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A@ A/C Pip. Producers Association \) Public Affairs Committee (4/M--.... J. F. Welch, Vice President FROM Internal Correspondence April 21, 1982 DATE Field Problem - Weston, Wisconsin REF: JFW correspondence, same title, March 16,1982 ACTION REQUIRED: Review for information On March 22, 1982, a public hearing was held in Weston, Wisconsin to review the allegations of Dr. William Croft that the A/C water system in that town is deteriorating and creating a public health hazard. Enclosed is an outline report prepared by Hal Olson (Johns-Manville) and a news article from The Daily Herald. If you have any questions, please do not hesitate to call. JFW/ajb Enclosure cc: A. Kahn, Esq. copies to: Public Affairs Committee H. Olson w/o enclosure R. LeGault B. Cook W. Perrell J. Woods J. Baker T. Dougherty W. MeCallie w/o enclosure B. Collier w/o enclosure F01PI21906 Chrono iCAPCO JEN 0032408  eI. ' 9U ti- a \ I ,w j O O 8 > 2 v4 .a -- s V) 9 tiZ O --Jji Or+, "co . a = bjD ? 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"Asbestos is a utilitarian product par excellance" "Many uses". \ - Pictures of old industrial plants; Patterson, NJ Made point that pictures are not indicative of today's industrial plants. "There are now good preventative measures to avoid asbestos exposure". "Major concern now is existing old asbestos insulation". "--that care be taken in removing old insulation." "Route of entry important", "Occupational exposure ----inhalation". "Asbestos is one of the most studied and best understood but we still don't know all." Gave data on synergistic effect of smoking on asbestos disease. Dr. Anderson spent considerable time on E.P.A. water quality model - i.e. 300,000 f/1 relates to increase in cancer deaths, i.e. Drinking two liters per day of 300,000 f/1 water for 70 years will result in one additional death per 100,000 deaths. H. Olson's comment: What can we do to discredit this model? Dr. Anderson tried to emphasize this was a low risk `level (equal to getting hit by lightening) but it did cause a stir in the audience. Second speaker: Carol Gannon from Dr. Anderson's office Report on air samples taken: "Nine homes tested for asbestos in air" "Two in areas other than Weston for control" "Used NIOSH method" "Purpose of tests to determine if air from humidifiers exceeded OSHA F/cc level". CAPCO JEN 0032410 Page 2 "Total samples: 43". "Range of results: 0.01 F/cc to 0.02 F/cc" "Results well below occupational standard of 2F/cc" "There was no significant difference between control, homes and Weston homes". - Applause from audience - Third speaker: Marty Kanerak, University of Wisconsin Described reserve mining operation that developed concern for asbestos in water supply. Chart on Gibel study which shows "some increase in cancer to rats fed asbestos" (Kanerak mentioned asbestos fed in a filter cake containing plastic material, but did not emphasize the increase in cancer could also be attributed to the plastic.) Referred to "government animal feeding study" (This is NIEHS Study) - "No excess cancer noted". Connecticut Study: "Negative results" "Size and geo metry of the fiber is the critical element--not chemistry of fiber". Duluth/Minneapolis Study: "Duluth had lower cancer rate over all" "Only 15 years exposure and too early to tell". Quebec Study: "Essentially negative according to authors, but looking closer shows some higher rates for asbestos exposure". San Francisco Bay Area: - "Higher cancer rates for areas of high asbestos counts" "Results not likely to be due to chance" "Stable tracts gave essentially the same results". (H. Olson's comment: This is not what Kenny Crump reports) Washington-State Study: "Totally negative" "This is possibly because fiber size in Washington study was smaller than fiber size in San Francisco Study.". Weakness of indirect study", "It is possible asbestos was not the factor", "Should do a case control study in California", "Need more study". (H. Olson's comment: Kanerak reported accurately but over all effect seemed to be his study did establish a causeeffect connection.) CAPCO JEN 00324-1 1 rage o Fourth speaker: Tom Bashau ' (Stand in for Bob Baumeister of Dept. Natural Resources) "I will not discuss health effects but will report on the existance of asbestos in water in Wisconsin" "35 systems in Wisconsin sampled for asbestos in water" Results of testing program: Water Systems Fiber Level # Samples STATEWIDE N.D to 12 x 106 F/L < 1 x 106 >1 x 106 31 6 WESTON