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Plaintiffs Exhibit S-UC-211
Hay 14, 1975
Insulators Health Hazard Program
511 Machinists Building 1300 Connecticut Ave., N.W.
Washington. D C. 20036 (202) 785-2150
Mr. W.C. Thurber Union Carbide Corporation Mining and Metals Division 270 Park Avenue New York, New York 10017
Dear Mr. Thurber:
A
This is in reference to your communication of May 5, 1975 and the various information you supplied in regards to amendments to Senator Milton Marks' legislation. I would like to make the following comments.
1. I am deeply concerned over the handling of the dry materials such as the methods of mixing and the pre cautions and safety equipment which are to be used. What safety precautions and equipment would be used in the cleanup, especially of the overspray after drying?
2 I noticed the various percentages of asbestos that are in the different mixtures and find that they run as high as approximately 20%. We have many statistics to show that our people who have been exposed to less than the two fiber amount, which will become the law under 0SHA next year, are still experiencing severe difficult ies healthwise with asbestosis and the many other dis eases associated with asbestos. This includes wives, children and other people who do not know they are being exposed to the above product. We are naturally concern ed with asbestos exposure to anyone, regardless if they are affiliated or not with any individual union.
3. What consequences are experienced from erosion, abrasion, damage to the finished products, cutting, sanding, etc.?
4. Although you mention the use of just a small percent or
amount of asbestos, I again question the amount which
rises to approximately 20%. This is a greater percentage
than many of the products we have used in the past such
as pipe covering and flat block materials containing
received
asbestos.
MAY 1 5 J975
PLAINTIFFS EXHIBIT
43971-QQ
PLAINTIFF'S EXHIBIT
Mr. W.C. Thurber - page two
We feel that we would have to take a very close look at the many different applications, including the overspray effect, before we could reach any conclusions regarding changes in Senator Marks' legislation.
We are not overly concerned about a wet or sealed in application but the effects before and after application is our main worry with asbestos in a dry state.
We sincerely hope that you can answer the above questions to our satisfaction and that a mutual understanding can be reached.
With best regards, I am
Very truly yours.
RJ S:mgm
CC: Dr. Irving J. Selikoff Senator Milton Marks Dr. Bill Nicholson Dr. Duncan Holaday Mr. Ed Story
Roy J. Steinfurth Insulators' Health Hazard Program
Ma/5, 1975
Mr. Roy J. Stelnfurth, AMniiMor insulotan Hsolth Hncesd Ptogrem 511 Mochinist Building 1300 ConmcHa* Avenue N.W. Washington, D. C. 20006
Door Mr. Stelnfurth:
At a follow up (o today's hltf^ons canyawHwi, I an nclcdm lor your InformuHun otpin
Of WVl^QnQPICi wWCn W WiCMl IWUlfi ini VdvIiTWO IVmiiinViVf
lv-
Senator Milton Maria regarcRng profooad additional snapriM to the roeantly sncM Colf-
fondo law relating to the graying at ohdn.
As yow can soo Iran this Informotion, wo no suggesting that cortaln additional notariats In which relatively anoll nnaonti of asbootos are contalnod In a llgold binder and gflltl by spraying cob do ooo^dv wibopi popoowP^ tvio noomt o* mo inovYiflMi wovooc w mo ganoral ptblle. Tho data claarly drew that lbs air bcrwo asboaloo cancantratian gsnaratsd during tho graying of paints, textured coatings, polyostor resins, asphalt boss roofing materials and tho Ifloo ora nibstawHally bolow tho 2 flbar/cc Hna weighted average vako which Is soon to became tho natlanal standard. While wo are canvinood that tho spraying at essentially pare asbestos with little or no binder for fireproofing end insulation Is a totally Inappropriate are of tMs material, wa are also convinced that the snare ban should not apply
to the spraying of sretarials eontsdnlng anoll aareunts of asbootos wall wot oat by a permanent
II bo able to Ins proposing re-
Very truly yours, "ORIGINAL SIGNED BY * ft THI/RBER',
W. C. Thurher
WCT/es Enclosures
bcc: Messrs. F. H. Lxrrison - with attachments
H. B. Rhodes - without "
P. McAmis - "
"
let mo know.
Draft - April 23, 1975 Senator Milton Marks California State Senate Dear Senator Marks:
It was a pleasure meeting with you last week and having the opportunity to discuss proposed am< ments to SB24I9 relating to the spraying of materials containing asbestos.
