EPA-AA-TEB-511-82-8
EPA Evaluation of the Jacona Fuel System Under Section 511
of the Motor Vehicle Information and Cost Savings Act
by
Edward Anthony Barth
August 1982
Test and Evaluation Branch
Emission Control Technology Divison
Office of Mobile Sources
U.S. Environmental Protection Agency
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EPA Evaluation of the Jacona Fuel System Under Section 511 of the Motor
Vehicle Information and Cost Savings Act
The Motor Vehicle Information and Cost Savings Act requires that EPA
evaluate fuel economy retrofit devices and publish a summary of each
evaluation in the Federal Register.
EPA evaluations are originated upon the application of any manufacturer
of a retrofit device, upon the request of the Federal Trade Commission,
or upon the motion of the EPA Administrator. These studies are designed
to. determine whether the retrofit device increases fuel economy and to
determine whether the representations made with respect to the device are
accurate. The results of such studies are set forth in a series of
reports, of which this is one.
The evaluation of the Jacona Fuel System was conducted upon receiving an
application for evaluation from the inventor/marketer of the device. The
device is claimed to improve a vehicle's fuel economy without adversely
affecting emissions. The device is an electrically powered in-line fuel
heater.
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 Jacona Fuel System under Section 511 of
the Motor Vehicle Information and Cost Savings Act
2. Identification Information;
a. Marketing Identification of the Product;
Trade name: JACONA FUEL SYSTEM
Model Number: JE 6-2 (Electric Only)
JEW (Electric and Water)
b. Inventor and Patent Protection;
(1) Inventor
Jack R. Dodrill
1510 Londondale Parkway
Newark, Ohio 43055
(2) "Patent applications are pending."
c. Applicant;
(1) Jacona, Inc.
1510 Londondale Parkway
Newark, Ohio 43055
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(2) Principals
Jack R. Do drill
1510 Londondale Parkway
Newark, Ohio 43055
John L. Gray
Emens, Kurd, Kegler & Ritter
250 East Broad Street
Columbus, Ohio 43215
(3) Jack R. Dodrill and John L. Gray are authorized to
represent Jacona, Inc. in communication with EPA
d. Manufacturer of the Product;
(1) Heat Exchange & Transfer, Inc.
500 Superior Avenue
Carnegie, Pennsylvania 15106
(2) Principals
Howard E. Meyer, President
3. Description of Product (as supplied by Applicant);
a. Purpose;
"A method of treating fuel for an internal combustion engine."
b. Theory of Operation;
"Fuel, such as gasoline or diesel fuel is heated utilizing waste
heat from the engine, to a critical temperature. The heated
fuel is then introduced into the engine in the normal fashion.
Fuel savings of 25 percent have been consistently achieved, and
considerably higher results have also been obtained.
Objectionable emissions have been kept below EPA maximums."
c. Construction and Operation;
"The device is a heat exchanger which is contained in an
insulated shell and which contains a heat transfer fluid which
is preferably ethylene glycol. The fuel traverses the
cylindrical container in the fluid in a sealed, coiled tube
which is preferably made of seamless copper tubing. Also
immersed in the fluid and extending the length of the container
is an electrical heating element which is controlled by a solid
state thermostatic control utilizing a sensor which controls the
temperature of the heat transfer fluid. Attached as Exhibit A
is a drawing of the device." Exhibit A is Attachment A.
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4. Product Installation, Operation, Safety and Maintenance (as supplied
by Applicant);
a. Applicability;
"JE 6-2 is for all domestic and foreign automobiles, diesel or
gas powered, fuel injection or conventional carburetors, up to a
maximum size of 350 cu. in.
"JEW is useful for anything larger than that including diesel
truck engines and off-the-road vehicles."
b. Installation - Instructions, Equipment, and Skills Required;
"The device is connected between the outlet of the fuel pump and
the inlet of the carburetor. It is preferably mounted on the
fenderwell of the car. The controls are mounted under the
dashboard in the car. The electrical connections go to the
positive and negative terminals of the battery. The device is
wired to the igniton so that it is activated when the engine key
is turned on."
c. Operation;
"The operation of the device is entirely automatic and there are
no instructions needed for its use."
d. Effects on Vehicle Safety;
"The device utilizes ethylene glycol as an intermediate heat
exchange agent and thus the fuel is not directly heated by the
electrical heating units. The unit has a temperature sensor at
the carburetor and at the unit, and either of these sensors can
turn the unit off."
e. Maintenance;
"There is no maintenance required on the device."
5. Effects on Emissions and Fuel Economy (submitted by Applicant);
a. Unregulated Emissions;
"The device has been tested at A.P. Parts Company, Toledo, Ohio
in October 1980 and passed the test. A.P. Parts Company is an
EPA-approved testing facility and the test results are attached
as Exhibit B." Exhibit B is Attachment B.
b. Regulated Emissions and Fuel Economy;
"The test results on emissions are summarized and included in
the affidavits which accompanied the letter from John L. Gray to
Merrill W. Korth dated July 27, 1981, a copy of which is
attached and marked Exhibit C." This letter is Attachment C of
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this evaluation. The emissions data submitted with the letter
was the testing at A.P. Parts Company which is Attachment B.
The affidavits are 18 notarized documents in which the vehicle
operators stated their mileages with and without the device.
These data are summarized in the letter of July 27, 1981.
Analysis
a. Identification Information;
(1) Marketing Identification: Although the application covered
two models, JE 6-2 (electric only) and JEW (electric and
water), the descriptions submitted appeared to apply only
to the Jacona Fuel System model JE 6-2.
(2) Inventor and Patent Protection: Although EPA requested a
copy of the patent application as an aid in evaluating the
Jacona Fuel System (Attachment E), the applicant failed to
provide either a copy of it or the application number.
b. Description;
(1) The primary purpose of the device is to improve fuel
economy by heating the fuel. Since the model JE 6-2
(electric only) device is installed in the fuel line, it is
judged to be able to heat the fuel to some limited extent.
