Document gDgB5oBO4jn1vbz91vdagdE3

Lead Industries Association, Inc. Mi U*l*OA IkNiM New Vort. N- V. 10017 WhiHom; {ilg STMMO &? January 22, 1971 SUBJBCT: 10: BULIETIH VO. 13 HEAD IX GASOUXZ AHD OTHER HUB HZLAIIHO TO ESVXRCKKEirr ALL XEXBE3S OP THE LEAD ECASIRIB ASSOCIATE* Oentlfen; Bulletin Ro. 12 vu sailed to you on October 6. The eltuatloa u concern* lead in ga*ollne ha* alid essentially ildevlae though not for the better daring the Intervening period. There ha* been a substantial asount of activity In which the Asiociatlon has been Involved, but It ha* resulted sore in development* of niitor program* and legislation than In new approaches. This topical report Is Intended to bring you up-to-date. Items are presented by basic classification rather than chronologically. KATIOKAL A. Clean Air Amendment* of 1970 " Coaaittee* of the two houses of congress set and reached a cosproalaa agreement on the House and Senate bills previously passed, which more favors the Senate version (Hustle's) than that frca the Houae. As a result, the Clean Air Amendments of 1970 were signed by President Hlxon In mid-December and ordered printed December 17, 1970. Vote: The official document has the identification "Report Jto. 91-1783". It appear# to this writer that Section 211 - Regulation of Fuels - starting on page 2k is that section of primary Interest Involving lead. The hill does not mention lead. It does, however, grant to the "administrator" powers td regulate the manufacture and sale of additives under the following qualifications: a) If any emissloa products of such fuel, or fuel additlvee, ere endangering the public health or welfare, or. 5 t r ' A >:`ci IP?fSP^ N 3534 b) 1f emission product* of ruch fuel, or fuel additive,will impair to ft ilgnifleant degree the performance of any emission control derice or system which 1* In general uie, or which the Administrator find* has been developed to a point that within a reasonable time it would be In general uie were such regulation to t* be prcaaulgated. ft c) The bill provide* that the Administrator before controlling or prohibiting the additive, Bust coni id*r "all relevant medical and arlentlflc evidence available to hln. Including coniideration of other technologically or economically feaaible t earn of achieving eadaalon standards". d) The manufacture of additive* can, within 10 day* of any regulation by the Administrator, require public hearing* and, e) The Administrator Bay not act if another fuel or fuel additive, to replace that In question, will produce e&l((lon which will endanger the public health and welfare to the same or greater degree than the us* of fuel or fuel additives r*- proposed to be prohibited. t) The Clean Air Aaendaent* would sees to preclude action by individual t States (or political subdivision* thereof) along the line of prohibiting fuel l additives unless earlier action has granted such authority to a State or aub- ; division thereof. Sot*: Bils latter condition would seen to leave California free to act as it wishes. There is certainly doubt aa to what new actions can * be taken, and quite possibly tome actions (as in Buffalo, later described) aay ;U : have to be rescinded. r i1 If this general Interpretation of the dean Air Amendment* of 1970 as concerns t additives is correct. It clearly Indicate* a greater significance Lk,. for the various approaches and documents being prepared by the national Air Pollution Control Adainistratlon. Aa an example, a Lead Liaison Committee y working with HATCA has recently reviewed (with the Government) a very damagli* document aimed/establishing criteria for lead as related to health and safety. i. The Lead Liaison Coralttee includes members from the TEL industry, the LXA, XLZKO and lead producer*. This coraittee i* well aware of the importance of Its assignment and is protesting the Issuance of the forthcoming document with- J- i, out a third review. This aspect of activity will be followed aa diligently and as aggressively a* practical. i t: B. Environmental Protection Agency - y Earlier, considerations of Governmental action to establish the fate of lead additives in gasoline were slated to be under the Jurisdiction of the Department ?