EPA-AA-TEB-511-91-1
      Second EPA Evaluation  of  the Platinum Gasaver Device
            Under  Section 511  of the Motor Vehicle
               Information  and Cost Savings Act
                           July 1991
                            NOTICE

Technical  Reports  do   not   necessarily   represent   final  EPA
decisions or positions.   They are intended  to  present technical
analysis  of  issues using  data which  are  currently  available.
The purpose in the release of such reports  is  to  facilitate the
exchange  of  technical  information and  to inform the  public  of
technical development which may  form  the  basis for a  final EPA
decision, position or regulatory action.


                   Test  and Evaluation Branch
              Emission Control Technology  Division
                   Office of Mobile Sources
              U.S.  Environmental Protection  Agency

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EPA Evaluation of  the  Platinum Gasaver Device Under Section 511
of the Motor Vehicle Information and Cost Savings Act


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

     EPA evaluations are  originated upon the application of the
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.

     In  1981 EPA  evaluated  the  device  at  the   request  of  a
distributor1.   However,  the  applicant  failed  to  conduct  the
required screening  tests  following the test protocols for this
voluntary program.   EPA  completed the evaluation  based on the
information  available  and  our   technical  assessment  of  the
technology.    EPA judged  that  there was  no technical basis  or
appropriate test data  to  support the claims for  a  fuel  economy
improvement   or   emission  reduction   due   to    the   device.
Therefore, EPA issued a report concluding that  the device  would
not have an emission or fuel economy benefit.

     This second evaluation  of  the Platinum Gasaver device was
conducted upon  the  request  of  the Federal Trade  Commission.
The unit  is a vapor  bleed device.  It  functions by bleeding  a
mixture  of  air  and   "platinum  concentrate"   through   a  "T"
connection   that  is   installed   in   the   Positive  Crankcase
Ventilation  (PCV)  line.   The  device  consists  of  a   liquid
reservoir,  proprietary   liquids,   an  orifice,  and  connecting
tubing to the PCV line.   During  vehicle  operation,  air  is  drawn
through the  controlling  orifice  by engine  manifold vacuum.  The
device  is  claimed  to  reduce  emissions,  improve  fuel  economy,
raise the octane of gasoline, and  extend engine life.
     "EPA  Evaluation  of  the  Platinum  Gasaver  Device  under
     Section  511 of  the  Motor  Vehicle   Information  and  Cost
     Savings Act,"  EPA-AA-TEB-511-81-14  or PB  81-226706.   This
     document   is  available   from   the  National   Technical
     Information  Service,  U.S.  Department  of  Commerce,  5285
     Port Royal Road,  Springfield, Virginia 22161.

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 1.   Title:
      Request  for Evaluation  of  Platinum  Gasaver  Under Section
      511  of the  Motor  Vehicle Information  and Cost Savings Act
•The  information  contained  in  sections  two  through  five which
 follow, was extracted  from  various  documents.
      Identification  Information:

      a.    Marketing  Identification of  the Product:

           Platinum Gasaver    (from packaging and  installation
                               instruction booklet  (pack &  inst))

      b.    Patent Protection:

           Patent  #4,295,816     (pack  & inst)

      c.    Manufacturer  of the Product:

           (1)   National Fuelsaver Corporation     (pack & inst)
                 60 Plain Street
                 Clinton, Massachusetts 01510

           (2)   B. Joel Robinson     (pack & inst  plus related
                                      correspondence)

      Description of Product:

      a.    Purpose:

           The  device is  claimed to reduce  emissions,  improve
           fuel  economy,  raise  the   octane  of   gasoline,  and
           extend  engine  life.   (pack  &  inst   plus  related
           correspondence)


      b.    Applicability;

           for  a  gasoline vehicle getting  at  least 9 miles per
           gallon,  vehicles   getting  less  than   9  miles  per
           gallon  require  more platinum concentrate so that the
           platinum will correlate to the fuel   (pack & inst)

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     c.    Theory of Operation:

           Air  bubbling   through   the   solution  transports  a
           minute  amount  of   platinum  to  engine  where  the
           platinum  is  theorized  to  enhance  the  combustion
           process.

     d.    Construction and Operation:

           The  system  consists  of a  molded  plastic container
           containing the  platinum  solution plus the connecting
           tubing

     e.    Specific Claims for the Product:

           The  device  is  claimed  to reduce  emissions,  improve
           fuel  economy,   raise the  octane  of  gasoline,  and
           extend  engine  life.    (pack  &  inst  plus  related
           correspondence.)   No  specific  numeric  claims  for
           these improvements  are given;  however,  the packaging
           prominently states  that  the  "Device  may increase gas
           mileage by  22%" or  "Device  increases  gas mileage by
           22%."  Ads have appeared in  magazines and newspapers
           that  state  either  these  same  numbers  or  "Device
           increases gas mileage by 22% to 40%."

     £.    Cost And Marketing Information:

           The unit retails for approximately $130.   EPA has in
           the  past  received  correspondence  stating that  the
           unit  sells  for  $100   to   $170.    The  refills  of
           "platinum concentrate" cost  $80  to  $90 and last from
           12,000 to  18,000  miles.   The  units are  apparently
           principally sold by independent distributors.


