PLEASE NOTE: THIS DOCUMENT HAS BEEN REDACTED 706413 *. , . GE lighting /*«/•«/ fttnnr Vo IS/S f/U/f flnnff Heiafuli Cn»tiimt. OH u 112 June 21,1996 VIA FAX: (908} 906*182 Ms. Marissa Wiggett Emergency and Remedial Response Division U.S. Environmental Protection Agency, Region II 2890 Woodbridge Avenue Edison, NJ 08837 Re: Response of General Electric Company to 104(e) Request for Information Re: 722 Grand Street Site, Hoboken, New Jersey Dear Ms. Wiggett: This letter is General Electric Company's (GE's) response to the second I04(e) request for information on the 722 Grand Street site, Hoboken, NJ, (the "Site"). GE has conducted an investigation of its records and current and former employees. GE reserves the right to supplement its responses if additional information becomes available. In addition, GE sets forth the following general objections to the Information Request to preserve its rights. 1. GE objects to the Information Request to the extent that its instructions, definitions, and questions, both individually and collectively, are arbitrary and capricious, unduly burdensome, overbroad, vague, unreasonable, or an abuse of discretion. See, e.g.. U.S. v. Morton Salt Co.. 338 U.S. 632,652 (1950); Dow Chemical Co. v. Alien. 672 F2d 1262 (7th Cir. 1982). 2. GE objects to the Information Request to the extent it encompasses information that is not relevant to the Site. 3. GE objects to the requirements that the response be notarized and certified. This request exceeds the statutory authority of U.S. ERA. • The following is GE's response to the specific requests for information: 706414 Ms. Marissa Wiggett -2- June 21 1996 I REQUEST FOR INFORMATION 1 . Provide the current names, addresses and telephone numbers for the following persons and Indicate the years they were employed by the General Electric Company: RESPONSE Name Full Nime & Address Phone No. Years at GE a. b. c. d. e. 1 'Deceased «• * Our pension recofds indicate multiple employees/former employees with this name. We have not determined who.if any, had a connection to the Hoooken Site. 706415 Ms. Marissa Wiggett • 3 - /une 21,1996 9- h. I. » k. 2. Describe uVn» @r;$n of She Gsf**^/ ^"'cr ?c *-£ppf <Larop Company seal which appears on several deeds attached to your March 8, 1996, Information Request response. Specifically, describe why the year "1910"appears on the seal. RESPONSE We have not been able to identify the origin of the Genera) Electric Vapor Lamp Company seal. Attachment 1 contains a response from the New Jersey Department of State, Division of Commercial Recording which indicates that the Cooper Hewitt Electric Company (which was renamed the GE Vapor Lamp Company in 1930) was incorporated in New Jersey in 1910. 3. With regard to your March 8, 1996, response to EPA's Information Request, specifically identify each former employee referenced in your response to the following: a. request *4; RESPONSE 3 See footnote num&er 2. 4 Deceased -.. 7064.16 15 JUN 21 'S6 17:IB FR CENTRflL EHS 216 TO 81212637309S Ms. Marissa Wiggett -4- June2l, 1996 6. request *5; RESPONSE c. /eguesf #5,9. r 0,11,12 and 14; RESPONSE d. request *13. RESPONSE 4. State whether any Glow lamps manufactured in the 722 Grand Street building from 1910 to 1955 contained mercury, tt your answer is anything but an unqualified "no": RESPONSE During an interview with he stated that a small quantity of glow lamps were manufactured that used about 2 milligrams of mercury in each lamp. We have not confirmed this but, most glow lamps were made with neon and did not contain mercury. a. describe the amount, of mercury they contained using the most precise unit of measurement possible; RESPONSE Although the actual amount of mercury contained in a glow lamp is unknown, Patent #2,199,956 (Attachment 2) for a mercury vapor glow lamp indicates "a few cubic millimeters" of mercury was introduced into the bulb to give the bulb from "one to three cubic millimeters of mercury after sealing off." b. state the number of 'Glow Lamps containing mercury which were manufactured In the 722 Grand Street building per week, the number manufactured per month, and the number manufactured per year; 70641 _ _——-——————— -_ . c.oo ooojT<^ u i c. i c.o j r o«y ooFTc JUN *l'bb l<-:ifc i-K UtrsiKHL. ens «• D 1 o coo ' Ms. Marisea Wiggett - 5 • June 21,1996 RESPONSE Based on a search of our records, GE could not determine the manufactured quantity of glow lamps containing mercury. Attachment 3 is copies of documents from 1947 that appear to specify lamp quantities for certain months of that year. Due to the cryptic nature of the headings we are not certain as to what the handwritten figures or lamp type headings exactly represent. c. list the years in which