PBT
National
Action
Plan
For
Alkyl­
lead
Prepared
by
The
U.
S.
Environmental
Protection
Agency
(EPA)
Persistent,
Bioaccumulative,
and
Toxic
Pollutants
(PBT)
Program
June
2002
Alkyl­
lead
Action
Plan
June
2002
ii
TABLE
OF
CONTENTS
Page
PART
I
–
PRIORITIES
FOR
ACTION
........................................
1
1.
1
The
Problem................................................
2
1.
2
Our
Long­
term
Goal
...........................................
3
1.3
Priority
Actions
(2001
–
2006)
...................................
3
1.
4
Implementation..............................................
4
PART
II
–
TECHNICAL
ASSESSMENT
......................................
6
2.
1
Health
and
Environmental
Assessment..............................
7
2.
1.
1
Description
of
Alkyl­
lead
..................................
7
2.
1.
2
Alkyl­
lead
Use
.........................................
8
2.
1.
2.
1
Aviation
Fuel
...............................
8
2.
1.
2.
2
Other
Non­
highway
Uses
......................
10
2.
1.
2.
3
Competition
Vehicles
(Cars,
Boats,
Etc.)
...........
10
2.
1.
2.
4
Bulk
Terminals,
Bulk
Plants
and
Service
Stations......
11
2.
1.
3
Emissions
...........................................
11
2.
1.
4
Environmental
Transport,
Transformation,
and
Fate...............
13
2.1.5
Human
Exposure
and
Health
Risks
..........................
14
2.
2
Programmatic
Assessment
.....................................
15
2.
2.
1
Current
Regulations
and
Programs
..........................
15
2.
2.
1.
1
Regulations
Controlling
Use
....................
16
2.2.1.2
Regulations
Governing
Emissions,
Releases
and
Spills
.
.
17
2.
2.
1.
3
Regulations
Calling
for
Source
Identification
.........
18
2.
2.
1.
4
Compliance
and
Enforcement
...................
18
2.
2.
1.
5
International
Activities........................
19
2.
2.
1.
6
Activities
Related
to
Products
...................
20
2.
3
Relationship
to
the
Canada­
U.
S.
Great
Lakes
Binational
Toxics
Strategy
......
20
2.
4
Opportunities
Assessment
.....................................
21
2.
4.
1
Issues
Considered
in
the
Development
of
the
Strategic
Approach
.....
21
2.
4.
1.
1
Priority
Setting
.............................
21
2.
4.
1.
2
Data
Gaps
................................
21
2.
4.
1.
3
Regulatory
Constraints
.......................
22
2.
4.
1.
4
Stakeholder
Issues
/
Concerns
..................
22
2.
4.
2
Strategic
Assessment
–
The
Priorities
for
Action
................
23
2.
4.
3
Other
Actions
Considered
................................
23
2.
4.
3.
1
Proposed
Outreach
/
Education
..................
23
2.
4.
3.
2
Proposed
Research
/
Information
Needs
............
24
2.
5
Measuring
Progress..........................................
25
Alkyl­
lead
Action
Plan
June
2002
iii
TABLE
OF
CONTENTS
(Continued)

REFERENCES.........................................................
27
GLOSSARY
...........................................................
iv
APPENDIX
A:
LIST
OF
KEY
CONTACTS
AND
GPRA
GOALS
........................
A­
1
LIST
OF
TABLES
Table
1.
Illustration
of
Available
Racing
Gasoline
..............................
11
Table
2.
Current
Regulations
and
Programs
..................................
16
Table
3.
Violations
Issued
for
Excess
Lead­
Levels
in
Gasoline
.....................
19
Table
4.
Measures
of
Progress
for
Actions
to
Reduce
Risks
from
Alkyl­
lead
............
26
LIST
OF
FIGURES
Figure
1.
Finished
Aviation
Gasoline
Supplied
in
the
U.
S.
1995­
1998.
.................
9
Figure
2.
Total
Lead
Emissions
(Short
Tons)
by
Year.
............................
12
Alkyl­
lead
Action
Plan
June
2002
iv
GLOSSARY
ASTM
American
Society
for
Testing
and
Materials
ATSDR
Agency
for
Toxic
Substances
and
Disease
Registry
CAA
Clean
Air
Act
CAAA
Clean
Air
Act
Amendments
CERCLA
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
CRC
Coordinating
Research
Council
CWA
Clean
Water
Act
FAA
Federal
Aviation
Administration
G­
8
Nations
Canada,
France,
Germany,
Great
Britain,
Italy,
Japan,
Russia,
and
the
United
States
GLNPO
Great
Lakes
National
Program
Office
GPRA
Government
Performance
and
Results
Act
of
1993
MTBE
Methyl
tert­
butyl
ether
NASCAR
National
Association
for
Stock
Car
Automobile
Racing
NAAQS
National
Ambient
Air
Quality
Standards
NIOSH
National
Institute
for
Occupational
Safety
and
Health
NOAA
National
Oceanic
and
Atmospheric
Administration
OAQPS
Office
of
Air
Quality
Planning
and
Standards
OAR
EPA
Office
of
Air
and
Radiation
OECA
Office
of
Enforcement
and
Compliance
Assurance
OIA
EPA
Office
of
International
Activities
ORD
Office
of
Research
and
Development
OSHA
Occupational
Safety
and
Health
Administration
OTAQ
EPA
Office
of
Transportation
and
Air
Quality
PBT
Persistent,
Bioaccumulative,
and
Toxic
RCRA
Resource
Conservation
and
Recovery
Act
SARA/
EPCRA
Superfund
Amendments
and
Reauthorization
Act
/
Emergency
Planning
and
Community
Right­
to­
Know
Act
SDWA
Safe
Drinking
Water
Act
TEL
Tetraethyllead
TML
Tetramethyllead
TRI
Toxic
Release
Inventory
TSCA
Toxic
Substances
Control
Act
Alkyl­
lead
Action
Plan
June
2002
1
PART
I
PRIORITIES
FOR
ACTION
Alkyl­
lead
Action
Plan
June
2002
2
PART
I
PRIORITIES
FOR
ACTION
1.1
THE
PROBLEM
Alkyl­
lead
compounds
are
man­
made
compounds
used
as
a
fuel
additive
to
reduce
"knock"
in
combustion
engines
and
also
to
help
lubricate
internal
engine
components.
Research
has
clearly
shown
that
exposure
to
alkyl­
lead
can
cause
serious
toxic
effects
to
the
nervous
system
of
humans,
with
the
potential
to
cause
neurological
disorders,
such
as
mood
shifts
and
impairment
of
memory.
While
these
exposures
do
not
appear
to
pose
a
health
risk
for
most
of
the
human
population,
certain
groups,
such
as
children
and
certain
occupational
groups
may
be
at
risk.
The
human
exposure
pathways
for
alkyl­
lead
are
through
inhalation
of
leaded
gasoline
vapors,
or
by
dermal
exposure
to
leaded
gasoline.
In
the
body,
alkyl
lead
compounds
are
distributed
through
the
blood
to
"soft
tissues,"
particularly
the
liver,
kidneys,
muscles
and
brain.
Children
are
at
a
higher
risk
of
lead
poisoning
than
adults
due
to
their
lower
body
weights
and
developing
neurological
systems.
Blood­
lead
concentrations
as
low
as
10
:
g/
dL
have
been
associated
with
neurological
damage
in
children,
and
increasing
blood­
lead
levels
have
been
highly
correlated
with
decreased
performance
on
standardized
intelligence
tests
(i.
e.,
lower
I.
Q.
test
scores)
(CDC
2000;
ATSDR,
1999).

Over
the
past
twenty
years,
there
has
been
significant
progress
in
reducing
lead
exposures,
particularly
with
respect
to
preventing
childhood
lead
poisoning.
Data
from
the
Center
for
Disease
Control's
third
National
Health
and
Nutrition
Examination
Survey,
Phase
2
(1991
­
1994)
(CDC,
1997)
shows
that
average
blood
lead
levels
in
children
have
decreased
approximately
80%
since
the
late
1970s
(CDC,
2000).
The
geometric
mean
for
blood­
lead
levels
in
children
has
declined
from
approximately
15
:
g/
dL
in
1976
(Mahaffey
et
al.,
1982)
to
2
:
g/
dL
in
1999
(CDC,
2000).
Total
lead
emissions
have
been
reduced
by
98
percent
between
1970
and
1996
(USEPA,
1997b).
Much
of
this
can
be
attributed
to
the
passage
of
the
1971
Lead­
based
Paint
Poisoning
Prevention
Act,
the
phase­
out
of
lead
in
gasoline
under
the
Clean
Air
Act,
and
the
banning
of
lead­
based
paint.

While
the
use
of
alkyl­
lead
and
associated
health
risks
have
been
tremendously
reduced,
limited
uses
remain
in
the
United
States.
Gasoline
containing
alkyl­
lead
is
still
currently
being
used
as
fuel,
particularly
for
airplanes
(general
aviation
piston
engine
aircraft)
and
race
cars.
In
addition,
significant
international
use
of
gasoline
containing
alkyl­
lead
is
still
occurring.
These
remaining
uses
are
the
focus
of
this
action
plan.
Alkyl­
lead
Action
Plan
June
2002
3
1.2
OUR
LONG­
TERM
GOAL
The
ultimate
goal
of
this
alkyl­
lead
action
plan
is
to
identify
and
reduce
risks
to
human
health
and
the
environment
from
current
and
future
exposure
to
alkyl­
lead.
EPA
believes
that,
with
the
actions
it
has
taken
to
date,
this
goal
is
within
reach.
However,
the
Agency
is
concerned
about
any
sub­
populations
that
may
remain
at
risk,
for
example,
individuals
exposed
at
racetracks
or
general
aviation
airports.
The
Agency
also
recognizes
that
these
remaining
risks
should
not
be
taken
lightly.

EPA
does
not
have
the
authority
under
the
Clean
Air
Act
to
regulate
the
use
of
leaded
gasoline
for
the
racing
industry,
and
the
authority
to
regulate
aircraft
fuel
lies
with
the
Federal
Aviation
Administration.
Therefore,
the
Agency
has
chosen
to
address
the
risks
that
remain
for
alkyl­
lead
through
voluntary
efforts
under
its
Persistent,
Bioaccumulative
and
Toxic
(PBT)
pollutants
program.
The
PBT
program
provides
a
holistic
approach
and
an
agency­
wide
perspective.
It
is
likely
that
further
reductions
in
exposures
to
this
chemical
will
come
only
through
product
substitution
and
voluntary
measures.
A
holistic
approach
such
as
that
provided
by
the
PBT
program
will
ensure
that
the
ultimate
substitute
has
been
carefully
evaluated
within
and
among
all
media
offices
in
EPA.
This
will
reduce
the
chances
of
replacing
one
environmental
problem
with
another.
It
is
from
this
perspective,
then,
that
the
Agency
sets
the
following
priorities
for
action
for
alkyl­
lead.

1.3
PRIORITY
ACTIONS
(2001–
2006)

Alkyl­
lead
is
one
of
12
chemicals
identified
as
Level
1
priority
PBT
pollutants.
Historically,
the
health
effects
and
environmental
concerns
related
to
the
use
of
alkyl­
lead
are
well
documented,
but
EPA
regulations
under
the
Clean
Air
Act
(CAA)
requiring
the
use
of
unleaded
gasoline
in
on­
road
vehicles
have
dramatically
reduced
environmental
and
human
health
impacts
from
the
use
of
alkyl­
lead.
Current
domestic
use
may
still
pose
a
threat
to
certain
populations.
However,
because
of
funding
constraints,
EPA
must
consider
the
proposed
actions
for
alkyl­
lead
in
the
larger
context
of
the
proposed
actions
for
all
twelve
Level
1
substances.
Within
this
context,
the
following
priority
actions
emerged.

