DEPARTMENT OF LABOR
Employment and Training Administration
TA-W-59,071

UCAR CARBON COMPANY, INC
A GRAFTECH INTERNATIONAL LTD COMPANY
CORPORATE HEADQUARTERS
WILMINGTON, DELAWARE

Negative Determination Regarding Eligibility
To Apply For Worker Adjustment Assistance
And Alternative Trade Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974, as
amended (19 USC 2273), the Department of Labor herein presents the
results of an investigation regarding certification of eligibility
to apply for worker adjustment assistance.
The investigation was initiated on March 22, 2006 in response
to a petition filed on behalf of workers at UCAR Carbon Company,
Inc., a GrafTech International Ltd. Company, Corporate
Headquarters, Wilmington, Delaware. The workers at the subject firm
are engaged corporate administrative functions including corporate
and legal governance, finance, treasury and investor relations, tax
planning & compliance, internal audit and strategic risk
assessment, accounting and financial control, and mergers and
acquisitions.
In order to be considered eligible to apply for adjustment
assistance under Section 223 of the Trade Act of 1974, the worker
group seeking certification (or on whose behalf certification is
being sought) must work for a "firm" or appropriate subdivision
that produces an article domestically and there must be a
relationship between the workers' work and the article produced by
the workers' firm or appropriate subdivision. The investigation
revealed that although production of an article(s) occurred within
the firm or appropriate subdivision, the workers at the Corporate
Headquarters facility do not directly support this production. Thus
the worker group can not be considered import impacted or affected
by a shift in production of an article.
The predominant cause of worker separations is the relocation
of the leased Wilmington facility to a facility owned by the
company located in Ohio. It is anticipated that the elimination of
a separate, leased corporate office will result in cost savings.
In addition, in accordance with Section 246 the Trade Act of
1974 (26 USC 2813), as amended, the Department of Labor herein
presents the results of its investigation regarding certification
of eligibility to apply for alternative trade adjustment assis-
tance (ATAA) for older workers.
In order for the Department to issue a certification of
eligibility to apply for ATAA, the worker group must be certified
eligible to apply for trade adjustment assistance (TAA). Since
the workers are denied eligibility to apply for TAA, the workers
cannot be certified eligible for ATAA.


Conclusion
After careful review, I determine that all workers of UCAR
Carbon Company, Inc., a GrafTech International Ltd. Company,
Corporate Headquarters, Wilmington, Delaware are denied
eligibility to apply for adjustment assistance under Section 223
of the Trade Act of 1974, and are also denied eligibility to
apply for alternative trade adjustment assistance under Section
246 of the Trade Act of 1974.
Signed in Washington, D.C., this 3rd day of April, 2006

/s/Richard Church
______________________________
RICHARD CHURCH
Certifying Officer, Division of
Trade Adjustment Assistance