Interpretation ID: nht94-1.63
TYPE: INTERPRETATION-NHTSA
DATE: February 18, 1994
FROM: Gilbert Gallahar -- Kings Environmental Hydrogen Systems
TO: John Womack -- Acting Chief Counsel, NHTSA
TITLE: None
ATTACHMT: Attached To Letter Dated 5/18/94 From Jonhn Womack To Gilbert Gallahar (A42; Std. 301)
TEXT: Ref. Request for interpretations on requirements for an on board Hydrogen Generator to be used on an internal combustion engine (stationary and mobile) to help control exhaust emissions.
Dear Mr. Womack,
Our company manufactures a hydrogen generator, that is installed on any gasoline or diesel vehicle (except engines with 2 spark plugs per cylinder and 2 cycle diesel engines), to help cut HC, CO and NOx.
This device takes water, and on demand, by electrolysis, manufactures hydrogen and oxygen. The gases (the higher form of water or the molecular form of water), are then pumped immediately to the normal (OEM) intake air stream of an internal combustion e ngine. The air stream gets this mixture, mixes it with the air, and sends it to the combustion chambers where it mixes with the primary fuel (diesel or gasoline), and ignited.
To insure that the hydrogen tank is never under pressure, the generator is designed to be operated without positive pressure. The vacuum pump is designed to pick up all gases generated and send it directly to the OEM intake air system. There is at leas t 3 systems in place, which independent of the other 2 systems, act to relieve the pressure in the producing tank. When the system is turned off, even without the pump working, in less than 15 minutes, all the pressure within the tank has been equalized to that of the outside atmospheric pressure.
The connection to drive the generator comes through a 15 amp. fused electrical line from the battery, through a relay, that is connected to the ignition. The device is connected such that the only time it is on is when the ignition is on.
Hydrogen is a non toxic gas, that is extremely buoyant. This buoyancy prevents any pockets of gas forming outside of its dictated path. If any hydrogen should escape, the buoyancy would cause the gas to find any way out, to the surrounding atmosphere.
The electrolyte is food grade, and is in, less of a concentration,
2
than a weak lemonade. NEPA Rating: Health - 0, Flammability - 0, Reactivity - 0. RCRA Hazard Class, Dilute solution (if discarded) non-hazardous. DOT hazard class, corrosive material.
From a safety point of view, the hydrogen generator is a much safer device than the battery. We are a tank of water as opposed to a tank of acid. We both make hydrogen but our hydrogen is vented out as soon as it is made. The hydrogen generator is pro tected to a maximum current draw of 15 amps. The hydrogen generator is designed to work under a slight negative pressure (supplied by the pump) and within minutes, of the engine being turned off, there is no hydrogen pressure left in the system. If the water should run out, there is no longer any current path, therefore no current flow. The vehicle then operates as if the device did not exist.
Enclosed is a set of installation instructions. The installation of the hydrogen generator in no way interferes with any OEM device of the vehicle to be installed.
Please, let me know as soon as is possible, your interpretation of NHTSA statutes, regulations or standards for our device.
Sincerely Yours,