Document 7MVvLBoO9GVyz12kawJmaxOb6
CIRCUIT COURT OF KANAWHA COUNTY WEST VIRGINIA
IN RE: ASBESTOS
) )
) No. 92-C-8888
) )
TELEPHONE DEPOSITION OF JOHN
MANGAN
a witness herein, called by the Plaintiffs for examination,
taken pursuant to the Federal Rules of Civil Procedure, by
and before Barbara D. Bombara, a Registered Professional
Reporter and Notary Public in and for the Commonwealth of
Pennsylvania, at the offices of Henderson & Goldberg,
1030 Fifth Avenue, Pittsburgh, PA on Thursday, August 26,
1993, at 2:00 p.m.
Powers and Garrison
The Court Reporters
600 Warner Centre Pittsburgh, Pennsylvania 15222
Phone: (412) 263-2088
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LAWYER'S NOTES
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2 3 INDEX
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5 WITNESS
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6 JOHN J. MANGAN
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Examination by Mr. Elmer..............................................
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8
9 EXHIBITS
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10
PLAINTIFF'S DEPOSITION NO. 1....................................................
5
11 PLAINTIFF'S DEPOSITION NO. 2.................................................... 26
12 PLAINTIFF'S DEPOSITION NO. 3.................................................... 43
13 PLAINTIFF'S DEPOSITION NO. 4.................................................... 51
14 PLAINTIFF'S DEPOSITION NO. 5.................................................... 58
15 PLAINTIFF'S DEPOSITION NO. 6.................................................... 63
16
17 COUNSEL PRESENT:
18 For the Plaintiff:
19 Henderson & Goldberg
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(NOT AN ORIGINAL],,
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20 by Michael Elmer, Esq.
21 For the Defendant, Hedman Mines:
22 Kenneth Robb, Esq.
23 For the Defendants, Foster Wheeler Corporation, Plibrico Company and Seegott, Inc.:
24 Gorr, Moser, Dell & Loughney
25 by Carl H. Shelly, Esq.
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3 For the Defendant, CSR, via telephone;
4 Louis, Freedburg, Glasser, Kasey & Rollins by Richard Gottlieb, Esq.
5 For the Defendant, Metropolitan Life Insurance
6 Company, via telephone:
7 Bowles, Rice, McDavid, Graff & Love by Anthony Damiani, Esq.
8 For the Defendant, LAC d' Amiante du Quebec,
9 Ltee, via telephone:
10 Porzio, Bromberg & Newman by Francis Fazio, Esq.
11 For the Defendant, A&I Company, via telephone:
12 Goodwin & Goodwin
13 by David Fenwick, Esq.
14 For the Defendant, Foseco, via telephone:
15 Dickie, McCamey & Chilcote by Hunter McGeary, Jr., Esq.
16 For the Defendant, Insul Company, Inc.,
17 via telephone:
18 Zimmer & Kunz by Alexander Bickett, Esq.
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1 2 3 PROCEEDINGS 4 5 MR. ELMER: Please just identify who 6 you are and who you represent so the court reporter 7 can get that down. 8 MR . GOTTLIEB: Richard Gottlieb. 9 MR . ELMER: You're here on behalf of 10 which defendant? 11 MR . GOTTLIEB: CSR, Limited. 12 MR . FAZIO: Frank Fazio, Porzio, 13 Bromberg & Newman. 14 MR . McGEARY: Hunter McGeary. 15 MR . ELMER: Mr. McGeary, you're here 16 representing who, please. 17 MR. McGEARY: Foseco. 18 MR . ELMER: Mr. Fazio, you're 19 representing who? 20 MR. FAZIO: LAC.
21 MR. ELMER: Thank you.
22 MR. FENWICK: David Fenwick here 23 representing A&I Company. 24 MR. DAMIANI: Tony Damiani. I'm here 25 on behalf of Metropolitan Life Insurance Company.
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5 1 2 3 (Whereupon, a brief off-the-record 4 discussion was held. ) 5 MR. ELMER: Good afternoon everyone. 6 I'm Mike Elmer here on behalf of the plaintiffs, and 7 we're all here pursuant to the Notice of Deposition, 8 In Re: Asbestos, Civil Action No. 92-C-8888. 9 That's Kanawha County, West Virginia. 10 This is a deposition of a 11 of Hedman Mines pursuant to West Virginia Rule 12 30-B-6 held pursuant to the Notice of Deposition, 13 and that notice will be marked as Plaintiff's 14 Exhibit No. 1 and attached to the deposition. 15 Before we go, I guess we can go ahead and 16 stipulate pursuant to the West Virginia rules of 17 civil procedure that all objections except as to the 18 form of the question will be reserved until time of 19 trial. Is that agreeable to everyone? 20 MR. GOTTLIEB: Yes. 21 (Whereupon, Plaintiff's Exhibit No. 1 22 was marked for identification.) 23 MR. ELMER: Now, based on that, our 24 deponent, Mr. Mangan, is he on the line? 25 THE WITNESS: Yes, I am. Is Ken Robb
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6 1 J. Mangan - by Mr. Elmer 2 3 on the line? 4 MR. ROBB: I'm here, Pat. 5 6 EXAMINATION 7 BY MR. ELMER: 8 Q. Now, Mr. Mangan, again, my name is Mike 9 Elmer, and I'm here on behalf of the plaintiffs. 10 Let's see. We just had - 11 MR. SHELLY: Carl Shelly. 12 MR. ELMER: Representing? 13 MR. SHELLY: Foster Wheeler, Plibrico 14 and Seegott . 15 MR. ELMER: Who is appearing pursuant 16 to Notice. He has just made his entrance. Let the 17 record so reflect. 18 Q. Mr. Mangan, again, I'm Mike Elmer. If you 19 have any problems hearing me, I want you to let me 20 know. Okay? 21 A. I'm wearing a hearing aid. 22 Q. Good. Thank you. 23 A. I'm hoping it works. It's only recent 24 that I have. 25 Q. Okay. I hope it's one of the more current
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7 1 J. Mangan - by Mr. Elmer 2 3 models. Now, look, I understand you've been deposed 4 before and I'll get into that, but I just want to go 5 over the ground rules. 6 I'll be asking you questions, and all you 7 can do is give your best recollection and response. 8 If you do not understand my question or if you do 9 not hear my question, I ask you to please interrupt 10 me and just say, "Whoah, Mike I don't hear you," or 11 "I do not understand the question." Okay? Do we 12 have that agreement that you'll do that? 13 A . Yes . 14 Q. All right. Now, when you respond to my 15 question, unless you otherwise say that, "Mike, I 16 don't understand it," or, "I cannot hear you," then 17 you and I agree that you're answering a question 18 that you've heard me ask you. Will that be fair? 19 Can you agree to that? 20 A. Yes. That's fair. 21 Q. Thank you. Now, let me just ask 22 preliminarily is there anyone else in the room with 23 you? 24 A. Just my secretary. 25 Q. Just for the record would you mind if she
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8 1 J. Mangan - by Mr. Elmer 2 3 would be identified? Does anyone have any 4 objections? 5 MR. ROBB: I have no objections r 6 Pat. It's Ken. Go ahead and identify her. 7 Q. Who is that, please, Mr. Mangan. 8 A. My daughter, Jane Mangan. 9 Q. Thank you. Good afternoon, Jane. I'm 10 going to be asking you some questions. So here we 11 go, so to speak. First of all, would you state your 12 name, your address, your age? Could you do that for 13 me, please. 14 Excuse me. The court reporter has pointed 15 out something. I'm going to place you under oath. 16 So please listen to the court reporter. 17 18 JOHN J. MANGAN 19 a witness herein, having been first duly sworn, was 20 examined and testified as follows: 21 EXAMINATION 22 BY MR. ELMER: 23 Q. All right. Now, let me ask some 24 background questions. First of all, who are you and 25 where do you reside?
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9 1 J. Mangan - by Mr. Elmer 2 3 A. I'm J.J. Mangan and I reside in Timmons, 4 Ontario, Canada, and I'm 73 years of age. 5 Q. What is your educational background? 6 A. Educational background is high school and 7 business college and home courses in mineralogy and 8 geology. 9 Q. What courses did you take in mineralogy 10 and geology? 11 A . Three. 12 Q. Can you please describe for the record the 13 courses that you took? 14 A. They were courses that were put on by the 15 Department of Mines, Ontario Department of Mines in 16 Canada. 17 Q. Now, when was the first time you took a 18 course from the Ontario Department of Mines? Can 19 you give me your best shot at that, when you first 20 took a course? 21 A. Probably 1940. 22 Q. Do you have any recollection of what 23 course that was? 24 A. Well, it was just a course in prospecting. 25 Q. Then what was the next course that you
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10 1 J. Mangan - by Mr. Elmer 2 3 took from the Ontario Department of Mines? 4 A. It was geology and mineralogy. 5 Q. Can you describe for me in general what 6 was the subject matter, you know, what you took, the 7 subject matter of the course? 8 A. Well, there's a lot entailed there. 9 Q. I know. All I can ask you is to give it 10 your best shot. 11 A. Well, my best shot is practical geology. 12 Q. Did you get into any courses with the 13 Ontario Department of Mines concerning mining safety 14 and mining standards like when you were digging a 15 hole or scooping up dirt? Did you hear my question? 16 A. Me? 17 Q. Yes. 18 A Oh, I said no. 19 Q. I'm sorry. We didn't hear a response 20 here 21 A. I see. 22 Q. Have you taken any courses concerning 23 industrial hygiene or the hazards of mining? 24 A . No . 25 Q. Now, would you have any record of the
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11 1 J. Mangan - by Mr. Elmer 2 3 courses that you took with you or on the premises of 4 Hedman? 5 Do you know if you'd have any records of 6 the courses that you took? Would that be somewhere 7 in the documents at Hedman Mines? 8 A. Who ? 9 Q. Would you have any documentation or to records of the courses you have taken with respect 11 to mineralogy and geology or anything from the 12 Department of Mines? 13 A. No. Prospector's license. I have a 14 prospector's license hanging on my wall here. 15 Q. Now, what is your current position? 16 What's your title? 17 A. I'm the chairman. 18 Q. Chairman of what? 19 A. Chairman of Hedman Resources, Limited. 20 Q. How long have you been chairman? 21 A. Oh, ten years, I guess. 22 Q. Now, do you hold any financial stake in 23 Hedman Resources, Limited? 24 A . Yes, I do. 25 Q. Would you please state for the record what
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7 12 1 J. Mangan - by Mr. Elmer
2 3 is your ownership interest. 4 A. I'm a shareholder. 5 Q. What percentage of the shares do you hold? 6 A. I couldn't tell you exactly. 7 Q. Would there be a stockholders' book where 8 we could find out that information? 9 A. I guess I hold over ten percent. 10 Q. Do you hold a majority interest in Hedman? 11 A . No . 12 Q. All right. Does your family, and by 13 family I mean -- and I'm not certain of your marital 14 status, and if I say something I shouldn't say, just 15 let me know, but with respect to a wife or children 16 and you all combined, do you hold a majority 17 interest in Hedman? 18 A . No . 19 Q. By Hedman -- I just want to make sure. 20 Let's set another little ground rule. By Hedman I'm 21 referring to Hedman Mining, Limited and Hedman 22 Resources, Limited. Do you understand me there? 23 A. There's no Hedman Mining, Limited. 24 Q. There's no Hedman Mining, Limited; right? 25 A. Right.
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J. Mangan
by Mr. Elmer
2 3 Q. When did Hedman or the entity known as 4 Hedman become Hedman Resources, Limited? 5 A. Hedman Resources, Limited, I believe, was 6 in 19 -- transferred from Hedman Mines. 7 Q. Around what date was that? 8 A. I think it was probably 1983. 9 Q. Thank you. Now I'm going to ask you some 10 questions that attorneys categorize as corporate 11 history. No mystery about this. What was the 12 predecessor of Hedman Resources, Limited? What 13 entity existed before that? 14 A. Hedman Mines, Limited. 15 Q. When did Hedman Mines, Limited come into 16 existence? 17 A. Hedman Mines, Limited came into existence 18 in 1956. 19 Q. Who were the principal stockholders or
20 owners of Hedman Mines, Limited in 1956? 21 A. Diamond Prospecting Syndicate. 22 Q. Who composed Diamond Prospecting 23 Syndicate? 24 A. I did with a partner.
25 Q. Who was your partner?
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14 1 J. Mangan - by Mr. Elmer
2 3 A . Mr . Dyer.
4 Q. Is he still living?
5 A . No . He died in 1971,
6 Q. Now , with respect to 1956, was Hedman
7 Mines , Limited under Canadian law a corporation? 8 A . No .
9 Q It was what, a limited partnership or just
10 a partnership? 11 A . Just a partnership.
12 Q . Now, what is Hedman Resources, Limited?
13 Does that have stock or is it a partnership? 14 A. Stock. 15 Q. If you can answer for me, who is the 16 majority stockholder for Hedman Resources, Limited? 17 A. Majority shareholder of Hedman Resources, 18 Limited is made up of people in Austria and 19 Switzerland 20 Q. At Hedman Resources, Limited do you have a 21 stockholders' book or a stock book listing
22 shareholders?
23 A. I guess at the head office. 24 Q. Where's the headoffice? 25 A. Lively, Ontario.
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15 1 J. Mangan - by Mr. Elmer 2 3 Q . What is that address, please. 4 A . Live ly . 5 Q . Ontario? 6 A . Ontario . 7 Q What's the street address, please. 8 A . 106 Fielding Road. 9 Q. That is Lively, Ontario? 10 A . Yes . 11 Q. What is the ZIP code there? 12 A . POM 2 EO. 13 Q. Does that office have a phone number? 14 A . Yes. 15 Q- Would you mind giving me that phone 16 number? 17 A . 705-8203. 18 Q. With respect to the Austrian and Swiss 19 shareholders, are there any corporations involved? 20 A . I believe, yes. There's a corporation in 21 Austria. 22 Q * Do you know the name of that corporation? 23 THE OPERATOR: Mr. Bickett is now on 24 the line. 25 MR. ELMER: Thank you.
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16 1 J. Mangan - by Mr. Elmer 2 3 A. Actually it's a new corporation, they just 4 did a private placement. 5 Q. Can you please tell me that corporation 6 and when the private placement occurred. 7 A. By the way, these people have nothing to 8 do with this. 9 Q. I hear what you're saying. 10 A. Actually it's just a private placement 11 that went through to the stock exchange. These 12 people haven't had anything to do with the company 13 until just the end of July or August I guess. 14 Q. Thank you. 15 (Whereupon, a brief off-the-record 16 discussion was held.) 17 Q. I just had a conference with your 18 counse1. 19 MR. ELMER: If this needs to be 20 pursued can I - 21 MR. ROBB: Sure. No problem. 22 Q. That's all right, Mr. Mangan. If I need 23 any follow up on these questions, I will present 24 them to Mr. Robb and he can supply me that 25 information.
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17 1 J. Mangan - by Mr. Elmer 2 3 A. Okay. That's right. 4 Q. Now, prior to -- just around recently, did 5 either Hedman Mines, Limited or Hedman Resources, 6 Limited have any other predecessor company? 7 A . No . 8 Q. Were there any subsidiaries to either 9 Hedman Mines, Limited or Hedman Resources, Limited 10 at any time? 11 A. Can you hear me? 12 Q. I'm sorry. I didn't hear you. 13 A . No . 14 Q. Has either Hedman Mines, Limited or Hedman 15 Resources, Limited other than what you've just told 16 me had any mergers, consolidations, purchase of 17 assets of any entity or the selling of any entity, 18 any other entity? 19 A. Would you repeat that? 20 Q# All right. Has either Hedman Mines, 21 Limited or Hedman Resources, Limited had any other 22 merger, consolidation or purchase of assets of any 23 other entity or by any other entity other than what 24 you just got through telling me? 25 A. Did you get that?
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18 1 J. Mangan - by Mr. Elmer
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3 Q No, I didn't. What is your answer again.
4 please .
5 A . Pardon?
6 Q. What is your answer again, please.
7 A . No .
8 Q. So if I understand you correctly, the only
9 other corporations or entity in which Hedman Mines 10 or Hedman Resources is now involved with is the
11 corporation for which the private placement was just
12 made ?
13 A. That's right.
14 Q. Now, can you tell me what did Hedman
15 Mines, Limited do beginning in 1956?
16 A. It was incorporated.
17 Q. What business was Hedman Mines, Limited in
18 in 1956? What was the corporation all about? What
19 did it do?
20 A. It was incorporated by two
who
21 had been prospecting on the site.
22 Q. For what were they prospecting?
23 A. Anything at all, any mineral at all.
24 Q. Now, in 1956 did Hedman Mines, Limited
25 mine any mineral?
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19 1 J. Mangan - by Mr. Elmer 2 3 A . No . 4 Q . Nothing? 5 A . No . 6 Q. When was the first time that Hedman Mines, 7 Limited, regardless of the amount, mined a product? 8 What was the date? 9 A. February 1969, I believe. That was the 10 first day following testing period. 11 Q. All right. I have some information that 12 perhaps there was a pilot mill and maybe more -- I 13 don't know -- going from 1964 at least. Would that 14 15 A. That would be correct. 16 Q. Was there anything, pilot mill or any 17 mining, occurring before 1964? 18 A. Before when? 19 Q. Before 1964. 20 A. No, 21 Q. Now, in 1964 what was being mined? 22 A. Hedmanite. 1964 we were testing. 23 Q. What was the product being mined? 24 A Hedmanite 25 Q. Was any Hedmanite being sold in 1964 to
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20 1 J. Mangan - by Mr. Elmer
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3 any other entity?
4 A . No .
5 Q. So what was happening to the Hedmanite
6 that was being mined in 1964?
7 A. It was being tested.
8
Q. It was tested.
For what was it tested?
9 A. It was being tested to find out whether we 10 could mill it, what kind of a mill.
11 Q. Now, would you please describe for me all
12 the tests that were done on Hedmanite in 1964. Were
13 you trying to figure out the ingredients and the
14 quality of this Hedmanite?
15 A. We were just trying to find out what it
16 would produce.
17 Q. What tests did you work on to see -- what
18 tests did you have performed to see what could be
19 produced? 20 A. We actually did screening.
21 Q. You did screening?
22 A. That's right.
23 Q. Would you please describe. What
24 occurs -- you know, I'm not an engineer. What
25 occurs when you're doing screening?
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21 1 J. Mangan - by Mr. Elmer 2 3 A, You're doing the same thing as a cook 4 would do with flour. You crush rock real fine, 5 create a powder, grain, you put it through a screen 6 or a sieve. 7 Q. Did you test the Hedmanite to see what 8 were its ingredients, what composed Hedmanite? 9 A. It was a fine powder. 10 Q. Did you run any analysis as to what were n the ingredients of this fine powder, like 12 minera 1ogica 1 tests? When I see a powder, it's got 13 to be composed of something. Did you run any tests 14 to see what was contained in that powder? 15 A . No . 16 Q. I didn't hear you? 17 A. I'm not too sure what we did at that time 18 other than to find machinery that would produce the 19 product, find out what the machinery would do. 20 Q. Let me ask it this way: What is 21 Hedmanite? 22 A. Hedmanite is a lizardite mineral. 23 Q. When did you find out what you were mining 24 was a lizardite mineral? 25 A. When we were running the pilot mill.
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22 1 J. Mangan - by Mr. Elmer
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3 trying to get the pilot mill designed.
4 Q. That would be at least in 1964? A. It would probably be in '64, thereabouts. I
5
6 Q. Well, what tests did you run to ascertain
7 that what you were digging out was a lizardite
8 minera1?
9 A. The Ontario Securities Commission 10 geologist determined that that was the product we 11 were producing.
12 Q. That was the Ontario Securities
13 Commission?
14 A. R ight .
15 Q. Geo1ogis t ?
16 A. Well, he was the inspector for the
17 Securities Commission.
18 Q. Now, did he run tests? 19 A. He claims that's what it was.
20 Q. Now, do you have records of -- in your authority, control or possession concerning the
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22 Ontario Securities Commission geologist?
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23 A. No. He's dead.
24 Q. But does Hedman Resources, Limited have
25 those records?
