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ENVIRONMENTAL PROTECTION AGENCY 40 CFR Part 87 [EPA - HQ - OAR - 2007 - 0294; FRL _XXXX - X ] RIN 2060 - AP79 Advance Notice of Proposed Rulemaking on Lead Emissions from Piston - Engine Aircraft Using Leaded Aviation Gasoline AGENCY: Environmental Protection Agency (EPA). ACTION: Advance notice of proposed rulemaking. SUMMARY: EPA is issuing this Advance Notice of Proposed Rulemaking (ANPR) to describe information currently

available and information being collected that will be us ed by the Administrator to issue a subsequent proposal regarding whether, in the Administrator’s judgment, aircraft lead emissions from aircraft using leaded aviation gasoline (avgas) cause or contribute to air pollution which may reasonabl y be anticipated to endanger public health or welfare. In this ANPR we describe and request comment on the data available for evaluating lead emissions, ambient concentrations and potential exposure to lead from the continued use of leaded avgas in piston - engine powered aircraft. We also describe and request comment on additional information being collected that will inform any future action. This ANPR is being issued to further respond to a petition submitted by Friends of the Earth (FOE) in 2006. Emissions of lead fr om piston - engine aircraft using leaded avgas comprise approximately

half of the national inventory of lead emitted to air. There are almost 20,000 airport facilities in the U.S. at which leaded avgas may be used. EPA has long - standing concernsDRAFT March 16, 2010

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regarding exposure to lead, particularl y during childhood. The most recent review and revision of the National Ambient Air Quality Standard (NAAQS) for lead, promulgated in 2008, found that serious health effects occur at much lower levels of lead in blood than pre viously identified and did not identify

a safe level of lead exposure. DATES: Comments must be received on or before [Insert date 60 day s after publication in the Federal Register] . ADDRESSES: Submit your comments, identified by Docket ID No. EPA - HQ - OAR - 2007 - 0294, by one of the following methods:

 www.regulations.gov : Follow the on - line instructions for submitting comments.

 Email: a - and - r - docket@epa.gov

 Fax: (202) 566 - 9744

 Mail: Environmental Protection Agency , Mail Code: 6102T, 1200 Pennsy lvania Ave., NW, Washington, DC, 20460. Please include two copies .  Hand Delivery : EPA Docket Center (Air Docket), U.S. Environmental Protection Agency , EPA West Building, 1301 Constitution Avenue, NW, Room: 3334 Mail Code: 2822T, Washington, DC. Such deliveries are onl y accepted during the Docket’s normal hours of operation, and special arrangeme nts should be made for deliveries of boxed information. Instructions: Direct your comments to Docket ID No. EPA - HQ - OAR - 200 7 - 0294 . EPA's policy is that all comments received will be included in the public docket without change and may be made available on line at www.regulations.gov , including an y personal information provided, unless the comment includes information claimed to be Confidential Business Information (CBI)DRAFT March 16, 2010

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or other information whose disclosure is restri cted by statute. Do not submit information that y ou consider to be CBI or otherwise protected through www.regulations.gov or e - mail. The www.regulations.gov website is an “anony mous access” s ys tem, which means EPA will not know y our identity

or contact information unless y ou provide it in the body of y our comment. If yo u send an e - mail comment directly to EPA without going through www.regulations.gov y our e - mail address will be automatically captured and included a s part of the comment that is placed in the public docket and made available on the Internet. If you submit an electronic comment, EPA recommends that you include your name and other contact information in the body of your comment and with an y disk or CD - ROM y ou submit. I f EPA cannot read y our comment due to technical difficulties and cannot contact y ou for clarification, EPA may not be able to consider yo ur comment. Electronic files should avoid the use of special characters, any form of encry ption, and be free of any

defects or viruses. For additional information about EPA’s public docket visit the EPA Docket Center homepage at http://www.epa.gov/epahome/dockets.htm. Docket: All documents in the docket are listed in the www.regulations.gov index. Although listed in the index, some information is not publicly available, e.g., CBI or other information whose disclosure is restricted b y statute. Certain other material, such as copyrighted material, will be publicl y available only in hard copy . Publicly

available docket materials are available either electronicall y in www.regulations.gov or in hard cop y at the EPA Docket Center, EPA/DC, EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, DC. The Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holiday s. The telephone number for the Public Reading Room is (202) 566 - 1744, and the telephone number for the Air Docket is (202) 566 - 1742 .DRAFT March 16, 2010

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FOR FURTHER INFORMATION CONTACT: Marion Ho ye r, Assessment and Standards Division, Office of Transportation and Air Qualit y, 2000 Traverwood Drive, Ann Arbor, MI, 48105; telephone number: (734) 214 - 4513; fax number: (734) 214 - 4939; email address: hoy er.marion@epa.gov . SUPPLEMENTARY INFORMATION: I. General Information A. What Should I Consider as I Prepare My Comments for EPA? 1. Submitting CBI. Do not submit this information to EPA thr ough www.regulations.gov or e - mail. Clearl y mark the part or all of the information that you claim to be CBI. For CBI information in a disk or CD ROM that y ou mail to EPA, mark the outside of the disk or CD ROM as CBI and then identify electronically

within the disk or CD ROM the specific information that is claimed as CBI. In addition to one complete version of the comment that includes information claimed as CBI, a cop y of the comment that does not contain the information claimed as CBI must be submitt ed for inclusion in the public docket. Information so marked will not be disclosed except in accordance with procedures set forth in 40 CFR Part 2. 2. Tips for Preparing Your Comments. When submitting comments, remember to:

• Id entify

the rulemaking by

docket number and other identify ing information (subject heading, Federal Register date and page number).DRAFT March 16, 2010

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• Follow directions - The agency may ask you to respond to specific questions or organize comments by

referencing a Code of Federal Regulations (CFR) part or section number.

• Explain why

y ou agree or disagree, suggest alternatives, and substitute language for your requested changes.

• Describe an y assumptions and provide an y technical information and/or data that yo u used.

• If you estimate potential costs or burdens, explain how y ou arrived at y our estimate in sufficient detail to allow for it to be reproduced.

• Provide specific examples to illustrate y our concerns, and suggest alternatives.

• Explain your views as clearl y as possible, avoiding the use of prof anity or personal threats.

• Make sure to submit y our comments by the comment period deadline identified.DRAFT March 16, 2010

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Table of Contents I. Overview A. Background on Leaded Aviation Gasoline B. Background Information Regarding General Aviation and Use of Piston - Eng ine Aircraft C . Background on the Petition and EPA’s Response D . Statutory

Authorit y 1. Background 2. Regulatory

Authority

for Emission Standards 3. Regulatory

Authority

for Fuel Standards E . Federal Actions to Reduce Lead Exposure II. Health and Welfare Effects of Lead A. Multimedia and Multi - Pathway Exposure Considerations B. Health Effects Information 1. Blood Lead 2. Health Effects 3. At - Risk P opulations and Life Stages C. Welfare Effects 1. Terrestrial Ecos ys tems 2. Aquatic Ecos ys tems III. Lead Emissions from Piston - Engine Aircraft A. Inventory

of Lead from Piston - Engine Powered AircraftDRAFT March 16, 2010

7 1. National Emissions of Lead from Piston - Engine Aircraft 2. Airport - Specific Emissions of L ead from Piston - Engine Aircraft B. Projections for Future Growth IV . Lead Concentrations in the Vicinity of Airports A. Chemical and Phy sical Properties of Lead Emitted by Piston - Engine Aircraft B. Summary

of Airport Lead Monitoring and Modeling Studies 1. Summary

of Airport Lead Monitoring Studies 2. Summary

of Airport Lead Modeling Studies V. Exposure to L ead from Piston - Engine Aircraft and Potential for Impacts A. Exposure to L ead Emissions from Piston - Engine Aircraft 1. Population Residing Near Airports 2. Children Attendin g School Near Airports 3. Agricultural Activities 4. Pilots, Student - Trainees, Passengers 5. Bioaccumulation of Lead in Aquatic Organisms B. Related Exposures of Concern 1. L ead Contribut ion to Ambient Particulate Matter 2. Ethy lene Dibromide 3. Non - Exhaust Exposure to Tetraethy l Lead VI . Additional Information Available for the NPRM to Evaluate the Potential for Public Health and Welfare Impacts and Considerations Regarding Engine Emission StandardsDRAFT March 16, 2010

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A. The Lead NAAQS and L ead Emissions from Piston - Engine Aircraft 1. Monitoring Lead at Airports to Evaluate Ambient Concentrations to Which Lead Emissions from Piston - Engine Aircraft Contribute 2. Evaluating the Contribution of L ead Emissions from Piston - Engine Aircraft t o Areas Approaching or Exceeding the Lead NAAQS B. Additional Information EPA is Collecting to Evaluate Ambient Lead Concentrations Attributable to Emissions from Piston - Engine Aircraft C. Considerations Regarding Engine Emission Standards VII. Statuto ry

and Executive Order Reviews 

## I. Overview EPA is publishing this ANPR in further response to a petition submitted by Friends of the Earth (FOE) entitled “Petition for Rulemaking Seeking the Regulation of Lead Emissions From General Aviation Aircraft Und er § 231 of the Clean Air Act.” 1 Inthe petition, FOE requests that the Administrator of EPA: 1) make a finding that lead emissions from general aviation aircraft endanger public health and welfare and issue a proposed emission standard for lead from ge neral aviation aircraft under the Clean Air Act (CAA) or, alternativel y, 2) if the Administrator of EPA believes that insufficient information exists to make such a finding, commence a study and investigation of the health and environmental impacts of lead emissions from general aviation aircraft, including impacts to humans, animals and ecos ys tems under the CAA and issue a public

1 See docket item EPA - HQ - OAR - 2007 - 0294 - 0003.DRAFT March 16, 2010

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report on the findings of the study and investigation. Section I . C of this notice discusses the background on the petition and EPA’s response to date and Section I. D discusses EPA’s statutory authorit y under section 231(a) of the CAA. Under the CAA, i f, in the Administrator’s judgment, lead emissions from the use of l eaded avgas cause or contribute to air pollution which may reasonably

be anticipated to endanger public health or welfare, then EPA would be required under our statutory

authority to prescribe standards to control the emissions of lead from piston engine a ircraft. In promulgating such standards, the EPA would be required to consult with the Federal Aviation Administration (FAA), and could not change standards if doing so would significantl y increase noise and adversel y affect safety. FAA would then be req uired, after consultation with EPA, to prescribe regulations to insure compliance with any standards to control the emissions of lead from piston - engine aircraft. Under 49 USC 44714, FAA would also be required to prescribe standards for the composition or chemical or phy sical properties of piston - engine fuel or fuel additives to control or eliminate aircraft lead emissions. In this notice, we discuss our anal ys is of the relevant information and issues to date, and we seek further public input regarding FO E’s petition. For the purposes of this notice, we will refer to the positive or negative exercise of judgment as to whether lead emissions from aircraft engines resulting from the use of aviation gasoline (avgas) cause or contribute to air pollution which may

reasonabl y be anticipated to endanger public health or welfare as the “endangerment finding” and the “cause or contribute finding.” This short - hand use of “endangerment finding” and “cause or contribute finding” is strictl y for purposes of simplifyin g the discussion, and should not be read as imply ing that EPA considers the exercise of the Administrator’s judgment to require a formal “finding” or “determination.”DRAFT March 16, 2010

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In 2006, EPA completed the Air Quality Criteria Document (AQCD) for Lead, which critic ally assesses and integrates relevant scientific information regarding the health effects of lead. 2 EPA concluded that the latest evidence indicates adverse health effects, most notably among children, are occurring at much lower levels than previously co nsidered. In 2008, EPA decreased the level of the primary National Ambient Air Quality Standard (NAAQS) for lead from 1.5 micrograms per cubic meter (  g/m 3 ) to 0.15  g/m 3 in order to provide increased protection for children and other at - risk populations against an array of adverse health effects, most notably

neurological effects in children, including neurocognitive and neurobehavioral effects. 3 Neurotoxic effects in ch ildren and cardiovascular effects in adults are among those best substantiated as occurring at blood lead concentrations as low as 5 to 10 μg/dL (or possibly lower); and these categories are currently clearl y of greatest public health concern (AQCD for Le ad, p. 8 - 60). The U.S. Centers for Disease Control and Prevention (CDC) concluded in 2005 that no “safe” threshold for blood lead has been identified, and emphasized the importance of preventative measures. 4 , 5 To provide increased protection against lea d - related welfare effects, in 2008 EPA revised the secondary standard to be identical in all respects to the revised primary standard. Section II of this ANPR provides more detail regarding health and welfare effects of lead.

2 U.S. Environmental Protection Agency (2006) Air Quality Criteria for Lead. Washington, DC, EPA/600/R 5/144aF. Available online at: www.epa.gov/ncea/ 3 Na tional Ambient Air Quality Standards for Lead 73 FR 6696 4 (Nov. 12, 2008). 4 Centers for Disease Control and Prevention (2005) Preventing lead poisoning in young children: a statement by the Centers for Disease Control and Prevention. Atlanta, GA: U.S. De partment of Health and Human Services, Public Health Service. August. 5 Advisory Committee on Childhood Lead Poisoning Prevention (ACCLPP) (2007) Interpreting and managing blood lead levels <10 ug/dL in children and reducing childhood exposures to lead: R ecommendations of CDC’s Advisory Committee on Childhood Lead Poisoning Prevention. Morbidity and Mortality Weekly Report. 56(RR - 8). November 2, 2007.DRAFT March 16, 2010

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Given the recent findings of the science summarized by EPA in the AQCD for Lead as well as the findings of the CDC, the Agency is concerned about the potential for health and welfare effects from exposure to lead emissions from aircraft engines using leaded avgas. On a national basi s, emissions of lead from aircraft engines using leaded avgas are the largest single source category

for emissions of lead to air, comprising approximately half of the national inventory . 6 There are almost 20,000 airport facilities in the U.S. at which le aded avgas may be used, and in some areas of the country there are densely

populated residential developments immediately

adjacent to these airport facilities. As described in Section V, we estimate that up to 16 million people reside and three million ch ildren attend school in close proximity to airport facilities servicing piston - engine aircraft that are operating on leaded avgas. Exposure to lead occurs through multiple routes (e.g., inhalation, ingestion and dermal adsorption), and lead emitted to the atmosphere can contribute to lead levels in multiple media (e.g., air, soil and water). The lead monitoring studies conducted at o r near airports , described in Section IV of this ANPR , indicate that lead levels in ambient air on and near airport s servicing piston - engine aircraft are higher than lead levels in areas not directl y influenced b y a lead source . In addition, the emissions of lead from these engines are also expected to distribute widely through the environment. This is in part due to the emission of lead at various altitudes during aircraft operations as well as the fine particle size of lead emitted by piston engines. Continued use of leaded avgas provides an ongoing source of new lead that is deposited in various environmental media and participates in long term cy cling mechanisms in the environment, thus adding to the pool of lead available for uptake b y humans and biota. We expect the lead from

6 U.S. Environmental Protection Agency Electronic Report on the Environment. Available at: http://cfpub.epa.gov/eroe . Updated in December 2009 using the 2005 National Emissions Inventory.DRAFT March 16, 2010

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avgas to be bioavailable in the same way as the lead emitted by

motor vehicles in the past, which was well documented to contribute to blood levels through both ingestion and inhalation. As note d in Section II of this ANPR, once deposited to surfaces, lead can subsequently be resuspended into the ambient air and, because of the persistence of lead, emissions of this metal contribute to environmental media concentrations for man y ye ars into the future. Lead that is a soil or dust contaminant today may have been airborne y esterday or man y years ago. Therefore lead emissions from piston - engine aircraft could contribute to increased lead exposure and risk currentl y or at some time in the future. Se ction VI of this ANPR provides an overview of additional information that will be available for the NPRM to evaluate the potential for public health and welfare impacts from lead emitted by

piston - engine aircraft. These additional data will come from lead monitoring being planned to satisfy

requirements of the Lead NAAQS, air quality modeling planned at EPA and any information submitted to EPA during the comment period for this ANPR. The remainder of this section provides background on leaded avgas, FOE’s petition and EPA’s response to the petition to date, and statutory authority over emissions, fuel for aircraft and federal actions to reduce lead exposure. Section II provides a discussion of the health and welfare effects of lead. Sections III, IV and V describe the emissions of lead from avgas, ambient lead concentration in the vicinity of airports and potential exposure to lead from leaded avgas, respectivel y. In Section VI, we describe the additional information EPA is collecting and considerations regarding engine emission standards. Section VII contains information on statutory and executive order reviews covering this action.DRAFT March 16, 2010

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### A. Background on Leaded Aviation Gasoline In 1996, EPA promulgated regulations that banned the use of leaded gasoline in highway vehicles. 7 The addition of lead to fuel used in piston - engine powered aircraft was not banned in this action, and the use of leaded avgas is the largest remaining source category of lead emissions. Lead is not added to jet fuel that is used i n commercial aircraft, most military aircraft, or other turbine - engine powered aircraft . Most piston - engine aircraft fall into the categories of either general aviation (GA) or air taxi (AT). GA and AT aircraft include a diverse set of aircraft ty pes and engine models and are used in a wide variety of applications. 8 Lead is added to fuel for piston - engine aircraft in the form of tetraeth yl lead (TEL). This lead additive helps boost fuel octane, prevents knock, and prevents valve seat recession and sub sequent loss of compression for engines without hardened valves. T here are two main ty pes of leaded avgas: 100 Octane, which can contain up to 4.24 grams of lead per gallon; and 100 Octane Low Lead (100 LL), which can contain up to 2.12 grams of lead per gallon. Currently , 100LL is the most commonly available and most commonly used ty pe of avgas. 9 , 10 TELwas first used in piston - engine aircraft in 1927. 11 In to the 1950s commercial and military aircraft in

7 See “ Prohibition on Gasoline Containing Lead or Lead Additives for Highway Use ” 61 FR 3832 (Feb. 2, 1996) . 8 Commercial aircraft include those used for scheduled service transporting passengers, freight, or both. Air taxis fly scheduled and for - hire service carrying passengers, freight or both, but they usually are smaller aircraft than those operated by commer cial air carriers. General aviation includes most other aircraft (fixed and rotary wing) used for recreational flying, business, and personal transportation. 9 ChevronTexaco (200 6 ) Aviation Fuels Technical Review . FTR - 3. Available online at: http://www.chevronglobalaviation.com/docs/aviation_tech_review.pdf 10 ASTM International (2005) Annual Book of ASTM Standards Section 5: Petroleum Products, Lubricants, and Fossil Fuels V olume 05.01 Petroleum Products and Lubricants (I): D 56

– D 3230. 11 Ogston, A.R. (1981) A Short History of Aviation Gasoline Development, 1903 - 1980. Society of Automotive Engineers. Paper number 810848.DRAFT March 16, 2010

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the U.S. operated on 100 Octane leaded avgas, but in subsequent y ears, the commercial and military aircraft fleet largely

converted to jet turbine - engine propelled aircraft. However, the use of avgas con taining 4 grams of lead per gallon continued in piston - engine aircraft until the earl y 1970s when 100LL became the dominant leaded fuel in use. Currentl y, very little 100 Octane is supplied in the U.S. and we use the lead content of 100LL (2.12 grams per gallon) to characterize the lead available from avgas. Since lead is a persistent pollutant, it is important to characterize the historical use of this fuel. Approximately

14.6 billion gallons of leaded avgas have been consumed in the U.S. between 1970 and 2007. If this fuel was all 100LL, it would account for approximately 34,000 tons 12 of lead emitted to the air. 13 Interms of the potential impacts from long - term use of leaded avgas at and near airports , older facilities would be expected to have a leg acy of lead, particularl y those that supported military and commercial aircraft operating on 100 Octane. Over 3,000 of the 20,000 airport facilities in the U.S. are at least 50 ye ars old and some airports have been in operation since the earl y 1900s. The Department of Energy ’s (DOE’s) Energy I nformation Administration (EIA) provides information on the volume of leaded avgas supplied in the U.S. 16 The Department of Transportation’s (DOT’s) FAA provides information on the volume of leaded avgas consumed in the U.S. 17 EPA has historically used the DOE EIA avgas fuel volumes supplied to calculate national lead inventories from the consumption of leaded avgas. We are currentl y evaluating 12 In this ANPR and in EPA’s National Emissions Invent ory , the use of the unit tons refers to short tons. 13 Oak Ridge National Laboratory (2009) Transportation Energy Data Book: Edition 28. Available at: http://cta.ornl.gov/data. Table A.7. 16 D epartment of Energy Information Administration. Fuel production volume data obtained from http://tonto.eia.doe.gov/dnav/pet/hist/mgaupus1A.htm accessed June 2009 . 17 U.S. Department of Transportation Federal Aviation Administration Aviation Policy and Plans. FAA Aerospace Forecast Fiscal Years 2009 - 2025. p.81. Available at: http://www.faa.gov/data_research/aviation/aerospace_forecasts/2009 - 2025/media/2009%20Forecast%20Doc.pdf This document provides histori cal data for 2000 - 2008 as w ell as forecast data.DRAFT March 16, 2010

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methods used by

DOE and DOT to calculate annual avgas suppl y and consumption volumes. In this document, we provide avgas fuel volume data supplied by DOE and DOT and we note the source of the data for clarity . Over the past ten ye ars, DOE estimates of the volume of leaded avgas supplied ha s ranged from 326 million gallons in 19 99 to 235 million gallons in 2008 (Figure 1) . Appl yi ng the concentration of lead in 100LL (2.12 grams of lead per gallon), the total quantity

of lead supplied in avgas in the nation has ranged from 762 tons in 1999 to 550 tons in 2008 (a 28% decrease over that time period). The decrease in fuel consumption is attributed to the decrease in piston - engine aircraft activity over that time period and not due to a shift to unleaded fuel. There are currently over 200,000 piston - engine aircraft in the U.S. that continue to consume leaded avgas and approximately 2,000 new piston - engine aircraft requiring leaded avgas are manufactured annually . 18 As described in Section III.B of this ANPR, there is a slight growth in the activity of general aviation aircraft projec ted to 2025.

