United States
              Environmental Protection
              Agency
              Office of
              Policy Analysis
              Washington DC 20460
March 1984
Draft Final Report
r/EPA
Costs and Benefits of
Reducing Lead in Gasoline

-------
            COSTS AND BENEFITS
               OF REDUCING
             LEAD IN GASOLINE
                   by
              Joel Schwartz
              Jane Leggett
              Bart Ostro
              Hugh Pitcher
              Ronnie Levin
            Draft Final Report
        Office of Policy Analysis
Office of Policy, Planning and Evaluation
   U.S. Environmental Protection Agency
         Washington, D.C.  20460
              March 26, 1984

-------
                                 ACKNOWLEDGEMENTS





     We wish to publically acknowledge the extraordinary support we received



fron many people in doing this analysis.   Although the list is too long to name



them all, we wish to recognize the special assistance, expertise, and effort of



certain individuals.  First, George Sugiyama, Bob Fegley, and Albert Nichols



have provided invaluable assistance, analysis, and general acumen.  We are deeply



indebted to them.



     For technical assistance, even under strict time strictures, we thank



Craig Miller (of Energy and Resource Consultants); Steve Sobotka, Bill Johnson,



and Terry Higgins (of Sobotka and Company); and Ed Fu.



     For secretarial and production support well above the call of duty, we



thank Saundra Womack, Joyce Morrison, Delores Thompson, Sylvia Anderson, and



Ethel Stokes.  For research assistance, we thank James Chow, and for help with



the process and general principles, we thank Marty Wagner.



     For specialized and professional help, we wish to thank Les Grant,



Barry Nussbaum, Karl Heltoan, Dan Salisbury, Susan Martin, and members of the



staff of the Office of Air Quality Planning and standards.  For extensive review



and comments, we thank Valle Nazer of the Office of Policy Analysis and Review.



For reviewing our statistical methodologies we would like to thank Kathleen Knox



and John Warren of EPA's Statistical Policy Staff.  We also thank Terry Yosie,



the director of the Science Advisory Board, for arranging for the external peer



review of an earlier draft of this document, and the nine reviewers for their



valuable insights.

-------
                             EXECUTIVE SUMMARY

              COSTS AND BENEFITS OF REDUCING LEAD IN GASOLINE

COSTS

     Lead is a relatively inexpensive way to boost gasoline octane, but eliminating
or severely limiting lead would increase the manufacturing cost of gasoline by less
than 1%.  Eliminating lead altogether may result in excessive valve wear in some
trucks and older cars; a low-lead fuel of 0.10 grams/gallon would prevent this
problem.

BENEFITS

Maintenance Savings:  Lead forms corrosive compounds that increase automobile
maintenance costs.  Cars that use leaded gasoline need more frequent tune-upsf
exhaust system replacements, and oil changes.

Misfueling;  Recent EPA surveys indicate that over 12% of all cars equipped
with catalytic converters to control auto emissions are currently being
"misfueled" with leaded gasoline because consumers want either to save money
or to obtain higher octane.  Misfueling poisons catalysts and substantially
increases the conventional auto pollutants:  hydrocarbons, carbon monoxide,
and nitrogen oxides.  Given current misfueling rates, misfueled vehicles will
account for one-third of leaded gasoline demand in 1988, significantly increasing
our estimates of future lead and conventional pollutant emissions.  The impact
of these emissions on public health and welfare is substantial.

Health:  Cur analysis and other major studies both in the U.S. and abroad
indicated that the amount of lead in blood is directly related to the amount
of lead in gasoline.  Lead has long been known to cause pathophysiological
changes, including the inhibition of major enzymatic processes, adverse effects
on the central nervous system, and decreases in cognitive ability.  Children
are especially vulnerable to lead, and black children are more severely affected
than others.  Children with elevated blood lead levels require medical monitoring
and/or treatment.

     Adverse effects of lead in the blood are now found at levels that were
previously thought safe, and additional effects are suspected.  The Centers for
Disease Control is currently investigating lowering its definition of lead
toxicity.

SUMMARY

     Our examination of the costs and benefits of two options for further
restricting the use of lead in gasoline, summarized in Table 1, on the next
page, indicated that the benefits exceed the costs.  Although we were able to
place dollar values on reduced medical costs and cognitive damage for children
with high lead levels we did not monetize other factors affecting this group,
such as behavioral and other problems, nor the pain of medical treatment and
parents' lost work time.  No monetary values at all were estimated for children
with lower lead levels, although they suffer some negative effects.  These non-
monetized benefits are represented by "H" in the table.  Table 2 provides a
summary of the environmental effects of reducing lead in gasoline.

-------
                                   SUMMARY TABLE 1

                          Comparison of Benefits and Costs of
                            Lead Reduction Options in 1988
                              (millions of 1983 dollars)
 COSTS

 Manufacturing Costs

 Non-monetized Valve Damage
   to Engines that Need Lead

 TOTAL COSTS
                                                   Low-lead Option*   All Unleaded**
      $503
      $503
        $691

           D


      $691+D
 BENEFITS

 Maintenance Benefits

 Environmental and Health Benefits

      Conventional pollutants

      Reduced damage by eliminating misfueling

      Non-monetized health benefitst

      Lead

      Reduced medical care costs

      Reduced cognitive damage

      Non-monetized health benefits^

 TOTAL BENEFITS
      $660
      $404


        Hl



       $41

      $184
        $755
 NET BENEFITS
$786+Hi+H2
        $404

          H!



         $43'

        $193


         H3

$1,395+H]+H3


 $704+H1-i-H3-D
 * This option would make a low lead gasoline (0.10 grams of lead per gallon) avail-
   able only for those few vehicles that require some lead.  It assumes no misfueling.
**
   All lead in gasoline would be banned by 1988.

   These include chronic health effects of ozone and CO, and any effects of reduced
   sulfate particulates.

   Since medical costs and cognitive damage were only monetized for children with
   high blood lead (>30 ug/dl), H2 and H3 represent other benefits for this group
   (pain, lost work time to parents, etc.) as well as all the benefits (medical,
   cognitive, behavior, etc.) for the lower lead group (<30 ug/dl).  H2 and H3 differ
   because the numbers of children at risk under the two options differ.

-------
                                    SUMMARY TABLE 2
                        ENVIRONMENTAL EFFECTS IN 1988 OF REDUCED
                                   GASOLINE LEAD USE
 REDUCTIONS IN EMISSIONS
 (thousands of metric tons)

      Lead
      HC
      CO
      NOx

      Ozone (As a consequence of
             HC and NOX Emissions)

 REDUCTIONS IN THE NUMBER OF CHILDREN
 AT RISK OF ADVERSE HEALTH EFFECTS

 Reduction in number of children
 at risk of:

      - Inhibition of enzyme
        activity  (PY-5-N and ALA-D)

 Reduction in  number of children
 at risk of:

      - Changes in EEC patterns
      - Impairment of  heme synthesis
      - Elevated  levels of ALA and
        possible  interference with
        neurotransmission processes
      - Impairment of vitamin D activity
      - Possible  adverse cognitive
        effects

Reduction in number of children
at risk of impaired globin synthesis

Reduction in number of children
at risk of:

     - Potentially requiring
       active medical care
     - Probable adverse cognitive
       effects
                                                    LOW-LEAD
     33.4
      314
    2,202
      130

1.5% reduction
 4,257,000
1,475,000
  476,000


   43,000
                    ALL UNLEADED
     35.6
      314
    2,202
      130

1.5% reduction
 4,486,000
 1,553,000
  500,000


   45,000

-------
                               T2BLE CF CONTENTS

EXECUTIVE SUMMARY

CHAPTER I:  INTRODUCTION, FINDINGS, AND QUALIFICATIONS

    I. A.    Background                                                    I.  1

    I.B.    Approach                                                      I.  4

            I.B.I.  Base Case                                             I.  4

            I.B.2.  Hypothetical Options                                  I.  5

    I.C.    Summary of Analysis                                           I.  5

            I.C.I.  The Costs of Reducing Lead in Gasoline                I.  6

            I.C.2.  The Benefits of Reducing Lead in Gasoline             I.  8

    I.D.    Limitations of the Analysis                                   1.14

    I.E.    Quantifying Effects                                           1.16


CHAPTER II:  COSTS OF REDUCING LEAD IN GASOLINE

   II.A.    Input Assumptions                                            II.  2

            II.A.I.  Gasoline Volume                                     II.  2

            II.A.2.  Leaded-Unleaded Split                               II.  3

            II.A.3.  Misfueling                                          II.  4

            II.A.4.  Octane Requirements                                 II.  6

   II.B.    Reduction in Lead Emissions                                  II.  7

   II.C.    Cost Estimates                                               II.  8

            II.C.I.  Incremental Cost of the All Unleaded Case           II.  9

            II.C.2.  Low-lead Case                                       11.11

            II.C.3.  Cost of Lead Reductions                             11.12

   II.D.    Price Differentials                                 .         11.12

   II.E.    Longer Term Projections                                      11.14

   II.F.    Refinery Model                                               11.15

            II.F.I.  General Description of DOE Petroleum
                     Refinery Yield Model                                11.15

-------
      Attachment I:   Evolution of DOE Refinery Model and Current Status  11.28

      Attachment II:   Refinery Processes                                  11.32

      References                                                          11.36

 CHAPTER III:   BENEFITS FRCM REDUCED VEHICLE MAINTENANCE REQUIREMENTS

    III.A.     Maintenance Savings in the All Unleaded Case                III. 5

              III.A.l.   Sources of Data                                   III. 5

              III.A.2.   General Comments on the Method                    III. 6

              III.A.3.   Fewer Replacements  of Exhaust Systems             III. 8

              111.A.4.   Better Performance  or Less Frequent
                        Spark Plug Changes                                 III.12

              III.A.5.   Extended Oil  Change Intervals                     III.16

              III.A.6.   Improved Fuel Economy                             III.23

    III.B.     Maintenance  Savings for the Low-Lead Case                    III.26

              III.B.I.   Exhaust System Savings                            III.27

              III.B.2.   Spark  Plug Savings                                 III.29

              III.B.3.   Oil Change Savings                                 III.30

              III.B.4.   Sum of Maintenance  Savings for the
                        Low-lead Case                                     III.30

    III.C.     Risk of Valve Recession                                     III.31

              III.C.I.   How Much Lead is  Required  to
                        Protect Valves                                    III.36

              III.C.2.  Alternatives  to Lead  to Avoid
                        Valve  Recession                                   III.37

   III.D.    Summary                                                      III.42

   References                                                             III.46

CHAPTER IV:  BENEFITS OF AVOIDING  EXCESS HC, NOX AND  CO EMISSIONS

   IV.A.    Value by the Costs  of  "Next-Step" Regulations                 IV. 6

   TV.B.    The Value of Preserving Pollution Control Equipment           TV. 8

   IV.C.    Benefits Estimated  Directly  from Health and Welfare
            Improvements                                                  IV. 10

            IV.C.I.  Benefits of Reducing Ozone                           IV. 10

-------
            IV.C.l.a.  Ozone Health Effects                             IV. 16

            IV.C.l.b.  Ozone Agricultural Benefits                      IV.29

            IV.C.I.e.  Nonagricultural Vegetation
                       Benefits of Reduced Ozone                        IV.31

            IV.C.l.d.  Ozone Materials Benefits                         IV.32

            IV.C.2.  Benefits of Reducing No* Emissions                 IV.33

            IV.C.3.  Reducing Emissions of Hydrocarbons                 IV.35

            IV.C.4.  Reducing Emissions of Carbon Monoxide              IV.37

   IV.D.    Summary of Health and Welfare Benefits                      IV. 41

   IV.E.    Sunmary of HC, CO, and NOx Benefits                         IV.42

   Technical Appendix                                                   IV. 44

   References                                                           IV. 56


CHAPTER V:   BENEFITS OF REDUCING LEAD:  CHILDREN WITH HIGH BLOOD LEVELS

   V.A.      The Relationship between Gasoline
             Lead and Blood Lead                                         V. 3

   V.B.      Medical Benefits of Reducing High Blood Lead Levels         V. 6

   V.C.      Cognitive and Behavioral Effects                            V.ll

   V.D.      Estimating Avoided Costs of Reduced Cognitive Ability       V.12

   V.E.      Statistical Methods                                         V.15

              V.E.I.  The NHANES II Data                                 V.15

              V.E.2.  Reduction in Number of Children
                      Below Critical Thresholds                          V.20

              V.E.3.  Incidence Versus Prevalence                        V.24

              V.E.4.  Assessing the Accuracy of our
                      Forecasting Procedures                             V.28

    V.F.     Conclusion                                                  V.30

   Technical Appendix                                                    V.33

   References                                                            V. 41

-------
CHAPTER VI:   BENEFITS OF AVOIDING HEALTH EFFECTS OF BLOOD LEAD LEVELS
              BELOW 30 ug/dl


   VI.A.      Pathophysiological Effects                                     VI. 3

   VI.B.      Hematological Effects of Lead                                  VI. 9

              VI.B.I.    Effects on Blood Cell Volune and
                        Hemoglobin Content                                   VI. 10

              VI.B.2.    The Relationship Between Blood
                        Lead and FEP                                         VI. 13

              VI.B.3.    The Relationship Between FEP
                        Levels and Anemia                                    VI. 15

   VI.C.      Fetal  Effects                                                  VI. 19

   VI.D.      Neurological Effects                                           VI.20

              VI.D.I.    Cognitive and Behavioral Effects                     VI.23

                V.D.I.a   Assessment of the Relationship Between
                           10 or Cognitive Function and Low Blood
                           Lead Levels                                       VI.23

                V.D.I.b   Policy Implications of Significance Tests          VI.30

              VI.D.2.    Estimating Avoided IQ Loss Associated with
                        Reduced Blood Lead Levels                            VI.32

              VI.D.3.    Threshdld for Effects of Blood Lead on IQ
                        and the Size of the Affected Population              VI.34

   VI.E.       Estimating the Reduction in the Number of Children at Risk     VI.38

              VI.F.I.   Distributional Aspects of Lead Exposure               VI.40

   VI.F.       Conclusion                                                     VI. 41

   Re ference s                                                                 VI. 4 4

-------
                           TABLES, EXHIBITS AND FIGURES
CHAPTER I

    TABLE 1-1



    TABLE 1-2
Comparison of Benefits and Costs of
Lead Regulation Options in 1988

Environmental Effects in 1988
of Reduced Gasoline Lead Use
 I. 9


 1.11
CHAPTER II

    TABLE II-l

    TABLE 11-2



    TABLE 11-3

    TABLE II-4
Projected Gasoline Demands

Amounts of Leaded Gasoline
Consumption Due to Misfueling

Metric Tons of Lead Removed

Cost of Reducing or Banning
Leaded Gasoline Production
II. 3


II. 4

II. 8


11.11
    EXHIBIT 1     Flow Diagram of Topping Refinery
                  Processing ..Low Sulfur Crude Oil

    EXHIBIT 2     Flow Diagram of Hydroskimming Refinery
                  Processing Low Sulfur Crude Oil

    EXHIBIT 3     Flow Diagram of Fuels Refinery
                  Processing High Sulfur Crude Oil

    EXHIBIT 4     Flow Diagram of High Conversion Refinery
                  Processing High Sulfur Crude Oil

    EXHIBIT 5     Functional Characterization of
                  Petroleum Refinery Process

    EXHIBIT 6     Yields and Operating Costs Coefficients
                  Crude Distillation Unit

    EXHIBIT 7     Yields and Operating Costs Coefficients
                  Catalytic Reforming Unit

    EXHIBIT 8     Estimated U.S. Refinery Processing
                  Unit Capabilities for 1988
                                                      11.18


                                                      11.19


                                                      11.20


                                                      11.21


                                                      11.22


                                                      11.25


                                                      11.26


                                                      11.27

-------
                   TABLES, EXHIBITS, AND FIGURES (Continued)
CHAPTER III

    TABLE III-l




    TABLE II1-2


    TABLE II1-3


    TABLE II1-4


CHAPTER IV

    TABLE IV-1

    TABLE IV-2


    TABLE IV-3


    TABLE IV-4


    TABLE IV-5

    TABLE IV-6


    TABLE IV-7
Summary of Studies on Maintenance
Differences Between Leaded and
Unleaded Vehicles

Summary of Findings:  Valve Recession
at Varied Lead Concentrations

Number of Engines At Risk of Severe
Valve Recession Without Leaded Gasoline

Summary of Maintenance Savings
Increase in Emissions Due to Misfueling

1982 Misfueling Rates by Age
of Vehicle and by I/M Status

Discounted Future Emissions Avoided
by Eliminating Misfueling in 1988

Benefits Valued by "Next-Step" EPA
Regulations

Benefits of Reducing Asthmatic Attacks

1988 Benefits of Reducing HC,
NOX, and CO Emissions

Benefits in 1988 of Reducing HC,
CO, and NOX Emissions
    TECHNICAL APPENDIX

      APPENDIX TABLE IV-1   Light Duty Vehicle Projections

      APPENDIX TABLE IV-2   Light Duty Truck Projections

      APPENDIX TABLE IV-3   Summary of Fleet Model Parameters

      APPENDIX TABLE IV-4   General Fleet Assumptions

      APPENDIX TABLE IV-5   Misfueling Rates By Age
III.6


III.35


III.43

III.45
 IV.  2


 IV.  3


 IV.  5


 IV.  7

 IV. 2 7


 IV. 41


 IV.43
                                                        IV. 4 5

                                                        IV.46

                                                        IV. 4 7

                                                        IV.49

                                                        IV. 52

-------
                   TABLES, EXHIBITS, AND FIGURES (Continued)
CHAPTER V

    TABLE V-l
1988 Reduction in Number of
Children Above 30 ug/dl
    TABLE V-2    Medical Cost Savings in 1988
V. 3

V.10
    TABLE V-3    Benefits of Reduced Cognitive Losses

    TABLE V-4    Estimated Lead Used for Gasoline in 1988

    TABLE V-5    Changes in Mean Blood Lead for 1988 for
                 Black and White Children Aged 5 or less

    TABLE V-6    1988 Population Projects

    TABLE V-7    Monetized Benefits of Reduced Numbers of
                 Children Above 30 ug/dl Blood Lead Level
                                                         V.14

                                                         V.23


                                                         V.23

                                                         V.24


                                                         V.31
    FIGURE V-l   Children's Blood Lead Levels Vary Directly
                 With Levels of Lead in Gasoline

    FIGURE V-2   Lead Used in Gasoline Production and
                 Average NHANES II Blood Lead Levels

    FIGURE V-3   Average NHANES II Blood Lead Levels
                 Vs. Lead Used in Gasoline Production

    FIGURE V-4   Average Blood Lead Levels For Black Children
                 In Chicago and Gasoline Lead In Chicago
                                                         V. 4


                                                         V.17


                                                         V.18


                                                         V.19
CHAPTER VI

    TABLE VI-1


    TABLE VI-2
    TABLE VI-3
Blood Lead Levels of Persons Aged six Months
- 74 Years in United States 1976-1980

Computation of Joint P-Value fron
Epidemiological Studies of Cognitive
Effects fron Low Level Lead Exposures
in Children

Decrease in Number of Children Above
Thresholds for Cognitive Effects
VI. 2
                                                                          VI.27
                                                                          VI. 36

-------
                   TABLES, EXHIBITS, AND FIGURES (Continued)
TABLE VI-4    Possible Change In Person 10 Points
              As a Function of Threshold Levels for
              Children 6 Months to 7 Years

TABLE VI-5    Decreased Number of Children
              (13 years old of less) Above
              Apparent Threshold Levels

TABLE Vl-6    Estimated Distribution of Blood
              Lead Levels in 1988

TABLE VI-7    Summary of the Benefits of
              Reducing Lead Exposure
VI. 37



VI.39


VI. 40


VI.42
FIGURE VI-1   Percent of Children with MCV below 74 fl

FIGURE VI-2   Percent of Children with Anemia

FIGURE VI-3   Mean 10 Difference Between High Lead Groups
              and Controls, Adjusted for Socioecononic
              Factors
VI.12

VI.17



VI. 29

-------
                            CHAPTER I

           INTRODUCTION,  FINDINGS,  AND QUALIFICATIONS



 I.A.   Background


      Since 1973, the U.S.  Environmental Protection Agency (EPA)

 has  regulated  the use of lead  as  an additive to gasoline.   Section

 211  of the Clean Air Act gives the EPA Administrator authority

 to control or  prohibit any fuel or fuel additive that:

      0 causes,  or contributes  to,  air pollution which may
        reasonably be anticipated  to endanger the public  health
        or  welfare,  or

      0 will impair  to a  significant degree  the  performance  of  any
        emission control  device or  system which  is in general use...

      To avoid  the adverse  effects  of lead in the environment and

 to protect emission control  equipment which is  rendered  ineffec-

 tive  or "poisoned"  by lead additives,  EPA required  that  cars,

 beginning  with  model year  1975, meet tighter emissions limits.

 To do this automobile manufacturers installed catalytic  converters

 requiring  unleaded  gasoline.   In several  stages  during the  period

 1976-1982,  EPA  mandated  that the lead  content of  leaded  gasoline

 be reduced from over 2.0 grams  per  gallon to 1.1  g/gal.

      During  this  period, studies on blood lead  levels showed

 that  reducing the lead content  of gasoline  would  also reduce

 blood  lead  levels in  all major  population groups  in  the  United

 States.  It  was anticipated that the combination  of  these two

 actions would restrict and eventually eliminate  the  exposure of

 the general  population, especially  young children, to airborne

 lead  from  mobile  sources, as well as reduce  health and welfare

damage  from  conventional pollutants.

-------
                              1.2





     While  EPA's  rules  have  virtually  eliminated  leaded  premium



 gasoline, consumers  of  regular gasoline must  choose  between



 relatively  inexpensive  gasoline containing  lead additives  or



 more expensive unleaded gasoline.  In  addition to  savings, some



 consumers want the slightly  higher octane of  leaded  regular.



 (However, few recognize lead's corrosive effects on  their  engines



 or the increased maintenance  cost of using  leaded  gasoline.)



     Recently, several  EPA and private studies have  found  wide-



 spread "misfueling"  (i.e., the use of  leaded  gasoline  in vehicles



 designed for unleaded gasoline).  The studies showed that  con-



 stant misfueling rates  of over 12% have slowed the decline in



 lead emissions significantly, and challenged  the assumption that



 leaded gasoline would soon be eliminated because of  lack of



 demand.  These findings have occurred at the  same  time that the



 public health community's long-standing concern about  lead has



 produced a substantial  literature about the adverse effects of



 lower lead exposures.  Specifically, recent studies have strength-



 ened the identification of gasoline lead as a major source of



 blood lead and new information on the effects of lead on physio-



 logical functions has become public.



     Some of this information began to surface during the hearings



and subsequent comment period related to EPA's proposed lead phase-



down rule making in 1982.   At that time, the Agency had proposed



several regulatory alternatives.   As  a result of the information



gained from the public response during the proceedings, EPA



tightened the restrictions on the amount of lead permitted in

-------
                              1.3





leaded gasoline.  The restriction also set a uniform limit for



both small and large refiners.



     The growing problem of the misuse of leaded fuel in cars



with catalytic converters, the increasing recognition of serious



health effects from even low lead levels, and the fact that gaso-



line has been identified as the major source of environmental



exposure to lead all indicated that a simple continuation of



current policies needed reexamination.  EPA presently has two



review processes underway for assessing the effects of lead.



The first is the Agency's formal Criteria Document process,



which is managed by the Office of Research and Development.



The Lead Criteria Document will evaluate all of the environmental



effects of lead.  A Draft Lead Criteria Document was circulated



for comment in October 1983; a final document is expected by



August 1984.  Nothing in this paper is intended to prejudge or



supercede the outcome of that process.



     Concurrently, and on a somewhat faster timetable, EPA's



Offices of Policy, Planning and Evaluation, and Air and Radiation



have been reviewing data from the 1982 phase-down effort to



evaluate the costs and benefits of additional restrictions of



the amount of lead in leaded gasoline.  This paper is primarily



an analysis of the monetized costs and health and welfare benefits



of reducing the lead content of gasoline.

-------
                              1.4
 I.B.   Approach



      For this  paper,  we have contrasted the costs  and benefits



 of  two hypothetical  options  against a base case which continues



 existing regulations  and compliance practices.   The first option



 is  a  low-lead  fuel  (0.10 grains  of  lead per gallon)  for the few



 classes  of  vehicles,  such as trucks and older cars, that may



 require  the valve lubrication that lead provides.   Contrary to



 the current situation,  such  a low  lead fuel would  cost more to



 manufacture than regular gasoline.   We assume this  cost inversion,



 coupled  with availability restrictions on  this  fuel,  would elimi-



 nate misfueling as a  practical  problem.  The second option is



 the banning of all leaded gasoline.





 I.B.I.   Base Case



     At  present, EPA  regulations restrict  the use of  lead in



 gasoline  in two ways.   First, beginning  with the 1975 model year,



 almost all  light-duty vehicles  have been equipped with catalytic



 converters  and require  unleaded gasoline.   By 1981,  virtually  all



 new light-duty vehicles  should  have been using  unleaded gasoline.



 Second,  EPA limits the  lead  content of leaded gasoline to 1.1



 grams per gallon.  Because lead is  a relatively inexpensive octane



 enhancer, this is about  half  of what refiners would  use if not



statutorily  constrained.



     The lead standard must  be  met  on  a  quarterly average,  how-



ever,  not for each gallon produced.   In  addition, refiners  may



average their own production  or sell off-sets to each other.

-------
                             1.5





That is, two refiners may agree that one of them will produce



gasoline with 1.0 grams of lead per gallon and the other will



use 1.2 grams of lead (and, presumably, pay the first one an



agreed amount).   This allows the refinery industry as a whole to



optimize its use of octane manufacturing capacity and to minimize



the cost of meeting the restrictions on lead use.





I.B.2.  Hypothetical Options



     To address the problems of misfueling and airborne lead



pollution, the first alternative we considered was an outright



ban on the use of lead in gasoline.  Such a regulation would



meet both the public health and misfueling concerns, and we



examined this option carefully.  However, some vehicles could



experience severe valve damage if no leaded fuel were available.



We therefore added a second "low-lead" option, which assumed



that marketing restrictions would be designed so as to eliminate



misfueling.  The amount of lead in leaded gasoline would be



restricted to 0.10 grams per gallon, which is sufficient to



protect valves from undue wear, but which minimizes environmental



contamination.





I.C. Summary of Analysis



     Our analysis evaluates and compares the costs and benefits



of reducing or eliminating lead in gasoline.  To calculate the



costs of restricting lead as an octane-enhancer, we used a linear



programming model of the refinery industry.

-------
                              1.6





      In  the  benefits  area,  we calculated  vehicle  maintenance



 savings  that  would  be  realized by  eliminating  the corrosion and



 engine fouling  problems  associated with  lead  in gasoline.  We



 also  monetized  the  benefits  of reducing  the emissions  of conven-



 tional pollutants that result from misfueled vehicles,  and



 analyzed  the  number of children at risk of various health



 effects  from  lead exposure.



      We  have  valued the  benefits associated with  reducing the



 number of children  suffering  from  "undue  lead  absorption,"



 currently defined by the Centers for Disease Control as blood



 lead  levels above 30 micrograms per deciliter  (ug/dl)  and free



 erythrocyte protoporphyrin  (FEP) levels over 50 ug/dl.  For



 children with blood lead levels below 30  ug/dl, we  calculated



 the change in the number of children with blood lead levels



 above the lowest observed effects  level for pathophysiological



 changes but we  did  not ascribe  any dollar values  to reducing



 their lead exposures.  We also  estimated  the change in  the number



 of children who might suffer  small decreases in cognitive ability,



 but again we attached no monetary  value to this.



    Chapters II (on costs) and  V (on the  health effects of blood



 lead  levels over 30 ug/dl) contain detailed sections describing



 the methods we  used in our analysis.





 I.C.I. The Costs of Reducing  Lead  in Gasoline



     Lead is added  to gasoline  because it is the  least expensive



way for petroleum refiners to boost the octane of  fuel.  Reducing

-------
                             1.7





or eliminating the lead content of gasoline will require extra



energy use (and potentially more equipment) and, consequently,



greater resource costs.  We estimated the increased costs of raw



materials and refining would be less than 1%.  As a result, many



consumers would pay slightly more for gasoline.



     Chapter II contains a description of consumer demand for



gasoline, the leaded/unleaded split, and current needs for octane.



Based upon our models and projections by the Energy Information



Administration and Data Resources, Inc. (DRI), we have projected



gasoline demand and the leaded/unleaded split under existing



policies and misfueling rates, and under the two hypothetical



options:  low-lead and all unleaded.  The refinery cost figure



is an estimate of the extra manufacturing costs incurred by



refineries if they must use other octane-producing processes to



meet U.S. demand for gasoline.  These costs were derived from



the same linear program of the refining industry which was used



in EPA's economic analysis of the 1982 lead phase-down regulations.



     We projected that, meeting current consumer requirements for



octane, the 1988 cost to refiners of reducing lead in the low-



lead option would be $503 million and the cost of the all unleaded



option would be $691 million.  Because we could not predict how



changes in production costs might affect the marketing strategies



of retailers under our two options, we did not attempt to estimate



the change in gasoline prices to consumers.

-------
                                1.8


   I.e.2. The Benefits of Reducing Lead in Gasoline

        Chapters III-VI describe the monetized benefits of reducing

   the amount of lead in gasoline and some unmonetized health

   benefits of reducing overall exposure to lead.

        Chapter III  (Maintenance Savings)  describes the vehicle

   operation and maintenance savings that  would result from restrict-

   ing lead in gasoline.   Lead  compounds and their associated

   scavengers foul and  corrode  the engines and exhaust systems  of

   all vehicles using  leaded gasoline,  whether designed for it  or

   not.*  Operation  and  maintenance savings  come from  three primary

   areas:   less frequent  tune-ups,  less frequent exhaust  system

   replacements,  and  less  frequent  oil  changes.  We  estimated that

   vehicle  owners who switch from  leaded to  unleaded gasoline could

   save 3-4  cents per gallon of  gasoline.  The total benefits were

   computed  by multiplying the  savings  per gallon  times the total

   number of  gallons consumed.   The estimates  of maintenance  savings

   we  have  included  in Table  1-1  (on  the next  page) were  at the low

   end of our  range.   We also discussed  the  possibility of  valve

   damage to  leaded vehicles, which  could occur in our  all  unleaded

   option, but  not in our low-lead  option.    We were unable  to estimate

   a monetary  value for this because we did  not have information on

   how many vehicles  are driven under the conditions where  it could

  occur.
* Scavengers are necessary to remove lead from the engine after
  combustion.  Without these scavengers, engine performance
  would rapidly deteriorate to complete inoperability.

-------
                                          1.9

                                       TABLE 1-1

                          Comparison of Benefits and Costs of
                             Lead Reduction Options in 1988
                               (millions of 1983 dollars)
 COSTS

 Manufacturing Costs

 Non-monetized Valve Damage
   to Engines that Need Lead

 TOTAL COSTS
                                                   Low-lead Option*   All Unleaded**
                        $503
                        $503
       $691

          D


     $69H-D
 BENEFITS

 Maintenance Benefits

 Environmental and Health Benefits

      Conventional pollutants

      Reduced damage by eliminating misfueling

      Non-monetized health benefitst

      Lead

      Reduced medical care costs

      Reduced cognitive damage

      Non-monetized health benefits'

 TOTAL BENEFITS


 NET BENEFITS
                        $660
tt
       $755
$404
Hi
$404
Hi
                  $786+1^+112
$704+H]+H3-D
 * This option would make a low lead gasoline (0.10 grams of lead per gallon)  avail-
   able only for those few vehicles that require seme lead.  It assumes no misfueling.
**
   All lead in gasoline would be banned by 1988.

 f These include chronic health effects of ozone and CO, and any effects of reduced
   sulfate particulates.

^ Since medical costs and cognitive damage were only monetized for children with
   high blood lead (>30 ug/dl), H2 and H3 represent other benefits for this group
   (pain, lost work time to parents, etc.) as well as all the benefits (medical,
   cognitive, behavior, etc.) for the lower lead group «30 ug/dl).  H2 and HS differ
   because the numbers of children at risk under the two options differ.

-------
                                1.10





      We  estimated  that  total  savings  from  reduced  maintenance  and



 operation  expenses would  be $660 million for  the low-lead  option



 and  $755 million for  the  all  unleaded  option.



      Chapter  IV  (Benefits  of  Avoiding  Excess  HC, CO,  and NOX



 Emissions) examines misfueling  practices and  their consequences



 for  emissions of the  conventional  auto pollutants:  hydrocarbons,



 carbon monoxide, and  nitrogen oxides.  As  we  have  noted, using



 leaded gasoline  in vehicles designed  to run on  unleaded gasoline



 poisons  their catalytic converters, which  causes a substantial



 increase in HC, CO, and NOX.  While all vehicles equipped  with



 catalytic  converters  are  required  to use unleaded  gasoline, over



 12%  of all vehicles equipped  with  catalysts are currently  being



 misfueled  with leaded gasoline.



     We  estimated  the excess  emissions in  grams per mile and



 computed the  increases in  total emissions  due to poisoned



 catalysts.   Because HC and NOX combine to  form ozone, we also



 estimated  the increase in  ozone which  formed  as a  result of



 more conventional  pollution.  Our  estimates of the size of



 these changes appear  in Table 1-2.  We used existing  literature



 and data on the negative health and welfare effects of these



 conventional pollutants to value these changes in  emissions.



     We used three methods to value the benefits of avoiding



 these excess emissions:  1) an estimate valuing the avoided



emissions at the average cost per  ton of the most  cost effective



alternative for controlling these  pollutants, 2) an estimate



valuing the avoided emissions at the average cost per ton of the

-------
                                       1.11
                                    TABLE 1-2
                     ENVIRONMENTAL EFFECTS IN 1988 OF REDUCED
                                GftSOLINE LEAD USE
REDUCTIONS IN EMISSIONS
(thousands of metric tons)

     Lead
     HC
     CO
     N°x

     Ozone (As a consequence of
           HC and NOV Emissions)
                                                    LOW-LEAD
     33.4
      314
    2,202
      130

1.5% reduction
                     ALL UNLEADED
      35.6
       314
     2,202
       130

1.5% reduction
REDUCTIONS IN THE NUMBER OF CHILDREN
AT RISK OF ADVERSE HEALTH EFFECTS

Reduction in number of children
at risk of:

     - Inhibition of enzyme
       activity (PY-5-N and ALA-D)

Reduction in number of children
at risk of:

     - Changes in EEC patterns
     - Impairment of heroe synthesis
     - Elevated levels of ALA and
       possible interference with
       neurotransmission processes
     - Impairment of vitamin D activity
     - Possible adverse cognitive
       effects

Reduction in number of children
at risk of impaired globin synthesis

Reduction in number of children
at risk of:

     - Potentially requiring
       active medical care
     - Probable adverse cognitive
       effects
 4,257,000
 1,475,000
   476,000


    43,000
 4,486,000
 1,553,000
   500,000


    45,000

-------
                               1.12





program requiring catalytic converters on cars, and 3) an estimate



using econometric damage functions to value the avoided emissions.



We used the average of the last two alternative methods, $404



million, as a point estimate in Table 1-1.



     Chapter V discusses the health benefits of eliminating lead



in gasoline by valuing the damage resulting from blood lead levels



over 30 ug/dl (which is, in combination with elevated FEP levels,



currently the Centers for Disease Control's definition of lead



toxicity).



     Lead emissions from cars increase the blood lead levels of



children.  Inner city black children have the highest rates of



elevated blood lead levels, but a substantial number of white



children also are affected.  Lead is known to damage the kidney,



the liver, the reproductive system, blood creation, basic cellular



processes, and brain functions.   Using the projected lead reduc-



tions from Chapter II, we estimated how many fewer children would



be likely to be at risk of undue lead exposure.  From these we



estimated the benefits of avoiding the pathophysiological and



cognitive and behavioral effects of elevated blood levels.



     When children's blood lead levels are over 30 ug/dl, they



require follow-up and/or medical treatment.  The estimate in



Table 1-1 was based on a regression that projected the number of



additional children who would require medical treatment for



elevated blood lead levels as a result of gasoline lead use.



It did not include children who would need treatment for lead



poisoning because of lead-based paint or other sources of



exposure.  We included the costs of medical treatment even for

-------
                              1.13





the children whom public health officials do not find and treat,



because we assumed that the social cost of elevated lead levels



for an untreated child was at least as great as what we spend on



treatment for those who are identified.



     Some of these children have blood lead levels high enough



to reduce cognitive performance, including the loss of several



10 points.  Researchers have found that these cognitive deficits



remain three years later, even after medical attention.  Table



1-1 also includes the costs of compensatory education to overcome



the additional learning difficulties that children with high



lead levels incur.  As in the case of medical costs, we included



costs even for those children who do not receive compensatory



education.  Again, we assumed that the costs to society of a



learning disability were at least as great as the cost of a



program to partially compensate for the damage.



     We estimated, for the all unleaded case, that the benefits



of avoiding medical and associated costs for children with



blood lead levels over 30 ug/dl were $43 million, and that the



value of avoiding the cognitive damage likely to occur at those



levels was $193 million.



     Chapter VI discusses the health effects of blood lead levels



below 30 ug/dl.  As measurement tools have improved, research



has detected pathophysiological effects at blood lead levels



that were previously thought to be safe, and additional effects



are suspected.  These results warrant concern about even small



changes in the total body lead burden of children, especially



those children who are subject to sources of lead exposure in



addition to lead from gasoline.

-------
                               1.14





     While the full clinical significance of the effects of blood



lead levels below those requiring medical management under current



practice is not yet clear, the Centers for Disease Control is now



considering lowering its current (30 ug/dl of blood lead and FEP



levels of 50 ug/dl) criteria for lead toxicity.



     Among the recent data on these pathophysiological changes



are inhibition of the enzymes Pyrimidine-5'-nucleotidase (PY-5-N)



and aminolevulinic acid dehydrase (ALA-D), which begins to be



detectable at about 10 ug/dl of blood lead; changes in EEG



patterns, detectable at about 15 ug/dl; elevated ZPP or FEP in



red blood cells at about 15 ug/dl; inhibition of globin synthesis



at about 20 ug/dl; increased risks of abnormally small red blood



cells at 20-25 ug/dl; and other disruptions of aminolevulinic



acid (ALA) and vitamin D homeostasis at about 15 ug/dl.  In



addition, our analysis of the combined evidence from all the



relevant studies indicated that mild cognitive effects also



occurred at low lead exposure levels.



     Our estimates of the reduced number of children at risk



of health effects are presented in Table 1-2.  We have not valued



these changes monetarily, but crude valuation procedures suggest



the benefits are likely to be large.






I.D.  Limitations of the Analysis



     This paper is a cost-benefit analysis of reducing the lead



content of gasoline.  To do this, we have proposed two hypothet-



ical options:  a low-lead and an all unleaded scenario.  Our



analysis measured the effects in one year, 1988.  With such a

-------
                              1.15





far-reaching issue, the limitations of our findings should be



clarified.



     We have forecast circumstances and events that will occur



four years in the future, and the future is, at best, uncertain.



One problem is shifts in underlying behavior such as a change in



consumer preferences back to large cars or changes in external



events (e.g., another big war in the Mideast).  In addition,



because we are extrapolating from our perceptions and experience



to date, any misapprehension of what is will tend be magnified



as we project several years ahead.  (An example of this may be



the misfueling problem.)  Our benefit estimates are vulnerable



to these two kinds of uncertainties.



     Although we believe that our model of the refinery industry



is as accurate as possible, we can not predict marketing



behavior.  We believe we have estimated real resource costs



fairly accurately, but we can not predict with confidence what



would happen to consumer prices.



     In the benefits area, we are still learning about the



health effects of lead and other criteria pollutants.  The body



of knowledge is neither well-defined nor unequivocal.  While the



trend in new findings seems to be uncovering more effects at



lower levels, the clinical significance of these findings is not



always clear.  Also, the distributions of effects that we are



predicting, especially at 30 ug/dl of blood lead, are near the



tails of the distributions, and therefore, more susceptible  to



changes and uncertainties.  However, we have no indications

-------
                                1.16





that our estimation procedure  is biased, so  the effects are  as



likely to be larger as smaller.  In addition,  it  is difficult



to measure IQ loss, and even more difficult  to put a dollar



value on lost IQ points.



   While we have used accepted state-of-the-art methods for



valuing health and environmental effects, there are uncertainties



about the health and welfare effects of hydrocarbons, nitrogen



oxides, and carbon monoxide; and about the transformation of



hydrocarbons and nitrogen oxides into ozone.   Finally, there are



some uncertainties inherent in the monetary  valuation of these



effects .





I.E. Quantifying Effects



     We have, in the course of this analysis, explored many



alternative assumptions and methods for valuing effects.  Through-



out, our overall results have proven to be very robust to changes



in details; that is, small changes did not alter  results.



     The effects for which we have presented monetary values in



Table i-l have a solid basis.  Where the data could not support



a point estimate or even a range, we did not provide a monetary



value.   All significant effects, however, whether monetized or



not, are included in Table I-l to allow the  reader to gain a



full perception of the problem.



     The clear conclusion from the data summarized in Table  I-l



is that the benefits of the low-lead option substantially exceed



the costs.   For the all unleaded case, the issue  is less clear

-------
                              1.17





because of the unresolved nature of the cost of valve damage.



However, as engines which need leaded gasoline retire from the



fleet, the issue of valve damage becomes less important.  Thus,



in the long run, the option of eliminating lead in gasoline



appears very attractive.

-------
                           CHAPTER II



               COSTS OF REDUCING LEAD IN GASOLINE





     Petroleum refiners add lead to gasoline as the least



expensive way to boost octane.  There are alternative additives



that also help boost octane, but they generally are more



expensive and, like lead, can also be toxic.



     The most attractive alternative refiners have for raising



the octane of unleaded gasoline is additional processing of the



gasoline in either catalytic reformers or in isomerization units.



Increasing the use of reformers and isomerizers requires more



energy consumption, and thus raises the cost of manufacturing



gasoline.  (This may also increase the density of gasoline which



raises slightly the energy content per gallon of gasoline.)



     If refiners need to produce more unleaded gasoline but are



limited by isomerization or reforming capacity, they can construct



more capacity, incurring a capital charge.  Alternatively,



refiners can purchase either a better grade of crude oil or add



other octane boosters, incurring higher operating costs.  The sum



of all these costs, along with miscellaneous energy costs, etc. ,



is the additional cost of making gasoline with less or no lead.



     In this chapter we discuss some of the basic input assump-



tions we used to estimate the refinery costs of producing



gasoline under our  two options.



      Estimates of  the reduction in  lead emissions under our



two policy options  are presented.  We then  show the costs



derived from applying our assumptions to the Department of



Energy  (DOE) refinery model.  A description of the DOE model

-------
                              II.2



and a brief explanation of refinery processes are presented in

the last section of this chapter.



II.A. Input Assumptions

     The cost to refiners of manufacturing unleaded or low lead


gasoline depends principally on three factors:

     o  the total gasoline volume produced,

     o  the portions of gasoline production that are leaded and
        unleaded, and

     o  the level of octane specified for the gasoline pool.



II.A.I. Gasoline Volume

     Table II-l presents the gasoline demand assumptions that we

used to estimate the costs of manufacturing unleaded gasoline for

our baseline and two policy options.  Gasoline demand estimates

are obviously subject to uncertainty.  Demand in 1983 was approxi-
  »
mately 6.6 million barrels per day.  We assumed that demand in

1988 would fall to 6.5 million barrels per day, because newer

cars are more fuel efficient (i.e., get more miles to the gallon)


than the older vehicles they replace.  We believe fuel efficiency

effects will slightly outweigh the effects of the growing number

of vehicles, even though vehicle miles travelled is also expected

to increase.  (For comparison with our estimate, a recent Data

Resources Inc. [DRI, 1983]  model forecast for 1988 is for 3%

fewer gallons of gasoline than we assumed; last year's Energy

Information Administration [EIA, 1983]  estimate was much lower

but has been revised upward to about our level.)

-------
Leaded
3.13
2.80
2.45
2.11
1.80
Unleaded
3.41
3.78
4.09
4.39
4.66
Total
6.54
6.58
6.54
6.50
6.46
Leaded
N.A.
2.32
1.88
1.48
1.07
Unleaded
N.A.
4.26
4.66
5.04
5.39
Total
N.A.
6.58
6.54
6.50
6.46
                              II.3
                           TABLE II-l

                   Projected Gasoline Demands
                 (millions of barrels per day)

                    With Misfueling         Without Misfueling
Year

1982 (actual)
1984
1986
1988
1990

*To convert to billions of gallons per year, multiply by
 42 gallons/barrel times 365 days/year.


II.A.2.  Leaded-Unleaded Split

     We projected the split in demand between leaded and unleaded

gasoline in two ways.  First, we fit linear and logistic regres-

sions to the monthly leaded-unleaded split documented in the

Monthly Energy Review (from the Department of Energy), using time

as the explanatory variable.  We also regressed the thirteen-month

moving average, to remove seasonal and random variation.  These

all suggested an unleaded share of 67.5% (plus or minus 0.6% at

a 95% confidence level) of the gasoline market in 1988.  Our

vehicle fleet model (described in Chapter III), using historic

scrappage rates from DRI, predicted essentially the same unleaded

share.  For our cost analysis, therefore, we assumed a 67.5%

share.

     The first set of projections, "with misfueling," is our

reference or baseline of current regulations and current

misfueling rates.  The projections for leaded gasoline "without

misfueling" reflect our first policy option — to reduce lead

-------
                               II.4


content to the level necessary to protect older vehicles' valves,

but restrict its retail availability to avoid misfueling.

     We believe this low-lead option will eliminate misfueling

because leaded gasoline with only 0.1 grams per gallon will cost

more to manufacture than unleaded regular gasoline, so it will

no longer be the lowest cost product.  Also, restrictions on

availability will reduce the incentive to misfuel, particularly

if this grade were limited to full service stations.


II.A.3.  Misfueling

     While the population of vehicles that legally may use

leaded gasoline is shrinking, misfueled vehicles are slowing the

decline in demand for leaded gasoline.  By 1990, misfueling will

account for over one-third of leaded gasoline demand.   Table II-2

shows  these percentages.  (The model that forecast them is

discussed in Chapter III.)


                           TABLE II-2

    Amounts of Leaded Gasoline Consumption Due to Misfueling

                Billions       Percent of        Percent of
     Year      of Gallons     Total Gasoline   Leaded Gasoline

     1984          7.36            7.3               17
     1986          8.72            8.7               23
     1988          9.97           10.0               31
     1990         11.19           11.3               41

-------
                             II.5


     EPA surveys indicated that over 12% of vehicles designed to

use unleaded gasoline in fact use leaded (EPA, 1983).  Because

surveyed motorists may refuse to allow their cars to be inspected,

however, these survey results probably greatly underestimate the

misfueling rate.  Misfueling has significantly increased the cur-

rent demand for leaded gasoline.  Only 52% of gasoline demand in

1982 was unleaded, as opposed to Dupont's 1979 projections of 62%.

