Document 5kgjv9RNq3Zez4v5J0Grz2YyD

y. i-ss/. "s-* - * -- . TT7T. yy - '4523 Lead Industries Association, Inc. O I*t Meson Awnue Mew Ye*. N. Y. 10017 Te*ee#*one: pit) tTHOH August 9, 1971 euBjrcTi BULLKTH *0. lV - LEAD H OASOLDCt & TO: ALL MEKBZ88 CT LEAD UWJBTRXIS ASSOCIATE* !; Gentlemeni While pressure baa continued oa lead la the environment, not too neb baa transpired la th vsy of specific developments. Attached, hereto, la a copy of a apeecb I Bad# before the Idaho Mining Association oa July 31, 1971, which la intended to update and eisaaarlae the aituation aa It atanda today . Further, and of major latereat la aa extract fro* a lev lork Tlaea, page 66, article of Thursday, August 5, 1971, by-llned Xr. Jerry K. Flint, Detroit Bureau Chief of the lev Tort Tlaea which baa the following to aay concerning Ford1 a Nark IT Continental and all 1972 nodal ear* In general - "Ford would not announce the horsepower figures on the nev model (Mark 17 Continental) vhich uaea the ease L60-cubic-inch displacement engine aa the 1971, but performance, top speed, acceleration and gasoline economy have probably worsened with the added weight and engine modifications needed to reduce enlaalone. F00X FEHFCffiHAJd "He mission Modifications are leadii^ to the poorest englna ft si Srt performance In years on Detroit's cars. The engines sputter; diesel, or keep running after they are turned off; are harder to start; usa *ore fuel, and lack the acceleration of past models". The loss of quality la now seemingly confirmed end la What ve hare predicted for veil over a year. er.i V continue glad to bare your questions or comments. JIK/gt be. Sincerely, </> / / J.L. Kimberley Kxscutlre Vice President V t LIA14524 Mek HXARES TO 153 IDAHO KDflHO ASSOCIATI08 MEETIH SATURDAT, JULT 31, OCCUS d'AUHX, 10*90 J.L. Kimberley, Executive Vie* President Lead Industrie# Association gUBJKCTi HAD POIXUTIC* - FACT AXD flCTIO* Kr. Chairman, Ladle* and Oentlieni It 1* a privilege and pleasure to apeak with you today oa thi* subject of vital Importance to u* all - Idaho being the second largest producer of lead la the country. Idaho with Utah end Colorado mine more than 20 of the U.8. total new lead. Perhaps the assigned subject of these remarks "Lead dilution - Fact and Fiction" is a bit too broad. I vlll be talklr^ primarily about lead la gasoline vhich now requires about 20^ of all lead consumed la the U.S., taking 277,000 tons la 1970. lhls Is about 70 of new lead. The market Is unique because little secondary lead la used and non* come* back to the Industry as scrip. The overall subject of lead In gasoline la extremely complex la a technical sense end today Involves much more la emotion approaching hysteria, and Z think politics, than Logic. Oertaialy no complete review of the technical aspect* Is possible. Z hop* to be brief eaoar that there vlll be time for questions. I should Uk* to reriev some of the circumstance* surrounding general attitude* oa lead In the environment, emphasising certain aspect* to shew the areas In which v* continue strong, some of th* negative feature* and to expre*i an opinion as to what we - must do and where our future hopes 11*. Today ws are subject to massive propaganda from the Government, from sem* scientists and from enrlrormwital group*. This no doubt has had large Influence oa th* public's attitude. << Without question there are negative influence* but we have not seen specific N 3441.01 ---------------- ------------------- --------- ' - 8'------- ' ' " ~ ....... -- data to Justify the threat of doom which so many of the environmentalists put forward. It ii not iu j - to iigr "no" concerning atmospheric pollution. Om of the ooralMt but ptt phrou tint we can ui la tht old o m "you can't b against motherhood*. V can't *ay ara for pollution. But the subject ha* been treated by some in Government and by environmental group* In each fashion that r*n with allowance for their "why*", "maybe*", and "perhaps**", the altuatlon reaalna difficult. California, particularly the Ice Angela* area, 1* geographically uniqua. Jhcy hare a smog problem. Aa a remit, California haa been acting on atmospheric pollution ilnce the early 1950'* and haa been a leader. They hare don* neny thing* of vdilch X will epeal bit later, but actually not