18 General Aviation Manufacturers Association (2008) General Aviation Statistical Databook & Industry Outlook. Available online at: http://www.gama.aero/files/2008_general_aviation_statistical_databook__indu st_499b0dc37b.pdfDRAFT March 16, 2010

16 Av gas Pb, 1 999-2008

0 1000 2000 3000 4000 5000 6000 7000 8000 9000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Ye arThousand Barrels of AvgasSupplied

0 98 196 294 393 491 589 687 785 883Tons of Pb from Avgas

Figure 1. Tons of Lead Supplied in Aviation Gasoline Annually from 1999

– 2008. Source: DOE Energy Information Administration 

### B. Background Informat ion Regarding General Aviation and Use of Piston Engine Aircraft In the U.S., general aviation aircraft fl y over 27 million hours and carry 166 million passengers annuall y. 19 Approximately 66 percent of hours flown by general aviation are conducted b y piston - engine aircraft. 20 Aircraft in the general aviation fleet are used for personal

19 General Aviation Manufacturers Association (2008) General Aviation Statistical Databook and Industry Outlook, p.30. Retrieved on August 17, 2009 from: http://www.gama.aero/files/2008_general_aviation_statistical_databook__indust_499b0d c37b.pdf 20 General Aviation Manufacturers Association (2008) General Aviation Statistical Databook and Industry Outlook, p.30. Retrieved on August 17, 2009 from: http://www.gama.aero/files/2008_general_aviation_statistical_databook__indust_499b0dc37b.pdfDRAFT March 16, 2010

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transportation (36 percent) , instructional fl yi ng (19 percent) , corporate uses ( 11 percent ), business ( 11 percent ) , air taxi and air tours (eight percent) and the remainder include hours spen t in other applications such as aerial observation and aerial app lication. 21 According to the 2008 General Aviation Statistical Databook & Industry Outlook report by

the General Aviation Manufacturers Association (GAMA) there were 578,541 pilots in the United States in 2008 . 22 According to GAMA , in 2008 , the number of active single - engine piston - powered aircraft was 144,220 and the number of active twin - engine piston - powered aircraft was 18,385 . In2008, 1,791 new piston - engine aircraft were manufactured in the U.S. FAA’s Office of Air Traffic provides a complete listing of operational airport facilities in the National Airspace S ystem Resources (NASR) database. 23 In 2008, there were 19,896 airport facilities in the U.S., the vast majority of which are expected to have activity by piston - engine aircraft that operat e on leaded avgas. FAA’s National Plan of Integrated Airport Sy stems identifies approximately

3,400 airports that are significant to national air transportation. 

### C . Background on the Petition and EPA’s Response In a 2003 letter to the EPA, FOE initially raised the issue of the potential for endangerment caused or contributed to by lead emissions from the use of leaded avgas. 24 In 2006, FOE filed a petition with EPA requesting that the Administrator find endangerment or, if there was insufficient information to find endangerment, commence a study of lead emissions from piston - engine aircraft. In 2007, the EPA issued a Federal Register notice on the petition

21 General Accounting Office Report to Congressional Requesters (2001) General Aviation Status of the Industry, Related Infrastructure, and Safety Issues. GAO - 01 - 916. 22 General Aviation Manufacturers Association (2008) General Aviation Statistical Databook and Industry Outlook, pp.51 - 55. Retrieved on August 17, 2009 from: http://www.gama.aero/files/2008_general_aviation_statistical_databook__indust_499b0dc37b.pdf 23 An electronic report can be generated from the NASR database and is available for dow nload from the internet at the following website. . http://www.faa.gov/airports _airtraffic/airports/airport_safety/airportdata_5010/ This database is updated every 56 days. 24 FOE letter dated December 12, 2003 submitted to EPA Docket EPA - HQ - OAR - 2002 - 0030.DRAFT March 16, 2010

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requesting comments and information related to a wide range of issues regarding the use of leaded avgas and potential public health and welfare exposure issues. 25 We sought comments regarding exposure to lead from avgas combustion, emissions of lead, fuel options, and piston engine technology . The comments received to date are publicl y availab le in the docket (EPA HQ - OAR - 2007 - 0294). The majority of comments received concerned the nature of the industry and fuel suppl y issues. The commenters did not supply information regarding health or exposure issues. In2008, the EPA initiated a lead stud y which will improve the manner in which EPA models emissions from piston - engine aircraft. This study is described in further detail in Section VIof this document. At the time we received FOE’s petition, the EPA was in the process of a full re - evaluatio n of the science supporting the lead NAAQS. Information from that re evaluation and the relationship between the new lead standard and the emissions of lead from piston - engine aircraft are discussed in this ANPR. 

### D. Statutory Authority

1. Background Section 231 of the CAA sets forth EPA’s authority to regulate aircraft emissions of air pollution. As described further in Section I. D .2 of this ANPR, Section 231(a)(2)(A) requires EPA to, from time to time, issue proposed emission standards applicabl e to the emission of any air pollutant from an y class or classes of aircraft engines which, in the Administrator’s judgment, cause or contribute to air pollution which may reasonably

be anticipated to endanger public

25 See “Petition Requesting Rulemaking To Limit Lead Emissions from General Avi ation Aircraft; Request for Comments” 72 FR 64570 (Nov. 16, 2007).DRAFT March 16, 2010

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health or welfare. EPA has broad autho rity in exercising its judgment regarding whether emissions from certain sources cause or contribute to air pollution which may reasonably

be anticipated to endanger public health or welfare. 26 EPA has discussed its “endangerment finding” authority

at length in recent notices for greenhouse gases published in the Federal Register, and we refer readers to those notices for detailed discussions of the anal yt ical and legal framework. 27 In 1976, EPA listed lead under CAA section 108, making it what is called a “criteria pollutant.” As part of the listing decision, EPA determined that lead was an air pollutant which, in the Administrator’s judgment, has an adverse effect on public health or welfare under then s ection 108(a). Once lead was listed, EPA issued primary and secondary NAAQS that the Administrator determined were requisite to protect public health with an adequate margin of safet y and to protect public welfare from an y known or anticipated adverse effects. Section 109(b)(1) and (2). As discussed elsewhere in this notice, EPA issued the first NAAQS for lead in 1978, and recently

revised the lead NAAQS by reducing the level of the standard from 1.5  g/m 3 to 0.15  g/m 3 , measured over a 3 - month averaging period. These actions are part of the context for the issues before EPA under section 231(a). The first part of the endangerment test concerns identification of air pollution which may reasonabl y be anticipated to endanger public health or welfare. The CAA defines both “air

26 See, e.g., Ethyl Corp. v. EPA , 541 F.2d 1, 6 (D.C. Cir.), cert. denied 426 U.S. 941 (1976); see also Massachusetts v. EPA , 549 U.S. 497, 506, n.7 (2007). 27 See , “Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act; Final Rule,” 74 FR 66496, 66505 (Dec. 15, 2009); see also, “Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act,” 74 FR 18886, 18890 - 94 (April 24, 2009); see also “Regulating Greenhouse Gas Emissions Under the Clean Air Act; Ad vance Notice of Proposed Rule ma king ,” 73 FR 44354, 44421 - 23 (July 30, 2008).DRAFT March 16, 2010

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pollutant” and “welfare.” Air pollutant is defined in CAA section 302(g) as: “Any air pollution agent or combination of such agents, including an y physical, chemical, biological, radioactiv e (including source material, special nuclear material, and by product material) substance or matter which is emitted into or otherwise enters the ambient air. Such term includes any precursors to the formation of an y air pollutant, to the extent the Admin istrator has identified such precursor or precursors for the particular purpose for which the term ‘air pollutant’ is used.” Lead fits within this capacious definition, and has long been regulated as an air pollutant b y EPA under the CAA (see Section I. E . of this ANPR). There is no definition of public health in the CAA. The U.S. Supreme Court has discussed the concept in the context of whether costs can be considered when setting NAAQS. Whitman v. American Trucking Ass’n , 531 U.S. 457 (2001). In Wh itman , the Court imbued the term with its most natural meaning: “the health of the public.” Id ., at 466. When considering public health, EPA has looked at morbidity , including acute and chronic health effects, as well as mortality . EPA has long regulate d emissions of lead air pollution due to their adverse impacts on public health (see section I . E . of this ANPR). Exposure to lead causes “a broad array of deleterious effects on multiple organ s ys tems,” among children and adults (AQCD for Lead, p.8 - 24 an d Section 8.4.1). Of particular concern are the neurotoxic effects of lead in y oung children. 28 See Section II of this ANPR for a more complete overview of the public health effects of lead. Regarding “welfare,” CAA section 302(h) states that “[a]ll language referring to effects on welfare includes, but is not limited to, effects on soils, water, crops, vegetation, man - made

28 See “National Ambient Air Quality Standards for Lead” 73 FR 66970 - 67007 (Nov. 12, 2008)DRAFT March 16, 2010

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materials, animals, wildlife, weather, visibility , and climate, damage to and deterioration of propert y, and hazards to transportatio n, as well as effects on economic values and on personal comfort and well - being, whether caused b y transformation, conversion, or combination with other air pollutants.” This definition is quite broad, and may include effects other than those listed here as effects on welfare. Welfare effects caused by lead have been evaluated b y EPA and were the basis for establishing the secondary lead standard. 29 By instructing the Administrator to consider whether emissions of an air pollutant cause or contribute to air pollution, the statute is clear that she need not find that emissions from any one sector or group of sources are the sole or even the major part of an air pollution problem. Moreover, section 231(a) does not contain a modifier on its use of the term contribute. Unlike some other CAA provisions, it does not require “significant” contribution. 30 Congress made it clear that the Administrator is to exercise her judgment in determining contribution, and authorized regulatory

controls to address air pollut ion even if the air pollution problem results from a wide variet y of sources. T he cause or contribute test is designed to authorize EPA to identify and then address what may well be man y different sectors or groups of sources that are each part of an air pollution problem. S ection 231(a)(2) refers to contribution and does not specify that the contribution must be significant before an affirmative finding can be made. A ny finding of a “contribution” requires some threshold to be met; a truly trivial or de minimis “contribution” might not count as such. In the past, the Administrator has evaluated the emissions of the source or sources in different way s, based on the particular circumstances involved. I n some mobile source rulemakings, the 29 See “National Ambient Air Quality Standards for Lead” 73 FR 67007 - 67012 (Nov. 12, 2008). 30 See, e.g., CAA sections 111(b); 213(a)(2), (4).DRAFT March 16, 2010

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Administrator h as used the percent of emissions from the regulated mobile source category compared to the total mobile source inventory for that air pollutant as the best way to evaluate contribution. 31 Inother instances the Administrator has looked at the percent of em issions compared to the total nonattainment area inventory of the air pollution at issue. 32 EPA has found that air pollutant emissions that amount to 1.2 percent of the total inventory met the statutory test for contribut ion, triggering EPA’s regulatory authority . 33 2. Regulatory Authority for Emission Standards Section 231 of the CAA sets forth EPA’s authority to regulate aircraft emissions of air pollution. Section 231(a)(2)(A) requires EPA to, from time to time, issue proposed emission standards appli cable to the emission of an y air pollutant from an y class or classes of aircraft engines which, in the Administrator’s judgment, cause or contribute to air pollution which may reasonabl y be anticipated to endanger public health or welfare. Section 231(a)( 2)(B)(i) directs EPA to consult with FAA on aircraft engine emission standards, and section 231(a)(2)(B)(ii) provides that EPA shall not change the aircraft engine emission standards if such change would significantl y increase noise and adversel y affect sa fety . Section 231(a)(3) directs EPA to issue final regulations with such modifications as the Administrator “deems appropriate.” In setting or revising standards, section 231(b) provides that EPA shall have them take effect after such period as EPA fin ds necessary (after consultation with the Secretary of

31 See, e.g., 66 FR 5001 (January 18, 2001) (heavy duty engine and diesel sulfur rule). 32 See, e.g., 67 FR 68242 (November 8, 2002) (snowmobile rule). 33 Bluew ater Netw ork v. EPA , 370 F.3d 1, 15 (D.C. Cir. 2004) (For Fairbanks, this contribution w as equivalent to 1.2 percent of the total daily CO inventory for 2001).DRAFT March 16, 2010

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Transportation) to permit the development and application of the requisite technology , giving appropriate consideration to the cost of compliance within such period. Section 231(c) then states that EP A’s regulations regarding aircraft shall not apply if disapproved by

the President, after notice and opportunity for public hearing, on the basis of a finding by DOT that such regulations would create a hazard to aircraft safet y. Section 232 directs DOT t o issue and implement regulations to insure compliance with EPA’s standards, while section 233 pre - empts states and local governments from adopting or enforcing an y aircraft emission standards that are not identical to EPA’s standards. In recently

reviewi ng this statutory

scheme, the U.S. Court of Appeals for the District of Columbia Circuit ruled that it constitutes a “both explicit and extraordinarily broad” delegation of “expansive authorit y to EPA to enact appropriate regulations applicable to the emis sions of air pollutants from aircraft engines.” 34 3. Regulatory Authority for Fuel Standards Section 211(c) of the CAA allows EPA to regulate fuels used in motor vehicles and nonroad vehicles or engines where emission products of the fuel either: (1) ca use or contribute to air pollution that reasonably may be anticipated to endanger public health or welfare, or (2) will impair to a significant degree the performance of any emission control device or s ys tem which is in general use, or which the Administrator finds has been developed to a point where in a reasonable time it will be in general use were such a regulation to be promulgated. This section of the CAA was used to eliminate lead from fuel used in motor vehicles. EPA’s authority to

34 NACAA v. EPA , 489 F.3d 1221, 1229 - 30 (D.C. Cir. 2007).DRAFT March 16, 2010

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regulate fuels is limited to those fuels used in motor vehicles, motor vehicle engines, or nonroad engines or vehicles, under CAA section 211(c)(1). The CAA defines “motor vehicle,” “nonroad engine,” and “nonroad vehicle” in section 216 for purposes of part A of title I I of the CAA. Part A is also where the authority to regulate fuels under section 211 resides. However, EPA’s authority to regulate aircraft resides in part B of title II, and therefore the definitions of section 216 do not apply

to aircraft. This means that aircraft are not “nonroad vehicles,” and aircraft engines are not “nonroad engines.” Consequentl y, EPA’s authority to regulate fuels under section 211 does not extend to fuels used exclusively in aircraft, such as leaded avgas, that are not also used in motor vehicles or nonroad vehicles or engines (excluding fuel used in vehicles exclusively). Instead, fuels used exclusively in aircraft engines are to be regulated b y the FAA. Title 49 (49 U.S.C. 44714) requires that “the Administrator of the Federa l Aviation Administration shall prescribe (1) standards for the composition or chemical or ph ys ical properties of an aircraft fuel or fuel additive to control or eliminate aircraft emissions the Administrator of the Environmental Protection Agency decides under section 231 of the Clean Air Act (42 U.S.C. 7571) endanger the public health or welfare; and (2) regulations providing for carry ing out and enforcing those standards.” 

### E . Federal Actions to Reduce Lead Exposure The U.S. has made tremendous progress in reducing lead concentrations in the outdoor air. Nationwide, average concentrations of lead in the air have dropped 91 percent between 1980DRAFT March 16, 2010

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and 2008. 35 Much of this dramatic improvement occurred as a result of the permanent phase - out of lead i n motor vehicle gasoline discussed in this section of the ANPR. However, lead continues to be emitted into the air from man y different t ypes of stationary sources and piston engine aircraft as well as certain high performance engines such as race cars . F ederal programs provide for nationwide reductions in emissions of lead and other air pollutants through several provisions in the CAA. Inthe early 1970s, EPA issued regulations regarding lead in gasoline in order to accomplish two purposes. 36 First, EPA issued regulations designed to ensure the availability of unleaded gasoline for use in motor vehicles equipped with emission control sy stems such as cataly tic converters. EPA had determined that lead additives would impair to a significant degree the perf ormance of emission control sy stems. Second, EPA issued regulations designed to graduall y reduce the content of lead in leaded gasoline, because EPA found that lead emissions from motor vehicles presented a significant risk of harm to the health of urban population group s, especially children . Children are at a sensitive life stage with regard to the adverse health effects of lead . In 1985, EPA, noting the significant reduction in adverse health effects, mainly among pre - school age children, that would r esult from reductions in lead content in gasoline, promulgated additional regulations to decrease the allowable concentration of lead in gasoline for motor vehicles to 0.10 grams per gallon. 37 In1990 Congress added section 211(n) to the CAA which provides that after December 31, 1995, it shall be unlawful to sell an y gasoline for use in an y motor vehicle which contains lead or lead additives. In 1996, EPA incorporated the CAA statutory ban on gasoline containing lead or lead additives for highway

use into the Agency ’s existing regulations on the lead content of

35 See http://www.epa.gov/airtrends/lead.html 36 “Regulation of Fuels and Fuel Additives” 38 FR 1254 (Dec. 4, 1973) 37 “Regulation of Fuels and Fuel Additives; Gasoline Lead Content” 50 FR 9386 (March 7, 1985)DRAFT March 16, 2010

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gasoline. 38 In this regulation, it was noted that the petroleum industry may continue to make and market gasoline produced with lead additives for all remaining uses, including use as fuel in aircra ft, racing cars, and nonroad engines such as farm equipment engines and marine engines, to the extent otherwise allowed b y law. 39 In fact, there have been no regulatory limits placed on the production and consumption of leaded avgas, and, as noted in Secti on I .A of this ANPR, emissions of lead from piston - engine aircraft account for an increasing fraction of the lead emissions to air (e.g., accounting for approximately

half the national inventory of lead emission in 2005). This is in spite of the decrease in the suppl y of leaded avgas nationall y from 374 million gallons (875 tons of lead) in 1990 to 235 million gallons (550 tons of lead) in 2008. 40 The decrease in fuel consumption is attributed to the decrease in piston - engine aircraft activity over that ti me period and not due to a shift to unleaded fuel. There are over 200,000 piston - engine aircraft in the U.S. that continue to consume leaded avgas and approximately 2,000 new piston - engine aircraft requiring leaded avgas are manufactured annually . Projec ted growth for this industry is discussed in Section III.B. Significant reductions in emission of lead from stationary sources have been achieved between 1985 and 2002, totaling almost 2,000 tons of lead. 41 Regulations promulgated in 1995, 1997 and 1999 controlled emissions of lead from primary and secondary

lead smelters,

38 “ Prohibition on Gasoline Containing Lead or Lead Additives for Highway Use” 61 FR 3832 (Feb. 2, 1996) 39 “ Prohibition on Gasoline Containing Lead or Lead Additives for Highway Use” 61 FR 3834 (Feb. 2, 1996) 40 These fuel volume estimates are from the Depart m ent of Energy Information Administration. http://tonto.eia.doe.gov/dnav/pet/hist/mgaupus1A.htm 41 U.S. Environmental Protection Agency (2008) EPA’s Report on the Environment EPA/600/ R - 07/045F. Available at: http://www.epa.gov/roe/DRAFT March 16, 2010

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contributing to these reductions. 42 , 43 , 44 Currentl y, metal industry emissions of lead comprise 23% of the national inventory ( 298 tons ) . Additional reductions in the emission of lead have been accomplished through controls on waste incineration and other stationary sources. 45 , 46 , 47 These standards have been set at “maximum achievable control technology” (MACT) levels, and under CAA sections 112 and 129 EPA must revisit these standards in the future to determine whether they

are sufficiently

stringent to provide an ample margin of safety to protect public health and prevent an adverse environmental effect. As lead is a multimedia pollutant, a broad range of Federal programs bey ond thos e that focus on air pollution control provide for nationwide reductions in environmental releases and human exposures. In addition, the U.S. Centers for Disease Control and Prevention (CDC) programs provide for the tracking of children’s blood lead levels nationall y and provide guidance on levels at which medical and environmental case management activities should be implemented. 48 , 49 In1991, the Secretary of the U.S. Department of Health and Human Services (HHS) characterized lead poisoning as the “number one environmental threat to the health of

42 “National Emission Standards for Hazardous Air Pollutants From Secondary Lead Smelting ” 60 FR 32587 (June 23, 1995) 43 “National Emission Standards for Hazardous Air Pollutants From Secondary Lead Smelting ” 62 FR 32209 (June 13, 1997) 44 “National Emission Standards for Hazardous Air Pollutants for Primary Lead Smelting ” 64 FR 30194 (June 4, 1999) 45 “ Standards of Performance for New Stationary Sources and Em ission Guidelines for Existing Sources: Municipal Waste Combustors ” 60 FR 65387 (Dec. 19, 1995) 46 “ Emission Guidelines for Existing Sources and Standards of Performance for New Stationary Sources ” 62 FR 45124 (Aug. 25, 1997) 47 “ Standards of Performance fo r New Stationary Sources and Emission Guidelines for Existing Sources: Large Municipal Waste Combustors ” 71 FR 27324 - 27348 (May 10, 2006) 48 Centers for Disease Control and Prevention (2005) Preventing lead poisoning in young children: a statement by the Centers for Disease Control and Prevention. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service. August. 49 Advisory Committee on Childhood Lead Poisoning Prevention (2007) Interpreting and managing blood lead levels < 10 μg/dL in children and reducing childhood exposures to lead: Recommendations of CDC’s Advisory Committee on Childhood Lead Poisoning Prevention. Morbidity and Mortality Weekly Report. 56(RR - 8). November 2, 2007.DRAFT March 16, 2010

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children in the United States.” 50 In1997, President Clinton created, by Executive Order 13045, the President’s Task Force on Environmental Health Risks and Safety Risks to Children in response to increased awaren ess that children face disproportionate risks from environmental health and safet y hazards (62 FR 19885). 51 By Executive Orders issued in October 2001 and April 2003, President Bush extended the work for the Task Force for an additional three and a half y e ars bey ond its original charter (66 FR 52013 and 68 FR 19931). The Task Force set a Federal goal of eliminating childhood lead poisoning b y the ye ar 2010 , and reducing lead poisoning in children was identified as the Task Force’s top priority . Federal abatement programs provide for the reduction in human exposures and environmental releases from in - place materials containing lead (e.g., lead - based paint, urban soil and dust, and contaminated waste sites). Federal regulations on disposal of lead - based p aint waste help facilitate the removal of lead - based paint from residences (68 FR 36487). Further, in 1991, EPA lowered the maximum levels of lead permitted in public water sy stems from 50 parts per billion (ppb) to 15 ppb measured at the consumer’s tap ( 56 FR 26460). Federal programs to reduce exposure to lead in paint, dust, and soil are specified under the comprehensive federal regulatory framework developed under the Residential Lead - Based Paint Hazard Reduction Act (Title X). Under Title X and Title IV of the Toxic Substances Control Act (TSCA), EPA has established regulations and associated programs with the goal of reducing exposure to lead via lead - based paint. For example, under Title IV of TSCA, EPA established standards identify ing hazardous l evels of lead in residential paint, dust, and soil in 50 Alliance to End Childhood Lead Poisoni ng ( 1991 ) The First Comprehensive National Conference; Final Report. October 6, 7, 8, 1991 51 Co - chaired by the Secretary of the HHS and the Administrator of the EPA, the Task Force consisted of representatives from 16 Federal departments and agencies.DRAFT March 16, 2010

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2001. On March 31, 2008, the Agency issued a new rule (73 FR 21692) to further protect children from lead - based paint hazards resulting from renovation and repair work occurring in housing in which the y live . Programs associated with the Comprehensive Environmental Response, Compensation, and L iability

Act (CERCLA or Superfund) and Resource Conservation Recovery Act (RCRA) also implement abatement programs, reducing exposures to lead and other pollut ants. For example, EPA determines and implements protective levels for lead in soil at Superfund sites and RCRA corrective action facilities. Federal programs, including those implementing RCRA, provide for management of hazardous substances in hazardous and municipal solid waste. 52 Federal regulations concerning batteries in municipal solid waste control the collection and recy cling or proper disposal of batteries containing lead. 53 Similarly , Federal programs provide for the reduction in environmental r eleases of hazardous substances such as lead in the management of wastewater. 54 A variet y of federal nonregulatory programs also provide for reduced environmental release of lead - containing materials through voluntary measures and more general encouragemen t of pollution prevention, promotion of reuse and recy cling, reduction of priorit y and toxic chemicals in products and waste, and conservation of energy and materials. These include the voluntary

partnership between EPA and the National Association for St ock Car Auto Racing (NASCAR) which has achieved the goal of removing alky l lead (organic forms of lead)

