EPA-AA-TEB-511-82-13
      EPA Evaluation of the Russell Fuelmiser Device Under
Section 511 of the Motor Vehicle Information and  Cost  Savings Act
                               by

                        Stanley L. Syria
                         September 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  Russell Fuelmiser 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 EPA  evaluation of  the  Russell Fuelmiser  device was conducted  after
receiving an  application for evaluation by  the  marketer.  The device  is
claimed to improve fuel economy  and  exhaust emission  levels  as well  as
vehicle performance.  The device consists  of  two components;  one  to chill
the  fuel  and  the  other  to  chill the  air-fuel mixture.   The   chilling
process is accomplished by installing the  above components into the  air
conditioning   system's  low  pressure  refrigerant   lines.   Additionally,
certain parameter  changes to  the  carburetor  and  ignition  systems  are also
recommended.   Because   this  device is  intended to  modify  the   engine's
induction  characteristics,  in  accordance  with  40 CFR 610.21  of  the
regulations,  it is classified by EPA as a air-fuel  distribution device.

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  Russell  Fuelmiser  under Section  511  of
    the Motor Vehicle Information and Cost  Savings Act

2.  Identification Information:

    a.   Marketing Identification of the  Product:

         (1)   Title  of  the  Invention  (Device): Device  and  Process  for
              Improving the Performance of  an Internal  Combustion  Engine.

         (2)   Marketing Title:  Russell Fuelmiser.

    b.   Inventor and Patent Protection;

         (1)   Inventor

              James M. Russell and James  R. Russell
              4805 Polk Avenue
              Alexandria, Virginia  22304

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     (2)  Patent

          "Copy of  the Patent  (Application)  is  shown  as Encl.  1."
          (Attachment A of this evaluation)

c.   Applicant:

     (1)  Name and Address

          J.C.A. Corporation
          45 L Street, N.W.
          B24311
          Washington, DC  20024-1611

     (2)  Principals

          James M. Russell, President (DESIGNATED CORRESPONDENT)
          James R. Russell, Vice President

d.   Manufacturer of the Product:

     (1)  Name and Address

          Cleanweld Products, Inc.
          16016 Montoya Street
          Irwindale, CA  91706

          Donsco Incorporated
          North Front Street
          P.O. Box 40
          Wrightsville, PA  17368

     (2)  Principals

          (a)  Cleanweld Products, Inc.
               (1)  Charles R. Muirhead, President
               (2)  Richard D. Shivers,  Executive Vice President
               (3)  Murray McDougal, Chairman of the Board

          (b)  Donsco Incorporated
               (1)  Donald Smith, President
               (2)  William E. Young, Vice President
               (3)  Arthur Mann, Vice President

Description of Product (as supplied by Applicant);

a.   Purpose;

     "See  Enclosures  1  and   2."   (Attachments  A   and  B   of  this
     evaluation).

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    b.   Theory of Operation;

         "See  Enclosures  1  and  2."  (Attachments  A  and  B  of   this
         evaluation).

    c.   Construction and Operation;

         "See  Enclosures  1  and  2."  (Attachments  A  and  B  of   this
         evaluation).

    d.   Specific Claims for the Product;

         A general  claim  in  Attachment  B  states  that,  "the  invention
         described  herein  improves  the  performance  of  the  internal
         combustion engine and  thereby  improves  the mileage delivered  by
         a given  quantity  of  fuel and  reduces  the  pollutants emitted  by
         the  exhaust  system."  Attachment  B further  states  that,  "test
         results have varied  from  a  50 percent  increase in fuel mileage,
         (never less),  to  a 100 percent  increase  in fuel mileage".  The
         reader  of  this  report is  cautioned not  to confuse  this  last
         statement,  which  is  an observation  of. test  data obtained  from
         other then EPA  recommended  procedures  (and discussed in  Section
         6d2),  with claims of specific  percentage changes  that purchasers
         of the device may realize  when using the  device.

    e.   Cost And Marketing Information (as supplied by Applicant);

         Cost and marketing information not submitted.

4.  Product Installation,  Operation,  Safety and Maintenance (as supplied
    by Applicant);

    a.   Applicability;

         "This device (invention)  can  be  installed  on, and will function
         on,  all  internal  combustion engines,  foreign or  domestic,  which
         possess  a  functioning  air  conditioning  system   as  an integral
         part  thereof,  or upon which  an air conditioning system  can  be
         installed.   The  function  of the  device  (invention)  is possible
         without regard to engine  size, type  of carburetion (single,  dual
         or four  barrel  construction),  model  year,  transmission type,  or
         ignition type.  The  fuel-chilling tank is a  standard model for
         use  on all engines.

         "The riser (See Encl 1 and  2)  [Attachments A and  B],  is made  in
         two  models,   i.e.,  one  model  for  the  single  and  two  barrel
         carburetors and one model  for the four  barrel carburetors."

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    b.   Installation - Instructions,  Equipment,  and Skills Required;

         "See  Enclosures  1  and  2  [Attachments  A  and  B].   NOTE:   The
         following is  intended to  respond  to all  inquiries  (a)  through
         (f) of application format of  para 10.

         "Tools and equipment  required  to install,  adjust, maintain,  and
         check  the  device  are  commonly  available  in  any  installation
         which performs tune-ups  on the engines  upon which the device  is
         to  be installed and  which maintenance  and service  to  the  air
         conditioning  systems  of  such  engines  is  performed.    Skills
         associated  with  the  installation  of  the  device  are   those
         necessary  to  service   and  perform  maintenance  on  the   air
         conditioning systems, those skills necessary to perform  tune-ups
         on  the  applicable  engines and  the  skill necessary  to  change
         carburetor jets."

    c.   Operation;

         "Operation  and  installation   instructions  similar  to   those
         contained in Encls  1  and 2 [Attachments A  and  B], and a  period
         of  classroom  training  — if  necessary  —  will be given to  all
         those who will be installing  the device."

    d.   Effects on Vehicle Safety;

         "The device in operation,  function,  or malfunction cannot  cause
         any  unsafe  condition which  would  endanger  the  vehicle,   its
         occupants or  persons  or  property  in   close  proximity  to  the
         vehicle."

    e.   Maintenance;

         "No specific maintenance is  required on the device,  per se.   It
         has no moving parts.   The  air  conditioning system of the  engine
         must  however,  receive normal maintenance.  No  additional  tools
         or  equipment,  other   than  those  needed  for  air  conditioning
         system  service  and maintenance  and  tune-up  of  the  engine  are
         required as  a consequence of  having installed the  device upon
         any engine."

5.  Effects on Emissions and Fuel Economy (submitted by Applicant);

    a.   Unregulated  Emissions;

         "No adverse effects  upon engine emissions  are  possible because
         of  the installation,  operation,  function,  or  malfunction of  the
         device.   Contrariwise,  benefits  due to a  more   complete fuel
         combustion,  can be  reasonably expected."

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    b.   Regulated Emissions and Fuel Economy;

         "See Exhibits 1,  2, 3, and 4 of Encl 1."  (Attachment  A)

6.  Analysis

    a.   Identification Information;

         Marketing Identification:

         EPA finds  no problems with  the  titles of  the  device which  are
         listed  in  Section 2 .A  of  the  application.  The  reader  should
         note that  the  Russell Fuelmiser is  considered  by the  applicant
         to be both  a device  and a  process.   The  device consists  of  two
         components;  one  to chill  the  fuel  and  the other  to chill  the
         air-fuel mixture.  The  process  includes  the above components  in
         addition to the  air  conditioning  system  and  certain  parameter
         changes to the carburetor and ignition systems.

    b.   Description;

         (1)  The  primary  purpose  of  the  device/system  is  to  improve
              vehicle performance,  particularly with respect  to  improved
              fuel   economy  and   exhaust    emission   levels.    Without
              additional appropriate  test data, the Agency does  not know
              whether or  not  the device can  achieve any fuel economy  or
              emission benefits.   The Agency  does  know that  adjustments
              to  the  fuel  and   ignition   system,  as  suggested  by  the
              applicant,   often  cause  improved levels  of  fuel  economy.
              However, these  improvements are sometimes accompanied by  a
              degradation  in  exhaust emission levels and/or  performance.
              Because emission levels may be  adversely affected,  and also
              because  the  device   in  most   instances  will  likely   be
              installed by  commercial automotive  service  facilities  and
              fleet  facilities,  the  installation  of the device  (by these
              facilities),  may  be  considered by  the Agency and  certain
              State  governments  to  be  an   act   of   tampering.    EPA's
              decision on this concern would  be based on exhaust  emission
              results from future test programs.

         (2)  The  theory   of   operation  given in  Enclosures  1  and   2
              (Attachments A and B)  describes  the device as consisting  of
              two components  which  are  installed  into  the  low  pressure
              refrigerant   lines  of  an  air  conditioner  system.    One
              component is  intended  to  prechill  the fuel being  delivered
              to the carburetor while the other component (referred to  as
              the "riser" by  the applicant),  which is  installed  between
              the carburetor and  the intake manifold,  is claimed  to cool
              the air-fuel mixture prior to  entering the  manifold.

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Based on the  information given,  the chilling  device  should
be  capable  of  cooling  the  fuel  to  some extent.   Whether
there are  any  benefits  by  doing  so  is  not  known by  the
Agency at this  time  for  the  following  reasons.   Because  the
chilled  fuel  passes  through other  components  (e.g.,  fuel
line, fuel filter, and carburetor float bowl)  subsequent  to
becoming  chilled,  its  temperature  will   rise  due  to  the
absorption of  heat  from those components.   The amount  of
heat  absorbed  will  depend  on a  number  of  factors  (e.g.,
component configuration, materials  used,  engine compartment
temperatures,   and fuel  flow  rates)  and will  vary  among
vehicles.  Depending  on  the amount  of heat absorbed,  this
reheating of the  fuel could potentially negate part or  all
of any heat loss during the cooling process.

Although Attachment  A states that  the fuel  is cooled to  a
temperature range  of -20°F  to 30°F,  no mention is made  of
the  final  fuel temperature  at  the  carburetor  main  jet.
Additionally,   data were  not submitted  showing final  fuel
temperatures  for  modified   versus  unmodified  vehicles  or
showing the benefits  achieved when  the fuel  chilling  device
alone is  used.   Further,  because  the temperature  of  the
refrigerant upon  leaving the  expansion valve   is  generally
in the range of 20°F to  34°F,  it does not seem possible  to
cool  the  fuel  to  the degree  stated  above (-20°F  to  30°F)
unless   the    refrigerant   controls   are  modified.    The
applicant did  not address   any  such  modifications.   Thus,
until the applicant  submits  additional supporting  data,  the
Agency does not know for sure the  net decrease  in  the  fuel
temperature or whether there  are  benefits associated with
chilling of the fuel.

With  respect  to  the air-fuel mixture cooling device,  the
Agency is skeptical  as to its  ability  to  significantly  cool
the mixture so as to  change the  combustion process.   This
skepticism arises  because  the  device design (see Figures  1
through 6 in Attachment  A)  suggests that  the  total  cooling
surface area  in contact with  the  air-fuel  mixture may  be
insufficient when  dealing  with the high  mixture  velocities
as  found  in  the  fuel induction  system.   Additionally,  as
ambient  temperatures  increase,   a  greater heat   load   is
placed  upon  the  refrigerant  prior  to  it  reaching   the
riser.   Consequently, at  very high  ambient  temperatures,
the  cooling  capabilities  may be  diminished  to  the  point
where  proper   cooling  of   the  air-fuel mixture   is   not
possible.

