Document ERkdqRdq9zkmMr3R93O2J12b

A/C Pips Producers Association 1600 Wilson BoUvo/d. SuiU 1308 Arlington, Virginio 22209 (703) 841'15S6 September 10,1981 Dr. George E. Symons 86 Edgewood Avenue Larehmont, New York 10538 Dear Dr. Symons: Enclosed is my ballot on Draft #5 of the proposed AWWA Policy Statement on Asbestos in Drinking Water. I do not favor including paragraph 5 in the Policy Statement. The recommendation that "(u)tilities should minimize the possibility of asbestos fibers in drinking water", after stating that AWWA "believes there is no demonstrated risk associated with ingestion of asbestos in drinking water," weakens considerably the very foundation of the basic policy statement. Tacitly, it is only numbers away from recommending a MCL for asbestos in drinking water. Water quality goals for noncorrosivity and turbidity already are articulated in AWWA's statement of policy, "Quality Goals for Potable Water," adopted by the Board of Directors on January 28, 1968. Not only is it redundant to restate these general recommendations,vitagain raises implied concerns not supported by the basic premise of the policy. I also oppose transmittal of the "Commentary" to Trustees of the "Water Quality Division. The facts in paragraphs 1 and 2 of the "Commentary" are well known and represent a small, elementary portion of the body of science reviewed and discussed by the Committee. Quite frankly, I would be amazed if the Trustees were not aware of these very simple facts. CAP CO JEN 0011926 A/C Pipe Producers Associotion ur. ueorge K. Symons September 10,1981 Page 2 Further, in the last paragraph of "Commentary'', the phrase "Until it is proven" supports the belief that there js some undetermined risk to ingesting asbestos via drinking water, a view supported further by recommending water utilities "minimize the possibility of asbestos fibers in drinking water." As previously stated, this equivocates the Committee's position that there is no demonstrated risk associated with asbestos fibers in drinking water. For these reasons, I recommend that only the Policy Statement be forwarded to the Trustees. Respectfully yours, A/C PIPE PRODUCERS ASSOCIATION JCJ/ajb cc: Ad Hoc Committee Members A. Kahn, Esq. N. Itahn, Esq. SIS/2 Chrono CAP CO JEN 0011927 AWWA Water Quality Division Ad Hoc Committee on Asbestos in Drinking Water Draft No. 5 Aug. 12, 1981 AWWA Policy Statement on Asbestos in Drinking Water The American Water Works Association believes there is no demonstrated risk associated with the ingestion of asbestos in drinking water. Approve X_______ Disapprove Reason for disapproval __________ The American Water Works Association believes that no demonstrated health risk exists related to the ingestion of asbestos in drinking water. .......... __.............__ Approve _____________ Disapprove ______ X Reason for disapproval ( -Cn--the-basi'&--ef-tbirs-b'el-ref-i--th-e-A-ssxrciartrran'iretromm'errds^tiiart: v In accordance with this policy, the Association recommends that: e ( Strike out one) 1. The Association keep its members fully informed on the sub;ject of asbestos in drinking water. Approve ^_______ Disapprove ______ ;. Reason for. d&pproval _________________________ 2'. -Mater utilities &fccr.ld) share this information with their .customers and with local health authorities, when appropriate to the local situation. Approve with word "should" added Approve without the word "should" added ^ CAPCO JEN 0011928 Disapprove both statements Reason for disapproval __ 2 3* Every water utility should be prepared to respond promptly, to the extent of its knowledge, to public inquiries made about asbestos in the local drinking water supply. Approve X Disapprove ________________ Reason for disapproval _____________________ 3. Every water utility should be prepared to respond promptly to the extent of its knowledge,.to public inquiries about the number of asbestos fibers in the local drinking water supply. Approve __________ Disapprove ^ Reason for disapproval _________________________ ;___________ ' 4. Utilities which use asbestos-cement pipe in the water system should follow established and approved AVFWA procedures for handling, cutting, machining, and tapping pipe. Approve ______ X Disapprove Reason for disapproval 4. Utilities which use asbestos-containing materials should fol low established and approved AVJVJA procedures, particularly with respect to handling, cutting, machining, and tapping asbestoscement pipe. Approve __________ Disapprove y Reason for disapproval ___________________________________________ CAPCO JEN 0011929 5* Utilities should minimize the possibility of asbestos fibers n in drinking water by striving to meet the Association's water e quality goals regarding noncorrosivity and turbidity and its w policy on the treatment of public v/ater supplies. Approve __________ Disapprove X ' Reason for disapproval Weakens basic policy statement. Redundant; articulated in AlP.iA statement of policy "Quality Goals for Potable Water." " Unless a definite causal relationship between asbestos in' drinking v/ater.and adverse health effects is established, re straint should be exercized in the promulgation, adoption, and enforcement of standards and regulations with respect to asbestos in drinking water. Approve Disapprove X Reason for disapproval 6. Unless a definite causal relationship between asbestos in drinking water and adverse health effects is demonstrated, standards and regulations with respect to asbestos in drink ing water should not be promulgated. Approve ______ X , Disapprove ___________ Reason for disapproval ,________ ;____________________________________ 6. Restraiit shouMbe exercised in the promulgation, adoption, C and enforcement of standards and regulations with respect } ' to asbestos in drinking-water. Approve __________ Disapprove ^ Reason for disapproval f CAP CO JEN 0011930 7. Research on asbestos in drinking water should continue. Approve ^_____ Disapprove Reason for disapproval________ ________________________ It has been suggested that the following "Commentary" be included .as a part of the letter of transmittal from the Ad.Hoc Committee to the Trustees of the Water Quality Division and other bodies that will have to ' review the proposed policy statement. It has not been suggested that this "Commentary" be published for informational purposes when the proposed policy statement is published in accordance with AWWA procedures. COMMENTARY The policy proposed by the Ad Hoc Committee, together with the recommendations pertinent thereto, resulted from careful consideration of all information available on the subject at the time the policy statement was drafted; at which time consideration was also given to other information relating to asbestos in drinking water, to wit: o Asbestos may enter water supplies from naturally occurring geological formations in the earth's crust or as the result of man caused activities. Asbestos may also leach into drinking water if the water is specifically corrosive toward these materials. CAP CO JEN 0011931 o Treatment of raw water by an appropriate filtration process' significantly reduces the number of asbestos fibers in water. Treatment of the water to reduce in corrosive characteristics toward asbestos-containing materials will reduce the liklihood of asbestos being leached from asbestos-cement materials in contact with water. Surface treatment of asbestos-containing materials to be in contact with water, ... before use or after cleaning, will reduce the leaching effect of-Mfrosive'1*-waters on the material. o Until it is proven that the ingestion of drinking water containing asbestos fibers, over some period of time, does involve a potential health risk, it appears prudent for water utilities, to minimize the possibility of asbestos fibers in drinking water whenever appropriate and reasonable. 8. Do you approve the previous commentary to be transmitted with the final approved policy statement? Approve__________ Di sapproveX Reason for disapproval Superficial and equivocates Committee's conclusion that there is no demonstrated________ risk associated with the ingestion of asbestos in drinking water CAP CO JEN 0011932