52 Se e, e.g., 66 FR 58258. 53 See, e.g., “Implementation of the Mercury - Containing and Rechargeable Battery Management Act” http://www.epa.gov/epaoswer/hazwaste/recycle/battery.pdf and “Municipal Solid Waste Generation, Recycling, and Disposal in the United Stat es: Facts and Figures for 2005” http://www.epa.gov/epaoswer/osw / conserve/resources/msw - 2005.pdf. 54 http://www.epa.gov/owm/DRAFT March 16, 2010

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from racing fuels used in the Nextel Cup, Busch and Craftsman Truck Series. 55 Other programs include the Resource Conservation Challenge, 56 the National Waste Minimization Program, 57 “Plug in to eCy cling” (a partnership between EPA and consumer electronics manufacturers and retailers), 58 and activities to reduce the practice of back yard trash burning. 59 In addition to the lead control programs summarized above, EPA’s research program, with other Federal agencies, identifies, encourages and conducts research needed to locate and assess serious risks and to develop methods and tools to characterize and help reduce risks. For example, EPA’s Integrated Exposure Uptake Biokinetic Model for Lead in Children (IEUBK model) and the Adult Lead Methodology are widely

used and accepted as tools that provide guidance in evaluating site specific data. More recently , in recognition of the need for a single model that pr edicts lead concentrations in tissues for children and adults, EPA is developing the All Ages Lead Model (AAL M) to provide researchers and risk assessors with a pharmacokinetic model capable of estimating blood, tissue, and bone concentrations of lead base d on estimates of exposure over the lifetime of the individual. EPA research activities on substances including lead focus on better characterizing aspects of health and environmental effects, exposure, and control or management of environmental releases. 60

55 U.S. Environmental Protection Agency Persistent, Bioaccumulative, and Toxic Pollutants (PBT) Program (2002) PBT national action plan for alkyl - Pb. Washington, DC. Available online at: http://www.epa.gov/pbt/pubs/A lkyl_lead_action_plan_final.pdf 56 http://www.epa.gov/epawaste/rcc/index.htm 57 http://www.epa.gov/epawaste/hazard/wastemin/ 58 http://www.epa.gov/epawaste/partnerships/plugin/index.htm 59 http://www.epa.gov/epawaste /nonhaz/municipal/backyard/index.htm 60 http://www.epa.gov/ord/DRAFT March 16, 2010

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## II. Health and We lfar e Effects of Lead A. Multim edia and Multi - Pathway Exposure Considerations This section briefl y summarizes the information presented in the 2008 NAAQS for Lead, 61 the 2007 Lead Staff Paper 62 and the 2006 Air Quality Criteria Document for Lead (AQCD for Lead). 63 Lead is an unusual pollutant in that the distribution of lead to different environmental media (e.g., air, soil, water) is important for evaluating public health and welfare effects. Lead emitted to the air can result in exposure via multiple pathways (e.g., inhalation, ingestion, dermal absorption). Some key multimedia and multi - pathway considerations for lead include the following: (1) Lead is emitted into the air from man y sources encompassing a wide variety of stationary and mobile source t ypes. Lead emitted to the air is predominantly in particulate form, with the particles occurring in various sizes. Once emitted, the particles can be transported long or short distances depend ing on their size, which influences the amount of time spent in the aerosol phase. In general, larger particles tend to deposit more quickly , within shorter distances from emissions points (e.g., kilometers) , while smaller particles will remain in the aer osol phase and travel longer distances before depositing (e.g., hundreds to thousands of kilometers) . 64 As

61 National Ambient Air Quality Standards for Lead 73 FR 66970 - 67007 (Nov. 12, 2008) Section II.A. 62 U.S. Environmental Protection Agency Review of the National Ambient Air Quality Standards for Lead: Policy Assessment of Scientific and Technical Information OAQPS Staff Paper ( 2007) Chapter 2. EPA - 452/R - 07 - 013 November. 63 U.S. Environmental Protection Agency Air Quality Criteria for Lead (2006) Volume I: Chapters 2 & 3. EPA/600/R - 5/144aF. October. 64 U.S. Environmental Protection Agency (2004) Air quality criteria for particulate matter. Research Triangle Park, NC: Office of Research and Development, National Center for Environmental As sessment ; EPA report no. EPA 600/ P - 99 / 0 028aF.DRAFT March 16, 2010

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summarized in the AQCD for Lead, airborne concentrations of lead at sites near sources are much higher than at sites not known to be directl y influen ced b y sources. (2) Once deposited to surfaces, lead can subsequently be resuspended into the ambient air and, because of the persistence of lead, emissions of this metal contribute to environmental media concentrations for many y ears into the future as it is cy cled within and between environmental media such as soil , air and water . Lead that is a soil or dust contaminant today may have been airborne y esterday or many y ears ago. 65 (3) Exposure to lead emitted into the ambient air can occur directl y b y inhalation, or indirectly by ingestion of lead - contaminated food, water or other materials including dust and soil. This occurs due to the environmental cy cling of this persistent metal which, once emitted into the ambient air is distributed to other envi ronmental media and can contribute to human exposures via indoor and outdoor dusts, outdoor soil, food and drinking water, as well as inhalation of air. Atmospheric deposition is estimated to comprise a significant proportion of lead in food (AQCD for Lea d, p. 3

–48). For example, livestock may be exposed to lead in vegetation (e.g., grasses and silage) and in surface soils via incidental ingestion of soil while grazing (USEPA 1986, Section 7.2.2.2.2). 66 And dietary intake may

be a predominant source of le ad exposure among adults, greater than consumption of water and beverages or inhalation (73 FR 66971). These exposure pathway s are described more full y in Section 8.2.2 of the AQCD for Lead.

65 National Ambient Air Quality Standards for Lead 73 FR 66971 (Nov. 12, 2008) , AQC for Lead, Section 2.5. 66 U. S. Environmental Protection Agency (1986) Air quality criteria for lead. Research Triangle Park, NC: Office of Health and Environmental Assessment, Environmental Criteria and Assessment Office; EPA report no. EPA - 600/8 - 83/028aF - dF. 4v. Available from: NTIS , Springfield, VA; PB87 - 142378.DRAFT March 16, 2010

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(4) Air - related exposure pathway s are affected by changes to ai r quality , including changes in concentrations of lead in air and changes in atmospheric deposition of lead. Further, because of its persistence in the environment, lead deposited from the air may contribute to human and ecological exposures for ye ars int o the future as described above . Additionally , human exposures to lead include pathway s that are not related to ambient air concentrations. The pathway s of human exposure to lead that are not air - related include ingestion of indoor lead paint, 67 lea d in diet as a result of inadvertent additions during food processing, and lead in drinking water attributable to lead in distribution sy stems, as well as other generall y less prevalent pathways, as described in the AQCD for Lead (pp. 3 - 50 to 3 - 51). 

### B. He alth Effects Inform ation In 2008, EPA decreased the level of the primary (health - based) NAAQS for L ead from 1.5  g/m 3 to 0.15  g/m 3 in order to provide increased protection for children and other at - risk populations against an array of adverse health effects, most notably neurological effects in children, including neurocognitive and neurobehavioral effects. 68 This section summarizes information provided in the numerous recent documents summarizing health and welfare effects from exposure to lead, including the AQCD for Lead, CDC documents, the EPA Staff Paper 69 and the proposed and final NAAQS for Lead. First, the use of blood lead a s a measure of exposure to lead is described followed b y a brief summary of the broad array of lead - induced

67 Weathering of outdoor lead paint may also contribute to soil lead levels adjacent to the house . 68 National Ambient Air Quality Standards for Lead 73 FR 66965 (Nov. 12, 2008). 69 U.S. Environmental Protection Agency (200 7 ) Review of the National Ambient Air Quality Standards for Lead : Policy Assessment of Scientific and Technical Information, OAQPS Staff Paper. EPA - 452/R - 07 - 013. Office of Air Quality Planning and Standards, Research Triangle Park.DRAFT March 16, 2010

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health effects. Particular focus is given here to the effects of lead on the developing nervous sy stem in children since this is among the most se nsitive endpoints identified for this toxic metal. The section ends with a description of at - risk populations and life stages. 1. Blood Lead Lead enters the bod y most commonly via the respiratory sy stem and

/or gastrointestinal tract, from which it is quickly absorbed into the blood stream and distributed throughout the body . 70 Less commonly, lead, particularl y organic forms of lead such as ak yl lead, can be absorbed through the skin (AQCD for Lead, page 4 - 12). Blood lead levels are extensivel y used as an index or biomarker of exposure by national and international health agencies, as well as in epidemiological (AQCD for Lead, Sections 4.3.1.3 and 8.3.2) and toxicological studies of lead health effects and dose - response relationships (AQCD for Lead, Cha pter 5). The U.S. CDC, and its predecessor agencies, ha s for man y ye ars used blood lead level as a metric for identify ing children at risk of adverse health effects and for specify ing particular public health recommendations. 71 Most recentl y, in 2005, w ith consideration of a review of the evidence by their advisory

committee, CDC revised their statement on Preventing Lead Poisoning in Young Children. 72 CDC specifically recognized the evidence of adverse health effects in children with

70 Additionally, lead free ly crosses the placenta resulting in continued fetal exposure throughout pregnancy, with that exposure increasing during the latter half of pregnancy ( AQC for Lead , S ection 6.6.2). 71 Centers for Disease Control (1991) Preventing lead poisoning in young childr en: a statement by the Center s for Disease Control. Atlanta, GA: U.S. Department of H ealth and Human Services, Public Health Service; October 1. Available online at: http://wonde r.cdc.gov/w onder/prevguid/p0000029/p0000029.asp 72 Centers for Disease Control and Prevention (2005) Preventing lead poisoning in young children: a statement by the Centers for Disease Control and Prevention. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service. August.DRAFT March 16, 2010

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blood lead levels b elow 10 μg/dL, 73 the data demonstrating that no “safe” threshold for blood lead had been identified, and emphasized the importance of preventative measures. 74 Since 1976, the CDC has been monitoring blood lead levels in multiple age groups nationally through the National Health and Nutrition Examination Survey (NHANES). 75 The NHANES information has documented the dramatic decline in mean blood lead levels in the U.S. population that has occurred since the 1970s and that coincides with regulations regar ding leaded motor vehicle fuels, leaded paint, and lead containing plumbing materials that have reduced lead exposure among the general population (AQCD for Lead, Sections 4.3.1.3 and 8.3.3). While blood lead levels in the U.S. general population, including geometric mean levels in children aged 1 - 5 have declined significantl y, levels have been found to vary among children of different socioeconomic status (SES) and other demographic characteristics (AQCD for Lead, p. 4 - 21), as well as by

age. 76 Rac ial/ethnic and income disparities in blood lead levels in children persist. For example, blood lead levels for lower income and African American children are higher than those for the general population.

73 As described by the Advisory Committee on Childhood Lead Poisoning Prevention, “In 1991, CDC defined the blood lead level (BLL) that should prompt public health actions as 10 μg/d L. Concurrently, CDC also recogn ized that a BLL of 10 μg/d L did not define a threshold for the harmful effects of lead. Research conducted since 1991 has strengthened the evidence that children’s physical and mental development can be affected at BLLS <10 μg/d L” (ACCLPP, 2007). 74 Adviso ry

Committee on Childhood Lead Poisoning Prevention (2007) Interpreting and managing blood lead levels <10 μg/dL in children and reducing childhood exposures to lead: Recommendations of CDC’s Advisory Committee on Childhood Lead Poisoning Prevention. Mor bidity and Mortality Weekly Report. 56(RR - 8). November 2, 2007. 75 This information documents a variation in mean blood lead levels across the various age groups monitored. For example, mean blood lead levels in 2001 - 2002 for ages 1 - 5, 6 - 11, 12 - 19 and grea ter than or equal to 20 years of age, are 1.70, 1.25, 0.94, and 1.56 μg/dL , respectively ( AQC for Lead , p. 4 - 22). 76 Axelrad, D. , U.S. EPA (November 4, 2009 ) E - mail message to Marion Hoyer, U.S. EPA. Available in d ocket number EPA - HQ - OA R - 2007 - 0294.DRAFT March 16, 2010

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The spectrum of health effects discussed in the following section is relevant for all forms of lead that enter the blood stream. Once in the blood stream, lead bioaccumulates in the body , with the bone serving as a large, long - term storage compartment. Soft tissues (e.g., kidney , liver, brain, etc.) s erve as smaller compartments, in which lead may be more mobile (AQCD for Lead, Sections 4.3.1.4 and 8.3.1). During childhood development, bone represents approximately 70% of a child’s bod y burden of lead, and this accumulation continues through adulthood , when more than 90% of the total lead body burden is stored in the bone (AQCD for Lead, Section 4.2.2). Lead in bone can be mobilized during critical periods including pregnancy and lactation (AQCD for Lead, Section 5.8.6). 2. Health Effects Lead, as with mercury

and arsenic, has no known biological function. 77 Lead has been demonstrated to exert “a broad array of deleterious effects on multiple organ sy stems via widel y diverse mechanisms of action” (AQCD for Lead, p. 8 - 24 and Section 8.4.1). This arr ay of health effects includes effects on heme biosy nthesis and related functions; neurological development and function; reproduction and phy sical development; kidney function; cardiovascular function; and immune function. The weight of evidence varies ac ross this array of effects and is comprehensivel y described in the AQCD for Lead. There is also some evidence of lead carcinogenicity , primarily from animal studies, together with limited human evidence of suggestive associations (AQCD for Lead, Sections 5.6.2, 6.7, and 8.4.10). The U.S. EPA has listed lead under current EPA guidelines as a probable human carcinogen based on the available

77 U.S. Environmental Protection Agency (2007) Framew ork for Metals Risk Assessment. Office of the Science Ad visor. EPA 120/R - 07/001.DRAFT March 16, 2010

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animal data (AQCD for Lead, p. 6 - 195). 78 In organic lead has been classified as a probable human carcinogen b y the Inte rnational Agency for Research on Cancer (inorganic lead compounds), based mainly on sufficient animal evidence, 79 and classified as reasonabl y anticipated to be a human carcinogen b y the U.S. National Toxicology Program (lead and lead compounds) (AQCD for L ead, Section 6.7.2). 80 , 81 As described in the AQCD for Lead, the key effects associated with individual blood lead levels in children and adults in the range of 10 μg/dLand lower include neurological, hematological and immune 82 effects for children, and hem atological, cardiovascular and renal effects for adults (AQCD for Lead, Tables 8 - 5 and 8 - 6, pp. 8 - 60 to 8 - 62). As evident from the discussions in Chapters 5, 6 and 8 of the AQCD for Lead, “neurotoxic effects in children and cardiovascular effects in adult s are among those best substantiated as occurring at blood lead concentrations as low as 5 to 10 μg/dL(or possibly lower); and these categories are currently clearl y of greatest public health concern” (AQCD for Lead, p. 8 - 60). 83 , 84 The AQCD for Lead

78 U.S. Environmental Protection Agency, Integrated Risk Information System (IRIS) (1993) IRIS Summary for Lead and compounds (CASRN 7439 - 92 - 1 ), Available online at: http://www.epa.gov/ncea/iris/subst/0277.htm . 79 International Agency for Research on Cancer (IARC) ( 2006 ) Inorganic and organic lead com pounds. Lyon, France: International Agency for Research on Cancer. IARC monographs on the evaluation of the carcinogenic risk of chemicals to humans: volume 87. Available online at: htt p://monographs.iarc.fr/ENG/Monographs/vol87/index.php . 80 National Toxicology Program (2003) Report on carcinogens background document for lead and lead compounds. Research Triangle Park, NC: U.S. Department of Health and Human Services. Available online at : http://ntp.niehs.nih.gov/ntp/newhomeroc/roc11/Lead - Public.pdf 81 National Toxicology Program. (2004) Lead (CAS no. 7439 - 92 - 1) and lead compounds. In: Report on carcinogens, eleventh edition. Research Triangle Park, NC: U.S. Department of Health and Human Services. Available online at: http://ntp.niehs.nih.gov/ntp/roc/eleventh/profiles/s101lead.pdf. 82 At mean blood lead levels, in children, on the order of 10 μg/dL, and some what lower, associations have been found with effects to the immune system, includi ng altered macrophage activation, increased IgE levels and associated increased risk for autoimmunity and asthma ( AQC for Lead , Sections 5.9, 6.8, and 8.4.6). 83 With regard to blood lead levels in individual children associated w ith particular neurological effects, the AQC for Lead states “Collectively, the prospective cohort and cross - sectional studies offer evidence that exposure to lead affects the intellectual attainment of preschool and school age children at blood lead levels <10 μg/dL (most clearly i n the 5 to 10 μg/dL range, but, less definitively, possibly lower).” (p. 6 - 269) 84 Epidemiological studies have consistently demonstrated associations between lead exposure and enhanced risk of deleterious cardiovascular outcomes, including increased blood pressure and incidence of hypertension. A meta analysis of numerous studies estimates that a doubling of blood - lead level (e.g., from 5 to 10 μg/dL) is associate dDRAFT March 16, 2010

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state s, “There is no level of lead exposure that can y et be identified, with confidence, as clearl y not being associated with some risk of deleterious health effects” (AQCD for Lead, p. 8 - 63). While adults are susceptible to lead effects at lower blood lead levels than previously understood (e.g., AQCD for Lead, p. 8 - 25), among the wide variet y of health endpoints associated with lead exposures, there is general consensus that the developing nervous sy stem in children is among the, if not the, most sensitive. Blood lead levels in U.S. children have decreased notabl y since the late 1970s. Studies evaluating current blood lead levels in children have reported associations with neurodevelopment effects (AQCD for Lead, Chapter 6). Functional manifestations of l ead neurotoxicity during childhood include sensory , motor, cognitive and behavioral impacts. Numerous epidemiological studies have reported neurocognitive, neurobehavioral, sensory , and motor function effects in children with blood lead levels below 10 μg/dL (AQCD Lead, Sections 6.2 and 8.4). Cognitive effects associated with lead exposures that have been observed in epidemiological studies have included decrements in intelligence test results, such as the widel y used IQ score, and in academic achieveme nt as assessed by various standardized tests as well as by class ranking and graduation rates (AQCD for Lead, Section 6.2.16 and pp 8 - 29 to 8 - 30). As noted in the AQCD for Lead with regard to the latter, “Associations between lead exposure and academic ac hievement observed in the above - noted studies were significant even after adjusting for IQ, suggesting that lead - sensitive neurops yc hological processing and learning factors not reflected b y global intelligence indices might contribute to reduced performan ce on academic tasks” (AQCD for Lead, pp 8 - 29 to 8 - 30). with ~1.0 mm Hg increase in systolic blood pressure and ~0.6 mm Hg increase in diastolic pressure (AQC for Lead, p. E - 10) .DRAFT March 16, 2010

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With regard to potential implications of lead effects on I Q, the AQCD for Lead recognizes the “critical” distinction between population and individual risk, identifying issues regarding declines in IQ for an individual and for the population. The AQCD for Lead further states that a “point estimate indicating a modest mean change on a health index at the individual level can have substantial implications at the population level” (AQCD for Lead, p. 8 - 77). 85 A downward shift in the mean IQ value is associated with both substantial decreases in percentages achieving very

high scores and substantial increases in the percentage of individuals achieving very low scores (AQCD for Lead, p. 8 - 81). 86 For an in dividual functioning in the low IQ range due to the influence of developmental risk factors other than lead, a lead - associated IQ decline of several points might be sufficient to drop that individual into the range associated with increased risk of educati onal, vocational, and social failure (AQCD for Lead, p. 8 - 77). Other cognitive effects observed in studies of children have included decrements in attention, executive functions, language, memory , learning and visuospatial processing (AQCD for Lead, Sect ions 5.3.5, 6.2.5 and 8.4.2.1), with attention and executive function effects associated with lead exposures indexed by blood lead levels below 10 μg/dL(AQCD for Lead, Section 6.2.5 and pp. 8 - 30 to 8 - 31). The evidence for the role of lead in this suite o f effects includes experimental animal findings (discussed in the AQCD for Lead, Section 8.4.2.1; p. 8 -

85 As an example, the AQC for Lead states “although an increase of a few mmHg in blood pressure might not be of concern for an ind ividual’s well - being, the same increase in the population mean might be associated with substantial increases in the percentages of individuals with values that are sufficiently extreme that they exceed the criteria used to diagnose hypertension” (AQC for Lead, p. 8 - 77). 86 For example, for a population mean IQ of 100 (and standard deviation of 15), 2.3% of the population w ould score above 130, but a shift of the population to a mean of 95 results in only 0.99% of the population scoring above 130 (AQC for Le ad, pp. 8 - 81 to 8 - 82).DRAFT March 16, 2010

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31), which provide strong biological plausibility of lead effects on learning abilit y, memory and attention (AQCD for Lead, Section 5.3.5), as well as as sociated mechanistic findings. The persistence of such lead - induced effects is described in the AQCD for Lead (e.g., AQCD for Lead Sections 5.3.5, 6.2.11, and 8.5.2). The persistence or irreversibility of such effects can be the result of damage occurring without adequate repair offsets or of the persistence of lead in the bod y (AQCD for Lead, Section 8.5.2). It is additionally important to note that there may be long - term consequences of such deficits over a lifetime. Poor academic skills and achiev ement can have “enduring and important effects on objective parameters of success in real life,” as well as increased risk of antisocial and delinquent behavior (AQCD for Lead, Section 6.2.16). The current evidence reviewed in the AQCD for Lead with regard to the quantitative relationship between neurocognitive decrement, such as IQ, and blood lead levels indicates that the slope for lead effects on IQ is nonlinear and is steeper at lower blood lead levels, such that each μg/dL increase in blood lead may have a greater effect on IQ at lower blood lead levels (e.g., below 10 μg/dL) than at higher levels (AQCD for Lead, Section 6.2.13; pp. 8 - 63 to 8 - 64; Figure 8 - 7). As noted in the AQCD for Lead, a number of examples of non - or supralinear dose response relationships exist in toxicology (AQCD for Lead, pp. 6 - 76 and 8 - 38 to 8 - 39). With regard to the effects of lead on neurodevelopmental outcomes such as IQ, the AQCD for Lead suggests that initial neurodevelopmental effects at lower lead levels may be dis rupting very different biological mechanisms (e.g., early developmental processes in the central nervous sy stem) than more severe effects of high exposures that result in sy mptomatic lead poisoning and frank mental retardation (AQCD for Lead, p. 6 - 76). Th e AQCD for Lead describes this issue inDRAFT March 16, 2010