The ability of the model JEW (electric and water) to
function is unknown since this model was not described.
(2) In describing the operation of the device in Section 3b,
the applicant stated that the device heated the fuel,
"... utilizing waste heat from the engine, to a critical
temperature." However, neither the drawing of the device,
its description, or the installation instructions include
any use of "waste heat". For Model JE 6-2 the fuel appears
to be heated only by electrical heating elements.
EPA requested (paragraph 1, Attachment E) the applicant to
clarify what was meant by waste heat and to describe how it
was used. Also what was the critical temperature and why
was it critical. The applicant did not respond to this
request.
(3) The description of the device given in Section 3c is a
generalized, non-specific description of the device. It
does not describe a device using waste heat. It does not
provide sufficiently detailed information about the
device's effect on the fuel. EPA requested (paragraph 3,
Attachment E) additional details:
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, description of the device. What is the
temperature set point of the thermostatic control?
Please describe the control in greater detail. What
is the heating capacity of the electric heating
element? How much is the temperature of the fuel
raised? Please provide representative fuel inlet and
outlet temperatures for representative ambient
conditions while the vehicle is operating."
No response was received. Thus, the heating capacity of
the device is unknown.
In addition, neither the description of the device,
drawings, nor schematics show the ". . . temperature sensor
at the carburetor . . ." mentioned in Section 4d EPA
requested (paragraph 7, Attachment E) additional
information about this sensor but received no response.
(4) The device is claimed to consistently achieve fuel savings
of 25 percent (Section 3b). This claim is apparently based
on the driver testimonials contained in Attachment C. As
described in Section 6d(2), these data do not represent a
controlled evaluation of the device and, therefore, cannot
support the claim for a fuel economy improvement for the
device.
Emissions were claimed to be kept below EPA maximums
(Section 3b). EPA requested the applicant to clarify this
claim in paragraph 2 of Attachment E.
"Exactly what is meant by this statement (were
emissions lowered, unchanged, or raised but not over
statutory limits)? Were these measured by the Federal
Test Procedure (FTP)? Are there any emission test
results besides those provided with the application?"
No clarification was received.
(5) No cost information was provided.
c. Installation, Operation, Safety and Maintenance;
(1) Applicability;
(a) Based on the limited information supplied by the
applicant, the applicability of the product as stated
in Section 4a to ". . . all domestic and foreign
automobiles, diesel or gas provided, fuel injection or
conventional carburetors, up to a maximum size of 350
cu. in." is judged to be reasonable for the model JE
6-2 (electric only).
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The applicability of the model JEW (electric and
water) to larger engines is unknown since the
applicant provided no information about this model.
(b) The device apparently does not function for some
ambient temperature conditions and types of driving.
The applicant informed EPA (Attachment C) that
"... a cold start at 72°F which limits the
effectiveness of the Jacona Fuel System since at
elevated temperatures (ambient temperatures above
about 80°F) the Jacona Fuel System will only
operate effectively if the vehicle is operating
at highway speeds. Because of the limitations on
the ability adequately to insulate the Jacona
Fuel System at the present time from the higher
temperature generated under the hood of the
vehicle, the Jacona Fuel System at such
temperatures is only effective at highway speeds."
The applicant was requested (paragraph 7, Attachment
E) to explain this temperature limitation in greater
detail. He was also asked to explain why it was
necessary to insulate a heating device from the
elevated temperatures under the hood. The applicant
did not respond to these questions.
The applicant stated (Attachment C) that the device
would ". . . operate effectively during the majority
of normal driving conditions to which it is subjected
However, the applicant did not define the
normal driving and ambient temperatures for which this
applied and did not respond to EPA's request
(paragraph 10, Attachment E) for this information.
(2) Installation - Instructions, Equipment and Skills Required;
The installation instructions given in Section 4b are a
generalized, nonspecific summary of how the device is to be
installed. These instructions are inadequate for actual
installation. EPA requested (paragraph 5, Attachment E)
more detailed instructions and a detailed list of parts
"Do you provide more detailed installation
instructions? If so, please provide them. Is there
an installation kit (hoses, fittings, wiring, etc.)
which accompanies the device? If so, please describe."
The applicant did not respond to this request.
The schematic provided shows a light which apparently is
used to indicate when the heater is operating. However,
there was no mention of it in either the installation or
operating instructions.
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It appears that installation of the device would require at
least moderate mechanical skills. The applicant provided
no instructions or warnings related to the potential
hazards likely to be encountered when working with fuel and
electrical systems.
(3) Operation;
The schematic of the Jacona Fuel System Model JE 6-2 shows
a system that could be installed entirely in a vehicle's
engine compartment. However, in Section 4b, the applicant
stated "The controls are mounted under the dashboard of the
vehicle". This indicates that the operation may not be
entirely automatic as stated in Section 4c.
Also, the description of the device and electrical
schematic indicate that the device operates as soon as the
ignition key is turned on. It appears that there is no
over-ride when starting a vehicle in sub-freezing
temperatures. Since, when ambient temperatures are low,
electrical starting loads are high and battery output is
low, the applicant was asked (paragraph 6, Attachment E) if
the device caused starting problems for a vehicle. The
applicant did not respond.
The device apparently has an indicator light. However, its
purpose, usage, and location were not given.
(4) Effects on Vehicle Safety;
Since the applicant failed to submit sufficient information
about the device and no sample was provided, EPA is unable
to judge the safety of the actual device. However,
assuming that good design, materials, and workmanship are
used in manufacturing the system, it appears likely the
device has the potential to be safe in normal vehicle usage
(model JE 6-2 only).
The safety of the model JEW is unknown since no information
was provided describing this model.
