Document mm83g9BRYqJ8yzpBOyoRM7xYg

ORIGINAL 1 1 2 IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 160th Judicial District 3 4 5 IN RE: ALL ASBESTOS PERSONAL INJURY CASES FILED IN DALLAS, 6 TEXAS 7 8 West Conshohocken, Pennsylvania 9 Wednesday, April 29, 1992 10 TRANSCRIPT of testimony of JOHN J . 11 TABBUTT, as taken by and before Sean M. 12 Fallon, a Federa 11y-Approved Registered 13 Professional Reporter and Commissioner of 14 Deeds of the Commonwealth of Pennsylvania, a t 15 the offices of Sherr, Joffe & Zuckerman, 16 P.C., 200 Four Falls Corporate Center, 4th 17 Floor, commencing at 10:00 o'clock in the 18 forenoon. 19 20 21 22 23 230 South Broad Street 11th Floor 24 Philadelphia, Pennsylvania 19102 (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll l (609) 392-3543 TRENTON 1 2 A P P E A R A N C E S: 3 BARON Sc BUDD , P . C . BY: C. ANDREW WATERS, ESQ. 4 The Centrum 3102 Oak Lawn Avenue, Suite 100 5 Dallas, Texas 75219 Attorneys for Plaintiffs 6 McGUIRE WOODS BATTLE & BOOTHE 7 BY: JAMES F. STUTTS, ESQ. One James Center 8 Richmond, Virginia 23219 Attorneys for Defendant, 9 Westinghouse Electric Corp. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL 2 (609) 392-3543 TRENTON 3 1 2 INDEX 3 WITNESS PAGE 4 JOHN J. TABBUTT 5 By Mr.Waters 4 6 7 EXHIBITS 8 NUMBER DESCRIPTION PAGE 9 Ta b b u 11 -1 Letter, April 21, 1992, 1 0 with Notice of Deposition attached 28 11 T a b b u 11 -2 Process Specification 600433 159 12 Tabbutt - 3 Process Specification 600729 15 9 13 14 15 16 17 18 19 20 21 22 23 24 (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HHL (609)392-3543 TRENTON 4 1 -JOHN J. TABBUTT2 JOHN J. TABBUTT, aft e r having been 3 first d uly sworn , was examined a n d t e s t i f i ed 4 as foil o w s : 5 MR . STUTTS: I would 1 i k e to read 6 Andrew Roberts' -- at least the des i g n a t i o n 7 for Mr. Tabbutt. 8 MR . HATERS: I think i t ' s the same 9 as that found in the Deposition Not ice. Just 1 0 compare to make sure. 1 1 MR . STUTTS: Okay. 1 2 M R . HATERS: First page is the 1 3 designation and then f o llows the -- 1 4 MR . STUTTS : That's right. 1 5 MR . HATERS : I just kind of 1 6 skimmed his . I believe it's the same. 1 7 MR . STUTTS : All right. He don't 1 8 need to do that. 1 9 EXAMINATION 2 0 BY MR . HATERS : 2 1 Q. Could you state your full name for 22 the record. 23 A. John J. Tabbutt, T-a-b-b-u-t-t . 24 Q. How are you presently employed? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (g09) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 5 1 -JOHN J. TABBUTT2 A. I beg your pardon? 3 Q. How are you presently employed? 4 A. I am presently employed. 5 Q . How or by whom? 6 A. My employer is Westinghou.se 7 Electric Corporation. 8 Q. And what is your position with 9 that company? 1 0 A. I'm district service manager for 1 1 the Westinghouse Power Generation Service 1 2 Division. 13 Q. Power Generation Service 1 4 Division. How long have you been in that 1 5 position? 1 6 A. Since 1980. 1 7 Q. So since 1980 you have been the 1 8 district service manager? 1 9 A. Correct. 2 0 Q. Have you had your deposition taken 2 1 before? 22 A. Yes, I have. 23 Q. In how manyinstances? 24 A . Two . (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HU L (609) 392-3543 TRENTON 6 1 -JOHN J. TABBUTT- 2 Q. And when was the most recent? 3 A. Two years ago. 4 Q. Where was that? 5 A. This room. 6 Q. Was that in connectionwith an 7 asbestos case or asbestos cases? 8 A . Yes. 9 Q. And the previous time? 1 0 A. In Philadelphia. 1 X Q . And how long ago was that? 1 2 A. About the same time frame. 1 3 Q. Other than those two times have 1 4 you ever given your deposition before? 1 5 A . No. 1 6 Q. What was the differencebetween 1 7 those depositions, to the extent that you are 1 8 aware of any, what was the different in 1 9 purpose or the difference in focus? 2 0 A. I really don't think there was any 2 1 difference. 22 Q . As far as you can recall, your 2 3 testimony was similar or the same? 24 A. I believe so. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HfLL (609) 392-3543 TRENTON 7 1 -JOHN J. TABBUTT2 Q. Did you review any documents in 3 preparation for your deposition? 4 A. Yes , I did . 5 Q. Tell me what you reviewed. 6 A. Process -- Westinghouse process 7 specifications, Westinghouse material cards, 8 proposals -- Westinghouse proposals, 9 contracts, subcontracts. 1 0 MR. WATERS: Are you going to 1 1 furnish those materials to us? 1 2 MR. STUTTS: I'll tell you what 1 3 he's reviewed. What he's reviewed are the 1 4 documents that were produced and that you all 1 5 copied and that's all. 1 6 BY MR . WATERS : 1 7 Q . Where is your office located, by 1 8 the way? 1 9 A. My office is located in Radnor, 2 0 Pennsylvania . 2 1 Q . Is that close by? 22 A . It's about ten minutes from here 23 Q How long have you been there? 24 A . Six months. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HIL L (609) 392-3543 TRENTON 8 1 -JOHN J. TABBUTT2 Q. And prior to that? 3 A. Bala Cynwyd, B-a-l-a capital 4 C-y-n-w-y-d, Pennsylvania. 5 Q. Is that in the vicinity, as well? 6 A. About ten minutes. 7 Q. Here you in that office the entire 8 time from 1980 to six months previously? 9 A. Right. 1 0 Q. Tell me generally what it is Power 1 1 Generation Service Division does. 1 2 A. The Power Generation S ervice 1 3 Division has responsibility within 1 4 Westinghouse for the installation, 1 5 maintenance, and repairs of the pr o du c t s 1 6 manufactured by the Power Generati on Business 1 7 Unit. 1 8 Q . And what sorts of products does 1 9 the Power Generation Business Unit 2 0 manufacture? 21 A. The Power Generation Business Unit 2 2 presently manufactures an assortment of - 23 variety of steam turbines, combustion turbines 24 and generators. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 9 1 -JOHN J. TABBUTT2 Q . And for how long has that been the 3 case, that t h o s e were the things that they 4 manufactured? You said "now" in your response 5 earlier, that that's what they make now. 6 A . That1 s correct. 7 Q So, I guess, how long has that 8 the case? 9 A . Those particular products that I 1 0 had mentioned they've always made. 1 1 Q. And when you say always, you mean 1 2 as far as back as you can recall? 1 3 A. As far back as I can recall. 1 4 Q. Are there some other things that 1 5 they used to make that they no longer do, that X 6 you can recall? 1 7 A. He used to manufacture heat 1 8 transfer equipment, which consisted of 1 9 condensers, heaters, pumps, circulating water 2 0 pumps, condensate pumps, air removal 2 1 equipment, and what I'm going to class as 22 small steam turbines, mechanical drive steam 23 turbines . 24 Q. Hhat was your position immediately (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HIL L (609) 392-3543 TRENTON 10 1 -JOHN J. TABBUTT2 prior to 1 98 0? 3 A . Assistant manager. 4 Q . And where were you located as the 5 assistant manager? 6 A . Philadelphia . 7 Q How long were you there in that 8 pos ition? 9 A. Approximately five years. 1 0 Q '75 to '80? 1 1 A . Yes . 1 2 Q . Let me backtrack for a second t 0 1 3 your work as a district service manager. What 1 4 have your duties entailed in that position 7 X 5 A . The Power Generation Service 1 6 Division covers the United States and we have 1 7 various local district offices who are 1 8 responsible for all the customers within its X 9 geographically assigned area, so I'm 20 responsible for the servicing of industrial 2 1 and electric utility customers within the 22 mid-Atlantic area. 23 Q. Is there someone who has a similar 24 title to you who is responsible in, for (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 11 1 -JOHN J. TABBUTT2 instance, the southwest of the United States? 3 A . Do you want to give me a state? 4 Q Texas, for instance. 5 A . Yes, we have a local office in 6 Dallas, Texas . 7 Q . And your counterpart in that 8 p o s i t i o n would be in Texas? 9 1 0 Q. Do you know his name? 1 1 A. Gary Miller. 1 2 Q. He would be a district service 1 3 manager like yourself? 1 4 A. Correct. 1 5 Q. Does Westinghouse have offices and 1 6 operations in Texas, other than in Dallas, 1 7 that you are aware of? 1 8 A. Houston, Texas. 1 9 Q. Anything else besides those two? 2 0 A. Those are the only two service 2 1 offices that we have. 22 Q. Do you have any other sales 23 offices or representatives that you are aware 24 of ? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 12 1 -JOHN J. TABBUTT2 A. In Texas? 3 Q. Um-hum. 4 A. I'm surethere are. 5 Q. He'd have togo somewhere else for 6 s p e c i f i c s on that 7 7 A For sales offices, yes. 8 Q Okay. 9 A We can provide that information. 1 0 but I ' m no t -- I don't have a listing of each 1 1 and e very office for sales. 1 2 Q . Tell me what your duties were as 1 3 an as sistant manager -- duties and 1 4 r e s p o n s i b i 1 i t i e s from approximately ' 75 to 1 5 '80. 1 6 A. The assistant manager was 1 7 responsible for answering technical questions 1 8 from our customers, assigning service 1 9 engineers as required, processing 2 0 administrative paperwork. Those were the 2 1 major duties. 2 2 Q. So, is a portion of your -- would 23 a portion of your work have been in sort of 2 4 the customer relations department? (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 13 1 -JOHN J . TABBUTT- 2 A . Yes. 3 Q. How much of your work would have 4 been involved with customer contact? 5 A. Probably fifty percent. 6 Q. And would that have been in the 7 nature of responding to their inquiries about 8 your equipment or your services? 9 A. Correct. 1 0 Q. During that time you wouldhave 1 1 still been employed by the Power Generation 1 2 Service Division? . 1 3 A. Correct. 1 4 Q. So, your interaction with 1 5 customers or clientele would have been with 1 6 regard to equipment that had previously been 1 7 sold by Westinghouse to those customers, 1 8 perhaps servicing, or other things going on? 1 9 A. The correspondence would be in 2 0 relationship to operation, maintenance, 2 1 repairs or installation of any of the products 22 that we had previously discussed. 23 Q. Let me ask you about 24 installation. Was the Power Generation (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 14 1 -JOHN J. TABBUTT2 Service Division responsible for installation 3 of steam turbines, combustion turbines, 4 generators and the like that were manufactured 5 by Hestinghouse? 6 A. Hestinghouse Power Generation 7 Business Unit is a manufacturer of steam and 8 combustion turbines and generators. Each unit 9 that's sold is rather unique, none of them are 1 0 really the same. Traditionally the way the 1 1 process worked was Hestinghouse would receive 1 2 requests for quotation from either a customer, 13 such as Texas utilities, or from an architect 1 4 engineer, such as Brown and Hoot, R-o-o-t. He 1 5 would respond to that request for quotation 1 6 and we would supply what the customer wanted. 1 7 Q. So, in that sense, would the -- 1 8 A. Now, if -- 1 9 Q. You were probably going to short 2 0 cut me, so it's probably better to let you go 2 1 on . 22 A. Now, if the customer desired 23 installation services, they would normally ask 24 for a quote for that, which we would respond (215) 564*0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 15 1 -JOHN J, TABBUTT2 to installing a unit, but generally we sold 3 the equipment and the equipment was installed 4 by, I'm going to call it, an installation 5 contractor. The installation contractor could 6 have been Westinghouse, but it varied on a 7 unit-by-unit basis. There could be a unit in 8 Dallas that was installed by Westinghouse and 9 there could be five units in Houston that 1 0 could have been installed by Brown and Root, 1 1 as an example. So, without really knowing a 1 2 specific unit, we really don't know. 1 3 Our records are set up o n a 1 4 unit-by-unit basis. so if you were t o give 1 5 a specific unit in a specific location w e 1 6 would be able to tell you whether or not we 1 7 installed it or somebody else installed it. 1 8 Q. Then just so I'm clear on the 1 9 relationship between the service division and 2 0 the business unit, is the service division 2 1 work sort of a subset, if you will, of the 2 2 business unit, in terms of providing services 23 that were needed andwhat not? 24 A. We are a division of the business (21S) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 16 1 -JOHN J. TABBUTT2 unit. We have the manufacturing division and 3 we also have the service division, so we 4 service what's manufactured. 5 Q. Tell me a little bit about sort of 6 the range of issues that you would have dealt 7 with in your time as an assistant manager, 8 vis-a-vis the clients or the customers. Would 9 this have been all across the board kinds of 1 0 things you would have talked to customers 1 1 about with relationship to the products or 1 2 installation, repair, maintenance, that sort 1 3 of thing? 1 4 A . It w a s a fairly broad spectrum, 1 5 Q Did y ou travel in that capacity 1 6 A . Yes, I did . 1 7 Q . Would you go to the location of 1 8 the plant or the equipment or whatever and 1 9 provide your a d v i ce or comments in that way ? 2 0 A . I m a d e trips to various site 2 1 locations for cus tomer meetings, 2 2 Q . A n d w hat would you discuss at 23 those meetings? 24 A . Techn ical questions, repair (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (809) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 17 1 -JOHN J. TABBUTT2 questions . 3 Q. So that if the customer had a 4 question or a problem or a concern they could 5 contact you? 6 A. Um-hui, 7 Q. And you were there to provide that 8 service on behalf of Mestinghouse? 9 1 0 Q . ' And if i t was something that you 1 1 didn't feel q u a 1 i f i e d to address you could 1 2 refer it el s ewhere? 1 3 A. If there were a technical issue 1 4 that I would be unable to answer I would 1 5 p r o v i d e the answer to the customer. but 1 6 have to go to other sources to get that 1 7 answer, such as, i.e., engineering department. 1 8 Q. Did the Power Generation Service 1 9 Division provide any circulars or publications 2 0 or mail-outs that went to customers on a 2 1 routine basis? Just sort of industry 22 information, that sort of thing? 23 A. The Power Generation Service 24 Division did not put out bulletins, but the (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 18 1 -JOHN J. TABBUTT- 2 Power Generation Business Unit did. 3 Q. And would those typically be 4 mailed or sent to customers who had purchased 5 some of these items, steam turbines, 6 combustion turbines, generators? 7 A. They would be sent to whomever the 8 bulletin applied to. Again, each unit was 9 different, so a bulletin may not apply to all 1 0 customers because the equipment is different. 1 1 Q . So would you have different 1 2 bulletins about steam turbines and different 1 3 bulletins about combustion turbines? That 1 4 sort of thing? 1 5 A. Even more detailed than that. 1 6 Q . Even more specialized? 1 7 A . Yes. 1 8 Q. Here those a regular publication 1 9 or is it just they came out when there was 20 newsthat needed to be sent out? 2 1 A. The publications have always come 2 2 out and still continue to come out. 23 Q . On a regular basis? 24 A. On a routine basis. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL ($09) 392-3543 TRENTON 19 1 -JOHN J. TABBUTT- 2 Q . How often do they come out? 3 A. As required basis. 4 Q. Perhaps I'm misunderstanding, but 5 I'm hearing two different things. To me there 6 is a regular basis, be it monthly or 7 bi-monthly or something like that, and you 8 said "as required," and that implies to me 9 that if there is something that's newsworthy 1 0 they send one out, but they don't send one out 1 1 on a routine basis unless they've got 1 2 something specific they want to say. 1 3 A. There is not a monthly newsletter, 1 4 if you will. The bulletins come out, again, 1 5 on an as required basis with no specific time 1 6 frame . 17 Q. Tell me what you mean by as 1 8 required, so I understand. 1 9 A. As an example, if there is a 2 0 specificproblem that caused damage, we have 2 1 an obligation to notify our customers that 22 have the same piece of equipment that there 23 was a problem and advising them what the 24 problem was and what the corrective action (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Mil L (609) 392-3543 TRENTON 20 1 -JOHN J. TABBUTT- 2 should be. 3 Q. And again that bulletin advising 4 of a specific problem with a specific piece of 5 equipment or whatever would be specialized in 6 the sense that it would be sent only to the 7 people who needed to know that information, is 8 that right? 9 A. Only to those users that the 1 0 bulletin would apply to. X 1 Q. Can you tell me some of the names 1 2 of some of the bulletins, if youknow. 1 3 A. There are basically three types of 1 4 bulletins that are presently sent to our 1 5 customers. Those bulletins are categorized 16 as, one, customer advisory letters. Number 1 7 two is operation and maintenance memos, known 1 8 as OMM's. And three is availability 1 9 improvement bulletins, which are known as 2 0 AIB's, so you have CAL's, OMM's and AIB's. 2 1 Q . And that's the case at the present 2 2 time? 23 24 Q. And how long has that been the (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 21 1 -JOHN J. TABBUTT2 case, to your knowledge? 3 A . Westinghouse has always s e n t out 4 b u 1 1 e tin s . The three des ignations I g a v e you 5 as w h a t w e are presently sending ou t , th e y 6 have bee n coming out, I want to say t for ten 7 years w i th that nomenclature. 8 Q Prior to that was there s o m e thing 9 s i m i 1 ar , j ust perhaps not called th e s a m e 1 0 thing 7 1 1 A . Correct. X 2 Q Let's go back to your c a r e e r path. 1 3 going back wards in time. Prior to 1975 what 1 4 was your job description? 1 5 A. I was a field service engineer 1 6 from 1967 to T85 and X was responsible for -1 7 Q. To '85? X 8 A . To '75. 1 9 Q. Continue. 2 0 A. I was responsible for the 2 1 installation, repair and maintenance of our 22 equipment at customers' site locations. 2 3 Q. Were you still in the Atlantic or 2 4 mid-Atlantic region? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HIL L (609) 392-3543 TRENTON 22 1 -JOHN J. TABBUTT2 A . Cor r e c t . 3 Q And presumably that job would have 4 entailed travel , as well? 5 A . Yes 6 Q How did your duties differ from 7 your work as an assistant manager? 8 A . Fie Id engineer's duties were site 9 specific. You are assigned to one customer 1 0 and one site, one turbine generator, whereas 1 1 the assistant manager and manager were 1 2 responsible for all equipment, again within 1 3 that geographical territory. 1 4 Q. Mould you personally supervise the 1 5 installation, repair and maintenance of 1 6 equipment? 1 7 A . Installation, again, was a 1 8 contractual obligation. Me provided technica 1 1 9 assistance to our customers on site. 2 0 Q If you are not actually 2 1 contracting to do the installation are you . 22 going to be sort of in an advisory capacity? 23 A . If we had a contract to install a 24 unit, then we would supervise the workers. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 23 1 -JOHN J . TABBUTT- 2 Q . Okay. 3 A. If we did not have a contract and 4 we were hired for technical field assistance, 5 which is basically to answer any technical 6 inquiries that come up, but we were not 7 responsible for directing either the customer 8 orhis work place. 9 Q. But you would, presumably, in that 1 0 situation, have some degree of input into the 1 1 job that was being done, is that correct? 12 A. The principalduties of. that 1 3 position is to provide technical assistance. 1 4 Each customer varied as far as what their 1 5 requirements were. 1 6 Q. So you would respond to the 1 7 customers' -- 1 8 A. The customers' needs. 1 9 Q . Would that require an individual 2 0 such as yourself to be on site during the 2 1 entirety of the installationprocedure? 22 Again, assuming that Westinghouse does not 23 contract to do the installation, but was there 24 in an advisory or technical capacity? (215) 584-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hit L (609) 392-3543 TRENTON 24 1 -JOHN J. TABBUTT- 2 A. Again, it would vary on a 3 unit-by-unit basis. If contractually we were 4 obligated to be there for theentire duration 5 we would be there for the entire duration. 6 Q. So that's going to vary? 7 A. Yes. 8 Q. And what about repair and 9 maintenance type of work? 1 0 A. Would be the same. It would vary 1 1 on a contract-by-contract basis. 1 2 Q. Would there be some instances 1 3 where Westinghouse contracted to do the 1 4 repairs in their entirety? 1 5 A. We would accept a contract to do 16 the maintenance on a -- some type of X 7 generator, if requested by the customer. 1 8 Q. And if that were the case, then 1 9 the work would be done entirely by 2 0 Westinghouse or Westinghouse employees? 21 A. Not necessarily. Again, it would 22 depend on the specific contract requirements. 23 Q. So, it's going to vary on a 24 case-by-case basis? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 25 1 -JOHN J. TABBUTT2 A. Every unit was different and every 3 contract was different. In some cases our 4 customers would want to do a portion of the 5 work, such as remove insulation, and then 6 Westinghouse would come in and pick it up from 7 that point on. A lot of the utilities did 8 that because w e basically don't have our own 9 insulators, s o , therefore, we would 1 0 subcontract and put a markup on it, s o i t was 1 1 cheaper for the utility to just hire the same 1 2 company without the markup. That is jus t one 1 3 example . 