> of Health, Education and Welfare. A new agency known as the Environmental Protection Agency baa been created under the direction of kr. V.D. Ruckelshaaa. Apparently the information and proposed regulations being prepared by HEW will now be under the Jurisdiction of EPA. The Adalnlatrator referred to in t the first Item of this report will be an EPA man - undoubtedly Mr. Ruckeshaua. I, - Sr l ' 1 LIA14444 1 0 8TAIM A. California - 1. & California Air Baaourcea Board bald hearing* on Bovember 9 and Bovember 10, 1970, and shortly thensiter adopted an extremely tight Air Quality Standard which limit* lead In the ambient atmosphere to 1-1/2 mlcrograa* per cubic Deter. It vu announced (in the preaa) that It night taka aa much as 15 year* to Implement thla standard and In Boveaber apeciflc proposal* for implementation did Dot exlat. Dr. J.f. Cole of ILZRO testified at these hearing*. 2. On Boveaber 24, in California, the Transportation Cocetlttee of the California Bouse held hearings under the Jurisdiction of fiepresentatlv* Schabarum. neither XJA no ILZRO testified at this hearing for It was a follow-up on tha earlier sessions. Lead's interest* were covered by Nr. Howard Resselberg, of tbs Ethyl Corporation. 3. the firviroomental Defense fund, with the Sierra Club and friends of the Earth, have petitioned the Air Betources Board to consider an even more drastic action. Bearings will be held in Los Angeles on January 20 on a proposal that no new Californian registered and operated car hn exhaust acre than 0.0 grams of lead per Bile. Bote: 0.0 grams per Bile has been reported as Beanlng "no lead" In gasoline, from a basic specification point of view it is this writer's impression that 0.0 grass per Bile Beans not aore than 0.04999 grams per Bile. Ve have been told that those pressing for tbs restriction, interpret the number as Beanlng essentially no lead. The topic Bay be one for debate. DuPont and Ethyl, among others, are testifying in California on Janaary 20. lha debate Bust be of necessity extremely technical on aa engineering basis and it is felt that neither LIA nor UZRO can reasonably contribute. Bote: As of January 21 we learned that thla Batter has been deferred by the ABB. 4. In late September, the California legislation passed (and Gov. Beagan signed) Assembly Bill Bo. 919. This Bill covers older vehicle registration is California and saya in effect that any vehicle with an engine ccapresslon ratio between 8.5 to 1 and 9 to 1 ahall pay an extra $50 per annua and further, that engines with a compression ratio over 9 to 1 shall pay $100 extra per year. 5. Similarly Bill Bo. 1174 was passed and signed by Gov. Reagan which prohibits sals of cars - starting with 1972 aodels - if such cars require higher than 91 octane gasoline. B. Arisons - On Boveaber 20 the Arisons Stata Board of Health held hearings in Jboenix on the overall question. At the outset the bearings chairman announced that Arlsona did not propose any legislation at this time but was asking for genaral lnformatlon on ths overall problem. -3- i I1 i j > ' J DuPont, tthyl end thl* vrlter testified on behalf of lead's continuation. Xuaeroua refinery coeipsny representatives also teitifled - more moderately then ve have heard then In other cu. The autoswblle Industry vu represented hy a western engineer of General Motors. By-end-large, the Arlaona bearings vere quite reasonable. There vere no spokesman for the Cltlsens environmental group* though there vere * engineer ing professor* who spoke strongly against leal. Zt Is not known what stay next be expected from Arlioca. A copy of my testimony at Jhoenlx is attached. cities A. Buffalo - On December 21 the City of Buffalo, K.T. passed an ordinance, with the following restrictions: 1. Each service station shall have at least one jws^ to furnish 1/2 gran --w<hm of lead per gallon as of Septeaber 1971. 2. Xo gasoline with acre than 1/2 gram per gallon shall be sold after January 1, 1976 and, 3. Bo gasoline containing any lead shall be sold after January 1, 1900. B. Pallas - The City of Dallas is holding hearings on February 6 on a bill which Is Intended to duplicate Buffalo's. C. Kew York City - The lev fork City Council will hold hearings on potential Kew fork action January 27, 1971. Bote: In view of the apparent limitations of the Federal dean Air Amendments of 1970, It Is not known whether such city restrictions and ordinances as described can be made legal. It is quite likely this writer will testify at Dallas If hearings are actually held. I will teatlfy before the Kew Fork City Council and will report to you later on what may develop. OEmoua - A) Ve reoomnend for your reeding an article in the January issue of FOKTUXK magazine, ''Metallic Menaces In the Environment". This Is a damaging article suggesting flatly that lead Is going to be phased out of gasoline. It has been -k 11' J'. wi^ggwwt. iHwi ,\rs^. . * f; m :\ 'i 3 vary carefully prepared and there are fev polota which can be dearly knocked down. It la thla writer' opinion that the article la unfair, acre because of what It does not say than because of what It does say. Ve know of rebuttals being prepared, including our own. Frlamrlly these rebuttals will take the fora of letters to the editor of rOATiJVX. B) Mutual Broadcasting Radio - intenrler through arrangements made by Hill li Inowlton. The Mutual Broadcasting Company will shortly embark oa a series of 13 one-half hours broadcasts on environmental Issues. Dr. Cola of TTZBO and the writer were lnterrleved on January lU. Ve corered "lead In gasoline" from the Industry's point of rlew. The questions presented by the Interviewer, Mr. Bill Bertenshaw, had been cooperatively arranged and though the general atmosphere was very Informal, I believe the presentation will be worthwhile. Ve have been premised at least one week's notice ss to the broadcasting time throughout the country and will advise you as much in advance as ve ceu. The balance of thla report la concerned with other than lead In gaaollne. A) Lead-based Paint Poison Prevention Act (KH 19172^ has been passed and was signed by the President the week of January 11. This bill says In effect that paints containing store than li lead shall not be used on Interiors, nor on exterlo surfaces such as porch railings, window sills or other surfacee which can/ Shewed upon by children. LIA worked with the national Faint, Varnish and Lacquer Association during the time of bearings on this bill. The writer supported the position taken by XPVIA by telegram to the members of the congres sional committee Involved, with many acknowledgements received. The bill Is not ideal but neither is It as drastic as seme versions given serious consideration would have been. B) - federal Vater Quality Act - Hy mail of the week of January 11, U.8, members have had information from-LIA on coming action as concerns plant water effluents. Ve must take this opportunity to emphasise that your company's cooperation In the development of effluent standards can be of great importance COWCLOSIOH - If these thumbnail sketches of recent action preempt questions, do not hesitate to let me have them. JIA/gt Attach yegwr?^> .wji|!pw<^ .^}j gi* u. I * It N 3534.01 1 l y ^ i'f c y '1' rW ;? p;w u^i^ .j>yi*wjg^i> 3jiyg^a^y i J ft ^ u^Uj^s LIA14448 K- t-i:: My asm* 1* John L. lUmberley. I an executive vice president of Lead Industries Association, Inc., end ns her* today on behalf of LIA's 60 member companies engaged In the mining, production, manufacturlng and fabrication of lead and lead product*. I wish to thank you for this opportunity to outline tone of the value* of lead In gasoline, evidence demonstrating the absence of deleterious health effects from automotive lead emissions, and even of the problems \dilch might well arise on lead's removal from gasoline He, too, believe In your objective. The people aust be pro tected -- even at a loss to their pocketbooks -- but we believe ^he removal of lead from gasoline Is a step In the wrong direction. In the understandable and coesaendable drive to clean up our air, slsiple panaceas have been advanced where only complexity exists. In the absence of proper knowledge and with the emotional and political pressures which have been applied, a considerable momentum has developed behind the catch-phrase "get the lead out" of gaaollne, even though there la little evidence that such action would bring positive benefits and much evidence that the action could have adverse effects. wn rv*v'*v5 * - - 1'I * 4i> LIA14449 9 A Z-. Sloe* their Introduction In 1923, load addltlvai In gasoline have provided anti-knock qualities that auk* fuela raoother burning, more efficient, and leaa damaging to cnglnaa. They have mad* poaatbl* more powerful gaaollna at lower refining coat* and greater conacrvatlon of raw petroleum reaervea than would otherwlae have been poatlbl*. The lead lnduatry of th* U.S. ha* an obvlou* lntereat In getting th* facta and In helping to reaolve thla complex problem. We are talking about 20 percent of lead'* total