EPA-AA-TEB-511-85-2
Second EPA Evaluation of the POLARION-X Device Under Section
511 of the Motor Vehicle Information and Cost Savings Act
by
Edward Anthony Earth
April, 1985
Test and Evaluation Branch
Emission Control technology Division
Office of Mobile Sources
U.S. Environmental Protection Agency
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EPA-AA-TEB-511-85-2
Second EPA Evaluation of the POLARION-X Device Under Section
511 of the Motor Vehicle Information and Cost Savings Act
by
Edward Anthony Earth
April, 1985
Test and Evaluation Branch
Emission Control Technology Division
Office of Mobile Sources
U.S. Environmental Protection Agency
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EPA Evaluation o£ the POLARIQN-X 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.
This second evaluation of the POLARION-X device was conducted
upon receiving an application for evaluation from the marketer
of the device. The device is a fuel line magnet. It is
claimed to reduce emissions, to improve fuel economy and
performance, to provide more complete combustion, to eliminate
engine carbon buildup and dieseling, and to reduce the octane
requirements of the engine.
This application was essentially a copy of the previous
application with subsequent vehicle test data from private labs
included. Although these data did not show a clear or
consistent pattern for the device, they were sufficient to
justify EPA conducting a second evaluation if the applicant was
willing to fund the EPA confirmatory testing, the next step in
the evaluation process. The applicant provided the funds. EPA
tested the device and proceeded with the evaluation.
Since this application was a-, copy of the previously completed
application. EPA considers that the previous correspondence
and analyses that were incorporated in the prior evaluation
also apply to this evaluation. In addition, the intervening
correspondence about the device and test fuel are also
considered to apply to the application. The net result is
that, except for the test data, the previous submission and the
analyses of it are essentially unchanged.
The following is the information on the device as supplied by
the Applicant and the resulting EPA analysis and conclusions.
For Sections 1 through 6d(l) these are the same as in the" prior
evaluation. For brevity, this prior information is given below
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without the numerous applicable attachments (these attachments
are listed in the appendix and are available as part of the
previous evaluation report).*
1. Title:
Application for Evaluation of POLARION-X under Section 511
of the Motor Vehicle Information and Cost Savings Act.
The information contained in sections two through five was
supplied by the applicant.
2. Identification Information:
a. Marketing Identification of the Product:
POLARION-X Fuel Treatment Part No. 11587
b. Inventor and Patent Protection:
(1) Inventor
Albert J. Kovacs
1929 H
South Pasadena, CA 91030
(2) Patent #4,372,852 issued 2/8/83
Patent Application Serial No. 207,644 relating to
"MAGNETIC DEVICE FOR TREATING HYDROCARBON FUEL"
was replaced by the patent.
c. Applicant;
(1) AZ Industries, Inc.
28065 Diaz Road
Temecula, CA 92390
(2) Principals
LaVern (Les) L. Adam, President
31315 Via Norte
Rancho, CA 92390
Lawrence E. Beard, Vice President
2855 Monte Verde
Covina, CA 91724
The previous evaluation was "EPA Evaluation of the
POLARION-X Device Under Section 511 of the Motor Vehicle
Information and Cost Savings Act," EPA-AA-TEB-511-82-9.
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Barbara Adam
3135 Via Worte
Raneho, CA 92390
Robert L. Arnold, Treasurer
935 Roanoke Road
San Marino, CA 91108
Albert J. Kovacs, Consultant
1929 H
South Pasadena, CA 91030
(3) LaVern Adam is authorized to represent AZ
Industries in communications with EPA.
d. Manufacturer of the Product:
• (1) Name and address
AZ Industries, Inc.
28065 Diaz Road
Temecula, CA 92390
(2) Principals
LaVern (Les) Adam, President
Lawrence E. Beard, Vice-President
Barbara Adam, Secretary
Robert L. Arnold, Treasurer
Albert J. Kovacs, Consultant
3. Description of Product (as supplied by Applicant):
a. Purpose:
"The present device is a magnetic unit for treating
hydrocarbon fuel and an improvement on previous
electromagnetic devices developed with Saburo Miyata
Moriya in that it requires no outside source of energy
and therefore is a means to conserve energy."
b. Theory of Operation:
"It is a well established principle that an electric
field will promote combustion, increase vaporization
and heat transfer. Many papers have been presented by
the JSME and a list of Dr. Asakawa's papers are
enclosed in the letter of July 6, 1981 to Dr. John
Chao, Senior Motor Vehicle Pollution Engineer of the
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California Air Resources Board which explains in
detail the theory of operation." This letter and its
enclosures were contained in the application as an
exhibit. It transmitted a number of documents to
CARB. The pertinent ones have been incorporated in
this evaluation as attachments.
c. Construction and Operation:
"Information is in letter of July 6, 1981 and contains
data for this subsection c) under POLARION-X GAS SAVER
UNIT, BLOCK DIAGRAM, installation instructions and
Patent Drawing." (Attachments A, A-l, D, and E).
Product Installation, Operation, Safety and Maintenance
(as supplied by Applicant):
a. Applicability;
"The EPA Fuel Economy Estimates, Second Edition,
February 1981 California has been marked up to
indicate those vehicles which the device is suitable.
The device can be connected into all fuel line systems
of carbureted engines and is not suitable for fuel
injection, gasoline or fuel injection, diesel. Part
No. 11587 is applicable to all carbureted engines."
This copy of the EPA Fuel Economy Guide was marked to
indicate that the device applied to all 1981
California vehicles with carbureted gasoline engines.
b. Installation - Instructions, Equipment, and Skills
Required:
(1) "General instructions are contained in
installation instruction brochure and provide two
ways to install unit, with or without cutting
existing fuel line.
