United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 11
Number 4
May 1985
EPA JOURNAL
Phasing Down Lead
in Gasoline
-------
EPA's decision (o lower the lead contem
of U.S. gasoline will help protect
children, who are most susceptible to
lead poisoning.
Phasing Down Lead in Gasoline
In a far-reaching action to
protect public health and the
environment. EPA is phasing
down lead in gasoline. In this
issue, EPA Journal explores the
step and what it means to
Americans.
The first article explains (he
lead phasedown decision. The
second story reports on two
major factors motivating the
decision -fuel switching and
engine tampering. The third
article discusses the phase-
down's benefits and costs to
society and how they were
analyzed and weighed at EPA.
In an Interview, a key EPA
official explains the strong and
still accumulating evidence on
the health dangers from lead in
gasoline. The next feature
reports on the close relationship
between lead levels in gasoline
and the lead count in blood.
The popular but often
disastrous use of lead from
ancient times to the automobile
age is traced in a special report
putting lead's dangers in
historical perspective. Another
article explains how some other
nations are phasing down use of
the compound in automobile
fuel.
Focusing on other topics, the
Journal chronicles a day in the
life of EPA Administrator Lee M.
Thomas. This is another in a
series in the magazine profiling
various figures at EPA. Also
included is a story by an
experienced observer reflecting
on the history of the nation's air
cleanup effort and
recommending future steps.
Another article on air quality
reports on steps EPA Region 9 is
taking to deal with the
tenacious smog in Ixjs Angeles.
An article from EPA Region 2
reports on the steps taken to
deal with a recent ground-water
pollution emergency on Long
Island. The piece is the eighth
in a Journal series on actions
by the agency's regional offices.
Concluding the issue are two
regular features—Update and
Appointments at EPA. D
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United States
Environmental Protection
Agency
Office of
Public Affairs lA-107)
Washington DC 20460
Volume 11
Number 4
May 1985
vvEPA JOURNAL
Lee M. Thomas, Administrator
Josephine S. Cooper, Assistant Administrator for External Affairs
Paul A. Schuette, Acting Director. Office of Public Affairs
John Heritage, Editor
Susan Tejada, Associate Editor
Jack Lewis, Assistant Editor
Margherita Piyor, Contributing Editor
EPA is charged by Congress to
protect the nation's land, air, and
water systems. Under a mandate
of national environmental laws,
the agency strives to formulate
and implement actions which
lead to a compatible balance
between human activities and the
ability of natural systems to
support and nurture life.
The EPA Journal is published
by the U.S. Environmental
Protection Agency. The
Administrator of EPA has
determined that the publication
of this periodical is necessary in
the transaction of the public
business required by law of this
agency. Use of funds for printing
this periodical has been approved
by the Director of the Office of
Management and Budget. Views
expressed by authors do not
necessarily reflect EPA policy.
Contributions and inquiries
should be addressed to the Editor
(A-107), Waterside Mall, 401 M
St., S.W.. Washington, D.C.
20460. No permission necessary
to reproduce contents except
copyrighted photos and other
materials.
EPA's Lead
Phasedown Action
by Richard Wilson 2
The Problems
with Misfuelers
by Margherita Pryor 6
The Lead Phasedown:
How Society Gains
by Albert L. Nichols 7
Health and the
Lead Phasedown
An Interview with
Bernard Goldstein 9
The Link Between Lead in
People and Lead in Gas
by Joel Schwartz 12
Other Nations Phasing
Down Lead in Gas
by Michael P. Walsh 13
Lead Poisoning:
A Historical Perspective
by Jack Lewis 15
A Day in the Life
of the Administrator
by Susan Tejada 19
Reflections on the
Nation's Air Cleanup
by Joseph Padgett 22
Initiatives to Deal
with LA. Smog
by Judith Ayres 25
Handling a Pollution
Emergency
by Christopher J.
Daggett 27
Update: Recent Agency
Developments 29
Appointments at EPA 31
Front cobcr: Evening rush hour
traffic in New York City. Photo
by Jon Riley. ''"Fo/io. Inc.
Design Credits:
Robert Flanagan:
Ron Farrah.
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-------
EPA's Lead Phasedown Action
by Richard Wilson
EPA experts predict
that the standard will,
in 1986 alone,
spare 172,000 children
from adverse health effects.
EPA's recently announced decision to
lower the lead content of U.S.
gasoline by 90 percent is the greatest
single step the agency has taken toward
the ultimate goal of eliminating lead in
gasoline as a public health hazard. And
that goal is, in itself, one of the most
important and challenging EPA has
pursued in its 15-year history.
At a press conference on March 4, EPA
Administrator Lee Thomas announced
the timetable for the latest initiative in
the agency's decade-long effort to
phase down the lead content of U.S.
gasoline. EPA's current standard is 1.1
grams per leaded gallon (gplg) of
gasoline. That will drop to 0.5 gplg on
July 1, 1985. On January 1, 1986, the
standard will go down to 0.1 gplg, a level
90 percent lower than the current
standard.
"There is no doubt in my mind,"
Thomas told the media, "that lead in the
environment is still a major public
health problem, and that leaded gasoline
is a major contributor to lead exposure.
Our goal today is to reduce this threat to
the health ol Americans everywhere,
especially our children, as quickly as
possible."
Health Effects
The positive health effects of the lowered
lead standard are extremely compelling.
EPA experts predict that the 0.1 gplg
standard will, in 1986 alone, spare
172.000 children from adverse health
effects ranging from anemia and
behavior disorders to mental retardation
and nerve damage. That is the number
of children whose blood lead levels will
drop below 25 micrograms per deciliter
(ug/dl). Twenty-five ug/dl is the blood
lead level the federal Centers for Disease
Control recently set as the dividing line
above which further testing and possible
medical treatment are indicated and
below which they are not.
(Wilson is Director of EPA's Office of
Mobile Sources. 1
Adults have a greater tolerance for lead
than children since their bodies and
organs are fully developed. However, the
adverse effects known to result when
adults are exposed to lead are not always
minor. Symptoms range from headaches
and irritability at low blood lead levels to
stupor, coma, and brain damage at
blood lead levels above 100 ug/dl.
Fortunately, there is some evidence that
the ill effects of lead intoxication are
reversible, at least among adults, once
the source of the poison is removed.
The positive effects of phasing down
the lead content of gasoline must be
considered in the larger context of lead
pollution in the United States.
Automobile exhaust from vehicles
burning leaded gas is by no means the
only—or perhaps even the major—cause
of severe cases of lead poisoning.
Other Lead Pollution
For example, children who are known to
have ingested leaded paint, most often
found on the peeling walls of inner-city
ghettos, account for the most extreme
instances of juvenile lead poisoning. The
Department of Housing and Urban
Development monitors this problem
under the authority of the Lead Paint
Poison Prevention Act. Similarly,
inhabitants of communities adjacent to
lead smelters had abnormally high blood
lead levels before EPA began regulating
emissions from these factories under the
Clean Air Act.
Pervasive, low-level lead pollution—not
acute lead poisoning—is the target of
EPA's phasedown of lead in gasoline.
The agency estimates that 80 percent of
all lead in the atmosphere comes from
the exhaust pipes of vehicles burning
leaded fuel. Bioaccumulation of airborne
lead particles, inhaled day in and day
out, can tip the balance toward severe
lead intoxication in children and adults
exposed to lead from other sources.
There is also reason to suspect that
even the lowest levels of lead intoxication
are harmful to mind and body.
All of these health considerations gain
added force when yet another factor is
EPA JOURNAL
-------
Leaded fuel has been Slowing through
American gas pumps for more than half
a century. EPA's action means
use of lead in gasoline will decline
dramatically.
taken into account. Hydrocarbon,
carbon monoxide, and nitrogen oxide
emissions increase dramatically when
catalytic converters are disabled as the
result of pumping leaded gas into
vehicles designed to run on unleaded
fuel.
Carbon monoxide, which can be lethal
in heavy doses, impairs mental and
visual acuity and interferes with the
transfer of oxygen from the lungs to the
cells. Hydrocarbons and nitrogen oxides.
on the other hand, react with volatile
organic compounds in the atmosphere
to generate ozone, which is the key
component in the suffocating blankets of
smog that cover such cities as Los
Angeles and Denver. Coughing, chest
pain, and shortness of breath are the
typical human response to smog.
Mechanical Ramifications
Recent research also indicates that the
"health" of U.S. engines and valves will
not be threatened by the 0.1 gplg lead
standard. Opponents of the new
standard—especially owners of pre-1970
automobiles and heavy-duty
vehicles—have argued that lowering the
lead content of gasoline would increase
problems with engine knock and valve
recession, thereby impairing engine
performance and hastening engine
wear-out.
Various government and industry
studies indicate, however, that unleaded
gasoline poses little or no threat to
automobile engines that are properly
maintained and subjected to normal use.
One experiment, conducted by the Ethyl
Corporation in the middle and late
1960s, compared the performance of 64
matched pairs of vehicles. One vehicle in
each pair used leaded gasoline, and the
other used unleaded. The cars traveled
an average of 15,000 miles per year at a
time when speed limits of 65 or 70 miles
per hour were not uncommon.
Despite these factors, only four
unleaded vehicles (six percent) required
cylinder-head replacements owing to
valve-seat recession (one vehicle required
two replacements). One vehicle in the
leaded group also required a new
cylinder head during the same period.
On the other hand, the absence of lead
showed a beneficial effect in reducing
the amount of valve-related
maintenance. Only six vehicles in the
unleaded group required valve jobs.
compared with sixteen vehicles in the
leaded group.
Savings for Drivers
Other studies have confirmed that lead
in gasoline and the scavengers added to
prevent excessive lead accumulation in
engines foul spark plugs, corrode
exhaust systems, and necessitate more
frequent oil changes. Thus, reducing the
lead content of gasoline will result in
significant maintenance savings to
vehicle owners. EPA estimates that the
new lead phasedown proposal wiil
reduce maintenance costs by
approximately 8900 million a year.
Reducing lead in gasoline will also
improve fuel economy. More elaborate
refining techniques that will be used to
boost octane despite lowered lead
content will raise the energy potential of
gasoline. Moreover, the diminished lead
content of leaded fuel will mean that it
takes longer for misluelers to damage or
disable their catalytic converters and to
foul the oxygen sensors that optimize
the air-fuel mix in newer engines. EPA
estimates that this increase in fuel
efficiency resulting from the lead
phasedown could save consumers S200
million a year.
EPA believes that few if any
automobiles operated at legal speeds
under normal loads will suffer any
engine damage as a result of the lead
phasedown. However, the agency
recognizes that certain types of trucks,
farm equipment, boats, motorcycles, and
off-road machinery are thought by some
to face greater risk because they are
more likely than automobiles to operate
at high engine speeds. Even so. EPA is
confident that the 0.1 gplg standard will
provide sufficient lead to give
protection to all engines that need it
until new additives can be developed as
viable alternatives. Several already
appear promising, although none has
yet been fully proven.
MAY 1985
-------
Americans could see
a complete ban on leaded gasoline
by 1988.
Gas Pricing Trends
The added cost to refiners of meeting the
0.1 gplg lead standard will undoubtedly
be passed along to consumers in the
form of higher pump prices for leaded
gas. But this cost must be weighed
against monetized benefits of over 81
billion a year that are expected to result
from protection against the adverse
health effects of lead and conventional
pollutants as well as vehicle
maintenance savings. (See story on
page 7.)
It is hoped that the narrowing of the
price differential between leaded and
unleaded gasoline will discourage
misfueling, which is now running at the
alarming rate of 16 percent. In fact, EPA
hopes to see the day when leaded
gasoline costs more than unleaded.
However, even though it is certain that
the new standard will make it more
expensive for refiners to manufacture
leaded gasoline than unleaded regular,
EPA is not sure this will cause prices at
the pump to flip, because service
stations may continue to treat leaded as
"the fighting grade."
A Ban on Lead?
F'ossibly the only way of eliminating fuel
switching and engine tampering is to
impose a complete ban on lead in
gasoline. For the time being, however,
EPA is hoping that a reduced price
differential plus growing public
awareness of the delayed maintenance
costs caused by misfueling will lead to a
gradual reduction in the misfueling
problem, especially when reinforced by
state enforcement efforts. (See related
story on page 6.)
Americans could see a complete ban
on leaded gasoline by 1988, seven years
earlier than the date projected last
August when EPA first proposed the new
phasedown rule. In addition to future
misfueling patterns, EPA will consider
two other factors in determining when a
ban should go into effect: the correlation
between lead exposure and hypertension
and potential problems of valve-seat wear
that may result from unleaded fuel.
The timing of the lead phaseout
depends in part on the outcome of
further investigation into the
relationship between lead exposure and
blood pressure and cardiovascular
disease. Two recently published studies
show a strong statistical relationship
between blood lead and blood pressure.
Based on those studies, EPA has
developed preliminary estimates that
suggest that the 0.1 gplg standard could
result in 1.8 million fewer cases of
hypertension in 1986 alone. The
reductions in blood pressure could, in
turn, prevent more than 5,000 heart
attacks, 1,000 strokes, and 5.000 deaths
from all causes. And those estimates
cover only white males aged 40 to 59,
the demographic group for which the
In Richmond, Va., a man has his blood
pressure checked. Preliminary research
among while males ages 40 to 59
indicates a strong correlation between
lead exposure and hypertension.
best epidemiological data are available.
Because these studies are so new, and
the scientific community needs more
time to comment on them and to see
how they accord with other studies of
lead and blood pressure, EPA did not
rely on them in setting the phasedown
schedule. They could be a key factor,
however, in the decision on a final ban,
and the agency is actively soliciting
scientific comment and review to
determine how much weight should be
given to these effects. If the suspected
relationship between lead and blood
pressure holds up under additional
scrutiny, it will provide a powerful
argument for moving swiftly to a
complete ban.
EPA JOURNAL
-------
Eiylity percent of all lead in the atmosphere
comes from the exhaust pipes
of vehicles burning leaded Juel.
Valve-Seat Wear
Before reaching a final decision on a
lead ban, EPA will also further
investigate the issue of valve-seat wear.
The agency is seeking additional
evidence on the extent of the potential
problem, including data from engine
manufacturers and additional studies of
vehicles in actual use (as opposed to
track tests run under unusually severe
conditions).
Meanwhile, strong evidence already
exists to assuage any fears that a lead
ban would cause mechanical damage to
motor vehicles, even heavy-duty trucks
and tractors. Countering the arguments
of those who regard lead as crucial to
the performance of heavy-duty vehicles
are two studies conducted by the U.S.
Army and the U.S. Postal Service. These
verify for heavy vehicles what earlier
studies have already confirmed for
automobiles: that no noticeable damage
to engine parts or efficiency results from
the use of unleaded fuel.
The Army's test involved 7,600 light-
and heavy-duty vehicles. Many of these
vehicles dated from prior to 1970 when
U.S. manufacturers began making
hardened valve seats a standard feature
of cars and trucks. The Army switched
all of these vehicles from leaded to
unleaded fuel and subjected them to
normal use for a period of three years.
No untoward maintenance problems
could be traced to the use of unleaded
fuel in these Army vehicles, not even in
trucks, tractors, road-graders, cranes.
rollers, and compressors. The overall
engine failure rate was only 0.5 percent,
which was comparable to the Army's
experience with the same fleet when it
ran on leaded fuel. Only three cases of
valve-seat recession were reported, all in
light-duty vehicles.
After this test, all the armed services
converted completely to unleaded
gasoline wherever it was available.
Pentagon sources report no special
problems, whether of engine
performance or maintenance, as a result
of this conversion.
