EPA-AA-TEB-511-82-11
EPA Evaluation of the Dynamix Device Under Section 511
of the Motor Vehicle Information and Cost Savings Act
by
Edward Anthony Earth
August 1982
Test and Evaluation Branch
Emission Control Technology Divison
Office of Mobile Sources
U.S. Environmental Protection Agency
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EPA Evaluation of the Dynamix Device Under Section 511 of the Motor
Vehicle Information and Cost Savings Act
The Motor Vehicle Information and Cost Savings Act requires that EPA
evaluate fuel economy retrofit devices and publish a summary of each
evaluation in the Federal Register.
EPA evaluations are originated upon the application of any manufacturer
of a retrofit device, upon the request of the Federal Trade Commission,
or upon the motion of the EPA Administrator. These studies are designed
to determine whether the retrofit device increases fuel economy and to
determine whether the representations made with respect to the device are
accurate. The results of such studies are set forth in a series of
reports, of which this is one.
The evaluation of the Dynamix device was conducted upon receiving an
application for an evaluation from the inventor/marketer of the device.
The device is claimed to permit an engine to operate efficiently on a
blend of gasoline and alcohol. The device is an auxiliary fuel system.
The following is a summary of the information on the device as supplied
by the Applicant and the resulting EPA analysis and conclusions.
1. Title;
Application for Evaluation of Dynamix under Section 511 of the Motor
Vehicle Information and Cost Savings Act
2. Identification Information;
a. Marketing Identification of the Product:
Dynamix (Alcogas Device/System)
b. Inventor and Patent Protection;
(1) Inventor
Jose Ma. R. Coneepcion
#30 Melantic Street
San Lorenzo Village
Makati, Metro Manila
Republic of the Philippines
(2) Patent
Republic of Philippines Patent 13218, U.S. Patent pending
c. Applicant;
Jose Ma. R. Concepcion
#30 Melantic Street
San Lorenzo Village
Makati, Metro Manila
Republic of the Philippines
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d. Manufacturer of the Product;
(1) Philippines - Vulcan Industrial & Mining Corporation
Pioneer Street, Mandaluyong, Rizal
Republic of the Philippines
U.S. & International Market - Under Negotiation
(2) Chairman of the Board - Mr. Fred Velayo (representing the
Herdis group of Companies)
President - Mr. Walter Brown
Vice-President - Annabelle P. Brown
Treasurer - Mr. Fred Ramos
Note: "The above are manufacturer/licensees of the device
for the Philippines belonging only to Vulcan Industrial &
Mining Corp."
3. Description of Product (as supplied by Applicant);
a. Purpose;
"An add on device for the conventional [internal] combustion
engine (gasoline fed) to efficiently mix hydrous alcohol as low
as 160 proof or even lower with regular gasoline in vapor form
and in recommended proportions of 30% alcohol to 70% regular
gasoline.
"Note; The device can however operate on a wider range of
proportion including pure alcohol or pure gasoline, at the
option of the motorist. The above add on device can efficiently
use the above fuels on an unmodified engine."
b. Theory of Operation;
"While alcohol is considered as a leading source of alternative
form of energy by reason of past utilization by several
countries in the past, it is not without problems. Mainly the
need to use waterfree alcohol (anhydrous 199.5 proof) to prevent
phase seperation, which can cause deteriorated engine
performance; cold starting problems; comparatively higher fuel
consumption (than if you were to use pure gasoline); the high
solvent action of alcohol causes fuel line impurities to get
dislodged and clog up the carburetor jets to cause engine
stalling, corrosion, and other undesirable factors. The
af©restated, result from the traditional method of blending
alcohol with gasoline in one fuel tank particularly in mixed
fuel proportions higher than 20% alcohol to a proportionate
amount of gasoline.
"Other Considerations;
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(1) "Cheaper Fuel
"Furthermore, even on the assumption that there is
troublefree operation in the traditional way of blending
alcohol to gasoline, now more popularly referred to as
"gasohol", the strongest deterrent in its widespread
application throughout the world is the high cost of
producing anhydrous alcohol, in view of the additional
infrastructure required to dehydrate the alcohol as
compared to the prevalent alcohol distilleries throughout
the world producing 189 proof-alcohol. Additional
distillation/dehydration columns have to be added to the
conventional alcohol distillery producing 189 proof
alcohol, not to mention the higher cost of operation due to
more manpower and energy required to produce it. 160 proof
alcohol is even cheaper to produce than 189 proof. The
efficient utilization of this type of fuel alcohol alone
can result in considerable savings.
(2) "Vaporization Thru Heat
"The high latent heat of alcohol requires a higher source
of heat. To vaporize alcohol sufficiently, the heat source
must be other than the fuel line or the heating of the
incoming air thru the intake manifold. If you heat the
fuel line of the alcohol, you will develop vapor lock and
the engine will stall. If you heat the incoming air, you
will dilute the fuel and air charge and reduce the
volumetric efficiency and reduce the power output of the
engine. The heat must therefore be supplied in a localized
point to vaporize alcohol and yet not affect the two
aforementioned factors affecting fuel delivery and the
volumetric efficiency of the air/fuel charge.
(3) "Utilization of Waste Heat
"Likewise, the heat supplied should be inexpensive, not
draining additional energy from the engine or the
electrical system. Ideally then, it must utilize waste
heat.
(4) "Supplying Air and Alcohol Fuel in Metered Quantities
"The need likewise exists to supply air and fuel alcohol in
metered quantities into the intake manifold of the engine
since an indiscriminate supply of either factor could
adversely affect engine operation. A system must therefore
be incorporated into the device/system that will supply
fairly adequate supply of air and fuel alcohol in response
to the varying needs of the engine at different RPMs. The
device/system must therefore attempt to equal if not
surpass the conventional carburetor which even in its
present form is still an admittedly inefficient supplier of
vaporized fuel and air in precise quantities at any given
time of engine operation."
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c. Construction and Operation;
"... the device/system operates as follows:
(1) "It utilizes 160 Proof alcohol. (Some road tests were
conducted using as low as 140 proof.) This type of alcohol
is much cheaper than 199.5 proof anhydrous alcohol.
(2) "Heated air coming from a heat exchanger with air supplied
from the PCV and air cleaner passing thru [through] a small
pipe, combine with finely sprayed alcohol in a vaporization.
chamber, just before the intake manifold. Heated air
easily achieve temperatures of 120 degrees C and higher.
Dynamometer tests show that this heat source does not
deteriorate engine power. On the contrary, power is
consistently improved, percentages of power increases
varying with engine types. Superior vaporization have
resulted in improved mileage, in such tests. Likewise, the
fuel/air charge have not been diluted inasmuch as the
increased volumetric efficiency improved the power. There
have never been an instance of fuel line vapor lock
throughout the dynamometer and extensive road tests.