N.D. to 1.4 x 106 F/L < 1 x 106 >1 x 106 0I Fiber Level # Samples Water Wells N.D. to 3.4 x 106 < 1 x 106 >1 x 106 24 2 N.D to 1.3 x 106 < 1 x 106 >1 x 106 61 Asbestos is prevalent in ground water. If ground water is corrosive there is a problem \<ri.th all pipes-----"red water". "You will have a problem regardless of the type of pipe you use." Fifth Speaker: John Standridge - State of Wisconsin Health Dept. Laboratory Standridge described lab procedures for counting asbestos fiber. It is difficult to count and subject to wide variations. QUESTIONS & ANSWERS Q. Are there any studies that prove a positive relation between asbestos and cancer? A. (Kanerak) "I guess I didn't get my point across". The San Francisco study was a positive study." Q. Could the asbestos in the ground water be due to as bestos cement pipe in the ground? A. Tom Bashau"No, asbestos in ground water is found where there is no A/C pipe in the ground." iCAPCO JEN 00324-1 2 Page 4 Q. Why should we believe what you are saying and not believe Croft? A. Standbridge: "We are sure our test results for asbestos in water are accurate. McCrone Associates, E.P.A. and State lab all got similar results." Anderson: "On air sampling our studies used procedures recommended by NIOSH. Fibers longer than 5 microns and . using optical microscopy.(gave the impression Croft used a different technique)' Results are like comparing oranges and apples." Q. Is the time of the year when samples are taken a factor? (In stammer when Croft took samples the velocity could be higher). A. Tom Bashau: "We don't know." V Q. Is the town board contemplating doing nothing, and run the risk of future law suits for failure to act? A. Tom Bashau: "The Department of Natural resources is concerned about aggressive water, and will make recommendations to control water quality. Corrosive water is a serious problem for C.I. and A/C." Jack Allen - Chairman of Town Board: "No decision yet on pipe removal." "Facts are conflicting between these two meetings." "Town must go into a water treatment program." "Want to get results from McCrone tests before a decision is made to pull the pipe." "Have interviewed six engineering firms. If a decision is made to pull pipe it could be done quickly." "Town Board is working hard." Q. How deteriorated is the pipe? A. Jack Allen: "We are. having an engineering firm work on that." (Note to H.L.O. - Write to Jack Allen and Dick Weber requesting J.M. be present during this test.) (H.L.O. comment - In a subsequent discussion with Don Oakland (reporter) was advised there already had been some crush tests performed. I commented to Oakland that it was a good bet the tests for crush strength showed no loss of strength or we would have heard about it.) Q. Is there a clear cut difference between breathing fiber and drinking fiber in water? A. Million: "The evidence is clear on breathing asbestos but much less on drinking fiber." , Anderson: Went back to the Water Quality criteria model CAPCO JEN 0032413 Anderson (cont'd): i.e. 300,000 F/L for 70 years results in one additional death per 100,000. Q. What is the length of. fiber in our water? A. Standbridge: "Most short fiber in Weston." Tom Bashau: "A little in the high range for distri bution systems but not considered long."" The longest were 8 microns but the vast majority were 1 microns or ' less." Kanerak: "Fibers need to be longer than 10 microns to be a hazard." Q. Why spend six million dollars to replace pipe if we still have asbestos in our wells? -Applause- y. No Answer. Q. Dr. Croft took xxx samples (air). Do you have enough data from your work? (9 houses) A. Carol Gannon: "Our results were way under occupational exposure level." Anderson: "The number of samples doesn't matter if a wrong technique is used." "There are no studies to substantiate asbestos gets into homes from humidifiers." "It was a very serious report that asbestos in homes was exceeding occupational exposure levels." "We took it very seriously. It would have been a medical emer gency." "We do not believe an emergency exists." Q. On air counts did you only count long fibers? A. Carol Gannon: "Counted 5 microns and longer." Q. Is difference in Croft's air count and state air count only a difference in fiber length? A. Anderson: Reply was somewhat evasive. "We will be willing to do some parallel sampling with Mr. Croft." Q. How many of the panel members would drink Weston water? A. All members raised their hands. Q. Were there any sutdies done on the increase in fiber level as water