Document 2jqmRBkYgYvwMEZv7eoGprmnN

231 1 SUPERIOR COURT OF NEW JERSEY 2 LAW DIVISION: UNION COUNTY 3 DOCKET NO. UNN- 8 5 7 3- 8 9 4 5 IN RE ENVIRONMENTAL 6 INSURANCE DECLARATORY 7 JUDGEMENT ACTIONS 8 9 1 0 VOLUME II 11 DEPOSITION UPON 12 ORAL EXAMINATION 13 OF 14 C. WAYNE BICKERSTAFF 15 16 17 WEDNESDAY, APRIL 29, 1992 18 19 20 2 1 XABOT, BATTAGLIA & HAMMER/DE SIMONE 22 THE COURT REPORTERS 23 59 MAIN STREET 24 WEST ORANGE, N. J. 07052 25 (201) 669-3141 1 WESTINGHOUSE -ELECTRIC 2 CORPORATION/ et al, 3 Plaintiffs, 4 vs . 5 LIBERTY MUTUAL 6 INSURANCE CO./ et al, 7 De fendants. 8 9 WESTINGHOUSE ELECTRIC 1 0 CORPORATION/ et al. 11 Plaintiffs, 12 v s . 13 AETNA CASUALTY & 14 SURETY CO., et al, 15 Defendants. 16 17 18 19 20 21 22 23 24 25 232 DOCKET NO. L-069352-87 DOCKET NO. L-069351-87 23 3 1 TRANSCRIPT of the deposition 2 of C. Wayne Bickerstaf, a witness, 3 called for Oral Examination by the 4 parties in the above-entit1ed action, 5 said deposition being taken pursuant to 6 Rules governing Civil Practice in the 7 Courts of New Jersey, by and before ANN 8 P. CONLON, a Notary Public and Certified 9 Shorthand Reporter of the state of New 1 0 Jersey, at the office of Connell, Foley 11 & Geiser, Esqs., 85 Livingston Avenue, 12 Roseland, New Jersey, on Wednesday, 13 April 29, 1992, commencing at 10:00 in 14 the forenoon. 15 16 17 APPEARANCES: 18 19 KIRKPATRICK. 6 LOCKHART, ESQS., 20 1500 Oliver Building 2 1 Pittsburgh, PA 15222-5379 22 BY: NEAL R. BRENDEL, ESQ., 23 Attorneys for Plaintiff, 24 Westinghouse Corporation. 25 234 1 APPEARANCES: (continued) 2 3 MOUND, COTTON & WOLLAN, ESQS.., ' 4 One Battery Park Plaza 5 New York, NY 10004 6 BY: MITCHELL S. COHEN, ESQ., 7 and 8 CLAUSEN, MILLER, GORMAN, CAFFREY 9 & WITOUS, ESQS., 10 10 South LaSalle Street 11 Chicago, IL 60603 12 BY: LAWRENCE D. MASON, ESQ., 13 Attorneys for Defendants, 14 First State Insurance Company, 15 Allstate Insurance Company, 16 Colubia Casualty Insurance Company, 17 Employers Insurance company of Wausau, 18 The Home Insurance Company, 19 Birmingham Fire Insurance Company, 20 Lexington Insurance Company, 2 1 National Union Fire Insurance Company, 22 Ranger Insurance Company, 23 Royal Exchange Assurance Company. 24 25 235 1 APPEAR A- N C E S: (continued) 2 3 CUYLER, BURK & MATTHEWS, ESQS., 4 BOX 1947 5 Morristown, NJ 07962 6 BY: MARIA C. HERMIDA, ESQ., 7 Attorneys for Defendants, 8 Prudential Reinsurance Company, 9 Gibraltar Insurance Company, 1 0 General Reinsurance Corporation, 1 1 Harbor Insurance Company, 12 Zurich Insurance Company, 13 Zurich American Ins. Co. of Illinois, 14 Northstar Reinsurance Company. 15 16 MENDES 6 MOUNT, ESQ., 17 Three Park Avenue 18 New York, NY 10016 19 BY: DANIEL T. O'NEIL, ESQ., 20 Attorneys for Defendants, 2 1 Certain Underwriters at Lloyds, London 22 and London Market Companies. 23 24 25 1 ALSO PRESENT: 2 3 MEGHAN WISE, ESQ., . 4 Inhouse Counsel, Westinghouse, 5 6 7 8 9 10 11 12 13 INDEX 14 15 WITNESS DIRECT 16 C. WAYNE BICKERSTAFF 17 By Mr. Cohen 239 18 19 20 21 22 23 24 25 236 1 -EXHIBITS 2 IDENT. DESCRIPTION 3 4 26 Memo dated 11/8/77 from 5 Rudolph to ISD Locations 6 7 27 (i pg) 1977 Annual Safety Report 8 (12 pgs) 9 28 Industrial Hygiene 1 0 Newsletter of March 1988 11 (7 pgs) 12 29 Safety committee Meeting 13 Report of August 1978 14 (6 pgs ) 15 30 Memo dated 8/31/78 from 16 Whittier to Newark (1 pg) 1 7 31 Safety Information Letter 18 (2 pgs) 19 32 Memo dated 9/19/78 from 20 Kerns to Works Engineers 2 1 33 Memo dated 6/19/79 from 22 Berqulst to Bickerstaff 23 ( 2 0 pgs) 24 34 Memo dated 10/18/79 from 25 Aiken to Divisions (2 pgs) 237 PAGE 239 244 2 62 268 27 6 277 279 284 289 1 2 3 35 4 5 36 6 7 37 8 9 38 10 11 39 12 13 14 40 15 16 4 1 17 18 19 20 21 22 23 24 25 EXHIBITS (continued) 238 Memo dated 10/79 from . Mangan to Safety (2 pgs) Memo dated 7/7/81 from Heasley to Bryant (18 pgs) Toxic Substances List (6 pgs) Memo dated 11/2/79 from Conrads to Hamilton (2 pgs) Memo dated 11/9/79 from Gormley to Divisions (6 pgs) Memo dated 7/31/81 from Beal to Managers (1 pg) Corporate Procedure Document dated August 1982 (2 pgs) 295 302 307 308 317 324 326 Bickers ta direct 239 1 C. WAYNE BICKERSTAFF, 2 having been previously sworn, 3 testified as follows: . 4 5 CONTINUED DIRECT EXAMINATION 6 BY MR. COHEN: 7 Q. Good morning, Mr. Bickerstaff. 8 A . Good morning. 9 Q . I appreciate your coming back 1 0 for the continuation of your 11 deposition . You realize, sir, that you 12 are still under oath? 1 3 A . Yes . 14 Q. Let us mark as Exhibit 26 for 15 identification a one-page document 1 6 bearing Bates stamp number 132/4084649. 1 7 (Memo dated 11/8/77 is 18 marked as Exhibit Bickerstaff 26 for 19 Identification.) 20 Q * Mr. Bickerstaff, have you ever 2 1 seen this document before? 22 A. I saw it last week, yes. 23 Q. Aside from preparation for the 24 deposition 25 A. I may have seen it I don't Bickerstaff direct 240 1 remember it offhand. 2 Q. Okay. First of all, what were 3 the ISD locations? . 4 A. That was Industry Service 5 Division locations. 6 Q. And Mr. Rudolph, the 7 supervisor of safety and accident 8 prevention, what department did he work 9 with? 1 0 A. He was the supervisor of 11 safety and accident prevention for the 12 Industry Services Division. 13 Q. So that was a department 14 within the Industry Services Division. 15 A. Yes . 16 Q. Was the Industry Services 17 Division part of corporate headquarters? 18 A . NO . 19 Q. Was Industry Services Division 20 located in Pittsburgh headquarters? 2 1 A . No . 22 Q. Where were they located? 23 A. They were located in a small 2 4 community on the outskirts of Pittsburgh 25 called Greentree. Bickerstaff - direct 241 1 Q. Were there any standard 2 practice, policies or procedures with 3 regard to communications be t.w e e n the 4 Industry Services Division and your 5 division, sir? 6 A. Yeah, there would be 7 correspondence back and forth, yes. 8 Q. And was that pursuant to a 9 formal policy or an informal practice? 1 0 A. More the latter, informal 11 practice. 12 Q. Now, this document concerns a 13 necessity to resort to a substitute 1 4 program for asbestos. Has your 1 5 division, the Industrial Hygiene 16 Division, involved with this substitute 17 program? 18 A. The Corporate Industrial 19 Hygiene Department. It was not a 20 division. 21 Q. Pardon me. 22 * A. Yes, they were invo1ved with 23 an initial meeting before I came into 24 the department in early 1976 I believe, 25 looking at the uses of asbestos in t Bickerstaf direct 242 1 Westinghouse -and looking for possible 2 substitutions. 3 Q. Now, would you hav.e expected 4 to be involved in a safety communication 5 concerning the use of substitute products for asbestos because of 7 potential employee exposure? 8 A. We could have been. There was 9 no requirement that they had to. 1 0 Q. Generally speaking, were you 11 involved in matters concerning 12 compliance with OSHA standards? 13 A. Yes. 14 Q. And that is because OSHA was 15 particularly concerned with employee 1 6 exposure? 17 A. Correct. 18 Q. Now, this memo beginswith a 19 reference to the OSHA standard for 20 asbestos. Am X correct that there is no 2 1 indication on this document of your 22 department being a copied recipient? 23 A. Not on this copy, I don't see 24 anything. 2 5 Q. Is there anyindication on Bickerstaf f direct 243 1 this document of any division other than 2 the Industry Services Division being 3 involved in the dissemination of this 4 document? 5 A. No, I don't see anything. 6 Q. Did the Industry Services . 7 Division provide services to the 8 manufacturing divisions of Westinghouse? 9 A. They could have, but in most 1 0 cases it was a repair plant division. 1 1 They repaired motors for their 1 2 customers. In most cases it was 13 utilities where a pump would go bad or a 14 motor would go bad. They would send it 15 back to them to repair. 1 6 Q. So a supervisor forsafety and 17 accident prevention in the Industry 18 Services Division would not have any 19 reporting requirements with regard to 20 the Lamp Plant Division. 2 1 A. Correct. 22 Q. Or any otherdivision for that 23 matter. 2 4 A. Correct. 2 5 MR. COHEN: Let us mark as Bickerstaff direct 244 1 Exhibit 27 a -document bearing Bates 2 stamp numbers 844/6017283 through 3 844/6017294. . 4 (1977 Annual Safety Report is 5 marked as Exhibit Bickerstaff 27 for 6 Identification. ) 7 Q. Have you ever seen this 8 document before? 9 A. Last week. 1 0 Q. Pardon me. Aside from 1 X preparation for the deposition. 12 A. I may have/ but that was 1977, 13 that was 15 years ago. 14 Q. What was the Advanced 15 Technology Laboratories? 16 A. That was one of the facilities 17 or plants which was part of the Defense 18 Division located near Baltimore, 19 Maryland. 20 Q. So the reporting requirements 2 1 with regard to the Advanced Technology 22 Laboratories were strictly within the 23 Defense Division? 24 A. Correct. 25 Q. Mow, this document on the page Bickerstaff direct 245 1 bearing Bates- stamp number 6 0 17 287 at 2 the very top makes reference to the 3 Westinghouse six-point safet.y program. 4 Was that something within the Defense 5 Division or throughout the corporation? 6 A. Corporation. 7 Q. What was the six-pointsafety 8 program with regard to substances? 9 A. One was the administration/ 10 making sure you have a safety 11 committee. We had the Westinghouse 12 safety observer program, which was 13 another function, controlling hazards in 14 the workplace, fire prevention. I 15 forget exactly, but that's kind of the 16 gist of it. 17 Q. okay. If you would look at 18 page 6017292, which is about five or six 19 pages in? - 20 A. Yes. 2 1 Q, At the top of the page, there 22 is a reference to point three, * 23 industrial hygiene. Was that one of the 24 points in the six-point safety program? 25 A. Correct. Bickers ta f f direct 1 Q. Was- your department 246 2 responsible for point three? 3 A. Our department was. responsible 4 to develop that part of the six-point 5 program, yes . 6 Q. And then did you disseminate 7 whatever was developed throughout the 8 corporation? 9 A. Yes. 1 0 Q. And what practice or procedure 11 was followed with regard to the 12 dissemination of the industrial hygiene 13 aspect of the six-point safety program? 14 A. Once those were identified, 15 they were included and sent out as a 16 total package of the six points. 17 Q. It was first centralized I 18 take it? 19 A. Yes . 20 Q. Within the Defense Division? 2 1 A* No, it was centralized again 22 corporate. All locations, at all 23 locations, here's the six-point program 24 to administer an effective industrial 25 hygiene and safety program. It gave Bickerstaff direct 247 1 them guidelines. 2 Q. At the bottom of page 6017292 3 there is a reference to safe, practice 4 data sheets. Was that something created 5 by your division? 6 A. Yes. That was created by one 7 of my predecessors/ yes. 8 Q. Could I have the gentleman's 9 name please ? 10 A. Mr. Wilbur Speicher. He was 11 the administrator at the time. 12 Q. On the bottom of the page, 1 3 there is a reference to the safety 14 information letter. 15 A . Same page? 16 Q. Yes. It's at the very bottom, 17 last sentence, page 6017292. 18 A. I want to read the whole 19 thing. 20 Q. Sure, take your time. 2 1 A. Okay. 22 Q. What was the safety 23 information letter? 24 A. I don't know. That may have 25 been something that defense put Bickerstaff direct 1 together. I don't recognize it. 248 2 Q. This is mentioned as a subpart 3 to part three, industrial hy.giene. 4 Having pointed that out to you, does 5 that refresh your recollection as to 6 whether your department had anything to 7 do with the safety information letter? 8 A. I don't recognize the safety 9 information letter as something coming 10 out of our department. 11 Q. And I take it Exhibit 26, 12 which we marked just a moment ago, is 13 not an example of the safety information 14 letter, to your knowledge? 15 A. No. This again would be I 16 guess reference back to the Industrial 17 Services Division, not headquarters. 18 Q. I notice that Exhibit 26 is 19 entitled "safety." That's why I point 20 out the safety information letter. To 21 your knowledge that is not it? 22 A. No, that is not it. 1 don't 23 know for sure, but I doubt very 24 seriously. 25 Q. With regard to the safe Bicke rs ta f f direct 24 9 1 practice data sheet books, do you know 2 how they were disseminated throughout 3 the corporation, if at all? . 4 A. The safe what data? 5 Q. The safe practice data sheet 6 books. . 7 A. Oh, data sheets. 8 Q. Yes. 9 A. Those were distributed by the 10 Corporate Industrial Hygiene 11 Department. 12 q. That's your department? 13 A. Yes. 14 Q. And to whom were they 15 distributed? 16 A. They were primarily 17 distributed to the industrial hygiene 18 and safety representatives or officers 19 at each of the facilities. 20 Q. So they were transmitted 2 1 directly from headquarters to plants? 22 A. Correct. 23 Q. Was the purpose of the data 24 sheets to obtain uniform practices with 25 regard to Industrial hygiene? Bickerstaf f direct 1 A. Yes. They were guidance on 250 2 working with hazardous materials, 3 protective clothing to wear,, you know, 4 just uniform guidance. 5 Q. On page 6017293, there is a 6 reference to inspection and a gentleman 7 or a woman by the name of J. Adams, now 8 on the staff of the Industrial Hygiene 9 and Safety Department at the Defense and 1 0 Space Center. Was the Defense and Space 11 Center part of the Defense Division? 12 A. Yes, correct. 13 Q, Was the Industrial Hygiene and 14 Safety Department at the Defense and 15 Space Center part of that division or 16 part of the Headquarters Division? 17 A. Well, at the time during this 18 Inspection they're referring to, Mr. 19 John Adams was an industrial hygienist 20 from the corporate Industrial Hygiene 21 Department. sometime in 1977, he was 22 offered a position, a promotion to go to 23 the Defense and Space Center in 2 4 Baltimore, and he chose to accept that 25 position. Bickersta f f direct 25 1 1 Q. So 'he was promoted from his 2 headquarters position to a division 3 position? . 4 A. From an engineer to a manager, 5 correct. 6 Q. And headquarters to division. 7 A . Yes. 8 Q. So the same page, that being 9 6017293, point four is training. Is 1 0 that one of the six points of the 11 Westinghouse training safety program? 12 A. Yes . . 13 Q. Was that something within your 14 department's purview? 15 A. Well, it was both industrial 16 hygiene and safety. We all, both 17 organizations contributed information to 18 that. So it wasn't just safety or 19 industrial hygiene, it was both. 20 Q. The paragraph entitled 2 1 "employee indoctrination safety 22 training" makes reference to a "guide - 23 for your safety," and it states that "it 24 is believed that all new hired employees 2 5 did not receive a copy of same, nor did 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 -24 25 Bickerstaff direct they receive -employee safety 2 52 indoctrination in the safety slide program. order." Improvements are perhaps 'in First, what was the safety slide program? A. I believe it was a defense oriented safety slide training program. Q. When you say defense oriented, do you mean for the Defense Division? A. Yes. It was developed by them for their use internally. Q. Do you know if it had anything to do with the handling, use, disposal or storage of substances? A. It probably did. Q. Do you recall any discussions concerning what is referenced here, that the program had not been fully disseminated to all employees? A. No. Q. Do you recall any discussions about making the safety slide program available to Westinghouse employees other than the Defense Division? Bickerstaff direct 1 A. No,- that was not a normal . 253 2 practice. Especially the defense, 3 because their customer was the Air 4 Force, and they may have maybe some 5 sensitive information in there which 6 would not be allowed to be disseminated 7 to other Westinghouse locations. 8 Q. The decision whether Defense 9 Division information could or could not 1 0 be disseminated to other divisions was 11 made at what level, to your knowledge? 12 A. At the defense. 13 Q. On the last page of the 1 4 document, there is at the top of the 15 page a reference to the safety 16 committees and operational supervisors 17 and keeping them informed of OSHA and 18 MOSH safety information via Westinghouse 19 headquarters information letters. 20 First, what were the safety committees 21 and operational supervisors? 22 A. . Again, that would be for just 23 the defense plant, and again going back 24 to our corporate guidance, each location 25 should have a safety committee, and they Bickers ta f f direct 254 1 did have active safety committees for 2 all the defense locations. 3 Q. And what was the W.e s t i n ghou s e 4 headquarters information letter? 5 A. Could be anything. Could be 6 new information from OSHA. One of the 7 letters that was put out at least 8 annually were where the plants would 9 send their injury/illness data into us. 1 0 We would then combine it and then have a 11 "Westinghouae injury/illness rate and 12 send it back, and they could see how 13 they compared themselves against the 14 year before and against other 1 5 divisions . 16 Q. Did the Westinghouae 17 headquarters information letters appear 18 on any periodic basis? 19 A. No. 20 Q. Didthey have a particular 21 format? 22 A. That changed through the 23 years, the 15 years I had been there, 24 because our department had different 25 reporting functions. In the early years Bickerstaf f direct 2 55 1 it was basically just a letter, not even 2 a news letter. 3 Q. And in the early y.ears, would 4 it be entitled a headquarters 5 information letter or would it just be a 6 piece of correspondence from 7 headquarters ? 8 A. It would in most cases be a 9 piece of correspondence with the title 1 0 of the subject at the top of the page 1 1 and sent to all the tfestinghouse 12 locations. 13 Q. When you say the title or 14 subject at the top of the page, you mean 15 just as a reference, the subject matter 16 would be annunciated? 17 A. Right, OSHA new regulations on 18 whatever. 19 Q. Did there come a time when the 20 headquarters information letters became 2 1 more formalized and appeared on the same 22 type of memoranda heading or with a 23 formal letterhead such as with Exhibit 24 26, which is entitled "safety" at the 25 very top of the page? Bickerstaf f direct 256 1 A. Yes, we got to have later on 2 more formal newsletter letters. 3 Q. Do you know when that 4 occurred? 5 A. I think that occurred primarily after the Environmental 7 Affairs Department was pulled together 8 in 19 81. 9 Q. At the bottom of the last page 1 0 of the exhibit, there is a reference to 11 "miscellaneous training." There are 12 two columns. In the right-hand column, 13 the first three subjects are handling of 1 4 chemicals, handling and storing of 15 flammable liquids and shop safety. Who 16 attended these training sessions? 17 A. It would be the appropriate 18 individuals who would be either handling 19 the chemicals or -- this was inhouse 2 0 training that the defense department 2 1 again produced and then made available 22 or maybe purchased the film and made 23 available for use. But it was primarily 24 the people who received the exposure or 2 5 potential exposure got the training. Bickerstaff direct 257 1 Q. And this would be done 2 strictly within the Defense Division? 3 A. In this case, yes. 4 Q. Were there any reports by the 5 Defense Division to headquarters of what 6 training sessions were being made 7 available to the division employees? 8 A. This letter here, which is an 9 annual report, came back to us again as 10 a voluntary gesture. 1 1 Q. And this would provide 12 historical information about what had 13 happened previously? 14 A. For that year. 15 Q. Was there any prospective 1 6 dissemination of information concerning 17 the training sessions such that 18 employees in other divisions handling 19 the same or. similar chemicals would be 20 able to attend the Defense Division 2 1 training sessions? 22 A. No, that wasn't done.. 23 Q. Were there ever any 24 discussions about whether that would 25 have been a good idea? Bickerstaff direct 258 1 A. Not really, because to take an 2 employee from someplace in Pennsylvania 3 and move him down, pay for a.l 1 their 4 expenses and everything else, or maybe 5 even 15 or 20 employees, why not, if you 6 see that they're using such and such 7 film and they purchased it from some 8 industrial firm, why not purchase the 9 film yourself. But there really was not 10 a lot of accident exchange back and 11 forth between divisions on this. 12 Q. Were there any practices, 13 policies or procedures that would have 14 enabled the plant in Pennsylvania, to 15 use your example, to learn what films 16 had been purchased by the Defense 17 Division? 18 A. If it was, it would be through 19 our department as a clearing house. 20 Somebody would call in from plant A and 2 1 say do you know what they're using, and 22 I would say I think plant B is using 23 this, but let me find out and I'll get 24 back to you. 25 Q. Again, this would be on an ad Bickerstaff direct 25 9 1 hoc -- 2 A. Ad hoc basis. 3 Q. And the impetus for the 4 exchange of information remained at the 5 plant level for It to make an inquiry? 6 A. Yes. 7 Q. Did other divisions aside from 8 the Safety Division have annual reports 9 of safety activities? 10 A. You sayat the divisions? 11 Q. Let me rephrase that question, 12 if X may. Did the divisions other than 13 the Defense Division have the practice 14 of creating annual reports of safety 15 activities ? 16 A. There were certain 17 Westinghouse plants. X don't know about 18 divisions, but some of our nuclear 19 operations tend to have annual reports. 2 0 I don't know if they put it together as 21 a division. See, now, this here is not 22 a division but this is just the one 23 location. This is their annual report. 24 Advanced Technology Laboratories. 25 Q. This is simply an operation Bickersta f f direct 1 within that division and this report 260 2 only speaks as to that operation? 3 A . Correct. 4 Q. On the page Bates stamped 5 6017288/ the third delineated paragraph 6 makes reference to Westinghouse 7 Gettysburg. Was that a Defense Division 8 plant? 9 A. No, Gettysburg was not 1 0 defense. 1 1 Q. What type of plant was it, 12 sir? . 13 A. Let me think about that. That 14 was 1 believe elevator. 15 Q. Was there any practice or 1 6 procedure pursuant to which the Advanced 17 Technology Laboratories/ which were part 18 of the Defense Division/ visited plants 19 within other divisions to conduct OSHA 20 Inspections and submit safety 2 1 recommendations ? 