1 4 Q I should backtrack and go - - I 1 5 know you've been deposed before, but I s h o u 1 d 1 6 go through a couple of the ground rul e s . I 1 7 don't think we'll have any problem, but just 1 8 to get it on the record. 1 9 You need to wait until I fin i s h my 2 0 question, you are doing a fine job of that. I 2 1 need to let you finish your answer, I ' m trying 22 to do a good job of that, and we need to make 23 sure we get everything verbal, no nods of the 24 head, that sort of the thing, so the court (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll l (609) 392-3543 TRENTON 26 1 -JOHN J. TABBUTT2 reporter can have a good record. 3 A . Um-hum . 4 Q. You've been designated by 5 Westinghouse Corporation as its employee or 6 representative most knowledgeable about, and 7 I'll go ahead and quote the record, 8 Westinghouse ' s specification for use of 9 asbestos-containing insulation materials on, 1 0 in, or around turbines manufactured by 1 1 Westinghouse. The individual or individuals, 1 2 which is yourself, designated should also be 1 3 able to testify as to how, where and why 1 4 asbestos or asbestos-containing insulating 1 5 substances or products were incorporated 1 6 into, onto or otherwise made a part of 1 7 defendant's -- that's Westinghouse's -- 1 8 turbines. 1 9 Is that a subject that you are 2 0 generally familiar with? 2 1 A. Yes . 2 2 q . Are you aware of anyone else at 2 3 Westinghouse you would consider to be more 24 knowledgeable on this subject? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 27 1 -JOHN J . TABBUTT2 A . Not that I am aware o f . 3 Q . So, as far as you ar e aware. you 4 would be the person at Westingho use 5 Corpo ration most knowledgeable o n the is sues 6 just listed. as far as you know? 7 A . I don't know if I wo u 1 d be 8 c o n s i dered the most knowledgeabl e, but I ' m 9 aware of the facts . 1 0 Q You are not aware of anyone else 1 1 who would be more knowledgeable, then? 1 2 A. I'm not aware of anyone. That 1 3 doesn't mean that that person doesn't exist. 1 4 Q The Notice of Deposition, 1 5 which I ' 11 have the court reporter mark a s 1 6 E x h i b i t 1 , with the cover letter as part o f 1 7 that. dated April 21, contains a number o f 1 8 categories of documents that were requested to 1 9 be produced at your deposition. 20 Did you have an opportunity to 2 1 review that Notice of Deposition? 22 A . I don* t believe I received it 2 3 Q . 11 has not been shown to you? 2 4 A . I don' t remember any document (215) 664-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hill (609) 392-3543 TRENTON 28 1 -JOHN J. TABBUTT2 I was required to bring documents. 3 Q. Did anyone advise you that it was 4 necessary to bring documents or to look for 5 documents or anything of that nature? 6 A . No. 7 (Exhibit Tabbutt-1 is marked for 8 identification.) 9 MR. WATERS: In light of the fact 1 0 that n o documents have been produced at the 1 1 time o f the deposition. as attorney for the 1 2 plain t i ffs it would be necessary for us t o 1 3 preserve our right to continue the deposition 1 4 at a later time after there has been a 1 5 production of documentation. 1 6 I understand it's defense 1 7 counsel's position that all the documents 1 8 required to be produced have been produced as 1 9 documents that were produced in other 20 litigation. 2 1 It's our position that the judge 22 initially required that production several 23 months ago, I think after a hearing on 24 February 14, 1992. There was no restriction (21S) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 29 1 -JOHN J. TABBUTT2 on further production, as long as it was 3 limited in scope and relevant to the inquiry 4 and otherwise discoverable under the Texas 5 Rules of Civil Procedure. 6 H a v i n g said that. w e reserve our 7 right to file a mot ion to get the documents 8 and to continue the depos ition a s necessary. 9 BY MR . HATERS : 1 0 Q. Have you discussed your 1 1 anticipated testimony in this case with 1 2 anybody besides your attorneys? 1 3 A . No. 1 4 Q . Have you had any discussions with 1 5 anyone besides your attorneys in the past five 1 6 years about the possibility of exposure to 1 7 asbestos while working on Westinghouse 1 8 turbines or working in the vicinity of 1 9 Westinghouse turbines? 2 0 A . Havel talked with anybody other 2 1 than my attorneys - - I don 't understand the 2 2 question. 23 Q . L e t m e ask i t again. I'm not 24 interested in what you ' v e discussed with your (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hill (609) 392-3543 TRENTON 30 1 -JOHN J. TABBUTT- 2 attorneys . 3 Other than discussions with your 4 attorneys have you had any conversations 5 within the last five years with anyone 6 pertaining to the possibility of or prospect 7 that someone might be exposed to asbestos 8 while working on or in the vicinity of 9 Westinghouse turbines? 10 A. Probably frequently. 1 1 Q. okay. And in what context would 1 2 those have occurred? I mean, just -- let me 1 3 strike that question. 1 4 With whom do you specifically 1 5 recall having conversations of that nature? 1 6 A. Employees and also owners of 1 7 equipment. 1 8 Q. When you say employees, you mean 1 9 Westinghouse employees? 20 A. Correct. 2 1 Q. Let me focus for a moment on 22 owners of equipment, your customers. In that 23 context tell me how the discussions have 24 arisen. I mean, have they come to you for (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 31 1 -JOHN J. TABBUTT- 2 advice? Have you given them advice? What has 3 been the nature of the discus sion? 4 A. Many utilities and power plants 5 have instituted programs for insulation 6 replacement -- I should say, removal and 7 replacement. 8 Q . Um-hum . 9 A. That normally enters into a 1 0 discussion on turbine generator schedule, 1 1 maintenance schedules, outage schedules, what 1 2 have you. Again, it's fairly common in 13 today's world that theinsulation is replaced. 1 4 Q. Well, have customers come to you 1 5 soliciting advice about how to go about 1 6 removing the insulation? Is that the context? 1 7 A. Westinghouse really never was what 1 8 I would call -- we were a turbine generator 1 9 supplier. Our technical assistance related 20 basically to the turbine generator proper. 2 1 Turbine insulation was always done by a 2 2 contractor, if you will, just as replacement 2 3 is being done nowby contractors, or the 24 utilities, itself. If the utility, itself. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hill (609) 392-3543 TRENTON 32 1 -JOHN J. TABBUTT- 2 had its own pipe coverers slash asbestos 3 workers, insulators, they would do it 4 themselves or they might sub it outto another 5 insulation contractor. Normally we didn't get 6 involved with that, only as a matter of 7 scheduling type thing. 8 Q. Well, are you telling me, then, 9 that your conversations with customers with 1 0 regard to asbestos insulation on or in the 1 1 vicinity ofturbines or generators would have 1 2 been limited to scheduling issues? 1 3 A. As far as the replacement times -- 1 4 removal and replacement. 15 Q. Okay. 1 6 A. I mean, the utility -- again, it's 1 7 a unit-by-unit specific case. 18 Q. Sure. 1 9 A. Varies by customer and by plant 2 0 and again by unit. But usually the utility 2 1 makes those arrangements. Whether it's to be 22 replaced or whether it has to bere-used. 23 It's their equipment. It isn't Westinghouse's 24 equipment. Sold to themmany years ago. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 33 1 -JOHN J TABBUTT2 Q . Sure. 3 A. So, we don't -- again, it's rare 4 that we get involved in that process. 5 Q. Again, just talking for the moment 6 about the past five years, have you had any 7 discussions with customers or anyone else 8 where you advised the possible dangers or 9 hazards of this business, asbestos insulation, 1 0 or was that common knowledge? 1 1 A. I want to say that, again, most 1 2 utilities have been in some type of 1 3 encapsulation and/or removal replacement 1 4 program for many, many years. It's not a new 1 5 issue. 1 6 Q. So, it's not something that you, 1 7 as a Westinghouse employee in these past five 1 8 years, as we've been discussing, felt it 1 9 necessary to educate them about? 2 0 A. Correct. 2 1 Q. Okay. At this stage, like I said, 2 2 you would consider that to be common 23 knowledge, the dangers? 24 A. The power plant, itself, is -- you (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 34 1 -JOHN J. TABBUTT2 know, has a lot of insulation in a lot of 3 locations and a lot of parts and pieces. I'm 4 trying to think of a location where I've been 5 where there wasn't some type of program that 6 was going on, and I'm not aware of any 7 specific location. 8 Q . That's fin e . Let me go b a c k to my 9 specific question and then w e can move o n . 1 0 A . Okay. 1 1 Q And I 'm going to ask him to read 1 2 it back. I don't think you responded to it 1 3 and I want to go ahead and -- do you mind 1 4 reading the last question back. 1 5 (Pert inent portion of the record 1 6 is read.) 1 7 BY MR . WATERS : 1 8 Q. If you don't consider it to be 1 9 common knowledge, that's fine, I just need to 20 know if that's a yes or no. 2 1 MR. STUTTS: I think he's already 22 answered the question. He talked about what 2 3 others have done with respect to insulation 2 4 being on the equipment. Are you asking (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 35 1 -JOHN J. TABBUTT2 whether he considers that to be common 3 knowledge or whether that -- whether he infers 4 from that that there was common knowledge that 5 there were dangers from asbestos? 6 MR. WATERS: That's fine. I just 7 want to know what his opinion or his personal 8 knowledge is. 9 BY MR . WATERS : 1 0 Q. Do you consider it to be common 1 1 knowledge among your customers, if you will, 1 2 that asbestos is a hazardous substance and 1 3 needs to be dealt with with care? 1 4 A. I would say, again, that most of 1 5 the customers that I know recognize the 1 6 dangers of airborne asbestos fibers and they 1 7 are taking whatever steps are necessary to 1 8 eliminate and/or reduce that hazard. 1 9 Q. Let me keep backtracking. Tell me 20 what you did prior to or during and prior to 2 1 1 9 6 7. 2 2 A. 1967 X joined the corporation. 23 Q . In '67. 24 A . Right. (21S) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 36 1 -JOHN J . TABBUTT2 Q . What did you do prior to that? 3 A . I was in school. 4 Q . Where did y ou go to school? 5 A . Wentworth I nstitute of Technology 6 in Boston / Massachusett s . 7 Q Graduated i n '67? 8 A . Graduated i n '67, went into the 9 Westinghous e field serv ice engineering and 1 0 training program at Les ter, Pennsylvania in 1 1 July of r 6 7 . Went from there to be a field 1 2 engineer i n Philadelphi a . 1 3 Q Are you a 1 icensed engineer? X 4 A . No . 1 5 Q . What deg r e did you get? 1 6 A . Mechanic a 1 engineering. X 7 Q . Have you e er been a licensed 18 1 9 A . A licensed professional engineer? 2 0 Q . Yes. 21 A . No . 22 Q And how old a man are you? I 23 should be able to figure that out. 24 A . Forty-five. (215) 5644675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 37 1 -JOHN J . TABBUTT- 2 Q. Am I correct inassuming that, as 3 a field service engineer -- well, let me ask 4 it this way: The entire time you've been 5 employed by the Power Generation Service 6 Division, is that correct? 7 A. By Westinghouse. 8 Q. I guess I better get that 9 clarified. From '67 to '75 you worked as a 1 0 field service engineer. What division were 1 1 you working for? X 2 A. At that time it was called the 1 3 Lester Divisions. 1 4 Q. Lester? 1 5 A. L-e-s-t-e-r. 1 6 Q. Because of the place? 1 7 A. Right. At that time thetraining 1 8 programs were conducted at our manufacturing 1 9 plant and the service department was a 2 0 department of the manufacturing plant. It 2 1 wasn't until years later that we actually . 22 became a division of Westinghouse. 2 3 Q. Do you know when that would have 24 been, approximately? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 38 1 -JOHN J . TABBUTT2 A . I'll say 1969 or '70. 3 Q Sometime fairly shortly after you 4 started? 5 A . Right , right. 6 Q . Hell, did you have the Power 7 Generation Busine ss Unit as a continuing 8 entity the entire time? 9 A . T h e P ower Generation Business Unit 1 0 has been called d ifferent things, but it's 1 1 basically been th e same, although it's had 1 2 different names. 1 3 Q. What was it called prior to being 1 4 named the Power Generation Business Unit? 1 5 A. Steam Turbine Division was one 1 6 name. Lester Divisions was one name. But 1 7 each name had the same responsibilities and 1 8 that was for the manufacturing of power 19 generation equipment. 2 0 Q. Did you have the same structure in 2 1 the sense that Power Generation Business Unit 22 contained within it either the Power 23 Generation Service Division or its 24 predecessor? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 39 1 -JOHN J. TABBUTT2 A . Correct . 3 Q . In addition to manufacturing 4 division or its predecessor? 5 A . Correct. 6 Q Where is the headquarters, if you 7 will, of the Power Generation Business Unit? 8 A . Orlando, Florida. 9 Q . And how long has it been there? 1 0 Probably not that long. 1 1 A . Actually, it's been there for five 1 2 years . Around five years. 1 3 G And prior to that? 1 4 A . Headquarters was in Pittsburgh, 1 5 Pennsylvania. 1 6 Q. Now, as a field service engineer 1 7 where were you employed? In what -- 1 8 geographically what town? You may have told 1 9 me about that. 2 0 A. Everywhere. 2 1 Q . Did you have a n o f f i c e ? 22 A . My home 1 o c a t ion was Phi ladelphia 23 G But you were o n the road a lot? 24 A . I was on the road at numerous (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY Hit L (609) 392-3543 TRENTON 40 1 -JOHN J. TABBUTT2 locations. 3 Q. Who was your immediate supervisor 4 in that position? 5 A. My immediate supervisor was Frank 6 Horan, H-o-r-a-n. 7 Q Say that again 8 A . In the '60's. 9 Q . H-o-r-a-n? 1 0 A . Right. 1 1 G . And in the '70 ' s . 1 2 A . Larry Berley, B-e-r-l-e-y. 1 3 Q Are either of those gentlemen 1 4 still employed by W e s t i n g h o u s e ? 1 5 A. Frank Horan is deceased and Larry 1 6 Berley retired -- he's retired. 1 7 Q. Very recently or do you recall 1 8 approximately when? 1 9 A . 19 -- late '70 ' s . 2 0 Q Does he still live in this area? 2 1 A . Yes , he does. 2 2 Q . What town, if you know? 23 A . Media , P e n n s y 1 vania . 24 G . Just like it s ounds, M-e-d-i-a? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 41 1 -JOHN J. TABBUTT2 A. M-e-d-i-a. 3 Q. Is he someone you keep in touch 4 with? 5 A . Occasionally. 6 Q What kind of occasions would you 7 run into him or see him? 8 A . Retirements . 9 Q . So, during the time frame where 1 0 you were a f ield service engineer, from 1967 1 1 to 1 9 7 5 , tho se two gentlemen would have been 1 2 your immedia te supervisors? 13 1 4 Q. And would they have been district 1 5 service managers? 1 6 A. District managers, yes. 1 7 Q. Well, when you were promoted in 1 8 '75 to assistant manager would you still have 1 9 been working for Mr. Berley? 2 0 A . Berley. 2 1 Q. Is that correct? 22 A . Yes. 2 3 Q. Did you replace him when you moved 2 4 up to be district service manager? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hit l (609) 392-3543 TRENTON 42 1 -JOHN J. TABBUTT2 A . No, n o . 3 Q . Was there someone who w a s the 4 district service manager -- just te 11 m e 5 was the district service manager pr i o r t 0 6 yourself. 7 A . Joe St. Laurent, S-t. 8 L-a-u-r-e-n- t . 9 Q Did heretire? 1 0 A . No, he's located at - - he has 1 1 another posi tion with Westinghous e. He's 1 2 presently lo cated in Charlotte. 1 3 Q North Carolina? 1 4 A . North Carolina. 1 5 Q Just so I understand the 1 6 relationship , would he have been senior to M r . 1 7 Berley prior to Mr. Berley's reti reient? 1 8 A . There was an overlap period. 19 Q . What do you mean? 20 A . We had a new manager coming in 2 1 replacing a manager retiring, so we have an 2 2 overlap peri od of time where they were both 23 there . 24 Q . X s e e . (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 43 1 -JOHN J. TABBUTT2 A . Follow me? 3 G I think I un derstand. B e r 1 e y 4 would have been the one retiring -- 5 A . Correct . 6 Q St. Laurent would have been the 7 one coming in? 8 A . Um-hum. 9 Q . All right. Then he wasn't in that 1 0 position f or very long. was he? 1 1 A . Correct. 1 2 Q Where did he come from previously. 1 3 if you know? 1 4 A . He came from the Baltimore office. 1 5 Q Do you know his present position 1 6 in Charlotte? What his title is? What his 1 7 duties are? 1 8 A. Customer service manager. 1 9 Q. For the Power Generation Service 2 0 Division? 2 1 A . For the Charlotte plant, 22 Charlotte manufacturing plant. 23 Q . Any idea where he went in '80 when 2 4 you took over as district service manager ? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hill (609) 392-3543 TRENTON 44 1 -JOHN J. TABBUTT2 A. He went to our headquarters 3 organization, which at that time was located 4 in Broomall, Pennsylvania. 5 Q . What did he do for them? Any 6 idea? 7 A. He was the manager of the repair 8 services product line. 9 Q . Repair services product line. Is 1 0 that not going to be part of the Power 1 1 Generation Business Unit or is it still -- 1 2 A. Charlotte, Broomall, they are all 1 3 partof the business unit. 1 4 Q . As field service engineer, '67 to 1 5 '75, what was your regional area? Area that 1 6 you covered? 1 7 A. We wereresponsible for anywhere 1 8 in the United States. We could be assigned to 1 9 anywhere in the United States. 2 0 Q. And what regions were you assigned 2 1 to or was it just all over the map? 22 A. I've worked in numerous locations 23 throughout the United States and Mexico. 24 Q. So -- (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 45 1 -JOHN J. TABBUTT2 A . The management would try to assign 3 you within your geographical district 4 location. but obviously, i f there was n't any 5 work, you would be assigned outside of that 6 area. 7 Q So, did you do your work up in New 8 York, for instance? 9 A . Have I worked in New York State? 1 0 Q . During that ti me frame. 1 1 A . Yes. 1 2 Q How about Texa s ? 1 3 A . Visited Texas, but never worked 1 4 there . X 5 Q . How about the great State o f 1 6 Alabama? 1 7 A . Never been in Alabama. 1 8 Q Do you know a fellow by the name 1 9 of John Morykon? 2 0 A. John Morykon? 2 1 Q . Yes . 2 2 A . Yes, Ido. 23 Q . How do you know him? 2 4 A. John used to be in the same office (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hit L (609) 392-3543 TRENTON 46 1 -JOHN J . TABBUTT2 I was located in in Bala Cynwyd. 3 Q . And what -- how did he -- did his 4 duties interface with yours and how did you 5 deal with one another on a professional basis? 6 A. Me had a repair facility in 7 Philadelphia and John was the plant manager. 8 Then he got promoted to regional manager in 9 Bala Cynwyd and he was responsible for a 1 0 number of plants, so that's how I knew John. 1 1 Q. And when -- what's the time from 1 2 when you all would have worked together? 1 3 A. In the '80's, early ' 80 ' 3 . 1 4 Q . Did you ever have any 1 5 conversations with him about asbestos 1 6 insulation, the possible hazards of asbestos 1 7 insulation, that you can recall? 1 8 A. John's responsibilitywas 1 9 basically for the products manufactured by the 20 Transmission Distribution and Control Business 2 1 Unit, which I was not part of, so most of our 22 conversations were on a social basis, not on a 23 business basis. 24 Q . Well, is your answer, then, no. (215)564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 47 X -JOHN J. TABBUTT2 that you don't recall having any conversations 3 of that nature with him? 4 A. That's correct. 5 Q. One of the things that I requested 6 to be produced at the deposition was 7 photographs or diagrams of turbines slash 8 generator units so I could have you help me 9 understand how some of this stuff works. We 1 0 are not going to have that, unfortunately, but 1 1 I was wondering if I might get you to draw a 1 2 diagram of some sort to give me a general 1 3 sense of what the component parts generally 1 4 look like and how the things are going to fit 1 5 together. Would that be possible? 1 6 Understanding that these things are site 1 7 specific, as you said. 1 8 MR. STUTTS: Let me make a 1 9 comment. Many drawings were produced as part 2 0 of our earlier document production, so all 2 1 that was available. 2 2 MR. WATERS: In fact, I have some 23 of them with me, but they seem to be often 24 site specific. Maybe that's the nature of the (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 48 1 -JOHN J. TABBUTT- 2 beast. 3 MR . STUTTS : That's the nature of 4 the beast. There is no generic turbine 5 drawing . 6 BY MR . WATERS ; 7 Q. And I understand that, but just 8 so, since I am a true layman when it comes to 9 these things, would you be able to do that, 1 0 just to help me visualize a description -- I X X can have you describe to it me, but it's not 1 2 going to be nearly as helpful, unless you can 1 3 do that for me. Do you mind doing that? 1 4 A. If you have drawings here -- 1 5 Q. You would prefer to use those? 