0:12
13 STEPHEN BRUST, JR.,
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15 and MARY ELIZABETH BRUST, DEPOSITIONS UNDER
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17 his wife; and JOHN COMPELL and ORAL EXAMINATION
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19 DALE COMPELL, his wife, OF
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21 JOHN COMPELL and
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23 Plaintiffs DALE COMPELL
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25 vs
1: 1
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4 STATE INSULATION, et al.,
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6
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8 Defendants
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10 ______________________________
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16 BRODY & GEISER
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18 CERTIFIED SHORTHAND REPORTERS
19
20 77 Hamilton Avenue
21
22 Fords, New Jersey 08863
23
24 (201) 738-8555
25
2: 1 JOB #905176
2 TRANSCRIPT of the depositions of the witnesses,
3
4 called for Oral Examination in the above-captioned
5
6 matter, said depositions being taken pursuant to
7
8 Superior Court Rules of Practice and Procedure by and
9
10 before MELINDA S. ROETHKE, a Notary Public and
11
12 Certified Shorthand Reporter of the State of New
13
14 Jersey, at the Offices of GARRUTO, GALEX & CANTOR,
15
16 ESQS., 14 Old Bridge Turnpike, East Brunswick, New
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18 Jersey, on Wednesday, May 17, 1989, commencing at
19
20 approximately 10 oclock in the forenoon.
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4: 1 A P P E A R A N C E S:
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5 GARRUTO, GALEX & CANTOR, ESQS.
6
7 BY: WILLIAM PAULUS, ESQ.
8
9 Attorneys for Plaintiffs
10
11
12
13 McCARTER & ENGLISH, ESQS.
14
15 BY: ROBERT J. BASIL, ESQ.
16
17 Attorneys for Defendants A.P. Green Refractories, The
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19 Celotex Corporation, GAF Corporation, Keene
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21 Corporation, Pittsburgh-Corning
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23
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25 HOAGLAND, LONGO, OROPOLLO & MORAN, ESQS.
5: 1
2 BY: MARC. S. GAFFREY, ESQ.
3
4 Attorneys for Defendant Janos
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6
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8 HARWOOD, LLOYD, ESQS.
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10 BY: JANE M. WIEDER, ESQ.
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12 Attorneys for Defendant Owens-Corning Fiberglas
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14
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16 SLIMM, DASH & GOLDBERG, ESQS.
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18 BY: KIMBERLY KITTERMAN, ESQ.
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20 Attorneys for Defendant United Engineers
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25 A P P E A R A N C E S C O N T D:
6: 1
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4 TOMPKINS, McGUIRE & WACHENFELD, ESQS.
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6 BY: JOSEPH K. COBUZIO, ESQ.
7
8 Attorneys for Defendant General Electric
9
10
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12 ENRIGHT, LENNEY & McGRATH, ESQS.
13
14 BY: MICHAEL MC GRATH, ESQ.
15
16 Attorenys for Defendants State Insulation
17
18
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20 WATERS, McPHERSON & McNEILL, ESQS.
21
22 BY: JAMES C. DOWDEN, ESQ.
23
24 Attorneys for Defendant Anchor Packing Co.
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7: 1
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3 ROBERT C. POLLOCK, JR., P.C.
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5 BY: JOHN S. FETTEN, ESQ.
6
7 Attorneys for Defendant J.H. France
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9
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11 SHANLEY & FISHER, ESQS.
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13 BY: MICHAELA OBRIEN, ESQ.
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15 Attorneys for Defendant Westinghouse Electric
16
17 Corporation
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22
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24 A P P E A R A N C E S C O N T D:
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8: 1
2
3 SELLAR, RICHARDSON, STUART & CHISHOLM, ESQS.
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5 BY: JOSEPH J. BOTTIGLIERI, ESQ.
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7 Attorneys for Defendant John Crane, Inc.
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23 I N D E X
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10: 1
2 WITNESS PAGE NO.
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4
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6 JOHN COMPELL
7
8
9
10 Direct by Mr. Basil 8
11
12 Cross by Mr. Fetten 147
13
14 Cross by Mr. McGrath 158
15
16 Cross by Ms. Wieder 174
17
18 Cross by Mr. Bottiglieri 176
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20 Cross by Ms. OBrien 193
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22 Cross by Mr. Cobuzio 195
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24 Cross by Mr. Dowden 199
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11: 1 Redirect by Mr. Basil 206
2
3
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5
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7 DALE COMPELL
8
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11 Direct by Mr. Basil 211
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20
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22 E X H I B I T S
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24
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12: 1 NUMBER DESCRIPTION PAGE NO.
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5 D-1 Answers to Interrogatories 8
6
7
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9 D-2 List of five questions 157
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11
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13 D-3 Supplemental Answers 157
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17 D-4 Professional Health Services 208
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21 J O H N C O M P E L L,
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23 21 Marsand Drive, Hazlet, New Jersey,
24
25 called as a witness, having first been
14: 1
2 duly sworn according to law, testifies on
3
4 his oath as follows:
5
6 DIRECT EXAMINATION BY MR. BASIL:
7
8 (Answers to Interrogatories are marked as
9
10 D-1 for Identification.)
11
12 Q Mr. Compell, is that the way its
13
14 pronounced?
15
16 A Yes.
17
18 Q Good morning.
19
20 A Good morning.
21
22 Q My name is Robert Basil. Im with
23
24 McCarter & English and we represent certain defendants
25
15: 1 in this matter. This is a deposition. Have you ever
2
3 been deposed before, sir?
4
5 A No, I havent.
6
7 Q Well, Ill go over the ground rules for
8
9 you so you know why were here. This is a deposition
10
11 and under certain circumstances what you say here can
12
13 and may be used in a court of law. Therefore, its
14
15 just as important that you give truthful and accurate
16
17 answers here as you would in a court of law. Do you
18
19 understand that, sir?
20 A I do.
21
22 Q During the course of this deposition Ill
23
24 be asking you a lot of questions. If at any time you
25
16: 1 dont hear one of the questions or you dont understand
2
3 what Im saying which is probably more likely, just
4
5 stop me and I will repeat the question or explain it so
6
7 we make sure that we understand; all right?
8
9 A Right.
10
11 Q I dont want you to guess at any of the
12
13 answers. If you dont know the answer to one of my
14
15 questions just say I dont know or I dont recall,
16
17 those are perfectly good answers if theyre true; all
18
19 right, sir?
20
21 A Right.
22
23 Q And I want you to remember to give all
24
25 your answers orally. The court reporter is taking down
17: 1
2 every word we say and she cant effectively take down
3
4 nods of the head or gestures, so try to keep that in
5
6 mind as we have this conversation today, sir.
7
8 A I understand.
9
10 Q When I say I dont want you to guess, if
11
12 you can give an approximation, for instance, I worked
13
14 there in about 1975 or a particular item was about a
15
16 foot and a half long, those are fine. Just let us
17
18 know youre approximating; all right, sir?
19 A Okay.
20
21 Q Also during the course of this deposition
22
23 as I ask questions, many times youll know the end of
24
25 my questions before I ever get to it. Im going to ask
18: 1
2 you to refrain from answering until I finish my
3
4 question. The reason for that is the court reporter,
5
6 again, is trying to take down every word we say and if
7
8 we interrupt each other, she has a very hard time; all
9
10 right, sir?
11
12 A Okay.
13
14 Q During the course of this deposition one
15
16 of the attorneys in the room may object. Please pause,
17
18 allow them to state their objection, and when theyre
19
20 done you can proceed to answer unless your attorney
21
22 specifically instructs you not to answer; all right,
23
24 sir?
25
19: 1 A All right.
2
3 Q I dont know how long were going to be
4
5 here today, but if at any time during this deposition
6
7 you need a break or want a break or want to take five
8
9 or ten minutes, you tell us and we certainly will; all
10
11 right, sir?
12
13 A Fine.
14
15 Q Im going to ask you to look over what
16
17 purports to be your Answers to Interrogatories. These
18 are questions that my law firm sent to you and these
19
20 are your Answers. Its marked D-1 for Identification.
21
22 I want you to look through those briefly and tell me if
23
24 those are the Answers you provided.
25
20: 1 A I have to read this in total?
2
3 MR. PAULUS: Just look it over and see if
4
5 it generally is what you remember. You can skip
6
7 over that part.
8
9 A Yeah, these look like the papers that I signed.
10
11 Q Okay. Fine. While you have it, sir, I
12
13 direct your attention to the final short page. Is that
14
15 a copy of your signature, sir?
16
17 A That is a copy of my signature.
18
19 Q When you signed that page did you
20
21 understand you were stating that the Answers to these
22
23 Interrogatories were true to the best of your
24
25 knowledge?
21: 1
2 A Yes, I did.
3
4 Q Okay. Fine. Let me ask you, sir, are you
5
6 currently taking any medications?
7
8 A Yes, I am.
9
10 Q And have you taken any today?
11
12 A Yes, I have.
13
14 Q And would you tell me what those are?
15
16 A Ive taken a blood pressure pill.
17 Q Do you know the name of the drug?
18
19 A Yes, its Kayline SR 240.
20
21 Q And who prescribed that for you?
22
23 MS. COMPELL: Dr. Senz.
24
25 A Dr. Senz.
22: 1
2 MR. PAULUS: Ms. Compell, your husband is
3
4 being deposed right now. Hes going to have to
5
6 do his best without your help.
7
8 Q All right, fine. So that is Dr. Senz?
9
10 A Thats correct.
11
12 Q And how many of these pills do you take a
13
14 day?
15
16 A One a day.
17
18 Q Have you taken any other medication today?
19
20 A Its just another pill called Losal.
21
22 Q And do you know the purpose of that?
23
24 A Its to eliminate water out of my system.
25
23: 1 Q Is that also prescribed by Dr. Senz?
2
3 A Thats correct.
4
5 Q Are there any other medications you take
6
7 regularly?
8
9 A Just a vitamin pill.
10
11 Q Is there any reason to believe that these
12
13 medications will affect your ability to testify today?
14
15 A No, there shouldnt be any reason.
16 Q Okay. Fine. Let me ask you, Mr. Compell,
17
18 in preparation for todays deposition of you had a
19
20 chance to review any documents of any sort?
21
22 A Yes, I reviewed the doctors report.
23
24 Q The doctors report. Would that be this
25
24: 1 report of Dr. Valez?
2
3 A Thats correct.
4
5 Q Anything else?
6
7 A No, nothing else.
8
9 Q Have you ever reviewed a picture book of
10
11 asbestos products?
12
13 A A picture book of asbestos products?
14
15 Q It would be a book that would
16
17 illustrate –
18
19 A No, no.
20
21 Q Have you ever reviewed a product list, and
22
23 that would be a list of difference asbestos products?
24
25 A No.
25: 1
2 Q Okay, fine. I realize you stated this
3
4 already for the court reporter. Would you give your
5
6 full name and address?
7
8 A John Compell, 21 Marsand Drive, Hazlet, New
9
10 Jersey.
11
12 Q And your date of birth, sir?
13
14 A 1/20/33.
15 Q And could I have your Social Security
16
17 number?
18
19 A 147-24-2856.
20
21 Q And can you give me the benefit of your
22
23 educational background?
24
25 A High school education and Air Force technical
26: 1
2 school.
3
4 Q And what high school was that?
5
6 A Perth Amboy High School, Perth Amboy, New
7
8 Jersey.
9
10 Q And year did you graduate?
11
12 A 1951.
13
14 Q And you stated you went to some Air Force
15
16 technical school?
17
18 A Thats correct.
19
20 Q And what kind of training did you receive
21
22 there?
23
24 A Electronics training and weather observing.
25
27: 1 Q Did you receive any degrees or
2
3 certificates from this training?
4
5 A Yes, I did.
6
7 Q And what kind of degrees or certificates
8
9 were they?
10
11 A A degree in weather observing.
12
13 Q And how –
14 A Basic weather observing.
15
16 Q And how about the electronics, did you
17
18 receive anything for that?
19
20 A No, no degree on that.
21
22 Q I hesitate to ask this next question
23
24 because I have some knowledge of your subsequent
25
28: 1 training, but did you take any other courses or
2
3 training since you left the Air Force?
4
5 A No, only what the company supplied us with.
6
7 Q And what sort of courses did you take with
8
9 the company?
10
11 A Fundamentals of instrumentation, jet engine
12
13 controls, and various courses given by instrument
14
15 companies like Bently, Nevada; Bailey L & N.
16
17 Q What sort of instruments are these that
18
19 youre talking about?
20
21 A Oh, were talking about combustion control
22
23 instruments, level instrumentation.
24
25 Q And these courses we were mentioning after
29: 1
2 the Air Force, they were all courses that you were sent
3
4 to by your company?
5
6 A I was sent to some of them and some of them they
7
8 brought in instructors.
9
10 Q Okay. And what company is that?
11
12 A L & N, I went to a course in Pennsylvania.
13 Q I mean, what company is paying for these?
14
15 A What company?
16
17 Q Yes.
18
19 A Public Service Electric & Gas.
20
21 Q All right. And I see youre married; is
22
23 that correct, sir?
24
25 A Thats correct.
30: 1
2 Q Could you give me your wifes full maiden
3
4 name?
5
6 A Dale Schriber, Dale Lee Schriber.
7
8 Q Do you know her date of birth?
9
10 A Yes. 2/24/37.
11
12 Q And one more tough one, do you know your
13
14 date of marriage?
15
16 A Yes. September 20, 1959.
17
18 Q Thats pretty good. And where were you
19
20 married, sir?
21
22 A I was married in Keyport, New Jersey.
23
24 Q Was this the first marriage for both of
25
31: 1 you?
2
3 A Yes.
4
5 Q And were there children to the marriage?
6
7 A Three children.
8
9 Q And lets start with the oldest, his name?
10
11 A Kenneth George.
12 Q And how old is Kenneth?
13
14 A Hell be 26 in July.
15
16 Q No help allowed. Is Kenneth married?
17
18 A No.
19
20 Q Is he employed?
21
22 A Yes.
23
24 Q And who is he employed with?
25
32: 1 A Cadcon Corporation.
2
3 Q Is Kenneth living at home?
4
5 A No, hes living in Rockville, Maryland.
6
7 Q Is Kenneth in any way financially
8
9 dependent on you?
10
11 A No.
12
13 Q And your second oldest?
14
15 A Jeffrey John.
16
17 Q And his age?
18
19 A Hell be 25 in September.
20
21 Q And is Jeffrey John married?
22
23 A No.
24
25 Q Is he employed?
33: 1
2 A He is employed.
3
4 Q And with whom?
5
6 A Its one of those letter names.
7
8 Q Well, do you know what he does?
9
10 A Yes, hes a computer analyst.
11 Q Okay. Is Jeffrey John living at home?
12
13 A Yes.
14
15 Q Is he in any way financially dependent on
16
17 you?
18
19 A No.
20
21 Q Does he pay rent?
22
23 A No.
24
25 Q And your youngest?
34: 1
2 A Christopher George — Christopher Joseph rather.
3
4 Q And Christophers age?
5
6 A Hell be 20 in July.
7
8 Q And is Christopher married?
9
10 A No.
11
12 Q Does he live at home?
13
14 A Hes attending college but he does live at home.
15
16 Q Where is he attending college?
17
18 A East Stroudsberg University.
19
20 Q And is Christopher dependent on you for
21
22 financial support?
23
24 A Yes, he is.
25
35: 1 Q Are you paying his tuition?
2
3 A Yes.
4
5 Q Is anyone else dependent on your financial
6
7 support besides your sons?
8
9 A No.
10 Q Are you aware of any health problems that
11
12 any of your sons have at this time?
13
14 A No.
15
16 Q Have any of them ever suffered from any
17
18 respiratory problems; to your knowledge?
19
20 A Yes, asthma.
21
22 Q Which ones?
23
24 A Jeffrey.
25
36: 1 Q And was he treated by a doctor for that
2
3 problem?
4
5 A Yes, he was.
6
7 Q And who would that be?
8
9 A Dr. Kaloss.
10
11 Q And does he still suffer from asthma at
12
13 this time?
14
15 A Hell suffer occasionally — not really suffer,
16
17 but hes bothered by mainly cats. If he comes in
18
19 contact with a cat he has a tendency to exude water and
20
21 his breathing becomes tight.
22
23 Q Have either of your other sons suffered
24
25 from allergies or asthma?
37: 1
2 A They were bothered when they were young.
3
4 Christopher had one occasion where he was bothered by
5
6 asthma but he hasnt been bothered since.
7
8 Q Was he treated by a physician for that
9 problem?
10
11 A Yes, he saw a doctor.
12
13 Q Do you remember which?
14
15 A Dr. Senz.
16
17 Q And was Kenneth — did Kenneth ever have
18
19 asthma problems?
20
21 A No.
22
23 Q Let me ask you, Mr. Compell, is your
24
25 father still alive?
38: 1
2 A No.
3
4 Q When did he pass away?
5
6 A He passed away in 1969.
7
8 Q And do you know his age at death?
9
10 A 73.
11
12 Q Are you aware of his cause of death?
13
14 A Heart failure due to emphysema.
15
16 Q Was your father a smoker?
17
18 A Yes.
19
20 Q Cigarettes?
21
22 A Cigarettes.
23
24 Q Did he smoke while you were living with
25
39: 1 him?
2
3 A Yes.
4
5 Q Do you know if your father ever worked
6
7 with any asbestos or asbestos-containing products?
8 A He worked for Celotex Corporation in Metuchen,
9
10 at that time they were in Metuchen.
11
12 Q Do you know whether worked with asbestos
13
14 products at Celotex?
15
16 A Yes, he did.
17
18 Q What was his job?
19
20 A He was mainly a laborer. The only part he
21
22 related to me was he used to stack insulation as it
23
24 came down the conveyor belt.
25
40: 1 Q Do you know if your father was ever told
2
3 that any of his health problems were related to
4
5 asbestos exposure?
6
7 A No, he wasnt.
8
9 Q Is your mother still alive?
10
11 A No.
12
13 Q When did she pass away?
14
15 A 1956.
16
17 Q And do you know her age at that time?
18
19 A She was fifty — I think I wrote on my report
20
21 that she was 56 but I believe she was 57.
22
23 Q Okay. And are you aware of her cause of
24
25 death?
41: 1
2 A Heart attack.
3
4 Q And did your mother smoke?
5
6 A No.
7 Q Did you have any brothers and sisters?
8
9 A Yes. One brother and three sisters.
10
11 Q Are you aware of any health problems that
12
13 your brothers or sisters suffer from?
14
15 A My brother has an asthma problem.
16
17 Q And his name?
18
19 A George.
20
21 Q And how about your sisters?
22
23 A My sister Rose has a kidney problem and my
24
25 sister Mary had some kind of stomach disorder. I dont
42: 1
2 remember exactly what it was.
3
4 Q Is there any cancer in your immediate
5
6 family?
7
8 A No.
9
10 Q Did any of your brother or sisters smoke
11
12 when you were living with them?
13
14 A No, no. My brother had smoked at one time but
15
16 those cigarettes were — whatever they had to smoke for
17
18 the asthma treatment. It sort of looked like a
19
20 cigarette.
21
22 Q And it was smoked?
23
24 A Yes, I guess it was.
25
43: 1 Q I notice in your Answers to
2
3 Interrogatories youve listed three residences, is that
4
5 all the residences that youve lived at in your
6 lifetime?
7
8 A Thats correct.
9
10 Q Well start with the Hartford Street in
11
12 Perth Amboy, I guess 533 Hartford?
13
14 A Right.
15
16 Q And I suppose you only lived there when
17
18 you were a small boy; is that correct?
19
20 A Thats correct.
21
22 Q After you moved from 533 Hartford Street
23
24 you moved to 527 Hartford Street; is that correct?
25
44: 1 A Thats correct.
2
3 Q And how long did you live there?
4
5 A At 527 Hartford Street?
6
7 Q Yes?
8
9 A I lived there until 1959.
10
11 Q Do you remember how the home was heated,
12
13 the fuel?
14
15 A Yeah, the only fuel we had was a coal stove.
16
17 Q Did you have any duties with the coal,
18
19 shoveling the coal or –
20
21 A No, no.
22
23 Q And who did that?
24
25 A My father.
45: 1
2 Q And in 1959 you moved into your present
3
4 home; is that correct?
5 A Thats correct.
6
7 Q And that doesnt have coal heat; does it?
8
9 A No, gas.
10
11 Q Did it ever have coal?
12
13 A No.
14
15 Q During the course of the time you lived in
16
17 any of these homes were there any significant
18
19 renovations done?
20
21 A No.
22
23 Q In your present home have you had occasion
24
25 to have any of the walls ripped out?
46: 1
2 A Yes, weve had walls ripped out, we put an
3
4 addition on.
5
6 Q Was that work that you did or you hired
7
8 somebody?
9
10 A No, it was contracted out.
11
12 Q Do you know what sort of insulation you
13
14 have in that home?
15
16 A Its just a normal insulation they put between
17
18 the walls.
19
20 Q Do you know if any of these homes had any
21
22 asbestos or asbestos insulation in them?
23
24 A Not to my knowledge.
25
47: 1 Q Okay. You were in the armed forces; is
2
3 that correct?
4 A Thats correct.
5
6 Q What branch is that?
7
8 A United States Air Force.
9
10 Q And what dates were you in the Air Force?
11
12 A From February 20, 1951 to February 19, 1956.
13
14 Q And what was your rank when you left the
15
16 service?
17
18 A Airman first class.
19
20 Q Where did you do your basic?
21
22 A Sampson Air Force Base, New York.
23
24 Q Were you ever injured in basic?
25
48: 1 A No.
2
3 Q Did you ever come in contact with
4
5 asbestos, to your knowledge, in basic?
6
7 A To my knowledge, no.
8
9 Q Did you ever get any training in chemical
10
11 warfare?
12
13 A We had to wear a gas mask during one phase of
14
15 the training.
16
17 Q And would you explain to me how that
18
19 worked, what happened in that phase of the training?
20
21 A They exposed us to some irritant type goods and
22
23 how it would feel with and without the gas mask.
24
25 Q So how long were you exposed to this
49: 1
2 irritant gas?
3 A Ten seconds.
4
5 Q And after that you put the mask on?
6
7 A Yes.
8
9 Q After you left Sampson Air Force Base,
10
11 where did you go next?
12
13 A Kessler Air Force Base, Mississippi.
14
15 Q What were your duties there?
16
17 A Thats when I went through electronic school.
18
19 Q How long were you at Kessler?
20
21 A For about 9 months.
22
23 Q Ever injured at Kessler?
24
25 A No.
50: 1
2 Q And after Kessler?
3
4 A Shanute Air Force Base, Illinois.
5
6 Q And what did you do there?
7
8 A A weather observer course.
9
10 Q And after Shanute?
11
12 A Korea.
13
14 Q And what were your duties in Korea?
15
16 A Weather observer.
17
18 Q And after Korea?
19
20 A After Korea I was in Greenville Air Force Base,
21
22 South Carolina.
23
24 Q And your duties there?
25
51: 1 A Weather observer.
2 Q And after Greenville?
3
4 A Discharged.
5
6 Q Do you have any knowledge of being exposed
7
8 to asbestos or asbestos products in the service?
9
10 A No.
11
12 Q Were you ever required as part of your
13
14 regular duties to work with any chemicals of any sort?
