Document MM33noOq9y7M6zjXNwoMrEBnk

IN RE: BALTIMORE CITY ASBESTOS LITIGATION IN THE CIRCUIT COURT FOR BALTIMORE CITY Case No.: 96231701 ANTON BIEBLE, et al. Plaintiffs v. ACandS, INC., et al. Defendants August 1996 Trial Group Judge Edward J. Angeletti Lead Case No.: 93176519 CASE AFFECTED: RICHARD T. JARRETT Case No.: 94343606 RESPONSE 07 ARMSTRONG WORLD INDUSTRIES, INC. TO PLAINTIFF'S FIRST STANDARD SET OP LIABILITY INTERROGATORIES Armstrong World Industries, Inc. ("AWI"), by its attorneys, submits the following responses to plaintiff's interrogatories. GENERAL OBJECTION, STATEMENT AND LIMITATIONS These responses are based on facts known to or believed by Armstrong World Industries, Inc., at the time of answer. Because much of the information sought is fro* many years ago, and is therefore difficult or impossible to reconstruct or retrieve, AWI reserves the right to amend these responses as, and if, new or better information becomes available or if any error is discovered. These responses are from AWI' s records and knowledge and not those of its former wholly-owned subsidiary, Armstrong Contracting & Supply Corporation (hereinafter ACandS), which operated independently of AWI. Although AWI manufactured Nonpareil asbestos-containing insulation materials from 1910 until 1929, AWI is not aware of any current personal injury claims with respect to those products; thus, no answers are given concerning those products. AWI's Contract Department expanded into the high temperature insulation contracting field at the beginning of World War II, and AWI last sold an asbestos-containing insulation product in mid-1969. The responses set forth herein are limited in time and place to asbestos-containing thermal insulation products to which plaintiffs may allege exposure and which were manufactured or sold by AWI during this time period. Because virtually all cases against AWI refer to insulation products, no answer is made concerning floor products, gasket materials, roofing products, adhesives, board or other non-insulation products. To the extent this interrogatory or request calls for information beyond this limitation, an objection is made thereto as being irrelevant, immaterial, burdensome, oppressive and/or not calculated to lead to the discovery of admissible evidence. To the extent the information contained herein differs in any respect from any prior responses to discovery, this response shall be deemed to update and supersede such prior responses. This statement is incorporated by reference in each of the following responses. Documents which may expand upon these responses are available for inspection. An index is available. "" 2 &MSWERS Ql. State the full name, address, telephone number and position of the corporate officer answering these interrogatories. ANSWER; These responses were signed by D. D. Wilson, Assistant Secretary, Armstrong World Industries, Inc., Lancaster, Pennsylvania. Q2. Have any documents and records of the defendant been used or referred to, in connection with the preparation of or answers to these interrogatories? If so, for each document referred to, state the following: a. The number of the question and its subpart; b. the identity and title of the document; c. the name and location of the file in which the document was found; d. the name and location of the file in which the document is presently located. e. the originator of the document. ANSWER; objection. It is impossible for AWI to answer this interrogatory. AWI has been involved in the asbestos litigation for many years. During the course of said litigation, its legal representatives have reviewed voluminous records of itself and others, have conferred with many current and former employees of AWI and others, and have conferred with legal representatives of others. It has thus become impossible to distinguish sources of information in an accurate and meaningful way. Q3. State the names of each person who was spoken to or who provided information to assist in answering these interrogatories and for each person state the following: a. b. ' The number of each question and its subpart for which such personnel provided information; for each question identified in a., state the name, title and position description of the personnel supplying the information; 3 -*V'- I c. the present location and address of the personnel supplying information; d. the contents of the information provided. ANSWER: See response to interrogatory 2, which is adopted and incorporated herein. Q4. Please state in which state or states of the United States or what foreign countries your business is incorporated and where its principal place of business is located. ANSWER: AWI is incorporated in Pennsylvania. AWI1s principal place of business is located at Liberty and Charlotte Streets, Lancaster, Pennsylvania (headquarters were located in Pittsburgh, Pennsylvania from 1891 to 1929). Q5. Please state whether: a. Your company is authorized to do business in: (1) Maryland (2) California b. your company does business in: (1) Maryland (2) California ANSWER: 5(a)(1). AWI registered to do business in Maryland on 10/26/38. (2). AWI registered to business in California on 2/14/38. (b). See response to Interrogatory No.S(a). Q5. State the full and complete legal name under which your company or any predecessor is now doing business and has done business at^all times from the date when it began mining, processing, manufacturing and/or selling 4 ma-- I asbestos products or thermal insulation products and materials up until present time. ANSWER; Armstrong Brother & Company, Inc. (1891-1895) Armstrong Cork Company (1895-1980) Armstrong World Industries, Inc. (5/15/80 - Present) In 1860, a partnership named John D. Glass & Company was formed. In 1864, the partnership's name became Armstrong Brother & Company. In 1891, the business was incorporated as Armstrong Brother & Company, Inc. There are no predecessor corporations to AWI. Q7. Have you ever acquired, by way of a consolidation, merger, purchase of assets, or otherwise, any company which manufactured or sold any asbestos- containing products? If so, as to each such acquisition: a. State the name and state of incorporation of the company which was acquired: b. State the reasons