Document XzjvZzJ9Qje8VG8rkLXxKXVbJ

FILE NAME DuPont DUP DATE 2014 Nov 18 DOC DUP303 DOCUMENT DESCRIPTION Legal - Deposition of Raymond Anderson Vol 1 Raymond Anderson Volume I November 18 2014 Page 1 1 VOLUME I 2 3 PAGES 1-126 EXHIBITS 1-15 DOCKET NO 13-6037910S 4 : SUPERIOR COURT 5 MICHAEL TASKA : : J.D. OF FAIRFIELD 6 VS. : : 7 ACMAT CORP et al : AT BRIDGEPORT : 8 9 10 11 12 Videotaped deposition of Raymond Anderson 13 Tuesday November 18 2014 14 Murtha Cullina LLP 29th 185 Asylum Street Floor 15 Hartford Connecticut 10:17 a.m. - 2:25 p.m. 16 17 18 19 20 21 ------------- Sharon Roy RPR LSR 426 Post Office Box 382 23 Hopedale Massachusetts 01747 508.478.9795 Fax 508.478.0595 24 www.eppleycourtreporting.com 1 INDEX 2 EXAMINATION 3 4 By Mr. Kenney DelMonico 5 By Ms. DelMonico 6 7 PAGE 5 124 8 EXHIBITS PAGE 9 1 Notice of Videotaped Deposition Sporting Goods Properties Inc. .......sccessereeees 8 10 ' 2 Notice of Videotaped Deposition DuPont ....... 8 11 . 3 Front page and pages 170-174 of Popular 12 Science Monthly October 1951 ............... 27 : 13 4 Google Earth aerial view picture ...... 30 14 5 Picture of enlarged cross section of gauge shotgun shell 15 . sce ssntecetetere 33 6 Defendant Sporting Goods Properties Inc.'s 16 Responses and Objections to Plaintiff Michael Taska's Interrogatories and Requests for Production 17 ............ 18 7 Layout entitled Former Structures Plan . 51 . 19 8 2/26/86 document titled Manufacturing Areas at the Barnum Avenue Site with Environmental 20 Hazard Potential Past and Present . 56 9 with Manvil e 22 documents 10 Inspection Questionnaire .................. 78 23 24 Page 3 2 APPEARANCES 3 Representing the Plaintiff 4 Brian P. Kenney Esq Early Lucarelli Sweeney Sweeney & Meisenkothen LLC 5 265 Church Street 11th Floor New Haven CT 06508 6 203.777.7799 Fax 203.785.1671 7 bkenney@elslaw.com 8 Representing Remington Arms 9 Jennifer Morgan DelMonico Esq Murtha Cullina 10 265 Church Street 9th Floor New Haven CT 06510 11 203.772.7735_ 203.772.7723 jdelmonico@murthalaw.com 12 13 Representing General Electric 14 Dan E. LaBelle Esq Halloran & Sage LLP 15 315 Post Road West Westport CT 06880 16 203.227.2855 Fax 203.227.6992 labelle@halloran-sage.com 17 18 Appearing by phone 19 Christopher Howe Esq Campbell Campbell Edwards & Conroy 20 One Constitution Plaza Boston MA 02129 21 617.241.3000 Fax 617.241.5115 chowe@campbell-trial-lawyers.com 22 23 Also present Greg Jacques Videographer Geomatrix Productions Page 2 Page 4 1 11 Document entitled Chemical Market Output Analysis of Selected Chemical Substances to 2 Assess Sources of Environmental Contamination Task III Asbestos oo... 83 3 . Manifest 12 Hazardous Waste Manifest ......00..00000000... 90 4 . 13 Google Earth aerial view ........0.0.0..05 95 5 . 14 Photocopy of photograph ........... 122 6 : 15 Photocopy of photograph ............ 123 7 Original exhibits with Original exhibits 8 returned to Attorney Kenney with copies distributed to counsel 9 10 a 11 12 13 14 15 16 17 18 19 20 21 22 23 24 EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 5 Page 7 1 1 any companies PROCEEDINGS fl 10:17 a.m. 2 A. I did a little bit of consulting for my 3 company that I retired from for a couple months but 4 that was it 3 5 Q. Now have you ever given a deposition in an 4 THE VIDEOGRAPHER We are now on lawsuit 6 asbestos lawsuit before This deposition 5 record at 10:17 This is the deposition of 7 A. No. 6 Raymond Anderson recorded on November 18 2014 8 Q. Have you ever testified on behalf of DuPont 7 in Hartford Connecticut This deposition is 8 being taken in the case of Michael Taska 9 prior to today 9 versus ACMAT Corporation et al and was 10 A. No. 10 noticed by the Plaintiff 11 Q. And same question have you ever testified 11 My name's Greg Jacques videotape 12 on behalf of Sporting Goods Property Inc. prior to 12 operator of Geometrix Productions 270 13 today 13 Amityroad New Haven Connecticut 14 Please state the stipulations 15 MR KENNEY Good morning this is 16 Brian Kenney We're going to go by the usual 9 all objections except as 17 stipulations And most important for today being that to form are reserved until the time of trial 8 MS DELMONICO That's correct 2 THE VIDEOGRAPHER Could you state 2 your name 8 MS DELMONICO Yes Jennifer 2 DelMonico 14 A. I was called as an expert witness in a 15 product liability suit but it was settled and I 16 never testified 17 Q. Did that -- 18 A. I had gone through the preparation that 2 was it Did anything with 2 asbestos case have anything to do with ? A. 2 A. No. 3 Q. Did have anything to do with any sort of 3 chemicals Page 6 1 THE VIDEOGRAPHER The witness may 2 be sworn 3 RAYMOND ANDERSON sworn 4 5 EXAMINATION BY MR KENNEY 60 Q. Good morning sir My name is Brian 7 Kenney I'm with the law firm of Early Lucarelli 8 Sweeney & Meisenkothen andI represent the 9 plaintiff Michael Taska in this matter 10 Would you please state your full name for 11 the record 12 A. My name's Raymond Anderson 13 Q. How old are you sir 14 A. Sixty 15 Q. And where do you presently live 16 A. On Lake Road in Eastford Connecticut 17 Q. Are you currently employed * A. No. I'm retired 2 Q. What year did you retire 8 A. 2011 2 Q. Where did you retire from 2 A. Electric Cable Compounds Incorporated 2 Q. After your retirement in 2011 did you do 2 any type of consulting work or anything like that for Page 8 1 A. No. 2 Q. I'm going to go ahead here and mark the 3 Notice of Deposition as Exhibit 1 the Notice of 4 Deposition for Sporting Goods Properties 5 Incorporated Exhibit 2 will be the Notice of 6 Deposition for DuPont Company 7 Exhibits 1 and 2 marked 8 BY MR KENNEY 9 Q. Have you had an opportunity to review 10 either of those depositions prior to today 11 A. You mean this sheet here 12 Q. I'm sorry the Notice of Depositions 13 A. Yes 14 Q. And you understand that this is a 15 deposition of DuPont and Sporting Good Properties 16 Incorporated rather than you Raymond Anderson 17 personally correct 18 A. Yes am 19 Q. It's not your testimony today it's the 20 testimony of DuPont and Sporting Goods Property 21 Inc. correct 22 A. Yes 23 MS DELMONICO I just want to make 24 it clear for the record that Mr. Anderson is EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 9 1 here to testify today only to categories 1 2 1a and 12 of the notices of deposition marked 3 as Exhibits 1 and 2 4 MR KENNEY That's fine I'll make 5 sure that we're on the same page 6 BY MR KENNEY 7 Q. And you understand sir looking at the 8 Notice of Deposition that you've been produced today 9 to talk about items 1 1a and 12 on both of those 10 notices of deposition 11 A. Yes 12 Q. Okay Item 1 would be -- would relate to 13 any and all containing products manufactured 14 and distributed by Remington Arms in Bridgeport 15 correct 16 A. Yes 17 Q. lb sic would be any and all asbestos 18 fiber and asbestos products used at the Remington 19 Arms Facility 20 A. Yes 223 Q. And then Item 12 would be the brand names 223 and trade names and manufacturers names of any 223 and all asbestos or containing products that 22 the defendant has used Page 11 1 yesterday evening Did you have an opportunity to 2 review those documents 3 A. I'm not sure what ones you're talking 4 about 5 Q. Okay Well we'll go and follow up later 6 Did you bring any documents with you to the 7 deposition today 8 A. No. 9 Q. Tell me about your educational background 10 Where did you go to school 11 A. Where would you like me to start at what 12 level 13 Q. Did you grow up here in Connecticut 14 A. Yes I did Most of my life was in 15 Connecticut I went to high school at Fairfield Prep 16 in Fairfield Connecticut 17 Q. All right 18 A. I went for college at Georgia Tech in 19 Atlanta Georgia 9 Q. What degree did you earn 2 A. Bachelor of mechanical engineering 2 Q. What year did you graduate from Georgia 23 Tech 24 A. Well it was supposed to be 1967 but it Page 10 1 A. Yes 2 MS DELMONICO I'd also like to 3 just clarify that there are pending objections 4 to the Notice of Deposition but obviously 5 we're proceeding today subject to those 6 objections 7 BY MR KENNEY 8 Q. Sir are you the most knowledgeable person 9 to testify on behalf of DuPont and Sporting Goods 10 Property Incorporated regarding the items we just 11 discussed 12 A. I believe so I'm the last one left alive 13 I think 14 Q. Okay And do you have an understanding of 15 the allegations that have been brought against DuPont 16 and Sporting Goods Property Inc. in this present 17 case 18 A. Yes 19 Q. What's your understanding 20 A. My understanding is that the plaintiff 2 became ill with an asbestos disease and 22 there's some question as to whether Remington bears 23 any responsibility for that Remington DuPont 24 Q. There were documents produced to me Page 12 1 wound up being 1968 2 Q. 1968. And after you graduated from Georgia 3 Tech did you go on to obtain additional education 4 A. Yes I went to -- I got within three hours 5 of a master's degree in mechanical engineering at the 6 University of Bridgeport 7 Q. Have you ever held any types of 8 certifications at all 9 A. Yes I took the PE exam and I was in the 10 provisional part of that and I forget what they 11 called it 12 Q. And what does PE stand for 13 A. Professional engineer But I didn't pursue 14 that because I didn't really need it for my career 15 Q. So you graduated '68 Did you go 16 directly to the University of Bridgeport upon 17 graduation 18 A. No. It was year if I remember right 19 about a year maybe two before I went back 20 Q. And when did you first start working for 21 Remington Arms 22 A. 1968. March 23 Q. And to be clear when you first started 24 your employment with Remington Arms were you working EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 13 Page 15 1 in Bridgeport 2 A. Yes 1 Barnum Avenue facility 2 A. Ammunition 3 Q. And what year did you retire from Remington 4 Arms or should say leave Remington Arms 5 A. 1986 6 Q. Have you ever had any employment connected with -- withdraw that Have you ever been employed by Sporting 3 Q. And when you talk about product 4 development what specifically were you doing S A. I worked mostly on centerfire which is 6 rifle ammunition but I had some shotshell project as well And a typical project would be a product improvement or product change modification or in Goods Property Inc. some cases new products new calibers new 10 A. Not directly at the time but that's what 10 cartridges new bullet weights things like that 11 Remington became So during my time we were a 11 Q. How long were you a research engineer 12 subsidiary of DuPont 12 approximately 13 Q. Now have you had any related 13 A. Probably two years Then I was a senior 14 experience at Remington that pertains to asbestos at 14 research engineer for two more years At least 15 all 15 Maybe three Then I was a project supervisor 16 A. Yes 16 Q. And when did you become a project 17 Q. Tell me about that 17 supervisor about '73 18 A. Well after my career in -- we started out 18 Right in that ballpark yeah early 70s 2 in the R department at Remington went through 19 Project supervisor 2 various positions there and various projects during 20 2 which I had occasion to work in the plant a 21 2 substantial amount of time And I first became aware 22 Q. hmm All right Then I became a project manager All this 23 that Remington was using asbestos as one of the 32 is in the research department 3 components of base wads for shotgun shells early in 32 Q. And when did you become a project manager Page 14 1 my career probably 1969 or thereabouts And after I 2 finished my career in research I transferred to the 3 production department and I was the -- the title was 4 chief supervisor of the Barnum Avenue production 5 unit So all of the Barnum Avenue production 6 facilities were in my responsibility 7 Q. And maybe it might be best to run down the 8 differejnotb titles that you held and the 9 approximate years if you know -- 10 A. You mean from the beginning 11 Q. Yeah 1968 when you were hired there what 12 did Remington hire you -- 13 A. Okay yeah Not too hard Research 14 engineer 15 Q. That would be your title 16 A. Yes 17 Q. So what would your typical job duties and 18 responsibilities be as a research engineer 19 A. Primarily product development mostly 20 mechanical type things I was not into chemistry 2232 there was a lot of chemistry going on there with the 2232 explosives and so forth but I was a mechanical guy 2232 Q. And at that time in '68 what was 2232 Remington Arms in the business of making at that Page 16 1 A. '75 Maybe 76 2 Q. We're not going to hold you to these exact 3 dates just getting an idea 4 A. Yeah thank you 5 Q. And how long did you hold that position of 6 project manager 7 A. I think it was a couple years 8 Q. Until about 1978 1979 9 A. Yeah Yeah 10 Q. And what or I should say how did your job 11 title change after that if at all 12 A. I was transferred to the -- or I accepted a 13 transfer I should say sounds better that way to 14 the production department and became the chief 15 supervisor of production for the Barnum Avenue 16 production unit 17 Q. And that would be -- would that be 18 production for all of the ammunition that was made at 19 that site 20 A. No. This was - at around this time 21 Remington built another ammunition plant in Roanoke 2 Arkansas and the plan was to move all the ammunition 2 operations to Arkansas but that was quite an I undertaking and took quite some time The centerfire EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 17 1 production line was moved first and that was in the 2 early to mid 70s about the time I transferred to 3 production So my responsibilities were limited to 4 the Barnum Avenue unit which was shotshell production 5 and rimfire production Part of the rimfire production we made the rimfire shells the .22s 7 And then they were moved up to the part to 8 be loaded primed and loaded So it