Draft
PBT National Action Plan
for Alkyl-lead
Prepared by
The US EPA Persistent, Bioaccumulative, and
Toxic Pollutants (PBT) Alkyl-Lead Work Group
May 8, 2000
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY iv
1.0 INTRODUCTION 1
2.0 DESCRIPTION OF ALKYL-LEAD 2
3.0 HEALTH EFFECTS 3
4.0 HUMAN AND WILDLIFE EXPOSURE 4
5.0 ENVIRONMENTAL BASELINE 5
5.1 SCOPE OF THE PROBLEM AND CURRENT STATUS AND TRENDS 5
5.2 QUANTITATIVE AND QUALITATIVE DATA ON CURRENT SOURCES
AND RESERVOIRS 5
5.2.1 Aviation Fuel 6
5.2.2 Other Non-highway Uses 6
5.2.3 Competition Vehicles (Cars, Boats, etc.) 7
5.2.4 Bulk Terminals, Bulk Plants and Service Stations 9
5.2.5 Overall Lead Emissions 9
6.0 EPA'S PROGRAMMATIC BASELINE 14
6.1 OVERVIEW OF CURRENT REGULATIONS AND PROGRAMS 14
6.2 BASELINE ACTIVITIES 16
6.2.1 Regulations Controlling Use 16
6.2.2 Regulations Governing Emissions, Releases and Spills 17
6.2.3 Regulations Calling for Source Identification 18
6.2.4 Compliance and Enforcement 18
6.2.5 International Activities 19
6.2.6 Activities Related to Products 19
7.0 PROPOSED GOALS AND ACTIONS 20
7.1 EPA'S ASSESSMENT AND STRATEGIC APPROACH 20
7.2 GOALS 23
7.3 FUTURE DIRECTION AND ACTIVITIES 24
7.3.1 Stakeholder Involvement 24
7.3.2 International Efforts 25
7.3.3 Measurement 25
7.3.4 Actions Considered but Not Able to Be Implemented
Due to a Lack of Resources 26
8.0 REFERENCES 29
GLOSSARY 31
APPENDIX A: LIST OF KEY CONTACTS AND GPRA GOALS A-1
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TABLE OF CONTENTS
(Continued)
Page
LIST OF TABLES
Table 1. Illustration of Available Racing Gasoline 8
Table 2. 1995 and 1996 National Lead Emissions by Source Category 11
Table 3. Current Regulations and Programs 15
Table 4. Violations Issued for Excess Lead-Levels in Gasoline 18
Table 5. Measures of Progress and GPRA Goals for Actions to Reduce Risks from Alkyl-
lead 26
LIST OF FIGURES
Figure 1. Finished Aviation Gasoline Supplied in the U.S. 1995-1998 7
Figure 2. Total Lead Emissions (Short Tons) by Year 9
Figure 3. Percentage of 1996 National Emission Estimates by Source (Short Tons) 10
Figure 4. National 1990 Alkylated Lead Emissions Estimates in Pounds Per Year 13
Figure 5. Annual Evaporative Emissions of TML From Non-road Engines 14
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EXECUTIVE SUMMARY
On November 16, 1998, the U.S. Environmental Protection Agency (EPA) released its
Agency-wide Multimedia Strategy for Priority Persistent, Bioaccumulative, and Toxic (PBT)
Pollutants (PBT Strategy). The goal of the PBT Strategy is to identify and reduce risks to human
health and the environment from current and future exposure to priority PBT pollutants. This
document serves as the Draft National Action Plan for alkyl-lead, one of the 12 Level 1 priority
PBT pollutants identified for the initial focus of action in the PBT Strategy.
Alkyl-lead compounds are man-made compounds in which a carbon atom of one or more
organic molecules is bound to a lead atom. Tetraethyllead [TEL] and Tetramethyllead [TML]
compounds are the most common alkyl-lead compounds that have been used in the past and are
still in use today in the United States. These two alkyl-lead compounds are the focus of this
National Action Plan. Alkyl-lead is used as a fuel additive to reduce "knock" in combustion
engines and also to help lubricate internal engine components and protect intake and exhaust
valves against recession. Currently, the largest uses of alkyl-lead are in aviation gasoline for
general aviation (piston-engine) aircraft, and racing gasoline. Neither of these uses are subject to
any of the regulations that restrict leaded motor gasoline use.
Alkyl-lead is released to the environment primarily through evaporative emissions from
unburned gasoline retained in an engine's carburetor or fuel tanks and through evaporative losses
during the filling of gasoline tanks, accidental spillages, and releases during production. Typically,
only a very small percentage of alkyl-lead is exhausted uncombusted when driving at constant
speeds. However, alkyl-lead compounds combine with other compounds during the combustion
process to form lead halides that are subsequently emitted as microparticulates in the exhaust.
Once emitted, lead particles may remain airborne for about 10 days and may be transported far
from the original source. Lead is removed from the atmosphere and deposited on soil and water
surfaces via wet or dry deposition. Alkyl-lead itself is not a persistent environmental compound
but breaks down in the environment (or is emitted following combustion) to other forms of lead
which are much more persistent.
In the body, alkyl-lead compounds are distributed through the blood to "soft tissues"
particularly the liver, kidneys, muscles, and brain. Initial symptoms of alkyl-lead poisoning
include, among others: anorexia, insomnia, tremor, weakness, fatigue, nausea and vomiting,
mood shifts such as aggression or depression, and impairment of memory. In the case of acute
alkyl-lead poisoning, possible health effects include mania, convulsions, delirium, fever, coma, and
in some cases even death. Lead poisoning due to the ingestion or inhalation of inorganic lead
compounds emitted as exhaust through the combustion process (as a direct result of the use of
alkyl-lead in gasoline) is a widely recognized public health problem.
With the phase-out of leaded gasoline used in on-road vehicles in the United States, there
has been a substantial reduction in the risk of exposure for the general public. As a result of the
1990 Clean Air Act Amendments, the sale or use of gasoline containing alkyl-lead (greater than
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0.05 grams of lead per gallon) is currently prohibited in on-road vehicles. However, the
remaining uses of gasoline containing alkyl-lead, particularly for race cars and airplanes,
potentially puts certain subpopulations at risk. These subpopulations include residents
(particularly children) near sources such as race tracks and general aviation airports, fuel
attendants, racing crew staff, and spectators. EPA does not have the authority under the CAA to
regulate the use of unleaded gasoline for the racing industry, and the regulation of aircraft fuel lies
with the FAA. However, NASCAR is evaluating and testing the use of unleaded racing gasoline
(e.g., in the Busch Grand Nationals series). The FAA, working cooperatively with the
Coordinating Research Council, has initiated an Unleaded Fuels Research Program to complete
research on the development of unleaded aviation gasoline for civil aircraft.
On a global basis, lead in gasoline has been estimated to contribute 95 percent of the lead
air pollution found in the world's major cities. Aided by U.S. efforts to promote the phase-out of
leaded gasoline use in motor vehicles worldwide, several foreign countries have totally phased out
the use of lead in gasoline while others have lowered the levels of lead added to leaded gasoline.
Recognizing the large reduction in lead emissions related to the use of alkyl-lead, primarily
due to the regulated phase-out of leaded gasoline in on-road vehicles, the Agency has adopted the
following strategic approach to address the remaining risks to human health and the environment
from exposure to alkyl-lead: 1) contribute to international efforts to reduce the use of alkyl-lead
worldwide, 2) pursue voluntary initiatives to reduce the use of alkyl-lead in aircraft gasoline, race
cars, and non-road vehicles such as farm machinery, marine vessels, construction equipment, and
recreational vehicles, and 3) collect information as possible, given resource constraints, related to
production, use, emissions, and continued exposure scenarios. After consideration of priorities in
light of recommended actions for all Level 1 chemicals under the PBT Strategy, EPA proposes the
following priority actions:
# Continue current international efforts to reduce the use of leaded gasoline, including
participation in the United Nations Commission on Sustainable Development, Summit
of the Americas, Earth Summit + 5, the G-8, and the Great Lakes Binational Toxics
Strategy.
# Coordinate with NASCAR and NASCAR Sponsors to encourage a voluntary
unleaded phase-in partnership/program to eliminate the use of leaded gasoline in the
auto racing industry.
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1.0 INTRODUCTION
On November 16, 1998, the U.S. Environmental Protection Agency (EPA) released its
Agency-wide Multimedia Strategy for Priority Persistent, Bioaccumulative, and Toxic (PBT)
Pollutants (PBT Strategy). EPA has a long history of successful programs in controlling PBT
pollutants - pollutants that are toxic, persist in the environment, and bioaccumulate in food
chains, and thus pose risks to human health and ecosystems. The challenges remaining for PBT
pollutants stem from the fact that they transfer rather easily among air, water, and land, and span
boundaries of programs, geography, and generations. As a result, single-statute approaches are
not adequate for reducing these risks. To achieve further reductions, a multimedia approach is
necessary. Accordingly, through the PBT Strategy, EPA has committed to create an enduring
cross-office system that would address the cross-media issues associated with priority PBT
pollutants.
The goal of the PBT Strategy is to identify and reduce risks to human health and the
environment from current and future exposure to priority PBT pollutants. To attain this goal,
EPA has identified several guiding principles:
# Address problems on multimedia basis through integrated use of all Agency tools
# Coordinate with and build on relevant international efforts
# Coordinate with relevant Federal programs and agencies
# Stress cost-effectiveness (e.g., amount of PBT removed for dollar spent)
# Involve stakeholders
# Emphasize innovative technology and pollution prevention
# Protect vulnerable subpopulations
# Base decisions on sound science
# Use measurable objectives and assess performance.
The PBT Strategy outlines an approach to achieving PBT risk reductions which includes
the development and implementation of national action plans for priority PBT pollutants. These
action plans will draw upon the full array of EPA's statutory authorities and national programs,
building on work initiated under The Canada-United States Strategy for the Virtual Elimination
of Persistent Toxic Substances in the Great Lakes Basin (USEPA, EC, 1997) and using
regulatory action where voluntary efforts are insufficient. The action plans will consider
enforcement and compliance, international coordination, place-based remediation of existing PBT
contamination, research, technology development and monitoring, community and sector-based
projects, the use of outreach and public advisories, and opportunities to integrate efforts across
chemicals.