market. That'* why I wa* authorized earlier thla year to aiake an lntenalve Investigation of all aspect* of the developing problem end to represent the Industry through the Lead Industrie* Association before those federal, state and community bodies considering the lead additives question. LIA has taken a strong stand against proposal* for the arbitrary elimination of lead additive* from gasoline, based on Its knowledge of 43 years of Industry concern, research and general evidence. At the same time, we have consistently taken the position that efforts to reduce potentially hazardou* emissions from automobile engines should Include Intensified research and further development of existing and potential means for reducing exhausted lead,- which constitutes about one-third of 1 percent of total auto emissions. Ve believe our position Is fully supported by the following basic facts: 1. No data has been advanced to ahow that the amounts of lead exhausted from automobile* pose a health hazard, now or foreseeably. \ f 1 1is b ,1 ' ' K S% k b- % y M H. I" .1 r $ i r-'- 2. Much evidence, Including chat from federal research (0.1. Bureau of Mine*), Indicate* that pollution problems could actually be Increased If lead were to ba eliminated from gasoline under current condition*, becau** of the probability of Increased emissions of socalled aromatic compounds, known to contribute to smog and eye lrrltatloa and soma considered carcinogenic. 3. Elimination of lead from gasoline and the maintenance of today's gasoline quality would Involve massive expenditures by oil coeqsanles, auto companies and the public. These without assurance that there will be significant benefits in eliminating the carbon monoxides, unbumed hydrocarbon* and nitrogen oxides that constitute the major noxious automobile exhaust pollutants. 4. Pollution control systems for automobiles that work with leaded gasolines have been developed and demonstrated. The drive for non-lcaded gasoline 1* based heavily on the auto motive industry's assumption that control systems (Involving catalysts) are to be preferred and would work better and be longer-lasting with noo-leaded gasolines. However, to this point there has been no assurance that this assumption Is correct or that systems to work with con-leaded gasoline are anyvhere near ready to be put on new model cars. I should like to elaborate on these four points. First, there hsve been a number of studies on the health effects of lead In the atmosphere since the mld-1920's and none have shown a danger to national health from lead In the atmosphere -- no matter what lta source. There are no studies known to or studied by us that would alter the conclusions of those reports. h r"- These have Included: U.S. Surgeon Ceneral (1926 and 1959); data without comment froa the National Air Sampling Network (tarting 1957); World Health Organization (1965); U.S. Public Health Service (1965); American Medical Aaeoclatlon (1966), and the American Induatrlal Hygiene Aaaoclatlon (1969). The World Health Organization, U.S. Public Health Service and American Medical Aaaoclatlon have come to the conclualon -* there la not now nor la there foreaeen a threat to health from lead aa from auto motive emlaalona. The other atudlee to which I have referred have indicated no health hazard existed. V Time doea not permit a reading of the varloua conclusions atated In the reporta from the organlzatlona cited, but they are to be found In an LIA Bulletin, "Facta About Lead and the Atmosphere" which la attached. All thla notwithstanding, the lead lnduatry and additive manufacturers are continuing their reaearch and surveillance of lead in the atmosphere. In many euch hearings aa thla, during 1970, I have heard the statement that "the burden of proof rests with industry." Repetitively I emphasize that the Industry recognized thla need 43 years ago, and that lead in the atmosphere has been researched with thla need In ednd since the Introduction of gasoline additives. Our opponents -- pay no attention -offer theory and fear In contradiction. One fine example of a fallacious approach to the claim that atmospheric lead Is hazardous la to be seen In s report of research carried out by Dr. Henry A. Schroeder of Dartmouth Medical School. I can't say whether the news media or Dr. Schroeder has perpetuated this questionable data, but Schroeder's work was the basis for a statement which appeared In a