Document vQ741BmEm0GqpyZzOe8nLx9Z

the grounds that it is overly broad. Subject to its objections. Union Carbide responds as follows: Calidria is not an "asbestos-containing product." Calidria is a unique short-fiber chrysotile asbestos uncontaminated by tremolite which Union Carbide extracted from an asbestos ore body in the New Idria area of San Benito County in California. Calidria was marketed and sold by Union Carbide or by Calidria distributors to manufacturers or producers who incorporated and used Calidria in their products or production processes. From 1963 to 1985, Union Carbide sold Calidria asbestos fiber to various third party manufacturers or distributors. The asbestos third party manufacturers to whom Union Carbide sold Calidria used it in manufacturing various products used in commercial applications. Union Carbide did not manufacture those products and had no control over the nature of the products in which the fiber was used. Union Carbide produced four basic grades of Calidria asbestos: standard, super standard, high purity, and resin grade; the different grades reflect varying degrees ofpurity ofcontent. Certain grades were sold in pelletized form, certain grades in fibrous form, and certain grades in both forms. In appearance, Calidria is light gray (pelletized) or white (fibrous) in color and powdery in substance. The following is a representative listing and description of the various brands of Calidria produced and marketed by Union Carbide: PRODUCT SYMBOL HPO HPO-C HPP HPP-JAP RG-110 RG-110-D RG-144 A-14 RG-244 RG - 444-0 A-28 SG-100 SG-102 SG-130 SG-144 SG-200 SG-210 SG-444-0 T-135-0 T-135-P CG-100 CG-135-0 DOCSNYI:IOI20I8.1 PRODUCT CODE DESCRIPTION 651001 High Purity, Open Fiber 651101 High Purity, Open Fiber 651601 High Purity, Pellets 651701 High Purity, Pellets, 4-Ply bags 652101 Resin-Grade, Open Fiber 15% +325 652201 Resin-Grade, Open Fiber, 15% +325 652501 Resin-Grade, Open Fiber 652801 Resin-Grade, Open Fiber 653001 Resin-Grade, Open Fiber 653301 Resin-Grade, Open Fiber, 10% Stearic Acid 653601 Resin-Grade, Open Fiber, Silica Treated 654001 Standard Grade, Pellets 654201 Standard Grade, Pellets, 100-lb. bags 654501 Standard Grade, Open Fiber, 30% +325 654801 Standard Grade, Open Fiber, 45% +325 655001 Super Standard Grade, Pellets 655301 Super Standard Grade, Open Fiber, 15% +325 655501 Standard Grade, Open Fiber, 5% Stearic, Hydrophobic 656001 High Purity, Open Fiber, Titanated, 3 5%, Anatase 656301 High Purity, Pellets, Titanated, 35%, Anatase 656601 Coatings Grade, Pellets 656801 Coatings Grade, Open Fiber, Titanated 35%, Rutile 14