Cast iron DWV pipes are chemically reactive with water and wastewater. Both the quality of the wastewater and product durability are adversely impacted when cast iron pipes are used. In addition, the manufacturing of cast iron and cast iron pipes involves processes that have significant adverse environmental impact including the discharge of dioxins and greenhouse gases. Cast iron pipe manufacturer, McWane Corp. of Birmingham, Ala., and three of its executives were convicted in federal district court June 10 of violating the Clean Water Act. James Delk, former vice president; Mike Devine, a former plant manager; and Charles Robinson, vice president of environmental affairs, were all convicted on charges stemming from illegal dumping of wastewater contaminated with lead, zinc, oil and grease from the McWane cast iron pipe plant in Birmingham into a nearby creek. Delk, Devine and the company also were convicted of conspiring to violate the act, which carries a potential jail term of five years and a fine of $250,000. Robinson and McWane Corp. were convicted of making false statements to the Environmental Protection Agency. McWane Corp. faces a $50,000 per day fine for the 11-month period of pollution and five years of probation for its conspiracy and violations of the Clean Water Act. Sentencing will be on Oct. 25.

The Vinyl Institute is not aware of any information directly addressing this question. However, we believe that this is very important data to have if the Task Group is going to have comparable information for vinyl manufacturing facilities and alternatives.

The Draft Task Group report contains such information for vinyl facilities but there is no comparable information for alternatives. Toxics Release Inventory ( http://www.epa.gov/triinter/tridata/index.htm )and LCA data indicate that there are emissions from the facilities producing alternative materials. The Task Group report points out that Vinyl is a very well studied building material compared to the alternatives. The PVC Task Group database has nearly 1000 studies for vinyl but there is very little data for alternatives as indicated by this data gap for alternatives.

An addition to my first set of comments on fenceline exposure for alternative materials.

Given the lack of data for fenceline exposure for alternatives, the Task Group could identify this as an important data gap. In my opinion, it is not required that the Task Group delay the final report in an attempt to fill this data gap given the draft report's findings on fenceline exposure from vinyl manufacturing. If the Task Group changes its conclusion on fenceline exposure from vinyl manufacturing, data for alternatives would become essential for a fair comparison.