22 A. I don't know. 23 Q. i recognize the document 24 indicates that happened. 25 A . Yes Bickerstaff direct 26 1 1 Q. Was that, to your knowledge, 2 part of a formal practice or procedure? 3 A. No, that was not normal 4 procedure. 5 Q. Do you know of any practices 6 or procedures pursuant to which the 7 Advanced Technology Laboratories could 8 disseminate to other divisions the 9 information they would learn when 10 conducting mock OSHA inspections and 11 submitting safety recommendations? 12 A. Normally they would only be 13 either back to other defense locations 14 or back to headquarters. This is a very 15 rare occasion/ Westinghouse Gettysburg. 16 I have no idea why that took place. 17 Q. On page 6017289, the next to 18 last paragraph concerns federal, state 19 and local laws and regulations and makes 20 reference to keeping management and 21 supervision apprised of applicable 22 changes. Did the Advanced Technology 23 Laboratories keep corporate management 24 apprised of applicable changes? 25 A. They might keep us advised of Bickerstaf direct 2 62 1 state changes, not so much federal, 2 because it was our responsibility to 3 stay abreast of the federal.. But they 4 could have. 5 Q. I take it if they did, 6 however, it was not pursuant to a formal 7 policy or practice? 8 A. That's correct. 9 Q. On the next page there is a 10 reference to the management safety 11 committee. Was that something within 12 the Defense Division? 13 A. 1 believe that's -- again, 14 that's their style of letter. I believe 15 they're talking about their management 1 6 safety committee. 17 MR. COHEN: Let us mark as Mr. 18 Bickerstaf Exhibit 28 a document 19 bearing Bates stamp numbers 144/0080532 20 through 0080538. 21 (Industrial Hygiene Newsletter 22 is marked as Exhibit Bickerstaff 28 for 23 Identification.) 24 Q. When did the Industrial 25 Hygiene Department begin the practice of Bickerstaf f direct 1 publishing an industrial hygiene 263 2 newsletter or report? 3 A. Again, I'm trying to recall. 4 It was sometime in the 1980s. I don't 5 know exactly when it started. - 6 Q. What was the purpose of it? 7 A. Well, the purpose was to 8 inform the Westinghouse locations of 9 pending regulations, advise them of our 10 training courses, just keeping them 11 abreast of new regulations, changes, 12 whatever, good work practices, things 13 like that. 14 Q. I take it that a subject which 15 was treated in the regular course of 1 6 these hygiene newsletters was the 17 handling, use, storage and disposal of 18 various substances? 19 A. Well, it could. If we've 20 learned a new practice or procedure or 2 1 something like this, we could mention 22 that in here. -- 23 Q. If you became aware of new 24 OSHA regulations, would that be 25 included? Bickerstaff direct 264 1 A. That would be included too. 2 Q. If a particular plant had 3 advised corporate headquarters of a' 4 practice it had found to be a good one 5 for the purpose of protecting employees/ 6 would that be disseminated through this 7 letter? 8 A. That could be. 9 Q. If a particular practice had 1 0 been determined to be dangerous or 1 1 unacceptable to corporate headquarters, 12 would that be - 1 3 A. That could also be in there 1 4 too . 15 Q. Who was the person responsible 1 6 for the creation of the industrial 17 hygiene newsletter? 18 A. Everybody in our department 19 contributed, and we had a training 2 0 communicator manager, who would then, 2 1 after we submitted articles, would put 22 it* together so it would look like one 23 author writing the whole thing and she 24 would proof it. And everybody had an 2 5 opportunity to look at it before it went Bickerstaff direct 26 5 1 out to make sure misspellings and 2 whatever were corrected. 3 Q. What was the title of that 4 person? 5 A. She's listed here, manager of 6 training communication. 7 Q. That would be Debbie 8 Rockovlch? 9 A. Yes. 10 Q. And was she the first manager 11 of training and communications? 12 A. No, there was a predecessor to 13 her . 14 Q. Do you recall who the 15 predecessor was? 16 A. I knew you were going to ask 17 that. Oh, Norma -- I can't think of the 18 last name right now. 19 Q. We can leave a blank and 20 you'll have a chance to read the 2 1 transcript. Do you recall when Norma, 22 whatever her last name may have been, 23 first took the position of manager of 24 training and communication? 25 A. . I'm guessing around 1984, '85, Bickerstaf f direct 266 1 something like that. 2 Q . And to your knowledge, was 3 that about the time the industrial 4 hygiene newsletter came into being or 5 did it precede that woman's taking 6 office as manager of training and 7 communication? 8 A. We had communications. I 9 don't know if it was officially called 10 the industrial hygiene news or 11 newsletter. We always had 12 communications telling them about new 1 3 regulations and things like that, 14 announcing our training courses and 15 things. I don't know when we officially 16 took on the form of a newsletter. Z 17 can't say. 18 Q. Was the newsletter published 19 with any regularity? 2 0 A. Not really. We would just as 2 1 needed, as we got enough information 22 together to produce one, we would have a 23 news letter. 24 Q. This particular one happens to 25 be dated March, 1988. That is not an Bic kers ta f f direct 267 1 indication that the newsletter was . 2 printed on a monthly basis? 3 A. That's correct. . 4 Q. And I take it it was not 5 necessarily printed quarterly, 6 biannually or even annually? 7 A. That's correct. 8 Q. Can you estimate in anyway how 9 often a newsletter would appear? 10 A. It depends per year or 11 whatever. I would estimate we at least 12 had some sort of communication to the 13 Westinghouse plants maybe three times a 14 ye a r . 15 Q. Were there any particular 16 communications directed to divisional 17 headquarters as opposed to the plants? 18 A. Not in the form of a 19 newsletter or anything like that, no. 20 Q. Were the divisional 21 headquarters included within the 22 dissemination of the hygiene newsletter 23 to the plants? 24 A. Yes. 25 MR. COHEN: Let us mark as Mr. Bickerstaf f direct 1 Bickerstaff Exhibit 29 a document 268 2 bearing Bates stamp numbers 844/6072269 3 through 6072274. . 4 (Safety Committee Meeting 5 Report is marked as Exhibit Bickerstaff 6 29 for Identification.) 7 Q. Can you identify this 8 document, sir? 9 A. This appears to be a monthly 1 0 safety meeting, which was conducted at 1 1 one of the defense facilities near 12 Baltimore. 13 Q. To your knowledge, was it the 14 practice of the Aerospace and Systems 15 Development Divisions to have monthly 16 management safety committee meetings? 17 A. They would have pretty much 18 monthly meetings, yes. 19 Q. Was it also the practice of 20 the Aerospace and Systems Development 2 1 Divisions to record what had happened at 22 those meetings in this type of 23 memoranda ? 24 A. That's correct, that's my 2 5 understanding. Bickerstaff direct 269 1 Q. Was it also the practice that 2 you would be copied on the memoranda? 3 A. Yes, in most cases. I got 4 copies, correct. 5 Q. Now, at the top of the first 6 page of the Exhibit there is a list of 7 names. Are those members of the 8 management safety committee? 9 A. I think I only attended one of 1 0 their monthly meetings in 15 years, so I c 11 can't say for sure, but in looking at 12 this document, they look like they are 13 members of this local safety committee, 14 yes. 15 Q. Now, first off, most of the 16 names there at the top of the page with 17 the exception of one have a letter code 18 and then a number code following them, 19 and all of them have the prefix MS. Do 20 you know what that prefix meant? 21 A. I think that means mall stop. 22 . Q. Was it the practice within t.he 23 Aerospace and Systems Development 24 Divisions to use the mail stop when 25 communicating within the division? Bickers taf f direct 270 1 A. I believe so. 2 Q. So for the co's, when there 3 are, for the first six people, the 'MS 4 prefix, those are people also within the 5 division? 6 A. Yes. 7 Q. And is it your understanding 8 that all of these people were located at 9 the same plant? 1 0 A. Yes. 1 1 Q. And that was somewhere outside 12 Baltimore you had said? 1 3 A. Yes. 14 Q. Now, was that plant in the 15 Aerospace and Safety Development 16 Division? 17 A. It was part of the Defense and 18 Electronic Systems Division, yes. 19 Q. And that is the same division 20 we were talking about earlier with 2 1 regard to the Defense Division for the 22 Advanced Technology Laboratories? 23 A. Yes, the Advanced Technology 24 Laboratories is one of the facilities in 25 the Defense Division, yes. Bickerstaff direct 271 1 Q. The last three copy recipients 2 of Exhibit 29 are the administrator of 3 safety at headquarters, a Mr.. Ziefel, 4 the manager of industrial hygiene and 5 safety, and you, sir, at the industrial 6 hygiene laboratory. Why were those 7 three people copied on this? 8 A. Their prerogative from the 9 defense to just copy us on the X 0 information on the safety committee. 1 1 Q. Were the manager of industrial 1 2 hygiene and safety and the administrator 13 of safety for headquarters regularly 14 copied on these monthly meeting reports 15 as you were? 16 A. I be 1ieve so . 17 Q. on the page bearing Bates 18 stamp number 6072272, the third to last 19 page, there is a reference to a 20 directive from Westinghouse safety 2 1 headquarters Do you see that under 22 " OSH A update"? 23 A. Yes. 2 4 Q. Where were Westinghouse safety 25 headquarters located? Bickerstaff direct 272 1 A. It -was located in Pittsburgh. 2 Q. And what division was that 3 part o f ? 4 A. That's part of the 5 Headquarters Division. 6 Q. Am I correct that your 7 department was within the Westinghouse 8 safety headquarters? 9 A. Yes . 1 0 Q. Could this be a reference to a 11 directive from the Industrial Hygiene 12 Department of the Westinghouse safety 13 headquarters? 14 A. Well, it could be that or part 1 5 of our industrial hygiene safety 16 program. I had the industrial hygiene 17 part. 18 Q. Right, and I understand you 19 had a colleague who had the safety 20 aspect. 21 A. Right. 22 Q. How, it is extremely difficult 23 to read that paragraph, I recognize 24 that. But I would ask you to take a 25 good look at the underscored language, Blckersta direct 273 1 which I believe reads, "on advice of our 2 labor law section, these records should 3 not be made available to the. above," and 4 then the memoranda continues until it 5 reads, "locations should decline 6 compliance with revised regulation 7 pending court tests of its validity." 8 And the paragraph concerns OSHA or NIOSH 9 requests for employee individual 1 0 exposure and medical records. 1 1 Do you recall any 12 communications by safety headquarters 13 directing plants not to comply with OSHA 14 or NIOSH requests for individual 15 employee and medical records? 16 A. I remember something coming 17 out, yes. 18 Q. Could you tell me what your 19 recollection is please, sir? 20 A. He were advised by our Law 2 1 Department to put this communique out 22 because there was a new regulation and 23 it was being challenged* Until that 24 challenge was determined for or against, 25 we were told to comply with this order Bickerstaff direct 274 1 from the Law Department. 2 Q. Was the regulation that was 3 being challenged focused upo.n a 4 particular substance? 5 A. No. I think it was just the 6 challenge of this new regulation. 7 Q. Do you know what the outcome 8 of the challenge was? 9 A. The new regulation was upheld. 1 0 Q. Do you recall if there were 11 any further directives from safety 12 headquarters regarding the regulation? 13 A. I believe there was a 14 communique sent out that from now on you 15 will now comply with the regulation. 16 Q. And do you recall 17 approximately when that occurred? 18 A. No. It was after this, but 19 I'm not sure when. 20 Q. Do you know if it was before 21 1981, for example? 2 2 * A. I think it was, but I'm not 23 sure. It was not long after this. I 24 think it was a matter of six months or a 25 year that the challenge was finally Sickerstaff direct 275 1 decided. - 2 Q. Do you know if the types of 3 records which are the subject matter of 4 this paragraph were ever centralized at 5 Westinghouse headquarters? 6 A. So, I don't think they were. 7 Q. When the new directive came 8 out ordering compliance with the 9 requests, by government agencies, were 1 0 there any directives concerning IX notification to Westinghouse 12 headquarters ? 13 A. I can't remember exactly what 14 the communique said. I don't know. 15 Q. Do you know which departments 16 sent the communique out? 17 A. I believe it was theCorporate 18 Safety Department. 19 Q. That was your - 20 A. Wei 1, it was -- 21 Q. Your division? 22 A. Yes. 23 MR. COHEN: Let us mark as Mr. 24 Bickerstaff Exhibit 30 a one-page 25 document bearing. Bates stamp number Bickerstaff direct 276 1 833/0004533.- . 2 (Memo dated 8/31/78 is 3 marked as Exhibit Bickerstaff 30 for 4 Identification.) 5 Q. Have you previously seen this 6 document, sir, aside from preparation 7 for the deposition? 8 A. I probably did, because I was 9 advised of anything going out of our 10 department. I don't see a cc to me, but 11 I was advised. 12 Q. Was Diane Whittier a member of 13 your staff? 14 A. Yes . 15 Q. The document is from your 1 6 office i take it? 17 A. Yes . 18 Q. And it is to Westinghouse 19 Newark, New Jersey, attention Charles 20 Burger. Who was Mr. Burger? 2 1 A. Charles Burger was the 22 industrial hygiene and safety officer 23 for that location. 24 Q. And what was that location? 25 A. Newark. 1 think they made I Bickerstaff direct 277 1 relays, electrical relays. 2 Q. Do you recall what division 3 the plant belonged to? . 4 A. I think it was the Instrument 5 and Control Division. 6 Q. Now, the memo makes reference 7 to certain charcoal tube samples taken 8 by you, sir, and specifically mentions 9 the trichloroethylene sample. Do you 10 recall any advice given to Newark 11 concerning information received from 12 other plants or locations regarding 1 3 trichloroethylene? 14 A. Not offhand. 15 MR. COHEN: Let us mark as Mr. 16 Bickerstaff Exhibit 31 a two-page 17 document bearing Bates stamp numbers 18 eight 844/6072275 through 6072276. 19 (Safety Information Letter 20 is marked as Exhibit Bickerstaff 31 for 2 1 Identification.) 22 Q. Can you identify this 23 document, sir? 24 A. No, I don't know where it came 25 from Bickerstaff direct 278 1 Q. The document has in the upper 2 left-hand corner what appears to my eye 3 at least to be the Wes ting ho.use logo. 4 And the last page has the sign-off of 5 "Safety Department." Have you ever 6 seen a similar type of safety 7 information letter during your 8 employment at Westinghouse, if not this 9 particular document? 1 0 A. I don't remember this logo in 11 this style, no. 12 Q. Was it a practice of 13 Westinghouse to obtain safety 14 information letters from other 15 corporations? 16 A. We belonged to certain 17 committees and professional 18 organizations that other companies 19 belonged to and we did get together and 20 share information. This to me looks 21 like it's probably a plant or division 22 or something, because the corporation 23 would not send something out like this 24 unless there was a cover letter to it. 25 But by itself, you don't know who it Bickersta f direct 279 1 went to or whatever, and you certainly 2 wouldn't put Safety Department, you 3 would put the author who sent it. 4 Q. Have you ever seen such a 5 safety information letter attached to 6 the memoranda concerning the monthly . 7 management safety committee meetings of 8 the Defense Division? 9 A. It could have been. I can't 1 0 say. 11 Q. You can't say one way or the 1 2 other ? 13 A . No . 14 HR. COHEN: Let us mark as Mr. 15 Bickerstaff Exhibit 32 a document 1 6 bearing Bates stamp numbers 132/4079541 17 through 4079542. 18 (Memo dated 9/19/78 is 19 marked as Exhibit Bickerstaff 32 for 20 Identification.) 2 1 Q. First of all, sir. Gateway 22 Pittsburgh is a heading seen on many 23 documents. I take it that's a reference 24 to headquarters? 25 A. That's right. Bickerstaff direct 280 1 Q. And the "to" here is works 2 engineers. Would that be a memo 3 therefore directed to plants, or 4 divisions? 5 A. Plants and could be divisions 6 too . 7 Q. The document concerns a system 8 proposed by Chemical Waste Management, 9 whereby various PCB-contaminated 10 materials can be disposed of in five 11 regions of the United States. Was there 1 2 any practice concerning communicating 1 3 with the Industrial Hygiene Department 1 4 by the environmental control and 15 construction technology group headed by 16 Mr. Kerns with regard to PCB disposal 17 practices ? 18 A. We could have shared the same 19 person at a location. In other words, 20 that person who works in works 2 1 engineering could possibly have also 22 been the industrial hygiene safety 23 officer. But unless they were on his 24 official distribution, they did not get 25 copies. . Bickersta f f direct 281 1 Q. And unless you weresharing 2 the same person with Mr. Kerns, the 3 person to whom you communicated would 4 not necessarily know about this 5 c ommunic a tion? 6 A. That's correct. 7 Q. And 1 take it this 8 communication in no way was directed to 9 you as a direct or copy recipient? 1 0 A. No . 1 1 Q. Were there any formal or 12 informal practices, policies or 13 procedures followed by the Industrial 14 Hygiene Department with regard to 15 communicating with the corporate IS headquarters Insurance Department at 17 Westinghouse? 18 A. Not any formal. Informal, as 19 we had a need to, but nothing formal. 20 Q. If a loss had occurred at a 2 1 plant, would you be involved in the 22 reporting of that loss? ' 23 A. What kind of loss? 24 MR. BRENDGL: I'm going to 25 object on the grounds that this is Bickerstaf f direct 2 82 1 paragraph six information, and this 2 witness hasn't been designated or 3 offered or prepared for paragraph six 4 information. And it's out of scope. We 5 have a witness here today who is going 6 to address that subject, so I would 7 request that you direct your questions 8 to that witness. 9 MR. COHEN: I will direct many I 0 questions to that witness. If the 11 witness now testifying understood my 12 question, I would like an answer or an 13 explanation as to whether you are 14 directing him not to answer, and 15 certainly if he cannot answer my 16 question as phrased, I need to know 17 that. 18 MR. BRENDEL: Why don't you 19 read the question back, and I'll respond 20 accordingly. 2 1 MR. COHEN: Fair enough. 22 (The question is read by the reporter.) 23 MR. BRENDEL: I object to that 24 question. I'm directing the witness to 2 5 the extent that that question Bic ker s t a f f direct 283 1 contemplates -information relating to the 2 reporting requirements of Westinghouse 3 divisions and plants concerning property 4 loss procedures for insurance claims 5 generally and that arising out of the 6 presence of any substance, as 1 am 7 quoting verbatim from paragraph six of 8 the notice for which this witness is not 9 designated, if it involves that subject 10 matter, then the witness should not 11 respond. If you have information other 12 than something that involves the 13 reporting practices or requirements of 14 the divisions and plants concerning 15 property loss procedures for insurance 16 claims -- actually, as the question is 17 phrased, it's clear that it's directed 18 to paragraph six. So I'll make the 19 decision simple. Do not respond. 20 MR. COHEN: I disagree 2 1 vehemently and strenuously, but I will 22 not belabor the record. 23 Q. Were there any formal 24 policies, practices or procedures within 25 your division concerning communications Bickerstaff - direct 2 84 1 with the Insurance Department? 2 A. There was nothing formal. 3 MR. COHEN: Let's nark as 4 Exhibit 33 a document bearing Bates 5 stamp numbers 844/6073989 through 6 6074020. 7 (Memo dated 6/19/79 is 8 marked as Exhibit Bickerstaff 33 for 9 Identification.) 1 0 Q. Have you had a chance to 11 review the exhibit? 12 A. Yes. 13 Q. Can you identify it please? 14 A. It's a letter to me from Mr. 15 Bob Bergquist/ who was with the Power 15 Generation Service Division facility in 17 San Francisco. 18 Q. Now, the letter forwards to 19 you three reports submitted by a James 20 Jackson to the Tucson Electric Power 2 1 Company concerning asbestos insulation 22 removal at the customer's North Loop 23 station. Were there any formal 24 practices, policies or procedures which 25 you followed concerning asbestos Bickerstaf f direct 285 1 remediation at a customer's operation or 2 plant in 1979? 3 MR. BREKDEL: Could you read 4 the question back? 5 (The question is read by the reporter.) 6 MR. COHEN: I'll rephrase the 7 question. 8 Q. Were there any guidelines 9 governing you when advised of a plant's 1 0 involvement with the use of various 11 substances such as asbestos? 12 A. You're going to have to read 13 that back too. 14 (The question is read by the reporter.) 15 MR. BRENDEL: I don't think 1 6 it's very well focused. I'm not sure if 17 the witness understands it. 18 MR. COHEN: I'll try again. 19 Q. When you received a document 20 such as this, were there any practices, 2 1 policies or procedures which you were 22 required to follow concerning this 2 3 communication and to whom you should 24 communicate with? 25 A. Well, in this particular Bickerstaf f direct 2 86 1 document here, it was pretty much the 2 Power Generation Service Division. 3 Everybody was copied. The San Francisco 4 office, Phoenix where the project went 5 on, and Broomall, which was the 6 headquarters at that time for the Power 7 Generation Service Division. So he not 8 only copied me, he copied them too. 9 Q. Did you have'any requirements 1 0 to inform your superiors of these 11 circumstances? 12 A . No . 13 Q. Do you remember the subject 14 matter of this communication? 15 A . V e s . 16 Q. Do you recall communicating 17 back to the San Francisco plant? 18 A. I may have. I don't remember 19 o f fhand. 20 Q. On page 6074005, there is an 2 1 introduction to the report by Dr. 22 Jackson dated April 30 of 1979, which 23 indicates the involvement of 24 Westinghouse health and safety 25 representatives at both the corporate Bickers ta f f direct 287 1 and divisional levels. Would that have 2 involved people on your staff or Mr. 3 Kerns'staff? . 4 A. It would involve people on my 5 staff. 6 Q. When your staff was involved 7 in the evaluation of asbestos exposure 8 at customer sites, were there any 9 particular practices, guidelines or 1 0 requirements about communicating the 11 involvement to corporate headquarters? 