15
16 A No.
17
18 Q And what sort of discharge did you
19
20 receive?
21
22 A Honorable.
23
24 Q During the course of your life have you
25
52: 1 ever consumed tobacco products?
2
3 A I smoked a pipe and cigarettes.
4
5 Q Lets start with the pipe, when did you
6
7 smoke a pipe?
8
9 A Around 1961, somewhere around there.
10
11 Q And how long did you smoke a pipe?
12
13 A About two years.
14
15 Q And how about cigarettes?
16
17 A Cigarettes, very few, occasionally, mostly a
18
19 pipe.
20
21 Q What years are we talking about?
22
23 A The same years, in between.
24
25 Q In the early 60s?
53: 1 A Yes.
2
3 Q And lets take the heaviest time during
4
5 that period, what was the most that you would be
6
7 smoking a day?
8
9 A Just a couple of pipefuls and maybe a cigarette
10
11 or two a day, thats it. And that was only at work.
12
13 Q And how long did that period last, how
14
15 long are we talking about that youre smoking pipe and
16
17 cigarettes?
18
19 A Two years.
20
21 Q Since that time you havent smoked any?
22
23 A Thats correct.
24
25 Q And how about alcohol products, do you
54: 1
2 consume any beer, wine or alcohol?
3
4 A Occasionally a beer, occasionally a mixed drink.
5
6 Very seldom.
7
8 Q When you were younger did you used to
9
10 drink more than you do now?
11
12 A Yes, yes.
13
14 Q And what kind of alcohol would you drink
15
16 when you were younger?
17
18 A It would be beer, liquor.
19
20 Q And about what age did you acquire your
21
22 current drinking habits of just the occasional beer or
23
24 mixed drink?
25 A Id say within the past 10 years.
55: 1
2 Q Let me ask you, in your current leisure
3
4 time do you have any activities you would classify as a
5
6 hobby?
7
8 A That I would classify as a hobby? Mostly
9
10 reading, some gardening, fishing, boating.
11
12 Q Lets start with the gardening, what sort
13
14 of gardening do you do?
15
16 A Just planting bulbs, trimming.
17
18 Q And this is all on your property, right?
19
20 A Thats correct.
21
22 Q Was there ever a time when you used to do
23
24 more gardening than you do now?
25
56: 1 A Yes. I used to handle the grass but I dont do
2
3 that too often, my son does that.
4
5 Q And is there any particular reason you
6
7 dont do the grass anymore?
8
9 A Yes, for one Im allergic to it and two I have
10
11 shortness of breath that doesnt allow me to do it to a
12
13 great extent.
14
15 Q When you say youre allergic to it, what
16
17 sort of reaction do you have to the grass?
18
19 A It could trigger off my asthma.
20
21 Q Do you remember any incidents where the
22
23 cut grass had triggered your asthma?
24 A No, mostly it just irritates my nasal passage.
25
57: 1 Q And how about fishing, how often do you
2
3 get to go fishing?
4
5 A Just a few times during the summer. Id say two
6
7 or three times.
8
9 Q Are we talking about going out on a boat
10
11 fishing or by a stream?
12
13 A Both party boat or off surf on my own little
14
15 boat.
16
17 Q So I take it this is salt water?
18
19 A Yes, mainly salt water.
20
21 Q And was there ever a time when you used to
22
23 do more fishing?
24
25 A Yes, I used to do quite a bit of fishing on
58: 1
2 mostly — mostly every weekend. At least once a week
3
4 during the summer.
5
6 Q And when did you cut back to a few times
7
8 during the summer?
9
10 A Its been within the past few years.
11
12 Q And is there a reason for that?
13
14 A I dont have the stamina to go through what I
15
16 used to do.
17
18 Q And what sort of activity that you used to
19
20 go through that takes stamina?
21
22 A Lugging the boat around. Its a hard top boat.
23 The motor. Occasionally rowing, I cant do that
24
25 anymore.
59: 1
2 Q What size boat are we talking about?
3
4 A 12 footer, mine is a 12 footer.
5
6 Q And how about the party boat trips, did
7
8 you used to go out more often on the party boats?
9
10 A Yes, I havent been out on them, not — I would
11
12 make maybe one trip, two trips a year at the most.
13
14 Q Is there any reason you dont go out on
15
16 the party boats anymore?
17
18 A I just dont have the initiative anymore. I
19
20 dont have the desire.
21
22 Q Do you still enjoy fishing as much as you
23
24 did?
25
60: 1 A Yes, I still enjoy fishing. Its become almost
2
3 like a burden instead of an enjoyment.
4
5 Q How about the boating, is the boating
6
7 always related to the fishing?
8
9 A Yes, mainly unless it was to test the motor and
10
11 go for a cruise.
12
13 Q Lets take a period 10 years ago, did you
14
15 have the boat 10 years ago?
16
17 A Yes.
18
19 Q The same boat, the 12 footer?
20
21 A Same boat, yes.
22 Q How often would you get out 10 years ago?
23
24 A Mainly during the summer at least once every two
25
61: 1 weeks, sometimes once every week.
2
3 Q And how often did you get out last summer?
4
5 A Last summer I was out once.
6
7 Q Are there any other activities that you
8
9 can think of that you used to do more often that you
10
11 dont do so much anymore?
12
13 A I used to bowl.
14
15 Q Were you in a league?
16
17 A No, recreation. Well, way back I used to be in
18
19 a league, but then I had to switch it to recreational
20
21 type going out once in a while.
22
23 Q Who did you bowl with?
24
25 A Who?
62: 1
2 Q Yes?
3
4 A We had our own teams. I bowled with the Public
5
6 Service league, the plant league, and I also bowled on
7
8 another team on the outside.
9
10 Q And do you currently bowl at all?
11
12 A No, I havent bowled.
13
14 Q For how long?
15
16 A Id say maybe once in the past eight years.
17
18 Q And is there any particular reason eight
19
20 years ago you gave up bowling?
21 A No.
22
23 Q You just didnt care to do it anymore?
24
25 A That and time.
63: 1
2 Q Okay. Any other activities you can think
3
4 of that you used to do more frequently than you do now?
5
6 A Well, I used to play softball, but thats going
7
8 way back.
9
10 Q How about clubs or civic organizations, do
11
12 you belong to any?
13
14 A Not presently.
15
16 Q Did you at one time?
17
18 A Yes. I belonged to the Cub Scouts and the Boy
19
20 Scouts.
21
22 Q And thats when your sons were in
23
24 scouting?
25
64: 1 A Thats correct.
2
3 Q And after your sons got out of the scouts
4
5 did you stay on?
6
7 A Well, no, I didnt, I didnt stay on.
8
9 Q Did you do anything with the scouts after
10
11 your sons got out?
12
13 A No.
14
15 Q Any other organizations?
16
17 A No.
18
19 Q What is the first job you can remember
20 holding?
21
22 A The first remember, I remember holding? I was a
23
24 stock boy for the Acme food chain.
25
65: 1 Q And when was that?
2
3 A That was during my last two years of high
4
5 school.
6
7 Q And after that job what was your next job?
8
9 A The next job I was a jitney driver for General
10
11 Cable Corporation.
12
13 Q And do you remember what years that was?
14
15 A That was in 1951 for a period of about a month
16
17 or two months.
18
19 Q And after the jitney job?
20
21 A I left the jitney job because PSE&G hired me.
22
23 Q So you began PSE&G in 1951?
24
25 A Thats correct, September 21, 1951.
66: 1
2 Q Have you worked with Public Service
3
4 continually since that time?
5
6 A Except for the period in the Air Force.
7
8 Q And you still work for them today; is that
9
10 correct?
11
12 A Thats correct.
13
14 Q When you first were employed by Public
15
16 Service what was your position?
17
18 A My title was equipment operator.
19 Q And how long were you equipment operator?
20
21 A I was equipment operator up until the time in
22
23 February when I went into the service. That was
24
25 February the following year.
67: 1
2 Q And what location were you equipment
3
4 operator?
5
6 A Sewaren Generating Station.
7
8 Q So for this approximate six or seven month
9
10 period were you confined at the Sewaren Generating
11
12 Plant?
13
14 A Yes.
15
16 Q And were you always entitled an equipment
17
18 operator during those months?
19
20 A My job was entitled equipment operator, but we
21
22 would help the performers department — the maintenance
23
24 department on the unit outage.
25
68: 1 Q Let me ask you and well confine ourselves
2
3 to this six or seven month period, did you personally
4
5 work with any asbestos or asbestos-containing products
6
7 during this six-month period in 1951?
8
9 A Yes, I did.
10
11 Q Can you tell me what types of asbestos
12
13 products you worked with during that period?
14
15 A The types that I worked with with, mainly
16
17 insulation inside the boilers. Brand names?
18 Q Anything else besides the insulation
19
20 inside the boilers during that period?
21
22 A Insulation on the pipes, insulation on valves.
23
24 Q Can you think of any other asbestos
25
69: 1 products you worked with directly during that time
2
3 period?
4
5 A Not during that time period.
6
7 Q Okay. Lets talk about the insulation
8
9 inside the boilers. What were your duties with respect
10
11 to that insulation?
12
13 A We had to go into the boilers starting at the
14
15 top up in the super heater, and break down the old
16
17 firebrick and insulation so that the boilers could be
18
19 reinsulated.
20
21 Q And how did you breakdown the firebrick?
22
23 A We went in there with jackhammers, sledge
24
25 hammers, chisels.
70: 1
2 Q I take it this is inside an enclosed
3
4 boiler?
5
6 A Thats correct.
7
8 Q Was there any opening when you were
9
10 working in there?
11
12 A There were just boiler doors, access doors to
13
14 that particular section.
15
16 Q And those doors were open?
17 A Those doors were open, yes.
18
19 Q Can you describe what one of these
20
21 firebricks looks like?
22
23 A It was like sort of two different colors. One
24
25 was like a yellowish looking, some of them were like a
71: 1
2 reddish looking with shiny particles on them.
3
4 Q In both the yellowish and red, both had
5
6 the shiny particles?
7
8 A Thats correct.
9
10 Q Now, when you were breaking up these
11
12 firebricks, did you wear any protection over your face
13
14 of any sort?
15
16 A The only protection they offered us was a dust
17
18 mask which covered your nose and your mouth.
19
20 Q You say that was offered, was the offer
21
22 taken?
23
24 A It was taken on occasion, depending on how dusty
25
72: 1 it was. It wasnt mandatory that we wear them.
2
3 Q Let me see if we can find out just when
4
5 you were working with the firebrick during that period,
6
7 how often would you wear the dust mask?
8
9 A Well, quite a bit of the time, but because it
10
11 was dusty most of the time.
12
13 Q But not all of the time?
14
15 A Well, after you would leave the area and come
16 back in, actually it would be settled, but as soon as
17
18 you started moving around, the dust would rise.
19
20 Q Im a little confused. Im trying to find
21
22 out in that period of time when you were actually
23
24 working on the firebrick, actually working, not just
25
73: 1 happen to be in the boiler, what percentage of the time
2
3 when you were working did you have the mask on?
4
5 A At least 80 percent of the time.
6
7 Q After the firebrick was taken down by you
8
9 and broken down by you, what happened to it next?
10
11 A Well, we broke it away from the piping and
12
13 everything was dropped to the boiler floor. We then
14
15 had to go down to the level of the boiler floor, go
16
17 into the boiler, shovel it out into wheelbarrows, and
18
19 then wheel it out and dispose of it.
20
21 Q How far a drop are we talking about to the
22
23 floor?
24
25 A From the top of the boiler to the bottom only,
74: 1
2 its — the bottom of the boiler is on the second –
3
4 its what we call an elevation 126, all the way up to
5
6 an elevation of 191 which would be seven floors.
7
8 Q Just dropped free falls six or seven
9
10 floors?
11
12 A Thats correct. Every floor is, by the way, 13
13
14 feet.
15 Q Now, after you broke down the brick, you
16
17 went down and shoveled it up and put it in wheelbarrows
18
19 and disposed of it; right?
20
21 A Thats correct.
22
23 Q Where did you dispose of it?
24
25 A We used to at that time pile it outside of the
75: 1
2 building. After that I dont know how they eliminated
3
4 it.
5
6 Q Okay. Other than the firebrick, what
7
8 other sort of insulation did you work with inside the
9
10 boiler?
11
12 A Well, there was insulation around the tubes.
13
14 Q And since Im not familiar with the inside
15
16 of a boiler would you tell me what these tubes were?
17
18 A Boiler tubes are where the water goes through
19
20 the boiler and the heat of the boiler heats the water
21
22 in the tubes.
23
24 Q And how big a diameter are we talking
25
76: 1 about for the tubes?
2
3 A The tubes were various sizes, most of them were
4
5 3 to 4 inches around.
6
7 Q And you state there was insulation around
8
9 these tubes?
10
11 A Thats correct.
12
13 Q And did you have to remove this insulation
14 when you were in there?
15
16 A Yes.
17
18 Q Would this be a complete tear down or was
19
20 it just damaged areas?
21
22 A Well, during normal operation the insulation
23
24 would breakdown due to the time the unit was in
25
77: 1 service, and we would have to clean it out, and then
2
3 they would reinsulate it afterwards, but there was a
4
5 normal procedure for every long outage.
6
7 Q As long as were on that, how many
8
9 different boilers were you inside of during that time
10
11 period?
12
13 A That particular time I was only in one boiler.
14
15 Q And for how long were you in there?
16
17 A Well, I worked on that outage for a period of at
18
19 least two months. The whole time wasnt spent in that
20
21 boiler.
22
23 Q The outage itself was two months?
24
25 A It outage itself was at least two months.
78: 1
2 Q And can you estimate how many days you
3
4 were in the boiler?
5
6 A I would say I was a good month in the boiler.
7
8 Q And would that be five days a week, 40
9
10 hours a week?
11
12 A No. Some days it would be longer and it would
13 be weekends also.
14
15 Q So how long a workday are we talking
16
17 about?
18
19 A Well, were talking about eight oclock in the
20
21 morning till eight oclock at night.
22
23 Q Okay. Now, how would you go about
24
25 removing the insulation from the tubes?
79: 1
2 A We would just take it off, you know, if it was
3
4 loose we would just rip it off.
5
6 Q By hand?
7
8 A Yeah, with gloves on.
9
10 Q Okay. Did you ever use any tools to take
11
12 it off?
13
14 A We might have a pry bar or something where it
15
16 was held on tight.
17
18 Q Now, when the material came off the tubes,
19
20 would this also fall to the boiler floor?
21
22 A Thats correct. Everything went down to the
23
24 boiler floor. Even tools occasionally.
25
80: 1 Q Now, when you were removing the insulation
2
3 from the tubes, did you wear facial protection during
4
5 that operation?
6
7 A We wore a dust mask, yes.
8
9 Q And can you give me a percentage of the
10
11 time for that like you did with the firebrick?
12 A This time it was most of the time because there
13
14 was a lot more dust.
15
16 Q Well, you said 80 percent of the time on
17
18 the firebrick, this would be almost 100 percent of the
19
20 time?
21
22 A This would be roughly 100 percent of the time.
23
24 Q And you stateed that this was dustier than
25
81: 1 breaking the firebricks?
2
3 A Yes, because when everything was dropped down to
4
5 the boiler floor, it automatically disintegrated into
6
7 fine particles and was suspended into the air.
8
9 Q And that wouldnt happen so much with the
10
11 firebricks?
12
13 A The firebricks would break due to the amount of
14
15 extreme heat they were under, but they wouldnt
16
17 discintergrate as easy as the insulation.
18
19 Q Now, the dust that you say was generated
20
21 when this tube insulation hit the boiler floor, is it
22
23 your recollection that that dust went all the way up
24
25 back to where you were working?
82: 1
2 A It depended on the draft. I wouldnt say it all
3
4 went up there. I would say maybe at least it went up
5
6 halfway up the boiler.
7
8 Q Well, my question is do you believe that
9
10 the dust that was generated when these materials hit
11 the floor, Im talking about the bricks or the tube
12
13 insulation, do you believe that dust reached where you
14
15 were working at the time?
16
17 A It was hard to say because we were creating dust
18
19 working up there.
20
21 Q Okay.
22
23 A It was dusty enough around us that, you know, we
24
25 just couldnt — there was no like division line that
83: 1
2 we knew of.
3
4 Q All right, fine. Other than the firebrick
5
6 and the insulation around the tubes, were there any
7
8 other forms of insulation that you worked on inside of
9
10 the boilers?
11
12 A No.
13
14 Q Any other asbestos products that you
15
16 worked on inside the boilers?
17
18 A No, just those two.
19
20 Q Would you have any other duties inside
21
22 that boiler besides breaking down the firebrick or
23
24 removing insulation from the tubes?
25
84: 1 A Not in that particular boiler at that time.
2
3 Q Im just talking about this one incident
4
5 that you said in the 50s?
6
7 A Yes. I just wanted noted that this is just one
8
9 incident.
10 Q Im sure well get to all of them. So is
11
12 that your recollection that these were your only two
13
14 duties inside that boiler?
15
16 A Thats correct.
17
18 Q Do you remember if you had a supervisor on
19
20 that job?
21
22 A Yes.
23
24 Q Do you remember his name?
25
85: 1 A Yes.
2
3 Q And would you tell us?
4
5 A Joseph Nash.
6
7 Q Do you know if Mr. Nash is still employed
8
9 by Public Service?
10
11 A No, hes deceased.
12
13 Q All right. You also stated to me that
14
15 during this time period of September 51 until February
16
17 1952, you worked hands-on with insulation on piping; is
18
19 that correct?
20
21 A No, I didnt work hands-on with it. I worked in
22
23 the area of piping with insulation.
24
25 Q Okay. And Ill come back to that. Would
86: 1
2 that go equally for the insulation on the valves, that
3
4 you didnt work yourself with that insulation but you
5
6 worked near it?
7
8 A Thats correct. I was working in areas where it
9 was being worked on.
10
11 Q All right. Lets start with the
12
13 insulation on piping. How did you come to be working
14
15 in an area where there was insulation on piping?
16
17 A Well, practically the whole powerhouse is
18
19 insulated with — all the piping is insulated with
20
21 asbestos insulation.
22
23 Q Okay. But you stated that you were
24
25 working in an area where that insulation was being
87: 1
2 worked on; is that correct?
3
4 A Well, I would be passing through the area. They
5
6 would have maintenance men tearing down the insulation,
7
8 working on the piping, working on the valves.
9
10 Q Okay. Were you ever assigned to a
11
12 specific area where that operation was going on?
13
14 A Yes, I was.
15
16 Q And what was your job duty at that time?
17
18 A I was just a helper. I would be standing by
19
20 going for materials.
21
22 Q Can you tell me what sort of employees you
23
24 were helping?
25
88: 1 A They were maintenance department workers.
2
3 Q And were these maintenance employees
4
5 themselves working with the insulation?
6
7 A They were.
8 Q And during any of their operation was any
9
10 dust created?
11
12 A Yes.
13
14 Q And do you believe this dust came from any
15
16 of the asbestos at the plant?
17
18 A It did. You could see it falling from the
19
20 asbestos insulation.
21
22 Q Can you tell me what these maintenance
23
24 department employees were doing that was generating
25
89: 1 dust?
2
3 A They would be taking down the old insulation
4
5 where it had been ripped away from the piping and
6
7 replacing it.
8
9 Q And how would you help them do this?
10
11 A I would be just standing by, like I said, in
12
13 case they needed any help.
14
15 Q Just sort of a witness?
16
17 A No, well, they always sent a helper out. They
18
19 claimed it was cheaper to send a helper down to the
20
21 store room if they needed anything then to have
22
23 somebody else go.
24
25 Q Let me ask you, while you were helping the
90: 1
2 maintenance department, were those employees wearing
3
4 any protection over their face?
5
6 A They would be wearing dust masks occasionally,
7 not all the time.
8
9 Q Were they wearing dust masks half the
10
11 time?
12
13 A More than half, 70 percent.
14
15 Q And how about yourself, when you were
16
17 helping would you ever wear a dust mask?
18
19 A Yes.
20
21 Q And about what percentage of the time?
22
23 A Well, I would be standing back, more or less out
24
25 of the way, so maybe 50 percent of the time.
91: 1
2 Q When you were in this standing position,
3
4 about how far would you be from the workers?
5
6 A Id say 10 feet away.
7
8 Q And, now, you stated that you would go get
9
10 supplies for them; is that correct?
11
12 A Thats correct.
13
14 Q Would any of the these supplies be
15
16 asbestos-containing products?
17
18 A Yes.
19
20 Q And what particular supplies would they
21
22 be?
23
24 A They would be valve packings,
25
92: 1 Q Anything else?
2
3 A No, basically valve packings.
4
5 Q And what leads you to believe that the
6 valve packings were asbestos-containing?
7
8 A I was told by the older maintenance men, the
9
10 experienced maintenance men, and on some occasions it
11
12 said asbestos packing on the valve boxes.
13
14 Q Do you remember what the boxes looked
15
16 like?
17
18 A Well, most of it was — it came in boxes, but
19
20 inside the boxes were metal reels that the packing was
21
22 wrapped around.
23
24 Q So how big were the boxes, can you
25
93: 1 estimate?
2
3 A Most of the reels were maybe six inches wide, 4
4
5 inches round.
6
7 Q And your recollection was that some of
8
9 these boxes had the word asbestos on it?
10
11 A Thats correct.
12
13 Q Do you remember if any manufacturers name
14
15 was on the boxes?
16
17 A They were Crane, Garlock and Anchor.
18
19 Q And when you brought these valve packings
20
21 back to the maintenance department employees, what did
22
23 they do with them?
24
25 A They packed the valves were they were leaking,
94: 1
2 around the seams.
3
4 Q Did you take part in that procedure?
5 A No, no. You couldnt work, you know, outside of
6
7 your classification.
8
9 Q Let me ask you about that. At that time
10
11 were you a member of the union?
12
13 A Yes, I was.
14
15 Q And did the union have individual crafts?
16
17 A Yes.
18
19 Q Or job classifications?
20
21 A Thats correct.
22
23 Q And you stated that a person in one
24
25 particular, and Ill use the term craft, if you
95: 1
2 understand what Im talking about?
3
4 A Yes, I understand.
5
6 Q One particular craft was forbidden to do a
7
8 job that was supposed to be done by another craft; is
9
10 that correct?
11
12 A Thats correct.
13
14 Q During this time period in the early 50s
15
16 when you worked there, was it your recollection that
17
18 that was strictly enforced?
19
20 A Yes, it was.
21
22 Q And how would that be enforced?
23
24 A Well, the union itself wouldnt allow you to go
25
96: 1 out of your classification.
2
3 Q So if you attempted yourself to do a job
4 outside of your classification and someone in the union
5
6 saw you, they would generally stop you from doing that?
7
8 A They would tell you if you were doing something
9
10 wrong; right.
11
12 Q To your recollection would management
13
14 attempt to get you to cross crafts?
15
16 A Generally they didnt want you to cross crafts.
17
18 Q Okay.
19
20 A There were occasions but thats arbitration
21
22 things.
23
24 Q But, in general, the management followed
25
97: 1 that policy?
2
3 A Yes.
4
5 Q Let me get back to the valve packings for
6
7 a minute. The maintenance men who used these valve
8
9 packings that you brought, would they have to remove
10
11 old valve packings from these areas?