4.    Product Installation, Operation,  Safety and Maintenance:

     a.    Installation - Instructions,   Equipment,  and  Skills
           Required:

           The   installation    instructions    are   given   in
           Attachment  B.   As  noted  in  the  test  report,  "The
           instructions  were   generally   clear.    Only  simple
           tools and minimal mechanical skills were needed for

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      installation.   Installation  was  performed  by  EPA
      technicians  and  required approximately  one  hour per
      vehicle."  Although  the  note  on the device packaging
      states  that  it "takes only  10 minutes  to  install",
      one  hour  is  more  reasonable  since the  unit  must be
      installed  away from hot  spots,   must   be  installed
      upright, and should  be  located so as to minimize the
      length  of  the  tubing.   Also,  some  popular  vehicles
      have  PCV  lines that are metal  and/or  difficult to
      readily cut  the PCV  line and  install  the connecting
      ii rn ii

b.    Operation:

      Operation  is  automatic, bubbles  pass  through  the
      unit when the  engine is  running at  loads  which open
      the PCV valve.

c.    Effects on Vehicle Safety:

      No problems were observed in testing by EPA.

d.    Maintenance:

      The    manufacturer's    installation    instructions,
      Attachment  B,   specify   that   a   vial   of  platinum
      concentrate must be added to the gasaver solution.

Effects on Emissions and Fuel Economy:

a.    Unregulated Emissions:

      There   was   no    information   available   regarding
      unregulated emissions.

b.    Regulated Emissions and Fuel Economy:

      The  test  results  given  on  the   packaging,  in  the
      installation   booklet,   and   in   testimonials   from
      purchasers   of  the   device   represent   relatively
      uncontrolled test  programs and thus  cannot be relied
      upon  to  demonstrate  that  the  device  has   a  fuel
      economy benefit.

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           Furthermore,  emissions  cannot be evaluated  based on
           the  results  of the  Inspection/Maintenance  (I/M)  hot
           running  tests  that  are  used in many areas  of  the
           country.  These are  usually  tailpipe  emission tests
           of  a  vehicle  in  neutral.   These   test  procedures,
           equipment,  and  pass/fail  points  were  designed  to
           identify  'gross emitting' vehicles  and  thus are  not
           capable of  accurately  detecting  changes  in emissions
           and  fuel   economy   levels.    Therefore,   I/M  tests
           cannot be used to  show  that  a device has  a general
           effect  on  the emissions  and/or fuel  economy of  a
           vehicle when  driven  under  realistic road  loads  and
           operating modes.
The following Section is EPA's  analysis  and  conclusions for the
device.
6.   Testing by EPA:

     A detailed  report of the  testing performed by  the EPA is
     given in EPA  report,  EPA-AA-TEB-91-2,  "Emissions  and Fuel
     Economy  Effects  of  the   Platinum  Gasaver,   a  Retrofit
     Device" provided  as Attachment  A.  A brief  description of
     this testing effort is given below:

           "Three  typical  vehicles  were tested  at  EPA's  Motor
     Vehicle  Emission  Laboratory.   The  basic  test  sequence
     included  2,000 miles  of  mileage  accumulation,  replicate
     Federal Test  Procedures  (FTP)  and replicate Highway Fuel
     Economy Tests  (HFET).   This test sequence was  conducted
     both without and with the Platinum Gasaver installed."

7.   Conclusion:
           "The overall conclusion from these  tests  is  that the
     Platinum  Gasaver  did  not  significantly  change  vehicle
     emissions or fuel economy for either the  FTP  or HFET.   The
     device clearly  did not produce  the  large —  greater  than
     20  percent  —  fuel  economy   benefits   claimed   by   the
     manufacturer.  Therefore, users  of the device would not be
     expected  to  realize   either  an  emission or  fuel  economy
     benefit.   Vehicle  operation  and  performance  were unchanged
     by the device".

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                                               EPA-AA-TEB-91-02
               Emissions  and  Fuel  Economy  Effects

                             of the

                       Platinum Gasaver,

                       a Retrofit Device
                           July 1991
                             NOTICE

Technical  Reports  do  not   necessarily   represent   final  EPA
decisions or positions.   They are  intended to present technical
analysis  of  issues using data which  are currently  available.
The purpose  in  the  release of such reports is to facilitate the
exchange  of  technical information and  to  inform the  public  of
technical development  which may form the basis  for  a  final EPA
decision, position or regulatory action.


                  Test  and Evaluation Branch
             Emission Control Technology Division
                    Office of  Mobile Sources
             U.S. Environmental Protection Agency

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1.0  ABSTRACT

     This   report   describes   the   Environmental   Protection
Agency's (EPA) testing of the  "Platinum Gasaver"  as  part of its
evaluation  under  Section 511  of the  Motor  Vehicle  Information
and Cost  Savings  Act  (MVICSA).   This evaluation was  conducted
at the  request of the Federal Trade  Commission  (FTC)  to verify
the claims for large -- greater  than  20 percent  --  fuel economy
benefits.

     The Platinum  Gasaver is  a  vapor air bleed  device.  It is
installed  with  a  "T"  connecter  in  the  Positive  Crankcase
Ventilation (PCV)  line between the  PCV valve and the carburetor
base  or induction  system.    The device  consists of   a liquid
reservoir,   proprietary  liquids,  an  orifice,  and  connecting
tubing.   During  vehicle  operation,  engine  manifold vacuum  is
used to draw  air  into  the  bottle where  it  bubbles  through the
solution,   through  the controlling orifice,  through  the  "T"  in
the .PCV line,  and  by this means  is claimed  to  transport a very
small part of the "platinum concentrate"  to  the  engine  where it
is claimed to enhance the engine combustion process.

