EPA-AA-TEB-511-83-4
EPA Evaluation of the Atomized Vapor Injector Device Under
       Section 511 of the Motor Vehicle Information
                   and Cost Savings Act
                            by
                      John  C.  Shelton
                       February  1983
                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 Atomized Vapor  Injector  Device  Under  Section 511 of
the Motor Vehicle Information and Cost Savings Act

The  Motor  Vehicle  Information and  Cost  Savings  Act  requires that  EPA
evaluate  fuel  economy  retrofit  devices  and  publish a  summary of  each
evaluation in the Federal Register.

EPA  evaluations  are  originated upon  the  application  of  any  manufacturer
of a  retrofit  device,  upon the request  of the Federal  Trade Commission,
or upon the motion of  the EPA Administrator.  These  studies  are designed
to determine  whether the  retrofit device increases  fuel economy  and  to
determine whether the representations made with respect  to  the device are
accurate.  The  results  of such  studies are  set  forth in  a  series  of
reports, of which this is one.

The evaluation of the "Atomized Vapor Injector" device  was  conducted  upon
the application of the inventor.   This  device is  a vapor air bleed which
bubbles air through a 50/50 mixture  of  water and alcohol.  This vapor is
said  to cause  more  efficient  combustion  by "atomizing"   the  gasoline
droplets and lowering the  engine temperature.  This is  claimed to  improve
fuel economy and reduce emissions.

1.  Title:

    Application for  Evaluation of  Atomized  Vapor Injector Under  Section
    511 of the Motor Vehicle Information and Cost  Savings Act

THE  INFORMATION  CONTAINED IN SECTIONS TWO  THROUGH FIVE WHICH  FOLLOW WAS
SUPPLIED BY THE APPLICANT.

2.  Identification Information:

    a.   Marketing Identification of the Product:

         Atomized Vapor Injector

    b.   Inventor and Patent Protection:

         (1)   Inventor

              Lewis  J. Schneller
              2019 West Sussex Avenue
              Missoula,  MT  59801

         (2)   Patent

              "N/A"  [A copy of the  patent was not  submitted.]

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    c.   Applicant;

         (1)  Name and address

              Lewis J. Schneller
              2019 West Sussex Avenue
              Missoula, MT  59801
              (406) 728-2752 or
              (406) 721-1330, ext. 266

         (2)  Principals

              Lewis J. Schneller
              2019 West Sussex Avenue
              Missoula, HT  59801

         (3)  Lewis  J.  Schneller  is  authorized  to  represent  Atomized
              Vapor Injector in communication with EPA.

    d.   Manufacturer of the Product:

         (1)  Based   on   the   information   in   the   application,   the
              manufacturer of the product has not yet been determined.

3.  Description of Product:

    a.   Purpose:

         "With  the ever-increasing  cost  of  gasoline,  combined with the
         potential   international   oil   supply   system   bordering   on
         international crisis  and the subsequent  possible  gas  rationing,
         the need  for a gas  saver  like  a water/alcohol  injector  appears
         to be  a matter, of  being at the right  place  at the right  time;
         i.e.,  the  time   is  ripel    The  challenge  exists  to  develop  a
         readily available and  inexpensive  water/alcohol  injection system
         to increase  not  only  fuel  conservation,  but  to  increase engine
         operation efficiency  as well.   If  for no  other reason,   it may
         become  readily  apparent  that  water/alcohol  injection  systems
         should  be a mandatory  requirement  on all  gas-powered  vehicles,
         if only to  prevent unnecessary  engine  repairs  due  to  excessive
         carbon accumulation.

         "Presently,  there are  a  few varieties of  water/alcohol  injectors
         on  the market  today,  ranging  in  price  from  $29.95  to  nearly
         $400.00  per  unit.    Some   of  the  proposed  advantages  of  the
         Atomized Vapor Injector are the  following:

         "(1) Since  the  container  for AVI  is  accomplished  by  recycling
              used hospital  I.V.  bottles,  not  only  does  this  process
              contribute   to   our   national   philosophy   of    energy

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          conservation  through  recycling,  but   the   I.V.   hospital
          bottle seems  to be an  ideal container  for  the  successful
          operation of  a  water/alcohol injector.   The many  personal
          testimonials and independent testing results  by the  City  of
          Missoula's  Street  Maintenance  Department  seem  to  support
          this statement.

     "(2) Since  the AVI  unit  is  the  only  glass container  on  the
          market today, it  has  an inherent  advantage over all  other
          units  made  of  opaque  plastic.    AVI  can  be   visually
          monitored during operation, thereby eliminating any  need  to
          install  an  expensive  warning   light  system  to  warn  the
          vehicle  operator  when  the water/alcohol solution  becomes
          too low for satisfactory operation.  Because  AVI is  a  glass
          container with graduated milliliter marketings,  the  vehicle
          operator  can  very  easily  monitor  the   desired  consumption
          rate (approximately 100 ml of water/alcohol  solution per  20
          gallons  of  gasoline  consumed)  by  simply  adjusting  the
          needle  valve  setting  to   correspond  to  the  recommended
          consumption rate.   No  other water/alcohol  injection system
          has these advantages.

     "(3) The glass hospital  I.V. bottle  is  designed  to significantly
          exceed the maximum  safety  requirements for  safe and  durable
          operation.  In  the event  of  defect,  a  used hospital  I.V.
          bottle is easily replaceable and inexpensive.

     "(4) The  simplistic  design and operation of AVI  water/alcohol
          injectors easily lends  itself  to  satisfactory assembly  and
          distribution  programs by  handicapped  people.   Successful
          experimentation  with  this   concept   has   already   been
          demonstrated with Missoula's Opportunity Workshop  employing
          disabled adults.

     "(5) Atomized  Vapor  Injectors  lends   itself  to  a  variety  of
          creative  marketing  programs,   especially  when   viewed  in
          light   of  our   current   local  and   national   economic
          predicament.  The  potential  exists for  creating  employment
          and  services  that  may  serve   as  a  shining  example  of
          reflecting  America's   original  philosophy  of   fostering
          independence  through  the  spirit  of  innovation  and  novel
          creativity  for  self-determination.   (Please find  proposed
          budget  analysis and  marketing  format  enclosed  for   your
          convenience.)" [This document is found in Attachment  A].

b.   Theory of Operation:

     "Atomized  Vapor  Injector  is a hydroautomization  system  which
     adds a  50/50  water/alcohol vapor to  an engine's  intake  system.
     A water/alcohol  vapor  injector  produces a  more efficient  fuel

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burn  by  atomizing   Che  gasoline   droplets   and  lowering  the
engine's  temperature.  This  process will  not  only  improve  an
engine's overall performance and  increase gas  mileage  rates,  but
will  also  increase  the  engine's   life   span  by  eliminating
excessive carbon deposits.  This  water/alcohol injection system,
AVI, uses engine vacuum pressure  to  pull  outside air  through the
glass I.V.  hospital  reservoir  containing  a 50/50  water/alcohol
solution  which is  attached  to  the  car  under  the hood.   This
causes  the  solution  of water  and alcohol  to  bubble and  splash
within  the  vacuum chamber forming  a mist  of  water and  alcohol
droplets  and  vapor  in  the upper part of  the  glass  reservoir.
This mist is then drawn by the  vacuum pressure through  a plastic
hose which is  then connected to any  intake  manifold suction hose
(the   positive   crankcase   valve   is   the    most    desirable
connection).  This connection is  made by  very  easily  cutting  the
rubber  vacuum  hose  with  a sharp knife and  then  inserting  the
plastic  "T".    The   plastic  needle   valve  can   then  be  easily
adjusted  to allow just  the right amount  of water/alcohol  vapor
to pass into the combustion chamber  (best  results are  derived by
adjusting  consumption  rate  to   allow  100  milliliters  per  20
gallons of gasoline)."