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23 1 J. Mangan - by Mr. Elmer 2 3 A . No . 4 Q. What happened to them? 5 A. God knows. He took them with him. 6 Q. Can you tell me his name? 7 A. Hans Srohberg , S-R-O-H-B-E-R-G. 8 Q. Was he an independent geologist or an 9 employee of the Ontario Securities Commission? 10 A. I couldn't tell you. That was between he 11 and t hem. 12 Q. Now, you've previously told me that you're 13 a prospector? 14 A. That's right. 15 Q. I would kind of guess that when you're 16 mining something, it's because you want to make 17 money and sell a product? 18 A. That's the idea if you can find it. 19 Q. Now, to figure out the uses of a product 20 you got to know its minera1ogica1 and chemical 21 characteristics. Would you agree with that? 22 A. You would like to. 23 Q. Now, when was the first time that you 24 tested what was coming out of the mine that you were 25 beginning to mine? When was the first time that you
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2 3 said, "Hey, I got something, but I need to know the 4 ingredients"? 5 A. I guess when we designed or were working 6 on design of the technical bulletin. 7 Q . Of the what? 8 A. Technical bulletin. 9 Q. When was the first time that you put out a 10 technical bulletin -- well, that's what is called a 11 technical data sheet? 12 A. No. It's technical bulletin. 13 Q. When did you put out a technical bulletin? 14 A. God knows. I couldn't tell you. At my 15 age and that time, it's a long time ago. 16 Q. Would it have been around 1964? 17 A. I honestly can't tell you. 18 Q. Now, does Hedman Mines Resources, Limited 19 or you or any of your family or any of the 20 stockholders have any of these technical bulletins? 21 Do you have documents? You know, a 22 document room or just a file cabinet with these 23 technical bulletins? 24 A. Ken Robb should have any of that stuff. 25 MR. ELMER: Counsel, I'd just make a
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25 1 J. Mangan - by Mr. Elmer 2 3 request on the record for the technical bulletins. 4 MR. ROBB: If I had it, you got it. 5 Whatever I had I think was attached to the Answers 6 for Request for Production. 7 Q. Mr. Mangan, I want to try to get a 8 clarification of what you mean by technical 9 bulletin, so just bear with me. Okay? 10 Now, Mr. Robb turned over to me what was 11 called a technical data sheet. 12 A. That's close enough. 13 Q. Now, you kind of got my curiosity going 14 because I'm the typical lawyer. Was there something 15 called a technical bulletin? 16 A. That's what I say, yeah. 17 Q. Who would the technical bulletin have been 18 sent to? 19 A. I guess it was sent initially to anybody 20 who we were trying to interest in Ontario. 21 Q. Besides Ontario where else was it sent? 22 A. Probably anyplace in Canada where industry 23 may be located. 24 Q. What about south of the border, the 25 Canadian border? The United States?
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26 1 J. Mangan - by Mr. Elmer 2 3 A. No, not at that time. 4 Q. Well, what do you mean at that time? What 5 time period are we talking about? 6 A. At the time that you were asking about, 7 our development, 1964. 8 Q. So would 1964 be the first time that 9 Hedman Mines put out what I'm going to call a 10 technical data sheet? 11 A. That's right. They wouldn't have gone 12 south of the border. 13 Q. Well, do you have the documents that your 14 lawyer, Mr. Robb provided me in front of you? Do 15 you have that? Do you have a document called 16 Hedmanite Technical Date Sheet? Is that in front of 17 y ou ? 18 A. I got it in front of me now. 19 (Whereupon, Plaintiff's Exhibit No. 2 20 was marked for identification.) 21 Q. Good. Now, I'm going to mark for the 22 record here as Plaintiff's Exhibit No. 2 what is 23 designated as a Hedmanite Technical Data Sheet. 24 A. What's the date on it? 25 Q. The date on this one in the upper right
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3
hand corner is 9 HNL-9-82. Okay?
Are you and I
4 looking at the same document?
5 A . No .
6 Q. What?
7 A . No .
8 Well, describe for me what you're looking
9 at?
10 A. I'm looking at 7 HRL 15-91.
11 MR. ELMER: Counsel, I'm just going
12 to make a request that that document be produced,
13 please
14 A. What did you say the number was that
15 you're looking at?
16 Q. The number I'm looking at in the upper
17 right-hand corner, it has Hedmanite Technical Data
18 Sheet, and then that's all kind of lined in, just
19 squared in, just a little rule with the word,
20 Hedmanite on the right-hand side. Then on the very
21 top of the top line it has 9 HNL-9-82.
22 A. I have that one in front of me now. 23 Q. Good. Now, when was the first time that 24 Hedman Mines, Limited or Hedman Resources, Limited
25 put out a technical data sheet?
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28 1 J. Mangan - by Mr. Elmer
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3 A. Probably in -- it's a wild guess.
4 Q. Give me your best shot.
5
A.
I cannot tell you.
I don't know.
I'm 73
6 years old. I don't know whether I'm expected to be
7 sharper than some of the employees.
8 Q. How many employees doesHedman Mines 9 Resources, Limited have? 10 A . Eight.
11 Q. How many of thoseemployeesare actively 12 mining?
13 A. None of them.
14 Q. Is there any mining going on?
15 A . No .
16 Q. When was the last time that Hedman
17 Mines Resources, Limited mined Hedmanite?
18 A. Probably May.
19 Q. Of 1993?
20 A. I guess the last time we removed some tar
21 was May of '93.
22 Q. Now, are there periods of time when you 23 don't have orders, that you just kind of slow down
24 then you start back up again? Is that the process?
25 A. That's right. We're intermittent.
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29 1 J. Mangan - by Mr. Elmer 2 3 Q. So you're still an ongoing mining 4 company? You have plans if the orders come through 5 to keep on mining Hedmanite? 6 A. I expect so. It's pretty rough times, as 7 you all know. 8 Q. Now, with respect to the technical data 9 sheet, does Hedman Mines Resources, Limited or any 10 predecessor company or any of the majority 11 stockholders or you or your daughter have the 12 records of the technical data sheets put out by 13 Hedman? 14 I mean, do you have a file cabinet that's 15 got all of the copies of the technical data sheets 16 that were put out? 17 A. Did you hear me? 18 Q . No . 19 A . No . 20 Q You don't? 21 A . No . 22 Q. Well, you mentioned that you had one that 23 was -- that had the designation of 7 HRL 15-91? 24 A. That's right. 25 Q. Do you have copies of any other technical
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i 30 1 J. Mangan - by Mr. Elmer 2 3 data sheets with any other numbers? 4 A. No. No. That's the last one. 5 Q. So the only one -- I just want to get this 6 straight. So the only one in the authority, control 7 or possession of Hedman Resources, Limited, its 8 officers, directors or employees are the ones -- the 9 technical data sheet dated 9 HNL 9-82 and 7 HRL 10 15-91? Those are the only copies in your authority, 11 control or possession? 12 A. That's right. 13 Q. How often would you put out technical data 14 sheets? 15 A. Not very often. 16 Q. Was one put out before '69? 17 A. I couldn't tell you that because I don't 18 have it. 19 Q. Was there any requirement under Ontario, 20 Canada law, either local, regional, provincial, 21 national statute, to file your technical data sheets 22 with any entity? You know, industrial commission or 23 any other entity? 24 A . No . 25 Q. Now, what is lizardite?
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31 1 J. Mangan - by Mr. Elmer 2 3 A. Lizardite? 4 Q. Yes. 5 A. Lizardite is an industrial mineral. 6 Q. Can you tell me what are the ingredients 7 8 A. It's a dunite, D-U-N-I-T-E. 9 Q. How do you know that the Hedman fiber was 10 a dunite? 11 A. Hedman material is a fine powder. 12 Q. Right. How do you know it's a lizardite? 13 A. Based on the study. 14 Q. All right. The studies. Now, when were 15 those studies first conducted? 16 A. Literature from the United States, I 17 believe. 18 Q. But when were the studies first conducted 19 that you knew what Hedman Mining, Limited was 20 digging out of the ground? When did you first 21 realize it was a lizardite? 22 A. We knew it wasn't a fibrous material 23 because it was mostly a powder. 24 Q. When did you know the ingredients or the 25 composition of that fibrous material?
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32 1 J. Mangan - by Mr. Elmer 2 3 A. Actually the material, there's very little 4 fiber in it. We knew the material was not asbestos. 5 Q. Was not asbestos? 6 A. No, because actually the material was, 7 like, a very fine powder, as I explained. Asbestos 8 is chrysotile, and lizardite is the non-fibrous 9 portion. Cryptotene can be lizardite. And 10 tegerite, that's non-fibrous, and chrysotile can be 11 the fibrous portion. 12 Q. Now, when did you first test the mineral 13 fiber and find out its composition as you've just 14 stated to me from the Hedman Mines, Limited? 15 When is the first time that you had an 16 analysis done of the product that you were digging 17 out of the mine that Hedman, Limited was digging 18 out, was mining? 19 A. I cannot say . 20 Q. Was it around 1964? 21 A. Could be. We were doing a lot of testing 22 in that time 23 Q. Let me ask you the question in this 24 manner: If I've got a product, would you and I 25 agree that I have to know the basic characteristics
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33 1 J. Mangan - by Mr. Elmer
2 3 and ingredients in that product if I'm going to 4 market it to someone so that whoever my purchaser is 5 they are going to know the chemical characteristics 6 of that product, know what they are getting? 7 A. At that time there was no consideration 8 for that. It was the work in the product, would it 9 do a job for you. 10 Q. All right. But if you're going to sell 11 the product, is it not correct that your -- the 12 people to whom you're selling it, your purchasers 13 are going to want to know its chemical 14 characteristics to see if they can use it in their 15 end product ? 16 A. Well, they check those things out 17 t hems eIves 18 Q. Let me ask you a question straight 19 outright. In 1964 did you know that Hedmanite 20 contained -- I'm saying amounts, but had a 21 chrysotile asbestos component? 22 A. We weren't able to interest anybody in the 23 product because it was non-fibrous. The fiber in it 24 was s o sma11. 25 Q. When was the first time that you realized
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34 1 J. Mangan - by Mr. Elmer
2 3 Hedmanite contained asbestos, chrysotile asbestos? 4 A. You're talking about chrysotile asbestos? 5 Q. Right. 6 A. See the fibers in the rug? 7 Q . Right. 8 A. The smallness of the fibers in this rug 9 didn't stand a market. 10 Q. Now, when was the first time that anyone 11 at Hedman Mining, Limited or Hedman Resources, 12 Limited knew about this chrysotile asbestos being in 13 Hedmanite? 14 A. Well, you can see it on the surface in the 15 rock . 16 Q. You can see it in the surface in the rock, 17 the chrysotile? 18 A. The chrysotile was fibrous. 19 Q. So that would be since 1956? Could we 20 agree on that? 21 A. Well, I couldn't say that. Maybe 1960. 22 Q. So you and I agree that you knew or that 23 you and other employees at Hedman Mines, Limited 24 knew that the stuff you were mining had a chrysotile 25 asbestos in 1960?
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35 1 J. Mangan - by Mr. Elmer 2 3 A. Well, we could see that there was the odd 4 fiber. What we didn't know was lizardite and 5 tegerite at the time. The knowledge of that wasn't 6 until 1950 something by the U.S. Government. 7 Q. Now -- 8 A. Actually nobody knew about lizardite and 9 tegerite. 10 Q. Now, I want to go over the -- you know, 11 the technical data sheet that you have before you, 12 the one that has - 13 A. * 82. 14 Q. Yes. Did you have to approve this before 15 it went out? 16 A . No . 17 Q. Tell me the process by which this 18 Hedmanite Technical Data Sheet, Plaintiff's Exhibit 19 No. 2 was issued? How did this come to be printed? 20 A. Well, we got an engineer at that time and 21 he helped prepare it. We went over it together. 22 Q. You went over it together? 23 A. Right, I thought. 24 Q. Did you approve it and say, "Hey, go ahead 25 and issue this"?
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36 1 J. Mangan - by Mr. Elmer
2 3 A . I probably had something to say about it. 4 I can't tell you right now how the process is.
5 Q * Who was the engineer?
6 A . Earl Gagan.
7 Q How do you spell his last name?
8 A . G-A-G-A-N. He's dead.
9 Q. Is his company still in existence? Did he
10 work for any company? 11 A . No. He died. 12 Q. Now, with respect to what's on here, can 13 you and I agree that you approved of Plaintiff's 14 Exhibit No. 2, Hedmanite Technical Data Sheet, you 15 approved that being issued for Hedman Mines, Limited 16 or Hedman Resources, Limited? 17 A . I guess I would have to as chairman of the 18 board. 19 Q - Now -- 20 A . I was the prospector, so -- 21 Q- Just one second, please. Now, this 22 material safety data sheet -23 A . Yes . 24 Q -- it's got a lot of printing on it, and I 25 kind of want to go over it with you. Just one
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37 I
1
J . Mangan
by Mr . E1mer
2 3 second. I want to get my copy, please. 4 MR. ELMER: Counsel, do you have a 5 copy of that? 6 MR. ROBB: Which one? The data sheet 7 or the safety sheet? 8 MR. ELMER: The technical data sheet. 9 MR. ROBB: It's attached to the 10 Answers to Interrogatories. 11 Q. I've got mine. I just want to turn to 12 mine, that's all. One moment, please. Well, let me 13 go on to something else first. Okay? 14 A. Okay. 15 Q. Now, how is 1izardite processed or 16 Hedmanite processed for sale? 17 A. It's crushed to destruction. 18 Q. What do you mean by crushed to 19 destruction? 20 A. The dunite rock is crushed in various 21 stages, small crusher, point crusher, pulverizer
22 until it becomes a powder. 23 Q. Until it becomes a powder? 24 A. That's right.
25 Q. Then how is that powder packaged?
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38 1 J. Mangan - by Mr. Elmer
2 3 A . It's packaged in 50-pound bags. 4 Q. Fifty-pound bags? 5 A . Yes. Paper bags, trough bags. 6 Q. Now, what is the percentage of asbestos in 7 finished Hedmanite that's distributed? 8 A . Finished? 9 Q. Yes. 10 A . Of chrysotile or -- 11 Q - Well, I'll ask it this way: What types of 12 asbestos are in Hedmanite? 13 A . There's chrysotile. 14 Q. Is there any other asbestos? 15 A . In the technical data sheet, 1982 -16 Q. Well, let me ask you some questions about 17 the technical data sheet. 18 A . Okay . 19 Q. The '82 sheet. Do you have that in front 20 of you? 21 A . Yes . 22 Q. I'm going to read along. It says. 23 "Hedmanite is a natural, nonasbestos serpentine 24 2 powder"; right? 25 A . Right.
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39 1 J. Mangan - by Mr. Elmer 2 3 Q. Then it has with the quote, "With a minor 4 chrysotile impurity"? 5 A . Right . 6 Q. Why did you use the word, minor chrysotile 7 impurity or why is that used in the technical data 8 sheet ? 9 A. Because it's a minor quantity of 10 chrysotile. 11 Q. What do you consider minor? 12 A. Depending on the length of the fiber. 13 Q . The 1ength? 14 A. Yes, that's correct. 15 Q. Well, can you and I agree that Hedmanite 16 had at least a chrysotile mass of a little under 20 17 percent? 18 A. Fourteen percent. 19 Q. Fourteen percent? 20 A. Yes. 21 Q. Is that 14 percent mass, in your view, 22 minor? 23 A. Yes. 24 Q. All right. Because 14 percent of a 25 product -- I just want to get my mind clear. You
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1 J. Mangan - by Mr. Elmer
2 3 think that's just a minor chrysotile asbestos 4 component ? 5 A. That's a component in the product. The 6 average fiber length is two and a half microns. So 7 if you know what a micron looks like, there's not a 8 hell of a lot of asbestos in it. 9 Q. Well, if it's a minor chrysotile impurity, 10 why did the technical data sheet -- why did you 11 reference the chrysotile impurity? What was going 12 through your mind when that was referenced? 13 A. Could you repeat that question? 14 Q. Yes. Well, I'm looking at Plaintiff's 15 Exhibit 2, and it has minor chrysotile impurity, and 16 if in your view that was minor, then why was that 17 minor chrysotile impurity mentioned in the technical 18 data sheet? 19 A. Because it's a fact. 20 Q. Well, does that have any impact on the use 21 of the product?
22 A. Abso1ute1y . 23 Q. What is that impact?
24 A. The impact is you can't sell it as an 25 asbestos replacement.
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42 1 J. Mangan - by Mr. flraer 2 3 A. I would say if the data sheet was written 4 in '82 or printed in 1981, it could have been 5 1 970 ' s . 6 Q. Well, why is it -- if the study was done 7 in the 1970's, when would the first time be that you 8 had put out the technical data sheet then? 9 A. About 1970. 10 Q. Would be the first time that you put out a 11 technical data sheet? In 1970 would the technical 12 data sheet have then referenced the chrysotile 13 asbestos? 14 A . No . 15 Q. Why is that? 16 A. Well, we did one on a long fiber content 17 of Hedmanite found in asbestos fillers. 18 Q. What was going on in the principals or the 19 stockholders or employees of Hedman for doing this 20 study? There had to be a purpose. What was the 21 purpose of the study? 22 A. Repeat that question. 23 Q. What was the purpose of the study? 24 A. What was the purpose of the study? 25 Q. Yes.
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43
1
J . Mangan
by Mr. Elme r
2 3 A. To find out what we had, what we were 4 talking about and what you were suggesting or 5 inferring. 6 (Whereupon, Plaintiff's Exhibit No. 3 7 was marked for identification.) 8 Q. Well, I'm going to mark as Plaintiff's 9 Exhibit No. 3 a document called, "Electron 10 Microscopic Determination of Chrysotile Content of 11 Hedman, Cationic Fiber," dated December 19, 1974. 12 Do you have that document in front of you? 13 A . No, I don't . 14 Q. Would you have access to it? 15 A. That would probably be in the lawyer's 16 hands. You probably have it. 17 Q. All right. I do have it, but I just 18 wanted you to be able to have it in front of you. 19 A . No . I couldn't have it in front of 20 Q. What was the purpose of this report? 21 A. What was the purpose?
22 Q. Yes , of having the study conducted. 23 A . I couldn't tell you.
24 Q. Well , you couldn't tell me? You * re 25 business and you want to control costs. Can you and
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44 1 J. Man g a n - by Mr. E1me r
2 3 agree on that? 4 A . Pardon?
5 Q. You're a businessman; right?
6 A . That's right . I'm a prospector.
7 Q. Did you order this study conducted?
8 A . I probably did or okayed it . 9 Q. What was the purpose of okaying this 10 study. Plaintiff's Exhibit 3, which is the report 11 dated December 19, 1974 on Electron Microscopic 12 Determination of Chrysotile Content of Hedraan 13 Cationic Fiber? What was the purpose of having this 14 study made? 15 A. Probably because the newspapers were full 16 of the asbestos problems. 17 Q. So you were aware that chrysotile asbestos 18 may be a hazard? 19 A. Yes. .. 20 Q. When was the first time that you were 21 aware that chrysotile asbestos may be a hazardous 22 substance? 23 A. Probably in the seventies. 24 Q. When in the seventies? When would that be 25 in the seventies?
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45 1 J. Mangan - by Mr. Elmer 2 3 A. It would probably be -- whenever that 4 report was dated or prior to it, naturally prior to 5 it . 6 Q. It would be prior to it. Would it be at 7 least prior to it in the sixties? 8 A. No. 1974. I'm just looking at the -- 9 it's in the same Interrogatories I guess as your -10 Q. So were you able to find that article? 11 A. Pardon? 12 Q. Were you able to find the 1974 report? 13 A . That * s right. 14 Q. Have you found that now? 15 A. I have it now, yes. 16 Q. Good. I'm glad you found it. Now - 17 A. It's in somebody's -- some civil action, 18 Answers to Plaintiff's Request for Production of 19 Documents. 20 Q. Okay. Thank you. 21 A. Do you have all of that? 22 Q. Yes, I've got it. I just wanted to make 23 sure that you would have it so you can kind of 24 follow along with me. 25 A. I'm not hearing you very well.
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46 1 J, Mangan - by Mr. Elmer
2 3 Q. I wanted to make sure that you could 4 follow along with me. 5 A. Okay. 6 Q. Now, in that report there's an exhibit 7 that has fibers longer than five microns, 8 magnification 4,000, and it says, "Number percent of 9 fibers which are longer than five microns"? 10 A . Right. 11 Q. It's got an average value of 8.1 percent. 12 Have you found that? 13 A . No . 14 Q. Well - 15 A. What page would that be on? 16 Q. The only way I can do it is to tell you 17 from Page 1 where it has the date, I'm going to 18 count the number of pages that you should turn. 19 It's in the Appendix 1, the ninth page in 20 Appendix 1 21 A. Ninth page? 22 Q . Right . 23 A. Page 9. Okay. 24 Q. All right. There do you have the table 25 that has, "Average value, 8.1 percent. Number
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1
J. Man g a n
by Mr. Elmer
2 3 percent of fibers which are longer than five 4 microns"? At the bottom of the page it has 8.1 5 percent? 6 A. Average? 7 Q. Average value. 8 A. I'm not hearing you very well. 9 Q. All right. Average value, bottom 10 right-hand corner. 11 A. Okay. Average value. 12 Q. Of 8.1 percent? 13 A. Average value. 14 Q. Right-hand column next to the last 15 figure. Under the heading, "Number percent of 16 fibers which are longer than five microns"? 17 A. At what magnification? 18 Q. 4,000 X. You and I agree it says 8.1 19 percent? 20 A. No. I haven't seen that one yet. Oh,
21 okay .
22 Q. 8.1. Just from your viewpoint, is that a 23 minor chrysotile impurity?
24 A. It all depends on the length of the fiber
25 Q. Well, here it's longer than five microns.
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48 1 J. Mangan - by Mr. Elmer
2 3 You and I agree on that; 4 A. That's a 50 percent or 40 percent or 30 5 percent. It's minor in relation to 100. 6 Q. But you agree it says 8.1 percent? 7 A. That's right. 8 Q. Now, in that study - 9 A. That's chrysotile fibers. That's not 10 necessarily a fiber that is longer than five 11 mic rons. 12 Q. Well, it says, "Number percent of fibers 13 which are longer than five microns." Now, in that 14 December 14 -- well, let me make sure I have the 15 right date. December 1974 study. Plaintiff's 16 Exhibit No. 1, is there any data on the volume of 17 chrysotile asbestos fibers stated in fibers per 18 cubic centimeter of air? 19 A. I don't see it. 20 Q. All right. So that study is completely 21 devoid of any reference, you and I would agree, of 22 measuring Hedmanite with respect to the number of 23 asbestos fibers per cubic centimeter of air. 24 Is that not correct, any volumetric 25 measurement? You and I would agree on that; right?