1 6 A. We can use a drawing and it will 1 7 probably be a lot easier than me drawing. .1 8 Q. Maybe that's what we should do. I 19 may need to get an extra copy or two. Tell me 2 0 generally, and again understanding that these 2 1 things are going to be size and unit specific, 22 tell me generally what plant -- why a plant 23 purchases a turbine generator unit to be used 24 and what the purpose is behind that, in a (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 49 1 -JOHN J. TABBUTT2 general sense. 3 A. The reason that a utility 4 purchases a new turbine generator is because 5 of the electrical demand increase within its 6 geographically assigned territory. Or, in the 7 case of retiring older units, again requiring 8 a new unit to replace those that they have 9 retired . 1 0 Q. What about in the case of a 1 X manufacturing plant as opposed to a power 12 plant . 1 3 A. Why an industrial customer would 1 4 buy a turbi n e ? 1 5 Q Right , a s opposed to a utility. 1 6 A . There i s -- 1 7 Q I'm s u r e there is a number of X 8 reasons . 1 9 A . There i s a lot of that going on 2 0 right now and the reason for that is that an 2 1 industrial plant may have a demand for process 2 2 steam, where it needs steam in whatever 23 process it's doing, whether it's making paper 2 4 or making steel or heating greenhouses. If it (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 50 1 -JOHN J TABBUTT- 2 has a demand for steam. then it becomes 3 attractive to them to i n s t a 1 1 a turbine 4 generator to reduce the press ure of the steam 5 for its process, at the same time to gen e r a t e 6 electricity for its own use. and to sell the 7 surplus to the utility that serves it under 8 some type of long-range contract. So it can 9 be financially attractive for that industrial 1 0 customer to do that, especially in an area 1 1 that has high electric utility rates. 1 2 Q. So, as an example, if a paper mill 1 3 were to order a turbine generator unit,if you 1 4 will, the purpose would generally be to 1 5 provide its own power, in addition, perhaps, 1 6 to utilizing the steam that results? X 7 A. Correct. 18 Q. And you saidsomething just a few X 9 seconds earlier that caught my attention. Did 20 you say that this is something that is 2 1 happening more frequently now or did X 22 misunderstand you? 23 A. No, there is a lot of what we call 2 4 co-generators. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 51 1 -JOHN J. TABBUTT- 2 Q . What is meant by that? 3 A . They co-generate for themselves 4 also for the utility and use the process 5 steam again for whatever manufacturing process 6 that they have at that specific site location. 7 Q . And are utilities often required 8 to purchase back whatever excess there is? 9 A. There are specific requirements, 1 0 location, states, et cetera. As an example. 1 1 Texas is more leni e n t and encourages t h a t more 1 2 than other states. but i t ' s a process th a t ' s 1 3 happening nationwi de , not restricted t o any 1 4 specific area. Co -gen ors really are i n 1 5 every state. 1 6 Q. For how long a period of time has 1 7 Westinghouse been manufacturing and providing 1 8 generators and turbines to manufacturing 1 9 plants in the United States, that you are 2 0 aware of? Understanding that you've only been 2 1 there since '67, but I'm sure you've had some 2 2 dealings with machinery that was installed 23 long before. 2 4 A. Sixty years. Sixty-seven years. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HIL L (609) 392-3543 TRENTON 52 1 -JOHN J. TABBUTT2 Q, So going back into the '2 0 ' s ? 3 A. Could be. Could be earlier than 4 that. 5 Q Are some of those old ones still 6 operating? 7 A. There are some units that have 8 been in service for fifty years. 9 Q. Is that right? 1 0 How do you -- what do you use as a 1 1 measure -- or perhaps a better way to put it 1 2 is, how do you differentiate between the sizes 1 3 in turbines and generators in their uses? In 1 4 other words, it would seem to me that if you 1 5 have a very small manufacturing plant you 1 6 might need a very small unit and if you had a 1 7 large one you would perhaps need a larger one 1 8 or more than one or whatever the case may be? 1 9 A. Is there some measurement or some 2 0 grading level or some numerical system to 2 1 assign a size or capacity to that sort of 2 2 equipment? 23 A . Each application is different, 24 Each application has different steam (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 53 1 -JOHN J . TABBUTT2 requireients and each application has 3 different load requirements, but the one who 4 decides that is the user, the customer. 5 Again, we respond to whatever it is that they 6 want, but again they usually provide the 7 specifications to us. Say Westinghouse, we 8 would like a unit th is size that has so much 9 steam flow or so m u c h electrical load 1 0 Q You j u s t mentioned three things 1 1 that perhaps can be helpful in that regard, 1 2 unit size, steam flow and electrical load. 1 3 Those are all things that the customer asks 1 4 for, correct? 1 5 A . Right. 1 6 Q. And then, when you say unit size, 1 7 how is that measured? 1 8 A. Megawatt output. Generator 1 9 output. 2 0 Q. And give me, if you can, what your 2 1 range is going to be, the smallest to biggest, 22 in that sense. 23 A. We have units in service from two 2 4 megawatts up to twelve hundred megawatts. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L _____________ l (609) 392-3543 TRENTON 54 1 -JOHN J. TABBUTT- 2 Q . That seems like quite a 3 difference. Again, just so I can try to 4 visualize what this is going to look like, how 5 big is a unit, physical size,that generates 6 or has output of two megawatts,approximately? 7 A. Twenty feet long, six foot high, 8 eight foot wide. 9 Q. And on the other end of the 1 0 spectrum, a generator that has an output of 1 1 twelve hundred megawatts, approximately the 1 2 size of a unit of that nature? 13 MR. STUTTS:Can X ask for a point 1 4 of clarification? 1 5 MR . HATERS: Sure. 1 6 MR . STUTTS : You said generator X 7 Do you mean the turbine and the generator 1 8 together or -- I assume you are not just 1 9 talking about the generator portion of it. 20 BY MR . HATERS : 2 1 Q. Thank you. My understanding is 22 that the two are sort of in tandem, is that 23 correct? 24 A. Not necessarily. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 55 1 -JOHN J . TABBUTT2 Q. So they wouldn't necessarily be 3 side by side? 4 A. Those are called cross compound 5 units, side by sides, and then tandem,in-line 6 units. Again, each one is different. 7 Q . Well, when you gave me the -- a A. The larger units, the twelve 9 hundred megawatt units are basically nuclear 1 0 steam turbine generators. They are massive. 1 1 If you were standing on the floor that they 1 2 are located on they would be probably a 1 3 hundred fi fty, hundred sixty feet long. twenty 1 4 foot high. thirty foot across . 1 5 Q Going back to the -- 1 6 A . One -- jus t one component of the 1 7 nuclear unit can weigh two hundred tons. just 1 8 one piece of it. Mass i v e . 1 9 Q . Going back to what you descr i b e d 20 as two by six by eight , the two megawatts -- 2 1 A . Twenty. 22 Q . I'm sorry. you're right. Twenty 23 by six by eight, would that be just the size 2 4 of the generator, itself? (215)564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 56 1 -JOHN J. TABBUTT- 2 A. No, that would be the whole unit. 3 Q. Generator and the turbine? 4 A. Um-hum. Again, these are all 5 approximations. 6 Q. Sure. No, absolutely. 7 Is it necessary to insulate or 8 place insulation over some aspect of your 9 generator and your turbine when the two are in 1 0 combination, either side by side or tandem as 1 1 you've described, or for that matter, if they 1 2 were further apart? 1 3 A. The twelve hundred megawatt unit 1 4 that we were talking about basically consists 1 5 of four separate turbines and a generator. 1 6 There is a high pressure turbine, which -- the 1 7 steam comes into the high pressure turbine, an 1 8 exhaust from the high pressure turbine, and it 19 goesinto three, what I'll call, low pressure 20 turbines. Those turbines drive one 2 1 generator. The generator is not insulated. 22 The three LP turbines were not insulated, 23 there is no insulation on them. The high 24 pressure turbine is insulated. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 57 1 -JOHN J. TABBUTT- 2 Q. Let's, again, speaking in terms of 3 this twenty by six by eight unit, how large 4 would the high pressure turbine, itself, be in 5 that unit we've been theorizing about? 6 A. About half the size. 7 Q . So ten by six -- 8 MR. STOTTS : Let me make 9 another -- make sure we are talking about the 1 0 same thing. Mr. Tabbutt was just talking 1 1 about, on this example here, of a twelve 1 2 hundred megawatt unit as having high pressure, 1 3 which is insulated, three low pressure 1 4 turbines and a generator. 15 MR. HATERS: I beg your pardon. 1 6 BY MR . WATERS : 1 7 Q . Were we talking about the twelve 1 8 hundred? 1 9 A . The twelve hundred. 2 0 Q . I apologize. I meant to be asking 2 1 you about the two megawatt unit that we 22 discussed earlier . 23 A . Um-hum. 2 4 Q . Let me go back and ask you the (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hit L _________ I (609) 392-3543 TRENTON 58 1 -JOHN J . TABBUTT- 2 same quest ions in that regard. Are you going 3 to have a similar setup? 4 A . It w o u Id be -- the two megawatt 5 unit would be one turbine, one r ^ v o i? 6 Q . Okay. Now, in that context, would 7 the turbine be insulated? 8 A. The turbine would probably be 9 insulated. 1 0 a. Given that the unit as a whole is 1 1 twenty by six by eight, how large would the 1 2 turbine , itself. be, the s i n g 1 e turbine? 1 3 A . About ten by s i x by eight. 1 4 roughly. Roughly half the size. 1 5 MR. STUTTS s Again, to make sure 1 6 we are talking about the same thing, you are 1 7 talking about a two megawatt steam turbine and 1 8 generator. 1 9 MR. HATERS : Right . 2 0 BY MR . HATERS : 2 1 Q. In a little while, once we start 22 going through these documents and I run across 23 one, we'll get a diagram and you can explain 24 this to me a little better, but again in a (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 59 1 -JOHN J. TABBUTT- 2 typical context, where on that -- I'm assuming 3 again that there is not going to be any 4 insulation on the generator, correct? 5 A. Correct. 6 Q. Where, onthe turbine, itself, 7 exterior of the turbine, are we likely to find 8 insulation materials? 9 A. It would be located on the 1 0 turbine . 1 1 Q. On the turbine, okay, which you've 1 2 described as being approximately ten by six by 1 3 eight in the context -- 14 1 5 Q. Would it be all around the 1 6 exterior of that piece? 1 7 A. It could cover the exterior 1 8 surfaces . 1 9 Q. Would it also have pipe covering 20 that runs to and from the turbine unit? 2 1 A. On the two megawatt units we 2 2 didn't have -- there is no turbine piping, if 23 you will, other than oil piping, which is not 24 insulated. The pipes to the turbine is the (215)564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 60 1 -JOHN J. TABBUTT- 2 architect, engineer, constructor and/or 3 owner's responsibility, so they take all the 4 piping to the turbine. Again, on a two 5 megawatt unit. So there is no piping. 6 Q . Make sure I understand, in this 7 two megawattunit we've been discussing, are 8 you saying that there is not going to be any 9 piping other than oil piping? 1 0 A. Correct. 1 1 Q . And in larger units -- 1 2 MR. STUTTS: Let me make sure, 13 because I'm notsure we aretalking about the 1 4 same thing, there is no piping that 1 5 Westinghouse supplies to the two megawatt 1 6 turbine, is thatright? 1 7 THE WITNESS: There is no 1 8 Westinghouse supplied piping other than the 1 9 oil piping. 2 0 MR. STUTTS: But there is piping 2 1 to the turbine? 2 2 THE WITNESS! To the turbine. 23 yes 24 MR . STUTTS I'm not sure that you (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 61 1 -JOHN J. TABBUTT2 are straight about that. 3 BY MR . HATERS : 4 Q Just to clarify agai r\ , on this 5 smallest unit that we've discuss e d , you a r 6 going to have piping, none of it supplied by 7 Hestinghouse, except the oil piping, correct? 8 A. Correct. 9 Q. It's your testimony that the oil 1 0 piping is not insulated? 1 1 A. Correct. 1 2 Q. Now as we move up the spectrum in 1 3 terms of size of these types of units, is 1 4 there some size or some point in time at which 1 5 the piping is insulated by Hestinghouse? 1 6 A. Piping is insulated by 1 7 Hestinghouse where required by contract. 1 8 Q . Aga in , so it's going to vary? 1 9 A . The insulation could be s upp1 i e d 2 0 by the utili ty , by the arch i t e c t engineer , the 2 1 constructor o f the equipment. Again, so each 22 u n it -- keep i n mind, each unit is different. 23 But, in the case of turbines that have more 24 than one cylinder, as an example the nuclear (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hit L (609) 392-3543 TRENTON 62 1 -JOHN J, TABBUTT2 unit that we talked about, the thirteen 3 hundred megawatt unit that we talked about, 4 there is piping that was furnished by 5 Westinghouse that interconnects each turbine. 6 Q. And whether or not that piping is 7 actually insulated by Westinghouse is going to 8 depend on the specifics of the contract, is 9 that correct? 1 0 A. Right, for that individual uni t . 1 1 Q. When Westinghouse manufactures a 1 2 turbine generator to be installed at a 1 3 specific site, I understand from your earl i e r 1 4 testimony that the extent of Westinghouse' s 1 5 involvement with the installation is going t o 1 6 vary depending on the contract. 1 7 A. That's correct. 1 8 Q. And the extent of Westinghouse ' s 1 9 participation in future repair or maintena nee 2 0 work is going to vary by contract. 2 1 A . Correct. 22 Q . As far as the insulation i S 23 rn ed , does Westi nghouse specify what type 24 of insulation it feels should be used to (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 63 1 -JOHN J. TABBUTT2 insulate the turbines? 3 A. Each turbine generator that 4 Westinghouse manufactures has an engineering 5 record and those records are maintained for 6 the life of the unit. The engineering records 7 contain a detailed list of all the drawings 8 used for assembly of the unit. There is. 9 within that drawing list. a drawing entitled 1 0 insulation for that s p e c i f i c unit. That 1 1 drawing defines who s u p p 1 i e s the ins u 1 a t i o n , 1 2 who installs the insulation. 1 3 Q. And when you say it defines who 1 4 supplies the insulation, will it actually 1 5 describe the products that can be used for 1 6 that purpose? 1 7 A. The detail drawing for the 1 8 insulation gives a material list and the 19 material list may be a result of the AE's 2.0 requirement, the architect engineer's 2 1 requirement, or the owner's requirement, but 22 that drawing does tell you what materials were 23 used for the insulation on that specific unit. 24 q. And is that a decision that's made (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hilt (609) 392-3543 TRENTON 64 1 -JOHN J. TABBOTT2 by Westinghouse? 3 A . The d e c i sion is made by the 4 customer. as far as whether they are go i n g to 5 supply it or whether they are going t o install 6 it . 7 Q. I understand, but as for what 8 would be the best material to use, who makes 9 that decision? 1 0 A. In some cases, in the documents 1 1 that I reviewed yesterday about the New York 1 2 cases I remember that United Engineers' 1 3 proposal and other proposal -- a request to 1 4 quote specifically stipulated what types of 1 5 materials to be used, so in which case we 1 6 would quote what the customer wanted. Again, 1 7 we are a turbine generator manufacturer and 1 8 ninety-nine percent of our questions, et 1 9 cetera, et cetera, relate to the turbine 2 0 generator, itself . 2 1 The insulation aspects of it were 22 pretty much governed by what the architect 23 engineer or the customer desired at that 24 time. We did make drawings to show how the (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 65 1 -JOHN J. TABBUTT2 t u r b i n e i s insulated as part o f the equipm e n t 3 sale. but w ho supplied i t , who installed i t 4 was. a g a i n, a unit spec i f i c d e c i s i o n . 5 Q It's going to V ary ? 6 A . Exactly . 7 Q Is the type o f ins ulation that ' s 8 u t i 1 i zed o r specified g o i n g t o vary depend i n g 9 upon the s i ze of the un its o r the amount o f 1 0 heat i n v o 1 V ed or that s o r t o f thing? 1 1 A . The insulat ion v a r ied from uni t to 1 2 unit. 0 n e of the main fact o r s that, you ha d to 1 3 look at was the tempera t u r e / s team 1 4 temperature, into the turbine. Some plants 1 5 had higher steam temperatures than others. 1 6 The higher the steam temperature generally X 7 meant the greater the thickness of the 1 8 insulation. 1 9 Q. Are you familiar with cards, I 20 think maybe four by six inch cards, that 2 1 indicate or specify certain products, 22 materials to be used when insulating 23 turbines? Have you seen those? 24 A. Material cards. (215)564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hill (609) 392-3543 TRENTON 66 1 -JOHN J. TABBUTT2 Q. Okay, material cards. Do material 3 cards have an M number? 4 A, Correct. 5 Q. Have those cards or that -- has 6 that system been in place the entire time 7 you've been working at Mestinghouse? 8 A. The card system now is -- comes on 9 fiche, but basically the same concept. 1 0 Q. Just in a general concept -- 1 1 general sense, what is the concept, just so I 1 2 can understand it? 1 3 A. If you purchase the turbine from 1 4 me there would be a drawing list telling you 1 5 all drawings that make up your turbine 1 6 generator. If you were to pick one of those 1 7 drawings and look at it, it would list a 1 8 number of details on that drawing. Next to 1 9 the detail item there is a material spec 2 0 number and the material spec number refers you 2 1 to the card that you are describing, it's a 22 Westinghouse internal material card, and that 23 card will tell you what that product is, and 24 where to get it, who the approved suppliers (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (809) 392-3543 TRENTON 67 1 -JOHN J. TABBUTT2 are to provide you with that specific 3 material. 4 Q. So the material spec number is the 5 same as the M number? 6 A. Yes . 7 Q. So that the customer will see on a 8 diagram or a drawing a reference to a number 9 which hecan use to go back to the card and 1 0 find out, for example, what type of insulation 1 1 should be used? 1 2 A. That would give theinsulation 1 3 material, correct. 1 4 Q. So is that Westinghouse's way of 1 5 advising the customer what to use if it's 1 6 necessary to replace or something of that 1 7 nature? 1 8 A. The drawings are a communication 1 9 vehicle as far as what's to be installed on 2 0 equipment. 2 1 Q. Let's just narrow our focus to 2 2 insulation material, since that's the reason 23 we are here. 24 If the customer -- just again in a (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 68 1 -JOHN J. TABBUTT2 hyp othetical sense, if the customer has to 3 re- insulate his turbine for whatever reason 4 a n d he looks a t his drawing s , at the tur bine 5 gen erator sy stem, and finds an M number, will 6 h e then be a b 1 e to referenc e through you all 7 and understa n d which partic ular products are 8 r e c ommended for that insula tion work? Have X 9 got the pic t u r e down yet or not? 1 0 A . You d o . 1 1 Q I s that how it works? 1 2 A . He could go to that card. but that 1 3 card would reflect today's standards. 1 4 Q Okay. 1 5 A . In other word s, the cards are 1 6 not - - if you have a numb er of a material from 1 7 1920 and you get the d e s c ription from 1920 1 8 it's not going to be the same description a s 1 9 it is today. 2 0 Q So the cards are changed over the 2 1 course of time? 22 A. Correct. 23 Q. The numbers stay the same, but the 24 cards change? (215) 564*0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795*2323 CHERRY HILL (609) 392-3543 TRENTON 69 1 -JOHN J. TABBUTT2 A. The numbers always stay the same. 3 There is revisions to the numbers. 4 Q. Revisions to the numbers or to the 5 description? 6 A. To the card. 7 Q. And I think I've seen some of 8 th a t . Now I want to ask you about how the 9 c a r d s themselves are generated and revised and 1 0 th a t sort of thing. How does that work? 1 1 A. The Power Generation Business Unit 1 2 in Orlando, Florida has a standards group. X 3 Q. And are they constantly monitoring 1 4 these things and changing them as necessary or 1 5 as better products become available? 1 6 A. They are always being revised. 1 7 Q. And why are they revised? What 1 8 sorts of things occur that make it a good idea 1 9 or somebody thinks it's a good idea to revise 2 0 a card? 2 1 A. Maybe the product is now obsolete, 2 2 not manufactured. That's one simple example, 23 Q. All right. Would another example 2 4 be if it was determined to no longer use (215) 564*0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795*2323 CHERRY Hit L (609) 392-3543 TRENTON 70 1 -JOHN J. TABBUTT2 asbestos-containing insulation materials, but 3 instead to try to utilize some a s b e s t o s - f r e e 4 insulation materials, would the card be 5 changed to reflect that change, or the 6 appropriate cards, I should say? 7 A. The cards would be revised to 8 reflect that, yes. 9 I would like to take a five-minute 1 0 break, if that's all right. 