Document 6B0RdaamK1pbQ3x3ezr8Mnxjm

JUL-21-1993 09:40 FROM WEIL GOTSHfL & MANGES TO W eil, G o t s h a l & M a n g e s A INCIURMO PKO^CSSlOMAL eO**OHtOMS 7 6 7 FIFTH A VE N U E NEW YORK, N .Y . IO IS 3 -O II (12) 3IO-SOOO f a x : (b la dfO*SOOF C *BtC : COOMA TCwex: WQM Ul (212) 310*8904 July 21, 1993 P.02 OALLAS HOUSTON MENLO PARK alveo vAkvc") M IAM I W ASH IN O TO N . D .C . BRUSSELS BUDAPEST LONDON PRAGUE WARSAW y_X&^TELEC.QEIR Paul E. Merrell, Esq. Bradley 6 Merrell c/o Jones, Jones, Close & Brown, chartered 700 Bank of America Plaza 300 South Fourth Street, Suite 700 Las Vegas, Nevada 89101-6026 Re: Nevada Power/Monsanto reading Dear Paul: Attached please find pages 192, 193, 197 and 198 from Mr. Bickerstaff1s April 23, 1992 deposition. Very truly yours, KLC:ap Attachments Konrad L. Cailteux KYFS07...:\58\807$\0100\6K\LTR72193.K10 JUL-21-1993 09:40 FROM UEIL GOTSHAL & MRNGES TO d.h. P.03- Bickerataf - direct 192 1 A. B o .- What would happen was 2 there would just be a charge from budget 3 to budget so that somebody from 4 Bloomfield we'll say attending a course 5 would just fill out the form and put his 6 budget number down. 7 Q . And then the Bloomfield plant 8 would be billed by industrial hygiene? 9 A Yes, correct * 10 Q, Was there any requirements 11 concerning attendance at these courses? 12 a . There wasn't a requirement, it 13 was highly recommended that they attend* 14 Q. And who was It recommended 15 would attend? 16 A. The manager of industrial 17 hygiene and safety, work and human 18 resources that they reported to. 1 19 g Were these courses offered on 20 an annual basis? 21 A. 8 0 me of them were, other onea 22 were maybe offered just as a special, 2 3 maybe on radiation. it might not be 24 offered again for another three years. 25 Q. Were any of the coursee JLIL-21-1993 09:40 FROM gIL_ GOTSHPL & MANGES I TO p 04- BickaritAf - direct 193 1 offered on anythin? more frequent than 2 an annual basis? 3 A . z can't remember anymore 4 frequent than annual. 5 Q . The second page of the 6 document is "engineering and hazard 7 evaluation for materials used in 8 manufacturing.H The course description# 9 which is the third paragraph on the left 10 margin states that the course will 11 describe the organization of the 12 Corporate Standards department, their 13 westinghouse contacts and the purpose 14 and function of their basic material 15 parts and service codes. was that 16 another department# the Corporate 17 Standards Department within corporate 18 headquarters? 19 A. That was a department that wae 20 physically located at the science and 21 technology center# corporate standards. 22 Z believe they reported to the science. 23 and technology center# which in turn 24 reported to the headquarters. 25 q . Now# was this a course that JUL 21-1993 09:41 FROM JgIL GOTSHfiL 8. MRNGES TO P.05 Bickerstaff - direct 197 1 your corporate division. 2 A * Correct. 3 Q. And then the question of 4 whether or not the subjects discussed at 5 the meeting mad it to the corporate $ level would remain at the plant level in 7 the first Instance and then if it 8 reached a division level would remain at 9 the division level? 10 a . it would. 11 Q, Mere there anyprocesses or 12 procedures that you were aware of where 13 the information would pass directly to 14 corporate? 15 A. No. 16 MR. COKSN: Let us mark ae 17 Exhibit 18 a one-page document bearing 18 Bates stamp number 003 105836. 19 (Memo dated 10/25/74 is 20 marked as Exhibit Blckerstaff 18 for 21 Zdentification.) 22 Qi Sir, this documentr have you 23 ever seen it before with the exception 24 of preparing for your deposition? 2 5 A . No, I haven't. JUL-21-1993 09:41 FROM LgIL GOTSHAL & MANGES TO -.k P.06 Biclcarstaff - direct 198 1 Q.. Thm document raflacti three 2 reports of mercury vapor levels In an 3 area of the Bloomfield plant in excess 4 of permitted levels, and states that the 5 higher than permitted mercury vapor 6 level would be viewed by the Bureau of 7 Engineering and Safety as evidence of 8 our Inability to control employee 9 exposure. We will be re-cited, given 10 time to get in compliance and possibly 11 fined. 12 was the Bureau of Engineering 13 and Safety part of Westinghouse or 14 something external to Westinghouse? 15 A. I thin* it says New Jersey 15 Department of Labor, Bureau of 17 q . Up above* Perhaps you're 18 correct 19 A. Here in New Jersey the 20 Department of Labor 21 q . In the first paragraph? 22 A . Yes. 23 Q . Fine. The second paragraph 24 from which I read with regard to the 25 Bureau of Engineering, there is the JU L -2 1 -1 9 9 3 0 9 :3 9 FROM WEIL GGTSHAL 8, MANGES E&. RECEIVED PLEASE SEND: TD .k CO M PLETED 'P .01 IMMEDIATELY ASAP CONVENIENCE FACSIMILE COVER PAGE TO REFERENCE * Weil Gotshal & Manges 767 Fifth Ave., New York, N .Y. 10153 Main Telq>hone Number: (212) 310-8000 Main Fax Number: (212) 310-8007 Telex: 423144 Sender's Fax Number: (212) 310-8516 FROM: Konrad L. Cailteux. Es q . DATE: July 2 1 . 1993______________ ATTORNEY NO.: 1 6 1 4 EXT.: 8 9 0 4 PREPARED BY: A. Pavenick__________ CLIENT/MATTER NAME: CLIENT/MATTER NUMBER: TOTAL PAGES INCLUDING THIS PAGE: _6_ PLEASE DELIVER THE FOLLOWING PAGES TO: flame Facsim ile Number 1. Paul E . M errell. E so . 2. __________ ___ _(702) 384-047-9. 3 . ___________________ 4 . ___________________ 5 . ___________________ 6. ______________ Telephone Num ber (702) 385-4202 COMMENTS: IF YOU DO NOT R EC EIV E LEG IB LE COPIES OF A LL PAGES, PLEA SE C A LL: (212) 310-8888 TRANSMITTED B Y :__________ ]_______________ O N :___________________ A T :________________ M. CONFIRMED B Y : ______________________ O N :__________________ A T :_______________ .M. COMMENTS:_____________________________________________________________________________________ The Information contained in this facsimile sees9 Is confidential information intended only for use of the individual or entity n a n d above. If the reader of this aessase is not the Intended recipient, or the eaployee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strietfy prohibited. If you .have received this c o M u n teat ion in error, please M e d i a t e l y notify us by telephone, and return the original maaaage to us at the cbove address via the U.S. Postal Service. Thanh you. FORM d-MIS-teV' 9/91