New York Times editorial dated September 14. LIA14452 L. -3 "When fed to test animal*, lead In ewxinte which ere now takes tn by moat human beings ha* reduced life apan* by 20 percent, and Increaaed Infant mortality rate*, aterlllty and birth abnormal It lea.1* Ihla "geaf4 apparently came from work reported by Dr. Schroeder la 1963 and 1963. In falmea* to him, he reported other reault* In the January, 1970 laaue of the Journal of Nutrition. I quote completely and exactly a footnote from the latter paper. F "Prevloua report* have ataled that the doae of lead waa 3 ppm (part* per million). Thl* doae waa Incorrect. A typographical error la our laboratory lnatructlon* reaultlng In five tinea the dealred doae being uaed, both In the experiment* begun In 1960 and la those here reported.... When the error was discovered, the larger amount vat continued." Hf conrat la that this la a rather casual way to admit that there was a 300 percent error In this so-called scientific experiment. k As also reported In the Journal of Nutrition, the early rata wera deficient In chromium, an oversight that was corrected In the rerun. A chart on results of the second go-round (with chromium sufficiency) i showed no adverse effect by lead on the rata longevity, reproductive capability or general activity, they were vaguely reported to have coaraa hair and to be logy as their ends approached at advanced ages -- the asms I- ages aa for the control animals. Thl* In spits of the fact that tha lead dosage was fed (not breathed) at '#*ila over 227 times higher than a human*# normal dally intake. Accepted authority states that man's daily average Intake through food and drink Involved lead at about 0.11 parts per million. The rats were fed 25 parts per million. ' cf ,.--Ca1 iSWartffialiSlrtiilieeWrl mat LIA14453 . .-- * ' 1 think It fair to atata that giving credence to Schroeder' I work would be ouch the aame at auapectlng that one aapirtn la dangeroua to humana and then finding that 227 tablcta won't han even a rat. Second, there la tie very real poaalblllty that the chanced coopo- altlon of gaaollne that would rerult froa the elimination of lead would create both known and unknown problem*. A D.S. Bureau of Mlnaa atudy (Report Mo. 7390) publlahed In May, 5 1970, covered teata comparing leaded regular and premium gaaollnea with i- comparable non-leaded fuela. The conclualon waa Chat the unleaded fuel*1 potential to create eye-Irritating, *oog-producing cmlaalona lncreaaed by aa auch aa 23 percent over the leaded fuela. The very acrloua Implication* of thla report were very well atated by Dr. Richard D. Cadle of the National Center for Atmoapherlc Rerearch. An article on Dr. Cadle'a poaltlon appeared in the April 20, 1970 laaue of Chemical l> Engineering Neva and raid In part: "In connection with any poaalble health hazard from the lead com pound a that autooobllca aend into the atmoaphere. Dr. Cadle believe* that there la rearon for alarm, but warn* that quick aolutlon* could build Into problem* of an entirely different atrlpe. He auggeata, for example, that gaaollne manufacturera who hope to replace leaded alkane gaaollne with high-aromatic fuel* ahould look at leaat twice before they leap. *"lt'a conceivable that aome of theae aromatic* could lead to the formation of carcinogenic by-product* In the combuatlon proceaa, although I don't know of any hard evidence to aupport that Idea. Neverthelaaa, aromatic compound* generally are toxic, Irreapectlve of whether or not they're carcinogenic. mm mm a .l,i& a im .Jmv.. `i Ii mr-' .- >,, ,iti tM iff (,., .*&& r- "'Also, certain aromatic compounds have been found to be more (ever* In magnitude, more severe as eye Irritants, than tha peroxyalkyl nltratea formed from conventional gasolines. What I'm really laying hara la that In tha whole area of air pollution control, ve shouldn't rush ahead with one aolutlon before trying to anticipate the larger problem* It may create.IM Dr. Cadle'a feare may have already been demonstrated to have real aubttanca. Thla statement la baaed on cvcnte thla sunncr In Japan. Becauaa of a "lead polaonlng scare" subsequently proven falae, the Japaneae govern* ment hurriedly last cprlng act a limit on lead In gaaollne at about onehalf of normal use. The lower-level lead fuel vent on eale In Tokyo the first of July and in subsequent weeks the gasoline sold for cars In that large oriental city was of the reduced lead