EPA-AA-TEB-511-87-1
EPA Evaluation of the Emission Control Device
    of DeAcc  Devices  Inc.  (DeAcc BCD)  Under
 Section  511  of the Motor  Vehicle  Information
             and  Cost  Savings  Act
                     by

             Edward Anthony Earth
                  June 1987
          Test  and  Evaluation  Branch
     Emission Control  Technology  Division
           Office of Mobile  Sources
     U.S.  Environmental  Protection Agency

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06560-50]
              ENVIRONMENTAL PROTECTION AGENCY
                      [40 CFR Part  610]
                  [AMS-FRL
                FUEL  ECONOMY RETROFIT DEVICES
  Announcement  of Fuel  Economy Retrofit  Device  Evaluation
for the "Emission Control Device" of DeAcc Devices, (DeAcc
ECD)
AGENCY:    Environmental Protection Agency (EPA).

ACTION:    Notice of Fuel Economy Retrofit Device
Evaluation.

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SUMMARY:    This  document  announces  the  completion  of  the

EPA evaluation  of  the DeAcc ECD device  under  provisions of

Section  511  of the  Motor  Vehicle  Information  and  Cost

Savings  Act..   The  notice  also  announ:es  our  findings,

conclusions, and the availability of the 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
Telephone: (313) 668-4299
SUPPLEMENTARY INFORMATION:



I.    Background



     Section  511(b)(l)  and  Section  511(c)  of  the  Motor

Vehicle  Information   and   Cost  Savings  Act   (15  U.S.C.

2011(b)) requires that:



(b)(l)  "Upon application  of  any manufacturer of a retrofit

device  (or  prototype  thereof),  upon  the  request  of  the

Federal  Trade  Commission pursuant  to  subsection   (a),  or

upon his own  motion,  the EPA Administrator  shall  evaluate,

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in accordance  with  rules  prescribed  under  subsection  (d),  '



any retrofit device  to  determine  whether the retrofit device



increases  fuel   economy  and  to   determine  whether   the



representations (if  any)  made with  respect  to  such retrofit



devices are accurate."







(c)   "The  EPA  Administrator  shall  publish  in the  Federal



Register  a summary  of  the  results of  all tests  conducted



under  this section,   together  with  the  EPA  Administrator's



conclusions as to -







     (1)   the effect of any retrofit device on fuel economy;







     (2)   the effect of  any  such device on emissions of air



           pollutants; and








     (3)   any  other  information  which  the  Administrator



           determines  to  be  relevant  in  evaluating  such



           device."







     EPA published final  regulations establishing  procedures



for conducting  evaluations  of fuel  economy retrofit devices



on March 23,  1979 [44 FR 17946].

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II.  Origin  of  Request  for  Evaluation,  Device  Descriptions
and Report Identification:

     On February  7,  1986, the EPA  received  a  request  from
DeAcc  Devices,  Inc.   for evaluation  of the  DeAcc  ECD  as  a
fuel  saving  device   with reduced  emissions.   This  device
consists  of  a small gas mixing chamber  with lines that are
connected  to  the   air   intake,   exhaust  manifold,  intake
manifold  and  PCV  valve of the engine.  The device is claimed
to  reduce emissions  and  improve  fuel economy by  completely
burning the blow-by gases.

     Report:  "EPA Evaluation  of  the Emission Control Device
of DeAcc  Devices,  Inc.  (DeAcc  ECD)  Under Section 511  of the
Motor  Vehicle  Information and  Cost  Savings Act".   Report
Number  EPA-AA-TEB-511-87-1    contains   the   analysis   and
conclusions and consists of 17 pages plus attachments A-Q."

     As  part  of  the  evaluation   process,   the  applicant
conducted screening tests  at an  independent laboratory using
EPA approved  protocols.   This  independent laboratory testing
is described in this  report.

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Ill.  Availability of Evaluation Reports



     Copies of this report may be obtained  from the National

Technical  Information  Service  by  using  the  above  report

numbers.  Address requests to:
     National Technical Information Service
     U.S. Department of Commerce
     Springfield, VA  22161
     Telephone:  (703) 487-4650 cr FTS 737-4650

IV.  Summary of Evaluation
     EPA  fully  considered  all  of the  information submitted

by  the   device  manufacturer   in   the  Application.    The

evaluation  of  the  DeAcc  ECD was  based on  that  information

and the  results  of the  screening  tests conducted for  the

applicant  at  an  independent laboratory using EPA approved

protocols.  These tests  consisted of replicate'Federal  Test

Procedure  (FTP)  and Highway Fuel Economy Test  (HFET)  on two

vehicles both with and without the device.



     The  FTP  and  HFET  test  data  were  analyzed  by  the

analysis  of  variance  (ANOVA) technique to  determine  if  the

data  indicated  that  there  was   a statistically  significant

difference in emissions  or fuel  economy due to  the  device.

For  the  FTP  and   HFET,  although  the  device  reduced  NOX

emissions, there  was  an  increase  in FTP CO  emissions  and a

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fuel economy  penalty  for  the FTP.   The HFET  CO  emissions
indicated an  overall  improvement;  however,  one  of the  two
vehicles showed  an increase  in  CO emissions.   The  increase
in HC  emissions  for both driv.ng  cycles and changes  in HFET
fuel   economy   for  the   device   were   not   statistically
significant.

     Since  vehicles   are   designed  to   meet   the  emission
standards  for  HC,  CO,  and  NOX,  our policy  in  evaluating
emissions and/or  fuel  economy devices is that  a  device must
not show an adverse effect  in any  emissions  and  fuel  economy
tests  and  second  must   shov   a  significant  improvement.
Clearly, the  DeAcc device  did  not  pass these criteria  and
thus,  EPA did  not  proceed to  the in-house testing  phase.
The  NOX  reduction with   the   device  can   reasonably  be
attributed  to  the  increase in  exhaust  gas  recirculation
(EGR)  rather than  the  postulated  catalytic reactions  in the
copper  line  of  the  device.  This effect  on  NOX could be
achieved by recalibrating the EGR valve.

The  overall  conclusion  is  that  the  DeAcc  device did  not
improve emissions  or fuel economy.
Date                         J. Craig Potter
                             Assistant Administrator
                             for Air and Radiation

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                              8
EPA Evaluation of the  Emission  Control  Device of DeAcc Devices,
Inc.   (DeAcc  ECD)  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 "DeAcc  ECD"  was conducted  upon the
application of the  manufacturer.   The  device  is  a  small  gas
mixing  chamber with  four  lines that are  connected to  the air
filter, exhaust manifold, intake manifold, and  PCV valve of the
engine.  The   device  is claimed to  improve  fuel economy  and
control emissions.

     1.    Title:

           Application  for  Evaluation of  the  Emission  Control
           Device  of  DeAcc  Devices,  Inc.   (DeAcc  ECD)  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 and Marketing Information:

           a.     Marketing Identification of the Product:

                 "Emission Control  Device"  and DeAcc  Devices,
                 Inc.   will be used for manufacturing.

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            Inventor and Patent Protection:

            (1)    Inventor

                  Stephan DePakh,  President
                  DeAcc Devices Inc.
                  90 Warren Road
                  Suite 110
                  Toronto, Canada M4V 2S2
                  Telephone (416)  923-1248

            (2)    Patent

                  US. Patent Number:   4,512,325
                  Canadian Patent Number:  1,174,920

            Applicant:

            (1)    Name and address
                  DeAcc Devices, Inc.
                  90 Warren Road
                  Toronto, Canada  M4V 2S2

            (2)    Principals
                  Stephen DePakh,  President and owner
            (3)   Stephen   DePakh    is    authorized    to
                  represent   DeAcc    Devices    Inc.    in
                  communication with EPA

      d.   . Manufacturer of the Product:

            (1)   Name and address

                  DeAcc Devices, Inc.
                  90 Warren Road, Suite 110
                  Toronto, Canada M4V 2S2
            (2)   Principals
                  Stephen DePakh, President and owner

3.     Description of Product:

      a.     Purpos.e:

            Auto emission control and fuel economy

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                    10
b.    Applicability:

      "The  applicability  of  the device  is for  all
      makes,  all  models,   all  engine   sizes   and
      carburetion, all  model-years,  all  transmission
      types, all ignition types."

c.    Theory of Operation:

      The applicant used  the US Patent  abstract  for
      the  device  to  explain  the  device  theory  of
      operation.

      "This  invention  provides  the combination  of  a
      gas-mixing  chamber,  and  a first  conduit  con-
      nected to the crankcase of  an  engine and pass-
      ing  through the chamber   in  noncommunicating
      fashion, the conduit then  extending out  of the
      chamber   and  returning   to   open   into   the
      chamber.  The first conduit is  of  copper or at
      least  has its   inner  wall  made of  copper.   A
      second  conduit  leads  from  the  chamber  and
      connects   to  the   intake  manifold  of   the
      engine.    A  third   conduit   leads   from  the
      chamber   and  receives  heated   gas  from  the
      exhaust  pipe or  manifold.   A  fourth  conduit
      leads  from the  mixing chamber  and is  adapted
      for  connection  to  the   air   filter  of  the
      engine."
                42

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                         11
      d.     Construction and Operation:

            "The device has  a  simple  design  and it can  be
            affixed  anywhere  in  the  engine  compartment.
            It has  no moving  parts  (see  above.)   It  has
            one  control  valve  #42  manually  adjustable.
            The  device  allows  the engine  to  operate  at
            peak  capacity  with  no  loss  of  power.    The
            performance of  the engine  is more  responsive
            and  smoother.   It  does not  require  additional
            fuel to  reburn  the  unused  gases  and  vapours
            and  operates  at peak  efficiency,  both  during
            acceleration  and  deceleration.    Due   to  the
            total  combustion  afforded,   the  emission  of
            pollutant  reduction  is  up  to  total   and  no
            carbon  deposits  remain  on  pistons,   valves,
            etc.,  automobile and  like  engines,  and  there
            is fuel saving."

      e.     Specific Claims for the Product:

            This  information  was  not  provided  with  the
            application.

      f.     Cost And Marketing Information:

            This information was not provided with  the
            application.

4.     Product Installation, Operation, Safety and
      Maintenance:

      a.     "The first  conduit is  connected  to the  crank
            case (P.C.V.);

      b.     The  second  conduit  leads from the  device gas
            chamber to the intake manifold;

      c.     The  third  conduit  leads  from the device  gas
            chamber to the exhaust manifold;

      d.     The  fourth   conduit   leads   from  the  device
            mixing gas  chamber to  the  air  filter or  the
            engine;

      e.     The  above  installation instruction is  for all
            make/model/year  engine,  automobiles  and  like
            engines;

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                   12
£.-    Required tools are:

      -screw driver
      -a clipper for a hole to be clipped on the air
       filter for the fourth conduit
      -no required equipment to check the
       installation
      -mechanical efficiency emission test to
       balance the carburetion with DeAcc Device
       (air fuel, mixture fuel).
      -no special skills required with the
       installation of  the device, a mechanic can
       do it."

g.    Operation:

      "To assure efficiency  and mechanical  operating
      efficiency,  instructions  will  be furnished for
      its usage.

      (1)   Pre-tune the engine to the
            manufacturer's requirements,

      (2)   A lean  condition in the engine is caused
            by excess air  or too little  fuel  in the
            cylinders   to   promote   complete   com-
            bustion.    This   condition   lowers   the
            power  output  of  the  engine  and'  that
            condition is one  of  the  major sources of
            air  pollution of  an  automobile  engine,
            and there is no gas saving.

      (3)   Proper vehicle maintenance will decrease
            the  amount  of gasoline  that  is consumed
            and  reduce  the amount of  pollutants and
            a DeAcc Device,  will  also save more fuel
            and depollute the engine."

h.    Effects on Vehicle Safety:

      "The  device  has   no   malfunction  or  unsafe
      condition  to  the  automobiles  or -its  occupants
      or persons  or property  in  close  proximity to
      the automobile."

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                         13
      i.     Maintenance:

            "To  ensure  continued  correct  operation,  the
            DeAcc Device does not  require maintenance.   At
            the  regular  engine  tune  up,   emission  test
            required  to  ensure  that  there  is  no  lean
            condition in the carburetior. system."

5.     Effects on Emissions and Fuel Economy:

      a.     Unregulated  Emissions:

            This  information was  not  provided  with  the
            application.

      b.     Regulated Emissions and Fuel Economy:

            "The applicant  emission  control  device  has  no
            malfunction   to   emit  pollutant   like  hydro-
            carbons,  carbon   monoxide,   or   oxides   of
            nitrogen.   The   device   treats   the  "blow-by
            gases"  to  be   reburned   ar.d  therefore  normal
            atmospheric    constituents   such   as   carbon
            dioxide-water  vapour  in  a  quantity  differing
            from  that  emitted  in  the  operation  of  the
            automobile engine without the device."

      c.     Test Results:

            "Provided all   information  on the  effects  of
            the  device  on   vehicle emissions   and  fuel
            economy.

            (1)   The  technical  question   of  "catalytic
                  action"    of   No.  '34   (drawing  figure)
                  somewhat more difficult to  answer,  but I
                  would  like to make the following points:

            (2)   It  was   thought  at one  time  that  the
                  "catalytic   action"   to    be   due  .to
                  reduction  of  NOX  gases to  nitrogen  by
                  Cu-tubing  with  subsequent  oxidation  to
                  CuO  or   C.u.2   0',   thus   causing  some
                  decrease    in   NOX,    or    interaction
                  through   the  loop   between  HCs  and  NOX

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                              14
                       to  N.2/S.   I  would  like  to  point  out
                       that the device, while saving  fuel,  does
                       not increase NOX  2/S.  My  tests  for  CO
                       at  the  exhaust  while the  engine  is  in
                       idle show a large decrease in CO.

                 (3)   The  length of  No.   28  (drawing  figure)
                       are to  control direct  flooding  and  the
                       air/fuel    (blow-by    gases)     mixture
                       entering  the   cylinders  has  no  adverse
                       effect.      Under     deceleration    and
                       acceleration of  the  engine,  the  length
                       of  No.  28  eliminating  direct  flooding
                       and not lower  power  output  of  the engine
                       and show  a large  decrease of  pollutant
                       emission   gases;   therefore,    it   saves
                       gasoline."
The following  Sections  are EPA's  analysis  and conclusions  for
the device.
     6.     Analysis

           a.    Identification Information:

                 (1)   Marketing  Information:    The   marketing
                       identification of  the product,  Emission
                       Control Device (Section 2a)  is  a generic
                       name  for  a  class of  products   and  thus
                       could  lead to confusion.   Therefore,  to
                       avoid  confusion,  EPA  will  identify  the
                       product as  the Emission  Control  Device
                       of DeAcc Devices,  Inc., or DeAcc ECD.

                       EPA  requested the  applicant to clarify
                       how  a  vehicle owner  would  obtain  the
                       device  (Attachment  F).    The  applicant
                       stated  that   it  would be  sold  through
                       vehicle  service   and   installation  shops
                       (Attachment G) .

           b.    Description:

                 (1)   The  primary  purpose  of   the device  was
                       clarified  to  be  to  improve".... emission
                       and  fuel  economy  by  recycling  the  so

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             15
      called blow  by gases  and  use  it  as  an
      added fuel  with  the  engine  system  and
      reburn it  in the  combustion  process  in
      the   individual   cylinders,   with   the
      emission     gares:      CO,     HC,     NOX"
      (Attachments F ind G).

(2)    Applicability.   The applicability  of  the
      device,   as  seated  in  Section   3b  to
      essentially   all   carbureted,   gasoline
      powered   vehicles    is   judged   to   be
      reasonable.   That  is,  it is  possible  to
      install the device on these  vehicles.