1 1 (Recess called at 11:35 a.m.) 1 2 (Resumed at 11:45 a.m.) 1 3 BY MR. HATERS: 1 4 Q . Right before we took a break we 1 5 were talking about the standards group. Prior 1 6 to being in Orlando where was the standards 1 7 group located? 1 8 A. The standards group was always 1 9 located at either Orlando or Lester, Lester, 20 Pennsylvania. 2 1 Q. So did they move with everybody 22 else down to Orlando? 2 3 A. Right. Keep in mind that if you 24 look at organizational charts you'll see all _________________________________________________________________________________________ (215) 564-0675 REPORTING ASSOCIATES (609) 392-3543 PHILADELPHIA (609)795-2323 TRENTON CHERRY HILL 71 1 -JOHN J TABBUTT2 kinds of headquarters charts and what have 3 you. The standards group responsible for the 4 Power Generation Business Unit products were 5 located in Lester and are now currently 6 located in Orlando, Florida. 7 Q I s that a -- what ki nd of people 8 work for the s tandards group? I s it R and D 9 people? Science people? What s ort of people 1 0 do that work? Is it engineers? Just a 1 1 combination? 1 2 A . Really a mix. 1 3 2 . I s it -- do you know someone, for 1 4 instance. who is on it now or a member of it. 1 5 I should say? 1 6 A . A s of today I really don't know 1 7 who's in that -- in the standard s group. I 1 8 normally don * t deal with them. 1 9 Q . Tell me, if you can. who, over the 20 course of your time with Westinghouse , you 2 1 have known to be a member of the standards 22 group, if any names come to mind? 23 A. Again, we rarely deal with them. 24 Most of our material is on drawings and the (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795*2323 CHERRY Hll L (609) 392*3543 TRENTON 72 1 -JOHN J. TABBUTT2 drawings refer you to the material cards and 3 the drawing says use this material, then 4 that's the material you use. 5 Q . Okay . 6 A. The people in the field had very 7 little dealings with the standards group. 8 Q . Would the folks in the standards 9 group ever come to you and say -- and ask for 1 0 input on how a certain product worked or how 1 1 e f f i c ient it was or anything along those 1 2 lines 1 3 A . No . 1 4 Q. Going back to what you said 1 5 e a r 1 i er, just to make sure I'm clear on this. 1 6 the drawing for a specific turbine and 1 7 generator would contain references to an M 1 8 number which would permit the customer to 1 9 determine what products could be used for that 2 0 particular purpose. Have I got the picture 2 1 straight now? 22 A. The engineering records define the 23 drawings, the drawings define the detail parts 24 and the material specifications for that (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 73 1 -JOHN J. TABBUTT2 part. 3 Q. And, in defining the material 4 specifications, the drawings would refer the 5 customer to the M cards? 6 A . To the material spec card, yes. 7 Q And, so, if the customer -- 8 another hypothetical, if you will. If the 9 customer needs to replace i nsulation on his 1 0 turbine and he looks at his drawing and his 1 1 drawing says -- gives him an M number, 1 2 what does he then do? Does he ring up 1 3 Westingh o u s e and say. what can I use for 1 4 this -- I ' m going to go ahead and get this 1 5 insulati on w o r k done. I don't want you guys to 1 6 do it because you guys cost too much, is that 1 7 how he gets the information? 1 8 A. They could get the information 1 9 that way, but usually the insulator looks at 2 0 the job and says that these blankets are four 2 1 inches thick, so I'm going to buy -- supply 22 you with four inch thick blankets. I'll take 23 these ones off and use them as a template. 24 Reverse engineering. {215} 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 74 1 -JOHN J . TABBUTT- 2 Q . Okay. 3 A. I don't ever remember, in my 4 career -- in my twenty-five years at 5 Westinghouse where a customer called me asking 6 for details on insulation. 7 Q. Okay. That's something that they 8 would leave to their insulator,presumably? 9 A. Either there in-house -- again, a 1 0 lot of the utilities and industries have their 1 1 own employees who do the insulation or they 1 2 sub it out to another contractor who is 1 3 frequently on site doing other things. 1 4 Q . Ui-hum. 1 5 A. But they recognize that 16 Westinghouse isn't really an insulation 1 7 contractor, so they rarely -- again, I don't 1 8 know of anybody that has ever called me and 1 9 asked for, quote, replacement insulation. 2 0 Q. Okay, then. Well, on a sort of a 2 1 day-to-day basis how are the material cards, 22 used by Westinghouse? Let's just do this, 23 let's just stay with insulation, if we can, to 24 the extent that you know. If you don't know (21S) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 75 1 -JOHN TABBUTT 2 about insulation, we'll talk about some other 3 things, about who looks at them, who refers to 4 them? 5 A. The only time that they are really 6 used is the installation of a new unit. 7 That's really the only time they are used. 8 They are used for when we go out -- if we have 9 the installation contract and if we are 1 0 responsible to install insulation, we would 1 1 use that information to get bids from 1 2 insulation contractors to do that part of the 1 3 work. 1 4 Q. And if a customer was going to be 1 5 doing the initial insulation, itself, or 1 6 arranging for a contract with someone other 1 7 than Mestinghouse, would the customer 1 8 understand what the specifications were for 1 9 the appropriate kind of insulation? 2 0 A. He would furnish them the drawings 2 1 that we would furnish an insulation 22 23 Q. Hell, then, if the customer is 24 going to be arranging for it, himself, and (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HU L (609) 392-3543 TRENTON 76 1 -JOHN J . TABBUTT2 he's got the drawing, as you say, to refer to, 3 is he going to know what that M number means 4 or is he going to have to talk to somebody at 5 Westinghouse to determine what is the 6 appropriate type of insulation to be used? 7 A. That information, again, on a 8 specific unit basis, they may already have 9 that because they may have specified it to us, 1 0 as far as what it should be and how thick it 1 1 should be and what have you. So, again, we 1 2 are back to the individual unit. 1 3 Q. And regardless of what -- 1 4 A. He would provide a drawing and we 1 5 would provide the information on the drawing 1 6 which would allow a contractor to do that. 1 7 Q. Regardless of what the M number 1 8 happened to be? He could do it without 1 9 referring to that, is that what you are 2 0 saying? 2 1 A. I'm saying that the drawing gave 22 them enough information so that they could do 2 3 the job. 24 Q. And then, in the same context. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 77 1 -JOHN J. TABBUTT- 2 they could make the determination as to what 3 should be used, in terms of insulating 4 materials? 5 A. It could be changed by them. It 6 could have been specified by them initially. 7 We could have put down the material on the 8 drawing that they requested initially. 9 Q. Okay. 1 0 A. But thedrawings are our permanent 1 1 record of that unit. 12 Q. DoesWestinghouse maintain 1 3 drawings for each and every unit that it has 1 4 sold in the last sixty years? 1 5 A. I have never been able -- I've 1 6 always been able to get drawings for all the 1 7 units -- 18 Q. That you've been involved with? 1 9 A. -- that I've been involved with. 2 0 Q. As far as the specifications 2 1 provided by the standards group are concerned, 22 are you aware that the standards group 23 specified use of asbestos or 2 4 asbestos-containing insulation for the (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 78 1 -JOHN J. TABBUTT2 insulation of turbines -- of any turbines? 3 A . Mas X aware? 4 Q. Do you have knowledge of that? 5 A. Me have material cards, old 6 material cards, that contained asbestos 7 insulation products that we purchased from 8 insulation suppliers, yes. 9 Q. Mas it, back when you started with 1 0 the company in '67, was it normal or routine 1 1 to utilize asbestos-containing insulation 1 2 materials for the insulation of turbines, as 1 3 far as Mestinghouse was concerned? 1 4 A. Again, it depended on a specific 1 5 unit as far as what insulation was put on that 1 6 unit. It would be really unfair to generalize 1 7 that all turbines contained asbestos 1 8 insulation. 1 9 Q . Okay. 20 A. Mestinghouse units generally had 2 1 asbestos blankets -- not asbestos blankets -- 22 insulation blankets that covered areas that 23 were normally disassembled. Removable 24 insulation blankets. (215) 564*0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 79 1 -JOHN J. TABBUTT2 Q. But, you are also aware, I'm sure, 3 and we'll go into the specifics later, that 4 some of the Westinghouse specifications for 5 insulation of turbines included the use of 6 asbestos comment or asbestos-containing block 7 or pipe -- asbestos-conta i n i ng pipe covering 8 and products of that nature? 9 A. Correct. 1 0 (Recess called at 12:02 p.m.) 1 1 AFTERNOON SESSION 1 2 (Resumed at 12:25 p.m.) 1 3 BY MR . HATERS : 1 4 Q. We've been talking about 1 5 specifications for insulation on turbines and 1 6 you've told us that you are familiar with, you 1 7 are aware of the fact that there are 1 8 specifications for asbestos-containing cement 1 9 and block and pipe covering that are part of 2 0 these material cards, is that correct? 21 22 Q. My understanding is that there are 23 no -- that there were no such material cards 24 that specified use of nonasbestos-containing (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HIL L (609) 392-3543 TRENTON 80 1 -JOHN J . TABBUTT2 block, cement, or pipe covering until sometime 3 in the 1970*3. Is that correct? 4 A. Early '70's, '73. 5 Q. If a turbine is insulated with 6 asbestos-containing block, cement, or pipe 7 covering, to some extent, I take i t , that it 8 will be necessary to remove some o f that 9 insulation to do work on the turbine, 1 0 understanding that it will vary depending on 1 1 what's being worked on and the nature of the 1 2 turbine and that sort of thing, is that 1 3 correct? 1 4 A. Most of our turbine generators 1 5 were -- the insulation system was -- on most 1 6 turbine generators were designed with 1 7 maintenance in mind. The majority of the 1 8 turbines, and again I want to caution you that 1 9 each unit is specific and you should really 20 get the engineering records for each unit to 2 1 come up with a conclusion, but the majority of 2 2 the units were insulated with block insulation 23 in areas that were never to be disturbed. The 24 areas that required access for maintenance and {215)564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 81 1 -JOHN J. TABBUTT- 2 disassembly had removable blankets over those 3 areas, so that every five or six years when 4 the unit was opened, to gain access to the 5 bolting to open it, one would merely have to 6 remove the blanket insulation for disassembly, 7 which is a few hours to remove. 8 Q. Let me object to the 9 non-responsive aspect -- portion of your 1 0 answer. Let me ask you the question this 1 1 way: Andunderstanding what you'vesaid about 1 2 blankets, you'll agree with me, I think, from 1 3 time to time it would be necessary to remove 1 4 block insulation or cement insulation or pipe 1 5 covering that contained asbestos in order to 1 6 do repair or replacement work on turbines? 17 MR. STOTTS: Let me object to the 1 8 fora, because I think youare asking about two 1 9 different procedures. You say repair or 2 0 replacement. 2 1 BY MR . WATERS : 22 Q. I'll be happy to segregate it into 23 two or just talk about repair for the moment. 24 Obviously the specifications call (21S) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 82 1 -JOHN J. TABBUTT- 2 for use of these items, and that's not really 3 in dispute, and I understand what you have to 4 say about blankets. but I just want to know i f 5 I'm correct, if you' 11 agree that from time t o 6 time it was necessar y, would have been 7 necessary to remove block or cement or pipe 8 covering containing asbestos to do repair 9 work? 1 0 A . All the units that I've seen and 1 1 I've worked o n , to d isassemble the unit for 1 2 r e p a i r work all that was necessary was to 1 3 remove the removable blankets. 1 4 Q. All right. So if there was 1 5 removal of asbestos-containing insulation, 1 6 block, cement, or pipe covering, it's your 17 testimony that it wouldn't be necessary? Is 1 8 that what I understand you to be saying? 1 9 A. The drawing for the specific unit 20 would indicate what areas of the turbine were 2 1 insulated with block. An example is the base 22 of the turbine would be insulated with block, 23 but there was never any reason to access that 2 4 area for a maintenance and/or repair. The (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 83 1 -JOHN J . TABBUTT- 2 areas on the t u r b ine that contain bolting for 3 d i s a s s e m b 1 y of t h e uni t were normally covered 4 with blanket s . 5 Q What about -- 6 A . Which were tied to rails on the 7 t u r b i n e via wire. they were wired to the 8 rails 9 Q What about the pipe cover ing? 1 0 Would it be n e c e s s a r y to remove pipe covering 1 1 from time to time to c omplete repairs -- 1 2 a s b e s t o s - c o n t a i n i ng pi pe covering? 1 3 A . Pipe cover ing to me means a 1 4 cover i n g on pipe , and there would not be any 1 5 reason to remove covering on pipe to do a 1 6 turbine inspection. 1 7 Q. Okay. What if work was -- it was 1 8 necessary to do some work on the pipes that 1 9 run to or from the turbine? 2 0 A. I have never known us to do repair 2 1 work to pipes. 22 Q. But if it was being done by 23 someone else, understanding that Westinghouse 2 4 doesn't normally do that sort of work? (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hit L (609) 392-3543 TRENTON 84 1 -JOHN J. TABBUTT2 A . Normally t h e r e is no repair work 3 done on p i pin g . It' s ins tailed. it's 4 i n s u 1 a t e d and it run s for X numb er of year s . 5 Q D o e s n ' t ever need to be replac ed? 6 A . At some point in t i m e everythi ng 7 has t o be r e p 1 a c e d , but - 8 Q And if p i p e i s to be replaced. 9 then primarily the p i p e c o v e r i n g will have t o 1 0 be re placed, as well , or at leas t removed s o 1 1 that the pipe can be r e p 1 a c e d ? 1 2 A. Correct. 1 3 Q. And you are aware that there are 1 4 Westinghouse specifications, material cards, 1 5 that specifically call for asbestos -- use of 1 6 asbestos-containing pipe covering? 1 7 A. Not for today. X 8 Q. I beg your pardon? Not for today, 1 9 no, absolutely not, but that there have been? 20 A. In the past were there cards 2 1 that -- yes. 22 Q. Let me ask you a few questions 23 about these blankets that we talked about. 2 4 A . Sure. (21S) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 85 1 -JOHN J. TABBUTT- 2 Q. How thick would they be? 3 A. The thickness varied depending 4 upon the temperature application. 5 G 6 can. And j ust give me a range, i f you 7 A Two, three, four i n c h . 8 Q Were the blankets - - t ell me. i f 9 you can d e s c r i b e them for me. in t e r m s o f 1 0 their c o n s i s t e n c y or their mak e u p . 1 1 A The b est way to de s c r i be it i s 1 2 like a c u s h ion on a chair. 1 3 Q Cloth or canvas on the outs i de ? 1 4 A Cloth , canvas and fill e d w i th 1 5 f i b e r g 1 ass. 1 6 Q Or as b e s t o s ? 1 7 A They stopped using a s b e s t o s 1 8 f o r t y - f i v e years ago in blankets. 1 9 Q When you say they. you mean 2 0 Westinghouse? 2 X A . The Westinghouse blankets did not 22 contain asbesto s fill after ' 4 6 . 2 3 Q . Now , make sure I understand th i s , 2 4 is it y our test i m o n y that you would expect the {215)564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY Hil L (609) 392-3543 TRENTON 86 1 -JOHN J. TABBUTT2 diagram or the drawings for a particular unit 3 to reference a material card indicating the 4 use of asbestos blankets for insulating -- 5 excuse me, start this one over. 6 Is it your testimony that you 7 would anticipate that a drawing for a 8 particular unit would reference a material 9 card that would tell you to use insulating 1 0 blankets as opposed to some type of 1 1 asbestos-containing insulation material on 1 2 areas where it would be -- where you would 1 3 need access for repairs? That was a very long 1 4 question. 1 5 MR. STUTTS : Let me just make one 1 6 comment. I don't want you to get the wrong 1 7 impression. I think John is being, as he 1 8 ought to be, very technical about his terms 1 9 and what's used in a blanket as fill and in 2 0 the outer covering of the blanket, and this 2 1 has come up before and I want to make sure you 22 understand that, while John is talking about 23 fill being fiberglass, there are two 24 components, one is the covering and one is the (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 87 1 -JOHN J . TABBUTT- 2 fill, so with that you may want to - 3 BY MR. WATERS: 4 Q. Okay, I appreciate that. Let me 5 go back to that. The external portion of the 6 blanket, the cloth, or what we've described as 7 canvas material, did that contain asbestos at 8 any time? 9 A. That contained asbestos cloth. 1 0 Asbestos cloth covering. 1 1 Q. Up until what time? 1 2 A . '73. 13 s Q . All right. Let me go back to my 1 4 other question, the long-winded one. Can you 1 5 read back that other question? 1 6 (Pertinent portion of the record 1 7 is read.) 1 8 THE WITNESS: If I understand your 1 9 question correctly, the drawing, itself, will 20 tell you where blankets are located and where 2 1 block is located. 22 BY MR . WATERS : 23 Q . What about other types of 24 insulating materials, cement, pipe covering? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (9) 392-3543 TRENTON 88 1 -JOHN J. TABBUTT2 A. It would give you all information 3 needed to insulate the turbine. 4 Q. In addition to the blankets and 5 the block. what else is u s e d on the t u r b i n e 6 for insula tion purposes? 7 A . Well, again. the blankets normal ly 8 cover any areas that you would require access 9 for disass embly. The rem a i n d e r of the turbine 1 0 would be a combination of block and -- well. 1 1 they call it plastic insu 1 a t i o n or mud , with a 1 2 cloth covering that would go over the block . 1 3 Q That may well be what I'm calling 1 4 cement . 1 5 A . Yes. X 6 Q Is it something that's mixed 1 7 with a water base? 1 8 A . Yes. 19 Q . All right. 20 A . But the cloth 2 1 plastic insu 1 a t i o n and t h 2 2 Q . Let me object 23 nonresponsiv e n e s s , as w e 1 2 4 The -- did He (21S) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 89 1 -JOHN J. TABBOTT2 specifications in certain circumstances call 3 for the use of what you've called mud or I've 4 called cement that contained asbestos? 5 A. The engineering records define the 6 drawings. The drawings really define two 7 things. They define the materials , which is 8 in the form of an M card. and they also define 9 the process in which the material i s to be 1 0 applied. Thos e are known as proces s 1 1 specifications. The process spec tells you 1 2 how to do it. In other words, how to insulate 1 3 the turbine, and the M cards tell you what 1 4 materials to use. So to insulate a turbine 1 5 you would need the drawings, the process specs 1 6 and the material cards. 1 7 Q. So, do the drawings then reference 1 8 both the process spec cards and the material 1 9 cards? 2 0 A. Correct. 2 1 Q. So if you look at your drawing and 22 it says, look at this process spec card, you 23 can go look at that and you can see how you 2 4 are supposed to insulate the thing? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 90 1 -JOHN J. TABBUTT2 A . Correct. 3 Q. And then you would look at the 4 material cards and you see with what you are 5 supposed to insulate it? 6 7 Q. The material cards, would they 8 ever be sent to customers? Copies of them be 9 sent to customers? 1 0 A. As a normal course of business, 1 1 they were not. 1 2 Q. If a customer askedyou for one 1 3 you wouldn't have any problem sending it to 1 4 him, presumably? 1 5 A. For insulation? 1 6 Q. Yes . 1 7 A. No. That should not be a problem. 1 8 Q. I mean, is there any kind of trade 1 9 secret or anything that needs to be protected? 2 0 A. On some cards, yes. That's why I 2 1 wanted a further definition from you, but that 2 2 applies to other things, such as bolting, 23 blades, mechanical devices. 24 Q. Do the materialcardsrepresent (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 91 1 -JOHN J. TABBUTT2 what Westinghouse presumes would be o r 3 believes to be the best insulating materials 4 or the most appropriate insulating materials 5 in a certai n situation? 6 A . I would say s o . 7 Q Now, from ti me to time would 8 customers send their equipment in to be 9 repaired at one of your facilities? 1 0 A. Some components of the turbine 1 1 were frequently sent into our factory for 1 2 repairs. 1 3 G . But not the turbines. themselves? 1 4 A . Not the cylinder that contained 1 5 the insulat ion. 1 6 Q Internal parts? 1 7 A . Internal parts, yes. 1 8 Q . So if t h e internal parts were 1 9 received at one of y our factories , presumably 2 0 there wouldn't be any external insulation on 2 1 it? 22 A. Correct. 