Great Lakes Binational Toxics Strategy

Stakeholder Forum - 1998

IMPLEMENTING THE BINATIONAL TOXICS STRATEGY
Implementation

Stakeholders Minutes
March 23, 1998 - Chicago, Illinois

Alkyl-Lead Work Group Meeting Minutes

Work Group Leaders:
Anthony Kizlauskas, USEPA - Great Lakes National Program Office
Edwina Lopes, Environment Canada

Work Group Members:
Jeff Bowden, Council of Great Lakes Industries
Ken Scott, Texaco - International Aviation Sales
Jane Vass, American Indian Health and Family Services of S.E. Michigan
Russ Robinson, Environment Canada
Dan Hopkins, USEPA - Region 5 Toxics Reduction Team
Reg Gilbert, Great Lakes United
Ed Klappenbach, USEPA - Great Lakes National Program Office

Step 1 - Discussion of status of chemical; i.e. inventory, emissions sources, etc.:

Current known sources include: evaporative and spillage losses from production, storage, transfer, and fueling with leaded gas; use of leaded aviation gas and leaded racing gas; and contamination of soils and groundwater from spills or leaking storage tanks.

Current possible sources include: leaded gas in other off-road uses, including boats, farm machinery, and others. There may be some lead in certain jet fuels, and (possibly) other fuels used by the military. Possible use of lead in steelmaking.

Current production figures: in U.S., the Department of Energy, Energy Information Administration tabulates refiner volumes of petroleum products, including aviation gasoline and motor gasoline. Is this the best source of such information, and is more detailed information available, such as unleaded versus leaded motor gasoline information? What is the best source of production and use statistics for leaded racing gas? How to determine military uses of alkyl lead and leaded fuels?

Step 2 - Discussion of current and upcoming regulatory status:

U.S.: Alkyl-lead in gasoline still permitted in pre-1975 automobiles, and all off-road uses (aviation, racing, etc.). Leaded racing gas and aviation gas are produced in the U.S. December 22, 1998 is deadline for underground fuel storage tank replacement or conversion to above-ground storage.

USEPA has proposed to add aviation gas distribution evaporative losses associated with the distribution and storage of leaded aviation gas as a source category of hazardous air pollutants under Section 112(c)(6) of the Clean Air Act.

Canada: Alkyl-lead in gasoline still permitted in aviation and racing (racing to be reviewed in 3 or 4 years to determine whether to continue exemption). No known production of leaded gas in Canada.

There is an ASTM work group underway through the Coordinating Research Council (CRC) to develop an unleaded aviation gas to replace the current 100 LL (low lead, 2g Pb/gal). [100 LL is the fuel used by the vast majority of internal combustion aircraft. Some experimental or home-built aircraft use a fuel with a lower octane grade.] Participants in this work group include: FAA (Federal Aviation Agency), AOPA (Aircraft Owners and Pilots Association), EAA (Experimental Aircraft Association), GAMA (General Aviation Manufacturers Association), Textron Lycoming, Teledyne Continental Motors, Cessna Aircraft Company, Piper Aircraft, Raytheon Aircraft, Texaco, Exxon, Phillips Petroleum, Shell Oil, British Petroleum, and Chevron.

Before a replacement unleaded aviation gas can be put to use, it has to go through an extensive testing and certification process to ensure that its performance will not adversely affect safety or engine durability. Furthermore, the replacement additives for alkyl-lead must be tested for their toxicity and persistence to ensure that they are more benign to the environment than what they are replacing. Even when an acceptable unleaded aviation gas is developed, each engine and airframe wishing to use the new fuel would also have to go through a certification process before it could obtain FAA approval for use in that type of aircraft. As a result, replacement of 100 LL with an unleaded substitute is a lengthy and costly process. The potential timeframe for replacement with unleaded aviation gas is on the order of 5 to 10 years.

Other fuel substitutes have been proposed (and FAA-certified for use in certain aircraft), as well, including ethanol. Drawbacks to non-petroleum substitutes are that the current production and distribution of fuel at airports is based on the petroleum industry, making a non-petroleum substitute less practicable, since even if a fuel is certified for use, it must be readily available for the aircraft to use if it is to be a practical substitute. Of course, the non-petroleum substitutes would also have to go through the lengthy and costly certification process.

Worthy of note, is the unleaded gas certification process that has been headed by the EAA for many of the experimental or home-built aircraft that can utilize a lower octane aviation gas. The EAA and Cessna Aircraft worked to obtain ASTM approval for an 82-grade unleaded aviation fuel to replace leaded 80-grade leaded gas. This approval has been granted, and certification for use in aircraft can begin.

The status of unleaded racing gas replacements was not known by the participants, but some efforts to ban use of leaded gas in races in Canada were met with strong opposition from racing groups, leading to threats of boycotts of Canadian race tracks and to granting of temporary extension of approval for use of leaded automobile racing gas in Canada.

Step 3 - Discussion of voluntary reduction options:

Aside from the programs already mentioned to develop a replacement for leaded aviation gas, the status of options for further reductions was not known by the participants. It was proposed that an initial assessment will be made through the work group members once additional representative members join the group or through other contacts with these individuals or organizations.

Step 4 - Action items identified for workgroup, with due dates and assignments to workgroup members if applicable.

Discussion of the need to identify and recruit additional members:
The participants discussed additional individuals who should be contacted for potential membership in the work group:

• The members of the CRC work group seeking an unleaded aviation gas substitute would represent a cross-section of the groups having an interest in the unleaded aviation gas issue.
• Other aircraft industry associations to invite: NATA (National Aeronautics and Transportation Association) and NBAA (National Business Aircraft Owners Association), and an Airports association or FBO (Fixed Base Operator) association?.
• Max Schauck of Baylor University, who is working on an ethanol aviation fuel has expressed interest in joining and should be contacted.
• Other USEPA personnel involved in unleaded gas (Jim Caldwell) and Clean Air Act 112 programs (Steve Shedd, Eric Ginsburg) should be contacted.
• Contacts in automobile racing should be found.
• Ethyl Corporation (manufacturer of alkyl-lead) should be contacted.

Discussion of goals and workplan for workgroup:
How and how often Work Group should communicate:

• Difficult to determine before assessing Steps 1 and 2, but perhaps meet twice a year. The next meeting should be in July or August, 1998, including the new members that will be invited to participate. In keeping with the binational spirit, the next meeting will probably be in Toronto, Canada.

Overall Approach (Workplan):

• Complete the 4-Step process. A more specific workplan to be developed when meeting to discuss the Step 1 and 2 findings.

Issues identified for referral to Integration Group:
Should the Strategy challenge be expanded to address other forms of lead?

Upcoming events or activities:
Work Group meeting in August 1998 in Toronto, Canada to discuss Steps 1 and 2 outcomes and to engage newly invited Work Group members.

Other discussion:
Concern was expressed that only alkyl-lead was being addressed, while other forms of lead still pose potential health threats. It was noted that the Strategy challenges were very specific and the result of a binational negotiation and public comment process. Therefore, it would not be a simple matter to change the challenges. It was also noted that there are other lead-reduction efforts underway under other programs, so the problem of other sources is not being ignored.

Some clarification is needed on the baseline used to measure Canadian reductions.