(3)    The theory of operation  given in  Section
      5(c)   describes  the  device  but does  not
      provide  a  theory of  operation.   The  US
      patent Section  2b(2),  Attachment  A,  and
      Construction and Operation  Section 3d do
      not give  a  clear  and concise  explanation
      of how the device  functions  and  how  it
      is an improvement over a PCV  valve.   EPA
      requested     additional     clarification
      (Attachment   F).     However,    the   in-
      formation  provided  indicates  that   the
      device functions similar to the  standard
      PCV  valve,  i.e.,  both  recyle  crankcase
      gases into  the  intake manifold  through
      the   PCV   valve  (Attachment  G) .    The
      applicant  considers  catalytic  reactions
      in  the  copper  tube  to   be  plausible
      explanation   for   the   reduction    of
      nitrogen  oxides  to  nitrogen.   However,
      the  additional  EGR  obtained  by  tapping
      the   exhaust   manifold  gases  and   the
      possible  changes  in  fuel/air ratio  due
      to bleed-air  of  the  device  are  a  more
      probable   cause   for  any    changes   in
      nitrogen  oxides observed.

(4)    The  description of  the  device  provided
      by the patent,  figures,  and installation
      information   adequately   describes   the
      device design.

(5)    Specific    claims   for   device:     The
      application  made   no  claims  for   the
      device other  than  auto  emission  control

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             16
      and  fuel   economy.   EPA   requires   this
      information  in  order   to   judge   the
      efficacy of  a  device  and  develop  test
      plans.    Therefore,  we   requested   the
      applicant   to  state his  specific  claims
      for the  device  including  the  improve-
      ments   in  emissions  and   fuel   economy
      (Attachment F).

      The applicants  response:

            "The  improvements are in  emission
            and   fuel  economy  by  recycling  the
            so called  'blow by  gases'   and  use
            it as an  added  fuel  with  the  com-
            bustion  process  in  the  individual
            cylinders   ,   with    the   emission
            gases:   CO,  HC,   NOX"  (Attachment
            G).

      did  not provide  specific  criteria  to
      judge  the  performance  of  the   device.
      However, this   was discussed with   the
      applicant  and he stated that  he  expected
      the device to  achieve  better than   a  6
      percent  improvement  in   emissions   and
      fuel  economy.    The  test  plan  for   the
      independent  laboratory  testing   of   the
      device  was developed using six  percent
      as the  criteria  in selecting  the number
      of   vehicles    and  number   of  tests
      (Attachment F).

(6)    The  cost   of  the  device  plus  install-
      ation:   In response to the EPA  request
      for cost information (Attachment  F),  the
      applicant  provided a detailed  listing of
      the  manufacturing   costs.   The   retail
      cost of  the  device was  projected to be
      initially  $97,  dropping to  $78 in volume
      production.    However,     as   discussed
      further  in  Section  6c(l)  below,   the
      installation    of   the    device  would
      probably take several hours rather  than
      the few minutes the applicant suggests.
      Since  installation  is  to  be  done  by  a

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                   17
            mechanic    or    service    shop,     the
            installation  cost  would  probably  range
            from  $60  to  $90 depending  on time  and
            labor rates.

c.     Installation,  Operation,  Safety and
      Maintenance:

      (1)   Installation  -  Instructions,   Equipment
            and  Skills  Required:   The  installation
            information provided  in  Section  5c(l)  is
            only  an  overview,  therefore,  additional
            and  expanded   information  was  requested
            and  provided  (Attachments  F   and  G) .
            This  information  was  in  much  greater
            detail and  was  consistent  with  earlier
            information.   However  these  instructions
            present  some inherent problems.

            First,  few  vehicles  have  a  convenient
            access  port  to  tap   as  the  source  of
            exhaust   gas  required  by   the   device.
            Only  a  few  older   vehicles   used  the
            manifold  choke  tube  suggested   as   a
            source  of  exhaust  gas.   The  EGR  valve
            would also be a poor  choice because  of
            the   difficulty   in  tapping   into  the
            exhaust   gas   at  this  point   and  the
            adverse  effect  any added plumbing  would
            have  on  the  calibration of  the  valve.
            The  suggested method  of  welding a pipe
            or fitting to manifold presents  several
            problems.    The  applicant   provides  no
            guidance  as  to  the  proper  functional
            (location  for proper  exhaust gas  flow)
            or mechanical  location of this  port.   A
            poor  mechanical   choice   could   lead
            to warped/damaged   exhaust    manifolds.
            Drilling an exhaust gas  port  through the
            welded fitting  or  drilling  and  tapping
            the  manifold  create a potential  problem
            with  the  drill  filings  if  the  manifold
            is not  removed,  since the filings  could
            lodge in the  EGR valve and/or enter the
            induction system through the  EGR valve.

            A    second    problem    is    the    proper
            adjustment of the manual valve  installed
            in the line connecting the device  to the
            air   filter.    Any   vehicles    using
            closed-loop  (feedback)  control   of  the

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             18
      engine/fuel   induction   system   operating
      conditions     during     idle-deceleration
      would tend  to  automatically  compensate
      for  these adjustments.

      The    instructions   provided    in    -he
      application   and  correspondence  need  to
      be organized  and put  into  a  formal  •: et
      of    installation    instructions     -"or
      enclosure with the device.

      In past  discussions,  the  applicant  has
      indicated  that   the   device  could   be
      installed in  a  few minutes.    EPA  judged
      this    to    be   unlikely    with    the
      installation  and  mounting   of  the  jas
      mixing   chamber,   connecting  the   four
      ports  of  the  chamber  to  the  engine
      (including   the  exhaust manifold),   and
      adjusting the system  with  an  emission
      analyzer.   Several  hours   is  a   more
      reasonable  estimate and was  borne  out in
      testing (Attachment M).

(2)    Operation:   The applicant's  statement in
      Section  4(g)  that the device  functions
      automatically  for the  driver   is  judged
      to be correct.

(3)    Effects on Vehicle Safety:   Based  on the
      patent   application    description    and
      installation  information provided,  it is
      possible for the  device to be  fabricated
      and  installed  so that  it  is  safe  in
      normal vehicle  operation.    However,  as
      noted in Section  6c(l)  above,   there are
      potential  problems   in  obtaining   the
      source of  exhaust gases  by tapping  or
      welding  the  exhaust  manifold  that  were
      not  addressed by the  applicant.

(4)    Maintenance:    The maintenance  require-
      ments of Section  4d  was clarified  to be
      that   essentially no   maintenance   was
      required  (Attachments   F   and   G).    The
      applicant anticipated that only the idle
      CO   emission   checks  performed  during
      tune-ups. would  insure  that  the  system

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                              19
                       continued    to     function     properly.
                       However,   this   does  not   address   the
                       possible plugging  of  the  extensions  of
                       the  PVC  line  to  the  device  and  the
                       induction system.

           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  in  Section  5
                       relate  to  regulated emissions  and  fuel
                       economy only.  However,  since  the design
                       and  installation of   the  device  limits
                       its   effects   to  moderate  changes  in
                       fuel/air   ratio,  exhaust   gas   recir-
                       culation  (EGR),   or  positive   crankcase
                       valve  flows,  then the device  should not
                       significantly    affect    a    vehicle's
                       unregulated emissions.

                 (2)   Regulated Emissions and Fuel Economy:

                       The   applicant   submitted   test   data
                       conducted  at  an independent  laboratory
                       in  accordance   with   the  Federal  Test
                       Procedure  and the  Highway  Fuel Economy
                       Test.   These two test  procedures are the
                       primary  ones    recognized   by  EPA  for
                       evaluation of  fuel  economy and emissions
                       for light duty vehicles.*

                       The tests  consisted  of replicate FTP and
                       HFET tests on  two vehicles both with and
                       without the device (a total of  8 tests).
*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
in  tests   conducted  by  the  applicant   at   an  independent
laboratory.   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.

-------
       20
The FTP and HFET  test  data were analyzed
by  the  analysis  of   variance  (ANOVA)
technique  to   determine  if   the   data
indicated that there was  a statistically
significant  difference  in emissions  or
fuel   economy   due    to   the   device
(Attachmert  P) .    For   the FTP  and  and
HFET,  although  the  device  reduced  NOX
emissions  there  was  an increase  in FTP
CO  emissions  and  a fuel  economy penalty
for  the  FTP.   The  HFET  CO  emissions
indicated    an    overall    improvement;
however, one  of  the two  vehicles  showed
an   increase   in  CO   emissions.    The
increase   in   HC   emissions    for   both
driving cycles  and changes in  HFET  fuel
economy   for   the   device   were   not
statistically significant.

Since vehicles  are designed to  meet the
emission   standards   for  HC,   CO,   and
NOX,    our    policy    in    evaluating
emissions  and/or  fuel  economy  devices is
that  a device  must  first not  show  an
adverse effect in  any  emissions and fuel
economy  tests  and second must  show  a
significant  improvement.   Clearly,   the
DeAcc device did  not  pass  these criteria
and;  thus,  EPA  did not  proceed to the
in-house   testing   phase.     The    NO*
reduction with the device can reasonably
be  attributed to  the  increase  in exhaust
gas  recirculation (EGR) rather  than the
postulated  catalytic  reactions  in  the
copper  line  of  the device.   This  effect
on    NOX    could   be    achieved    by
recalibrating the EGR valve.

The  applicant  also  submitted  lab  and
road test  data  that indicated  a benefit
for the  device.   Although the  tests may
have been of value to  the  applicant, the
tests  were  conducted  under   relatively
uncontrolled test conditions.

The overall conclusion  is  that  the DeAcc
did   not   improve   emissions   or   fuel
economy.

-------
                              21
     8.     Conclusions

           EPA   fully  considered   all   of   the   information
           submitted  by  the  applicant.   The evaluation  of  the
           DeAcc ECD  device vas based  on that  information  and
           the results of  the screening tests conducted for the
           applicant  at   an  .adependent   laboratory  using  EPA
           approved protocols

           The overall conclusion  is that  the  DeAcc  device did
           not improve emissions or fuel economy.

FOR  FURTHER  INFORMATION  CONTACT:   Merrill W.   Korth,  Emission
Control   Technology  Division,   Office   of   Mobile   Sources,
Environmental Protection Agenjy, 2565 Plymouth  Road,  Ann Arbor,
MI  48105, (313) 668-4299.

-------
                              22
Attachment- A


Attachment B


Attachment C


Attachment D
Attachment E


Attachment F



Attachment G
      List  of Attachments

US Patent  Number  4,512,325 (provided  with 511
Application).

Canadian  Patent  Numbers  1,174,920  (provided
with 511 application).

Letter  of  July  16,  1985  from  EPA to  DeAcc
providing information on Section 511 process.

Letter of  August  12,  1985 from  Stephen DePakh
of DeAcc  Devices,  Inc.  to EPA requesting that
EPA provide test  vehicles and  announcing this
intention to reapply for evaluation.

Letter  of  August  19,  1985 from EPA  to  DeAcc
responding to preceding letter (Attachment D).

Letter  of  April  30,  1986  from  EPA to  DeAcc
requesting    clarification    and    additional
information regarding submitted application.

Letter  of  May 24,  1986  from  DeAcc responding
to  preceding   letter  (Attachment  F) .   Page  2
and the top half of page 3 of  Attachment  G are
not  included  since  they  contained  details of
the manufacturing and marketing costs.
Attachment H
Attachment I
Attachment J
Attachment K
Attachment L
Letter of June  11,  1986 from Automated Customs
Systems  Inc.  to  DeAcc discussing  independent
lab testing of device.

Letter of  July 24,  1986  from Arthur  L.  Smith,
DeAcc  Attorney,  discussing   independent  lab
tests.

Letter  of  July  9,  1986  from DeAcc  to  EPA
discussing   application    clarification   and
independent lab testing.

Letter  of   August   8,   1986   from  DeAcc  to
Automotive    Custom    Systems,    Inc.    (ACS)
discussing  their  independent  lab  testing  of
the device.

Letter of  August  8,   1986  from  DeAcc  to  EPA
discussing the  independent  lab testing  of the
device.

-------
                              23
Attachment M     Letter of September 3,  1986  from ACS  to  DeAcc
                 describing  the   independent  lab   tests   and
                 providing the data.

Attachment N     Letter of October  31,  1986  from DeAcc to  EPA
                 discussing the independent lab testing at ACS.

Attachment 0     Summary  tables  of ACS  lab  tests of  the  DeAcc
                 Device.

Attachment P     Statistical  analysis  of the  emissions and fuel
                 economy results for the DeAcc Device

Attachment Q     Letter of  January 13,  1987  from EPA  to  DeAcc
                 summarizing the analysis of the test.

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                                                Attachment A
States
 The Commissioner of Patents
        and Trademarks

 Has received an application for a patent
for a new and useful invention. The title
 and description of the invention are en-
 closed. The  requirements of law have
 been complied with, and it has been de-
 termined that a patent on the invention
 shall be granted under the law.

 Therefore, this

      United States  Patent

 Grants to the person or persons having
 title to this patent the right to  exclude
 others from making, using or selling the
 invention throughout the United States
 of America for the term of seventeen
 years from the date of this patent, sub-
ject to the payment  of maintenance fees
 as provided by  law.
                 Acting Commissioner of Patents and Trademarks
Attest
                                        a
                                                                   ft-

-------
United States  Patent
DePakh
                                                 [ii]   Patent Number:
                                                 (45]   Date of  Patent:
                                                                                 4,512,325
                                                                              Apr. 23,  1985
[54]
[76]


[21]
[22]
[51]
[52]
[58]
[56]
EMISSION CONTROL DEVICE
Inventor:
            Stephen DePakh, 90 Warren Rd.,
            Suite 110, Toronto, Ontario M4V
            2S2, Canada
 Appl. No.:  588,739
 Filed:      Mar. 12, 1984
 Int. Q.'	 F02M 23/06
 U.S. 0	 123/572; 123/573
 Field of Search 	  123/572. 573, 574, 41.86
            Reference* Cited
      U.S. PATENT DOCUMENTS
3.362,386  1/1968 McMthon 	 123/573
3.846,980 11/1974 DePtlma 	 I23/J73
4.269.607  3/1981 Wtlker 	 123/373

   FOREIGN PATENT DOCUMENTS
  1IJ638  7/1926 Switzerland 	 123/573
     2118861 11/1983 United Kingdom 	 123/573
Primary Examiner—Ronald H. Lazarus
Attorney, Agent, or Firm—Sim & McBurney
[57]               ABSTRACT
This invention provides the combination of a gas-mix-
ing chamber, and a Tint conduit connected to the crank-
case of an engine and passing through the chamber in
non-communicating fashion, the conduit then extending
out of the chamber and returning to open into the cham-
ber. The first conduit is of copper or at least has its inner
wall made of copper. A second conduit leads  from the
chamber  and connects to the intake manifold  of the
engine. A third conduit leads from the chamber and
receives heated gas from the exhaust pipe or manifold.
A fourth conduit leads from the mixing chamber and in
adapted for connection to the air filter of the  engine.