12
13 A All valve packings?
14
15 Q Old.
16
17 A Old valve packing, yes, before they replaced it
18
19 with the new stuff.
20
21 Q And how would that be done?
22
23 A Well, they went in there with some kind of a
24
25 pick and a little hammer and get it out of there.
98: 1
2 Q Do you remember if dust was generated from
3 that operation?
4
5 MR. DOWDEN: Objection.
6
7 A Yes, particles would fly.
8
9 Q And how far away from this operation would
10
11 you be?
12
13 A At that particular time I would be standing
14
15 close, you know, in case they needed any help.
16
17 Q And how close is close?
18
19 A A couple feet.
20
21 Q And in that particular occasion would you
22
23 be wearing a mask if you were working a few feet?
24
25 A Yes.
99: 1
2 Q And were the maintenance men wearing masks
3
4 at that time?
5
6 A Yes.
7
8 Q Do you recall bringing any other materials
9
10 that you believe contained asbestos to the maintenance
11
12 men during this 1951/1952 time period?
13
14 A No.
15
16 Q You say that you worked nearby when
17
18 someone was performing a function on valves?
19
20 A Packing valves, yes.
21
22 Q Is that the same –
23
24 A First they would remove some of the insulation.
25
100: 1 There were occasions where they had to remove
2 insulation to weld the piping.
3
4 Q So it would be the same maintenance men
5
6 weve been talking about?
7
8 A Yes.
9
10 Q Can you tell me during that six month time
11
12 period weve been talking about, how often you would
13
14 help these maintenance men in this type of operation?
15
16 A There was only the duration of that outage.
17
18 Whatever jobs we were assigned to on that outage.
19
20 Q Is this the same outage we were talking
21
22 about before?
23
24 A Yes, same outage.
25
101: 1 Q That two month time span?
2
3 A Thats correct.
4
5 Q Out of that time span you stated you spent
6
7 a month inside the boiler?
8
9 A At least a month inside the boiler.
10
11 Q And all the operations were talking about
12
13 here were operations that were outside of the boiler;
14
15 is that correct?
16
17 A Thats correct.
18
19 Q Now, other than the firebrick in the
20
21 boiler, the insulation around the tubes in the boiler,
22
23 the insulation on the piping, the insulation on the
24
25 valve, and the valve packings, do you believe you were
102: 1 exposed to any other asbestos or asbestos-containing
2
3 products during that time period?
4
5 A No, I couldnt say definitely.
6
7 Q Okay. Fine. During that time period how
8
9 many hours were you working?
10
11 A It was close to 70 hours.
12
13 Q Are you aware of any other toxic
14
15 substances besides asbestos that you were exposed to at
16
17 that time?
18
19 A At that time?
20
21 Q In that six- to seven-month period?
22
23 A No.
24
25 Q When you worked inside the boilers was
103: 1
2 there any sort of ventilation?
3
4 A No ventilation at all. Just opened doors.
5
6 Q Okay. When you were helping with the
7
8 maintenance department men, was this indoors or
9
10 outdoors? Im talking about the operation weve been
11
12 discussing where they were packing values.
13
14 A Those were indoors.
15
16 Q Indoors?
17
18 A Yes.
19
20 Q What particular area would that take place
21
22 of the plant?
23
24 A On any of the piping around the boiler.
25 Q Were these jobs done in ventilated areas?
104: 1
2 A Just open atmosphere, thats about it.
3
4 Q Atmosphere inside the building?
5
6 A Inside the building, right.
7
8 Q Do you remember any particular types of
9
10 ventilation that was present during that time period?
11
12 A Any type of ventilation?
13
14 Q Were there overhead fans or –
15
16 A No, not in the boiler room.
17
18 Q Lets talk about when you came back from
19
20 the service. Do you remember the month that you
21
22 started back at Public Service?
23
24 A I got back in 1956, February 1956. And I think
25
105: 1 there was a two-week period before I started, so it
2
3 could have been March that I started. In fact, I think
4
5 it was March 7th.
6
7 Q Okay. Thats pretty close. And when you
8
9 returned what was your work site?
10
11 A When I returned I was in the — at that time
12
13 what they called the test department.
14
15 Q And your position?
16
17 A I was a technical helper.
18
19 Q And was this at Sewaren?
20
21 A Still at Sewaren, right.
22
23 Q And this was still the same unit; is that
24 correct?
25
106: 1 A Thats correct.
2
3 Q And how long were you assigned to the test
4
5 department?
6
7 A I was there for approximately five months –
8
9 well, no, I shouldnt say that. I was there, Ive been
10
11 there ever since. I — I thought you were referring to
12
13 what job classification I was in.
14
15 Q All right. So you have remained in the
16
17 test department itself?
18
19 A Since then its been changed to the performance
20
21 department, you know, but its the same department
22
23 basically. The same work.
24
25 Q Now, Ill ask the question you thought I
107: 1
2 was going to ask. How long were you a technical
3
4 helper?
5
6 A Five months.
7
8 Q And those five months were spent in
9
10 Sewaren?
11
12 A Correct.
13
14 Q And is the test department a particular
15
16 area of the buildings or is that a classification of
17
18 employees?
19
20 A Its really a classification of the employees.
21
22 We worked throughout the building, throughout the whole
23 generating station.
24
25 Q As a technical helper did you work in any
108: 1
2 particular area or throughout the generating station?
3
4 A Throughout the generating station. Whatever the
5
6 job demanded.
7
8 Q What does a technical helper do?
9
10 A At that time we used to check coal samples and
11
12 oil samples and we used to analyze the boiler
13
14 chemistries and assisting technicians.
15
16 Q Im sorry, the third thing, you analyzed
17
18 boiler –
19
20 A Boiler water.
21
22 Q When you say you collected coal samples,
23
24 where would you get the coal samples?
25
109: 1 A The coal samples we used to get from the coal
2
3 store.
4
5 Q And this was coal that was delivered to
6
7 Sewaren by somebody else?
8
9 A It was delivered by barges.
10
11 Q And did you, yourself, perform any test
12
13 functions in that 5 months?
14
15 A On the coal?
16
17 Q On the coal?
18
19 A No. We just collected samples and shipped them
20
21 out.
22 Q And how did you check the samples?
23
24 A Well, we had to take so many — so many portions
25
110: 1 of a pile of coal that they set aside and break it down
2
3 and mix it up so we got an equal sample, and put it in
4
5 a can.
6
7 Q I dont understand what you mean by break
8
9 it down and mix it up.
10
11 A Well, when they were unloading the barge, they
12
13 would take a certain amount off coming up the conveyor
14
15 belt and just put it in the barrel for us. In other
16
17 words, each barrel had a barge name on it and that was
18
19 a representative sample from that barge. They
20
21 collected a certain amount and we just mixed it up and
22
23 take a quart sample of it.
24
25 Q Was any of this operation particularly
111: 1
2 dusty?
3
4 A Yes, there was coal dust, yes.
5
6 Q And how would the coal dust be generated?
7
8 A The coal coming down the conveyor belt.
9
10 Q And did the employees in that area where
11
12 facial protection?
13
14 A No.
15
16 Q Did you wear facial protection when you
17
18 were in that area?
19
20 A No.
21 Q How often would you be in that area where
22
23 the coal was coming down?
24
25 A Whatever they told us they unloaded a barge. It
112: 1
2 could be twice a week maybe.
3
4 Q How long would you be in the area each
5
6 time you went down?
7
8 A No, more than 15, 20 minutes.
9
10 Q And you talked about collecting oil
11
12 samples?
13
14 A Yes.
15
16 Q And how would you go about that?
17
18 A Well, we would just more or less pick them up
19
20 because they would unload a tanker and the samples
21
22 would be there waiting for us to pick them.
23
24 Q And you also said you collected boiler
25
113: 1 water?
2
3 A Yes.
4
5 Q And how did you go about that?
6
7 A We walked around with the containers, sampled
8
9 the different boilers, like hot level samples,
10
11 condensation, whatever boiler was used in the system.
12
13 Q It would just come out of a tap somewhere?
14
15 A Yes, we had sample areas.
16
17 Q How would you assist the technicians?
18
19 A We would assist the technicians on whatever jobs
20 they had to perform and on occasions we were in the
21
22 boiler again.
23
24 Q During that five-month period back in
25
114: 1 1956, do you believe you were exposed to any asbestos?
2
3 A Yes, I believe.
4
5 Q And how do you believe you were exposed?
6
7 A Well, its just — its just the constant
8
9 exposure due to the insulation around the piping, the
10
11 piping insulation wears away and the asbestos
12
13 insulation starts dropping.
14
15 Q So if I understand you correctly, you
16
17 believe you were exposed to asbestos even when
18
19 employees werent working on it?
20
21 A Yes, because it would be falling from piping,
22
23 piping that was vibrating, particles floating down.
24
25 Q And during this five-month period that you
115: 1
2 were a technical helper, your exposure to asbestos came
3
4 from just walking through where this piping was
5
6 deteriorating?
7
8 A No, I also worked on jobs inside the boiler
9
10 again.
11
12 Q Okay. Lets hold off on that. Other than
13
14 the jobs inside the boiler during this five-month
15
16 period, do you believe you were exposed to any asbestos
17
18 other than just what was falling from the pipes?
19 A Not that I recollect.
20
21 Q Okay. Fine. Now, you say you worked in
22
23 the boilers during that period; is that correct?
24
25 A Occasionally, yes.
116: 1
2 Q And what would you be doing in there?
3
4 A We would be going in to replace thermocouples
5
6 that were broken away from the boiler tubes.
7
8 Q Explain to me what a thermocouple is?
9
10 A A thermocouple is two dissimilar metals welded
11
12 together at the time to form an EMF signal which goes
13
14 back to the recorder and transforms that signal to a
15
16 temperature on the reformer.
17
18 Q Now, your job was to remove the
19
20 thermocouples?
21
22 A Yes, occasionally they would break away from the
23
24 tubes and we were to replace them.
25
117: 1 Q Do you know how many times you would have
2
3 done that during that five months?
4
5 A Just maybe once during an outage.
6
7 Q And how did removing the thermocouple
8
9 expose you to asbestos?
10
11 A Again, we were in the boiler where the asbestos
12
13 insulation was, and we had to move it aside to get to
14
15 the thermocouples to replace them.
16
17 Q As there anything in the replacement of
18 the thermocouple itself that exposed you to asbestos?
19
20 A Pardon? Would you repeat that?
21
22 Q Okay. You were working on this
23
24 thermocouple. Was there any asbestos right there where
25
118: 1 the thermocouple was?
2
3 A Yes, on occasion we would have to remove
4
5 insulation to get to the thermocouple.
6
7 Q Was there insulation around the
8
9 thermocouples?
10
11 A Thats correct.
12
13 Q And you say this happened maybe once
14
15 during the five months?
16
17 A At that period of time, yes.
18
19 Q Okay. Was that job, removing the
20
21 thermocouples, a job of a particular class of
22
23 employees?
24
25 A Yes, it was a technicians job to — we assisted
119: 1
2 but it was mainly a technicians job, and the reason
3
4 for that was that they were sent into the tube.
5
6 Q So that only technicians and technicians
7
8 helpers should be removing that thermocouple?
9
10 A Thats correct.
11
12 Q Let me go back just for a second to that
13
14 earlier period before you went in the service. You
15
16 stated that you would go to get supplies for the
17 maintenance people. Is there any particular area that
18
19 you would go to get the package?
20
21 A Yes, we had a central storeroom.
22
23 Q And where was that storeroom located back
24
25 in 1951?
120: 1
2 A It was — its right next to the maintenance
3
4 department office on the first floor.
5
6 Q Did that ever move — in other words, is
7
8 that still the central storeroom?
9
10 A That storeroom has been there as long as Ive
11
12 been there.
13
14 Q When you were in that central storeroom
15
16 back in 1950s, were there any other asbestos products
17
18 that you noticed being stored in there?
19
20 A Not in the storeroom but there were also
21
22 products outside the storeroom that had been shipped in
23
24 and they would be stored in the turbine bay ready to be
25
121: 1 used.
2
3 Q And was this in that 1951 to 1952 period
4
5 were talking about?
6
7 A Yeah, there was always — it was a continuous
8
9 cycle, no matter which year you picked, whatever they
10
11 did the boiler insulation was around.
12
13 Q Other than the four or five asbestos
14
15 products we mentioned during that earlier time period,
16 do you recall any other asbestos products being stored
17
18 in the turbine area?
19
20 A Yes, I remember products by J.H. LaFrance.
21
22 Q Do you remember what kind of products?
23
24 A They had firebrick on wooden pallets banded
25
122: 1 together.
2
3 Q Is it your recollection that there were
4
5 other kinds of firebricks there besides the J.H.
6
7 LaFrance or were all the firebricks J.H. LaFrance?
8
9 A I dont know definitely if all of them were J.H.
10
11 LaFrance.
12
13 Q Did you notice any other manufacturers of
14
15 firebrick?
16
17 A Not at that time.
18
19 Q Is there anything else you can remember
20
21 from that 51/52 period?
22
23 A Well, the only thing with the firebrick would be
24
25 cement, Im estimating a gallon-sized type can. They
123: 1
2 had two different sizes, I guess each can might have
3
4 weighed 50 pounds, 100 pounds, two different sizes.
5
6 Q And do you know the manufacturer of that
7
8 cement?
9
10 A The cement, it was LaFrance.
11
12 Q Did the maintenance men you helped ever
13
14 use the cement?
15 A We were never with them when they were
16
17 reinsulating.
18
19 Q Okay. Let me jump forward in time again.
20
21 Now youre a technical helper again. Was it your job
22
23 as a technical helper to get supplies?
24
25 A It was still, yes. We would supply the
124: 1
2 technicians with whatever they needed.
3
4 Q Did you go to the central –
5
6 A Storeroom.
7
8 Q — storeroom?
9
10 A Thats correct.
11
12 Q Did you ever personally get any supplies
13
14 which you believed contained asbestos during that time
15
16 period as a technical helper?
17
18 A No, because the technicians didnt particularly
19
20 work with it except removing what they had to get out
21
22 of the way.
23
24 Q Okay. Let me ask you, after you spent
25
125: 1 your five months as a technical helper, what was your
2
3 next title?
4
5 A Technical assistant.
6
7 Q And how long were you a technical
8
9 assistant?
10
11 A Until 1963.
12
13 Q Was all that time spent at Sewaren?
14 A Thats correct.
15
16 Q And what were your duties as a technical
17
18 assistant?
19
20 A A technical assistant we still had a little bit
21
22 of water analysing, we still assisted technicians, and
23
24 we also did the report type work like on the amount of
25
126: 1 fuel burned. The amount of generation, that sort of
2
3 desk work.
4
5 Q Did you work with any asbestos or asbestos
6
7 products as a technical assistant?
8
9 A Yes, again, we would be up on that same –
10
11 replacing thermocouples in the boilers. We also
12
13 assisted — oh, we also assisted the technicians with
14
15 whatever they had to do which meant crawling into areas
16
17 where there was quite a bit of insulation.
18
19 Q And about how often as a technical
20
21 assistant would you be called upon to remove
22
23 thermocouples?
24
25 A Again, I dont remember the exact times but it
127: 1
2 would be during these annual outages. By annual
3
4 outages I mean each unit had an outage. It could be
5
6 one particular unit one year, one unit the next year.
7
8 Q If my interpretation is correct, once a
9
10 year you would remove thermocouples?
11
12 A Some years I may not, somebody else might have
13 gotten the job.
14
15 Q But the most you would remove a
16
17 thermocouples would be once a year?
18
19 A Most of the time, yes.
20
21 Q And would you just remove one thermocouple
22
23 from the boiler?
24
25 A No, it could be — depending on the number that
128: 1
2 were there, we replaced all of the ones that were bad.
3
4 Q How would you know if one was bad?
5
6 A Well, first of all the recorder would tell you
7
8 or you could check for continuity between the two
9
10 wires, if you dont have continuity it was open.
11
12 Q How long would it take for your end of
13
14 that operation if you had one thermocouple to remove?
15
16 A Well, it was a matter of removing the
17
18 thermocouples plus the extension wire that came to the
19
20 thermocouple. You could spend an hour on just one.
21
22 Q Okay. Now, you stated that you did water
23
24 analysis, was there any asbestos exposure related to
25
129: 1 your water analysis job?
2
3 A No, not unless you walked to the general area
4
5 around the boiler where the insulation was falling
6
7 away.
8
9 Q And thats just the general deterioration
10
11 you mentioned before; is that correct?
12 A Thats correct.
13
14 Q And you stated that you might have to
15
16 crawl into areas where there was insulation?
17
18 A Yeah, we did a lot of work on feed water heaters
19
20 and the valving and the piping around the feed water
21
22 heater gets quite, you know, close. We maintain the
23
24 level columns.
25
130: 1 Q When you were crawling around the feed
2
3 water heaters, were there other employees that were
4
5 working on the insulation?
6
7 A Yeah, at the same time youd have maintenance
8
9 men in the area repacking valves, you know, taking off
10
11 the insulation.
12
13 Q And how often would you be called upon to
14
15 crawl around these feed water heaters –
16
17 A Well –
18
19 Q — as a technical assistant?
20
21 A Again, I say its, you know, if your turn comes
22
23 up, you do it. You know, I mean there were several
24
25 Ts. We didnt do the same job. I mean we all did the
131: 1
2 same job but not precisely the same time.
3
4 Q Would you have to — you, personally, have
5
6 to crawl around in one of these heaters once a month?
7
8 A No, I wouldnt say once a month. I would say
9
10 once during the year on that outage.
11 Q Okay. Are there any other duties you had
12
13 as a technical assistant which you believe exposed you
14
15 to asbestos?
16
17 A No, outside of the areas where the maintenance
18
19 men were working that related to our jobs, there would
20
21 be no other instances.
22
23 Q Okay. Would you have occasion to be
24
25 working within 5 or 10 feet of the maintenance men as a
132: 1
2 technical assistant?
3
4 A Definitely.
5
6 Q And the maintenance men would be removing
7
8 insulation during the time you were in 5 and 10 feet?
9
10 A Thats correct.
11
12 Q Would you be wearing a mask during those
13
14 time periods?
15
16 A Occasionally, again, not constantly.
17
18 Q Was there any direction by anybody at the
19
20 Sewaren plant?
21
22 A There was never a — it was never a forced
23
24 issue. You could wear it or you didnt have to wear
25
133: 1 it. We put them on when the particles in the air got
2
3 excessive.
4
5 Q Did you receive any guidance at all as to
6
7 when to put them on?
8
9 A No, they never said, you know, definitely wear
10 them.
11
12 Q Do you remember it being discussed with
13
14 supervisory personnel?
15
16 MR. PAULUS: Time frame?
17
18 MR. BASIL: While he was a technical
19
20 assistant.
21
22 A Not at that time.
23
24 Q Okay. After — well, lets take this time
25
134: 1 period again as a technical assistant. Did you have
2
3 occasion to go to the central storeroom as a technical
4
5 assistant?
6
7 A Oh, yeah, lots of times.
8
9 Q And while you were in the storeroom, do
10
11 you remember seeing any asbestos products during that
12
13 time period?
14
15 A Same products that I mentioned before.
16
17 Q No additional products that you recall?
18
19 A No.
20
21 Q And how about stored outside of the
22
23 central storeroom?
24
25 A Well, like I said, it was a continuous storing.
135: 1
2 The only other product I remember was something they
3
4 called Super 3000. I dont know who manufactured it.
5
6 Q Do you know what it was?
7
8 A Yeah, it was an insulation for inside of the
9 boiler. They used to — they had like the metal bins
10
11 that you would mix concrete in. They would drop the –
12
13 well, it was really fine insulation. They would drop
14
15 it into the bin, add water, mix it up and take it away
16
17 in buckets, and that was quite dusty. There were
18
19 particles.
20
21 Q So the Super 3000 wouldnt be put on just
22
23 the way it was packaged; is that correct?
24
25 A Thats correct.
136: 1
2 Q What craft would be involved in mixing the
3
4 Super 3000?
5
6 A Maintenance boiler repairmen.
7
8 Q And you stated that this was a dusty
9
10 product?
11
12 A Thats correct. As it was dumped from the bag
13
14 into the bin it was a dusty product.
15
16 Q After it was mixed, was there any dust
17
18 involved with this product?
19
20 A Well, the only dust would be the dust that
21
22 escaped the bin and was still on the floor or on the
23
24 guys clothes.
25
137: 1 Q Just from the mixing operation; is that
2
3 correct?
4
5 A Yes.
6
7 Q Once the product was wet did it generate
8 dust at all?
9
10 A No.
11
12 Q And how often would you have been — and
13
14 lets take this time frame as a technical assistant –
15
16 in an area where this Super 3000 was being mixed?
17
18 A Exactly, you know, Ive seen it done. I cant
19
20 say exactly the amount of time or the number of
21
22 occasions. It was such a natural thing, you never, you
23
24 know, you never paid that much attention to it.
25
138: 1 Q Do you remember working in an area where
2
3 this 3,000 was being mixed for an extended period of
4
5 time?
6
7 A Well, we would working on a piece of equipment
8
9 and they might be 10 or 20 feet away from us.
10
11 Q Do you have a specific recollection of
12
13 working within 20 feet of this mixing operation?
14
15 A Yes, thats correct.
16
17 Q And this would be in the 56 to 63 time
18
19 period or some other time period?
20
21 A That would be in that time period and even
22
23 beyond that time period.
24
25 Q And other than the products that youve
139: 1
2 already mentioned, can you think of any other asbestos
3
4 products that you believe you saw at the Sewaren plant
5
6 in that time period?
7 A Yes, there were — when we did the heater
8
9 control jobs, there was a gasket we used to replace
10
11 which was called Flexitallic which was a piece of
12
13 asbestos with metal wrapped around it, and these were
14
15 inserted, again, the flanges of the control unit itself
16
17 and the piping.
18
19 Q Whose job was that to install it?
20
21 A To install it was the technicians and we
22
23 assisted them.
24
25 Q And as a technicians assistant how would
140: 1
2 you assist in putting in a gasket?
3
4 A Well, it becomes kind of tricky trying to get it
5
6 in there and get the flange together without dropping
7
8 the gasket, so we would assist either bending the
9
10 piping out of the way or handing him the gasket or
11
12 whatever he wanted.
13
14 Q Do you remember if old gaskets had to be
15
16 removed before the new gaskets –
17
18 A Yes, mainly that was the purpose because we
19
20 would develop a leak around the flange and it would be
21
22 that the gasket was deformed.
23
24 Q Would you have any way of telling what
25
141: 1 type of gasket the old gasket was?
2
3 A They were also Flexitallic.
4
5 Q And how would you know that?
6 A Well, they — they went by the name of
7
8 Flexitallic. If we went to the storeroom to check them
9
10 out we would ask for Flexitallic gaskets.
11
12 Q Im talking about the old gasket that was
13
14 in there. Would you have any way of identifying the
15
16 old gasket as being Flexitallic?
17
18 A Yes, because we ordered it from a certain
19
20 company and they would supply them with that type of a
21
22 gasket. The company who made the control, wed also
23
24 order the gaskets from, and if we didnt order them
25
142: 1 they would be on hand in the storeroom.
2
3 Q Would there be any way from looking at the
4
5 gasket that you can identify it as a Flexitallic
6
7 gasket?