The Postal Service study produced
similar findings. In 1980, the Postal
Service began using unleaded fuel In
1,572 1975 model-year Ford heavy-duty
trucks. Most of these trucks were on
their second or third engine rebuild or
replacement at the time of the switch to
unleaded fuel. It is believed that all of
the new and rebuilt engines in the fleet
had hardened valve inserts.
Three and a half years later, the Postal
Service had recorded 69 instances of
valve problems (a valve failure rate of 4.4
percent) and 18 cases of valve seat
problems (a failure rate of 2.2 percent).
The Ford warranty data for the same
types of engines showed comparable
valve and cylinder-head failure rates
when they were run on leaded fuel. The
Postal Service, having experienced no
significant mechanical or operating
problems from the use of unleaded fuel,
is now committed to using it in its
everyday operations nationwide.
EPA plans to work with user groups
for various types of engines and vehicles
to ascertain whether particular engines
would be at risk if lead is phased out
altogether. Moreover, the agency will be
working with manufacturers of gasoline
additives to determine the availability of
alternative additives capable of providing
valve lubrication for any engines at risk.
Only after this consultative process will
the decision be made as to when lead
usage in gasoline should be banned
altogether.
The next few years are certain to be
busy ones not only for EPA but also for
oil refiners and marketers. But the
long-term benefits of EPA's lead
phasedown will more than compensate
for any costs or inconvenience
encountered along the way. After all, it is
more than the health of America's
engines and machines that is at stake
here. It is the health of every man,
woman, and child in the United States. D
Banking and Trading
As part of the new lead phasedown
rules, EPA is allowing refiners who
reduce lead ahead of schedule to
"bank" those reductions for later
use In meeting the 0.1 grams per
leaded gallon (gplgl standard. This
approach gives extra flexibility to
individual refineries and Is
expected to save more than S200
million in potential refinery costs
over the next three years.
Banking is an extension of the
lead rights trading policy that has
been in place since 1982. This
policy allows refineries to produce
gasoline with more than 1.1 gplg if
they induce other refineries to do
better than the standard. For
example, a refinery can produce one
million gallons at 1.3 gplg if it
purchases rights from another
refinery that produces gas with
only 0.9 gplg.
The lead trading policy uses
economic incentives to achieve
environmental goals at lower cost.
In a typical quarter, about
three-fourths of all refineries either
buy or sell lead rights, and over ten
percent of the allowable lead is
traded.
Banking extends this lead
trading program by allowing
refineries that go under the
current lead limit to save the extra
reductions. The banked rights can
be used to help meet the tighter
standards that will apply in 1986
or 1987, or they can be sold to
other refiners with higher
compliance costs or facing
unexpected problems (due, for
example, to equipment
breakdowns). Banking, like
trading, saves money without
increasing the total amount of lead
allowed in gasoline.
MAY 1985
-------
The Problems
with Misfuelers
by Margherita Pryor
The next time you pull into a gas
station, check out the cars filling up
with leaded gas. It's very possible that at
least one of them has a warning
stamped under the fuel cap that reads
"Use Unleaded Fuel Only." Or check out
the piles of "used" equipment behind
some service stations or repair shops.
Twenty-eight percent of cars have had
major emissions controls removed or
disconnected.
These drivers are probably trying to
save themselves money. However, recent
studies show misfueled cars actually cost
owners about 19 cents per gallon more
than they should because of reduced
engine performance and increased
maintenance expenses. And in a lot of
states, fuel switchers and engine
tamperers are breaking the law, too.
People switch fuels for a number of
reasons. The chief of these is economic.
Leaded gas is cheaper than unleaded
fuel, by seven cents a gallon between
regular leaded and unleaded, often by as
much as 25 cents a gallon between
leaded regular and unleaded premium.
In addilion, many drivers are convinced
lead is necessary for good engine
performance, even in later-rnodel cars.
And finally, many people are still
unaware that lead has serious adverse
effects, particularly on the health of
children, and that leaded gasoline
contributes about 80 percent of all leiid
in the air.
EPA's current standard allows 1.1
grams of lead per leaded gallon of
gasoline. It was set in 1982, on the
assumption that the demand for leaded
fuel would decline as older, pre-1975
cars disappeared from the roads. Fuel
switching has upset these calculations.
Today, over 40 percent of all gas sales
are for leaded fuel. EPA estimates that
16 percent of drivers who should be
using unleaded gasoline use leaded fuel
Instead. This not only puts more lead
into the air, it also destroys catalytic-
converters—the major emission controls
for modern cars. These devices are
designed to remove carbon monoxide,
hydrocarbons, and nitrogen oxides. But
cars with malfunctioning controls have
emissions 400 percent to 800 percent
higher than those with working
converters.
(Pn/or i.s Contributing Editor qf EPA
Journal. J
While many catalysts are ruined
incidentally through the use of leaded
gas, many others have been put out of
operation deliberately. EPA surveys
indicate that at least 28 percent of all
vehicles have had major tampering with
emission controls, despite the fact that
the Clean Air Act expressly forbids such
actions by commercial repair facilities,
new car dealers, or fleet operators.
In March of this year, EPA announced
actions that not only will drastically
reduce the threat of lead to human
health, but will effectively eliminate the
incentives to misfuel.
First, lead will no longer be available
in large quantities as a cheap octane
booster. On July 1, 1985, the current
limit of 1.1 grams per gallon will be
reduced to 0.5 grams. Beginning
January 1, 1986, the standard will drop
again to 0.1 grams per leaded gallon—a
90 percent reduction from the current
limit. Reducing the lead content of
leaded gas will increase production
costs, a factor that EPA expects will wipe
out the price differential that induces
people to switch fuels.
Secondly, EPA is continuing to
investigate lead substitutes for older cars
that need it as a valve lubricant or
sealer. Studies so far indicate that the
minimum lead content needed for
protection is between 0.04 and 0.07
grams per gallon. The new limit of 0.1
grams will not only meet that need with
a margin of safety, but will also give car
owners significant maintenance savings.
Leaded gas fouls spark plugs, corrodes
exhaust systems, and leads to more
frequent oil changes. EPA estimates that
the new rules will save owners about
S200 million annually.
Even the new standard, however,
retains enough lead to cause catalytic
damage if misfueling occurs. Therefore,
a major agency goal is to continue active
federal enforcement efforts and to
encourage vigorous state programs to
require the repair of damaged vehicles
and deter tampering and misfueling.
Jurisdictions within 40 states already
A lineup of gasoline samples thai EPA
has tested for lead content. Inspectors
usually collect samples from service
stations suspected of illegally
dispensing leaded gasoline from
small-gauge nozzles that bypass a car's
fuel inlet restrictor.
hold individuals liable for these actions.
Out of 46 million vehicles subject to
inspection and maintenance (1/M)
requirements, about 11 million are also
subject to anti-tampering laws. Sixteen
states have programs that look
specifically for evidence of tampering.
No two of these programs are alike.
Some enforce through their I/M
programs, others observe retail outlets
for misfueling, still others conduct
periodic road checks. Maryland's
program, for example, relies on three
kinds of tampering checks—routine I/M,
mandatory inspection for evidence of
tampering at any change of ownership,
and police observations—any of which
can result in citations against the
owners. Cited owners not only must pay
a fine; they also are required to replace
the damaged controls. In the case of
catalytic converters, this can cost as
much as S300.
Despite the difficulties of enforcing
prohibitions against actions by
individuals, the number of states with
such programs is increasing. Many are
recognizing that misfueled and damaged
vehicles contribute substantially to their
air pollution Durdens, and that
individual owners must be held
responsible for proper operation and
maintenance of their cars.
Taken together, EPA expects that
these actions—reducing lead content in
gasoline and enforcing fuel
switching/engine tampering laws—will
significantly reduce the public's
exposure to lead, with resulting benefits
of over a billion dollars a year beginning
In 1986. These benefits include not only
maintenance savings to vehicle owners,
but also the savings from reduced levels
of other automotive pollutants and from
lowered medical costs stemming from
excess exposure to lead. D
EPA JOURNAL
-------
The Lead Phasedown
How Society Gains
by Albert L. Nichols
Benefit-cost analysis has played an
integral role in EPA's recent
rulemaking on lead in gasoline. The
initial analysis, released by EPA's Office
of Policy, Planning and Evaluation in
March 1984, showed that, despite
substantial reductions achieved through
earlier rulemakings, further tightening
of the lead limit would yield large health
gains, with benefits far in excess of the
costs. That report helped spur intensive
development of a proposed rule, issued
in August 1984, less than two years
after the previous rulemaking on lead in
gasoline had been concluded.
Additional analysis demonstrated the
feasibility and desirability of setting a
very tight phasedown schedule. The final
rule, issued in March 1985, is even more
stringent than the original proposal; it
requires that lead in gasoline be reduced
from 1,1 grams per leaded gallon (gplg)
to 0.5 gplg by July 1985 and to 0.1 gplg
by January 1986. The agency is now
considering additional steps to reduce
the health threat posed by lead in
gasoline, including a possible ban as
early as 1988.
Costs of Reducing Lead
Since the 1920s, refineries have added
lead to gasoline as an inexpensive way of
boosting octane. To meet octane
requirements with little or no lead,
refineries must engage in additional
processing, which raises costs, or use
other additives that are more expensive
than lead.
To estimate the cost of the rule, EPA
used a computer model of the refining
industry. This model, developed for the
U. S. Department of Energy, is similar to
others developed by refiners themselves
to help increase the efficiency of their
operations. It uses a series of
mathematical equations to represent
processes used in refineries. These
equations show how various inputs can
(Nichols is Director of the Economic
Analysis Division in EPA's Office of
Policy. Planning, and Evaluation.)
MAY 1985
A motorist checks the
oil in his car.
Determining the
ai'eniye cost of an oil
change was one oj
the steps in calculating
maintenance benefits
of lite lead phasedown,
be turned into different products at
varying costs, and the constraints on
industry capacity. For any given set of
final products, the model finds the least
expensive method of production.
We first ran the model specifying the
current lead limit of 1.1 grams per
leaded gallon (gplg) and computed the
cost of meeting demand for refined
petroleum products. We then re-ran the
model specifying a tighter lead limit, and
recomputed the overall cost. The
difference between the costs at the two
lead limits is the estimated cost of the
tighter standard. Many constraints were
added to the model to ensure that the
cost estimates were not unrealistically
low.
Based on this analysis, we estimate
that the rule will cost less than SI00
million in the second half of 1985 (when
the standard will be 0.5 gplg) and just
over $600 million in 1986 (the first year
that the 0.1 gplg standard will take
effect). The model also showed that
demand for gasoline and other
petroleum products can be met with
existing refining equipment and without
any increase in imports.
We also tested the effect of more
pessimistic assumptions, such as
unexpectedly high demand for
high-octane unleaded gasoline, increased
downtime for refining equipment, and
reduced availability of non-lead
additives. These analyses showed that
the 0.1 gplg rule could be met under
virtually any conditions. Potential
problems appeared only when we
imposed many adverse conditions
simultaneously, an extremely unlikely
possibility.
Benefits of the Rule
We estimated benefits in several major
categories: children's health and
educational effects associated with lead
exposure; damages caused by excess
emissions of pollutants from misfueled
vehicles; and impacts on vehicle
maintenance and fuel economy. In
addition, we also used the recently
published studies on the relationship
between blood lead and blood pressure
to make preliminary estimates of some
of the health benefits that adults might
reap from the rule.
We first estimated the impact of
-------
reduced lead in physical terms. In the
case of children's health effects, we used
statistical studies relating gasoline lead
to blood lead to project how the numbers
of children with elevated blood levels
would change if lead in gasoline were
reduced. To estimate the impact of
reduced misfueling on emissions of
conventional pollutants (hydrocarbons.
nitrogen oxides, and carbon monoxide),
we used data on the current extent of
misfueling and Increased emission rates
in misfueled vehicles, and then
combined those with projections of miles
driven by vehicles of different types.
Based on several studies comparing
matched vehicles on leaded and
unleaded gasoline, we estimated the
impact of the rule on the frequency of
exhaust system replacements, oil
changes, and spark plug changes. To
estimate reductions in cases of
hypertension, heart attacks, strokes,
and deaths from all causes related to
blood pressure, we used a recently
published study on the relationship
between lead and blood pressure and
earlier studies linking blood pressure to
cardiovascular disease. (Because the best
data were available for white males aged
40 to 59, we cautiously restricted our
estimates to that group.)
Table 1 summarizes several
important non-monetary measures of
the benefits of the phasedown for the
years 1985 to 1987. Note that the
estimates for 1985 are for the 0.5 gplg
standard, and only cover the second half
of the year. The estimates for 1986 and
1987 are for the 0.1 gplg standard, and
cover the full years. The estimates for
adult blood pressure-related effects
should be interpreted cautiously, as they
Table 1. Non-monetary Measures of the Benefits of Lead Phasedown
1985 1986
1987
Reduction in number of children above 25 64.000 172.000 156.000
micrograms per deciliter (ug/dl)
Reduction in tons of emissions of conventional pollutants
Hydrocarbons 0 244,000 242,000
Nitrogen oxides 0 75,000 95,000
Carbon monoxide 0 1.692,000 1.691.000
Reductions in blood pressure-related effects in males aged 40-59
Hypertension 547.000 1,796,000 1,718.000
Myocardial Infarctions 1.550 5.323 5.126
Strokes 324 1,109 1,068
Deaths 1,497 5.134 4,942
Table 2. Costs and Benefits of Lead Phasedown (millions of dollars)
1985 1986
1987
Benefits
Children's health effects
Conventional pollutants
Maintenance
Fuel economy
Total Benefits Excluding Blood Pressure
Total Refining Costs
Net Benefits Excluding Blood Pressure
Adult blood pressure benefits
Net Benefits Including Blood Pressure
S223
0
102
35
360
96
264
1.724
$1.988
S600
222
914
187
1.924
608
1.316
5.897
87,213
S547
222
859
170
1,799
558
1.241
5,675
$6,916
are preliminary and EPA has not relied
on them in reaching decisions on the
rule just promulgated, pending
additional scientific review.
These estimates indicate substantial
benefits. They do not include the
maintenance benefits, however, and it is
difficult to compare them to the costs,
measured in dollars. Thus, the next step
was to value the benefits in dollar terms.
For the maintenance benefits, this step
was relatively easy; it involved, for
example, determining the average cost of
an oil change.
For the other benefit categories.
however, valuation is much more
difficult and controversial. How much is
it worth to prevent a child from having a
dangerously high level of blood lead, or
an adult from suffering a stroke? For the
most part, we did not attempt to assign
value to intangibles, such as pain and
suffering. Instead, we focused on more
easily quantified benefits, such as
reduced costs for medical care,
compensatory education, crops damaged
by pollution, and lost work days. We did,
however, tackle the difficult and
controversial task of placing a dollar
value on reductions in the risk of death.
EPA's Regulatory Impact Assessment
guidelines suggest a range of S400.000
to 87 million per statistical life saved. We
used a value from the lower end of that
range, 81 million per case.
Comparing Costs and Benefits
Despite the incomplete nature of the
benefit estimates, they outweigh the
costs of the rule by more than three to
one, as shown in table 2. If the
preliminary estimates related to blood
pressure are included, the ratio of
benefits to costs jumps to better than
ten to one.
As part of our analysis, we also
examined a wide range of alternative
standards, and found that tightening
the lead limit raised benefits
substantially more than it increased
costs. Although many other factors were
important in the agency's decisions, it is
clear that the very large health gains
estimated as part of the benefit-cost
study helped speed up the regulatory
process and contributed to the rapid
phasedown schedule that was
promulgated. Q
8
EPA JOURNAL
-------
Health and the
Lead Phasedown
An Interview with Bernard Goldstein
Increased evidence on the health
effects of Lead was one of the main
reasons for the recent EPA action
phasing down lead in gasoline.
EPA Journal interviewed a key
agency spokesman on the subject.