12 A. I don't know if there was a 1 3 policy. We worked very closely with the 14 Power Generation Service Division on 15 this project, because asbestos was 16 becoming a concern. We wanted to do 17 this one literally by the book, do 18 everything proper, and I was the one who 19 recommended Dr. Jackson. I knew him 20 from the American Industrial Hygiene 2 1 Association. And he was actually I 22 believe employed by Tucson Electric, but 23 it was the Westinghouse people who 24 actually performed the job and it was to 25 protect our Westinghouse people. Bickerstaf f direct 288 1 Q. Was there any discussion about 2 implementing the procedures used for 3 non-Westinghouse plants for Westinghouse 4 plants? 5 A. No. This kind of work, this 6 was a utility, and we don't operate 7 utilities . 8 Q. At the same time, however, 9 there was some discussion within 10 Westinghouse about Westinghouse employee 11 exposure to asbestos within Westinghouse 12 plants? 13 A. Right, that's correct. 14 Q. Given that circumstance, was 15 there any thought given to tying the two 16 types of situations together? 1.7 A. I'm not saying that it wasn't 18 totally excluded. I'm sure we gleaned 19 information from this that we would then 20 pass on to other Westinghouse locations 2 1 if they got involved in an "asbestos" 22 abatement or removal project, whatever. 23 Q. Do you recall any formal 24 method of disseminating that 25 information, such as a periodic report t Bickerstaff direct 289 1 or a practice, which was implemented? 2 A. It may have been put in one of 3 our "newsletters" or updates, included 4 in our training programs. We had a 5 formal Westinghouse asbestos abatement 6 training course we put on in, let me 7 think about that, oh, 1984, '85, 8 something like that. 9 Q. Prior to that, was all the 10 communications regarding asbestos 11 abatement whether at Westinghouse plants 12 or non-Westinghouse plants such as 13 customer plants on an ad hoc basis? 14 A. Correct. 15 MR. COHEN; Let us mark as Mr. 16 Bickerstaff Exhibit 34 a two-page 17 document bearing Bates stamp numbers 18 132/4429767 through 4429768. 19 (Memo dated 10/18/79 is 20 marked as Exhibit Bickerstaff 34 for 2 1 Identification. ) 22 . Q. Have you ever seen Exhibit 34 23 prior to today aside from preparation 24 for the deposition? 25 A. I don't remember it, no. Bickerstaff direct 290 1 Q. Is there any indication that 2 it went to your department or division? 3 A . No, I don't see a n.y indication 4 on the letter. 5 Q. Now, the author is a Mary Jo 6 Aiken, supervisor, accident prevention 7 and industrial hygiene. Was that within 8 the Motor Division? 9 A . Correct. 1 0 Q. And she therefore was not 11 within your division? 12 A. That's correct. 13 Q. Am I correct that Exhibit 34 14 is directed to four different divisions? 15 A. 1 think it's four different 16 divisions within the same division. 17 Q. So that the Large Motor 18 Division, Medium Motor Division, Power 19 Electronic and Drive System Division and 20 Technical Services are all part of the 21 Motor Division? 22 A* Correct. 23 Q. Now, Ms. Aiken speaks about 24 until such a viable computer tracing 25 program is developed, there needs to be Bickersta f f direct 29 1 1 a manual collection of names and 2 individuals within the division who have 3 been directly exposed to as be stos during 4 the course of their work in 1979. Would 5 employees in the Motor Division be 6 people who would ordinarily work within 7 Westinghouse plants or in sites of 8 c 1 ients ? 9 A. In this case here, these were 1 0 primarily people who worked in 11 Westinghouse plants. 12 Q. Do you recall any 13 communications with the Motor Division 14 regarding Dr. Jackson's monitoring of 15 asbestos exposure during the course of 16 work done for the Tucson Power Electric 17 Company? 18 A. Any correspondence between 19 them you say? I guess I'm -- 20 Q. Any correspondence from your 21 office, sir, to the Motor Division about 22 what Dr. Jackson was doing for the 23 Westinghouse client. 24 A. I don't remember any offhand. 25 Q. Were there any formal Bickers ta f f direct 292 1 practices, policies or procedures that 2 required you to inform the Motor 3 Division about the experience of the 4 Westinghouse health and safety 5 representatives at both the corporate 6 and divisional level who were working on 7 the Tucson Electric Power Company 8 project? 9 A. No, there was no formal 10 reporting information. 11 Q. Now, the letter to you which 12 we've marked as Exhibit 33 from the San 13 Francisco Power Generation Division I 14 believeitwas? 15 A * v e s . 16 Q. Concerning forwarding Dr. 17 Jackson's report is dated about four or 18 five months before Ms. Aiken is 19 providing a list of individuals known to 20 have been exposed to asbestos during 21 1978. Do you recall any advice by the 22 Motor Division concerning its employees 23 who had been exposed to asbestos and 24 requests for assistance? 25 MR. BRENDSL: Any advice from Bic ke rs ta f f direct 293 1 the Motor Division to? 2 . MR. COHEN: To industrial 3 hygiene, correct, to his department or 4 division. 5 A. There may have been inquiries for information, but let me clarify 7 something. 8 Q . Certainly. 9 A. This project here on the 1 0 abatement was taking it primarily off of 11 insulation. The exposure in Buffalo, if 1 2 there was any at all to asbestos, was 1 3 employees putting asbestos products, 1 4 asbestos-containing materials into 15 products. Totally different in scope of 16 work. See, here when you take it off 1 7 you wet it down, control it. If you wet 18 it down here, you would ruin the 19 product. 20 Q. Let me make sure I understand 2 1 your answer, sir. You were referring to 22 Exhibit 33 and the Tucson Electric Power 23 Company abatement program when you made 2 4 reference to controlling asbestos and 2 5 wetting it down. Bickerstaff direct 294 1 A . Correct. 2 Q. With regard to Exhibit 34 and 3 the Motor Division employees., those 4 people would be using asbestos products 5 in such a manner that wetting down the 6 asbestos would prevent the use of it for 7 the product? 8 A. You might ruin the product 9 then, correct. 10 Q. Exhibit 34 concerns employees 11 who have been directly exposed to 12 asbestos during the course of their work 13 in 1979 and attaches a list of 1 4 individuals who had been exposed in 15 1978. Is it your understanding of this 16 document that these people in 1978 and 17 the people whose names are sought for 18 1979 were exposed to asbestos in a 19 non-wetting situation? 20 MR. BRENDEL: I'm going to 2 1 object. 22 - A. I don't know. 23 MR. BRENDEL: We're getting 24 into the substantive areas of what 25 happened with respect to the actual * Bickerstaff direct 295 1 underlying matters as opposed to line of 2 communication. The witness has 3 indicated that in any event,, he doesn't 4 have any knowledge on the question. For 5 the record, I make the objection. 6 HR. COHEN: Your objection is 7 noted. 8 Let us mark as Exhibit 35 for 9 identification a document bearing Bates 1 0 stamp number 844/6072724 through 11 6072725. 1 2 Q. Have you had a chance to 13 review Exhibit 35, sir? 1 4 A . Yes. IS Q. Have you ever seen this IS document before aside from preparation 17 for the deposition? 18 A. Looking at the second page, I 19 was copied back in 1979. It must have 20 been in my department. 2 1 Q. Now, the document begins by 22 noting that the power generation 2 3 operations safety group meeting is 24 scheduled for October 24th through the 2 5 26th in Charlotte, North Carolina. Is Bickerstaff direct 296 1 that group part of the same division to 2 which R. L. Bergquist of the PGSD San 3 Francisco office, who wrote Exhibit 35, 4 belonged? 5 A. I believe so. 6 Q. Excuse me, I misspoke. That 7 was Exhibit 33 and you understood me? 8 A. Yes. 9 Q. Now, did the San Francisco 10 operation of the Power Generation . 11 Division receive a copy of Exhibit 35 12 according to the face of this document? 1 3 A. I don't see it on the front. 14 No, I don't see anything that indicates 15 they got copies of it. 16 Q. Now, this document is from a 17 Mike Mangan, manager, safety, wage and 18 salary administration. I take it that 19 was a department within the Power 20 Generation Division? 2 1 A. That was the tfestinghouse 22 Charlotte plant, and Mike Mangan at the 23 time was the manager of safety and 2 4 we 1 fare, yes. 25 Q. For that plant? Bickerstaf direct 297 X A. Yes. 2 Q. Not necessarily for that 3 division? 4 A . Correct. 5 Q. Am Z correct then that this is 6 an example of plant-to-plant 7 communication? 8 A. This probably was plant to 9 plant within the same division at the 1 0 time. westinghouse organizes and 1 1 reorganizes, and at that time this group 12 of plants were in the same division. 13 Q. Do you know if the San 14 Francisco plant was in the same 15 division? And I believe Exhibit 35 is 16 dated December of 1979. 17 A. I believe they were in the 18 same reporting division, correct. 19 Q. Now, Hr. Mangan is writing 20 directly to various people at the East 21 Pittsburgh, Lester, Broomall, Muncie and 22 Winston-Salem plants about a power 23 generation operations safety group 24 meeting. Do you know if those 2 5 particular plants had representatives Bickerstaff direct 298 1 within that safety group? 2 A. Within what group? 3 Q. The power generation 4 operations safety group. 5 A. Yeah, the people they've 6 indicated here, Mr. Brady, Whittington, 7 Engle, O'Kora and Waters were the 8 industrial hygiene and safety 9 representatives for each of those 10 locations. 1 1 Q. So this division had an 12 operations safety group for its plants? 1 3 A. At that time, yes. 1 4 Q. Do you recall when that group 15 was first formed? 16 A. No, I don't know. 17 Q. Do you know if ever the group 18 was disbanded? 19 A. Well, we no longer have an 20 Bast Pittsburgh, Lester, Broomall, 2 1 Mancie was sold. Winston-Salem is still 22 Westinghouse. 23 Q. Perhaps I did not phrase my 24 question clearly. I'm not concerned 25 with whether the component members of Bicker s taf f direct 299 1 the group changed but rather whether the 2 group ever ceased to exist. 3 A. Yes, they did, because again, 4 we only have one of those plants. I'm 5 sorry, and Charlotte too. Winston-Salem 6 and Charlotte are still plants of 7 Westinghouse . 8 Q. The memo sets forth the agenda 9 for the meeting, and the last item on 1 0 the agenda, which is page two of the 11 exhibit, reads, "medical surveillance of 12 first-line supervisors exposed to 13 asbestos, weld fumes, toxic materials, 14 et cetera." Do you recall any 15 communications or guidelines concerning IS communications with regard to the 1 7 results of the meeting on that subject 18 matter? 19 A. No, I don't. 20 Q. I notice that you, as you 2 1 pointed out, are a copy recipient and so 22 is~a P. Palmieri, manager of corporate, 23 safety, headquarters. Were you and Hr. 24 Palmieri the only two Headquarters 25 Division personnel that were copied on Bickerstaff direct 1 this document? 30 0 2 A. That's all I see on the 3 document,'' that's correct. 4 Q. Do you recall communicating to 5 any member of the group any of the 6 information provided to you in Exhibit 7 33 concerning the San Francisco 8 operations and experience with asbestos 9 exposure ? 10 A. You mean for this meeting? 11 Q . Yes, sir. 12 A. I don't rememberoffhand, but 13 one of the persons who was copied on 14 this attended the meeting. 15 Q. okay, and who would that be? 16 A . Mr. Engle. 17 Q. Was Mr. Englecopied on 18 Exhibit 33 pursuant to any practice or 19 procedure? 20 A. I think it was more of a 21 practice that information like that was 22 from the San Francisco office back to 23 the Power Generation Service Division 24 headquarters, which at that time was 25 Broomall. That's why he was copied. Bickerstaff direct 301 1 Q. So that the local san 2 Francisco plant would copy its 3 divisional headquarters in what 4 circumstances? 5 A. Well, in this case it was 6 because of the asbestos abatement 7 project that occurred there. 8 Q, I understand that. So was it 9 a significant fact that the substance 10 involved was asbestos? 11 A. Well, yes. It would probably 12 be a combination of asbestos, because 13 all power generation service offices, 14 plants, whatever, did the same thing. 15 They worked out at the customer 16 location. So anything that he learned 17 there in this job they were going to try 18 to put in practice for all other power 19 generation service operations. 20 Q. Do you recall any practices or 21 guidelines concerning the dissemination 22 of information obtained by the Power 23 Generation Division when working for 24 non-Westinghouse sites to Westinghouse 25 plants? Bickerstaf f direct 302 1 A. Nothing direct. Maybe through 2 us, if it was something we thought was 3 applicable. But I can't think of 4 anything direct. 5 Q. Do you recall any discussions 6 about whether it would be a good idea to 7 have the Power Generation Division 8 communicate with the Motors Division 9 concerning asbestos exposure to 10 employees ? 11 A . No . 12 MR. BRENDEL: Why don't we 1 3 take a brief break here. 14 (There is a brief recess.) 15 MR. COHEN: Let us mark as Mr. 16 Bickerstaff Exhibit 36 a document 17 bearing Bates stamp number 132/4085146 18 through 132/4085146. 19 (Memo dated 7/7/81 is 20 marked as Exhibit Bickerstaff 36 for 2 1 Identification.) 22 Q. Have you had a chance to 23 review the exhibit, sir? 2 4 A. yes . 25 Q. is this a document you have Bickerstaff - direct . V 303 1 seen previously outside of preparation 2 for the deposition? 3 A. Although I may not. be copied 4 directly on it, I remember this. This 5 was about eleven years ago though. 6 Q. Am I incorrect that this was a 7 response to a request made to you by Mr. 8 Bryant? 9 A. That's what it appears to be, 10 yes. 1 1 Q. And that request in this 12 response would be an example of an 1 3 informal communication between you and 14 your department and the Insurance 15 Department ? 1 6 A. Yes. This was apparently a 17 specific request. 18 Q. And aside from those occasions 19 when a specific request would be made, 20 were there any formal practices 2 1 concerning communications between the 22 Safety Division and the Insurance 23 Divis ion? 2 4 A. None that I'm aware of. 25 Q. Do you recall the reason, if Bickerstaff direct 304 1 you were told any reason, why the 2 request for this information was being 3 made ? . 4 A. I d o n't re m ember. 5 Q. Do you recall any further requests for information after this 7 response was made? 8 A. There may have been more 9 updates, but 1 can't say for sure. 1 0 Q. The first attachment to the 11 exhibit is a letter sent to all 12 industrial hygiene and safety 13 coordinators informing them of a one-day 1 4 seminar on asbestos and a questionnaire 15 that was sent with that letter to survey 1 6 the use of asbestos in each location. 17 The second attachment is a roster of 18 those who attended. When this seminar 19 took place in March of 1976, do you 20 recall what criteria was used for 2 i determining who would attend this 22 seminar? 23 A. Well, 1 think it was really at 24 the discretion -- if there was use of 25 asbestos in your facility, this was Bickerstaff direct 3 05 1 meaning to look at potential 2 substitutes. And the concern basically 3 was asbestos used in manufacturing 4 either parts or whatever/ not so much 5 asbestos like power generation, removing 6 it for a customer. This was primarily 7 in Westinghouse plants. 8 Q. The second delineated subject 9 matter of the memo is "employee exposure 10 to asbestos, current and historical." 1 1 The document appears to focus upon 1 2 employee exposure within Westinghouse 13 plants, as you have just pointed out, 14 and not outside of Westinghouse worked 15 on say by the Power Generation 16 Department. Was there any reason that 1 7 type of exposure was excluded from this 18 communication? 19 MR. BRENDEL: I'm going to 20 object on the grounds that it's beyond 2 1 the scope. It's asking substantive 22 questions about substantive subject . 23 matters as opposed.to reporting lines 24 and lines of communication. 25 MR. COHEN: I understand your Bickerstaff direct 306 1 objection. I- believe that my question 2 falls within the scope of the 3 deposition. My purpose is to find 'out 4 if there was some other type of 5 communication with regard to the power 6 generation employees or a rationale 7 regarding or a practice governing this 8 type of communication such that those 9 employees would not be within the scope 10 of this communication. 11 A . I don't know. 12 MR. COHEM: With all those 1 3 caviats, may I have an answer? 14 MR. BRENDEL: You may answer 15 to the extent that you can. 16 A. I don't know why they were not 17 included. I don't know. 18 Q. Do you know if that was part 19 of the requested information? 20 A. Againf 1 don't remember. 2 1 MR. COHEH: Let us mark as Mr. 22 Bickerstaff Exhibit 37 a document 23 bearing Bates stamp numbers 003/13736 24 through 13741. 25 (List of Toxic Substances is Bickers taf f direct 1 marked as Exhibit Bickerstaff 37 for 3 07 2 Identification.) 3 Q. Sir, have you ever, seen this 4 document before? 5 A . Last week. 6 q. Aside from that? 7 A. I don't remember it, no. 8 Q. Do you have any idea what it 9 is ? . 10 A. Well, I see several Lamp 11 Division plants and different sections 12 within those plants and a list of what 13 they call toxic substances. I don't 1 4 know who put it together or why. 15 Q. Focusing on why, are you aware 16 of any practice, policy or procedure in 1 7 or about October of 1979 concerning the 18 centralization of information regarding 19 toxic substances at various Lamp 20 Division plants? 2 1 A. Nothing from our office, no. 22 Q. And aside from your office, 23 are you aware of anything? 24 A . No . 2 5 MR. COHEN: Let us mark as Bickersta direct 1 Bickerstaff Exhibit 38 a document 308 2 bearing Bates stamp numbers 844/6073140 3 through 6073141. 4 (Memo dated 11/2/79 is 5 marked as Exhibit Bickerstaff 38 for 6 Identification.) 7 A. The name of the first training B communicator in our department, her name 9 was Norma Stamford, spelled just like 10 the university. I knew it would come to 11 me . 12 Q. Thank you, sir. Let me know 13 when you have had an opportunity to 14 review Exhibit 38. 15 A . Okay. 16 Q. Aside from preparation for the 17 deposition, sir, have you ever seen this 18 document before? 19 A* 1 may have. I don't see. that 20 I was copied on it, but I may have. Oh, 2 1 I*a sorry, yes, I am copied on the 22 front. 23 Q. This particular copy of the 24 document has a checkmark next to your 25 name. Does that checkmark signify Bickerstaff direct 1 anything to you? 309 2 A. That that copy was to come to 3 me. . 4 Q. Now, the document in the first 5 sentence refers to something known as 6 "Westinghouse considerations." Do you 7 recall a communication with that title? 8 That apparently was written by w. H. 9 Hamilton, senior consultant. 1 0 A. No, I don ' t . 1 1 Q. Exhibit 38 was authored by E. 12 A. Conrads, director of resources loss 13 prevention. Was he within the 14 Headquarters Division? 1 5 A . Yes. 1 6 Q. And what department was loss 17 prevention? 18 A. That was in the human 19 resources. He was my boss at the time. 20 Q. Mr. Conrads notes that the 21 Corporate industrial Hygiene Department, 22 which I take it was part of human 23 resources, has been involved in 24 assisting the Corporate Law Department 25 prepare for the various litigation and Bickerstaf f direct 3 10 1 workers' compensation cases. Were there 2 any practices or procedures followed 3 regarding communications be t.w e e n the 4 Corporate Industrial Hygiene Department 5 and the Corporate Law Department with 6 regard to litigation or workers' 7 compensation cases involving exposure to 8 substances, human exposure to 9 substances ? 1 0 A. It wasn't anything formal. X X They would tend to take the lead and 12 involved us if they felt we could help X 3 them prepare for these. 14 Q. now, the first delineated item 15 concerning the litigation is 180 16 lawsuits concerning asbestos. Were 17 there any discussions concerning 18 communicating information regarding 19 exposure to asbestos by various 20 divisions with regard to these lawsuits 2 1 or because of these lawsuits? 22 A. There could have been. I 23 can't say for sure. 24 Q. Was any formal practice or 25 policy implemented about disseminating Bickerstaff direct 1 asbestos information? 3 11 2 A. Not that I remember. 3 Q. Was there any discussion about 4 not disseminating information because of 5 concern of potential litigation 6 regarding human exposure to asbestos? 7 A. Not that I remember. 8 Q. The third item is beryllium 9 exposure to employees at Bloomfield, New 1 0 Jersey and Fairmont, West Virginia X 1 plants. Do you recall any 12 communications or procedures regarding 13 communications with regard to beryllium 1 4 exposure ? 15 A. I remember some workers' comp 16 cases at Bloomfield. I don't remember 17 the ones at Fairmont offhand, but we may 18 have put information together on the 19 workers' comp cases looking at our own 20 safe practice data sheets, things like 21 this, working with beryllium. But 22 that's the best I remember. - 2 3 Q. And the purpose in putting 24 that information together was what? 2 5 A. To help our defense on what Bickerstaff direct 3 12 1 our practices were for whatever 2 information we had on the use of 3 beryllium at that plant. . 4 Q. And from where did you draw 5 your information that was put together 6 to help the defense? 7 A. I would just go back through 8 what information we had in our files on 9 the use of beryllium. 1 0 Q. And would that include 11 information derived from local plants? 1 2 A. It could. He would probably 13 again, if it was Bloomfield, go back 14 through our records, what information we 15 had on the Bloomfield file. 16 Q. Did you cross-reference to 17 other plants that might have employee 18 exposure or human exposure to beryllium? 19 A. We could have. I don't know. 20 Q. Was there anything preventing 2 1 you from doing so? 22 A. No. 23 Q. Would the decision to do so or 24 not to do so be based upon any criteria? 25 A. No, not really. I can't think Bickerstaff direct 3 13 1 of anything that would prevent us. 2 Q. The fourth item refers to lead 3 exposure to employees at, correct me if 4 I'm wrong, two different plants? 5 A. Two different plants. 6 Q. Did the Industrial Hygiene 7 Department again gather information for 8 the purpose of defending the litigation 9 or workers' compensation claims? 1 0 A. I think these were workers' 11 compensation claims, because it talks 12 about employee exposures. Again, we 13 would, yeah, what information do we have 14 on use of lead or whatever at these two 15 locations. We would just pull 1 6 information from our files. 