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detail with regard to lead (summarized in AQCD for Lead at p. 8 - 39). Various findings within the toxicological evidence, presented in the AQCD for Lead, provide biologic plausibility for a steeper IQ loss at low blo od lead levels, with a potential explanation being that the predominant mechanism at very

low blood lead levels is rapidly saturated and that a different, less - rapidly saturated process becomes predominant at blood lead levels greater than 10 μg/dL. 3. At - Risk Populations and Life Stages Individuals potentiall y atrisk from exposure to environmental pollutants include those with increased susceptibility and vulnerability . The terms "susceptibility " and "vulnerability " have been used to characterize tho se with a greater likelihood of an adverse outcome given a specific exposure in comparison with the general population. This increased likelihood of response to a pollutant can result from a multitude of factors, including genetic or developmental factors , life stages (i.e., childhood or old age), gender differences, or preexisting disease states. In addition, new attention has been paid to the concept of some population groups having increased responses to pollution - related effects due to factors includi ng socioeconomic status (SES) (e.g., reduced access to health care, poor nutritional status) or particularly elevated exposure levels. EPA uses the term "life stage" to refer to a distinguishable time frame in an individual's life characterized by

uniqu e and relatively

stable behavioral and/or phy siological characteristics that are associated with development and growth. To recognize the rapid changes that occur during childhood related to phy siology , metabolism, anatomy and behavior that can impact exp osure and risk to environmental hazards, EPA now views childhood as a sequence of lifeDRAFT March 16, 2010

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stages, from conception through fetal development, infancy , and adolescence. EPA published several exposure and risk assessment guidance documents beginning in 2005, 87 88 89 in which we emphasized the importance of considering the potential for increased sensitivity of different life stages or age groups in addition to that of groups that form a fixed portion of the population b ased on characteristics such as pre - existing d isease, gender, socioeconomic status, geographical l ocation, culture/ethnicity , or genetic make - up. Phy siological, behavioral and demographic factors contribute to increased risk of lead related health effects. Children are at increased risk of lead - related health effects due to various factors that enhance their exposures (e.g., via the hand - to - mouth activity that is prevalent in very yo ung children, AQCD for Lead, Section 4.4.3) and susceptibility . While children are considered to be at a period of max imum exposure around 18 - 27 months, the current evidence has found even stronger associations between blood lead levels at school age and IQ at school age. The evidence “supports the idea that lead exposure continues to be toxic to children as they reach s chool age, and [does] not lend support to the interpretation that all the damage is done b y the time the child reaches 2 to 3 y ears of age” (AQCD for Lead, Section 6.2.12). Phy siological factors that can affect risk of lead - related effects in children inc lude genetic poly morphisms and nutritional status. Children with particular genetic poly morphisms (e.g., presence of the δ aminolevulinic acid deh ydratase - 2 [ALAD - 2] allele) have increased sensitivity to lead toxicity , which may

be due to increased suscep tibility to the same internal dose and/or to increased internal dose associated with the same exposure (AQCD for Lead, p. 8 - 71, Sections 6.3.5, 6.4.7.3

87 US EPA (2005) Guidance on Selecting Age Groups for Monitoring and Assessing Childhood Exposure to Environmental Contaminants. EPA/630/P - 03/003F . 88 US EPA (2006) A Frame wo rk for Assessing Health Risks of Environmental Exposures to C hildren. EPA/600/R 05/ 093 A . 89 US EPA (2008) Child - Specific Exposure Factors Handbook. EPA/600/R - 06/096F.DRAFT March 16, 2010

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and 6.3.6). Some children may have blood lead levels higher than those otherwise associated with a give n lead exposure (AQCD for Lead, Section 8.5.3) as a result of nutritional status (e.g., iron deficiency , calcium intake), as well as genetic and other factors (AQCD for Lead, Chapter 4 and Sections 3.4, 5.3.7 and 8.5.3). Demographic factors that can aff ect risk of lead - related effects in children include residential location, poverty , and race. As noted in previous EPA actions on lead, situations of elevated exposure, such as residing near sources of ambient lead, as well as socioeconomic factors, such as reduced access to health care or low socioeconomic status can also contribute to increased blood lead levels and increased risk of associated health effects from air - related lead. 90 Additionally , as described in the NAAQS for Lead, children in povert y and black, non - Hispanic children have notably

higher blood lead levels than do economicall y well - off children and white children, in general. 91 

### C. Welfare Effects Lead is persistent in the environment and accumulates in soils, aquatic sy stems (including sediments), and some biological tissues of plants, animals and other organisms, thereb y providing long - term, multi - pathway exposures to organisms and ecos ys tems. In 2008, EPA established a secondary

lead standard of 0.15 ug/m 3 . This standard is intended to protect the public welfare from known or anticipated adverse effects associated with the presence of lead in

90 U.S. Environmental Protection Agency (200 7 ) Review of the National Ambient Air Quality Standards for Lead : Policy Assessment of Scientific and Technical Information, OAQPS Staff Paper. EPA - 452/R - 07 - 013. Office of Air Quality Planning and Standards, Research Triangle Park. 91 See 73 FR 66973 (November 12, 2008 ).DRAFT March 16, 2010

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the ambient air. This section provides a summary of information regarding welfare effects of lead, focusing on terrestrial and aquatic ecos ys tems. This information is largel y drawn from the 2006 AQCD for Lead, Chapter 6 of the Office of Air Quality Planning and Standards Staff Paper on L ead (SP) 92 and the L ead NAAQS. 1. Terrestrial Ecosystems Lead is removed from the atmosphere and deposited on soil and other surfaces via wet or dry deposition. In soils, most lead is retained via the formation of stable solid phase compounds, precipitates, or complex es with organic matter. Thus, t errestrial ecos ys tems remain primaril y sinks for lead but amounts retained in various soil lay ers vary based on forest ty

pe, climate, and litter cy cling (AQCD for Lead, Section 7.1). Once in the soil, the migration and distribution of lead is controlled b y a multitude of factors including pH, precipitation, litter composition and other factors, which in turn, govern the rate at which lead is bound to organic materials in the soil (AQCD for Lead, Section 2.3.5, and Section AX 7.1.4.1). Lead exists in the environment in different forms which vary widely in their ability

to cause adverse effects on ecos ys tems and organisms. Many forms of lead in the ambient air are quite insoluble and thus not easily leached to underground w ater once deposited to surfaces. However, leaching may

occur under acidic conditions, where lead concentrations are extremel y high, or in the presence of substances (e.g., soluble organic matter, high concentrations of

92 U.S. Environmental Protection Agency (200 7 ) Review of the National Ambient Air Quality Standards for Lead : Policy Assessment of Scientific and Technical Information, OAQPS Staff Paper. EPA - 452/R - 07 - 013. Office of Air Quality Planning and Standards, Research Triangle Park.DRAFT March 16, 2010

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chlorides or sulfates) that form rel ativel y soluble complexes with lead (AQCD for Lead, Section 2.3.5). Plants take up lead via their foliage and through their root s ys tems. The rate of plant uptake from soil varies by plant species, soil conditions, and lead species. Most lead in plants is stored in roots, and very

little is stored in fruits. Metals that are applied to soil as salts (usually as sulfate, chloride, or nitrate salt) are accumulated more readily than the same quantity of metal added via sewage sludge, flue dust, or fl y ash ( AQCD for Lead, Section 2.3.7). Surface deposition of lead onto plants may represent a significant contribution to the total lead in and on the plant, as has been observed for plants near smelters and along roadsides (AQCD for Lead, page E - 19). Atmospheric deposition of lead also contributes to lead in vegetation as a result of contact with above - ground portions of the plant (AQCD for Lead, pp. 7

– 9 and AXZ7

– 39; USEPA, 1986, Sections 6.5.3 and 7.2.2.2.1). Wildlife may subsequently

be exposed to l ead in vegetation (e.g., grasses and silage) and in surface soils via incidental ingestion of soil while grazing (USEPA 1986, Section 7.2.2.2.2). 93 By far, the majorit y of air - related lead found in natural terrestrial ecos ys tems was deposited in the past during the use of lead additives in motor vehicle gasoline. Man y sites receiving lead predominantly through long - range transport of gasoline - derived small particles have accumulated large amounts of lead in soils (AQCD for Lead, p. AX7 - 98). There is litt le evidence that terrestrial sites exposed as a result of this long range transport of lead have

93 U.S. Environmental Pr otection Agency (1986) Air quality C riteria for L ead. Research Triangle Park, NC: Office of Health and Environmental Assessment, Environmental Criteria and Assessment Office; EPA report no. EPA 600/8 - 83/028aF - dF. 4v. Available from: NTIS, Springfield, VA; PB87 - 142378.DRAFT March 16, 2010

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experienced significant effects on ecos ys tem structure or function (AQCD for Lead, Section AX7.1.4.2 and p. AX7 - 98). Strong complexation of lead b y organic matter in soil may explain why few ecological effects have been observed (AQCD for Lead, p. AX7 - 98). Studies have shown decreasing levels of lead in vegetation, which appears to correlate with decreases in atmospheric deposition of lead resulting from the r emoval of lead additives to motor vehicle gasoline (AQCD for Lead, Section AX 7.1.4.2). The deposition of gasoline - derived lead into forest soils has produced a legacy of slow moving lead that remains bound to organic materials despite dramatic reductions in the use of leaded additives to motor vehicle fuels. Current levels of lead in soil vary widely depending on the source of lead but in all ecos ys tems lead concentrations exceed natural background levels. For areas influenced b y point sources of air le ad, concentrations of lead in soil may exceed b y many orders of magnitude the concentrations which are considered harmful to laboratory organisms. Adverse effects in terrestrial organisms associated with lead include neurological, phy siological and behavi oral effects which may influence ecos ys tem structure and functioning (73 FR 67008). 2. Aquatic Ecosystems Atmospheric lead enters aquatic ecosy stems primarily through deposition (wet and dry) and the erosion and runoff of soils containing lead. While ov erall deposition rates of atmospheric lead have decreased dramaticall y since the removal of lead additives from motor vehicle gasoline, lead continues to accumulate and may be re - exposed in sediments and water bodies throughout the United States (AQCD for Lead, Section 2.3.6).DRAFT March 16, 2010

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Several ph ys ical and chemical factors govern the fate and bioavailability of lead in aquatic s ys tems. A significant portion of lead remains bound to suspended particulate matter in the water column and eventually settles into the substrate. Species, pH, salinity , temperature, turbulence and other factors govern the bioavailability of lead in surface waters (AQCD for Lead, Section 7.2.2). Le ad can bioaccumulate in the tissues of aquatic organisms through ingestion of food and water, and adsorption from water, and can subsequently lead to adverse effects if tissue levels are sufficiently high. 94 The accumulation of lead is influenced b y pH and decreasing pH favors bioavailability and bioaccumulation. Organisms that bioaccumulate lead with little excretion must partition the metal such that it has limited bioavailability , otherwise toxicity will occur if a sufficientl y high concentration is reached. 95 The general sy mptoms of lead toxicity

in fish include production of excess mucus, lordosis, anemia, darkenin g of the dorsal tail region, degeneration of the caudal fin, destruction of spinal neurons, aminolevulinic acid deh ydratase (ALAD) inhibition, growth inhibition, renal pathology, reproductive effects, growth inhibition, and mortality . 96 Toxicity in fish ha s been closely

correlated with duration of lead exposure and uptake. 97 Lead exists in the aquatic environment in various forms and under various chemical and phy sical parameters which determine the abilit y of lead to cause adverse effects either from disso lved lead in the water column or lead in sediment. Current levels of lead in water and sediment vary

widel y depending on the source of lead. Conditions exist in which adverse effects to organisms and thereb y ecos ys tems may be anticipated given experiment al results. It is 94 AQC for Lead I. 7 - 24: (Vink, 2002; Rainbow , 1996). 95 AQC for Lead AX7.2.3.1 96 AQC for Lead page 232, Annex 7 97 AQC for Lead page 232, Annex 7DRAFT March 16, 2010

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unlikely that dissolved lead in surface water constitutes a threat to ecosy stems that are not directly influenced by

point sources. For lead in sediment, the evidence regarding the effects is less clear. Itis likel y that some areas wi th long - term historical deposition of lead to sediment from a variety

of sources as well as areas influenced by point sources have the potential for adverse effects to aquatic communities. The long residence time of lead in sediment and its ability to be resuspended by

turbulence make lead likely to be a factor for consideration regarding potential risk to aquatic s ys tems for the foreseeable future (73 FR 67008). 

## III. Lead Emissions fr om Piston - Engine Air craft Currently , lead emitted by piston - engine aircraft operating on leaded avgas is the largest source of lead to the air, contributing about 50% of the National Emission Inventory in 2005. This section describes the draft 2008 avgas lead inventory which is currently

undergoing review by state, local and tribal air agencies. We describe and request comment on input data used to derive airport - specific lead inventories. This section ends with a summary of data forecasting the potential growth of the industry using leaded avgas. 

### A. Inventory of Lead from Piston - Engine Powered Aircraft Every three y ears, the EPA prepares a National Emissions Inventory (NEI) of air emissions of criteria pollutants and hazardous air pollutants with input from numerous state, local, and tribal air agencies and from industry . 98 For the purposes of this ANPR, EPA is

98 http://www.epa.gov/air/data/neidb.htmlDRAFT March 16, 2010

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describing piston - engine aircraft lead information provided in the draft 2008 NEI as well as information from the final 2005 NEI . We have chosen to describe the draft 2008 NEI for the fo llowing reasons: 1) this is the first version of the NEI that will include airport - specific lead inventories that use our most recentl y developed methods for estimating lead (described below); 2) this inventory

is the first NEIto include approximately 20 ,000 airport facilities in the U.S.; and 3) to increase awareness of the opportunity for state, local, and tribal governments and industry to review this draft NEI and provide information that could improve airport lead inventories. Comments and data can be supplied to EPA for the 2008 NEI until mid - 2010. While we are describing the draft 2008 NEI for piston - engine aircraft emissions of lead, we do not have draft inventory

estimates for 2008 for all sources of lead. The 2008 NEI will be final in 2010. 

### 1. National Emissions of Lead from Piston - Engine Aircraft To calculate the national avgas lead inventory , the volume of leaded avgas produced in a given ye ar is multiplied by the concentration of lead in the avgas and by the fraction of lead emitted from a combustion sy stem operating on leaded fuel (to account for the lead that is retained in the engine, engine oil and/or exhaust sy stem). For example, the volume of avgas produced in the U.S. in 2008 according to DOE was 235,326,000 gallons. 99 The concentr ation of lead in avgas ([Pb] in the equation below) can be one of four levels (ranging from 0.14 to 1.12 grams of lead per liter or 0. 53 to 4.24 gram s of lead per gallon ) as specified by the American Society for Testing and Materials (ASTM). By far the mo st common avgas supplied is “100 Low Lead” or 100LL which has a maximum lead concentration specified by ASTM of 0.56

99 DOE Energy Information Administration. Fuel producti on volume data obtained from http://tonto.eia.doe.gov/dnav/pet/hist/mgaupus1A.htm accessed November 2006.DRAFT March 16, 2010

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grams per liter or 2.12 grams per gallon. 100 , 101 A fraction of lead is retained in the engine, engine oil and/or exhaust sy stem which we curr ently estimate at 5%. 102 For 2008, using DOE fuel volume estimates, the national estimate of lead emissions from the consumption of avgas is 522 tons as calculated according to the following equation:

(235,326,000 gal)(2.12 g Pb/gal)(0.95) = 522 short tons Pb

907,185 g/ short ton As described in the Overview section of this ANPR, DOT’s FAA also provides estimates of annual avgas fuel consumption. For 2008 , DOT estimates 351,000,000 gallons of avgas were consumed. Consumption of this volum e of avgas equates to a national lead emissions estimate for this source of 779 short tons. DOT fuel volume data are derived from FAA estimates of piston - engine activity

annually . 103 We are working to identify the source(s) of the information used to deri ve DOE fuel volume estimates. In the draft 2008 NEI, we are using DOT fuel volume estimates. We currentl y cannot estimate the fraction of total lead emissions th ese estimates comprise since the inventories for all other sources of lead to air are not ye t in the draft 2008 NEI. In

100 ChevronTexaco (200 6 ) Aviation Fuels Technical Review. FTR - 3. Available online at: http://www.chevronglobalaviation.com/docs/aviation_tech_review.pdf 101 ASTM International (2005) Annual Book of ASTM Standards Section 5: Petroleum Products, Lubricants, and Fossil Fuels Volume 05.01 Petroleum Products and Lubricants (I ): D 56

– D 3230. 102 U.S. Environmental Protection Agency (2008) Lead Emissions from the Use of Leaded Aviation Gasoline in the United States, Technical Support Document. EPA420 - R - 08 - 020. Available online at: www.epa.gov/otaq/aviation.htm . 103 U.S. Department of Transportation Federal Aviation Administration Aviation Policy and Plans. FAA Aerospace Forecast Fiscal Years 2009 - 2025. p.81. Available at: http://www.faa.gov/data_research/aviation/aerospace_for ecasts/2009 - 2025/media/2009%20Forecast%20Doc.pdf This document provides historical data for 2000 - 2008 as w ell as forecast data.DRAFT March 16, 2010

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2005, lead from avgas comprised about 50% of the national lead inventory for emissions to air. As point source emissions of lead have decreased, lead emissions from piston - engine aircraft have become the largest single source of lead to air (Figure 2). These lead emissions estimates do not include evaporative losses of lead and minimal military aircraft data. Few military aircraft are piston - engine powered and consume leaded avgas. 104 Military aircraft data are supplied by

states , and data provided to EPA during the 2008 NEI review will be included in the final 2008 inventory .

0 100 200 300 400 500 600 700 800

1999 2002 2005 2008 Yea rTons of Lead from Avgas

0% 10% 20% 30% 40% 50% 60%% Contribution of Avgas toTotal Lead

Ton s ofL ead fr om Avg as % C o nt ri but io n of Avg as to T ot al L ead Figure 2. The Increasing Contribution of L ead from Aviation Gasoline to the Total Inventory of Lead Emissions to Air Annually (the total lead inventory

for 2008 will be available in 2010).

104 ChevronTexaco (2006) Aviation Fuels Technical Review p. 44. Available online at: http://www.chevronglobalaviation.com/docs/aviation_tech_review.pdf .DRAFT March 16, 2010

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Fuel volume data is from DOE’s Energy I nformation Administration. 

### 2. Airport - Specific Emissions of Lead from Piston - Engine Aircraft Aircraft gaseous and particulate matter (PM) emissions are calculated thro ugh the FAA’s Emissions and Dispersion Modeling S ys tem (EDMS). 105 This modeling sy stem was designed to develop emission inventories for the purpose of assessing potential air quality impacts of airport operations and proposed airport development projects. Lead emissions from piston - engine aircraft are not included in EDMS. To estimate airport - specific lead inventories we use engine data and other attributes of general aviation ( GA ) and air taxi ( AT ) that are used in EDMS for GA and AT and we use methods similar to those in EDMS that are described in an EPA Technical Support Document (TSD) and briefly summarized here. 106 The data required to estimate airport - specific lead inventories includes the landi ng and take - off (LTO) activit y of piston - engine aircraft at a facilit y; fuel consumption rates by these aircraft during the various modes of the landing and take - off cy cle; the time spent in each mode of the LTO (taxi/idle - out, takeoff, climb - out, approach , and taxi/idle - in); the concentration of lead in the fuel; and the retention of lead in the engine and oil. The equation used to calculate airport - specific lead emissions during the LTO cy cle is below, followed by a description of each of the input param eters.

LTO Pb (tons) = (piston - engine LTO)(avgas gal/LTO)([Pb])(1 - Pb retention) 105 EDMS is available online at: http://www.faa.gov/about/office_org/headquarters_offices/aep/models/edms_model/ 106 U.S. Environmental Protection Agency (2008) Lead Emissions from the Use of Leaded Aviation Gasoline in the United States, Technical Support Document. EPA420 - R - 08 - 020. Available online at: www.epa.gov/otaq/aviation.htm .DRAFT March 16, 2010

53 907,185 g/ short ton Piston - engine LTO : Most piston - engine aircraft fall into the categories of either GA or AT . Some GA and AT activity is conducted b y turboprop and turbojet aircraft which do not use leaded avgas. There are no national databases that provide airport - specific LTO activity data for piston - engine aircraft separatel y from turbojet and turboprop aircraft. The fraction of GA and AT aircraft that use piston engines will vary by airport. However, in the absence of airport specific data, EPA calculated a national default estimate using FAA’s GA and AT Activity (GAATA) Survey . 107 The 2005 GAATA Survey reports that approximately 72% o f all GA and AT L TOs are from piston - engine aircraft which use avgas, and about 28% are turboprop and turbojet powered which use jet fuel, such as Jet A. 108 Le ad is not added to jet fuel. Therefore, to calculate piston - engine aircraft LTO as input for this equation, the total GA plus AT L TOs are multiplied by

0.72. Avgas use (gal/L TO) : Piston - engine aircraft can have either one or two engines. EDMS version 5.0.2 contains information on the amount of avgas used per LTO for some single and twin - engine aircr aft. The proportion of piston - engine L TOs conducted b y s ingle - versus twin engine aircraft was taken from the FAA’s GAATA Survey for 2005 (90% of L TOs are conducted b y aircraft having one engine and 10% of L TOs by aircraft having two engines). Since twin - engine aircraft have higher fuel consumption rates than those with single engines, a weighted average LTO fuel usage rate was established to apply to the population of piston -

107 The FAA GAATA is a d atabase collected from surveys of pilots flying aircraft used for general aviation and air taxi activity. For more information on the GAAT A, see Appendix A , online at : http://www.faa.gov/data_statistics/aviation_data_statistics/general_aviation/ 108 There are about 194,000 piston - engine aircraft in the U.S. general aviation and air taxi fleet (175,000 single engine and 19,000 tw in - engine aircraft) according to FAA’s 2005 GAATA Survey.DRAFT March 16, 2010

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engine aircraft as a whole. For the single - engine aircraft, the average amount of fuel consumed per LTO was determined from the six ty pes of single piston - engine aircraft within EDMS. 109 This was accomp lished by averaging the single - engine EDMS outputs for fuel consumed per LTO using the EDMS scenario propert y of ICAO/USEPA Default - Times in Mode (TIM), with a 16 minute taxi - in/taxi - out time according to EPA’s Procedures for Emission Inventory Preparati on, Volume IV: Mobile Sources , 1992. 110 This gives a value of 16.96 pounds of fuel per LTO (lbs/LTO). Next, the average single - engine consumption rate was divided by the average densit y of 100LL avgas, 6 pounds per gallon (lbs/gal), producing an average fu el usage for single - engine piston aircraft of 2.83 gallons per L TO (gal/LTO). This same calculation was performed for the two twin - engine piston aircraft within EDMS, producing an average LTO fuel usage rate for twin - engine piston aircraft of 9.12 gal/L TO . Using these single - and twin - engine piston aircraft fuel consumption rates, a weighted average fuel usage rate per LTO was computed b y multiplying the average fuel usage rate for single - engine aircraft (2.83 gal/LTO) b y the fleet percentage of single - engine aircraft LTOs (90%). Next, the twin - engine piston aircraft average fuel usage rate (9.12 gal/L TO) was multiplied by

the fleet percentage of twin - engine aircraft LTOs (10%). By summing the results of the single - and twin - engine aircraft usage rates , the overall weighted average fuel usage rate per LTO of 3.46 gal/LTO is obtained. Concentration of lead in fuel, [Pb] : T he maximum lead concentration specified b y ASTM for 100LL is 0.56 grams per liter or 2.12 grams per gallon. This amount of lead is 109 EPA understands that EDMS 5.0.2 has a limited list of piston eng ines, but these are currently the best data available. 110 U.S. Environmental Protection Agency (1992) Procedures for Emission Inventory Preparation, Volume IV: Mobile Sources , EPA - 450/4 - 81 - 026d (Revised).DRAFT March 16, 2010