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For these  reasons,  EPA requested (see Attachments C  and  D)
additional  data  showing  the  air-fuel mixture  temperatures
from both  modified  and unmodified vehicles.  The applicant
responded  (Attachment E)  that he  did  not  have  the requested
data.   Without  additional data,  the Agency  does not  know
for sure  the  cooling  capabilities  of the  air-fuel  cooling
component.    Even    if    the   component   could    indeed
significantly  cool   the  mixture  as  claimed,  there  is  no
assurance  this  would  result  in  improved  fuel  economy  or
emission   levels.   The   cooled  mixture  may   improve   the
volumetric efficiency and thereby increase  the  power output
of the engine.   However, because  the lower vapor  fraction
can adversely  affect the charge  distribution,  it also  has
the potential to cause driveability problems.

Attachment A states  that  in addition  to  the installation  of
the  two   cooling  components,  there  are  three  mechanical
adjustments to be  made.   They consist  of a)  replacing  the
carburetor  jets  with  ones of   smaller  diameter  (diameter
reduced  from  10%  to  50%),  b)  lowering  of  the  carburetor
float  level,  and  c) replacing  the  spark  plugs  with  ones
having two or three  heat  ranges hotter.   In a  letter to the
applicant  (Attachment  C)  EPA  asked if there were any other
adjustments  (e.g.,   ignition  timing,   idle  mixture,   or
choke).   The  applicant  responded  (Attachment  E)  that  on
their  test vehicles  the spark  plugs  were  changed,   the
carburetor  jets  reduced  by  10%  on one  vehicle  only,  the
carburetors  adjusted  for smoother  running  (idle  mixture
assumed)   and   the   ignition   timing  advanced  ten  degrees.
Based  on   the   applicant's   response,    it  appeared  that
carburetor  jets  and  float  level  do  not  have   to   be
changed/or adjusted on all vehicles.  It  also  appeared  that
adjusting  the  ignition timing and  carburetor  idle  mixture
is also  required  on some or  all vehicles.   Because  it was
not  clear as   to  exactly  what  adjustments  would   be
recommended  to  purchasers  of  the  device,  EPA  requested
(Attachment F) that  the  applicant clarify the matter.  The
applicant  did  not  respond  to  the Agency's  questions and
therefore,   the   Agency   does    not   know   exactly   what
adjustments  will  be  recommended.   With  respect   to   the
adjustments being considered,  it is known that  fuel  economy
gains are  possible  with  most of these changes.   Depending
on the  vehicle  and the  adjustments performed,  there may
however,  also be adverse  changes  in the  exhaust  emissions,
fuel economy and/or  driveability  characteristics.  Based  on
the limited information  provided  by the  applicant and  also
on EPA's  experience,  it  is expected  that if  there  are any
benefits     associated    with   the    Russell    Fuelmiser
device/system,   they would,  more  likely   be  caused  by  the
parameter   adjustments  rather   than  from   the   cooling

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     components.  To  verify  this,  the  applicant  was  requested
     (Attachments C and D) to submit additional  data  showing  the
     effect of  the  adjustments  alone  and  also  when  accompanied
     with installation of the cooling  components.  The  applicant
     responded  (Attachment  E)   that  he  could not   fund   the
     necessary testing.

     In  summary,  the  theory  of  operation  was   sufficiently
     detailed and therefore  EPA had no  difficulty  understanding
     how the  device/system  functions.   Although the  theory  of
     operation given by the  applicant  suggests there may  be  some
     benefits,  sufficient  supporting  data were not  submitted.
     Therefore, EPA does  not know  if  there  are indeed  benefits
     attributable to  the  device, and  if  so,  whether they  more
     than offset the fuel economy and  performance penalties  when
     running an air conditioning system on a  full time basis.

(3)  The description of  the device given  in  Enclosures 1 and  2
     (Attachments A and B) are judged to be adequate.

(4)  The  device  is  claimed  to  improve  vehicle   performance,
     particularly with  respect  to  improved  fuel economy  levels
     and  reduced  exhaust  emissions.   As  previously  stated  in
     7(b)(l),  actual  testing is  required to  properly  quantify
     these benefits.

(5)  The cost of the device  plus installation  is not  known.   The
     Agency requested cost information  (Attachments C, D,  and F)
     however, no response was received.   EPA estimates the  cost
     of the device alone  will not  be less than  $70.   Should  the
     purchaser have the device  installed by a  commercial  service
     facility,  then  an additional  fclOO for  labor  is  expected.
     The $100  for installation  is  based on 5  hours  of labor at
     $20 an hour for  the  shop  rate.   Five hours is the  minimum
     time  likely  to  be  required  and  was determined  based  on
     EPA's knowledge about other retrofit  devices (which  require
     approximately  2.5 hours   labor)  and  on  air   conditioning
     systems.

Installation, Operation, Safety  and  Maintenance;

(1)  Applicability;

     The  applicability  of   the  product,   as  stated  in   the
     application,  seemed  to   be  appropriate   except  for   the
     statement regarding the number of models required.  EPA  did
     question   (Attachment   C)   the   applicant   regarding   his
     statement  that only  two  models  of  the  riser  would  be
     required  to accommodate the complete range of  carburetors
     in use  today.  The applicant  responded  (Attachment E)  that
     he was  not certain that only  two models would  accommodate

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     all  carburetor/manifold  combinations.   He  further  stated
     that even though he planned to produce risers with  multiple
     bolt patterns,  additional  risers  would  probably  still  be
     required.

     Another  concern  is  the  fuel  chilling  component.    The
     applicant  states the component is  a standard model for  use
     on  all  engines.   Although  the  component  may  be   standard
     with respect  to cooling characteristics,  EPA  is  not  sure
     one model  will  readily  connect  into  all  air  conditioning
     and  fuel  lines  because  of  differences  in  diameters  and
     fittings.   Thus, additional models  may be required.   Aside
     from the aforementioned  concerns,  the applicability of  the
     device  seemed  reasonable.

(2)   Installation - Instructions, Equipment and  Skills Required;

     With  respect   to   the   installation   instructions,    the
     applicant  referred to Enclosures 1 and 2 (Attachments  A  and
     B).   These   enclosures   did    not   contain   the   actual
     instructions which are to be provided to purchasers of  the
     device  or to service garages.   EPA requested  (Attachment  C)
     a copy  but  the applicant  did not  respond.

     Installation procedures involve the addition of both a fuel
     cooling component and an air-fuel mixture  cooling component
     in  addition   to   certain   parameter   adjustments.     The
     installation  of   the   fuel   cooling  component   and   the
     parameter   adjustments  are  not   expected  to  cause   any
     significant problems.    The  installation  of  the   air-fuel'
     cooling  component is expected  to be a more difficult matter
     because it requires the  carburetor  (and  air  cleaner)   to  be
     raised.   Considering  that  most  vehicles  have  very little
     clearance  between the air cleaner  and the  hood, this  could
     create  a problem.  The applicant was  questioned (Attachment
     C) about this potential  problem.   He responded (Attachment
     E)  that he  had  experienced  a  clearance   problem   on a
     Cadillac El  Dorado,  however,  it  was  easily  overcome  by
     changing gaskets.  Although not  stated,  it  is  assumed  the
     gaskets referred to are those  located on the  top and bottom
     of the  cooling  component.   Considering  the  cramped engine
     compartments  and  low  hood   profiles  common  to  today's
     automobiles,   EPA  expects   the  clearance  problem  to   be
     encountered quite frequently and that  it may not  always  be
     possible to overcome the  problem  merely by  changing  gaskets.

     Another potential  problem that might occur as  a  result  of
     raising  the carburetor is that  caused by external linkages,
     vacuum   and  fuel  lines,   and   electrical  leads which  are
     connected  to the  carburetor  and/or air  cleaner which will

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                                                                     11
     also be raised.   This could be a very difficult problem for
     some vehicles  and  especially more  so  for  those engines
     which have the choke thermostatic spring, heat supply tube,
     or automatic  transmission  linkages  attached  to  the intake
     manifold.

     Such problems  were  encountered  during  a  recent  EPA  test
     program on another retrofit device which  involved raising
     the  carburetor  approximately one  inch.   The installation
     problems encountered are  addressed  in  the  Agency's report
     EPA-AA-TEB-82-8,  titled:  Emissions and  Fuel Economy of the
     Turbo-Garb, a Fuel Economy  Retrofit Device.

     EPA  further  expects   that  the  problems   may   preclude
     installation   of   the   device  on  some  vehicles  unless
     extensive  vehicle modifications are performed.

     With respect to  the tools, equipment,  and  skills  required
     for  device  installation,   the  applicant's  comments  are
     judged  to  be correct.  Because  the tools,  equipment,  and
     skills   required  are  more  than  those  possessed  by  most
     individuals,  it is  expected  that most  device installations
     will be performed at service garages.

(3)   Operation;

     The  operating    instructions   did   not    include  those
     instructions   intended  for  purchasers  of   the  device.
     Additionally, the instructions were  not clear as  to whether
     the device could  be used  during all seasons regardless of
     ambient  conditions,  and   if  so,   how  should   the   air
     conditioner  controls be   set.   The  applicant   was  asked
     (Attachment   C)  about the  seasonal  usage  and  the control
     settings.   He was also asked about the vehicle operation in
     the eventuality the air conditioner system  was  not used or
     it becomes inoperative due to a malfunction.  The  applicant
     responded   (Attachment  E)   that  the  heater  and   the  air
     conditioner may both  be  operated at  the same  time during
     all seasons.   While it is  true that  air  conditioner systems
     may be  operated during all seasons for some vehicles,  there
     are  other  vehicles  in  which  this  is  not  possible.   The
     reason  for this  is  that  some vehicles are  equipped  with
     compressor controls (e.g.,  ambient  temperature  switches or
     the compressor discharge  pressure  switch  used  in General
     Motor's Cycling   Clutch  Orifice  Tube   system)   which  are
     designed  to   prevent  air   compressor   operation   when  low
     outside air   temperatures  are  sensed.   This  action  is
     intended to prevent damage to the compressor seals, gaskets
     or reed valves  due  to  lack  of  proper  oil  circulation or
     cold components.    Of  course,  these  control  switches  could
     be bypassed  during  installation  of  the  device  although it
     would  be  at  the  risk  of  damaging   the  air  conditioner
     compressor.

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                                                                  12
     With respect  to  EPA's question  regarding engine  operation
     at times when  the  air conditioner  is  not functioning,  the
     applicant responded that the engine would  operate,  however,
     it would not achieve  nearly  the  same fuel economy  and  that
     it would run hotter and probably diesel.   The  applicant  may
     be  correct,  however,  it   would   likely  depend  on   the
     parameter  adjustments  made  and  the  amount   of  cooling
     achieved of the  fuel  and air-fuel mixture when the  device
     is  functioning.   That  is,   if   the  device  is  not  really
     capable  of  chilling  the  fuel and air-fuel  mixture,  then
     there  should  not  be  a  noticeable  difference  in  engine
     operation when the  air conditioning is  not running.