17 Q. And again, what files were you 18 pulling information from? 19 A. The plant file for KW Battery 20 and also for the Baltimore defense. 2 1 Q. Someone from industrial 22 corporate headquarters would obtain that 23 information from the plants? 2 4 A. What information we would have 25 from the plants, either through Bickerstaff direct 1 correspondence or if we had any air 3 14 2 sample records or things taken at that 3 plant or even general information on 4 lead. 5 Q. What I am unclear about, sir, 6 is whether your search for information 7 would be limited to the Industrial 8 Hygiene Department's files, which I take 9 it at that time were kept at East 10 Pittsburgh? . 11 A. At this time period, no, we 12 were at the Science and Technology 13 Center. 1 4 Q. Pardon me. Whether you would 15 search only the files at the Science and 16 Technology Center or whether you would 17 search files somewhere else. 18 A. We would primarily search our 19 files. . 20 Q. Science and Technology? 2 1 A. Yes, our files in that plant. 22 We kept our own files, yes. 23 Q. Did you cross-reference to 24 other plant files? 25 A. Probably not. Bickerstaff direct 3 15 1 Q. Was there any effort to gather 2 information from the particular plants 3 at issue in the various cases? 4 A. I don't know. I can't say for 5 sure. I don't know if we did or not. 6 Q. Would that have been something 7 that may have been handled by the 8 Corporate Law Department? 9 A. They may have. 10 Q. Do you know if they did? 11 A. I don't know. 12 Q. Do you know if the Corporate 13 Law Department cross-referenced to other 14 plants handling the same substances that 15 may have been involved in any particular 16 litigation or case? 17 A. I don't know. 18 Q. Now, your superior, Mr. 19 Conrads, suggests that the Corporate 20 Industrial Hygiene Department should be 2 1 used on a task force to respond to 22 litigation brought against Westinghouse 23 arising out of exposure to hazardous or 24 toxic materials. Was that suggestion 25 ever implemented? - Bickerstaff direct 3 16 1 A. I don't know if there was a 2 task force, but in the future, anytime 3 there was either workers' compensation 4 or anything involving toxic materials 5 and either employee exposures or 6 whatever, we would be contacted by 7 somebody from the Law Department to 8 somebody maybe from the Workers' 9 Compensation Department to assist him in X 0 preparing for the defense. I don't 1 1 think that there was a specific task 12 force really put together. 1 3 Q. If I understand you, sir, what 1 4 you are saying is that the procedure was 15 implemented without the formality of 1 6 calling it a task force? 17 A. I believe so, yes. 18 Q. Once that procedure was 19 implemented, were all plant records 2 0 concerning hazardous materials 2 1 centralized at industrial hygiene? 22 A. Mo. 23 Q. The assistance that industrial 24 hygiene lent in the event of workers' 25 compensation cases or litigation arising Bickerstaff direct 3 17 1 out of exposure to substances would be 2 limited to a search of the documents 3 already on file at industrial hygiene 4 headquarters? 5 A. Pretty much, yes. We didn't 6 have all records, you know, for 7 everything sent to our department, no. 8 Q. Was there ever any discussion 9 as to whether that would aid the 10 defense? 11 A. I'm sure the centralization of 12 records, but, you know, there was no 13 system to put it onto a computer. You 14 would just have hard copies, and a 15 search of that would .be endless. 16 Q. was there ever any discussion 1 7 about not centralizing the records? 18 A. I don't remember something 19 either for or against really. 20 Q. Let us mark as Mr. Bickerstaff 2 1 Exhibit 39 a document bearing Bates 22 stamp numbers 132/4085266 through ' 23 132/4085271. 24 (Memo dated 11/9/79 is 25 marked as Exhibit Bickerstaff 39 for Bickerstaff direct 1 Identification.) 3 18 2 Q. Aside from preparing for 3 today's deposition, have you. ever seen 4 this document before? 5 A. I may have. I don't remember. 6 Q . Were you one of the designated 7 addressees ? 8 A. No. It says division and 9 division general managers. 10 Q. Who would get a document 1 1 directed to division and division 12 general managers? 13 A. All the general managers and 14 division managers. 15 Q. That would be at divisional 1 6 headquarters? 17 A. Yes . 18 Q. So for example/ with regard to 19 lamp plants, this would go to the 20 operations manager at Bloomfield for the 2 1 division? 22 A. It could. Again, I don't 23 know. I don't know who John Gormley had 24 on his distribution. 25 Q. I take it your understanding, Bickerstaff direct 3 19 1 and I understand it's strictly your 2 understanding based upon your employment 3 at Westinghouse, is that this document 4 would not directly go to a Lamp Division 5 plant somewhere other than Bloomfield? 6 A. Say that again. 7 Q. Let me give you a concrete 8 example. 9 A. Okay. 1 0 Q. Would this document go 1 1 directly from the Design and 12 Manufacturing Center to a Lamp Division 13 plant site in Mexico? 14 A. Oh, I doubt it. I doubt it. 15 I don't know for sure. 16 Q. Would it go to any particular 17 plant which was not a divisional 18 headquarters in the ordinary course of 19 business? 20 A. I don't know. 21 Q. Mow, the document I had 22 indicates that there will be new 2 3 regulations restricting the use of 24 asbestos, and the penultimate sentence 25 of the first page of the document reads. Bickerstaff direct 320 1 "this is our `opportunity to influence 2 the direction of the government policies 3 before they become fixed." . 4 Do you recall any other times 5 when information was solicited in an 6 effort to influence the direction of 7 government policies with regard to 8 substances? 9 A . Oh, yeah. 1 0 Q. What other occasions do you 11 recall? 12 A . Just recently. OSHA was asking 1 3 again for comments in the Federal 1 4 Register - - 1 5 MR. BRENDEL: You should limit 1 6 yourself to the time frame at issue. 17 from '75 to '82. 18 A. Then we could have. Again, l 19 can't say specifically we asked for it. 20 Q * Let me ask this . Generally 2 1 was it a practice within Westinghouse 22 when regulations of substances were 23 being proposed to solicit information 2 4 from various divisions? 25 A . If we felt that there was a Bickerstaff direct 321 1 use of that product or that material in 2 Westinghouse and we could add comments 3 to the agency/ because they're asking 4 for comments, we would on occasion 5 solicit comments from plants and then 6 send them into the agency. 7 Q. And was it a practice in 8 soliciting comments that the responses 9 would be centralized for compilation, 10 reviewed for consistency and clearing 11 with the Law Department as indicated in 12 Exhibit 39? 13 A. In most cases I would guess 14 that happened, yes. 15 Q. Do you recall if a similar 16 circumstance took place with regard to 17 regulation, for example, of PCBs? 18 A. I don't know. 19 Q. Do you recall any other 20 substances where this occurred offhand? 21 A. Again, to that time period, 22 '75 to* '81, I'm just trying to think 23 what regulations were coming in at that 24 time. I can't think of any specific 25 ones right now. But again, the intent Bickerstaff direct 322 1 for the agency was they want comments, 2 how is this going to impact you, are 3 there substitutes. So if we. could, we 4 would try to comment, provide that, give 5 them alternatives. 6 Q. Was one of the reasons for 7 which this practice was followed was to 8 attempt to lessen the economic impact 9 upon Westinghouse? 10 A. It could be. 11 MR. BRENDEL: Objection. Out 12 of scope. Answer only if you have 13 personal knowledge. 1 4 A. It could have been. 15 Q. Was the safety Division one pf 16 the divisions being solicited for 17 comments by Exhibit 39? 18 A. I don't see anybody -- I don't 19 see any indication that we were copied 20 on this. 2 1 Q. So that something that is to 22 all division and division general 23 managers would not include industrial 24 hygiene and safety at headquarters? 25 A. it may not have. Bickerstaff - direct 323 1 Q. So whatever information was 2 centralized at your division would not 3 be provided to the Corporate Law 4 Department in response to this? 5 A. This wasn't my division. I 6 don't know -- I guess I don't follow 7 you . 8 Q. Perhaps I misspoke. You were 9 with the industrial hygiene - 1 0 A. Safety Department. 1 1 Q . Department, which was part of 12 the - - 13 A. Headquarters Division. 1 4 Q. Of? 15 A. Westinghouse. 16 Q. Was the Headquarters Division 17 intended, to your knowledge, to be a 18 recipient of this document? 19 MR. BRENDEL: I'm going to 20 object to the extent you're asking what 2 1 was intended. 22 MR. COHEN: I'll rephrase the 23 question. 24 Q. Is it your understanding that 25 a document addressed like this would go Bickerstaf f direct 324 1 to the Headquarters Division? 2 A. I don't know for sure. I 3 would suspect that somebody at 4 headquarters would have gotten a copy, 5 but I don't know for sure. 6 Q. Do you recall if you were ever 7 asked for information regarding the 8 contemplated asbestos regulations, the 9 subject matter of Exhibit 39? 10 A. We may have been. I can't say 11 for sure. 12 Q. You don't know one way or the 13 other ? 14 A. I don't know honestly. 15 Q. Let us mark as Exhibit 40 a 16 document bearing Bates stamp number 17 132 /4 07 96 5 2 . 18 (Memo dated 7/31/81 is 19 marked as Exhibit Bickerstaff 40 for 20 Identification.) 21 Q, Have you ever seen this 22 document, aside from preparation for the 23 depo sition? 24 A. Again, I may have. This is 25 again eleven years ago. Bickerstaff direct 325 1 Q. Is there anything on the face 2 of the document indicating that it went 3 to your department at headquarters? 4 A . No . 5 Q. In the second paragraph there 6 is a reference to Westinghouse policy 7 requiring the disposal of PCB-filled 8 capacitors that are no longer in use. 9 Do you know when that policy was first 1 0 promulgated? 11 A. No, I don't. 1 2 Q. Do you know if that was 1 3 something within the purview of the 1 4 environmental affairs group? 15 A. In looking at the date here, 16 July of '81, our "Environmental Affairs 17 Department" was formed in I think April 1 8 of that year. So if it was a directive 19 in the policy saying -- I don't know. I 20 don't know what it was for. 2 1 Q. Now, the last paragraph 22 concerns a form to be filled out by all 2 3 plants which have PCB capacitors in 24 storage for disposal. Was your 25 department provided with the completed Bickerstaff direct 326 1 forms for potential employee exposure to 2 PCBs ? 3 A. No. . 4 Q. Do you recall if your 5 department was asked about any information it had regarding PCBs at 7 various plants? 8 A. Not that I remember, no. 9 Q. The addressees are business 10 unit and division general managers, 11 plant managers, work engineers, 12 TSCA/RCRA representatives. Do you see 13 that? 14 A. Yes. 15 Q. Does that include the 16 Insurance Department or risk management 17 unit of Westinghouse? 18 A. I don't know. 19 (There is a discussion off the record.) 20 MR. COHEN: Let us mark as 2 1 Exhibit 41 a two-page document bearing 22 Bates stamp number 144/0045951 through 23 0045952. 24 (Corporate Procedure Document 25 is marked as Exhibit Bickerstaff 41 for Bic kersta f f direct 327 1 Identification.) 2 Q. Can yon identify that 3 document, sir? . 4 A. Yes, it's a corporate 5 procedure on reporting substantial risk 6 to health or the environment, and the 7 date is August, 1982. 8 Q. Do you recall when that or a 9 similar corporate procedure regarding 1 0 risk to health or the environment or 11 personnel was first promulgated within 12 Westinghouse? 13 A. I think this was the initial 14 procedure on the subject. 15 Q. Who created that procedure or 16 what department or division? 17 A. This was created in the 18 Environmental Affairs Department. 19 Q. And that would be something 20 within the purview of Mr. Kerns' 21 knowledge? 22 A*- Yes, Mr. Kerns' knowledge and 23 the rest of the department, yes. 24 Q. And not something that you had 25 anything to do with? Bic kerstaf f direct 328 1 A. I believe we also assisted in 2 helping put this together. 3 Q. Could you tell me your 4 recollections regarding what your 5 department did to help put it together? 6 A. I can't say for sure. I know 7 we were copied a draft copy just for our 8 comments and whatever, but I think there 9 were three or four people from the 1 0 Environmental Affairs Department who, 11 again, put this together, because it was 1 2 the first time. . 1 3 Q. When you say three or four 14 people from the Environmental Affairs 1 5 Department, did that include industrial 1 6 hygie ne ? 17 A. I think we were one of the 18 members , yes . 19 Q. What considerations led to 20 this policy being created? 2 1 A. It's a requirement in the TSCA 22 that this information has to be made 23 available to the Westinghouse 24 employees. So that's the reason for 25 putting the corporate procedure Bickerstaff direct 1 together, to comply. 329 2 Q. Anything else? 3 A. Just as a goodbusiness 4 practice too to have this procedure in 5 place. 6 Q. Was there any discussion about 7 having such a procedure, that such a 8 procedure should have been created and 9 implemented before required by law? 10 A. I don't remember that part. I 11 don't know. 12 q. Justsothe record is clear, 13 what does your reference to TSCA mean? 14 A. That's the Toxic Substances 15 Control Act. ', 16 (There is a discussion off the record.) 17 (There is a brief recess.) 18 MR. COHEN: I have no further 19 questions for this witness with regard 20 to the particular deposition notice for 21 which he has been produced subject to my 22 previous reservation of all rights to ' 23 conduct a full substantive deposition. 24 I do recognize that with regard to 25 paragraph six of the deposition notice, Bickerstaff - direct 330 1 Westinghouse has designated another 2 witness, Mr. Michael Bryant. 3 On the other hand, however, it 4 is also apparent that this witness, Mr. 5 Bickerstaff, is not fully knowledgeable 6 with regard to all subject matters other 7 than paragraph six encompassed in the 8 deposition notice, and for the purposes 9 of the motion practice concerning the 10 scope of discovery and the deposition on 1 1 the subject matters annunciated by 1 2 Special Master McDonough, we reserve our 13 rights to complete the scope of the area 14 of inquiry directed by the special 15 master. 16 MR. BRENDEL: If counsel has 17 specific areas that he wants to pursue 18 further, as we've discussed, we have had 19 discussions regarding making an 20 additional person available, and I'll 2 1 just await some discussions with you on 22 that. Maybe after today we can talk 2 3 about it and the necessity for that and 24 exchange some dates. 25 MR. COHEN: Right. Certainly Bickerstaff direct 331 1 if the decision made is that another 2 deposition is not necessary for that 3 purpose of the pending motion/ then we 4 will not take it simply to take one. We 5 will depose Mr. Kerns or whatever the 6 appropriate person may be in the regular 7 course of discovery. 8 MR. O'NEIL: I have no 9 questions. 1 0 MR. MASON: I have no 11 questions . 12 MS. HERMIDA: I have no 1 3 questions . 14 MR. BRENDEL: We will reserve 15 signature and read the transcript. 16 MR. COHEN: I want to thank 17 you very much for your time, sir. 18 (The deposition is adjourned.) 19 ***** 20 21 22 23 24 25 332 1 2 I have read the foregoing 3 transcript and it is true 4 and correct to the best of 5 my knowledge and belief. 6 7 8 9 C. WAYNE BICKERSTAFF 10 11 12 13 14 15 Sworn and subscribed to 16 before me this day 17 o f 18 19 20 2 1 Notary Public of the 22 State of 23 24 25 333 1 CERTIFICATE OF OFFICER 2 3 I , ANN p. CONLON, a Notary Public 4 and Certified Shorthand Reporter of the 5 State of New Jersey, do hereby certify 6 that prior to the commencement of the. 7 examination the witness was duly sworn. 8 I DO FURTHER CERTIFY that the 9 foregoing is a true and accurate 1 0 transcript of the testimony as taken 1 1 stenographically by and before me at the 12 time, place and on the date hereinbefore 1 3 set forth. 14 I DO FURTHER CERTIFY that I am 15 neither a relative nor employee, nor 16 attorney or counsel to any of the 17 parties involved; that I am neither 18 related to nor employed by such attorney 19 or counsel, and that I am not 20 financially interested in the outcome of 2 1 the action. 22 2 3 NOTARY PUBLIC OF THE STATE OF NEW JERSEY 24 My Commission Expires: June 28, 1994. 25 C.S.R. License No. 999 334 1 -LITIGATION SUPPORT INDEX 2 3 4 DIRECTION TO WITNESS NOT TO ANSWER 5 6 Page-Line 7 283-19 8 9 10 11 12 REQUEST FOR PRODUCTION OF DOCUMENTS 13 14 Page-Line 15 None 16 17 18 19 20 MOTIONS TO STRIKE 21 22 Page-Line 23 None 24 25 ALL I.S.D. LOCATIONS , CONFIDENTIAL ; IU---------------------- 1 Fran :Greentree WIN . :228-4679 Date :November 6. 1977 Subject; SUBSTITUTION FOB ASBESTOS The federal OSHA standard for asbestos now imposes stringent requirements for limiting airborne asbestos fibers. If an employer chooses to use asbestos or asbestos-containing products, elaborate controls must be maintained to avoid employe exposure, not to mention other requirements such as separate locker room facilities, providing change of clothing, monitoring- of the working environment, periodic medical examinations, retention of records for exposed employes, etc. we cannot expect to economically meet these legal requirements regardless of how limited our use of asbestos may be. In addition, we can expect a progressive reduction in the number of asbestos vendors and an accompanying increase in costs. Therefore, it is necessary to resort to a substitute program. The Standardization Committee has identified replacements f or major asbestos-containing materials presently used and suitable substitutes are listed in Standardization Letter #77-9. While it is our position to not handle asbestos, thereby eliminating the need to comply with the OSRA standard, there may be occasions where we will be confronted with the removal or demolition of asbestos from existing equipment such as motors, magnets or insulated piping. Under these circumstances, we are advised via the attached Westinghouse Safe Practice Data Sheet to provide respiratory equipment, the type of which is dictated by the amount of airborne concentration of asbestos fibers. Obviously we cannot monitor each job and in consideration of infrequent and short duration exposures, practical steps should be taken such as stripping asbestos near a ventilated booth if possible, avoid excessive air turbulence such as fans in the area and have . employes wear air purifying type respirators with the proper cartridge filter. LGR:pad Attachment L. G. Rudolph, Supervisor Safety ( Accident Prevention 132/4084649 t * *** ... -. 6*-^ K07XSCE0 TtCHNOtOCf UUOHMOXXSt um suts UKB 177 *' | . ~ | 1 1 >"'84i laonirs 'I -*t --'I gd W!5 MorBga*X** (n%wmh--a| *J~XSfni g* rt r <T > <M-rI o 2 CD CO CO --i UU EXHIBIT 7it*e*T*ce \ SXrCTT *T WtSTlMBHeOgf 0r NBMCT la utity, Otf FKXZU'1 u ... Eflaoorlaf ... Uantln. u4 ... tathuian Ou FWrXT la m>iu*4 ia ... Th* radvties of bous rsffariaf. ... As iacraaao ia production, aatf ... tb* of livoi uf aqaipaost. 1 Bart V. BahrlafOf, C.B.f, (after Sfutaat H-- ^ HXn 3 * HX ox^o 3nn *#cxn 3i 5 Vi n ia > *4 =5 3* 4 Oi 2 CD U2 CD --I 844 6017284 IF THE F IL M IMACiE IS LESS CLEAR TIIA K T H IS NOTICE, IT IS DUE TO THE O UALITY o r THE O R IG IN A L IXJCUMEMT. Advanced Technology Labor* tone# January 4, 197* * annuil sajttt uku - 1*77 Dr. G. Stroll, Manager Science ud Technology eci ATI - Safety Policy Coemittme ATI. - Management Safety Cwittee _ J. . Snau, General Kutftr, ASO - MS 234 * E. S. Crekan, Manager, Operation* - MS 124 . S. C. Sisbop. Manager, Manufacturing Operations - MS U4 J. 6. tor?by. Manager, labor Relatione - MS 115* E. w. wood. Supervisor, Safety Department - MS 61tt w, Ziefel, Administrator, Accident Prevention, Pittsburgh V. SioAerstaff, Administrator, Industrial Syrians, Pittsburgh Attached Is a eepy of the 1977 Annual Report of Safety Activities, Accident Injury Statistics and headquarters Plant Safaty Frogran Evaluation for 1977. Only cue lost workday injury occurred during the year (vieh 2 days Inst), and only one Bon*teat Say cat a vas re> potted. This compares with no tost Workdays and thrae tom* lost workday caaas in 1974, ; The last tnat^erkday case (or Disabling Injury) occurred on May 13, 1977. rtes May 13, 1937 thru Dec cuber 31, 1977, 549,701 hours (or 233 workdays) vsra recorded without a Reportable tost Workday caae. Such la Indeed a fine accomplish* mat. . The Safety ProScan and Performance Evaluation rating proved to be tho best~ever. A rating of 43.05 was obtained. This compares with 74,50 for 1974. Tho 197t Management Safety Committem, all Supervision, and Management certainly have their work cvt*out for them if they are to equal or bettor the 1977 performance evaluation. CD CQ --J un 844 (cO\138? J. <afaty facord ittbllahad in tha paat yaar can ba quailed or Improved In 11Ti only_i(_tht.flna cooperation o/ KintfiMiit continue* and a complete Safety Avaraneea continues to bo practiced by all auparviiorf and employee. ' ' *av A Safety Day .. m/i ...;..;.....-........./ ... Itrt v# lhriBfrf C.S.9* Zaduitriil >^7ia a4 S*f*ty JBpctriMf w 8*w/&onzso **l 2 **. ^WH n I in O3 0 w mm ~O nm rSs z >r *- h 5 R "aw n - SS 3n :* 3 Hn r__t rJ Oc a >^ rs H< i O 2 <0 C3 CO --I cn 4. . WTSTINGHOUSE ELECTRIC CCRRCRATIO* AUVXWCEO TECHNOLOGY LABORATORIES 1977 ANNUAL REPORT Of SAFETY ACTIVITIES \ The Mjor sefety activities engaged in during 1977 ara . reported is accordance with the Weatiaghouse Six-Point Safety t Prograse. POITf I - ORGANIZATION AMO APFCHI5TRATIO* Safety Policy Coralttso The Safety Policy Coralttee wee chaired toy 0. Strull, A.T.L. 1 Manager. This coralt tee established, implemented the Weatlnghouae j41 Six-Point Safety Prograa and approved the Safety Objectives for 1977, reviewed progress of the Management Safety Ceraittee. special Task force Committees, and provided guidance to these ceralttees. The members of thii ceraittee were appointed toy the A.T.L. Manager. Sopereisosy engineer L. P. Copper one the Che 1roan. Thin coraltbee vas held responsible to implement the plant safety program and provide support to all plant safety activities, objectless and procedures. This comlttee net Monthly. $ o 2 <o Have A Safety Pay___Every Oar . Members of the Safety Policy Coralttee and Kanagarant Safety Ceraittee attended the 1977 safety prograa kick-off nesting at friendship. Hr. I. S. Saith, Executive Vico President, Defense, aade the address. Safety Supervision- CD CO The Safety Supervisor provided Safety Service for the Advanced Technology Lahorutorica (A.T.L.), aa vail a# the Oceanic Division at Annapolis, Maryland, The Safety Supervisor vas secretary to the Safety Policy and Management Safety Ccraittoea. --i --I The following activities were participated in during the -- of the years .. Lectured and instructed at several educational institutes, i.e., University of Maryland (Collage Park, Maryland)! DePaul University (Chicago, Zllineislt and Catonavillo Coraunity College (Catonavillo, Maryland). Toplea ia* s eludedi Machinery and Machine Ouerdlngt Personal Protective Equipment? Industrial ttyglenet Elactrical Hsssrdsi portable | I I ' i* * I* 5. ' Pewersd Teels and ether*. Developed end leetursd thrss-credit tdvenced safety course. 