Document e7akN4kkdJ0d1kwjdnnp4eaK4

SENT b y : x er ox Telecopier 7017! 7-30-83 -% 701 Pennsylvania Avirus, N.W. V;as^infilcn D.C.20CC4-2696 Telaplione 202-503*5000 111PM 2025035736- BRADLEY AND HERRELLi# 2 I II EEa Edison Electric institute SOttAsttveisary 1S 33 19 93 July 30, 1993 via facsim ile transmission and first d ass mail Laurie A. Basch, Esq. W en, Gotshai & Manges 767 Fifth Avenue New York, NY 10153 Subject: N evada P ow er Co. v. M onsanto Co., Case No. CV-S-555-LDG CLRL) (D, Nev.) Dear Laurie: W e received the portion of Mr. Fabbi's deposition transcript; (pp. 64-66) which w e requested by facsim ile transmission on July 28,1993. W e have review ed this m aterial w ith EE1 staff who have knowledge o f the [pertinent su bject m atter. Based upon these discussions and our telephone conversation on July 28, w e have identified the following docum ents as being potentially responsive to your su bpoen a duces tecum : 1 Employee Injury Experience o f the Electric Utility Industry for the years 1978-89 (no reports w ere found forjthe years 1980,1982 and 1984); and M iscellaneous fatality report sum m aries for the [rears 1980-85 and 1989. The Employee Injury Experience of the Electric Utility Industry report Is a brief annual com pilation (approximately 15*25 pages) of statistical reports submitted by individual EEI m em ber com panies. EEI staff explained that individual com panies submit data on a voluntary basis and that som e, but not all, m em bers of EEI submit such information. As stated in the preface of |the 1978 report, nIt is em phasized that this publication cannot relate the entire [electric utility] industry's em ployee injury experience. The number of- [EEI m em ber] com panies reporting data has been steadily decreasing over the past y e a rs...." Moreover, w e have reviewed these docum ents and none of them describes the cause of any Injury. W e have also reviewed the m iscellaneous fatality report sum m aries i SENT 3Y: XEROX Telecopier 7017; 7-30-93 ; 1 s12PM : 202:035736- BRADLEY AND ME RR ELL # 3 Laurie A Basch, Esq. July 30, 1993 Page 2 and have found that none of them refers to a PCB-related accident. Mr. Fabbl Is correct in recalling that he had not seen any reference In any of these reports to a PCB-related injury. Based upon our telephone conversation on July 28, it is clear that none of these documents is of any real interest to you. This should fully satisfy any obligation of EEI under your subpoena duces tecum. Please call m e at (202) 508-5104 or Larry Brown at (202) 508-5618 if you have any questions. Very truly yours, i Joseph T. Yost Senior Attorney JTY/ms cc: Laurence W. Brown, Senior Attorney, EEI Paul E. Merrell, BRADLEY & MERRELL