CLEAN
AIR
AMD
CLEAN
The
Report
of
the
Blue
Ribboh
Oxygenates
in
Panel
on
Gasoline
in
Panel
to
review
the
us(
The
Panel
was
appointee
rntaf
Protection
Agency'!
was
originally
establishec
I
the
requirements
of
thg
APP.
8
9
(a.

led
technical,
analytical
pport
for
this
report.

eptem
ber
1999
...
...*
>.
A
......
U.
.......................
_
....
a.
........
,
.
I
1
I
CHAPTER
1
.
EXECUTIVE
SUMMARY
....................................
'.

CHAPTER
2
.
ISSUE
SUMMARIES
....................................................
Water
contamination
...................................................
A
.
TABLE
OF
CONTENTS
..........
1
15
17
Page
IV
.
Behavior
.......................................................
V
.
AppendixA
...........................................................
B
.
AirQualityBenefits
....................................................
I
.
Introduction
...................................................
I1
.
Federal
RFG
Program:
Requirements
and
Benefits
......................
I11
.
The
Impact
on
RFG
if
Oxygenates
are
Removed
........................
IV
.
Other
Air
Quality
Considerations
for
Oxygenates
...........
:
V
.
Appendix
B
...............................................
'.
C
.
Prevention.
Treatment.
and
Remediation
...................................
I
.
Introduction
.....................................................
I1
.
Sources
and
Trends
of
Water
Quality
Impacts
..........................
I11
.
Release
Prevention
and
Detection
..................................
IV
.
Underground
Storage
Tanks
...........................
.I
.

V
.
Protection
of
Drinking
Water
Sources
and
Water
Quality
Managerient
VI
.
Treatment
of
Impacted
Drinking
Water
...................
'

VI1
.
Remediation
....................................................
Fuel
Supply
and
Cost
....................................................
I
.
Introduction
.....................................................
I1
.
Industry
Overview
...................................
;
Impact
of
Fuel
Requirement
Changes
on
Supply
............
'
Cost
Impacts
of
Changing
Fuel
Reformulations
........................
AppendixD
..............................................
*
~
1
­
*

Comparing
the
Fuel
Additives
.................................
;.
I
.
Introduction
.....................................................
MTBE
.........................................................
I1
.
111
.
Ethanol
...........................................
.I
'

IV
.
Other
Ethers
....................................................
V
.
Other
Alternatives
...................................
,

AppendixE
...........................................................
Drinking
Water
Standards
.............................
.,.

Wintertime
Oxfiel
Program
...........................
'.

D
.

I
I11
.
IV
.

E
.

.­
21
..........
22
25
27
27
27
31
...........
35
..........
38
..........
42
45
45
45
50
..........
52
.....
53
...........
55
57
67
67
...........
68
...........
72
75
*
.
.
*
*
*
79
..........
81
81
81
84
86
...........
86
88
...........

CHAPTER
4
.
DISSENTING
OPINIONS
................................................

~

LIST
OF
PANEL
MEMBERS
AND
PARTICIPANTS
...........................
'

REFERENCES
..........................................................
'
99
..........
107
..........
113
TABLE
OF
CONTENTS
(continued)

GLOSSARY
OF
TERMS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
,
.
.
.
.!
.

...
Page
..­.........
121
CHAPTER
1.
EXECUTIVE
SUMMARY
,
I
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
butadieneY
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
cdntains
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
RIG
requirements
ail
fuel
blends
created
without
oxygenates
could
maintain
the
benefits
provided
today
by
oxygenated
R$
G.

At
the
same
time,
the
use
of
MTBE
in
the
program
has
resulted
in
growing
detections
of
AdTBE
in
drinking
water,
with
between
5
percent
and
10
percent
of
community
drinking
water
supplies
in
high
oxygenate
use
areas'
showing
at
least
detectable
amounts
of
MTBE.
The
great
majority
of
these
detections
to
date
have
been
well
below
IeveIs
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
US.
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)
I
1
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
bels
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
avaiIability
­­
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
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
RFG
provides
considerable
air
quality
improvements
and
benefits
for
millions
of
US
public
health.

8
citizens.
I
­
8
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.

2
e
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.

e
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
SingZepackage
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
weI1,
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).

Strengthen
release
detection
requirements
to
enhance
early
detection,
particularly
in
vulnerable
areas,
and
to
ensure
rapid
repair
and
remediation.
­
C.

d.
Require
monitoring
and
reporting
of
MTBE
and
other
ethers
in
groundwater
at
all
UST
release
sites.

3
2.
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.

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
identie
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
Welihead
Protection
Areas
including:

I
­
enhanced
permitting,
design,
and
system
installation
requirements
for
USTs
and
pipelines
in
these
areas;
strengthened
efforts
to
ensure
that
non­
operating
USTs
ate
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;

4
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.

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
finding;

b.
Establishing
another
form
of
fbnding
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
MT3E
in
groundwater
when
compared
to
other
components
of
gasoline,
states
in
RFG
and
Oxyfuel
areas
should
reexamine
and
enhance
based
on
their
proximity
to
drinking
water
supplies.
­
state
and
federal
"triage"
procedures
for
prioritizing
remediation
efforts
at
UST
sites
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
publidprivate
efforts
underway.
Recommendations
for
Blendinv
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
wit1
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
stabifity,
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
Pane1
recommends
an
integratedpackage
of
actions
by
both
Congress
and
EPA
that
should
be
implemented
as
quickly
aspossihle.
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
andor
eliminate
the
use
of
gasoline
additives
that
threaten
drinking
water
supplies;

0
Action
by
Congress
to
remove
the
current
2
percent
oxygen
requirement
to
ensure
that
adequate
fuel
supplies
can
be
bIended
in
a
cost­
effective
manner
while
quickly
reducing
usage
of
MTI3E;
and
0
Action
by
EPA
to
ensure
that
there
is
no
loss
of
current
air
quality
benefits.

The
Oxvgen
Reauirement
10.
The
current
Clean
Air
Act
requirement
to
require
2
percent
oxygen,
by
weight,
in
RFG
must
be
removed
in
order
to
provide
flexibiJity
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
­
1
1.
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.

6
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
CaIifornia
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
I1
and
Conventional
Gasotine
programs
to
define
and
maintain
in
RFG
11
the
real
world
performance
observed
in
RFG
Phase
I
while
preventing
deterioration
of
the
current
air
quality
performance
of
conventional
gasoline?

There
are
severa1
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
M
m
E
should
be
phased
out
completely.
The
Panel
recommends
that
Congress
act
quickly
to
clarify
federal
and
state
authority
to
regulate
andor
eliminate
the
use
of
gasoline
additives
that
pose
a
threat
to
drinking
water
supplies?

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
fiom
the
Panel's
recommendations
wiI1,
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
fiom
any
additional
benefits
that
might
accrue
from
the
sulfur
changes
currently
under
consideration.

'
Under
$2
1
1
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
$2
1
l(
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:
­

I
)
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.
(continued
...)

i
7
initial
efforts
to
reduce
should
begin
immediately,
with
substantial
reductions
to
begin
as
soon
as
Recommendation
IO
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
MlBE
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
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:

'
(...
continued)

2)
states
have
taken
necessary
measures
to
restrictleliminate
the
presence
of
gasoline
in
the
water
resource.
To
maximize
the
uniformity
with
which
any
changes
are
implemented
and
minimize
impacts
on
cost
and
he1
supply,
the
Panel
recommends
that
EPA
establish
criteria
for
state
waiver
requests
including
but
not
limited
to:

a.

b.
C.

d.
Water
quality
metrics
necessary
to
demonstrate
the
risk
to
water
resources
and
air
quality
metrics
Compliance
with
federal
requirements
to
prevent
leaking
and
spilling
of
gasoline.
Programs
for
remediation
and
response.
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.
­
to
ensure
no
loss
of
benefits
from
the
federal
RFG
program.

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.

8
;in
as
nt
­
out
the
%

suit
e
i
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.
Identi&
and
begin
to
collect
additional
data
necessary
to
adequately
assess
the
current
and
potential
future
state
of
contamination.

The
Wintertime
Oxvfuel
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,
ethanot
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
toot
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
ExDerience
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,
broad!
y­
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
quafity
benefits,
including
the
development,
to
the
maximum
extent
possible,
of
field
monitoring
and
cmissions
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
quaIity
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.

9
...

10
B
,
Summary
of
Dissenting
Opinion
By
Todd
C.
Sneller,
Member
EPA
Blue
Ribbon
Panel
The
complete
text
of
ME
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,
Z
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
1990
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.

11
I2
LYONDELL
CHEMICAL
COMPANY
SUMMARY
OF
DISSENTING
REPORT
The
complete
text
of
Lyondell
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)
wilI
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
reff
ect
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.
­
.,
i
i
..
..
'
!

I
.

..

f
14
:

..
.

1
.
."
..­
­­..
­.
..
.
­.
.
.

7
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.

15
i
...

I6
..
..
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.

11.
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
Surve);
(USGS)
report
examines
this
issue
with
respect
to
ambient
ground
water.
This
report
assessed
studies
conducted
between
1985
and
I
995
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.

..+
..
.?
t:
'

,.
&;:
'
:

17
'
I
Table
1.
Summary
of
Studies
Examining
MTBE
Contamination
of
Drinking
W
ater
Sources
~.

j
California
I
Maine
Maine
'
USGS/
EPA12
1
Public
Water
,
Public
Water
1
Privatewater
I
'
usGsmAwQA
i
Northeastern
State
I
Sources'
(wells)
!
Sources'
(wells)
j
Sources'
(wells)
'
;
Stud,+
'
Studies'
(wells)

i
Concentration
i
(PPW
I
N­
5,195
N­
793
1
~~9
4
6
(9
5
%~1
)
1
m
L
4
.2
p
P
b
1
N­
1,190
N=­
2,743
mJA*
I
PPb
:
mL+*
I
PPb
;
(censor
level)
MDL­
I
ppb'

Non­
Detects
­99%
­84.1%
­84.3%
­94.7%
­92.8%

MDL
­
5
ppb
NIA'
­14.6%
­12.8%
­
4.5%
­5.0%

5­
20
ppb
­0.3%
­0.9.
h
­1.5%
4.4%
­1.3%

>
20
ppb
­0.3%
­0.4%
­1.5%
4
.4
%
­0.9%

'California
Department
of
Health
Services,
April
22,
1999
(
u;
ww.
dlis.
ca.
e;
ov/~
s/
ddwcm/
chcmical~~
TBE/
int~
summaw.
htni).
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
pulposes
of
counting
"sources."
zAlthough
there
have
been
detects
below
5
ppb,
such
detections
are
not
required
to
be
reported.
'AX.
Smith,
Analysis
of
MTBE
data
in
public
and
private
water
sources
sampled
as
part
of
the
Maine
MTBE
Drinking
Water
Study
­

'Data
are
available
for
other
sources
(e.&
springs
and
surface
water).
'P.
J.
Squillace,
D.
A.
Bender,
J.
S.
Zogorski,
Analysis
of
USGS
data
on
MTBE
in
wells
sampled
as
part
of
the
National
Water
Quality
%.
J.
Grady,
Analysis
of
the
Preliminary
Findings
of
the
12­
State
MTBENOC
Drinking
Water
Study,
1993­
1998:
Communication
to
US.