8
9 A I dont remember anything being written on them
10
11 that said Flexitallic.
12
13 Q Can you think of any other asbestos
14
15 products that you remember –
16
17 A The only –
18
19 Q — during that time period?
20
21 A I have been acquainted with — there used to be
22
23 like a, what they call an asbestos blanket.
24
25 Q Did you ever see these asbestos blankets
143: 1
2 when they were packaged in any way?
3
4 A No. Mainly they would have them in the
5 storeroom. It came on a big roll and they hung them up
6
7 with a pipe through them, and you would go down and say
8
9 I want 4 foot, 5 foot. Whatever length asbestos sheet
10
11 you wanted.
12
13 Q And they would cut it in the storeroom?
14
15 A They would cut it right there. Very flaky.
16
17 Q And would any of your duties involve
18
19 working with the asbestos blankets?
20
21 A Yeah, I would go get it. The main reason why we
22
23 would go get it is if we had an area like we had to
24
25 lean up against a hot pipe, we would put it against the
144: 1
2 hot pipe so we wouldnt get burned, but we would be
3
4 actually leaning against the asbestos blanket.
5
6 Q This was as a technical assistant?
7
8 A As a technical assistant and even later on as a
9
10 technician.
11
12 Q Would you ever use old asbestos blankets
13
14 for this job?
15
16 A Yeah, if we had an old one laying around, it
17
18 might have been dirtier, but it would serve the same
19
20 purpose.
21
22 Q Would it be a regular practice to leave
23
24 old asbestos blankets laying around?
25
145: 1 A No, like we would maybe have some stored in the
2
3 shop under the bench folded up in case we needed them
4 again.
5
6 Q Do you have any idea who manufactured
7
8 these asbestos blankets?
9
10 A No.
11
12 Q Did you have any idea who manufactured the
13
14 Super 3000 you mentioned?
15
16 A No, I dont remember the manufacturer. That was
17
18 the name and I dont know who manufactured it.
19
20 Q Let me ask you as a technical helper, did
21
22 you ever have occasion to see any of these asbestos
23
24 products delivered to the Sewaren plant?
25
146: 1 A I dont know. The only deliveries I remember
2
3 were by trucks I saw coming done the road that said
4
5 State Insulation on them, thats all.
6
7 Q And what time period would that have been?
8
9 A That was mainly when I was a technician.
10
11 Q So thats later than 1963?
12
13 A Thats later, yes.
14
15 Q Do you recall seeing the State Insulation
16
17 trucks before that time?
18
19 A Never paid any attention to them.
20
21 MR. MC GRATH: Later than 63; is that
22
23 what you meant?
24
25 MR. BASIL: Yes. My question is do you
147: 1
2 remember seeing State Insulation before 1963.
3 Let me repeat it.
4
5 Q Do you recall seeing the State Insulation
6
7 truck before 1963?
8
9 A I cant say definitely. You know, Ive seen the
10
11 trucks but as far as the timing, who pays attention?
12
13 You see the name on the truck. You read every name
14
15 that comes in but the exact date and time I cant
16
17 define.
18
19 Q Did you see any other deliveries made
20
21 besides State Insulation?
22
23 A Well, there were always trucks coming in
24
25 bringing in insulation, but where they were from, some
148: 1
2 of them some trucks came in and never had any names on
3
4 them. The only reason why I guess this had a
5
6 significance, because I think they were located down on
7
8 outer State Street in Perth Amboy.
9
10 Q So you were familiar with the name from
11
12 where you lived; is that correct?
13
14 A Yeah.
15
16 Q Lets move on then from technical helper,
17
18 next you became a technician?
19
20 A Thats correct.
21
22 Q And what years were you a technician?
23
24 A 1963 up until 1984. Let me retract that. Ive
25
149: 1 had this job since two years ago, so 87.
2 Q 1983 to 87?
3
4 A 1963 to 1987.
5
6 Q Okay. And this also was a bargaining unit
7
8 position?
9
10 A Technician, yes.
11
12 Q Now, in 1963 when you became a technician,
13
14 was this at the Sewaren plant?
15
16 A Thats correct.
17
18 Q Were you at the Sewaren plant the entire
19
20 time?
21
22 A No, there was one occasion I was sent to Linden
23
24 generating station.
25
150: 1 Q You were only sent there once to Linden?
2
3 A Thats the only time I remember.
4
5 Q Lets see if we can get that part out of
6
7 the way. When were you sent to Linden?
8
9 A It was in the early 70s. I dont know the
10
11 exact date.
12
13 Q And how long were you there?
14
15 A For a period of three months.
16
17 Q Other than this three-month period in the
18
19 early 70s, all the rest of your time was spent in
20
21 Sewaren; is that correct?
22
23 A Thats correct.
24
25 Q Lets get Linden out of the way. You were
151: 1 a technician?
2
3 A I was a technician when I went.
4
5 Q And what was your duty in Linden?
6
7 A Basically it was the same. I had the same
8
9 duties, a technician there. We belonged to the same
10
11 company.
12
13 Q What job were you performing in Linden?
14
15 A Technician.
16
17 Q Why were you in Linden?
18
19 A Well, they had an outage and they had a unit
20
21 outage and we, at that period of time they were sending
22
23 technicians back and forth.
24
25 Q And what did you do during the outage?
152: 1
2 A Same instrumentation work, control work.
3
4 Q Do you believe you were exposed to any
5
6 asbestos products in Linden?
7
8 A Yes, I was exposed to asbestos products in
9
10 Linden.
11
12 Q And what particular products?
13
14 A Names I dont remember, but insulation, asbestos
15
16 insulation. Again, it was the same as Sewaren. You
17
18 know, insulation falling all over. Men working on
19
20 insulation.
21
22 Q So your testimony is you dont remember
23
24 any different products being in Linden than the ones
25 you described in Sewaren?
153: 1
2 MR. FETTEN: Object to the form. Are you
3
4 talking about type as opposed to brands?
5
6 MR. BASIL: Thats exactly right.
7
8 MR. FETTEN: Okay.
9
10 Q Do you remember any additional types of
11
12 asbestos products being in Linden that were not in
13
14 Sewaren?
15
16 A No, because when I went there I didnt really –
17
18 I didnt really get the sort of jobs that would
19
20 associate me directly with asbestos outside of like I
21
22 said, being in the maintenance in general.
23
24 Q Are you aware of the manufacturer of any
25
154: 1 asbestos products that were present in Linden when you
2
3 were there?
4
5 A No, no.
6
7 Q And other than the general falling of
8
9 asbestos insulation, were you exposed in any other way
10
11 to asbestos products in Linden?
12
13 A Just working generally on the controls, you
14
15 know, near the piping, whatever controls are on the
16
17 piping.
18
19 Q Were there ever maintenance men performing
20
21 functions on the piping when you were in the area?
22
23 A Yes.
24 Q And this was at Linden?
25
155: 1 A This was at Linden.
2
3 Q And what were they doing?
4
5 A They were, again, removing insulation, welding,
6
7 reinsulating, packing valves.
8
9 Q And how far away would you be from these
10
11 men at the closest?
12
13 A Well, I would walk a couple of feet past the job
14
15 site.
16
17 Q Was your job in Linden a walking job or a
18
19 standing job if thats possible to answer?
20
21 A Well, when you get to the job you stood there,
22
23 or otherwise, otherwise you had to walk to get there.
24
25 They didnt transport you.
156: 1
2 Q When you got to a particular area when you
3
4 were performing a function, would you tend to be
5
6 stationary for awhile?
7
8 A Thats correct.
9
10 Q At any of these times when you were
11
12 stationary, were you close to the maintenance men doing
13
14 their jobs?
15
16 A Yes.
17
18 Q And these would be the jobs you described
19
20 of removing and covering insulation?
21
22 A Thats correct.
23 Q Do you recall if you were wearing a mask
24
25 when you were in the stationary position?
157: 1
2 A Normally I wouldnt be unless I was real close
3
4 to where they were working, by real close, again, if
5
6 there were dust particles flying around where it was
7
8 detrimental to my job, I had to stay there and do the
9
10 job, then I would put on a dust mask.
11
12 Q This is probably a good place to break for
13
14 lunch. Is that okay Mr. Compell?
15
16 A Fine with me.
17
18 (A lunch recess was taken 12 p.m. to 1
19
20 p.m.)
21
22
23
24
25
158: 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22 A F T E R N O O N S E S S I O N
23
24 CONTINUED DIRECT EXAMINATION BY MR. BASIL:
25
159: 1 Q Mr. Compell, good afternoon.
2
3 A Good afternoon.
4
5 Q I want to remind you were back on the
6
7 record and youre still under oath, all right, sir?
8
9 A Right.
10
11 Q When we left off we were discussing your
12
13 promotion to technician at the Sewaren plant. We have
14
15 discussed a three-month period where you worked in
16
17 Linden. Let me ask you, during that three-month period
18
19 were you working 40 hour weeks or were you working
20
21 overtime?
22
23 A Overtime.
24
25 Q Can you estimate about how many hours you
160: 1
2 were working during that three months?
3
4 A Lets see. We were working Saturdays plus two
5
6 hours a night till 10 oclock so it would be 48, about
7
8 62 hours.
9
10 Q To your recollection were all of the
11
12 technicians working overtime hours or was it just you?
13
14 A Most of them were.
15
16 Q Was it optional?
17
18 A In a sense it was optional and you were
19
20 obligated to, you know, carry your share of the load.
21 Q You could have turned it down if you
22
23 really wanted to?
24
25 A I could have turned it down unless they said the
161: 1
2 job had to be done and that we would have to work.
3
4 Q Okay. Lets go back to Sewaren then and
5
6 in 1963 you became a technician; is that correct?
7
8 A Correct.
9
10 Q What were your duties when you first
11
12 became a technician?
13
14 A My duties when I first became a technician?
15
16 Q Thats right.
17
18 A I did most of the jobs that I had learned from
19
20 working with the technicians earlier. Still control
21
22 work, the instruments and controls.
23
24 Q Over the course of the 24 or 25 years you
25
162: 1 were a technician, did your duties change at all?
2
3 A No, basically the same duties.
4
5 Q At any time during the period when you
6
7 were a technician do you recall any sort of program or
8
9 announcement by Public Service that asbestos products
10
11 would no longer be used there?
12
13 A No, not in those –
14
15 Q Were going up to 1987.
16
17 A 1987, previously they had said that they
18
19 wouldnt bring in anymore asbestos products but the
20 asbestos there would not be totally removed. Whatever
21
22 was contained would be contained. The only time it
23
24 would be removed is if it became a hazard.
25
163: 1 Q Do you remember when that announcement
2
3 was?
4
5 A That was shortly before, this was before 1986,
6
7 85, somewhere in there.
8
9 Q Do you know if at that time there were
10
11 still asbestos products that were stored in the central
12
13 storeroom that we discussed?
14
15 A Yes, there were.
16
17 Q Were those products subsequently used or
18
19 destroyed?
20
21 A They were still being used.
22
23 Q To the best of your knowledge, are those
24
25 asbestos products which were in the storeroom in the
164: 1
2 1986 period still being used at Public Service?
3
4 A I cant say they definitely are still there. I
5
6 dont know.
7
8 Q Do you know if it was the policy of Public
9
10 Service in 1985 to use the products that they had
11
12 purchased?
13
14 A No, I dont know their policy.
15
16 Q Do you have any knowledge of those
17
18 products, lets take it — you mentioned a product
19 called Super 3000?
20
21 A Thats correct.
22
23 Q Do you know if that product was still
24
25 being used in this 1985/1986 period where they made
165: 1
2 some sort of announcement?
3
4 A No, I cant definitely say if it was being used.
5
6 Q How about the gaskets that you had talked
7
8 about, do you know if those products were still being
9
10 used in 1985?
11
12 A They were being used.
13
14 Q Do you have any personal knowledge that
15
16 they were used after that time period?
17
18 A Yes.
19
20 Q They were being used?
21
22 A Yes.
23
24 Q And how did you acquire that information?
25
166: 1 A They were still in the storeroom, and in our
2
3 storeroom, yes.
4
5 Q Do you know that they were actually used?
6
7 A They were used, yes.
8
9 Q So let me understand this. After 1985 if
10
11 they had to replace a gasket that was previously an
12
13 asbestos gasket, they would replace that with an
14
15 asbestos gasket?
16
17 A I cant say that, you know, they would. I cant
18 definitely say they would.
19
20 Q Do you know if they would use any other
21
22 type of gaskets in those places where they formerly
23
24 used asbestos gaskets?
25
167: 1 A They had switched to just the plain metal type
2
3 gasket.
4
5 Q And do you know when that switch took
6
7 place approximately?
8
9 A No. I couldnt definitely say when it was
10
11 switched.
12
13 Q And how about the asbestos blankets, do
14
15 you recall if they were still there around this
16
17 1985/1986 time period?
18
19 A Yes, there were still some there.
20
21 Q Are they still being used today?
22
23 A We havent been using them. I dont know if
24
25 other people have. I havent seen much of them lately.
168: 1
2 Q And are you aware of any pipe coverings,
3
4 asbestos pipe coverings that are currently being stored
5
6 at Public Service?
7
8 A Im not aware if theyre definitely asbestos.
9
10 There is pipe coverings. The word we had gotten was
11
12 they were to use non-asbestos material.
13
14 Q And do you know when you got that word?
15
16 A Yes, the word was passed around that they would
17 start using the non-asbestos insulations.
18
19 Q And when would that be that that
20
21 announcement came out?
22
23 A That was three or four years ago.
24
25 Q Do you know if theres any Public Service
169: 1
2 rule against using asbestos products at this time?
3
4 A Yes, whenever we have a job now we — its a
5
6 major thing to stay away from asbestos.
7
8 Q And how long has that been the policy, to
9
10 your knowledge?
11
12 A Well, theyve been pushing it for the past three
13
14 years, Id say three to four years.
15
16 Q Okay. During this 25 years as a
17
18 technician, were your duties entirely confined except
19
20 for this three-month period to the Sewaren plant?
21
22 A Yes, except for that duration at Linden. We
23
24 also had a new station built which was Edison
25
170: 1 generating station and we had to go there occasionally.
2
3 It was considered part of Sewaren generating station in
4
5 that we had to maintain it.
6
7 Q When was that built?
8
9 A That was built in the later 60s.
10
11 Q Were you there during construction?
12
13 A Yes.
14
15 Q And what was your job during construction?
16 A We were checking out all new equipment that was
17
18 installed.
19
20 Q Do you believe you were exposed to any
21
22 asbestos or asbestos containing products at the Edison
23
24 generating station?
25
171: 1 A It was never defined. There wasnt that much
2
3 insulation out there. There was still insulation on
4
5 piping, and still blanket insulation around the gas
6
7 turbines, but it was more or less contained.
8
9 Everything was brand-new. Nobody had said it was
10
11 asbestos or it wasnt.
12
13 Q Well, do you know if it was?
14
15 A I definitely dont know.
16
17 Q You stated earlier that you noticed at
18
19 Sewaren deteriorating pipe covering; is that correct?
20
21 A Thats correct.
22
23 Q Did you notice that at Edison Generating
24
25 Station at any time?
172: 1
2 A Yes, along the pipelines, the oil pipelines.
3
4 Q And how many years after the station was
5
6 completed did you notice the problem with the oil pipe
7
8 line?
9
10 A It took a while. It took maybe five years or so
11
12 to really — unless, of course, they were worked on.
13
14 Q And I take it from that statement that you
15 were at the Edison Generating Station on occasions
16
17 other than just when it was being built; is that
18
19 correct?
20
21 A Thats correct. After it was running I was out
22
23 there.
24
25 Q About how often after it was running were
173: 1
2 you called on to go to the Edison Generating Station?
3
4 A Well, we had a regular station where it was my
5
6 turn about every 10, 12 weeks, something like that.
7
8 Q And when it was your turn, what would be
9
10 your duties over there at Edison?
11
12 A Mainly just to keep the engines running, keep
13
14 the controls working.
15
16 Q And while you were over there, do you
17
18 believe you were exposed to any asbestos or asbestos
19
20 products?
21
22 A I cant definitely say. There was piping but I
23
24 was never sure whether it was asbestos or not.
25
174: 1 Q Okay. Lets get back to Sewaren then. By
2
3 the way, back to Edison for a second. When it was your
4
5 turn how long would you be over at Edison?
6
7 A It was like one, two weeks. Sometimes it
8
9 extended. Mainly it was two weeks. Sometimes you were
10
11 extended to three. Depending on how vacations ran.
12
13 How many men we needed out there.
14 Q So by a little quick mathematics your turn
15
16 would come up three or four times a year?
17
18 A Thats correct.
19
20 Q And when you were over there at Edison,
21
22 was that a 40 hour week or was that overtime?
23
24 A That was overtime. It depended, sometimes it
25
175: 1 was 40 hours and sometimes it was overtime.
2
3 Q Back to Sewaren for a little while. As a
4
5 technician do you believe you were exposed to asbestos
6
7 in Sewaren?
8
9 A Right now?
10
11 Q At any time. We have a long period here
12
13 where you were a technician.
14
15 A Oh, yes, I definitely was exposed.
16
17 Q Okay. Lets see if we can organize this.
18
19 Lets go back to when you first became a technician.
20
21 In that first couple of years how were you exposed to
22
23 asbestos?
24
25 A The same way. Going into boilers. Replacing
176: 1
2 thermocouples. Working in the areas where maintenance
3
4 men were working. Working with the Flexitallic gaskets
5
6 and asbestos blankets.
7
8 Q At any time during your career as a
9
10 technician did you work with asbestos products that you
11
12 havent mentioned so far?
13 A If they were asbestos products I didnt know.
14
15 Q But my question is can you expand this
16
17 list of asbestos products that youve given us this
18
19 morning?
20
21 MR. PAULUS: Do you want brands,
22
23 manufacturers, types?
24
25 MR. BASIL: All Im talking about is the
177: 1
2 types. Are there any additional asbestos
3
4 products that you were exposed to that you
5
6 havent mentioned so far?
7
8 MR. FETTEN: Object to the form. Go
9
10 ahead.
11
12 MR. PAULUS: Do you understand the
13
14 question?
15
16 THE WITNESS: Im not sure I understand.
17
18 Q Okay. This morning weve mentioned five,
19
20 six or seven different types of asbestos products that
21
22 you were exposed to before you became a technician.
23
24 A Right.
25
178: 1 Q Now, you stated once you became a
2
3 technician you continued to be exposed to asbestos; is
4
5 that correct?
6
7 A Thats correct.
8
9 Q Im asking you if there are any additional
10
11 types of asbestos products that you were exposed to
12 after you became a technician?
13
14 MR. FETTEN: Object to the form. Go
15
16 ahead.
17
18 A No. I dont know of any other.
19
20 Q Okay. Now, as a technician how often
21
22 would you be going into boilers?
23
24 A The only time we went into the boilers as a
25
179: 1 technician was to replace the thermocouples.
2
3 Q And as a technician was replacement of
4
5 thermocouples done on a rotating basis?
6
7 A Not really. They just decided — the
8
9 supervisors and the foremen decided who they wanted to
10
11 put on the job.
12
13 Q And was there any particular time period
14
15 during your 25 years as a technician where you no
16
17 longer went in the boilers and replaced thermocouples?
18
19 A No, it was a constant — whenever the job came
20
21 up somebody had to go in there.
22
23 Q So in 1987, your last year, you were still
24
25 going into boilers and replacing thermocouples?
180: 1
2 A I dont remember the last year I was in the
3
4 boiler, but it would have been a technicians job to go
5
6 in there.
7
8 MR. PAULUS: I think he really wants to
9
10 know do you recollect the last time that you
11 went into the boiler to replace the
12
13 thermocouples? You, yourself, if you can
14
15 remember that. Dont worry about other
16
17 technicians.
18
19 THE WITNESS: Not –
20
21 MR. PAULUS: Not other technicians, you.
22
23 When was the last time you did it?
24
25 THE WITNESS: That was back in the early
181: 1
2 60s.
3
4 MR. PAULUS: That was the last time you –
5
6 THE WITNESS: That Ive gone in to replace
7
8 them?
9
10 MR. PAULUS: Yes.
11
12 THE WITNESS: Thats as a technician.
13
14 MR. PAULUS: But you went in other times?
15
16 THE WITNESS: But we didnt get to that
17
18 yet.
19
20 Q Lets see if I can sum that up. So as a
21
22 technician you only replaced thermocouplers up to the
23
24 mid 60s lets say; is that correct?
25
182: 1 A Yes, me personally I would say.
2
3 Q Okay. You personally. And when you would
4
5 go into the boiler to replace thermocouplers how long
6
7 would that take?
8
9 A Sometimes it would take six or seven hours.
10 Q Sometimes it would take less?
11
12 A Sometimes less.
13
14 Q Depending on how many thermocouplers there
15
16 were?
17
18 A Thats correct.
19
20 Q And as a technician were you called on to
21
22 work in areas where the maintenance men were performing
23
24 the work we had described earlier on the pipes?
25
183: 1 A Yes.
2
3 Q And what would you be doing?
4
5 A Working on the controls around the heaters, feed
6
7 water heaters, boiler feed pumps.
8
9 Q Can you tell us how often you would be
10
11 working in the area of these maintenance men when they
12
13 were doing pipe covering work?
14
15 A You could be there a full todays work in the
16
17 same area that they would be working next to you.
18
19 Q Again, as a technician would you be
20
21 wearing a mask?
22
23 A Yes, when it got real dusty.
24
25 Q Which is whenever you felt personally that
184: 1
2 it was getting dusty?
3
4 A Thats correct.
5
6 Q And as a technician did you ever work with
7
8 the asbestos blankets we described earlier?
9 A Yes.
10
11 Q How did you do that? How did you work
12
13 with the asbestos blankets?
14
15 A Well, we worked on some units when it was real
16
17 hot. In order to get near the equipment we had to put
18
19 the asbestos blankets against the casting or whatever
20
21 in order to keep the heat so we could get close enough
22
23 to stand there for a certain period of time.
24
25 Q As a technician did you ever go to the
185: 1
2 central storeroom?
3
4 A Yes.
5
6 Q And Im going to ask you during this time
7
8 period that you were a technician did you have occasion
9
10 to see the asbestos products of any manufacturers you
11
12 havent mentioned before?
13
14 A Not of any other ones.
15
16 Q Okay. And would that also include
17
18 asbestos products that were stored outside of the
19
20 storeroom?
21
22 A Yes, that would. The same products were stored
23
24 outside that I mentioned, that I knew of.
25
186: 1 Q Lets go for the entire span then. The
2
3 whole time you were working at Sewaren are there any
4
5 additional manufacturers products that youre aware of
6
7 on the plant that you havent mentioned so far?
8 A No. Ive been in different boilers but as far
9
10 as materials –
11
12 Q By the way, do you know who made those
13
14 boilers?
15
16 A Combustion Engineering did four of them and I
17
18 believe Babcock & Wilcox did No. 5 unit boiler.
19
20 Q These are all at Sewaren; is that correct?
21
22 A Thats correct.
23
24 Q And how about at Linden, do you know who
25
187: 1 did those boilers?
2
3 A No, I cant say I definitely knew because I
4
5 wasnt involved in too much of the boiler work.
6
7 Q Were you there when any of these boilers
8
9 were being manufactured?