0ST-1J4,' 'keeopnltion *nd Centre! of physical end Sealth Batards,* at Catonsvilla Coranunity college. .. Safety Council of Maryland - node tali-slide presentation*. Electrical Safety At *, at 2 Electrical Safety --J--nr Tor*on, Maryland. .. w Gettysburg - vlaiated 3 day* at such facility. Conducted e Meek OSIA Inspection end submitted safety raceaoendatiene. .. Aaerleu Society of Safety Engineers, Chs*apeake chapter Hrxber ef Seminar Coraittse* Moderator for l*f* aeatinart also, lmacheca speakar, topic, 'Functioning Thru Safety cempLitteee at w*. . .. SSth Xatiooal Safety CODfrtaa - Chicago, I111anin. .. list Annual Saltinere Safety ieakinar " Attended sack ef the 21 yeara i speaker at many of these annual s^tnaro. Scheduled to speak at the 22nd Annual Seminsr in 17*. .. 10th Annual Maryland Hunter Safety Snatrnctor Workshop -- haminytoa Fane, cbettertMn, Maryland - Presanted yiepia. 'Archery and Sow Euatias Safaty." .. Aaerican Society of Safety Coglasers As t Certified Safety frofessional, attended executive couadttee and ftnsral newbatship eastings. As delegate far the Chesa peake Chapter, attended the Satienel A.S.S.t. Meeti&f and Frefsssional Oevslepment Conference in Kansas City. - .. *th Annual Satienel Hunting and PlaMny pay A--laytes rants, Chestsrtovn, Maryland Archery and beehuntlnf sefaty, exhibition. . .. Maryland Hunter Safety - conducted T hour State Couweo. 34S pmnena (many of shea cure Westinghouse eeployee and their families) completed course and so certified an - Safe Banters. Bate trained mere than 2,000 atadstn 1st Himtar Safety, -- , .. Satic&al Safety Council - Instructor for several 'Key Nan Development* and 'Fundamentals ef Industrial Safety" j Courses conducted throughout the State of Maryland. I *4 am s -n 5a n an Cx *> r 3 X>On X 5 H9 rmv> vt O 2 (D CD CO --I CQ 8 4 4 * 6017288 .. national Rifla Ataociation - a* a cacti find r.ft.A. and State of Maryland firaaraa and Huntar Safety in*truetor, praaantad n\saaroua talka, alida praaantetiona and danoaatretioas a tlrearo* in tho So*a and Ruittt Safaty to Civie Organirationa, Llona club, optinaaet, B.T.A., ftlflo and liittl Clsba, aw. .. Boy' Scouta of Aaariea - conducted Safety Writ Badge for Scouta. tone of 2, aaqployoa. ,, Catoaetilla Cewmicy Collage eafety eeudeat* - Arranged for plant tour of Bata Building. B. C. tlefaop aado a alida praaaaaatloa of what it developed and oaaufactsred at tha Dafanao and Space Cantor. .. Maryland Teatt Safaty Coaftrawt, Uu4m* Sigh School. Baltiaora County, Maryland - lectured oo Baao finer* Safety. ffatv Obaaprar >wma Zlgbtaee nawly appointed Safaty Cbaarrtra (ambers of tho aoa-eupervleory work forta) racaivad Safaty Training tan tho Safaty Supervisor and regular aeathly nestings vara hold. Tho outgoing group of Safaty Observers attandad a recognition banquet (along with obtarrars froo Eaat 4 vest Building) and wart praaaatad with a token gift in appraeiation and recog&itiea of tholr fina work and cooperation. federal (O.S.B.A.T, Stato (M.O.S.g-h.) and local Uwa and Regulation* Continued effort oada to kaap ahraait of now and reviaed lev* and ragulatioaa. Hanagenent and auparvlaion appriaad af applicable change a. Cepiaa of the rawiaad O.S.I.A. S tenderda, distributed to all raaponalhlo ooohora of nanegaoent and opervialo*. O.S.B.A. Standard* worn atraaaod in Aeeidaat freveatlea for Management Train ing rrograa conducted hy tho Safaty Supervleor. Safatw Staadaxda and Reference Material* A oooplato and up-to-date library la maintained (and ao utilised) of Safaty Standard* and Bafaraaco Materlala. mmtf X IF THE FILM IMAGE IS LESS CLEAR THAN T H IS MOTIC E . I T IS DUE TO THE O tlA L IT T IF THE O R IG IN A L DOCUMENT. stfetv proerw* >ppf*iti of the WM^cMAt Safety Cfiimlttaa participated la the Sti^urttn HMt S!cy rtefru tvlwUA for 1*77. Sack ereluatiea pointed out tea* areas of weakness la the Safety rn- _ . These *1 erase win bo ineorponted as objectless for ' 197t. roUowiay are th# evaluation result* for 1971 thru 1*77. A* reflected below, the 1*77 ratlay proves to b* tie beat to data. The Maasyeaeat Safety Ceoalttee will bare tbir work cut ** far thee la order to la^ror* os tbla ratio? is 1*7*. Advanced Technology labor*tori*e 122 *9.50 1221 7S.90 1221 7*.SO 1221 S0.S9 1221 S3.** 1221 7*. SO 122 01.0* Attached 1* copy of the cteplote Vestlagbou** Safety froyna aad ferforuoae* Svulaaeiea for 1977. gar.B--.wwv&nask Sew bculraent tad flaat Uvoet J Sew eyuipaest tad plant layout*, is eoet exeat, were lyyirosed by the Safety Snperrisor. Seadyuartar* Caution aad Mania? Tay^ct Systew 1* is Halted nee. Zaproreaeot it desired is botb of these area*. The faei 11atlet were Inspected several tlsee by tbs AsryUad Oeparaeet of let1th, radiation civlsio* for x-M4i*tios a* well ta leotop*. Only alaor discrepancies were noted aad ee eorreetod. Safety asd fceuaekeeplsy inspection* of the satire facility veto conducted each aoots by oeehert of the Has*;exeat safety Cnositt**. 19S ifeet were reported for correctly* actios - all but a fw have baas oo corrected. The few resol winy are is proyree*. TiQfWsiit wa* sade for expedition* eorrectiee actios os reposted itoo*. tbs boiler* were i&epeered by the Maryland boiler Inspector*. * UfncUMi MM* observed. _ ns ftcilitiae wax* inspected by rectory Mutual Representatives and the Asa* Arundel County fir* Oepartseat, Sow* alaor violation* wee* reported and oo corrected. . r S4 6017290 o S <o f-- -- C3 03 CO CO I IF THE FILM IHACE IS LESS CLEAR THAR T H IS NO TICE. I T IS OOF. TO THE O U A LITY OF THE O R IG IN A L OOCUMEHT. I. A ttoeh-NOSH type Inspection was conducted by R. Weber. Safety Supervisor >t Hunt valley, eighteen lte*a vets reported end so corrected. A detsiled O.s.H.A. type compliance inspec tion was else conducted by the A.t.L. Safety Supervisor. Seceeary corrective actions were taken. - Safety beeciatendatlons '* The Safety Observers submitted atauroas raceewenda ticas to their supervisors for the correction cf unsefe conditions and practices. All such recoaoendations were complied with or- acted upon. Tbe necessary personal protective equipment tflano Safety Spectacles. Prescription Safety rye Wear, race Shields, various types of gloves, sleeves, spats, sprons, ear miffs, and miscel laneous) was purchased for issuance to eapleyes. Safety shoo service was Bade available to eapleyes for purchase. A concerted effort was sad# by Ksnsgessst and supervision to enforce the use of required personal protective equipment. . ' Oleaster Control The Oleaster control Comittee was setive. few tea* cap tains were assigned to each ares. An emergency telephone tyatss is in uss* Decals with sergsney telephone mibec are on all phones. Sowever, a Joint seating with the other Defense a Space ` Center Olssttsr Control neetisge wss not held. A fir* drill was not held. ' i: 00 toonaqi EQiJff m - tvDurruiAt. wrcitw^ . Radiation Control . flla ktdfti ut la ui* vtiart potaatlal radiation aapeauxaa txiat. To dataet aad pravaat oploy*a fro* ebtaiaiaf high rad iation cxposor*!, paxiodle iatus vara ndi aad urlaalyais takaa. xadioactlw* Materials, handling, atari?* aad record fc**piay procedural wax* lap*ct*d by tb* Maryland laaltb D*paxt**at. Radiation eiaialoa. Th* aatcrlala, handling aad atari?* ef each *r* found to b* la ordar. to*nt( *-- diicxnpaaeiei war* raportad la tb* corractita atuun aad record keeping procedural. Such procedural war# pro^tly corrected, aad a eontiaulag aadIt la? lyiua mi eetabllibed. lb* radiation *guipo*at la raglatared with tb* (tato of Maryland (which la aa a?-ra*a*at itato with tb* raelsax Regulatory Ceaaliiiaa), XU aov tabiutad or voatod *qaipo*at u checked, Appropriate racnmandatloaa war* ruboittad. So** alaor an wll aa aajor ehaag** vara eada to laprov* ic*a of tb* exhausted cbwlcal booths aad hood*. Xavroweaaat is at 111 a**d*d la tb* fragwaey ef inspection# aad aaiatalaibg of racerda. arranges*at* ax* la process fox industrial Bygieo* mad work* engineering ts check all waatllatioa ryatm aad ta a* atabliah a precedar*. Spot check awvaya wara Bad* to Aatarmlao whether or net aaploya* war* exposed to axeaaalvo nola*, xa a result of tboao surveys, aad aidsting survey rasults, ao operation* w*xo found to It sola* lovoln 1a kii of tb* 0.1,11. or x.0.1.1. ataadaxdo, tifa_metic* .Pita Doata ti.rt.ll XU ttta Ufa metier Bata fbMt leeks wax* maintained ep-t* data. Profraa iaatltutod to encourage greater aa of aaa* by teporrlaor* aad raforaaead la procata specification*. semt orldaaoa of iac*M4d wo of srod'i vu aotod. Qxaator utilisation la atill aoodod. Aa appllcabla Safety Isfetattln Uur was prepared aad distributed to all aobari of aaaayaoaat aad eartala otb*r a^leyoa. kjt 6017292 4 4 C H2 ^- Hrn W * Hsw oX "o 3*fnal *cxn >r * R* 2 g rwV) tn hn sm rj o cy H *r4 s> < $ Og <6 CD CQ CQ rU IF THE FILM IMAGE IS LESS CLEAR THAN THIS MOTICE. IT IS DUE TO THE QUALITT OF THE ORIGINAL DOCUMENT. W 0019 i n LI o LI n3 LI _l 1 t*s Sfl M HM>* n | 0 4* 1? :j* OM C omn Co cjA4_O V 7D HO 15 51 9 CCJ us 4 OV OC. Ou H~4 o a Am m o 4J 4 h o p. JUS3 5 5^8 .*2 MV tr S 6 O Um4 M 3 4! O f O * (M*l U a 4* 10 3Co,hho*S3 O OH*4 5>| iH*- MU- o- OOd Ca o C ft *J *J S m 61 45EI3 a s 9 a ct $ 9x G O to r* u 9 AH I fl 1 j i u rnfonatlen to iwtviicn ' Hwbara of tba |{ty enaltUM and fipititleul Stftviieii **F* lofoiaad of C.S.I.X. ud X.O.i.i. Md otMr U^tunt atety iafoaatiea no w Baadquartars Xaforsstion Ucuri, O.S.S.A. Dlttctim, Sttitul li(cy MWi X.t.J.t., scarpto tram tk wiu of Satioaal tifKlxt, `Occupational biudi* wyulMit ud othar iafoaotion aourcaa. Ruck of sock lafwoatioa was salt* bio for auparriAor-urploya vorkplac* oaatlofa. - *o tiro drill u oaotfuctod. lma)Miti viU bo uda to Uia ancb a drill la 197*, cirnm Masbaza of tbe float rretoctiee finrd rote* received firm aid traialap tram float frotoetloa rirtt Alda Xaatrectere* Safety cbaorttr Tr*<"*Tf finite** bovIf appelated aoe-etparriaoty aupleyee vara yiaeo few boora trsiaiof la tbe saodquaxtere Safety Cheat-rare Tralalof Coarao. la additlce, oath aeetk tbo Safety Ohaarrer* oot vitk tbe Safety (uperrlsec tec 1 hour tec dditloaal traiaiey ud to die- n*a probleue. |afT E--MMT ; t A fur saporrlaors sad profaaaloaal poraotxaal attaadad the Hot Annual laltlaere Safety faoimr oa tboir ova tlao. Tbo Safety Suparriacr vts one of tbe ifaikm. riVTH******* Tralnlao ' Tarleta abort trvlaiof aaaaioaa vwre pretested to appropriate |ts<*a. Sack aoaaloao lacladodi personal hatacUta tfilpuat Heretical Aatety Pico Safety lifbvty tafaty ' teacm inatUaf loatiaf Safety Office Safety fCICt T - WOTTVAflW aodltay and ftatlaf fIssuable Uqaid Shop Safety Beoyceaaed eaa ludUnf rixa Acw Safety is tbo Kuo I 4* 6017294 $ o 2 CO C3 CO IF THE FILM IMAGE IS LESS CLEAR THAN T H IS H0T1CE, IT IS OWE TO THE Q UALITY OF THE OR1GIRAL DOCUMENT. 11 COMTIKUIKG EDUCAT208 Internal Training This year Environaental Affairs will effsr two educational progress to train division psrsonnsl is the Industrial Bygiene and Safety areas. * Fuadsataials On March 15-IS, 1888, Corporals Industrial Bygiene joined forces with Corporate Safety to offer a eoabined introductory course on industrial hygiene and safety. The course provided introductory aaterial to site industrial hygiene and safety representatives who had not yet received corporate sponsored training in these areas. This will be the only fuadaaentals course offered this year by either group. * 1.3. 1 Saittp On Hay 18, 17, and 18, we will present the Corporate Workshop end Industrial Bygiene and Safety Spring Vorkshop. This workshop Train tie Trsiotr: is geared toward the senior Industrial Bygiene and Safety Satrgtoe/ Stsposs* representative with tore than two years* experience. Following the Spring Workshop, on Bay 10 and 30, a 'Train the Trainer* session os Esergeecy lesponse will be held. This course is designed for individuals responsible for conpliaaee with the new OSEA Eaergeney lesponse standard nandated by the Superfund Aneadnent and leautborisation Act (SAlA). The eourse will provide site representatives with the skills and background necessary to assure that their eaergeney rcsposse/SAZMAT teaas aeet the requireaents of this new regulation. Environaental Affairs continually strives to provide you with an education prograa that offers current infornation to assist you in perforaing your duties. If you have any suggestions please contact Debbie lockovich, Manager, Training ft Coanunication, 8-373-5081. External Training * Ytatilatiea * Annual industrinl ventilation conferences will be held at three major universities. These conferences are designed for persons responsible for industrial hygiene prograas and system aainteeaace programs. These courses can be presented at three levels. The first level is intended for persons who have to design ventilation systeas Infrequently sad for persons with so prior experience or education ia ventilation systea design. The seeond and third levels are intended for -* persons who are aore experienced la ventilation systea design aad have responsibility in a broader range of industrial SOURCE 144 0880532 1 processes with non-standard air design requiresenta such a* elevated air teuperatures. Courses at all levels art excellent. Vestinghous* Corporate Industrial Hygiene parsonaal and aanp site facilities personnel bar* attended these conferences and highly recouend participation. If you have any responsibility for designing or selecting ventilation systeas, hoods, fans, etc., or responsibility for aeasuring the effectiveness of ventilation control systeas, this is the type- of course for you. The three location* and dates are: North Carolina State University taleigh, North Carolina April 18-22, 1988 University of Alabaas Birainghaa, Alabaaa October 10-U, 1988 Michigan State University East Lansing, Michigan February, 1989 For acre inferaation eall Corporate Industrial Hygiene, VIN 238-1364. INADEQUATE MSDSs Corporate Industrial Hygiene frequently is asked (8o* do I deteraine the adequacy of a supplier's MSDS?' then Meetinghouse receives an MSDS frea a cbeaical aanufaeturer, ee accept it on good faith, that is, ee expect our suppliers to provide a doeuaent that accurately refleets data on any hasards or potential hasards that their cheaieal product say pose under noraal conditions of use. The cheaieal user still aust revise the data sheet for obvious errors or blank sections and if found, contact the supplier for clarification or a corrected MSDS. Close exaaiaatioa of MSDSs is necessary for deteraining adequacy. A guide to follow when screening your MSDSs for adequacy is the date of preparation. Data sheets prepared prior to (foveaber 2$, 1983, are aoraally inadequate because rsquireaents of the lasard Coaauaicatioa Standard vers not published until this date. Data sheets using the OSSA Fora 20 should be questioned also. This fora was phased out May 38, IBM, because it was not identical to the Kasard Coaauaicatioa Standard MSDS rsquireaents. Therefore, if you have MSDSs on the old OSSA Fora 20 or MSDSs dated prior to Novesber 28, IBIS, request new ones froa your supplier. SOURCE 144 088O533 -* Another way to deteraine USDS adequacy is to look for ineoneieteneiee on ths data shoot. For example, as USDS that lists 'sent* in tho hasardous ingredients taction ohilo containing 'nay cause lung damage* in tho health hasard data section is inconsistent and a nee one should be requested. Also, generic ingredients sueh as 'pigaent* should b specified under ehesieal identity unless the ingredients are protected by the trade secret exclusion. Other examples of gtneric terss that sust be specified under ehesieal identity are*, catalyst, aroaatic hydrocarbons, binders, and fillers. Recent data released by OSEA for Basard Coaaunication violations revealed over 2300 industry citations for inadequate USDSs. Exaaples of these citations are as follows: 1. Failure to include OSSA permissible exposure liaits, ACCIS Threshold Limit Values (TLYe*), and any other exposure lisit used or reeoaacndsd by the preparer of the USDS. 2. Failure to include the health hasards of ths hatardous ehesieal, ineluding signs and syaptoas of exposure and any nodical conditions *hich are generally recognised as being aggravated by exposure. 3. Failure to include the date of preparation or the last revision of tho USDS. 4. Failure to include the ehesical'o primary route of entry into the body on the USDS. 5. Failure to include the ehesieal identity and hasard warning as it appears on the package label. 6. Failure to complete the USDS. Aa USDS may & contain any blank sections. tesesber, it is the responsibility of tho sits rep to reed and evaluate tho USDS, then prescribe eaployes protection eeasures as are appropriate. -t in -J o 9 00 CD uu SOURCE 144 0980534 tESPIJUTQt TDfl LIMITATIONS la many. situations, tcployets art rsquired to wear respirator! for extended period! of tiae during a work shift. These situations should be reviewed periodical!/ to assure that such usa(e of respirators is appropriate and reasonable. Frea a regulatory standpoint, there are curreatl/ no general requirements that liait the amount of tine that a respirator sa/ be worn during a work shift. The onl/ specific reference to respirator use tiae lisitatisns that *e are aeare of is contained in the QSHA Lead Standard [29 C7H 1910.1025 (f)(l)(i)]. Soeever, it should be noted that this requireaent limiting respirator usage to a aaxisua of 4.4 hours per da/ eaa included in the Lead Standard because the use of respirators was determined b/ OSHA to be an unacceptable aethod of cospliance with this Standard. The use of respirators eaa intentionally liaited in this case as ons aeans to fores ths installation of snginsering controls. Proa our retie*, this requireaent eaa not baaed on acdical cr industrial hygiene practice, but >as an administrates decision by OSSA. Assuming that the iaditidual has been found to he physically able to star a respirator, as determined through an adequate sedieal examination, the amount of time that an indiridual should *ear a respirator for a continuous period depends priaarily upon the follo*ing factors: 1. Perception of comfort while tearing the respirator. This would include physical cosfort, such as the absence of skin irritation, as veil as the actual fit of the respirator on the face. 2. fork activity aad strata. Heavy work that is physically draining aay affect an employee's capability of wearing certain types of respirator*. Temperature and humidity conditions present la ths work aria may affect ths physical or psychological stress level associated with wearing a respirator as **11 as the effectiveness of esrtaia respirator filters and cartridges. 3. Ths type of respirator sera aad ths airboras concentration of ths contaminant prsasat in the work arse. For example, the breakthrough time for an organic vapor cartridge respirator is dependent upon the airborne concentration of a specific contaminant and the length of time it in used. A low molecular eeight organic vapor aay have a very low breakthrough tine mt high 3 H -n Ion ;* a ** W gw,, 3-id" il HO c* o 2 09 CD UJ SOURCE 144 0030535 ' airborne eoncantratioas, thereby limiting the tiaa of eontinuous usage before replacement of tba cartridge is oaadad. Vitb consideration to tba factors influencing raspirator utaga, tha establishaent of a tiaa limitation oa coatiauoua usage must ba made oa a job-specific basis. Proa experience, a raasoaabla aad practical approach is to liait raspirator usage to oo aors thaa two hours at any oaa tiaa, with ao fixed tiaa liaitatios for total usa during a work shift, fewever, employees should ba abla to taka a pariodie break frot raspirator usage ia a cltaa araa at any tiaa as lone as is reasonably required. Is additioa to tha two-hour liaitatios, tha following provisions should apply, as a minimum; 1. Employees should ba paraittad, as thair specific job allows, a raasoaabla opportunity to laava tha work araa to wash thair faeaa aad raspirator faea pieces as oacassary to prevent skia irritation that aay ba ralatad to raspirator usa. 2. -Employees oust ba paraittad to change tha filter alaaaats or cartridges of air-purifying respirators whaaevar they detect aa iacraasa ia breathing resistance or datact as odor or tasta that aay ba caused by breakthrough of tha raspirator by costaaiaaatt prasaat ia tha work araa. Tha fiaal araa that should ba given consideration is the salactioa of an appropriate type, style, aad sine of respirator to ba used ia a particular situation. Diligence is required ia determining tha appropriate type of raspirator for protection against a specific hasard. This selection, process should also consider ease of use or eoafort. It is possible to select a raspirator that is over-protective for a specific task aad not worn by employees because it is cumbersome aad uncomfortable, thereby defeating the respirator's purpose. Aa ezasple of this mould ba the selection of a full-face piece respirator for protection against a nuisance particulate. < CD UJ Oj SOURCE M4 0080536 LABORATORY SEIVICSS CROAT* Tha newest Clayton Environaeatal Consultant laboratory, loeatad at Pleasanton, California 7as recently accredited by the Aaeriean Industrial Hygiene Association for industrial hygiene analyses.