was shotshell 9 and rimfire were my responsibilities 10 Q. And so what are your typical 11 responsibilities at that time 12 A. was the direct supervision for the 13 production staff at Remington which consisted of 14 general foreman foreman and hourly employees who 15 occupied a large number of different positions 16 Q. Are you working on the floor at the 17 facility throughout the day or are you in an office 18 where are you typically 19 A. had an office butI spent a lot of time 20 in the plant as well So it was hands 2232 supervision I would say is the best way to put it 2232 Q. And who was above you 2232 A. The plant manager and -- the production 2232 superintendent was my direct boss and his boss was Page 19 1 this deposition approximately 2 A. Twelve 3 Q. Are you being compensated for your time 4 here today 5 A. Compensated for my travel expenses 6 Q. Can you explain what you did to prepare for T this deposition today 8 A. Sure I had meetings with Jen DelMonico 9 from Murtha Cullina and we had one at my house in 10 Eastford we had one in Bridgeport which doubled as 11 a tour of the Bridgeport facilities which included 12 Barnum Avenue and the park facility We had a 13 session yesterday which involved just the whole 14 activity and procedure here And today 15 THE WITNESS Did I get that right 16 BY MR KENNEY 17 Q. And tell me little bit about the tour 18 that you had of the facility What did that entail 19 A. Well we started out at the park which is 20 another -- that's a separate unit from Barnum Avenue 21 There were -- the Remington plant was divided into 22 production units there was the Barnum Avenue 23 production unit the part production unit and then 24 there was the primer mixers and that sort of stuff Page 18 1 the plant manager 2 Q. Did you have any involvement at all in the 3 eventual phaseout of asbestos from ammunition 4 A. Not directly but it happened during the 5 time that I was there 6 Q. And were you involved at all when you 7 became the chief supervisor of production in dealing 8 with any OSHA requirement or any type of state or 9 federal regulations 10 A. Well all those things fell -- well I 11 shouldn't say all of them The OSHA things fell 12 under our safety program which was quite extensive 13 and the environmental things were handled by a 14 separate environmental person who was also under the 15 safety umbrella but I didn't have much to do with 16 the environmental things 17 Q. Do you know who that environmental person 18 was at the time 19 A. I don't recall his name right now It was 20 a gentleman who was also in the -- he was also in the 2232 security department Safety and security was the 2232 department that administered the safety program and 2232 the security of the plant Q. How many hours have you spent preparing for Page 20 1 The Barnum Avenue facility we toured 2 second The first part of the tour was the park 3 And we went up into the park area which was as I 4 mentioned the explosives manufacturing and many S years ago it was the centerfire ammunition 6 manufacturing facility And we toured in particular 7 the area where the -- where there was a scrapping 8 operation when I was there back in the day And we 9 generally drove through the park noted the location 10 of certain things including the old administrative 11 offices for Remington which are now owned by other 12 folks Then we came down to the Barnum Avenue 13 facility that was a -- it was a car tour and a 14 walking tour of the park We came down to Barnum 15 Avenue and walked around that -- I think we walked 16 about half of the perimeter noted the sad decline of 17 the buildings and so forth Some of the buildings 18 that come up in these discussions are gone 19 Q. Right 20 A. A big pile of rubble 21 Q. Right And did you note any specific 22 buildings at the Barnum Avenue facility 23 A. We had -- included in the tour was kind of 24 a walking tour and it was quite a memory jolt for me EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 21 Yeah we looked at where we recalled the asbestos operation was and some of the other operations in the shotshell buildings Q. So the park was one site the Barnum Ave. area was another tour you took through the site 6 A. Those were two separate sites they were 7 not contiguous 8 Q. The Remington property's kind of broken up 9 into three parcels of land technically is that 10 true 11 A. Yes I believe so Barnum Avenue the 12 park and the administrative offices on Stratford 13 yeah 14 Q. And what other site -- the park Barnum 15 Avenue and what was the other tour you took 16 A. Well we passed by -- the administrative 17 office building is on a parcel of land which shares a 18 common boundary with the park production land We 19 just looked at those 20 Q. Did you review any specific materials 2 to the Michael Taska case that -- for instance Mr. 2 Taska's deposition or any documents that were 2 produced by the plaintiff 24 A. No. The rest of the tour between Barnum Page 23 records including some related things That's about it Q. How do you define process records A. Process records are directions for how an 5 operation that's performed as part of the production 6 process is performed it includes what equipment is 7 used what safety equipment is used what -- where 8 it's located that kind of stuff 9 Q. Just to kind of circle back to your tour of 10 the park you mentioned that you went around and you 11 identified where some of the scrapping operations 12 were 13 A. hmm 14 Q. What do you mean by that 15 A. Well there was off -- what you call 16 specification product as there is in any 17 operation and that was stored basically in an area 18 in the park that consisted of unloaded shotshells 19 sometimes primed but not loaded And other shotshell 20 components as in shotshell bodies plastic base wads 21 that's about it 23 Q. So Remington Arms has certain 23 specifications that its ammunition needs to meet 24 before it can be sold correct Page 22 1 Avenue and the park we rode around the neighborhood 2 that surrounded the Barnum Avenue facility and 3 visited a couple houses that were apparently involved 4 in this proceeding a couple locations 5 Q. Did you review documents in preparation for 6 this deposition 7 MS DELMONICO I object to the extent you're asking about which documents he reviewed But you may answer the question about whether you reviewed documents A. We did review documents Q. And which documents did you review MS DELMONICO Objection for work product and attorney privilege BY MR KENNEY Q. Well do you know how many the volume of documents that you reviewed in preparation for this deposition A. I wouldn't say that I reviewed them in 20 detail I would say that I looked at them and read 21 some of them Most of them were process documents 22 from Barnum Avenue production there were a number of 23 those There were a couple documents from the DEP 24 inspections of the plant There were process Page 24 1 A. Correct 2 Q. And those -- the ammunition that's made 3 that doesn't meet those specifications are obviously 4 not sold and - 5 A. Not sold possibly reworked depending upon 6 the operation and the problem Or scrapped 7 Q. Reworked or scrapped A. Yes Q. And they were scrapped in the park area 10 A. Yes 11 Q. Do you have an understanding of how many 12 years that scrapping operation took place in that 13 area 14 A. No. I became aware of it when I went to 15 production I had never seen it before that And 16 that was in the early 70s early to mid 70s I 17 would say the first time I saw it And I don't know 18 how long it was operating 29 Q. Did you create any reports or any summaries 29 in preparation for your deposition today 2 A. No. Did I create any 22 Q. Did you yes 23 A. No. 24 Q. Were you given any reports or any summaries EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 25 1 to prepare for your deposition today 2 A. Just what you just gave me here 3 Q. Did you review any deposition transcripts 4 of any DuPont corporate witness or any former 5 Remington Arms employees 6 A. No. 7 Q. Now the Remington Arms plant -- well 8 before we -- if I say Remington you're fine with me 9 just saying Remington instead of Remington Arms 10 A. Yeah sure 11 Q. The Remington plant in Bridgeport that's 12 no longer in operation correct 13 A. That's correct 14 Q. When did that plant shut down 15 A. Well Remington left it in I think the 16 last remnants went in 1986 but there was some follow 17 on to the company that I wanted to be employed by 18 We ran under contract the rimfire making 19 business there because the equipment in that 20 operation was enormous and they didn't have a spot 2 for it at Roanoke yet So we ran that under contract 2 for Remington for the next two years 3 And then when that left which was I 2 don't remember the precise date probably 1988 or 9 Page 27 1 Q. What does that mean 2 A. .22s The priming mix is located in the 3 rim of the shell when the firing pin strikes it it 4 strikes it right on the rim That's a rimfire 5 Q. Lead shot 6 A. Lead shot is the projectiles that used to 7 be loaded into shotshells a lot of it's steel shot 8 now for environmental reasons 9 Q. And you also indicated that this plant also 10 made various types of centerfire bullets 11 A. Yes Well centerfire ammunition 12 completely before they moved to Roanoke Centerfire 13 is rifle ammunition predominantly or pistol and 14 it's characterized by the primer that's struck in the 15 center That's the centerfire 16 Exhibit 3 marked 17 BY MR KENNEY 18 Q. I show you what's been marked as Exhibit 19 No. 3. Exhibit 3 is an excerpt from the Popular 20 Science Monthly magazine from October 1951. Have you 21 ever seen this document before 22 A. No. I've seen Popular Science before 8 Q. Yeah I think we all have 24 A. 25 cents Page 26 1 that was the end of operations at that plant for 2 Remington But the plant itself continued for the 3 RemGrit Corporation which was my follow employer 4 until the RemGrit operation was sold And that was 5 it 6 Q. In fact if you drive by that site today 7 you can still see the RemGrit sign 8 A. Yes 9 Q. Now 10 A. The site was also occupied by businesses 11 that rented some of the buildings but I'm not 12 familiar with how that was done It was a park an 13 industrial park I guess and it was an enterprise 14 zone associated with it 15 Q. What did Remington make between 1964 16 through 1981 at this Barnum Avenue facility 17 A. Shotshell ammunition Rimfire shells 18 Lead shot Various bullets centerfire bullets and 19 rimfire bullets That was it 20 Q. And just if you can maybe kind of help 2 with some definitions for people who are not familiar 2 with firearms or ammunition you mentioned a couple 23 of times rimfire shells A. Yeah Page 28 1 Q. Like I said it's from 1951. But if we 2 take a look at page 2 the article indicates that -- 3 and this is at the bottom of the page it indicates 4 that Remington was making about 1,800,000 shotgun 5 shells a day Do you see that there 6 A. hmm 7 Q. Do you know how many shotgun shells 8 Remington was making per day when you started with 9 the company 10 A. WhenI started at the company 11 Q. Yeah 12 A. No. 13 Q. Does that number 1,800,000 shotgun shells 14 per day seem like an accurate number regarding 15 production 16 MS DELMONICO Object to the form 17 You may answer 18 A. It a seems little high But it's a big 2 number 8 Q. When you were in charge of production in 2 the late 70s did you have an understanding as to 2 how many shotgun shells were manufactured per day at 3 the Barnum Avenue facility A. Roughly yeah EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 29 Q. What is that number A. really don't remember I'd be guessing if I gave you a number But it was -- let me see 4 I'm trying to think of the production rates of the 5 machines 6 Probably more like four or five hundred 7 thousand 8 Q. Okay 9 A. Less than half of what they've got here 10 Q. In 1951 when this article was published 11 do you know whether or not asbestos was used to make 12 shotgun shells 13 A. I don't know I was six years old 14 Q. Based on your experience working with the 15 company do you have any reason to believe that 16 asbestos was not used in the shotgun shells at the 17 time 18 MS DELMONICO Object to form You 19 may answer A. No. No I would say I don't know 2 really 2 BY MR KENNEY 2 Q. On page 3 you can see there's a picture at 3 the top of the page of the shot tower What was the Page 31 BY MR KENNEY Q. Can you take that marker and just identify the Remington site for me 4 A. To the extent of what you have here 5 MS DELMONICO Objection to the 6 extent that you're asking for the entire 7 Remington site on -- 8 THE WITNESS Yeah the entire 9 Remington site is not here 10 BY MR KENNEY 11 Q. Well what's visible in this exhibit 12 A. Your pen doesn't show up The land bounded 13 by Barnum Avenue Seaview Avenue Helen Street and 14 Grant Street that's the Barnum Avenue production 15 unit 16 Q. my fingers can work here I'll try to 17 get a Sharpie out for you It might be a little 18 better 19 A. I think it's the paper 20 Q. Let's try it with a Sharpie that might be 21 little easier the black Sharpie 22 A. Brian would you repeat the question that 23 you asked me about identifying the Barnum -- the 24 Remington site I'm wondering about this over here Page 30 1 purpose of the shot tower 2 A. Manufactured lead shot 3 Q. If you're in the Bridgeport area as you 4 were recently around the old Remington Arms facility 5 that shot tower kind of sticks out as a landmark for 6 the Remington Arms property -- 7 A. sure does Q. - correct A. Yes 10 Exhibit 4 marked 11 BY MR KENNEY 12 Q. I'm going to show you what's been marked as 13 Exhibit 4 which is an aerial view of the Barnum 14 Avenue property 939 Barnum Avenue which was taken 15 from Google Earth 16 Are you able to identify the parcels of 17 property that made up the Remington Arms Company site 18 from looking at