Construction and Operation;

"The  Atomized  Vapor  Injector  consists  of a  recycled  hospital
I.V. bottle secured  in  a  plastic holder, which  is  then attached
under the hood  to the inside  of  the  engine compartment.   A high
quality rubber  stopper  with two  holes  is placed in  the opening
of the glass I.V. bottle.   An 8 inch plastic tube with  a plastic
air-stone  (aerator)  on  one end of  the tube is  attached  to  the
rubber stopper, with  the plastic  air-stone  (aerator)  placed near
the  bottom  of  the  bottle.   Now   a plastic  needle  valve  is
attached  in the  remaining  opening in the rubber  stopper,  with a
high quality four foot plastic tube  attached to  the other  end of
the  plastic  needle  valve.   All  that remains   is to  insert  the
black plastic  "T"  into the rubber  vacuum hose.  Make  sure that
the  four  foot plastic  tube  between  the  AVI   unit  itself  is
completely straight, with no up or down bends  in it, and that it
is not in contact with any super-hot  surfaces,  as this  may cause
the  plastic  tube to collapse.    The  AVI  unit  itself   should  be
installed  lower than the  "T"  connection,  as  this  facilitates
vapor rising  upward.  It  is  also advisable to  operate the  AVI
unit on the top half  of the reservoir,  as  the  vaporizing process
diminishes on  the  bottom half of the bottle.    This  establishes
another need to have  a glass container  for  visual monitoring,  as
the  glass  container  should be  refilled when  it is  half-empty.
The  unit's  effectiveness  diminishes  on  the bottom half of  the
bottle."

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    d.   Specific Claims for the Product;

         "The introduction of AVI's water/alcohol  vapor  into  the  fuel air
         mixture  through a  vacuum line leading  to  an engine's  intake
         system  produces a  cooling  effect  that   increases  the  mixture
         density,  extending  the  burning rate,  and improving  combustion
         efficiency.   This  process   helps  to   eliminate   engine   ping
         (predetonation) and  dieseling  (after  running of motor).   Since
         steam is  a  good cleaning process,  this helps to dissolve carbon
         deposits  on  the  spark  plugs and  cylinder   walls   of  older
         vehicles,  and  prevents  carbon   build-up  in   newer   vehicles.
         Engine horsepower and  octane can be increased  because  less  fuel
         is  needed to  produce  the same amount of  energy when using  a
         water/alcohol injector."

    e.   Cost And Marketing Information:

         "Please  see  attached  marketing and  sales schedule  [Attachment
         A].   Mr.  Larry Wilkinson  of  Edwin  K.  Williams  and  Company,
         Missoula, Montana, had indicated a willingness  to undertake  this
         aspect of AVI."  The listed cost of the unit is  $29.95  each.

4.  Product   Applicability,    Installation,    Operation,    Safety    and
    Maintenance;

    a.   Applicability;

         "Atomized Vapor Injector is  designed  to   be  implemented on  all
         gas-powered vehicles.  The only known restriction today  is  that
         certain vehicles with  little or no extra available  space  in the
         engine  compartment  cannot   accomodate   insertion   of   a  quart
         container  the   size of  AVI.    AVI  is  presently considering  the
         feasibility of  manufacturing  units smaller  than its  present  size
         with 1/2  quart  containers  in order to accommodate vehicles  with
         less available engine space.

         "It is  not  known whether operation  of a  water/alcohol  injector
         is  adversely  affected by  adverse  weather  conditions,   types  of
         driving or topographical differences."

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

         "Please see attached installation instructions." [Attachment  A]

    c.   Operation;

         "Please see attached operation instructions."  [Attachment A]

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    d.   Effects on Vehicle Safety;

         "It is not known whether  the use  of  this  product  could result in
         any unsafe  conditions  for the  vehicle  occupants, or  persons or
         property in close proximity."

    e.   Maintenance;

         "There  is  no maintenance schedule  or  procedure  for  successful
         operation of AVI."

5.  Effects on Emissions and Fuel Economy;

    a.   Unregulated Emissions;

         "Information unavailable."

    b.   Regulated Emissions and Fuel Economy;

         "Please see  independent  testing results of the City  of  Missoula
         Street and Maintenance Department."  [Attachment A]

THE FOLLOWING SECTIONS CONTAINS EPA'S ANALYSIS OF THIS DEVICE.

6.  Analysis

    a.   Description of Device;

         The device  is  basically  a controlled air  bleed device where the
         air  is bubbled  through  a  mixture  of  alcohol  and water.   The
         resulting vapor  is  introduced  into  the intake manifold  through
         vacuum line between the PCV valve and the carburetor.

    b.   Applicability Installation,  Operation, Safety and Maintenance;

         (1)  Applicability;

              The applicability of the device "to  be  implemented on all
              gas-powered vehicles" is judged  valid  for all gasoline fuel
              vehicles presently being produced.

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

              The  installation  instructions  are  included in  Attachment
              A.  They appear to be complete  and only  average  ability and
              simple tools are required for the installation.

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(3)  Device Operation;

     No specific  instructions  were provided  for operation of  a
     vehicle  with  the  device,  and  none  were  judged  to   be
     required.    However,   we   have   some  concern   for   the
     recommendations  made  for  the  fluid.   The  applicant  states
     you can  use  any alcohol additive  like gasohol or  gas  line
     antifreeze.   Gasohol  normally contains  90%  gasoline  and
     could not be used.  Gas line  anti-freeze  is almost  entirely
     alcohol and would have to be  mixed with  water  to  obtain  the
     50/50 mixture.

(4)  Effects on Vehicle Safety;

     The applicant  states  "It  is  not known  whether the use  of
     this product could  result  in any unsafe conditions for  the
     vehicle   occupants   or  persons   or   property  in   close
     proximity".  The addition  of  the  device probably would  not
     affect the vehicle safety.

(5)  Maintenance;

     The applicant states that  "There is no maintenance  schedule
     or procedure for successful operation  of  the Atomized  Vapor
     Injector".   He  states  "The  glass   container  should   be
     refilled  when  half  empty".   This appears  to  be  the only
     maintenance required.

     Since the device does  not  contain an  inlet air filter,  the
     mixture would be exposed  to contamination from oil and  gas
     fumes, dirt,  road salt and bugs.