The two most common reasons given by motorists for misfueling are

the price differentials between leaded and unleaded fuel, and

driver dissatisfaction with performance resulting from the lower

octane generally found in regular unleaded gasoline.

     A problem of octane-related performance occurs because

regular leaded gasoline generally has 89 octane* while regular

unleaded has 87 octane.  Some cars designed to use leaded gaso-

line do not function as well with the lower octane in unleaded

regular.  In our analysis we addressed this issue by projecting

actual octane need and requiring our refinery model to meet  that

demand.  This increased the cost of manufacturing unleaded gaso-

line.  We included the octane-related performance issue as a

cost of manufacturing, not as performance degradation.  The

specific assumptions we made about the distribution of octane

requirements for misfuelers and leaded gasoline  vehicles are

discussed below.
* In  this paper, we define octane  to  be  the  average  of  research
  and motor octane, commonly  expressed as  (R +  M)/2.

-------
                             II.6


II.A.4. Octane Requirements

     If the no lead or low-lead options eliminate misfueling, we

must then identify what octane fuel the former misfuelers will

choose.  If all misfueling resulted from the current seven cent

per gallon average price differential, misfuelers would revert

to the lowest priced alternative.  In our two hypothetical

options, regular unleaded would be the least expensive.  If

about half of misfueling were due to price and half to performance

considerations, half of the misfuelers would drop to 87 octane

regular unleaded* but the other half would still require 89

octane.**  If all misfueling were due to octane needs, misfueled

cars would still require 89 octane after reverting to unleaded.

     We believe the intermediate case (half misfueling due to

price and half to octane) is the most reasonable assumption,

but we have calculated the range of costs for the various

assumptions.
 * Currently, the average octane of "87 octane" unleaded is
   really above 87 octane and the average octane of leaded
   gasoline and premium unleaded is also above the number
   specified.  We have used the real average octanes, not
   their numerical specifications,  for the three gasoline
   grades in our model, but we refer to them as "87 octane,"
   etc., for convenience.

** An 89 octane unleaded grade need not be specifically
   manufactured for retail outlets.  Most gasoline stations
   now have three pumps.  If they ceased selling leaded,
   they could attach the third pump to a blend of regular
   unleaded (87 octane) and premium unleaded (91 octane),
   thereby producing a mid-grade fuel.

-------
                             II.7


     The second policy option we analyzed was eliminating all

leaded gasoline.  To estimate the costs for this case we used

the projected total 1988 demand for gasoline.*  Here, again, we

had to allocate octane demand.  We used the same assumptions about

misfuelers as before.  We assumed people who owned leaded gasoline

vehicles would continue to require an average of 89 octane.


II.B.  Reduction in Lead Emissions

     Our analysis of reduced lead emissions assumed that every

gram of lead entering a car's gas tank came out its tailpipe.

In fact, some lead ends up in the oil (and may end up as waste

oil recycled for home heating) and some adheres to the exhaust

system and tailpipe, eventually flaking off.  Ultimately, however,

all lead in gasoline ends up in the environment as a potential

source of lead contamination.

     To estimate the reduction  in lead emissions, we first

computed the number of tons of  lead that would be removed in

1988 under our base case.  We used gasoline demands  from Table

II-l and assumed 1.1 grams of lead per gallon of gasoline (the

amount allowed under current  regulations).

     To calculate the  tons of lead removed under the all unleaded

option, we took the volume of leaded  gasoline that would be used

in 1988 assuming no  changes in  current rules or practices  (i.e.,
* We may  have  overestimated  costs  by  assuming  that unleaded
  demand  would  equal  total demand  in  the  all  unleaded  case.
  We assumed  demand would not  change  as  a result  of changing
  prices,  i.e.,  we assumed no  elasticity  of demand.

-------
                               II.8



 1.1  grams  of  lead  per  gallon  and  continued misfueling).   Multi-

 plying that volume  (32.4  billion  gallons) by  the  lead  content

 (1.1 g/gal) gave us the total  amount of  lead  reduced in  the  all

 unleaded options.  The result, shown in  Table II.3, was  35,600

 metric tons of  lead removed.

     For the  low-lead  option we needed to calculate the  lead

 emissions  resulting from  that  reduction  option  (i.e.,  demand

 [22.4 billion gallons] times  0.10 grams  per gallon).   Subtracting

 the  lead emissions under  the low-lead option  from  1988 emissions

 based on no changes in rules gave us emission reductions  of
        •
 33,400 metric tons, shown in Table II-3.



                         Table I1-3

            METRIC TONS OF LEAD REMOVED  IN 1988*

                                                %

                 Low-Lead         All Unleaded

                  33,400             35,600



 *Computed  by assuming  1.1 grams of lead  per gallon and using
 gasoline  demands from Table II-l.



 II.C.  Cost Estimate

     To estimate the costs of lowering the lead content of

gasoline, we used the Department of Energy's  linear program-

ming model of the petroleum refinery industry.  The model and

oil refinery processes are described in  greater detail in

Section II.F.

-------
                               II.9





     Using the DOE refinery model and the assumptions described



above, we have estimated the cost differences for our two cases.



The costs, and their sensitivities to octane assumptions, are



discussed below.  These costs have been estimated for several



different scenarios that indicate sensitivities to the basic



assumptions.



     Our cost analysis indicated that reducing the amount of



lead in gasoline would involve relatively little capital cost.



This is because refiners overbuilt catalytic reforming capacity



before the 1978 Iranian revolution and were left with a surplus



as oil prices rose and gasoline demand fell.  The capital costs



of this excess capacity are already sunk.





II.C.I.  Incremental Cost of the All Unleaded Case



     We computed costs for three different categories of octane



demand:  a high octane scenario, a low octane scenario, and an



intermediate octane scenario.  We also looked at how sensitive



our cost numbers were to changes  in projected demand for gasoline.



     We examined one additional factor that influenced costs.



There are several octane boosting additives besides lead on



the market.  One of them, ethanol, receives large government



subsidies.  If we allowed ethanol demand to vary among our cases,



and the model "saved money" by replacing lead with subsidized



ethanol rather  than using a more  expensive alternative, we would



be underestimating the cost of removing  lead.  We avoided this  by



holding the quantity of ethanol used  constant as lead was removed

-------
                               11.10



 Because  other  additives  frequently contain  fewer  BTUs  per  barrel


 than  gasoline,  whenever  additive  use  increased  we readjusted


 total  demand to keep  BTUs,  rather than  volume,  constant.


      Case  1:   High Octane Demand.  If we  assumed  all misfueling


 was for  octane,  not price,  the annual cost  of removing  lead from


 gasoline would  be $759 million, of which  $104 million was  the


 cost  of  moving  misfuelers back to unleaded  and  $655 million was


 the cost of eliminating  leaded gasoline.


      Case  2:  Low Octane Demand.  At the  other  extreme, if we


 assumed  that 50% of the  people using 91 octane  premium  unleaded

                      •
 would  be satisfied by an 89 octane mid-grade unleaded,  and that


 50% of misfueling was due to price, the annual  cost would decrease


 to $538  million, of which $66 million was the cost of moving


 misfuelers back  to unleaded and $482 was  the cost of eliminating
                                                              •

 leaded gasoline.  (The petroleum  industry's Coordinating Research


 Council  studies of octane satisfaction suggested  that about half


 of the people using 91 octane premium unleaded would be satisfied


 by 89 octane unleaded.)


     Case  3:  Intermediate Scenario.  If we left  all the premium


 unleaded demand at 91 octane and assumed that half of misfueling


was due  to price, the annual cost would be $691 million (of


which $104 million, as in case 1,  was the cost of moving mis-


fuelers).  We have used this number in Summary Table 1 because


we believe that at least half of misfueling was due to price.


Also,  we cannot be sure that premium unleaded users will switch

-------
                              11.11


to a lower grade, although we believe that some will.  This point

estimate represents caution, not expectation.

     Case 4:  Volume Sensitivity.  This was measured against

demand in the high octane case (6.5 million barrels), the most

expensive case.  If gasoline demand were 6.75 million barrels

per day,  our estimate for the high octane scenario would be

$761 million.  If gasoline demand were 6.25 million barrels

per day,  it would be $759 million.


II.C.2.  Low-lead Case

     The 0.10 gram of lead per gallon of gasoline case resulted

in annual costs of $550 million in 1988, assuming all misfueling

were due to octane, and $503 million, if half were due to price.

In the low octane demand case, costs would be reduced to $410

million.



                           TABLE I1-4

     Cost of Reducing or Banning Leaded Gasoline Production


                                                       cents*/
                               Point     Misfueling    leaded
                    Range	Estimate    Portion      gallon
                       (millions of 1983 dollars)

Low-lead          $410-550      $503        $104        1.66£
(0.10 g/gal)

All Unleaded      $538-759      $691        $100        2.13£
* This is the increased cost of making gasoline under the two
  options divided by the number of gallons of leaded gasoline
  in the base case.

-------
                               11.12


     As  a  check on  the plausibility  of  the  model,  we  examined

 the  spot price* differential  between leaded regular and  unleaded

 regular  for  barge load quantities  of fuel.   This  differential has

 been between one and four  cents/gallon  for  the  last few  years.

 While spot prices can differ  from  manufacturing costs, they will

 not  differ for long periods unless there  are supply constraints.

 As the last  column  in Table II-4 indicates,  when  we allocated the

 cost of  removing all lead  from gasoline to  our projected  leaded

 gasoline demand, we obtained  a cost  per gallon well within the

 range of market price differences  between leaded  and  unleaded

 regular  gasoline.   This confirms that.our cost estimates  are

 reasonable.


 II.C.3.  Cost of Lead Reduction

     The low-lead and the  all unleaded options would  reduce lead

 emissions by about 33,400  and 35,600 metric  tons,  respectively,

 in 1988.   The cost per metric ton  of avoided  lead  emissions,

 therefore,  would be about  $15,100  for the low-lead option and

 $19,400  for  the all unleaded  option.  (These  figures  are  not net

 of vehicle maintenance savings, which we discuss  in Chapter III.)


 II.D.  Price Differentials

     Our  estimates assessed incremental changes in manufacturing

costs;  they do not indicate what changes might occur  in consumer
* "Spot price" refers to the price of large quantity purchases
  on the open market, as compared to long-term supply contracts.

-------
                              11.13





prices.   Consumer price differentials between leaded,  unleaded



regular, and unleaded premium gasoline currently are considerably



larger than the differences in manufacturing costs of  the three



grades and considerably larger than the refiners'  price differen-



tial to intermediate and bulk purchasers.   For example, average



spot price differentials between leaded regular and unleaded



regular for barge load quantities in New York harbor were 1.29



cents per gallon in December 1983.   The differential at the



Gulf termini of the pipelines bringing gasoline from the Gulf



to the Northeast was 1.1 cents per gallon.  Contract price dif-



ferentials in the Gulf were 2.75 cents per gallon in Houston.



(The source of these price differentials is Platts Oilgram.)  On



the other hand, retail price differentials are usually seven



cents per gallon.  This indicated that most of the price differen-



tial was added at the retail level, and may be part of the retail-



ers' marketing strategy of cross-subsidization, where  leaded



gasoline serves as a "loss leader" product.



     Apparently, price differentials depend on market  conditions



and oil company marketing strategies as well as costs.  For



example, most gasoline marketers presently seem to be  selling



regular leaded gasoline as a very low margin product,  and are



making their profit on unleaded grades.  This situation has



occurred in the past with regular or subregular leaded grades



vs. premium leaded gasolines.  The two most common explanations



are that consumers shop on the basis of the lowest cost gasoline



offered regardless of whether  they purchase that gasoline, and

-------
                               11.14






 that the price elasticity of demand for gasoline is higher for



 users of leaded gasoline, perhaps because they own older cars.



      It  is  difficult  and  beyond  the scope of  this analysis to



 predict  what marketing  strategies might be adopted if either



 the  low-lead or all unleaded policy options were implemented.



 Under either of our hypothetical  options,  however,  regular



 unleaded gasoline would be  the lowest  cost product.   In  fact,



 the  model showed that in  the 0.10 gram case the marginal  cost  of



 making unleaded gasoline  would decrease  slightly from its



 cost in  the  base case, while the  costs of  leaded gasoline and



 premium  unleaded gasoline would both increase  by about one  cent



 per  gallon.   If marketers continue  to  make the lowest cost  product



 the  "fighting"  grade, then  the current  situation will invert,



 with regular unleaded gasoline prices  falling  and leaded  and



 intermediate-grade unleaded  becoming the  high  profit  products.



 The  differences  in prices that individual  consumers pay will



 depend upon  changes in retail marketing strategies.



      In  this  analysis, however, we  used the real  resource costs



 of manufacturing to measure economic costs.  We  expect these to



 reflect  the  differences in prices that consumers  pay  on average.



 That  is,  we  believe that  all manufacturing costs  will be passed



on to consumers, and that average retail margins  will not



 increase, although their  distribution among grades may change.





II.E.  Longer Term Projections



     The costs  for both the 0.10 grams per gallon and the all



unleaded cases will decline over time because the total demand

-------
                              11.15




for leaded gasoline will shrink as the fleet of vehicles designed


for leaded gasoline retires.  Thus, these restrictions will


affect fewer gallons of gasoline in later years.




II.F.  Refinery Model


   Our estimates of the costs of lowering the lead content of


gasoline, given these various projections, were calculated using


the DOE linear programming model of the petroleum refining indus-


try.  The model simulates current and projected U.S. refining


capacity, using available crude oil supplies, and projected


imports to meet expected U.S. petroleum product demands.  The


objective function is to minimize costs, subject to constraints


on lead usage.  The model recently has been subjected to two


verification checks by the Department of Energy (DOE), described


in Attachment 1.
                 »



II.F.I. General Description of DOE Petroleum Refinery Yield Model


     The DOE Refinery Yield Model estimates optimal refining


industry operations under a range of assumptions and operating


conditions.  The solution provides "optimum" petroleum flows,


prices, investments, etc., for the petroleum refining industry.


In addition to the optimal answer, the model provides valuable


economic  information on  important aspects of the refining  indus-


try's operations, such as the rate at which costs change  (the


marginal  costs and values of specific refinery  processes)  as


refinery  operations are  altered  to change the yield of products


or  to accommodate different  inputs.

-------
                               11.16


      The  model  contains  approximately  350  equations  to  simulate

 the  process  by  which  crude  oil  and other  inputs  are  turned

 into various  products and the costs  that are  thereby incurred.

 The  model  can show  which products can  be made  at varying  costs

 in the many  different refineries that  exist throughout  the world.

 It allows  investment  in  new equipment  in later years  at a real

 (constant dollar) capital charge of  15%.

      The  DOE  model  is based on many  fairly similar models

 developed and used  widely by the petroleum refining  industry for

 years.  The  refinery  industry model  was one of the earliest

 industrial applications of linear programming.

      The  basic model has been used by  EPA  in  its  analyses of the

 impacts of regulations on the petroleum industry  and on petroleum

 product purchasers, and served DOE in many ways,  including:

      0 evaluating Strategic Petroleum  Reserve crude mixes for
       selections of storage sites,

      0 assessing the impacts of petroleum disruptions on
       product supplies, and

      0 evaluating the industry's capability to respond  to
       changes in feedstock quality or product demands.

     To understand  the model, it is useful to describe  briefly

 how refineries work.  Exhibit II-l is a schematic of a very

simple refinery, often called a topping plant, which processes

low sulphur crude oils.   A complex refinery contains distil-

lation units  and other types of processing units.  Exhibits

II-2, II-3, and II-4 (provided by Sobotka and Company, Inc.)

illustrate schematics of such refineries.   (The model presents

-------
                              11.17



considerably more detail than even these exhibits indicate.)


In all refineries, there is a selection of a combination of


different process "units" that can be assembled into final


structures that accomplish different but related purposes,


and that look similar.  The basic similarity of process units


makes it possible to model refineries.


     Basically, the model is a system in which the various


units that make up all types of refineries are represented by


the boxes in the schematics.  Each unit takes in a raw material


(crude oil or an intermediate product) and makes one or more


intermediate or final products (and often some pollutants).


The exact types and quantities of the product(s) made are

functions of the properties of the inputs of each unit and the


process that each performs.  Fuel and utilities (e.g., electri-

                                «
city and steam) are consumed and an operating cost is incurred


for each operation.  A capital cost may or may not be charged,


as appropriate to the particular analysis being performed.


Exhibit II-5 is a summary of the basic types of refinery pro-


cesses.  Attachment 2 to this chapter contains a more detailed


description of processing operations.


     Because all refineries are made up of these building


blocks, the smallest structure in the model is a process unit


rather than a plant.  The individual functions that are


modeled are the  inputs and outputs from each type of unit.


The model is made up of refinery units, each of which has an


output (or a series of products), the quantity of which  is a

-------
                      11.18


                  EXHIBIT II-l


     FLOW DIAGRAM OF  TOPPING REFINERY
     PROCESSING LOW SULFUR CRUDE OIL
  GAS
                                                                                                  YIELD. VOLUMI
                                                                                                   PERCENT OF
                                                                                                  RAW MATERIAL


CRUDE
OIL
DISTILLATION




GASOLINE (LOW OCTANE)

NAPHTHA
LIGHT GAS
HEAVY GAS


OIL ^
OIL

RESIDUE
*-
8
I
0
1
N
G

B
L
E
N
0
1
N
G
 REFINERY
 GAS FUEL
 (CONSUMED
  INTERNALLY)

 PETCHEM FEED
 a MILITARY
 JET FUEL
                                                                                       KEROSENE.
                                                                                       DISTILLATE
                                                                                      •FUELOIL a
                                                                                       DIESEL FUEL
 RESIDUAL
» FUEL OIL

 REFINERY
 LIQUID FUEL
 (CONSUMED
  INTERNALLY)
                                                                                                      3.1




                                                                                                    33.1
               25.5
                                                                                                    37.2

                                                                                                      *
*Included  with  gas  fuel

-------
                                 II. 19
                              EXHIBIT II-2
             FLOW DIAGRAM OF HYDROSKIMMING  REFINERY
                PROCESSING LOW SULFUR CRUDE OIL
            GAS
                                                                BUTANE (HIGH OCTANE)
                      GASOLINE (LOW OCTANE)
                                                   GASOLINE (HIGH OCTANE)
CRUDE
            RESIDUE
                                                                                                   REFINERY GAS
                                                                                                   FUEL (CONSUMED
                                                                                                    INTERNALLY)
                                                                                                   GASOLINES
YIELD. VOLUME
 PERCENT OF
RAW MATERIALS
                                                                                                   KEROSENE.
                                                                                                   JET FUEL.
                                                                                                   DISTILLATE
                                                                                                   FUEL OIL 8
                                                                                                   DIESEL FUEL
                                                                                                   RESIDUAL
                                                                                                 ^ FUEL OIL

                                                                                                  REFINERY LIQUID
                                                                                                  FUEL (CONSUMED
                                                                                                   INTERNALLY)
    4.9

    2.2



  29.0
  25.5
  38.3

   *
           *  Included with gas fuel

-------
                             11.20
                          EXHIBIT II-3

              FLOW DIAGRAM OF FUELS REFINERY
              PROCESSING HIGH SULFUR CRUDE OIL

r

HYDROGEN
RECOVERY 6
MANUFACTURE
SULFUR
RECOVERY
HYDROGEN

NATURAL GAS LIQUIDS
                    GASOLINE (LOW OCTANE)
                                                  GASOLINE (HIGH OCTANE)
                  ((OPTIONAL)
                  I
                    •	» (ASPHALT)
            Percent  by weight
            Included  with  gas  fuel
* SULFUR
 FOR HYDROGEN
 TREATING
 REFINERY GAS
 FUEL (CONSUMED
  INTERNALLY)
                                                                                                 GASOLINES
YIELD. VOLUME
 PERCENT OF
RAW MATERIALS

    1.5*
   11.0

    2.3



   53.8
                                                                                                 KEROSENE,
                                                                                                 JET FUEL,
                                                                                                 DISTILLATE
                                                                                                 FUEL OIL 6
                                                                                                 DIESEL FUEL
 RESIDUAL
 FUEL OIL


 REFINERY
 LIQUID FUEL
 (CONSUMED
  INTERNALLY)
                  27.4
                                                                                                                   8.1

-------
                               T I  "> 1
                               1 I . - I
                           EXHIBIT II-4


          FLOW DIAGRAM OF HIGH CONVERSION REFINERY
               PROCESSING  HIGH  SULFUR CRUDE  OIL
NATURAL GAS LIQUIDS
 SULFUR
RECOVERY
                                                                        HYDROGEN
                                                                       RECOVERY B
                                                                       MANUFACTURE
                                                         LIGHT
                                                         ENDS
                                                       PROCESSING
                                                                               (HIGH OCTANE)
                     GASOLINE (LOW OCTANE)
                                                   GASOLINE (HIGH OCTANE)
               LIGHT GAS OIL
    DISTILLATION
               HEAVY GAS
                   OIL
                                                   GASOLINE (MEDIUM OCTANE)
    DISTILLATION
         VACUUM
         PITCH
                                           I  I GASOLINE (LOW OCTANE)
                                             JNAPHTHA
                                         _J GAS OIL
SULFUR

FOR HYDROGEN
TREATING
REFINERY
GAS FUEL
(CONSUMED
 INTERNALLY)
                                                                                                    GASOLINES
YIELD. VOLUME
 PERCENT OF
RAW MATERIALS

     1.4*
                              13.0
                                                                                                   KEROSENE.
                                                                                                   JET FUEL.
                                                                                                   DISTILLATE
                                                                                                   FUEL OIL 8
                                                                                                   DIESEL FUEL
            REFINERY
            LIQUID FUEL
            (CONSUMED
              INTERNALLY)
                                                                                                   HIGH SULFUR
                                                                                                   COKE
                                                                                                                    77.5
                              10.8
                              4.6*
         *  Percent by weight
         ** Included  with gas  fuel

-------
                                  11.22
                               EXHIBIT II-5
       FUNCTIONAL  CHARACTERIZATION  OF PETROLEUM  REFINERY  PROCESSES
        SEPARATION
A.  Separation  on  the Basis of
    Molecular Weight

    Distillation (atmospheric and
     vacuum fractionation of crude
     oil, naphtha splitting,
     depropanizing, stabilization)

   Absorption  (recovery of olefins
     from catalytic cracked gas,
     recovery of propane from
     natural gas or hydrocracked
     gas)

   Extraction (deasphalting of feed-
     stock for lubricating oil manu-
     facture or for catalytic
     cracking)

B.  Separation on the Basis of
   Molecular Structure

   Extraction  (recovery of
     benzene,  toluene,  and zylenes
     from catalytic  reformate,
     removal  of aromatics  from
     lubricating oil  feedstock)

   Crystallization (dewaxing  of
     lubricating oils,  recovery  of
     paraxylene from  mixed  xylenes)
     ALTERATION  (CONVERSION)

 A.  Conversion on  the  Basis  of
    Molecular Weight

    Thermal  cracking (visbreaking,
     coking)

    Catalytic cracking

    Hydrocracking

   Alkylation

    Polymerization
B. Conversion on the Basis of
   Molecular Structure

   Catalytic reforming (benzene,
     toluene, and xylene manufac-
     ture and octane improvement)
   Isomerization (normal butane to
     iso for alkylation, normal
     pentane and hexane to iso
     for octane improvement)
                     TREATMENT TO  REMOVE  IMPURITIES

                     Hydrogen treatment (hydrotreating)

                     Caustic treatment  (Merox, Bender)

                     Clay treatment  (of lubricating oils)

                     Acid treatment

-------
                             11.23





function of the material that the unit is "fed."  Each unit




incurs some costs that vary with how hard it is run — called



"severity".



     The model can be operated in either of two modes — minimum



cost or maximum profit.  It can constrain product quantities and



compute a minimum cost solution.  (This is useful for analyzing



large refining regions in which aggregate demands can be forecast.)



Alternatively, the simulation can vary product quantities at



preselected prices.



     The principal purpose of using computer models to simulate



petroleum operations is to measure differences between alter-



native scenarios in order to estimate the changes in petroleum



activities when some conditions change.  Simulations of petroleum



activities are complex.  The models are more reliable for deter-



mining differences in costs between scenarios than they are for



predicting the total costs of manufacturing all petroleum



products in the United States.  So the major focus of analyses



should be differences between alternative model solutions.



These practical considerations should be kept in mind in the



interpretation of model results.



     Exhibits II-6 and II-7 illustrate the basic structure of the



linear programming refinery model.  All processes consist of a



series of linear relationships that describe the process output



and operating cost, given a specific input and a set of operating



conditions.  The relationships are stored in the model in the



form of a process data table.  Each column in this process table



represents the processing of a specific type of crude oil and

-------
                              11.24






each row represents a specific  input or output stream, fuel,



utility consumption, etc.  For  example, the first column  in



Exhibit II-6 specifies that as  one barrel of Saudi Light  crude



is processed, a mix of sixteen  intermediate streams is created.



The operation consumes fuel, power, steam, and capacity,  and



incurs variable operating costs of 9.2 cents per barrel.



     Finally, after all processing is complete, the refinery



ends up with numerous process output streams that are blended



together to produce final, salable refined products.  This



activity is represented in the model by product blending units.



The blending units contain quality data for all refinery streams



and quality specifications for final products.  The components



are then combined by the model such that the qualities of the



blended mixes meet the minimum requirements of product



specifications.



     Exhibit II-8 presents projected capacity in 1988 for



various processing units in the model.

-------
                             11.25
                        EXHIBIT II-6
             YIELDS AND OPERATING COST COEFFICIENTS
                    CRUDE DISTILLATION UNIT
SAUDI ARAB LIGHT
SAUDI ARAB HEAVY
MEXICAN MAYA
CAPACITY FACTOR
                                           Crude Oil Type
                                       Saudi Arab     Mexican
                                     Light    Heavy     Maya
 -1


 1.0
 -1

1.0
-1
1.0
                                     Yields  (Fraction of  Intake)
STILL GAS
PROPANE
ISOBUTANE
NORMAL BUTANE
LT ST RUN (C5-175) LO OCT
LT ST RUN (C5-175) INT OCT
LT NAPH (175-250) PARF
LT NAPH (175-250) INTM
NAPH (250-325) PARF
NAPH (350-325) INTM
HVY NAPH (325-375) PARF
HVY NAPH (325-375) INTM
KERO (375-500) JET FUEL QUALITY
KERO (375-500) OTHER
DIST (500-620) HI SULFER
HY GAS OIL (800-BTMS) (2.0% S)
ASPH VERY HI SUL  (4.3% S)
 .001
 .003
 .002
 .013
 .051

 .070

 .050
 .020
 .020
 .020
 .115
 .015
 .130
 .180
 .143
 .001
 .003
 .002
 .015

 .040
 .060

 .044
 .011
 .020
 .014
 .090
 .005
 .090
 .180
 .300
 .001
 .003
 .002
 .009

 .035
 .025
 .025
 .010
 .050
 .005
 .030
 .070
 .040
 .100
 .105
 .350
FUEL, FUEL OIL EQUIVALENT
POWER, KWH
STEAM, LB
OTH VAR OP COST, $
CAPITAL CHARGE
                                     Operating  Cost  Coefficients
                                       (Per Barrel  of Throughput)
-.021
-0.6
-60.7
-.092
-.022
-0.6
-63.4
-.093
varies
-.020
-0.6
-57.9
-.092
Note: The negative signs  (-)  indicate  consumption  of  crude  oil,
      fuel oil, power, steam, etc.

-------
                               11.26
                          EXHIBIT II-7
               YIELDS  AND OPERATING COST COEFFICIENTS
                      CATALYTIC  REFORMING UNIT
                   (200  PSIG  Operating  Pressure)
                                    Paraffinic
                                    Feedstocks
                    Naphthenic
                    Feedstocks
                                 90  RON   100  RON   90 RON  100 RON
REF FEED  (250-325) PARF
REF FEED  (250-325) NAPH
CAPACITY  FACTOR
  -1

 .95
  -1

1.05
  -1
 .95
  -1
1.05
                                  Yields  (Fraction  of  Intake)
H2 (100 PCT FOE)
STILL GAS
PROPANE
ISOBUTANE
NORMAL BUTANE
REFORMATE (90 RON)
REFORMATE (100 RON)
LOSS
.034
.036
.031
.020
.037
.852

.010
.041
.069
.076
.029
.052

.739
-.006
.047
.025
.015
.003
.005
.930

-.025
.056
.036
.030
.007
.012

.886
-.027
FUEL, FUEL OIL EQUIVALENT
ELECTRICITY, KWH
STEAM, LB
OTH VAR OP COST, $
CAPITAL CHARGE
                                   Operating Cost Coefficients
                                     (Per Barrel of Thoughput)
-.04,2
-2.6
-75.
-.099
-.045
-2.6
-75.
-.108
-.042
-2.6
-75.
-.099
-.045
-2.6
-75.
-.108
              varies
Note: The negative signs (-) indicate consumption of  crude oil,
      fuel oil, power, steam, etc.

-------
                           11.27


                       EXHIBIT II-8
ESTIMATED U.S. REFINERY PROCESSING UNIT CAPACITIES FOR 1988
               (thousands of barrels per day)
   PROCESSING UNIT                       CAPACITY

   CRUDE DISTILLATION                     15,900
   COKER-DELAYED                           1,175
   COKER FLUID                               170
   VISCBREAKER                               170
   NAPHTHA HYDROTREATER                    3,770
   DISTILLATE HDS                          2,670
   FCC FEED HYDROFINER                     1,085
   RESID DESULFURIZER                        580
   CAT REFORMER  450 PSI                     760
   CAT REFORMER  200 PSI                   3,145
   FLUID CAT CRACKER                       5,325
   HYDROCRACKER - 2 STAGE                    980
   ALKYLATION PLANT                          960
   CAT POLYMERIZATION                         77
   HYDROGEN PLT, MBPD FOE                    115
   AROMATICS RECOVERY PL                     300
   PEN/HEX ISOMERIZATION                     140
   BUTANE ISOMERIZATION                       55
   LUBE + WAX PLANTS                         240

-------
                                      11.28

                           Attachment  1  to Chapter  II

               Evolution of DOE  Refinery Model and  Current  Status

      In  late  1983 Decision Analysis  Corporation and  Sobotka  & Company,  Inc.,
 jointly  updated  the  Department  of  Energy's  Refinery  Yield  Model  (RYM) and
 performed model  verification tests for  the Energy Information Administration.
 The recent  update involved revisions  to the model's raw material availability,
 product  demands,  and  product  specifications  to  reflect  a  1982  environment.
 Processing  capacities  were revised to represent operable capacity on January 1,
 1983, as reported by  DOE.  In addition,  the model's technical representations
 were altered  to  reflect  changes or improvements  in processing technology that
 have  taken  place since the original  model development, to  update  major  crude
 assays,  and to  expand processing  flexibility  in  the residual  fuel  portion of
 the crude oil barrel.

     The verification  tests  of  the udpated model  were  conducted  to determine
 how closely the  RYM  could  simulate refinery activities in 1982.  The verifica-
 tion  test runs  on the updated model  were designed  to  verify material balance
 closure  in  the  model  solution and to assess  the  capability of the  models to
 simulate actual regional refining activities.  Each regional model was run with
 most crude  and products specified  at  actual 1982 levels.  The model then simu-
 lated the 1982 operations with some flexibility to vary marginal feedstocks and
 products.  After  the  Initial  check for  overall material balance  closure, the
 model results were compared with  actual  1982 refining balances, process utiliza-
 tions, and  economic  relationships.   The  verification  tests  and  results are
 discussed in more detail below.

Verification Methodology

     The Refinery Yield Model (RYM) verification tests consisted of two simula-
tions for each model  region,  Verification  A and  Verification  B,  specified as
 follows:

-------
                                     11.29

     Verification A;  All  crudes  except  for a  marginal high  and  a  marginal
low sulfur crude were  fixed at  the actual  1982 levelI/ as were natural gasoline,
plant condensate, outside  fuel and  utility  purchases,  and  unfinished  oils.£/
The marginal crudes were permitted to vary within a range equal to about 2 to 3
percent of actual crude input.  Butane purchases  were also  allowed to  vary but
were not allowed to exceed actual.   Product  output  was  fixed at the 1982 level
except for liquefied petroleum gas (LPG),  coke, and low and  high sulfur residual
fuel.

     Verification B;  All  input was  specified at  the  1982  level.   Gasoline,
distillate fuel, LPG, coke, and low and high sulfur residual fuels were allowed
to vary while all other output was fixed at 1982 volumes.

     The primary purpose  of  the first simulation test,  Verification A, was to
check the model for  face  validity.   This included first a check for material
balance closure  in  the  overall refining  operations as well as in each  process-
ing and  blending operation.   The results  were  then  compared  against actual
operations to  check  the  ability  to meet  end product  demand  with available
feedstocks and  to check the model's  calculation  of fuel consumption.   Finally,
                                             «
the Initial  simulations were  checked to ascertain if model economics and pro-
cessing operations  were within acceptable limits.

     The second verification   simulation  runs,  Verification  B,  allowed for an
additional check of model face validity.  The refinery material balances  and
projected economics  were  again checked  against  actuals.   In this  case,  the
models were  allowed  more flexibility  to optimize  and  would be  expected to
operate major  conversion processing  at  maximum.  The  product prices  provided
      I/  Actual  crude types were estimated by the contractors, based  on avail-
able  DOE data.
      2/  Actual  natural  gas input  was assumed  to  be  equivalent to  reported
natural gas consumed for  fuel.   Actually, refiners  may use  additional  natural
gas as hydrogen  plant feed.  In the district 13 model, a large volume of natural
gas was routed  to  the hydrogen plant,  and  therefore,  natural gas  purchases were
increased  about  25 percent.

-------
                                      11.30

 are  those  which  would result  if all  these facilities  were in  short  supply
 (which  was  the  actual  situation  during  1982).

     Verification B runs also  provided  an  assessment  of model  overoptlmization.
 The  volumes  of  light and heavy products produced  from the 1982 volume of  feed-
 stocks  were compared for each region run to evaluate the impact of overoptimiza-
 tion of product yield  capabilities*  In this  comparison, the sum  of gasoline
 and  distillate  production  was compared  to actual  rather  than  production of
 individual  products.   The   actual gasoline-distillate  mix  is  a   function of
 regional weighted  average  price  differentials  for 1982.   The available  price
 data are not  sufficient  to  accurately test the model's projection of gasoline-
 distillate  production  costs.

     Verification A Results;  The  results   of  the initial  verification  showed
 that the model  was able  to  balance all material and account for all processing
 streams.  The model provides a  summary  for each processing and blending  opera-
 tion which  includes a  balance row  indicating  any stream  not  accounted for in
 the  model.  The balance rows for all regional models were zero.

     The model  was able  to  produce a product  slate  close to actual operations
 with available  raw materials.   The  flows  calculated by  the model  were very
 close to actual  figures.  The  model used  about two  percent less  feedstock, and
 produced about  two percent  less output.   The  model calculated a  four percent
 loss of  petroleum (products  excluding  refinery   fuel)  which  is   exactly the
 actual  1982 loss.   Refinery fuel was  about five  percent  higher  in the model,
 indicating that  the  process  efficiencies   within the  model  may  be  slightly
 under-estimated.

     Crude and product prices varied from region to region, but in general were
reasonable.  Gasoline  and distillate  prices were  close,  with  regular gasoline
 typically less than one dollar per barrel  above middle distillate.   Low sulfur
residual fuel was  $6-8 per  barrel below distillates and high sulfur  residual
around  $15 below.  These results compare well with 1982 actual price differen-
tials.

-------
                                      11.31

     Verification B Results;  The aggregate U.S. refining  balance from Verifi-
cation B was close  to  actual 1982 operations.  The  models overstated the cap-
ability to produce  light  products by about 276,000  barrels  per day (i.e., the
yield of gasoline plus distillate per barrel  of crude  was overstated by 2.3Z).
The Verification B  results  indicated  a  large  reduction in high sulfur residual
versus actual.  The high sulfur residual  reduction was also due in part to the
nature of the  test.  Refining  regions were not required  to produce a very low
sulfur fuel grade that is typical of  some regions, and were thus able to blend
a greater  volume  of  high  sulfur  components  to  low  sulfur  residual  to  meet
product demands.  Fuel consumption calculated by the model was about 11% higher
than actual, but  as a  percent of  total  crude input  there is less  than  a 1Z
difference.

     The combination of Verifications A and B provide substantial confidence in
the model's ability to predict  the changes in costs and  in operations  that would
take place in  the  domestic  petroleum refining industry if gasoline  specifica-
tions, such as limits on the use of  lead additives, were changed.  And the model
also provides  adequate  flexibility  in combining  refinery process units so that
the same analytical question can  be answered  for  subsections  of the petroleum
industry categorized by size of plant or firm, or by  the processing  complexities
of plants, or  geographically.

-------
                               TI.?2





                     ATTACHMENT 2 to CHAPTER II



                         Refinery Processes





      In  refining,  crude  oil  is first separated by molecular size



 into fractions,  each of  which can be blended directly into final



 petroleum products or processed  further.   In the downstream pro-



 cessing  operations,  the  molecular size  and structure of petroleum



 fractions are  altered to conform to  desired characteristics of



 refined  products.   Exhibit II-5  classifies the various refinery



 processes according  to their  principal  functions.   The actual



 processing configuration will depend on the characteristics of



 the  crude oil  processed  and on the desired final product mix.



 These major processing steps  are described briefly below.



     Fluid Catalytic  Cracking uses high temperature  in the pres-



 ence of  a catalyst  to convert or "crack" heavier fractions into



 lighter  products,  primarily gasoline  and distillates.   Feed is



 brought  to process conditions (1000°F and  20 pounds  per square



 inch pressure  [psi])  and  then mixed  with a  powdered  catalyst in  a



 reaction  vessel.   In  the  reactor, the cracking process is  complet-



 ed and the hydrocarbon products  pass  to a  fractionating  section



 for separation.



     Coke, a coal-like by-product, is formed on  the  catalyst as  a



 result of  the cracking reaction.  Coked catalyst  is  transferred



 from the  reactor to a regenerator vessel where air is  injected



 to burn the coke to CO and CC>2.  The regenerator  flue  gases are



passed through cyclones and,   sometimes, electrostatic  precipita-



 tors, to  remove entrained catalyst.  They are then vented  to the

-------
                              11.33





atmosphere or sent to a CO boiler where carbon monoxide is burned



to produce C02«  The regenerated catalyst is returned to the



reactor.



     Hydrotreating (also known as hydrodesulfurization) is a



catalytic process designed to remove sulfur, nitrogen, and



heavy metals from petroleum fractions.  Feed is heated to process



temperatures (650° to 705°F), mixed with hydrogen, and fed to



a reactor containing a fixed bed of catalyst.  The primary reac-



tions convert sulfur compounds in the feed to hydrogen sulfide



(H2S) and the nitrogen compounds to ammonia.  The H2S and



ammonia are separated from the desulfurized product; the H2S



is sent to sulfur recovery facilities.



     Catalytic reforming is used to upgrade low-octane naphtha



to produce high-octane gasoline blending stocks.  The flow pat-



tern is similar to that of hydrotreating except that several



reactor vessels are used.  The required temperature is about



1000°F and the required pressure is about 200 pounds per square



inch.  Reforming catalysts are readily poisoned by sulfur,



nitrogen, or heavy metals, and therefore the feed is normally



hydrotreated before being charged to the reforming unit.



     In hydrocracking the cracking reaction takes place in the



presence of hydrogen.  The process produces high quality desul-



furized gasoline and distillates from a wide variety of feed-



stocks.  The process employs one or more fixed bed reactors and



is similar in  flow to the hydrotreating process.  Process



conditions are 800°F and 2000 psi.  Like hydrotreating, hydro-

-------
 cracking  produces  by-product  H2S,  which  is  diverted  to sulfur
 recovery.
      Coking  is  another  type of  cracking  which does  not employ a
 catalyst  or  hydrogen.   The process  is  utilized to convert  heavy
 fuel  oils  into  light products and  a solid residue  (coke).   Feed
 is  brought to process conditions  (900°F  and 50 psi)  and fed to
 the coking vessel.  Cracked products are routed to a fractionation
 section.  Coke  accumulates in the  vessel and is drilled out about
 once  a day.  In one version of  the  coking process,  fluid coking,
 a portion of the coke is  used for  process fuel and  the balance
 is  removed as small particles.
      Acid gas treating  and sulfur  recovery  units are used  to
 recover hydrogen sulfide  (H2S)  from refinery gas streams and
 convert it to elemental sulfur.  Sour  gas containing H2& is
 produced  in several refinery  units, particularly cracking  and
 hydrotreating.  In the  acid gas treating units, H2S  is removed
 from  the fuel gas by absorbing  it  in an  alkaline solution.   This
 solution, in turn, is heated  and steam-stripped to remove  the
 H2S to form sulfur and water.    Sulfur  recovery  is high  but
 never 100%.  The remaining sulfur  is incinerated and discharged
 to the atmosphere or removed  by a tail gas  treating  unit.
     The purpose of the tail  gas treating unit  is to convert any
 remaining sulfur compounds from the sulfur  recovery  unit to
elemental sulfur.   There are  several processes  available,  the
most common of which are the  Beavon and SCOT processes.  In  both
processes, sulfur compounds in  the sulfur unit  tail  gas are

-------
                             11.35
converted to H2S.  The Beavon process converts I^S to sulfur
through a series of absorption and oxidation steps.  The SCOT
process concentrates the H2S and returns it to the sulfur
recovery facilities.  In both processes, the treated tail gas
is virtually free of sulfur compounds when released to the
atmosphere.

-------
                             11.36


                           References


Dupont Petroleum Chemicals, Tech Brief 17909, December 1979.

Energy Information Administration, Annual Report to Congress,
       1983.

Platts oilgram Price Report,  Price Average Supplement,
   December 1983 Monthly Averages;Thursday, January 26, 1984,

U.S. EPA, Motor Vehicle Tampering Survey 1982,  National
   Enforcement Investigations Center, April 1983.

U.S. EPA, 1982 "Regulation of Fuel and Fuel Additives,"
   47 Fed. Reg. 49382 (October 28, 1982).

-------
                            CHAPTER III


       BENEFITS FROM REDUCED VEHICLE MAINTENANCE REQUIREMENTS


       Lead in gasoline has served both beneficial and destructive

functions.  Refiners add lead because it is the least expensive

way to boost the octane of motor gasoline.  Thus, for gasolines

of equivalent octane, leaded gasoline would be less expensive to

make than unleaded gasoline.  However, when vehicles burn leaded

gasoline, deposits are formed in the engine and exhaust system.

To reduce combustion chamber deposits, organic halogens —

primarily ethylene dibromide (EDB) and ethylene dichloride (EDO

— are added to scavenge the lead.*  These compounds react with

most of the lead to form compounds more volatile than those formed

with lead alone, and are discharged in exhaust gases.  While this

effectively reduces combustion chamber deposits, a significant

portion still deposits on internal engine and exhaust system

surfaces.  Such deposits (e.g., halogen acids and lead salts),

become very corrosive in the humid and warm environments within

engines and exhaust systems.  For these and other reasons, the use

of unleaded gasoline reduces maintenance costs.

     The deposits from leaded gasoline form a coating on exhaust

valve seats.  On pre-1971 and some other vehicles, this thin layer

protects against the abrasive and adhesive wear that can occur

between the exhaust valve face and valve seat during certain engine
*Restricting or removing lead from gasoline would restrict or
 remove EDB and EDC.  This would have compounding environmental
 benefits as EDB, EDC, and lead are substances of concern in
 leaks from underground storage tanks and in tailpipe and
 evaporative emissions.  We have not included EDB or EDC benefits
 in our analysis.

-------
                                   III.2


 operating modes.  By 1971, however, several major engine manufac-

 turers were building vehicles with valve seat metallurgy that had

 minimized or eliminated valve recession with unleaded gasoline.

      Because leaded gasoline combustion products form engine

 deposits and corrode exhaust systems, studies have found four

 main categories of savings in operating and maintenance costs

 from switching to unleaded gasoline:

      0  less corrosion of the exhaust  train, requiring fewer
        muffler and exhaust pipe replacements;

      0  better engine performance due  to less fouling and
        corrosion of  spark  plugs;

      0  less corrosion and  rusting in  the engine,  decreasing
        engine  wear and  allowing longer periods  between oil
        changes;  and

      0  better  fuel economy,  relating  partly to  better engine
        performance (from the  effects  listed above),  and
        partly  to the  fact  that  unleaded  gasoline  contains
        more  energy content per  gallon  than  leaded gasoline.
        Quantitative  estimates of this  last  benefit,  however,
        are  less  reliable than the others.

 We discuss each  of these in the  sections  under Maintenance  Savings.

     As the  remainder of this chapter  indicates,  switching

 misfueled and other vehicles  currently using leaded  gasoline  to

 unleaded would likely produce millions of dollars  in  vehicle

 operation and maintenance savings.  The fuel economy  benefits

 are less certain and are not  included in our summation of mone-

 tized benefits.  Most cars using  regular leaded gasoline would

run as well, or better, on unleaded gasoline of the same octane.

However, some older engines and non-diesel trucks require the valve

lubrication that lead in gasoline provides.   Valve recession

-------
                              III.3





can occur in these engines from the inadequate lubrication of



exhaust valves, potentially resulting in premature valve failure.



The major constraint on an all unleaded policy in this decade



is a technical one:  some vehicles need the valve lubrication



currently provided by lead in gasoline.  The cost and practi-



cality of other solutions to this problem (e.g., other protective



additives or retrofits with improved valve seats) seem to pose



significant obstacles, but more information is needed to evaluate



these options.



     As an alternative, we examined the maintenance benefits



and technical feasibility of a low-lead option (0.10 grams of



lead per gallon of gasoline) to lower sustantially the current



concentrations of lead in gasoline (1.1 grams per gallon), but



still allow sufficient lead to protect valves.  The question of



the linearity of the maintenance benefits, and an estimate of



the dollar savings at 0.1 grams of lead per gallon of gasoline



follow the discussion of the all unleaded case.



     We have not included three additional adverse effects due



to misfueling:  plugging of catalytic converters, clogging of



exhaust gas recirculation (EGR) valves, and reduced performance



from exhaust gas oxygen sensors.  In a recent communication



with the Motor Vehicle Manufacturers Association (MVMA, 1984),



these effects were raised, and subsequent contacts with automotive




engineers substantiated the engineering rationales for these



effects.  The mechanisms for coating engine systems and exhaust



systems would also plug catalysts and EGR valves and coat oxygen



sensors.  Extensive testing on another metal-based fuel additive,

-------
                               III.4


 methylcyclopentadienyl  manganese  tricarbonyl  (MMT),  clearly

 demonstrated  the  existence  of  catalyst  and  EGR  valve plugging

 and  interference  with oxygen sensors.

      Catalyst  plugging  may  result  in  back pressure problems.