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49
1
J. Mangan
by Mr. E1me r
2 3 A. Right. You'd have to look at the 4 magnification of weighing average fiber length. I 5 don't know what page that is. 6 Q. Okay. But in terms of -- if the Hedmanite 7 that was measured, you know, the samples here were 8 thrown up into the air or were in the air or were 9 dispersed, you and I would agree that the 10 December 19, 1974 report has no measurement or no 11 value as to the number of chrysotile asbestos fibers 12 longer than five micrometers per cubic centimeter of 13 air? You would agree on that; correct? 14 A. I couldn't say. 15 Q. Well, did you look at this report and 16 approve it before it was issued? 17 A. Pardon? 18 Q. Did you look at the December 19, 1974 19 report and approve it before it was issued? 20 A. I didn't hear you. 21 Q. Did you look at the December 19, 1974 22 report and approve it before it was issued? 23 A. I could have
24 Q. You and I would agree that with respect to
25 dispersion of Hedmanite, if it's released into the
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50 1 J. Mangan - by Mr. Elmer 2 3 atmosphere -- this report -- you don't know whether 4 it's a minor component of chrysotile that would be 5 dispersed or a major component from this report? 6 A. I don't think anybody could. 7 Q. So that value wasn't measured, meaning the 8 number of fibers? 9 A. I don't remember. You're looking at the 10 report and I just looked at it, and that's dated 11 1974. So I personally couldn't make a judgment. 12 Q. All right. Can you take the time and just 13 leaf through the report and see if you find any 14 measurements like that made? 15 A. Well, when you take a look at the 16 pictures, my analysis of the pictures would suggest 17 to me, as an intelligent person, that there couldn't 18 be a hell of a lot in the air. 19 Q. All right. But you and I would agree that 20 there's no actual study as to asbestos fibers, 21 meaning fibers longer than five microns per cubic 22 centimeter of air measured in this report? 23 A. I don't know. I couldn't tell you that. 24 If you read the report, you'd have to make that 25 assessment.
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51 1 J. Mangan - by Mr. Elmer 2 3 Q. So the report would speak for itself? 4 A . Yes. 5 Q. Now, on the -- there's another document 6 called, "Caution", the caution. Do you have a 7 document marked caution in front of you? 8 A. You say a caution? 9 Q. Yes. Just a document that has on the top 10 of it the word, caution. 11 A. Yes. Okay. 12 Q. All right. Now, when was the first time 13 that Hedman Mines put any such caution on its 14 packaging? 15 A . I don 1t know. 16 Q. Do you have any records as to when it 17 wou1d be ? 18 A. No. Any of that stuff would be gone, long 19 gone. We're looking at old stuff here. 20 Q. Right 21 A* What do the current ones -- 22 (Whereupon, Plaintiff's Exhibit No. 4 23 was marked for identification.) 24 Q. Well, just for the record so you'll know 25 what I'm looking at and the court reporter will
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52 1 J. Mangan - by Mr. Elmer
2 3 know, this will be Plaintiff's Exhibit No. 4. 4 It has at the top. Contents with, like, an 5 asterisk, and then it has non-fibrous serpentine, 6 approximately 80 percent, chrysotile mass under 20 7 percent, and then a parentheses, average fiber 8 length, two and a half microns. Do you have that 9 document in front of you? 10 A. Is that the caution one? 11 Q . Yes . 12 A. What do you have right behind the '82 13 technical data sheet? 14 Q. Well, what I'm looking at it says, 15 "Caution." In the lower corner, "Avoid creating 16 dust. Breathing asbestos dust may cause serious 17 bodily harm." Do you see that? 18 A. What are you looking at now? 19 Q. I'm looking at a document that on the very 20 top says. Contents. It's attached to your 21 production of documents. Do you have the legal 22 documents that Mr. Robb submitted in front of you? 23 It's going to have on the top of it the 24 word, contents, and then about at least, I'd say, 25 five-eighths down the page the word, caution?
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53 1 J. Mangan - by Mr. Elmer 2 3 A . That's right in the middle of it. 4 Q- Right. Do you see that? 5 A . Yes. 6 Q- Now, when did that first come out? When 7 did Hedman, Limited or Hedman Resources put this 8 caution on any package? 9 A . It's not. 10 Q - It's not ? 11 A . No . 12 Q- Well, what was this -- first of all, what 13 is this document to you? 14 A . This document is a paper bag. 15 Q. Right. 16 A . That * s right. 17 Q. Now, the document. Plaintiff's 4, that I 18 have the word caution on in front of me, what was 19 this document? Tell me in your own words. What is 20 this? 21 A . It's not a document. It's just the 22 printing on the back of the bag. 23 Q. On the bag. When was this printing on the 24 back of the bag? Can I presume that was a Hedmanite 25 bag?
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54 1 J. Mangan - by Mr. Elmer 2 3 A. That's right . 4 Q. When was this printing first put on the 5 back of a Hedmanite bag? 6 A. Probably back in '74. 7 Q. Why was this printing put on the Hedmanite 8 bag? I mean, what was the purpose of this printing? 9 A. The next page in that document -- the bag 10 says Hedmanite. 11 Q . Right . 12 A. And the caution put in there in case. 13 Q. In case of what? 14 A. In case of someone being concerned. 15 Q. Was that because of your feeling that the 16 chrysotile component of Hedmanite was capable of 17 causing lung damage? 18 A. Well, we never did have a problem in 35 19 years, so at that time we never experienced any 20 problems. But anyway, I think people said that it 21 would be a good idea to put it on the bag. 22 Q. Who advised you that would be a good idea 23 to put it on the bag? 24 A. Anybody you*re talking to. When you start 25 reading in the papers, it says put it on anything
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55 1 J. Mangan - by Mr. Elmer 2 3 that is harmful or potentially harmful. 4 Q. Did you consult lawyers concerning this 5 warning? 6 A. What they do -- 7 Q. Did you consult lawyers concerning putting 8 Exhibit No. 4 on the back of your bag? Did anyone 9 advise you to put this on the back of a bag? 10 A. I don't think so. I guess people who read 11 the newspapers and the periodicals and read all the 12 crap that went on, you're being told about these 13 things all the time. 14 Q. So who and how was the decision made to 15 put what is labeled Plaintiff's Exhibit 4 on the 16 back of the Hedman bag? 17 A. Probably the vice-president at that time. 18 Q. Who was the vice-president? 19 A. Steve Charvula. 20 Q. Is he still with the company? 21 A. No. He's gone a long time ago. 22 Q. Is he any relationship to you? 23 A. No. In 1980 he left. 24 Q. How do you spell his last name? 25 A. C-H-A-R-V-U-L-A.
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56 1 J. Mangan - by Mr. Elmer 2
3 Q Do you know where he is now?
4 A . No , I don ' t # 5 Q. Wa s he ever r e1 a ted in any way to you by 6 blood or marriage? 7 A . No .
e Q. Now, going back to the Hedmanite Technical g Data Sheet, Plaintiff's 3, it has the words, "That
10 is the category considered by the medical research ii experts to be devoid of pathogenic potential." Do 12 you see those words? 13 A. Just a second. Okay. I got *82. 14 Q. Whose language was it that that is the 15 category considered by the medical research experts 16 to be devoid of pathogenic potential? Was that your 17 language? Who put that language on there? 18 A. Yes. 19 Q. Who put that language on there? 20 A. Well, we put the language on there, but it
21 was from the -- the information provided to us from
22 the University of Charleston. 23 Q. Charleston where? 24 A. Pardon? 25 Q. Charleston where?
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57 i
1
J . Mangan
by Mr. El me r
2 3 A. Off the top of my head I can't tell you. 4 Not being in the U.S., I'm not familiar with the 5 various Charlestons in the United States. 6 Q. Okay. Did you consult with someone in 7 Charleston or how did you get to Charleston? 8 A. Well, there was a publication that was 9 given to us. 10 Q. So do you have publications and brochures 11 and technical material at Hedman Resources, Limited? 12 A. Well, I might have one of those. I'm not 13 too sure .
14 MR. ELMER: Well, I'd just make the 15 request to Mr. Robb that any and all brochures that 16 you have if we can make arrangements to have those 17 produced. 18 Q. There's one other document or maybe a 19 couple more I want to ask you about. Well, no. Let 20 me ask you. We got the technical data sheet. It
21 says, "minor chrysotile impurity"?
22 A. Right. 23 Q. Then you folks also put out a material 24 safety data sheet?
25 A. What?
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i 58 1 J. Mangan - by Mr. Elmer
2 3 (Whereupon, Plaintiff's Exhibit No. 5 4 was marked for identification.) 5 Q. Material safety data sheet. Do you have 6 that? I'll mark that as Plaintiff's Exhibit No. 5. 7 It's a document called. Material Safety Data Sheet. 8 A. Yes. Okay. 9 Q. Do you have that in front of you? 10 A. Yes. It was right behind the technical
n data sheet.
12 Q. Right. Now, when was the first time that 13 Hedman Resources, Limited or Hedman Mines, Limited 14 put out a material safety data sheet? 15 A. About the same time that I guess we put 16 out the -- '82. 17 Q. 1982? 18 A. Cou1d be. 19 Q. Could it have been in the 1970's? 20 A. Just a minute. I'll see- if I can find the 21 date here. It could have been in the seventies. 22 Q. Well, what is the best of your 23 recollection as to when Plaintiff's Exhibit 5, the 24 material safety data sheet, was first put out by 25 Hedman Resources, Limited?
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----------r 59 I
1
J. Manga n
by Mr. E1mer
2 3 A. That would be back in -- I imagine in the 4 seventies. 5 Q. All right. Do you have copies of all the 6 various material safety data sheets that Hedman 7 Resources, Limited or Hedman Mines, Limited put out? 8 A . No .
9 Q. The one in front of me says, "Hedman
10 Resources, Limited." So we know that couldn't have
11 been before 1983; right?
12 A. The reason we see them is because in these 13 cases we had the material safety data sheet at that 14 time. So we don't have any of that stuff now. 15 We're a very small outfit. There's one person in 16 the office, two people, eight people at the plant 17 when they work, if they work. 18 You know, it's a situation that -- we're 19 not a trading corporation. In other words, all 20 we -- we don't have all the information that 21 everybody would like to have.
22 Q. Because in the material safety data sheet 23 it has the heading. Section 2, hazardous components
24 of mixtures? 25 A. Yes.
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60 1 J. Mangan - by Mr. Elmer 2 3 Q. And chrysotile asbestos is listed under 4 hazardous components of mixtures; correct? 5 A. Yes. 6 Q. And yet in the Hedmanite Technical Data 7 Sheet you call chrysotile only as a minor chrysotile B impurity? 9 A. Right . 10 Q. But in the material safety data sheet 11 that's listed under hazardous components of 12 mixtures; is that not correct? 13 A. Yes. 14 Q. Well, something is wrong somewhere. 15 MR. ROBB: Wait a minute. If you 16 want to ask him questions, that's fine. If you want 17 to argue with him, I'm not going to allow you. If 18 you want to identify documents. That's fine. 19 MR. ELMER: Counsel's objection is 20 noted on the record. 21 Q. Also on the material safety data sheet 22 there's a listing for use approved respirators; 23 correct? Plaintiff's Exhibit 5, the last page? Do 24 you see the last page of Plaintiff's Exhibit 5, the 25 material safety data sheet?
POWERS & GARRISON
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61 | i
1 J. Mangan - by Mr. Elmer 2 3 A. Yes . 4 Q. And there it says, "Use approved 5 respirators if required." Do you have that page? 6 A. I'm looking through it here. 7 Q. It's on the -- it's the U.S. required 8 document, material safety data sheet. On the last 9 page of that it has, "Use approved respirators if 10 required"? 11 A. Oh, yes. Okay. That's Page 3 of that. 12 Q. Right. When your miners are mining 13 Hedmanite, do they use respirators? 14 A. When they were in the mill, the mining 15 industry in any event always has to comply with the 16 Mining Act, and the Mining Act says any dust, any 17 dust you have to wear a respirator. 18 Q. Would that dust also include chrysotile 19 asbestos dust and fiber? 20 A . No . 21 Q. What? 22 A. Silica and clay and various types of fine 23 powdered rock make a dust. 24 Q. Right . 25 A. As a result of that you have to provide
POWERS & GARRISON
Phone: (412) 263-2088
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62 1 J. Mangan - by Mr. Elmer 2 3 4 Q. Right. Isn't it correct that the 5 respirators have to be provided for chrysotile 6 asbestos when it's over five microns when it's 7 dispersed into the air? 8 A. That's right. 9 Q. Would you and I agree that Hedmanite 10 material when it's dispersed in the air, that the 11 respirator should be worn? 12 A. Yes. Yes. Whenever you're creating dusty 13 conditions. It tells you in all of our literature. 14 Q. Okay. Thank you. Now, Hedmanite alone is 15 not a product, you would agree; right? I mean, it 16 can't be used -- just standing alone Hedmanite has 17 no application or purpose? 18 A. That' s right. 19 Q. So Hedmanite that you mine has to be used 20 in conjunction with another product. Would you 21 agree with that? 22 A. That's right. 23 Q. Now, when was the first time that 24 Hedmanite was distributed into the United States? 25 A. I didn't get you on that.
POWERS & GARRISON
PHONE: (412) 263-2068
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63 1 J. Mangan - by Mr. Elmer 2 3 Q. When was the first time that Hedmanite was 4 distributed into the United States? 5 A . When? 6 Q. Yes. When was the first time? Was it in 7 1964 for some test marketing? 8 A. I think it was some test material, yeah. 9 Q. And to whom was that test material sent? 10 A. That was sent toHooker Chemicals. 11 Q. Hooker Chemicals? 12 A. Hooker Chemicals in New York. 13 Q. Let me ask you this: How did Hedmanite 14 get involved with the New Jersey Zinc Company? 15 A. They were going to -- let's see. They 16 took an option on that property. 17 Q. They did? 18 A. I think it was. I think it was an option. 19 Q. When did they take that option? 20 A. I couldn't tell you right now. That was a 21 long time ago. 22 Q. Did they ever exercise that option? 23 A . No * 24 (Whereupon, Plaintiff's Exhibit No. 6 25 was marked for identification.)
POWERS & GARRISON
Phone: (412) 263-2088
64 1 J. Mangan - by Mr. Elmer
2 3 Q. Because there's another document, and I'm 4 going to have to have it designated Plaintiff's 5 Exhibit No. 6. Do you have in front of you the New 6 Jersey technical information? It was a one-page 7 document. 8 A. The technical information from New Jersey 9 Zinc? 10 Q. Right . 11 A. Yes. Okay. 12 Q. What was the reason why this technical 13 information was received from the New Jersey Zinc 14 Company? 15 A. When ? 16 Q. Well, the document is dated 12/7/72. 17 A. Right. They did a lot of work on 18 analyzing everything. 19 Q. So was the Hedmanite analyzed at least 20 back in 1972? So what was the purpose for having 21 the Hedmanite examined in '72? 22 A. To compare it with asbestos in order to 23 break into the asbestos market. The asbestos market 24 was a huge market and any market that we could find 25 where Hedmanite would fit in we wanted to find why
POWERS & GARRISON
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65 1 J. Mangan - by Mr. Elmer
2
3
it fit in.
That's one of the reasons why they did
4 all that analyzing.
5 Q. Was that the only reason, the economic
6 reason?
7 A. Well, yes, absolutely.
8 Q. Did New Jersey -- I take it New Jersey 9 Zinc Company never purchased Hedmanite -- they did 10 not exercise their option? 11 A. They didn't buy Hedmanite. 12 Q . Now --
13 A. They never used our product.
14 Q. When was -- after Hooker Chemical, to whom 15 did you distribute Hedmanite?
16 A. Pardon? 17 Q. After Hooker Chemical in New York -- let
18
me ask you this:
What is the Seegott Corporation?
19 A. Pardon?
20 Q Seegott. 21 A. Oh, Seegott, yes.
22 Q. Yes. When was your first contact with
23 Seegott ?
24
A.
I couldn't tell you.
I couldn't tell you.
25 Q. Do you have any documents as to the first
POWERS & GARRISON
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1 J. Mangan - by Mr. Elmer
2
3 date of sales to Seegott of New Jersey?
4 A . Seegott of Cleveland.
5 Q. Of Cleveland? When were the first sales
6 made to Seegott of Cleveland?
7 A . I don't know.
8 Q Do you have any documents concerning that
9 sale or any sales invoices?
to A . Maybe Ken Robb can tell you.
11 MR. ELMER: Well, Mr. Robb, do you
12 have any information?
13
MR. ROBB:
I don't have any documents
14 to that. We may have to ask Seegott. 15 (Whereupon, a brief off-the-record
16 discussion was held.)
17 Q. Well, Mr. Mangan, can you help me at all
18 as to when you first sold to Seegott?
19 A. We can look through and see if we can find
20 anything. 21 Q. I'd appreciate if you could do that, okay,
22 because -- didn't you know a Paul Seegott?
23 A I knew him.
24 Q. At one time is it not correct that Paul
25 Seegott was designated as a sales agent of Hedmanite
POWERS & GARRISON
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1 J. Mangan - by Mr. Elmer
2
3 in the United States?
4
A.
January 1, 1976.
Jane just put it in
5 f ront of me.
6 Q. January 1, 1976?
7
A.
To December 31, 1976.
That was the
8 agreement.
9 Q. Do you have a copy of that agreement? Do 10 you have a copy of the agreement between you and 11 Paul Seegott? 12 A. Well, I haven't got the complete
13 agreement, but I got the -- Ken Robb may have a copy
14
of the -- wait a minute.
I'm not sure.
15 Q. Well, I would just make a request -- and I
16 appreciate -- that you turn over to Mr. Robb any and
17 everything related to Paul Seegott -- okay -- and a
18 sales agent agreement, and I'm also going to make a
19 request, and I don't know if we want to do this or
20 not, but if you could tell me if you have any of the 21 sales invoices to Seegott.
22 Do you have any sales invoices or any
23 documents indicating sales to Seegott? So if you
24
could do that.
Now, did you have any conversations
25 with Paul Seegott concerning the properties of
POWERS & GARRISON
Phone: (412) 263-2068
68 1 J. Mangan - by Mr. Elmer
2
3 Hedma nit e ?
4
A.
I don't know.
Hedman would supply their
5 product, Hedman Cationic fiber at that time.
6
Q.
That's good.
Again, I want you to save
7
that document and send it to your counsel.
Excuse
8
me.
I can't tell you to do that.
I retract that.
9 I'm just going to make a request to 10 Mr. Robb that after this deposition he get with you 11 and that Mr. Robb secure from you any and all 12 documents concerning Paul Seegott or Seegott of New
13 Jersey or the Seegott of Cleveland, anything with
14 the word Seegott in it.
15 Do you know a Dick McNamara?
16
A.
I've spoken to him once or twice.
I never
17 met him
18 Q. Who is Dick McNamara? 19 A. I think he's a salesman, was a salesman
20 for Seegott at that time.
21 Q. When do you first recall speaking to
22 Mr. McNamara?
23 A. Probably a year or two after we gave Paul
24 the agreement.
25 Q. And again, would you talk about the
POWERS & GARRISON
PhonE: <412) 263-2088
69 1 J. Mangan - by Mr. Elmer
2 3 asbestos content with Paul Seegott or with Dick 4 McNamara, about the asbestos content or what you 5 allege is the impurity in Hedmanite? Were they 6 aware of the chrysotile asbestos component in 1976? 7 A. I'd imagine so. They got copies of the 8 technical data sheet. 9 Q. So do I understand you correctly that to 10 the best of your recollection and in the course of 11 Hedmanite -- I'm going to ask you this question: 12 Would it be the standard procedure and habit for 13 Hedman Resources, Limited or Hedman Mines, Limited 14 to send out the technical data sheet to its 15 supplier -- to purchasers of Hedmanite? 16 Would that just be the course of conduct 17 and standard habit of Hedman, Limited and Hedman 18 Resources ? 19 A. Did you hear me?
20 Q. What was your answer? 21 A. I don't know. 22 Q Because before you said Paul Seegott most 23 probab1y got the technical data sheet; is that
24 correct?
25
A.
I would imagine so.
I'm not positive.
He
POWERS & GARRISON
PhonCi (412) 263-2086
70 1 J. Mangan - by Mr. Elmer
2
3 dealt with my vice-president at that time.
4
Q.
Well, let's put it this way:
Does Hedman
5 Resources , Limited send out technical data sheets
6 now ?
7 A . Pardon?
8 Q. Do you send out technica1 sheets now?
9 A . Do we ? 10 Q- Yes. 11 A . Yes, if a person asks for i t . 12 Q . Now, would that have been your custom back
13 in 1976, to send out technical data sheets ?
14 A. Well, he was an agent at that time, so he 15 would actually have technical data sheets. 16 Q. So you and I agree that as an agent, Paul
17 Seegott would have Hedman Resources, Limited or 18 Hedman Mines, Limited technical data sheets because
19 he'd have to be able to explain the product to 20 people whom he wanted to sell it, is that not 21 correct, to the best of your knowledge?