Effects on Emissions and Fuel Economy;

(1)  Unregulated Emissions;

     The   applicant   did   not   furnish    any   information   on
     unregulated  emissions.  The   small  flow  of  alcohol/water
     mixture  probably  would   have  little  or  no   effect   on
     unregulated emissions.

(2)  Regulated Emissions and Fuel Economy;

     The applicant did  not  submit  test data  in accordance with
     the Federal  Test  Procedure  and  the   Highway  Fuel Economy
     Test.    These  two   test  procedures  are  the  primary ones

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              recognized  by  EPA  for  evaluation  of  fuel  economy  and
              emissions for light duty vehicles.*   Although the applicant
              did  submit  data  from on-the-road  tests  the results  were
              inconclusive  because  the  program   was  not  sufficiently
              controlled nor  extensive  enough to adequately  quantify the
              worth  of  the  device.   Moreover,   this  testing  did  not
              include any measurements of exhaust emissions.

              A  few air-bleed  devices   tested  by  EPA  have  shown  small
              improvements  in emissions  or  fuel economy  by leaning out
              the  rich  air/fuel  mixtures of  vehicles  which were produced
              prior to  emission  standards.   Without even using  a device,
              however,  these  results could  be  approximated by  adjusting
              the  idle  mixture  screws.    With  the  leaner calibrations  of
              recent  years,  even   these  few  devices  would   not   show
              improvements and may  cause driveability problems.   Most  of
              the  current models  now employ feedback  carburetor systems.
              As a result,  any changes  attributable  to  the device  would
              automatically be negated by the controls.

              Several other devices  tested by EPA have introduced liquids
              or  vapors  into  the  combustion  chamber.   In  sufficient
              quantities,  water  injection  can  extend  the   detonation
              limits  of  the  engine.    This  allows   modifications  or
              adjustments  which   can  improve  fuel  economy   (although
              usually at the  expense of  emission levels).   In  the case  of
              the  Atomized  Vapor  Injector,  however, the amount  of liquid
              introduced  is  relatively  small.   The device is  stated  to
              use  100 ml of liquid per 20 gallon tank  of gasoline.  For a
              vehicle achieving  20 miles per  gallon,  this rate  is  only
              0.25  ml  of  liquid per  mile.   At  this  level,   the  energy
              content of  the alcohol  would have  no  discernible  effect.
              The  amount  of  water  is  also  insignificant,   especially
              considering that the  applicant does  not specify  any engine
              parameter adjustments.
*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
         (3)  EPA Testing;

              Because the  test data  submitted with  the application  was
              inconclusive,   we  asked   that   the   applicant   conduct
              appropriate  testing  at  an   independent   laboratory   (see
              Attachment B).  A test  plan was submitted by  the applicant
              and approved by  EPA (see Attachment C).  Our  evaluation of
              this test plan was  conducted and  transmitted  in  a letter of
              September 10, 1982  (see Attachment D).  A  second letter  was
              sent November 2,  1982  also  requesting additional  test  data
              (see  Attachment  E).   At  a   later  time,   the  applicant
              contacted EPA by  telephone  and stated he would  not  be  able
              to  supply   any   additional  test  data  because  of   cost
              considerations.   Therefore, lacking  any data  or reasonable
              theories  to substantiate  the  applicant's  claims,  no  EPA
              testing of the Atomized Vapor Injector was performed.

7.  Conclusion

    The  evaluation  of  the  Atomized  Vapor  Injector was   based  on  the
    information  submitted  by  the applicant,  EPA's engineering  judgment,
    and the results of EPA's  evaluation of  similar  products.  The  overall
    conclusion  from  the  EPA  evaluation  is  that  there  is  no  reason  to
    expect that  the device will significantly improve  the  fuel economy or
    performance  of  a vehicle.  Any  changes  in  emission levels would  be
    due solely to the air bleed aspect of  the device.

FOR  FURTHER  INFORMATION  CONTACT:   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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                                                                             11
                           List of Attachments

Attachment A       Letter  of  June 24,  1982  from  Lewis  J.  Schneller  to
                   EPA.  This document contains the original application.

Attachment B       Letter of July 16, 1982  from EPA  to  Lewis  J.  Schneller
                   evaluating his original application.

Attachment C       Letter of September 2, 1982 from  Lewis  J.  Schneller  to
                   EPA.  This  document  includes  a  proposal  for  testing
                   the device from Olson Engineering, Inc.

Attachment D       Letter  of  September  10,  1982  from  EPA to  Lewis  J.
                   Schneller evaluating the  test  plan.

Attachment E       Letter  of  November   2,   1982  from  EPA  to  Lewis  J.
                   Schneller.

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                                                     Attachment A

                                                              12
                              Atomized Vapor Inlectors
                              Federal I.D. #81-0393244
                              2019 West Sussex Avenue
                              Missoula, Montana 59801
                              June 24, 1982
United States Environmental Protection Agency
Motor Vehicle  Emission Laboratory
Emission Control Technology Division
2565 Plymouth Road
Ann Arbor,- Michigan 48105

Attention:  Mr. Merrill W. Korth

Dear Mr. Korth:

I am writing this letter to formally submit my application
to you in order to obtain EPA test requirements for an
approved EPA evaluation of ray water/alcohol injector called
Atomized Vapor Injectors  (AVI).

On June 11, 1982, I received a letter from the Honorable Pat
Williams, Western Montana Congressman, detailing efforts on
his behalf to obtain EPA test requirements and application
format for my water/alcohol injector, AVI.  Congressman
Williams also included a letter with pertinent information
submitted to Ms. Diane Hicks, Congressional Liasion Office
of the Environmental Protection Agency, 401 "M" Street S.W.,
Washington, D.C., from you.  I have included a copy of both
of these letters for your convenience.

Also, please be advised that I have already received a  will-
ingness from the Private Industries Council of Montana, Inc.,
517 Power Block Building, Helena, Montana, 59624, to under-
take .the funding requirements necessary to obtain independent
testing data prior to marketing Atomized Vapor Injectors.

In your letter to Ms. Hicks, you stated that you could assist
in the development of a satisfactory test plan.  This service
would be most desirable,  as I am sure the Private Industries
Council, of Montana would positively respond to an EPA approved
testing format for my water/alcohol injector.  Furthermore,
I would greatly appreciate your suggestions as to which
independent testing laboratory would be most desirable  to
conduct the testing of my product.

Also, please be advised that I have included an independent
testing format provided by the City of Missoula Street
Maintenance Department for your convenience.

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                                                             13
United States Environmental Protection Agency
Mr. Merrill W. Korth
June 24, 1982
Page Two
Thank you for any consideration you may give to my proposal,
and please do not hesitate to contact me for any  further
assistance.  I hope to hear from you soon.
    :erely,
 .ewis JJ Schneller
 1406)728-^752, or
 ;406)721-1330/266(message phone)

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                                                                        14
PAT WILLIAMS                         ^ ,™, „
   MONTANA                            ^^sJjg.Tt^T                      EDUCATION AND LABOR
       imocr                           ^^ggpr                       ILXM«HTARY, SCCONDI-TV AMD
                                             _
                   CONGRESS OP THE UNITED STATES
                             HOUSE OF REPRESENTATIVES                   INTERIOR
      o.c. sals                    WASHINGTON, D.C. 2051S
     (202)22*4211                                                       MMV AND
      Mr. Lewis J.  Schneller
      2019 West Sussex Avenue
      Missoula, Montana  59801

      Dear Lewie:

           I've finally been able to obtain EPA's test requirements
      for your water/alcohol injectors.   I'm enclosing the  entire
      packet of information which EPA made  available to me.