(3) "A jacketed heat exchanger easily attached to the exhaust
pipe immediately after the exhaust manifold heats up the
air coming from the PCV and air cleaner before it is sucked
thru the vaporization chamber where it combines with
sprayed alcohol. The heat from the exhaust pipe is free.
The system makes efficient utilization of the waste heat of
the exhaust pipe to supply heat to the alcohol.
(4) "The air coming from the PCV has a PCV valve, and likewise
with the air coming from the air cleaner. When there are
no PCV valves, the system is supplied. Most motor vehicles
are now provided with such PCV valves which supply
additional air to the intake manifold in accordance with
vacuum pressures and which are already calibrated by the
various automotive/truck manufacturers into their
respective engines. The device/system, simply makes use of
the existing system of supplying additional air into the
intake manifold, thus metering of the air is achieved.
"An accelerator valve directly coupled into the carburetor
throttle valve controls the flow of fuel alcohol. The
opening and closing of the accelerator valve is in
conjunction with the opening and closing of the carburetor
throttle valve. Likewise, fuel metering is achieved.
Openings are adjusted in accordance with engine types and
displacement, also bearing in mind the fuel to air ratios
of the type of alcohol utilized." A drawing of the system
is provided in Figure 1 of the Attachment B.
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(5) "Manner of Operation - Basically, the system of operation
is on the basis of dual fuel simultaneously fed into the
combustion chamber in vaporized form. The conventional
carburetor supplies gasoline in vaporized form into the
combustion chamber in the usual manner. The alcohol fuel
is vaporized thru this novel system of vaporization whereby
the heated air combines with the fuel, and subsequently
combines with gasoline, both of which fuels are in vapor
form. They combine at a point just before the combustion
chamb er.
"The device therefore uses two kinds of fuels
simultaneously, using two fuel tanks independent of each
other using their respective fuel pumps, filters, and pass
thru a metering device that proportionately meters the
desired percentage of fuel passing thru it. The alcohol
system follows the following sequence in liquid/vapor flow;
From the fuel tank, the fuel passes thru the electric fuel
pump which forces the fuel to flow to the engine, then thru
a filter, the proportioning valve, the accelerating valve,
the vaporizing chamber, and into the intake manifold in
vapor form."
4. Product Installation, Operation, Safety and Maintenance (as supplied
by Applicant);
a. Applicability:
(1) "In view of the systems utilization of the stock parts of
the motor vehicle, virtually all gas-driven gasoline
engines can be provided with the device."
(2) "The only inhibiting factor would involve the engine having
no PCV valves. In such a case, the installer can make use
of such valves provided for in the kit, and install same in
the same manner and form as indicated in the installation
manual.
"The kit cones in two sizes;
Type A - From, 1,000 cc to 3,000 cc engines
Type B - From 3,000 cc to 10,000 cc engines"
b. Installation - Instructions, Equipment, and Skills Required;
(1) Device Installation - General Instructions;
(a) "Installation of the alcohol fuel tank in the trunk of
the motor vehicle or in any suitable place beside or
opposite the fuel tank of pick-ups and trucks. In
which case, the alcohol fuel tank should be strapped
securely in the chassis in a manner similar to that of
the conventional gasoline fuel tank."
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(b) "The electric fuel pump should then be installed
beside the fuel tank, preferably in the lowest level
of the fuel tank immediately preceded by an in-line
fuel filter. The level of the electric fuel pump
should not be higher than 2 feet from the lowest level
of the fuel tank."
(c) "The proportioning valve shall then be installed in a
readily accessible place in the engine's firewall.
The alcohol fuel line should be in series with the
alcohol valve and the same series installation should
be made with the gasoline fuel line. The cuts in the
fuel line should be carefully made and connected with
supplied rubber connectors." A drawing of the
proportioning valve is provided in Figure 2 of the
Attachment B.
(d) "From the proportioning valve, the alcohol fuel line
proceeds to the accelerating valve or solenoid valve.
The accelerating valve should be installed in
conjunction with the accelerator pedal. The action
should be the same as the action of the throttle
valve. When the accelerator pedal is depressed, the
connecting action on the accelerator should open the
throttle valve of the carburetor. The same action
should govern the opening and closing of the
accelerating valve, which is normally connected to the
carburetor by a bracket normally connected to the
carburetor bolts in the base of the carburetor. The
suitable and recommended installation is as follows:"
A drawing of the accelerator valve and linkage is
provided in Figure 3 of Attachment B.
(e) "Vaporizing Chamber - Most gas-driven motor vehicles
are provided with an orifice in the intake manifold of
the. engine. In such a case, the plug is removed and
the vaporization chamber is installed in its place.
Where such an orifice is not present, the PCV line is
connected in the intake manifold, the PCV line is
removed and the vaporization chamber is installed in
its place. The PCV line is then provided with a
connector that is then connected in the air inlet side
of the vaporization chamber." A drawing of the
vaporizing chamber is provided in Figure 4 of
Attachment B.
(f) "The heat exchanger is then attached to the exhaust
pipe, in the closest and most convenient place after
the exhaust manifold. The PCV line [is] connected by
a tee connection from the air cleaner line, is then
attached to the inlet side of the heat exchanger. The
exit side of the heat exchanger is connected to the
vaporization chambers' air inlet side. Please refer
to the following diagram." A drawing of the heat
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exchanger and heated air system is provided in Figure
5 of Attachment B.
(2) "Tools required for installation.
"In addition to the usual complement of small tools that
most mechanics are provided, a set of tube flaring and
cutting tools should be added."
(3) Equipment required to check accuracy of installation.
(a) "Vacuum gauge. 0 to 30 negative pressure and from 0
to 5 psi.
"The vacuum reading should be taken prior to the
installation of the vaporization chamber. The vacuum
gauge may be tapped to the vacuum line of the brake
booster and a vacuum reading taken. Subsequently,
another reading should be taken following the
installation of the vaporization chamber. If only a
small drop is shown in the reading, for instance,
between 1 -2 atm. [psi] then the reading is normal. A
greater amount of drop shows a leak in the system and
all fittings and connections should be checked.
"On the positive pressure test of the vacuum gauge, to
test the fuel line, the electric fuel pump should be
activated. After bleeding the system free of all air,
and a consistent pressure drop takes place, then the
fuel line should be checked for leaks.
(b) "Flowmeter - to check" the rate and flow of the fuel.
(c) "Pulse Indicators - All electric fuel pumps are
provided with pulse indicators connected to the
contact point and each opening and closing of the
contact point is transmitted to an electric bulb or
LED in the instrument panel. Depending on the
distance of the electric fuel pump to the vaporization
chamber, each pulsation can be calibrated in each
vehicle by measuring the fuel volume by cc in relation
to the pulsation of the electric fuel pump." A
drawing of the wiring diagram is given in Figure 6 of
Attachment B.