(2) "Unit is a universal model fitting vehicles with
carburetors only.
(3) "Tools required are a knife or scissors to cut
hose or hoses to proper length, pliers and a
screwdriver for unloosening existing clamps and
tightening new clamps.
(4) "No equipment required to check the accuracy of
the installation.
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(5) "No adjustments to vehicle or vehicle systems as
well as the device following installation.
(California mandates no deviations from factory
settings and specifications.)
(6) "Skills associated with the installation of the
device would be those possessed by the average do
it-yourself person who services his own car and is
capable of minor repairs such as adjusting fan
belts, removing and replacing air, oil and
gasoline filters, etc."
c. Operation:
"The unit is furnished with installation instructions
and a brief explanation of the history and principles
of the magnetic fuel treatment device for use on
engines equipped with carburetors."
d. Effects on Vehicle Safety:
"No effect on vehicles or occupants have been observed
since the supervised testing program was initiated at
California State University of Los Angeles beginning
in January 1980 on 10 vehicles driven by graduate
students, faculty and technicians. Independent
testing laboratories; Automobile Club of Southern
California; Transportation Testing, Inc. of Texas;
USAC, (IMS), Speedway, Indianapolis have reported no
unsafe conditions resulting from installing. Total of
33 cars have had units installed for testing purposes
with no record of any unsafe condition. Additional
backup data in Exhibit No. 5 supports no hazardous
conditions have occurred dating back to original
electromagnetic models which have been sold since
early in 1962." Exhibit No. 5 was a copy of the
EPA/DOE 1981 Gas Mileage Guide for California and
contained no information about the device.
e. Maintenance:
"No maintenance is required on the unit except
periodic inspection of hose connections."
Effects on Emissions and Fuel Economy (submitted by
Applicant):
a. Unregulated Emissions:
"See exhibit, letters from Ed Payne, Vice President
and General Manager of Transportation Testing
Incorporated of Texas dated September 3, 1981 to Al
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Kovacs, Azaka Co., inventor, on fleet vehicles used in
their testing operations which were equipped with the
fuel treatment unit. Some are vehicles used in the
50,000 mile reliability testing but not individually
identified. Approximately 15 vehicles are equipped
with fuel treatment units, accumulating mileage and
are checked weekly on an exhaust gas analyzer."
b. Regulated Emissions and Fuel Economy:
"Test data supplied as noted - Exhibit No. 8". The
new test data that was submitted for this second
evaluation is presented and discussed in Section 6d(2).
The following sections are EPA's analyses and conclusions
for the device
6. Analysis
a. Identification Information:
(1) In the first evaluation, a copy of the patent
application, Attachment A, was provided by the
applicant (Attachment J) in response to the EPA
request (Attachment H) for additional information
about the device. A copy of the patent was
provided with this second application.
b. Description:
(1) The primary purpose of device as given in Section
3a did not give a clear purpose for the device.
EPA twice requested (Attachments H and L) the
applicant to clarify the purpose.
The purpose was finally clarified to be
(Attachment N):
"The purpose of the Polarion X Gas Unit is:
1. Increase fuel economy
2. Reduce exhaust emissions
3. Eliminate carbon build up
4. Permit use of lower octane rated gasoline
5. Increase engine performance
6. Eliminate after running or dieseling"
The installation brochure (Attachment E) also
states that the device promotes fuel vaporization,
provides more complete combustion, and improves
the combustion rate.
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(2) The theory of operation given in Section 3b refers
to the use of an electric field to "... promote
combustion, increase vaporization, and heat
transfer." The exhibits also refer to electrical
devices. However, since the POLARION-X is a
magnetic device, the applicability of this
information was not apparent and EPA requested the
applicant to clarify how his magnetic treatment of
the fuel would beneficially affect emissions or
fuel economy.
Despite numerous requests and responses, the
applicant was unable to adequately explain the
theory of operation for the POLARION-X (see
Attachments H, J, L, N, O, and P) . During a
follow up phone call by EPA, the applicant finally
stated that it was difficult to explain the theory
by which the device works, that it worked by
molecular theory.
Thus, the applicant did not provide a sound
technical basis for EPA to believe the POLARION-X
has a beneficial effect on either emissions or
fuel economy. EPA is not aware of any information
that demonstrates that magnetically treating the
fuel will affect emissions or fuel economy. The
applicant was unable to provide a technically
sound theoretical explanation that adequately
described the beneficial effects of the device.
(3) The description of the device as described by the
documents listed in Section 3c, the block diagram
(Attachment A-l), installation instructions
(Attachment E), and patent drawing (Attachment A)
provided an adequate description of the
construction and claimed method of operation of
the device.
However, because the applicant stated in Section
3a that this device was ". . .an improvement over
previous electromagnetic devices developed . . .",
EPA requested (Attachment H) the applicant to
describe these improvements in greater detail.
The applicant provided the following description
of the differences:
"The improvement is based on the increased
magnetic lines of force with the placement
of the magnet element. The previous ION-X
and ATOM-X electromagnetic units produce
approximately 450 gauss at the center of the
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unit. The POLARION-X unit measures
approximately 750 gauss at the magnet
surface and 1500 gauss equidistant between
the surfaces .060 inches apart.
Improvements of the magnetic unit over
earlier electromagnetic units are (1)
increased gauss readings, (2) no electrical
potential required to activate the
electromagnets and conserving energy from
not being connected to the alternator, (3)
the magnet unit cannot cause a spark which
is a possibility with an electromagnet, (4)
ceramic magnets are capable of operating at
engine compartment temperatures." See
Attachment J.