Voluntary
Partnership
with
NASCAR.
The
Agency
has
identified
one
key
priority
for
action
for
alkyl­
lead
over
the
next
five
years.
It
will
work
in
voluntary
partnership
with
the
National
Association
for
Stock
Car
Automobile
Racing
(NASCAR)
to
permanently
remove
alkyl­
lead
from
racing
fuels
used,
specifically,
in
the
Busch,
Winston
Cup
and
Craftsman
Truck
Series.
NASCAR
has
also
committed
to
making
their
athletes
available
for
outreach
and
communication
efforts
targeted
at
reducing
use
and
release
of
PBT
substances.

NASCAR
and
its
fuel
supplier
TOSCO
Corporation
(TOSCO)
are
recognized
leaders
in
the
auto
racing
industry.
For
quite
some
time,
NASCAR
has
expressed
its
commitment
to
removing
alkyl­
lead
from
its
racing
fuels.
The
presidents
of
NASCAR
and
TOSCO
are
working
together
to
develop
an
alternative
fuel
recipe
that
will
not
include
alkyl­
lead.
Any
changes
that
they
make
are
expected
to
have
a
significant
effect
throughout
the
industry.
Alkyl­
lead
Action
Plan
June
2002
4
In
1998,
NASCAR
was
very
close
to
having
an
alternative
fuel,
only
to
learn
that
the
fuel
additive
they
were
considering
as
a
replacement
had
its
own
potential
environmental
consequences.
It
was
subsequently
abandoned.
This
has
led
NASCAR
into
discussions
with
the
EPA's
PBT
Program
staff.
NASCAR
will
continue
to
work
with
TOSCO
over
the
next
several
months
to
accelerate
its
efforts
to
find
an
appropriate
fuel
substitute.
EPA
will
offer
technical
assistance
to
NASCAR
and
work
with
them
on
this
effort,
specifically
in
facilitating
an
agencywide
multimedia
review
of
any
alkyl­
lead
substitute
they
develop.

Other
Continued
Efforts.
Although
EPA
will
focus
its
attention
and
resources
primarily
on
the
action
outlined
above,
it
will
continue
to
explore
additional
opportunities
and
engage
in
other
activities
that
will
help
meet
the
goals
of
this
National
Action
Plan.
Most
importantly,
these
include
continuing
current
international
efforts
to
reduce
the
use
of
leaded
gasoline
and
dialogues
with
the
Federal
Aviation
Administration
(FAA).
Continued
current
international
efforts
to
reduce
the
use
of
leaded
gasoline
will
include
participation
in
the
United
Nations
Commission
on
Sustainable
Development,
Summit
of
the
Americas,
Earth
Summit
+5,
the
G­
8
(includes
Canada,
France,
Germany,
Italy,
Japan,
Russia,
the
United
Kingdom,
and
the
United
States)
and
the
Great
Lakes
Binational
Toxics
Strategy.
The
United
States
is
committed
to
being
a
world
leader
in
promoting
the
phase­
out
of
leaded
gasoline
used
in
motor
vehicles.
The
Agency
will
also
continue
to
dialogue
with
the
Federal
Aviation
Administration
on
the
use
of
leaded
gasoline
in
the
aviation
industry
and
the
possibilities
of
reducing
the
lead
content
and/
or
replacing
leaded
gasoline
with
unleaded
gasoline.
Similar
discussions
will
continue
with
the
Coordinating
Research
Council
task
force
investigating
alternative
(no­
lead)
gasoline
for
aircraft.

1.4
IMPLEMENTATION
The
key
Agency
players
in
the
implementation
of
this
action
plan
will
be
the
Office
of
Pollution
and
Prevention
Toxics
(OPPT),
the
Office
of
International
Activities
(OIA),
the
Office
of
Air
and
Radiation
(OAR),
the
Great
Lakes
National
Program
Office
(GLNPO),
and
the
Office
of
Transportation
and
Air
Quality
(OTAQ)
Ann
Arbor
Facility.
OPPT
and
OTAQ
will
continue
to
take
the
lead
in
supporting
the
efforts
of
NASCAR
and
TOSCO
to
develop
a
viable
substitute
for
alkyl­
lead
in
racing
gasoline.
Technical
assistance
to
NASCAR,
specifically
in
facilitating
an
agency­
wide
multimedia
review
of
any
alkyl­
lead
substitute
they
develop,
will
also
be
coordinated
under
OPPT
lead.
EPA's
involvement
in
current
international
efforts
to
reduce
the
use
of
leaded
gasoline
will
continue
under
the
direction
of
OIA.
Dialogues
with
the
FAA
and
the
Coordinating
Research
Council
task
force
investigating
alternative
(non­
lead)
gasoline
for
aircraft
will
be
coordinated
by
OPPT
and
OTAQ.

EPA
also
considers
stakeholder
involvement
essential
to
reaching
the
goal
of
the
PBT
Strategy.
EPA
has
considered
stakeholder
input
in
the
development
of
this
draft
national
action
plan
for
alkyl­
lead,
and
will
now
seek
stakeholder
input
for
its
implementation.
EPA
will
also
encourage
all
interested
partners
to
join
in
establishing
voluntary
agreements
to
reduce
risk
to
human
health
and
the
environment
from
exposure
to
alkyl­
lead.
Primary
stakeholders
in
this
effort
are
the
Federal
Aviation
Administration
(FAA),
the
National
Association
for
Stock
Car
Alkyl­
lead
Action
Plan
June
2002
5
Automobile
Racing
(NASCAR),
the
Coordinating
Research
Council
(CRC),
Agency
for
Toxic
Substances
and
Disease
Registry
(ATSDR),
National
Oceanic
and
Atmospheric
Administration
(NOAA),
the
U.
S.
Coast
Guard,
National
Institute
for
Occupational
Safety
and
Health
(NIOSH),
and
the
Occupational
Safety
and
Health
Administration
(OSHA).
EPA
anticipates
that
each
of
these
groups
will
have
a
significant
role
in
reducing
the
use,
releases,
and
exposure
to
alkyl­
lead
compounds.
Alkyl­
lead
Action
Plan
June
2002
6
PART
II
TECHNICAL
ASSESSMENT
Alkyl­
lead
Action
Plan
June
2002
7
PART
II
TECHNICAL
ASSESSMENT
2.1
HEALTH
AND
ENVIRONMENTAL
ASSESSMENT
2.1.1
Description
of
Alkyl­
lead
Lead
(CAS
number
7439­
92­
1)
is
a
naturally
occurring,
bluish­
gray
metal
originating
in
the
earth's
crust.
It
is
odorless,
tasteless,
and
has
no
known
physiological
value.
It
does
not
dissolve
in
water
and
does
not
burn.
The
vast
majority
of
lead
chemical
compounds
are
inorganic.
However,
lead
can
be
combined
with
organic
chemicals
to
form
lead
compounds
with
very
different
characteristics
from
metallic
lead.
This
action
plan
does
not
address
inorganic
lead,
but
addresses
one
of
the
more
predominant
types
of
organic
lead
compounds:
alkyl­
lead.

Organolead
compounds
are
man­
made
compounds
in
which
a
carbon
atom
of
one
or
more
organic
molecules
is
bound
to
a
lead
atom.
Generally,
"alkyl­
lead"
compounds
are
classified
as
"tetraalkyllead"
compounds
(e.
g.,
tetraethyllead
[TEL]
and
tetramethyllead
[TML]),
"trialkyllead"
compounds
(e.
g.,
trimethyllead
chloride
[TriML]
and
triethyllead
chloride
[TriEL]),
or
"dialkyllead"
compounds
(e.
g.,
dimethyllead
chloride
[DiML]
and
diethyllead
chloride
[DiEL]).
Of
these,
the
tetraalkyllead
compounds,
TEL
and
TML,
are
the
most
common
alkyl­
lead
compounds
that
have
been
used
in
the
past
and
are
still
in
use
today
in
the
United
States.
These
two
alkyl­
lead
compounds
are
the
focus
of
this
National
Action
Plan.

Alkyl­
lead
is
produced
through
several
different
methods
including
through
the
electrolysis
of
an
ethyl
Grignard
reagent
or
through
alkylation
of
a
lead­
sodium
alloy.
Alkyl­
lead
is
used
as
a
fuel
additive
to
reduce
"knock"
in
combustion
engines
(by
contrast,
inorganic
lead
is
used
in
leaded
paint).
The
most
common
alkyl­
lead
compound
used
as
an
anti­
knock
agent
in
gasoline
is
TEL
lead,
though
TML
lead
is
also
used
as
an
anti­
knock
agent.
These
alkyl­
lead
compounds
also
help
to
lubricate
internal
engine
components
and
protect
intake
and
exhaust
valves
against
recession.

Although
the
use
of
alkyl­
lead
has
been
prohibited
by
legislation
in
on­
road
automotive
gasoline,
several
authorized
uses
of
alkyl­
lead
still
remain.
Currently,
the
largest
use
of
alkyllead
occurs
in
aviation
gasoline
for
general
aviation
(piston­
engine)
aircraft,
racing
gasoline,
and
recreational
marine.
None
of
these
uses
are
subject
to
any
of
the
regulations
that
restrict
leaded
motor
gasoline
use.
These
current
uses,
as
well
as
trace
amounts
of
lead
in
automotive
gasoline,
result
in
releases
to
the
environment.
1
Additional
information
on
alkyl­
lead
sinks,
fate
and
transport,
and
exposure
pathways
is
presented
in
sections
2.1.4
and
2.1.5.
2
Current
data
on
the
use
of
leaded
gasoline
for
these
sources
was
not
available
at
the
time
of
this
action
plan
development.

Alkyl­
lead
Action
Plan
June
2002
8
Sources
of
alkyl­
lead
emissions
include:

#
Airport
fuel
terminals
#
Bulk
plants­
aviation
gasoline
#
Bulk
plants­
leaded
racing
and
other
non­
road
vehicle
gasoline
#
Evaporative
emissions
from
aircraft
#
Evaporative
emissions
from
non­
road
vehicles
#
Spills
from
fuel
loading,
transfer,
storage
and
fueling
Sinks
1
include:

#
Soils
and
sediments
#
Fish
and
shellfish
2.1.2
Alkyl­
lead
Use
Leaded
gasoline
(containing
alkyl­
lead)
is
used
as
fuel
predominantly
in
the
aviation
(piston
engine)
industry,
but
also
in
non­
road
competition
race
vehicles
(cars,
boats,
etc.)
2
.

Current
overall
production
and
use
rates
of
alkyl­
lead
in
gasoline
in
the
U.
S.,
particularly
for
non­
road
motor
vehicles,
are
difficult
to
determine
due
to
the
fact
that
the
U.
S.
Department
of
Energy
discontinued
the
tracking
of
leaded
gasoline
in
1990.
Thus,
most
of
the
available
information
on
alkyl­
lead
use
in
gasoline
is
limited
to
older
data
on
sales,
imports,
exports
and
throughput
at
bulk
distribution
plants.

The
EPA
TSCA
Chemical
Inventory
Chemical
Update
System
indicates
that
alkyl­
lead
was
not
manufactured
domestically
as
of
1994.
However,
the
U.
S.
Department
of
Commerce
web
site
documents
that,
in
1998,
the
quantity
of
antiknock
preparations
imported
into
the
U.
S.
was
approximately
14.4
million
pounds
per
year
(based
on
TEL
or
TEL/
TML
mixtures)
and
the
quantity
exported
was
7.07
million
pounds
per
year
(based
on
lead
compounds)
(U.
S.
Department
of
Commerce,
1998).
It
is
reasonable
to
assume
the
majority
of
the
7
million
pound
difference
between
imports
and
exports
was
used
for
the
production
of
leaded
gas.