content, nevertheless, about four weeks later, Tokyo was experiencing the worst smog crisis in Its history -- attributed not to lead but to the reactive emissions that created the clty-vlde photochemical smog when the spring rain clouds passed and let the sun hit the gaseous automobile emissions of nitrogen oxides and unbumed hydrocarbons. I quote from the October 17 edition of The Key York Tines: "The Government (Japanese) began a campaign for lead-free gasoline, only to encounter new problems. Experts said that If lead were removed, petroleum companies would have to Increase the level of hydrocarbons to produce equal performance. "This In turn produced a phenomenon In Tokyo known as "white" or "photochemical" smog, as strong sunlight acted on the hydrocarbons In tha atmosphere to produce a mist that caused thousands of cases of sore eyas, sore throats and breathing difficulties," & i i iMM* a lfill afiM a t i IlM Third, on the economic ramification* end other consequence* of a quick twitch to non-leaded gasoline, without good reason, the April 8 Issue of The Wall Street Journal went Into considerable detail, and can be turned up a* follows: 1. The oil Industry will have to make a laajor investment In new refining facilities, variously estimated from $6 billion to $10 billion, at well as an additional 6 to 8 percent annual draw down In petroleum reserve*. 2. Small petroleum refineries stay have to shut down becauto . they do not have the capital resources to make the new Investment. 3. Asphalt, the backbone of road building, would be curtailed since this product 1* made largely by the small reflnerlea. 4. The hundreds of thousands of retail outlets for gasoline would have to Install new gasoline pumps and gasoline storage tanks. The availability of pumps Is strictly limited; the labor required to Install them and the tanks will add to the Inflation of construction costa. 5. Without lead In gasoline, oil companies would have to make greater use of benzene, toluene and xylene, thereby diminishing the supply of these materials to the petrochemical Industry, with sharp Inflationary consequences. 6. Sellers of bromine and sodium would lose a major market since these are the elements used in comblnstlon with lead for gasoline additives. 7. The lead Industry would lose 20 percent of its total market. A replacement market cannot be found overnight. The problem la complicated by the feet that many lead producers have already made major capital outlay* for recent plant expansion*. ~:i........ ....................................................................... J r; F I r" J | ft' %' S- 4 < t ?:. i. S' t- (.. fcSfe? f f i I- r F: . r-^i ''i<i_-.. ? .. . - '-- LIA14456 K",, *Hs3S -9 fourth and finally. In view of current technical development# for systems to control exhausts from leaded gasoline, LIA believe# that restrictive legislation would severely handicap the development of the best systems for the solution of the problem, for example. In ald-suxaser 1970 Texaco announced development of a lead filter that would capture a substantial amount of the lead In the exhaust. A major California coeg>any concerned with aircraft has also developed a promising trapping system for use on leaded fuela. Involving chemical scrubbing from the gaseous state ahead of any catalytic reactor. The California Air Resources Board earlier this year verified a Du Pont system which cut escaping hydrocarbons and nitrogen oxides to a level more than 50 percent below the state's proposed standards for 1975. The same device was shown to reduce carbon monoxide emissions more Chan 53 percent below these 1975 standards. And this Is with leaded gasoline. Six such cars with the Du Pont system and carrying particulate traps are now under extensive test by California's Air Resources Board. Ethyl has a well advanced ayatem with a slightly different approach. These are Important current developments Indicating that aaich progress Is being made In developing control sytems that work effectively with leaded gasoline and that would also be capable of reducing lead and other particulate emlsslooa. As long as there is a reasonable doubt on the overall need for the reduction of the lead content of fuel, no legislative action should be taken. Lead additives have been In gasoline for 50 years without adverse health effects, and nothing has occurred In the past eleven months to change that fact. t \