     The  device  is   claimed   to improve  fuel  economy,  reduce
emissions,   raise   the  octane  of gasoline,  and  extend  engine
life.  Only the fuel  economy  and emission claims for the device
were evaluated in this test program.

     Three typical vehicles were tested  at EPA's Motor Vehicle
Emission Laboratory.   The  basic test sequence  included  2,000
miles   of   mileage    accumulation,    replicate   Federal   Test
Procedures  (FTP)   and  replicate  Highway  Fuel  Economy  Tests
(HFET).   This test sequence was  conducted  both without  and with
the Platinum Gasaver installed.

     The  overall  conclusion  from  these  tests  is  that  the
Platinum Gasaver did not  significantly change  vehicle  emissions
or fuel economy for  either  the FTP or HFET.   The device clearly
did not produce the  large  -- greater than  20  percent   —  fuel
economy benefits claimed  by  the  manufacturer.   Therefore,  users
of  the  device  would  not  be  expected   to  realize  either  an
emission  or   fuel   economy   benefit.   Vehicle   operation  and
performance were unchanged by the device.

     EPA  previously  evaluated  the  Platinum  Gasaver   at  the
request  of  a  marketeer  of  the  device  but  did  not  conduct
confirmatory  tests  since  the  applicant   did  not  conduct  the
required   screening   tests   following  the  established   test
protocols  for this voluntary program.

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2.0  BACKGROUND

     Under Section  511 of MVICSA,  EPA is  required  to evaluate
devices  which  are  claimed  to  improve  fuel  economy for  the
effect of  the device  on  both emissions  and  fuel  economy.   The
results  of  these  evaluations  are  published  in  the  Federal
Register. '

     EPA  receives information  about  many  systems  which  appear
to  offer  a  potential  for  reduction   in  emissions   and/or  an
improvement  in the  fuel  economy in  conventional  engines  and
vehicles.   EPA's  Emission   Control   Technology   Division   is
interested  in  evaluating  all  such  systems  because  of  the
obvious benefits  to the Nation.   EPA invites  developers  of  such
systems  to submit  information  on the  principle  of  operation
together with  available test  data.   In  those  cases  where  the
system  shows   promise  in  the  screening  tests  at  an approved
independent  laboratory,  confirmatory  tests  are  run  at  the
applicant's   expense    at   the   EPA   Motor  Vehicle   Emission
Laboratory   in   Ann   Arbor,   Michigan.    Most   Section   511
evaluations were  conducted at the request .of the applicants.

     Under the  MVICSA,  EPA is also required to evaluate devices
"at the  request of  the FTC when  it  has  reason  to believe  that
fuel  economy  representation  made for   a  retrofit  device  being
marketed   may  be   inadequate."2   This  test   program   was
initiated  at  the request  of the FTC  to  determine  if  the  fuel
economy   claims  for   the   "Platinum   Gasaver"   device   are
representative.   The   results  of such  test  projects are  set
forth in a series of test  and  evaluation  reports,  of which  this
is one.

     The  conclusions  drawn  from the  EPA evaluation  tests  are
necessarily of  limited  applicability.   A  complete  evaluation of
the   effectiveness   of   a  device  in   achieving  performance
improvements on the many  different  types of vehicles  that  are
in actual  use  requires  a  larger sample of test vehicles than is
economically  feasible  in   the   evaluation  of   test   projects
     The Section  511 evaluation report,  of  which this  testing
     is  part,  is  given  in  "Second  EPA  Evaluation  of  the
     Platinum Gasaver  Device  Under  Section  511  of  the  Motor
     Vehicle     Information     and     Cost     Savings     Act,
     EPA-AA-TEB-511-91-2.  This document  is available  from the
     National Technical  Information  Service, U.S.  Department of
     Commerce,  5285  Port  Royal  Road,  Springfield,  Virginia
     22161.

     40 CFR Part 610, paragraph 610.12(a)

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conducted  by EPA.   The  conclusions   from  the- EPA  evaluation
tests can be considered  to  be quantitatively valid only for the
specific  test   cars   used;  however,   it   is   reasonable   to
extrapolate  the  results  from the EPA test to  other  types  of
vehicles in a directional manner; i.e.,  to  suggest that similar
results are likely to be achieved on other types of vehicles.

3.0  INTRODUCTION

     The Platinum  Gasaver is a vapor  air bleed  device  which  is
installed with a  "T"  connecter  in the PCV  line  between the  PCV
valve and  the  carburetor base or induction system.   The device
consists  of  a   liquid   reservoir,    proprietary   liquids,   an
orifice, and  connecting  tubing  to  the  PCV line.   The plastic
bottle  reservoir  contains  the  Gasaver  solution  to which  the
user  adds   the   Gasaver   concentrate   containing   the   "platinum
concentrate".  During vehicle operation,  engine  manifold vacuum
is  used to draw  air  into  the  bottle where it  bubbles through
the solution, through the controlling orifice,  through the  "T"
in  the  PCV  line,  and by this means  is  claimed to  transport  a
very  small  part  of  the  "platinum  concentrate"  to  .the  engine
where it is claimed to enhance the engine combustion process.

     The device  is   claimed  to  improve fuel  economy,  reduce
emissions,   raise  the  octane of  gasoline,  and  extend  engine
life.  Only the  fuel  economy and  emission claims for the device
were evaluated in this test  program.