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normally added to assure that the required lean and rich mixture knock values are achieved. As noted above, 100 Octane ( containing 1.1 2 grams of lead per liter or 4.24 grams of lead per gallon ) is used by

a small number of piston - engine aircraft. We currently do not include estimates of lead emissions using 100 Octane and we are requesting comment on the airport facilities where 100 Octane is used and the LTO activity associated with the use of this fuel. Retention of lead in engine and oil (1 - Pb Reten tion) : Recent d ata collected from aircraft piston engines operating on leaded avgas suggests that about 5% of the lead from the fuel is retained in the engine and engine oil. 111 Thus the emitted fraction is 0.95. Multiplying th e lead concentration in 100LL avgas by the weighted average fuel usage rate produces an overall average value of 7.34 grams of lead per LTO (g Pb/L TO) for piston engines: 3.46 gal/L TO x 2.12 g Pb/gal = 7.34 g Pb/L TO. The denominator is a unit conversion factor used to express the lead inventory in units of short tons. Apply ing these parameters in the equation above y ields the following equation:

Pb (tons) = (piston - engine L TO)(7.34 g Pb/LTO) (0.95)

907,185 g/ short ton which simplifies to: Pb = (piston - engine LTO) (7.7 X 10 - 6 short tons) or 7 grams of lead per

111 The information used to develop this estimate is from the follow ing references: (a) Todd L. Petersen, Petersen Aviation, Inc, Aviation Oil Lead Content Analysis , Report Number EPA 1 - 2008, January 2, 2008, available at William J. Hughes Technical Center T echnical Reference and Research Library at http://actlibrary.tc.faa.gov/ and (b) E - ma il from Theo Rindlisbacher of Switzerland Federal Office of Civil Aviation to Bryan Manning of U.S. EPA, regarding lead retained in engine, September 28, 2007.DRAFT March 16, 2010

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LTO where piston - engine LTO = (GA LTO + AT L TO)(0.72). EPA used similar methods to estimate lead emissions from piston - engine powered helicopters which are described separately . 112 We currently estimate there are 6 grams of lead emitted b y piston - engine helicopters per LTO. Lead emitted during the LTO cy cle is assigned to the airport facility where the aircraft operations occur. 113 FAA’s Office of Air Traffic provides a complete listing of operational airport facilities in the National Airspace Sy stem Resources (NASR) database. 114 In 2008, there were 19,896 airport facilities in the U.S., the vast majority of which are expected to have activity by piston - engine aircraft that operate on leaded avgas. There are seven t yp es of airport facilities: airports, balloonports, seaplane bases, gliderports, heliports, stolports, 115 and ultralight facilities. Among these, balloonports are the onl y facilities not expected to have piston - engine aircraft activity . Preparing airport - spe cific lead inventories requires information regarding LTO activity . These activity

data are reported to the FAA for only a small subset of the approximately 20,000 facilities in the U.S. EPA obtains L TO information for approximately 3,400 facilities fro m FAA’s Terminal Area Forecast (TAF) database that is prepared by FAA’s Office of Aviation

112 U.S. EPA (March 2010) Memorandum from Meredith Pedde to docket EPA - HQ - OAR - 2007 - 0294, titled, “Calculating Aviation Gasoline Lead Emissions in the 2008 NEI. ” pp.8 - 9. 113 An aircraft operation is defined as any landing or take - off event, therefore, to calculate LTOs, operations are divided by two. Most data sources from FAA report aircraft activity in numbers of operati ons which, for the purposes of calculating lead emissions using the method described in the TSD, need to be converted to LTO events. 114 An electronic report can be generated from the NASR database and is available for dow nload from the internet at the follo wing website. . http://www.faa.gov/airports_airtraffic/airports/airport_safety/airportdata_5010/ This database is updated every 56 days. 115 Stolport is an airport designed w ith STOL (Short Take - Off and Landing) operations in mind, normally having a short single runway .DRAFT March 16, 2010

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Policy and Plans. 116 The TAF database currently includes information for airports in FAA’s National Plan of Integrated Airport Sy stems (NPIAS), which identifies airpo rts that are significant to national air transportation. For airports not listed in the TAF, operations data are obtained from the NASR database, where available. Operations data provided by the NASR database may

be self - reported by

airport operators thr ough data collection accomplished by airport inspectors who work for the State Aviation Agency , or operations data can be obtained through other means. 117 We are using the January 15, 2009 version of the NASR database to evaluate airport lead emissions inventories for 2008. Using the TAF database as the primary source of LTO information and the NASR as a secondary source, we have LTO activity data for approximately 5,600 ai rport facilities. There are approximately 14,000 facilities in the NASR database for which there are no LTO activity data. 118 We developed methods based on previous work conducted b y the FAA to estimate L TO activit y atthe remaining airport and heliport fa cilities. We are requesting comment on these methods which are described here briefly . The details regarding the method described here are available in the docket. 119 The FAA has used regression models to estimate operations at facilities where operatio ns data are not available. 120 , 121 In this work and other work, FAA identified characteristics of small

116 http://aspm.faa.gov/main/taf.asp 117 In the absence of updated information from States, local authorities or Tribes, w e are using the LTO dat a provided in the FAA database. 118 No Commuter, GA Itinerant, GA Local, or Air Taxi operations data. 119 U.S. EPA (March 2010) Memorandum from Meredith Pedde to docket EPA - HQ - OAR - 2007 - 0294, titled, “ Calculating Aviation Gasoline Lead Emissions in the 2008 NEI . ” . 120 Federal Aviation Administration, Office of Aviation Policy and Plans, Statistics and Forecast Branch. ( July 2001 ) Model for Estimating General Aviation Operations at Non - towered Airports Using Tow ered and Non tow ered Airport Data. Prepared by GRA, Inc.DRAFT March 16, 2010

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towered airports for which there were statisticall y significant relationships with operations at these airports. 122 Regression models based on the airport c haracteristics were then used to estimate general aviation operations for a set of non - towered airports. The airport characteristics identified by

the FAA and used to estimate general aviation operations at small airports include: the number and t ype of a ircraft based at the facility (i.e., ‘based aircraft’), population in the vicinity of the airport, airport regional prominence, per capita income, region of the country , and the presence of certificated flight schools. We were able to obtain data from the NASR and the U.S. Census Bureau to evaluate relationships between several airport characteristics and LTO activity . LTO estimates were derived using different models depending on data availability . The number of based aircraft and county population in which the airport is located were the most highly

significant and positive regressors to L TO activity that our anal ys is provided. 123 The regression equation for based aircraft and county population is: L TOs = 1248 + 203.04*Aircraft + 0.0019*County Populat ion with an R 2 = 0.64. For approximately 7,800 facilities that do not report L TO activity to FAA, we used based aircraft and county population to estimate activity . We request comment on the method we are using to estimate LTO activity at these airport f

acilities. To estimate LTO activity at the airport facilities that do not report based aircraft, we used a regression equation based on count y population and region of the country. The regression equation using count y population and regression of the c ountry is: LTOs = 6200.2 +

121 Hoekstra, M. (April, 2000) Model for Estimating General Aviation Ope rations at Non - Tow ered Airports. P repared for FAA Office of Aviation Policy and Plans. 122 GRA, Inc. “Review of TAF Methods,” Final Report, prepared for FAA Office of Aviation Policy and Plans under Work Order 45, Contract No. DTFA01 - 93 - C - 00066, February 25, 1998. 123 U.S. EPA (March 2010) Me mo randum from Meredith Pedde to docket EPA - HQ - OAR - 2007 - 0294, titled, “Calculating Aviation Gasoline Lead Emissions in the 2008 NEI. ” .DRAFT March 16, 2010

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0.0087*county

population

– 175.07*West State

– 5567.3*Alaska + 854.83*Northeast with an R2 = 0.15. This equation has a low correlation coefficient and we are exploring additional options for estimating LTO activity at these fa cilities for which very little information is reported to the FAA. We request comment on apply ing the regression equation above an d alternative methods to estimate L TO activity

at these facilities. For heliports, which comprise approximately 5,500 facili ties in the NASR database, we had insufficient information on which to develop a regression equation and are currentl y using the median of activity

(141 L TOs/ ye ar) at heliports for which we have LTO activity data. Nationally , 25% of helicopters are piston - engine powered and therefore use leaded avgas. The FAA and EPA have limited information regarding the specific heliports that have activity by piston - engine helicopters. We are requesting information regarding heliport facilities at which piston - engine powered aircraft operate and the activity of these aircraft. The draft 2008 NEI is the first inventory for which we are implementing the use of LTO based lead estimates at almost 20,000 airport facilities and we are expecting state, local and tribal air a gency

review of these data to improve our current estimates. The specific information on which we are requesting data include: 1) the fraction of GA and AT LTO activity reported to FAA that is conducted by piston - engine versus jet - engine powered aircraft , 2) airport - specific LTO activity

for single - versus twin - engine piston - powered aircraft, 3) fuel consumption rates for the piston - engine aircraft operating at each airport, 4) the time spent in each mode of operation including run - up checks conducted by piston - engine aircraft prior to take - off, and 5) the concentration of lead in fuel delivered to individual airports. Methods for providing information to EPA as part of the review process involved in finalizing the 2008 NEI areDRAFT March 16, 2010

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available. 124 The discussion above pertains only to lead emissions during the LTO cy cle. L ead emitted outside the L TO cy cle occurs during aircraft cruise mode and portions of the climb - out and approach modes. This part of an aircraft operation emits lead at various altitu des as well as close to and away

from airports. We are developing methods to estimate lead emissions outside the L TO cy cle which we anticipate will be available in 2010. 

### B. Projections for Future Growth The FAA publishes an annual forecast of the numb er of piston - engine powered aircraft, hours flown, the consumption of avgas, the numbers of pilots and student pilots. 125 The most recent forecast is for the years 200 9 through 2025. The General Aviation Manufacturers Association (GAMA) reproduces the FAA forecast in their annual statistical databook. 126 According to the GAMA summary , the number of active single - engine piston - powered aircraft is projected to increase annually at a 0.5% growth rate, with the aircraft population increasing from 144,220 in 2008 to 157,400 in 2025. The number of active twin - engine piston - powered aircraft is projected to decrease 0.9% annuall y, with aircraft population decreasing from 18,385 in 2008 to 15,650 in 2025. The piston - powered helicopter population is expected to grow 4.7% annually from a population of 3,970 in 2008 to 8,295 in 2025.

124 All documentation for use in preparing 2008 emission inventories can by found on the NEI/EIS Implementation website : http://www.epa.gov/ttn/chief/net/neip/index.html. 125 FAA Aerospace Forecast Fiscal Years 200 9

–2025 . Available online at: http://www.faa.gov/data_research/aviation 126 General Aviation Manufacturers Association (2008) General Aviation Statistical Databook and Industry Outlook, pp.51 - 55. Available online at: http://www.gama.aero/files/2008_general_aviation_statistical_databook__indust_499b0dc37b.pdfDRAFT March 16, 2010

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The FAA forecast predicts the number of hours flown in single - engine piston - powered aircraft is projected to increase 0 . 5 % ye arl y from 2008 to 2025); the number of hours flown in twin - engine piston - powered aircraft is projected to decrease 1.5% annuall y and the number of hours flown in piston - powered rotocraft is projected to increase 3.9% annually . The changes in numbers of piston aircraft and hours flown is generally reflected i n the consumption of leaded avgas. For the ye ars 200 8 through 2025, DOT’s FAA estimates no change in the volume of leaded avgas consumed by single - engine aircraft in the U.S. (204 million gallons in 2008 and 2025), a 1.9% decrease in leaded avgas consume d by multi - engine aircraft (from a baseline of 108 million gallons in 2008 to 78 million gallons in 2025), and a 3.8% annual increase in the volume of leaded avgas consumed by piston - powered helicopters (from a baseline of 13 million gallons in 2008 to 24 million gallons in 2025). For 2025, the forecast volume of leaded avgas is 3 48 million gallons. Consumption of this volume of fuel would release 773 tons of lead to the air in 2025. The number of active pilots fly ing general aviation aircraft (excluding air transport pilots) is projected to be slightl y over half a million in 2025, representing a yearl y increase of 0.7% over the forecast period. 127 The student pilot population is forecast to increase at a slightly higher rate of 1.0% yearl y for a 2025 tota l slightly over 100,000. Private pilots and sport pilots are also projected to increase ye arly (0.2% y earl y increase in the number of private pilots). EPA is requesting comments on the forecast information presented in this section and on the uncertainty in these projections.

127 Except for sport pilots, an active pilot is a person with a pilot certificate with a valid medical certificate. Source: FAA 2008 - 2025 Aerospace Forecast .DRAFT March 16, 2010

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## IV . Lead Concentrations in the Vi cinity of Airports This section summarizes information regarding the chemical and ph ys ical properties of lead emitted b y piston - engine aircraft and monitoring and modeling studies regarding ambien t and soil lead concentrations in the vicinity of airports where piston - engine aircraft operate. 

### A. Chem ical and Physical Properties of Lead Em itted by Piston - Engine Aircraft

In formation regarding lead emissions from engines operating on leaded fuel is summarized in prior AQCDs for Lead. 128 , 129 The chemical form of lead added to avgas (i.e., tetraeth yl lead) and the lead scavenger, ethy lene dibromide, are the same compounds used in leaded gasoline for motor vehicles in the past . Therefore, the summary of the science regarding emissions of lead from motor vehicles presented in the 1997 and 1986 AQCD for Lead are relevant to understanding some of the properties of lead emitted from piston - engine aircraft. In addition, the Swiss Federal Office of Civil Aviation (FOCA) published a study of piston - engine aircraft emissions including measurements of lead. 130 When leaded avgas is combusted, the lead is oxidized to form lead oxide. In the absence of a lead scavenger in the fuel, lead oxide can collect on the va lves and spark plugs and if the

128 U.S. Environmental Protection Agency (19 77 ) Air Q uality C riteria for L ead. Research Triangle Park, NC: Office of Health and Environmental Assessment, Environmental Criteria and Assessment Of fice; EPA report no. E PA 600/8 - 77 - 017 . Available at: http://www.epa.gov/ttn/naaqs/standards/pb/s_pb_pr.html . 129 U.S. Environmenta l Protection Agency (1986) Air Q uality C riteria for L ead. Research Triangle Park, NC: Office of Health and Environmental Assessment, Environmental Criteria and Assessment Office; EPA report no. EPA 600/8 - 83/028aF - dF. 4v. Available at: http://www.epa.gov/ttn/naaqs/standards/pb/s_pb_pr.html . 130 Federal Office of

Civil Aviation Environmental Affairs (2007) Aircraft Piston Engine Emissions Summary Report. 33 - 05 - 003 Piston Engine Emissions_Swiss FOCA_Summary. Report_070612_rit. Available online at: http://www.bazl.admin.ch .DRAFT March 16, 2010

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deposits become thick enough, the engine can be damaged. Eth yl ene dibromide reacts with the lead oxide, converting it to brominated lead and lead ox yb romides. These halogenated forms of lead are volatile at the high temper atures experienced under combustion conditions and are therefore exhausted from the engine along with the other combustion by - products. 131 Upon cooling to ambient temperatures these brominated lead compounds are converted to particulate matter. In addition to lead halides, ammonium salts of lead halides were also emitted by motor vehicles. 132 Le ad halides undergo compositional changes upon cooling and mixing with the ambient air as well as during transport ; the water - solubility of these lead - bearing particles increase s with a shift toward smaller mean particle size (USEPA 1977, Section 6.2.2.1). Lead h alides from automobile exhaust break down rapidly in the atmosphere, via redox reactions in the presence of atmospheric acids (AQCD for Lead, page E - 17 ). A small fraction of uncombusted alky l lead was measured in the exhaust of motor vehicles operating with leaded gasoline and is therefore likely to be present in the exhaust from piston - engine aircraft. 133 Alky l lead is the general term for organic lead compounds and includes the lead additives tetramethy l lead and tetraethy l lead. Tetraeth yl lead is a highl y volatile compound and therefore, a portion of tetraethy l lead in fuel exposed to air will partition into the vapor phase. Tetraeth yl lead can ente r the atmosphere from avgas distribution sy stems, refueling

131 ChevronTexaco (2006) Aviation Fuels Technical Review pp. 64 - 65. Available online at: http://www.chevronglobalaviation.com/docs/aviation_tech_review.pdf 132 U.S. Environmental Protection Agency (1986) Air Q uality C riteria for L ead. Volume 2 Section Chapte rs 5 & 6. Research Triangle Park, NC: Office of Health and Environmental Assessment, Environmental Criteria and Assessment Office; EPA report no. EPA - 600/8 - 83/028aF - dF. 4v. Available from: NTIS, Springfield, VA; PB87 - 142378. 133 U.S. Environmental Protection Agency Persistent, Bioaccumulative, and Toxic Pollutants (PBT) Program (2002) PBT national action plan for alkyl - Pb. Washington, DC. Available online at: http://www.epa.gov/pbt/pubs/A lkyl_lead_action_plan_final.pdfDRAFT March 16, 2010

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operations, fuel check pre - flight procedures and evaporative losses from the aircraft. 134 Tetraeth yl lead has an atmospheric residence time ranging from a few hours to a few day s. Tetraeth yl lead r eacts with the hy droxyl radical in the gas - phase to form a variet y of products that include ionic trialky l lead, dialk yl lead and metallic lead. Trialky l lead is slow to react with the hy drox yl radical and is quite persistent in the atmosphere (AQCD for L ead, page 2 - 5). Particles emitted by

piston - engine aircraft are in the submicron size range (less than one micron in diameter). The Swiss FOCA reported the mean particle diameter of particulate matter emitted by

one single - engine piston - powered aircraf t ranged from 0.049 to 0.108 microns under different power conditions. The particle number concentration ranged from 5.7x10 6 to 8.6x10 6 particles per cm 3 and using a specific density for soot of 1.2, the authors estimated the mass concentration of particu late emissions as approximately 10,000  g/m 3 . The authors noted that these particle emission rates are comparable to those from a t ypical diesel passenger car engine without a particle filter (FOCA, Section 2.2.3.a). A significant fraction of particles in the submicron size range are deposited and retained in the lower respiratory

sy stem of humans and animals (AQCD for PM, page 6 - 108). 135 The 1986 AQCD for Lead concludes that lead deposited in the lower respiratory tract is totally absorbed (USEPA 1986, page 10 - 2).

134 U.S. Environme ntal Protection Agency Persistent, Bioaccumulative, and Toxic Pollutants (PBT) Program (2002) PBT national action plan for alkyl - Pb. Washington, DC. p. 12. Available online at: http://www.epa.gov/pbt/pubs/A lkyl_lead_action_plan_final.pdf 135 U.S. Environment al Protection Agency (2004) Air Quality Criteria for Particulate Matter (AQCD). Volume II Document No. EPA600/P - 99/002bF. Washington, DC: U.S. Environmental Protection Agency. Available online at: http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=87903DRAFT March 16, 2010

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Due to their small size (i.e., ty pically less than one micron in diameter) , lead - bearing particles emitted b y piston engines may disperse widely in the environment. However, lead emitted during LTO, particularly during ground - based operatio ns such as start - up, idle, preflight run - up checks, taxi and take - off may deposit to the local environment. Meteorological factors (e.g., wind speed, convection, rain, humidity) will influence local deposition rates. As discussed in the overview section of this ANPR, many airports in the country

have been home to piston engine operations for decades, including ye ars when lead concentrations in avgas were twice as high as current levels. We seek comment on the chemical and ph ys ical form of lead emissions from piston - engine aircraft as well as dispersion and deposition patterns that may influence the risk for local - scale impacts. 

### B. Summ ary of Airport Lead Monitoring and Modeling Studies Lead concentrations in ambient air have been reported for samples collected on or near five airports: the Santa Monica municipal airport in Santa Monica, CA, the Van Nu ys airport in Van Nu ys , CA, the Chicago O’Hare airport in IL, the Toronto Buttonville municipal airport in Ontario, Canada, and the Destin airport in Des tin, FL. 136 , 137 , 138 , 139 , 140 Air quality modeling of lead emissions from piston - engine aircraft has been conducted as part of EPA’s National Air

136 South Coast Air Quality Management District (2007) Community - Scale Air Toxics Monitoring

– Sun Valley Neighborhood and General Aviation Airports. Presented by Dr. Philip Fine at the U.S. EPA Air Toxics Data Analysis Workshop - Chicago, IL. October 2 - 4, 2007. 137 Illinois Environmental Protection Agency Bureau of Air ( 2002 ) Chicago O’Hare Airport Air Toxic Monitoring Program June

– December, 2000. 138 Environment Canada ( 2000 ) Airborne Particulate Matter, Lead and Manganese at Buttonville Airport. Toronto, O ntario, Canada:Conor Pacific Environmental Technologies for Environmental Protection Service, Ontario Region. 139 Tetra Tech, Inc. (2007) Destin Airport Air Sampling Project Executive Summary. Prepared for City of Destin, Florida. 140 Tetra Tech, Inc. (2008) Destin, Florida Airport Sampling Report. October 2008. Prepared for City of Destin, Florida.DRAFT March 16, 2010

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Toxics Assessment and in one study . 141 , 142 As discussed in Section VI.A of this ANPR, state and local agencies are initiating lead monitoring at four airports in 2010 that will provide additional information regarding the air quality impact of lead emissions from piston - engine aircraft.