2.1.2.1
Aviation
Fuel
Aviation
gasoline
(avgas)
is
currently
the
fuel
with
the
greatest
alkyl­
lead
(TEL)
content,
ranging
from
4.4x10
­3
to
8.8x10
­3
lbs
as
lead/
gal
(USEPA,
1998a).
Only
TEL
is
used
in
aviation
gasoline.
The
other
aviation
fuels,
such
as
Jet
kerosene
and
JP­
4,
do
not
contain
alkylated
lead
compounds.
Leaded
avgas
is
currently
available
in
several
grades
with
differing
lead
concentrations,
and
is
used
primarily
in
civil
aviation
for
reciprocating
piston
engine
aircraft.
Avgas
80/
87
has
the
lowest
lead
content
at
0.5
grams
lead
per
gallon,
and
is
only
used
in
very
low
compression
ratio
engines.
Avgas
100/
130
is
a
higher
octane
grade
aviation
gasoline,
containing
about
4
grams
of
lead
per
gallon.
Finally,
a
lower­
lead
blend,
Avgas
100LL
("
low
Alkyl­
lead
Action
Plan
June
2002
9
329
311
330
295
270
280
290
300
310
320
330
340
1995
1996
1997
1998
Year
Finished
Aviation
Gasoline
Supplied
(millions
of
gallons)

Figure
1.
Finished
Aviation
Gasoline
Supplied
in
the
U.
S.
1995­
1998.
lead")
was
designed
to
replace
Avgas
100/
130.
Avgas
100LL
contains
about
2
grams
of
lead
per
gallon,
and
is
typically
the
most
commonly
used
aviation
gasoline
(Purvis,
1999).

First
sales
of
total
aviation
gasoline
(all
grades)
in
1990
totaled
322.6
million
gallons
(U.
S.
DOE,
1991),
and
throughput
at
bulk
plants
was
also
322
million
gallons
(USEPA,
1993).
In
1998,
the
quantities
of
finished
aviation
gasoline
(all
grades)
produced
at
refineries
and
imported
into
the
U.
S.
totaled
298.8
million
gallons
and
1.8
million
gallons,
respectively
(U.
S.
DOE,
1998).
There
were
no
exports
of
aviation
gasoline
in
1998
(U.
S.
DOE,
1998).
Adjusting
for
changes
in
avgas
stocks,
the
total
volume
of
aviation
gasoline
supplied
as
a
product
in
1998
was
295.3
million
gallons
(U.
S.
DOE,
1998).
Trends
in
the
total
finished
aviation
gasoline
supplied
in
the
U.
S.
between
1995­
1998
are
summarized
in
Figure
1.

As
the
volumes
above
represent
only
total
gallons
of
aviation
gasoline,
the
exact
amount
of
alkyl­
lead
associated
with
this
total
is
unknown
without
information
which
breaks
down
the
production
and
use
of
aviation
gasoline
by
grade.
However,
based
on
American
Society
for
Testing
and
Materials
(ASTM)
specifications
for
100LL
aviation
gasoline
(which
typically
constitutes
the
majority
of
avgas
consumption),
a
rough
conservative
estimate
of
TEL
used
in
aviation
can
be
derived
for
1998
as
295.3
million
gallons
of
gasoline
x
2.128
g
(TEL)/
gallon
=
628
million
grams
of
TEL,
which
is
equivalent
to
1.39
million
pounds
of
TEL.
Alkyl­
lead
Action
Plan
June
2002
10
2.1.2.2
Other
Non­
highway
Uses
In
addition
to
aviation,
non­
road
leaded
fuel
consumption
includes
use
in
competitive
race
vehicles
(cars,
boats,
etc.)
(USEPA,
1993).
In
1990,
first
sales
of
leaded
motor
gasoline
in
the
U.
S.
were
estimated
to
total
5.8
billion
gallons,
which
comprised
about
4.8
percent
of
the
total
gasoline
sales
(U.
S.
DOE,
1991).
By
1991,
use
of
leaded
gasoline
had
declined
to
3.1
billion
gallons
representing
3.2
percent
of
total
gasoline
use.
(Unpublished
data,
USEPA,
1991).

Although
more
recent
data
on
total
motor
gasoline
production
levels
is
available,
the
proportion
of
leaded
gasoline
produced,
as
well
as
the
rate
of
leaded
gasoline
use
by
each
of
the
non­
road
sources,
is
unknown.
Total
(leaded
and
unleaded)
motor
gasoline
supplied
in
the
U.
S.
between
the
years
1995
and
1998
has
gradually
increased
from
119.4
billion
gallons
in
1995
to
126.5
billion
gallons
in
1998
(U.
S.
DOE,
1998).
If
the
supply
of
leaded
gasoline
has
not
increased
from
the
1991
level
of
3.1
billion
gallons,
the
percentage
of
leaded
gas
based
on
1998
total
motor
gasoline
supply
levels
would
be
2.45%.
However,
it
is
more
likely
that
the
volume
of
leaded
gasoline
supply
has
actually
decreased
since
1991.

In
1997,
imports
of
leaded
gasoline
into
the
U.
S.
totaled
more
than
9.4
million
gallons,
and
exports
were
about
9.1
million
gallons
(U.
S.
Bureau
of
the
Census,
1998).

2.1.2.3
Competition
Vehicles
(Cars,
Boats,
etc.)

Currently,
no
readily
available
government
source
of
information
exists
on
the
amount
of
leaded
fuel
used
by
racing
cars
and
boats.
The
National
Motor
Sports
Council
(1999)
estimates
that
approximately
100,000
gallons
of
leaded
gasoline
were
used
by
NASCAR
in
1998.
There
are
many
different
suppliers
of
leaded
racing
fuel
in
the
United
States.
Almost
all
of
these
suppliers
offer
racing
fuel
at
various
octanes
and
lead
content.
For
example,
76®
Racing
Gasoline,
the
"Official
Fuel
of
NASCAR,"
offers
four
different
types
of
racing
gasoline:
100
Octane
Unleaded,
110
Octane
Leaded,
114
Octane
Leaded,
and
118
Octane
Leaded.
In
addition
to
76®,
many
suppliers
offer
unleaded
fuel
as
well
as
leaded
fuel.
Therefore,
it
seems
likely
that,
to
some
extent,
unleaded
gasoline
is
being
used
for
races
or
at
least
in
particular
race
vehicles.
Table
1
illustrates
several
suppliers
and
the
types
of
racing
fuel
they
offer.

As
an
alternative
to
the
purchase
of
commercial
racing
gasoline,
gasoline
additives
may
be
purchased
that
can
be
added
to
unleaded
motor
gasoline
to
raise
the
octane
level.
For
example,
Tosco
Racing
Fuels
offers
the
"Accelerator
Race
Fuel
Concentrate"
in
both
a
leaded
and
unleaded
form.

There
is
also
evidence
that,
to
some
degree,
leaded
aviation
gasoline
may
be
added
to
the
fuel
used
for
some
racing
vehicles.
For
example,
some
of
the
suppliers
of
gasoline
additive
products
present
information
on
how
their
concentrate
can
be
blended
with
100LL
to
create
a
higher
octane
racing
fuel.
Alkyl­
lead
Action
Plan
June
2002
11
Table
1.
Illustration
of
Available
Racing
Gasoline
Supplier
Racing
Gasolines
Offered
Octane
Lead
Content
76
Racing
Gasoline
(Union
76)
76
Unleaded
Racing
Gasoline
76
Leaded
Racing
Gasoline
76
Superstock
Racing
Gasoline
76
Prostock
Racing
Gasoline
100
110
114
118
Unleaded
Unknown
Unknown
Unknown
Phillips
66
Phillips
B­
32
Phillips
B­
33
Phillips
B­
35
Phillips
B­
37
Phillips
B­
42
110
114
101
118
105
4.0
ml/
gal
4.0
ml/
gal
Unleaded
6.0
ml/
gal
Unleaded
Sunoco
Sunoco
GT
Unleaded
Sunoco
GT
Plus
Unleaded
Sunoco
Standard
Sunoco
Supreme
Sunoco
Maximal
Sunoco
Supreme
N.
O.
S
Sunoco
Maximal
#5
100
104
110
112
116
117
116
Unleaded
Unleaded
Unknown
Unknown
Unknown
5.0
ml/
gal
6.0
ml/
gal
2.1.2.4
Bulk
Terminals,
Bulk
Plants
and
Service
Stations
Bulk
gasoline
terminals
are
the
primary
distribution
facilities
for
the
gasoline
produced
at
refineries
prior
to
its
distribution
by
tank
trucks
to
consumers.
Some
gasoline
is
distributed
from
bulk
terminals
to
secondary
distribution
facilities
called
bulk
plants
before
it
is
distributed
to
smaller
consumers
such
as
small
service
stations.
Bulk
terminals
and
plants
may
distribute
both
leaded
and
unleaded
gasolines
for
various
uses
(e.
g.,
motor
vehicle
gasoline
and
aviation
gasoline).
In
1990,
the
number
of
distribution
facilities
nationwide
were
estimated
at
748
bulk
terminals,
12,600
bulk
plants,
and
387,750
service
stations
(USEPA,
1993).
The
majority
of
leaded
aviation
gasoline
is
distributed
by
tank
truck
directly
from
the
refinery
to
the
storage
tanks
and
refueling
equipment
at
airports.

2.1.3
Emissions
Overall
lead
emissions
(all
forms
of
lead
and
lead
compounds,
including
alkyl­
lead)
in
the
U.
S.
have
decreased
by
two
orders
of
magnitude
between
1970
(220,869
short
tons
emitted)
and
1996
(3,869
short
tons
emitted)
(USEPA,
1997b).
Figure
2
summarizes
estimates
of
total
lead
emissions
by
year.

Most
notable
in
Figure
2
is
that
the
greatest
reduction
in
lead
emissions
occurred
between
1970
and
1985.
This
large
reduction
is
a
direct
result
of
the
regulated
phase­
out
of
leaded
gasoline
(reductions
in
both
the
lead
content
per
gallon
and
the
total
gallons
produced)
and
the
increased
availability
of
unleaded
gasoline
(USDHHS,
1997).
Remaining
sources
of
airborne
3
Through
the
combustion
process
in
automotive
engines,
alkyl­
lead
compounds
combine
with
fuel
scavengers
to
form
lead
oxides.
Alkyl­
lead
is
the
only
known
significant
source
of
lead
in
gasoline.

Alkyl­
lead
Action
Plan
June
2002
12
0
50,
000
100,000
150,000
200,000
250,000
1970
1975
1980
1985
1990
1995
Year
Lead
(short
tons)

Figure
2.
Total
Lead
Emissions
(Short
Tons)
by
Year.

[Figure
reproduced
from
National
Air
Pollutant
Emission
Trends
Report,
1970­
1996
(USEPA,
1997]
lead
emissions
3
include
bulk
production
plants
for
aviation
gasoline,
non­
road
vehicles,
waste
incinerators,
metal
processing
facilities,
and
other
fuel
combustion
facilities
(e.
g.,
electrical
utility,
industrial).
The
available
data
on
specific
types
of
releases
of
lead
compounds
are
discussed
below,
including
exhaust
emissions,
evaporative
emissions,
and
spills
and/
or
leaks
(from
fuel
loading,
transfer,
storage,
and
fueling).
The
focus
of
the
discussion
is
on
lead
emissions
attributable
to
the
use
of
alkyl­
lead,
either
direct
alkyl­
lead
emissions
or
lead
emissions
resulting
from
combustion
of
fuel
containing
alkyl­
lead.
Data
specific
to
alkyl­
lead
are
presented
where
possible.
However,
in
some
cases,
the
information
is
limited
to
reports
of
inorganic
lead
releases
only.