the Glow Lamps containing mercury were manufactured In the 722 Grand Street building. RESPONSE; Based on a search of our records, no information is available to determine the exact years in which glow lamps containing mercury were manufactured in the 722 Grand Street building, if ever. However, ; stated that a small quantity of argon glow lamps, which contained approximately 2 mg of mercury, were manufactured on the 5th floor of the 722 Grand Street Building. We have not been able to confirm this. 5. State whether any Cooper-Hewitt type lamps manufactured In the 722 Grand Street building from 1910 to 1955 contained mercury. If your answer is anything but an unqualified "no": RESPONSE All Cooper-Hewitt type lamps contained mercury. However, to the best of our knowledge, no Cooper-Hewitt type lamps were manufactured ai 722 Grand Street from 1928-1948. a. describe the amount of mercury they contained using the most precise unit of measurement possible; RESPONSE Although the actual quantity of mercury contained in Cooper-Hewitt type lamps is unknown, patent #1,658,622 (Attachment 4) for a shipping case for this type of lamp, indicated that each lamp contained about a half a pound of mercury. We understand that Cooper-Hewitt type lamps were made in different sizes (lengths) and contained different amounts of mercury. b. state the number of Cooper-Hewitt type lamps containing mercury which were manufactured In the 722 Grand Street building per week, the number manufactured per month, and the number manufactured per year; 706418 ivis. Marissa Wiggett -6- June21,1996 RESPONSE Based on a search of our records, GE could not determine the manufactured quantities of Cooper-Hewrtt type lamps. Attachment 3 is copies of documents from 1947 that appear to specify lamp quantities for certain months of that year. Due to the cryptic nature of the headings we are not certain as to what the handwritten figures or lamp type headings exactly represent. We believe that no Cooper-Hewitt type lamps were manufactured in that building that year. c. list the years in which the Cooper-Hewitt type lamps containing mercury were manufactured in the 722 Grand Street building. RESPONSE Based on interviews with and we presently believe that Cooper-Hewitt type lamps were manufactured at 722 Grand Street from 1910 to 1928. In addition, Cooper-Hewitt 2 manufactured Cooper-Hewitt type lamps at 722 Grand Street from 1948 to possibly as late as 1964. 6. Identify the vendor(s) from which Cooper-Hewitt 1, General Electric Vapor Lamp, General Electric and Cooper-Hewitt 2 purchased mercury for their Hoboken operations. State the amount purchased per week, per month and per year from the vendor(s). Provide the name and address of the vendor(s). RESPONSE Based on a search of our records, no information is available regarding any specific vendors from whom the Hoboken operations may have purchased mercury. recalled that mercury may have been purchased from a company called Metal Salts in New York. 7. Describe any policy which Cooper-Hewitt 1, GE Vapor Lamp Company, GE, or Cooper Hewitt 2 had regarding how to handle spills of mercury at 722 Grand Street or 410 Eighth Street Provide a copy of any written policy. RESPONSE Based on a search of our records, no information is available that describes a policy regarding how to handle mercury spills. Our interviews with did indicate that due to the high cost of mercury, special care was taken in its handling. For example, a large stainless steel catch basin pan was placed to catch any possible spills when mercury was transferred from one container to another. In the event of a spill, employees would use hand brushes to collect the mercury. Presumably, mercury collected from any spills would be returned to the purification system on the first floor. * 706419 >.9? 1T.I7 FR CENTRRL EHS 216 266 6663 TO 812126373096 P.0B/15 Ms. MariSoo VViggett • 7 - June 21,1996 Administrative depositions were taken by the EPA of and both of whom worked with mercury at the 410 Adams Street building in the 1940's. Neither deponent remembered being given a written policy regarding the handling of spilled mercury. Both stated that if any mercury was dropped in their work areas, it was swept up or collected and reused. recalled that the table where she worked with the mercury had "walls" around it that would retain any mercury that may have spilled and could then be easily collected. See copies of relevant pages as Attachment 5. 8. Describe in detail (amount stored per week/month/year; type of storage container used, whether storage container was covered, where storage containers were placed, etc...) the storage of mercury in the 722 Grand Street building: a. from 1910 to 1928; b.