          .You will notice that the EPA  will also evaluate  your  device
      upon submission of an application  and the results of  your  inde-
      pendent tests.

           I hope  this covers what you'll need to have the  necessary
      tests run in order to begin marketing.  Please let me know if
      I can be of  further assistance.

           Best regards.

                                          Sincerely,
                                          Pat Williams

      Enclosures

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        \    UNITED STATES ENVIRONMENTAL PROTECTION  AGENCY
        3                                                                        15
\ ^V+.f                    ANN ARBOR. MICHIGAN 48105
    May 10,  1982
                                                                        OFFICE OF
    Ms. Diane Hicks                                              AIR. NOISE AND RADIATION
    Environmental  Protection Agency
    Congressional  Liasion Office
    401 "M"  Street,  S.W.
    Washington, DC  20460

    Dear Ms. Hicks:

    Except for  this  first sentence, these documents are  identical  to  those  we
    send  to  a device manufacturer  who is interested  in  an EPA evaluation  of
    his   device.     The   Environmental   Protection  Agency   is   charged   by
    Congressional  mandate   to   evaluate  fuel  economy  and  emission  control
    devices.  While  the  EPA does not actually "approve"  such  devices,  it  does
    conduct  evaluation's  for the purpose of increasing  the  common knowledge  in
    the  area.   For  this reason,  the  outcome of  any  testing  by  ETA  becomes
    public information.   It  is  this  information which may be  cited,  although
    no  claims  can be made that  any EPA findings constitute "approval" of  the
    device or  system.

    Enclosed with  this letter is a packet of materials which  you will  need  to
    apply  for  an  ZPA evaluation  of  your device.   This  packet .consists  of
    1)  an application   format,  2) a  document  entitled  "EPA Retrofit   and
    Emission Control Device Evaluation Test Policy",  3)  "Basic Test Plans  and
    Testing  Sequences",  and  4)  a  copy of the applicable Federal Regulations.
    Engine  oils,   oil additives, and other  lubricants do  not fall under  the
    provisions  of  Section  511  of the  Motor  Vehicle  Information  and  Cost
    Savlrgs  Act.   Recently,   there  has  been  confusion over the wording in  the
    regulation  that  gives-  EPA  the  authority  to  evaluate  fuel   additives.
    Until  we are  able  to eliminate  this confusion  by modifying  the  regula-
    tion,  we cannot  accept  applications  for evaluations  of   fuel  additives.
    If  you wish to  improve  the credibility - of your  oil  or fuel additives  by
    performing  tests on your  own,  we  will try  to  help by commenting  on  your
    test  plans.

    In  order for  the  EPA  to conduct  an  evaluation of  your  device,  we  must
    have  an application.   Once you  have reviewed  all  the  documents in  the
    packet,  you should  prepare an application  in  accordance with ' the  guide-
    lines  of the  application format.   A critical  part of the application  is
    the  substantiating  test  data.  The  required test results will have to  be >
    obtained at a laboratory of your  choice.  Such  testing would be  conducted
    at  your expense.   A list  of  laboratories, which are known to  have  the
    equipment  and personnel  to  perform acceptable  tests, has  been  included  in
    the  enclosed  packet.  The  laboratory list is revised  periodically, so  be
    certain  that  the  list  you are  using is  current.  Please  allow EPA  to
    comment  on  your test   plan before  beginning  testing at an  independent
    laboratory.   If  you desire, we  can assist in the development  of  a satis-
    factory  test  plan.

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                                                                        16

There  are,  however,  several  aspects  concerning  testing  at  an  outside
laboratory which I would like to* bring to your attention at this time:

    Minimum Test  Requirements - Although  different  types of  devices may
    require a more complex  test  plan,  the  minimum we require involves two
    vehicles  and  two   test   sequences  run  in  duplicate.   The  vehicles
    should be  selected  from  those listed  in Table  1;  if  possible.   Each
    vehicle is to  be set  to manufacturer's tune-up specifications for the
    baseline tests.

    The  tests  are  conducted in  a "back-to-back" manner,  once  with the
    vehicle in baseline condition,  and  again  with  the  device  installed
    with  no  vehicle adjustments  between  tests.   If installation of the
    device also involves  some adjustments, e.g.  timing, fuel-air mixture,
    choke  or  idle speed,  another test  sequence with  only  these adjust-
    ments  should  be  inserted  between the  first and  last.  If  mileage
    accumulation  is  necessary in  order  to realize  the  full  benefit, the
    same  number  of miles that are accumulated before  the  test  runs must
    also  be accumulated before  baseline  runs.   In addition,  the  method of
    mileage accumulation should be  kept  constant.   Also,  as a minimum,
    the  test  sequence  shall  consist of  a  hot-start  LA-4 portion  (bags 1
    and 2) of  the  Federal Test  Procedure  (FTP) and a Highway Fuel Economy
    Test  (HFET).   The  details  of  these  tests are   contained  in  the
    enclosed  packet.   Although  only  a  hot-start  FTP is  required  to
    minimize  the  costs  to   you,  you  are  encouraged to have the  entire
    cold-start test  performed,  since  any  confirmatory testing and evalua-
    tion  performed by EPA will be based  on  the  complete FTP,  and  you may
    wish  to  know how  a vehicle with  your  device performs   over  this
    official test.   As  a final  requirement, the personnel  of  the outside
    laboratory  you  select   should perform  every  element   of   your  test
    plan.  This  includes preparation  of  the test vehicle,  adjustment  of
    parameters, and installation of the device.

    Submission of  Data  - We  require that  all  test data obtained from the
    outside laboratories in  support  of  your application be  submitted  to
    us.   This  includes  any   results you  have which  were declared  void or
    invalid  by the  laboratory.   We also  ask  that  you notify us of the
    laboratory you have chosen, when  testing  is scheduled  to begin, what
    tests you  have decided  to conduct, allow  us to  maintain contact with
    the  laboratory during the course  of  the testing,  and  allow the test
    laboratory to directly  answer any  questions at any time  about the
    test  program.                                                        ,

    Cost  of  the  Testing  - The  cost  of  the  minimum test   plan  (two
    vehicles,  two test  sequences  in duplicate)  described above  should be
    less  than  £3000 per vehicle  and  less  than  1^6000  for the total test at
    any  of the laboratories  on the list.   It  should  be  recognized that
    additions  to  the  minimum  test  plan  (such  as  mileage accumulation,
    parameter  adjustment,  or additional  testing)  will result   in  addi-
    tional  costs.  In  any  case,  you  will have to  contact  them individ-
    ually to obtain  their latest prices.

