Document nkjjaey7d7Njv5YRBozj3vxK1
WML M H M N BCTROtT, H ie M M N M i l l ( i l l ) M I - t M l
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Answer;
Yes*
(a) Defendant objects
because this Interrogatory is not answerable in its present form
since the amount of residual VCM in PVC is not a function of
moleculer weight.
18 = Question:
Do any of the "PVC products"
release detectable amounts of VCM at room temperature (approx.
75)?
a. If the answer is yes, please indicate which of the products.
Answer:
Defendant objects to said Interroga
tory because it is not answerable in its present form since any
answer would vary depending upon the length of time PVC products
have been in storage and the method employed to handle them.
Also, see answer to Interrogatory No. 17.
19. Question:
For each of the "PVC products"
please indicate the temperature at which detectable amounts of
VCM are released.
URL 08444
a. If they do, please indicate the amounts going back to at least 1965 and preparing an | illustration of any variation in later years.
Answer:
See answer to Interrogatory No. 18.
|
20. Question:
To produce the various "PVC
| products" have you also carried out the polymerization reaction
to produce the required PVC?
a. Have you ever purchased the PVC?
b. Please indicate dates when such purchasing started.
c. What percentage of total usage was purchased?
Answer:
Yes.
(a) No.
(b) Not applicable.
(c) Not applicable.
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