He is Bernard Goldstein, Assistant
Administrator for Research and
Development. The interview
follows:
In Washington. D.C.. a technician takes
ajinger prick blood sample.from a child
for initial screening for lead poisoning.
The D.C. government has hud a lead
poisoning prevention program for youny
children since 1973.
jfj Could you tell us what the most
serious adverse health effects of lead
are?
A
The most seriously affected are
children. The effect of lead on their
brains is what concerns us most.
Children become vegetables at a high
enough dose. And higher than that, they
can die.
9
Why are children more
susceptible than adults?
A child s brain seems to be more
susceptible because it's growing. Also,
children tend to take in much more lead
than adults do. They take in lead from
more sources. They put their hands into
their mouths all the time. They eat little
paint chips that come off the wall that
have lead. There's also lead in dirt that
comes from automobile exhaust.
9
too.
I guess they're outdoors more,
•^ They are outdoors more. They also
breathe more than adults. We're sitting
around here just talking, but if you had
a couple of kids in the room with us, the
odds are they'd be running around the
room. You breathe more if you run. Even
at rest, children tend to breathe a little
bit more than adults do, so the dose of
anything that is in the air will be greater
in children.
J5J Could you explain the scientific
basis for the recent decision of the
Centers for Disease Control (CDC) to
lower the maximum tolerance level for
lead in children?
A
Really, it's a medical basis,
provided by experts CDC brought
together. There is sufficient evidence
that lead at relatively low levels—lower
levels than were thought before—may
have an adverse effect. What CDC has
developed is a guideline for practicing
physicians and local health departments.
The guideline says at what level of
blood lead you should thoroughly
investigate a child, or bring the child to
the hospital, or consider at the very least
repeating the tests and beginning
therapy.
In the past, if the blood lead level was
below 30 micrograms per deciliter
(ug/dl). there was little reason for you to
do anything or be too concerned about
it. Now. you'd better start being
concerned at a blood lead level of 25
ug/dl. That's an enormous difference;
there is a very large number of kids
who have blood lead levels between 25
and 30 ug/dl, far more than there are
between 30 and 35.
So now, as a result of the CDC
decision, all children with blood lead
levels between 25 and 30 at the very
least have to have further medical
evaluation. And, of course, it's
expensive, even assuming that there's no
harm done at that lead level in the child.
A lot of recent information suggests
there are effects of lead at lower levels
than we suspected before. They range
from biochemical effects, where if you
take blood tests and look at enzyme
levels, you'll find changes in those levels
or changes in the levels of intermediate
substances piled up behind a
lead-poisoned enzyme. For example,
consider an enzyme active in vitamin D
metabolism — and vitamin D is obviously
important to a growing child since it has
to do with bones. There are visible
effects at very low levels of blood lead.
Some of the more important new
evidence further suggests, though
there's no proof, that lower levels of lead
affect children's I.Q., that the child does
not develop with the same I.Q. as if
there had not been lead exposure.
How did EPA take this evidence
into account?
A
EPA has been very conservative in
that we have not assumed low-level lead
effects in our cost-benefit analysis.
That's an important point because the
lead industry and others have accused
us of taking one side in the controversy
over whether blood lead levels below, say,
30 ug/dl produce any adverse effect on
children's brains. What EPA has said is
that we do not know for sure, although
my belief is that lead probably does
affect I.Q. However, we have not
attached any dollar costs to low-level lead
effects on brain function. What that
means is that since the cost-benefit
dollar calculation is so overwhelmingly
in favor of there being more cost than
-------
benefit from lead, if we had attributed
any cost to low-level lead effects, the
benefits would have been even greater.
If anything, we have underestimated
the benefits of removing lead from
gasoline by not ascribing any l.Q. effects
to the blood lead levels below 30 ug/dl.
That is very important, because some
people may be confused by the
controversy into believing that we have
somehow or other ascribed costs to
blood lead levels below 30 ug/dl in terms
of central nervous system effects. We
have not done so because we don't
believe those effects are proven, although i
we do feel that they are likely.
J3 Do any scientific studies show a
correlation between blood lead levels
and lowered l.Q. in adults?
•**• No. If you, as 1 have, take care of
people who have lead poisoning as
adults, some of the symptoms are
decreased mentation, but they clear up.
9
A
What is mentation?
9
A
So it's reversible.
Well, for instance, I saw a young
man just before I came to EPA, at a
health clinic in New Jersey. His hobby
was restoring old homes. He spent a lot
of time using a high-powered sander to
get rid of old paint. What he did was
make tiny breathable particles of lead
paint. After a few months his blood lead
level was over 90 ug/dl. He was an
accountant, and he noticed that while
he used to be able to keep a string of
numbers in his head, and add them all
together, he couldn't do it anymore. He
had to use a calculator. After he was
treated for lead poisoning, he could
again count and add six or seven
numbers in his head. He didn't think
that there was any difference from before
the lead exposure.
It seems to be, but that's not an
important test of l.Q. If, in fact, we know
that his l.Q. beforehand was 106. and
you ask me now if his l.Q. was 104 after
the exposure and treatment, I couldn't
tell you. With children, however, by
using l.Q. tests, we seem to see a
difference between those kids who had
elevated blood levels and those who did
not. Now, we couldn't do a study where
you do l.Q. tests before you poison kids
with lead, test them afterwards, and
then again after treatment. Further, you
can't do a study of animals because you
can't measure l.Q. in a rat. We only test
very gross behavioral effects in animals.
And you certainly do get gross behavioral
effects in animals due to lead.
In I'.1' 'u (ituiii til
-------
due to EPA action. What happens, of
course, is that as more information is
developed, we take further action. The
insinuation that nothing happened
between 1969 and 1985 is simply wrong.
There has been a marked decrease in the
blood lead levels in the U.S. population
during that time.
Joj What recent scientific findings
have caused EPA to accelerate the lead
phasedown?
A
The additional evidence of
biochemical effects at very, very low
levels of blood lead. Additional evidence
of brain effects, central nervous system
effects, which includes, as I mentioned,
the EPA study showing brain-wave
changes in children at these low levels. A
whole series of studies which have
indicated much more subtle levels of
damage. The thread running through it
all is that our science has improved. We
can now detect effects at levels that we
really couldn't detect before.
Q
How about the health effects of
lead in paint and in emissions from
lead smelters? How much lead
poisoning is attributable to those
sources as opposed to gasoline fumes?
**• If you look at a lead-poisoned child,
with blood lead levels of about 80 ug/dl
of blood, you're looking at a child who
has most of his body lead from a source
other than gasoline, other than what
comes out of a tailpipe. They are usually
being poisoned by lead paint in old
buildings.
By the same token, however, body lead
burden is in a dose-responsive fashion
responsible for the toxicity. So the
higher the dose, the more toxic the child
is.
In other words, if the child complains
of a stomach ache and might be just a
little lethargic, more lead might actually
induce a coma. There's no question that
the child's elevated body lead burden is
added to by the gasoline. Now if you get
down to lower blood lead levels, like 25
ug/dl, you're talking about a situation
where it's quite conceivable that a
significant contribution to that situation
was the gasoline lead as compared to
other sources of lead. We must not forget
that gasoline lead comes out as particles
in the exhaust. The particles settle on
the ground. Kids who put dirt in their
mouths will ingest lead particles.
EPA has the mandate to do something
about airborne lead. We have a
responsibility to the public to do so, and
we are. However, the responsibility to
remove lead from the walls of homes
belongs to another part of the federal
government. They, by the same token,
cannot address the airborne lead issue
as we can.
In 1980, the National Academy of
Sciences criticized lack of coordination
and integration in the way various
federal agencies regulate lead. Has
anything been done since 1980 to
improve coordination?
**• I don't know about the
coordination problem. We have our
mandate and other agencies have theirs.
However, with certain types of
compounds, it's difficult to determine
who's in charge of what aspect of the
problem. Then things get caught in the
cracks. That's not true at EPA. It is
quite clear that when it comes to lead in
gasoline, EPA — and only EPA — has that
mandate. Our approach to the lead in
gasoline issue Is simple and
straightforward. But when you talk
about lead from a smelter, we have the
mandate once it gets outside the
smelter, and the Occupational Safety
and Health Administration (OSHA) has
the mandate within the smelter.
J3 How would you rank this lead
phasedown action in importance?
It's one of the most important. It's
going to have a major positive impact on
the health of the public for a long time
to come.
Would you say this is an example
of the usefulness of environmental
research?
Absolutely. Without the science, we
simply could not have gone in the
direction we're going. It's the science
that backs it up, that gives us the
analysis we need to support regulating
lead.
J2> Lawrence Blanchard of the Ethyl
Corporation has said, "In over 60 years,
no one has ever found a single person
to suffer any identifiable health effects
from lead in the general atmosphere."
Would you care to comment?
**• It's a statement which ducks the
issue. As I say, if you do have an
identifiable lead-poisoned individual, the
lead source is going to be not just in the
atmosphere, but from other sources as
well. In our bodies right now we have
lead that comes from the air we breathe.
It also comes from the lead in the water
that we drink because there's some lead
soldering in the pipes. There's going to
be a little lead in some of the food that
we eat. So you cannot point to a
lead-poisoned kid and say that poisoning
is solely due to leaded gasoline.
However, you can point to that kid
and say that if there had not been lead
in the air, the kid would not have been as
sick; the body lead burden would not
have been as high. We can certainly
point to literally hundreds of thousands
of children in whom the body lead
burden is so high that the contribution
of gasoline led the CDC to tell physicians
that they must re-examine the child. Do
something about it. Get their body lead
burden reduced, because of the added
amount that's contributed by gasoline
lead. No question about that. Death is
not the issue. Poisoning and its harmful
effects—that's the issue.
9
How much of the problem would
you estimate we're going to take care of
with the phasedown?
**. Well, close to half the children with
blood lead levels over 25 ug/dl will now
be below that level. That's the magic
dividing line the CDC has given us.
That doesn't mean that you have
gotten rid of all the problems. We still
have children who will be poisoned by
lead. And we still will have lead burdens
that are intolerable in that they are
responsible for adverse effects. The
control of gasoline as a major source of
lead is a very major step along the way.
9
^7 Is there any particular lesson that
you would draw from the whole
experience with the phasedown, the
research, the interaction and the
follow-through, and so on?
**• We always have to recognize that
there are going to be people who have
different points of view on these issues.
Industry has an honest belief in its
differences with us on these problems.
The history of the agency has been that
we have been unsuccessful in
approaching issues in which we do not
have a credible, scientific base. Where
we do have a credible, scientific base, we
have been more successful. And I think
lead is an example of that. We can move
on lead, not because we are waving a
banner saying lead is a pollutant and it
must be bad for us, but because we have
sound, scientific information which
allows us to put into a very objective
mode the benefits and costs that we will
get from lead, and to allow us to
convince the public that, in fact, we are
doing the right thing. I hope in the long
run that this will also convince the
courts.
When you have that scientific
background, you can deal with
controversy and differences of opinion?
MAY 1985
1 1
-------
•**• Yes, and we can deal with it from a
position of strength. We have
approached the lead phasedown in a
very carefui, cautious way. We have
evaluated every aspect of the matter.
We've not just chosen those facts that
make our case and ignored those facts
which will make someone else's case.
We have reviewed everything we
possibly can in this area. We've brought
in the scientific community to peer
review everything we've done. We've
given every opportunity for the
public to comment. We've taken
everything into consideration, and based
upon all that, we've come to this
judgment. Without that process, I don't
think we could be successful.
j£5 Do you have any further
comment?
A
One of the issues that the lead
industry raises is that the American
public will demand octane. A way to get
octane is by adding aromatic
compounds. One of the aromatic
compounds which may get added to
replace lead is benzene. Benzene causes
cancer. Therefore, it is said that removal
of lead is a foolish approach by EPA
because this will end up causing more
cancer since there will be more benzene
in the air. One Nobel Prize winner came
to me and said, "Isn't this an example of
how stupid you people are? Getting lead
out will result in more cancer-causing
problems."
EPA's answer is obvious: anytime you
burn anything, you make mutagenic
agents. Many of these compounds are
carcinogenic, or cancer-causing. We
have, in fact, as part of the air toxic
program, arrived at a rough estimate of
about how many people die each year
from lung cancer due to products of
incomplete combustion coming out of
automobile exhaust. If you put a
catalytic converter on an automobile,
you convert cancer-causing polycyclic
compounds into non-cancer-causing
agents. Most of the mutation capability
of particles in urban air is ascribable to
cars that do not have functioning
catalytic converters. To the extent that
you have a working catalytic converter
you get rid of these compounds. To the
extent that lead poisons the catalytic
converter, it is obviously making more of
those compounds available. Any estimate
of the number of additional cancer
deaths clue to increased benzene that
might be put into low-lead gasoline is
completely swamped by the much larger
number that would be due to the
amount of incompletely burned
carcinogens that corne out of a tailpipe
from lead-poisoned catalysts. D
The Link Between Lead in
People and Lead in Gas
by Joel Schwartz
Since the mid-1970s, when EPA began
regulating lead in gasoline, a crucial
question has been, "How much of the
lead in people comes from gasoline?"
A preliminary answer came in 1979,
when Dr. Irwin Billick of the U.S.
Department of Housing and Urban
Development published data
demonstrating a strong correlation
between gasoline lead use in the New
York metropolitan area and the average
blood lead levels of children screened for
lead poisoning in New York. This
correlation was particularly striking
because those children were chosen as
most likely to have high exposure to lead
from paint, which would be expected to
obscure any relationship with gasoline
lead.
When EPA began to consider new
regulations limiting lead in gasoline, the
agency was especially concerned about
the impact those rules would have on
the distribution of blood lead levels
throughout the U.S. population. To
assess that relationship, we examined
data from the second National Health
and Nutrition Examination Survey. This
survey—containing medical,
demographic, and nutritional
information on a representative sample
of the U.S. population—enabled the
agency to assess the relationship
between gasoline lead and blood lead
TOTAL LEAD USED PER 6 MONTH PERIOD
ilOOO tons)
1_10 AVERAGE BLOOD LEAD
, ~ 'microcj^irns fief.1 '• II
using data on 10,000 individuals.
The figure, below, which plots lead in
gasoline and lead in blood over time,
shows the striking relationship. Note
how closely changes in blood lead follow
changes in gasoline lead, tracking
short-term seasonal fluctuations as well
as the long-term downward trend caused
by earlier EPA rules. When we control for
other factors that affect blood lead levels
(including age, race, sex, income, degree
of urbanization, and lead solder in food
cans), the relationship remains strong.
We estimate, for example, that the
reductions in gasoline lead from 1976 to
1980 caused a 40 percent drop in blood
lead levels.
EPA also examined several other sets
of data on children In New York,
Chicago, and the national Centers for
Disease Control screening program as
well as data on pregnant women in
Boston. All data showed the same strong
relationship between gasoline lead levels
and lead in people's blood. In addition,
an Italian study, which altered the
isotope of lead used in gasoline in Turin,
Italy, found that the isotope of lead in
people's blood was likewise altered.
Similar studies in the United States
found the same strong relationship.
Using this relationship, EPA predicted
that, in 1986 alone, as a result of the
recently announced reduction of lead in
gasoline, 172,000 fewer children would
require medical treatment for excessive
blood-lead levels. Cumulatively, there
should be over a million fewer cases by
1992. D
(Schwartz is a reynlatury impact
analyst in El'A's Office of Policy.
Planning, and Evaluation.)
60
soil;
1976
1977
1978 | 1979
1980
12
EPA JOURNAL
-------
Selbstbedienung
Other Nations
Phasing Down
Lead in Gas
by Michael P. Walsh
(Walsh is a consultant involved in a
atudy by the Organization for Economic
Cooperation and Development in
Europe on the impact of transportation
on the environment. He was Deputy
Assistant AdministratorJor Mobile
Source Air Pollution Control at EPA from
1978 to 1981.)