22 A . '75, I gue s s.
23 Q. That would be in 1975?
24 A. ' 76 .
25 Q. Mr. Seegott would have been sent the
POWERS & GARRISON
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1 J. Mangan - by Mr. Elmer
7 3 technical data sheets in 1976 as an agent? 4 A . Yes .
5 Q. Who is Dolores Thompson?
6 A. Pardon?
7
Q.
Do you know a Dolores Thompson?
Does the
8 name Dolores Thompson mean anything to you?
9 A. Try me again.
10 Q. Does the name Dolores Thompson mean
11 anything to you?
12 A. I'm not getting you.
13 Q. Does the name Dolores Thompson mean
14 anything to you?
15 A. It's not ringing a meal.
16 Q. Do you know what Ceilcote is,
17 C-E-I-L-C-O-T-E?
18 A. What's that again?
19
Q.
Ceilcote.
Does that corporation or entity
20 mean anything to you?
21 A. No.
22 Q. In addition to Paul Seegott, was Seegott,
23 Inc. of Ohio, the corporation, designated as a sales
24 agent for you in the United States for Hedman
25 Resources, Limited or Hedman Mines?
POWERS & GARRISON
Phone; (412) 263-2068
72 1 J. Mangan - by Mr. Elmer
2
3
A.
Yes.
We had an agreement.
4 Q. With Seegott, Inc.? With the corporation?
5 A. It's Associates, Inc.
6 Q. Well, was it Seegott of Chagrin Falls,
7
Ohio?
It was in Ohio; correct?
8 A. The first line it says Seegott &
9 Associates, Inc., Cleveland Ohio distributors.
10
Q.
Okay.
So they were a distributor of
11 Hedman Resources, Limited or Hedman Mines, Limited
12 in the United States?
13 A . In Ohio.
14
Q.
Thank you.
So you had reason to know then
15 that perhaps Hedman products would be sent into
16 Ohio, the Hedmanite?
17 A. Yes.
18 Q. What was your answer?
19 A. Yes.
20
Q.
Thank you.
How long have you or did you
21 do business with Seegott, the entity, not the
22 person? 23 A. Terminated January 31, 1988.
24 Q. Did it go until 1976? Did that
25 relationship go from 1976 to January of 1988?
POWERS & GARRISON
PHONE: <412) 263-2088
73 1 J. Mangan - by Mr. Elmer
2 3 A . Right. 4 Q. Now, do you know what Seegott did with 5 Hedmanite? 6 A. No. That was between he and whoever he 7 sold to. 8 Q. Well, do you know what product Seegott 9 made with Hedmanite? 10 A. What was that again? J ? Q. Do you know what product Seegott made 12 using Hedmanite? 13 A. No, I don't. 14 Q. Well - 15 A. He was a distributor. 16 Q. A distributor of what? 17 A. Distributor of Hedmanite. 18 Q. Do you know the types of entities to whom 19 Seegott would distribute the Hedmanite? I mean, 20 would it be hot top makers or plastic makers or
21 what?
22 A. I'm not hearing you. What was that
23 again?
24
Q.
All right.
Do you know the types of
25 entities to which Seegott would distribute the
POWERS & GARRISON
Phone: <412) 263-2088
74 1 J. Mangan - by Mr. Elmer
2
3 Hedmanite? Would it be entities that would, let's
4 say, make hot tops?
5
MR. McGEARY:
Objection to form.
6
MR. ELMER:
Oh, who's this?
I'm
7
sorry.
We just don't recognize who you are.
8
MR. McGEARY:
It's Mr. McGeary
9
representing Foseco.
I object to the question.
The
10 question is leading.
11
MR. ELMER:
Oh, a leading question on
12
cross-examination.
Well, I'll take it.
13 Q. You can go ahead and answer, Mr. Mangan.
14 I have a feeling lawyers are going to be lawyers
15
now, and I'm your typical lawyer here.
So just go
16 ahead and respond to the question after and when an
17 objection is made.
18
MR. ROBB:
Pat, this is Ken Robb.
19 You go ahead and respond until I tell you not to.
20 All right? Did you hear me, Pat?
21
THE WITNESS:
What's that, Ken?
22
MR. ROBB:
You keep responding to the
23 questions until I tell you not to.
24
THE WITNESS:
You're not getting
25 through to me.
POWERS & GARRISON
Phone: (412) 263-2088
75
1 J. Mangan - by Mr. Elmer
2
3
MR. ROBB:
Pat, keep responding to
4 the questions until I tell you not to answer. Did
5 you hear that?
6
THE WITNESS:
No.
7 Q. Mr. Mangan. We're going to take a
8 ten-minute break. Okay? We're going to take a
9 ten-minute break. I'm going to step out of the room
10
and you can talk to your lawyer or just rest.
Go
11 get a glass of water or go to the rest room or
12 something like that.
13 (Whereupon, a brief recess was
14 taken . )
15 MR. ELMER: We had an off-the-record
16 discussion with all counsel present, and if I
17 misclarify or misstate anything, I hope you folks
18 will let me know.
19 Mr. Mangan's daughter has given us her
20 opinion that from her observation, that her father
21
should not go on.
Let me -- I don't even want to
22 ask it leading or anything. Can you just ask your
23 client what he wants to do because if he's ready to
24 stop, I don't want to press him.
25
MR. ROBB:
Pat, are you there? Do
POWERS"* GARRISON
Phone: (412) 263-2096
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76 1 J. Mangan - by Mr. Elmer
2
3 you feel you've had enough questioning for today?
4 We could come back and finish this up at some other
5 time. Would you prefer doing that?
6 THE WITNESS: Just a second, Ken.
7 I'll put Jane on.
8
MR. ROBB:
Jane?
9 JANE MANGAN: Yes, Ken. 10 MR. ROBB: Do you feel that we should
11
stop then? He didn't hear what we were saying.
I
12 think we'll stop then.
13
JANE MANGAN:
I would say yes.
14 MR. ELMER: Again, this is Mike Elmer
15
for the plaintiffs.
I do not want to press
16
Mr. Mangan.
If I'm advised that we should stop,
17 then we'll stop and we'll reconvene at a future
18 date . 19
Counsel for Hedman Mines Resources,
20 Limited has advised me that as long as the judge 21 doesn't mind, he's not going to hold me to finish
22 the discovery immediately. Do you want to go ahead
23 and state your stipulation?
24 MR. ROBB: This is Kenneth Robb for
25 Hedman Mines Resources. We will not hold the
POWERS & GARRISON
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77
t J. Mangan - by Mr. Elmer
2
3 plaintiffs to finishing this deposition by 4 October 1 as the schedule now stands unless the
5 judge would insist that all discovery be done by
6 that time .
7
MR. ELMER:
On behalf of the
8 plaintiffs everyone can expect a quick testimony
9 Notice of Deposition to go out on this case -- I 10 know within a week -- and I would imagine we were
11 going to want to wrap this up in two weeks so our
12 Notice will go out to the continuing deposition.
13 With that said, this deposition is
14 adjourned, and pursuant to the notice, it will
15 continue on and all parties will be notified as to
16 the continuation date of this deposition.
17 18 (The deposition was concluded at
19 4:15 p.m.)
20 (Signature not waived.)
21
22 23 24
25
POWERS & GARRISON
PHONE: (412) 263-2088
78
1
2
3 4 IN RE : 5 ASBESTOS
6
7 CERTIFICATE
8 I, JOHN J. MANGAN, do hereby certify that
9 I have read the foregoing transcript of my deposition consisting of Pages 3 through 77, and it
10 is a true and correct copy of my testimony, except for the changes, if any, made by me on the attached
11 Deposition Correction Sheet.
12
13 John J. Mangan
14
15
16 Notary Public
17 18 (Date)
19
20
21
( Date)
22 23 24
25
POWERS & GARRISON
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79
1
2
3
4 COMMONWEALTH OF PENNSYLVANIA)
5 COUNTY OF ALLEGHENY
)
6 I, Barbara D. Bombara, a notary public in
7 and for the Commonwealth of Pennsylvania, do hereby certify that the witness JOHN J MANGAN, was by me
8 first duly sworn to testify the truth, the whole truth, and nothing but the truth; that the foregoing
9 deposition was taken at the time and place stated herein; and that the said deposition was recorded
10 stenographica11y by me and then reduced to typewriting under my direction, and constitutes a
11 true record of the testimony given by said witness, all to the best of my skill and ability.
12 I further certify that the inspection,
13 reading and signing of said deposition were not waived by counsel for the respective parties and by
14 the witness.
15 I further certify that I am not a relative, or employee of either counsel, and that I
16 am in no way interested, directly or indirectly, in this action.
17 IN WITNESS WHEREOF, I have hereunto set my
18
19
20
21
22
23
Notarial Sed
24
Barbara 0. Bcmoara. Notary Pubic Pittsb'Jfgh, Allegheny County
My Comrrss&on Expires Aug. 19,1995
25 Member, I-'^r^yivaniaAssociation of Notaries
POWERS & GARRISON
Phone: (412) 263-2068
1
harim.n.dap
IN THE CIRCUIT COURT OF KANAWHA COUNTY, WEST VIRGINIA
IN RE:
ASBESTOS
CIVIL ACTION NO. 92-C-8888
BEFORE: HON. A. ANDREW MacQUEEN
NOTICE OF DEPOSITION
TO:
ALL COUNSEL OF RECORD ON BEHALF OF EACH DEFENDANT THEY REPRESENT IN PENDING ASBESTOS/SILICA CASES IN KANAWHA COUNTY, WEST VIRGINIA
PLEASE TAKE NOTICE that counsel for Plaintiffs will take the telephone deposition(s) of representatives of defendant Hedman Hines, Ltd. on Thursday, August 26, 1993 commencing at 2:00 p.m., and continuing from day to day until completed, to take place at the law offices of Henderson & Goldberg, P.C., 1030 Fifth Avenue, Pittsburgh, PA 15219, (412) 471-3980.
Defendant Hedman Mines is hereby requested, pursuant to Rule 30(b)(6) of the West Virginia Rules of Civil Procedure, to designate and produce one or more individuals with personal knowledge as to the following areas of concern:
1. One or more company representatives who can testify as to an overview of defendant's and its predecessor's past business activities with respect to asbestos and/or silicacontaining materials, including but not limited to defendant's
w
corporate or business history, dates of manufacture and sale of asbestos and/or silica-containing products, insulation activities, nature and composition of products, type of asbestos fiber used, description of package and any information provided with reference to health hazards, and provide information with respect to the various matters and basic subject matters of interrogatories, requests for production and requests for admission served on the defendant by the undersigned firms in this Kanawha County, West Virginia, litigation;
2. One or more representatives who are knowledgeable about the sales, marketing, use and promotion of defendant's asbestos and/or silica-containing materials and who can identify people or entities responsible for and/or knowledgeable concerning, sales and uses of asbestos and/or silica-containing materials produced or sold by this defendant to West Virginia and surrounding areas, and in particular to the jobsites listed on Exhibit A attached herein;
3. One or more representatives who can testify as to existing record-keeping systems concerning asbestos and/or silica and/or products containing asbestos or silica and sales or usage records, such as those discussed in Interrogatory No. 50 (e.g., invoices, orders, purchase records, sales summaries, confirmations, bills of lading, annual or other periodic summaries of sales or orders, accounts payable or accounts receivable records, etc.);
4. One or more representatives who can testify to any and all investigations that defendant had made at, before or during the time period that defendant sold or used asbestos or silica-
containing products or fiber, into the safety of asbestos and/or silica generally and also specifically as to defendant's asbestos
or silica-containing products;
5. One or more representatives who can testify to any
and all steps taken by defendant to protect, by warning or otherwise, the health and safety of persons who were or who may
have been exposed to asbestos or silica-containing materials supplied by this defendant or used by this defendant.
6. One or more representatives who can testify as to
defendant's past and present insurance coverage, including terms of
coverage, policy limits and remaining available insurance.
In
addition, this representative should be able to testify as to
defendant's current economic status, including corporate or
business net worth and past, present and projected future earnings.
7 One or more representatives who can identify any and
all documents (including statements and trial deposition testimony
of current or former employees of this defendant) in possession of this defendant indicating that this defendant relied upon the
January 1946 article, "A Health Survey of Pipecovering Operations in Constructing Naval Vessels" by Walter E. Fleischer, Frederick J. Viles, Jr., Robert L. Gade and Philip Drinker, during the time that
defendant manufactured, supplied, distributed, sold or used
asbestos-containing materials as a reason for not warning or
informing users or consumers of asbestos-containing products of any
and all actual or potential health hazards associated with such
products.
8. One or more representatives who can identify any and
all documents (including statements and trial or deposition
testimony of current or former employees of this defendant) in
possession of this defendant indicating that this defendant relied
upon the Threshold Limit Value of 5 million particles per cubic
foot for asbestos-containing dust during the time that defendant
manufactured, supplied, distributed, sold or used asbestos-
containing materials,
as a reason for not warning or informing
users or consumers of asbestos-containing products of any and all
actual or potential health hazards associated with such products.
Defendant, pursuant to Rule 34 of the West Virginia Rules
of Civil Procedure, is requested to produce the originals and, if
possible, a photocopy of all documents subject to outstanding
discovery requests, so that they can be discussed and marked as
exhibits by the court reporter.
Defendant is also requested to
produce the originals of any and all records of sales of asbestos
or silica-containing materials in West Virginia.
desire.
You are invited to attend and participate should you so
HENDERSON & GOLDBERG, P.C.
(412) 471-3980
and BY:
Sc ot t*^T"Segaiy Segal and Davis 810 Kanawha Boulevard Charleston, WV 25301 (304) 340-9100
T
EXHIBIT "A
Albright PS
Alcon Rolled Products, Fairmont, WV
Allied Chemical Charleston
Alloy
American Car Foundry, Huntington, WV
Ames Company, Parkersburg, WV
Amos Power House Analine Chemical Charleston
Armory, National Guard
Atomic Energy Plant, Waverly
Bank, Parkersburg National
Beaver Valley #1 PS
Beverly PS - Muskingum River
BlawKnox Corp., Wheeling, WV
Borg Warner/Marbon, Parkersburg, WV/Washington, WV
Bruce Mansfield PS
Burger PS
C & 0 Railroad
Carbon Black, Degussa Corp.
Cardinal a/k/a Brilliant PS
Cardinal PS/Brilliant PS/Tidd PS, Brilliant, OH
Celanese Corp.
Centre Foundry, Wheeling, WV
College, Concord
College, Bethany
Consolidated Aluminum, Hannibal, OH
Dillies Bottom PS - R.E. Berger PS, Dillies Bottom,
Dupont - Washington/Parkersburg, WV
Dupont - Belle, WV
FMC, Charleston Fort Martin PS Fort Martin PS
Gavin PS - Chesire PS Gavin PS
Glasgow PS - Kanawha PS,
Glasgow,
WV
Glen Lyn PS
Glen Lyn PS
Goodyear, Charleston
Graham's Station PS - Philip Sporn PS Harrison PS Harrison PS
Harrison PS, Masontown, PA Hatfield's Ferry PS
Hazel Atlas Glass, Hazel, WV
OH
Helmick Foundry, Fairmont, Hospital, St. Mary's Hospital, Fairmont General
WV
Hospital, Hospital, Hospital,
St. Joseph's, Parkersburg Wheeling WVU Medical Center
Hospital, Monongalia General Hospital, Elkins Inco Steel, Huntington, WV John Amos PS John Amos PS Kaiser Aluminum, Ravenwood, WV Kammer/Mitchell PS
Kammer PS Kammer PS - Cressup PS, New Martinsville, Kanawha a/k/a Glasgow PS
WV
Koppers - Bridgeville, PA Koppers - Follansbee, WV Mall, Ohio Valley/St. Clairsville Mine Academy, Beckley Mitchell PS, New Martinsville, WV Mobay - Natrium, WV Mountaineer PS
Mt. Storm PS Mt. Storm PS Muskingum River a/k/a Beverly PS Niles PS Olin Matheson/Ormet/Conalco - Hannibal/Clarington, Ormet, Hannibal, OH Philip Sporn PS Phillip Sporn Power House
OH
Pleasants Power Station Point Marion PS PPG - Natrium, WV (New Martinsville & Proctor) Rivesville PS Rivesville PS Sammis a/k/a Stratton PS Sammis/Stratton PS School, Woodrow Wilson High Shell Chemical, Marietta, OH Solvay Chemical, Moundsville, WV Steel of WV (Connor Steel, H.K. Porter), Huntington, Sterling Fawcett, Morgantown, WV
WV
Toronto PS U.S. Steel, Portsmouth, OH Union Carbide - Washington Bottoms, WV (Parkersburg) Union Carbide - Anmoore/Clarksburg Union Carbide - Marietta (Gulf) Union Carbide - Sistersville/BensRun/LindeAir/LongReach Union Carbide - South Charleston, WV
University of Athens - Ohio U., Athens, OH Weirton Steel
w
Weirton Steel, Weirton, WV Westinghouse Glass Plant, Fairmont, WV Wheeling Downs Wheeling-Pitt Steel, Benwood Wheeling-Pitt Steel, Yorkvilie Wheeling-Pitt Steel, Martins Ferry Wheeling-Pitt Steel, South Plant (Mingo Junction) Wheeling-Pitt Steel, East Plant (Follansbee, WV) Wheeling-Pitt Steel, North Plant (Steubenville) Wheeling-Pitt Steel, Beechbottom White Sulfur Springs Hotel Willow Island PS Willows Island PS - Pleasants PS, Willow Island Yorktown PS Youngstown Sheet & Tube
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct
copy of the within NOTICE OF DEPOSITION was served upon all counsel
of record via United States mail, postage pre-paid at Pittsburgh,
MlPennsylvania and/or by Hand Delivery this
day of August,
1993.
r An. n
BY: Craig L/ vandepgri
/Esquire
HENDERSON & GOLDBERG/ P.C.
1030 Fifth Avenue
Pittsburgh, PA 15219
(412) 471-3980
ATTORNEY FOR PLAINTIFFS
HEDMANITE
technical data sheet
0--ML
Hedmanite is a natural nonasbestos serpentine - lizardite - powder with a minor chrysofile impurity having an average fibre length of about 2Vi microns (determined at 4000X magnification), that i$ m the cate gory considered by the medical research experts to be devoid of pathogenic potential. The lap shear strength of the prismatic laths coupled with the fibre reinforcement provided by Hedmanite will help the formulator acnieve most of the desirable qualities of asbestos, mica and talc without the drawbacks. The minor free iron (magnetite) impurity results in good insulating and di-electrical properties. Contains no free silica or additives. Control any dust.
PLASTIC USES:
Hedmanite is used in phenolic and polyester molding compounds and gelcoats as a reinforcing filler. It aiso has application m vinyl flooring and in vinyl acetate and epoxy adhesives, acrylic, melamine, nylon, poly propylene. polyethylene.
PAPER USES:
Hedmanite is a low-cost extender of cellulose fibres in paperboard, construction paper, and cover paper, it can be used m newsprint and other printing papers for improvements in print quality and opacity, and gene rally in the pulp and paper industry for pitch control.
GENERAL USES:
Hecmanite has application in refractory compounds for steel mills, in welding rod flux coatings, texture & rust proof pcmts. stains & primer paints, friction materials, asphalt paving, sealants, caulking tape and compounds, certain cement products, wood preservatives, corrosion resistant coatings, stucco, latex backing for linoleum ana floor tiles, mastic cell putties and insulating cement, grease.
TECHNICAL DATA (Typical Values):
Typical Chemical Analysis:
CONSTITUENT
%
Silica Ferrous Oxide
(SiO:)....................... 40.98 (Fed)........................... 2.05
Ferric Oxide
(Fe:03)......................... 2.41
Alumina
(Al203)....................... 2.52
Lime
(CaO).........................0.30
Mcgnesia
(MgO)...................... 38.07
Manganese Oxide (MnO)....................... 0.21
Chromic Oxide
(Cr,03).........................0.44
Nickel Oxide
(NiO)...........................0.24
Carbon Dioxide
(C0Z).......................... 0.22
Moecular H;0 - L0I at 982C....................... 12.93
Moisture - oven drying at 205C.......................50
Identity and Physical Data:
Appearance..............................White (biueish)
Chemical family Hydrous magnesium silicate
Molecular formula.................... M92(Si205)(0H)j
Bulk density: mi/tOCg -
Dry 300-500
Wet
300-560
Pressure 135-160
Charge............................................ Electropositive pH...........................................................................9 4
Specific Gravity.................................................. 1.87
Brightness......................................................... 57-63
Oil Absorption' .....................................................32
M) SPATULA RUBOUT METHOD LBS 011/100 LBS PIGMENT
HKDMANITL
HEDMAN RESOURCES LIMITED
Timmins, Ontario, Canada P4N 7E7 - Telephone: (705) 264-3709, Cable "Hedman''
Warehoused stock in Toronto. Cleveland, Liverpool, Antwerp, Tokyo and Kobe
Sales Agents are world wide. The Agent in your area is:
WE ASSUME NO RESPONSIBILITY OR LIABILITY pop The RESULT op any APPLICATION MADE OP ANY INPORMATION CONTAINED HEREIN NOR 00 WE
ASSUME ANY LIABILITY POP INFRINGE MENT OP ANY PATENT WHICH MAY RE SULT PROM THE APPLICATION OP SUCH INFORMATION
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MATERIAL SAFETY DATA SHEET
Section I Identification of Product
Manufacturer's Name HEDMAN RESOURCES LIMITED
Emergency Telephone No. 705/264-3709 or 264-0593
Address P.O. Box 590, TIMMINS, Ontario, Canada P4N 7E7
Trade Name and Synonyms
HEDMANITE
Chemical Name and Synonyms - serpentine powaer - Lizaraite, tne nonasbestos analog with a minor chrysotile impurity having an average fibre length of 2H microns (1)
Chemical Family Hydrous Magnesium Silicates
Molecular Formula Mg3(Si205) (OH)4
Section 11 Hazardous Components of Mixtures
Component
Chrysotile "asbestos
fibres"( =
1.7%
(number)
9.6% (of volume)
threshold 1 imit value
(units)
Component
threshold limit value
(units)
(=Fibres > 5 microns included in average fibre length of 2% microns (1 *)Average determination at 4000X magnification. **)See OSHA Asbestos Regulations, Part 1910.93a re threshold limit value
(1)In category considered by medical research pathogenic potential, average fibre length criterion.
experts below 5
to be devoid of microns being the
Section III Physical Data
Appearance and Odor
blueish-white powder? odorless
Boiling Point (Degrees Fahrenheit)
, N/a
Melting Point (Degrees Fahrenheit)
,,. N/a
Vapor Density (Air^)
N/a
Specific Gravity (Water=l)
1>87
Vapor Pressure (MM. of Mercury)
Percent Volatile (By Weight)
N/a
Solubility in Water
N/a
Evaporation Rate (Butylacetate*!)