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                                                                          17
    Outcome of  the  Testa -  In Border for EPA  to  best utilize  our  facil-
    ities,  confirmatory  testing  will be performed  only on  those  devices
    that demonstrate  a  statistically  significant  improvement  in  fuel
    economy or emissions based on data  from  an EPA-recognized independent
    laboratory.  We have established some  guidelines which will help  you
    determine whether the test results  with  your  device should be  consid-
    ered encouraging.  These values  have been  chosen  to assure both of us
    that a  real difference  in fuel  economy  exists, and  that we are  not
    seeing  only the variability  in the  results.   The  table below presents
    the minimum number of cars that  need to  be tested  for varying  degrees
    of fuel economy improvement, assuming a  typical amount of variability
    in fuel economy measurement.  For a minimum test plan which was con-
    ducted  on  a  fleet  of two cars,   the average improvement  should  be at
    least 62.  If at least a 62  difference in  average  fuel economy  can be
    shown,   then we would  be able to say  statistically  at the 802  con-
    fidence level that there is a real improvement.

    Similarly, we would expect a minimum of  32 improvement for a  fleet of
    5' vehicles.   Test  results  which  display  a  significant  increase  in
    emission levels should be reason  for concern.

         Minimum Fuel Economy Improvements versus Size of Test Fleet

         Fleet Size                   Average Improvement Required
              2                                  52
              3                                  52
              4                                  42
              5                                  3Z
             10                                  22

Once we  receive your application,  it will  be  reviewed  to  determine if it
meets  the  requirements  listed  in the format-.   Please do  not  submit con-
fidential,   trade  secret,  or proprietary information as EPA cannot  assure
that  such   information  can be  protected  in  all situations.   If  your
application  is  not  complete, we will ask  you to  submit  further  informa-
tion  or data.   After  any  missing   information has been  submitted,  your
application will  be  reconsidered, and once  it  meets our requirements,  you
will be  advised  of  our  decision  whether or not EPA will  perform any con-
firmatory  testing.   Any  EPA testing  will be  performed  at no  cost  to  you
and you will be given  the  opportunity to concur with  our test plan.  Once
this  testing is complete,   an  evaluation report  will  be  written.    If no
further  testing is required,  the  report will be  written solely  on  the
basis  of the test data submitted and  our.engineering analysis.

EPA  intends to process  your application  in as  expeditious  a manner as
possible.  We have  established a goal of twelve weeks  from the receipt of
a complete  application  to  the  announcement  of  our report.  The attainment
of  this  objective requires very precise scheduling, and  we are depending
on  the applicant  to respond promptly  to any questions, or  to submit  any
requested  data.   Failure to respond  in a timely  manner will unduly delay
the  process.   In  the extreme case,  we may  consider lack  of  response as a
withdrawal of  the application.

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                                                                        18
I hope the information above  and  Chat  contained  in the enclosed documents
will aid you  in the preparation of  an acceptable application  for  an  EPA
evaluation of  your  device.   I will  be  your  contact with EPA  during  this
process  and  any  subsequent  EPA  evaluation.  . My address  is   EPA,  Motor
Vehicle  Emission  Laboratory,  2565  Plymouth  Road,  Ann Arbor,  Michigan,
A8105.  The telephone number  is  (313)  668-4299.   Please contact me  if  you
have any questions or require any further information.

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

.Enclosures

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                                                              19
                  AVI - Lewis J. Schneller


1.   Title;   The following is an application for evaluation

    of Atomized Vapor In lectors under Section 511 of the

    Motor Vehicle Information and Cost Savings Act.

2.   Identification Information;

    a.  Marketing Information;  This water/alcohol injector

        system will be marketed under the trade name of

        Atomized Vapor Injectors; Federal I.D. #81-0393244.

    b.  Inventor and Patent Protection; NA

        (1)   Lewis J. Schneller, 2019 West Sussex Avenue,

        Missoula, Montana 59801, designer and sole proprietor

        of Atomized Vapor Injectors.

    c.  Applicant;

        (1)   Name and address of individual applying for this

        evaluation:

                   Lewis J. Schneller
                   2019 West Sussex Avenue
                   Missoula, Montana 59801

        (2)   Principal officers and/or owners of this organiza-

        tion :  '

                   Lewis J. Schneller
                   2019 West Sussex Avenue
                   Missoula, Montana 59801

        (3)   The person who is authorized to represent Atomized

        Vapor In lectors in communications with the EPA:

                   Lewis J. Schneller
                   2019 West Sussex Avenue
                   Missoula, Montana 59801
                   Phone:   (406)728-2752 or
                   Message: (406)721-1330, ext.  266

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                                                              20
    d.  Name and address of the individual or corporation who



        is (or will be)  manufacturing the product:  This



        information is undecided at this time, although,



        because of the simplistic design and operation of



        AVI,  we have successfully experimented untilizing



        emotionally and physically disabled adults for



        assembly and distribution procedures at Missoula's



        Opportunity Workshop, 1005 Marshall Street, Missoula,



        Montana  59801.   Mrs. Donna Booth was the supervisor



        in charge of this operation.



3.   Description:



    a.  Purpose; with the ever-increasing cost of gasoline,



        combined with the potential international oil supply



        system bordering on international crisis and the



        subsequent possible gas rationing, the need for a gas



        saver like a water/alcohol injector system appears to



        be a matter of being at the right place at the right



        time; i.e., the time is ripel  The challenge exists



        to develop a readily available and inexpensive water/



        alcohol injection system to increase not only fuel



        conservation, but to increase engine operation efficiency



        as well.  If for no other reason, it may become readily



        apparent that water/alcohol injection systems should be



        a manditory requirement on all gas-powered vehicles,



        if only to prevent unnecessary engine repairs due to



        excessive carbon accumulation.





                             -2-

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                                                       21
     Presently, there are a few varieties of water/



alcohol injectors on the market today, ranging in



price from $29.95 to nearly $400.00 per unit.  Some



of,,the proposed advantages of the Atomized Vapor



In lector are the following:



     (1)  Since the container for AVI is accomplish-



ed by recycling used hospital I.V. bottles, not only



does this process contribute to our national philosophy



of energy conservation through recycling, but the I.V.



hospitai bottle seems to be an ideal container for



the successful operation of a water/alcohol injector.



The many personal testimonials and independent test-



ing results by the City of Missoula1s.Street Mainten-



ance Department seem to support this statement.



     (2)  Since the AVI unit is the only glass



container on the market today, it has an inherent



advantage over all other units made of opaque plastic.



AVI can be visually monitored during operation, thereby



eliminating any need to install an expensive warning



light system to warn- the vehicle operator when the



water/alcohol solution becomes too low for satisfactory



operation.  Because AVI is a glass container with



graduated milliliter markings, the vehicle operator



can very easily monitor the desired consumption rate



(approximately 100 ml of water/alcohol solution per



20 gallons of gasoline consumed)  by simply adjusting






                     -3-

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                                                          22
    the needle valve setting to correspond to the recommend-


    ed consumption rate.  No other water/alcohol injection


    system has these advantages i


         (3)  The glass hospital I.V. bottle is designed to


    significantly exceed the maximum safety requirements


    for safe and durable operation.  In the event of defect,


    a used hospital I.V. bottle is easily replaceable and


    inexpensive.