for the acquisition; c. State the date of the acquisition; d. State the terms of the acquisition, including but not limited to the consideration paid (e.g., amount of stock, cash, etc.) if any; e. Identify all of the company's assets which were acquired (e.g., plants, machinery, stock in trade, trademarks, patents, goodwill, etc.),- f. Identify all of the company's liabilities which were assumed by you in the acquisition; g. Identify each of the company's asbestos-containing product lines; h. Identify each asbestos-containing product line of the acquired company which you continued to manufacture after the acquisition;i. i. State the number of employees of the acquired company which w were retained by you after the acquisition; 5 j. State the names of the directors, officers, and major stockholders of your company and the acquired company at the time of the acquisition and the names of the directors, officers, and major stockholders of your company and, if it continued to exist, of the acquired company, after the acquisition; k. State the total number of shares of the acquired company which you held before and after the acquisition; l. Identify and produce a copy of the agreement between you and the acquired company, the pertinent minutes of your Board ofDirectors and all other related documents. ANSWER; Asset Purchase: John R. Livezy Company (PA 1938) T. R. Nunan Company (MA 1941) J. W. Clise and A. J. Stream (WA 1951) Goroco Products Company (PA 1936) Standard Asbestos Covering Company, Inc. (MA 1942) Stock Purchase: Van Fleet-Freear Company (CA 1934) Documents which may expand upon these responses are available for inspection. An index is available. Q8. State the names and positions of all corporate officers or officials having the responsibility for creating, directing or setting the policy of your firm with regard to the mining, manufacturing, processing, sale and/or packaging of asbestos products since 1930. AHSHSb. Objection. This interrogatory is overly broad, vague and ambiguous. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory as argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, the Vice-Presidents of the Building Materials Operations Division were-. H. R. Peck (deceased) J. V. Jones 1938 - 1960 1966 - 1967 6 F. O. Schweizer I960 1969 The above persons had responsibility for creating, formulating, etc. the policy of Armstrong Cork Company with regard to the manufacture, sale, marketing, and packaging of asbestos-containing insulation products. Q9. Have you or any of your predecessors or subsidiaries ever mined, processed, refined, sold or distributed asbestos or asbestos-containing products. If so, for each such product, complete an "Asbestos Product Information Sheet, Attachment #1. ANSWER: objection. This interrogatory is overly broad, vague and ambiguous. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, AWI was not in the business of mining asbestos. AWI was not in the business of selling raw asbestos. (a)-(c) . See Attachment A. (d). LT-30 Cork Covering Trademark: Registered: November 8, 1955. Assigned to North Lime Corp.: August 1, 1969. Armabestos Registered: 9-4-56, Reg. No. 633,840 - Mark cancelled 9-4-62 by failure to file Affidavit of Use - file tossed Armatemp Registered: 4-21-59, Reg. No. 677,201 and 5-26-59, Reg. No. 679,091 Assigned: Assigned to North Lime Corp. 8-1-69 (e)-(g). See Attachment C. (h)-(j). See Attachment A. (k)-(l). Certain products were rebranded for AWI. 7 After 1957, AWI was required to be the signatory on certain relabeling agreements between the manufacturer of the products and ACandS. These products were purchased by, delivered to and used by ACandS in contracts of installation. AWI did not purchase, sell, or install these products. (m). See Attachment B. (n) . LT Cork Covering was first manufactured with a kraft paper cover. In 1956, asbestos paper was substituted for the kraft paper for the purpose of creating a more fire resistant surface. Armasprayoriginally contained a 6D5 chrysotile asbestos. In July 1967, A. W. Amosite was substituted, and in January 1968, S/33/65 asbestos was substituted. The initial asbestos change was due to the increased fiber length, greater wet strength and improved thermal conductivity of the Amosite. The next change was a result of the discontinuation of supply of A. W. Amosite, the substitution being based upon the supplier's recommendation. ' (o). LT Cork Covering Patent: Patent Number: 2,776,231 Date of patent: January 1, 1957 Date of Application: June 28, 1954 (p)-(r). See Attachment E. (s). See Attachment D. (t) -(v). LT Cork Covering was occasionally cut or sawed to assure proper fitting around pipes. Armaspray was mixed with water and applied in wet form by a specially designed applicator. The balance of the pipe covering and block insulation identified in Attachment A was factory molded or shaped in various lengths in order to allow for custom fitting, thereby reducing the need for cutting at the job site. Cements were mixed with water before application. Documents which may expand upon these responses .are available for inspection. An index is available. 8 I (w). Process specifications for LT Cork Covering and Armaspray are available. Documents which may expand upon these responses are available for inspection. An index is available. (x). Documents which be relevant to these responses are available for inspection. An index is available. (y). Objection. This interrogatory contains an implicit assumption of matters not otherwise established which renders the interrogatory as argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, Gordon Walker, Manager, Financial Administrative Services, AWI, Lancaster, Pennsylvania, is in charge of and the custodian of the record retention schedule. (z) . LT Cork Covering can be distinguished by its unique physical structure, while Armaspray was primarily a mineral wool product with about an 8% asbestos content. With regard to the balance of products identified in Attachment A ' which were sold but not manufactured by AWI, we have neither records nor actual knowledge by which to answer this interrogatory. (aa). W. G. Owens, Senior Research Scientist, and W. H. Yeager, Senior Lab Technician, participated in the design of Armaspray. Both Mr. Owens.and Mr. Yeager have retired. Research continues with regard to the persons employed by AWI who were involved in the design of LT Cork Covering. Documents which may expand upon these responses are available for inspection. An index is available. (ab) -(ac). The manufacture of LT Cork Covering was discontinued in 1959 for the reason that it was no longer a competitive product. Armaspray was developed as a test product which was found to be commercially unacceptable; therefore, it was discontinued in mid-1969. with regard to those asbestos insulation products which AWI installed/sold but did not manufacture, these were discontinued when it got out of the contract installation business on 12/31/57.