In the interim since our meeting, we have had the opportunity to review Dr. Selikoff's letter of March 14, 1975, to you and would like to provide some comments on the questions raised by Dr. Selikoff. Dr. Selikoff apparently did not receive the detailed dust count data which CMA submitted in support of the proposed amendments and thus is quite correct in theposition that the information available was not adequate to evaluate the proposed amendments. It seems from the nature of his other questions that he is looking at this in the same light as the now discontinued operation of spraying asbestos building insulation. In insulation spraying, bags of raw asbestos fiber are mixed in a water slurry and sprayed on to steelwork and other surfaces for fireproofing. There is little or no permanent binder so the sprayed material ends up as a mater of virtually pure asbestos held in place by its own entangled fibers. Such operations obviously represent an in appropriate use of asbestos and have been outlawed.
There is a substantial difference between this spraying of asbestos for building insulation and the operations covered by our proposed amendments wherein a relatively small amount of asbestos is added to a liquid binder for control of certain physical properties of the material. The os bestos in the finished coating or item is firmly held in a permanent binder. Recognition of these distinctions is essential for an appropriate evaluation of the proposed amendments.
Referring to Dr. Selikoff's five specific questions, the following comments are offered: 1. All of the systems except the interior wall and ceiling texture sprays i.e.
water-based systems with water soluble binders, are factory mixed and de-
livered to the spraying location with the asbestos fully wetted out. The tex ture sprays, containing 1-3% asbestos mixed into the other dry ingredients are typically added to water at the site. The act of dumping is controlled by the OSHA regulations and if it cannot be done in compliance the entire opera tion should be stopped. There are moves at some locations to compound this type of spray at factory locations and pump it directly into the sprayer's tank. 2. Extensive supporting data have been supplied on this point. (See Tables I--IV attached) The maximum level found was a ceiling concentration of 1.6 fibers/cc with values of several tenths of a cc most typical. It should also be noted that in most of these counts all particles longer than 5m wi th L/D^3 that in the judgment of an experienced operator could possibly be asbestos were counted as such. This tended to include a proportion of particles that were not really asbestos. 3. Regarding contamination of adjacent surfaces during spraying, it should be stressed that the materials sprayed are being used in the finishing or as the finish for surfaces and parts. Where overspray occurs, it is normally removed immedi ately or covered with subsequent coatings. Where it is not removed, the binder sets and holds the asbestos. There are no dry clumps of unbound asbestos as could occur with the insulation spraying and which seems to be of particular concern to Dr. Selikoff. We are prepared to provide an application by appli cation commentary for the systems tested in developing the supporting data if it wilt be useful.
4. Regarding subsequent manipulation of the coated surfaces, the texture sprays (Table I) the wall and roof sprays, (Table II) and the asphaltic roof and under coats (Table IV) are finished as applied and are not sanded or worked further to any extent. Certain of the resin applications (Table III) are cut, sanded or ground after the binder resin has hardened. A substantial amcunt of fiber
(V .
count data has been obtained for this type of operation and wets provided in Tables V and VI. The highest level found in a commercial situation was 0.4 fibers/cc. In a laboratory test in a small closed room the maximum was 1.2 fibers/cc. 5. Regarding contamination of the workplace by waste materials, it should be noted that these materials cure or harden when used so the asbestos is bound in. An exception to this is the "empty" bags for the interior wall and ceiling texture sprays. These do present a potential exposure but are rigidly controlled by both the Federal and California OSHA regulations. It should also be noted that the removal of overspray on the floor is required after some texturing opera tions. This is noimally done wet with a scraper and the floor is then finished.
*
We would like to reiterate that the proposed exemptions of certain additional ques tions from SB24I9:
1. Can be accomplished within existing OSHA and EPA regulations; 2. Will generate very low levels of airborne asbestos contamination and that these
dust levels are similar to those of already exempted operations; 3. Will insure the continuing economic well-being of those companies and workers
in operations proposed for exemption.
Your continuing consideration of this matter is appreciated. Very truly yours.
Attachments
cc: Mr. E. H. Story - Local 16 AFL-CIO 2601 Mission Street - Room 707 San Francisco, California 94110
R. T. Monagan, President California Manufacturers Association
*
PROPOSED MODIFICATIONS IN CALIFORNIA HEALTH & SAFETY CODE
CHAPTER 10.3, 25910 (CALIFORNIA MARKS BILL, SB 2419)
Exempt the following, in addition to "cold process cutback asphalt roof coating":
1. Water-based interior texture sprays containing as sprayed a maximum of 3% by weight of asbestos and a minimum of 2% by weight of water-soluble starch, soya protein, polyvinyl alcohol, or equivalent binder.