such haa been accomplished a* concern* care, though California,with a Vaahington waiver, yet ney be the flret itate to go into action agalnat the uae of lead in gaaoline. the Clean Air Amendment* of 1970 preempt political sub- dirlaiooa (California excepted) frca action. nevertheless, Buffalo ha* an ordinance, X.T.C. haa astlgned a 14 tax on leaded gasoline and has a 197% phaseout scheduled, Maryland has passed another schedule calling for phaseout. Though the federal Government baa passed the Clean Air Amendment* of 1970 it has not yet said specifically bow these will affect lead and has not been made public. Existing state and city actions My be overridden. The position of the 0.8. has been developed along the line that carbon monoxide, unburned hydrocarbons and nitrogen oxide are the major polluters from automobiles and that these cannot be well controlled if lead is used. That the lead Itself presents e threat Is to date sore the cry of the environmentalists than that of the Government. Foreign attitudes are scmewhat different. In Germany and in Japan only the lead has been under attack. In other parts of the world where the environment he* beoome an issue, Sweden and to a lesser extent other countries in Western Europe, only the lead has been discussed substantially. The pot is stirring In England and Australia but no specific actions have been taken or threatened for the predictable future. f I* I -3- While It Is tru that the envtromentsl groups of the D.B. end to * lesser extent the congresses here spoken against lend - the official position ef this Government Inspiring the positions of the automobile end refining Industries has been against the gaseous emissions, with leed of secondsry interest, further, on this point the eoto~ mobile Industry bss ssld end persists thst they cannot oontrol the gsseous emlsslom l If leed 1s in the gas because it fouls those catelytle reactor system which they ( beliere bold the (reateet promise for the oontrol of gaseous missions. i I I beliere this 1s enough of an Introduction. I should like sow to rerlee bcme I of the specific factors pro and con which bear on the problem. let me start with a b I brief review of those factors which we belive favor the retention of leed - 1. Atmospheric lead is not now a general threat - arerage city larals rma In below h nlerograas per cubic mter. * b 2. In spite of apparent Increasing levels of atmospheric lead in large cities, I there is not any sound demonstration that this has been paralleled with blood lead increases in the population. I hare two slides to illustrate this point, they are A.'- w>- extracted froa a year's study ending December, 1969 corering los Angeles, Jhlladelphla, F 4 Cincinnati, Washington, lew fork, Houston and Chicago, the lead contents are avenge for a year. The blood readies. Involving a larger number of people than any other I I study previously conducted, are taken substantially from women living in the specific areas. It is of extreme Importance that 209 people in Pasadena had lower blood leads than 137 women in Rittenbouse Square, Rxilndelphin, though the Rlttenhouse'Square I area people were exposed to only 1/2 of the atmospheric lead. This fact has been difficult for extremists to get around. 3. In Urban areas of presently high lead levels there is Much reason to expect that the atmospheric lead will not further increase because traffic densities hare t1 '*y. s t ft1000 LEAD LEVELS AS A FUNCTION OF AIR Ifltf LEYEU nuber of poopl* LEAP IN ILOOP, a t/IO O t 1----------------------------1-------------------------- 1---------------------------- 1-------------------------------------------- -- 1.0 2.0 3.0 4.0 LTJ.t IN AIR. i:p/r3 . ^^fe^^i'ifiiaaiir^ peeked or ere Yi7 do*# to peeking, l. The ch*p cetsdytlc converter system envisioned by the automobile induetry ee the beet approach to a eolation end very reliably eetlaated at a coat of $60.00 per car in early 1970 baa not eatertallied. Almost weekly the estimates of control system* ooeta goes op. m May of 1971 it va* ae high aa $500 - scats authorities in the autonobil* Indue try estimate even higher. 