'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
"MDt"
=
Minimum
Detection
Level.
Preliminary
Report,
October
13,
1998:
Written
Communication
to
U.
S.
EPA,
May
20,
1999.

Assessment
Program,
1993­
1998:
Written
Communication
to
U.
S.
EPA.
May
20,
1999.

EPA,
May
20,1999.

highest
reported
concentration
range.

MTBE
was
the
second
most
commonly
detected
VOC
in
water
fiom
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
win
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.
RFGIOXY
Areas
Versus
Non­
RFG/
OXY
Areas
Data
from
the
joint
USGS
and
U.
S.
Environmental
Protection
Agency
(EPA)
12
Northeastern
State
study7
and
the
USGSNAWQA
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
WSGSEPA
Northeastern
State
study
indicate
that
MTBE
is
detected
ten
times
more
often
in
drinking
water
from
'
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.

U.
S.
Environmental
Protection
Agency
and
United
States
Geological
Survey,
Preliminary
Finding
of
the
IZ­
Stare
h4TBEWOC
Drinking
Water
Retrospective,
1999.

18
community
water
sys
jn
non­
RFG/
OXY
are
UG/
OXY
areas
(Tab
ppb)
are
19
times
mol
detections
are
clearly
ethylbenzene,
and
xyl
G
)
or
oxygenated
fuels
(OXY)
than
tes
a
similar
detection
frequency
in
that
higher
levels
of
MTBE
(>
20
n
non­
R.
FG/
OXY
areas.
9
MTBE
2X
(benzene,
toluene,

Table
2.
on­
RFG/
OXY
Areas"

Non­
RFG/
OXY
Areas
in
the
United
States
(2,263)
2%
1
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."

C.
Co­
Occurrence
of
MTBE
and
Other
Gasoline
Components
For
co­
occurring
components
in
gasoline,
preliminary
data
from
both
the
USGSEPA
12
Northeastern
State
study
and
the
USGSNAWQA
study
shows
that
MTBE
is
generally
detected
in
groundwater
samples
that
contain
another
VOC,
but
is
not
associated
with
BTEX
detections.
In
USGSEPA
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
USGSNAWQA
ground
water
samples
containing
MTBE,
with
only
13
percent
of
the
samples
with
MTBE
also
detecting
BTEX.
I3
'
Stephen
Grady
and
Michael
Osinski,
"Preliminary
Findings
of
the
12­
State
MTBENOC
Drinking
Water
Retrospective,"
presentation
at
the
April
1999
MTBE
Blue
Ribbon
Panel
meeting.

Paul
Squillace,
"MTBE
in
the
Nation's
Ground
Water,
National
Water­
Quality
Assessment
(NAWQA)
Program
Results,"
presentation
at
the
April
1999
MTBE
Blue
Ribbon
Pane1
meeting.

lo
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.

"
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.

'*
Stephen
Grady
*and
Michael
Osinski,
"Preliminary
Findings
of
the
12­
State
MTBENOC
Drinking
Water
Retrospective"
presentation
at
the
April
1999
MTBE
Blue
Ribbon
Panel
meeting.

''
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.

19
111.
Sources
The
most
frequent
sources
of
higher
levels
of
ground
water
contamination
(greater
than
20
ppb)
I4
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.
California's
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
6
10
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.
Maine16
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"

The
use
of
motorized
watercraft
yielded
concentration
levels
from
0.1
ppb
to
12
ppb.

l
4
Office
of
Science
and
Technology
Policy,
National
Science
and
Technology
Council,
Interagency
Assessment
of
Oxygenated
Fuels,
June
1997.

Komex
H20
Science,
Draft
Investigation
Report
of
MTBE
Contamination:
City
of
Santa
Monica,
Charnock
Well
Field
Los
Angeles,
California,
March
2
1,
1997;
Geomatrix
Consultants,
Inc.,
Summary
oflMTBE
Groundwater
Monitoring
Results,
Fourth
Quarter
1998,
Charnock
Well
Field
Regional
Assessment,
Los
Angeles,
California,
April
1,
1999.

l6
B.
Hunter
et
al.,
"Impact
of
Small
Gasoline
Spills
on
Groundwater,"
preliminary
report
abstract
presented
at
the
Maine
Water
Conference
Meeting,
April
1999.

I'
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.

20
d.
MetroDolitan
Water
District
of
Southern
Caiifornia
Monitoring
Program"

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.

e.
OSTP
Re~
01­
t'~

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.

N.
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
(Le.,
BTEX).
Zo
In
surface
water,
volatilization
of
MTBE
at
the
air­
water
interface
is
a
significant
contributor
to
decreased
concentrations
of
MTBE."

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
I
s
Metropolitan
Water
District,
Methyl
Tertiary
Butyl
Ether
Monitoring
Program
ut
the
Metropolitan
Water
District
of
Southern
California,
monitoring
program
update,
April
1999.

l
9
Office
of
Science
and
Technology
Policy,
National
Science
and
Technology
Council,
Interagency
Assessment
of
Oxygenated
Fuels,
June
1997,
pp.
2­
33
­
2­
35.

2o
A.
M.
Happel
et
al.,
An
Evaluation
ofMTBE
impacts
to
Culyornia
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.

*'
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
Geoffiey
S.,
Schladow.

21
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
oficials
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
majority
of
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.
Sei.
Tech.,
1996,35,9­
16.

2s
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
Eflects
Analysis
on
Methyl
Tertiary­
Butyl
Ether
(MTBE)),
December
1997.

22
F
`

i
*.
public
groundwater
supply
wells
will
still
not
be
monitored
for
MTBE.*
'
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.

€3.
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
1
Maine
(35
ppb)
New
Jersey
(70
ppb)
1
:
New
York
(50
ppb)

~

South
Carolina
(20­
40
ppb)
States
with
Primary
Drinking
Water
Standards
(health­
based)

State
with
a
Secondary
Standard
(aesthetic)
California
(5
ppb);
enforceable
States
with
Enforceable
Guideiines
Michigan
(240
ppb);
health­
based
West
Virginia
(20­
40
ppb);
EPA
Advisory
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
(1
5
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
States
with
a
Guideline
or
Action
Level
in
Place
Source:
U.
S.
Environmental
Protection
Agency.

Water
suppliers
are
required
to
monitor
for
volatile
organic
compounds
and
MTBE
can
be
analyzed
by
the
21
Same
analytical
methods
and
therefore
could
be
included
along
with
scheduled
volatile
organic
compound
sampling.

23
­
.
,.
.
.

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.
.
.
I
,.
.
.
.
,.
.
.
..
­
­
_..
.
..
­
.­.
...
­.
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
(NO,).
In
general,
these
programs
have
resulted
in
greater
emission
reductions
than
statutorily
required.

11.
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
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
NO,?
9
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..
Based
on
separate
cost
effectiveness
analyses
conducted
by
both
the
U.
S.

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
NO,,
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
NO,,
VOC,
and
toxics,
relative
to
1990,
for
that
fuel.
Phase
I
of
the
program
began
in
1995.
Phase
11,
scheduled
to
begin
on
January
1
,
2000,
will
implement
more
stringent
NO,,
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,
NO,,
and
toxic^.^
'
Toxics
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
(continued..
.)

27
reductions
in
particular
were
substantially
greater
than
the
standard
(an
over
33
percent
reduction
versus
a
17
percent
requirement).
(Refer
to
Figures
B
1
through
B3
in
this
Issue
Summary's
Appendi~).~
'
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
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
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
I1
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
B
1
in
Appendix
B.

30
(.;.
continued)
universe
of
RFG
producers
or
importers.
The
RFG
survey
data
are
derived
from
a
carefully
planned
statistical
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
US.
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.

28
Table
BI.
Typical
Fuels
and
Standards
­
I
Federal
RFG
Phase
I
Federal
RFG
Phase
I
I
Conventional
Fuel
Parameter
Gasoline
Actual'
Comp'ex
Averaging
California
RFG
'
Averaging
Reid
Vapor
Pressure
(psi)
8.7R.
8
7.9R.
O
(8.0/
7.1)
2
(Summer)
Avg.
Std.
Actual
Sulfur
(ppm)
339
190
(285)
(1
50)
20
30
Oxygen
(wt%)
c0.5
2.26
2.1
min
2.1
min
2.07
(2.0)

Aromatics
(vol%)
32
26
(32)
(25)
23
22
Olefins
(~
01%)
13
10
(1
0)
(11)
4
4
E200
(%)
41
49
(45)
(49)
51
(49)

E300
(%)
83
83
(83)
(87)
89
(91)

.95
max
0.55
0.8
Benzene
(vel%,)
1.5
0.68
0.95
max
Phase
II
complex
model
performance
(A
reduction
from
I990
baseline)
of
these
fuels:

VOC
performance
26.1
22.1
29.8
29.9
29.6
NOx
Performance
5.3
1.4
6.8
14.6
14.7
Toxics
performance
30.1
19.7
28.4
37.0
34
A
1
Standard
Standard
"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
perse.
but
indicate
the
average
properties
a
summer
fuel
must
have
to
meet
the
emissions
performance
standards.
The
'/"
indicates
'NorthlSouth"
specific
values.
South
(VOC
Control
Region
1)
values
were
used
in
performance
comparisons.

As
shown
in
Table
1,
Phase
I1
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
I1
also
requires
reductions
that
are
greater
than
the
actual
reductions
achieved
in
Phase
I.
However,
for
both
air
toxics
and
benzene,
the
Phase
I1
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
vocs
NOx
Toxics
Benzene
Oxygen
Northern
States:
17%
RFG
Phase
I
(1995­
1999)
Southern
States:
37%
1.5%
17%
1%
2.0
wt%

Northern
States:
21.2%
(4.9%
Average;

3,8%
­
7,4%
(33.2%
Average;

0.68
'Yo
2.0
WtYO
23.7%
­36.9%
Av2,
20.3
­
25.0%
Range
I
1998
Southern
States:
39.4%
Actual
RFG'
Phase
Range)
Range)

Av,
38.4
­
40.3%
Range
RFG
Phase
I1
(2000)
27%
6.8%
22%
1
YO
2.0
wt%

29.6%
14.7
34.4
0.8
0
­
2.0
wt%
CaRFG
Standards
(approx.)

'1998
RFG
Compliance
Survey
Data
(summer
surveys),
completed
by
the
RFG
Survey
Association.
'Av"
=
the
average
of
the
individual
area
results
weighted
by
estimated
gasoline
volume
in
each
area.

29
I.
B.
CaRFG
Program
Also,
as
shown
in
Table
1,
the
California
RFG
program
has
in
place
more
stringent
standards
for
its
Phase
I1
than
Federal
RFG,
in
particular
for
NO,,
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
(ie.,
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
esfimated
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,
NO,,
toxics).
This
analysis
indicates
that
sulfur
was
the
primary
factor
influencing
relative
VOC
and
NO,
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
NO,
performance.