### 1. Summary of Airport Lead Monitoring Studies The ambient air monitoring studies reporting lead concentrations on and near airport propert y served man y purposes and therefore used different criteria for determining sample locations, sample durations, sample collection methods, and collection of important metadata (e.g., activit y of pis ton - engine aircraft and aircraft engine ty pe). This section summarizes results from these studies. Ambient monitoring studies at and near airports indicate that lead levels in ambient air at or near airports with piston - engine activity are higher than lead levels in areas not directly influenced b y a lead source . The stud y at the Santa Monica A irport 143 is the only study to date in which a lead monitor was sited at an area of anticipated maximum concentration for a period of time that provides ambient concentrations relevant for comparison to the Lead NAAQS. 144 In

141 Piazza, B for the Los Angeles Unified School District Environmental Health and Safety Branch (1999) Santa Monica Municipal Airport: A Report on the Generation and Downwind Extent of Emissions Generated from Aircraft and Ground Support Operations. Report Prepared for The Santa Monica Airport Working Group. Available online at: http://yosemite.epa.gov/oar/CommunityAssessment.nsf/6ce396ab3fa98ee485256db0004acd94/$FILE/Santa_Monica .pdf 142 U.S. Environmental Protection Agency (2009) 2002 National - Scale Air Toxics Assessment (NATA). Available online at: http://www.epa.gov/ttn/atw/nata2002/index.html 143 South Coast Air Quality Management District (2007) Community - Scale Air Toxics Monitoring

– Sun Valley Neighborhood and General Aviation Air ports. Presented by Dr. Philip Fine at the U.S. EPA Air Toxics Data Analysis Workshop - Chicago, IL. October 2 - 4, 2007. This presentation includes lead monitoring data collected at and near the Santa Monica Airport and the Van Nuys Airport. 144 As with o ther lead sources, source - oriented monitors for airports should be sited in ambient air at theDRAFT March 16, 2010

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this study where monitors were placed in locations to identify the gradient in lead concentrations with distance from piston - engine activity , ambient lead increased with increasing proximity to the airport. Lead monitors were located at seven sites around the Santa Monica Airport for two three - m onth periods, in Spring 2006 and Winter 2006 - 2007. At the monitor placed near the runway blast fence (i.e., the maximum impact site) on the Santa Monica A irport propert y, the quarterl y average concentrations of lead in total suspended particulate matter ( TSP ) were 0.08 ( w inter) and 0.10 ( s pring)  g/m 3

. 145 T he maximum quarterl y average concentration of lead in total suspended particulate matter (TSP) was 0.10  g/m 3 , 67% of the 2008 Lead NAAQS of 0.15  g/m 3 . This suggests that ambient air lead concentrations at similar airports with more piston engine activit y than the Santa Monica A irport may be higher, and could further approach or exceed 0.15  g/m 3

. At a neighborhood site, 70 meters in the prevailing downwind direction from the maximum impact site, quarte rl y average concentrations of lead in TSP were 0.02  g/m 3 (winter) and 0.03  g/m 3 (spring). 146 At a distance of one kilometer in the prevailing downwind direction from the maximum impact site, lead concentrations were 0.004  g/m 3 and 0.008  g/m 3 in winter and spring, respectivel y (these concentrations are considered the background lead concentration) . The study conducted at the Santa Monica Airport reported concentrations of ambient lead that were highest at on - and near airport areas downwind f rom the emissions of piston - engine aircraft. These data suggest that piston - engine activit y can increase ambient lead concentrations in downwind neighborhood sites, resulting in levels that are four to five times

location of predicted maximum lead concentration. Typically, the location of maximum lead concentration will be dow nwind of the take off strip near the “blast fe nce.” http://www.epa.gov/ttnamti1/files/ambient/pb/Netw orkDesignQA.pdf 145 A low - volume sampler w as used at this site which EPA expects w ould y ield com parable results to a high - volume sampler, the later of which is the current method used to collect samples for comparison with the Lead NAAQS. 146 These distances were measured using Google Earth Pro softw are.DRAFT March 16, 2010

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higher than background levels and maximum impact site concentrations that are up to 25 times higher than background lead levels. 147 As with other emissions from internal combustion engines, lead emitted b y piston - engine aircraft are largely

in the submicron and even ultrafine size fraction; therefo re, analogies to gradients in ultrafine PM are relevant. As summarized in EPA’s 2009 Integrated Science Assessment for Particulate Matter, ultrafine particulate number counts decrease exponentially with distance from roadway s. 148 A recent stud y at the Sant a Monica Airport reported increased ultrafine PM in a neighborhood downwind from aircraft operations that were conducted b y jet and piston - engine aircraft. 149 The EPA is conducting modeling and monitoring studies to further evaluate the gradient in lead co ncentrations with distance from airports (see Section VI.B of this ANPR). At the Van Nu ys Airport, lead monitoring in ambient air was conducted at six sites for two three - month periods. L ead monitoring for this study included locations of ambient air on airport property . However, monitors were not sited in the area anticipated to experience the maximum impact from piston - engine aircraft emissions. The monitoring site that was in closest proximity to the maximum impact area was more than one kilometer do wnwind from the maximum impact site. 150 The highest quarterl y concentration of lead observed at the Van Nu ys Airport was at the monitor located over one kilometer away from the maximum impact site and 147 EPA notes that additional information regarding this study at the Santa Monica Airport may become available. If additional information does become avai lable, EPA will take this information into account in the NPRM. 148 U.S. Environmental Protection Agency (2009) Integrated Science Assessment for Particulate Matter. Second External Review Draft. EPA/600/R - 08/139B. p. 3 - 110. Available online at: http://cfp ub.epa.gov/ncea/cfm/recordisplay.cfm?deid=210586 149 Hu, S., Fruin, S., Kozaw a, K., Mara, S., Winer, A.M., Paulson, S.E. (2009) Aircraft Emission Impacts in a Neighborhood Adjacent to a General Aviation Airport in Southern California. Environ. Sci. Technol. 43:8039 - 8045. 150 These distances were measured using Google Earth Pro softw are. Prevailing wind direction, which determines the direction in which the majority of aircraft depart, is provided in the SCAQMD presentation of these data.DRAFT March 16, 2010

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the lead concentration at this site was 0.03  g/m 3 whic h was four - fold higher than the regional background level of 0.008  g/m 3 measured during the same time period at a site over 2.5 kilometers from the north end of the Van Nu ys Airport . At the Toronto Buttonville M unicipal A irport, ten 24 - hour PM 10 samples were collected at four sites at the airport (as close as 15 meters from the runway) and one urban background site in downtown Toronto (located about 10 kilometers west, southwest of the airport). PM 10 is particulate matter less than ten microns i n aerod ynamic diameter. The average lead concentration among the airport monitors (which includes three samples that were taken for less than a 12 - hour period), was 0.03  g/m 3 and the maximum 24 - hour lead concentration was 0. 1 3  g/m 3 . One sample, collect ed for 11 hours, measured 0.30  g/m 3

. The maximum concentration observed over a 24 - hour period at the airport during this study (0. 13  g/m 3 ) was 11 times higher than the lead concentration reported for the downtown Toronto, Canada background site during the same time period (0.012  g/m 3 ) . 151 The average lead concentration reported for the downtown Toronto site was 0.007  g/m 3

. The total particulate matter mass in PM 10 was also measured in this study , and at the airport, the average mass of lead in PM 10 wa s 0.15% of the total PM 10 mass. At the downtown Toronto site, the average mass of lead in PM 10 was 0.04% of the total PM 10 mass. The study reported that the use of leaded avgas at the airport was evident in enhanced airborne lead levels. Lead and other hazardous air pollutants were measured at sites upwind and downwind of the Chicago O’Hare Airport on sixteen day s during the period from June through December,

151 Average concentrati ons reported in this study include three days of short - duration sampling so the average is not used for comparison here.DRAFT March 16, 2010

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2000. In order to assess the potential impact of airport operations on ambient c oncentrations of lead and other pollutants in areas adjacent to airport propert y, two monitoring sites were deploy ed on different sides of the airport: one in Bensenville, IL and the other in Schiller Park, IL. For five day s during the sampling campaign, the prevailing wind direction provided samples that were collected simultaneously upwind and downwind of the airport. Lead concentrations measured at the downwind site on these five day s were, on average , 88% higher than lead concentrations measured at th e upwind site. Lead concentrations at the upwind site over the five day s averaged 0.016  g/m 3 and downwind concentrations averaged 0.030  g/m 3 . This study demonstrates the potential for operations on airport propert y to impact ambient lead concentrations downwind. Lead TSP samples were collected for four day s in April 2007 and for three day s in July 2008 near the Destin Airport in Destin, FL. Twelve - hour TSP samples (AM and PM) were collected at four residential locations ranging from 200 meters to 400 meters from the runway at the Destin Airport and at two urban background locations which were 1.4 kilometers and 2.7 kilometers from the airport. 152 The average lead concentration among the four residential locations was 0.004  g/ m 3 and 0.005  g/m 3 in April and July , respectively , and the average urban background lead concentration was 0.003 and 0.004  g/m 3 in April and July , respectively . In addition to these airport - specific studies, authors evaluating ambient lead concentrations collected as part of the Interagency Monitoring of Protected Visual Environments (IMPROVE) network and the National Oceanic and Atmospheric Administration (NOAA) monitoring sites reported a weekend increase in ambient lead that the authors attributed to 152 These distances were measured using Google Earth Pro softw are.DRAFT March 16, 2010

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weekend increases in pi ston - engine powered general aviation activity . 153 At some airports, piston - engine aircraft activity conducted for recreational purposes can increase greatl y on weekends and can also change seasonally with weather conditions. These peaks in activity are imp ortant to capture because they may have a strong influence on long - term average concentrations in an area. However , the current database for ambient lead concentrations at maximum impact sites at airports is severely limited and does not allow us to quant itatively evaluate the influence of this variability in activity on ambient lead concentrations. We have identified no studies evaluating the potential contribution of piston - engine aircraft emissions on vegetation. We have identified o nly one study

that reports soil concentrations on airport propert y where piston - engine aircraft are active. The air monitoring study conducted at the Toronto Buttonville airport in Ontario, Canada reported lead concentrations in soil samples collected at eight locations at the airport and two locations at the urban background site. Soil samples that were collected at the Toronto Buttonville airport had lead concentrations ranging from 22

– 46  g/ g which was not substantially higher than the lead concentrations in soil samples at the two urban background sites (29 and 31  g/g). We are seeking comments on the potential for piston - engine aircraft emissions to impact local soil lead concentrations. 

### 2. Summary of Airport Lead Modeling Studies Lead emissio ns from piston - engine aircraft at 3,410 airports were included in the recently

153 Murphy, D.M., Capps, S.L., Daniel, J.S., Frost, G.J., and White, W.H. (2008) Weekly patterns of aerosol in the United States. Atmos . Chem. Phys., 8, 2729

– 2739.DRAFT March 16, 2010

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released 2002 National Air Toxics Assessment (NATA) as nonroad sources of lead. 154 Ambient lead concentrations and exposures to lead are modeled for area, point and nonroad sourc es. Nonroad sources include only lead emissions from piston - engine aircraft. Lead emission rates are based on the lead concentration in fuel and not direct emission measurements. For the NPRM we will summarize modeling results from the 2005 NATA which will incorporate all 20,000 airport facilities discussed in Section III of this ANPR. As discussed in Section VI of this ANPR, the EPA has conducted a stud y to develop a model ing approach to evaluate the local - scale variability in ambient lead concentrations attributable to piston - engine activity at a case study

airport. This project include s collection of air monitoring data for use in evaluating model performance. In the NPRM, we will describ e the results of the modeling study with NATA results for this airport and previous modeling work. 156 We are requesting comment on the availability of additional monitoring or modeling studies that evaluate the air quality impact of lead emissions from pis ton - engine aircraft as well as potential impacts on soil, house dust, surface water or other environmental media. We also request comment on the availability of studies that assess the potential public health and welfare impact s of lead emissions from pis ton - engine aircraft .

154 U.S. Environmental Protection Agency (2009) 2002 National - Scale Air Toxics Assessment (NATA). Available online at: http://www.epa.gov/ttn /atw/nata2002/tables.html . 156 Piazza, B for the L os Angeles Unified School District Environmental Health and Safety Branch (1999) Santa Monica Municipal Airport: A Report on the Generation and Downwind Extent of Emissions Generated from Aircraft and Ground Support Operations. Report Prepared for The San ta Monica Airport Working Group. Available online at: http://yosemite.epa.gov/oar/CommunityAssessment.nsf/6ce396ab3fa98ee485256db0004a cd94/$FILE/Santa_Monica .pdfDRAFT March 16, 2010

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## V. Exposur e to Lead fr om Piston - Engine Air craft and Potential for Im pacts The continued use of lead in avgas b y piston - engine aircraft is a significant source of current lead emissions to the environment. Piston - engine aircraft emissions of lead occur at ground level as well as at fly ing altitude. L ead from this source is thus concentrated near airports and is also deposited over a large geographic area potentially contributing to higher ambient concentrations in many communities. Numerous groups within the population may be at risk of exposure to lead in fresh emissions from piston - engine aircraft, resuspended dust or other routes. Further, lead accumulates in the environment posing a p otential risk to future generations In this section we discuss a variet y of exposure pathway s and scenarios b y which the general population and environment may experience an increase in lead exposure from emissions of lead b y piston - engine aircraft. This section also describes the potential for public health and welfare effects from exposure to compounds associated with the continued use of tetraethy l lead in fuel, such as the contribution of lead to ambient particulate matter, emissions of ethylene dibro mide and non - exhaust exposure to tetraethy l lead. We are seeking comments and information on these exposure scenarios as well as additional exposure pathway s and scenarios. 

### A. Exposure to Lead Em i ssions from Piston -

Engine Aircraft Piston - engine aircraft emissions of lead occur at ground level as well as at altitudes, resulting in areas of more concentrated ambient air exposure, as discussed in Section IV, and canDRAFT March 16, 2010

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also be distributed over large geographic areas due to in - flight emissions. L ead pa rticles can deposit to soil, water, vegetation and other surfaces or remain airborne for some time following emissions. Inthis section we discuss potentially exposed populations which include people living or attending schools near airports and pilots. Additional pathway s by which people and animals could be exposed to lead emissions from piston - engine aircraft are those associated with agricultural applications of these aircraft and piston - engine activity at seaport and inland waterway s. Lead from aviation gasoline has been identified as a potential source of contamination for local communities. 157 As described below, man y general aviation airports are located in densely populated areas. GA airport facilities were t ypically built in sparsely populated areas, man y of which are now heavily

populated or are experiencing increased residential development. This development includes dense residential neighborhoods, schools, businesses, and recreational facilities. Airports can function as a center of man y forms of activity in a community. InEPA’s initial research, EPA has found that a irports are often surrounded b y a variety of land uses including recreational sport facilities (e.g., baseball diamonds, soccer fields, golf courses, and swimming pools) and residential communities that take advantage of the ease of transport and pilot training/recreation offered b y quick access to an airport. Man y airports offer on - site tours to the general public, educational classes, and recreational opportunities that ca n present near source exposure scenarios. Airports are especially attractive to young children, and programs at some airports are focused on this population and provide outdoor observation facilities and 157 Levin, R.; Brow

n, MJ; Kashtock, ME ; Jacobs, DE; Whelan, EA; Rodm an, J; Schock, MR; Padilla, A; Sinks , T. (2008) US Children’s Lead Exposures, 2008: Implications for Prevention. Environ. Health Perspec. 116:1285 - 1293.DRAFT March 16, 2010

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picnic facilities for families to observe aircraft operations. Many general aviation airports offer instructional fly ing and/or clubs where children 14 y ears of age and older as well as adults can learn to fl y in rental aircraft. Airport facilities also host community - friendly activities such as antique sales, fireworks display s, air shows and community meals. Many

airport facilities provide activities which bring people from the general public in close proximity to lead emissions from piston - engine aircraft and piston - engine helicopters. EPA is request ing information regarding national databases that provide information regarding recreational fields and community

gardens in close proximity to airports. 

### 1. Population Residing Near Airports To evaluate the number of people who might be exposed to elevated lead levels due to emissions from piston - engine aircraft, EPA calculated the number of people that live within one kilometer of the centroid of an airport. 158 The centroid of the airport is defined here as the latitude and longitude coordinate prov ided b y airports to FAA. 159 These coordinates ty pically identify a location in the center of the runway or runway

area. For some airports, nearb y residences are outside the one kilometer distance from the airport centroid. This is the case for residences near airports that have runway s that are longer than two kilometers and for residences near large airports such as those servicing primarily commercial aircraft activity . For airport facilities with one runway that is approximately one kilometer in length , this method will generall y include people residing within approximately 500 meters from the ends of the runway and may include residences up to approximately 900 meters from the sides of the runway . The

158 U.S. EPA ( March 2010) Memorandum f rom Meredith Pedde to docket EPA - HQ - OAR - 2007 - 0294 , titled, “ Evaluation of People Living Within 1 km of U.S Airport Facilities . ” 159 Federal Aviation Administration. Airport Data (5010) & Contact Information, Airport Facilities Dat a. Retrieved on August 13, 2009 from: http://www.faa.gov/airports/airport_safety/airportdata_5010/menu/index.cfmDRAFT March 16, 2010

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limited ambient lead monitoring data near airports presented in Section IV of this ANPR suggests that for some airports this analy sis will underestimate the actual number of people potentially

exposed to elevated levels of ambient lead from piston - engine powered aircraft. This is because the anal ys is wil l include very little of the nearby

population for airports that have a large footprint . We plan to revise this anal ys is for the NPRM using a graphical interface s ys tem that will allow us to evaluate the number of people living within uniform distances of aircraft activity . Using 2000 U.S. Census Data 160 at the block level, EPA estimates that 16 million people live within one kilometer of the centroid of the 19,896 airport facilities which includes airports, seaplane bases, heliports, stolports, ultralight facilities and glider ports. There are currentl y 5,567 heliports in this analy sis, which can be in densely populated areas. Fourteen of the 16 million people living within one kilometer of the centroid of an airport facility live within one kilometer of a heliport. We currentl y have limited information regarding which heliport facilities have piston - engine activity and we are seeking comment on piston - engine activity at heliports. There are several pathways b y which people may be exposed to lead associated with the use of piston - engine aircraft. These include inhalation of ambient airborne lead as well as incidental ingestion of ambient lead through contact with indoor or outdoor s urfaces to which ambient lead has deposited. Additionally , ambient lead deposited to outdoor soil can be tracked into interior spaces. There is also the potential for ingestion of lead emitted by piston engine aircraft emissions to deposit on edible plants and produce being cultivated in locations near airports. Consequently , there is the potential for exposure to lead emitted by piston - engine

160 Obtained from : http://www.epa.gov/ttn/fera/human_hem_censusandmet.htmlDRAFT March 16, 2010

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aircraft via ingestion for those consuming vegetables grown near airports that service piston engine aircraft. In addition to personal gardens, community gardens are sometimes sited near airports as these areas can have undeveloped available land. We do not have information on the potential significance of this exposure pathway and we are seeking comment on inform ation and anal ys es that could inform this issue. In some cases, pilots and their families choose to live in close proximity to an airstrip. These communities intentionally placed near airports are known as airport communities, fly - in communities or resid ential airparks. Some residential airparks are private while others have public services and facilities. Some residential airparks are specificall y designed as airport communities with driveway s leading from aircraft hang ars or tie - downs onto the airstri p, while other residential airparks allow apartments to be built in the airplane hangar . Other residential airparks are developed by the addition of a neighborhood immediately adjacent to a commercial airport. FAA terms this a “through - the - fence” operati on. 161 Homes are required to be at least 45 meters from the runway

centerline and can be built along one or both sides of the runway. 162 Some residential airparks provide taxiway s for access to the runway , some provide streets separate from taxiway s, and some share automobile and aircraft traffic on the same thoroughfares. A variety of resources list the location and services offered by residential airparks in the U.S. and estimates of the number of residential airparks range from 300 to 600. 163 ,

161 FAA officially defines “through - the - fence” as those activities pe rmitted by an airport sponsor through an agreement that permits access to the public landing area by independent entities or operations offering an aeronautical activity or to ow ners of aircraft based on land adjacent to, but not part of, the airport prope rty. The obligation to make an airport available for the use and benefit of the public does not impose any requirement for the airport sponsor to permit ground access by aircraft from adjacent property. ( http://www.aopa.org/whatsnew/region/airportOps0712.pdf ) 162 ASTM International (2005) ASTM F2507

– 05 Standard Specification for Recreational Airpark Design 163 www.airparks.com maintains a list of airparks that have fiv e or m ore homes/lots. The list can be updated by the public and as of July 31, 2009, lists 326 residential airparks.DRAFT March 16, 2010

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164 Insome cases, records are maintained onl y for those residential parks that have five or more homes or lots. Exposure modeling at the EPA in dicates that, for the 20 highest air emission sources, local emissions are significantly related to local blood lead levels. 165 We are aware of no studies evaluating blood lead levels among people who live in close proximity to airports with piston engine a ctivit y or those for whom lead emissions from piston engines may elevate their exposure via other exposure pathway s. As noted in Section II.B.2, the current evidence indicates that the slope for lead effects on IQ is nonlinear and is steeper at lower bloo d lead levels, such that each μg/dL increase in blood lead may have a greater effect on IQ at lower blood lead levels (e.g., below 10 μg/dL) than at higher levels (AQCD for Lead, Section 6.2.13; pp. 8 - 63 to 8 - 64; Figure 8 - 7). We are therefore seeking comm ent and information regarding blood lead concentrations in children living near airports and the extent to which these emissions cause or contribute to an y increases in blood lead levels . 

### 2. Children Attending School Near Airports As noted in Section II. B.2 of this ANPR, while adults are susceptible to lead effects at lower blood lead levels than previousl y understood (e.g., AQCD for Lead, p. 8 - 25), there is general consensus that the developing nervous s ys tem in children is among the, if not the, most se nsitive health endpoints. Also, as noted in Section II.B.3, while children are considered to be at a period of maximum exposure around 18 - 27 months, the current evidence has found even stronger associations between blood lead levels at school age and IQ at school age. The

164 http://livingwithyourplane.com/about/ has a directory of over 600 residential airparks. 165 U.S. E nvironmental P rotection A gency ( 2007 ) Pilot Study of Targeting Elevated Blood Lead Levels in Children (Draft Final Report). Washington DC:U.S. EPA Office of Pollution Prevention and Toxics. http://cfpub.epa.gov/si/si_public_record_report.cfm?dirEntryId=195303 .DRAFT March 16, 2010

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evidence “supports the idea that lead exposure continues to be toxic to children as they reach school age, and [does] not lend support to the interpretation that all the damage is done b y the time the child reaches 2 to 3 y ears of age” ( AQCD for Lead, Section 6.2.12). Accordingl y, school - age children are an at - risk population for lead exposures. This section discusses potential exposures of children at school to lead associated with piston - engine aircraft. During the school year, students spend many hours a day

at school, which usually includes time on school play grounds and on school athletic fields. Those children attending schools in close proximity to piston - engine activity

may have increased exposure to lead. Using data from the U.S. Department of Education’s National Center for Education Statistics, EPA calculated that there are 8,637 schools located within one kilometer of the centroid of an airport in the U.S., at which over 3 million children are in attendance (Table 1 ). 166 , 167 These children represent 6% of the total U.S. student population. Table 1 . Numbers of Public and Private Schools and School Children Attending Schools Located within One Kilometer of the Centroid of an Airport Servicing Piston - engine Aircraft. Number of Schools within 1 km of an airport Number of students who

attend schools within 1 km of an airport Private Schools 2,185 420,824

166 U.S. EPA ( March 2010) Memorandum from Meredith Pedde to docket EPA - HQ - OAR - 2007 - 0294, titled, “ Identification of Schools Within 1 km of U.S Airport Facilities . ” 167 Public School Data available for 2006 - 2007: http://nces.ed.gov/ccd/bat/ ; Private School Data available for 2007 - 2008: http://nces.ed.gov/sur vey s/pss/pssdata.aspDRAFT March 16, 2010

80 Public Schools 6,452 2,869,939 All Schools 8,637 3,290,763

Section II.B.1 notes that children in povert y and black, non - Hispanic children have notably higher blood lead levels than do economically well - off children and white children, in general. To evaluate potential ethnic and economic disparities among children attending schools close to airports compared with the general population, we used data from the Department of Education that provides this information. These data indicate that m inorities are overrepresented at schools that are located within one kilometer from the centroid of an airport. For example, Hispanic students represent 23% of students at schools located within one kilometer of an airport, whereas Hispanic students represent 19% of students in all U.S. schools (Table 2 ). Black students represent 18% of students at schools located within one kilometer of an airport, whereas black students represent 16% of the student population in the U.S. (Table 2 ). Table 2 . Racial Distribution at Schools w ithin One Kilometer of the Centroid of an Airport and the Racial Distribution at all U.S. Schools.