     Because  the  device   is  said  to  cool  the  fuel  and  the
     air-fuel  mixture,  EPA  was  concerned   about   potential
     operational  problems   due   to   icing   of  the   carburetor
     throttle  plate(s)  under   high   humidity/low   temperature
     conditions.  This  phenomenon occurs  when the  evaporating
     fuel absorbs heat  from  the  inducted air and metal  parts  of
     the  carburetor.   The  air  temperature   decreases  and  water
     vapor condenses and freezes  on the throttle plate(s).   The
     resulting  ice  buildup can  eventually  cause  rough running
     and  stalling  of  the   engine.   Low  temperatures  can  also
     cause freezing of  water within  the fuel  lines and thereby
     cause  blockage  of  the  lines.   These  problems  have  been
     overcome on modern engines  by heating  the inducted air  and
     carburetor  base   (which  is  opposite   the effect  of   the
     Russell Fuelmiser), and  by  fuel anti-icing  additives  such
     as alcohol, ammonia salts, and phosphates.

     The  applicant was questioned   (Attachment   C)   about   the
     potential  icing  problem  and he  responded  (Attachment  E)
     that the device was not capable of  freezing the  fuel  within
     the  fuel line  and that  he  had  not   seen  any  carburetor
     icing.   Without additional data,  EPA does  not know  if  icing
     is a real  problem  at  lower  ambient  temperatures which  can
     lead to operational problems.

     There  may  also   be   operational  problems due   to  leaner
     air-fuel ratios (caused by smaller jets and lowering  of  the
     float level).   Again,  without additional data, EPA  does  not
     know for sure  if  this  is a real concern.

(4)  Effects on Vehicle  Safety;

     Because  the potential icing  problem discussed  in Section
     6C(3) can  cause  stalling,  there  may be instances when  the
     device  could  cause an unsafe driving   situation.   However,
     without additional data, EPA does not know for sure if  this
     is a real hazard.

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         (5)  Maintenance;

              Aside from the icing problem mentioned  above  which  can lead
              to  additional  maintenance  being  required, the  applicant's
              statement regarding maintenance  appears to be correct when
              considered on  a  short  terra basis.  Data were  not  submitted
              to  EPA  showing  what  affects  the  lean  air/fuel  ratios
              (caused  by  smaller jets  and  lowering  of  the float  level)
              and  the  hotter  range  spark  plugs  may  have   on  engine
              durability  over  a  longer period of  time.   Therefore,  EPA
              does not know  for  sure  if more maintenance will  be  required
              when considered over a long term basis.

    d.   Effects on Emissions and Fuel Economy;

         (1)  Unregulated Emissions;

              Based  on the  design of   the  device,  EPA  agrees  with  the
              applicant  that  the  device  should   not cause  any  adverse
              affects  on  nonregulated pollutants.  However, without data
              from  the applicant,  EPA  can  not  support the  applicant's
              statement  that,  "Contrariwise,   benefits  due  to   a  more
              complete fuel combustion can be reasonably expected."

         (2)  Regulated Emissions and Fuel Economy;

              The applicant  did  not  submit  test  data in accordance with
              EPA's  recommended   test  policies which includes  both  the
              Federal  Test Procedure  (FTP)  and  the Highway Fuel  Economy
              Test  (HFET).   These  two  test  procedures  are  the  primary
              ones  recognized  by EPA for evaluation  of  fuel economy  and
              emissions   for  light   duty   vehicles.*    The  test   data
              submitted by the applicant  consisted  of results  obtained at
              the Norris Garage in Forest Heights, Maryland  using  a Sun
*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.   Additionally, Section 610.41  of  the
Federal Register Part VIII,  dated  March 23,  1979 provides  that  for  those
devices which require engine parameter  adjustments be  made,  tests will be
performed  with   the  parameter   adjusted   exclusive   of   the   retrofit
hardware.   Thus,  three  sets   of  duplicate  test  sequences   would   be
required.  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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                                                                           14
              Dynamometer  and  from Custom  Engineering  Performance  and
              Emissions  Laboratories  in Garden  Grove,  California  from
              steady  state  and FTP  and  HFET  testing.   The  results  from
              the Norris  Garage and the steady  state  test  results  from
              Custom  Engineering  did  indicate  some fuel  economy  gains
              attributable   to  the   device   and   are   acceptable   as
              supplemental data.  However,  because  of  inadequate  control
              of the  many variables during  the  testing,  the data  cannot
              be used in lieu of FTP and HFET testing.

              The  only  other  testing  was   that   performed  by   Custom
              Engineering which consisted of duplicate  FTP  and  HFET tests
              on only one vehicle in two configurations (with and  without
              the device).   Because the testing performed  did not  meet
              EPA's minimum  test  requirements,  the  data were  considered
              inadequate.   EPA  requested   (Attachments  C,  D,   and  F)
              additional  data,  however,  the  applicant did  not  provide
              any.   The  results from  the  duplicate FTP  and HFET  showed
              that  although  hydrocarbon and  carbon  monoxide   emissions
              were decreased,  the oxides of  nitrogen were  increased.   It
              also showed that  the  fuel economy on  the FTP  was unchanged
              and that there was a  loss  on the  HFET.  Without a third set
              of duplicate  tests, with  the  parameters  adjusted exclusive
              of the device, EPA does  not know if the changes noted above
              are  caused  by  either  the   adjustments  or   the   cooling
              components, or by the  combination of these factors.

    e.   Test Results Obtained by EPA:

         EPA did not test the  device for this  evaluation  because the test
         data submitted  by  the applicant did  not adequately, support  the
         claims made for the device.

7.  Conclusion

    EPA  fully  considered  all  of  the information   submitted   by  the
    applicant.  The evaluation  of the  Russell Fuelmiser device was based
    on that information and EPA's engineering  judgment.   Appropriate data
    was  not   submitted   showing   the  " device  actually   delivered   a
    significantly cooler air-fuel mixture  to the engine or  that it could
    achieve the benefits  claimed.   Thus, there is no technical basis  for
    EPA  to  support  the  claims made  for  the device  or to   perform
    confirmatory testing.

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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                                                                              15
                           List of Attachments

Attachment A       Copy of Enclosure 1, Patent  Application  (provided with
                   511 application).

Attachment B       Copy  of  Enclosure   2,  Disclosure  Document  (provided
                   with 511 application).,

Attachment C       'Copy  of   letter  from  EPA  to   J.C.A.   Corporation,
                   November 16, 1981.

Attachemnt D       Copy of  letter from EPA  to J.C.A.  Corporation,  March
                   24, 1982.

Attachment E       Copy of  letter from J.C.A.  Corporation  to EPA,  April
                   8, 1982.

Attachment F       Copy of letter from EPA to  J.C.A.  Corporation,  May 24,
                   1982.

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      TITLE OF THE INVENTION
          f           .            ''                •     Attachment  A
      Device 'and Process for Improving the 'Performance of an
                       Internal Combustion Engine

      FIELD OF THE INVENTION

5          This invention is concerned with improving the per-
      formance of an internal combustion engine.  More specifi-
      cally,  the invention is concerned with improving the
      mileage delivered by a given quantity of fuel, especially
      gasoline, in the internal combustion engine of an automo-
10    bile.

      BACKGROUND 07 THE INVENTION

           When the internal combustion engine of an automobile
      is operated, the heat generated raises the temperature
      within the engine compartment very substantially.   The
15    intake manifold and the carburetor may operate, for
      example, in an environment of several hundred degrees
      Fahrenheit.  This  high ambient temperature often vaporizes
      at least a portion of the fuel in the carburetor fuel bowl.
      The designs of some carburetors take this into account:,
20    and permit vaporized fuel to pass into the. atmosphere
      through the fuel bowl vent.
           After an engine has become hot, even after the engine
      is placed out of operation,  the residual heat  will often
      continue vaporizing the fuel in the carburetor fuel bowl.
25    This makes it more difficult to start the engine the next
      time, because of the low level or absence of fuel  in the
      bowl.
           In addition,  a heated carburetor heats the fuel-air
      mixture that is delivered to the intake manifold.   The
30    heated fuel-air mixture does not deliver optimum engine
      performance. . .

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           Some prior workers in this field have sought to       17
      improve fuel economy and improve engine performance by
      increasing the temperature of the fuel-air mixture
      delivered from the carburetor to the intake manifold.  A
5     variety of techniques have been used to accomplish this.
      In U.S. patent 4,044,742,  a device referred to as a fuel
      expander is employed to heat the fuel to a desired pre-
      determined temperature.
           There also have been devices made available for cool-
10    ing the fuel or the fuel-air mixture,' generally to a very
      limited extent.  These have been intended, usually,  for
      purposes other than improving fuel economy or engine per-
      formance.   For example, in patent 2,885,865,  a refrigerant
      fluid circulated from the air conditioning system of an
15    automobile was employed to cool the fuel line leading to
      the carburetor.  The' purpose was to reduce vapor locking
      tendencies.
           In patent 3,332,476,  a cooling device of very limited
      capability was disposed between the-discharge  outlet  of the
20    carburetor and the intake manifold inlet.   The purpose was
      to reduce  vaporization of fuel in the carburetor fuel bowl,.
      so as to facilitate restarting the engine.
           In patent 3,672,342r  a cooling device, was disposed to
      maintain the fuel temperature just ahead of the carburet or r
25    and the air temperature just ahead of the carburetor.
      within predetermined temperature ranges.  The fuel was
      to be at 70°"F to 110°F.  The air was to be at 90°F to
      110°F.  The objective was  to control and reduce"exhaust
      emissions.  There was also an attempt to improve engine
 30    performance,  by adjusting the proportions of  air and fuel
      to the optimum for ambient conditions.
           A somewhat different  approach was  taken  in patent
      3,684,257, where a profiled needle was  employed in con-
      junction with each jet of the carburetor,  and in addition,
 35    the temperature of air supplied to the  carburetor was
      maintained or attempted to be maintained at a substantially

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                                                              18
      constant value.'  However, the 'objective "here 'was  to  con-
      trol emissions, particularly under, engine 'idling  condi-
      tions, for both hot and cold engine 'conditions.
           The inventor in patent 3,882','692, cooled fuel
5     passing through the 'fuel, line- "by using cool water 'accumu-
      lated in a reservoir attached to a refrigerant evapora-
      tor of an air conditioner.  Patent 4,036,138 sought  to
      eliminate vapor lock "by the use 'of a carburetor incor-
      porating a fluid cooling system for a casing of the '
10    carburetor. -Cooling fluid was^ circulated through the
      casing for a predetermined period .after the ignition
      switch was opened, i.e.', after the 'engine was turned off.