(4) "Adjustments to the Vehicle or Vehicle Systems as well as
the Device Following the Installation.
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(a) "The flowmeter should be attached to the gasoline
line. The flowrate should then be monitored at a
point just before the red-line* of the tachmometer
(while the vehicle is in motion). After the flowmeter
is disconnected, the flowmeter should be attached to
the alcohol fuel line, and the alcohol flow should be
adjusted to 30% of the gasoline flow rate previously
taken a point close to the red-line of the tachometer.
The adjustment should be made on the proportioning
valve, at which point the accelerating valve should be
inoperative.
(b) "The accelerating valve should be set in such a manner
that the metering valve should be closed at idling
speed. It should only start to open at approximately
1/10 of the total throttle linkage travel.
(c) "The electric micro switch should be similarly
adjusted. It should only activate at a point 1/10 of
the total throttle linkage travel.
(d) "The idling air should be slightly closed, to
compensate for the additional air from two PCV
valves. The distributor may likewise be slightly
advanced to take advantage of the anti-detonation
characteristics of alcohol. Generally upwards of
about 2 degrees BTDC can be added depending upon the
engine type and condition.
(e) "The system will still work effectively even without
modifying the distributor."
(5) Skills Associated with the Installation of the Device
"A skilled mechanic with some knowledge of electrical
wirings and the use of the vacuum gauge and flowmeter.
Most 'week-end' mechanics with moderate knowledge of the
above skills should likewise be able to manage."
c. Operation;
"After the engine has sufficiently warmed up, the system is
activated by putting the power switch on, in the control box and
which control box is normally placed in a convenient place in
the instrument panel.
"This activates the electrical system which involves the
electric fuel pump, accelerator switch, and the pulse (fuel
flow) indicator.
*Maximum allowable rpm recommended by the engine manufacturer.
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"At idling speeds and very low RPMs, the system is not activated
and only the normal gasoline flow takes place. Once the pedal
is depressed, to place the vehicle in motion and at accelerating
or cruising speeds, the alcohol system is activated. When
decelerating or idling, the system is automatically deactivated.
"The heated air entry into the intake manifold is automatically
regulated by the PCV valves additionally installed or is
normally provided in the stock system. At low intake manifold
vacuum pressures (as when accelerating or at cruising speeds)
more air is admitted into the system. At high vacuum inlet
manifold pressures, (as when idling) very little air is admitted
into the inlet manifold.
"The amount of air admitted into the inlet manifold therefore
varies in accordance with vacuum pressures and is fairly
efficient air metering device, standard in most motor vehicles
today.
"The bleeding of additional air into the inlet manifold
(together with additional alcohol fuel) likewise reduces the air
flow thru the carburetor and reduces the supply of vaporized
gasoline extracted from the carburetor in proportion with the
orifice size in the inlet manifold and the amount of air passing
thru the orifice.
"Before putting out the engine, the alcohol system should be
deactivated. However, no harm can take place even if it is
inadvertently forgotten to be switched off."
d. Effects on Vehicle Safety;
"The only possible hazards involving the use of the device
involve the escaping fumes of leaking alcohol from the fuel
system. The human body's tolerance to alcohol fumes can be
considered non-hazardous unless alcohol in considerable
quantities is spilled in a sealed and non-ventilated passenger
compartment. In which case, dizziness can occur. Such a
possibility is however remote as the fuel system does not pass
thru the interior of the motor vehicle [but] along the chassis
[to where the] proportioning valve is attached to the firewall
of the engine side.
"The air fuel system [is] contained in sealed lines, none of
[these] components expose the alcohol fuel to the atmosphere."
e. Maintenance:
"Post Installation check-up should be made within 15 days or 500
kms. whichever comes first. It will involve the following:
Schedule I - Check for any air or fuel leaks
Schedule II - Check for the proper operation of the
electric fuel pump
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Schedule III - Check for any clogging of the fuel jets and
clean same if necessary
Schedule IV - Check fuel filter and clean if necessary.
Check calibration of alcohol fuel rate.
Schedule V - Check proportioning valve and accelerating
valve for clogging or leaks and correct.
"Recommended Maintenance Schedule of the Device:
"Every 30 days Every 90 Days Every 120 Days
or 1,500 Kms. or 3,000 Kms. or 4,500 Kms.
Sched. I & III Schedule I to IV Schedule I to V"
5. Effects on Emissions and Fuel Economy (submitted by Applicant);
a. Unregulated Emissions;
"Virtually all pollutants, HC, CO and even NOx are reduced.
Even while low grade alcohol is used (160 proof), the efficient
vaporization resulting from the combination of finely sprayed
fuel with heated air (120 degrees [celsius] plus) reduce water
vapor in even less quantities than those emitted in the
operation of the automobile without the device.
"The only [problem that a] malfunction in the supply of alcohol
will [cause is that it will] simply deactivate the entire system
(malfunction of the electric fuel pump)."
b. Regulated Emissions and Fuel Economy;
•' No data was provided with the application. Limited data were
supplied with the applicant's response, Attachment E, to EPA's
request for additional information, Attachment D.
6. Analysis
a. Identification Information;
(1) Marketing Identification; In section 2a the applicant
identified the device as the "Dynamix" (Alcogas
device/system). In the cover letter accompanying the
application, the applicant also referred to the device as
the "Dynamix (alcohol/gasoline add on device)". The
applicant's response, Attachment E, to EPA's initial
request for additional information included test data for
this device identified as "Alcogas dual flow device". All
three identifications are variations of the name for the
same device.
A related product for diesel engines was also referred to
in the information submitted on the gasoline/alcohol
device. This diesel/alcohol system was referred to as the
Powerflo (alcodiesel device) and the alcodiesel dual flow
device. No description of this diesel/alcohol device was
provided.
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(2) The applicant stated in Attachment E that an intake
manifold adapter is provided when necessary to ensure that
the alcohol entered the manifold at the center. Since
there are many different configurations of carburetor
bases, several different adapters (and thus model numbers)
would be required. Therefore, the marketing identification
of the device is judged to be incomplete.
(3) Inventor and Patent Protection: The original application
did not include a copy of the patents. After reviewing the
application, EPA requested, see Attachment D, a copy of the
Republic of Philippines patent no. 13218 and U.S. Patent
application covering the device. The applicant's response,
Attachment E, did not include a copy of the Republic of
Philippines patent. The applicant provided no response to
a subsequent request, Attachment F for this patent. The
only U.S. patent information supplied was a copy of the
filing document for the U.S. Patent (Attachment A). This
document provided no drawings or detailed description of
the device.
