EPA420-R-99-021
Achieving Clean Air and Clean Water:
The Report of the Blue Ribbon Panel
on Oxygenates in Gasoline
September 15,1999
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TABLE OF CONTENTS
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CHAPTER 1. EXECUTIVE SUMMARY 1
CHAPTER 2. ISSUE SUMMARIES 12
A. Water Contamination 13
I. Introduction 13
II. Contamination 13
III. Sources 16
IV. Behavior 17
V Drinking Water Standards 18
Appendix A 21
B. Air Quality Benefits 22
I. Introduction 22
II. Federal RFG Program: Requirements and Benefits 22
III. The Impact on RFG if Oxygenates are Removed 26
IV Other Air Quality Considerations for Oxygenates 30
V Wintertime Oxyfuel Program 33
Appendix B 37
C. Prevention, Treatment, and Remediation 40
I. Introduction 40
II. Sources and Trends of Water Quality Impacts 40
III. Release Prevention and Detection 45
IV Underground Storage Tanks 47
V Protection of Drinking Water Sources and Water Quality Management 48
VI. Treatment of Impacted Drinking Water 50
VII. Remediation 52
D. Fuel Supply and Cost 61
I. Introduction 61
II. Industry Overview 62
III. Impact of Fuel Requirement Changes on Supply 66
IV Cost Impacts of Changing Fuel Reformulations 69
Appendix D 73
E. Comparing the Fuel Additives 75
I. Introduction 75
II. MTBE 75
III. Ethanol 78
IV Other Ethers 80
V Other Alternatives 80
Appendix E 82
CHAPTER 3. FINDINGS AND RECOMMENDATIONS OF THE BLUE RIBBON PANEL 83
Appendix A 91
CHAPTER 4. DISSENTING OPINIONS 92
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TABLE OF CONTENTS (continued)
Page
LIST OF PANEL MEMBERS AND PARTICIPANTS 99
REFERENCES 104
GLOSSARY OF TERMS Ill
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CHAPTER 1. EXECUTIVE SUMMARY
The Federal Reformulated Gasoline Program (RFG) established in the Clean Air Act Amendments of
1990, and implemented in 1995, has provided substantial reductions in the emissions of a number of air
pollutants from motor vehicles, most notably volatile organic compounds (precursors of ozone), carbon
monoxide, and mobile-source air toxics (benzene, 1,3-butadiene, and others), in most cases resulting in
emissions reductions that exceed those required by law. To address its unique air pollution challenges,
California has adopted similar, but more stringent requirements for California RFG. In addition, areas in
both California and elsewhere in the nation that have not attained the National Ambient Air Quality
Standard for carbon monoxide are required in the Act to implement the Wintertime Oxyfuel program.
The Clean Air Act requires that RFG contain 2 percent oxygen by weight. Over 85 percent of RFG
contains the oxygenate methyl tertiary butyl ether (MTBE) and approximately 8 percent contains ethanol
~ a domestic fuel-blending stock made from grain and potentially from recycled biomass waste. The Act
requires Wintertime Oxyfuel to contain 2.7 percent oxygen by weight.
There is disagreement about the precise role of oxygenates in attaining the RFG air quality benefits,
although there is evidence from the existing program that increased use of oxygenates results in reduced
carbon monoxide emissions, and it appears that additives contribute to reductions in aromatics in fuels
and related air benefits. It is possible to formulate gasoline without oxygenates that can attain similar air
toxics reductions, but it is less certain that given current Federal RFG requirements all fuel blends
created without oxygenates could maintain the benefits provided today by oxygenated RFG.
At the same time, the use of MTBE in the program has resulted in growing detections of MTBE in
drinking water, with between 5 percent and 10 percent of community drinking water supplies in high
oxygenate use areas1 showing at least detectable amounts of MTBE. The great majority of these
detections to date have been well below levels of public health concern, with approximately one percent
rising to levels above 20 parts per billion (ppb). Detections at lower levels have, however, raised
consumer taste and odor concerns that have caused water suppliers to stop using some water supplies and
to incur costs of treatment and remediation. Private wells have also been contaminated, and these wells
are less protected than public drinking water supplies and not monitored for chemical contamination.
There is also evidence of contamination of surface waters, particularly during summer boating seasons.
The major source of groundwater contamination appears to be releases from underground gasoline
storage systems. These systems have been upgraded over the last decade, likely resulting in reduced risk
of leaks. However, approximately 20 percent of the storage systems have not yet been upgraded, and
there continue to be reports of releases from some upgraded systems, due to inadequate design,
installation, maintenance, and/or operation. In addition, many fuel storage systems (e.g. farms, small
above-ground tanks) are not currently regulated by the U.S. Environmental Protection Agency. Beyond
groundwater contamination from underground storage tank (UST) sources, the other major sources of
water contamination appear to be small and large gasoline spills to ground and surface waters, and
recreational water craft - particularly those with older motors ~ releasing unburned fuel to surface
waters.
Areas using RFG (2% by weight oxygen) and/or Oxyfuel (2.7% by weight Oxygen)
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The Blue Ribbon Panel
In response to the growing concerns from State and local officials and the public, U.S. EPA
Administrator Carol M. Browner appointed a Blue Ribbon Panel in November 1998, to investigate the air
quality benefits and water quality concerns associated with oxygenates in gasoline, and to provide
independent advice and recommendations on ways to maintain air quality while protecting water quality.
The Panel members consisted of leading experts from the public health and scientific communities,
automotive fuels industry, water utilities, and local and State governments. The Panel was charged to:
(1) examine the role of oxygenates in meeting the nation's goal of clean air; (2) evaluate each product's
efficiency in providing clean air benefits and the existence of alternatives; (3) assess the behavior of
oxygenates in the environment; (4) review any known health effects; and (5) compare the cost of
production and use and each product's availability both at present and in the future. Further, the Panel
studied the causes of ground water and drinking water contamination from motor vehicle fuels, and
explored prevention and cleanup technologies for water and soil. The Panel was established under
EPA's Federal Advisory Committee Act's Clean Air Act Advisory Committee, a policy committee
established to advise the U.S. EPA on issues related to implementing the CAAA of 1990. It met six
times from January - June, 1999, heard presentations in Washington, the Northeast, and California about
the benefits and concerns related to RFG and the oxygenates; gathered the best available information on
the program and its effects; identified key data gaps; and evaluated a series of alternative
recommendations based on their effects on:
- air quality
- water quality
- stability of fuel supply and cost
This report consists of five issue summaries: water contamination; air quality benefits; prevention;
treatment and remediation; fuel supply and cost; and comparing the fuel additives. In addition, this
report contains the findings and recommendations of the Panel, dissenting opinions, list of Panel
members, references, and glossary of terms.
The Findings and Recommendations of the Blue Ribbon Panel
Findings
Based on its review of the issues, the Panel made the following overall findings:
The distribution, use, and combustion of gasoline poses risks to our environment and
public health.
RFG provides considerable air quality improvements and benefits for millions of US
citizens.
The use of MTBE has raised the issue of the effects of both MTBE alone and MTBE in
gasoline. This Panel was not constituted to perform an independent comprehensive
health assessment and has chosen to rely on recent reports by a number of state, national,
and international health agencies. What seems clear, however, is that MTBE, due to its
persistence and mobility in water, is more likely to contaminate ground and surface water
than the other components of gasoline.
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MTBE has been found in a number of water supplies nationwide, primarily causing
consumer odor and taste concerns that have led water suppliers to reduce use of those
supplies. Incidents of MTBE in drinking water supplies at levels well above EPA and
state guidelines and standards have occurred, but are rare. The Panel believes that the
occurrence of MTBE in drinking water supplies can and should be substantially reduced.
MTBE is currently an integral component of the U.S. gasoline supply both in terms of
volume and octane. As such, changes in its use, with the attendant capital construction
and infrastructure modifications, must be implemented with sufficient time, certainty,
and flexibility to maintain the stability of both the complex U. S. fuel supply system and
gasoline prices.
The following recommendations are intended to be implemented as a single package of actions designed
to simultaneously maintain air quality benefits while enhancing water quality protection and assuring a
stable fuel supply at reasonable cost. The majority of these recommendations could be implemented by
federal and state environmental agencies without further legislative action, and we would urge their rapid
implementation. We would, as well, urge all parties to work with Congress to implement those of our
recommendations that require legislative action.
Recommendations to Enhance Water Protection
Based on its review of the existing federal, state and local programs to protect, treat, and remediate water
supplies, the Blue Ribbon Panel makes the following recommendations to enhance, accelerate, and
expand existing programs to improve protection of drinking water supplies from contamination.
Prevention
1. EPA, working with the states, should take the following actions to enhance significantly
the Federal and State Underground Storage Tank programs:
a. Accelerate enforcement of the replacement of existing tank systems to conform
with the federally-required December 22, 1998 deadline for upgrade, including,
at a minimum, moving to have all states prohibit fuel deliveries to non-upgraded
tanks, and adding enforcement and compliance resources to ensure prompt
enforcement action, especially in areas using RFG and Wintertime Oxyfuel.
b. Evaluate the field performance of current system design requirements and
technology and, based on that evaluation, improve system requirements to
minimize leaks/releases, particularly in vulnerable areas (see recommendations
on Wellhead Protection Program in 2. below).
c. Strengthen release detection requirements to enhance early detection,
particularly in vulnerable areas, and to ensure rapid repair and remediation.
d. Require monitoring and reporting of MTBE and other ethers in groundwater at
all UST release sites.
e. Encourage states to require that the proximity to drinking water supplies, and the
potential to impact those supplies, be considered in land-use planning and
permitting decisions for siting of new UST facilities and petroleum pipelines.
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f. Implement and/or expand programs to train and license UST system installers
and maintenance personnel.
g. Work with Congress to examine and, if needed, expand the universe of regulated
tanks to include underground and aboveground fuel storage systems that are not
currently regulated yet pose substantial risk to drinking water supplies.
2. EPA should work with its state and local water supply partners to enhance
implementation of the Federal and State Safe Drinking Water Act programs to:
a. Accelerate, particularly in those areas where RFG or Oxygenated Fuel is used,
the assessments of drinking water source protection areas required in Section
1453 of the Safe Drinking Water Act, as amended in 1996.
b. Coordinate the Source Water Assessment program in each state with federal and
state Underground Storage Tank Programs using geographic information and
other advanced data systems to determine the location of drinking water sources
and to identify UST sites within source protection zones.
c. Accelerate currently-planned implementation of testing for and reporting of
MTBE in public drinking water supplies to occur before 2001.
d. Increase ongoing federal, state, and local efforts in Wellhead Protection Areas
including:
- enhanced permitting, design, and system installation requirements for
USTs and pipelines in these areas;
- strengthened efforts to ensure that non-operating USTs are properly
closed;
- enhanced UST release prevention and detection; and
- improved inventory management of fuels.
3. EPA should work with states and localities to enhance their efforts to protect lakes and
reservoirs that serve as drinking water supplies by restricting use of recreational water
craft, particularly those with older motors.
4. EPA should work with other federal agencies, the states, and private sector partners to
implement expanded programs to protect private well users, including, but not limited to:
a. A nationwide assessment of the incidence of contamination of private wells by
components of gasoline as well as by other common contaminants in shallow
groundwater;
b. Broad-based outreach and public education programs for owners and users of
private wells on preventing, detecting, and treating contamination; and
c. Programs to encourage and facilitate regular water quality testing of private
wells.
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5. Implement, through public-private partnerships, expanded Public Education programs at
the federal, state, and local levels on the proper handling and disposal of gasoline.
6. Develop and implement an integrated field research program into the groundwater
behavior of gasoline and oxygenates, including:
a. Identifying and initiating research at a population of UST release sites and
nearby drinking water supplies including sites with MTBE, sites with ethanol,
and sites using no oxygenate; and
b. Conducting broader, comparative studies of levels of MTBE, ethanol, benzene,
and other gasoline compounds in drinking water supplies in areas using primarily
MTBE, areas using primarily ethanol, and areas using no or lower levels of
oxygenate.
Treatment and Remediation
7. EPA should work with Congress to expand resources available for the up-front funding
of the treatment of drinking water supplies contaminated with MTBE and other gasoline
components to ensure that affected supplies can be rapidly treated and returned to
service, or that an alternative water supply can be provided. This could take a number of
forms, including but not limited to:
a. Enhancing the existing Federal Leaking Underground Storage Tank Trust Fund
by fully appropriating the annual available amount in the Fund, ensuring that
treatment of contaminated drinking water supplies can be funded, and
streamlining the procedures for obtaining funding;
b. Establishing another form of funding mechanism which ties the funding more
directly to the source of contamination; and
c. Encouraging states to consider targeting State Revolving Funds (SRF) to help
accelerate treatment and remediation in high priority areas.
8. Given the different behavior of MTBE in groundwater when compared to other
components of gasoline, states in RFG and Oxyfuel areas should reexamine and enhance
state and federal "triage" procedures for prioritizing remediation efforts at UST sites
based on their proximity to drinking water supplies.
9. Accelerate laboratory and field research, and pilot projects, for the development and
implementation of cost-effective water supply treatment and remediation technology, and
harmonize these efforts with other public/private efforts underway.
Recommendations for Blending Fuel for Clean Air and Water
Based on its review of the current water protection programs, and the likely progress that can be made in
tightening and strengthening those programs by implementing Recommendations 1-9 above, the Panel
agreed broadly, although not unanimously, that even enhanced protection programs will not give
adequate assurance that water supplies will be protected, and that changes need to be made to the RFG
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program to reduce the amount of MTBE being used, while ensuring that the air quality benefits of RFG,
and fuel supply and price stability, are maintained.
Given the complexity of the national fuel system, the advantages and disadvantages of each of the fuel
blending options the Panel considered (see Appendix A), and the need to maintain the air quality benefits
of the current program, the Panel recommends an integrated package of actions by both Congress and
EPA that should be implemented as quickly as possible. The key elements of that package, described in
more detail below, are:
Action agreed to broadly by the Panel to reduce the use of MTBE substantially (with
some members supporting its complete phase-out), and action by Congress to clarify
federal and state authority to regulate and/or eliminate the use of gasoline additives that
threaten drinking water supplies;
Action by Congress to remove the current 2 percent oxygen requirement to ensure that
adequate fuel supplies can be blended in a cost-effective manner while quickly reducing
usage of MTBE; and
Action by EPA to ensure that there is no loss of current air quality benefits.
The Oxygen Requirement
10. The current Clean Air Act requirement to require 2 percent oxygen, by weight, in RFG
must be removed in order to provide flexibility to blend adequate fuel supplies in a cost-
effective manner while quickly reducing usage of MTBE and maintaining air quality
benefits.
The Panel recognizes that Congress, when adopting the oxygen requirement, sought to
advance several national policy goals (energy security and diversity, agricultural policy,
etc) that are beyond the scope of our expertise and deliberations.
The Panel further recognizes that if Congress acts on the recommendation to remove the
requirement, Congress will likely seek other legislative mechanisms to fulfill these other
national policy interests.
Maintaining Air Benefits
11. Present toxic emission performance of RFG can be attributed, to some degree, to a
combination of three primary factors: (1) mass emission performance requirements; (2)
the use of oxygenates; and (3) a necessary compliance margin with a per gallon standard.
In Cal RFG, caps on specific components of fuel is an additional factor to which toxics
emission reductions can be attributed.
Outside of California, lifting the oxygen requirement as recommended above may lead to
fuel reformulations that achieve the minimum performance standards required under the
1990 Act, rather than the larger air quality benefits currently observed. In addition,
changes in the RFG program could have adverse consequences for conventional gasoline
as well.
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Within California, lifting the oxygen requirement will result in greater flexibility to
maintain and enhance emission reductions, particularly as California pursues new
formulation requirements for gasoline.
In order to ensure that there is no loss of current air quality benefits, EPA should seek
appropriate mechanisms for both the RFG Phase II and Conventional Gasoline programs
to define and maintain in RFG II the real world performance observed in RFG Phase I
while preventing deterioration of the current air quality performance of conventional
gasoline.2
There are several possible mechanisms to accomplish this. One obvious way is to
enhance the mass-based performance requirements currently used in the program. At the
same time, the Panel recognizes that the different exhaust components pose differential
risks to public health due in large degree to their variable potency. The Panel urges EPA
to explore and implement mechanisms to achieve equivalent or improved public health
results that focus on reducing those compounds that pose the greatest risk.
Reducing the Use of MTBE
12. The Panel agreed broadly that, in order to minimize current and future threats to drinking
water, the use of MTBE should be reduced substantially. Several members believed that
the use of MTBE should be phased out completely. The Panel recommends that
Congress act quickly to clarify federal and state authority to regulate and/or eliminate the
use of gasoline additives that pose a threat to drinking water supplies.3
2 The Panel is aware of the current proposal for further changes to the sulfur levels of gasoline and recognizes
that implementation of any change resulting from the Panel's recommendations will, of necessity, need to be
coordinated with implementation of these other changes. However, a majority of the Panel considered the
maintenance of current RFG air quality benefits as separate from any additional benefits that might accrue from the
sulfur changes currently under consideration.
3 Under §211 of the 1990 Clean Air Act, Congress provided EPA with authority to regulate fuel formulation to
improve air quality. In addition to EPA's national authority, in §211(c)(4) Congress sought to balance the desire for
maximum uniformity in our nation's fuel supply with the obligation to empower states to adopt measures necessary to meet
national air quality standards. Under §21 l(c)(4), states may adopt regulations on the components of fuel, but must demonstrate
that 1) their proposed regulations are needed to address a violation of the NAAQS and 2) it is not possible to achieve the desired
outcome without such changes.
The Panel recommends that Federal law be amended to clarify EPA and state authority to regulate and/or eliminate
gasoline additives that threaten water supplies. It is expected that this would be done initially on a national level to maintain
uniformity in the fuel supply. For further action by the states, the granting of such authority should be based upon a similar two
part test:
1) states must demonstrate that their water resources are at risk from MTBE use, above and beyond the risk posed by
other gasoline components at levels of MTBE use present at the time of the request.
2) states have taken necessary measures to restrict/eliminate the presence of gasoline in the water resource.
To maximize the uniformity with which any changes are implemented and minimize impacts on cost and
fuel supply, the Panel recommends that EPA establish criteria for state waiver requests including but not
limited to:
a. Water quality metrics necessary to demonstrate the risk to water resources and air quality metrics
(continued...)
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Initial efforts to reduce should begin immediately, with substantial reductions to begin as
soon as Recommendation 10 above - the removal of the 2 percent oxygen requirement -
is implemented4. Accomplishing any such major change in the gasoline supply without
disruptions to fuel supply and price will require adequate lead time - up to 4 years if the
use of MTBE is eliminated, sooner in the case of a substantial reduction (e.g. returning
to historical levels of MTBE use).
The Panel recommends, as well, that any reduction should be designed so as to not result
in an increase in MTBE use in Conventional Gasoline areas.
13. The other ethers (e.g. ETBE, TAME, and DIPE) have been less widely used and less
widely studied than MTBE. To the extent that they have been studied, they appear to
have similar, but not identical, chemical and hydrogeologic characteristics. The Panel
recommends accelerated study of the health effects and groundwater characteristics of
these compounds before they are allowed to be placed in widespread use.
In addition, EPA and others should accelerate ongoing research efforts into the
inhalation and ingestion health effects, air emission transformation byproducts, and
environmental behavior of all oxygenates and other components likely to increase in the
absence of MTBE. This should include research on ethanol, alkylates, and aromatics, as
well as of gasoline compositions containing those components.
14. To ensure that any reduction is adequate to protect water supplies, the Panel recommends
that EPA, in conjunction with USGS, the Departments of Agriculture and Energy,
industry, and water suppliers, should move quickly to:
a. Conduct short-term modeling analyses and other research based on existing data
to estimate current and likely future threats of contamination;
b. Establish routine systems to collect and publish, at least annually, all available
monitoring data on:
use of MTBE, other ethers, and Ethanol;
levels of MTBE, Ethanol, and petroleum hydrocarbons found in ground,
surface and drinking water;
trends in detections and levels of MTBE, Ethanol, and petroleum
hydrocarbons in ground and drinking water;
3 (...continued)
to ensure no loss of benefits from the federal RFG program.
b. Compliance with federal requirements to prevent leaking and spilling of gasoline.
c. Programs for remediation and response.
d. A consistent schedule for state demonstrations, EPA review, and any resulting regulation of the
volume of gasoline components in order to minimize disruption to the fuel supply system.
4 Although a rapid, substantial reduction will require removal of the oxygen requirement, EPA should, in order
to enable initial reductions to occur as soon as possible, review administrative flexibility under existing law to allow
refiners who desire to make reductions to begin doing so.
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c. Identify and begin to collect additional data necessary to adequately assess the
current and potential future state of contamination.
The Wintertime Oxyfuel Program
The Wintertime Oxyfuel Program continues to provide a means for some areas of the country to
come into, or maintain, compliance with the Carbon Monoxide standard. Only a few
metropolitan areas continue to use MTBE in this program. In most areas today, ethanol can and
is meeting these wintertime needs for oxygen without raising volatility concerns given the
season.
15. The Panel recommends that the Wintertime Oxyfuel program be continued (a) for as
long as it provides a useful compliance and/or maintenance tool for the affected states
and metropolitan areas, and (b) assuming that the clarification of state and federal
authority described above is enacted to enable states, where necessary, to regulate and/or
eliminate the use of gasoline additives that threaten drinking water supplies.
Recommendations for Evaluating and Learning From Experience
The introduction of reformulated gasoline has had substantial air quality benefits, but has at the same
time raised significant issues about the questions that should be asked before widespread introduction of
a new, broadly-used product. The unanticipated effects of RFG on groundwater highlight the importance
of exploring the potential for adverse effects in all media (air, soil, and water), and on human and
ecosystem health, before widespread introduction of any new, broadly-used, product.
16. In order to prevent future such incidents, and to evaluate of the effectiveness and the
impacts of the RFG program, EPA should:
a. Conduct a full, multi-media assessment (of effects on air, soil, and water) of any
major new additive to gasoline prior to its introduction;
b. Establish routine and statistically valid methods for assessing the actual
composition of RFG and its air quality benefits, including the development, to
the maximum extent possible, of field monitoring and emissions characterization
techniques to assess "real world" effects of different blends on emissions;
c. Establish a routine process, perhaps as a part of the Annual Air Quality trends
reporting process, for reporting on the air quality results from the RFG program;
and
d. Build on existing public health surveillance systems to measure the broader
impact (both beneficial and adverse) of changes in gasoline formulations on
public health and the environment.
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Summary of Dissenting Opinion
By Todd C. Sneller, Member
EPA Blue Ribbon Panel
The complete text of Mr. Sneller's dissenting opinion on the Panel's recommendation to
eliminate the federal oxygen standard for reformulated gasoline is included in Chapter 4 of this
report.
In its report regarding the use of oxygenates in gasoline, a majority of the Blue Ribbon Panel on
Oxygenates in Gasoline recommends that action be taken to eliminate the current oxygen
standard for reformulated gasoline. Based on legislative history, public policy objectives, and
information presented to the Panel, I do not concur with this specific recommendation. The basis
for my position follows:
The Panel's report concludes that aromatics can be used as a safe and effective replacement for
oxygenates without resulting in deterioration in VOC and toxic emissions. In fact, a review of
the legislative history behind the passage of the Clean Air Act Amendments of 1990 clearly
shows that Congress found the increased use of aromatics to be harmful to human health and
intended that their use in gasoline be reduced as much as technically feasible.
The Panel's report concludes that oxygenates fail to provide overwhelming air quality benefits
associated with their required use in gasoline. The Panel recommendations, in my opinion, do no
accurately reflect the benefits provided by the use of oxygenates in reformulated gasoline.
Congress correctly saw a minimum oxygenate requirement as a cost effective means to both
reduce levels of harmful aromatics and help rid the air we breathe of harmful pollutants.
The Panel's recommendation to urge removal of the oxygen standard does not fully take into
account other public policy objectives specifically identified during Congressional debate on the
7990 Clean Air Act Amendments. While projected benefits related to public health were a focal
point during the debate in 1990, energy security, national security, the environment and
economic impact of the Amendments were clearly part of the rationale for adopting such
amendments. It is my belief that the rationale behind adoption of the Amendments in 1990 is
equally valid, if not more so, today.
Congress thoughtfully considered and debated the benefits of reducing aromatics and requiring
the use of oxygenates in reformulated gasoline before adopting the oxygenate provisions in 1990.
Based on the weight of evidence presented to the Panel, I remain convinced that maintenance of
the oxygenate standard is necessary to ensure cleaner air and a healthier environment. I am also
convinced that water quality must be better protected through significant improvements to
gasoline storage tanks and containment facilities. Therefore, because it is directly counter to the
weight of the vast majority of scientific and technical evidence and the clear intent of Congress, I
respectfully disagree with the Panel recommendation that the oxygenate provisions of the federal
reformulated gasoline program be removed from current law.
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LYONDELL CHEMICAL COMPANY
SUMMARY OF DISSENTING REPORT
The complete text ofLyondell 's dissenting report is in Chapter 4 of this report.
While the Panel is to be commended on a number of good recommendations to improve the
current underground storage tank regulations and reduce the improper use of gasoline, the
Panel's recommendations to limit the use of MTBE are not justified.
Firstly, the Panel was charged to review public health effects posed by the use of oxygenates,
particularly with respect to water contamination. The Panel did not identify any increased public
health risk associated with MTBE use in gasoline.
Secondly, no quantifiable evidence was provided to show the environmental risk to drinking
water from leaking underground storage tanks (LUST) will not be reduced to manageable levels
once the 1998 LUST regulations are fully implemented and enforced. The water contamination
data relied upon by the panel is largely misleading because it predates the implementation of the
LUST regulations.
Thirdly, the recommendations fall short in preserving the air quality benefits achieved with
oxygenate use in the existing RFG program. The air quality benefits achieved by the RFG
program will be degraded because they fall outside the control of EPA's Complex Model used for
RFG regulations and because the alternatives do not match all of MTBE's emission and gasoline
quality improvements.
Lastly, the recommendations will impose an unnecessary additional cost of 1 to 3 billion dollars
per year (3-7 c/gal. RFG) on consumers and society without quantifiable offsetting social
benefits or avoided costs with respect to water quality in the future.
Unfortunately, there appears to be an emotional rush to judgement to limit the use of MTBE. For
the forgoing reasons, Lyondell dissents from the Panel report regarding the following
recommendations:
The recommendation to reduce the use of MTBE substantially is unwarranted
given that no increased public health risk associated with its use has been identified
by the Panel.
The recommendation to maintain air quality benefits of RFG is narrowly limited to
the use of EPA's RFG Complex Model which does not reflect many of the vehicle
emission benefits realized with oxygenates as identified in the supporting panel
issue papers. Therefore, degradation of air quality will occur and the ability to
meet the Nation's Clean Air Goals will suffer under these recommendations.
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CHAPTER 2. ISSUE SUMMARIES
In the course of its deliberations, the Blue Ribbon Panel heard from a number of experts in the field, and
reviewed a large number of analyses and reports compiled by a range of organizations and individuals on
the topics of air quality, water contamination, prevention and remediation, fuel supply and price, and
health effects (see References below). In order to guide its development and evaluation of the range of
options, and the selection of its recommended option, the Panel worked with its own staff, staff of a
number of federal agencies, and consultants assigned to it from ICF Consulting to compile the following
Issue Summaries.
These Issue Summaries are not intended to be complete reproductions of the many analyses and reports
the Panel reviewed, nor did the Panel necessarily have the charter or the expertise to conduct an entire de
novo review of all of the evidence on any one topic (e.g. health effects). Rather, these summaries are
designed to summarize all of the available information in a relatively neutral manner, capturing those
areas where the scientific and technical community have come to some conclusions about these topics,
and noting those areas where either there is not agreement, or where additional information is needed.
For example, the Panel provides in Issue A. Water Contamination, the first systematic summary of water
contamination data from the states of Maine and California and from the U.S. Geological Survey. This
data, which emerged beginning late last year, was augmented substantially by analyses completed by
USGS, and a summary of the relevant data was presented to the Panel in April. The Panel did not,
however, conduct a detailed review of the analytic techniques, assumptions, and methods of each study,
but rather accepted them as valid efforts to attempt to characterize an emerging situation, and refers the
readers to the original studies for further detail.
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A. Water Contamination
I. Introduction
There have been increasing detections of methyl tertiary butyl ether (MTBE) in ground waters and in
reservoirs. Overall, approximately 90 percent of tested waters have no detects, with remaining waters
generally exhibiting relatively low level contamination. As sources of water contamination are
identified, the behavior of oxygenates in ground water needs to be analyzed in order to understand the
extent of contamination. The following is a summary of what is known today concerning water
contamination.
II. Contamination
A. Concentration Levels in Public and Private Wells
The use of MTBE in the RFG program has resulted in growing detections of MTBE in drinking water,
with between 5 percent and 10 percent of community drinking water supplies in high oxygenate use
areas5 showing at least detectable amounts of MTBE. The great majority of these detections to date have
been well below levels of public health concern, with between 0.3 percent to 1.5 percent rising to levels
above 20 parts per billion (ppb). Detections at lower levels have, however, raised consumer taste and
odor concerns that have caused water suppliers to stop using some water supplies and to incur costs of
treatment and remediation. Private wells have also been contaminated and these wells are less protected
than public drinking water supplies and not monitored for chemical contamination. There is also
evidence of contamination of surface waters, particularly during summer boating seasons. A variety of
studies, summarized in Table 1, have sought to determine the extent of MTBE contamination of drinking
water sources. In addition, the USGS 12 Northeastern State Study has compiled data for MTBE levels in
community drinking water.
Although there are no nation-wide drinking water data sets from which to fully characterize MTBE
detections in the United States, a recent United States Geological Survey (USGS) report examines this
issue with respect to ambient ground water. This report assessed studies conducted between 1985 and
1995 by USGS-NAWQA (National Water Quality Assessment Program), local, State, and Federal
agencies by examining sampling data from 2,948 urban & rural, drinking water, and non-drinking water
wells. Projections from these data sets suggest that up to 7 percent of the nation's ground water resources
could potentially contain a volatile organic compound (VOC) such as MTBE at concentrations of at least
0.2 ppb. At this time it is difficult to project future trends of contamination due to the lack of time-series
data.
5 Areas using RFG (2% by weight oxygen) and /or Oxyfuel (2.7% by weight Oxygen).
13
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Table 1. Summary of Studies Examining MTBE Contamination of Drinking Water Sources
Concentration
Range (ppb)
California
Public Water
Sources1 (wells)
N=5,195
MDL=5 ppb
Maine
Public Water
Sources3 (wells)
N=793
MDL=0.1ppb
Maine
Private Water
Sources3 (wells)4
N=946 (95% CI)
MDL=0.1 ppb
USGS/NAWQA
Studies5 (wells)
N=2,743
MDL=0.2 ppb
(censor level)
USGS/EPA 12
Northeastern State
Study6 (systems)
N=l,190
MDL=1 ppb7
Non-Detects -99% -84.1% -84.3% -94.7% -92.8%
MDL-5ppb N/A2 -14.6% -12.8% -4.5% -5.0%
5-20 ppb -0.3% -0.9% -1.5% -0.4% -1.3%
> 20 ppb -0.3% -0.4% -1.5% -0.4% -0.9%
'California Department of Health Services, April 22, 1999 ( www.dhs.ca.aov/DS/ddwem/chemicals/MTBE/mtbe summarv.htm). Because the
same source may be counted more than once (e.g., as both "raw" and "treated", as with a reservoir), data from a single source have been
consolidated for purposes of counting "sources."
