Document O3enaaEYQ37p4z8pQgrqnkQqQ

r < /t/d PRELIMINARY SURVEY OF CHEMICAL COMPOSITION, CONTAMINATION, AND ASSOCIATED HEALTH HAZARD OF PLASTIC PIPE FOR POTABLE WATER SUPPLY 1 NOVEMBER 14, 1980 THOMAS REID ASSOCIATES PALO ALTO, CALIFORNIA BFG07240 20823001 PRELIMINARY SURVEY OF CHEMICAL COMPOSITIONr CONTAMINATION AND ASSOCIATED HEALTH HAZARD OF PLASTIC PIPE FOR POTABLE WATER SUPPLY NOVEMBER 14, 1980 THOMAS REID ASSOCIATES Palo Alto, California Thomas S. Reid Karen G. Weissman, Ph.D. Barbara Castro Carol Manahan Tay Peterson BFG07241 n READER'S GUIDE This study is a preliminary survey of the chemical constituents of plastic pipe, potable water contamination, and the associated health hazard. The study was prepared by Thomas Reid Associates (Palo Alto) under contract to Thomas R. Adams, Adams, Broadwell and Russel attorneys representing Local 467 Plumbers and Steamfitters Union, AFL-CIO. The material Is an Informational submission to the California Housing and Community Development Commission. The study specifically addresses proposed amendments to the Uniform Plumbing Code (Section 401 (e})> Five kinds of plastic pipe are being considered for domestic potable water use in residential construction: polyvinyl chloride (PVQ, chlorinated polyvinyl chloride (CPVC), acrylonitrile-butadiene-styrene (ABS), polyethylene (PE), and polybutylene (PB). Contamination of the water supply by plastic pipe constitutes a health hazard. The purpose of this study is to indicate the scope of the problem which must be considered in order to fully evaluate the degree of the health hazard. In this study we consider the population at large -- the families that will be using water from installed plastic piping systems. We do not consider the hazards of occupational exposure for people installing the plastic piping systems. Chapter I introduces the philosophy of the study, describes the methods used, and the limitations of the results presented here. The reader is invited to pay particular attention to the limitations. Assessing the hazard of plastic pipe is a complex task and this report is intended only to give an indication of the extent of the problem. Chapter II describes the range of chemical substances which can be present in pipe applied to domestic water service. This is the starting point of the study: if a substance is present in the pipe, then it may be a contaminant. Chapter III assesses the likelihood that chemical constituents will actually contaminate the water supply and be communicated to the population at risk. This includes a discussion of the water analyses conducted by Montgomery Laboratories for the Department of Health Services, Hazard Evaluation System (HES). Chapter IV summarizes information available on the health effects of some of the compounds. This gives an indication of what the impact might be on the population at risk. C&QEZ80I r >i TABLE OF CONTENTS Chapter Summary Title S-l I. Introduction A. Approach B. Methodology Used in This Study C. Limitations 1-1 1-1 1-2 1-2 II. The Chemical Constituents ofPlastic Pipe A. Basic Types of PlaaticUsed for Pipe 1. Polyvinyl Chloride (PVC) 2. Chlorinated Polyvinyl Chloride (CPVC) 3. Acrylonitrile-butadiene-styrene (ABS) 4. Polybutylene (PB) 5. Polyethylene (PE) Il-l II-l Il-l I1-3 II-4 I1-4 II-5 B. Summary of Test Results II-5 III. Contamination III-l A. General Considerations IXI-1 B. Test Data XII-2 /' 1. Numerical Interpretation of Montgomery Data IXX-3 (x 2. Montgomery Data Reliability III-9 IV. Possible Effects onPopulation atRisk A. Population at Risk B. Exposure C. Types of Effects 1. Background 2. Observed Effects of Those Chemicals Found in Water from Plastic Pipe 3. Hazard Assessment IV-l IV-l IV-2 IV-3 