2. Latex-based interior and exterior coatings containing as sprayed a maximum of 5% by weight of asbestos and a minimum of 8% by weight of vinyl, acrylic, vinyl-acrylic, or equivalent polymer binder.
3. Resin-based laminating and/or coating materials containing as sprayed a maximum of 12% by weight of asbestos and a minimum of 6% by weight of polyester resin, alkyd resin, epoxy resin alone or in combination with coal-tar, or an equivalent resin binder.
-4. Asphaltic-based coatings containing as sprayed a maximum of 15% by weight of asbestos and a minimum of 40% by weight of cutback asphalt or emulsified asphalt binder.
The Honorable Milton Marks Member, California Stato Senate State Capitol, Room 2070 Sacramento, CA 95S14
Dear Senator Marks:
In 1974 you carried SB 2419, which was signed into law on
September 26 of 1974. This act, which added Chapter 10.3 to the
Health and Safety Code, prohibited the spraying of any substance
containing any amount of asbestos after July }, 1976, in or upon
rtj othc* ^tructur^
cor**t^ion
or Tepair, with the exception of colu process cutback asphalt root
coatings. In addition to tho present statutory exemption of coal
cutback asphalt roof coating, we believe that there are other
applications which should also be exempted from the statute. These
proposed additional execrations will in no way jeopardize the health
of the citizens of California and will, at the sane time, protest
the employment of workers in the California asbestos and related
industries.
It is our firm belief that various materials containing small quantities of asbestos can be applied safety by spraying with no significant hazard, either to the occupational worker, or the general public. And further, that such spraying can be dene in total com pliance with Section 5202 of the General Industry Safety Orders for tho State of California dealing with asbestos, and the EPA National Emission Standards for Hazardous Air Pollutants. Those applications which we propose for exemption generally involve the spraying of paints and coatings where asbestos is a miner but important constituent added to give criticaal properties to tho material. These coatings are applied-wet as a slurry or liquid, thus precluding the generation of airborne, asbestos fibers in excess of established California and Federal regulations. Specifically, I have attached a proposed draft of a bill which would provide additional exemption:* be added to tho existing statute.
Supporting data from a variety of representative industrial operations in each class are provided in Tables I-IV. These data indiciitethat in r.m instance does the airborne concentration of asbestos fiber exceed eithor the tine-wei.chtcd average tor peak concentrations spasefied in Section S223 of the General Safety Orders even for the lower level standard to be invoked on July 1, 1976.
Exhibit One attached provides additional information relevant to this proposal. Tnis information was excerpted frcn the federal register and is part of the EPA background information included with the promulgated National Emissions Standards for Hazardous Air Pol lutants. This material clearly indicates the undesirability of, and enforcement problems associated with, an absolute ban on asbestos spraying.
Adding of these exemptions to the present statute will assure the continuing economic viaSility of those segnents of the mining. Billing, and formulating industries involved with asbestos while protecting the health of the workers and the general public. These proposed amendments are fully supported by the Asbestos Information Association of Korth .America. This organisation cons is ss of 22 Bomber companies and associations which represent three-quarters of the asbestos mining, milling, manufacturing, and importing indus tries of the United States.
I would be pleased to further discuss this proposed amendBent to tho Health and Safety Coda with you at any time.
Sincerely yours.
RTHrrk Enclosure
Robert T. Monagan President
f
>
The proposed standard would have
prohibited the spraying of any material
containing asbestos on w portion of
.a bulldin? or structure. prohibited the
spraying of any material containing as
bestos In an area directly open to tho
atmosphere, ar.d limited emissions from
' ` ail other spraying ot ar.y material con-
- talnlng asbestos to the amount which
would be emitted if specified air-cleaning
equipment were used. Comments re
ceived pointed out that this standard
would: (1) Prohibit the use of materials
containing only the trace amounts of
. asbestos which occur in numerous nat-
/ .-oral substances. (2) prohibit the use of
: materials to which very small quantities
of asbestos are added in order to enhance
their effectiveness, and (3) prohibit the
: ase of materials m which the asbestos is
strongly bound and which would not gen
erate particulate asbestos emissions. The
`promulgated standard aopiies to those
uses of spray-on asbestos materials
which could generate major emissions of
. - particulate asbestos material. Tor those
: spray-on materials used to Insulate or
fireproof buildings, structures, pipes, and
conduits, the standard limits the asbestos
content to no more than 1 percent. Jfa-
terials currently used contain :rom 10-
r. to 80-percent asbestos. The intent o: the
. 1-percent limit is to ban the use of na-
- terials which contain significant quanti-
... ties of asbestos, but to allow the use of
.. materials which would: (1) Contain trace
'amounts of asbestos which occur in
numerous natural substances, ana (2)
include very small quantities of asbestos
flesa than 1 percent) added to enhance
the material's eTectiveness. Although a
standardized reference method has not
been developed to quantitatively deter-
. mine the content of asbestos in a ma-
teriat. there are acceptable methods
available, based on electron microscopy,
which Independent laboratories have de
veloped Determining the asbestos con-
' tent of a material with these methods
; costs approximately $300, ar.d the resuits
i are accurate within plus or .minus 50
i percent; these limits on accuracy were
_ taken into account in establishing the
. I-percent limitation.