      SUMMARY OF THE INVENTION                 .  •   '

           This invention.provides means for adjusting the
15    temperature of the fuel-air mixture 'of an internal com-
      bustion engine having a carburetor and an intake 'manifold.
      This temperature-ad jus ting means is disposed intermediate;
      the discharge outlet of the carburetor and the intake port
      of the manifold.  The 'temperature 'of the fuel-air mixture
20    is adjusted to not above about 4'0°F~-(4*C) ....
           According to one 'preferred embodiment of the inven-
      tion, the temperature-adjusting means comprises a
      •thermally-conductive conduit means having at least one
      passage therethrough.  This passage.is preferably the same
25    size as the bore of the carburetor barrel» and inter-
      connects the discharge 'outlet of the carburetor barrel
      and the inlet port of the intake manifold, to provide
      communication therebetween for the flow of the fuel-air
      mixture therethrough.  Multiple passages are provided for
30    multiple barrel carburetors.
           Heat exchange means are 'disposed either within,
      about, or both within or about the 'conduit means.   In one
      preferred embodiment, this heat exchange means is in the
      form of a jacket that is disposed about the conduit means,
35    providing a chamber internally of the jacket and about

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                                                           19
                                -H-
      the 'conduit, through which" "heat exchange 'fluid 'can be '
      circulated.  Temperature 'adjustment is achieved by,
      circulating refrigerant fluid at 'a low temperature 'through
      the heat exchange 'chamber, for'heat exchange with 'the '•
5     fuel-air mixture passing- through 'the passage 'of the" "con-
      duit.
           In other embodiments of the 'invention, the "heat
      exchange 'efficiency Is enhance'd by providing metallic fins.
      that project into the 'pass-age 'through the conduit, from
10    its wall.  Alternatively, to supplement the cooling effect-
      provided by the jacket'; or in place of it, a network .of.
      tubes may be disposed in the'conduit passage/ and may even;
      project" into the'inlet of the intake manifold, to circu-
      late refrigerant fluid; or a combination of all of .these
15    may be 'used. •            '       '               •
           Preferably, this temperature 'adjustment of. the 'fuel -
      air mixture 'is supplemented'by pre-.caoling of the fuel,
      prior to the time the "fuel is delivered to. the carburetor..
      In a preferred embodiment, this is accomplished by simple
20    heat exchanger that is mounted near the 'fire wall in the
      engine compartment of an automobile.'. .     '   •  ' '
           The cooling is accomplished by the circulation of
      refrigerant- fluid.  When the invention is applied to an
      automobile,, the source of the "refrigerant- fluid at a low
25    temperature, may be the" air conditioning system of. the
      automobile."                          .    .
           The invention is" also concerned-with a process for-
      improving engine-performance, and particularly,, for
      improving fuel economy and for reducing engine emission.
30    This process involves adjusting the temperature of the
      fuel-air" mixture as it leaves the carburetor, and before
      it enters the intake manifold, of an internal combustion
      engine, to a temperature not above about 40°F (4°C), and
      preferably, within the range "from about -20°F (-29°C) to
35    about 30°F  (-1°C).                       .

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                               . -5-
           In practicing the invention,' three mechanical
      adjustments are made.'  Thus, each jet ordinarily present
      in the carburetor is removed and replaced with a jet
      having an opening diameter at least 10% smaller than
5     originally present, and preferably, 20% smaller, and most.,
      preferably, 30% to 50% smaller; each carburetor float is
      lowered, to reduce the amount of fuel present in the bowl
      and to reduce the residence time of the fuel in the bowl;
      and finally, the spark plugs normally used are replaced
10    with plugs at least twd and preferably three ranges"hotter
      than those originally and normally present.

      BRIEF DESCRIPTION OF THE DRAWINGS

           Fig. 1 is an exploded,.fragmentary, isometric view,
      partly broken away, of a heat exchange device constructed
15    in accordance with one preferred embodiment of the inven-?
      tion, designed for insertion, between the discharge outlet
      of a general type,' double "barrel carburetor for an internal
      combustion engine, and the inlet port of the intake mani-
      fold (not shown) of the engine, showing, the-two jets and
20    single float that might be used in such a general type
      carburetor;
           Fig. 2 is a section in a vertical plane through a
      single conduit,  showing heatr exchange (cooling) coils dis-
      posed within the passage "of the conduit, and projecting
25    below the lower end of the conduit so that upon assembly
      some cooling coils will project into the inlet port of
      the intake manifold,  in accordance with a modified embodi-
      ment of the invention;
           Fig. 3 is a section taken on the line 3-3 of Fig.  2,
30    looking in the direction of the arrows;
           Fig. 4 is a top plan view of a conduit equipped with
      heat exchange fins, in accordance with another modification
      of the invention;
           Fig. 5 is a schematic diagram of another embodiment of
35    the invention, in which the  operation of the jacket-type

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                                -6-
      heat exchanger shown in Fig. 1 : is supplemented by  chat  of
      a heat exchanger for the fuel that .is being  supplied  to
      the carburetor, the source of cooling for both heat
      exchangers being the air conditioning system of an auto-
      mobile in which the engine is mounted, the air conditioner-
      being of the compressor type,' .and
           Fig. 6 is a schematic diagram similar to that of Fig.
      5, but in which the 'source of refrigerant fluid is an air
      conditioning system operated by a refrigerant unit of the
      gas absorption (Serve!) type.'
      DETAILED DESCRIPTION OF THE"

           Referring now to the 'drawings by numerals of
      reference,' the numeral 10 'denotes generally the heat
      exchange 'means for adjusting the temperature of a fuel-
15    air mixture, intermediate the discharge outlet: of a
      double "barrel carburetor and the intake 'port, of the
      manifold of an internal combustion engine, in accordance
      with one embodiment of the invention.  This heat exchange
      means is referred to hereafter for convenience as a
20    "riser", when it is fully assembled as described below.
           The 'riser 10 consists of four main parts.  These are
      a base plate 12,  the riser body 14 that, in the assembled
      riser, is seated on the base plate. 12 and welded thereto
      about its periphery, a top plate 16 that, in the ass em-
25    bled riser, is welded about its periphery to the upper end
      of the riser body 14, and a pair of generally tubular,
      upright conduits 18 and 20, that are disposed centrally
      within the riser body.
           The two conduit members 18 and 20 respectively, in
30    the assembled riser, are welded or otherwise secured in
      fluid-tight fashion to both the base plate 12 and the top
      plate 16, so that they are rigidly secured in place within
      the riser.  The base plate 12 and the top plate 16 are
      preferably formed to have the same shape, and each is

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                                                               22
                                -7-
      provided with a pair of circular openings 22, that are in
      registry, in the assembled riser,, with the passages 24 of
      the conduit members respectively.   As is easily visualized,
      when the riser is fully assembled, its construction pro-
5     vides a chamber 26 about the conduits 18 and 20 respective-
      17-
           The riser 10 is provided with an opening 28 to which
      a refrigerant fluid supply line  30 is connected.  Dia-
      metrically opposite the .inlet opening 28 in the body of
10 ''   the riser,  the riser is provided with an outlet opening
      in which a refrigerant  fluid discharge 'line 32 is inserted.
           The body of the riser and the base  and top plates are
      also provided with other registering openings (shown but
      not numbered), providing passageways for fasteners for
15    assembling the riser in position at the  inlet port of the
      intake manifold of an automobile engine, and to permit the
      assembly of a general type carburetor on top of the riser.
      For simplicity,  neither the engine nor the carburetor are.
      shown in the drawings.
20         However, in the practice of the invention,  it is
      necessary to make some  adjustments to the standard equip-
      ment of the automobile.   For this  reason,  although the
      carburetor itself is not shown in  the drawing,  a float 34
    ,  and the main jets 36 are shown in  the approximate positions
25    that they would occupy  in the carburetor,  if it  were shown
      in the exploded view of Fig.  1.
           In use,  refrigerant: fluid is  circulated from the
      supply line 30 into the chamber  26.   It  circulates abouc
      the chamber,  in heat exchange contact with the surfaces of
 30   the conduits 18 and 20.   Eventually it leaves the chamber
      through the outlet line 32,  for  return to the refrigerating
      system, as will be described presently.
           The riser body 14  may optionally be provided with
      inwardly projecting ribs or baffles  38.   These serve the
 35   dual function of creating turbulence in  the refrigerant
      fluid and thus improving heat exchange,  and of strengthen-
      ing the riser body.

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                                                                 23
                                -8-

      "„•>: In the embodiment of the invention shown in Fig. 1,
      heat exchange with a fuel-air mixture passing through the
      passages 24 of the two conduits IS and 20 respectively, is
      accomplished because the conduits are thermally conductive.
5     Somewhat improved heat exchange efficiency can be obtained
      in the embodiments of the invention illustrated in Figs.
      2,  3 and 4.
           Referring now to Figs.  2 and 3,  the conduit IS1  is
      formed with a passage therethrough 24',  for providing
IQ    communication between one barrel of a carburetor and the
      inlet port of the intake manifold.  Tubing 40 is inserted
      in fluid-tight fashion through a bore 42 drilled through
      the wall of the conduit 18'.   Within the passage 24'  of
      the conduit,  the tubing 40 is wound through a series  of
]j    convolutions, which generally lie in the same horizontal
      plane.  The tubing is then led out through another bore 44
      drilled through the wall of the conduit, again in fluid-
      tight fashion.  As shown in Fig. 2,  there may be several
      levels of such planar windings disposed within the passage
2Q    of a single conduit.   The exterior lengths of the tubing
      may be connected to a manifold (not  shown) at each side of
      the conduit,  one for- connection to refrigerant fluid
      supply,  and the other for connection to  refrigerant fluid
      return line.
25         Alternatively,  to simplify fabrication,  the wall
      of the conduit may be penetrated only once for the inlet
      or supply side of the tubing,  and once for the outlet
      side of the tubing,  with all  other planar series of con-
      volutions of the tubing being interconnected within the
30    passage in the conduit.   Preferably,  in  addition to the
      several levels of planar convolutions of tubings,  for
      optimum heat  exchange,  shown  in Fig.  2,  at least one
      planar convolution 46 of tubing is disposed to project
      below the lower end of the conduit passage,  so that upon
35    assembly, that convolution 46  projects into the  intake
      manifold.
           Fig. 4 illustrates  a somewhat simpler construction
      for improved heat exchange efficiency as compared to  the

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                                                               24
                                -9-
      structure illustrated in Fig.. 1..  In Fig. 4, the conduit
      18" ia formed with a plurality of thin, radially inwardly
      projecting fins 48.  These are-united at their radially
      inner ends to a thin-walled cylinder 50, for rigidity.
5     The entire structure is metallic for good thermal con-
      ductivity.                     .
           The operation of the device can be illustrated as
      installed in an air conditioned automobile equipped with a
      reciprocating internal- combustion engine and a compressor-
10    type air conditioner.  The riser illustrated in Fig. 5
      has- the.construction as shown in Fig. 1.
      : -  .  Referring now to Fig. 5, the 'riser 10, shown in
      fragmentary fashion in Fig.  5,  should be understood to be
      fully assembled,  so that its chamber 26 is completely
15    enclosed.  Moreover, it is to be understood to be disposed
      between the discharge outlet of a double barrel carburetor
      and the inlet port of the intake manifold.  Its refrigerant-
      outlet line 32 is connected to one 'port of a check valve
      52.   A second port of the check valve 52 is connected
20    through a line 54 to a compound gauge 56 (both; the line 54
      and the gauge 56  are shown in phantom).  A third port of
      the check valve communicates through; a passage 58 in the
      head 60 of the compressor of the refrigeration unit with
      the bore 62 of that cylinder.  A second passage 64 provides
25    communication between the bore 62 of the cylinder of the
      compressor discharge service valve 66.   One port of this
      valve 66 communicates through a line 68 with a high pressure
      gauge 70 (both the line 68 and the gauge 70 are shown in
      phantom).
 30         A line 72 is connected to  the discharge outlet from
      the discharge gauge 66,  to carry compressed refrigerant
      fluid through a series of convolutions  in the condenser.
      The refrigerant fluid then passes from the condenser through
      a line 76, through a check valve 78,  into a receiver
 35    dehydrator 80, that is equipped with a  screen 82 in the
      usual fashion. A length of tubing is arranged with its

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                                                                25