- AWI has manufactured a number of non-asbestos insulation products for low temperature applications. They were not intended to be substituted for higher temperature asbestos insulation products. Documents which may 9 I expand upon these responses are available for inspection. available. An index is Q10. If your company ever manufactured or sold any of the following types of asbestos products, please identify each product and describe how it is cut, shaped, mixed and applied on the job: a. asbestos cement mixes; b. asbestos pipe covering; c. asbestos bricks or blocks; d. asbestos sheeting, boards or marinite; e. asbestos insulation used to protect against extremes of heat as well as cold; f. asbestos insulation in loose form which may be blown into homes or buildings; g- asbestos applied in spray form; h. asbestos tape, cloth, yarn, thread or tape; i. asbestos felt or blanket; j asbestos paper; k. asbestos gaskets; giving particular reference as to whether or not the materials have been sawed or cut on the job, blown into confined areas, or mixed with water into a cement or paste. m<nm see General Objection, Statement and Limitations. Additionally, see Attachment A. LT Cork Covering was occasionally cut or sawed to assure proper fitting around pipes. Armaspray was mixed with water and applied in wet form by a specially designed applicator. The balance of the pipe covering and block insulation identified in Attachment A was factory molded or shaped in various lengths in order to allow for custom fitting, thereby reducing the need for cutting at the job site. Cements were mixed with water before 10 application. Documents which may expand upon these responses are available for inspection. An index is available. Qll. Please state if there is any way known to you that the products listed in questions 9 and 10 can be used, applied or installed without the worker involved inhaling any asbestos dust or fibers. ANSWER: Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory as argumentative, incapable of fair and correct answer, and without foundation, without waiving same and subject thereto, AWI states that since the beginning of World War II, AWI manufactured only two asbestos-containing thermal insulation products. LT Cork Covering, which contained only a small percent of asbestos in the outside paper wrapper and was used as low temperature insulation, was sold from 1956-1959. Judge Robert M. Parker granted Judgment N.O.V. in Gracedel v. Fibreboard Corporation, et al (E.D. Texas June 13, 1982) (Order attached) denying Plaintiff's claims that LT Cork Covering was defective in design and marketing and holding that AWI "shall not be liable to the Plaintiff for any exposure to Plaintiff, if any, from LT Cork Covering." For Armaspray, manufactured and sold only from August 1966 until mid-1969, Armstrong Contracting & Supply Corporation published safety instructions to be followed in all applications. The instructions were not placed on the container but were presented in the Armstrong Contracting & Supply Corporation construction manual. It is AWI's understanding that the specially trained insulation mechanics applying Armaspray were instructed according to the provisions of the construction manual. Armaspray was sold by AWI exclusively to Armstrong. Contracting & Supply Corporation. For applications of Armaspray with A-200 spray equipment, the safety instruction read: "Always wear a U.S. approved respirator when spraying. If tamping in the vicinity of the actual spray operator, the tamper should also wear a respirator." - 11 For application of Armaspray with the Armaspray junior spray machine, the safety instruction read: "Always wear an MSA approved respirator when spraying. If tamping in the vicinity of the actual spray operator, the tamper should also wear a respirator." Armaspray was sold by AWI exclusively to Armstrong Contracting & Supply Corporation (now ACandS, Inc.) from 1966 to 1969. Armaspray was packaged in bags containing the Armstrong Contracting & Supply Corporation label. Documents which may expand upon these responses are available for inspection. An index is available. Q12. Is it possible to distinguish the asbestos products listed by you in Answers 9 and 10 from those manufactured or distributed by a competitor? a. If so, please describe how you contend your product can be distinguished and identify each of your products by trade and generic name. b. ' If there are products which, in your opinion, cannot be distinguished from products of a similar kind manufactured by a competitor, please state the name of each such similar product, who manufactured it, as well as the trade name of the product manufactured by your competitor. ANSWER: LT Cork Covering can be distinguished by its unique physical structure, while Armaspray was primarily a mineral wool product with about an 8% asbestos content. With regard to the balance of products identified in Attachment A which were sold but not manufactured by AWI, we have neither records nor actual knowledge by which to answer this interrogatory. Q13. For each asbestos product listed by you in Answer 9 and 10, state whether the product could be used interchangeably with products of other manufacturers, distributors, or sellers, and if so, please identify such product and manufacturer. _ 12 ANSWER; Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, the substitution for particular products would depend upon the particular specifications and requirements of each application which information AWI does not presently have. Q14. For each asbestos product listed by you in Answer 9 and 10, state the names and addresses of each Maryland and California customer who purchased the product and each Maryland and California job site to which the products were delivered by year, and complete a Worksite/Purchase Sales Information Sheet (Attachment II) for each purchaser or worksite (Attachment IV). ANSWER; Objection. This interrogatory is overly broad, vague and ambiguous. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, under AWI's record retention schedule, sales records (invoices, bills of lading, etc.) for asbestos-containing insulation products no longer exist. All contract documents went with ACandS upon its formation in late 1957. LT Cork Covering, which contained only a small percent of asbestos in the outside paper wrapper and was used as low temperature insulation, was sold from 1956-1959. Armaspray was sold only to ACandS 1966-1969. Documents which may expand upon these responses are available for inspection. An index is available. Q15. For each asbestos product you manufactured or sold, state the total dollar, linear feet and/or number of pounds of the product: a. Sold in Maryland State; * b. Sold in the United States. ' 13 ANSWERi See response to interrogatory 14, which is adopted and incorporated herein. Q16. Identify for the period from 1935 to 1980, each distributor, dealer, wholesaler and contractor who sold, distributed or used your asbestos-containing products in Baltimore City and San Francisco California and within a 75 mile radius of each City. For each such distributor, dealer, wholesaler and contractor, state: a. The name, last known address and person who you did business with; b. The years of your relationship with the distributor, dealer, wholesaler and contractor; c. Whether there was a written agreement. If so, identify it (or them) by date, title, signatories and present location; d. Whether the relationship was exclusive, i.e., whether the distributor was not allowed to carry competing brands of some or all of'the relevant products, if exclusive as to any particular product, identify that product; e. The annual volume in pounds and linear feet and dollar amount of each type of asbestos product sold; f. The names and ultimate recipients of the asbestos products sold to or through each dealer, distributor, wholesaler, sales agent and contractor. ANSWERS Objection. This interrogatory is overly broad, vague and ambiguous. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, AWZ had no distributors (retailers or franchisers) for asbestoscontaining insulation products. Most of AWl's products were installed by AWI employees, with the exception of Armaspray, which was sold by ACandS on an installed basis. See response to interrogatory 67. 14 I Under AWI's record retention schedule, sales records (invoices, bills of lading, etc.) for asbestos-containing insulation products no longer exist. All contract documents went with ACandS upon its formation in late 1957. LT Cork Covering, which contained only a small percent of asbestos in the outside paper wrapper and was used as low temperature insulation, was sold from 1956-1959. Armaspray was sold only to ACandS 1966-1969. Documents which may expand upon these responses are available for inspection. An index is available. Q17. Identify each of your sales personnel responsible from 1935 to 1980 for sales of asbestos products in Baltimore City, Maryland and San Francisco, California and within a 75 mile radius of each city. For each such person, state the years of such employment, his job title, the last known addresses and whether he is still your employee? ANSWBRs Objection. This interrogatory is overly broad, vague and ambiguous. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation, without waiving same, under AWI's record retention schedule, sales records (invoices, bills of lading, etc.) for asbestos-containing insulation products no longer exist. All contract documents went with ACandS upon its formation in late 1957. LT Cork Covering, which contained only a small percent of asbestos in the outside paper wrapper and was used as low temperature insulation, was.sold from 1956-1959. Armaspray was sold only to ACandS 1966-1969. 15 Documents which may expand upon these responses are available for inspection. An index is available. Q18. Did you at any time manufacture asbestos-containing products which were sold to another manufacturer for resale by that company under its own name? If SO: a. Identify each manufacturer to whom such sales were made and the date of such sales; b. Identify the product or products involved in each such agreement; c. If such sales were made pursuant to an agreement, identify the dates that each such agreement was in effect and produce a copy of the agreement. ANSWER: Objection. This interrogatory is overly broad, vague and . ambiguous. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, Armaspray was sold by AWI exclusively to Armstrong Contracting t Supply Corporation (now ACandS, Inc.) from 1966 to 1969. Armaspray was packaged in bags containing the Armstrong Contracting & Supply Corporation label. Documents, which may expand upon these responses are available for inspection. An index is available. Q19. Did you ever purchase any asbestos or any asbestos containing products of say other manufacturer for distribution or sale under your name or trademark? If so: a. Identify each manufacturer from whom products were purchased; b. Identify the name of each product purchased; c. Identify the dates of each such purchase and distribution. d. Produce a copy of each purchase agreement; 16 ANSWERs Objection. This interrogatory is overly broad, vague and ambiguous. Without waiving same, certain products were rebranded for AWI. (a) Name of manufacturing company. (b) Trade name. (c) Time period. (d) Volume of transfer. (e) Purchaser. (a) (b) (c) (d) (e) . Unarco. Armabestos. 