(4) According to the specific claims of the applicant
for the device "Emissions - Depending on engine
conditions, can be reduced in a range from 5% to
10% for CO, 2% to 10% HC. Gas mileage
improvements as measured by SAE methods 5%.
Increased performance measuring various engine
parameters 10%." (Applicants response (Attachment
J) to EPA request (Attachment H) for specific
claims for the device.)
(5) According to the applicant (Attachment J), the
suggested retail price of POLARION-X IS $35.00.
c. Installation, Operation, Safety and Maintenance:
(1) Applicability:
The applicability of the product as stated in the
application, to essentially all carbureted
gasoline powered vehicles is judged to be
reasonable. That is, it is possible to install
the device on these vehicles. In Attachment K,
the applicant also stated that a new design was
being developed for gas and diesel injection
systems.
(2) Installation - Instructions, Equipment and Skills
Required:
The installation brochure (Attachment E)
adequately describes the installation of the
device. The applicant's statements, Section 4b,
about the tools, equipment, and skills required
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for installation appear reasonable. The
installation is relatively simple. In the EPA
tests of the device, installation took one hour.
There are, however, several aspects of the
installation that were overlooked by the
applicant. Installation of the device requires
additional hardware that is not provided with the
device. According to the applicant (Attachment
J), this "Additional hardware is not supplied due
to the various engine configurations. Hoses and
clamps of proper size are readily available for
specific engines from auto parts shops."*
Although the application clearly stated in Section
4b(5) that no post-installation adjustments are
required, the installation instructions state that
"Slightly less fuel is used if the carburetor is
adjusted when you have a tune up to take advantage
of the magnetic effect." EPA requested
(Attachment H) the applicant to explain what this
adjustment entailed, how was it made, and to
explain this apparent inconsistency between the
installation instructions in the application and
those provided with he device. In Attachment J,
the applicant informed EPA that:
"A tune-up is strongly recommended at time
of installation. California prohibits any
deviation from factory specifications for
tune-ups. In states where adjustments are
permitted a slightly leaner setting can be
made. After the unit is installed and
approximately 500 miles is accumulated full
economy increase can be measured and
emission by products are reduced."
Therefore, it appears the instructions provided
with the device are slightly misleading and do not
inform the purchaser how to adjust the carburetor
". . .to take advantage of the magnetic effect."
(3) Operation:
The applicant refers to the installation
instructions for operating information. These
instructions make no reference to the necessity
*Although the applicant didn't indicate that the hardware was
now supplied, the blister-pak packages provided for the EPA
testing of the device contained the necessary clamps and hoses .
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for a mileage accumulation prior to obtaining a
benefit. However, the "Abstract of Development of
POLARION-X" states "Most engines would require
preconditioning periods of up to 1000 miles before
optimum fuel mileage was obtained." EPA requested
(Attachment H) the applicant to clarify these
statements. The applicant's response (see
Attachment J)
"Depending on carbon deposits in the engine,
most vehicles require 2 to 3 tanks of fuel
to be consumed to clean out the engine and
as this occurs gas mileage increases.
Assuming the average car tank capacity
provides 250 to 350 miles range, 2 to 3
tanks are approximately 500-1050 miles to
show results. Yes, some vehicles show
immediate benefits the first day. Benefits
are observed after the unit is removed.
This is confirmed by test vehicles with and
without devices which are switched halfway
between the test program and by exhaust
emission readings of HC and CO which
remained lower after completion of test
programs."
indicates that mileage accumulation with the
device is required before the device would be
expected to have an observable benefit.
(4) Effects on Vehicle Safety:
Based on the patent application description and
the installation instructions, the device is
judged to be capable of being fabricated to be
safe in normal vehicle usage.
(5) Maintenance:
The applicant's statement that no maintenance is
required, except for periodic inspection of hose
connections, is judged to be correct.
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 and fuel economy only.
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However, since the device does not modify the vehicle's
emission control system or powertrain and does not appear to
change fuel characteristics or regulated emissions, the device
should not significantly affect a vehicle's nonregulated
emissions.
(2) Regulated Emissions and Fuel Economy:
The applicant submitted three sets of test data
from recognized independent laboratories using the
FTP/LA-4 and HFET test procedures.* These data
are given below:
SCI Laboratories
Test of 78 Ford LTD, April 1982
Hot LA 4, grams/mile
HFET
HC CO NOx MPG MPG
Baseline LA-4 1.01 1.30 1.09 12.6 17.7
.67 .19 1.25 12.3 17.9
POLARION-X after .51 2.06 1.15 12.0 17.8
500 miles .50 .89 1.27 12.3 17.7
Fairway Environmental Engineering
Chevrolet Malibu, April 83
Baseline .28 8.84 .60 17.2
POLARION-X .30 8.51 .47 17,5
Fairway Environmental Engineering
82 Datsun B-210, April 83
Baseline .24 7.10 1.06 21.7
POLARION-X .21 6.46 .92 22.4
Fairway Environmental Engineering
83 Ford Mustang, December 83
Baseline .21 2.86 .31 14.7 20.6
.23 2.49 .43 14.7 20.6
POLARION-X .21 1.31 .40 15.4 21.0
after 1000 miles .20 2.71 .35 15.5 21.4
FTP is the Federal Test Procedure, LA-4 is the Urban
Driving Schedule. A cold start LA-4 is bags 1 and 2 of
this cycle. A hot start is bags 2 and 3 of this cycle.
Bag 3 repeats the bag 1 driving schedule, HFET is the
Highway Fuel Economy Test.