. N/a
MATERIAL SAFETY DATA SHEET
Section IV Fire and Explosion Hazard Data
Flash point (Specify Method) (Degrees Fahrenheit)
N/a
Fire Extinguishing Media
Flammable Limits (Percent By Volume)
(not flammable)
Lower
Upper
N/a
N/a
It will extinguish fires
Special Fire-Fighting Procedures
N/a
Unusual Fire and Explosion Hazards None
Stability
unstable stable
Section VI Reactivity Data
conditions to avoid
N/a
Incompatibility (Materials to avoid)
N/a
; Hazardous Decomposition Products
N/a
Hazardous Polymerization
May Occur
conditions to avoid
Will Not Occur
N/a
Section VII Spill of Leak Procedures
Steps to be Taken in Case Material is Released or Spilled
Vacuum clean spillage. Repair broken bags.
Waste Disposal Methods
Maintain good housekeeping practices. in closed containers.
Vacuum clean waste and place
MATERIAL SAFETY DATA SHEET
Section VIII Special Protection Information
Respiratory Protection (Specify type)
Use approved respirators, if required. (See OSHA Part 19108,1910.93a)
Ventilation
Local Exhaust Mechanical (General)
Special Other
Control wit i mechanical dust collect .on equipment to within TLV.
Protective Gloves
Eye Protection
nothing special Other Protective Equipment
n/a
Section IX Special Precautions
Precautions to be Taken in Handling and Storing Avoid creating dusty conditions. Avoid breathing excessive dust when handling, dumping, mixing, etc. See Contents & Caution Label on bag.
Leave plastic wrap on each palletized unit during handling and storing.
Date
Sheet Number
COmEMtb*:
fNON-flBROUS
SERPENTINE
' t.<
'APPROX. SO?i
Y:;/n; chrysotile mass.
under 20^
J
v ,:v ; ;':://{AVEHAGE;RBEE LENGTHr'2Vi";y;iCR6NS)
v;(2; ASBESTOS FlBRES^-5 MICRONS::'UNDER &':V: Y .'.''^'";'-'FREE'SiLICCAA ':Y Y'-YAY;YY-.v:j'?}f$'?!d;' l NILjg&-S
;
3 ';;JQf
ADDITIVES
- : :V" - v' .* Aversge Values determined si4000.X Magnification ' A' v':
, J <. : -
;:: v rn-; ;
IN CATEGORY CCNSCEnEO EY MEDICAL RESEARCH EXPERTS TO EE
IV' ' < " : "-DEVOID Or PATHOGENIC FOTENTtAL.AVEH.AGc FiSHE LENGTH EELCW
MICRONS BEING THc_CRfTEH/CiU .'>r7V
:Y-; .
{2} INCLUDED' IN (1)
r: I'V *'fO?
I
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technical iisjnan ?:jk:
information 0Arg
HF- 16 i: /; / ?:
LONG ~I13FR CCNT-NT
M D*1 4* ` T
ifd-han ?i:\p.z
A NO COMMON A^bSTOS FILLERS
A study of Che fiber content of four specimens (three of asbestos jnd one of Hedman Fibre) was made using electron micrographs of parctcie dispersions and counting die fibrous particles according to their length. The method gives only an app rox i.tia c i on of the tocal fiber content expressed in numbers of fibers, because the method could no: evaluate the relative moss of the non-fibrous content, and because die samples were statistically small.
_^i_c_fO_g_ra_shs_we_r_g_nr_goj_red_a_c__I_7^_500_ma an i f ic a t i o n using a rubout technique designed to sepume -nd disperse die particles without destroviii'O fiber structure. Sufficient dispersions were made to assure chat the procedure provided representative and reproducible micrographs.
For each specimen one thousand fibers were measured and counted with the following results:
Spec inerts_________________
Percent of Fibrous Par t ic 1 es Lo nge r Than 5 Microns
7R Asbestos Shorts (Supplier
7R Asbestos Shorts (Supplier
7RF Asbestos Floats
Hedman Fibre
______
A) U;
3.3 6.3 6.0 0.Z
Since all specimens contain substantial amounts of globular rion-fibrous particLcs l to 3 microns in si2e, an attempt was made to ap proximate the total fiber content of Hedman Fibre m comparison with the ?R: Asoestos Floats. Previous experience hud indicated that use of flo tation techniques used in mineral dressing applications concentrates the fibers in the froth product and the non-Cibrouc parti.les ;n the tailings. These separations were made and the products examined by electron micros copy to assess Che degree of separation.
In the case of Hedman Fibre, only about 9T of the sample appeared in the frotn product, and a substantial amount of this 9" consisted of nonCibrous material.
In cite case of the 7RF Asbestos Floats, the froch contained 317. of the sample and this 317. contained less non-fibrous material than was seen for Hedman Fibre. Ic should be noted < Iso that the tailings product from the 7RF separation contained a considerable amount of fibers.
Overall, these studies indicate dm: Hedman Fibre contains a lower proportion of total fiber than 7R? Asbestos Floats, and contains substantially fewer long fibers (five microns or longer) than the asbestos fillers with which it was compared, 'because of this, it is reasonable to expect chat its dust would contribute fewer long fibers to the atmosphere than the products containing larger proportions o: long fibers. However, tins type of study cannot establish die extent of such a difference.
Q /,/The New Jersey Zinc Company 3
*CkUK * /'Hlf n*i
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ONTARIO RESEARCH FOUNDA TION
MISSISSAUGA. ONTARIO. CA\ACA. .i* <B3
AMCMg W6) 822--H'.: Cfi 279-3771 r*x 6>Z-432 2SZ*
ELECTRON-MICROSCOPIC DETERMINATION OF CHRYSOTILE CONTENT OF HEDMAN CATIONIC FIBRE
Submitted to Redman Mines Limited
Titsins, Ontario Canada
Prepared by
r
R. . 3 e r t r a: Associate Research Scientis
Approved by u. Puliun Director
Department of Applied Physics Dec eirbe-r : 9 , 1 9 74
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TABLE OF CONTENTS
I Introduce ion II Sample Preparation III Microscopic Examination and Identification IV Counting Method
Bibliography Appendix I: Figures and Summary of Results Appendix II: Collected Data Appendix III: Analysis Program
j
3
5
5 14
1
Introduction
The purpose of this study has been to analyze samples of a mineral powder, described as being predominantly lizarcice, which is called "Hecmar. Cationic Fibre'' to determine the quantity and distribution of the chrvsocile asbestos fibre content. Two lets of material, identified as CS113 and C91CA by Hedman Mines limited, were examined.
Samples for electron micrcscopv were oreoarec bv usir.z a new technique which provides a uniform and representative dispersion of particles on a specimen support. Ultrasonic agitation was no: used .
Samples of the material were examined in a Jr^i 1CCU transmission electron microscope (TEM) in which selected area diffraction was used to differentiate between chrysotiie end nonchrysocile matter. A Cambridge Stereoscan scanning electron microstore (SFM) was then used to obtain photographs of a number of dispersed samples.
| To assist with particle measurement and counting, automatic data logging was employed. Thus it was possible from SEM photographs
t
r
:o size over 9000 particles with cvo dimensions measured on each particle. rive separate powder samples were taken from the rater provided. From these, 11 pairs of photographs were made, each pa comprising a high (4000X) and low (1000X) magnification picture o the same general area of specimen.
The data was analysed using a special computer program tr.e following information derived from each photograph:
a) content by weight of chrysotile; b) content by volume of chrysotile; c) number percent of all chrysotile fibres, which are longer
5 micrometers; d) weight percent of all particles, which consist of cr.r^scci
fibres longer than 5 micrometers; e) number of fibres Longer than 5 micrometers per milligram o
Henman material; i) weighted average fibre length.
Inspection of the results indicated that the dispersion mceed sufficiently uniform and that enough data was obtainec prcvide a representative analysis of the material supplied
3
II Sample Preparation
In order co provide a suitable sample for purposes of particle counting it was necessary to disperse the material so as to be suitable for electron microscopic examination. In all cases distilled water which had been filtered through a Q.lun filter was used as the dispersing medium.
In an initial attempt tc solve the dispersion problem, samples were added to 500ml of water and then vigorously shaken by hand before dilution to 1 part in 200. They were then centrifuged onto cover glasses at 7000G for thirty minutes. A TEf examination of the sample revealed widely dispersed chrvsotiie, plate-like and clay-like matter. Further samples exhibited a distribution consisting of vicel'/ dispersed clumps of particles which were generally not suitable for quantitative evaluation.
The next method attempted involved dilution as before with 0.017I8gms of material (randomly selected from various areas of one of the Hedman lots) into 110ml distilled and filtered water, of which LOci was further diluted in 90ml of water so that the final concentracion was 15.61 micrograms per ml of solution. 50ml of this solution was then deposited onto a filter (O.lum Miilipore) by vacuum filtration so that
che sample deposited was 7.31 x 10 4 gm of Kedman material.
The filter material was dissolved on a mesh support in
1
acetone over TDi grids with previously prepared carbon grids. These specimens proved to be satisfactory for TD* examination.
The final method of sample dilution settled upon used che concentrations, manual shaking method, and vacuum filtration as described above. However, "uclepore filters (O.lum pore sice) were substituted for the Millipore filters. These filters were then cut into pieces which were mounted directly in the STH for examination. In this way, the time-consuming and possibly clump-causing filter dissolution step was eliminated and the background picture was less confusing than the paper filter, which is fibrous, or carbon film which can break and sag.
The adopted method consisted then, of simple dispersion, hand agitation and vacuum filtration only. Violent mechanical methods, such as ultrasonic agitation or centrifuging, are not involved and total sample collection provides an easy check of uniformity of distribution over large sample areas.
Five filters were prepared by this method, three frcm lot
-5-
'/2 91CA and two frora lot ^281 IB and two areas were cur from each of these filters for SEM examination.
HZ Microscopic Examination and Identification
Observation of dispersed samples using an optical microscope revealed a large number of particles below 5 microns. For this reason optical methods could not be used for analysis due to the limited resolving power of the optical microscope.
A mixture of fibrous and non-tibrous particles was observed when the samples were examined in a 7ZM at magnifications up to 2C\20CX. The particles that appeared to be fibrous were found to have an electron diffraction pattern identical to that of chrysotile. The particles that appeared amorphous seldom exhibited any diffraction ?a*-arr- aC all* end those that appeared flaky were found to have dirrraction patterns similar to mica which does not resemble that of chrysotile (Figures 1 and 2).
The sacples prepared tor 7EM examination were not as well dispersed as those prepared for the SEM. Furthermore, the larger (-a.-*w.es or --'ores were orten opaque or too long for proper ider.t tr icacion and siting in the 7EM.
6
Ic was therefore decided to do all of the work using the $Z^. This aear.t that identification was purely visual since the SEh does r.c: permit electron diftract ion. Further 7EM examination confirmed, however, that the visual identification criteria were satisfactory.
IV Counting Method
examination in the SUM indicated that the noa-chrysctile particles could be approximated by spheres and therefore a single measurement oi diameter is sufficient; chrysotile on the other hand is tubular ar.d requires measurements of both length and diameter. Results sr.cved that it was possible to assume that the chrysotile fibres were approximately circular in cross section, or that, where they were obviously oval, an equivalent circular cross section could be estimated with a reasonable degree of accuracy. The stereo pairs shown in Figure 3 lend further support to this assumption.
The volume of non-chrysotile matter is calculated as (4/^ 3;\'S were D is the diameter of the equivalent sphere. The chrysotile volume is Lr D^/4 where L is the fibre length and D is the diameter of the equivalent cylinder.
-7-
After a sample had been prepared by the technique described abcve, SEi pictures were taken from randomly chosen areas of the filter and photographs were taken at two nominal magnifications. Enlargements of nominal size 8" x S" were made from these SEM pictures such chat the final magnifications were of the order of 1QQ0X and iQQOX. In practice the specific magnifications were measured for each enlargement by comparison to the original $2i photograph, of which the magnification was known. Typical pictures are shewn in Figures i ;o 7.
-r
The pictures were measurec using semi-automatic data acquisition equipment and analyzed by means of a computer program for
this purpose. The data acquisition system consisted of a Carl Zeiss TGZC size counter, a Fluke S300A digital meter and a Hewlett Packard
31S9A data punch. The Zeiss instrument contains a variable diameter
ligntspot vhicn is projected through the photograph from the back. The
operator turns a wheel to adjust the Lightspoc diameter to match one
dimension of a particle and a precision potentiometer mounted coaxially
~"e s^a^-
Che wheel is automatically turned in the same
propor.^on. .he potentiometer has a linearity of 0- 1551 and varies from
approx atelv .000 to 9000 ohms. Its resistance value is read by the
*g..al me.er
four figures precision when a foot switch is depressed,
t the same , -e, the rootswitch causes a needle to punch a hole in the
T
phonograph at Che centre of the measured particle, so chat it will not be counted twice. The digital resistance measurement is transmitted to the datapunch where it is translated into ASCII code and punched onto a paper tape. Thus a record of all measurements is made automatically at the rate of about 20 measurements per minute.
The operators have been trained to recognize chrysotile by its fibrous or cylindrical form and make two readings, the first being length, the second diameter. All ocher material is read twice at the same wheel setting.
The computer program (Appendix III) has been designed to
distinguish non-chrysotile records by recognizing those pairs or
adjacent readings which are within i ohms of each other. Chrysotile
is recognized by the sequence of a higher and a lower number. If
extraneous readings have been introduced by the operator, they are
recognised by the fact that they cause the readings to get out of see?
such that some low-high number combinations occur. When this happens,
c.-.ese data and the adjacent data are printed out by the computer and
=ay be corrected by the operator at che computer terminal. Measurements
whic.n exceed the size of the lightspot (typically Less than iZ of the
-o^al number) are measured by means of a vernier caliper and entered
*R-3
?rSram from the terminal keyboard.
-9-
Once the data has been read and corrected by the computer, the magnification and range factors are fed into it along with the sample number. A calibration of the lightspot size has been made using size standards and this is included in the computer program. The computer sorts the data, makes the required calculations and prints out the final data in the form shown in Appendix II.
It is possible to estimate the total particle mass of any observed area by calculating that area ''from the photograph and the magnification factor), dividing by the effective filter area (90S=m:! and multiplying by the sample mass. This also is dene by computer and is printed out with the final results as a check of accuracy as will be discussed below.
Examination of the literature revealed no clear cut value for the density of lizardite except for one reference" which gave a value of approximately 2.55gm/cm- . The tabulated' value for chrysctils ot 2.56gm/cm^ falls near this value; therefore, it was decided to use c..e whrysotile density for all material. Consequently, the mass and volume distributions are identical. The validity of this assumption is supported by the agreement which was subsequently found between mass calculated on this basis for all particles in the sample area and mass
'-*po*ated trem the total weighed mass distributed over the whole
10
sample area.
The data collected follows In Appendix II. The chrysocile particles are sorted into categories by length, these categories separated logarithmically. The lengths are listed in the first column and the accumulated numbers of fibres below each length are listed in the second. The number percents calculated with respect to the total number of fibres counted are listed in the third and the mass percent with respect to total fibre mass are listed in the fourth column. The amount above any particular length may be found by subtracting the given figures from 100%. This is how the ''number perter.t longer than 5 microns" is determined.
The mass of the sample is computed' by totalling the particle weights (estimated volumes x density). The value obtained is compared vim that estimated from the gross sample weight as described above (1 rar.ogram * 10 * grams or 10 5 milligrams). The comparison shows that deviation between the two values is typically less chan 45% with a rew values in excess of 70% these latter all being positive, inspection of the related photographs shewed chat major discrepancies --u-- otter, be explained by an unusually large particle in the field
/lew upsetting the distribution. Generally the agreement between ""e w.o mass estimates can be regarded as evidence that the sampling
11
raecMods are adequace.
The percent mass of chrysocile is calculated with respect
At-
to tne total sample mass, which is then subdivided into the mass
percent of fibres longer chan 5 microns. Finally the number of fib
longer than 5 microns per milligram of material is calculated.
The values obtained are summarized in Appendix I. The second figure attached to each average value consists of twice :.-.e standard error. The true average value, i.e. that which is oalculs r'rcc- an extremely large number of samples, has a 95% probability
mg between the limits set by this figure. The standard error o: this value has been calculated by dividing its standard deviatic oy the scyuare root of 11, the number of samples over which ea va.u2 is calculated.
The fibre mass computed at 1000X magnification as a pares of total mass was found to be 19.7 m 5.5%. This value is prererrec to that obtained at 4000X magnification because it included the larges: fibres.
Values for number percent greater than a given length" are functions of magni fication which determines the range of measur sices. The effective length range is luo to 200in at 1000X and .25 :o 30um at -COOX. The lower limit is determined by the minimum Lig sice and the upper lim it is estimated as the length of one side c:
i
I
l
]
r
12
photographic enlargements used for measurement. Since the higher magnification range brackets the 5um length more symmetrically than the low magnification range, we consider the figures obtained at
IQOQX magnification to give more reliable indications of number perter.t. m
Thus the values obtained were as follows:
S.l r 3.0** of all chrysotile fibres observed in the .25 to 50_n
range were longer than 5uo.
-
l.T c 1.5^ of all particles in the .25 to 50ua range consisted t: chrysotile fibres longer than 5um.
?.o t 6. ir; or the mass of particles in the .25 to 50um range consisted of chrysotile fibres longer than Sum.
These data were also used to calculate the average fibre
length of the sample. This is defined for^he purpose
this study
as the weighted average length, i..
*
"
* I P.l./N
where-a* Is the number of fibres in cKe i'th-vaacegory and 1. ip' a
. Tie?
-
a; 1 >
vaj.ua o.f -i^f|th'which is midway between the upper and lower
oouncanas of the i'th category, N being the total number or fibres
counted. As with fibre density, it was felt that the high magni: ico: :cr.
save a tore significant figure, at 2.52 microns.
T
- 13
Bibliography
1. E. H. Kalsus, Journal of Applied Physics, 25_, 87, 1954. 2. Handbook of Chemistry and Physics, 48th ad, Chemical Rub
Company, 1967-68, p. B282. 3. Industrial Minerals and Rocks, S. 4*. Mucd Series, Gillsc
American Institute of Mining, Metallurgical and Pecrcleu Engineers, New York, 1960, p. 23.
APPENDIX I GURZS AND S'J^AXY OF RESULTS
# t #
# #
i.
1
F V
i
k
t
f )
i
\ 9 t
t
i
4
p
Sample No.
1
Lot No. 2811B
2 2910A
3 2910A
291QA
5 28113
Area Examined
A A
C C
B 3
C C
A A
C C
E
n
c c c c
E
c
c
Calculated Magnification
1060 4140
1000
3980
1000
4020 1060 4240
1050 4240
1000
4040
1060 4180 1050 4250 4260 1050
4230 1050 4160 1050
Sample Designation
Bll
B13 B17 B19
A26 A28 A29 A2H
A31 A33 A37 A39
: :
A41 A42 A410 A415 A4 16 A417
352
B55 3512 3514
' .
Sample Description Kedman Cationic Fibre
Hedman Cationic Fibre MASS OF CHRYSOTILE
AS A PERCENT OF TOTAL MASS Magnification: 1000X
Sample Number
311 317 A26 A29 A3 1 aJ / A- .
-- 40 A4 1 7 355 3514
i Number of Particles ! Counted
413 322 408 508 500 373 519 455 626 380 526
Number of Fibres Counted
104 90 99
102 100
96
110
131 167
76
100
Mass of Chrysccile as a Percent of Total Mass
12.41 12.15
9.95 11.1" 27.3-
9.53 3.1? 15.53 33.-30.15 IS. 15
Average value
IX standard error
19.7 5.;
Sample Number
313 319 AlS Alii A3 3 A3 9 A4 2 A- 15 A* i c 352 3513
Average value
2X standard error
Hedman Cationic Fibre
FIBRES LONGER THAN 5 MICRONS
Magnification: 40QCX
Number of Fibres Counted
76 48 69 84 60 67 114 82 71 73 74
: Number Perce | Fibres which ! Loneer than i if 1.32 i 8.33 i 13.04 i 4.76 fi 1.67
10.45
7.89
6. ;c
15--9 f
4.11
1 16.22 I>
8. 1 i f 3.0
i
Hedman Cationic Fibre FIBRES LONGER THAN 5 MICRONS
Magnification: 4000X
t
1 Sample ' Number
'f j '
313 !