American Indian / Alaskan Indian Asian /

Pacific Islander Black,

Non Hispanic Hispanic White, Non Hispanic Total

Students* All Number 46,861 154,408 597,223 764,704 1,646,882 3,290,763DRAFT March 16, 2010

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Schools within 1 km of an airport Percent 1% 5% 18% 23% 50%

All U.S. Schools Number 632,237 2,581,822 8,696,565 10,525,763 30,664,231 54,271,986

Percent 1% 5% 16% 19% 57% *T his table includes only those children that identify as one of the five races/ethnicities. A small fraction of students identify as mixed race or ‘other’ and they are not included here, therefore the percent of students does not total 100%. In general, housing and income data suggest that people living in close proximity to major transportation sources (i.e., major roadway s, airports, ports, ra ily ards) are likel y to have lower income than the general population. 168 To evaluate the socioeconomic status of students who attend schools near airports, EPA evaluated the number of students who are eligible for the U.S. Department of Agriculture’s free or reduced school lunch program. Children from families with incomes at or below 130 percent of the poverty level are eligible for free meals. Those with incomes between 130 percent and 185 percent of the povert y level are eligible for reduced - price meal s. 169 Free and reduced lunch eligibility is onl y tracked b y the U.S. Department of Education’s National Center for Education Statistics for students who attend public schools. At public schools that are located within one kilometer of the centroid of an ai rport, 47% of students are eligible for either free or reduced lunches, whereas nationall y, 41% of students at public

168 U.S. Environmental Protection Agency (2007) Regulatory Impact Analysis for the Regulation to Control Hazardous Air Pollutant Emissions from Mobile Sources. Chapter 3, p. 3 - 122. 169 United States Department of Agriculture: Food and Nutrition Service, National School Lunch Program Fact Sheet. Obtained from: http://www.fns.usda.gov/cnd/Lunch/AboutLunch/NSLPFactSheet.pdf , August 3, 2009. For the period July 1 , 2008, through June 30, 2009, 130 percent of the poverty level is $27,560 for a family of four; 185 percent is $39,220 .DRAFT March 16, 2010

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schools are eligible for either free or reduced lunches. As this anal ys is demonstrates, those living in the vicinity

of airports are more likel y to be low - income households and minority residents. We are aware of no studies evaluating blood lead levels among children attending school in close proximity

to airports with piston - engine activity . We are seeking comment and information regar ding blood lead concentrations in children who attend schools in close proximity to airports and the extent to which these emissions cause or contribute to any increases in blood lead levels. 

### 3. Agricultural Activities

Piston - engine aircraft are used i n a variet y of agricultural activities that may introduce lead into the human diet as well as contribute to lead in the environment. The FAA conducts the General Aviation and Air Taxi A ctivity (GAATA) Survey annuall y to obtain information on the general aviation and air taxi fleet, the number of hours flown, and the reasons people use general aviation and air taxi aircraft . 170 , 171 According to the results of the 2007 GAATA Survey (the most recent), aerial application in agriculture and forestry represented 5 % of all hours flown b y general aviation aircraft in 2007. Of the total aerial application hours flown in 2007 (1.41 million hours), 60% of the hours were flown b y piston - engine aircraft. Aerial application activity includes crop and timber production, which involve fertilizer and pesticide application

170 The FAA GAATA is a database collected from surveys of pilots flying aircraft used for general aviation and air taxi activity. For mo re information on the GAAT A, see Appendix A at http://www.faa.gov/data_statistics/aviation_data_statistics/general_aviation/ 171 National Agricultural Aviation Association : “Help the Aerial Application Industry by completing the 2008 General Aviation Activi ty Survey”. Retrieved from: http://www.agaviation.org/2008%20GenAvnSurvey.htm on August 13, 2009DRAFT March 16, 2010

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and seeding cropland. The National Agricultural Aviation Association estimates that there are approximately

3,200 aerial application professional operators and pilots in the United States. 172 As discussed in Section II.C.1, surface deposition of lead onto plants may represent a significant contribution to the total lead in and on the plant. Lead halides, the primary form of lead emitted b y engines operating on leaded fuel, are slightl y water soluble. They therefore may be more readil y absorbed by plants than other forms of inorganic lead. Atmospheric deposition of lead also contributes to lead in vegetation as a result of contact with above - ground portions of the plant (AQCD for Lead, pp. 7

– 9 and AXZ7

– 39; USEPA, 1986, Sections 6.5.3 and 7.2.2.2.1). Livestock may

subsequently

be exposed to lead in vegetation (e.g., grasses and silage) and in surface soils via incidental ingestion of soil while grazing (USEPA 1986, Section 7.2.2.2.2). 173 The l ead concentrati on of plants ingested b y animals is primarily a result of atmospheric deposition of lead particles onto plant surfaces rather than the uptake of soil lead through plant roots. Some of the highest levels of lead exposure among livestock have been attribute d to grazing near major sources such as smelters (AQCD for Lead, Section 2.3.8). Atmospheric deposition is estimated to comprise a significant proportion of lead in food (AQCD for Lead, p. 3

–48) and dietary

intake may

be a predominant source of lead expos ure among adults (greater than consumption of water and beverages or inhalation (73 FR 66971)).

172 National Agricultural Aviation Association : “History”. Retrieved from: http://www.agaviation.org/history.htm on August 13, 2009. 173 U.S. Environmental Protection Agency (1986) Air Q uality C riteria for L ead. Research Triangle Park, NC: Office of Health and Environmental As sessment, Environmental Criteria and Assessment Office; EPA report no. EPA 600/8 - 83/028aF - dF. 4v. Available from: NTIS, Springfield, VA; PB87 - 142378.DRAFT March 16, 2010

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Depending on wind conditions, an aircraft involved in aerial application may fl y onl y 4 inches to 12 feet above the crops. 174 , 175 , 176 The low fl yi ng height is needed to minimize the drift of the fertilizer and pesticide particles away from their intended target. An unintended consequence of this practice is that exhaust emissions of lead have a substantially increased potential for di rectl y depositing on vegetation and surrounding soil. We have not identified an y data or analy ses regarding the contribution of piston - engine aircraft lead emissions to lead concentrations in or on plant tissues, in livestock or the dose that this might d eliver to the human population. We are seeking comments on the potential significance of this exposure pathway . 

### 4. Pilots, Student - Trainees, Passengers Pilots, student - trainees, and passengers are all potentially exposed to lead emissions from piston - engine aircraft that use leaded avgas. General aviation passengers and pilots access their aircraft in areas that are ty pically in close proximity

to runway s. Therefore, these individuals walk near and breathe the air near locations where aircraft are i dling, conducting run - up checks, taxiing, taking off, and landing. In the U.S., general aviation aircraft fl y over 27 million hours and carry 166 million passengers annuall y. 177 Approximately 36 percent of the hours flown by general aviation are for perso nal transportation, 19 percent are instructional flight hours, 11 percent are corporate flight 174 Xiong, Chao. (9 - 23 - 2007) “Future for Crop Dusters is up in the Air”. The Star Tribune. Retrieved on Au gust 12, 2009 from: http://www.startribune.com/local/11606661.html 175 Harpole, T. (3 - 1 - 2007) “That Old - Tim e Profession” Air & Space Magazine. Retrieved on August 12, 2009 from: http://www.airspacemag.com/history - of - flight/old_time_profession.html 176 Peter sen, R. “So you want to be a spray pilot”. AgAir Update. Retrieved on October 9, 2009 from: http://www.agairupdate.com/aau/wannabe/pilot.html 177 General Aviation Manufacturers Association (2008) General Aviation Statistical Databook and Industry Outlook. Available at: http://www.gama.aero/files/2008_general_aviation_statistical_databook__indust_499b0dc37b.pdfDRAFT March 16, 2010

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hours, 11 percent are for business, eight percent are air taxi and air tours and the remainder include hours spen t in other applications such as aerial observat ion and aerial application. 178 According to the 2008 General Aviation Statistical Databook & Industry Outlook report by

the General Aviation Manufacturers Association (GAMA) there were 578,541 pilots in the United States in 2008. 179 Among the pilot populatio n, 75,382 were student pilots, comprising 13% of the total pilot population. The majority of initial pilot training is conducted in piston - engine aircraft. 180 There is no age minimum for pilots to begin taking fl yi ng lessons. 181 The minimum age for conducti ng a solo flight is 16 y ears and a pilot certificate cannot be issued until 17 y ears of age. According to the 2008 General Aviation Statistical Databook & Industry Outlook report by the GAMA, there are 190 student pilots in the 14 - 15 y ear old age group an d 11,562 student pilots in the 16 - 19 y ears old age group. GAMA reports that in 2008 there are 3,846 private pilots in the 16 - 19 y ears old age group. According to the FAA there are more than 500 flight training schools. 182 , 183 The requirement for a private pilot certificate is 40 hours in a non - approved school, and 35 hours in an approved school. However, most people obtain 60 to 75 hours of training before earning their pilot certificate . The general public for whom fly ing is a recreational activity may be the most highly exposed population to lead emissions from piston - engine activity . In addition to their inhalation

178 General Accounting Office Report to Congressional Requesters (2001) General Aviation Status of the Industry, Related Infrastructure, and Safety Is sues. GAO - 01 - 916. 179 GAMA 2008 General Aviation Statistical Databook & Industry Outlook report . Retrieved on August 17, 2009 from: http://www.gama.aero/files/2008_general_aviation_statistical_databook__in dust_499b0dc37b.pdf 180 See http://flighttraining.aopa.org/learntofly/aircraft/ 181 Federal Aviation Administration (FAA). “ Becom e a Pilot

— Student Pilot's Certificate Requirements .” Retrieved on August 17, 2009 from: http://www.faa.gov/pilots/become/student_cert/ 182 Federal Aviation Administration (FAA). “ Ty pes of Pilot Schools & Choosing a Pilot School ”. Retrieved on August 17, 2009 from: http ://www.faa.gov/training_testing/training/pilot_schools/ 183 Federal Aviation Administration (FAA). “Pilot Schools - Search”. Retrieved on August 17, 2009 from: http://av info.faa.gov/PilotSchool.aspDRAFT March 16, 2010

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exposure to engine exhaust emissions, pilots can be exposed to evaporati ve emissions of TEL during aircraft fueling, and fuel sump checks during preflight inspections. 

### 5. Bioaccumulation of Lead in Aquatic Organisms As discussed in Section II.C.2 of this ANPR, lead bioaccumulates in the tissues of aquatic organisms throug h ingestion of food and water. Because of the potential for significant deposition of lead compounds to water bodies, EPA researches and reports on the atmospheric deposition of lead compounds to the Great Waters (the Great Waters include the Great Lakes, Lake Champlain, Chesapeake Bay and many

U.S. coastal estuaries). 184 Alky l lead, in particular, has been identified b y EP A as a Level I Persistent, Bioaccumulative, and Toxic (PBT) pollutant. Level I substances are targeted for virtual elimination through pollution prevention and other incentive - based actions that phase out their use, generation or release in a cost - effective manner within the most expedient time - frame. In 2002, EPA issued the PBT National Action Plan for Alky l - lead to promote further voluntary reductions of use and exposure to alky l lead compounds, including leaded avgas. 185

We are interested in the potential for lead emissions from piston - engine aircraft to be a source of lead pollution to aquatic organisms. Among the approximately 20,000 airport facilities in the United States there are 448 seaplane facilities. L anding and take - off activity b y aircraft at these facilities provides a direct pathway for emission of organic and inorganic lead to the air

184 U.S. Environmental Protection Agency, “The Great Water s Program . ” Retrieved on August 17, 2009 from: http://www.epa.gov/air/oaqps/gr8w ater/ 185 U.S. Environmental Protection Agency Persistent, Bioaccumulative, and Toxic Pollutants (PBT) Program (2002) PBT national action plan for alkyl - Pb. Washington, DC. Ava ilable online at: http://www.epa.gov/pbt/pubs/A lkyl_lead_action_plan_final.pdfDRAFT March 16, 2010

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near/above inland waters and ocean seaports where these aircraft operate. In addition to seaplane facilities, man y airports and heliports are lo cated very close to rivers, lakes and streams, which can provide a direct pathway for emission of organic and inorganic lead to the air near/above inland waters. Lead emissions from seaplane facilities as well as airports and heliports near water bodies c an enter the aquatic ecos ys tem by either deposition from ambient air or runoff of lead deposited to surface soils. As noted in Section IV.A, lead halides (the primary form of lead emitted by

engines operating on leaded fuel) are slightly water - soluble and may

be more readil y dissolved into water than other inorganic forms of lead. The EPA Office of Water maintains a database of the National L isting of Fish Advisories (NLFA) which is made available on the Internet to provide information regarding locall y - issued fish advisories and safe eating guidelines. 186 States, territories, and tribes (collectively referred to here as "states") provide this information to EPA every y ear. The most recent ye ar for which data are available is 2008. States provide information regarding contaminant levels of bioaccumulative toxins measured in fish including lead, mercury , pol ychl orinated biphen yl s (PCBs) and dioxin. Based on these data states issue fish consumption advisories that provide information regarding water bodies for which fish tissue concentrations of these pollutants are found by the state criteria to be safe or unsafe for consumption. The EPA recommends that if fish are detected as having an y m easureable level of accumulated lead in their tissues that this is cause for concern for all consumers, but especially for children and pregnant or nursing women, and that issuing an advisory is prudent. The 2008 NLFA database includes data on lead concentrations in over 23,000 fish from over 1,000 lakes and streams. A mong these fish, lead concentrations were above the anal yt ical 186 U.S. Environmental Protection Agency, “The National Listing of Fish Advisories”. Retrieved on August 17, 2009 from: http://www.epa.gov/waterscience/fish/advisories/DRAFT March 16, 2010

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detection limit in 1,000 fish samples 187 and among the fish in which measureable lead concentrations were reported, the concentrations of lead ranged from 5 ppb to 60,400 ppb. 188 States do not provide information regarding the source of contamination in water bodies where fish tissue concentrations of lead are above detection limits. L ead concentrations in fish tissue samples declined from mean concentrations of 0.28 ppm in 1976 to 0.11ppm in 1984. 189 The decrease in mean lead concentrations was attributed primaril y to reductions in the lead content of motor vehicle gasoline. Sources of contamination of lead to waterway s frequently noted include lead gunshot, lead sinkers, and Superfund sites. 190 Lead emissions from piston - engine aircraft may contribute to fish tissue lead concentrations in water bodies that are in close proximity to piston - engine aircraft activity . In one case, a state reported lead contaminated fish in a lake on airport prope rty . Piston - engine aircraft emissions of lead also have the potential to contribute to fish tissue lead concentrations at water bodies throughout the U.S. due to the emission of lead in flight. These in - flight emissions are greatl y dispersed in the envir onment and have been providing a source of lead to the environment for over 80 years. The Fond du Lac Band of Lake Superior Chippewa, the Leech Lake Band of Ojibwe and the Mille L acs Band of Ojibwe submitted comments to the L ead NAAQS docket noting the imp ortance of fish consumption in their diet. 191 The Fond du Lac Band of Lake Superior Chippewa also noted in their comments, “As a reservation with municipal airport within its 187 In som e instances states supply individual fish tissue sample results and in some instances states supply averages of multiple fish tissue sample results 188 State - specific fish advisories for lead can be down l o aded from: http://oaspub.epa.gov/nlfwa/nlfwa.bld_qry?p_type=advrpt&p_loc=on 189 U.S. Environmental Protection Agency (2000) Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories. Volume 1: Fish Sampling and Analysis. EPA 823 - B - 00 - 007. p.4 - 59. Ava ilable online at: www.epa.gov/waterscience/fish/advice/volume1/index.html 190 U.S. Environmental Protection Agency, “Lead Fishing”. Retrieved on August 17, 2009 from: http://www.epa.gov/owow/fish/anim als.html 191 See Docket ID Number EPA - HQ - OAR - 2006 - 0735. The tribes that submitted comments were: The Bad River Band of Lake Superior Tribe of Chippew a Indians, The Quapaw Tribe of Oklahoma, The Leech Lake Band of Ojibw e, The Lone Pine Paiute - Shoshone Reserv ation, The Fond du Lac Band of Lake Superior Chippew a, and The Mille Lacs Band of Ojibw e.DRAFT March 16, 2010

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exterior boundaries with two schools and tribal housing in close proximity to the airport (one half mile), leaded aircraft fuel is a concern.” The Leech Lake Band of Ojibwe noted in their comments, “ Along with the concerns over the emission inventory, the Tribes have great concern regarding the amount of lead from “small” prop engine a irports. On or very near the Leech Lake Reservation there are seven prop plane airports with many private air strips scattered throughout the area.” EPA is requesting comment on an y information regarding the potential impact of lead emissions from piston - engine aircraft on aquatic environments. 

### B. Related Exposures of Concern While the subject of this ANPR is focused on the emissions of lead from piston - engine aircraft, the use of tetraethy l lead in fuel contributes to additional public health and welfare issues that are also of concern to the Agency . Among these issues are 1) the contribution of lead emissions to ambient PM, especiall y in areas in nonattainment with the PM 2.5 NAAQS, 2) the emissions of ethy lene dibromide to the environment and 3) the evaporative emissions of tetraeth yl lead. 

### 1. Lead Contribut ion to Ambient Particulate Matter As discussed in Section IV.A of this ANPR, lead emitted by piston engines is expected to be predominantl y in the particle phase and will contribute to ambi ent PM. There are two U.S. National Ambient Air Quality Standards (NAAQS) for PM 2.5 : an annual standard (15 μg/m 3 ) and a 24 - hour standard (35 μg/m 3 ). As of March 4, 2009 there are 39 1997 PM 2.5 nonattainment areas. Area designations for the 2006 24 - hour PM 2.5 NAAQS were promulgated in 2009 for 31DRAFT March 16, 2010

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areas. 192 All of these nonattainment areas have at least one airport servicing aircraft using leaded avgas and most nonattainment areas have several airport facilities. The Los Angeles - South Coast Air Basin has 343 airport facilities which have a cumulative lead inventory of 15.0 tons. The contribution of PM - lead to these nonattainment areas ranges from 0.001 to 0.7% of the mobile source PM 2.5 inventory in these areas. In each of four areas designated as nonatt ainment with the PM 2.5 annual standard, there is at least one lead monitor at which design values for 2006 - 2008 are greater than the 2008 Lead NAAQS and two of these counties have PM 2.5 concentrations exceeding the 24 - hour PM 2.5 NAAQS. Reductions in lead emissions in these counties would help bring the area into attainment. 

### 2. Ethylene Dibromide As noted in Section IV.A, ethy lene dibromide (1,2 - dibromoethane) is added to leaded avgas to scavenge lead in order to prevent the deposition of lead oxide to va lves and spark plugs. Emissions of ethylene dibromide are a concern to the EPA. Ethy lene dibromide is classified in EPA’s Integrated Risk Information Sy stem database as likely to be carcinogenic to humans, and a number of chronic noncancer effects have b een observed in animals and humans exposed to ethy lene dibromide by

inhalation and ingestion. 193 EPA developed an inhalation reference concentration, ingestion dose and cancer unit risk estimates for inhalation and ingestion of ethy lene dibromide. 194 Evidenc e of nasal tumors, hemangiosarcomas and mesotheliomas in rodents was used b y EPA to develop inhalation unit risk estimates (central tendency estimates

192 http://www.epa.gov/pmdesignations/ 193 U.S. Environmental Protection Agency (2004) Integrated Risk Information System (IRIS), IRIS Summary for 1,2 - dibromoethane CASR N 106 - 93 - 4. Available online at: http://www.epa.gov/ncea/iris/subst/0361.htm . 194 U.S. Environmental Protection Agency (2004) Integrated Risk Information System (IRIS), Toxicological Review of 1,2 - dibromoethane in support of summary information on the Integr ated Risk Information System. Available online at: http://www.epa.gov/ncea/iris/toxreviews/0361 - tr.pdfDRAFT March 16, 2010

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and 95% upper bound estimates) of 3 x10 - 4 to 6x10 - 4 per μg/m 3

. Evidence of forestomach tumors, hemangiosarcomas, thy roid follicular cell adenomas or carcinomas was used by EPA to develop drinking water unit risk estimates (central tendency estimates and 95% upper bound estimates) of 3 x10 - 5 to 6x10 - 5 per μg/L assuming consumption of 2 Lof water per day by a 70 kg human. EPA developed a reference concentration for chronic inhalation of 9 μg/m 3 based on the critical effect of nasal inflammation and a reference dose for chronic ingestion of 9 μg per kg per day based on the critical effects of testicular atrophy , liver peliosis, and adrenal cortical degeneration. The National Toxicology Program listed ethy lene dibromide as "reasonably anticipated to be a human carcinogen" in the Eleventh Report on Carcinogens in 2005. 195 T he International Agency

for Rese arch on Cancer (IARC) has classified ethy lene dibromide as a Group 2A carcinogen: probably carcinogenic to humans. In the additive package used to dose fuel with lead, ethy lene dibromide is added to achieve a lead - to - bromine atom ratio of 1:2 and a brom ine - to - lead weight ratio of 1:2. 196 The concentration of eth yl ene dibromide in leaded avgas is listed as less than 4 milliliters per gallon (<9 grams per gallon). 197 Since eth yl ene dibromide was measured in the exhaust and evaporative emissions from light - duty vehicles in the U.S. when they were operated on leaded fuel containing ethy lene dibromide we anticipate piston - engine aircraft are currently a source of ethy lene dibromide to air. 198 Measurements of eth yl ene dibromide have not been made that

195 National Toxicology Program (NTP) (2005). 11 th Report on Carcinogens. Public Health Service, U.S. Department of Health and Human Services, Research T riangle Park, NC. Available from: http://ntp server.niehs.nih.gov. 196 Thomas VM; Bedford JA; Cicerone RJ. (1997) Bromine emissions from leaded gasoline. Geophys Res Letters 24(11):1371 - 1374. 197 Chevron Material Safety Data Sheet for aviation gasoline. Avail able online at: http://www.chevronglobalaviation.com/docs/aviation_gas.doc 198 Sigsby, J.E.; Dropkin, D.L.; Bradow , R.L.; Lang, J.M. (1982) Automotive Emissions of Ethylene Dibromide. SAE Technical Paper Series 820786.DRAFT March 16, 2010

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would allow estimation of the exhaust and evaporative emissions from piston - engine aircraft as well as the emissions associated with refueling and pre - flight fuel checks. In addition to contributing to ambient concentrations, ethy lene dibromide may also enter underground aquifers via leaking underground storage tanks or fuel spills. Studies demonstrate that ethy lene dibromide may persist for long periods of time in certain groundwater environments. 199 The EPA established a Maximum Concentration Level (MCL ) of 0. 05  g/L for ethy lene dibromide, which is 100 - fold lower than the MCLfor benzene and 300 - fold lower than the MCLfor lead. The MCLis the highest level of a contaminant that is allowed in drinking water and is an enforceable drinking water standard. 200 The EPA Office of Underground Storage Tanks (OUST) and Office of Research and Development’s National Risk Management Research Laboratory (NRMRL) in association with the Association of State and Territorial Solid Waste Management Officials (ATSWMO) have for med a team to evaluate the potential for public health and welfare effects attributable to ethy lene dibromide from past or present fuel leaks and spills. 201 Among the goals of the EPA/ATSWMO team is to develop information on the distribution of ethy lene dib romide in groundwater at leaking underground storage tank sites in states that do not routinely monitor this contaminant. Water samples for this study were provided by

state agencies to EPA between October 2005 and July

2007. Of the 802 groundwater sampl es provided from 102 sites, ethy lene

199 U.S. Environmental Protection Agency Office of Research and Development (2008) Natural Attenuation of the Lead Scavengers 1,2 - Dibrom oethan (EDB) and 1,2 - Dichloroethane (1,2 - DCA) at Motor Fuel Release Sites and Im plications for Risk Management, Chapter 2. EPA 600/R - 08/107. Available online a t: www.epa.gov/ada . 200 U.S. Environmental Protection Agency, “Drinking Water Contaminants” Available online at: http://www.epa.gov/safe wa ter/contaminants/index.html 201 U.S. Environmental Protection Agency Office of Research and Development (2008) Natural Attenuation of the Lead Scavengers 1,2 - Dibrom oethan (EDB) and 1,2 - Dichloroethane (1,2 - DCA) at Motor Fuel Release Sites and Im plications for Risk Management. p.3. EPA 6 00/R - 08/107. Available online at: www.epa.gov/ada .DRAFT March 16, 2010

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dibromide was detected in 54 samples, 43 of which had ethylene dibromide concentrations above the MCL . 202 These sites did not include anal ys is of groundwater at airports. While not the focus of this ANPR , ethylene dib romide exposure from inhalation or ingestion pathway s is an ongoing concern for EPA , and reduction in the use of leaded gasoline containing ethy lene dibromide may reduce exposure and risk to public health and welfare from ethy lene dibromide . 

