Document zdrdobQLq6j8xoLGy3YYj6KYz

PLAINTIFF'S EXHIBIT A/C Pipe Producers Association Public Affairs Committee TO FROM. Internal Correspondence June 1,1981 DATE; SUBJECT AWWA Policy Statement Asbesstos in Water ACTION REQUIRED: (a) Immediate and critical reyiew (b) Revisions to draft language at 6/9/81 PAC meeting. Attached for your immediate and critical review is Draft No. 3 of AWWA's proposed policy statement on asbestos in water. The transmittal letter from George Symons, Chairman of the Water Quality Division (WQD) Ad Hoc Committee, has been included so you can better gauge the political climate and procedural constraints which will prevail during AWWA deliberations on the proposed statement in St. Louis. As AACPP representative to the WQD Ad Hoc Committee, it is essential that I have the benefit of your collective thoughts on this critical issue. Thus, come prepared to discuss and reach a consensus on revisions to the draft language at the PAC meeting scheduled for 6/9/81. Since the AWWA Ad Hoc Committee will meet the following morning, we must reconcile any in-house differences before the PAC meeting adjourns. If you have any questions, please give John or me a call. JCJ/ajb Enclosure cc: A. Kahn, Esq. N. Rahn, Esq. copies to: Public Affairs Committee H. Olson B. Cook I. Adams Perrell J. Woods J. Baker T. Dougherty D. Stinson W. McCallie B. Collier SIS/l PACMEMO Chrono i CAPCO JEN 0031 TOO RECEiVED'MAy 2 8 f$8? American Water Works Association | 6666 West Quincy Avenue | Denver, Colo. 80235 | 303 794-7711 REPLY TO: GEORGE E. SYMONS. PhJD. 86 Edgewood Avenue Larchmont N. Y. 10538 .Kay 23, 1981 Memo Tot Comm. Members - WQD Ad Hoc Comm, on Asbestos in Water Re: 3rd Draft - AWWA Policy Statement Sorry! I am running about ten days late on my schedule, but you should have this draft in time to review the text and be prepared. to discuss and vote on-its provisions during the committee meeting .in St. Louis, on Wed. June 10 at 9:00 am in the Cervantes Center-Room 271 If you do not plan to attend the committee meeting, please make your suggestions on the enclosed draft and mail it to me- (before June !) addressed to me c/'b Sheraton St. Louis Hotel 910 North Seventh St. St. Louis, M0 63101 (l4hall leave Larchmont on June 2nd and shall arrive in St , Louis on F^i. June 5) About the enclosed draft: I have tried to consolidate and simplify the essence of ten revisions of Draft No. 2, into one coherent text, accepting some suggestions, rejecting others, including some alternatives, etc. a Where suggestions were made`for word or phrase changes, I have placed the prssible alternative language in parentheses above the original wording . o Where I agreed completely with suggested revisions, I included them, as suggested. Where I did not fully agree with suggested revisions X for what ever reason), I indicated suggested deletions in brackets and suggested word changes in parentheses. There were many variations in word choice, even paragraph revisions, and suggested whole new paragraphs, some dealing with details. /lany might well be accepted when we meet, others seem doubtful of consensus. ------- In approaching this Draft No. 3* I took the position thayAWWAs policy Should be broad, with limited "whereases" and free from specific details as to sampling, analytical techniques, particle size, particle numbers, particle identification,etc. and status of current studies. proT-nit'ni JEROME O GH RPR I*. ('nlifomui Pinsicfcnt-fticci KEMNFTM J Mil LEFI. Dc*uc;r, CVIoiodo Vnr Pic^iet^nt. JOHN H STACHA \U\\?iw Pp'it'Pit'S'dcnt' DONAL D K Si UNt\ Wyo*'iinci. Michicinn r*< .isurr*- THOMAS J BLAIR. Ill GNul^stor Virginia fw -f/ian M.recfor DAVID R PRPSTON. Honvor. O'f'irnMo i l* I CAPCO JEN 0031701 May I ask that you read the enclosed draft carefully, referring as you may wish to the copies of Draft No. 2 comments which you received from other committee members. Jeptha Wadels letter contained several good suggestions, but I decided not to attempt to draft statement for him. If Jeptha wishes he may ' draft his preferences for wording at this time, and well review it at the Committee Meeting. The same ccrsideration goes to other mem-=bers of the Committee, but I hope that you will all be willing to work on this draft and not to propose whole new approaches. For the committee meeting procedure, I pDopose; 1. Decide on the method of establishiing a consensus with regard to format, content, specific wording, etc. 2. Review Draft No. 3 paragraph by paragraph and Sentence by sentence, if necessary, considering word choice if need be. 3. Consider possible new additional paragraphs, or extensive revisions of paragraphs; i.e. , consider some of the suggestions made with respect to Draft No. 2, that did not get into Draft No. 3- I look forward to seeing you in St. Louis. I hope that all of you will be able to attend the Committee Meeting. Sincerely, ... ".J.ttwi.w I Committee Chairman CAPCO JEN 0031702 Draft No. 3 May 20, l8l AWWA Policy Statement