(5) Maintenance;
In section 4e, the applicant states that there is "no
maintenance required on the device". For model JE 6-2,
this statement is judged to be reasonable. However, the
added fuel fittings and electrical components would require
the normal periodic inspection accorded similar components
in the vehicle. The maintenance requirements of the model
JEW are unknown since no information was provided for this
model.
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d. Effects on Emissions and Fuel Economy;
(1) Unregulated Emissions:
The applicant submitted no test data and made no claims
regarding unregulated emissions. The statements and data
supplied in Section 5a relate to regulated emissions only.
However, since the device probably does not appreciably
modify the vehicle's emission control system or powertrain,
the device would not significantly affect a vehicle's
nonregulated emissions.
(2) Regulated Emissions and Fuel Economy;
The applicant did submit test data in accordance with the
Federal Test Procedure but not the Highway Fuel Economy
Test. These two test procedures are the primary ones
recognized by EPA for evaluation of fuel economy and
emissions for light duty vehicles.*
The limited test data submitted (Attachment B) consisted of
replicate FTP tests on one vehicle. The results were;
Federal Test Procedure
Baseline #1
Baseline #2
with Jacona #1
with Jacona #2
The fuel economy results were calculated from the emission
values using the carbon balance technique. Since these
data were for a 1978 Lincoln with a 400 CID engine, they
were presumed to be for the Jacona Fuel System Model JEW
(electric and water).
HC
.54 g/mi
.47
.47
.42
CO
5.49 g/mi
6.62
4.77
4.96
NOx
1.97 g/mi
1.80
1.67
1.53
F.E.
10.1 mi/gal
10.7
10.3
9.9
*The requirement for test data following these procedures is stated in
the policy documents that EPA sends to each potential applicant. EPA
requires duplicate test sequences before and after installation of the
device on a minimum of two vehicles. A test sequence consists of a cold
start FTP plus a HFET or, as a simplified alternative, a hot start LA-4
plus a HFET. Other data which have been collected in accordance with
other standardized procedures are acceptable as supplemental data in
EPA's preliminary evaluation of a device.
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10
This data did not indicate a fuel economy benefit for the
device and the applicant was so advised (paragraph 8,
Attachment E). The limited FTP data was inconclusive and
showed no fuel economy change due to the device. Although
the emission data did indicate an improvement in cold start
(FTP bag 1) emissions, the overall effect is unknown due to
the limited amount of test data provided.
The user testimonials given in Section 5b cannot be used to
evaluate the effectiveness of the Jacona Fuel System
because they are relatively uncontrolled tests. The
applicant also recognized the problems involved in
verifying the accuracy of these claims. He noted problems
in controlling the vehicle usage, discounted negative
results, and had to disregard an unrealistically large
improvement (Attachment C).
Prior to the submittal of the application, Mr. Gray and Mr.
Dodrill had claimed that the EPA test procedure was
inappropriate for the evaluation of their device due to the
unique characteristics of the device. However, their
application did not adequately address this issue and they
failed to respond to our subsequent request for information
that would allow EPA to investigate their contentions.
The applicant was advised of our requirements for test data
as outlined in the 511 application procedure. They were
reminded of our test requirements and the obligation to
publish the result of our evaluation. Although they were
given adequate time to obtain the required information, no
further data or information was provided. Therefore, this
evaluation was completed on the basis of the information
available.
e. Test Results of other Fuel Preheaters;
Previous EPA testing of a fuel preheater showed no fuel economy
benefits. Also, the two previous fuel preheaters evaluated
under the 511 process contained no valid data indicating either
a fuel economy or emissions benefit.
7. Conclusions
EPA fully considered all of the information submitted by the
applicant. The evaluation of the Jacona Fuel System device was
based on that information.
The information supplied by the applicant was insufficient to
adequately substantiate the claims for the device. The applicant
failed to respond to repeated written and telephone requests for
additional information.
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11
The applicant was advised of our requirements for test data as
outlined in the 511 application procedure. They were reminded of our
test requirements and the obligation to publish the result of our
evaluation. They were given adequate time to obtain the required
information, yet no further data or information was provided.
Therefore, our evaluation was completed on the basis of the
information available.
The limited test data supplied by the applicant was inconclusive.
These data showed no fuel economy improvement due to the device. The
emission data did show an improvement in cold start (FTP bag 1) on
one car emissions but the overall effects on emissions are unknown
due to the limited test data provided.
Previous EPA testing of a fuel preheater had shown no fuel economy
benefits. Applications for two other fuel preheaters provided no
valid data indicating any effects on either fuel economy or
emissions. Based on these results and on engineering judgment, it
was concluded that there is no technical basis to justify an EPA
confirmatory test program on the Jacona Fuel System or to support any
claims for a fuel economy improvement due to its use.
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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12
List of Attachments
Attachment A Drawings of Jacona Fuel System, Figures 1 through 5
(provided with 511 application).
Attachment B Letter of October 6, 1980 from A.P. Parts Company to
Jack Dodrill of Jacona Fuel Systems (provided with 511
application and as an attachment to July 27, 1981
letter to EPA).
Attachment C Letter of July 27, 1981 from John L. Gray to EPA (a
copy was also provided as an attachment to the 511
application).
Attachemnt D Letter of July 31, 1981 from EPA to John L. Gray in
response to his request to review the test data on the
Jacona Fuel System.
Attachment E Letter of October 20, 1981 from EPA to John L. Gray
acknowledging receipt of 511 application for the
Jacona Fuel System and requesting clarification and
additional information.
Attachment F Letter of January 13, 1982 from EPA to John L. Gray
reiterating previous requests for information.