         (4)  The simplistic design and operation of AVI


    water/alcohol injectors easily lends itself to satis-


    factory assembly and distribution programs by handi-


    capped people.  Successful experimentation with this


    concept has already been demonstrated with Missoula's


    Opportunity Workshop employing disabled adults.


         (5)  Atomized Vapor Injectors lends itself to a


    variety of creative marketing programs, especially


    when viewed in light of our current local and national


    economic predicament.  The potential exists for creat-


    ing employment and services that may serve as a shining


    example of reflecting America's original philosophy of
                                                            t

    fostering independence through the spirit of innovation


    end novel creativity for self-determination. (Please


    find proposed budget analysis and marketing format


    enclosed for your convenience.)


b.  Theory of Operation:  Atomized Vapor In lectors is a


    hydroautomization system which adds a 50/50 water/alcohol




                         -4-.

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                                                      23
vapor to an engine's intake system.  A water/alcohol



vapor injector produces a more efficient  fuel burn



by automizing the gasoline droplets and lowering  the



engine's temperature.  This process will  not only



improve an engine1^ over-all performance and increase



gas mileage rates, but will also increase the engine's



life span by eliminating excessive carbon deposits.



This  water/alcohol  injection system, AVI,  uses engine



vacuum pressure to pull outside air through the glass



I.V. hospital reservoir containing a 50/50 water/



alcohol solution which is attached to the car under



the hood.  This causes the solution of water and



alcohol to bubble and splash within the vacuum chamber



forming a mist of water and alcohol droplets and



vapor in the upper: part of the glass reservoir.  This



mist is then drawn by the vacuum pressure through a



plastic hose which is then connected to any intake



manifold suction hose (the positive crankcase valve



is the ^nost desireable connection).  This connection



is made by very easily cutting the rubber vacuum  hose



with a sharp knife and then'inserting the plastic "T".



The plastic needle'valve can then be easily adjusted-"



to allow just the right amount of water/alcohol vapor



to pass into the combustion chamber (best results are



derived by adjusting consumption rate to  allow 100



milliliters per 20 gallons of gasoline).




                    -5-

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                                                         24
c.  Const ruction and Operation;  The Atomized Vapor



    Injector consists of a recycled hospital I.V. bottle



    secured in a plastic holder, which is then attached



    under the hood to the inside of the engine compartment.



    A high quality rubber stopper with two holes is placed



    in the opening of the glass I.V. bottle.  An 8 inch



    plastic tube with a plastic air-stone or airiator on



    one end of the tube is attached to the rubber stopper,



    with the plastic air-stone  (airiator) placed near the



    bottom of the bottle.  Now a plastic needle valve is



    attached in the remaining opening in the rubber stopper,



    with a high quality four foot plastic tube attached to



    the other end of the plastic needle valve.  All that



    remains is to insert the black plastic "T" into the



    rubber vacuum hose.  Make sure .that the four foot



    plastic tube between the AVI unit itself is completely



    straight, with no up or down bends in it,  and that it



    is not in contact with any super-hot surfaces,  as this



    may cause- the plastic tube to collapse.  The AVI unit



    itself should be installed lower than the "T" connect- ,



    ion, as this facilitates vapor rising upward.  It is



    also advisable to operate the AVI unit on the top



    half of the reservoir,  as the vaporizing process



    diminishes on the bottom half of the bottle.  This



    establishes another need to have a glass container
                        -6-

-------
                                                               25
         for visual monitoring,  as the glass container should



         be refilled when it is  half-empty.  The unit's effect-



         iveness diminishes on the bottom half of the bottle.



     d.   Specific Claims;  The introduction of AVI's water/



         alcohol vapor into the  fuel air mixture through a



         vacuum line leading to  an engine's intake system



         produces a cooling effect that increases the mixture



         density, extending the  burning rate,  and improving



         combustion efficiency.   This process  helps  to elimin-



         ate engine ping (predetonation)  and diesling (after-



         running of motor).  Since steam is a good cleaning



         process, this helps to  dissolve carbon deposits on



         the spark plugs and cylinder walls of older vehicles,



         and prevents carbon build-up in newer vehicles.



         Engine horsepower and octane can be increased because



         less fuel is needed to  produce the same amount of



         energy  when   using a  water/alcohol injector.



     e.   Cost and Marketing:  Please see attached marketing



         and sales schedule.  Mr.  Larry Wilkinson of Edwin K.



         Williams and Company, Missoula,  Montana, has indicated ,



         a willingness to undertake this  aspect of AVI.



4.   Installation, Operation, Safety and Maintenance:



     a.   Applicability;  Atomized Vapor In lectors is designed



         to be implimented on all gas-powered vehicles.   The



         only known restriction  today is  that  certain vehicles
                             -7-

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                                                         26
    with little or no extra available space in the engine



    compartment cannot accomodate insertion of a quart



    container the size of AVI.  AVI is presently consider-



    ing the feasibility of manufacturing units smaller



    than its present size with  ^  quart containers in



    order to accomodate vehicles with less available



    engine space.



         It is not known whether operation of a water/



    alcohol injector is adversely affected by adverse



    weather conditions, types of driving or topographical



    differences.



b.  Installation;  Please see attached installation



    instructions.



c.  Operation;  Please see attached operation instructions.



d.  Safety;  It is not known whether the use of this



    product could result in any unsafe conditions for



    the vehicle occupants, or persons or property in



    close proximity.



e.  Maintenance;  There is no maintenance schedule or



    procedure for successful operation of AVI.



Effects on Emmissions and Fuel Economy;



a.  Unregulated Emmissions;  Information unavailable.



b.  Regulated Emmissions and Fuel Economy;   Please see



    independent testing results of the City of Missoula



    Street and Maintenance Department.





                        -8-

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   GAS SAVER
                 GAS SAVER
                     ATOMIZED VAPOR INJECTOR
                    (Water/Alcohol Vaporizer)
               (Missoula  Street  Dept.
   * Saves Gas  tested)
   * Increases Engine Power  (RPM's)
   * increases Gas Octane  Rating
   * Eliminates Carbon
   * Eliminates Ping
* Easier  Starts
* Cleaner Exhaust
* Cleaner Spark  Plugs
* Easy to Install
* Economical
                                                               27
   THIS ATOMIZED VAPOR  INJECTOR  is a hydroautomization system
   which adds a 50/50 water/alcohol vapor to an engine's intake
   system and produces  the  above-noted benefits.  Water/alcohol
   vapor produces; a more  efficient fuel burning by "automizing"
   the gasoline droplets  and  lowering the engines temperature.
   This process .not only  improves an engine's over-all perform-
   ance, but increases  the  engine's life span by eliminating
   carbon deposits.

   OPERATIONAL INSTRUCTIONS;  (Water/alcohol Formula)
        Fill injector unit  with  a 50/50 ratio of water and
   methol alcohol.   There are many commercial outlets for your
   alcohol supply,  such as  any gasoline additive like gasohol
   or preventive gas line freeze.