IV-3 IV-5 IV-8 Appendix A -- Known Plastic Constituents and Commercial Additives Appendix B -- Partial Toxicology Literature Abstracts A-l B-l i Oi^3 * LIST OF TABLES Number Il-l III-1 III- 2 IV- 1 IV-2 Title ' Impurities Detected in ABS, PVC, and CPVC Plastic Pipe Highest Concentrations of Compounds Tested by Montgomery Labs Concentration as a Function of Elapsed Time and Dwell Tine Summary of Findings from Preliminary Literature Review Likelihood of Contamination by Formally Recognized Carcinogens -3L ii r Page II-7 XXI-5 HI-8 XV-5 XV-7 c \ SUMMARY This report examines the chemicals found in those plastic pipes under consideration by the California Commission on Housing and Community Development for use for potable water supply. Generically, the five types of pipe are acrylonitrile-butadiene-styrene (ABS), polyvinyl chloride (PVC)r chlorinated polyvinyl chloride (CPVC), polyethylene <PE), and polybutylene (PB). He consider which chemicals found in the pipe can enter the water supply and the health risks posed by these. Only with a complete understanding of this can a reasonable decision to license these materials be made. At this time, the necessary understanding is seriously deficient and there is no proof that plastic pipe for water supply does not pose an unacceptable public health hazard. The major findings of our study are as follows: (1) There is a wide variety of chemical substances present in the five types of plastic pipe* In addition to the polymers ("plastic") making up the bulk of the pipe# there are compounds used in the manufacture of the pipe such as solvents, monomers, plasticizers and stabilizers, as well as impurities and reaction products between other chemicals. Earlier data and a November 1960 analysis of some of the pipe in question by California Analytical Laboratories, Sacramento, show that the impurities include known carcinogens such as chloroform, benzene, acrylonitrile, and styrene, as well as other compounds on the EPA list of priority pollutants. (2) The James M. Montgomery labs report is the only study we know of to date which addresses the question of which substances present in plastic pipe can enter the water supply. Our review of this report supports our conclusion that this single study is not a sufficient basis for a decision to license the five kinds of pipe under consideration. Our conclusion is based on the following definite limitations of this report: (a) The Montgomery study only examined a previously agreed on list of compounds, selected because they were priority pollutants or known solvents. It was not an attempt to analyze all actual contaminants from plastic pipe in the water. It is dangerous to assume that Montgomery had done an exhaustive analysis of all possible pollutants, when this was not the case. (b) The Montgomery study only examined two kinds of pipe, PVC and CPVC, each made by a Bingle manufacturer. The results cannot be extrapolated to ABS, PE or PB pipe, or even PVC and CPVC pipe made by other manufacturers. A review of plastics literature and a search of U.S. patents revealed that the manufacturing processes of different pipe fabricators can be quite different, and that the same manufacturer can change its process from time to time. A different process or a different kind of pipe means that different amounts and different types of chemicals have the potential to contaminate the drinking water supply. Obviously, the Montgomery study only shows the potential risk from the pipes it examined. S-l rV A i.T/m&nmhr--jA- r (c) The Montgomery results themselves do not allow reliable statistical inference that there is any method of pre-treating the pipe before use (ie. flushing) which will reduce the