August 13, 2004

I was an employee of Mathieson Chemical Company/Olin Corporation in
Pasadena, Texas from 1952 until 1994.

My job classifications during this period were

I have been told that, in the early 1950’s, uranium was present in this Mathieson
Chemical Company/Olin Corporation plant. I did not know about the presence of
uranium or its hazardous waste products.

No safety precautions were taken, no warning signs were posted, no monitoring
was done, no monitoring devices were worn, and I did not know that I, or anyone else,
was in danger of exposure to hazardous materials.

_SUBSCRIBED AND SWO TO before me, the undersigned authority, on this
the /D day of Uk Zaza A, 2004. |

MW YY,
NOTARY PUBLIC

erpre pen


August 7, 2004

I was an employee of Mathieson Chemical Company/Olin Corporation in
Pasadena, Texas from 1945 until 1977.

My iob classifications during this period were
n _ and then the last few years, I went back to work in the
due to a reduction in force.

I have been told that, in the early 1950’s, uranium was present in this Mathieson
Chemical Company/Olin Corporation plant. I did not know about the presence of
uranium or its hazardous waste products.

No safety precautions were taken, no warning signs were posted, no monitoring

was done, no monitoring devices were worn, and I did not know that I, or anyone else,
was in danger of exposure to hazardous materials.

SUBSCRIBED AND SW‘ TO before me, the undersigned authority, on this
the / day of 2004. ,

NOTARY PUBLIC

34


Page 32

NEW EVIDENCE

EXHIBIT C

AFFIDAVITS OF FOTIR FORMER FMPT OVERS OR MATHTRSON CHEMICAL,

_ This is new evidence in the sense that these affidavits were also submitted to
the Hearing Representative on September 1, 2004, but I was not told that these were ever
considered. These gentlemen were all long-time employees at Mathieson Chemical
Company and each one stated that he did not know about the presence of uranium or its
hazardous waste products in the plant. Each also stated that no safety precautions were
taken, no warning signs were posted, no monitoring was done, no monitoring devices
were worn, and he did not know that he or anyone else was in danger of exposure to
hazardous materials. These affidavits were made in August 2004. Three of these
gentlemen have died of cancer.

Rane Affidarite attached:


August 7, 2004

I was an employee of Mathieson Chemical Company/Olin Corporation in
Pasadena, Texas from 1950 until 1980.

My job classifications during this period were

J have been told that, in the early 1950’s, uranium was present in this Mathieson
Chemical Company/Olin Corporation plant. I did not know about the presence of
uranium or its hazardous waste products.

No safety precautions were taken, no warning signs were posted, no monitoring

was done, no monitoring devices were worn, and I did not know that I, or anyone else,
was in danger of exposure to hazardous materials.

ve Fine D SWORN TO before me, the undersigned authority, on this

NOTARY PUBLIC

53


August 7, 2004

I was an employee of Mathieson Chemical Company/Olin Corporation in
Pasadena, Texas from February 1950 until May 1950 when I was laid off. I went back to
work there in August 1950 and worked there until September 1990.

My job classifications during this period were

T have been told that, in the early 1950’s, uranium was present in this Mathieson
Chemical Company/Olin Corporation plant. I did not know about the presence of
uranium or its hazardous waste products.

No safety precautions were taken, no warning signs were posted, no monitoring
was done, no monitoring devices were worn, and I did not know that I, or anyone else,
was in danger of exposure to hazardous materials.

SUBSCRIBED AND SWO!

the 7_ day of

TO before me, the undersigned authority, on this
104.

Pua» Lay

NOTARY PUBLIC N |

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