this aerial view 19 A. Yes 20 Q. If give you this red pen will you be 21 able to mark the parcels of land owned by Remington 22 MS DELMONICO Owned by Remington A. I don't know about -- 24 MR KENNEY I'll withdraw that Page 32 1 This is part of the Remington site too but it was 2 inactive when I got there 3 Q. What you understand the parcels of property 4 to be related to Remington 5 A. This is it pointing 6 Q. Where you pointed that right there is the 7 main facility A. Yes That's the Barnum Avenue facility The park facility is up here somewhere 10 Q. Now we touched on it a little bit maybe 11 not directly but did the Remington facility 12 manufacture containing products between 13 19 - well between the periods in question in this 14 case between 1964 up through 1982 15 A. I don't know if the -- I don't know what 16 they were making in 1964 because I wasn't there so 17 my knowledge starts in 1968 and '69 for the 18 production operation 2 Q. And when you first started in 1968 were 8 you aware that Remington was making ammunition that 2 contained asbestos when you first started 2 A. Yes 8 Q. Do you know when that operation ended 24 where asbestos was used as a component part of EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 33 1 ammunition 2 A. I don't have a specific date but I 3 would -- in the early 80s 4 Q. We'll get back to that in a minute 5 Exhibit 5 marked 6 BY MR KENNEY 7 Q. I'm going to show you which if can find 8 it I'm going to show you what's been marked as 9 Exhibit 5. It's a cross section of a gauge 10 shotgun shell For people maybe not familiar with 11 ammunition maybe you can kind of explain how 12 Remington Arms designed its shotgun shells and what 13 each component is meant to do 14 A. Do you know what time period we're talking 15 about here 16 Q. Sure This cross section actually came out 17 of the Popular Science article so this would be a 18 cross section of a gauge shotgun from about 1951 2 MS DELMONICO I'll just object to 2 the extent that the shotshell depicted here 2 was from a time period significantly before 2 that at issue in this case but subject to 3 that you may answer 2 MR KENNEY Well I think you Page 35 1 Q. And then this diagram indicates that there 2 was an powder wad do you see that there 3 A. Correct 4 Q. Was that also used when manufacturing 5 shotgun shells during your time period at Remington 6 A. was just kind of reaching the end of its 7 useful life when I got there but yes there were 8 some -- I think the buckshot loads still had fiber 9 10 11 12 13 14 15 16 17 / 19 22 wads in them in the powder wad Q. Do you know when that changed when that was phased out A. Well it started to be phased out before I got there with plastic wads piece plastic wads that would take the place of the other wads that you see here in many loads Some loads that had particular characteristics of loading the arrangement of the shot and so forth which is a result in large part of the size of the shot how it nests and so forth would cause this to maintain the individual wads But for the most part there was what Remington patented as a power piston wad which has petals on it with a wad down below it made of plastic which is polyethylene and the dimensions of that were determined by what the load was how much Page 34 1 know we can use that as an opportunity if 2 there are any differences in the way the shell 3 is designed we can talk about that but I 4 think it might be good to have a diagram to 5 get a better visual as to how Remington made 60 ammunition in this case gauge shotgun 7 shells 8 A. hmm 9 Q. could you tell me about how the design 10 was made It appears here that a gauge shotgun 11 shell had shot pellets 12 A. Yes 13 Q. And what's the shot for 14 A. The shot is the ejecta and if you're 15 hunting that's what you get birds with Or if 16 you're clay target shooting that's what you get the 17 targets with Those are the projectiles 18 Q. Now was felt fiber -- were felt fiber wads 1919 used in the production of shotgun shells when you 20 worked at Remington Arms 2 2 A. Yes 2 2 Q. And in this diagram they're depicted as 2 2 2 and 3 the felt filler wads 224 A. Yes Page 36 1 shot it held what its purpose was what the powder 2 charge was and so on 3 So I would say that this typical 4 construction that you're showing me here was obsolete 5 by the end of the 60s 6 Q. Okay Below the powder wad there's a 7 progressive powder do you see that 8 A. Yes 9 Q. It says it builds up power along the gun 10 barrel until charge has left muzzle 11 A. hmm 12 Q. So is that essentially the gunpowder 13 A. That's gunpowder right 14 Q. And then below that there's a reference 15 to base wad It says a wound strip of 16 paper strengthens head and primer 17 A. hmm 18 Q. Would that have been used in Remington 19 ammunition up through the time period of your 20 employment 21 A. No. It was used -- I don't think there 22 were any paper base wads left when I got there 23 Q. What replaced the paper base wad if you 24 know EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 37 Page 39 1 A. A combination of asbestos and wood flour 1 BY MR KENNEY 2 and wax 3 Q. Okay So when we talk in a few more 4 minutes in more detail about the asbestos components 5 of the shotgun shell would that be located at the 6 bottom portion of the shell right where the number 7 No. 6 is indicated 8 A. Yes 2 Q. I'm going to show you what's been marked as 3 Exhibit 6 and for the record these are the 4 Defendant Sporting Goods Properties Inc.'s Responses 5 and Objections to Plaintiff's Interrogatories and 6 Requests for Production of Documents 7 Have you seen this document before today 8 A. I don't believe so 9 MS DELMONICO Could we take a 10 quick break 11 MR KENNEY Sure 12 THE VIDEOGRAPHER Going off record 13 at 10:58 14 Attorney LaBelle now present 15 THE VIDEOGRAPHER We are back on 16 record at 11:06 17 BY MR KENNEY 9 Q. I'd like to draw your attention to page 3 10 specifically with respect to Question 2 which asks to 11 identify all containing products if any 12 including but not limited to shotgun shells and 13 ammunition shell wadding manufactured at the 14 Remington Arms Company plant in Bridgeport 15 Connecticut between the years 1964 through 1982. Do 16 you see that question there 17 A. hmm I do 18 Q. Mr. Anderson if we can just go back to 18 Q. There's a response below which indicates as 19 Exhibit 5 and can you use this highlighter to 19 follows It says SGPI Sporting Goods Properties 20 indicate where the containing component on a 20 Inc. responds that between 1963 and 1981 it 2222 Remington shotgun shell would be located 21 manufactured at the Barnum Avenue site a component of 2222 MS DELMONICO Same objection as 22 certain types of ammunition referred to as a dry mold 2222 before and that is this shotshell depicted 23 basewad Dry mold basewads contained asbestos as an 2222 in Exhibit 5 is a from a time period other 24 ingredient Page 38 1 than what we're talking about in this case 2 But subject to that you may answer 3 A. So this shotshell that you showed me has a 4 paper base wad 5 Q. Correct 6 A. That's where the asbestos would be in the F next generation of shell 8 Q. Okay So can you highlight the area where 9 that would be located 10 A. It goes all the way around 11 Q. And the basic design the outline of that 12 shotgun shell that's in Exhibit 5 basically remained 13 the same correct throughout the years 14 MS DELMONICO Object to the form 15 You may answer 16 A. remember the paper base wads but I don't 17 remember if all the shells were like that before my 18 time 28 Q. Some components within the shell may have 28 changed throughout the years but the basic shape 22 remained the same 22 A. That's correct The exterior shape was 8 identical 24 Exhibit 6 marked Page 40 1 Do you have any reason to dispute that 2 statement at all 3 A. No. 4 Q. Now we a talked little bit about 5 ammunition and there were different types of 6 ammunition made at this plant Did all the 7 ammunition made at the Remington Arms plant between 8 1963 through 1981 contain asbestos as a component 9 A. No. 10 Q. Certain types of ammunition contained 11 asbestos between 1963 through 1981 is that correct 12 A. Yes 13 Q. Are you able to identify which types of 14 ammunition would have contained asbestos during this 15 time period 16 MS DELMONICO Object to the form 17 and the use of ammunition which is vague 18 and ambiguous 19 But if you understand it you can 20 answer 2232 A. There were numerous specifications of 2232 shotshells that contained a dry molded base wad and 2232 one of the constituents of that mixture was asbestos 2232 Q. And so we talked little bit about EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 41 1 shotshell casings a few minutes ago correct 2 A. hmm Yes 3 Q. Did shotshell casings made at this facility 4 between '64 and '81 contain asbestos to your 5 knowledge 6 A. Some did yes 7 Q. Some did 8 A. Yes 9 Q. What would be the determining factor as to 10 whether asbestos would or would not be used for 11 shotshell casings 12 A. To the best of my knowledge the field 13 loads known as field loads that were hunting loads 14 had the dry molded base wad in them Target loads 15 generally did not Target loads were much lighter 16 than the field loads 17 Q. And what do you mean by field loads 18 A. Field loads are hunting loads They would 9 be used in the field 8 Q. You made reference to I think rimfire 2 shot as well 2 A. Rimfire shell 3 Q. Shell I'm sorry Rimfire shell that was 2 also made at the Remington Arms plant correct Page 43 1 contain asbestos correct 2 MS DELMONICO Objection to the 3 form 4 You may answer if you understand 5 the question 6 A. Yeah I'm a little vague on what you mean 7 Q. Well out of the different types of 8 ammunition made at the Remington plant between 1963 9 and 1981 only certain types of the shotshell 10 ammunition contain asbestos correct 11 A. Yes 12 Q. And the specific shotshell that contained 13 asbestos would be for field loads 14 A. Yes 15 Q. And that essentially means it would be the 16 type of shotgun shell that would be used for hunting 17 A. That's right 18 Q. Do you have an understanding as to what 19 percentage of shotshell was made that incorporated 20 asbestos versus shotshell that did not incorporate 21 asbestos between 1963 through 1981 22 A. don't have a specific number 23 Q. Do you have an approximation 24 MS DELMONICO Objection to the Page 42 1 A. Correct "/ "fl Q. Did rimfire shells made at the Remington 3 plant contain asbestos between 1963 and 1981 4 A. No. 5 Q. You talked about lead shot 6 A. hmm 7 Q. Did any of the lead shot made at the 8 Remington Arms plant between 1963 and 1981 contain 9 asbestos 10 A. No. 11 Q. And then I think we kind of got into 12 another type of ammunition I think you talked about 13 centerfire bullets -- 14 A. Centerfire cartridges 15 Q. --rifle or handgun 16 A. Yes 17 Q. Did any of the ammunition made at the 18 Remington Arms plant intended for rifles or handguns 2 contain asbestos between 1963 and 1981 8 A. No. 2 Q. Okay So the specific type of ammunition 2 that was made at the Remington Arms plant between 3 1963 and 1981 would be shotshells and out of that 2 category only a certain type of shotshell would Page 44 1 form 2 A. No I don't have an approximation 3 Q. Were you about to say something before the 4 objection What were you going to say 5 MS DELMONICO Objection to the 6 form You may answer if you can 7 BY MR KENNEY 8 Q. You can answer the question 9 A. The majority had the asbestos base wad 10 But I don't know what the percentage is 11 Q. The shotshell casing made for hunting was 12 more popular than the shotshell casing that was used 13 for the target practice between the years of 1963 14 through 1981 15 A. Yes 16 Q. Did you have any role in providing 17 responses to the answers in this exhibit 18 A. I don't believe so no 19 Q. The last page the second page on 20 this exhibit there's a verification form and it 21 indicates that the facts stated in the foregoing 22 responses of Sporting Goods Properties Inc. to 23 Plaintiff Michael Taska's interrogatories have been 24 assembled by authorized employees and the attorneys EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 45 Page 47 1 of Sporting Goods Properties Inc. time 2 Do you know who the authorized employees 2 Q. Do you have an understanding as to when 3 were who were consulted in this case 3 Remington began incorporating asbestos in its 4 A. This is the page here 4 shotshells 5 Q. Yeah Look at No. 3 5 A. I don't really know 60 I draw your attention to paragraph 3 there 6 Q. But it's your understanding that there was 7 And it says that the facts stated in the foregoing 7 at least some point in time prior to the 1960s where 8 Responses of Sporting Goods Properties Inc. to 8 asbestos was not used 9 Plaintiff Michael Taska's Interrogatories have been 9 A. Yes there was 10 assembled by authorized employees and the attorneys 10 Q. Do you happen to know the decade if you 11 of Sporting Goods Properties Inc. 11 don't know the exact year 12 Do you see that there 12 A. A decade with regard to what 13 A. Yes 13 Q. With regard to a time period when the 14 Q. Do you have an understanding as to who 14 shotshell made at Remington did not contain asbestos 15 these authorized employees were who helped in 15 A. I don't know for sure 16 answering these interrogatories 16 Q. What's your basis for believing that there 17 MS DELMONICO Objection to the 17 was a period of time prior to the 1960s when 18 form and objection lack of foundation he's 2 already testified he had no involvement with 18 Remington made a shotshell product that did not 19 contain asbestos 20 this 20 A. The shotshells used to have paper base wads 2 Subject to that you may answer if 2 in them like your exhibit here And I don't know 2 you can 2 when that changed but I remember seeing the tooling 8 A. No. 3 for it and so forth