Document pBZj9Dw0m3B56x9814moQ7bO6

FILE NAME: Kaiser Gypsum (KG) DATE: 1985 KG041 DOC#: KG041 DOCUMENT DESCRIPTION: Legal - Answers to Interrogatories * a PATRICK J.' HAGAN, ESQ. CURTIS A,; CANFIELD, ESQ. KINCAID, GIANUNZIO, CAUDLE & HUBERT A Professional Law Corporation 200 Webster Street Oakland, CA 94607-3789 (415) 465-5212 - . RECEIVED JiAit * ' 001603 / pA-iSSL Attorneys for Defendants KAISER CEMENT. CORPORATION and KAISER GYPSUM COMPANY, INC. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA \ IN AND FOR THE COUNTY OF SOLANO 11 1 In Re: Related Asbestos Cases Consolidated For Discovery i: (McQuaid, Bedford & Brayton) / i: NO: 1327 ANSWERS TO INTERROGATORIES b PROPOUNDING PARTY: Blaintiffs it RESPONDING PARTY: 16 SET N O : 17 DATED. Defendants, KAISER CEMENT CORPORATION and KAISER GYPSUM COMPANY,INC. TEN COME NOW fendants KAISER CEMENT CORPORATION (heracr.aft_r 19 "KAISER CEMENT") and KAISER GYPSUM COMPANY, INC. (hereinafter 20 "KAISER GYPSUM") and in answer to the Tenth Set of 21 Interrogatories propounded by plaintiffs state as follows: 22 KINCAID, GIANUNZIO, CAUDLE & HUBERT 23 24 /, t / J J \ :. . 3y: v crrf- 25 CURTIS A. CANFIELD, ESQ. 26 27 28 MST OF IKOUK. _ <ONlAlhlNG AftllKSlU M anufactured \tj KAJSHt g jtf mgjKtOKAllOti*1 > FMHxrr/mDt mus HIHFUSE OF IKODUCT DFSCMPTlOh of muuuei GDWOS1T10N % ASBtslOS (Approx.) Miser Plastic U m Cement Miser Plastic cement (band) Miser tesnry Qeanenfe Used to make stucco for tfie exterior of houses and other buildings (applied by gun) Gray colored powder. Packaged and sold in sacks ot varying sizes and also in bulk. Used to nake stucco O for the exterior of houses and other buildings (applied manually with a trowel). Used in masonry mortar ft in building construc tion. Primarily powdered portland cement. The asbestos used in this product was chrysotile., 9 Primarily Portland cement. The asbestos used in this product was chrysotile. 2-5 <31 1-5 <3> 0.4 (31 y PAHS CONlAlhlHG ASBiSTOS 1960-74 PLAK1S hhHE HANUFACIUHfcD(2* REGION OP DISlRIBUTIOW* ' Permanente (Calif.) cuahtnbury (Calif.) Northern and Southern California 1961-73 Permanent (Calif.) Cushenbury (calif*) C1963-64 only) 1972-77 cushenbury (calif.) Arizona (primarily Hioenix)* 15) fysiseff Cement Corporation was known as Permanente Cement Cocrpagy fro 1939-64 and as Kaiser Cement i Gypsum Corporation from 1964-79. 52) The information in the "eats Containing Asbestos* column pertains to the company as a whole -- the individual plants listed in the 'Plants Met tenufactured* column did not necessarily manufacture each product during all ot the stated years. Similarly, the areas Indicated in the "Region of Distribution0 column aid not necessarily correspond to all of the stated years. 531 contractor typically mixed these products with three to five parts by weight of sand so the t asbestos was less than 1\ in the product actually ^pUS V83 *)ii i. fnooua/TWB um: tentage Paints: Reiser Coyer-tex wall texture MJMOSi; DESgO 4ION ObIRODUCTOF IDUiUCT p ' OJHlOiilTlOM Used to produce tex ture effects over gypsum wallboard surfaces. White to off-white powuer. Packaged and sold in sacks of 25 to 50 lbs. Primarily casein, lime stone ar/J mica. The asbestos used in this product was chrysotile. % AMU MUS ( Approx. ) 4-6% Kaiser K-Spray Ceiling texture. OiliTO Boards Kaiser Mineral Fibreboard Ut FiterRated (Under writers* Laboratories, Inc design) * * Millboard: Kaiser Gyps "NUl-A-Fire" Type X Millboard . V V-r* Used to produce tex White powder with ture over gypsum polystyrene aggre wallboard or interior gate. Packaged concrete ceilings. nna sold in sacks of 25 to 50 lbs. Used for acoustical ceiling tile and layin board and partition sound-deadening board. 1/2" or 5/6* thick by 12" or 24" wide by 12", 24* or 48" long sheets, with face side white or colored and with perforated or fissured design for acoustical treatment. Packaged and sold in boxes of various quantities* Primarily mineral wool and various wood fibers, clays and starch. Hie asbestos used in this product was chrysotile. 1.3-6.61 f 1.6% Used for interior walls and ceilings. 1/2* or 5/8* thick Prioiarily gypsum, plus by 4* wide 8* or additives of glass fiber, 12' long sheets, paper fiber and vermiculite. covered with gray The vermiculite contained or manila colored two lOOths of It tremolite paper. Two sheets (a type of asbestos) which were bound together was considered an inpurity for purposes of sale. and was totally encapsulated in the vermiculite. 0.02% X aic ; ix o t a in ii*; 1956-75 / ut PtARlS F ( 1 * v ni DtSY 11 * 0 1969-75 c tv '4 1965-74 St. Melons (Oregon) National, but largely in western states 1969-76 Antioch (Calif.) long beach (Calif.) Seattle ( Wash.) Rosario (Mew Mexico) Oelanco (Mew Jersey) Jacksonville (PI*.) Al western states, texas and east coast states. \ 111 lb information In the Teats containing Asbestos" column pertains to th carpany as a whole -- the individual plants listad in the `Plants toete Manufactured* colimm did not necessarily manufacture each product during all of the stated years. Similarly, the areaa indicated in the "Region of Diatribution* column did not necessarily correspond to all of the stated years. Pot exaaple, the Jacksonville and Calanco .plants were not built until 1961 ana 1965, respectively! thus, distribution of products on the east coast did not cessene* until some time after the plants were completed, i I 6/8 $ OMVak * v M & mA ffla&a Kaiser Joint Ouepowidmy S M c iaisef finirfdng ifbppingj Qxfpmmtl Itslast Otwrbsy Joinfe Mi@m htonpow Oospounti ejriose of fftosucr lV " UESOUPllUK of mcuucr r* t * i n i 1 1,1ST Of IIKA'tx l* HMW! KAI 1 cdhiositsow Used to 11 gypsun board joints, anted joint reinforcing tape, finish joints and to cover And finish nailbeads and metal cornerbead. White to off-white powder. Packaged and sold in sacks of 25 to SO lbs. Used to. top and finish gypsw board joints Used to fill gypsum board joints, embed joint reinforcing tape, finish joints and to cover and finish nailhead and metal cornerbead. Used to tape, top and finish gypsum board joints, nailheads and metal cornerbead Used to fill gypsun board joints, embed joint reinforcing tape, finish joints and to cover and finish nailheads and corner bead. White to off-white or light buff colored paste. Packaged and sold in buckets ranging from 12 to *2 lbs., and in cartons of 5 to 50 lbs. Used to top and finish gypsum board joints Primarily finely ground materials including casein/ clay, talcs, - limestone and mica. The asbestos used in this product was chrysotile. Weed to fill gypetes board joints, embed joint reinforcing * tape, finish joints and to cover and finish nailheads and metal cornerbead. White to off-whits or light buff colored paste. Packaged and sold, in buckets ranging from 12 to 62 lbs., and in cartons of 5 to 50 lbs. Primarily finely ground materials including casein, clay, talcs, limestone and mica, fhs asbestos used in this product was chrysotil. * Tainit. A.*. S ty i. HANV, INC. % JSBfcSTQS jjfe E fO X j y ears CONTAINING . ASBESTOS t U PANTS WHEHE HWUFACIHRg3 1* (IM'jO 1 REGION Of DISTRIBUTION ^ 6.6- 10*4% 1953-75 3.7- 116 1961-75 3.3-3.41 1968-75 Santa AM ( C a lif . I Antioch Icalif. Saatti oeldnco (New dtcsefl JadtiQAVlU (Fla* I e All western states including Hawaii and Alaska, New England, and all east ooast states. e 4 .M .H 1969-75 1.5-6% 1960-75 e e> 1*5-61 1960-75 Santa Ana (Calif*) Antioch (Calif* t/ a s s b m * Jacksonville (Fla*) All western states including Hawaii and Alaska* Hsw haglend* and all eaat ooast State