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EPA Region 5 Lead Inspector Mr.
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refid# mBknopRQk3DrXnQMNMXwM50bZ24 pages
Kelly Davis (ERG, Lead Inspector) presented her Clean Water Act (CWA) inspector credential to the Facility representative, Mr.
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refid# ZBoNK6kdgYbQO5gnR6kZmwML8 pages
David Benecke Facility/Site Description Title Lead Inspector Physical Scientist Director of Concrete Operations Environmental Manager Present in Opening Conf.
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refid# 2Rx58q0BRopzGvBx0K14xEExR20 pages
EPA Region 5 Lead Inspector Anne Marie Vincent presented credentials to Gregory Sprehe, President of the Facility.
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refid# v137XNzqggaq2VBd374EKELy910 pages
In the north portion of the property, a tote receiving vehicle wash water from a drain in the vehicle wash area was located on top of riprap leading into a stormwater detention basin.
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refid# x18m76y95YDzo90v07w88OpG17 pages
Broad Street Suite 1010 Philadelphia PA 19102 & Mudd LLC COMES NOW Defendant PACCAR Inc PACCAR and serves its Objections and Responses to Plaintiffs Interrogatories and Requests for Production of Documents to PACCAR the Requests and states as follows The discovery responses that follow are based on the knowledge and information possessed by PACCAR's attorneys and their agents and staff unless otherwise privileged as well as knowledge and information known to PACCAR PACCAR may not have any knowledge or information concerning a particular Request Verification by PACCAR is not an indication that PACCAR has any knowledge personal or otherwise concerning any particular Response which has been provided Moreover the language and word usage in the answers to these Requests include that of PACCAR's attorneys As a result some or all of these answers may not be in the words or language which PACCAR itself might use PRELIMINARY STATEMENT These discovery responses are provided only for those products identified by Plaintiffs and to which Plaintiffs allege exposure These discovery responses are based on an ongoing review of PACCAR's documents and information obtained from ongoing discussions with various PACCAR personnel Much of the information requested dates back many years and is difficult or impossible to reconstruct or retrieve These discovery responses are made pursuant to a reasonable and diligent investigation and search for the information requested PACCAR reserves the right to amend these discovery responses if new or additional information becomes available to it PACCAR prepared these discovery responses with the assistance of counsel No single employee officer or agent of PACCAR has hand knowledge regarding each and every response The person signing these responses does so to satisfy whatever requirement may exist under the applicable rules regarding verification That person is informed and believes that the information known as of the date of his signature supports the discovery responses below DEFINITIONS AND INSTRUCTIONS Plaintiffs definitions and instructions are not repeated herein for the sake of brevity PACCAR objects to Plaintiffs definitions and instructions to the extent they are overbroad unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence PACCAR further objects to Plaintiffs definitions and instructions to the extent they include meanings and characterizations inconsistent with PACCAR's interpretation of the defined terms and phrases GENERAL OBJECTIONS a PACCAR objects to Plaintiffs Requests to the extent that they seek corporate knowledge as it is impossible for PACCAR to set forth the collective knowledge of all of its past or present employees PACCAR reserves the right to revise correct supplement and amend its discovery responses to provide information discovered subsequent to the responses contained herein PACCAR asserts the following objections and incorporates each by reference into each and every Response to Plaintiffs Requests set forth herein b PACCAR asserts the right to object on the grounds of competency privilege relevancy materiality or any other proper ground to the use of any said discovery response for any purpose in whole or in part in any subsequent step or proceeding in this litigation c PACCAR asserts the right to object on any other ground to other requests or other discovery procedures involving or relating to the subject matter of the Requests answered herein d PACCAR asserts the right to revise correct supplement or clarify any of its discovery responses set forth herein at any time and PACCAR reserves the right to object to the use of these discovery responses at trial or any other proceeding as deemed necessary and appropriate by PACCAR e PACCAR objects to the extent Plaintiffs seek documents no longer in PACCAR's possession PACCAR's document retention policy is 7 years save for documents that fall under specific categories As such PACCAR may no longer possess documents responsive to certain Requests f PACCAR objects to Plaintiffs Requests to the extent