2Although there have been detects below 5 ppb, such detections are not required to be reported.
3A.E. Smith, Analysis of MTBE data in public and private water sources sampled as part of the Maine MTBE Drinking Water Study
Preliminary Report, October 13, 1998: Written Communication to U.S. EPA, May 20, 1999.
"Data are available for other sources (e.g., springs and surface water).
5P.J. Squillace, D.A. Bender, J.S. Zogorski, Analysis of USGS data on MTBE in wells sampled as part of the National Water Quality
Assessment Program, 1993-1998: Written Communication to U.S. EPA. May 20, 1999.
6S.J. Grady Analysis of the Preliminary Findings of the 12-State MTBE/VOC Drinking Water Study, 1993-1998: Communication to U.S.
EPA, May 20, 1999.
'Some samples with higher reporting levels have not been screened out.
Note: Some systems have multiple sources and the total number of sources is unknown. Systems with multiple detections are counted in the
highest reported concentration range.
"MDL" = Minimum Detection Level.
MTBE was the second most commonly detected VOC in water from urban wells6. Due to the inadequacy
of long-term monitoring data, the extent and trends of ground and surface water contamination in the
nation are still not well known. As such, research is underway to obtain more contamination occurrence
data for ground and surface waters. An American Water Works Association Research Foundation
(AWWARF) study of the national occurrence of MTBE in sources of drinking water (i.e., rivers,
reservoirs, ground water, etc.) began in May 1999 and will continue for two years. This type of data will
document near-term impacts and provide important input for analysis to predict future contamination
trends.
B.
RFG/OXY Areas Versus Non-RFG/OXY Areas
Data from the joint USGS and U.S. Environmental Protection Agency (EPA) 12 Northeastern State
study7 and the USGS/NAWQA study (Table 1) were analyzed to evaluate the frequency of MTBE
detections in drinking water in RFG/OXY versus non-RFG/OXY areas. Results from the USGS/EPA
Northeastern State study indicate that MTBE is detected ten times more often in drinking water from
community water systems in areas that use reformulated gasoline (RFG) or oxygenated fuels (OXY) than
6 Paul Squillace, et al., "Occurrence of the Gasoline Additive MTBE in Shallow Ground Water in Urban and
Agricultural Areas; Fact Sheet FS-114-95; U.S. Geological Survey: Rapid City, DS, 1995; Paul Squillace, et.al.,
Preliminary assessment of the occurrence and possible sources of MTBE in groundwater in the United States, 1993-
1994. Environ. Sci. Tech. 30 (5) 1721-1730, 1996.
7 U.S. Environmental Protection Agency and United States Geological Survey, Preliminary Finding of the 12-
State MTBE/VOC Drinking Water Retrospective, 1999.
14
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in non-RFG/OXY areas.8 Likewise, data from USGS/NAWQA indicates a similar detection frequency in
RFG/OXY areas (Table 2). The USGS/NAWQA study also indicates that higher levels of MTBE (>20
ppb) are 19 times more likely to be detected in RFG/OXY areas than in non-RFG/OXY areas.9 MTBE
detections are clearly elevated in RFG/OXY areas as compared to BTEX (benzene, toluene,
ethylbenzene, and xylene) detections.
Table 2. MTBE and BTEX Detection, RFG/OXY vs. Non-RFG/OXY Areas
10
RFG/OXY Areas Using MTBE
(480 Wells)
Non-RFG/OXY Areas in the
United States (2,263)
MTBE Detection
(0.2 ppb)
21%
2%
BTEX Detection
(0.2 ppb)
4%
2%
After normalizing for factors that affect detection frequency (i.e., gasoline stations, commercial and
industrial land use, etc.), MTBE is four to six times more likely to be detected in RFG/OXY areas than
non-RFG/OXY areas. In RFG/OXY areas, of the 50 million people dependent on ground water, 20
million use an aquifer containing at least one VOC, indicating potential vulnerability to MTBE.11
C.
Co-Occurrence of MTBE and Other Gasoline Components
For co-occurring components in gasoline, preliminary data from both the USGS/EPA 12 Northeastern
State study and the USGS/NAWQA study shows that MTBE is generally detected in groundwater
samples that contain another VOC, but is not associated with BTEX detections. In USGS/EPA drinking
water samples containing MTBE, BTEX co-occurrence were only 0.3 percent, even though
approximately 44 percent of the samples contained one or more other VOCs.12 Similar results are
exhibited for USGS/NAWQA ground water samples containing MTBE, with only 13 percent of the
samples with MTBE also detecting BTEX.13
8 Stephen Grady and Michael Osinski, "Preliminary Findings of the 12-State MTBE/VOC Drinking Water
Retrospective," presentation at the April 1999 MTBE Blue Ribbon Panel meeting.
9 Paul Squillace, "MTBE in the Nation's Ground Water, National Water-Quality Assessment (NAWQA)
Program Results," presentation at the April 1999 MTBE Blue Ribbon Panel meeting.
10 Paul Squillace, "MTBE in the Nation's Ground Water, National Water-Quality Assessment (NAWQA)
Program Results," presentation at the April 1999 MTBE Blue Ribbon Panel meeting.
11 Paul Squillace, "Volatile Organic Compound in Untreated Ambient Groundwater of the United States, 1985
-1995," presentation at the April 1999 MTBE Blue Ribbon Panel meeting.
12 Stephen Grady and Michael Osinski, "Preliminary Findings of the 12-State MTBE/VOC Drinking Water
Retrospective" presentation at the April 1999 MTBE Blue Ribbon Panel meeting.
13 Paul Squillace, "Volatile Organic Compound in Untreated Ambient Groundwater of the United States, 1985
-1995," presentation at the April 1999 MTBE Blue Ribbon Panel meeting.
15
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III. Sources
The most frequent sources of higher levels of ground water contamination (greater than 20 ppb)14 appear
to be releases from gasoline storage and distribution systems, although there have been reports (e.g.,
Maine) that would suggest other sources of contamination, such as small spills and improper disposal. In
reservoirs and lakes, MTBE detections, which vary seasonally, appear to be from recreational watercraft,
particularly those with older motors. More general contamination of ground and surface waters at lower
levels (usually less than 5 ppb) are primarily from storm water runoff and to a lesser degree, air
deposition, as well as from leaking tanks and accidental spills.
Specific examples of recent findings regarding the sources of ground water contamination include the
following:
a. Santa Monica. California15
Ground water contamination from LUSTs has resulted in the contamination
and closure of 9 high volume production drinking water wells (daily water
demand at approximately 6.5 million gallons per day) at levels up to 610 ppb
in the production wells, up to 17,000 ppb in regional monitoring wells, and
up to 230,000 ppb in LUST source-site monitoring wells.
b. Maine
16
An automobile gasoline leak contaminated a supply well 100 feet away to a
level of 900 ppb.
c. University of California. Davis Donner Lake Study
17
The use of motorized watercraft yielded concentration levels from 0.1 ppb to
12 ppb.
14 Office of Science and Technology Policy, National Science and Technology Council, Interagency
Assessment of Oxygenated Fuels, June 1997.
15 Komex H20 Science, Draft Investigation Report of MTBE Contamination: City of Santa Monica, Charnock
Well Field, Los Angeles, California, March 21, 1997; Geomatrix Consultants, Inc., Summary of MTBE
Groundwater Monitoring Results, Fourth Quarter 1998, Charnock Well Field Regional Assessment, Los Angeles,
California, April 1, 1999.
16 B. Hunter et al, "Impact of Small Gasoline Spills on Groundwater," preliminary report abstract presented at
the Maine Water Conference Meeting, April 1999.
17 J.E. Reuter et al., "Concentrations, Sources and Fate of the Gasoline Oxygenate Methyl Tert-Butyl Ether
(MTBE) in a Multiple-Use Lake," Environmental Science and Technology 32, 3666-3672, 1998.
16
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d. Metropolitan Water District of Southern California Monitoring Program18
A monthly monitoring program (January 1997 to present) at six surface
water reservoirs resulted in concentrations as high as 29 ppb during summer
boating months.
19
e. OSTP Report
Storm water runoff exhibited concentrations of 0.2 - 8.7 ppb in 7
percent of samples tested in 16 cities from 1991 to 1995. Based
on modeled air concentrations, concentrations in rainwater are
predicted to range from less than 1 ppb to 3 ppb.
IV. Behavior
A. MTBE
In ground water, MTBE is more soluble, does not adsorb as readily to soil particles, biodegrades less
rapidly, and thus moves more quickly than other components of gasoline (i.e., BTEX).20 In surface
water, volatilization of MTBE at the air-water interface is a significant contributor to decreased
concentrations of MTBE.21
Much of MTBE's behavior is dependent upon the nature of the release, whether the release source is
point or non-point, its geologic settings, and environmental and microbial factors. In studies to date, in
situ biodegradation of MTBE has been minimal or limited at best, which is significantly less (by at least
one order of magnitude) when compared to benzene.
B. Ethanol
Ethanol is extremely soluble in water and, based on theory, should travel at about the same rate as
MTBE. Ethanol is not expected, however, to persist in ground water due to ethanol's ability to
biodegrade easily. In fact, laboratory research findings suggest that ethanol may inhibit the
18 Metropolitan Water District, Methyl Tertiary Butyl Ether Monitoring Program at the Metropolitan Water
District of Southern California, monitoring program update, April 1999.
19 Office of Science and Technology Policy, National Science and Technology Council, Interagency
Assessment of Oxygenated Fuels, June 1997, pp. 2-33 -2-35.
20 A.M. Happel et al.,An Evaluation of MTBE Impacts to California Groundwater Resources, Lawrence
Livermore National Laboratory Report, UCRL-AR-130897, June 1998; A.M. Happel, B. Dooher, and E.H.
Beckenbach, "Methyl Tertiary Butyl Ether (MTBE) Impacts to California Groundwater," presentation at the March
1999 MTBE Blue Ribbon Panel meeting; Salanitro, J.P, "Understanding the Limitations of Microbial Metabolism
of Ethers Used as Fuel Octane Enhancers," Curr. Opin. Biotechnol. 6: 337-340, 1995.
21 Paul Squillace et al., "Review of the Environmental Behavior and Fate of Methyl Tertiary-Butyl Ether,"
Environ. Tox. Chem, 1997; UC Davis Report, Transport and Fate Modeling of MTBE in Lakes and Reservoirs,"
Stephen A. McCord and Geoffrey S., Schladow.
17
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biodegradation of BTEX because the microbes preferentially metabolize ethanol before BTEX.22
Qualitative and quantitative characterizations of ethanol biodegradation under field conditions have not
been done to date. In one hypothetical analysis presented to the Panel, the addition of ethanol to gasoline
was estimated to extend BTEX plumes by 25 percent to 40 percent.23 Additionally, a study in Brazil
indicated that, high ethanol concentrations in ground water (greater than 2 percent) enhanced the
solubilization and migration of BTEX.24 No national monitoring of ethanol in ground water, surface
water or drinking water has been completed at this time.25
V. Drinking Water Standards
A. Drinking Water Advisory
In certain situations, either the public's concern about potential contamination, or water supply officials'
concerns about the taste and odor effects of MTBE contamination, or both, has affected the ability of
local authorities to rely on their water supplies for drinking water. For example, South Lake Tahoe,
California water officials recently closed 13 wells due to the proximity of MTBE plumes to its drinking
water wells.
The U.S. Environmental Protection Agency's Office of Water has established a drinking water advisory26
level of 20 to 40 ppb as a guidance for State and local authorities, based on taste and odor concerns. This
guidance suggests control levels for taste and odor acceptability and also provides a large margin of
safety against any potential adverse health effects. The advisory levels enable water suppliers to easily
assess if their drinking water is likely to be acceptable to consumers. The advisory also recognizes that
some members of the population may detect it below this range. However, as indicated in table 3, states
have established different guidelines and standards based on differing interpretations of the data
concerning the taste and odor thresholds and health effect studies for MTBE.
In addition, EPA has proposed a revised Unregulated Contaminant Monitoring Rule, which would
require large water systems (serving more than 10,000 persons) and a representative sample of small- and
medium-sized water systems (serving fewer than 10,000 persons) to monitor and report MTBE levels.
This program is scheduled to take effect in January 2001. Under this regulation, the maj ority of public
22 H.X., Corseuil et al., "The Influence of the Gasoline Oxygenate Ethanol on Aerobic and Anaerobic BTX
Biodegradation," Wat. Res., 1998, 32, 2065-2072.; C.S. Hunt et al., "Effect of Ethanol on Aerobic BTX
Degradation Papers from the Fourth International In Situ and On-Site Bioremediation Symposium," Battelle Press,
April-May 1997, pp. 49-54.
23 Michael Kavanaugh and Andrew Stocking, "Evaluation of the Fate and Transport of Ethanol in the
Environment," November, 1998. Presentation at the May 1999 MTBE Blue Ribbon Panel. [Based on Malcome
Pirnie, Inc. Evaluation of the Fate and Transport of Ethanol in the Environment (Oakland, CA, 1998.)]
24 H.X. Corseuil and P. J.J. Alvarez, "Natural Bioremediation Perspective for BTX-Contaminated Groundwater
in Brazil," Wat. Sci. Tech., 1996, 35, 9-16.
25 EPA analytical methods are limited for ethanol analysis providing only ppm range detection limits.
26 U.S. Environmental Protection Agency, Office of Water, Drinking Water Advisory: Consumer Acceptability
Advice and Health Effects Analysis on Methyl Tertiary-Butyl Ether (MTBE), December 1997.
18
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groundwater supply wells will still not be monitored for MTBE.27 The availability of Consumer
Confidence Reports will notify the public of what contaminants are found in drinking water. Increasing
numbers of consumers may find the water unacceptable if they are aware of MTBE's presence.
Private wells are not subject to monitoring under the Safe Drinking Water Act, but are left to the
discretion of the State. Therefore, private well owners rarely have routine monitoring for either bacterial
or chemical contamination. Private wells are typically more vulnerable than public wells due to
differences in wellhead construction. Specifically, these wells typically draw from shallow groundwater,
which is more vulnerable to impacts from surface contamination.
B.
State Guidelines and Action Levels
As Table 3 indicates, a number of States have established drinking water guidelines and action levels.
Currently, four States have primary drinking water standards, three States have enforceable guidelines,
and 12 States either have an MTBE guideline or action level in place. Figure Al, located in Appendix A,
contains a map illustrating these various State standards.
Table 3. State Drinking Water Standards, Guidelines, and Action Levels
States with Primary Drinking Water Standards
(health-based)
Maine (35 ppb)
New Jersey (70 ppb)
New York (50 ppb)
South Carolina (20-40 ppb)
State with a Secondary Standard (aesthetic)
California (5 ppb); enforceable
States with Enforceable Guidelines
Michigan (240 ppb); health-based
West Virginia (20-40 ppb); EPA Advisory
States with a Guideline or Action Level in Place
Arizona (35 ppb); health-based
California (13 ppb); health-based
Connecticut (70 ppb); health-based
Illinois (70 ppb); health-based
Kansas (20-40 ppb); EPA Advisory
Maryland (10 ppb); aesthetically-based
Massachusetts (70 ppb); health-based
New Hampshire (15 ppb); aesthetically based
Pennsylvania (20-40 ppb); EPA Advisory
Rhode Island (20-40 ppb); EPA Advisory
Vermont (40 ppb); EPA Advisory
Wisconsin (60 ppb); health-based
Source: U.S. Environmental Protection Agency.
27 Water suppliers are required to monitor for volatile organic compounds and MTBE can be analyzed by the
same analytical methods and therefore could be included along with scheduled volatile organic compound sampling.
19
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National Primary Drinking Water Standards, as defined by the Safe Drinking Water Act (SDWA), must
be health-based. Although standards can be developed at the Federal level based on taste and odor, such
standards are secondary and non-enforceable. Currently, the Drinking Water Advisory serves only as a
national guidance level for aesthetic effects that EPA recommends for drinking water. Due to
uncertainties in the health effects database, gaps in characterizing national occurrence, and significant
variability among health study methodologies, EPA does not have sufficient information to establish an
enforceable health-based standard at this time.
20
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Appendix A
Figure A1
Drinking Water Regulations and Guidelines
forMTBE(ug/L)
U.S. EPA, June 1999
Guideline (240) enf.
Aesthetic guideline (20-40)
Standard (35\
HA (40)
Guideline
Action Level (13)
Sec.Std(5)enf.
ction level (70)
Standard (70)
Action Level (10)
HA (20-40) enf.
Interim Standard MCLG
(20-40)
HA -- Health Advisory
Enf. - Enforceable
MCLG - Maximum
Contaminant Level Goal
* Guidelines and Action Levels are often interchangeable (depending on the State)
Source: U.S. Environmental Protection Agency
21
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B. Air Quality Benefits
I. Introduction
The Federal and California reformulated gasoline (RFG) programs have significantly improved air
quality by reducing emissions of toxics and lowering the ozone forming potential through reductions in
volatile organic compound (VOC) and oxides of nitrogen (NOX). In general, these programs have
resulted in greater emission reductions than statutorily required.
II. Federal RFG Program: Requirements and Benefits
A. Summary of RFG Requirements and Benefits
Ozone and air toxic levels in this nation have decreased substantially in recent years as a result of the
Clean Air Act's implementation. There are over 30 areas, however, that are still in nonattainment with
the current ozone standard. The results of emissions tests, tunnel studies, and remote sensing of tail pipe
exhaust indicate that RFG usage can cause a decrease in both the exhaust and evaporative emissions from
motor vehicles.28 Based on separate cost effectiveness analyses conducted by both the U.S.
Environmental Protection Agency (EPA) and the State of California, when compared to all available
control options, RFG is a cost-effective approach to reducing ozone precursors such as VOCs and NOX.29
Although there is no National Ambient Air Quality Standard for toxics, a number of provisions of the
Clean Air Act require reductions in toxics emissions, and Federal RFG has contributed to these
reductions..
The RFG program, mandated under the 1990 Clean Air Act Amendments, requires changes in motor fuel
formulation which result in decreased vehicle emissions for areas in the U.S. with significant low-level
ozone pollution, otherwise known as smog. These areas represent about 30 percent of U.S. gasoline
consumption. The program requires reductions relative to a 1990 fuel baseline in levels of NOX, toxics,
and VOC emissions and also requires a minimum level of oxygen and limits the maximum benzene level.
The emissions performance of fuels relative to 1990 is evaluated using a linear regression model, referred
to as the "complex model," which was developed using thousands of emissions tests relating fuel
properties to emissions performance. To certify a fuel as RFG, a fuel manufacturer measures the eight
relevant physical and chemical properties of the fuel, enters those results into the complex model, and the
model determines the percent reduction in NOX, VOC, and toxics, relative to 1990, for that fuel. Phase I
of the program began in 1995. Phase II, scheduled to begin on January 1, 2000, will implement more
stringent NOX, VOC and toxics reduction standards.
The best available data indicate that the RFG program has substantially reduced emissions of ozone
precursors and toxics (See Table 1). Analysis of fuel data reported by refiners for 1995 through 1998
indicates that emission reduction benefits exceeded the standards for VOCs, NOX, and toxics.30 Toxics
28 National Research Council (NRC), Ozone-Forming Potential of Reformulated Gasoline, May 1999.
29 U.S. Environmental Protection Agency, Regulatory Impact Analysis, 59 FR 7716, Docket No. A-92-12,
1993.
30 Refinery Reporting Data and RFG Survey Association Data. Data on gasoline properties contained in this
Issue Summary are derived from two primary sources. The RFG reporting data represent data submitted by the
universe of RFG producers or importers. The RFG survey data are derived from a carefully planned statistical
(continued...)
22
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reductions in particular were substantially greater than the standard (an over 33 percent reduction versus
a 17 percent requirement). (Refer to Figures B1 through B3 in this Issue Summary's Appendix).31 In
addition, ambient monitoring data also suggest that the RFG program is working. The EPA's 1995 Air
Quality Trends report, which coincides with the first year of the RFG program, shows a median reduction
of 38 percent in ambient benzene and significant decreases in other vehicle-related VOC concentrations
in RFG areas.32 No other control action could have accounted for such a substantial decrease in benzene
levels.
In 1998, Northeast States for Coordinated Air Use Management (NESCAUM) conducted an assessment
of the toxicity of conventional gasoline (CG) versus RFG sold in the Northeast. This study33 focused on
six toxic air pollutants [benzene, 1,3-butadiene, acetaldehyde, polycyclic organic matter (POM),
formaldehyde, and MTBE]. A modified version of the complex model, incorporating MTBE emission
rates, was used to compare differences in predicted emissions between composited average RFG and
conventional fuel types sold in the Northeast. While emissions estimated by the complex model may not
accurately represent actual emissions from the motor vehicle fleet, it does provide a means of
establishing relative effects of fuel composition on emissions. Relative cancer potencies were assigned
to the six compounds to compare carcinogenicity among fuel types. This study concluded that Phase I
RFG (in 1996) "served to reduce cancer risk associated with gasoline vapors and automobile exhaust. . .
by 12 percent. . . ." and that Phase II RFG would "reduce the public cancer risk ... by 20 percent. . . ."
This report also noted that "since the cancer potency of MTBE is significantly less than that of benzene,
1,3-butadiene and POM, its presence in RFG at 10 percent by volume tends to dilute other carcinogens. .
. ." The National Research Council (NRC) report also stated that the most significant advantage of
oxygenates in fuel appears to be displacement of some air toxics (e.g., benzene from RFG). For
additional information on typical fuels and standards, refer to Table B1 in Appendix B.
30 (...continued)
sampling of retail stations in various RFG cities. The survey plan is designed to estimate average gasoline
properties for a given area over a specific time period with a high degree of statistical confidence.
The calculation of VOC, NOx, and toxics reductions is based upon measured properties from these two data
sources and is calculated by the "complex model," a regression model based upon thousands of vehicle emissions
tests. As with any model, some uncertainty exists regarding the calculated emissions reductions and their
applicability for any given fleet in any given year.
31 U.S. Environmental Protection Agency bar charts reflect survey data collected from 19,000 samples during
1998. Data from RFG Survey Association.
32 U.S. Environmental Protection Agency, National Air Quality and Emissions Trends Report, 1995.
33 NESCAUM, Relative Cancer Risk of Reformulated Gasoline and Conventional Gasoline Sold in the
Northeast, August 1998.
23
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Table B1. Typical Fuels and Standards
Fuel Parameter
Conventional
Gasoline
Pre-RFG
Federal RFG Phase I
Actual1
(Summer)
Complex
Avg. Std.
Federal RFG Phase II
Actual
Averaging
Standard
California RFG
Actual
Averaging
Standard
Reid Vapor
Pressure (psi)
Sulfur (ppm)
Oxygen (wt%)
Aromatics (vol%)
Olefins (vol%)
E200 (%)
E300 (%)
Benzene (vol%)
8.7/7.8
339
<0.5
32
13
41
83
1.5
7.9/7.0
190
2.26
26
10
49
83
0.68
(8.0/7. 1)2
(285)
2.1 min
(32)
(10)
(45)
(83)
0.95 max
Phase II complex model performance (% reduction
VOC performance
NOx performance
Toxics performance
26.1
5.3
30.1
22.1
1.4
19.7
(6.7)
(150)
2.1 min
(25)
(11)
(49)
(87)
.95 max
6.8
20
2.07
23
4
51
89
0.55
(6.8)
30
(2.0)
22
4
(49)
(91)
0.8
from 1990 baseline) of these fuels:
29.8
6.8
28.4
29.9
14.6
37.0
29.6
14.7
34.4
'"Actual" Phase I summer (VOC-controlled) RFG properties and performance estimated from 1998 RFG Compliance Surveys.
Properties listed under the Federal RFG "standards" columns in parentheses are not standards per se, but indicate the average properties a
summer fuel must have to meet the emissions performance standards. The "/" indicates "North/South" specific values. South (VOC Control Region
1) values were used in performance comparisons.
As shown in Table 1, Phase II RFG, which takes effect on January 1, 2000, requires additional emission
reductions, beyond those required in Phase I. With the exception of air toxics and benzene, Phase II also
requires reductions that are greater than the actual reductions achieved in Phase I. However, for both air
toxics and benzene, the Phase II requirements, unless changed, would allow the formulation of RFG that
does not maintain the current benefits (e.g. a 22 percent reduction in toxics versus a 33 percent actual
Phase I reduction).
Table 1. Emission Reductions Required by the RFG Program
RFC Phase I
(1995-1999)
*
Actual RFC1 Phase
1 1998
RFG Phase II
(2000)
CaRFG Standards
(approx.)
VOCs NOx
Northern States: 17%
1.5%
Southern States: 37%
Northern States: 21.2% ,. _, .
A 2 OA T oc AO/ r> (4.9% Average;
Av>, 20.3 -25.0% Range 3.8%_7B4./0
Southern States: 39.4% Range)
Av, 38.4 - 40.3% Range
27% 6.8%
29.6% 14.7
Toxics Benzene Oxygen
17% 1% 2.0 wt%
(33. 2% Average;
23.7% -36 9% A68% 20wt%
Range)
22% 1% 2.0 wt%
34.4 0.8 0 - 2.0 wt%
'1998 RFG Compliance Survey Data (summer surveys), completed by the RFG Survey Association.
2"Av" = the average of the individual area results weighted by estimated gasoline volume in each area.
24
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B. CaRFG Program
Also, as shown in Table 1, the California RFG program has in place more stringent standards for its
Phase II than Federal RFG, in particular for NOX, air toxics, and benzene. The second phase in the
California RFG program (CaRFGII) is intended to ensure that benefits continue as the vehicle technology
advances and fleets turn over. CaRFGII helps automakers meet the increasingly stringent emission
standards for new vehicles. California's program requires automakers to certify their vehicles on
CaRFGII, thus ensuring that new vehicles will be designed to meet emission standards on a fuel similar
to what the vehicles will be operated with during daily use.
The CaRFG program is designed to ensure that different formulations of gasoline will meet the required
emissions performance levels. This is accomplished through the predictive model, which allows one to
compare the emissions performance of alternative fuel parameters against a standard set of parameters
contained in the CaRFG regulation. If the alternative formulation provides emission benefits equal to or
better than the standard formulation, emission benefits are preserved and the refiner (or fuel importer) is
allowed to market the fuel. To ensure the predictive model reflects the most recent data on the
relationship between fuel properties and emissions, the California Air Resources Board (CARB) is in the
process of updating the model to reflect newer technology vehicles. This will provide extra assurance
that the model will continue to be applicable as the vehicle fleet changes. In California, the predictive
model has been used to produce and market fuels with no oxygenates while preserving the program's full
air quality benefits.
C. EPA 1998 Area by Area Analysis
The EPA's Area by Area analysis of 1998 RFG Survey Data indicates that the complex model emissions
performance of RFG in Chicago and Milwaukee, while easily exceeding all Phase I performance (i.e.,
emission reduction) requirements, generally ranks low compared to other RFG areas. In order to
investigate factors influencing the performance of Chicago and Milwaukee RFG relative to RFG in other
areas, it is necessary to consider the composition of the fuels. Table B2 and an accompanying
discussion, located in the Appendix, discuss estimates of average values of the fuel properties that are
complex model inputs. The Chicago and Milwaukee properties are averages of the individual summer
survey property averages. The National Average properties were estimated by calculating an average for
each of the RFG areas surveyed during 1998, and then weighting these values by estimates of fuel
volume for each area. The National Average Reid vapor pressure (RVP) value was for VOC Control
Region 2 (North), which includes Chicago and Milwaukee. Other values include both regions.
(California oxygen-only surveys were not included in the oxygenate computations.)
The higher sulfur levels in Chicago and Milwaukee RFG areas affected its relative complex model
performance for all three pollutants (VOC, NOX, toxics). This analysis indicates that sulfur was the
primary factor influencing relative VOC and NOX performance, and that sulfur may have some influence
on toxics performance. The margin of air toxics overcompliance was not as great in Chicago and
Milwaukee as in other areas primarily due to higher benzene content, but other factors such as increased
acetaldehyde emissions and sulfur levels also contributed. Oxygenates had little impact on VOC or NOX
performance.
25
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Table B2. Chicago and Milwaukee Data
MTBE (wt% oxygen)
ETBE (wt% oxygen)
Ethanol (wt% oxygen)
TAME (wt% oxygen)
SULFUR (ppm)
RVP (psi) region 2
E200 (%)
E300 (%)
AROMATICS (vol%)
OLEFINS (vol%)
BENZENE (vol%)
National
Average
1.62
0
0.51
0.12
190
7.9
49.4
82.7
26.0
10.3
0.68
Chicago
0.08
0
3.38
0
255
7.9
50.7
81.8
25.1
6.7
0.90
Milwaukee
0.06
0
3.39
0
261
7.9
50.9
82.2
24.9
7.0
0.99
III. The Impact on RFG if Oxygenates are Removed
A. Introduction
MTBE provides about 76 percent of the oxygenate used in all RFG, and ethanol provides about 19
percent. The remaining 5 percent is made up of other ethers, tertiary-amyl methyl ether (TAME) and
ethyl tertiary butyl ether (ETBE).34 MTBE and ethanol have been the primary oxygenates in RFG
because of their availability, blendability, and ability to deliver air quality benefits while meeting
American Society for Testing and Materials (ASTM) specifications. (Refer to Table Dl in Issue
Summary D, Fuel Supply and Cost, for usage data and references.)
As shown in Table I above, Phase I RFG currently overcomplies with VOC, NOx, toxics, and benzene
requirements. The key question is whether this current overcompliance with the Phase I RFG standards
will be maintained in Phase II RFG if oxygenates are not required. Because the Phase II performance
standards for VOCs and NOX are above the current actual performance of Phase I RFG, all fuels will be
required to maintain or exceed the current VOC and NOx benefits, whether or not they contain
oxygenates. However, since the Phase II performance standard for air toxics (22 percent reduction) is
below the current Phase I actual reductions (average 33 percent reduction), there is no guarantee that the
current (Phase I) level of air toxics benefits will be maintained in all cases
The impact of removing oxygenates such as MTBE is not likely to be identical for CaRFG and Federal
RFG. Federal RFG is subject to fewer caps on specific properties (e.g. aromatics) than CaRFG and
therefore is more likely to show emissions impacts from the removal of oxygenates. Specific fuel
parameters (e.g. the CaRFG cap on aromatics) may provide extra assurance that certain pollution
reductions occur. Alternatively, performance standards (such as the current mass-based requirements for
toxics and VOCs) assure that pollution reductions will occur, but allow the refiner more flexibility in
determining how to achieve those reductions.
34 Estimate from 1997 RFG Survey Data.
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B. Air Toxics
Current RFG over complies with both the Phase I and planned Phase II toxics standards. With the data
available the panel could not determine with precision all of the factors which produce this
overcompliance. However, as is explained below, when blending gasoline, it is reasonable to conclude
that the use of octane-rich oxygenates is one of the factors that affects a refiner's decision to use high-
octane aromatics, a major contributor to the formation of toxic emissions.35
Decisions about refinery blending are complex and vary greatly over the range of U.S. refineries.
Despite the variability in fuels likely to result from this complex system, however, certain trends can be
identified that may help explain the larger-than-expected air toxics benefits.
First, it would be expected that each refiner would incorporate a measurable degree of
overcompliance in order to ensure that their fuel never falls below the standard.