     EPA  previously  evaluated  the  Platinum  Gasaver   at  the
request of  Pegusus Enterprises,  a marketeer of  the  device,  but
did not conduct  confirmatory tests since:

     "The applicant did  not  submit  any  valid data  to support
     the   claims   for    increased   fuel   economy   and   lower
     emissions.   The applicant was advised  by  letter on several
     occasions  of  EPA's requirement  that  applicant's  submit
     valid   test  data following  proper  EPA  test  procedures.
     Based  on the information provided  by  the applicant,  there
     was no  technical basis  to support  any claims  for a  fuel
     economy  improvement   or  emission   reduction  with   the
     Platinum Gasaver."3
     "EPA  Evaluation  of  the  Platinum  Gasaver  Device  under
     Section  511  of   the  Motor  Vehicle  Information  and  Cost
     Savings Act,"  EPA-AA-TEB-511-81-14  or PB  81-226706.   This
     document   is   available   from   the   National   Technical
     Information  Service,  U.S.  Department  of  Commerce,  5285
     Port Royal Road,  Springfield,  Virginia  22161.

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4.0  PURPOSE OF THE TEST PROGRAM

     The  purpose  of  the  EPA  test  program  was  to  conduct  a
controlled  technical  evaluation of  the device  to  determine if
the  Platinum  Gasaver  met   its   advertised  claims.    Exhaust
emissions,  fuel  economy,   installation,  and  safety were  to be
specifically evaluated.   The other  claims  --  increased octane
and extended engine life — were not evaluated.

5.0  TEST PLAN

     A  test plan  was  developed by  EPA (Appendix  A) .   The FTC
notified  National  Fuelsaver  Corporation,   the  manufacturer of
the Platinum Gasaver,  of  the intent to  evaluate the  device and
sent  the  company  a  copy  of  the  test  plan.   The manufacturer
declined to participate in this test effort.4

     The EPA test  program  consisted  of  the checkout of the  test
vehicles,   mileage  accumulation without  the  device5,  replicate
baseline  tests,  device  installation, mileage  accumulation with
the device,  and replicate device tests.   The  purpose  of  the
vehicle checkout was  to ensure each vehicle was representative
of  a  properly-tuned  vehicle  and  would  provide   a  reasonable
reference  test  condition.   Installation was  to  be  done  per the
instructions supplied with the product.   (Appendix B.)

     The  vehicles  were to be  tested  using  the FTP and  HFET.
The FTP  is the official EPA  test  procedure  for determining the
exhaust emissions  of  a  vehicle.   The results of both of  these
tests  are  also  used  to  determine  the   fuel  economy  of  a
vehicle.  The FTP  is  described  in  the  Federal  Register  (40  CFR
Part 86;  July  1,  1990)  and the HFET is  described in the  Federal
Register  (40 CFR Part  600;  July  1,  1990).   The  vehicles  were
not tested for evaporative emissions.

     Claims for  the Platinum  Gasaver not specifically addressed
were the increased octane  and extended  engine  life. The reason
for not using  specific procedures to  evaluate  these claims is
that  several  of  these   are   in  large   part  subjective  and
procedures  for  their evaluation  are neither  well defined  nor
routinely  used  by EPA to  evaluate devices.   Others  require
extensive vehicle mileage or engine  (out of vehicle) operation.
     Letter  dated  June  19,  1989  from William  I.  Cowin  of
     Freidman  and  Atherton   (Counselors  at  Law  for  National
     Fuelsaver Corporation)  to the FTC.

     Mileage  accumulation  consisted of  2,000 miles  of  driving
     over a prescribed  route of  city and highway  mileage.   The
     same 150-mile route was  used for all mileage accumulation.

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     Three  typical  production vehicles  were  used;  a  Chevrolet
Celebrity  with  a  four-cylinder  engine,  a Ford  Taurus with  a
six-cylinder  engine,  and  a  Dodge  Van  with  an  eight-cylinder
engine.     All    vehicles   were   equipped    with    automatic
transmissions.  A more  detailed  description of each  vehicle  is
provided in Appendix C.

5.1  CONDUCT OF TESTING

     The testing  (including  mileage  accumulation)  was conducted
by  EPA.   All  tests  were  performed  by the  EPA  at its  Motor
Vehicle  Emission  Laboratory  in Ann  Arbor.    In  general,  the
testing proceeded as planned.

     Test Results - Installation

     There  were  no  problems  encountered  in  installing  the
device  on  each  vehicle.    The  instructions   were  generally
clear.  Only  simple tools  and  minimal  mechanical  skills  were
needed  for  installation.    Installation  was  performed by  EPA
technicians and  required  approximately  one  hour  per  vehicle.
The  installation  on the  Chevrolet  Celebrity  was  slightly  more
complicated since  the  PCV  line  was metal  rather  than  rubber;
and  therefore  required cutting  the metal  tubing and installing
reducer fittings to adapt to the small line of the  device.