1954-1956. Unknown. AWI purchased this product for use in its contract installation services. (a) Ehret Magnesia Manufacturing Company. (b) Armstrong 85% Magnesia Pipe Covering (included Calcium Silicate inner layer for higher temperature applications.) (c) 1957. (d) Unknown. (e) AWI purchased this product for use in its contract installation services. This trademark was later assigned to ACandS. (a) (b) (c) (d) (e) Eagle-Picher. Armatemp 166 Cement. At the time AWI installed Armatemp 166 1954-1957), product data provided by Eagle-Picher contained no reference to asbestos. Through the course of litigation. Eagle Picher has provided information that suggests Armatemp 166 contained asbestos. Armstrong's information is to the contrary 1954-1957. Unknown. _ AWI purchased this product for use in its contract 17 I installation services. ACandS. This trademark was later assigned to After 1957, AWI was required to be the signatory on certain relabeling agreements between the manufacturer of the products and ACandS. These products were purchased by, delivered to and used by ACandS in contracts of installation. AWI did not purchase, sell, or install these products. Q20. Did you ever enter into distribution or licensing agreements with any manufacturer of asbestos-containing products? If so: a. Identify each manufacturer with whom such agreement was entered into; b. State the dates, products and geographical areas involved; c. Produce a copy of each such agreement; ANSWER: objection. This interrogatory is overly broad, vague and ambiguous. Without waiving same, no. Q21. For the period 1928 to the present, state the address of each miner, manufacturer or processor of asbestos or asbestos fibers used in your products and for each such miner, manufacturer or processor state: . a. The date, amounts and delivery point for each shipment of asbestos you received; b* The products in which the asbestos was used. ANSWERi Objection. This interrogatory is overly broad, vague and ambiguous. Without waiving same, the asbestos fiber in Armaspray was purchased from Lake Asbestos of Quebec, Ltd. and from North American Asbestos Corporation. The asbestos paper in LT Cork Covering was purchased from Dobeckmun Company. Documents which may expand upon these responses are available for inspection. An index is available. 18 Q22. With respect to each asbestos product (including loose asbestos fiber) you manufactured, refined, processed, sold or delivered, state whether you claim any caution, warning, caveat or other statement about health involved in using the product and/or dust generated by the product was ever given to purchasers of the product or directed to the users of the product. If so, state separately for each product: . a. The precise wording of each caution or set of instructions; b. For each asbestos product, the exact date you claim each caution was first used on that product; c. The inclusive dates you contend any alleged warning was affixed to each of your asbestos-containing products; d. Whether the wording of the alleged warning has been altered since its first appearance, and if so, when and how amended; e. Specifically what prompted you to first affix such caution, warning, caveat, statement or explanation, and what prompted the amendments, (i.e., if medical reports were relied upon, if so, identify such reports). f. The name, title and present address of the author of each such warning and/or instructions,- g. Whether the warning and instructions were physically attached to the product itself when sold and/or delivered by you, and if so, the method of attachment; h. Whether you have a copy of the warning and/or instructions in your possession at the present time, and if so, where it is located,- i. Whetbe* any studies, evaluations or analyses of any potential hazards of your asbestos product were conducted by you prior to your use of each warningand/or instructions. If so, identify the study by date, author, title and file number and state its present location. AHSWBRa Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same and subject thereto, AWI states that since the beginning of World War II, AWI manufactured only two asbestos-containing thermal 19 insulation products. LT Cork Covering, which contained only a small percent of asbestos in the outside paper wrapper and was used as low temperature insulation, was sold from 1956-1959. Judge Robert M. Parker granted Judgment N.O.V. in Gracedel v. Fibreboard Corporation, et al (E.D. Texas June 13, 1982) (Order attached) denying.Plaintiff's claims that LT Cork Covering was defective in design and marketing and holding that AWI "shall not be liable to the Plaintiff for any exposure to Plaintiff, if any, from LT Cork Covering." For Armaspray, manufactured and sold only from August 1966 until mid-1969, Armstrong Contracting & Supply Corporation published safety instructions to be followed in all applications. The instructions were not placed on the container but were presented in the Armstrong Contracting & Supply Corporation construction manual. It is AWI's understanding that the specially trained insulation mechanics applying Armaspray were instructed according to the provisions of the construction manual. Armaspray was sold by AWI exclusively to Armstrong Contracting & Supply Corporation. For applications of Armaspray with A-200 spray equipment, the safety instruction read: ' "Always wear a U.S. approved respirator when spraying. If tamping in the vicinity of the actual spray operator, the tamper should also wear a respirator." For application of Armaspray with the Armaspray junior spray machine, the safety instruction read: "Always wear an MSA approved respirator when spraying. If tamping in the vicinity of the actual spray operator, the tamper should also wear a respirator." Armaspray was sold by AWI exclusively to Armstrong Contracting & Supply Corporation (now ACandS, Inc.) from 1966 to 1969. Armaspray was packaged in bags containing the Armstrong Contracting & Supply Corporation label. Documents which may expand upon these responses are available for inspection. An index is available. 