Second, no matter how refiners blend fuel to meet the air quality standards, fuels will also be
blended to maintain at least the minimum octane required for current automobiles. Thus, one
would expect that with increased use of oxygenates (a high octane component) in RFG, one
would see, on average, reduced need for, and use of, other high-octane components such as
aromatics. Conversely, one would expect that with reduced use of oxygenates, this octane need
would be met, in part, with increased use of aromatics and, in the longer term once capacity is
expanded, alkylates.36
Third, although it is difficult to determine the precise role that oxygenates play in
overcompliance, and some fuels would likely be blended by some refiners with lower oxygen yet
35 Air toxics emissions reductions result primarily from reductions in RFG of aromatics and benzene (itself an
aromatic) when compared to pre-RFG gasoline.
36 The production of octane quality is the primary performance property considered by refiners in the
production of gasoline. All refining/blending decisions are based, in part, on the need for a certain minimum level
of octane quality in order that vehicles using the fuel operate properly. There are a limited number of octane rich
components that refiners can choose to produce needed octane. Aromatics, alkylates, and oxygenates are three of
the most available sources of octane quality for U.S. refiners. The most important (and for most refiners, the most
economical) gasoline upgrading process in U.S. refineries is catalytic reforming which produces aromatics and
increases the octane quality of the gasoline. (See, for example, Anderson, Robert O., Fundamentals of the
Petroleum Industry, University of Oklahoma Press, 1984, p. 221.) Reforming changes the shape of straight-chain
carbon molecules to high-octane ring-shaped molecules. These ring-shaped molecules are referred to as aromatics
and include benzene and benzene-like molecules. Since oxygenates are also primarily used for octane enhancement
when producing gasoline, for a refiner using these two octane sources, there exists a gasoline balance situation
between the use of aromatics and the use of oxygenates. Although the increased use of alkylates would also be
expected as oxygenates are reduced, U.S. reforming capacity to produce aromatics is far greater than is the capacity
to produce alkylates.
Under the federal RFG program, the oxygenate requirement results in a high level of octane quality and,
for the reasons mentioned above, would be expected to push the use of aromatics and benzene from reforming in a
downward direction. (Addition of oxygenate volumes would result in more than a 10 percent decrease in aromatics
and benzene from dilution alone, even if the octane quality properties are ignored.) Refiners would not be expected
to utilize refinery capacity to produce aromatics that are not needed for octane. Since aromatics (including benzene)
are the strongest contributors to the formation of toxics in the complex model, it is reasonable to conclude that the
use of oxygenates and the resulting downward movement in aromatics and benzene is likely responsible for a
substantial amount of the overcompliance in toxic emission reductions.
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high air toxics benefits, on average one would expect the presence of higher levels of oxygenate
in the fuel to lead to reduced levels of aromatics, and thus greater air toxics benefits.
Although reasonable to assume that oxygenates thus contribute to toxics overcompliance, it is difficult to
quantify this effect. The ideal data set would be able to compare fuels blended to meet current RFG
requirements with a full range of oxygen levels (i.e. 0%, .5%, 1.0%, 2%, etc.), and such a data set does
not exist. There is limited data from the State of Maine which recently implemented its own fuel
program, albeit with less stringent requirements than RFG, to substantially reduce the use of MTBE: fuel
properties reported by Maine's gasoline suppliers and distributors show a decrease in MTBE use by 50%
and a corresponding increase in aromatics of 20% over the levels of aromatics present in RFG sold in
Maine in 199737. There is also data from Northern California (where 2.0% oxygen is not required) that
CaRFG sold in the San Francisco area contained over 8% by volume MTBE in 1997 in part to meet the
more stringent CARB requirements for CaRFG, although such data must be interpreted carefully since
both the RFG requirements and the market situation in California are unique38.
The only other available data set is data on actual RFG fuel properties collected as part of the
implementation of the program. At the Panel's request, EPA analyzed available data on actual RFG
properties in the marketplace and the relationship in that data between MTBE use, air toxics and
aromatics content. The EPA's regulations allow producers of RFG to meet the oxygen content
requirement on an averaged basis and to employ oxygen credits to meet the averaged standard of 2.1
percent by weight. Consequently, the oxygen content in any given sample of RFG may vary to a limited
degree from the statutory 2.0 percent by weight per gallon requirement. In 1998 RFG fuel quality
surveys, the oxygen content of samples that did not contain ethanol but were oxygenated wholly or in
part with MTBE, varied between about 1.5 and 3.0 percent by weight. Even though the availability of
this data provides an opportunity to explore how aromatics content changes as oxygen levels vary, most
of the data points clustered around the 2.1 percent average standard and the data set contains no data for
oxygen levels below the regulatory minimum of 1.5 percent. Therefore, although the analyses performed
for the Panel showed a weak positive correlation between oxygen levels and both toxics performance and
aromatics content, and more recent analyses by the Colorado School of Mines of the same data found
some stronger correlations,39 the Panel concluded that this data is extremely limited and can not be used
for the purpose of coming to any specific quantitative statistical conclusions.
In the absence of certainty on the effects of removing oxygenates, the primary concern is that if the
oxygen mandate is removed and a significant amount of RFG does not contain oxygenates, use of
aromatics might rise at least in some portion of the RFG fuel blends. Such a rise would likely decrease
the overcompliance now seen for toxics in Federal RFG. In California, where CaRFG both requires
much lower sulfur levels and places a limit on the level of aromatics allowed in the fuel, such
overcompliance is more likely to continue. In the absence of certainty around this issue, the only way to
ensure that there is no loss of current air quality benefits is for EPA to seek mechanisms for both the
RFG Phase II and Conventional Gasoline programs to define and maintain in RFG II the real world
performance observed in RFG Phase I while preventing deterioration of the current air quality
performance of conventional gasoline.
37
NESCAUM, RFG/MTBE Findings and Recommendations, Boston, MA, August, 1999.
38 University of California, Health and Environmental Assessment of MTBE, Volume I. Summary and
Recommendations, R16, November 1998.
39 NESCAUM, RFG/MTBE Findings and Recommendations, Boston, MA, August, 1999.
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There are several possible mechanisms to accomplish this. One obvious way is to enhance the mass-
based performance requirements currently used in the program. At the same time, the panel recognizes
that the different exhaust components pose differential risks to public health due in large degree to their
variable potency. EPA should explore and implement mechanisms to achieve equivalent or improved
public health results that focus on reducing those compounds that pose the greatest risk.
C. Carbon Monoxide Benefits
Although there is no carbon monoxide (CO) standard for RFG, oxygenates affect CO emissions so that
current RFG actually produces significant CO benefits. Estimates show that about one-fourth of the CO
benefits associated with oxygenated RFG will disappear if oxygenates are on used.40 Thus, if RFG
contains no oxygenates, the CO reductions associated with RFG will be reduced by approximately 25
percent. This will be less critical in future years due to stricter tailpipe CO emission standards. As the
vehicle fleet turns over, the oxygenate impact on CO emissions diminishes (see Table 3). It is important
to note that there are now relatively few CO nonattainment areas (see discussion of Wintertime Oxyfuel
Program in Section V. below).
D. Particulate Matter Benefits
There are limited data available on the effect of oxygenates on emissions of particulate matter (PM). The
Colorado Department of Public Health and Environment conducted a study to evaluate the effects of
oxygenated fuels on motor vehicle emissions at low ambient temperatures.41 The study, which analyzed
winter oxygenated fuels rather than RFG, concluded that there were statistically significant PM
emissions reductions associated with the use of an ethanol oxygenated fuel.42 Additional research is
necessary including use of ethanol-oxygenated RFG and non-oxygenated RFG fuels in a variety of
climates, to better understand how different formulations of gasoline affect PM.
IV. Other Air Quality Considerations for Oxygenates
40 EPA estimate based on complex and MOBILE model calculations.
41 Colorado Department of Public Health and Environment (Ken Nelson and Ron Ragazzi), The Impact of a 10
percent Ethanol Blended Fuel on the Exhaust Emissions of Tier 0 & Tier 1 Light Duty Gasoline Vehicles at 35 F,
March 26, 1999.
42 This study involved testing light duty vehicles (LDVs) and trucks (LDTs) at 35 °F. Twelve Tier 0 and 12
Tier 1 vehicles (8 LDVs, 4 LDTs), six high emitters, and one low emission vehicle (LEV), were tested under three
driving cycles [Federal Test Procedure (FTP), Unified, and REPO5]. The FTP is based on typical urban driving
patterns. The Unified Cycle has higher speeds and accelerations than the FTP, and the REPO5 is a very aggressive
driving cycle. In this program, the FTP was conducted from a cold start while the other cycles were conducted from
a hot running start. The vehicles were tested with a non-oxygenated fuel and a 10 percent ethanol oxygenated fuel.
The program measured emissions of hydrocarbons (HC), CO, NOx, carbon dioxide (CO2) and fine particulate
(PM10 and smaller).
The study reported that FTP particulate emissions were reduced with the oxygenated fuel. For the FTP, a
mean absolute reduction of 3.31 milligrams per mile (mg/mi) or 36.0 percent was achieved for the main group of 24
Tier 0 plus Tier 1 vehicles. The reduction for the Tier 0 vehicles was 5.24 mg/mile, or 39.7 percent, and the
reduction for the Tier 1 vehicles was 1.38 mg/mi, or 26.6 percent. These absolute reductions were statistically
significant at the 95 percent confidence level. The numbers indicate that older vehicles receive greater PM benefits
from the use of oxygenated fuels than newer technology vehicles. No statistically significant differences were
detected for other driving cycles. There were no statistically significant changes in particulate emissions for the high
emitters. Because only one LEV was tested, statistical significance cannot be determined.
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A. Ozone Reactivity of Alternatives (CO Reduction)
One key question that has been raised about the air quality effects of RFG has been whether the ozone
reactivity of fuels with different oxygenates could be a better measure of ozone forming potential than
the correct mass-based measurement of VOCs.
A recently released report from the National Research Council (NRC), Ozone-Forming Potential of
Reformulated Gasoline, concluded that there is no compelling scientific basis at this time to recommend
that ozone forming potential or reactivity replace mass of emissions in the RFG program. A change from
the mass of emissions approach to a reactivity approach would not impact the choice of one fuel over
another from the standpoint of air quality benefits.
The NRC report found that fuel oxygen content appears to have only a small effect on the ozone forming
emissions of RFG with reductions in CO emissions and in exhaust emissions of VOCs but with some
evidence of increases in NOX emissions. The NRC did not examine the contribution of oxygenates to the
emissions of air toxics.
The NRC report found that the contribution of CO to ozone formation should be recognized in
assessments of the effects of RFG. The NRC committee found that CO emissions account for 15 percent
to 25 percent of the reactivity of exhaust emissions from light duty vehicles and should be included in
reactivity assessments because despite its low reactivity adjustment factor, the large mass of CO
emissions contributes to ozone formation.
B. Ethanol Blend Commingling with MTBE and Hydrocarbon Blends
An RVP43 increase of approximately one pound per square inch (psi) is caused by the addition of ethanol
to a hydrocarbon base fuel.44 As a result, all ethanol blended RFG is now blended with base gasoline that
has had certain high RVP components, such as pentanes and butanes, reduced in order to ensure that
ethanol blended RFG meets RVP requirements.45
Traditional thinking would conclude that when an ethanol blend is commingled with a non-ethanol blend
in a consumers tank, one would see a resulting RVP greater than would be expected from a simple
volume-weighted linear combination of the two blends' RVPs, at least if a sufficient amount of the
ethanol blend were to be present. Thus, in a 50-50 commingled blend, where 10 percent ethanol gasoline
with an RVP of 8.0 psi is added to an all-hydrocarbon gasoline with the same 8.0 psi RVP, the resulting
blend has an RVP of about 8.5 psi and not 8.0 psi as would be expected when non-ethanol blends are
commingled.
43 Reid vapor pressure is a measure of the gas pressure a liquid/gas system will apply to a closed system when
heated to 100 degrees Fahrenheit. As such, RVP is a measure of a liquid's volatility (i.e., its tendency to evaporate).
44 The size of increase in RVP is clearly affected by other factors, including the hydrocarbon makeup and
original volatility characteristics of the blend into which the ethanol is added.
45 EPA has promulgated a program controlling the RVP of conventional gasoline on a nationwide basis. (See
40 CFR 80.27.) This program allows for a 1.0 psi exemption for 10 percent ethanol blends. Thus, if this program
requires that RVP not exceed 9.0 psi for a given area, 10 percent ethanol blends are allowed at RVPs of up to 10
psi. This exemption for ethanol blends does not apply to the RFG program.
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Commingling these two blends is equivalent to first combining the hydrocarbon portion of both blends
and then adding the ethanol from the first blend to the combined hydrocarbon components. The
hydrocarbon gasoline by definition has an RVP of 8.0 psi. The hydrocarbon portion of the ethanol
gasoline had to have an RVP of 7.0 psi (since the subsequent addition of the ethanol produced an ethanol
gasoline with an RVP of 8.0 psi). The hydrocarbon components combine linearly producing a new
hydrocarbon component having an RVP of about 7.5 psi (halfway between 7.0 and 8.0 psi).46 Then,
adding in the ethanol component, which would now be about 5 percent of the final blend, increases the
RVP of the final blend to about 8.5 psi. It is important to note that although the new 50-50 commingled
blend would have an ethanol level of around 5 percent, not 10 percent as in the original ethanol blend,
the full 1.0 psi RVP increase due to ethanol addition would still occur even at this lower ethanol level.47
Although this scenario does accurately describe the basic principles involved in volatility changes when
these types of gasolines are blended, the reality is somewhat more complicated. The presence of less
polar oxygenates like MTBE can decrease the volatility bump to some degree when more polar
oxygenates like ethanol (e.g., as an ethanol blend) are added. This mechanism is called cosolvency.48
One recent study on the impact of ethanol blend commingling concluded in part that an RVP bump of
slightly greater than one psi occurs when ethanol is added at a two volume percent level in an all-
hydrocarbon blend, but that a bump of 0.7 psi occurs when ethanol is added to an MTBE blend at the
same original RVP level.49
In addition to the expected RVP increase, many other factors are extremely important in determining the
effect of commingling. These include ethanol blend market share, station/brand loyalty, and the
distribution of fuel tank levels before and after a refueling event. Caffrey and Machiele attempted to take
these variables into account in modeling the effect of ethanol blend commingling in a mixed fuel
marketplace. Their conclusions include the following:
(1) Brand loyalty and ethanol market share are much more important variables than the
distribution of fuel tank levels before and after a refueling event.
(2) Commingling effects can cause a significant increase in fuel RVP.
(3) Commingling effects are clearly more dramatic in a market in which a significant portion of
the gasoline is all-hydrocarbon (i.e., non-oxygenated). Depending on the combination of
variables chosen (/'. e., especially ethanol market share), the RVP increase over the entire gasoline
pool can range from around 0.1 to 0.3 psi in a reformulated gasoline market (i.e., ethanol blends
commingled only with MTBE blends). Analogous increases for a non-reformulated market (i.e.,
46 The final RVP resulting from the combination of these two hydrocarbon components would actually be
slightly higher than 7.5 psi since the volume of the hydrocarbon portion of the ethanol gasoline is less than the
volume of the hydrocarbon gasoline by an amount equal to the volume of the ethanol component.
47 These are approximations in order to demonstrate basic blending patterns. The volatility of blends resulting
from commingling are not necessarily exact linear interpolations of the volatilities of the commingled blends.
48 Peter Caffrey and Paul Machiele, "In-Use Volatility Impact of Commingling Ethanol and Non-Ethanol
Fuels," SAE Technical Paper #94065, February 29, 1994. See also, "The Octamix Waiver," 53 FR 3636, February
8, 1988.
49 Peter Caffrey and Paul Machiele, "In-Use Volatility Impact of Commingling Ethanol and Non-Ethanol
Fuels," SAE Technical Paper #94065, February 29, 1994.
31
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ethanol blends commingled only with all-hydrocarbon blends) range from under 0.1 psi to over
0.4 psi.
(4) The effects of the increase in RVP commingling approaches a maximum when the ethanol
market share becomes 30 to 50 percent, and declines thereafter as ethanol takes a larger market
share.
C. Fuel Quality in Conventional Gasoline
Conventional gasoline is controlled under EPA's Anti-Dumping Program. When the reformulated
gasoline (RFG) regulations were introduced, an anti-dumping program was also introduced. Refiners
(and importers) were required to provide information on CG to show that its properties become no worse
than they were in 1990. This program was meant to prevent refiners from simply removing "bad"
blendstocks from RFG and dumping these into CG. In order to show that properties of CG would not
deteriorate, refiners established individual 1990 baselines for CG, which were independently audited and
submitted to the EPA. Refiners who could not establish a baseline because of insufficient available
information were required to adopt the Clean Air Act baseline included in the statute. (Most parties
believe that the Clean Air Act baseline is actually more stringent than a typical individual refinery
baseline.)
However, there is no assurance that CG air toxics benefits gained since 1990 will be protected. The
EPA's 1997 refinery survey data indicates that 1997 CG sold in the Northeast was 12.8 percent less toxic
than 1990 levels. The data also indicate an additional 3.5 percent VOC reduction in the Northeast over
the 1990 levels.50
Under the complex model, refiners must not exceed their 1990 baselines for exhaust toxics and NOX.
Although EPA does collect information on the quality of CG, the first data on complex model CG (from
1998) were not required to be submitted to EPA until May 31, 1999. The analysis of that data will take
at least several months. Thus, at this time the EPA does not have current data on whether complex model
CG toxics is in overcompliance. The Agency has indicated, however, that this analysis would be a
critical element of guaranteeing that future increase in emissions potential will not occur in CG. Once
the analysis is completed, EPA should review any regulatory or administrative authorities available to
prevent deterioration of the current air quality performance of conventional gasoline.
If MTBE use was phased out, the antidumping program would prevent any increase in CG from 1990
NOX and toxics levels only. However, should MTBE be eliminated and ethanol use increase in CG,
Department of Energy (DOE) modeling shows a 6 to 7 percent VOC increase in conventional gasoline
due to the one pound waiver for ethanol use outside RFG areas. Regarding MTBE use in CG, the Energy
Information Administration (EIA) data show that very little MTBE is actually used in conventional
gasoline;51 estimates range, however, from 4,000 to 25,000 barrels per day. It should be noted that the
anti-dumping program would not prevent increases in MTBE use in CG.
50 NESCAUM, Relative Cancer Risk of Reformulated Gasoline and Conventional Gasoline Sold in the
Northeast, August 1998.
51 U. S. Energy Information Administration (Aileen Bonn and Tancred Lidderdale), Demand and Price Outlook
for Phase 2 Reformulated Gasoline, 2000, April 1999. Data indicate that 5 thousand barrels per day oxygenate
demand for conventional gasoline.
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EPA is also pursuing other initiatives that are related to the quality of CG. EPA has proposed a gasoline
sulfur program and, if any form of sulfur control program were adopted nationally, NOX levels in CG
would clearly be better than current levels.52 The Agency is also in the process of evaluating mobile
source air toxics and is expected to issue a proposal in early 2000, at which time the Agency will further
address the issue of toxic emissions.
V. Wintertime Oxyfuel Program
A. Introduction
In addition to the RFG program, the CAAA of 1990 required the establishment of a Wintertime Oxyfuel
program. Under this program gasoline must contain 2.7 percent oxygen by weight during the wintertime
in areas that are not in attainment for the National Ambient Air Quality Standards for CO.
In 1992, when the oxygenated fuels program began, there were 36 areas implementing the program. The
1998-99 oxygenated fuels season had 17 areas implementing the program. Nineteen areas were able to
redesignate to CO attainment due to the implementation of the oxygenated fuels program along with
other control measures. Of the remaining 17 areas, eight have data to redesignate and are either working
on or have submitted redesignation requests to EPA, or they have chosen to continue to implement the
program as a CO control measure even though they have attained the standard. Six areas are classified as
"serious" CO nonattainment areas, and the remaining three areas are classified as "moderate" CO
nonattainment areas; all of these areas continue to implement the program in an effort to attain the CO
standard.
Most of the winter oxygenated fuel areas use ethanol. The only two areas using MTBE for the winter
oxygenate program are Los Angeles and the New York City metropolitan area. It is a possibility that
New York City, which includes metropolitan Connecticut, New Jersey, and New York, will leave the
program before the next winter season because they will demonstrate attainment with the CO standard.
Los Angeles will need to phase-out MTBE use under the Governor's recent directive. Therefore, MTBE
use for winter oxygenated areas is not likely to be common in the future.
52 The Panel is aware of the current proposal for further changes to the sulfur levels of gasoline and recognizes
that implementation of any change resulting from the Panel's recommendations will, of necessity, need to be
coordinated with implementation of these other changes. However, a majority of the Panel considered the
maintenance of current RFG air quality benefits as separate from any additional benefits that might accrue from the
sulfur changes currently under consideration.
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B. Air Quality Benefits
The most comprehensive study regarding oxygenated fuels was completed in June 1997 by the Office of
Science and Technology Policy (OSTP).53 The report concluded that "analyses of ambient CO
measurements in some cities with winter oxygenated fuels programs find a reduction in ambient CO
concentrations of about 10 percent."54 The report also suggested "the need for a thorough, statistically
defensible analysis of ambient CO data." In response to that suggestion, EPA initiated a study55 that
analyzed ambient CO data from about 300 monitoring sites. The study indicated a downward shift in
ambient CO ranging from 6 percent to 13 percent for the six month winter season in areas implementing
an oxyfuel program in 1992. This EPA study was further refined by Systems Applications International
(SAI).56 The SAI study analyzed summer (June and July) and winter (December and January) bimonthly
means or maximum daily 8-hour CO concentrations from 1986 to 1995. The report concluded that there
was a substantial (14 percent reduction) and statistically significant association (± 4 percent with 95
percent confidence) between the use of oxyfuels and monitored CO concentrations.
On this point, the OSTP report concluded:
Older technology vehicles (carbureted and oxidation catalysts) benefit more from the use
of oxygenated fuel. The amount of pollutant emissions is smaller in newer technology
vehicles (fuel injected and adaptive learning, closed loop three-way catalyst systems).
Additionally, the percentage reductions in CO and hydrocarbon emissions from the use
of fuel oxygenates are found to be smaller in the newer technology vehicles compared to
older technology and higher emitting vehicles.57
Analysis by the EPA (MOBIL6 Model) also indicates that even with fleet turnover, a significant
contribution to CO reduction from the winter oxygenated program is expected until at least 2005
(Table 3).
53 Office of Science and Technology Policy, National Science and Technology Council, Interagency
Assessment of Oxygenated Fuels, June 1997.
54 Office of Science and Technology Policy, National Science and Technology Council, Interagency
Assessment of Oxygenated Fuels, June 1997, p. iv.
55 U.S. Environmental Protection Agency, Office of Mobile Sources, (R. Cook), Impact of the Oxyfuel
Program on Ambient CO Levels, 1996.
56 Systems Application International, Regression Modeling of Oxyfuel Effects On Ambient CO Concentrations,
January 1997.
57 Office of Science and Technology Policy, National Science and Technology Council, Interagency
Assessment of Oxygenated Fuels, June 1997, p. iv.
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Table 3. Percent Reduction in CO Emissions Resulting from 3.5 Percent Oxygen,
As Predicted by the MOBILE Model58
Year MOBILE6
1997 10% to 20%
2000 5% to 15%
2005 0%tolO%
2010 0%to2%
Source: U.S. Environmental Protection Agency
Most winter oxygenated areas use ethanol, which is typically blended at 3.5 percent by weight.
Therefore the chart reflects actual benefits rather than the benefits that may result from the regulatory
requirement of 2.7 percent oxygen by weight. If a lower oxygen level is used, one would expect there to
be a linear downward trend in benefits.
The U.S. Environmental Protection Agency's Area by Area analysis of 1998 RFG Survey Data indicates
that the complex model emissions performance of RFG in Chicago and Milwaukee, while easily
exceeding all Phase I performance (i.e., emission reduction) requirements, generally ranks low compared
to other RFG areas. In order to investigate factors influencing the performance of Chicago and
Milwaukee RFG relative to RFG in other areas, it is necessary to consider the composition of the fuels.
The Chicago and Milwaukee property values were similar, and there were notable differences from the
National Average properties. The sulfur and benzene levels for Chicago and Milwaukee were
substantially higher. These two areas had the highest and second highest levels of all areas for these
parameters. Oxygenate type and oxygen content differed from the National Average. Ethanol was the
primary oxygenate used in these areas. Therefore, the total oxygen content and the ethanol contribution
to total oxygen were highest for these areas. Olefin content was lower than the National Average RFG,
and the olefin content for these two areas was the lowest of all areas surveyed.
The higher sulfur levels in the Chicago and Milwaukee RFG affected its relative complex model
performance for all three pollutants. This analysis indicates that sulfur was the primary factor
influencing relative VOC and NOx performance, and that it may have some influence on toxics
performance. Although 1998 RFG Survey Data indicates that the complex model emissions performance
of RFG in Chicago and Milwaukee, easily exceeded all Phase I performance (i.e., emission reduction)
requirements. The margin of air toxics overcompliance was not as great there as in other areas primarily
due to higher benzene content, but other factors such as increased acetaldehyde emissions and sulfur
levels also contributed. Oxygenates had little impact on VOC or NOX performance.
58 MOBILE6 effects are draft only. Only after MOBILE6 is finalized will actual and more accurate estimates
be available. These projected MOBILE6 Oxy-on-CO effects are based on MOBIL Report #M6.FUL.002, which is
posted on the MOBILE6 web site (http://www.epa.gov/OMS/M6.htm.')
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It is important to realize that this analysis was intended to identify factors which caused Chicago and
Milwaukee to rank lower than most other RFG areas in complex model emissions performance. The
approach was to vary one property at a time and look at its effect on emissions performance. In reality,
fuel properties are not independent, and this "one at a time" analysis was not intended to answer more
complex questions such as "What would happen to fuel properties and emissions performance if Chicago
and Milwaukee RFG suppliers switched from ethanol to MTBE?"
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Appendix B
Figure Bl. RFC Survey Data, Summer 1998: Phase I VOC Reduction
Lewiston-Auburn, ME
Louisville, KY
Portland, ME
Rhode Island
Covington, KY
Portsmouth-Dover, NH
Springfield, MA
Manchester, NH
CT (remainder)
Boston, MA
Hartford, CT
Poughkeepsie, NY
Philadelphia, PA
Chicago, IL
Milwaukee, Wl
NY-NJ-LI-CT
Averaged Std.
Per. Gal. Std.
Houston.TX
Norfolk.VA
Richmond.VA
Dallas.TX
Baltimore, MD
Washington, D.C.
Averaged Std.
Per. Gal. Std.
I VOC Reg. 2
VOC Reg. 1
10
15 20 25 30
Percent Reduction from 1990 Baseline
35
40
45
37
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Figure B2. RFG Survey Data, Summer 1998: Phase I Toxics Reduction
Rhode Island
Springfield, MA
Boston, MA
CT (remainder)
Hartford, CT
Baltimore, MD
Poughkeepsie, NY
Washington, D.C.
NY-NJ-LI-CT
Philadelphia, PA
Richmond.VA
Manchester, NH
Dallas.TX
Norfolk.VA
Portsmouth-Dover, NH
Lewiston-Auburn, ME
Portland, ME
Houston.TX
Covington, KY
Louisville, KY
Chicago, IL
Milwaukee, Wl
Averaged Std.
Per. Gal. Std.
10
15 20 25
Percent Reduction from 1990 Baseline
30
35
40
38
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Figure B3. RFC Survey Data, Summer 1998: Phase I NOx Reduction
Boston, MA
Portsmouth-Dover, NH
Rhode Island
Springfield, MA
Portland, ME
Lewiston-Auburn, ME
Philadelphia, PA
Manchester, NH
Dallas-Fort Worth, TX
CT (remainder)
Hartford, CT
Houston-Galveston, TX
Baltimore, MD
Covington, KY
Norfolk.VA
Poughkeepsie, NY
Washington, D.C.
NY-NJ-LI-CT
Chicago, IL
Richmond.VA
Louisville, KY
Milwaukee, Wl
Averaged Std.
Per. Gal. Std.
345
Percent Reduction from 1990 Baseline
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C. Prevention, Treatment, and Remediation
I. Introduction
This Issue Summary reviews the technical and regulatory approaches to reducing the sources of
oxygenate impacts on water resources; release prevention and detection; storage tank-related issues;
Federal and State approaches to protecting drinking water sources; the treatment of impacted drinking
water; the remediation of oxygenate-impacted ground water; and funding sources. Because of recent
detections of methyl tertiary butyl ether (MTBE) in drinking water supplies, MTBE is emphasized
throughout this section. The body of information available to evaluate impacts of other gasoline
oxygenates on water resources is significantly more limited.
The water resources described in this section are generally divided into two categories: surface water
(streams, lakes, reservoirs, and stormwater); and ground water (water table and confined aquifers).
Drinking water refers to those water resources currently used for public and private water supply
systems. Although a variety of sources of MTBE impacts to water quality have been identified, this
section focuses primarily on releases from underground storage tank (UST) systems, as this population
comprises the vast majority of the known potential point sources and has been studied in much greater
detail than other potential sources of MTBE impact.
II. Sources and Trends of Water Quality Impacts
As described in Issue Summary A (Water Contamination), surface water and ground water resources are
impacted by both gasoline oxygenates and a variety of other natural and anthropomorphic sources of
contaminants. There are a number of primary sources that appear to be responsible for most identified
MTBE impacts:
Underground storage tanks, other gasoline storage and distribution facilities,
such as bulk storage terminals, small household/farm gasoline tanks, and
aboveground storage tanks;
Interstate and intrastate petroleum pipelines;
Small releases (e.g., gasoline tank ruptures during car accidents or consumer
disposal of gasoline in backyards) appear to have been the source of private well
contamination in Maine.59 These types of releases are also expected to be a
source of contamination to private wells in other States;
Engine exhaust and related releases (e.g., spillage) into lakes and reservoirs from
two-stroke watercraft and older four-stroke watercraft;
Stormwater runoff.
59 State of Maine Bureau of Health, Department of Human Services, Bureau of Waste Management &
Remediation, Department of Environmental Protection, Maine Geological Survey, and Department of Conservation,
Maine MTBE Drinking Water Study, The Presence of MTBE and other Gasoline Compounds in Maine's Drinking
WaterPreliminary Report, 1998.
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A. Assessing Impacts and Trends
There are no comprehensive quality assessments of our nation's water resources that can provide clear
indications of the trend of MTBE impacts on water supplies. Further, it is unknown how frequently
gasoline compounds are released from the current population of UST systems or the quantity of gasoline
that is released. As such, it is unknown whether releases of gasoline and related impacts to water
resources are continuing to grow, whether increasing awareness of this issue has stabilized or reduced the
frequency of such releases, or whether they are on the decline. Not all States require monitoring for
MTBE at LUFT sites and in drinking water quality sampling, further preventing a full characterization of
MTBE's current or potential future impacts.