30
Table
B2.
Chicago
and
Milwaukee
Data
Chicago
Milwaukee
National
Average
MTBE
(wt%
oxygen)
1.62
0.08
0.06
ETBE
(wt%
oxygen)
0
0
0
Ethanol
(wt%
oxygen)
0.5
1
3.38
3.39
TAME
(wt%
oxygen)
0.12
0
0
RVP
(psi)
region
2
7.9
7.9
7.9
SULFUR
(ppm)
190
255
26
1
E200
(%)
49.4
50.7
50.9
E300
(%)
82.7
81.8
82.2
AROMATICS
(~
01%)
26.0
25.1
24.9
OLEFINS
(~
01%)
.
10.3
6.7
7.0
BENZENE
(~
01%)
0.68
0.90
0.99
111.
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
D1
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
I1
RFG
if
oxygenates
are
not
required.
Because
the
Phase
I1
performance
standards
for
VOCs
and
NO,
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
I1
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
FWG
Survey
Data.
'

31
B.
Air
Toxics
Current
RFG
over
complies
with
both
the
Phase
I
and
planned
Phase
I1
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.

8
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.

8
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
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
refininghlending
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.

32
e
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
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.
O%,
.5%,
1
.O%,
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
1
99737.
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
unique3'.

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.
Therefo.
re,
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
~orrelations,
3~
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
I1
and
Conventional
Gasoline
programs
to
define
and
maintain
in
RFG
I1
the
real
world
37
NESCAUM,
RFGMTBE
Findings
and
Recommendations,
Boston,
MA,
August,
1999.

38
University
of
California,
Health
and
Environmental
Assessment
of
MTBE,
Volume
I.
Summary
and
Recommendations,
P.
16,
November
1998.

39
NESCAUM,
RFGMTBE
Findings
and
Recommendations,
Boston,
MA,
August,
1999.

33
40
EPA
estimate
based
on
complex
and
MOBILE
model
calculations.

41
Colorado
Department
of
Public
Health
and
Environment
(Ken
Nelson
and
Ron
Ragazzi),
The
Zmpact
of
a
IO
percent
Ethanol
Blended
Fuel
on
the
Exhaust
Emissions
of
Tier
0
&
Tier
I
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
REPOS].
The
FTP
is
based
on
typical
urban
driving
patterns.
The
Unified
Cycle
has
higher
speeds
and
accelerations
than
the
FTP,
and
the
REP05
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),
COY
NOx,
carbon
dioxide
(CO,)
and
fine
particulate
(PM
10
and
smaller).

The
study
reported
that
FTP
particulate
emissions
were
reduced
with
the
oxygenated
fuel.
For
the
FTP,
a
mean
absolute
reduction
of
3.3
1
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
(continued..
.)

34
performance
observed
in
RFG
Phase
I
while
preventing
deterioration
of
the
current
air
quality
performance
of
conventional
gasoline.

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
turn<
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!
'
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
fueL4*
Additional
research
is
c
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
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
NO,
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.
M
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
requirement^.^^

42
(...
continued)
emitters.
Because
only
one
LEV
was
tested,
statistical
significance
cannot
be
determined.

43
Reid
vapor
pressure
is
a
measure
of
the
gas
pressure
a
liquidgas
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.

35
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.

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
(half
way
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
wouid
have
an
ethanol
level
of
around
5
percent,
not
10
percent
as
in
the
original
ethanol
blend,
the
full
1
.O
psi
RVP
increase
due
to
ethanol
addition
would
still
occur
even
at
this
lower
ethanol
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
cos~
lvency.~~
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
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,
statiodbrand
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.

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
Caffiey
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.

36
(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
(Le.,
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
(ie.,
ethanol
blends
commingled
only
with
MTBE
blends).
Analogous
increases
for
a
non­
reformulated
market
(i.
e.,
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
NO,.
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
3
1,
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
NO,
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
NESCAUM,
Relative
Cancer
Risk
of
Reformulated
Gasoline
and
Conventional
Gasoline
Sold
in
the
Northeast,
August
1998.

37
ga~
oline;~
'
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.

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,
NO,
levels
in
CG
would
clearly
be
better
than
current
level^.
'^
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.

''
U.
S.
Energy
Information
Administration
(Aileen
Bohn
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.

'*
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
sulf'ur
changes
currently
under
consideration.

38
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
per~
ent."
'~
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
SA1
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
(k
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
vehicle^.
'^

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).

''
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
US.
Environmental
Protection
Agency,
Office
of
Mobile
Sources,
(R.
Cook),
Impact
of
the
Oxyfuel
Program
on
Ambient
CO
Levels,
1996.

Systems
Application
International,
Regression
Modeling
of
Oxyfuel
Efects
On
Ambient
CO
Concentrations,
January
1997.

39
''
Office
of
Science
and
Technology
Policy,
National
Science
and
Technology
Council,
Interagency
Assessment
of
Oxygenated
Fuels,
June
1997,
p.
iv.
Table
3.
Percent
Reduction
in
CO
Emissions
Resulting
from
3.5
Percent
Oxygen,
As
Predicted
by
the
MOBILE
Model5*

Year
MOBILE6
1997
10%
to
20%

2000
5%
to
15%

2005
0%
to
10%

2010
0%
to
2%

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
(ie.,
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
NO,
performance.

'*
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
(htt~://
www.
e~
a.
gov/
OMS/
M6.
htm.)

40
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?"

41
Y
U
1111
0
P
W
(n
.­
s
i
s
t
1
C.
Prevention,
Treatment,
and
Remediation
I.
In
trod
uction
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:

8
Underground
storage
tanks,
other
gasoline
storage
and
distribution
facilities,
such
as
bulk
storage
terminals,
small
householdlfarm
gasoline
tanks,
and
aboveground
storage
tanks;

8
Interstate
and
intrastate
petroleum
pipelines;

Small
releases
(e.
g.,
gasoline
tank
ruptures
during
car
accidents
or
consumer
8
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;

8
Engine
exhaust
and
related
releases
(e.
g.,
spillage)
into
lakes
and
reservoirs
from
two­
stroke
watercraft
and
older
four­
stroke
watercraft;

8
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
h4TBE
Drinking
Water
study,
The
Presence
of
MTBE
and
other
Gasoline
Compounds
in
Maine's
Drinking
Water­
Preliminary
Report,
1998.

45
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
ro
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.@
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,
bLt
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
timitations
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
th&
100,000
ppb,
indicating
a
wide
range
in
the
magnitude
of
MTBE
impacts
at
these
sites
(Table
1).

eo
U.
S.
Environmental
Protection
Agency,
Office
of
Underground
Storage
Tanks,
``
Corrective
Action
Measures
Archive,"
httr,
://
www.
eaa.
rrov/
swerust
1
/catfcamarchv.
htm.

61
US.
Environmental
Protection
Agency,
Office
of
Water,
National
Water
Quality
Inventory:
1996
Repor?
to
Congress,
1
996.

46
Table
I.
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
5­
50
50­
200
23%

12%

11%

200­
1,000
17%

1,000­
5.000
5,000­
20,000
20,000­
100,000
14%

13%

7%

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
I999
MTBE
Blue
Ribbon
Panel
meeting.

There
are
currently
an
estimated
825,000
regulated
USTs
at
approximately
400,000
facilitie~.~~
Of
the
nation's
approximately
182,000
retail
gasoline
outlets,
the
"major"
oil
companies
own
about
20
percent,
or
about
36,000
fa~
ilities.
6~
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.&,
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
fie1
storage
tanks
exempt
from
Federal
regulations
(e.
g.,
certain
farm
and
residential
gasoline
tanks
and
home
heating
oil
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
Large
aboveground
storage
U.
S.
Environmental
Protection
Agency,
Office
of
Underground
Storage
Tanks,
based
upon
FY
1999
Semi­
Annual
Activity
Report
­
First
Hav(
unpub1ished).

`'
National
Petroleum
News,
Market
Facts
1998
(Arlington
Heights,
IL:
Adams
Business
Media,
1998),
p.
124.

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
hotection
Agency,
Office
of
Underground
Storage
Tanks,
"Corrective
Action
Measures
Archive,"
httD://
www.
eDa.
gov/
swerust
l/
cat/
camarchv.
htm.

"
U.
S.
Environmental
Protection
Agency,
Underground
Heating
Oil
And
Motor
Fuel
Tanh
Exempt
From
Regulation
Under
Subtitle
I
Of
The
Resource
Conservation
And
Recovery
Act
(May
1990).

47
m
,
release
statistics
for
ASTs
are
not
available.
A
1994
American
Petroleum
Institute
(API)
survey
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
States6'
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
ali
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
3
1
percent.
Although
the
specific
volume
of
gasoline
spilled
cannot
be
readily
identified,
gasoIine
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
Oflice
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
€or
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
Ofice
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.

66
American
Petroleum
Institute,
A
Survey
of
API
Members
'
Aboveground
Storage
Tank
Facilities,
July
1994.

`'
The
U.
S.
Department
of
Transportation
(Don'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).

Development
of
the
definition
and
its
subsequent
application
are
subject
to
notice
and
comment
requirements
under
Federal
rulemaking
procedures.

48
D.
Small
Releases
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
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
(WG)
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
proce~
s.
'~

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
Stu&,
The
Presence
of
MTBE
and
Other
Gasoline
Compounds
in
Maine's
Drinking
Water­­
Preliminary
Report,
1998.

'O
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,
2
13th,
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
Butyl
Ether
(MTBE)
in
a
Multiple­
Use
Lake,"
Environmental
Science
&
Technology,
1998,
v.
32,
mo.
23,
pp.
3666­
3672.

72
J.
E.
Reuter
et
al.,
L`
Concentrations,
Sources,
and
Fate
of
the
Gasoline
Oxygenate
Methyl
Tert­
Butyl
Ether
(MTBE)
in
a
Multiple­
Use
Lake,"
Environmental
Science
&
Technology,
1998,
V.
32,
mo.
23,
pp.
3666­
3672.

49
stations
and
retail
businesses)
and
roadways
and
from
"atmospheric
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
typicaIly
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.
Refease
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
I
O­
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
dispensinghtorage
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
CaIiforniq,
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.

'3
G.
C.
Delzer
et
al.,
Occurrence
of
the
Gasoline
Oxygenate
MTBE
and
BTEXCompounds
in
Urban
Stormwater
in
the
UnitedStates,
1991­
95,
US.
Geological
Survey
Water
Resources
Investigation
Report
WRIR
96­
4
145,1996.
­

74
A.
L.
Baehr,
P.
E.
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.
I
,
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,
1
998,
v.
10
1
,
pp.
22
1­
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/
wtrcpal/
factmtbe.
htm.

50
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
requirement^.^^
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
(ie.,
fewer
than
20,000
gallons)
to
replace
regulated
USTS.~~
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.

13.
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

'`
U.
S.
Environmental
Protection
Agency,
Ofice
of
Underground
Storage
Tanks,
estimate
based
upon
data
submitted
by
States
on
February
28,
1999
and
April
30,
1999
(unpublished).

