Document MGMbO0DVr2bmyDMOJ5yzJnbYj

NEW YORK WASHINGTON ALBANY BOSTON DENVER HARRISBURG HARTFORD JACKSONVILLE LeBoeuf, Lamb, Greene & MacRae A PARTNERSHIP INCLUOtNG PROFESSIONAL CORPORATIONS 601 Grant Street Pittsburgh, PA 15219-1819 (4IZI 594*2300 FACSIMILE: 1412) 594*5237 WRITER'S OIRECT DIAL: 412-594-2330 May 17, 1994 William Rutzick, Esquire Schroeter, Goldmark & Bender 500 Central Building 810 Third Avenue Seattle, WA 98104 V LOS ANGELES NEWARK PITTSBURGH SALT LAKFCITY SAN FRANCISCO BRUSSELS LONDON MOSCOW PLAINTIFF'S EXHIBIT - 4l-620 Re: Newberg v. Fiberboard Corp. et al. Dear Mr. Rutzick: As you know, this firm represents the Aluminum Company of America (hereinafter "Alcoa"). This letter and the enclosed documents constitutes Alcoa's response to the 30(b)(6) notice of deposition transmitted to "General Counsel, Aluminum Company of America" by your letter dated April 4, 1994. With respect to Paragraph 1,1 enclose copies of the employment records of Hubert Wright. As I have informed you orally on the telephone, Alcoa also has in its possession x-rays taken of Mr. Wright during his employment. You informed me that you did not want to go through the expense of having these x-rays copied. Therefore, those Rims have not been duplicated nor will they be produced. With respect to Paragraph 2,1 have included copies of records that provide a basis for inferring what products were on-site at the Vancouver plant. There are very few documents that I can find after a reasonable search. The Purchasing Department's document retention program caused purchase orders and other contracts to be discarded or otherwise destroyed after seven years. Moreover, the property-related records that we do have are comprised mainly of specifications that do not show what product was actually purchased or used on the property. ALCOA0002285 William Rutzick May 17,1994 Page 2 With respect to Paragraph 3,1 have been unable to find anyone who can testify as is requested in the Notice. However, I am informed that the facility was substantially shut down in the early 1980s and sold in 1985, at which time Alcoa transferred many documents to the new owners and destroyed others. I have continued to make calls to former Alcoa employees in an effort to locate the information that you are seeking. If I locate such a witness, I will be sure to give you a call. Very truly yours, i ALCOA0002286 William Rutzick May 17, 1994 Page 3 bcc: Kathleen Garvin ALCOA0002287 <=jfys As C. /<?* <J<s*j<L J?7 /<2>: /Js&i7os //s/hz /2 A'dT- A f^S/Z37~os ey^MO> ydJ #s / Ss <3q)(IuGc(& 6*<S7~*4-- / *? 7J? /,- *j&s #*&& 'A'UL. <Z. . 7*l& /0-Q*jT ca-SAS *JC.oT a^.AaJ7 J. /3*s Ajr& ~SMeflu's **-< f?+rL spn&r*H- 7~&/lAjsttt 77106/M M* i. /3&&CZ7&S- /P/T-f&L c/S<2A fJ/2u<-,*r ptSfUfJ 4 CjSS. A<UJ) OaJ /^LjOuJ <-0JCj.S, >3: ^LjL2t,tL,)TjOKl . 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ALCOA0002289 FROM EGBERT ?. CARTER INDUSTRIAL HYGIENE DIVISION PITTSBURGH OFFICE TO INDUSTRIAL HYGIENISTS August 21, 1972 RE: ASBESTOS-CONTAINING REFRACTORY AND INSULATING MATERIALS USED IN FURNACE AND CASTING EQUIPMENT CONSTRUCTION___________ __________ ____________ Rex: R.P. Career's letter dated 12/25/71 Re: Emergency Standard, for Exposure to Asbestos Dust. G.H. Farra'n's letter dated U/17/72 Re: Asbestos Dust Exposures, Because of the very stringent standard which has been established by OSHA for worker exposures to airborne asbestos fibers, we have received several inquiries for information as to which materials used in Alcoa operations contain asbestos so that the use of these materials can be surveyed for our conforming fully with the provisions of this standard. The list below includes, to the best of our knowledge, all asbestos-containing materials used in our furnace, smelting pot and casting equipment construction. We have not made any attempt to include here the asbestos-containing materials which are used for pipe lagging and other forms of insulation in general construction. Material Superex Insulation Marinate CEB Asbestos Asbestos Millboard or Paper (.Note: May be supplied by Rubberoid or other supplier) Kaylo (.Calcium silicate-asbestos combination) Translte Asbestos Tape Asbestos Content 8% 25-5C# 100J 5056 or more 10-15/6 25-50^ 80-9956 For your farther information, we are presently making a survey of refractory and insulating materials for free silica content which will be forwarded to you when obtained for your guidance in proper application of the OSHA standard for worker exposures to silica dusts. It will probably be six to eight weeks before this information has been obtained and compiled for transmitting to you. If we can be of any further assistance in this matter, please do not hesitate to contact Mr. G.H. Farrah on matters relating to the sampling and test methods and either Mr. T.B. Bonney or the writer on other matters related to this asbestos standard. Of course, Mr. V.W. Rieke and the Environmental Engineering Division will be actively involved in our engineering control efforts with respect to worxer exposures to asbestos fibers and their assistance should be fully utilized in this area. Robert P. Carter RPC:mh ALCOA ALCOA0002290 Industrial Hygienists August 21, 1972 Page 2 co: 7.W. Rieke, Pittsburgh - 2 G.H. Farrah/J.M. Plunkett - ATC H.M. Short, Pittsburgh - 7 0 P M.J. Caprio, Pittsburgh - 19 Info copies to: F.C. Irving, Jr., Pittsburgh - 29 J.C. Bates, Pittsburgh - 22 R.S. Adams/R. Kohler, Alcas Cutlery Co. F.D. Koran/E.A. Moats, Tlfton Aluminum Co., Inc. A.P. LeClair, Jr./J.A. Elliott, H C Products Co. J.L. McKinley/R.B. Kempton/M.L. Bookout, Rea Magnet Wire Co., Inc. R.F. Butler/D. Trudel, Permanent Mold Div., Cleveland Works J.W. Anderson, ABP, Inc. A.C. Sheldon/W.J. Koopman, ACPC, Allegheny Center J.W. Warnock, ACPC, Marshall Works J.S, Hamilton/J.J. Thimons, Wear-Ever Aluminum, Inc. R.C. Wilson, LeFiell Sport Products, Inc. D.D. Rhoads/W.A. Coward, Lincoln Manufacturing Co., Inc. R.C. Dean, Frigidome Division ALCOAO 002291 ALCOA CONDUCTOR PRODUCTS COMPANY Otv. Aluminum Comp.i'*v o< m#fca - *''mco<ivik Business U<*t P. O. SOX 9801 VANCOUVER. WASHINGTON 98CG6 (206) 699-4540 ALCOA March 17, 1987 Department of Ecology MS/PV-11 Olympia, Washington 98504 Attention: Mr. Ted Mix Dear Mr. Mix: This is formal notification that we plan to remove building 410A which is located at our Vancouver Operations. This building is approximately 12 feet square, was built in 1949, was used for housing fuel oil pumping equipment and piping. Some of the piping in this building is insulated with asbestos material, approximately 50 lineal feet, which will be removed by our contractor, Crosby and Overton, Incorporated. The contractor will use a combination of glove bag and wet spray techniques for this removal project. The asbestos will be disposed of in the Circle C landfill in Richfield Washington. Removal is scheduled to begin March 23, 1987 and will be completed in approximately two (2) working days. ALCOA0002292 -:* L. L. HAISCH VANCOUVER OPERATIONS MEMORANDUM May 3, 1972 FILE RE: INDUSTRIAL HYGIENE INSPECTION There are several areas where asbestos is being used. These areas are to be monitored to see if work areas are in compliance with any promulgated OSHA standards referring to asbestos. No remarks made about potroom area, nor anodizing mill. A list of specific check points need to be setup for anodizing. These will probably appear on next inspection report. The carbon plant and rodding room still use the old salamander type oil heaters near areas where men need heat. These produce unburned hydrocarbons which discharge into work areas. In cleaning machine area of carbon plant one of these heaters was operating very close to a cardboard wind break. This was a potential fire hazard. L. L. HAISCH LLH:br Attachments cc: Mr. T. B. Bunney - Pittsburgh Dr. F. J. O'Hara/J. H. Stahl Mr. P. F. Woodward copy routed to : R. W. Anderson E. T. Vanderheyden a ALCOA <v ALCOA0002293 frezsooovoDaY :q M15 & o r**% Sroo> S6S2000VOD7V l* iX a A p r i l 20 6. 2 5 , 1972 i 3 ) :o iC-tj *I .!SJ> iyS, jop 9622000VOD1Y Nj 7> N 4 3 N k <c 1 i i Mo f2 O ruos ioi A63ZOOOVODnV