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Attachment A
13
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Attachment B
16
EXHIBIT B
AP Parts Company
Engineering & Development Division
543 Matzinger Road
PO Box 1040
Toledo Ohio 43697
419259 3461
October 6, 1980
Mr. Jack Dodrill
Jacona Fuel Systems
(Heath Auto Parts)
142 Union Street
Newark, OH 43055
Dear Jack:
Enclosed are copies of the computer print-out sheets for exhaust emissions
tests on your 1978 Lincoln (Serial #F8Y89A816097F) the week of September 29,
1980. .After reviewing all the input data and the final test results, no
discrepancies could be found. Therefore, you can use these results to
evaluate your system's emission performance.
The results for the acceleration tests run on the vehicle are as follows:
(4-Test Average)
0-30 mph
0-50 mph
w/o Device
5.2 sec.
9.6 sec.
With Device
5.0 sec.
9.0 sec.
We hope everything was satisfactory during your stay in Toledo and if you
have any questions or wish to pursue further testing, please feel free to
write or call.
Sincerely,
AP PARTS COMPANY
Todd C. Tracey
Supervisor, Dynamics and
Emissions Test Labs
TCT:tmi
cc: M. W. Clegg
Enclosures
AP Paro is a Questor Company
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DATE
TIME
9-30-;
9115 ,
CONSTANT VOLUME. SAMPLER PARAMETERS
17
TOTAL. TIME
REVOLUTIONS
AVE,INLET PRESS,(IN
AVE,INLET TEMP,(DEC
CU,FT,/MIN,(STP>
CU* FT*/PHASE
CU,FT,/REV.(STP)
DILUTION FACTOR
HOT SOAK DURATION
H20)
F)
COLD TRANS,
506,1
9092,0
"^33, ^ 1
'124,33
273,48
2306.82
0,254
5.482
601.0 SECS.
COLD STABL.
863.3
15599.0
382.96
124.00
272.93
3951,87
0.253
6.909
HOT TRANS
507,0
9100.0
383.04
123,67
273.27
2305.50
0.253
5,570
*
CO(NDIR)
'QA 9
INSTRUMENT CODE NO,
C02CNDIR)
QA10
HC(FID)
QA 7
MASS RESULTS
COLD TRANS.
NO(CHEM)
QA 6
NOX(CHEM)
QA 6
HC(P)
CO
C02
NO
NOX.
NO*H
NOX*H
METER
. 43.0
69.0
20,0
28.0
38.5
'28,0
38,5
RANGE
2
5
1
' -. 3
3
3 '
3 -.
CONC
43,000
711,075
2.361%
28 , 000
33,500
23,000
33,500
BACKGND
7,200
11.925
0,088%
0,200
1,050
0,200
- f 1,050
CORRECTED*
111.340
701,326
22333,843
27.336
37,642
27,836
37,642
GMS,
4,194
53.34
2737,100-
2.295
4.703
2.368
4.353
GMS/MI
1.168
14.S5S
762.446
0.639
1.310
0.660
1 .352
' \v>
COLD.STABL.
HC(P)
CO
C02
NO
NOX
NO*H
NQX#H
METER
11,0
6.0
63.5
27,5
35.5
27.5
35 , 5
RANGE CONC
o
6
3
3
3
. 3
. 3
11,000
24-, 330
; i . 934%
27.500
35'. 500
27.500
35.500
BACKGND
6.600 .
7.663
6.101%
0.450
1,150
0.450
1.150
CORRECTED*
16,066
17/777
18472,539
27,115
34,516
27,115
34.516
GMS,
1,037
2. 32
3735.103
3.830
7.333
. 3.952
7.624
GMS/MI
0,265
' 0,592
968.095
0.930
1.390
1.011
1.950
METER .RANGE
HC(P)
CO
C02
NO
NOX
NO*H
NOX*H
77.0
77.0
55.0
69,0
55,0
69,0
6
3
3
3
3
3
CONC
' 25,500
372,397
2,361%
55.000
69,000
55.000
69,000
HOT TRANS,
BACKGND
8,000
7.663
0,088%
0,500
1,000
0.500
1.000
CORRECTED*
56.809
366,110
22886,385
54,590
63,180
54,590
68,180
GMS,
!735.S44
4.498
8.513
4.642
8.786
GMS/MI
0,599
7.. 795
766,303
1.260
2,335
1,300
2.461
-
CONCENTRATIONS=PPM-- HC CONCENTRATIONS^PPMC
CO C 0 2
GMS,/MI. 5,488 870.869
STOP
COMPOSITE W-iLUEb*^**:^K:^:-
HC NO NOX NO*H
0,542 0,986 1,905 1.017
\l* \k & \if vt* -i> -4* -^
s\; *\\ *f. jf. .-,-. ,-^v sp, ,-p
3
NOX*H
1.966
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;-.'.
DATE ' . 10-1-8
.-::-, . . TIME ' 9,*10 A.
2
.18
^ CONSTANT VOLUME SAMPLER PARAMETERS
"vi'
COLD TRANS, COLD STABL* 'HOT TRANS.
TOTAL TIME 505,8 . 868*2 505*3
::" REVOLUTIONS - 9090.0 . 15604.0 9084*0
AVE, INLET PRESS, (IN, H20) 330*56 330*56 380,56
AVE. INLET TEMP, (DEG, F) 124,33 124.33 .124.33
.:- CU.FT./MIN, (STP) 271,32 '271,32 271,32
. CU. FT* /PHASE (STP) 2236,32 3926*75 . 2283*53
..:,. CU.FT./REV. (STP) 0.252 0.252 0.251
:"'' DILUTION FACTOR . . 5*335 ' . 7.418 5*925
HOT SOAK DURATION 601.0 SECS. . .
'l~ INSTRUMENT CODE NO.
.,.,. CO(NDIR) C02(NDIR) , HC(FID) NO(CHEM) NOX(CHEM)
v-' QA 9 , QA10 QA 7 . QA 6 QA 6
' ..,.;,, . . MASS RESULTS
' COLD TRANS.