This document serves as the Draft National Action Plan for Alkyl-lead, one of the
12 Level 1 priority PBT pollutants identified for the initial focus of action in the PBT Strategy.
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2.0 DESCRIPTION OF ALKYL-LEAD
Lead (CAS number 7439-92-1) is a naturally occurring, bluish-gray metal originating in
the earth's crust. It is odorless, tasteless, and has no known physiological value. It does not
dissolve in water and does not burn. The vast majority of lead chemical compounds are inorganic.
However, lead can be combined with organic chemicals to form lead compounds with very
different characteristics from metallic lead. This action plan does not address inorganic lead, but
addresses one of the more predominant types of organic lead compounds: alkyl-lead.
Organolead compounds are man-made compounds in which a carbon atom of one or more
organic molecules is bound to a lead atom. Generally, "alkyl-lead" compounds are classified as
"Tetraalkyllead" compounds (e.g., Tetraethyllead [TEL] and Tetramethyllead [TML]),
"Trialkyllead" compounds (e.g., Trimethyllead chloride [TriML] and Triethyllead chloride
[TriEL]), or "Dialkyllead" compounds (e.g., Dimethyllead chloride [DiML] and Diethyllead
chloride [DiEL]). Of these, the Tetraalkyllead compounds, TEL and TML, are the most common
alkyl-lead compounds that have been used in the past and are still in use today in the United
States. These two alkyl-lead compounds are the focus of this National Action Plan.
Alkyl-lead is produced through several different methods including through the
electrolysis of an ethyl Grignard reagent or through alkylation of a lead-sodium alloy. Alkyl-lead
is used as a fuel additive to reduce "knock" in combustion engines (by contrast, inorganic lead is
used in leaded paint). The most common alkyl-lead compound used as an anti-knock agent in
gasoline is TEL lead, though TML lead is also used as an anti-knock agent. These alkyl-lead
compounds also help to lubricate internal engine components and protect intake and exhaust
valves against recession. Currently, the largest uses of alkyl-lead are in aviation gasoline for
general aviation (piston-engine) aircraft, and racing gasoline. Neither of these uses are subject to
any of the regulations that restrict leaded motor gasoline use.
Alkyl-lead is released to the environment primarily through evaporative emissions from
unburned gasoline retained in an engine's carburetor or fuel tanks and through evaporative losses
during the filling of gasoline tanks, accidental spillages, and releases during production. Typically,
only a very small percentage of alkyl-lead is exhausted uncombusted when driving at constant
speeds. However, alkyl-lead compounds combine with other compounds during the combustion
process to form lead halides (e.g., PbBrCl, 2PbBrCl*NH4Cl, etc.) that are subsequently emitted as
microparticulates in exhaust.
Alkyl-lead in the atmosphere degrades rapidly by direct photolysis, reaction with ozone,
and by reaction with hydroxyl compounds. The half-lives of TEL and TML in summer
atmospheres is approximately two hours and nine hours, respectively. In winter atmospheres, the
half lives of both TEL and TML consists of several days. In water and soil, alkyl-lead compounds
are also degraded to other forms of lead, eventually forming stable inorganic lead compounds.
Therefore, alkyl-lead itself is not a persistent environmental compound. However, it breaks down
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in the environment (or is emitted following combustion) to other forms of lead which are much
more persistent.
Airborne lead particles (such as those emitted as exhaust) may remain airborne for about
10 days and, therefore, may be transported far from the original source. Lead is removed from
the atmosphere and deposited on soil and water surfaces via wet or dry deposition. In soils, most
lead is strongly retained via the formation of stable solid phase compounds, precipitates, or
complexes with organic matter. In general, most of these forms of lead are quite insoluble and
thus not easily leached to underground water. However, leaching may occur under acidic
conditions, where lead concentrations are extremely high, or in the presence of substances
(e.g., soluble organic matter, high concentrations of chlorides or sulfates) which form relatively
soluble complexes with lead. Transport of lead to surface waters most commonly occurs through
direct deposition from the atmosphere or as lead associated with suspended solids in the erosional
process. In water, lead is typically bound to sediments.
3.0 HEALTH EFFECTS
In the body, alkyl-lead compounds are metabolized in the liver by oxidative dealkylation
catalyzed by cytochrome P-450. Through this process, alkyl-lead compounds are converted to
triethyllead- and trimethyllead-metabolites and inorganic lead. It is these three compounds that
are thought to cause the toxic effects of lead. In the body, triethyllead and trimethyllead
compounds are distributed through the blood to "soft tissues" particularly the liver, kidneys,
muscles, and brain. Experiments on mice and rabbits have suggested that the highest
concentration of triethyllead compounds is found in the liver, kidneys, brain, and muscles in that
order. Initial symptoms of alkyl-lead poisoning include, among others: anorexia, insomnia,
tremor, weakness, fatigue, nausea and vomiting, mood shifts such as aggression or depression,
and impairment of memory. In the case of acute alkyl-lead poisoning, possible health effects
include mania, convulsions, delirium, fever, coma, and in some cases even death.
The inorganic lead compounds emitted as exhaust (e.g., PbBrCl, 2PbBrCl*NH4Cl, etc.)
through the combustion process (as a direct result of the use of alkyl-lead in gasoline) also
contribute to human exposure through ingestion and/or inhalation. The biochemistry and
toxicology of inorganic lead differs from that of alkyl-lead compounds. However, lead poisoning
due to the ingestion or inhalation of inorganic lead compounds is a widely recognized public
health problem. Blood-lead concentration is a commonly used measure of body lead burden.
Children are at a higher risk of lead poisoning than adults due to their lower body weights and
developing neurological systems. Blood-lead concentrations as low as 10 to 15 |ig/dL have been
associated with neurological damage in children, and increasing blood-lead levels have been highly
correlated with decreased performance on standardized intelligence tests (i.e., lower I.Q. test
scores). Adverse health effects such as impaired hearing acuity and interference with vitamin D
metabolism have also been observed at blood-lead levels of 10 to 15 |ig/dL. Increased blood
pressure, delayed reaction times, anemia, and kidney disease may become apparent at blood-lead
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concentrations between 20 and 40 |ig/dL. Symptoms of very severe lead poisoning, such as
kidney failure, abdominal pain, nausea and vomiting, and pronounced mental retardation can
occur at blood-level concentrations as low as 60 |ig/dL. At even higher concentrations,
convulsions, coma, and death may result.
4.0 HUMAN AND WILDLIFE EXPOSURE
The human exposure pathways for alkyl-lead are through inhalation of leaded gasoline
vapors, or by dermal exposure to leaded gasoline. Unlike metallic forms of lead, alkyl-lead is
easily absorbed through the skin. Additionally, through the combustion process, alkyl-lead in
gasoline is converted to lead halides and exhausted into the air where it can be inhaled. These
lead halides create the potential for exposure to lead through ingestion of soil or dust containing
lead, and ingestion of lead-contaminated food or water.
The absorption of lead is influenced by the route of exposure. Due to the lipophilic nature
of alkyl-lead and its ability to permeate biological membranes, alkyl-lead is absorbed rapidly and
extensively through the skin. For this reason, alkyl-lead is much more bioavailable and is
considered to be much more toxic than inorganic forms of lead. Further, the toxicity of alkyl-lead
compounds varies with the degree of alkylation. Tetraalkyllead compounds such as TEL and
TML are considered to be more toxic than Trialkylead or Dialkyllead compounds.
With the phase-out of leaded gasoline used in on-road vehicles, there has been a
substantial reduction in the risk of exposure for the general public. However, as gasoline
containing alkyl-lead is still currently being used as fuel (particularly for race cars and airplanes),
certain subpopulations may remain at risk.
Lead particles can remain airborne for some time following the initial introduction into the
atmosphere. Therefore, residents in the vicinity of race tracks and general aviation airports where
leaded gasoline is still being used as fuel may have an increased risk of lead exposure. Similarly,
spectators at racing events or air shows may also be exposed to alkyl-lead emissions resulting
from fueling or to lead compounds emitted as exhaust. Information to quantify the risk of these
exposure pathways is not currently available.
Aviation fuel attendants, mechanics, and racing crew staff are potentially exposed due to
inhalation of alkyl-lead compounds during fueling, evaporative emissions from spills, or
evaporative emissions from unused gasoline remaining in the engine or fuel tanks. Further, these
populations are also at risk because of possible dermal absorption of gasoline containing
alkyl-lead compounds. Information to quantify the risk of these exposure pathways is not
currently available.
Inorganic lead may bioconcentrate in some aquatic animals, especially benthic organisms
such as bottom feeding fish and shellfish such as mussels. Biomagnification of inorganic lead does
not appear to be significant in aquatic organisms. Alkyl-lead compounds, however, have been
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found to significantly accumulate in both fish and shellfish. Some crops can become contaminated
with lead by exposure to exhaust in the air or lead in the soil.
5.0 ENVIRONMENTAL BASELINE
5.1 SCOPE OF THE PROBLEM AND CURRENT STATUS AND TRENDS
Although the use of alkyl-lead has been prohibited by legislation in on-road automotive
gasoline, several authorized uses of alkyl-lead still remain. Currently, the largest use of alkyl-lead
occurs in aviation gasoline for general aviation (piston-engine) aircraft, racing gasoline, and
recreational marine. These current uses, as well as trace amounts of lead in automotive gasoline,
result in releases to the environment.