                                -10-
      lower end projecting into the receiver dehydrator 80, and
      with its upper end connected to an expansion valve 86.
      This valve- 86 is arranged with a main discharge line 88
      that supplies the expanded, very cold refrigerant fluid
5     to the interior chamber of a heat exchanger 90.
           This heat exchanger 90 may be mounted just in front
      of'the fire wall of the automobile, or alternatively,
      within the air intake line 'of the air filter, where it will
      chill incoming air.  A coil 92 is mounted within the heat
10    exchanger shell, to carry liquid.fuel from a supply line
      94- through the coil and to a discharge line 96 communi-
      cating with the carburetor.  The chamber of the heat
      exchanger 90, through which the refrigerant fluid circu-  •
      lates, communicates with a line '98, that passes through
15    several convolutions in the evaporator or cooling unit
      section 100 of the air conditioning system.  This is the
      part of the air conditioner system that is intended to
      permit cooling of the passenger compartment of the automo-
      bile.   .
20         After leaving the convolutions in, the cooling unit,
      the line 98 is connected to the refrigerant supply line 30
      of the riser 10.                   •
           In operation.in a typical modern air conditioned auto-
      mobile, refrigerant fluid is discharged from the com-
25    pressor through the line 72 at a temperature of about 170°F
      (77°C).  As the refrigerant fluid enters the receiver
      dehydrator 80, its temperature is about 85°F (29°C).   After
      leaving the expansion valve 86,  the refrigerant fluid is
      extremely cold, and after passing through the liquid fuel
30    heat exchanger 90, the passenger compartment cooling unit
      100, and the riser 10, its temperature is about 10°F to
      20°F (-12°C to -6°C), typically about 17°F (-8°C).
           The outer surface of the riser quickly becomes
      encrusted with frost and ice.  The fuel-air mixture  that
35    is traveling through the passages 24 in the conduits  of
      the riser is chilled to a temperature not above about 40°F

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                                                               26

                                -11-
      (4°C).  The drastic decrease 'in the temperature of the air
      in the 'air-fuel, mixture.,' as it passes through the 'riser,
      causes' moisture to condense out.  Consequently the fuel-
      air mixture passing into the inlet port of the intake
5     manifold carries with it entrained droplets of water,
      which appear to have a very beneficial effect, in known
      fashion,  on the combustion*process.
           The fuel entering the carburetor is pre-chilled
      because of its passage through the heat exchanger 90.  The
10    temperature of the fuel leaving the heat exchanger 90 is
      not above 40°F (4°C) and generally is much lower.
           Since the fuel-air mixture is entering the intake mani-
      fold at a very low temperature, the density of the mixture
      is substantially greater than would be the case if both
15    were at ambient temperature.  It must be remembered that in
      normal operating circumstances for an internal combustion
      engine of an automobile that has been operated for a
      period of time at a normal rate of speed, the temperature
      within the engine compartment of the- automobile may be as-
20    high as several hundred degrees Fahrenheit, so that the
      temperature of the fuel-air mixture entering the intake
      manifold would be well above ambient temperature.  To
      accommodate the chilled condition of the fuel-air mixture
      brought about through use of the present invention,  certain
25    adjustments must be made for proper engine performance.
      First, the float or floats in the. carburetor must be
      lowered,  to reduce the residence time in the carburetor.
      This limits the exposure of the fuel in the carburetor
      to the ambient temperature in the engine compartment, and
 30    helps keep the fuel at either ambient temperature, or at
      the temperature to which it had been pre-cooled,  if a pre-
      cooling heat exchanger is in use.
           Secondly, the opening diameter, of the jet or jets of
      the carburetor must be reduced in size.   The reduction in -
 35    opening diameter should be at least  1.07,, and preferably is
      at least. 20%, and most preferably,  is in the range from

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                                                                27
                                -12-

      30% to 50%,  as  compared to normal opening diameter of a
      standard,  unmodified automobile of the same "kind.
           Third,  the spark plugs muse be replaced with spark
      plugs that are  at least two ranges hotter than would be
5     normal for an unmodified automobile of the same kind.  A
      spark plug range indicates the ability of the spark plug
      to dissipate heat through the  body of its connector,  its
      insulation,  and the  cylinder head of the  engine,  so that
      only the tip of the  plug stays hot.   A spark plug  range
16*    is generally indicated by its  number.   For example, the
      spark plug could be  a No-.  44,  a No.  45, or a No. 46.
      The first  numeral,  (4), indicates that the plug has a
      14 millimeter diameter.   The second numeral denotes the
      heat range of the plug;  the higher the number,  the hotter
15    the spark  plug.   A hot plug would be indicated 'for use when
      the fuel would  enter'the intake manifold  at a relatively
      low temperature or in a liquid state.   In the case of the
     •present invention, the chilled fuel-air mixture requires
      hotter plugs than normal for proper ignition.   Generally
20    plugs two  ranges hotter are satisfactory,  but preferably,
      plugs that are  three ranges hotter are used.   Some experi-
      mentation  may be required to optimize engine performance.
           While not  shown in the drawings  previously referred
      to,  all of the  refrigerant fluid lines are insulated,  as
25    is the line  carrying pre-chilled liquid fuel from  the heat
      exchanger  90 to  the  carburetor.
           Demonstrations  of the use of the  invention on auto-
      mobiles indicate that use of the invention produces a
      substantial  improvement  in the mileage obtained from  a
 30    given quantity  of gasoline fuel.   In addition,  the quality
      of the emission from the exhaust is  improved substantially^
      Performance  seems to be improved to  such  an extent that
      elimination  of  the catalytic converter appears  to  be  a
      possibility.
 35         in the  modified embodiment of the invention illustrated
      schematically in Fig.  6,  the principal difference  from the

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                                                              28

                                -13-
      embodiment of the invention shown in Fig. 5 is that the
      refrigeration unit is of the Serve! type, operating on
      the principle of gas absorption.   The source of heat that
      operates the refrigerating unit may be the exhaust system
5     of the car,  for great economy.
           Referring now to Fig.  6, where primed numerals refer
      to 'components similarly identified by the same numerals
      in Fig.  5,  the refrigerant  leaving the riser 10 passes"'
      through a line 32',  and then through the operating portion
10    of the refrigeration unit,  generally denoted by the
      numeral 102.  Heat is furnished to this unit by inter-
      connection 104 with the exhaust line of the automobile
      engine.
           While the use of the invention has been discussed
13    here in primarily the terms of  its 'application in connec-
      tion with reciprocating internal  combustion engines for
      automobiles, it should be understood that the invention
      can also be employed with reciprocating internal combus-
      tion engines in any kind of installation, and with any
20    kind of fuel delivery system to the engine.
           While the invention has been disclosed herein by
      reference to the details of preferred embodiments thereof,
      it is to be understood that such  disclosure is. intended in
      an illustrative, rather than a  limiting sense,  as it is
25    contemplated that various modifications in the construc-
      tion and arrangement of the parts will readily occur to
      those skilled in the art, within  the spirit of the inven-
      tion and the scope of the appended' claims.

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                                                               29

                                -14-
      WHAT IS CLAIMED' IS:
      1.   Means for adjusting the temperature 'of a fuel-air
           mixture intermediate the discharge outlet of a car-
           buretor and the intake port of the manifold of an
5          internal combustion engine, comprising:
               conduit means having at least one passage there-
           through for interconnecting each discharge outlet of
           a carburetor barrel and an intake port of the manifold,
           to provide communication therebetween for the flow
10         therethrough of a fuel-air mixture, and
               means for circulating a refrigerant fluid in heat
           exchange relation, to said fuel-air mixture within,
           adjacent, or about said conduit means, for chilling
           said mixture to a temperature not above about 40"F
15         (4*C>.

      2.   Means for adjusting the temperature of a fuel-air
           mixture in accordance with claim 1, wherein said
           means for circulating refrigerant fluid comprises
               jacket means disposed about said conduit means,
20         providing a chamber within said jacket and about said
           conduit means,  and
               means for circulating refrigerant fluid through
           said chamber for heat exchange with a fuel-air mix-
           ture passing through said conduit means,
25             said conduit means being thermally conductive.

      3.   Means for adjusting the temperature of a fuel-air
           mixture in accordance with claim 1, wherein said
           means for circulating a refrigerant fluid comprises
               tubular heat exchange means disposed within the
30         passage through said conduit means, and
               means for circulating the refrigerant fluid
           through said tubular heat exchange means,  for heat
           exchange with a fuel-air mixture passing  through the
           passage of said conduit means.

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                                                               30
                                -15-

     4.   Means for adjusting the 'temperature of a fuel-air
          mixture in accordance with claim 3, wherein said
          tubular heat exchanger is formed with a portion there-
          of that projects into the intake port of the manifold.

5    5.   Means for adjusting the temperature of a fuel-air     -""•
          mixture in accordance with claim 3, wherein said
          tubular heat exchange means is in the form of a net-
          work of tubes disposed transversely of the passage
          through said conduit means.

10   6.   Means for adjusting the temperature of a fuel-air
          mixture in accordance with claim 2, wherein said con-
          duit means and said jacket are metallic and generally
          conforms in its peripheral shape in horizontal section,
          to the shape of the base of the carburetor.

15   7.   Means for adjusting the temperature of a fuel-air
          mixture in accordance with claim 6, wherein said
          jacket is formed from a generally tubular body that
          is closed at its upper and lower ends with top and
          bottom cover plates, said plates being formed with
20        apertures in registry respectively with each passage
        ,  through said conduit means.

     3.   Means for adjusting the temperature of a fuel-air
          mixture in accordance with claim 1, 2, or 3, wherein
          said conduit means has either single, double,  or
 25        quadruple passages therethrough, to accommodate a
          single,  double, or quadruple barrel carburetor,
          respectively.

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                                                               31

                                -16-

      9.    Means for adjusting the temperature of a fuel-air
           mixture in accordance with 'claim 1, 2, 3, or 4, where-
           in said conduit means is formed with wall means de-
           fining each said passage therethrough, and with fins
5          that project from said wall means into each said
                                                        *
           passage,  said wall means and said fins being in
         •  thermally conductive relation, whereby the surfaces of
           said fins provide additional heat exchange in each
           said passage for the fuel-air mixture.

10    10.   Means for adjusting the temperature of a fuel-air
           mixture in accordance with claim 8, wherein said
           means for circulating refrigerant fluid comprises
               the air conditioning system of an automobile in
           which said engine is mounted.

15    11.   In combination,  means for adjusting the temperature
           of a fuel-air mixture in accordance with claim 1, and
               heat exchange means for cooling the fuel to a
           temperature not above about 40°F (4°C), disposed to
           cool the fuel prior to its admission to the car-
20         buretor,  and
               means for circulating refrigerant fluid to and
           from said heat exchange means  in heat exchanging
           relation with said fuel.

      12.   The combination of claim 11 wherein said means for
 25         circulating refrigerant fluid  to and from said heat
           exchange means comprises  the air conditioning system
           of an automobile in which said engine is mounted.

      13.   The combination of claim 12 wherein said heat
           exchange means for cooling the fuel is disposed in
 30        front of the fire wall of an automobile in which said
           engine is mounted,.

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                                                               32
                                -17-
      14.  The combination of claim 12 wherein  said  heat
           exchange means for cooling the  fuel  is mounted and
           disposed within the air inlet' passage 'leading  to
           said carburetor, and wherein said heat exchange
5, _,...^,,. /v/meao^foi'-cool3l%;%he'fuel also serves to cool
      ...    incoming .air.  .  ••-"-.'