20 atfifr- I Q23. State whether any of your distributors, dealers, contractors and/or customers were provided with any warnings, cautions, caveats or instructions regarding the use of your asbestos containing products. If so, please state: a. By whom and when these instructions were first made; b. Whether the instructions were written or oral; if written, attach a copy; if oral, state the contents thereof; c. Whether your company carried but follow-up inspections to ascertain whether such instructions were adhered to and if so, please state when, where and by whom such inspections were made and the results of each such inspections. answer: See previous response. Further AWI had no distributors (retailers or franchisers) for asbestos- containing insulation products. Most of AWI's products were installed by AWI employees, with the exception of Armaspray, which was sold by ACandS on an installed basis. Q24. State the first time any officers of your Company discussed, putting * a warning or caution on any asbestos containing product, and as to that first discussion, state: a. the names of the persons who were involved in the discussions and the date and place of the discussions; b. the identity and location of all documents memorializing the discussion; c. the alleged substance of the discussion; d. what action if any, the Company took as a result of the discussion. ANSWER: See response to interrogatory 22, which is adopted and incorporated herein. Q25. Do you know of any facts or documents to support acclaim 21 that you provided any warnings, instructions or information as to the dangers of asbestos inhalation to any insulator, construction worker, building trades worker or other user of your asbestos products in the Baltimore City and San Francisco area prior to 1972? If so, for each such alleged warning: a. ' Describe in detail each such warning, instruction or information given; b. State the exact date of each such warning; c. State whether such warning, instruction or information was oral or written; d. If oral, identify the substance of the warning instruction or information given and the date and name of the person to whom given; e. If written, or printed attach a copy of each warning, instruction and information, identify it by date given, title and reference number and state the manner and location whereby it was transmitted to users of the product. ' ANSWER: See response to interrogatory 22, which is adopted and incorporated herein. Q26. Do you claim that you ever recommended to purchaser or users of the asbestos-containing products you manufactured, processed, mined, distributed, or sold, that respirators, protective masks and/or protective safeguards, be worn while working with, installing or removing your asbestos-containing product? If so, state separately for each product: a. The date or dates when each such recommendation was made; b. Who made the recommendation; c. If oral, the manner and substance of the recommendation; d. If written, identify the documents by title* date, file designation and author of each such recommendation and the location and present custodian of each such recommendation. 22 ANSWER: See response to interrogatory 22, which is adopted and incorporated herein. Q27. Did you at any time recommend that your own employees use respirators, protective masks, or other precautionary safeguards when working with asbestos-containing materials? If so, state: a. When and precisely to whom such recommendations were made; b. whether you ever supplied respirators, face masks to your employees, and if so, the date when first supplied and whether you are supplying them now; c. From what specific source you have obtained such respirators and face masks (state address of company and dates obtained). ANSWER: See response to interrogatory 22, which is adopted and incorporated herein. . Q28. Have you stopped producing, distributing and/or selling or has asbestos been eliminated from any of the asbestos products listed in Answer 9 or 10? If so, state for each product: a. The reason and date you stopped producing the product, or eliminated asbestos ,- b. The names and titles of each person who recommended and who authorized or directed the action; c. Whether any studies were conducted before you directed that production and sale of the product be stopped, or asbestos eliminated from the product, and if so, identify each study by date, author, title and subject matter and attach a copy. ANSWER: (a). The manufacture of LT Cork Covering was discontinued in 1959 for the reason that it was no longer a competitive product. Armaspray was developed as a test product which was found to be commercially unacceptable; therefore, it was discontinued in mid-1969. With regard to those asbestos insulation products which AWI installed/sold but did not manufacture, these were discontinued when AWI got out of the contract 23 1 installation business on 12/31/57. Documents which may expand upon these responses are available for inspection. An index is available. (b). LT Cork Covering: Unknown Armaspray: W. B. King (c) . Objection. This interrogatory is overly broad, vague and ambiguous. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Q29. Have any officers or employees of defendant ever discussed or evaluated whether sales of your asbestos products would be damaged if the public learned of the health hazards associated with asbestos exposure? If so, state the dates and names of participants of each such meeting and identify all documents relating to such meetings. ANSWER: See response to interrogatory 22, which is adopted and incorporated herein. Q30. At the time of the development of, and sale of each of your asbestos product did you attempt to determine whether the product complied with any allegedly applicable safety standards, orders, rules, regulations or design requirements promulgated by any professional society, association, or government body? a. If you did not, please state the reasons for not conducting such an analysis and identify the name of the person deciding not to conduct the analysis; b. If you did, identify the safety standards, safety orders, rules, regulations, which you claim you considered by naming the title, number, page and date of the regulation, and identifying the place where a copy of said regulation can be obtained. 24 I ANSWER: Objection. This interrogatory is overly broad, vague and ambiguous. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving these objections, see response to interrogatory 65, which is adopted and incorporated herein. Q31. For each asbestos-containing product, identify and produce all promotional and/or advertising material used by you with regard to the sale and/or promotion and distribution of such products. ANSWER; Objection. This interrogatory is overly broad, vague and ambiguous, without waiving same, see attached representative product sales literature for LT Cork Covering and AWI's Industrial Insulations. Documents which may expand upon these responses are available for inspection. An index is available. Q32. Identify and produce pictures and descriptions of each product. ANSWER; Objection. This interrogatory is overly broad, vague and ambiguous. Without waiving same, see attached labeling photographs of LT Cork Covering (1956 to 1959) and Armaspray (1966 to 1969) . Documents which may expand upon these responses are available for inspection. An index is available. Q33. Were any brochures, writings, or other materials made available to distributors, dealers, contractors, ultimate users, or the - general public concerning the design, manufacture, use, quality and/or properties of the asbestos products referred to in Answer 9 and 10? If so, for each such brochure or other material: a. State the purpose of each brochure and given the name, present address, telephone number of the person responsible for the 25 -*5j I preparation and acceptance of the material for distribution on behalf of the company; b. Identify the brochure or material by author, date and present location and custodian, and attach copies of each. ANSWER: See response to interrogatory 31, which is adopted and incorporated herein. Q34. Have you at any time since 1930 bought from, sold to, delivered or supplied any asbestos products to any other defendant in this action or to any other manufacturer listed in Attachment 3? If so: a. Identify the products involved by name and description; b. List the dates, quantity and price of each sale and the names of the persons who placed or accepted the order; c. Were any warnings regarding the health hazards of the product given or received and if so identify the warning by . description, date, to whom it was given and by who received, and if oral state the substance and if written identify the document and state its present location. ANSWER: Objection. This interrogatory is overly broad, vague and ambiguous. Without waiving same, sales of asbestos-containing insulation products were primarily through AWI's Contract Department. To its knowledge, AWI did not sell its asbestos-containing insulation products to other manufacturers of asbestos-containing products. Additionally, see Attachment A. Q35. With respect to any product manufactured by you which does not contain asbestos, have you ever included a warning with the product indicating that it may in some way be harmful to human beings? If so, for each such non asbestos containing product state: a. The name of the product, its intended use or purpose, and the chemical composition, or ingredients of the product; b. ' The manner in which it is thought that the product may cause harm to human beings; ' 26 c. The size, color and contents of each warning; d. The date warning was first given to the public; e. The names, addresses and titles of the people responsible for or participating in the decision to provide the warning; and f. Identify every document which relates to the making of the decision to provide a warning. ANSWER: Objection. The information sought is irrelevant to matters between Plaintiff and AWI. Q36. Were any of the asbestos-containing products sold by you to private persons or companies (i.e.., non-military or nongovernment sales) the same products you sold to the government pursuant to military or federal specifications? If so please state: a. Your name or designation for the product; b. The military or federal specification you claim is applicable; c. The person or company to whom sold and the date and amount sold. ANSWER: objection. This interrogatory is overly broad. Without waiving same, neither asbestos-containing insulation product AWI manufactured received military specification approval or was found on a Q.P.L.; as to other asbestos-containing insulation products installed by AWI's contract operation, this interrogatory should be directed to their manufacturers. Q37. Do you claim that you did anything prior to 1972 to notify users of asbestos-containing products of the possible dangers of inhalation of asbestos dust and fibers? If so, explain in detail what you did, to whom and give the dates. ANSWER: See response to interrogatory 22, which is adopted and incorporated herein. 27 I Q38. Had you at any time prior to 1973 performed, participated in or financed any tests, studies, investigations or analyses to determine the asbestos level produced when your asbestos products were used, installed or removed from a prior installation? ANSWER; Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, environmental total dust level monitoring was tested on two occasions at a job site at Brunner Island, Pennsylvania. In November 1968 and January 1969, membrane filters were used to collect dust which was present during the application of Armaspray, a mineral wool insulation product containing asbestos, manufactured by AWI. The results were inconclusive. Further tests were not pursued because of the decision having already been made to no longer manufacture the product being tested, Armaspray. Documents which may expand upon these responses are available for inspection. An index is available. Q39. Had you at any time prior to 1973 performed, participated or financed any tests, studies, investigations or analyses to determine the effects of your product on workers using or working with any of your asbestos products? ANSWER; See previous response. Additionally, the Travelers Insurance Company insured AWI's contract operation, administered workers' compensation claims, and undertook to visit selected jobs in progress to inspect job conditions and observe if reasonable safety precautions were being taken. Documents which may expand upon these responses are available for inspection. An index is- available. Q40. Had you, at any time prior to 1973 performed, participated in or financed any tests, studies, investigations or analyses which had the purpose to prevent, minimize, or eliminate inhalation of asbestos dust or fibers by those using or exposed to your asbestos products? 