After several decades of increasing use
of lead in gasoline, many nations
appear to be coming full circle and, like
the United States, are reducing the
amounts of lead in the fuel used in
automobiles. In fact, one country, Brazil,
is phasing out gasoline entirely, in favor
of ethanol, and in Japan over 90 percent
of all gasoline is unleaded.
One of the major uses of lead in the
modern world is in gasoline. This
followed the discovery in 1921 that
adding lead to gasoline raised octane
levels. Because of this and other growing
uses of lead, human lead exposures have
been increasing for many generations. It
is now estimated that lead exposures of
modern man all over the world are 100
times greater than background or
"natural" levels. Studies of annual arctic
ice layers in Greenland show that lead
levels have risen over the whole of the
earth's surface.
Evidence has been accumulating that
children in cities suffer serious adverse
health consequences when the lead
added to gasoline is emitted from
vehicles, and very recent data link such
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Hciulihors both in rc.sfnriiru; the lend
content oj fuel and in introducing
unleaded
emissions to high blood pressure in
adult males. Further, the use of lead
disables catalytic converters that have
been demonstrated to reduce emissions
of hydrocarbons and other noxious gases
in vehicle exhaust fumes.
Because of these problems, the United
States has dramatically reduced the lead
content ol gasoline over the past decade.
EPA's latest rules will reduce the total
lead content even further to 0.1 grams
per gallon (0.03 grams per liter) by
January 1986; ultimately, it is hoped
the permissible level will be reduced to
zero.
If this happens, the U.S. will be the
first country to eliminate lead in
gasoline completely, but many other
countries are moving in the same
direction by lowering the permissible
amounts of lead added to gasoline or
MAY 1985
13
-------
requiring the introduction of at least one
grade of unleaded fuel. And it is
anticipated that a number of nations
will move swiftly to follow the new U.S.
standards.
The reasons for these reductions vary.
In some countries, the major concern is
with the health problems created by lead
exposure. In others, the primary
motivation is to allow the use of catalytic
converters to reduce other pollutants
from cars. Foreign automobile
manufacturers have for years been
exporting to the United States only cars
designed for unleaded gasoline.
Prior to the mid-1970s, the lead
content of gasoline throughout Europe
averaged about 0.8 grams per liter (gpl),
or about three times the amount
permitted in the United States prior to
the most recent EPA actions. West
Germany unilaterally adopted a
maximum level of 0.15 gpl in 1976 for
regular grade fuel with the intention of
increasing control opportunities for
other motor vehicle pollutants.
After intense discussion, the ten
members of the European Economic
Community (the Common Market
nations) agreed that all member
countries should set standards between
0.15 and 0.4 gpl. This was a major step
towards reduction of lead in the
atmosphere.
Major opposition to lead restrictions
during the late 1970s came from the
United Kingdom. The British believed
lead additives were important for energy
conservation. By 1983. however, the
United Kingdom reversed its position
after a comprehensive review of the
latest lead and health information by the
Royal Commission on Environmental
Pollution concluded, "the safety margin
between the blood lead concentrations in
the general population and those at
which adverse effects have been proven
is too small....It would be prudent to
take steps to increase the safety margin
of the population as a whole." The report
continued, "measures should be taken to
reduce...dispersal of lead wherever
possible."
Almost immediately after the report
was issued, the United Kingdom
petitioned the Common Market to
further reduce lead in gasoline and to
introduce lead-free fuel by J 990 at the
latest. Several other countries, including
West Germany, endorsed the proposal
and, in 1984, the Common Market
proposed a new directive allowing
member countries to mandate the
availability of unleaded fuel by as early
as 1986, to require at least one grade of
unleaded fuel in each country by 1989,
and to restrict the lead content of the
remaining leaded fuel to a maximum of
0.15 gpl that same year. On March 20 of
this year, the Common Market formally
approved this proposal. Unleaded
gasoline has, in fact, already been
introduced in Germany.
European non-members of the
Common Market such as Austria.
Sweden, and Switzerland are also on the
cutting edge of lead reductions and are
generally moving as fast or faster than
most neighbors.
In Japan, lead reduction has been the
greatest in the world so far. Prior to
1975, all gasoline sold in Japan
contained lead, whereas today over 90
percent is unleaded. In 1983, the
maximum lead content was pegged at
0.13 gpl. far below the
about-to-be-changed U.S. standard.
Hong Kong has reduced the lead
content of gasoline twice within the past
two years to the current maximum of
0.3 gpl. Singapore has moved to a lead
level of 0.4 gpl. Malaysia has just decided
to go to a similar level on July 1 and has
indicated its intention to go to 0.15 gpl
by 1990.
Australia, motivated primarily by a
desire to reduce carbon monoxide and
hydrocarbon emissions through use of
catalytic converters, will widely
distribute unleaded gasoline by July 1 of
this year. Further, all new
gasoline-fueled vehicles manufactured
after the end of this year must operate
satisfactorily on unleaded fuel of 91 to
93 octane.
The USSR, to conserve available lead
for military applications, has prohibited
leaded gasoline in the Soviet Union's
largest cities since 1959.
Canada is following the U.S. in
phasing down leaded gasoline, but has
not yet adopted the EPA's new. more
stringent standards. In Brazil, normal
gasoline is being eliminated. All new
cars built in the last three years run on
100 percent ethanol. Older cars use
gasoline with a 20 percent ethanol
content.
Interestingly, some of the Arab
nations, where automobile traffic has
hitherto not created much of a pollution
problem, are beginning to look at the
issue. Other countries with large urban
populations, such as Mexico and Israel,
are faced with such severe economic
constraints that conversion to unleaded
gasoline has been deferred.
The foregoing represents considerable
progress and a major thrust towards
eventual worldwide reduction or
elimination of lead in gasoline, especially
in crowded urban areas. Although lead
residues will remain with us for many
years, at least the health problems
created by peak urban exposures will be
reduced for many million people. It's a
real reversal of the upward global lead
pollution trends of the last seven
decades. D
14
EPA JOURNAL
-------
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Lead was a key component in face
powders, rouges, and mascaras; the
pigment in many paints ("crazy as a
painter" was an ancient catch phrase
rooted in the demented behavior of
lead-poisoned painters); a nifty
spermicide for informal birth control;
the ideal "cold" metal for use in the
manufacture of chastity belts; a sweet
and sour condiment popular for
seasoning and adulterating food: a wine
preservative perfect for stopping
fermentation or disguising inferior
vintages; the malleable and inexpensive
ingredient in pewter cups, plates,
pitchers, pots and pans, and other
household artifacts; the basic
component of lead coins; and a partial
Ingredient in debased bronze or brass
coins as well as counterfeit silver and
gold coins.
Most important of all was lead's
suitability as inexpensive and reliable
piping for the vast network of plumbing
that kept Rome and the provincial cities
of the Roman Empire supplied with
water. Indeed, the very word "plumbing"
comes from the Latin word for lead,
plumbum, The lead pipes that were the
vital arteries of ancient Rome were
forged by smithies whose patron saint,
Vulcan, exhibited several of the
symptoms of advanced lead poisoning:
lameness, pallor, and wizened
expression.
Addicted to Lead
The Romans were aware that lead could
cause serious health problems, even
madness and death. However, they were
so fond of its diverse uses that they
minimized the ha/ards it posed. Romans
of yesteryear, like Americans of today,
equated limited exposure to lead with
limited risk. What they did not realize
was that their everyday low-level
exposure to the metal rendered them
vulnerable to chronic lead poisoning,
even while it spared them the full
horrors of acute lead poisoning.
The symptoms of acute lead
intoxication appeared most vividly
among miners who were thrown into
unhealthy intimacy with the metal on a
daily basis. Romans reserved such
debilitating and backbreaking labor for
slaves. Some of these unfortunates were
forced to spend all of their brief and
blighted lives underground, out of sight
and out of mind. The unpleasantness of
lead mining was further neutralized late
in the Empire when the practice was
prohibited in Italy and consigned
completely to the provinces.
Lead smelting, which had once been
commonplace in every Roman city and
town, eventually followed mining
operations to the provinces. Italy, the
heart of imperial Rome, grew tired of the
noxious fumes emanating from lead
smelting forges. The obvious damage to
the health of smithies and their families
was a matter of little or no concern.
Roman aristocrats, who regarded labor
of any sort as beneath their dignity.
lived oblivious to the human wreckage
on which their ruinous diet of lead
depended. They would never dream of
drinking wine except from a golden cup.
but they thought nothing of washing
down platters of lead-seasoned food with
gallons of lead-adulterated wine.
The result, according to many modern
scholars, was the death by slow
poisoning of the greatest empire the
world has ever known. Symptoms of
"plumbism" or lead poisoning were
already apparent as early as the first
century B.C. Julius Caesar for all his
sexual ramblings was unable to beget
more than one known offspring. Caesar
Augustus, his successor, displayed not
only total sterility but also a cold
indifference to sex.
The first century A.D. was a time of
unbridled gluttony and drunkenness
among the ruling oligarchs of Rome. The
lead concealed in the food and wine they
devoured undoubtedly had a great deal
to do with the outbreak of
unprecedented epidemics of saturnine
gout and sterility among aristocratic
males and the alarming rate of infertility
and stillbirths among aristocratic
women.
Still more alarming was the
conspicuous pattern of mental
incompetence that came to be
synonymous with the Roman elite. This
creeping cretinism manifested itself
most frlghteningly in such clearly
degenerate emperors as Caligula, Nero,
and Commodus. It is said that Nero
wore a breastplate of lead, ostensibly to
strengthen his voice, as he fiddled and
sang while Rome burned. Domitian, the
last of the Flavian emperors, actually
had a fountain installed in his palace
from which he could drink a
never-ending stream of leaded wine.
Medieval and Renaissance Lead
During the Middle Ages, lead was widely
used by alchemists as a key component
in procedures thought to be capable of
generating gold from baser metals. Lead
served an even more lofty function when
leaded type launched Gutenberg's galaxy
late in the fifteenth century. Mass
printing was crucial to the eradication of
ignorance that led to the upheavals of
the Reformation and the Enlightenment.
Kinkier and more destructive uses of
lead never lagged far behind. The
advantages of the metal as an invisible
and slow-acting poison were not lost on
the Lucrezia Borgias and Catherine de
Medicis of Renaissance Europe. Lead
was known to be extremely convenient
for eliminating inconvenient relatives. In
fact, the world-weary French jokingly
referred to the metal as poudre de la
succession—or succession powder.
Another sinister latter-day use of lead
was, of course, in the mass production
of pistols, rifles, and cannons and the
ammunition designed to blaze a bloody
trail from their barrels.
Lead mining and smelting began in
the New World almost as soon as the first
colonists were settled. By 1621 the metal
was being mined and forged in Virginia.
The low melting temperature of lead
made it highly malleable, even at the
most primitive forges. Furthermore,
lead's resistance to corrosion greatly
enhanced its strength and durability.
Technological progress in the American
colonies and the American republic was
to owe a great deal to this useful and
abundant metal.
By the twentieth century, the U.S. had
emerged as the world's leading producer
and consumer of refined lead. According
to the National Academy of Science's
report on Lead in the Hitman
Environment, the United States was by
1980 consuming about 1.3 million tons
of lead per year. This quantity, which
represents roughly 40 percent of the
world's supply, translates into a usage
rate of 5,221 grams of lead per American
per annum: a rate of dependence on lead
and lead-containing products nearly ten
times greater than that of the ancient
Romans! According to Jerome O. Nriagu,
the world's leading authority on lead
poisoning in antiquity, the comparable
Roman rate of lead usage was
approximately 550 grams per person per
year.
Not the least significant of those U.S.
lead uses, although the one subject to
the sharpest decline in the past decade,
has been in the automotive industry.
Since 1923—with a brief interruption in
1925—the U.S. has made extensive use
of tetraethyl lead as an anti-knock,
octane-boosting gasoline additive.
In 1923, motorists gus up at pumps in
Dayton, Ohio. This service station was
the first to sell leaded gasoline to the
public.
16
EPA JOURNAL
-------
Running on Lead
Considerable ballyhoo surrounded the
introduction of tetraethyl lead in the
early 1920s, Iodine, aniline, selenium,
and other substances had all fallen by
the wayside in the frantir search for a
fuel additive that would improve engine
performance and reduce engine knock.
Then in December 1921. three General
Motors engineers—Charles Kettering.
Thomas Midgeley. and Thomas
Boyd—reported tremendous success
with their first test of tetraethyl lead.
Through the Ethyl'Corporation,
then a GM subsidiary, GM quickly
began touting this lead compound
as the virtual savior of the American
automobile industry.
The discovery was indeed extremely
important. It paved the way for the
development of the high-power,
high-compression internal combustion
engines that were to win World War II
and dominate the U.S. automotive
industry until the early 1970s.
Unfortunately, the use of tetraethyl
lead created almost as many problems
as it solved. The first danger sign was
the mysterious illness that forced
Thomas Midgeley to spend weeks
convalescing in the winter of 1923.
Midgeley had been experimenting rather
recklessly with various methods of
manufacturing tetraethyl lead, and he
did not at first realize just how
dangerous the substance was in its
concentrated liquid state.
The deadliness of tetraethyl lead was
sadly confirmed in the summer of 1924.
Workers engaged in producing the
additive fell sick and died at several
refineries in New Jersey and Ohio.
Banner headlines greeted each new
fatality until a total of 15 workers had
lost their lives—and their minds.
Terrifying rumors circulated about the
madness that had put some of the
doomed into straitjackets before it put
them six feet under. It was not long
before journalists were calling leaded fuel
"loony gas." Ironically, the gas in
question was routinely dyed "a wine
color" that made it reminiscent in more
ways than one of something served at a
Roman orgy.
In May 1925. the Surgeon General
temporarily suspended the production
and sale of leaded gasoline. He appointed
a panel of experts to investigate the
recent fatalities that had "occurred in
the manufacture and mixing of the
concentrated tetraethyl lead."The panel
was also asked to weigh "the possible
danger" that might arise "from . . . wide
distribution of a lead compound"
through its sale as a gasoline additive.
Industry dominated the Surgeon
General's investigatory committee, which
included only one genuine
environmental visionary, Dr. Alice
Hamilton of Harvard University. The
Coolidge Administration gave the panel
just seven months to design, run, and
analyze its tests.
The committee's final report.
published in June 1926. complained of
the time constraints under which it had
been forced to operate. Seven months
was "not sufficient," argued the panel.
"to produce detectable symptoms of lead
poisoning" in experimental subjects
because of the very slow gestation of that
toxicological syndrome.
Nevertheless, the Surgeon General's
panel ruled that there were "no good
grounds for prohibiting the use of ethyl
gasoline ... as a motor fuel, provided
that its distribution and use are
controlled by proper regulations." The
coming decades of Depression, total war,
Product the General flotors Research Corporation
MAY 1985
17
-------
and post-war boom were hardly
conducive to the implementation of
"proper regulations" for leaded gasoline.
Indeed, no compulsory standards were
set for the industry until the early 1970s
when EPA began its long, hard struggle
to phase down lead levels in U.S.
gasoline.
One saturnine prophecy marred the
otherwise sanguine 1926 report to the
Surgeon General. By 1985 these words
were to reverberate with particular
resonance down the corridors of time:
"It remains possible that, if the use of
leaded gasolines becomes widespread,
conditions may arise very different
from those studied by us which would
render its use more of a hazard than
would appear to be the case from this
investigation. Longer experience may
show that even such slight storage of
lead as was observed (among human
guinea pigs] In these 11925) studies
may lead eventually to recognizable
lead poisoning or to chronic
degenerative diseases of a less obvious
character. In view of such possibilities
the committee feels that the
investigation begun under their
direction must not be allowed to lapse
.... With the experience obtained
and the exact methods now available.
it should be possible to follow closely
the outcome of a more extended use of
this fuel and to determine whether or
not it may constitute a menace to the
health of the general public after
prolonged use or under conditions not
now foreseen. . . . The vast increase in
the number of automobiles
throughout the country makes the
study of all such questions a matter of
real importance from the standpoint
of public health."