      15.  In combination, a carburetor for an  internal com-
           bustion engine, and
               means for adjusting the temperature of a fuel-
10         air mixture in accordance with claim 1,
               said carburetor having at least  one float  that
           controls the volume of liquid fuel and the residence
           time of said fuel in said carburetor, said carburetor
           being adjusted to have said float lowered below the
13         level appropriate for the carburetor in the absence
           of said means for adjusting the temperature of the
           fuel-air mixture, and having its jet or jets reduced
           in size to at least 107, smaller opening diameter than
           appropriate for the carburetor in the absence  of said
20         means for adjusting the temperature  of the fuel-air
           mixture.

      16.  The combination of claim 15 wherein  said means  for
           circulating refrigerant fluid comprises the air con-
           ditioning system of an automobile in which said car-
25         burster and said means for adjusting the  temperature
           of the fuel-air mixture are mounted.

      17.  The combination of claim 15 including heat exchange
           means for cooling~*fhe fuel, disposed to cool the fuel
           prior to its admission to the carburetor,  and
30             means for circulating refrigerant fluid to and
           from said heat -exchange means in heat exchanging
           relation with said fuel.

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                                                                  33
                                -18-
      18.  The combination of claim 15,' having its jet or jets
           reduced in size to at lease a 207. smaller diameter
           opening that would be appropriate for the carburetor
           in the absence of the means for adjusting the
5          temperature of the fuel-air mixture in accordance
           with claim I.'

      19.  The combination of claim 18 wherein said jet or
           jets are reduced in size of opening to the range
  c..        from 30^ to 507. of the diameter of opening that
10         would be appropriate for the carburetor in the
           absence of the means for adjusting the temperature
           of the fuel-air mixture in accordance with claim 1.

      20.  In the combination of claim 15, 18, or 19, an internal
           combustion engine having at least one spark plug.
15         said spark plug,, being at least two ranges hotter than
           appropriate for such an engine having an unmodified
           carburetor mounted directly on its manifold, without
           the benefit of the temperature adjusting means of
           claim 1.

20    21.  In the combination of claim 20, said spark plug
           being at least three ranges hotter than appropriate
           for such an engine having a carburetor mounted direct-
           ly on its manifold, without the benefit of the
           temperature adjusting means of claim 1.

25    22.  A process for improving the performance of an
           internal combustion engine that is equipped with a
           carburetor and an intake manifold, comprising
           adjusting the temperature of the fuel-air mixture
           by cooling it just before or as it enters the inlet
30         port of the intake manifold,  to a temperature not
           above about 40°F (4°C).

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                                                                34
                                -19-
      23.  The process of claim 22, including preceding the
           fuel* before it is delivered to  the carburetor,  so
           that it is delivered to the 'carburetor at  a
           temperature not above about 40°F  (4°C).

5     24.  A process according to claim 22 or 23 wherein the
           temperature of the fuel-air mixture, after it leaves
           the carburetor and as it enters the intake of the
           manifold, is not above about 35°F (2°C).

      25.  A process according to claim 24 wherein the fuel  is
10         precooled before it is delivered to the carburetor
           to a temperature not above about 30°F (-1°C).

      26.  A process according to claim 22 or 23 wherein the
           cooling is accomplished by heat exchange with a cir-
           culating refrigerant fluid.

15    27.  A process according to claim 26 wherein the
           refrigerant fluid is circulated by the air condi-
           tioning system of an automobile in which said engine
           is mounted.

      28.  A process according to claim 22, wherein the
20         temperature of the fuel-air mixture, after it leaves
           the carburetor and as it enters the intake of the
           manifold, is in the range from about -20°F to about
           30*F (-29°C to -1°C).

      29.  The process of claim 23, wherein the fuel  is  pre-
25         cooled before it is delivered to the carburetor to
           a temperature in the range from about -20°F to about
           30°F (-29°C to -1°C).

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                                                          35
     DECLARATION, POWER OF ATTORNEY, AND PETITION

     We, James R. Russell, a citizen of the United  States
of America residing at 4805 Polk Avenue, Alexandria,
Virginia 22304; and James M. Russell, a citizen of  the
United States of America residing at 4805 Polk Avenue.
Alexandria, Virginia 22304s declare that we have  read the
foregoing specification and claims and we verily  believe
we are the original, first, and joint inventors of  the
invention or discovery in

          Device and Process for Improving the
      Performance of an Internal Combustion Engine

described and claimed therein; that we do not know  and do
not believe the same was ever known or used in the  United.
States of America before our invention thereof, or
patented or described in any printed publication  in any
country before our invention thereof or more than one year
prior to this application, that the same was not  in public
use or on sale in the United States of America more than
one year prior to this application, that the invention has
not been patented or made the subject of an inventor's
certificate issued before the date of this application
in  any country foreign to the United States of America
on an application filed by us or our legal representatives
or assigns more than twelve months prior to this  applica-
tion, that we acknowledge our duty to disclose informa-
tion of which we are aware which is material to the
examination of this application, and that no application
for patent or inventor's certificate on this invention
has been filed in any country foreign to the United
States of America prior to this application by us  or
our legal representatives or assigns, except as follows:
                          NONE

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                                                           36
     And we hereby  appoint
         Frank  E. Robbins         Registration No.  17,729
       -  James  R. Laramie         Registration No.  26.934
all of Robbins  & Laramie, whose address is  1835 K Street,
Northwest, Washington, D.C. 20006, telephone  (202)  887-
5050,  our attorneys with full power of substitution and
revocation, to  prosecute this application and  to  transact
all business in the Patent Office connected therewith.
Please direct all correspondence and telephone calls to
Frank  E. Robbins, Registration No. 17,729.
     Wherefore we pray that Letters Patent  be  granted to
us for the invention or discovery described and claimed
in the foregoing specification and claims,  and we hereby
subscribe our names to "the foregoing specification  and
claims, declaration, power of attorney, and this petition.
     The undersigned'petitioners declare further that,all
statements made herein of their own knowledge  are true and
that all statements made on information and belief  are
believed to be  true; and further that these statements
were made with  the knowledge that willful false statements
and the like so made are punishable by fine or imprison-
ment, or both, under section 1001 of Title  18  of the
United States Code and that such willful false  statements
may jeopardize  the validity of the application or any
patent issuing thereon.
         Inventor
                  First Name  Middle InitialLast Name
                  James             R.        Russell
         Date
         Post Office Address:  4805 Polk Avenue
                               Alexandria, Virginia  22304
         Inventor
                  First Name  Middle Initial  Last Name
                  James             M.        Russell
         Date
         Post Office Address:  4805 Polk Avenue
                               Alexandria, Virginia  22304

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                                                         ..37
     DECLARATION, POWER OF ATTORNEY, AND  PETITION

     We, James R. Russell, a citizen of the United  States
of America residing at 4805 Polk Avenue,  Alexandria,
Virginia 22304; and James M. Russell, a citizen of  the
United States of America residing at 4S05 Polk Avenue,
Alexandria, Virginia 22304; declare that we have  read the
foregoing specification and claims and we verily believe
we are the original, first, and joint inventors of  the
invention or discovery in

          Device and Process for Improving the
      Performance of an Internal Combustion Engine

described and claimed therein; that we do not know  and do
not believe the same was ever known or used in the  United
States of America before our invention thereof, or
patented or described in any printed publication  in any
country before our invention thereof or more than one. year
prior to this application, that the same was not  in public
use or on sale in the United States of America more than
one year prior to this application, that the invention has
not been patented or made the subject of an inventor's
certificate issued before the date of this application
in  any country foreign to the United States of America
on an application filed by us or our legal representatives
or assigns more than twelve months prior to this applica-
tion, that we acknowledge our duty to disclose informa-
tion of which we are aware which is material to the
examination of this application, and that no application
for patent or inventor's certificate on this invention
has been filed in any country foreign to the United
States of America prior to this application by us or
our legal representatives or assigns,  except as follows:
                          NONE

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                                                        38
     And we hereby appoint
         Frank E. Robbins      '   Registration No. 17,729
         James R. Laramie         Registration No. 26,934.
all of Robbins & Laramie, whose address is 1835. K. Street,
Northwest, Washington, D.C. 20006, telephone  (202) 887-
5050, our attorneys with full power of substitution and
revocation, to prosecute this application and to transact
all business in the Patent Office connected therewith..
Please direct all correspondence and telephone calls to
Frank E. Robbins, Registration No. 17,729.
     Wherefore we pray that Letters Patent be granted to
us for the invention or discovery described and claimed
in the foregoing specification and claims, and we hereby
subscribe our names to the foregoing specification and
claims, declaration, power of attorney, and this petition.
     The undersigned, petitioners declare further that all
statements made herein of their own knowledge are true and
thalr all statements made on information and belief axe
believed to be true; and further that these statements
were made with the knowledge that willful false statements
and the like so made are punishable by fine or imprison-
ment, or both, under section 1001 of Title 18 of the
United States Code arid that such willful false statements
may jeopardize the validity of the application or any
patent issuing thereon.
         Inventor
                    ,rst NameMiddle InitialLast Name
                   rames             R.        Russell
         Date . ..	
         Post Office Address:  4805 Polk Avenue
                               Alexandria,  Virginia  22304
         Inventor
                 /1>irst Name  Middl£ Initial  Last Name
                /James             M.        Russell
         Date
         Post Office Address:  4805 Polk Avenue
                               Alexandria,  Virginia  22304

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                           39
34
          FIG.1

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                                        40
42,
       ^ r
           '   ]   l
       r r
       "   f   1   c    ^
V
                          •24'
            FIG. 2
            F/S.3

-------
                         41
                              81
F/6.5

-------
                         42
FIG. 6

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                         43
TANK

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                                                                                  .!


                                                                                  I
I ,
                                                                       _-. T *«*•£» ^
                                                                       f     *•**•
\fl

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                                                                             45
Exhibits 1, 2, 3, and 4

EPA  could  not  obtain  legible  copies  of  the  subject  documents  and
therefore, they  have  not been made part of  this Attachment.   Individuals
may request  copies  of these  documents  from:  Merrill W.  Korth,  Emission
Control  Technology  Division,  Office  of  Mobile  Sources,  Environmental
Protection  Agency,   2565 Plymouth  Road,  Ann  Arbor,  MI   48105.   (313)
668-4299.

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                                                     Attachment B        .r
                                                                           46
                         PROPRIETARY
Tr.I6 DISCLOSURE CONTAINS INFORMATIOK-WRI-CH-IS— U4— A- -TRADE- SEC3ET-CIR  (
        OR FINANCIAL I11FORMATION--THAT^-SS— PRiV-ILEGED-OR- CONFIDENTIAL.
                           DISCLOSURE DOCUMENT
    TITLE:   Device and Process for Improving the Performance of an Inter-
            nal Combustion Engine. Common Title:  Russell Fuelmiser.

    PURPOSE OF THE INVENTION:  The invention described herein improves
    the performance of the internal combustion engine and thereby im-
    proves  the mileage delivered by a given quantity of fuel and redu-
    ces the pollutants emitted by the exhaust system.

         Following is a simple narrative describing the function and pro-
    cess of the invention.  A more detailed and complete description and
    drawings are contained further within the Disclosure Document:

         PATH OF THE REFRIGERANT:  Refrigerant leaves the air conditioning
    condenser, passes through the expansion valve and enters the fuel-
    chilling tank.  The refrigerant surrounds and chills the fuel which
    is passing through the coils within the fuel-chilling tank, and exits
    the fuel-chilling tank.  The refrigerant proceeds to enter the 'riser'
    which is placed under the carburetor and on top of the intake mani-
    fold.  The refrigerant cools the air/fuel mixture within the throat(s)
    of the  'riser' and exits the 'riser'  enroute to the compressor thus
    completing the cycle.

