Document B7V5Ogyr5qpgEz31BDyrj31o

September 4, 1993 TO: L. C. Ambler FROM: J. Himmelberger CC: B. Jo C. Pontz SUMMARY OF NOTES: 9/2/93 Uni-Bell Sub Committee of Potable Water Pipe Producers meeting. ATTENDEES: Jim Rash Tom Torquevey Elroy Smith Bud Layton Dennis Bauer Dave Eckstein Dr. Nina McClellan Ken Smith Art Kahn PW Ipex Diamond JM ETI Uni-Bell NSF NSF Dave E. did a quick review of the summary sent out covering the EPA/Industry meeting held August 16, 1993. He also handed out a map showing the states deemed to have Rural Water Districts that contain systems that could potentially be troublesome. The attached map indicates the number of RWD in each state. It should be noted that the map does not take size into consideration. Some of the systems in the north contain hundreds of miles of pipe in them. REVIEW OF ACTION ALTERNATIVES Sampling Program Discussion on this topic consumed about half of the meeting time. F-EPA -- Peter^CookT^ Deputy, Director^and.. top. EPA. man _ at^the, meeting ^stronglyisuggested.that A-sampling'program be-conducted, and"that ^Industry- should pay for it. The program has to be statistically and scientifically sound enough to withstand peer review. He indicated that if the program shows a small problem then a small response can be expected from EPA, if a big problem, then ------------- Vinyl- Institute - The Issues and Management Committee, which is the body within The Vinyl Institute (VI) that is responsible for action on this issue, has reportedly agreed that a sampling 1' CTL032761 ^program?is^apjjroprfate. It is understood that the sampling ^^og^ifT^i's^to "`assess the magnitude of the problem. In an attempt to meet EPA's statistical criteria for the program, VI has had Dow's head statistician develop a proposal for the sampling program. It was discussed (at length!!!) at this meeting, and is very complicated. I'm^sure it will be discussed at length at the Sept. 7th meeting. f*Therbottom::lirie*is*_J&at~the- recommended {^progranVwi 1 consistofapproximatelyfeoff sampled...1 bD./ea Prease*understand this is just for lab fees to NSF *" does not include any cost for gathering, shipping, or coordinating the project. This is a bio project. and tr~ /ysLvJvTM' note: NSF's list price for these samples is $280 and Dr. McClellan pushed Ken Smith down to $150, she tried to get him to commit to $125. My impression from this incident and other things said at the meeting, that NSF wants to-be a very cooperative partner in this situation. c~:ThisTrecap `doesn't" come closeJto. capturing^ the^amount of tdiscussioxu-tiiatr-tobkl placeMy*...thoughts_.on...ttieTma jor issues. that `must-be_satisfied by this"statistical" approach for random ^sampling - are:-- IJCSatisfy-EPA )^^^SS^g.ques,tiorstp^^iQi^i:ea.l^bliei problea;;is^ ^ ^ f^X^lowSthei>Ind\ist]ry&t6>imequivocairy: claimthat post. NSFfFbertifiedpipe-will^not- cause^a^VCM problem^ /System^Modelt rantsFatTmodel? that- can| be-used^tb1- "predict"* potentially.-. iblesomeisystems.Svi^ S^UniyEell^ ac^cee,'with^ this, . and a .modelj BSeing^deyeloped'- to^accomplish"- this. '-TtT is" 'due'"to'"be completed bytdct^JLstr.' Time will not permit the model to be checked against any systems other than Doniphan #5, which is being used to develop the model. There is a high degree of Industry - ... nee m this effort due to it's author (Dr.-Al Berehs). rRemediation-Recommendations The VI is pursuing viable remediation recommendations. Current f^Efeedbacki suggests-that: thereis-, nothing out..- there right now. ....Filters,'treatment, lining, forced flushing, etc., are being_____^ looked at but there does not seem to be an obvious answer. -This r~also"should be-a majorjtopic of discussion.on the 7th, as EPA.is ^expiectTng answers: on Oct.- 1st .1' These three-issues represent the external topics for which EPA is hexpecting answers. The following are subjects of an internal nature that were discussed, OcJ- I Speaker Packets This subject is an extension of the media response sheet that is CTL032762 in circulation. Dave E. feels that when this problem gains in public awareness, the Industry needs a better damage control program. For now, I think Uni-Bell will mention this subject to VI as an open issue. Involving Non Uni-Bell/VI Members . The consensus of the group is that other manufacturers need to become involved for two reasons. 1) So they can respond with the same story as the rest of the Industry. 2) Possibly participate in the funding. We were told by Dave E. that VI feels this "notification" should take place when the whole package is laid in EPA's lap (ie. when all sampling is done, etc.). I don't's think that Uni-Bell agrees with this, but they have no clear "but recommendation. One thought was to discuss the issue at the PPFA meeting in Oct. I am sure this will be discussed on the 7th. ^Funding fjfEPA;. has-jmadeflt| clear^they^ feel"7the7I^dustry^sliouid` stepTup! big/# time`f?#feUnl:Beli^ieaLns2LvervSiieaviiv:l:6ward"rvr: funding; tfiis?' *" * gTpro jectS^They^-feei^it-;-is- technically-a- resin~issue~ but*' realize' ^fromtaimarketing^viewpoint-itrisiatpipe^issuet This position does not allow Uni-Bell to take a strong stand on pushing VI real hard to fund_the_whole,,project. While it will be discussed on the 7th, n^don't?think-.Uni-Bell'-'hasaTcl'ear^cut; position. ll|Prcri ect^Lead Currently VI seems very content (reportedly pleased) to have Dave E. lead the project. Jim Rash has some strong feelings the VI is not "interested" enough, and this makes him very uncomfortable. All seem to agree with this in concept, but feel that if they push the issue and turn the lead over to VI, progress will grind to a halt. I think strong feelings on this subject, will.get^^^. expressed on the 7th. "Again, my~opinion is"that Uni-Beil-wants*^ito.: keep_ control, but they, want a. stronger- commitment- from- VI-.-- fgrRisk""Assesiment Work is being done on a "new" approach to risk assessment. The methodology is different from what EPA has used to develop their 2ppb threshold, although reportedly EPA has allowed/used it is some other risk assessments. The people at Dow have used this methodology to assess the VCM risk. It is hinted to show that 25ppb is a more appropriate level of concern. Nobody thinks EPA will buy this number because EPA has a 5ppb threshold set for carcinogens that are considered less dangerous than VCM. As a result, I don't think this will even be mentioned to the EPA. CTL032763 The feeling seems to be that the work will have some long term value should liability become an Industry problem. More Personal Comments I do not see Uni-Bell going into the meeting on the 7th with much in the way of departure from Vi's position on the major issues. VI agrees on sampling (probably at Industry's expense), providing a model, and suggesting viable remediation procedures. With this done, VI then intends to tell EPA it's you baby and walk away. This is the one point, on which, Uni-Bell strongly disagrees. Uni-Bell feels if the samples show a problem more serious than anybody now thinks exists, then Uni-Bell doesn't want to walk away. It is my understanding that your delegation has one hour on the agenda -- I'd bet a dollar to a donut that you are there longer than that. ~- CTL032764 TOTAL RURAL WATER DISTRICTS BY STATE CTL032765