 Interference with oxygen  sensors and  closed-loop  systems will

 affect  fuel metering systems regulating  the air-fuel ratio.

 Both  affect driveability  and fuel economy.  Finally,  plugging

 the  EGR valve  can also  adversely affect  fuel  economy, knock,

 and  driveability.  Some of  these effects were observed with MMT

 use  and there  is  a plausible case for their occurrence with lead

 use  in cars designed for  unleaded gasoline.*

      MVMA  (1984)  valued the cost to a single  consumer for catalyst

 plugging at $300, for EGR plugging at $60, and  for oxygen sensor

 disruption at  $75, all  after 50,000 miles of driving.  Given the

 large number of misfuelers, approximately 13.5% of light-duty

 vehicles (EPA, 1983), the aggregate costs could be large.  However,

 because we do  not have  the  "dose-response" function  for these

 effects, we could not evaluate them under the regulatory options

 examined here.  Therefore, we have not monetized them.  Excluding

 these effects  obviously underestimates the maintenance benefits

 of reducing lead  in gasoline.
* DuPont (1982) has observed severe catalyst plugging due to
  lead in gasoline (0.5 grams/gallons); the implications of
  this are still under study.

-------
                              III.5




III.A.  Maintenance Savings in the All Unleaded Case


III.A.I.  Sources of Data


     In assessing the effects of lead on vehicle maintenance


requirements and the potential savings of switching to unleaded


gasoline, we evaluated nine studies and some independent ancillary


data.  Most of these studies were conducted in the late 1960s


and early mid-1970s (Cordera, 1965; Pahnke and Conte, 1969; Pahnke


and Bettoney, 1971; Gallopoulos, 1971; Gray and Azhari, 1972;


Wintringham et al., 1972; Pless, 1974; Gergel & Sheahan, 1976;


Hickling Partners, 1981).


     Concerning exhaust systems and spark plugs, we examined four
                                                           k

on-road vehicle studies involving nine samples of light-duty


vehicles in both commercial and personal use.  One oil company


has provided a theoretical calculation based on its experiences


with the effects of gasoline quality on vehicles (Pahnke and


Bettoney, 1971).  For this analysis, we also examined changes in


automobile manufacturers' recommendations for vehicle maintenance


periods and the reasons for the changes, and we quantified the


portion attributable strictly to a switch from leaded to unleaded


gasoline.  We have summarized the findings of these studies for


spark plug and exhaust systems  in Table Ill-l; we scaled the


reported rates to reflect equivalent mileages to facilitate the


comparison of results.


     There are fewer data concerning the effects of  lead in


gasoline on oil change intervals, and some discussion is only


qualitative.  In addition to drawing upon manufacturers' recommend-


ations, we used four sources of information.  One was research

-------
STUDY
                                        Table III.I
         SUMMARY OF STUDIES ON MAINTENANCE DIMERENCES BETWEEN LEADED AND
                        (Spark Plugs and Exhaust Systems)

        REPLACEMENT RATES
PER 11,000 MILES (OR PER 1 YEAR)


Pahnke & Conte
(DuPont, 1969)

Humble
(rpted. in Pahnke &
Bettoney, 1971)
Gray & Azhari (1972)
(Amoco)
MY 1967:
MY 1968:
Gray & Azhari (1972)
Amoco)


Wintringham, et.al.,
(Ethyl, 1972)

Detroit:
Baton Rouge:


Hickling Partners
Environment Canada)
( 1981)
Municipal Fleet



Changes in
Manufacturers
Recommendations



SPARK
UNLEADED
.534


.330


.373
.307
.247
PLUGS
LEADED
.726


.550


.840
1.085
.295
weighted avg.
1
1

.440
.347 |



1



.677
.519




2.9 times as many
w/leaded vehicles
1

1



1
2.2 more replace-
ments for leaded
vehicles,
net of
other technology
changes

EXHAUST SYSTEMS
UNLEADED
.0033


.220


.149 1
0
1
.004
LEADED
.187


.275


.535
.217
.071
weighted avg.
1
1

.155
.004 |

I

1
2.4 times
many for
vehicles



.289
.358




as
leaded
(they
exclude Toronto
fleet) |

(Not
Applicable)

1





AVG. MPV/YR
11,400


10,000


7,500
7,500
Not
reported




14,575
16,850




(Unknown)



(Not
Applicable)




ACCUMULATED
AVG. MVP
65,000


_ _


24,000
17,000
1 to 6 yrs.




72,883
84,260




23,810 leaded
24,990 unleaded



(Not
Applicable)




TYPE OF
SERVICE
Personal Use


Theoretical

Commuting and
business use


Personal Use
(Consumer
Panel)

Employee Fleet
(Business and
Personnel






Municipal
Service



(Not
Applicable)




1 OF VEHICLES
LENGTH OP TEST
59 matched pairs/
4.7 years




12 matched pairs/
2 and 3 years

151 matched
pairs/1-5 years




31 matched pairs
33 matched pairs/
5 years 	



835/5 years



(Not
Applicable)




LOCATION
South New Jersey
and Wilmington,
Delaware



Chicago and
suburbs

Eastern states
concentrated
in Mid-Atlantic

De t ro i t
Baton Rouge






Edmonton
Toronto



(Not
Applicable)




-------
                             III.7





conducted on four fleets of commercial vehicles under conditions



that strain oil performance (Pless, 1974).  Another study used



engine tests on a road simulator to compare the use of leaded



gasoline at standard oil change intervals with unleaded gasoline



at extended intervals (Gergel and Sheahan, 1976).  The third



source was a detailed analysis of the potential lengthening



of periods between oil changes by switching to unleaded gasoline



(Gallopoulos, 1971).  Finally, Cordera et al. (1965) related



engine rust build-up to lead concentration in gasoline.



     In addition, some studies found other categories in which



unleaded vehicles experienced lower maintenance expenses — notably



fewer carburetor adjustments (Gary and Azhari, 1971; Wintringham



et al., 1972) and fewer engine overhauls.  We did not include them,




however, for several reasons:  some of these effects may not be



related exclusively to differences between leaded and unleaded



gasoline, several studies used data bases which were too small to



provide meaningful conclusions, and some were not considered



reasonable to extrapolate to vehicles operating in 1988.





III.A.2.  General Comments on the Method



     In quantifying the consumer benefits of switching from leaded



to unleaded gasoline, we considered changes in the observed main-



tenance behavior of vehicle owners.  For matched pairs of vehicles



and drivers, changes in observed maintenance reflect, and are used



as a proxy for, underlying effects of gasoline quality on vehicle



performance and durability.  If most people maintain their vehicles



at manufacturers' recommended schedules, and would continue to do



so with a switch to unleaded gasoline, our method could overestimate

-------
                                III.8






 maintenance  benefits.   This  would also be  true  if  manufacturers'



 recommended  schedules  were based on  the performance  and  durability



 of  the worst cars,  rather than  average cars.   In this  case,



 scheduled  maintenance  may provide a  large  safety factor  relative



 to  the average  car,  and we may  have  overestimated  maintenance



 savings.



      On the  other hand,  manufacturers  may  develop  maintenance



 schedules  by balancing  the extra maintenance expenses  of  the



 average or better vehicles against the expected avoided  costs  of



 the more problem-prone  vehicles.   In this  case, our  evaluation



 of  changes in maintenance behavior probably does not overstate



 benefits.



      In any  case, the  evidence  — from the fleet studies  we cite



 here,  consumer  surveys,  and  conversations with auto  specialists



 —  indicates that,  in general,  people  substantially  under-maintain



 their  vehicles  relative  to recommendations.  (See, for example,



 the 1984 AAA Potomac Division survey that found most of  2,600



 cars  suffering  from maintenance  problems.)  In sum,  we expect



 that  observing  owners'  behavior  correctly reflects the intervals



 at which they begin to notice performance degradation.   (An



 exception  to this is exhaust systems,  which comprise half the



 estimated  savings, because people  repair these only  when  they



 fail.)





 III.A.3.   Fewer Replacements of  Exhaust Systems



     All of  the studies  found demonstrable differences in



expected lifetimes  (measured in miles)  of exhaust systems between



matched pairs of unleaded  and leaded vehicles.   The  range of

-------
                               III.9





estimated differences between leaded and unleaded replacement



rates, however, was very broad, from only 20% fewer muffler



changes (at equivalent mileage) for unleaded vehicles (but based



only on a theoretical calculation) to, more commonly, virtually



no replacements for unleaded vehicles in four of the nine distin-



guishable fleets.  Averaging the results of all these studies, we



found about one exhaust system replacement every 56,000 miles for



cars using lead fuel, and essentially none for vehicles using



unleaded fuel during the test periods.



     Unfortunately, however, these studies were conducted on



fleets of vehicles over several years, but for less than the



lifetimes of the vehicles.  It is possible, therefore, that



the studies ended shortly before many of the unleaded vehicles



required exhaust system replacements.  Perhaps the replacement



rates for unleaded vehicles would have increased significantly



had the fleets travelled another 10,000 to 20,000 miles.  The



reported findings, thus, may have overestimated the differences



between unleaded and leaded vehicles.



     It is useful to look most closely at the Ethyl Corporation



(Wintringham et al., 1972) findings, since their vehicles had the



greatest mileage, and there is a clear geographic distinction



between the fleets.  Their Baton Rouge fleet, after over 84,000



miles of travel per car (compared to a projected lifetime of



100,000 miles), had essentially zero exhaust system repairs  for



unleaded vehicles, but rates of about 1 per 31,000 miles for



leaded vehicles.  By comparison, the Ethyl Detroit fleet, after



about 73,000 miles of travel per vehicle, had a rate  for

-------
                                III.10






 unleaded  vehicles  of  one  exhaust  system  repair  per  46,000 miles,



 but  rates of  one per  24,000 miles for  leaded  vehicles.   The main



 reason  for the  different  experiences in  Baton Rouge and  Detroit,



 the  authors concluded, was the  greater external  corrosion due



 to road salts in the  colder climate.   This was  consistent with



 the  Environment Canada findings  (Hickling Partners, 1982) for two



 municipal  fleets,  which had 42% fewer  exhaust system replacements



 (at  equivalent mileage) for cars  using unleaded  fuel in  cold



 climates.



     On the other  hand, the DuPont  (Pahnke and Bettoney, 1971)



 and  Amoco  (Gray and Azhari, 1971) findings, conducted in the mid-



 Atlantic  region, Chicago, and in  the eastern  U.S., were  closer to



 Ethyl's in Baton Rouge: there were virtually  no exhaust  repairs for



 vehicles  using unleaded fuel.   (The average muffler replacement



 rates for  leaded cars among the different studies also varied



 greatly,  ranging from 1 per 20,500 miles to 1 per 154,900 miles.)



     Weighting Ethyl's findings for Detroit and Baton Rouge



 according  to the portion  of registered cars in Sunbelt versus



 Snowbelt  states in 1982 (43% and  57%,  respectively, according



 to MVMA,  1983), mufflers  nationally would last an average of



 three times longer on unleaded vehicles than  on leaded ones.



 However, because of our concern that these limited duration



 studies may have underestimated muffler replacements over the



 lives of vehicles using unleaded  fuel,  we conservatively concluded



 that mufflers on vehicles using unleaded fuel would last twice



as long (in miles)  as those on vehicles using leaded fuel.



Given the projected lifetime of a car  (100,000 miles),  this

-------
                             III.11


meant about two exhaust system changes per leaded vehicle versus

one per vehicle using unleaded.

   We assumed mufflers on vehicles using leaded gasoline would

last about 50,000 miles.  In the studies we reviewed, the leaded

fleets averaged about 40,000 to 60,000 miles between exhaust

system replacements.  Several automotive specialists independently

confirmed the reasonableness of this assumption.*

     We calculated exhaust system replacement savings as follows:

for leaded exhaust systems replaced once every 50,000 miles,**

each mile therefore accounts for .00002 of the system replacement;

for unleaded vehicles replaced once every 100,000 miles (doubled

exhaust lifetime), the system replacement figure is  ,00001/mile.

The difference is ,00001/mile.  At $120 per repair (muffler,

tailpipe, and exhaust pipe), this was 0.12 cents/mile, or 1.68
 * Passing references in literature and several reviewers of
   this document have suggested that the metallurgy of exhaust
   systems was upgraded during the 1970s, e.g., changing from
   cold-rolled milled steel to chromium stainless steel.  Since
   the more durable metal would corrode less easily, this design
   improvement might affect performance so that our estimates
   of benefits might be substantially overstated.  However, on
   the improved exhaust systems, only the parts from the exhaust
   manifold to the catalytic converter are stainless steel.
   The remaining components of the exhaust system (exhaust
   pipe, muffler, and tailpipe) are generally made of rolled
   steel.  These are the parts that we estimated would corrode
   from leaded gasoline.  Thus, this technology change should
   have no effect on our estimates of savings.

** It can be argued that effects due to fuel use are best deter-
   mined in terms of total gallons consumed rather than miles
   traveled.  For a majority of the studies examined in this
   paper, fuel consumption data was unavailable.  Thus, we used an
   assumed value of 14 miles per gallon.  To the extent that this
   value is higher or lower than the actual fuel economy of the
   vehicles in the studies used here, our estimates will vary
   accordingly.

-------
                              III.12


cents/gallon (at the average 14 miles per gallon achieved by

cars in the late 1960s).*  A savings of 1.68£ per gallon times

light-duty vehicle demand (22.8 billion gallons of leaded

gasoline in 1988) yielded exhaust system savings of $383

million for the all unleaded case (1983 dollars).


III.A.4.  Better Performance or Less Frequent Spark Plug Changes

     The second category of maintenance savings is better vehicle

performance by avoiding the fouling and corrosion of spark plugs

by lead deposits.  The fleet studies results were more consistent

in establishing spark plug effects than exhaust system effects.

     Eight fleets in four studies (Pahnke and Bettoney, 1971;  Gray

and Azhari, 1971; Wintringham et al., 1971;  and Hickling Partners,

1982) clearly showed that owners of vehicles using unleaded fuel

increased mileage intervals between spark plug changes by .35%  to
* Changing to savings per gallon,  then extrapolating to 1988 via
  changes in leaded gasoline demand,  automatically adjusts for
  changes in fuel economy and changes in miles per year among
  different cohorts of vehicles.   Vehicles traveling fewer miles
  would burn fewer gallons and,  hence, acquire fewer savings.
  Likewise, vehicles with better fuel economy would achieve lower
  savings than average.  It should be noted that our benefits
  estimation assumes that these  savings are a function of fuel
  use.   Given the current trend  towards more fuel efficient cars,
  such  an assumption may considerably underestimate actual bene-
  fits, as the age of the vehicle  becomes an important variable
  in determining the life of a muffler.  Implicit in our model
  is the assumption that an automobile that gets 28 mpg will need
  a new muffler every 200,000 miles,  or at 42 mpg,  300,000 miles.
  To the extent that these muffler lifetimes are overestimated,
  benefits are underestimated.  Unfortunately,  we were constrained
  by the lack of data concerning  the  effects of time on muffler
  life.

-------
                              III.13





300% over the intervals for leaded vehicles.  The average of the



studies was about a 60% increase in the distance traveled between



spark plug changes on unleaded versus leaded vehicles.  We used



this change in replacement to compute the savings of lowering



lead concentrations from the pre-phasedown level of 2.3 g/gal to



zero lead.



     By comparison, the Environment Canada/Hickling Partners



study (1982) found over a 50% increase in spark plug life for



unleaded cars in the municipal fleet studies.  They also found



almost a doubling of the intervals recommended by auto manufac-



turers for spark plug changes on unleaded vehicles compared to



leaded ones, a function of several technological improvements



(e.g., the addition of high energy ignition systems).



     However, some evidence suggested that the 1982 lead phase-



down ruleraaking, which lowered average lead concentrations to



1.1 grams per gallon, has already achieved a portion of this 60%



increase in spark plug life.  (Other data suggested that the same



is not true for exhaust systems and oil changes — lowering lead



to 1.1 g/gal may not have provided savings in these categories.



These are discussed in greater detail in section III.B of this



chapter.)  Therefore, we pro-rated the 60% savings according to



the portion left to be gained by further restrictions of lead.



     There are scant data on spark plug fouling at very low lead



levels.  In 1971, Toyota (Champion, 1971) reported finding that



fouling of spark plugs occurred at equivalent rates with unleaded



and low-lead gasoline of 0.20 g/gal (both maintaining ignition

-------
                               III.14


 performance  for  30,000 miles).  At  the  1972  Champion  Spark  Plug

 Conference,  Union Oil also  reported that  spark plug performance

 was similar  for  unleaded and low-lead gasoline of  0.5 g/gal.

 Both outlasted by over four times  the spark  plugs  operating with

 leaded fuel  of 3.0 g/gal.  These findings suggested that there

 was some threshold for gasoline lead content above which the

 lead in gasoline degraded spark plug performance.  For lack of

 other information, we assumed  that this threshold  was 0.5 g/gal,*

 and that the relationship between lead and spark plug fouling

 was linear from  this threshold to higher  lead levels.

     Earlier, we noted that intervals between spark plug changes

 could increase 60% by reducing lead from  2.3 g/gal to zero

 (0.0 g/gal.)  If the threshold by which all benefits have been

 achieved is  0.5 g/gal, then the 1982 lead phase-down rule (which

 lowered the  lead content of gasoline to 1.1 g/gal) would have

 resulted in  (2.3-1.1)/(2.3-0.5) times (60%), or an estimated

 40% increase in change intervals.   The remaining 20% gain would

 be attributable to phasing down from 1.1 g/gal to 0.5 g/gal (or

 also down to 0.0 g/gal).   We used this 20% rate of savings to

 calculate the benefits of fewer spark plug changes.

     We assumed that drivers of vehicles using leaded gasoline

 began to experience significant performance degradation by about
* The Toyota and Union Oil results could have been averaged for
  a threshold of 0.35 g/gal.  Use of a lower threshold will
  result in benefits of 23% increased spark plug life in phasing
  down from 1.1 to 0.35 g/gal (Champion, 1971, 1972).

-------
                              III.15


12,000 miles of spark plug life.  This was a little longer than

automobile manufacturers' recommendations would imply, but some-

what less than the actual change intervals for leaded vehicles

observed in most of the fleet studies.  The observed intervals

averaged about every 15,000 to 16,000 miles (but ranged from

10,000 to 37,000 miles for leaded vehicles).

     A 20% increase in spark plug life accompanying a switch to

unleaded gasoline would provide savings of about 0.35 cents/

gallon* of gasoline.  This, multiplied by the projected 22.8

billion gallons of demand for leaded gasoline in 1988 in the

base case, translated to savings from fewer spark plug changes

of about $80 million under an all unleaded policy.

     Interestingly, the effects appeared smaller than the

researchers had hypothesized.  Apparently, owners tuned up their

vehicles and changed the spark plugs more as a function of

mileage (and habit) than performance.  Using the difference in

observed behavior between paired drivers of leaded and unleaded

vehicles, as these studies did, may underes.timate the performance

degradation of leaded gasoline on spark plugs and engine timing.
* Calculation:  A 20% increase in the 12,000 miles between
  spark plug change experienced in cars using leaded gasoline
  translates to 14,400 miles between changes.  The difference
  in the number of changes per mile is therefore 1/14,400 -
  1/12,000 or .000014/ mile.  Given a price of $18 per spark
  plug change, this becomes .025jzf/mile, or ,35/ef/gallon (at
  14 miles per gallon).

-------
                               III.16


 In  fact, using the data  from MVMA  (1984) reveals an estimate of

 $328 million* — over  four  times the value derived in  our

 analysis.


 III.A.5.  Extended Oil Change  Intervals

     The combustion products that deposit on engine surfaces

 cause corrosion and rusting.   Engine oil accumulates much of the

 debris from this corrosion, as well as some portion of the gaso-

 line lead.  According to at least one estimate, up to  10% of the

 lead in gasoline ends up in the used oil, comprising up to 50%

 of the weight of engine oil sludge (Gallopoulos, 1971).

     The particles that accumulate in the used oil cause sub-

 stantial abrasive wear in the engine, while the internal engine

 rust may cause hydraulic valve lifter sticking (Cordera et al.,

 1965).  Besides the long-term engine wear that reduces the dura-

 bility of the engine, the vehicle driver may also experience

 excessive valve noise and other performance degradation due to

 this premature contamination of oil.   While rusting can occur

 even in the absence of the halogen acids derived from lead salts,

 engine oil tends to be the major cause of internal rusting under

 normal driving conditions.
* MVMA estimated spark plug changes to occur every 30,000 miles
  for vehicles using unleaded gasoline, compared with every
  15,000 miles for those using leaded gasoline.  This yields
  1/15,000 - 1/30,000 = .000033 spark plug changes/mile
  difference.  At $18 per plug change this is .06/d/mile or
  1.44^/gallon using the MVMA's figure of 24 miles per gallon.
  Given an estimate of 22.8 billion gallons of leaded fuel in
  1988, total benefits are just over $328 million.

-------
                              III.17





     The fleet studies investigating differences in maintenance



costs between unleaded and leaded vehicles tended either not to



consider effects on engine oil, or found very small savings.  In



general, these studies were not conducted in a manner to deter-



mine easily the effects on oil change intervals or engine wear



from using leaded or unleaded gasoline.   Possibly consumers were



not aware of the potential decrease in oil change requirements



when using unleaded gasoline, and/or did not tend to change their



habitual maintenance behavior.  Therefore, this analysis relies



more heavily on experimental studies of engine wear with unleaded



and leaded gasolines at varying oil change intervals than the



fleet studies.  The exception is Pless (1974) which was a fleet



study specifically designed to examine oil change effects.  Even



if consumers did not realize the possible short-term cost savings



of fewer oil changes, they would have benefited from better



engine durability with unleaded gasoline.  Since most evidence



indicates that vehicle owners do not change oil often enough,



this would be especially true.



     Many of the experimental studies in the early 1970s on oil



change requirements did not provide conclusive evidence on oil



quality after extended intervals between changes.  The results



consistently did show that unleaded gasoline decreased rusting,



corrosion, and sludge; low temperature piston varnish tended  to



increase, however.  No significant  difference was  found  for oil



thickening, high temperature  varnish, or adhesive  wear or



scuffing.  It was  not clear whether, overall, unleaded fuel



would allow substantially longer  intervals  between oil changes.

-------
                               III.18






 In  any  case,  manufacturers  have  changed  their  specifications  for



 oil  changes  from every  3-5,000 miles  to  every  7-10,000  miles.



      A  study  by  Gallopoulos,  of  the General  Motors  Corporation



 (GM), was  one of the  earliest works that we  examined.   He



 concluded  in  1971  that  with unleaded  gasoline  it might  be  feasible



 to extend  requirements  from two  to three yearly changes to only



 one  annual oil change,  but  added  that more investigation was  needed



      Pless, also of GM,  reported  more conclusive results in 1974



 from experiments on taxicabs  in conditions that take an unusually



 severe  toll on oil quality.   In a group  of twenty taxis (1970



 model year),  Pless found less piston  varnish,  ring  wear, and



 used-oil insolubles for  the unleaded  vehicles  after 16,000 miles



 of stop-and-go service.  However, the unleaded vehicles experi-



 enced more oil filter plugging and higher used-oil  viscosity.



 On a fleet of 1971 taxis, he  found that  doubling oil change



 intervals with unleaded gasoline  (from 8,000 miles  to 16,000



 miles)  significantly increased oil filter plugging  and  used-oil



 insolubles.



     On a fleet  of 1972 taxis, Pless  compared unleaded  vehicles



 after 16,000 miles without  an oil change with leaded vehicles



 (2.7 grams of lead per gallon) after  8,000 miles.   The  results



 indicated less sludge, oil  ring deposits, compression ring wear,



 cam  and lifter wear, and oil degradation for the unleaded vehicles



with extended oil change intervals, compared to the leaded taxis



with "normal" oil changes.  While the unleaded vehicles had some-



what greater plugging of oil filters,  Pless concluded that this

-------
                            III.19


was not a significant finding.  Finally, another fleet traveling

predominantly short trips (closer to "typical" consumer driving

patterns) led Pless to conclude:


        A combination of unleaded gasoline and doubled
        oil change interval allowed significantly less
        ring wear, and directionally less sludge,
        varnish, and cam and lifter wear than did the
        combination of leaded gasoline and 'standard'
        oil-change interval.


He qualified this conclusion by stating that only unleaded

gasoline and SE or better quality oils be used.  (Currently, SF

oils, which are better than SE, are the most widely used.)

Subsequent to these findings, both GM and Chrysler recommended

lengthened periods between oil changes.  Both companies now only

manufacture cars built to run on unleaded fuel.

     In 1976, Gergel and Sheahan (Lubrizol Corp.) found results

similar to those of Pless, but found no significant plugging of

oil filters.  Importantly, they concluded that engine wear was

the limiting factor in extending oil change intervals suggesting

a maximum of 12,000 miles between changes for leaded gasoline

engines.

     The evidence indicates that there  is a relationship between

lead additives and oil change interval, shown through reduction

in engine and engine parts wear (either through reduction in

abrasive lead particles or rust), oil degradation, and general

engine and engine part cleanliness  (e.g., lack of deposits and

sludge).  For analytical purposes, we need to determine the

-------
                              III.20






 functional  relationship  between  lead  in  gasoline  and  oil  change



 intervals.   The  available  direct evidence  is  from Pless who tested



 engine  oil  change  intervals  on unleaded  gasoline  and  2.70 grams/



 gallon  leaded  gasoline.  However,  the existing  lead phase-down



 regulation  limits  the  lead content to 1.1  grams/gal.   Given this



 data, the issue  is whether some  of the benefits of reduced oil



 change  intervals already occurred  in  going to 1.1  grams/gal,  and



 how much remains to be obtained  in decreasing from 1.1 grams/gal



 to 0.1  or 0  grams/gal.



     Gallapoulous,  in  discussing future  engine oil requirements



 for unleaded vehicles, noted a number of studies  which examined



 lead or lead scavenger use in relation to  engine  or engine part



 rusting.  He concluded that  the  use of unleaded gasoline  would



 result  in less internal  rusting.   The inference was that  with



 less sludge, oil degradation, and  deposit  build-up, the overall



 task of engine oils is reduced.  As a result, a switch to unleaded



 gasoline would produce a net increase  in engine oil lifetime.



     With this engineering data  in mind, we examined  the  studies



 relating lead additives or lead  scavengers to engine  rust.  While



 it may be argued that most of these studies were designed  to



 identify lead scavenger effects, it is also true that  such  scav-



engers would not be used in the  absence of lead in gasoline.



Furthermore, a substantial portion of  the  corrosive elements  in



the engine are acids derived from the  lead halide  salts,  a  product



of both lead and its scavengers.  In  fact, all of  the  studies



looked at various  lead concentrations  as well as lead  scavenger



concentrations.

-------
                              III.21





     One notable study (Cordera et al., 1965)  examined the



relationship betweeen engine rust and lead-scavenger concentra-



tions, while varying lead content.  Cordera et al. showed that



in addition to a relationship between lead-scavenger concentra-



tion and degree of internal rust, there also was a relationship



between lead concentration and rust.  These authors evaluated



valve lifter rusting at 0, 0.53, and 3.2 grams of lead per gallon



of gasoline.  The level of rust decreased non-linearly with



decreasing lead content.  An examination of the data indicated



that in going from roughly 2.3 grams (pre-phasedown) to 1.1



grams there was a 12.7% improvement.  From 1.1 to 0.1 g/gal



there was an additional 58.3% less rust, and from 0.1 to 0 there



was an additional 29% improvement.  Thus, going from a current



gasoline lead level of 1.1 grams to 0.1 grams would yield 58.3%



of the benefits of eliminating lead and scavengers, whereas



going from 1.1 to 0 gives 87.3%.



     The preponderance of evidence indicated that using unleaded



gasoline decreases oil contamination, engine wear and rust, even



with a doubled oil change interval.  We believe a decrease from



2.3 grams/gallon to zero would yield dollar savings at least as



great as those which would accrue by the doubling of oil change



periods.  (Vehicle manufacturers recommended such a doubling for



their vehicles concurrently with the switch to unleaded gasoline.)



It is important to note that even if owners did not change main-



tenance behavior, i.e., if they continued with their prior oil

-------
                               III.22
 change intervals, they would still achieve longer engine dura-

 bility from the greatly preserved oil quality when using only

 unleaded gasoline, and therefore achieve long run savings.

      Manufacturers'  specifications have changed from one oil

 change roughly every 3,000 to 5,000 miles, to about one every

 7,000 to 10,000 miles.   This translated to about one or two —

 instead of  two or three — oil changes  per year.   We assumed an

 oil  change  required  4  quarts of oil at  $1.50  each,  that oil

 filters ($4  each)  would be replaced every  other oil change  (so

 $2/change)  and we  assumed  15 minutes of labor.   (We valued  that

 labor at  an  hourly wage rate of $10.00,  the average for manufac-

 turing.)  This calculation was for  a "typical"  owner changing

 his/her own  vehicle's oil  and  would  be  substantially less than

 the  prices people  generally  pay  at  service stations.  This

 yielded $10.50  per avoidable oil change, or savings  of  about

 1.47  cents per  gallon of gasoline.*  In  1988, this  produced

 additional savings of $332 million  for the all  unleaded case.

 But note, in the study by Cordera et al. we found that  only

 87.3% of these benefits were achieved in going  from  1.1 to 0

grams of lead per gallon.  Thus, we have lowered this value by
* For vehicles using leaded gas, one oil change every 5,000
  miles was assumed versus one every 10,000 miles for the
  vehicles using unleaded gas.  Therefore, 1 change/5,000
  miles minus 1 change/10,000 = .001/ mile.  At $10.50 per
  oil change and an average fuel economy of 14 miles per
  gallon,  1.47 cents/ gallon is the average savings,  with
  22.8 billion gallons projected consumption in 1988, the
  value is $332 million.

-------
                              III.23


12.7% for a savings of $292 million.  Again,  this is less than

the value of $542 million predicted from using the MVMA analysis.*


III.A.6.  Improved Fuel Economy

     There are three reasons why drivers could expect to get

better fuel economy by switching from leaded to unleaded

gasoline:


     0  Unleaded gasoline has more energy content per
        gallon.  These small per-gallon savings would
        accrue to any consumer of unleaded, rather than
        leaded gasoline (Exxon, 1978).

     0  Lead fouls spark plugs, which hurts fuel economy.
        The benefits of avoiding this would be counted
        mostly by our spark plug estimate.

     0  For vehicles built after 1980, misfueling with
        leaded gas affects oxygen sensors, which can
        adversely affect fuel metering.


Energy Content

     An analysis by Exxon  (1978) on the energy content of

different kinds of gasoline showed that vehicles using unleaded

gasoline should get better mileage because unleaded gasoline

contains more aromatic compounds and  is "denser"  (i.e., has higher

energy content per unit volume) than  leaded gasoline.  Also,

engines that run on unleaded gasoline build up more deposits  in
*  The MVMA assumed unleaded gasoline vehicles require an oil
   change every 7,500 miles versus 5,000 miles for leaded gas
   users.  The difference is, therefore,  .00007 change/mile.
   Using MVMA estimates of $15/oil change and an average of 24
   miles per gallon, this produced a value of 2.4 cents/ gallon,
   or $547 million in 1988.

-------
                               III.24


 the  combustion  chambers  which tend  to increase the compression

 ratio,  thereby  improving engine efficiency slightly.   For these

 reasons,  vehicles  burning unleaded  gasoline should be slightly

 more fuel efficient.   The Exxon memo calculated that  improved

 fuel economy  might be  about  1 to 1.5%.   Using  a Society of

 Automotive Engineers  formula (SAE #Jl082b)  to  adjust  miles per

 gallon  for differences in gasoline  density,  and using the Exxon

 density estimates,  we  computed about 0.8%  fuel economy improve-

 ments from using regular unleaded gasoline.  This  produced savings

 of about  $199 million  in 1988.*

     We are not sure what the difference  in  density may be between

 future grades of leaded  and  unleaded  gasoline.   Because of this

 uncertainty we did  not include this  savings  in our tabulation

 of benefits.

 Spark Plug Fouling

     Spark plug fouling  caused by leaded gasoline  also reduces

 fuel economy.   This loss  necessarily  occurs  in  the interim

 between spark plug  cleanings  and  changes, not  just if  maintenance

 does not occur.   High energy  ignitions, used in most  vehicles by

 the mid-1970s, help extend spark  plug life by maintaining  reli-

 ability and may have some  impact  on delaying fouling and  adverse

 fuel economy impacts.   We probably have included much  of  this fuel

economy saving in the previous section on spark plug savings, so
* $199 million = 22.8 billion gallons of light-duty vehicle
  demand for leaded gasoline in 1988 times $1.10 per gallon
  times 0.8% fuel economy improvement.

-------
                              III.25


we did not include it again here.  But as a check on our previous

estimate of spark plug savings, we calculated the fuel economy

loss if spark plugs were not changed frequently enough.  The

fuel economy penalty of extra spark plug fouling would have to

be only 0.32%* to be comparable to the estimated spark plug

savings of $79 million in Section III.A.4.

Oxygen Sensor Fouling

     For some misfueled vehicles, lead deposits can also

affect oxygen sensors causing engines to run richer and thereby

reducing fuel economy.  How much  this occurs depends on the types of

feedback and failure modes of specific electronic controls, as

well as how particular oxygen sensors react to the  introduction

of lead.

     One EPA official  in the Office of Mobile Sources  has

estimated  the impact of these factors on gasoline consumption.

Arbitrarily taking a low estimate in  the range presented — a  3%

loss** —  we estimated roughly what preserving fuel economy might

be worth for would-be misfuelers  in 1988.  The 3% loss times 10.3
  * Given  retail gasoline prices of  $1.10, our estimate  of
   $79 million from  spark plug savings  is equivalent
   to 71.8 million gallons  of gasoline.  This, divided  by
   the 22.8  billion  gallons of light-duty vehicle  demand
   for leaded gasoline,  is  equivalent to a  .32%  increase
   in fuel consumption.

 ** Four Canadian  studies have estimated that  fuel  economy
   may be up to 4% greater  for vehicles using unleaded
   gasoline. However,  the  applicability of these  findings
   to the U.S. situations is questionable,  so we did  not
   use them  in this  analysis.

-------
                              III.26





billion gallons of misfuelers1 demand, times $1.10 per gallon,



equals $339 million  in  1988.  Currently, we have  insufficient



data to estimate this more precisely, or to include  it in our



tabulation of benefits.





III.B.  Maintenance  Savings for the Low-Lead Case



     The previous sections estimated the maintenance benefits



likely to result from an all unleaded policy.  If leaded gasoline



were unavailable, however, some vehicles might experience excess



valve wear.  This risk suggested  that we evaluate an option lower-



ing the concentration of lead in  gasoline to a level that still



would be sufficient  to protect against valve recession.  (Valve



recession and alternatives to prevent it are discussed in the



next section of this chapter.)



     This section examines the relationship between lead



concentrations and maintenance benefits at high, low, and no lead



levels.   We then discuss the savings likely from a low-lead case



allowing 0.10 grams of lead per gallon of gasoline.   To estimate



these benefits we had to assess the shape of the effects function



in order to interpolate between the relatively high lead levels



at which most research has been conducted (about 2.3 to 3.0 g/gal)



and zero lead.  With that information, we calculated the portion



of the "all unleaded option" savings that would be achieved by



the low-lead option.



     Data with which to interpolate the relationships, and thus,



to estimate savings,  were scant.   We are confident that current



lead concentrations of 1.1 g/gal are above the threshold where

-------
                            III.27





Towering lead levels would result in savings related to exhaust



systems or oil changes.   However, it is likely that the 1982



lead phase-down regulations may have already achieved some of



the potential spark plug savings of going from 2.3 g/gal to 0



lead.





III.B.I.  Exhaust System Savings



     Most of the studies we evaluated to estimate maintenance



savings involved fleets of vehicles, half of which used commer-



cially available leaded gasoline.  In the late 1960s, when



these studies were conducted, the weighted average lead content



of gasoline  (weighted by the portions of premium and regular



grades) was  about 2.3 grams of lead per gallon.  Unfortunately,



because the  discussion at the time focussed on relatively high



lead levels  versus "zero" lead, there are extremely few data



with which to define the relationship between low lead concen-



trations and exhaust system corrosion between 2.3 and 0 g/gal.



     Gray and Azhari (1971) was the only study that examined



exhaust system corrosion rates at lead levels as low as 0.5 g/gal,



They found no difference between  corrosion rates at 2.3 g/gal  and



0.5 g/gal, with corrosion rates at both lead levels 10-20 times



higher  than  those of vehicles using unleaded gasoline.  This



suggested that there was some threshold at or below 0.5 g/gal,



below which  lead levels must fall before any savings may  be



achieved by  fewer muffler replacements.  It also suggested  that



no  savings were achieved from previous "lead phase-downs",  since

-------
                              III.28


 the  current  lead  concentration  is  1.1  g/gal  —  well  over  Gray  and

 Azhari's  upper  bound  threshold  of  0.5  g/gal.  With no  information

 to the  contrary,  we assumed  that  the relationship between lead

 levels  and exhaust corrosion was  linear below this threshold.

     To calculate the exhaust system savings at  0.1  g/gal, we

 distinguished between two  categories of would-be users of leaded

 gasoline:  misfuelers and  those vehicles designed to use  leaded

 gasoline.  Because of the  likely changes in price differentials,

 marketing strategies, and  possible administrative controls on

 the  distribution  of leaded gasoline, we assumed  that there would

 be no misfueling  under the 0.1 g/gal low-lead case.  For  consumers

 who  previously  had misfueled, the  savings would be the same under

 both the  low-lead and no lead cases: 1.68 cents/gallon savings,

 or $173 million in 1988.*

     For  light-duty vehicles  designed  to use leaded  gasoline,

 savings in the  low-lead case  would be  (.5-.I)/.5 or  80% of the

 all unleaded savings for fewer exhaust system replacements.

 This would equal 1.34 cents/gallon, or $168 million  in 1988.**

Adding  this to  the savings for misfuelers,  we estimated the

exhaust system replacement savings under the low-lead option

would be $341 million in 1988.
 * $173 million = 1.68 ff/gal times 10.3 billion gallons of
   misfuelers1  demand in 1988.

** $168 million = 1.34 /d/gal times 12.5 billion gallons of
   legal (non-misfueling) light-duty vehicle demand for
   leaded gasoline.

-------
                            III.29

III.B.2.  Spark Plug Savings

     As with exhaust system corrosion, we had little information

about the form of the relationship between low lead concentrations

and spark plug fouling.  As we discussed in section III.A.4 of

this chapter, two citations indicated that all spark plug savings

are likely to be achieved by lowering lead concentrations to 0.5

g/gal (from the studies'  beginning point of 2.3 g/gal).  For the

purposes of this analysis, further savings would be gained from

less spark plug foulings  by going from current levels of 1.1 g/gal

only to 0.5 g/gal; no further savings would be achieved by reduc-

ing from 0.5 g/gal to zero lead.*  Thus, given the state of our

current knowledge, total  savings would be identical for misfuelers

and other leaded light-duty vehicles in both options under con-

sideration.  (But the uncertainty surrounding the correct threshold

for additional engine fouling is substantial, and affected our

estimates for both the low-lead and all unleaded cases.)  As

earlier, we estimated that spark plugs would last 20% longer

under either policy, resulting in .35 cents/gallon savings, or

about $79 million for both the low-lead and all unleaded cases

in 1988.
* As previously noted in section III.A.4 the threshold could
  be an average of the two available studies (Toyota and
  Union Oil), in which case the threshold would be 0.35
  g/gal with 23% of the savings available in going from
  1.1 to  .35 g/gal versus the 20% value used in going from
  1.1 to  0.5 g/gal.  We have thus understated benefits by
  using a higher threshold.

-------
                               III.30


 III.B.3.   Oil  Change  Savings

      Our  discussion of  the  savings  to be  achieved  from fewer

 required  oil changes  was made  in  Section  III.A.5.   Principally,

 we  relied on the  work of Pless who  found  decreased engine  wear

 with  unleaded  gasoline  and  doubled  oil  change  intervals  compared

 with  engines using gasoline containing  2.70 grams  of  lead  per

 gallon and a standard oil change  interval.  We  also relied  on

 Gallopoulos and Cordera, who described  the relationship  between

 engine rust and lead  additive  variations.  To  interpolate  oil

 change savings to our low-lead case of  0.1 g/gal,  we  used  the

 same  methodology  as in  the  no  lead case.  In going from  1.1 to

 0.1 grams of lead per gallon 58.3% of the benefits are achieved.

 For legal  leaded  gasoline users this becomes a savings of

 $107  million.  Since  we assume  that no  misfueling  would  occur

 under the  low-lead option,  the  savings  achieved by misfuelers

 under this option is  the same  as  the all unleaded  option or,

 $132 million.  Total  savings is the savings for the legal leaded

 gasoline  user plus the misfuelers1 savings, $239 million.*


 III.B.4   Sum of Maintenance Savings for the Low-Lead Case

     As calculated in the previous three sections,  we estimated

 $339 million savings from decreased exhaust system  replacements,

$79 million savings for less spark plug fouling, and $200 million

savings with fewer required oil changes.  In total, lowering lead
* Calculation:  Legal leaded users:  1.47^/gallon times, .583 =
  ,857^/gal savings.  Thus, .857£/gal times 12.49 billion
  gallons of legal leaded use equals $107 million.  Misfuelers:
  1.47^/gal times .873 = 1.283^/gal.  Thus, 1.283jzf/gal times
  10.29 billion gallons equals $132 million.

-------
                             III.31

concentrations to 0.1 g/gal would  yield about $618 million in
vehicle maintenance benefits.

III.C.  Risk of Valve Recession
     Balancing these savings is the fact that reducing the amount
of lead in gasoline may increase wear on some engines requiring
the lubrication that lead compounds now provide.  In particular,
some studies argued that severe exhaust valve recession could
occur, resulting in leaking valves, loss of compression pressure,
greatly increased hydrocarbon emissions, degraded vehicle perfor-
mance, and reduced fuel economy.  Reviewing the available data,
it appeared that eliminating leaded gasoline could mean exhaust
valve recession in some light-duty vehicles and other engines
that were originally designed to run on leaded gasoline.
     The following paragraphs describe:
     0  the process of valve recession,
     0  the conditions under which it  is likely to occur,
     0  the concentration of lead in gasoline needed to
        prevent damage, and
     0  alternative mechanisms that might provide
        sufficient protection.
We also estimated  the types  and numbers of engines that might
be at risk without leaded gasoline.
     Exhaust  valve recession appeared  to result from  both
abrasion and  adhesion on the valve seat when engines  operated
under high  temperatures, loads, or engine  speeds.   (For detailed
discussions of  the mechanisms of valve wear, see  Godfrey  and
Courtney, 1971; Giles,  1971; or Kent and Finnegan,  1971.)

-------
                              III.32





     Several researchers have examined rates of valve recession



as a function of engine operating variables and the amount of lead



in the fuel.  Giles, and Godfrey and Courtney were consistent in



finding that recession rates appeared to be mostly a function of



engine speeds.  Giles, for example, found that valve recession



increased almost linearly with higher engine speeds to a point



(on the engine he tested, about 3700 rpm), and then rose as an



exponential function of engine speed.  The shape of this function



apparently varied significantly by vehicle models and years.



     We reviewed two types of research about the causes and rates



of valve recession.  The first type of study was engine tests on



dynamometers, done either using unusually high engine loads to



test valve durability, or using cycles that simulated typical



driving patterns, or a combination of the two.  The second type



of study involved on-road vehicle tests, ranging from high-load



studies to surveys of consumers'  experiences.   An advantage of



engine tests was their greater measurement precision and control



over test conditions.  The vehicle studies, on the other hand,



may have been more likely to reflect "real world" effects.



      Table III-2 summarizes the available studies of valve



recession as a function of lead concentrations.   It should be



noted that most engine studies of valve recession were conducted



at speeds and loads much greater than normal driving patterns.



For example, Giles and Updike (1971), of TRWs Valve Division,



conducted six dynamometer tests simulating vehicle speeds from



50 to 100 mph.  These tests, combined with the two described



later, led them to conclude that:

-------
                              III.33


     exhaust valve recession in engine I accelerates rapidly
     above 70 mph....  The data shown here also indicate that
     the average driver,  who seldom exceeds 70 mph,  should not
     experience significant engine deterioration while using
     lead-free gasoline.   The salesman, however, who drives
     15,000 turnpike miles per year at 80 mph, may well expect
     valve train problems.  (p. 2369)

Their data showed the rate of valve-lash loss actually decreased

slightly between 50 and 70 mph (wide open throttle at 2000 and

2800 rpm, respectively).   Felt and Kerley (1971), of Ethyl

Corporation, also found that valve recession (using unleaded

gasoline) was about two-thirds lower for a vehicle traveling at

60 mph than vehicles traveling at 70 mph, despite going 22% to

280% more miles.  The following conditions were used in engine

studies finding serious valve wear with unleaded gasoline:

     0  Giles (1971) conducted tests with passenger car engines
        under varied conditions from steady-state wide-open
        throttle (WOT) to simulated road-load cycles.  He found
        that the valve recession rates were about ten times
        higher without lead than with 2 to 3 grams of lead per
        gallon of gasoline.  But since he does not report the
        magnitudes of recession, it was impossible to tell how
        serious the recession was under the various conditions.
        (Valve recession occurred at a slight rate even with
        lead additives.)

     0  Giles and Updike (1971) ran one engine for 50 hours at
        a steady-rate of 3500 rpm WOT (speed selected to maxi-
        mize valve recession rates while minimizing the other
        engine durability problems of other components at higher
        engine speeds); another engine ran for 50 hours at 2600
        rpm WOT.  Finding: about three times the rate of reces-
        sion with unleaded gasoline vs. leaded.

     0  Kent and Finnegan  (1971) also found severe valve reces-
        sion in tests simulating a 1970 V-8 pick-up truck
        hauling a camper at freeway speeds of approximately
        65-70 mph, with some engine cycling,  for a total
        running time of 80 hours.  In contrast, they found very
        low exhaust valve wear when running engines at  2300 and
        2400 rpm.

-------
                              III.34



      0   Godfrey  and  Courtney (1971) found  somewhat lower rates
         of  recession than did  other high  load  engine  studies
         when  they  tested  an  engine  at  4400 rpm WOT for 10 1/4
         hours.   They also found  recessions of  unreported magni-
         tudes on six other engines  running 9,000  to 11,000 miles
         at  70 mph  under conditions  designed to generate artifi-
         cially high  temperatures.

      0   Felt  and Kerley (1971) used both dynamometer  and road
         tests, mostly testing  at 70 mph freeway schedules,  and
         some  on  a  cycled  route of combined city and freeway
         driving.   They found 2/3 less  valve wear  at 60 mph than
         at  70 mph.

      0   Pahnke and Bettoney  (1971)  found serious  valve reces-
         sion  in  three unleaded dynamometer tests  after the
         equivalent of 8,000  miles at a steady  speed of 70 mph.