10
11 A When they were being repaired?
12
13 MR. PAULUS: At Edison.
14
15 Q No. The five boilers you mentioned were
16
17 at Sewaren; is that correct?
18
19 A Thats correct.
20
21 Q And these were who built the boilers?
22
23 A Thats correct.
24
25 Q Were you there when any of those were
188: 1
2 originally built?
3
4 A I started there in 1951. They were just
5
6 completing No. 4 but that was mainly — the boiler was
7 up already.
8
9 Q And how about No. 5?
10
11 A No. 5 I was there during the duration of the
12
13 building since they started, yes.
14
15 Q Do you know when that was built?
16
17 A That was built somewhere around 1963.
18
19 Q Did you have any part in that construction
20
21 work?
22
23 A No, not in the construction work, just checking
24
25 instruments that were installed, thats basically it.
189: 1
2 Q Did Combustion Engineering ever come back
3
4 to do work on the boiler after the original work was
5
6 done?
7
8 A Yeah, on an occasional outage they hired outside
9
10 companies to come in and repair the boilers.
11
12 Q Do you know when that was?
13
14 A Well, it was periodically. I cant remember the
15
16 exact dates. If it was like a massive repiping,
17
18 retubing job in the boiler, and they didnt feel that
19
20 we had enough time to get it done during outage, they
21
22 would hire outside units.
23
24 Q Do you remember the names of any other
25
190: 1 outside units?
2
3 A No, Combustion Engineering was the main, as far
4
5 as I remember, builder for Public Service.
6 Q Do you recall any other outside
7
8 contractors who came onto the Public Service facility
9
10 to do work with asbestos products?
11
12 A This is again during the period of technician?
13
14 Q Well, lets take it for your whole time
15
16 make it easier on you. Can you remember any other
17
18 outside contractors who came onto the grounds of Public
19
20 Service to do work with asbestos products?
21
22 A Up until the present day?
23
24 Q Up until yesterday.
25
191: 1 A Assured Asbestos Abatement.
2
3 Q Any others?
4
5 A There might have been others but I –
6
7 Q Any others that you recall?
8
9 A No, because I wasnt directly associated with
10
11 any.
12
13 Q And what kind of project is Assured
14
15 Asbestos Abatement doing?
16
17 A Asbestos removal.
18
19 Q Did you have any part of that operation
20
21 that you were responsible for?
22
23 A I was supervisor for our part of the job.
24
25 Q Ill come back to that when I get to
192: 1
2 supervisor, all right?
3
4 A Okay.
5 Q During the time you were a technician, did
6
7 you work with any other toxic substances that you
8
9 havent mentioned?
10
11 A Chlorine.
12
13 Q What would you do with chlorine?
14
15 A We have a chlorine system that chlorinates the
16
17 water going into the condensors to kill any allergy,
18
19 fungus or impurities.
20
21 Q And how do you work with it?
22
23 A Well, we handle the instrumentation.
24
25 Q As a technician were you exposed to
193: 1
2 chlorine at all?
3
4 A There were times when we were exposed if we had
5
6 to change a chlorine tank or if we came in contact with
7
8 a leak.
9
10 Q Do you recall leaks?
11
12 A Yes.
13
14 Q Do you ever recall a major leak?
15
16 A No, nothing major, just a minor leak. A lead
17
18 gasket leaking.
19
20 Q Did you wear facial protection when you
21
22 worked on the leaks?
23
24 A They never said it was mandatory up until
25
194: 1 recently, recently you have to use a Scott air pack if
2
3 you go into the chlorine contaminated area.
4 Q Previously when you worked on the chlorine
5
6 leaks did you yourself have a mask on?
7
8 A Ive had masks on on occasion, yes.
9
10 Q Sometimes you did and sometimes you
11
12 didnt?
13
14 A Thats correct. When I knew there was a leak I
15
16 had one on.
17
18 Q Let me ask you again about overtime as a
19
20 technician. Lets take the 80s, your last seven years
21
22 as a technician, did you work much overtime?
23
24 A No, during that period the overtime for some
25
195: 1 reason was squashed down. We didnt work too much
2
3 overtime.
4
5 Q It wasnt available?
6
7 A It wasnt available.
8
9 Q How about in the 70s as a technician?
10
11 A The 70s it was available, yes.
12
13 Q Did you work a lot of overtime?
14
15 A Yes.
16
17 Q And how about in the 60s?
18
19 A In the 60s, yes.
20
21 Q And your duties as a technician, did they
22
23 take you through the entire Sewaren plant?
24
25 A Yes, the entire plant.
196: 1
2 Q Is there any particular areas you were in
3 more often than others?
4
5 A Yeah, we were mostly concerned about the feed
6
7 water heaters up on the boiler working on the oxygen
8
9 analyzers.
10
11 Q And can you approximate for me the amount
12
13 of time in the average week you would be up by the feed
14
15 water heaters?
16
17 A Well, maybe for a day during the week. Whenever
18
19 they had trouble with the controls wed try to adjust
20
21 the controls to maintain the levels.
22
23 Q Was there any particular asbestos exposure
24
25 when you were working on the water feed, Im sorry, the
197: 1
2 feed water heater?
3
4 A Yes, that was the area where I previously stated
5
6 that there was a lot of piping with asbestos material
7
8 around it and leaking valves with asbestos packing.
9
10 Q Lets confine this to your bargaining unit
11
12 time.
13
14 A Okay.
15
16 Q Do you recall safety meetings being held
17
18 at Public Service by management?
19
20 A Yes, they used to have a safety meeting once a
21
22 month.
23
24 Q Did you attend?
25
198: 1 A Yes, it was mandatory. You had to attend, you
2 had to sign the sheet if you were at work that day.
3
4 Q Do you recall asbestos problems being
5
6 discussed at any of these safety meetings when you were
7
8 a technician?
9
10 A Not until probably after 1985 somewhere.
11
12 Q So there would have been something
13
14 mentioned in 1985 or 1986, is that your recollection?
15
16 A Yeah, we had — well, it seemed that all of a
17
18 sudden everybody became aware of asbestos. The union,
19
20 you know, knew that asbestos was around.
21
22 Q And do you remember what was said at any
23
24 of these safety meetings?
25
199: 1 A Well, they prescribed wearing different –
2
3 instead of the dust masks there were respirators and
4
5 different cartridges. If you went into a dusty area,
6
7 one cartridge, a chemical area, another cartridge,
8
9 asbestos, another cartridge.
10
11 Q Did they ever mention the type of health
12
13 problems that were associated with asbestos?
14
15 A Yes. They would relate — they would give us
16
17 questionnaires to fill out when we took our annual
18
19 X-rays.
20
21 Q But my question was did they tell you of
22
23 any particular health problem that were associated with
24
25 asbestos?
200: 1 A Well, they just said asbestos wasnt good for
2
3 you, you know, try to stay away from it, protect
4
5 yourself if you go into those areas.
6
7 Q They didnt mention any problem in
8
9 particular that you recall?
10
11 A Well, they mentioned it being cancerous,
12
13 possible cancerous reactions from it.
14
15 Q Do you remember if they said any
16
17 particular kind of cancer?
18
19 A I dont know, I dont know the exact name that
20
21 they mentioned. Some big long medical term.
22
23 Q Okay. Other than the management safety
24
25 meetings did the union give out any information on
201: 1
2 asbestos?
3
4 A Yes. The union used to notify us occasionally
5
6 at meetings, the union is actually the one who made us
7
8 aware of the asbestos before any management really did.
9
10 Q And when would that have been, do you
11
12 recall?
13
14 A That was like around 1984, 84, 85, in that
15
16 area.
17
18 Q And do you remember the information they
19
20 gave out in that time period?
21
22 A There was one little pamphlet they passed around
23
24 but I dont recall now what exactly was in there. They
25 said that asbestos has been in industrial use for quite
202: 1
2 a long time, but nobody ever, you know — we werent
3
4 really abreast of what — how bad it was. It was more
5
6 or less kept secret from people that worked around it.
7
8 Q At the time you received that pamphlet
9
10 were you, yourself, experiencing any health problems?
11
12 A At that time, what particular kind of health
13
14 problems are you talking about?
15
16 Q About any health problems that you
17
18 personally relate to asbestos exposure.
19
20 A Not — I wasnt experiencing anything at that
21
22 time.
23
24 Q When was the first time you experienced a
25
203: 1 problem that you related to asbestos exposure?
2
3 A Well, I was brought aware of it when I went for
4
5 a visit to Dr. Valez.
6
7 Q And when was that, if you recall?
8
9 A It was about April 5 1986.
10
11 Q Well call it 86. Before Dr. Valez, had
12
13 any other doctor examined you for any of the complaints
14
15 youve made about breathing?
16
17 A Well, Ive — I had X-rays taken, lung X-rays
18
19 taken by Public Service. I had lung X-rays taken by my
20
21 own doctor. Nobody was ever aware of asbestosis. They
22
23 didnt say I had anything.
24 Q When you got that pamphlet from the union,
25
204: 1 did you relate any of your health problems to asbestos?
2
3 A Well, there were certain things they said in
4
5 there like shortness of breath, you know, if you had
6
7 asbestos the shortness of breath and sleeping on two
8
9 pillows and that, you know, that sort of thing. They
10
11 mentioned wheezing.
12
13 Q And were those problems you were having at
14
15 that time?
16
17 A Yes, I had those problems at that time.
18
19 Q And as a result of getting that pamphlet
20
21 did you seek any medical treatment?
22
23 A Well, thats when I went to Dr. Valez.
24
25 Q There seems to be a little gap in there.
205: 1
2 You stated you went to Dr. Valez in 1986?
3
4 A Well, I had been going to my regular doctor, Dr.
5
6 Senz periodically but nothing — I had trouble, you
7
8 know, respiratory problems.
9
10 Q Did you ever bring up to Dr. Senz the fact
11
12 that you had worked with asbestos before you went to
13
14 Dr. Valez?
15
16 A I cant say I definitely mentioned it to him,
17
18 no.
19
20 Q When you went to see Dr. Valez did you
21
22 mention to him that you worked with asbestos?
23 A Yes.
24
25 Q While you worked at Public Service, what
206: 1
2 was the name of the union you belonged to?
3
4 A IBEW. Local Union 1673.
5
6 Q And were you ever an officer in that
7
8 union?
9
10 A Shop steward.
11
12 Q What years were you a shop steward?
13
14 A Mostly from the early 60s up until the early
15
16 80s.
17
18 Q While you were a shop steward do you
19
20 recall any complaints being made to management
21
22 concerning dusty conditions at Public Service?
23
24 A Yes.
25
207: 1 Q And when would be the first time you
2
3 remember a complaint was made concerning dust at Public
4
5 Service?
6
7 A Well, the first time — I dont know exactly the
8
9 first time. I cant pinpoint the date on the first
10
11 time.
12
13 Q Would it have been in the 60s that
14
15 complaints were being made?
16
17 A No, Id say probably later than that.
18
19 Q In the 70s?
20
21 A The 70s.
22 Q During any time when you were a shop
23
24 steward do you recall any complaints being made to
25
208: 1 management concerning asbestos?
2
3 A No. It wasnt that frequent. They werent
4
5 complaining at that time. Afterward I was a shop
6
7 steward.
8
9 Q But there were complaints about dust?
10
11 A Yes.
12
13 Q Was anything ever done by management in
14
15 response to those complaints?
16
17 A Just they tried to tell you more to wear your
18
19 dust mask, thats all.
20
21 Q Were there any dust containing measures
22
23 ever taken at Public Service?
24
25 A Not that Im aware of.
209: 1
2 Q Did your union ever put out publications,
3
4 magazines, newspapers?
5
6 A We used to get a magazine once a month from the
7
8 IBEW, thats all.
9
10 Q Do you remember if there were ever
11
12 articles about asbestos in that magazine?
13
14 A I dont remember definitely.
15
16 Q Did you read the magazine every month?
17
18 A Not that much.
19
20 Q Im going to read some names to you, I
21 want you to tell me if you recognize them and tell me
22
23 from where if you do, all right, sir?
24
25 A Sure.
210: 1
2 Q How about Vincent Chesnowski?
3
4 A No.
5
6 Q How about Casper Damoci?
7
8 A Sewaren Generating Station, yes.
9
10 Q What years do you remember Mr. Damoci at
11
12 Sewaren?
13
14 A He was probably there in the 60s I imagine.
15
16 Q How about after the 60s, do you remember
17
18 him?
19
20 A No, he retired from there for some reason, but I
21
22 dont exactly remember what year.
23
24 Q Do you ever work with Mr. Damoci?
25
211: 1 A I may have, there were times we might have been
2
3 close, not work with him, I might have been near him
4
5 but not work with him.
6
7 Q Do you know what his job was?
8
9 A He was in the maintenance department.
10
11 Q Do you know if you ever observed Mr.
12
13 Damoci working on the pipes that you described?
14
15 A Yeah, that was part of his job. He worked on
16
17 the piping.
18
19 Q Do you specifically recall him working on
20 those pipes or was it just that he was a maintenance
21
22 man?
23
24 A Yeah, Im associating him with part of the job.
25
212: 1 Q So no specific recollection of Mr. Damoci
2
3 working on the pipes?
4
5 A I wouldnt remember. I see guys all over the
6
7 place.
8
9 Q Okay. How about William Frank?
10
11 A No.
12
13 Q How about Robert Hedinger?
14
15 A No.
16
17 Q Otto Jensen?
18
19 A Otto Jensen. I remember — I dont know if its
20
21 the same Jensen. I remember a real old timer when I
22
23 first started working there, his name was Jensen. If
24
25 thats the guy, I dont know.
213: 1
2 Q I assure you I dont.
3
4 A I think he had the same name. It could have
5
6 been.
7
8 Q Do you know what Mr. Jensen did?
9
10 A Mr. Jensen was in the maintenance department.
11
12 The Jensen that I know.
13
14 Q Do you recall specifically working in an
15
16 area where Mr. Jensen was doing his job?
17
18 A If its the same man, you know, Im not saying
19 its the same guy, but I did work with a man by the
20
21 name of Otto Jensen and the name seems to strike me
22
23 that I had worked very closely with him if it is the
24
25 same Otto Jensen.
214: 1
2 Q If it is the same Otto Jensen, do you
3
4 recall working with him with asbestos products?
5
6 A At that time we were working with forced draft
7
8 fan dampers and we were cleaning out the bottom of the
9
10 fan hoppers.
11
12 Q Well, since I dont work there, would that
13
14 involve asbestos products?
15
16 A Yes. Well, it would involve collecting all the
17
18 dust coming out of the boiler.
19
20 Q Okay.
21
22 A The induced draft fans pull all the gases and
23
24 dust out of the boiler and the buildup in the bottom of
25
215: 1 the fan.
2
3 Q How would you go about collecting the dust
4
5 out of the bottom of the fan?
6
7 A You go in and fill pans and pass it out.
8
9 Q With a shovel?
10
11 A With a shovel, scoopers, anything just to get it
12
13 out of there. There wasnt that much area to have a
14
15 large shovel is what Im saying.
16
17 Q Do you remember wearing a mask when you
18 did that function?
19
20 A Yeah, occasionally we wore masks.
21
22 Q Does that mean occasionally you didnt
23
24 wear a mask?
25
216: 1 A Yes.
2
3 Q How about Stephen Kieran?
4
5 A No.
6
7 Q John Lee?
8
9 A Well, I — if I remember Jackie Lee, I think his
10
11 real name might have been John. I remember a Jackie
12
13 Lee who worked at Sewaren and Linden. Everybody called
14
15 him Jackie.
16
17 Q Do you remember Mr. Lees job?
18
19 A He was in the maintenance department.
20
21 Q Did you ever work alongside of Mr. Lee?
22
23 A I cant say I worked directly alongside him. I
24
25 was in the area.
217: 1
2 Q Do you have a recollection of Mr. Lee
3
4 working with any asbestos products?
5
6 A Yes.
7
8 Q Do you remember that specifically?
9
10 A Yes. It was on the insulation.
11
12 Q On the pipe job we talked about?
13
14 A Pipe, yes.
15
16 Q And how about William Ligus.
17 MR. PAULUS: Ligus.
18
19 Q Ligus, does that help you?
20
21 A No.
22
23 Q How about Andrew Stevenson?
24
25 A No.
218: 1
2 Q How about George Kokoszczenski?
3
4 A No.
5
6 Q Not by that name anyhow. How about John
7
8 Bukowski?
9
10 A John Bukowski. He was in the maintenance
11
12 department.
13
14 Q At Sewaren?
15
16 A At Sewaren.
17
18 Q Do you remember Mr. Bukowski working with
19
20 asbestos products?
21
22 A Yes, basically they all had the same type boiler
23
24 repair jobs.
25
219: 1 Q How about John Kudrich?
2
3 A Yes, he was in the maintenance department at
4
5 Sewaren.
6
7 Q And you have a recollection of him working
8
9 with asbestos products?
10
11 A Yes.
12
13 Q In the same function as the other
14
15 gentlemen?
16 A Thats correct.
17
18 Q And Victor Monticello?
19
20 A Yes, he worked Sewaren.
21
22 Q And what was his position?
23
24 A He was in the maintenance department. He
25
220: 1 started — he was in operations as I was. We worked
2
3 together on the same shift. Same boiler we went up
4
5 into and he transferred to the maintenance department.
6
7 Q And do you have a recollection of Mr.
8
9 Monticello working with the pipes?
10
11 A Yes.
12
13 Q In the same way that the other gentlemen
14
15 did?
16
17 A Yes.
18
19 Q And how about George Nimetz?
20
21 A Yes, George Nimetz was also in the maintenance
22
23 department.
24
25 Q And do you have a specific recollection of
221: 1
2 him working with asbestos products?
3
4 A Yes, I did.
5
6 Q How about John Williams?
7
8 A I dont know.
9
10 Q Donald MacDonald?
11
12 A Donald MacDonald? There was — I dont know, I
13
14 cant say for sure. He my have been at Linden station.
15 The name sounds familiar, but I dont know.
16
17 Q How about John Wayton?
18
19 A No.
20
21 Q John Dmytryk?
22
23 A No.
24
25 Q Frank Dragotta?
222: 1
2 A Yes.
3
4 Q And what was his position?
5
6 A Mr. Dragotta, he was in the operating
7
8 department. He was in the storeroom and recently until
9
10 he retired he was a maintenance man. In fact, he was
11
12 in charge of the storeroom.
13
14 Q Do you know about what years he was in
15
16 charge of the storeroom?
17
18 A It was a very short period of time because he
19
20 had a heart attack. He couldnt take the stress of the
21
22 job. I would say that was in the 70s.
23
24 Q Do you recall Mr. Dragotta being employed
25
223: 1 somewhere else at Sewaren before he was in the
2
3 storeroom?
4
5 A He was an operator on the shift.
6
7 Q What is an operator?
8
9 A Equipment operator. See, theres equipment
10
11 operators, first class operator. Theres different
12
13 phases of it, but I know he was in the operator
14 department. He was brought originally from the Perth
15
16 Amboy Station when Sewaren opened up.
17
18 Q How about James Kadlac?
19
20 A Yes, he works in the storeroom right now. He
21
22 used to be in the operations also.
23
24 Q Benjamin Parsons?
25
224: 1 A Yes.
2
3 Q What does he do?
4
5 A We worked together in operations. And he went
6
7 to the maintenance department.
8
9 Q What were you doing in operations when you
10
11 worked with Mr. Parsons?
12
13 A Cleaning out the boiler.
14
15 Q Anything else?
16
17 A Well, that was on the outage. The other times
18
19 we were just doing our regular operating job.
20
21 Equipment operator job.
22
23 Q What period of time were you an equipment
24
25 operator, is that the same as a technician?
225: 1
2 A No, that was the period of time from when I
3
4 started until I went into the service and the two
5
6 months in between there we were transferred over to the
7
8 maintenance department to help them out.
9
10 Q How about Stephen Garvey?
11
12 A No.
13 Q Gilbert Fehn?
14
15 A No.
16
17 Q Frank Litsas?
18
19 A Frank Litsas. He was in the storeroom.
20
21 Q At Sewaren?
22
23 A Yes. Thats when I remember him. He
24
25 transferred to other stations, but I dont know.
226: 1
2 Q Do you know the period of time were
3
4 talking about when he was in the storeroom at Sewaren?
5
6 A He was there, I believe when I first started
7
8 there he was in the storeroom in the late 50s, early
9
10 60s.
11
12 Q And George Oakes?
13
14 A No.
15
16 Q After you were through with your career as
17
18 a technician in 1987, what was your next job?
19
20 A Instrument supervisor.
21
22 Q Are you still an instrument supervisor
23
24 today?
25
227: 1 A Thats correct.
2
3 Q As an instrument supervisor do you believe
4
5 you were exposed to any asbestos or asbestos containing
6
7 products?
8
9 A Yes.
10
11 Q By the way, instrument supervisor is not a
12 bargaining unit job; is that correct?
13
14 A Thats correct.
15
16 Q Youre now a member of management;
17
18 correct?
19
20 A Correct.
21
22 Q What asbestos-containing products do you
23
24 believe youve been exposed to as an instrument
25
228: 1 supervisor?
2
3 A I dont know the products names, but its the
4
5 old insulation that was left on the boiler and the
6
7 piping since Ive been supervisor.
8
9 Q So your exposure is limited to the
10
11 boilers; is that correct?
12
13 A The boilers and just, you know, walking around
14
15 in general, whenever theyre taking asbestos down.
16
17 They still have periods where they remove asbestos, but
18
19 now its more contained.
20
21 Q Let me ask you, the removal of asbestos,
22
23 is that done by Public Service employees or by outside
24
25 contractors?
229: 1
2 A Both.
3
4 Q And one of these outside contractors was
5
6 the one you mentioned earlier?
7
8 A Yeah. Thats the only one Im sure of because I
9
10 was directly attached to them. There have been others,
11 but I dont recall the names of the others.
12
13 Q Lets talk about the old insulation in the
14
15 boilers, how do you believe you were exposed to that
16
17 insulation as a supervisor?
18
19 A Well, we had a job to replace some more
20
21 thermocouples just within the past month or so and
22
23 samples were taken of the compartment we had to go into
24
25 and it was analyzed as 25 percent amosite and 10
230: 1
2 percent crimosite.
3
4 Q And where did that material come from?
5
6 A It came from pieces of the insulation that were
7
8 on the walls and on the floor of that compartment and
9
10 on the tubing.
11
12 Q Youre talking about in the boiler?
13
14 A Yes.
15
16 Q Did you, yourself, remove this sample or
17
18 was that removed by other employees?
19
20 A No, we have an industrial hygienist that does
21
22 it. Anybody can do it. If youre not sure its
23
24 asbestos you send it out to be analyzed.
25
231: 1 Q Let me ask you as a supervisor how many
2
3 times have you been inside of a boiler?
4
5 A Maybe once, thats about it.
6
7 Q And how long did you stay in?
8
9 A Not very long, two minutes until I recognized
10 what was in there.
11
12 Q Now, you stated that you had some
13
14 supervisory responsibility during the removal of
15
16 asbestos; is that correct?
17
18 A Well, presently. Alls I did was tell the
19
20 asbestos company what had to be removed.