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Fairway Environmental Engineering
83 Oldsmobile Custom Cruiser, December 83
Hot LA 4, grams/mile
HFET
HC CO NOx MPG MPG
Baseline .16 1.84 .94 14.1 21.3
.14 1.87 1.09 14.0 21.3
POLARION-X .13 .57 .97 14.7 22.8
after 1000 miles .14 .72 1.04 15.0 22.6
Fairway Environmental Engineering
83 Dodge Van, December 83
Baseline .15 1.34 1.23 12.3 16.4
.20 2.02 1.20 12.1 16.4
POLARION-X after .17 .72 .70 12.7 16.8
1000 miles .15 .59 .58 12.8 16.8
The analysis of the data indicates that the test
results do not show a clear or consistent pattern
for the device. The April 1982 test of one
vehicle at SCI with Indolene showed no benefit.
The April 1983 tests of two vehicles at Fairway
with commercial unleaded demonstrated no benefit.
The December 1983 tests of three vehicles at
Fairway with commercial unleaded indicated that
there may be a small benefit. Furthermore, there
is insufficient data to separate differences
attributable to changes in the various test
programs (e.g., mileage accumulation or fuel type)
from differences-due to the device . Explanations
offered for these inconsistencies are unsupported
by sufficient data to permit a conclusion.
However, it did appear that the data were
sufficient to justify EPA proceeding with
confirmatory testing, the next step in the
evaluation process, if the applicant was willing
to bear the test costs (Attachment T).
The applicant concurred, requested EPA to test the
device, and provided the test funds (Attachments
U, V, and W) . EPA tested the device." The
detailed report of this testing is given in
Attachment W and summarized in Section 7, the
following section.
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EPA Testing o£ POLARION-X
At the request of the applicant, EPA developed a plan for
EPA testing of the device (Attachments U and V) . AZ
Industries concurred with this plan and funded the test
costs (Attachment W).
The test program consisted of mileage accumulation without
the device, replicate baseline tests, mileage accumulation
with the device, and replicate device tests. The vehicles
were tested using the FTP and HFET.* Three vehicles were
tested. The test program and results are discussed in
detail in the EPA report titled: "Emissions and Fuel
Economy of the POLARION-X, A Retrofit Device,"
EPA-AA-TEB-85-1 (Attachment W).
The results for each vehicle are summarized in Table I
below. Emission levels are given in grams/mile while fuel
economy is given in miles per gallon. The individual test
results for each vehicle are given in the report.
Table I
Plymouth Reliant
Baseline
POLARION-X
Summary of EPA Test Results
FTP
HC
,50
,63
CO
5.90
7.81
NOx MPG
.98
.96
26.4
26.0
08
08
HFET
HC CO
22
22
NOx MPG
.92
1.02
35.3
35.1
Chevrolet Mailbu
Baseline .22 1.59 .. .76 20.0 .05 .20 .29 29.1
POLARION-X .22 1.63 1.00 20.0 .05 .18 .66 28.9
Ford Granada
Baseline 1.53 10.12 1.52 15.7 .26 .26 1.76 22.0
POLARION-X 1.18 11.24 1.49 15.7 .28 .57 1.65 21.9
*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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These data show no improvement in emissions or fuel economy for
the POLARION-X. As discussed in the report, the differences in
the Granada HC emissions was attributed to a stall in the
second baseline test.
The overall conclusion from the EPA tests is that there is no
reason to expect that the POLARION-X will significantly improve
vehicle emissions, fuel economy, or operation. There was no
improvement in fuel economy for any vehicle. Changes in
emissions were not statistically significant.
As noted in Section 6b(2) EPA is unaware of any information
that provides a technical basis to support the claim for
improved emissions and fuel economy for an in-line fuel magnet
device like POLARION-X. EPA previously tested and evaluated a
similar product known as Super-Mag Fuel Extender
(EPA-AA-TEB-511-82-3) and provided a copy of the Super-Mag
report to the applicant (Attachment M) . The Super-Mag also
showed no emissions or fuel economy benefit.
Conclusions
EPA fully considered all of the information submitted by the
applicant. This second evaluation of the POLARION-X device was
based on that information and the results of the EPA
confirmatory test program of the device.
The information supplied by the applicant was insufficient to
adequately substantiate either the emissions or fuel economy
benefits claimed for the device. In the EPA tests there was no
improvement in fuel economy for any vehicle. Changes in
emissions were not statistically significant. Vehicle
operation and performance were unchanged by the device. The
overall conclusion from these tests is that the POLARION-X did
not significantly improve vehicle emissions, fuel economy, or
operation.
EPA is unaware of any technical analysis or data that
demonstrates that magnetically treating a hydrocarbon fuel will
beneficially affect the emissions or fuel economy of a
vehicle. The previous EPA testing of Super-Mag, a similar
device, showed no emissions or fuel economy benefits.
Therefore, based on this information, our engineering judgment,
and the test results it is concluded that the POLARION-X device
will not improve emissions or fuel economy.
At the conclusion of the testing and evaluation process copies
of the test report and 511 evaluation report were sent to the
applicant for review. The applicant raised objections related
to the EPA analysis of the Polarian-X theory of operation and
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the applicant funded road and laboratory tests. Since, the EPA
results differed from these results, he felt that another
independent 511 test program was warranted. EPA reviewed these
concerns but considered further testing unwarranted and
therefore published the results unchanged. The applicant's
letter, Attachment W, and EPA's reply, Attachment X, were added
to the 511 evaluation report.
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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Attachment A
Attachment A-l
Attachment B
Attachment C
Attachment D
Attachment E
Attachment F
Attachment G
Attachment H
Attachment I
List of Attachments*
Patent Application (provided as an attachment
to November 30, 1981 letter to EPA). The
device is now patented, Pat. No. 4,372,852
dated 2/8/83.