   INSTALLATION INSTRUCTIONS:
        1.  Attach unit to  engine fire wall or fender (or any
   available space) with  sheet metal screws.
        2.  Next locate the positive crank case (PCV) line
   which leads to the base  of the carburetor.  If your car  is
   not equiped with a PVC line,  most vacuum lines will easily
   SUf fj-CA^.	•	'
        3.  Now simply  cut  PVC line (rubber hose)  with a knife
   and insert plastic "T".            ~ .
        4.  Last,  fill  unit with. 50/50 mixture of water/alcohol,
   start engine,  and adjust bubbling process with needle valve
   so that liquid is vigorously  bubblinq. NOTE: For best re-
   sults, unit should use 100ml. of mixture per 20 gallons  of
   gasoline and operate unit  on  top half of bottle only,  as
   vaporizer action diminishes on bottom half of bottle.
#&+

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                                                                28
                 Missoula,  Montana
                                                     saaoi


                                                      STREET OEPARTMgNT
                                                        8oowo.«8rcadw.y
                                                   Phon«: 721-4700, g*t. 248


                         TEST RESULTS

                       WATEK VAl'OKIZOR

SUBMITTED TO TttE CITY FUK TESTING BY  LEWIS SCHNELLEK, 728-2341


CONDITIONS.':

      1.   Pickup 010 (Vehicle Maintenn&ce department) with 50,000 + miles
      2.   Check 010 on 3 cope and tune engine
      3.   Check all tires, 32 Ibu.
      4.   Check wheel bearings
      5.   Install 1.1 gallons gas can with 3-way valve.   Install at fuel
          pump
      6,   All  tests shall ho. made off _L_. i g4.s ^aiik
      7.   Highway test. shall bo nude  n^ing wosc on Highway 10 toward
          French town.  Speed wichjn  the city ahall be 30  mph  and 50 mph
          on  Che highway
      8..  City  testing shall b« un  ci ty streeta at a apeed of 20 to 25 mph
    • 9.  Temperature and wind Speed  v/JlJ be recorded each test.

TEST I  (ON HIGHWAY)  12-10-80

      Base test without any sab-saving device.

      Temperature 24", no wind

      Speedometer after               50.966.6
      Speedometer before              50,947.9

      Base mileage                        18.7  *

TEST I  (ON HIGHWAY, USING WATEK VAPORIZER)  12-10-80

      Temperature .30*, no wind

      Speedometer aftar               SI, 015, 7
      Speedometer before              50,995.7

      Mileage                            20.0 ^  + /. J

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                          TEST RKSl'l.TS
                             page 2                                  29
TEST II   (ON HIGHWAY, USING WATER VM'ORIZEK)    12-I.L-80

      Temperature 4U", licud wind  7-9  mph

      Speedometer aftur                5l,0bh,3
      Speedometer before               5i,04'5.7

      Milea*e                               20. 6-


TEST I   (IN CITY, USING WATKR  VAPORiZEaj    i2-22-«0

      Tcmp«racurc 36*, no wind

      Spaedbmetcr after                51.236,5
      Speedonmccr bcforu               3', 221. 5
TEST II    (IN CITY, WITHOUT WATER VAPOIUZKR)

      Tempera Cure 41*, no wind
                               i
      Speedometer after         •        51,2.52.2
      Speedometer bcfora                5L,237.4

     % Mile age                               I A. a
NOTE;  Vehicle was  tested back  on  the  .sci'i»j.   Ail standard tests
       were O.K.

REMARKS ;  Katest City ilrlving *«> vehicle  //.LO  is  not  in a atop li
       route.  1 believe  the  test will be more accurate.
TEST III  (IN CITY, WITHOUT WATER  VAi'Oki >;i- R)    1-5-81

      Temperature 37°, no wind

      Speedometer after                 51.364.4
      Speedometer .before                51,348.5

      Mileaye                             .  "l4,(J

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                                                                   3Q
TEST IV   (IN CITY, USING WATER VAPORIZKK)

      Temperature  41*, no wind
                                             1-5-81
      Speedometer after
      Speedometer before

      Mileage
51 ,381.9
31,366.8

    15.1
                                                 -  -/-*  a
TESTING DONE BV ROY WIU1ELM, VEHICLE MAINTENANCE SUPERVISOR

                                                   1-23-81

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                                                                                 31

             ESTP1ATED  PROJECTION AtfD  FORECAST OF THREE  YEARS EARNINGS

                   (Attach Narrative  Explaining Eosis  for Figures
                     Showing Receipts,  Expenses, and  Profits.)

                 YEAR                         /^ >         /?XJ
Gross  Receipts .   .  .  . @. •'.''• f*".  . .       $M4 a
Merchandise Coat .  .  , ?.  . **•.**, .  .         £e>^»f<^^_    1*0
Cress  Profit

Expenses:

  Officers' Salaries  (If  Corporation)   $  /•?, r^Pj. »•«   •?  *•?<><,*,*>   ••?  t <». * ^ o_r •_?
  Snnloyee V.'ay.es .  .  .  . '
  Accounting 4 Legal Fees
  Advertising  .  .  .  .	         «?, /fz.. .»<*    	L±?f.*±.      J. •/•».> *
  Telephone	          /.2+«.fo        3. •/++.••    	^ti»0.»»
  Interest	      •    I, J+* .*•*
  Repairs	           ?**..<>	,
  Taxes   .  .  ,	           5^*••*.__   	/•>«.»•       3.»+f...
  Insurance	           J/"o,^<»         1C«.»*    	7««.».
  3ad Debts
-•'Miscellaneous  (Postage,etc)^A*?        77/7^>.>o    ^illJjHi£_   /T/r
     Total Expenses  ..<....     $ //»   $   /7V
     Le»a  Income Taxes ......         3.1 r/. » •
  Net Profit  After Taxes	     $  //. 7-». j^-' S
     Less Withdrawals	      $	.  $	  $.
        (Proprietorship/Partnership)
     sun  is  large,  please itemize.
     I certify  tha  foregoing data  fairly represents  the financial situation
to the best of  my knowledge.
                                                                    /

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                                                                              32
                                                                      Attachment  B
         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         ANN ARBOR. MICHIGAN  48105
July 16, 1982                                                        OFFICE OF
                                                               AIR. NOISE AND RAOIATIG:

Mr. Lewis J. Schneller
2019 West Sussex  Avenue
Missoula, Montana 59801

Dear Mr. Schneller:

Our  engineering  evaluation group  has  reviewed  your application  for an
evaluation  of  the Atomized  Vapor Injector.   Before your device  can be
fully  evaluated  by EPA,  you must  submit  data from  exhaust  emission and
fuel  economy tests on  at least  two  vehicles.   These tests  must  be  per-
formed  at an independent laboratory  recognized by  EPA.   I am enclosing a.
current list of  these  laboratories and other  documents  which define our
policy  on acquistion  of test  data.   This  is  the  latest version  of the
information  I  sent to you with  the application  format.

We  have also  reviewed  the  road  test  data you submitted  but  do not  feel
that  the  program  was   sufficiently  controlled  or  extensive  enough to
accurately quantify the  worth of your device.  Moreover,  this testing did
not include  any measurements  of exhaust  emissions.