            8 Claims, 1 Drawing Figure
                                   42

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4,512,325
         EMISSION CONTROL DEVICE

  This invention  relates  to devices for reducing the
emission of pollutant gases from reciprocating internal 5
combustion engines.
  It is well known that one of the major sources of air
pollution from an internal combustion engine, particu*
larly in an automobile, are the emission of gases result-
ing from so called "blow-by" of gases between the 10
cylinder wall and  piston rings into the crankcase. Such
gases have  commonly  been vented to atmosphere
through a suitable vent pipe.
  In order to solve the problem of air pollution result-
ing from the above  source, it has been  proposed to 15
couple the vent pipe  leading from an  engine crankcase
to the intake manifold where vacuum conditions nor-
mally exist. Thus the pollutant gases are immediately
drawn back into the intake manifold of the engine and
are burned in the  combustion  process in the cylinders.  20
  However, due to varying vacuum conditions in the
intake manifold of an automobile engine, devices of
known type have  not proven successful. Typically, for
example, a greater amount of blow-by is liable to occur
during acceleration of the engine. Simultaneously, how- 25
ever, vacuum  in  the intake manifold decreases thus
reducing the capacity of the engine  to draw in the
crankcase emissions.  Also the addition of crankcase
gases to the charge fed to the engine disturbs the air/f-
uel mixture entering the cylinders with adverse effects. 30
  Further, some prior art devices, in addition to leading
crankcase emissions directly into the intake  manifold,
have provided an air intake to the crankcase so that
under condition of high vacuum, air could be drawn.
through the crankcase to ventilate it. However,  such 35
systems are considered dangerous due to the possibility
of creating an explosive mixture of gases in the crank-
case.
  According to the present invention, in order to ap-
proach a solution to the  above problems of prior art 40
devices, there is  a provided, in combination: means
defining a gas-mixing chamber, a first conduit having
one end adapted for connection to the crankcase of an
engine,  the primary conduit passing  in  non-com-
municating fashion through said chamber so that gases 45
in said chamber contact the outside of the conduit, the
conduit opening at its other end into said chamber, the
first conduit being such that its inner wall is of copper,
a second conduit leading  from said chamber and being
adapted for communication with the intake manifold of 50
the engine, a third conduit leading  from said mixing
chamber and receiving a gas which has been heated by
exhaust  heat, and a fourth conduit leading from said
mixing chamber and  being adapted for connection, to
the air filter of the engine.                           55
  The invention is illustrated schematically in the at-
tached drawing, which shows an internal combustion
engine in plan, together with the various components of
the accessory provided  by this invention.
  In the FIGURE, an  engine 10 is seen in plan, and 60
includes a head and a crankcase one  above the other,
such that they are in alignment in the view of the FIG-
URE. An exhaust manifold 12 and an intake manifold 14
of the usual construction are provided, the exhaust
manifold 12 emptying into an  exhaust pipe 16. and the 65
intake manifold 14 being connected by a short pipe 17 to
a carburettor/choke device 18. A line 20 extends from
the choke of a carburettor/choke 18, and passes into
        and along the exhaust manifold 12, ultimately opening
        at the location 22 through the wall of the exhaust mani-
        fold  12. The line 20 draws  atmospheric air from the
        location 12 into the choke. By drawing it through the
        exhaust manifold 12, the atmospheric air is pre-heated..
          The accessory provided by this invention is that illus-
        trated within the broken-line  rectangle in the FIGURE.
          This accessory  includes,  in  combination,  means 24
        defining a gas mixing chamber 26, a first conduit 28
        having one end for connection to the crankcase of the
        engine 10. and second, third and fourth conduits 30. 31
        and 32, respectively. The purposes of all of these con-
        duits will become clear subsequently.
          Returning to the first conduit 28, it will be seen that
        this passes in non-communicating fashion through the
        chamber  26 so that any gases in  the chamber 26 can
        contact the outside of the conduit 28. This arrangement
        is made for heat-transfer purposes. The conduit 28 then
        has a relatively extended portion 34, the specific length
        of which  will be  dealt with later, following which it
        opens at  its other end 36 into the chamber 26. The
        means defining  the  chamber 26 would typically be a
        metallic wall surrounding the  chamber, and therefore
        the first conduit 28 opens at  its other end through that
        wall.
          The first conduit is such that its inner wall is of cop-
        per, and preferably the entire conduit 28 is of copper.
          The second conduit 30 leads from the chamber 26,
        and in the FIGURE is connected  to the pipe 17 which
        is a part of the intake manifold 14.
          The third conduit 31 leads from the chamber 26 and
        makes a T-connection into the pipe 20 at the location 39.
          The fourth conduit 32 leads from the chamber 26 and
        is adapted for connection to the standard air filter 40 of
        the engine.
          Preferably, there is a control valve 42 provided in the
        fourth conduit 32.
          It has been found that the first conduit 28 should be
        substantially about 7 feet (2.2  meters) in total length.
        Naturally, some variation from this ideal length is possi-
        ble, but a reasonably lengthy first conduit 28 appears to
        be beneficial in terms of increasing the mileage of auto-
        mobiles to which  this accessory device is attached.
          The  second  conduit 30 is that through  which the
        mixture of gases within the chamber 26 passes  into the
        pipe 17 and thence into the intake manifold 14. This
        conduit may be of rubber, and typically an inside diame-
        ter of 8 mm would be satisfactory for the rubber tube
        constituting this conduit.
          The third conduit 31 is that which M connected to the
        engine choke pipe 20 with a T-connection, as aforesaid.
        In the solid line connection  illustrated, the conduit 31
        allows heated air from the pipe 20 to be drawn  into the
        chamber  26. In certain instances of older engines, the
        portion 200 of the pipe 20 within the exhaust manifold
        12 is rusted or cracked, and exhaust gase* can be drawn
        into the pipe 20. This invention is also directly applica-
        ble to such a situation. It is not a disadvantage to draw
        exhaust gases into the chamber 26, since the  exhaust
        gases often include  certain  unhurried components,
        which  can be drawn back  through  the engine and
        burned on a second pass. If the pipe 20 is not deterio-
        rated in the portion 20a or if the vehicle does not have
        such a pipe, then the alternative conduit 310 shown in
        broken lines may be employed. Conduit 310 is con-
        nected directly to and opens into the exhaust  pipe 16
        close to the exhaust manifold 12.

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                                               4,512,325
                   EXAMPLE I
                                                    10
  The third conduit 31  may  be of rubber, and may
conveniently be of rubber tubing with a 3 mm  inside
diameter. It will be understood that the third conduit 32
is essentially intended to tap a source of heat for the
mixture within the chamber 26, although naturally the
heat must  be conveyed  in  •  gas  of some kind. The
heated gas, whether air or exhaust fumes, is of course
supplied by the pipe 20 or the conduit 31a.
  The fourth  conduit 32  is intended to draw filtered
atmospheric air from the air filter 40 of the car, and the
quantity of air being drawn in is intended to be adjusted
by means of the valve 42.
  The fourth conduit 32 may again be of a rubber tub-
ing, conveniently having an inside diameter of about 5 15
mm.
  A further  connection  may  be made to the  mixing
chamber 26, which may  be either closed or  may be
connected to. a standard emission control device. Such a
connection has not  been illustrated in the FIGURE.
  Experiments have indicated that the first conduit 28
should be relatively long.  A length of about 7 feet (ap-
proximately 2.2 meters) has been found satisfactory, but
is not considered to be strictly limiting. It is considered 25
that this relative length is necessary in order to allow
certain  catalytic reactions to  take place in the gases
drawn from the crankcase. prior to the admission of
these  gases into the chamber 26.
  It is contemplated to adapt this invention to make use w
of the EGR (exhaust gases recycling) connection in
some  of the more recent vehicle models.
  An auxiliary device meeting  the above description
was connected to a  number of automobiles during 1977
and during 1979. The detailed cases are given below,
and are exemplary of the advantages to be attained by
use of the auxiliary  device provided  herein.
                                                    20
                                                    40
                                     Hydrocarbons
                Carbon Mononide
              % volume  grams/mile
                                 pirn per
                                  million
                                          grams/mile
Without device
installed
With device
installed
                1.75.
                0 13
                          41.7
                                   226

                                   IM
It

2.1
                                                    50
                                                    55
                   EXAMPLE 2
  Driving tests were carried out on Nov. 12, 1977 on a
1966 Oldsmobile Delta 88, with and without the instal-
lation of a device meeting the above description. The
test distance was 39 miles along Highway 403 and the
QEW  between Hamilton and  Oakville. The  vehicle
speed was maintained at 50-55 mph. The weather lem-
perature  was -1* C.  Prior to the  test, the  automobile
had undergone hydraulic valve lifter  replacement and
valve work.
                                                       Te«t
                                                                          Test
                                                                         distance
                                                                                        On
                                                                                     consumed
                                                                                                Miln/Oil
                                                       With device
                                                       initialled
                                                       Without device
                                                       installed
                                                                        39 0 miln

                                                                        39 0 miln
                                         215 Imp.
                                          gallons
                                         2 45 Imp.
                                          gallons
                                                                                                   18.1
                                            15.9
                                                         For this test, a minimum 13% of gas mileage savings
                                                       was recorded.
                                                                          EXAMPLE 3
                                                         Driving tests were carried out on Aug. 26, 1979 on a
                                                       1967 Cadillac vehicle, 340 cubic inches, with and with-
                                                       out the installation of an auxiliary device meeting the
                                                       foregoing specifications. The  test  distance was 93.4
                                                       miles and covered the following route in Ontario: High-
                                                       way 6 from Dundas to Highway 401, to new Highway
                                                       6 bypassing Guelph, to old Highway 6 to about 5 miles
                                                       beyond Fergus, and returning along the same  route.
                                                       The route was travelled twice, once without and once
                                                       with the device. The time  span for the tests was from
                                                       about 2:00 p.m. to 8:00 p.m. The weather was overcast,
                                                       with the temperature varying between 23* and 26* C.
                                                       The speed was maintained  generally at 50-60 pmh but
                                                       included 70 mph for one minute on a stretch  of High-
                                                       way 401 and idling at a few stoplights. The car under-
                                                       went no prior tuneup or carburettor adjustments.
                                                       Test
                                                                      Test
                                                                     distance
                                                                                 On
                                                                               consumed
                                             Cost of
                                              gas
                                            Miln
                                           per liter
                                                       without device
                                                       imlalled
                                                       with device
                                                       installed
                                                                       934

                                                                       934
                                                                      miln
                                    25.2
                                    liters
                                    19.4
                                    liters
                                                                                           SS.54
                                    $4.26
                                                                                                   3.71
                                            4.11
  Pollutant emission tests were carried out by the Vehi-
cle Emissions Section  of the Ontario  Ministry of the
Environment on  a  1970 Ford Galaxie 500. The tests
were carried out on the vehicle before and afer installa-
tion of the device constructed in accordance with the 45
foregoing specification.
  For this test, the savings in gas consumed and in cost
was 23%.

                   EXAMPLE 4
  On Sept.  2.  1979, a 1968  Buick  Riviera (430 cubic
inches) was tested with and without the installation of a
device meeting the foregoing specification.  The test
distance as measured by the vehicle odometer was 92.4
miles along the following route in Ontario: Highway 6
from  Dundas to Highway 401, to new Highway 6 by-
passing  Guelph,  to old  Highway  6 to about 5 miles
beyond  Fergus, and returning along the same  route.
The route was travelled twice, once with and once
without the device. The tests were done from 10 a.m. to
4 p.m. The weather was  generally overcast with a few
light showers and the temperature was 22"-26* C. The
speed was maintained generally at  50-60 mph  but in-
cluded stretches at 40-50 mph due  to slow traffic and
also idling at a few stoplights. This vehicle had had a
major tune-up on Aug. 28, 1979, prior to the two tests.
                                                    M)
Test
                                                                      Test      Gjs    Cost of
                                                                     Distance  Consumed   gas
                                                    Miln
                                                   per liter
With device
installed
Without device
installed
                                                                      92.4
                                                                      miles
                                                                      92.4
                                                                      miles
                                                                                209     M.79
                                                                               liters
                                                                                2K.O     Wi.42
                                                                               liters
                                                     4.42
                                                 (19.9 miles/gal)
                                                     .»..»(>
                                                 (14.9 miles/gal)

-------
                                              4,512,325
  For this lest, the savings in gas consumed and in cost
 vas 25.4%.

                  EXAMPLE 5

TeM
With device
initialled
Without device
installed
Te*t
Diuince
»6.ft
mile*
R6.6
milei
Consumed
9 JJ
liter*
19.3
liter*
COM of
S2.IK
S4.4«
Mile*
per liter
9.07
(40.8 mile*/gil)
4.44
(20.0 mile*/gil)
                                                   10
                                                   15
  Driving tests were carried out on Sept. 2, 1979 on a
 975 Chrysler  Plymouth  Fury  vehicle (318  cubic
 nches). with and without  the installation of a device
 neeting the above specifications. The lest distance as
 neasured by the vehicle odometer was 86.6 miles along
 lie following route in  Ontario: Highway 6 from Dun-
 las  to  Highway 401.  to new Highway  6 bypassing
 juelph, to old  Highway 6  to about 5 miles beyond
 "ergus, and return along the same route. The route was
 ravelled twice, once with and once without the device.
 The tests were done from 10 a.m. to 4 p.m. The weather
 was generally overcast with a few light showers and the
 iemperature about 22'-25' C. The  speed was  main-
 ained generally at 30-60 mph but included stretches at
40-50 mph due to slow traffic and also idling at a few  20
itoplights. There was  no prior tune-up or carburettor
adjustment. The standard auto emission unit was not
altered in any way during the installation of the device
 or the first of the two tests below.
                                                   25
                                                   30
  For this test, the savings in gas consumed and in cost
was 51%.                                           35
  I claim:
  1. An improved internal combustion engine including
a crankcase ventilation system, an air filter and an intake
manifold, wherein the improvement comprises in com-
bination:                                            40
  means defining a gas-mixing chamber,
                                                   45
                                                   50
                                                  55
  a firs) conduit having one end adapted for connection
    to the crankcase of the engine and passing in non-
    communicating fashion  through said chamber so
    thai any gases in said chamber contact the outside
    of the first conduit, the first conduit opening at its
    other end into said chamber and being such that at
    least its inner wall is of copper,
  a second conduit  leading  from said  chamber and
    being adapted for communication with said intake
    manifold.
  a third conduit leading from said mixing chamber and
    receiving a gas which has been  heated by exhaust
    heat,
  and a fourth conduit leading from  said mixing cham-
    ber and being adapted  for connection to the air
    filter of the engine.
  2. The invention claimed  in claim 1. in which the
engine has an automatic choke, and in which said third
conduit connects  through  a  T-connection with a pipe
that extends from the automatic choke, passes through
the exhaust manifold, and opens to the atmosphere.
  3. The invention claimed  in claim 1,  in which said
third conduit  connects directly to  the exhaust pipe and
allows hot exhaust gases to be drawn  into said chamber.
  4. The invention claimed in claim 1, claim 2 or claim
3, in which a control valve  is provided  in said fourth
conduit.
  9. The invention claimed in claim 1, claim 2 or claim
3, in which the first conduit  is substantially 2.2. meters
in total length.
  6. The invention claimed in claim 1, claim 2 or claim
3, in which the second, third and fourth conduits are of
rubber.
  7. The invention claimed in claim 1, claim 2 or claim
3, in which the first conduit is of solid copper having an
inside diameter of substantially 6 mm.
  8. The invention claimed in claim 1, claim 2 or claim
3, in which the second, third and fourth  conduits have
inside diameters of substantially 8 mm, 3 mm and 5 mm
respectively.
                                                  60
                                                  65

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                                                                            Attachment  B
Consumer and
Corporate Affairs Canada

Patent Office
Consommation
et Corporations Canada

Bureau des brevets
Canadian Patent
Brevet canadien
                                      1174920
To all to whom these presents shall come:

Whereas a petition has been presented to the
Commissioner of Patents praying for  the grant of
a patent for a new and useful invention,  the title
and description of which are contained in the
specification of which a copy is hereunto attached
and made an essential part hereof, and the
requirements of the Patent Act having been
complied with,

Now therefore the present patent grants to the
applicant whose title thereto appears  from the
records of the Patent Office and as indicated in
the said copy of the specification attached hereto,
and to the legal representatives of  said applicant
for a period of seventeen years from the date of
these presents the exclusive right,  privilege and
liberty of making,  constructing, using  and vending
to others in Canada the  invention, subject to
adjudication in respect thereof before any court
of competent jurisdiction.