when I was there It was 24 Q. Okay may have -- I apologize if I'm 3 obsolete at that time Page 46 1 repeating myself but with respect to the shotshell 2 that we just talked about a few minutes ago -- 3 A. The Popular Science one 4 Q. No just in general the shotshell that we 5 were just talking about that contained asbestos 6 A. Yes 7 Q. You said there was one that contained 8 asbestos and one that did not contain asbestos Was 9 there ever a time when the shotshell ammunition made 10 at Remington always contained asbestos 11 A. No. 12 Q. Was there ever a time when the shotshell 13 ammunition made at Remington did not contain 14 asbestos 15 MS DELMONICO Objection to the 16 form but you may answer 17 A. Can you repeat the question please 18 Q. ask this way Prior to 1964 was 2 there ever a time when all of the shotshell 8 ammunition made at the Barnum Avenue facility did not 2 use asbestos 2 A. There was but I'm not sure of the 3 significance of 1964 in that discussion I don't 3 know whether it was before that or right at that Page 48 1 Q. I want to focus on the shotshell that 2 contained asbestos for my following questions okay 3 A. Okay 4 Q. The component of the shotshell that 5 contained asbestos was called a base wad 6 A. Correct 7 Q. Was that base wad component made on site at 8 the Remington plant 9 A. Yes 10 Q. What ingredients if we can call them 11 ingredients -- 12 A. You can 13 Q. -- went into making this base wad 14 A. There were three ingredients Wax wood 15 flour and asbestos 16 Q. Do you know what the asbestos fiber type 17 was 18 A. I believe it was chrysotile 19 Q. I've reviewed some documents in this case 20 and I've seen some references to a fiber grade of a 21 7T15 Does that ring a bell at all 22 A. No. 23 Q. Also seen a reference to chrysotile 24 with a grade of 17.9 Does that ring a bell EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 49 A. No. 2 Q. You don't know what grades of asbestos were 3 used at the Remington Arms facility 4 A. No. 5 Q. Can you tell me what the process was for 6 making this asbestos containing base wad 7 A. The manufacturing process 8 Q. Yes 9 A. Yes The big summary The ingredients 10 were mixed above the press which is called a dial 11 press a tablet press a pill machine a number of -- 12 it was characterized by a rotary dial with cavities 13 in it The mixture of the ingredients which we just 14 discussed were introduced into the cavities of the 15 dial and as it rotated punches came down into the 16 cavities to establish the height of the base wad 17 The diameter of the base wad was established by the 18 diameter of the cavity 2 And the base wad would be compressed 2 mightily you might say it was a serious operation 2 it was a serious force operation And after the 2 forming operation -- that was the end of the forming 3 operation -- the part would be ejected from the dial 3 and collected and inspected and so on and so forth Page 51 1 between Barnum Avenue and the park 2 Q. When raw asbestos fiber was delivered 3 where was it stored at the facility 4 A. Well it was offloaded in the building the 5 building adjacent to the shot tower as a good 6 landmark and it was stored in one of the adjacent 7 buildings 8 Q. Now if you can pick up Exhibit 6 for a 9 second turn to page 6 10 A. Okay 11 Q. Look at Response 8. It states that 12 Sporting Goods Properties responds that the asbestos 13 fiber used to manufacture dry mold basewads were 14 stored in the area where the dry mold basewads were 15 manufactured in building 43. 16 Do you see that there 17 A. I see 343 18 Q. I'm sorry building 343. Do you agree with 19 that statement 20 A. I don't think that's the correct building 21 but I'm not really sure 22 Exhibit 7 marked 23 BY MR KENNEY 24 Q. I'll show you what's been marked as Exhibit Page 50 Page 52 1 sample inspection 1 7. This is a document that was produced by Sporting 2 Q. What type of capacity did the facility have 2 Goods Properties Incorporated and you can see it's 3 to make these asbestos waddings 3 titled Former Structures Plan 4 A. You mean a numerical capacity 4 Do you see that there 5 Q. Yeah 5 A. Yes 6 A. I don't know off the top of my head But 6 Q. First off have you ever seen this document 7 enough for what was made to load the shotshells that 7 before 8 were on the schedule 8 A. Not this specific one no 9 Q. In what form did the asbestos arrive in at 9 Q. Do you recognize what's depicted there 10 the plant 10 A. Yes 11 A. It was shipped in in bags 11 Q. And what do we see there 12 Q. It was raw asbestos fiber that was in the 12 A. We see the Barnum Avenue production 13 bags 14 A. Yes Yes I believe it is 13 facility of Remington Arms 14 Q. It's kind of tough to read but you can see 15 Q. Do you know how it was delivered to the 15 there are various buildings depicted there with 16 facility 17 A. Yes by truck Palletized on a truck 16 numbers 17 A. Correct 18 Q. Do you know if it was ever delivered by 18 Q. And if you look to the hand side of 19 rail 20 A. No don't Not in my time But I don't 19 the map there you'll see Maple Street 20 A. hmm 7 know about before that 21 Q. And then right across that street there is 28 Q. That Barnum Avenue property abuts the 22 a reference to building 343. Do you see that there 28 railroad though doesn't it 23 A. Yes 2 A. It has a private railroad yes It goes 24 Q. Is that the building that you understand to EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 53 Page 55 1 be building 343 1 or N A. Yes 2 MR KENNEY Yeah it's not a very 3 Q. Now is that where the asbestos fiber was 3 good question 4 -- the asbestos was used to manufacture the dry 4 BY MR KENNEY 5 molds or dry wads 3 Q. When the raw asbestos fiber was delivered 6 A. No I believe it was in building 340 6 where did Remington store this asbestos 7 Q. Okay And if we scroll down go down just 7 A. really don't recall It was in one of 8 a little bit we see 343 and then there's a big 8 these buildings These are all story buildings 9 building below it for 341 9 there's a lot of volume there and there were raw 10 A. hmm 10 material stored in various places But it was stored 11 Q. And it looks as if building 341 -- right close to the operation 12 below that is a building 340 do you see that 13 A. Correct 14 Q. Is that where you understand the operations 15 related to asbestos to have taken place 16 A. That's correct 17 Q. And maybe what we can do if you can get 18 that yellow highlighter and just color in building 2 340 so we can see it Q. So it was stored close or nearby building 14 340 A. Correct 15 Q. Do you know how the raw asbestos fiber got 1616 to building 340 17 A. It was conveyed from the loading 1818 platform which is farther north of there via a 1919 forklift operation type of thing But it was a 2 A. Witness complying 2 Q. I'm going to give you this red to outline 20 ground level forklift it was not a truck with forks 21 that raised It was like a platform I think they 2 it just because that didn't come out very strongly 22 used to call them jetties but I'm not sure 3 If you can outline building 340 that would be 23 So it was manually pulled by the operator 24 helpful 24 and it could raise my best recollection is maybe Page 54 Page 56 1 A. This didn't work before when you gave it to 2 me 3 Q. know it might work a little better on 4 this one 5 A. Yeah that's better 6 Q. So building 340 what went on in there 7 during your time period of employment MS DELMONICO Object to form but go ahead A. That was the dry molded base wad operation manufacturing operation Q. So that's where the asbestos and the wood flour and wax was mixed A. Correct Q. well And that's where the product was punched as 1 four inches off the ground no higher than that And 2 there were no forks on it It was just like a flat 3 platform a rectangular double platform It 4 went underneath the pallet 5 Q. Where on this map is the loading 6 platform 7 A. There were a number of them but the one I believe was probably used was 343 or 345. Down in the northwest corner of the site where the rail 10 lines are there on the side and the driveway 11 Q. So you believe that the loading 12 platform would have been either in building 343 or 13 building 345 14 A. I believe that's right 15 Q. Okay And is that also where the wood 16 flour and wax would be stored A. That's right Q. Where on this map was the raw asbestos -- withdraw that 17 A. Yes 18 Exhibit 8 marked 19 BY MR KENNEY When the raw asbestos fiber was delivered where did it go this map Are you able to identify where on this map it would have been -- MS DELMONICO Objection to the form Are you asking where it was stored 20 Q. I'll show you what's been marked as Exhibit 21 8. Just a take minute to look at that I'm going to 22 get organized myself while you do that 23 Have you had a chance to take a look at 24 this document EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 57 Page 59 A. Not the whole thing but yes Q. Exhibit 8 is a document it appears to be dated February 26 1986 and it's entitled 4 Manufacturing Areas at the Barnum Avenue Site with 5 Environmental Hazard Potential past and present 6 Have you seen this document before today 7 A. I don't believe so 8 Q. I'd like you to turn to page 4 and at the 9 top of the page you'll see there's a reference to 10 building 340-1 Do you see that there 11 A. Yes 12 Q. It says that the quote Colton wad job was 13 located there 14 A. Correct 15 Q. And Pill making machines were used to form 16 asbestos wads from a D.M.B.W. mix . 17 A. Form wads They were used to form wads it 18 says 9 Q. Yes 8 A. hmm 2 Q. What is the -- what is a Colton machine I 2 saw a reference to a Colton machine 3 A. That's the dial machine that I referred to 3 awhile back It's a rotary dial forming machine that's the area where the wood flour and asbestos were blended correct A. Yes 4 Q. Can you walk me through the different steps 5 in the process in terms of -- the process of making 6 this dry molded base wad mix It sounds as if it may 7 have started on a certain floor or floors in building 8 340 and then gone to different areas of the building 9 as the process went on Can you just describe how 10 that process -- what was done in that building or 11 performed in that building 12 MS DELMONICO Objection to the 13 form 14 You may answer 15 A. was a vertical process and it was done 16 in four floors of building 340 starting with the top 17 floor And then there was also work done on in some 18 cases on the mezzanines which were arranged between 19 the floors The mezzanines were maybe a quarter of 20 the space that the main floors had 21 Q. So what operation was started or what 22 operation was conducted on the top floor 23 A. The mixing of the asbestos and the wood 24 flour Page 58 1 which forms components by pressure vertically and -- 2 well from the top and from the bottom 3 Q. Is that separate from a pill making 4 machine 5 A. That pill making machine is a generic term 6 for a machine like the Colton 7 Q. There's reference to D.M.B.W. mix 8 A. hmm 9 Q. Do you know what that stands for 10 A. Dry molded base wad 11 Q. It appears too based on this document 12 that your recollection of building 340 as being the 13 mixing area for this dry molded base wad mix is that 14 correct 15 A. Yes 16 Q. Now if we go little bit further down the 17 page there's a reference to a building 340-4 First 18 off do you know what the different dashes mean We 19 have building 340-4 -- 20 A. They're floors 2 Q. So that would be floor No. 4 23 A. Yes And if there's an M after the number 23 it's a mezzanine 24 Q. So we look at building 340-4 it says Page 60 1 Q. Was that the only operation that was done 2 on the top floor 3 A. Yes 4 Q. And once that operation was complete what 5 happened next in the process 6 A. The mix was sent down to the third floor -- 7 let's see The second floor Okay yeah the second 8 floor mezzanine 340-2M 340-2M 9 Q. And what happened there 10 A. There was wax added to the mix of the 11 asbestos fibers and the wood flour 12 Q. Now at that phase of the operation when 13 the wax was added to the mix what consistency was 14 the product at that time 15 A. It's a little hard to describe but it was 16 basically a dry mixture that had a waxy feel to it 17 You could hold it in your hand and squeeze it and it 18 would agglomerate 19 Q. So after the wax was added to the mix on 20 the second floor what happened next in the process 21 A. The wax wood flour asbestos mix was fed 22 into the Colton machine and the base wads were made 23 Q. Remind me again the Colton machine is 24 that where the mix was compressed EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 61 1 A. Correct It's a rotary dial forming 2 machine 3 Q. And by compressing the mix did that 4 harden the product 5 A. Yes 6 Q. I'm sorry what floor did that take place 7 on 8 A. That was the Colton machine was located on 9 the ground floor 340-1 10 Q. And when that product was compressed it 11 was formed and sized to the right dimensions 12 A. Correct 13 Q. And so the Colton machine essentially took 14 this mix and hardened the product into individual 15 pieces or wads 16 A. It compressed it into pieces into wads 17 Q. Was there any other phase left in the wad 18 making process after that 19 A. Inspect and gauge And weigh it there was 8 a weigh operation All one It was basically an 2 inspection operation Check the weight check the 2 diameter check the height dimensional -- 3 Q. There was a quality control process that 3 went on there Page 63 1 A. For the most part we ran the operation 2 one two shifts rarely three So it had plenty of 3 capacity to load -- I really don't remember the 4 numbers It was a high capacity 5 Q. And the -- 6 A. To match the loading machines basically 7 Q. And the shifts would a shift be an 8 eight shift 9 A. Yes 10 Q. So this process would run two shifts 11 essentially 16 hours per day 12 MS DELMONICO Objection What 13 time period are we