^ Westinghouse sites wanting to use this West Coast laboratory will receive the saee corporate discount and services as fro* the other Clayton Laboratories. The following is the contact list for all five Clayton Environmental Consultant laboratories: 1352 Quarry Lane Pleasanton, CA 94565 (41S)-428-2600 ' 22345 Roethal Drive (sain offiet and laboratory) Novi, XI 48050 (313J-344-1770 Raritan Center 160 fieldcrest Avenue Edison, NJ 08837 (2015-225-6040 2141 Kingston Court, S.E. Suit* 116 Marietta, CA 30067 (4045-952-3064 400 Huron Church Road Windsor, Ontario NSC 2J9 (519}-255-6797 M (fl S O xo-t n "i 2o nn- cx >-X ro H* Iw 8"SS" art z HO =n rg* 8> -e C5 3* tlTB IIP! IOC CCOXPLISUCBNTS IX UXOIIUX ' A special note of recognition goes to John Spicber, the Industrial Hygiene Representative at the RIB Center, Pittsburgh, PA. John recently became a Certified Safety Professional. Special recognition goes to Robert L. Bergquist, the Industrial Hygiene Representative at Power Ceoerator Service Division (PCSD) in Lafayette, CA. Bob recently was named Safety Professional of tbs Tear by the San framciseo chapter of the Americas Society of Safety Engineers. I* irt saddened to report oo the reeent death of Hr. U|ir C. Btnai. Hr. Barnes atart ad Xlf earaar till) Testiaghouse la the 1930'a a* the eorporata Industrial Hygienist. la van a ploaaar ia the industry and served ao fraaIdaat of the national Aaarlcaa laduatrial Hygiene Aaaoeiatioa. Previous to Bis ratiraaaat froa Testiaghouse la 1971, he bad served ao Kanager of Corporate Xaduotrial Hygiene, Olraetor of ladiatioa frotaetloa at Bettis Laboratory, aad Corporata Olraetor of Kadlatloa frotaetloa aad Nuclear Licensing. SOURCE 144 08805Z? UU I put JBJ CD !,i siisi SOURCE 144 0080538 Il wsrrciO'Jsc ars: cwcsatio* ottnss * mcncxzz sYsrs-j csrra issi?cz * srrni'-j srniiKOT srnnow mirnsfi sinn cc-cgrrs jgexi 1UUHI 197* X. e. Bjhcp, is m 2* r. uis S3 024 *&Z. !srlJfwai*trl S3 '64 X3 134 *12. rTtS..uCh3*W1?4.9mH1o1i a) S3 TJ3 S3 1143 v*.. st. obrutltr a. k r<?i9M . & nldr K3 5QO S3 127 S3 71J S3 F1J J. K. C*nU, X.& S3 117* rI JL J. 12. SS3EA5*04 fwlltw sabn ast J. X. bMl C. K. HaidS* nt L HeCnny a. a kliiu 4 4 Trrrr l & rtn & U EsllAt* t. K. kit* L L Siwrali c. kith , L4 43. TVoaa4d*a j ` 0. SUaer* 3. 4 MiU( S3 1152 S3 L25 S3 114 S3 X10 S3 127 S3 504 S3 T-100 K3 213 S3 02 S3 159 K3 163 K3 024 S3 331 S3 767 J .cci M3.. 0. E. K7h7 - *3 1156 2n* - S3 114* 2 3. SollhM - S3 134 .E. B. Cr*3*a - "3 122 2 V. Ststtt n 1276 T. 2. nil*r - S3 1704 G. la imuB. S*2tT, fsam 2064 V. R. 21*7*1. 'JUfir, MutAtl fVcir.t a 3*2A/ Eelnn irt-H ^-^.*a* li3 Cutir 3965 4 enttac ifUlte ten. Cut feU41c<, EUhop pr14d. itt 3*2Ar Ge^tt** ni hld la th 7* a. Caifarv** tapat 7, 197* A lOiOO 4.1. Ch*4n*a 4. C. fta roUurfactflfiM * uu SOU^ee 6B72269 J i -a- fc ! 'CHrvT-T-.r.nT L'JLJi'n iit t The eccldcrt 9ulw u mtmd for bath dirtiiaoe (see etechad r^art j) iii uxann e?CTATToq Loot NorMey Cmas Mar* Ait* tort 3 i Seriate But tart itoridsy Ces hnt Aid Trtitrart Xejwl.ce 7T1 i.P.3. CFgjnca teat ferkdcy Cm as Mark 0ey teat Sarlaa* fiso-toat VTridey Cum Tim Aid treats** lejertee 0 0 0 0 Off-Jeb the off-job rtctlittce far fely 1971 (te reported to Katieel) war* rericusd* (9m attached report j). the Safe*.7 Btpertsest rtlll rejects of Xtdicel that rack wpJlat be brakes* dwn rrpattlAC leeetioo or --rirt*, 1. a., AS3 (text Slip.;, CCD (rrrt IJf ) end kLrtrlftratIte Sertitce* (Sicb Is. la k**plnf etth the repertlsf eyeta tad the etjeetlvee)* en cr rgscrj* rcriirrrs ty.T*gty Cutiw Hitef ftmeed tke need far til Kwiamt and Sipanrlilan te apltilte the bpoitirie far ell apt7 te we the prescribed lefety gyl^aetf<* uiMt ile( rwpimore, etc* the Safety tfMjn described I reportable etaec wJlch occurred 1a July 1a ettch epler wcipimtiy act Mulrc the neeeeeuy pertenel ymecclTe eqialpeesw To tide 1a ewdtdlti tile ewi<t ere 2 eliteAicrtc. See OfiUet Races tbs tapenibillty k^erm ts like Cartels Proper Protectl* is fern go tke Job by Bpleyset ed 9 - Seas eiceeted pwaltias by CiXA tar feilar* te ynrldt peretro! protectlre sodfocot* etc.- fra* Jely 20* 197* 0.1.11. fa*mt. ii 0V#C tty 6972270 ! ?>^ - il" ||Mf . i|,)liUl^.^P4,R 'S|i| h isi i i 11| s j isen .e n . i : : <e -3 - cnwgreia CMIiua Hihe? thi fict tilt U ty Foist Ctrii oro food tool* U wi to carTtf tbo laftty eni(< to tbo ol:r< in Iratruotlon shift, Hh To frtparo z*r -irti, >u axtritutod. nuk w mst com u* imiabio tin tbo Slfit/ QfAcot Tii CUlRta ri;:T.d tilt Ctiutif ^tnl Cocrdlaxtor, 1. !Ui) la /Atlni U{iUir gr<U:i antli* i:ri?t far amt CotnL /iro V.trtiai 9> riacr*,rf?ertlr-f ct tbo met fin drill, (totod tilt on 7*57I, nrt Alan U1 (lift 31df., Shrp Im, I<r J, Cols *i u ittrm for prints* I fin drill, Tbo fin triftio rtoperisd oil Us ritb tti follerirt pntlm 1. ffofelea of jftt'.-f o fin eirt tin illla 2. Tirn (3) till* filial to cjinti tad rill bo rtprind 3 Oto im vii fwit to nood u lir: ocd rill to to Isstollod 4* no CLiirttr Control tow ilotU look lot) oeea tnu oa hei tasetisj^ip* did ooesr ct loco oritt, Uo,, tbo no* o?layo cetor edt to tho sola pirribf lad 5* Sow poriorippo n7 ioe<a rill to Intallri to nplooo tho "flum toroid t7po, u im ^10700 iron roluetted to push trio t/po dirthc tbo drill. unrr^ixji 1 laralo rtper&ri tfat th* July tbeo 3c*tlS( Sofoty, y*<ctchlr4 display with * fill i: ml boot, mi txri.ri.iri by 2riri.*d snd ti iifTty npirditn J* Z> labroll rill to rnpKittli for Ui Aifirt tie* ri^ar*/ Sof it7, to to exhibit'd t/ itfri 1$ for tb* pr.vt lo^oet iaarii.itCy prior to tbo labor fit/ Holldiy. T^ssjsa f< toliisoori nrttfwt tbo aood fcrl^nriadctMM ofMlMfniiP A tk* arinocoa to ;.i>ri 1 Tgyfrc mx irifrii isif* tbo orinr***, particular:/ dsrihf nin ad man, 1. C. iiibr? ctotod that psrMp* lorvf'r np iro noodf nth oa tbo now c?layo riiiii1t to tbo ealn psr'rinc lot tonal ft, Htrio bd., tbo dorrlctt tide* odirno and otbor*. & bollstt* <u uslfiod to look Into tMa aottori i 30U&CI t*f<{ 6972271 i I "4- I gt - T-_-a_-^ tg.fr 4 aswii ;tV.! r.t tho firt t`j*. tlw tho offer!* of can of ttii emttoo llii o!4 ooidor ;at ittek* n ertirsl to to tltv>*4 tu'.ri toir* tni otUitod for : S mi b*n thi in.r of ioni ti.ru in ti# put. hw,t uteilcs iMuld to citn to tho evtsil* r.sntMCnji r.c4 1A or01 Utb (RitiAi liU.*4 told tni.`.tn, K? tci4 to .line, r.c. 4 Softtf tnd Sroitictoplr-i prrtlc ulrtod 1a tio outride oroo. locolod la tie rtor of tr.o Jft y~!' *" y. Torioui oU c=toir.tn o*4 l*jvi ro etud ir uptMiw ea to uj:ic to tU r=w YT. SULcp carttriod Uo rooporoUlo 4 TJO-Jtnl, cl Ui eorditlea Uo tow oorrortot. oyqt-Ti'fto I no Si.V.7 f-jifTiJor rrpertod tio*. jj Softtr Uo dtrrrto*--tut U the <ri 0.3./.k. or 5.I.O.S.X. r*T.trii orplcro ingirlful eperu* *A :rl:il rorordj--1if .*.. there ttrtid *t e -tie Tilljtlo t; .**;> r:;*. .:: -- (.; i ".<..- -.to l .;.; *,:t:v*.oiQ m .mi wjiltr u i::i<7 ;i :< tt rta'.u c;.'.ii>._Miioi tr ulifii, !:"ir cpl^u end tirlr S;rtir.r.i:u, '...iMr.tri it;:1*' eocilt-ee /* the r'-.m rer^lrltt rvitrj tc:- iir.i (aadireeari-tj oddod) s*se.T ftuTTP- yo^ta (:* lot* eUafo, Ci* to bdA* "Stsspeoe* f'r idddlerl's) Septcber 5. ITT* - Aidlterlda ut sart - i> 2nd san, - JiU iPf.p4eiioirf1it3M. ITiTt*ornV-edMiee:d-va 49)00 IX 1 ! i o. M.'r.'cr. ^44i jeurotorr KC44AW1 WAf Comlttoo OOQC't */</ 6972272 \ t *rr.Ttr>^ r.tTiJKrt :*t* *r,,i - r.ra JjittM Owlef-wt K-lilon || .,> yQ T*b\l 7<% f (Mtjrnl PKUM Vl*itat mn Lint >oio*iUy IrjctArr.tlt ten-! A.dt HilWlT JrtidutAi .Tti y OecvUiAM Mrir* Mr*.#*! E*. of *e<tst*t hmrjlff !*<*:v*r 1-111* F-a.*.*or > *-TUl Tfftl-fp*- f-- 21 OU wiaitr 1 1 U*M 3 Wold** | J2 2 11 * v^* |l --issTr w.> So e. JL 3fflM XT 13.17 rL r-o, of 3 2 3 3 *** J- f, SeitS V, feuftt f. Stf lb Iran - Cif trill* xtl/rwaue* Offie* HUiMr TtthAdu ftniiir * 2 <3 2 C2 <1 3 `s. _ 1 Crinfir 2 KMdirr 2 4 7kr Uftirar 1 1. 'T^*t4t+tmtrt ft* ,fj * . f 1 1 *** < i:s=iiT *f Arti4*-n iy ?rfi Strait Jy 23 | LCnr.t itant* 1 1 A-r- -i. Codt*n*d Jy 7 |a-T*U "'_t _bl_ew_Ur*a2cr *#4 *- j '-T*' Gonuct W3tA 7 j Ca 7*11 f*t I*T*. i I IWIMTI ^ * V f ------- '------rf rx U`.:t soi*. clsttly 1 2 2 Kind Tull lAi*w<M^*mtic3-Sosratri^nrii'aR r.~3Ysti Kdln *.**a Ut* I 4 4 13 >'<Air* 7il n&*m.*.rC^l*0i,.?ttis iun Fl**4 *tt l"^U`.eo 4 e;;st X-''>*41aiU* SvS9*py - Tart* *f aod* fi!. 9J >: ___ Ma STmalitr 1 12 v J4u* I<m4 rTtt. ___fc_ -- .Ttl._____ ' *. 2 4 g- Vn User* Uy IUA Cwii hr th J*t* Bm* QmA 7lam C"**i frtt ?*ntcl Vttult CCici f^r,, 6 ifji;. V* a* ***<*o)sI1>aI*d* 4 r.t. "* ?a.--. 1 Itbyd*ao* 13 Uf ( . 1 1 1 40V6CC fVV 0?22?3 t '. orr job accidcst tint* aisb-soo fcrW. Ad*. OT Total # *t tecUtttt 19 tost eorklac dir* 399* Sai si (9M . Otk ritttvn fc toot ' Injured kick * Ismlkg lTacnecrwatretd-.teundttont,r*Me-nte- lclaontntingkltcken <toU Sprain ankle caaplst Keek lajurr - auto accident Keck iajurr * cuts accident Motorcycle accident Sprained mnkl* -S fArramctluarjeur-r -noatn*tefeaect c-ideivnimt alac peel Auto aeeldent * neck pron lees Sprained erist x Injured back s fractured let motorcycle accident Auto aeckbnt seek Injuries Kurd# npaas - clipped at keoo x Auto aeeldent - seen injuries Auto aeeldent * kip Injury Bays tent 30, till out 30, ntlll out 30 1*. atilt out 30, at HI out 4 * 7 1157,, ntlll ntlll #i*. o* 10 n % >5: ntlll out ntlll oat 3, ntlll out 3, ntlll out 5: ntlll out ntlll nut 7ota " uer*l- PUnt Fkynlclao 1st* S314 UJ i f Ui 400MI 6072274 irxjuut KTCinn! uwuttut U6-JWI Aufoat 31, UTI , i\ imn or a wnu HTMUC, NJ imt Charla* Kt**r The roaulta of the iru Htplu that mi taka* at Smart ara all Nil bale* the OSiiA Tioo Vclfhtod Avar*** for I hour*. Sloe* your aaoploa vita tatm for laaa than t hour* they war* Tla V*l*htod for the tlaa that thay vara takaa aod oo* could airaa that tha cooecatratloo |in would rmaia martat eonataat owor tha raat c! tha ahlft. 1 would caution aialnat tatuoin* that thaaa araa teaploo raprooaot tha concentration* that would ha ohtalaad la tha breath* in* toot of a particular amloya*. raat axparlanca ha* ahown aa that araa aaaplaa uaually chew lower coocaotratleaa thaa rmraal plea, . too* of tha charcoal tub* *aapi*a takaa by Vaysa llcfcarataff laat Saptmbor hare ban aaalycod. Tha trlchloroothylao* aeoplo is mil under tha VIA. Tha raaulta of tha other aaoplea are not la jrot. Aa aeon aa they com la, a full rayort *111 bo foot to yow. to Wilttirr, Indaattui yiiao* tntlnoar Corporate loduitrial Uy*l*oa Laboratary 1 I O0j*0 I ;.sw;a mm*! SOURCE $33 0C04S33 {,"! .W. .1:" . i^-V- is rt _. M,u*i fucrs mr ws?eaijn.tn ex nunu tD kb cnuis nzn\ m fisizciic: a vsu ai at jot tr enora }i(*t> (lino n i lir kii k** itNct ft **ty y*r* tt tailfuti y* fmittin _ till i* Irtvttr? Jtr ccuyltitr.*! lyfttjtiry (rttictltt. Cifirtttr.j lily, tfct *tf I lin "tifity i'.iiiii* *4* iin W itfi(uilr.(, A rnj *n* hv| Uiltlitrittn (Ri) i mUt, vMcS Iium (.'iilvi .'luir; l. 11*2 iiitiini tkit *11 prttcrlftlm ty* ; |ln 1sj (fit **t*iniwttrt*l ) li *l^m rnlitm*. link 1m* : tr* 21 *** m'.vtlist f lc<ui:rtil>rul(t7 iilit; !* (t* 1* *v*tikl* at* th# till (ill it J:;:i::n **r "?!isi' *r p:nc:i)tli!>(;ii u.'itj {linn, *t Hit Jt** i ill (ii i:iiirc:m:*t:7i n!ity |lttt*t) i:l *h*vl4 ttt H tuC If jtni J*k tt qitt* iln ticviiii "iiiii; limit*. 1 1 Drily nil!* t- r.irt Hil tiitl if MtiiCl (11 Hi rtTulttrutti *f tsillut S**l**l 1 StitliTl II*.1 f:n::n !r C<iv;it!iul lit Eluitliul (> ini T*< ?titKtin (ti/itisiii it Civjit litvlitiiii) (t minii !:r NU*tlu cu V7 tiCuiitiil irltti> Hi AMI IJU tinCirl isiUdi i)icmciiltu Iwr iji id !m rntiiiin tt crry ! try it, i.-.tlvdr.t t;:n!u (nitty (Uiiii), rv*r *r sn*>t*ttli. ft** UdUi, I vtldf.t icjjlii ir.< $. T>.i Cimniiul *4(1:7 it< liiltl At (CfKA) yliui tt* ' MHiiiliiUt; it t>.* isliyit t* c*kt (ryl* Hie r*yr *y* ytitiitlit 1* *n( ' Hill (*114(7, * til jlk, 1 Dii ZI7 tiirdrl (itdtiteil 1* OtU) i;n1!(ii Hit litmiiit Mfcy liuti to it lilt! Is It iiu;::iil, It tlllriAiilly tdulfiil ky Xiaidttilil, ltd iifilli f ` vlthitir.(lr.| in trtiit !m t tni*inch*(li?tttr itl kill (n;tit M lulu, tit TEA rullr; siai.s iMcVtm ! te* vu il'.tlutil (7to*rl I*|i(t*r VL. 31, Hi. 13, !lr ;3, I1?l), tt<t lit* mil tec !i Uinclidt t* I* Ximiditmii lit . ' ihUii, J/l mi ilititir it(*l kill 1* vi( t* virt.'j ir;i<t fttlicct*. JtJtt . 14 111 fW rill:| ;li riltiifiiifl lilt ti|il i:rr. i* It (ittuilll ullty j lmitt with tli lit tt filiriiHM, V4i * iuti viy ( tiMrsfnlivf vtiitlii Hi ltii vr H*t: limit. K u(h uttirs imW Ii *(* { (trm *r <mm ilmii f-ir.'.ii* lytcltlly irtiiit *11(117 |liinr)'i Km>iii, ltd * 7IUII* My li tm In |l***4t timi(itt*iil t* :7a flA * * pae= ^ *tr*i ymitt (KiUtiebiti) * t* km iriitit '.* yQm litvn* tv* 7(lit::it| tlitit, >w M7 to *n 1* TtA `iHiii>riiliiJtt* ti*it*i ii v*u t* it :ii, <oinu r*utr*0 iUmtUl (UtMt. Tit* 131 III lilt IfKlCll Hit ttftty frs* k Kit* KRlt II tt MmIKKIHi mtt to til* *t il*vkvt*iit( ritirUU, ted dtxtft*4 tt T*(it llMI* Ullt L**tll, Ik* It\ nlltf imlni KAlttor it tto* (f?*n*>i Otitj liitmit lft iwtitAM a; thA Arkthttrii osvni(r ijrmil| th* TW #r4r * (wylytftj with tk* hi* 'utity (Im.'i* *** (7 th* tMimmt imvtiii, IT toil cot, .* <*> .. 3oor&t *0?22?s /11 u, i l l s r (' *> cnmy, pittifrertt, W. " 2J5-36I6 <** stptnbtr 19. 1976 **** Propcool for RTJ Bitpoiol ,'6i 'fl'1 . Vert* taflattri tnc-3-i S-jbitqutci to v letter of Stpircbtr 6, 197S llitist tbt fw oppi-eni ditpoiol titti for KS filled topoeltert, jpriy VtiMi truiitmn, coctitiu'.ii toll, dirt, ri(i cl otstr dtbrli, n bon ritilni fret est of tat Itsifill it*r portst oocpocy * torporoit-vide propel*! for tit (lapiti of pci*. Tit Ckiuetl vtitt Miattoii*. Bin lies of Unit K*st(eac=t, 1st. 90C Jorlt ieiiltnrd, Cat Brook, II 60521, bo* oatliatd to vtttlsci-oJt * tyitcE vbtrtty nriwi K1 eoet*iiattd uttrlili etc it dlipottd ef is fin rtfioai of tit ceuctry. fbttt rtfiono on: vtit Virjlsi* iPctvesfotyrlinau WI5TPJ M3ICT K. Dokst* s. Site:* Mi(tiottrnutuonit*o WyiKlif w*itia(toB Ctllferoi* SCtayleunndsite Antes* Ut*i Idtie Pend* enter. Bg.TBHg KBIT* Storfi* vu-fisi* 5. corslln* Hliiiitlppi leuiilta* Tim florid* Ktbtsely Ttbscntt txsr *Biat Ntv Jtrtty Ceaaeetlevt Piodt lilosi K*n*eiu*ttti vbHDttovtrii*sef*ttnorttpiairt Ktrylud la t*ei ef tit fin rtfies* Vo it* Mu*ttatat, Ine. a* intoins os tiittiaf Voitt Mu*cntst Caep*ny met nil netm tit K1 cm'ori.ir.ii Mtiritli tad omac* for ibi^tet to tbt Uimi* Iosifill titt. C^ -st " J V* 9o --4 --m . S *5 i s*: SS " !**"H0tVf*. *4 n Sg ; l Ea*l ; s i 1O O ro to ,'0 \ ;:*_n i'-O sSS?'.' 1 &-'i Mrian 1 -a* MX V* X4 kibwtit asion Ch**leal Wait* *B*<*!r*. ljS'.a It. k Caluact tzprurvay T. 0. Be* Hk Calwat City, It 60*09 Contact: Hut Koruna Lea Llsdtnan Hone: (603) 323-U*I! us,-. TOira Hoff trottan tafui* Corp, 101 Ontario Strati tatt Been*ater, ITT lUi; Contact: Jack Hoff fbone: (716) 361-2937 * --- E .r * hs S5 i wr hi *4 n sr r, HIT gCTTBAl KSCICH Otto liquid Sdrpeaal, Zac. S>> liberty Jtrti: Tranent, 3" i'-JO Cbesleal Watt* Hasacmast, Inc. 903 jorlt Boulevard OU Brook, 11 60521 ?> 4* ' =I 5X Contact: Sen fekkardl Tfcona: (H?) 33:-z4S3 Cer.taet: Bay Bock Hor-t: (312) 65S.-8600 tst. 373 reoios 1 ChRici] Wait* Haslfcctt 2131 Kiaftten Cwi S.w. Suit* 11? Marietta, Ca JCo6t Contact: Ktt Jofcntes Tfcon*: (W-) 97-C^- Ia accordant* wltt tkit ccrpcn'.r.v'.St propoaal, tfc* (ellMlel Kl dltpcasl price* save tit: offered: JJ fallen i-a . tS9.?e kC fallen drts * twj.oS '3 fallen dr* * $32.72 5 fallen ins $3.13 title loot dirpotal SE.14 i ii 1 Net* --a: *t* pclen lltttd are fir Uncial only. Transportation prlets* will to* frevd.dtd ty tut Individual dlvltiont cf Watt* Kanao*r.i, Zne. on a eat* toy eat* tacit. Watt* Kaaaftwnt, 1st. tat tnrptiti a tatlfm lyttn and a lab*list tytta* ablet suit tt uni fer tr.e tr.ipsest of Kit. Infemotion on I till tyttae can to* obtained Ires aw of the wait* matf't*-i Ierational repratestativet or ty ealllst ti for a copy of tst cocplet* Watt* Htnofcnast proper*!. fify >. k. Kent, Kanafer tnviromental Control Conttrieties tcetnelecy 131/407950 t L'i.-.Jvcxirrjg'js-'*2^?- I J i iI i FC >..- $*:rw. t:tv3<i i*as it -7rjiiut*fWI.Scw*-.erLIrTVwTfc*rSJkWkR&4*awween*r i h. litT4.'!/Ti; Canter lnA*nri*i P/pur* Ur at; . C. kemtr; * Par furf.an- KS S. muuj * tar-J KS *. . Ecprl - fenmll KS fc-'rmr1 u * as?r cf *4^ ef LVk npervi edrvttad ty *, Jo* d. .'cmct ca '-r ~-j^a Occrtc Pm: Ca-p*-/ araiwt uua ^jU.-yjr. rwii at tf< utnn Lop ruvjei, fcrt- : ;a tt axnr mapped V Mrlai of ft. .'iMor. eXvrcua- W Mr.*', pence.-* I wtnwt In V igiiu! ru i !en ou.-.vc-u ftwn;. it. r*t.v* ei u Pau Cutn ctivcc ce-.e_-d * easy c: v* ipen \o as-pl*w v *M*ur<rojM nff.tJ c! '.Mi Sr tmt t*ft ottsi |M nml tit xuCi*vl of riiuw i ex-iee-w* mvui*li, frvneineUy tirKa. (rar aitwt Mr icep Cei Scram* 1 fcnr r*aea. TTm utnup *f Ai Uch. till 's* dert! Apart. far tf pula! IfrU 111*. IKSA^fi April Itl?., HT. nlji umv ttpesi u cplr>ci t.-in; w r*Ml et uaiw l orvec-mt stein <-e t:o* vnCiuai u'jtvii tra cr* euiwan :rv. lap Cu tvatm* w. 1. rr* tMrfl rrper: li beiiceliy titcliua e! Userttesy OMlyii* pcricpK ty nr. .'aesjor. d e*-p: eUxte ty v t*Un;rauM vpwu. nr. C. 1. Tratt. r*. .'eat** tad preevey* :cr tf pence ef r;j;l Iter. trrAJft tta lft>. end in i Ml <tMT.il . Truitt ecUt*e V* **rp tni i*. ;<MSi la nlyiU. ttad ITU m it Bsiaaly, tf ravttaljc Cf<vr*_lcr. et e* r-ivp-rri A ntri M-t ^c* tfrc.nx <v ;<: *t?cam tt'.y vp Ciia ravituvt W> M t l^cll u Uet c! pracvcliviry, , X rp.*ic tn* ) tr< atrium rrvcrvi, u vr.l w rv rTpcr*. t! IpTVI }:th emAui) v< czev venrs ca-iC_c3e it tier utaui Lmn-nc-ve ivivia; t* usliw IP. 2. as d*v*s*er* i! w* twui ec!!ri*r-t snttcrira itu ta *ruelifc ireenttad wrre rv>j end praartjrei u> easarplut; evrvler co* nrn eui pent-v.n; inr monp epenuav. .*< LC t-awo- riieirie Pea*.- avpar-y dwti uv., ;r aae Tw> 'rni e: w UTAiliUd data indicate the rat UWr preaarurt *--Jt oyjd u suea-tus-tsc kitfu ,^nx' muterue la Ust ot raw* i'i reiM-.a-.i.-< saMitea-ee-iairi-e llanast Irauiruvi. / newt oi April lish u *s n. -'anaa-a n^x--. tor hertb loop se. 1 tree hairt *'t\.-aar, As:tl U1- k-ciiBs the eats Its sntenur. It is Mooed ws f--S c.' t aU b* m vr.ils (mnernel are atnre db reel sf is prstsets'* e;ei-_*i; nd abd-ab r_ ir-ra..- u it*unsn or ** ea-*u -- tUfi'tun tc-ifwt v-.-_- pa.me.Ula filtiT T t>p T. In natlUar., It La t*ss-nd t*s: v> pei-surial ta sd-.snd la a sa/tty Hwa prlt* ta I sun 5! rt <:i el V* na.-kbu.-i; ^tcnuos nfilad ta tat; Ut Aart leei ta t unn 1 Altai raldU^ til. .`laarj r^sit let IU*> I09 tie. ) u trail as hi Utcraitry Obytu el dais lei tm jarred April l?tft I I lt ill i-L-t It Ulbcr: dais la lailtr prtrcaed kin rtanl c! i utiMi-iPiib-^i biaii-sx iioOk witnekit `tn.v aeiturtn;. hmwi I ivlaal /air uua.a aisar your review cf taa M^et Inuial. tta addltivuj era -V-ttlv. vu In^etad las CM IwaUrelrn estarUl crsbikiiuff. ty n. jaws aborts 1 In lea 1 el tls Mtonadstim pe.mx. el -bi tepee: ler ten.*- Ur ! *1* Rsiaeart tint tbtan,Uis is rat f.ta; Vb-e taab-.i taut el its east, as tall as us ettaailnq r anult ev.ee sib** fistic lass t tha _b*ect npat. Mla-a V k panaas sa-e stter.ucr. tteuii ta paid ts tha roplananr-.t raiarlai By CM asacontre. 'viisn, 1 o.unsd s nt.-uaiu-J'.t el tt9 Ire., <de felia- Be nt.uvt i-jl--iibS-. ratenal. and was advlaatf ihn CM tiberplass ratarda! as nrdKTid i* ,'.t. ixe-j Cepesi' tie Oaal^u-jaa t"s launai a* TST-ef-. r-ai.- liureraft indieatag ire meet flier dire-jr is .ecej) leet. re `user la-em -as e-.t*r m tna OttcIfti'e uresswv- and Ots rauriai is !i-vt: dticdad as rstue t/pt. bu era Carat l-tr Uteri naetJUd utavar. "Sis rb*^> nprtsa-.uuka will Icrvard a eery el taa J.P. fta-ara daicriptiv* iitarature tuei : trill lerwd v!-a i*ai-d. t I neiest tf-st you review tr# 1 liarclass iriosatlo-. prevtdad Vr . Jaeuat snd ar. bsa n it tna Ha id heeline et CMS oatanal repfia pretneu-a I raw-res w.-nLtrat used tru V* irstsllstiv, el ts fun Herat rattrlal tisvUed. feAas b'-'t-iltr. tenaxi rarulbra L.-S idutlui rapiaoran i rattr.als 1 .*.*.* * --ptetactlka cictlbre as tall ss Ciapraatls reSrvur naats. Ceuld yoj ncaln furtiar Wamstio-. to help In you rraluatlm, plaaaa ar.ua a. t) aonrl3--r*' *aarrk f ;5 gsf iE1" i"F ? 3S ^n >H -S/ & SOURCE 844 6673990 | t i future iP*(ftiU4iibhi evaluate V1^ ttt Ijm tfviurt ie(j |* tliiViM iUakii v*^vfrc*i'i */* tvi*.n (4 ikji iciu*r i*|wurv^ arc Mt eMWk((rrt in t4-^ tUMtitn, the *vt* r<**vtl ?> Iht IkiWiA* f*r tr*vc **ff C-rjr cr wraf.pci ih rustic anJ ft** cauwaa th*U Pc tifteiifj it Mivliin* ihf UrArt& ifiuct l' twf*r twill**1). Nil cn W* ItMrit*< 4* ihn ifimly AllA*-** th* hhiih l*fiU 4* Ml im if **c*va. reH ? 11**? t*?J*rt** J* ^l* a4 n. **AMnutf c* wr pntr.:v* tltthini *u rttpmufi t itr Mfih JJtA. uipitt m Mil* nlUctH ** varim hrf at tha rti lacati**. fimnt Mlviuit **Et*r*a *.*. eJ**tr4 th* tvf*ih n mult *f th* prifiwl <M'I n. J. *1 Mi N. "illup Iptm IA UMtitr *f ihtr tlM f|lylM th* flaer. pip*t. th* twMtl*ur:icti titit wart ttm th* fclafUi*t rf*l M *ni*i 4uat particlt* *r* MM/itii *r 4i*twfP*4 lnnp Vil imtU7+ A MAt**rr *4*4. 12-tali** w*t m* 4ry view* *:**htf wai w*wl f*r |t* dy**up. W. JffT ?mu, * tttifi*h*u* A** Milu* v* my <l*Ahr ** liilr* * water trap lit Mi c*xau4t*^j *f tf* ***.. Mt *;* tap** All Mt* nuicuiu, T?.* **itp*r.4 ( tha can *tr trap v*t *; et*r4 with tMr va*u claaear tat. In *:;<*! tf tha wat*r*l4h*4 'ficu# aiAaMt *aa miieia* ta'.tiumM vhatAtx alhaitM Clttra w*r* ktlny (aptyH *r mc_ \ k Imirth urplii *a place* 1* t>* Ntiiitt hMlhf turtle* *4 an* lm* la a* Aft* tiAilar t im tn *M;)m fir tws^a il, T>w* fwvrth tafflcr. a* affact. waa rmrattrin* ucifrtgrvi iimiui ce-icantrat**** witMh th* NAIM **li4Ln*. ^ IV. (myri k**4, * tlwvicUn Ait* unia* far 4) Admit** Nrla* U wBffc uma* t\, a* a *v?flia* with a C*^a U t* w*r viili M th* turtle* h*U4**f. . th* *ft*rn**n, ;. *i* ft m, *HU*> paint** th* *r*ca tf a*t MM atlt*Mi*nnUiM*i ratal.*: L.*at wat u-i *a-*t ft**i| tin th* *4 vhtit,r*tbrtlM< tcitii* Ah4 th* aluhir^ Utti F*l?-t Mtt IMh#* |* MimpllM Man lull* pvfpi* arj aaal th* **riul vlfatt*. litlurch it 6*1* y *. RkliMi *r* **ne* munttM am rrtttr tu* iiap.tfi Mi th* cm area Mhi&sr MI ui fU ctliirun* pimn;*m tin m* wmim *r. :VitMl ^r~~T1f tf th* trf*fii pat*t* *n harth }|tf> Meat* m 4u*tl**i. Ititlia* vitk a itrMnvit art tlifhv lai^nutM aviJ tf K*i*ny 4i< Mt a aart t* llitftu *r hvtt th* jair.ul ufaer. ?.%i it ipmr* that paittiat % u*atf*au*MAf furlac** I* lu*Mj iaurikl*. X* ar*l t* mm th* ira*;*u Mill far cvntinwati#* *f M tniMlri ptfMMl pr*tCU*A n*if*atn plC|* lhe Mt i-M, J#u filuit w*r* *mt*4 (r AMlrtit *t th* Uhtwartity *f iruiy lne.itfial L*ui*t*tr. Mtalti frai (Mw aaapm hi* iiictaif* vi%h fe*vh ;:it pinaawt (6. *m aM J. iwlil SOURCE 844 4874887 I 0*4 <1. *>'4miV 4n4 J. tfUIttl, *f. 0*r**lt 4*r** t*u *:.* ;.rth4l prttif i i*f. <**iJ 04 f*r*vcf vfcto tft* an* *r *Jiif'*t* *4* M tvimr^rl thi( *r* t* t'Ai,ftw*t (If 4 I 44T* ir-l lh*L 4t *tff*rrc4 Outo* 1 KflfVIfti 14 M. Iftwiat'l rtW4K4utM 4U1C4I f4prCftl4tl*fc. mfg*t 22 *** *.* H f- 2222= fcrt* a**?!!!'! ciauM Ur im Joy-aaaft Mura *t i*" iauua^ <i ?r*i*n*ly iturtiii, >tft_| 22* 1W Nnawl I4VUM r,4 4f UK|Uf4 ait yttfirvil iariii *', flail Mi It. 0**4^ tUiWitt latt tM twrM*4 bvildM oMmt 13*1. -3. 