Document EdeoMYg3kk60KeGv1YRRraN6b

Hicks, el al. v. ACandS, Inc., et al. 6/1/01 - Paul L. LeCour Page U6 Page 148 l' 2 3 4 5. 6 7 8 9 10 ' II 12 13 14 15 16 17 18 19 20 21 22 23 24 25 after it's being taken off the vehicle and been used? A. No. MR. RILEY: He answered that. He gave you the answer. Q. (By Mr. Dumler) I'm not talking about the interim steps. I'm talking about MR. RILEY: He's telling you where the dust is created. Q. (By Mr. Dumler) Just so we're clear, the asbestos content or the time period where the burn occurs is after the product and the core is coming back after being used, correct? A. Yes. Q. Then it goes through whatever machinations it goes through and is put into the burner room, correct? . A. No. It's in the burner room already. Q. Okay. . MR. RILEY: All right. Describe for him, when the truck backs up to Rayloc and the barrels come off, how does it get from there to the point where this measurement occurred? THE WITNESS: All right, It is checked in on a receiving belt. After the receiving belt. it's put onto a cart. It is taken into the storage area. Then the orders are pulled, as t this document lor me. if you can, Exhibit No. 32. 2 A. Okay. Tliij is Travelers, Travelers Company, 3 May 30th, 1989, Mr. Art Catlin, who is general manager 4 ' of our Payson, Utah, facility. S Q. This is a different facility; is that correct? .6 A. Yes, it is. 7 ,Q. Are you familiar with this report? 8 A. Not this particular report. 9 Q. Was it ever brought to your attention that the 10 testing dune on that facility exceeded recommended It levels ofusbesios exposure? 12 A. No, not to my knowledge. 13 (Plaintiffs'Exhibil LeCour 33 was marked.) 14 Q. (By Mr. Dumler) Next I'm going to hand you .15 Exhibit No. 33 - it's a report done in 1991 by 16 Travelers - and ask you if you can identify that 17 document for me? 18 A. This is an engineering report. It says, 19 Genuine Parts Company, Rayloc Division, Hancock, 20 Maryland, Industrial Hygiene Evaluation. It's prepared 21 by Travelers, or The Travelers. It is to a David W. 22 Classman, Control Engineering. It looked like they 23 performed if. Eimrunmciifaf Service Unit, they worked 24 for Travelers. 25 . Q. Did you receive notification of this report Page 14? . Page 149 ' 1 far as going now to the storage area and 2 saying, I need this barrel of brake shoes. 3 Those brake shoes are pulled. 4 They are brought to the bum area. They 5 are then processed in this burner with the .6 1800 degrees Fahrenheit. 7 And when they come out of the burner, then 8 .the friction material is removed off of the 9 lining -- excuse me -- off of the table of the 10 brake shoe. That is where the problem was, 11 because the resins had been baked out of the 12 lining. 13 ' Q. (By Mr. Dumler) So after it went through the 14 baking process 15- A. Burning. 16 Q. - burning process, there were still asbestos 17 fibers left that were exceeding permissible levels; 18 is that correct? 19 MR. RILEY: Object to the form of the 20 question. After the resins were baked out. 21 that's why there were fibers. 22 THE WITNESS: Yes. 23 MR. DUMLER: Okay. 24 (Plaintiffs' Exhibit LeCour 32 was marked.) 25 Q. (By Mr. Dumler) Let me have you identify 1 when it occulted? 2 A. No, 1 did not. 3.' Q. The report indicates that the exposure to 4 asbestos fibers for the chopper operator exceeded 5 50 percent of the action level. What exactly is the 6 chopper operator doing? 7 A. That is to remove riveted brake lining from 8 the brake shoe, which would be similar to (he one 1 just 9 told you about on the debonding of. 10 Q. How is the chopper's position different than It the burner? ' 12 A. It's located basically in the same area, but 13 it's a different procedure done to a riveted shoe than 14 it tvas done to the bonded shoe to remove the friction 15 material. 16 Q. So explain to mo what the chopper does as 17 opposed to the burner. IS A. Okay. The burner basically burns the linings. 19 Everything goes through there to remove the grease, 20 okay. 21 Then when the shoe com.es oTr, if it's bonded, 22 then it removes. You pick it up, and you separate the 23 two, the shoe and the table.' 24 The riveted has to go over to the chopping 25\ area. And it actually is a blade that goes in and 3$ (Pages 146 io 149) . WHEELER REPORTING COMPANY. INC.;;404-3S|.4577 '