talking about 14 BY MR KENNEY 15 Q. During the time you were production 16 manager 17 A. Generally two shifts yeah 18 Q. I didn't ask you this but the facility 19 itself was it a hour operation 20 A. Yes The plant was operating 24 hours but 21 various operations not all of them 28 Q. Sure If we can go back to the aerial 23 shot the exhibit where we had a hard time marking -- 2 A. This one Page 62 1 A. Yes "/ "fl Q. Was there a lag time after the dry wad was 3 made before it was sent to being incorporated into a 4 shotgun shell 5 A. Yes 6 Q. Where was the dry base wad stored during 7 that interim period A. The process storage I believe was also in 340-1 Q. Do you know how the dry base wads were stored A. They were stored in bins Q. Were they stored in open or closed bins A. I don't recall Q. Do you have a memory as to how big these bins were A. My recollection is that they were metal bins and they were about two feet square maybe a foot deep or a little more Q. terms of output do you know -- and maybe this might be a question better asked for your time period as the -- in operations In terms of output do you know how many dry base wads the plant could make in one day Page 64 1 Q. Yeah I don't know if I'm going to have 2 any better luck with these different colors but I'll 3 try I'm going to give you a green marker and if 4 you can can you please identify where the building 5 340 would be located in this aerial map If you can 6 circle it 7 As you can see from the document there are some buildings that are no longer standing A. Right It's right ... a lot of them aren't standing right here Right here Indicating Q. How did that show up on there A. Not very well Q. Let me see I'm going to have to invest in some better markers So you circled in green where you believe building 340 is located- located- A. was trying to coordinate it with Exhibit 7 which is much more readable MayI see the map MS DELMONICO Would you like it back MR KENNEY the witness You can give it back to BY MR KENNEY Q. The loading platforms that we EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 65 discussed do they still exist in the aerial view marked as Exhibit 4 A. No. No. They were in this general area 4 Q. Okay May I see that back please 5 Do you have understanding as to who or what 6 job title -- I'll withdraw that 7 Who would be responsible for the mixing 8 process in building 340 9 MS DELMONICO Objection Object 10 to the form 11 BY MR KENNEY 12 Q. During the time period that asbestos was 13 used 14 A. Who would be responsible for making it or 15 overall responsibility of -- 16 Q. Of overseeing the process 17 A. The foreman 18 Q. The foreman And would there be a foreman 19 devoted to that particular building or operation how 2 does that work 2 A. No. The foremen were spread over the 2 process from a processing standpoint not a building 3 standpoint So one foreman might have a job in 2 building 339 and go all the way up to 343. So it was Page 67 feet deep Q. Do you know how many bags of asbestos fiber would be required for a mixing cycle 4 A. No I don't recall 5 Q. Do you know how the bags of raw asbestos 6 fiber made its way up to the fourth floor 7 A. Yes They were brought up in an elevator 8 on one of these low profile forklifts Forklift is 9 not the right word They're transportation vehicles 10 as opposed to a forklift that everybody understands 11 you ride on and has forks sticking out of them 12 Q. So more than one bag of raw asbestos fiber 13 would have gone up to the fourth floor for the mixing 14 operation 15 A. Yes Yes 16 Q. And who was responsible for mixing the 17 asbestos and wood flour 18 A. An operator Machine operator 19 Q. Do you recall any of the names of the 20 machine operators during your time period of 228 employment 228 A. There was one gentleman whose last name was 228 Simmons butI don't recall his first name and he's 24 the only one I remember There were only two guys on Page 66 1 a foreman whose responsibilities included that 2 portion of the manufacturing process 3 Q. Do you remember any of the names of the 4 foremen who would have responsibilities during your 5 time period of employment for that process 6 A. remember one A gentleman named Rocky Riccio Q. Rocky Riccio A. Rocky Rick Riccio 10 Q. In terms of the actual mixing process in 11 building 340 where the asbestos and the wood flour 12 was mixed how did the actual raw asbestos fiber get 13 placed into the mixer 14 A. The bags were brought up from storage I 15 don't recall where that was and they were placed on 16 a table that was even with the mixing bowl or mixing 17 container and the bag would be sliced open with a 18 knife with a utility knife and urged over the thing 19 and just let it fall in let it just run out of the 20 bag 2 Q. In terms of the actual mixer itself how 23 big was this mixer 23 A. My best of recollection was that it was 24 about three or four feet in diameter and a couple of Page 68 1 that job 2 Q. Was the mixing process a man operation 3 A. Essentially The second guy sometimes 4 would assist or they would overlap on shifts when we S had two shifts scheduled It's essentially a man 6 operation Q. Did that fourth floor in building 340 have more than one mixer A. I don't really recall I only recall one 10 Q. Did the mixer have a specific -- 11 A. Are you talking about the mixer on the 12 fourth floor or the Colton machine 13 Q. The mixer on the fourth floor that mixed 14 the wood flour and asbestos 15 A. There may have been two I only recall 16 one 17 Q. Would you ever throughout your career at 18 Remington would you ever have reason to be in that 19 area while asbestos and wood flour was mixed 20 A. I saw the entire operation whenI first 2 went over this I made it a point to go around and 2 get familiar with all of them But as a general 23 rule no it was a very reliable operation and 2 required very little care EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 69 Page 71 Q. So you may have been over there initially 2 when you were first employed to see what the process 3 was but after that it wasn't really necessary for 4 you to visit that area 5 A. Correct 6 Q. Do you know what the ratio of asbestos to 7 wood flour was for that mix 8 A. Asbestos to wood flour No. What I recall 9 is that the wood flour was the largest percentage 10 ingredient and then the asbestos and then the wax 11 Q. Do you know how long the mixing process 12 took 13 A. Just -- you're talking the blending 14 process 15 Q. Yeah the blending 16 A. No I don't recall how long 17 Q. Now the product itself as it was being 18 blended and as it went down to the Colton machine 9 did it have a certain color 8 A. Yeah it was sort of a brown white 2 Q. A brownish 2 A. With a kind of sheen to it because of the 2 wax 2 Q. Do you know who supplied Remington with raw 1 were but I really don't recall 2 Q. I draw your attention back to the discovery 3 responses 4 A. Which one is that 5 Q. Sporting Goods Properties Inc. Exhibit 6 6 It's on your left there Go to page 5 7 A. Got it 8 Q. In Response 5 which is a response to 9 question asking to identify the suppliers and brokers 10 and distributors of asbestos fiber used in 11 manufacture of containing products Sporting 12 Goods Properties Inc. responds by saying that they 13 have located no information responsive to this 14 interrogatory 15 Did you provide Sporting Goods Properties 16 Inc. with the information regarding the raw asbestos 17 fiber suppliers prior to this deposition 18 MS DELMONICO Objection to the 19 form and to the extent it calls for 20 information protected by the attorney 21 privilege and work product doctrine 22 BY MR KENNEY 23 Q. You can answer 24 A. I can answer Page 70 1 asbestos fiber between 1964 up through 1981 2 A. I believe Johns Manville was the primary 3 supplier 4 Q. And how do you know that 5 A. I remember it on the bags 6 Q. What did the bags of raw asbestos look 7 like 8 A. They were fiber bags I believe they were 9 50 pounds although we had some larger ones at one 10 point in time too but the ones I'm familiar with 11 were 50 pounds or thereabouts And they were about 12 maybe feet long and inches high and a 13 foot wide 14 Q. Somewhere on the bag it said 15 Manville 16 A. Yes Yes 17 Q. Did the bag indicate that it contained 18 asbestos 19 A. I don't recall specifically I think it 20 did but I'm not sure It had a trade name on it of 21 some sort which I don't recall 22 Q. Do you know if any warnings were on those 23 bags of raw asbestos fiber 24 A. really don't recall I imagine there Page 72 1 Q. Yes 2 A. No. 3 Q. Okay Do you know why -- I'll withdraw 4 that 5 So in fact as we sit here today Sporting 6 Goods Properties Inc. and DuPont understand that 7 Manville was the primary supplier of raw 8 asbestos fiber correct 9 MS DELMONICO Objection to the 10 form 11 A. That's my understanding 12 Q. And you're here today testifying on behalf 13 of DuPont and Sporting Goods Properties Inc 14 correct 15 A. Yes hmm 16 Q. So between 1964 through 1981 17 Manville was the primary supplier of raw 18 asbestos fiber to the Remington Arms facility in 19 Bridgeport 20 A. That is my recollection 21 Q. And were there any other suppliers during 22 that time period other than Manville of the raw 23 asbestos fiber 24 A. don't recall EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 73 1 Q. Approximately how much raw asbestos fiber 2 did Remington require per month in order to 3 manufacture containing shotshell between 4 1964 through '81 5 A. I don't know 6 Q. Do you know how much asbestos do you know 7 what quantity of asbestos was being purchased per 8 month during your period of employment with Remington 9 Arms 10 A. No. 11 Exhibit 9 marked 12 BY MR KENNEY 13 Q. I show you what's been marked as Exhibit 9 14 Specifically I'd like you to go six pages into this 15 documents into this exhibit and you'll see that 16 page 6 of this exhibit has a Bates stamp on the 17 bottom hand corner marked RemingtonArms- 18 000004 19 A. I don't see any page numbers on it 20 Q. This exhibit doesn't have page numbers but 2 it has what's called a Bates stamp on the bottom 2 hand -- 2 A. Okay And what page are you looking for 24 Q. It's a Bates stamp that ends in 000004. Do Page 75 1 sentence that begins with Action must be taken -- 2 do you see that there 3 A. Yes 4 Q. And the next sentence states quote We 5 have 40 tons to ship in January do you see that 6 A. see it 7 Q. Does that quantity or amount sound like an 8 accurate amount of raw asbestos fiber that was 9 shipped to Remington Arms during your period of 10 employment when asbestos was used to make shotshells 11 MS DELMONICO Objection to form 12 You may answer 13 A. I don't really recall That would have 14 been a planning function not a production function 15 Q. Who would have been in charge of the 16 planning function at Remington during your period of 17 employment 18 A. James Pavia 19 Q. James Pavia 2 A. hmm 2 Q. This section marked Pertinent Data 2 indicates that the shipment the car had a very bad 3 ride Do you see that there up on the -- 2 A. Yes do very bad shape Page 74 Page 76 1 you see that there 2 A. Got it 3 Q. Just to orient you this particular page 4 on the top of the which page it says Call Report 5 A. Yes 60 Q. To the left it says Manville F A. Yes 8 Q. To the right of the heading it says 9 Asbestos Fibre Division Do you see that there 10 A. Yes 11 Q. And it says Date of Call right below 12 that December 12 1975 13 A. hmm 14 Q. FirstI should ask have you ever seen this 15 document before 16 A. No. 17 Q. Have you ever seen any call reports from 18 Manville 2 A. No. 8 Q. The middle of the page actually it's in 7 the section marked Pertinent Data Do you see that 2 section 3 A. hmm 3 Q. In the middle of that section there's a 1 Q. All units were tilted on the top 3 to 4 2 feet in spite of bags being glued and that there 3 were broken bags all over the car 4 A. hmm 5 Q. In situation like this during your period 6 of employment if a shipment of asbestos arrived 7 damaged whose responsibility would it to be deal 8 with the damaged product 9 A. You mean to relocate it or pick it up or 10 what have you 11 Q. Correct 12 A. It would be supervised by the planning 13 Q. So either James Pavia or someone holding 14 his position 15 A. sorry it's Bob Pavia Robert Pavia 16 not James He was another guy 17 Q. Okay You'll also see here in this 18 document it says RR inspector called in Do you 19 see that 20 A. Yes see it 21 Q. Railroad inspector called in would you 22 agree that's what the statement is 23 A. guess so yeah RR usually means 24 railroad EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 77 Page 79 1 Q. Yeah And you mentioned that there were -- 2 there's a private railroad that went onto the 3 Remington Arms site 4 A. There's a spur yes 5 Q. Do you know -- I'll withdraw that 6 Did those rail -- did that private railroad 7 go as far as the loading platform at the site 8 A. Yes 9 Q. So if ask you how many tons of asbestos 10 was purchased by the Remington facility per month 11 during certain years is it your testimony today that 12 you would not know the answer to that 13 A. That's correct I would not know 14 Q. And if asked you any questions regarding 15 the packaging and the decision as to how to receive 16 the raw asbestos fiber from Manville -- I'll 17 withdraw that 18 If asked you any questions regarding 19 Remington Arms wanting to receive raw asbestos fiber 20 from Manville would it be fair to state that 223 you would not have any idea as to how that occurred 223 MS DELMONICO Object to the form 223 A. Yes 2 1 marked as Exhibit 10. Take a look at this and let me 2 know if you've ever seen this document before 3 A. I don't believe so no 4 Q. Exhibit 10 indicates in the top center of 5 the page that this is a inspection questionnaire 6 A. hmm 7 Q. And there's a date on the top hand 8 side of the document of October 7 1975 9 A. Yes 10 