on Asbestos in Drinking Water #X Because appreciable numbers of water supply consumers have expressed concern about possible health effects of asbestos in drink ing water, the American Water Works Association has adopted this pol icy statement concerning the education of the public and appropriate A actions to be taken by water utilities. As a prelude to establishing this policy, the Association con sidered [and evaluated] available information on tb? subject and con cluded that [at this time] certain known and accepted facts are per tinent, to wit: .. Asbestos may enter water supplies from naturally occurring geologic formations in the earth's crust; occasionally, it . may enter water supplies as the result of man-caused activities. Asbestos may also leach into drinking water from asbestos-contain ing [pipes and] materials in contact with the water, if that water corrosive is specifically aggressive toward asbestos-cement materials. Note: not all aggressive waters will corrode asbestos-cement pipe or asbestos-containing materials. Although studies have shown that inhalation of airborne asbestos fibers has produced disease in human beings with high-level occup ational-related exposure, there is no conclusive evidence that the \ * " - CAPCO JEN 0031703 results of these studies may be extrapolated meaningfully to deter mine physiological effects in humans who ingest asbestos [particles] in= drinking water, Furthermore, ' > [ there are no clear-cut research data ] ( there is no substantial body of data) indic ate that ingestion of water-borne asbestos fil^i/^s by human is detri mental to health. [Alternative A to Par. 4] Although studies have shown that inhalation of air, heavily laden with asbestos fibers, has produced adverse-human health effects, there is no evidence that the results of these studies may be extrapolated to determine health effects of water-borne asbestos. Furthermore, several studies on health effects of water borne asbestos carried out to date have failed to show a definite health risk. [Alternative B to Par. 4] Although -|t is scientifically accepted that inhalation of asbestos fibers has produced cancer in human Vr.ir.f-s, it is uncertain whether the results of occupational aihborne asbestos studies can be used to determine the risk of ingested asbestos. At this time, there are no definitive human or animal data Which prove that ingestion of water-borne asbestos fibers is injurious to human health. However, because some studies suggest that in gested asbestos is not completely without effect on the body, sev eral important research studies are presently underway to pro- CAPCO JEN 0031704. vide more definitive information on the effects of ingested asbes tos. a Treatment of raw water by filtration (significantly! reduces the number if asbestos fibers in water [supplied to the consumer]. Treatment of water to reduce i^s|aggessive! c^arac'teris'tics (r to provide a corrosion inhibitor) will reduce the ("^tendency! of asbestos released! ^or S^P leaching of asbestos) from asbestos-containing [pipe or] materials in contact with corrosite waters. [ Surface treatment of asbestos-containing pipe and ma terials before use, or after cleaning, will reduce the leaching effect of aggressive waters on asbestos-containing pipe of mater ials.] e [At the present time], no federal regulations prescribe max imum allowable concentrations of asbestos fibers in drinking water or mandate ad"justment of the ({aagogrrroess*sYivee)3 characteristics of water to be carried in [asbestos-cement pipe] (water distribution systems). In consideration of these facts, it is the policy of the Amer ican Water Works Association that: The Association has a responsibility to keep its members fully informed on the subject of asbestos in drinking water> Water utilities have a responsibility to share this information with their customers and with local health authorities, when appropriate to the local situation. ii CAPCO JEN 0031705  Where public concern is evidenced or customer inquiry made about asbestos in the local drinking water supply, every water utility should respond .promptly and knowledgeably; Where asbestos fibers are present in the local water supply,the local water utility should take steps to ascertain the necessary actions to avoid, reduce, or remove such fibers, if such action is indicated; o Utilities that use asbestos-cement pipe in their systems should follow established and approved AWWA procedures for handling, cutting, machining, and tapping A-C pipe. - Research on any possible causal relationship between asbestos ; in drinking water and adverse health effects should continue until definite.'' data are abtainedi a Until a causal relationship has been established definitely between asbestos in drinking water and adverse health effects, jtj. restraint should be exercised in the promulgation, adoption and enforcement of standards and regulation with respect to asbestos in drinking water. X." i II ' CAPCO JEN 0031706