     Test Results - Fuel Economy and Emissions

     The test  results   for  each  vehicle  are  summarized  below.
Emission levels  are  given  in  grams/mile while fuel  economy  is
given  in  miles  per  gallon.   The  individual  test   results  for
each vehicle are given  in Appendix D.
                   Summary  of EPA Test Results

                            FTP                      HFET
                   HC   CO    NOx   MPG      HC   CO   NOx   MPG

Chevrolet Celebrity
Baseline          .13  2.36   .49   25.9    .04  .67   .27   41.0
Platinum Gasaver  .12  2.17   .60   26.3    .04  .74   .37   41.9

Ford Taurus
Baseline          .25  4.26  1.17   21.5    .02  .48   .91   36.8
Platinum Gasaver  .31  5.73  1.06   22.0    .03  .65   .92   37.5

Dodge Van
Baseline          .44  6.03  1.81   14.0    .12  .28  3.03   20.2
Platinum Gasaver  .39  5.24  1.83   14.2    .11  .26  3.03   20.1

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     These  data  were  analyzed  for  statistic-al  significance
using  the  student   "t"  test6  technique  to  determine  if  the
differences observed  were  real or  due  sole'/ to  chance.   This
analysis  showed that  for  the  FTP  tests  the HC,  CO,  and  NOx
differences  were  not  statistically  significant  at  the  95%
confidence  level.   For  the   HFET  this   analysis  showed a  very
small decrease in HC emissions for one vehicle and  a  very  small
increase  in  NOx emissions  for another  vehicle.    Although  the
similar analysis indicated  that the very small changes noted in
fuel economy might  be  statistically significant  for one vehicle
on the FTP (but not  for the HFET on any  vehicle),  these  data do
not demonstrate that  the device has a beneficial  impact on fuel
economy  or  emissions.   EPA   believes  that   the  statistical
significance of this  fuel  economy  change is attributable solely
to  the unusually  low  test  variability  (less than   1%)  noted
during EPA's testing  of the  device rather  than an effect of the
device.  The fuel economy  test  variability  normally experienced
at  EPA and  other   test  facilities  (greater  than  2% for  even
rigorously  controlled  correlation   programs),    would   have
resulted  in  EPA  concluding  that  there  was no   fuel  economy
benefit.   Clearly,  the Platinum  Gasaver  did not  produce  the
large  —   greater   than  20  percent  — fuel  economy  benefits
claimed by the manufacturer.   For this  reason  EPA  believes  that
real  fuel  economy  benefits  are  unlikely  to be  realized  in
actual  driving  when  using  the   Platinum  Gasaver.    Vehicle
operation and performance were unchanged by the device.

     In   addition,   because   all  three   test   vehicles   had
relatively low  odometer  readings  (less  than 20,000 miles),  it
is  unlikely  that the  fuel economy  of   the  vehicles  was  fully
stabilized.   For  this reason  the  mileage  accumulation   that
occurred between the baseline testing and device  testing would
     The student "t" test  is  a  standard statistical method that
     provides  a  powerful  technique  for analyzing  experimental
     data  involving quantitative  measurements  especially  for
     small numbers  of  tests  (i.e.   30  tests  or  less  on  each
     vehicle).    The method  allows   confidence  levels  to  be
     attached  to   the  estimates   of   the   effects  of   the
     independent variable  (i.e.,  device  effect).   To  minimize
     test costs for the screening tests conducted  by applicants
     at  independent  laboratories,  only hot  start  LA-4  (bags  1
     and 2 of  the  FTP)  are required  and  the data  are  screened
     at an 80  percent  confidence  level.   For confirmatory tests
     conducted at  EPA,  the data are screened  at  a  95  percent
     confidence  levels.    Note:   At a  50  percent  confidence
     level, there is an  equal probability  that the  device  does
     or does  not have an effect.

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tend to increase the fuel economy of the vehicLes  and thus tend
to  bias  the   test   results   in  favor  of  the  device.   EPA
recognizes this complicating aspect of  mileage  accumulation but
has had  to  design Section  511  device  evaluation  test  programs
without this factor  since  test  programs designed  to  factor out
the mileage  effects  would be several times  larger and  the test
costs  would  escalate  for  the  applicant.    Other   EPA  test
programs do  have adjustments for vehicle mileage.

     Thus,  EPA  concluded  that  the  Platinum  Gasaver  has  no
emission  or  fuel  economy  benefit  (or  penalty)  for  either the
FTP  or  HFET.   Therefore,  users of  the  device  would  not  be
expected to  realize either an emission or fuel economy benefit.

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                          Appendix A

       Test Plan for EPA Testing of the Platinum Gasaver
Test Plan

     The following  is  the test  plan  which will be  used  by the
EPA in collecting data on the fuel economy  and  emission effects
of   the   Platinum  Gasaver   device   of   National   Fuelsaver
Corporation  (a  retrofit  device under  Section  511  of  the Motor
Vehicle  Information and  Cost  Savings Act).   This  testing  is
being conducted at the request of the FTC.

     1.    Representative   vehicles  will   be   identified   and
     obtained  by  the  EPA.   Representativeness will  be  based
     upon the applicability of  Platinum Gasaver as  detailed  in
     the manufacturer's  literature;  i.e.,  1989 year  or  older,
     domestic,  gasoline   fueled  and  for   engine   size   and
     manufacturer;  i.e.,   small,  medium,   large  engines  from
     different manufacturers.

     2.  Vehicles  will  each be  checked and adjusted  to  ensure
     that  they   are   operating  in   accordance  with  vehicle
     manufacturer's specifications.

     3.  The test fuel will be  commercial  unleaded summer-grade
     gasoline  from  EPA   storage  facilities.   This  fuel  is
     routinely used by EPA and its specifications are known.