Provided that the grant hereby made  is subject to
the conditions contained in  the Act aforesaid.
In testimony whereof, these letters patent bear
the  signature of the Commissioner and the seal of
the  Patent Office hereunto affixed at Hull, Canada.
A tous ceux qul les presentes verront:

Considerant qu'une requete a et6 presentee au
Commissaire des brevets, demandant la
delivrance d'un brevet pour une invention nouvelle
et utile, dont le titre et la description apparaissent
dans le memoire discriptif dpnt copie  est annexee
aux presentes et en fait  partie essentielle, et que
ladite requete satisfait aux exigences  de la Loi
sur  les brevets,

A ces causes, le present brevet confere au
demandeur dont le titre de propriete audit brevet
est  etabli d'apres les dossiers du Bureau des
brevets et est indique dans ladite copie du
memoire  descriptif ci-annexe, et aux representants
legaux du dit demandeur, pour une periode de
dix-sept ans, d compter  de la date des presentes,
le droit, la faculte et le privilege exclusif de
fabriquer, construire, exploiter et vendre £ d'autres
au Canada I'invention, sauf jugement  en I'espece
par  un tribunal de juridiction  competente.

La concession faite par les presentes etant
soumise aux conditions contenues dans la loi
precitee.

En foi de quoi ces  lettres patentes portent la
signature du Commissaire ainsi que le sceau du
Bureau des  brevets appos6 d Hull, Canada.
                                                                                                             I
                                        SEP 15  1984
                                                Commissioner of Patents   Commissaire des brevets
                                                Attesting Officer
                    Certificateur

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I—
         Consumer and       Consommaflon
         Corporate Affairs Canada  et Corporations Canada
                                     iii> (A) NO.   1 174 920

                                        (45)  ISSUED 840925
                                        (52)  CLASS  123-37
          (51) INT. CL.  F02D 33/00
          (19) (CA)
CANADIAN  PATENT
(12)
          (54) Emission Control Device
          (72) DePakh, Stephen,
                Canada
          (21) APPLICATION No.     376,937

          (22) FILED             810506
                 No.  OF CLAIMS ,    8
         Canadat

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                          1174920
                            i
          IMPROVED EMISSION CONTROL DEVICE
          This invention relates to devices for reducing the
emission of pollutant gases from reciprocating internal combust-
ion engines.
          It is well known that one of the major sources of air
pollution from an internal combustion engine,  particularly in an
automobile, are the emission of gases resulting from so called
"blow-by" of gases between the cylinder wall and piston rings
into the crankcase.  Such gases have commonly been vented to
atmosphere through a suitable vent pipe.
          In order to solve the problem of air pollution result-
ing from the above source, it has been proposed to couple the
vent pipe leading from an engine crankcase to the intake mani-
fold where vacuum conditions normally exist.  Thus the pollutant
gases are immediately drawn back into the intake manifold of the
engine and are burned in the combustion process in the cylinders.
          However, due to varying vacuum conditions in the
intake manifold of an automobile engine, devices of known type
have not proven successful.  Typically, for example, a greater
amount of blow-by is liable to occur during acceleration of the
engine.  Simultaneously, however, vacuum in the intake mani-
fold decreases thus reducing the capacity of the engine to
draw in the crankcase emissions.  Also the addition of crank-
case gases to the charge fed to the engine disturbs the air/
fuel mixture entering the cylinders with adverse .effects.
          Further, some prior art devices, in addition to lead-
Ing crankcase emissions directly into the intake "manifold,
have provided an air intake to the crankcase so that under
condition of high vacuum, air could be drawn through the crank-
case to ventilate it.  However, such systems are considered
dangerous due to the possibility of creating an explosive
mixture of gases in the crankcase.

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                               1174920
                                 2
               According to the present invention, in order to
     approach a solution to the above problems of prior art
     devices, there is a provided, in combination: means defining a
     gas-mixing chamber, a first conduit having one end adapted for
 5   connection to the crankcase of an engine, the primary conduit
     passing in non-communicating fashion through said chamber so
     that gases in said chamber contact the outside of the conduit,
     the conduit opening at its other end into said chamber,
     the first conduit being such that its inner wall is of copper,
10   a second conduit leading from said chamber and being adapted
     for communication with the intake manifold of the engine,
     a third conduit leading from said mixing chamber and
     receiving a gas which has been heated by exhaust heat, and
     a fourth conduit leading from said mixing chamber and being
15   adapted for connection to the air filter of the engine.
               The invention is illustrated schematically in the
     attached drawing, which shows an internal combustion engine
     in plan, together with the various components of the
     accessory provided by this invention.
20             In the figure, an engine 10 is seen in plan, and
     includes a head and a crankcase one above the other, such
     that they are in alignment in the view of the figure.  An
     exhaust manifold 12 and an intake manifold 14 of the usual
     construction are provided, the exhaust manifold 12 emptying
25   into an exhaust pipe 16, and the intake manifold 14 being
     connected by a short pipe 17 to a carburettor/choke device
     18.  A line 20 extends from the choke of a carburettor/choke
     18, and passes into and along the exhaust manifold 12,
     ultimately opening at the location 22 through the wall of
30   the exhaust manifold 12.  The line 20 draws atmospheric
     air from the location 22 into the choke.  By drawing it               f
     through the exhaust manifold 12, the atmospheric air is               ;f
     pre-heated.      '                                                     ':
               The accessory provided by this invention is that            ;;
35   illustrated within the broken-line rectangle in the figure.
               This accessory includes, in combination, means              '
     24 defining a gas mixing chamber 26, a first conduit 28 having        ;
     one end for connection to the crankcase of the engine 10,             :

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                              1174920
                                3
     and second,  third and fourth conduits 30,  31 and  32,
     respectively.   The purposes of all of these conduits  will
     become clear subsequently.
               Returning to the  first conduit 28, it will  be seen
 5   that this passes in non-communicating fashion through the
     chamber 26 so that any gases in the chamber 26 can contact
     the outside of the conduit  28.  This arrangement  is made for
     heat-transfer purposes.  The conduit 28 then has  a relatively
     extended portion 34, the specific length of which will be dealt
10   with later,  following which it opens at its other end 36 into
     the chamber 26.  The means  defining the chamber 26 would
     typically be a metallic wall surrounding the chamber, and
     therefore the first conduit 28 opens at its other end through
     that wall *
15             The first conduit is such that its inner wall is
     of copper, and preferably the entire conduit 28 is of copper.
               The second conduit 30 leads from the chamber 26,
     and in the figure is connected to the pipe 17 which is a
     part of the intake manifold 14.
20             The third conduit 31 leads from the chamber 26 and
     makes a T-connection into the pipe 20 at the location 39.
               The fourth conduit 32 leads from the chamber 26
     and is adapted for connection to the standard air filter
     40 of the engine.
25             Preferably, there is a control valve 42 provided
     in the fourth conduit 32.
               It has been found that the first conduit 28 should
     be substantially about 7 feet (2.2 meters) in total length.
     Naturally, some variation from this ideal length  is possible,
30   but a reasonably lengthy first conduit 28 appears to  be
     beneficial in terms of increasing the mileage of  automobiles
     to which this accessory device is attached.
               The second conduit 30 is that through which the
     mixture of gases within the chamber 26 passes into the pipe
35   17 and thence into the intake manifold 14.  This  "conduit
     may be of rubber, and typically an inside diameter of 8 mm
     would be satisfactory for the rubber tube constituting this
     conduit.
               The third conduit 31 is that which is connected to
40   the engine choke pipe 20 with a T-connection, as  aforesaid.

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                                1174920
                                  4
     In the solid line connection illustrated, the conduit 31 allows
     heated air from the pipe 20 to be drawn into the chamber 26.
     In certain instances of older engines, the portion 20a of
     the pipe 20 within the exhaust manifold 12 is rusted or
 5   cracked, and exhaust gases can be drawn into the pipe 20.
     This invention is also directly applicable to such a situation.
     It is not a disadvantage to draw exhaust gases into the chamber
     26, since the exhaust gases often include certain unburned
     components, which can be drawn back through the engine
10   and burned on a second pass.  If the pipe 20 is not deteriorated
     in the portion 20a, or if the vehicle does not have such a
     pipe, then the alternative conduit 31a shown in broken
     lines may be employed.  Conduit 31a is connected directly
     to and opens into the exhaust pipe 16 close to the exhaust
15   manifold 12.
               The third conduit 31 may be of rubber, and may
     conveniently be of rubber tubing with a 3 mm inside diameter.
     It will be understood that the third conduit 31 is essentially
     intended to tap a source of heat for the mixture within the
20   chamber 26, although naturally the heat must be conveyed in
     a gas of some kind.  The heated gas, whether air or exhaust
     fumes, is of course supplied by the pipe 20 or the conduit 31a.
               The fourth conduit 32 is intended to draw filtered
     atmospheric air from the air filterNof the car, and the quantity
25   of air being drawn in is intended to be adjusted by means of
     the valve 42.
               The fourth conduit 32 may again be of a rubber
     tubing, conveniently having an inside diameter of about 5 mm.
               A further connection may be made to the mixing
30   chamber 26, which may be either closed or may be connected to
     a standard emission control device.  Such a connection has not
     been illustrated in the figure.
               Experiments have indicated that the first conduit
     28 should be relatively long.  A length of about 7 feet (approx-
35   imately 2.2 meters) has been found satisfactory, hut is not
     considered to be strictly limiting.  It is considered that
     this relative length is necessary in order to allow certain
     catalytic reactions to take place in the gases drawn from the
     crankcase,  prior to the admission of these gases into the
40   chamber 26.

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                          1174920
                            5
          It is contemplated to adapt this invention to
make use of the EGR (exhaust gases recycling) connection
in some of the more recent vehicle models.
          An auxiliary  device meeting the above description
was connected to a number  of automobiles during 1977 and
during 1979.  The detailed cases are given below, and are
exemplary of the advantages  to be attained by use of the
auxiliary device provided  herein.

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                              1174920
     Example 1
                Pollutant emission tests were carried out by the
     Vehicle Emissions Section of the Ontario Ministry of the
     Environment on a 1970 Ford Galaxie 500.   The tests were
     carried out on the vehicle before and after installation of
     the device constructed in accordance with the foregoing
     specification.
Test
Without device
installed
With device
installed
Carbon Monoxide
% volume
1.75
0.15
ytams/Tiu.le
41.7
3.6
Hydrocarbons
parts per
million
226
163
grams/mile
2.9
2.1
10
15
Example 2
           Driving teats were carried out on November 12,
1977 on a 1966 Oldsmobile Delta 88, with and without the
installation of a device meeting the above description.   The
test distance was 39 miles along Highway 403 and the QEW
between Hamilton and Oakville.  The vehicle speed was maintained
at 50-55 mph.  The weather temperature was -1°C.  Prior  to the
test, the automobile had undergone hydraulic valve lifter
replacement and valve work.
Test
With device
installed

Without device
installed

Test
distance

39.0 miles


39.0 miles

Gas
consumed

2.15 imp.
gallons

2.45 Imp.
gallons
Miles/Gal

18.1


15.9

20
25
           For this test,  a minimum 13% of gas mileage savings
was recorded.                                    -
Example 3
           Driving tests were carried out on August 26,  1979
on a 1967 Cadillac vehicle, 340 cubic inches,  with  and without
the installation of an auxiliary device meeting the foregoing
specifications.   The test  distance was 93.4 miles and  covered
the following route in Ontario: Highway 6 from Dundas  to Highway
                                                                           K'
                                                                           I

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                               1174920
      * ,     ii \\\5\Jwn-j          7
   \6 bypassing Guelpti,  to old Highway 6 to about 5 miles beyond
    Fergus, and returning along the same route.  The route was
    travelled twice, once without and once with the device.  The
    time span for the tests was from about 2:00 p.m. to 8:00 p.m.
 5  The weather was overcast, with the temperature varying between
    23 and 26°C.   The speed was maintained generally at 50-60 pmh
    but included 70 mph for one minute on a stretch of Highway
    401 and idling at a few stoplights.  The car underwent no prior
    tuneup or carburettor adjustments.
10  Test        Test         Gas          Cost of      Miles
               distance      consumed      gas          per litre
without device
installed
with device
installed
93.4
miles
93.4
miles
25.2
litres
19.4
litres
$5.54
$4.26
3.71
4.81
               For this test, the savings in gas consumed and in
    cost was 23%.
    Example 4
               On September 2, 1979, a 1968 Buick Riviera (430
15  cubic inches) was tested with and without the installation of
    a device meeting the foregoing specification. .The test dis-
    tance as measured by the vehicle odometer was Ci24- miles
    along the following route in Ontario: Highway 6 from Oundas
    to Highway 401, to new Highway 6 bypassing Guelph, to old
20  Highway 6 to about 5 miles beyond Fergus, and returning along
    the same route.  The route was travelled twice, once with and
    once without the device.  The tests were done from 10 a.m. to
    4 p.m.  The weather was generally overcast with a few light
    showers and the temperature was 22-26°C.  The speed was
25  maintained generally at 50-60 mph but included stretches at
    40-50 mph due to slow traffic and also idling at a few stop-
    lights.  This vehicle had had a major tune-up on August 28,
   . 1979, prior to the two tests.