Sources of alkyl-lead emissions include: Sinks include:
# Airport fuel terminals # Soils and sediments
# Bulk plants-aviation gasoline # Fish and shellfish
# Bulk plants-leaded racing and other
non-road vehicle gasoline
# Evaporative emissions from aircraft
# Evaporative emissions from non-road
vehicles
# Spills from fuel loading, transfer,
storage and fueling
5.2 QUANTITATIVE AND QUALITATIVE DATA ON CURRENT SOURCES AND
RESERVOIRS
Leaded gasoline (containing alkyl-lead) is used as fuel predominantly in the general
aviation (piston engine) industry, but also in a variety of non-road uses, including competition
race vehicles, construction equipment, farm machinery, and marine vessels.
Current overall production and use rates of alkyl-lead in gasoline in the U.S., particularly
for non-road motor vehicles, are difficult to determine due to the fact that the U.S. Department of
Energy discontinued the tracking of leaded gasoline in 1990. Thus, most of the available
information on alkyl-lead use in gasoline is limited to older data on sales, imports, exports and
throughput at bulk distribution plants.
The EPA TSCA Chemical Inventory Chemical Update System indicates that alkyl-lead
was not manufactured domestically as of 1994. However, the U.S. Department of Commerce
web site documents that, in 1998, the quantity of antiknock preparations imported into the U.S.
was approximately 14.4 million pounds per year (based on TEL or TEL/TML mixtures) and the
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quantity exported was 7.07 million pounds per year (based on lead compounds) (U.S. Department
of Commerce, 1998). It is reasonable to assume the majority of the 7 million pound difference
between imports and exports was used for the production of leaded gas.
5.2.1 Aviation Fuel
Aviation gasoline (avgas) is currently the fuel with the greatest alkyl-lead (TEL) content,
ranging from 4.4xl0"3 to 8.8xl0"3 lbs as lead/gal (USEPA, 1998a). Only TEL is used in aviation
gasoline. The other aviation fuels, such as Jet kerosene and JP-4, do not contain alkylated lead
compounds. Leaded avgas is currently available in several grades with differing lead
concentrations, and is used primarily in civil aviation for reciprocating piston engine aircraft.
Avgas 80/87 has the lowest lead content at 0.5 grams lead per gallon, and is only used in very low
compression ratio engines. Avgas 100/130 is a higher octane grade aviation gasoline, containing
about 4 grams of lead per gallon. Finally, a lower-lead blend, Avgas 100LL ("low lead") was
designed to replace Avgas 100/130. Avgas 100LL contains about 2 grams of lead per gallon, and
is typically the most commonly used aviation gasoline (Purvis, 1999).
First sales of total aviation gasoline (all grades) in 1990 totaled 322.6 million gallons (U.S.
DOE, 1991), and throughput at bulk plants was also 322 million gallons (USEPA, 1993). In
1998, the quantities of finished aviation gasoline (all grades) produced at refineries and imported
into the U.S. totaled 298.8 million gallons and 1.8 million gallons, respectively (U.S. DOE, 1998).
There were no exports of aviation gasoline in 1998 (U.S. DOE, 1998). Adjusting for changes in
avgas stocks, the total volume of aviation gasoline supplied as a product in 1998 was 295.3
million gallons (U.S. DOE, 1998). Trends in the total finished aviation gasoline supplied in the
U.S. between 1995-1998 are summarized in Figure 1.
As the volumes above represent only total gallons of aviation gasoline, the exact amount
of alkyl-lead associated with this total is unknown without information which breaks down the
production and use of aviation gasoline by grade. However, based on ATSM specifications for
100LL aviation gasoline (which typically constitutes the majority of avgas consumption), a rough
conservative estimate of TEL used in aviation can be derived for 1998 as 295.3 million gallons of
gasoline x 2.128 g (TEL)/gallon = 628 billion grams of TEL, which is equivalent to 1.39 million
pounds of TEL.
5.2.2 Other Non-hiqhwav Uses
In addition to aviation, non-road leaded fuel consumption includes use in competitive race
vehicles (cars, boats, etc.), construction machinery, agricultural equipment, logging equipment,
industrial and light commercial equipment, recreational equipment (boats, ATVs, jet skis,
snowmobiles, etc.), airport service equipment, and lawn and garden equipment (USEPA, 1993).
In 1990, first sales of leaded motor gasoline in the U.S. were estimated to total 5.8 billion gallons,
which comprised about 4.8 percent of the total gasoline sales (U.S. DOE, 1991). By 1991, use of
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leaded gasoline had declined to 3.1 billion gallons representing 3.2 percent of total gasoline use.
(Unpublished data, USEPA, 1991).
329
311
330
295
1996 1997
Y ear
Figure 1. Finished Aviation Gasoline Supplied in the U.S. 1995-1998.
Although more recent data on total motor gasoline production levels is available, the
proportion of leaded gasoline produced, as well as the rate of leaded gasoline use by each of the
non-road sources, is unknown. Total (leaded and unleaded) motor gasoline supplied in the U.S.
between the years 1995 and 1998 has gradually increased from 119.4 billion gallons in 1995 to
126.5 billion gallons in 1998 (U.S. DOE, 1998). If the supply of leaded gasoline has not
increased from the 1991 level of 3.1 billion gallons, the percentage of leaded gas based on 1998
total motor gasoline supply levels would be 2.45%. However, it is more likely that the volume of
leaded gasoline supply has actually decreased since 1991.
In 1997, imports of leaded gasoline into the U.S. totaled more than 9.4 million gallons,
and exports were about 9.1 million gallons (U.S. Bureau of the Census, 1998).
5.2.3 Competition Vehicles (Cars. Boats, etc.)
Currently, no readily available source of information exists on the amount of leaded fuel
used by racing cars and boats. However, there are many different suppliers of leaded racing fuel
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in the United States. Almost all of these suppliers offer racing fuel at various octanes and lead
content. For example, 76 Racing Gasoline, the "Official Fuel of NASCAR," offers four different
types of racing gasoline: 100 Octane Unleaded, 110 Octane Leaded, 114 Octane Leaded, and
118 Octane Leaded. In addition to 76, many suppliers offer unleaded fuel as well as leaded fuel.
Therefore, it seems likely that, to some extent, unleaded gasoline is being used for races or at least
in particular race vehicles. Table 1 illustrates several suppliers and the types of racing fuel they
offer.
Table 1. Illustration of Available Racing Gasoline
Supplier
Racing Gasolines Offered
Octane
Lead Content
76 Racing Gasoline
76 Unleaded Racing Gasoline
100
Unleaded
(Union 76)
76 Leaded Racing Gasoline
110
TBD
76 Superstock Racing Gasoline
114
TBD
76 Prostock Racing Gasoline
118
TBD
Phillips 66
Phillips B-32
110
4.0 ml/gal
Phillips B-33
114
4.0 ml/gal
Phillips B-35
101
Unleaded
Phillips B-37
118
6.0 ml/gal
Phillips B-42
105
Unleaded
Sunoco
Sunoco GT Unleaded
100
Unleaded
Sunoco GT Plus Unleaded
104
Unleaded
Sunoco Standard
110
TBD
Sunoco Supreme
112
TBD
Sunoco Maximal
116
TBD
Sunoco Supreme N.O.S
117
5.0 ml/gal
Sunoco Maximal #5
116
6.0 ml/gal
RAD Racing Fuel
RAD 110
110
4.5 g/gal
As an alternative to the purchase of commercial racing gasoline, gasoline additives may be
purchased that can be added to unleaded motor gasoline to raise the octane level. For example,
Tosco Racing Fuels offers the "Accelerator Race Fuel Concentrate" in both a leaded and unleaded
form.
There is also evidence that, to some degree, leaded aviation gasoline may be added to the
fuel used for some racing vehicles. For example, some of the suppliers of gasoline additive
products present information on how their concentrate can be blended with 100LL to create a
higher octane racing fuel.
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5.2.4 Bulk Terminals. Bulk Plants and Service Stations
Bulk gasoline terminals are the major distribution points for the gasoline produced at
refineries, while bulk plants are the secondary distribution facilities that received gasoline from the
bulk terminals before it is distributed to smaller consumers such as service stations. Bulk
terminals and plants may distribute both leaded and unleaded gasolines for various uses (e.g.,
motor vehicle gasoline and aviation gasoline). In 1990, the number of major facilities nationwide
were estimate at 748 bulk terminals, 12,600 bulk plants, and 387,750 Service stations (USEPA,
1993). Airports were considered to be bulk plants as they receive direct deliveries from refineries.
5.2.5 Overall Lead Emissions
Overall lead emissions (all forms of lead and lead compounds, including alkyl-lead) in the
U.S. have decreased by two orders of magnitude between 1970 (220,869 short tons emitted) and
1996 (3,869 short tons emitted) (USEPA, 1997b) Figure 2 summarizes estimates of total lead
emissions by year.
250,000
200,000
c
-8 150,000
-4-»
o
¦E
(A
¦O 100,000
TO
0)
_l
50,000
0
1970 1975 1980 1985 1990 1995
Year
Figure 2. Total Lead Emissions (Short Tons) by Year.
[Figure reproduced from National Air Pollutant Emission Trends Report, 1900-1996 (USEPA, 1997]
Most notable in Figure 2 is that the greatest reduction in lead emissions occurred between
1970 and 1985. This large reduction is a direct result of the regulated phase-out of leaded
gasoline (reductions in both the lead content per gallon and the total gallons produced) and the
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increased availability of unleaded gasoline (USDHHS, 1997). Currently, there are several
remaining major sources of airborne lead emissions1, including bulk production plants for aviation
gasoline, nonroad vehicles, waste incinerators, metal processing facilities, and other fuel
combustion facilities (e.g., electrical utility, industrial). The available data on specific types of
releases of lead compounds are discussed below, including exhaust emissions, evaporative
emissions, and spills and/or leaks (from fuel loading, transfer, storage, and fueling). The focus of
the discussion is on lead emissions attributable to the use of alkyl-lead, either direct alkyl-lead
emissions or lead emissions resulting from combustion of fuel containing alkyl-lead. Data specific
to alkyl-lead are presented where possible. However, in some cases, the information is limited to
reports of inorganic lead releases only.