Evaporative
Emissions.
No
significant
amounts
of
alkyl­
lead
have
been
observed
to
be
released
via
tailpipe
emission
during
the
combustion
of
leaded
gasoline
(USEPA,
1993),
as
only
a
very
small
percentage
(0.2%­
0.4%)
of
alkyl­
lead
is
typically
exhausted
uncombusted
when
driving
at
constant
speeds
(Grandjean,
1983).
Lead
releases
from
the
combustion
of
leaded
gasoline
predominantly
occur
in
the
form
of
inorganic
lead
/
lead
halides.
Alkyl­
lead
releases
from
these
sources
are
primarily
associated
with
evaporative
emissions
or
spills
that
may
occur
during
fuel
distribution
or
refueling,
as
well
as
evaporative
emissions
that
can
originate
from
unburned
fuel
in
the
carburetor
or
gas
tank.
Alkyl­
lead
Action
Plan
June
2002
13
In
response
to
the
1990
Clean
Air
Act
Amendments
(CAAA),
which
call
for
the
identification
of
source
categories
emitting
90
percent
of
the
total
national
alkyl­
lead
emissions
(plus
six
other
air
toxics)
the
EPA
published
the
1990
Emissions
Inventory
of
Section
112(
c)(
6)
Pollutants
in
April
of
1998.
In
the
inventory,
the
total
national
emissions
of
TEL
and
TML
in
1990
were
estimated
to
be
810.6
lbs
of
TEL
and
481.23
lbs
of
TML.
The
112(
c)(
6)
estimates
assumed
that
evaporative
emissions
associated
with
the
use
of
alkyl­
lead
in
custom
blended
fuels
(i.
e.,
in
competitive
race
vehicles)
were
negligible
compared
to
evaporative
emissions
associated
with
aviation.

2.1.4
Environmental
Transport,
Transformation,
and
Fate
Alkyl­
lead
is
released
to
the
environment
primarily
through
evaporative
emissions
from
unburned
gasoline
retained
in
an
engine's
carburetor
or
fuel
tanks
and
through
evaporative
losses
during
the
filling
of
gasoline
tanks,
accidental
spillages,
and
releases
during
production.
However,
alkyl­
lead
compounds
combine
with
other
compounds
during
the
combustion
process
to
form
lead
halides
(e.
g.,
PbBrCl,
2PbBrCl
C
NH4Cl,
etc.)
that
are
subsequently
emitted
as
microparticulates
in
exhaust.

Alkyl­
lead
in
the
atmosphere
degrades
rapidly
by
direct
photolysis,
reaction
with
ozone,
and
by
reaction
with
hydroxyl
compounds.
The
half­
lives
of
TEL
and
TML
in
summer
atmospheres
are
approximately
two
hours
and
nine
hours,
respectively.
In
winter
atmospheres,
the
half
lives
of
both
TEL
and
TML
are
several
days.
In
water
and
soil,
alkyl­
lead
compounds
are
also
degraded
to
other
forms
of
lead,
eventually
forming
stable
inorganic
lead
compounds.
Therefore,
alkyl­
lead
itself
is
not
a
persistent
environmental
compound.
However,
it
breaks
down
in
the
environment
(or
is
emitted
following
combustion)
to
other
forms
of
lead
which
are
much
more
persistent.

Airborne
lead
particles
(such
as
those
emitted
as
exhaust)
may
remain
airborne
for
up
to
10
days
and,
therefore,
may
be
transported
far
from
the
original
source.
Lead
is
removed
from
the
atmosphere
and
deposited
on
soil
and
water
surfaces
via
wet
or
dry
deposition.
In
soils,
most
lead
is
retained
via
the
formation
of
stable
solid
phase
compounds,
precipitates,
or
complexes
with
organic
matter.
In
general,
most
of
these
forms
of
lead
are
quite
insoluble
and
thus
not
easily
leached
to
underground
water.
However,
leaching
may
occur
under
acidic
conditions,
where
lead
concentrations
are
extremely
high,
or
in
the
presence
of
substances
(e.
g.,
soluble
organic
matter,
high
concentrations
of
chlorides
or
sulfates)
that
form
relatively
soluble
complexes
with
lead.
In
most
surface
and
ground
waters,
relatively
little
lead
is
found
in
a
dissolved
form;
lead
is
typically
bound
to
sediments.
Transport
of
lead
to
surface
waters
can
occur
through
direct
deposition
from
the
atmosphere,
via
industrial
waste
water
discharge,
or
as
runoff
(e.
g.,
lead
associated
with
suspended
solids
in
the
erosional
process)
(ATSDR,
1999).

Inorganic
lead
may
bioconcentrate
in
some
aquatic
animals,
especially
benthic
organisms
such
as
bottom
feeding
fish
and
shellfish
such
as
mussels,
and
some
crops
can
become
contaminated
with
lead
by
exposure
to
exhaust
in
the
air
or
lead
in
the
soil
(ATSDR,
1999).
However,
inorganic
lead
does
not
appear
to
be
biomagnified
in
aquatic
or
terrestrial
food
chains
(ATSDR,
1999).
Alkyl­
lead
and
other
organolead
compounds
have
also
been
found
to
Alkyl­
lead
Action
Plan
June
2002
14
significantly
bioconcentrate
in
aquatic
organisms
(e.
g.,
fish
and
shellfish),
although,
again,
biomagnification
of
organolead
compounds
has
not
been
shown
(ATSDR,
1999).

2.1.5
Human
Exposure
and
Health
Risks
The
human
exposure
pathways
for
alkyl­
lead
are
through
inhalation
of
leaded
gasoline
vapors,
or
by
dermal
exposure
to
leaded
gasoline.
Unlike
metallic
forms
of
lead,
alkyl­
lead
is
easily
absorbed
through
the
skin.
Additionally,
through
the
combustion
process,
alkyl­
lead
in
gasoline
is
converted
to
lead
halides
and
exhausted
into
the
air
where
it
can
be
inhaled.
These
lead
halides
create
the
potential
for
exposure
to
lead
through
ingestion
of
soil
or
dust
containing
lead,
and
ingestion
of
lead­
contaminated
food
or
water.

The
absorption
of
lead
is
influenced
by
the
route
of
exposure.
Due
to
the
lipophilic
nature
of
alkyl­
lead
and
its
ability
to
permeate
biological
membranes,
alkyl­
lead
is
absorbed
rapidly
and
extensively
through
the
skin.
For
this
reason,
alkyl­
lead
is
much
more
bioavailable
and
is
considered
to
be
much
more
toxic
than
inorganic
forms
of
lead.
Further,
the
toxicity
of
alkyl­
lead
compounds
varies
with
the
degree
of
alkylation.
Tetraalkyllead
compounds
such
as
TEL
and
TML
are
considered
to
be
more
toxic
than
trialkylead
or
dialkyllead
compounds.

With
the
phase­
out
of
leaded
gasoline
used
in
on­
road
vehicles,
there
has
been
a
substantial
reduction
in
the
risk
of
exposure
for
the
general
public.
However,
as
gasoline
containing
alkyl­
lead
is
still
currently
being
used
as
fuel
(particularly
for
race
cars
and
airplanes),
certain
subpopulations
may
remain
at
risk.

Lead
particles
can
remain
airborne
for
some
time
following
the
initial
introduction
into
the
atmosphere.
Therefore,
residents
in
the
vicinity
of
race
tracks
and
general
aviation
airports
where
leaded
gasoline
is
still
being
used
as
fuel
may
have
an
increased
risk
of
lead
exposure.
Similarly,
spectators
at
racing
events
or
air
shows
may
also
be
exposed
to
alkyl­
lead
emissions
resulting
from
fueling
or
to
lead
compounds
emitted
as
exhaust.
However,
the
available
information
is
too
limited
at
this
time
to
pursue
a
quantitative
analysis
of
risk
for
this
source
and
potential
exposure
pathway.

Aviation
fuel
attendants
and
mechanics
are
potentially
exposed
due
to
inhalation
of
alkyllead
compounds
during
fueling,
evaporative
emissions
from
spills,
or
evaporative
emissions
from
unused
gasoline
remaining
in
the
engine
or
fuel
tanks.
Further,
these
populations
are
also
at
risk
because
of
possible
dermal
absorption
of
gasoline
containing
alkyl­
lead
compounds.
However,
the
available
information
is
too
limited
at
this
time
to
pursue
a
quantitative
analysis
of
risk
for
this
source
and
potential
exposure
pathway.

In
the
body,
alkyl­
lead
compounds
are
metabolized
in
the
liver
by
oxidative
dealkylation
catalyzed
by
cytochrome
P­
450.
Through
this
process,
alkyl­
lead
compounds
are
converted
to
triethyllead­
and
trimethyllead­
metabolites
and
inorganic
lead.
It
is
these
three
compounds
that
are
thought
to
cause
the
toxic
effects
of
lead.
In
the
body,
triethyllead
and
trimethyllead
compounds
are
distributed
through
the
blood
to
"soft
tissues"
particularly
the
liver,
kidneys,
muscles,
and
brain.
Experiments
on
mice
and
rabbits
have
suggested
that
the
highest
Alkyl­
lead
Action
Plan
June
2002
15
concentration
of
triethyllead
compounds
is
found
in
the
liver,
kidneys,
brain,
and
muscles
in
that
order.
Initial
symptoms
of
alkyl­
lead
poisoning
include,
among
others:
anorexia,
insomnia,
tremor,
weakness,
fatigue,
nausea
and
vomiting,
mood
shifts
such
as
aggression
or
depression,
and
impairment
of
memory.
In
the
case
of
acute
alkyl­
lead
poisoning,
possible
health
effects
include
mania,
convulsions,
delirium,
fever,
coma,
and
in
some
cases
even
death.

The
inorganic
lead
compounds
emitted
as
exhaust
(e.
g.,
PbBrCl,
2PbBrCl
C
NH4Cl,
etc.)
through
the
combustion
process
(as
a
direct
result
of
the
use
of
alkyl­
lead
in
gasoline)
also
contribute
to
human
exposure
through
ingestion
and/
or
inhalation.
The
biochemistry
and
toxicology
of
inorganic
lead
differs
from
that
of
alkyl­
lead
compounds.
However,
lead
poisoning
due
to
the
ingestion
or
inhalation
of
inorganic
lead
compounds
is
a
widely
recognized
public
health
problem.
Blood­
lead
concentration
is
a
commonly
used
measure
of
body
lead
burden.
Children
are
at
a
higher
risk
of
lead
poisoning
than
adults
due
to
their
lower
body
weights
and
developing
neurological
systems.
Blood­
lead
concentrations
as
low
as
10
to
15
:
g/
dL
have
been
associated
with
neurological
damage
in
children,
and
increasing
blood­
lead
levels
have
been
highly
correlated
with
decreased
performance
on
standardized
intelligence
tests
(i.
e.,
lower
I.
Q.
test
scores).
Adverse
health
effects
such
as
impaired
hearing
acuity
and
interference
with
vitamin
D
metabolism
have
also
been
observed
at
blood­
lead
levels
of
10
to
15
:
g/
dL.
Increased
blood
pressure,
delayed
reaction
times,
anemia,
and
kidney
disease
may
become
apparent
at
blood­
lead
concentrations
between
20
and
40
:
g/
dL.
Symptoms
of
very
severe
lead
poisoning,
such
as
kidney
failure,
abdominal
pain,
nausea
and
vomiting,
and
pronounced
mental
retardation
can
occur
at
blood­
level
concentrations
as
low
as
60
:
g/
dL.
At
even
higher
concentrations,
inorganic
lead
poisoning
can
result
in
convulsions,
coma,
or
death.

2.2
PROGRAMMATIC
ASSESSMENT
2.2.1
Current
Regulations
and
Programs
Current
regulations
and
programs
targeting
lead
emissions
and
releases
(including
alkyl­
lead
compounds)
are
presented
in
Table
2.