..
l
V
ri..*,:*v
V
VATtR-gASCO STSTTMS WITH UATCP-SOlUGlt 81f.:cgs
jingle
Comerclal Sisiicstlon
1 . lKTtRtOR TWTVe.E S"A*S 12 Celling spray.
>2
3 Vail spray. 3S
38 28 36
131 102
Calling spray
Vail spray.
Date
4/14/73
9
m
-
Under Soya protein.
Starch.
_ 'a' . '
. ' " *
A$pro-{11
Imate Vt. 1 Asbestos
Soray Gun Tvpe
Operation
Soplc ll (Win.)
2 Air supported
2
2' 2\
. .* *
Operator applying celling spray to condominium apts.
Operator wiping aalls after ceiling Spray.
Operator applying nil spray to condoniniia apts.
Operator carrying hose during wall spraying.
1 Operator spraying
-V
ceiling of condcoiniun.
1
*
1'
2 Operator spraying nils of condominium.
2
.
71 68 51 34 14 15 IS 21 12
. 8-3 8-2 K-2 2-2S
2-49 2-54
Catling spray
*
Kali spray. *-- -
10/3/74 m:
*
m'
Catling spray.
12/4/73.
-v
-1
.1
2.S
LS
. v
1 ** 1
Operator applying calling spray to home.
Operator `wiping* walls . after celling spray.
Operator applying wall spray to hs=e. Full coverage.
Operator spraying glitter. Immediately after ceiling sprayed.
19 22 24
26
Operator applying ceiling Spray to condominium apts.
Operator 'wiping* walls after ceiling spray.
20 24
0) tied on total formulation as sprayed.
no ici - u c :> cu jv^ie:;i^.wi ut tiO -- 2>U i UP 1 c pincers
Binders:
.
Type:
Starch, polyvinyl alcohol, soya protein or equivalent.
Content: Typically 6-8% by weight of the dry formulation before mixing with water, 2-4% as sprayed.
Main Uses: Interior wall and ceiling texture sprays.
(Where texture is applied to walls it must be . covered with at least one coat of a latex or
oil-based paint.)
Asbestos Content: Up to 3% by weight of the total formulation as sprayed.
Supporting Data: Table I.
vtTK uni si:;s
StvpU Br1c"*teo
Confrc(I *99 W Cit i on
- IXTEKIO* COS rimes
- Vail and Roof %*t*L
a
C-2
-
loof spray.
Data
tO/A/tt a a
j/30/71
linger
Vinyl latex. a
Acrylic latex Acrylic IittXs
*VJ
a a
Approx-^ tiU Ht. J Asbestos
V
J.7
1.1
0
Spray Cun Tvpe
Operation
Sen? to Tim
l*:<0
Air supported.
a a
Operator spraying vortical wall panel
a
a
IS
1
*7 Airless. 0.7 a
Operator spraying downward onto a large roof.
a
it It
Afrbomt Aabcttoi Concentraf iFibert/cc;
0.0
0.2 0.2
0.0
0.0
(I) taxed on local formlatlen as sprayed.
IIU UUI -- --~ ~J-'
J * \.i i_UCC/\ UIIIOC! 5
Binders:
Type: Vinyl latex, acrylic latex, vinyl-acrylic latex, or equivalent.
Content: Polymer content of 10-20% by weight as sprayed
Main Uses: Exterior coatings for buildings and mobil homes,
including roofs.
,-
Asbestos Ranee: Up to 4% by weight of the total formulation as sprayed.
Supporting Data: Table II.
.