public health hazard from chemical contaminants. Although flushing is an intuitively attractive idea, there is no data to prove it effective or to show how long flushing is required. (d) Among the problems encountered in the Montgomery tests were the problem of resolving too many compounds, high levels of solvent interference with compounds of interest, .presumably a large residual set of unanalyzed material, and too few replicates of individual tests. The Montgomery study is an adequate first attempt at a very difficult technical problem, but its results are preliminary in the extreme. Only a large-scale study of water contamination from all types of pipe would support the decision at hand. If any conclusion is to be drawn from the Montgomery data, it must be conservative? that is, the data presented show at least some high values for each contaminant in the water and these should be considered in interpreting the health hazard of the system. (3) The population at risk exposed to the substances in the pipes will be all of the occupants of new homes outfitted with this material. This population will ultimately comprise millions of persons of all ages and both sexes. Among the population at risk will be individuals with high sensitivity to toxic, carcinogenic, mutagenic, and teratogenic substances, such as young children or pregnant women. They will be exposed to these compounds through drinking water, cooking water, bathing and even laundry. While the government tries to protect the health of these sensitive individuals, as with careful control of drugs, the dose of chemicals they would receive from the plastic pipe would be uncontrolled and unregulated. (4) In addition to a human health risk there is a definite risk to the environment from the waste discharge of water flowing through plastic pipes. The subject chemicals will add to the existing load of pollutants known to have serious environmental effects because they display all of the characteristics of such chemicals. Namely, they are toxic or carcinogenic, are selectively partitioned into and accumulated in living organisms and food chains, are persistent (long half-lives) and may be widely dispersed in the environment. The conservative levels of carcinogens and other toxins found in the Montgomery study are tens to hundreds of times greater than the EPA "acceptable risk levels" (1 cancer in 1 million persons exposed). At best, the licensing of plastic pipe for potable water will expose a large population to long term, low-level, chronic toxicity of unknown danger. At present, the data concerning chemicals in the pipe, the levels entering the water supply over time, time population health effects, and the environmental effects are incomplete and inconclusive. What evidence there is indicates that the chemicals present a potentially serious risk. In the absence of conclusive information to the contrary, a blanket decision to license PVC, CPVC, ABS, polyethylene and polybutylene pipe for domestic water supply cannot reasonably be supported. f c 20823007 S-2 TABLE IV-2 LIKELIHOOD OF CONTAMINATION BY PORMALLY RECOGNIZED CARCINOGENS Compounds Expected Pound in Pound in4 (used in mfg) Pipe4 water OSHA list of Carcinogens3- 2-Acetylaminofluorine 4-Aminoblphenyl Benzidine 3,3*-Dichlorobenzidlne 4'-Dimethylaminoazobenzene alpha-Naphthylamine beta-Naphthylamine 4-Nitrobiphenyl N-Nitrosodimethylamine beta-Proplolactone bis-(chloromethyl)ether Chloromethyl methyl ether 4,4'-Methylene-bis(2-chloroaniline) Ethyleneimine Asbestos2 Benzene2 Coal tar volatiles - coke oven emissions2 Vinyl chloride2 2 Strong Carcinogens Benz(a)pyrene 2.4-Diaminotoluene Dimethylcarbamoyl chloride 1,1-Dimethylhydrazine (and salts) Dimethyl