As
seen
in
the
table,
the
1990
CAAA
specifically
target
the
use
of
leaded
gasoline
for
onroad
vehicles,
calling
for
a
complete
prohibition
on
the
use
of
leaded
gasoline
in
on­
road
vehicles
after
December
31,
1995
(§
220).
However,
the
1990
CAAA
specifically
exempt
fuels
for
race
cars
or
"Competition
Use
Vehicles."
Alkyl­
lead
Action
Plan
June
2002
16
Table
2.
Current
Regulations
and
Programs
Regulations
CAA
/
CAAA
CWA
SDWA
RCRA
SARA
/
EPCRA
CERCLA
Current
Standards
and
Regulations
§109:
NAAQS
is
1.5
:
g/
m³
(lead)

§112(
b):
Lead
is
designated
a
HAP;
Source
categories
identified
under
§112(
c)(
6);
Emission
standards
to
be
promulgated
§220:
Use
of
gasoline
containing
>
0.05
grams
of
lead
per
gallon
in
on­
road
vehicles
prohibited
(Leaded
gasoline
is
still
permitted
in
nonroad
vehicles)

§211(
g):
Prohibits
misfueling
of
vehicles
built
after
1990
designed
for
unleaded
gasoline
CWA
Priority:
Lead
and
lead
compounds
are
listed
priority
pollutants
(40CFR
423);
subject
to
NPDES
effluent
limitations
under
§304(
b)
(40CFR
122)
and
general
pretreatment
(40CFR
403)
NPDWR:
Action
Level
is
0.15
mg/
L
lead
(treatment
technique)

MCL
Goal
is
zero
Subtitle
C:
Leadcontaining
substances
may
be
classified
hazardous
wastes
based
on
toxicity
characteristic
(40CFR
261.24);
subject
to
hazardous
waste
regulations
(40CFR
260
­
266
and
268)
and
ground
water
monitoring
requirements
(40CFR
264
and
265)

Universal
treatment
standards
for
lead
in
waste
(40CFR
268.40)
§313:
Releases
of
lead
and
lead
compounds
(by
facilities
with
10
or
more
employees
and
that
process
25,000
lbs.,
or
otherwise
use
10,000
lbs.)
must
be
reported
to
TRI
(40CFR
372.65)

Jan.
17,
2001
Federal
Register
amendment
lowered
the
TRI
reporting
threshold
for
lead
and
lead
compounds
to
100
lbs/
year
(66
FR
4499)
§103:
Spills
of
tetraethyl
lead
>
10
lbs.
must
be
reported
to
the
National
Response
Center
Policy
and
Programs
–
Binational
Toxics
Strategy
Level
1
substance
–
International
Joint
Commission
(IJC)
Critical
Pollutant
–
Tier
I
chemical
under
the
Canada­
Ontario
Agreement
–
Recognized
pollutant
in
Lake
Superior
Lakewide
Management
Plan
(LaMP)
–
Targeted
chemical
in
the
Great
Lakes
Regional
Air
Toxic
Emissions
Inventory
Project
–
Included
in
the
USEPA
Cumulative
Exposure
Project
(lead
compounds)
–
Included
in
CAA
§112(
m)
program,
Atmospheric
Deposition
to
Great
Lakes
and
Coastal
Waters
–
Children's
blood
lead
levels
monitored
in
NHANES
–
OIA
program
on
international
efforts
to
phase­
out
lead
in
gasoline
2.2.1.1
Regulations
Controlling
Use
In
the
early
1970s,
EPA
issued
two
regulations
under
the
statutory
authority
of
the
1970
Clean
Air
Act
(CAA).
First,
EPA
required
major
gasoline
retailers
to
begin
selling
one
grade
of
unleaded
gasoline
by
July
1,
1974.
This
mandate
was
primarily
focused
on
preventing
the
deterioration,
as
a
result
of
leaded
gasoline,
of
emissions
control
systems
(e.
g.,
catalytic
converters)
in
motor
vehicles
so
equipped.
In
developing
these
regulations,
EPA
first
established
the
working
definition
of
"unleaded"
gasoline
as
"gasoline
containing
not
more
than
0.05
gram
of
lead
per
gallon
and
not
more
than
0.005
gram
of
phosphorus
per
gallon"
[38FR1255,
January
10,
1973].
Second,
EPA
issued
a
regulation
calling
for
the
gradual
phase­
out
of
leaded
gasoline.
The
schedule
for
reduction
of
lead
content
in
automobile
gasoline
was
1.7
grams
per
gallon
Alkyl­
lead
Action
Plan
June
2002
17
(g/
gal)
in
1975,
to
1.4
g/
gal
in
1976,
1.0
g/
gal
in
1977,
0.8
g/
gal
in
1978,
and
0.5
g/
gal
in
1979
[38FR33741,
December
6,
1973].
Subsequent
regulations
reduced
the
allowable
lead
content
to
0.1
g/
gal
in
1986
[50FR9397,
March
7,
1985],
and
prohibited
leaded
gas
use
after
1995
[61FR3837,
February
2,
1996].
Most
recently,
alkylated
lead
compounds
have
been
regulated
under
the
1990
CAAA.
Section
220
of
the
CAAA
specifically
targets
the
use
of
leaded
gasoline
for
on­
road
vehicles,
calling
for
a
complete
prohibition
on
the
use
of
leaded
gasoline
in
on­
road
vehicles
after
December
31,
1995.
However,
as
outlined
below,
the
1990
CAAA
specifically
exempt
fuels
for
race
cars
or
"Competition
Use
Vehicles."
The
following
components
of
the
1990
CAAA
relate
to
the
use
of
alkyl­
lead
in
gasoline:

#
Prohibition
on
the
Use
of
Leaded
Gasoline
in
On­
Road
Vehicles.
Section
211(
n)
of
the
1990
CAAA
states:
"After
December
31,
1995,
it
shall
be
unlawful
for
any
person
to
sell,
offer
for
sale,
supply,
offer
for
supply,
dispense,
transport,
or
introduce
into
commerce,
for
use
as
fuel
in
any
motor
vehicle
(as
defined
in
Section
219(
2))
any
gasoline
which
contains
lead
or
lead
additives."
This
provision
applies
only
to
onroad
vehicles.
Enacting
regulations
were
promulgated
[61FR3837,
February
2,
1996].

#
Misfueling
with
Leaded
Gasoline.
Section
211(
g)
of
the
1990
CAAA
prohibits
misfueling
vehicles
built
after
1990
(or
vehicles
designated
solely
for
unleaded
gasoline)
with
leaded
gasoline.

#
Prohibition
on
Production
of
Engines
Requiring
Leaded
Gasoline.
Section
218
of
the
1990
CAAA
requires
USEPA
to
promulgate
rules
that
prohibit
the
"manufacture,
sale,
or
introduction
into
commerce
of
any
engine
that
requires
leaded
gasoline."
Further,
these
rules
apply
to
all
motor
vehicle
engines
and
non­
road
engines
manufactured
after
the
1992
model
year.

Thus,
the
sale
or
use
of
gasoline
containing
alkyl­
lead
(greater
than
0.05
grams
of
lead
per
gallon)
is
now
prohibited
in
on­
road
vehicles
[40CFR
Part
80.22].

2.2.1.2
Regulations
Governing
Emissions,
Releases
and
Spills
The
1990
CAAA
also
contain
language
specific
to
emissions
of
lead
compounds
resulting
from
the
use
of
leaded
gasoline.
Lead
compounds
(not
alkyl­
lead
specifically)
are
included
in
the
CAA
Section
112
list
of
hazardous
air
pollutants
(HAPs).
The
EPA
developed
a
list
of
categories
of
stationary
sources
that
emit
HAPs
for
development
of
emissions
standards
established
under
Section
112,
including
maximum
achievable
control
technology
standards
(MACT)(
40CFR
Part
63).

The
Clean
Water
Act
(CWA)
prohibits
any
person
from
discharging
a
pollutant
from
a
point
source
into
navigable
waters
without
a
National
Pollutant
Discharge
Elimination
System
(NPDES)
permit
(33
U.
S.
C.
sec.
1342,
40
CFR
122).
Under
the
CWA,
lead
and
lead
compounds
are
listed
priority
pollutants
(40CFR
423).
As
a
result,
many
facilities
are
subject
to
lead
effluent
limits
or
monitoring
requirements
in
their
NPDES
permits.
Alkyl­
lead
Action
Plan
June
2002
18
Lead­
containing
substances
may
be
classified
as
hazardous
wastes
under
the
Resource
Conservation
and
Recovery
Act
(RCRA),
Subtitle
C
(40CFR
261.24).
As
such,
lead­
containing
wastes
may
be
subject
to
hazardous
waste
regulations
(40CFR
260
through
266
and
268)
and
ground
water
monitoring
requirements
(40CFR
264
and
265).
RCRA
also
establishes
Universal
Treatment
Standards
for
lead
in
wastes
(40CFR
268.40).

Section
313
of
Title
III
of
the
1986
Superfund
Amendments
and
Reauthorization
Act
(SARA)
also
requires
that
releases
of
lead
and
lead
compounds
to
air,
water,
or
land
be
reported
to
the
Toxic
Release
Inventory
(TRI)
by
manufacturing
facilities
(SIC
codes
20­
39,
plus
other
specific
facilities),
that
have
10
or
more
full
time
employees,
and
manufacture/
process
25,000
lbs.
of
a
listed
chemical,
or
otherwise
use
10,000
pounds
of
a
listed
chemical
(40CFR
372.65).
An
amendment
to
lower
the
TRI
reporting
threshold
to
100
pounds
for
lead
and
lead
compounds
was
published
on
January
17,
2001
(66
FR
4499),
and
took
effect
on
February
16,
2001.
First
reports
at
the
lower
threshold
are
due
on
or
before
July
1,
2002.

Finally,
Section
103(
a)
of
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
(CERCLA)
requires
that
any
spills/
releases
of
tetraethyl
lead
in
quantities
exceeding
10
lbs.
must
be
reported
immediately
to
the
National
Response
Center
(40CFR302.4).

2.2.1.3
Regulations
Calling
for
Source
Identification
The
CAAA
also
contain
requirements
pertaining
to
the
identification
of
sources
of
alkyllead
Section
112(
c)(
6)
of
the
CAA
specifically
directs
EPA
to
include
source
categories
that
account
for
at
least
90
percent
of
the
emissions
of
alkyl­
lead
(among
other
pollutants)
on
its
lest
of
source
categories
for
development
of
emission
standards.
The
listing
of
sources
was
published
in
the
Federal
Register
in
April
1998.

2.2.1.4
Compliance
and
Enforcement
The
potential
for
illegal
misfueling
of
leaded
gasoline
cannot
be
entirely
eliminated
because
leaded
gasoline
is
still
produced
in
the
United
States
for
use
in
non­
road
vehicles
(primarily
as
general
aviation
fuel
and
in
race
cars)
and
is
dispensed
by
private
citizens.
Historically,
EPA's
Office
of
Enforcement
has
not
found
this
to
be
the
case
in
public
gasoline
service
stations.
In
previous
years,
EPA's
Office
of
Enforcement
screened
for
lead
during
routine
inspections
at
service
stations.
However,
as
leaded
gasoline
became
increasingly
scarce,
the
number
of
violations
related
to
the
misuse
of
leaded
gasoline
dropped
dramatically,
as
shown
in
Table
3
(USEPA,
1998d).
As
a
result
of
finding
virtually
no
cases
of
misfueling,
EPA's
Office
of
Enforcement
no
longer
routinely
screens
for
lead
as
part
of
the
typical
inspection
process.
EPA,
does,
however,
continue
to
test
for
lead
on
a
case­
by­
case
basis
if
illegal
misfueling
is
suspected.