Q. And above it it indicates that we're 11 looking at page 1 of 19 correct 12 A. hmm 13 Q. I'd like you to turn to page 3 of 19 14 A. Okay 15 Q. At the top there you see that there's a 16 little chart with four columns 17 A. hmm 18 Q. And the first column says -- it's tough to 19 read but it says Explicit chemical name or trade 20 name supplier full address Do you see that 21 there 22 A. see it yes 23 Q. And below it it says Asbestos 7T15 24 Canadian J.M. Asbestos Ltd. and then there's an Page 78 1 Q. That was outside of your job duties and 2 responsibilities 3 A. Yes 4 Q. Okay And likewise if I asked you about 5 how much storage capacity that Remington had on site 6 to store raw asbestos fiber you wouldn't know that 7 answer either 8 A. That's correct a MR KENNEY How are you doing in 10 terms of timing 11 I should probably ask you 12 Mr. Anderson how you're doing It's ten 13 after twelve do you want a break do you 14 want a lunch break or what would you -- 15 MS DELMONICO How much longer do 16 you think you have 17 MR KENNEY Probably more than an 18 hour so we're probably going to take a lunch 128 break no matter what Would you prefer to 128 take a lunch break now and come back 21 record discussion 22 Exhibit 10 marked 23 BY MR KENNEY 24 Q. Sir I'm going to show you what's been Page 80 1 address correct 2 A. Yes 3 Q. J.M. stands for Manville 4 A. Yes 5 Q. And in the next column over the heading is 6 " Applications 7 A. hmm 8 Q. Do you see that there 9 A. hmm 10 Q. And below it it says Manufacturing 11 wads 12 A. Yes 13 Q. right And that would be the dry 14 molded base wads that we've been talking about 15 correct 16 A. That's correct 17 Q. The third column again it's hard to read 18 but it appears that it states Consumed Per Week 19 A. hmm 20 Q. And below it it says 15,400 Do you 723 see that there 723 A. do 723 Q. Do you know what that stands for 24 A. assume that's the consumption of this EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 81 1 material per week 2 Q. Do you know in what -- what measurement is 3 that is that a weight is it quantity 4 A. It's pounds 5 Q. It's pounds 6 A. hmm 7 Q. So you understand that to mean 15,400 8 pounds per week 9 A. Yes 10 Q. And then the column to the right the 11 heading is Storage Tank Size 12 A. hmm 13 Q. Do you see that 14 A. Yes 15 Q. And below that it says 100 bags 16 A. pound bags 17 Q. pound bags * A. Yes 2 Q. Okay So we were talking a few minutes 8 ago I think about the raw asbestos fiber bags and 2 you indicated that you recall seeing pound bags 2 and maybe some other bigger bags 8 A. And hundred bags yes 2 Q. Do you know what -- what does storage tank Page 83 1 shell no base wadding 2 Exhibit 11 marked 3 BY MR KENNEY 4 Q. I'm going to show you what's been marked as 5 Exhibit 11 and this is actually an excerpt from an 6 EPA document entitled Chemical Market Output 7 Analysis of Selected Chemical Substances to Assess 8 Sources of Environmental Contamination Task III 9 Asbestos 10 A. hmm 11 Q. Have you ever seen this document before 12 today 13 A. Not that I recall 14 Q. If you turn to page 2 you can see that the 15 document is dated August 1978 16 A. Yes 17 Q. As said this is an excerpt from a larger 18 document but if you can flip the page to page No. 19 276 and let me know when you get there 9 A. Okay I have it 2 Q. At the bottom of the page there's a 22 heading 17.4 Shotgun Shell Base Wads 23 Do you see that there 24 A. Yes Page 82 Page 84 1 size means do you have an understanding as to what 1 Q. states below that Only one shotgun 2 that means that column heading 2 shell manufacturing plant in the United States is 3 A. looks to me like they're using it as the 3 known to use commercial asbestos that plant is 4 container that it comes in 4 located in Bridgeport Connecticut and is operated 5 Q. So during this period in 1975 would you 5 by Remington Arms Company EPA 1974 6 agree that Remington was receiving -- 6 Do you see that there F A. That was right near the end 7 A. Yes 8 Q. Remington was receiving asbestos from 8 Q. Is DuPont and Sporting Goods Properties 9 Manville in a hundred bags 9 Inc.'s position that by 1974 the Remington plant in 10 A. That's what it says Must be 10 Bridgeport was the only shotgun shell manufacturer 11 Q. Now I believe you testified earlier that 11 making a shotshell that contained asbestos in the 12 Remington stopped using asbestos in its shotshells 12 United States 13 used for hunting sometime in 1981 or thereabouts 13 MS DELMONICO Objection to the 14 A. Thereabouts yes 14 form and objection again because it goes 15 Q. What was the reason for doing so 15 beyond the scope of the Notice of Deposition 16 A. It was to eliminate the asbestos 16 that Mr. Anderson is here to testify about 17 Q. And why did Remington want to eliminate the 17 If you have any personal knowledge 18 asbestos 18 you can answer the question 282 A. Because it's a known hazardous material 19 A. Would you repeat the question 282 Q. And I apologize if I asked you this 20 Q. Let me ask you this Do you agree with the 282 earlier but what was used to replace the asbestos in 21 statement there on page 276 that indicates that the 28 that particular shotshell product 22 only shotgun shell manufacturing plant in the United 28 A. You didn't ask me and the answer is 23 States using commercial asbestos was the Remington 24 plastic and different designs of shell piece 24 Arms plant in Bridgeport Connecticut EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 85 1 MS DELMONICO Same objection 2 But you may answer 3 A. I don't know 4 THE VIDEOGRAPHER End of videotape 5 No. 1. Going off record at 12:21 p.m. 6 7 A lunch recess was taken 8 9 THE VIDEOGRAPHER We're back on 10 record at 1:21 This begins videotape No. 2 11 BY MR KENNEY 12 Q. Mr. Anderson who did Remington consider to 13 be competitors during your period of employment with 14 the company 15 A. the ammunition business 16 Q. the ammunition business 17 A. Winchester and Federal 18 Q. Those two Winchester and Federal 19 A. Those are the two biggies PMC came in 20 after a while too a Korean company 2 Q. In 1974 do you know whether any of those 2 competitors used asbestos in shotgun shell wadding 2 A. I don't know 2 Q. I'd like to draw your attention to Exhibit Page 87 1 Monroe but I'm not sure 2 Q. The first paragraph states Ray 3 Beckerdite Manager Purchasing Division Remington 4 Arms Company Bridgeport Connecticut called today 5 to say that they are giving up the use of asbestos in 6 the near future Do you see that 7 A. Yes 8 Q. The next paragraph states They may 9 require another truckload or two before this takes 10 effect but they have been trying for some time to 11 find a substitute for ecological reasons and have 12 finally succeeded 13 Have I read that correctly 14 A. hmm 15 Q. Do you know what is meant there when they 16 reference ecological reasons 17 A. You mean what the reasons were 18 Q. Yeah 19 A. Yeah It was asbestos A good thing to 20 get rid of 2 Q. And this letter was typed in 1978 22 A. I see that 23 Q. Do you know why it took Remington another 24 three years before it stopped using asbestos in Page 86 Page 88 1 9 which is there in front of you andI took the 2 liberty of putting a little yellow sticky there so we 3 can get there a little faster Actually it's the 4 second page of the exhibit 5 A. Okay 6 Q. This is actually a letter dated September 7 12 1978. Have you seen this document before 8 A. No. 9 Q. The first sentence makes reference to a Ray 10 Beckerdite 11 A. Yes 12 Q. Manager of Purchasing Division 13 A. hmm 14 Q. Do you recognize that name 15 A. Yes 16 Q. Did you know Mr. Beckerdite when he worked 17 there 18 A. Yes 19 Q. Is he still alive 20 A. I want to say no but I'm not sure 21 Q. Do you know where he lived -- or withdraw 22 that 23 Do you know his last known address 24 A. When I knew him I think he lived in 1 its - 2 A. No is the short answer 3 Q. -- its wadding 4 A. No. 5 Q. I know that you had some experience on the 6 D end 7 A. Yes 8 Q. Were you involved at all in the research to 9 try to find a asbestos replacement 10 A. No. 11 Q. Do you have an idea as to what was involved 12 in that process 13 A. Yes 14 Q. Who would that be or who would those 15 individuals be 16 A. Ed Yacko K He is deceased I 17 went to his funeral too 18 Q. Now when asbestos was removed completely 19 from all shotshell products did the quality of 20 Remington's shotshell suffer at all 21 MS DELMONICO Objection to the 22 form but you may answer if you can 23 A. I don't really know I have an opinion 24 but I don't know EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 89 Page 91 1 Q. Well what's your opinion 2 MS DELMONICO Objection to the 3 form 4 BY MR KENNEY 5 Q. You can answer 6 MS DELMONICO You can answer if 7 you can 8 A. It's not really a qualified opinion so I'll 9 just keep it to myself 10 Q. Well I mean you worked there for several 1211 years and then you have seen the product the 12 shotshell products go through different changes I'm 1413 sure you probably have seen how these different 14 products performed in the ballistics labs correct 1515 A. hmm 16 Q. There's a gun range or a range on site at 17 Remington ** A. Yes 28282 Q. Was there a perceivable difference between 28282 the shotshells that contained asbestos versus the 282282 asbestos shotshells that had that asbestos 2828 replacement in 1982 28 MS DELMONICO Objection to the 3 form but you may answer 1 Q. That would have been during your time 2 period of employment correct 3 A. Yes 4 Q. Let me know if you need a minute to take a 5 look at this document but would you agree that this 6 document appears to be a waste -- hazardous waste 7 manifest dealing with the transport and storage of 8 waste asbestos wood and shotshell wadding 9 material 10 A. Yes 11 Q. During your period of employment at 12 Remington Arms during that time period in which 13 asbestos was still being used in certain shotshell 14 products do you know how if at all asbestos waste 15 or -- how asbestos waste was removed from the 16 17 18 19 20 2 23 2233 24 Remington site A. I know it was packaged in plastic bags and then in sealed drums Q. And if we look at this document from 1982 we see here that that's what's happening correct A. hmm Q. But this the date of the shipment is May 1 1982 correct A. hmm Page 90 Page 92 1 A. Not in ballistics no No difference "/ "fl Q. When this asbestos replacement was 3 introduced in 1982 to that specific shotshell 4 product did sales suffer at all to your knowledge 5 A. my knowledge no 6 Exhibit 12 marked 7 BY MR KENNEY 8 Q. I'm going to show you what's been marked as Exhibit 12. Exhibit 12 is a page document Two 10 different documents Page 1 it's entitled at the 11 top State of New York Department of Environmental 12 Conservation Hazardous Waste Manifest Do you see 13 that there 14 A. Yes 15 Q. And if you turn to page 2 it has a similar 16 heading 17 A. hmm 18 Q. Have you seen these documents before 2 A. No. 2 Q. Now if you look at the bottom hand 2 corner you'll see there's a date shipped section 2 A. hmm 23 Q. And it's May 1 1982 3 A. Yes 1 Q. You see that in the bottom hand 2 corner 3 A. Yes 4 Q. So this would have been for a period of 5 time after the manufacturer of containing 6 products took place at Remington correct 7 MS DELMONICO Objection to the 8 form but you may answer if you know 9 A. Could you repeat that 10 Q. Remington stopped using asbestos in its 1111 shotshells in 1981 correct 12 A. Thereabouts yes 113 3 Q. And here we have a hazardous waste manifest 1514 from May of 1982 that appears to be removing 15 asbestos among other things to a storage site or 17 17 facility in New York correct A. hmm 118 8 Q. So I guess do you have an understanding 19 19 of why asbestos was still present at the plant in 20 1982 21 A. It might have been leftover stock I don't 21 really know Just from a logic standpoint that's 2323 what it would be I guess 24 Q. the middle of the page there's another EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 93 1 chart In the fifth column there's an indication 2 there's a column heading that says Net Quantity 3 Do you see that there 4 A. Yes 5 Q. And below that it says 24,000 6 A. hmm 7 Q. Do you know what unit of measurement that 8 is 9 A. No. 10 Q. To the right of it there's a column heading 11 of Units and then right next to that column there's 12 a column heading of Containers and the number of 13 containers containing waste asbestos wood and 14 shotshells 120 correct 15 A. That's what it says yes 16 Q. According to this document 17 A. Yes 18 Q. 120 gallon drums were needed to remove 282 the asbestos waste from the Remington site to this 282 New York facility correct 282 MS DELMONICO Object to the form 28 You may answer 28 A. I don't know That's what the document 2 claims But I wasn't involved in this at the time Page 95 1 take a look at Exhibit 6 specifically page 13 2 A. Okay 3 Q. And I want to draw your attention to 4 Response 23 which is at the top of the page 3 A. hmm 6 Q. It indicates that Sporting Goods 7 Properties Incorporated had a landfill located in 8 the eastern portion of Remington park for disposal of 9 scrap ammunition Do you see that there 10 A. Yes 11 Q. Remember when we talked about or you 12 talked about the scrapping operation 13 A. hmm 14 Q. Is that what you understand -- or is that 15 where you understand the scrapping operation to be 16 located or is that a different area 17 A. I don't know for sure I shouldn't say 18 probably so I won't I don't know 19 Q. Well Remington park is Remington park -- 20 can Remington park be identified anywhere in Exhibit 21 4 22 A. No. 23 Q. Okay 24 Exhibit 13 marked Page 94 Page 96 1 Q. Who would have been involved in the removal 2 of Remington's remaining asbestos fiber from the 3 Remington site during this time period 4 A. don't know I don't know But reading 5 downa little further I see a name I recognize 6 Q. Okay Which name is that 7 A. Wnek Bob Wnek He was a warehouse 8 supervisor 9 Q. So during this time period in 1982 you were the chief supervisor of production 11 A. No I was not 1012 Q. What position did you hold at that time in 13 1882 14 A. I was either the chief supervisor of plant 1515 engineering or the superintendent of quality and 67 process control And I forget the specific dates of 17 a 67 when I moved around as you know now bit 18 Q. And your job duties and responsibilities 1919 during the 1982 time frame did not involve any 20 discussion regarding the removal of hazardous waste 22822282 such as asbestos from the plant 22822282 A. May of '82 No I don't think so 2 822282 Q. Okay The discovery responses that we kind 24 of referenced a couple times actually Exhibit 6 1 BY MR KENNEY 2 Q. I show you what's been marked as Exhibit 3 13 and here we have an aerial view of the Barnum 4 Avenue area thanks to Google Earth 5 A. Aren't they wonderful 6 Q. If you look at this exhibit are you able 7 to locate the Remington park area 8 A. Yes 9 Q. Can you point to where the Remington park 10 area is located on that exhibit 11 1 11 22 A. stop It's way up at the top where the houses 13 13 Q. On the top there you can see like a white rectangle up there 1515 A. hmm 1616 Q. Would that be the area where the 17 Remington -- is that the Remington park area there 1188 A. Yeah I believe it is I'm not sure what 1919 building that is but ... 