Exhaust Emissions
As seen in Figure 3, on-road exhaust emissions (the predominant emissions source in the
1970s and 1980s) contributed less than one-half of one percent to the total lead emissions in 1996
(USEPA, 1998c; USEPA, 1997a). In 1996, metals processing was estimated to be the
predominant source of lead emissions. Therefore, not only have total lead emissions been
reduced, but the relative contribution of on-road vehicles has also been reduced. With the
continued implementation of provisions of the 1990 Clean Air Act Amendments (CAAA), this
trend is expected to continue.
100.0%
90.0%
80.0%
70.0%
60.0%
50.0%
40.0%
30.0%
20.0%
10.0%
0.0%
51.69%
-
-
-
20.01%
-
10.70%
'0
-
3.02% 0.49%
Metals Fuel Chemical and On-road Nonroad All Other
Processing Combustion Allied
(Other) Products
Figure 3. Percentage of 1996 National Emission Estimates by Source (Short Tons).
[Figure produced using data from National Air Pollutant Emission Trends Report, 1900-1996. USEPA, 1997a.]
1 Through the combustion process in automotive engines, alkyl-lead compounds combine with fuel scavengers to
form lead oxides. Alkyl-lead is the only known significant source of lead in gasoline. Typically, only a very small percentage
(0.2%-0.4%) of alkyl-lead is exhausted uncombusted when driving at constant speeds (Grandjean, 1983).
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Table 2 summarizes the information contained in Figures 2 and 3. Lead emissions from
on-road vehicles were estimated by EPA to be approximately 19 tons in 1996. However, this
estimate does not imply a widespread use of leaded gasoline as a fuel source for on-road vehicles.
Rather, the estimate reflects the trace amount of lead remaining in unleaded gasoline. This trace
amount of lead is due to the sharing of distribution systems utilized by gasoline manufacturers for
the production of leaded and unleaded gasoline and residual amounts of lead in crude oil. EPA
has determined that requiring manufacturers to eliminate this trace amount is not economically
feasible. As production of leaded gasoline has decreased, so too has the trace amount of lead in
unleaded motor gasoline.
Table 2. 1995 and 1996 National Lead Emissions by Source Category
Emissions (short tons)
Source Category
1995
1996
Metals
2,067
2,000
Primary lead production
674
636
Secondary lead production
432
400
Gray iron production
366
339
All other
595
625
Fuel combustion other
414
414
Chemical and Allied Products (lead oxide and pigments)
144
117
On-road
19
19
Nonroad(a)
545
545
Nonroad gasoline
0
0
Aircraft
545
545
All other
754
774
Total
3,943
3,869
Table reproduced from Table 2-1 in the National Air Pollutant Emission Trends Report, 1900-1996, EPA 1997a.]
(a) EPA did not develop estimates for Nonroad emissions (other than those for aviation) because they were deemed to be
extremely low relative to other sources.
Table 2 and Figure 3 also show that aircraft accounted for 545 tons (14.1%) of the total
lead emissions. EPA did not develop estimates for non road emissions (other than those for
aviation) because they were deemed to be extremely low relative to other sources. Of the
remaining mobile lead sources, aircraft are most significant in terms of exhaust emissions of lead.
Evaporative Emissions
No significant amounts of alkyl-lead have been observed to be released via tailpipe
emission during the combustion of leaded gasoline (USEPA, 1993) (releases occur in the form of
inorganic lead / lead halides). Alkyl-lead releases from these sources are primarily associated with
evaporative emissions or spills that may occur during fuel distribution or refueling, as well as
evaporative emissions that can originate from unburned fuel in the carburetor or gas tank.
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In response to the 1990 CAAA, which call for the identification of source categories
emitting 90 percent of the total national alkyl-lead emissions (plus six other air toxics) the EPA
published the 1990 Emissions Inventory of Section 112(c)(6) Pollutants in April of 1998. In the
inventory, the total national emissions of TEL and TML in 1990 were estimated to be 810.6 lbs of
TEL and 481.23 lbs of TML. Together, aviation bulk plants (58%), non-road vehicles (26%),
and service stations (9%) comprise roughly 93% of the total estimated alkyl-lead emissions
(USEPA, 1998a).
As shown in Figure 4, bulk aviation gasoline plants were the major sources of TEL
emissions (749.57 lbs/yr). Transport of gasoline produced at refineries to the bulk terminals
occurs via pipeline, ship, or barge. Tank trucks transport gasoline from the bulk terminal to the
bulk plant, where it is transferred to storage tanks until distribution to smaller volume clients (e.g.,
service stations, farms, other business) occurs by tank truck. Thus, emissions associated with
bulk terminals and plants are associated with loading and unloading of tank trucks, storage tank
emissions, and fugitive emissions from leaking pumps and valves. Service station emissions may
occur as a result of fugitive vapor or spills / leaks during storage tank filling or vehicle refueling.
In the 1993 EPA study, Estimation of Alkylated Lead Emissions, only three states were identified
that still marketed leaded gasoline through service station outlets: Montana, Colorado, and
Georgia (USEPA, 1993).
Evaporative emissions from non-road vehicles were the major source of TML (293.21
lbs/year) in 1990. The distribution of evaporative TML emissions from nonroad engines and
source and vehicles, by source categories, is shown in Figure 5. As can be seen, in 1990
recreational marine uses constitute the overwhelming majority (93.91%) of non-road TML
emissions, as well as TML emissions overall.
It should be noted, however, that there were potential sources of alkyl-lead emissions for
which credible emissions estimates in the 112(c)(6) report could not be developed, due to
insufficient data. These included: evaporative emissions for operations of aircraft, evaporative
emissions from operation of onroad vehicles, and alkylated lead production processes (in 1990)
and facilities. In addition, it should also be noted that the 112(c)(6) estimates assumed that
evaporative emissions associated with the use of alkyl-lead in custom blended fuels (i.e., in
competitive race vehicles) was negligible compared to evaporative emissions associated with
aviation and other off-road uses.
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1990 National Alkylated Lead Emissions Estimates
o-
Bulk Plants -
A viation
Gasoline
Non-road
Vehicles
Evaporative
Service Stations
Bulk Plants -
Motor Vehicle
Gasoline
Bulk Terminals
Pipelines
¦ TEL
749.57
3 7.92
12. 72
4.81
3.62
1.96
~ TML
293.21
102.29
39. 68
29. 98
16.07
Figure 4. National 1990 Alkylated Lead Emissions Estimates in Pounds Per Year.
[Figure produced using data from the 1990 Emissions Inventory of Section 112(c)(6) Pollutants. USEPA,
1998a.I
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Recreational Marine
Recreational Equipment
Logging
Light Commercial
Lawn and Garden
Industrial
Construction
Airport Service
Agricultural
0 20 40 60 80 100 120 140
Annual Evaporative TML Emissions (kg/tyr)
Figure 5. Annual Evaporative Emissions of TML From Non-road Engines
[Figure reproduced using data from Estimation of Alkylated Lead Emissions Final Report.
USEPA, 1993.] Aviation emissions are not included as Avgas does not contain TML.
6.0 EPA'S PROGRAMMATIC BASELINE
6.1 OVERVIEW OF CURRENT REGULATIONS AND PROGRAMS
Current regulations and programs targeting lead emissions and releases (including
alkyl-lead compounds) are presented in Table 3.
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93.91%
4.35%
0%
0.14%
0.74%
0.08%
0.01%
0.08%
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Table 3. Current Regulations and Programs
Regulations
CM
CWA
SDWA
RCRA
SARA/EPCRA
CERCLA
§109: NMQS is
CWA Priority:
NPDWR:
Subtitle C: Lead-
§313: Releases of
§103: Spills
1.5 |jg/m3 (lead)
Lead and lead
Action Level is
containing
lead and lead
of tetraethyl
compounds are
0.15 mg/L lead
substances are (T)
compounds (by
lead > 10 lbs.
§112(b): Designated
listed priority
(treatment
classified
facilities with 10 or
must be
a HAP; Major source
pollutants (40CFR
technique)
hazardous wastes
more employees and
reported to the
categories identified
423); subject to
based on toxicity
that process 25,000
National
under
NPDES effluent
MCL Goal is
characteristic(40CF
lbs., or otherwise use
Response
W
C
§112(c)(6); MACT
limitations under
zero
R 261.33); subject
10,000 lbs.) must be
Center
"ro
standards to be
§304(b) (40CFR
to hazardous waste
reported to TRI
3
O)
promulgated
122) and general
regulations (40CFR
(40CFR 372.65)
requirements
Federal Register
¦a
0.05 grams of lead
(40CFR 264)
amendment to lower
¦a
C
per gallon in on-road
the TRI reporting
<0
CO
vehicles
Universal treatment
threshold for lead
"c
prohibited
standards for lead
compounds to 10
0)
(Leaded gasoline is
and lead compound
lbs/year (64FR 687)
3
o
still permitted in non-
levels in waste
road vehicles)
(40CFR 268.48)
§211(g): Prohibits
misfueling of vehicles
built after 1990
designed for
unleaded gasoline
- Binational Toxics Strategy Level 1 substance
W
E
- International Joint Commission (IJC) Critical Pollutant
ro
O)
- Tier I chemical under the Canada-Ontario Agreement
2
n
- Recognized pollutant in Lake Superior Lakewide Management Plan (LaMP)
¦a
- Targeted chemical in the Great Lakes Regional Air Toxic Emissions Inventory Project
£
- Included in the USEPA Cumulative Exposure Project (lead compounds)
o
- Included in CAA §112(m) program, Atmospheric Deposition to Great Lakes and Coastal Waters
~o
Q_
- Children's blood lead levels monitored in NHANES
- 0IA program on international efforts to phase-out lead in gasoline
As seen in the table, the 1990 CAAA specifically target the use of leaded gasoline for on-
road vehicles, calling for a complete prohibition on the use of leaded gasoline in on-road vehicles
after December 31, 1995 (§220). However, the 1990 CAAA specifically exempt fuels for race
cars or "Competition Use Vehicles." Also, though the 1990 CAAA require EPA to consider
regulating emissions from off-highway vehicles (construction equipment, marine vessels, farm
machinery, lawn equipment, recreational vehicles, etc.), these vehicles are currently permitted to
use leaded gasoline.