METER RANGE CQNC BACKGND CORRECTED* CMS. GMS/MI
.
HC(P)
CO
£ ':»>, C02
a ''-y . NO
NOX
I
,:-:, NO#H
NOX#H
^i ?* -
-v
.'.."-'
HC(P)
CO
"^ C02
NO
. . NOX
"^ " NO#H
NOX#H
^3
^ HC'iP)
CO
C02
-.\ NO
W ' NOX
NO#H
NOX^i'H
38.0
54.0
20,5
26,5
37,0
26.5
37.0
METER
9.5
10.0
59.0
24.5
33.0
24,5
33.0
METER
20.0
84.5
72,5
47.5
65,5
47,5
65.5
2
4
1
3
3
vJ
3 '
RANGE
2
6
3
3
3 '
3
3
RANGE
2
6
3
3
3
3
3
3 8". 000
877.304
2.412%
. 26.500
37*000
26.500
37.000
.CONC
9.500
46.206
1 . 799%
24*500
33,000
24.500
' 33.000
CONC
20.000
418,822
2,214%
47.500
65.500
47.500
65.500
5,750
24.330
0 . 038%
0.750
1.'700
' 0*750
1.700
COLD STABL
BACKGND
5*150
16*647
0*101%
1.050
1.800
1.050-
1.800
HOT TRANS.
BACKGND
5.900
. 9,728
0,088%
1,000
1.550
1.000
1,550
99,983
357.534 '
23407.227
25.891
35.619
25.891
35*619
* .
CORRECTED*
15. 133
31,803
17112*445
' 23.592
31,443
23.592
31.443
CORRECTED*
45.287
410.736
21404.707
46.669
64.212
46.669
64.212
3 . 733
64*64
2774,323
2,116
4,411
2.172
4.529
CMS*
0*970
4*12
3434*129
3,311
6,637
3,400
6,366
CMS,
1,689
30,92
2534,336
3,309
7.941
3,911
3,154
1,040
13,006
772.956
0.589
1.229
0.605
- 1.262
GMS/MI
. 0*249
1,057
894*057
0,850
1.716
0.872
1.762
GMS/MI
0.471
8.631
707,316
1.063
2.216
1,092
2,276
CONCENTRATIONS=PPM HC CONCENTRATIONS=PPMC
###:0m^!; WEIGH TED
CO C02
COMPOSITE
HC ' NO
I1 ALUES^M;:^^^^::;::;-/;' ^:-
NOX NO*H
CMS. /MI.
STOP
6.619
SIS. 101
0.473
0,354
1.752
0.877
NOX*H
1.799
-------
vyj i T~H OLA,'.* I
.j i-j j c
TIME
9J30
>
CONSTANT VOLUME SAMPLER PARAMETERS
TOTAL TIME
REVOLUTIONS-
AVE.INLET PRESS.(IN.
AVE.INLET TEMP,(DEC.
CU.FT./MIN,(STP)
CU,FT,/PHASE(STP)
CU,FT,/REV,(STP)
DILUTION FACTOR
HOT SOAK DURATION
H20)
F)
COLD TRANS,
506.1
.9036.0
379.83
123.67
271.15
2286,17
0,252
5.049
601*0 SECS,
INSTRUMENT CODE NO.
COLD STABL,
863,3
15590.0
379,SS
124,00
271,00
3920,15
0,251 .
7,006
19
HOT TRANS,
505.9'
9045.0
379.S3
124.00
271.00
2273.15
0.251
5. 332
CO(NDIR)
QA 9
C02(NrHR)
QA10
HC(FID)
QA 7
NO(CHEM)
QA 6
NOX(CHEM)
QA 6
MASS RESULTS
COLD TRANS.
HC(P)
CO
C02
NO
NOX
NO*H
NQX#H
23,5
64,5
34.5
34.5
51.5
34,5
51,5
NO
o
6
3
3
3
3
3
)E CONC
23,500
311,664
2.616%
34.500
51.500
34.500
51,500
BACKGND
3.700
7,663
0,101%
0,450
1,200
0,450
- 1.200
CORRECTED*
61.593
305.519
25344,381
34,139
50,533
34.139
50,533
CMS.
2,300
23,03
3004,323
2,789
6 ,25S
2,373
6.456
CMS/ MI
0.641
6.415
836 , SS:
0,777
1.743
0.802
1.798
COLD STABL,
HC(P)
CO
C02 "
NO
NOX
NO*H
NOX#H
METER
10.0
12,5
62,5
21,5
.26,5
21,5
26.5
RANGE
o
6
3
3
3
3
3
CONC
10,000
59.626
1 . 904%
21.500
26,500
21,500
26,500
BACKGND
3,750
5,748
0,123%
0,900
1,450
0,900
1,450
CORRECTED*
. 20,356
54,693
17942.072
20.728
25'. 257
20.728
25,257
QMS,
1,303
7.07
3646.397
2,904
5,362
2.996
5,532
GMS/MI
0.334
1,314
935.S25i
0,745
1,376
0.769
1.420
HOT TRANS,
HC(P)
CO
C02
NO
NOX
NO*H
23,0
83,0
73,5
49,0
58.5
49,0
NGE
o
6
3
3
3
3
3
: CQNC
23,000
445.730
2,246%
49.000
53.500
49,000
53,500
BACKGND
4,550
9,728
0,114%
0.800
1,200
0,800
1.200
CORRECTED*
57,690
437,670
21512,609
43,337
57,506
48,337
57,506
CMS,
2. 141
32.30
2535.535
3,927
7,030
4.051
7.304
QMS /MI
0.593
9.155
707.65
1.096
1 ,976
1 ,131
2,033
CONCENTRATIONS=PPMHC CONCENTRATIONS=FPMC
CMS, /MI.
###
STOP
CO
4.767
C02
853.