Block Diagram of Magnetic Unit (provided with
511 application).
"Abstract of Development of POLARION-X", dated
July 1, 1981 (provided with 511 application).
Background Data on Magnetic Fuel
(provided with 511 application).
Treatment
POLARION-X GAS SAVER UNIT SPECIFICATIONS by
Albert J. Kovacs, the inventor of the device.
POLARION-X installation brochure and warranty,
the pamphlet also contains history and
principles of operation (provided with 511
application).
Letter of September 3, 1981 from Ed Payne,
Transportation Testing of Texas, to Al Kovacs,
a consultant of AZ Industries (provided with
511 application).
Letter of September 23, 1981 from Ed Payne,
Transportation Testing of Texas to Dale Diver
of AZ Industries (provided with 511
application).
Letter of October 26, 1981 from EPA to LaVern
Adam of AZ Industries acknowledging receipt of
511 application for the POLARION-X and
requesting clarification and additional
information.
Letter of October 27, 1981 from EPA to LaVern
Adam of AZ Industries describing procedures for
testing at an independent laboratory by the
applicant.
Attachments A through S were incorporated in the previous
evaluation of the device and, to conserve space, are only
listed here.
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Attachment J
Attachment K
Attachment L
Attachment M
Attachment N
Attachment O
Attachment P
Attachment Q
Attachment R
Attachment S
Attachment T
Letter of November 30, 1981 from LaVern Adam of
AZ Industries to EPA in response to EPA request
for clarification and additional information
about the device.
Letter of December 11, 1981 from LaVern Adam of
AZ Industries to EPA requesting EPA to comment
on two quotations and to assist in developing a
test plan.
Letter of December 14, 1981 from EPA to LaVern
Adam of AZ Industries requesting clarification
and information for items not fully covered by
prior response (Attachment J).
Letter of December 18, 1981 from EPA to LaVern
Adam of AZ Industries responding to request to
comment on proposal testing.
Letter of January 15, 1982 from LaVern Adam of
AZ Industries to EPA responding to EPA request
(Attachment L) for information and
clarification.
Letter of January 21, 1982 from EPA to LaVern
Adam of AZ Industries reiterating EPA's request
for information.
Letter of March 9, 1982 from EPA to LaVern Adam
of AZ Industries notifying applicant that EPA
would shortly close out the evaluation if
adequate test data wasn't provided.
Letter of Match 24, 1982 from Dale V. Diver of
AZ Industries to EPA which provided a copy of
the POLARION-X test plan.
Letter of March 25, 1982 from Albert J. Kovacs,
a consultant of AZ Industries, to EPA providing
information and data on POLARION-X.
Letter of April 5, 1982 from EPA to LaVern Adam
of AZ Industries commenting on the test plan
for POLARION-X.
Letter of February 6, 1984 from EPA to Mr.
LaVern Adam, President of AZ Industries
acknowledging receipt of the new 511
application for the POLARION-X and asking if AZ
is willing to fund the EPA confirmatory testing.
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Attachment U
Attachment V
Attachment W
Attachment X
Attachment Y
Letter of February 23, 1984 from Mr. Adam of AZ
Industries that indicated AZ wished to proceed
and would pay the test costs.
Letter of March 13, 1984 from EPA to AZ
Industries which discussed the testing,
provided a test plan test agreement, a test
plan for concurrence, and request for test
funds. A copy of the attachments to this
letter is provided on the test report below.
Letter of July 30, 1985 from Thomas S.
Huntington, an AZ Industries Attorney, in which
he took exception to several items in the 511
report.
Letter of August 22, 1985 from EPA to Thomas S.
Huntington, and AZ Industries responding to
preceding letter.
EPA Test Report, "Emissions and Fuel Economy
Effects of the POLARION-X, a Retrofit Device,"
EPA-AA-TEB-85-1.
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ATTACHMENT T 20
UNITED. STATES ENVIRONMENTAL PROTECTION AGENCY
¥ ANN ARBOR. MICHIGAN 48105
OFFICE OF
AIR. NOISE AND RADIATION
February 6, 1984
Mr. LaVern Adam, President
AZ Industries, Inc.
28065 Diaz Road
Temecula, CA 92390
Dear Mr. Adam:
We received your letter of December 19, in which you applied for a
second evaluation of the POLARION-X as a fuel economy retrofit device.
Our engineering evaluation group has made a preliminary review of
your application and has identified several items which we wish to
clarify. Our comments below address these items and our understanding
or position on each of them.
1. Your accompanying letter (Speedimemo) stated that this was a
resubmittal of the original application. However, since we conducted and
completed an evaluation of the device in response to your previous
application, we consider this to be a new application. Therefore, our
previously completed evaluation must be considered our official and only
evaluation until this evaluation process is completed.
2. Your application implied that this was a photostatic copy of the
original application, with subsequent test data incorporated. We also
noted a few minor changes (e.g., patent now issued rather than pending, a
few changes in principals) but do not consider these to have materially
altered the original application.
3. Since this application is essentially unchanged from the
previously completed evaluation of the device, we consider the previous
corresponding responses and analyses that were incorporated in the
evaluation of the original application to also apply to this application.
4. There were numerous letters and phone calls concerning the device
and the test fuel that were not incorporated in your original application
since they occurred after the evaluation was written. These are
considered to apply to this application. A summary of the pertinent
letters is enclosed.
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5. Although the type of test fuel used and/or its effect on the
device were not addressed in either this or your original application,
your previous concern about the proper test fuel is considered to be
incorporated in this application.