All  these studies were designed either to  investigate  the mech-

anisms causing exhaust valve seat recession, or to show the

importance  of leaded  fuel  combustion products  in  reducing valve

wear.  They did  not  usually  test for the likelihood of valve

recession under  normal driving conditions.

     Overall, it seemed that using  unleaded  gasoline exclusively

in vehicles requiring  lead's lubrication may risk  premature valve

failure  under severe  engine  loads.   These  studies  indicated that

such severe recession  is most likely to occur  in vehicles  travel-

ing at high loads or  speeds  well above the  legal speed  limit of

55 mph for extended periods  of time  (tens or hundreds  of  hours,

or for thousands of miles).  Several related studies using  fleets

of drivers under more  typical conditions found  little  or  no

incidence of valve problems with unleaded gasoline  (Pahnke  and

Conte, 1969; Orrin et al., 1972;  Gray and Azhari,   1971).  Two

studies cited more valve problems for unleaded  than for  leaded

vehicles (Wintringham et al., 1971;   Felt and Kerley, 1971).

-------
                                                          III.35
                                                       TABLE  III-2
                               SUWARY OF FINDINGS;   VALVE RECESSION AT VARIED LEAD CCJNCENTRATICJNS
         Paper

  Pahnke  6 Conte,  1969


 Gray &  Azhari, 1971


 Pless,  1974


 Orrin et al., 1972

 Giles, 1971

 Giles 6 Updike, 1971


 Doelling,  1971


 Kent &  Finnegan,  1971

 Panhke & Bettoney,  1971
Fuchs,  1971

Felt & Kerley, 1971




Godfrey & Courtney, 1971


       ot al., 1971
Wintringham et al., 1972
    Test Type

 Employee fleet.
 Personal use

 a. Employee fleet
 b. Consumer survey

 Taxi fleets
 Taxi fleets

 Varied engine loads

 Varied high loads


 Engine tests


 High load

 a. Consumer survey


 b. High load, enginge
   tests

 Engine tests

 a. Employee fleet

b. High load & cycled


High load engine tests
a. Patrol fleet, very
   severe service

b. 50K mile road test
   (.008 g/gal)
Employee fleets
 g Pb/gal

 2.8,0.1,0
 2.3,0
 2.3,0

     0
 2.8,0

 2.5,<0.03

     0


 0.14,0.07,
 0.04,0

 3.0,0.5,0.2,0

 2.3,0


 0.5,0


 0.5,0

 0.5,0

    0
3.1,0


2.6,0



2.3,0
               Findings

 No extra valve problems with unleaded
 a.
 b.
 No severe valve problems, but some valve
 stem wear in one fleet with unleaded

 No extra valve problems with unleaded

 Need more than 0.03 g/gal

 Recession rate inc. above 70 mph.
 Avg. driving should not pose problem.

 Between 0.04 and 0.07g/gal is adequate


 0.20 g/gal is adequate

 a. No clear difference,  but somewhat
   more valve problems  with unleaded

 b. Severe  recession after  8000 miles
   an unleaded;  none at  0.5 g/gal.

 0.5 g/gal  virtually eliminates recession

 a. More valve  problems with unleaded

 b. Recession rates  accelerate with
   high speeds 0.5 g/gal is  adequate

High loads and speeds are
major causes of recession

 a. Recession after  10-15K miles or
   more in severe service

 b. In matched pairs direct tonally
   less tip wear on unleaded; severe
   recession in one unmatched engine

More expensive valve problems with unleaded

-------
                              III.36






 Other  fleet  studies  were  inconclusive  concerning  the  relative



 incidence  of  valve problems  for  unleaded  vehicles  (Pahnke  and



 Bettoney,  1971; Grouse et al., 1971; Pless,  1974).  Finally,




 reported incidents of valve  problems were  rare  among  users of



 unleaded gasoline in the  late 1960s (Wintringham et al., 1972).



     The evidence indicated  that conditioning a vehicle on leaded



 gasoline helped to prevent valve recession during  subsequent use



 of unleaded gasoline for a limited time, but did not  lower the



 longer-term risk.  Giles  (1971) measured valve wear during and



 after  "break-in" periods of  an engine  running on leaded gasoline.



 He demonstrated that recession rates were high initially,  even



 using  leaded gasoline.  But, as the leaded gasoline combustion



 products built up on the valve seat, recession rates dropped to



 very low levels (from 0.001  inch per hour  (iph) initially,



 stabilizing at less than 0.0001 iph after 25 hours).  Giles then



 showed that, after switching the engine to unleaded gasoline,



 recession rates continued to be low until the lead deposits wore



 away (after about 10 hours).  Recession then rose again to high



 rates.  In sum, it may take  10-25 hours for lead deposits  to



build up sufficiently to mitigate valve wear; if leaded fuel is



not used, these deposits will wear off in several hours (about



10), leaving the exhaust valve vulnerable again to wear.





III.C.I.  How Much Lead is Required to Protect Valves



     A critical question is:  "How much lead or similar additive



in gasoline is necessary to protect against severe valve reces-



sion?"  Most studies were performed with the high lead concen-

-------
                              III.37





trations in gasoline that were common in the late 1960s — about



2.3 grams of lead per gallon of gasoline.   Also present in that



gasoline are traces of sulfur, which occurs naturally in petroleum,



and small quantities of phosphorus, which is added with lead to



modify the deposits in the cylinder.



     Several studies concluded that 0.5 grams of lead per gallon



of gasoline was a sufficient concentration to protect against



valve recession (Kent and Finnegan, 1971;  Pahnke and Bettoney,



1971; Felt and Kerley, 1971; Fuchs, 1971).  Kent and Finnegan



found that "as little as 0.2 g/gal of lead was sufficient to



reduce wear to substantially zero."



     Only one study examined valve wear at very low lead



concentrations to discover how little lead was necessary to



eliminate valve recession.  Doelling (1971) conducted tests at



2650 rpm at lead levels of 0.04, 0.07, and 0.14 g/gal, for 100



hours each.  Focusing on maximum recession of any of the valves,



Doelling found no recession at 0.07 or 0.14 g/gal, but found



excess wear at 0.04 g/gal.  He thus concluded that leaded gaso-



line would protect exhaust valves beginning at levels between



0.04 and 0.07 grams of lead per gallon.





III.C.2. Alternatives to Lead to Avoid Valve Recession



     Other mechanisms besides lead  in gasoline can mitigate



significant valve recession.  Among these,  improved metallurgy of



the valves and phosphorus additives to gasoline are of greatest



interest for this analysis.

-------
                               III.38





      Since  1971,  the  automobile  industry  has  used  induction



 hardened  valve  seats,  seat  inserts, or  chrome or nickel  plating



 in  light-duty vehicles to mitigate valve  recession without lead.



 Essentially, these  technologies  either  stop the oxidation of  the



 iron  valve  seat or  harden the  valve seat  (or  face)  to protect



 against the adhesive  and abrasive processes.   By 1971, General



 Motors Corporation  was using this improved metallurgy on all  its



 light-duty  vehicles to compensate for the use of unleaded gaso-



 line.  Ford made  these improvements on  most of its  light-duty



 vehicles  by 1971  as well.   After that date, other  manufacturers



 also  implemented  these changes.  By the 1975  model  year, virtually



 all cars  were "clear  fuel tolerant," although the  changes in  light



 trucks may  have been  slower.   The widespread  use of these improve-



 ments since the early  1970s has  greatly limited the number of



 vehicles  that might be  at risk of valve damage due  to the unavail-



 ability of  leaded gasoline.



     In addition, other substances could feasibly  provide vehicles



 with the  lubrication they now  receive from lead in gasoline.  Most



 plausible among the alternatives are phosphorous compounds which



 are already added to gasoline along with lead  (i.e., the alterna-



 tive technology is  already  in  use and has been found to  be effec-



 tive in reducing valve wear).



     Several experiments suggested that phosphorus  in unleaded



gasoline could reduce  or eliminate the  threat of valve recession



at high speeds.   Specifically,  at about 0.06  or 0.07 g phosphorous/



gallon,  valve wear proceeds at  one-half to one-third the rate

-------
                             III.39


occurring with no additives (Giles and Updike, 1971;  Kent and

Finnegan, 1971; Felt and Kerley, 1971; and  Wagner, 1971).   The

tests were run primarily under unusually high loads or speeds,

similar to conditions used in the previously described studies of

valve recession.  Amoco (Wagner, 1971) reported that its road

tests of heavily loaded 1970-vintage cars, for 20,000 to 30,000

miles at average speeds of 60 mph (and up to 70 mph), found that

0.07 g/gal of phosphorus was effective in controlling valve reces-

sion for nearly 90% of the cars tested.  The phosphorus more than

halved the rates of recession for the cars that, without lead or

phosphorus, had experienced sinkage rates of more than 0.01 inches

per 10,000 miles.*  Kent and Finnegan found, however, that at

lower load conditions and 2300 rpm for 80 hours, phosphorus was

fully protective against any valve seat widening or oxidation.

Cordera et al.  (1964) showed that neither altering the scavenger

mix nor eliminating scavengers from the fuel curtailed exhaust

valve life in  the engines.  They found the presence of phosphorus

in the gasoline was critical to exhaust valve  life durability.

All of these results indicated that the addition of phosphorus to

unleaded gasoline would substantially reduce  the risk of valve

recession  for  those vehicles at risk.

     In  addition to gasoline engines  in light-duty vehicles,

three other categories of engines might require leaded gasoline.
 * Giles  (1971)  said  that  the  limit of  tolerable  recession
  was about  0.125  to 0.150  inches of change,  at  which  point
  the hydraulic valve lifters  had problems  operating.

-------
                              III.40





 The  first  of  these  are  a  variety  of  classes  of  small  engines:



 lawnmowers, snowmobiles,  snowblowers,  garden tillers,  and



 other  small equipment.  We  asked  representatives  of the  three



 major  manufacturers  of  small  engines in  the  United States  (Briggs,



 Tecumseh,  and  Kohler) what  kind of gasoline  they  recommend  for



 these  engines.  They said that their engines almost always  could



 use  either leaded or unleaded gasoline,  or they should use  unleaded



 gasoline.  These representatives  also  believed  that this had been



 true for their engines  for  at least  a  decade (and knew of no



 changes that would make this  untrue  for  earlier engines).   Impor-



 tantly, the reason they cited for preferring unleaded gasoline for



 this equipment was that leaded gasoline  caused  harmful deposits



 and corrosion  in the engines.



     Second, we investigated  the possibility that marine engines



 required leaded gasoline, but the responses  from manufacturers



 of boat engines were not clear-cut.  Some boat engines may  require



 the lubrication they now get  from lead,  while others are supposed



 to use clear fuel.    Two-stroke engines should not be affected by



 using unleaded gasoline.  One complicating issue was the relative



 octanes of leaded and unleaded gasolines.  With the limited



 information we had,   it appeared that some, but not all, marine



engines would require leaded gasoline.



     Third, gasoline-powered heavy-duty  trucks are designed to



use leaded gasoline.  (Such trucks account for roughly 4% of all



gasoline demand.)   Because heavy-duty trucks are more likely than



passenger cars to travel under heavy loads for long durations,

-------
                             III.41


this category may carry the highest risk of premature valve

failure if fueled with only unleaded gasoline.  However, the

extra magnitude of risk was difficult to assess because we did

not know what fraction of these trucks used a high portion of

their potential power.  Giles (1971) wrote that

     Heavy duty engines, however, usually have valve seat
     inserts, rotators, and heavy duty valves already
     included in the design package....  Valve face reces-
     sion and seat wear both are observed with heavy duty
     engines running on leaded fuels today.  Wear rates are
     low, however, and recession is noticed only because of
     the extended operating life of these engines.  Some
     increase in wear rates might occur when these engines
     are switched to lead-free gasoline, but catastrophic
     wear is not expected.  Limited dynamometer testing
     does indicate that wear is not increased significantly
     but each engine design and application should be
     weighed separately.  (Giles, 1971, p.1483)

Nonetheless, manufacturers reportedly would recommend against

allowing heavy-duty trucks to operate solely on unleaded gasoline.

As a result, heavy trucks may be the single category significantly

affected if  leaded gasoline were not available.

     We have estimated approximately how many engines might be

"at risk" of severe valve recession if  leaded gasoline were not

available.*  Using the method and assumptions described in detail

in the Technical Appendix to Chapter IV, we estimated that about

2.2 million  light-duty vehicles without improved valves would exist
* For most of these vehicles at risk, the probability of severe
  valve recession due to  lack of  lubrication  from lead appears
  to be well below 10%  in any year.  Because  of limited data,
  we were unable to quantify this probability with any greater
  precision.  The probability for any individual vehicle will
  depend very much on its particular design and the ways in
  which it is operated.

-------
                               III.42


 in  1988.  An  additional  12.2 million  cars  (model  years  1971-80)

 were  designed  for  leaded gasoline  and some  of  these may be  at

 risk.  However, GM has indicated that since  1971  all  of its cars

 used  the  improved  valves.  Because  roughly  50% of the market

 was GM vehicles, we have reduced this number by half, to 6.1

 million cars.  Ford also used  improved valves  and we  have reduced

 the value by  Ford's market share of roughly  20%.   This  final

 value (3.7 million cars) is most likely too  high  also because

 other manufacturers probably used  improved valves as  well.

 Table III-3 shows  a more disaggregated forecast and presents

 projections for the full range of engines.  These 25.5  million

 "at risk" vehicles represent about  13.5% of  the 188 million

 projected total fleet of highway vehicles.*


 III.D.  Summary
            %
     This chapter  has presented national estimates of the vehicle

 maintenance benefits of a reduction of lead in gasoline.  Two

 scenarios have been examined:  a reduction of lead in gasoline

 from the current 1.10 grams/gallon to 0.10 grams/gallon, as  well

 as the total elimination of leaded gasoline.  These estimates

 are based on projections of gasoline demand and vehicle  fleet

 characteristics in 1988,  and are valued in 1983 dollars.

     Three sources of vehicle maintenance benefits have been

 tabulated and  are presented in Table  III-4.  Both policy options
* Equal to 1.17 times the projected light-duty truck and light-
  duty vehicle fleet of 160 million, using Bureau of Census
  1977 proportions.

-------
                              III.43


                           Table III-3




             NUMBER OF ENGINES AT RISK OF SEVERE VALVE

                 RECESSION WITHOUT LEADED GASOLINE
Type of Vehicle


Cars Pre-'71

LDTt Pre-'71

Cars 1971-1980

LDTt 1971-1975

Heavy-Duty Trucks

Boats


    TOTAL "AT RISK" GROUP:
 Thousands of Vehicles in 1988

   High Risk*       Low Risk*


     2,240

     1,146

                       3,700

                       7,505

    10,865**

Not calculated     Not calculated


    14,251            11,205
                 TOTAL ALL VEHICLES:   25,456,000
 * The "high risk" group  represents  heavy-duty  and  those
   light-duty vehicles manufactured  before  1971.  While
   many vehicles manufactured between  1971-1980 were
   built to use leaded gasoline, most  of  these  have
   newer more durable valve  and valve  seat  materials  and
   and thus form a "low risk" group.

** This is equal to  30% of our projection of  light  trucks
   in 1988 — the same proportion  as was  found  in the Bureau
   of the Census publication 1977  Census  of Transportation
   (1980).

t  Light-duty trucks.

-------
                              III.44





are expected to result  in savings  in decreased exhaust system



replacements,  longer  life for spark plugs, and increased  time



intervals between oil changes.  The point estimate of vehicle



maintenance benefits  for the  low-lead option is $618 million,



while the no lead scenario yields an estimate of $741 million



in benefits.   Several other sources of potential vehicle



maintenance benefits have also been discussed in this chapter,



but no monetary estimate of their magnitude has been attempted.



     Chapter III also presents estimates of the number and types



of vehicles expected to be at increased risk of severe valve



recession if leaded gasoline is completely eliminated.  As shown



in Table III-4, more than 25 million vehicles are expected to be



at increased risk of damage in 1988.  However,  monetary values



for these damages have not been computed due to considerable



uncertainty as to the number*of vehicles likely to experience



damage.

-------
                                  111-45
                                 TABLE III-4

                         SUMMARY OF MAINTENANCE SAVINGS
                          (1983 dollars,  in millions)
                                               LIVs* Designed
Billions of gallons of
leaded gasoline demand in 1988
ALL UNLEADED SAVINGS:
Exhaust Systems @ $1.68
-------
                               III.46


                            REFERENCES

                           CHAPTER III
Adams, W.E.,  (Ethyl Corporation),  "Discussion of SAE Paper
   #720084," Detroit, January, 1972.

American Automobile Association  (Potomac Division), "What's
   Wrong with  the Average Washington Car", (News Release).
   Falls Church, VA., January 3,  1984.

Bettoney, W.E., (DuPont de Nemours and Co.), "Discussion
   of SAE Paper #720084," Detroit, January, 1972.

Canadian Energy and Emissions Committee, Comments on "Control
   Options For Lead Phase Down in Motor Gasoline," Environment/
   Canada Report, International Lead ZMC Research Organization,
   May 1983.

Champion Spark Plug Co., Champion Ignition and Engine
   Performance Conferences, volumes 1971-1976

Committee on Motor Vehicle Emissions, Report on the Development
   of a Long-Term National Motor Vehicle Emission Strategy,
   Australian Transport Advisory Council, 1972.

Coordinating Research Council, 1982 CRC Octane Numbers
   Requirement Survey, July 1983~*

Cordera, F. J., et al. (Shell Oil Company), "TEL Scavengers in
   Fuel Affect Engine Performance and Durability," SAE Paper
   #877A, June 1964.

Doelling, R. p. (Cities Service Oil Company), "An Engine's
   Definition of Unleaded Gasoline," SAE Paper #710841.

DuPont,  Petroleum Laboratory, "Exhaust Catalysts for Leaded
   Fuel - A Progress Summary, "PLMR-42-81, submitted to EPA
   May 1982.

Exxon Memo, "Re: Gulf/East Coast Gasoline," January, 1978.
   (in Attachments to this paper.)

Felt, A. E., and Kerley R. V., (Ethyl Corporation), "Enginges
   and Effects of Lead-Free Gasoline," SAE Paper #710367,
  October 1970.

Gallopoulos, N. E.  (General Motors Corporation), "Projected
  Lubricant Requirements of Engines Operating with Lead-Free
  Gasoline," SAE Paper #710585.

-------
                              III.47
Gergel, W.C., and Sheahan,  T.  J.  (Lubrizol Corporation),
  "Maximizing Petroleum Utilization Through Extension of
  Passenger Car Oil Drain Periods - What's Required?," SAE
  Paper #760560, 1976.

Giles, W. S. (TRW Incorporated),  "Value Problems with Lead Free
  Gasoline," SAE Paper #710368.

Godfrey, D., and Courtney,  R.  L., (Chevron Research Company),
  "Investigation of the Mechanism of Exhaust Value Seat Wear in
  Engines Run on Unleaded Gasoline,"  SAE Paper #710356.

Gray, D. S. , and Azhari, A. G. (American Oil Company), "Savings
  Maintenance Dollars with Lead-Free Gasoline," SAE Paper #720084,
  January 1972.

Hickling, J. F., Analysis of Lead Phase-Down Control Options,
  Management Consultants Ltd., October 1983.

Hickling Partners, Inc., Final Report on the Assessment of the
  Economic Impact on the Automotive Parts/Service Industry of
  Proposed Gasoline Lead Content Regulations, submitted to Policy
  Planning and Assessment Directorate,Environment/Canada,
  March 1981.

Kent, W. R. and Cook, W. A. (Union Oil Company), "The Effects of
  Some Fuel and Operating Parameters on Exhaust Value Seat Wear,"
  SAE Paper #710673, 1971.

Motor Vehicle Manufacturing Association Motor Vehicle Facts and
  Figures  "83".  Detroit, 1983.

Motor Vehicle Manufacturing Association, "incentives  for Proper
  Usage of Unleaded Fuel", memo to EPA, January, 1984.

Pahnke, A. J., and Bettoney, W. E., "Role of Lead Antiknocks in
  Modern Gasoline", SAE Paper #710842, 1971.

Pahnke, A. J., and Conte, J. E.  (DuPont de  Nemours and Co.),
  "Effects of Combustion Chamber Deposits and  Driving Conditions
  on Vehicles' Exhaust  Emissions,"  SAE Paper  #690017, 1969.

Pless,  L.  G.  (General Motors Corporation),  "Interactions Among
  Oil  Parameters Affecting Engine  Deposits  and Wear," SAE Paper
  #720686,  1972.

Pless,  L.  G.  (General Motors Corporation),  "A  Study  of Lengthened
  Engine Oil-Change Intervals," SAE Paper #740139, 1974.

-------
                              III.48
Schwochert, H. W. (General Motors Corporation), "Performance of
  a Catalytic Converter on Non-leaded Fuel," SAE Paper #690503,
  May 1969.

U.S. Environmental Protection Agency.  Motor Vehicle Tampering
  Survey - 1982.   National Enforcement Investigations Center,
  Office of Enforcement, April 1983.

Wintringham et al. (Ethyl Corporation), "Car Maintenance Expense
  in Owner Service with Leaded and Non-leaded Gasolines,"  SAE
  Paper #720499,  May 1972.

-------
                           CHAPTER IV






      BENEFITS OF AVOIDING EXCESS HC, NOX AND CO EMISSIONS





     This chapter discusses the effects of increased emissions



from poisoned catalysts of vehicles misfueled with leaded gaso-



line.  We estimated the excess emissions of hydrocarbons (HC),



nitrogen oxides (NOX), and carbon monoxide (CO)  that we could



avoid by eliminating misfueling in 1988.  We then examined three



alternative methods to value avoiding this air pollution.  We



synthesized this information to generate a best estimate of the



economic benefits of reducing misfueling.



     Both the all unleaded and low-lead policy options are



assumed to eliminate "misfueling" and its consequent excess



emissions.  "Misfueling" or "fuel switching" refers to the use



of leaded gasoline in a vehicle originally designed and certi-



fied to use unleaded gasoline.  Because leaded regular gasoline



is cheaper and higher in octane than regular unleaded gasoline,



some drivers deliberately misfuel their vehicles  in an attempt



to reduce expenses or to improve vehicle performance.  Our



low-lead option assumes a low-lead fuel  (0.10 grams of lead per



gallon of gasoline) for the few classes of vehicles that may



require the valve lubrication  lead provides, but  with avail-



ability restrictions designed  to eliminate misfueling as a



practical problem.



     Misfueling can occur by removing or damaging  the nozzle



restrictors  installed in the fuel inlets of  vehicles with  cata-



lytic  converters, by using an  improper  size  fuel  nozzle, or  by



funneling leaded fuel into the tank.  Sometimes gasoline  retailers

-------
                              IV. 2


sell gasoline that is mislabeled or contaminated (U.S. EPA,

1983c), but this accounts for less than 1% of misfueling.

     It is illegal for service stations or commercial fleet

owners to misfuel or to allow misfueling of vehicles originally

equipped with catalytic converters.  However, federal law does

not apply to individuals who misfuel their own vehicles.  This

limitation hurts EPA's ability to curb this harmful practice.

     Using leaded gasoline in vehicles with catalytic converters

damages this pollution control equipment and can increase emissions

of HC, CO, and NOX by as much as a factor of eight.  Table IV-1

shows the emissions increases.  The excess HC and NOX emissions

also increase ozone concentrations.

                           TABLE IV-1

       Increase in Emissions Due to Misfueling (grams/mile)

Light-Duty Vehicle Model Years           HC      CO       NOV

1975 - 80                               2.67    17.85
1981 and later                          1.57    11.07     0.71

Source:  U.S.  EPA, Office of Mobile Sources, "Anti-Tampering
         and Anti-Misfueling Programs to Reduce In-Use
         Emissions from Motor Vehicles," May 23, 1983.

     According to a 1982 survey by EPA (U.S. EPA, 1983c) the

current misfueling rate of light-duty vehicles designed to use

unleaded gasoline is about 12%.*  We assumed for our analysis that
*The unweighted average the survey found was 10.5%.   Weighting
 the results by the portions of the light-duty fleet in areas
 with and without Inspection and Maintenance (I/M)  programs, by
 the fractions of light-duty vehicles of each age (in 1982), and
 by the number of vehicle miles traveled by each model year, the
 weighted average is 12.2%.  (About 17%-18% of the  light-duty
 fleet was in I/M areas.)  We believe this estimate  may be an
 underestimate of actual  misfueling rates for several reasons
 discussed later in this  and other chapters.

-------
                               IV.3


this rate would stay constant to 1988.   If this rate rises over

time, as preliminary data from the  1983 survey imply, our emission

estimates may be too low.

     Misfueling rates apparently vary by the age of vehicle, by

whether the vehicles are in localities  that have Inspection and

Maintenance (I/M)  mobile source enforcement programs, by whether

they are part of a commercial fleet, and other factors.   Table IV-2

provides 1982 misfueling rates by model year of vehicle  and by I/M

status.

                              TABLE IV-2

      1982 Misfueling Rates by Age of Vehicle and by I/M Status
Model
Year
1982
1981
1980
1979
1978
1977
1976
1975
Overall
Misfueling Rates
5.2%
7.4%
8.1%
12.1%
12.2%
12.4%
14.5%
17.7%

I/M Areas
4.4%
4.3%
5.7%
4.9%
5.9%
9.9%
9.6%
6.3%

Non-I/M Areas
6.3%
9.6%
10.1%
20.3%
19.5%
16.5%
20.2%
30.9%
Weighted Average:*     13.5%            6.2%         15.1%

*This weighted average does not take into account the number of
 miles driven by each model year.


     The EPA surveys probably underestimated real misfueling rates

by a significant margin.  One of the main reasons for this was that

vehicle inspections for misfueling were voluntary, which would bias

the results downward.  In some areas, the rates of drivers refusing

inspections were very high.  The refusal rates ranged from less

than 1% to 8% in I/M areas, and from 3% to 44% in non-I/M areas.

-------
                               IV. 4





      Imperfect  indicators of misfueling also provided a possible



downward bias in these rates.  EPA used three tests  to check for



misfueling:  whether the fuel inlet restrictor was removed or



damaged, whether the gasoline in the tank had more than 0.05 grams



of lead per gallon, and whether traces of lead could be found



inside the tailpipe (the plumbtesmo test).  Each of  these three



tests is likely to miss a substantial portion of misfuelers, and



the plumbtesmo  test had a high rate of false negative findings



when  administered hastily in field tests.  By using  the three



indicators together, EPA tried to minimize the likelihood of



missing catalysts damaged by misfueling.  The results suggested



that  excess emissions from misfueling in 1983 were significant.



As explained in detail later in this chapter, misfueling accounted



for roughly 2.48% of all HC emissions, 5.18% of all  CO emissions,



and 0.78% of all NOX emissions, nationally.



      In economic analysis, because 1988 dollars are  not equal to



1983 dollars, future costs are discounted to arrive  at a "present



value."  To make the benefits of avoiding excess emissions compar-



able  to the estimate of costs that we presented in Chapter II, we



discounted our emission figures by 3% (the standard  rate used for



long-term analysis).  Table IV-3 shows the 1988 estimates of the



discounted stream of future emissions avoided by implementing



either of the policy options this paper is examining.  The



emissions estimates are from all cohorts of vehicles that would



misfuel in 1988 in the absence of any change in policies or



practices.

-------
                               IV.5


                            TABLE IV-3

               Discounted Future Emissions Avoided
                by Eliminating Misfueling in 1988
                    (thousands of metric tons)


                  HC       CO       NO     TOTAL

                 314     2,202     130     2,646

We estimated the tons of excess emissions that would be avoided in

1988 if EPA were to eliminate misfueling for all light-duty vehicles

in 1988 (under either the low-lead or all unleaded option).  We did

not consider emissions that would occur in 1988 from misfuelings in

previous years.  Since the costs of eliminating misfueling are

calculated for one year (1988), the benefits should include only the

avoided emissions attributable to eliminating misfueling in that

year, and none from other years.  The technical appendix to this

chapter provides a description of the fleet model and the discount-

ing procedure for avoided emissions beyond 1988, and a discussion

of uncertainties that may have biased our results.

     There is no consensus on a good, simple way to value the bene-

fits of eliminating habitual misfueling and its consequent excess

emissions.  As a result we have used three different approaches:

     A.  the value by the costs of alternative regulations;

     B.  the value of preserving catalytic converters; and

     C.  the value of avoiding damage to health, vegetation,
         and materials.

Table IV-8, which appears at the end of this chapter, summarizes

the values we derived by each of these three methods.  In the next

three sections, we present our calculations by each method in more

detail.

-------
                               IV.6





IV.A.  Value by the Costs of  "Next-Step" Regulations



     Our first method computes the value of avoiding misfueling



emissions by using the cost per ton of other HC, CO, and NOX



regulations that the Agency is considering promulgating  (Table



IV.4).  The rationale for this method is that these "next-step"



regulations reveal the low end of the range of values that EPA



or Congress imputes for controlling further increments of these



pollutants.  (This does not imply that EPA would not promulgate



such regulations if we were to adopt either the low-lead or



all-unleaded option.)



     To value these emissions, we chose future regulatory options



from among the least costly alternatives that could potentially



control a similar amount of each pollutant.  However, it should



be noted that EPA has imposed much more costly regulations for



these pollutants in the past.  In many of the more expensive



cases, the cost per ton of pollutants abated was not a good mea-



sure of what the Agency or Congress was valuing with that parti-



cular regulation.   For instance, Congress frequently required



EPA to choose the best technology available — sometimes without



regard to costs.  In other cases, controlling certain sources



was considered more valuable than abating an apparently similar



quantity from other sources.  This might have been because poten-



tial exposures to some sources were greater, or because the



particular pollutants may have different toxicities.  Thus,



"cost per ton" may be a very crude measure of cost-effectiveness



or the social value of controlling pollution.

-------
                               IV.7


     Table IV-4 shows our estimates of the present value of

emissions avoided by eliminating misfueling using the costs per

metric ton of alternative regulations.  The total benefit from

avoiding these pollutants would be $121-452 million in 1988.
                          TABLE IV-4

        Benefits Valued by "Next-Step" EPA Regulations
                        (1983 dollars)

                     HC         CO
                        NO,
                              Total
Total Value
of Emissions
$/metric ton
$81-217M
$232-618*
$27-140M
$11-57**
$13-95M
$92-660t
$121-452M
N/A
   Cost of $232-$618/ton of HC removed by Stage II vapor recovery
   from gasoline marketing.  Estimates were from Pacific
   Environmental Services, Inc., Update of the Gasoline Marketing
   Emissions Data Base,
   The"next-step
   of HC - would be
   $882 per ton of HC.
   Regulations Relating
	  September 1983  (4th Quarter 1982 dollars)
at petroleum refineries - another major source
 secondary seals on gasoline storage tanks, at
     This is from SCI, Impacts of Revising EPA
        Petroleum Refining and Petrochemical
to
   Production, June 1983.  Using this cost per ton would value
   avoiding excess HC emissions from misfueling at $217 million
   in 1988 (1983 dollars).

** Cost of $ll-$57/ton of CO removed by engine modification,
   catalysts, and inspection and maintenance on heavy trucks.
   Estimates were from Chapter 3, Regulatory Impact Analysis of
   the HC and CO Standards for Heavy Duty Trucks, U.S. EPA,
   forthcoming.
 t Cost of $92-660/ton of NOX removed by low excess air and
   staged combustion at utility and industrial coal boilers.
   Estimates for utility boilers were $84-251/short ton, from
   ICF, Inc., Analysis of a 10 Million Ton Reduction in Emissions
   from Existing Utility Powerplants, June"1982;industrial
   boiler estimates were $320-$600/short ton, calculated using
   emission factors from AP-42 and from the draft U.S. EPA,
   Background Information Document for the Industrial Boiler
   NSPS (1979),while costs came from Costs of Sulfur Dioxide,
   Particulate Matter, and Nitrogen Oxide Controls on Fossil
   Fuel Fired Industrial Boilers^ EPA-450/3-82-021, August, 1982.

-------
                               IV.8


IV.B.  The Value of Preserving Pollution Control Equipment

     Our second method of valuation used the cost per ton of

emissions control by catalytic converters and other equipment

disabled by misfueling.  To estimate the benefits of eliminating

misfueling, this method used EPA's implicit balancing of costs

and benefits in selecting catalytic converters as the method for

emissions control on mobile sources.  We assumed that this cost

per ton reflected the value that EPA and society placed on

reducing these pollutants.   In addition, this method of valuation

most nearly approximated the loss of catalytic converters poisoned

by misfueling.  Each year,  consumers purchase roughly 9.7 million

catalytic converters on their new light-duty vehicles; over 12%

of these are subsequently disabled by misfueling with leaded

gasoline.

      We estimated a cost of $283 per car for emission control

equipment (U.S. EPA, 1981).*  (About half of the cost of oxygen

sensors and other equipment was allocated to fuel efficiency,

not pollution control.)  We counted the emissions controlled by

that equipment over an average ten-year car life, beginning with

90% control efficiency in the first year, and leveling off by the

fifth year to 50% efficiency.  (EPA regulations require that

manufacturers provide warranties on catalytic converters for only
 * The costs are "retail price equivalents," which are 30% to 50%
   of the manufacturers' suggested retail price of the components
   as replacement parts.  There may be a small upward bias in this
   estimate, but we used the lower estimate in the cited report
   ($250, compared to a $425 upper bound).  Converting to 1983
   dollars gave a cost of $283.

-------
                               IV. 9


five years, but EPA data indicated that this equipment can be

effective for the life of the vehicle (Faucett,1983).) We may

have understated the rate at which catalytic converter effi-

ciencies deteriorate at low mileage.  If so, our estimate

would overstate the tons controlled and underestimate the

value of avoiding emissions by eliminating misfueling.

     We projected the tons of HC, CO, and NOX controlled in each

year of a ten-year catalytic converter life.  We then discounted

the future emissions at a 3% rate (as when calculating excess

emissions and costs) to the first year, when the equipment costs

would be incurred.  This produced a cost per ton of $163 for

avoiding HC, CO, and NOX emissions.*  We multiplied this by the

2.65 million tons of excess emissions avoided (from Table IV-3).

This gave us a benefit estimate of $432 million for eliminating

misfueling under either the low-lead or all unleaded policy

options.
*  Our calculations used 1981 emissions standards of 0.41 grams
   per mile for HC, 3.4 g/mi for CO, and 1.0 g/mi for NOX.  This
   totaled 4.81 g/mi for all pollutants in each future year.

   We divided 4.81 g/mi by (1 - catalytic converter efficiency
   in that year), multiplied by 10,000 mi/yr, and divided by
   1000 b/Kg to get kilograms controlled in each year by one
   catalytic converter.

   We then discounted the estimate for each year back to the
   first year of the catalytic converter's life.  Summing these
   present values gave us an estimate of 1.733 tons controlled
   by each car's catalytic converter over a ten-year life.

   A cost of control equipment of $283, divided by 1.733 tons
   controlled, equalled a cost per ton of $163 in 1983 dollars.

-------
                               IV.10


 IV.C.  Benefits Estimated Directly from Health  and Welfare
       Improvements

     Research has suggested  that  HC, NC>x' an<3 CO emissions may

 directly affect human health and  welfare.  Our  third method of

 valuing the adverse effects  of misfueling provided direct

 estimates of the health, vegetation, material,  and ecosystem

 benefits that would result from reducing these  emissions.  In

 addition, since HC and NOX are precursors of ozone, we estimated

 the benefits that a reduction  in  ozone would have on agricultural

 yield, materials damage, and health.

     Unfortunately, because  of scientific uncertainty, lack of

 data or quantitative estimates, or inability to value certain

 effects monetarily, we have  presented only a partial calculation

 of the total benefits of reducing misfueling.   For example, we

 did not calculate the effects of  ozone on ecosystems or the

 effects of chronic exposure of ozone on health, nor did we

 include a quantitative estimate of health benefits from reducing

 CO emissions.   When possible, however, we have described these

 effects qualitatively.

     A few of  the studies used in this analysis are EPA contractor

 reports in progress or in completed draft.  As such, they have not

undergone full peer review and should be considered preliminary.


 IV.C.I.  Benefits of Reducing Ozone

     To calculate the benefits of reducing ozone, we first had to

determine the  relationship between reducing HC and NOX and the

subsequent decrease in ozone.  Once we determined the reduction

-------
                              IV. 11





in ozone, we used both dose-response (bottom-up) approaches and



proportionate share (top-down)  approaches to determine the corre-



sponding amount of economic benefits.  In the bottom-up approach,



we used disaggregated damage functions to estimate the impact of



a given change in ambient levels.  In the top-down approach, we



interpolated aggregate damage numbers to obtain the impacts of a



single pollutant or of a given change in ambient levels.  Regard-



less of the approach, the benefit estimates contain a good deal



of uncertainty and should be interpreted with caution.



     we needed two general simplifying assumptions to use the



top-down technique.  First, unless noted otherwise, we assumed a



constant elasticity between pollution reduction and the economic



effect of concern.  Second, for certain estimates, we assumed



that the current base level for calculating changes in ambient



air quality was roughly equivalent to levels existing in the



mid-1970s.  Given the overall uncertainty in the available



information on benefits, changing the base year is within the



"noise level" of the estimates.



     The effects of ozone on human health, vegetation, materials,



and ecosystems were summarized in the EPA Criteria Document for



ozone (U.S. EPA, 1978), currently being revised.  In addition,



considerable new research has become available  since the



Criteria Document was published.



     Ozone changes are influenced by the amount of solar



radiation and changes in the concentrations of  NOX and HC.  They



are, therefore, very dependent on local conditions.  To estimate



the national change  in ambient ozone, we assumed average U.S.

-------
                              IV.12


atmospheric and meteorologic conditions.  This averaging will

introduce additional uncertainty into the estimate because local-

ized conditions are not fully represented.  Using the estimates

of avoided emissions in Table IV-3 and projections of total

emissions in 1988, we calculated the reductions in the HC and NOX

emissions under either of the two policy options under considera-

tion.*  The reductions in HC and NOX would be approximately 2.48%

and 0.8%, respectively.
*  Baseline projections for NOX,  HC,  and CO for 1988 were
   calculated as follows:

   For NOX we used an EPA emission factor generated in the draft
   model of MOBILE III for on-road vehicles in 1988 of approxi-
   mately 3.19 g/mi.   We assumed  159.6 million on-road vehicles
   traveling an average 11,436 miles  (see Appendix).  Multiplying

   3.19 g/mi x 11,436 mi/vehicle  x 159.6 x 106 vehicles
                      1 x 10^ g/metric ton

   = 5.82 x 106 metric tons

   Assuming motor vehicles account for 35% of the NOX emissions
   from transportation, stationary source fuel combustion, and
   industrial processes, total NOX emissions in 1988 will be
   16.634 x 10° tons  (U.S. EPA, 1982b).   Therefore, the 130,000
   avoided tons of NOX in 1988 (Table IV-3)  is approximately a
   0.78% reduction.

   The emission factors for HC and CO generated by EPA's
   MOBILE III were reduced by .75 to  adjust for that model's
   exclusion of localities with Inspection and Maintenance
   programs and the state  of California  which has its own, more
   stringent, emission controls.

   For HC, a 2.5 g/mi emission factor was used, along with
   the assumption that motor vehicles account for 36% of the
   HC emission from transportation, stationary source fuel
   combustion, and industrial processes.  Therefore, the HC
   reduction is 314,000/12.67 x 106,  or  roughly 2.48%.

   For CO, a 20 g/mi  emission factor  was used,  (generating
   36.5 x 10*> tons of CO)  with the assumption that motor vehicles
   emit 86% of all CO from transportation and residential fuel
   combustion.  The reduction of  2,202,000 metric tons is 5.18%
   of the total (5.18 = 2.2 x .86/36.5)  in 1988.

-------
                            IV.13





     Converting these changes in HC and NOX to subsequent changes



in ozone involves considerable uncertainty.  Disagreement exists



as to the ultimate magnitude of the effect.  For example,



research by General Motors suggested that because of scavenging



effects of NOX on ozone, decreases in NOX (holding HC constant)



may actually increase ozone levels in the area near the NOX



source; further downwind from the source, ozone levels would



decrease (Glasson, 1981).  To the extent that ozone is scavenged,



however, nitrogen dioxide levels would increase and potentially



contribute to health effects and materials damage.  Other General



Motors research suggested that decreases in both NOX and HC will



reduce subsequent ozone., but by less than that resulting from a



reduction in HC alone (Chock et al., 1981).  Because of the



uncertainty in predicting changes in ozone, we considered three



separate estimates to determine a reasonable point estimate for



the change.



     First, a preliminary report recently completed for EPA by



ETA Engineering (1983) employed a method for relating HC emissions



to ozone production using the Empirical Kinetic Modeling Approach



(EKMA) recommended by EPA.  ETA Engineering also evaluated the



actual changes in HC and ozone in the Chicago metropolitan area.



The analysis suggested a one-to-one relationship as an upper



bound between the percent change in HC and the resulting percent



change in ozone.  Using  this method, the decrease in ozone



concentration would be 2.48%.  Unfortunately, the ETA model did



not explicitly incorporate the impact of changes in NOX.

-------
                              IV. 14


     A second estimate of the change  in ozone was provided by

 the work of Kinosian  (1982).  Using EKMA curves derived from the

 Los Angeles basin as  data, he regressed ozone levels on HC and NOX

 concentrations.  He found the following functional  form fit the

 data well for a wide  range of HC/NOX  ratios:
                                        0.5
                      Z=a+b(HxN)

 where:  a and b are empirical constants that vary across locations

                  ( .04 £ a £ .06;  . 6 £ b <_ . 8 )

 and where:

       Z = Ambient ozone levels

       H = Ambient hydrocarbons

       N = Ambient oxides of nitrogen.

 To approximate the percent change in  ozone due to percent changes

 in HC and NOX, we set a = 0 and b = bo.  Taking the logarithm of

 this equation and the total derivative, we obtained:

                    dlog Z = .5  (dlog H + dlog N)

 Since the derivative of the log function is a percent change,

 the equation yielded:

           % change in Z = .5 (% change in H + % change in N)

                         =  .5 (2.48  + .78)
                         = 1.63

However because "a" is actually greater than zero, the change

 in Z according to this model would be less than 1.63%.  With a

nonzero "a", we obtained an approximation for the percent change

 in Z using a power series expansion.  Specifically:
                                       •
          log Z = log(a + b (H x N)-5) = log T +   2a
                                                 2T + a

-------
                             IV. 15


                       where T =  b (H x N)-5.

Taking the derivative and collecting terms:

      d£
      Z  = % change in ozone = 1.625[l-(2ab(HN)•5)/(2T + a)2]

     To determine the change in ozone, we assumed a = .05, b = .7,

an HC to NOX ratio of 10, and an  average daily maximum ambient

ozone level of .054 ppm.  These point estimates were averaged

from currently available data (Council on Environmental Quality,

1980).  We were then able to solve directly for H and N using

Kinosian's equation relating ozone levels to HC and NOX.  Substi-

tuting these values into the above equation, we obtained:

             % change in ozone =  (1.63)(1-. 18) = 1.43.

Therefore, this technique generates a point estimate of 1.43%

for the actual change in ozone.

     A third estimate of the change in  ozone was determined using

recent EPA data from 1982 ozone State Implementation Plans  (SIPs)

(U.S. EPA, 1984b).  These SIPs estimated  the percent of HC  control

that was required to obtain a given reduction  in ozone.  The data

indicated that, as a best estimate, a 1.5% change  in HC would

change ozone, on average, by 1%.   Extrapolating  linearly, this

suggested that a 2.48%  reduction  in HC  would generate a 1.63%

reduction in ozone.

     These three techniques yielded potential  changes in ozone of

2.48, 1.43, and 1.63%.   Since the last  two methods  explicity

incorporate the impact  of changes in  NOX  on  ambient levels, we

have given them greater weight and  used a point  estimate  of 1.5%

as  the predicted change in  ozone.

-------
                              IV. 16


     Because of transport, oxidant pollution  is a regional, rather

than local, problem.  Oxidant transport can occur over a range of

several hundred miles or more.  Given its regional nature and the

nationwide distribution of the sources of ozone, we assumed a 1.5%

reduction in ozone concentration for the nation.  Since the bene-

fits from ozone reduction will occur in both urban and rural

areas, despite site-to-site variation,* this 1.5% change for a

national estimate appeared reasonable.

     We have estimated four benefits of reducing ozone levels:

health, agriculture, non-agricultural vegetation, and materials.

This is followed by estimates of the direct benefits of reduced

HC, NOX, and CO.


IV.C.I.a.   Ozone Health Benefits

     Studies of the effects of ozone on human health have

investigated the relationships between changes in ozone concen-

trations and changes in lung function; decrements in physical

performance; exacerbation of asthma; incidence of headaches;

respiratory symptoms such as coughing and chest discomfort; eye,

nose, and throat irritation; and changes in blood parameters

(U.S. EPA, 1978; Goldstein, 1982; Ferris, 1978).

     Regarding the "sub-clinical" effects,  for example, Hammer

et al.  (1974)  found an association of increased oxidants with

symptom rates of eye discomfort, cough,  headache,  and chest

discomfort in young, healthy adults.   He obtained the symptom
*The ultimate change in ozone levels for rural areas is least
 certain.

-------
                              IV.17





rates from daily diaries and adjusted them by excluding days on



which subjects reported fevers.   Makino and Mizoguchi (1975)



found a correlation between oxidant levels and eye irritation



and sore throats in Japanese school children.  Even low levels



of exposure to photochemical oxidants were shown to provoke



these respiratory symptoms for adults with predisposing factors,



such as smoking or respiratory illness (Zagraniski et al. , 1979).



Evidence of decreased athletic performance and dysfunction of



pulmonary systems was provided by Lippmann et al. (1983) and



Lebowitz et al. (1974).



     Unfortunately, it was not possible to estimate economic



benefits from these studies of "sub-clinical" effects.  Most of



them focused on determining either a threshold level for health



effects or whether there was a particular effect relating to



ozone exposure.  Thus, no exposure-response  relationship was



available from this literature.



     Recent work by Portney and Mullahy (1983) at Resources for



the Future (RFF)* and data reanalysis by Hasselblad and



Svendsgaard (1975) were exceptions.  The former  study considered



the effect of alternative levels of ozone on, among other mea-



sures, the number of minor restricted activity days (MRADs) over



a two-week survey period.  This health measure indicated how



frequently a person curtailed normal activity without actually



missing work or being bedridden.  The second study was  a statis-



tical reanalysis of the Hammer et al. study  cited above.   It
*The RFF study will undergo formal EPA peer  review  in April,  1984,

-------
                               IV. 18





used logistic estimation to relate sub-clinical health effects



to alternative levels of ozone.   Our results from applying each



of these studies follow.



     The RFF analysis consisted of regressing MRADs on a number



of independent variables, including socioeconomic and demographic



factors, chronic health status, urban variables, ozone, and other



pollutants.  Because of the inherent uncertainty in the analysis,



we used the 1.5-2.5 range for  the estimated regression coefficient



of ozone (measured as the average daily maximum 1-hour concentra-



tion during the two-week survey period) indicated in the RFF



study.   This resulted in an elasticity of 0.17-0.29 MRADs to



ozone.   Therefore, a 1.5% reduction in annual average ozone



levels would reduce MRADs by 0.255% to 0.435%.



