Document kDyz0JNVG2rKmqVgQpOEkERJJ

A/C Pipe Producers Association Internal Correspondence TO FROM SUBJECT Board of Directors International Affairs Committee l.f-. ----;-- . F. Welch, Vice President August 7,1984 DATE SOP-01-06 (OSHA-EPA) - Municipal Intervention Tactic REF: (1) (2) JFW correspondence, same title, July 6,1984 JFW correspondence, SOP-01-06 (OSHA-EPA Rulemakings), June 18,1984 ACTION REQUIRED: Review for information Current Status Enclosed is letter from the Tucson Water Department to Environmental Protection Agency (EPA) Administrator Ruckelshaus opposing the Agency's consideration of an A/C pipe ban. This letter, like comparable letters from the cities of Wichita, San Antonio and the Arizona Water Company, resulted from staff meetings with utility managers. There are no substantial differences between EPA's response to Tucson and previous EPA responses. By now, U.S. member companies should have provided salesman with materials that will assist them in persuading utilities to send additional letters to EPA opposing an A/C pipe ban. If Staff can be of any assistance in this effort i.e by answering salesmen's questions, etc., please have them call. JFW/lk Enclosure . V' \/ cc: A. H. Kahn, Esq. Timothy S. Hardy, Esq. copies to: Board of Directors KB2SS5^* L. Ambler L. Cejudo J. M. Couture B. Layton L. Taylor 0172080703 Chrono International Affairs Committee R. Dorner A. Junes G. Zaviezo M. A. Elola A. Lluch R. Hobbs R. Jalan H. Hudson S. Al-Tarkait M. Delcourt B. Dubois E. van der Rest E. Costa J. Schmaus F. Mansour P. Hart A. Saoulis V. Pattabhi C. Barton C.Saeng-Xuto B. Giboin J. Bryant CAPCO JEN 003334-7 S@gH/HDJUU3 July 5, 1984 Mr. John Welsh 1600 Wilson Blvd. Suite 1008 Arlington, VA 22209 Dear Mr. Welsh: SUBJECT: Proposed Ban of Asbestos Pipe Manufacturers Attached for your information is Tucson Water's letter to EPA and their response on the asbestos pipe issue. Please call if we can be of further assistance. Sincerely ministrator TMM:br Attachment cc: Tucson Water Division Managers Engineering Section'Leaders Tucson Water City of Tucson. P.O. Box 27210 .Tucson, AZ 8572B-7210 .(602) 791-4331 CAPCO JEN 0033348 \ 5SB* UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 T'juvcr, i- - Distributed to: Mr. Frank Brooks Director Tycson Water P. 0. Box 27210 Tucson, Arizona 85726 Dear Mr. Brooks: Administrator Ruckelshaus has asked me to respond to your letter of May 15, 1984, in which you expressed concern over the Environmental protection Agency's (EPA) intention to propose a ban on asbestos-cement pipes. In spite of previous ongoing regulatory efforts, asbestos-related.health hazards continue to be a serious problem in the United States. Human exposure to asbestos occurs throughout the life cycle of the mineral--when it is mined,_processed, and fabricated into industrial and consumer products and when these products are used and disposed. Therefore, EPA is working on-a proposal that would eliminate the use of asbestos in virtually all products over the next 10 years in a two-phased approach. Iu-phase one, EPA's Office of Toxic Substances (OTS) would propose a mile under the Toxic Substances Control Act (TSCA) in August 1984 to prohibit the importation, manufacturing and processing of four asbestos products for which substitutes are now readily available. These-products accounted for about half of the asbestos consumption in 1981. They are: saturated and. unsaturated roofing felt; flooring felt and asbestos.felt-backed sheet flooring; vinyl-asbestos floor tile; and asbestos-cement pipes and fittings. These products were chosen because they are large-volume uses of asbestos, and the availability of substitutes can be easily documented. Our studies indicate that polyvinyl chloride pipe, reinforced concrete pipe, ductile iron pipe, among other substitutes, are indeed competitively priced compared to asbestos-cement pipe. Additional categories of products which pose a disproportionately high risk of disease compared with their volume may be added. This action would have an immediate and significant impact on the asbestos hazard. iCAPCO JEN 0033349 In phase two, OTS would propose a rule under TSCA in November 1984 to reduce the total amount of asbestos imported and used in all other applications. Eventually, most uses of asbestos would be eliminated through a staged phased-down rule over a 10-year period. As you correctly pointed out, our risk assessment is based on inhalation, not ingestion of asbestos, and we have emphasized this point in.our drafts of the proposal. Accordingly, at the present time, we foresee no circumstances under which removal of asbestos-cement pipes would be required.. r must emphasize- that this proposed- action is only under consideration at this time and may very likely undergo further changes. You will be promptly notified at the beginning of the 60-day comment period following the announcement of any proposed rule involving asbestos-cement pipes, so that yourviews will, be considered before any rulemaking decision is CAPCO JEN 0033350 William D. Ruckelshaus Administrator Environmental Protection Agency ' 401 M Street, S.W. Washington, D.C. 