: s: 9 1 ACS
; '
ac :: A3 3 ; A3 9 Aw ^ . A415
!
; |
1
!
A4 z
1
; 353
:
: 3513
!i i
. Average
ii |
: value
1
2X standard j
error !
t ij
Number of Particles Counted
410 302 291 469 397 281 439 376 394 319 414
! Number Percent :: ill j Particles which are Fibres Lcr.zer than :.r. i
0.24 1 1.32
: 3.C9 0.55
i 0.23 i 2.-9 1 2.05
! 1.23 ; .w
j 0.94
; 2.90
i 1l 1 1 \*
i 0.6 !
T
Hedman Cationic Fibre
MASS OF
FIBRES LONGER THAN 5 MICRON'S
Magnification: 4000X
Sample : N umb a r
j 1 Percent of Sample Mass
j Number of Particles
which consists j:
'
Counted
' Fibres lor.aer than 5_r
' 313 ! 319 ' A2S ' A2 11
Ao A3 9 ' A4 2 ' A415 A4 1 6 ! 35: - 3513
; '
no 302 291 469 397 231 439 376 394 319 414
0.06 0.44 30.50 2.47 iJ . -0 3*9? 21.12 1.37 12.19 0.21 20.16
Average value
2X standard error
(
6.1
Hedman Cationic Fibres DENSITY OF FIBRES LONGER THAN 3 MICRONS
Magnification: 4000X
Sa-ple
!
Nur.be r ______!
Number of Fibres Counted ______
Density (sillior.s/r.g)
313 i 319
A2S A2 11 A33 A3 9 A4 A415 A4 16 352 5513
76 4S 69 84 60 67 114 32 71 73 74
0.39 3.09 4.51
1.51
0. 46
7. r s
1.?:
3. 17 3.90 2.23 4.23
Average vaiue
X standard error
3.5 1.5
T
Hedman Cationic Fibre WEIGHTED AVERAGE FIBRE LENGTH
Magnification: 4000X
Sart?le Nur.ber
312 319 A2S A211 A3 3 A3 9
'>
A4 1.5 A4 16 352 3513
Number of Fibres Counted
76 48 69 84 60 67 114 82 71 73 74
weighted average length for all fibres
Weighted Average Ler.ath 1.58 2.51 2.92 2.29 1.31 2.50 2.66 1.78 3.71 2.03 3.62
2.52
APPENDIX II
COLLECTED DATA
I "WAN CATIONIC FIBRE uriRYSOTILE ANALYSIS
SAMPLE NO. 3 I I *1*7 /oao
\
NoTH DISTRIBUTION*
22/10/74
LENGTH (MICRONS)
NO. OF FIBRES BELOW LENGTH '
NUMBER PERCENT BELOW LcNOiH
. 0.200 0.256 0.329 0.420 0.533 0.690
- 0.334
I . 132 I .450 1.557 2.379 3.047 - 3.903 3.000 6.405 S. 204
!0.509 1 3.462 - ".244
.039
4.5.295 30.244
46.423 o 9.472 * 76.150 97.534
125.000 ; oO. 120 2C5. 1 06 I62.732
0 0 0 0 0 0 0 1 1 6 14 27 48 73 32 91 94
97 99
1 00 101 10! 1C2 103 ! 04 1 04 104 104 104 104
0. 00 0.00 0.00 0.00
0.00 0.00 0.00 0.96 0.96 5.77 13.46 25 96 46.15 70. 19 78.3d 87.50 90.38 93.27 95. 1 9 96. 1 5 97. 12 97. 12 98.05 99.04
100.00 100.00 100.00 100.00 I00.00 100.00
TOTAL N UMBER OF PARTICLES IN SAMPLE*
413
NUMBER OH rISRES IN SAMPLE*
I 04
i NUMBER PERCENT LONGER THAN 5 MICRONS* 29.31 %
` MACS OF SAMPLE*
mass peece; BEL'hi LENT.
0.00 0.00 0.00 0.00 0.00 0.00 0. 00 0.05 0.05 1.60 3.94
19.01 25.64
37.51 41 . 15 oS .25 59. 97 76.36 75. o 7
32.92 93.73 93.73 94.97 99.43 102.30 IOC.00 100.00 100.00 100.00 !00.OC
CALCULATED FROM PARTICLE SIZES ESaI MATED FROM GROSS WEIGHT
30.94 MANOGRAM3 29. 70 NANOGRAM3
CALCULATED PERCENT MASS Or CHRYSOTILE*
12.42 %
\
'A53 OF FIBRES LONGER THAN 5 MICRONS AS PERCENT OF SAMPLE MASS *
75
'0. OF FIBRES LONGER THAN -j MICRONS* I. 00 41LLION/MILL!CP 4"
SAMPLE NO.313
hedman cationic = :sps
CHRYSOTILE ANALYSIS
17/10/74
NGTH DISTRIBUTION!
LENGTH (MICRONS)
NO. OF FIBRES BELOW LENGTH
NUMBER PERCENT BELOW LENGTH
MASS PERCENT BELOW LENGTH
0.200
0.256 0.328 0.420
0.538 0.690 0.884
1.132
1 .450 1 .857 2.379 3.047
3.903 5.000 6.405 8.204
10.509 13.462 17.244
22.089
28.295 36.244
46.423 59.472 76.180 97.584
125.000 160.120 205.I06
262.732
0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 3 3.95 I 1 14.47
23 30.26 39 51.32 49 64.47 57 75.00 64 84.2! 71 93.42 75 98.68 75 98.68 76 100.00 76 100.00 76 100.00 76 100.00 76 100.00
76 100.00 76 100.00
76 100.00
76 100.00 74 100.00
76 100.00 76 100.00 76 100.00
76 100.00
76 100.00
TOTAL NUMBER OF PARTICLES IN SAMPLE* 410
0.00 0.00
0.00 0.00 0.00 2.32 5.73 14.51 2 1 .56
40.44
47.35 56.13 73.34
98. 10 98. 10 100.00
100.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00 ICO.00 100.00 100.00
NUMBER OF FIBRES IN SAMPLE* NUMBER PERCENT LONGER THAN 5 MICRONS*
MASS OF SAMPLE*
76 1.32 **
CALCULATED FROM PARTICLE SIZES ESTIMATED FROM GROSS WEIGHT
CALCULATED PERCENT MASS OF CHRYSOTILE*
1 . 70 nanograms 1.95 NANOGRAMS
2.90 %
MASS OF FIBRES LONGER THAN 5 MICRONS AS PERCENT OF SAMPLE MASS*
0.34 S
NO. OF FIBRES LONGER THAN 5 MICRONS* 0.59 MILLION/MILLIGRAM
SAMPLE NO.3!7
- Ai i u.N I w rlzntz
CHRYSOTILS ANALYSIS
I 7/10/74
CNCTH DISTRIBUTION!
LENGTH (MICRONS)
NO* OF FIBRES BELOW LENGTH
NUMBER PERCENT BELOW LENGTH
i
F.
)
i.
)i i) \ \ i
i i ' >-
-
0,200 0.256
0.328 0.420 0.533 0.690 0.334
1.132 1.450 1 .857 2.379 3.047 3.903 5.000 6.405 3.204
10.509 13.462 17.244 22.089
28.295 36.244
46.423 59.472 76. 180 97.584
125.000160.120 205.106 262.732
0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 5 5.56 ! 2 13.33 26 28.89 39 43.33 53 58.39 66 73.33 71 78.39 77 85.56 82 91. ! I
85 94.44 85 94.44
86 95.56 87 96.67 89 98.39 89 98.39
89 93.39 90 100.00 90 100.00 90 100.00
TOTAL lNUMBER- OF PARTICLES IN SAMPLE* 322
k\ *
\
NUMBER OF FIBRES IN SAMPLE* NUMBER PERcarr longer than s MICRONS*
90 71.11 %
MASS OF SAMPLE*
MASS PERCENT below leng;h
0.00 0.00 0.00 0.00 . 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.55 4.46 8.51 12.43 18.29 26.53 31.71 36.77 41 .24 47.39 47.39 48.36 50.29 51.06 51.06 5 1.06 100.00 100.00 100.00
CALCULATED FROM PARTICLE SIZES
ESTIMATED FROM QftQSS WEIGHT
65.29 NANOGRAMS
33.37 NANOGRAMS
CALCULATED PERCENT MASS ClF. CHRYSOTILEt 12.18 X
MASS OF FIBRES LONGER THAN 5 MICRONS AS PERCENT OF SAMPLE MASSi
4%
no, of fibres Longer than 5 microns* o.ea million/milligram
SAMPLE N0.3J9
HELMAN OATInMO FIBRE CHRYSOTILE ANALYSIS
18/10/74
.HNGTH DISTRIBUTION:
LENGTH C MICRONS)
NO. OF FIBRES BELOW LENGTH
NUMBER PERCENT BELOW LENGTH
MASS PERCE. BELOW LENO
0.200 0.256 0.323 0.420 0.533 0.690 0.334
1 . 1 32 1.450 1 .357 2.379 3.047
3.903 5.000 6.405 3.204
I 0.509 13.462 17.244
22.039 28.295 36.24*
46.423 59.472
76.ISO 9 7.534
125.000
160.120 205.106 262.732
0
0.00
0.00
0
0.00
0.00
0
0.00
0.00
0
0.00
0.00
0
0.00
0.00
0
0.00
0.00
1
2.08
0.96
6
12.50
6,09
12
25.00
15.23
25
52.08
45.53
34
70.33
63.6!
40
33.33
75.32
41
85.42
75.93
44
9! .67
38.30
44
91.67
38.30
46
95.33
95.01
48
100.00
i00.00
48
100.00
I 00.00
48
100.00
100.00
48
!00.00
100.00
48
100.00
100.00
48
100.00
100.00
48
100.00
100.02
48
I00.00
100.00
48
100.00
100.00
48
1 GO.00
100.00
48
1 CO.00
100.00
48
1 QQ.00
100.00
48
100.00
100.00
48
100.00
ioo.o:
TCH'AL NUMBER UF PARTICLES IN SAMPLE* 302
NUMBER OF FI3RES IN SAMPLE* NUMBER PERCENT LONGER THAN 5 MICRONS:
MASa OF SAMPLE*
48 3.33 %
CALCULATED FROM PARTICLE SIZES
ESTIMATED from gross HEIGHT
1.30 NANOGRAMS
a.!I NANOGRAMS
CALCULATED PERCENT MASS OF CiiNYSOTILL*
7,/h *
MAO I OF Flu RES LONGER THAN b MICRONS AS PERCENT OF SAMPLE MASS i
NO. Jr rIHRES LONGER THAN 5 MICRONS: 3.09 ULL:ON/m ILLIGrtAM
HEQMAN CATIONIC FIBRE CHHYSOTILE ANALYSIS
SAMPLE NO. A26 ^ / :oa
23/10/74
LENGTH DISTRIBUTION*
LENGTH
(MICRONS)
0.200 0.2d 6 0.323 0.^2 0
0.538 0.650 0. 85 4 1 . 1 32 I .430 I .357 2.379 3.04 7 3.903 d.OCO 6.405 8.204 !0.509 13.462 17.244
22.039 23.295 36.244
46.423 59.472 76.130 97.554
125.000 160.!20 205.I06 262.732
NO. OF FIBRES BELOW LENGTH
0 0 0 0 0 0 0 0 0 0 3 7 !4
30 33 53 65 73 77
35 96 96 97 99 99 99 99 99 99 99
NUMBER PERCENT BELOW LENGTH
0.00 0.00 0.00. 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.03 7.07 14.14
30.30 33.33 53.54
65.6o 73.74
77.75 35.36 96.97 96.97 97.9c !00.00 100.00 100.00 100.00 100.00 100.00 100.00
MASS PERCE. BELOW LE;v0
0. CD G.OO r*
0.00 0.00 0. :c 0. :o 0.00 c. 20 0.00 2.01
3.06 3. ?! 7.; 5
= . 7! 1 3 . cS 2 3.14
47! :~
66.31
90. 75
90. r:
9 1.53 1 w *> v w
1 DC.CO
1oc.u:
1l
-vwr
-i
----
IOO.O: J1 ^ W w^ -^1
TOTAL NUMBER OF PARTICLES IN SAMPLE*
NUMBER OF FIBRES IN SAMPLE< number percent LONGER THAN 5 MICRON'S*
MASS OF SAMPLE*
405
99 69.70 S
CALCULATED FROM PARTICLE SIZES ESTIMATED FROM GROSS mEIGHT
50. d7 NANUGRAMS 33.37 rtANOGRAM -j
CALCULATED PERCENT MASS OF CHRYSOTILE*
v. 9ti
"ASS OF FIBRES LONGER THAN 5 MICRONS
AS PERCENT OF SAMPLE MASS*
9.2
No. OF FIBRES LONGER THAN *3 MICRONS* 1.36 M ILLIOO/M I LL I Oh A*
SAMPLE NO.A28
I 8/10/74
;gTH ClS7SISUTIONt
^ ' 5 -D
LENGTH {MICRONS)
NO. OF FIBRES BELOW LENGTH
NUMBER PERCENT 3ELOW LENGTH
MASS PERCE; BELON LEND
0.200
0.256 0.323
0.42Q
0.333 0.590 0.384
1.132 I .450 1 .337
2.3 7 9 3.04 7
3.903
5.000
6.403
U3
.
*)
6.
W*~/>
I0.209
1 3.462
17.244
22,039
23.295 36.244
46.425 59.472
76.150 9 7.53 4
122.000 160.120
205.I05 262.732
0 0. 00
0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 2 2.90 8 11.59 21 30.43 23 4Q. 55
40 57.97 46 66.67 57 82.61
60 56.96 62 89.86 67 97. 10 67 97. 10 69 100.00 69 100.00
69 100.00 69 100.00 69 !00.00
69 100.00 69 1 CO.00 69 !00.00 69 100.00 69 100.00
69 100.00 69 100.00 69 !00.00
TOTAL < JM5EE Jr PARTICLES IN SAMPLE* 291
NU.MJER Jr FIBRES IN SAMPLE t 0 5 E 2 PERCENT LONGER THAN 5 M I CRON'S *
69 13.04 -V6
0.00 0.00 0.00 0.00 0. 00 0.00 0.36 0. 70 2.53 2.52
4.33 4.73 1^.57
1 9.70 25.33 59.07 59.07 100.00
100.00
100.00 loo.:: ioc.:c
I 00.00 100.00
!00.00
!00.00 100.00
100.00 IOC.00 100.00
MASS OF SAMPLE*
C ALCULATED -FROM PART ICLE SIZES 4 STIMATED FROM GROSS F: GHT CALO'JLAfED PERCENT MASS Or Q i i;(Y SOTI L
2.00 N ANCONA'-' 3 2.07 nanograms
38.1 l 1'*
'AO i 'Jr FIBRES LONGER THAN 0 MICRONS AS PERCE NT OF 3AM PLF MASS*
3C.6
) r FIBRES LONGER THAN 5 MICRONS * 4.51 ' r LLION/M ILL:GO ^"
1 5A '.PLE .M1.A29
iEDMAN CATION I C hZBRS CHRYSOTILE ANALYSIS
-jj-
30/10/74
i0TH jt3VRl3U7ION:
LENOi. C MICRO., j >
NO. '.Oh h: SPSS BELOW LENGTH
NUMBER PERCENT 3EL0w LENGTH
0.200
0.256 0.323 3.420
O.^Sd 0.690 03h4 1.132 1.450 1 .3 2 7 2.379 3 . C4 /
3.903 d.GCO
6.40j 3.204
1 0 vjOv 13.462 17.244
22.089 23.29^ 30.244
4o.42o 39.472 76.130 9 7.od 4
i2o000 i6C.I20 205.I0 6 262.732
0 0 0 0 0 0 0 0 0 0 0 4
16
33 51 60 o7 77 OD 92 95 99 1 00 102 102 1 02 102 102
102 102
0 00 0.00 0.00 0.00 0.00 0. GO 0.00 0.00 0.00 0. 00 0.00 3.92 15*69
32.36 30.00 55.32 6*3.69 75.49 33.33 9 0 2 'j 93, 197. 06 yfl 04
I00.00 100.30 100. 0>j 1 00.00 100.00 100.00 100.00
total : luMEEh OF PARTICLES IN SAMPLE* ..U -UE.R or FIBRES IN SAMPLE*
..UM.iEP percent longer than 5 MICRONS :
503
1 02 67 . j*j 9
MASS PERCE BHLO.t LE.30
0.00 0.00 0.Ou 0.03 vj V w 0.30 0.30 0.30 0.00 0.00 0.00 0.34 1 .40 4.6 w 26.79 29.44
37.29 43.24 79. 59 42 92.597. 75 95.42 13C.C0
ioc. o:
100.30 I00,00 IOC.30 100.00 1OC.00
Mb'S Sr SAMPLE*
CALCULATED FROM ?ARTICLE SIZES ESTIMATED FRO .J GROSS WEIGHT
42.40 ANQGRAMS 2 9. 76 NANOORAMS
CALCULATED PERCENT MASS Oh CMKYSO T IL.-
! 1 . I / ;
MSS Or r I SPSS LONGER THAN 6 `.11 CHONS AS PERCENT Oh SAMPLE MASS:
ID.
iO.
FIBRES LO.wEO THAN 5 MI COONS *
.oi T LLI ON/ T !_L TOR A
r i i
> ^ S/UPLS AG.ALtl
AEOG Ai'l CAflO.ilC rIE;?S CHAYSCU'ILE ANALYSIS
4430
3 i/\ 0/74
jO-HnGi*!! DI i f.4 I 301 IG;*:
1 LEGGTH
GO. Or 51 39 55
C ': 1 5pi-.jA5 )
SELO/j LEGOin
i
AU 1UEP ; Pc.ACrii'j i SELO/. LEoGT.-i
1 0,200
0 0.00
0.286
\ 0.52 3
0.420
11
0.53d 0.090
! - 3.364 > I . 132
>
I ,4'jO I . dD7
2.379
G 0.00 0 0.00 0 0.00 1 1.19 7 3.33 1 6 1 9.06
33 39.29 47 38.93 60 7! .43
66 SO. 93
( 3.047 3.903
73 co. 93 80 98.24
1 d.GCO 1 6.4Q3
d. 204
3 0 ' 93.24 8 ! 96.4;
6 ) 96. 43
10.609
81 9 *j. 4 3
13.462 1 7.244
52 97.62 82 9 7.62
22.039
83 y -j . 6 l
2 d . 2 9 -j 3o.244
83 98.51 94 1 CO.00
4o.423
39.472 - 7w. ! 30
9 / .3-*4
84 I00.00 8 4 i00.03
y 4 1^0.0 5 54 IJJ.00
122.000 1 60. 120 200.106 262.732 "
y 4 103.00 34 1 0 0.0 j
84 ]CO.00 34 i00.00
i G i\\L . .u .BE2 OF ? \9 31C LE5 10 8.4 150E :
46 9
)
Li U i i.j z .9 Or FISAS5 [.0 SAMPLE:
J4
>
.N J ,Li .9 PSriCEGI' LOGOS!? FHAA o `ICSOmS
4 . /3
GASS PESOS OSLO 1 LEGO
0.03 ' 0.00
0.00 0.00 0. ! ! 0.45 1 . 33 2. 73 o.!2 12.64
23. 15 26.29 67.86 6 7.8 j 65.13 6c. 1 3 o'*. ! 3 90. 72 9 0. 7 2 92.3: 92.5 3 1 30. 35 loo.j: 133.53 1 33.55 153. ' ' io'.o: 1 37:. 3 3 153.53 1 30.55
i /.ASS .Jr- SAMPLE:
l
CALCJLA i'EJ rii'.y[ PAP II OLE SIZES
2.20 aANOGPAGS
c`J FI MA FcO ;A<u ' 0A0S3 .iSIOof
! . - 6 .j AuOGOA A 5
CAL JOL 0 i'AO PE. r Cz -' 5 i \ 55 OF C- 5\ Y 50 i 11- * :
i . .jy
!AiJ -5- rIB.OES L.J..5r9 lGA*; 5 ICGOGj a.' ;j5Acr::i' Or i.-WLS IASS:
., v J, v)c .* I c ri E 5 L.). i Or' i.! \ j ' l 0.\ Ac
..n ;illio../ 'ILL!
. -i
SAMPLE NO.AS I
HEOMAN CATIONIC FIBRE CHRYSOTILE ANALYSIS
/a sc
28/10/74
LENGTH DISTRIBUTION!