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Test
With device
installed
Without device
installed

Test
Distance
92.4
miles
92.4
miles
1174920
8
Gas
Censured
20.9
litres
28.0
litres

Cost of
gas
$4.79
$6.42

Miles
per litre
4.42
(19.9 miles/gal)
3.30
(14.9 miles/gal)
               For this test, the savings in gas consumed and in cost
    was 25.4%.
    Example 5
 5             Driving tests were carried out on September 2, 1979
    on a 1975 Chrysler Plymouth Fury vehicle (318 cubic inches),
    with and without the installation of a device meeting the
    above specifications.  The test distance as measured by the
    vehicle odometer was 86.6 miles along the following route in
10  Ontario: Highway 6 from Dundas to Highway 401, to new Highway
    6 bypassing Guelph, to old Highway 6 to about 5 miles beyond
    Fergus, and return along the same route.  The route was travelled
    twice, once with and once without the device.  The tests were
    done from 10 a.m. to 4 p.m.  The weather was generally over-
15  cast with a few light showers and the temperature about
         o                                          -f&—-60
    22-25 C.  The speed was maintained generally at 50-66 mph
    but included stretches at 40-50 mph due to slow traffic and
    also idling at a few stoplights.  There was no prior tune-
    up or carburettor adjustment.  The standard auto emission
20  unit was not altered in any way during the installation of
    the device for the first  of the two tests below.
Test
With device
installed
Without device
installed
Test
Distance
86.6
miles
86.6
miles
Gas
Consumed
9.55
litres
19.5
litres
Cost of
gas
$2.18
$4.46
Miles
per litre
9.07
(40.8 miles/gal)
4.44
(20.0 miles/gal)
               For this test,  the savings in gas consumed and in
    cost was 51%.                                     '

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                          1174920
CLAIMS:
1.        In combination:
          means defining a gas-mixing chamber,
          a first conduit having one end adapted for connection
to the crankcase of an engine of the kind having an air filter,
the primary- conduit passing in non-communicating fashion through
said chamber so that gases in said chamber contact the outside of
the conduit,  the conduit opening at its other end into said chamber,
the first conduit being such that at least its inner wall is of
copper,
          a second conduit leading from said chamber and being
adapted for communication with the intake manifold  of the
engine,
          a third conduit leading from said mixing chamber and
receiving a gas which has been heated by exhaust heat,
          and a fourth conduit leading from said mixing
chamber and being adapted for connection to the air filter
of the engine.
2.        The combination claimed in claim 1, in which the engine
has an automatic choke, and in which said third conduit
connects through a T-connection with a pipe that extends from
the automatic choke, passes through the exhaust manifold,
and opens to the atmosphere.
3.        The combination claimed in claim 1, in which said third
conduit connects directly to the exhaust pipe and allows hot
exhaust gases to be drawn into said chamber.
4.        The combination claimed in claim 1, claim 2 or
claim 3, in which a control valve is provided in said fourth
conduit.
5.        The combination claimed in claim 1, claim 2 or
claim 3, in which the first conduit is substantially 2.2.
meters in total length.
6.        The combination claimed in claim 1, claim 2 or
claim 3, in which the second, third and fourth conduits
are of rubber.                                   '
7.        The combination claimed in claim 1, cla^m 2 or
claim 3, in which the first conduit is of solid copper having
an inside diameter of substantially 6 mm.
8.        The combination claimed in claim 1, claim 2 or
claim 3, in which the second, third and fourth conduits have
inside diameters of substantially 8 mm, 3 mm and 5 mm
respectively.
                             r

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                                   1174920
40

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                                                        Attachment

       UNITED STATES ENVIRONMENTAL PROTECTION  AGENCY
                      ANN ARBOR. MICHIGAN  48105
July 16, 1985                                                    OFFICE OF
                                                             AIR AND RADIATION

Mr. S. DePakh, President
DeAcc Devices, Inc.
90 Warren Road, Suite 110
Toronto, Canada M4V2S2

Dear Mr. DePakh:

     Ttiis  letter  is in  response  to  your inquiry on July  16 regarding an
EPA  evaluation of  DeAcc  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  evaluations  for the  purpose  of  increasing  the  common
Knowledge  in  the area.   For this reason,  the  outcome of  any  testing by
EPA  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  witn this  letter  is a  packet of materials  which you will
need to apply for  an  EPA 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," 4) a copy of  the  applicable  Federal Regulations, and
5) otner documents  that may  be of  interest.

     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 tne
guidelines 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 an  independent  laboratory  of  your choice.   Such testing
would  be   conducted  at  your  expense.    A  list  of  laboratories which are
willing  to contract for  testing  and  are known to  have  the equipment and
personnel  to  perform  acceptable  tests,  has  been  included  in the enclosed
packet.  Tne  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 satisfactory  test plan.  In
the  evaluation of  devices EPA  is required  to  work with the manufacturer
of  the  product.   Applicants  such as  distributors,  retailers and  importers
of  devices   will   be  asked  to  obtain  written  authorization  from the
manufacturer  to act as his representative.

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    Retrofit fuel additives are  defined  as  devices  in the regulations and
will  be  evaluated by  the  same  procedures  as devices.   Engine  oils,  oil
additives,  and  other  lubricants  do  not   fall  under  tne provisions  of
Section  511  of  the  Motor  Vehicle  Information  and Cost  Savings  Act.   If
you  wish to  improve  the  credibility  of   claims  for your  lubricants  by
performing  tests on  your own, we  will try to help  by commenting on your
test  plans,  but  we  cannot  accept  applications for  formal evaluations  of
lubricant products.

    Before  you  begin to evaluate  your device, there  are several aspects
concerning  testing   at  an  independent  laboratory  which  I would  like  to
bring to your attention:

    Minimum  Test Requirements - Although  different  types  of  devices may
    require a more complex  test  plan,  the  minimum we  require involves two
    vehicles  and  with  replicate  test  sequences   on each  vehicle.   The
    vehicles  should  be  selected   to  be   representative  of the largest
    selling  engine-transmission  combinations in the  United States.  Each
    vehicle is to  be set to manufacturer's tune-up specifications for the
    baseline  tests.   Baseline emissions  and fuel  economy  should be near
    the  levels at wnich  the vehicles were certified.

    The   test   sequences  are   conducted   in  a  "back-to-back"  manner;
    duplicate  with  the  vehicle  in  baseline condition, and then  duplicate
    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, choice or  idle  speed, another test  sequence
    with only  these  adjustments  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  were accumulated  before
    the  tests  with  the  device  must  also   be  accumulated before  baseline
    tests   without   the  device.    In  addition,  tne  method  of mileage
    accumulation should  be Kept  constant.   Also,  as  a  minimum,   tne 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  evaluation 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 independent  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
    independent  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

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    laboratory you nave  chosen,  wnen testing is scheduled  to  begin,  wnat
    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  answer any questions  directly  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 $3500 per  vehicle  and  less  than  $7000  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 providing  test  vehicles,
    mileage  accumulation,   parameter  adjustment,   or additional testing)
    will  result  in  additional  costs.    In  any case,  you  will  have  to
    contact them individually to obtain their latest  prices.

    Outcome  of  the Tests -  In  order 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.  Tnese  values  nave  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
    conducted on a fleet of  two cars,  the  average  improvement  should be
    at  least  6  percent.   If  at least  a  6 percent  difference  in average
    fuel economy can  be  shown,  then  we  would be able to say statistically
    at the 80 percent confidence level that there is a real improvement.

    Similarly, we  would  expect  a  minimum of 3 percent  improvement  for a
    fleet  of five  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                                  6%
              3                                  5%
              4                                  4%
              5                                  3%
             10        .                          27,

    Once we  receive your application,  it  will  be  reviewed to determine if
it meets  the requirements  listed  in the  format.  The  submission of  data
or information  labeled as  confidential  or proprietary  must  be  justified
on  a  case-by-case  basis   by  the  applicant.   EPA  will not  treat  test
results, including those conducted  by  independent or other laboratories,

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as confidential since Section  5il(c)  of  the  Motor Vehicle Information and
Cost Savings  Act  requires disclosure of  sucn information.   Additionally,
EPA may  decide  not to perform an  evaluation of a device if  it  judges it
canno.t develop  a  technically  sound  final report  Decause  the preliminary
information   submitted   by   the    manufacturer   was    claimed   to   be
confidential.   If  your application  is  not  complete,  we will asK.  you to
submit further  information  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  confirmatory testing.   You must provide  funds  to cover
the cost  of  any  testing  in  the  EPA laboratory.   You  will  be  given the
opportunity  to  review 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 weefcs from the receipt of
a complete  application to  the  announcement of our repo'rt.  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.

    I  nope  the information  above  and   that  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,. 48105.   The  telephone  number  is (313) 668-4299.  Please contact
me if you have any  questions or require any  further information.

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

Enclosures

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                                                               Attachment D
CORPORATE ATTORNEY:
PATENT AOENT:
SIM 8c MCBURNEY

CONSULTANT:
PROFESSOR A. CORSINI. ASSISTANT DEAN
OF SCIENCE (STUDIES) . MCMASTER UNIV.
  DeAcc Devices Inc.
DECELERATION •• ACCELERATION

   CONTROL SAVE GASOLINE
                                  TELEPHONE (416) 923-1248

                                 TORONTO, ONTARIO, CANADA
PRESIDENT:
STEPHEN DEPAKH
                         August  12,  1985.
        Mr. Merrill W. Korth,
        Device Evaluation Co-Ordinator,
        U.S. Environmental  Protection  Agency,
        2565 Plymouth Road,
        Ann Arbor, Michigan  4810$,
        U.S.A.

        Dear Mr. Korth:

                RE:  PLANNED E.P.A.  TESTING OF DEACC DEVICE

        Thank you for your  prompt  response to  my inquiry o'f July 16/85
        and my request for  updated  information regarding E.P.A. test
        procedures.

        As indicated to you,  Patent  protection on my device has now
        been finalized and  I am  in  a position  to re-submit my E.P.A.
        Test application as  per  your recommendation of November 15/82.
        (See Copy letter encl.)

        Prior to re-submitting my  application  and based on the general
        material you have recently  supplied, the following questions
        require clarification/confirmation:

        1.  Could you supply the following (preferably high mileage)
            U.S. vehicles for E.P.A. testing with the DEACC DEVICE:
        Test "A"   (8 Cyl.  Cars/Win.  Test Plan)
                                 Projected
                                 Test Costs
        1 - 1982 Chevrolet

        1 - 1984 Ford

        TEST "B"   (4 Cyl. Cars/Min.  Test Plan)
     )E.P.A.  supplied  cars
     )        or
     )DEACC   supplied  cars
        1 - 1982  (German  Make)  )E.P.A.  supplied cars
                                )        or
        1 - 1984  (Japan Make)   )DEACC   supplied cars
U.S.S

U .'S. $



U.S.S

U.S.S
                                                  (Continued

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                        - Page 2 -
2.  Or does each test require identical make/year cars?

3.  With reference to E.P.A.  LISTING OF F.E.  DEVICES tested:
    Approximately how many  of these devices,  dealing with re-
    cycling of blow by/crankcase gases had Patent protection
    prior to E.P.A. testing?

Your early reply will be  most appreciated.

                                        Sincerely,

                                      '  DEACC
                                        Stephen DePakh,
                                        President,
                                        90 Warren Road,
                                        Suite 110,
                                        Toronto, Ontario,
                                        M4V 2S2.
SD/grh
Encl.  - Copy of your letter of Nov.l 15/82
       - Ethyl Corp. test documents

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                                                     Attachment E
     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                  ANN ARBOR, MICHIGAN  48105
August 19, 1985                                        OFFICE OF
                                                  AIR. NOISE AND RADIATION

Mr. Stephen DePakh, President
DeAcc Devices Inc.
90 Warren Road, Suite 110
Toronto, Ontario
CANADA M4V2S2

Dear Mr. DePakh:

     This  is  in  response  to your  letter  dated August 12,  1985
discussing your  plans for testing  of  the  DeAcc Device.   I  will
answer  the  questions  listed  in  your  letter and clarify the  EPA
policy related to  the evaluation of retrofit devices.

     EPA  evaluates  fuel  economy  retrofit  devices  under   the
authority  of  Section 511  of the Motor  Vehicle Information  and
Cost   Savings   Act   (MVICSA).    In   order  to  perform  these
evaluations  at  a  reasonable  cost to. the  Government,  it  is
necessary  to  require  that  applicants  provide persuasive  test
data  substantiating their claims.   We have established  precise
protocols  to be followed by EPA and the device manufacturer,  in
determining  the  effectiveness  of  a  device  in improving  fuel
economy  and  in improving  or degrading air pollution  emissions.
These  procedures  require  the device  to  first be  tested  in  a
commercial  laboratory where  proficiency has been  recognized  by
EPA.   If  the  private  laboratory  data  indicate  a likely  fuel
economy  improvement,  EPA  may choose  to  perform more  thorough
confirmatory   testing  at  the   EPA laboratory  in  Ann  Arbor,
Michigan,  as part of  its evaluation process.

     In  my  letters to you  on October  12,  1982  and  July 16,  1985
I  explained  that  EPA expects  the  device  manufacturer  to  obtain
at  least  a  minimum  amount  of data  from  an  EPA  recognized
commercial  laboratory before it can be  determined  if  the  device
warrants  testing  in the EPA laboratory.   The  minimum commercial
laboratory  data requirement  consists  of  duplicate  back-to-back
tests  on each of  two  vehicles  representative of  those  widely
used  by  drivers   in  the  United  States.   The  tests on the  one
Canadian  vehicle  that you performed at  the Ethyl  Corporation do
not meet  this  minimum data requirement.

-------
     Question number 1  in  your  letter asked if EPA could supply
vehicles for  testing  of the DeAcc  Device.   EPA does not supply
vehicles  for testing   at  the  commercial  laboratory but  does
supply  the  vehicles  for  testing   in  the EPA  laboratory.   The
testing  at  the  commercial  laboratory  usually  costs  between
$5000 and $8000 and a  rough estimate of the cost  for testing  in
the EPA laboratory would be $10,000 to 20,000, depending on the
nature of the device.

     Question number  2  asked  if  the cars  should be identical.
No, they  should be different to provide  some indication of the
device  being effective on  more  than  one  model of  car.   The
vehicles  should be  modern  (1980 or later  model) .popular U.S.
vehicles representative of engine  families  most widely used  in
the U.S.   We usually  recommend that one  four cylinder and one
six cylinder  model be  tested.   I  will be happy to work with you
by commenting on  the test plan that you  arrange for testing  at
a private  laboratory.   Often the private laboratory is able  to
obtain the vehicles for  you.

     Question   number    3   in   your   letter  concerned  patent
protection   for  devices  being  evaluated   by   EPA.   EPA  must
understand  the  operating  principle  of  the  device  to properly
evaluate  it.  Our  reports  also discuss  the  theory behind the
operation  of the device  and the results  of the  EPA evaluation
becomes  public  information.   All   of  the devices  that  EPA has
evaluated  in the  past  were not patented,  but  in  those cases the
manufacturer  usually  feels  sufficiently protected  that  he can
freely discuss the principles by which  the device operates.

     If   there    are   additional    questions  concerning   these
comments, please  call  me at  (313) 668-4299.

                                Sincerely,

                              ,«•>       .      j  *      •
                              •\-t~^_jL^~ <-'»—'  r—•t-'vct.
                                Merrill W. Korth
                         Device Evaluation Coordinator
                            Test and Evaluation Branch

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                                                       Attachment F
       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                    ANN ARBOR. MICHIGAN  48105
April 30, 1986                                          OFFICE OF
                                                      AIR AND RADIATION
Mr. Stephan DePakh, President
DeAcc Devices Incorporated
90 Warren Road, Suite 110
Toronto, CANADA  M4V 2S2

Dear Mr. DePakh:

     We  received  your  letter  of  February  25  in  which  you
requested  EPA  to  evaluate  your  DeAcc  Device,   Incorporated,
"Emission  Control  Device"  under   Section   511   of  the  Motor
Vehicle  Information and  Cost  Savings  Act   (MVICSA).   We  have
reviewed   your   application   and   determined   that,   although
additional  information/explanation   is  needed  in  several  areas,
you  should be  readily able  to  supply the  information and  to
proceed with testing at an  independent  laboratory.

     Our   comments   below  address   these  items   and   briefly
describe the independent lab testing you will need to conduct.

     1.  How  will  the  device  be  marketed?  Direct to  users?
Through service and installation  shops?

     2.  What is the cost of the  device?

     3.  Neither  the  application nor the patent  gives  a  clear
or  concise explanation  of  how  the device  functions.   How  is
this device an  improvement  over a PCV valve?

     4.  Will  the  use  of   the   three   tubes  to  the  induction
system  change  the  overall  fuel/air  ratio  or alter the  F/A ratio
of individual cylinders?

     5.  Additional details are needed  for  the  installation  of
the device.

         a.  Are  all  parts necessary for installation  supplied
with the device?

         b.  Will    the    device    be   installed   by    the
purchaser/vehicle owner?

-------
         c.  Does the PCV remain on the engine?

         d.  Detailed   device   installation   instructions  are
needed.
         e.  The  control  valve  to the  air  filter  is manually
adjustable.  How is the proper adjustment determined?

         f.  Vehicle   specific   installation  instructions   are
needed  for  the  tube to be  installed  on  the exhaust manifold  or
connected to a choke tube.

     6.  The  section  on  device  operation  notes   "To  assure
efficiency  and  mechanical  operating efficiency,   instructions
will  be   furnished  for   its  usage."   Please  provide   these
instructions.

     7.   The  section  on  device  maintenance refers  to an  "...
emission  test   required   to  ensure  that   there   is  no   lean
condition  in   the   carburetor  system".   What is  this emission
test and what are the  criteria for determining lean  operation?