moved along the pipe? A. Kanerak: "Pipe contributed negligible amounts of fiber to the water." i i CAPCO JEN 0032414 Statements from a man in the audience: "It's time we told the board to forget the asbestos problem." -Applause- Q. What effect will water treatment have on asbestos in water from A/C pipe? A. . Tom Bashau:- "We are concerned about corrosive water on all pipes including C.I." Q. Was the D.N.R. aware of corrosive water in Weston when the pipe was installed? A. Tom Bashau: "I can't answer." Jack Allen: "I can't answer directly. . I can only read past minutes." - An update on board action^ "Water has been treated. Some difference of opinion on how good was the treatment." "We must go to a more stringent program." "Engineers tell us the asbestos count will drop drastically by treating the water." Q. Do you have enough samples to form an opinion? A. Tom Bashau: "D.N.R. has about 50 samples from Weston area. Million: "Additional samples are being taken." Q. Are there substitutes for asbestos? A. Tom Bashau: "There are substitutes for A/C pipe, but there would be problems of red water with C.I." Q. What action is planned for the future? A. Jack Allen: "We will treat the water. After all samples are in we will make a decision if we should pull the pipe." I Q. What treatment is required and will it open an other "can of worms"? A. Tom Bashau: "Zink coatings have been used with A/C pipe. No matter what kind of pipe is used it would be attacked. Not positive if another problem would result." CAPCO JEN 0032415 Q. What is the cost factor for treatment? A. Tom Bashau: ' "This will be looked into by engineers." Q. What was the difference in fiber count by you and Croft? A. Standgridge: "A factor of at least 10." Meeting adjourned. After the meeting I introduced myself to Jack Allen, Chairman of the Town Board, and Dick Weber, Attorney. Neither had any significant comment to make. I asked Weber if he had noted where there had been applause from the audience. He said he did. This meeting was covered by WSAW-TV and the Daily Herald. Dave Thompson (TV) wanted me to leave during Kanerak's presentation for an interview. I refused aa I wanted to hear Kanerak but did agree to meet after the meeting. Thompson had a deadline to meet and was gone by the time the meeting ended. I did not meet Don Oakland at the meeting, but did call him the next morning. I told him we were pleased that George Million had arranged the meeting and thought the meeting gave the citizens of Weston some valuable information. Alan Vogt and Mike Krosnoski attended the meeting. Alan made a tape recording of Kanerak*s presentation. Alan, Mike and I all concur that the meeting went well and that it will be difficult for the Town Board to make a decision to remove A/C pipe based on current information and the general reaction of the audience. /ba CAPCO JEN 0032416 CAPCO JEN 00324 / ii CAPCO JEN *s <? ,/ \,fOt^C^<-?.-~, t/ysA.f^*Z/ciaj^f.t;.- -y*- ? --4^6&6^'%ti2z> J> y ' ^ /?0 * ~Jt^Z>~-' jSW-C&iy too^j^y 7*^/ !/W y x /y * CAPCO JEfvj 00324 tS^yTufy^Ta-?Ats - C%****-~<^ 'yoAU. f)\ yyj?et/-t^cSj/l^- '_*n.~9 y1 Af fffT* &>-----*-<-y < II CAPCO JEN 0032420 //<W// / tC'rfA' - S*C\'Jvi<?si4,L s- J'Aj '~?a<J fa***'?, 0xo -\ 7^ . J -- / W' ^s / / /^f/ '7h*u- /?jT~z. j^-V \-ii. j&(L 3^r /f& /fs^ B.J yu. CAPCO JEN 003242 j; ^4 4. -A- V-^f- *7 *''" (ZZa^a ~Z<iriS s^y iV ^/U'^y~_ S~o~<zX;S' ' /) / / i_ /t. / - y <*^X. <fjUstsL* f 7.1 cstry~>y' x -V^fcdlwu-tr- -- * CAPCO JEN 0032422 /T/.-V`<7 S- '^yr'7~' Citcsb~ Ltbcu!^ /c^-'C p? ,-<2d. c I I CAPCO JEN 0032423 CAPCO JEN 0032424 A/C Pipe Producers Association Board of Directors International Affairs Committee ---------- . /j. F. Welch, Vice-President Internal Correspondence August 17,1984 DATE SUBJECT' U.S. National Institute of Environmental Health Sciences (NIEHS) - Asbestos Feeding Studies REF: (1) JFW correspondence, U.S. Environmental Protection Agency (EPA) Advance Notice of Proposed Rulemaking on National Drinking Water Regulations (2) JFW correspondence, same title, April 30, 1983 ACTION REQUIRED: Review for information Reference (1) mentions the reported finding of "nodules" in rats fed chrysolite in the National Toxicology Program (NTP) animal studies. NTP Draft Technical Report on the Toxicology and Carcinogenesis Studies of Chrysotile Asbestos in F344/N Rats Enclosed are excerpts from the report. To summarize, oral administration of "short range" chrysotile did not cause any overt toxicity and neoplastic or nonneoplastic disease. These results are