TED COMPOSITE
HC NO NOX NO£H
25 0.469 0.848 1.616 0.374
#**#***#**#*****#***#***###*#*####
NOX*K
1,667
-------
i i H
HATE
TIME
10-3-
9.*00
CONSTANT VOLUME SAMPLER PARAMETERS
20
TOTAL TIME
REVOLUTIONS
AVE.INLET PRESS,(IN,
AVE,INLET TEMP,(DEC.
CU.FT./MIN,(STP)
CU»FTt/PHASE(STP)
CU.FT./REV.(STP)
DILUTION FACTOR-
HOT. SOAK DURATION
CO(NDIR)
QA 9
COLD TRANS.
506.1
9093.0
H20) 380.24
F) 123.67
271,28
2237,79
0,252
4.992
601.0 SECS,
INSTRUMENT CODE NO,
COLD STABL,
363,5
15613.0
330,32
123,67
271.47
3926.40
0.251
6.846
C02(NDIR)
QA10
HC(FID)
QA 7
MASS RESULTS
NO(CHEM)
QA 6
HOT TRANS.
506.0
9089,0
380.41
124,00
271.50
2239.79
0,252
5,577
NOX(CHEM).
QA 6
COLD TRANS.
HC(P)
CO
C02
NO
NOX
NO*H
NOX*H
METER
24.5
56.0
85.5
32.5
49.0
32.5
49,0
RANGE
O
6
3
3
3
3
3
-CONC
24,500
267,303
2,650%
32,500
49; 000
32,500
49,000
BACKGND
4,000
7,663
0,083%
0.500
1.150
0.500
1,150
CORRECTED*
63 , 904
261.675
25794,719
32,100
48,080
32.100
43.030
CMS ,
2.387
19.74
3059.823
2.625
5.957
2.713
6.169
GMS/MI
0,665
5,498
852,34-
0.731
1,660
0,757
1.713
COLD STABL,
HC ( P )
CO
C02
NO
NOX -
NO*H
NOX*H
METER
9,5
11,5
64,0
19,5
24,5
19.5
24,5
RANGE
rt
6
3
3
3
3
3
CONC
9,500
54,334
1,949%
19.500
24.500
19,500
24,500
BACKGND
4,000
5,743
0,114%
0.850
1.350
0.850
1.350
CORRECTED*
18,253
49,426
18512,918
18,774
23", 347
18,774
23,347
GM3 ,
1.170
6,40
3768.933
2,635
. 4.965
2.728
5.141 .
GMS/MI
0.300
1.642
967.141
0.676
1,274
0.700
1.319
METER RANGE
CONC
HOT TRANS.
BACKGND
CORRECTED*
43.335
515/735
22612,988
40,467
49,638
40,467
49.638
CONCENTRATIONS--PPMHC CONCENTRATIONS=FPMC
*********#**********WEIGHTED COMPOSITE VALUES****/:.*****;
CO C02 HC NO NO)/ NGvH
QMS./MI. 4.956 833.991 0.417 0.755 1.475 0.7S2
* * * * * * * * * ************ * * * * * * * * * * # # *****£ * * * * * * * * # % # £ ;]< % >};; j;
STOP
HCCP)
CO '
C02
NO
NOX
NO*H
NOX*H
19
97
76
41
50
41
50
,0
,0
.5
.0
.5
.0
.5
?
6
' 3
3
3
3
3
19.000
523,719
2,344%
41,000
50,500
41,000
50.500
c~
U +
9.
0,
0,
1 ,
0,
1,
550
723
101%
650
050
650
050
o
CMS.
1.620
38.94.
634.740
3.312
6.156
3.429
6.374
GMS/MI
0.452
10.867
749,293
0.924
1,713
0.957
1.779
i C" O ~7
1 » J J/
#***#**&
-------
TIMOTHY J. BATTAGLIA
JACK A. BJERKE
J. RICHARD EMENS
LAWRENCE F. FEHELEY
JOHN L. GRAY
ALLEN L. HANDLAN
THOMAS W. HILL
DWIGHT I. HURD
CHARLES J. KEGLER
JOHN c. MCDONALD
WILLIAM W. MILLIGAN
PAUL D. RITTER. JR.
JOHN R. THOMAS
HTJTRD. KEGLER & RITTER
ATTORNEYS AT LAW
250 EAST BROAD STREET
COLUMBUS, OHIO 43215
ATTACHMENT C
21
TELEPHONE: {sit) 221-3527
CABLE: LAW ETHKR
TELEX: 24SS7I
July 27, 1981
STEPHEN E. CHAPPELEAR
EDWARD C. HERTENSTEIN
JOHN I. CADWALLADER
WILLIAM A. HOPPER. JR.
BEATRICE W. RAKAY
JOHN P. BRODY
NANCY A. DONALDSON
KEVIN L. SYKES
THOMAS E. DeBROSSE
RICHARD P. McHUGH
BARBARA L. SPENCER
BARBARA A. BELVILLE
HERMAN R. TINGLEY (IB87-I973)
JOSEPH M. MILLIOUS
JOHN B. TINGLEY
S. NOEL MELVIN
COUNSEL
Mr. Merrill W. Kor.th
Device Evaluation Coordinator
Emission Control Technology Division
United States Environmental Protection
Agency
Office of Air, Noise and Radiation
2565 Plymouth Road
Ann Arbor, Michigan 48105
Dear Mr. Kor.th:
This firm represents Mr. Jack R. DodrilJL and he has
asked me to write to you in accordance with his recent dis-
cussion with you and your letter of July 23, 1981, so that
you may be supplied with certain data which has been developed
in the testing and. evaluation of the Jacona Fuel System.