New Federal and State UST regulations promulgated in the 1980's have spurred comprehensive
assessments and corrective action programs at facilities with USTs. As of December 1998, many
currently regulated UST facilities can be expected to have had some type of site assessment conducted as
part of compliance activities and property transfer information requirements in order to determine
whether there have been any releases. The number of identified UST releases has grown steadily during
the last decade, averaging about 20,000 new known releases annually.60 Most releases have been
discovered with tank removal during the tank upgrading process, rather than being detected as part of a
continuous monitoring program. Thus, it is not possible to know when the release actually occurred
(e.g., many releases reported in 1998 occurred in previous years, but were only discovered in 1998). The
rate at which new release sites are discovered is expected to decrease in coming years, as most UST
facilities being evaluated for contamination were in the process of meeting the December 1998 upgrading
deadline. Because of limitations inherent in current leak detection technologies, it is expected that
releases reported in future years from the current population of upgraded facilities will not provide a
more accurate characterization of the occurrence of new releases.
Limited information is available regarding releases from other gasoline storage/distribution facilities, and
very little data exist to characterize the extent to which other types of gasoline releases occur.
B. Underground and Aboveground Storage Tanks
Underground storage tanks represent the largest population of potential point sources of gasoline releases
to ground water.61 Gasoline storage and distribution facilities are of particular importance as potential
sources of ground water contamination from MTBE and other oxygenates, because these facilities can
release relatively large volumes of gasoline (e.g., hundreds of gallons to thousands of gallons), which
can result in localized subsurface impacts with aqueous concentrations in excess of 100,000 parts per
billion (ppb) adjacent to the release source, as well as extensive dissolved plumes at lower
concentrations. In California, MTBE (associated with gasoline releases throughout the State) is a
frequent and widespread contaminant in shallow groundwater. Detections of MTBE are reported at 75
percent of sites where fuel hydrocarbons have impacted ground water. The minimum number of MTBE
point sources from leaking underground storage tank (LUST) sites in California is estimated at greater
than 10,000. Maximum concentrations at these sites ranged from several ppb to concentrations greater
than 100,000 ppb, indicating a wide range in the magnitude of MTBE impacts at these sites (Table 1).
60 U.S. Environmental Protection Agency, Office of Underground Storage Tanks, "Corrective Action
Measures Archive," http://www.epa.gov/swerustl/cat/camarchv.htm.
61 U. S. Environmental Protection Agency, Office of Water, National Water Quality Inventory: 1996 Report to
Congress, 1996.
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Table 1. Comparison of Maximum MTBE Ground Water Concentrations Collected by the California
Regional Boards, January 1999
MTBE Concentration Sites Exhibiting Concentration
(Parts Per Billion) Level (Percent)
<5 23%
5-50 12%
50-200 11%
200-1,000 17%
1,000-5,000 14%
5,000-20,000 13%
20,000-100,000 7%
> 100, OOP 3%
Note: Data represent collections from 4,300 sites.
Source: Happel, Dooher, and Beckenbach, "Methyl Tertiary Butyl
Ether Impacts to California Groundwater," presentation at the March
1999 MTBE Blue Ribbon Panel meeting.
There are currently an estimated 825,000 regulated USTs at approximately 400,000 facilities.62 Of the
nation's approximately 182,000 retail gasoline outlets, the "major" oil companies own about 20 percent,
or about 36,000 facilities.63 On average, each of the nation's retail outlets have about 3 storage tanks,
thus containing a total of approximately 550,000 USTs, 66 percent of the national total. The remainder
of the regulated UST population consists of state or federally owned facilities and nonretail fueling
facilities (e.g., on-site fueling for taxis, rental cars, delivery trucks, etc.). Over the past 10 years,
approximately 1.3 million Federally regulated USTs have been closed, i.e., removed or properly emptied,
cleaned, and buried in place.64
There are approximately 3 million underground fuel storage tanks exempt from Federal regulations (e.g.,
certain farm and residential gasoline tanks and home heating oil tanks).65 Large aboveground storage
tanks (ASTs) at refineries and distribution terminals, however, are regulated under both State and Federal
laws, including the Spill Control and Countermeasures (SPCC) regulations of the Oil Pollution Act
(OPA) of 1990. There are currently over 10,000 facilities with this type of bulk storage of gasoline. As
compared with USTs, there is no comparable Federal regulatory program for ASTs, and thus current
release statistics for ASTs are not available. A 1994 American Petroleum Institute (API) survey
62 U.S. Environmental Protection Agency, Office of Underground Storage Tanks, based upon FT 1999 Semi-
Annual Activity Report - First Half (unpublished).
63 National Petroleum News, Market Facts 1998 (Arlington Heights, IL: Adams Business Media, 1998), p.
124.
64 There is no database that identifies the specific locations of these federally regulated facilities or their
proximity to drinking water supply sources. See U.S. Environmental Protection Agency, Office of Underground
Storage Tanks, "Corrective Action Measures Archive," http://www.epa.gov/swerustl/cat/camarchv.htm.
65 U.S. Environmental Protection Agency, Underground Heating Oil And Motor Fuel Tanks Exempt From
Regulation Under Subtitle I Of The Resource Conservation And Recovery Act (May 1990).
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estimated that ground water contamination had been identified at approximately 68 percent of marketing
terminals with ASTs, 85 percent of refinery tank fields with ASTs, and 10 percent of transportation
facilities with ASTs. Of these facilities, over 95 percent were engaged in corrective action under the
guidance of a State or Federal authority.66
C. Pipelines
Excluding intrastate pipelines and small gathering lines associated with crude oil production fields, there
are approximately 160,000 miles of liquids pipelines in the United States.67 These pipelines transport
approximately 12.5 billion barrels of crude oil and refined products annually. Over a recent six-year
period (1993 to 1998), an average of 197 spills occurred annually, with an average volume from all spills
totaling 140,000 barrels per year. Of the volume spilled during this period, crude oil accounted for 44
percent, whereas refined petroleum products (e.g., gasoline, home heating oil, jet fuel) accounted for 31
percent. Although the specific volume of gasoline spilled cannot be readily identified, gasoline
represents the largest volume of refined products transported. Additionally, there are little or no data on
the extent of MTBE releases from pipelines.
In California, pipeline release data are currently being compiled by the Office of the State Fire Marshal,
which regulates approximately 8,500 miles of pipelines. Since 1981, there have been approximately 300
pipeline releases within the State Fire Marshal's Jurisdiction.
The pipeline industry is working with pipeline regulators and environmental trustee agencies to develop a
definition of areas that may be unusually sensitive to environmental damage from pipeline leaks to be
used in conducting future risk assessments along pipeline rights-of-way. Included under the draft
definition are areas with drinking water resources, which are based on EPA's standards for defining both
surface and subsurface drinking water supplies. Once work is completed both on drinking water and
biological resources that may be unusually sensitive to environmental damage, OPS will make
information available for pipeline operators to use in conducting risk assessments along pipeline rights-
of-way. The Office of Pipeline Safety may also require increased pipeline integrity standards to prevent
releases in unusually sensitive areas.68
In California, the locations of fuel pipelines and drinking water wells are being integrated into a
geographic information system (GIS), which is discussed in greater detail in Section V of this Issue
Summary. The State Fire Marshal Office is required at least once every two years to determine the
identity of each pipeline or pipeline segment that transports petroleum products within 1,000 feet of a
public drinking water well. Furthermore, these pipelines' operators must be notified to prepare a pipeline
wellhead protection plan for the State Fire Marshal's approval.
D. Small Releases
66 American Petroleum Institute, A Survey of API Members'Aboveground Storage Tank Facilities, July 1994.
67 The U.S. Department of Transportation (DOT)'s Office of Pipeline Safety (OPS) oversees the safety and
environmental regulation of interstate petroleum pipelines. Petroleum pipelines are also subject to economic
regulation by the Federal Energy Regulatory Commission (FERC).
68 Development of the definition and its subsequent application are subject to notice and comment
requirements under Federal rulemaking procedures.
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Small releases from automobile accidents, consumer disposal of "old" gasoline, or other backyard spills
during fueling operations have been identified by officials in Maine as sources of contamination of
private drinking water wells. For example, in a 1998 study of over 900 private household drinking water
wells in Maine, approximately 16 percent had detectable MTBE concentrations, and about 1 percent
contained concentrations exceeding the State of Maine's 35 ppb drinking water standard.69 In one
incident in Maine, about 7 to 12 gallons of gasoline spilled during a car accident contaminating 24
nearby private wells installed in a bedrock aquifer. Eleven of the wells had MTBE concentrations in
excess of 35 ppb. Following the excavation of the contaminated soil, well monitoring at this site has
indicated that MTBE levels are decreasing rapidly in all wells. Similarly, home heating oil storage tanks
have also been identified as potential sources of MTBE contamination, as MTBE might be present from
mixing the heating oil with small volumes of gasoline in the bulk fuel distribution or tank truck delivery
systems.70
E. Watercraft
Gasoline-powered watercraft have contributed to the contamination of lakes and reservoirs with MTBE.
These impacts are primarily attributed to exhaust discharges from two-stroke engines, which are the most
commonly used engine type in such watercraft. The two-stroke engines discharge in their exhaust up to
30 percent of each gallon of gasoline as unburned hydrocarbons. In two recent studies examining MTBE
contamination at lakes at which reformulated gasoline (RFG) with MTBE was used, concentrations of
MTBE in substantial portions of the lakes' volume ranged from 10 ppb to 30 ppb after peak periods of
recreational watercraft usage.71 After the boating season ended, these concentrations decreased fairly
rapidly (half-life of approximately 14 days) to low background levels (approximately 1 ppb to 2 ppb or
less). Volatilization is considered the dominant mechanism for this removal process.72
F. Stormwater Runoff
Stormwater runoff is considered a nonpoint source of MTBE contamination. Runoff becomes
contaminated with MTBE from both the dissolution of residual MTBE from parking lots (e.g., service
69 State of Maine Bureau of Health, Department of Human Services, Bureau of Waste Management &
Remediation, Department of Environmental Protection, Maine Geological Survey, and Department of Conservation,
Maine MTBE Drinking Water Study, The Presence of MTBE and Other Gasoline Compounds in Maine's Drinking
WaterPreliminary Report, 1998.
70 G.A. Robbins et al., "Evidence for MTBE in Heating Oil," Ground Water and Remediation, Spring 1999,
pp. 65-68.
71 M.S. Dale et al., "MTBE ~ Occurrence and Fate in Source-Water Supplies," in American Chemical Society
Division of Environmental Chemistry preprints of papers, 213th, San Francisco, CA: American Chemical Society,
v. 37, no. 1, 1997, pp. 376-377; J.E. Reuter et al., "Concentrations, Sources, and Fate of the Gasoline Oxygenate
Methyl Tert-Buryl Ether (MTBE) in a Multiple-Use Lake," Environmental Science & Technology, 1998, v. 32, mo.
23, pp. 3666-3672.
72 J.E. Reuter et al., "Concentrations, Sources, and Fate of the Gasoline Oxygenate Methyl Tert-Buryl Ether
(MTBE) in a Multiple-Use Lake," Environmental Science & Technology, 1998, v. 32, mo. 23, pp. 3666-3672.
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stations and retail businesses) and roadways and from "atmospheric washout."73 MTBE contamination
from atmospheric washout is thought to be small compared to that from paved surfaces.74 The United
States Geological Survey (USGS) has characterized MTBE concentrations in runoff in many areas and
has typically found such contamination to be lower than 2 ppb. Stormwater is discharged both to surface
water and to ground water, and thus serves as a source of very low-level MTBE contamination of these
potential drinking water sources.
III. Release Prevention and Detection
A. Prevention
Since the passage of Federal UST legislation in 1984, improved release prevention practices (e.g.,
corrosion protection, and compatibility between the tank's construction materials and its contents) has
been required for all new USTs. Following a 10-year phase-in period from the promulgation of EPA
regulations in 1988, as of December 1998, all regulated USTs are required to be protected from
corrosion, small spills, and overfills, and must also have release detection equipment and procedures in
place. Many States have additional and more stringent standards. These regulations are intended to
prevent releases, and should a release occur, to detect it promptly in order to minimize ground water
impacts. Presently, it is not possible to demonstrate the effectiveness of individual States' UST upgrade
programs or the Federal upgrade program in preventing releases of gasoline from dispensing/storage
facilities.
Even after tank systems (tanks and piping) are in full compliance with the 1998 regulations, however,
some releases are expected to occur as a result of improper installation or upgrading, improper operation
and maintenance, and accidents. Many of these releases may not be detected as intended due to the
inherent limitations of release detection technologies.
Anecdotal reports from California, Maine, and Delaware indicate that upgraded USTs continue to have
releases. Efforts are underway by the EPA and in California to evaluate new and upgraded UST systems
to determine which factors may contribute to such releases. In California, for example, the Santa Clara
Valley Water District has completed a study evaluating release prevention and detection performance at
approximately 30 upgraded facilities.75 The California Environmental Protection Agency (CalEPA) is
planning to begin a similar study in 1999. Further studies will likely be required in order to investigate a
representative sampling of the UST population.
73 G. C. Delzer et al., Occurrence of the Gasoline Oxygenate MTBE and BTEX Compounds in Urban
Stormwater in the United States, 1991-95, U.S. Geological Survey Water Resources Investigation Report WRIR
96-4145,1996.
74 A.L. Baehr, RE. Stackelberg, and R.J. Baker, "Evaluation of the Atmosphere as a Source of Volatile
Organic Compounds in Shallow Ground Water," Water Resources Research, Jan. 1999, v. 35, no. 1, pp. 127-136;
T.J. Lopes and D.A. Bender, "Nonpoint Sources of Volatile Organic Compounds in Urban Areas ~ Relative
Importance of Urban Land Surfaces and Air" Environmental Pollution, 1998, v. 101, pp. 221-230.
75 Santa Clara Valley Water District Groundwater Vulnerability Pilot Study, "Investigation of MTBE
Occurrence Associated with Operating UST Systems," July 22, 1999. http://www.scvwd.dst.ca.us/wtrqual/
factmtbe.htm.
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Based on reports received to date from the States, EPA estimates that approximately 80 percent of the
regulated universe of UST systems currently meet the December 1998 requirements.76 By the end of
2000, EPA expects at least 90 percent of the regulated tanks will be in compliance, leaving
approximately 80,000 tanks that have not been upgraded. States' UST programs are primarily
responsible for implementing and enforcing UST regulations. In augmenting and assisting States'
activities, EPA provides outreach, helps States train UST inspectors, and fosters the exchange of
information among States regarding effective means of securing compliance. Upon a State's request, or
acting independently when necessary, EPA will also take direct action to enforce the regulations.
Approximately 20 States now prohibit deliveries to UST systems that are not fully compliant with the
December 1998 regulations, and several major gasoline suppliers have stopped fuel delivery to
non-compliant tanks. These actions, along with the traditional enforcement actions taken by EPA and
States, have contributed to higher compliance rates.77
The U.S. Environmental Protection Agency and the States also require that USTs that do not meet the
technical standards are properly closed with thorough site assessments for potential releases. Through
December 29, 1999, non-compliant USTs can be temporarily closed, but must be permanently closed,
and any releases identified and remediated, thereafter if not brought into compliance.
Currently, there is an apparent trend toward using small ASTs (i.e., fewer than 20,000 gallons) to replace
regulated USTs.78 These ASTs are generally not subject to the same release prevention and detection
requirements as USTs. Releases from ASTs may also result in MTBE contamination, and so it may be
necessary to evaluate the performance of such systems.
B. Detection
Existing regulations require the use of release detection techniques that meet specific performance
criteria. Internal (e.g., automatic tank gauges) or external (e.g., ground water monitoring) approaches
may be used in meeting these criteria. Although these regulations do not allow any detected releases to
go unreported, the regulations do permit several options of varying degrees of sensitivity in the detection
of a release, which can result in smaller releases going undetected for an extended period of time.79 The
regulations, promulgated in 1988, were considered adequate and "best available technology" for typical
gasoline (and other fuels) formulations at the time because hydrocarbon plumes are generally self-
limiting (primarily due to intrinsic bioremediation) and thus small releases or slow chronic releases that
76 U.S. Environmental Protection Agency, Office of Underground Storage Tanks, estimate based upon data
submitted by States on February 28, 1999 and April 30, 1999 (unpublished).
77 Ellen Frye, "When Push Comes to Shove," L USTLine, September 1998.
78 Juan Sexton, Kansas State Department of Health & Environment, paper presented at the 10th Annual
UST/LUST National Conference (Long Beach, CA, March 30, 1999); Wayne Geyer, "Above the Ground but not
the Law: ASTs on the Rise, Regulators in Hot Pursuit," Petroleum Equipment and Technology, July 1999.
79 For example, under one option, a 0.2 gallon per hour release could go undetected in up to 5 percent of all
cases (i.e., it is detected in 95 of 100 instances) and unreported by compliant systems (in a worst case scenario).
The same technology should not have greater than a 5 percent occurrence of false alarms. Other types of leak
detection may have lower or higher thresholds and still meet the EPA guidelines. A 0.2 gallon/hour release would
result in a release of 1,752 gallons if undetected for one year, and could go undetected for several years.
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remain undetected have typically not resulted in drinking water impacts. The regulations did not address
the use of oxygenates although they were used as octane enhancers at this time, albeit at generally lower
levels than in RFG and oxyfuel.80
Changing existing UST release detection regulations to address the use of oxygenates in gasoline will
require EPA to analyze the risks, costs, and benefits of any regulatory changes. In the past, changing
such a regulation has taken three to five years. The U.S. Environmental Protection Agency has initiated a
field verification study of UST release detection performance and expects initial results in early 2000.81
IV. Underground Storage Tanks
A. Materials Compatibility
The use of oxygenates in gasoline in the conventional gasoline supply was well established in the mid-
1980's when EPA began formulating the current Federal UST regulations (1998), which formally
identified and addressed compatibility issues. The regulations noted that standard specifications for steel
and fiberglass tank system materials had been established to provide for compatibility with
gasoline/oxygenate mixtures containing up to 15 percent by volume MTBE, 10 percent by volume
ethanol, and 5 percent by volume methanol. Industry standards for materials compatibility have been in
place since 1986.
A recent evaluation concluded that there are no known studies indicating that any significant
deterioration will occur in metal or fiberglass UST systems as a result of concentrations of MTBE or
other oxygenates in gasoline.82 The same study indicated, however, that given the lack of existing "real
world" characterizations of the long-term performance of typical UST system materials, further
independent quantitative evaluation may be warranted, particularly with regard to potential metallic
corrosion, fiberglass permeability, and the elastomer integrity of gaskets and seals. Because tank and
piping materials may be in contact both with gasoline vapors and water containing high concentrations of
dissolved gasoline components, compatibility with the vapor or aqueous phase of oxygenated gasolines
may also merit study, especially if there is potential for the substantial enrichment of oxygenates in either
phase.
B. Training, Education, and Certification
It has long been recognized that UST releases can be caused by the failure to adequately perform certain
standard installation and daily operational and maintenance practices. Despite existing regulations that
address many of these practices, owners, contractors, and employees may not routinely exercise
appropriate care in performing these activities. The most frequently identified problem areas include
80 The use of oxygenates in gasoline was well established by the mid-1980's.
81 Thomas M. Young and the U.S. Environmental Protection Agency, Field Evaluation of Leak Detection
Performance, National Leak Detection Performance Study, 1999.
82 Kevin Couch and Thomas M. Young, "Leaking Underground Storage Tanks (USTs) as Point Sources of
MTBE to Groundwater and Related MTBE-UST Compatibility Issues," in University of California and UC Toxic
Substances Research & Teaching Program, Health and Environmental Assessment of MTBE, Volume IV, 1998.
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installation, fuel delivery and procedures, and routine maintenance of dispensers and release detection
equipment.83
Federal UST law contains neither any requirement nor any authority for the certification of owners,
operators, inspectors, or contractors. In practice, most Federal, State, and local inspectors are well
trained, and many UST owners require training for their employees. There is often considerable turnover
of facility employees in State and local programs, however, and constant training is required. A few
States have third party inspection programs requiring that facility owners hire a certified inspector to
document a facility's state of compliance, although there is anecdotal evidence that these programs are
not followed.
States have taken the impetus in certification and similar programs. For example, half of the States have
programs for licensing or certifying contractors who install, repair, and remove USTs. A smaller
percentage of States (perhaps 25 percent) require certification or licensing of tank testers primarily for
those who perform release detection tests. Finally, even a smaller percentage of States, probably around
20 percent, have registration or certification programs for remediation contractors. As these estimates
indicate, further progress could be made in establishing such programs in additional States.
V. Protection of Drinking Water Sources and Water Quality Management
A. Federal Efforts
Section 1453 of the 1996 Safe Drinking Water Act (SDWA), as amended in 1996, requires all States to
complete assessments of their public drinking water supplies. By 2003, each State and participating
Tribe must delineate the boundaries of areas in the State (or on Tribal lands) that supply water for each
public drinking water system; identify significant potential sources of contamination; and determine each
system's susceptibility to sources of contamination. The assessments will synthesize existing
information about the sources of drinking water supplies in order to provide a national baseline of the
potential contaminant threats and to guide future watershed restoration and protection.
The assessment of drinking water sources is only one part of protecting underground drinking water
sources.84 The Wellhead Protection Program, which was established under the 1986 SDWA
amendments, goes beyond assessment to add additional requirements for prevention within wellhead
protection areas, and to establish contingency plans in the case of a release. Wellhead protection
programs are currently in place in 49 States and territories. Over 125,000 public drinking water systems
have community-level wellhead protection measures in place or under development.
To further identify those areas that may be impacted by MTBE and other contaminants associated with
gasoline, EPA is reviewing all State assessment program submittals to ensure that each program
inventories gasoline service stations, marinas, USTs, and gasoline pipelines in drinking water source
83 California State Water Resources Control Board, "Are Leak Detection Methods Effective In Finding Leaks
In Underground Storage Tank Systems? (Leaking Site Survey Report)" January 1998.
Http ://www. swrcb. ca.gov/~c wphome/ust/leak_reports/Index. htm.
84 U. S. Environmental Protection Agency, Office of Water, State Source Water Assessment and Protection
Programs Guidance, EPA 816-F-97-004, August 1997, www.epa.gov/OGWDW/swp/fs-swpg.html.
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protection areas. This will provide an opportunity to collect locational data for water sources and
contaminant sites as part of the State Source Water Assessment Programs. Here, the challenge will be
threefold: (1) to collect information useful to multiple stakeholders; (2) to maintain, update, and improve
the data over time; and (3) most importantly, to make this information easily accessible among agencies
The U.S. Environmental Protection Agency is also revising its current Unregulated Contaminant
Monitoring Rule. The revised rule, scheduled to take effect in January 2001, will require large water
systems (serving more than 10,000 persons) and a representative sampling of small and medium-sized
water systems (serving fewer than 10,000 persons) to monitor and report MTBE detections, a procedure
that should not add substantially to monitoring costs due to the inclusion of MTBE analysis within
analytical tests used for monitoring of other VOCs. Although this will substantially increase the
monitoring for MTBE, under this regulation, the majority of public groundwater supply wells will still
not be monitored for MTBE. For example, if this regulation were to be enacted today, in California,
MTBE monitoring and reporting would be required for all 3,094 active wells (within water systems
serving more than 10,000 persons) and a representative sample of the other 7,160 active wells (within
water systems serving fewer than 10,000 persons), resulting in fewer than half of the total number of
active wells being monitored.
B. State Efforts
Under California legislation enacted in 1997, the State Water Resources Control Board (SWRCB) is
required to implement a statewide GIS to manage the risk of MTBE contamination to public ground
water supplies. In the short-term (by July 1999), this project seeks (1) to identify all underground storage
tanks and all known releases of motor vehicle fuel from underground storage tanks that are within 1,000
feet of a drinking water well; and (2) to identify public wells within 1,000 feet of a petroleum product
pipeline.85
This GIS displays and reports detailed information for both tank release sites and drinking water sources.
Most importantly, the system streamlines the integration of data from multiple agencies, i.e., the system
integrates data for both contaminant sites and drinking water sources. This GIS will be used by a variety
of State agencies to better protect public drinking water wells and aquifers reasonably expected to be
used as drinking water from both motor vehicle fuel sources, including underground storage tanks
(operating sites and closed sites with existing contamination), and petroleum pipelines. Public access via
the Internet will serve to overcome current limitations on obtaining and sharing data among multiple
regulatory agencies, water purveyors, the petroleum industry, and other stakeholders. Furthermore, the
system gives all stakeholders access to on-line data analysis tools that can be used to estimate
vulnerability.
Other States are also developing and implementing GIS capabilities, although not as comprehensively as
California's program.
85 The GeoTracker report was a pilot study that addressed the Santa Clara Valley and Santa Monica water
districts - not the entire state. However, the GeoTracker approach is expected to be used to get information for the
rest of the state compiled. For more information about this GIS, refer to http://geotracker.llnl.gov/.
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VI. Treatment of Impacted Drinking Water86
When drinking water supplies become contaminated with MTBE, water suppliers must take steps to treat
the water so as to restore it to potable condition. The MTBE Research Partnership, which includes the
Association of California Water Agencies, the Western States Petroleum Association (WSPA), and the
Oxygenated Fuels Association (OFA), recently published Treatment Technologies For Removal of MTBE
From Drinking Water, a report reviewing and analyzing the costs of three water treatment technologies:
air stripping; activated carbon; and advanced oxidation.
Treatment of extracted air and water effluents is typically accomplished using air stripping, a
process in which contaminated water flows down a column filled with packing material while
upward-flowing air volatilizes the contaminant from the water. Although highly effective for
benzene, it is less effective and somewhat more costly for MTBE (e.g., 95 percent and higher
removal efficiency for benzene vs. 90 percent and higher for MTBE). Commonly, air stripped
effluent is "polished" to lower contaminant levels by subsequent treatment with activated carbon.
Activated carbon, or carbon adsorption, is also widely employed to remove low levels of organic
compounds from water by pumping it through a bed of activated carbon. Additionally, many
individual homeowners use small carbon canisters to remove a variety of contaminants, including
MTBE, from impacted private wells. Again, this process is highly effective for benzene, but
much less so for MTBE, which requires greater volumes of carbon per unit mass of MTBE
removed, and thus is significantly more expensive and less effective than benzene removal.
Advanced oxidation technologies use appropriate combinations of ultraviolet light, chemical
oxidants, and catalysts to transform contaminants. Oxidation technologies have been
demonstrated to oxidize a wide range of organic chemicals, including MTBE. These same
technologies, especially air stripping and granular activated carbon (GAC), have been employed
successfully for use at individual homes with impacted drinking water wells.87
The costs associated with these types of treatment for drinking water are summarized in Figure 1.
86 This discussion refers specifically to the treatment of ground waters or surface waters intended for
distribution to consumers or to private well owners; remediation of ground water associated with contaminant sites
is addressed in the following section.
87 J.P. Malley, Jr., P. A. Eliason, and J.L. Wagler, "Point-of-Entry Treatment of Petroleum Contaminated Water
Supplies," Water Environment Research, 1993, v. 65, no. 2, pp. 119-128.
50
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Figure 1
Annual MTBE Treatment Costs for a Family of Four
$400
re $350
£
Jj $300
Q.
^ $250
E
£ $200
a)
$150
o $100
$50
0
60 gpm
600 gpm
6,000 gpm
$391
86
$50
$42
Source: MTBE
Research
Partnership
$244
Air
Stripping
Ozone/
Hydrogen Peroxide
Granular
Activated Carbon
Source: MTBE Research Partnership (Western States Petroleum Association, Association of California
Water Agencies, and Oxygenated Fuels Association), Treatment Technologies for Removal of Methyl
Tertiary Butyl Ether (MTBE) from Drinking Water Air Stripping, Advanced Oxidation Process (AOP),
and Granular Activated Carbon (GAC), Executive Summary, Sacramento, CA, December 1998.
Tertiary butyl alcohol (TEA) is another oxygenate that has been found at oxygenated gasoline release
sites. Because TEA is a byproduct of some MTBE production processes, TEA is found in some fuel-
grade MTBE.88 TEA is also a metabolite of the biodegradation of MTBE.89 Because TEA is infinitely
soluble in water, use of air stripping and activated carbon treatment methods are even more limited than
for treatment of MTBE. TBA's treatment by advanced oxidation may generate compounds potentially of
health and environmental concern. The presence of TEA will further limit the usefulness of the above
described technologies and increase treatment costs.
88 National Toxicology Program, Summary of Data For Chemical Selection: Methyl Tert-Butyl Ether,
http://ntp-db.niehs.nih.gov/NTP_Reports/NTP_Chem_H&S/NTP_MSDS/HS_1634-04-4.txt
89 J.P. Salanitro et al., "Perspectives on MTBE Biodegradation and the Potential for in situ Aquifer
Bioremediation," proceedings of the National Ground Water Association's Southwest Focused Ground Water
Conference: Discussing the Issue of MTBE and Perchlorate in Ground Water (Anaheim, CA, June 3-4, 1998), pp.
40-54.
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VII. Remediation
A. MTBE
1. Risk Based Corrective Action
The following discussion focuses on the remediation of UST releases, as they are the predominant source
of higher levels of MTBE contamination and potential drinking water supply impacts. Releases from
other point sources of gasoline (e.g., ASTs and pipelines), however, would be managed in a similar
fashion.
Regulatory policies have evolved during the last decade toward the increasing use of risk-based
corrective action (RBCA) programs. These programs serve as a means through which the management
of petroleum releases is prioritized so that time and resources can be directed to those sites most likely to
impact public or environmental health and safety. These changes in policies and practices are the result
of conclusive demonstrations of existing and innovative technologies' limits in achieving complete
remediation of impacted ground water systems.90 The complex properties and interactions of gasoline
and hydrogeologic systems have been found to be substantial barriers to the effective removal of motor
fuel hydrocarbon masses released to ground water. The ascendancy of RBCA programs paralleled and
was assisted by an increased understanding of the role of natural attenuation and intrinsic bioremediation
in limiting the migration of dissolved hydrocarbon plumes. As a result, corrective action for many sites
now focuses first on removing any readily mobile hydrocarbon mass at the source, and then on managing
the dissolved plume using intrinsic bioremediation. Because MTBE is generally recalcitrant, the
presence of MTBE is expected to limit the utilization of intrinsic bioremediation as a remediation option.
Although other natural attenuation processes may be used as deemed appropriate.
The American Society for Testing and Material's (ASTM) E 1739-95 Standard Guide for Risk Based
Corrective Action, developed during the early 1990's, forms the basis for most State risk-based programs.
This RBCA guidance focuses on setting remedial goals based on health risks. MTBE also presents
aesthetic (/'. e., taste and odor) problems at relatively low levels, which is currently not addressed by
ASTM RBCA. Alternative RBCA guidance would need to be developed to adequately address aesthetic
concerns.
Methyl tertiary butyl ether is included in this guide as a compound of concern when evaluating impacts
from gasoline releases. The use of a risk-based framework places the emphasis on decisions that balance
cost, resource value, and risk to human health and the environment. Risk-based approaches seek to
implement management strategies that shift the focus of cleanup away from broadly defined cleanup
goals, which have been demonstrated to be technologically infeasible, and instead focus on a more
site-specific elimination or reduction of risk. It should be noted, however, that RBCA focuses on health
risks, and because MTBE has also been shown to present aesthetic (i.e., taste and odor) problems at
relatively low levels, alternative RBCA guidance may need to be developed to adequately address those
types of environmental concerns.
90 U.S. Environmental Protection Agency, Office of Research and Development, Pump-and-Treat Ground-
Water Remediation: A Guide for Decision Makers and Practitioners, EPA/625/R-95/005, 1996.