20 MS DELMONICO I'll just object to 2121 this exhibit in that it's a partial 22 representation of the park BY MR KENNEY 24 24 EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 97 Page 99 1 Q. Remington Park is a big area right 2 A. It's a good size yeah 3 Q. But that gives us at least -- what this 4 does in this exhibit is we see a portion of Remington 5 park correct 6 A. Yes 7 Q. And it's the closest portion to where -- 8 it's the closest portion to the Barnum Avenue 9 facility correct 10 A. Yes that's right 11 Q. Can you take that Sharpie and just once 12 again circle where that Remington park area begins 13 on that map 14 A. can show approximately where it begins 15 Q. Okay 16 A. Right about there indicating 17 Q. So it's basically the top portion of that 18 exhibit 28228 A. Yes 28228 Q. There's a reference in the discovery 28228 responses that that was an area where scrap 28228 ammunition was - do you know how it was -- it says 28228 that they maintained a landfill in that area So how 2 was scrap ammunition disposed of in that area if you 1 Q. So it would be further up 2 A. I'm not sure I would recognize it Brian 3 to be honest with you But no I think it's 4 probably farther up here 5 Q. right And was this waste was this 6 just dumped above ground or was there a hole dug how 7 was this waste -- 8 A. It was above ground 9 Q. Do you know how many years Remington used 10 that area to dispose of shotshell waste 11 MS DELMONICO I'm just going to 12 object to the line of questioning It's going 13 beyond the scope of the deposition 14 But if you have personal knowledge 15 you may testify to it 16 A. No don't 17 Q. Was this area being used to dispose 18 shotshell waste during your period of employment with 19 Remington up until 1981 9 A. Yes 2 Q. We also talked at the beginning of this 2 deposition about the park area which is a little 23 further down which is an area that's basically 24 across the street from the main Remington parcel of Page 98 Page 100 1 know 2 MS DELMONICO Object to the form 3 but you may answer 4 A. It was taken up there by truck and put over 5 in the shotshell scrap area At that time -- what 6 was the date 1982 That last document you 7 showed -- 8 Q. 1982 correct 9 A. So that would have only been shotshell 10 waste It was nothing else 1 Q. And would that shotshell waste include the asbestos wadding we've been talking about 13 A. If there were any in the shipment that went 14 up there it would 15 Q. the shotshell waste could include the 17 16 asbestos shells and it could also include the 17 containing shells 18 A. Yes 19 Q. Okay You indicated a moment ago that there is an area where the shotshell waste was disposed of A. hmm Q. Is that visible in this picture or no A. No I don't see it 1 property correct 2 A. The park area 3 Q. Let me go back to my notes to make sure I'm 4 quoting you correctly 5 The park I believe you indicated that you 6 went to the -- went on a tour and the first site you 7 saw was the park 8 A. Oh you mean this year a couple months 9 ago yes 10 Q. Correct 12 A. And what was your question Q. Was any shot shell -- I'll withdraw that 13 Was any containing shotshell 14 disposed of at the park during your period of 15 employment 17 MS DELMONICO Object to the form but you may answer 18 A. Yes 19 Q. What would determine where shotshell was 20 well what would determine the location of disposal 21 of shotshell A. It was a defined area where shotshells were 24 scrapped 24 Q. Right It sounds like there were two EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 101 areas though where scrap and ammunition would be discarded one would be the Remington park area which is way at the top end of Exhibit 13 4 A. Correct 5 Q. And then there was another area that was 6 closer to the Remington facility that you identified 7 as the park is that correct 8 A. No. No. When I say park I mean this 9 Q. You do okay So I was confused by your 10 earlier testimony Thank you for clarifying 11 Now did this facility have an incinerator 12 on site 13 A. Which facility 14 Q. The Remington facility 15 A. Yes There was one on Barnum Avenue 16 Q. So there was an incinerator located on 17 Barnum Avenue 18 A. hmm 2 Q. If we go back to Exhibit 4 whereabouts on 8 this exhibit was the incinerator located 2 MS DELMONICO And again just 2 note my continuing objection to this line of 3 questioning which is beyond the scope of the 2 notice Page 103 supervisor too Q. During what period of time was that that was -- 4 A. After production 5 Q. But what years were you the maintenance 6 supervisor 7 A. I was the chief supervisor of maintenance 8 It was called chief supervisor of plant engineering 9 maintenance division of plant engineering It would 10 have been the early 80s Early to mid 80s 11 Q. Would that have been before or after 12 asbestos was removed from the shotshells 13 A. It was after 14 Q. Do you have any knowledge as to the type of 15 maintenance that was performed in building 340 16 between the years 1964 through 1981 17 A. Specific occurrences or in general 18 Q. Specific occurrences 19 A. No. I don't remember 20 Q. Do you have general understanding as to 2 what went on -- 2 A. Yeah it was general maintenance on the 3 equipment production equipment there just as 3 everywhere else in the plant The Colton machine was Page 102 Page 104 1 A. I believe it's in the area that's excavated 2 here It's gone 3 Q. Can you point to that area 4 A. Witness indicating 5 Q. Can you actually just hold it up and point 6 so that we can get a - F A. Right here where you see all the 8 demolition 9 Q. Okay Do you know what was burned in the 10 incinerator during your time period at Remington 11 A. Primed shells primarily 12 Q. What's that 13 A. It's a shell with primer in it 14 Q. To your knowledge was any shotshell that 15 contained asbestos burned in the incinerator 16 A. I don't know I don't know It was 17 primarily rimfire shells that were burned in there 18 Q. Do you know if any asbestos scrap material 19 was burned in the incinerator 8 A. I don't know I seriously doubt it 21 Q. As understand it you're not qualified 2 really to talk about maintenance at the facility is 23 that true 2 A. Not entirely I was a maintenance 1 maintained by maintenance people 2 Q. And do you know what type of maintenance 3 work was required on the Colton machine 4 A. Electrical Tooling changes Tooling 5 repairs Inspection of the machine in general the 6 maintenance people would have done that during 7 shutdown probably That's it 8 Q. Who had your position prior to you 9 A. Which one 10 Q. Let me make sure I get it right Who held 11 the position of chief superintendent of plant 12 engineering prior to you 13 A. Robert Kruger 14 Q. Between 1963 through 1981 you didn't have 15 any responsibilities related to exhaust and 16 ventilation systems at the Remington plant did you 17 MS DELMONICO Objection to the 18 form but you may answer 19 A. I don't quite understand you Did I have 20 anything to do with it or did I maintain it or -- I 21 knew it was there I was familiar with it 22 Q. Did you have any involvement in the -- I'll 23 withdraw that 24 You said were familiar -- actually EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 105 1 withdraw that 2 MR KENNEY Can you read that back 3 Question read back 4 BY MR KENNEY 5 Q. During the 1964 through 1981 time period 6 did any of your job responsibilities require you to 7 provide any oversight to ensure that the ventilation 8 system and dust collection devices were properly 9 maintained 10 MS DELMONICO Objection to the 11 form but you may answer 12 A. The exhaust system or ventilation systems 13 associated with the plant were within my realm of 14 responsibilities so if I was aware that there was 15 something not working properly or anything like that 16 yes I would have been involved 17 Or somebody that reported to me would have 18 been involved 19 Q. And so you started with the plant in -- or 20 you started with the company in 1968 2 A. hmm 2 Q. And so during that period of time you were 3 in research and development 2 A. Correct Page 107 1 research and development 2 Q. Okay Did your duties as a project manager 3 within the research and development department 4 require any oversight of the ventilation systems at 5 the Remington plant 6 MS DELMONICO Objection to the 7 form 8 A. No. 9 Q. In approximately 1978 you were transferred 10 to the production department 11 A. Correct 12 Q. And became the chief supervisor of 13 production at that time 14 A. Yes And in 1978 did your duties and 15 responsibilities require oversight of the ventilation 16 system at Remington 17 MS DELMONICO Objection to the 18 form 19 A. Yes 20 Q. So 1978 would be the date when those 21 responsibilities as it relates to ventilation systems 2 at Remington began 23 A. Yeah in that ballpark The specific dates 2 are becominga little fuzzy Page 106 Page 108 1 Q. Would that position require you to have any 2 involvement in the ventilation systems 3 A. No. Not in the plant 4 Q. In 1970 you were a senior research 5 engineer correct 6 A. hmm 7 Q. Would that require you to have any 8 involvement or oversight of the ventilation systems 9 of the plant 10 MS DELMONICO Objection to the 11 form 12 A. No. 13 Q. And in approximately 1973 you became a 14 project supervisor 15 A. Correct 16 Q. Would you be charged with any oversight or 17 responsibilities related to the ventilation systems 18 at the plant then 28 MS DELMONICO Objection to the 28 form 2 A. No. 2 Q. approximately 1975 to 1976 you were 3 project manager 24 A. Yes All of these positions were in 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 24 Q. Can you describe what ventilation systems and dust collection systems were in place in building 340 in 1978 A. My best recollection I can yes Q. Okay A. There was a bag house filter at the end of the operation that is the last point that the air stream from -- the operation was inside the building It was the last device that conditioned the air stream before it went into the atmosphere Q. I'm sorry was that bag house filter did you say that the filter was inside the building or outside the building A. It was inside the building on the fourth floor It exhausted outside the building Q. And there was a bag house area that collected asbestos fiber correct A. Collected whatever was in the air stream Q. Did that have to be changed on a regular basis that bag house filter A. Yes It was monitored Q. How often was that replaced A. I don't really recall Q. So there was a bag house filter Do you EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 109 1 know when that bag house filter was installed at 2 Remington 3 A. No I don't but it was there when I was 4 transferred to production 5 Q. So it was there in 1978 60 A. Yes 7 Q. Were there any other collection devices in 8 building 340 in 1978 9 A. I believe there might have been a cycling 10 filter on the -- in the operation where the wood 11 flour and the asbestos were put into the kettle for 12 the mixing blending bowl and that subsequently 13 exhausted to the bag house filter 14 Q. The same bag house filter as you just 15 discussed a minute ago 16 A. Yes That's my recollection 17 Q. Were there any collection devices for 18 floors one through three of building 340 19 A. One through three 20 MS DELMONICO Object to the form 2282 but you may answer 2282 A. Let's see One was the Colton two was the 2282 feed ... 2282 The centrifugal exhaust that I mentioned Page 111 1 Q. Do you know where in building 340 that 2 rotoclone system was located 3 A. If it was the one that I'm thinking of it 4 was probably on the fourth floor And it exhausted 5 the blending kettle that I mentioned before 6 Q. Do you know if the rotoclone system was in 7 place in 1978 8 A. only have a vague recollection of it but 9 if the recollection is correct it was there then 10 yes It wouldn't have been taken out prior to that 11 Q. It goes on to say that In addition 12 Sporting Goods Properties Incorporated records 13 indicate that dust collectors were in use as early as 14 1966. Do you see that there 15 A. No. Where is it 16 Q. It's the next sentence 17 A. On page ? 