23 Q. That would be back with the - 24 what did you call the outer part again? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 92 1 -JOHN J . TABBUTT2 A . Outer cylinder. 3 Q Outer cylinder, okay 4 Prior to the early 1 97 0 ' s were 5 there any specifications or material cards for 6 insulation on turbines that specified mud or 7 cement or block that did not contain asbestos? 8 A . The question, itself, is in a 9 general nature. A customer might have elected 1 0 an option of putting blankets on the entire 1 1 turbine and no block, as an example. 1 2 Q . I understand that, but my question 1 3 to you is, and maybe the better way to ask it 1 4 is this: If a customer relied solely on your 1 5 material cards to determine what type of mud 1 6 or cement or block or pipe covering to use in 1 7 insulating portions or all of his turbine or 1 8 turbines prior to the 1970's, would those 1 9 products have all contained asbestos? 2 0 A . Prior to 1970 2 1 Q You said early ' 7 0 ' s . 22 A He used mineral wool on some units 23 prior to 1970 24 Q Okay. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 93 1 -JOHN J. TABBUTT2 A. But again, I don't remember and 3 I'm n ot -- eachmaterial card had a number of 4 revis ions to it. If you were to give me a 5 s p e c i fic unit our records should be able to 6 indie ate what material was on that specific 7 unit, but to say that I knew every material 8 spec and process spec for every year from *73 9 back, I don't think I can answer that. 1 0 Q. You mentioned mineral wool. Is 1 1 that a material that can be used in place of 1 2 a s b e s tos for insulation products such as we've 1 3 been talking about? 1 4 A. Mineral wool wasused. 1 5 Q. And you've said it was used prior 1 6 to t h e * 7 0 ' s ? 1 7 A . Right. 1 8 Q . And has it been used since the 1 9 *70*3 -- I mean, since that time frame, as 2 0 well? 2 1 A. I don't believe so. 22 Q . What did -- 23 A. I don't believe so. 24 Q . Did there come a time at some time (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HIL L (609) 392-3543 TRENTON 94 1 -JOHN J. TABBUTT2 in the early '7 0 's that asbestos stopped being 3 used for insulating turbines and something in 4 its place began to be used? 5 A. Up until -- well, if you've had 6 access to our M cards you'll notice that on 7 all of those cards that you are referring to 8 for all of those products, that Westinghouse 9 purchased them through various suppliers, 1 0 Owens Corning, Keane and whatever the cards 1 1 show. If Westinghouse had a contract with a 1 2 utility to supply a turbine, if part of the 1 3 that contract was for us to supply insulation, 1 4 we would purchase the insulation from one of 1 5 those suppliers on one of those cards and that 1 6 supplier would send it to Houston Light and 1 7 Power, and then it would be the responsibility 1 8 of the installation contractor to install 1 9 that. That was how the process went. 2 0 In the early 'TO's, '72 -- '73, I 2 1 believe it was, there was a massive program to 22 go to nonasbestos insulation and, as that 23 became available, Westinghouse put that type 24 of insulation on the material cards. Now, I (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 95 1 -JOHN J. TABBUTT2 don't know if that answers your question. 3 Q. It does, in part, I think. What 4 material or materials were used to -- in the 5 place of asbestos as part of that changeover? 6 A. Example would be the blankets. 7 Again, we've been using the fiberglass fill 8 for forty-five years, but they were covered 9 with an asbestos-containing cloth material. 1 0 That was changed to a fiberglass cloth. 1 1 That's one example. But, the insulation today 1 2 is all totally nonasbestos material, for 1 3 federal installations. Again, the latest M 1 4 card would reflect who we would purchase it 1 5 from and also what their brand names would be. 1 6 Q. Was the changeover fairly quick? 1 7 I mean, did sort of the word come down from on 1 8 high and you stopped using asbestos in your 1 9 insulation of these turbines? The 20 specifications changed fairly quickly, is that 2 1 what happened? 22 A. What do you call fairly quickly? 23 Q. Well, I mean, did it take a year 24 to get it implemented? Did it take a month? (215) 564-067S PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll l (609) 392-3543 TRENTON 96 1 -JOHN J. TABBUTT2 What's your recollection of that? 3 A . I think it became effective 4 immediately upon notification. 5 Q. What is your recollection ab out 6 the notification? I mean, when did you first 7 become aware personally that asbestos wa s a 8 health hazard and that something was bei ng 9 done about it? 1 0 MR. STUTTS: Object to the f o r m . 1 1 BY MR . WATERS : 1 2 Q. Let me rephrase it. When di d you 1 3 first became aware that asbestos was a h e a 1 t h 1 4 hazard? 1 5 MR. STUTTS: Are you asking him 1 6 personally? 1 7 MR. WATERS: Personally. 1 8 MR. STUTTS: Not as a witnes s 1 9 designated to testify to that? 2 0 MR. WATERS: I'm only asking about 2 1 his personal knowledge, anyway. 22 MR. STUTTS: But if the ques t i o n 23 is not to be included within the scope o f his 2 4 designation, then I will object to it. He can (215)564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 97 1 -JOHN J. TABBUTT2 ansuer the question, but I think it's outside 3 the scope of what he's here to testify about. 4 BY MR . WATERS : 5 Q. So when didyou personally become 6 aware of the hazards of asbestos, regardless 7 of whether you learned about it at work or 8 wherever else? 9 A. In the early '70's. 1 0 Q. And did you learn about it at 1 1 work? 1 2 A . Yes . 1 3 Q. And how did you learn about it at 1 4 work? 1 5 A . Through an insulation contractor 1 6 Q And do you recall his name? 17 A . No . 18 G . Do you recall the name of the 1 9 company? 2 0 A . I think it was Keane Insulation. 2 1 Q Keane Insulation? 22 A . No, was it Keane? Philadelphia 23 Asbestos, I think. 2 4 Q. Philadelphia Asbestos? (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hill (609) 392-3543 TRENTON 98 1 -JOHN J. TABBUTT2 A . Yes . 3 Q. And what was the nature of the 4 communication that you received that gave you 5 this understanding? 6 A. I think the conversation was 7 something to the effect that they are changing 8 all the materials. Going tononasbestos 9 material because of medical problems 1 0 associated with the asbestos workers. 1 1 Q . Okay. 1 2 A. That the major companies were all 1 3 going that way. 1 4 Q. When you say themajor companies, 1 5 does that mean the manufactures of insulation? 1 6 A. Correct, yes. 1 7 Q. So the first you heard of the 1 8 hazards of asbestos didn't come from someone 1 9 within Westinghouse, it came from someone 20 outside of Westinghouse that you were dealing 2 1 with on a business basis? 22 A. Correct. 23 Q. Did you report that back to 24 someone at Westinghouse? (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 99 1 -JOHN J. TABBUTT- 2 A. At the same time that this was 3 going on Westinghouse came out and notified 4 everyone that there was changes in turbine 5 insulation, the requirements. 6 Q. So that -- 7 A. It's difficult for me to home in 8 as far as exact time frames twenty years ago. 9 Q . I understand. 1 0 A. Conversations. 1 1 Q. All right. Is it fair to say, 1 2 then, that you heard about it froman external 1 3 source sometime in the relatively near future 1 4 after it became an issuewithin Westinghouse? 1 5 MR. STUTTSs I'm going to object 1 6 to the form. When you say, it became an issue 1 7 withinWestinghouse, I think that's not what 1 8 he's testified to. 1 9 BY MR . WATERS : 2 0 Q. Let me rephrase that. Became a 2 1 matter of concern for Westinghouse. . 2 2 MR. STOTTS: Same objection. My 23 objection is what became a concern to 24 Westinghouse and the time it became a (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll l (609) 392-3543 TRENTON 100 1 -JOHN J . TABBUTT- 2 particular concernis different from the time 3 when Mr. Tabbutt was informed about any formal 4 program to switch over to a different kind of 5 product. 6 BY MR . HATERS : 7 Q. Hould it be fair to say that you 8 heard about it from an external source and 9 sometime in -- relatively soon after that you 1 0 heard it from within Westinghouse that they 1 1 were going to be changing to using a different 1 2 type of insulation that did not contain 1 3 asbestos? 1 4 A. That's correct. 1 5 q. And was there a memorandum or some 1 6 sort of written communication that you 1 7 received at Hestinghouse in that regard? 18 A. Yes . 1 9 Q. And do you recall approximately 2 0 when you received it? 2 1 A. ' 73 . 22 Q. Have you -- 23 A. March, '73. 2 4 Q. Do you recall from who or which (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 10 1 1 -JOHN J. TABBUTT2 department it came? 3 A. Came from the technical support 4 group 5 Q * Where were they located? 6 A . Lester. Lester, Pennsylvania. 7 Q Do you remember who was in charge 8 of that group? 9 A . Came from technical development. 1 0 I'm sorry. 1 1 Q Technical development? 1 2 A . Technical development. The 1 3 manager in charge at that time was John 1 4 Ristuccia, R-i-s-t-u- c - c - i - a . 1 5 Q A n d to t h e extent you can recall 1 6 the substance of that memo -- was it a short 1 7 memo? 1 8 A . Two page. 1 9 Q Have you seen it since 1973? 2 0 A . Yes. 2 1 Q . Have you seen it recently? 2 2 A . Recently meaning? 2 3 Q. Well, when was the most recent 24 time you saw it? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (60S) 795-2323 CHERRY HIU (609) 392-3543 TRENTON 102 1 -JOHN J. TABBUTT2 A . When was the last time I saw it? 3 Probably a year ago. 4 Q. Did you see it in the context of 5 one of your other depositions? 6 A. I don't believe so. 7 Q. Tell me in what context you 8 reviewed that memo? 9 A. I was using it for another case. 1 0 Q . Another asbestos case? 1 1 A . Correct . 1 2 Q . And how were you using it? 1 3 A . Information only. 1 4 Q . To refresh your memory or 1 5 something? 1 6 A . Yes. 1 7 MR. HATERS: Is that a document 1 8 you all have? 1 9 MR. STUTTS: I don't know. 2 0 MR. HATERS: I presume it is, but 2 1 we haven't been provided it. 22 MR. STUTTS: It came up in which 2 3 other -- Morykon's deposition? 24 MR. HATERS: Yes. I'massuming (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 10 3 1 -JOHN J. TABBUTT2 it's the same memo. It may not b e . 3 MR . S TUTTS : I don' t know. I'll 4 check . 5 BY MR. MATERS: 6 Q . Tell me w hat you can a b out what it 7 said. the two-page me m o . 8 A . Bas ically w h a t it s a i d i s , 9 e f f e c t i v e as of this date the ins ul a t i on has 1 0 been changed to a nonasbestos type insulation, 1 1 and listed a number of companies and 1 2 replacements. Mho to buy the insulation from. 1 3 in the event that w e had to supply it. who the 1 4 approved vendors were o f nonasbestos 1 5 insulation. List o f various types, bl 1 6 blanket, cloth. 1 7 Q. Mud? 1 8 A. Yes, plastic cement. 1 9 G . Other than telling you we are not 20 going to use a s b e stos-containing insul a t i o n 2 1 anymore and these are the replacements , did it 2 2 say anything else about anything that should 2 3 be done about asbestos that might already be 24 in place? o o X (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hit L (609) 392-3543 TRENTON 10 4 1 -JOHN J. TABBUTT- 2 A. I believe that this was based 3 purely on new work. 4 Q. Was it followed by any other 5 memorandum on the same topic o r o n th e general 6 topic of asbestos that came t o you? 7 A . I don ' t recall. X don' t remember 8 any. Again, you know, the documents that get 9 changed are the drawings, the process specs 1 0 and the M cards. That's what we normally use 1 1 in the field. 1 2 Q. Tell me what you were doing a year 1 3 or so ago that required you to look at this 1 4 memo. 1 5 A . Again , it was doing som e 1 6 investigative work for an other case 1 7 Q Where did you find the memo? 1 8 A . I beg your pa r d o n ? 19 Q . Where did you find it? Did 2 0 somebody give it to you t o look at? 2 1 A . No, I have it in my off ice. . 2 2 Q You have it i n your off ice now? 23 A . Yes . 24 Q . Well, at leas t we know where it (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 05 1 -JOHN J. TABBUTT2 is. Nou Id you be able to se n d a copy of that 3 to your attorney? 4 A . Certainly. 5 Q Or to Westinghou se's attorney? 6 A . Certainly. 7 Q Mould you be abl e to do that 8 tomorrow 7 Are you going to be in the office 9 tomorrow o r are you going to b e playi n g golf? 1 0 A . I will not be in the o f f i c e 1 1 tomorrow 1 2 Q . When will you ne xt be in the 1 3 office? 1 4 A . Next Monday. 1 5 Q . Mhen you are in the o f f i c e next 1 6 Monday w ill you be able to s end that to your 1 7 attorney s down in Richmond? 1 8 A . Yes . 1 9 MR . MATERS : Do you have any 2 0 problem with getting that and sending it on to 2 1 us? 22 MR. STUTTS: I don't think so, but 2 3 until I look at it and know what really I'm 2 4 dealing with -- (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hill (609) 392-3543 TRENTON 1 06 1 -JOHN J. TABBUTT2 MR. WATERS: Okay. Just for the 3 record, I would state that I think that 4 particular document would fall within the 5 scope of the documents requested under the 6 depo notice and, as I stated earlier, we 7 reserve our right to continue the deposition 8 to ask questions about that document and some 9 other things. 1 0 BY MR. WATERS: 1 1 Q. The substitute materials, and if 1 2 you are not comfortable with that term I'll 1 3 try to define it in a different way, but the 1 4 materials that have been used in lieu of 1 5 asbestos-containing insulation since '73, do 1 6 they do the job, as far as you know? 1 7 A. As far as I know, the thermal 1 8 insulation materials that have been supplied 1 9 recently have been adequate to perform their 2 0 functions. 2 1 Q. You haven't had any complaints 22 from customers that there is a problem with 23 the insulation materials that Westinghouse now 24 specifies? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 107 1 -JOHN J. TABBUTT2 A. Not that I'm aware of. 3 Q. When you saw the memo in 1973, 4 presumably the materials that were to be 5 substituted were a v a i 1 a b 1 e s o m e t i m e before 6 1973, is that c o r r e c t ? 7 A . I can't answer that q u e s t i o n . 8 Q You just don't know? 9 A . I don't know. 1 0 Q Did you ever receive any 1 1 instructions o r did you ever see any written 1 2 instructions a s to h o w to deal w i t h or what to 1 3 do with asbestos insulation that was already X 4 in place with respect to this 1973 memorandum 1 5 and what may have occurred after that? 1 6 A. I don't really understand your 1 7 question. 1 8 Q. I'll be happy to rephrase it. Did 1 9 you ever receive any instructions or did you 2 0 ever see any instructions or are you aware of 2 1 any instructions from anyone in Westinghouse 22 with regard to asbestos insulation that was 23 already in place in 1973? Understanding that 24 they are not going to use it anymore for new (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 1 08 1 -JOHN J. TABBUTT- 2 work, but there may have been some already in 3 place as a result of prior work. 4 A. I don't recall -- I don't recall 5 anything coming down about that during that 6 time frame. Again, at that particular time 7 frame I was a field service engineer going 8 from site to site. Generally, when we arrived 9 at a customers' location for a maintenance 1 0 outage, the insulation had already been 1 1 removed, the blankets had already been removed 1 2 before they started disassembly, so even when 1 3 we were requested to be there to provide 1 4 technical field assistance during repairs 1 5 and/or maintenance, normally the insulation 16 was off and normally we left before it got put 1 7 back on. Again, it depends on location by 1 8 location, customer by customer. 1 9 Q. During that time frame -- 2 0 A. We were not looked at as the 21 technical experts of insulation. That was not 2 2 really our forte. Customer always relied on 23 whoever his insulation contractor was or his 24 insulation people at the site. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 09 1 -JOHN J. TABBUTT2 Q. Did Westinghouse ever advise any 3 of its customers -- by any of those bulletins 4 or other circulars, things that we discussed 5 earlier, did Westinghouse ever advise any of 6 its customers that it was no longer specifying 7 use of asbestos or asbestos-containing 8 insulation because that was considered to be a 9 health hazard? 1 0 A In the sens e w e n o t i fied them. 1 1 from a t e c h n i c a 1 n a t u r e r o n the drawings and 1 2 the pro cess specs that w e w ere u sing 1 3 nonas be s tos mater i a 1 s . 1 4 Q. With the exception of the actual 1 5 material cards and the drawings, are you aware 1 6 if Westinghouse sent anything to any of its 1 7 customers to advise of the possible hazards of 1 8 asbestos? 1 9 A. I really don't know the answer to 2 0 that question. 2 1 Q. Who would know the answer to that 22 question? 23 A. We have a safety and hygiene 2 4 department. That would probably fall under {215)564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HIL L (609) 392-3543 TRENTON 1 10 1 -JOHN J. TABBUTT2 that department. If there was any warnings or 3 cautions sent directly to customers, other 4 than via drawings, process specs and material 5 cards . 6 Q. Safety and health department, 7 okay. Where are they located? 8 A. Orlando. 9 G . But, as far as you know. the P ower 1 0 Generation Service D ivision and the Power 1 1 Generation Business Unit did not sen d any such 1 2 written warnings to any of their cus toiers 7 1 3 A . I don't know. 1 4 Q You are not aware of any such 1 5 warnings being sent? 1 6 A. I do not know that they were or 1 7 were not sent out. I would have to look into 1 8 that further . 19 Q. And who, understanding what you've 2 0 said about the safety and health department, 2 1 but who at the Power Generation Service 2 2 Division and the Power Generation Business 23 Unit would know what warnings were sent by 2 4 either of those two entities? (215)564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 111 1 -JOHN J. TABBUTT- 2 A. I could answer thatquestion by 3 contacting other people. 4 Q . Who would you contact? 5 A. I don't know yet. 6 Q. Pardon? 7 A. I don't know yet. 8 Q. During that time frame, '67 to 9 '75, when you were a field serviceengineer, 1 0 did you basically have a series of 1 1 a p p o i n t m e n t s ? I mean , did you have a schedule 1 2 where you knew you were going to be going t o 1 3 this plant for three or four days and then t 0 1 4 that plant for a few days and on and on? I 1 5 mean. did you have a schedule in advance? 1 6 A . There was never any schedule. 1 7 Q . Just sort of happened when it 1 8 happened? 1 9 A . Yes. 2 0 Q. Did the customers advise 2 1 Westinghouse that they were going to be making 2 2 repairs ? 23 A. Each customer is different. There 24 were some customers that may not advise (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795*2323 CHERRY HliL (609) 392-3543 TRENTON 1 12 1 -JOHN J. TABBUTT2 Westinghouse, that may do an inspection 3 without Westinghouse and re-assemble the unit 4 without Westinghouse. There are other 5 customers who Westinghouse becomes an integral 6 part of planning for the outage. It varies 7 and it varies within individual power plants 8 within an individual utility's system. 9 Q. If a customer wanted a 1 0 Westinghouse representative to be on site for 1 1 the duration of repair work, presumably they 1 2 would advise Westinghouse before the repair 1 3 work began? 1 4 A. If it's planned repairs, 1 5 hopefully, yes. 1 6 Q. Do you recall any instance where 1 7 Westinghouse was aware that repairs were going 1 8 to take place and advised the customers to 1 9 take special precautions when removing the 2 0 asbestos insulation around the turbine in 2 1 question? 2 2 A. Normally the utility, again, does 23 not discuss that with Westinghouse, because we 2 4 are not the technical expertise of (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 13 1 -JOHN J. TABBUTT2 insulation. I mean, the insulation was 3 provided by Westinghouse under contract 4 initially only as part of a bid spec and it's 5 provided by an insulation contractor and 6 installed by an insulation contractor. We 7 were rarely involved in that process of 8 replacement. Again, I say rarely involved. 9 Q. I understand that they may not 1 0 have asked you or solicited your advice about 1 1 how they should remove the insulation or in 1 2 what fashion they should doit or what 1 3 precautions they should take, but my question 1 4 to you is, are you aware of any instance where 1 5 Westinghouse provided that information, 16 whether or not it was requested? 1 7 A. The question -- during a 1 8 pre-outage meeting with a customer you 1 9 normally go into recommendations, Westinghouse 2 0 recommendations, and what they were going to 2 1 do during the inspection, what repairs are 22 going to be made and what parts are going to 23 be replaced. Normally, again, the insulation 24 is not an issue. (21S) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HU L (609) 392-3543 TRENTON 1 14 1 -JOHN J. TABBUTT- 2 Q. Well, let me get back to my 3 original question, because I think you are 4 saying no, but I want to make sure. I can 5 take it, then, that you are not aware of any 6 instance where Westinghouse provided 7 information to a customer about how to remove 8 asbestos or how to deal with asbestos 9 insulation, regardless of whether that 1 0 information was solicited by the customer? 