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6.2 BASELINE ACTIVITIES
6.2.1 Regulations Controlling Use
In the early 1970s, EPA issued two regulations under the statutory authority of the 1970
Clean Air Act (CAA). First, EPA required major gasoline retailers to begin selling one grade of
unleaded gasoline by July 1, 1974. This mandate was primarily focused on preventing the
deterioration, as a result of leaded gasoline, of emissions control systems (e.g., catalytic
converters) in motor vehicles so equipped. In developing these regulations, EPA first established
the working definition of "unleaded" gasoline as "gasoline containing not more than 0.05 gram of
lead per gallon and not more than 0.005 gram of phosphorus per gallon" [38FR1255, January 10,
1973], Second, EPA issued a regulation calling for the gradual phase-out of leaded gasoline. The
schedule for reduction of lead content in automobile gasoline was 1.7 grams per gallon (g/gal) in
1975, to 1.4 g/gal in 1976, 1.0 g/gal in 1977, 0.8 g/gal in 1978, and 0.5 g/gal in 1979
[38FR33741, December 6, 1973], Subsequent regulations reduced the allowable lead content to
0.1 g/gal in 1986 [50FR9397, March 7, 1985], and prohibited leaded gas use after 1995
[61FR3837, February 2, 1996],
Most recently, alkylated lead compounds have been regulated under the 1990 CAAA.
Section 220 of the CAAA specifically targets the use of leaded gasoline for on-road vehicles,
calling for a complete prohibition on the use of leaded gasoline in on-road vehicles after
December 31, 1995. However, as outlined below, the 1990 CAAA specifically exempt fuels for
race cars or "Competition Use Vehicles." Also, although Section 213 of the 1990 CAAA
requires EPA to consider regulating emissions from off-highway vehicles (construction
equipment, marine vessels, farm machinery, lawn equipment, recreational vehicles, etc.), these
vehicles are currently permitted to use leaded gasoline. The following components of the 1990
CAAA relate to the use of alkyl-lead in gasoline:
# Prohibition on the Use of Leaded Gasoline in On-Road Vehicles. Section 21 l(n) of
the 1990 CAAA states: "After December 31, 1995, it shall be unlawful for any person
to sell, offer for sale, supply, offer for supply, dispense, transport, or introduce into
commerce, for use as fuel in any motor vehicle (as defined in Section 219(2)) any
gasoline which contains lead or lead additives." This provision applies only to on-
road vehicles. Enacting regulations were promulgated [61FR3837, February 2, 1996],
# Misfueling with Leaded Gasoline. Section 211(g) of the 1990 CAAA prohibits
misfueling vehicles built after 1990 (or vehicles designated solely for unleaded
gasoline) with leaded gasoline.
# Prohibition on Production of Engines Requiring Leaded Gasoline. Section 218 of the
1990 CAAA requires USEPA to promulgate rules that prohibit the "manufacture,
sale, or introduction into commerce of any engine that requires leaded gasoline."
Further, these rules apply to all motor vehicle engines and nonroad engines
manufactured after the 1992 model year.
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Thus, the sale or use of gasoline containing alkyl-lead (greater than 0.05 grams of lead per
gallon) is now prohibited in on-road vehicles [40CFR Part 80.22],
6.2.2 Regulations Governing Emissions. Releases and Spills
The 1990 CAAA also contain language specific to emissions of lead compounds resulting
from the use of leaded gasoline. In particular, Section 213 of the 1990 CAAA requires USEPA
to consider regulating emissions from off-highway vehicles2 (construction equipment, boats, farm
equipment, lawn equipment, etc.). Currently, these vehicles are permitted to use leaded gasoline,
but may be regulated in the future.
Lead compounds (not alkyl-lead specifically) are included in the CAA Title III list of
hazardous air pollutants (HAPs). Facilities releasing HAPs will be subject to standards
established under Section 112, including maximum achievable control technology standards
(MACT)(40CFR Part 61 and 63).
The Clean Water Act (CWA) prohibits any person from discharging a pollutant from a
point source into navigable waters without a National Pollutant Discharge Elimination System
(NPDES) permit (33 U.S.C. sec. 1342, 40 CFR 122). Under the CWA, lead and lead compounds
are listed priority pollutants (40CFR 423). As a result, many facilities are subject to lead effluent
limits or monitoring requirements in their NPDES permits.
Lead-containing substances are classified as hazardous wastes under the Resource
Conservation and Recovery Act (RCRA), Subtitle C (40CFR 261.33). As such, lead-containing
wastes are subject to hazardous waste regulations (40CFR 302.4) and ground water monitoring
requirements (40CFR 264). RCRA also establishes Universal Treatment Standards for lead and
lead compound levels in wastes (40CFR 268.48).
Section 313 of Title III of the 1986 Superfund Amendments and Reauthorization Act
(SARA) also requires that releases of lead and lead compounds to air, water, or land be reported
to the Toxic Releases Inventory (TRI) by manufacturing facilities (SIC codes 20-39, plus other
specific facilities), that have 10 or more full time employees, and manufacture/process 25,000 lbs.
of a listed chemical, or otherwise use 10,000 pounds of a listed chemical (40CFR 372.65). An
amendment to lower the USEPA Toxics Release Inventory (TRI) reporting threshold to 10
pounds for lead compounds, as well as require the filing of separate reports for TEL and TML,
was published October 29, 1999 (64 FR 687), and became effective January 1, 2000. This
amendment will allow identification of facilities that have specific lead compounds and facilitate
the tracing of TEL and TML.
2 Fuels for Race Cars or "Competition Use Vehicles" are exempted from regulation under the Clean Air
Act.
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Finally, Section 103(a) of the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) requires that any spills/releases of tetraethyl lead in quantities
exceeding 10 lbs. must be reported immediately to the National Response Center (40CFR302.4).
6.2.3 Regulations Calling for Source Identification
The CAAA also contain requirements pertaining to the identification of sources of alkyl-
lead. Section 112(c)(6) of the CAAA specifically directs EPA to identify sources of alkyl-lead
(and six other chemicals) that account for 90% of the aggregate emissions of alkyl-lead by 1995,
and to promulgate alkyl-lead standards, using MACT standards, by 2000.
6.2.4 Compliance and Enforcement
As leaded gasoline is still produced in the United States for use in nonroad vehicles
(primarily as aviation fuel, but also in farm machinery and race cars), and is dispensed by private
citizens, the potential for illegal misfueling cannot be entirely eliminated. Historically, EPA's
Office of Enforcement has not found this to be the case in public gasoline service stations. In
previous years, EPA's Office of Enforcement screened for lead during routine inspections at
service stations. However, as leaded gasoline became increasingly scarce, the number of
violations related to the misuse of leaded gasoline dropped dramatically, as shown in Table 4
(USEPA, 1998d). As a result of finding virtually no cases of misfueling, EPA's Office of
Enforcement no longer routinely screens for lead as part of the typical inspection process. It does
continue to test for lead on a case-by-case basis if illegal misfueling is suspected. Typically, very
few cases of suspected misfueling with leaded gasoline are investigated in a given year.
Table 4. Violations Issued for Excess Lead-Levels in Gasoline [Source: usepa,I998d]
Year
Number of Service Station
Inspections
Number of Violations
Issued
Violation Rate
1980
5,021
83
1.65%
1981
10,179
73
0.72%
1982
10,266
60
0.5%
1983
9,896
41
0.41%
1984
4,652
24
0.52%
1985
5,363
30
0.56%
1986
5,363
8
0.15%
1987
9,003
4
0.04%
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Although it is possible for misfueling of on-road automobiles to occur using leaded racing
gasoline, such misfueling, if it occurs at all, is likely to be rare. Limited supply, limited
distribution, higher costs, incompatibility with emission control systems on production
automobiles, and limited performance benefits in production automobiles designed for unleaded
gasoline all weigh against use of leaded racing gasoline in on-road automobiles.
6.2.5 International Activities
The United States is committed to being a world leader in promoting the phase-out of
leaded gasoline use in motor vehicles. Since 1994, national governments have committed to the
phase-out of lead in gasoline at key international and regional agreements, including the United
Nations Commission on Sustainable Development, Summit of the Americas, Earth Summit + 5
and the G-8. As a result of the active campaign to remove lead from gasoline, spearheaded by
EPA's Administrator since 1994, seven countries in Latin America, one country in Eastern
Europe and two countries in Asia have totally phased out the use of lead in gasoline. Efforts by
the United States have resulted in lower levels of lead added to the leaded gasoline in one country
in Asia, two in Latin America, and one in Eastern Europe where leaded gasoline is still sold.
The impact of the activities undertaken by EPA in Latin America and the Caribbean has
been to accelerate the formulation and implementation of lead phase-out plans throughout the
region. The use of leaded gasoline is declining rapidly. By the year 2001, about 85 percent of the
gasoline consumed in the region will be lead-free. According to World Bank figures, the amount
of lead added to gasoline in Latin America and the Caribbean declined from 27,000 metric tons in
1990 to 8,200 tons in 1996. It is estimated that, based on national phase-out, the lead added to
gasoline in 1999 will be approximately 4,200 metric tons.
Worldwide, at least 25 additional countries have made significant commitments to phase-
out, but are hampered from comprehensive action by technical complications. Using the
Implem enter's Guide on Phase-out of Lead in Gasoline that EPA and the U.S. Agency for
International Development (USAID) recently completed, associated workshops will be planned
and conducted to target the 25 countries with technical difficulties. EPA will continue in its
current efforts to enhance and promote the phase-out of leaded gasoline worldwide.