641* too olanwt* | t* 6* ftcotitt S an r(|Uttf4 Oi tcf liiatttt *ul# 3, 641* attkii > t4l ** **4 in* 6;iftl*t4. Omit p4tti* f vi44t tori*} tM4 Activity ita rail 4| (+*<* 4ft* tflt t*tll4tl*ft %4I 4ff. ?M fel44tt tt*l4Mftt 4t UO*l*t#4 40mV111$4A4 UP^itM tmifkiut. A Itvlr 6o* 0**ft Mf <**< 44 *M incawi tt|it4ft M acrltM laiiq ih* frf.j*n.ct^;?M*Uy***iUtft4fafttii.Mb*tft4i *#m* cf.atiminiiU#m{ 6taMt*tuatca<*AU^Lnf iri*mt*rui4*l**,*. tM i:;cv:t`y ctMiwtitfi irt yrtittt 1. OtltfM* 4fV 094**4 t itltdit !ll*n t* tM o*tftt Out Mitul i**.UtnM 1* tt 0!i*a* *y tK ArtaMf 1416 OtktKtAtfillMMflAn iufitittrlttliiH t* m tum?Muv| i6i i*t*mm****>t1U*9M**IfitpMitati liliHi 6.1 UMfi/ic. 3. Vhil* tfi* CPU rvt yiftitimt ttUMttt* licit *( 2 fl>m/it v p*t titntfl i* Oil *ta>*r, 4 rtlwittiA of M niiraal tt ffactic** cault malt in aifaiam IlfHttAf Oil lUfllltl, bUMll* tM 0**0 t*lllft| licit Of 16 lllri/<* vat not tact*4*4 fto a*y U*flt <*ll*to4 |ft tMl t*4y* Olt/ioufh finUit MmU"? of lituni i^/it 6l*o c#*u r**lt i* ai^tvrii imm M c*ili*4 *4lo*. lurUta iTittoi of *t*r4l *6640* w iiJiur. ily r*m v. yimiiity oi itatittff clotniM on* iru?#li*o tiiftrmti of* Mt tf^u4 *t V* 1***L4 ( *aHiu it~rA * 0;t lta*f< Mr fufifylo* miintart in romtra* if oi I*awi Too ftvoiMioi* opjr U f kOcrt/fc) *f tM ctillf* or tm^iO (16 fk6cf*/ct) iivtl *4t f*at*ft4frlr nMtiH tf ** *o oof* tM* 10 tiOo tMaa UotU* KeOrfO.l t* 21 fft 1610.1601. 6l*ll4fiy lytcial *veh 4t tavariin. M*0 to**flMt, floai ft*. * mt tmml aaim **Um Jo*l* Of* **o*4. 4. St if Mt Kt:ceury (Or scourtly Atrvcr-r-cl to u**t iti* ?*t<riM reyotor *Ua rams tu*f ^e*;A8 rounOt *-rM uitinr ortr^nl ^ettvititt iitiiif to dot* k Uui iffiu. wr rou* oteuIO olto Mt r: miNtry v,*ipm haUu rt *r*ctttt Irtmtutt or (tvt otr i4.-pn* riuili ind;mi t*i( t*tr*rr. UiK on tfi (IMiflu ; u.i o*r aao *4 muU ( oitoitisorj sa Tycoon lUctnc fmt*t C*a>oAT ni tmnori<i r>t*ritf do UtlowMt rcM4nau*w oro ilUrHi i* UMtir*(VhtilASrf untuii oucti i kStwui an* |1mu C4t 0t utC 0* tM^UCI SA t/i (J rJkkMI ftAOulO kt roplocot u?i o&Mitei*l/o i* *4 oo o ft;jtoirt Tf utt tt;fr;v^i* ori i;*iu Oo*tr for turrit* wr.iort-ftottiy* ftooroioit *t tx\ vithnt not wiu fourf of iu wjt., ttuc.itf i vktriti v u <( root#* omeu on !u<r;:oit vot >*:*;< fiir too oooo SMtm into cwtT-t v. inAin* on t>oi sotoriti* Alts* oocuoo of do t.'Sti biufu Unoiftt on ItkfifUM l* owloi^. X m4U*1 rontutix* ;mra ** OoftrtiM U 39 CTt tflO.lUV lOkl( M tiulil!l<j. A copy ( tM 0SY* rfft)nl|lt so oofcotto* AO ................. for yoyt itltit'tt oo AfpoMUft vs Jo oikMto* oonltrnM ;rrio imU M l?.tttoto4 to Mr tUt c;lrt ,'<ett oro to or peptul*y oictof ttavsMtf'roo 1* bit ft J t*,tv.rfm U.U Vit fPC Soiorr Doporeont to* jwt pttcotoo tvoo w roal 9 OsrOOool itffiir* ^}i ori Coo *tcn csftotnly i*nuwtri o aeanm to o*oi* vo wMxftiM 9 Ur.. >rio4i ftryul ttfjUrt ritU Pfioiiit Sht Oloroot iu:m^ o*t rtUtuot UlU o well *t ony mil of kl*<4 piuritS. SMrttr ttOtttfl lv. of OyfotiO* oif#cto4 t OOthoyo 2 ip or troatrr. motll to otmroO ol# to *"Nft Wt IIMtll II4SIIO 04 Uo to sot otrottoi* Ail kUMftt* kl>4 on* o*y odor orntnnuinb>t utttuit 29>t oro rrtroffi *< to k rt(uuf, too ** Btrrurt tttfUir .n v..b r*^A,rt. fm tstivtty. tout Uop irdAot* 0Ot(l to cwt two OuOt ttMmilK. X! ttkkMttllH Mttuturt o*4 prsttttivo cfotUnr yestfd o*o*U ssnUAtfO to ko 4o*il*; to vsisyooi or.til out* ttso o* 4 4ot* mm art ta* von ytteticot ih dot ookoov* orpoturot ai *4*smi4. I <mtx ptittlrw tvit Oo to iitkt of UH IMittl. Ipo (If it m;ph*4 0A4 a*v*: yrocoOurOt OAOvU O# OUot Of*foa4ctttoaotfOiMvtl tl4tuFittnfUioll*t ot itttAtip*yil#t:aloMMH<W *f SOURCE 844 S3; ;. tfXriutn Mtfittt titfr Ca::ctu< *f * 1, ***! T+m9 3* ruift m*u* u*ji ) muiKint 4.1 a ilih tavMrani) f&ltar 3. T^tiM ar.a lMl ei*M 4%., ttfutiT;JdMirrhSuhaat mv \ 1. T* IMVII ivffitlkft Mttar/ c.Uf?* 4-(iff i*447l* amliiUO. ^nMl pwO fcaia 4* charcif '/mic-s nUm . if Mtmin. %M ii<i 4mifT r*fy can 34 4:tMr(H Stm u tHrantM 4 fall 4 3* Attach tM U*rliM y Vt wtctir with! tM H>1 *r fattn X tha HAift.r - V4 4tn.,'i **u. ifian am aaryy la N^a | aaUacttC. *:;j ih* fxt u 4 *fi4 ivffart at aynayatiif ma 1ml vat* matam mp at 4 mil* ^ \*ii yy p;*f ft4 tM (Uut tiimta Wvu 0a M01 *4a;wc lay tf.a tamtu ait am. \ 0VMt tyiy t l> wal tCaattf a*t atyih tM lHl tllp ta ralarai'a callar. Maa if* ^.at the tdat la tw!21i*atl? l*f* *4 Uit it fatt nat itiuict avifr**'* *4'mhi at *ith wan patfafrAMa. 11m, im iUttt ^$r,r.t 3* Uutaf clay at tatUkli u th* aaw. .*f mm a* at ta appr****4tt tM artivuai tt* *>iia am lapfliri 11 tt.ai mifffti, v> fiitar fat* iMall 3a vanml r tUthtlr #M1* v;y th fact 4a*wiu, m that yctmuta till mx fall aata tM iutar. iry tM fat* w) ai tM aatittti tMt a^iUnt 1U M aMt*iacti. !dft yi faftayl twspUnt f.v a* art yt tM i*4Ml flaw rata. r*r art tmiui r,.v*.*t <*' irt :u I*r*o SS fha flav rata / aria ifvyt attaf Sul Mat a! **."?!*t* 4yKy ayn tM i^rMtur; tt.ara. aUc 4 Mura a? a^-fUM- w* p ain't M Mat latriy (tv;mlr ana awyai aftar ayranutalr $ Man *{ < ft, that tafwiMun* taaart tM Um M final flM fata W iipim tM aaitatu fata tap art ply* 1. 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IMM IM tirMU IcutUH aapatura *m M, t* 7VI-C.ff'rt t 277 >*l?f/eg 1 IT ala O.i+f/frg i iMm C.tSf/ct t *3e` TVA .4i UMti/ic far 9 hmra trt 21 imtm, m It MUvlitil la an n(hffawt |*tU, tfcm IM va*14 ka 1.17 UUr*/t. iru itfiiitt lurch J7, 1*7* CalaaladMi ft tlaa^Mi-fMa# (fa) ---- 1, Ac*il **rHn* iuv4> At.M flk*r/ac far *10*1* u*Vl C.U fifcart/a* fr U* aa* u*71 2* Uii thit itfiit **1 li o.e;s ratkar Um rt.Cif, TiU Ia4*a4 tiffimu a uiuta vW ht tut Uut ^amti ftut at Mtimn far aalnlauaf i 2* flafitm. vnif U faravU UintMi (M irti aaapU* fft mu _ y.e;f//cc ais *j c.n f/cc i m at* 1 Jl) tu* 1 t 4. (Vt aa\wlUa<u t*-*a.aajf^cr t usi* * c.mtuc ttoU o.n;/rc t inn * aas m m flkara/aa Tt** I r v' \ ATrVKiXl ti; iM r.ttf^tfi tt e*ic*Un** nif'^t ttfirstM *t cvtrtnuh Wtrt $1* WJ* M4swrttf..........0.1 fl*r*/t *r IJJ U-U 1.1 fiwrt/t ftr *i w` tat' V-J it >* tittu* **< J-1 *0 citAUtitt. 0.1 f/* t ><0 ttv* 1.11/te_> *0_tw 5*.4 <lMtt/cc T J lAnrtwtli NtfwrM t.tit !imh/ ftr Hi lm <**l) |,M t*l >* in 14*1' . HIM............... |>I it l tkWMi ii I** II w Ctlnlttkt*.. _*** *{]* * ?<a **' * *'** t,..n. 1- *--* *`*V i,l >lttn/it limit ttfitiiM * ci!> jjtiti ** . Ut . lit* 4* Stitt t ill*/**...........t.M (IMtl/tt ftf tittttt U*>l .: rik*ti/ rtr it* *i**t*t w*tj CtlnUtiu 4. StMCttl/** MlltiX nmtM i.u rtt * *ititt uoi 4.11 ftttrt/tt ftr 111 tittttt *!> till lUfin^^it u MMKI W *1 It tlMUl Ctltvlttlt*, I I-.. . it .i. e.i; f> iw 4tt ft* * 4.14 ll*tt/ft ii*t tittiirti Mnk * Wi 1*** 4. Stitt iC.Ml fi*rt/tf ftt flMtt* U*W 4,11 Cttttt/tt Itr It tlf-tttt 14**1 4.1* IlMtt/ft ftr 1J1 W-il \ SOURCE 944 6874017 . .. rilpww-i 4**)r tv\ itr >. * t .. o lM rv |mv <AU4l4tMiM *** a.jt?.yjr n tt--.\ , x.-- t.\t.t/n i :!&' .Tti/r ?vm 41> ** ' t.ttl Jihfl/ef flf 4? MtNtlt IH"J] 6,;} (iWM/ft i*t #4 r.**.t** <-)) c.ch (iMti/t* lit i;a hmmi <**) ........................... -4 it j;e 4.11 U*r$/t* St ?1 turnn itn 4^iir r*i ;r m. iujuo/;. itMtvii) e.u imtt/ct f iH"w i :> a? !ff'a t {; * ?V4*/rf t 4i* J* t " I 7: ,. ; {; lr1',)/ I j'- ,> SOURCE 844 <8?4018 -..-v v-""- >>*vSsrvrV ; .'// * t" -# */j i >`j * ./ ! ;'J 1.-4 'i \ V* t 4i*.*',.t*.*,: '. - lt*U fc-I l*J 0-4 *- **4 *01 4-* H M 0*1 J*4 * 4*1 j-t -i M i**j*jih>* U*>HH 1/17/11 wm 3/ii/T* 1/10/71 1/V11 4/11/11 <1** om-io: UCi-jSP M>U3t UlVtft** o*ii*inj cm*im 0747-17*4 UU-1IW jv mittml tai* fa?u VOltfW e 101.000 im.poo 27*.000 004.000 *U.M H9.NS 1JI.OOO r.rt/ film _4-- ,.M Jl.MO <4,000 <4*000 4,0 DO <0.011 0.11 <t.ou 4 0,011 <0.01 40.01 40,01 1,040** . 0.011 j/nm l/OT W)/! j/atfli /*/? j/r. v/ 1 ,v VIW* 1014-UCT mi-im U5J-14SJ 4 04J3-0f$1 loivuit 1144-1))} M14-XU1 0IJ4*4ff leiwut lU^XM uiwu< mHM io>t*i:o im*i:u 1111-DH 1404*107 1041*00 ui.ooo 43,000 44*000 111*000 n.m* 01.000 114.000 V.tM 10,100 .M 4,10i 11.400 11,000 0.30 l.J t.KI <0.041 0.11 0.14 J11.000 44,100** 140,000 . 4.100 4.0)1 0.040 14.050 00.000 10.100 41,400*** ,mU* 0.04 0.00 0.4) SOURCE 044 % 1 ' s<4 ; *',*. 1 n-j : iv IIKfUlt t4t *>t 8-1 J/at'Tt *J >//? #4 J/ll/M M IO jyji/n *1 */nnt 4-1 s/st/?* 4*r|ltft* 093V*) leawm mo-ms 1414*15*; ooi-nt' lOU-111* 1044'im 1104*1143 i43i-im o*:j*ivx5 v#im mi.poo ,CM *1,094 114,904 fiO*f/ Liilii- 14,904 * 30.904** <4,190 1),*00 11.400" 13 ,*94 rinn/ +jE^m* 0-11 0.13 <6.944 9.11 9.13 0.0*4 tr-rtti *<*1-1} 4vfi.il *1,000 43.499 It1.906 4.140 <(,U0 0.10 <0.11 0,0*1 441,009 44,190 <9.91 UWvft 1/31/7* tUnk IllAl Iftnt *Wra VT/T* J/I/M >//'* vum 9447*04M -- ** -- 1)4,009 _ --* *** --* *,199 <4,*04 <4,100 <4,*49 <l.0* *** -- -- ~ --* * *4**lifl* t*U ( 1.1 Uitn Mr WWW ** iiuirtH r*4^r lr ur* i* **it **** City * M tht #llhW itM UT tfsirl II KU *1% 8? tM ' 4U ^ii9 UU v**hm *1? *1 t* MiK. UiM U 41 th tv* uiiit in vtM* fnunM iW tiwti. _i SOURCE 844 i ii 8874828 . ' * l . .*-<^ ^i ; :: ;,;>v . A0 ' * -4 lemiUH.tUl Soviets t-n Htkltr, J, Jtt Stn< 0. turnttt, C. Htnkartsn, It. 11 v k *111, i. iruciynitt, j, ftrrj, M. Aosgiritl, J, JU*, J. aienCt.i, i. ZttlOtfljr. A. US ItdrtMtl , . ADPtC*. A. sou*ce 132 i m*Ju2-vn.ua % C. T. ftraty - B(T., tccltat hwitla, t. Htt*. I. VUtUttui - X|r., ktiiat hiiMtlci, U>t> ft. I. U(U - BlTilloa Safaty Caortlaatarj L t'lm hfiirtwr, Safaty, 7. hlui - Uii7 CwrilMWr,, VTaaraa ^tili 7U Twtr CxrarTfaa O^tntlM hfity Craay titiltt la acVatalat far Oetator It (knu4k OctaVar 21, 13S la Oiarlitia, Berth Carallaa. Tha aaattat ahaolt atari at 11 aaoa ot ai tootloti irwl 3:00 y.m. aa frlfcy. ItMmttai Un Uaa mmU at tfta lolUay la, llttia lack bat cat I-tJ. I *111 rnrlti sjoofat tTCBtyerUtlao far tU frny. Llatad Velar ara tU topic* aa hat malaoaly ylioaat ta- flacaaa at tWaacrlm \ TrUrj Float oafity laapactlaa a* tU CUrlat^a Stua Tortla* flat. I'mpact!aa afetr - bfttr Obaci'rar prusr-- (Vbat ara . talat at yaar laeatlaat - oatariala). folia* o* tlacuiln Min Co^. pro*r**. (Ltatar - Charlotte) 0oa mt eaatral af toxic cVartcala U the wrtjloei (TPS atrli| ayotn). ' bcltaot tact aaalyala. tar facility oafaty procraa pLnaiii, Safaty auarrmaaa yrrtrnt tyycc aat ffactloiiiaii Baton af --rlair aatarlala (Laottr Braaaall ft. Mtta). Baa af imrolas laVala far (MNlif aatarlala. Urolls UVali aa protect far coacaaeto* oaa. Caaflaat cpac* pracatota. . SwV-ceatTaccer ufity i tftlrf party aalta. M aafaty aaalyci* proem. Safety coacoltatlaB 4 (trlar prefraa. ' Carpcroti aataclal cata tyttao J I i 0 CORPORATE INDUSTRIAL HYGIENE 236*5648 July ?, 1961 ASBESTOS PRODUCTS 6 EMPLOYE EXP05URE TO ASBESTOS i: VEST1NCK0USE BUILDING - 2016 V. M. Bryant, Director Property 6.Casualty Insurance \ The attached information is provided in an attempt to comply vith the following request that you made to C. U. Biekerstaff, Manager, Industrial Hygiene several weeks ago. ' 1. List of products manufactured or supplied by (V) which contaio asbestos. If possible, please indicate which of these products are no longer manufactured or supplied by (V}. 2. Employe exposure to asbestos--current and historical. At the outset I want to mention that this data is by no means complete, but we are hopeful it will provide some background information. During the early to mid 1960's, Industrial Hygiene was encouraging the divisions to eliminate the use of asbestos and find suitable substitutes. In February, 1976 an effort was made to gather specific data on'the use of asbestos within the corporation, and to alert the divisions to the significance of its continued usage and the problems of compliance vith OSHA Regulations. Attachment 1 is a copy of the letter sent to all Industrial Hygiene and Safety Coordinators, informing them of a one-day seminar on asbestos. A questionnaire was sent with this letter to survey the use of asestos at eaeh location. Attachment 12 is a roster of chose attending the seminar. . Attachment III liata (W) locations that at one time or another used material containing asbestos. In Attachment IV we have summerised the data aupplied on the returned questionnaires to indicate some of the Veatinghouse produets that contain some^form of aabcstoa. EXHIBIT (OitKEJtSrjtfP-3(p | CONFIDENTIAL j c Since 1976 00*1 of the** asbestos product* have been replaced with another type of materi*l> Attachment V i* a list of tome of theie substitute material*. We are aware that Trafford PC8 has had aoae difficulty in finding a replacement for the asbestos-neoprene stop gasket material for bushing*. At the seminar, the Hampton people announced that a decision was made to stop production on asbestos eontsining sicartss. However, beeauae of the special need at other divisions, they may have aome limited production. Bedford dees have some limited production of coated asbestos paper. We cannot answer to vhicb (W) products, that contained aabestot arc no longer manufactured or supplied, except to note that the Consumer Products group is oo longer part of Westioghouse. In regards to employe exposure, no monitoring vat done prior to 1973. Attachment VI is a summary of asbestos monitoring done from 1973 to 1979, which ve prepared for the Legal Department. We can bring it up to date if you need this information. I have also included Attachment VII summarising data from the questionnaires to show asbestos products, used during plant operations, that are not included in a (V) product. - Hopefully this data will be helpful, and if we can be of any further assistance give us a call. /jme 132/4085147 QUEST!OSHAIftt - ASBESTOS* PRODUCTS 1. Vhjch of the following asbestos containing products are used in your operatic.-.*: _____ Block Filter Media Rope Packing ____ Board Laminated Conposltions Sheet Packing _____ Brake Lining Miearta Bars Sheet (Asbestos _____ Cable & Wire Micarta Sheet bonded with rubber) (Asbestos Insul.) Molding Mixtures Sheet (Mill Board) _____ Cement Sheet Molding Compositions Sleeving _____ Cloth-Treated Paper-Treated Tape _____ Cloth-Untreated Paper-Untreeted Trancite _____ Fibers (Air Floats) Powder Yarn _____ Fiber Powder (Resin Grade) (rPulverised Asbestos---. List any others not mentioned above. CONFIDENTIAL If possible bring to the seminar or send in advance a small sample of each product used at your plant. Place each sample in a plastic bag Identified by a Westinghouse Material Code Humber and/or Supplier and Tradename. 2. Describe application (if more space Is needed) use other side). 3. List products that have been investigated and found satisfactory as substitutes for asbestos. . Application Tradename A Supplier Bring or send a small sample of each. Package and mark the same as requested for the asbestos product. * If you need a copy of the proposed asbestos standard, call Zella Heisl^er->du^- trie! Hygiene, Vn;: 236-58:7. 132/4065:49 RETURN TO: Zell* Heasley, Vestinghouse R6C Center, by February 2?, 197& ATTACHMtM il -ROSTER aseestos seminar Marriott motor ink PITTSBURGH (GREENTREE), MARCH 5, 1976 PA. i----------- -- ! CONFIDENTIAL I Raymond A. Sleeker Design Engrg. Architectural Systems Dlv. Grand Rapids, Michigan VIS: 523-7277 Needhae Holden Accident Prevention Charlotte Nuclear Turbine Plant WIN: 422-2454 Edward S. Bober Safety Adalnlstra tor Accident Prevention R6D Center VIS: 236-7272 V. A. Ittel, Staff Asst. Engr. Industrial Services Division Creentree, Fa. 412-928-4768 . J. C. Botts, Manager Insulation Design Engrg. East Pittsburgh-LRA WIN: 236-2823 B. A. Kerns, Manager Environmental Control Construction Technology, Bldg. WIN: 235-3616 Phil Cheksnskl, Safety Engr. Water Reactors Division NES Building-Monroevilie 412-373-4651 George E. Eaverty, Safety Accident Prevention Sharon Transf. Diva. WIN: 224-5316 Supvr. Denese A. Deeds Industrial Hygienist Accident Prevention Buffalo Divisions VIS: 245-2616 - Norman E. Kartello, Engr. PCB - Trsfford WIN: 236-5316 . Carol V. Erdley, LRAD Irwin Mica Plant 412-863-7000 Engr. Gene Martlnella, Supvr. Manufacturing Planning PCB - Trafford WIN: 236-5221 Saith Cause Engineering Manager Kaapton Miearta Diva. WIN: 422-6343 Paul Falmleri, Supvr. Accident Prevention Control Equipment Croup-Beaver WIN: 222-1371 M. A. Cipko, Envir. Plant Services East Pittsburgh WIN: 236-2454 Engr. John Harrington ^ General Manager Hampton Miearta Divs. WIN: 422-6320 Larry Rudolph, Manager Accident Prevention Industry Services Division Creentree, Fa. 412-928-4679 C. R. Ruffing, Engrg. Insulation Development East Pittsburgh-ERA WIN: 236-277! 132/4065150 Andy Sale, Director list., Safeguards l Safety Nuclear Energy System* Monroeville, P*. 412-373-4645 C. H. Schilling Accident Prevention Derry, IMD-Bedford, Manor, Vest Mifflin Plants WIN: 222-7263 X. M. Sextos, Manager Insulation Development East Pittsburgh-LRA VIK; 236-2774 Dr. A. A. Spritter Medical Director Nuclear Center Monroeville, Pa. 412-373-4649 C. V. Valtz OSKA Adclnittrator East Pittsburgh-LRA WIUi 236-2192 Janes R. Velshons Corporate Standards c? *4D Center WIN: 236-7232 Paul Vike, Buyer East Pittsburgh-LRA VIK: 236-2234 Richard T. Villiaas Division Adain. Accident Prevention Bloosfleld Leap Div. VIK: 326-3338 Eugene V. Wood Accident Prevention Baltimore Defense Dlv. VIK: 234-2007 C. R. 2icrercin IMS - Bedford vis-. :::-fci25 Gerald ?. Brady, Manager Accident Prevention East Pittsburgh ' VINr 236-2823 Industrial Hygiene t Safety Staff John Adaas, Engineer George Arensaao, Adaiaiatrator Keith Bodden, Administrator Zella Beasley, Engineer Willie* Ziefel, Kejtager CONFIDENTIAL 132/4085151 (I--C-O--N-F--ID--E-N--T-I-A-L- f| )' ^............. ----------------- - In March 1976, the Corporate Standard* Department lnforaed Industrial Kygiene of *2 Westinghouse Manufacturing locations that were using at the time, or were known to have used, asbestos or asbestos containing materials in their operations. This information was available, because these divisions were participating in the Corporate Standards Material Code System. following is a list of these locations. Athens, GA - Overhead Dist. Transformers Baltimore, >D - Syster.s Development beaver, FA - Control Products Bedford, ?A - Treated Materials Bloomfield, NJ - Lamp ocmicgtcn, IN - Dist. Apparatus .idgeport, CT - Bryant Electric Buffalo, NY - General Control Buffalo, NY - Large Motor Buffalo, NY - Medium Motor and Gearing Buffalo, NY - Industrial Equipment Chesyiek, PA - Eleetro-Meeh Cleveland, OH -`Outdoor Lighting Derry, PA - Industrial Ceramics East Pittsburgh, PA - LRA 6 Switchgear Creenville, ?a - Specialty Transformers Dreentree (?gh), PA - Industry Services Hampton, SC - Micarta iorseheads, NY - Elehtronic Tube Hunt Valley, ID - Electronics System Supports Hyde Park (Boston, MA) - Sturtevant leffersco City, MO - Underground Dist. Transformers Lester, PA?Steam Turbine, Gas Turbine Lima, OH - Appliance Motors Lisa, OH - Aerospace Electrical Lima, OH - Small Motors Muncie, IN - Larger Power Transformers Newark, NJ - Relay Instruments Norman, OK - Residential Air Conditioning Raleigh, KC - MeterRandolph, NJ - Elevators Roundroek, TX - Heavy Industries Motor Sharon, PA - Transformers South Boston, VA - Small Power Transformers Staunton, VA - Commercial 6 Ind. Air Conditionir. Sunnyvale, CA - Marine Sykesville, KD - Industrial Equipment SykesviHe, KD - Welding Trafferd, PA - Power Circuit Breaker Vicksburg, MS - Interior Lighting West Mifflin, PA - Transportation YounguQod, PA - Semiconductor 132/40B51S2 ATTACHMENT IV ([confidential | fV? PRODUCTS CONTAINING ASBESTOS PLANT Su ffalo FORM OF ASBESTOS Treated and untreated cloth and paper. Miearta sheet and bars Cement - filled with asbestos fibers APPLICATION Insulation in motors Wedges is notors Baked on wound resistor tubes to keep vires properly spaced Consumer Products Paper, Cloth Division Insulation Esse Fittsurgh Miearta Sheet Asbestos paper - treated Sheet - asbestos bonded Cable l wire * asbestos insulation - Stator slot wedges Turn insulation on edge wound field coils for large hydro generators Gasket aaterial Ease Pittsburgh ""Irvin-- Cloth, Paper Powdered asbestos Molded "U" channels and molded shields for insulation Filler in resio mixture; supplied to other (W) locations Grand Rapids' Board and Sheet Fire retardant office divider panels 132/40851S3 PLAN' Greenville DO (5edford) IKD (Hampton) DO (Manor) IMD (Wes: M;fflin) Lester Muncie CONFIDENTIAL ATTACHMENT IV Fite 2 FORM OF ASBESTOS APPLICATION Re*in filled with asbestos Caulking for metal transformer case seams Laminated compositions Insulation Miearta sheet Terminal boards Paper (silicone resin treated) Coils Paper Paper Powdered asbestos Coat and laminate the paper for electrical insulation for (V) divisions Asbestos filled micartas Filler in their B--7--365 vhich is used at Sharon as vet winding resin. Filler in epoxy resin (V) 'M53533FD used at Trafford PCS at tract resistant costing Treated paper Molded part (not certain as to ultimate usage) Slock Asbestos sheet packing Insulation in turbines Casket material Tape Barrier on shell of trans former gasket material 132/4088184 PUNT Sharon South Boston Staunton Trafford PCB CONFIDENTIAL; ATTACHMENT IV Page 3 FORM OF ASBESTOS Miearta sheet Varnished asbestos paper Transits APPLICATION Terminal boards and core-eoil spacers Wound into coils as fillers Duct spacers and fillers plus . reactor disks Rope packing Used as barrier during welding of covers on top of trans formers. Material is caught between top flange of tank and bottom of cover. Transformer is shipped with asbestos pack ing in position. Miearta sheet (Hampton product) Terminal supports for CE terminals Kicarta sheet Asbestos-neoprene sheet Asbestos filled epoxy resin (W) W53533FD Core washers for current transformers. Stop gaskets for bushings and EHV columns. Tract resistant coating 132/4085155 i ^ ATTACHMENT V SUMMARY ASBESTOS SUBSTITUTES PRESENTLY USED 1976 PLANT Blooefie 1 d APPLICATION Curttins-glare and heat shield SUBSTITUTE MATERIAL Fiberglass Cloth (Pais Mfg. Co.) Buffalo Insulation None* (DuPont) Mieartt Silicone Class Doryl Class MelaBlne Sheet . Peh. . Protective Blankets for Soldering Blankets Koaex (DuPont) ' Refrasil (Hitco) H 41514CC Lester Insulating Blanket Filler Pipe Insulation Block Insulation and Pipe Cenent for Block Insulating Blanket Cover Kaovool (Babcock 4 Vilcor.) M 4 1414 AD Teop Hat (Pgh. Corning) M 41414AD Flace Safe (Johns-Hanville) K 41424JC (fiberglass) Therco 12 (Johos-Manville) M 46102BB Super Power Bouse Ceaent (Keene Ind. Insulation Corp.) Textoglass 1925/9383 Class Cloth (Pocar, Philadelphia, Fa.) Sharon cuihte s: e r. V >;: Tank Cover Gaskets Fiberfrax Rope (Carborundua) Class Sleeving Heat Trap for Brasing Vet Cheese Cloth Fiberfrax Rope (Carborundua) Stop Casket for Bushings Duroid 900 (Rogers Corp.) Shielding for VeldBraze Aluainua Sheet Kosex (DuPont) Fiberfrax (Carborundua) >'eld Sat'r ier (I lankets) Textoglass S/192-/9383 (J.P.Stevens) `-`el- Barrier (Sheet) Texterlass S/84205/9363 (J.P.Stcver.s CONFIDENTIAL Ii 132/4085156 . 1/1 <L Asheville ATTACHMENT VI ASBESTOS AIK SAMPLE RESULTS 1973-1979 confidential YEAR SAMPLES NUMBER TAKEN RANGE OF RESULTS NUMBER ABOVE PEL 1979 3 < 0.01 to 0.013 0 Baltiaore 1976 (Before July) 3 < 0.2 to 2.0 / 0 Bedford 1976 (Before July) 1976 15 3 < 0.02 to 0.04 0.04 0 0 ^ettis (Wes: Niff Ur.) . Sloosington ! i , ! \ 1979 . 