6. As we have previously stated, we consider all pertinent data in
the evaluation of a device. Therefore, we consider the test results from
all six-vehicles, rather than just the last three, to apply to this
application.
7. Thus, since it appears we do not require further information, we
consider your application to be complete and are now processing it.
In our prior evaluation of the device we concluded that neither the
information supplied nor our own literature search provided a reasonable
theoretical or technical basis to support the conclusion that the device
might improve fuel economy or emissions. This application provided no
new technical information to alter this conclusion.
The analysis of the data indicates that the key item, the test
results from recognized independent laboratories using the proper test
procedures, do not show a clear or consistent pattern for the device.
The April 1982 test of one vehicle at SCI with Indolene showed no
benefit. The April 1983 tests of two vehicles at Fairway with commercial
unleaded demonstrated no benefit. The December 1983 tests of three
vehicles at Fairway with commercial unleaded indicated that there may be
a small benefit. Furthermore, there is insufficient data to separate
differences attributable to changes in the various test programs (e.g.,
mileage accumulation or fuel type) from differences due to the device.
Explanations offered for these inconsistencies are unsupported by
sufficient data to permit a conclusion. However, it appears that the
data is sufficient to justify EPA proceeding with confirmatory testing,
the next step in the evaluation process.
As you are aware, EPA is now required to charge for this testing.
Based on the available information for your device, we anticipate that we
will need to test up to five vehicles (replicate tests with and without
your device). To reduce costs we would test only with commercial
unleaded, thus the fuel question would not be resolved. Also, the
vehicles would be tested with at least 1,000 miles rather than at
different mileage intervals. Again this would not resolve the mileage
issue but would remove it as a test variable. To further minimize test
cost we will try to supply most of the test vehicles; however the
required testing will still cost up to $18,000.
Thus, at this time, we consider your application complete but we
cannot now proceed with our evaluation without positive action on your
part to fund the necessary confirmatory testing. Please let me know by
March 1, if you desire to proceed and will pay the required costs. We
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WIU then «„!, a test plan £ £« £-£« «„ «%£ "£* /e^lred
transfer of the funds. « ycioseout the evaluation wUh essentially
confirmatory testing, »e «"" "^ ?" that there are Insufficient data
*
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Attachment 1
Attachment 2
Attachment 3
Attachment 4
Attachment 5
Attachment 6
Attachment 7
Attachment 8
Attachment 9
Attachment 10
Attachment 11
POLARION-X
Supplemental Correspondence
Letter of September 1, 1982 from Michael A. Keefe of
Little Buddy Products Company (a consultant to AZ
Products and marketer of the POLARION-X) providing
test results for the device and commenting on the test
fuel.
Letter of September 20, 1982 from EPA to Michael Keefe
of Little Buddy Products Company responding to
preceding letter.
Letter of October 15, 1982 from Michael Keefe of AZ
Industries requesting that the evaluation of the
POLARION-X be halted.
Letter of November 15, 1982 from EPA to Michael Keefe
of AZ Industries informing him that evaluation would
have to proceed.
Letter of March 10, 1983 from EPA to AZ Industries
informing them that device applicants would be charged
for the EPA evaluation testing of devices.
Letter of March 15, 1983 from AZ
acknowledging receipt of preceding letter.
Industries
Letter of May 4, 1983 from Les Adam of AZ Industries
which stated that the POLARION-X had been recently
tested by Fairway Environmental Engineering (at the
request and expense of AZ Industries). This data was
to be submitted to GARB to support an exemption
request. Note, no data was provided with this letter.
Letter of May 16, 1983 from EPA to Ted Schoenberg, a
consultant of AZ Industries, providing him a package
of information regarding device evaluations.
Letter of May 24, 1983 from Ted W. Carlson of Fairway
Environmental Engineering to EPA discussing screening
test of vehicle for a POLARION-X test program.
Letter of May 25, 1983 from Les Adam of AZ Industries
to EPA that forwarded preceding test plan letter - co
EPA and requested comment.
Letter of May 27, 1983 from EPA to Les Adam of AZ
Industries commenting on preceding test plan.
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Attachment 12
Attachment 13
Attachment 14
Attachment 15
Attachment 16
Attachment 17
Mailgram of October 5, 1983 from Fairway Environmental
Engineering to EPA discussing screening test of
vehicle for a POLARION-X test program.
Letter of October 11, 1983 from EPA to Richard Carlson
of Fairway Environmental Engineering commenting on
test program and vehicle test results.
Test report of December 8, 1983 summarizing POLARION-X
test results for the three test vehicles.
Letter of December 13, 1983 from Richard Carlson of
Fairway Environmental Engineering to EPA forwarding
preceding test results.
Letter of December 19, 1983 from Les Adam of AZ
Industries to EPA submitting an application for a 511
evaluation of the POLARION-X device. Accompanying
Speedimemo of the same date noted that this
application was a photostatistically reproduced copy
of the original application of October 14, 1981.
Letter of January 3, 1984 from Les Adam of AZ
Industries to EPA that provided a copy of their test
data booklet on the POLARION-X.
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TM
IHCOHfOMTfD
•TRIES I
wurco I
•Wfl»«^»<>^»o«Bi^r
INDUSTRIES
ATTACHMENT U
28065 DIAZ ROAD. rEMECULA. CALIFORNIA. 92390 • TELEPHONE |7t4) 676-6331
February 23,
Mr. Merri11 Korth
Device Evaluation Coordinator
Test and Evaluation Branch
United States Environmental Protection Agcy.
Ann Arbor, Michigan 48105
Dear Mr . Kor th:
We are in receipt of your letter dated February 6, 1984 .