1 1 A. I'm not aware of it. 1 2 Q. You do not personally recall, 1 3 yourself, ever giving that information to the 1 4 customer, correct? 1 5 A. Giving what information? 1 6 Q. About the dangers of asbestos or 1 7 care should be taken when removing asbestos 1 8 insulation? 1 9 A. Again, I'm normally not involved 2 0 in that process. It's normally the customer 2 1 telling me that he's going to strip his . 2 2 turbine and re-insulate it. I sit and listen. 23 Q. Okay. 24 A. Again, that's a process that has (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 15 1 -JOHN J. TABBUTT2 been going on at power plants across the 3 country for years and years as part of their 4 asbestos abatement programs at the plant 5 sites . 6 Q Okay. 7 A . We are not, again, the leader of 8 the i n s u 1 a tion replacement. 9 Q So the short answe r is, no, you 1 0 don't have any recollection of giving anyone 1 1 a d v i c e a b o ut how they should r emove asbestos 1 2 insu1 ation7 1 3 A. I don't recall. 1 4 Q. Are you saying you don't recall if 1 5 you've done so or you don't recall whether or 1 6 not you may have done so? 1 7 A. I don't recall seeing anything 1 8 going to our customers telling them about the 19 dangers of asbestos. I don't remember that, 2 0 but that does not necessarily mean that that 2 1 wasn't transmitted by another group. 22 Q. After this, what you've described 23 as the initial memo, I think, in 1973, were 24 there any subsequent memos dealing with the (215)564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hill (609) 392-3543 TRENTON 1 16 1 -JOHN J. TABBUTT2 hazards of asbestos or how to deal with 3 asbestos in Westinghouse plants or in any 4 other context? 5 A. The individual process specs and 6 the material cards, you will find that they 7 have caution notes on them, ala, do not 8 breathe, that kind of thing, so notes of 9 warning and caution were placed on even the 1 0 older cards, if I recall. 1 1 Q . I'm not understanding you. When 1 2 you say "on the older cards" you mean prior to 1 3 the ' 70 ' s? 1 4 A. Exactly. I believe that you have 1 5 some material cards in the documents that were 1 6 given to you that have caution statements on 1 7 them for anybody using that particular 1 8 material. , 1 9 Q Because of asbestos dust or 2 0 whatever? 2 1 A. The reason for the caution note I 22 can't comment on, other than there were 23 caution notes that were placed on material 24 cards and process specifications. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 17 1 -JOHN J. TABBUTT2 Q. And that goes back as far as the 3 '40's? 4 A . The earlier cards had it. I don't 5 know i f it went back to the ' 4 0 ' s. I would 6 have t o look to refresh my memory. 7 ft . P r i or to that 1973 memo that we've 8 talked about a little bit did you have any 9 idea whatsoever, you personally, that asbestos 1 0 might be a health hazard? 1 1 MR. STUTTS: Same objection. If 1 2 this is meant to be within the scope of his 1 3 designated testimony, you can answer it. The 1 4 objection is that you are not speaking for 1 5 Mestinghouse, you are speaking for yourself, 1 6 apparently. 1 7 THE WITNESS: It was my 1 8 understanding that asbestos was nonhazardous 19 to your health. That if it was encased you 20 could look at it. you could put i t in your 2 1 pants, you could jump -- you know. put it on 22 your dresser drawer. What I was advised on 23 was that if it was airborne and you breathed 24 it every day and you ate it every day that it (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HIL L (609) 392-3543 TRENTON 118 1 -JOHN J. TABBUTT2 could be hazardous to your health. 3 BY MR. WATERS: 4 Q. How did you know that? 5 A. Again, this was from the 6 insulation contractor that I dealt with. We 7 relied on them. Again, they provided all 8 materials and they installed it. It was not a 9 business that the Westinghouse Power 1 0 Generation Business Unit was heavily involved 1 1 with. 1 2 Q. They provided the materials in 1 3 response or in accordance with your 1 4 specifications, correct? 1 5 A. In accordance with the customers' 1 6 specifications . 1 7 Q . And in accordance with -- 1 8 A. If the customer and his architect 1 9 engineer or his constructors request a quote 2 0 and said the turbine shall be insulated and 2 1 specified in some cases what insulation was 22 defined as, we responded to that 23 specification. 24 Q. But there were occasions, were (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 19 1 -JOHN J. TABBUTT- 2 there not, where the specification was 3 provided by Westinghouse in the form of what's 4 stated on the material cards? 5 A. Again, it was on a unit-by-unit 6 basis . 7 Q. But that was the case from time to 8 time? 9 A Occasionally that could happen. 1 0 sure. 1 1 q. Would you agree, Mr. Tabbutt, that 1 2 if Westinghouse had known earlier than 1973 of 13 the dangers and hazards ofasbestos, that it 1 4 should have warned its customers or switched 1 5 to different types of insulating products? 1 6 MR. STUTTS: Object to the form of 1 7 the question and the substance of the 1 8 question. It's beyond this witness' 1 9 designation and the designation for Mr. 2 0 Tabbutt, as stated in the notice, and you will 2 1 be provided with some other witnesses, I 22 believeit's been agreed, in the area of 23 industrial hygiene, and whether or not 24 Westinghouse should or should not have warned (215)564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hill (609) 392-3543 TRENTON 1 20 1 -JOHN J. TABBUTT- 2 is beyond the scope of his designation. 3 BY MR. WATERS: 4 Q. You can answer the question. 5 MR. STUTTS: Could we have the 6 question repeated? 7 (Pertinent portion of the record 8 is read.) 9 MR. STUTTS: The question is also 1 0 vague when referring to the dangers of 1 1 asbestos. It's a generic general question and 1 2 really has no specific meaning. 1 3 THE WITNESS: I don't feel I'm 1 4 qualified to answer that question. 1 5 BY MR . WATERS : 1 6 Q . Okay. 1 7 Who would be qualified to answer 1 8 that question? 19 MR. STUTTS: I'm going to object 2 0 to the question. If you have an area of 2 1 testimony that you want designated, then the 22 appropriate wayto do that is to send that 23 notice tous and we then have a right to 24 designate a witness to testify in that area. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 121 1 -JOHN J. TABBUTT2 I don't think it's up to this witness to be 3 questioned about who the appropriate designee 4 should be for areas outside of his 5 designation. 6 MR. WATERS: Well, he's been 7 designated to testify about the use of 8 asbestos insulation on turbines. 9 MR. STUTTS: Right. 1 0 MR . WATERS : A n d i f that' s u n s a f e 1 1 in any respect I think that ' s somethi ng h e can 1 2 testify about , and if he feels it's n o t u n s a f e 1 3 he can say that . If h e feels it should o r 1 4 s h o u 1 d n ' t have you bee n used. he can s a Y 1 5 that. I don't think i t ' s outs i d e the s cope a t X 6 all. 1 7 MR . STUTTS : I th i n k it i s outs i d e 1 8 the scope and I think you know that what we've 1 9 got here is an engineer and you know that you 2 0 have asked for and we are going to give you 2 1 somebody from industrial hygiene . At some 22 point it's clear to you and to m e when you are 23 going outs i d e o f the expertise o f a w i t n e s s 24 like an engineer and you know i t gets to be (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY Hit L (609) 392-3543 TRENTON 1 22 1 -JOHN J. TABBUTT2 unfair. To ask him questions of a medical 3 nature when, in fact, he's here to testify 4 about engineering issues on the turbine. 5 MR. WATERS: Well, if he doesn't 6 have an opinion, he can tell me that. 7 MR. STUTTS : I don't want the 8 witness testifying -- I'm going to let him 9 give his answer, but I want to make sure I 1 0 have an objection here, because I don't want 1 1 the witness testifying on behalf of 1 2 Westinghouse on an issue that I think is 1 3 outside the designation. Whether or not his 1 4 answer is, I can't answer, or whether or not 1 5 he gives you an answer beyond that. 1 6 MR. WATERS: I understand. I 1 7 think you've adequately registered your 1 8 objection. 1 9 MR . STUTTS : A1 1 right. 2 0 BY MR . WATERS : 2 1 Q. Can you answer the question? 2 2 A. Could you repeat the question? 23 MR. WATERS: Could you read back 24 the question? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 23 1 -JOHN J. TABBUTT- 2 (Pertinent portion of the record 3 is read.) 4 THE WITNESS: The answer to that 5 is, I cannot answer that question. 6 BY MR. WATERS: 7 Q. How can we determine the location 8 of Westinghouse units in the State of Alabama? 9 A. We maintain an engineering record 1 0 for every unit we sold, turbine generator 1 1 record. . 1 2 Q. So, if we have the name of the 1 3 plant will Westinghouse be able to provide 1 4 some of the documents we have talked about 1 5 today, such as the drawings and other 1 6 documents related to the units that would have 1 7 been at those plants? 1 8 A. If you could provide me with the 1 9 customer and the plant location I can tell 20 you, number one, if Westinghouse had equipment 2 1 there and, two, if the equipment is still 22 there we should be able to provide the 23 engineering record which would give the 24 drawings . (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hit L (609) 392-3543 TRENTON 1 24 1 -JOHN J. TABBUTT- 2 Q. Do you have any knowledge about 3 asbestos-containing gaskets being used on any 4 of these units we've been talking about, the 5 turbines and generators? 6 A. Various types of gaskets are used 7 on various types of turbines. Again, if you 8 could give me a serial number or a customers' 9 name, location, plant, we should be able to 1 0 tell you what gaskets were originally 1 1 supplied. 1 2 Q. Did Westinghouse -- 1 3 A. Keep in mind that gaskets are 1 4 replaced on a fairly routine maintenance basis 1 5 by the customer. They are not a Westinghouse 1 6 replacement part. So after the original part 1 7 went in in, say, 1950, in all probability 1 8 what's in there now is not what we supplied. X 9 So all I can tell you is what was originally 2 0 installed and that is not indicative of what's 21 in there now. Gaskets are replaced at every 22 overhaul . 23 Q. Did Westinghouse manufacture 2 4 gaskets for use in its turbine? (215) 564*0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 25 1 -JOHN J. TABBUTT2 A. No, not that I'm aware of, 3 Q. Where did the gaskets that 4 Westinghouse used in its turbines, where did 5 they come from, d o you have any idea? 6 A . They are purchased f r o m outside 7 supp1 iers . 8 Q Would that be a part o f the 9 s p e c i f i c a t ion she ets or the mate rial cards? 1 0 A . Drawi ngs . 1 1 Q Drawi ngs . 1 2 A . But a gain I want to c a u t ion you 1 3 that this gasket was installed in 1950 and 1 4 there was an inspection in *51, every gasket 1 5 from '51 on was probably somebody else's. 1 6 Q. Are you saying that you are 1 7 certain that Westinghouse did not make gaskets 1 8 or that you do not know whether Westinghouse 1 9 made gaskets? 2 0 A, Most of the gaskets that were made 2 1 were made on site out of sheet material. 2 2 Gasket sheet material. There were specialty 2 3 gaskets made by Flexitalic Corporation and 2 4 there were -- the gasket depended upon the (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 126 1 -JOHN J. TABBUTT2 application, the temperature, there were a 3 number of factors, so there were a number of 4 gaskets involved and , again, if you could tell 5 me a specific unit, we can look into that. 6 Q. Let me go back to my question. My 7 question was, are you saying you don't know 8 whether Westinghouse made any gaskets? Is 9 that the case? Or are you saying that they 1 0 did not? 1 1 A. I'm not aware that Westinghouse 1 2 made gaskets. To my knowledge, they were 1 3 supplied by outside vendors. 1 4 Q . What about packing material? Do 1 5 you know w h e ther Westinghouse provided packing 1 6 material t 0 its customers? 1 7 A . What we call packi ng material is 1 8 made of steel. 1 9 Q . Do you know if Westinghouse ever 2 0 provided sheet material to its customers from 2 1 which gaskets could be made? 22 A. That's what I was just telling you 23 about. You would get a sheet of material, cut 24 it to fit a certain bolt circle, but that was. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 127 1 -JOHN J . TABBUTT2 I ' m going to use the term, gasket material. 3 Q. As opposed to gaskets? 4 A. No. As opposed to asbestos 5 gaskets . 6 Q. Okay. Let me backtrack a second. 7 A. All I'm saying is there is a 8 multitude of gaskets and there is a multitude 9 of applications and if you were to give me a 1 0 specific unit, then we can look up in our 1 1 files and tell you what we think was 1 2 o r i g i n a 1 1 y there . Again, in all pro bability, 1 3 that was replaced by a customer many times 1 4 since the unit was installed. 1 5 Q Did Westinghouse -- 1 6 A . So we. Westinghouse, d o not 1 7 necessarily know what's in there now. 1 8 Q. I understand. Hell, did 1 9 Westinghouse ever sell or provide gasket 2 0 material or sheets from which gaskets could be 2 1 made to any of its customers? 22 A. The turbine generator, when it was 23 sold, came with gaskets, came as a complete 2 4 unit, we supplied everything. Therefore, if (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HU L (609) 392-3543 TRENTON 1 28 1 -JOHN J. TABBUTT2 you are saying that a gasket was part of the 3 turbine generator contract, yes, we sold the 4 gaskets, if itwas part of that contract. 5 Q. I asked about gasket material or 6 sheets from which gaskets could be made, if 7 Westinghouse ever sold or provided any of 8 those to its customers. Not talking about 9 gaskets that may have come with the finished 1 0 product already in place. 1 1 A. I really-- whether any of our 1 2 customers, there is thousands of them, ever 1 3 placed an order with us for gasket material? 1 4 I can't answer that question. 1 5 Q. That wasn't my question. ' 1 6 My question was, did Westinghouse 1 7 ever sell it? And if you don't know, that's 1 8 fine. 1 9 A. Did we ever sell it? We have sold 2 0 replacement gaskets. I'm sure of it. 2 1 Q. Have you ever sold replacement 22 gaskets that contained asbestos? 23 A. I don't know. 2 4 Q. Who would know that? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 29 1 -JOHN J. TABBUTT- 2 A . A g a in, a 11 o f our files are by 3 unit numbers. We do m a i n t ain records of 4 renewal parts o r d e r s for a period o f time. So 5 whether or not that part i c ular cust o m e r on 6 that parti c u 1 a r unit w e pr ovided ga skets , 7 that's the only way I c a n answer th e question. 8 Q Did West i n g h o u s e ever s ell or 9 di stribute Mica r t a s h e e t s , that you are aware 1 0 of ? 1 1 M R . STUTTS: I ' m sorry. I started 1 2 reading that. 1 3 BY MR . HATERS : 1 4 Q. Did Westinghouse ever sell or 1 5 distribute Micarta sheets. 1 6 MR. STUTTS s You mean in 1 7 connection with turbines? 1 8 MR. WATERS: Yes. 1 9 THE WITNESS: I'm not aware of 20 it. Not for steam turbine generators. 2 1 BY MR . WATERS : . 22 Q. Did you ever see any documents 23 from -- any Westinghouse documents, I guess, 24 after 1973 that identified asbestos as a (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 130 1 -JOHN J. TABBUTT2 health hazard and then set forth some sort of 3 precautions to be taken when having to deal 4 with it? 5 A . I don't recall any. 6 Q . Okay. 7 A. Again, that does not necessarily 8 mean that there was never any generated. 9 Q. Is it your understanding that, 1 0 after that memo of 1973,that Westinghouse, 1 1 subsequent to that time, did not -- no longer 1 2 specified use of asbestos-containing products 1 3 with regard to its turbines? X 4 A. It's my understanding that all of 1 5 the thermal insulation specifications were 1 6 changed after that date. 1 7 Q. Do you have any personal knowledge 1 8 as to whether or not asbestos-contain i ng 1 9 products were or were not used after that date 2 0 w e s tinghouse turbines? 2 1 MR . STUTTS: By anyone? 22 MR . HATERS: Pardon? 23 MR . STUTTS : By anyone? 24 MR . WATERS : By anyone. (215)564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 13 1 1 -JOHN J. TABBUTT2 BY MR . WATERS : 3 Q . I'm understanding that th e 4 s p e c i f i c a t ions were changed. My ques tio n to 5 you i s , do you have any knowledge one way or 6 the o t h e r about whether the specifi c a t i o n s 7 were folio wed in eve ry instance, or d o you 8 know of an y occasion where they may n o t have 9 been? 1 0 A . I'm not aware of any oc c a s i o n s 1 1 where they weren't f o 1 1 o w e d . 1 2 Q . Were you told by anyone t o get rid 1 3 of as b e s t o s that was -- asbestos in s u 1 a t i o n 1 4 mater i a 1 s that were in stock? 1 5 A . We did n ot stock therma 1 -- 1 6 a s b e s tos thermal ins ulating materia 1 . They 1 7 were purchased from insulators and s h ip p e d to 1 8 various site locations. 1 9 Q . A s need be? 2 0 A . 0 n a con tract-by-contract basis. 2 1 Q . Are you aware that anywhere within 2 2 Westinghouse there was a move to get rid of 23 any asbestos materials that had been 2 4 stockpiled? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY Hit L (609) 392-3543 TRENTON 132 1 -JOHN J. TABBUTT- 2 MR. STUTTS: I'm going to object 3 to the form of the question and also the 4 assumption in the question that asbestos was 5 stockpiled. It's also outside this witness' 6 designation. You can answer. 7 THE WITNESS: As far as I know, 8 the Power Generation Business Unit did not 9 stockpile any asbestos thermal insulating 1 0 product . 1 1 BY MR . WATERS : 1 2 Q. Were there ever any occasions when 1 3 a turbine would come to Westinghouse for 1 4 repair and it would still be within its casing 1 5 and within its insulation shell? 1 6 A. Westinghouse made a multitude of 1 7 steam turbine generators ranging in size from 1 8 units that can fit on top of this table to 1 9 units that were absolutely massive. 2 0 Q. Let the record reflect we are 2 1 talking about a table about fifteen feet in 2 2 length. Twelve to fifteen. Okay. 2 3 A. There were some smaller units that 24 were returned for service, but the smaller (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 33 1 -JOHN J. TABBUTT- 2 mechanical drive turbines weren't insulated. 3 Q . Okay. 4 A. Generally speaking, the outer 5 cylinder became a permanent fixture in the 6 power plant. 7 Q. So, is that, then, the basis for 8 your earlier testimony that you would not 9 anticipate asbestos insulation being something 1 0 that Westinghouse employees would have to deal 1 1 with at a Westinghouse plant in working on a 1 2 turbine? 13 1 4 Q. Are you familiar -- 1 5 MR. STUTTS: Let me make sure I 1 6 understand. That's a follow-up to the 1 7 question, I take it, about the repair of 1 8 turbines that would be -- or turbine parts 19 that would be shippedin toWestinghouse for 2 0 repair? 2 1 MR . WATERS : Right . 2 2 THE WITNESS: The Westinghouse 2 3 factory versus the plant. 2 4 BY MR. WATERS: (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 34 1 -JOHN J. TABBUTT- 2 Q. Right. The plants that -- the 3 Westinghouse factories that you are familiar 4 with, did they have a requirement that workers 5 wear respirators or dust masks of some sort? 6 A. The Westinghouse manufacturing 7 facilities did have certain requirements for 8 working in certain areas. It's a very, very 9 general question. 1 0 Q . Okay . 1 1 A. As an example, if a rotor was 1 2 returned to our factory to be dust blasted, 1 3 the operator or the dust blasting would wear 1 4 protective equipment during that process. 1 5 Q. So, was there a policy that 1 6 required dust masks in certain situations? If 1 7 you don't know, that's fine, we'll move onto 1 8 something else. 1 9 A. I think that the industrial 2 0 hygienist, who is going to speak with you at a 2 1 later date, is better qualified to answer that 22 question. 23 Q. Do you have, atWestinghouse, or 2 4 have you seen some sort of a publication that (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 35 1 -JOHN J. TABBUTT2 goes to employees or to managerial employees 3 like yourself? We talked about circulars 4 earlier that go to customers, for example. 5 What I'm asking about now is if there are some 6 sorts of publications that are distributed to 7 either all employees or some portion o f 8 employees or people who are involved with 9 management and that sort of thing? 1 0 A. There are publications that go to 1 1 all of our employees. 1 2 Q. Are there any publications that 1 3 you, for example, received that someone 1 4 further down the line might not? 1 5 A . I'm sure that there are. 1 6 Q . Have you ever seen any art i c 1 e s or 1 7 comments or anything in writing in a c o m p a n y 1 8 publication of that nature addressing asbestos 1 9 or the dang ers of as b e s t o s ? 20 A . Not that I can recall. 2 1 Q Did your particular divisi on or 2 2 does your particular division have its own 23 safety department? 2 4 A. Yes, it does. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY MIL L (609) 392-3543 TRENTON 1 36 1 -JOHN J. TABBUTT- 2 Q . And is that a component, if you 3 will, of a larger safety department for the 4 bigger Westinghouse? 