''
Ellen
Frye,
"When
Push
Comes
to
Shove,"
LUSTLine,
September
1998.

jug^
Sexton,
Kansas
State
Department
of
Health
&
Environment,
paper
presented
at
the
10'
Annual
USTLUST
National
Conference
(Long
Beach,
CA,
March
30,
1999);
Wayne
Geyer,
LLAbove
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
gallonhour
release
would
result
in
a
release
of
1,752
gallons
if
undetected
for
one
year,
and
could
go
undetected
for
several
years.

5
1
limiting
(primm*
ly
due
to
intrinsic
bioremediation)
and
thus
small
releases
or
slow
chronic
releases
that
remain
undetec&
d
have
typically
not
resulted
in
drinking
water
impacts.
The
regulations
did
not
address
the
use
ofoxygaates
although
they
were
used
as
octane
enhancers
at
this
time,
albeit
at
generally
lower
levels
than
in
RFG
oxYfuel.*
D
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
regulatim
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
n!
Underground
Storage
Tanks
A.
Materials
Compatibility
The
use
ofoxygenates
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
gasoIine/
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
wcut
in
metal
or
fiberglass
UST
systems
as
a
result
of
concentrations
of
MTBE
or
other
oxygenates
in
gasoline.**
The
same
study
indicated,
however,
that
given
the
Iack
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
The
use
of
oxygenates
in
gasoline
was
well
established
by
the
mid­
1980's.

Thomas
M.
Young
and
the
US.
Environmental
Protection
Agency,
Field
Evaluation
of
Leak
Detection
Performance,
National
Leak
Detection
Performance
Study,
1
999.

*2
Kevin
Couch
and
Thomas
M.
Young,
"Leaking
Underground
Storage
Tanks
(USTs)
as
Point
Sources
of
M
~E
to
Groundwater
and
Related
MTBE­
UST
Compatibility
Issues,"
in
University
of
California
and
UC
Toxic
Substances
Research
&
Teaching
Program,
Health
and
Environmental
Assessment
of
MT..
E,
Vofgme
W,
1998.

52
appropriate
care
in
performing
these
activities.
The
most
frequently
identified
problem
areas
include
installation,
fuel
delivery
and
procedures,
and
routine
maintenance
of
dispensers
and
release
detection
equ
i~
ment.
8~

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
simiIar
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.

...

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.
s
wrcb.
ca.
gov/­
cwphome/
ust/
leak­
reportdIndex.
htm.

U.
S.
Environmental
Protection
Agency,
Office
of
Water,
State
Source
Water
Assessment
and
Protection
84
programs
Guidance,
EPA
8
16­
F­
97­
004,
August
1997,
www.
epa.
gov/
OGWDW/
swD/
fs­
swDg.
html.

53
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
protection
areas.
This
will
provide
an
opportunity
to
coIlect
locational
data
for
water
sources
and
contaminant
sites
as
part
of
the
State
Source
Water
Assessment
Programs.
Here,
the
challenge
will
be
threefold:
(I
)
to
collect
information
useful
to
multiple
stakehoIders;
(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
samphg
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,
h
e
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
impIement
a
statewide
GIS
to
manage
the
risk
of
MTBE
contamination
to
public
ground
water
supplies.
In
the
short­
term
(by
JuIy
1999),
this
project
seeks
(1)
to
identify
all
underground
storage
tanks
and
ai1
known
releases
of
motor
vehicle
fuel
from
underground
storage
tanks
that
are
within
1,000
feet
of
a
drinking
water
well;
and
(2)
to
identifj.
public
wells
within
1,000
feet
of
a
petroleum
product
pipeline.**

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
vulnerabiIity.
­

*'
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
htt~://
aeotracker.
llnl.~
ov/.

54
Other
States
are
also
developing
and
implementing
GIS
capabilities,
although
not
as
comprehensively
as
California's
program.

VI.
Treatment
of
Impacted
Drinking
WateP6
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
Wafer,
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
ef€
luents
is
typically
accomplished
using
air
striminq,
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
adsomtion,
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.*
'

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;
remediution
of
ground
water
associated
with
contaminant
sites
is
addressed
in
the
following
section.

''
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.

55
Figure
1
Annual
MTBE
Treatment
Costs
for
a
Family
o
m
$400
k
$350
L
$300
..­
3
$250
E
s
Q)
P
2
$200
0
*
$100
L
$150
lw
tn
0
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)
porn
Drinking
Water
­­
Air
Stripping,
Advanced
Oxidation
Process
(A
OP),
and
Granular
Activated
Carbon
(GAC),
Executive
Summay,
Sacramento,
CAY
December
1998.

Tertiary
butyl
alcohol
(TBA)
is
another
oxygenate
that
has
been
found
at
oxygenated
gasoline
release
sites.
Because
TBA
is
a
byproduct
of
some
MTBE
production
processes,
TBA
is
found
in
some
fuel­
grade
MTBE.**
TBA
is
also
a
metabolite
of
the
biodegradation
of
MTBE.*
9
Because
TBA
is
infinitely
soIuble
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
TBA
will
further
limit
the
usefulness
of
the
above
described
technologies
and
increase
treatment
costs.

*
National
Toxicology
Program,
Summary
of
Datu
For
Chemical
Selection:
Methyl
Tert­
Butyl
Ether,
http:
Nntp­
db.
niehs.
nih.
govMTP_
ReportsMTP_
CheS­
1
634­
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
ofMBE
and
Perchlorate
in
Ground
Water
(Anaheim,
CA,
June
3­
4,
1998),
pp.
40­
54.

56
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
contpmination
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.
g0
The
complex
properties
and
interactions
of
gasoline
and
hydrogeologic
systems
have
been
found
to
be
substantial
barriers
to
the
effective
removal
of
motor
&el
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
(i.
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
adequateIy
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
MTl3E
has
also
been
shown
to
present
aesthetic
(i.
e.,
taste
and
odor)
problems
at
relativelylow
levels,
alternative
RBCA
guidance
may
need
to
be
developed
to
adequately
address
those
types
of
environmental
concerns.

SQ
US.
Environmental
Protection
Agency,
Office
of
Research
and
Development,
Pump­
and­
Treat
Ground­
water
Remediation:
A
Guide
for
Decision
Makers
and
Practitioners,
EPAl625/
R­
95/
005,
1996.

57
During
the
last
several
years,
it
has
become
an
accepted
practice
at
UST
release
sites
to
carefully
evaluate
the
potential
for
intrinsic
remediation
(Le.,
bioremediation
of
the
contaminant
primarily
by
the
microbial
population
naturally
present
in
the
subsurface),
and
then
tu
determine
whether
there
is
a
need
for
active
remediation.
The
presence
of
MTBE
can
complicate
the
utilization
of
intrinsic
remediation,
as
although
the
BTEXgl
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
recaicitrant,
and
therefore
intrinsic
remediation
wiIl
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
O\
IAPL)
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
aquiferY2
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
condition^.^^
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.

PumD
and
treat
is
a
mature,
well­
understood
technology
that
pumps
ground
water
to
the
surface
for
subsequent
treatment
and
dischirge.
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
a11
pump
and
treat,
the
effluent
91
The
compounds
benzene,
toluene,
ethyl
benzene,
and
xylene
are
commonly
known
as
"BTEX."

"4J.
S.
Environmental
Protection
Agency,
Ofice
of
Research
and
Development
and
Office
of
Solid
Waste
&
Emergency
Response,
Ligh
Nonaqueous
Phase
Liquidr,
EPA
Ground
Water
Issue
Paper
#
EPAI540fS­
95l500,
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,"
NationaI
Ground
Water
Association,
1998
Petroleum
Hydrocarbons
and
Organic
Chemicals
in
Ground
Water,
pp.
55
1­
559.

58
will
have
to
be
treated
with
technologies
such
as
air
stripping,
advanced
oxidation,
GAC,
or
bioreactor.

Soil
vauor
extraction
(WE)
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
suarninq
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
aidoxygen
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
M"
l3E
remediation
(ie.,
dissolved
phase
does
not
volatilize
and
may
be
relatively
recalcitrant
to
native
biodegradation).
Air
sparging
is
fiequently
teamed
with
SVE
to
capture
the
volatilized
compounds.

Dual
bhase
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,
aIlowing
for
a
larger
area
of
influence
for
the
vapor
extraction
system.
As
discussed
above,
when
MTBE
is
dissolved
in
soif
moisture,
vapor
extraction
will
not
effectively
remove
MTBE,
which
is
highly
sohble.
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
gasoIine
constituents
in
the
subsurface
(e.
g.,
benzene),
and
MTBE
generally
has
been
recalcitrant
or
limited
relative
to
benzene
biodegradation
in
field
samples,
aIthough
there
is
some
field
evidence
to
the
contrary."
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
11
15;
A..
M.
Happel,
B.
Dooher,
and
E.
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
Livertnore
National
Laboratory.
An
Evafuation
of
MTBE
Impacts
to
Calfornia
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
(1
993­
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.
1
13­
122;
Reid,
J.
B.,
et
al.,
"A
Comparative
Assessment
of
the
Long­
Term
Behavior
of
MTBE
and
Benzene
Plumes
in
Florida,"
pp.
97­
1
02
Natural
Attenuation
of
Chlorinated
Solvents,
Petroleum
Hydrocarbon
and
Other
Organic
Compoundr
(continued..
.)

59
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).

0
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
Efluent
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."
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
microbia1
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
acceptabiIity
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
94
(...
continued)
(1999);
Hurt,
K.
L.,
et.
ai.,
"Anaerobic
Biodegradation
of
MTBE
in
a
Contaminated
Aquifer..,"
pp.
103­
108,
Natural
Attenuation
of
Chlorinated
Solvents,
Petroleum
Hydrocarbon
and
Other
Organic
Compounds
(1
999);
Bradley,
P.
M.,
et.
al.,
Aerobic
Mineralization
of
MTBE
and
tert­
Butyl
Alcohol
by
Stream­
bed
Sediment
Microorganisms:
E
m
l
.
Sci.
Tech.,
v.
33
no.
1
I
,
pp.
1877­
1
897
(1999).

95
Depending
on
the
precise
circumstances,
these
costs
can
range
from
moderately
higher
than
BTEX­
related
costs
to
significantly
higher.

60
'..
,
,
.
effluents
generated
during
the
remediation
process;"
(3)
the
size
of
the
dissolved
plume;
and
(4)
the
potential
for
using
natural
attenuation
as
the
treatment
technology.

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.
SimiIarly,
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?
'
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
iess
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.
OveraII,
this
study
concluded
that
on
average
MTBE
contaminated
sites
may
be
I40
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
potentia1
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.
w
If
MTBE
plumes
are
expected
to
migrate
further
because
of
higher
source
96
These
levels
are
addressed
in
the
permits
issued
by
the
appropriate
regulatory
authorities
for
these
discharges.

97
Robert
Hitzig,
Paul
Kostecki,
and
Denise
Leonard,
"Study
Reports
LUST
Programs
are
Feeling
Effects
of
MTBE
ReTeases,"
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
I
.4
times
more
costly
to
remediate
than
conventional
gasoline
sites.