18 Q. Page 9 19 A. Okay Down at the bottom 20 Q. Yes 21 A. Yes see it 22 Q. So 1966 we know that as early as 1966 23 Sporting Goods Properties had a -- well I'll 24 withdraw that Page 110 Page 112 1 was exhausting I believe the mixing -- I mentioned 2 that it was exhausting the mixing kettle on the 3 fourth floor I believe it was the fourth floor or 4 the mezzanine I'm not sure 5 Could you repeat the question please 60 * Question read back 7 A. really don't recall I remember the bag 8 house and that's really it Because that was a big 9 one Q. Can you in your pile there of exhibits 10 11 find the discovery responses Actually it's right 12 there Exhibit 6. Turn to page 9 please 13 A. Got it 14 Q. Question 14 asked about asbestos collection 1515 devices during the manufacture of containing 16 products And the response indicates that exhaust 1717 was used in handling asbestos in the dry mold base 18 wad manufacturing process as early as 1963. And it 28 2282222 goes on to say that available records describe the 282222 exhaust system in the dry mold base wad area as a 282222822222 rotoclone system Do you know what is meant by a 28222822222 rotoclone system 28 2282222 A. That's a cyclone exhaust the 282222 rotoclone 1 We know that as early as 1966 the Remington 2 facility had dust collectors in use correct 3 A. hmm 4 Q. And how if at all if you know were the 5 dust collectors that were in use as early as 1966 6 different from the rotoclone system that was in use 7 as early as 1963 8 A. I don't know I'm not quite sure what 9 that's referring to 10 Rotoclone is a cyclone it was used in 11 1 various locations in the plant not just in 340 1122 Q. And these rotoclone systems did they 1313 always exhaust to the outside air 14 MS DELMONICO Objection to the 1515 form Go ahead 1716 A. No. Not always 17 Q. Do you know if the rotoclone system that 1188 was in place as early as 1963 in building 340 do you 1919 know whether or not that exhausted out into the air 20 or into a bag house 2121 A. My recollection is that it went to a bag 22 house It would certainly not have gone into the 2324 air Q. Your recollection extends to 1978 correct EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 113 1 A. Yes 2 Q. You don't know what was done between 1963 3 up through 1977 in terms of how the rotoclone system 4 was vented 5 MS DELMONICO Objection to the 60 form 7 BY MR KENNEY 8 Q. Correct 9 A. I don't know 10 Q. You don't even know if that rotoclone 11 system was in place in 1978 correct 12 A. I believe it was but I'm not sure I 13 wouldn't book on it 14 Q. Do you know why Sporting Goods Properties 15 Inc. distinguishes between a rotoclone system and a 16 dust collector system in their discovery responses 17 there 18 MS DELMONICO Objection to the form 282282 282282 A. I don't know 282282 Q. Have you ever heard of limpet M 282282 A. No. 282282 Q. It's an insulation product 282282 A. No. Page 115 1 A. Yes People under my supervision were 2 Q. What type of abatement programs went on at 3 the Remington Arms facility 4 A. The only ones I'm familiar with were pipe 5 insulation Whenever we had a repair to make in a 6 pipe that was insulated with asbestos they would 7 follow the procedures for normal abatement for 8 asbestos insulation 9 Q. Do you have any memory as to any specific 10 abatement projects that went on at the site 11 A. Only insofar as they were in various 12 locations in the plant We had asbestos pipe 13 insulation in a lot of places in the plant dated from 14 1900 15 Q. Did Remington have its own insulators on 16 the payroll 17 A. You mean to install insulation 18 Q. Yes 19 A. No. 2 Q. If insulation were needed to be performed 2 at Remington whether it was asbestos or asbestos 2 insulation would Remington hire outside contractors 8 A. Yes We did very small jobs of abatement 24 with all the right personal protective equipment and Page 114 Page 116 1 Q. Have you ever heard of crocidolite 2 asbestos 3 A. Yes 4 Q. Do you know if -- 5 A. Do you mean chrysotile 6 Q. No crocidolite 7 A. Crocidolite 8 Q. different form of asbestos than 9 chrysotile 10 A. Okay No. 11 Q. You don't know whether or not crocidolite 12 asbestos was used at the Remington Arms facility 13 A. My understanding is chrysotile was used 14 Q. Do you have any understanding as to the -- 15 as to whether or not asbestos was used to insulate 16 piping at the Remington Arms facility 17 A. Yes it was 18 Q. And do you know what type of asbestos was 28 used to insulate piping at the Remington Arms 28 facility 2 A. No. 2 Q. As supervisor in plant operations in 3 1978 were you ever involved in any sort of asbestos 24 abatement for the Remington Arms facility 1 everything but if it was a large job it was 2 contracted 3 Q. Do you recall the names of any of the 4 insulation contractors that Remington contracted 5 with 6 A. No. 7 Q. The Remington site also had a heat treat 8 area correct 9 A. Heat treat area Many moons ago it did 10 yeah 11 Q. Were there furnaces and ovens located at 12 the site 13 A. Yes 14 Q. Do you recall any of the brand names of the 15 furnaces that were present on site 16 A. No. 17 Q. Have you ever heard of the name Lindberg 18 A. Sure 19 Q. Do you know if any Lindberg products were 20 on site there 21 A. Yes there were Yes 22 Q. Do you know what types of Lindberg 23 equipment were on site at the Remington facility 24 A. We had a tempering furnace that was a EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 117 1 Lindberg 2 Q. Do you know what building that furnace was 3 located in 4 A. It was in 875 I believe Let me just 5 refresh my memory here It was in the tool room and 6 machine shop and that was in -- I believe that's 7 building 875 8 Q. Are you familiar with the name Blue M 9 A. Yes 10 MS DELMONICO Again I have a 11 continuing objection here but we are way far 12 afield of the Notice of Deposition in the 13 categories in which Mr. Anderson is here to 14 testify today I'll just assert my continuing 15 objection to this line of questioning and I'm 16 hoping you're wrapping this up soon or this 17 will become an issue okay 18 MR KENNEY Yes 29 MS DELMONICO Thanks 29 BY MR KENNEY 2 Q. You indicate you're familiar with the name 2 Blue M 23 A. Yes 3 Q. How you familiar with that name Page 119 1 Q. you look at the exhibit and you can 2 actually see the road it says Barnum Avenue right 3 there 4 A. hmm 5 Q. And then there's a series of structures 6 It looks like a building 77 maybe building 876 7 A. hmm 8 Q. And then there's a bigger -- those appear 9 to be part of a bigger structure there do you see 10 that there 11 A. This here 12 Q. Yeah 13 A. Yeah 14 Q. What operations were located in those 15 buildings there 16 A. Maintenance was in this area here 17 Q. Was there a building number associated with 18 that that you recall 19 A. 875. Or 876 let me see No 876. 875 20 was the office in front of that And there was an 228 & what we call the works operation over here 228 Q. Is that where you worked when you first 228 started at Remington 24 A. Yes That's where I did a lot of my work Page 118 1 A. We had Blue M ovens in the labs drying ~ ovens 3 Q. And what did these drying ovens do what 4 did they dry 5 A. Let's see we had one in the & chem lab 6 They would dry samples of -- quality control samples 7 and that kind of stuff 8 Q. One of the last things I want to do is 9 since we have you here and kind of take advantage of 10 your knowledge of the facility -- 11 A. Three items 12 Q. I want to just draw your attention back to 13 Exhibit 7 there the Former Structures Plan and I'll 14 try to find my copy here 15 We talked a little bit about building 340 16 but can you show me or indicate where the main 17 entrance of the Remington facility was located I 18 assume it was somewhere on Barnum Avenue 19 A. It depends on what you were coming in for 20 But to answer your question the main entrance was 2282 from Barnum Avenue was right here 2282 THE WITNESS I should show you 23 that too 24 BY MR KENNEY Page 120 1 yeah 2 Q. Above that I see a building 773 3 A. 773 4 Q. It's actually kind of at the center of the 5 page there 6 A. Oh this That's the warehouse 7 Q. That's the warehouse 8 A. hmm 9 Q. What would be stored in the warehouse 10 A. Ammunition for sale 11 Q. So that would be finished product 12 A. Yes 13 Q. And then to the right there's a structure 14 that appears to be -- these are tough to read -- it 15 looks like it's building 81. To the right of it 16 there's a -- 17 A. Yeah I see it there 18 Q. any event those structures there do 19 you know what went on in that area of the site 20 A. I think those were the garage facilities 21 87 I believe there Is that the number 87 and 22 81 Q. Okay 24 A. Those were the garage facilities EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 121 Page 123 1 Q. Across the street across from Arctic 1 Properties Inc. and I just wanted to show you -- 2 Street it looks like there's a series of -- they 3 kind of look like circles or octagons it's a little 2 Exhibit 14 marked 3 BY MR KENNEY 4 tough to see but do you see where that is 4 Q. Well first off I want to show you what's 5 A. Right here 6 Q. Yeah What was located over there 5 been marked as Exhibit 14 and see if you recognize 6 what's depicted in that photograph 7 A. That was a waste water treatment plant 8 Heavy metals separation 9 Q. The Remington site uses a lot of water and 7 A. No don't It's a lousy photograph 8 Q. It poor quality yeah And I'm going to 9 show you what's marked as Exhibit 15 10 chemicals to manufacture products on site 11 A. Not much water in the manufacturing 10 Exhibit 15 marked 11 BY MR KENNEY 12 process But there's metals in it Copper brass 12 Q. Let me know if you recognize what's 13 zinc lead 13 depicted in Exhibit 15 14 Q. And that was just to -- that was what to 14 A. It's a piece of ground If you're trying 15 filter out the water to clean it or 15 to get me to say it's something specific I can't 16 A. No. It was to separate the heavy metals 16 Q. Well it's a poor quality photograph I'll 17 out And they would be collected from the treatment 17 give you that I didn't know if -- you mentioned 18 plant and taken to a proper storage location 18 that there was a scrapping area we talked about 9 Q. So that would be the waste that was 19 that 8 collected from the facility is that where the water 20 A. hmm 2 went 2 A. Yes Most of that was from rimfire 3 Rimfire production not shotshell Although there 2 was some from shotshell too 7232 Q. Where some of the shotgun shells were 7232 disposed of I didn't know if that was a picture of 7232 that or if you'd recognize -- 7232 A. I would never recognize it from that Page 122 1 Q. Now if we go across the street from Barnum 2 Avenue the area that is between Barnum Avenue and 3 New Haven Railroad there's number of buildings in 4 that area What function did that area of the site 5 serve 6 A. Okay That's on the bottom 7 Q. Yeah You see all those buildings there A. Yes all this This was a former part of the operation which was for military production centerfire ammunition for the Armed Forces When I was there it was a parking lot That's how long ago These buildings on the left are still there They were vacant MR KENNEY Why don't we take a break We'll go off the record THE VIDEOGRAPHER Going off record at 2:14 Off the record Exhibit 14 marked THE VIDEOGRAPHER We're back on the record at 2:22 BY MR KENNEY Q. Mr. Anderson there were some photographs that were produced in this case from Sporting Goods Page 124 1 picture no 2 Q. Okay All right 3 MR KENNEY Those are all the 4 questions I have 5 MS DELMONICO Ijust have a 6 couple 7 EXAMINATION BY MS DELMONICO Q. Mr. Anderson you described earlier today 10 the manufacturing process for the asbestos dry mold 11 base wads at Remington Arms do you recall that 12 testimony 13 A. do 14 Q. And is it your understanding from your 15 personal knowledge and the documents that you 16 reviewed for your deposition today that that 17 manufacturing process was in place the entire time 18 Remington Arms manufactured asbestos dry mold base 2 wads 8 A. Yes 2 Q. You also testified about the use of a bag 2 house filter in that manufacturing process do you 23 recall that 24 A. do EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com Raymond Anderson Volume I November 18 2014 Page 125 1 Q. And is it your understanding based on your personal knowledge and the documents that you 3 reviewed for your deposition today that that bag 4 house filter was in place the entire time Remington HH Arms manufactured asbestos dry mold base wads 6 MR KENNEY Object to form 7 A. Yes 8 MS DELMONICO That's all 9 MR KENNEY Off the record WITNESS Raymond Anderson CASE Taska v ACMAT et al SIGNATURE ERRATA SHEET PAGE LINE CHANGE OR CORRECTION AND REASON THE VIDEOGRAPHER Going off record 1211 at 2:25 p.m. 12 Witness excused 13 Deposition concluded at 2:25 p.m. 1414 15 16 1177 * 282 28282 282 28 28 2 20 have read the transcript ofmy deposition taken 21 November 18 2014. Except for any corrections or changes noted above I hereby subscribe to the 22 transcript as an accurate record of the statements made by me 23 Signed under the pains and penalties ofperjury 24 Date STATE OF CONNECTICUT Page 126 I Sharon R. Roy a Notary Public in and for the State of Connecticut do certify that pursuant to notice there came before me on the 18th day of November 2014 at the law offices of Murtha Cullina LLP 185 Asylum Avenue , Hartford Connecticut the following named person to wit RAYMOND ANDERSON , who was by me duly sworn to testify to the truth and nothing but the truth as to his knowledge touching and concerning the matters in controversy in this cause that he was thereupon examined upon his oath and said examination reduced to writing by me and that the deposition is a true record of the testimony given by the witness to the best of my knowledge and ability I further certify that I am not a relative or employee of counsel or attorney for any of the parties nor a relative or employee of such parties nor am I financially interested in the outcome of the action Witness my hand this 1st day of December 2014 Sharon R. Roy/ 426 My commission expires March 31 2017 EPPLEY COURT REPORTING LLC www.eppleycourtreporting.com