Although
it
is
possible
for
misfueling
of
on­
road
automobiles
to
occur
using
leaded
racing
gasoline,
such
misfueling,
if
it
occurs
at
all,
is
likely
to
be
rare.
Limited
supply,
limited
distribution,
higher
costs,
incompatibility
with
emission
control
systems
on
production
automobiles,
and
limited
performance
benefits
in
production
automobiles
designed
for
unleaded
gasoline
all
weigh
against
use
of
leaded
racing
gasoline
in
on­
road
automobiles.
Alkyl­
lead
Action
Plan
June
2002
19
Table
3.
Violations
Issued
for
Excess
Lead­
Levels
in
Gasoline
[Source:
USEPA,
1998d]

Year
Number
of
Service
Station
Inspections
Number
of
Violations
Issued
Violation
Rate
1980
5,021
83
1.65%

1981
10,179
73
0.72%

1982
10,266
60
0.5%

1983
9,896
41
0.41%

1984
4,652
24
0.52%

1985
5,363
30
0.56%

1986
5,363
8
0.
15%

1987
9,003
4
0.
04%

2.2.1.5
International
Activities
The
United
States
is
committed
to
being
a
world
leader
in
promoting
the
phase­
out
of
leaded
gasoline
use
in
motor
vehicles.
Since
1994,
national
governments
have
committed
to
the
phase­
out
of
lead
in
gasoline
at
key
international
and
regional
agreements,
including
the
United
Nations
Commission
on
Sustainable
Development,
Summit
of
the
Americas,
Earth
Summit
+
5
and
the
G­
8
(an
informal
group
of
eight
developed
democracies
–
Canada,
France,
Germany,
Italy,
Japan,
Russia,
the
United
Kingdom,
and
the
United
States
–
with
interests
in
global
developments
on
a
range
of
broad
economic
and
foreign
policy
issues).
As
a
result
of
the
active
campaign
to
remove
lead
from
gasoline,
seven
countries
in
Latin
America,
one
country
in
Eastern
Europe
and
two
countries
in
Asia
have
totally
phased
out
the
use
of
lead
in
gasoline.
Efforts
by
the
United
States
have
resulted
in
lower
levels
of
lead
added
to
the
leaded
gasoline
in
one
country
in
Asia,
two
in
Latin
America,
and
one
in
Eastern
Europe
where
leaded
gasoline
is
still
sold.

The
impact
of
the
activities
undertaken
by
EPA
in
Latin
America
and
the
Caribbean
has
been
to
accelerate
the
formulation
and
implementation
of
lead
phase­
out
plans
throughout
the
region.
The
use
of
leaded
gasoline
is
declining
rapidly.
By
the
year
2002,
about
85
percent
of
the
gasoline
consumed
in
the
region
will
be
lead­
free.
According
to
World
Bank
figures,
the
amount
of
lead
added
to
gasoline
in
Latin
America
and
the
Caribbean
declined
from
27,000
metric
tons
in
1990
to
8,200
tons
in
1996.
It
is
estimated
that,
based
on
national
phase­
out,
the
lead
added
to
gasoline
in
1999
will
be
approximately
4,200
metric
tons.

Worldwide,
at
least
25
additional
countries
have
made
significant
commitments
to
phaseout
but
are
hampered
from
comprehensive
action
by
technical
complications.
Using
the
Implementer's
Guide
on
Phase­
out
of
Lead
in
Gasoline
that
EPA
and
the
U.
S.
Agency
for
International
Development
(USAID)
recently
completed,
associated
workshops
will
be
planned
and
conducted
to
target
the
25
countries
with
technical
difficulties.
EPA
will
continue
in
its
current
efforts
to
enhance
and
promote
the
phase­
out
of
leaded
gasoline
worldwide.
Alkyl­
lead
Action
Plan
June
2002
20
2.2.1.6
Activities
Related
to
Products
Alternative
Aviation
Fuel
Research.
Industry
is
currently
researching
an
alternative
to
alkyl­
lead
for
aviation
fuel.
An
industry
group,
the
Coordinating
Research
Council
(CRC)
has
formed
a
task
force
for
the
purpose
of
finding
a
no­
lead
gasoline
substitute
for
the
existing
aviation
fleet.
Working
cooperatively
with
the
CRC,
the
FAA
has
initiated
an
Unleaded
Fuels
Research
Program
to
complete
research
on
the
development
of
unleaded
aviation
gasoline
for
civil
aircraft.
Under
this
program,
engine
and
fuel
testing
(e.
g.,
engine
performance,
emissions,
fuel
consumption
changes,
etc.)
at
the
FAA's
small­
engine
and
fuel
test
facilities
began
in
1994.
Data
from
this
testing
will
aid
the
FAA
in
replacement
fuel
certification
for
100­
octane
low­
lead
gasoline,
as
well
as
developing
fuel
specifications
with
the
ASTM.
Considering
all
of
the
testing
that
must
be
conducted
(different
conditions,
different
engine/
airframe
combinations,
toxicity,
etc.),
as
well
as
the
approvals
from
FAA
and
the
acceptance
by
the
aviation
industry,
petroleum
companies,
and
gasoline
distributers
that
must
be
obtained,
it
is
not
possible
to
currently
estimate
a
time
frame
for
the
change
over
to
an
unleaded
high­
octane
aviation
gasoline.

Racing
Gasoline.
NASCAR
is
evaluating
and
testing
the
use
of
unleaded
racing
gasoline
in
the
Busch,
Winston
Cup
and
Craftsman
Truck
Series.
NASCAR
and
its
fuel
supplier
TOSCO
Corporation
(TOSCO)
are
recognized
leaders
in
the
auto
racing
industry,
and
any
changes
that
they
make
are
expected
to
have
a
significant
effect
throughout
the
industry.

2.3
RELATIONSHIP
TO
THE
CANADA­
U.
S.
GREAT
LAKES
BINATIONAL
TOXICS
STRATEGY
The
overall
goal
of
the
PBT
Strategy,
to
identify
and
reduce
risks
to
human
health
and
the
environment
from
current
and
future
exposure
to
PBTs,
builds
upon
the
objectives
and
goals
contained
in
The
Canada­
United
States
Strategy
for
the
Virtual
Elimination
of
Persistent
Toxic
Substances
in
the
Great
Lakes
Basin
(Binational
Toxics
Strategy),
which
was
established
in
1997.
For
alkyl­
lead,
the
Binational
Toxics
Strategy
identifies
the
following
national
challenge
goal:
"Confirm
by
1998,
that
there
is
no
longer
use
of
alkyl­
lead
in
automotive
gasoline.
Support
and
encourage
stakeholder
efforts
to
reduce
alkyl­
lead
releases
from
other
sources."

The
Binational
Toxics
Strategy
has
the
overall
goal
of
virtual
elimination
of
persistent
toxic
substances
in
the
Great
Lakes
Basin
and
in
the
case
of
alkyl­
lead,
throughout
the
United
States.
Significant
work
has
already
been
completed
by
EPA's
Great
Lakes
National
Program
Office
to
confirm
the
"no­
use
of
alkyl­
lead
in
automotive
gasoline."
(USEPA,
1999a)
Alkyl­
lead
Action
Plan
June
2002
21
2.4
OPPORTUNITIES
ASSESSMENT
2.4.1
Issues
Considered
in
the
Development
of
the
Strategic
Approach
2.4.1.1
Priority
Setting
As
outlined
in
Part
I,
EPA
has
considered
the
proposed
actions
for
alkyl­
lead
within
the
larger
context
of
actions
and
resources
necessary
to
reduce
risk
for
all
twelve
Level
1
substances
currently
being
addressed
under
the
PBT
Strategy.
The
specific
actions
within
the
Alkyl­
lead
National
Action
Plan
were
prioritized
based
on
several
key
factors
such
as
the
likelihood
of
health
risks,
amount
of
resources
required,
the
availability
and
willingness
of
non­
agency
partners
and
stakeholders,
and
the
anticipated
impact
on
the
amount
of
alkyl­
lead
released
into
the
environment.
These
key
factors
need
to
be
examined
simultaneously
to
determine
the
appropriate
prioritization.
For
example,
at
the
current
time,
data
seem
to
indicate
that
the
amount
of
leaded
aviation
gasoline
is
significantly
higher
than
the
amount
of
leaded
gasoline
used
by
the
automotive
racing
industry.
However,
technical
considerations
may
limit
the
amount
of
progress
that
can
be
made
toward
an
alternative
aviation
fuel.
On
the
other
hand,
there
are
fewer
technical
limitations
associated
with
racing
fuel
and
representatives
from
the
automotive
racing
industry
have
expressed
a
willingness
to
work
with
EPA
to
develop
alternatives.
Priority
Actions
were
presented
in
Part
I
of
this
Action
Plan.

2.4.1.2
Data
Gaps
EPA
estimated
national
emissions
for
alkyl­
lead
for
1990
in
conjunction
with
its
analysis
under
section
112
(c)(
6)
of
the
CAA.
However,
sufficient
data
were
not
available
to
develop
emissions
estimates
for
operations
of
aircraft,
operations
of
non­
road
vehicles,
or
alkyl­
lead
production.

Additionally,
other
than
aviation
gasoline,
very
little
data
exist
on
current
levels
of
leaded
gasoline
use.
Since
1991,
the
Department
of
Energy
(DOE)
stopped
tracking
information
on
the
production
of
leaded
gasoline
for
non­
aviation
uses.
Consequently,
there
is
no
readily
accessible
information
on
how
much
leaded
gasoline
is
being
produced
for
the
continued,
legal
use
of
alkyllead
in
racing
cars.
However,
it
may
be
possible
to
derive
upper
bound
estimates
for
these
uses
from
other
available
information
and
from
industry
representatives.

Finally,
there
is
insufficient
information
to
assess
whether
the
remaining
uses
of
leaded
gasoline
result
in
adverse
environmental
or
health
effects.
Most
notably,
there
is
no
information
to
determine
whether
there
is
increased
risk
of
lead
exposure
to
at­
risk
populations
(especially
children)
living
in
the
vicinity
of
race
tracks
or
general
aviation
airports,
spectators
at
racing
events
or
air
shows,
and
fuel
handlers
(aviation
or
racing
crews).

Bridging
these
data
gaps
is
discussed
below
in
section
2.4.3.2
Proposed
Research
/
Information
Needs.
Alkyl­
lead
Action
Plan
June
2002
22
2.4.1.3
Regulatory
Constraints
EPA
does
not
have
the
authority
to
regulate
aviation
fuel
(e.
g.,
the
constituents
of
the
fuel).
This
authority
lies
with
the
FAA.
EPA
also
does
not
have
the
authority
under
the
CAA
to
regulate
the
use
of
unleaded
gasoline
for
the
racing
industry.
There
is
a
provision
in
the
CAA
that
prohibits
EPA
from
regulating
engines
(or
their
fuels)
that
are
designed
solely
for
competition,
but
the
regulation
of
fuel
could
potentially
occur
under
the
TSCA
Section
6
Rule.

2.4.1.4
Stakeholder
Issues/
Concerns
There
are
a
large
number
of
experimental
aircraft
with
lower
performance
piston
engines
that
use
unleaded
gasoline,
as
well
as
various
alternative
fuels
that
have
been
researched.
However,
the
identification
of
alternatives
for
leaded
aviation
gasoline
will
present
a
technical
challenge,
as
some
alternative
additives
(e.
g.,
methyl
tert­
butyl
ether
(MTBE)
and
toluene)
may
have
adverse
environmental
and
human
health
effects
as
well.
These
alternatives
include
those
containing
alcohols
(e.
g.,
ethanol),
aromatics
(e.
g.,
toluene),
and
ethers
(e.
g.,
MTBE
and
ETBE).
A
manganese­
based
additive,
MMT
(methyl­
cyclopentadienyl
manganese
tricarbonyl),
has
also
been
used
in
gasoline
blends
as
an
octane
booster,
although
research
indicates
that
it
will
probably
not
find
widespread
usage
due
to
potential
deposit­
control
problems.
For
many
years
MTBE
has
been
used
as
a
blending
agent
in
gasoline
to
raise
the
octane
number,
eliminate
corrosive
action,
and
serve
as
an
oxygenate.
In
fact,
reformulated
gasoline
containing
an
oxygenate
(such
as
MTBE)
is
required
to
be
sold
in
many
states
to
reduce
air
pollution
(smog)
levels.
Recently,
however,
due
to
evidence
that
MTBE
is
polluting
groundwater
supplies,
an
independent
Blue
Ribbon
panel
has
recommended
to
EPA
that
oil
companies
should
not
be
required
to
sell
MTBE­
blended
gas,
and
that
use
of
MTBE
be
sharply
reduced
(USEPA,
1999b).