6.2.6 Activities Related to Products
Alternative Aviation Fuel Research. Industry is currently researching an alternative to
alkyl-lead for aviation fuel. An industry group, the Coordinating Research Council (CRC) has
formed a task force for the purpose of finding a no-lead gasoline substitute for the existing
aviation fleet. Working cooperatively with the CRC, the FAA has initiated an Unleaded Fuels
Research Program to complete research on the development of unleaded aviation gasoline for
civil aircraft. Under this program, engine and fuel testing (e.g., engine performance, emissions,
fuel consumption changes, etc.) at the FAA's small-engine and fuel test facilities began in 1994.
Data from this testing will aid the FAA in replacement fuel certification for 100-octane low-lead
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gasoline, as well as developing fuel specifications with the American Society of Testing and
Materials. Considering all of the testing that must be conducted (different conditions, different
engine/airframe combinations, toxicity, etc.) as well as the approvals from FAA and the
acceptance by the aviation industry, petroleum companies, and gasoline distributers that must be
obtained, the time frame for implementation of an unleaded high-octane aviation gasoline is
projected to be 8-10 years.
Racing Gasoline. NASCAR is evaluating and testing the use of unleaded racing gasoline
(e.g., in the Busch Grand Nationals series). Canada proposed a ban on leaded gas in racing and
an unleaded racing series as an alternative. Therefore, the automobile racing industry may be
receptive to participating in a voluntary unleaded phase-in partnership/program.
7.0 PROPOSED GOALS AND ACTIONS
7.1 EPA'S ASSESSMENT AND STRATEGIC APPROACH
The Agency recognizes that tremendous progress has been made in reducing lead
emissions related to the use of alkyl-lead. Total lead emissions have been reduced from
220,869 short tons in 1970 to 3,869 short tons in 1996, totaling a reduction in emissions of
approximately 98 percent (USEPA, 1997b). This large reduction is primarily due to the regulated
phase-out of leaded gasoline in on-road vehicles. To address the remaining risks to human health
and the environment from exposure to alkyl-lead, the strategic approach of the Agency will focus
on the following areas:
1. Contribute to international efforts to reduce the use of alkyl-lead worldwide. On a
global basis, lead in gasoline has been estimated to contribute 95 percent of the lead air
pollution found in the world's major cities. Goal 6 of EPA's Ten Year Strategic Plan
GPRA Goals calls for the reduction in worldwide levels of lead in gasoline.
2. Pursue voluntary initiatives to reduce the use of alkyl-lead in aircraft gasoline, race
cars, and non-road vehicles such as farm machinery, marine vessels, construction
equipment, and recreational vehicles. Regulatory options are limited for these uses
under the CAA. However, there are voluntary initiatives already underway, which the
Agency will encourage and support to achieve cost-effective reductions in these
remaining uses of leaded gasoline. These efforts will help to address Goal 1, Goal 4,
and Goal 8 of EPA's Ten Year Strategic Plan GPRA Goals, which call for clean air,
the reduction of blood-lead levels in children, and greater innovation to address public
health and environmental problems, respectively.
3. Collect information as possible, given resource constraints, to estimate the production
and use of leaded gasoline for legally continued uses, to refine air alkyl-lead emission
estimates reported in the CAA Section 112 (c)(6) report, and to assess whether
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exposure in the vicinity of general aviation airports or race tracks contributes to
elevated blood-lead levels in at-risk populations (especially children).
Priorities
As discussed previously, alkyl-lead is one of 12 chemicals identified as Level 1 priority
PBT pollutants. Historically, the health effects and environmental concerns related to the use of
alkyl-lead are well documented and current domestic use may still pose a threat to certain
populations. However, because of funding constraints, EPA will need to consider the proposed
actions for alkyl-lead in the larger context of the proposed actions for all twelve Level 1
substances.
The specific actions within the Alkyl-lead National Action Plan will be prioritized based on
several key factors such as the likelihood of health risks, amount of resources required, the
availability and willingness of non-agency partners and stakeholders, and the anticipated impact on
the amount of alkyl-lead released into the environment. These key factors need to be examined
simultaneously to determine the appropriate prioritization. For example, at the current time, data
seem to indicate that the amount of leaded aviation gasoline is significantly higher than the
amount of leaded gasoline used by the automotive racing industry. However, technical
considerations may limit the amount of progress that can be made toward an alternative aviation
fuel. On the other hand, there are fewer technical limitations associated with racing fuel and
representatives from the automotive racing industry have expressed a willingness to work with
EPA to develop alternatives. Actions that will initially be implemented as part of this action plan
are described in Sections 7.3.1-7.3.3. Actions that have been considered but are not presently
able to be implemented due to a lack of resources are described in Section 7.3.4.
Data Gaps
EPA's 1990 Clean Air Act (CAA) Inventory of Section 112 (c)(6) Pollutants estimates
national alkyl-lead emissions for source categories accounting for not less than 90 percent of the
aggregate emissions of alkyl-lead. However, sufficient data were not available to develop
emissions estimates for operations of aircraft, operations of non-road vehicles, or alkyl-lead
production. In particular, Section 112 (c)(6) of the CAA requires emissions inventories from oil
refineries, but the gross estimates of emissions that are currently provided do not also provide a
clear picture of the production and release quantities of alkyl-lead.
Additionally, other than aviation gasoline, very little data exists on current levels of leaded
gasoline use. Since 1991, the Department of Energy (DOE) stopped tracking information on the
production of leaded gasoline for non-aviation uses. Consequently, there is no readily accessible
information on how much leaded gasoline is being produced for the continued, legal use of alkyl-
lead in racing cars, off-road, non-road vehicles, etc. However, it may be possible to derive upper
bound estimates for these uses from other available information and from industry representatives.
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Finally, there is insufficient information to assess whether the remaining uses of leaded
gasoline result in adverse environmental or health effects. Most notably, there is no information
to determine whether there is increased risk of lead exposure to at-risk populations (especially
children) living in the vicinity of race tracks or general aviation airports, spectators at racing
events or air shows, and fuel handlers (aviation or racing crews).
Regulatory Constraints
The regulation of aircraft fuel lies with the FAA. However, under the CAA, EPA can
indirectly impose regulations by establishing lead emissions standards for aircraft such that the
FAA would have to restrict the lead content in gasoline. Further, under 112 (c)(6), EPA is
committed to promulgating MACT standards for aviation fuel distribution. Thus, one way that
EPA can regulate evaporative emissions is to set a particular standard for the fuel delivery system
requiring the recapture of vapors that would otherwise evolve at the gas tank.
EPA also does not have the authority under the CAA to regulate the use of unleaded
gasoline for the racing industry. There is a provision in the CAA that prohibits EPA from
regulating engines (or their fuels) that are designed solely for competition, but the regulation of
fuel could potentially occur under the TSCA Section 6 Rule.
Stakeholder Issues/Concerns
The identification of alternatives for aviation gasoline will present a technical challenge.
There are a large number of experimental aircraft with lower performance piston engines that use
unleaded gasoline, as well as various alternative fuels that have been researched. These
alternatives include those containing alcohols (e.g., ethanol), aromatics (e.g., toluene), and ethers
(e.g., MTBE and ETBE). A manganese-based additive, MMT (methyl-cyclopentadienyl
manganese tricarbonyl), has also been used in gasoline blends as an octane booster, although
research indicates that it will probably not find widespread usage due to deposit-control problems.
For many years MTBE (methyl test-butyl ether) has been used as a blending agent in gasoline to
raise the octane number, eliminate corrosive action, and serve as an oxygenate. In fact,
reformulated gasoline (containing MTBE) is required to be sold in many states to reduce air
pollution (smog) levels. Recently, however, due to evidence that MTBE is polluting groundwater
supplies, an independent Blue Ribbon panel has recommended to EPA that oil companies should
not be required to sell MTBE-blended gas, and that use of MTBE be sharply reduced (USEPA,
1999b).
While an alternative fuel for aircraft is desirable, care must be taken to balance this with
safety concerns. Aircraft are certified for very specific fuels. The performance of an alternative
unleaded high-octane aviation gasoline under all possible operational and environmental
conditions must be thoroughly tested because of concerns regarding aircraft safety.
High-performance piston aircraft engines require high-octane gasoline, and lead is extremely
efficient at raising the octane without causing any other undue performance effects. To re-certify
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aircraft for a different fuel is time-consuming and expensive. To date, EPA has not focused on
fuel alternatives due to the financial hardships it would impose on the small aircraft industry.
Although there are a large number of experimental aircraft that use unleaded gasoline for
lower performance piston engines, there appears to be no ready substitute for the 100-octane
low-lead gasoline used by high performance piston engines. However, one new fuel specification
has been approved by ASTM. This new fuel, which will be known as 82UL, is an unleaded
aviation grade fuel that can be used only by the low compression ratio segment of the
reciprocating-engine-aircraft fleet. The initial production and supply of this new fuel is currently
being studied by fuel suppliers. As a move forward in promoting 82UL, the FAA has extended
approval for use of this fuel by aircraft previously approved to use auto fuel under Supplemental
Type Certificates (STC). In addition, the FAA has recently certified another new unleaded fuel,
AGE85, developed by the National Alternate Fuels Laboratory (NAFL) at the University of North
Dakota Energy and Environmental Research Center (EERC). With the initial certification
completed, the developers of the fuel are moving forward to obtaining FAA certification for more
engine and airframe combinations (EERC, 1999).