99
US.
Environmental
Protection
Agency,
Draft
Memorandum
from
Timothy
Fields,
Jr.,
Acting
Assistant
(continued
...)

61
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
(i
e
.,
active
remediation
wouJd
be
required,
thus
increasing
cleanup
costs).
Only
a
limited
number
of
field
studies
have
been
conducted
to
evaluate
MTBE
natural
attenuation;
IDO
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."
'

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.
'02
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
`mounts
of
dissolved
ethanol.
Laboratory
research
suggests
that
microorganisms
prefer
to
biodegrade
ethanol
over
other
fuel
components,
so
that
ethano1
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
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.

*
(...
continued)
Administrator,
Ofice
of
Solid
Waste
and
Emergency
Response,
"Use
of
Monitored
Natural
Attenuation
at
Superfund,
RCRA
Corrective
Action,
and
Underground
Storage
Tank
Sites,"
June
9,
1997.

R.
C.
Borden
et
ai.,
"Intrinsic
Biodegradation
of
MTBE
and
BTEX
in
a
Gasoline­
Contaminated
Aquifer,"
Water
Resources
Research,
2997,
v.
33,
no.
5,
pp.
1105­
1
115;
J.
E.
Landmeyer
et
al.,
"Fate
of
MTBE
Relative
to
Benzene
in
a
Gasoline­
Contaminated
Aquifer
(1
993­
981,"
Ground
Water
Monitoring
&
Remediation,
Fall
1998,
pp.
93­
1
02;
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,
1
13­
122.

lo'
Arhwo
Keller,
Ph.
D.,
et.
al.,
Executive
Summary,
Recommendations,
Summary,
"Health
and
Environmental
Assessment
ofMTBE,"
1999.

`02
Malcome
Pirnie,
Inc.,
Evaluation
of
the
Fate
and
Transport
ofEthanol
in
rhe
Environment,
(Oakland,
CA:
Malcome
Pirnie,
Inc.),
1998;
H.
X.,
Corseuil
et
al.,
"The
Influence
of
the
Gasoline
Oxygenate
Ethanol
on
Aerobic
and
Anaer6bic
BTX
Biodegradation,"
"at.
Res.,
1998,32,2065­
2072.;
C.
S.
Hunt
et
ai.,
"Effect
of
Ethanol
on
Aerobic
BTX
Degradation
Papers
from
the
Fourth
International
In
Situ
and
@­
Site
Bioremediation
Symposium,"
Battelle
Press,
April­
May
1997,
pp.
49­
54.

IO3
Michael
Kavanaugh
and
Andrew
Stocking,
"Fate
and
Transport
of
Ethanol
in
the
Environment,"
presentation
at
the
May
1999
NTBE
Blue
Ribbon
Panel
meeting.
fBased
on
Malcome
Pirnie,
Inc.
Evahtion
of
the
Fate
and
Transport
of
Ethanol
in
the
Environment
(Oakland,
CA,
1998.)]

62
C.
Funding
I
.
State
and
Federal
Sources'"

I
..
The
primary
sources
of
funding
for
UST
remediation
are
State
UST
cleanup
funds.
'05
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
baIance.
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).
IM
Monies
in
this
fund
are
subject
to
appropriation,
and
Congress
has
been
appropriating
approximately
$70
million
annually
in
recent
years.
'"
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
deanups
in
which
the
IO4
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/
Publicationslpdfl98vtsum.
pdf.

`OS
U.?.
Environmentd
Protection
Agency,
State
Assurance
Funds:
S&
ate
Fun&
in
Transition
Models
for
Underground
Storage
Tank
Assurance
Funds,
1997,
EPA
5
10­
B­
97­
002,
www.
epa.
gov/
swerust
I
/states/
fundinfo.
htm.

IO6
Executive
Office
of
the
President
of
the
United
States,
Budget
of
the
United
States
Government,
Fiscal
year
2000
­
Appendix,
1999,
p.
937.

lo'
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.)

63
owner
and
operator
are
unknown,
unwilling,
or
financially
unable
to
undertake
and
to
complete
cleanup
of
a
contaminated
site.
1o8
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
(I
)
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
CWSW
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
Ioans
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
finding
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
3
1
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.

I
I
lo*
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.

64
..
.._­_,..
­.
..
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
wblic
water
systems,
and
to
act
as
a
gradual
disincentive
for
use
of
MTBE,
a
tadsurcharge
could
be
le
ied
on
MTBE
production
for
use
in
gasoline.
These
levied
monies
could
then
be
made
readily
accessibl
by
public
and
private
water
suppliers
to
reimburse
incurred
expenses
associated
with
addressing
A
B
E
contamination
incidents.
The
economic
viability
and
amount
of
this
surcharge
would
need
to
be
dl
ermined,
but
would
likely
range
from
5
percent
to
50
percent
of
the
price
of
each
gallon
of
MTBE
;old.
For
example,
a
10
percent
surcharge
with
an
MTBE
price
of
$0.70
per
gallon
and
RFG
with
11
)ercent
by
volume
MTBE
would
add
about
1
cent
to
the
per
gallon­
price
of
RFG
and
would
accumulate
ibout
$300
million
annually
with
current
MTBE
usage.
This
surtax
could
also
be
structured
to
incr
ise
over
time
to
further
discourage
MTBE
use.
.
D.
Fuel
Supply
and
Cost
I.
In
trod
u
ctian
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:

e
The
time
required
to
implement
capital
investments
in
both
refineries
and
infrastructure,
which
entails
raising
capital,
obtaining
permits,
and
constructing
units
and
infrastructure.
IO9
The
need
for
reguIatory
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
fingibility
in
the
system.
At
present,
the
US.
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:
faditate
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,
kowever,
ethanol
is
produced
primarily
in
the
Midwest
and
is
not
manufactured
in
suficient
volume
to
meet
national
demand.
Although
new
ethanol
production
capacity
can
be
brought
on­
line
in
'09
Moreover,
if
all
refineries
and
terminals
require
capital
upgrades,
the
construction
industry
may
become
Strained.

67
!

,
two
years,
the
permitting
and
construction
of
necessary
infrastructure
will
be
a
critical
determinant
of
ethanol's
availability
and
cost.

11.
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
annuaIly."*
Based
on
Federal
fuel
supply
data,
total
U.
S.
oxygenate
demand
was
approximately
370,000
b/
d
in
1997
(refer
to
Table
D1
in
this
section's
Appendix)."
'
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
Wd,
4
1,000
b/
d,
and
17,000
bid
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
Caiijornia
's
Ethanol
Demand
A
recent
study
funded
by
the
Renewable
Fuels
Association
(RFA),
The
Use
of
Ethanol
in
Calqornia
Clean
Burning
Gasoiine,
estimates
that
if
MTBE
was
banned,
California
would
demand
4
1,000
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."*
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
import^."^

US.
Energy
Information
Administration,
Petroleum
Supply
Annual
1998,
Volume
I
,
Table
S4,
p.
17,
June
1999.
­
'
I
'
U
S
.
Energy
Information
Administration
(T.
Litterdale
and
A.
Bohn),
Demandand
Price
Outlook
for
Phase
2
Reformulated
Gasoline,
2000,
April
1999,
pp.
7­
8.

'I2
California
Energy
Commission,
Supply
and
Cost
Alternatives
to
MTBE
in
Gasoline,
October
1998.

'I3
Downstream
Alternatives,
Ethanol
Sup&,
Demand,
and
Logistics:
Cali$
ornia
and
Other
RFG
Markets,
May
1999.

68
B.
Ethanol
Production
Current
U.
S.
ethanol
production
capacity
is
estimated
at
120,000
b/
dlL4,
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
bid
of
ethanol
would
be
needed,
assuming
that
no
ethanol
is
used
for
economic
octane
blending.
Il5
Thus,
in
a
scenario
of
complete
MTBE
removal,
an
estimated
additional
67,000
b/
d
of
ethanol
would
be
needed
to
filfill
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
producti0.
n
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
prod~
ction.`~
'

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."*
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
butanedpentanes
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
`I4
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.

I"
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
4
1,000
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
D1
in
the
Appendix).

Jcck
Huggins,
Submitted
written
comments
on
behalf
of
the
Renewable
Fuels
Association
at
the
April
1999
MTBE
Blue
Ribbon
Panel
meeting.

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:
Calijornia
and
Other
RFG
Markets,
May
1999.

`I
8
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.

69
oil­
based
RFG
production
capacity
by
the
full
11
percent
by
volume
lost
by
removing
MTBE.
'19
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.
'"

C.
Ethanol
InfrastructureiTransprtation
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
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
fiom
the
Midwest
to
the
Northeast
and
the
West
is
challenging
and
will
likely
be
costly
and
transportation­
facility
intensive.

A
studylZ2
estimates
that
approximately
1,982
rail
cars
(30,000­
gallon~
'~~
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.
'24
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
`I9
A1
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.

U.
S.
Department
of
Energy,
Estimating
the
Refining
Impacts
of
Revised
Oxygenate
Requirements
for
Gasoline:
Summary
Findings,
May
1999.

121
AI
Jessel,
Chevron
Products
Company,
"Fuels
Regulations
and
Emissions
Technology,"
presentation
at
the
March
1999
MTBE
Blue
Ribbon
Panel
meeting.
­
Downstream
Alternatives,
Ethanol
Supply,
Demand.
and
Logistics:
Carifornia
and
Other
RFG
Markets,
May
1999.

123
42
gallons
=
1
barrel
124
Based
on
API
confidential
communications
with
rail
car
lessors,
1999.

70
preferable
to
spotting,
inspecting,
and
unloading
numerous
rail
cars.
Moreover,
in
the
Northeast,
nearly
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
tran~
port.
'~~

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
MT3E
(at
the
refinery
terminal).
The
infrastructure
to
support
such
blending
on
a
wide
scale
does
not
currently
exist.
'26
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
petr01eurn.
l~~
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
fueIs
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
111
below.

­

lZs
Letter
to
Daniel
Greenbaum
from
Robert
E.
Reynolds,
President,
Downstream
Alternatives,
Inc.,
June
24,
1999.
See
also,
Downstream
Alternatives,
Ethanol
Supply,
Demand.
and
Logistics:
Calforniu
and
Other
RFG
Murk&,
May
1999.

IZ6
Oil
and
Gas
Journal,
California
refners
anticipate
broad
efects
ofpossible
state
MTBE
ban,
January
18,
1999.

`27
Dexter
Miller,
"Alkyates,
Key
Components
in
Clean­
Burning
Gasoline,"
presentation
at
the
May
1999
MTBE
Blue
Ribbon
Panel
Meeting.

71
111.
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
he1
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
capita1
costs
(e.
g.,
new
refinery
facilities)
and/
or
operating
costs
(e.
g.,
transportation
and
distribution
costs);
and
0
The
cost
of
replacing
octane
while
continuing
compliance
with
environmental
standards.

B.
Time
Government
agencies
and
fuel
refinerdmarketers
have
stated
that
without
adequate
lead
time,
rapid
reductions
in
the
volume
of
MTF3E
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.*
28
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
hture
sulfur
limits
is
show
in
TabIe
1
as
a
general
guide
to
such
capital
pr0je~
ts.
I~~
(Actual
time
requirements
will
vary
from
refinery
to
refinery.)