21
22 Q Did you observe them?
23
24 A Did I observe them move? No, I didnt.
25
232: 1 Q How about the Public Service employees
2
3 that removed asbestos, did you ever observe them?
4
5 A Yes.
6
7 Q What sort of employees removed asbestos at
8
9 Public Service?
10
11 A Mostly in the maintenance department. We also
12
13 have the force they call central maintenance which is
14
15 located right next door to us and they do that type of
16
17 work also.
18
19 Q And about how much time did you spend
20
21 observing the Public Service employees removing
22
23 asbestos?
24
25 A I dont spend that much time in that area.
233: 1
2 Q Less than an hour?
3
4 A Very less. In fact, they rope everything off.
5
6 You cant really get near the place if you wanted to.
7
8 Q You stated that earlier as a technician,
9 as a technicians helper you had noticed asbestos
10
11 falling from the pipes that were deteriorating; isnt
12
13 that correct?
14
15 A Thats correct.
16
17 Q Do you still notice that?
18
19 A Not so much now. Occasionally you will. Its
20
21 like its more kept after now. Now you have a tendency
22
23 anybody in the plant reports it you know theres
24
25 insulation falling down.
234: 1
2 Q Was there a particular time when you saw
3
4 this reduction in the amount of falling material from
5
6 the pipe?
7
8 A Well, recently, like I say, its been kept
9
10 after. Within the past three or four years.
11
12 Q As a supervisor do you work a 40-hour
13
14 week?
15
16 A Sometimes 40, sometimes more.
17
18 Q Within the past year have you been working
19
20 overtime?
21
22 A Just within the past two months mainly.
23
24 Q And about how much time do you work per
25
235: 1 week in the last two months?
2
3 A Sometimes I work my normal 40 hours. Maybe one
4
5 night a week, two nights a week and an occasional
6
7 Saturday.
8 Q When you say one or two nights a week?
9
10 A Till 10 oclock at night.
11
12 Q Which is how many hours extra?
13
14 A Six hours extra.
15
16 Q So its a 14-hour day?
17
18 A Yes.
19
20 Q Are you aware of any other employees at
21
22 Public Service that suffer — that have
23
24 asbestos-related health problems?
25
236: 1 A That have asbestos-related health problems?
2
3 Q To your knowledge.
4
5 A Yes.
6
7 Q You do know other employees?
8
9 A That have told me they believe they have
10
11 asbestos problems.
12
13 Q And can you tell us who those employees
14
15 are?
16
17 A Well, we mentioned some of them. We mentioned
18
19 Victor Monticello. We mentioned Benjamin Parsons, and
20
21 the other two are Stephen Brust and Mike Choma.
22
23 Q Can you spell the last name?
24
25 A C-h-o-m-a.
237: 1
2 Q Any others?
3
4 A No, thats about it.
5
6 Q Okay.
7 A Thats just, you know, outside of the ones that
8
9 were mentioned before.
10
11 Q Well, the ones that were mentioned before?
12
13 A The ones that you brought up that I said I knew,
14
15 okay, these I believe werent brought up.
16
17 Q Well, let me assure you I didnt have a
18
19 list of people who I thought were suffering from
20
21 asbestos-related disease. Any of the other ones that
22
23 were brought up, do you have any knowledge of them
24
25 suffering from an asbestos-related disease?
238: 1
2 A As far as I know Benjamin Parsons and Victor
3
4 Monticello.
5
6 Q And how did you hear about Benjamin
7
8 Parsons?
9
10 A We discussed it in general amongst ourselves.
11
12 Q From Mr. Parsons himself you heard it?
13
14 A Yes.
15
16 Q Do you know when that was?
17
18 A That was shortly after we went for the testing
19
20 to see if we had it.
21
22 Q After you went to Dr. Valez or before
23
24 that?
25
239: 1 A After we went to see Dr. Valez.
2
3 Q And how about Mr. Monticello?
4
5 A The same.
6 Q Any discussion with him after you had seen
7
8 Dr. Valez?
9
10 A Thats correct.
11
12 Q How is it you came to see Dr. Valez?
13
14 A Well, the union said that we were working with a
15
16 lot of asbestos and it probably would be for the
17
18 benefit of us to be checked on it to see whether we did
19
20 have it or we didnt have it or whatever.
21
22 Q So shortly after that you went to see Dr.
23
24 Valez –
25
240: 1 A Thats correct.
2
3 Q Did anyone refer you to him?
4
5 A Just the union said, you know, Dr. Valez.
6
7 Q When was the first time you became aware
8
9 that asbestos might be hazardous to anybodys health,
10
11 not just your own?
12
13 A Well, when I, like I said, previously when I
14
15 received that pamphlet from the union.
16
17 Q That was the first time?
18
19 A First time I ever paid any, you know, attention
20
21 to it. Otherwise I might have heard it but it just
22
23 bypassed me.
24
25 Q And when was the first time that you
241: 1
2 linked any health problem of yours to asbestos?
3
4 MR. PAULUS: Do you understand the
5 question?
6
7 A That I linked –
8
9 Q When was the first time you came to the
10
11 conclusion that you had a problem that was caused by
12
13 asbestos?
14
15 A Well, I didnt come to the conclusion myself.
16
17 Dr. Valez, he said that, you know, I have an asbestos
18
19 problem.
20
21 Q Okay. You mentioned way back this morning
22
23 that you were taking two different kinds of medication,
24
25 a blood pressure pill and a water pill; is that
242: 1
2 correct?
3
4 A Thats correct.
5
6 Q Within the past year have you taken any
7
8 other prescription drugs?
9
10 A Within the past year, yes. I had a leg
11
12 infection. I cant remember exactly the name. One of
13
14 them said something Bufferin or something like that.
15
16 Q Was this Dr. Senz?
17
18 A Yes.
19
20 Q Anything other than the leg infection?
21
22 A No, I havent had any problems outside of that.
23
24 Q And as you sit here today do you have any
25
243: 1 complaints about your current state of health?
2
3 A Yes, I do. Like I said, I have trouble sleeping
4 at night. I feel more agitated or more edgy. I do
5
6 have a shortness of breath. I definitely have to sleep
7
8 with either two pillows or the pillow on top of my arm
9
10 with my head on top of the pillow, and I dont get the
11
12 right amount of sleep that I should.
13
14 I have a very restless night, and outside
15
16 of feeling listless, I dont have any energy and the
17
18 ambition that I had say four or five years ago.
19
20 Q By the way, do you have any other
21
22 complaints or is that just about it?
23
24 A You mean physical complaints?
25
244: 1 Q Physical complaints.
2
3 A No, thats about it.
4
5 Q Do you have any mental complaints?
6
7 A Mental? I could be under stress, you know,
8
9 thinking. I know definitely that right after I went to
10
11 see Dr. Valez I was very emotional and it really upset
12
13 me and I had to go to the doctor and he told me my
14
15 blood pressure was up, and I had to go on blood
16
17 pressure medication. Up until that time I had periods
18
19 of high blood pressure but I was able to control it.
20
21 After that Ive been totally on blood pressure
22
23 medication.
24
25 Q You say that after you spoke to Dr. Valez
245: 1
2 you were very upset. Are you still upset about your
3 diagnosis?
4
5 A Thats correct. Every time I think about it I
6
7 keep thinking Im on the edge of cancer of the lungs or
8
9 something like that.
10
11 Q Well, let me ask you, do you have a fear
12
13 of getting cancer?
14
15 A Yes, definitely.
16
17 Q And thats lung cancer or just any kind of
18
19 cancer?
20
21 A Lung cancer and he also said you could have
22
23 cancer of the intestines or colon which I was checked
24
25 for also by Dr. Valez.
246: 1
2 Q And have you mentioned your fear of cancer
3
4 to any other doctors?
5
6 A Well, I mentioned it to my own doctor, that I
7
8 have asbestosis, and he knew the same thing, you know,
9
10 there was a fear of cancer.
11
12 Q Did he do anything for you, give you any
13
14 treatment or medication?
15
16 A No, he didnt give me any type of medication.
17
18 He just said try to control yourself, you know, keep
19
20 your blood pressure down.
21
22 Q Let me ask you, you gave me really five
23
24 complaints, physical complaints. There was trouble
25
247: 1 sleeping, that you were edgey, that you have shortness
2 of breath, that you have lack of energy, and that your
3
4 blood pressure went up after you found out.
5
6 Do you recall if any of these, well call
7
8 them complaints, came about first? Did you first have
9
10 shortness of breath or did you first have trouble
11
12 sleeping or did you first have a lack of energy? Do
13
14 you remember if one of those came on before the others?
15
16 A No, because I was always active, very active.
17
18 Q So your recollection is they all came on
19
20 about the same time?
21
22 A Shortly after each other, yes.
23
24 Q When was the first time you noticed some
25
248: 1 of these problems?
2
3 A I dont know the exact date, you know, its just
4
5 my overall general feeling just went down the drain.
6
7 Q Well, lets take five years ago. Five
8
9 years ago were you having any of these problems?
10
11 A Five years ago, 1984, no, not really. I might
12
13 have been tired but that could have been from working
14
15 too much. The blood pressure was under control then.
16
17 I didnt have any problems.
18
19 Q Lets talk about shortness of breath.
20
21 When do you get short of breath?
22
23 A Sometimes when I just get excited or if I
24
25 overexert myself. Sometimes I can smell a cigarette
249: 1 and Ill gag. There are periods of time where I have
2
3 to get out into the fresh air like immediately.
4
5 Q Can you tell me when the first time you
6
7 remember that happening was?
8
9 A Remember that happening the first time?
10
11 Q When you became short of breath over some
12
13 episode.
14
15 A Yeah. It was one time when we visited my son
16
17 down in Maryland. We were walking through Washington
18
19 and I had to stop. I couldnt catch my breath.
20
21 Another time is when I climbed to the top of a fuel oil
22
23 tank out at Sewaren Station and I got up there and
24
25 there were fumes up there and I had a hard time getting
250: 1
2 my breath. I mentioned that to Dr. Senz and he said
3
4 well, youre overexerting yourself. You shouldnt be
5
6 climbing 50 foot oil tanks.
7
8 Q Was this before you saw Dr. Valez?
9
10 A No, this was after I saw Dr. Valez.
11
12 Q How about the trip to Washington?
13
14 A After, this was after.
15
16 Q And when do you remember first needing two
17
18 pillows to sleep?
19
20 A That was only like within the past four or five
21
22 years because normally I used to sleep without a pillow
23
24 at all, pillows used to bother me to a certain extent.
25 Id sweat too much. I just didnt use a pillow that
251: 1
2 often.
3
4 Q And why is it you need two pillows?
5
6 A I dont know, its just that — I dont know
7
8 whether Im breathing easier or whatever. Now its
9
10 habit. I do it all the time.
11
12 Q And you state that youre somewhat edgey
13
14 nowadays?
15
16 A Yeah. I get sort of edgey, temperamental.
17
18 Q Do you remember when this came on?
19
20 A When things arent going right I sort of tense
21
22 up and that seems to have an effect on my breathing.
23
24 Q And how about lack of energy? When was
25
252: 1 the first time you noticed you were having less energy?
2
3 A Within the past I would say three years its
4
5 really slowly progressing.
6
7 Q And is there any particular activity that
8
9 you notice youre having a lack of energy of your being
10
11 involved in it?
12
13 A Its really when I have to overexert myself. I
14
15 couldnt play any sports or anything.
16
17 Q How about on the job, are you able to do
18
19 your job?
20
21 A Im able to do my job if I stay away from stairs
22
23 because if I go up two, three flights of stairs, then I
24 start getting short-winded.
25
253: 1 Q Have you ever received any therapy or
2
3 treatment for any of these symptoms, any of these
4
5 complaints lets call them?
6
7 A No, just high blood pressure, thats about all.
8
9 Q Okay. How tall are you?
10
11 A Well, Im about 5 foot 11 and a half.
12
13 Q And how much do you weigh?
14
15 A About 245.
16
17 Q Has that been your weight during your
18
19 adult life or have you gained weight over the past ten
20
21 or fifteen years?
22
23 A Just recently within the past four or five years
24
25 that I really gained weight.
254: 1
2 Q Lets go back six years, six years what
3
4 was your weight?
5
6 A Six years I was down to maybe 210, something
7
8 like that.
9
10 Q Have any of your doctors discussed your
11
12 weight gain with you over the past five or six years?
13
14 A Yeah. The doctor has mentioned it and the only
15
16 thing he said he couldnt put me on any kind of a diet
17
18 because I was taking these blood pressure pills. Any
19
20 diet that he would really recommend. Maybe theres
21
22 something I could take but what he recommended, no.
23 Q Over the course of your life have any
24
25 doctors told you to restrict your diet in any way for
255: 1
2 any reason?
3
4 A Just for being overweight, thats about it.
5
6 Q A particular doctor?
7
8 A Dr. Senz.
9
10 Q And when was the first time he tried to
11
12 restrict your diet?
13
14 A That was back in — its been several times.
15
16 Once was probably back in the 70s. The beginning of
17
18 the 70s. The end of the 70s.
19
20 Q Was his advice related to any particular
21
22 health problem or was it just for general health?
23
24 A He just said if you lost the weight it might be
25
256: 1 beneficial to your blood pressure and usually if I
2
3 dropped the weight the blood pressure came down.
4
5 Q Is Dr. Senz the only doctor thats treated
6
7 you for blood pressure?
8
9 A Yes.
10
11 Q During your career at Public Service were
12
13 physicals given to the employees on a regular basis?
14
15 A Not a physical, no. Like I said, the yearly
16
17 X-rays. Yearly X-rays, chest X-rays, ear examinations,
18
19 and we used to blow into that wind, wind capacity
20
21 machine they had.
22 Q When did all that start?
23
24 A I would say thats been in the past 10 to 12
25
257: 1 years. It could have been longer. Im just guessing
2
3 the year. Its been like on a yearly basis for quite a
4
5 few years.
6
7 Q And as long as theyve had the program
8
9 have you participated in it?
10
11 A Yeah, whenever I was, you know, whenever they
12
13 set us up to go, we would go. If I was out sick or
14
15 wasnt there, that was another story. They did try
16
17 to — if you missed it they would have a screening
18
19 later on that you could make it up.
20
21 Q Was this performed by a doctor on the
22
23 plant ground or did you go out?
24
25 A They used to bring a mobile trailer in.
258: 1
2 Q And did you receive results from this
3
4 every year?
5
6 A They would send us a letter from Newark saying
7
8 if there was anything wrong they would say it. If not
9
10 they would say you were in good health.
11
12 Q Did any of yours ever say there was
13
14 anything wrong?
15
16 A Yes. After I put on the questionnaire that I
17
18 had asbestosis, then they questioned my X-ray.
19
20 Q And when was that?
21 A That was 1985 I guess. Right after — it would
22
23 have been right after I visited Dr. Valez and I filled
24
25 out the questionnaire that they wanted to know what
259: 1
2 type of diseases you had.
3
4 Q So the year before you went to Dr. Valez
5
6 your chest X-ray read normal?
7
8 A Yes. The only thing they told me there, well,
9
10 there were areas of doubt, thats all they said, but it
11
12 could have been to a poor X-ray. They never defined
13
14 anything wrong.
15
16 Q How about two years before Dr. Valez, do
17
18 you remember if your X-ray came back with any –
19
20 A They all came back good according to their
21
22 doctor.
23
24 Q Was there ever another X-ray that had this
25
260: 1 area of doubt?
2
3 A Well, my doctor took X-rays but he was looking
4
5 like at bronchitis or something like that.
6
7 Q So as far as you recall the only X-ray
8
9 from the company physical which showed a problem before
10
11 you went to Dr. Valez was that year before when there
12
13 was something doubtful?
14
15 A Yes.
16
17 Q And all the rest were supposedly clean?
18
19 A Thats correct.
20 Q Have you ever filed a Workers
21
22 Compensation action?
23
24 A No.
25
261: 1 Q Im going to go down a list of maladies
2
3 and I want you to tell me if youve ever suffered from
4
5 them, all right, sir?
6
7 A Sure.
8
9 Q Have you ever suffered from pneumonia?
10
11 A No.
12
13 Q Have you ever suffered from any heart or
14
15 circulatory problems?
16
17 A No, outside of high blood pressure, thats all.
18
19 Q Bronchitis?
20
21 A Bronchitis, yes.
22
23 Q More than once?
24
25 A Yes.
262: 1
2 Q Whens the first time you remember being
3
4 told you had bronchitis?
5
6 A That was about eight years ago.
7
8 Q And what doctor?
9
10 A Dr. Senz.
11
12 Q And at some point was Dr. Senz satisfied
13
14 that you recovered?
15
16 A Yes.
17
18 Q And how long did that take?
19 A Most of the times within a week, 10 days.
20
21 Q And when was the next time you were told
22
23 that you had bronchitis?
24
25 A Well, I had a series there, it was like two
263: 1
2 years in a row I think I had it. I dont remember the
3
4 exact years but.
5
6 Q Was it just two times that you recall
7
8 having bronchitis?
9
10 A Yeah, it was an upper respiratory infection,
11
12 thats about it.
13
14 Q Now, you alluded before to a problem you
15
16 had with asthma?
17
18 A Thats correct.
19
20 Q When was the first time you were diagnosed
21
22 as having asthma?
23
24 A I was diagnosed as a child and the doctor that I
25
264: 1 had at that time said that I would outgrow it when I
2
3 reached my teenage. And then previously after that I
4
5 must have been about, oh, about 40 years old before I
6
7 had another asthma attack.
8
9 Q And did you see Dr. Senz for that?
10
11 A I saw Dr. Senz. I also saw Dr. Kaloss.
12
13 Q Doctor who?
14
15 A Kaloss.
16
17 Q And what were you told about this asthma
18 attack by your doctors?
19
20 A Well, I mentioned to Dr. Senz that it hadnt
21
22 occurred since I was, you know, a teenager and he
23
24 suggested I see Dr. Kaloss to see if there was anything
25
265: 1 that I was allergic to that would trigger the asthma
2
3 off.
4
5 Q And did you subsequently see Dr. Kaloss?
6
7 A Yes.
8
9 Q And what did Dr. Kaloss tell you?
10
11 A I had to go through a series of tests to find
12
13 out what I was allergic to.
14
15 Q And did Dr. Kaloss find any allergy?
16
17 A Yes.
18
19 Q And what were you allergic to?
20
21 A Grass, wool, and rabbits.
22
23 Q Was it Dr. Kaloss opinion that these
24
25 allergies triggered the asthma, did he ever tell you
266: 1
2 that?
3
4 A Well, they buildup your system to try to
5
6 counteract them. I believe thats what he was doing.
7
8 Q Did he tell you that the allergies and the
9
10 asthma were related? Or didnt he tell you?
11
12 A No, he didnt really tell me. He just told me
13
14 that I was allergic to these things and I was getting
15
16 shots to build up my resistance.
17 Q So you received a series of shots for
18
19 these allergies?
20
21 A Yes.
22
23 Q And how long a period did you receive
24
25 these shots?
267: 1
2 A Oh, it started on a weekly basis and then it
3
4 progressed up until a six-week basis.
5
6 Q And for what period of time did you
7
8 continue with your shots?
9
10 A Well, it was continuous until I was doing
11
12 without them for a six-week period and then after a
13
14 period of time he said I didnt need them anymore.
15
16 Q So did you receive these shots for a year?
17
18 A It was at least a year.
19
20 Q Did you ever have another asthma attack?
21
22 A Just once after that.
23
24 Q And do you remember when that was?
25
268: 1 A That was about five years ago.
2
3 Q So when you were about 45?
4
5 A Yes.
6
7 Q And did you go to the doctor?
8
9 A Yes.
10
11 Q Dr. Senz or Dr. Kaloss?
12
13 A I went to Dr. Senz.
14
15 Q And what sort of treatment did you get?
16 A The medicine treatment was a shot of adrenaline.
17
18 Q And after that?
19
20 A That was about it.
21
22 Q And after that episode when you were 45
23
24 have you suffered from any asthma attacks?
25
269: 1 A No.
2
3 Q Were you ever given any medication besides
4
5 the shots for asthma?
6
7 A No.
8
9 Q Any breathing apparatus?
10
11 A No, nothing.
12
13 Q Other than the grass, wool and rabbits, do
14
15 you have any other allergies?
16
17 A No, thats all that was mentioned.
18
19 Q Okay. Have you ever been diagnosed as
20
21 having tuberculosis?
22
23 A No.
24
25 Q Any form of cancer?
270: 1
2 A No.
3
4 Q Have you ever had any sort of chest or rib
5
6 injury?
7
8 A No.
9
10 Q You ever had diabetes or high blood sugar?
11
12 A No.
13
14 Q Now, we talked about hypertension a
15 little. Lets see if we can get a history of that.
16
17 When was the first time you were diagnosed as having
18
19 high blood pressure?
20
21 A It was I guess back in 1960 somewhere.
22
23 Q And was that Dr. Senz?
24
25 A Yes.
271: 1
2 Q Were you told by Dr. Senz what was causing
3
4 your high blood pressure?
5
6 A He just mentioned the weight at the time, thats
7
8 all.
9
10 Q Do you remember how much you weighed at
11
12 that time?
13
14 A I was maybe 225, somewhere around there.
15
16 Q Did Dr. Senz attempt to help you with your
17
18 weight?
19
20 A Yes. Like I mentioned before, he prescribed,
21
22 you know, diets for me.
23
24 Q Did he ever prescribe any diet pills?
25
272: 1 A Just the water pill and that was it. No diet
2
3 pills.
4
5 Q Were you ever successful in losing weight?
6
7 A Yes.
8
9 Q And what weight did you get down to from
10
11 225?
12
13 A At one time I got down to 185.
14 Q And do you remember when that was?
15
16 A That was the first time I went.
17
18 Q So it would be around 1970?
19
20 A Yes, 1969, 70.
21
22 Q Have you ever been told you were suffering
23
24 from any kind of hernia?
25
273: 1 A No.
2
3 Q Any arthritis?
4
5 A No.
6
7 Q Has Dr. Senz treated you for any other
8
9 problem than the ones weve discussed?
10
11 A No, just weve already discussed all of them.
12
13 Q How about just injuries, have you ever had
14
15 an accident or an injury?
16
17 A Car accident, thats right.
18
19 Q And when was that?
20
21 A That was in the 1970s, the early part of
22
23 1970s.
24
25 Q And what sort of injury did you receive?
274: 1
2 A I had a contusion on the left thigh.
3
4 Q No broken bones?
5
6 A No broken, nothing broke.
7
8 Q Any lingering effects from that accident?
9
10 A No.
11
12 Q Were you ever injured on the job?
13 A No. Not serious injuries, cuts, you know.
14
15 Sprained ankle.
16
17 Q Let me ask you, when you were having this
18
19 asthma allergy problem when you were 40 years old, did
20
21 you miss time at work for that?
22
23 A Yes, I did.
24
25 Q And do you remember how much?
275: 1
2 A It was only a few days at the most.
3
4 Q Did you ever miss more than a week of work
5
6 for any particular health problem?
7
8 A Yes.
9
10 Q And what health problem was that?
11
12 A That was with the leg infection.
13
14 Q That would be just last year?
15
16 A It was last year and the year before that also.
17
18 Q You had two bouts with this leg infection?
19
20 A Yes.
21
22 Q And who treated you for the leg infection?
23
24 A Dr. Senz and also an emergency medical office, I
25
276: 1 dont remember the name of the doctor.