### 3. Non - Exhau st Exposure to Tetraethyl Lead

Tetraeth yl lead is a volatile component of leaded avgas. The largest source of tetraeth yl lead exposure is expected to originate from evaporative emissions associated with fuel production, fuel distribution, aircraft refuel ing, pre - flight fuel checks, accidental spills, and fuel tank venting. Pilots check fuel for contaminants by draining a small amount of fuel from each tank sump before flight and after refueling. This fuel is frequentl y deposited onto the tarmac after th e fuel check. EPA is interested in data regarding this practice and any estimates of lead emitted to the air by

evaporation of the alky l lead in the fuel deposited on the tarmac. Alky l lead becomes oxidized in the atmosphere b y direct photoly sis, reactio n with ozone, and b y reaction with hy drox yl compounds. Therefore, depending on ambient conditions, alky l lead may exist in the atmosphere for hours to day s. Pilots, aviation fuel attendants and mechanics are likely to be among the most highly exposed pop ulation to alky l lead. These populations are at risk due to both inhalation and 202 U.S. Environmental Protection Agency Office of Research and Development (2008) Natural Attenuation of the Lead Scavengers 1,2 - Dibrom oethan (EDB) and 1,2 - Dichloroethane (1,2 - DCA) at Motor Fuel Release Sites and Im plications for Risk Management. p.4. EPA 600/R - 08/107. Available online at: www.epa.gov/ada .DRAFT March 16, 2010

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possible dermal exposure. Absorption of inhaled alky l lead into the bloodstream is higher than that for inorganic lead compounds which are generally in particulate form (AQCD for Lead, Section 4.2.1). In addition to exposure to lead in the exhaust emissions from piston - engine aircraft, the PBT National Action Plan for Alky l - lead 203 noted that aviation fuel attendants and mechanics are potentiall y exposed to alkyl lead emissions due to inhalation of alkyl lead compounds released to the air during fueling, via evaporative emissions from spills, or via evaporative emissions from unused gasoline remaining in the engine or fuel tanks. Further, these populations are also at risk beca use of possible dermal absorption of gasoline containing alky l lead compounds. Due to the lipophilic nature of alky l lead and its ability to permeate biological membranes, alk yl lead is absorbed rapidly and extensively

through the skin (AQCD for Lead, pag e 4 - 12). In addition to direct human exposure, runoff and deposition of alkyl lead to waterway s would increase the amount of lead available for uptake by aquatic plants and animals (see Section V.A.7 of this ANPR for more information). 

## VI. Additional Inform ation Av ailable for the NPRM to Evaluate the Potential for

Public Health and We lfar e Im pacts and Considerations Regarding Engine Emission S tandards As noted in the Overview section of this ANPR, in this action we are describing info rmation currently

available and information being collected that will be used by the

203 U.S. Environmental Protection Agency Persistent, Bioaccumulative, and Toxic Pollutants (PBT) Program (2002) PBT national action plan for alkyl - Pb. Washington, DC. Page 14. Available online at: http://www.epa.gov/pbt/pubs/A lkyl_lead_action_plan_final.pdfDRAFT March 16, 2010

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Administrator to subsequently exercise her judgment regarding whether aircraft lead emissions from avgas use cause or contribute to air pollution which may reasonabl y be anticipated to endanger public health or welfare. These additional data will come from lead monitoring being planned to satisfy

requirements of the Lead NAAQS, air quality modeling planned at EPA that is described below and an y information submitted to EPA during the comment period for this ANPR. 

### A. The Lead NAAQS and Lead Em issions from Piston - Engine Aircraft On November 12, 2008, when EPA promulgated revisions to the L ead NAAQS, EPA also adopted revisions to ambient air monitoring requirements for lead, described the approach for implementing the revised standards, and provided an implementation timeline. We describe each of these activities as well as more recent activities below. This section also discusses the most current information available regarding how implementation of the Lead NAAQS may provide additional data on the potential for lead emissions from piston - engine aircraft to cause or contribute to ambient air concentrations that exceed the 2008 Lead NAAQS. Acknowledging that the existing monitoring network for lead is not sufficient to determine whether man y areas of the country would meet the 2008 Lead NAAQS, the EPA re designed the nation’s lead monitoring network to allow assessment of compliance with the revised lead standard. Lead mo nitoring requirements promulgated in 2008 stipulate that, at a minimum, monitoring agencies must place monitors at maximum impact areas where lead emissions are greater than or equal to one ton or more per ye ar. We refer to these monitors asDRAFT March 16, 2010

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source - orient ed monitors. EPA Regional Administrators may waive the source - oriented monitoring requirements if the monitoring agency can demonstrate that emissions from the source will not contribute to maximum air lead concentrations greater than 50 percent of the re vised standard, or 0.075 ug/m 3 . EPA estimated that approximately 135 facilities emit lead at levels over the one ton emission threshold, making them subject to the lead monitoring requirements. Lead monitors are operating at a small number of these sources (described in Section VI.A.2 below). For the remainder, source - oriented monitors are to be operational b y January 1, 2010. EPA also required monitors to be operated in each of the 101 urban areas with populations greater than 500,000 in order to gather information on the general population’s exposure to lead in air. We refer to these monitors as population - oriented monitors. Following promulgation of the 2008 Lead NAAQS and monitoring requirements, the Natural Resources Defense Council, the Mi ssouri Coalition for the Environment Foundation, Phy sicians for Social Responsibility , and the Coalition to End Childhood L ead Poisoning (Petitioners) petitioned EPA for reconsideration of the lead emission rate at which we required monitoring (the “emissi on threshold,” currentl y 1.0 tpy). 204 EPA granted the petition to reconsider aspects of the monitoring requirements and proposed revisions to lead ambient air monitoring requirements in December 2009 (74 FR 69050). Also as part of promulgating the 2008 Lea d NAAQS, EPA described the approach for implementing the revised standards and provided an implementation timeline. EPA will use

204 The petition is available at: http://www.epa.gov/air/lead/pdfs/OAR.09.000.7687.pdfDRAFT March 16, 2010

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county boundaries as the presumptive boundaries for nonattainment areas, and adjustments to boundaries will be made on case - by - case bases. States in which there is sufficient monitoring data made recommendations for areas to be designated attainment, nonattainment, or unclassifiable in October 2009. States update their recommendations to EPA in October 2010 using an y additional monitoring data available from the increased source - oriented monitoring network described above. Final designations of all attainment, nonattainment and unclassifiable areas will be effective no later than January 2012. Where data are sufficient from th e currently existing lead monitoring network, we expect that initial designations will be effective January 2011. States are directed to submit State Implementation Plans (SI Ps) no later than eighteen months after designation, outlining how they will redu ce pollution to meet the lead standards. States are required to attain the standards no later than five ye ars after designation. Additional information regarding the lead standard implementation is available at www.epa.gov/air/lead/actions.html and in the 2008 L ead NAAQS (73 FR 67030 - 67043). 1. Monitoring Lead at Airports to Evaluate Ambient Concentrations to Which Lead Emissions from Piston -

Engine Aircraft Contribute Among the e stimated 135 sourc e - oriented lead monitoring sites, there are four airports where we expect lead monitoring to begin in January 2010. These airports are the Van Nuy s A irport in Van Nu ys , CA; the Phoenix Deer Valley A irport in Phoenix, AZ; the Centennial A irport in Englewoo d, CO; and the Day tona Beach International A irport in Day tona Beach, FL. In each of these areas, we will, as data becomes available, evaluate the impact of lead emissions from piston - engine aircraft on air quality .DRAFT March 16, 2010

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2. Evaluating the Contribution of Lead Emissions from Piston - Engine Aircraft to Areas Approaching or Exceeding the Lead NAAQS In this section we discuss available information and information that will become available in 2010 that can be used to evaluate the potential for lead emissions from piston - engine aircraft to contribute to ambient concentrations in areas exceeding the Lead NAAQS. This evaluation may

include the following: 1) areas currentl y out of attainment or designated as maintenance with the 1978 L ead NAAQS; 2) areas with current lead monitors that are out of attainment with the 2008 Lead NAAQS; and 3) locations that will have new lead monitors to meet the 2008 Lead NAAQS source - oriented monitoring requirements. In each of these areas, we will, as data become available, evaluate the contribution of lead emissions from piston - engine aircraft to lead inventories and air qualit y. The EPA is retaining the 1978 L ead NAAQS until one y ear after designations for the 2008 L ead NAAQS, except in current nonattainment areas. In those areas, EPA will retain the 1978 standard until the area submits, and EPA approves, attainment and/or mainte nance demonstrations for the new standards. Onl y two areas, East Helena, MT (including Lewis and Clark counties), and part of Jefferson County in Herculaneum, MO, are designated nonattainment with the 1978 L ead NAAQS. The industrial facility causing nonattainment with the Lead NAAQS in the East Helena area closed in 2001. Eleven areas are designated as maintenance areas, onl y three of which currentl y have lead monitors. These three locations (Iron County , MO, Dakota County MN, and Collin County , TX) hav e lead monitors with design valueDRAFT March 16, 2010

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concentrations exceeding the 2008 Lead NAAQS. The design value is the highest “rolling” three month average over a three - ye ar period that is relevant for comparison to the level of the 2008 Lead NAAQS. Implementation o f the 2008 L ead NAAQS is underway , and we have not y et designated areas under it. When EPA promulgated the 2008 Lead NAAQS, EPA provided a list of 18 counties with design values exceeding the 2008 lead standard of 0.15 μg/m 3 . Using more recent data from EPA’s Air Quality S ys tem, there are 14 sites at which design values exceed the 2008 Lead NAAQS (Table 3 ). Over 4.6 million people live in the counties where design values are greater than the 2008 Lead NAAQS. After EPA designates areas that currently have sufficient lead monitoring data , no later than October 15, 2010, w e will evaluate the contribution of lead emissions from piston - engine aircraft to lead inventories in nonattainment, maintenance and in some cases, unclassifiable areas, depending on the presence of point sources of lead and the status of ambient lead monitoring in those areas. Table 3 . Counties with Maximum Rolling Quarterly Average Lead Concentrations Exceeding the 2008 Lead NAAQS. County , State EPA Region County Population (2000 Census) Design Value, 2006 -

2008 (  g/m 3 ) Jefferson, MO 7 198,099 2.89 Iron, MO 7 10,697 2.46 Delaware, IN 5 118,769 2.16DRAFT March 16, 2010

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Hillsborough, FL 4 998,948 1.77 Collin, TX 6 491,675 1.26 Pike, AL 4 29,605 1.21 Dakota, MN 5 355,904 0.70 Fulton, OH 5 42,084 0.69 Berks, PA 3 373,638 0.36 Madison, IL 5 258,941 0.28 Lo gan, OH 5 46,005 0.27 Sullivan, TN 4 153,048 0.26 Beaver, PA 3 181,412 0.20 Cuy ahoga, OH 5 1,393,978 0.17 Lead emissions from piston - engine aircraft operating at airports outside nonattainment areas can also contribute to lead measured in the nonattainment area . In addition, other sources of lead that do not, b y themselves, exceed the lead emission monitoring threshold may be located near airports. For example, at some airports i n the U.S., race track venues are located immediately

adjacent to runway s where piston - engine aircraft operate. We are seeking information regarding ambient concentrations of lead that can result from the combined emissions of leaded fuel used in some rac e vehicles, lead emissions from piston - engine aircraft and other sources of ambient lead. The EPA intends to conduct modeling anal ys es to evaluate the contribution of these lead emissions to nonattainment areas and areas that may be approaching nonattainment concentrations. Lead emitted by piston - engine aircraft fl yi ng through nonattainment areas mayDRAFT March 16, 2010

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also contribute to lead measured in the nonattainment area. These emissions would be potentially

challenging to quantify , although a series of sc oping analy ses could be conducted. We seek comment on characterizing the contribution of lead emissions from piston - engine aircraft fl yi ng through areas that are not attaining the 2008 Lead NAAQS and the potential contribution of piston - engine lead emissi ons that may be transported into lead nonattainment areas. As noted above, approximately 135 new lead monitors will begin collecting ambient lead samples starting in January 2010 in order to satisfy

the source - oriented monitoring requirements of the 2008 Lead NAAQS. In the NPRM we will discuss the potential contribution of lead from piston - engine aircraft to these areas where the ambient data suggest lead concentratio ns are close to or exceeding the 2008 Lead NAAQS of 0.15  g/m 3

. 

### B. Additional Information EPA is Collecting to Evaluate Am bient Lead Concentrations Attributable to Em issions from Piston - Engine Aircraft In 2008 EPA initiated a study to provide informatio n regarding the local - scale gradient in lead concentrations on - and near airport facilities with piston - engine powered aircraft activity . 205 This study focused mainly on developing an approach for modeling lead emissions from piston engine aircraft using the Meteorological Societ y (AMS)/EPA Regulatory Model (AERMOD), and evaluating it using air quality measurements. For purposes of local - scale dispersion

205 U.S. EPA (March 2010) Memorandum from Marion Hoyer to the docket EPA - HQ - OAR - 2007 - 0294, titled, “ Work Plan for Air Quality Modeling and Monitoring of Lead .” Em issions from Piston - Engine Pow ered Aircraft . ” Docket number EPA - HQ - OAR - 2007 - 0294.DRAFT March 16, 2010

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modeling, AERMOD is EPA’s preferred model. 206 The approach developed includes apportioning lead emitted during landing and take - off to different altitudes in order to characterize emissions during these modes of operation in a realistic manner. In addition, this modeling study

includes anal ys is of the spatial and temporal emissions from piston - engin e aircraft during the other modes of aircraft operation (e.g., taxi, run - up check, take - off, landing). The modeling results include an evaluation of the relative contributions of all known sources of lead to the local ambient air, including piston - en gi ne aircraft, local traffic, resuspended road dust, and industrial sources within 20 km of the airport selected for our case study. The EPA study at the Santa Monica A irport was recently completed. 207 As part of this work , we collect ed air, soil and house dust samples for lead anal ys is in order to conduct a model - to - monitor evaluation, and to evaluate the potential for lead emissions from piston - engine aircraft to create a gradient in air, soil and house dust concentrations of lead in p roximity

to the airport activities. We selected the Santa Monica municipal airport for this study because of the data available from the monitoring stud y conducted b y the SCAQMD in 2005 - 2007 discussed in Section IV.B of this ANPR . In addition, there are no major point sources of lead in close proximity to the airport, simplifying the model development and interpretation of monitoring results. EPA intends to use this modeling approach to evaluate potential for exceed ance of the

206 The EPA provides modeling guidance for AERMOD at www.epa.gov/ttn/scram/guidanceindex.htm and www.epa.gov/scram001/dispersion_prefree.htm#aermod . A post - processor for AERMOD that reads model output and calculates rolling 3 - mo nth averages for the period modeled to provide lead concentrat ions that can be compared with the Lead NAAQS is available online at: http://www.epa.gov/ttn/amtic/files/ambient/pb/leadpost.zip . 207 The report from this study is posted at www.epa.go v/otaq/aviation.htm.DRAFT March 16, 2010

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Lead NAAQS on airport propert y and surrounding areas, as well as providing an approach to characterize the contribution of lead emissions from piston - engine aircraft to areas wi th ambient lead concentrations currently exceeding the 2008 Lead NAAQS. This modeling approach will also allow us to quantify

the changes in ambient lead concentrations following the implementation of different piston - engine control strategies. The appli cation of this modeling approach to a case - study

airport could also be used as input to conduct a risk assessment evaluating the potential contribution of lead from piston - engine emissions on blood lead levels and IQ deficits for those living near or atten ding school near general aviation activity . We request comment on all information EPA is collecting to evaluate ambient lead concentrations attributable to emissions from piston - engine aircraft and risk posed by emissions of lead from piston - engine aircraft.



### C . Considerations Regarding Engine Em is sion Standards A positive endangerment and cause or contribute finding with respect to the emissions of lead from general aviation aircraft would trigger EPA’s duty to set emission standards. In considering emission standards, EPA would consider control ling emissions from piston engines using aviation gasoline in aircraft . In cooperation with FAA, EPA would evaluate the technical feasibility of a possible phase - down or elimination of leaded aviation gasoline. One option to consider, for example, could be an emissions standard (established under 40 CFR 87) that would require all newl y - manufactured general aviation piston engines to be able to operate with appropriate reliability

and durability

on unleaded aviation gasoline by some future date. Such aDRAFT March 16, 2010

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st andard might require that new engines used in aircraft would have to receive an FAA ty pe certificate that reflects achievement of these requirements under FAA regulations set forth at 14 CFR parts 33/34. Be yond this, EPA recognizes that there is a big ch allenge in dealing with the in - use fleet. Converting in - use aircraft/engines to operate on unleaded aviation gasoline would be a sign ificant logistical challenge, and in some cases a technical challenge as well. In many cases, the implementation of this concept might depend upon efforts and actions of aircraft and engine manufacturers in identifying the necessary modifications and developing hardware as necessary . Depending on timing , these engines might need to be able to operate on either leaded or unl eaded aviation gasoline, or a blend thereof. EPA recognizes that in many cases these modifications could trigger the need for FAA regulatory approval of the modifications for both the engines and airframes. Given the potentially large number of affected aircraft and the potential complexities involved, a program affecting in - use aircraft engines would need careful consideration b y both EPA and FAA and the two agencies would need to work together in considering an y potential program affecting the in - use fl eet. EPA requests comment on this outline of approaches for transitioning the fleet to unleaded aviation gasoline , as well as potential implementation dates, if EPA were to trigger the duty to set emission standards. Comment is also requested on how a program could be best structured to assure that conversions conducted b y engine manufacturers (OEMs), independent sho ps, and in the field by certified power plant mechanics are performed to fully meet the intent of a possible program without compromising the safet y of those aircraft and engines. EPA also asks for comment on potential problems with this approach including suggested modifications,DRAFT March 16, 2010

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improvements, or other approaches. EPA requests comment on how market incentives might be developed to encourage modification to run on unleaded aviation gasoline as part of a regulatory requirement. As part of the responses to the Federal Register notice EPA published in November 2007 entitled “Petition Requesting Rulemaking to Limit L ead Emissions from General Aviation Aircraft,” EPA received a number of comments addressing both technology and fuel - based options as potential measures to reduce or eliminate lead in avgas. 209 In addition to these comments, EPA is aware of completed and ongoing work done under the auspices of the Coordinat ing Research Council and more recent viewpoints and efforts put forth by industry trade associations, airframe/engine manufacturers, specialty vendors, aviation user groups, and other innovators. The work and perspectives of these groups on technology and avgas fuel quality options are important, and EPA asks for further comment reflecting any new data on technology

developments, fuel formulation approaches, or other technical viewpoints. According to Department of Energy data, annual demand for aviation gasoline is very small in comparison to motor gasoline ye t its use is as geographically widespread. This of course creates challenges for supply , distribution, and storage. EPA asks for comment on the avgas refining locations and practices, supply (inclu ding imports and exports, if any), details on distribution to terminals and airports, and storage practices for avgas at terminals and airports across the country . EPA is also interested in comments on progress and timeframes for developing alternatives t o current leaded avgas and how these might be integrated into the fuel supply and distribution sy stem.

209 72 FR 64570 (Nov. 16, 2007); EPA Docket EPA - HQ - OAR - 2007 - 0294.DRAFT March 16, 2010

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### VII. Statutory and Executive Order Reviews Under Executive Order 12866, entitled Regulatory Planning and Review (58 FR 51735, October 4, 1993), this is a “significant regulatory action” because of the cross - agency nature of this issue. Accordingly , EPA submitted this action to the Office of Management and Budget (OMB) for review under Executive Order 12866 and any changes made in response to OMB recommendations have been documented in the docket for this action. Because this action does not propose or impose any requirements, other statutory and Executive Order reviews that appl y to rulemaking do not apply . Shoul d EPA subsequently determine to pursue a rulemaking, EPA will address the statues and Executive Orders as applicable to that rulemaking. Nevertheless, the Agency welcomes comments and/or information that would help the Agency to assess any

of the followin g: tribal implications pursuant to Executive Order 13175, entitled Consultation and Coordination with Indian Tribal Governments (65 FR 67249, November 6, 2000); environmental health or safety effects on children pursuant to Executive Order 13045, entitled Protection of Children from Environmental Health Risks and Safety Risks (62 FR 19885, April 23, 1997) and human health or environmental effects on minority or low income populations pursuant to Executive Order 12898, entitled Federal Actions to Address En vironmental Justice in Minority Populations and Low -Income Populations (59 FR 7629, February 16, 1994). The Agency

will consider such comments during the development of any subsequent rulemaking. Dated_____________

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Lisa P. Jackson, Ad ministrator Advance Notice of Proposed Endangerment Finding for Lead Emissions from Piston Engine Aircraft Using Leaded Aviation Gasoline page 103 of 103