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During the last several years, it has become an accepted practice at UST release sites to carefully
evaluate the potential for intrinsic remediation (i.e., bioremediation of the contaminant primarily by the
microbial population naturally present in the subsurface), and then to determine whether there is a need
for active remediation. The presence of MTBE can complicate the utilization of intrinsic remediation, as
although the BTEX91 plume may be shown to be contained satisfactorily, adequately demonstrating
stability and/or containment of an MTBE plume may be much more difficult. Methyl tertiary butyl ether
is generally recalcitrant, and therefore intrinsic remediation will typically not be a feasible option.
Source control (i.e., removal of contaminant mass near the source of the release) is frequently employed
to reduce long-term impacts to ground water and drinking water in situations where intrinsic remediation
is not viable. After a release, non-aqueous phase liquid (NAPL) is likely to be present in the vadose
zone, capillary fringe, and ground water. The NAPL (e.g., gasoline) will act as a long-term source of
dissolved contaminants. Where practical, delineation and removal of NAPL are critical for complete
restoration of an impacted aquifer.92 In areas with shallow ground water, excavation of the NAPL-
contaminated source area (down to and below the water table) can be an effective remediation approach.
This technique is less effective at sites with extensive areal contamination, subsurface structures, or
deeper water tables. The excavation and disposal of large volumes of contaminated soil or aquifer
sediments have also been discouraged at many sites, in part because of limited solid waste treatment and
disposal facilities.
2. Conventional and Innovative Technologies
Although the conventional and innovative technologies used for ground water remediation of
nonoxygenated gasoline releases are also applicable for MTBE remediation, their relative effectiveness
and costs may vary depending on site-specific conditions.93 A remediation system typically employs air-
or water-based approaches for removing contaminants from the subsurface, and one or more treatment
technologies for removing the contaminant from those aqueous or vapor phase effluents. Alternatively,
in-situ techniques can be used to treat or destroy contaminants without bringing them above the surface.
The applications of these technologies for MTBE and benzene are briefly compared below.
Pump and treat is a mature, well-understood technology that pumps ground water
to the surface for subsequent treatment and discharge. Because of the relatively
low solubility of benzene, this technique is more effective as a benzene plume
migration control technology than for mass removal. MTBE's high solubility
and low soil sorption should enable MTBE to be more readily extracted from an
aquifer than benzene. As with all pump and treat, the effluent will have to be
treated with technologies such as air stripping, advanced oxidation, GAC, or
bioreactor.
91 The compounds benzene, toluene, ethyl benzene, and xylene are commonly known as "BTEX."
92 U.S. Environmental Protection Agency, Office of Research and Development and Office of Solid Waste &
Emergency Response, Light Nonaqueous Phase Liquids, EPA Ground Water Issue Paper # EPA/540/S-95/500,
1995.
93 Daniel N. Creek and J. Davidson, "The Performance and Cost of MTBE Remediation," National Ground
Water Association, 1998 Petroleum Hydrocarbons and Organic Chemicals in Ground Water, pp. 560-569;
Tom Peagrin, "Empirical Study of MTBE Benzene and Xylene Groundwater Remediation Rates," National
Ground Water Association, 1998 Petroleum Hydrocarbons and Organic Chemicals in Ground Water, pp.551-559.
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Soil vapor extraction (SVE) pulls air through the soil to volatilize contaminants.
Because MTBE does not adsorb strongly to soils and has a higher vapor pressure
than benzene, MTBE will readily volatilize from gasoline in soils. When MTBE
is dissolved in soil moisture, however, SVE will not remove MTBE, which is
highly soluble.
Air sparging injects air below the water table to volatilize contaminants from
ground water. Compared with BTEX, a much larger flow of air is required to
volatilize a similar mass of MTBE. This addition of air/oxygen also enhances
biodegradation of contaminants that are aerobically degraded by native
microorganisms. Although air sparging will readily enhance the biodegradation
of benzene, studies to date have shown MTBE to be relatively recalcitrant to
biodegradation by native populations of microbes in the subsurface. Therefore,
although air sparging is known to be an effective technology for remediating
benzene (increases volatilization and biodegradation), it is expected to be less
effective and more costly for MTBE remediation (i.e., dissolved phase does not
volatilize and may be relatively recalcitrant to native biodegradation). Air
sparging is frequently teamed with SVE to capture the volatilized compounds.
Dual phase extraction involves vapor extraction and ground water extraction in
the same well. This technique is likely to be most effective in situations in
which the water table can be lowered, allowing for a larger area of influence for
the vapor extraction system. As discussed above, when MTBE is dissolved in
soil moisture, vapor extraction will not effectively remove MTBE, which is
highly soluble. Therefore, this technique is most effective for volatilizing
MTBE from gasoline.
Bioremediation of MTBE contamination is an increasingly active area of
research. The biodegradability of MTBE is considered to be much slower
relative to the abundant natural bioremediation of other gasoline constituents in
the subsurface (e.g., benzene), and MTBE generally has been recalcitrant or
limited relative to benzene biodegradation in field samples, although there is
some field evidence to the contrary.94 Recent lab and field studies have
94 R.C. Borden et al, "Intrinsic Biodegradation of MTBE and BTEX in a Gasoline-Contaminated Aquifer,"
Water Resources Research, 1997, v. 33, no. 5, pp. 1105-1115; A..M. Happel, B. Dooher, andE.H. Beckenbach,
"Methyl Tertiary Butyl Ether (MTBE) Impacts to California Groundwater," presentation at MTBE Blue Ribbon
Panel meeting (March 1999); A.M. Happel et al., Lawrence Livermore National Laboratory. An Evaluation of
MTBE Impacts to California Groundwater Resources, UCRL-AR-130897, p.68 (June 1998); J.E. Landmeyer et al.,
"Fate of MTBE Relative to Benzene in a Gasoline-Contaminated Aquifer (1993-98)," Ground Water Monitoring &
Remediation, Fall 1998, pp.93-102; Mario Schirmer and J.F. Barker, "A Study of Long-Term MTBE Attenuation in
the Borden Aquifer, Ontario, Canada," Ground Water Monitoring & Remediation, Spring 1998, pp. 113-122; Reid,
J.B., et al., "A Comparative Assessment of the Long-Term Behavior of MTBE and Benzene Plumes in Florida," pp.
97-102 Natural Attenuation of Chlorinated Solvents, Petroleum Hydrocarbon and Other Organic Compounds
(1999); Hurt, K.L., et. al., "Anaerobic Biodegradation of MTBE in a Contaminated Aquifer..," pp. 103-108, Natural
Attenuation of Chlorinated Solvents, Petroleum Hydrocarbon and Other Organic Compounds (1999); Bradley,
P.M., et.al., Aerobic Mineralization of MTBE and tert-Butyl Alcohol by Stream-bed Sediment Microorganisms:
(continued...)
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indicated that biodegradation processes can be accelerated by augmenting the
subsurface environment or microbial population (e.g., by the addition of oxygen,
microbes, nutrients, or hydrocarbons that stimulate MTBE cometabolism).
In-situ oxidation relies on the capacity of certain chemical mixtures (e.g.,
hydrogen peroxide combined with iron) to rapidly oxidize organic molecules
such as MTBE in water. Because MTBE oxidizes rapidly, it will be removed
during the course of routine water treatment by this technique. Although current
use of this technology is limited, when subsurface conditions and contaminant
distribution are favorable, it has been demonstrated to effectively remove both
MTBE and conventional gasoline components.
3. Treatment of Remediation Effluent
Treatment of the air and water effluents extracted from the above processes is typically accomplished
using the same processes described previously for drinking water treatment (air stripping, activated
carbon, and oxidation). Again, these processes are highly effective for benzene, but less so for MTBE.
The costs associated with the treatment of effluents with MTBE are thus likely to be somewhat higher
than for BTEX.95 Catalytic or thermal oxidation technologies are also commonly used for air phase
effluents, and MTBE again poses a more difficult and costly problem than benzene. Fluidized
bioreactors are less commonly employed, as they require somewhat more complex operation and
maintenance. They typically use activated carbon to support microbial growth so that contaminants are
adsorbed onto the carbon and destroyed by resident microbes as the contaminants pass through the unit.
This technology is somewhat more elaborate than air stripping and carbon adsorption, but may grow in
acceptability if reliable MTBE treatment can be documented. In general, MTBE-BTEX effluents will be
more costly to treat and discharge than BTEX alone. Synthetic Resin Adsorbents, which exhibit a much
higher adsorbent capacity for MTBE relative to activated carbon, are currently available. With additional
research, they may become a viable cost effective treatment.
4. Incremental Costs for MTBE Remediation
A certain level of remediation activity/corrective action is required for almost every release of gasoline,
with or without oxygenates. Evaluation of the incremental remediation costs of MTBE contamination is
a difficult task because of the numerous site-specific variables to address. Four key variables include (1)
the cleanup target established for the site; (2) allowable MTBE discharge levels in the water and vapor
effluents generated during the remediation process;96 (3) the size of the dissolved plume; and (4) the
potential for using natural attenuation as the treatment technology.
94 (...continued)
Envtl. Sci. Tech., v. 33 no. 11, pp. 1877-1897 (1999).
95 Depending on the precise circumstances, these costs can range from moderately higher than BTEX-related
costs to significantly higher.
96 These levels are addressed in the permits issued by the appropriate regulatory authorities for these
discharges.
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Clearly, it will be more expensive to reach an MTBE ground water cleanup goal of 15 ppb than a goal of
40 ppb or higher. Similarly, the related effluent treatment costs will be much higher if permitted water
discharge levels are 35 ppb as opposed to 500 ppb, and daily volatile organic compounds (VOC)
discharges to the atmosphere are limited to 2 pounds compared with 50 pounds. As there are no national
standards for MTBE, it is not possible to estimate these incremental costs.
The U.S. Environmental Protection Agency has surveyed UST program managers to obtain some initial
estimate of increases in remediation cost.97 Although the survey data have a high degree of uncertainty
and should be viewed as preliminary, the EPA survey estimated that perhaps 75 percent of MTBE-
impacted UST sites would have remediation costs less than 150 percent of the cost of typical BTEX sites,
and that many MTBE sites might have no additional cost. The Leaking Underground Storage Tank
(LUST) program managers estimated that the remaining 25 percent of sites would cost greater than 150
percent of representative BTEX sites, with perhaps 5 percent costing in excess of 200 percent more than
typical BTEX sites. The UC study, Health and Environmental Assessment of MTBE, evaluated costs of
remediation of MTBE sites in California based on industry, regulatory data and studies of MTBE impacts
to groundwater in California. Overall, this study concluded that on average MTBE contaminated sites
may be 140 percent of the cost of remediating conventional gasoline sites.98
Remediating MTBE plumes can be roughly comparable to the cost of conventional BTEX treatment for
equivalent plume sizes, assuming the permitted MTBE effluent treatment and discharge levels allow
standard air stripping and carbon adsorption approaches to be used. However, because an MTBE plume
is more likely to become larger than typical benzene plumes when release detection is delayed, if
dissolved MTBE source zone concentrations are much higher than BTEX (as they might be from a
release of an RFG), or if stringent MTBE effluent discharge levels are applied, remediation costs are
expected to increase proportionately. Absent active remediation or sufficient intrinsic bioremediation to
prevent further migration, MTBE plumes are expected to extend further, perhaps by a large extent, than
the companion benzene plumes.
This potential difference between benzene and MTBE plume lengths may influence remediation costs in
another way. Monitored natural attenuation (MNA) is a widely accepted, cost effective approach to
managing benzene plumes.99 If MTBE plumes are expected to migrate further because of higher source
area dissolved concentrations and exhibit limited biodegradation as compared to benzene, then fewer
sites may be able to use MNA as an acceptable remediation option (/'. e., active remediation would be
required, thus increasing cleanup costs). Only a limited number of field studies have been conducted to
97 Robert Hitzig, Paul Kostecki, and Denise Leonard, "Study Reports LUST Programs are Feeling Effects of
MTBE Releases," Soil & Groundwater Cleanup, August-September 1998, pp. 15-19.
98 The UC Study, Health and Environmental Assessment of MTBE, evaluated costs of remediation of MTBE
sites in California based on industry, regulatory data and studies of MTBE impacts to groundwater in California.
Overall, this study concluded that on average MTBE contaminated sites may be 1.4 times more costly to remediate
than conventional gasoline sites.
99 U.S. Environmental Protection Agency, Draft Memorandum from Timothy Fields, Jr., Acting Assistant
Administrator, Office of Solid Waste and Emergency Response, "Use of Monitored Natural Attenuation at
Superfund, RCRA Corrective Action, and Underground Storage Tank Sites," June 9, 1997.
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evaluate MTBE natural attenuation;100 thus, it is difficult to assess fully the potential future costs. A
recent study estimated that while over 80 percent of non-MTBE conventional gasoline sites might utilize
MNA, few MTBE sites would be able to, resulting in substantially higher cleanup costs for MTBE
sites.101
B. Ethanol
The above discussions are focused on remediation issues identified for MTBE. It is difficult to make a
comparative assessment of MTBE versus ethanol gasoline releases, as there is relatively little field data
characterizing the behavior of ethanol gasoline releases.102 Monitoring for ethanol is not required at UST
sites, even in Midwestern States that use large volumes of ethanol. Additionally, standard EPA methods
used to analyze fuel hydrocarbon compounds are not technically appropriate for detection and
quantification of ethanol below the 1 part per million (ppm) to 10 ppm range. Ethanol is known to be
much more biodegradable than benzene. Although ethanol is likely to biodegrade rapidly in ground
water, because ethanol is infinitely soluble in water, much more ethanol will be dissolved into water than
MTBE. It is not known how long it may take to biodegrade large amounts of dissolved ethanol.
Laboratory research suggests that microorganisms prefer to biodegrade ethanol over other fuel
components, so that ethanol biodegradation consumes all available oxygen and depletes other electron
acceptors needed for biodegradation, thus delaying the onset, and potentially slowing the rate, of BTEX
biodegradation. Although the magnitude of this effect is presently unknown, it is expected to result in
somewhat longer BTEX plumes at gasoline release sites.103 Because ethanol is most commonly blended
at distribution terminals, releases of neat (pure) ethanol may occur at those facilities, requiring
remediation. The extent of any current possible problem and cost associated with such clean up is
unknown.
C. Funding
100 R.C. Borden et al., "Intrinsic Biodegradation of MTBE and BTEX in a Gasoline-Contaminated Aquifer,"
Water Resources Research, 1997, v. 33, no. 5, pp. 1105-1115; J.E. Landmeyer et al., "Fate of MTBE Relative to
Benzene in a Gasoline-Contaminated Aquifer (1993-98)," Ground Water Monitoring & Remediation, Fall 1998,
pp.93-102; Mario Schirmer and J.F. Barker, "A Study of Long-Term MTBE Attenuation in the Borden Aquifer,
Ontario, Canada," Ground Water Monitoring & Remediation, Spring 1998, pp. 113-122.
101 Arturo Keller, Ph.D., et.al., Executive Summary, Recommendations, Summary, "Health and Environmental
Assessment of MTBE" 1999.
102 Malcome Pirnie, Inc., Evaluation of the Fate and Transport of Ethanol in the Environment, (Oakland, CA:
Malcome Pirnie, Inc.), 1998; H.X., Corseuil et al., "The Influence of the Gasoline Oxygenate Ethanol on Aerobic
and Anaerobic BTX Biodegradation," Wat. Res., 1998, 32, 2065-2072.; C.S. Hunt et al., "Effect of Ethanol on
Aerobic BTX Degradation Papers from the Fourth International In Situ and On-Site Bioremediation Symposium,"
Battelle Press, April-May 1997, pp. 49-54.
103 Michael Kavanaugh and Andrew Stocking, "Fate and Transport of Ethanol in the Environment,"
presentation at the May 1999 MTBE Blue Ribbon Panel meeting. [Based on Malcome Pirnie, Inc. Evaluation of
the Fate and Transport of Ethanol in the Environment (Oakland, CA, 1998.)]
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1. State and Federal Sources104
The primary sources of funding for UST remediation are State UST cleanup funds.105 State cleanup
funds raise and expend about $1 billion annually, by far the largest source of funding available to pay for
remediation of MTBE-contaminated soil and ground water. The second largest source of funding is
private insurance. Most owners and operators have the required financial assurance coverage provided
by State funds. Owners and operators in States without State funds, or in those States in which State
funds are transitioning and not providing coverage for new releases, must meet their UST financial
responsibility requirements by other mechanisms, most commonly UST insurance provided by private
insurers. According to the insurance industry, roughly 10 percent to 15 percent of USTs are currently
covered by private insurance. This percentage is likely to increase as more States transition out of their
UST cleanup funds.
The Federal LUST Trust Fund is supported through a 0.1 cent per gallon Federal tax on motor fuels that
expires after March 30, 2005. At the end of fiscal year (FY) 1998, the Trust Fund had a balance of
approximately $1.2 billion. In FY 1998, the Fund received approximately $203 million in new monies -
$136 million from the Federal tax and $67 million in interest on the Fund's balance. In FY 1999, new
receipts are expected to increase to $278 million ($212 million from the tax and $66 million in interest),
raising the Fund's balance to approximately $1.4 billion (after FY 1999 appropriations).106 Monies in
this fund are subject to appropriation, and Congress has been appropriating approximately $70 million
annually in recent years.107 Approximately 85 percent of the appropriated funds are given to the States to
administer and enforce their LUST programs and to pay for remediation of eligible releases. The States
use approximately two-thirds of the funds to support staff who oversee and enforce cleanups by
responsible parties. Approximately one-third of the funds are used to pay for cleanups in which the
owner and operator are unknown, unwilling, or financially unable to undertake and to complete cleanup
104 See EPA OUST's Publication on Sources of Financial Assistance for Underground Storage Tank Work.
The document entitled "Financing Underground Storage Tank Work: Federal and State Assistance Programs" lists
Federal and State programs that provide money to assist in upgrading or replacing underground storage tanks,
conducting investigations, and performing remediation. This document provides information on financial assistance
available to municipalities, State or local governments, non-profits, private UST owners or operators, and for tanks
on Native American or tribal lands. The assistance is available in the form of direct loans, loan guarantees, grants,
or interest subsidies. The publication also describes some of the available State financial assistance programs.
Eighteen States have active financial assistance programs for UST upgrades and replacement; some of these
programs also offer assistance cleaning up UST releases. Also, see the ASTSWMO Report, "State Leaking
Underground Storage Tank Financial Assurance Funds Annual Survey Summary," June 1998.
Http://www.astswmo.org/Publications/pdf/98vtsum.pdf.
105 U.S. Environmental Protection Agency, State Assurance Funds: State Funds in Transition Models for
Underground Storage Tank Assurance Funds, 1997, EPA 510-B-97-002,
www.epa.gov/swerustl/states/fundinfo.htm..
106 Executive Office of the President of the United States, Budget of the United States Government, Fiscal
Year 2000 - Appendix, 1999, p. 937.
107 Fiscal year 1998 (actual) and 1999 (estimated) appropriations from the LUST Trust Fund were $65 million
and $73 million, respectively. (See Executive Office of the President of the United States, Budget of the United
States Government, Fiscal Year 2000 - Appendix, 1999, p. 937.)
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of a contaminated site.108 The law establishing the LUST Trust Fund places clear responsibility for
remediation on owners and operators and places significant eligibility requirements on the use of LUST
Funds for actual cleanup of contaminated sites.
2. Recovery of Funds from Potentially Responsible Parties
Water suppliers can face substantial expenditures for either replacement water supplies or treatment of
contaminated waters. For example, the City of Santa Monica lost 50 percent of its existing water supply
in 1996 as the result of MTBE impacts. The annual costs of the required volume of replacement water
(more than 6 million gallons per day) are estimated at approximately $4 million. Although these costs
are the full responsibility of the party shown to be liable for the contamination, establishing such liability
may take months or years. It has been suggested that a funding mechanism should exist for covering
these unexpected costs.
3. State Water Supply Revolving Funds
Other potential funding sources for addressing MTBE contamination are the Clean Water State
Revolving Fund (CWSRF) and Drinking Water State Revolving Fund (DWSRF) programs. These
programs were established to provide States with a continuing source of funding to address (1)
wastewater treatment, nonpoint source, and estuary activities (CWSRF); and (2) drinking water
treatment, source water protection, and water system management activities (DWSRF). Funding
decisions for projects and activities are made by each State, pursuant to eligibility guidelines provided by
EPA.
The CWSRF can be used for site mitigation efforts to address MTBE releases to the extent that such
activities are included in an EPA-approved State nonpoint source management program. To date, three
States (Delaware, Nebraska, and Wyoming) have provided a total of approximately $48 million in
CWSRF loans to about 1,200 sites for removing underground tanks and purchasing release detection
systems. In these three States, the CWSRF program works in partnership with the State's Leaking
Underground Storage Loan Program to provide technical assistance and funding support to potential loan
recipients. Funds available to address problems related to MTBE may increase as States expand use of
their CWSRF programs to address nonpoint source problems.
Although the DWSRF cannot be used to fund remediation efforts, States can loan DWSRF monies to
public water systems for the installation of treatment equipment to address contaminated source water
entering the treatment plant. In addition to providing loan assistance to public water systems for eligible
projects, the DWSRF also allows each State to reserve up to 31 percent of its grant to fund programs and
activities that enhance source water protection and water systems management. Several of the activities
eligible under the reserves could address protection and management issues associated with MTBE.
108 If the owner or operator is financially able, but otherwise unwilling to cleanup the site, the implementing
agency is responsible for recovering the costs of remediating the site.
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4. Alternative Water Supply Funding Mechanism
The above discussion has reviewed a variety of existing potential sources of funds available to replace or
treat public and private water systems. Should these sources not meet existing needs adequately, an
alternative funding approach may be required. To simultaneously provide a source of funding for
emergency alternative supplies and treatment of impacted public water systems, and to act as a gradual
disincentive for use of MTBE, a tax/surcharge could be levied on MTBE production for use in gasoline.
These levied monies could then be made readily accessible by public and private water suppliers to
reimburse incurred expenses associated with addressing MTBE contamination incidents. The economic
viability and amount of this surcharge would need to be determined, but would likely range from 5
percent to 50 percent of the price of each gallon of MTBE sold. For example, a 10 percent surcharge
with an MTBE price of $0.70 per gallon and RFG with 11 percent by volume MTBE would add about 1
cent to the per gallon-price of RFG and would accumulate about $300 million annually with current
MTBE usage. This surtax could also be structured to increase over time to further discourage MTBE
use.
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D. Fuel Supply and Cost
I. Introduction
The current U.S. fuel supply system is a finely balanced network that depends on crude oil supply,
refinery production, unimpeded pipeline and marine movements, and strategically sited commercial
stocks to protect against market volatility. Recent accident- and weather-related refinery and pipeline
outages (e.g., incidents in California and Washington State) demonstrate the system's delicate nature.
As such, changes in fuel regulatory requirements, with their attendant capital investment needs and
infrastructure changes, must be implemented without introducing unnecessary volatility. Disruptions to
the nation's fuel supply system result in price volatility and increased costs to consumers. Therefore, any
proposed changes to U.S. fuel requirements should consider the following:
The time required to implement capital investments in both refineries and infrastructure,
which entails raising capital, obtaining permits, and constructing units and
infrastructure.109
The need for regulatory certainty to provide industry with sufficient lead time to make all
necessary changes. Regulatory uncertainty increases investment risks and forces
industry to postpone investments to the last minute.
The need for regulatory flexibility in achieving targeted goals. The petroleum industry is
diverse, and what is optimal for one sector may not be optimal for another.
The need for fungibility in the system. At present, the U.S. fuel supply system works
well, as most requirements tend to be national (e.g., low sulfur on-road diesel) or
regional (e.g., reformulated gasoline or California reformulated gasoline). Once small
areas begin requiring unique fuels, however, the system operates at sub-optimal
efficiency, costs to consumers increase, and fuel supplies are more vulnerable to
volatility.
This combination of sufficient time, regulatory certainty and flexibility, and fungibility will facilitate a
smooth transition, thus avoiding excessive cost increases driven by unnecessary stress to the system.
An important consideration in this discussion is the regulatory status of methyl tertiary butyl ether
(MTBE). If the use of MTBE (and other ethers) is reduced substantially or phased out, but the oxygenate
requirement is maintained, ethanol (and possibly other alcohols) will remain as the only alternatives. At
present, however, ethanol is produced primarily in the Midwest and is not manufactured in sufficient
volume to meet national demand. Although new ethanol production capacity can be brought on-line in
two years, the permitting and construction of necessary infrastructure will be a critical determinant of
ethanol's availability and cost.
109 Moreover, if all refineries and terminals require capital upgrades, the construction industry may become
strained.
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II. Industry Overview
A. Consumption
1. Consumption of Gasoline and Oxygenates
Current consumption of gasoline in the United States is approximately 8.3 million barrels per day (b/d),
or approximately 126.5 billion gallons annually.110 Based on Federal fuel supply data, total U.S.
oxygenate demand was approximately 370,000 b/d in 1997 (refer to Table Dl in this section's
Appendix).111 Excluding the volume of oxygenate used only for octane purposes, the average 1997
demand for oxygenates in reformulated gasoline (RFG) and oxygenated gasoline in environmental
control areas was approximately 265,000 b/d, 41,000 b/d, and 17,000 b/d per day for MTBE, ethanol, and
other ethers, respectively. Thus, although making up less than 5 percent of total national gasoline
consumption, MTBE and other ethers met approximately 87 percent of the oxygenate volume
requirement in 1997.
2. Meeting California's Ethanol Demand
A recent study funded by the Renewable Fuels Association (RFA), The Use of Ethanol in California
Clean Burning Gasoline, estimates that if MTBE was banned, California would demand 41,000 b/d of
ethanol in order to meet the oxygenate volume in the mandated areas plus 30 percent penetration into the
non-mandated areas. A study by the California Energy Commission (CEC), however estimates 75,000
b/d in demand for similar requirements.112 According to the RFA report, California's demand could be
met from currently underutilized production, which equates to 29,000 b/d with 100 percent utilization,
and new plant start-ups. The balance would be made up by ethanol redirected from the octane
enhancement markets and increased imports.113
110 U.S. Energy Information Administration, Petroleum Supply Annual 1998, Volume I, Table S4, p. 17, June
1999.
111 U.S. Energy Information Administration (T. Litterdale and A. Bonn), Demand and Price Outlook for
Phase 2 Reformulated Gasoline, 2000, April 1999, pp. 7-8.
112 California Energy Commission, Supply and Cost Alternatives to MTBE in Gasoline, October 1998.
113 Downstream Alternatives, Ethanol Supply, Demand, and Logistics: California and Other RFG Markets,
May 1999.
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B. Ethanol Production
Current U.S. ethanol production capacity is estimated at 120,000 b/d114, which is equivalent in oxygen
content to approximately 230,000 b/d of MTBE. In order for ethanol alone to fulfill the nationwide
oxygen requirement in all RFG and oxygenated fuels areas, the U.S. Environmental Protection Agency
(EPA) estimates that approximately 187,000 b/d of ethanol would be needed, assuming that no ethanol is
used for economic octane blending.115 Thus, in a scenario of complete MTBE removal, an estimated
additional 67,000 b/d of ethanol would be needed to fulfill the required oxygenate volume nationwide.
Ethanol supply could be fulfilled by a combination of imports and additional production capacity created
by removing bottlenecks at existing plants and by building new facilities. The ethanol industry estimates
that the current expansion of existing ethanol-from-corn production facilities may increase production
capacity by as much as 40,000 b/d. Additionally, new ethanol production facilities currently being
planned could provide another 25,000 b/d (new ethanol plants may take two or more years to build).116
The U.S. Department of Agriculture (USDA) estimates that 5 percent of the total corn utilized in 1997-98
was for fuel ethanol production.117
Ethanol production from biomass processing is currently about 60 million gallons per year (equivalent to
approximately 4,000 b/d). Estimates from the USDA indicate that assuming favorable economics, the
resource base for ethanol from biomass could reach approximately 10 billion gallons annually
(approximately 650,000 b/d) after 2025.11S Recently, on August 12, 1999, President Clinton issued an
executive order to initiate a government effort to develop a biomass research program. The goal of the
program is to triple the use of bioenergy and bioproducts by 2010, which includes the production of clean
fuels such as ethanol and other products.
Based on total gasoline regulated properties, ethanol used at 5.7 percent by volume to meet the 2.0
percent by weight (wt.%) oxygen requirement in RFG will not be able to replace all of the 11 percent by
volume of MTBE in RFG. In California, some refiners have stated that they must remove some volume
of butanes/pentanes from California Phase 2 RFG in order to accommodate the increase in gasoline's
Reid vapor pressure (RVP) with the addition of ethanol, and thus must significantly expand their crude
114 Roger Conway, "Ethanol and Its Implications for Fuel Supply," presentation at the April 1999 MTBE Blue
Ribbon Panel meeting; Downstream Alternatives, Ethanol Supply, Demand, and Logistics: California and Other
RFG Markets, May 1999.
115 This figure is the result of the following calculations: (1) Calculate the total ether supply for RFG and
oxygenated fuels in 1997: 265,000 b/d + 17,000 b/d = 282,000 b/d; (2) Multiply 282,000 b/d by 0.52 to adjust for
the oxygen equivalency of ethanol = 146,640 b/d; and (3) Add 41,000 b/d to include the current volume of ethanol
utilized for RFG and oxygenated fuels, thus reaching a total of 187,640 b/d (refer to Table Dl in the Appendix).
116 Jack Huggins, Submitted written comments on behalf of the Renewable Fuels Association at the April 1999
MTBE Blue Ribbon Panel meeting.
117 Roger Conway, "Ethanol and Its Implications for Fuel Supply," presentation at the April 1999 MTBE Blue
Ribbon Panel meeting; Downstream Alternatives, Ethanol Supply, Demand, and Logistics: California and Other
RFG Markets, May 1999.
118 Stephen Gatto, presentation on BC International Corporation at the April 1999 Blue Ribbon Panel meeting;
Roger Conway, "Ethanol and Its Implications for Fuel Supply," presentation at the April 1999 MTBE Blue Ribbon
Panel meeting.
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oil-based RFG production capacity by the full 11 percent by volume lost by removing MTBE.119
Although this Panel did not investigate the effect that the loss of MTBE would have on refineries outside
of California, there are some similarities and a number of differences in refinery processes that, on
balance, result in similar volume shortfalls in blending component capacities during the summer seasons.
A similar analysis by the U.S. Department of Energy (DOE) also concluded that additional supply would
be necessary under an ether ban in the Northeast, requiring increased domestic supply or foreign
imports.120
C. Ethanol Infrastructure/Transportation
Because ethanol is soluble in water, which is commonly found in pipelines and storage tanks associated
with the gasoline distribution system, and will separate from gasoline, ethanol is usually blended at the
distribution terminal.121 Therefore, because most of the nation's ethanol is produced in the Midwest, the
ethanol would have to be transported to terminals for blending through a dedicated (ethanol-only)
pipeline, by rail, by marine shipping, or by some combination of these methods. Transportation from the
Midwest to the Northeast and the West is challenging and will likely be costly and transportation-facility
intensive.