7.2 GOALS
The goal of the PBT Strategy, to identify and further reduce risks to human health and the
environment from existing and future exposure to PBTs, is the guiding principle in the
development of the strategic approaches for alkyl-lead in this action plan. In addition, this action
plan supports several goals outlined in EPA's 1997 Five Year Strategic Plan. As required under
the Government Performance and Results Act of 1993 (GPRA), EPA's Strategic Plan describes
EPA's mission and sets forth ten major goals that serve as the framework for the Agency's
planning and resource allocation decisions. These ten goals apply to all of EPA's programs and
projects and, therefore, clearly encompass many goals, targets and programs that do not apply to
alkyl-lead. There are, however, several GPRA goals and sub-objectives that do call for programs
promoting reductions in the environmental presence of all toxics of concern, and thus effectively
contribute to the desired outcome of alkyl-lead exposure risk reduction. These broader GPRA
goals that are relevant to alkyl-lead and the associated strategy described in this report are listed
in Appendix A.
The goal of this alkyl-lead action plan is to identify and reduce risks to human health and
the environment from current and future exposure to alkyl-lead.
The overall PBT Strategy builds upon the objectives and goals contained in The Canada-
United States Strategy for the Virtual Elimination of Persistent Toxic Substances in the Great
Lakes Basin (Binational Toxics Strategy), which was established in 1997. For alkyl-lead, the
Binational Toxics Strategy identifies the following national challenge goal:
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"Confirm by 1998, that there is no longer use of alkyl-lead in automotive gasoline.
Support and encourage stakeholder efforts to reduce alkyl-lead releases from other sources. "
The Binational Toxics Strategy has the overall goal of virtual elimination of persistent
toxic substances in the Great Lakes Basin and in the case of alkyl-lead, throughout the United
States. Significant work has already been completed by EPA's Great Lakes National
Program Office to confirm the "no-use of alkyl-lead in automotive gasoline." (USEPA, 1999a)
7.3 FUTURE DIRECTION AND ACTIVITIES
7.3.1 Stakeholder Involvement
EPA considers stakeholder involvement essential to reaching the goal of the PBT
Strategy. EPA will seek stakeholder input in the development and implementation of this draft
national action plan for alkyl-lead. EPA will also invite comment on the draft national action plan
and will encourage all interested partners to join in establishing voluntary agreements to reduce
risk to human health and the environment from exposure to alkyl-lead.
The key Agency players will be the Office of International Affairs (OIA), Office of Air and
Radiation (OAR), Great Lakes National Program Office (GLNPO), Office of Mobile Sources
(OMS) Ann Arbor Facility, and the Office of Pollution and Prevention Toxics (OPPT). The EPA
PBT Alkyl-lead Workgroup will take the lead in coordinating voluntary initiatives. Primary non-
Agency stakeholders in this effort will be the Federal Aviation Administration (FAA), the National
Association of Stock Car Auto Racing (NASCAR), other racing organizations (other automobile
racing, boat racing, etc.), construction and farm machinery manufacturers and associations, the
Coordinating Research Council (CRC), Agency for Toxic Substances and Disease Registry
(ATSDR), National Oceanic and Atmospheric Administration (NOAA), the U.S. Coast Guard,
National Institute of Occupational Safety & Health (NIOSH), and Occupational Safety & Health
Administration (OSHA). EPA anticipates that each of these groups, and possibly others, will
have a significant role in reducing the use, releases, and exposure to alkyl-lead compounds. In
particular, EPA will conduct the following activities with these stakeholders:
# Auto Racing Industry: EPA will coordinate with NASCAR and NASCAR Sponsors
to encourage a voluntary unleaded phase-in partnership/program to eliminate the use
of leaded gasoline in the auto racing industry. EPA will identify and begin a dialogue
process with other auto racing stakeholders (such as the National Hot Rod
Association (NHRA) and similar associations for open wheel, motor cross, etc.) about
similar partnerships/programs.
EPA does not have the authority under the Clean Air Act to regulate the use of leaded
gasoline for the racing industry. However, the auto racing industry is investigating
the use of unleaded gasoline. Therefore, a voluntary partnership with EPA may be
the most effective means of reducing the use of alkyl-lead in the auto racing industry.
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# Federal Aviation Administration (TAA) and Coordinating Research Council (CRC):
EPA will establish a dialogue with the FAA to continue discussions surrounding the
use of leaded gasoline in aviation and the possibilities of reducing the lead content
and/or replacing leaded gasoline with unleaded. Similar discussions will be held with
the CRC task force investigating alternative (no-lead) gasoline for aircraft. EPA will
continue to support and encourage such research activities as that undertaken by the
CRC task force.
7.3.2 International Efforts
EPA will continue its commitment to international efforts to reduce the use of leaded
gasoline, as described in Section 6.2.5. This includes participation in the United Nations
Commission on Sustainable Development, Summit of the Americas, Earth Summit + 5, the G-8,
and the Great Lakes Binational Toxics Strategy.
7.3.3 Measurement
As stated in the PBT Strategy, EPA will use the following measures to track progress in
reducing risks from alkyl-lead: (1) environmental or human health indicators, (2) chemical
release, waste generation, or use indicators, or (3) programmatic output measures.
In addition to the goals and measures given in Table 5, EPA will measure progress
towards the virtual elimination of alkyl-lead production and use throughout the United States by
comparison to the following quantifiable baseline measures:
# The amount of leaded aviation gasoline produced: In 1996, U.S. refineries produced
305,000,000 gallons of aviation gasoline (USDOE, 1998).
# The amount of leaded gasoline used by the racing industry: In 1998, approximately
100,000 gallons of leaded gasoline were used by NASCAR (National Motor Sports
Council, 1999).
# The amount of anti-knock preparations imported into the US: In 1998, the United
States imported approximately 14,318,800 pounds of anti-knock preparations based
on TEL and/or TML and 1,316,800 pounds of anti-knock preparations based on lead
compounds (U.S. Department of Commerce, 1998). (These compounds are used to
make leaded fuel for aviation, racing fuel, marine vessels, etc.) Assuming anti-knock
agents containing TEL typically contain 62 percent TEL, a rough estimate for the
amount of TEL imported into the U.S. in 1998 would be about 9.7 million pounds of
TEL. However, according to Ethyl Corporation (1999), only approximately
2,866,000 pounds of anti-knock fluid were consumed in the U.S. in 1998, equating to
approximately 1,129,000 pounds of alkyl-lead. Approximately 331,000 pounds of
this anti-knock fluid was used to serve the NASCAR industry.
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Table 5. Measures of Progress and GPRA Goals for Actions to Reduce Risks from
Alkyl-lead
Focus
Action
GPRA
Goal
Measure of Progress
1. Contribute to
international
efforts
# Support international efforts to reduce the use of
leaded gasoline
Goal 6
Number of countries that have
initiated/reached a phase-out of
leaded gasoline; amount of
leaded gasoline used worldwide
2. Pursue
voluntary
initiatives
# Encourage a NASCAR voluntary phase-out
partnership/program
# Identify contacts in other racing (auto and non-
auto) organizations to initiate similar
programs/partnerships
Goal 4,
Goal 8
Goal 4
NASCAR Agreement
Agreements with other
organizations including (boating,
non-auto racing, construction,
farm machinery, etc.)
# Identify contacts in other organizations to initiate
similar programs/partnerships
Goal 4
Continued dialogue with CRC
and FAA
# Work with Coordinating Research Council and
FAA to promote alternative, unleaded fuels and
the phase-out of leaded aviation gasoline
Goal 4
Reductions in lead exposure and
blood-lead levels among at-risk
populations
# The lead content in aviation gasoline: Currently, aviation gasoline has a maximum
lead TEL standard of 0.13 mL TEL/L for Grade 80, 0.53 mL TEL/L for Grade
100LL, and 1.06 mL TEL/L for Grade 100. The maximum lead standard is
0.14 g Pb/L for Grade 80, 0.56 g Pb/L for Grade 100LL, and 1.12 g Pb/L for
Grade 100 (ASTM, 1997).
# The number of petroleum refining facilities submitting lead or lead compound reports
to TRI: In 1995, 29 petroleum refining facilities (SIC 2911) submitted forms to TRI
(USEPA, 1998b). This number may have an increase from 1995 levels with the
proposed threshold reductions. Also, this number may change as reporting
requirements are refined from lead and lead compounds to alkyl-lead compounds.
7.3.4 Actions Considered but Not Able to Be Implemented Due to a Lack of Resources
As discussed in Section 7.1, proposed actions for alkyl-lead were evaluated in the larger
context of proposed actions for all Level 1 substances and in the context of available resources.
Following are actions that were considered to have merit but which could not be implemented or
planned at this point in time in light of other higher priorities.
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Proposed Outreach/Education
EPA, along with others, has conducted an extensive outreach/education campaign to make
the general public aware of the dangers of lead. However, these efforts have primarily focused on
inorganic forms of lead such as those found in lead-based paint. While EPA will continue its
efforts to inform the general public on the dangers of inorganic lead, it was proposed that the
Agency also investigate new possibilities for expanding the outreach/education campaign to
include targeted audiences. For example, EPA might investigate the possibility of having a well
known NASCAR driver support and encourage "lead free" races as a way of reinforcing the
negative environmental and health impacts of using leaded gasoline.
Other possible outreach/education campaigns were also raised. For example,
outreach/education campaigns on the dangers of alkyl-lead (especially the hazards of dermal
exposure) could be targeted to persons that routinely fuel vehicles with leaded gasoline.
Proposed Research/Information Needs
Research on several issues was proposed to address the data gaps identified above and as
the initial step in promoting the voluntary phase-out of leaded gasoline. In particular, the
following research activities and information collection efforts were considered:
# Refine CAA 112(c)(6) Emission Estimates: The 1990 CAAA require EPA " to
identify the source categories and subcategories emitting alkylated lead
compounds. " Further, "the source categories and subcategories identified must
account for 90 percent of the alkylated lead emissions... " EPA completed this
requirement in 1998. However, since the development of these emission estimates,
the overall use of leaded gasoline may have been further reduced. Further, though
estimates are given for several non-road engine and vehicle categories, estimates are
not provided for competitive use vehicles (such as those used by NASCAR). EPA
considered developing rough estimates of the potential emissions from race cars
through modeling of emissions, monitoring during races, soil sampling in the vicinity
of race tracks, or other means as appropriate.