     To calculate the health benefit from the reduction in ozone,



we applied these elasticities  to  the entire U.S. population in



1988, projected to be 245 million.  We used summary statistics



from the RFF report that indicated an annual average of 10.32



MRADs per person.  Using the low estimate of elasticity, the



improvement in ozone would result in 6.4 million (245 x 10^ x



10.32 x .00255)  fewer MRADs per year for the U.S.  population.



The higher elasticity generated an estimate of  11.0 million MRADs,



assuming some risk at all levels of exposure.



     To generate "low-low" and "high-high" estimates we placed,



somewhat arbitrarily, two alternative values on an MRAD.   As a



lower bound,  we  assigned a value of $7 per episode,  approximately



10% of  the average daily wage, to indicate some minimum amount

-------
                               IV. 19

 a  person would pay  to  avoid the minor restriction  in activity.
 We  then applied this value to  the  lower estimate of the total
 MRADs  to yield an estimate of  $45.1 million.
     For the  "high-high" estimate, we used $20 as  the value of
 an  MRAD which, applied to the  11.0 million MRADs,  yielded an
 estimate of $220.0 million.  This  still may be a conservative
 estimate for  several reasons.  To  obtain the health benefits of
 reducing air  pollution, Freeman (1982) used a value of $20 (1978
 dollars) for  a restricted activity day (non-minor) and also added
 expected reductions in medical expenses.  In addition, MRADs
 may affect work productivity.  Our "low-low" and "high-high"
 estimates produced a range of  $45  to $220 million  for 1988.
     An alternative estimate of the health benefits from reduced
 ozone concentrations was derived from the preliminary results of
 Gerking et al. (1983), which demonstrated that survey respondents
 were willing  to pay to avoid suffering an increase in ozone
 concentrations.  Specifically, the study estimated that a 10%
 reduction in  ambient ozone concentrations would generate a per
person "willingness to pay" of $1.55 to $1.92 per year.   Assuming
 linearity,  a  1.5%  reduction would result in a benefit of $0.23
to $0.29 per person, or $57 to $71 million nationally.   Unfortu-
nately, potentially serious problems with data and methodology
render this study  only suggestive of the benefits of reducing
ozone.   Nonetheless, it lends credence to the monetary estimates
suggested by applying the RFF model.

-------
                             IV.20


     To check the plausibility of these results, separate

estimates of symptoms were obtained using the Hasselblad and

Svendsgaard (1975) results.  The authors fit logistic curves to

estimate the relationship between ozone concentration (measured

as a daily maximum hourly concentration) -and eye irritation,

headache, cough, and chest discomfort.  The probability of a

response at an ozone level, X, measured in parts per hundred

million (pphm), was given as:


     p(X) = C + (1-O/U + exp  [-A - BX ] )


The following parameter values  (A,B, and C) were determined:

     For eye irritation  :  A = -4.96, B = .0907, C =  .0407
         headache        :  A = -4.88, B = .0470, C =  .0976
         cough           :  A = -2.98, B = .0092, C =  .0450
         chest discomfort:  A = -3.53, B = .0023, C = -.0166


    To calculate the change in this probability due to a change

in ozone, we differentiated the above with respect to X.  The

change in the probability (dp) of a given symptom due to a change

in ozone (dx) was:


     dp(X) = B( 1-C )(exp (- A - BX)) dX/ (1+ exp (- A - BX ))2


The change in probability can be estimated given information on

the existing daily maximum ozone levels.  To use pollution

measures commensurate with the original estimation, we obtained

EPA's data from the entire Storage and Retrieval of Aerometric

Data (SAROAD) network of ozone monitors.  Because of the non-

linearity in the equation representing the probability of a

-------
                              IV. 21





health effect, the mean daily one-hour maximum of ozone was cal-



culated for two separate six-month periods.   One period included



data from the second and third quarters, April through September



(when higher ozone levels generally occur),  while the other



period used the first and fourth quarters of the year.  For the



two periods we obtained average ozone measures of 6.1 and 3.3



pphm, respectively, yielding an annual average of 4.7 pphm.



     To reduce the chances of obtaining more than one symptom per



person and thus double-counting people affected, we used chest



discomfort to represent the symptoms reported as cough as well as



those reported as chest discomfort.  We calculated separately



the number of persons with reduced eye irritation and headaches.'



     Substituting the appropriate values for A, B, C, X, and dX



into the above equation for each six-month period, we obtained



the number of reduced symptoms.  For example, to calculate the



expected number of cases of chest discomfort in the second and



third quarters, we used the following values: A = -3.53,



B = .0023, C = -.0166, X = 6.1, dX = (.015H6.1) = .0915.



Substituting, to obtain the probability of a chest discomfort



symptom per person per day, yielded:
     dp(X) = (.0915) (.0023) (1.0166)H/(1 + H)2



                 where H = exp(3.53 -  (.00235(6.1))



           = 6.00 x 10~6 per person per day.





Multiplying by 245 million people and  183 days, we obtained a six



month total projection of 269,000 cases of chest discomfort in

-------
                              IV.22


1988.  Using this equation, the total change in the number of

symptom days expected in 1988 was:

                    Chest discomfort:    400,000
                    Eye irritation   :  5,783,000
                    Headaches        :  2,493,000

                               Total:  8,676,000

     Although we were not able to determine the exact correspon-

dence between MRADs and these reported symptoms, the projection

for these symptoms fell within the 6.4 to 11.0 million range

estimated for MRADs and.supported the estimate.

     Another important health effect of ozone, reported by

Whittemore and Korn (1980)  and Linn et al. (1981), was the

exacerbation of asthma and nonspecific obstructive respiratory

disease.   To estimate the decrement in asthmatic attacks result-

ing from the reduction in misfueling, we used the analysis of

Whittemore and Korn.  They used a logistic curve to estimate the

probability that an asthmatic would have one or more attacks on

a given day.  This probability was hypothesized to depend on air

pollution levels, temperature and humidity, the day of the week,

and the presence of an attack on the preceding day.

     The  results suggested that the probability of an attack was

significantly related to exposure to ozone.  Specifically, their

results suggested the following:


                log (P/l-p)= 1.66 z + bixi

     where p = the probability of an attack

           z = ambient ozone (24-hour average concentration)

           Xi= meteorologic and other control variables.

-------
                             IV. 23


To determine the change in the probability of an attack (dp)  due

to a change in ozone (dz), we partially differentiated both sides

of the above (i.e., dX = 0) and solved for dp:


                       dp = 1.66  (p)  (1-p) dz


     To estimate the actual change in probability, we had to

determine the ambient ozone level and the baseline probability of

an attack, represented as "p".  Because of the inherent uncertainty

in these numbers, we used the point estimate to determine economic

benefits and then conducted a sensitivity analysis using alter-

native values for "p" and "dz".  An ambient ozone level was

approximated using available data for 1979 through 1982 (U.S. EPA,

1982a; Evans et al., 1983).  For this analysis, we used a point

estimate of 0.040 ppm, but considered 0.035 ppm in the sensitivity

analysis.

     Data on the baseline probability of an asthmatic attack were

difficult to obtain.  These attacks vary widely in frequency,

duration, and intensity.*  For example, asthmatics with a condition

characterized as "mild and intermittent" (roughly 60% of all

asthmatics) may have two or three attacks a year.  However,

they may be ill-prepared to respond to severe attacks and may

undertake significant medical expenses.  "Moderate" asthmatics

(25% of all asthmatics) may have one attack a month, requiring
*  Estimates of the frequency and severity of asthmatic attacks
   were based on personal communications with Jeff Cohen, U.S.
   EPA, Office of Air Quality Planning and Standards, based on
   his survey of experts.

-------
                              IV.24



some medical expense, lost work, or restrictions in activity.

There may be some chronic respiratory impairment.  "Severe"

asthmatics (up to 15% of all asthmatics)  may have several attacks

a month.  Evidence from daily diaries in Salt Lake City and New

York City suggested 30-40 attacks per year.   This group may be-

better prepared for the attack, but may be on continuous medica-

tion and/or be forced to undertake significant preventive

actions.

     To estimate the baseline probability of an attack, we used

a weighted average of the expected number of attacks for each

group.  Multiplying the proportion of asthmatics in each classi-

fication by their average number of attacks per year, we obtained;


      (.6)(3) + (.25X12) + (.15M36) = 10.2 attacks per year


This generated a probability of 2.8% per day (10.2/365=2.8%).

Other research suggested a daily probability of an attack

ranging from 1.4-2.5% per day with a point estimate of 1.8%.*

Therefore, as a point estimate we used 2.0% for the daily

probability of an attack, indicating an average of 7.3 attacks

per year.  (This estimate obviously does not reflect the extreme

variability among asthmatics.)

     The change in the probability of an attack was calculated

using a point estimate of .04 ppm for ozone exposure, a 1.5%
* These estimates were also based on personal communications
  with Jeff Cohen, U.S. EPA, Office of Air Quality Planning
  and Standards.

-------
                             IV. 25





change in ozone, and a value of .02 for the baseline probability



of an attack.   Substituting:





       dp = (1.66)(.02)(.98)(.0006) = 1.95 x lQ-5/person/day





     To estimate the population at risk, we used estimates of the



numbers of asthmatics and atopies (persons potentially sensitive



to ozone) in the entire U.S. population (245 million).  Currently,



4% of the population is considered asthmatic, with an additional



9% considered atopic.  Thus, the population at risk is 13% of



245 million, or 31.85 million.  The total reduction in the annual



number of attacks would be:



             227,000 = 1.95 x 10~5 x 31.85 x 10^ x 365.



     To determine the monetary benefit of these reduced attacks



we had to assign a value per attack avoided.  Ideally, this would



equal the individual's (or society's) willingness to pay to



prevent the occurrence of an attack.  Unfortunately, no data



exists on this willingness to pay.  Likewise, we could not find



any published estimates of the average medical costs  incurred



for an attack.



     Based upon the existing evidence of the potential severity of



an attack, we arbitrarily valued each attack at $70,  the average



daily wage, as a "ballpark" estimate.  Because of their chronic



condition, 7% of all asthmatics are consistently forced to limit



their activities outside of their  "major activity" such as working,



keeping house, or going to school  (U.S. DHEW, 1973a).  Another



7% are forced to limit their  amount or kind of major  activity.



Finally, an additional 1.5% are unable  to pursue any  major activity,

-------
                               IV.26





      Data  also  existed  on  the  frequency  and  degree  of  annoyance



 from  an  asthmatic  condition  (U.S.  DHEW,  1973b).   Of the  asth-



 matics sampled,  52%  reported that  they were  bothered by  asthma



 "once in a while," 21%  were  bothered  "often,"  and 14%  were



 bothered "all the  time."   Regarding the  degree of bother, 11%



 reported "very  little," but  36%  reported "some"  and 43%  reported



 a  "great deal"  of  bother.  Evidence on visits  to physicians



 indicated that  40% of the  asthmatics  saw a doctor two  or more



 times a  year, while  20% saw a doctor  five or more times  a year.



 Finally, 51% of  the  asthmatics were taking medicine or following



 treatment recommended by a doctor.  Thus, given  the degree of



 bother and medical care involved,  we  used $70 per attack as  a



 point estimate.  However,  it may well be  that many  asthmatics



 would be willing to  pay more than  $490 ($70/attack  x 7 attacks



 per year) to prevent any asthma attacks  from occurring in the



 year.



     Multiplying the 227,000 expected attacks by $70,  we



 estimated benefits of $15.9 million.   Table IV-5  displays the



 sensitivity of this  estimate to alternative values  for the base-



 line probability, the ozone level, and the value  of an attack.



A reasonable range for the benefits of reduced asthma  attacks is



 $10.5 to $28.2 million,  with a point  estimate of  $15.9 million.

-------
                              IV.27
                            Table IV-5



              Benefits of Reducing Asthmatic Attacks

High Estimate
Point Estimate
Low Estimate
Ozone Level
(ppm)
.04
.04
.035
Baseline
Attack Rate
Probability
(percent)
2.5
2
1.5
Value of
Attack
($)
100
70
70
Benefits
($ millions)
28.2
15.9
10.5
     To avoid the double counting of asthma attacks with the MRADs



calculated above, we subtracted the estimated 227,000 attacks from



the number of MRADs that were estimated to occur.  We then added



the point estimate of $15.9 million for reduced asthma attacks to



the adjusted "low-low" and "high-high" estimates of MRADs to obtain



the total acute health benefits.  Consequently, these studies sug-



gested benefits from the reduction in acute health effects, includ-



ing both MRADs and asthma attacks, ranging from $59.3 million to



$233.4 million, with a point estimate of $146 million.



     These ozone health benefits reflect the likely acute effects



generated by intense, short-term exposure to ozone.  Long-term



exposure to ozone may also affect the health of some people, but



the epidemiological evidence on chronic ozone effects is sparse.



One of the available studies, Detels et al.  (1979), compared the



effects of prolonged exposure to different levels of photochemical



oxidants on the pulmonary functions of both  healthy individuals



and individuals with chronic obstructive pulmonary disease.

-------
                              IV. 28


Persons exposed to an annual mean of 0.11 ppm of oxidant, compared

to a control group exposed to 0.03 ppm of oxidant, showed statis-

tically significantly increased chest illness, impairments of

respiratory function, and lower pulmonary function.*

     In addition to the sparse epidemiological evidence of the

effects of long-term exposure to ozone, several animal experi-

ments have demonstrated effects on lung elasticity, blood

chemistry, the central nervous system, the body's ability to

defend against infection, and the rate at which drugs are

metabolized (U.S. EPA, 1983a).  While work is now under way to

extrapolate these animal data to human dose-response functions,

this is not presently possible.  Therefore, we could not quantify

the chronic health effects attributed to ozone, but we believe

that some of these effects may be significant at current ambient

levels.

     Using the studies cited above, the total health benefits

from the reduction in ozone due to reduced misfueling was $146

million from reduced MRADs and asthmatic attacks, plus potential

reductions in chronic health conditions from decreased ozone

levels.  If we symbolize these non-monetized health benefits as

OZC, the total health benefits are $146 million + OZC.
* At workshops related to the development of the Criteria Document
  for ozone, some shortcomings in this analysis were noted.  For
  example, the study group was also exposed to higher levels of
  NC>2 and 304 and there was some question about the adequacy of
  the measurement of ozone exposure and about the subject selec-
  tion and the test measures.  Although it is both reasonable and
  likely that long-term exposures are harmful to health, the
  failure to correct for the effects of other pollutants raises
  uncertainties about the specific findings.

-------
                              IV. 29





IV.C.l.b.  Ozone Agricultural Benefits



     Research has shown that ozone alone, or in combination with



sulfur dioxide and nitrogen dioxide, is responsible for most of



the U.S. crop damage associated with air pollution.  Ozone can



affect the foliage of plants by biochemical and cellular alter-



ation, thus inhibiting photosynthesis and reducing plant growth,



yield, and quality. '



     To generate a top-down estimate of agricultural benefits,



we used generalized relationships between ozone concentration,



yield, and economic loss.  The aggregate estimates of Adams (1983)



and SRI  (1981), as summarized by Freeman (1982), suggested that



the average annual benefits associated with a 10%  reduction in



ozone concentrations were $200 to $500 million in  1983 dollars.  To



use the  top-down approach, we assumed that this relationship held



over a broad range of exposures.  Thus, the 1.5% ozone reduction



could produce a benefit of $30 to $75 million from increased crop



yields  (1.5%/10% times $200 to $500 million = $30  to $75 million).



     As  an alternate approach, we followed the bottom-up approach



of Kopp  (1983).  He estimated the effects of ozone changes on



soybeans, wheat, corn, peanuts, and cotton on a county-by-county



basis.   Because this analysis directly incorporated estimates of



the demand and supply elasticities  for these crops, it appeared



to be the most precise assessment of benefits available.   His



estimates suggested  that  a  1.5% change  in ozone would  produce



approximately $120 million  in lost  economic value  (1983 dollars).



These five crops accounted  for roughly 76% of the  total value of

-------
                              IV. 30





commercial crop production  in  the United States.  Therefore, we



scaled Kopp's estimate of crop damage by assuming that ozone



damages to all other crops  occur in the same proportion as their



relative values.  The benefits of the 1.5% change in ozone grew



to approximately $157.5 million  (1983 dollars).



     Another benefit estimate  for reduced ozone, conducted on a



crop and region-specific basis, was provided directly from the



National Crop Loss Assessment Network (Heck et al. , 1983).  Their



estimate of the effects on  economic surplus (consumer and



producer well-being) included only crops in the corn belt —



corn, soybeans, and wheat — which are less than half of all



expected crop losses from ozone.  The results suggested that a



3% reduction in ozone would increase economic surplus by $140 to



$230 million.  Assuming linearity, a 1.5% change would generate



a surplus of $70 to $115 million.  If these crops in the corn



belt constitute 50% of all ozone-related damages (probably a



high estimate), the total benefits of the 1.5% reduction would



be $140 to $230 million.



     Together,  the benefit estimates from these studies ranged



from $30 to $230 million per year.   To determine a point estimate



of the damage to agricultural crops, we weighted the last two



analyses most heavily, because they contained the most precise



estimate of changes in economic welfare.   This suggested a point



estimate of agricultural loss from ozone concentrations of



approximately $160 million.

-------
                              IV.31





IV.C.l.c  Nonagricultural Vegetation Benefits of Reduced Ozone



     The estimates presented above addressed only agricultural



crops.  They excluded damages to forests and ornamental plants,



which may be substantial.  For example, in a very small contingent



valuation study, Crocker and Vaux (1983) found that the shift of



an acre of timberland in the San Bernardino National Forest from



either the severely or moderately harmed category into the



unharmed category would generate additional annual recreational



benefits of $21 to $68 per person.  These findings are difficult



to generalize for the rest of the nation because the San Bernardino



area has very high ozone concentrations and because of other site



attributes and socioeconomic characteristics.  Nevertheless, they



indicate that reduced damages to vegetation may produce signifi-



cant benefits.



     The preliminary draft of the Ozone Criteria Document  (1983a)



also provided additional qualitative evidence:  "The influence



of 03 on patterns of succession and competition and on individual



tree health is causing significant forest change in portions of



the temperate zone	 Long-term continual stress tends to



decrease the total foliar cover of vegetation, decrease species



richness and increase the concentrations of species dominance  by



favoring oxidant-tolerant species.  These changes are occurring



in forest regions with ozone levels (1-hour maximum) ranging  from



0.05 ppm (111 ug/m3) to 0.40 ppm  (785  ug/m3)."  For commercial



timber purposes, however, damages are  likely  to be small,  as most

-------
                               IV. 32





 commercial  forests are  in areas with low ozone concentrations.



 In areas with relatively high  concentrations, trees  resistant  to



 ozone can be planted.



     Finally, we present one quantitative estimate,  noting that



 it was based on very sparse data  and generated by making some



 significant abstractions from  existing studies.  Leighton et al.



 (1983) have estimated that the benefits associated with non-



 agricultural vegetation from a 10% reduction in ozone concentra-



 tions are $0.0 to $100 million.  Assuming linearity, the benefits



 from a 1.5% reduction in ozone would be $0.0 to $15.0 million,



 with a point estimate of $7.5 million for 1988.  We  stress,



 however, that the existing evidence is uncertain.





 IV.C.l.d.  Ozone Materials Benefits



     Ozone directly damages many types of organic materials,



 including elastomers, paint, textile dyes, and fibers.  It can



 increase the rigidity of rubber and synthetic polymers, causing



 brittleness, cracking, and reduced elasticity.  Ozone exposure



 also can generate other effects,  such as avoidance costs (pur-



 chasing of specially resistant material) and aesthetic losses.



Only the direct costs were incorporated in this analysis, however.



     In his survey of the literature, Freeman (1982) suggested



 that annual material damages from oxidants and NOX amounted to



approximately $1.1 billion (1978  dollars).   Using the Consumer



Price Index as well as census figures on projected population



increases to update the figure, produced an estimated $1.88

-------
                              IV. 33





billion for 1983.   An ozone reduction of 1.5%, assuming linear-



ity, suggested a benefit of $28.2  million annually.



     We obtained an alternative estimate of the benefits from



reduced materials  damage by using  dose-response information from



the Ozone Criteria Document (U.S.  EPA, 1978).  The text supplied



per capita economic damages for elastomers, textiles, industrial



maintenance, and vinyl paint costs as a function of annual ozone



levels.  Using an  annual 24-hour mean for ozone of .040 ppm, as



reported above, and a population estimate of 245 million for 1988,



we calculated a benefit range of $16.4 to $22.6 million in 1983



dollars (point estimate of $19.5 million), for a 1.5% reduction



in ozone.  Taking  the arithmetic mean of the point estimate from



the two different  approaches for materials benefits yielded a



point estimate of  $24 million annually in 1988.





IV.C.2.  Benefits  of Reducing NOV Emissions



     NOX emissions are believed to damage health and materials,



to contribute to reductions in visibility, and are associated



with acid deposition.  In addition, damage to vegetation has been



demonstrated experimentally.  Unfortunately, specific dose-



response information relating to NOX  is sparse.  As a consequence,



only broad aggregate estimates were presented to approximate the



effects of NOX emissions on health and welfare.



     Materials damage from NOX are not included in this section



since  it was contained in the ozone benefits section.  While



there may be acid rain benefits as well, we  have not included

-------
                               IV.34


 them  because  of  the  uncertainties  over  the  role  of  NOX  in  acidic

 deposition.   Therefore,  we  included  only  the  benefits of reduced

 health  effects and  improved  visibility, as  benefits for reducing

 NOX emissions in  1988.

      Regarding NQX health effects, EPA  is currently reviewing

 its ambient air  standard for  nitrogen dioxide  (NC^).*   The

 Clean Air Scientific Advisory  Committee (CASAC)  recommended  that

 any NC>2 standard  should protect against repeated short-term

 "peak" exposures  and against  long-term  "chronic" exposures

 because of possible health effects.**

      Repeated exposure to short-term peaks  of  NOX has been

 associated with excess respiratory illness  and symptoms in

 children, and with small (but  statistically significant) reduc-

 tions in lung function (U.S. EPA,  1982c).    Because  repeated

 episodes of respiratory tract  irritation and  illness in children

 may carry into adult life in the form of reduced lung function

 and chronic bronchitis, NOX reductions may  also reduce  subsequent

 adult cases of chronic bronchitis.  Long-term exposure  to  low

 level NC>2 may contribute to emphysema.  Thus, significant  bene-

 fits, although unquantified in this paper, may result from

 controlling NOX.

     Surveying several research efforts, including  those linking

NOX to changes in property values (which may capture both  health
 * NC>2 is an indicator pollutant for all nitrogen oxides.

** CASAC closure letter on OAQPS Staff Paper for NOX,
   July 6, 1982.

-------
                             IV.35


and welfare effects), the National Academy of Sciences (1974)

suggested a range of $1.0 to $8.0 billion, adjusted to 1983

dollars, for the annual effects other than materials damage.

Assuming proportionality between the predicted .78% reduction of

NOX and reduced damages, the benefits would be $7.8 to $62.4

million annually.  We used the midpoint of this range, $35

million, as the point estimate.

IV.C.3  Reducing Emissions of Hydrocarbons

     The various chemicals constituting hydrocarbons from automo-

bile emissions may affect health.  Specifically, benzene, which

is believed to cause leukemia, constitutes 4% of total tailpipe

HC emissions (U.S. EPA, 1983b).

     To estimate the number of benzene-linked leukemia deaths we

might avoid by eliminating misfueling, we used the EPA Carcinogen

Assessment Group (CAG) Risk Assessment for Benzene.  This analysis

predicted that human exposure to automobile benzene emissions*

resulted in an estimated 50.89 leukemia deaths per year in 1976

(U.S. EPA, 1979).  As displayed  in Table IV-3, we estimated that

misfueling in 1988 would produce 314,000 metric tons of HC

emissions, or 4.99% of the 6.29 million tons of automobile HC

emissions in 1976, the year of CAG's analysis (U.S. EPA, 1982b).

This estimate, however, was based on a unit risk estimate  for
* CAG assesses risks as the amount of exposure  (in parts per
  billion), times the population exposed, times  duration of
  exposure.  Their benzene analysis yielded 150  million ppb-
  person-years.

-------
                              IV.36





benzene  (,024/ppm) which was revised by CAG in November 1981



(.022/ppm).  Using this new unit risk estimate and CAG's analysis,



automobile tailpipe-benzene emissions were predicted to result in



an estimated 47.34 leukemia cases per year (U.S. EPA,  1974a).



Therefore, assuming linearity, 4.99% of the 47.34 leukemia deaths,



or 2.36 deaths, would be avoided by preventing misfueling in 1988.



This assumed that benzene would be the same fraction of the



reduced HC emissions as it was of total automotive HC  emissions



in 1976.



     Economic studies (Brown, 1978; Thaler and Rosen,  1976)



suggested that people are willing to pay $0.45 to $7.0 million to



save a "statistical" life.  Under this assumption, the health



benefits of avoiding the HC emissions would be $1.06 to $16.52



million in 1988.   We used the geometric mean of this range, $4.19



million, as our point estimate.



     Hydrocarbons also are a factor in the formation of sulfates.



In particular, S02 oxidizes faster when the amount of hydroxide



radicals in the atmosphere increases (which is, in turn, a func-



tion of the amount of HC in the  atmosphere).   However, the ability



to quantify these complex relationships has just been developed,



and experts at Systems Applications Incorporated (SAI) and EPA's



Office of Research and Development believe that the total change



in sulfates is highly dependent  upon many factors (e.g. , cloud



cover, current hydrocarbon and NOX concentrations, and oxidant



and sulfur dioxide levels) for which we have only limited data.

-------
                              IV.37





      A recent modeling analysis by SAI  (Seigneur et al. ,  1982)



indicated that a 50% reduction in HC would reduce sulfates in



urban areas by 30 to 60%.   However, because of the uncertainty



surrounding this estimate  at this time,  and the uncertainty in



interpolating this to a 2.4% change, we  did not explicitly



consider the reduction in  sulfates in this analysis.  Because



the reduction in sulfates  would generate significant economic



benefits from improved health and visibility and reduced soiling,



this omission may seriously underestimate the benefits.



IV.C.4.  Reducing Emissions of Carbon Monoxide



     Existing scientific knowledge concerning CO indicates that



health impacts are the primary concern at or near ambient levels.



Current information suggests that persons with cardiovascular



disease are most sensitive to low levels of CO.  Additional



subgroups of the population also believed to be sensitive to CO



exposure are people with chronic respiratory diseases, pregnant



women, and the elderly.  Unfortunately, clinical dose-response



functions relating low level CO exposure to particular health



effects, when estimated, have not been conclusive.  Therefore,



we have not estimated quantitatively the impact  that reduced CO



(through reduced misfueling) may have on health.  However, we



have described the  impact  that misfueling may have  on  the



distribution of  carboxyhemoglobin  (COHb) levels  for the U.S.



population.



     Probably the greatest concern  about CO exposure  is its



effect on the cardiovascular  system.  The  effect  of CO thus  far

-------
                               IV. 38






 measured  at  the  lowest  level of exposure  is  reduced exercise



 time  until the onset of  angina pectoris.  This clinical pheno-



 menon  is  a result of insufficient oxygen  supply  to the heart



 muscle and is characterized by spasmodic  chest pain, usually



 precipitated by  increased activity or stress, and relieved with



 rest.  Typically, atherosclerosis, which  causes  a narrowing of



 the arteries in  the heart (coronary heart disease), predisposes



 a person  to  attacks of angina.



     Angina  pectoris is  not believed to be associated with



 permanent anatomical damage to the heart.  Nonetheless, the



 discomfort and pain of angina can be severe, and each episode of



 angina may carry the risk of myocardial infarction (the death of



 a portion of the heart muscle).  However, epidemiological studies



 as yet have  provided inconclusive results on the association



 between CO exposure and  the incidence of myocardial infarction.



     The health effects  from exposure to CO are associated with



 the percentage of total  blood hemoglobin that is bound with CO,



 producing carboxyhemoglobin (COHb) and thereby reducing the



 oxygen-carrying capacity of the blood.  The median concentrations



 of COHb in blood are about 0.7% for nonsmokers and about 4.0% for



 smokers.   At 2.9% COHb,  at least one clinical study (Anderson et



 al., 1973) associated reduced exercise time until the onset of



 pain in patients with angina pectoris.  At 4.5% COHb, this same



 study reported an increased duration of angina attacks.



     The potential health improvements from reduced CO may be



great for two reasons.    First,  there are many people in the

-------
                              IV. 39





population believed to be sensitive.   EPA has estimated that



5.0% of the U.S. adult population  —  roughly 9.5 million people



— have definite or suspected coronary heart disease.   Of this



group, 80% have suspected or definite angina pectoris  (U.S.  EPA,



1980).  Second, the blood of many  people shows concentrations of



COHb above 2.9%, the lowest level  of  COHb where adverse effects



are indicated.   Data from the second  National Health and Nutri-



tion Examination Survey (NHANES II) indicated that for the U.S.



population over twelve, 2% of those who have never smoked, 3% of



former smokers, and 66% of current smokers exceeded 2.9% COHb at



the time of the survey (U.S. DHHS, 1982).



     Other health effects have been reported at comparable or



higher COHb levels.  For example,  several investigators have



found statistically significant decreases (3 to 7%) in work time



until exhaustion in healthy young  men with COHb levels at 2.3%



to 4.3% (Horvath et al., 1975; Drinkwater et al., 1974; Raven



et at., 1974).   At higher COHb levels (5% to 7.6% COHb and above),



investigators have reported impaired visual perception, manual



dexterity, ability to learn, and performance of complex sensor-



imotor tasks in healthy subjects.



     Finally, additional large subgroups of the population may be



particularly sensitive to exposure to CO, including individuals



with pre-existing conditions that compromise oxygen delivery to



various tissues, that enhance oxygen need, or that elevate the



sensitivity of the tissues to any oxygen imbalance.  Sensitive



groups may include:

-------
                              IV.40


     0  people with peripheral vascular diseases such as

        atherosclerosis and intermittent claudication

        (0.7 million people);

     0  people with chronic obstructive pulmonary diseases

        (17 million people);

     0  people with anemia or abnormal hemoglobin types that

        affect the oxygen-carrying capacity of the blood

        (0.1-.245 million people);

     0  people drinking alcohol or taking certain medications

        (e.g., vasoconstrictors);

     0  the. elderly;

     0  visitors to high altitudes; and

     0  fetuses and infants* (3.7 million total live births

        per year).

     A comprehensive economic estimate of the benefits from

reduced CO is not possible.  The current medical literature does

not provide a dose-response relationship between COHb levels and

specific health effects that can be valued monetarily.  However,

analysis relating changes in CO emissions to the distribution

of COHb levels in the U.S.  is possible using NHANES II.  Work

still in progress indicates that a change in ambient CO levels

may have significant impacts on the distribution of COHb.
* Animal studies showed that pregnant females exposed to CO
  reported lower birth weights, increased newborn mortality,
  and lower behavioral levels in newborn animals, even when
  no effects on the mothers were detected.  In addition,
  research has reported a possible association between
  elevated CO levels and Sudden Infant Death Syndrome
  (Hoppenbrouwers et al., 1981).

-------
                              IV.41


IV.D.  Summary of Health and Welfare Benefits

     Table IV-6 summarizes the estimates of the benefits of

reducing HC and NOX by pollutant and benefit subcategory.   The

range of $114 to $579 million in annual benefits incorporates the

estimates of both the top-down and bottom-up approaches.   The

point estimate of $377 million was derived by aggregating the best

estimates of each subcategory.

                             Table IV-6

        1988 Benefits of Reducing HC, NOX and CO Emissions
                     (millions of 1983 dollars)


Benefit Category                     Range          Point Estimate

Ozone

  Acute Health             .          $59-233            $146
  Agriculture                        $30-225            $160
  Vegetation                         $ 0- 15            $7.5
  Materials Damage                   $16- 28            $ 24
  Chronic Health                        NA                OZC

NOX

  Health and Visibility              $7.8-62             $35

Hydrocarbons

  Health                            $1.06-16.52         $4.19
  Sulfate Deposition (Health,           NA                NA
    Materials Damage, Visibility)

Carbon Monoxide

  Acute Health                          NA               CMA
                        TOTAL      $ 114-579       $ 377 +OZC +CMA

NA = Quantitative estimates not available or attempted.

CMA = Non-quantified benefit of reducing acute health effects
      from CO.

OZC = Non-quantified benefit of reducing chronic health effects
      from ozone.

-------
                               IV.42


 IV.E.  Summary of HC, CO, and  NOX Benefits

     As we noted earlier, there  is no consensus on a good, simple

 way to value the benefits of eliminating misfueling and its

 consequent excess emissions.   As a result we have used three

 different approaches:

     0  the value using the costs of alternative regulations;

     0  the value of preserving catalysts; and

     0  the value of avoiding  damage to health, vegetation, and
        materials.

 Table IV-7 summarizes the values obtained by each of these three

 methods.

     The first method computed the value of reduced emissions

 by using the cost of HC, CO, and NOX regulations that EPA is

 considering promulgating.  This revealed the low end of the range

 of values that EPA or Congress impute for controlling additional

 increments of these pollutants.

     The second method of valuation used the cost of catalytic

 converters and other emission  control equipment disabled by mis-

 fueling to approximate the benefits of eliminating misfueling.

    Finally,  the third method directly calculated some of the

 health and welfare benefits of reducing HC and NOX emissions,

 by applying the results of research that related improvements

 in air quality to improvements in human health, or reductions in

damages to materials and vegetation.

    Our health and welfare estimates are probably low because

 they do not include all the potential health and ecological

-------
                              IV.43
effects of ozone and CO.   This method of valuation is also less

certain than the other methods.  Conceptually, however, it is a

reasonable (and probably the best) way to measure the social

benefit of reducing emissions of HC, NOX, and CO.

     We used the mean of this direct estimate and the value of

preserving catalytic converters as the best estimate of the

benefits of reducing misfueling.  We obtained a value of $405

million to represent the benefit of reducing HC, NOX, and CO

emissions through the elimination of misfueling.  Note that the

different methods yielded fairly similar estimates of the

benefits.


                             Table IV--7

       Benefits in 1988 of Reducing HC, CO, and NOV Emissions
                     (millions of 1983 dollars)

Value by Next-Step   Preserving Catalytic   Improved Health and
   Regulations       	Converters	   	Welfare	

   $121 - 452                  $432             $114 - 579
                                            (point estimate: $377)

-------
                              IV. 44






                TECHNICAL APPENDIX FOR CHAPTER IV






     Accurately estimating the costs and benefits of reducing lead



in gasoline required the use of disaggregated data some of which



was not readily available.  For this reason, we developed a fairly



simple "bottom-up" model to forecast light-duty fleet size and mix,



numbers of misfuelers, and gasoline demands by various categories



of vehicles.  This technical appendix describes this model.





Overall Structure of Model and Summary of Estimates



     In general terms, the fleet model can be broken into five



major pieces:



     0  It ages the existing stock of cars (1982)  and light trucks



        (1980)  — using data from Polk, 1983 — and includes Data



        Resources, Inc. (DRI)  projections of sales from 1983 to



        1988,  to estimate  the  size and composition of the light-



        duty fleet in 1988.   Appendix Tables 1 and 2 show the



        projection of this fleet into 1988.



     0  Misfueling rates by  age  of vehicle are used to estimate



        both the number of misfueled vehicles and  those that



        would  misfuel for  the  first time in 1988  under current



        policies.   The sources of misfueling data  are surveys



        conducted by EPA's Office of Mobile  Sources.   Our analysis



        assumed that current misfueling rates would continue.



     0  The model estimates  excess emissions due  to new misfuelings



        in 1988 by aging (retiring)  the new  misfuelers over the



        subsequent 20 years  (to  2007),  calculating the expected

-------
                                     IV. 45


                               APPENDIX TAKE IV-1

                          LIGHT DUTY VEHICLE PRDOBCTIONS
                              (thousands of vehicles)
           CARS IN
          OPERATION
MODEL YR    1982
           (Polk)
1983
1984
1983
1986
                                        1987
1988
1988
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
1966





8,000
8,280
8,825
10,075
10,155
9,661
8,471
6, 190
7,498
7,629
5,989
4,243
3,581
2,822
2,208
1,609
5,220




9,200
7,992
8,255
8,723
9,838
9,927
9,429
8,099
5,790
6,836
6,725
5,098
3,521
2,910
2,282
1,789
1,306
4,176



10,500
9, 191
7,968
8, 159
8,518
9,618
9,689
9,015
7,576
5,279
6,026
5,724
4,230
2,861
2,354
1,850
1,453
1,045
3,299


1 1 , 000
10,490
9,163
7,876
7,968
8,327
9,386
9,263
8,432
6., 907
4,653
5,129
4,750
3,438
2,314
1,907
1,502
1,162
826
2,540

1 1 , 200
10,989
10,458
9,057
7,690
7,789 .
8, 127
8,974
8,665
7,688
6,088
3,961
4,256
3,860
2,781
1,875
1,549
1,201
918
636
1,905
1 1 , 600
11,189
10,956
10,337
8,844
7,518
7,602
7,770
8,395
7,900
6,777
5, 182
3,287
3,459
3, 122
2,253
1,523
1,239
949
707
477
0
1 1 , 800
1 1 , 588
11, 155
10,829
10,094
8,646
7,337
7,268
7,268
7,653
6,964
5,768
4,300
2,671
2,798
2,530
1,829
1,218
979
731
530
0
0
           110,456  111,897    114,353   117,033  119,668   121,084   123,957

-------
                               IV. 46


                          APPENDIX TABIE IV-2

                     LIGHT DUTY TRUCK PROJECTIONS*
                         (thousands of vehicles)
        LDTs IN
MlODEL OPERATION
 YEAR      1980   1981
       (Polk*.87)
1982   1983
1984
1983
1986    1987
1988
1988
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
1974
1973
1972
1971
1970
1969
1963
1967
1966



1,936
2,931
2,844
2,580
2, 139
1,494
1,976
1,927
1,608
1, 127
1,022
1,048
769
640
• 556


1,826
1,926
2,907
2,815
2,546
2,099
1,458
1,914
1,849
1,595
1,013
949
* 961
698
575
496

1,748
1,817
1,911
2,878
2,778
2,498
2,048
1,412
1,837
1,834
1,434
940
870
872
627
513
439
2,520
1,739
1,802
1,891
2,840
2,726
2,437
1,984
1,355
1,322
1,649
1,331
862
790
784
560
454
387
2,970
2,507
1,725
1,784
1,866
2,787
2,660
2,361
1,904
1,344
1,638
1,530
1,220
783
709
700
495
4O1
340
3,050
2,955
2,487
1,7O8
1,760
1,831
2,719
2,576
2,266
1,888
1,208
1,520
1,403
1, 108
703
633
618
437
352
297
3, 120
3,035
2,931
2,462
1,685
1,727
1,787
2,633
2,472
2,247
1,697
1,121
1,394
1,274
995
628
560
546
384
308
260
3,320
3, 1O4
3,010
2,902
2,429
1,654
1,685
1,731
2,527
2,452
2,020
1,575
1,028
1,265
1, 145
888
555
494
480
335
269
0
3,450
3,303
3,079
2,980
2,863
2,384
1,613
1,632
1,661
2,507
2,204
1,875
1,444
933
1,137
1,022
785
49O
434
419
293
0
0
         24,597 25,628  26,456 27,933  29,724 31,521  33,267 34,870  36,511
 * Trucks  0-8500 Ibs.

-------
                              IV.47


        excess emissions of HC, CO, and NOX in each year

        (based on both the extra grains of emissions per mile

        travelled and annual miles per vehicle by age).  It then

        discounts these emissions (at 3% rate) back to the year

        of misfueling — 1988.

     0  The model estimates gasoline demand in 1988 for four

        major categories of demand: those vehicles designed for

        and using leaded gasoline, those designed for leaded

        gasoline but switching to unleaded premium (for the octane),

        those vehicles designed for and using unleaded gasoline,

        and those misfueling with leaded gasoline.  A fifth

        category is "special" uses for heavy trucks, agricultural

        equipment, boats, etc.  We hold "special" use demand

        constant at 9.6% of total gasoline demand, the 1982 '

        percentage.

     Table 3 is a summary of the results.


                       APPENDIX TABLE IV-3

                SUMMARY OF FLEET MODEL PARAMETERS


Total # of light-duty cars and trucks in 1988:        159,644,000
Incremental # of vehicles assumed to misfuel in 1988:   2,524,000
Total # of vehicles in 1988 misfueling in all years:   19,481,000
Overall misfueling rate:                                 12.2%
Average miles per gallon for cars and trucks:            20.4
Average miles per year per cars and trucks:            11,436

Total demand for gasoline (million gal/yr):           100,737   100%
Legal light duty demand for leaded (million gal/yr):   12,485  12.4%
Misfuelers1 demand for leaded (million gal/yr):        10,290  10.2%
Demand for unleaded (million gal/yr):                  68,290  67.8%
Other legal demand for leaded (million gal/yr):         9,671   9.6%

-------
                               IV.48


Sources of Data and Major Assumptions

      We found it necessary to draw actual data  from several

different sources to estimate other important pieces of  infor-

mation.  In general, we used the  following hierarchy of  sources;

if a preferred source did not provide the data,  or did not

provide it in enough disaggregation, we turned to the next-pre-

ferred source.

                 HIERARCHY OF SOURCES OF DATA

     R.L. Polk & Co. (mostly provided in MVMA Facts & Figures)
     U.S. DOT/FHA: Highway Statistics 1982
     U.S. EPA Office of Mobile Sources: MOBILE II Documentation
     The Transportation Energy Book

These sources are all referenced  in Chapters III or IV.  In

addition, we also derived certain estimates based on the

data these sources presented.

Sensitivities of Our Projections  to Alternative  Assumptions

     Our predictions of total gasoline demand in 1988 are sen-

sitive to the average miles per year travelled by vehicles, to

the projected sales of cars and light trucks in  each year to

1988, and to the scrappage rates we used to retire portions of

each cohort in each year.   Roughly, changes in these parameters

cause proportional changes in gasoline demand.   Appendix

Table IV-4 lists the basic age-related assumptions.

     Data concerning avenge miles per vehicle per year* (MPV)

came from EPA's MOBILE II  documentation, representing about a
*  Wherever possible with data and method, we disaggregated by
   cars and light trucks (0-8500 Ibs. GVW),  and by age of vehicle

-------
                                     IV. 49

                               APPENDIX TABLE IV-4

                            GENERAL FLEET  ASSUMPTIONS
A8E

OR <
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
# OF
LDVs
13,230
14,892
14,235
13,809
12,957
1 1 , 030
8,951
8,900
8,929
10, 160
9, 168
7,643
5,745
3,604
3,934
3,552
2,615
1,708
1,413
1, 150
'/. MIS-
FUELING
IN 1 YR
5.5
1.7
1.6
1.6
1.6
1.6
1.7
1.6
1.6
1.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
CUMU- V
LATIVE
X MIS- -
FUELING
5.5
7.7
8.8
10.4
12.0
13.6
15.3
16.9
18.5
20.1
20.1
20. 1
20. 1
20. 1
20.1
20. 1
20. 1
20. 1
20. 1
20. 1
VEHICLE SURVIVAL AVG ANNUAL MILES
RATES * PER VEHICLE **

CARS
0.999
0.996
0.988
0.976
0.978
0.976
0.956
0.935
0.912
0.881
0.851
0.830
0.813
0.809
0.810
0.812
0.800
0.790
0.770
0.750

LOT
0.995
0.987
0.977
0.964
0.946
0.923
0.894
0.858
0.851
0.765
0.710
0.651
0.591
0.331
0.474
0.419
0.370
0.325
0.284
0.248

CARS
14,400
14,275
13,775
13,250
13,250
12,673
12, 175
1 1 , 650
1 1 , 075
10,575
10,050
9,473
8,975
8,450
7,875
7,375
6,850
6,275
5,775
5,000

LOT
15,676
13,276
13,692
12,223
11,001
9,992
9,238
8,488
7,913
7,413
6,929
6,510
. 6,163
5,829
5,425
5, 160
4,934
4,625
4,400
4,400
        159644
13.5
Note:  Light duty vehicles (LDVs)  includes cars  and light  duty  trucks  (LDTs)

*   First time misfuelers

**  Includes current and past misfuelers.   (Source:  U.S.  EPA Office of  Mobile
    Sources, 1983d.)

+   Source:  R.L. Polk & Co. in MVMA Facts & Figures, 1981

++   Source:  U.S. EPA Office of Mobile Sources, 1983d.

-------
                               IV. 50



 1.1%  annual growth  from  actual  1980 MPV  figures  (estimated by

 Polk  in MVMA, 1982).   In  1988,  these  figures  are about  9% greater

 than  1980 figures.  Consequently,  if  one were  to use  1980 data,

 gasoline demand would  be  8-9%  lower.

      Estimates of the  initial  number  of  cars  from each  model year

 came  from Polk, as  reported by  MVMA.  The data on light trucks

 were  acquired by the EPA  directly  from Polk,  but were adjusted

 downward by 13%, to transform  the  category from 0 to  10,000 pounds

 to 0  to 8500 pounds.   This adjustment was derived by  a  comparison

 of several different sources of data  and is used by EPA's Office

 of Air and Radiation.

     We use transitional  probabilities of survival in order to

 retire some portion of each cohort as it moved into the next age

 category.  That is, 99.6% of one year old cars live to  be two

 years old; 98.8% of two year olds  live to be  three, etc.  For

 cars, we averaged the  transitional probability of survival for

 each age group reported by Polk in MVMA for 1978-1982.  For

 light trucks,  sufficient  Polk data were not available;  instead,

 we used survival rates estimated in Kulp and Holcomb  (1982).   We


 did not use their estimates for cars because  it was derived by a

model with which we were not familiar and which used scrappage

 rates well above any observed in recent years.  We used a 7.4%
                                   4
 scrappage rate in the current analysis.   Using Kulp and Holcomb's

estimate of 10.5% would decrease gasoline demand from 100.7

billions gallons to 89 billion gallons in 1988.  In addition,

such a change  in assumptions would increase the unleaded market

share from 67.8% to 70.5%.

-------
                              IV. 51





     We used Data Resources, Inc.  (DRI) projections for sales



of cars and light trucks (TRENDLONG2008B),  as reported in U.S.



Long-Term Review (Fall, 1983).   Miles per gallon per vehicle



came from the road mileages reported in EPA's Passenger Car Fuel



Economy and were adjusted for change in fuel economy by age.



     There are several assumptions that do not influence total



demand for gasoline but do determine the split between leaded



and unleaded grades.  Most important are misfueling rates by



age of vehicle, and, in particular, the shape of this curve in



the youngest model year cohorts (i.e., model years 1985-1988).