A study122 estimates that approximately 1,982 rail cars (30,000-gallons123 each) would be necessary to
supply the California market with ethanol for RFG purposes, assuming only rail transport. Given the
range in ethanol demand projected by the CEC study (35,000 b/d to 92,000 b/d), this rail car estimate
could actually be more than double. The existing fleet of 30,000-gallon rail cars is between 8,000 and
10,000, nearly all of which are currently unavailable for ethanol transport due to prior leasing
commitments. With existing manufacturing capability, it is estimated that approximately 1,000
additional (30,000-gallon) rail cars could be built per year.124
In California, marine transport has been found to cost approximately the same as rail transport, although
in certain instances marine shipping can be slightly cheaper. Surveys of terminal operators in California
have indicated that a large portion of product (most likely at least 50 percent) would be shipped as
waterborne cargo. Some California operators have stated that the large size of marine cargoes makes it
preferable to spotting, inspecting, and unloading numerous rail cars. Moreover, in the Northeast, nearly
119 Al Jessel, Chevron Products Company, "Fuels Regulations and Emissions Technology," presentation at the
March 1999 MTBE Blue Ribbon Panel meeting. See also, Duane Bordvick, Tosco Corporation, "Perspectives on
Gasoline Blending for Clean Air," presentation at the March 1999 MTBE Blue Ribbon Panel meeting.
120 U. S. Department of Energy, Estimating the Refining Impacts of Revised Oxygenate Requirements for
Gasoline: Summary Findings, May 1999.
121 Al Jessel, Chevron Products Company, "Fuels Regulations and Emissions Technology," presentation at the
March 1999 MTBE Blue Ribbon Panel meeting.
122 Downstream Alternatives, Ethanol Supply, Demand, and Logistics: California and Other RFG Markets,
May 1999.
123 42 gallons = 1 barrel
124 Based on API confidential communications with rail car lessors, 1999.
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every terminal location is accessible by water, whereas only a few can be accessed by rail. As such,
some estimate that 60 percent of the Northeast's total demand would be met through ship and ocean-
going barge transport.125
These will also be cited to develop the necessary blending and distribution infrastructure to deliver
ethanol-based RFG to retail outlets. Ethanol requires blending much further down the distribution
channel (at the truck-loading point) than does MTBE (at the refinery terminal). The infrastructure to
support such blending on a wide scale does not currently exist.126
D. Producing Non-Oxygenate Alternatives
In the event of an MTBE phase down with oxygenate flexibility, refiners have a number of blending
options to meet RFG performance standards, including increased use of alkylates, aromatics, and perhaps
other fuel blending streams derived from petroleum.127 Each refinery has a uniquely optimal mode of
operation, facility selection, and size, all of which are currently balanced for MTBE use. Without
MTBE, refiners would have to determine their most economic mode of operation and also determine
which new facilities and technologies would provide the economic return on investment that shareholders
require for continued investment. The strategy of total alkylate replacement is expensive (possibly
exceeding $1 billion), may not fully meet octane needs, and demands other operational trade-offs in the
refinery and/or additional supply of isobutane and olefin feedstocks. Although aromatics can also be
produced in greater volume and will provide higher octane, higher aromatics use will also increase toxics
emissions so that aromatics cannot likely fulfill all non-oxygenate needs. Nevertheless, oxygenate
flexibility is an important component of the solution to removing MTBE from the system in a timely
manner since it increases refiner flexibility in meeting RFG performance standards. The Panel could not
conduct a comprehensive evaluation of the technologies, facilities, and strategies necessary to achieve a
new, economically optimal fuels refining industry without MTBE, and with or without the current
oxygenate requirements, but rather chose to rely on analyses by others to estimate likely effects on
supply and cost, as discussed in Section III below.
125 Letter to Daniel Greenbaum from Robert E. Reynolds, President, Downstream Alternatives, Inc., June 24,
1999. See also, Downstream Alternatives, Ethanol Supply, Demand, and Logistics: California and Other RFG
Markets, May 1999.
126 Oil and Gas Journal, California refiners anticipate broad effects of possible state MTBE ban, January 18,
1999.
127 Dexter Miller, "Alkyates, Key Components in Clean-Burning Gasoline," presentation at the May 1999
MTBE Blue Ribbon Panel Meeting.
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III. Impact of Fuel Requirement Changes on Supply
A. Overview
The impact of a change in fuel requirements (e.g., reduction in the use of oxygenates or of a particular
oxygenate) on fuel availability and cost will depend primarily on the following factors:
The time available for a transition and the availability of adequate and sustained
supplies of any new component, and the time required for permitting and
achieving compliance with applicable regulations;
Regulatory certainty and flexibility regarding fuel specifications;
The degree to which fuel changes are national, regional, or state-by-state in
scope, i.e., fungibility;
Additional capital costs (e.g., new refinery facilities) and/or operating costs (e.g.,
transportation and distribution costs); and
The cost of replacing octane while continuing compliance with environmental
standards.
B. Time
Government agencies and fuel refiners/marketers have stated that without adequate lead time, rapid
reductions in the volume of MTBE allowed in the gasoline supply stream will have an immediate and
negative effect on regional markets as well as the nation's ability to meet gasoline demand.128
In general, refineries must undergo a stepwise process to implement major changes in fuel processing,
such as desulfurization or oxygenate reduction. A summary of Sunoco's recent analysis of the process
time required to comply with future sulfur limits is show in Table 1 as a general guide to such capital
projects.129 (Actual time requirements will vary from refinery to refinery.)
128 U. S. Department of Energy, Estimating the Refining Impacts of Revised Oxygenate Requirements for
Gasoline: Summary Findings, March 1999; California Energy Commission, Supply and Cost Alternatives to MTBE
in Gasoline, October 1998; Robert Cunningham, "Costs of Potential Ban of MTBE in Gasolines," presentation at
the March 1999 MTBE Blue Ribbon Panel meeting.
129 Sunoco, Time Required to Complete Desulfurization, personal communication.
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Table 1. Sample Process Timetable for Complying with Future Sulfur Limits in the Refining
Industry
I. Conceptual/Process Feasibility
Identify purpose, scope, and permits required
Produce cost estimates
Management approval
II. Process/Proiect Scope Definition
Develop scope, equipment requirements,
project milestones, and construction strategies
Produce more accurate budget estimates
Management approval
III. Preliminary Engineering
Select engineering contractor
Submit permit applications
Conduct design review
Issue master schedule
Submit costs for approval
IV. Detailed Proiect Execution
Procure materials
Receive all permits
Award contracts
Construction
Testing
Training
Start-up
Total
7 months
8 months
12 months
21 months
48 months
Source: Sunoco
Should ethers, particularly MTBE, be phased out in California, the CEC estimates that in three years
California refineries would require as much as 75,000 b/d of ethanol and up to 142,000 b/d of additional
gasoline imports to meet demand.130
The U.S. Department of Energy estimates that if regulation changes are finalized, four years would be
needed to allow for new construction of refineries and for ethanol production, transportation, loading and
unloading capacities to increase. Under this assumption, a scenario of an ether phase-out should not
130 California Energy Commission, Supply and Cost Alternatives to MTBE in Gasoline, October 1998. This
study did not analyze the likely fuel supply impacts to areas outside of California if MTBE use were to be phased
out in California.
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cause supply problems in Petroleum Administration for Defense District (PADD) I, the East Coast.131
This analysis did not consider effects on regional supplies in the event of a national MTBE ban or other
changes in fuel properties (i.e., sulfur reductions).
Relative to California refiners, the transition to a non-ether RFG would be more difficult and require
more time for non-California refiners. Implementation of the proposed sulfur rules (TIER 2) will have
less impact on California refiners, as all California RFG (CaRFG) is already at a sulfur level of 30 parts
per million (ppm) or lower. Other refiners will need additional time to build adequate desulfurization
units, as well as other facilities needed to generate the octane lost through desulfurization. The State of
California believes that with a repeal of the Federal oxygen mandate, MTBE should be phased out in
three and one-half years.132
C. Certainty
Refiners/marketers have stated that regulatory certainty is necessary to insure low-risk capital investment
in alternatives to our current fuel supply system. For example, whether the current oxygenate mandate
will remain or be removed will be a critical factor in future refinery, product transportation, and
marketing terminal construction decision making. Refiners/marketers believe that the removal of the
oxygenate mandate would provide maximum flexibility for the individual decisions necessary for each
refiner to meet all Federal and State RFG performance standards.
D. Fungibility
Refiners/marketers have indicated that to meet consumer fuel demand and to minimize supply shortages,
the scope of any future fuel changes should be national or regional. Permitting state-specific fuel
changes (e.g., low RVP, low sulfur) may lead to greater uncertainty in fuel supply and may cause
periodic shortages unless there is a mechanism to ensure consistency across state boundaries.
Although ethanol blended gasoline can be blended to maintain low vapor pressure, reformulated gasoline
made with ethanol will likely increase evaporative emissions when commingled with other fuels in
markets where ethanol occupies 30 percent to 50 percent of the market.133 (Refer to Issue Summary B,
"Air Quality Benefits"). In order to minimize commingling, refiners in these markets will need to
develop and use infrastructure (storage, trucks, etc.) dedicated to fuels containing ethanol. In areas of the
country (e.g., the Midwest) where ethanol has been the predominant fuel additive, this will not be a
problem. However, areas of the country that have not traditionally used ethanol fuels, but would likely
do so for a part of their supply in the future, will need to make infrastructure investments to avoid losses
in air quality as a result of commingling. Even then, some commingling of fuels will likely occur when
consumers mix ethanol blended gasoline with non-ethanol blended gasoline in their vehicles' tanks (see
discussion in Air Quality Section B.).
131 U. S. Department of Energy, Estimating the Refining Impacts of Revised Oxygenate Requirements for
Gasoline: Summary Findings, March 1999; Downstream Alternatives, Ethanol Supply, Demand, and Logistics:
California and Other RFG Markets, May 1999.
132 California Energy Commission, Supply and Cost Alternatives to MTBE in Gasoline, October 1998.
133 Office of Science and Technology Policy, National Science and Technology Council, Inter agency
Assessment of Oxygenated Fuels, June 1997.
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IV. Cost Impacts of Changing Fuel Reformulations
A. Cost Impacts
The cost of gasoline is influenced by a wide range of factors, including crude oil prices, refining costs,
the grade and type of the gasoline, taxes, available supplies (inventory), seasonal and regional market
demand, weather, transportation costs, and specific areas' relative costs of living. Each additional cent
per gallon increase in average gasoline price is equivalent to annual costs of between $1 billion to $1.3
billion, borne ultimately by consumers.
Both ethanol and oil receive some subsidy from the government. All fuel ethanol receives a $0.54 per
gallon subsidy, while approximately 6-7 percent of gasoline receives a cost benefit from the crude oil
depletion allowance. In both cases these government subsidies are supported by Congress because it is
seen to expand domestic industry; increase commerce and employment; improve the nation's balance of
trade (i.e., reduce imports and increase exports); and generate additional personal and corporate incomes
and the taxes accruing from these incomes. Analysis has suggested that the real cost to the government is
a net benefit. For example, replacing the 282,000 b/d of ethers used in RFG in 1997 would require
approximately 146,000 b/d of ethanol on an oxygen equivalent basis. The U.S. Environmental Protection
Agency estimates that the incremental annual cost to the Federal government (/'. e., to taxpayers) for new
fuel ethanol production of 146,000 b/d (approximately 2.2 billion gallons per year) would be
approximately $1.2 billion.134 The State of Nebraska Ethanol Board estimates that the ethanol subsidy
resulted in $3.5 billion in net savings for the Federal government in 1997.135
Table 2 shows recent information from the U.S. Energy Information Administration (EIA) regarding the
price differences among CaRFG, Federal RFG, conventional gasoline, and the national average price for
gasoline. These prices reflect the various factors that influence the cost of gasoline. For example, after
reaching their lowest point in 25 years (adjusted for inflation) at the end of 1998, world crude oil prices
began recovering during the spring of 1999. In addition, April represents the beginning of the summer
driving season, which leads to higher gasoline demand; California is regionally influenced by the summer
driving demand before much of the rest of the nation. Finally, California prices have been influenced in
1999 by fires and shutdowns at several major refineries. Thus, due to regional and seasonal demand
variation, the volatility of world crude oil prices and unforeseen supply shortages, consumers may see
swings in gasoline prices of as much as $.50 per gallon.
134 This figure is the result of the following calculations: (1) Calculate the total ether supply for RFG and
oxygenated fuels in 1997: 265,000 b/d + 17,000 b/d = 282,000 b/d; (2) Multiply 282,000 b/d by 0.52 to adjust for
the oxygen equivalency of ethanol = 146,640 b/d, or 2.2 billion gallons annually; (3) Multiply by the $0.54 per
gallon subsidy = $1.2 billion per year (refer to Table Dl in the Appendix for total ether volumes).
135 State of Nebraska Ethanol Board, "Economic Impacts of Ethanol Production in the United States," April,
1998.
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Table 2. Gasoline Prices, February 1999 and April 1999
(per gallon, including State and Federal taxes)
California RFC
Federal RFC
Conventional
Average
February 1999
$1.101
$0.987
$0.901
$0.927
April 1999
$1.568
$1.229
$1.088
$1.131
Source: U.S. Energy Information Administration
Nevertheless, the real cost of gasoline, although quite variable, increases with higher refining costs,
which are associated with environmental quality restrictions and local or regional differences in gasoline
specifications. Fuel refiners/marketers have commented that with (1) adequate lead time to make
refinery investments and modifications; (2) regulatory certainty regarding specific fuel requirements; and
(3) fuel fungibility on a regional or national scope, increases in fuel prices due to regulatory changes may
not cause substantial and unnecessary volatility in prices beyond the normal seasonal fluctuations.
Economic impacts will not be shared equally among petroleum refiners/marketers. Refineries each
process different types of crude, supply different mixes of products (e.g., some refineries do not
manufacture any RFG), and use widely varying technologies. For example, the State of California
currently requires low levels of sulfur in CaRFG. As such, the economic impact of lowering sulfur levels
would not be as great for some California refineries that manufacture mostly CaRFG as it might be for
some other refiners, and in other markets where refineries would require capital investments for
desulfurization facilities. Similarly, areas of the country that rely heavily on oxygenates such as MTBE
will experience a more pronounced economic effect in the event of a oxygenate replacement or removal
(e.g., Texas, California, and Northeast RFG markets use MTBE, whereas the Chicago and Milwaukee
RFG markets use ethanol).
B. Modeling
Modeling fuel price increases is a relatively effective technique with which to examine the direction of
the impacts of regional fuel formulation choices on gasoline costs. Such predictions are instructive in
assessing the relative impacts of different options assuming constant assumptions. Models should not be
used, however, to predict exact outcomes. With the exception of precipitous transition times and a major
increase in ethanol use, which would require significant new infrastructure, all other modeled scenarios
add cost to gasoline of a magnitude similar to the typical variability of gasoline prices. The results of
three such models are summarized below (also refer to Table D2 in the Appendix):
The California Energy Commission estimated that the intermediate-term (three years)
change in the price of California RFG could range from a decrease of 0.2 cents per
gallon to an increase of 8.8 cents per gallon depending on the type of oxygenate used (if
oxygenates are used at all), the lead time to implement the changes, and flexibility
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regarding the type and amount of oxygenate allowed.136 This study did not analyze the
likely economic impacts to areas outside of California if MTBE use were to be phased
out in California or nationally (i.e., increased market volatility from dependence on
imported blendstocks to replace MTBE, with or without ethanol use).
A Chevron/Tosco analysis estimates that if refiners were given flexibility in oxygenate
use, a California ban on MTBE would increase the cost of CaRFG 2.7 cents per gallon
within a three year-period. Without oxygenate flexibility, the price would increase 6.1
cents per gallon.137
An analysis by Pace Consultants found that it would cost an additional 0.7 to 24 cents
per gallon to make reformulated gasoline blendstock that is suitable for use with ethanol
(rather than MTBE) in the summer during the RFG Phase II program. For refiners
already using ethanol in RFG (less than 10 percent of the RFG market), the Pace study
indicated that the additional cost of using ethanol in Phase II RFG would be less than one
cent per gallon. In general, the cost of RVP reduction differs among refiners and
depends on refinery process configuration, product and raw material slates, and ability to
dispose of streams displaced in RVP reduction.138
A recent DOE analysis shows that under the scenario of an ether ban, assuming at least
four years for refinery investment, and with a continuation of the oxygenate requirement
for RFG, the increased cost for RFG per gallon in PADD I ranges from 2.4 cents to 3.9
cents, with the cost most sensitive to the price of ethanol.139 This analysis, however, was
not national in scope.
C. Conclusions
Assuming that changes in oxygenate requirements occur, the limited modeling analyses to date have
shown that for California and PADD I:
Once regulations are finalized, a range of three to six years is necessary to develop the
infrastructure necessary to substantially alter the regional, possibly national, fuel
formulation and supply infrastructure without serious market volatility.
The estimated costs of implementing these changes will range from a slight savings
under a scenario of oxygenate-use flexibility and continued MTBE use, to a cost of about
8.8 cents per gallon under a scenario of no oxygenate use (no mandate). (See Table D2 in
the Appendix).
136 California Energy Commission, Supply and Cost Alternatives to MTBE in Gasoline, October 1998.
137 MathPro, Potential Economic Benefits of the Feinstein-Bilbray Bill, March 18, 1999.
138 PACE Consultants, Inc., Analysis and Refinery Implications of Ethanol-Based RFG Blends Under the
Complex Model Phase II, November 1998.
139 U. S. Department of Energy, Estimating the Refining Impacts of Revised Oxygenate Requirements for
Gasoline: Follow-up Findings, May 1999.
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Because no studies have been national in scope, the predictions of cost impacts are
uncertain. In addition, most studies were conducted on the assumption of meeting only
the current regulatory minimum emission reductions.
The likely oxygenate replacement for MTBE is ethanol. Current and near future ethanol
production (i.e., on-line in less than two years), however, is not adequate to meet the
volume of oxygenate required nationally. Transporting ethanol from the Midwest, where
it is primarily produced, to Northeast and California markets will require significant
efforts to upgrade and build new pipeline (or use segregated shipments through existing
pipelines), rail, marine, and truck transportation infrastructure.
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Appendix D
Table D1. Oxygenate Demand in Reformulated and Oxygenated Gasoline Control
Areas, 1997
(thousands of barrels per day)
Estimated 199
Region Gasoline Demand i
Control Area
Estimated Oxygenate Volume
in Control Area Gasoline
s MTBE ETBEorTAME Ethanol
Reformulated Gasoline
PADD 1 (East Coast) 1,054 128.2 9.1 1.0
PADD 2 (Midwest) 270 4.0 0.0 21.8
PADD 3 (Gulf Coast) 282 27.4 3.2 0.0
PADD 4 (Rocky Mountain) 0 0.0 0.0 0.0
PADD 5 (West Coast) 934 100.9 3.4 2.0
Subtotal 2,674 259.5 15.7 24.7
Oxygenated Gasoline
PADD 1 (East Coast) 0 0.0 0.0 0.0
PADD 2 (Midwest) 79 0.0 0.0 6.7
PADD 3 (Gulf Coast) 16 0.0 0.0 1.4
PADD 4 (Rocky Mountain) 36 0.3 1.1 2.7
PADD 5 (West Coast) 73 0.1 0.0 4.7
Subtotal 204 0.5 1.1 15.5
Oxygenated-Reformulated Gasoline
PADD 1 (East Coast) 137 4.8 0.0 0.4
PADD 5 (West Coast) 10 0.1 0.0 0.7
Subtotal 147 4.9 0.0 1.1
Average 1997 Oxygenate Demand for RFG and
Oxygenated Gasoline Blending
265 17 41
Imputed Oxygenate Demand for Conventional Gasoline
(e.g., octane and gasohol) 4a - 41
Total 1997 Oxygenate Supply
269 17 82
aOther sources have estimated this number to be as high as 25,000 b/d (Sunoco) and 28,000 b/d (DeWitt) for ethers in the
conventional pool, with a slightly lower volume in the RFG pool.
Source: U.S. Energy Information Administration, (T. Litterdale and A. Bohn), Demand and Price Outlook for Phase 2
Reformulated Gasoline, 2000. April 1999, pp. 7-8.
Note:"-" signifies "Not Applicable."
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Table D2. Summary of Modeling Results
(cents per gallon)
Report
Scenario
Results (cents per gallon)
Intermediate Term
(3 years)
Long Term
(6 Years)
MTBE allowed - no
oxygenate requirement
-0.2 to -0.8
-0.3to-1.5
CEC Analysis:
California Only
No oxygenates allowed -
no oxygen requirement
Ethanol only - oxygen
requirement maintained
4.3 to 8.8
6.1 to 6.7
0.9 to 3.7
1.9 to 2.5
Chevron/Tosco
Analysis: California
Only
No ethers - no oxygen
requirement
Ethanol only - oxygen
requirement maintained
2.7
6.1
1.2
1.9
Near Term
(less than 2 years, no
investment)
Long Term
(at least 4 years,
investment allowed)
DOE Analysis:
PADD I Only
MTBE allowed - no
oxygenate requirement
No ethers - no oxygen
requirement
-0.3
Not Investigated
Not Investigated
1.9
Ethanol only - oxygen
requirement maintained
6.0
2.4 to 3.9
Source: U.S. Environmental Protection Agency
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E. Comparing the Fuel Additives
I. Introduction
In comparing various alternatives to the current use of automotive fuel additives (primarily oxygenates),
the relative impact of these alternative compounds on the environment as a whole must be considered.
More specifically, one must assess how changes to fuels or fuel additives impact:1
Air quality and fuel blending characteristics;
Fuel or fuel additive behavior and fate under various water and soil conditions;
and
Potential health effects resulting from exposure to the additives or their
combustion products.
Health effects research is currently underway by industry2 and EPA3 to understand more fully the
comparative risks associated with exposure to fuels both with and without oxygenates, including methyl
tertiary butyl ether (MTBE), ethanol, ethyl tertiary butyl ether (ETBE), tertiary-amyl methyl ether
(TAME), and tertiary butyl alcohol (TEA).4 Although the majority of this research is focused on
inhalation-related health effects, the results should help in our understanding of the human health risks
associated with exposure to fuels from any route of exposure. Currently, there is not enough information
to fully characterize potential health risks of all the oxygenates or their alternatives.
II. MTBE
A. Air Quality and Fuel
Blending serves as a cost-effective oxygenate for blending in reformulated gasoline (RFG), enabling
fuels to meet both California and Federal RFG air quality requirements while preserving octane
enhancement, low VOC emissions, and driveability. Analyses have shown that even without an oxygen
1 Refer to Issue Summaries A and B, "Water Contamination" and "Air Quality Benefits" respectively, for
detailed discussions of these topics.
2 U.S. Environmental Protection Agency, Federal Register Vol. 63, No. 236, December 9, 1998, p. 67877.
Final Notification of Health Effects Testing Requirements for Baseline Gasoline and Oxygenated Nonbaseline
Gasoline and Approval of an Alternative Emissions Generator.
3 Jim Prah of the U.S. Environmental Protection Agency is currently conducting studies on pharmacokinetics
of MTBE.
4 Refer to Table El in this section's Appendix for detailed data on the chemical properties of these and related
compounds.
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mandate, MTBE use is economically suited to meet air quality and gasoline performance goals.5
However, it should be noted that emissions of formaldehyde (a probable carcinogen), resulting from the
incomplete combustion of fuels, increase by about 13 (+ 6) percent with the use of 2.0 percent by weight
(wt%) MTBE oxygenated gasoline.6
B. Behavior in Water
MTBE, an ether, is more soluble in water than other gasoline components and appears recalcitrant to
biodegradation relative to other components of concern in gasoline, such as benzene, toluene,
ethylbenzene, and xylenes (collectively referred to as "BTEX").7 In general, compared to the slow
migration of BTEX compounds in subsurface soil and ground water, MTBE moves at nearly the same
velocity as the ground water itself. This is due to MTBE's high water solubility and low soil sorption.
Given sufficient time and distance, MTBE would be expected to be at the leading edge of a gasoline
contamination plume or could become completely separated from the rest of the plume if the original
source of oxygenate were eliminated.8
Tert-butyl alcohol (TEA) is the primary metabolite of MTBE resulting from biodegradation, but is also a
common byproduct in the production of MTBE and often present with MTBE in the fuel supply. Thus,
detection of TEA in ground water is not necessarily evidence of MTBE biodegradation. By itself, TEA,
like ethanol, is infinitely (miscible) soluble in water and is reported to be recalcitrant to biodegradation.9
C. Health Effects
In terms of neurotoxicity and reproductive effects, inhalation toxicity testing to date generally has not
shown MTBE to be any more toxic than other components of gasoline. At high doses, MTBE has caused
tumors in two species of rat and one species of mouse at a variety of sites; it is uncertain, however,
whether these effects can be extrapolated to humans. The International Agency for Research on Cancer
5 U. S. Department of Energy, Estimating the Refining Impacts of Revised Oxygenate Requirements for
Gasoline: Summary Findings, March 1999; California Energy Commission, Supply and Cost Alternatives to MTBE
in Gasoline, October 1999; Robert Cunningham, "Costs of Potential Ban of MTBE in Gasolines," presentation at
the March 1999 MTBE Blue Ribbon Panel meeting.
6 T.W. Kirchstetter, et. al, "Impact of Oxygenated Gasoline Use on California Light-Duty Vehicle
Emissions," Environ. Sci. And Tech., 1996.
7 U.S. Environmental Protection Agency, Office of Research and Development, Oxygenates in Water: Critical
Information and Research Needs, December 1998.
8 A.M. Happel et al.,An Evaluation of MTBE Impacts to California Groundwater Resources, Lawrence
Livermore National Laboratory Report, UCRL-AR-130897, June 1998.
9 Office of Science and Technology Policy, National Science and Technology Council. Interagency
Assessment of Oxygenated Fuels, June 1997; Steffan, R.J,. et. al., Biodegradation of the Gasoline Oxygenates
Methyl tert-Butyl Ether (MTBE), Ethyl tert-Butyl Ether (ETBE), and tert-Amyl Methyl Ether (TAME) by Propane
Oxidizing Bacteria, Appl. Environ. Microbiol. 63(ll):4216-4222).
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(IARC) and the National Institute of Environmental Health Sciences (NIEHS) have indicated that at this
time there are not adequate data to consider MTBE a probable or known human carcinogen.10
There are limited data on human populations that may be sensitive to MTBE. Although there is some
evidence that fuels containing MTBE could irritate the eyes, as well as cause headaches and rashes,
effects attributed to MTBE alone have yet to be proven. Limited epidemiological data suggest greater
attention should be given to the potential for increased symptom reporting among highly exposed
workers.11
There have been no human or animal health effects studies performed for MTBE in drinking water.
However, human and animal studies are currently underway at the U.S. Environmental Protection
Agency (EPA), Health Effects Institute (HEI) and the Chemical Industry Institute of Toxicology (CUT)
to address some of these research needs.12 Animal ingestion studies using "bolus" (all at once) dosing of
MTBE in olive oil have shown carcinogenic effects at high levels of exposure (250,000 micrograms per
kilogram animal body weight and higher).13 14
Drinking water containing MTBE at or below the taste and odor levels identified in the EPA's Drinking
Water Advisory (20 to 40 micrograms per liter) is not expected to cause adverse health concerns for the
majority of the population.15 The turpentine-like taste and odor of MTBE, however, can make such
drinking water unacceptable to consumers.
TEA is a major metabolite of MTBE, regardless of the route of exposure. Animal testing of TEA in
drinking water produced carcinogenic effects at high levels of exposure (1,250,000 micrograms per liter
and higher).16 Additionally, formaldehyde, also a metabolite of MTBE, is a respiratory irritant at high
10 Office of Science and Technology Policy, National Science and Technology Council, Interagency
Assessment of Oxygenated Fuels, June 1997.
11 Office of Science and Technology Policy, National Science and Technology Council, Interagency
Assessment of Oxygenated Fuels, June 1997.
12 Correspondence with the Health Effects Institute, Chemical Industry Institute of Toxicology, and EPA verify
currently on-going studies on animal and human health effects from MTBE exposure.
13 U.S. Environmental Protection Agency, Office of Water, Drinking Water Advisory: Consumer
Acceptability Advice and Health Effects Analysis on Methyl Tertiary-Butyl Ether (MTBE), December 1997.
14 It should be noted that the National Research Council has cautioned against the use of this study until a
thorough review has been accomplished, including an objective third-party review of the pathology. (Toxicological
and Performance Aspects of Oxygenated Motor Vehicle Fuels, National Research Council, Washington, D.C. 1996,
page 115.)
15 U.S. Environmental Protection Agency, Office of Water, Drinking Water Advisory: Consumer
Acceptability Advice and Health Effects Analysis on Methyl Tertiary-Butyl Ether (MTBE), December 1997.
16 U.S. Environmental Protection Agency, Office of Water, Drinking Water Advisory: Consumer
Acceptability Advice and Health Effects Analysis on Methyl Tertiary-Butyl Ether (MTBE), December 1997.
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levels of human exposure and is currently considered by EPA to be a probable human carcinogen by the
inhalation route, with less certainty via ingestion.17
III. Ethanol
A. Air Quality and Fuel Blending
Ethanol is commonly used as an octane enhancer in conventional gasoline, as well as serving as an
oxygenate for blending in Federal RFG and oxygenated gasoline in a number of locations (primarily in
the Midwest).18 Because of its unique physical and chemical properties, ethanol raises the volatility of
gasoline with which it is blended, thus additional refinery processing of blendstocks is performed prior to
ethanol blending in order to meet the air quality performance standards in reformulated fuels.19 Ethanol
is soluble in the water commonly found in pipelines and storage tanks associated with the gasoline
distribution system, and once mixed with water will separate from the gasoline. Due to this potential
phase separation, which can occur when ethanol and gasoline blends are transported through pipelines,
ethanol is usually blended at the terminal, rather than the refinery.
A National Research Council study20 did not support using ozone forming potential or reactivity (as
opposed to mass emission reductions) to assess the relative effectiveness of MTBE or ethanol in the RFG
program. However, the report did find that the contribution of the reduction of carbon monoxide (CO)
and its effect on ozone formation should be recognized in assessments of the effects of ethanol in RFG.
(Refer to Issue Summary B, "Air Quality Benefits.")
In markets where ethanol blended fuels make up 30 percent to 50 percent of the market, the possibility of
commingling of ethanol fuels with non-ethanol fuels in the fuel supply system will require separation of
ethanol fuel infrastructure, and commingling in the gas tank can result in an increase in both vapor
pressure and evaporative emissions.21 (Refer to Issue Summary B, "Air Quality Benefits.")
Vehicle exhaust emissions data have shown that acetaldehyde (principle metabolite of ethanol) emissions
can increase by as much as 100 percent with the use of 2.0 wt% ethanol oxygenated gasoline, part of
which undergoes photochemical reactions in the atmosphere to make peroxyacetyl nitrate (PAN).22
17 Office of Science and Technology Policy, National Science and Technology Council, Inter agency
Assessment of Oxygenated Fuels, June 1997.
18 Refer to Issue Summary D, "Fuel Supply and Cost," for a more detailed discussion of this topic.
19 California Energy Commission, Supply and Cost Alternatives to MTBE in Gasoline, October 1999.
20 Office of Science and Technology Policy, National Science and Technology Council, Interagency
Assessment of Oxygenated Fuels, June 1997.
21 Office of Science and Technology Policy, National Science and Technology Council, Interagency
Assessment of Oxygenated Fuels, June 1997.