We would like to proceed with the testing of the Polarion-X
and will pay the required costs of the tests up to the stated
amount of $18,000. We then await your test plan for the
Po1ar i on-X.
Respect fu11y,
Les Adam
Pr es i dent
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ATTACHMENT .V
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\ ±\\/2. " ANN ARBOR. MICHIGAN 48105
*• .4?
March 13, 1984
OFFICE OF
AIR, NOISE AND RADIATION
Mr. LaVern Adam, President
AZ Industries, Inc.
28065 Diaz Road
Temecula, CA 92390
Dear Mr. Adam:
We received your letter of February 23, indicating your
willingness to proceed with the Section 511 evaluation of
POLARION-X by funding the EPA confirmatory testing.
We have developed a test plan which we believe will
appropriately evaluate the effectiveness of your device. All
mileage accumulation will be conducted using established road
routes. All testing will be conducted at our laboratory in Ann
Arbor and you will be charged for all mileage accumulation and
testing. The test plan has been prepared and is transmitted
for your concurrence. Upon receipt of your written concurrence
and the funds to cover test costs, we will begin the actual
testing as soon as feasible.
You will be welcome to observe all phases of the testing
and we will provide you with a complete set of results once our
evaluation is completed. The testing should require a total of
six to eight weeks to complete. Another two to four weeks
should be allowed for us to evaluate the results and to prepare
a technical report. Although EPA does not "approve" devices
under Section 511, you will receive an official notification of
our findings and a synopsis of the test results will be
published in the Federal Register.
Representative passenger cars will be tested first in a
baseline configuration (set to vehicle manufacturer's tune-up
specifications) and second, after the POLARION-X has been
installed. Both test sets will be preceded by 1000 miles of
mileage accumulation on the road. EPA presently intends to
test the device in two phases. In the first phase, three
vehicles will be used. Then, if additional testing is required
to confirm the results, two additional vehicles will be tested.
The tests to be performed are the Federal Test Procedure
and the Highway Fuel Economy Test. These tests are the ones
which result in the published values for city and highway fuel
economies. Each of these tests will be performed at least two
times at each test point to increase the confidence in the
results. You should find the remainder of our test procedure
to be described in sufficient detail in the enclosed test plan.
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If you believe either the mileage accumulation distance or
procedure will not adequately prepare the vehicles for the
testing, please inform EPA immediately and provide
documentation to justify alternative recommendations.
If you concur that the results of testing conducted in
accordance with this test plan will accurately reflect the
effectiveness of your device, please sign the agreement portion
and return the document with the funds to cover the test costs
to EPA by March 31, 1984. The signed test plan should be
returned to EPA, Ann Arbor. The funds in the amount of $18,000
for the test program should be sent to:
Mr. Richard Ruhe
U.S. Environmental Protection Agency
Accounting Operations Office
Cincinnati, OH 45268
and made payable to:
U.S. Environmental Protection Agency
We have established an account there to process these
funds. Any excess will be returned to you.
We will provide you the specifications of the commercial
unleaded fuel to be used for this program. You will be
notified of the testing schedule as soon as possible. You
should also be aware that the EPA reserves the right to conduct
any additional testing which may be necessary to resolve
questions arising from the basic test program. This is
required by the regulations under 40 CFR 610.
Please let me know by March 31, 1984 whether or not you
concur with the Test Plan and Tqst Agreement.
Edward Earth is the project engineer who will perform the
EPA evaluation of POLARION-X. However, I will remain your
official point of contact within EPA. If you have any
questions or require further information before returning the
agreement forms, please contact me at (313) 668-4299.
Sincerely,
Merrill W. Korth
Device Evaluation Coordinator
Test and Evaluation Branch
Enclosure
cc: Pat Brower
Ted Schoenberg
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ATTACHMENT W
LAW OFFICES
PETER M. ROSEN & ASSOCIATES
29373 RANCHO CALIFORNIA ROAD
P.O. BOX 1819
TEMECULA, CALIFORNIA 92390
M. ROSEN JUly 30, 1985
JEFFREY C STEARNS J
JOYCE E. FLEMING
THOMAS S. HUNTINGTON
OF COUNSEL
RICHARD A. MUENCH
Merrill W. Korth
Device Evaluation Coordinator
U. S. Environmental Protection Agency
Ann Arbor, Michigan 48105
RE: A-Z Industries, Inc.
POLARIAN-X
Dear Mr. Korth:
I am writing on behalf of A-Z Industries, Inc to express and put
on record their comments and protests of your evaluation of the
Polarian-X as contained in the EPA Draft report by Edward Earth,
dated April 1985.
The first comment in the report that A-Z takes issue with is the
statement on page 8:
"The applicant did not provide a sound technical basis to
believe the POLARIAN-X has a beneficial effect on the
emissions or fuel economy. EPA is not aware of any
information that demonstrates that magnetically treating the
fuel will affect emissions or fuel economy. The applicant
was unable to provide a technically sound theoretical
explanation that adequately described the beneficial effects
of the device."
Despite numerous attempts by A-Z to provide scientific and
technical explanations for the operation of the Polarian-X the
EPA apparently refused to crive credence to any of the theories
advanced. A-Z candidly admitted that the scientific reasons for
the operation of 'the POLARIAN-X ma.y bg difficult to explain and
that its operation is based upon theories. It appears that the
EPA focused on that statement rather than aivina credence to the
theories advanced.
One of the theories for explaining the operation of maqnets on
hydrocarbon fuels, advanced by A-Z, was that propounded by J.D.
Van Der Waals, Phd in physics, as follows:
"Electrons orbiting around the nuclei of
atoms have di-poles which are in a neutral state.