As was mentioned in his discussion with you by Mr. Dodrill,
the standard EPA mileage test which is described in your letter
of July 23, 1981, involves a cold start at 72°F which limits the
effectiveness of the Jacona Fuel System since at elevated
temperatures (ambient temperatures above about 80°F) the Jacona
Fuel System will only operate effectively if the vehicle is
operating at highway speeds. Because of the limitations on
the ability adequately to insulate the Jacona Fuel System at
the present time from the higher temperature generated under
the hood of the vehicle, the Jacona F.uel System at such tempera-
tures is only effective at highway speeds.
On the other hand, for normal driving with a start up at
ambient temperatures, there is an opportunity for the Jacona
Fuel System to operate effectively during the majority of the
normal driving conditions to which it is subjected and, as a
consequence, the test data that has been developed to show the
significant improvement in mileage obtained with the Jacona Fuel
System has been developed in real life driving conditions by a
variety of different individuals located in thr.ee different states,
which includes start up, city driving, and highway driving under
ambient temperature conditions in late spring and early summer.
-------
EMENS. HURJD, KJEGLER 8e RITTER
22
Mr. Merrill W. Korth
July 27, 1981
Page two
Enclosed, therefore, are the following:
1. Exhibit A--Affidavits of eight (8) individuals
in Pennsylvania who utilized the device on their personal
vehicles under their normal driving conditions.
2. Exhibit B--Affidavits of six (6) individuals who
utilized the Jacona Fuel System on their personal and, in some
cases, state-owned vehicles, under normal driving conditions for
varying periods of time.
.3. Exhibit CAffidavits of four (.4) individuals utilizing
state-owned vehicles which achieved negative results.
4. Exhibit DA communication dated October 6, 1980
and enclosures from Mr. Todd C. Tracey, Supervisor, Dynamics
and Emissions Test Labs of AP Parts Company.
5. Exhibit EA listing dated July 14, 1981 of .the
independent laboratories recognized by EPA as capable of
performing emission tests on motor vehicles.
Set forth below is a summarization of the .percentage
changes in mileage accomplished, by use of the Jacona Fuel
System based on the information contained in the affidavits
of Exhibits A, B, and C.
EXHIBIT: A ' Percentage Increase Average %
35
20
27
69
44
28
21
31 32
EXHIBIT B 8
22
4
31
133
10 35
-------
, HCTRD, KEGLER St RITTER
23
Mr. Merrill W. Korth
July 27, 1981
Page three
EXHIBIT C Per centage D ecr e'a se Average %
-20
-22
-11
-19 . -18
The average of the results in Exhibits A and B is 33 percent,
so it may be concluded from these data that there has been an
overall average increase of 33 percent, if the negative results
are completely discounted.
Of the negative results, three of the vehicles were AMC
Concords and one was a Plymouth Fury.. The data for these vehicles
without the Jacona Fuel System was generated while the vehicles
were primarily engaged in field work which involved considerable
high mileage highway driving. After the Jacona Fuel System was
installed on these vehicles they were used primarily for city
driving for the motor pool with different drivers. This can be
confirmed by Mr. James L. Nichols, head of Ohio's Department of
Energy.
However, even if the negative results are averaged in with
all of the positive results, the overall average increase from
all three exhibits is 22 percent.
A more logical approach would be to throw out the negative
results and the unusually large 133 percent result in Exhibit B
and this produces an overall improvement in mileage of 26 percent.
It should be emphasized that these results were obtained
while the vehicles were being used by the individuals in the
normal way that he or she would drive: driving to work, driving
out on the highway, stopping, starting, and in some cases on
long trips, and thus is perhaps a fair representation of the kind
of mileage increase that would be obtained with this device under
normal rather than extreme test conditions.
Referring to Exhibit D, you will note that the emission
test results for both hydrocarbons and carbon monoxide as
tested by AP Parts Company, which is one of the independent
laboratories recognized by the EPA as capable of performing
emission tests on motor vehicles was well within tolerances so
that it can be concluded that the addition of the Jacona Fuel
-------
EMEN'S, KURD, KEG.L.ER & ROTTER
24
Mr. Merrill W. Korth
July 27, 1981
Page four
Systems to a motor vehicle does not result in any increase in
objectionable emissions.
Exhibit E is a listing of independent laboratories
recognized by EPA as capable of performing emission tests on
motor vehicles.
In view of the data submitted, it is believed that it would
be in the public interest for your office to recognize the value
of the Jacona Fuel System and its attendant improvement in
gasoline mileage.
John L. Gray
JLG/kk
Encs.
-------
ATTACHMENT D 25
July 31, 1981
Mr. John L. Gray
Emens, Kurd, Kegler, and Ritter
250 East Broad Street
Columbus, OH 43215
Dear Mr. Gray:
This is in response to your letter dated July 27, 1981, dealing with the
Jacona Fuel System, invented by Mr. Jack R. Dodrill. 1 have reviewed the
information that you attached.
The last paragraph of your letter suggests that EPA "recognize the value
of the Jacona Fuel System and its attendant improvement in gasoline mile-
age". The mechanism for doing such a thing is the EPA device evaluation
program under Section 511 of the Motor Vehicle Information and Cost
Savings Act. My letter to Mr. Dodrill on July 23, 1981 outlined the
policy and procedures to be followed in undertaking such a program and
enclosed an application format. If Mr. Dodrill is interested in an EPA
evaluation of the Jacona Fuel System, he should prepare an application in
accordance with the guidelines of the application format. EPA will per-
form a preliminary evaluation of all the data and information submitted
nd advise Mr. Dodrill if EPA testing of his device is justified, or if
more data is needed from one of the independent laboratories recognized
by EPA. During that preliminary analysis, we will address Mr. Dodrill's
contention that the EPA test procedure is inadequate due to the unique
characteristic of his device.
I am looking forward to receiving Mr. Dodrill's application. If there
are questions concerning these comments, I can be reached on (313)
669-4299.