     4.   All  mileage  accumulation   will   be  with  this  same
     commercial unleaded summer-grade gasoline.

     5.   Baseline  mileage  accumulation.    Each  vehicle  will
     accumulate 2,000 miles on  an  established road  route using
     commercial unleaded  summer-grade  fuel.   The  vehicle  will
     then be baseline tested.

     6.    Baseline   tests.   Duplicate,   valid   Federal   Test
     Procedure  (FTP)   and  Highway  Fuel   Economy   Test  (HFET)
     procedures will  be performed  on  each  test  vehicle  after
     baseline mileage accumulation.  Basic  vehicle driveability
     will be noted.

     7.  The  Platinum Gasaver device will  then  be  installed  in
     accordance  with  the  written   installation   instructions
     provided with the device.

     8.  The  installations will  be  performed by EPA personnel.
     The vehicles may  be  checked,  as  necessary,  for  correct
     operation prior to initiation of these device  tests.

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9.   Device   Mileage  Accumulation.   Each   vehicle  will
undergo  mileage  accumulation on  the  road   sufficient  to
bring  the  total  mileage  with the  device to 2,000  miles
(commercial   unleaded   summer-grade   fuel).    For   each
vehicle, the  mileage  accumulation  procedure  will   be  the
same as that used prior to baseline testing.

10.    Device   Tests.   After  mileage   accumulation,   the
testing sequence  performed for the  baseline test will  be
repeated with the Platinum Gasaver installed.

11.   Data   Analysis.   Test   results  will be analyzed  to
determine   if  there   is   a  statistically   significant
difference  between  the data  sets  (vehicles without  and
with Platinum Gasaver) .

12.   Additional  testing  may  be  undertaken  by  EPA  to
further investigate  items noted  during the   course  of  the
test program.

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         Platinum Gasaver Detailed  In-House Test Plan
I.    Introduction

     Comparative exhaust emission and  fuel  economy data  are  to
     be obtained on  late model  vehicles  both without  and  with
     the Platinum  Gasaver.   All  mileage accumulation  will  be
     done using  commercial  unleaded summer-grade  gasoline  from
     EPA storage facilities  as needed.

II.   Test Vehicles

     Three vehicles will be  tested.

Ill.  Required Testing

     A.    Vehicle  Prep

           Prior to  start  of  testing, each  vehicle is  to  be
           tuned  to  manufacturer's  specifications  and  parts
           replaced as  required  to  ensure  proper  operation  of
           the vehicle for  5,000  miles.
           Parts

           Air filter
           Distributor cap
           Fuel filter
           Ignition wires
           Oil

           Oil filter
           PCV filter
           PCV valve
           Rotor
           Spark plugs
           Tires
check
check
check
check
change use the same
10W30 oil in all test vehicles
change, use OEM
check
check
check
check
check
           Adjustments (if adjustable)

           Air/fuel mixture
           Choke
           Curb idle
           Fast idle
           Ignition timing
           Checks

           Compression

           Record  all  items adjusted/checked/replaced.
           manufacturer's  specifications  and  measured
           for all items as appropriate.
                          Record
                          values
                             10

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B.   Test Schedule

     All vehicles will be tested using the same test schedule:

     1.  Check tire pressure set for road.

     2.   Drain  and  pressure  check fuel  system.   Then  refuel
     with commercial  unleaded  summer-grade gasoline  from  EPA
     fuel supply.

     3.  2,000 miles  of mileage accumulation  on  an established
     road route using commercial unleaded summer-grade gasoline
     from the EPA storage facilities.

     4.  Drain and refuel (approximately 3 gallons).

     5.  Sun analyzer vehicle specification check.

   .  6.  Set tire pressure for dyno.

     7.  Drain and refuel to 40% fill  for prep.

     8.  LA-4 prep.

     9.  Overnight soak

     10.  Drain  and  40% fill  with chilled  fuel.   Heat  build
     with no  evaps.   Then FTP  and HFET  tests with  commercial
     unleaded summer-grade gasoline.

     11.  Repeat  steps  7 to 10.

     12. Remove test tires from vehicle and store.

     13.  Install  Platinum  Gasaver per  manufacturer's  written
     instruction.

     14.  Mileage   accumulation  to  2,000  miles  with  Platinum
     Gasaver  using  commercial  unleaded  summer-grade  gasoline
     from  EPA  supplies.    For  each   vehicle,    the   mileage
     accumulation  route with  the   device  will be  the same  as
     that used prior to baseline testing.

     15. Install  test tires.

     16. Drain and refuel (approximately 3 gallons).

     17. Sun analyzer vehicle specification check.

     18. Duplicate FTP and HFET tests with  the Platinum Gasaver
     installed (steps 7 to 10 completed twice).
                              11

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C.    General

The same driver  and dynamometer should  be used to  test  a
given vehicle whenever  possible.   Driveability      should
be  evaluated on  the  road  and  during  testing.   Written
driveability  comments  are  needed.   To   ensure  only  the
proper fuel  is used,  the vehicles  should  be  equipped  with
locking gas  caps.   Mileage  accumulation will be performed
by EPA drivers using  an established road  route.   All  fuel
will be from EPA supplies.
                         12

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                                                     Appendix  B
             TABLE OF CONTENTS

Contents.of GASAVER KIT                               3

Installation Instructions                                  4

Metering device replaces catalytic converter
(excerpt from DESIGN NEWS)                             6

Homogeneous Catalysis of Gasoline Combustion By Platinum
and Rhenium
(presentation to the American Chemical Society)               8

Excerpts from Mobil research referred to on page 15        20

Fleet Tests Data                                  21&22
  NATIONAL FUELSAVER CORP.

