CA tn <N C\ CD CN CD Required: Lead Analyses

Lead & Zinc Res.Asn. 73 08-59 Lead-Zinc Producers (Executive Committee) 74 08-66 Mining Club (red) 08-73 New Mexico Mining Assn. 74 "" " "(blue) II It II II 75 08-85 Selenium-Tellurium Develop. 75 08-92 U.

Abex further objects to this request on the ground that the information it seeks otherwise lacks relevance to the issues arising in this case, and is not reasonably calculated to lead to the discovery of admissible evidence. -18-

Leaded Zinc 35y Thite Lead Metronite Zopaque Tltramarine 31ue LL Thiele: 29.2$ Alkali Refine4 Linseed Oil Cobalt Drier Oleum Spirits Special Oil Thite Heavy 3odied Linseed Oil Calculated Yield Manufacturing Loss Actual Yield Lb.

However, in view of the urine lead concentration of 0.84 mg.

.& Leaded Zinc Oxide Basic Carbonate Uhl to Lead Titanox Abestise TESICUli 35.35S Heavy Bodied Linseed Oil Refined Linseed Oil Drier 4 Thinner Calculated yield Manufacturing Loss Actual Yield 39 26a 151 219 . 56 m . 6 1.815 COST AHaLYS IS t 'Material Cost per Gallon or Pound Direct Labor Coat per Oalloa or Pound Factory Or.rh.ad por Oallan or Pound Bulk Cost per Gallon, or pound Carnplete Package Cost por Gallon or Pound Package .Labor Overhead Factory Cost in Package por Gallon nits : Gamra unit;cost TOTAL 006?

\ Reduction Recommendations for this Soft Paste White Lead NEW WORK--Soft Wood FIRST COAT SECOND COAT THIRD COAT White Lead 100 Pounds 100 Pounds 100 Pounds Pure Raw Linseed Oil 4 Gallons* Gallons* 3 Gallons* Pure Turpentine 1)4 Gallons 1% Gallons Drier .

-.S 111 previous eontrit-utlar.* tv.vc been brought up to dote and new corrosive* added which had not a-'pearod in the lorrooicn rorra,* The follod.n$ correctres are covered in the report, at least so far as lead is concerned!

SSSico, m,, n*I Tndo Hum: Citigory: Colon Quality: IXipont Pnpind Pilot #40 Outiidi Hhlt* Extort.or Hoo* Pilot Whtti 301-756 Pint Pimnt 63% TtPur# 351 Leaded Zinc Oxide Biilo Carbonate White Lead UbiiUu Bodirt*Linaeed Oil Refined lloind Oil Dri#r Ind Hiphtbmiti ICanganeie Haphthenate Uloeral Spirit!

(2) Indeterminate exposure to metallic lead and lead oxide dusts.

John Warren Work History Date 5/12747"- 2/14/49 2/14/49 2/17/50 2/17/50 3/6/50 3/6/50 - 4/6/50 4/6/50 - 5/5/52 5/5/52 - 1/3/53 1/3/53 - 1/9/53 1/9/53 - 5/3/53 5/3/53 - 6/1/53 6/1/53 - 11/12/53 11/12/53 - 2/1/54 2/1/54 - 6/6/54 6/6/54 - 7/12/54 7/12/54 - 9/7/54 9/7/54 - 9/14/59 9/14/59 - 4/2/62 4/2/62 - 7/19/72 7/19/72 - 7/16/73 7/16/73 - 7/1/74 7/1/74 - 3/14/77 3/14/77 - 3/21/77 3/21/77 - 7/19/82 Job Title Process Helper Process Helper Operator "BM " "A" '*** Process Helper w Operator "B" Operator "A" Lead Operator Process Helper Lead Operator Operator "A" Process Helper Operator "A" Control Operator Control Kettle Operator e w Control Operator Process Operator Yard Tank Farm Location Resinox PVC H It I* M 1* * H I* M e PVC Barrier Resin Yard Tank Farm PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 085414 1 ' *4*

Abex further objects to this request on the grounds that it is l compound, vague, ambiguous, overly broad as to time and scope, unduly burdensome, irrelevant to any issue in this action and not reasonably calculated to lead to the discovery of admissible evidence.

BPS House Paint Exterior House Paint White 218 First o I 89 CJt t Oo Mto \ + to M i Pigment: 65$ leaded Zinc (62$ lead) Titanium Oxide Asbestine Vehicle: 35$ Refined linseed Oil Raw linseed Oil Bodied linseed Oil Processed linseed Oil Mineral Spirits Brier Drier / Calculated Yield' Yield in Unit Total kb'___ Gallons Coat_______________ Cost 780 104 156 186 263.5 32. 24. 45.5 10.6 10.6 -,,^>45 7 15.4 sjifitO?

I stressed the importance of ordering Turbinol 1122 with as much lead time as possible, and Gene said he thought he would be able to give us as much as two weeks lead time.

The best material--PIONEER WHITE LEAD, pure linseed ofl, line and color-- are combined with long-jUtC skil^ in sci entifically exact proportion*. .....