Needless to say, this advice fell on deaf
ears during the gin-soaked, jazz-crazed
Roaring Twenties.
Voluntary Standard
In 1927 the Surgeon General set a
voluntary standard for the oil industry to
follow in mixing tetraethyl lead with
gasoline. This standard—3 cubic
centimeters per gallon
(cc/g)—corresponded to the maximum
then in use among refiners, and thus
imposed no real restraint. Even without
prodding, however, the industry did take
giant strides toward instituting safer
working conditions in oil refineries,
thereby protecting individual laborers in
the microcosm of the workplace.
Three decades later, the Surgeon
General actually raised the lead standard
to 4 cc/g (the equivalent of 4.23 grams
per gallon). This voluntary standard
once again represented the outside
range of industry practice. Nevertheless,
the Surgeon General concluded in 1958
that a loosening of the voluntary
standard posed no threat to the health
of the average American: "During the
past 1 1 years, during which the greatest
expansion of tetraethyl lead has
occurred, there has been no sign that
the average individual in the U.S. has
sustained any measurable increase in
the concentration of lead in his blood or
in the daily output of lead in his urine."
The actual industry average during the
1950s and the 1960s hovered in the
vicinity of 2.4 grams per total gallon.
The Department of Health, Education
and Welfare (HEW), which was home to
the Surgeon General starting with the
Kennedy Administration, had authority
over lead emissions under the Clean Air
Act of 1963. The criteria mandated by
this statute were still in the draft stage
when the Act was reauthorized in 1970
and a new agency called EPA came into
existence.
By then, the adverse effects of
America's decades-old addiction to fossil
fuel in general and leaded fuel in
particular were becoming obvious to all.
In January 1971, EPA's first
Administrator, William D. Ruckelshaus,
declared that "an extensive body of
information exists which indicates that
the addition of alkyl lead to gasoline . . .
results in lead particles that pose a
threat to public health."
It should be emphasized, however,
that scientific evidence capable of
documenting this conclusion did not
exist in previous decades. Only very
recently have scientists been able to
prove that low-level lead exposure
resulting from automobile emissions is
harmful to human health in general, but
especially to the health of children and
pregnant women.
EPA took an emphatic stand on the
issue in its final health document on the
subject, "EPA's Position on the Health
Implications of Airborne Lead," which
was released on November 28, 1973.
This study confirmed what preliminary
studies had already suggested: namely.
that lead from automobile exhaust was
posing a direct threat to public health.
Under the Clean Air Amendments of
1970, that conclusion left EPA with no
option but to control the use of lead as a
fuel additive known to "endanger the
public health or welfare."
The very next month, in December
1973, EPA issued regulations calling for
a gradual reduction in the lead content
of the tola! gasoline pool, which includes
all grades of gasoline. The restrictions
were scheduled to be implemented
starting on January 1, 1975, and to
extend over a five-year period. The
average lead content of the total gasoline
pool of each refinery was to be reduced
from the level of approximately 2.0
grams per total gallon that prevailed in
1973 to a maximum of 0.5 grams per
total gallon after January 1, 1979.
Litigation was to postpone
implementation of this phasedown for
two years.
Dawn of the Catalytic Converter
Starting with the 1975 model year, U.S.
automakers responded to EPA's lead
phasedown timetable by equipping new
cars with pollution-reducing catalytic
converters designed to run only on
unleaded fuel. Fittingly, a key
component of these catalysts that were
to be the undoing of lead was that
noblest of noble metals, platinum.
Although over 40 percent of all pump
sales are still leaded as of today, the
market share of leaded vehicles is
steadily diminishing. And with it, so is
the noxious cloud of lead-polluted air we
have grown accustomed to breathing.
EPA estimates that ambient lead levels
dropped 64 percent between 1975 and
1982.
In 1982, with the introduction of
unleaded gasoline well underway. EPA
developed a new standard intended to
apply strictly to leaded gasoline. In
October of that year the agency
promulgated a standard of 1.1 grams per
leaded gallon (gplg). This was roughly
equivalent to the standard of 0.5 per
total gallon that had become effective in
1980. But by focusing on leaded gallons
only, EPA's new standard narrowed the
range of lead content deviation and set
the stage for significant reductions still
to come. At this writing, 1.1 gplg is still
the EPA standard, but it will expire on
July 1 of this year when a lower
standard takes effect.
As part of the EPA's latest lead
phasedown initiative, the 1.1 gplg
standard will drop on July 1 to 0.5 gplg.
Then on January 1, 1986. the standard
will go down even further to 0.1 gplg.
This will represent a 90 percent decrease
from the agency's current standard for
leaded fuel. Overall, the 1986 standard
will represent a drop of more than 98
percent in the lead content of U.S.
gasoline from the time of EPA's founding
in 1970 to 1986. This already impressive
achievement may go one step further if
EPA institutes a total ban on lead; the
agency is now considering a total lead
phaseout, which could begin as soon as
1988.
On the basis of all that is known
about the history of lead and its adverse
effects on human health, it is impossible
not to welcome EPA's latest lead
phasedown initiative as well as the
agency's decision to consider banning
lead altogether from U.S. gasoline. D
(Leuns is Assistant Editor of EPA
Journal.)
18
EPA JOURNAL
-------
EPA Diary
A Day
in the Life of
the Administrator
by Susan Tejada
(This article is part of a series on
how some EPA employees spend
their uwking days.j
B
rief a U.S. Senator on a controversial
issue.
Decide the fate of a S5 million
program.
Answer probing questions in a
one-hour press interview, knowing your
answers will be syndicated to
newspapers all over the country.
For an average government worker.
any one of these activities would
dominate a day, generating hours of
advance preparation and, more than
likely, hours of anxiety as well. But for
an Administrator of EPA, these activities
and more comprise an ordinary day's
work.
Last February, Lee Thomas, agency
Assistant Administrator for Solid Waste
and Emergency Response, became EPA
Administrator, succeeding outgoing
Administrator William Ruckelshaus.
Thomas had been with EPA since 1983,
when President Reagan named him to
revitalize solid and hazardous waste
programs that had been badly shaken by
scandals and resignations.
This article describes one day in the
life of Administrator Thomas: March 13,
1985.
March 13. 4:30 p.m.: Administrator Lee Thomas prcsidfs over a decision
on n .stjrrriy <>l /x'.snnd.'s in (jrtiitnd inucr.
5:30 a.m.
Lee Thomas woke up at his regular time
and put on a gray suit, white shirt, and
red tie. Moving quietly so as not to
awaken his wife and two young sons, he
fixed himself some coffee and looked
over the morning paper. As usual, coffee
would be his only nourishment until
lunch.
6:30 a.m.
With the rest of the family still asleep,
Thomas left his home in suburban
Virginia for the one hour drive to the
office. Agency cars and drivers are
available to the Administrator and
Assistant Administrators, after they
arrive at work, for official business.
Thomas always drives his own car back
and forth to work. He tuned in to the
traffic reports on the car radio to figure
out which route was offering the fewest
headaches today.
7:30 a.m.
Thomas took the two separate elevator
trips necessary to reach his top-floor
office. Fortified by a second cup of
coffee, he began the workday by meeting
with Jack McGraw, his replacement in
the Office of Solid Waste and Emergency
Response (OSWER).
"I like to try to meet with each of the
Assistant Administrators once every
week or so, on a one-to-one basis," says
Thomas. But, for the time being at least.
MAY 1985
-------
the meetings with McGraw are more
frequent: "a couple of times a week,"
Thomas explains, "as I phase out the
involvement I had down there."
Some half dozen subjects were on
their agenda, including an update on
the production of methyl isocyanate at
the Union Carbide plant in Institute, W.
Va.; the difficulties of obtaining liability
insurance at Superfund and RCRA sites;
and the status of the RCRA codification
rule, a package updating existing
regulations. Despite a somewhat baffling
array of subjects, the two men worked
quickly because, according to McGraw,
Thomas "already knows the issues and
has amazingly quick recall. He doesn't
need background information. He
already has that. What he needs is the
bottom line."
Their discussions were not strictly
business-related. The first thing Thomas
inquired about—as he usually does,
according to McGraw—was the health of
Kathy Greenwood, his former secretary
in OSWER who is courageously battling
a serious illness.
8:00 a.m.
Thomas held his daily staff meeting,
with Jim Barnes, Acting Deputy
Administrator; Josephine Cooper,
Assistant Administrator for External
Affairs; Executive Assistant Linda Fisher;
and Special Assistant Russ Dawson.
Today's meeting was shorter than
usual. Discussion centered on the status
of EPA's Bhopal Task Force, and the
possible need to reschedule Superfund
hearings.
These early morning sessions are "not
major policy or strategy meetings,"
according to Fisher, but more "an
opportunity to get everybody going. Lee
runs down his schedule for the day, we
review any breaking news stories, and
we go over the latest scoop from the Hill.
Today, for example, I was able to brief
Lee on my conversation with a
congressman from Louisiana before his
meeting with the state environmental
director from Louisiana. That's the
important thing about these meetings:
we know we will see Lee every morning,
so If we can't catch him during the day,
we know we'll have a chance to update
him the next morning."
8:30 a.m.
At Thomas' request, representatives of
Clean Sites, Inc., came in to provide a
status report on their work. Clean Sites
is a non-profit corporation formed last
year to clean up hazardous waste sites.
Of the members of the corporation's
Board of Directors present in Thomas'
twelfth floor office, two were former EPA
Administrators: Russ Train and Doug
Costle. Thomas urged Clean Sites to
become very interactive with EPA
regional offices.
10:00 a.m.
Accompanied by Jo Cooper, Region 2
Administrator Chris Daggett, and Allan
Hirsch, Director of the Office of Federal
Activities, Thomas headed for Room 567
of the Dirksen Senate Office Building
and a meeting with Senator John Chafee
of Rhode Island.
Chafee wanted to discuss his
dissatisfaction with an EPA decision not
to oppose a dredge and fill permit for the
Westway highway project in New York
City. Section 404(c) of the Clean Water
Act gives the EPA Administrator
authority to veto such permits if he
determines they "will have an
unacceptable adverse effect on municipal
water supplies, shellfish beds and
fishery areas...wildlife or recreational
areas." Chafee felt the dredge and fill
activity for Westway would have an
adverse impact on striped bass in the
Hudson River. But Thomas had decided
not to refer the Westway environmental
impact statement to the Council on
Environmental Quality for review.
Instead, he proposed to add to the
permit stipulations calling for further
study to be carried out concurrently with
the dredge and fill activity.
"Senator Chafee was very upset about
our decision," explains Thomas. "He felt
it was an example of how we were not
carrying through with the 404 program
the way he would like to see it carried
through. And I told him that I was not
very well satisfied with the program
either, and I was going to do two things
about it. One, I was going to work on
the 404 procedural issues with the
Corps of Engineers. And two, I was
going to take a broader look at how the
overall wetlands protection effort was
being addressed by the agency."
"I don't think Senator Chafee was
totally satisfied with that. He felt that we
should be more aggressive in using the
404(c) provision of the law, and he's
going to hold oversight hearings."
This kind of give-and-take with
Members of Congress is a standard
feature of Thomas'job. "I would say," he
estimates, "that 1 go up on the Hill three
or four times a week to meet with an
individual Congressman or Senator
about concerns over a program. And I
think that's an important thing for me
to do, an important role for me to play,
expressing our opinions about how we
think legislation should be amended or
initiated."
11:30 a.m.
Back in the office, Thomas switched
gears and turned his attention to more
mundane matters. He interviewed a job
applicant.
"I interview people for the major jobs,
like Assistant Administrator positions,"
he says, "but generally only after Jim
Barnes has interviewed them. Right
now, we've got three or four major jobs
open, so I'm interviewing a couple of
times a week. That'll certainly taper off
as the positions are filled."
Noon
In the dining room that adjoins his
office, Thomas finally had his first meal
of the day, lunch with a friend. A former
attorney with the Environmental
Defense Fund, this man had actually
fulfilled an escapist fantasy many
overscheduled bureaucrats entertain. He
had taken a year off and traveled the
world, to New Zealand, Australia,
Indonesia, India, Thailand, and China.
"I was real interested in his trip," says
Thomas, with a hint of longing in his
voice.
The lunchtime conversation was more
interesting than the food. "There was no
time to go out. Somebody went to the
restaurant downstairs, and brought
lunch up in little boxes. Actually," says
Thomas, pointing to the large conference
table in his office overlooking the
Potomac River, "I usually have a
sandwich right there. There's never any
time to go out. Generally we work during
lunch, while we eat. I've done that ever
since I came to EPA." He pauses for a
moment before recalling, "1 guess I did it
even before I came to EPA."
20
EPA JOURNAL
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1:OO p.m.
Thomas got together with Jack Ravan,
Assistant Administrator for Water at the
time, to prepare for a 2:00 meeting at
the White House. The Cabinet Council
on Natural Resources and the
Environment was meeting to go over
the Administration's position on
reauthorization of the Clean Water Act.
"Jack Ravan and I went over the Clean
Water Act positions." Thomas notes.
"and where we were with resolving those
positions, and talked through each of
the issues. Then we jumped in the car
and dashed to the White House. We
spent an hour with the Cabinet Council,
and got their consensus on 90 percent of
what we had come to discuss. The rest
we carried over to the next week."
3:30 p.m.
Running a half hour late and beginning
to feel the effects of both his crowded
schedule and the flu he had caught from
his children, Thomas arrived back at
EPA for an interview with reporter Kay
Kahler.
"She covers this agency for Newhouse
News," Thomas remarks. "She knows the
issues very well, so she asked some good
questions."
According to Thomas aide Russ
Dawson, who sat in on the interview.
Kahler's tough questions covered a wide
range of issues: President Reagan's
support for the environment, EE^A's
relationship with the Office of
Management and Budget (OMB), the
Administration's position on acid rain,
the aftermath of Bhopal. "Lee is
comfortable with reporters," says
Dawson, "and comfortable with his own
opinions. But today he was not feeling
well. It was a mistake to schedule the
Interview late in the day. He was
exhausted."
Thomas submits to these one-on-one
press interviews as often as he can—
sometimes two or three times a week.
"There are more than 20 reporters that
cover the agency regularly," he explains.
"They like an opportunity periodically to
have a half an hour or so to talk with
the Administrator." Thomas also usually
has a brown bag lunch with a group of
reporters every few weeks.
The press is not the only group
requesting time on Thomas' calendar.
According to Dawson, he and other aides
"sit down two or three times a week and
go through a stack of requests for
speeches and meetings and courtesy
visits and everything under the sun. In
the course of a week, that stack is pretty
big."
4:30 p.m.
Thomas presided over a large meeting
called to decide the fate of a proposed S5
million survey of pesticides in ground
water and drinking water.
For nearly a year, staff of the Office of
Drinking Water and the Office of
Pesticide Programs had been cooperating
in planning the survey. Now. as they
gathered outside the Administrator's
office waiting to argue their case, they
appeared nervous. They did some last
minute strategizing.
Finally, with the late afternoon sun
shining through the windows as a
backdrop, they took their seats around
the Administrator's conference table and
began their presentation.
Thomas had read briefing materials on
the survey the night before, and had
formulated some pointed questions to
identify potential trouble spots: What
will EPA do if the survey does document
contamination? Has OMB approved the
paperwork involved? What does the
agricultural chemical industry think of
the survey? Where will the $5 million
come from? Is the Department of
Agriculture involved?