9. Alto Mission oontrol ayetaae, ae by DuRant and Ethyl - Involving thermal reactora for carbon monoxide and hydrocarbon!, recirculation to control nitrogen aside and trapping for particulatea including lead area clearly to be more advanced toward control than any others of which Z have knowledge, there are DuPont and Ethyl equipped care under teet in California. Twelve '70 or '71 Chevrolet'a - by DuPont - ill with full control systems and alx unequipped are being cohered under trying condition! by the California Air Seeourcea Board. They are doing better then original '75 atandarda and are approaching the objective* aet for 1980. Bote: Coe of the complexities of the situation which contribute! substantially to confusion, uncertainty and lack of progress la tbs frequent changing of atandarda and teat methods by the federal Government. Aa I bars already said, the DuPont cars are doing better than any other system equipped can of which vs know, but they are not good enough to meet the latest standards aa established by the Clean Air Amendments of 1970. More confusion! 6. The automobile industry of the world is unanimously opposed to the Clean Air Amendments of '70 and the restrictions which it Imposes namely, 9o reduction of 00 and HC'i by 1975 and 90 reduction of BOg by 1976, all related to emissions of 1970 models. At hearings in Washington held by the Environmental Protection Agency la early May - the automobile industry said in affect - we will continue to seek improve* ment but we fear will not meet such standards. This auto Industry opinion mi unanimous 0.8. and foreign. Their remarks also served notice of probable losses in mileage - 10 > | i LI A145 29 . > r.Ji'! usii- -5 - to control 00 and HC, another 20^ to oontrol NO*. ^ 7. The press 1* hot pushing u bard though thl* nay ba temporary, and there la beginning to ba dlaseat within the Government. Secret*rjr 8tana of Ooanerca baa officially recontended caution, Extremely good authority haa atatod that Secretary Norton of tba Interior la simulsrly dlaturbed. Stana baa already bean pilloried by tba New Toxic Tinea for daring to auggeat that coat night male a dlfferanca and abould ba conaidared. 8. It aeona clear that at wont, fren our point of view, pbaaeout tinea of to aeven yeare, whether by legislative action or by regulation will permit further appraisal, teat^develojwsen^research and poaalble reversals of whatever nay flret appear. 9. In tba field of reaeerch and development - new enlaalon control aystena and derlcea and eatalysta ccxq>atlbl* with lead are conatantly being announced. Since away of theae bare naaaira canaerclal potential, detalla are unavailable until development la well along. To lllnatrate a few: The Carborundum Company propoae* blgbar valent chrcnUn oxldea on an alminua rubitrate with exceptional reelatance to polaonlng by lead additive*. & eomterclal organization In Germany, Deguaaa, bea announced a eatalyst^not adrcrealy affected by lead In gaaollne with carbon nonoxide and nitrogen reduced to very low level*, ibe Atonic* International divlalcn of North American Bocbvell baa a low neltlng eutectic**alt gaa acrubber, unique In that it would be located ahead of any catalytic device. It la aald to reaore lead effectively. vmiia it prove to function aa claimed It could conatltute the beat anever yet. Sri* la being examined very cloeely by a TEL manufacturer and 1* aald to be under teat by ford. Bra Tex*a Ccmpaay announced a lead trap in 1970 which did not atlr much U.8. enthualaan but la aald to be under extensive teatlng In Europe. DuPont, Ethyl and Houaton fhf<<**1 are continuing to refine their ayitma which Include lead trapping. Seas of the oil conpanlea have not "rolled over*. The poaalbllity for the uae of ceramic ooated ateel K -3 ppip^AjfrMastUlif^gP^^ lia^'tfriririiilsaifcaaat. .T1 6 * in thermal reactors la drawing large attention. This la of lj^ortance la thermal reactor emission control devices for It could permit tb< uaa of such cheeper materials of conatructlon. A Swedish manufacturer claims to her* a caraalc reactor* 10. though the automobile industry haa no doubt aada aubataatlal progress In the development of catalysts which will only work with *00" or "low-lead" gasoline - none baa yet atated they can meet the '75 target of 50,000 miles guaranteed before change. 