L EAGTH (Mr CRONS)
0.200 0.2c6 0.323 0.420 0.235 0.690 0. S3 4
1 . 1 32 1 .430 i .357 2.379 3.047 3.903 5.000 6.405 3.204
1 0.3-0 9 1 3.^62 1 /.244 22.03/ 26.295 36.244
46.42S 59.472 76.150 97.564
125.000 160.120 20d.106 262.702
NO. OF FIBRES 3ELON LENGTH
0 0 0 0 0 0 0 1 1 2 3 16 30 45 56 65 71 85 90 94
98 98 99 99 99 99 99
1 00 100 100
NUMBER PERCENT BELDrt LENGTH
0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.00 1.00 2.00 8.00 16.00 30.00 45.00 56.00 65.00 71.00 85.00 90.00 94.00 93.00 98.00 99.00 99.00 99.00 99.00 99.00
100.00 100.00 100.00
TOTAL .NUMBER OF PARTICLES IN SAMPLE*
500
NUMBER OF FIBHE3 IN SAMPLE NUMBER PERCENT LONGER THAN 5 MICRONS*
ICO 55.00
MASS Or SAMPLE *
MASS PE-CS. RELUN LENO
0.00 0. 00 0,00 0. CO 0.00 0. CO
o.co
0.02 0. 22 0. 12 0.55 1 . 76 2. -*7 4.32 5. =7 16.55 I 9.3 7 73.92 3 1.4,
93.3 4 96.3' 96.37 96.54 96.54 96. S4 96.r4 96.34 1oc.o: ioc.o: 1 J4 w 0
CALCULATED FROM PARTICLE SIZES ESTIMATED FROM GROSS HEIGHT
CALCULATED PE?.CE:AT MASS OF CHRYSOTILE*
30.26 NAN0CHA.<3 30.39 NANOGRAMS
27.34 *
MASS Or FI3RES LONGER THAN 5 MICRONS AS PERCENT OF SAMPLE MASS*
26. ; 2
NO. Or FIBRES LONGER THAN j MICRONS* 1.32 M I LLI ON/M I LLI On
SAMPLE < 0A33
HEDMAN CATIONIC FIBRE CHRYSOflLE ANALYSIS
4JSj
29/10/74
i G1" i 01 5 " RI3UTI0N*
LENGTH C micronss)
NO. OF FI3PE5 3EL0W LENGTH
NUMBER PERCENT BELOW LENGTH
MASS PERCE. BELOW LENG
J - 200 0.206 0.323
0. 420
0. c3c 0.690 0.654
i . I 32 I .450 I .357 2.379 3.047 3.9Q3 5.000 6.403 3.204
10.509 I 3.462 17.244 22.039
23.29s 36.244 46.423 59.4 72
76.!dO 97.584
125.000 I 60.120 206.106 2o2.732
0 0.00
! 1.67
2 3.33
4 6.6 7
4
0.67
'
1 I 13.33
16 26.67
21 35.00
34 56.67
41 68.33
46 76.6 7
54 90.00
55 91.67
59 93.33
59 95.33
59 98.33
59 98.33
60 !00.00
60 100.00
60 I00.00
60 !00.00
60 !00.00
60 100.00
60 100.00
60 100.00
60 100.00
60 100.00
60 i00.00
60 100.00
60 100.00
TOTAL number of particles in SAMPLE*
397
NU.M3E R OF FIBRES IN SAMPLE* R PERCENT LONGER THAN 3 f I CRONS :
60 1.67
0.00 0. 08 0. 12 0.2 1 0.2 i 0. 70 0.32 3.63 4.93 5. 70 9.56 17.15 1 /. 76 20.3c 20. 35 2 0.3c 20.3c ioo.o: 1oc.oc ico.c: !CO.00 I00.0^ 1OC.00 ioo.o: 1 00.00 1cc.00 ! 00.00 i:o.oo iOC.00 1oc.oc
MASS OF SAMPLE*
CALCULATED FROM PARTICL.E SIZES ESTIMATED from GROSS WEIGHT
2. 1 9 NANOGRAMS 1 .36 NANOGRAMS
CaLCu LA TED PERCENT MASS OF CHuYSOTILH*
Iu.o4 A
MAC5 Or FI3R55 LONGER THAN 5 MICRONS AS PERCENT OF SAMPLE MASS*
13.26
r FIBRES LONGER THAN
MICRONS * 0.46 MILL! ON /MI LIIG P A
SAMPLE NO.A37
HERMAN CATIONIC FIERI
CHRYSOTILE ANALYSIS
?J
I 7/10/74
;ENGTH DISTRIBUTION*
LENGTH (MICRONS)
NO. OF FIBRES BELOW LENGTH
NUMBER PERCENT BELOW LENGTH
0.200 0.256 0.328
0.420 0.539 0.690 0.884 1.132 l- 1.450 1.857 2.379 3.047
3.903 5.000
6.405 8.204
10.509 13.462 17.244
22.089
28.295 36.244
46.428 59.472
76.180 97.584
125.000 160. 120 205.106
262.732
0 0.00 0 0.00 0 0.00 0 0.00 0 0.00
0 0.00
0 0.00 0 0.00 0 0.00 0 0.00
0 0.00 9 9.37 21 21.87 42 43.75 68 70.83 77 90.21 80 83.33 83 86.46 89 92.71 90 93.75 95 98.96
95 98.96 95 98.96
95 98.96
96 too.00 96 1 00.00
96 100.00
96 100.00
96 100.00 96 i00.00
TOTAL NUMBER OF PARTICLES IN SAMPLE* 373
NUMBER OF FIBRES IN SAMPLE!
-
NUMBER PERCENT LONGER THAN 5 MICRONS*
MASS OF SAMPLE*
96 56.25 X
MASS PERCEI' BELOW LENGj
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.42 4.08 ! 0, 12 17.65 25.36 28.74 31.07 37.60 38.54 42.47 42.47 42.47 42.47
I 00.00 IOC.00 100.00 100.00 100.00 100.00
calculated from particle sizes
ESTIMATED FROM GROSS HEIGHT
49.33 NANOGRAMS 33.37 NANOGRAMS
CALCULATED PERCENT MASS OF CHRYSOTILE*
9.64 X
MASS OF FIBRES LONGER THAN 5 MICRONS AS PERCENT OF SAMPLE MASS*
8.67 %
NO. OF FIBRES LONGER THAN 5 MICRONS* .08 MILLION/MILLICRAM
T
SAMPLE NO.A39
-.e-MAti .A* I .; N I C r I 2 R CHRYSOTILS AN'ALYSIS
st-zj -jj:
18/10/74
NOTH DISTRIBUTION*
LENGTH (MICRONS)
NO. OF FIBRES BELOW LH NCTH
NUMBER PERCENT BELOW LENGTH
0.200 0.255 0.325 0.420 0.53 3 0.590 0. =4 1 . I 32 1 .450 1 .357 2.379 3.047 3.903 j. 000 6.405
d. 224
i0.=09 I ^ *" c ^ 1 7.244
22.059
25.295 36.^44
46.423 59.472 76.:5 0 97.-54
1 2 -j . 0 0 0 160.120 205.I05 252.732
0 0.00 0 0.00 0 0.00 0 0.00 0 0.00 1 1.49 9 1 3.43 13 19.40 30 44.78 43 64. 13 49 73. 13 55 82.09 58 86.57 60 89.55 64 95.52 65 9 7.01 66 98.51 66 98.5 i 66 93.51 66 98.51 67 100.00 67 100.00 67 100.00
67 100.00 67 100.oc 67 100.00
67 100.00 67 1CC.00
67 100.00
67 i00.00
TOTAL oUMSE.A of particles IN SAMPLE*
28 1
N'iJ.V HER OF FIBRES IN SAMPLE t NOME HR PERCENT LONGER THAN 5 MICRONS*
/67
1 0. 45 3
`NASS OF SAMPLE*
MASS PERCE. BELOW LENT
0.00 0.00 0.00 0.00 0.00 0.06 1 .39 2.39 7.06 19.45 41 .53 49.6'j 53.65 57.66 32.36 A4.07
A3.72
2 w / 2 38.72 Be. ~2 100.33 ijg.c: i 3C . C0 130.00 130.33 i20.23 !20.23 ! 20.OC ! 30. OC 100.03
CALCULATED FROM PARTICLE 3IZE3 ESTIMATED FROM GROSS WEIGHT
0. 90 NANOGRAMS 2.04 NANOCRAM3
v-ALDOLAfHJ PFRCE.IT MAS5 OF CHHYSOTILE *
9.43
w
MAG4 OJ fibres lonce R THAN 6 .MICRONS AS PERCENT OF SAMPLE MASS*
3.99
-w. FIBRES LONGER THAN :5 MICRONS* 7. 78 MI LL I Oin /M I LLI ORA
SAM PL E :;c. a. 4i
HE CM AN CATIONIC FI ERF CHRYSO TI LE AN ALY SIS
/r^->/ ' ^ ?
11/11/74
- LENGTH DISTRIBUTION:
LE>' G TH (micron 55
NO. OF FIBRES BELOV LENGTH
MUM EE?. PERCENT BELOV LENGTH
MASS PEROEM E2L0" LEMGT
0.203 0. 255 3. 222 0. 420 0. 5 23 3. 690 0.334 I. 122 1.453 1.357 2. 379 3. 347 ,, 3.903
0 3. 07 3 0. 33 3 0.0 0 3 0. 00 0 3.3 3 0 0.00
3 3.03 I 0.9 1
2 N32
2 1.32
3 2. 73
8 7.27
16 14.55
5. 003 6.405 8.204
1 10.509 12.462
- 17.2^4 22.039 23-295 36.244 46.42" 59.47 1
33 53 71 31 95 99 100 104 105 106 107
33.00 48. IS
64.55 73.64
36.36 90. 07 90.9 1 94.55 9 5.45 96.36 97.27
-* 76. 179 97.352
124.999
139 I 13 1 13
99.09 100.00 I 33*37
160. 1 !"
1 10
100.00
235.103
262.722 i1
1 10 1 13
103.0C 1 00.23
1
total NUMBER OF PARTICLES IN SAMPLE:
5 19
0. 02 0. 32 0. 00 3. 30 0.07 2. 03 3. 07 0. 33 7. 3 I 3.0 1 0.3 1 3. 13 0. IS 0.35 3 c9 3.50
s. i :
IS. 53 14.24 ! 4. i 4
15.6 1 15-64
2 1.19 2 1.21 99.76 1 ? 7. 7.7 17". ^
107.70
100.00
1t ^w U _ ^C
MUM 22 R OF FIBRES IN SAMPLE
I 10
NUMZZ F. PERCENT LONGER THAN 5 MICRONS:
70. C0 *r%*
1
1'
MASS 3 F SAMPLE:
1f
CALCULATED FROM PART ICLE SIEES ESTIMATED FROM CROSS ''EIGHT
277.84 NAN OCR AM 5 79.5 4 N AM C G R AM S
_
CAT C" MATED PERCKMT MASS OF CMRYSOTILE :
33. 19
RES LON G Z? THAN 5 M! CHONS AS PERCE
4, -- ^ rr
CNG2R THAN 5 MI CRONS
SAMPLE MASS:
3 3."! r.
I L L 10 N / M ILL I "RAN
T
SAMPLE NO. A 42
helman cationic ":=r CHHYSOTILS ANALYSIS
rt a i -
I 1/ t 2/7ii
LENGTH DISTRIBUTIONS
L EN G TH CMICRCNS)
NO. OF FIBRES BELOV LENGTH
NUMBER PERCENT BELOW LENGTH
0. 200 0. 256 0. 323 0.420 0. 533 0.690 0.334 . 1.102 1.450 1.357 2. 079 3. 047
3. 903 5. 000 6. 4 05 8.204 10.539 13.46 2 17.244 22.359 25.295 36.244 46.42T 59.471
76. 179 97.532 124.999
163. 1 17 235.103 262.723
1 1 2 2 5 8 1I 19 28 55 72 84 97
105 108 1 10 111 I 12 1 14 1 14 1 14 1 14 l 14 1 14 1 14 1 14 1 14 1 14 1 14 1 14
0.38 0.38 1.75 1. 75 4.39 7.02 9.65 16.67
24.56 48.25 63. 16 73.68 85.09 92. 1 I 94. 74 96.49 97.37
98.25 100.00 100.00 100.00 100.00 100.00 I 00.30 1 00.00 100.30 100.00 100.30 100* 00 100.00
TDTAL NUMBER OF PARTICLES IN SAMPLE:
409
MASS PERCE BELOW LING
0.03 3.00 0. 30 0. 00 0. 36 3. 17 0.24 0.30 I . 36 2. i 1 5.94 6.62 20.05 20. 33 21.62 63. "4 70.42 99. 3S 100.02 100.00 100.03 i0e.00 100.00 170.00 100.00 100.23 100.00 I0C.00 100.00 120.03
NUMBER OF FIBRES IN SAMPLE: NUMBER PERCENT LONGER THAN 5 MICRONS:
MASS OF SAMPLE:
l 14 . 39 %
CALCULATED FROM PARTICLE SIDES ESTIMATED FROM GROSS WEIGHT
CALCULATED PERCENT MASS OF CHFYSOTILE
4.70 NANOGRAMS 1.36 NANOGRAMS
26.69 t
MASS OF FIBRES LONGER TH/VJ 5 MICRONS AS PERCENT OF SAMPLE MASS:
2!.:
NO. OF FIBRES LONGER THAN 5 MICRONS: l.2 MILL I ON/MILLI CRAM
.RLE
a 4;
3/ ' i /7-
12HGL il DIETS! 3UTI0N *
LENGTH (MICRONS)
0*200
0.255
0.323
0.42 J
0.53-3
0.690 0.334
i . ! 32 11 ! .450
1 .557
\1 -
2.379 3.047
11
3.903 5.000
6.4Q5
1 3.204 10.509
11 1
13.462 1 / 2 44
22.03 9
) 2 3.29 j
3o.24-
- 46.423 o 9.4; 2
76.13 0
9 /.DU-
123.000
IoO. 12 0 - 0 0 -j I 0.)
403.732
NO* OF FIBRES 3ELOW LENGTH
0 0 0
0 0 0 2 2 2 6 !0 12 29 51 74
96 1t1 124
1 25 1 29 1 3! 131 I31 1 31 1 31 131 131 131 131 131
NUMBER PERCENT BELO, 1 LENGTH
o.co 0.00 0 0u 0.00 0.00 0.00 1.53 ! 53 1 4.52 7.33 9. 1 6 22.14
33.93 56.4y
73.23 34.73 94.65 95.42 98.47 100.00 100.00 100.00 100.00 100.00 100.00 100.00 1 00.00 1 00.05 ICO. 0"0
.
MASS PERCE BELOW LSNO
0. OO 0.00 0.00 0.00 0.00 0.00 0. I 4 0. 14 0.14 2.10 2.71 3 02 13.35 22.35 31.32 45.35 37.55 73.67 76.54
91.05 1 O'J . >' w 100.00 roc.:: ioo. :o 100.00 100.00 1 OC . -j . IOC.CO ioc.o: 1 wJ J.
lOiAL .-i JMSER OF P ARTICLES IN SAMPLE:
455
.iu-tdER OF r 13 K E 3 IN SAMPLE: NUMBER PERCENT Lo NGsE THAN 5
I CRONS *
131 61.07 '9
! MASS )F SAMPLE*
CALCULATED FROM PARTI CL E SIZES
9. 33 NANOGRAMS
t
E511MATED F ROM GROSS NS ; Mr.!
30.27 nanograhs
CALCULATED PERCENT MASS OF CHRTSOTIIE
15.60
MASS OF FIBRES LONGER THAN 5 MICRONS AS PERCENT OF SAMPLE MASS *
U. '
NO. OF FI ORES LONGER THAN j MICRONS* 3.57 ULLlUN/uLLIGN V'
T
SAMPLE NO. A 415
HEDMAN CATIONIC FIBRE CHRYSOTILE ANALYSIS
ufooo
04/11/74
ngth distribution*
LENGTH (MICRONS J
0.200 0.256 0.323 0.420 0.533 0. o90 0.364
1 . 132 1.450 1 .857 2.379 3.04 1 3.90 3 5.000 6.40d d .204 10.j09 I 3.4c2 I /. 2 4 4
22.089 23.295 36.244
46.423 59.472 76.ISO 97.534 !25.000 160.120 205.106 262.732
no. Or FIBRES 3EL0W LENGTH
0 0 0 0 0 4 17 35 52 61 69 73 74
77 90 ai 82 82 32 82 82 82 32 82 82 82 82 82 82 82
NUMBER PERCENT BELOW LENGIn
0.00 0.00 0.00 0.00 0.00 4.38 20.73 42.63 63.4 1
74.39 34. 1 5 89.02 90.24 93.90 97.56 98.78 100.00 !00.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00 I00.00 100.00 100.00
MASS PERCE. BELOW LENC
0.00 0.00 0.00 0.00 0.00 0.70 4.5 1 18.40 23.43 34.25 43.37 5o. 53 57.57 63.65 36.92 38.37 100.00 100.00 100.00 ioc.o: 100.00 ioc.o: 100.00 100.00 100.00 100.00 100.00 I00.03 100.00 100.00
TOTAL NUMBER OF PARTICLES IN SAMPLE*
NUMBER OF FIBRES IN SAMPLE i DUMBER PERCENT LONGER THAN 5 MICRONS*
376
82 6.io a
MASS OF SAMPLE*
CALCULATED FROM PARTICL E SIZES ESTIMATED FROM GROSS WE IGHT
0.61 NANUCWAM3 t.d'j NANOfiRAMS
CALCULATED PERCENIT MASS OF CHRYSOTILE *
4.38 %
MASS Or FIBRES LUNGER THAN 5 MICRONS AS PERCENT OF SAMPLE MASS*
*0. r I 3RES LONGER THAN 5 MICRONS* 8.17 ' ILLI 0N/M I :_L I r"- '
6 A 1PLE NO. A 416
HEDUAN CATKIN tC FISPE CHRYSOTILE ANALYSIS
rfij y-oo#
00/1 1 /7<I
,oi'H jrsraiBuriom
LENGTH (MICRO.13)
NO. OF FIBRES BELON LENGTH
DUMBER PERCENT BELON LENGTH
NASS PERCE 5FLJ N L.-.NG
0.2QJ 3.255 0.226
0. 420 0.633
0.690 0.364
f . 132
1.400
1 .06 7 2.379
3.047
3.VC3 i.000
6. 406 6.204
10.509 17.4 62 1 7.244
22.0c9 2 i.2* J 3 o. 2 4
4c .423 *j y . 4 7 2
Jo . 1 0 *7.434 1 2j.000
1oO.120 404.100 2 02.732
0 0.00 0 3.00 0 0.00
0 0.00 1 1 .41
3 4.23 6 7. 04 I 6 22.54 24 33.30
3 = 49.30 40 64.79
6 i 7 1.33 DO 7 6.3 7 60 jA.; 1 64 90. 14 64 90.14
65 9 1.66 66 95.77 66 95. 77 70 95.69 70 96.59 70 9B.59 7 1 100.00 71 100.00 71 100.00 71 100.00
71 100.00
7! 100.00 71 100.00 71 I00.00
20TaX. NUMBER OF PARTICLES IN SAMPLE*
394
0.00 0. 70 0.30 0.00 C.3I 0.04
3.07
3.53 2.63 3.34 1 3.4y
1 3.67 1 4 . 09
1 3.5 j
16.3^ IB. 7 ^ 23.7 7
19.35 39.25 S3.. 3
6c . "D 6c.45
!00.33
[30.03 f 30.30 I30.03 100.00
I 00.00 100.30 1OG.00
NUMBER OF FIBRES IN SAMPLE t i U n l ~ R PERCENT LONGER THAN 5 MICRONS:
71
Id.49 /
'' A 5 3 OF SAMPLE*
* CALCULATED rSOM PASTICL. F SIZES = sTi.OAicO from gross NS 10 H T
OALOJLA f-I) PERCENT MASS OF C'6 NY501TL":
2.32 .-.ANOGRA 3 1.34 NMGOPA': 3
1 4. i - "
'A 3 0 Or FIBRES LO.iGFr THAN 3 VI CRONS AS 9-RC.ENT OF 3 \ PLF IASS:
1'
. < 0 . ,;, fibres longer I*hai 6 '1 I CRONS* 3.90 ILL ION/ TL -IONA '
!L HEDMAN CATIONIC F1BRE CHP.YSOTILE ANALYSIS
i' SAMPLE N0.A4I7 t
t
LENGTH DISTRIBUTION:
/OJ3
11/11/74
L EN G TH CM I CRONS:
NO. OP FIBRES EELOW LENGTH
NUMBER PERCENT BELOV LENGTH
MASS PERCE*BELOV LENG"
0. 200 0. 256 0- 325 0. 420 0. 538 3.690 0. 384 1.132 1.450 1.357 2. 379 3. 047 3. 903 5.000 6.435 8.234 10.509 13.462 17.244 22.089 28.295 36.244; 46.427 59.471 76. 179 97.532 124.999 160. I 17 205. 103 262. 728
0 0 0 0 3 0 0 1 2 5 24 37 47
6I 75 94
1 16 133 14 1 15 1 156 159 162 164 166 166 166 167 167 167
0. 00
0. 00 0. 00
0.00 0. 00 0.00 0.00 0.60 1.20 2.99 14.37 22. 16 28. 14 36.53 44. 9 1 56. 29 69.46 79.64 34.43 90.42 93.4 1 95. 2 I 97.01
98.20 99.40 99.40 99.40
1 00. 00 100.00 100.00
.