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29
However, these di-poles may be affected by magnetic
and electric forces which appear to cause deflection.
A simple form of hydrocarbon fuel is pentane C^E ^2.
Hydrogen has a cage-like structure and has a tendency
to interlock with other elements, not forming other
compounds, but temporarily forming 'pseudo
compounds.1 When these 'pseudo compounds' are
influenced by electric and magnetic fields there is
pronounced interlocking with oxygen causing better
combustion. "
I believe A-Z supplied you with the basics of this theory, as
well as other theories propounded by other scientists. Some
other literature, which I believe was supplied, included studies
on the subject of the magnetic treatment of water for removing
impurities. That literature also included descriptions of
devices used in purifying water similar in operation to the
Polarian-X and included detailed discussions of the theories upon
which those devices are believed to work. See for example the
article written by James F. Grutsch, Director of Environmental
Technology Standard Oil of Indiana and J. Warren McClintock,
Engineer Environmental Control, AMOCO Oil Company entitled
"Corrosion and Deposit Control in Alkaline Cooling Waters Using
Magnetic Water Treatments at AMOCO's Largest Refinery." I am
enclosing another copy.
There is a suspicion on the part of A-Z that you and the EPA .have
a preconceived bias against such magnetic devices based solely
on the fact that the precise explanations for how such devices
work are based upon scientific theories rather than any clearly
visible mechanical operation. Again on page 15 of the EPA
report, in evaluating the test results, the report says "EPA is
unaware of any information that provides a technical basis to
support the claim for improved emissions and fuel economy for an
in-line fuel magnet device like POLARIAN-X".
The report notes that the test results on the device prior to
this last EPA test are not consistent. This is quite apparent
and is explained by the fact that the various test were all
different. For example, there was no mileage accumulation test
on the tests conducted for the California Air Resources Board,
and indolene was used on the SCI laboratory tests and dynometers
were used rather' than actual mileage.
Bssnl£s Qf. AJJL T
Nevertheless, the EPA report fails to discuss all of the prior
test, most notably the testing done at Transportation Testing,
Inc in Texas, which showed fuel improvement increases of from
5.18% to 18.10%. The report does take note that a total of 33
cars have had the units installed for testing purposes, but the
report fails to mention that out of those 33 cars tested 29 cars
showed various degrees of. positive results.
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EPA
Even granting that all those prior test result may be
inapplicable for EPA purposes, that should not be true for the
EPA 511 testing done by Fairway Environmental Engineering in
1983. This was a test approved by you and according to the
information I have, Fairway Environmental is one of several
independent testing companies authorized by the EPA to conduct
EPA Section 511 tests. It is also my understanding that the
tests conducted by Fairway are the same as the tests conducted by
you.
Yet Fairway's test results for its EPA 511 test for three cars
(Fairway Environmental Test Reprt dated December 8, 1983) showed
positive mileage gains with the POLARIAN-X of +5.4%,+ 5.8% and
+ 4.7% on the city driving test (LA- 4 test) and of +2.9%, +6.7%
and +4.0%E on the Highway Fuel Economy tests (HFET), whereas your
test shows no positive results for either the LA-4 test or HFET
test on any of the three vehicles tested by you. Similarly
Fairway's tests showed decreases in all categories of emissions
and decreases of from -1.0 to -65.1 for both tests except for a
small increase in hydrocarbons on the highway test for one car
(+6.3) and an even smaller increase in NOx emissions on the city
driving test for the same car (+2.7). All the other emissions
tests for the Fairway Test showed decreased emissions with the
Polarion-X. The average percentage decreases in emissions for
all three cars were from 3.8% to 46.4%. EPA's test on the other
hand showed either very slight increases in emissions or very
slight decreases.
lDd.gBgpd.SDt E.PA.r.511
Why the inconsistency? Is there something wrong with Fairway's
testing procedures? Again, even if we discount all the positive
results shown from ail the non-EPA 511 tests, is it fair to
apparently totally disregard the positive result achieved by
Fairway's 511 test?
We have had discussions with Fairway, and it is their opinion
that the differences in the results of their test and yours are
quite significant. They are at a loss to explain the divergence.
They attest to the correctness of their testing procedure and
claim that their equipment is correlated with yours. In
discussions with Ted Carlson at Fairway he said that he and his
engineers took special interest in testing of the Polarian-X
because they also were skeptical of the device. Because of their
skepticism he aid that they did additional testing which is not
on their EPA 511 report. They ran 15 different tests, and that
on every test there was at least some favorable results.
A-Z Industries has put a lot of time and money into the testinq
of the Polarian-X, and they believe in their product. Under the
circumstances it seems only fair and equitable that the
inconsistency between the two EPA 511 tests be able to be decided
by a third EPA 511 test by a different independent laboratory
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31
approved and certified by the EPA as qualified to do a 511 -test.
A-Z would, of course, have to bear the additional expense, but
they would be willing to abide by the result if the EPA would
also agree to abide by the results of such a third independent — a
tie breaker, as it were — and that the EPA would include such
results in any published EPA reports on the Polarian-X.
Even if there is no administrative procedure for requiring such
agreement to additional testing on the part of EPA, please
consider this a formal request for such action. Even if there is
no such formal procedure or even precedent, for such action,
there should be the flexibility to find a way to accomplish it,
and again A-Z will fund it and will abide by it unequivocally.
Please seriously consider this request and if there is anything I
can do or anyone I can contact to help bring it about, please let
me know.
Sincerely,
THOMAS S. HUNTINGTON
TSH:mjr
APPROVED: A-Z INDUSTRIES
By:
/LBS--ADAM, President
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