Document B8Ndq0QrVKqekX5b2v67m6v0E

The Vinyl Institute 1Ao P f A VI3TA POLYMERS LVC. Way o3 1985 PVC BUSINESS AREA May 23, 1985 TO: FROM: Subject: Vinyl Institute Technical Committee-- Vinyl Institute Codes and Regulatory Committee Roy T. Gottesman NSF Standard for PVC Pipe I believe you will find the enclosed letter from the Vinyl Institute's General Counsel, Jerome Heckman, of interest. RIG: enclosure r \ A Division of THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 355 LEXINGTON AVENUE NEW YORK, NY. 10017 (212) 573-9400 VAB.0001183452 JOICM C. KELLER JEROME H. HECKMAN CHARLES M, HUMAN WILUAM H. OWNllANl, JN. HALCOLH O MACAUrHUR MAVNI V. VLACII MANTIN W. MUeOVlCl JOHN S. CLOMO CAROLS C. MAURIS MICHAEL F, MORROWS LARRY S. SOLOMON JOHN s. ouascw PETER L. * bA CRUX Christine a. msaohsr shirley a. FUJIMOTO LAWRENCE P. HALRRIN MARR FOX CVCN9 RALPH A. SIMMON* C. DOURLAS PETER A. SUMO SMCI LA A. MILLAR RUSSCLL H. FOX LCt M. WEINER ILCNC RINOCL HCLLCR SUSAN J. SLUM HARM C- HAYES* DC REft A. SLOOM SANDRA J.P. OCRNIS KCNNCTH A. ONI44. JR. AOMITTCO IN NSW YORK AND VIROIMIA ONLY LAW OFFICES Keller and Heckman 1150 17T STREET, N.W. SUITE lOOO WASHINGTON, O.C. 20035 (202) 457-1100 May 20, 1985 RECEIVED MAY 2 21985 DR. R. T. GOTTETMELMEXM TELECOPIER (SOCI IS7I CASLt AOORCSS "ftCLMAN WRITER'S DIRECT DIAL NUMtCN 202/457-1110 Dr. Roy T. Gottesman The Society of the Plastics Industry, Inc. 355 Lexington Avenue New York, NY 10017 Re s NSF Standard for PVC Pipe Dear Roy: The purpose of this letter is to provide you with an abbreviated synopsis of my discussions with Nina McClelland of the National Sanitation Foundation (NSF) concerning the rumor reported at the recent Vinyl Institute meeting that NSF might be moving to reduce the permissible residual vinyl chloride monomer (RVCM) level in polyvinyl chloride (PVC) potable water pipe from 10 parts per million (ppm) under current NSF standard 14 to 2 parts per billion (ppb). What is actually happening here flows from the general knowledge I think we have all had for quite some time that, in the near future, the Environmental Protection Agency (EPA) is expected to issue a regulation under the Safe Drinking Water Act (SDWA) limiting the amount of vinyl chloride in water to 1 ppb, just as other "contaminants" will be so limited. In anticipation of this EPA regulation, NSF is trying to establish, if possible, the relationship between the RVCM level in pipe walls and the amount of vinyl chloride monomer that might be expected to migrate into water. When the current 10 ppm standard was set, it was based on finding no detectable VCM migrating into water with a test sensitive to 50 ppb. NSF is now trying to determine what vinyl chloride monomer, if any, might be detected in water using a more sensitive analytical method than one geared to 50 ppb. The results of this test could be combined with other tests using pipes with lower RVCM levels. With this information, NSF feels it would be in a better position to respond to any antici pated EPA action. VAB.0001183453 Dr. Roy T. Gottesman May 20, 1985 Page 2 Keller and Heckman The suggestion that NSF is moving towards a 2 ppb RVCM limit in pipe is simply incorrect. Apparently, a comment was made that the revised standard would be somewhere between 10 ppm and 2 ppb. This was only meant to highlight the two ends of the spectrum but in no way reflected an NSF decision or predilection to move to the lower detection limit. I trust that this will adequately summarize a signifi cant part of my telephone report to you. If you have any comments or questions, or if I can be of any further assist ance pending our giving you a more complete report on the relationship between this situation and some new developments in the "water additives" area that we want you to know about, please let me know. Cordially yours cc Don Goodman VAB.0001183454