(4) Applicants The applicant was identified in Section 2c as
Mr. Jose Ma. R. Concepcion. However, all correspondence
received from the applicant was on stationery with a
Tricontech Inc. letter head. Mr. Concepcion1s position
with Tricontech Inc. was not stated nor is there indication
of this company's connection with the device.
b. Description;
(1) The primary purpose of the device is to allow a vehicle to
efficiently operate on a blend of gasoline and hydrous
ethyl alcohol. The important feature of this device is
that the alcohol does not need to be water free since it is
introduced in a vaporized form and the alcohol is contained
in a separate fuel system. Normally, vehicles operating on
a liquid fuel blend of gasoline and ethyl alcohol must use
water-free alcohol to prevent phase separation (the water
will separate out of the alcohol/gasoline mixture) and the
problems associated with having liquid water in the fuel
system. The alcohol may also attack parts of a standard
fuel system.
The applicant also stated in Section 3b that the device
would allow a vehicle to operate on a much wider range of
fuel combinations - from only hydrous ethyl alcohol to only
gasoline. EPA asked the applicant (Attachment D) if
vehicles had been successfully operated over a wide range
of fuel proportions and with what alcohols. The applicant
replied (Attachment E) that vehicles had been
satisfactorily operated with a wide range of gasoline/
hydrous ethanol blends, but that the engines stalled during
prolonged idle when operating only with 160 proof ethanol.
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EPA also asked the applicant (Attachment D) if other
alcohols could be used. Since the applicant did not
respond to this question, it is not known if the device is
able to operate properly with other alcohols.
(2) The theory of operation given in Section 3b adequately
describes the problems encountered with the use of a
gasoline/ethyl alcohol fuel blend and the approach the
device takes to overcome these problems.
(3) The description of the device given in Section 3c does not
adequately describe the Dynamix device. The description of
the major components of the system is only given in general
terms. However, a detailed description of the major
components was not provided. EPA's request (Attachment
D & F) for more details of the proportioning and
accelerating valve was only partially answered by the
applicant's one technical reply (Attachment E).
The description of the proportioning valve is not
sufficient to show that is is actually able to function as
claimed. The description does not specify how the device
is able to control the flow of gasoline to be a fixed
percentage (i.e., flow ratio) of the alcohol flow and how
this flow ratio is readily adjustable by the operator.
The description of the "accelerating valve" was also
inadequate. Although it was called an accelerating valve,
it appears to be more properly an alcohol flow control
valve that is opened and closed by the throttle linkage.
It does not replace the function of the carburetor
accelerator pump. The functioning of this valve is also
questionable. The linkage adjustment procedures instruct
the installer to adjust this valve so that it is shut off
at idle and is open at engine red-line (while in gear)
sufficiently to control the alcohol flow to be the desired
alcohol/gasoline fuel ratio. Therefore, the alcohol flow
is controlled to be a function of throttle position only,
regardless of engine load, whereas, in an unmodified
engine, gasoline flow is controlled to be a function of
both load and rpm. Thus the engine could have either too
much or too little of this gasoline/alcohol blend under all
operating conditions.
An additional problem is that the normal supplemental
carburetor circuits (idle, accelerator pump, and power
enrichment) probably will not function normally due to the
reduced flow of gasoline and air into the carburetor. The
device appears to have no means to incorporate these
necessary auxiliary carburetor functions into the alcohol
system. The applicant did not respond to EPA's requests
(Attachment D & F) for this additional information.
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The applicant also states that "... the increase in
alcohol fuel makes up for the energy lost by gasoline.
However, quick and easy accelerating valve adjustments are
necessary to effect this condition." (Attachment E) This
implies that problems in obtaining the proper amount of
fuel are readily overcome by the driver. However, since
this valve is mounted under the hood, the operator is
unable to readjust the fuel flow to current driving
conditions while operating the vehicle.
The vaporized alcohol is introduced at any convenient hole
in the intake manifold. This will cause uneven fuel
distribution to the various cylinders if either the hole is
not centrally located or there is uneven mixing of the
vaporized alcohol and gasoline. EPA asked the applicant to
comment on this mixing problem (Attachment D). The
applicant's response indicated that he was aware of the
problem and now uses a carburetor base plate adapter to
allow the vaporized alcohol to be introduced at the center
of the intake manifold (Attachment E). This approach will
tend to make the fuel mixture more uniform. However, the
applicant submitted no information that showed that good
mixing and distribution actually occurred.
(4) The device is claimed to permit an existing vehicle to be
modified to operate on a combination of alcohol and
gasoline. However, there is no data that showed that
modified vehicles had performed satisfactorily in normal
usage.
(5) The cost of the device plus installation is not known.
EPA's request for cost information (Attachment F) was not
answered. Due to the lack of specific details about the
device, EPA is also unable to estimate the cost or time
required for installation of the device.
c. Installation, Operation, Safety and Maintenance:
(1) Applicability;
The applicability of the product, as stated in the
application, to essentially all gasoline vehicles is
questionable. Necessary carburetor baseplate adapters may
not be made for all vehicles. Also, the fuel injection
systems of most fuel injected gasoline vehicles would not
function satisfactorily with these reduced gasoline flow
rates.
(2) Installation - Instructions, Equipment and Skills Required:
The installation instructions for the device provide a
generalized but reasonably complete description of how the
device is to be installed. However, there are several
major problems not addressed.
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The device may not contain all the necessary components and
parts. EPA asked the applicant if the accelerating valve,
electric fuel pump, heat exchanger, carburetor adapter,
hoses, fittings, wiring, etc. necessary for the
installation were provided with the device (Attachment F)
but received no response. If these components and parts
are not provided, the installer would have to have a
working knowledge of the system and expend considerable
effort to acquire the required parts and to insure all
components are compatible.
As stated only "... the usual complement of small tools
that most mechanics are provided..." would be required for
the installation. However, the proper adjustment will
require a fuel flowmeter and possibly the use of a vehicle
chassis dynamometer (Attachment E). A fuel flowmeter is
not a normal mechanic's tool and a chassis dynamometer is a
very expensive piece of specialized testing equipment. Few
mechanics would even have access to these necessary items.
The adjustment procedures 4b(3)(a) require the engine fuel
flow to be measured at engine redline while in gear.
Besides the safety hazard and potential for engine/
transmission damage this presents, it would be difficult to
obtain the necessary measurements. The applicants response
to EPA's concern about the safety of this procedure was
that the procedure had been modified. The applicant stated
that he now measures the flow rate with the vehicle on a
chassis dynamometer and, by doing this for many
representative vehicles, has developed a table of
recommended flow rates for a given application. However,
the applicant did not provide this table of recommended
settings or provide the revised adjustment procedures.
Even if this table were available it might not cover an
individual's vehicle model or specific combination of
vehicle and powertrain. Therefore an installer would
either need access to a chassis dynamometer or have to
revert to the potentially unsafe road procedure.