The one hour discussion ended with
Thomas' decision: "Let's go ahead." He
enjoined the group to develop a
communications strategy, coordinate
with the Department of Agriculture, and
work with Jim Barnes on funding
possibilities. "I think the substance of
your proposal is excellent," he told the
group, "and we ought to proceed with
it."
"Almost all the meetings I have are
decision meetings," Thomas notes. In
fact, he adds, this is the big difference
between being an Assistant
Administrator and being the
Administrator. "In this job, you can't
say, 'Well, the Administrator has to
decide that, or the Deputy Administrator
has to decide that.' You don't have
anybody you can say is going to decide
that. You've got to decide that. You're
the court of last resort."
6:00 p.m.
Thomas and Jim Barnes got together, as
they do at the end of every- workday, to
go over leftover business and plan for
the next day.
7:30 p.m.
One more hour on the freeway, and
Thomas arrived back home. "I like to get
home, if I can. by 7:30," he says.
"because that's when the boys are
finishing their supper. I help get them
ready for bed. and give them a bath. We
play for awhile. And then I put one of
them to sleep, and my wife puts the
other one to sleep." At ages one and
two-and-one-half, "they're both still
rockable, so they both get rocked."
9:00 p.m.
With the kids asleep, and with the White
House Cabinet Council. Congress, and
the press taken care of for the day,
Thomas cleaned up the kitchen and got
something to eat. Then he spent an
hour and a half reading briefing
materials for the next day.
Because of the workload, the
additional time he puts in as
Administrator is, Thomas concedes,
"more demanding on the family,
particularly my little children. So
basically, I spend all my time either
working, or with them. There isn't time
for anything else. On weekends, 1 work
three or four hours a day, at home,
when the boys take their naps, or at
night. Every Saturday. I do the grocery
shopping with my older boy. That way, I
get to spend time just with him, and my
wife gets to spend time together with the
little one. You really learn to structure
your time."
Still, despite the additional work and
pressure, Thomas concludes, "1 really
like this job." D
(Tr;nda is Associate Editor oj ICl'A
Journal.)
MAY 1985
21
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Reflections on the
Nation's Air Cleanup
by Joseph Padgett
In this article, Joseph Padgett
reviews the progress to date of the
nation's air cleanup effort and
discusses its future. Padgett
currently is President of the Air
Pollution Control Association, the
first EPA official to be elected to this
office. During his one-year term as
APCA president, he is on
assignment to the North Carolina
Division of Environmental Control
under the Intergovernmental
Personnel Act exchange program. At
EPA. Padgett was Director of the
Strategies and Air Standards
Division in the Air Program Office.
The views expressed here are not
necessarily those of EPA.
Three decades ago the first federal Air
Pollution Control Act was signed into
law by President Dwight Eisenhower. In
that time, and particularly since 1970,
we have made remarkable progress in
cleaning up the air. But new problems,
such as air toxics, atmospheric
deposition, and indoor air pollution,
have arisen. Unfortunately, these "new"
problems are equally threatening to our
environment and perhaps more complex
to solve. Our challenge in the 1980s and
beyond Is to deal successfully with these
new issues without losing any of the
gains we already have made.
First, let's take a brief look at the
progress achieved over the years in
controlling air pollution. This
background provides a context within
which we can discuss emerging air
issues and possible changes in our
regulatory and legislative approach to
help to deal with them. It also helps us
to assess our current status.
Historical Perspective
We have long recognized dirty and
polluted air as a serious problem.
However, until the 1940s, air pollution
was viewed largely as one involving
smoke from furnaces, industrial
processes, and locomotives. Little
attention was paid initially to
health-related aspects of dirty air.
Compared with states, counties, and
municipalities, the federal government is
very much a newcomer to air pollution
control in the United States. Municipal
and county regulations against smoke
emissions go back to Chicago and
Cincinnati in 1881, and Albany County,
N.Y., around 1913. Probably the earliest
state law was passed by Ohio before
1897 to limit smoke emissions from
steam boilers. It was not until 1952 that
a state, Oregon, first passed
comprehensive legislation and provided
statewide authority to a state air
pollution control agency. In 1907, the
International Association for the
Prevention of Smoke, which later
became the Air Pollution Control
Association (APCA), was organized to
foster smoke prevention regulations and
controls.
By the end of the 1940s, improved
boiler design, developed partly to reduce
black smoke and partly to increase
efficiency, had greatly reduced
emissions. While comprehensive smoke
abatement ordinances and laws were
being implemented to ensure continued
progress, attention was turning to
control of other pollutants and sources
other than boilers.
California's smog problems, the killer
fog at Donora, Pa., in 1948, and another
killer fog, this time in London in 1952,
focused national attention on the
complexities and potential health
hazards of air pollution. The State of
California, Los Angeles County, and local
industries began spending millions of
dollars to study the causes and effects of
smog. Legislators began pushing for the
federal government to take the lead (and
supply the money) for air pollution
research.
A series of federal air pollution laws
has been enacted since 1955. The initial
Clean Air Act was passed in 1963. In
1970, it was amended, but the
amendments were so sweeping and total
that they could be considered an entirely
new Act. Further amendments in 1977
continue to shape today's federal air
pollution control program. (The
references in the remainder of this
article to the Clean Air Act, or CAA,
mean the 1970 and 1977 amendments.)
The scope of federal activities in the
federal-state partnership has grown with
each new law.
The explicit performance-oriented
nature of the 1970 CAA seemed to reflect
the nation's frustration with lack of
progress resulting from earlier federal
and individual state actions. Clearly,
direction, coordinated action, and
regulatory and enforcement authority at
the national level were needed. Equally
important, much more money was
needed for research and development
and for strengthening state and local
control agencies charged with most of
the implementation responsibilities.
Success in achieving this last goal was
one of the most important
accomplishments of federal legislation
and especially of the CAA.
The fundamental purpose of the CAA
is protection of the public health and
welfare from harmful air pollution. It
creates a federal-state partnership which
provides for national oversight and a
framework of national regulations
supplemented by individual state
implementation regulations. The CAA
requires EPA to establish national
standards for ambient air quality and for
22
EPA JOURNAL
-------
emissions from new stationary sources.
!t also requires EPA to identify and list
hazardous air pollutants, to set
hazardous pollutant emission standards
for sources whose emissions may cause
a risk to health, and to set fuel and fuel
additive standards. Automobile emission
standards were included in the CAA and
an automotive testing and certification
program was established. Specific
deadlines were set for many actions,
Timetables were included for states to
prepare and submit plans to attain
national ambient standards, and for
federal approval of the state standards.
Federal implementation of regulations is
required where state progress is
inadequate.
Progress Under the Clean Air Act
The CAA has been a highly successful
law under which substantial progress
has been made in cleaning up the
nation's air. Concentrations of five of the
six criteria pollutants for which national
ambient air quality standards are set
have dropped significantly since state
and federal emission controls began to
take effect in 1975-77. From 1975 to
1982, levels of lead in the air recorded at
46 urban sites dropped 64 percent;
carbon monoxide levels recorded at
traffic-saturated center city locations fell
31 percent; and ozone levels decreased
18 percent at almost 200 sites. Sulfur
dioxide in urban areas dropped 33
percent; and particulate levels decreased
15 percent. Nitrogen dioxide (NO^) levels
remained the same at the end of the five
year period, but concentrations are low.
For example, only one area in the nation
did not meet the primary standard for
NO2 in 1984.
Until recently, EPA's air program has
emphasized control of criteria
pollutants. The figures cited above show
clearly the success which has been
achieved. What's more, EPA, state, and
local regulatory programs in place, or
being implemented, will reduce
emissions further and improve air
quality in most areas of the nation. This
impressive achievement required the
continuing and cooperative efforts of
EPA and the entire network of state and
local air pollution control agencies. The
underlying regulatory framework of this
program includes a myriad of
regulations and procedures. Taken
together, they comprise our nation's air
management system for criteria
pollutants. It is complex and needs to be
simplified, but it works.
Nonetheless, there are still problems
associated with criteria pollutants, fligh
ozone and particulate concentrations
persist in some urban areas, such as Los
Angeles and Houston. It is likely that
ozone levels there will continue to exceed
the national standard for the foreseeable
future despite our best control efforts.
Also, the periodic review and revision of
ambient air quality standards can result
As part of the Rationed Atmospheric
Deposition Program, a field technician
changes collection vessels on a
precipitation sampler in West Point.
.\.V. Hath wet samples (rain and snoir)
and dry samples (dust and din) arc
collected weekly and analy/.ed/or
evidence ol acidity in the atmosphere.
in major program modifications. The
particulate standard is currently being
revised, and will likely result in major
changes to the control program.
The most difficult unresolved issue
under the CAA is our inability to identify
and implement appropriate controls for
toxic air pollutants (defined here as all
pollutants other than the criteria
pollutants), which have, or may have, an
adverse effect on human health. The
CAA provides for the identification and
control of "hazardous" pollutants,
defining them as those which "may
reasonably be anticipated to result in an
increase in mortality or an increase in
serious irreversible, or incapacitating
reversible, illness." EPA is required to
list these pollutants, identify sources of
emissions, then establish emission
standards which will provide an "ample
margin of safety to protect the public
health."
The number of potentially hazardous
air pollutants is large, but the health
data for most are uncertain and
controversial. EPA has listed eight
hazardous pollutants and established
emission controls for six. Primary
concern has been with potential
carcinogens, which are considered to
have no safe level. To meet the letter of
the law, emissions of such pollutants
might have to be banned entirely. The
resulting dilemma—uncertain health
data and often unreasonable control
costs to reduce potential risk low enough
to approximate "zero"—has made it
difficult to reach regulatory decisions. So
far EPA has not regulated sources where
the risk is judged to be low. P^PA has
promised decisions on whether to
regulate between 20 and 25 pollutants
by January 1986. However, it is likely
that EPA may decline to list most
candidates as hazardous because of
uncertain health data. There is not
much middle ground in the CAA to
support the imposition of modest
controls for pollutants when data are
uncertain but suggestive.
Substantial indirect control of air
toxics has been achieved by controlling
particulates and those volatile organics
which are precursors to ozone
formation. For direct control of air
toxics, EPA continues to develop
emission standards lor hazardous
pollutants of national concern while
providing support to state and local
MAY 1985
-------
initiatives where air toxics concerns may
be more localized. State and local
regulatory agencies have more flexibility
in dealing with toxics. Many have
effective programs in place, and others
are developing programs.
Emerging Air issues
A major task of the 1980s and beyond is
to translate our success and expertise in
controlling criteria pollutants to the
resolution of emerging air issues, many
of which appear to be at least as complex
and resistant to effective control
strategies as any associated with criteria
pollutants in the past.
Air toxics, atmospheric deposition
such as acid rain, and indoor air
pollution are three important air issues
which will command our attention for
the next decade and beyond. Other
important air issues include air
emissions from hazardous waste sites,
ozone depletion in the stratosphere,
emissions from wood stoves, visibility,
and pollutants associated with new
industries such as bioengineered
products. The toxic chemical disaster in
Bhopal, India, dramatically focused our
attention on another air-related issue. It
is not yet clear what role the air program
will play in the nation's response to avert
such a disaster in this country.
Air Toxics: The identification and
control of air toxics is the main item of
unfinished business from our 1970 CAA
agenda. EPA has been unable to make
much headway on this under the CAA
for reasons discussed earlier. However,
extensive resources are being devoted to
developing an effective national strategy
on air toxics. Revisions to the CAA may
be needed to implement a
comprehensive air toxics strategy.
Acid Deposition: Often called acid
rain, acid deposition is a part of a larger
problem—atmospheric deposition, by
which pollutants drop from the air onto
the soil and vegetation. There is strong
popular support for regulatory action on
acid rain. The U.S. has committed to an
extensive acid rain research program but
no legislation has been passed to
authorize regulatory action. Atmospheric
deposition includes not only acid
deposition pollutants, but all gases and
particulates which may come in contact
with vegetation or soil surfaces. Ozone is
of particular concern. A combination of
air pollutants is thought to be
24
responsible for killing trees in certain
high elevation forests; research about
this problem is intensifying. Accepting
some additional delay in implementation
and then addressing the broader
question of atmospheric deposition,
rather than focusing only on acid rain,
may be the better control strategy.
Indoor Air Pollution: EPA is reluctant
to develop a regulatory program for
indoor air pollution without legislative
guidance from Congress. Lack of
attention to this problem is hard to
understand when one considers that
most individuals spend over 90 percent
of their time indoors. Pollutants such as
formaldehyde, radon, asbestos, and
some of the criteria pollutants are of
special concern, especially in colder
climates where buildings are more
airtight. Research has been underway
for years and pressure may be mounting
for legislative and regulatory action.
Legislative and Regulatory
Approaches
The major air issues on our future
regulatory agenda tend to be complex,
the science uncertain, and the solutions
expensive. Repeated surveys show that
the public strongly supports
environmental control, but the public
also believes that reasonable benefits
should be realized from control
strategies. Concepts such as risk
management and cost/benefit analysis
should be considered to provide
increased flexibility in setting the
standards, regulations, and
implementation schedules needed to
achieve cost-effective control strategies.
The CAA now limits consideration of
risk management and cost/benefit
concepts in setting standards and
mandates specific pre-set
implementation schedules. Many such
mandated schedules have proven to be
unrealistic. Realistic attainment dates
are specific to both pollutant and
geographic location. Some areas, such
as Los Angeles, may never attain the
present ozone standard. Others attained
it within the prescribed time schedule.
Experience gained since 1970 argues for
a more flexible approach which would
permit EPA to set attainment dates on a
case-by-case basis.
The regulation of hazardous pollutant
emissions is one example of the value of
risk management and cost/benefit
analysis. This issue has been discussed
earlier in some detail. Another example
is the use of these techniques in setting
national ambient air quality standards.
The CAA now requires that these
standards be set at levels below a
threshold concentration at which
adverse effects to human health are
experienced. However, some pollutants
have no clearly defined thresholds, and
limited effects on a few individuals
might be inferred at near zero levels.
Also, available health data often are so
sparse or unreliable that a wide range of
uncertainty is associated with the choice
of a specific standard. In either of these
situations, risk and benefit/cost
estimates can help to select a standard
which adequately protects health
without incurring unreasonable costs to
attain the standard.
The requirement to meet specific
numerical emission or ambient
standards, as now specified in the CAA,
also should be reassessed. EPA on
occasion has discussed using ranges in
standard setting. Given the uncertain
quality of the effects data often available,
this approach, or perhaps the use of
goals in some cases, might be superior
to the present method.
Future legislative and regulatory
strategies may be dealing less with the
traditional "smokestack" industries and
more with diverse decentralized sources
which more directly involve the
Individual. Indoor air pollution
strategies, wood-burning stove controls,
gasoline pump controls, automobile
inspection and maintenance, and
transportation controls are examples of
this trend.
Educating the Public
Former Administrator William
Ruckelshaus often expressed concern
about helping the public to understand
risks, benefits, the sometimes poor
quality of data available for
decision-making, and the myriad of
factors EPA must consider in reaching a
regulatory decision. The public needs to
understand risk management and the
fact that responsible public policy
cannot protect every individual against
all risk. And, above all, EPA needs to
build public understanding and trust
that it is carrying out its
role—protecting the environment—in a
balanced, responsible manner, and in
the public's best interest. D
EPA JOURNAL
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Gabriella Doric of Italy races to the finish of the women's 1500 meter race at the 1984 Summer Olympics in Los Angeies.
Air pollution, which can impair limy function and endurance, was afactor in scheduling times and locations of events.
Initiatives to Deal
with LA. Smog
by Judith E. Ayres
(Ay res is Administrator of EPA Region 9.)