     8.    What   are   the  specific   claims   for   the  device,
anticipated improvements  in  emissions  and  fuel economy?

     9.  Please  provide  detailed  information on  the  catalytic
action  occurring  in  the  seven-foot  coiled  copper  tube  that
passes  the  crankcase vapors   through   the  chamber   and   then
returns to open  into the  chamber.

    10.  From  the  information   provided,   it  appears  that  you
expect  full  benefits  to  be seen  immediately and that there  is
no  need for  mileage accumulation.   Please notify us  if this  is
not the case.

     As outlined in the  EPA correspondence with DeAcc Devices,
Incorporated,  during  the  past   four  years,  the  minimum  test
program for  any device without  mileage  accumulation consists of
replicate  FTP  (or  LA-4)  tests  and  replicate HFET  tests   on  at
least  two representative vehicles,   both  with  and  without  the
device,  at  an   independent  lab.   Thus,  the minimum total  is
eight FTPs  (LA-4) and  eight  HFETs.

     The  data  you  provided  consists  of highway  driving   and  a
few limited  emission tests on Canadian  vehicles.  These data do
not meet  the  minimum  requirements  for  independent lab testing
and are considered  to  be  background  information  only.

     Although  we will need  your  response to  the   preceding  to
further process the evaluation  of  your  device,  it  appears that
you should  be able  to. promptly  conduct  the  screening  testing at

-------
an  independent   laboratory.   Since  it appears  you  expect the
device  to  improve  emissions  and  fuel  economy,  do  not require
mileage accumulation,  require  no vehicle  parameter adjustments,
and expect at least  a  six percent improvement, test plan code A
using  test  sequence code  4  (replicate FTP  and  HFET tests both
without  and  with  the  device  on  two  vehicles)  will  meet this
need.   These tests  will  probably  cost  you  $6-12,000.   I  am
enclosing a  copy of our  recent  packet  of Section 511  materials
which  contains  an  updated list  of recognized labs.  Please let
us  review your  detailed test plan prior  to  testing so  that you
may avoid wasted expenditure of  time and  money.

     If  the  independent  lab  data indicate  a  benefit,   EPA will
probably  conduct  confirmatory  testing.   These  tests  are more
extensive  than   the  independent  lab tests.   Also,  we are now
required to  recover the  direct  test costs  from the applicant.
For your device  the  costs  wo.uld  probably  range from $10-15,000.

     If  I  can be  of any  further  assistance,  please contact me
at  (313) 668-4299.

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

Enclosure

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                                                            Attachment G
                             DeAcc Devices Inc.
PATENT AGENT:
SIM ft MCBURNEY


CONSULTANT:
PROFESSOR A. CORSINI. ASSISTANT DEAN
OF SCIENCE (STUDIES) . MCMASTER UNIV.
DECELERATION ^^B ACCELERATION


   CONTROL SAVE GASOLINE
                                                             TELEPHONE (416) 923-1248

                                                            TORONTO. ONTARIO. CANADA
 PRESIDENT:
 STEPHEN DE PAKH
                                   24 May  1986
Mr. Merril W. Korth
Device Evaluation Coordinator
U.S.A. Environmental Protection Agency
2565 Plymouth Road
Ann Arbor, Michigan  48105
U.S.A.

Dear Mr. Korth:

     T received your letter  of Way  10,  1986,  in which you and your
personnel reviewed my application and determined that,  additional infor-
mation/explanation is needed in several areas and I should readily be
able to supply the information to you  (E.P.A.)  and to proceed with testing
at an independent laboratory recognized as capable of performing E.F.A.
retrofit device emission  test for DeAcc Devices Inc.

      Tt is outlined  in  your  letter  that at least two vehicle tests are
necessary and should consist of the total of eight F.T.P^. (L.A.4) and
eight H.F.E.T/S., and therefore do  not  have to have mileage accumulation
test, also that you  need  my  response to further process the evaluation
of the DeAcc device, and  that I should  promptly conduct the screening
testing in a laboratory recognized  by  E.P.A.   Further,  T do appreciate
your advice, I do thank you,  that T should inform you with the detailed
test plan, prior to  testing,  so that DeAcc devices Tnc. may avoid wasted
expenditure  of time  and money.
      T wish  to  inform  you that  the  closest from Toronto,  Ontario,  to an
independent  laboratory is namely:   ATOMATES,,CUSTOM SYSTEMS TIC.,  645
LUNTJAVE EIK  GROVE  VTIAGE,  Jt~   As  they arRecognized by E.P.A.  and
their equipment  is identical  or equivalent to that used by E.P.A.

      I do my best  Mr.  Korth to  answer your comments,  that additional
information/explanation is needed  in several areas,  my answers are
below:

      1.  First  - how will the device marketed through service and
         installation  shops,  etc.?

         The first answer is  that  the device will be marketed through
         service and installation  shops,  and hopefully, that through
         the Canadian  Automobile Association in the U.S.A. and in Canada
         will be marketed.

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                         - 2 -
What is the cost of the device?

The answer is prefix, and below the following represents a
short form cost projection for production of the DeAcc device.

Initial production of the economy model will utilize manual
assemble of standard parts, presently available from several
industries at wholesale costs, as set out below, herein.

Future mass production with customized components, assemble
techniques and higher ratio  of number of employees versus
basic overhead/equipment cost should reduce the production cost
by up to kQ% in Canada and in U.S.A. approximately up to

A.  PRODUCTION COST

    Farts

    Qty   Parts Description            Unit Cost     Total
7
7
6
1
1
1
3/8 O.D. Copper tubing
3/8 T.D. P.C.V. hose
Hose clamps
3/8 O.D. (male) air valve
3/8 O.D. (male) air filter
F/W clamp W. screws
$0.30
$0.60
$0.17
$3.60
$0.70
$0 . 46
$2.10
$4.20
31.02
$3.60
$0.70
$0.46
                                       Parts Total  $12.08

    Optional

    1     Plastic Casting for Device     $3-50

    Packaging and Printing

    1     Blister pkg/instructions       $0-55      $0-55
    1/10  Shipping carton/labels/tapes   $0.80      $0.08

    Equipment (Combined cost per hour)

    1/2'hr rental or purchase amort.     $3-00/hr   $1-50

    Labour (including socal contributions)

    1/2 hr coil tubing, solder fittings $18.00/hr   *9-00
           attach hoses and filter test
           package.

    Overhead (combined cost per hour)

    1/2 hr  Office/plant facilities     $15-00/hr   $7-50
            services and supplies
            legal taxes, insurance

-------
                           Unit Cost/Retail            $78.06

Neither the application nor the patent gives a clear of concise
explanation of how ... etc.  This device an improvement ... etc?

The device function is simple.  The device has four conduits,
connected to the device gas-mixing chamber.

The first conduit connected to the P.C.V. Valve with a sefc^n,
foot copper tubing to control direct flooding in the intake
manifold, and the other end of it connected to the device
gas chamber.

The second conduit leads from the device gas-chamber to the  intake
manifold, where the varying vacuum condition draws the unused
gases,  the so called "hot blow by gases" through the seven foot
copper conduit, from the P.C.V.  valve to the device gas-mixing
chamber.

-------
   The third conduit leads from the device gas-chamber to the exhaust
   pipe manifold,  and through the vacuum conditions the NOx - H.C.  -
   C.O. - gases drawn into the device gas-chamber.

   The fourth conduit leads from the device gas-chamber to the air
   filter of the engine,  and through the vacuum conditions oxygen-air
   drawn in to the device gas-chamber.

   In conclusion of the device functions and the improvement over
   the standard P.C.V.  valve is the following explanation:  The
   device recycle the unburd gases through the device gas-chamber,
   where mixed with oxygen to be lead into the intake (vacuumed)
   manifold to reburn.

   The catalytic actions reactions are plausible,  it has not been
   verified; I do consider it worthwhile to have a test with and
   without the 7 foot copper conduit.  But it is thought that when
   copper oxide is present in the 7 foot copper conduit mixed with
   oxygen some conversion of nitrogen oxide to nitrogen will occur.
   The driving force of this reaction resides in the high thermo-
   dynamic stability of nitrogen gas.

   The presence of oxygen in the device gas-mixing chamber may
   also cause some conversion of the copper to copper oxide.  In
   turn, the copper oxide may be reduced, at least in part to copper
   by the action of hydrocarbons (H.C.) and carbon monoxide (C.O.).

   This two reaction would tend to regenerate the copper while
   also reducing the content ratio of C.O. and H.C.

4. >Will the use of the three (four) tubes to the induction system
   change ... etc?

   The overall fuel/air ratio is altered through the device.  The
   reason is that the so called "blow by gases" add to the fuel/air
   intie and alter for the best, the F/A ratio in the combustion
   process  in the individual cylinders.

5« Additional details are needed ... etc?

   (a)  First an emission control test (SCOPE) to balance the
        carburator F/A mixture to the U.S.A. or Canadian Government
        requirements in idle condition of the engine.

   (b)  Find a place in the  engine compartment 5" by 6" in length,
        2" thick where it is safe and secured with a clipper.

   (c)  Connect the first conduit to the P.C.V. valve, with a hose
        c1amp.

        Connect the second conduit to the intake manifold, with a
        hose clamp.

-------
                         - 5 -
     Connect the third conduit to the exhaust manifold pipe
     after an outlet welded out into it,  by 3/8"i  then has
     to weld into the exhaust pipe,"a 8"  - 10" heat resistant
     steel tube, that the third conduit which is made of rubber
     won't burn.  (The rubber hose other side is connected
     to the device gas-chamber).   Tf the engine prior 1964
     has an old choke tube so use a T shaped connector (natur-
     ally have to cut the choke rubber tube to do this) and
     connect the hose from the device gas-chamber with the
     T shape connector.  The steel tube welded into the
     exhaust system for hot-heat into the choke, but after
     a short time the "heat resistant" 7" or 8" length tube,
     which is connecting a rubber hose directly into the
     choke; collapses, and errosion takes place through the
     constant high heat from the exhaust system.  Therefore
     emission gases of 0 C.-H.C.-N.0.x in presence in the
     choke, but with the T shape connector, the emission
     gases vacuumed into the device gas chamber and reburn
     in the process of combustion before entering into the
     old choke system.

(d)   The fourth conduit is connected to the engine air filter
     where a hole of J/5" should be made to lead the rubber
     conduit from the device air intake valve into the engine
     air filter 1/2" inwardly, and a larger clipper needed
     then thejhole, so it should hold inwardly the rubber hose
     and it can not slip out from the air filter.  The other
     end of the fourt conduit is connected to the device manually
     adjustable air intake valve and through it the air enters
     to the device gas chamber.

(e)   As the emission standards is set by the U.S.A. - Canadian
     Governments and the requirements in idle engine condition
     for example 0.40$ C.O. or 1.003 C..C. or 3.00^ C.C. as it
     would register on a "SCOPE" emission test device, then
     the manually adjustable air intake valve has to be open
     as far or further till the "SCOPE" emission test device
     shows 0.00^ C.C. in idle-deceleration.

(a)   Are all parts necessary for installation supplied with
     the device?

     Yes, all parts necessary will be supplied by DeAcc Devices
     Inc .

(b)   Will the device be installed by the .purchaser/vehicle
     owner?

     The installation will be, has to be by a specialized
     professional.

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                          - 6 -
(c)   Does the F.C.V.  remain on the engine?

     Yes, the P.C.V.  remain on the engine.  To replace it the
     cost of the device would be higher, but not for the auto
     leading manufacturers.

(d)   Detailed device installation instructions are needed.

     The answer is explained from the beginning of question
     no. 5 through a,b,c,d,e.

(e)   The control valve to the air filter is adjustable,
     how is proper ... etc?

     The answer is explained through No. 5 (e).

( f)   Vehicle specific installation instructions are needed
     for the tube ... etc.

     The answer is explained through No. 5 (c) "connect the
     third conduit."

6.   The section on device operation notes "to assure efficiency
     and mechanical operating efficiency"... etc.

     The answer is explained through f-:o. 5 a,b,c,d,e, - these
     instructions will be furnished with the device.

?.   The section on device maintenance refers to an  ... etc.

     The emission test with a "3CCFE" emission test device
     would show what are the criteria for determining the
     lean condition in the carburator system of an engine.

     The emission standards is set by the governments and
     the requirements have to be set through the carburator
     in  idle engine condition to not have lean operation.

8.   What are the specific claims for the device, anticipated
     . .  . etc .

     The improvements are in emission and fuel economy by
     recycling .the so called "blow by gases" and use it as
     an added fuel with the engine system and reburn it in
     the combustion process in the individual cylinders,  with
     the emission gases:  C.0.-H.C.-N.0.x.

9-   Please provide detailed information on the catalytic
     action  ...  etc.

     The role of thejcopper tubing (in the patent No. 3^)
     is  considered to be as follows.   As hot gases are drawn
     through Ho. J.k from the crankcase,  it is thought that
     the concentration of N.C.-x.  gas  (primarily mono-nitrogen
     oxide)  in the crankcase gas v.'il]  be reduced by the
     rf ac t i or;:

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                        -7-
 9.    Simutaneously,  the  presence  of  oxygen  may  also
      cause  some  conversion of the copper  oxide.   In
      turn the  copper oxide may be reduced back  in
      part to copper  by the action of hydrocarbons (H.C.)
      and carbon  monoxide (C.O.).

           C.U.O.  + C.O.    C.U.  +  C.O..
           C.U.O.  + H.C.    C.U.  H-'C.O.g.' + H20.

      This two  reaction would tend to regenerate the.
      copper while also reducing carbon  monoxide (C.O.).

      Because the copper is regenerated  the  term
      "cataoy'tic" has been used.   Strictly speaking,
      however,  the copper is not really  a  cata6ylic
      agent because  it is produced and regenerated in
      two separate reaction.

            N.O. +  C.U.    C.U.O.  + 1/2  N2


      That is  to  say, some conversion of nitrogen oxide
      to nitrogen will occur, with the simultaneous for-
      mation of copper oxide.  The driving force for this
      reaction  resides in the high thermodynamic stabil-
      ity of nitrogen gas.  (Question No.  3  explained it)

10.    From the  information provided,  it  appears  that  you
      expect full benefits   ...  etc.

      Yes, I would like to have full  benefits immediately
      and as you  say that there is no need for mileage
      accumulation.

      Thank you,  Mr.  Korth, for your  .letter.

                         Sincerely yours,
                         S.  De Pakh
                         President
                         90  Warren Road
                         Suite 110
                         Toronto, Ontario
                         Canada, M4V 2S2

                         Phone, (416) 923-124-8

-------
                                                         Attachment H
               4UTOM4TED CUSTOM 5VBTEM5 INC.
              1238 West Grove Ave., Orange, CA 92665-4134 (714) 974-5560
June 11, 1986

Mr . Stephan DePakh
DerAcc Devices,  Inc.
90 Warren Rd.
Suite 110
Toronto, Canada M4V252
                     REF: EPA 511 Test  Program
Dear Mr. Depakh,
Confirming  our telephone conversation  of  June 11, 1986, en-
closed is our current price schedule reflecting the cost en-
volved to perform a 511 Test Program.   For your further ref-
erence,  I have also attached an example copy of a completed
511 program,  (Highway Fuel Economy Only),  computer print out.

Automated Custom Systems presently has in their possession
the following vehicles with over  50,000 miles which may be
used for your program:

                        TYPE                 MILES
                        Olds Custom Wagon   60,153
                        Lincoln Mark IV     79,281
                        Olds Cutlass        86,000

The above vehicles may be utilized at  a cost of $100.00 each
for your program.