22 J. Froines et. al, Health and Environmental Assessment of MTBE, Vol. II, November, 1998; A.P Altshuller,
"PANs in the Atmosphere," J. Air Waste Manag. Assoc., 1993, 43(9), 1221-1230; L. Milgrom, "Clean Car Fuels
Run Into Trouble," New Scientist, 1989, 122 (1656), 30.
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B. Behavior in Water
"Neat" (pure) ethanol is infinitely soluble in water. Laboratory data and hypothetical modeling indicate
that based on physical, chemical, and biological properties, ethanol will likely preferentially biodegrade
in ground water compared with other gasoline components with the potential to extend BTEX plumes
further than they would be without ethanol present.23
Although ethanol has been shown to retard BTEX biodegradation under certain laboratory conditions,
evidence of ethanol's effect on the migration of BTEX plumes under various conditions, i.e.,
hydrogeology; field concentrations; nature of release scenario (for example, large sudden release versus
slow continuous release) has not been collected and compiled.24 A more comprehensive review is still
needed to investigate and determine the nature and extent of field experiences regarding ethanol's effect
(including behavior and fate properties) on BTEX plume migration, aquifer remediation, and drinking
water treatment.
C. Health Effects
The health effects of ingested ethanol have been extensively investigated. Given that ethanol is formed
naturally in the body at low levels, inhalation exposure to ethanol at the low levels that humans are likely
to be exposed are generally not expected to result in adverse health effects.25 Health effects questions
have been raised, however, about potentially sensitive subpopulations. In addition, increased use of
ethanol may result in increases of certain atmospheric transformation products, such as PAN and
acetaldehyde, although the extent of such increase is unknown.26 PAN, which has been shown to be
mutagenic in cellular research, is a known toxin to plant life and a respiratory irritant to humans.27
Combustion byproducts of ethanol may also cause adverse health effects. Acetaldehyde is a respiratory
irritant at high levels of human exposure and is currently classified by EPA as a probable human
carcinogen.
23 Michael Kavanaugh and Andrew Stocking, "Fate and Transport of Ethanol in the Environment,"
presentation at the May 1999 MTBE Blue Ribbon Panel meeting. [Based on Malcome Pirnie, Inc. Evaluation of
the Fate and Transport of Ethanol in the Environment (Oakland, CA, 1998.)]
24 Michael Kavanaugh and Andrew Stocking, "Fate and Transport of Ethanol in the Environment,"
presentation at the May 1999 MTBE Blue Ribbon Panel meeting. [Based on Malcome Pirnie, Inc. Evaluation of
the Fate and Transport of Ethanol in the Environment (Oakland, CA, 1998.)]
25 Health Effects Institute, The Potential Health Effects of Oxygenates Added to Gasoline, April 1996.
26 Health Effects Institute, The Potential Health Effects of Oxygenates Added to Gasoline, April 1996.
27 L. Milgrom, "Clean Car Fuels Run Into Trouble," New Scientist, 1989, 122 (1656), 30.
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IV. Other Ethers28
A. Air Quality and Fuel Blending
Other ethers have been shown to provide the same emissions benefits as MTBE or ethanol. Alternative
ethers (except tertiary-amyl methyl ether - TAME) have found only limited use, however, because they
are economically less competitive to manufacture.
B. Behavior in Water
Other ethers are likely to be similar, although not identical to, MTBE, i.e. highly soluble in ground water,
poorly sorbed to soil, and degraded more slowly than BTEX chemicals. Behavior in ground water is a
function of solubility, soil sorption, and the ability to biodegrade. All oxygenates are significantly more
soluble than benzene and evidence to date demonstrates that in situ biodegradation of these compounds is
limited as compared to benzene. Differences may exist between solubility and degradability of ethers.
Accelerated studies are necessary in order to make this determination.
C. Health Effects
Although toxicity testing of these substances is underway, there is less current knowledge regarding the
inhalation or ingestion health effects associated with these compounds than for ethanol and MTBE.
V. Other Alternatives
A. Air Quality and Fuel Blending
In addition to ethanol, the most likely alternatives to replace the current volume of MTBE and other
ethers in RFG are increased use of refinery streams such as alkylates, reformates, aromatics, and other
streams resulting from the fluid catalytic cracking (FCC) processes.
Alkylates are a mix of high octane, low vapor pressure branched chain paraffinic hydrocarbons that can
be made from crude oil through well established refinery processes, using the output from an FCC unit.
Because of these desirable properties, alkylates are highly favored as streams for blending into gasoline.29
In general, an increase in the amount of alkylates used in fuels will have no adverse effect on overall
vehicle performance.30 Aromatics are hydrocarbons characterized by unsaturated ring structures of
carbon atoms (i.e. benzene, toluene, and xylene), and increased use of aromatics would be likely to
28 Ethers are organic compounds consisting of carbon, hydrogen, and oxygen. Often used as gasoline
blendstocks and as oxygenates, ethers include: MTBE; ETBE; TAME; and diisopropyl ether (DIPE).
29 Dexter Miller, "Alkylates, Key Components in Clean-Burning Gasoline," presentation at the May 1999
MTBE Blue Ribbon Panel meeting.
30 Duane Bordvick, Tosco Corporation, "Perspectives on Gasoline Blending for Clean Air," presentation at the
March 1999 MTBE Blue Ribbon Panel meeting; Al Jessel, Chevron Products Company, "Removing MTBE From
Gasoline," presentation at the March 1999 MTBE Blue Ribbon Panel meeting.
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increase toxic emissions when used in high quantities. Refiners in California have produced non-
oxygenated fuels using lower sulfur, alkylates and aromatics, that meet or exceed all California RFG air
quality requirements.31
B. Behavior in Water
Alkylates are nonpolar and have a much lower (over 100 times less) solubility in water than aromatics
such as BTEX compounds. Based on alkylates' physical, chemical, and biological properties, dissolution
from the gasoline source area, biodegradation, and movement in ground water, are all expected to be
significantly slower than BTEX compounds.
Water-related environmental fate research should include studies in the following areas:
Water solubility, dissolution behavior, and sorption tendency to soil and aquifer material;
Effects of biodegradation on the gasoline contaminated plume's overall movement;
Transformation studies to determine if the compound breaks down in soil or
surface/ground water; and
Whether intermediates and/or final products pose either a greater or lesser risk.
C. Health Effects
Alkylates have long been a common ingredient in fuels, and thus a modest increase in alkylate content
would not be expected to cause additional human health risks above those already associated with human
exposure to fuels. However, the human and aquatic toxicity risk data associated with exposure to
alkylates are limited. Aromatics have also long been used in fuel, and contain compounds (e.g. benzene
and toluene) which are known to have a range of potential health effects; any substantial increase in their
use should be carefully evaluated. At a minimum, testing for non oxygenated fuel alternatives should
include sufficient data to develop an adequate risk assessment. These tests should seek inhalation and
ingestion data through animal toxicity and human microenvironmental exposure studies using both the
additives themselves, and the gasoline mixtures of which they are a part.
MathPro, Potential Economic Benefits of the Feinstein-Bilbray Bill, March 18, 1999.
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Appendix E
Table E1. Chemical Properties of Selected Compounds3
Molecular Weight (g/mol)
Boiling Point (°C)
Vapor Pressure
(mm Hgat20°C)
Density (g/L)
Octane Number
Neat Solubility (g/100g H20)
Benzene2
78.11
80.1
73
0.88
94
0.178
MTBE2
88.2
55.2
240
0.74
110
4.8
Ethanol3
46.1
78.5
44
0.79
115
miscible
ETBE1
102.2
72.2
130
0.74
112
1.2
TAME1
102.2
86.3
75
0.77
105
1.2
Alkylates
TEA3 (isooctane)
74.1
82.4
41
0.79
100
miscibl
e
114.2
99.2
72
0.69
100
« 0.01
Solubility into H20 from
Gasoline (g/100g H20)
Taste Threshold
in Water (ug/L)
Odor Threshold (ppm)
<01 0.55
500 20 to 40
0.5 0.053
5.7b
0.33
0.24
2.5b
47 128
49 0.013 0.027 21
a Adapted from USGS. For a detailed discussion of the solubility in water from gasoline mixture containing 2% oxygen, see p.
2-50 - 2-53 of the National Science and Technology Council. Interagency Assessment of Oxygenated Fuels (June 1997).
b The water solubilities of the alcohols are estimates based on partitioning properties.
Sources:
1 D.L. Conrad, Texaco Research and Development Department, The Impacts of Gasoline Oxygenate Releases to the
Environment - A Review of the Literature (Port Arthur, Texas, 1995).
2 Donald Mackay, W.Y. Shiu, and K.C. Ma, Illustrated Handbook of Physical-Chemical Properties and Environmental Fate for
Organic Chemicals: Vol. Ill, Volatile Organic Compounds (Boca Raton, FL: Lewis Publishers, Inc, 1993) p. 916.
3 Donald Mackay, W.Y. Shiu, and K.C. Ma, Illustrated Handbook of Physical-Chemical Properties and Environmental Fate for
Organic Chemicals: Vol. Ill, Volatile Organic Compounds (Boca Raton, FL: Lewis Publishers, Inc, 1993) p. 962.
Key:
" -" signifies "Not Applicable."
g/mol = Grams Per Mole
X°C = Degrees Celsius
mm Hg = Millimeters of Mercury
g/L = Grams Per Liter
g/1 OOg H20 - Grams Per 100 Grams of Water
ug/L = Micrograms Per Liter
ppm = Parts Per Million
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CHAPTER 3. FINDINGS AND RECOMMENDATIONS OF THE
BLUE RIBBON PANEL
Findings
Based on its review of the issues, the Panel made the following overall findings:
The distribution, use, and combustion of gasoline poses risks to our environment and
public health.
RFG provides considerable air quality improvements and benefits for millions of US
citizens.
The use of MTBE has raised the issue of the effects of both MTBE alone and MTBE in
gasoline. This Panel was not constituted to perform an independent comprehensive
health assessment and has chosen to rely on recent reports by a number of state, national,
and international health agencies. What seems clear, however, is that MTBE, due to its
persistence and mobility in water, is more likely to contaminate ground and surface water
than the other components of gasoline.
MTBE has been found in a number of water supplies nationwide, primarily causing
consumer odor and taste concerns that have led water suppliers to reduce use of those
supplies. Incidents of MTBE in drinking water supplies at levels well above EPA and
state guidelines and standards have occurred, but are rare. The Panel believes that the
occurrence of MTBE in drinking water supplies can and should be substantially reduced.
MTBE is currently an integral component of the U.S. gasoline supply both in terms of
volume and octane. As such, changes in its use, with the attendant capital construction
and infrastructure modifications, must be implemented with sufficient time, certainty,
and flexibility to maintain the stability of both the complex U. S. fuel supply system and
gasoline prices.
The following recommendations are intended to be implemented as a single package of actions designed
to simultaneously maintain air quality benefits while enhancing water quality protection and assuring a
stable fuel supply at reasonable cost. The majority of these recommendations could be implemented by
federal and state environmental agencies without further legislative action, and we would urge their rapid
implementation. We would, as well, urge all parties to work with Congress to implement those of our
recommendations that require legislative action.
Recommendations to Enhance Water Protection
Based on its review of the existing federal, state and local programs to protect, treat, and remediate water
supplies, the Blue Ribbon Panel makes the following recommendations to enhance, accelerate, and
expand existing programs to improve protection of drinking water supplies from contamination.
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Prevention
1. EPA, working with the states, should take the following actions to enhance significantly
the Federal and State Underground Storage Tank programs:
a. Accelerate enforcement of the replacement of existing tank systems to conform
with the federally-required December 22, 1998 deadline for upgrade, including,
at a minimum, moving to have all states prohibit fuel deliveries to non-upgraded
tanks, and adding enforcement and compliance resources to ensure prompt
enforcement action, especially in areas using RFG and Wintertime Oxyfuel.
b. Evaluate the field performance of current system design requirements and
technology and, based on that evaluation, improve system requirements to
minimize leaks/releases, particularly in vulnerable areas (see recommendations
on Wellhead Protection Program in 2. below).
c. Strengthen release detection requirements to enhance early detection,
particularly in vulnerable areas, and to ensure rapid repair and remediation.
d. Require monitoring and reporting of MTBE and other ethers in groundwater at
all UST release sites.
e. Encourage states to require that the proximity to drinking water supplies, and the
potential to impact those supplies, be considered in land-use planning and
permitting decisions for siting of new UST facilities and petroleum pipelines.
f. Implement and/or expand programs to train and license UST system installers
and maintenance personnel.
g. Work with Congress to examine and, if needed, expand the universe of regulated
tanks to include underground and aboveground fuel storage systems that are not
currently regulated yet pose substantial risk to drinking water supplies.
2. EPA should work with its state and local water supply partners to enhance
implementation of the Federal and State Safe Drinking Water Act programs to:
a. Accelerate, particularly in those areas where RFG or Oxygenated Fuel is used,
the assessments of drinking water source protection areas required in Section
1453 of the Safe Drinking Water Act, as amended in 1996.
b. Coordinate the Source Water Assessment program in each state with federal and
state Underground Storage Tank Programs using geographic information and
other advanced data systems to determine the location of drinking water sources
and to identify UST sites within source protection zones.
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c. Accelerate currently-planned implementation of testing for and reporting of
MTBE in public drinking water supplies to occur before 2001.
d. Increase ongoing federal, state, and local efforts in Wellhead Protection Areas
including:
- enhanced permitting, design, and system installation requirements for
USTs and pipelines in these areas;
- strengthened efforts to ensure that non-operating USTs are properly
closed;
- enhanced UST release prevention and detection; and
- improved inventory management of fuels.
3. EPA should work with states and localities to enhance their efforts to protect lakes and
reservoirs that serve as drinking water supplies by restricting use of recreational water
craft, particularly those with older motors.
4. EPA should work with other federal agencies, the states, and private sector partners to
implement expanded programs to protect private well users, including, but not limited to:
a. A nationwide assessment of the incidence of contamination of private wells by
components of gasoline as well as by other common contaminants in shallow
groundwater;
b. Broad-based outreach and public education programs for owners and users of
private wells on preventing, detecting, and treating contamination; and
c. Programs to encourage and facilitate regular water quality testing of private
wells.
5. Implement, through public-private partnerships, expanded Public Education programs at
the federal, state, and local levels on the proper handling and disposal of gasoline.
6. Develop and implement an integrated field research program into the groundwater
behavior of gasoline and oxygenates, including:
a. Identifying and initiating research at a population of UST release sites and
nearby drinking water supplies including sites with MTBE, sites with ethanol,
and sites using no oxygenate; and
b. Conducting broader, comparative studies of levels of MTBE, ethanol, benzene,
and other gasoline compounds in drinking water supplies in areas using primarily
MTBE, areas using primarily ethanol, and areas using no or lower levels of
oxygenate.
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Treatment and Remediation
7. EPA should work with Congress to expand resources available for the up-front funding
of the treatment of drinking water supplies contaminated with MTBE and other gasoline
components to ensure that affected supplies can be rapidly treated and returned to
service, or that an alternative water supply can be provided. This could take a number of
forms, including but not limited to:
a. Enhancing the existing Federal Leaking Underground Storage Tank Trust Fund
by fully appropriating the annual available amount in the Fund, ensuring that
treatment of contaminated drinking water supplies can be funded, and
streamlining the procedures for obtaining funding;
b. Establishing another form of funding mechanism which ties the funding more
directly to the source of contamination; and
c. Encouraging states to consider targeting State Revolving Funds (SRF) to help
accelerate treatment and remediation in high priority areas.
8. Given the different behavior of MTBE in groundwater when compared to other
components of gasoline, states in RFG and Oxyfuel areas should reexamine and enhance
state and federal "triage" procedures for prioritizing remediation efforts at UST sites
based on their proximity to drinking water supplies.
9. Accelerate laboratory and field research, and pilot projects, for the development and
implementation of cost-effective water supply treatment and remediation technology, and
harmonize these efforts with other public/private efforts underway.
Recommendations for Blending Fuel for Clean Air and Water
Based on its review of the current water protection programs, and the likely progress that can be made in
tightening and strengthening those programs by implementing Recommendations 1-9 above, the Panel
agreed broadly, although not unanimously, that even enhanced protection programs will not give
adequate assurance that water supplies will be protected, and that changes need to be made to the RFG
program to reduce the amount of MTBE being used, while ensuring that the air quality benefits of RFG,
and fuel supply and price stability, are maintained.
Given the complexity of the national fuel system, the advantages and disadvantages of each of the fuel
blending options the Panel considered (see Appendix A), and the need to maintain the air quality benefits
of the current program, the Panel recommends an integrated package of actions by both Congress and
EPA that should be implemented as quickly as possible. The key elements of that package, described in
more detail below, are:
Action agreed to broadly by the Panel to reduce the use of MTBE substantially (with
some members supporting its complete phase-out), and action by Congress to clarify
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federal and state authority to regulate and/or eliminate the use of gasoline additives that
threaten drinking water supplies;
Action by Congress to remove the current 2 percent oxygen requirement to ensure that
adequate fuel supplies can be blended in a cost-effective manner while quickly reducing
usage of MTBE; and
Action by EPA to ensure that there is no loss of current air quality benefits.
The Oxygen Requirement
10. The current Clean Air Act requirement to require 2 percent oxygen, by weight, in RFG
must be removed in order to provide flexibility to blend adequate fuel supplies in a cost-
effective manner while quickly reducing usage of MTBE and maintaining air quality
benefits.
The Panel recognizes that Congress, when adopting the oxygen requirement, sought to
advance several national policy goals (energy security and diversity, agricultural policy,
etc) that are beyond the scope of our expertise and deliberations.
The Panel further recognizes that if Congress acts on the recommendation to remove the
requirement, Congress will likely seek other legislative mechanisms to fulfill these other
national policy interests.
Maintaining Air Benefits
11. Present toxic emission performance of RFG can be attributed, to some degree, to a
combination of three primary factors: (1) mass emission performance requirements; (2)
the use of oxygenates; and (3) a necessary compliance margin with a per gallon standard.
In Cal RFG, caps on specific components of fuel is an additional factor to which toxics
emission reductions can be attributed.
Outside of California, lifting the oxygen requirement as recommended above may lead to
fuel reformulations that achieve the minimum performance standards required under the
1990 Act, rather than the larger air quality benefits currently observed. In addition,
changes in the RFG program could have adverse consequences for conventional gasoline
as well.
Within California, lifting the oxygen requirement will result in greater flexibility to
maintain and enhance emission reductions, particularly as California pursues new
formulation requirements for gasoline.
In order to ensure that there is no loss of current air quality benefits, EPA should seek
appropriate mechanisms for both the RFG Phase II and Conventional Gasoline programs
to define and maintain in RFG II the real world performance observed in RFG Phase I
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while preventing deterioration of the current air quality performance of conventional
gasoline.32
There are several possible mechanisms to accomplish this. One obvious way is to
enhance the mass-based performance requirements currently used in the program. At the
same time, the Panel recognizes that the different exhaust components pose differential
risks to public health due in large degree to their variable potency. The Panel urges EPA
to explore and implement mechanisms to achieve equivalent or improved public health
results that focus on reducing those compounds that pose the greatest risk.
Reducing the Use of MTBE
12. The Panel agreed broadly that, in order to minimize current and future threats to drinking
water, the use of MTBE should be reduced substantially. Several members believed that
the use of MTBE should be phased out completely. The Panel recommends that
Congress act quickly to clarify federal and state authority to regulate and/or eliminate the
use of gasoline additives that pose a threat to drinking water supplies.33
32 The Panel is aware of the current proposal for further changes to the sulfur levels of gasoline and recognizes
that implementation of any change resulting from the Panel's recommendations will, of necessity, need to be
coordinated with implementation of these other changes. However, a majority of the Panel considered the
maintenance of current RFG air quality benefits as separate from any additional benefits that might accrue from the
sulfur changes currently under consideration.
33 Under §211 of the 1990 Clean Air Act, Congress provided EPA with authority to regulate fuel formulation
to improve air quality. In addition to EPA's national authority, in §211(c)(4) Congress sought to balance the desire for
maximum uniformity in our nation's fuel supply with the obligation to empower states to adopt measures necessary to meet
national air quality standards. Under §21 l(c)(4), states may adopt regulations on the components of fuel, but must demonstrate
that 1) their proposed regulations are needed to address a violation of the NAAQS and 2) it is not possible to achieve the desired
outcome without such changes.
The Panel recommends that Federal law be amended to clarify EPA and state authority to regulate and/or eliminate
gasoline additives that threaten water supplies. It is expected that this would be done initially on a national level to maintain
uniformity in the fuel supply. For further action by the states, the granting of such authority should be based upon a similar two
part test:
1) states must demonstrate that their water resources are at risk from MTBE use, above and beyond the risk posed by
other gasoline components at levels of MTBE use present at the time of the request.
2) states have taken necessary measures to restrict/eliminate the presence of gasoline in the water resource.
To maximize the uniformity with which any changes are implemented and minimize impacts on cost and
fuel supply, the Panel recommends that EPA establish criteria for state waiver requests including but not
limited to:
a. Water quality metrics necessary to demonstrate the risk to water resources and air quality metrics
to ensure no loss of benefits from the federal RFG program.
b. Compliance with federal requirements to prevent leaking and spilling of gasoline.
c. Programs for remediation and response.
d. A consistent schedule for state demonstrations, EPA review, and any resulting regulation of the
volume of gasoline components in order to minimize disruption to the fuel supply system.
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Initial efforts to reduce should begin immediately, with substantial reductions to begin as
soon as Recommendation 10 above - the removal of the 2 percent oxygen requirement -
is implemented34. Accomplishing any such major change in the gasoline supply without
disruptions to fuel supply and price will require adequate lead time - up to 4 years if the
use of MTBE is eliminated, sooner in the case of a substantial reduction (e.g. returning
to historical levels of MTBE use).
The Panel recommends, as well, that any reduction should be designed so as to not result
in an increase in MTBE use in Conventional Gasoline areas.
13. The other ethers (e.g. ETBE, TAME, and DIPE) have been less widely used and less
widely studied than MTBE. To the extent that they have been studied, they appear to
have similar, but not identical, chemical and hydrogeologic characteristics. The Panel
recommends accelerated study of the health effects and groundwater characteristics of
these compounds before they are allowed to be placed in widespread use.
In addition, EPA and others should accelerate ongoing research efforts into the
inhalation and ingestion health effects, air emission transformation byproducts, and
environmental behavior of all oxygenates and other components likely to increase in the
absence of MTBE. This should include research on ethanol, alkylates, and aromatics, as
well as of gasoline compositions containing those components.
14. To ensure that any reduction is adequate to protect water supplies, the Panel recommends
that EPA, in conjunction with USGS, the Departments of Agriculture and Energy,
industry, and water suppliers, should move quickly to:
a. Conduct short-term modeling analyses and other research based on existing data
to estimate current and likely future threats of contamination;
b. Establish routine systems to collect and publish, at least annually, all available
monitoring data on:
- use of MTBE, other ethers, and Ethanol;
- levels of MTBE, Ethanol, and petroleum hydrocarbons found in ground,
surface and drinking water;
- trends in detections and levels of MTBE, Ethanol, and petroleum
hydrocarbons in ground and drinking water;
c. Identify and begin to collect additional data necessary to adequately assess the
current and potential future state of contamination.
The Wintertime Oxyfuel Program
34 Although a rapid, substantial reduction will require removal of the oxygen requirement, EPA should, in
order to enable initial reductions to occur as soon as possible, review administrative flexibility under existing law to
allow refiners who desire to make reductions to begin doing so.
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The Wintertime Oxyfuel Program continues to provide a means for some areas of the country to
come into, or maintain, compliance with the Carbon Monoxide standard. Only a few
metropolitan areas continue to use MTBE in this program. In most areas today, ethanol can and
is meeting these wintertime needs for oxygen without raising volatility concerns given the
season.
15. The Panel recommends that the Wintertime Oxyfuel program be continued (a) for as
long as it provides a useful compliance and/or maintenance tool for the affected states
and metropolitan areas, and (b) assuming that the clarification of state and federal
authority described above is enacted to enable states, where necessary, to regulate and/or
eliminate the use of gasoline additives that threaten drinking water supplies.
Recommendations for Evaluating and Learning From Experience
The introduction of reformulated gasoline has had substantial air quality benefits, but has at the same
time raised significant issues about the questions that should be asked before widespread introduction of
a new, broadly-used product. The unanticipated effects of RFG on groundwater highlight the importance
of exploring the potential for adverse effects in all media (air, soil, and water), and on human and
ecosystem health, before widespread introduction of any new, broadly-used, product.
16. In order to prevent future such incidents, and to evaluate of the effectiveness and the
impacts of the RFG program, EPA should:
a. Conduct a full, multi-media assessment (of effects on air, soil, and water) of any
major new additive to gasoline prior to its introduction;
b. Establish routine and statistically valid methods for assessing the actual
composition of RFG and its air quality benefits, including the development, to
the maximum extent possible, of field monitoring and emissions characterization
techniques to assess "real world" effects of different blends on emissions;
c. Establish a routine process, perhaps as a part of the Annual Air Quality trends
reporting process, for reporting on the air quality results from the RFG program;
and
Build on existing public health surveillance systems to measure the broader
impact (both beneficial and adverse) of changes in gasoline formulations on
public health and the environment.
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Appendix A
In reviewing the RFG program, the Panel identified three main options (MTBE and other ethers, ethanol,
and a combination of alkylates and aromatics) for blending to meet air quality requirements. They
identified strength and weaknesses of each option:
MTBE/other ethers A cost-effective fuel blending component that provides high octane, carbon
monoxide and exhaust VOCs emissions benefits, and appears to contribute to
reduction of the use of aromatics with related toxics and other air quality
benefits; has high solubility and low biodegradability in ground water, leading to
increased detections in drinking water, particularly in high MTBE use areas.
Other ethers, such as ETBE, appear to have similar, but not identical, behavior in
water, suggesting that more needs to be learned before widespread use.
Ethanol An effective fuel-blending component, made from domestic grain and potentially from
recycled biomass, that provides high octane, carbon monoxide emission benefits, and
appears to contribute to reduction of the use of aromatics with related toxics and other
air quality benefits; can be blended to maintain low fuel volatility; could raise possibility
of increased ozone precursor emissions as a result of commingling in gas tanks if ethanol
is not present in a majority of fuels; is produced currently primarily in Midwest,
requiring enhancement of infrastructure to meet broader demand; because of high
biodegradability, may retard biodegradation and increase movement of benzene and
other hydrocarbons around leaking tanks.
Blends of Alkylates Effective fuel blending components made from crude oil; alkylates
and Aromatics provide lower octane than oxygenates; increased use of aromatics will likely
result in higher air toxics emissions than current RFG; would require
enhancement of infrastructure to meet increased demand; have groundwater
characteristics similar, but not identical, to other components of gasoline (i.e.
low solubility and intermediate biodegradability).
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CHAPTER 4. DISSENTING OPINIONS
State of Nebraska. Nebraska Ethanol Board
Oxygen Standard Should Be Maintained
Insufficient Evidence to Support Recommendation to Remove Oxygen Standard
Blue Ribbon Panel Dissenting Opinion
Submitted for the Record By
Todd C. Sneller, Panel Member
In its report regarding the use of oxygenates in gasoline, a majority of the Blue Ribbon Panel on
Oxygenates in Gasoline (BRP) has based its recommendation to support removal of the oxygen standard
on several conclusions which I believe to be inaccurate:
1). That aromatics can be used as a safe and effective replacement for oxygenates without
resulting in deterioration in VOC and air toxic emissions. In fact, a review of the legislative
history behind the passage of the Clean Air Act Amendments of 1990 clearly shows that Congress
found the increased use of aromatics to be harmful to human health and intended that their use in
gasoline be reduced as much as technically feasible.
2). That oxygenates fail to provide overwhelming air quality benefits associated with their
required use in gasoline. The BRP recommendations do not accurately reflect the benefits
provided by the use of oxygenates in reformulated gasoline. Congress correctly saw a minimum
oxygenate requirement as a cost effective means to both reduce levels of harmful aromatics and
help rid the air we breathe of harmful pollutants.
3). That the BRP recommendation to urge removal of the oxygen standard does not fully take
into account other public policy objectives specifically identified during Congressional debate on
the 1990 CAAA. While projected benefits related to public health were a focal point during the
debate in 1990, energy security, national security, the environment and economic impacts of the
Amendments were clearly part of the rationale for adopting such amendments. It is my belief that
the rationale behind adoption of the Amendments in 1990 is equally valid, if not more so, today.
As Congress debated the Reformulated Gasoline (RFG) provisions of the Clean Air Act Amendments of
1990, it became clear that aromatics (e.g. benzene, xylene, and toluene) added to gasoline were extremely
toxic, and lead to the further deterioration of U.S. air quality. To specifically reduce aromatic levels in
RFG - and help remove harmful air toxics from the air - an overwhelming bi-partisan majority of
Congress specifically required the addition of cleaner burning oxygenates to gasoline. As stated in the
record, a primary purpose behind the addition of oxygenates to gasoline was the reduction in carbon
monoxide emissions in winter, ozone formation in summer, and air toxic emissions year-round.
Recognizing the harmful effects increased aromatic use has on public health, Senate Democratic Leader
Tom Daschle (D-SD), a primary sponsor of the RFG provision, said on March 29, 1990;
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"The primary aromatics used in gasoline are benzene, toluene and xylene, all of which
are EPA-listed hazardous chemicals. The amount of benzene emitted from the tailpipe is
directly related to the amount of benzene found in gasoline. However, a gasoline can
have no benzene and still produce benzene exhaust because of the chemical
transformation that toluene and xylene undergo during the combustion process" .."The
most significant single step that can be taken to improve urban air quality is to limit
aromatic content in gasoline" (Emphasis added)
Echoing that Congressional sentiment, Senator Tom Harkin (D-IA) said;
"The aromatic hydrocarbons in gasoline include benzene, toluene, and xylene. Benzene
is a known carcinogen, one of the worst air toxics. Eighty-five percent of all benzene in
the air we breathe comes from motor vehicle exhaust. Xylene, another aromatic, is
highly photoreactive - meaning that it forms ozone very rapidly in sunlight. Xylene from
automobile exhaust in the morning rush hour forms ozone in sunlight to choke our lungs
by the afternoon trip home. Toluene, another aromatic, usually forms benzene during the
combustion process, and thus becomes carcinogenic along with benzene in the gasoline.
Today, about 33 percent of gasoline is composed of aromatics by volume... Worse yet,
the aromatics tend to reduce the effectiveness of catalytic converters... .By reducing the
amount of aromatics by volume, you substantially reduce the amount of carbon
monoxide, hydrocarbons, and nitrogen oxide emitted into the atmosphere...Fortunately,
there are other choices than aromatics to maintain octane level in gasoline. Guess what
they are? The oxygenated fuel additives"
"... Fuels high in aromatics cause deposits in the combustion chamber interfering with
combustion and increasing emissions. Aromatics have higher carbon content than the
rest of gasoline, so gasoline high in aromatics contributes more to global warming.
Aromatics were only about 20 percent of fuel in 1970, but percentages have increased
substantially because the aromatics have been used to replace the octane that was lost as
a result of the lead phase-down." (emphasis added)
The refining industry has informed the BRP that it will, in fact, increase use of aromatics in gasoline if
the oxygenate provisions of the RFG program are removed. The BRP recommendations further state that,
in most instances, oxygenates can be "effectively" replaced by aromatics. This position is directly
counter to the vast weight of evidence on the harmful effects of aromatics and the positive air quality
effects of oxygenates. Further, it is in direct conflict with the clear intent of Congress to improve U.S. air
quality by restricting use of aromatics.