The applicant understates the skill level and knowledge
required to install the device. Proper installation and
adjustment of the Dynamix device will require above average
mechanical skills plus a good understanding of the theory
and operation of the device. It is unlikely most weekend
mechanics or many professional mechanics will be able to
properly and safely install and adjust the device.
(3) Operation;
The operation of the system presented by the applicant in
Section 4c is that it is only necessary to switch the
device on, after starting and the engine is warmed up, and
then off prior to turning the engine off. However, in
practice, operation of the system would require
considerably more operator attention.
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Since a vehicle with the device is dual fueled and will use
large amounts of ethyl alcohol, the operator will need to
provide storage and handling for the alcohol since it is
unlikely to be located at a nearby service station.
The system does not provide an alcohol fuel gauge. Since a
considerable amount of alcohol would be burned and running
out would cause the engine to stop, a fuel gauge should be
provided.
A feature of the system is the ability to choose different
proportions of alcohol and gasoline. Although this can be
accomplished by adjusting the control on the proportioning
valve, to maintain a correct overall air/fuel ratio the
accelerating valve linkage would also need to be
readjusted. The user would have to develop the data to
determine the proper new settings. These adjustments can
only be performed when the vehicle is parked since the
proportioning and accelerating valves are in the engine
compartment.
(4) Effects on Vehicle Safety;
In Section 4d, the applicant identifies some of the safety
hazards associated with the device and properly notes these
identified hazards are minimal. However, he overlooked
several hazards that are more serious and much more likely
to occur.
Use of the device will require large amounts of ethyl
alcohol. Unless alcohol is available at a service station,
the operator of the vehicle will need to provide for the
safe storage and handling of large amounts of a highly
flammable liquid.
The routine maintenance checks will require partial
disassembly of the alcohol fuel system in the engine
compartment, thus presenting another safety hazard.
Finally, the installation adjustment procedure requires
that the vehicle be operated at engine redline while in
gear. Exceeding this engine rpm could lead to engine/
drivetrain damage. Also, since it may be necessary to
perform this adjustment procedure on the road while
monitoring other system parameters, this procedure could
cause accidents.
(5) Maintenance;
The maintenance schedule given in Section 4e is judged to
be adequate. However, checking the items required will
require partial disassembly of the system. Since these
maintenance requirements occur quite frequently, every 30
days or 1500 kilometers, the vehicle operator will probably
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17
need to be able to perform, many of these checks. Checking
the required items will require average mechanical skills,
a working knowledge of the device, and the usual complement
of mechanic's small tools.
d. Effects on Emissions and Fuel Economy;
(1) Unregulated Emissions;
The applicant submitted no test data and made no claims
regarding unregulated emissions. The statements given in
Section 5a relate to regulated emissions only.
An EPA sponsored study (1) showed that aldehyde emissions
were relatively unaffected by the use of gasohol (gasoline
with 10% ethyl alcohol). Also, there were no significant
quantities of ethyl alcohol observed in the exhaust. A
similar result could be expected for the Dynamix device
when operating with a 10% alcohol concentration if the
device functions as stated and is properly matched to the
vehicle. The effects on unregulated emissions are unknown
when operating the device with higher alcohol
concentrations since vehicles tested with higher alcohol
concentrations normally have had engine modifications.
(2) Regulated Emissions and Fuel Economy;
The applicant did not submit test data in accordance with
either the Federal Test Procedure or the Highway Fuel
Economy Test. These two test procedures are the primary
ones recognized by EPA for evaluation of fuel economy and
emissions for light duty vehicles(2).
The test data which was submitted consisted of a limited
amount of fuel economy data for passenger cars on the road,
steady state passenger car and light duty vehicle tests on
a chassis dynamometer, and a heavy duty engine dynamometer
test (Attachment D). This data did not substantiate the
fuel economy claims for the device. Although emission
benefits were claimed, no supporting data were supplied.
(1) "Gasohol, TEA, MTBE, Effects on Light Duty Emissions," EPA
460/3-79-012
(2) The requirement for test data following these procedures is stated in
the policy documents that EPA sends to each potential applicant. EPA
requires duplicate test sequences before and after installation of the
device on a minimum of two vehicles. A test sequence consists of a cold
start FTP plus a HFET or, as a simplified alternative, a hot start LA-4
plus a HFET. Other data which have been collected in accordance with
other standardized procedures are acceptable as supplemental data in
EPA's preliminary evaluation of a device.
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18
The applicant was advised of our requirement that
applicants submit appropriate .test data to substantiate
their claims. He was reminded of the test requirements and
our obligation to publish the results of our evaluation
(Attachments C, D, G, H, I, and J). Although he was given
adequate time to comply, no further data or information was
provided. Therefore, our evaluation was completed on the
basis of the information available and EPA's engineering
judgement.
EPA has performed only a limited amount of testing with
gasolines containing ethyl alcohol. For 'gasohol', a blend
of 10% ethyl alcohol in gasoline, EPA's test program showed
that the expected result would be higher evaporative
emissions, lower hydrocarbon and carbon monoxide emissions,
and poorer fuel economy (3). However, because the
applicant failed to provide valid test data or an adequate
description of his device, it is impossible to determine if
the Dynamix device would perform in a similar manner. The
device uses a wide range of ethyl alcohol to gasoline
ratios, is able to use hydrous ethyl alcohol, and uses a
different fuel induction system.
7. Conclusions
EPA fully considered all of the information submitted by the
applicant. The evaluation of the Dynamix device was based on that
information.
The information supplied by the applicant was insufficient to
adequately assess if the device would mechanically function as
claimed. The applicant failed to respond to repeated requests for
this additional information.
The limited fuel economy test data supplied were inconclusive.
Although emission benefits were claimed, no supporting data were
supplied. The applicant was advised by letter and by telephone on
several occasions of EPA's requirement that applicants submit
appropriate test data to substantiate their claims. Although he was
given adequate time to comply, no further data or information was
provided. Therefore, our evaluation was completed on the basis of
the information available and EPA's engineering judgement.
The installation and adjustment, operation, and maintenance of the
Dynamix device will expose the installer or operator to serious
safety hazards.
(3) "Gasohol Test Program", EPA Test and Evaluation Branch report 79-4A.
Part of the decrease in fuel economy is due to the fact that ethyl
alcohol has a lower energy content than the gasoline it displaces.
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19
The installation of the Dynamix device on a vehicle would require
many hours and need to be done by a skilled mechanic who has had
specialized training. Specialized tools and equipment would be
needed for the post installation adjustments.
