Document wqZEqaENMGXYw5gejznRx86J4

Lead Industries Association, Inc. 292 Madison Avenue - New York, N. Y. 10017 Telephone: (212) 679-6020 September 15, 1970 Mr. Clark Wilson Anaconda Company 1849 W. N. Temple Street Salt Lake City, Utah 84116 Dear Mr. Wilson: At the request of Gerry Sorell, I am attaching some infor mation about the use of lead in gasoline. Included are several Bulletins that we published on this point, Jack Kimberley's testimony which he will be giving before the Ways and Means Committee on Thurs day this week, plus a mock-up of an article that will be appearing in our next issue of LEAD Magazine. If you need any additional information or have any further questions, please do not hesitate to call or write me. EMB :1m Enclosures cc: Mr. G. P. Sorell David M. Borcina Secretary, Treasurer PNrC00002074 N10164 LEAD IN GASOLINE By S. L Kimberley Executive Vice President Lead Industries Association, Inc. Lead additive- for gasoline. which |i*<j\hh- untold millions of im-xpcn'ivr horsepower for American auto, mobile?. luxe hi'i'ii caught in fho wrangle of frantic vlTorls to ledwi* air polluting vtni??ioii? from auto ex haust?. Iti the understandable and com mendable dri\e to clean up our air. -impir panacea.' arc frequently ad vanced whi te only complexity it-igns. That*? why lli-.i'- has developed considerable momentum behind the atch-phrase "get tin- lead out" of aa~linc. evn though theie i- little evidence that -ueh action would ininvr jnitivp benefits and much evidence that J^e u tion could have hoomerana Kitr<Y. /' .Since their discovery in the L92U? / Nad additives in gasoline have pro* vided anti-knock qualities that make f (rid- smoother burning. more vUi* <hut. and !<>* damaging to engines. I hey make possible higher octaiu more powetfuh gu?oiiw at lower I'lming cu-ts and greater conser vation of raw petroleum stocks than would otherwise he possible. head industries A?*o> ialion. (nc. ha? an obvious interest lit getting the fact? and in helping to u-suive this* complex problem. That's why I was authorized earlier this vear to make an intensive investigation of all aspeets of this subject ami to represent the 1.1 A before various H-islati U? hodir? considering Hie lead additive? quotum. I urn gralelii! for consider able help and guidance from mem ber? oi our own and other Industriei oneerned. As a result. LIA has taken a siiong >tand against proposals tor the arbi trary elimination of lead additives from gasoline, based on present knowledge and evidence. \t the same time, we have taken the position that clloil- to reduce o\jwu? emis-ion? front automobile cmrtnrs .-Would iui iude intensified research bu a meanof reducing exhausted lead, which con?lhute> about one-third of l pri ed it of auto exhaust emission?. This position is fully supported by live following basic farts: 1. \o data has been advanced to -how that the amount? u! lead ex hausted trotn automobile? . po-e a iieallh hazard or major pollution threat, now or foreseeabhThe ques tion of lead in the atmosphere ha? been intensively research1 d. in la rutpart with assistance from the lead industry, for manv Year- and con tinues lo be closelv studied. 2. Scientihe i-v idemv iiuiic ale? liui! pollution hazard? could .etmiliy he increased if had were to be elimi nated from gasoline umlri current condition*. Tivi- is partly bnau-e of the likelihood of increased i imv Io k ? of -o-taJlcd aromatic compounds which are known to voWnbuie to -mog and eye irritation and -o.ne of which are considered can inoginu. >. Ellhmuatiun of lead from-gaso line would involve massive expendi tures by oil companies, auto < urn* panie?. and'the public- -with no dear asurance at this time that lln-ie would be commensurate benefits in eliminating .the carbon monoxides, hydrocarbons, and nitrogen oxides that constitute the major noxious automobile exhaust pollutants. 4. Pollution control system? for automobile? that work with leaded gasoline? have hern developed anil demonstrated. The drive for nonleaded ga?oline is premised primarily m the automotive industry's assump tion that control systems {involving ratal)>1$) are to be preferred anil would wmk better and be longerla-ling with iion-leaded gasolines. However, at this point there ha? been no assurance ihat thi? assumption is correct or that svstema to work with non-li-aded gasoline are anywhere m u rear.lv to be put on new model eats tn the foicse.aUe future. These points are a distillation from the ureal volume of information col lected for [.