The BRP has not heard evidence supporting the "safe and effective" use of increased levels of aromatics
in gasoline. In fact, according to evidence presented to the BRP on March 1-2, 1999, by William J. Piel,
Technical Director of the Clean Fuels Development Coalition (CFDC), increased use of aromatics will
lead directly to increases in air toxic emissions, exhaust VOC emissions, combustion chamber deposits,
carbon monoxide emissions, and worsen fuel factors contributing to vehicle performance (i.e. the
driveability index). Use of aromatics will also increase VOC emissions at both stationary and mobile
sources.
In fact, the BRP majority's apparent willingness to accept higher aromatic levels runs directly counter to
Congressional intent. In his October 27, 1990 statement in support of the CAAA Conference report,
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Senate Environment and Public Works Committee member David Durenberger stated that the
performance standard for post-2000 RFG should logically lead to a 25 percent or lower cap on aromatics.
According to Durenberger;
"The so-called formula gasoline which contains a cap on benzene at one percent and a
cap on aromatics at 25 percent should achieve substantial reductions in the aggregate
amounts of the five [toxic] pollutants... After the year 2000, the situation is different
because the Administrator is to choose the performance standard for toxics which
reflects the maximum reduction in toxic emissions that is feasible taking cost into
account. The formula gasoline may well achieve a reduction in toxics which exceeds 20
percent, and if so, whatever it does achieve would be a floor for the performance
standards after the year 2000 (emphasis added). In this Senator's view, controls on
benzene and aromatics more stringent than those in the formula gasoline are certainly
feasible... The performance standards and the formula stated explicitly in the legislation
are only minimum requirements."
As a Nebraska state official and Panel member, I find it troubling that the majority of the BRP members
have chosen to ignore such evidence as well as the clear intent of Congress in its recommendation to
remove the oxygenate standard from RFG. It also concerns me that the BRP recommendation regarding
the oxygenate standard will likely lead directly to the increased use of aromatics - compounds
universally condemned for their harmful effects on air quality.
Finally, the legislative history clearly shows that Congress specifically required the use of oxygenates in
gasoline for other important public policy goals: national energy security through the reduction in oil
imports; and, stimulating domestically produced renewable fuels made from agricultural products.
As Sen. Harkin stated;
"[Use of oxygenates] will reduce our health care costs. We can have reduced farm
support costs. And reduced oil imports. By lowering reformer severity and aromatics
content as a means of achieving octane, and replacing it with high octane oxygenates,
you conserve large quantities of oil in two ways - first, savings in gasoline because of
the lower severity of the refining operation of the base gasoline; and second, straight
physical displacement of gasoline by oxygenates. This amendment will save millions of
barrels of oil every year."
And in a May 2, 1990 "Dear Colleague" letter, Representatives Bill Richardson (now Energy Secretary)
and Ed Madigan urged their colleagues to support the House version of the Daschle-Dole RFG provision.
They wrote;
"Cleaner gasoline also slashes foreign imports. Today's gasoline relies on imported
aromatic compounds. When we replace these compounds with domestically produced
alcohols and ethers made from corn, wheat, barley and other crops, we shift trade from
OPEC to our farmers. According to the GAO, this new market could save taxpayers over
$1.2 billion that is now spent annually on farm price supports."
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These and other references make it clear that Congress thoughtfully considered and debated the benefits
of reducing aromatics and requiring the use of oxygenates in RFG. Based on the weight of evidence
presented to the BRP, I remain convinced that maintenance of the oxygenate standard is necessary to
ensure cleaner air and a healthier environment. I am also convinced that water quality must be better
protected through significant improvements to gasoline storage tanks and containment facilities.
Therefore, because it is directly counter to the weight of the vast majority of scientific and technical
evidence and the clear intent of Congress, I must respectfully disagree with the BRP
recommendation that the oxygenate provisions of the RFG Program be removed. I also request that
the final report from the BRP include a recommendation to place a cap on the use of aromatics in
gasoline at 25 percent by volume, in keeping with the Panel's commitment to preserve air quality
improvements.
Todd Sneller serves as Administrator of the Nebraska Ethanol Board, a state agency. He is the past
chairman of the Clean Fuels Development Coalition, and currently serves as the Nebraska
representative of the 22 state Governors' Ethanol Coalition. Mr. Sneller was appointed to the EPA
Blue Ribbon Panel in December 1998.
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Lyondell Chemical Company's Dissenting Report
Summary
While the Panel is to be commended on a number of good recommendations to improve the current
underground storage tank regulations and reduce the improper use of gasoline, the Panel's
recommendations to limit the use of MTBE are not justified.
Unfortunately, there appears to be an emotional rush to judgement regarding the use of MTBE. The
recommendation to reduce the use of MTBE substantially is unwarranted for the following four reasons:
Firstly, the Panel was charged to review public health effects posed by the use of oxygenates, particularly
with respect to water contamination. The Panel did not identify any increased public health risk
associated with MTBE use in gasoline.
Secondly, no quantifiable evidence was provided to show the environmental risk to drinking water from
leaking underground storage tanks (LUST) will not be reduced to manageable levels once the 1998
LUST regulations are fully implemented and enforced. The water contamination data relied upon by the
Panel is largely misleading because it predates the implementation of the LUST regulations.
Thirdly, the recommendations will not preserve the air quality benefits achieved with oxygenate use in
the existing RFG program. The air quality benefits achieved by the RFG program will be degraded
because they fall outside the control of EPA's Complex Model used for RFG regulations and because the
alternatives do not match all of MTBE's emission and gasoline quality improvements.
Lastly, the Panel's recommendation options depend upon the use of alternatives that have not been
adequately studied for air quality and health risk impacts. These alternatives will also impose an
unnecessary additional cost of 1 to 3 billion dollars per year (3-7 c/gal. RFG) on consumers and society
without quantifiable offsetting social benefits or avoided costs with respect to water quality in the future.
Discussion of Issues
No increase in public health risk associated with the use of MTBE has been identified.
Based on the Panel's review of the available health studies, the Panel did not identify any increased
health risk associated with MTBE's normal use in gasoline and the Panel's review is best summarized by
the following paragraph from the Issue Summary E, "Comparing the Fuel Additives."
"In terms of neurotoxicity and reproductive effects, inhalation toxicity testing to date generally has not
shown MTBE to be any more toxic than other components of gasoline. At very high doses, MTBE has
caused tumors in two species of rat and one species of mouse at a variety of sites; it is uncertain,
however, whether these effects can be extrapolated to humans. The International Agency for Research
on Cancer (IARC) and the National Institute of Environmental Health Sciences (NIEHS) have indicated
that at this time there are not adequate data to consider MTBE a probable or known human carcinogen."
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No quantifiable evidence has been provided to show that full compliance with the 1998 LUST
regulations will not achieve its purpose of substantially reducing the release of gasoline, and
thereby MTBE, from UST systems today and in the future.
The Panel states that enhanced UST programs will not give adequate assurance that water supplies will
be protected. However, this statement is made without any quantifiable analysis or support. The facts
are that most MTBE detects are very low level concentrations and have occurred prior to UST systems
being upgraded to meet the 1998 deadlines. The MTBE detection data presented to the Panel by the
USGS was collected between 1988 and 1998 when most UST systems were still out of compliance. In
addition, data summarized by the Association of State and Territorial Solid Waste Management Officials
(ASTSWMO) shows that less than 50 percent of all UST's were in compliance prior to 1998 and that as
recent as 1996 only 30 percent were in compliance.35 Therefore, the detection data reflects a time period
before most of the underground tanks were upgraded.
In addition, the risk of drinking water contamination by MTBE and other gasoline constituents has been
greatly reduced with the onset of LUST regulation compliance. The UC Davis study36 which was
presented to the PANEL estimates that tank failure rates (leak occurrences) decrease by over 95 percent
(from 2.6 percent failures per year for non-upgraded tanks to 0.07 percent per year for upgraded tanks)
once UST systems are upgraded to meet the current LUST regulations. Also, with the required
installation of early leak detection monitoring, the time between when a leak occurs and when it is
detected will now be significantly reduced. As a result, the amount of gasoline released from a new
leaking site before it has been remediated is substantially minimized. Both of these effects combined
should lead to substantial reductions (orders of magnitude) in the amount of gasoline and MTBE that
escapes undetected from the UST population which therefore makes it a much more manageable situation
for protecting drinking water supplies.
The recommendations fail to recognize the full emission benefits from using MTBE and oxygenates
in RFG, and that the alternatives do not equal the emission reductions and combustion enhancing
blending properties of MTBE in gasoline. Therefore, a reduction in MTBE use will result in a net
loss in air quality.
Although the Panel was charged with "examining the role of oxygenates in meeting the nation's goal of
clean air" and "evaluating each product's efficiency in providing clean air benefits and the existence of
alternatives," the Panel did not identify and quantify all the emission benefits realized when oxygenates
are used to make cleaner burning and low polluting gasolines. Neither was the Panel able to identify
combinations of alternatives that could match both the emission reductions and the combustion
enhancing blending properties of MTBE in gasoline. The Panel did not recognize the fact that the simple
use of oxygenates along with a vapor pressure reduction were the only requirements used to achieve the
ozone precursor reduction goals in the first three years of a very successful RFG program.37 Since all
other alternatives have one or more inferior properties as compared to MTBE in gasoline, it would be
difficult if not nearly impossible to achieve the same real air quality efficiency provided by MTBE. And
35 Sausville, Paul, Dale Marx and Steve Crimaudo: A Preliminary State Survey with Estimates based on a
Survey of 17 State databases of early 1999. ASTSWMO UST Task Force, 11th Annual EPA UST/LUST National
Conference, March 15-17, 1999. Daytona Beach, Florida.
36 Keller, Arturo, et. al. Health & Environmental Assessment of MTBE. Report to the Governor and
Legislature of the State of California as Sponsored by SB 521. November 1998.
37 "Overview of Fuel Oxygenate Development", William J. Piel For Lyondell Chemical Co., Presentation to
the EPA's Blue Ribbon Panel, January 22, Arlington, VA.
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since sulfur reductions are also expected to occur under other fuel regulations, it would be a double-
accounting of emissions benefits if sulfur reductions in RFG are to be used to compensate or make-up for
any increase of emissions resulting from reduced oxygenate use in RFG.
Beyond reducing VOC's, NOX and toxics, improving gasoline properties through the use of oxygenates
reduce many other vehicles pollutants such as CO (carbon monoxide), PM (particulate matter) and CO2
(carbon dioxide) as well as the ozone reactivity of VOC's. Also, gasoline property changes associated
with oxygenate use in RFG provide additional emission reductions of VOC, NOX, toxics and CO (an
ozone precursor) over the life of the vehicle by lowering combustion chamber deposits and therefore the
vehicle's emissions deterioration rates overtime. Since none of these additional emission reductions are
reflected or controlled in EPA's Complex Emissions Model used for RFG, reducing MTBE in RFG will
result in a loss of these extra emission benefits.38
Unfortunately, the Panel recommendations limit themselves to only meeting the regulatory requirements
established in EPA's existing RFG rules and did not focus on capturing all the real world emission
benefits associated with MTBE's use in RFG. Though the Panel recommends reducing the use of
oxygenates in RFG, they failed to explain how equivalent air quality is to be maintained when the only
identifiable fuel alternatives cannot match all of MTBE's emission reductions and combustion enhancing
blending properties in gasoline. Therefore, replacing MTBE with the alternatives under the current
recommendations will contribute to a net loss in air quality with regards to Peak Ozone levels, PM, toxics
and CO2 (greenhouse gas) in addition to higher costs.
Alternatives have not been adequately studied for their health risk impacts, availability or their
cost effectiveness in RFG
From a scientific, policy, and political perspective, no one should rush to judgement on MTBE without a
thorough evaluation of the alternatives. The Panel cannot afford to be wrong about MTBE's benefits or
deficiencies. As a matter of sound public policy, any alternative needs to be held up to the same rigorous
examination as MTBE, while adhering to the following criteria.
To assure the public that any alternative will produce the same real air quality benefits as MTBE.
That any alternative will be abundantly and economically available.
That any alternative will not be a probable or known human carcinogen nor increase the risks to
human health.
These criteria are consistent with the Panel's recommendation to investigate more fully any major new
additives to gasoline prior to its introduction and therefore should equally apply to the alternatives
already identified by the Panel, namely Ethanol, Alkylates, and Aromatics. The expanded use of these
alternatives should not occur without a more rigorous analysis of the impacts on health, air quality, and
water quality as well as their availability and costs.
38 "Staff Report: Proposed Amendments to the California Regulation Requiring Deposit Control Additives in
the Motor Vehicle Gasoline" Calif. Environ. Protection Agency, Air Resources Board, Aug 7, 1998; "Benefits of
the Federal RFG Program And Clean Burning Fuels with Oxygenates", William J. Piel of Lyondell Chemical Co.,
Presentation to EPA Blue Ribbon Panel, March 1, 1999, Boston.
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LIST OF PANEL MEMBERS AND PARTICIPANTS
Members of the Blue Ribbon Panel
Dan Greenbaum, Health Effects Institute, Chair
President
Health Effects Institute
955 Massachusetts Ave.
Cambridge, MA 02139
(617) 876-6700
Fax: (617) 876-6709
dgreenbaum@healtheffects.org
Mark Beuhler, Metropolitan Water District, So. California
Director of Water Quality
Metropolitan Water District of Southern California
P.O. Box 54153
Los Angeles, CA 90071
(213)217-6647
Fax: (213)217-6951
mbeuhler@mwd.dst.ca.us
Robert Campbell, CEO, Sun Oil
Chairman and CEO
Sunoco, Inc.
1801 Market Street
Philadelphia, Pennsylvania 19103-1699
(215) 977-3871
Fax: (215) 977-3559
ann_l_williams@sunoil.com
Patricia Ellis, Delaware Department of Natural Resources and Environmental Control
Hydrologist
Delaware Department of Natural Resources and Environmental Control
Air and Waste Management Division
391 Lukens Drive
New Castle, DE 19720
(302) 395-2500
Fax: (302) 395-2601
pellis@dnrec.state.de .us
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Linda Greer, Natural Resources Defense Council
Senior Scientist
Natural Resources Defense Council
1350 New York Ave., N.W.
Washington, D.C. 20005
(202) 289-6868
Fax: (202) 289-1060
lgreer@nrdc.org
Jason Grumet, NESCAUM
Executive Director
NESCAUM
129 Portland Street
Boston, MA 02114
(617)367-8540, ext. 216
Fax: (617) 742-9162
j grumet@ne scaum.org
Anne Happel, Lawrence Livermore National Laboratory
Environmental Scientist
Lawrence Livermore National
Laboratory, L-542
7000 East Avenue
Livermore, CA 94550
(925) 422-1425
Fax (925) 422-9203
happell@llnl.gov
Carol Henry, American Petroleum Institute
Director, Health and Environmental Sciences
American Petroleum Institute
1220 L Street, N.W.
Washington, D.C. 20005-4070
(202) 682-8308
Fax: (202) 682-8270
henry cj @api .org
Michael Kenny, California Air Resources Board
Executive Officer
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812
(916)445-4383
Fax:(916)322-6003
mkenny@arb .ca.gov
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Robert Sawyer, University of California, Berkeley
Professor, Graduate School
Mechanical Engineering Department
University of California at Berkeley
72 Hesse Hall
Berkeley, CA 94720-1740
(510)642-5573
Fax: (510)642-1850
rsawyer@newton.berkeley.edu
Todd Sneller, Nebraska Ethanol Board
Executive Director
Nebraska Ethanol Board
301 Centennial Mall South
Fourth Floor
Lincoln, NE 69509
(402)471-2941
Fax: (402)471-2470
sneller@nrcdec .nrc . state .ne .us
Debbie Starnes, Lyondell Chemical
Senior Vice President, Intermediate Chemical
Lyondell Chemical Company
1221 McKinney Street, Suite 1600
Houston, TX 770 10
(713) 652-7370
Fax: (713) 652-4538
debbie.starnes@lyondellchem.com
Ron White, American Lung Association
Director, National Programs
American Lung Association
1726MSt.,NW
Suite 902
Washington, DC 20036
(202) 785-3355
Fax: (202)452-1805
rwhite@lungusa.org
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Federal Representatives (Non-Voting):
Robert Perciasepe, Air and Radiation, US Environmental Protection Agency
Assistant Administrator
Office of Air and Radiation
US Environmental Protection Agency
401M Street, SW
Washington, DC 20460
(202) 260-7400
Fax: (202)260-5155
perciasepe.robert@epa.gov
Roger Conway, US Department of Agriculture
Director, Office of Energy Policy and New Uses
U.S. Department of Agriculture
1800 M Street NW, Room 4129 N
Washington, DC 20036
(202) 694-5020
Fax: (202) 694-5665
rkconway@econ.ag.gov
Cynthia Dougherty, Drinking Water, US Environmental Protection Agency
Director, Office of Ground Water and Drinking Water
US Environmental Protection Agency
401M Street SW
Washington, DC 20460
(202) 260-5543
Fax (202) 260-4383
dougherty.cynthia@epa.gov
William Farland, Risk Assessment, US Environmental Protection Agency
Director, National Center for Environmental Assessment
Office of Research and Development
US Environmental Protection Agency
Washington, DC 20460
(202)564-3319
Fax (202) 565-0090
farland.william@epa.gov
Barry McNutt, US Department of Energy
Senior Policy Analyst
Department of Energy
1000 Independence Avenue
RoomH021
Washington, DC 20585
(202) 586-4448
Fax: (202)586-4447
barry.mcnutt@hq.doe .gov
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Margo Oge, Mobile Sources, US Environmental Protection Agency
Director, Office of Mobile Sources
Office of Air and Radiation
US Environmental Protection Agency
401M Street SW
Washington, DC 20460
(202) 260-7645
Fax (202) 260-3730
oge.margo@epa.gov
Sammy Ng, Underground Tanks, US Environmental Protection Agency
Acting Director, Office of Underground Storage Tanks
US Environmental Protection Agency
401M Street SW
Washington, DC 20460
(703) 603-9900
Fax (703) 603-0175
ng.sammy@epa.gov
Mary White, Agency for Toxic Substances and Disease Registry
Epidemiologist Chief
Health Investigations Branch
Agency for Toxic Substances and Disease Registry
1600 Clifton Road
Mail Stop E-31
Atlanta, GA 30333
(404) 639-6229
Fax (404) 63 9-6219
mxw5 Wcdc .gov
John Zogorski, US Geological Survey
Project Chief, National Water Quality Assessment Program
US Geological Survey
1608 Mountain View Road
Rapid City, SD 57702
(605)355-4560X214
Fax: (605)355-4523
j szogors@usgs .gov
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GLOSSARY OF TERMS
ACRONYMS
AQMD
AS
AST
ASTM
AWWARF
BTEX
Btu
CAA
CAAA
CAFE
CalEPA
CARB
CaRFG
CEC
CG
CUT
CO
CO2
CWSRF
DIPE
DOE
DOT
DWSRF
EIA
EPA
EPACT
ETBE
EIO
FCC
HC
HEI
IARC
ILEV
LEV
LLNL
LUST
MNA
MTBE
NAAQS
NAPL
Air Quality Management District
Air Sparging
Aboveground Storage Tank
American Society for Testing & Material
American Water Works Association Research Foundation
Benzene, Toluene, Ethylbenzene, and Xylene
British Thermal Unit
Clean Air Act
Clean Air Act Amendments of 1990
Corporate Average Fuel Economy
California Environmental Protection Agency
California Air Resources Board
California Reformulated Gasoline
California Energy Commission
Conventional Gasoline
Chemical Industry Institute of Toxicology
Carbon Monoxide
Carbon Dioxide
Clean Water State Revolving Fund
Di-isopropyl Ether
U.S. Department of Energy
U.S. Department of Transportation
Drinking Water State Revolving Fund
U.S. Energy Information Administration
U.S. Environmental Protection Agency
Energy Policy Act of 1992
Ethyl Tertiary Butyl Ether
10% Ethanol/90% Gasoline by volume
Fluid Catalytic Cracked
Hydrocarbons
Health Effects Institute
International Agency for Research on Cancer
Inherently Low Emission Vehicle
Low Emission Vehicle
Lawrence Livermore National Laboratory
Leaking Underground Storage Tank
Monitored Natural Attenuation
Methyl Tertiary Butyl Ether
National Ambient Air Quality Standards
Non-Aqueous Phase Liquid
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NAWQA National Water Quality Assessment Program
NESCAUM Northeast States for Coordinated Air Use Management
NMOG Non-Methane Organic Gases
NOX Oxides of Nitrogen
NRC National Research Council
OMS U.S. Environmental Protection Agency, Office of Mobile Sources
OSTP White House Office of Science and Technology
OUST U.S. Environmental Protection Agency, Office of Underground Storage Tanks
OXY Winter Oxyfuel Program
PADD Petroleum Administration for Defense Districts
PAN Peroxyacetyl Nitrate
PM Particulate Matter
POM Polycyclic Organic Matter
ppb Parts Per Billion
ppm Parts Per Million
psi Pounds Per Square Inch (pressure)
RBCA Risk-Based Corrective Action
RFC Reformulated Gasoline
RVP Reid Vapor Pressure
SDWA Safe Drinking Water Act
SIP State Implementation Plan
SPCC Spill Control and Counter Control
SULEV Super Ultra Low Emission Vehicle
SVE Soil Vapor Extraction
TAME Tertiary Amyl Methyl Ether
TBA Tertiary Butyl Alcohol
TLEV Transitional Low Emission Vehicle
ULEV Ultra Low Emission Vehicle
USDA U.S. Department of Agriculture
U.S. EPA U.S. Environmental Protection Agency
USGS United States Geological Survey
T50 50% Distillation Temperature
T90 90% Distillation Temperature
UST Underground Storage Tank
VOC Volatile Organic Compound
ZEV Zero Emission Vehicle
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TERMS
Additives: Chemicals added to fuel to improve and maintain fuel quality. Detergents and corrosion
inhibitors are examples of gasoline additives.
Air Toxics: Toxic air pollutants defined under Title II of the CAA, including benzene, formaldehyde,
acetaldehyde, 1.3 butadiene, and polycyclic organic matter (POM). Benzene is a constituent of
motor vehicle exhaust, evaporative, and refueling emissions. The other compounds are exhaust
pollutants.
Alcohols: Organic compounds that are distinguished from hydrocarbons by the inclusion of a hydroxl
group. The two simplest alcohols are methanol and ethanol.
Aldehydes: A class of organic compounds derived by removing the hydrogen atoms from an alcohol.
Aldehydes can be produced from the oxidation of an alcohol.
Alkanes: See Paraffins.
Alkylate: The product of an alkylation reaction. It usually refers to the high octane product from
alkylation units. This alkylate is used in blending high octane gasoline.
Aromatics: Hydrocarbons based on the ringed six-carbon benzene series or related organic groups.
Benzene, toluene, ethylbenzene, and xylene are the principal aromatics, commonly referred to as
the BTEX group. They represent one of the heaviest fractions in gasoline.
Attenuation: The reduction or lessening in amount (e.g., a reduction in the amount of contaminants in a
plume as it migrates away from the source). Attenuation occurs as a result of in-situ processes
(including biodegradation, dispersion, dilution, sorption, volatilization), and chemical or
biological stabilization, transformation, or destruction of contaminants.
Benzene: Benzene is a six-carbon aromatic that is common gasoline component. Benzene has been
identified as toxic and is a known carcinogen.
Biodegradation: A process by which microbial organisms transform or alter (through metabolic or
enzymatic action) the structure of chemicals introduced into the environment.
Biomass: Renewable organic matter, such as agricultural crops, crop-waste residues, wood, animal and
municipal wastes, aquatic plants, or fungal growth, used for the production of energy.
British Thermal Unit (Btu): A standard unit for measuring heat energy. One Btu represents the
amount of heat required to raise one pound of water one degree Fahrenheit (at sea level).
Butane: An easily liquefied gas recovered from natural gas. Used as a low-volatility component of
motor gasoline, processed further for a high-octane gasoline component, used in LPG for
domestic and industrial applications, and used as a raw material for petrochemical synthesis.
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Butyl Alcohol: Alcohol derived from butane that is used in organic synthesis and as a solvent.
CAA: The original Clean Air Act was signed in 1963, setting emissions standards for stationary sources.
The CAA was amended several times, most recently in 1990. The Amendments of 1970
introduced motor vehicle emission standards. Criteria pollutants included lead, ozone, CO, SO2,
NOX, and PM, as well as air toxics. In 1990, reformulated gasoline (RFG) and oxygenated
gasoline (OXY) provisions were added. The RFG provision requires use of RFG all year in
certain areas. The OXY provision requires the use of oxygenated gasoline during certain
months, when CO and ozone pollution are most serious. The regulations also require certain
fleet operators to use clean-fuel vehicles in 22 cities.
California Low Emissions Vehicle Program: State requirement for automakers to produce vehicles
with fewer emissions than current EPA standards. The five categories of the Program, from least
to most stringent are as follows: TLEV; LEV; ULEV; SULEV; and ZEV
Carcinogens: Chemicals and other substances known to cause cancer.
Distillation Curve: The percentages of gasoline that evaporate at various temperatures. The distillation
curve is an important indicator for fuel standards such as volatility (vaporization).
Ethanol: Can be produced chemically from ethylene or biologically from the fermentation of various
sugars or from carbohydrates found in agricultural crops and cellulosic residues from crops or
wood. Ethanol is used in the United States as a gasoline octane enhancer and oxygenate. It
increases octane 2.5 to 3.0 numbers at 10 percent concentration. Ethanol also can be used in
higher concentrations in alternative-fuel vehicles optimized for its use.
Ethers: A family of organic compounds composed of carbon, hydrogen, and oxygen. Ether molecules
consist of two alkyl groups linked to one oxygen atom. Light ethers such as ETBE, MTBE,
TAME, and DIPE have desirable properties as gasoline blendstocks and are used as oxygenates
in gasoline.
Ethyl Tertiary Butyl Ether (ETBE): An aliphatic ether similar to MTBE. This fuel oxygenate is
manufactured by reacting isobutylene with ethanol. Having high octane and low volatility
characteristics, ETBE can be added to gasoline up to a level of approximately 17 percent by
volume.
E10: Ethanol/gasoline mixture containing 10 percent denatured ethanol and 90 percent gasoline, by
volume.
Evaporative Emissions: Hydrocarbon vapors that escape from a fuel storage tank, a vehicle fuel tank,
or vehicle fuel system.
Exhaust Emissions: Materials that enter the atmosphere through the exhaust, or tailpipe, of a vehicle.
Exhaust emissions include carbon dioxide (and water vapor), carbon monoxide, unburned fuel,
products of incomplete combustion, fuel contaminants, and the combustion products of
lubricating oils.
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Feedstock: Any material converted to another form of fuel or energy product.
Fungible: A term used within the oil refining industry to denote products that are suitable for
transmission by pipeline.
Ground Water: The water contained in the pore spaces of saturated geologic media. Ground water can
be confined by overlying less permeable strata (confined aquifer) or open to the atmosphere
(water table or unconfmed aquifers).
In-situ: In its original place; unmoved; unexcavated; remaining in the subsurface.
Methyl Tertiary Butyl Ether (MTBE): An ether manufactured by reacting methanol and isobutylene.
The resulting ether has high octane and low volatility. MTBE is a fuel oxygenate and is
permitted in unleaded gasoline up to a level of 15 percent by volume.
National Ambient Air Quality Standards: Ambient standards for criteria air pollutants specifically
regulated under the CAA. These pollutants include ozone, particulate matter, carbon monoxide,
nitrogen dioxide, sulfur dioxide, and lead.
Neat Fuel: Fuel that is free from admixture or dilution with other fuels.
Neat Alcohol Fuel: Straight or 100 percent alcohol (not blended with gasoline), usually in the form of
either ethanol or methanol.
Nonattainment Area: A region, determined by population density in accordance with the U.S. Census
Bureau, which exceeds minimum acceptable NAAQS for one or more "criteria pollutants." Such
areas are required to seek modifications to their State Implementation Plans (SIPs), setting forth
a reasonable timetable using EPA-approved means to achieve attainment of NAAQS for these
criteria pollutants by a certain date. Under the CAA, if a nonattainment area fails to attain
NAAQS, EPA may superimpose a FIP with stricter requirements or impose fines, construction
bans, cutoffs in Federal grant revenues, etc., until the area achieves the applicable NAAQS.
Octane Enhancer: Any substance such as MTBE, ETBE, toluene, xylene and alkylates that is added to
gasoline to increase octane and reduce engine knock.
Oxyfuel Program: Nonattainment areas for carbon monoxide are required to use oxygenated fuel
during the winter season.
Oxygenate: A term used in the petroleum industry to denote fuel additives containing hydrogen, carbon,
and oxygen in their molecular structure. Includes ethers such as MTBE and ETBE and alcohols
such as ethanol and methanol.
Oxygenated Gasoline: Gasoline containing an oxygenate such as MTBE or ethanol. The increased
oxygen content may promote more complete combustion, thereby reducing tailpipe emissions of
CO.
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Paraffins: Also referred to as Alkanes, a group of chain saturated aliphatic hydrocarbons, including
methane, ethane, propane, butane, and alkanes (not including cycloalkanes).
Particulate Matter (PM): A generic term for a broad class of chemically and physically diverse
substances that exist as discrete particles (liquid droplets or solids) over a wide range of sizes; a
NAAQS pollutant.
Recalcitrant: Unreactive, nondegradable; refractory. Slowly degraded compounds.
Reformulated Gasoline (RFG): Gasolines that have had their compositions and/or characteristics
altered to reduce vehicular emissions of pollutants, particularly pursuant to EPA regulations
under the CAA.
Reid Vapor Pressure (RVP): A standard measurement of a liquid's vapor pressure in psi at 100 degrees
Fahrenheit. It is an indication of the propensity of the liquid to evaporate.
State Implementation Plan (SIP): Plan that a state must submit to EPA under the CAA to demonstrate
compliance to NAAQS.
Tertiary Amyl Methyl Ether (TAME): An ether based on reaction of C5 olefins and methanol.
Toluene: Basic aromatic compound derived from petroleum and used to increase octane. A
hydrocarbon commonly purchased for use in increasing octane.
Toxic Emission: Any pollutant emitted from a source that can negatively affect human health or the
environment.
Toxics: Pollutants defined by the CAAA, including benzene, formaldehyde, acetaldehyde, 1,3 butadiene,
and polycyclic organic material. Benzene is emitted both in exhaust and evaporative emissions;
the other compounds are exhaust emissions.
Volatile Organic Compounds (VOCs): Reactive gases released during combustion or evaporation of
fuel and regulated by EPA. VOCs react with NOX in the presence of sunlight and form ozone.
Volatilization: The process of transfer of a chemical from the aqueous or liquid phase to the gas phase.
Solubility, molecular weight, vapor pressure, mixing of the liquid, and the nature of the gas-
liquid interface affect the rate of volatilization.
Vapor Pressure or Volatility: The tendency of a liquid to pass into the vapor state at a given
temperature. With automotive fuels, volatility is determined by measuring RVP.
Wellhead: The area immediately surrounding the top of a well, or the top of the well casing.
Wellhead Protection Area: The recharge area surrounding a drinking water well or wellfield, which is
protected to prevent contamination of a well.
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