Document DddjOMjgmN9M6d4wvokLeMVKa

! JefClAGSWSTlSURVEVi ........ tTRANSITEIPIP|F1ELD|0PERATIONS p^^MlSnusqKamplesfwrefteken by the membrane Filter method on several field operations thtQ^ef()rformed|onkTRANSITE Pipe. The Initial tests were conducted on March 9, 1972 Building and Hew Business Building. Moderate to strong n a direction away from the operation. However, frequent iwfwlndslcontamlria'tedlthe sample area. j^^sWfandW 1 ncopa clfico performed the operations and Larry Jarema and Ooe Macke ^3^|K|^JTngfe, .. . ?ff^8aW^^n^2i^pn^^wefe used during the tests; 4 in. Telephone Duct, 6 in. CL 150 jyt&J*i n :Seweriff j|**i f | 'n i i ii nmni Pipe. TTLhe saurmn*p. 1leMOs Iw.IAeMreA aof uvaemrwy esKhnowrtf dHuiirnattiinonn, rcnowvaerrii'ng; jK?^ET^|rj^u|^d^oi^a||Ingle operation. The test results are listed below. m Pips Size Sample Time, min. ' Kantne ms- v ' 4 In. 6 In. 8 in. 6 in. 8 in. 6 In. 8 In. |fpp*: v v. . 4 In. 6 in. 8 In. irbide.Tip Blade . i-. 1 BffiaC?-*','; 'J . m. . ipping for Sewer Saddle) w;;' ; vassj-r- .. . : . -:"- 4 in. 6 In. 8 in. 8 In. 4 in. 4.1 3.4 3.0 3.0 4.5 ' 3.6 6.0 5.0 : 6.6 5.0 129.0 96.0 8.2 20.0 28.0 24.0 ' 13.7 3.6 20.0 6.9 5.5 9.9 19.0 3.3 ` l*uu-~ --' MiedfotH: tWBi? MT003746 SC-JMM-1350 Slip' ' ................................... .. K_ .. '. . the'values listed above are not truly representative of the -t^a^0ni^erefore sPec<fic operations were re-tested on March 17, 1972 ja^hfpurpose.of^repeating.thetoperations In order to obtain a sufficient sampling time iTKefrestil ts^ofsthisurveys are41 is ted bel ow. 1 J e< _ -Mr-' VSkvi Pipe Size 6 in. 8 in. 4 in. 6 In. 8 in. 6 in. 8 In. Sewer Saddle) 8 in. Sampling Time, ........min. 20 20 20 20 20 20 20 20 F/cc 1.2 &,(o 4.1 0.7- 2.5 0*4* 3.3 1.12.5 0.4 2.5 t. <o 2.9 l. v 2.5 |.V > rmm `V ^Oenver ^V. iiis|tev;v: " iil...i.. MT003747 '!% Cf=. Research;:.A* Englneerlng Center Apr1U14r l972 : # : - LjwV., ' few EifFenner'- Denver.; v ;. istHRfrsStefe W PCf . Ivf **1 <'V'.'\.'.: i * * , ,,......... .. Especial;dust survey ITRANSITE^PIPE; FIELD.OPERATIONS - [Persona1Idust?samples:.on several field operations that are performed fon^TRANSITE:pipe;,havekbeen re-tested. Samples taken on April 10, 1972 FWemobta 1 ned-outs 1 de'between PD #1 Building and New Business Building. |Strpng?-drafts|v<erefpresent- blow1hg dust away from the operator. Due|toTra1n^those(taken on April 13, 1972 were Inside the walkway rconnect1ngPD;#l:and PD #2, The large doors on both sides of the |Walkwaytv/ere.opened and a moderate draft was blowing away from the ... ipo&jfAnderson performed the operations and Joe Macko and Tom Bordas con[ducted|the,sampling. a. pissed"for"testing were 4 In. Telephone Duct, 6 In. CL150 Water >Pipe and 8 In. CL2400 Sewer Pipe. All samples were of 20 minute Iduratlbni ; The test results are as follows: ,rtf' . ^Dpe^tion^ilfe-;;'#- . v Date Pipe Size F/cc [HanuaV Machining . > _ 53! J?1^ ` \ ' |Power: Machl ril ng 7 . ' " 4-10-72 4-10-72 4 In. 6 In. 8 In. 6 In. 8 In. 0.4 1.2 0.4 0.6 0.4 !<; i il-J J.'r*y'> ----------- Pi ammer^lridllChlsel; (Tappl ng lforiSewer;Saddle) v; 4-10-72 4-10-72 6 In. 8 In. 8 In. 1.6 1.2 1.2 V'Av#'4' ,*,..* 1 . . - ^gtSf: 4-13-72 4 In. 6 In. 8 In. cc: G. L. Swallow - Denver R. S. Anderson - Manville MT003745 Environmental Control DepartmenBenver GHQ July 20, 1972 PIPE FABRICATION --xf' Date 4/10/72 (1) 3/9/72 (2) 3/17/72 (3) 4/10/72 3/9/72 Operation Count F/cc Power Machining 0.6 0.4 Power Machining ' ; 28.0 24.0 Pipe Size Comments Sampled inside walkway - strong draft blowing away from operator. ' Sampled outside - moderate to strong drafts present - Frequent swirling winds contaminated area Short sample time - not representative of the average concentration. power Machining 1.2 4.1 Manual Machining 0.4 1.2 0.4 Manual Machining, S 13.7 3.6 .f, la;z7y.,M4Svci^jKrSfisa<5ir`iwrtaStftlS&SlgSBSfSes&f2rS'vo. .o mu--*ftJKfir MM ire 1.2 r-A. miMM S^^8' HandlRasplng;^ #p.2; 20.0! i2.5\ I2i9j Sufficient sampling time. Sampled inside walkway - Strong draft blowing away from operator. Same as item #2 Same*as' item'#3 f f-K/"'' `7?' Same ,as ./item #1; 5'A'-- Isainefas /item ; -Vjgft Mri ISamel litemjf#3 MT003748 MT003749 pnvironmental Control Department iDehver.CHO. l*i* ^rch^6^S2i:ils /yi^6o FIjU MAR 2 6 , t~.. i -r UAR vvAbwu ; KotM^IM^Candee - Manville . , Harris^^p^.