This part of the fleet is particularly important because:



there will be more of these vehicles in 1988 than older cohorts,



these vehicles will be emitting farther into the future than



older vehicles, and, because of discounting back to the year



of misfueling, they are weighted most heavily.  We used EPA's



1982 survey of vehicle tampering for raw data, which provided



misfueling rates by age of vehicle.  We used regression analysis



to estimate the relationship between age and incremental mis-



fueling, using several specifications of form.  By far, the best



fit was a tri-linear form, with a 5.5% increase in the first



year of the cohort's existence, a 1.66% increase per year for



ages 2 to 9, and with no incremental misfueling in subsequent



years.  (In 1982, the time of the survey, vehicles with catalytic



converters had been sold for only seven years, so no data existed



on misfueling beyond the seventh year.)

-------
                              IV. 52


     Listed below are the actual 1982 survey results and the

regression estimates used in the analysis.


                       APPENDIX TABLE IV-5

                     MISFUELING RATES BY AGE
               (as percentage of model year cohort)


                            EPA                REGRESSION
        AGE             1982 SURVEY            ESTIMATES

      1  or less              5.2                    5.5
         2                  7.4                    7.2
         3                  8.1                    8.8
         4                 12.1                   10.4
         5                 12.2                   12.0
         6                 12.4                   13.6
         7                 14.5                   15.3
         8                 17.7                   16.9
         9                    NA                  18.5
        10                    NA                  20.1
        11                    NA                  20.1

-------
                              IV. 53
  METHOD FOR ESTIMATING DISCOUNTED STREAM OF AVOIDED EMISSIONS


    In estimating the discounted streams of avoided emissions,

    the following procedure was used:
1.  We assumed 87.3 million cars and 31.9 million light-duty
    trucks designed for using unleaded fuel would be on the
    road in 1988.  From the use of vehicle survival rates, it
    was estimated that approximately 82% of the total light-
    duty vehicles (cars and trucks) would be equipped with
    catalytic converters in 1988.

2.  We then estimated, from data developed by EPA, the propor-
    tion of these vehicles expected to misfuel for the first
    time in 1988.  These estimates are presented below:
Model      Total » of Vehicles*
Year     (thousands of vehicles)

1988-89         15,250
1987            14,892
1986            14,235
1985            13,809
1984            12,957
1983            11,030
1982             8,951
1981             8,900
1980             8,924
1979            10,160
First-Time**
Misfueling
  Rates

  .055
  .017
  .016
  .016
  .016
  .016
  .017
  .016
  .016
  .016
Total # of
First-Time
Misfuelers

  839
  253
  228
  221
  207
  176
  152
  142
  143
  163
* Automobile data from MVMA Facts and Figures  '83; light duty
  truck data from R.L. Polk & Co.

**No first-time misfueling was assumed for vehicles older than
  model year 1979.

-------
                               IV.54
 3.  The projected number of misfueling vehicles was multiplied
    by an estimate of the number of miles driven per vehicle in
    1988.  The average annual mileage factors were specific both
    for class* and age of vehicle.  These calculations were
    repeated for every year of the assumed 20-year life of the
    vehicle, with the fleet size being diminished annually
    according to contemporary scrappage rates.  Annual mileage
    per vehicle was adjusted according to vehicle age.  In this
    way, model year-and vehicle class-specific estimates for
    total miles driven after misfueling in 1988 were derived,
    with the final year investigated being 2007 (when the 1988
    model year fleet was assumed to be retained).  This forecast
    the mileage from each misfueled cohort in each future year.

 4.  Each future year's mileage etimates were discounted back to
    1988 at a 3% discount rate.  The total discounted mileage
    figures are shown below:

         Model
         Year           Automobiles      LDTi**       LPT2**

         1979              3.45***       1.00         0.45
         1980              4.21          0.72         0.33
         1981              4.54          0.82         0.38
         1982              5.64          0.97         0.42
         1983              7.34          1.52         0.75
         1984             10.06          2.06         0.96
         1985             12.48          2.43         1.14
         1986           ' 14.74          2.85         1.34
         1987             18.44          3.68         1.73
         1988-89          67.90         13.94         6.57

    The 1988-89 numbers are large because of the 5.2% rate of
    misfueling in the first year and because 15 months of auto
    sales are included in the last category.

 5.  Discounted future mileage was multiplied by excess emissions
    factor developed by EPA (1983d); measured in grams of pollu-
    tant per mile, (see below).  This yielded total discounted
    future emissions of conventional pollutants as a result of
    misfueling in 1988.

         Model Year        CO           NOX         HC

         1981-1988      11.07g/mi    0.71g/mi    1.57g/mi *
         1979-1980      17.65g/mi       —       2.67g/mi

6.  This result was divided by IxlO6 to calculate total metric
    tons of discounted emissions shown in Table IV-3.
*Automobiles, light duty truck between 0 and 6000 Ibs, and light
 duty trucks between 6000 and 8500 Ibs.

**LD1l = Trucks between 0 and 6000 Ibs.
  LDT2 = Trucks between 6000 and 8500 Ibs.

***A11 figures in millions of miles driven, discounted back to
   1988 (See #4).

-------
                              IV.55
               POSSIBLE BIASES IN AVOIDED EMISSIONS
A. Reasons our Emissions Estimates may be too low

0  1982 misfueling rates, based on EPA surveys, may be too low
   for reasons explained on page IV-3ff and in the 1979 EPA survey.
   Most notable is that vehicle inspections for misfueling were
   voluntary and in some areas, the rates of drivers refusing
   inspections were very high.

0  We held misfueling rates constant over time, but these rates
   may be increasing over time.

0  Vehicles are lasting longer than previously; therefore, our
   vehicle survival rates may be too low.  With longer lifetimes,
   older, dirtier, misfueled vehicles would be in operation longer,
   and the stream of excess emissions would extend farther into
   the future.  Furthermore, we retired each cohort after its
   twentieth year of operation (with about 7% remaining in the
   twentieth year).

0  If vehicles are not well-maintained, excess emissions factors
   for misfueling would be higher.


B. Reasons our Emissions Estimates may be too high

0  We assumed that pollution control equipment would be effective
   past the five-year manufacturer's warranty, for the life of
   the vehicle.  Some EPA data indicated that this was true if
   vehicles were not misfueled or tampered.

-------
                          IV. 56


                       References
Adams, R., and McCarl, B., "Assessing the Benefits of
Alternative Oxidant Standards on Agriculture:  The Role of
Response  Information," completed for U.S. EPA, September 1983.

Anderson, E., et al., "Effect of Low-Level Carbon Monoxide
Exposure  on Onset and Duration of Angina Pectoris:  A Study
on 10 Patients with ischemic Heart Disease," Annals of Internal
Medicine, 79: 46-50, 1973.

American  Petroleum Institute, Unpublished Carcinogenicity Study
on Unleaded Gasoline in Vapor in Fischer 344 Rats and B6C3F1
Mice, 1982.

Brown, C., "Equalizing Differences in the Labor Market,"
Quarterly Journal of Economics, Vol. 94, 1980.

Chock, D., et al., "Effect of NOX Emission Rates on Smog
Formation in the California South Coast Air Basin",
Environmental Science and Technology, Vol. 15, No. 8,
August 1981.

Council on Environmental Quality, Environmental Quality - 1980,
Government Printing Office, December 1980.

Crocker,  T., and Vaux, H., "Some Economic Consequences of
Ambient Oxidant Impacts on a National Forest," completed for
U.S.  EPA, Office of Policy Analysis, August 1983.

Detels, R., et al., "The UCLA Population Studies of Chronic
Obstructive Respiratory Disease," American Journal of
Epidemiology,  Vol.  109,  1979.

Drinkwater, B., et al.,  "Air Pollution,  Exercise, and Heat
Stress,"  Archives of Environmental Health, 28: 177-181,  1974.

Durand, D., Stable Chaos, Morristown, N.J. , General Learning
Corporation, 1971.

ETA Engineering,  Inc., "Assessment of Benefits from New Source
Performance Standards  for Volatile Organic Compounds," com-
pleted for U.S. EPA, Office of Policy Analysis, September 1983.

Evans, et al., "Ozone  Measurement from a Network of Remote
Sites," Journal of the Air Pollution Control Association, V61.
32, No. 4, April  1983.

Faucett Associates, Draft Report:  Review and Critique of
Previous  OMSAPC Cost-Effectiveness Analysis, March 1983.

-------
                         IV.57
Ferris, B., Jr.,  "Health Effects of Exposure to Low
Levels of Regulated Air Pollutants,"  Journal of the Air
Pollution Control Association, Vol. 28, No.  5, May 1978.

Freeman, A.M., Ill,  Air and Water Pollution Control;  A
Benefit-Cost Assessment, New York:  John Wiley and Sons, 1982.

Gerking, S.; Stanley, L. ; and Weirick, W.,  "An Economic
Analysis of Air Pollution and Health:   The  Case of St.  Louis,"
report to U.S. EPA, Office of Policy Analysis, July 1983.

Glasson, W., "Effect of Hydrocarbons and NOX on Photochemical
Smog Formation Under Simulated Transport Conditions," Journal
of the Air Pollution Control Association, Vol. 31, No.  11,
November 1981.

Goldstein, E., moderator, Photochemical Air Pollution,
interdepartmental conference sponsored by the Department of
Medicine, University of California, School  of Medicine,
Davis, California, 1982.

Hammer, D., et al., "Los Angeles Student Nurse Study.  Daily
Symptom Reporting and Photochemical Oxidants," Archives of
Environmental Health, Vol. 28, 1974.

Hasselblad, v., and Svendsgaard, D., "Reanalysis of the Los
Angeles Student Nurse Study," U.S. EPA, Health Effects
Research Lab, Research Triangle Park,  NC, August 1975.

Heck, W., et al., "A Reassessment of Crop Loss from Ozone,"
Environmental Science and Technology,  Vol.  17, No. 12,  1983.

Hoppenbrouwers, T., et al., "Seasonal  Relationships of Sudden
Infant Death Syndrome and Environmental Pollutants," American
Journal of Epidemiology, Vol. 113, No.6, 1981.

Horvath, S., et al., "Maximal Aerobic  Capacity at Different
Levels of Carboxyhemoglobin,"  Journal of Applied Physiology,
38: 300-303, 1975.

Kinosian, J., "Ozone Precursor Relationships from EKMA
Diagrams," Environmental Science and Technology, Vol. 16,  No.
12, 1982.

Kopp, R., and Vaughan, W., "Agricultural Benefits Analysis:
Alternative Ozone and Photochemical Oxidant Standards,"
Resources for the Future, June 30, 1983; and discussion
with the authors.

Lave, L., and Seskin, E., Air Pollution and Human Health,
Baltimore, Johns Hopkins University Press,  1977.

-------
                         IV.58
Lebowitz, M., et al., "The Effect of Air Pollution and
Weather on Lung Function in Exercising Children and
Adolescents," American Review of Respiratory Diseases/
Vol. 109, 1974.

Leighton, J.; Shehadi, A.; and Wolcott, R., "The Aggregate
Benefits of Air Pollution Control," prepared for U.S. EPA,
Office of Policy Analysis, by Public Interest Economics
Foundation, Washington, D.C., June 1983.

Linn, W., et al., "Human Respiratory Effects of Heavy
Exercise in Oxidant-Polluted Ambient Air,"  American Review
of Pespiratory Disease, Vol. 123, No. 4, 1981.


Lippmann, M., et al., "Effects of Ozone on the Pulmonary
Function of Children," in: Lee, S., et al., eds, The Bio-
medical Effects of Ozone and Related Photochemical Oxidants,
Princeton Scientific Publishers, Inc.; Princeton, N.J.:
Advances in Modern Environmental Toxicology, V: 423-46; 1983.

Makino, K., and Mizoguchi, I., "Symptoms Caused by
Photochemical Smog,"  Japan Journal of Public Health, Vol.
22, No. 8, 1975.

National Academy of Sciences,  Air Quality and Automobile
Emission Control, Vol. 4; prepared for The Committee on
Public Works, U.S.  Senate, U.S. Government Printing Office,
1974.

Portney, P., and Mullahy, J.,  "Ambient Ozone and Human
Health:  An Epidemiological Analysis," completed for U.S.
EPA, Office of Air Quality Planning and Standards, September
1983.

Raven,  P.  et al., "Effect of Carbon Monoxide and Peroxyace-
tylnitrate on Man's Maximal Aerobic Capacity,"  Journal of
Applied Physiology, Vol.  36, 1974.

Seigneur,  C.; Saxena, P.; and Roth, P., "Preliminary Results
of Acid Rain Modeling," Submitted at a Specialty Conference
on Atmospheric Deposition sponsored by the Air  Pollution
Control Association, November 7-10, 1982, Detroit, Michigan.

SRI International,  "An Estimate of the Nonhealth Benefits of
Meeting the Secondary National Ambient Air Quality Standards,"
a final report to the National Commission on Air Quality,
1981.

Thaler, R.,  and Rosen, S./ "The Value of Saving a Life:
Evidence from the Labor Market," in Household Production and
Consumption, ed. N. E. Terleckyj, New York,  Columbia
University Press, 1976.

-------
                         IV.59
U.S.  Department of Agriculture,  Agricultural Statistics,  1980,
Washington, D.C.,  U.S.  Government Printing Office,  1980.

U.S.  Department of Health and Human Services,  Public Health
Service, "Blood Carbon Monoxide  Levels in Persons 3-74  Years
of Age: United States,  1976-80," Advance Data, No.  76,
March 17, 1982.

U.S.  Department of Health,  Education,  and Welfare;  Public
Health Service, Vital and Health Statistics Series  10,
No. 96, "Limitations of Activity and Mobility Due to Chronic
Conditions", 1973a.

U.S.  Department of Health,  Education,  and Welfare;  Public
Health Service, Vital and Health Statistics Series  10,
No. 84, "Prevalence of Selected  Chronic Respiratory
Conditions:  United States - 1970," 1973b.

U.S.  EPA, "Response to Public Comments on EPA's Listing of
Benzene Under Section 112 and Relevant Procedures for the
Regulation of Hazardous Air Pollutants," OAQPS, forthcoming
Summer, 1984a.

U.S.  EPA, "VOC/Ozone Relationships from EKMA," memo from
Warren Freas (Air Management Technology Branch) to
Alan McGartland (Benefits Branch), January 27, 1984b.

U.S.  EPA, Draft Revised Air Quality Criteria for Ozone
and Other Photochemical Oxidants, Office of Research and
Development, 1983a.

U.S.  EPA, "The API Study and Its Possible Human Health
Implications," memo from Al Lorang (Chief, Technical Support
Staff) to Charles Gray, Jr. (Director, Emission Control
Technology Division), May 16, 1983b.

U.S.  EPA, Motor Vehicle Tampering Survey - 1982, National
Enforcement Investigations Center, Office of Enforcement,
April 1983c.

U.S.  EPA, 1982 NCLAN Annual Report, Environmental Research
Lab,  Corvallis, Oregon, 1982a.

U.S.  EPA, National Air Pollutant Emissions Estimates, 1940 -
1980, Monitoring and Data Analysis Division, January 1982b.

U.S.  EPA, Air Quality Criteria for Nitrogen Oxides, Office
of Research and Development, 1982c.

U.S.  EPA, Office of Mobile Source Air Pollution Control, The
Costs of Controlling Emissions of 1981 Model Year Automobiles,
June 1981.

-------
                         IV. 60
U.S. EPA, Regulatory Impact Analysis of the National Ambient
Air Quality Standards for Carbon Monoxide, Office of Air
Quality Planning and Standards, 1980.

U.S. EPA, Carcinogen Assessment Group, "The Carcinogen
Assessment Group's Final Report on Population Risk to Ambient
Benzene Exposure," January 10, 1979.

U.S. EPA, Air Quality Criteria for Ozone and Other Photo-
chemical Oxidants, Office of Research and Development,
April 1978.

Whittemore, A., and Korn, E. L., "Asthma and Air Pollution
in the Los Angeles Area," American Journal of Public Health,
Vol. 70, 1980.

Zagraniski, R.; Leaderer, B.;  and Stolwuk, J., "Ambient
Sulfates, Photochemical Oxidants and Acute Adverse Health
Effects: An Epidemiologic Study," Environmental Research,
Vol. 19, 1979.

-------
                           CHAPTER V



    BENEFITS OF REDUCING LEAD:  CHILDREN WITH HIGH BLOOD LEAD



     Our analysis of the health benefits of reducing lead is


presented in two parts.  This Chapter deals with the benefits

associated with reducing the number of children with blood lead

levels above 30 ug/dl.   Currently the Centers for Disease Control

(CDC) considers this level the criterion for lead toxicity when

combined with FEP levels of 50 ug/dl or more (CDC, 1978).  Chapter

VI addresses the benefits for children with blood lead below 30

ug/dl.  We have focused our analysis on children.  Although adults


experience adverse effects from lead, these effects generally

occur at higher lead levels than in children.


     Blood lead levels above 30 ug/dl are associated with adverse

cognitive effects, anemia, kidney damage, hypertension, and other


pathophysiological consequences.  Several of these effects have
         *
only been documented at blood lead levels well above 30 ug/dl.

In the next chapter, we discuss the physiological and cognitive

effects that occur below 30 ug/dl.

     It should be noted that while our discussion of reducing

lead emissions has focussed on airborne lead, airborne lead is


eventually deposited in the environment on land, water, buildings,

etc.  Children, as a class, are most at risk from all sources of

lead — inhaled or ingested.  Small children who crawl and "mouth"


objects and hands are especially likely to ingest lead.  Fetuses


and young children are more vulnerable than the population as

a whole.  The absorption and retention rates, and the partitioning

of lead in hard and soft tissues all contribute to the fact that

-------
                               V.2





children possess greater  lead body  burdens  for  a given exposure.



Children have  also been shown to  display  a  greater  sensitivity



to lead toxicity, and their inability  to  recognize  symptoms, may



make  them especially vulnerable.  In the  late 1970s  data  indi-



cated that well over 10%  of black children  had  blood lead  levels



above 30 ug/dl (Mahaffey  et al.,  1982a).



     The first section of this chapter presents the  evidence



supporting the relation of blood  lead  to  gasoline lead.   Next,



two aspects of the effects of lead  exposure that we  have  been



able  to monetize are discussed.   First, we  assessed  the costs



associated with medical treatment and  follow-up care for  the



children who experienced  elevated blood lead levels.  Second, we



considered the cognitive  and behavioral impacts of high blood



lead  levels (above 40 ug/dl) in children.  This chapter also



presents the methodology  by which we predicted  the changes in



the number of children above 30 ug/dl  (and other thresholds) as a



function of changes in the total amount of lead used in gasoline.



     The monetized benefits of reducing the number of children



with blood lead levels above 30 ug/dl fall into two categories:



1) the avoided costs of testing for and monitoring children with



elevated blood lead levels,  and medically treating children with



very elevated levels;  and 2) the costs associated with the



cognitive effects of lead exposure above 30 ug/dl.




     The benefits computed in this chapter are a linear function



of the reduction in the number of children above 30 ug/dl of blood



lead.   For each policy option,  we estimated these reductions by

-------
                               V.3






by using the techniques discussed in the statistical methodo-



logies section (V.E).  The results are shown below in Table V.I.






                             TABLE V-l



        1988 Reduction in Number of Children above 30 ug/dl






              Low-Lead Option             All Unleaded



                  43,000                     45,000






V.A.  The Relationship between Gasoline Lead and Blood Lead



     Several recent articles have shown persuasively that blood



lead levels for a given age group will fall as gasoline lead



content falls.  The first important statistical studies were



done by Billick et al. (1979), who showed a strong relationship



between the blood lead levels of several hundred thousand



children screened in New York City's lead screening program and




local gasoline lead use.  Figure 1 on the next page shows this



relationship graphically.



     In 1982, Billick presented additional regression analyses



on data from New York City's program (with data from several



additional years); a Chicago screening program (800,000 children




over more than ten years); and a Louisville, Kentucky program,




all of which confirmed his earlier results.



     A recent paper by EPA's Office of Policy Analysis (Schwartz,



Janney, and Pitcher, 1984), presented the results of a study




concerning the relationship between blood lead levels and gasoline



lead.  Three different data sets were employed for this analysis,

-------
                                v.<*



                              FIGURE 1
                rNT0's BLOOD-LEAD  LEVELS VARY
                DIRECTLY WITH LEVELS OP LEAD  IN GASOLINE
    35  -
                                       BLACK

                                     HISPANIC

                               GASOLINE LEAD
"9k 30  -
ui
Q
O
o
IU


O
£  15 -
IU
o
^     A
                                                   /
                                                     V
                                I  I  I  I  I  I  I  I  I  I  I  I  I  I  I
                                                            6.0
                                                               m
                                                               O

                                                               3

                                                            4.0 f
                                                                3.0  5
1970     1971     1972     1973     1974     1975

                 QUARTERLY SAMPLING DATE
                                                    1976

-------
                               V.5





including the second National Health and Nutrition Evaluation



Survey (NHANES II)  and the CDC lead poisoning screening program.



The statistical results indicated a highly significant regression



coefficient for gasoline lead levels which was consistent across



all of the data sets.  External estimates of environmental lead



from other sources clearly indicated that paint and other dietary



lead were not the primary sources of the.observed decline in



blood lead levels.   (An earlier paper on this subject was



presented by Schwartz at the International Conference on Heavy



Metals in the Environment (1983) in Heidelberg, West Germany.)



     Critics questioned whether the association between gasoline



lead and blood lead levels could have been due to the sequence



in which the NHANES II survey team moved from one site to the



next.  Repeated tests of the results, using variables for each



location, indicated that specific locations or geographic regions



did not confound the relationship between blood lead and gasoline



lead.  Furthermore, performing separate  regressions for urban



areas, rural areas, adults,  children, blacks, and whites indi-



cated these factors could not be substituted for gas lead to



explain the changes  in blood lead levels.



     A third study, by Annest et al. (1983) of the U.S. Public



Health Service, also used data  from the  NHANES II, finding  that



the only reasonable explanation for the  decline in blood lead



levels was the decline in the amount of  lead  in gasoline.



     Finally, the  Draft  Lead Criteria Document cited  two studies



(Fachetti and Geiss,  1982; and  Wanton,  1977) which,  by  introducing

-------
                               V.6






tetraethyl lead with a different isotope ratio into gasoline,



were able to directly measure the contribution to blood lead



levels from gasoline.  Both of these papers showed that gasoline



accounted for about 5-10 ug/dl of blood lead.





V.B.  Medical Benefits of Reducing High Blood Lead Levels



     To estimate the benefits from reduced numbers of children



with blood lead levels above 30 ug/dl, we assumed that all



children whose lead levels were elevated above this limit would



receive follow-up medical attention and/or immediate medical



treatment.  Unfortunately, however, many — perhaps even most --



children with elevated lead levels are not detected, although



their lives and health are adversely affected.  It should be



noted,  therefore, that children with blood lead levels greater



than 30 ug/dl who go untreated bear a burden which we valued



equal to the cost of follow-up and/or treatment.   Furthermore,



the dollar estimate of average medical management cost (testing



and monitoring)  assumed a prototypical method of  determining




treatment; these costs were representative of the costs associ-



ated with treatment and follow-up techniques in general use,



although the exact procedures may vary.



     We have distinguished between three basic follow-up and



treatment categories:   children with blood lead levels over 30



ug/dl but with free erythrocyte protoporphyrin (FEP) levels



below 50 ug/dl,  children in the Centers for Disease Control's

-------
                              V.7


(CDC) lead toxicity category II,  and children in CDC  categories

III and IV.*  Treatment and follow-up practices may differ for

each.

     For children with over 30 ug/dl of blood lead, given FEP

levels below 50 ug/dl, we assumed one follow-up blood test and

the associated overhead costs.  From the regression presented by

Piomelli et al. (1982) on the probability of elevated FEP versus

blood lead, we estimated that 60% of the children over 30 ug/dl

had FEP levels above 50 ug/dl.  However, Mahaffey and coworkers

(1982) cited data from the CDC screening program indicating that

75% of all screened children over 30 ug/dl of blood lead also

had FEP levels above 50 ug/dl.  Since the CDC sample was both

larger and more representative of the entire nation than that

used by Piomelli et al., we have placed slightly greater emphasis

on this result and assumed 70% of the children above 30 ug/dl

would be  classified lead toxic by CDC.  To further estimate the

fraction  of the most severely lead toxic children  in categories

III  and IV, we examined  the results of  the CDC screening program

for  1977-81.  They showed a relatively  constant 33% of all lead

toxic children were in categories III or IV; the remaining 67%
 * CDC  classifies children as  "lead  toxic"  if  they have  blood  lead
  levels above 30 ug/dl and FEP  levels above  50 ug/dl.  Children
  between  30-49 ug/dl blood lead and  50-109 ug/dl FEP are  category
  II.   Category III  is either children > 50 ug/dl blood lead  and
  <250 ug/dl FEP or  > 110 ug/dl FEP and 30-50 ug/dl  blood  lead.
  Children >50 ug/dl blood lead and >250 ug/dl FEP or children
  >70  ug/dl blood lead are category IV.

-------
                              V.8


must, therefore, have been in category II.*  Therefore, for all

children with blood lead levels above 30 ug/dl, 30% have FEP

levels below 50 ug/dl, 47% are in category II, and 23% are in

CDC's categories III and IV.

     We assumed that children in category II would receive six

regularly scheduled blood tests, and that about half of these

children would also have a county sanitarian visit their homes to

evaluate possible sources of lead exposure.  (The CDC screening

program data indicated that 65% of the homes of all lead toxic

children were visited.  Assuming all category III and IV children

had home visits, this suggested a 50% rate for category II.)

     We also assumed,  per the CDC's recommendations, that

detailed medical histories,  physical examinations, and an assess-

ment of nutritional status would be performed by a physician.

For children in categories III and IV, we assumed a three-day

hospital stay for testing,  and that a county sanitarian would
* The quarterly prevalence data for the percent of all lead toxic
  children who were category III or IV are:

  Year     1st Quarter   2nd Quarter   3rd Quarter  4th Quarter
1977
1978
1979
1980
1981
32%
31%
30%
29%
30%
32%
32%
33%
34%
33%
34%
35%
37%
38%

31%
31%
34%
35%

  (source:   Morbidity and Mortality Weekly Reports)

  Approximately 7,000 children per quarter were found to be lead
  toxic.   Note that the percent in categories III and IV was
  highest in the 3rd quarter (July, August and September) when
  gasoline lead emissions are highest.

-------
                               V.9





inspect their homes.  On the basis of CDC recommendations, it was



assumed these children would have six monthly follow-up blood tests



after discharge, and another six quarterly follow-ups.  Finally, we



assumed the children in these severely afflicted categories would



receive a neurological examination, and that one-third of them would



undergo provocative ethylenediaminetetraacetic acid (EDTA) testing



and chelation therapy to remove lead from the the body.



     EPA has estimated the cost of blood tests to be $30.  We



assumed (1) a one-time administrative overhead charge of $50 for



every child who entered the system, (2) a physician's cost of $50



per visit, and (3) a home inspection by a county sanitarian cost



of $60, including overhead.  We have used 1982 hospital costs per



adjusted inpatient day from the Department of Health and Human



Services publication Hospital Statistics (1983).  Having regressed



the trend in these costs since 1972 against the GNP deflator, we



obtained an average rate of increase in real costs and projected



costs per day in 1988 (including lab tests, etc.) to be $425 (in



1983 dollars).  For each of the major hospitalization stages,



physician's costs of $250 have been estimated, including a neuro-



logical work-up.  Using these figures we estimated the average



medical costs for children over 30 ug/dl to be $950 per child.



     Table V-2 shows the medical cost savings of reducing the



number of children over 30 ug/dl.  Because we have not estimated



welfare losses (such as work time lost by parents), the adverse



health effects of chelation (such as the removal of helpful



minerals), or such non-quantifiables as the pain from the

-------
                              V.10


treatment, our estimate of the benefits of reduced treatment is

conservative.  As mentioned above, we have taken these medical

costs as a measure of avoidable damage for all the incremental

cases of lead toxicity, whether detected or not.

                          TABLE V-2

                 Medical Cost Savings in 1988
                        (1983 dollars)

                   Low-Lead       All Unleaded

                 $41 million      $43 million


     Our analysis has assumed 30 ug/dl as the criterion for

defining when a child is at risk for undue lead exposure or toxi-

city and may require pediatric care.  (This is the criterion now

used by CDC, in conjunction with elevated FEP levels.)  If that

criterion is lowered, greater numbers of children would receive

medical management, thereby increasing the medical expense savings

from lowering blood lead levels.  This is not an unlikely event,

as the Draft Lead Criteria Document (1983) indicated:

        "If, for example,  blood lead levels of 40-50 ug/dl in
    "asymptomatic" children are associated with chelatable lead
    burdens which overlap  those encountered in frank pediatric
    plumbism, as documented in one series of lead exposed children,
    then there is no margin of safety at these blood levels for
    severe effects which are not at all a matter of controversy.
    Were it both logistically feasible to do so on a large scale
    and were the use of chelants free of health risk to the
    subjects, serial provocative chelation testing would appear
    to be the better indicator of exposure and risk.   Failing
    this, the only prudent alternative is the use of a large
    safety factor applied  to blood lead which would translate to
    an "acceptable" chelatable burden.  It is likely that this
    blood lead value would lie well below the currently accepted
    upper limit of 30 ug/dl,  since the safety factor would have
    to be large enough to  protect against frank plumbism as well
    as more subtle health  effects seen with non-overt lead
    intoxication." (Chapter 13, p.  15) (emphasis added)

-------
                               V.ll





For example,  the estimated number of children whose blood lead



levels would  be expected to drop from above 25 ug/dl to below



this figure as a result of an all unleaded gasoline scenario in



1988 is 150,000, over three times the figure of 45,000 used in



the present analysis, derived from a criterion of 30 ug/dl blood



lead.





V.C.  Cognitive and Behavioral Effects



     Many studies have noted neurological effects in children



with elevated blood lead levels.  De la Burde and Choate's results



(1972, 1975)  have been summarized by the Draft Lead Criteria



Document as showing persisting neurobehavioral deficits at blood



lead levels of 40-60 ug/dl.  In the 1975 study, seven times as



many high lead children were found to have repeated grades in



school or were referred to school psychologists as low lead



control children.  The control children were drawn from the same



clinic population and were matched for age, sex, race, parent's



socioeconomic status, housing density, mother's IQ, number of



children below six in the family, presence of father in the



family, and mother working.



     Although the children examined  in the work of de la Burde



and Choate included some with blood  lead levels between 30 and



40 ug/dl, the issue of whether  the cognitive deficits occurred



at those levels was not clear from the results.  Several addi-



tional studies cited  in the Draft Criteria Document, as well  as



a recent work by Odenbro et al.  (1983), indicated  a significant



association between these blood  lead levels and neurological/

-------
                               V. 12





cognitive effects in children:  Needleman et al. , 1979; McBride



et al. , 1982; Yule et al., 1981; Yule et al., 1983; Smith et



al., 1983; Yule and Lansdown, 1983; Harvey et al., 1983; and



Winneke et al., 1982, to name some recent work.   All of these



studies generally support these results, even though individually



the probability of a false positive was not always less than 5%



and the possibility of uncontrolled covariates existed.  Neverthe-



less, despite the difficulties with the specific studies, the



combined weight of the evidence showed that cognitive deficits



occured at blood lead levels over 30 ug/dl, with the work of



de la Burde and Choate indicating that the most serious damage



may be associated with blood lead levels over 40 ug/dl.  (A more



detailed analysis of the studies is presented in Section VI.E.)






V.D.  Estimating Avoided Costs of Compensatory Education



     The evidence for cognitive effects of lead in children



above 30 ug/dl is fairly strong, and the studies by de la Burde



and Choate gave direct evidence of poorer classroom performance



by children with higher lead levels, particularly those over



40 ug/dl.   It also showed that the cognitive effects remained



three years later.



     To value avoiding such cognitive effects, we could posit



that children involuntarily exposed to enough lead to make them



seven times more likely to be forced to repeat a grade should



be given enough supplementary educational assistance to bring



their school performance back to what it otherwise would have



been.  Therefore, we could use the cost of such compensatory



education as a proxy for the avoided cost.

-------
                              V.13


     Of course, it is probably impossible to completely restore

these high lead children's performance.   Therefore,  lifetime

work and production may be affected.   However, tutoring, reading

teachers, school psychologists, and the like can help improve

their achievement in school.

     Given the finding of at least a three year persistence in

the cognitive effects of lead, we assumed that the cost of

correcting these cognitive effects would be at least three years

of compensatory education.  We judged that de la Burde and

Choate's exposed population corresponded to children in CDC's

categories III and IV, as well as some category II children.

From January 1977 until mid-1981, one-third of the children

identified by the CDC screening program as being lead toxic

(over 30 ug/dl blood lead and  50 ug/dl FEP) were in CDC cate-

gories III and IV, the more severe categories of lead toxicity.

From this we estimated that one-third of the  children above

30 ug/dl would fall  in the  category of those  severely enough

affected to need  compensatory  education to recover their

previously expected  performance levels.  Children with  lower

internal lead/FEP  levels  were  assumed not  to  need this

education.  Therefore, an average  of one year of compensatory

education would  be required per child with blood levels over

30 ug/dl to compensate for  the deficits.*
 * We  assumed  that  the  number of person-years  of  compensatory
  education divided  by the  number  of  children would  be  about
  one.   In other words,  if  one-third  of  these children  require
  three  years of compensatory education,  there is  an average
  of  one year of education  for each of  the  children.

-------
                              V.14


     As a rough approximation of the expense of such compensa-

tion, we have used the cost of part time special education for

children who remain in regular classrooms.  The staff of the

Department of Education's Office of Special Education Programs

(OSEP) felt this level of effort was appropriate for these

children.  According to a report written for OSEP (Kakalik et

al. , 1981), a child needing this form of compensatory education

incurred additional costs of 93,064 per year in 1978 dollars,

or $4,290 in 1983 dollars (using the GNP deflator).   This

figure was quite close to Provenzano's (1980)  estimate of the

special education costs for non-retarded lead exposed children.

We applied these costs to our estimate of the number of children

who would fall below 30 ug/dl in order to obtain the values in

Table V-3.**


                            TABLE V-3

               Benefits of Reduced Cognitive Losses
                          (1983 dollars)


                   Low-Lead             All Unleaded

                 $184 million           $193 million
**We have not assumed that all these children would be classi-
  fied as having learning disabilities, but rather that they
  would all perform worse than they would have otherwise.
  Thus, compensatory education costs were used as a proxy for
  the cost of restoring their cognitive functioning.

-------
                             V.15



V.E.  Statistical Metholodogies


     In this section we present the regression results and


forecast procedures that underlie the estimates of the changes


in the number of children at risk of elevated blood lead levels


used in this and the subsequent chapter.   First, however, we


review the evidence of a relationship between blood lead levels


and the amount of lead in gasoline.  Following this, we describe


the data base used for our regression work and the regression


results.  Finally, there is a discussion of our forecasting


procedures and a consideration of the implications of forecast-

                   •
ing prevalence rather than incidence.



V.E.I.  The NHANES II Data


     The data base for the regressions  used to estimate the


coefficients in our prediction models was  the health and demo-


graphic information collected  in  the NHANES II survey.  The U.S.


Bureau of the Census selected  the NHANES II sample according  to


rigorous specifications  from the  National  Center  for Health


Statistics so that the probability  of selection  for each person


in  the sample could be determined.   The survey used subjects


selected according to a  random multi-stage sampling scheme,


designed to utilize the  variance  minimization  features  of  a


stratified random  sample.  A total  of 27,801  persons  from  64


sampling areas were chosen as  representative  of  the U.S.  non-


institutionalized  civilian population,  aged  six  months  through


74  years.  Of those 27,801 persons, 16,563 were  asked  to  provide

-------
                              V.16


blood samples, including all children six months through six

years and half of those between seven through 74 years.  The

non-respondent rate for blood samples was 39% and did not

correlate with race, sex, annual family income, or degree of

urbanization.*  A study of the potential non-response biases

indicated that this was not a significant problem (Forthofer,

1983).

     Lead concentrations in the blood of sampled persons and

control groups were determined by atomic absorption spectro-

photoroetry using a modified Delves Cup micro-method.  Specimens

were analyzed in duplicate with the average of the two measure-

ments being used for the statistical analysis.  Bench quality

control samples were inserted and measured two to four times in

each analytical run to calibrate the system.  In addition, at

least one blind quality control sample was incorporated with

each twenty NHANES II blood samples.  No temporal trend was

evident in the blind quality control measurements.

     The NHANES II data did, however, display a marked relation-

ship between blood lead and gasoline lead, as is shown in Figures

2 and 3.  A similar pattern existed between average blood lead

levels for black children in Chicago and lead use in local Chicago

gasoline during the same period.   This is evident in Figure 4.
* Because children were less likely to respond, they were double
  sampled, and 51% of the children did not provide blood for lead
  determinations in the NHANES II data set.  The weights used to
  adjust the data to the national population accounted for both
  the oversampling and under-response of the children.

-------
•-3
O
•-3
f

B
O
W

O
ra
I
  110
100
 90
80
  70
•d
W
JO
H
O

0 60
o
o
o
ft
o
3
tn
50
        LEAD USED  IN  GASOLINE PRODUCTION AND

        AVERAGE NHANES II  BLOOD  LEAD  LEVELS

                 (FEB.  1976 -  FEB,  1980)
                   LEAD USED IN

                      GASOLINE
       AVERAGE

       BLOOD

       LEAD LEVELS
        1976
                1977
                            1978
1979
1980
                                                      .
                 h16 £


                    I
                    M

                  4 C V
                 -|D f
                    O
                    O
                    o
                                                          5
                                                          f
                                                          W
                                                      -13
                                                      -12
                                                          U)
                                                        3
                                                        »-••
                                                        o
                                                        n
                                                        o
                                                          (0
                                                        (D

                                                        O
                                                      ^-10
                                                       g
                                                     r
                       e


                       (D



                       K>

-------
O
UJ
DC
O
      AVERAGE NHANES  II BLOOD LEAD LEVELS VS.

           LEAD  USED IN GASOLINE  PRODUCTION
  17-
OL


gl.
  «r
  15-
  12-
y 11 -

o
o

3 10-
QB '

UJ
O
   8
                                                               
-------
AVERAGE BLOOD LEAD LEVELS FOR BLACK CHILDREN IN CHICAGO
              AND GASOLINE LEAD IN CHICAGO
                                                  BILLIONS
                                                  OF GRAMS
                                                  Legend

                                               ,1 D BLOOD LEAD

                                                 A GASLEAD
                                                                   
-------
                               V.20


V.E.2.  Reduction in Number of Children Below Critical Thresholds

     The NHANES II data was used to estimate both linear

regressions relating blood lead to gas lead and the percentage

of children who would be expected to have blood leads above

various thresholds.

     To estimate these percentages, logistic regressions were

performed separately for white and black children to see how

the odds of having blood lead levels above a 30 ug/dl threshold

varied with gasoline lead.  These regressions were performed on

data from individual children.  The dependent variable was the

natural log of the odds of being above the threshold while the

independent variables were various demographic factors* and

gasoline lead.  The  original selection of demographic factors

for consideration was based on linear regressions on individual

blood lead levels, discussed in detail in the paper by Schwartz,

Janney, and Pitcher  (1983).**
 * The demographic variables were selected by backwards stepwise
   elimination.   We also used a procedure that maximized R2 for
   any given number of variables and a procedure that minimized
   the difference between cp and the number of independent vari-
   ables.   They  produced the same model as backwards elimination,

** The regressions were all performed on individual data using
   the SAS procedure SURREGR to estimate the coefficients.
   SURREGR is a  special procedure designed to estimate the
   variances in  regressions using clustered stratified samples.
   Demographic control variables were eliminated by backwards
   stepwise elimination until all the remaining variables were
   significant at the 95% confidence level.  See Schwartz,
   Pitcher, and  Janney (1983) for further detail.

-------
                              V.21





     To predict how the number of children above each threshold



would change as the amount of lead in gasoline was reduced, a



mechanism was needed to forecast the distribution of blood lead



as a function of gasoline lead.  In this analysis, we assumed



that the distribution of blood lead would remain log-normal as



gasoline lead levels declined.  Then estimates of the mean and



variance of the associated (transformed) normal distribution



could be used to determine the percentage of the population



above any blood lead level.



     The estimates of the mean and standard deviation of the



underlying normal distribution were derived from logistic



regression estimates of the percentage of children with blood



lead levels above 30 ug/dl and SURREGR estimates of the mean



of the log-normal distribution.



     If the distribution X is normal with mean u and standard



deviation s (X:N (u,s)), then Y = exp X  is log-normal with a



mean of a and a standard deviation of b  where



     a = exp  (u + 1/2 s2) and b = exp (2u + s2)  (exp (s2)  -1).



Further, if eg and vg are percentiles of the log-normal and  its



corresponding normal distribution, we have eg = exp  (u + vg  s).



We used the logistic regressions  to estimate eg  in equation  (2)



and fche SURREGR regressions to estimate  a in equation  (1)  which



yielded





                        (1)    a =  exp  (u  + 1/2 s2)



                        (2)    eg  = exp (u + vg s).

-------
                               V.22
Solving these equations for u and s produced a quadratic equation
                 0 = (In (e ) - In (a)) - v  s + .5s2
which had the solution s = -v  _+  ^vq^ ~ 2 ^n ^e' ~ *n ^a^ "*•
Then u = ln(a) - 1/2 s2.  Only the smaller root yielded sensible
values for u and s.  Using the estimated values for u and s, we
determined percentages of the distribution above 10, 15, 20, and
30 ug/dl by looking up the results of (In (10) - u)/s etc., in
the normal table.
     We chose to use a logistic equation to estimate the percent-
age of children over 30 ug/dl to control for problems of multiple
sources of exposure.  If we had simply used the regressions
explaining the mean and assumed a constant standard deviation,
we would have predicted that removing lead from gasoline would
have resulted in there being no children above 30 ug/dl.  This
seemed unreasonable since paint, food, and water are known alter-
nate sources of lead, and are sometimes associated with high
blood lead levels.
     Because of the sensitivity of the blood lead distribution to
age, we estimated separate distributions for each two-year age
interval.   The tabulated changes in the number of children above
various thresholds represented the sum of distributions for each
age category.  The regression results are shown in Appendix 1.
     For children from six months to seven years of age, we used
logistic regressions for the percent above 30 ug/dl blood lead.
For children aged eight to thirteen we used logistic regressions
for the percent above 20 ug/dl blood lead because there were too
few observations above 30 ug/dl for the logistic procedure to work

-------
                               V.23


     Because our figures included only children under age

thirteen and no adults, these results significantly under-

estimated the benefits from reduced lead levels in the entire

population.  To make our predictions, we used our projections of

lead used each year under the various scenarios.  These are

shown on Table V-4 below:


                          TABLE V-4

          Estimated Lead Used for Gasoline in 1988*
                     (metric tons per day)


       Base Case         Low-Le^d         All Unleaded

          97.6             6.1                  0
*Computed using gasoline demand in Table ll-.l and assuming
 1.1 g/gal, 0.1 g/gal, and 0 g/gal.
     From this, we could also predict changes in mean blood

lead levels.  These are shown in Table V-5 below.


                            TABLE V-5

             Changes in Mean Blood Lead for 1988**
          for Black and White Children aged 5 or less
                   (micrograms per deciliter)


      Base Case    	Low-Lead              All Unleaded
                 Incremental  Projected  Incremental  Projected
               4   Decline      Level      Decline      Level

White   7.93        1.93        6.00          2.13         5.80
Black  14.31        1.72       12.59          1.89       12.42
**Derived using gasoline  lead values  in Table V-4  and
  regressions in Appendix  I.

-------
                              V.24





     To compute the number of children above the various



thresholds in 1988, we needed estimates of the population at



different ages.  These were produced by linearly interpolating



the Bureau of the Census population projections (mid-range



forecast) for 1985 and 1990 and are shown in Table V-6.





                           TABLE V-6



                  1988 Population Projections*





             Ages              Blacks          Whites



      1/2 year - 7 years      4,573,000      23,259,000



      8 years - 13 years      3,797,000      16,528,000





       *Bureau of the Census, 1982





     These results also tend to underestimate the extent of the



problem because the NHANES II survey, upon which our model was



based, omitted children under six months of age.  This was



especially significant because we are learning that the damage



to this infant population from elevated blood lead levels may be



more severe than that of older children.





V.E.3.  Incidence Versus Prevalence



     Our predicted decreases in the number of children above a



given threshold were for a specific point in time; our costs were



for an entire year.  If children remain above 30 ug/dl for less



than a year,  there will be more children above 30 ug/dl in a



year than we  estimated and our benefits will be understated.

-------
                              V.25





Conversely, if children remain above 30 ug/dl for more than a



year, these cases may be counted twice and we will overstate



benefits.



     This raised the difficult epidemiological issue of prevalence



versus incidence.  Prevalence means the percent of people who have



the condition of interest at a particular time, e.g., the number



(or percent) of people with the flu on February 14.  Incidence



is the number (or percent) of people who develop new cases of



the flu in a given time period, e.g., the month of February.



Prevalence is the integral of the incidence of cases times



their duration, or prevalence is approximately incidence times



average duration.



     This issue became important because the NHANES II survey,



upon which we based our regressions, measured the prevalence of



cases above 30 ug/dl blood lead or other thresholds rather than



the incidence.  Yet the benefits we wanted to estimate may in



fact be reduced numbers of cases in a time period, i.e.,



inc idence.



     Clearly an excursion of a child's blood lead level above



30 ug/dl  for a day or  two will produce less damage than a pro-



longed elevation.  However, data indicate that such occurrences



are not very likely.   Odenbro et al.  (1983) found fairly stable



blood lead levels in individual children with high levels  in



Chicago.  For these children, levels  remained high for more  than



a  few days, usually for months or years.  However, if  the  average



elevation of blood lead was six months,  the actual number  of

-------
                               V.26





 children affected  in a year would be  twice  the average prevalence



 for  the year.  This obviously would affect  our benefit estimates.



     Because we only valued cognitive  losses  for  children in



 CDC  categories III and IV, and because data from  Odenbro et al.



 suggested that such children's blood  lead levels  remained ele-



 vated  for a long time unless treated,  we believe  our prevalence



 estimate is reasonable for estimating  cognitive effects.  Medical



 management costs, on the other hand,  seem more reasonably



 associated with incidence.



     In any case,  it was necessary to  determine the duration of



 effects.  To do this we looked at several available pieces of



 information.  They all suggested that  the average duration' was



 less than one year, so that our estimate of prevalence (based



 on the NHANES data) understated annual incidence.



     As our first source we looked at  the CDC screening program.



 This program screened approximately 100-125,000 children per



 quarter of the year to detect lead toxicity.  Approximately



 6-7,000 cases were found each quarter.  This established the



 general prevalence of lead toxicity in the screening population.