2
3 Q Where was it?
4
5 A It was in Middletown. EMO they called it.
6
7 Emergency Medical Offices. And recently Dr.
8
9 Sivaprasad.
10
11 Q Can you tell spell that for everybody?
12 A S-i-v-a-p-r-a-s-a-d.
13
14 Q Are you still having problems with the
15
16 leg?
17
18 A Not right now, no.
19
20 Q Are your doctors satisfied that the
21
22 infection is cured?
23
24 A Not really, it comes and goes.
25
277: 1 Q Are you receiving any sort of treatment
2
3 for it?
4
5 A No.
6
7 Q Were you told what caused your leg
8
9 infection?
10
11 A They just called it a cellulitis and it might be
12
13 formed by a fungus. It might be started by a fungus.
14
15 Q Does it impede your ability to walk?
16
17 A When I have it, yes.
18
19 Q How about right now?
20
21 A No.
22
23 Q Other than the leg infection are there any
24
25 other times you missed work for more than a week for an
278: 1
2 injury or an illness?
3
4 A I had bursitis of the hip at one time.
5
6 Q And how long were you out for that?
7
8 A I was out for a couple of weeks.
9
10 Q Any lingering problems with the bursitis?
11 A No, it cured up whatever it was.
12
13 Q Okay. Is that it? Any other times you
14
15 were out for more than a week?
16
17 A No, outside of the car accident and thats
18
19 basically it.
20
21 Q Were you ever hospitalized?
22
23 A Yes. The gallbladder removal.
24
25 Q Your gallbladder was removed?
279: 1
2 A Yes.
3
4 Q And when did this take place?
5
6 A Again, thats back in the 70s somewhere.
7
8 Q Do you know the doctor who did the
9
10 surgery?
11
12 A I cant remember his name. His office is in
13
14 Long Branch but I cant remember his name.
15
16 Q And what hospital was that?
17
18 A That was in Monmouth Medical.
19
20 Q Were you ever told the source of your
21
22 gallbladder problem?
23
24 A No.
25
280: 1 Q Do you know what was wrong with your
2
3 gallbladder?
4
5 A Buildup of gallstones.
6
7 Q Do you have any lingering effects from
8
9 your gallbladder surgery?
10 A No.
11
12 Q Were you ever hospitalized for anything
13
14 else?
15
16 A Just tonsillitis when I was a teenager.
17
18 Q Your tonsils are out?
19
20 A My tonsils are out.
21
22 Q How about your adenoids. Wasnt that the
23
24 year they took the adenoids out with the tonsils?
25
281: 1 A I dont remember.
2
3 Q Any other hospitalizations?
4
5 A I was in the Air Force hospital for an athlete
6
7 foot infection.
8
9 Q No lingering problems from that?
10
11 A No.
12
13 Q When you went to Dr. Kaloss for the
14
15 allergy problem, did you discuss with him the type of
16
17 dust you were exposed to at Public Service?
18
19 A I cant be sure. You know, I could have, I
20
21 dont know exactly.
22
23 Q You dont recall discussing your work
24
25 situation with him?
282: 1
2 A No. He probably asked me my occupation and I
3
4 told him. Thats about it.
5
6 Q Since you have been experiencing the
7
8 health complaints that we discussed a few minutes ago,
9 have you noticed it has any effect on your family live?
10
11 A Yeah, my sexual relationships with my wife.
12
13 Q And how have they been affected?
14
15 A Limited.
16
17 Q And when did you notice that your sexual
18
19 relations were limited?
20
21 A That was within the past four or five years.
22
23 Q And when you say limited, can you be more
24
25 specific? Do you still have sexual relations?
283: 1
2 A Yes.
3
4 Q And how often?
5
6 A Not to often.
7
8 Q Previous to these past four or five years
9
10 did you have sexual relations?
11
12 A Yes.
13
14 Q Do you know how often?
15
16 A Yes, a lot more. Are you looking for numbers
17
18 or –
19
20 Q Well, it probably would be helpful if we
21
22 could quantify this.
23
24 A All right. Cutting down from three or four
25
284: 1 times a week to once a month.
2
3 Q Okay. How about just the way you get
4
5 along with your wife from day to day? Has there been
6
7 any change?
8 A Yeah, theres been a change. Theres been a lot
9
10 of arguing.
11
12 Q And when did this begin to occur?
13
14 A It first started — in fact it started that
15
16 first Saturday when I left Dr. Valez office.
17
18 Q So that before you went to Dr. Valez you
19
20 were not arguing?
21
22 A Oh, we were arguing but not as much. We argued
23
24 and it was over.
25
285: 1 Q And do you relate this change to the fact
2
3 that you were told about your asbestos problem?
4
5 A I relate it because, you know, ever since Ive
6
7 been more irritable.
8
9 Q Ever since that day?
10
11 A Ever since that day.
12
13 Q Let me ask you about your relationship
14
15 with your children, has that changed at all?
16
17 A No, not to a great extent. The only thing I
18
19 developed was a fear that something would happen to me
20
21 and I didnt know how they would be taken care of.
22
23 Q But your actual relationship hasnt
24
25 changed?
286: 1
2 A No, we stay close. The two that are home and
3
4 the other one I dont see that much but we still have a
5
6 great relationship.
7 Q Have the activities that your wife and you
8
9 take part in changed at all in the past few years?
10
11 A We really havent taken part in any activity.
12
13 Q Did you previous to the past three or five
14
15 years?
16
17 A Yes, we were involved in scouting and things
18
19 like that.
20
21 Q Anything else besides the scouting that
22
23 you and your wife used to do together?
24
25 A Well, she used to go fishing with me which I
287: 1
2 dont do that much anymore. We used to go bowling and
3
4 dont do that anymore.
5
6 Q Okay. I dont have any more questions for
7
8 you right now. I have to look over my notes. Theres
9
10 no sense holding you up.
11
12 MR. PAULUS: Do you want to break right
13
14 now before we go into the next phase?
15
16 THE WITNESS: Yes.
17
18 (Recess.)
19
20 CROSS EXAMINATION BY MR. FETTEN:
21
22 Q Sir, my names John Fetten. I have some
23
24 questions for you. Back when you started with Public
25
288: 1 Service in 1951, to that February of 1952 period –
2
3 A Correct.
4
5 Q How many boilers or units were there at
6 the Linden station at that time?
7
8 A Sewaren Station?
9
10 Q I mean Sewaren Station.
11
12 A There were four.
13
14 Q Were they all totally constructed at that
15
16 time?
17
18 A Four they were just finishing up. No. 4 unit.
19
20 The boiler may have been intact. I dont know, the
21
22 unit wasnt ready.
23
24 Q What were the numbered designations of the
25
289: 1 units at Sewaren that were already constructed besides
2
3 the No. 4 unit?
4
5 A One, two and three.
6
7 Q And who constructed the No. 1 boiler?
8
9 A The No. 1 boiler?
10
11 Q Yes.
12
13 A Combustion Engineering.
14
15 Q Who constructed the No. 2 boiler?
16
17 A Combustion Engineering.
18
19 Q And the No. 3 boiler?
20
21 A Combustion Engineering.
22
23 Q And the No. 4 unit I think you mentioned,
24
25 was that CE as well?
290: 1
2 A That was Combustion Engineering.
3
4 Q And the No. 5 unit was B & W?
5 A B & W.
6
7 Q When you worked inside of the boiler
8
9 during that short period of months, especially during
10
11 that one overhaul that you recall working on where you
12
13 spent about a month working on the boiler itself –
14
15 A Right.
16
17 Q — the bricks that you took down, did they
18
19 have any identifying marks on them?
20
21 A I dont remember any names being written on
22
23 them.
24
25 Q Do you recall any numbers or symbols or
291: 1
2 anything like that?
3
4 A No, no, I couldnt.
5
6 Q You dont recall any?
7
8 A No, I dont recall.
9
10 Q These bricks that were up in the super
11
12 heater area, thats the very top of the boiler; is that
13
14 right?
15
16 A Thats right.
17
18 Q Were they held in place by any type of
19
20 material?
21
22 A They were held in place by some kind of
23
24 insulating material.
25
292: 1 Q Well –
2
3 A That Super 3000 was probably one of them.
4 Q I dont want you to assume. By looking at
5
6 what was there could you tell what it was?
7
8 A Could I tell what type of material.
9
10 Q Could you tell the trade name of the
11
12 product?
13
14 A Oh, no.
15
16 Q Did it look like cement?
17
18 A It looked like some type of cement.
19
20 Q Mortar?
21
22 A Mortar cement, basically.
23
24 Q Now, when you say, and correct me if Im
25
293: 1 wrong, during that period of time you recall seeing by
2
3 the storeroom a pallet of bricks; is that correct?
4
5 A Thats correct. Not by the storeroom, the
6
7 turbine room.
8
9 Q Okay. It was in the turbine room?
10
11 A Right.
12
13 Q And those bricks, from what you said
14
15 earlier, were made by J.H. France?
16
17 A Correct.
18
19 Q How do you know that?
20
21 A At the time I remember there was like cardboard
22
23 around them with the bands and the names on them.
24
25 Q Was there any writing on the bricks
294: 1
2 themselves?
3 A I didnt look that close.
4
5 Q When you looked at it how far away from
6
7 them were you?
8
9 A Well, it was like the elevator was here and they
10
11 were stashed over here, you know, waiting. Id say
12
13 about maybe 10 feet away.
14
15 Q Okay. Was it just one pallet that you
16
17 saw?
18
19 A No, there were quite a few pallets of bricks.
20
21 Q How many is quite a few?
22
23 A There would have been 30, 40 of them.
24
25 Q 30, 40 pallets?
295: 1
2 A Right.
3
4 Q Were they all J.H. France pallets of
5
6 brick?
7
8 A The ones that I saw. There might have been
9
10 others.
11
12 Q What color were the bricks?
13
14 A They were sort of like a reddish yellow. I
15
16 dont know if you call them orange.
17
18 Q Did they all appear to be the same size?
19
20 A The way they were stacked, they appeared to be
21
22 the same size.
23
24 Q Could you approximate for me what the
25
296: 1 dimensions of each individual brick was?
2 A Oh, each individual brick?
3
4 Q Well, the general size of the brick that
5
6 you saw.
7
8 A It might have been a foot by six to eight
9
10 inches, something like that.
11
12 Q How thick were they?
13
14 A Well, they were about two, two and a half inches
15
16 I would say.
17
18 Q Were they all rectangular shaped?
19
20 A Yes, the ones that I saw.
21
22 Q And you never personally performed any
23
24 type of test on those bricks, did you?
25
297: 1 A No.
2
3 Q You never took them apart and sent them to
4
5 a laboratory to see what composition was in there?
6
7 A No.
8
9 Q So you dont know whether or not those
10
11 bricks contained asbestos?
12
13 MR. PAULUS: Objection.
14
15 MR. FETTEN: Whats the basis?
16
17 MR. PAULUS: Youre characterizing his
18
19 testimony before you ask the question. Why
20
21 dont you ask the question first?
22
23 MR. FETTEN: I asked the question.
24
25 MR. PAULUS: No you didnt. Its a
298: 1 different question.
2
3 Q Im asking you, sir, whether or not you
4
5 know if those bricks contained asbestos?
6
7 A Yes, I know.
8
9 Q How do you know?
10
11 A I was told they contained asbestos.
12
13 Q Who told you that?
14
15 A The workers.
16
17 Q What were the names of the workers that
18
19 told you that?
20
21 A I dont remember the names.
22
23 Q Aside from what the workers told you, you
24
25 have no independent basis to say that they contained
299: 1
2 asbestos?
3
4 A Thats correct.
5
6 Q That is correct?
7
8 A Yes.
9
10 Q I didnt hear you.
11
12 A Outside of what I was told, I have no — I cant
13
14 say, I didnt have them tested or anything like that.
15
16 Q Now, you also mentioned some other type of
17
18 product, I think you said that it came in a can?
19
20 A There were cans of cement, some kind of cement
21
22 there.
23
24 Q Okay. Was that at the same period of time
25 that you saw the pallets of brick?
300: 1
2 A Thats correct. They were near the pallets of
3
4 brick.
5
6 Q How many cans did you see?
7
8 A There were piles of them. It could have been 50
9
10 cans at least.
11
12 Q And you indicated before, if I recall your
13
14 testimony correctly, that the name LaFrance was on
15
16 those cans; is that correct?
17
18 A No, I didnt say it was on it, I just said I saw
19
20 cans of cement there. I didnt say LaFrance was on
21
22 those, it was on the bricks.
23
24 Q Okay. So the cans that you saw, can you
25
301: 1 describe them for me? How tall were they?
2
3 A They were about, about that high, (indicating).
4
5 There were two different sizes.
6
7 Q But youre –
8
9 A Okay. They were about maybe 2 foot high, some
10
11 of them. Some of them were larger, higher.
12
13 Q And what was the diameter?
14
15 A They were maybe 14 inches in diameter.
16
17 Q Are these like five gallon pails?
18
19 A Close to that, yeah.
20
21 Q Were they made out of tin or plastic?
22
23 A They were tin.
24 Q And what color were they?
25
302: 1 A I think they were black.
2
3 Q Did you see any labels or any writing on
4
5 the cans?
6
7 A There might have been something that related
8
9 them to cement because cement sticks in my mind. That
10
11 might be what I read, cement.
12
13 Q I dont want you to guess at anything. As
14
15 best you recall as you sit here now, do you recall any
16
17 writing on the cans?
18
19 A I recall the word cement, thats all.
20
21 Q Did you ever open up one of those cans to
22
23 see what was in it?
24
25 A No.
303: 1
2 Q Did you ever use any of the product that
3
4 was in those cans?
5
6 A No.
7
8 Q Did you ever use the bricks that had the
9
10 name J.H. France on the cardboard around them?
11
12 A No.
13
14 Q Did you ever handle those bricks?
15
16 A No.
17
18 Q Other than the time back in the early 50s
19
20 when you recall seeing these pallets of brick with the
21
22 bands and the cardboard that said France on them, do
23 you recall any other product that had the name France
24
25 on it during your entire tenure at Public Service?
304: 1
2 A No, I dont recall any others.
3
4 Q Now, the material that was up by the
5
6 boiler feed tubes –
7
8 A Right.
9
10 Q — that was I guess after you removed the
11
12 brick, was that insulation or was that a refractory or
13
14 do you know the difference between the two?
15
16 A I really dont know the difference.
17
18 Q At the Edison facility, is that like a
19
20 substation?
21
22 A Its a station entirely by itself. The only
23
24 difference is, it doesnt have boilers, it has gas
25
305: 1 turbine engines.
2
3 Q Thats what I was going to ask you, there
4
5 are no boilers there?
6
7 A No boilers there.
8
9 Q When you say gas turbine engines, are
10
11 these jet engines propelled by gas and they crank the
12
13 generator?
14
15 A Thats correct.
16
17 Q Mr. Compell, Im going to show you some
18
19 written questions, theres five of them with some
20
21 subparts. I want you to take a look at those questions
22 and tell me whether or not youve ever seen those
23
24 before?
25
306: 1 A If Ive ever seen these?
2
3 Q Yes.
4
5 A These particular questions or –
6
7 Q Those particular questions, thats right,
8
9 sir.
10
11 A I dont remember seeing them.
12
13 (D-2 received and marked for
14
15 identification.)
16
17 Q Im going to show you another document and
18
19 ask that you take a look at that and tell me whether or
20
21 not youve ever seen that particular sheet of paper
22
23 before.
24
25 A No, Ive never seen it.
307: 1
2 (D-3 received and marked for
3
4 identification.)
5
6 Q Do you recall this document which weve
7
8 now had marked D-3 which states Answers to Supplemental
9
10 Interrogatories propounded by J.H. France Refractories
11
12 Company?
13
14 A I never saw those answers before.
15
16 MR. PAULUS: Why dont you sit down.
17
18 MR. FETTEN: Im trying to read it at the
19
20 same time. Im across a circular table.
21 A No, Ive never seen it.
22
23 Q So I take it then, Mr. Compell, with
24
25 respect to answer No. 2 C, where it says Hydrogen No. 5
308: 1
2 cement, you dont know what that is; is that correct?
3
4 A No, I dont.
5
6 MR. PAULUS: Objection to the form of the
7
8 question.
9
10 Q You have no knowledge of ever having
11
12 seeing Hydrogen No. 5 cement at Public Service?
13
14 A I wouldnt even associate Hydrogen with cement.
15
16 Q You have no knowledge of seeing that
17
18 product listed in Answer to Interrogatory 2C at Public
19
20 Service; is that correct?
21
22 A Thats correct.
23
24 Q And I take it then, Mr. Compell, that you
25
309: 1 have no personal knowledge from your own observations
2
3 at Public Service that J.H. France supplied any cement
4
5 to the Sewaren facility that came in 50 pound and 100
6
7 pound cans; is that correct?
8
9 A Thats correct. I cant say they definitely
10
11 did.
12
13 Q Thank you. Thats all I have.
14
15 CROSS EXAMINATION BY MR. MC GRATH:
16
17 Q Mr. Compell, my name is McGrath. I have a
18
19 few questions for you. You were talking earlier about
20 the removal of some of the insulation off of the
21
22 equipment. You said there was an outside contractor
23
24 that came in to do some of this work and you told us
25
310: 1 the name of the outfit. Do you know where theyre
2
3 located?
4
5 A I believe theyre in Point Pleasant.
6
7 Q And that was Associated Asbestos?
8
9 A Assured Asbestos.
10
11 Q Assured. When was it that they came in to
12
13 do any work?
14
15 A Last week.
16
17 Q Had they been in any time before last
18
19 week?
20
21 A Not that Im aware of. They may have been in
22
23 the station somewhere but thats the first time I knew.
24
25 Q Which part of the station were they
311: 1
2 working on last week?
3
4 A Last week was the super heater reheater outlet
5
6 box on the No. 4 unit.
7
8 Q When they did this did they rope off the
9
10 area and put up plastic sheets?
11
12 A Thats correct.
13
14 Q Have there been other contractors in the
15
16 plant to remove insulation from other parts of the
17
18 plant in the same manner as Assured?
19 A I cant tell you definitely. I could say I
20
21 think so, but I cant definitely say.
22
23 Q Now, if I understand what you said, there
24
25 have been times when Public Service employees have had
312: 1
2 to do the same sort of thing; is that correct?
3
4 A To remove asbestos?
5
6 Q Yes.
7
8 A Thats correct.
9
10 Q And did they hang up plastic sheets and
11
12 that sort of thing?
13
14 A Thats correct. Depending on the extent of the
15
16 job.
17
18 Q When was the first time they did that?
19
20 A Its, I would say within the past two to three
21
22 years.
23
24 Q And which parts of the plant have the
25
313: 1 Public Service employees done this removal work?
2
3 A Its been in parts of the boilers, parts of the
4
5 piping insulation.
6
7 Q When they do this, do they do a whole
8
9 boiler at once?
10
11 A No, not really.
12
13 Q Okay. Are they only doing parts where the
14
15 insulation is loose?
16
17 A Theyre doing parts where the insulation is
18 loose. Theyre doing the parts where work has to be
19
20 done.
21
22 Q Has anyone in Public Service management
23
24 told you that they have any sort of plan to go through
25
314: 1 the plant and remove anything that might contain
2
3 asbestos?
4
5 A No.
6
7 Q So the instances of the outside
8
9 contractors, they appear to be to you isolated to
10
11 specific jobs?
12
13 A Yes.
14
15 Q You mentioned that Combustion Engineering
16
17 at some point, if I understood you, came back into the
18
19 plant to do some work after the boiler was up?
20
21 A I said I wasnt sure. They may have because
22
23 they have a lot of outside contractors there during
24
25 that period of time.
315: 1
2 Q Do you know if any of those outside people
3
4 who came in to do work on the boiler were from
5
6 Combustion Engineering?
7
8 A I dont know definitely.
9
10 Q Do you know the names of any of the
11
12 outside companies other than Assured that came in to do
13
14 any work with the insulation?
15
16 A No, I dont.
17 Q During the years you were at Sewaren, was
18
19 there ever a time that there was a major insulating job
20
21 where new insulation was installed by an outside
22
23 contractor?
24
25 A I dont know, Im not aware of it. They did
316: 1
2 install insulation on a couple of new heaters they put
3
4 in, but thats all non-asbestos.
5
6 Q When the No. 5 boiler was built, was
7
8 insulation put on it?
9
10 A Yes.
11
12 Q Was it put on by Public Service people or
13
14 outsiders?
15
16 A It was outside people.
17
18 Q Do you know the names of any of those
19
20 people or who they worked for?
21
22 A No, no.
23
24 Q Have any new turbines been added other
25
317: 1 than what may have been put in with the No. 5 boiler?
2
3 A A new turbine?
4
5 Q Yes.
6
7 A They put in a No. 6 gas turbine last year.
8
9 Q Was insulation done in connection with
10
11 that turbine?
12
13 A Yes.
14
15 Q Was it done by Public Service people or
16 outside?
17
18 A No, it was all outside construction.
19
20 Q Do you have any idea of where those
21
22 insulators were from?
23
24 A No.
25
318: 1 Q Do you know if these outside insulators
2
3 were union or nonunion people?
4
5 A I — just the one I told you about, Assured,
6
7 they are union workers. The others Im not familiar
8
9 with because I wasnt directly related to any of those
10
11 jobs.
12
13 Q When the No. 5 unit was insulated, were
14
15 you in the vicinity?
16
17 A When it was originally insulated?
18
19 Q Yes.
20
21 A Most of the time I would say no. It would have
22
23 been in that area occasionally but not completely in
24
25 there.
319: 1
2 Q Just so I have an idea, approximately how
3
4 long did it take to put in the No. 5 unit from when
5
6 they started doing it until they finished?
7
8 A It took about three years or so.
9
10 Q I have to ask you a question about
11
12 something else. You mentioned in one of your jobs you
13
14 had to take samples of the coal, did you, if I
15 understood you, did you say you had to grind it up or
16
17 crush it or something like that?
18
19 A No, just mix it up. Mix the coal up.
20
21 Q Okay. The coal that you had to mix up,
22
23 what did it look like?
24
25 A What did it look like.
320: 1
2 Q Yes?
3
4 A It was soft coal. It wasnt real dusty or, you
5
6 know.
7
8 Q Was it in chunks or was it pulverized or
9
10 what?
11
12 A Soft coal is not real big chunks and its not
13
14 real, you know, like you would specify chestnut coal or
15
16 anything like that.
17
18 Q How big are these pieces were talking
19
20 about?
21
22 A If you looked at it you would think it was a
23
24 mound of dirt basically. Theres not much body to it.
25
321: 1 Q So the pieces are smaller than marbles
2
3 from my understanding?
4
5 A Yes, there would be pieces larger but thats a
6
7 good estimation. Its quite small but not too big.
8
9 Q At some point did the Sewaren plant switch
10
11 from coal fire to something else?
12
13 A Thats correct.
14 Q Do you know when that was?
15
16 A They never did switch, it was just a matter of
17
18 stopping burning coal.
19
20 Q And are all of the boilers still in use?
21
22 A All except No. 5.
23
24 Q Do you know why they stopped using that
25
322: 1 one?