Sincerely,
Merrill W. Korth, Device Evaluation Coordinator
Test and Evaluation Branch
-------
ATTACHMENT E 26
October 20, 1981
Mr. John L. Gray
Emens, Rural, Kegler & Retter
250 East Broad Street
Columbus, OH 43215
Dear Mr. Gray:
We received your letter of October 6, 1981 in which you applied for an
EPA evaluation of the "Jacona Fuel Systems", a fuel economy retrofit de-
vice. Our Engineering Evaluation Group has made a preliminary review of
your application and has identified several areas that require additional
clarification prior to further processing of your application. Our com-
ments below address the individual sections of your application.
1. Section No. 3 - Please provide a copy of the patent application.
2. Section No. 8(B) of the application states the device heats fuel
"utilizing waste heat from the engine, to a critical tempera-
ture." However, the drawing of the device, its description, or
the installation instructions do not include any use of "waste
heat". The fuel appears to be heated by electrical heating
elements. Please clarify what is meant by waste heat and how it
is used? What is the critical temperatures and why is it criti-
cal?
3. Section No. 8(B) states "Objectionable emissions have been kept
below EPA maximums." Exactly what is meant by this statement
(were emissions lowered, unchanged or raised but not over statu-
tory limits)? Were these measured by the Federal Test Procedure
(FTP)? Are there any emission test results besides those pro-
vided with the application?
4. Section No. 8(C), description of the device. What is the tem-
perature set point of the thermostatic control? Please describe
the control in greater detail. What is the heating capacity of
the electric heating element? How much is the temperature of
the fuel raised? Please provide representative fuel inlet and
outlet temperatures for representative ambient conditions while
the vehicle is operating.
5. Section No. 10 gives a simplified overview of the device instal-
lation procedures. Do you provide more detailed installation
instructions? If so, please provide them. Is there an instal-
lation kit (hoses, fittings, wiring, etc.) which accompanies the
device? If so, please describe.
-------
27
6. Section No. 11 states "The operation of the device is entirely
automatic and there are no instructions needed for its use."
Are there any possible starting problems due to the electrical
requirements of the heating element, especially when starting
the vehicle at sub-freezing temperatures?
7. Section No. 14 states "The unit has a temperature sensor at the
carburetor and at the unit ..." This is the only mention of a
carburetor temperature sensor, it does not appear to be de-
scribed elsewhere. Please provide a detailed description of it,
its function, and mode of operation.
8. Section No. 15 provides the duplicate FTP test results on one
vehicle only. As identified in your application, the results
are:
Federal Test Procedure
H£ C0_ NOx FE_
Baseline #1 .54 g/mi 5.49 g/mi 1.97 g/mi 10.1 mi/gal
Baseline #2 .47 6.62 1.90 10.7
with Jacona //I .47 4.77 1.67 10.3
with Jacona #2 .42 4.96 1.53 9.9
The fuel economy results were calculated from the emission values using
the carbon balance technique.
As you are aware from our previous meeting and correspondence,
EPA requires duplicate tests (FTP or hot start FTP plus HFET)
before and after device installation on a minimum of two vehi-
cles. Also, the data you submitted do not indicate a fuel econ-
omy improvement due to the device. Before we will undertake
testing at our laboratory, we must have test results which show
the potential for benefit. The guidelines for this improvement
were stated in a previous letter to you.
9. Exhibit C states" ... a cold start at 72°F which limits the
effectiveness of the Jacona Fuel System since at elevated tem-
peratures (ambient temperatures about 80°F), the Jacona Fuel
System will only operate effectively if the vehicle is operating
at highway speeds." Please elaborate on this in greater
detail. Also, why is it necessary to insulate the device from
higher underhood temperatures?
10. Exhibit C states "... for normal driving with a start up at
ambient temperatures . . ." What is normal driving? What
ambient temperatures/temperature range are these ambient temper-
atures?
Due to the need for clarification of details of the Jacona Fuel System,
we are presently unable to address Mr. Dodrill's contention that the EPA
test procedure is inadequate due to the unique characteristics of his
device. On the other hand, we are prepared to assist you in developing a
-------
28
test plan which will allow you do conduct appropriate testing at an inde-
pendent laboratory.
Submittal of the information requested above will be necessary to further
process your evaluation. In order for us to process Section 511 applica-
tions efficiently, we have established a schedule for each. I ask that
you respond to this letter by November 6. If you have any questions or
require further information, please contact me.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
-------
Attachment F
;"
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 29
ANN ARBOR. MICHIGAN 48105
Tanuarv 13 1982 OFFICE OF
Januarys, x?oz T MA
AIR AND WASTE MANAGEMENT
Mr. John L. Gray
Emens, Hurel, Kegler, and Ritter
250 East Broad Street
Columbus, OH 43215
Dear Mr. Gray:
In a letter dated October 20, I asked for additional information on your
application for an EPA evaluation of the "JACONA FUEL SYSTEM". Your
response was due on November 6, but we have not yet received it. Several
subsequent phone calls have also failed to produce a satisfactory
response. As I noted in my letter, we still require this information
prior to further processing of your application. Please provide the
requested information immediately.
The Environmental Protection Agency is obligated to expeditously process
your application. However, the information you previously submitted does
not adequately describe your device and includes only limited test data
following the proper EPA test procedures. Therefore, we presently have
insufficient technical information to adequately evaluate your claims for
the device.
Unless I receive a satisfactory response by February 9, 1982, Ve will
complete the evaluation of-^ybur device using the information that is
currently available.
Again, I welcome the opportunity to answer your questions and to work
with you in designing a test plan to test your device at an independent
laboratory. However, I will need the requested information to efficently
assist you.
Please contact me immediately if you do not understand this course of
action.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
cc: Jack R. Dodrill
1510 Londondale Parkway
Newark, OH, 43055
------- |