The applicant's concept of modifying vehicles to operate on a dual
fuel system appears to be a potentially viable approach for operating
a vehicle on a combination of gasoline and ethanol. However, without
a detailed description of the device or valid supportive test data,
there is no technical basis to support any claims that the Dynamix
device improves fuel economy, reduces emissions, or provides an
acceptable method of using an alternate fuel.
FOR FURTHER INFORMATION CONTACT; Merrill W. Korth, Emission Control
Technology Division, Office of Mobile Sources, Environmental Protection
Agency, 2565 Plymouth Road, Ann Arbor, Michigan 48105, (313) 668-4299.
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20
Attachment A
Attachment B
Attachment C
Attachment D
Attachemnt E
Attachment F
Attachment G
Attachment H
Attachment I
Attachment J
List of Attachments
Patent Application (provided with 511 Application)
Figures 1 through 6 (provided with 511 application)
Letter of September 23, 1981 to Jose Ma. R. Concepcion
acknlowedging receipt of application.
Letter of September 30, 1981 from EPA to Jose Ma. R.
Concepcion requesting clarification and additional
information.
Letter of October 19, 1981 from Triconteck Inc. to EPA
in response to EPA request.
Letter of November 19, 1981 from EPA to Jose Ma. R.
Concepcion requesting clarification and information
for items not fully covered by prior response
(Attachment F).
Letter of January 11, 1982 to Jose Ma. R. Concepcion
repeating request for information.
Letter of February 11, 1982 from EPA to Jose Ma. R.
Concepcion repeating the request for information and
allowing additional response time.
Letter of March 26, 1982 from EPA to Jose Ma. R.
Concepcion providing copies of Attachments E, F, and G
and advising applicant EPA was considering completing
the evaluation with the information presently provided.
Letter of April 20, 1982 from EPA to Jose Ma. R.
Concepcion notifying applicant that EPA would shortly
close out the. evaluation if inadequate test data and
description of the device weren't provided.
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21
Attachment A
Patent
The patent information provided with the application was a single page of
a form which is used in the course of filing for a patent. This form
contained no technical information about the device.
Similarly, the single page patent 'Notice of Allowance' provided as part
of the Attachment D contained no technical information about the device.
Therefore, neither of these documents is provided as attachments to this
evaluation.
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Attachment B 22
Control Pan«l
Figure 1 Dynamix System
At* «
•« I
' I
' I
I I
* t
I »
I I
i •
I •
1 t
t
e
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r*
**
ft
y
Jjl
1
Figure 2 Proportioning Valve
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23
Figure 3 Accelerator Valve and Linkage
t U"
Figure 4 Vaporization Chamber
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24
1 I
Figure 5 Heat Exchanger and Heated Air System
*
ft>W«T
pV*-*
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Attachment C
25
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN AR3GR. MICHIGAN 48105
OFFICE OF
AIR AND '.YASTE •.: A .\ A G E v. E -
September 23, 1981
Mr. Jose Ma. R. Conception
Triconteck, Inc.
The Manila Hilton, Suites 120 to 135A
United Nations Avenue
Ermita, Metro Manila
Philippines
Dear Mr. Conception:
We have received your application for an EPA evaluation of the "Dynamix"
device. Our evaluation group is making a preliminary evaluation of the
information that you enclosed and we will contact you in the near future
concerning the next actions to be taken.
If possible, when you visit North America during November, we would wel-
come your visiting the EPA Laboratory in Ann Arbor, Michigan to discuss
your device and the EPA evaluation process. We would like to work with
you in designing a plan to test your device at an independent laboratory
here in the United States.
If you could telephone me when you arrive at the Mexico trade fair, we
can work out final arrangements for your visit to Ann Arbor. My phone
number is (313) 668-4299.
Sincerely,
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch
cc: J. White
511 file "Dynamix"
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Attachment D
26
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
September 30, 1981
OFFICE OF
AIR AND WASTE MANAGEMENT
Mr. Jose Ma. R. Concepcion
//30 Melantic Street
San Lorenzo Village Makati
Metro Manila
Republic of the Philippines
Dear Mr. Concepcion:
We have received your application for an EPA evaluation of the "Dynamix"
device. Our Engineering Evaluation Group has reviewed your application
and has identified several areas that require additional clarifications
prior to further processing of your application. The questions are
listed below .according to the section numbers of your 511 application.
1. Section III, B, Patent Protection. We ask that you submit a copy of
RP patent 13218 and the U.S. patent application.
2. Section VIII Description of the device
A. Section VIII, A. states the device normally operates in the
recommended proportions of 30% alcohol to 70% regular gasoline.
Is this 30% alcohol the 160 proof hydrous alcohol mixture, or
does this mean the alcohol content in the hydrous alcohol mix-
ture is in a ratio of 30% pure alcohol to gasoline?
B.
C.
D.
Section VIII, A. states regular gasoline
country use unleaded gasoline.
Most vehicles in this
Section VIII, A. states that a wider range of proportions can be
used, including only alcohol and only gasoline. Have modified
vehicles been successfully operated only on gasoline? only
alcohol? which alcohols? what range of proofs (water content)?
Section VIII, C. states the proportioning valve meters the
desired percentage of fuel passing through it. By fuel, I
presume you mean gasoline. That is, the amount of gasoline flow
is controlled to be a preset ratio of the hydrous alcohol flow
rate (normally 70% gasoline to 30% hydrous alcohol). The
alcohol flow is controlled solely by the alcohol accelerator
valve. Is this correct?
E. Details of the proportional valve and its controls are needed.
F. The device appears to restrict the flow of gasoline to a set
percentage of the alcohol being consumed. It appears that under
most driving conditions, the carburetor float bowl will not be
full and in fact may be relatively empty. If this is correct,
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27
-2-
the carburetor, idle circuits, accelerator pump, and power
enrichment circuits will not function properly. There is
apparently no function in the alcohol circuits to take over
these functions. Is this correct?
3. Section IX, F. shows the vaporization chamber located in any
convenient orifice in the intake manifold or the manifold PCV hole.
It appears that this would not give an identical homogenous mixture
of air, hydrous alcohol and gasoline to each cylinder for most
vehicles. Please comment and provide data.
4. Section X, I. states that for adjusting the device and vehicle, the
gasoline flowrate is taken "at a point just below the red-line of the
tachometer while the vehicle is in motion". This adjustment
procedure is unacceptable. It would require the vehicle to be
operated at maximum speed for an extended period and thus present a
safety hazard.
If you are able to visit EPA when you come to North America early in
November, we could discuss the questions listed in this letter. If you
can not come to EPA, we would like to receive answers to these questions
by mail by the first of November.
I am enclosing our latest policy documents related to the evaluation of
fuel economy and emission control devices.
Sincerely,
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch
Enclosure
cc. T. Earth
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TRICONTECH INC.