5 A . Yes. 6 Q . Where is your safety department 7 located? 8 A. Orlando, Florida. 9 Q. Where is the big Westinghouse 1 0 safety department located? 1 1 A. Orlando, Florida. 1 2 Q. Do you know how many employees 1 3 there are in your division's safety 1 4 department? 1 5 A. No, I do not. 1 6 Q. Does the overall safety department 1 7 distribute things to the individual safety 1 8 departments to distribute to that division, 1 9 the specific division? Is that how the chain 20 of command goes? 2 1 MR. STUTTSs I'm going to object. 22 Thisis outside his scope of designation. If 23 he knows, he can answer, but I think you'll 24 get somebody else. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRYHILL (609) 392-3543 TRENTON 137 1 -JOHN J. TABBUTT2 THE WITNESS: Our division 3 distributes safety information directly to 4 each and every employee on a number of 5 issues . 6 BY MR. WATERS: 7 Q. Do you have any knowledge about 8 dust level studies as related to insulation 9 products used on or around turbines? 1 0 A. I think that that question could 1 1 be best answered by our industrial hygienist. 1 2 Q. If you are not aware, fine. 1 3 A. I'm not really knowledgeable on l 1 4 that subject. 1 5 Q. I didn't ask you if you were 1 6 knowledgeable, I asked if you were aware of X 7 any studies. 1 8 A . No, I'm not a ware of any studies. 1 9 Q In your divis ion m ed i c a 1 20 department and the safety depart m e n t, are they 2 1 one and the same? 2 2 A . They are all part of the human 23 resources group. 2 4 MR . WATERS : Do you want a take a (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HU L (609) 392-3543 TRENTON 1 38 1 -JOHN J , TABBUTT2 break for a couple minutes. 3 (Recess called at 1:57 p.m.) 4 (Resumed at 2:11 p.m.) 5 BY MR . WATERS : 6 Q Do you know a gentleman named M r . 7 GiUlicci? 8 A . Joe GiUlicci. 9 Q . Did much better than I. How d o 1 0 you know Mr . GiUlicci? 1 1 A . Joe used to be a project engi n e e r 1 2 at Lester. 1 3 Q Did you work with him? 1 4 A . Not really. 1 5 Q Where is he presently, do you have 1 6 any idea? 1 7 A . No idea. 1 8 Q How old a man was he when you 1 9 worked in h is vicinity? 2 0 A . I would suspect he's retired. 2 1 Q . Let me ask you again, how old d o 2 2 you think he was when you worked with him o r 23 around him? How much older than you is h e , 2 4 would you suspect? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 39 1 -JOHN J. TABBUTT2 A I think Joe is in his late 3 sixties 4 Q . At the present time? 5 A. That's a guess. 6 Q How about a man by the name of 7 Quinn, R . Qu inn ? 8 A . Don ' t know him. 9 Q Doesn't ri n g a bell , okay . 1 0 I ' m not s u re if you answered this 1 1 before / I th ink you m a y h a v e, but I just want 1 2 to m a k e sure I don't r e c a 1 1 . 1 3 I n connect ion w ith Westinghouse 1 4 turbines, is it your testimony that 1 5 Westinghouse does not specify or condone the 1 6 use of asbestos-containing products in, 1 7 around, or on its turbines at the present 1 8 time? 1 9 A . To the best of my knowledge -- 2 0 G As the person most knowledgeable. 2 1 A . -- Westinghouse does not recommend 22 the use of asbestos in thermal insulating 23 systems. 24 Q Does it recommend asbestos -- (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll l (609) 392-3543 TRENTON 140 1 -JOHN J . TABBUTT2 MR. STUTTS: Let me make objection 3 to the comments that were just made, as the 4 person most knowledgeable. As I recall, his 5 testimony was. he does not know anybody more 6 knowledgeable than he is. There are lots of 7 people in Westinghouse that may be as 8 knowledgeable as he on this subject. So why 9 don't we accept the person as he is a person 1 0 knowledgeable. I think the testimony was, he 1 1 doesn't know of anybody who has any more 1 2 knowledge than he does. 1 3 MR. WATERS: He's been designated 1 4 at the person most knowledgeable. 1 5 MR. STUTTS: He's been designated 1 6 by Westinghouse as the person who will testify 1 7 on this subject. You asked him whether or not 1 8 there would be anybody within Westinghouse 1 9 more knowledgeable. The answer was, he didn't 2 0 know of anyone. Whether or not his 2 1 counterpart in Texas or the State of 2 2 Washington has as much knowledge as John 23 Tabbutt does is a question that he did not 24 answer, and I think it's fair to say, given (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 141 1 -JOHN J. TABBUTT2 his testimony today, that there would be 3 others who would have as much knowledge as Mr. 4 Tabbutt would, and I don't, in fact, know if 5 that's the case about this particular 6 subject . 7 BY MR. WATERS: 8 Q. Going back to my question, are you 9 aware if Westinghouse has recommended the use 1 0 of any asbestos-conta i ning products other than 1 1 thermal insulation products with regard to 1 2 their turbines? 1 3 A . On-1 4 Q. At the present time, I should 1 5 clarify . 1 6 A. For high temperature gasket 1 7 applications there is no acceptable substitute X 8 at this time for asbestos gaskets. 1 9 Q. So, is it your testimony that 20 Westinghouse continues to specify 2 1 asbestos-containing gaskets for use in its 22 turbines, in certain circumstances? 23 A. In certain applications, certain 2 4 high temperature applications, Westinghouse (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 1 42 1 -JOHN J, TAB8UTT2 continues to recommend the use of asbestos 3 gaskets . 4 Q. What would asbestos felt be used 5 for with regard to Westinghouse turbines? 6 A. Do you have a copy of a card? May 7 I look at it? 8 Q Yes. 9 A . Used as a liner for met al jackets. 1 0 turbine covers, to prevent t u r b i n e heat from 1 1 burning the paint from the o u t s i d e surfaces of 1 2 the jacket. 1 3 Q. Do you have any personal 1 4 experience with that? 1 5 A . This i s -- the turbines came w 1 6 an e n c 1 osure and i t can be classifi e d as a 1 7 housing. enclosure, or lagging. or a turbine 1 8 cover . This spec dates backs f o rty-six years 1 9 ago, so forty-six years ago this was used on 2 0 the inside of the covering for the turbine, 2 1 metalcovering. 22 Q. That's not something that's been 23 used during the time frame that you've worked 24 for Westinghouse? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 43 1 -JOHN J. TABBUTT2 A. Well, this would have been used 3 for turbines installed in '46 that had metal 4 jackets. 5 Q. The materials cards, I asked you a 6 question sometime ago about whether those were 7 ever sent to the customers, and correct me if 8 I'm wrong. but I b e1 i e v e y o u stated that you 9 don't recall that ev e r h a p p e n i n g or a n y b o d y 1 0 ever asking for it o r anyth in g like that 1 1 A . I think what I said was that i t 1 2 was rarely done. 1 3 Q * Would it only b e done if the 1 4 customer as k e d for i t? 1 5 A . It would not be done for a p r o d u c t 1 6 that could be manufa c t u r e d by somebody e 1 s e 1 7 that was in direct c o m p e t i t ion, ala a bolt, as 1 8 an example. A customer may have a bolt on a 1 9 turbine, we don't really want to tell him what 2 0 the material is because that would enable him 2 1 to go outside and have it made by another 2 2 vendor, so we consider that proprietary 2 3 information. Insulation, we bought it from 24 somebody else anyway, and we have no real (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HIU (609) 392-3543 TRENTON 144 1 -JOHN J . TABBUTT2 desire to be in that business. 3 Q. Okay. 4 A. Therefore, that was normally 5 provided to somebody that had an installation 6 contract for the insulation so that they would 7 know what the requirements are to bid on it. 8 Q. So, while Westinghouse didn't have 9 a problem with p r o v i d i ng materials cards to a 1 0 customer. with re g a r d to insulation , who may 1 1 have wish e d to re view them, it wasn ' t 1 2 something that w a s don e as a matter of c o u r s e 1 3 is that f air to s ay? 1 4 A . Cards were not normally sent out 1 5 automatically, if that 's your quest ion. 1 6 Q . Well, do y ou have a spe c i f i c 1 7 recollect ion of e v e r s ending out a card to a 1 8 cus tomer who had r e q u e s t e d it? 1 9 A . Well, a c u stomer or an a r c h i t e c t 2 0 engineer or an owner o r a construct or or a 2 1 turbine installer would need to know what's, on 2 2 those cards in order to submit a quotation to 23 install what's shown on those drawings. 2 4 Q. They would need to know the types (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 45 1 -JOHN J. TABBUTT- 2 of products that metthe specifications so 3 that they would know how much they cost and 4 they could add that into their quotation? 5 A. Correct. 6 Q. And could they get that 7 information from you over the telephone? 8 A. Normally that was sent out on a 9 formal request to quote. 1 0 Q, Tell me how that worked. You 1 1 would send out a formal request for a quote? 1 2 No? . 1 3 A . Yes. 1 4 Q. You would? 1 5 A . Yes. 1 6 Q . A n d i n i t you w o u 1 d -- -- 1 7 A . No. We , m e a n i ng the s e r vice 1 8 department or the s e r v ice d i v i s i o n , depending 1 9 what year you are t a 1 k i n g about, w e would go 20 out for quotation S , i f w e -- a g a in , if we had 2 1 contractual obligations to furnish or furnish 22 and install insulation, we would go out for 23 competitive bids from approved suppliers to do 24 that work. Westinghouse did not do, quote. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 1 46 1 -JOHN J. TABBUTT2 its own insulation work. 3 Q . Right . Well, would part o f the 4 package be the mater ials cards or wou 1 d that 5 information just be incorporated on w hat you 6 sent out? 7 A. It would be part of the bid 8 package, drawings, process specs, material, 9 all the information required to bid on it. 1 0 Q. And that would go to, for 1 1 instance, an insulating contract? 1 2 A. Right, to a J and M or a Keane. 1 3 Usually what happened in power plants is that 1 4 there was an insulation contractor o n site 1 5 doing everything else. the balance o f plant 1 6 work. the boiler. the reactor, whatev e r the 1 7 case may be. Generally what happened was that 1 8 that was the same contractor that did the 1 9 turbine work, only because they were there on 2 0 site and could do it usually cheaper than 2 1 other vendors that would have to come out. 22 Q . I'm just confused about a 1 i 111 e 2 3 piece of the process . I understood you to say 2 4 earlier that it was relatively rare for the (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 47 1 -JOHN J. TABBUTT- 2 materials cards to be sent out. 3 A . Right. 4 Q . Now I think I'm hearing you say 5 that as a normal routine part of the bidding 6 process they would be sent out as part of the 7 package, and I don't mean to confuse you, but 8 I'm confused. 9 A. Okay. Again, the only time that 1 0 normally we get involvedwith the process is 11 on new equipment. When a new turbine 12 generator issold. We are required -- if the 1 3 contract requirement was that Westinghouse 1 4 provide the insulation, provide and install 1 5 the insulation, we would solicit bids from 1 6 various contractors requesting a formal quote 17 on the work scope. The work scope is defined 1 8 in the drawings and process specs and material 1 9 cards. We provide all the bidders the same 2 0 information as to what we want, and they, in 2 1 turn, respond back to us. 22 Q . Okay. 23 A. We select the appropriate bidder 24 to be the contractor for that particular (215)564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 148 1 -JOHN J. TABBUTT2 contract . 3 Q . And that's a situation where -- 4 A. They come in at the end of the 5 installation, install the insulation and they 6 leave . The uni t goes into operation and 7 Westi n g h o u s e ' s obligation f or their contra c t 8 is o v e r . 9 G And this is in the relatively rare 1 0 conte x t w h e r e W estinghouse is responsible for 1 1 pr o v i ding i n s u 1 ation servic es and they 1 2 c o n t r act i t out to someone else, correct? 1 3 A . I f required by Westinghouse, I f 1 4 it's part o f a contract by Westinghouse . We 1 5 don't d o i t our selves . 1 6 Q Right, I unders tand. I guess what 1 7 I got c o n f u s e d with was thi s is a relative iy 1 8 rare p r o c e du r e because, for the most part. the 1 9 customer took care of the i nstallation. 2 0 correct? 2 1 A . N o . What I lea n by rare is we 22 normally don ' t send those c ards out becaus e 2 3 there i s literally hundreds of thousands o f 24 cards for different products, bolting, on and (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 49 1 -JOHN J. TABBUTT2 o n a n d on. S o , it's rare that we sent out 3 m a ter ial cards. but on i n s u 1 a t ion, because we 4 d o n ' t have anything to do with it, the people 5 b i d d i n g on it n eed that information to bid. 6 Q I ' m sorry for the breakdown , but 7 u n d e r stood you to say earlier that the 8 insulation was taken care of by a contractor, 9 it was not something that Westinghouse was 1 0 contractually obligated to provide. If 1 1 Westinghouse was contractually obligated to 1 2 provide the insulation work they would do so, 1 3 but they would get somebody else to do it. In 1 4 other words, they would contract with someone 1 5 else to provide the service and then they 1 6 would bill the customer for it, correct? 1 7 A . Now I ' m confused. X 8 Q Let's go off the rec o r d . 1 9 (Discuss ion is held off 2 0 record. ) 2 1 BY MR . WATERS : 2 2 Q . Let 's talk about this one first. 23 we'll mark this as Exhibit Number 2 . Can you 2 4 tell me what th is document is? (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 150 1 -JOHN J. TABBUTT- 2 I t a process specification 3 number 600433. 4 Q . And what is it a process 5 specification for? 6 A. Process spec is for application of 7 block and molded insulation. 8 Q. What sort of information does this 9 provide? 1 0 A. Provides the how to, as far as 1 1 application of block and molded insulation of 1 2 turbine cylinders, valve covers, steam chests, 1 3 pipes, flanges and other parts as described in 1 4 the specification. 15 Q. And thespecification is two pages 1 6 in length? 1 7 A. Correct. 1 8 Q. Would this specification apply to 19 a specific turbine or two specific turbines? 20 A. There is no way to take the 2 1 specification, which is sub 16, dated 1965, 22 and find out what units this applied to. 2 3 Q. But, if you had other 24 documentation -- (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 151 1 -JOHN J. TABBUTT2 A. But, if I had a turbine generator 3 that was installed in 1965 and looked up the 4 cor d s and the records showed that p r o c e s s 5 e c s 600433 sub 16 was used. then this would 6 t h e docum e n t . 7 Q. And then this document would 8 explain to you how that turbine was meant to 9 be insulated? 1 0 A . Correct 1 1 Q Can you look at the d i a grams o n 1 2 the right- hand column of the fi r s t page a n d 1 3 tell me -- actually , it appears t o be f a i r 1 y 1 4 specific. although it's a littl e b i t di f f i c u 1 t 1 5 to read. Does this call for -- can you t ell 1 6 whether th is calls for use of a s b e s t o s 1 7 insulation ? 1 8 A . This specification call s for 1 9 utilizing Westinghouse material 46102BB, 2 0 calcium silicate blocks. 2 1 Q. And to know more about that we 22 could look at a material card? 23 A. A 1965 material card, correct. 24 Q. Without looking at that card, do (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HIL L (609) 392-3543 TRENTON 1 52 1 -JOHN J. TABBUTT- 2 you k now i f t h a t c a Icium sili cate i 3 a s b e s t o s - c o n t a i ning product? 4 A . I w o u 1 d prefer to look card 5 from that s p e c i f i c time frame 6 Q oka y 7 A . T o reac quaint mys elf. 8 Q The ref erence to molded 9 i n s u 1 a t i o n , i s that what you and I ' 1 0 calling pipe covering? 1 1 A. Correct. 1 2 Q . Let's take a look at the other 1 3 document, which we'll call Exhibit Number 3 . 1 4 What is this a specification for? 1 5 A. This is Westinghouse process X 6 specification 600729, sub 10, dated 1965. I t 1 7 generally covers the application of water 1 8 resistant thermal insulating block on the 1 9 inner and outer surfaces and of plastic 2 0 insulation over the block on the outer sur face 2 1 of turbine cylinders and other turbine par t s . 2 2 Q. Why is it necessary to have wa ter 23 resistant insulation on the exterior of a 2 4 turbine cylinder? (215)564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 53 1 -JOHN J. TABBUTT2 A . Which p r o c ess spec is used is 3 usual ly dependent upon the customers' 4 r e q u i r e m e n t s . Th ere a re some of our units 5 that are outdoor units that do not have -- or 6 not c o n t a i n e d within a building, per s e , that 7 are e x p o s e d to t h e e 1 e ments. Some of those 8 units there are d i f f e r ent specificati o n s than 9 i n d o o r units 1 0 Q This parti cular specification is 1 1 an ex ample. I g u e s s , o f a situation where 1 2 a s b e s t o s - c o n t a i n i n g b 1 ankets were not used to 1 3 i n s u 1 ate the c y 1 i n d e r ? 1 4 A . This p r o c e ss spec does contain 1 5 total block i n s u 1 a t i o n over the turbine, 1 6 Q . Okay. D o you find that to be 1 7 unus ua 1? 1 8 A . Very u n u s u a 1 . 1 9 Q . But i t is an example of a turbine 2 0 i n s u 1 a t i o n s p e c i f i c a t i on that requires thermal 2 1 block insula t i o n to be used and surround the 2 2 entire cylin d e r , c o r r e ct? 23 A. Correct, r igh t . 24 Q. And if the cylinder were so {215)564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 154 1 -JOHN J . TABBUTT2 insulated it would b e neces sary t o remove at 3 least some portion o f that block i n sulation to 4 make repairs on the turbine, itself? 5 A. Our competitors use the design 6 shown on 600729. Most of our customers did 7 not use this specification purely for the 8 maintenance reason, that it has to be totally 9 disassembled for access to the joint bolting. 1 0 None of my customers, to my knowledge, in my 1 1 r e g i o n, or the units I've worked o n , w o u Id 1 2 have had this type o f i n s u 1 a t i o n s y s t e m o n 1 3 their turbine genera tors. Again, the s p e c 1 4 drawing list for a specific unit would 1 5 indicate which one of these process specs 1 6 would apply. 1 7 Q. Let me again object to the 1 8 responsiveness of your answer. 1 9 My question was. i n this con text 2 0 i t would be necessary. would i t not, to remove 2 1 the block insulation in order t o effect 2 2 -repairs to a turbine? 23 A. If a customer chose process spec 2 4 600729, sub 10, it would be necessary to (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 155 1 -JOHN J, TABBUTT- 2 remove the block to inspect the turbine. 3 Q. And you stated earlier that this 4 was a design utilized by your competitors? 5 A. Correct. 6 Q. But it was also, as is apparent 7 from the Westinghouse document in front of 8 you, that it was utilized by Westinghouse? 9 A. It was adesign that wasavailable 1 0 to our customers. None, to my knowledge, have 1 1 taken advantage of it. 1 2 Q. What are the numbers of those two, 1 3 again? 600729. What was the number? 1 4 A . 6 0 0 4 3 3. 1 5 Q. Do either of those -- we know that 1 6 one of them doesn't, but do they both 1 7 anticipate using block rather than blankets? 1 8 A. The 600433 utilizes the removable 1 9 blankets over the joint bolting for 2 0 maintenance . 2 1 Q . What sort of -- how would you 2 2 describe the texture of the blankets, the 23 exterior of the blankets? Rough like canvas? 24 A . Um-hum. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 1 56 1 -JOHN J. TABBUTT2 Q. Do those blankets need to be 3 replaced from time to time? 4 A. Everything needs to be replaced 5 from time to time. 6 Q. How often would the blankets need 7 to be replaced? 8 A. It varies. On an as required 9 basis . 1 0 Q. Did Westinghouse advise any of its 1 1 customers on or about 1973 that they should 1 2 replace their asbestos-containing blankets 1 3 with some other type of blankets that did not 1 4 contain asbesto s ? 1 5 A . If the unit was made before 1 6 1946 -- after ' 46 it didn't contain asbestos. 1 7 Q . But I believe you told us that the 1 8 exterior -- 1 9 A . Was a n asbestos cloth. You said 2 0 asbestos filled / I thought. 2 1 Q . Id i d n ' t mean to if I did. I 2 2 apologize. Let m e put this question to you 2 3 this way: On or about 1973, when Westinghouse 24 became aware of the hazards of asbestos and (21S) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 57 1 -JOHN J. TABBUTT2 stopped using asbestos insulation materials 3 and stopped specifying them, didWestinghouse 4 do anything to advise its customers that they 5 should replace the asbestos blankets with the 6 exterior of asbestos cloth that they were 7 using in many cases to insulate their turbine 8 cylinders? 9 MR . STUTTS : Object t o the f o r m of 1 0 the q u e s tio n to the extent that you have built 1 1 in an a ssumption that it was on o r about 1973 1 2 that Westinghouse learned of the hazards of 1 3 asbestos. But, other than that, you can 1 4 answer the question. 