[.A since about thr first of the year. They come from -tudv ol past ami current scientific and Urhi.hal literature, from personal inter views 1 have had with top executive? A automobile, petroleum and bad additive producers, from discussion? with knowledgeable government offi cial-. testimony either heard by me personally or read from transcripts of federal and ?tate hearings on the question, and from reports of experts curienlly studying the question. Un the basis of these fai ls. I wa? authorized to appear before, or sub mit statements to. several state bodie? considering legislative restrictions on leaded gasoline, appropriate Congres sional committees.in Washington, and a ?pecial Presidential Commerce De partment panel considering automobile fuel composition. Cover photo CQu<tty of Th R*arch Corporation of N*w England. PNYC0000L075 5 ^10164-01 Gaseous and pjfticuiate emission standards lor automobiles orooosed Cy the fee*' -i gov-a-i. ment for :975 can now be met Oy the use of existing automotive systems, suen is the j-oait one developer by OuPonr. The cyclone trap oortion of the system snown ner traps jr..i stores particulate em.Siions, .nciudmg lead. LIA also piepured a succinct posi tion pa(t?r for the iitfot matioti of menibci- of tlic l- iii tal i.oiign?- con sidering proposal. affecting gasoline additives. ()m- proposal would rive (he Department of Health. l\dutuli`*n and Welkin- broad powers to regulate the composition of automobile fuels. iiM'fuciJmtr tiic- use of load and other additives Another would place > pu nitive tax on leaded gasoline in an effort to drive il oH [he matkrt. Neither of these proposals is iu-tilied by evidence showing that, a bun on leaded gasoline would brim: liie de sired results dra-tic reduction or diminution of auto poUutunls. In v ii-u of current technical deveb opmenls lor ?\-tom> "to control ex hausts from irat!<*d g:t*<diuc. LIA be lieves that a ban or siniiljr legislative restriction <>u gasoline composition would result in restricting the range of etlort? lo develop workable sys tems to alleviate automobile pollution, for example, in mid-summer 1970 mir of the largest oil .companies an nounced development of a lead filter for autos that would raptute a sub stantial amount of the lead resulting Iroin u-mbtisiinn of leaded gasoline, lifts is only one of recent develop ments indit uting that there is much progress being made in developing eontrol systems that work clleeltvely with leaded gasoline and that would also |.e cjpabie of reducing lead emis sion?, too. The California Air Uesourees Board earlier this year verified that one such system cut escaping hydrocar bons and nitrogen oxides to a level more than 50 percent below the state's proposed standards for 1975. The same device vs as shown to reduce carbon monoxide emissions more than M3 percent below these stan dards. Nitrogen oxides were reduced to less thuu 50 percent of California's 1975 standards. And this was with leaded gaswlme. Id fjr-t. the (.. rmiterci- Dcpail- merits lerlittieui Xdvi'otA iioaid I'uuc! ui Automotive fuel* and Air I'oIIulioM ii ro'jni/i d the poa-iidfitv of efficient emission (-octroi sv.terns which operate on leaded gu.nfinebt-ing developed in the mar future, and did not recommend the elimi nation of lead additive;. although tli-Barnl also recommended tle avail ability <t an unleaded fuel. Aside from leeiuuVal aspect... thenis tiie very real possibility dial the i hanged Composition of gasoline that would result from the elimination of lead would pose both hm.vui ami vinknown problems. A U.S. Bueruu el \lin> study published in May reported on tes(> comparing haded regular and pre mium gasolines uitli comparable nonleaded fuels. 'Hie eumdiish n was that the unleaded fuels increased eve-irri tating. smog-produ' iiea emissions l*v as much as 25 pereeul over the leaded fuels. I hese Very sei i<u~ considerations were succinctly pul by l)r. Bieiuird l). Ladle of tile National Center 1 Atmospheric Keseurrh. An article Dr. Ladle's position appeared in t April 20, 1970 issue of Chrmicul N Angfneermg ,Vnu and said in part: "In connection with any possible health hazard from the lead com pounds that automobile^ x.-mi into the atmosphere, Dr. Ladle believe* that there is reason for aluim. but warns that quick solutions could build into problems of an entirely different stripe. He suggests, for ex ample, that gasoline mnuufat tim-r> who hope to replace leaded alkane gasoline with high-aronuttie fuels -hottld look at least tw ice heloiv they leap. "lt*s conceivable that sotne of these aromatics could lead to the formation of carcinogenic by-products in the . >ubu>U0u process, although I don'i know 111 am haul evidemr l* sup poll lieu idea. Neverthele'?. ammalie oniponiids geuerallv are toxic, ir( -.prt live of whether <u not thev're earciungeiih "Al.'o. tertaio atunialic euiupound' have been found Ut la- more >evere in magnilmle. more j-evere a> eve ii i ilants. Ilian the |>eiu\yjlk\I idtuilex loi mod from (uveiilhmal g.ixiline'. \\ but I'm tvally saving here i* that in I hr whole area oJ air poilutioti (<>nli"l. we slnmldn't rush ahead w it It iir -"lulimi hefoi'r tiling to anticipate the huger problem? il tmiv cieatr.