  PACKING CONTENTS and INSTALLATION INSTRUCTIONS
       For a vehicle getting at least 9 miles per gallon.
  Do NOT pour the GASAVER concentrate into the GASAVER
     instrument without following the instructions below.
   If your vehicle is under warranty, check with your dealer
         that this will not jeopardize the warranty.

1 GASAVER Instrument, filled with GASAVER Solution
1 Plastic "T" Connector
3 Vials of GASAVER Concentrate (Each vial contains enough
  platinum  for 6,000 miles of driving.)
1 Plastic Self-locking Releasable Strap

A. GASAVER Instrument
B. Horizontal Opening
C. Vertical Opening
D. GASAVER tubing
E. PCV Rubber Vacuum
  line of vehicle
T. "T" Connector
                                                                                         PCV Vacuumliiw
1.  Horizontal opening "B" appears to be closed. IT IS NOT. We
have gone to great expense to create an opening there equal to
1/200 inch. Do not disturb.
2.  Locate the PCV rubber vacuum line going from the PCV valve
to the base of the carburetor. Cut that vacuum line at a convenient
spot and insert the two larger legs of the plastic "T" into the ends
of the tube created by cutting it
3.  Connect one end of the GASAVER tubing "D" to the third leg
of the "T".
4.  Remove BOTH black cap* from the GASAVER instrument and
throw them away. YOU MUST REMOVE THE CAP COVERING
OPENING "C" AS WELL AS THE CAP AT "B".
5.  Find a safe and convenient location for the GASAVER instru-
ment "A" under the hood of your car. Keep it away from the hot
parts of the engine and exhaust and avoid sharp comers that might
puncture the instrument. Usually there is a suitable spot behind a
headlight next to a canister, windshield washer container, or battery.
(Do NOT attach to a warm or hot part of the car such as the radiator
or radiator overflow tank.)
6.  Secure the GASAVER instrument" A" using the self-locking strap
provided for this purpose. Make sure that the instrument's horizontal
opening "B" faces the "T" (point "T") in the vacuum line "E" to
which the GASAVER tubing "D" has been attached.
7.  Attach second end of GASAVER tubing to Horizontal opening
"B" on GASAVER instrument, making the GASAVER tubing "D" as
short and as straight as  possible.
 8.  TURN ON ENGINE. After about 30 seconds you should see
 bubbling in the GASAVER Instrument. A bubbling rate of 20 to 30
 bubbles in 10 seconds is correct. If otherwise contact your supplier.
 9.  With your engine still running, slowly and carefully pour one
 (1) of the vials of GASAVER concentrate into the GASAVER instru-
 ment "A" through the vertical opening "C".
 10.  Your PLATINUM GASAVER is now fully operational, although
 it may take from 200 to 1,800 miles for it to become fully effective.
 Even though NONE of the GASAVER solution in the instrument is
 consumed during the normal course of driving, the platinum is used
 up every 6,000 miles. It is necessary, therefore, to add one (1) of the
 vials of the GASAVER concentrate to the instrument each 6,000
 miles of driving, to keep this PLATINUM GASAVER process effec-
 tive and operational.

 (Vertical opening "C" does not have to be covered. However, if
 you wish to cover it with nylon stocking material, you may. Just
 make sure that the  bubbling rate remains 20 to 30 bubbles each
 10 seconds.)
                                                        13

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Make/Model

Model Year

Vehicle ID


Type

Initial Odom.

Engine
  Family

Fuel Metering

Evaporative
  Family

Emission
  Control
  System
Transmission
                             Appendix C

                      Test Vehicle Description

               Chevrolet Celebrity  Ford Taurus

               1988                 1988

               1G1AW5IR6J6164308    1FABP50U5JG281067
               Four-door sedan

               13423 miles

               2.5L/I-4
               J1G25V5TPG4

               Fuel injected

               JAD-1C
               EGR
               3-way catalyst
               Closed-Loop
               Automatic
               Lockup-3 speed
Four-door  sedan

12149 miles

3.0L/V-6
JFM3.OV5FEGX

Fuel injected

.AFU
EGR
3-way catalyst
Closed-Loop
Automatic
Lockup-4 speed
Dodge Van

1987

2B4HB21T8HK
        266892

B250 Van Wagon

5320 miles

5.2L/V-8
HCR52T2BBF8

2 venturi

HCRTJ
EGR
Oxidation
Catalyst

Air pump

Automatic
Lockup-3 speed
               P185/75R14
Tires

Test
Parameters
Inertia Weigh  3,000

hp @ 50 mph    6.3
P205/70R14
                                    3,500

                                    6.6
P225/75R15
                    5,000

                    16.1
                              14

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 Appendix D



Test Results
1988
Emiss
Test No.
Baseline
# 1
# 2
Platinum
# 1
# 2
1988
Chevrolet Celebrity, 2.5 liter
FTP
ions in Grams/Mile
HC

.14
.11
CO

2.28
2.43
NOx

.45
.52
MPG

26.1
25.8
Test

#
#
, 4 cylinder
HFET
Emissions in
No.

1
2
HC

.04
.05
Grams/Mile
CO NOx

.61
.74

.27
.28
MPG

40.
41.