You indicated that milage accumulation would not be required
for your device.  Therefore, the  program for two vehicles
could be completed in two working days .  This test program
could be scheduled immediately with one (1) week advance
notice.

We again thank you for your interest in our company and cap-
abilities and look forward to performing your test requirements
in the future^

Sincerely,
   10/um
Loren  T.  Mathews
Vice President /Gen. Mgr
LTM/jms
Chkifo
B64SLui»tAvt.
 Bk Grow
 (J12) Mi-1790
lL 60007
Denver
OlB3»)MperS«.
 Aurora. CO «0011
 (303)3444470
                                                     Ft. LaudenUle
                                                     D 1000 Wwt Newport Gmter Driw
                                                      OwrfttU Bach. to* 33441
                                                      (305) 4M-2M3

-------
                                                               Attachment I
Arthur L. Smith, BA
Barrister & Solicitor
Suite 1606, 141 Adelaide St. West, Toronto, Ontario M5H 1V7  (416) 864-9677
                                                        July 24, 1986
         Mr. Merril W.  Korth
         Device Evaluation  Coordinator
         U.S.A. Environmental Protection
           Agency
         2565 Plymouth  Road
         Ann Arbor, Michigan
         48105, U.S.A.
         Dear Sir:
                           Re:   DeAcc Devices Inc.
                           	-  E.P.A.  511 Test Programme
                    I have been  asked to write to you by my client,
         DeAcc Devices  Inc.,  to confirm that Mr. Stephen DePakh will
         attend at  the  office of Automated Custom Systems Inc. on
         Monday, August 4,  1986.   My client has requested that a
         copy of the test results be forwarded to you by Automated
         Custom Systems Inc.

                    My client  further instructs me to thank you for
         your co-operation  and  the assistance that you have rendered
         to him in  arranging  for the test programme.
                                          Yours very truly,
                                          Arthur L. Smith
         ALSrbr.

-------
                                                    Attachment J
       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                    ANN ARBOR. MICHIGAN 48105
          -*•                                             OFFICE OF
          *•                                          AM AND RADIATION
July 9, 1986


Mr. Stephen DePakh, President
DeAcc Devices Incorporated
90 Warren Road, Suite 110
Toronto, Canada  M4V 252

Dear Mr. DePakh:

     We received  your  letter of  May 24,  in which you  responded
to  our request  for clarification  and added  information  about
your "Emission  Control  Device."  It  appears you have  addressed
all our questions  and  are ready to proceed with  the  independent
laboratory testing.

     The  test plan  we  previously  suggested  (Test  Plan Code  A
using  test  sequence code  4,  with  replicate  FTP and HFET  tests
both with and without  the device on each of two  vehicles)  still
appears to be the  minimum test plan required.  FTPs  rather than
LA-4s  are  needed  for  your  device,  since  the  fuel  economy
benefits  are  to   achieved  principally   through   an   emission
improvement.

     Please  note  this  is  eight FTPs (3  bag test)  and  eight
HFETs,   not  eight  LA-4s  (2  bag  test)   with  eight  HFETs  as
suggested  in  your  letter.   Again, please let  us  review  your
detailed test plan  prior  to testing.  Also, we would appreciate
knowing your  test schedule  (dates)  prior  to testing.

     If  I  can be  of  any  further assistance,  please contact  me
at  (313)  668-4299.

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

-------
                             DeAcc Devices Inc.
f-ATENT AGtNT:
SIM a MCBURNEY

CONSULTANT:
PROFESSOR A. CORSINI. ASSISTANT DEAN
Or SCIENCE (STUDIES). M CM ASTER UNIV.
DECELERATION
             ACCELERATION
                                    Attachment K



                                  TELEPHONE (416) 923-1248

                                 TORONTO. ONTARIO. CANADA
   CONTROL SAVE GASOLINE
PRESIDENT:
STEPHEN DE PAKH
                                                        August 8, 1986
       Mr. Loren T. Mathews
       Vice-President and General Manager
       Automated Custom Systems  Inc.
       645 Lunt Avenue
       Elk Grove Village
       Chicago, Illinois 60007
       U.S.A.

       Dear Mr. Mathews:


                 Further to our  meetings in  your office in Elk Grove
       Village on August 4th last,  I wish  to confirm what was resolved
       during our discussion, as follows:


                  (a)  You had not been  advised of the required test
                      procedure  by  Mr.  Korth of the Environmental
                      Protection Agency, due to your trip to Korea
                      from which you returned on August 3rd last;


                  (b)  The E.P.A. requirements are that you conduct
                      eight F.T.P.'s and eight H.F.E.T.'s (3 bag test);


                  (c)  Your 1982  oldsmobile station wagon (60,153 miles)
                      and your 1981 Lincoln  Mark IV (79,281 miles) are
                      to be tuned by your  master mechanic and soaked
                      immediately without  being driven; "


                  (d)  The carburetion systems of the two cars are to
                      be set to  the manufacturer's specifications;


                  (e)  It is extremely important that the carburetion
                      systems should not be  "leaned",  (i.e.  not suf-
                      ficient oxygen or not  sufficient fuel);

-------
                       - 2 -                      August 8, 1986
            (f)  The carburetion systems should be rich in order
                to create the utmost power efficiency of the
                engines;


            (g)  The cost of the above testing procedures will
                be $8,450.00 as confirmed in discussions with
                yourself, Mr. Furton and Mr. Korth, and I
                shall have with me a certified cheque in payment
                of this amount.

            (h)  The tests on the engines are to be conducted on
                August llth and 12th without the device and the
                data is to be available on August 13th at 10:00
                a.m. when I arrive at your office.


            (i)  I shall bring two devices with me so that the
                hot and cold comparison tests can be done com-
                mencing August 13th.


            (j)  The devices will be put on the engines by your
                master mechanic which procedure should take
                approximately one minute per engine.


           I wish to thank you for your co-operation and look
forward to meeting with you on August 13th next.
                                       Sincerely,
                                       Stephen DePakh
SDePrbr.

-------
                                                               Attachment L
CORPORATE ATTORNEY:
R. M. LIEBERMAN

PATENT AGENT:
SIM & McBURNEY

CONSULTANT:
PROFESSOR A. CORSINI, ASSISTANT DEAN
OF SCIENCE (STUDIES). MCMASTER UNIV.
  DeAcc Devices Inc.
DECELERATION
              ACCELERATION

    CONTROL SAVE GASOLINE
                                  TELEPHONE ( 4 I 6 > 923-1 248

                                  TORONTO. ONTARIO, CANADA
PRESIDENT:
STEPHEN DE PAKH
                                                          August 8,  1986
         Mr. Merril  W.  Korth
         Device Evaluation Co-ordinator
         U.S.A. Environmental Protection
           Agency
         2565 Plymouth  Road
         Ann Arbor,  Michigan 48105
         U.S.A.

         Dear Mr.  Korth:


                    I am pleased to advise that  the  test plan you sug-
         gested will be performed by Automated  Custom Systems Inc.
         on August llth to 14th next at their laboratory in Elk Grove
         Village,  Illinois.  Please note that eight F.T.P.'s (3 bag
         test) and eight H.F.E.T.'s will be performed as suggested in
         your letter of July 9, 1986.

                    I enclose a copy of my letter  of August 8, 1986,
         to Mr. Mathews confirming the testing  procedure.  The test
         results will be forwarded by Mr. Mathews upon completion of
         the tests.

                    I wish to thank you for the  interest you have shown
         in my invention.
                                               Yours  sincerely,
                                               Stephen  DePakh
         SDeP:br.

         Encl.

-------
                              CUSTOM SVST6MS INC.
                                                                 Attachment M








I                     1238 West Grove Ave., Orange, CA 92665-4134 (714) 974-5560
   DeAcc Devices Inc.                                    September 3, 1986
   90 Warren Road
   Suite 110
   Toronto, M4V 2S2, Ontario,
   Canada
                                  Reference:  EPA 511 Test Program

   Gentlemen,

   Confirming our telephone conversation, attached are the original copies
   of all the associated test  reports covering the above referenced EPA  511
   run on 2 ACS provided vehicles.   The attached summary sheets detail the
   test results.

   Several points regarding this  test program are clarified and detailed
   below:

   1.  The 1984 Chevrolet Camaro  received 2 HFET preps throughout the
       program prior  to  the data  acquisition at the end of the third cycle.

   2.  Both vehicles  were baseline tested on 8/12/86 and 8/13/86 after
       an LA-4 prep on 8/11/86.   One day, 8/14/86, was lost during the
       program because Mr.  DePakh failed to arrive as scheduled with the
       2 devices.   Mr. DePakh  finally arrived the morning of 8/14/84 with
       the devices  which were  installed as further described below.  LA-4
       prep cycles  were  performed on both vehicles and removed for 24 hour
       soak.  NOTE: It should  be  noted that the 2 devices were NOT IDENTICAI
       in mechanical  configuration.  Furthermore, ACS was not provided with
       a detailed instruction/installation set-up manual.  Mr. DePakh
       indicated that EPA Ann  Arbor had reviewed the manual and he would
       instruct our personnel  during the installation.

   3.  INSTALLATION
       A.  ITEM  (j) of Mr.  DePakh's 8/8/86 letter indicated that the device
           would be installed  in  the respective vehicles in 'approximately
           one minute per engine.'  For your reference, the following
           describes  in  detail the installation procedure as supervised  by
           Mr. DePakh:
       B.  Completely remove air  filter assembly.
       C.  Remove existing PCV line from intake manifold.
       D.  Install  one line from  the device on PCV fitting (Item C)
       E.  Original PCV  line connects to second line on the device.
Ann Arbor           CMcago           Denver           Ft. LaudenUIe

                     UntA          Ol859,..p.rS*.       D 1000 W...

-------
            >1UTOM>lTeD CUSTOM 5VSTEM5 IIMC.
F.  The third line from the device was to be installed in the exhaust
    manifold!!   To accomplish this, Mr. DePakh advised us to drill a
    hole in the exhaust manifold and install a threaded fitting with
    a 3 inch 1/4 inch tube to act as a heat sink rubber tubing.
    Obviously,  ACS refused to alter the provided test vehicles in
    this manner.  As mutually agreed, the third line was tapped
    into a 20 foot rubber hose and terminated at a 1/4 inch fitting
    installed in the standard silicon exhaust boot.
G.  The fourth line (intake air) was placed randomly within the
    engine compartment.
H.  Both devices contained a brass needle valve which during idle
    was adjusted and set 'by ear' by Mr. DePakh.  An LA-4 prep was
    performed and the vehicles removed to the soak area.

It should be quite obvious to the most casual observer that the
installation procedure took considerably longer than 'one minute'
as originally indicated!!

INITIAL PREPARATION OF ACS TEST VEHICLES
The ACS provided test vehicles were set-up and prepared for the
test program along the guidelines established by the U.S.E.P.A.
This procedure was set-up over 4 years ago and all 5 locations of
Automated Custom Systems, Inc. have been recognized by the U.S.
Environmental Protection Agency as having the facilities, equipment
and personnel necessary to conduct exhaust emission tests on light
duty motor vehicles in accordance with the current Federal Test
Procedure.  Mr. DePakh made several derogatory statements regarding
our set-up and vehicle qualification procedures which I therefore
feel should again be restated in detail. It should be further
noted that the ACS 'general vehicle procurement procedure' usually
involves local rental vehicles with low milage as detailed in
your original letter from E.P.A.  In the case of DeAcc, we were
requested to provide older vehicles with approximately 50,000
miles.
A.  Check and set timing to factory specifications.
B.  Check spark plugs and replace as required.
C.  Check and replace filters as required.
D.  Check cap, rotor and wires.
F.  Oil change as required.
G.  Check idle RPM.
Mr> DePakh's  letter  also  indicated  'carburetion systems should
 e rich  in  order to  create the utmost power.'  As you know, the
vehicles we provided for  test come  from the factory with sealed
adjustments,  thus  preventing tampering.  Late model vehicles,
included those  fuel  injected, include closed loop Lamda systems
which also  are  not adjustable.

It should be  noted that the baseline emission numbers obtained
on the 2 ACS  provided test vehicles were found to be acceptable
by EPA during a telephone conversation on 8/15/86 with Mr.  Korth.
Mr. Korth further  advised that since no adjustments could be
made to  the carburetion systems that the devi      ting should
precede  per our established procedure.

-------
           XlUTOM/lTeD CUSTOM SVSTEMS INC.
Based on the above, ACS feels that Mr. DePakh's comments about
the 1982 Oldsmobile are unfounded and the vehicle is certainly
representative of on the road models of this type.  However,
ACS will agree to run a third test program oh a late model,
fuel injected, low milage vehicle provided by DeAcc Devices Inc.
The program proposed is as follows:
a)  Parameter Check
b)  LA-4 Prep
c)  12-36 Hour Soak
d)  Cold FTP (3 Bag)
e)  HFET Prep
f)  HFET with Data
g)  12-36 Hour Soak
h)  Cold FTP (3 Bag)
i)  HFET Prep
j)  HFET with Data
k)  Parameter Check
Install device and repeat steps a-k.  It is further suggested that
the vehicle provided have provisions to quickly install the third
device line to the exhaust manifold, such as a 1/4 inch capped
Swagelok fitting.  A detailed instruction manual will be provided.


COST TO DEACC DEVICES, INC.                       $3000.00

The program will be completed in 5 days, Monday-Friday and 1 week
notice is required.  Payment will be by certified check in U.S.
dollars immediately prior to testing.
Sincerely,
Loren T. Mathews
Vice President

-------
                                                            Attachment N
CORPORATE ATTOHNEY;
PATENT AGENT:
SIM & MCBURNEY


CONSULTANT:
PROFESSOR A. CORSINI. ASSISTANT DEAN

OF SCIENCE (STUDIES) . MCMASTER UNIV.
  DeAcc Devices Inc.
DECELERATION ^^B ACCELERATION

   CONTROL SAVE GASOLINE
                                                            TELEPHONE (416) 923-1248

                                                            TORONTO, ONTARIO. CANADA
PRESIDENT:
STEPHEN DEPAKH
       REGISTERED MAIL

       31 October 1986

       Mr. Merril W. Korth,
       Device Evaluation Coordinator
       U.S.A. Environmental Protection Agency
       2565 Plymouth Road,
       Ann Arbor, Michigan
       48105 U.S.A.

       Dear Mr. Korth:

       Re;  DeAcc Devices
                    ?st Programme
       During our last  telephone  conversation,  I tried to explain
       what occured  regarding Automated Custom Systems Inc.  in
       Chicago.

       On Monday, August 4,  1986, I arrived at Chicago with a
       certified cheque for  $6,000.00 U.S.  which was the amount
       quoted by Loren  T.  Mathews to conduct the E.P.A 511 Test
       Programme on  two different cars.

       Mr. Mathews informed  me in the morning that he had just
       returned from Korea and that he had to leave immediately
       for an appointment with his dentist.  Mr. Roy D. Sinclair,
       the Manager,  was left in charge and he informed me that
       Automated Custom Systems Inc. does not have a mechanic on
       their staff,  which comprises three people and a secretary.
       At this point, I wanted to leave to return to Toronto, but
       Mr. Sinclair  asked me to remain and showed me a piece of
       paper on which was written, "prepare three bag tests".  He
       was afraid that  if I  left  he might be blamed and he would
       be fired, although Mr.  Mathews had not discussed the tests
       with him.