11. there la a growing acceptance that "no-l*ade4"gasollnes can lead to early valve recession and massive lncreaaea la exhausted gaaea. I think there la little* If anything* to be done 00 thla for the care on the road (of which there are over 65,000,000). for new production the automobile lnduftry can overcoat valve receaalon by hardened aeata and lnaerta but thla will add ooet. 12. the oil industry haa been consistent, though not unanimous* la its opinion # that In order to keep today'* car* going e hli*r percentage of aronatlca will be used. Arooatlc* contribute to smog formation tad there la large reason to believe that their emissions could aggravate the formation of compounds tending to produce cancer, this la an Important plus for lead's case. 13. Technical papers from GX bare within the last 2 months announced a fear that the catalytic systems involved In the control of nitrogen oxide might result In a parallel increase In the emission of Simla. Ik. The'newest argument on behalf of lead's retention la to be found In a Dultont report, out about a month, coverii^t an experiment in en abandoned tunnel In fenoaylvania. Visability was reduced to almost 50$ and toiling Increased more than 50$ When Don-leaded gasoline was used. The tunnel was about on* mile long and a fleet of cars used. I have dwelt at tooe length on those points vhlch speak strongly for the retention of lead in gasoline. In the absence of any demonstrated adverse health effects it la a little difficult to see how an adrerat Judgment could be made but it la necessary a !f::- -7to consider unfavorable uptcti of the situation a* wall. Let me talk for a while about tbeas. 1. first, and without question the most iaportant, ia the Oovwrment'a attituda. There haa been no sign of official softening ia the poettire of the Extentire Brandi aiaee late 1969. It ia expected that the DA will within the next aereral sonthe iaane three documents related to lead cowering "Sources of Brrlrotseental Lead", "Criteria for Lead in the Atmosphere" and "ZnrlroaMotal Lead and Public Health". She preparation of theee documents haa involved Committees with repreaentativea of the Lead and TEL Ininatrite, but final fame have not been generally reviewed by induetry aen and can be expected to be tough. Actions on paint and water aa well aa thoaa debated on the ataoephere demonstrate clearly their intention to preea for lead'a reetrictloo or el iminatioa broedly, and particularly where there nay be public eupport. There la each of politlca la thla. The Ocnrerrmcnt ia using its Missive propaganda wachine to lead'a detriment. Dr. lewill of the DA made a presentation at LXA'a April Amrnal meeting ia Chicago suggesting that auto emission "fall out" cca^licatea lead paint poisoning of ghetto children any very well Indicate a new line of attach - "let us protect the childrenl" *e can expect more attacks on lead in food. 2. The autcaobils industry haa not retreated from its early 1970 statement that the beat way to control emissions la with catalytic converters and the catalytic converter ia rendered quickly ineffective if lead la present. This ia a massive threat. 3. There is continued threat of a tax on lead used for the manufacture of additives. Tha announced objective of the tax, as proposed In 1970, was to drive lead from gasoline although it would be a revenue producer in the meantime. As proposed in 1970 the tax calculated to yltld $1,600,000,000 in its first twelve months of operation, or over 19 times the market value of the lead consumed in that period for the purpose. It would ss_- *) hare aaounted to about 2.3# par gallon to th couiwr at th pu*p. The proposal vaa defeated in 1970. It nay well c o m up again. I do not know whit vill happen the next time. 4. It la factually true that atmospheric lead did increase between 62 and 1968, '69. Tha Seven-Cities Study to which I har* Made reference involves three of the cltiee which bad baan atudiad in 1962 and a ecaqparinoe vaa possible. At o m atmospheric alta in Los Angeles/levels vara up 61%, Lester incraaaaa vara notad la Rclladelphla and Cincinnati. It ranalns to ba aaan vbatber rueb general Incraaaaa vill continue or whether aaturatioo traffic baa been reached. Begardless, tbla fact will ba oaad substantially by tba proponenta of lead's removal. 