specified in Section 511 of the
Motor Vehicle Information and Cost Savings Act.

     The following is the information you requested and in the format
you specified:


  1. TITLE:

     Application for Evaluation of a Fuel Economy Retrofit Device
     Under Section 511 of the Motor Vehicle Information and Cost
     Savings Act.

  2. MARKETING IDENTIFICATION OF THE DEVICE:

     The Glynn-50

  3. IDENTIFICATION OF INVENTOR AND/OR PATENT PROTECTION:

     (a)  The inventor is:  Mr. Percy Glynn, R.D. #1, 3041 Briner Rd,
          Middletown, PA. 17057

     (b)  The necessary papers are being filed by our Patent Attorney.

  4. IDENTIFICATION OF DEVICE MANUFACTURERS:

     The device will be manufactured by:
     The Hopkins-Glynn Corporation
     140 South Main Street
     Madisonville, Kentucky
     42431

  5. IDENTIFICATION OF MANUFACTURING ORGANIZATION PRINCIPALS:

     Barney Q. Hopkins, President
     Percy Glynn, Vice President
     Jerry F: Wilbur, Jr., Treasurer
     Curtis D. McCoy, Jr., Secretary

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                                  15


 6.  IDENTIFICATION OF ORGANIZATION MAKING APPLICATION:

    The Hopkins-Glynn Corporation
    140 South Main Street
    Madisonville,  Kentucky
    42431

 7.  IDENTIFICATION OF APPLYING ORGANIZATION'S PRINCIPALS:

    Barney Q. Hopkins
    Percy Glynn
    Jerry F.  Wilbur, Jr.
    Curtis D. McCoy, Jr.

    All correspondence and communication as a result of this
    application is to be  directed to

    Barney Q. Hopkins
    140 South Main Street
    Madisonville,  Kentucky 42431
    (502)821-1985

 8.  DESCRIPTION OF DEVICE:

    (a) The primary purpose of the device is fuel economy and it
        should produce lower exaust emmissions.

    (b) The theory of operation is a venturi box fits under the
        carburetor with two heat sources which vaporizes the fuel
        better and the carburetor jet is reduced in size and a
        fuel regulator to prevent over supply of fuel.   As the fuel
        goes down  the venturi the fuel becomes more combustive by
        better vaporization and expansion of air and gasoline
        because of the heat sources.  Thereby reducing the amount
        of fuel requirement, which is accomplished by reducing the
        size of the jet and the fuel pressure regulator eliminates
        excess fuel pressure.

    (c) See attached sketch "A"

 9.  APPLICABILITY  OF THE  DEVICE:

    The device is  applicable to all carburetored gas powered vehicles
    with very minor adaptions.

10.  DEVICE INSTALLATION:

    (a) Remove the carburetor and install the device between the
        carburetor and manifold; cut the gas line and install the
        fuel regulator; install smaller jet.

    (b) Applies to all carburetored gas powered vehicles.
                                - 2 -

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                                   16
     (c)  The tools required are V wrench, screwdriver, small
         pipe cutter and 9/16" wrench.

     (d)  No equipment necessary to check proper installation.

     (e)  No adjustments necessary.

     (f)  The average mechanical skill is necessary.

 11.  DEVICE OPERATION:

     No instructions are necessary which pertain to its usage.

 12.  DEVICE MAINTENANCE:

     Maintenance is not necessary.

 13.  EFFECTS OF VEHICLE EMMISSIONS:

     Less fuel is used therefore less emmissioh and pollutants should
     result.

 14.  EFFECTS ON VEHICLE SAFETY:

     The device will not cause any unsafe condition.

 15.  TEST RESULTS:

     Automotive Testing Laboratories of East Liberty, Ohio will con-
     duct test on June 8 and 9, 1981 and the results will promptly
     be furnished to the EPA Laboratory in Ann Arbor, Michigan.


     Mr.  Korth, if there are any further requirements I would appreciate
it very much if you would promptly get in touch with me at the above
address and phone.  I will look forward to meeting you in the near fu-
ture.
                          Sincerely,
                          Barney^Q. Hopkins


BQH/reh


                                 - 3 -

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       17
s
              'A
    g=an
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                                                                 Attachment C'
                                    18
>        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

'                        ANN ARBOR.  MICHIGAN  48105



JUne 3°>  1981                                                      OFFICE OF
                                                             AIR, NOISE AND RADIATION
 Mr.  Barney Q.  Hopkins
 180  South Main Street
 Madisonville,  KY  42431

 Dear  Mr.  Hopkins:

 We  have received  your  recent application  for  an EPA  evaluation of  "The
 Glynn-50",  a  fuel  economy retrofit device.   We have  made a preliminary
 review of  your application  and  will  undertake  a  complete  review  upon
 receipt  of appropriate  test data  in accordance  with the provisions of my
 original  letter to you.   Our  preliminary  comments are as  follows.

     1.   Section No. 8(c)  does not provide sufficient descriptive  informa-
         tion for the following parameters.

         a.   Fuel pressure regulator:   Does  one size/design  apply to all
             engines?

        b.   Fuel metering  jets:   Does one  size/design  fit  all  carbure-
             tors?   How much is the diameter of the jet  reduced?

         c.   Venturi:  Does one size/design fit  all  engines?   How much is
             the inside diameter  of the  venturi throat reduced?

        d.   Heat source:   Does one size/design  fit  all engines?  What is
             the method  of  operation  (e.g.  electric, exhaust  gas, etc.)?
             Is  the heat  source  operating continuously  or  intermittantly?
             If  electric,  what is/are  the  power rating(s)?  Is data avail-
             able which  would show the  change in temperature  of the  air-
             fuel mixture  as a result of  the  heat source?   If so, please
             provide such  data.