-Smile
CemercUl Ar?lieation
Bate
I - roiTESTtS ' 51NS A. General Pure OS*
S >sint
(9 Boat manufacture. 12/7/72
Binder
General purpose laminating resin.
tSlH-0?CD STSUHS -
-
Approa-^
(mate Vt. t Asbestos
Soray Gun Type
0.5 Air-supported chopper.
.
Ooeratlon
* Operator spraying molds with resin 1 chopped glass.
Sample lime
tmn-V
24
t-13 1-25 *-30
10/31/74
0.5
o.s
'
o.s
'
1C Operator spraying
resin 1 chopped fiber glass. (Includes
roll-out time.')
*
Operator spraying resin l c-.opped fiber glass.
.s
Operator spraying 4 resin 1 chopped fiber glass.
1-34
10/8/74
- WO . '
1-12
1. Chemical Resistant Resins
3-21
Fiber-glass pipe manufacture.
8/13/74
R-2C
r
. . ` -
Chemical resistant resin.
0.5 0.5 0.5
1.4
Airless.
1.4 *
. Operator spraying mold with resin. (Ro glasss)
Operator adjacent to automatic spray machine coating ( 20* mandrels. Operator wiping mandrels. In area near spraying.
55 S3 35
23 14
.3*5 . 3-7
*20
Ship coating.
10/3/74
Chemical resistant resin chopped fiber glass.
0.7 0.7 0.7
Air-supported wand.
*.
*
Roll-out man. In
spraying area about
1/4 of time.
Operator spraying ' Ship hull In Cry
dock.
(5 41 23
Based on total formulation as sprayed.
-. .
..
IASU lit fccntl-ucdl BEStB SAStO STSTtlS
Saeple Oesloation
Cerrereial Aoollcatten
tl - tOQTT RES CVS
A. filled t raxy
H Ship coating.
Oate ' 10/2/74
Binder
Approx-' *
irate *. X asbestos
Saray Cun Type
.
Epoxy prlnec
l.S Airless.
t-10
'
1.5
8-10
High build poxy-
0 Air supported.
1-27 0-1
m
i
.
. 0
k,,
J. Epoxy - Coal Tar
IMS
Coating dry dock. 10/1/74
Epoxy Coal-tar, solvent.
1
Airless.
K-l
- -
1.
. C-3
Coating pipe interiors.
*
III - AllCTD RESn PAINT
B-7
Painting
10/5/74
building exterloe ;
1-35
1
.'. , -
*. .
Alkyd resin.
12
. tt
Air-Supported rand.
Airless gun.
Operation
Saople ii*
Operator spraying outside A under a ship.
Operator spraying Side of ship froa scaffold.
33
8
31
. M <0
Operator spraying Side of dry deck from suspended platform.
Operator spraying
side of dry dock fren fixed scaffold.
Operator ssreylng Interior of 3", S' and 12* diaceter pipe.
11 38 37
Operator spraying building exterior
rail.
J
S
lased on total formulation as sprayed.
III. Resin-Based Systems
Binders:
(. Type: Polyester resins, alkyd resins, epoxy resin alone or in combination with coal tar or equivalent resin.
. Content: Range from ~61 in zinc-rich primer to~>49% for heavily filled alkyd to 99+ for polyester laminating resins.
Main Uses: Fiber glass reinforced boats, pipes, shower stalls, and
similar articles.
.
Maintenance coatings for steel and concrete.
Intumescent and zinc-rich paint.
..
Exterior alkyd paints.
>
^
*. y *
.
Asbestos Ranoe: Up to 12% by weight of the total formulation as sprayed.
. Supporting Data: Table III.
ASfHatTIC *J*0 COl-T *St0 STSTtnS
1
I,
$e*le Infill ftetlon
r-42
A-JI 3
a
3 3 -
9
-
Ccrrercfel Application
Date
Auto undercoatIng,10/7^ (Sound deadener)
'm
ffbreted Roof CMtin),
9/2S/7*
m 10/11/7*
m 3/2/7* m 10/11/7*
Emulsified asphalt ffbrated roof coating.
12/18/74
1
tinder Cut beck asphalt
M
m m
Steam refined, emulsified asphalt.
Approi- W Irate *tt. : Asbestos
IS
Spray Cun Type Airless.