 However, this prevalence rate showed strong within-year variation,



 with levels much higher in the third quarter,  summer (when gaso-



 line consumption was also highest).   This intra-year variation



 suggested that the average duration was not so long that the



effects of quarterly changes in exposure were swamped by previous



cases.

-------
                             V.27


     We have also used the CDC lead screening data in another way.

CDC reported quarterly the number of children under pediatric

management, which included all the new cases discovered during

that quarter plus the children remaining under pediatric manage-

ment who had been discovered with lead toxicity in the previous

quarters.  We compared that number to the sum of the cases

detected in the same quarter plus the previous two quarters and

found the results were quite close.  This suggested that children

remained under pediatric management for an average of three

quarters.  However, children were generally followed for several

visits after their blood levels returned to normal to .ensure  that

the decline was real.  This implied that the average duration

of blood lead levels above 30 ug/dl was even shorter, closer  to

two quarters.  If this is true, then it is possible that we have

underestimated the number of cases of children above 30 ug/dl

by as much as a factor of two.

     The amount of time it takes  for lead toxicity percentages to

respond  to fluctuations in gasoline lead levels also may help to

determine  the duration of lead toxicity.  If this time was rela-

tively short (e.g., a few months  or less), it is unlikely that

duration would extend beyond a year.  For lead toxicity to last

a year or  more, one would expect  lead toxicity levels to be
                                      *
relatively insensitive to intra-annual variation  in gasoline  lead.

     Two other data sets supported the conclusion of  a  short  lag

between  gasoline  lead and blood  lead  levels.  First,  in the

NHANES II  data, we examined both  the  lag structure of blood  lead

-------
                               V.28





relationship to gasoline lead, and whether any seasonal dummy



variables were significant in explaining the large observed



seasonal variations in blood lead.  Schwartz, Janney, and Pitcher



(1983) found that the lag structure of average blood lead levels'



dependence on gasoline lead extended about three months.



     In addition, Billick (1982) examined the results of the



screening programs for lead toxicity in Chicago (800,000 children



screened) and in New York (450,000 children screened) over a ten



year period and found a strong seasonal pattern in the number of



children with lead toxicity.  This pattern followed the seasonal



variation of gasoline use.  When Schwartz and coworkers analyzed



this data in a logistic regression, gasoline explained the



cyclical variation in blood lead levels, with no seasonal



variable obtaining a p-value of better than 0.38.



     All of this suggested that the average time a child spent



above 30 ug/dl was short enough so that quarterly prevalence rates



corresponded well to quarterly exposure incidence.  Therefore, our



estimate of the number of children above 30 ug/dl during 1988 is



low, as is our estimate of avoided medical expenses.





V.E.4.  Assessing the Accuracy of our Forecasting Procedures



     The NHANES II data we used to estimate the regressions in our



forecasting model corresponded with a range of gasoline lead usage



from 193 to 550 metric tons per day.  The options we are consider-



ing have gasoline lead usage rates of 97.6, 6.1, and 0 metric



tons per day, values which are below the range associated with

-------
                               V.29





the NHANES II data set.   An obvious concern was the applica-



bility of results gathered from NHANES II data to the policy



options under consideration.



     To examine the hypothesis that the gasoline lead coefficient



changed at lower gasoline lead values, we regressed blood lead



levels for white children for just the last two years of the



NHANES II period.  (During this time period both blood and gaso-



line lead levels were lowest.)  The gasoline lead coefficient



changed by 3%, which was not significantly different from that



derived for the full period.  For blacks, the small sample size



did not allow separate estimates for different periods.  While



there is no reason to believe that the functional form of the



dependence was different for blacks and whites, we used an alter-



nate procedure that did not require a reduction in sample size



to check the linearity of blood lead's dependence on gasoline



lead for blacks.



     The log of blood lead was regressed against age,  income,



sex, and degree of urbanization, and against the log of gasoline



lead.  This produced a model  in which blood lead was a function



of gas lead to some power B, where B was the coefficient of  log



(gaslead) in the  regression.  We performed this regression  to



estimate the power law of blood lead's relation to gasoline.



     Had we just  regressed  log (blood lead) on  log  (gaslead),



we would have artificially  forced  blood  lead  to be  zero when



gasoline lead was  zero.  While studies of  the  bones  of ancient



Nubians  indicated  that prehistoric  lead  levels  were  essentially

-------
                                V.30





 trivial,  studies  of  remote populations today (e.g.,  in the



 Himalayas)  suggested that general  environmental  contamination



 produced  3-5  ug/dl blood  lead  levels  in the  absence  of any gaso-



 line  or  local industrial  emissions (Piomelli et  al.f 1980).



      Since  background  levels  in the United States  were likely



 to  be higher  than those of remote  populations, we  tested  models



 with  intercepts ranging from  6  to  10  ug/dl.   They  yielded



 exponents ranging from 0.82 to  1.08 for the  dependence of black



 children's  blood lead  levels on gasoline  lead.   The  model with



 the highest R2 had an  intercept of 8  ug/dl and an  exponent of



 0.98.  The  fact that the  exponent  values  which fit the data  best



 were  very close to unity  implied that  blood  lead is  equal to



 (gaslead)l — i.e.,  the relationship  was  linear.



      Finally, we tested a  model where  blood  lead was related to



 the square root of gasoline lead,  and  it  did  not fit as well as



 the linear model.  We believe,  therefore, that the assumption



 that  blood lead levels in  black children  are  a linear  function



 of gasoline lead is  reasonable.





 V.F.  Conclusion



     We have monetized two health  related effects  of  reducing



 the amount of lead in gasoline.  The projected benefits



 estimated from these two effects alone are presented  in Table



V-7.

-------
                               V.31


                            TABLE V-7

              Monetized Benefits of Reduced Numbers
           of Children Above 30 ug/dl Blood Lead Level
                    (millions of 1983 dollars)


                  Low-Lead           All Unleaded

                $225 million        $236 million


     There are additional effects that we have  not monetized

which have also been associated with blood lead levels  above

30 ug/dl.


     0  we have not estimated the value of adverse effects in

        adults or infants under six months.  As we mentioned

        above, new data has indicated that fetuses and  newborn

        infants may be most vulnerable to lead  effects.

     0  Non-neurological effects such as kidney damage, anemia,

        and other medical problems have not been assessed.

     0  Behavioral problems have not been addressed.

         (These can adversely alter attention span or

        take more overt forms such as serious behavioral

        abnormalities, perhaps affecting the education

        of other children in the classroom.)

     0  Finally, we mentioned certain non-quantifiable

        problems earlier such as the pain associated

        with some medical procedures, lost work  (and

         leisure) time by family members, and the potential

         long-term social costs  from  the lower employment

-------
                       V.32





potential of individuals whose learning



abilities have been impaired.  As a result,



the health benefits presented in Table V-7



are likely to be much less than the real



cost to society.

-------
                             V.33
               TECHNICAL APPENDIX TO CHAPTER V


     In addition to the regressions shown  in Schwartz,  Janney,

and Pitcher  (1983), we have used the regressions presented  in

this appendix for our forecasts.  We used  the following variables

in these regressions:
Variable Name

Gaslead


Poor

Age 1


Age 2


Age 3


Age 4


Age 5


Age 6


Age 7


Income 1


Income 2


Teen
              Description
Lead used in gasoline, in hundreds of
of tons/day, lagged one month

1 if Income 1 (see below); 0 otherwise

1 if age j> 6 months and < 2 years;
0 otherwise

1 if age >^ 2 years and <_ 3 years;
0 otherwise

1 if age J> 4 years and £ 5 years;
0 otherwise

1 if age >_ 6 years and £ 7 years;
0 otherwise

1 if age _>. 8 years and <_ 9 years;
0 otherwise

1 if age _> 10 years and £ 11 years;
0 otherwise

1 if age _> 12 years and <^ 13 years;
0 otherwise

1 if family income < $6,000;
0 otherwise

1 if family income < $15,000 and >
$6,000; 0 otherwise

1 if age >^ 14 years and < 18 years;
0 otherwise
Male
1 if gender is male; 0 if female

-------
                               V.34
Variable Name

Teen Male


Adult Male


Small City


Rural


Drinker


Heavy Drinker
Northeast, Midwest,
South

Education
              Description
1 if gender is male and age _>. 14 years;
and < 18; 0 otherwise

1 if gender is male and age _>. I9 years;
0 otherwise

1 if residence is in city with population
£ 1,000,000; 0 otherwise

1 if residence is a rural area as defined
by the Bureau of the Census; 0 otherwise

1 if alcohol consumption is _> 1 drink/
week and £ 6 drinks/week; 0 otherwise

1 if alcohol consumption is _> 1 drink/
day; 0 otherwise

Are regions of the country as defined
by the Bureau of the Census.

Is 0 if the person never completed grade
school; 1 if grade school was the highest
level completed; 2 if high school was the
highest level completed; and 3 if college
was completed.
Kid
1 if age < 6 ; 0 otherwise

-------
Intercept
Gaslead
Poor
Age 1
Age 2
Age 3
-6.9468
0.8633
0.9815
1.1404
1.1938
0.5428
1.2656
0.2452
0.2803
0.6246
0.5696
0.5728
                               V.35


                    Logistic Regression Results*


Black children = under 8 years old, 479 observations

Dependent variable:  1 if blood lead is over 30 ug/dl; 0 otherwise

  Model Chi square = 39.63 with 5 D.F.

Variable       Beta       Std. Error       Chi square         P

                                              30.13         0.0000

                                              12.40         0.0004

                                              12.26         0.0005

                                               3.33         0.0679

                                               4.39         0.0361

                                               0.90         0.3433

Fraction of concordant pairs of predicted probabilities
and responses = 0.718


White children = under 8 years old, 2225 observations

Dependent variable:  1 if blood lead is over 30 ug/dl; 0 otherwise

  Model Chi square = 33.58 with 5 D.F.

Variable       Beta       Std. Error       Chi square         p

                                              43.93         0.0000

                                               8.59         0.0034

                                              17.21         0.0000

                                               3.23         0.0724

                                               5.36         0.0206

                                               2.31         0.1285

Fraction of concordant pairs of predicted probabilities and
responses = 0.637
Intercept
Gaslead
Poor
Age 1
Age 2
Age 3
-8.1667
0.6331
1.2174
1.4332
1.7168
1.1405
1.2322
0.2160
0.2935
0.7978
0.7415
0.7503
*All  logistic regression results were  run  using  PROC  LOGISTIC
 within the Statistical Analysis System  (SAS).   This  procedure
 uses  individual data where  the dependent  variable  is one  if
 the  individual is above the threshold,  and  zero otherwise.

-------
                               V.36


Black Preteens = 8-13 years old, 112 observations

Dependent variable:  1 if blood lead is over 20 ug/dl;  0 otherwise

  Model Chi square = 6.42 with 4 D.F.


Variable       Beta       Std. Error       Chi square         P
Intercept
Gaslead
Poor
Age 5
Age 6
-6.0148
0.9786
0.2356
0.6158
0.2397
2.4044
0.4943
0.5289
0.6304
0.6208
                                               6.26         0.0124

                                               3.92         0.0477

                                               0.20         0.6560

                                               0.95  '       0.3286

                                               0.15         0.6994

Fraction of concordant pairs of predicted probabilities
and responses = 0.656


White Preteens = 8-13 years old, 660 observations

Dependent variable:  1 if blood lead is over 20 ug/dl;  0 otherwise

  Model chi-square = 21.35 with 4 D.F.


Variable       Beta       Std. Error     Chi square
Intercept
Gaslead
Poor
Age 5
Age 6
-8.9395
1.0674
0.8355
1.4199
1.2041
1.6782
0.3374
0.4883
0.5810
0.5904
28.38
10. 01*
2.93
5.97
4.16
0.0000
0.0016
0.0871
0.0145
0.0414
Fraction of concordant pairs of predicted probabilities
and responses = 0.710

-------
                               V.37
                    SURREGR Regression Results
Whites:  children 6 months to 7 years
Dependent variable: indiv
Variable
Intercept
Gaslead
Income 1
Income 2
Age 1
Age 2
Age 3
Age 4
Teen
Male
Teen male
Adult male
Small City
Rural
Drinker
Heavy Drinker
Northeast
Midwest
South
Education level
Beta
5.4436
2.1835
0.7675
0.3381
3.2352
4.0452
3.2020
2.1818
-0.7386
0.5763
1.7556
3.9812
-0.8490
-1.3215
0.8582
2.0871
-1.0908
-1.2243
-1.0598
-0.9440
idual blood lead levels
Std. Error
1.1842
0.0345
0.0553
0.0288
0.2015
0.1713
0.1267
0.2118
0.0519
0.1040
0.2150
0.1203
0.1080
0.1188
0.0296
0.0889
0.1302
0.1631
0.2493
0.0182
F-Statistic
—
138.19
10.65
3.97
51.95
95.51
80.91
22.48
10.52
3.19
14.34
131.72
6.67
14.70
24.84
48.97
9.14
9.19
4.51
48.90
P
—
0.0000
0.0026
0.0548
0.0000
0.0000
0.0000
0.0000
0.0028
0.0834
0.0006
0.0000
0.0146
0.0006
0.0000
0.0000
0.0049
0.0048
0.0416
0.0000

-------
                               V.38
Whites;  6 months to 13 years
Dependent variable: ind
Variable
Intercept
Gaslead
Income 1
Income 2
Kid
Teen male
Rural
Small City
Teen
Male
Adult male
Age 4
Age 5
Age 6 '
Age 7
Drinker
Heavy Drinker
Northeast
Midwest
South
Education level
Beta
5.4593
2.1821
0.7542
0.3386
3.2344
2.0860
-1.3350
-0.8443
-1.5987
1. 1333
3.4231
1.8952
0.5581
0.4784
0.3958
0.8672
2.0789
-1.0823
-1.2414
-1.0619
-0.9461
ividual blood
Std. Error
1.1766
0.0344
0.0559
0.0284
0.0926
0.2093
0.1221
0.1098
0.0910
0.0348
0.0504
0.2205
0.1126
0.1629
0.0727
0.0303
0.0894
0.1312
0.1663
0.2504
0.1808
lead levels
F-Statistic
—
138.53
10.17
4.04
112.97
20.79
14.59
6.49
28.08
36.90
232.33
16.29
2.77
1.41
2.15
24.92
48.35
8.92
9.27
4.50
49.51

P
—

0.0000
0.0032
0.0531
0.0000
0.0001
0.0006
0.0159
0.0000
0.0000
0.0003
0.1060
0.2445
0.1520
0.0000
0.0000
0.0054
0.0046
0.0417
0.0000

-------
                               V.39
Blacks;  6 months to 7 years
Dependent variable: indiv
Variable
Intercept
Gaslead
Income 1
Income 2
Age 1
Age 2
Age 3
Age 4
Teen
Male
Adult male
Drinker
Heavy drinker
Education level
Beta
4.8847
1.9342
1.1457
1.0941
6.1030
8.8867
6.6989'
4.8920
0.6352
1.8280
4.2469
1.0359
1.4088
-0.8329
idual blood lead levels
Std. Error
2.4116
0.1432
0.2593
0.2902
1.3729
0.5052
0.4592
0.7706
0.1869
0.3413
0.6157
0.4713
1.2531
0.0874
F-Statistic
--
26.12
5.06
4.13
27.13
156.32
97.73
31.06
2.16
9.79
29.29
2.28
1.58
7.93
P
—
0.0000
0.0328
0.0522
0.0000
0.0000
0.0000
0.0000
0.1533
0.0042
0.0000
0.1429
0.2190
0.0090

-------
                            V.40
Blacks;  6 months to 13 years
Dependent variable: ind
Variable
Intercept
Gaslead
Income 1
Income 2
Kid
Teen
Male
Adult male
Age 4
Age 5
Age 6
Age 7
Drinker
Heavy Drinker
Northeast
Midwest
South
Education level
Beta
4.795
2.041
1.016
1.063
7.204
-0.806
1.860
4.061
4.869
2.494
2.215
0.417
1.063
. 1.386
-1.460
0.145
-0.1173
-0.826
ividual blood
Std. Error
2.48
0.12
0.26
0.33
0.29
0.35
0.24
0.48
0.81
1.10
0.44
0.59
0.44
1.17
0.84
1.05
0.501
0.086
lead levels
F-Statistic
—
33.84
3.90
3.44
180.91
1.84
14.39
34.08
29.22
5.67
.11.07
0.30
3.03
1.64
2.53
0.02
0.03
7.91

P
—
0.0000
0.0587
0.0748
0.0000
0.1857
0.0008
0.0000
0.0000
0.0246
0.0025
0.5910
0.0933
0.2117
0.1230
0.8885
0.8695
0.0091

-------
                               V.41


                          REFERENCES


Annest, J.L.; Pirkle, J.L.; Makuc, D.;  Neese, J.W.,;
     Bayse, D.D.; Kovar ,  M.G. (1983) Chronological trend in
     blood lead levels between 1976 and 1980.  (Boston) New
     England Journal of Medicine.   308: 1373-1377.

Billick, I.H. (1982) Prediction of pediatric blood lead levels
     from gasoline consumption (submitted to docket for public
     hearing on lead phase-down proposed rule making, April 15).
     Available from:  U.S. Environmental Protection Agency,
     Central Docket Section, Washington, DC; docket no. A-81-36;
     document number IVA.4.

Billick, I.H.; Curran, A.S.; Shier, D.R. (1979) Analysis of
     pediatric blood lead  levels in New York City for 1970-1976.
     Environmental Health  Perspect.  31: 183-190.

De la Burde, B.; Choate, M.S., Jr. (1972) Does asymptomatic
     lead exposure in children have latent sequelae?
     J. Pediatrics (St. Louis) 81:  1088-1091.

De la Burde, B.; Choate, M.S., Jr. (1975) Early asymptomatic
     lead exposure and development at school age.
     J. Pediatrics (St. Louis) 87:  638-642.

Fachetti, S.; Geiss, F. (1982) Isotopic lead experiment:
     status report.  Luxembourg:  Commission of the European
     Communities; Publication no.   EUR 8352 EN.

Forthofer, R.N. (1983) Investigation of nonresponse bias in
     NHANES II.  American  Journal  of Epidemiology (Baltimore)
     117: 507-515.

Harvey, P.; Hamlin, M.; Kumar R. (1983) The Birmingham blood
     lead study.  Presented at:  annual conference of the
     British Psychological Society, symposium on lead and
     health.  Available for inspection at:   U.S.  Environmental
     Protection Agency, Environmental Criteria and Assessment
     Office, Research Triangle Park, NC.

Kakalik, J.s. et al. (1981) The Cost of Special Education, Rand
     Corporation (Report No. N-1792-ED).

Mahaffey, K.R.; Annest, J.L.; Roberts,  J.;  Murphy, M.S. (1982)
     National estimates of blood lead levels: United States,
     1976-1980:  association with  selected demographic and
     socioeconomic factors, New England Journal of Medicine
     307: 573-579.

-------
                               V.42
Manton, W.I. (1977) Sources of lead in blood:  identification
     by stable isotopes.  Archives of Environmental Health
     32: 149-159.

McBride, W.G.,; Black, B.P.; English, B.J.  (1982)  Blood lead
     levels and behaviour of 400 preschool  children.  Medical
     Journal Aust. 2: 26-29.

Needleman, H.L.;  Gunnoe, C.; Leviton, A; Reed, R.;  Peresie,  H.;
     Maher, C.; Barrett, P. (1979) Deficits in psychological
     and classroom performance of children  with elevated dentine
     lead levels.  New England Journal of Medicine  300: 689-695.

Odenbro, A.; Greenberg, N.; Vroegh, K.; Bedreka, J.; Kihlstrom,
     J.E.  (1983) Functional disturbances in lead-exposed
     children.   Ambio 12: 40-44.

Piomelli, S.;  Corash, L.; Corash, M.B.; Seaman, C.; Mushak,  P.;
     Glover, B.;  Padgett, R. (1980) Blood lead concentrations in
     a remote Himalayan population.  Science 210:  1135-1137.

Piomelli, S.;  Seaman, C.; Zullow, D.; Curran, A.;  Davidow, B.
     (1982) Threshold for lead damage to heme synthesis in urban
     children.   Proc. Natl. Acad. Sci. U.S.A. 79:  3335-3339.

Provenzano, G.  (1980) The social cost of excessive  lead exposure
     during childhood.  In: Low Level Lead  Exposure,
     H.L. Needleman, editor. Raven Press, New York.

Schwartz, J.D.; Pitcher, H.; Janney,  A. (1983) The  relationship
     between gasoline lead and blood  lead.   (submitted for
     publication)

Smith, M.; Delves, T.; Lansdown, R.;  Clayton, B.;  Graham, P.
     (1983) The effects of lead exposure on urban children:  the
     Institute of Child Health/Southhampton study.   London,
     United Kingdom:  Department of the Environment.

U.S. Department of Commerce, Bureau of the  Census (1982)
     Projections  of the population of the United States, 1982 to
     2050.  Current Population Reports series P-25, No. 922.

U.S. Department of Health and Human Services (1983) Hospital
     Statistics.

U.S. Environmental Protection Agency  (1983) Review  Draft Air
     Quality Criteria for Lead, Volumes III and IV  (Research
     Triangle Park, North Carolina).

-------
                               V.43
Winneke, G. ;  Hrdina, K-G.;  Brockhaus,  A.  (1982)  Neuropsychological
     studies  in children with elevated tooth-lead concentrations.
     Part I:  Pilot study.  Int. Arch. Occup. Environ.  Health 51:
     169-183.

Yule, W.; Lansdown, R.  (1983) Lead and children's development,
     recent findings.  Presented at:  International conference:
     management and control of heavy metals in the environment;
     September; Heidelberg, West Germany.

Yule, W.; Lansdown, P.; Millar, I.B.;  Urbanowicz, M.A.  (1981)
     The relationship between blood lead concentrations,
     intelligence and attainment in a school population:  a
     pilot study.  Dev. Med. Child Neurol. 23:  567-576.

Yule, W.; Urbanowicz, M.A.; Lansdown,  R. ; Millar, I.  (1983)
     Teachers' ratings of children's behaviour in relation to
     blood lead levels.  Br. Journal Development Psychol (in
     press).

-------
                             CHAPTER VI
                BENEFITS  OF  REDUCING LEAD:   CHILDREN
                      WITH MODERATE BLOOD LEAD
      In  this  chapter,  we  discuss .the  known pathophysiological

effects  of  lead  that may  occur  in  children below 30 ug/dl of

blood  lead.   As  noted  in  the  introduction to Chapter  V,  we

focused  our analysis on children because, on the whole,  they .

-are more sensitive  and vulnerable  to  lead than adults.   We discuss

the hematological and  neurological effects in particular, as well

as the expected  change.in the number  of children at potential risk

of those effects under our policy  alternatives.

      Our benefit estimates present only changes  in the  numbers

of children at risk of these  .effects;  we have not associated any

dollar values with  reducing exposures.   Although no monetary

estimate of adverse effects is  provided, the social costs (to

the individuals  affected  and  society  as a whole) associated with

even  low blood lead levels is probably  substantial.

      The scientific literature  presents evidence of a continuum

of biological effects  associated with lead across a broad range

of exposure.  Even  at  low exposure levels, the Draft  Lead Criteria

Document (EPA, 1983) found that:

      biochemical changes,  e.g., disruption of certain enzymatic
      activities  involved  in heme biosynthesis and erythropoietic
      pyrimidine metabolism, are detectable.   With increasingilead
      exposure, there are  sequentially more pronounced effects  on
      heme synthesis and a broadening  of lead effects  to  additional
      biochemical and physiological mechanisms in various  tissues,
     such that increasingly more severe disruption of the normal
      functioning of many  different organ systems becomes  apparent.
      In  addition to impairment  of  heme  biosynthesis,  signs ofi
      disruption of  normal functioning of the erythropoietic and
      nervous systems are  among  the earliest  effects observed in
      response to increasing lead exposure.  At increasingly higher

-------
                              VI. 2
     exposure levels, more severe disruption of the erythropoietic
     affected so as to result in the manifestation of renal effects,
     disruption of reproductive functions, impairment of  immuno-
     logical functions, and many other biological effects.  At
     sufficiently high levels of exposure, the damage to  the
     nervous system and other effects can be severe enough to
     result in death or, in some cases of non-fatal lead  poisoning,
     long-lasting sequelae such as permanent mental retardation.
     (Draft Lead Criteria Document, 1983, Chapter 12, pages 1-2)

While the hematopoietic, nervous, and renal systems are generally

considered to be the most sensitive to lead, lead has a significant

impact on reproductive and developmental processes as well.

     Table VI-1 presents blood lead levels from the Second

NationaJ Health and Nutrition Evaluation Survey (NHANES II).

                          TABLE VI-1
                   BLOOD LEAD LEVELS OF PERSONS
      Aged 6 Months - 74 Years in the United States 1976-80*
                      (percent.in each cell)
                   <10 ug/dl

                       22.1%
                       12.2%
                       27.6%
                       21.2%
All Races
all ages
6 months-5 years
6-17 years
18-74 years

White
all ages            23.3%
6 months-5 years    14.5%
6-17 years          30.4%
18-74 years         21.9%

Black

all ages             4.0%
6 months-5 years     2.7%
6-17 years           8.0%
18-74 years          2.3%
10-19
ug/dl

62.9%
63.3%
64.8%
62.3%
                                62.8%
                                67.5%
                                63.4%
                                62.3%
                                59.6%
                                48.8%
                                69.9%
                                56.4%
20-29
ug/dl

13.0%
20.5%
 7.1%
14.3%
         12.2%
         16.1%
          5.8%
         13.7%
         31.0%
         35.1%
         21.1%
         34.9%
30-39
ug/dl

 1.6%
 3.5%
 0.5%
 1.8%
         1.5%
         1.8%
         0.4%
         1.8%
         4.1%
        11.1%
         1.0%
         4.5%
40-69
ug/dl

 0.3%
 0.4%
 0.0%
 0.3%
         0.3%
         0.2%
         0.0%
         0.4%
         1.3%
         2.4%
         0.0%
         1.8%
*Table 1 Advance Data #79 May 12, 1982, from Vital and Health
 Statistics , National Center for Health Statistics (Supplemental
 Exhibit 4.)  NOTE: These results were produced after adjusting
 the data for age, race, sex, income, degree of urbanization,
 probability of selection, and non-response to the NHANES survey.

-------
                              VI.3


VI.A. Pathophysiological Effects

     Pathophysiological effects are found at blood lead levels

well below 30 ug/dl, particularly in children.  There is evidence

that blood lead levels under 30 ug/dl result in:

     1. Inhibition of pyrimidine-51-nucleotidase (PY-5-N) and
        delta-aminolevulinic acid dehydrase (ALA-D) activity,
        which appears to begin at 10 ug/dl of blood lead (Angle
        et al., 1982).  Hernberg and Nikkanen (1970) found 50%
        of ALA-D inhibited at about 16 ug/dl.

     2. Elevated levels of zinc protoporphyrin  (ZPP or FEP) in
        erythrocytes (red blood cells) at about 15 ug/dl.  This
        probably indicates a general interference in heme
        synthesis throughout the body, including interference
        in the functioning of mitochondria (Piomelli et al.,
        1977).

     3. Changes in the electrophysiological functioning of the
        nervous system.  This includes changes  in slow-wave EEC
        patterns (Otto et al., 1981, 1982) which begin to occur
        at about 15 ug/dl, and which appear to  persist over a
        two-year period.  Also, the relative amplitude of syn-
        chronized EEC between left and right lobe shows effects
        starting at about 15 ug/dl (Benignus et al., 1981).
        Finally, there is a significant negative correlation
        between blood lead and nerve conduction velocity from
        about 15 ug/dl on (Landrigen et al., 1976).

     4. Inhibition of globin synthesis, which begins to appear
        at approximately 20 ug/dl (White and Harvey, 1972;
        Dresner et al., 1982).

     5. Increased levels of aminolevulinic acid (ALA) in blood
        and soft tissue, which appear to occur  at about 15 ug/dl
        and may occur at lower levels (Draft Lead Criteria Docu-
        ment, p 13-34; Meredith et al., 1978).  Several studies
        indicated that increases of ALA in the  brain interfered
        with the gamma-aminobutyric acid (GABA) neurotransmitter
        system in several ways (Draft Criteria  Document, p 12-32).

     6. Inhibition of vitamin D pathways, which has been detected
        as low as 10 to 15 ug/dl (Rosen et al., 1980, 1981; Mahaffey
        et al., 19825).  Further, as blood lead levels increased,
        the inhibition became increasingly severe, and the lead
        absorption rate was enhanced.

-------
                             VI.4



These levels approximate the lowest observed effect levels to


date and do not necessarily represent the affirmative findings


of a threshold.


     The types of specific effects listed above as occurring at


blood lead levels below 30 ug/dl indicate (a) a generalized lead


impact on erythrocytic pyrimidine metabolism, (b) a generalized


lead-induced inhibition of heme synthesis,  (c) lead-induced


interference with vitamin D production, and  (d) lead-induced


perturbations in central and peripheral nervous system functioning


The medical significance of such effects is  not yet fully under-
                   6-

stood.  But current knowledge regarding the  deleterious nature


of such effects and the vital nature of the  affected physiological


functions both individually and in the aggregate, suffices to


warrant both public health concern and efforts to minimize their


occurrence due to lead exposure.  Drawing on material in Chapter
     '*

12 of the Draft Lead Criteria Document, we discuss the potential


consequences of these findings below.


     Heme, in addition to being part of hemoglobin, is the obli-


gatory prosthetic group for diverse hemoproteins in all tissues,


both neural and non-neural.  Hemoproteins play important roles


in generalized functions such as cellular energetics, as well as


in more specific functions such as oxygen transport and detoxifi-


cation of toxic foreign substances (e.g., drug detoxification in


the liver).  Available data (on elevated ALA and FEP levels,


inhibited ALA-D, etc.) show clear and significant inhibition


in the heme biosynthetic pathway at low blood lead levels, with

-------
                            VI.5





statistically significant effects detectable at 10-15 ug/dl.



This heme biosynthetic disturbance may result  in the  impairment



of many normal physiological processes and/or  the  reduced  reserve



capacity of many cells or organs to deal with  other types  of



stress (e.g., infectious diseases).



     The best known effect of lead on erythrocytic pyrimidine



metabolism is the pronounced inhibition of PY-5-N  activity.  This



enzyme figures in the maturation of erythrocytes as well as



erythrocyte function and survival; it controls  the degradation



and removal of nucleic acid from the maturing  cell (reticulocyte),



As noted earlier, the disruption of this function  by  lead  has



been noted at levels of exposure beginning at  10 ug/dl.  At blood



lead levels of 30-40 ug/dl, this disturbance is sufficient to



materially contribute to red blood cell lysis  (destruction) and,



possibly, decreased hemoglobin production contributing  to  anemia



(Draft Lead Criteria Document, p 12-27f).



     Another serious consequence of lead exposure  is  the impair-



ment of the biosynthesis of the active vitamin D metabolite,



1,25(OH)2 vitamin D, which is detectable at blood  lead  levels



of 10-15 ug/dl.  Interference with vitamin D production disrupts



calcium, zinc, and phosphorous homeostasis, partially resulting



in the reduced absorption of these elements from the  gastro-



intestinal tract.  This alters the availability of these elements



for physiological processes crucial to the normal  functioning of



many tissues, cell membranes, and organ systems.

-------
                             VI.6



     The reduced uptake and utilization of calcium has two



compounding consequences.   There is interference with calcium-



dependent processes that are essential to the functioning of



nerve cells, endocrine cells, muscle cells (including those in



the heart and other components of the cardiovascular system),



bone cells, and most other types of cells.  The second concern



is possible increased lead absorption resulting from decreased



calcium availability.  The latter can create a feedback response



further exacerbating the vitamin D production inhibition, reduced



calcium availability, and consequently even greater lead absorp-



tion and greater vulnerability "to increasingly more severe lead-



induced health effects (Draft Lead Criteria Document, p 10-32f).



These effects are especially dangerous for young (preschool age)



children who are developing rapidly.  These children, even in



the absence of lead, generally are deficient in calcium because



of the large amount of calcium used for the formation of the



skeletal system as well as several other calcium-dependent



physiological processes important in young children.



     The negative correlation between blood lead and serum 1,25-



(OH)2D, the active form of vitamin D, appears to be an example



of lead's disruption of mitochondrial activity at low concentra-



tions.  While serum levels of 1,25-(OH)2 vitamin D decreased



continuously as blood lead levels increased from an apparent



threshold of 10-15 ug/dl, this was not true for its precursor,



25-(OH) vitamin D.  In fact, in lead intoxicated children after



chelation therapy, vitamin D levels were restored, but the precursor



levels remained unchanged.  This indicated that lead may inhibit

-------
                             VI.7






renal 1-hydroxylase, the enzyme that converts the precursor to



vitamin D.  Renal 1-hydroxylase is a mitochondrial enzyme system,



which is mediated by the hemoprotein cytochrome P-450.  This



suggests that the damage to the mitochondrial systems detected




at 15 ug/dl has uncompensated consequences.



     If cytochrome  P-450 is being  inhibited at the low  levels



that the reduced renal 1-hydroxylase activity suggests, we must



consider the possibility that other physiological functions



related to cytochrome P-450 may also be disrupted.   In  particular,



reduced P-450 content has  been correlated  with impaired activity



of the  liver detoxifying enzymes,  aniline  hydroxylase and  amino-



pyrine  demethylase, which  help to  detoxify medications, hormones,




and other chemicals.



     While cytochrome P-450  inhibition -has been  found  in  animals,



and in  humans at higher lead  levels, this  damage  has  not  yet  been



detected  in children at low  blood  lead  levels  (i.e.,  10 to 15



ug/dl).  The disruption of vitamin D biosynthetic pathways  at



these  levels is suggestive of  an  effect.



     The elevation  of ALA  levels  is another  indication  of  lead's



interference in mitochondrial  functioning.  In vitro studies  have



shown  that ALA can  interfere  with several  physiological processes



involved  in  the GABA-ergic neurotransmitter  system,  including a



possible  role  as,  a  GABA-agonist.   There appears  to  be no  thres-



hold concentration  for  ALA at the neuronal synapse  below  which



presynaptic  inhibition  of  GABA release  ceases.   We  do not know



at  what blood  lead  level  detectable interference with brain

-------
                             VI.8


functions by ALA begins in-vivo, nor the level at which  the

neural interference becomes "critical".  However, since  ALA passes

the blood brain barrier and is taken up by brain tissue,  it

seems likely that elevated ALA levels  in the blood correspond  to

elevated ALA levels in the brain (Moore and Meredith,  1976).

Lead in the brain is likely to enhance brain ALA concentrations

because neurons are rich in mitochondria, the subcellular site

of ALA production.  Blood ALA elevations begin to be detectable

at 15 ug/dl of blood lead.  Since ALA  is a neurotoxin, the poten-

tial implications for brain function are disturbing.   The fact

that EEC patterns also begin to change at this blood lead level

is an additional source of concern.

     In addition to the effects of lead on the brain and central

nervous sysem, there is evidence that peripheral nerves  are

affected as well.  Silbergeld and Adle (1978) have noted lead-
   V
induced blockage of neurotransmitter (acetylcholine) release in

peripheral nerves, a result of lead's disruption of the  transport

of calcium across cellular membranes.  The Draft Criteria Document

notes:

     ...(lead causes]  a blockade of calcium binding to the
     synaptosomal membrane reducing calcium-dependent  choline
     uptake and subsequent release of acetylcholine from the
     nerve terminal.  Calcium efflux from neurons is mediated by
     the membrane (Na*, K+)-ATPase via an exchange process with
     sodium.  Inhibition of the enzyme by lead/ as also  occurs
     with the erythroctye...., increases the concentration of
     calcium within nerve endings (Goddard and Robinson,  1976).
     As seen from the data of Pounds et al. (1982a), lead can
     also elicit retention of calcium in neural cells  by easy
     entry into the cell and by directly affecting the deep
     calcium compartment within the cell, of which the mito-
     chondrion is a major component.  (Section 12.2.3)

-------
                              VI.9



This disruption of cellular calcium transport may also contribute


to the effects of lead on peripheral nerve conduction velocity.


Landrigan et al. (1976) have noted a significant correlation


between blood lead and decreasing conduction velocity in children


in a smelter community.  This effect may indicate advancing


peripheral neuropathy.



VLB.  Hematological Effects of Lead


     High levels of blood lead are known to produce anemia.


Previously it was an unresolved question whether blood lead


below 30 ug/dl increased the risk of anemia in children.  We


addressed this question in two ways.  First, we examined the


relationship between blood lead levels and various measures of


anemia, and the inhibition of heme synthesis as evidenced by


elevated free erythrocyte protoporphyrin (FEP) levels.  Second,


because FEP is a more stable indicator of a person's lead


exposure over several months than a single blood lead determi-


nation, we also analyzed the relationship between elevated FEP


levels and anemia.  We found that blood lead and FEP levels were


associated with increased risks of anemia in children, even


below 30 ug/dl of blood lead.


     For this analysis we again used data from the NHANES II

                           •-:'!
survey.  Among the hematological information collected was mean


corpuscular volume (MCV), mean corpuscular hemoglobin (MCH),


serum iron, hematocrit, FEP, and percent transferrin saturation.


We used regression analysis of these data for 1,967 children


under the age of eight to determine whether there was a relation-


ship between blood lead levels and the presence of hematological


abnormalities .

-------
                             VI.10






VI.B.I.  Effects on Blood Cell Volume and Hemoglobin Content



     We found that blood lead was inversely related to both mean



cell volume (MCV) and mean cell hemoglobin (MCH), even for blood



lead levels below those currently considered to be safe.



     Linear regressions were performed of MCV and MCH on blood



lead levels in children, controlling for race, age, income, and



iron status (i.e., the level of iron in their blood).  Income



was found not to be a significant confounding variable once we



controlled for iron status, and was dropped from the analysis.



Race also had no bearing on MCV once iron status was ^controlled



for, although it was a significant explanatory variable for MCH.



This suggested that there may be additional dietary or biochemical



factors predisposing black children to lower erythrocyte hemoglo-



bin levels.  As previous work led us to expect, percent transfer-



rin saturation was a superior control for iron status compared



to serum iron and was used throughout our analysis.



     The regressions for both MCV and MCH found blood lead to be



a significant explanatory variable (p < .0001 and .0033, respec-



tively) for the decreases in each.



     Because small decreases in MCV and MCH are of unknown sig-



nificance, we also analyzed the probability of children having



abnormally low MCV or MCH levels as a function of blood lead,



since this is a clearer sign of physiological derangement.  For



this analysis we used logistic regressions.   Once again, blood



lead was a significant explanatory factor both in mean cell volume



being low (MCV < 80 femptoliters [fl],  p < .0001), and in mean

-------
                             VI. 11






cell volume being seriously low (MCV < 74 fl, p < .0001).  Blood



lead levels were also significantly associated (p < .023) with



the percent of children having MCH less than 25 pico grains (pg),



but only for children under six.



     To test the hypothesis that the relationship with MCV held



at low blood lead levels as well as high blood lead levels, we



repeated the regression for abnormal MCV using only those children



whose blood lead levels were less than 25 ug/dl.  The regression



coefficient for blood lead was unchanged and significant



(p < .014).  Thus, blood lead levels under 25 ug/dl were associated



with increased risks of microcytic anemia.



     To further investigate the relationship between lead and



abnormal hematological variables, we used our regression to



predict the percentage of children with MCV < 74 fl as a function



of blood lead for two cases:  children with average transferrin



saturation levels (22.4% saturated for children  in the NHANES II



survey) and children with transferrin saturation levels  one



standard deviation below average  (13.6%).  The results are shown



in Figure VI-1.  Note that at 25  ug/dl of blood  lead almost 10%



of the children with average iron levels and 17% of children



with below average iron levels had MCVs of less  than 74  fl.



     The relative risk of children having MCV levels less than



74 fl when their blood lead levels were 25 ug/dl compared to  10




ug/dl was 1.98  (the 95% confidence interval was  1.44-2.71).



Using the same  10 ug/dl reference point, the relative risk at 20



ug/dl was 1.53  (1.27-1.95 at 95%).  Since logistic regressions

-------
                            VI. 12
                          Figure VI-1

PERCENT OF CHILDREN WITH  MCV BELOW 74
                (Age 6 Months to 8 Years)
   25
  20
   15
 .c
 (J
 o
 o
   10
    0
                   With Transferrin Saturation
              One Standard Deviation Below Average
                                    With Average
                                  Transferrin Saturation
10
15
20
25
30
35
                    Blood Lead Level (/ig/dl)

-------
                             VI.13

gave the same results when we used only children with blood lead
levels under 25 ug/dl, and since the 95% confidence limits on the
relative risk did not include 1.0, these results showed  increased
risks of hematological abnormalities in children at blood  lead
levels of 20 ug/dl and below.

Vi.B.2.  The Relationship Between Blood Lead and FEP
     The increased interference of lead in  the  formation of hemo-
globin, and  consequent accretion of  protoporphyrins  in  red blood
cells, has been well  documented by Piomelli et  al.  (1982). Our
analysis of  the NHANES II data  confirmed  that study's  results.
Annest and Mahaffey  have  recently analyzed  the  relationship bet-
ween  FEP levels and  blood  lead  in the  NHANES  II data  and found  a
strong relationship  after  controlling  for iron  status.   (The
authors  have not  yet published  these findings.)  We also analyzed
the  NHANES  II  data  and  found that,  even after controlling for iron
status  using transferrin  saturation, the  relationship was very
strong.
      A  considerable body  of literature exists suggesting  that FEP
 levels  are  exponentially  related  to blood lead levels (Piomelli
 et al.,  1973;  Kammholz  et al.,  1972; Sassa et al., 1973;  Lamola
 et al.,  1975a,b;  Roels  et al.,  1976).   To test this relationship,
 we tested  several alternative specifications.  We considered a
 linear model, we examined a model where FEP was proportional to
 both exp(Blood lead) and exp(Percent transferrin saturation),  a
 model where FEP was proportional to exp(Blood  lead) and  (Trans-
 ferrin saturation)6, and a model where FEP was proportional  to

-------
                               VI.14





 (Blood lead)81 and  (Transferrin saturation)B2.   The model  that



 that fit best was exp(Blood lead)  times  (Transferrin saturation)6.



 We examined the possibility of different additive  intercepts  in



 this model and found the highest correlation  coefficient and



 F-statistic for a zero additive constant.  This  model suggested



 the relationship:   FEP = 36.73 (Transferrin saturation) -0.11684



 exp(0.01183 Blood lead).*



     While others have found sex differences  in  the response  of



 FEP to blood lead, sex was not a significant  variable in any  of



 our models for children.  This was probably a result of the fact



 that the sex difference in the response of FEP to  blood lead  is



smaller in children.  We also suspect that the differences  in



 adults are due predominantly to sex differences  in iron status,



 which we controlled for directly.



     We also investigated the relationship between the probability



 of elevated FEP levels and blood lead, and verified previous



 findings.  Again using NHANES II data, we performed logistic



 regressions on the probability of  FEP levels  being above 50 ug/dl



 as a function of blood lead, using both blood lead and log(blood



 lead) as the independent variable, and obtaining a better  fit with



blood lead.  The 50 ug/dl FEP level is considered  to indicate



severe enough interference with heme processes that medical



attention is usually required even when not coupled with elevated



 blood lead levels.



     Again, we checked to see whether the relationship between the



 risk of elevated FEP and blood lead held at lower  blood lead  levels,
  Transferrin saturation is expressed in tenths of a percent.

-------
                               VI.15





repeating the regression only for children with blood lead levels



under 30 ug/dl.  Using maximum likelihood analysis, blood lead was



again extremely significant (p < .0001).  The coefficient of blood



lead for the low group was .178 _+ .04 compared to  .175 +_ .018 for



the regression with all blood lead levels, a trivial difference



between the two cases.  This indicated that the risk of seriously



elevated FEP levels was strongly related to blood  lead, even at



blood lead levels well below the currently defined safety level.



     Piomelli and coworkers1 studies have suggested a threshold



for lead-induced increases in FEP levels of about  15 ug/dl.  Taking



17.5 ug/dl of blood lead as our reference level, our regression   0



predicted that the relative risk of FEP levels over 50 ug/dl was



1.55 (1.42-1.70 at 95%) at 20 ug/dl of blood lead, and was 3.73



(2.55-4.89 at 95%) at 25 ug/dl of blood lead.  This was true



across all transferrin saturation levels.





VLB.3.  The Relationship Between FEP Levels and Anemia




     Since the average lifetime of erythrocytes is approximately



120 days, a single blood lead level measured concurrently with



hematocrit levels, MCV, and MCH cannot adequately  evaluate the role



of lead in the impairment of red cell production.  Such a single



measurement is a poor proxy for the blood lead levels over the



previous 120 days, as these levels may not have beeqrconstant.



By contrast, FEP, once created, remains in red cells for their



lifetime. .While FEP levels are affected by iron status as well



as blood lead, using iron status as an independent variable



along with FEP restricts FEP to principally being  a surrogate for

-------
                               VI.16



average blood lead levels when studying its association with


anemia.  Because FEP levels are exponentially associated with


blood levels, log(FEP) was used as a proxy for lead exposure over


the relevant period.


     We analyzed the relationship between log(FEP) and hematocrit,


hemoglobin, and MCV.  We performed linear regressions on all three


outcomes as a function of log(FEP), controlling for race, age, and


transferrin saturation.  These analyses showed that log(FEP) was


strongly inversely related (p < .0001 in all cases) to hematocrit


levels, hemoglobin levels, and MCV.  We then performed logistic


regressions on the probability of abnormal levels of hematocrit,


hemoglobin, and MCV as a function of log(FEP), with the same controls,


They also showed that FEP was an excellent predictor (p < .0001)


of the probability of abnormally low levels of all three indicators.


Again, we repeated bur regressions using only children with FEP
      •»,

values of less than 33 ug/dl, and FEP was still very significant


(p < .0001).  The coefficients differed by less than one standard


deviation from those for the full sample.  Thus, the relationship


appeared to hold for low FEP levels as well as high ones.


     FEP levels of less than 33 ug/dl are generally associated


with blood  lead levels under 30 ug/dl.  Figure VI-2 shows the


regression's prediction of the percent of children with anemia as


a function  of FEP levels at normal transferrin saturation levels


for children.  The data used in the regression contained FEP levels


as low as 9.6 ug/dl, but we have shown the projections only for


18 ug/dl and above.  For our definition of anemia we have used

-------
                        VI. 17


                      Figure VI-2
       PERCENT OF CHILDREN WITH ANEMIA

    By Age and Race at Average Transferrin Saturation Levels
  48
  42
  36
c 30
0)

TJ

z
o

o. 24
•^

(U
o

03
Q.

  18
  12
Black

White
                             2—6 yrs.
                                 0.5 — 2 yrs.
                    r
   12-5
20    25
          30
35    40     45     50
                       FEP Level (pg/dl)

-------
                              VI. 18






 hematocrit  levels of  less  than  33% for  ages  0.5-2,  less  than  34%



 for  ages  2-6,  and less  than  35%  for  ages  6-8 —  the minimum normal



 range  levels recommended by  the  Journal of Pediatrics  (1977).