As  you requested,  we have  also  enclosed  a set  of  test  plans.   Unfortu-
nately, none  of   the testing laboratories  are located  near you  and we
cannot  recommended one laboratory  over  another.   Any of  the  ones  on our
list will be satisfactory.

You are probably  aware  that the design of your device is  quite  similar to
a number of  devices which are,  or have been, on  the  market.  We have  also
included a  listing of the  devices which  EPA has evaluated.   Your device
would  be categorized as  a  "vapor air bleed".  Upon  your request,  I  will
give you more  information on any of these  devices.

In  order to  maintain our overall schedule for  evaluating  devices, we  need
to  know when we will receive the above information.  Please contact me by
August  9 with  your choice of laboratories and a  schedule  for  testing.  We
expect  that  the  results  will be  submitted  to us  by September 15, 1982.
If  you have any  question or require  further information, please contact
me.

Sincerely,
V^  f)   ,r
                    ^
 lerrill W. Korth
 Device  Evaluation Coordinator
 Test  and Evaluation Branch

Enclosures

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                                                  Attachment  C  33
                              Lewis J. Schneller
                              Atomized Vapor Injectors
                              2024 South Avenue West
                              Missoula, Montana 59801
                              September 2, 1982
United States Environmental Protection Agency
Motor Vehicle Emission Laboratory
Emission Control Technology Division
2565 Plymouth Road
Ann Arbor, Michigan 48105

Attention:  Mr. Merrill W. Korth

Dear Mr. Korth:

Please find enclosed the proposed testing format for Atomized
Vapor Injectors from Olson Engineering, Inc.  As soon as I
can secure some financial assistance to defray the costs for
these testing requirements, please be assured that I will
proceed as soon as possible.

Thank you for all your assistance, and please do not hesitate
to offer any further suggestions.
Sincerely,
      J. Schneller
 i406) 728-2752 OR 728-2720

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                   Engineering Inc.
                                                               35
                   Automotive Researcn Center
                   15442 Chemical Lane, Huntir
                   Zio Code 92649. Telepnone (714) 891-4821. Telex 685-599
^^ I {j ^^ tp+ ^ "^^ ^ 15442 Chemical Lane, Huntington Beach. California
August 25, 1982
Mr. Lewis J. Schneller
Atomized Vapor Injectors
2019 West Sussex Avenue
Missoula, Montana  59801

Dear Mr. Schneller:

This letter will serve as  a proposal to provide testing and
evaluation services  to you as  requested in your letter of
August 10, 1982.

Specifically, Olson  Engineering,  Inc.  (OEI) will test and
evaluate the Atomized Vapor Injector (AVI) device as specified
in the EPA guideline for aftermarket vapor-air bleed device
evaluations to satisfy the requirements of Section 511.  The
test program will  utilize  two  vehicles as required of a type
compatible with the  EPA test car  fleet to insure that EPA
will have an available basis for  comparison.   Our normal
computer printout  includes all the exhaust emission values
necessary as well  as accurate  fuel mileage figures calculated
from the emission  test data by the carbon balance method.
The OEI test equipment and methodology is approved by EPA
and conforms to the  accepted standards.

The test sequence  will be  as follows:

     1.  Obtain two  test vehicles compatible with the
         EPA fleet and suitable for use with the AVI
         device, probably  by renting.-
     2.  Inspect each vehicle  for legality and compliance
         with the  manufacturers emission parameters.
     3.  Remove the  cylinder head(s),  inspect and photograph
         the combustion chambers  and piston crowns to determine
         the deposit characteristics and levels.
     4.  Replace the cylinder  head(s)  and adjust to manufacturers
         specifications.
     5.  Conduct "baseline" tests:
              1 each 75 FTP CVS-II
              1 each HFET
   UAISONOFF1CE   *  3901 VARSITY WIVE  •   ANN ABBOT. MICHIGAN 48104  •   (3131 973-0310 TELEX 230-1 78

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                                                               36
Mr, Lewis Schneller
August 25, 1982
Page Two
     6.  Install the AVI device according to manufacturers
         instructions.

     7.  Conduct on-road "conditioning" mileage accumulation
         if required.

     8.  Conduct "device" test with the system fully
         operational:

              1 each 75 FTP CVS-II
              1 each HFET

     9.  Conduct "device" test with the system fluid
         resevoir dry but with the system otherwise
         operational:

              1 each 75 FTP CVS-II
              1 each HFET

    10.  Remove the cylinder head(s),  inspect and photograph
         the combustion chambers and piston crowns with
         particular regard to variations in deposit
         characteristics.

    11.  Restore the vehicles to the original condition.

    12.  Analyze the test data and the deposit inspections
         and prepare a comprehensive report.

Cost Analysis

The cost of the test program to satisfy the requirements of
Section 511 as outlined by EPA is based on renting two vehicles
for a period of four weeks, the testing, teardown (twice) of
the engines and the preparation of the final report.  OEI does
not know of any requirement to accumulate mileage after install-
ation of the AVI device but that task is listed as item No. 7
in the test program and will be considered an option.

     Basic cost for both vehicles:     $11,750.00

     Mileage Accumulation Option:      $1.00/mile

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                                                            37
Mr. Lewis Schneller
August 25, 1982
Page Three
I hope that OEI may be of service to you and that your
project will be successful.  Please do not hesitate to
call at any time if you have further questions.
Best regards',
H. James Law
Senior Project Engineer

HJL:rb

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                                                                            38
                                                         ATTACHMENT D
September 10, 1982
Mr. Lewis J. Schneller
Atomized Vapor Injectors
2024 South Avenue West
Missoula, MT  59801

Dear Mr. Schneller:

We have evaluated  your  test  plan which we received on  September  7,  1982.
Our comments are as follows:

    1.   We  require  duplicate  tests  sequences on  each  vehicle  at  each
         test  point.   Your  plan indicated  that  only  a  single test  se-
         quence would be conducted.

    2.   While we  do  not require  removal  and  inspection of  the  cylinder
         head(s) for our purposes, we do not object.  Our concern is that
         no changes other than  the installation of  the  device are  made to
         the vehicle during the testing portion of the program.

    3.   Step  9  of your plan  requires  that the  vehicles is  tested  with
         your  device  installed  but  with  the  reservoir  dry.   We do  not
         require this step for our evaluation.

We hope  the  above  comments  are helpful to  you in conducting a test  pro-
gram to  evaluate the  "Atomized Vapor Injector".  We  ask that  you submit
the results  from your tests by October 29,  1982.   If you have any  ques-
tions, please contact me at (313) 668-4299.

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

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              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY         Attachment  E
November 2, 1982
Mr. Levis J. Schneller
Atocized Vapor Injectors
2024 South Avenue West
Missoula, tlT  59801

Dear Mr. Sclmalleri

We still rave not  received data  from  your test plan which we  approved  on
September  10*   AS a  result, ve  lack test  data which  may support  your
claiinc for the Atomised Vapor Injector.

As I explained in  our earlier letters  and telephone  conversations,  we arc
obligated to publish  the  results  of  our evaluation in the  Federal  Fleglc-
ter.  We cannot 
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