Attachment E
October 19, 1981
Mr. Merrill W. Korth
Device Evaluation Coordinator
United States Environmental Protection Agency
Dear Mr. Korth,
Hereunder please find the answers to your queries contained in
your letter dated Sept. 30, 1981.
1. Attached please find a photocopy of the Notice of Allowance from
the US Patent Office relative subject application and referred to
as application no. 115,616 labelled and attached hereto as Annex A.
The consolidated and amended claims are contained in the US patent
which my lawyers in Washington DC should have by now. I have ins-
tructed them to mail you a copy.
2A. This refers to 30% of 160 proof hydrous ethanol to 70% gaoline.
2B. For purposes of this application, we shall refer to unleaded gasoline.
Reference must however be made to tests with leaded gasoline in RP.
2C. "Modified" vehicles run normally with pure gasoline. The same vehi-
cles run satisfactorily when in motion and at cruising speeds with
160 -nroof ethanol. However Engine stalls occur at prolonged idling
speeds when operating with only 160 proof ethanol.
2D. Your observation is correct, the alcohol flow is controlled by the
accelerating valve, after maximum proportions are preset by the pro-
portioning valve.
2E. Attached please find the details of the proportional valve referred to
as Annex B.
2F. The proportioning valve does restrict the flow of gasoline at such points
where the flow of alcohol is increased sicne the metering valves are dia-
gonally opposed. This is particularly true when cruising at proportions
exceeding 50% hydrous alcohol to gasoline. In such a case, when gasoline
fuel starvation take place, the increase in alcohol fuel makes up for the
energy lost by gasoline. However, quick and easy accelerating valve ad-
justments are necessary to effect this condition.
The overiding principle in the device is to operate at preset proportions
such as 30% hydrous alcohol to 70% gasoline and operate on pure alcohol
or liberal proportions thereof on rare but necessary occassions when there
is no gasoline.
EXECUTIVE OFFICES: The Manila Hilton. Suites 120 & 135-A, United Nations Ave., Ermita, Metro Manila, Philippines
Telephones: 595^»6I . 583-I43 . 573-7II ext. 8I85 Telex 27920 OPTE PH ATTN: TRICONTECH
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Pa;;e 2
29
TRICONTECH INC.
Item: Likewise, when the intake air is bled thru the device orifice
in the intake manifold, there is a proportional drop in carburetor
air velocity which in this case is compensated by the alcogas device/
system infusing both heated air and alcohol fuel thru said orifice. It
is reasonable to presume therefore that becasue of lessened vacuum pres-
sure and air velocity passing the gasoline carburetor, that a sonse-
quential reduction of gasoline fuel would take place.
The orifice size of the intake manifold therefore would enable a given
engine to operate efficiently only at certain parameters, that, is why
it is recommended that for most applications, a 20% to 30% hydrous
alcohol to the equivalent gasoline proportion is recommended. On the
basis of fixed and present proportions, this factor alone may even set
aside the mechanical manipulations in the proportioning valve. This,
plus the fact that alcohol contains oxygen, which gasoline does not have.
3. You must be referring to the need to effect a fairly equal distribution
of air and fuel alcohol to all the cylinders. This is not a problem
when the orifice is located in the center of the intake manifold. Most
of the popularly sold cars in the PHILIPPINES (RP) have the orifice in
the center of the intake manifold. Whenevsr the orifice in the intake
manifold is not centered, we provide an adapter immediately under the
carburetor containing an inlet orifice for the device to effect a more
equal distribution .of fuel alcohol and heated air to all the cylinders.
4/ There would be a safety hazard at top gears, but we normally take this
at the lowest gears. STill, you have a point, irregardless if the moni-
toring is being taken at crawling sppeds at low gear. We have since,
amended the procedure by priorly dterming proportions on chassis dynos
on as many representative cars and recommending the desired flow rate
for a given application.
Certainly, considerable improvements can still be effected, such as mo-
nitoring and computerizing fuel and air deliveries in relation to varied
engine loads and speeds. Please allow me to respectfully aver however, that
the worldwide concern involves survival considerations in utilizing economi-
cally feasible alternatives. The socio-economic implication in suitable
alternatives such as cheap alcohol involving and affecting the grain interests
(corn, wheat, manioc, sugar, etc. feedstocks) plus the capability of distressed
governments to reduce crude oil dependence has now assumed survival conside-
rations. Incidentally, several top oil company executives have expressed
satisfaction over this 30% hydrous alcohol compromise. The device can be
further improved to exceed this recommedded proportions but the imperatives
of international business require a concept of l£ve and let live.
i (
\ • [ '
: Sincerely,
'./ i/'-iv _______ -
/ - -\k
JOSE MA. R. CONCEPCION
EXECUTIVE OFFICES: The Manila Hilton, Suites 120 & 135-A, United Nations Ave.. Ermita. Metro Manila. Philippines
Telephones- 595-461 . 583-143 . 573-711 ext. 8185 Telex 27920 OPTE PH ATTN: TRICONTECH
9 5 J 4
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Attachment F
30
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
/ ANN ARBOR, MICHIGAN 48105
November 19, 1981 AIR AND WASTE MANAGEMENT
Mr. Jose Ma. R. Concepcion
#30 Melantic Street
San Lorenzo Village Markate
Metro Manila
Republic of the Philippines
Dear Mr. Concepcion:
We have received your letter of October 19, 1981 in which you responded
to our request for additional information on "Dynamnix". Our Engineering
Evaluation Group has reviewed your response and has identified several
areas that still require additional clarification prior to further pro-
cessing of your application. Again, our questions are listed below ac-
cording to the section numbers of your 511 application.
1. Section III, B, Patent Protection. We ask that you .submit a
copy of RP patent 13218.
2. Section VIII, Description of the Device.
A. Section VIII, A, your reply (2C) referred to 160 proof
ethanol. I therefore assume your device has not been
tested with other alcohols nor is it meant to be used with
other alcohols. Is this assumption correct? Your answer
also appears to imply the vehicles do not start and accel-
erate properly when operating on only 160 proof ethanol.
Is this assumption correct?
B. The drawings of the proportioning valve, provided as an
attachment to your letter, do not adequately describe the
valve and its manner of operation. Please provide a more
detailed description of the valve and its method of con-
trolling the flows of ethanol and gasoline.
C. Your reply (2F) stated "However, quick and easy acceler-
ating valve ...". I presume the accelerating valve here
referred to is the alcohol accelerating valve. Is this
assumption correct? The function of this accelerating
valve appears to be to replace part of the engine's basic
fuel requirement. Since the normal supplemental carburetor
circuits (idle, accelerator pump, and power enrichment)
probably will not function normally due to the reduced flow
of gasoline and air into the carburetor, how are these
supplemental functions performed by the alcohol acceler-
ating valve.
