Document 2j3OE0djLQogwnJ1gnaNdN6zp

aSWStCS - G-38,738-1 UNION CARBIDE CORPORATION (OSHA Citation 84-0705) Ms. Betty-Lynn White Linda Division Union Carbide Corporation Old Ridgebury Road Danbury, Connecticut 06817 Dear Betty-Lynn: I have enclosed a copy of a subpoena duces tecum requiring Union Carbide to designate an agent to appear at the hearing in this matter and bring the documents listed in the subpoena. You will note that sane of the documents whioh have been eubpoenaed are ones which will disclose the amount of shell pressure in the unit at the time that the cooling system was first operated. I am aware of Lee Rosenthal's contact by Mike Solar and that a lawsuit against union Carbide now appears to be eminent. Me now need to discuss what approach we intend to take toward the ultimate resolution of this nutter. closed. Please aall me after you have reviewed the en Sincerely, RHtldO Enc. act Mr. Foley Provensano Ms. Lee Rosenthal Ross Harrison i -- ' ' W . - ---- : : UCTC 21138 SUBPOENA DUCES TECUM rx*n ttiaG cassr \ cr-:--` "O ,r: & UNITED STATES OF AMERICA Occupational Safety and Health Review Commission ELOO Catmeroe Street, Suite 7B11 Dallas, Texas 75242 Union Carbide Corporation Post Office Bex 471 Texas City, Texas 77590 Bequest therefor having been duly made by Robert A. Fitz, an attorney for the Secretary of Labor, United States Department of Labor, ccnplainant herein, whose address is 555 Griffin Street, Suite 501, Dallas, Texas 75202, YOU ARE HEREBY REQUIRED AND DIRECTED TO JfBXKaBEBHEBBETO DESIGNATE A KNOWL EDGEABLE AGENT TO APPEAR BEFORE THE HONORABLE DEE C. BLXTHE, an Administrative Law Judge 0f the Occupational Safety and Health Review Commission, x* in the Exchange Roan on the Lobby Level of the Downtown Campus of the University of Houston,101 Main Street, in the City of Houston, Texas, on the 25th day of October ,19 84 at 9.30 o'clock a. m- of that day, to testify in the Matter of Union ra-rt-nd* Corporation OSHRC Docket Mo. 84-0705 And you are hereby required to bring with you and produce at said time and place the following books, records, correspondence, and documents: (a) The annual financial report, profits-and-loss statement and receipts-and-disbursenents statement of Union Carbide Corporation far its most recently ended fiscal year. (b) The written occupational safety and health program (if ary) of Union Carbide Corpora tion for its Texas City, Texas, plant as it existed an April 13, 1984. (c) The map of Union Carbide Corporation's Texas City, Texas, plant showing the physical location of the Vinyl Acetate Unit with respect to the rest of the plant. (d) The building plans and/or blueprints for the Vinyl Acetate Unit at Uhion Carbide Corporation's Texas City, Texas, plant. (e) The building plans and/or blueprints for the water chilling unit installed at Union Carbide Corporation's Texas City, Texas, plant on April 13, 1984 by Mobil Air Conditioning, Inc. (f) The loose leaf book for the Texas City, Texas, plant of Union Carbide Corporation, page 1-9 of which is entitled "Standard Solvents & Intermediates, [CONTINUED ON THE BAG In testimony whereof, the seal of the Occupational Safety SDT-2- 13269 and Health Review Commission is affixed hereto, and the undersigned, a member of said Occupational Safety and Health Review Commission, has hereunto set his hand and authorized the issuance hereof. Issued at Da ...as, Texas 75242, this 2nd day of October * 19 84. notice to wmrnia.--whmh im who* mint tlx iritacu to aafcrauiM*. Umi ta fra* tfcn UA Cm* nunlto MnUt br fht putr it U niatantawml far O0-M7-AU UCTC 21139 M: .-.'St': t STANDARD SOLVENTS & INTERMEDIATES QUICK CONNECT (Kamlock Type) FITTING PRESSURE RATINGS Texas City Metal Cast Iron Steel Stainless Monel Malleable Iron Brass Aluminum 250 < 2" <. 2" < 2" < 2" < 2" Pressure, psig 200 125 1Q0 NOT RECOMMENOEO AT UCC 3" _ 4 3" - - 4" 3" 4" 6" < 2" 3 3" 4" 6-8" -- 3" 4" -- 3" 4" 75 6,8" 6,8" 8" 6,8" 6,8" NOTE: 1. 2. 3. May be used only for pneumatic conveying of solids at UCC. Data from Seal Fast, Inc. Catalog Not approved for metal chemical transfer hose since this down grades the rating below these given in Plant Procedure I-F-2. \ UCTC 2U40 u: