Perillo, Scraping Beneath the Surface: Finally Holding Lead-Based Paint Manufacturers Liable by Applying Public Nuisance and Market-Share Liability, 32 HOFSTRA L.

Was the property tested for the presence of lead?

National Lead had the benefit of industrial hygiene surveys by Metropolitan Life Insurance Company.

CO-EXPOSURE TO OTHER ENVIRONMENTAL CONTAMINENTS A second major concern raised by EPA, FIERA SAP peer reviewers, and public commenters is the ability of the CCCEH study authors to accurately measure and statistically model the relationship between other environmental chemicals (lead and PAH, specifically) or other pesticides (diazinon, propoxur) that may influence fetal brain development and childhood neurodevelopmental performance, and also be related to chlorpyrifos exposure (these are "potentially confounding" exposures).

FILE NAME: National Lead (NATL) DATE: 2019 DOC#: NATL061 DOCUMENT DESCRIPTION: BC Notes National Lead National Safety Council (NSC) was established in 1912 in Chicago by big business to share information on occupational safety and health.

http://bit.lv/2G0smrW Lead service line replacement is not a simple task.

As a part of EPA's ongoing effort to understand and assess lead exposure, the agency initiated a peer review of draft scientific modeling approaches to inform EPA's evaluation of potential health-based benchmarks for lead in drinking water.

EPA Office: 202.564.2615 From: Theresa Clift <tclift@tribweb.com<mailto:tclift@tribweb.com Date: August 9, 2017 at 6:10:21 PM EDT To: "Jones, Enesta" <Jones.Enesta@epa.gov<mailto:Jones.Enesta@epa.gov Subject: Request for call on lead samples hi Enesta, I have some technical questions about whether PWSA and the Borough of Braddock are complying with certain parts of the Lead and Copper Rule regarding which homes are tested for lead every six months.

EPA Office: 202.564.2615 From: Theresa Clift <tclift@tribweb.com<mailto:tclift@tribweb.com Date: August 9, 2017 at 6:10:21 PM EDT To: "Jones, Enesta" <Jones.Enesta@epa.gov<mailto:Jones.Enesta@epa.gov Subject: Request for call on lead samples hi Enesta, I have some technical questions about whether PWSA and the Borough of Braddock are complying with certain parts of the Lead and Copper Rule regarding which homes are tested for lead every six months.

This is because the facility would release more emissions of lead than the battery recycling facility that has caused the lead nonattainment problem.

Lead is especially bad for children.

With reference to the attached Exhibit 1 admit that Rogers is Source 4 referenced throughout the document but particularly described at the bottom of page 1223 and onto page 1224 Response to Request No. 1 See Preliminary Statement and General Objections Responding Defendant objects to this Request as burdensome vague ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant can neither admit nor deny this Request for Admission as it was not the author of the referenced publication 2 Admit that Rogers utilized chrysotile asbestos in its manufacturing process in its plant in Rogers CT Response to Request No. 2 See Preliminary Statement and General Objections Responding Defendant objects to this Request as vague overly broad burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Request because it is not sufficiently limited to a specific product location or time and thus seeks information that is wholly irrelevant to the present case and not reasonably calculated to lead to the discovery of admissible evidence By way of further answer and without waiver of the foregoing objections and subject thereto Responding Defendant states that some of its products manufactured at its Rogers CT facility utilized chrysotile asbestos as an ingredient 3 Admit that Rogers utilized crocidolite asbestos in its manufacturing process in its plant in Rogers CT Response to Request No. 3 See Preliminary Statement and General Objections Responding Defendant objects to this Request as vague overly broad burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Request because it is not sufficiently limited to a specific product location or time and thus seeks information that is wholly irrelevant to the present case and not reasonably calculated to lead to the discovery of admissible evidence By way of further answer and without waiver of the foregoing objections and subject thereto Responding Defendant states that some of its products manufactured at its Rogers CT facility utilized crocidolite asbestos as an ingredient 4 Admit that the Rogers plant in Rogers CT emitted chrysotile asbestos fibers into the ambient air outside the plant Response to Request No. 4 See Preliminary Statement and General Objections Responding Defendant objects to this Request as vague overly broad burdensome ambiguous and not reasonably calculated to lead ~ to the discovery of admissible evidence Responding Defendant further objects that this Request prematurely calls for expert testimony Responding Defendant can neither admit nor deny this Request 5 Admit that the Rogers plant in Rogers CT emitted crocidolite asbestos fibers into the ambient air outside the plant Response to Request No. 5 See Preliminary Statement and General Objections Responding Defendant objects to this Request as vague overly broad burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects that this Request prematurely calls for expert testimony Responding Defendant can neither admit nor deny this Request 6 Admit that the Rogers plant in Rogers CT utilized asbestos every year between 1950 and 1980 inclusive Response to Request No. 6 See Preliminary Statement and General Objections Responding Defendant objects to this Request as vague overly broad burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Request because it is not sufficiently limited to a specific product location or time and thus seeks information

PFHxS - update on preparations (Lead: NO) 11.

PWSA's treated water contains no detectable lead, but can pick up lead through corrosion in lead service lines -- the pipes that cany water from mains under the street into residences, and from lead soldered pipe joints and interior lead plumbing.

Region 5 is the lead region for water.