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31
D. Your reply (2F) states "On the basis of fixed and present
proportions, this factor alone may even set aside the
mechanical manipulations in the proportioning valve. This,
plus the fact that alcohol contains oxygen, which gasoline
does not have." The meaning of this statement is not
clear. Please describe more fully what is meant by this
statement.
E. Your reply (3) states that mixture distribution is not a
problem when using the orifice located at the center of the
intake manifold. Please provide data or other information
to support this statement.
3. Section IX, Device Installation
A. Your reply (3) refers to a carburetor adapter. For which
makes/models/years of vehicles sold in the U.S. do you
provide adapters? Is the appropriate adapter supplied with
the device? Which makes/models/years of vehicles sold in
the U.S. can use the device without an adapter?
B. Your reply (4) states you have modified the recommended
installation adjustment procedures. What are the propor-
tions recommended for each make/model/year of vehicle?
Please list. Does the installer simply dial in this
value? Are adjustments required to be performed on a
chassis dynamometer? Are road adjustments required?
Please provide a copy of the current installation instruc-
tions as provided with the device.
What is the suggested retail price of Dynamix?
What parts are supplied with the Dynamix device, e.g., accelerating
valve, electric fuel pump, heat exchanger, carburetor adapter, hoses,
fittings, wiring, etc.
Again, I welcome the opportunity to personally discuss these questions
with you if you have the opportunity to visit EPA in November. If you
cannot come to EPA, we would like to receive answers to these questions
by mail by December 4th.
Sincerely,
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch
cc: Dynamix File
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isas
Attachment G
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 48105
32
OFFICE OF
January 11, 1982 AIR AND WASTE MANAGEMENT
Mr. Jose Ma.R. Concepion
#30 Melantic Street
San Lorenzo Village Makati
Metro Manila
Republic of the Phillipines
Dear Mr. Concepcion:
We received your letter of October 19, 1981 in which you responded to our
request for information on your "Dynamix" device. As I noted in my
letter of November 19, 1981 (copy enclosed) we still require additional
information prior to further processing of your application. Please
provide the requested information immediately.
The Environmental Protection Agency is obligated to expeditously process
your application. However, the information you previously submitted does
not adequately describe your device and does not include valid test data
following the proper EPA test procedures. The limited information you
provided does not show a benefit for your device. Therefore, we presently
have insufficient technical information to adequately evaluate your
claims for the device.
Unless I receive a satisfactory response by February 5, 1982, we will
•complete the evaluation of your device using the information that is
currently available.
Again, . I welcome the opportunity to answer your questions and to work
with you in designing a test plan to test your device at an independent
laboratory here in the United States. However, I will need the requested
information to efficently assist you.
Please contact me immediately if you do not understand this course of
action.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test Evaluation Branch
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Attachment H
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN AR3OR. MICHIGAN 481C5
OFFICE OF
AIR AND WASTE MANAGEMENT
February 11, 1982
Mr. Jose Ma. R. Concepcion
#30 Melantic Street
San Lorenzo Village Makati
Metro Manila
Republic of the Philippines
Dear Mr. Concepcion:
We received your telegram of February 1 in which you stated that you had
just learned of our request for information on "Dynamix" as contained in
our recent two letters. You also indicated that you had not received the
actual request contained in our letter of November 19, 1981. Although a
copy of the letter of November 19 was to be enclosed with the letter of
January 11, apparently you did not receive it. I am therefore enclosing
a copy of both these letters.
Your telegram also stated that you expect to return to the United States
in March to run tests on your device. Again, I welcome the opportunity
to answer your questions and to work with you in designing a test plan
for testing your device at an independent laboratory in this country.
However, I will need the requested information to efficiently assist you
and ask that you respond to my letters of November 19 and January 11 by
March 19.
Because of the problems we have had with the mails, please notify me by
telegram as soon as you receive this letter.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosure
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Attachment I
34
ANN i.RBOR MICHIGAN -8iOr,-
March 26, 1982
Mr. Jose Ma. R. Concepcion
Tricontech, Incorporated
Manila Hilton Hotel, Suite 135A
United Nations Avenue
Ermita, Metro Manila
PHILIPPINES
Dear Mr. Concepcion:
I am enclosing copies of three letters that we sent to you previously on
November 19, 1981, January 11, 1982, and February 11, 1982. During our
telephone conversation on March 25 you did not seem to recall what corre-
spondence you had received from EPA.
We are discouraged that you have not been able to respond to our letters
nd answer our questions, especially the questions posed in our letter date
d November 19. Your application for an EPA evaluation of your device dates
back to September 10, 1981 and we have made no significant progress.
We are considering completing our evaluation with the information at hand
at this point. In that situation, you could reapply at a later date whan
you will be nearer to the point of developing scientific data to demon-
strate the effectiveness of your device. I would be happy to comment on
the suitability of your test plans at any time.
Please let me know if you have any questions concerning these actions.
Sincerely,
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch
Enclosures (3)
cc: Dynamix File
J. White/A. Earth
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Attachment J
35
April 20, 1982
Mr. Jose Ma. R. Concepcion
Tricontech, Incorporated
Manila Hilton Hote, Suite 135A
United Nations Avenue
Erminta, Metro Manila
PHILIPPINES
Dear Mr. Concepcion:
We still lack several critical pieces of information before we can prop-
erly evaluate "Dynamix". As explained in our earlier letters and tele-
phone conversations, we are obligated to publish our evaluation in the
Federal Register. We cannot delay that action indefinitely. Therefore,
I am forced to complete our evaluation and publish our conclusions with
the information at hand.
The most important information we lack is substantive test data to sup-
port your claims for the device. We have yet to see your test plan for
the test program you are about to initiate. As we explained, if we do
not have the opportunity to review your plan, you run the risk of an
oversight that might invalidate your whole effort. We recognize that
such testing is expensive and want to ensure that your testing will meet
our needs.
The other important pieces of information are the details of the device
description and installation instructions. We originally requested that
information in our letter of November 18 and have reiterated the request
in subsequent correspondence.
Because of the inordinate amount of time that has passed since we first
received your application and the difficulties encountered in getting the
information in proper form for us to analyze, we are faced with the need
to establish a deadline. That deadline is May 21. At that time, we will
conclude our evaluation, with or without the requested information. We
believe that that date allows more than enough time for our review of
your plan and the conduct of the test program at an independent labora-
tory. At least three vehicles should be tested. If the data from the
independent laboratory indicate a meaningful fuel economy or emission
benefit, EPA will perform confirmatory tests even though you may not wish
to fully disclose the detailed description of your device.
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36
Please let us know when you send us the test plan what laboratory you
have selected and the scheduled dates for your testing. If you have any
questions about these requirements, please contact me immediately at
(313) 668-4299.
Sincerely,
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch
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