MAY 1985
D.st summer Los Angeles hosted (he
1984 Summer Olympics. Although
many feared smog levels would
skyrocket, it turned out that the
Olympics actually contributed to cleaner
air in Los Angeles, if only tor a short
period of time.
How did this happen?
As a result of a concerted
public-private effort to reduce traffic
congestion during (he games, daily bus
ridership in (he Los Angeles area grew
by abou( 250,000. Many commu(ers
s(ar(ed (o work one-half hour earlier
than normal, stretching out the typical
morning traffic peak. The local air
regulatory agency estimated that
improved distribution of traffic and
25
-------
increased use of mass transit appeared
to be largely responsible for a 12
percent Improvement in air quality
during the Olympic period. This
translated into fewer air pollution alerts
rather than more. It showed that an
extra effort (in this case, flex-time and
ride-sharing) can lead to significant air
quality improvement without major
life-style changes. An Impossible situation
became a little less impossible!
Why is this footnote to the success of
the Summer Olympics important?
Because It shows that Los Angeles can
take on an ambitious air quality
challenge and succeed.
The Clean Air Act requires areas not
meeting ozone and carbon monoxide
standards by December 31,1987, to face
sanctions that include restrictions on
federal highway funds, sewage treatment
plants, air pollution control grants, and
prohibitions on construction or growth
of certain major industrial sources.
Four areas in California have a high
likelihood of not meeting the 1987
deadline: the Los Angeles metropolitan
area (or South Coast Air Basin): Fresno
for ozone and carbon monoxide; and
Ventura and Sacramento for ozone only.
For the Los Angeles area, expected
improvements in air quality
notwithstanding, attainment of the air
quality standards by 1987 is impossible.
Because of this, Region 9 has initiated a
program—the Reasonable Efforts
Program—which we believe will result in
emissions reductions and cleaner air
without major life-style changes or
crippling costs to taxpayers. This
program seeks a regulatory solution for
areas like Los Angeles that face the
threat of sanctions for missing the 1987
deadline, but are willing to move beyond
the level of controls already in place and
to try harder to give an extra effort, as
Los Angeles did during the Olympics.
The Reasonable Efforts Program has
two distinct phases. The first presses for
adoption of additional technically
feasible control measures. Although EPA
will have the first cut at evaluating the
feasibility of such measures, state and
local agencies will help EPA determine
the appropriateness of a particular
measure for a specific area. Based on an
agreed-upon list of additional measures,
local and state agencies and EPA will
take appropriate actions to control
pollution sources further.
The second phase is aimed at
maximizing the effectiveness of air plans
and programs by auditing or oversight.
Auditing will look at enforcement,
permitting, emission inventory
gathering, and rule effectiveness. Again.
EPA will work closely with local and state
agencies.
The Reasonable Efforts Program is an
ongoing process. New measures will be
regularly considered. Existing controls
will be re-evaluated periodically.
In large part, Region 9's approach is
based upon policy set in 1983 by former
Administrator William Ruckelshaus
when he committed the agency to : 1)
expeditiously carry out the Clean Air Act:
2) move the nation closer to the health
goals of the Act; 3) strengthen federal,
state and local air pollution programs; 4)
treat all parties fairly; 5) provide
incentives for states to fulfill their
planning and implementation
obligation—rather than punish them for
failures; and 6) avoid unnecessary
economic disruption.
Region 9 has taken this policy to mean
that sanctions should be avoided if they
do not improve air quality. Sanctions,
however, can serve as a useful incentive
to obtain positive results. This was
evidenced by California's adoption of an
inspection and maintenance program
following invocation of a construction
ban and highway funding restrictions.
However, we do not support invoking
sanctions in areas making reasonable
efforts to take steps to promote progress
toward achievement of federal air
standards, even if attainment of those
standards by 1987 is impossible. In
other words, an area should not be
penalized for doing the very best it can.
This approach can result in significant
emissions reductions and cleaner air.
EPA Headquarters and other EPA
regions have expressed interest in the
Reasonable Efforts Program and are
assessing its broader applicability.
Our region will continue to set
priorities to ensure that best efforts are
made to achieve clean air goals. The
Reasonable Efforts Program is a
practical solution for areas with
intractable air pollution problems.
It has the possibility of producing
more environmentally effective results
than sanctions. If so, the environment
will benefit, the people will benefit, and
our public policy will benefit, and that is
about the best we can do. D
26
EPA JOURNAL
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Handling a
Pollution
Emergency
by Christopher J. Daggett
This is the eighth in a series of articles in the EPA Journal by the
agency's regional offices on environmental problems they are
addressing. The author is Administrator of Region 2.
At a public meeting iriih Sac; Harbor
residents last January. Bob Cobiciia
(left). EPA on-scenc coordinator.
explains plans to extend the public
water main to homes icit/i
contaminated tcells, Local officials
present were (left to right) Southampton
Town Supervisor Manin Lciay. Deputy
Supervisor Wayne Allen, and town
engineer Elias Kalogeras.
Tmagine beginning each day with a
Idrive across town to use a friend's
shower, or preparing your meals,
washing your hands, and brushing your
teeth with bottled water. How would you
feel about running down to the local
firehouse for a drum of clean water
whenever your supply ran out''
For 11 months, this was the routine
for 16 families living in Long Island's
tiny Sag Harbor community. Their
private "water wells were contaminated by
a 500-foot-wide, half-mile-long plume of
ground water polluted with volatile
organic chemicals from a nearby
Industrial site.
Thanks to some of the residents'
diligence, however, as well as the
concerted work of elected officials and
environmental authorities, potable water
began flowing again from the taps of
their homes in February of this year.
The events that led to this fortunate
conclusion demonstrate what can be
accomplished when the federal, state,
and local governments coordinate their
efforts in response to the mysterious and
complex problem of ground-water
contamination.
In the fall of 1983, Charles Soffel and
his wife discovered that their well water
was making them ill. They contacted
Suffolk County's Department of Health
Services (SCDHS), which in turn tested
the well and found it contaminated with
toxic chemicals. As SCDHS made plans
to sample other wells in the area,
neighbors of the Soffels began coming
forward with complaints about their own
water and the trouble it was causing
them. Residents' fears that their
drinking water was seriously
contaminated were confirmed when the
sampling of the wells showed traces of
trichloroethane and trichlorethylene,
toxic industrial solvents used by
manufacturers for fumigation and metal
degreasing. These solvents are
potentially carcinogenic and known to
cause skin irritation, fatty degeneration
of the liver, and even cardiac arrest.
when consumed in large enough doses.
Further testing by SCDHS determined
the origin of the contamination to be in
the ground water under the nearby Sag
Harbor Industries facility. Health
officials advised the residents not to use
their well water for drinking or
household purposes.
Experts agreed that the only
practicable long-term solution for the
home owners would be an extension of
the public water main into the affected
area. The Southampton Town Board, the
local governing authority, noted that
estimates of the cost of the extension
were running as high as $500,000 and
informed the residents that its funds
were insufficient to underwrite the
project.
Faced with the prosper! of funding the
construction themselves, residents
turned to their elected representatives,
Southampton Town Supervisor Martin
Lang, U.S. Congressman William
Carney, and U.S. Senator Daniel Patrick
Moynihan. In turn, the representatives
petitioned New York State for immediate
funding. In September, SCDHS
forwarded an official request for funding
to the New York State Department of
Environmental Conservation (DKC).
MAY 1985
27
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The DEC responded that, because of
state budgetary constraints and built-in
administrative delays, it would be unable
to provide funding quickly enough to
alleviate the Sag Harbor situation. DEC
was aware, however, that under the
Superfund program, EPA had the
necessary funds, as well as the
authority, to clean up the site before
seeking compensation from the parties
responsible for the contamination. On
November 5, DEC asked the EPA Region
2 office to study the eligibility of the
project for Superfund backing.
One week later, the regional office sent
a team of investigators to the site.
Thanks to the outstanding job done by
SCDHS and New York State's DEC, the
data the team had to work with were
much more extensive than typically
encountered. Using these data as a base,
the team conducted further tests and
determined that actual contamination
existed at the tap for about 45 people,
and 39 more were threatened with
exposure. The contaminant plume was
reported to be moving at a rate of one to
two feet a day. and all 28 homes within
or adjacent to the plume were considered
to be at risk.
It was clear that conditions at the Sag
Harbor site presented an immediate
threat to the health of the residents and,
therefore, met the criteria for a removal
action under the Superfund statute (in
this case, actually an action to install
water pipe). When EPA announced its
decision on December 7, the reaction of
residents and local officials was, as
expected, very positive.
As originally outlined, the regional
office plan was to provide an interim
solution to the problem by installing
individual carbon filtration units in
those houses with contaminated wells.
We planned to install public water
mains, taps, meters, and hook-up lines
in the spring, when the warmer
temperatures would make the necessary
excavation work feasible.
It was discovered, however, that the
water mains could be installed
immediately, provided that temperatures
remained seasonable. Accordingly, on
January 19 the Suffolk County Water
Authority, under a contract with EPA,
began laying some 4,000 linear feet of
water main. In the weeks that followed.
work progressed faster than expected
and the original target date for
completion was moved up from March
20 to March 7. The accelerated work
schedule, coupled with the
abandonment of the installation of
carbon filters as an interim solution, cut
the final contract cost of the project from
S440.000 to $310,000.
Now that the bulk of the construction
work is done, and residents have access
to clean water, EPA and the state are
considering several potential options for
removing the actual source of the
contamination from the Sag Harbor
Industries site.
EPA is also moving to collect
compensation for the costs it has
incurred in the construction project.
Under Superfund law, any parties which
generated or transported the industrial
wastes that contaminated the ground
water, or owned the site at which the
waste was generated are liable for the
costs of removal and construction. EPA
is in contact with the current owner of
the site. Sag Harbor Industries, as well
as a former owner, Nabisco Brands, and
we are hopeful that the issue can be
settled without a protracted legal
dispute.
One factor that has contributed to the
success of the Sag Harbor project is a
general awareness on Long Island of the
critical status of the area's ground-water
supply. The island's underground
aquifers have the highest per capita
usage in the United States and, as such,
are the most heavily monitored. In fact,
ground water is the sole source of water
supply for residents of the island, and
also the predominant source of fresh
water for the area's wetlands, rivers, and
bays. The village of Sag Harbor is
situated in the middle of Suffolk
County's most critical watershed
recharge site, where precipitation flows
deep into the Glacial Aquifer.
The ground-water issue is beginning
to get the attention it requires, not only
on Long Island, but around the country.
The consumption of ground water is
increasing at twice the rate of surface
sources of fresh water and it won't be
long before most Americans will rely on
ground water for their drinking supply.
Many regions and communities simply
could not exist without clean and
dependable ground water.
Unfortunately, through the early
1970s, ground-water problems were
pushed to the bottom of the national
agenda as the public and private sectors
concentrated on more visible pollution.
In time, as the nation met many of the
challenges posed by polluted air and
surface water, it was able to focus on the
more complicated question of
ground-water contamination. The
increasing ability to measure
contamination at much lower levels than
before also helped bring the issue to the
foreground of public debate.
In 1983, EPA created a ground-water
task force to develop a strategy for
protection of this vital resource (see EPA
Journal, July/August 1984). The task
force found, among other things, that
state, local, and federal officials are
hampered in their protection initiatives
by a lack of coordination among
responsible agencies. After an extensive
analysis of EPA statutory authorities, as
well as existing state ground-water
programs, the task force also concluded
that the nature and variability of ground
water make its management the primary
responsibility of the states. The group's
study reiterated EPA's commitment to
assisting the states where necessary and
to strengthening a federal-state
partnership that will ensure the most
effective use of our resources for
protecting ground-water quality.
The cooperation among state, federal,
and local levels witnessed at the Sag
Harbor cleanup bears out the
conclusions of the task force. We in
Region 2 are aware that we must serve
as a resource for local government, and
provide the expertise of our experienced
personnel. Moreover, when the threat to
human health is significant and
requires the immediate funding that can
only be provided under a program like
Superfund, we will take the necessary
action. D
28
EPA JOURNAL
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Update
A review of recent major EPA
activities and developments in
the pollution control areas.
AIR
Acid Rain Implementation
Grants
EPA has announced the first of
a series of grants to states for
exploring solutions to problems
they can expect to face should a
national acid rain control
program be adopted.
Awards totaling S590.000
have been made to Wisconsin's
Department of Natural
Resources, the New York State
Department of Environmental
Conservation, and an
organization of northeastern
states for projects to identify
and explore the implementation
problems which might be
associated with any potential
acid rain control program.
Congress appropriated S3
million for the STAR (State Acid
Rain) program, which
encourages states to use their
perspectives and existing air
pollution management expertise
to find solutions to the
implementation challenges
posed to states by any potential
national acid rain program.
State, local, and regional
agencies from all parts of the
U.S. have submitted over 50
proposals to EPA, with funding
requests totaling 860 million.
^ZARDOUSWASTE^
Incineration Studies
EPA lias released two studies
that examine the environmental
effects of incineration of liquid
hazardous wastes at sea and on
land. The stvidies are part of the
continuing effort to provide
information for EPA decisions
on hazardous waste
management options.
The studies were carried out
during the past year by the EPA
Office of Policy. Planning and
Evaluation (OPPE) and the
agency's Science Advisory Board
(SAB) at the request of the
Administrator.
The purpose of the OPPE
study was to collect in one place
all currently available
information on incineration.
including its advantages and
disadvantages, and the issues
associated with its use.
The purpose of the SAB study
was to identify those scientific
aspects of incineration where it
was felt that additional research
was needed.
Both the OPPE study and the
SAB study, undertaken for
different reasons, conclude that
incineration is a method for
disposing of liquid organic
hazardous wastes that is
environmentally preferable to
current land disposal methods.
PESTICIDES
Proposed Penalty for Diamond
Shamrock
EPA's Office of Pesticides and
Toxic Substances has issued an
administrative civil complaint
against the Diamond Shamrock
Chemicals Company of Irving,
Tex., assessing a SI,782,000
proposed penalty for violations
of the Toxic Substances Control
Act (TSCA).
EPA is citing the company for
three counts of failing to notify
EPA prior to the manufacture of
three new chemicals (TSCA
requires all U.S. companies to
notify EPA 90 days prior to
manufacturing a new chemical
so the agency can conduct a
health effects review). The
complaint also cites the
company with one count of
using an illegal chemical
substance for commercial
purposes.
Diamond Shamrock
voluntarily disclosed this
violation information to EPA.
The chemical names cannot be
released by EPA because the
company has declared them
confidential business
information under Section J4 of
TSCA.
2,4,5-T and Silvex
Registrations Terminated
EPA has terminated all
registrations for the once
commonly used weed and brush
killer pesticides, 2,4,5-T and
Silvex. At the same time, the
agency ended the cancellation
proceedings for these two
pesticides. The agency's actions
culminate more than a decade of
government action aimed at
regulating these pesticides.
Although the registrations for
2,4,5-T and Silvex have now
been canceled, existing stocks of
certain canceled 2,4,5-T and
Silvex products may be sold and
distributed for a limited time for
certain uses which were not
suspended in J979. However.
the period to use existing stocks
already has expired for most
affected products, and within
approximately one year 2,4,5-T
and Silvex will no longer be
available in the U.S.
marketplace.
TOXICS
Union Carbide Agrees
to MIC Production Changes
EPA, through its participation
in an intergovernmental task
force technical review, has
determined that resuming
production of methyl isooyanate
(MIC) at Union Carbide's
Institute. W. Va., plant will not
endanger the residents of the
Kanawha Valley.