9
2
Gasaver
.12
.12
Ford
Emissions
Test No.
Baseline
# 1
# 2
Platinum
# 1
# 2
1987
HC

.25
.25
2.42
1.92
.63
.56
Taurus, 3.
FTP
in Grams/Mi
CO

4.71
3.81
NOx

1.15
1.19
26.1
26.4
0 liter, 6
le
MPG

21.4
21.5
#
#
1
2
.05
.04
.91
.57
.39
.35
41.
42.
7
0
cylinder
HFET
Emissions in
Test

#
#
No.

1
2
HC

.02
.02
CO

.51
.45
Grams /Mi
NOx

.89
.93
le
MPG

36.
37.


5
1
Gasaver
.27
.34
5.78
5.68
Dodge Van
Emissions
Test No.
Baseline
# 1
# 2
Platinum
# 1
# 2
HC

.40
.47
1.09
1.04
, 5.2
FTP
in Grams/Mi
CO

5.89
6.17
NOx

1.93
1.70
22.1
21.9
liter, V-8
le
MPG

14.0
13.9
#
#

1
2

.02
.03

.43
.87

HFET
Emissions in
Test

#
#
No.

1
2
HC

.12
.12
CO

.22
.34
.92
.92

Grams/Mi
NOx

3.12
2.94
37.
37.

le
MPG

19.
20.
6
3



9
3
Gasaver
.40
.39
4.79
5.69
1.88
1.78
14.2
14.2
#
#
1
2
.11
.11
.25
.28
2.95
3.11
20.
20.
0
1
   15

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                                                     Appendix  B
             TABLE OF CONTENTS

Contents.of GASAVER KIT                               3

Installation Instructions                                  4

Metering device replaces catalytic converter
(excerpt from DESIGN NEWS)                             6

Homogeneous Catalysis of Gasoline Combustion By Platinum
and Rhenium
(presentation to the American Chemical Society)               8

Excerpts from Mobil research referred to on page 15        20

Fleet Tests Data                                  21&22
 NATIONAL FUELSAVER CORP.

  PACKING CONTENTS and INSTALLATION INSTRUCTIONS
       For a vehicle getting at least 9 miles per gallon.
  Do NOT pour the GASAVER concentrate into the GASAVER
     instrument without following the instructions below.
   If your vehicle is under warranty, check with your dealer
          that this will not jeopardize the warranty.

1 GASAVER Instrument, filled with GASAVER Solution
1 Plastic "T" Connector
3 Vials of GASAVER Concentrate (Each vial contains enough
  platinum for 6,000 miles of driving.)
  Plastic Self-locking Releasable Strap
1
                                                               A. GASAVER Instrument
                                                               B. Horizontal Opening
                                                               C. Vertical Opening
                                                               D. GASAVER tubing
                                                               E. PCV Rubber Vacuum
                                                                 line of vehicle
                                                               T. "T" Connector
1.  Horizontal opening "B" appears to be closed. IT IS NOT. We
have gone to great expense to create an opening there equal to
1/200 inch. Do not disturb.
2.  Locate the PCV rubber vacuum line going from the PCV valve
to the base of the carburetor. Cut that vacuum line at a convenient
spot and insert the two larger legs of the plastic "T" into the ends
of the tube created by cutting it
3.  Connect one end of the GASAVER tubing "D" to the third leg
of the "T".
4.  Remove BOTH black caps from the GASAVER instrument and
throw them away. YOU MUST REMOVE THE CAP COVERING
OPENING "C" AS WELL AS THE CAP AT "B".
5.  Find a safe and convenient location for the GASAVER instru-
ment "A" under the hood of your car. Keep it away from the  hot
parts of the engine and exhaust and avoid sharp comers that might
puncture the instrument. Usually there is a suitable spot behind a
headlight next to a canister, windshield washer container, or battery.
(Do NOT attach to a warm or hot part of the car such as the radiator
or radiator overflow tank.)
6.  Secure the GASAVER instrument" A" using the self-locking strap
provided for this purpose. Make sure that the instrument's horizontal
opening "B" faces the "T" (point "T") in the vacuum line "E" to
which the GASAVER tubing "D" has been attached.
7.  Attach second end of GASAVER tubing to Horizontal opening
"B" on GASAVER instrument, making the GASAVER tubing "D" as
short and as straight as  possible.                           ,.
8.  TURN ON ENGINE. After about 30 seconds you should see
bubbling in the GASAVER Instrument. A bubbling rate of 20 to 30
bubbles in 10 seconds is correct. If otherwise contact your supplier.
9.  With your engine still running, slowly and carefully pour one
(1) of the vials of GASAVER concentrate into the GASAVER instru-
ment "A" through the vertical opening "C".
10.  Your PLATINUM GASAVER is now fully operational, although
it may take from 200 to 1,800 miles for it to become fully effective.
Even though NONE of the GASAVER solution in the instrument is
consumed during the normal course of driving, the platinum is used
up every 6,000 miles. It is necessary, therefore, to add one (1) of the
vials of the GASAVER concentrate to the instrument each 6,000
miles of driving, to keep this PLATINUM GASAVER process effec-
tive and operational.

(Vertical opening "C" does  not have to be covered. However, if
you wish to cover it with nylon stocking material, you may. Just
make sure that the bubbling rate remains 20 to 30 bubbles each
10 seconds.)

-------