U.
S.
Department
of
Energy,
Estimating
the
Refining
Impacts
of
Revised
Wgenate
Requirements
for
Gasoline:
Summary
Findings,
March
1999;
California
Energy
Commission,
Suppb
and
Cost
Alternatives
to
MTBE
in
Gasoline,
October
1998;
Robert
Cunningham,
"Costs
of
Potentia!
Ban
of
MTBE
in
Gasolines,"
presentation
at
the
March
1999
MTBE
Blue
Ribbon
Panel
meeting.

Iz9
Sunoco,
Time
Required
to
Complete
Desulfitrization,
personal
communication.

73
Table
1.
Sample
Process
Timetable
for
Complying
with
Future
Sulfur
Limits
in
the
Refining
Industry
1.
Identify
purpose,
scope,
and
permits
required
1
Produce
cost
estimates
I
,
7months
I
Management
approval
I
!
I
II.
Process/
Proiect
ScoDe
Definition
.
Develop
scope,
equipment
requirements,
project
milestones,
and
construction
strategies
`
i
8
months
Management
approval
Produce
more
accurate
budget
estimates
__

111.
Preliminanr
Enaineerinq
Select
engineering
contractor
Submit
permit
applications
Conduct
design
review
I
12
months
i
i
Issue
master
schedule
Submit
costs
for
approval
I
I
I
I
!
i
I
IV.
Detailed
Proiect
Execution
Procure
materials
Receive
all
permits
Award
contracts
Construction
1
21
months
!
Testing
Training
Start­
up
I
1
rota1
1
48months
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."
'

The
U.
S.
Department
of
Energy
estimates
that
if
regulation
changes
are
finalized,
four
years
would
be
neede_
d
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
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
73
cause
supply
problems
in
Petroleum
Administration
for
Defense
District
(PADD)
I,
the
East
Coast.
'31
This
analysis
did
not
consider
effects
on
regional
supplies
in
the
event
of
a
national
MTBE
ban
or
other
changes
in
fuel
properties
(Le.,
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
shouId
be
phased
out
in
three
and
one­
half
years.
132
C.
Certainty
Refinerdmarketers
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
teiminal
construction
decision
making.
Refinerdmarketers
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
Refinerdmarketers
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
ethanoI
has
been
the
predominant
fuel
additive,
this
wilI
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
l
3
LU.
S.
Department
of
Energy,
Estimating
fhe
Refining
Impacts
of
Revised
mgenate
Requirements
for
Gasoline:
Summary
Findings,
March
1999;
Downstream
Alternatives,
Ethanol
Supply,
Demand,
and
Logistics:
Calfornia
and
Other
RFG
Markets,
May
1999.

`''
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,
heragency
Assessment
of
Oxygenated
Fuels,
June
1997.

74
consumers
mix
ethanol
blended
gasoline
with
non­
ethanol
blended
gasoline
in
their
vehicles'
tanks
(see
discussion
in
Air
Quality
Section
B.).

JY.
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
(i.
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
bi1li0n.
l~~
The
State
of
Nebraska
Ethanol
Board
estimates
that
the
ethanol
subsidy
resulted
in
$3.5
billion
in
net
savings
for
the
Federal
government
in
1997.13'

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.

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
D1
in
the
Appendix
for
total
ether
volumes).

13'
State
of
Nebraska
Ethanol
Board,
"Economic
Impacts
of
Ethanol
Production
in
the
United
States,"
April,
1998.
Table
2.
Gasoline
Prices,
February
1999
and
April
1999
(per
gallon,
including
State
and
Federal
taxes)

February
1999
April
1999
California
RFG
$1.101
$1.568
Federal
RFG
$0.987
$1.229
Conventional
$0.901
$1
.OB8
Average
$0.927
$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
refinedmarketers
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
substantia1
and
unnecessary
volatility
in
prices
beyond
the
normal
seasonal
fluctuations.

Economic
impacts
will
not
be
shared
equally
among
petroleum
refinedmarketers.
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):

I
0
The
California
Energy
Commission
estimated
that
the
intennediate­
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
76
regarding
the
type
and
amount
of
oxygenate
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
ChevrordTosco
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
gall~
n.
'~
'

An
analysis
by
Pace
Consultants
found
that
it
would
cost
an
additional
0.7
to
24
cents
per
gaIion
to
make
reformulated
gasoline
blendstock
that
is
suitable
for
use
with
etfianol
(rather
than
MTBE)
in
the
summer
during
the
RFG
Phase
I1
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
I1
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
ethan01.
I~~
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:

0
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.

0
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
'36California
Energy
Commission,
Supply
and
Cost
Alternatives
to
MTBE
in
Gasoline,
October
1998.

13'
MathPro,
Potential
Economic
Benefits
of
the
Feinstein­
Bilbray
Bill,
March
18,
1999.

13*
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
Relining
Impacts
of
Revised
Oxygenate
Requirements
for
Gasoline:
Follow­
up
Findings,
Nay
1999.

77
3
.!
­4
8.8
cents
per
gallon
under
a
scenario
of
no
oxygenate
use
(no
mandate).
(See
TabIe
D2
in
the
Appendix).

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.

0
The
likely
oxygenate
replacement
for
MTBE
is
ethanol.
Current
and
near
future
ethanol
production
(Le.,
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.

78
­­­­
Appendix
D
Region
Table
D1,
Oxygenate
Demand
in
Reformulated
and
Oxygenated
Gasoline
Control
Areas,
1997
(thousands
of
barrels
per
day)

I
Estimated
Oxygenate
Volume
I
in
Control
Area
Gasoline
Estimated
1997
1
ControlAmas
1
MTBE
1
ETBEorTAME
I
Ethanol
Reformulated
Gasoline
PADD
1
(East
Coast)
PADD
2
(Midwest)
PAD0
3
(Gulf
Coast)
PADD
4
(Rocky
Mountain)
PAD0
5
(West
Coast)
1,054
128.2
270
4.0
282
27.4
0
0.0
934
100.9
9.1
1
.o'
0.0
21.8
3.2
0.0
0.0
0.0
3.4
2.0
Subtotal
2,674
259.5
f5.7
24.7
Oxygenated
Gasoline
PAD0
1
(East
Coast)
PADD
2
(Midwest)
PADD
3
(Gulf
Coast)
PADD
4
(Rocky
Mountain)
0
c.
0
79
0.0
16
0.0
36
0.3
0.0
0.0
0.0
6.7
0.0
1.4
1.1
2.7
PADD
5
(West
Coast)
73
0.1
0.0
4.7
Subtotal
204
0.5
f
­I
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
.o
I
.I
Average
1997
Oxygenate
Demand
for
RFG
and
Oxygenated
Gasoline
Blending
265
17
41
Imputed
Oxygenate
Demand
for
Conventional
Gasoline
(e.
g.,
octane
and
gasohol)
4.
­
41
Total
1997
Oxygenate
Supply
269
17
82
'Other
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
end
Price
Outlook
for
Phase
2
Reformulated
Gasoline,
2000.
April
1999,
pp.
7­
8.
Note:
"­
'
signifies
"Not
Applicable."

...

!,
,
79
g;
L
I
.
i
Table
D2.
Summary
of
Modeling
Results
(cents
per
gallon)

__
Results
(cents
per
gallon)

Report
Scenario
I
Intermediate
Term
Long
Term
I
No
oxygenates
allowed
­
CEC
Analysis:
no
oxygen
requirement
California
Only
9
Ethanol
only
­
oxygen
requirement
maintained
(3years)
1
(6
Years)

4.3
to
8.8
6.1
to
6.7
(less
than
2
years,
no
investment)
0.9
to
3.7
1.9
to
2.5
(at
least
4
years,
investment
allowed)
No
ethers
­
no
oxygen
requirement
ChevronKweo
Analysls:
California
Only
Ethanol
only
­
oxygen
requirement
maintained
2.7
6.1
1.2
1.9
MTBE
allowed
­
no
oxygenate
requirement
DOE
Analysis:
No
ethers
­
no
oxygen
PADD
I
Only
requirement
Ethanol
only
­
oxygen
requirement
maintained
­0.3
Not
Investigated
Not
Investigated
1.9
6.0
2.4
to
3.9
Source:
U.
S.
Environmental
Proteaion
Agency
80
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:
'

Air
quality
and
fie1
blending
characteristics;

Fuel
or
fuel
additive
behavior
and
fate
under
and
rarious
water
and
soil
conditions;

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
(TBA).`
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
fiels
Erom
any
route
of
exposure.
Currently,
there
is
not
enough
information
to
fully
characterize
potential
health
risks
of
all
the
oxygenates
or
their
alternatives.

Ir.
MTBE
A.
Air
Quality
and
Fuel
Blending
serves
as
a
cost­
effective
oxygenate
for
blending
in
reformulated
gasoline
(FWG),
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
'
Refer
to
Issue
Summaries
A
and
B,
"Water
Contamination"
and
"Air
Quality
Benefits"
respectively,
for
detailed
discussions
of
these
topics.

T3.
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.

Jim
Prah
of
the
U.
S.
Environmental
Protection
Agency
is
currently
conducting
studies
on
pharmacokinetics
of
MTBE.

Refer
to
Table
El
in
this
section's
Appendix
for
detailed
data
on
the
chemical
properties
of
these
and
related
compounds.

81
!

!
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
I3
(+
6)
percent
with
the
use
of
2.0
percent
by
weight
(wt%)
MTBE
oxygenated
gasoline!

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").
'
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
(TBA)
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
TBA
in
ground
water
is
not
necessarily
evidence
of
MTBE
biodegradation.
By
itself,
TBA,
like
ethanol,
is
infinitely
(miscible)
soluble
in
water
and
is
reported
to
be
recalcitrant
to
bi~
degradation.~

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
U.
S.
Department
of
Energy,
Estimating
the
Reflning
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.

'
T.
W.
Kirchstetter,
et.
al.,
"Impact
of
Oxygenated
Gasoline
Use
on
California
Light­
Duty
Vehicle
Emissions,
''
Environ.
Sci.
And
Tech.,
1996.

'
U.
S.
Environmental
Protection
Agency,
Office
of
Research
and
Deveioprnent,
Oxygenates
in
Water:
Critical
information
and
Research
Nee&,
December
1998.

8­
A.
M.
Happel
et
al.,
An
Evaluation
of
MTBE
Impacts
to
Caifornia
Groundwater
Resources,
Lawrence
Livemore
National
Laboratory
Report,
UCRL­
AR­
130897,
June
1998.

ORce
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
Bupl
Ether
(ETBE),
and
tert­
Amyl
Methyl
Ether
(T.
AME)
by
Propane
Oxidizing
Bacteria,
Appl.
Environ.
Microbiol.
63(
1
l):
42
16­
4222).

82
.,._
I..
.,._._...
­I_...­­­­­

..
..

­­­
(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,
'0
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."

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
(CIIT)
to
address
some
of
these
research
needs.
I2
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).
I3
l4
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
pop~
lation.
'~
The
turpentine­
like
taste
and
odor
ofMTBE,
however,
can
make
such
drinking
water
unacceptable
to
consumers.