         PATH OF THE FUEL:  The fuel leaves the fuel pump and enters the
    fuel-chilling tank.  While passing through the coils contained with-
    in the  fuel-chilling tank, the fuel is chilled by the refrigerant
    therein, and proceeds to the carburetor inlet.  The fuel enters the
    float chamber (inwhich the float level has been lowered), passes
    through the carburetor jets, (in which the orifice size has been re-
    duced) , and thence through the 'riser' where the fuel/air mixture is
    again chilled, and enters the intake maniford enroute to the combustion
    chambers. The spark plug heat range is increased as appropriate to
    the jet orifice size in conjunction with fuel, air and temperature.

    THE EXISTING METHODS:  No existing method of increasing fuel mileage
    and/or  reducing pollutant emissions duplicates the function of this
    invention.  There are however, several devices being marketed today
    which 'claim1 to increase fuel mileage and/or reduce pollutants. NONE
    uses the proces or.system described herein.

    STATUS  OF THE INVENTION:  Our test results, (Ends No. 5,6,7, and 8),
    were produced by tests on equipment and using methods which closely
    duplicate the methods and equipment used by the Enviornmental Protec-
    tion Agency (EPA), for their evaluations.  Our tests were conducted
    on the  Sun Electric Mark XI Dynomometer and very accurately demon-
    strate  a substantial increase in fuel mileage.  Test results have
    varied  from a 50 per cent increase in fuel mileage, (never less), to a
    100 per cent increase in fuel mileage,  we need to develop an ac-
    curate  determination of the proper ratio of air, fuel, jet size, tem-
    perature, and spark plug heat range in order to achieve the maximum
    performance possible for various engine sizes, fuels and fuel systems.
    This must be done so that a dependable determination of mileage in-
    crease  can be accurately predicted and the full potention of the in-
    vention can be realized.  Given the range of fluctuation of fuel
    mileage increases -50 to 100 per cent- we feel the higher range of
    increase percentage in imminently possible, with great probability
    of exceeding the 100 per cent mark.(See enclocure 4 wherein it states
    that less than 20 per cent of the fuel energy is converted into energy
    for a car's performance).

         It is not a question of whether the invention works, it is merely
    a matter of how well:

         Testing on fuel injection engines and diesel engines has been


            2.

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                                                                           47
Russell Fuelmiser cont.


cursory   *?e have used only the  'historical' method  oi  teo>.i».s
which is totally unscientific and  inaccurate except  when  conducted
over a'prescribed course, using  professional drivers (two per car),
and is timed to the second over  the  entire  course  and at  critical
points within the course.  This  is usually  a most  expensive, time
consuming and less accurate method of conducting these  tests than
using the dynomometer.  To date, our tests  results on diesel engines
(not documented by dynomometer tests),  indicate a  fuel  mileage in-
crease of 30 percent.  Tests with  the fuel  injected  engine portend
a fuel mileage increase in excess  of 75 percent.

     We have not begun testing engines  converted to  natural gas,
propane, methane, etc., nor on rotary or turbine engines.  We anti-
cipate continuing development and  testing of the previously tested
engines before embarking upon these  tests unless sufficient capital
and equipment for such tests become  available.  Most of  the test
equipment and materials to be used in such  tests of  these engines is
the same used in the development and testing of the  carburetor, fuel
injected and diesel engine.

     The total impact of the successful development  of  this invention
in just the basic areas mentioned,  (carburetor, fuel injected and
diesel engines), on the United States alone is incalculable.  A prudent
assessment can be made.  The United  States  currently spends $224 mil-
lion each day on imported oil.   Annually that is over $80 billion
which can be saved each year.

     Our military vehicles,(trucks,  tanks,  personnel carriers, artil-
lery pieces, light planes, etc.) use gasoline and  diesel  fueled en-
gines for motive power.  An increase of only 25% in  the "battle field
day",(the length of time equipment can  operate on  the battle field
without, resupply), for our military  forces  would provide  the U.S.
Armed Forces with an advantage that  just cannot be evaluated in dol-
lars and cents.

     Small craft of the U.S. Navy, larger craft of our  Naval and Mari-
time Service and various size craft  of  our  fishing fleets and myriad
size pleasure craft used at sea  and  upon inland waterways use gasoline
and diesel engine power.  A minimum  decrease of only 25%  in fuel usage
for these ships and boats is beyond  our accurate calculation or 'pru-
dent ' assessment.

     There are approximately 170 million passenger cars and trucks
operating on the highways of the U.S. today.  Our  automobile industry
produces approximately 6 million such vehicles each  year  and we im-
port approximately 4 million foreign automobiles each year.  Even the
minimum 50% fuel mileage increase  already demonstrated  would save U.S.
citizens billions of dollars each year  and, as important, break the
yoke of our dependency upon expensive imported oil which  has been im-
posed upon us by the OPEC nations.

     Sharing this invention with other  industrialized nations would
impact significantly ttpon the political aspect of  our future nego-
tiations with all the nations of the world.

     The Energy Research Corporation (Encl. 4), estimates that less
than 20% of fuel used in internal combustion engines is converted
into energy for a car's performance.  Even  if their  estimate should
be proven true, our  invention at  this  early stage of development has
demonstrated , and documented, mileage  increases that make their fig-
ures me os.

     Without considering the savings accruing to our government or its
citizens;  the rar.scr; imposed upon us by the OPEC  countries will be
broken.   We will no longer have  to be dependent upon or responsive to
the whims of a few individuals who control  the OPEC  national policies
of oil exportation.

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                                                               Attachment  C  43
November 16, 1981
Mr. James M. Russell, President
J.C.A. Corporation
1307 E. Capitol Street, N.E.
Washington, D.C.  20003

Dear Mr. Russell;

I have received your letter of October  26  in which  you applied for an EPA
evaluation  of  the  "Russell  Fuelmiser" under  Section  511  of  the  Motor
Vehicle Information  and  Cost  Savings Act.   The  contents of  your applica-
tion have  been reviewed  by our  Engineering  Evaluation  Group.  Following
are their comments and  requests  for clarifications  or additional informa-
tion.

    1.   Is the device  currently available to the public?   If so,  how is
         it being marketed and what is  the suggested retail price?

    2.   With  regard to  installation  of  the device,  do you  forsee  any
         clearance  problems  due to  the  additional  height  of  the  car-
         buretor?  Are you certain  that only two models of the riser will
         be able  to  accommodate  the complete range of carburetors in use
         today?   Have  you developed any  installation  instructions beyond
         the sections  in  your Enclosures  1  and  2?   We  are  interested in
         reviewing the  actual documents which will be  supplied  with  the
         device.   Your  instructions  include  lowering  the  float  level,
         installation  of  smaller  jets and  use of  spark  plugs with  a
         higher  heat range.   Are  there  any other adjustments required,
         e.g.,   timing,   idle   mixture,   or  choke,    to   optimize   the
         performance of the device?

    3.  --In~the operation of  the device,  it  appears that the vehicles air
         conditioner must be  on  at  all  times.  If  this  is  true,  how were
        -the  air  conditioning   controls  set for each  of  the  tests  at
         Custom Engineering?   How well  can a modified  vehicle operate if
         the air  conditioner  is  broken  or  is not used?

    4.   According  to  your application,   the fuel-air mixture  is cooled
         substantially  before it enters  the intake manifold.   While  the
         fuel  itself could be  chilled  in advance, we believe  that  the
         amount of heat that  could  be drawn from the  mixture is insignif-
         icant.   Do  you have  any data  which compares  the temperatures of
         the incoming charge  with and without your  device?  How does your
         device  prevent  carburetor icing  and ensure  proper vaporization
         of the  fuel?  Can it  be  effective in  all  climates  during  all
         seasons  of the year?

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                                                                       49
5.    We have reviewed  the  test  results you supplied with  your appli-
     cation.  These include data  from Custom Engineering  and  results
     from another  facility which  used a  Sun Dynamometer.   Although
     testing on  a Sun  Dynamometer is  not recognized  by  EPA as  an
     official technique  to evaluate  devices,  we will  consider  the
     results.  Please provide more  information  on these  latter  tests
     such as the name and  location of the laboratory, details on the
     test vehicles and how they were  prepared for each  test.  In one
     statement  in  Enclosure  2, you  note  "Test  results have varied
     from a  50  percent  increase in fuel mileage,  (never less)   to  a
     100  percent  increase  in  fuel  mileage."   The   results  which
     accompany  this  enclosure  indicate  several  instances where  the
     increase was  outside this  range,  primarily  on  the  low  side.
     There also appear to  be several  anomalies  in the test  data from
     the Sun Dynamometer.  The 1969 Chrysler  was  apparently  tested  at
     77 and 78 horsepower  at 31  and 30 miles per hour,  respectively.
     This type  of  loading  is not  generally representative  of  typical
     driving.  The results for the  1981  Chevrolet appear to have been
     obtained at  two different  speeds while  the tests  on the  1978
     Chevrolet  seem to have been conducted at  different  loads.

     The  results  from  Custom  Engineering  have  also  given  us  some
     cause for  concern.  Although we  require  duplicate  test  sequences
     on two vehicles with and without  the  device,  you  submitted  trip-
     licate test sequences on only  one vehicle.   The results of  these
     tests do not support your claims for a fuel  economy benefit.  We
     acknowledge  your contention   that  the  additional  water  vapor
     introduced  into  the  combustion  chamber  causes  carbon  particles
     to be released but do not feel that  this phenomenon,  if present,
     would have any measurable effect on the carbon balance  calcula-
     tion.  The  steady state  tests  which  were  conducted at Custom
     Engineering are not recognized by EPA as appropriate  but  we have
     considered  them.   Please  provide  more   information  on the  test
     vehicles and  the procedures' \ised  by your  personnel to'  prepare
     the vehicles for testing.   Not only did  my  original letter  indi-
     cate  the  need  for  two test   vehicles,  it  also  specified  that
     devices which  require parameter' adjustments also  need a  third
     test configuration -  one with  the parameters adjusted  but  with-
     out the device.   You  should  include  this  configuration  in  your
     future testing.   I am prepared  to  help you  develop an appro-
     priate plan.

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                                                                               50
 Your responses  to the  questions above  will  be  required  before we  can
 procedd with the EPA evaluation  of  your device.  Since we  intend to con-
 duct these evaluations on a  timely  basis, we  have  established  a schedule
 for each.  Please submit your response  to  this letter  by  December 14.   If
 you have  any questions  or  require  further  information,   please contact
 me.  My telephone number is (313) 668-4299.

 Sincerely,
'f 
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                                                      Attachment  D           51
March 24, 1982
Mr. James M. Russell
J.C.A. Corporation
45 L Street, N.W.
B 24311
Washington, DC  20024-1611

Dear Mr. Russell:

In a letter dated  November 16, 1981, we asked  for additional information
on your application  for an  EPA  evaluation  of the  "Russell Fuelmiser".
Your  letter of  February 1  stated  the  information would  be on  its  way
within thirty days.  We have not yet received your response.

