Document 2JVm3GRVLXJ19vQa0QjGa1qBp

ASBESTOS INFORMATION ASSOCIATION KORTH AMER'CA 1835 K Street, N.W., Washington, D C. 20006 (202) 223-4885 t 27 October 1976 Dr. Andrew Breidenbach Assistant Administrator for Water & Hazardous Materials Environmental Protection Agency 401 M Street, S.W., Rm W-1037 Washington, D. C. 20460 ' Dear Dr. Breidenbach: I am sorry I was unable to meet with you this past Friday to discuss the use of asbestos cement pipe and asbestos brake and clutch linings as a "sample research request" in the Request For Proposal No. WA 76-B231, distributed by EPA letter of August 2, 1976. I know John Autry of Johns-Manville Corp. and Joseph Jackson of the Asbestos Cement Pipe Producers Association ably voiced the industry's objection to the use of these locked-in asbestos containing products as the single example of "sample research request," Enclosure IV, for possible studies on the economic impact of selected control options for particular toxic substances. 4 The EPA letter came to our attention only a few days ago.. We were surprised that we did not have the opportunity to discuss the contents of Enclosure IV of the document with , your people. As you know it is an objective of this Association to maintain close liaison and cooperate fully with EPA in those matters of mutual interest. Certainly, even in a "sample research request" it is less than fair anfl highly presumptive to suggest a requirement} "that no A/C, pipe be produced or installed in the U.S. from two (2) years from a specified date" or "no asbestos containing friction products be utilized in any motor vehicle produced or im ported into the United States from two (2) years from a specified date." We are unaware of any sciehtific data that would justify the extreme suggestions contained in the "sample research request." We believe public distribution of Enclosure IV to the EPA letter can in itself have an adverse impact on the asbestos industry even if not intended.f Though asbestos has recently . been listed among 65 toxic pollutants, to single out products FMSI-0299 FMSl 03186 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. P.C. 20460 AUG 1973 Gentlemen: Subject: Request for Proposal No. WA 76-B231 You are invited to submit to the Environmental Protection Agency a proposal for a study of the Economic Impact of 7^^ Selected Control Options for Particular Toxic Substances. ` " The Period of Performance for completion of the work called for in the enclosed Statement of Work will be 24 months. It is anticipated that a Cost-Plus-Fixed-Fee (CPFF) term contract will result from this solicitation; however, the Government reserves the right to award another type of contract. . Your "Technical Proposal" shall be submitted in accordance with the enclosed Technical Proposal Instructions. Your price or cost breakdown shall be submitted by separately identifiable tasks, utilizing DD Form 633-4 or Optional Form 60, which shall be completed in accordance with the enclosed "Business Proposal Instructions." The Technical Proposal and the cost or price breakdown shall be separate and complete in themselves so that evaluation of them may be accomplished concurrently and independently. The Technical Proposal shall be precise, factual, and complete, and not contain any reference to cost. This request does riot commit the Government to pay any costs incurred in the submission of your proposal or in making necessary studies or designs for the preparation thereof. Nor does it commit the Government to procure or contract for said services or supplies. It is also brought to your atten tion that the Contracting Officer is the only individual who can commit the Government to the expenditure of public funds in connection with this proposed procurement. FMSI 03187 I I Page 2 t associated with asbestos for illustrative purposes in the EPA letter seems: to us to be unwarranted and discriminatory. We believe reference to asbestos containing products, that is A/C pipe and asbestos brake and clutch lining in Enclosure IV of the EPA letter, gives the reader the impression of pre conceived opinions or attitudes leading to public misap prehensions. . ' Though it is our understanding responses to the RFP are now being evaluated, we believe that it would be proper to advise the recipients of the August 2 letter that Enclosure IV was developed for illustration purposes only and does not necessarily reflect fact or opinions of the federal government with regard , to the toxic effect of asbestos containing materials or actions contemplated by EPA with regard to asbestos containing products, in this instance A/C pipe and asbestos brake and clutch linings. We would appreciate hearing from you on this matter. CC: MEMBERS Adrian May, Esq., Cadwalader, Wickersham 6 Taft (Mr. John Autry, Johns-Manville Corp. (Washington office) ' Mr. Joseph Jackson, A/C Pipe Producers Assn. E. Drislane. Friction Materials Standards Institute RHMsv *. FMSl 03188