While
an
alternative
fuel
for
aircraft
is
desirable,
care
must
be
taken
to
balance
this
with
safety
concerns.
Aircraft
are
certified
for
very
specific
fuels.
The
performance
of
an
alternative
unleaded
high­
octane
aviation
gasoline
under
all
possible
operational
and
environmental
conditions
must
be
thoroughly
tested
because
of
concerns
regarding
aircraft
safety.
High­
performance
piston
aircraft
engines
require
high­
octane
gasoline,
and
alkylated
lead
compounds
are
extremely
efficient
at
raising
the
octane
without
causing
any
other
undue
performance
effects.
To
re­
certify
aircraft
for
a
different
fuel
is
time­
consuming
and
expensive.
To
date,
EPA
has
not
focused
on
fuel
alternatives
due
to
the
financial
hardships
it
would
impose
on
the
small
aircraft
industry.

Although
there
are
a
large
number
of
experimental
aircraft
that
use
unleaded
gasoline
for
lower
performance
piston
engines,
there
appears
to
be
no
ready
substitute
for
the
100­
octane
low­
lead
gasoline
used
by
high
performance
piston
engines.
However,
one
new
fuel
specification
has
been
approved
by
ASTM.
This
new
fuel,
which
will
be
known
as
82UL,
is
an
unleaded
aviation
grade
fuel
that
can
be
used
only
by
the
low
compression
ratio
segment
of
the
reciprocating­
engine­
aircraft
fleet.
The
initial
production
and
supply
of
this
new
fuel
is
currently
being
studied
by
fuel
suppliers.
As
a
move
forward
in
promoting
82UL,
the
FAA
has
extended
approval
for
use
of
this
fuel
by
aircraft
previously
approved
to
use
auto
fuel
under
Supplemental
Type
Certificates
(STC).
In
addition,
the
FAA
has
recently
certified
another
new
unleaded
fuel,
Alkyl­
lead
Action
Plan
June
2002
23
AGE85,
developed
by
the
National
Alternate
Fuels
Laboratory
(NAFL)
at
the
University
of
North
Dakota
Energy
and
Environmental
Research
Center
(EERC).
With
the
initial
certification
completed,
the
developers
of
the
fuel
are
moving
forward
to
obtaining
FAA
certification
for
more
engine
and
airframe
combinations
(EERC,
1999).

2.4.2
Strategic
Assessment
–
The
Priorities
for
Action
The
Agency
recognizes
that
tremendous
progress
has
been
made
in
reducing
lead
emissions
related
to
the
use
of
alkyl­
lead.
Total
lead
emissions
have
been
reduced
from
220,869
short
tons
in
1970
to
3,869
short
tons
in
1996,
totaling
a
reduction
in
emissions
of
approximately
98
percent
(USEPA,
1997b).
This
large
reduction
is
primarily
due
to
the
regulated
phase­
out
of
leaded
gasoline
in
on­
road
vehicles.
Based
on
considerations
of
all
opportunities,
and
taking
into
account
the
issues
discussed
in
section
2.4.1,
the
Agency
has
identified
one
key
priority
for
action
for
alkyl­
lead
over
the
next
five
years.
It
will
work
in
voluntary
partnership
with
the
National
Association
for
Stock
Car
Automobile
Racing
(NASCAR)
to
permanently
remove
alkyl­
lead
from
their
racing
fuels,
specifically,
in
the
Busch,
Winston
Cup
and
Craftsman
Truck
Series.

In
addition,
EPA
will
continue
other
activities
that
will
help
to
meet
the
goals
of
this
action
plan.
In
particular,
EPA
will
continue
its
commitment
to
international
efforts
to
reduce
the
use
of
leaded
gasoline,
including
those
being
conducted
under
the
United
Nations
Commission
on
Sustainable
Development,
Summit
of
the
Americas,
Earth
Summit
+
5,
the
G­
8,
and
the
Great
Lakes
Binational
Toxics
Strategy.
On
a
global
basis,
lead
in
gasoline
has
been
estimated
to
contribute
95
percent
of
the
lead
air
pollution
found
in
the
world's
major
cities.
Goal
6
of
EPA's
Ten
Year
Strategic
Plan
GPRA
Goals
calls
for
the
reduction
in
worldwide
levels
of
lead
in
gasoline.
EPA
will
also
continue
dialogues
with
the
Federal
Aviation
Administration
(FAA)
to
discuss
the
use
of
leaded
gasoline
in
the
aviation
industry
and
the
possibilities
of
reducing
the
lead
content
and/
or
replacing
leaded
gasoline
with
unleaded
gasoline.
EPA
will
continue
to
support
and
encourage
such
research
activities
as
that
undertaken
by
the
Coordinating
Research
Council
(CRC)
task
force
investigating
alternative
(no­
lead)
gasoline
for
aircraft.

2.4.3
Other
Actions
Considered
As
discussed
in
section
2.4.1.1,
proposed
actions
for
alkyl­
lead
were
evaluated
in
the
larger
context
of
proposed
actions
for
all
Level
1
substances
and
in
the
context
of
available
resources.
Following
are
actions
that
were
considered
to
have
merit
but
which
could
not
be
implemented
or
planned
at
this
point
in
time
in
light
of
other
higher
priorities.

2.4.3.1
Proposed
Outreach
and
Education
EPA,
along
with
others,
has
conducted
an
extensive
outreach/
education
campaign
to
make
the
general
public
aware
of
the
dangers
of
lead.
However,
these
efforts
have
primarily
focused
on
inorganic
forms
of
lead
such
as
those
found
in
lead­
based
paint.
While
EPA
continues
its
efforts
to
inform
the
general
public
on
the
dangers
of
inorganic
lead,
EPA
Alkyl­
lead
Action
Plan
June
2002
24
considered
investigating
new
possibilities
for
expanding
the
outreach/
education
campaign
to
include
targeted
audiences.
For
example,
outreach/
education
campaigns
on
the
dangers
of
alkyllead
(especially
the
hazards
of
dermal
exposure)
could
be
targeted
to
persons
that
routinely
fuel
vehicles
with
leaded
gasoline.

2.4.3.2
Proposed
Research/
Information
Needs
Research
on
several
issues
was
considered
to
address
the
data
gaps
identified
above
and
as
the
initial
step
in
promoting
the
voluntary
phase­
out
of
leaded
gasoline.
In
particular,
the
following
research
activities
and
information
collection
efforts
were
discussed:

#
Develop
Current
Emission
Estimates:
The
last
air
emissions
inventory
specific
to
alkyl­
lead
represented
the
year
1990.
Since
then,
the
overall
use
of
leaded
gasoline
may
have
been
further
reduced.
Further,
estimates
could
be
made
for
competitive
use
vehicles
(such
as
those
used
by
NASCAR).
EPA
considered
developing
rough
estimates
of
the
potential
emissions
from
race
cars
through
modeling
of
emissions,
monitoring
during
races,
soil
sampling
in
the
vicinity
of
race
tracks,
or
other
means
as
appropriate.

#
Investigate
Exposure
to
At­
Risk
Populations:
As
discussed
above,
gasoline
containing
alkyl­
lead
compounds
is
still
being
used
today
and
as
such
there
remains
the
potential
for
exposure
to
certain
populations.
EPA
considered
research
activities
to
evaluate
the
risk
for
these
subpopulations,
including
research
to
assess
whether
exposure
in
the
vicinity
of
general
aviation
airports
or
race
tracks
contributes
to
elevated
blood­
lead
levels
in
at­
risk
populations
(i.
e.,
nearby
residents
(especially
children)
and
spectators
of
racing
events).

#
Update
Inventory
of
Leaded
Gasoline
Production
and
Use:
As
stated
above,
the
Department
of
Energy
(DOE)
stopped
tracking
information
on
the
production
of
leaded
gasoline
for
non­
aviation
uses.
Information
on
the
extent
to
which
leaded
gasoline
is
currently
used
could
be
developed
through
published
statistics,
discussions
with
petroleum
manufacturers,
and
discussions
with
end­
users.

#
Determine
the
Availability
of
Leaded
Gasoline
and
Potential
for
Misfueling:
The
extent
to
which
racing
gasoline
containing
lead
is
available
for
purchase
at
the
roadside
could
be
estimated.
Although
EPA's
Office
of
Enforcement
no
longer
routinely
screens
for
lead
during
routine
inspections
at
service
stations,
information
on
the
extent
to
which
misfueling
occurs
could
be
consolidated
and
estimates
of
the
extent
of
misfueling
developed.

#
Determine
the
Extent
to
Which
Leaded
Gasoline
Is
Available
for
Purchase
at
Marine
Fuel
Docks:
It
is
unknown
whether
leaded
gasoline
is
still
being
widely
used
as
a
marine
fuel.
However,
fuel
is
known
to
overflow
from
fuel
tanks
frequently
during
operations
into
waterways,
lakes,
etc.
While
the
quantities
may
be
small,
the
number
of
such
sites
may
be
much
larger
than
for
race
tracks.
Alkyl­
lead
Action
Plan
June
2002
25
2.5
MEASURING
PROGRESS
As
stated
in
the
PBT
Strategy,
EPA
will
use
the
following
measures
to
track
progress
in
reducing
risks
from
alkyl­
lead:
(1)
environmental
or
human
health
indicators,
(2)
chemical
release,
waste
generation,
or
use
indicators,
or
(3)
programmatic
output
measures.

In
addition
to
the
goals
and
programmatic
measures
given
in
Table
4
below,
EPA
will
measure
progress
towards
the
virtual
elimination
of
alkyl­
lead
production
and
use
throughout
the
United
States
by
comparison
to
the
following
quantifiable
baseline
measures:

#
The
amount
of
leaded
aviation
gasoline
produced:
In
1996,
U.
S.
refineries
produced
305,000,000
gallons
of
aviation
gasoline
(USDOE,
1998).

#
The
amount
of
leaded
gasoline
used
by
the
racing
industry:
In
1998,
approximately
100,000
gallons
of
leaded
gasoline
were
used
by
NASCAR
(National
Motor
Sports
Council,
1999).

#
The
amount
of
anti­
knock
preparations
imported
into
the
US:
In
1998,
the
United
States
imported
approximately
14,318,800
pounds
of
anti­
knock
preparations
based
on
TEL
and/
or
TML
and
1,316,800
pounds
of
anti­
knock
preparations
based
on
lead
compounds
(U.
S.
Department
of
Commerce,
1998).
(These
compounds
are
used
to
make
leaded
fuel
for
aviation,
racing
fuel,
marine
vessels,
etc.)
Assuming
anti­
knock
agents
containing
TEL
typically
contain
62
percent
TEL,
a
rough
estimate
for
the
amount
of
TEL
imported
into
the
U.
S.
in
1998
would
be
about
9.7
million
pounds
of
TEL.
However,
according
to
Ethyl
Corporation
(1999),
only
approximately
2,866,000
pounds
of
anti­
knock
fluid
were
consumed
in
the
U.
S.
in
1998,
equating
to
approximately
1,129,000
pounds
of
alkyl­
lead.
Approximately
331,000
pounds
of
this
anti­
knock
fluid
was
used
to
serve
the
NASCAR
industry.

#
The
lead
content
in
aviation
gasoline:
Currently,
aviation
gasoline
has
a
maximum
lead
TEL
standard
of
0.13
mL
TEL/
L
for
Grade
80,
0.53
mL
TEL/
L
for
Grade
100LL,
and
1.06
mL
TEL/
L
for
Grade
100.
The
maximum
lead
standard
is
0.14
g
Pb/
L
for
Grade
80,
0.56
g
Pb/
L
for
Grade
100LL,
and
1.12
g
Pb/
L
for
Grade
100
(ASTM,
1997).

#
The
number
of
petroleum
refining
facilities
submitting
lead
or
lead
compound
reports
to
TRI:
In
1995,
29
petroleum
refining
facilities
(SIC
2911)
submitted
forms
to
TRI
(USEPA,
1998b).
This
number
may
have
an
increase
from
1995
levels
with
the
proposed
threshold
reductions.
Alkyl­
lead
Action
Plan
June
2002
26
Table
4.
Measures
of
Progress
for
Actions
to
Reduce
Risks
from
Alkyl­
lead
Focus
Action
Measure
of
Progress
Voluntary
phase­
out
of
leaded
gasoline
use
by
NASCAR
#
Encourage
a
NASCAR
voluntary
phase­
out
partnership/
program
#
NASCAR
Agreement;
lead­
free
Busch,
Winston
Cup
and
Craftsman
Truck
Series
#
Reductions
in
lead
exposure
and
bloodlead
levels
among
at­
risk
populations
Dialogues
with
the
FAA
and
CRC
#
Continue
work
with
the
Federal
Aviation
Administration
(FAA)
and
Coordinating
Research
Council
(CRC)
to
promote
alternative,
unleaded
fuels
and
the
phase­
out
of
leaded
aviation
gasoline
#
FAA
Agreements
or
voluntary
partnerships/
programs
#
Reductions
in
lead
exposure
and
bloodlead
levels
among
at­
risk
populations
International
efforts
#
Continue
to
support
international
efforts
to
reduce
the
use
of
leaded
gasoline
#
Number
of
countries
that
have
initiated/
reached
a
phase­
out
of
leaded
gasoline;
amount
of
leaded
gasoline
used
worldwide
Alkyl­
lead
Action
Plan
June
2002
27
REFERENCES
ASTM
(1997),
"Standard
Specification
for
Aviation
Gasolines,"
Annual
Book
of
ASTM
Standards,
Designation
D910­
97.
American
Society
for
Testing
and
Materials.

CDC
(2000),
"Blood
Lead
Levels
in
Young
Children
–
United
States
and
Selected
States,
1996
1999
Centers
for
Disease
Controls
and
Prevention,
Morbidity
and
Mortality
Weekly
Report,
December
22,
2000.
49(
50):
1133­
7.

CDC
(1997),
"Update:
Blood
Lead
Levels
–
United
States,
1991­
1994
,"
Centers
for
Disease
Controls
and
Prevention,
Morbidity
and
Mortality
Weekly
Report,
February
21,
1997.
46(
07):
141­
146.

CDC
(1994),
"Blood
Lead
Levels
–
United
States,
1988­
1991,"
Centers
for
Disease
Controls
and
Prevention,
Morbidity
and
Mortality
Weekly
Report,
August
5,
1994.
43(
30):
545­
548.

EERC
(1999),
North
Dakota
Energy
and
Environmental
Research
Center,
"FAA
Certifies
Low­
Cost,
Environmentally
Friendly,
Ethanol­
Based
Aviation
Fuel."
Press
Release,
www.
eerc.
und.
nodak.
edu.

Ethyl
Corporation
(1999),
Comments
on
Draft
National
Action
Plan
for
Alkyl­
Lead.

Mahaffey,
K.
R.,
Annest,
J.
L.,
Roberts,
J.,
and
R.
S.
Murphy
(1982),
"National
estimates
of
blood
lead
levels:
Unites
States,
1976­
1980,"
N.
Engl.
J.
Med.
307:
573­
9.

National
Motor
Sports
Council
(1999),
Personal
communication.

Purvis
Brothers,
Inc.
March
6,
1999,
Fuel
Technology
Series
(http://
nauticom.
net/
users/
macpjr/
av3.
htm
Accessed:
8­
19­
99).

U.
S.
Bureau
of
the
Census
(1998),
Imports/
exports
History
Database,
1993­
97
Summary.
(http://
govinfo.
kerr.
orst.
edu/
import/
import.
html)

U.
S.
Department
of
Commerce
(1998),
International
Trade
Association.
(http://
www.
ita.
doc.
gov/
industry/
otea/
Trade­
Detail/
Latest­
December/
Exports/
38/
381111.
html
Accessed:
8­
10­
99)

U.
S.
Department
of
Energy.
December
1991,
Petroleum
Marketing
Annual,
1990.
Energy
Information
Administration,
Washington,
DC.
DOE/
EIA­
0487(
90).

U.
S.
Department
of
Energy
(1998),
Petroleum
Supply
Annual,
1998,
Volume
1.
Energy
Information
Administration,
Washington,
DC.
Alkyl­
lead
Action
Plan
June
2002
28
USDHHS
(1999),
"Toxicological
Profile
for
Lead,"
U.
S.
Department
of
Health
and
Human
Services,
Public
Health
Service,
Agency
for
Toxic
Substances
and
Disease
Registry,
July
1999.

USEPA,
Unpublished
data
(1991),
Amount
of
leaded
and
unleaded
gasoline
produced
in
the
United
States,
1967­
1991.

USEPA
(1993),
Estimation
of
Alkyl­
lead
Emissions.
Final
Report.
Prepared
by
TRC
Environmental
Corporation.

USEPA,
EC
(1997a),
"The
Great
Lakes
Binational
Toxics
Strategy:
Canada­
United
States
Strategy
for
the
Virtual
Elimination
of
Persistent
Toxic
Substances
in
the
Great
Lakes,"
April
7,
1997.

USEPA
(1997b),
"National
Air
Pollutant
Emission
Trends
Report,
1900­
1996,"
Office
of
Air
Quality
Planning
and
Standards,
EPA­
454/
R­
97­
011,
December
1997.

USEPA
(1998a),
1990
Emissions
Inventory
of
Section
112(
c)(
6)
Pollutants.

USEPA
(1998b),
1996
Toxics
Release
Inventory
Database.

USEPA
(1998c),
"National
Air
Quality
and
Emissions
Trends
Report,
1996,"
Office
of
Air
Quality
Planning
and
Standards,
U.
S.
Environmental
Protection
Agency,
EPA­
454­
R/
97­
013,
January
1998.

USEPA
(1998d),
Personal
communication
with
George
Lawrence,
USEPA,
Office
of
Enforcement,
1998.

USEPA
(1999a),
"U.
S.
Challenge
on
Alkyl­
Lead:
Report
on
Use
of
Alkyl­
Lead
in
Automotive
Gasoline,"
Draft
Report,
www.
epa.
gov/
glnpo/
bns.

USEPA
(1999b),
Press
Release
on
July
27,
1999,
Statement
by
Carol
M.
Browner,
U.
S.
Environmental
Protection
Agency
Administrator,
on
Findings
by
EPA's
Blue
Ribbon
MTBE
Panel.
Alkyl­
lead
Action
Plan
June
2002
A­
1
APPENDIX
A:

LIST
OF
KEY
CONTACTS
AND
GPRA
GOALS
Alkyl­
lead
Action
Plan
June
2002
A­
2
LIST
OF
KEY
CONTACTS
Name
Organization
Phone
EPA
STAFF
Jim
Caldwell
US
EPA,
OTAQ,
Fuels
and
Energy
Division
(202)
564­
9303
Sylvia
Correa
US
EPA,
OIA,
Office
of
Technology
Cooperation
and
Assistance
(202)
564­
6443
Laurel
Driver
US
EPA,
OAQPS,
Emissions
Factors
and
Inventory
Group
(919)
541­
2859
Tony
Kizlauskas
US
EPA,
GLNPO
(312)
353­
8773
George
Lawrence
USEPA,
OECA
(202)
564­
1307
Paul
Matthai
USEPA,
OPPT
(202)
564­
8839
Erv
Pickell
USEPA,
OECA
(202)
969­
6476
STAKEHOLDER
AND
OTHERS
Bill
Bader,
Sr.
International
Hot
Rod
Association
(419)
663­
6666
Duane
Bordrick
Tosco
Corporation
(925)
370­
3660
Jerry
Cook
NASCAR
(904)
947­
6724
Nicholas
W.
Craw
Sports
Car
Club
of
America
(303)
694­
7222
Arnold
D'Ambrosa
U.
S.
Offshore
Racing
Association
(732)
892­
3000
Paul
Dodson
International
Marina
Institute
(941)
480­
1212
James
Erickson
Federal
Aviation
Administration
(202)
267­
3576
Dallas
Gardner
National
Hot
Rod
Association
(626)
914­
4761
Bill
Joiner
Tosco
Corporation
(76
Racing
Division)
(847)
310­
6840
Edward
Klim
International
Snowmobile
Manufacturers
Association
(517)
339­
7788
Ken
Knopp
Federal
Aviation
Administration
(609)
485­
5693
Earl
Lawrence
Experimental
Aircraft
Association
(800)
236­
4800
William
D.
Mitchelson
National
Boating
Federation
(414)
352­
0967
Robert
Rasor
American
Motorcyclist
Association
(614)
856­
1900
Jerry
Roper
Ethyl
Corporation
(804)
788­
6023
Mark
Rumizen
Federal
Aviation
Administration
(781)
238­
7113
Bill
Savage
SCORE
International
(760)
599­
1013
William
Schultz
General
Aviation
Manufacturers
Association
(202)
393­
1500
Gloria
Urbin
American
Power
Boat
Association
(810)
773­
9700
Joseph
Valentine
Texaco
Additives
International
Research
and
Development
(914)
838­
7718
Ron
Wilkinson
CRC
(334)
227­
8306
Alkyl­
lead
Action
Plan
June
2002
A­
3
GPRA
GOALS
The
goal
of
this
action
plan
is
to
identify
and
reduce
risks
to
human
health
and
the
environment
from
current
and
future
exposure
to
alkyl­
lead.
This
goal
is
consistent
with
the
goal
of
the
PBT
Strategy.
Achieving
this
goal
will
help
EPA
meet
the
following
Government
Performance
and
Results
Act
of
1993
(GPRA)
goals
that
pertain
to
alkyl­
lead:

GPRA
Goal
1:
Clean
Air
#
By
2010,
reduce
air
toxics
emissions
by
75%
from
1993
levels
to
significantly
reduce
the
risk
to
Americans
of
cancer
and
other
serious
health
effects
caused
by
airborne
toxics;

#
By
2005,
improve
air
quality
for
Americans
living
in
areas
that
do
not
meet
NAAQS
for
carbon
monoxide,
sulfur
dioxide,
lead,
and
nitrogen
dioxide;

GPRA
Goal
4:
Preventing
Pollution
and
Reducing
Risk
in
Communities,
Homes,
Workplaces,
and
Ecosystems
#
By
2005,
the
number
of
young
children
with
high
levels
of
lead
in
their
blood
will
be
significantly
reduced
from
numbers
in
the
early
1990's;

GPRA
Goal
6:
Reduction
of
Global
and
Cross­
Border
Environmental
Risks
#
By
2005,
consistent
with
international
obligations,
the
need
for
upward
harmonization
of
regulatory
systems,
and
expansion
of
toxics
release
reporting,
reduce
the
risks
to
U.
S.
human
health
and
ecosystems
from
selected
toxics
(including
pesticides)
that
circulate
in
the
environment
at
global
and
regional
scales.
Results
will
include
a
50%
reduction
of
mercury
from
1990
levels
in
the
United
States.
Worldwide
levels
of
lead
in
gasoline
will
be
below
1993
levels;

GPRA
Goal
8:
Sound
Science,
Improved
Understanding
of
Environmental
Risk,
and
Greater
Innovation
to
Address
Environmental
Problems
#
Incorporate
innovative
approaches
to
environmental
management
into
EPA
programs,
so
that
EPA
and
external
partners
achieve
greater
and
more
cost­
effective
public
health
and
environmental
protection.