5. Tba situation in California raaalna difficult. California baa bean active in atmospheric pollution control a Inca the early 1950's. They bars made dwaanda on tba autoaohlla industry far More stringent than any other state. In 1970 tbs Call* fornia Air Baaourcaa board adopted an Air ^iality Standard of 1-1/2 Micrograms par cubic meter although it vaa acknovledged that it vould take 15 years to achieve. On July 12 of this year the California State Senate voted dovn a phaseout bill, but typically has already reopened the subject through the introduction of another bill vhlch vould grant authority to control lead additive* to the state's Air Besources Board. 6. Pressure on lead 1s world vide as I hare already coeaaentvl. In Japan use of lead has been haired and a nev TXL plant scheduled to etart producing in late *70 has bean abandoned. Busla permits no lead. Svedan is believed to have a schedule of limitations and phaseout. Gernacy baa acted and baa a further schedule of reduction. Sniping continues in the cwn Market, England and Australia. Tha U.B. Oovamnartt la talcing and Making - frequent opportunities to press its point abroad. finally in this connection it Bust ba realised that about 400,000 tens of lead .II.HUMM** iI ..... ................. .. ' ~.......... * - 9 - ..... ..........*............... per year *r presantly eonsueed fur gasoline additive* throughout the world *nd that about 3/It of this la bell* exhausted Into the atmosphere. this 1* atrot* in It Ion ' : for tboae who favor lta removal. m fact Z halleve that our aalratioc Xlea la trapping i - and that this Is practical. i i Z think it worth a content that should trapping be developed and adopted, the lsad ! industry (idtether Involving the primary or the secondary producers, or both) Is folaf I' to have a new problem in recycling a nasalre new emount of very meaey scrap. Up to now Z have rewlcwed rarloo* aspects of general attitudes, snd have listed lki basic pro's and con's concerning the situation. let a* doe* with two additional R points. I- -.1 Be far as the Goverrmant 1* concerned. Its present official poeltlon now revolve* around the enforcement of the Clean Air Amendments of 1970. Mr. Killian Baekalshsus Is the Administrator of the Kmrlrooeental Protection Agency. Z should like to read extracts of his openly remarks on the occasion of XFA hearings In Washington on May 6 and 7, 1971r *Xy first point, then, Is to emphasise that the lav itself does not permit R" r ? traditional conceptions of satisfactory vehicle driving performance to stand in the wsjr of whatever change* in vehicle design and power system are needed to control axisslons. Ih* seme Is true with regard to vehicle cost, this hearing is part of a continuing effort by the Environmental Protection Agency to find out Just what sacrifices might be needed, in cost, in fuel economy, in power. Is acceleration, and i in other historic yardsticks of vehicle performance, to produce an automobile that we can live with as a people. 4 "the low-emission car of the future may be a more expensive car. It may not equal today's car In road performance. But this Is a price that may be necessary If we are to hare and presarve a healtiy environment for ouraelve* and our families. "w p u y . wwwpppft^ mMiaiiia<ytth'i iI ri ' LIA14534 .... ~ ~ ' ............................. ' - 10 - ............... "........... ............... .. "A* a consequence, n cannot and vlU not accept anythin* laaa than a vide open research and dcrelopaent effort to Met the Act's requirements. We vill not, for exaaqjle, find acceptable a Manufacturer's decision not to explore Innovative designs or power system on the ground that a vehicle so designed or so powered would be More costly or would not meet traditional performance criteria. Ve must develop and apply ( whatever technology le needed to achieve the degree of ealsslon control required by the Act, and ve aust be willing to accept any necessary sacrifices in other areas of vehicle perforeeace. *Ky second point Is related to the first end baa to do with the specific power conferred upon M by the dean Air Act to suspend the effective date of an ealasloo standard for ooe year. Kxerclse of this power Is carefully circuascrlbed by lav. I am required to sale a determination relating to good faith, and two separate 1l determinations concerning the technology feeslbllity