consistent with NTP studies feeding amosite and erocidolite asbestos to rats and hamsters. In male rats fed "intermediate range" (IR) chrysotile, however, benign neoplasms called adenomatous polyps were observed in the large intestine. The incidence of these neoplasms was not statistically significant when compared to the control group (not fed asbestos) in this study. When the incidence is compared with all male control groups in NTP's oral asbestos studies, it is considered highly significant. Thus, the report concludes that there is some evidence of carcinogenicity in male rats fed intermediate range chrysotile. In the section entitled "Discussions and Conclusions," NTP interprets the significance of these findings. Five important observations are made: (1) adenomatous polyps are benign neoplasms, (2) no malignant neoplasms were observed in this study (or any of the other oral asbestos studies), (3) the polyps did not progress to carcinomas even though, (4) this was a lifetime study that allowed progression to malignancy. Finally, no gastrointestinal tumors were observed in female rats in the same experiment. Discussions with NTP Staff On July 27, 1984, NTP's Board of Scientific Counselors peer reviewed the draft technical reports of the chrysotile feeding studies. According to Dr. E. E. McConnell, Project Officer, the Board determined that the polyps were "absolutely related to exposure to intermediate range chrysotile." Unfortunately, the Board did not address the question of why neoplasms were induced by IR chrysotile but not induced by amosite and erocidolite of comparable fiber dimensions in the same test animals. McConnell went on to say, "It's real. The neoplasms are definitely treatment-related. These results probably would not have been detected in a study involving a smaller number of animals (e.g. Smith, et al) and indicate that ingested asbestos certainly is not a rip-roaring carcinogen." He said that the Donham animal study, in which an asbestos dosing level of 10% resulted in a "trend toward increased colon lesions," suggested that neoplastic CAPCO JEN 0032425 response might occur but did not do so with statistical significance. The larger number of animals in this NTP study permitted this "trend" to develop fully, in his judgement. Public Health Significance When questioned about the point, McConnell stated that the current findings "meant very little with regards to human health." He said (not a direct quote), "From a public health standpoint, we obviously know that inhaled asbestos is carcinogenic. Ingested asbestos is probably not much of a public health threat, especially since many of the fibers in water are much shorter than IE chrysotile. The dosing levels in these studies were 160,000 to 16 billion times greater than the projected level of possible human exposure. I'm not going to lose any sleep worrying about drinking water coming out of A/C pipe." After the peer review meeting, McConnell discussed the Board's conclusions with NTP Director Dr. David Rail. Rail concurs with McConnell's views, including the public health implications. Staff Analysis It would have been highly desirable for all the NTP studies to show no evidence of carcinogenicity with all fiber types, size ranges, and animal species and sexes. The current findings demonstrating "some evidence of carcinogenicity" blemish what previously was a strong, consistent body of animal toxicology studies showing no carcinogenic effects from ingested asbestos. It is not known whether EPA will share NTP's views about the public health implications of these findings. If anything, they complicate the question of whether asbestos in drinking water should be regulated and may well slow down the Agency's decision-making process. For example, the Office of Drinking Water may reraise the issue with the EPA Science Advisory Board. The matter definitely will be discussed at the next meeting of the National Drinking Water Advisory Council. iT CAPCO JEN 0032426 Staff plans to issue an A/C Advisory on this NTP study and McConnell's comments so that undue significance is not imparted to the findings. If you have any questions, please do not hesitate to call. JFW/bwm Enclosure cc: A. H. Kahn, Esq. Timothy S. Hardy, Esq. AIA A1A/NA CAIC W. E. Smith, M.D. B. T. Commins, Ph.D. copies to: Board of Directors International Affairs Committee L. Ambler L. Cejudo J. M. Couture B. Layton L. Taylor a R. Corner 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 0172081301 Chrono CAPCO JEN 0032427