1976 (After July) Buffalo 1975 ' 1977 1 1978 ! i Canada LTD Burlington 1979 2 3 3 19 3 14 0.02 to 0.33 0 < 0.01 to 0.04 0 < 0.5 < 0.01 to 0.22 0.06 to 0.09 0 0 0 < 0.01 to 0.2 0 32/4085157 Chesvick Derry icarsros Alft SWII RZS'JLTS 1973-1979 YEAR SAXF1.ES KUX3SR TAKEN THAT YEAR RANGE or RESULTS (Fims/co 1976 (After July) 1976 (Eefore July) 2 2 6.2 to 9.4 4_ < 0.1 to 0.1 2 0 East Pittsburgh * 1973 1974 1975 1976 (After July) 1977 j.*7e 1979 Eltira Fairaor.t 1976 (After July) 1971 s 1 1976 20 3 10 18 2 3 23 2 26 2 < 0.1 to 110 < 0.1 to 1.4 < 0.3 to 0.48 < 0.01 to 3.8 0.5 to 2.1 < 0.01 to 0.16 < 0.01 to 1.5 . 0.7 to 1.7 < 0.01 to 0.18 4 0 0 2 1 0 0 0 0 0.09 to 0.11 0 Forest Kills 1978 2 < 0.01 0 132/4065158 fe) PLANT Greentree 1 I Si u! ;r* 'i CQI.F.DBTlALASBESTOS AIR SAMPLE RESULTS 1973-1979 it Ji YEi3t SA.Y2n.IS NUMBER TAKEN THAT YEA? RANGE OF RESULTS (FIBERS/eel NUMBER ABOVE PEL 2 0.12 to 0.22 0 Lester Manor 1977 1979 1977 8 0.9 to 6.3 3 / 6 < 0.01 to 0.53 0 * 6 < 0.01 to 95 0 Newark Soman 1978 1579 e < 0.01 *. 2 < 0.01 c 0 O'Hara Township 1977 5 < 0.01 0 Pittsburgh KDKA-TV i r 1979 5 < 0.01 0 Puerto Rico 1979 1 < 0.01 0 *^5 ai- sa=-ies taken for short tice period along with OSHA Industrial Hygienist resulted ir high cor.ce.'.rratirr.sof Asbestos-like fibers. Over an 8-hour period the results did net exceed tie 132/4085159 f.-; '#* () PLANT Research 4 Developaent Center Churchill AWSTOfi AIR SAUPU RESULTS 1973-1971 ICOWFIDEWTIAL II YEAR SAX? IIS VERI TAKEN RUX5IR TAKEN THAT TEAR 1 RANGE 07 results (mRS/cc) NVXEIR ABOVE PEL 1974 1976 (Before July) 2 6 0.07 to 0.14 < 0.03 to 123 0 3 Richmond Kentucky 1979 2 < 0.01 0 Saline 1978 6 < 0.01 to 0.03 0 'V.aror. 1975 1 1976 (After July) . ' 1977 1976 \ 4 8 .. 2 4 < 0.5 to 8.0 < 0.02 to 0.06 < 0.03 < 0.01 1 0 0 0 South Boston . 1979 t 2 < 0.01 .. 0 Sunnyvale 1976 (After July) | 1977 1978 1 4 20 6 < 0.01 < 6.01 to 1.7 < 0.01 to 20 0 0 1 -1 * (t) PLANT Sykesville \ 4<;*T0S MR SIM?'-* RESULTS 1973-1979 YEAR SAMPLES WERE TAXES KUMSER TAXES THAT YEAR RA.KCI OF RESULTS (FIBERS/ec) 1978 2 0.02 to 0.09 KVM3ER ABOVE PEL 0 Trafford 1975 1976 (After July) 1978 3 1 1 < 0.03 to`3.0 0.05' < 0.01 0 0 0 Vest Mifflin 1MD 1976 (Before July) 3 0.2 to 21 .1 ' Vest Mifflin Transportation I 1976 (Before July) 1976 (After July) 3 2 0.1 to 0.2 0.02 to 0.06 0 0 132/4085161 ' ATTACHMENT VII ASBESTOS USED IN PLANT OPERATIONS [!lCONFIDENTIAL 1: II PLANT Baltieore Dive. FORM OF ASBESTOS Board, pipe covering Bicarta, rope pecking, cable end wire, sheet pecking, trensite sheet, caulking coopound Buffalo Untreated paper USAGE Insulation Weld curtains Casket aaterial Electrical tape s Used aa a liner in die cast and to catch drippings of varnish in ovens Derry Sheet Cloth untreated Rope packing and transits Tape Place unfired ware on it until it cures or sets Used vhen annealing sachine parts Making arc stacks Ease Pittsburgh Blanket Cloth, tape, yarn, sleeving, paper untreated board Blanket for soldering, brazing or cutting (no specific operation oentioned) Greenville Sheet packing Oven lining Creentree Micarta Paper Rope packing Cable Motor slot vedges General use Packing IMD (Minor) Asbestos fibers . Mixed into resins for B-7-365 and (W) M53533FD 132/4065162 i l i 1 4 j CONFIDENTIAL Attaehoeot VII Page 2 PLANT Laap Divisions PORM Of ASBESTOS Board, block., transits Treated cloth Pulverized USAGE Insulation on furnaces, ovens and laap asking equipment Curtain* for glare and heat shielding Used to aake furnace ceaest for heat insulation Lester Cloth, sheet packing, sleeving, tape, flex tubing Paper, rope, packing, sleeving tape Rope packing Induction heating and stress relieving Babbitting Suboerged arc velding Muncie Rope packing, sheet packing Heat barriers on brazing and/or velding operations Re fore Sleeving, transire, yarn Insulation Sharon Cloth or paper Heat trap for brazing. Shielding for welding or brazing South Boston Blanket, sheet Veld barrier 132/4085163 CPSC UST (Coot.) Asbestos ceaent product* Water, sever 4 septic drain field pipe Alrduct pipe Sheet produces Roofing clapboard Siding Shingles Interior veils So Her 4 furnace baffles Bulk sheeting Welding shields Baking sheets Blackborads Laboratory table tops Linings for vaults, safes, huaidifiers 4 filing cabinets Viscous Matrix Products Adhesives (glues 4 epoxies) Air duct ceaent for asbestos-ceaent air duct Buffing 4 polishing cospounds Caulks and putties Floor tile ceaent 4 mastic Auto body filler Flashing ceaent Furnace ceaent Glaring coground for cerealcs Pipe and boiler coverings Roof and driveway coatings Stains and varnishes Autoaotive metal daadenar Autoaotive undercoating Refrigerator ceaents Autoaotive auffler repair compounds Products subject to inadvertent asbestos contaalnation Driveway gravel Fertilirsr 4 1cm care produets Potting materials (veraieullte) Talcs for aoneosmetle or food use applications Acoustical 4 thermal insulation material sprayed Ammunition shell wadding (CONFIDENTIAL !j ""gFATlST (Cont.) Aluminum roof coating Roof patch Roofing felta Roof preservative Sealants 4 castlea for Consumer M. coroerclal use A/C pipe joint sealant Adhesives Caulking eonpomd* ind putty Furnace cement , Glazing compound Radiator sealant Varnish *32/4085270 I gsc LIST (Cont.) Automotive mufflers Barbecue flrcbed materials In |ts barbecue grille Boat hull repair kite Hover pota - Friction sateriale Clutch platee , Brake lining* , Fetter* kiln* (hose hobby) Pottery clay Powder (aabeato*) Bulk fiber Reinforcement in molded plastics and rubber Automotive radiator sealant Vinyl asbestos floor tiles Abrasive wheels Aerial distress flares Molded plastics and Phenolic laoinates Paint Textured paint Cement, dryvall k plaster patching ccapo in ds Artificial gas fireplace eaberixing material Phonograph records Consumer products possibly con taining asbestos Air conditioners Dishwashers Hand-held mixers Portable electric heaters Popcorn poppers Refrigerators Vacuum cleaners Waffle makers Carpet peddlag Fireplaces Insteat Light fixtures ea railroad passenger cars Welding masks File cabinets 132/4085271 n. Ct*AT1ttUT LtASJR*CEPE. tdL-bS X Up* ChJthta Ctnttr Office Svlldlnt m 2JS-AU1 H July 31, 11 Bitpetti of rCl*Tllltd Ciptcltert u Sutlnttt Uni: and Civilian Central fUnistrt Hint Hani|tri Word Ensinttn TOSCA/RCRA Rtpnttntitlvtt (. ), iA ml 1*: PK.-}*-fi-bS) Veitlnsheun h ii|ntd in i|tttctnt vlth DISCS, tnrerpontid, if II Conic, Artiom, (ar the dltponl a! PCI*fllled eiptcltori. DISCO hit epulpetni for cruihlni ini cheap In* the attaint parti of the ctpttUot ml for dtotroyns the PCS Upuldt by anna of ntnatly tilth tarptntunt. Thli Incinerator epart tier, it tl Cottle it the only PES-fllled tipteller llapettl touret prtttntly available. It It Vtttln|hout policy thit PCI-fllltd ciptcltert thit m no lon|tr la tut be llapettl of. Inclntntlen it tht er.ly ptmtilhlt lltponl Hthod. httllutrttri tnvironaantil Afftltt, util Hint the cerpontt contnet With CISCO, will ovtntt tht litpetil protm, *e iccoapllth thit wt ouat ittibllth in up-to-litt invtntery of lU PCS ciptcltert which art in ttsnst for lltponl. On tht bitlt of this Invtntery. trrinstatntt will St tilt to eelltct ill ciptcltert and tnntpert thtc via tht sett tcennlctl route to CVSCO for dtttruction. attached to thit lttttr It t fore which cut: bt filled out by ill plmti which hive PCS cipttltort In ttertst for dltponl. Pltttt ttcurn tht for* to hr. S. A, Kent. Chithti Cmttr Office Sulldisp, Set 1011, Pltttbursh. PA 152)0, Sy Aututt 11. lit;. Cltcuttlent will thin bt held with DISCO to dtttmnt tht tchtdult and vehicle routlnt to tchitvt tht lovtt: pet t lb It cot: for dltponl of thttt ctpaeitori. At thit tin, coat fliurtt will bt dltcuittd with etch pitot rtipondlhi tl CM* purvey. Bltpottl cotta will bo hindltd through Utttln|houot Kotdduirtoro wtlni tht cerpontt centrict end will then bt billed to etch dlvliltn bond on tht ictutl cott to the Civil ion. --7lfr>wCJL&j u_s3 Trent S. Sell, Cirtetor tnvlronatntal Affiltt rtS/a) Atticbatnt rn 1sn * Is E** o t! M 5*? 5SPSf"* a5 4n Rp >r Hi I ...o :o iL (Iso5 ;{ lie r JCn _ LU l)2/407*: t L 1i EXHIBIT ^ Corporate Procedure CP MS . Atiftto IM2 Wtaosfboua Citrate Corpenuon Reporting Substantial Risks To Health Or The Environment Background Stcocc I () of tba Torte jutotaamt Cootroi Act pratidat that lay pcnoa wha maaufimtm. pmiwm or dowibuttr i ditsued tad who ottaau Bfermatioa wtuch ruppors tha coaduaos that tht totsucd fnma autotiatid rat of iajiay to health or the nreon*nt aurt a/raa tba A* aatatntor of tbr EstvosbcuI Ptotecttoe Ajmey (CPA). Failun to promptly taform tht CPA nay nbjtct V* iaiboua aqd to employee to erfl or mmiad pmaldtL It it atpcruai, thtttfon, tbit tU Weraathoiai employee too* of this npertoi tad that rapoosMU- OM and ptoctouna for Wttpttioa in tloady anabikbed tad widely dtoemautod. Purpose Tba piapom of tbit pterdtn a to: Detcnto *bat afonniaea mun to reported. IdasoiV peenblo eouicat of bfotmatwa. Cnablah impaBdbiimei ad procedure for enluatAf iaformosoe tad for reponai to CPA. Detail tbt pesaitoa tor tuiuo to upon fcfoimasoa. Policy It b Wettiactoeiaa policy to comply fully with the repuuw- mob of Sceooo I <e)of the Tout Storaacm Ceatroi Aa at aippnnn nfiiinma information that Must Be Reported Tba Aat require tbit tba foQowatf in/onnatioe mist to rvponed: o Konaa health eftata,tototdta|: 1. Aay toataace of cuter. birth defeat, atuuftaidty. death, or snout or protonped meapaaution. if ooa or non toesueda 0 tmofiy implicated. 2. Aay patten of tff*ett which tuppom tbt cooduaoo that tba toeraied ca product caaett. muuuoe, birth daftra or tone effect! neultut| n daatb or nrioua or proion|td dnpostauoa. 3. The ntufea of aay ttudy which lupponi tha eooeli. mao that tba tortunl aa hart aa advene eife o Ina health. EatVOWBtliftiKU.iBdUdStf: 1. Wdatpnad aad pnnoialy uuiopecied dtratbuuer of tba totaled ia tha cmmiMat. 2. fnaottocod btoaccumulanm of tba ditstoL 3. Aay atom effecti taoeattd with juefi nd*rpm. dnmnirnno or biooanasulauoe. o Cariyacy taodaaa of oarwoaaicrual ecmuruattion that threetea >"> or tbmias noneumaii orumen wtth larpa-ocala or cfniopntfy opuficant popiuaaao c acnicsoe. Sources of Reportable Information Sotsre ofropotublo tafomiatioa aduoc : o Report! or oihtt enhance of adnne tfleco on tnv pioyaa, ooruumen or tbt eanroomtat. Health audita os htenasi or aatmaia. o Medied aad health nmyi. o CamonaeBtd ttudioa. o Otborfailed aad ceotiaflod ocoropcd rapttusenu aad audita. Responsibilities A* Captoyee AS Weeda^toeae empioym capable of apprteiatmi tht tijaiftaaoc of tvbttaaual mb e/orraatton art tutieet to tht npotoai restatement. Aa employe who hat tubmmed itformatna at aeeerdaact with tha proetdurr *dl \i*t dutoaiitd hit or bar Sttsoa I (t> obli|atis Padlry Maaaptr Tbtmaaapnofotto Vtttia|boiat facility jonmia by tht Irwi of tht Uaitcd Statti wiS; laforta allcaploym of tht ton unit of iha Ccrponti Piootdtn tad of thttroblipnom to rtpon miormttion atom rati that ceistt to thru aimnoo SOURCE 144 r- o j ? - ? j i-r> m* &MC1 K i D CENTER - #601 DESIGN AND MANLTACTURINC CENTER 236-5635 November 9, 1979 lT* confidential) _____ j 1# ALL DIVISION AND DIVISION'S GENERAL MANAGERS There is en announced Intention by several government agencies, primarily the Consumer Products Safety Commission (CFSC) and the Environmental Protection Agency (EPA) to res trict the use of asbestos in "non-essential" applications. They have published an extensive list of products containing asbestos on which they are beginning a formal investigation in order to determine if this asbestos presents a substantial product hazard. At present, the CPSC and EPA are soliciting comments by means of an Advance Notice of Proposed Rule Making. The EPA is considering either: ' 1) The traditional regulatory approach restricting the manufacture of asbestos by product categories, or 2) limiting the amount of asbestos available and allowing the marketplace to determine the use and application of asbestos. The two agencies are combining forces on this Issue in order to coordinate their actions and not duplicate efforts. Thit letter la written to accomplish the following: 1) Let you be aware of the situation, if you are not already, in order that you may evaluate the impact on your division. 2) Request your review for additional products vhieh are not Included in the ettached lists. These lists were supplied as part of the CPSC's and EPA'a Advance Notice of Proposed Rule Making. 3) To solicit your cosznents on this proposed rule. Comments should be sent to me for eoopilatien, review for eoneistency and for clearing with the law department. further details oa the areas in which they are soliciting comments are given in the attachment. This Is cur opportunity to Influence the direction of the government policies before they become fixed. Therefore it is iterative that you suke coam*nts that will help us Influence the government agencies and that these comments be sent to me by December 3, 1979. 132/4085266 CPSC LIST Asbestos paper products Acoustical ceiling tile Lamp sockets Burner nets for gas stoves Roofing felts (outer layers) Pipe end boiler covering . Vinly sheet flooring becking Radiator top insulation Appliance heating shielding (paper) Slow cookers Hair dryers Paper sheets for heat insulation Millboard TV & ocher electronic switch plates Electric switch boxes Metal reinforced gaskets (for air-cooled engines) Electrical washers Linings for ovens, kilns, safes, safety boxes, incinerators Millboard sheet Wall protection behind heat-generating products Floor protection under wood and coal stoves Soldering and welding blocks Iron rests Appliance heat shielding (Billboard) Toasters Rotlsscrle broilers Fireproof wallboard Metal-dad fire doors 4 partitions Tent groanets Stove pipe rings Cloth and woven products Flexible air conductor-for heating, cooling & ventilating squlpaent Appliance wiring Barbecue fire starters . Broilers Curling irons Electric blsfikets Hslr dryers Resting psds Ranges Tossters Irons Deep fat fryers EPA LIST Automotive Repair Mufflers Brake linings Clutch facings Custoa auto body filler Metal deadener Household Material! Appliance wiring Coto ter surfaces Electrical cord Filler for shoe solas Floor tile ' Hair dryers Heat protective mats Ironing board pads k covers Lamp nancies Lao? sockets Potters kilns Slow cookers Toasters Safety Equipment Xprons Ara protectors Blankets Boots Csps Clothing Curtains Draperies Clovas Hats Helasts Hoods Mittens Overgaiters Sleevss Suits Ui&rellss Aerial distress flares Ammunition shell wadding Catalytic hcatar mantles Tent groat ts TV sets 4 projector equipment Roae Building rgjirs tatex paints Texture paints Cownerclal applications 132/408S268 r, CP SC LIST (Cant.) CONFIDENTIAL EPA UST (Core.) Electric fry pen* Avnings Candlestick* Catalytic heater mantles Cigarette lighter wicks ' Cord Seal* for high temperature gasketa Valve *tcao packings Insulation for glass handling tools Reinforcing for brsided vail stes hose Theater curtains Felt Reinforcements in plastics Gaskets Reinforcement in asbestos tapes Secondary Insulation in high tempera ture wire and cable Asphalt impregnated roofing felts Plano 6 organ felts Heating pads (element insulation) Ironing board pads and covers Lamp and lantern mantles Pipe and boiler covering Pot holders and oven mitts Flame resistant garments Gloves Hats Helmets Hoods Kittens Overgaiters Sleeves Suits Umbrellas Aprons Arm protectors Flane-reslstsmt blsnkets Soots Csps Smokers bibs Stoves - Cosl 6 wood burning Tape for pipe insulation Sraid and rope for packing Motion picture screens . Tent grommets Aluminized cloth Sags Searings Belting Slocks Boards Braid Buffing & polishing compovsids Cloth Cord > Diaphragms Drier felt Drilling fluids Fabrics Felt Filtering material Metallic cloth Millboard Paper Pipe 4 boiler covers Pottery Clay Plywood patch Sheet flooring Table tops Tape Textiles Welding electrodes Asbestos cement products A.16 sir duct A/C pips A/C sheet Baking sheets Cement boards Clapboard Roofing Shingles Siding Tile ttolded products Gun gripe -- Filler 4 reinforcement in plastic Pond liners Phenolic laminates Resins Rheostat backing Rooflnj Materials * 132/4085269 location SiaeoTiald - Sect. S003.C3 . t. Worphy hriii tiiu i.c. Cartar/C.o. Saith Blooafiald, Saction 715 Jo* t. Xty&elda EXHIBIT A StAff 37 SiKw;,. Tone suiting** Toxic Snbataao* October 23, 1979 nibotyi phthniat* Bansana, CbloroCoppar A Coppar Conpeenda tthyltta, Triohleie Ithylan* flyeol lydraalna Hydreccn nlfld* j.Butaann* (KB) Kathnna, BlbnaoTlefcal end liekal eoapos&da Soap*t (fatty acid aalta) fltaalsa dioxide Toluene Taa^ta Xylan* (nix ad laoaert) Zlne (natal) Coppar natal liekal natal Tons* tan Te&natnn outbid* Asatyian* Carte blank Chronica eonpovda Coppar and Coppar eonpecnda Cyananida, ealeln tali Ethan*, Chloreliekal and liekal conpeund* Tuajtttt Tua^tan carbide Tittle icld Sydroehlorle anld Solfarie laid Anaphoric leid Sodln Cyanide Chronic Anld Caantle Seda Oakito iyi<490 Salla Chrenat# ifmim fcotphat* Oakit* 32 A 90 arc cccosroUl aside with *! asldn nixed. SOUPCE 003 J 37 -cotton * 2- Sloovflold, Section 715 Cost'd. Jot E. Biysoida Trl-*than ZrietloToothaaa Oo*r*aaid Sol. Mierovaak - Laqaar Hioroatrlp Sol. Sloov/lald - lu3 Jbocpbor a Chwleala J. P. Olatta Ysdsoct S. 1. Pasrlah 205 ' Soso K*ttSv ftiaust )09 S.l. C. V. Podioy . Vlp - Toss* ton fthaaa. 1*1.1. Trlchlo- Jtaoapkora - istloony Trlszid* Honor,o (Carboaat#) TaaaiUsv Pavtexlda Cbvaleall Titaaita Blond* SlaHtk Cklorida Pthylso Glysel Tolsav* TVTOStlAO Xthasa. 1.1,1. TriekloroZylono iootyltso Coppar tad Coppai eoopossd* Ceppor (ootsl) lthaaa. 1. 1. 2. 2-?itrbre*>Xtbylna, Brcvoliekal aad Siekil eovpeoda liokal (vital) Tsaciton pesetas oaxbldi iottylo&i ianoalsv. illyl (Cft-ClS) divatteyl 3,1*- diekloroboaxyl*. ehlorid* Cbrovinv eovpomda i.f. Chrovie acid, ealeisv aalt (ill), dlhydnti Chrovie sold, dipetaaalsv aalt 3uvlsa(XXI)oxldt (20) Chnvisv (TZ) ozida (It3) Coppor asd Coppor oovpemdj SOURCE 003 1 lococaatitoionn - 3Toxic Pubataaeea Maaoat - }09 Sealed Bui Coal'd, ttbaa*. 1,1,1-Trlshloro- 0. V. Padley Itftjleai, Tetrnaaloro- ,f, tthaaa, lChloro-l, i-diTlaarcKethaae, ChlondinuaroKetbaae, Siohlorofltwro- Mareaptsas Hiokel aad fiscal eoepcsada a.(. Yiokal (aetal) Uekel (IX) oxide (1*1) Soap* (fatty acid salts) Tttacataa faa^taa carbide Zyleaaa ,f. Xylene (aired isooers) Palanat - SOU C. 3. Killer 20$ - Bld<i.4 Crouds leetyleae - Shop BiVntyl pkthalate eoatlaf latlaoy trioxide eoatia* Copper (actel) Land Vina Pthane, 1,1,1-Triehlon fthaac. l*l.S-Trichloro Haacaaaao - traca la phosphors (counter) Ileksl'cad Yiokal ccupo.irirta - Lead Vina Pstnltai dlatUlataa - eleeniaf Tltaaiaa dloxlda - nfleotor eeatlac Ttniditaa Leap Celia Tamtao Carbide tool'a shop Torpamtlxe palet Xylenes a.. Xylene (alxed leonan tl^ Hired Xylene* Toxpeatlae Uebaesd - 310 Drufald leetyleae - mldlai . latinany (HZ) chloride - etching ao lotIon Baasana, Chloro- Polirieoope Clyoele a.f. Sthylue glyool Xydnslas adder flax Petrolsna distillates - mineral epirits Titanic* dloxlda ehellac eoetiay 1W Tuaysten Vln SOURCE 053 1 Location Sloeafiald - 151* .'u> v. Earbart Ovasaborv I. 7. idtaa li Tails SibittMH ioatylaaa Wbutyl ftithalata lauaaa, CilbCoppar (aatal) Stbaaa, l,l,lTrlshior9Sthylaaa jiycol lydnaiaa Mstiua* KB Mathua, filbmoIlolcaX (attal) tlttBln dioxlto Tolutat Tnfita Xylaat (alxad liwn) 2iao (aatal) ieatyla&a - valdlaf Slbutylphthalata oils kuw ehloro-float atrala laapaetloa Ceppar (fatal) laada Xthaaa l,l,l*?riohlor9 - elaaal&t roca tttylaaa *lyeol - aoldar flax Eydnaiia - aoldaf An j-Pattaant KB paixt aolraat Hathaaa dibit*^halofaa fill p4 liekal (attal) laada Tita&ia Siaxida - eartale paint foluaaa ooatinf tad baalac <wat aolTat Taaotaa - fllaaaatt Zylaa* - eoatlac A baa lac eaaaat aoIrast a Zlaa aatal - aoldar Ilibutyl pithalata Ba&sa&a, ChloraCoppar aad Cappa* eoaponada a.(. Coppar (Midi) liekal (aatal) Propant, l-vbloTo-2,3,-apc^Propana, 1,2-PiohlaroPraptMf l(2*lpoi7* Propana, l.fitw- Pwpana, 2-IitraPropaaa, 2,2'-Osybia- Propana, 1,2,}-Triohloro- SOURCE 053 13739 locatlea Ovaaabero - Coat'd S. ?. td*a JlOOSfilld - luii V, 1. Morcoa tittle Lock J. Veaaac C. S. hit - 5- Toxic gobetaaoee Soape (fatty acid ealte) Tuafiten Tnacstaa earbida TUrpentlna 2iao (aatal) Sodiua Uaryl Sulfate Laaol? Chroale acid Copper and Copper eospounda Stha&a. 1,1,1-Triehlorofiekel (attal) I1C12 1130b fttnlra tlatlllatee Taraol? Sotpt (fatly acid aalta) Toluca# (thinner for tpoty paint) Senates Tuaptaa oarbide Taaadin eoapcunde laasalua aata vanadate Acetylene Sibutyl phthaleta itnsBi, ChloroCopper (attal) fthaaa, tnao> Ithtu, l,1.2.2-Tetrabres Ithaae 1,1,1-Trioblorottbylone, lna> lydmalae Hotel (aatal) Soap# (fatty acid aalta) Tsaptaa Zlae (aatal) Copper and Copper eeapoasd* Itbaa#i lll2.2-?etrubrea Tnpim SOURCE 003 1 ~ruA location Bleoaflold 116/126 1. 7. Eliott* -6- - Totie Subataaeo* ioatylan* nuoroetrbonj - Kathasa, Chlcro dlflooro - fraon 12 Nathasa. Sietioro difluore - ?reo 22 Glycol* - Ctbylaa* Clyeol (OtlM Pitnlia Eiatlllato* - Selvast Saphth* Cthaaa - 1,1,1-Triohloro ' . Toltan* - iolaant is padst abop Titanic* Slozld* - padata Torpaatlat . SOURCE 003 w*r= S vwTiaaoust iciuiae -is: V. X. doalitoo, tr. Cooealtnc la rti^otM to your docuoajt, *Vttlo4SoM Cetaldarttloco," tatoMlobJag o ti.t tort* to ni?enA to llt!t*tleo brevgoc a^unat to corporate** la tcontln U rnwctist Co utxtiu tiwu< Her* It^otunt, ciilo took fare* aiauld cite *snU*r wLat futura lit t title* la pottlbW fro* o*ol Esift to ralUtlet tad ou.tr haaardoua or udc atwrlal and tiUui of tuA *utriol to too wrlHittt. t TSa Corner* t lnd* trial 0*1 la* >part*rat boa boo* Itto lead la ootlttittf i Carf^ntu Lav ?r<fon for (bo (oUovlx( mAt lltl^otloa tod vorLon' covpoaaatloa caici; *' 1. Corr tally Vat tie pa yea la tbo da leadone la *ora than 1W Lav Oulu coartrslat aabeete*. v. 2. 1 cent mat loo valdar u?ohI to vtldlaf fi detail* la ttuc'Tt 0. (Sea addItiecaJ. 2. 1`rrUiu* aooiurs to raclsyea at lloo*fulit * lartry aad falntoot, dot Hnicla fltau. _ t. Load tpomrt to o^loyat at Di lottery, Jto'aU, lUtnot* and Soltlaert Eefcaea Cottar, , S. itarooSotdo, Mv Tori vSaro a foraar aaplaya vat alliflot Lor coator to ttouted (re* ocddiUmol t^oirn to rtdla. e* tbo imUuou c`a jroue K*o ** tbit to lend la tSoto tad t >r eoeat, C ONculd a enaotdar'J for *o*^.r`iln o- t.nlo iir-.ortjnt (area for a olplflcoAt tola to iwatLet too Careoratt rtayouioliity u 0. Sao of iLa Ceryatata Indu* trial dyflrto Looartia.it la tala rUto to boot tioaa rtaaoti tat leaetuui lata frcvaotlon ^aptrtaut lUSad. . 1. Stall* dipoitMt towaiUbLliry;. ^ .* *4 2. Sladlo polat tf cotwtt. ; . , * +. a ** , SOURCE 844 8873140 I W* K-.. *: + ii SOURCE 844 8073141