^viV'v fS. J. McDuff,,* :; |b if. H ,`i BrundrettV |Pile|l6iC^ r/n^PfWAjwC-: IuFICJ GAS *' f "}*' . ; AND ELECTRIC ' COMPANY - CALIFORNIA EMERGENCY STANDARDS FOR EXPOSURE TO ASBESTOS DUST ' i^R'PMilCandee?forwarded to me a copy of your letter to him fdated;February 16, 1972. The best interim answer to the ?fquestion raised by Mr. Henry Hoenter of Pacific Gas and iElectric -is that :the Finishing Ends of our own pipe plants ^arejwithin the OSHA Standards. -. SjVs.va final answer/ 1 suggest you tell Mr. Hoenter that within |the|next/two weeks we will sample the dust levels to which fan*operator cutting and tapering asbestos-cement duct |would;be/exposed/using the OSHA recommended membrane filter/ |personal air sampler technique for determining these dust Iconcentratioris. ,rResults from these tests will be forwarded |a8^soon as they fare received. ^^|Ey|; MXrenner; EMF/ems ;t /.<fA.' ' jn?r , t* ; jfrv.''//v'A'/.' - w&SSsfc**1*'"*vj 'y j ' ' ' ' ' j| / MT003744 dCt . r j Ha # *** * TMA ;& V&& m * */** pVi to- a,f aJ slc^` l/Jc \ K^t ` . n/ff ^ cm JJ AFFIDAVIT STATE OF COLORADO COUNTY OF JEFFERSON ) ) ss. ) I, Margaret J. Baumgardner, being of full age and first duly sworn do hereby state: 1. I am the Research Coordinator for the Claims Resolution Management Corporation ("CRMC"), a wholly owned subsidiary ofthe Manville Personal Injury Settlement Trust ("Trust"). The CRMC was created in December 1998 and is staffed by former Trust employees. On January 1, 1999, CRMC began providing claims resolution facility services to the Trust. 2. In this position, I manage the Asbestos Claims Research Facility ("Facility"), a document and records repository, located at 4755 East 46th Avenue, Denver, Colorado. The Facility contains the business records including but not limited to correspondence, memoranda, reports, records and data compilations ("records") ofManville Corporation or related entities ("Manville"), generally, as well as Manville records relevant to litigation of asbestos liability. The Trust has managed and operated the Facility from November 28, 1988, the date on which the Manville bankruptcy plan was consummated. 3. My experience and familiarity with the documents at the Facility began in 1983 while working for Manville. In my work as a paralegal for Manville, I assisted in locating, indexing and packing many ofthe records which became the foundation documents for the Facility. I continued to work for Manville until September 1987. From March 1988 to September 1988,1 was hired to supervise and assist in the indexing of the first 20,000 boxes which were tinned over to the Trust in November 1988. From September 1988 to January 1989, I assisted in the privilege review of documents to be given to the Trust. From November 1988 to April 1994,1 worked for Freeborn & Peters and was put in charge of the Facility, managing all productions and "new" acquisitions. In September 1995,1 was hired by the Trust to manage the Facility. In December 1998,1 was hired by the CRMC to manage the Facility for the Trust. Accordingly, I am personally familiar with many of the records stored at the Facility, as well as how the records have been gathered. 4. To the best of my present knowledge, information and belief, I certify that these records were m ade atom ear t he t ime b y, o r from i nformation t ransmitted b y, a p erson w ith knowledge, were kept in the course of the regularly conducted business activity ofManville, and it was the regular practice and the business activity of Manville to make the records. Margaret J. Baumgardner Affidavit Page 2 5. Documents from this Facility were copied for Trine & Metcalf. The documents copied have come from microfilm at the Facility and are bates labeled MT003743 through MT003749, and these documents are true and correct copies of documents found at the Facility. Margaret J. BaumgardnsSp Subscribed and sworn to before me this 12th day of April, 2004.