20460 Dear Mr. Ruckelshaus: Tucson Water is very concerned about EPA's announced plans to ban- asbestos/cement pipe. Tucson Water has use asbestos/cement water pipe to serve its 470,000 customers for more than 30 years. Asbestos/cement pipe has proven to be the most cost-effective means of- conveying potable water in the distribution system. Our literature search has indicated that asbestos/cement pipe poses no risks of any consequence to our customers. We, therefore, continue to use asbestos/cement pipe today almost exclusively and hope to continue its use in the future. . " ' Were EPA to ban manufacture of asbestos/cement pipe, we would face-substantial additional costs. Moreover, we are very concerned that such EPA action would create intense public pressures to remove existing asbestos/cement, pipe. Were such demands ever heeded, the costs would be staggering-. We,, therefore, urge EPA to consider carefully any plans to ban- the manufacture of asbestos/cement pipe. In order-to-assist the-Agency in understanding the asbestos/cement pipe issue,, the remainder of this letter provides some information on-why Tucson Water utilizes the product. . Tucson- Water first began using asbestos/cement pipe in the 1950s. - Over the- years, asbestos/cement pipe has been demonstrated to have a lifetime, yet to be determined with minimal maintenance costs; Today, ninety percent of our water system is currently serviced by asbestos/cement pipe. In selecting pipe materials, we are concerned with both initial installation costs, long-term maintenance costs, and with the safety :of the material. In each .respect.- our experience has often led us to' choose asbestos/cement pipe. The costs of purchasing and installing asbestos/cement pipe have been approximately twenty percent lower than alternative materials. Tucson Wafcpr PitTM nf Tt mcnn .DO Rnv 9721 fl Tttrcnn A *7 RR7* 51 R CAPCO JEN 0033351 William D.. Ruckelshaus - 2- May 15, 1984 We are constantly concerned and vigilant about the safety of the water conveyed in our system. Needless to say, with the great 'publicity that asbestos health effects have had in the past decade, we have been concerned about the possibility that some health risk might be- posed by fibers from asbestos cement water pipes. We have thus followed closely the reviews conducted by the American Water Works. Association and EPA of asbestos ingestion risks. We. were reassured when AWWA conducted an independent review of the medical and technological evidence on asbestos/cement pipes in 1974-and concluded that, "the probability of risk to health from the use of such- [asbestos/cement] systems is small -- approaching zero." We nonetheless welcomed, the extensive research program on asbestos fir water conducted' by. EPA in cooperation with the National Toxicology Program over the past- decade. The results of that program, as announced at EPA's 1982 Workshop on Ingested Asbestos, confirmed the- earlier AWWA assessment and once again reassured us . that "asbestos/cement pipe could safely be used in our system.. Several. EPA..'scientists- and officials from its Office, of Safe Drinking. Water participated' in ` that workshop and unanimously concluded that-the extensive, research program failed to find any human or animall'evldence. of a risk form ingested asbestos.. ::i;We-;~:have^taken; '-numerous precautions in installation and maintenance- .' operations.. to .minimize asbestos exposures. Our -installation, specification require special cutting tools, special tapping, procedures,. and extensive flushing.. .V:"/C-We have-found asbestos/cement.pipe to be effective, affordable, and safe. We "plan to. continue, its use.. Were we to be denied use of asbestos/cement.pipe, our expenditures, for new installed pipe would increase- by ten to twenty, percent. Maintenance costs would also increase oyer-the years. ...Perhaps more importantly,'we would, as previously stated, expect an EPA ban to cause public demands to remove asbestos/cement pipe already installed. ,.,It would be extremely difficult for us to explain to our customers our confidence that the materials we use to convey water are safe when the manufacture of the same materials have been banned by EPA. CAPCO JEN 0033352 \ William D. Ruckelshaus -3- May 15, 1984 It is our understanding that any EPA ban would be premised on alleged risks to workers from inhaling asbestos when manufacturing and installing pipe, rather than from ingestion'risks, but may well * be a distinction without a difference to the public. Should such public pressure occur and should we be forced to begin removing and replacing asbestos/cement pipe; our ability to provide potable water' at a reasonable price would be seriously jeopardized. Replacement costs in our system would be in excess of $140 million. We trust that EPA's thinking on the asbestos/cement pipe issue is not firm or final and we urge you to carefully consider any plan to ban this product. If we can provide further information that would be helpful in your deliberations, please let us know. Sincerely, Frank Brooks Director "VI FB:TM:jm cc: Joel D. Valdez:, City Manager CAPCO JEN 0033353