0. 00 0.00 0. 00
0. 30 0.00
0. 33 0.00 0. 01 0. 32 0. 13 1.50 3.26 4.24 7.41 1 U 17 16.04 22.00 42.69 SC. S3 9 3- 13 93.35 93. 19 93.61 96.32 99.56 99.56 99.56 100.00 107.30 100.00
total :NUMBER OP PARTICLES IN SAMPLE:
M r rMQrB OP FIBRES IN SAMPLE: NUMBER. PERCENT LONG EP. THj^J 5 MICRONS:
6 26
167 63.47 W/*
MASS 0 P SAMPLE:
CALCULATED PROM PARTICLE SIZES ESTIMATED PROM GROSS WEIGHT
32.92 NANOGRAMS 29.53 NANOGRAMS
CALCULATED PERCENT MASS OP CHRYSOTILE:
33.44 t
MASS OP PIBRES LONGER THPN 5 MICRONS AS PERCENT OP SAMPLE MASS:
33.^6
NO. OP PIBRES LONGER THAN 5 MICRONS: 1.20 M ILL ION/M ! I.I. I G^AM
T
SAMPLE NO. B 52
HEDM AM CATIONIC P1 SHE CHHYSQTtLE ANALYSIS
/rf&j
0*
1 1/ 1 1/741
LENGTH DISTRIBUTION:
\
LENGTH CM I CRONS)
NO. OP PIBRES BELOW LENGTH
NUMBER PERC^J 7 BELOV LENGTH
MASS PERCENT 3EL0V LENGTH
0. 200 0. 256 0. 32S 0.420 0. 538 0.690 3. 384 1. 132 1.4 50 1.857 2. 379 3.047 3.903 5.000 6.405 8. 234 10.539 13.462 17.244 22.089 28.295 36.244 46.427 59.471 76. 179 97.582 124.999 160. I 17 205.133 262.723
0
0.00
0.00
0
0. 00
0. 00
0
0.00
0.00
0
0. 00
0.00
3
4. 1 1
0.33
6
8.22
I .42
9
12.33
4.39
15
20.35
12.46
30
4 1.10
29.03
40
54.79
33.13
54
73.97
74.90
63
86.30
79.49
65
89.04
30.36
70
95.89
96.73
73
100.00
10e.e?
73
1 00.00
103.00
73
1 00.00
100.30
73
I 00.00
100.30
73
100.00
100-30
73
100.00
103.30
73
100.00
130.30
73
1 00.00
100.30
73
100.00
100.00
73
100.00
100.00
73
100.30
100.00
73
100.00
100.00
73
100.30
130.00
73
100.00
100.00
73
100.00
100.30
73
100.00
100.00
TOTAL NUMBER OP PARTICLES
SAMPLE:
3 19
NUMBER OP PIBRES IN SAM PL NUMBER PERCENT LONGER THAN 5 MICRONS:
73 4. 1 I W
MASS OR SAMPLE:
|
CALCULATED PROM PARTICLE SIZES
1.35 NANOGRAMS
1
ESTIMATED PROM GROSS WEIGHT
1.33 NANOGRAMS
CALCULATED PERCENT MASS OP CHRYSOTILE:
6.36 Z
> MASS OP PIBRES LONGER THAN 5 MICRONS
I
AS PERCENT OP SAMPLE MASS:
0.2 1 -
NO. OP PIBRES LONGER THAN 5 MICRONS: 2.23 MILLION/M ILLIG
SAMPLE NO.B 55
HEDMAN CATIONIC FIEF CHRYSOTILE ANALYSIS
/T, s /Oa*
11/11/74
LENGTH DISTRIBUTION:
LENGTH (MICRONS)
NO. OF FIBRES BELOW LENGTH
NUMBER PERCENT BELOW LENGTH
MASC otwcS'J BELOW LENG7
0. 200
0. 2S6 0. 3 25 0. 420 3. 335 3. 693 0.534
l. 122 1.453 1.357 2. 279 3. 347 3. 903 5.300 6.435 S. 204 10.539
13.462 17.244
22.359 25.295 36* 244 46.42" 59.47 1 76. 179 97.552 124.999
160. I 17 205.I33 262.723
0 0.00 0 0* 00 0 0* 00 0 0.00 0 0. 00' 0 0.00 0 0. 00 3 3.95 4 5.26 6 7.59 7 9.2 1 12 15.79 22 28.95 37 45.65 50 65. 79 56 73.68 64 84.21 7 I 93.42 73 96. 05 75 98.65 76 100.30 76 100.30 76 100.30 76 100.30 76 100.00 76 100.00 76 100.00 76 100.00 76 100.00 76 100.00
TC'AL NUMBER OF PARTICLES IN SAMPLE:
380
.
3* 30 0.30 0. 33 0.00 0. 30 3.00 0.00 0.07 0. 13 3. 17 0. 22 0.53 2.52 9.30 13.6 1 11.77
15.33 97.41
95.55 99.56 103.33
133.33 I 00,33 130.33 133.30 103.00 100.00 130.30 100.33 100.30
NUMBER OF FIBRES IN SAMPLE: NUMBER PERCENT LONGER THAN 5 MICRONS :
MASS or SAMPLE:
76 51.32 S
CALCULATED PROM PARTICLE SIZES ESTIMATED FROM GROSS WEIGHT
22.80 NANOGRAMS 29.51 NANOG?AM5
CALCULATED PERCENT MASS OF CHRYSOTILE:
30.13 %
OF 5 MICRONS
AS PERCENT OF SAMPLE MASS:
27.42
NO. OF FIBRES LONGER THAN 5 MICRONS: t * 7 1 MILLION/M ILL!GRAM
jA iPL.i HO. o o I 3
>1 EDM AM CATIONIC FIBRE CHPYSCflLE ANALYSIS
/rf&& ^oo o
05/11/74
rOTH 01 3 TAI BUTTON
LENGTH ('TCHOOi)
NO. OF FIBRES 3EL0W LENGTH
NUMBER PE3CEN i* BELOV< length
0.200 0.256 0.323 0.420 0. y 3 8 0.690 0.334
1.132 1.450 1.367 2.379 3.04 7
3.903 5.000 3.403 3.204
10.509 11.462 I /.244 22.069 2-.29d 36.444
4 w.42 2 *. 474 7 u. 1 o 0 97. j34 1 2-j.OOO i oO. 120 405.1Oo 462.732
0 0.00 0 0.00
(J 0.00 0 o.oo I 1 .35 2 2. 70 4 5.41
7 9. 4o ! 7 22.97
30 40.54
43 53.11 50 67.57 53 78.30 62 83.7d 64 86.4v
69 93.24
71 9 , y *j
72 97.30 73 98.6y
73 98.6-5
73 93.6'j
73 98.85 74 100.00 74 100.00 74 100.00 74 100.00 74 i00.00 74 100.00 74 100.00 74 I00.00
TOTAL i. UMBER OF PARTICLES IN SAMPLE*
414
NuM.BEN OF FIBRES IN SAMPLE * <UM5ER PERCENT LO NGER THAN 5 MICRONS !
74 16.22 . i
MAGS Or SAMPLE*
MAOS PERCE BELON LENS
0.00 0. 00 0.00 ;. oo 0.03 0! 09
0.23 0.51 0.85 2.41
3.90 9. o 7 14.77 15.64 16.39 A-. 35 9 r.. : 7 79. 5 = 99. ; / /y ^ v 9.5 9 99.59 132.00
1 00.00
I 00.30 I5C.00 I 00.00 100.07 I 00.0 3 1 C 3 _/
CALCULATED FROM PARTICLE SIZES ESTIVATED r RO.i GROSS AEI(7 iT
2.33 1 .92
it Ah 00 A AM S
.t A AKiA a j
OAL ON.A n-.O PCKCSN T '4ASS OF* C; iA V SO TII.1 * *
2.3.90
'A. > OF FlLTTiJ LONGER THAN -3 'ICAO..3
AS PSrtCS.ii OK SAMPLE -'/ASS:
4O. :
'0. Or FI FriES LOA'GcP THAN 3 ``I CRONS* 4.23 1 I LLIOA/'1 r LL I':-''. f
T
SAMPLE NO.B5 1 4
HEDM AN CAT IONIC FI BR CHRYSOTILE ANALYSIS
sri ~ <s
1 1/ 1 2/74
length distribution:
LENGTH (MICRONS)
0. 233 0. 256 0. 323 0.420 0. 53S 0. 692 0. SS4 1. 132 1.453 1*557 2. 37? 3. 047 3. 903
. 000
6.405 3. 204 10.509 13.462 17.244 22.039 23.295 36.244 46.427 59.47 1 76- 179 97.532 I 24. 999 160. I 17 205. 103 262.723
NO. OF FIBRES BELOV LENGTH
0 0 0 0 0 0 1 1 2 2 3 6 17 33 51 66 77 34 86 39 94 94 97 98 99 100 100 100 100 100
NUMBER PERCENT BELOV LENGTH
0.00 0. 00 0. 03 0.00 0.00 0.00 1.00 1.00
.2. 00
2 00 3.00 6.00 17.00 33.00 5 1.00 66.00 77.00 84.00 86.00 89.00 94.00 94.00 97.00 93.00 79.00 123.00 100.30 100.00 100.30 100.00
TOTAL NUMBER OF PARTICLES IN SAMPLE:
526
NUMBER OF FIBRES IN SAMPLE: NUMBER PERCENT LONGER THAN 5 MICRONS:
MASS OF SAMPLE:
100 67.00
MASS PERCENT BELOV LENGTH
0. 00 0. 00
.0.00
0 00 0. 00 0.00 0.23 3.23 3.33 0. 33 0. 36 0.53 1.25 3. 10 12.33 23.48 32. 37 83.32 34 37 3 1 39 02 39 02 9 1 , S3 94.48 97.04 100.00 100.30 103.00 100.33
CALCULATED FROM PARTICLE SIDES ESTIMATED FROM GROSS VEIGHT
38.76 NANOGPAMS 29.78 NANOGRAMS
CALCULATED PERCENT MASS OF CHRYSOTILE:
13.13 X
MASS OF FIBRES LONGER THAN 5 MICRONS AS PERCENT OF SAMPLE MASS:
17.62 X
NO. OF FIBRES LONGER THAN 5 MICRON?: 1.73 MILLION/M ILL!ORAM
APPENDIX III ANALYSIS PROGRAM
HSDMAh
OOSNuM
10
20
30 40
3-0
60
70
d0 1 ynj
200
2!0 220
230 240
I0
20 0
260 2 70 230 290
310
320
330 340
350
360
3 10
3d0
390
4000
4 IOC
420C
4300
4400
4500
4600
470C329C
450
490
5 00
510
220
330
240
<
550
260 l i
t^
jC
VC
DIMENSION FINDC30),VCRYC 30),NCATC30)
DIMENSION FCAlC30),KDAT3) DIMENSION SNNC20),SN(2Q)
DIMENSION ON(20)
DIMENSION PNCATC 30),DC3YC30)
DIMENSION SIZEC!000),CRUD(I 000),CHRYC1000),CL(500)
D=2.5
DO 10 I=1,30
FINDCI).1561336*1290955**1
VCRYCI)*0.
NCATCI)=0
PRINT,"LISi MAGNIFICATION,HIGH,AND LOW VALUES","*
READ,AMAG,HI,LO
HI=HI+5
LO-LO-5
PRINT,"WHAT TS TOTAL MASS Op SAMPLE","* .READ, XOTMAS
CALL OPENrCI,"KED3IN")
READ f1;,EER=2,5ND*2)C5 IZHC J),J=1 , I 000)
PRINT,"NO. OP READINGS POUND IN DATA FILE
i",U
JCOUNT=CJ-!)/2
NONC=0
NCRY=0
CVC-0
CHRYV0
IE3*0
N'*0
NN = -- I
NMISS=UC0UNT*3
SORT OUT SIZECN) PILE*
FIBRE LENGTHS CL(J)
J-I,NCRY
FI3RE VOLOSES CHRYCJ) JI,NCRY
NUMBER OF FI3RES NCRY
OTHER PARTICLE VOLUME CRUDCJ)
J*l,w)NC
TOTAL NUMBER OF FEATURES ^-iONC+hCRY
DO 100 1=I,JCOUNT w=N+2 NN=N-I
IF(N.NE.NMI S3)GO TO 9 NN+I
GO TO 1 I
IF(NN.SO.NMIS3)N=N+I Ni = N-1
CONTINUE IFCSIZE(N).LT.LOJCO TO td Ip C SIZECN ) .OT.HI )H0 TO 1 . I r ( SIZEC NN ) .LT. LO h :o i O I M
2
HHOMAN CONTINUED
500
610 620 630 640
62O coO 670 550 oy 0 700 710 720 730 740 750 760 770 730 790 5 30 610
320 330 540
530 5 60 370 530 390 900 9!0
920 930 940
950 960 970
930 990
1000 1010 1 020 1030 I 040
1 050 1 OqO i 070 1 OrtQ 1 OVQ
13 19 20
21 22 2.3 24
25
Ir(SIZECNN).01.HI)G0 To 18
GO TO 1 9 NMK=N MARK-N/6 I MK I
NONMK=*ONC
NCRYMK=NCRY GO TO 22
DEL*5IZE!N)-$IZE!N+I) DEL I=3IZE!NN)-3IZE(N)
IF(DEL 1.LT.-5. JGO TO 20
IF!ABS<DEL).3T.5.)CO TO 70 CONTINUE
IER*IER+I IF(IER.3T. I )GO TO 2 1 NMK-N MARK-N/6 rMK=r
NONMK-NONC NCRYMK=NCRY IFC IER.LT.3JG0 TO 70
Ir(d-IMK).LT.5)G0 TO 22 I ER=G
GO TO 70 IER=0
NN5aN'Mi<-o
NP2-NMK+2 PRINT 23,MARK
FORMAT!IX,"DATA ERROR*ROW NO."
PRINT 24,(SIZE!JJ),JJ*NN5,NP2) FORMAT!/,IX,4(19,16),/)
PRINT,"SKIP-0 OR REPLACE*! "d* READ, KS
IF (KS.EQ.O) GO TO 25
PRINT, JlREPLACE NO. AND VALUE11
READ, KR.NUM3 >i INK-NN5+KR-I SIZE! NK)=NUMB GO TO 70 PRINT, "SKIP NO.
READ,K
(0-3)'\~*
IF(K.SG.O)GC) TO 70 NMISS=NMK-6+K
NONC=NONMK
NCRY-NCRYMK n=NMK-4 NN=N-I
QEL*3IZE!N)-SIZECNN) IF(ABS!DEL).GT.5)GO TO 26
NONC-wONC- 1
3
HSDMAN CONTINUED
1 00 1 10 120 l 30 1 40
150 1 oO
1 70
1 80 1 VO 200 2!0 220 230 240
250 260
270 2oO
290 3C0 310 320 330 140
550
3oO 3 70
180 5 90 400 410
420 430 440 ^ ' w 460
4 70
-30 450
500
310 520
5 30 540
550 5oO 5 70
1 5O0C
! 5900
GO TO 27
26 NCRY=NCRY-1 27 ^=N+2 Nn=NN+2
'
DEL=5IZEC N)-$IZEC NN)
IF(A8S(DEL).GT.5)G0 T029
NONOiiONC-l
GO TO 30
29 NCHY=NCRY-I
30 CONTINUE
IIMfC-2 N=N-4
NN=NN-4
GO TO 100
70 CONTINUE
DEL=5IZEC N)--51ZEC NN)
5IZN=C-2566-L0 + 3.4gi*SIZE(N ))/a,'MG SIZNNs(-2566-L0+3.48!*SIZE(NN))/AMAG IFCAES(DEL).GT.5. )00 TO 5C
.*ONC=i'iONC+ 1
ORJD(NONC)=5IZN**3 *.52 3c GO TO 100
5C NCRY=NCRY+1
CL(NCRY)=SIZNN
CHRY (NCRY )=CL( NCRY)*SIZN**2*. 7354 I 00 CONTINUE
PRINT,"HON MANY ADDITIONAL FIBRES",** READ,NADD
ifcnadd.lt.i)Go ro 120
PRINT,"GIVE SIZES" READ, CCSNNCJ),5N(J)),J*l,NADD) DO I10 Jal,NADD
NCRY-NCRY+I CL(NCRY)*SNN( J ) 100./AMAG
S*5N<J)*l00./AMAG CHRYCNCRY>CL(NCRY>*S*~2*.7854
1 I 0 CONTINUE 120 CONTINUE
PRINT,"HOW MANY OTHER PARTICLES" READ,NODD
IFCNODD.LT.I)G0 TO 130
PRINT,"GIVE SIZES","* READ, (ON'C J) ,J*I ,NO0D)
DO 125 J= 1 , NO DD
NONC=hONC+I
CRUDC *u')NC) = (ONC J)*l 00./AiVUC)**3*.523o
125 CONTINUE
1 30 CONTINUE
'
DETERMINE DISTRIBUTION OH FIBRES hCAI
ANP /CRY C
-4
hedman continued
I 6CDC
I o 1 OC
TOTAL VOLUME OF FI3RE5 =CHRYV
! 62GC
VOLUME OF OTHER PARTICLES *CVC
I 630C
1640
JO 75 LL=1,NCRY
1 650
CHRYV-CHRYV+CHRY(LL)
1 660 72 JO 75 L=1,30
I 670
ri=3i-L
1690
IFCCL(LL),GT.FIND(II))G0 TO 75
1690
NCAT(II)NCAT(II)+f
1700
rCATCII)=FLOATCNCAT(II ))
1710
VCRYC ID-VCRYC II)+CHRY(LL)
1 720 75 CONTINUE
1 730
JO 200 LL=1,N0.NC
1 740 200 CVC*CVC+CRUDC LL)
i 750
C.M ASS= C CVC+CHRYV ) *2.5* 1 . E- 1 2
1 760
CMASSCMASS*1.E9
1 770
NTOT*NCRY+NONC
! 760
EMASS=42.73*TOTMAS/AMAG**2
\ 190
EMAS5=SMASS*i. EV
IN 00 2 = 0 CON'l INUE
1d10
PRINT, "WHAT IS SAMPLE N0.`*,~*
1320
READ(50,290) ALP, APL
1 33 0 2 VO FORMAT(2A3)
1340
CALL UATI.MECXUNITS,TIMDAY,;<DAT
1350
PRINT,C"-",J=I,72)
1 3 cO
PRINT 300
I 3 70 300 FORMATC//25X,"HEDMAN CATIONIC
1 loO 1 nvG I POO
PRINT 3!0,AL?,L-KLAT
310 format(3Xf"SAMPLE NO.",2A3,37X PRINT 320
iy10 i V20
32 0 FORMAT(/"LENGTH DISTRIBUTION:" PRINT 330
IV30 330 F0PMATI/4X,"LENGTH",6X,"NO. OF ,FIBRES",6X,"NUMBER P
i yt-OSdX, "MASS PERCENT")
1 PdO
PRINT 340
VoO 340 rOR.MATC 3X * " C MICRONS ) " IX, "3SLOW LENGTH" , 3X, "SSLO.v
^ 70S , dX, " MELO'O LENGTH*',/)
] VdQ 1 PVO 4 000 4 71 0 2 040 2030 404 j
4.)50
4 JOO 4 J?Q
4 0.-O ' -vc
350
*00 410
DO 350 :<=l,30 PNCAT (,<) sFCAT(?C) /NCRY* ! 00*
JCRY({0 = VCRY(K)/CHRYV*l 00. CONTINUE
PNOT5*FLOAT( NCRY-NCAT C 1 4) ) /FLO ATC NC.7Y ) < I OC CRYMAS*CHRYV/( CVC+CH3Y V ) * | 00.
CRYMS5=(CHRYV-VCRY ( ! 4 ) ) /( CVC+-CHRY V) * I GO.
P5mIL*(NCRY-NCAT( I 4 ) )/C,fASS 00 400 <=I,30
POINT 4| 0, FIN DC K) , NCAT C \ ) , PNCAf C !C) ,DCRY C FORMATC FI 0.3, I 19,F20.2,FIB.2) P NIN T 42 0, N TO T
3
:0..AN CONTINUED
2 I DO SMU
420
PRINT 430.NCRY
2120 2130 2140
430 FORMATC/6X,"NUMBER OF FIBRES IN SAMPLE *",11 5> PRINT 440,PNGT5
440 FORMATC6X,"NUMBER PERCENT LONGER THAN 5 MICRONS*",F3,
2130
PRINT 450
2 160 4jO FORMAT!/6X,"MASS OF SAMPLE*"/)
2 170
PRINT 451,CMASS
2 ! 50
451 FORMAT!12X,"CALCULATED FROM PARTICLE SIZES "fr3.2,
2190*"
A.NOCttAMS")
2200
PRINT 452,EMAS3
22 10 4-j2 FORMAT!12X,"ESTIMATED FROM GROSS HEIGHT",4X,r3.2,
2220*" i, A,NOGRAMS",/)
2220
PRINT 460,CRYMAS
2240 4o0 FORMAT!6X,"CALCULATED PERCENT MASS OF CHRYSOTILS*"F3.
11
22sC
PRINT 470,CRY?.!S5
.`
22o0 4 7 0 F0RMATC/6X,"MASS OF FIBRES LONGER THAN 5 MICRONS", /
..4 70*34X," AS PERCENT OF SAMPLE MASS*",r8.2," %")
2250
PRINT 480,?5MIL
20/0 4d: rORJMTC/6X, "NO. Or FIBRES LONGER THAN 3 MICRONS* '' ,F6.2
2SCO* " M I LLIOn/M ILLIGRAM",//)
23 1 0
PRINT,J*l,2)
2 320
PRINT,J-I,72)
2320
END
11 ^
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