In announcing the decision on
April 16. KPA Regional
Administrator James M. Sei!
gave background on the
investigation: "In light of the
accident at Bhopal. India, we
initiated a technical review
involving a wide range of
government experts to respond
to public concerns about the
likelihood of a major release of
MIC at the Institute plant. We
have thoroughly reviewed Union
Carbide's MIC unit, as well as
contingency planning in the
Valley."
Members of the task force,
which was formed in January,
included EPA. the U.S.
Occupational Safety and Health
Administration, the West
Virginia Department of Natural
Resources, and the West
Virginia Air Pollution Control
Commission. The Federal
Emergency Management Agency
provided technical assistance.
The task force inspected the
plant and independently
evaluated Information, including
data from Union Carbide, using
basic principles of engineering,
MAY 1985
-------
physics, and chemistry as well
as standard industrial practices
and technical judgment.
Union Carbide has agreed to
make the following
modifications before MIC
production resumes:
• Increasing the neutralization
and destruction capacity of
control equipment;
• Modifying relief valves;
• Modifying and strengthening
operating procedures for MIC
storage and handling;
• Installing a leak detection
system:
• Installing a computerized
system to predict the path and
concentration of an air release;
• Installing backup temperature
and pressure detection devices
in production and storage
tanks;
• Modifying the internal
emergency response plan;
• Reducing the amount of MIC
In storage.
WATER
Clean Water Act Proposal
EPA has outlined the Reagan
Administration's proposals for
reauthorlzatlon of the Clean
Water Act. This is the
Administration's second
proposed bill to reauthorize a
major environmental law. The
first was the Comprehensive
Environmental Response,
Compensation and Liability Act
(Snperlimdl. which was
submitted to Congress on
February 22.
Among the Administration's
chief proposals are provisions
for strengthening the
enforcement of the Clean Water
Act, refining the permitting
system used to regulate
dischargers, and phasing out
the construction grants program
by the end of this decade.
The Reagan Administration's
bill recommends changes in the
enforcement provisions. These
include an option allowing EPA
to assess penalties of up to
SI0.000 per day per violation
with a maximum penalty of
SI25.000. The option of"
assessing administrative
penalties already is available
under other environmental
statutes, but this would be the
first time such penalties would
be employed under the Clean
Water Act. Also, the daily
maximum penalty per day which
could be imposed by court
action would be increased from
SI0.000 to S25.000 per
violation.
In addition, criminal penalties
would be increased. Penalties for
knowing violations of
substantive provisions of the act
have been increased to felony
levels. Maximum fines for
knowing first offenses have been
increased to S50.000 and terms
of imprisonment up to three
years.
Also, maximum prison
sentences for knowingly
making false statements.
representations, and
certifications, or tampering with
monitoring equipment have all
been Increased from six months
to two years. Another new
provision would be added to the
act providing for stronger felony
penalties for certain conduct
which knowingly threatens
"imminent danger of death or
serious bodily injury."
12-Mile Site Petitions Denied
EPA has announced its final
determination to deny petitions
to re-designate the 12-Mile
Sewage Sludge Dump Site in the
New York Bight Apex. The site
has been used since 1924 for
ocean dumping of municipal
sludge.
The decision means that
several current municipal sludge
dumpers will no longer be
allowed to dispose of municipal
sludge within 12 miles of the
New Jersey and Long Island,
N.Y., shores.
Instead, they must relocate
their dumping operations to the
designated Deepwater Municipal
Sludge Dump Site (formerly
known as the 106-Mile Site).
which occupies an area of 100
square miles. This site is located
approximately 120 nautical
miles southeast of Ambrose
Light, N.Y., and 115 nautical
miles from Atlantic City. N.J.,
the nearest coastline. The site is
In water depths ranging from
7.380 to more than 9,000 feet.
EPA determined that the
deepwater site is
environmentally preferable since
living resources there are more
sparse and less valuable.
Because of its great depth and
the dispersion of dumped
material by currents, disposal of
municipal sludge there will
result in relatively low
concentrations of contaminants
and reduced environmental
Impacts. Its greater distance
from the coastline will also
reduce the potential for any
impact on shorelines, beaches.
and near-shore recreational
activities.
Pretreatment Program Changes
Proposed
A special task force has urged
EPA to simplify procedures.
impose tougher enforcement,
and increase resources for its
program dealing with
pretreatment of industrial
wastewater discharged into
publicly owned treatment plants.
The recommendations are
included in the final report to
EPA Administrator Lee M.
Thomas from the Pretreatment
Implementation Review Task
Force. The panel, created in
February 1984, Included
representatives from state and
city governments, industry,
public interest groups, and EPA
regional offices.
Many industrial facilities
release their liquid wastes to
publicly owned treatment works
rather than into a waterway.
The Clean Water Act directed
EPA to establish national
standards for pretreatment of
this wastewater since it could
either cause the plants to
malfunction or pass through
and contaminate sewage sludge
and waterways.
In 1978. EPA proposed
regulations and a national
pretreatment strategy. However,
dissatisfaction with the rate of
progress in achieving its
goals last year led former EPA
Administrator William D.
Ruckelshaus to create the task
force for the purpose of advising
the agency on how the program
could be made more effective.
The panel was headed by
Rebecca Hanmer, Director of the
EPA Office of Water
Enforcement and Permits. EPA
has already initiated work on a
number of the task force
proposals.
AGENCYWIDE
Faculty Exchange Progam
This summer, EPA's Region 5
office in Chicago will inaugurate
a faculty exchange program with
Clark College. Talladega College,
and Savannah State University.
The 16-week pilot program is
designed to familiarize selected
science and engineering faculty
at these colleges with EPA's
mission, personnel, and
operations as well as the
agency's current research and
development needs.
Through closer association
with these and other historically
black colleges and universities,
EPA hopes to generate new
perspectives on environmental
problems and innovative
approaches to their solution.
The agency would like these
colleges and universities to
become new centers for
environmental studies and
ecological research. Students
enrolled in science and
engineering courses at these
schools could also help to meet
EPA employment needs in the
years ahead.
The names of the first four
participants in the faculty
exchange program were to be
announced at the end of April.
All four will work from June to
August in the Environmental
Services Division of EPA
Region 5 D
30
EPA JOURNAL
-------
Appointments at EPA
Linda J. Fisher
F. Scott Bash
Terrell E. Hunt
Frederick F. Stiehl
Linda J. Fisher has been named
Executive Assistant to EPA
Administrator Lee M. Thomas. In her
new position. Fisher is serving as the
Administrator's senior staff advisor on
all policy and legislative matters.
Fisher came to EPA in 1983, shortly
after Lee Thomas began his tenure as
Assistant Administrator for Solid Waste
and Emergency Response (OSWER). She
served as his Special Assistant in
OSWER from July 1983 until the
beginning of this year.
In 1983, Fisher worked as a lawyer
with the firm of Chester. Hoffman,
Willcox in Columbus, Ohio. From 1980
to 1982 she studied for a J.D. at Ohio
State University.
Fisher was an associate staff member
of the U.S. House of Representatives
Appropriations Committee from 1979 to
1980. She was a legislative assistant to
Congressman Ralph Regula (R.-Ohio)
from 1976 to 1978. She began her
career on Capitol Hill in 1974 as a
legislative assistant to Congressman
Clarence J. Brown (R.-Ohio).
In addition to her 1982 J.D. from
Ohio State, Fisher has a 1978 M.B.A.
from George Washington University and
a B.A. in History from Miami University
of Oxford, Ohio.
F. Scott Bush has been appointed
Director of the Analysis and Evaluation
Division in EPA's Office of Water. In his
new position. Bush will be responsible
for the analysts of EPA's Water
Regulations and Standards as well as
administering various grant programs to
the states.
Bush comes to EPA from the U.S.
Department of Energy (DOE), where he
has held a variety of executive positions
since 1977. Most recently, he served in
DOE's Economic Regulatory
Administration, where he managed
DOE's petroleum, electricity, and natural
gas import programs.
In 1981. Bush served as Acting
Director of the Programs Operations
Office in DOE's Economic Regulatory
Administration. From 1979 to 1981 he
was DOE's Assistant Administrator in
charge of regulatory policy.
Bush also served in several high-level
positions in the Federal Energy
Administration (FEA), which became
part of DOE in 1977. From 1976 to 1977
he served as FEA's Acting Associate
Administrator for Policy and Evaluation.
From 1973 to 1974 Bush worked as a
Special Assistant to the Executive
Director of the Cost of Living Council.
He was Assistant Executive Secretary of
the Pay Board from 1971 to 1973. From
1968 to 1971 Bush was program
specialist for the Economic Development
Administration at the U.S. Department
of Commerce. He worked as a lawyer for
McDermott, Will & Emery of Chicago
from 1967 to 1968.
Bush studied for his law degree at
Northwestern University Law School
from 1964 to 1967, when he received his
J.D. He completed his undergraduate
education at Dartmouth College, where
he graduated with a degree in Political
Science in 1959.
From 1959 to 1961 Bush served in the
U.S. Army. He was a Foreign Service
Officer with the Department of State
from 1961 to 1964. Among other duties,
he served for two years in the U.S.
Embassy in Tunisia.
Terrell E. Hunt has been appointed
Director of the Criminal Enforcement
and Special Litigation Division of EPA's
Office of Enforcement and Compliance
Monitoring (OECM). In his new position.
Hunt will supervise three units within
OECM: the Office of Criminal
Enforcement, which houses the
headquarters attorneys assigned to the
criminal enforcement program; the Legal
Enforcement Policy Division, which
establishes generic cross-media
enforcement policy: and the Special
Litigation Division, which litigates
enforcement actions arising from the
pesticides and toxic substances
programs.
Hunt first joined EPA in July 1972 as
a Management Intern, and served
rotational assignments in four different
offices at EPA headquarters to gain
practical experience in a variety of areas.
From 1973 to 1983 he served in various
staff and supervisory positions In the
pesticides and toxic substances
enforcement program of the Office of
Pesticides and Toxic Substances (OPTS).
Hunt became Chief of the enforcement
program's Policy and Strategy Branch in
1979. In 1983 he served as a Special
Assistant to former Deputy
Administrator Al Aim.
Prior to joining EPA, Hunt was a
research assistant in the Executive
Office of the President, Office of
Emergency Preparedness.
Hunt graduated with high honors in
economics from Brigham Young
University in 1970. He received his J.D.
from the Georgetown University Law
Center in 1976 and is a member of tin-
District of Columbia Bar.
Hunt, who has received several cash
awards for his work at EPA, won an EPA
Bronze Medal in 1975.
Frederick F. Stiehl has been named
Associate Enforcement Counsel for
Waste in EPA's Office of Enforcement
and Compliance Monitoring (OECM). In
his new position, which he has held on
an acting basis since August 1984,
Stiehl is responsible for overseeing EPA's
national enforcement litigation program
under the Resource Conservation and
MAY 1985
31
-------
Susan II. Shcnnun
Maryarct J. Stastkowski
Dr. Charles K. Findley
Recovery Act and the Comprehensive
Environmental Response, Compensation
and Liability Act.
Stiehl has been with EPA since 1979
in a variety of executive positions. Until
1981 he was a senior attorney-advisor
charged with providing advice and
support to regional legal staff. For eight
months in 1981 he was Chief of the
Office of Hazardous Waste Enforcement
Litigations Branch. In December 1981.
Stiehl began serving as Deputy Associate
Enforcement Counsel in OKCM. a
position he held until 1984.
From 1972 to 1979, Stiehl served as a
tria! attorney in the Office of the
Corporation Counsel of the District of
Columbia government. He was
Chairman of the Howard County Mental
Health Advisory Board in Columbia, Mel..
from 1976 to 1982. From 1970 to 1972
Stiehl was an assistant editor at the
Bureau of National Affairs, Inc.
Stiehl received his J.D. from the
Washington College of Law of American
University in 1970. He completed his
undergraduate education at Rutgers.
where he graduated with a B.A. in
Political Science in 1967.
Susan H. Sherman has been named
Deputy Director of the Office of Pesticide
Programs in OPTS. In this position,
which she has held on an acting basis
since June 1984, Sherman plays a key
role in managing and directing EPA
activities in regulating the 45,000
pesticide products now marketed in the
United States.
Sherman began her civil service career
as a caseworker at the USDA Food and
Nutrition Service in 1968. She joined
EPA in 1972 as a writer-editor in the
Registration Division of the Office of
Pesticide Programs. In 1974 Sherman
was named Chief of EPA's External
Affairs Unit, a position she held for five
years.
In 1979 Sherman became Acting
Deputy Director of the Hazard
Evaluation Division in the Office of
Pesticide Programs. She held that
position until 1980 when she became
Chief of OPTS's Policy and Special
Projects Staff.
Sherman received her B.A. in English
from the College of William and Mary in
1968. She was the recipient of EPA's
Gold Medal in 1978 and the agency's
Bronze Medal in 1976 and 1979. In
1983 she received an EPA Special
Achievement Award. Also active in civic
affairs, Sherman is on the Board of
Directors of the Falls Church Village
Preservation and Improvement Society.
Margaret J. Stasikowski has been
appointed Director of the Chemical
Control Division in EPA's OPTS. In this
position, which she has held on an
acting basis since March 1984,
Stasikowski is responsible for
management of the Toxic Substances
Control Act (TSCA) Premanufacture
Notice Review Program and regulation of
new and existing chemicals under
Sections 5, 6 and 7 of TSCA.
Stasikowski joined EPA in 1974 as a
physical science administrator in the
Office of Research and Development.
Between 1975 and 1977 she worked as a
physical scientist in EPA's Industrial
Environmental Research Laboratory.
From 1977 to 1980 Stasikowski '
worked as Chief of the Office of
Operations of the Certification Division
of the Mobile Source Pollution Control
Program in Ann Arbor, Mich. She
returned to EPA headquarters in 1980
as a Special Assistant to the Director of
the Office of Toxic Substances. In 1981
she became Deputy Director of the
division she is now directing.
From 1973 to 1974 Stasikowski was
an industrial hygienist with the Oil,
Chemical & Atomic Workers Union in
Denver.
Stasikowski received her M.S. in
industrial hygiene and air pollution
control from the University of Cincinnati
in 1973. She received her B.S. from
Ohio State University in 1970.
Dr. Charles E. Findley has been named
Director of the Hazardous Waste
Division at EPA's Region 10 office in
Seattle. In this position, he will be
responsible for implementing the RCRA
and Superfund programs in Region 10.
For the past five years, he has served
in Region 10's Air and Waste
Management Division, first as its Deputy
Director and then as its Acting Director.
Dr. Findley has been with EPA's
Region 10 office since the beginning of
his civil service career. He began
working there in 1971 as a mechanical
engineer. In 1974 he became the Chief
of Region 10's Air Operations Section.
He held that position for three years.
In 1977 Findley became Chief of the
National Pollutant Discharge
Elimination Standards Permits Section
in Region 10. Between 1979 and 1980
he worked on an intergovernmental
personnel assignment in the Mayor's
Office of Intergovernmental Relations in
Seattle.
Dr. Findley received his B.S, in
Mechanical Engineering from the
University of Washington in 1966. In
1971 he was awarded an M.S. in
Engineering from the same university.
Simultaneously in 1978, Findley
completed his Ph.D. in Engineering at
the University of Washington and his
M.A. in Public Administration at
Harvard. D
32
EPA JOURNAL
-------
In 1932. a gas pump advertises "tiro
fisted motorfuel" to boost engine
performance. Today, more than 40
percent of all U.S. pump sales are still
of leaded gasoline.
Back cover: A scenic panorama of
Magens Bay on St. Thomas, U.S. Virgin
Islands. Photo by Michael Flaherty,
EPA.
-------
United States
Environmental Protection
Agency
Washington DC 20460
Official Business
Penalty for Private Use $300
Third-Class Bulk
Postage and Fees Paid
EPA
Permit No. G-35
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