sulfate Hexamethylphosphoramide Hydrazine (and salts) N-(2-Hydroxyethyl)ethyleneimine Methylhydrazine (and salts) 2-Sitronaphthalene Nitrosoamines Propane sultone Propyleneimine 2 Experimental Carcinogens Acrilonitrile 3-Amino-l,2#4-triazole Carbon tetrachloride Chloroform 1.4-Dichloro-2-butene Dioxane Epichlorohydrin Ethylene dibromide Ethylenethiourea Lead chromate Methylenedianiline Styrene IV-7 BFG07274 S9OE2S02 "T APPENDIX A -- KNOWN PLASTIC CONSTITUENTS AND COMMERCIAL ADDITIVES The polymer industry stakes use of hundreds of chemicals in manufacture of commercial plastics. The following pages list several classes of additives to illustrate the range of substances that may be in plastic pipe. The significance Is twofoldt 1) these substances complicate the analytical problem of analysing what is in a pipe sample or in water from a pipe* and 2) these substances may not have been subject to adequate toxicological screening. The lists are taken from T.R. Crompton Chemical Analysis of Additives in Plastics 2n edition* 1977 Pergamon Press* New York. A-l BFG07277 20823038 Antloxidant9 1 Topenol A 2,4-Diethyl-6" t-butylphenol 2 Topenol OC 2,6-Di-t-butjrl4-mathylphenol 3 Tenox HU Mixture of 2" and 3-c-butyl"4hydroxyanisole 4 Binox M Bis(3,5-dl-t-butyl t-hydroxyphenyl) ethane 5 lonox 330 l,3,5-Tri*echyl-2, 4,6-tris-(3,5-dit-butyl-4-hydroxybenzyl)benzene 6 Nonox VSF Bi(2-hydroxy-3-oaethyl-cyclobexyl5-aethylphenyl)ethane 7 Nonox VSL 2,4-Oinethyl-6-aaethyl-cyclohexylphenol 8 Nonox DCP 9 Calco 2246 2,2-8is(3-ethyl-4hydroxyphenyl) propane Bia(2-hydroxy-3t-butyl"5-*eehylphcnyl)M thane 10 Topenol CA 1,1,3-Trie (2-a#ethyl -4-hydroxy-5"tbutylphenyl)aethane 11 Santonox B Bis(2-*ethyl-4hydroxy-5-tbucylphenyl) aulphide 12 Topsaol 7? Bi(2-hydroxy-3,5di-t-butyl-6nethylphenyl)sulphide 13 Suconox 18 N-Stearoyl-paninophenol 14 Naugavhicc Bis(2-hydroxy-3nonyl-5"ethylphenyl)aethenc IS Agerite Superlite - 16 Voidox 1001 2,6-Di-t-butyl- 4-oethyl phenol * eorbitan/fatty acid cootpound 17 Irganox 1010 Pantaerythritolcetra-B-(3,5-di-t -buty1-4-hydroxyphenyDpropionace 18 Irganox 1076 n-OctadeeylB-(3,5 -di-c-butyl-4- hyd roxypheny1) propionate 8l^0OdH A-2 19 Irganox 10931 Di-n-octadecyl-3,5 -di-t-butyl-4hydroxybenzyl phosphooatt 20 Polygard 21 Nonox Cl 22 DLTDP 23 Selol 24 Cyasorb UV9 Trie(nonylpheny1) -phosphite N,N'-Di-6-oaphthylp-phenylentdlamina Dilaurylthiodipropionaee Fhenylsalicylace 2-Hydroxy-4-mathoxybenxophenone 25 Cyasorb UV 531 2-Hydroxy-4-noctoxybentophenone 26 Uvinol 400 2,4-Dihydroybensophenone 27 Cyasorb UV 2,2'-0ihyd roxy-424 methoxybenzophenone 28 Tinuvin P 2-(21-Hydroxy-5'methylpheny1)bentotriazole 29 Tinuvin 326 2-(21-Hydroxy-5't-butylphenyl)3-chlorobensotriazole AgoRite Alba Agefcite Spar AgeRite Superlite Antioxidant 5 Antioxidant 425 Antioxidant 2246 Dsenax Xonol 1-Naphthol 2-Naphthol NauRavhite Nevaatain A Navaatain 8 Nonyl phanol f--Phenyl phenol Polygard Santovar A Santovax 0 Santovhite Cryatals Santovhite MX Santovhite Powder Solux Scabilite white powder Styphen 1 Vingseey S Vingstay T Hydroquinone noaobenzyl ether Styrenated phenol A polyalkyl polyphenol Not discloeed 2,2r-Methylen-bia (6-tert- butyl-4-methylphenol) 2,2'-Kethylenebia (6-tertbutyl-A-vethylphenol) Z,6,Di-tert-butyl-p-cr*sol 2,6-0i-tert-butyl-j-cresol l-Kaphthol 2-Naphthol Alkylated phanol Not dieclosed Not diacloaed Nonyl phenol p-Phenyi phenol Trie (nonylatad phenyl) phosphite 2,5-Di-tert-anyl- hydroquinone . 2,5-Di-cert-butyl- hydrequinone 4,4'-Thio-bia (6-tert- butyl-Z-methylphenol) Reaction product of 6-tert- bucyl-ffl-creeol and SClj 4,4'-Butylid*ne-bis (3- methyl-6-t*rt-butylphenol) N-p-Hydroxyphenyl^rpholina Not diacloaed Styrenated phenol Styrenated phenol A hindered phenol \ 20823033