IS . .
m Air supported,
sm
< Airless tm
3 Atr supported
3 . Airless
Operation
Operator spray**) on out* body.
m
Operator spraying gainst vertical Steel surface.
at
mm
mm
Operator spraying against vertical steel surface.
e
Sumle tine (Hio.l
7
(
-
lirlarni Asbestos Concentre^ (f bsi-/ei
OJl
I.J
0.0X
. .. -. 43
0.11
0.03 0.07
0.1*
23 0.17
^ tased on total formulation as sprayed.
.; "
. .
.Binders:
.
Type:
Cutback and emulsified asphalt and coal-tar materials or equivalent.
Content: Typically^45%.
Main Uses: Automotive undercoating and sound deadener, roof coatings foundation coatings.
Asbestos Content: Up to-15%.
.r. '
:
Supporting Data: Table IV.
\r
;/
\9
i
i
i
Sx-pl*
C;-r<rcii1 acolieatien
1 j. mran P.ES!** (Pol /euer)
t
1'
i
i
9
i 1529-4M
ii
Holding furniture parts
1
i
i
ii
ii . t'
*
4
i
1
i-
1929-82-3
1329-82-4 1924-82-5
M3
i-t
f **
Fabrication of reinforced fiter fits* pipe.
.
..
'
# '
'
.
*
i MS
4 .
2m jU ?
V 1-39 J
9
9 1929-84-4
h U25-84-5
j?
*
t.
%
8-20
8-25
*
> *
1
1
1
!t
Fabrication of FSP . tints end pipe.
*
'0
Production of artificial bricks.
Production of fiber (less boets.
..
.
i
MRCOPht A5EEV05 MCt CIttTS -
C8tioiirt am 5tir..-. rr orwr-w> iss'f^s'CGnmntv;
-
Kate
tesin
3/15/72
Polyester
_
12/6/72
Asbestos
Tyne
.Approx. t
Operation
*
Sample
Tine
86-244
.
0.0S 0.05
Operetor hind sanding Snail ports.
Open tor running power under ith integral hood.
45 45
0.3 `Operator sanding ind grinding molded parts.
t' iood hood ventilating -tystea on grinder.
23
Airborne AsteStJt fiber Concentration
IFibe-s/cc >t>
0.002 0.002
0-3
-.
2/27/73
m m
Polyester
~
86-144
*
V13/74 -
- .
1
*6-244
'
* ,'
' '
2-3
2-3 2-3
1.4
1.4
Operator pulls pipe lion} line. Sam off tod with circular sax.
19
Sane operation as 1929-
82-3.
49
Operator rreing end of 4S pipe with scarfing sacnine.
Operator shaping end of pipe with bell 4 spigot HChine.
18 *
Operator euttir.j off pipe end and light crindin;
00 exterior Surface.
17
8/13/74
Polyester
.
- *-
86-244
1.5
'*7 .:
U U
Operator grinding inside f 13' l.D. x 2$' tank.
Continuation of sane operation as 1-25.
Operitor'.grfnding edges Of aiscelianecus saa11 parts.
16 S
25
3/8/73
.
Polyester
- **
11/28/74
Polyester
'
86-244
2.0
j
2.0
8G-244*
0.5
, 0.5
Operator cutting with sabre saw.
Operator tritsfng with sabre saw.
a
39
Operator grinding inside f boat hull.
Operator grinding.
ii 4
0.1
0.1
0.04
.
. 0J
. .
0.2
0.4 0.3
" -; 0.3
0.1
0.2
. 0.0
oa>
t*
TABLE VI
o o cc
o UJ
to o
in CO X
wCO
X
CO
to 2c:
ZD to
8
cc
UJ
CD
to
o
--
to to
O UJ
K to LU
tcCoD
CD
to CD
UJ z
cc
coCOc O t_>
to
UJ ZD O c
to
LU CC
U. O
CD
CC CD
c
c o
*r
2: e r-. t-
OOo
+> o t- > C
U CJ>
<v L
tn CM
u QJ 4J p
--J O ai o
o
oo
o
o
O
o
c ftj
-O <c
a. -*->
5T
o
o
o
oo
oo
o S LU o
.
c
s. 3
o
o CD LO LO cc
O
1. ^
.
OJ LO
C r*. S-
JO k r-- 9*
o a> a u>c
u. u c 0) i.
u *r-
o
A V O (A
s
CJ r--
o
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o
CM
CM CM
CM
o
4-> Sv> or
C-4J c= o o o S Lu o
*
o r-- o
(U -Q
r3 o
JO 1- -o ooinc
CA fr-
c
- -_ -
T
i.
01 CD i. rc om
o JO.
cn 4- C a
c rO O r-- o o o r^. CM to o
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