TBA
is
a
major
metabolite
of
MTBE,
regardless
of
the
route
of
exposure.
Animal
testing
of
TBA
in
drinking
water
produced
carcinogenic
effects
at
high
levels
of
exposure
(1,250,000
micrograms
per
liter
and
higher).
'$
Additionally,
formaldehyde,
also
a
metabolite
of
MTBE,
is
a
respiratory
imtant
at
high
Io
Office
of
Science
and
Technology
Policy,
National
Science
and
Technology
Council,
Interagency
'I
Office
of
Science
and
Technology
Policy,
National
Science
and
Technology
Council,
Interagency
Assessment
of
Oxygenated
Fuels,
June
1997.

Assessment
of
Oxygenated
Fuels,
June
1997.

I*
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.

US.
Environmental
Protection
Agency,
Ofice
of
Water,
Drinking
Water
Advisory:
Consumer
Acceptability
Advice
and
Health
Effects
Analysis
on
Methyl
Tertiav­
Butyl
Ether
(MTBE),
December
1997.

I4
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.)

Is
U.
S.
Environmental
Protection
Agency,
Ofice
of
Water,
Drinking
Water
Ahisow:
Consumer
Acceptability
Advice
and
Health
Egects
Analysis
on
Methi
Tertiaiy­
Butyl
Ether
(MTBE),
December
1997.

I6
US.
Environmental
Protection
Agency,
Office
of
Water,
Drinking
Water
Advisory:
Consumer
Acceptabiliry
Advice
and
Health
Effects
Analysis
on
Methyl
Tertiary­
Butyl
Ether
(MBE),
December
1997.

83
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."

El.
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
biending
in
order
to
meet
the
air
quality
performance
standards
in
reformulated
fuels.
'9
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
usuaily
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
QuaIity
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
(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
Office
of
Science
and
Technology
Policy,
National
Science
and
Technology
Council,
Interagency
Assessment
of
Oxygenated
Fuels,
June
1997.

'*
Refer
to
Issue
Summary
D,
"Fuel
Supply
and
Cost,"
for
a
more
detailed
discussion
of
this
topic.

l9
California
Energy
Commission,
Supply
andcost
Alternatives
to
MTBE
in
Gasoline,
October
1999.

Office
of
Science
and
Technology
Policy,
National
Science
and
Technology
Council,
Interagency
Assessmenf
of
Oxygenated
Fuels,
June
1997.

Office
of
Science
and
Technology
Policy,
National
Science
and
Technology
Council,
Interagency
Assessment
ofoxygenated
Fuels,
June
1997.

z2
J.
Froines
et,
al.,
Health
andEnvironmentaI
Assessment
of
m
B
E
,
Vol.
I/,
November,
1998;
A.
P.
Altshuller,
"PANS
in
the
Atmosphere,"
J.
Air
Waste
Manag.
ASSOC.,
1993,43(
9),
1221­
1230;
L.
Milgrom,
"Clean
Car
Fuels
(continued
...)

84
B.
Behavior
in
Water
"Neat"
(pure)
ethanol
is
infin.,
ely
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
pre~
ent.
'~

Although
ethanol
has
been
shown
to
retard
BTEX
biodegradation
under
certain
faboratory
conditions,
evidence
of
ethanol's
effect
on
the
migration
of
BTEX
plumes
under
various
conditions,
Le.,
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
pfume
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.=
Health
effects
questions
have
been
raised,
however,
about
potentiaIly
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.*
'
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
probabIe
human
carcinogen.

22
(...
continued)
Run
Into
Trouble,"
New
Scientist,
1989,
122
(1656),
30.

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.)]

*%
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
Uxygenutes
Added
to
Gasoline,
April
1996.

26
Health
Effects
Institute,
The
Potential
Health
Eflects
of
Oxygenates
Added
to
Gasoline,
April
1996.

27
L.
Milgrom,
"Clean
Car
Fuels
Run
Into
Trouble,"
New
Scientist,
1989,
122
(1656),
30.

85
N.
Other
Ethers28
A.
Air
QuaIity
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
witer,
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
ga~
oline.
'~
In
general,
an
increase
in
the
amount
of
alkylates
used
in
fuels
will
have
no
adverse
effect
on
overall
vehicle
perf~
rmance.~
'
Aromatics
are
hydrocarbons
characterized
by
unsaturated
ring
structures
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
(continued..
.)
March
1999
MTBE
Blue
Ribbon
Panel
meeting;
AI
Jessel,
Chevron
Products
Company,
"Removing
MTBE
From
86
of
carbon
atoms
(Le.
benzene,
toluene,
and
xylene),
and
increased
use
of
aromatics
would
be
likely
to
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
requirement^.^
'

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:

0
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
0
Whether
intermediates
andor
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
carefulIy
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.

(...
continued)
30
Gasoline,"
presentation
at
the
March
1999
MTBE
Blue
Ribbon
Panel
meeting.
1
I
3
1
MathPro,
Potential
Economic
Benefits
of
the
Feinstein­
Bilbray
Bill,
March
18,
1999.
I
87
i
I,
Appendix
E
Table
El.
Chemical
Properties
of
Selected
Compounds'

Alkylates
Benzenez
MTBE'
Ethanol'
ETBE'
TAME'
TBA'
(isooctane)

Molecular
Weight
(glmol)
78.11
88.2
46.1
102.2
102.2
74.1
114.2
Boiling
Point
(O
C)
80.1
55.2
78.5
72.2
86.3
82.4
99.2
Vapor
Pressure
(mm
Hg
at
20
OC)
73
240
44
130
75
41
72
Density
(glL)
0.88
0.74
0.79
0.74
0.77
0.79
0.69
Octane
Number
94
110
115
112
105
100
100
Neat
Solubility
(gl1OOg
H,
O)
0.178
4.8
miscible
1.2
1.2
miscible
<<
0.01
Solubility
into
H20
from
Gasoline
(g/
lOOg
H20)

Taste
Threshold
in
Water
(ug/
L)
<.
01
0.55
5.7b
0.33
0.24
2.5'
­

500
20to40
­
47
128
­
­

21
­
Odor
Threshold
(ppm)
0.5
0.053
49
0.013
0.027
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).
The
water
solubiliiies
of
the
alcohols
are
estimates
based
on
partitioning
properties.

Sources:

Environment
­
A
Review
of
the
Literature
(Port
Arthur,
Texas,
1995).

Otganic
Chemicak:
Vol.
Ill,
Volatile
Otganic
Compounds
(Boca
Raton,
FL:
Lewis
Publishers,
Inc,
1993)
p
.
916.

Organic
Chemicals:
Vol.
Ill,
Volatile
Orgenic
Compounds
(Boca
Raton,
FL:
Lewis
Publishers,
Inc,
1993)
p.
962.
'
D.
L.
Conrad,
Texaco
Research
and
Development
Department,
The
lmpacfs
of
Gasoline
Oxygenate
Releases
to
the
Donald
Mackay,
W.
Y.
Shiu,
and
K.
C.
Ma,
Illustrated
Handbook
of
Physical­
Chemical
Properties
and
Environmental
Fate
for
Donald
Mackay,
W.
Y.
Shiu,
and
K.
C.
Ma,
Illustrated
Handbook
of
Physical­
Chemical
Properties
and
Environmental
Fate
for
Key:

­
"
signifies
'Not
Applicable."
g/
mol=
Grams
Per
Mole
x°
C
=
Degrees
Celsius
mm
Hg
=
Millimeters
of
Mercury
g/
L
=
Grams
Per
Liter
g
l
l
00s
H20
­
Grams
Per
100
Grams
of
Water
uglL
=
Micrograms
Per
Liter
ppm
=
Parts
Per
Million
­

88
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
sul­
face
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
US.
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.

89
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
leaksh­
eleases,
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
reIease
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.

90
C.
AcceIerate
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
weils.
.

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
impIement
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
91
primarily
MTBE,
areas
using
primarily
ethanol,
and
areas
using
no
or
lower
levels
of
oxygenate.

Treatment
and
Remedialion
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
Blendiw
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
integrutedpackuge
of
actions
by
both
Congress
and
EPA
that
should
be
implemented
as
quickly
aspossible.
The
key
elements
of
that
package,
described
in
more
detail
beIow,
are:

92
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
Oxwen
Reauirement
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
1
1.
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
Ca1
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
staiidards
required
under
the
1990
Act,
rather
than
the
Iarger
air
quality
benefits
currently
observed.
In
addition,
changes
in
the
RFG
program
could
have
adverse
consequences
for
conventiona1
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.

93
In
order
to
ensure
that
there
is
no
loss
of
current
air
quality
benefits,
EPA
should
seek
appropriate
mechanisms
for
both
the
RFG
Phase
I1
and
Conventional
Gasoline
programs
to
define
and
maintain
in
RFG
I1
the
real
world
performance
observed
in
RFG
Phase
I
while
preventing
deterioration
of
the
current
air
quality
performance
of
conventional
gasoline?*

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
MTl3E
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
~upplies.
3~

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
$2
1
I
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
$2
1
I(
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
821
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
i
s
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
restrictleliminate
the
presence
of
gasoline
in
the
water
resource.
To
maximize
the
uniformity
with
which
any
changes
are
implemented
and
minimize
impacts
on
cost
and
he1
suppiy,
the
Panel
recommends
that
EPA
establish
criteria
for
state
waiver
requests
including
but
not
limited
to:

a.

b.
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.
Compliance
with
federal
requirements
to
prevent
leaking
and
spiHing
of
gasoline.
(continued.
..)

94
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
im~
lemented~~.
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
diminated,
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
&
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
likeiy
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;
­

33
(...
continued)
C.
d.
Programs
for
remediation
and
response.
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.

34
Although
a
rapid,
substantial
reduction
wilI
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.

95
C.
Identify
and
begin
to
collect
additional
data
necessary
to
adequately
assess
the
current
and
potential
future
state
of
contamination.

The
Wintertime
Oxvfuel
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
CIarification
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
Evaiuatiw
and
LearninP
From
Emerience
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
FWG
program;
and
e
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.

96
Appendix
A
In
reviewing
the
RFG
program,
the
Pane1
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
groundwater,
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
bfending
component,
made
from
domestic
grain
and
potentially
fiom
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
fiiels;
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
and
Aromatics
Effective
fuel
blending
components
made
from
crude
oil;
alkylates
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).

i.
97
98
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
concfusions
which
I
believe
to
be
inaccurate:

I).
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
harmfbl
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
fullv
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
beIief
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
W
.
­
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
gasoIine.
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
pubIic
health,
Senate
Democratic
Leader
Tom
Daschle
(D­
SD),
a
primary
sponsor
of
the
RFG
provision,
said
on
March
29,
1990;

99
"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
signifcant
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
oxygenatedfuel
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
BFW
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
3.
Piel,
Technical
Director
of
the
CIean
Fuels
Development
Coalition
(CFDC),
increased
use
of
aromatics
will
lead
diriictly
to
increases
in
air
toxic
emissions,
exhaust
VOC
emissions,
combustion
chamber
deposits,
carbon
monoxide
emissions,
and
worsen
fuel
factors
contributing
to
vehicle
performance
(Le.
the
driveability
index).
Use
of
aromatics
will
also
increase
VOC
emissions
at
both
stationary
and
mobile
sources.