 These  definitions are supported  by the  work  of Yip  et  al.  (1981).



     Figure VI-2 shows  that  as  FEP levels increase  from  20 ug/dl



 to 50  ug/dl, an additional 20%  of children aged  2-6 years  would



 develop anemia at normal iron levels.   Our earlier  regressions



 of blood  lead  levels  on FEP  suggested that blood lead  levels  of



 less than 15 ug/dl  were necessary to keep average FEP  levels



 below  20  ud/dl.  Since  elevated  FEP  is  a  symptom of interference



 in heme synthesis,  it cannot be  viewed  as the cause of these



 abnormal  hematocrits.   The causal association must  be  with what-



 ever produced  the excess FEP.   As the data portrayed in  Figure



.VI-2 was  for normal iron levels,  the anemia  appeared to  be the



 outcome of  the lead exposure underlying the  FEP  values.



     In summary, blood  lead  levels below  the currently defined



 "undue lead exposure" range  of  30 ug/dl (and, indeed,  even below



 25 ug/dl) seem to be  associated  with increased incidence of anemia



 in children and increased  interference  with  heme synthesis pro-



 ducing elevated levels  of  free  erythrocyte protoporphyrin.  This



 suggests  that  both  the  levels of blood  lead  and  FEP used in the



 current Centers for Disease  Control  definition of undue  lead



 exposure  may be inadequate to protect children from the  risk  of




 anemia.   In addition, the  reduced mean  cell  volumes and  the lower



 hematocrits again indicate that  lead's  effect on heme  synthesis has



 uncompensated  effects at levels  below 30  ug/dl.   This  further

-------
                              VI.19





strengthens the case for considering elevated FEP levels, which



mark lead's interference with normal body activity, as a patho-



physiological effect.






VI.C.  Fetal Effects



       A growing concern in the public health community is that



the most sensitive population for lead exposure is not children,



but fetuses and newborn infants.  This concern is supported by



both animal studies and, recently, human data.



     Crofton et al. (1980)  found that the development of



exploratory behavior by rat pups exposed to lead in utero lagged



behind that of control rats.  Average blood lead levels on the



21st post-natal day were 14.5 ug/dl for the exposed pups and 4.8



ug/dl for the controls.



     Gross-Selbeck and Gross-Selbeck (1981) found alterations



in the operant behavior of  adult rats after prenatal exposure to



lead via mothers whose blood lead levels averaged 20.5 ug/dl.



At the time of testing (3-4 months, postnatal), the lead-exposed



subjects' blood lead levels averaged 4.55 ug/dl compared to 3.68



ug/dl in the controls.  This suggested that changes in central



nervous system function may persist for months after the cessation



of exposure to relatively low blood lead levels.



     Several other papers (McCauley and Bull, 1977; Bull et al.,



1979) have shown that the prenatal exposure of rats to 0.2% lead



chloride irf the mother's drinking water markedly reduced the



cytochrome C content in the cerebral cortex, and possibly



produced an uncoupling of the electron transport chain in the

-------
                             VI.20
cortex.  This reduction in cytochrome C content occurred at blood
lead levels as low as 36 ug/dl, with delays' in the development of
central nervous system energy metabolism being seen as late as 50
days after birth (Bull et al. , 1983).
     Human data are scarcer.  Needleman et al. (1984) have analy-
zed data from over 4,000 live births at Boston Women's Hospital
and found an association between some congenital anomalies and
umbilical cord blood lead levels.  Holding other covariates
constant, the relative risk of a child's demonstrating a minor
malformation at birth  increased by 50% as lead levels increased
from 0.7 ug/dl to 6.3  ug/dl  (the mean cord lead level).  This
increased an additional 50%  at 24 ug/dl.  (Umbilical cord  blood
lead levels are somewhat lower than, but correspond  to, maternal
blood  lead levels  [Lauwerys  et al.,  1978].)
     A preliminary analysis  by Needleman and  coworkers  (1984)
algo found an association between increasing  cord  lead  levels
and deficits  in the  child's  subsequent performance on the  Bayley
development scales,  after controlling  for covariates.   Again,
the cord  lead levels  in  this study were very  low.
     Finally  Erickson  et  al.  (1983)  found lung and bone  lead
levels in  children who died  from  Sudden Infant Death Syndrome
were statistically significantly  higher than  in  children  who
died of other causes,  after  controlling for age.

VI.D.   Neurological  Effects
     The adverse  effects of  lead  on  neurological  functioning,  both
on the microscopic (i.e.,  cellular  and enzymatic)  level  and  the
macroscopic  (i.e.,  learning  behavior)  level,  are  well  documented.

-------
                              VI.21





     On the micro-level, data from experimental animal studies



suggest several possible mechanisms for the induction of neural



effects., including:  (1) increased accumulation of ALA in  the



brain as a consequence of lead-induced impaired heme synthesis,



(2) altered ionic balances and movement of ions across axonal



membranes and at nerve terminals during the initiation or  conduc-



tion of nerve impulses due to lead-induced effects on the  meta-



bolism or synaptic utilization of calcium, and  (3) lead-induced



effects on the metabolism or synaptic utilization of various



neurotransmitters (Draft Lead Criteria Document, Section 12.3.4).



In addition, lead-induced heme synthesis  impairment, resulting



in reduced cytochrome C levels in brain cells during crucial



developmental periods, has been clearly associated with the



delayed development of certain neuronal components and systems



in the brains of experimental animals (Holtzman and Shen Hsu,



1976).  Cytochrome C is a link in the mitochondrial electron



transport chain that produces adenosine triphosphate (ATP) energy



for the entire cell.  Given the high energy demands of neurons,



selective damage to the nervous system seems plausible.



     Paralleling these cellular or biochemical effects were



electrophysiological changes indicating the perturbation of



peripheral and central nervous system functioning observed in



children with blood lead levels of approximately 15 ug/dl  (Otto



et al., 1981, 1982; Benignus et al., 1981).  These included



slowed nerve conduction velocities, as well as persistent



abnormal EEC patterns.  Aberrant learning behavior has been

-------
                              VI. 22





noted in rats with blood lead levels below 30 ug/dl (Draft
                                         r-


Criteria Document, Section 12.4.3.1.3).  This behavior evidenced



both reduced performance on complex learning problems and signs



of hyperactivity and excessive response to negative feedbacks



(Winneke, 1977, 1982).



     Finally, the cognitive effects of lead in children showed



signs of a dose-response relationship.  For high level lead



poisoning, adverse cognitive effects in children are indisputable



and mental retardation is a common outcome.  For children with



somewhat lower blood lead levels, de la Burde and Choate (1972,



1975) found lesser but still significant cognitive effects,



including a 4-5 point difference in mean IQ and reduced attention



spans.  Several studies discussed in more detail later in this



chapter have found smaller effects at lower blood lead levels.



The precise biological mechanisms connected with these effects

 -w

are not yet clearly defined.



     While some of these effects have only been observed at higher



blood lead levels, in animals, or in vitro, they all showed a



consistent dose dependent interference with normal neurological



functioning.  Furthermore, some of these effects have been docu-



mented to occur at low blood lead levels in children, with no



clear threshold having been demonstrated.



     This general pattern of lead's interference in neurological



functioning on the cellular level, including effects below 30



ug/dl, form the background against which we examined the studies



that investigated changes in cognitive processes in children

-------
                              VI.23


at low blood lead levels.   Because of the intrinsic difficulties

in performing such studies, and because most investigators have

not employed sample sizes that would permit unambiguous detection

of small effects, it is important to integrate those larger scale

studies with what has been discovered on the molecular and cellu-

lar levels.


VI.D.I.  Cognitive and Behavioral Effects

     Many studies have noted neurological effects in children

with elevated blood lead levels.  A brief discussion of these is

presented in Section V.B. of this paper, concentrating on those

examining the effects of blood lead levels above 30 ug/dl.  In

this section, we will examine the effects below 30 ug/dl.


VI.D.I.a.  Assessment of the Relationship Between IQ or
           Cognitive Function and Low Blood Lead Levels

    The answer to the question of whether the relationship between

blood lead and cognitive performance extends to levels below 30

ug/dl is tremendously important.  If 10  is affected at blood lead

levels below 30 ug/dl, the benefit of reducing lead"emissions is

very large because of the many children  who would be at risk.

     The literature on cognitive effects at low lead levels is

extensive.  However, most of the studies have methodological flaws

of varying '.importance and few display indisputable  results con-

cerning the relationship between IQ effects and changes in low
           j-                                          ...
lead levels.  The Draft Lead Criteria Document divided the studies

into four groups:  clinical studies of high lead children, general

population studies, lead smelter area studies, and  studies of

children who are mentally or behaviorally abnormal.

-------
                               VI. 24





     The summary  table  in  Chapter  12  of  the  Criteria Document



 (pp  55-58)  indicated  that  virtually all  of the studies  showed



 high lead groups  performing  more poorly  on a variety of tests



 used to assess  cognitive  function.  For  more than half  of these



 tests, however, the probability of falsely finding an effect due



 to chance was more  than 5%,  i.e.,  less  than  half of them had a



 p-value of  less than  0.05.   (Significance  levels in the studies



 were reported as  probabilities  if  they were  below 0.05  and as



 "not significant" otherwise.)   However,  because the reported



 sample sizes were small,  it  was not likely that small effects



 would have  been detected.  The  consistent  pattern in all the



 studies of  high lead  groups  doing  less well  indicated that the



 combined evidence of  a  significant effect  was  stronger  than the



 evaluations of  the  individual studies suggested.



     In developing a  better  test for  the existence of a specific



 effect, we  limited the  studies we examined for two reasons.



 First, because we were  interested  in  low level exposure effects



 in the whole population, we  used only the  six  general population



 studies.  The smelter study  by Winneke et  al.  (1982)  was also



 included, as blood lead levels appeared  to be  in the same range



.as the general population studies.  Second,  because we  were



 interested  in general effects, we chose  to look only at Full



 Scale IQ measures.  While not all studies  used the same IQ test,



 the Full Scale  IQ measures employed were close enough, to allow



 us to compare differences between groups and across  studies.



     We used the  Fisher aggregation procedure  (Fisher,  1970,



 p.99) to develop an estimate of the combined significance of the

-------
                               VI.25
 observed  effects,  and  to derive a joint  p-value for all of the

 studies.   To  do  this,  we needed the p-values for all of the

 individual studies.  Unfortunately,  as indicated above, they

 were  not  reported  where  they  were larger than 0.05,  so we  had  to

 calculate  several  p-values  from the  data presented.

      For  each  study we used the standard deviation  of  the  IQ

 measure to compute the standard deviation  for the difference in

 the mean  IQs across groups.   From the ratio  of  the  IQ  difference

 to this standard deviation, we  could compute  a  p-value.  We

 could directly apply this method  to  the  study by Smith  et  al.

 (1983).   In this study,  one of  the best  methodologically,  all

 of the 10  effects were reported  as  "not  significant".   However,

 when we computed the p-values,  we  found  that  the p-value was

 0.051 when comparing high and low  lead groups for the Full Scale

 10.* Similar computations for the Verbal and  Performance IQs

produced p-values of 0.068 and  0.105, respectively.**

  W.  Yule, in a personal communication at the the International
  Conference on Heavy Metals in the Environment  (Heidelberg,
  September 1983),  said  that a  recomputation paying more attention
  to round-off and  computational errors  found a one-tailed
  p-value  of less than 0.05.

**The mean IQs for  the low and high groups given in Smith et at.
  (1983)  were  quoted with 95%  confidence  intervals.   For the
  sample size  (145,155)  for these groups  we can assume normality.
  LThe sample  size  is  taken from Table 13 of Smithi et al. (1983).]
  Thus,  for the low group, 2.0 IQ poin_ts  = -1.96 si,and, for
  the high group, 1.9-10 points = 1.96s2, where sj and ¥2 were
  the standard  deviations for  the low and_the high groups,
  respectively.   This  implied  values for  sj of 150.98 and s"2 of
  145.66.   Combining  these variances yielded an overall variance
  of  148.23.   Weighting  this by the sum of the inverses of  the
  sample sizes  gave the  variance for the  difference  of the  means,
  which  was 1.978.   Taking the square root of these  yielded a
  standard deviation of  1.407.   Dividing  the difference between
  the  high and  low  group  (2.3)  by 1.407 produced a normal statistic
  of  1.635  which  has an  associated p-value  of 0.051  (Bryant,  1966).

-------
                              VI.26






     For other studies, where we could not determine the standard



deviation for the test procedure, we assumed it was equal to 15.



This is the commonly cited standard deviation for IQ, although it



varies slightly from test to test.  Because this standard devia-



tion was somewhat higher than the standard deviations in the



studies that reported such values (the study groups were more



homogeneous than the general population), our calculations probably



produced p-values larger than the true p-values.



     We used these p-values and the Fisher procedure to compute



a joint probability for the observed results, presented in Table



Vl-2.  The resulting probability of 0.014 indicates that it was



very unlikely that we could get the observed pattern of results



if there were really no effect.  The overwhelming preponderance



of the data (all studies show high lead groups with lower cog-



nitive ability) was highly unlikely to have been due to chance.



     Only if the studies were consistently biased towards finding



an effect would the robustness of our result be questionable.  In



at least one case (Smith et al., 1983), a procedure was used that



biased against finding an effect, and biased upward the p-values.



These authors used a two-stage analysis of variance or covariance



where the effects of all covariates (except lead) on IQ were



controlled for in the first stage, and the remaining IQ effects



were regressed on lead in the next step.  Many of these covariates



(e.g., parental care, income, IQ) negatively correlate with lead



exposure, and this procedure attributed all of the joint variation



to the nonlead variable.

-------
                                                       VI. 27
                                                       TABLE VI-2


Studya
Me Bride et al.
(1982)
Yule et al.
(1981)
Smith et al.
(1983)
Yule and Lansdown
(1983)
Harvey et al.
(1983)
Winneke et al.
(1982a)
Joint P-Value

Needleman et.al


Sample
Control E
100
20
145
on
oU
Total of
26

for Studies:

100
Computation c
of Cognitive El
Sizes Blood
xposed Control
100 0.5-9
21 7-10
155 	

189 N/A
26 	

P(X?2 > 25.10)

58
5f Joint P-\
:fects from
Internal I
(ug/dl)
Exposed
19-30
17-32
——————

N/A
______

= .014


/alue from Epidemiological Studies
Low Level Lead Exposures in Children
^ead Levels
Teeth (ppm)
Control Exposed IQ Difference
______ 	 ib
	 -. 	 :._ 7.6c
< 2.5 8 2.2C

N/A N/A .7d
2.4 7 5C



< 10 < 20 4C


P-Value -2 In p
.32 2.28
.029 7.08
.051 5.95
99 1 no
• £.£. J.UJ
.34 2.15
.10 4.61
25.10


.03 7.01
(1979)

 Joint  p-.value including Needleman P(X^4 >  32.02)  = .004

    a  Citations refer to Draft Lead Criteria Document, October,  1983
    b  Peabody Picture Vocabulary 10 Test
    c  Welchsler Intelligence Scale for Children-Revised
    d  British Ability Scales
32.11

-------
                              VI.28

      Another study (Harvey et al., 1983) chad IQ measurements on
131 children but only 71 degrees of freedom in the t-test for
lead.  If this study included 59 covariates in the analysis,
such an over specification clearly would bias downward the
significance of lead as well.
     We have treated one major study (Needleman et al. , 1979)
differently because a recent critique raised questions about the
appropriateness of the p-value reported in the study (Draft
Criteria Document, Appendix 12C).  Pending the resolution of that
issue, we have presented our results both with and without this
study.  Even when it was omitted, the p-value (.014) was clearly
significant.  Recent reanalysis by Needleman using the alternative
specifications for his model suggested by the review committee
still found .a significant lead effect.  Including this study
would lower the joint p-value to .004.
     Figure VI-3 presents an alternative method to evaluate the
results from these studies.  For each study the figure give the
90% confidence interval for the full scale IQ difference between
the high and low lead groups.  The mean is represented by the
square, the upper limit by an X, and the lower limit by a +.  For
two of the studies the confidence interval does not include zero,
which is computationally equivalent to finding that a one-tailed
hypothesis test would reject a null hypothesis of no effect at
the 5% level.  However, as the figure shows, all of the studies
found that the high lead group had a lower mean IQ, and that the

-------
                                 VI.29
                             FIGURE VI-3

            Mean IQ  Difference  Between High Lead Groups
         and  Controls,  Adjusted  for Socioeconomic  Factors
                      (90% Confidence Intervals)
J
a
u
e
z
Et}
ti-

er
  i
  o

 -2
 -3
 -e -



 -9


-11


-13
-14
-15
              McBride
              et ali
               (1982)
                  „
                  Yule
                 et a1'
                 (1981)
 Smith
et al<
(1983)
Yule and
Lansdown
 (1983)
Harvey
et al.
(1983)
Winneke
 et al.
 (1982)
Needleman
 et al.
 (1979)
       • = Mean

        X= Upper Confidence Limit

        += Lower Confidence Limit

-------
                            VI.30


range of effects consistent with all of them was a  loss  of  one

to three and a half IQ points.

     Therefore, we accepted the implication of the  joint probab-

ility computation that there was an association between  cognitive

deficits and differences in lead exposure even at low  levels.

Ignoring such a risk without considering the potential cost of

the error associated with that risk would have been  inappropriate

in determining the desirability of implementing a policy.


VI,D.l.b.  Policy Implications of Significance Tests

     In making policy decisions, we should be concerned  with the

cost of not implementing an appropriate policy (false  negative)

as well as with the cost of implementing an inappropriate policy.

Policy makers must balance the risks of each type of error,

weighted by its costs.  Because of this, even if the p-value for

the -joint test had been slightly larger than the arbitrary  0.05

level,*  we still would have considered the cognitive  effect.

the risk of a false negative  is large.  For example, for the

Smith et al. study, we computed that the probability of  falsely
*  Over the years the significance level of 0.05 has become  the
   basis for rejecting the scientific  ("null") hypothesis.   While
   adherence to the strict definition  of "statistical significance"
   has been important in science, it must be remembered  that this
   p-value is arbitrary and may not be the appropriate sole
   criterion for regulatory decision making.

-------
                               VI.31

 asserting  the  null  hypothesis  was  true was  .587.*  This false

 negative rate  would be  even higher in the other studies considered

 here owing  to  their smaller sample sizes.

     The cost  of  not avoiding  small cognitive effects  for

 millions of  children is  high.   If  insisting  on a p-value of less

 than 0.05 before  accepting  that a  cognitive  effect exists means

 a substantial  risk  of a  false  negative,  then the potential cost

 of the wrong decision may be too large.   In  this case,  given the

 relatively small sample  sizes,  the small  cognitive deficits one

 might expect,  and the standard  deviation  of  the test procedure,

 We believe that this association,  coupled with the biochemical

studies, animal studies, and high  level effects discussed in the

 introduction to VI.D. suggests  a causal relationship.

     The existence  of a  large chance  of a false negative for

outcomes where costs are potentionally high  suggested  the need

 for carefully  considering the entire  process  by which  the

validity of the hypothesis  was  evaluated.  In  particular,  where

 the choice of  a null hypothesis  gives  credence  to  one point of

view which is  not justified  given  the  power  of  the  test,  a

hypothesis  test may not be  appropriate.   An  alternative  method

is  to look at confidence intervals  around the  estimated  parameter
  We computed the false positive from the Smith et al. data
  as follows.  To estimate the p-value, we derived a standard
  deviation for the difference of the high and low lead groups
  of 1.407.  At a 5% chance of rejecting the null hypotheses
  when it was true, the normal one-tailed statistic was 1.65.
  Therefore, we would reject the null hypothesis only for
  differences greater than (1.407) (1.65) = 2.32.  If the
  difference in the groups were two IQ points, the probabil-
  ity of the difference being below 2.32 is given by
  p (z < [2.32-2]/ 1.407)  = .587.

-------
                              VI.32

values.  As an example, consider the confidence  intervals  in

Figure VI.3, which shows graphically that elevated  lead  levels

have a negative effect on  IQ.

     This conclusion, plus the above joint probability estimate

of p = 0.014 for the general population studies,  led  us  to accept

the existence of cognitive effects of  low level  lead  exposure.


VI.D.2. Estimating Avoided IQ Loss Associated with
8
        Reduced Blood Lead Levels

     We used two hypotheses to evaluate the extent of  IQ  loss .

Both were based on the Smith et al. study which used tooth  lead
     8
as the measure of lead intoxication, where particular  attention

was paid to measuring and controlling for covariates .  Their

"high lead group" had teeth with lead levels of 8.0  ug/g  or

more, a relatively low cutoff level.

     Our first hypothesis, assuming a step function  with  a  thres-

hold^was that .a group of children whose teeth lead  levels  were

above 8 ug/g would have an average IQ 2.3 points lower than the

average IQ of children in the control group, whose lead exposure

resulted in tooth lead levels below 2.5 ug/g.

     To convert tooth lead to blood lead, we used three methods.

First, we followed Steenhout and Pourtois (1981) and Steenhout

(1982), who used regression analysis to estimate the increase in

tooth lead (t)  concentration that would result from various

blood lead (BL) levels over time.  Her model was:
Tooth Lead(t') =    f   q(t)BL(t)dt.
                   J

-------
                              VI. 33


For adults, q = 0.045, a constant, and the model reduced to:

      Tooth lead(t') = q "BL  /\ t.

     At the International Conference on Heavy Metals and the

Environment (September 1983), held in Heidleberg, West Germany,

Steenhout presented additional results.  For children, the rate

of tooth lead accumulation per unit of blood lead , was much higher

than for adults and appeared to decline exponentially to the adult

level with age.  Steenhout's best fit of the data was:
      Tooth lead(t') = I     [0.045 + 0.2 exp( -t/4 . 5 ) ppm] BL( t )dt
                       Jt0

where t was measured from Steenhout's "midgrowth stage".  Replacing

BL(t) by ~BL, we could solve for BL.  This analysis obtained a BL

of 5.0 ug/dl or less for Smith's low exposure group, and  16 ug/dl

or more for her high group.

     Second, we used Winneke's data (Winneke, 1979) which showed

mean blood lead levels equaled 2.5 times mean tooth lead  levels.

This gave blood lead levels of 6.25 ug/dl for the control group

and 18 ug/dl for the high group, which was consistent with

Steenhout's results.

     Finally, we examined Smith's data on blood  lead levels for a

non-random sample of her survey population.  These showed blood

lead levels of 11.5 ug/dl for 20 low lead children and 15.1 ug/dl

for her high group.  While  this yielded about the same results for

the high group, it showed much higher levels for the control group.

We are not sure what caused this discrepancy, although the  number

-------
                            VI. 3 4
 of low lead children was very small.   in any, case,  the  three  dif-

 ferent procedures for imputing blood lead suggested  a threshold

 for IQ loss at about 15 ug/dl.

        Tne second hypothesis assumed that,  instead of a step  func-

 tion with a threshold occurring at 15 ug/dl of blood lead,  there

 was a linear function relating IQ loss to blood lead level.   For

 our estimate of the effect, we also used the Smith et al. study

 and assumed the low tooth lead group had an average blood lead

 level of  3 ug/dl and the high group had an average blood lead

 level of  18 ug/dll   We  used the estimated blood lead levels

 based on  Steenhout's procedure and divided the difference in IQ

 by  the difference in blood  lead to yield a slope of 0.15 IQ/ug/dl

 of  blood  lead.   Other studies,  such as  the 1981 study by Yule et

 al.,  had  coefficients as  high as  0.7  IQ points  per ug/dl of

 blood  lead.  Using  Smith's  limited blood  lead data would suggest

 a slope of  0.64.  To be  conservative,  we  have used the  0.15

slope.

     we computed  the total  lost  IQ points  for several hypotheses,

but did not attach monetary  values  to  the  lost  IQ.


VI.D.3.  Thresholds  for  Effects of  Blood  Lead o.n  IQ  and  the  size
         of the Affected Population  '           '	

     In assessing the size of the  population  at risk, two alterna-

tive hypotheses were again possible.  The first was a no thres-

hold model.  It assumed that the effect of lead on IQ was a

continuous function, with increasing risk and effect  as blood

-------
                             VI.35
lead levels rose.  Under this assumption, adverse effects on



either IQ or behavioral patterns/ such as disruptive behavior or



shortened attention span, occurred at lower lead levels  and



increased at higher lead levels, and despite  individual  dif-



ferences, the extent of effect was related to the extent of



exposure.



     Alternatively, many people believe that  cognitive deficits



from lead exposure occur only above a specific  threshold, i.e.,



that blood lead levels below some value will  not affect  either



intelligence or behavior patterns that may reduce educational



attainment.  Several alternative threshold values are possible.



     Because there is little dispute concerning cognitive effects



above 30 ug/dl, selecting that blood lead level was one  option.



On the other hand, ALA levels are elevated at 15 ug/dl and EEC



patterns also show persistent changes at that level.  This evidence



suggested that blood lead levels of 15 ug/dl may be a threshold.



This is buttressed by the Smith et al. study, where we have deter-



mined that children whose exposure averaged above 16 ug/dl had



lower IQ levels than children whose exposure averaged below 5



ug/dl.  While the cognitive damage may have occurred at  earlier



ages when blood lead levels were higher, the work of Harvey, who



surveyed two year old children in Birmingham, Alabama, indicated



that blood lead levels among two year olds averaged 15.6 ug/dl.



This, was only slightly higher than the average among Smith's



older children.  Furthermore, the study by Yule et al. (1981)



indicated that children with blood leads of 7-10 ug/dl had

-------
                               VI. 36


  higher IQs than those with blood leads of 17-32 ug/dl.  Yule and

  Landsdown (1983) can be taken as supporting this level or even

  indicating that the threshold may be somewhat lower.

       Alternatively, the study by McBride et al. (1982) showed a

  small difference between children above 19 ug/dl and those below

  10.  This data suggested that the threshold may be around 20 ug/dl.

       Because all three thresholds (15, 20, and 30 ug/dl) were

  possible, we have calculated the number of children potentially

  at risk for each of the three options.  These estimates are

  shown in Table VI-3.    j

                             TABLE VI-3

           Decrease in Number of Children Above Thresholds
                        for Cognitive Effects

Possible Threshold          Low-lead Option         All Unleaded

15 ug/dl                      1,475,000              1,552,000
20 ug/dl                        476,;000                500,000
30 oig/dl                         43,000                 45,000

       As noted, accepting the hypothesis of a cognitive effect

  at a given threshold does  not imply that all the children above

  the threshold are affected or that all below the threshold are

  free of the  effect.

       In addition to computing the  number of  children at risk, we

  estimated the total  effect on intelligence,  expressed as the

  number of children at risk times the mean change in-. IQ.  Our

  estimate of  the change in  IQ was 2.2 IQ points.*  We then computed
  *  The 2.2  IQ figure  is  the  difference  between the  average  IQ of
    the Smith et  al. middle group of  children and  the average  IQ
    of  that  study's  high  lead group.   We had  found the average
    blood lead level of  the children  below 15 ug/dl  was nearer
    that of  the children  in the  Smith et al.  middle  group.

-------
                             VI.37


the change in person-IQ points  (i.e.,  the  number  of  people  at  risk

times the average 2.2 IQ points lost)  as a  result of the  policy

options.  For simplicity, we used the  same  2.2  IQ point decrement

for the other two thresholds.   The results  are  shown on Table  VI.4,

     Finally, assuming there is no threshold, we  converted  the

changes in mean blood lead levels to changes  in IQ using  an estim-

ate of the rate of change of IQ per ug/dl.  We  assumed  that the

mean of the IQ change for any child was dependent on the  mean

change in blood lead levels.  (As,shown in  Table  VI-1,  black and

white children had different blood lead levels  and this was

considered in our calculation.)  The estimated  changes  in IQ

points for children aged 6 months to 7 years  are  shown  in Table

VI-4.  These were computed using the coefficient  of  0.15  IQ/ug/dl

derived earlier from the Smith  et al.  study,  from changes in

mean blood lead levels given in Table  V-5,  and  from  population

figures in Table VI-6 for children aged 0  to  7.


                          TABLE VI-4

             possible Change in Person IQ  Points  as  a
                 Function of Threshold Levels for
                   Children 6 Months to 7  Years

       Threshold     .       Low-Lead .           All  Unleaded

       15 ug/dl            2,867,000               3,018,000
       20 ug/dl              986,000               1,035,000
       30 ug/dl               92,000                  97,000

       No threshold        7,913,000                 8,728,000


     Because there are so many  children at  risk,  any reasonable

monetary value ascribed to avoiding the loss  of one  person's IQ

-------
                             VI.38



point would produce very large savings for these changes  in



person-IQ points.  For example, if parents were willing  to pay



$100 per IQ point to remove the possibility of such a  loss,




we would have estimated benefits for the all unleaded  case ranging



from $9.2 to $302 million for the thresholds listed above and up



to $873 million if there were no threshold.  Thus, even  if only




small changes in IQ are found to be associated with lead  exposure,



the large number of children affected would make the benefits of



avoiding such effects extremely large.






VI.E.  Estimating the Reduction in the Nulhber of Children at Risk




     Reducing or eliminating leaded gasoline will reduce  the



number of children at risk for the pathophysiological  effects



from elevated blood lead levels.  Table VI-5 presents  the decrease




in the number of children above the "minimum observed  effect level,"



or "apparent thresholds," for various health effects.   In many



cases, these apparent thresholds reflect the limitations  of current



experimental measurement techniques and not a finding  that no



effect exists at lower levels.  Therefore, our estimates  are



likely to be conservative.  Our estimates of the decreased number



of children with abnormal physiological functioning are  based on



statistical methods described in section V.E,

-------
                             VI.39
                           TABLE VI-5

        Decreased Number of Children (under 14 years old)
                 Above Apparent Threshold Levels

                          Apparent
Medical Effect           Threshold      Low-lead    All Unleaded

inhibition of PY-5-N      10 ug/dl      4,257,000    4,486,000
inhibition of ALA-D       10 ug/dl


Inhibition of vitamin D   10-15 ug/dl
Elevated ZPP              15 ug/dl
EEC changes               15 ug/dl      1,475,000    1,553,000
Elevated ALA levels       15 ug/dl


Inhibition of globin      20 ug/dl        476,000       500,000
  synthes is

     Even if we  take  the thresholds  in  Table  VI-5  as true  thres-

holds,  it is very unlikely  that all  individuals  with blood lead

concentrations above  a given threshold  will suffer a particular

effect, and  it is unlikely  that all  those below  the threshold are

free from the effect.  The  specific  blood lead  level at which a

particular effect begins to occur  varies from person  to person.

in  the  general population,  such variation generally produces  an

S-shaped curve of the percent  of  people with  the effect as a  func-

tion of blood lead  level or other  exposure  index.   In  Table VI-5

we  approximated  the dose-response  curve with  a step function

instead of a continuous curve;  the numbers,  therefore, only

roughly estimate the  true  values.

     We also used regressions  to  predict  the  distribution of

blood  lead levels  in  1988.  These  values  are  given in  Table

VI-6.   (Details  of  how  these  numbers were  calculated are

contained  in Section  E  of  Chapter V.)

-------
                              VI.40

                            TABLE VI-6
       Estimated Distribution of Blood Lead Levels in 1988
(in thousands of
Blood lead
Base Case
Low-lead
All Unleaded
<10ug/dl
3,386
4,496
4,559
children
Black
10-15
ug/dl
2,588
2,131
2,096
aged 1.3 and under)
15-20
ug/dl
1,191
790
766
20-30
ug/dl >30ug/dl
490 36
267
256
17
16
Non-Black
Blood lead
Base Case
Low-Lead
All Unleaded
<10ug/dl
34,608
37,764
37,921
10-15
ug/dl
4,326
2,001
1,884
15-20
ug/dl
1,085
486
458
fl. Distributional Aspects of Lead Expos
20-30
ug/dl >
397
186
177
ure
30ug/dl
52
29
28

     One feature often overlooked  in  analyzing  the  pathophysio-
logical changes induced by lead  is  the close  correlation  between
the occurence of high lead levels  and high  levels of other stres-
sors, which, like lead, both have  direct adverse effects  and
reduce the reserve capacity of the  body to  deal with environmental
insults.  When two or more stressors act in concert, the severity
of the adverse impacts increases and makes  it much more likely
that the reduced reserve capacity produced by lead will, in
fact, produce adverse consequences.

-------
                             VI.41


      People who have the highest blood lead  levels  tend  to  be

children, in general; black children,  in particular;  and  poor

people.  Children are often deficient  in iron and  calcium, the

adverse effects of which are exacerbated by lead.  Children's

nervous systems are more sensitive  to  toxins, and  they  are just

beginning their cognitive development.  Blacks  tend  to  have  higher

hypertension rates, which may also  be  associated with or  exacerb-

ated by lead (Beevers et al., 1976).   Blacks  also  tend  to have

lower vitamin D levels which are further reduced by  lead, and

tend to be poor.  Poor people usually  have a  lower level  of

vaccination, well baby care, and preventive medicine  in general.

poor people are .more likely to be sick and/or malnourished,  have
                                  V  -\
inadequate medical care, and be under  greater stress, both physical

(e.g., poor heating and sanitation) and psychological.

     Poor people, on average, are less successful  in  school  so

even marginal central nervous system or cognitive  effects of lead

may have more serious implications,for this group.   Many  of  the

people at high risk of lead exposure have a high risk of  experi-

encing these other factors.  For them  lead effects that would be

sub-clinical in the absence of these- other factors may  not

be sub-clinical.                      :


VI.F.  Conclus ion

     We examined several different  ways to value the  benefits

of reduced lead exposure through reduced use of lead  in gasoline.

In Table VI-7 we present a summary  of  the estimated  benefits for

-------
                             VI.42


children under age fourteen of reducing^the adverse effects

resulting from exposure to lead from gasoline.


                         TABLE VI-7

     Summary of the Benefits of Reducing Lead Exposure

                                   Low-lead      All Unleaded

Reduction in number of
children (under 14 years
of age) at risk of:

At 10 ug/dl                        4,257,000       4,486,000

   Inhibition of PY-5-N
   Inhibition of ALA-D                                      H

At 15 ug/dl                        1,475,000       1,553,000

   Inhibition of vitamin D
   Elevated ZPP
   EEC changes
   Elevated ALA levels

At 20 ug/dl

   Inhibition of globin synthesis    476,000         500,000

Average loss of 2.2 10 points      43,000 to       45,000 to
                                   1,475,000       1,553,000

Percent change in children's
    mean blood lead levels:

      Whites                              24%             27%
      Blacks                              12%             13%


    The size of the populations potentially at risk for the low

level effects preceding overt manifestations of clinical symptoms

of lead poisoning is large.  Although we have not attached any

dollar values, the changes that would occur under our two policy

-------
                         VI.43
Ions  suggest that reducing the pathophysiological effects of



3 exposure would be a significant public health benefit of




ucing lead in gasoline.

-------
                               VI.44
                             REFERENCES


Angle, C. R.; Mclntire, M. S.; Swanson, M. S.; Stohs, S. J. (1982)
     Erythrocyte nucleotides in children - increased blood lead
     and cytidine triphosphate.  Pediatr. Res. 16. 331-334.

Beevers, D. G.; Erskine, E.; Robertson, M.; Beattie, A. D.;
     Campbell, B. C.; Goldberg, A.; Moore, M. R.; Hawthrone, V. M.
     (1976) Blood-lead and hypertension.  Lancet 2(1): 1-3.

Benignus, V. A.; Otto, D. A.; Muller, K. E.;  Seiple, K. J. (1981)
     Effects of age and body lead burden on CNS function in young
     children.  II. EEC spectra.  Electronencephalogr. Clin.
     Neurophysiol. 52: 240-248.

Bryant, E.G. (1966) Statistical Analyses (2nd ed.) McGraw Hill,
     New York.

Bull, R. J.; Lutkenhoff, S. D.; McCarty, G. E.; Miller, R. G. (1979)
     Delays in the postnatal increase of cerebral cytochrome concen-
     trations in lead-exposed rats.  Neuropharmacology 18: 83-92.

Bull, R. J.; McCauley, P. T.; Taylor, D. H.; Croften, K. M. (1983)
     The effects of lead on the developing central nervous system
     of the rat.  Neurotoxicology 4(1): 1-17.

Crofton, J. M.; Taylor, D. H.; Bull, R. J.; Sivulka, D. J.;
     Lutkenhoff, S. D. (1980) Developmental delays in exploration
     and locomotor activity in male rats exposed to low level
     lead.  Life Science 26: 823-831.

De la Burde, B.; Choate, M. S., Jr. (1972) Does asymptomatic lead
     exposure in children have latent sequelae?  J. Pediatr.
     (St. Louis) 81: 1088-1091.

De la Burde, B.; Choate, M. S., Jr. (1975) Early asymptomatic lead
     exposure and development at school age.  J. Pediatr. (St. Louis)
     87: 638-642.

Dresner, D. L.; Ibrahim, N. G.; Mascarenhas, B. R.; Levere, R. D.
     (1982) Modulation of bone marrow heme and protein synthesis by
     trace elements.  Environmental Research 28: 55-66.

Erickson, M. M.; Poklis, A.; Gantner, G. E.; Dickinson, A. W.;
     Hillman, L. S. (1983) Tissue mineral levels in victims of
     sudden infant death syndrome.  I. Toxic metals-lead and cadmium.
     Pediatric Research 17: 779-784.

Fisher, R. A. (1970) Statistical Methods for Research Workers.
     Hafner press, New York

-------
                               VI.45


Gross-Selbeck, E.; Gross-Selbeck, M. (1981) Changes in operant
     behavior of rats exposed to lead at the accepted no-effect
     level.  Clin. Toxicol. 18:  1247-1257.

Harvey, P.; Hamlin, M.; Kumar, R. (1983) The Birmingham blood
     lead study.  Presented at:  annual conference of the
     British Psychological Society, symposium on lead and health.
     Available for inspection at:  U.S. Environmental Protection
     Agency, Environmental Criteria and Assessment Office, Research
     Triangle Park, NC.

Hernberg, S.; Nikkanen, J. (1970) Enzyme inhibition by lead under
     normal urban conditions.  Lancet 1: 63-64.

Holtzman, D.; Shen Hsu, J. (1976) Early effects of inorganic lead
     on immature rat brain mitochondrial respiration.  Pediatr. Res.
     10: 70-75.                                        	

journal of Pediatrics (editorial) (1977) New approaches to screening
     for iron deficiency. 90: 678.

Kammholz, L. P.; Thatcher, L. G.; Blodgett, F. M.; Good, T. A. (1972)
     Rapid protqporphyrin quantitation for detection of lead
     poisoning.  Pediatrics 50: 625-631.

Lamola, A. A.; Joselow, M.; Yamane, T. (1975a) Zinc protoporphyrin
     (ZPP); a simple, sensitive, fluorometric screening test for
     lead poisoning.  Clin. Chem. (Winston-Salem, N.C.) 21: 93-97.

Lamola, A-A.; Piomelli, S.; Poh-Fitzpatrick, M. B.; Yamane, T.;
     Harber, L. C. (I975b) Erythropoietic protoporphyria and lead
     intoxication: the molecular basis for difference in cutaneous
     photos ensitivity.  II:  Different binding of erythrocyte
     protoporphyrin to hemoglobin. J. Clin. Invest. 56: 1528-1535.

Landrigan, P. J.; Baker, E. L., Jr.; Feldman, R. G.; Cox, D. H.;
     Eden, K. V.; Orenstein, W. A.; Mather, J. A.; Yankel, A. J.;
     von Lindern, I. H. (1976) Increased lead absorption with anemia
     and slowed nerve conduction in children near a lead smelter.
     J. Pediatr. (St. Louis) 89: 904-910.

Lauwerys, R.; Buchet, J-P.; RoeIs, H.; Hubermont, G. (1978)
     Placental transfer of lead, mercury, cadmium, and carbon
     monoxide in women.  I:  comparison of the frequency distri-
     butions of the biological indices in maternal and umbilical
     cord blood.  Environmental Research 15: 278-289.

Mahaffey, K. R.; Annest, J. L.; Roberts, J.; Murphy, M. S.  (1982)
     National estimates of blood lead levels:  United States, 1976-
     1980:  Association with selected demographic and socioeconomic
     factors.  New England Journal of Medicine 307  (10): 573-579.

-------
                               VI.46


Mahaffey, K. R.; Rosen, J. F.; Chesney, R. W.; Peeler, J. T.; Smith,
     C. M.; De Luca, H. F. (1982)  Association between age, blood
     lead concentration, and serum 1,25-dihydroxcholecalciferol
     levels in children.  American Journal Clin. Nutr.  35: 1327-
     1331.

McBride, W. G.; Black, B. P.; English, B. J. (1982) Blood lead
     levels and behaviour of 400 preschool children. Med. Journal
     Aust. 2: 26-29.

McCauley, P. T.; Bull, R. J. (1978) Lead-induced delays in
     synaptogenesis in the rat cerebral cortex.  Fed. Proc. Fed.
     Am. Soc. Exp. Biol. 37: 740.

Meredith, P. A.; Moore, M. R.; Campbell, B. C.; Thompson, G. G.;
     Goldberg, A. (1978) Deltaaminolevulinic acid metabolism in
     normal and lead-exposed humans.  Toxicology 9: 1-9.

Moore, M. R.; Meredith, P. A. (1976) The association of delta-
     aminolevulinic acid with the neurological and behavioural
     effects of lead exposure.  In:  Hemphill, D. D., ed. Trace
     Substances in Environmental Health - X; [proceedings of
     University of Missouri's10th annual conference on trace
     substances in environmental health]; June; Columbia, MO.
     Columbia, MO:  University of Missouri-Columbia; pp. 363-371.

Needleman, H. L.; Gunnoe, C.; Leviton, A.; Reed, R.; Peresie, H.;
     Maher, C.; Barrett, P. (1979) Deficits in psychological and
     classroom performance of children with elevated dentine lead
     levels.  New England journal of Medicine 300: 689-695.

Needleman, H. L.; Rabinowitz, M.; Leviton, A.; Linn, S.; Schoenbaum,
     S. (1984) The relationship between prenatal exposure to lead
     and congenital anomalies.  Journal of the American Medical
     Society (in press).

Otto, D. A.; Benignus, V. A.; Muller,  K. E.; Barton, C. N. (1981)
     Effect of age and body lead burden on CNS function in young
     children. I: Slow cortical potentials.  Electroencephalogr.
     Clin. Neurophysiol. 52: 229-239.

Otto, D.; Benignus, V.; Muller, K.; Barton, C.; Seiple, K.; Prah,
     J.; Scroeder, S.  (1982) Effects of low to moderate lead exposure
     on slow cortical  potentials in young children:  two year
     follow-up study.   Neurobeha. Toxicol. Teratol. 4: 733-737.

Piomelli, S.; Davidow, B.; Guinee, V.  F.; Yound, P.; Gay, G. (1973)
     The FEP (free erythrocyte protoporphyrin)  test: a screening
     micro-method for  lead poisoning.   pediatrics 51: 254-259.

-------
                               VI.47


Piomelli, S.; Seaman, C.; Zullow, D.;  Curran, A.; Davidow, B. (1977)
     Metabolic evidence of lead toxicity in "normal" urban children.
     Clin. Res. 25: 459A.

Piomelli, S.; Seaman, C.; Zullow, D.;  Curran, A.; Davidow, B.
     (1982)  Threshold for lead damage  to heme synthesis in urban
     children.  Proc National Academy  Science U.S.A. 79: 3335-3339.

RoeIs,  H.; Buchet, J-P.; Lauwerys, R.; Huermont, G.; Bruauz, p.;
     Claeys-Thoreau, F.; Lafontaine, A.; Van Overschedle, J. (1976)
     Impact of air pollution by lead on the heme biosynthetic
     pathway in school-age children.  Archives of Environmental
     Health 31: 310-316.

Rosen,  J. G.; Chesney, R. W.; Hamstra, A.; De Luca, H. P.; Mahaffey,
     K. R. (1980) Reduction in 1,25-dihydroxyvitamin D in children
     with increased lead absorption.  In:  Brown, S. S.; Davis, D.
     S., eds. Organ-directed Toxicity; Chemical  Indices and
     Mechanisms.  New York, NY:   Pergamon Press; pp. 91-95.

Sassa,  S.; Granick, J. L.; Granick, S.; Kappas,  A.; Levere,  R. D.
     (1973)  Studies in lead poisoning. I: Microanalysis of erythrocyte
     protoporphyrin levels by spectrofluormetry  in  the detection
     of chronic lead intoxication in the subclinical range.  Biochem.
     Med. 8: 135-148

Schwartz, J. D.; Janney, A.; Pitcher,  H.  (1983)  The relationship
     between gasoline lead and blood lead.   (submitted for publication)

Smith,  M.; Delves, T.; Lansdown,  R.; Clayton, B.; Graham, p. (1983)
     The effects of lead exposure on urban children: the  Institute
     of Child Health/Southampton study.   London, United Kingdom:
     Department of the Environment.

Steenhout, A. (1982) Kinetics of  lead storage on teeth and bones:
     an epidemiologic approach.   Archives of Environmental Health
     37:  224-231.

Steenhout, A.; Pourtois, M. (1981)  Lead  accumulation  in  teeth as a
     function of age with different exposures.   British journal of
     Industrial Medicine 38: 297-303.

U.S. Centers for Disease Control  (1978) Preventing  lead poisoning
     in young children.  Journal  of Pediatrics Vol  93.

U.S. Department of Health and Human Sevices  (1982)  Vital  and Health
     Statistics.  Advance Data #79, May 12,  1982.

U.S. Environmental Protection Agency  (1983)  Review Draft Air
     Quality Criteria for Lead (Research  Triangle  Park,  NC.).

-------
                               VI.48


White, J. M.; Harvey, D. R. (1972) Defective synthesis of A and B
     globin chains in lead poisoning.  Nature (London) 236: 71-73.

Winneke, G.; Hrdina, K-G.; Brockhaus, A. (1982a) Neuropsychological
     studies in children with elevated tooth-lead concentrations.
     Part I: Pilot study, Int. Arch. Occupational and Environmental
     Health 51: 169-183.

Winneke, G.; Brockhaus, A.; Baltissen, R. (1977) Neurobehavioral
     and systemic effects of long term blood lead elevation in
     rats.  Arch Toxicol. 37:247-263.
Winneke, G.; Lilienthal, H.; Werner, W. (1982) Task
     dependent neurobehavioral effects of lead in rats.
     Arch Toxicol; Supp. 5: 84-93.

Yule, W.; Lansdown, R. (1983) Lead and children's development:
     recent findings.  Presented at:  International conference:
     Management and Control of Heavy Metals  in the Environment;
     September; Heidelberg, West Germany.

Yule, W.; Lansdown, R.; Millar, I. B.; Urbanowicz, M. A. (1981)
    .The relationship between blood lead concentrations, intel-
     ligence and attainment in a school population:  a pilot
     study. Dev. Med. Child. Neurol. 23: 567-576.

-------