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, 2PbBrClCNH4Cl, 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, 2PbBrClCNH4Cl, 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.