of meeting the statutory standards. "I have given serious consideration to the proper construction of the statutory provision for suspension. It 1s sy present Judgment that the required determinations relating to technological feasibility do not permit me to suspend an emission standard ] In favor of a single applicant or group of applicants, if technical knowledge exists. - S In the Industry or elseidiere, which would enable any member of the Industry to mass i produce a light duty motor vehicle in compliance with the Act. "It le important that all of the Implications of this construction of the lav be well understood at the earliest possible time. It means that if any member of the i Industry could meet the Act's deadlines for compliance, all applications for a suspension will be denied. \ "Any other construction of the suspension provision would be incompatible with M LIA14535 -li the claw Intent of the law to require whatever changee la design or power systems are needed to control maisslons. Where seme manufacturers meet the statutory deadlines by naklng najor changes which substantially increase the cost of their reticles or which require major sacrifices in reticle performance, I do not beliere that Congress intended to subject such manufacturers to competition from cars produced by other manufacturers who are required to meet a lees stringent standard, "As I read the lav, the separate determination concerning good faith beccsMS applicable where it in not technologically feasible for any merdxr of the Industry to coaply with the Act's requirements. In that event, suspensions for one year would be granted only to applicante who can establish that they made a good faith effort to meet the statutory deadlines for ooepliance. Hers on the separate issue of good faith, the special problems which may face a particular manufacturer ajpew to be pertinent." Ob this and the overall situation, I can offer you only aqr own reaction - Xf the dean Air Amendments of 1970 sue literally interpreted and enforced as Kr. Rickelshaus proposes, if the auto industry of the U.B. is acting and speaking in "Good faith," - end barring a miracle - the auto Industry will essentially shut down In 1976. This is so preposterous that I believe the "CAA of 1970" will be emended more sensibly. Assuming such future amendment to be a probability, we (the lead industry) should continue to press our cass based on logic as we see It. I believe we are deeply involved In a political chess game. 8uccees at the polls in 1972 is the stake. Logic end technical fact might well be returned to influence in 1973-197V. Let me close with a word of caution for the enriromentallsta and others rushing ahead at full speed as ooncerns the enrirooeeat. A cass Z should like to describe has nothing to do with lead but should be food for thought in the of those seeing -disaster f m ........................... ................ ' - 12 - ~T'..... ' -------- ----------------------- closaly ahead and precipitous action deaanded. Zn 1966 there vara 2,800,000 death* fren aelaria on the laland of Oeyloc. In 1967 and 1968 tha Inland vu liberally and expensively prayed vith DDT. Zn '68 there vara 128 deaths fra* aalarle on Ceylon. Zn '89 and *70^ for whatever reason;they did not epray. Zn 1970 there vara 2,500,000 deaths fron malaria. The authority for this bettor story was John V. Campbell, editor of the Oonde Vast publication "Analog'. It appeared editorially in July, 1971. Mr. Caagbell died on July 12 and vas eulogised vith great raspect for his technical cca^eteuce and vith paraonal admiration In The lev fork Tines on July 13. This Is a aenbar note on which to cloae, but certainly should be thought provoking. Ve should not rush ahead until va know aora than va do, for ve can readily vorsen rather than Improve situations. Ve have cited eane of the posslbllltlea of exrrironnental degradation as Involved vith our own problem. Perhaps the Boat trying aspect of this has been that the finllng* 9 and claims of Industry, regardless of bow solidly based or scientifically determined, are discounted because our Interest Includes consideration of profit. Me should not overlook any opportunity to Improve that Image. Thank you. Z would welcome any questions. XXX 5: 9- lpswiswwjflJBi '