100
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,
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..
.Afier
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
ifso,
whatever
it
does
achieve
would
be
afloor
for
theperformance
standards
af?
er
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
renewabIe
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
physicaI
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
fiom
corn,
wheat,
barley
and
other
crops,
we
shift
trade
from
101
.i
I
,

I
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."

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.
j.

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
current&
serves
as
the
Nebraska
representative
of
the
22
state
Governors
'
Ethanol
Coalition.
ME
Sneller
was
appointed
to
the
EPA
Blue
Ribbon
Panel
in
December
1998.

102
Lvondell
Chemical
Companv`
s
Dissentinv
ReDort
Summarv
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
recornmendations
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
identi@
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
i
s
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
I
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
foliowing
paragraph
from
the
Issue
Summary
E,
"Comparing
the
Fuel
Additives."

"In
terms
of
neurotoxicity
and
reproductive
effects,
inhalation
toxicity
testing
to
date
generaIly
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."
­

103
No
quantifiable
evidence
has
been
provided
to
show
that
full
compliance
with
the
1998
LUST
reguiations
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
~ornpliance.~~
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
studyJ6
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
bIending
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
.WG
pr~
gram.~
'
Since
all
other
alternatives
have
one
or
more
inferior
properties
as
compared
to
MTBE
in
gasoline,
it
would
be
3s
Sausville,
Paul,
Dale
Marx
and
Steve
Crimaudo:
A
Preliminarv
State
Survev
with
Estimates
based
on
a
SuGev
of
17
State
databases
of
earlv
1999.
ASTSWMO
UST
Task
Force,
1
Ith
Annual
EPA
USTLUST
National
Conference,
March
15­
1
7,
1999.
Daytona
Beach,
Florida.

36
Keller,
Arturo,
et.
al.
Health
&
Environmental
Assessment
of
MTJ3E.
ReDOrt
to
the
Governor
and
hislamre
of
the
State
of
California
as
SDonsored
bv
SB
521.
November
1998.

37
"Overview
of
Fuel
Oxygenate
Development",
WilIiam
J.
Pie1
For
Lyondell
Chemical
Co.,
Presentation
to
the
EPA's
Blue
Ribbon
Panel,
January
22,
Arlington,
VA.

I04
difficult
if
not
nearly
impossible
to
achieve
the
same
real
air
quality
eficiency
provided
by
MTBE.
And
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,
NO,
and
toxics,
improving
gasoline
properties
through
the
use
of
oxygenates
reduce
many
other
vehicles
pollutants
such
as
CO
(carbon
monoxide),
PM
(particulate
matter)
and
C02
(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,
NO,,
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
over
time.
Since
none
of
these
additional
emission
reductions
are
reflected
or
controlled
in
EPA's
Complex
Emissions
Model
used
for
RFG,
reducing
MTBE
in
RFG
wi11
result
in
a
loss
of
these
extra
emission
benefits?*

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
C02
(greenhouse
gas)
in
addition
to
higher
costs.

Alternatives
have
not
been
adequately
studied
for
their
health
risk
impacts,
availability
or
their
cost
effectiveness
in
FWG
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:
Pie1
of
Lyondell
Chemical
CO.,
hesentation
to
EPA
Blue
Ribbon
Panel,
March
1,
1999,
Boston.

105
I
LIST
OF
PANEL
MIEMBERS
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
F~
x:
(617)
876­
6709
dgreenbaum
8
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
Campbeil,
Sunoco,
Inc.
Chairman
and
CEO
Sunoco,
Inc.
1801
Market
Street
Philadelphia,
Pennsylvania
19
103­

Fax:
(215)
977­
3559
ann­
1­
williams
@
sunoil.
co
(215)
977­
3871
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
­
Linda
Greer,
Natural
Resources
Defense
Council
Senior
Scientist
Natural
Resources
Defense
Council
1350
New
York
Ave.,
N.
W.
Washington,
D.
C.
20005
Fax:
(202)
289­
1
060
Igreer@
nrdc.
org
(202)
289­
6868
Jason
Grumet,
NESCAUM
Executive
Director
NESCAUM
129
Portland
Street
Boston,
MA
02
1
14
(6
1
7)
367­
8540,
ext.
2
16
jgrumet@
nescaum
.org
Fax:
(61
7)
742­
9
162
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
happel
1
@lInl.
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
henrycj@
api.
org
Michael
Kenny,
California
Air
Resources
Board
Executive
Officer
California
Air
Resources
Board
P.
O.
Box
28
15
Sacramento,
CA
958
I2
Fax:
(9
16)
322­
6003
mkenny@
arb.
ca.
gov
(9
I
62445­
4383
108
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:
(5
IO)
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)
47
1­
294
1
Fax:
(402)
47
1­
2470
sneller@
nrcdec.
nrc.
state.
ne.
us
Debbie
Starnes,
Lyondell
Chemical
Senior
Vice
President,
Intermediate
Chemical
Lyondell
Chemical
Company
122
1
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
1726
M
St.,
NW
Suite
902
Washington,
DC
20036
Fax:
(202)
452­
1
805
rwhite@
lungusa.
org
(202)
785­
3355
1
09
Federal
Rewesen
ta
tives
mon­
Votin&

Robert
Perciasepe,
Air
and
Radiation,
US
EnvironmentaI
Protection
Agency
Assistant
Administrator
Ofice
of
Air
and
Radiation
US
Environmental
Protection
Agency
401
M
Street,
SW
Washington,
DC
20460
(202)
260­
7400
Fax:
(202)
260­
5
155
perciasepe,
robert@
epa.
gov
Roger
Conway,
US
Department
of
Agriculture
Director,
Ofice
of
Energy
Policy
and
New
Uses
U.
S.
Department
of
Agriculture
1800
M
Street
NW,
Room
4
129
N
Washington,
DC
20036
(202)
694­
5020
Fax:
(202)
694­
5665
rkconway@
econ.
ag.
gov
Cynthia
Dougherty,
Drinking
Water,
US
EnvironmentaI
Protection
Agency
Director,
Ofice
of
Ground
Water
and
Drinking
Water
US
Environmental
Protection
Agency
401
M
Street
SW
Washington,
DC
20460
(202)
260­
5543
Fax
(202)
260­
4383
dougherty.
cynthia@
epa.
gov
WiIIiam
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
Fax
(202)
565­
0090
farland.
wiiliarn@
epa.
gov
(202)
564­
33
19
Barry
McNutt,
US
Department
of
Energy
Senior
Policy
Analyst
Department
of
Energy
1000
Independence
­
Avenue
Room
H021
Washington,
DC
20585
(202)
586­
4448
Fax:
(202)
586­
4447
barry.
rncnutt@
hq.
doe.
gov
Margo
Oge,
Mobile
Sources,
US
Environmental
Protection
Agency
Director,
Office
of
Mobile
Sources
Office
of
Air
and
Radiation
US
Environmental
Protection
Agency
401
M
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
401
M
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
3
1
Atlanta,
GA
30333
Fax
(404)
639­
62
19
mxw5
Wcdc.
gov
(404)
639­
6229
John
Zogor~
ki,
US
Geological
Survey
Project
Chief,
National
Water
Quality
Assessment
Program
US
GeologicaI
Survey
1608
Mountain
View
Road
Rapid
City,
SD
57702
(605)
355­
4560
X214
Fax:
(605)
355­
4523
jszogors@
usgs.
gov
111
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be
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on­
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­

State
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of
Health,
Department
of
Human
Services,
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Pump­
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U.
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S.
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004.
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"Use
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Air
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Criteria
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Carbon
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1998,
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1998).

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S.
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1999).

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S.
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­
First
Half(
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S.
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28,
1999
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April
30,
1999
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119
*...
­.

..
.
P
~

ACRONYMS
AQMD
AS
AST
ASTM
AWWARF
BTEX
BtU
CAA
CAAA
CaIEPA
CARB
CaRFG
CEC
CG
CIIT
co
COZ
CWSRF
DIPE
DOE
DOT
DWSRF
EIA
EPA
EPACT
ETBE
El0
FCC
HC
HE1
IARC
ILEV
LEV­
LLNL
LUST
MNA
MTBE
NAAQS
NAPL
CAFE
GLOSSARY
OF
TERMS
Air
Quality
Management
District
Air
Sparging
Aboveground
Storage
Tank
American
Society
for
Testing
&
Lter,,
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
isoprop
yl
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%
EthanoI/
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
121
NAWQA
NESCAUM
NMOG
NO,
NRC
OMS
OSTP
OUST
OXY
PADD
PAN
PM
POM
PPb
P
P
psi
RBCA
RFG
RVP
SDWA
SIP
SPCC
SULEV
SVE
TAME
TBA
TLEV
ULEV
USDA
US.
EPA
USGS
T50
T90
UST
voc
ZEV
National
Water
Quality
Assessment
P
r
o
p
Northeast
States
for
Coordinated
Air
Use
Management
Non­
Methane
Organic
Gases
Oxides
of
Nitrogen
National
Research
Council
U.
S.
Environmental
Protection
Agency,
Office
of
Mobile
Sources
White
House
Office
of
Science
and
Technolo
U.
S.
Environmental
Protection
Agency,
Office
of
Underground
Storage
Tanks
Winter
OxyfueI
Program
Petroleum
Administration
for
Defense
Districts
Peroxyacetyl
Nitrate
Particulate
Matter
PolycycIic
Organic
Matter
Parts
Per
Billion
Parts
Per
Million
Pounds
Per
Square
Inch
(pressure)
Risk­
Based
Corrective
Action
Reformulated
Gasoline
Reid
Vapor
Pressure
Safe
Drinking
Water
Act
State
Implementation
Plan
Spill
Control
and
Counter
Control
Super
Ultra
Low
Emission
Vehicle
Soil
Vapor
Extraction
Tertiary
Amyl
Methyl
Ether
Tertiary
Butyl
Alcohol
Transitional
Low
Emission
Vehicle
Ultra
Low
Emission
Vehicle
U.
S.
Department
of
Agriculture
U.
S.
Environmental
Protection
Agency
United
States
Geological
Survey
50%
Distillation
Temperature
90%
Distillation
Temperature
Underground
Storage
Tank
Volatile
Organic
Compound
Zero
Emission
Vehicle
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
alkyIation
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
t
the
BTEX
group.
They
represent
one
of
the
heaviest
fractions
in
gasoline.
as
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
stabiIization,
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.

123
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,
SOz,
NOx,
and
PM,
as
we11
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
chemicaIIy
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.

EIO:
EthanoVgasoline
mixture
containing
I
O
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
oiIs.

124
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
unconfined
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.

Oxyfuei
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
fueI
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.

125
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
(I`
M):
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
pohtant.
Recalcitrant:
Unreactive,
nondegradable;
refractory.
SlowIy
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
IrnpIementation
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
C,
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
hels,
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.

126