# Investigate Exposure to At-Risk Populations: As discussed above, gasoline
containing alkyl-lead compounds is still being used today and as such there remains
the potential for exposure to certain populations. EPA considered research activities
to evaluate the risk for these subpopulations. Of particular concern are spectators of
racing events and nearby residents.
# Update Inventory of Leaded Gasoline Production and Use: As stated above, the
Department of Energy (DOE) stopped tracking information on the production of
leaded gasoline for non-aviation uses. Information on the extent to which leaded
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gasoline is currently used could be developed through published statistics, discussions
with petroleum manufacturers, and discussions with end-users.
# Determine the Availability of Leaded Gasoline and Potential for Misfueling: The
extent to which racing gasoline containing lead is available for purchase at the
roadside could be estimated. Although EPA's Office of Enforcement no longer
routinely screens for lead during routine inspections at service stations, information on
the extent to which misfueling occurs could be consolidated and estimates of the
extent of misfueling developed.
# Determine the Extent to Which Leaded Gasoline Is Available for Purchase at Marine
Fuel Docks: It is unknown whether leaded gasoline is still being widely used as a
marine fuel. However, fuel is known to overflow from fuel tanks frequently during
operations into waterways, lakes, etc. While the quantities may be small, the number
of such sites may be much larger than for race tracks.
Stakeholder Involvement
Non-Auto Racing Organizations: EPA considered investigating the extent to which
leaded racing gasoline is employed by non-auto racing organizations such as marine
racing, motorcycle racing, snowmobile racing, etc. EPA considered initiating a dialogue
process with representatives from these organizations to establish a voluntary phase-out of
leaded gasoline.
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8.0 REFERENCES
ASTM (1997), "Standard Specification for Aviation Gasolines," Annual Book of ASTM
Standards, Designation D910-97.
EERC (1999), North Dakota Energy and Environmental Research Center, "FAA Certifies
Low-Cost, Environmentally Friendly, Ethanol-Based Aviation Fuel." Press Release,
www.eerc.und.nodak.edu.
Ethyl Corporation (1999), Comments on Draft National Action Plan for Alkyl-Lead.
National Motor Sports Council (1999), Personal communication.
Purvis Brothers, Inc. March 6, 1999. Fuel Technology Series (http://nauticom.net/users/macpir/
av3.htm Accessed: 8-19-99).
U.S. Bureau of the Census (1998), Imports/exports History Database, 1993-97 Summary.
(http://govinfo.kerr.orst.edu/import/import.htmn
U.S. Department of Commerce (1998), International Trade Association.
(http://www.ita.doc.gov/industrv/otea/Trade-Detail/Latest-December/Exports/38/381111.html
Accessed:8-10-99)
U.S. Department of Energy. December, 1991. Petroleum Marketing Annual, 1990. Energy
Information Administration, Washington, DC. DOE/EIA-0487(90).
U.S. Department of Energy (1998), Petroleum Supply Annual, 1998, Volume 1. Energy
Information Administration, Washington, DC.
USDHHS (1997). U.S. Department of Health and Human Services, Public Health Service,
Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Lead, Draft for
Public Comment," August 1997.
USEPA, Unpublished data (1991). Amount of leaded and unleaded gasoline produced in the
United States, 1967-1991.
USEPA, (1993). Estimation of Alkyl-lead Emissions. Final Report. Prepared by TRC
Environmental Corporation.
USEPA, EC (1997a), "The Great Lakes Binational Toxics Strategy: Canada-United States
Strategy for the Virtual Elimination of Persistent Toxic Substances in the Great Lakes,"
April 7, 1997.
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USEPA (1997b), "National Air Pollutant Emission Trends Report, 1900-1996," Office of Air
Quality Planning and Standards, EPA-454-R-97-011, December 1997.
USEPA (1998a). 1990 Emissions Inventory of Section 112(c)(6) Pollutants.
USEPA (1998b). 1996 Toxics Release Inventory Database.
USEPA (1998c). "National Air Quality and Emissions Trends Report, 1996," Office of Air
Quality Planning and Standards, U.S. Environmental Protection Agency, EPA-454-R-97-013,
January 1998.
USEPA (1998d). Personal communication with George Lawrence, USEPA, Office of
Enforcement, 1998.
USEPA (1999a). "U.S. Challenge on Alkyl-Lead: Report on Use of Alkyl-Lead in Automotive
Gasoline," Draft Report, www.epa.gov/glnpo/bns.
USEPA (1999b). Press Release on July 27, 1999, Statement by Carol M. Browner, U.S.
Environmental Protection Agency Administrator, on Findings by EPA's Blue Ribbon MTBE
Panel.
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GLOSSARY
AT SDR
Agency for Toxic Substances and Disease Registry
CAA
Clean Air Act
CAAA
Clean Air Act Amendments
CRC
Coordinating Research Council
FAA
Federal Aviation Administration
GLNPO
Great Lakes National Program Office
GPRA
Government Performance and Results Act of 1993
NASCAR
National Association of Stock Car Auto Racing
NAAQS
National Ambient Air Quality Standards
NIOSH
National Institute of Occupational Safety & Health
NOAA
National Oceanic and Atmospheric Administration
OAR
EPA Office of Air and Radiation
OIA
EPA Office of International Activities
OMS
EPA Office of Mobile Sources
OSHA
Occupational Safety & Health Administration
PBT
Persistent, Bioaccumulative, and Toxic
TEL
Tetraethyllead
TML
Tetramethyllead
TRI
Toxics Release Inventory
TSCA
Toxic Substances Control Act
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APPENDIX A:
LIST OF KEY CONTACTS
AND GRPA GOALS
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LIST OF KEY CONTACTS
I Name
Organization
Phone |
EPA STAFF
Jim Caldwell
US EPA, OMS, Fuels and Energy Division
(202) 564-9303
Sylvia Correa
US EPA, OIA, Office of Technology Cooperation and Assistance
(202) 564-6443
Anita Cummings
USEPA, OSW
(703) 308-8303
Laurel Driver
US EPA, OAQPS, Emissions Factors and Inventory Group
(919) 541-2859
Tony Kizlauskas
US EPA, GLNPO
(312) 353-8773
George Lawrence
USEPA, OECA
(202) 564-1307
Paul Matthai
USEPA, OPPT
(202) 260-3385
Ed Ohanian
USEPA, OW
(202) 260-7574
Erv Pickell
USEPA, OECA
(202) 969-6476
Janet Remmers
USEPA, OPPT, Chair, Alkyl-lead Workgroup
(202) 260-1583
Kate Sijthoff
USEPA, OR
(202) 260-0424
Hugh Tilson
USEPA, ORD
(202) 541-2671
Andrew Teplitzky
USEPA, OR
(202) 260-4088
STAKEHOLDER AND OTHERS
Bill Bader, Sr.
International Hot Rod Association
(419) 663-6666
Duane Bordrick
Tosco Corporation
(925) 370-3660
Jerry Cook
NASCAR
(904) 947-6724
Nicholas W. Craw
Sports Car Club of America
(303) 694-7222
Arnold D'Ambrosa
U.S. Offshore Racing Association
(732) 892-3000
Paul Dodson
International Marina Institute
(941) 480-1212
James Erickson
Federal Aviation Administration
(202) 267-3576
Dallas Gardner
National Hot Rod Association
(626) 914-4761
Bill Joiner
Tosco Corporation (76 Racing Division)
(847) 310-6840
Edward Klim
International Snowmobile Manufacturers Association
(517) 339-7788
Ken Knopp
Federal Aviation Administration
(609) 485-5693
Earl Lawrence
Experimental Aircraft Association
(800) 236-4800
William D. Mitchelson
National Boating Federation
(414) 352-0967
Robert Rasor
American Motorcyclist Association
(614) 856-1900
Jerry Roper
Ethyl Corporation
(804) 788-6023
Mark Rumizen
Federal Aviation Administration
(781) 238-7113
Bill Savage
SCORE International
(760) 599-1013
William Schultz
General Aviation Manufacturers Association
(202) 393-1500
Gloria Urbin
American Power Boat Association
(810) 773-9700
Joseph Valentine
Texaco Additives International Research and Development
(914) 838-7718
Ron Wilkinson
CRC
(334) 227-8306
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GPRA GOALS
The goal of this action plan is to identify and reduce risks to human health and the
environment from current and future exposure to alkyl-lead. This goal is consistent with the goal
of the PBT Strategy. Achieving this goal will help EPA meet the following Government
Performance and Results Act of 1993 (GPRA) goals that pertain to alkyl-lead:
GPRA Goal 1: Clean Air
# By 2010, reduce air toxics emissions by 75% from 1993 levels to significantly reduce
the risk to Americans of cancer and other serious health effects caused by airborne
toxics;
# By 2005, improve air quality for Americans living in areas that do not meet NAAQS
for carbon monoxide, sulfur dioxide, lead, and nitrogen dioxide;
GPRA Goal 4: Preventing Pollution and Reducing Risk in Communities. Homes. Workplaces,
and Ecosystems
# By 2005, the number of young children with high levels of lead in their blood will be
significantly reduced from numbers in the early 1990's;
GPRA Goal 6: Reduction of Global and Cross-Border Environmental Risks
# By 2005, consistent with international obligations, the need for upward harmonization
of regulatory systems, and expansion of toxics release reporting, reduce the risks to
U.S. human health and ecosystems from selected toxics (including pesticides) that
circulate in the environment at global and regional scales. Results will include a 50%
reduction of mercury from 1990 levels in the United States. Worldwide levels of lead
in gasoline will be below 1993 levels;
GPRA Goal 8: Sound Science. Improved Understanding of Environmental Risk, and Greater
Innovation to Address Environmental Problems
# Incorporate innovative approaches to environmental management into EPA programs,
so that EPA and external partners achieve greater and more cost-effective public
health and environmental protection.
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