1 5 THE WITNESS: I'm not aware of any 1 6 customer correspondence at that time or around 1 7 that time advising them to replace their 1 8 insulation blankets. That does not 1 9 necessarily mean that that was not done. 2 0 BY MR . WATERS : 2 1 Q. Did the exterior of the asbestos 2 2 blankets become worn or frayed over the course 23 of time? 24 A. The insulation blankets did, like (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HU l (609) 392-3543 TRENTON 158 1 -JOHN J. TABBUTT- 2 any other component, wear out over time. 3 Q. Now I would think that you 4 personally wouldn't have a lot of occasions to 5 W 0 r k with well worn or well used asbestos 6 b 1 a n k e t s , because when you went to have a 7 at the turbine the insulation was already 8 removed, correct? 9 A . Right. 1 0 Q. Are these documents. Exhibits 2 1 1 and 3, documents that would have been prepared 1 2 in the usual course of Westinghouse's 1 3 business? X 4 A. Yes . 1 5 Q. And they would have been 1 6 maintained, again, in the usual course of 1 7 Westinghouse's business? 1 8 A. Correct. 1 9 Q. Do you have any doubt that these 2 0 are true and correct copies of the originals? 2 1 Feel free to take a look at them again, if you 22 want. 23 A. They wouldappear to be originals. 2 4 Q . They are notoriginals. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 59 1 -JOHN J . TABBUTT2 A. Copies o f originals. 3 (Exhibit Tabbutt-2 is m a r k e d for 4 ident ification , ) 5 (Exhibit Tabbutt-3 is m a r k e d for 6 ident ification . ) 7 BY MR . WATERS : 8 Q . I t a k e i t that you were aware when 9 you s tarted working for the company in 1967 1 0 that material cards or some of the material 1 1 cards contained a wa rning about asb e s t o s dust? 1 2 A. Correct. 1 3 Q From what you 've seen in the 1 4 Westinghous e records. how far back in time 1 5 were there warnings on material cards about 1 6 asbestos dust? 1 7 A . I really don't remember h o w far 1 8 back the warnings go . It's something w e could 1 9 look up , but X don't really remember how far 2 0 back they go on the cards . 2 1 Q . All you can say with cert a i n t y is 2 2 that they were there when you got there i n 23 1 967 ? 24 A . Yes. (215) 564-0675 PHILADELPHIA REPORTING ASSOCIA TES (609) 795-2323 CHERRY Hll L (609) 392-3543 TRENTON 160 1 -JOHN J. TABBUTT2 Q. And the designation, GTS 3 engineering, what does GTS stand for you, if 4 you know? 5 A . Gas turbine system s . 6 Q Gas turbine system s ? 7 A . Uni-hum . 8 Q Do you reca 11 a Mr -- 9 A . It depends on what year i t was. 1 0 Q July of '72 1 1 A . That was th e year o f the gas 1 2 turbines . as turbine systems Did i t 1 3 pertain to a combustion turbine or a steam 1 4 turbine? 1 5 Q. Just a memo on asbestos from '12. 1 6 Just talks about substitutes for block. What 1 7 I wanted to ask you about is if you recalled a 1 8 Mr. Haftel? 1 9 A . A 1 Haftel . 2 0 Q . A1 Haftel. Is he still with the 2 1 company? 22 A. I don't believe so. 23 Q. How did you know him? 24 A. He was with the gas turbine (215) 564*0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 16 1 1 -JOHN J. TABBUTT- 2 division in the '70's and at t h a t time I was 3 installing combustion turbine sy stems . 4 Q Did you all have any dealings with 5 o n e another? 6 A. Business. 7 Q. Did you work withhim -- just 8 business? 9 A . Yes. 10 MR. HATERS: Idon't have any more 1 1 questions. At this time. 1 2 MR. STOTTS: Why don't we take 1 3 about a five-minute break. 1 4 (Recess called at 2:55 p.m.) 1 5 (Resumed at 3:08 p.m.) 1 6 MR. STOTTS: We've just taken a 1 7 break and I've talked to Mr. Tabbutt about a 18 couple points just for clarification, that I 1 9 would like to state for the record that, if it 2 0 prompts any follow-up questions, then, Andy, 2 1 you are free to follow-up on those. 22 First I wanted t 0 make sure that 23 one point Mr . Tabbutt made was understood. and 2 4 that is, he commented that the felt lining for (21S) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY Hit L (609) 392-3543 TRENTON 16 2 1 -JOHN J . TABBUTT- 2 the lagging was used in 1946 and, as I recall 3 his testimony, it would have been used for 4 turbines installed in 1946. I want to make 5 sure that you don't understand that to mean if 6 it was 1947 or 1948 that it may not have been 7 installed in one in 1947 and 1948 or some 8 other time. The point is, you have to look at 9 the engineering record, the turbine record, to 1 0 know whether or not that particular product 1 1 was called for for a specific turbine. He was 1 2 not saying exclusively it was used only in 1 3 1 9 4 6. 1 4 And the second thing is that Mr X 5 Tabbutt has been testifying about material 1 6 cards and the relationship between 1 7 Westinghouse and its customer and the 1 8 insulation or the architect 1 9 engineer, and that has been to the extent that 20 it has been general or generic in nature, it 2 1 has been with relation to turbines that are 22 installed and erected in the field; that is, 23 at the power plant, itself, and again I think 24 that the point to be made is that you have to (215) 564-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON 1 63 1 -JOHN J. TABBUTT2 look at each record individually to know what 3 was called for, but I want to make sure that 4 we are clear on those two points. 5 MR. HATERS: I don't have any 6 further questions. 7 We have an agreement that the 8 witness will review his deposition and make 9 any changes and sign the original and that, if 1 0 notification of changes has not been provided 1 1 within thirty days of his attorney's receipt 1 2 of the depos i t i o n , that we can use the 1 3 original or a copy uns igned for any purposes 1 4 at trial or whatever. 1 5 MR. STUTTS: Or for whatever 1 6 purposes you can use a deposition for. 1 7 MR. WATERS: Fair enough. 1 8 (3:11 p.m . ) 19 20 21 22 23 24 (215) 664-0675 PHILADELPHIA REPORTING ASSOCIATES (609) 795-2323 CHERRY HILL (609) 392-3543 TRENTON fPEOER'CK M SARON Mussel.w buod SPENT M PCSENThA: -JANE N SAO'NAW 9PIAN o wE; N S r i N -ISA a BljE O- O MAPV e SKELNlK STEVEN O wOlENS Baron <3c Budd A PROFESSIONAL CORPORATION ATTORNEYS AND COUNSELORS THE CENTRUM 3102 OAK LAWN AVENUE SUITE iiQO Dallas. Texas 75219 (2IA) 321-3605 TELECOPIER (ai) 520-nai April 21, 1992 jCNAThsN OAVO 'PETER A KRAUS JENNIFER a CAl-ClN JANICE E ROS'NSCN SCOTT M hENO-EP LICENSED ONlv in IL ANO MO LICENSES ONL' in va VIA TELECOPIER Mr. Robert E. Thackston McGuire, Woods, Battle & Boothe One James Center 901 East Cary Street Richmond, Virginia 23219 ^ Re: Dallas County Asbestos Litigation Dear Robert: Please find enclosed a notice of deposition as we have discussed. Please note that the deposition notice requests the production of certain documents specifically dealing with Westinghouse turbines. I believe that this is in line with your request that discovery in this respect be limited to specific Westinghouse products. With regard to your request to review documents/exhibits, please contact Pat Folkerth directly to arrange for a convenient time. In addition to the documents you have requested. Plaintiffs, of course, reserve the right to use as exhibits any of the documents produced by Westinghouse in the last six weeks. Those documents will not be made available for review as you have already reviewed them in conjunction with their production. Please let me know if you will be attending the deposition in Philadelphia. If not, I hope to meet with you on Thursday the 30th or Friday the 1st to discuss other outstanding discovery issues. Very truly yours, CAW/k Enclosure cc: Mark Hendrix Dallas Counsel C. ANDREW WATERS IN RE: ALL ASBESTOS PERSONAL INJURY CASES FILED IN DALLAS COUNTY. TEXAS IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 160TH JUDICIAL DISTRICT NOTICE OF DEPOSITION TO: ALL COUNSEL OF RECORD PLEASE TAKE NOTICE that Plaintiffs, by counsel, will take the deposition of JOHN TABBUTT, designated by Westinghouse Corporation as its representative most knowledgeable to testify concerning: Defendant's specification for use of asbestos-containing insulation materials on, in, or around turbines manufactured by Defendant. The individual or individuals designated should also be able to testify as to how, where and why asbestos or asbestos-containing insulating substances or products were incorporated into, onto or otherwise made a part of Defendant's turbines. * The deposition upon oral examination will take place before an officer duly authorized to take depositions and swear witnesses from Pappas Reporting, 710 5th Avenue, Suite 1000, Pittsburgh, Pennsylvania 15219 (412/566-2209). The oral examination will commence at 10:00 AM on Wednesday, April 29, 1992 at the law offices of Sherr, Joffee & Zuckerman, P.C., 200 Four Falls Corporate Center, Suite 400, West Conshohocken, Pennsylvania. The deposition will continue from day to day until completed and you are invited to attend and cross-examine. The witness is required to produce the following documents at the time of the deposition, as follows: 1. Any and all photographs or diagrams not already produced that demonstrate, show, depict or indicate the application or presence of asbestos insulation materials, or other insulation materials, on Westinghouse turbines or attached piping or other attachments to Westinghouse turbines; NOTICE OF DEPOSITION Page 1 2. Any and all documents not already produced describing, detailing or discussing the application of asbestos insulation, to Westinghouse turbines or attached piping or other attachments to Westinghouse turbines; 3 . Any and all written instructions not already produced relating to the application or replacement of asbestos insulation Westinghouse turbines, or attached piping or other attachments to Westinghouse turbines; 4 . Any and all written precautions or warnings not already produced regarding, indicating or discussing the application of asbestos insulation to Westinghouse turbines or attached piping or other attachments to Westinghouse turbines; Any and all printed or written warnings or instructions not already produced that relate to the dangers of possible inhalation of asbestos fibers or dust during the application of asbestos insulation on or in the vicinity of Westinghouse turbines. Respectfully submitted BARON & BUDD A PROFESSIONAL CORPORATION The Centrum, Suite 1100 3102 Oak Lawn Avenue Dallas, Texas 75219 214/5?1-'J*AK BY RUSSELL W. BUDD State Bar No. 03312400 BY C. ANDREW WATERS State Bar No. 20911450 NOTICE OF DEPOSITION Page 2 CERTIFICATE OF SERVICE I hereby certify that an exact copy of the foregoing has been telefaxed to counsel for Westinghouse on this the ^ day of April, 1992 and sent regular U.S. mail to all other counsel of record herein. ----* C~." ANDREW WATERS NOTICE OF DEPOSITION Page 3 6. ..I - Vi." &* .-.-**** '***> >?*'* * - "-r?- f * T-ri-- -vft>L/. '-fV--Tfn'-"' '-' rtfiM----------r' r r Ol\ri -'-< l. i* ^ *** fv {..., r . f * ,' - - * 4^ . , - i. ` 'Un --*\ PRO\.-S$ SPECIFICATION . APPLICATION OF BLOCK AND MOLDED INSULATION 600433 PACE I OP * ccnERal. OiC :iTxn.t CClSuftS nCCIIS*** rot nl PPl:CAT.cn Of nluufi* KXI AM { t Ct*C to tuRAinC c>l- nfi!T>r.vt cats. 5Tt exists. ks, u<o c*other plats *t oiscmieoin t* sns^c*rtc. tiinsula^c* pyre mo tvicancs* >*".1. Si shorn on rl insulation orawinctoa UO> class er ru****. this sftCifiCATicN il Orvieio iro r#c nt*j fOiLO**:* PART t . APPLICATION Of BLOC*. TfJTTr . tPMunon Cf yOLOSO PIPE CffliC. /Vi!5 par? i application of blockcchk *>tt 77vpl*atl-ri bees not tjccio *oo**.. material aeiijmcalolw silicate blocks sall sc applied in*single LAYER Oi*lCTw TO tt SU*f *CE BEiNC UtiUUO. when temperature rances prom mi* ro iaso*f.. * double LAYER Of MATL. *610288 BLOCK INSULATION SMALL REUSED. DjER 10SCF.. OOUBLE LAYER CONSHTIHCOf MATERtAL U*DIW (INNER) ANO 4610288 'CURB) SHALL 81 USES. OPERATIONS- 1. SELECTING, CUTTTN6 AND nrftRC BLOCIS. 2. ATTACHING ANCHOR POINTS. 3. AlT*Cx<*C ITAII6CM*C$. 4. (CvCHtC TURBINE ASSEMBLY fLANCES. 5. COVERING PPE fLANCES. 6. PATCHING. FILLING AM flMSMINCWlTH MATERIAL 46110SA CIment. 7. COVERING PIPES Of LARGE 0'AUCTER. 4. COvfNiM fu*8INC ASSCwa.T f(_ANCCS INSULATION shall SC S-iPPEO A SLff'C'ENT OISTAWCE fRCTR ALL fLANCES 'O ALLOA ACCESS TO ON NfvOVAL Of BOLTS am ASSO* CiaIIO ^A4TS AT C AJ-ACENT TO THE f LANCES. IN CCNEtAL. lbOUSrAL *V*8INC ASSCU8LT fLANCES shall be C^ERCOwtTh SLANXt TS AS S-9RN1N fiCUNE 1. (SEE PROCESS SPEC. 600)391. - ON SPECUL INSTALLArKT^LOCIS HAY 8E RE0UT4E5 fOR JOINT C0WEA1NC. IN SUCH CASE 5 ^NT SHAA.L BE PNOTECTEO BY A *y '.* mi'h "YCEL, MA'EP'Al 1S16-1 tCiNfONCCO >H"| A-M-. -Ii.< RiClOirY 04 AS PPCW-0E9 tr P40CESS OLOCKSSh>aL THEN BE APPLIES TO T"C PPOTEiflNC BLOCN ALUTCN 1. SELECTING. CUTT1NCAM FITTING BLOCKS BLOCK SHAPES SHALL 81 SELECTED TO CONFORM AS NE PRACTICAL to ThC Shape OS CONTOUR BE nC COVERED. inSU may 9( Cur mkth Cither a ham or.a power Saw. MPEnoi* QUANTITY AM AMOUNT of f'TTING NECESSARY. '' 16 GENERAL, the LCNCOlWENSiQNCf BLOCKS I M fLACEO 0* to THE CURVATuAtOP TmC luBFACC WHEN HTTiNC BLOCKS. SLlOtT Olff CtNCC$ IN SCIVrEEN the iNSvcaIION anO THE PANT T 8E C MBLE. IN SUCH CASES. THE INSULATION BLOC OWEN A TMIW COATINC Of INSULATION CEMENT APPLIEO OlNCCTLY TO THE SUNfACE Of TV APPLIES WHILE THE CEVEN7 IS WET. WHERE SEVERAL LAYERS Of BLOC :f THE top LAYER Shall 8C STaCOE .Are*. Each LAYER Shall JC wini ALL JOiNTS AM OPENINGS *I>PSH 2. ATTACHINC ANCHOR POINTS ON ALLOY STEEL CAST. *CYUNOE*<AM 0THER1 IN. TO STYLE JWAffCR ito* WHEN PIP FLANCCS * IN. ANO OVEN NIC INVOLVED COVE THEM [WITH tlPAMCD METAL CM'S ANO INSULATE AS SHOW* ON fICUPES 2 AM 3 ANO AS OCSCRISSO IN PANT li OPERATION t. . CAUTIBIfc NO'fU TO ANYTl^Oy-STCELI EMNCCRINOAPP' 270A0YSH01. SMALL BE WEL3EP C*C RCaiAREO TO:ANCHOR INSULATION. (LHRC Oifc (SEE fICURC l)~ - S OR FORONCSt EYt OOLT STUOS MAY" STINC 0R-P0ROR6 USINC the STLft L BE LOGLTlO SO THAT RETMRIRC ' RtiN-Af RIQIT ANCLES TOTHS OjRVANCCOVCREO, MAT AIOIT ANCLES TO TMC rsuRfAcest MIU NAM OP HMJLATT06 4*0 ^.TUWl. I4TIWnACPLOTH 1 'aadai!&sswsi MNSTTLVIO1OMNNWNITH4TI TTLO.NN6OHMORN*T t/^TO fYEMPEAATURESUP TO SO0^.. SETT CALVANI2C9 m .UNf&AL 36*7'-l. OP 1VCACE Si2SSMAL>.B( USeMC&N-tfTAINiaCMIRCV SERVICE TEMPIRATVACS ABOAR 500"*. SftIMLESS STSU MR, .0*70*. 0T7MR-2 MATEJML SMALL EC'USd.*' __ _ _" THCWRRES SMALL MiECMC* TMC OLOWtOR WAPES AN*SCUD TOTH* ANCMORPONPISECUMM TMCOL^CAS PMMlLY I*PLACE. - WINtLOOPS THMTCO TOCETH(A TMiKCR LOOPS SMALL I EOON.PWgTNSULATW ANO SMALL M -TR PAE^QRBNMOMS, THE l;tSH ' RPPLio-Anai er iniulation to uwilAEaa til TMINUONMO imsTo*CTAtl NIL TIM*) EM S \v*- msmmm i&m pk osx. ^ [ &$**** E | ( CS Sz X * A* - ----- u ;Sj'.-v^:.-.. ^> 4,4;. '*- iCO\<c^. r "' J "H 6004-33 PAG 2 OF 2 PROCESS SPECIFICaOn APPLICATION OF BLOCK AND MOLDED INSULATION 6. patching filling a no F'nsh'nQyhth 61io&a matebial .NSuUAr.cvccvENT watebj*l 4U0*a shall #6 usCBvnTM 4*n**oc*d#>Uo<b4i*.cpl*p*lt;coftb{loflcw*.s*kfiuoc*cpwattc.h1in.4g,tfoillli2ngm>o*mtchiuctf^.*<*nbeetas \ M*1NIL *6 UOBA lS AP^-lEO BY MUlNCwtTM A MINIMUM AMOUNT OF WAtEB ic PBOOuCC STIFF Mil 4*0 THEN TBOYltUNCIN PLACE. 4. FINISHING ' INSULATION CEMENT. MATEBtAL 461108A. SHALL SC USES FOB FITTING. PAIOHnCAM FlMSHINO FIFE INSULATlCB. >EN PIPE INSULATION IS SECU0 IN PLACE. FILL ALL PINTS ANOCPtNINCS 'MTM CEMENT 44110BA Uixto -STM A MINIMUM (* AAT ro PNCOuCt A STIFF Mix. TBOAEL IN PLACE UNTIL A SMOOTH NEAT APP1AAANCC IS OBTAINCO. . 7. ctn ms a met ojamctcb .' LANCE B^PES < to (4 ) $MM.t SC CE9 AS MCV'OUSir 0ESC*I819 . 0tATlC*S 1 440 J WtTH BLOC* INSULATION ANO FiNSmCCJ AS 0CSCBI8C3 i FAST il. CPCBATlQN I. PABTI1 APPLICATION Of UQLOCO PIPE IHSULATlOM PIPINC EXTEBNAL TO THE TUB0INE SMAU C0VCNE8 HATH 12 OUNCE PEB SQUABE YANO ASBESTOS CLOTH MATE PUL 41S11 API PASTtO OH HATH UATCtlAL S3SS10U PASTE. AFlML COAT OF PASTE SHAU. e APPLIES W(l THE ASBESTOS CLOTH. BEON CBOSS-OVEB PIPES. V)VCN PASTE IS OPT. PAINT SHALL FlNtSN SPEOFICAnON 1180.APPUEOINACCOBOANCC WITH UKUl: UaTCBiAL 4660104. -TUP. PlBl INSULATION *40 MATEMAA S4JSUM $;l;CATE PIPE INSULATION ABC NOLOEO TO FIT STANOABO pipe sues uATeiAA annoiba consists of a single latch of MI-TEMP. iNSlLA'iOniN sues UP 10 1-1-2 IN.. INCL.. A40 AOQUBLt LAYER OF A hi-TEMP. ANO A SJUCATC INSULATiCHtN SUES CNt4 1-1/2 14.) OPERATIONS- t. SELECTING *40 FITTI40 PtPC INSULATION, 2. COVENiNC PIPE FLANGES. 3. SECLBlvG INSULATION. 4. FlNSiNG. . . . ,,. ' 'CCM*Tf;*Ir4J.I0B*AS\ r?CJ *MC)TOS C*.CY 'v *S.| SUSU *U'i MFOa<MscFo IclCoallMooi 1. SELECTING A40 FITTING PIPE INSULATION. STAtiexT WPE SECTIONS . 04 SnaiGHT SECTION* OF PIPC SPLIT CVLMORtCAL MOLDED SCCTI04S OF PIP( INSULATION SHALL 8 USEO. EACH LATER SHALL 8 INOTVIQVALLY APPLitO. 06C H OTHC. UNTIL TH6 SPECIFIES,. N thickness a$ seta attained. the cm joints between SECTiiwy SMALL 8 TtOlTLY 8<jTT0 14 E*CH LAYER. A40 THC LONGITUDINALS'- joints f*ou section to section shall be staggered *no Tj-artC OBAWN TOGETHER 0V MEANS OF MPE LOOPS. THE LONClTUOIOOUND' CIRCUMFERENTIAL JOINTS FQ0 (ACM LAYER SHALL ALSO BE STACCTEO NRTK RELATION TO THE ADJACENT LAYER. NV CLV0 PIPE SECTIONS ONCUNVEO SeCTICNS OF PIPE use SHUT. I INSULATION WHEN AVAILABLE. AMO WINE IN-PLBCI WHEN CLNVCO SHAPES ARC NOT AVAILABLE. STRAlOir MOLDED FIFE INSULATION 0* t ' SMALL BC AiNEO-IV PLACE OVEN A ACT I 46110SA 4PPLIC0 0I4CCTLV ro me FTPC; IBRECULAR SHAPES Ate USCO. THE OUTS* FINISHEO NEATLY AND SMOOTHLY. USU THC OESIPEO BESULTS. ' 2. C0VE414C PIPE FIANCES. PIPC INSULATION SHAL FMM FLANOES TO ALLOA ACC ON TO ALLOW FOB FLANCC , YOAIEfIO.NFITLEAVDNCISCBTESASBN'OCLETS OtfiATEB. P'PE FLANGE MTTH UPANOEO ME (NSULAT1GN AS SH fitexpanocomEt SECncNs abound me F' MOLOCO PIPE INSULATION TEXCECO *0 LBS.). APPLES WTMWTL. 7960-2'MB OIOC* TO FAaUTAT^J on pipe 2CBESFMOBACLLABPE0LPYB1ONT8E- CTESr FOLLOWSr S Ti_iOr_uF_ALA_sJPtHtCAnEMoANNtiaOsjcrHNecPETuTiOMuTO-NsaOSlrEoTnTbHovkE*tBot* mnc MB CS at stcnO.B jaars t ' :6INu INSULATE AS SIIMW 4NFW. 4. -PATCM/^t^MVPtWSI ALL OPEWNCS.ANO joweswib CfMCTI*TL.^A^AASMSC^UlSMM6-aOX ' S. SECUBINC INSutATfON- ' V> ' ' '1 '" MTVWLEOBg.BMOCrCPPfLSC.USOBMNSOAAHAFPTTCCSAEUOUOIBIBN.NEFASSSS'SC*U.UO.7LTPTFA9VNTT6lMiSOOt^STP-SNTEI3C'TStC.gOOHTl3FHOA*M1C,LCLTLACpCEBTBiABOCHMCCETSEIBCUSVAmCILtBB*UOBnSOMOCiTLi9gM.EA1M^FWN'AdTPUVT1LUQSMAAUS4SX-LMSV3tlffEBNF.*.|NWSA.BES..C..B0-A.1T*.A,M3O.F*O.XMF0.fTFL.E'* <5 /l *4- `m - , iii-r^M^ifaiiiri .Siifftifi '/ / .'V --V -<<r ^vJE- v-^rst- ~\ CH1MQC0 \ '''Vi i: * * ,' * *' * f v # ; i ~ .. P i5S SPeCJFiCATiOH f**u S*f m APPLICATION OP 8LOCX ANO PLASTIC INSULATION 600729 PACE i F 2 CEt*L - - O\i.C.(iS)CC(WrCPuEitO.5oit oTp"f*4PclcSaiPoSEu"CC*FtsiiaCaaScuTciloea*sT.siCaPryOyCc*TtHhEeB*LpO*CuKCCA*tic*A(oOfUmTEaRteS*URFcAsCiSEtOaFatTUnB-ftctAwi CivLia-ASOuElPaSt-iaMc ivO<TXH>ERoaT u*><(*R*(*RcT*J Uo(t r( iaSulaTiOa OPAanacs ret c*Cm tu*aE will $9* r< tASgLAnca type mo TwC*t$i to m appliEO. this SPtCiFICATic* is 0<Vi0E0 iAtO r#o Parts AS FOLLOWS rapt i APPLiCAfioaor aiOCt iasulatiCa. - ' p*nr >{ *ppl-catica cr plastic :SL'iAtica. ' i>*>> th n-e\. ca^ca cr slock iaSuLAt_ct S'APS AS PPCYlOUSLT OESCAMB. CESEAAL -' ' 141 CCVEAAC VALVE SOAAfTL OALV WAtEP CSiS?Ar 'HEIMal lASULATrAC BLOCK UATEB'AL 46601AB SMALL SS US5 Ct ApPLlCAflCAS PEPTAIAIAC ?0 THIS JPSC.f-CATiCR. THESE BLOCKS ARC CM**CTEI2E0 BY THCJA OlPTY flPCWACCLCP * ?m(i*ES>$taaCE TO WATER aBSQRPTIOA. CPfAllCAS - ' lASVLATICA fcp tmacttle valve BCAAETS, 1ATPCEPCP VALVE SCPPtTS. AAO SPECUL VALVE BOAAE T % SMALL 9E UAOE IA SEC-ICAS AS SMOAA l*FiCU*t 2. wtlCMT * SECTIOAAOT TO EKCEEB APPPCKHKATELV40POUAOS ASSUME 2* PtLAOS PECVAC FOOT.) THE CKPAtOCB HtTAt JS^ItOAS SHALL 2 flTTEO TO SLXaET ;l) aTTAChiAC AACMOA PORTS. '2) SELECT)AC. FlTTIAC AAO ATTACHIAC BLOCKS. ill COvEBitC TU*kC ASSEMBLY FLARCCS. .41 COVEBItC VALVE SCAACTS. Si patohac. riLLitc aao fiwsmiac. . CCATOL-* A AO THEAEAf XiKar',.LI UP M TH WA'ECiAL AftiOlAt SLOCK, BBULTP--AETTltC AV\K^S*HC IASOLATIOA WA rCPlAL 4A110<L> TO OCS^g^CKAtSS-Li\S S/2-IACA. - r>t AS^CaTiOA SECTlCAS A8C IA PLACE. THCV SMALL 3t AfCE^TCCETHEA CtKsKHf UtATIALLV AJ.0 THE Tit M8CS SO L>M*EO TH\N|F rt TKt 1. 2 lOt FIAiSM CCAT IS APPLIES. THESE Ul ATTACHIAC AACHQR PORTS OS ALLOT STEEL CASTIACS CP FOICIMCS. AT POSlTIORS SCWA 0 /fJTpt*ES SVALLVwiCATE nc LOCATiOA CF The IMSULATIO* uctica (Uns, Jll^Aia FLOUTATI aSMAATUAC. 'CYLIAOEB 'AAO OTXE*> 1ASULATI0A PaO' tumilrts. 'ASULAT-it PA til PATO^B. TlLLIAC AJIQ mgSMIVC TO STVLE to. 27SA0B6M01 WILL SC WELOEO 't PLACE. Cautici- to fcathe* wELOAC OF aav aaCmQ* POiATS 9.*C to aaT'aCLSV STEEL CASTIACS 0* FOBQACS SMALL SE 90tE -'A'C EAC>aEE*taC APPPOAL. EVE BClT stubs. STYLE 270a0*IH01. SMALL SE WELOEO ?> PLASTIC IASULATIOA, MATXAUL *6110SJ. SHALL BE USEO FOA PAT CHiAO AAO FILLIK IAKECULAB APCAS AAO fop flAISMiAO, AS IA PAPT II. IMSULATTOt PAOS CtLT WHERE ItQU'BCO TO AtCMC* `tSULAVtjl USlACA ACLSOA .<5 EQUAL) STUO WLBlC CLA. S F'AtNi?' THE KPPTJCATICWOF PLASTIC IASULAT1CA 0JACAAS0* STEEL CYL1A0EKS, EYEBOLT STUDS Mt^fcMEUJCI OlSCCTLY TO THE CYLItOES USltC THE STUO WEUB>455L>7 (j CEAtPAL (2) SELECT1AC, HTTVAC AAp ATTACMiAC BLCCAs/^ FLAST1C IASULATIOA, UATEtlAL 46U0EJ. IS *ECtlVEBlA A OBV BLOCK SHAPES SHALL BE SELECTED < afc AwVfcy COPOITTCN AAO MUST FIRST BE MUCO WITH \*TEP BEFORE 3trt6 TPOHELEO IA PLACE. aCaAlv as possible to the Shape op ' eeiAccovEAEO. the wethooofcuttinc quaatitv acouiiCBCF EACH $)EE 0* i ACCESSATtv. ;A CCAEAal, THCLOAC OIT the TCttC svhc ; AMOLtCJf FITTIAO "pKS S-*LL 86 THE PLASTIC IASULATIOA SHALL SC APPUCO OA TOP CF THE WaeArTnEaPaPiEsSiAISPTLAAATCIcA.SULATIAO (K.OCK AFTER THE 20 CAUSE POULTRY PLACEO 0* to THE CUAVATOAC'OF THE EE9. WHCM OPtPATIOAS- FlTTiAC BLOCKS. SLIGHT 0lFFEtAC6fHrt> nOAAAO THE PA*T TO BE COVEACq ' tt the iasolH rsLiM cases. (1) TCXJNC. ' THE BLOC* WAV BE StCLACO avEM^PuVCAvC WATL. 4HJ0SJ. APPL1EQ OlAC&Kr^tt^HE ' kSt-C itSULAIIOA. Of the papt. cd affucatioa cr the first coat. 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