2
3 A Yeah, it was because during the oil crisis, No.
4
5 5 burnt strictly oil, and the price of oil didnt
6
7 warrant the fact of keeping the unit in, plus the fact
8
9 they could not take it down below a 150 mega, with the
10
11 load at nighttimes when they didnt need the load.
12
13 Those are the two main considerations in taking the
14
15 unit out of service.
16
17 Q The other four boilers, how are they
18
19 currently fired?
20
21 A Gas or oil.
22
23 Q Whens the last time they had any coal
24
25 fire operating?
323: 1
2 A I would be guessing, but its a good 15 years
3
4 ago.
5
6 Q When it was coal fired did the coal have
7
8 to be pulverized?
9
10 A Yes.
11
12 Q Did you ever work in that pulverizing
13 process?
14
15 A In the pulverizing process?
16
17 Q Yes.
18
19 A No. The pulverizing process was done –
20
21 everything was done mostly automatic.
22
23 Q Did you ever have to do any maintenance
24
25 work on any of the equipment connected with pulverizing
324: 1
2 the coal?
3
4 A Yeah, we had to occasionally free a feeder line
5
6 that was going to a draft gauge.
7
8 Q Was that a dusty job?
9
10 A Not that dusty because most of the coal dust
11
12 would have been sucked out before the pulverizer was
13
14 turned off.
15
16 Q How often did you have to do maintenance
17
18 work on the pulverizing equipment?
19
20 A Very seldom, very seldom. If you were in there
21
22 once a year.
23
24 Q I want to ask you the names of just a few
25
325: 1 of the fellows that were mentioned before because Im
2
3 not sure of what you said. I know you told us that you
4
5 were familiar with Mr. Bukowski?
6
7 A Right.
8
9 Q Did you ever actually work with him?
10
11 A I could have. I cant be exact because when
12 I — the only time I ever worked was in that short
13
14 period, that short two-month period when I first
15
16 started.
17
18 Q Do you know if you ever worked with Mr.
19
20 Kudrich?
21
22 A No.
23
24 Q Because of my poorly worded question Ill
25
326: 1 have to ask you a different one. Are you telling me
2
3 you did not work with him or you dont know if you
4
5 worked with him?
6
7 A I did not work with him.
8
9 Q You mentioned Victor Monticello, did you
10
11 ever work with him?
12
13 A Yes.
14
15 Q Is that something that you did often or
16
17 occasionally or?
18
19 A Well, we were on the same shift together and we
20
21 were also on that same boiler outage together.
22
23 Q Was that just the one outage you were on
24
25 with him?
327: 1
2 A Yes.
3
4 Q Do you know approximately when that was?
5
6 A When?
7
8 Q Yes.
9
10 A It was I believe December and January, December
11 1951 to January 1952, somewhere.
12
13 Q Did you ever work with Mr. Monticello
14
15 during the years that you were a technician?
16
17 A As a technician?
18
19 Q Yes.
20
21 A I worked with him several times where he had to
22
23 remove some equipment for me with a burning torch or
24
25 welding. He was — its like a combined effort. Our
328: 1
2 department and his department. If I needed something
3
4 to put up an instrument, he would put a frame up for
5
6 me, a metal frame because we werent allowed to use the
7
8 welder.
9
10 Q Did you ever work with Mr. Nimetz?
11
12 A Directly with Mr. Nimetz, no.
13
14 Q You told us before that you used two
15
16 pillows to sleep at night?
17
18 A One pillow, either two pillows or a pillow on my
19
20 arm.
21
22 Q Okay. Why is it that you use two pillows?
23
24 A Because it seemed like thats when I would fall
25
329: 1 asleep, otherwise I would be restless. The most
2
3 comfortable I felt.
4
5 Q Okay. If you were not comfortable, how
6
7 would that be?
8
9 A I would be tossing and turning. I just wouldnt
10 fall asleep, from one side to another.
11
12 Q Was your neck hurting? I dont want to
13
14 put words in your mouth. What caused the restlessness
15
16 if you know?
17
18 A Mainly it was if I was in one position, I had a
19
20 hard time breathing so Id get in another position. I
21
22 could never lay on my stomach.
23
24 Q Have you ever been to see a psychiatrist?
25
330: 1 A No.
2
3 Q Have you ever been to see a psychologist?
4
5 A No.
6
7 Q Do you have any plans to see any?
8
9 A No.
10
11 Q Did you ever have anything to do with
12
13 purchasing any materials that were used at Public
14
15 Service?
16
17 A Purchasing materials?
18
19 Q Yes.
20
21 A Yeah, I write out work orders for a lot of
22
23 materials, materials orders.
24
25 Q When you would write out a work order –
331: 1
2 A Material order.
3
4 Q — what would you do? List the type of
5
6 material that you needed?
7
8 A Thats correct.
9 Q And where would you send it?
10
11 A I would just fill it out and pass it off into
12
13 the office and they would go through with the rest of
14
15 the paperwork.
16
17 Q Do you know who in the office you gave it
18
19 to?
20
21 A Yes, the administrative clerk, office
22
23 administrator.
24
25 Q Did you ever make out any work orders for
332: 1
2 any insulation material?
3
4 A No.
5
6 Q For the work orders that you did make out,
7
8 do you know what the administrative clerk did with
9
10 them?
11
12 A Well, they just typed it and sent it to the
13
14 companies that you were ordering from.
15
16 Q Do you know if Public Service had any
17
18 system of central ordering through the office in
19
20 Newark?
21
22 A Central office ordering in Newark? Well, a lot
23
24 of it depends on the price of what we buy. If its an
25
333: 1 extreme amount it has to go to Newark.
2
3 Q Did you ever unload any trucks making any
4
5 deliveries to Public Service?
6
7 A Any trucks making deliveries?
8 Q Yes.
9
10 A No.
11
12 Q Did you ever see anybody else unloading
13
14 any trucks making deliveries?
15
16 A Yeah, that happens almost on a day-to-day basis.
17
18 Q How would it be that you would happen to
19
20 see a truck being unloaded, just passing through the
21
22 area?
23
24 A Passing through the area, being in back of the
25
334: 1 storeroom.
2
3 Q Would be in the storeroom to get materials
4
5 for another job?
6
7 A Yes, occasionally.
8
9 Q In the Sewaren plant was there one
10
11 storeroom or more than one?
12
13 A There was one main storeroom.
14
15 Q Where was the main storeroom located –
16
17 A Its on the bottom floor at the extreme — the
18
19 side nearest the river.
20
21 Q Does that floor have a name or a number?
22
23 A We go by elevations, we call it elevation 100.
24
25 Q Other than going to the storeroom to pick
335: 1
2 up some materials, did you have any other reason to be
3
4 there?
5
6 A No. The only other reason I would have to be
7 checking on an order that I sent out.
8
9 Q So you wouldnt be watching the men unload
10
11 the trucks?
12
13 A No, I wouldnt stand there watching people
14
15 unload trucks.
16
17 MR. BASIL: Excuse me, could I ask a
18
19 question on that just for a second?
20
21 When did you have this ordering
22
23 responsibility?
24
25 THE WITNESS: Only when I became a
336: 1
2 supervisor.
3
4 MR. BASIL: Okay.
5
6 Q Earlier you mentioned the name State
7
8 Insulation?
9
10 A Thats correct.
11
12 Q How did you know that name?
13
14 A Well, normally I used to live in Perth Amboy and
15
16 I used to drive down State Street to get home, and I
17
18 happened to see State Insulation and I also noticed
19
20 the — like I mentioned before on the trucks, thats
21
22 probably why I noticed State Insulation.
23
24 Q When you say you noticed it on the trucks,
25
337: 1 where did you see the trucks?
2
3 A The trucks were either coming through the gate
4
5 or being parked by the storeroom or something.
6 Q What did these trucks look like?
7
8 A They looked like, you know, full-bodied trucks,
9
10 you know, container trucks. No open trucks that I
11
12 remember.
13
14 Q How many days did you see a State
15
16 Insulation truck at Public Service?
17
18 A Id say two or three times.
19
20 Q Can you tell me what years it was, either
21
22 by the year or what job category you were in?
23
24 A It was when I was a technician.
25
338: 1 Q Now, you were a technician from
2
3 approximately 63 through 87; is that correct?
4
5 A Thats correct.
6
7 Q Is there any way you can narrow it down
8
9 for me as to when in those years?
10
11 A No, I have no idea.
12
13 Q And those trucks, did you ever see the
14
15 State Insulation truck unloaded at Public Service?
16
17 A No.
18
19 Q And when you say you saw them, was that at
20
21 the Sewaren facility?
22
23 A They were on the Sewaren premises.
24
25 Q You didnt see them at Linden or Edison?
339: 1
2 A No.
3
4 Q Did you ever see any other trucks
5 delivering materials to Public Service that you can
6
7 tell us the name of the truck?
8
9 A Sure, the UPS truck, trucks from different
10
11 lumber yards. Hydrogen deliveries, soda — caustic
12
13 soda deliveries, acid deliveries.
14
15 Q Did you ever see any companies delivering
16
17 insulation?
18
19 A There were other deliveries, but I cant say
20
21 specifically insulation.
22
23 Q Am I correct in my understanding that the
24
25 reason State Insulation stands out in your mind is
340: 1
2 because you had gone past their place on State Street
3
4 in Perth Amboy?
5
6 A Yes, it was a continual thing driving back and
7
8 forth. It seemed strange, I saw the place then all of
9
10 a sudden the truck came.
11
12 Q When was it you lived in Perth Amboy?
13
14 A Up until 51.
15
16 Q Thats all the questions I have, thank
17
18 you.
19
20 MS. KITTERMAN: No questions.
21
22 MR. GAFFREY: No questions.
23
24 CROSS EXAMINATION BY MS. WIEDER:
25
341: 1 Q Mr. Compell, my name is Jane Wieder. I
2
3 have a few questions for you. Are you familiar with
4 the name Kaylo.
5
6 A No.
7
8 Q Are you familiar with the name
9
10 Owens-Corning Fiberglas?
11
12 A Yes.
13
14 Q What about that name are you familiar
15
16 with?
17
18 A Well, the name Owens-Corning, insulation
19
20 automatically.
21
22 Q Do you associate the name Owens-Corning
23
24 Fiberglas with your employment at PSE&G?
25
342: 1 A Ive seen it on cartons at PSE&G. Cardboard
2
3 cartons.
4
5 Q Do you know during what time frame or what
6
7 particular job you were working you recall seeing it on
8
9 cartons?
10
11 A No, its just every bulk thing they store in the
12
13 turbine room because they dont have room in the main
14
15 storeroom.
16
17 Q Do you have any idea what was contained in
18
19 the cartons?
20
21 A No.
22
23 Q I have a few questions of clarification of
24
25 your earlier testimony. Did you actually remove any
343: 1
2 pipe covering?
3 A Yes. Yes, I did.
4
5 Q On what jobs were you doing when you
6
7 removed the pipe covering?
8
9 A If youre talking about just pipes in general it
10
11 was on No. 5 unit.
12
13 Q And you actually removed the pipe covering
14
15 from pipes on the No. 5 unit?
16
17 A Thats correct.
18
19 Q Was that during the outage?
20
21 A Yes, it was during the outage.
22
23 Q Did you remove pipe covering at any other
24
25 time?
344: 1
2 A No.
3
4 Q Do you recall the years that you would
5
6 remove the pipe covering during the outage on No. 5?
7
8 A It could have been around 68. It was in the
9
10 60s.
11
12 Q Do you know the name of the manufacturer
13
14 of the pipe covering that you removed?
15
16 A No.
17
18 Q Did you ever apply pipe covering?
19
20 A No.
21
22 Q Thats all I have, thank you.
23
24 CROSS EXAMINATION BY MR. BOTTIGLIERI:
25
345: 1 Q Sir, my name is Joseph Bottiglieri. I
2 have some questions for you. Did you ever, yourself,
3
4 work with packing?
5
6 A Myself work with packing?
7
8 Q Yes. Did you actually handle it?
9
10 A I handled it in the sense I handed it to a
11
12 maintenance man, thats about it.
13
14 Q Did you ever have to pack a valve?
15
16 A No, its out of our classification.
17
18 Q Did you ever remove packing?
19
20 A No.
21
22 Q Okay. You stated earlier that as an
23
24 equipment operator you remembered dealing with packing;
25
346: 1 correct?
2
3 A Thats correct.
4
5 Q Were you, at that time, were you just
6
7 handing it to someone or?
8
9 A Thats correct.
10
11 Q Do you remember who you were working with
12
13 at that time?
14
15 A No. It might have been that Otto Jensen but Im
16
17 not sure.
18
19 Q Okay. The people that you were handing
20
21 the packing to, do you know what they were doing with
22
23 the packing?
24
25 A They were repacking leaking valves.
347: 1 Q Did you watch them doing that?
2
3 A Yes.
4
5 Q Did they at any time have to cut the
6
7 packing?
8
9 A Yes.
10
11 Q And how far were you from them when they
12
13 were doing this?
14
15 A Just a few feet away.
16
17 Q Can you tell me what the packing looked
18
19 like?
20
21 A Oh, there were different colors they used. Some
22
23 was gray, some was black, shiny looking on the outside.
24
25 Some was quarter inch round, some what about 3/8s,
348: 1
2 5/8s. Different sizes.
3
4 Q Could you tell, was there graphite on the
5
6 outside of the packing?
7
8 A It looked like graphite, the real shiny part of
9
10 it.
11
12 Q Where did you get the packing from?
13
14 A Sometimes they kept extra in the maintenance
15
16 department and sometimes we had to go to the storeroom
17
18 and take it out of the storeroom.
19
20 Q What type of packaging was it in?
21
22 A Most of them were in just like cardboard boxes
23
24 with these reels, metal reels inside with the packing
25 wrapped around the rim.
349: 1
2 Q You stated earlier that you knew the name
3
4 John Crane; is that correct?
5
6 A That is correct.
7
8 Q How do you know that name?
9
10 A Ive seen it on boxes.
11
12 Q Do you know what color the letters were on
13
14 the boxes?
15
16 A What color the letters were?
17
18 Q Yes.
19
20 A I couldnt say for sure.
21
22 Q Do you know what color the boxes were?
23
24 A I remember black and yellow boxes, it might have
25
350: 1 been yellow with black writing on them, something like
2
3 that.
4
5 Q Did you ever take Crane packing out of a
6
7 box and hand it to someone?
8
9 A Yes.
10
11 Q How often would you do that?
12
13 A Not too often.
14
15 Q Could you clarify that for me?
16
17 A Well, if he asked me to hand him a piece, I
18
19 would hand him a piece.
20
21 Q How often, lets say in one week?
22
23 A Maybe only one day, you know, one day, a few
24 hours a day.
25
351: 1 Q Was it one day a week or one day every two
2
3 weeks?
4
5 A It depended on what job you had at this time.
6
7 It wasnt like it was something that we did
8
9 consistently. You were assigned to the maintenance
10
11 department to certain jobs.
12
13 MR. DOWDEN: Can I have a clarification as
14
15 to whether or not the witness is talking
16
17 specifically about using Crane packing or simply
18
19 about his use of packing regardless of brand.
20
21 Q Lets talk about packing in general.
22
23 A Packing in general would be done occasionally.
24
25 If they assigned me to somebody that was packing valves
352: 1
2 that day you would be with him all day.
3
4 Q Can you estimate at all how often they
5
6 would assign you to someone that was packing valves,
7
8 were talking about when you were an equipment
9
10 operator?
11
12 A It could be one day on the whole outage.
13
14 Q Was it only on outages?
15
16 A Yes, because we werent allowed to do any of
17
18 that kind of work during our equipment operating job.
19
20 Q And could you differentiate how much of
21
22 that time was spent with just Crane packing?
23 A No, I couldnt differentiate.
24
25 Q Do you know if you used more of one type
353: 1
2 of packing than another?
3
4 A No, I couldnt specify that one was used more
5
6 than the other.
7
8 Q Did you ever have to handle packing after
9
10 someone took it out of a valve?
11
12 A Yeah, they would hand it to you and youd throw
13
14 it in a little pail there or something.
15
16 Q Did you do that?
17
18 A Yes.
19
20 Q Could you tell who manufactured that
21
22 packing?
23
24 A No.
25
354: 1 Q Okay. How about while you were a
2
3 technical assistant, I think you said from 1956 to
4
5 about 1963, did you ever have to handle packing during
6
7 that time?
8
9 A When I was a technician?
10
11 Q A technical assistant I believe it was.
12
13 A Okay. No, we didnt handle it at that time.
14
15 Q Okay. Were you around any people working
16
17 with packing?
18
19 A Yes.
20
21 Q What were you doing while those people
22 were working with packing?
23
24 A I was calibrating instruments, replacing tubing
25
355: 1 to the instruments.
2
3 Q And how far would you be from the people
4
5 that were working with packing?
6
7 A Just a few feet away.
8
9 Q Okay. How about while you were a
10
11 technicians helper in 1956, did you handle any packing
12
13 then?
14
15 A No.
16
17 Q Were you next to any people that were
18
19 working with packing?
20
21 A Yes.
22
23 Q Lets go back to a technical assistant for
24
25 one second. Do you remember any of the names of the
356: 1
2 people that you were working around that were working
3
4 with packing?
5
6 A No, I dont remember exactly the names.
7
8 Q Okay. Do you remember any of the names of
9
10 the people that were working with packing while you
11
12 were a technicians helper?
13
14 A No.
15
16 Q How often while you were a technicians
17
18 helper, how often were you around these people that
19
20 were working with packing?
21 A When I was a technicians helper?
22
23 Q Right.
24
25 A Not too frequently when I was a helper.
357: 1
2 Q Not too frequently. Was it once a month,
3
4 was the one a week?
5
6 A It might have been once a week, once every two
7
8 weeks. Whenever I had to assist a technician in that
9
10 area.
11
12 Q How about as a technicians assistant?
13
14 A The same thing. There was always two men
15
16 checking the level columns on the heaters.
17
18 Q Did you see what they were doing with the
19
20 packing?
21
22 A Alls I could see is they were pulling some out
23
24 and replacing it.
25
358: 1 Q Did you see them cutting it?
2
3 A They had to cut it to get the right size to fit
4
5 around the steam.
6
7 Q Okay. But did you see them actually
8
9 cutting it?
10
11 A Yes.
12
13 Q While you were a technicians helper or a
14
15 technical assistant, at any time did you see the
16
17 packaging that the packings came in?
18
19 A No, no, no.
20 Q Could you tell the names of the
21
22 manufacturers of any of the packing that these people
23
24 were working with?
25
359: 1 A The only names I knew of was I saw in the
2
3 storeroom like Garlock and Anchor.
4
5 Q When was that, though, was that during
6
7 while you were a technicians helper?
8
9 A While I was working on other packing materials.
10
11 It would be both when I was a helper and a technical
12
13 assistant. Not — retract that. Not while I was a
14
15 technical assistant. When I was a helper in the
16
17 equipment operator helper.
18
19 Q Okay. Im talking about — right now Im
20
21 just talking about when you were a technicians helper
22
23 or technical assistant.
24
25 A The only times I saw that is when it was in the
360: 1
2 storeroom or when there was other people working.
3
4 Q Okay. But do you have a specific
5
6 recollection of seeing packaging from packing while you
7
8 were a technicians helper or a technical assistant?
9
10 A Only in the storeroom.
11
12 Q What manufacturers, if any, can you recall
13
14 that you saw at those times?
15
16 A The only three names that I remembered were
17
18 Anchor, Garlock.
19 Q Any others?
20
21 A The other one I cant think of the name right
22
23 now.
24
25 Q Okay. You also stated when you were a
361: 1
2 technician from 1963 to 1987 you worked next to people
3
4 that were working with packing; correct?
5
6 A Thats correct.
7
8 Q Can you tell me how often you worked next
9
10 to these people during that time?
11
12 A It might have been for two weeks during an
13
14 outage. Whenever we did, you know, the whole heater
15
16 calibration job.
17
18 Q At that time did you see any packaging
19
20 that the packing came in?
21
22 A Not packing. I just saw packing on reels or
23
24 whatever they had in their hands.
25
362: 1 Q Could you tell who the manufacturer of the
2
3 packing was at that time?
4
5 A No.
6
7 Q How far were you from the people working
8
9 with packing during that time?
10
11 A We were just, again, a few feet away.
12
13 Q Do you remember any of the names of those
14
15 people that were working with the packing?
16
17 A No.
18 Q How about while you were an instrument
19
20 supervisor, did you at any time have to handle or work
21
22 next to anyone working with packing?
23
24 A No.
25
363: 1 Q While you were a supervisor, do you
2
3 remember seeing any packing packaging or boxes or
4
5 anything like that?
6
7 A Again, only in the storeroom.
8
9 Q Was it the same manufacturers that you
10
11 talked about earlier?
12
13 A Thats correct.
14
15 Q Do you know if the Crane packing contained
16
17 asbestos?
18
19 A I was told it did, I wasnt sure.
20
21 Q Who told you that?
22
23 A Whoever was working with it.
24
25 Q Do you remember who that was?
364: 1
2 A No.
3
4 Q Did you ever have to test samples of
5
6 packing?
7
8 A No.
9
10 Q To determine if it contained asbestos?
11
12 A No.
13
14 Q Did you ever put in a purchase order to
15
16 buy any packing?
17 A No.
18
19 Q You also stated earlier that there were
20
21 times you had to either work on or near feed water
22
23 heaters; is that correct?
24
25 A Thats correct.
365: 1
2 Q And you said there was packing around
3
4 those?
5
6 A There was packing — theres a lot of valves on
7
8 feed water heaters and the maintenance department
9
10 packed the valves that were around them.
11
12 Q Were they packing them while you were
13
14 working on the feed water?
15
16 A While we were working on the feed water
17
18 instrumentation, yes.
19
20 Q How often would that occur?
21
22 A Its like every outage. Its done on every
23
24 outage in every unit.
25
366: 1 Q Is that again about two weeks?
2
3 A Yeah, you could spend a good two weeks on the
4
5 whole chain of heaters.
6
7 Q And during the whole two weeks were the
8
9 maintenance people working with packing?
10
11 A Packing and insulation, yes.
12
13 Q Do you remember the model number or serial
14
15 number on any of the Crane packing?
16 A No.
17
18 Q Do you know what types of or what the heat
19
20 temperature was that the packing was exposed to?
21
22 A What the temperature that it was exposed to?
23
24 Q Yes.
25
367: 1 A It depended on what heater they were working on.
2
3 Q Do you know the maximum?
4
5 A Yeah, you could have up to 800 degrees.
6
7 Q And how about the minimum?
8
9 A The minimum could have been 100 degrees.
10
11 Q Do you know what pressure that the packing
12
13 was exposed to?
14
15 A The pressures were any where from 800 pounds
16
17 down to 100 pounds, 50 pounds.
18
19 Q Do you know what was in the lines that the
20
21 valves were used for?
22
23 A Yes, it was, I believe, steam from the turbine
24
25 and water being heated inside the heater.
368: 1
2 Q Do you know if there was any acids or
3
4 alkalines in those lines?
5
6 A Not — there shouldnt have been.
7
8 Q When you handled the packing could you
9
10 tell if it was braided or woven?
11
12 A Yes, it was braided.
13
14 Q Sir, Im going to read you a list of
15 manufacturers of packings and gaskets, Id like you to
16
17 tell me if you know of any of these names.