that they involve matters outside of the geographical area at issue in this litigation and limits its discovery responses to said area g Furthermore these Requests ask PACCAR to disclose information of which may no longer exist or may not be readily available is unrelated to the products at issue in this case Such information is also unrelated to the locations at which Plaintiffs may have used any PACCAR product the conditions under which Plaintiffs may have used any PACCAR product the time period during which Plaintiffs may have used any PACCAR product or the time period during which Plaintiffs allege exposure to any PACCAR product Thus Plaintiffs Requests seek information which is neither material nor relevant to the issues in this litigation are overbroad in time scope and location and are otherwise not reasonably calculated to lead to the discovery of admissible evidence h Plaintiffs Requests are oppressive burdensome and would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Moreover many of these Requests are not susceptible to a response because they request information which dates back many years and is now virtually impossible for PACCAR to reconstruct or retrieve in its entirety PACCAR objects to Plaintiffs Requests because they were propounded to harass and coerce a settlement despite the lack or complete absence of verifiable product identification and the lack of evidence of injury as a result of alleged exposure to or use of any product which PACCAR may or may not have manufactured q@) PACCAR objects to these Plaintiffs Requests because they are propounded for an additional improper purpose namely as a fishing expedition for the purposes of obtaining information that may be taken out of context by Plaintiffs counsel to create allegations against PACCAR where none may legitimately exist k PACCAR objects to Plaintiffs Requests as overbroad in that they seek information from entities other than itself or its predecessors PACCAR over the course of its long history has owned several businesses which are not involved in the instant litigation Therefore all references in Plaintiffs Requests to DEFENDANT YOU or YOUR and the like are assumed to refer only to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company 1 PACCAR objects to each and every Request that seeks production of any information constituting a trade secret confidential financial data or other confidential research development or commercial information m PACCAR objects to each and every Request that seeks production of any information constituting a trade secret confidential financial data or other confidential research development or commercial information n PACCAR objects to Plaintiffs Requests as argumentative because they assume that a health hazard is created by the PACCAR products that may have incorporated asbestos- containing component parts which PACCAR denies o PACCAR objects to Plaintiffs Requests on the basis that they are vague and ambiguous Requests relating to certain diseases fail to provide facts relating to the amount of exposure duration of exposure fiber type in exposure and latency period p PACCAR objects to Plaintiffs Requests in that they tend to group together all of Defendants in this litigation and are therefore overbroad unduly burdensome harassing and not calculated to lead to the discovery of relevant and material evidence q PACCAR objects to each and every Request that calls for either pure speculation or legal conclusions on the part of PACCAR r PACCAR objects to each and every Request that calls for a medical conclusion beyond the scope of PACCAR's knowledge and capability s PACCAR objects to each and every Request that purports to impose any obligations on it that are not set forth in the Pennsylvania Code of Civil Procedure or the Pennsylvania Supreme Court Rules t PACCAR objects to each and every Request that seeks information protected by the attorney privilege or attorney work product doctrine u PACCAR objects to each and every Request that seeks disclosure of information generated by persons other than PACCAR that has come into the possession of PACCAR's counsel during the course of discovery and trial preparation in asbestos litigation v PACCAR objects to each and every Request that seeks information for any time period unrelated to Plaintiffs alleged exposure w PACCAR objects to each and every Request that seeks information that is not under PACCAR's custody or control or which is within the public domain or otherwise equally available to Plaintiffs or their counsel Subject to and without waiving any of the foregoing objections PACCAR states as follows OBJECTIONS AND RESPONSES TO PLAINTIFFS INTERROGATORIES INTERROGATORY NO 1 With respect to the indiv
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refid# knG7yEJ44DgZenXBrpwyBGxq60 pages
Digital Image Log Inspection Report Sign-Off Lead Inspector's Name: Elizabeth Hubbard, ERG X Lead Inspector Supervisor's Name: Lance Avey, Acting Air Branch Chief, ECAD X Supervisor
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refid# 6bOx2Yz6GnQXxjR7ZzkXLpR914 pages
Spent lead films are also stored in this area in a 275-gallon non-hazardous waste tote.
