Document JNo1zKKyNRz2NkRveQoEKXEGX
A/C Pips Producers Association
1d>00 Wdson BoUtivoid, Sute 1308 Arlington. Virginia 22209 (703) 8qH5S8
PLAINTIFF'S EXHIBIT
September 10, 1981
Dr. George E. Symons 86 Edgewood Avenue Larehmont, New York 10538
Dear Dr. Symons:
Enclosed is my ballot on Draft i`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, jt-again 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.
CAPCO JEN 0031716
A/C Pipe Producers Association ur. George 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 I-Ioc Committee Members
A. Kahn, Esq. N. Rahn, Esq.
SIS/2 '-.^9 Chrono
iI
CAPCO JEN 0031717
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 ______ ^
Reason for disapproval _
( -Crh-the- -basi-s- -of- -t-bi-s- - bei-iref --the -Assxrc iartxon- re cromnvHnds "tha't: ( In accordance with this policy, the Association recommends that:
( Strike out one)
1. The Association keep its members fully informed on the subr
ject of asbestos in drinking water.
Approve
^________
Disapprove _______;______
Reason for disapproval_______________________________________________
2. -Water utilities ('hbo- 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
V
11 CAPCO JEN 0031718
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 asbestbs in the local drinking v/ater 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
v
Reason for disapproval ~
4. Utilities which use asbestos-cement pipe in the water system should follow established and approved AWWA procedures for handling, cutting, machining, and tapping pipe.
Approve ______ X
Disapprove ____________
Reason for disapproval _
4. Utilities v/hich use asbestos-containing materials should fol low established and approved AWWA procedures, particularly with respect to handling, cutting, machining, and tapping asbestoscement pipe.
Approve __________
Disapprove
v
Reason for disapproval
CAPCO JEN 0031719
3
5. Utilities should minimize the possibility of asbestos fibers
in drinking water by striving to meet the Association's water quality goals regarding noncorrosivity and turbidity and its w policy on the treatment of public water supplies.
Approve ___________ Disapprove
x
Reason for disapproval Weakens basic policy statement. Redundant; articulated in AWVIA statement of policy "QualityGoals for Potable Water."_______ _________________ ____
_____
6*> Unless a definite causal relationship between asbestos in
drinking water.and adverse health effects is established, re A 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. Restraint should be exercised in the promulgation, adoption,
C and enforcement of standards and regulations with respect
to asbestos in drinking-water.
Approve __________
. Disapprove
y
Reason for disapproval _____________
CAPCO JEN 0031720
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.
ii
CAPCO JEN 0031721
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 corrosive waters on the material.
o Until it is proven that the ingestion of drinking water containing asbestos fibers, over seme 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__________
DisapproveX
Reason for disapproval _____Superficial and equivocates
Committee's conclusion that there is no demonstrated risk associated with the ingestion of asbestos in drinking
water.
CAPCO JEN 0031722
A/C PIPE PRODUCERS ASSOCIATION 12TH ANNUAL MEETING & INDUSTRY CONFERENCE 'V : MARRIOTT'S MOUNTAIN SHADOWS RESORT ,
SCOTTSDALE, ARIZONA
APRIL 1-4,1984
Schedule of Events
Sunday, April 1
2:00 p.m. .
.... International Affairs Committee
7:00 p.m..
Welcoming Reception & Buffet Dinner
Monday, April 2
9:00 a.m. .
................... Industry Conference Session I
9:00 a.m. .
..................... Spouse's Breakfast
12:00 p.m.
Executive Committee Luncheon
2:00 p.m. .
................... Industry Conference Session II
Open Evening
Tuesday, April 3
9:00 a.m...................................................... .................................. ............. Industry Conference Session III
11:30 a.m............................................................................................................Luncheon Buffet
1:00 p.m............................................................................................... Golf/Tennis Tournament
7:00 p.m. .......................................... ............... -................................................ .Dinner/Dance
Wednesday, April 4
.. ...... : . . .. ", ' . f.
9:00 a.m.................................................................................................... .... Board of Directors
CAPCO JEN 0031723
'
REGISTRATION FORM
AACPP's 12th Annual Meeting and Industry Conference April 1-4,1984
Marriott's Mountain Shadows Scottsdale, Arizona
IMPORTANT! Complete a separate registration form for eai<c*hh rrefxgriissttrrannntf annnd/i ri*eohtur>nn wwiltfhh
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check for registration fee made payable to A/C Pipe Producers Association by reply dat
shown below. Please check box is this if your first Annual Meeting , '
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Name
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Company
R<AO / pJyf/R ` ~ Apj '
Spouse's Name - *Pa
iXwiU P Win not attend ..
V" (/; * ' -
Spousej^will will not attend
HOTEL RESERVATIONS * Arrival Date ......... r5 --3 I - <*? 4~........... Departure Date _
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Room Accommodations: Single Room Rate: $145 + 3% tax
Double
, ,
..7;.:; . i
RECREATIONAL ACTIVITIES Spouse's Program: SpouseJSj? will will not participate
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Men
Women
.. .
Golf Tournament___ . ,,
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Handicaps or approximate Rental clubs requested:
Tennis Tournam ent
Right Left
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REGISTRATION FEE*
'fg' Regular Member............................ $400(U.S.) Associate Member.......................... $400(U.S.) Affiliate Member............................ $400(U.S.) Non-Member................................... $600(U.S.)
Registration Fee for Spouse is Complimentary
REPLY BY: FEBRUARY 10,1984
RETURN TO: A/C Pipe Producers Association
1600 Wilson Boulevard
Suite 1008
- _
; _ Arlington, Virginia, 22209
.v. ..
CAPCO JEN 0031724