In order for  us to evaluate  your device on  a  timely basis, we  ask that
this  information be  submitted  by April 9.   Otherwise,  we  will  complete
our evaluation  using "the  information we have.  A  copy of  our report will
be sent to you  prior  to  its  announcement in the Federal  Register.  Please
contact me  as  soon as possible if  you  have any questions.   I  am looking
forward to hearing from you.

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

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J.C.A, CORPORATION,                             ATTACHMENT E
                                                             52

                                        8  April  1982
                                     45 L Street S.W.
                                          B/24311
                                 Washington, D.C. 2004-1611
                                      (202)  554-5332
                                      (703)  370-4937
Mr. Merrill E. Korth
U.S.Environmental Protection Agency
Office of Air and Waste Management
Ann Arbor, Michigan 48105


Dear Mr. Korth:
     I shall respond to your Nov 16, 1981 letter,(remailed on
January 13, 1982), paragraph by paragraph thus providing us a
mutually available reference.  All paragraph numbers refer to
your letter.

     1.  No. It is not now available to the public.  Tooling
is in the process of completion.

     2.  We have experienced clearance problems on the Cadil-
lac El Dorado.  This was easily corrected by changing gaskets.
I am not certain that only two  (2) models of the riser will be
able to accomodate all carburetor-intake manifolds.  We do
plan to produce risers with multiple bolt patterns.  Even so,
we still shall probably have to produce more than two (2) ri-
ser models.  (I shall deal separately with installation in-
structions) .

     3.  Yes.  The vehicle air conditioner is to be on at all
times.  The air conditioner was operating during all tests.
A modified vehicle,(with Fuelmiser device installed), will op-
erate if the air conditioner is broken.  The vehicle will not
achieve nearly the same fuel economy, it will run hotter and
will probably diesel.  Proper installation of the device per-"
mits the A/C compressor to function (for benefit of the device)
as well-as permitting the heater to operate when necessary,
for comfort of the passengers.  They may both operate at the
same -time summer or winter.

     4.  Please observe that the chilled fuel enters the car-
buretor and ambient air and chilled fuel pass through a frost-
ed riser. I~have".no temperature comparisons.  I have never
seen an "iced" carburetor nor have I been able to locate an
auto mechanic who has seen one on a car.  The engine compart-
ment temperature is quite hot, especially in newer cars, re-
gardless' of seasonal temperatures.  We are not freezing the
fuel (-274*) merely chilling it.

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                                                           53
Our device does not have the capability of freezing the fuel.
Water in the fuel was, in days past, a problem and our device
could possibly freeze it under the proper conditions.  That
amount of water passing the filtering devices probably would
cause the engine to malfunction anyway.  We have run several
cars through-'-. this past winter, in which sub-zero temperatures
were common, with no difficulty at all.  The engine answers
the question of proper vaporization by functioning better and
delivering an infinitely better fuel economy.  We have not ex-
perienced any seasonal difficulties or changes in engine/device
performance due to seasonal changes.  Sensors controlling the
A/C compressor maintain the riser and fuel chilling tank at a
constant temperature.

     5.  Tests using the Sun Electric Dynomometer (Roadomatic
Mark XI) were conducted by personnel at the:
                  Norris Garage
                  5509 Livingston Road
                  Forest Heights, Md. 20021
The engines were prepared as stated in the disclosure documents
in that the engines were tuned without the device and tested.
Then the device was installed, the engine again tuned and test-
ed.  Our statement of 50% increase in fuel mileage (never less)
was (is) based on cumulative mileage.  You may note that in
several instances, at different speeds, the mileage increases
exceed 100%I  We had no actual control over the tests on the Sun
machine.  The operator was asked to subject the autos to before
and after tests using the same simulated conditions.   The 'trip-
licate1 .test sequence from Custom Engineering was submitted to
you only as part of what they had in-fact done.  We have explain-
ed the reason for invalidation of the tests other than the sep-
erate source  tests.  I have examined the pertinent results of
testing conducted by Custom Engineering and can find no basis
for your statement, "The results of these tests do not support
your claim for a fuel economy benefit."  In each case, the fuel
benefit claimed on a cumulative basis - since vehicles operate
over a range of speeds - exceeded 50%.  The Ford was  in-fact
considerably over that figure.  The steady-state tests conducted
by Custom Engineering were~~conducted according to EPA procedures,
i.e., para 610.42 Federal Register, Part VIII, dated March 23,
1979 and US Environmental Protection Agency, Office of Air and
Waste Management Publication Nr. FS-5, Title: EPA Retrofit and
Emission Control Device Evaluation Test Policy, Page  A-9.  Custom
Engineering used a graduated buret which was coupled  to a timer
in hundredths of seconds and a dynomometer when making the steady-
state tests.  The tests were totally scientific and objective, as
attested in their report.  The vehicles were first tuned to man-
ufacturers specifications by their personnel and tested.  They
then had the spark plugs changed, the jets were reduced by 10%
on the Ford Truck only, and the device was installed.  The car-
buretors were adjusted for smooth running and the tests were
made.  Timing was advanced ten degrees  (10*).

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                              3-
     All adjustments and changes of equipment were made by, or
under the supervision of Custom Engineering personnel.  The Cad-
illac El Dorado Biaritz (1978) has continued operation with the
device installed.  The Ford Pick-Up Truck (1978 3/4 ton) has con-
tinued operation with the device installed.   Neither has exper-
ienced any difficulty in operation for any reason.

     I believe that many of your questions could be better di-
rected to Custom Engineering,  We were assured by them that they
had contacted your office regularly, that they knew exactly the
tests you required and that they were totally capable of making
such tests.  On that basis we paid them over $4,ooo.oo and a
like amount was spent on travel and expenses.  We can not afford
to have to do the whole thing over again.

     We have since purchased our own buret and timer and contin-
ue to test and work with the device.  Our current projects in-
testing on fuel injected and diesel engines.  I shall certainly
keep you informed of results.

     Thank for your kind assistance and patient consideration.

                               Sincerely yours,
                               JAMES M. RUSSELL
                               President

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                                                                           55
              .                                             Attachment  F
        UNITED ST.i^ES ENViPr\v-N-ii  = pnr->	-•  - .: -  .--.
                    '           '     -•..-••---•.-•  •-....  • -
May 24, 1982                                                 iis. ,JO;S^,;- ^I

Mr. James M. Russell
4805 Polk Ave.
Alexandria, VA  22304

Dear Mr. Russell:

The  Post  office  has  repeatedly returned  our  letters addressed  to  the
address on  your company letterhead.  As  a  result, I  am send  this  letter
to your home address.

I have received your letter  of  April 8 which responded  to our  preliminary
evaluation  letter  of  November 16.   1981.   Although you addressed some  of
our concerns, you  did  not  address them all.   In fact, your letter  raised
some new  questions.   These concerns/questions  are  given below.  The  item
numbers correspond to  those listed in your  letter.

    1.   What is the  tentative  suggested  retail price of the device?   How
         do you plan to market it?

    2.   Have you  developed any  installation  instructions  for purchasers
         of the device?  If so,  please submit a copy.

         In paragraph  2 of  your  letter,  you did not address whether other
         changes (e.g.,  timing,  idle mixture,  or  choke) were  required  in
         addition  to  the  changes  mentioned  in  the  application,  i.e.,
         float  level,  jet size,  and spark plug heat  range.   However,  in
         paragraph 5 you  state  "the  vehicles tested by  Custom  Engineering
         had the spark plugs  changed,  the jets  were reduced by 10% on  the
         Ford truck  only,  and the device was  installed.  The  carburetors
         were  adjusted  for  smooth  running  and   the  tests   were  made.
         Timing  was  advanced ten degrees  (10°)."   Based on  your  state-
         ments,  it is  my understanding that a)  the changes  in spark plug
         heat range, float  level, and  jet size are not.required for every
         vehicle in  which the device  is  installed and  b),  other adjust-
         ments,  i.e.,  timing  and idle  mixture  not  mentioned in the appli-
         cation  are  required for some or  all  vehicles.   Please clarify
         exactly  what  adjustments   are   required   and  whether they  are
         required  for  all  vehicles.   How do you determine  which vehicles
         require engine  parameters  to be adjusted?   How do  you determine
         the specific  setting for each parameter?

    5.   With respect  to  the  tests  performed using the  SUN Electric Dyna-
         mometer you  state, "the engines  were prepared as  stated  in  the
         disclosure  documents".  The  disclosure  documents  do not  ade-
         quately  detail how  the engines  were  prepared.   Please clarify
         what specifications  the engine  parameters were  adjusted  to when
         tested with and without  the device.

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                                                                          56
         With  respect   to  tests  performed  by  Custom  Engineering,  you
         state,  "we  have explained  the  reason  for  invalidation of  the
         tests other  than the  separate  source  tests".   Please  clarify
         that statement.  Additionally you state,  "the  steady-state  tests
         conducted by Custom Engineering  were  conducted according to  EPA
         procedures,  i.e.,  para 610.42, Federal Register Part  VIII,  dated
         March 23, 1979."  Please note that EPA does  not have  a specified
         steady-state test  procedure.   Further,   the  referenced  Section
         610.42 does not address  steady-state testing.  I  would  like  to
         bring to your attention that  Section  610.40  states,  "two chassis
         dynamometer  test  procedures,  the  Federal Test  Procedure  (FTP)
         and the Highway Fuel Economy Test  (HFET)  will generally be used
         to evaluate  the effectiveness of the  device  supplemented (under-
         line added  for emphasis)  by  steady-state or engine  dynamometer
         tests where  warranted."  This  means  that  steady-state  tests  are
         not used in lieu of FTP and  HFET testing. Additionally, Section
         610.41  provides  that  for  those devices which  require engine
         parameter adjustments to  be made,  tests  will  be performed with
         the  parameters adjusted  exclusive  of  the   retrofit  hardware.
         This means  that during  the  test  program "on  the Russell  Fuel-
         miser, each vehicle must be  tested in three  different configura-
         tions.   The  requirements  of  replicate  testing of  at  least  two
         vehicles in three configurations using the  FTP  and  HFET proce-
         dures were previously explained in  my original  letter to you.

         Further, Section 610.42(b) requires -the carbon balance procedure
         for measuring  fuel  consumption  unless  track or  road  tests  are-
         employed.  As  previously stated  in  my November 16 letter,  we  do
         not believe  the release of carbon particles  as a  result of  addi-
         tional water vapor will have  any measurable  effect on the carbon
         balance calculations.  Therefore,  future  testing  should  be done
         using the carbon balance method.   The gravimetric or volumetric
         procedures may be  used to  supplement,  the  carbon balance method.

         Our last comment with respect to Paragraph 5 is that  you did  not
         adequately detail all the changes made to the  vehicles tested  by
         Custom Engineering.  For  example,  what were  the  differences  in
         spark  plugs?   For  each  test  configuration,   please  provide
         specific  settings   for all  parameters   that  were   subject   to
         adjustment.
                                s'
Thus, in addition to clarifying certain portions of your letter,  we  still
need new  test data.    I am prepared  to help  you  develop  an  appropriate
plan.

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                                                                         57
We ask that you  respond  to  this  letter by June 9 and that you  submit all
new test data  by  July  9.   Should we  not hear from you by  these dates,  we
will complete  our evalutation using  all available  information.   A copy of
that  report  will be  sent  to  you prior to announcement  in the  Federal
Register.

Sincerely,


   ^UJLZ-
Merrill W. Korth
Device Evaluation Cooridinator
Test and Evaluation Branch

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