       I waited for  Mr.  Mathews until 3:00 p.m. and at which time
       I mentioned to him that the cars were not prepared for the
       test  (they were  untuned and thick dust covered the engines)
       and that I could not  wait  for two days,  and then I left.
       On the way back  to Toronto, I stopped at Ann Arbor and met
       with the President of Automated Custom Systems Inc.,  who
       telephoned Mr. Mathews in  Chicago and he was informed that
       the price for future  tests had risen from $6,000.00 to

-------
Mr. Merril W. Korth...2                   31 October 1986
$8,450.00 U.S.  The President of A.C.S.I, apologized to me
and suggested that I make another appointment, which was
made for August 14th.  I am enclosing a copy of a letter
dated August 8, 1986 which I sent to Mr. Mathews setting
out my understanding of what had been resolved at our
earlier meeting, as well as what my specific requirements
would be on my return to Chicago on August 14th.

I requested proof that the engines were not leaned down but
running rich, and it was not available.  I obtained
information from a mechanic next door to A.C.S.I, that he
had done a minor tune up, that the engines were running
lean and that the carburetion system should be opened up in
order to create power efficiency in the engines.

After I had a lengthy discussion with Mr. Mathews, he
wanted to refund me the sum of $3,500.00 U.S. which I
refused to accept.  At that time, I telephoned you and
informed you of the discussion I had with him, and he
assured you that the cars were tuned up rich and I decided
to proceed with the tests.  After the tests were conducted,
he informed me:  "I have to show the test results to an
expert for him to figure it out".  I did not receive his
letter in which he enclosed the results until a month after
the tests.

Mr. Mathews  indicated in his letter that the two devices
were not identical.  He  is wrong in making such  a
statement; one of them was packed  into  a stainless steel
box, but both were the same mechanically.  Furthermore, he
stated in his  letter that the  installation lasted longer
than 1-2 minutes.  This is because he did not  call in a
mechanic whom  I could instruct on  the  installation, which
should not have taken more than  1-2 minutes.   The
Manager, Mr.  Sinclair, said:   "I am not a mechanic, but I
have to do the  installation".  As  a result, it took
longer.  Furthermore, a  dealer such as  General Motors, who
is familiar  with the carburetion system and an  engine which
has run over 60,000  miles, should  have  checked  it out.  I
suppose Mr.  Mathews  did  not want to incur  further expenses
so the mechanic whom he  hired  did  a minor  tune up.

I wish to inform you that two  cars, an  Oldsmobile and a
Camaro, both 305 c.c. V-8 4 barrel engine, had  similar
percent emission gases and with  the device installed the

-------
Mr. Merril W. Korth...3                 31 October 1986
Camaro had over a 60% average reduction of the emission
gases.  An Ontario dealer, General Motors, conducted a test
on a 305 c.c. V-8 4 barrel engine, 6221 km. on the
odometer, a 1985 Buick, and the fuel economy improved
21.9%, idle: No C.O.  (see copy attached).

I also wish to inform you that a third 5-day test programme
can be conducted by Automated Custom Systems Inc. at the
cost of $3,000.00 U.S.

With your assistance and your prestige, I feel that Mr.
Mathews can be made to realize after your engine analysis
that DeAcc Devices Inc. is entitled, with your approval, to
one E.P.A. 511 Test Programme without cost.  In the
alternative, I would prefer to have the test done in the
laboratories of your agency.

Mr. Korth, in Chicago, two cars were tested at the cost of
$8,450.00 U.S. within 5 days.  Mr. Mathews is offering a
one car test  (511 Programme) for $3,000.00 within 5 days.
Is this generosity to DeAcc Devices Inc. or an admission of
his mistakes?

I wish to take this opportunity to thank you for your
assistance up to the present time and in the future.

Respectfully yours,
         -'  v.  , V  •* > ^
Stephen  DePakh,  President,
DeAcc Devices  Inc.
 SDP/dr
 Encls.

-------
                                                                                                 Attachment 0
AUTOMATED CUSTOM SYSTEHS,  INC.
ELK 6ROVE, IL.  60007

CUSTOMER: DEACC DEVICES, INC.
          TORONTO, CANADA

TEST-TO-TEST VARIABILITY WORKSHEET
                                                   TEST WEEK:   8/11/BA
                   EPA 511 TEST PROGRAM
                 MMMMMMMMMMMMM
AUTO/YR: 1984 CHEVROLET
MODEL: 2 DOOR CAMARO RED
VIN: 161AP87H2EL105034
DRIVER: RAY SINCLAIR
OPERATOR: CHUCK SHOEMAKER
COMMENTS: BEFORE/AFTER BACK-TO-BACK
BASELINE VEHICLE TPST DflTEs 	
TEST RUN ODOMETER

1 24,737
2 24,787
MEAN
S.D.
C.V.

FINAL VEHICLE
TEST RUN ODOMETER

I 24,837
2 24,919
MEAN
S.D.
C.V.

PERCENT CHANGE
COLD START FTP
HC
0.294
0.281
0.288
0.009
3.2
tm
TEST DATE
CO
2. 586
2.372
2.479
0.151
6.1
MM
t
COLD START FTP
HC
0.301
0.552
0.427
0.177
41.6
MM
48.35
CO
2.696
2.702
2.699
0.004
0.2
mt
8.87
8/12/86,

C02
638.7
632.1
635.4
4.649
0.7
mm
8/15/86,

C02
636.5
642.5
639.5
4.197
0.7
mm
0.6
8/13/86

NOX
1.126
1.146
1.136
0.014
1.2
MM
8/16/86

NOX
0.747
0.796
0.772
0.035
4.5
MM
-32.09
ENGINE CID: • 305/8 CYLINDER
TRANSMISSION: AUTO
A/C EQUIPPED: YES
CURB MT: 3186
INERTIA NT: 3500
HP ACT/IND: 12.3/10.4
HFET (AFTER
F.E.
13.777
13.927
13.85
0.106
0.8
MM

HC
0.176
0.389
0.283
0.151
53.3
MM

HFET
CO
5
8
7
1



HFET (AFTER
F.E.
13.819
13.676
13.75
0.101
0.7
mt
-0.75
HC
0.107
0.101
0.104
0.004
4.1
MM
-63.19

3
3
3
0


.713
.309
.011
.836
26.2
MM

HFET
CO
.399
.956
.678
.394
10.7
mt
-47.55
PREP)
C02
445.1
442.8
443.9
1.653
0.4
MM

PREP)
C02
440.7
438.2
439.4
1.785
0.4
mt
-1.02

NOX
2.050
2.272
2.161
0.157
7.3
mt


NOX
0.655
0.675
0.665
0.014
2.1
MM
-69.23

F.E.
19.51
19.40
19.45
0.073
0.4
tttt


F.E.
19.87
19.94
19.91
0.052
0.3
tttt
2.32
 NOTE 1:  Exhaust emissions are  in qrais per lile, fuel  econoiy  is in illes per gallon.
 NOTE 2:  C.V.  is the Coefficient of Variation for the tests.
 NOTE 3:  C.V. =
STANDARD DEVIATION

       MEAN
X 1001

-------
AUTOMATED CUSTOh SYSTEMS, INC.
TEST KEEK:  8/11/86
CLf. DKUVC, JL. OUUU/
CUSTOMER: DEACC DEVICES, INC.
TORONTO, CANADA
TEST-TO-TEST VARIABILITY WORKSHEET
EPA 511 TEST PROGRAM
HHHHHHHHHHHHH
AUTO/YR: 1982 OLDSMQBILE
MODEL: CUSTOM CRUISER BROWN
VIN: 1G3AP35Y6CK 106335
DRIVER: CHUCK SHOEMAKER
OPERATOR: RAY SINCLAIR
COMMENTS: BEFORE/AFTER BACK-TO-BACK
BASELINE VPHTT.IF TFST nATF- 	 fl/17/RA.
TEST RUN
ODOMETER COLD START FTP
HC CO
1
2
MEAN
S.D.
C.V.

FINAL
TEST RUN

1
2
MEAN
S.D.
C.V.

PERCENT
NOTE 1:
NOTE 2:
unit t.
61,567 0.543 2
61,607 0.484 2
0.514 2
0.042 0
8.1
HH
VEHICLE TEST DATE:.
ODOMETER COLD START
HC
61,644 0.592 3
61,696 0.591 3
0.592 3
0.001 0
0.1
HH
.897
.554
.726
.243
8.9
HH

C02
623.
612.
618.
7.
1.


5
5
0
7
3
mm
	 8/le,/flA.
FTP
CO
.512
.257
.385
.180
5.3
HH
CHANGE 15.19 24.18
Exhaust emissions are in qrais
C.V. is the Coefficient

C02
671.
668.
669.
2.
0.


2
0
6
3
3
HHH
8.
per
4
8/13/86

NOX
1.380
1.313
1.347
0.047
3.5
HH
8/16/86

NOX
0.842
0.794
0.818
0.034
4.1
HH
-39.25
ule, fuel
of Variation
STANDARD DEVI A
p U - 	
TION

for the
» 1f\M
ENGINE CID: 305/8 CYLINDER
TRANSMISSION: AUTO
A/C EfiUlPPED: YES
CURB HT: 3964
INERTIA HT: 4250
HP ACT/IND: 13.2/11.2
HFET (AFTER HFET
F.E.
14.083
14.348
14.22
0.187
1.3
HH

HC
0.131
0.139
0.135
0.006
4.2
HH

CO
0.359
0.435
0.397
0.054
13.5
HH

HFET (AFTER HFET
F.E.
13.068
13.138
13.10
0.049
0.4
HH
-7.83
econoiy
tests.

HC
0.164
0.167
0.166
0.002
1.3
HH
22.59
is in liles


CO
0.670
0.596
0.633
0.052
8.3
HH
59.45
PREP)
C02'
401.7
388.6
395.1
9.266
2.3
HH

PREP)
CQ2
414.7
416.5
415.6
1.263
0.3
HH
5.19

NOX
1.418
1.335
1.377
0.059
4.3
HH


NOX
0.885
0.864
0.875
0.015
1.7
HH
-36.47

F.E.
22.02
22.76
22.39
0.518
2.3
HH


F.E.
21.30
21.22
21.26
0.060
0.3
HH
-5.05
per gallon.








                                 MEAN

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                                                                     Attachment P
.543
.484
1.027
.592
.591
1.183
2.210
.294
.281
.575
.301
.552
.853
1.428

1.602

2.036
3.638
            Detailed Example of Analysis of Variance Calculation

                              FTP HC Emissions


                      OLDS         CAMERO        ROW TOTALS

Baseline


SUM

DeAcc


SUM

TOTALS

r=2  No. of Rows = No. of Configurations (with and w/o Device)

c=2  No. of columns = No. of Vehicles

N=8  Total No. of Tests

n=2  No. of Replications

T=  3.638 sum of X's where X = value of each test

T2/N=  3.6382/8 = 1.654

SX2= Sum of X2 = 1.790

SSC Sum of squares among columns (cars)

  = (2.2102 + 1.4282)/ (2x2) - 1.654 =  .076

           Tc 2         nxc    T2/N

SSr= Sum of squares among rows (device  vs no device)
      (1.6022 + 2.0362)/(2x2) - 1.654 = .024

           Tr2            rxc      T2/N

SScr= column row interaction = Sum of squares of rows and columns
= (1.0272 + 1.1832 +  .5752 +.8532)/2 -  1.654 - .076 -.024 = .0002
                 Tcr 2         n  T2/N         SSC      SSr
SSt = Sum of squares total

    =SX2       T2/N

    = 1.790 - 1.654 =  .135

-------
                              FTP HC Emissions
Source

Among col
  Cars Effect
              Sum
                Squares
                	SJ5

                .076
Among Rows      .024
  Device Effect
Coi/Row
Interaction
                .002
Degrees    Mean    Mean Sq.
Freedom    Square  Ratio        MSR  w 90%
  DF       SS/DF   MSR=MS/MSRS  Confid. Factor
2-1=1
c-1

2-1=1
r-1
.076
                                     .024
           .002
9.175
        2.826
         .223
4.54
             4.54
             4.54
Residual
Total
                .033
                 135
Total-Sum
Of Prev
4-3=4

N-l=8-l=7
.008
                                     2.826 is less than 4.54 therefore
                                     no statistically signficant device
                                     effect on emissions
              Summary of Statistical Analysis of Device Effects
                           By Analysis of Variance
        FTP
HC Emissions

CO Emissions
NOX Emissions
MPG Economy
                          Minimum
                        Mean Square
                        Ratio
                          2.826

                         13.524


                        333.478


                         50.175
                                      MSR (4 90%
                                      Confidence
             4.54

             4.54


             4.54


             4.54
                               Conclusion
                No Device Effect

                Negative Device Effect
                     Increased CO

                Positive Device Effect
                     Reduced NOX

                Negative Device Effect
                     Reduced Fuel Economy
       HFET
HC Emissions

CO Emissions
NOX Emissions
                          1.927

                          5.435


                        280.072
             4.54

             4.54


             4.54
                No Device Effect

                Positive Device Effect
                     Reduced CO

                Positive Device Effect
                     Reduced NOV
MPG Economy
                          3.239
            4.54
                No Device Effect

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                                                     Attachment Q
       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

   *                ANN ARBOR. MICHIGAN 48105
                                                        OFFICE OF
                                                     AIR AND RADIATION
January 13, 1987
Mr. Stephen DePakh, President
DeAcc Devices Incorporated
90 Warren Road, Suite 110
Toronto, Canada M4V2S2

Dear Mr. DePakh:

     We  received  your letter of  October 31, which  included  the
test packets  for  independent  laboratory  testing  of your  DeAcc
device.   We have  reviewed  the  packets  and have  analyzed  the
results.

     The  test  program was conducted in accordance with  the test
plan we  suggested  in  our previous correspondence.  .The  vehicles
and  the  test variability  are  acceptable,  and  there appears  to
be  no  technical   reason  to  rerun  tests  or  conduct  tests  on
additional  vehicles.

     The  FTP  and  HFET  test data  were  analyzed by  the  analysis
of   variance   (ANOVA)   technique  to   determine  if  the   data
indicated that  there  was a statistically significant  difference
in  emissions  or  fuel economy due to the  device.   For  the  FTP
and  HFET,  although  the  device   reduced  NOX  emissions,  there
was  an  increase in FTP  CO emissions  and a  fuel economy penalty
for  the  FTP.   The  HFET  CO  emissions  indicated  an   overall
improvement;  however,   one  of   the  two   vehicles   showed  an
increase  in CO emissions.   The  increase   in  HC  emissions  for
both  driving  cycles  and changes  in  HFET  fuel  economy  for  the
device were not statistically significant.

     Since  vehicles  are designed  to meet  the emission  standards
for  HC,  CO,   and NOX,   our  policy   in  evaluating   emissions
and/or  fuel economy  devices is   that  a device  must  first  not
show an  adverse effect  in  any  emissions and fuel economy  tests
and  second  must  show a  significant  improvement.  -  Clearly,  the
DeAcc device did  not  pass these criteria and;  thus, we  will not
proceed  to  the   in-house  testing  phase.   The  NOX   reduction
with the  device can reasonably be attributed to the increase in
exhaust  gas  recirculation  (EGR)  rather  than  the  postulated
catalytic reactions in  the copper  line.

     A  section  511 evaluation  report on  the  DeAcc device will
be  prepared and   a  notice  published  in  the  Federal  Register

-------
announcing   the   conclusions   of  our   evaluationn   and  the
availability  of  the  final  report.   You  will  be  sent  a draft
copy  of  the  final  report  and  the  notice  prior  to  their
release.  Additionally,  the DeAcc device  will be added  to our
list  as  a  device  for  which  an  evaluation  was  performed.
Devices  on  this  list  are  categorized  by  device  type  and
effectiveness.   This  list  is distributed  to interested parties
upon request.

     Enclosed  are  the  test  packets  and  summary  sheets  you
provided.   If  I  can  be  of   any further  assistance,  please
contact me at (313) 668-4299.

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

-------