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PLAINTIFF'S EXHIBIT
SEP T'984
Mr. Dwayne Hargesheimer Director of Water utilities City of Abilene p. o. Box 60 555 Walnut Street Abilene, Texas 79604
Dear Mr. Hargesheimer:
Thank you for your letter of August 23, 1984 to Mr. William D. Ruckelshaus, the Administrator of the Environmental Protection Agency (EPA), concerning possible regulatory action on asbestos concrete (A-C) pipe. I have been asked to respond.
EPA believes there is overwhelming scientific evidence of risk to humans from exposure to asbestos and is considering the proposal of rules banning certain asbestos product categories where non-asbestos substitutes are readily available and competitively priced. EPA is also considering proposing a staged phase-down of all other remaining asbestos uses over a ten-year period.
The scientific evidence shows that workers involved in the life cycle of asbestos products are subject to hazards associated with (A-C) pipe. There is exposure when asbestos used to make the product is mixed and milled, when the pipe is manufactured, and when the pipe is installed, maintained and disposed. There are also hazards to people who live in the same house with an asbestos worker, and who simply breath city air that contains asbestos fibers.
We believe there are suitable substitutes for A-C pipe, and that the risks associated with asbestos are unreasonable and justify regulations to require the use of substitutes. In this way, exposure throughout the product's life cycle is eliminated.
CAP CO JEN 0012020
I
We do not plan to impose any requirements on existing A-C pipe because the results of human and animal studies have not clearly shown evidence of risk from ingestion of asbestos. The EPA office of Drinking Water continues to study whether there is a need for regulation of asbestos under the Safe Drinking Water Act.
EPA is planning to propose recommended maximum contaminant levels under the Safe Drinking Water Act for tetrachlorethylene (TCE) and several chemically related solvents. TCE is used in lining A-C pipe with vinyl.
you will have an opportunity to comment on any proposals the Agency makes concerning the regulation of asbestos and your comments will be fully considered. If you have any additional questions, you may call the Toxic Substances Control Act Assistance Office, 800-424-9065.
^Edward A. Klein Director TSCA Assistance Office
CAPCO JEN 0012021