    2.  Section No. 13   does  not address  non-regulated pollutants   ade-
        quately.   Please  identify  which  pollutants   were measured  and
        provide the specific  results.

    3.  Section No. 14   states  "the  device  will  not  cause any unsafe
        condition".   Because  "The  Glynn-50" is  changing the  air-fuel
        mixture ratio  and the  engine's  volumetric efficiency,  EPA is
        concerned  the  drivability characteristics  of  a  vehicle may he
        adversely  affected.  Does the  statement  within  Section No.  14
        take into  consideration  the  driveability aspect? With respect to
        the  affect on  driveability,  has  an evaluation been  made for the
        vast number  of  engine/vehicle  calibrations   available   on   late
        model   vehicles?   Is   test  data  available  which  would  provide
        assurance  that  the statement, is  applicable  to all vehicles?   If
        so,  please  provide such data.

    4.  Section No. 15 indicates  that  "The  Glynn-50"  will be  tested by
        Automotive  Testing Laboratories  (ATL)   of  East  Liberty,  Ohio.

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                           19
Following are  a  few points regarding the testing  I  would like to
stress.

First,  to  assure the  test  vehicles are  fully  broken in,  we ask
that  each  vehicle have at  least 4000 miles  accumulated  prior to
start of testing.   Selected  test vehicles should  a)  be typical of
most  vehicles  being  driven  today,  b)  be  in good mechanical condi-
tion  and,  c)  have a representative history  of  use.   Please refer
to  the  list   of  suitable  makes and  models  I provided to  you
earlier.

Second,  the minimum  test  requirements  consist of  at least  two
vehicles.   Each  vehicle  is  subjected  to   baseline  tests  which
consist  of  a  Federal  Test  Procedure  (FTP)  followed by a Highway
Feul Economy Test (HFET).  The FTP  and HFET  test  sequence is then
repeated, thus resulting in  four baseline tests per  vehicle.   The
retrofit device  is  then installed  and  the same test  sequence is
repeated,  thereby giving  a  total  of  four FTP  and four  HFET per
vehicle.   Of   course,   this  does   not   include  void  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 baseline test sequence and the installation of the device.

Third,  all  test  data  should  include  test  location (e.g.,  test
facility name),  test  cell  number,  test number,   and  test  date.
This will facilitate EPA's tracking of data during the evaluation.

Fourth,  your   supporting  test   data  should  include  a  detailed
description of each  test  vehicle used in the test program.   This
includes, but  is not limited to the following information:

    (1.)  Vehicle Identification Number

    (2.)  Model Year

   *(3.)  Model

   *(4.)  Body Style (e.g.,  2 door with hatchback)

   *(5.)  Curb Weight

    (6.)  Engine Displacement

    (7.)  Engine Family (from  the  emission  sticker in the  engine
          compartment)

    (8.)  Fuel System type  (e.g., 2 barrel carburetor)

    (9.)  Ignition System  Type (e.g.,  high energy breaker-less)

   (10.)  Emission  Control  System  Type  (e.g.,   air  injection
          reactor (AIR),  exhaust  gas recirculation  (EGR))

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                                   20
           (11.)  Transmission Type (e.g., automatic, manual)

           (12.)  Number of  transmission  gears (noting overdrive  or  lock
                  up features)

           (13.)  Drive axle ratio

           (14.)  Tire type, size, air pressures and brand name.

*Please refer  to 40 CFR 86.079-2 and 40  CFR 86.080-2 titled:   "Defini-
tions".   Copies  of   the   regulations  containing  these   sections   are
enclosed.   We  would like  to comment  on  your test  plan before  testing
begins.

In order  for EPA to process  our  evaluations  efficiently, we have  estab-
lished a  schedule for each.   I ask  that  you respond  to this letter  by
July 17 and  plan to submit  the required  test data  by August 3.   If  you
have any questions or require further information, please  contact  me.

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

Enclosures                   v^

cc: S. Syria

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                                                                 Attachment D
                                       21
..>•*-' '->v-.
*     «j.
 ;x^>  '>    UNITED  STATES ENVIRONMENTAL  PROTECTION AGENCY  -
\-\'^ y
-OV,|i^i- ;?                   ANN ARBOR. MICHIGAN
                                                                OFFICH OF
                                                        AIR AND WASTE MANAGEMENT
    July 22, 1981
    Mr. Barney Q. Hopkins
    180 South Main Street
    Madisortville, KY  42431
    Dear Mr. Hopkins:

    In a  letter  dated June  30,  1981,  we asked  for additional  information on
    your application  for  an EPA evaluation  of  "The Glynn-50".   Ue  also asked
    that you respond to our request by July 17.

    We have  not  yet received your  response.  If you  are still  interested in
    pursuing an EPA evaluation,  I ask that you contact  me by August 6.  Other-
    wise, we will  complete our  evaluation  based on  the information  we have.
    My telephone  number is  (313) 668-4299.   I  am  looking  forward  to hearing
    from you.

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

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