Document Rjk635aq6jo72ROOBq8YZYxXE

BRADLEY & MERRELL JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank of America Plaza 300 South Fourth Street Las Vegas, Nevada 89101-6026 (702) 385-4202 MESSAGE FROM XEROX 7024: (7021 385-1655 DATE: f / v / / 73 . TO: David E. Schalk, Esq. c/o Hilton Hotel FAX#: (412) 594-5161 PHONE #: (412) 391-4600 FROM: Bradley & Merrell CLIENT/MATTER: Nevada Power v. Monsanto CLIENT/MATTER NO.: 11927.2 DOCUMENT(S) DESCRIPTION: iCs sr cLd'PrP NUMBER OF PAGES (including cover page): ^v ^) MESSAGE: THIS TELECOPY IS INTENDED ONLY FORTHE ADDRESSEE NAMED ABOVE. IT MAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL IF YOU HAVE RECEIVED THE TELECOPY IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE. DESTROY ALL COPIES, AND DO NOT DISSEMINATE THE INFORMATION TO ANYONE. THANK YOU FOR YOUR ASSISTANCE. IF YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, please call (702) 385-4202 and ask for: Operator, Ext. 615 B R A D L E Y Sc M O R R E L L JONES, JONES, CLOSE S c BROWN, CHARTERED Sovonih Floor -- Bank of An*rlc Plozo 300 South Fourth Street Lao VAgaa, Nevade B9101-6026 (702) 385-4-202 M ESSA G E FROM X E R O X 70 24 : (702) 38B-1 655 DATE: __________~/X- ___________ TO: David E. Schelk, Esq. 0 / 0 Milton Hotel FAX Jtr: RHONE t f z FROM: Bradlav & Merreli CLIENT/MATTER: Nevada Power v . Monsanto CUEN T/M ATTER NO.r 1I 927-2 DOCUMENT<S) DESCRIPTION: 2* T NUMBER OF PAGES (Including covar page): MESSAGE: (412) 994-0161 (412) 391-4600 <rs') THlfiTELEGOPV MMTEMDCD ONLY FO RTH ! A D O VtB M Il N A lW D ABOV1. IX MAY CONTAIN INFORMATION THAT M H W ILW X D AMD uN riD EN TIAL. IF YO U HAVK REGUVED THE TELECOPY M ERROR. PLEAAI NOTIFY UR iM M gfllATELY flY TELEPHONE. DESTROY ALL C O F U . AND DO NOT U SO EM lN A tC THE WYORMATI OH TO AN YO N E THANK YO U POH VOUA AAA1ATANOL IF YOU EXPERIENCE PROBLEMS WITH TMIS TRANSMISSION, please call (702) 385--4 2 0 2 and aak for: Operator, Ext. 61 5 TRANSMISSION REPORT THIS DOCUMENT WAS CONFIRMED (REDUCED SAMPLE ABOVE - SEE DETAILS BELOW) ** COUNT ** TOTAL PAGES SCANNED : 5 TOTAL PAGES CONFIRMED : 5 *** SEND *** No. REMOTE STATION START TIME DURATION #PAGES MODE RESULTS 1 314-12594-5161 7-21-83 10:00AM 1 '27" 5/ 5 EC COMPLETED 9600 TOTAL 0:01 '*21" 5 NOTE : No. OPERATION NUMBER 48 4800BPS SELECTED EC ERROR CORRECT G2 G2 COMMUNICATION PD POLLED BY REMOTE SP STORE & FORWARD RI RELAY INITIATE RS RELAY STATION MB SEND TO MAILBOX PG POLLING A REMOTE MP MULTI--POLLING RM RECEIVE TO MEMORY JUL-21-1993 09:40 FROM WEIL GOTSHAL & MANGES C: TO P.03 Bickerstaff - direct 193 1 A. 5 0 / 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* 19 Q Were these courses offered on 20 an annual basis? 21 A. Some of them were# other ones 22 were maybe offered Just as a special# 23 maybe on radiation. It might not be 24 offered again for another three years. 25 Q . Were any of the courses JUL-21-1993 09:40 FROM UEIL GOTSHAL & MANGES ! TO P.04 Biekarstaff - direct 193 1 ottered on anything more frequent than 2 an annual basis? 3 k 2 can't remember anymore 4 frequent than annual. 5 0 - The second page of the 6 document is "engineering and hazard 7 evaluation for materials used In 8 manufacturing." 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 weztinghouse contacts and the purpoee 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 w n 20 physically located at the science and 21 technology center, corporate standards. 22 X believe they reported to the science. 23 and technology center, which in turn 24 reported to the headquarters. 25 Q . Wow, was this a course that .JUL-21-1993 09:41 FROM UEIL GOTSHAL & MANGES 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 made it to the corporate 6 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. Were there any processes or 12 procedures that you were aware of where 13 the information would pass directly to 14 corporate? 15 A. No. 16 MR. COHEN: Let us mark as 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 Bicksrstaff 18 for 21 Identification.) 22 Q, Sir, this document, have you 23 ever seen it before with the exception 24 of preparing for your deposition? 25 A. No, X haven't. JUL-21-1993 09=41 FROM UIEIL GOTSHAL & MANGES TO 2 .G3\ 1 P.0S Bickerstaff - direct 198 1 Q .. Ther document reflects 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. 0 12 Was the Bureau of Engineering 13 and Safety part of Westinghouse or 14 something external to Westinghouse? 15 A. I think it says New Jersey 16 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 . Zn the first paragraph? 22 A . Yes 23 Q . Fine. The second paragraph 24 from which X read with regard to the 25 Bureau of Engineering, there is the