*' Dr. t adh-'s Ic-ais may have alveadv beeiyq-femdnslfatod ter have reat -ah- -lance, l ids uecurri'd this summer in Japan. Beeau'e of a "lead seme" liiat ;is subsequent!) proved false, the Jafiauese Ljoveniment htnriedly last spring s-1 a limit on lead in gasoline at about one-half of what it had been. This lower-level lead fuel went on -ah* in Tokyo the first of July and in 'ubsci|Ueiil weeks the ga-olilie sob! for car? in that large oriental cilv was ol the greatly reduced lead content. \e\ertliefe.". about lour v\reks later. I'okyo was experiencing the worst suiog erisis tit its history-- atli ilmted not to had lut to the reactive emis sions that'created the cilywide photo chemical smog when the spring rain hauls passed and lei the sun hit the gj-eotts automobile emissions. \s 'Oggesied by the Bureau of Mines study and by Dr. Ladle, the reduced lead eonlent of gjso7fne' uiav wtll' have resulted in higher aromatic emissions!- ' -- - Du the economic ramifications and other consequence* of a quick switch lo nou-leaded gasoline, without good irason, the April 8 issue of 77u* U all V/eet journal went into considerable detail, and can he summed up as follows: 1. The oil industry will have- to make a major investment in new re fining facilities, variously estimated from Sf> billion to $10 billion, as well us an additional C> to 8 percent draw down in fietroleum reserve?. 2. Small petroleum refineries may have U> shut down because' they do 6 PNYC00001076 * iml have the capital resources to make the new investment. \>|ihalt. the backbone of mad building. would ho curtailed since this [u'o.luct is made largelv by the ' mall lelitirtirs. 1. The hundred? ot' thousands of retail outlets for gasoline would have to install m-w gaolin<- pumps and gasoline storage tanks. The availabil ity of jnimps is strictly limited; tinlabor required to install them and the tank-* will add to the inllation of con'Inntion costs. 5. Without kail in gasoline, oil companies would have to make greater u-e of hen/cue., toluene and v\ku. ohcieby dimimsluag .the. sup.* ply of these materials to the petro chemical industry, with sharp inllalioiurv consequences. C>. Sellers of bromine and sodium would Jose a major market since these are the elements Used in combination with lead for gasoline additives. 7. I he lead industry would lose 20 percent of its total market. A replace ment market cannot be fouucl over night. The problem is complicated by the fucL that many lead producers have already made major capital outlavs lor recent plant expansions. The Lead industries Association.mine. main tains an extensive fite of reference material renting to lead additives. Material available upon request includes: UA statements te: The Commerce Department Technical Ad visory Board Panel on Automotive Fuels and Air Pollution. The California Assembly Transportation Com mittee. The Pennsylvania House Committee on Health and Welfare. The U S. Senate Subcommittee on Air and Water Pollution. The U.S. House Subcommittee on Public Health and Welfare. Informative material: "Facts About Lead and the Atmosphere.** The LIA Position Paper on Removal of Lead Additives from Gasoline. "Gettin' the Lead Out" Molar Trend, May 1970. "Comparative Emistfons From Somd Leaded and Prototype Lead-Free Automobile Fuels." U.S. Bureau of Mines Report 7390. May 1970. | Ths Uriknov-: c' Substitution j All these dislocations and diilicultie> might be justified if I there* had been demonstrated the availability of devices to i deal with emissions trom unleaded gasoline that would ma tcrinlly reduce air pollution. However, this has yet to be proven. * These then are the major reasons why the Lead Industries ! Association maintains that it is |m<r public policy to compel I the abandonment of an existing proved source of efficient autoj motive power without a clear. accepted proof that the alterna tive represents a cb-ur and demonstrated improvement. ::: : .. .:l .; Six Facs Re; .. j u y : Proposed Removal (.! i.-_ -0 I ' ->S. I'ne Fact Number 1: No proven benefits in auto emission have been demonstrated to re sult from lead-free gasoline, despite speculation and assurances. Fact Number 2: Significant reduction in auto emissions has already been accom plished with systems that work with present automobiles and pres ent gasoline. Fact Number 3: The knowns and unknowns about non-leaded gasoline do not at this point support the supposition that auto emission problems will be solved by the removal of lead. Fact Number 4: The uncertainties about results of using non-leaded gasoline empha size the need not to ban leaded gasoline now for the future. Fact Number 5: Lead does not contribute to formation of photochemical smog--one objectionable result of auto emissions. Fact Number 6: Lead in the atmosphere--whether from auto exhausts or other sources--does not represent a health hazard to the public. Lead traps for automobile exhausts are being developed and demonstrated. PNYC00001077 7 .+