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refid# Vj9xmwLzq0J0q9pnrYK6Kqjzg4 pages
Choate Ave Hennessey, OK 73742 Pope County 405-853-7170 Chase Holder (405-853-1540) Person Responsible for Operation cholder4@icloud.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A ARU002278; ADEQ State No-Discharge Permit 0825-WG-SW-3 (AFIN 5800780) N/A 213112 1389 Personnel participating in inspection: Kerri McCabe (lead) EPA / Region 6 ECDW Inspector / Enforcement Officer EPA Lead Inspector Signature/Date Supervisor Signature/Date KERRI MCCABE Kerri McCabe Digitally signed by KERRI MCCABE Date: 2025.02.19 08:55:00 -06'00' Date JEANNE ECKHART Date: 2025.02.25 09:54:15 -06'00' Digitally signed by JEANNE ECKHART Jeanne Eckhart Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Rheba SWD, LLC / Rheba 20-2 SWDS Tank Battery (ARU002278 / CWA) Inspection Date 01/16/2025 PURPOSE OF THE INSPECTION EPA Region 6 Inspector Kerri McCabe (lead) arrived at the Rheba SWD, LLC / Rheba 20-2 SWDS Tank Battery ("facility") at 1100 on 01/16/2025 for an announced inspection.
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refid# 4vjVwd8LMkj1R7bbRkaN83GXa5 pages
Digital Image Log Inspection Report Sign-Off Lead Inspector's Name: Elizabeth Hubbard, ERG X Lead Inspector Supervisor's Name: Lance Avey, Acting Air Branch Chief, ECAD X Supervisor
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refid# Ew4xVBaEzQYXodZ66Rq0LrMR4 pages
Together,weare leading Europe towards amorecircular future through the endlessly recyclable potential of metals. www eurometaux be Euromines, the European Association of Mining, Meta Ores & Industrial Mineral, represents large and small companies and subsidiaries in Europe and in other parts of the world which provide jobs. to more than 350,000 people.
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refid# 2Rqx863bRMmmr5KN2gMxO1KbL3 pages
Adequate lead time for searching alternatives and the need for review clause.
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refid# Ozan9p4mkxvo2m0EEqG9rOVYj15 pages
(Contractors): James Arambarri, Optimization Lead David Ellis, Principal Engineer Report Prepared by: Matthew Schulte, EPA Region 5 Inspector, (312) 886-2405, Schulte.matthew@epa.gov EPA Inspectors: Matthew Schulte, Lead Inspector, EPA Region 5 Megan Zale, Assistant Inspector, EPA Region 5 EPA Lead Inspector Signature: ________________________________________ Report Date: March 7, 2023 Approver Name & Title: Molly Smith, Supervisor, Section 1, Water Enforcement and Compliance Assurance Branch MOLLY Digitally signed by MOLLY SMITH Approver Signature: ___S_M__IT__H_______0_8:_59_:3_9 _-05_'0_0'_________________________ Date: 2023.05.10 Table of Contents INTRODUCTION .......................................................................................................................... 3 BACKGROUND ............................................................................................................................. 3 INVESTIGATION ACTIVITY SUMMARY ......................................................................... 3 List of Appendices Appendix A: Photo Log Emerald BioEnergy, U.S.
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refid# zb3MknJXvRLNxn83mq44Gj5Ja4 pages
The results of parastomal hernia repair are poor, leading to recurrencies, re-operations and complications in a number of patients (10).
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refid# KGeEXLyKb3xgv9Oeqmev4BV402 pages
This endangers competitiveness in these markets and leads to crowding out.
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refid# GD234E0xVZZjozKzN8oG645v5 pages