Gypsum objects to these Interrogatories to the extent they ask for "identification" of voluminous documents on the ground that they are overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Coolidge reported that this year's total expected requirements for white lead are 12,500 tons as compared with current production capacity of 9,500 tons.

Waste Minimization 4 Characterized and quantified reductions/elimination all wastes, evaluating 4 Examples: Cardboard box/paper bag recycle Eliminate lead bags by buying lead in supersacs API Separator oil - reuse in plasticizer Waste oil recycle 4 VAB.0001140383 VII.

Pure lead paint provides lasting beauty for vour home.

Gypsum objects to these Interrogatories to the extent they ask for "identification" of voluminous documents on the ground that they are overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

1.23 yr, Funds of are requested for the purchase of fifty (50) Air Pallets and ten (10) Taicon bags for shipping semi - bulk quanities of lead stabilizers

Signifi cantIjr, lead ahaathisg la readily adapted to eoonoadoal reclaiadng aad rawerting, being the only oabla oefonant acceptable to AUC aftar atrlpplng *ad reapplying.

Coolidge reported that this year's total expected requirements for white lead are 12,500 tons as compared with current production capacity of 9,500 tons.

This gave a time-weighted average concentration for lead of less than 0.004 ag/)P, This calculates to be less than 2% of the existing threshold ltait value for lead in workroom air.

PLAINTIFF'S EXHIBIT AL-I273 >5 Current Report Lead LONG-RANGE OPTIONS FOR CONTROLLING LEAD CAN BE CONSIDERED IN EVALUATING COMPLIANCE Citations for failure to meet the deadline for preparing compliance plans under the Occupational Safety and Health Administration's lead standard will not be issued to employ ers in the primary and secondary smelting and battery manufacturing industries if the employer has initiated a study of long-range control options and has met other re quirements, according to a draft field directive by OSHA.

MANUFACTURING DEPARTMENT PAGE 1 of 3 ENGINEERING INSTRUCTIONS NUMEEXCAL INDEX - ALL ISSUES : NUMBER ES-14 R-2I ES -32 R-34 R-100 R-I01 ES-102 SF-I04 SF-105 ES-204 ES-209 R-209 e S-a.it ES-219 ES-300 ES-301 R-301 R-302 ES-304 R-306 SF-307 ES-308 R-3I0 SF-3I0 ES-310 R-31I ES-312 R-401 R-402 R-407 R-408 R-500 - S TITLE Handling of WorEZfay Engineering Work Requisition (EWO) Administration^Snd Control of Rigging Distribution ofReports and Recommendations of Equipment Inspections Control of Heat_Exchanger Tube Bundle Replacements Steel Tank ShelTZ Design Code-for Welding;Instructions on Drawings Safe Oil Heights;and Hold-Off Distances Tanks and Reservoirs Safety Instruction Sheets Refinery Piping Washing Insulators on High Voltage Distribution System Radiography Program, Operating and Emergency Procedures Handling 500 MGJCobalt 60 Radiographic Capsule P.CAOT10OS MOtlS?

Sating 111 Exposed 1939 1 coat (Bed lead-line Illo4it| Phenolic ($).Unmd Oil) 1 cost (line Pert. *!

This waste could contain lead compounds.

Surface Dries First Any coat of paint dries first on the Hpridae. whether it containe boiled oil Lead Changes Into Sulphate "Lead is also subject to attack, but the lead sulphate is insoluble and If the paint contains red-lead the effect will be to change the pigment hi the1 very thin outer, layer, probably only one five-thousandth of an inch in growths- were positive-thb not;:so pro nounced from the1 -painted .area.

Defendant objects to plaintiffs' definitions of the terms "specified chemicals" and "these specified chemicals" on grounds that they are overly broad, burdensome, and 5 not reasonable calculated to lead to the discovery ofrelevant or admissible evidence.