28 I ANSWERi. See response to interrogatories 38 & 39, which are adopted and incorporated herein. Q41. Had you at any time prior to 1973 performed, funded or participated in any investigation, study, test or analysis concerning asbestos-related diseases, asbestosis, pulmonary diseases or cancer. ANSWER: Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation, without waiving same, not to AWI's knowledge. Q42. Had you, at any time prior to 1973 performed, participated in or financed any tests, studies, investigations or analyses to determine the . effects of inhalation of asbestos dust or fibers on any one using or being exposed to asbestos products manufactured by your company? ANSWER: See response to interrogatory 41, which is adopted and incorporated herein. Q43. Have you ever performed, participated in or financed any studies to determine whether any type of respirator and/or protective mask would either eliminate or reduce asbestos inhalation to safe levels? iwqim. Objection: this interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory as argumentative, incapable of fair and correct answer, and without foundation; without waiving same, to our knowledge, respirators were effective for the purpose for which they were manufactured. 29 Q44. Have you ever undertaken or financed any tests or studies to determine whether any type of ventilator or ventilating system would eliminate or decrease the number of airborne asbestos fibers in confined spaces? ANSWER: Objection. The term "confined spaces" is vague and ambiguous. Q45. For each study identified in response to Questions 38-44, state: a. The subject matter, title, date and names of the persons who conducted and/or authored the study; b. The reason for the study; c. The date the study was completed; d. If the results were disseminated, where and to whom and if published the name and identity of the publication; e. The results of each study, and the data and assumptions relied on; f. If in writing, identify it by date, title, identification number, present location and custodian and attach a copy. ANSWER: See response to Interrogatories Nos. 38-44, which are adopted and incorporated herein. Q46. State whether you took any action as a result of any of the studies listed in answer to interrogatories 38, 39, 40, 41, 42, 43 and 44. If so: a. Describe the date and action taken; b. Identify who authorized or directed the action; c. Why was the action taken; d. Identify all documents discussing the study, the action considered and the action taken by date, title, subject, author and present custodian and location and produce the documents; e. If you have not taken any action state in detail, why not; f. If you have not given any consideration to taking such actions, state in detail the reasons why. 30 ANSWERi See response to interrogatories Nos. 38-44, which are adopted and incorporated herein. Q47. From the year 1920 to date, have you supported by gift, grant, direct cash or property payment any kind of medical research concerning asbestos? If so, state: a. The date or dates of such support; b. The dollar amount paid or contributed; c. The identity of the persons and/or organizations carrying out the research study; d. Identify and produce all documents relating to each such study. . ANSWER; Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, AWI did not direct to be performed, sponsor, finance or receive the results of any such tests or studies. Q48. Have you, at any time prior to 1975, conducted, financed, or had conducted for you any asbestos inspection or made any dust count in any of your own plants which are or were engaged in the manufacture of asbestos products. If so, state the date, place and people involved in each such inspection or test, the results of the tests and identify all records. ANSWER; See response to interrogatory 40, which is adopted and incorporated herein. Q49. Had you, at any time prior to 1975, conducted, financed, or had conducted for you any asbestos inspection or made any dust count in any of 31 your own plants which are or were engaged in the manufacture of asbestos products. If so, state the date, place and people involved in each such inspection or test, the results of the tests and identify all records. ANSWER; Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, the payment of life insurance, weekly sickness and nonoccupational benefits, total and permanent disability benefits, and retirement pensions were undertaken by Metropolitan Life Insurance Company in 1931 for Armstrong and it undertook a number of plant surveys over time in order to determine ratings for premiums and to identify and eliminate any potentially harmful conditions. Similar surveys by other entities took place in later years. The Travelers Insurounce Company insured AWI's contract operation, administered workers' compensation claims, and undertook to visit selected jobs in progress to inspect job conditions and observe if reasonable safety precautions were being taken. Documents which may expand upon these responses are available for inspection. An index is available. Q50. Does your company recognize that workers in the following trades were foreseeable users of your asbestos products? If so, when did you come to such a recognition? a. Pipe Daggers1 b. Pipe Pitters c. Welders; d. Burners; e. Sheetmetal Workers f. Tapers ,g. Chippers; h. Plasterers; 32 i. Riggers; j. Grinders; k. Inspectors; 1. Shipwrights, m. Painters; n. Boilermakers; o. Insulators; P- Custodians; q* Planners ,r. Testers; s. Teachers; ANSWER: Insulation mechanics employed by AWI were foreseeable users of asbestos-containing insulation products which AWI installed. Insulation mechanics employed by ACandS were foreseeable users of LT Cork Covering (1958 and 1959) and Armaspray (1966-1969). Q51. Does your company recognize that the types of workers listed in Question 50 would be exposed to asbestos in the course of working on jobs where other trades would be using asbestos products? ANSWER: See response to interrogatory SO, which is adopted and incorporated herein. Q53. Does your company recognize that it was foreseeable that tradesmen listed in Question 50 would inhale and/or ingest asbestos fibers released from your asbestos products? ANSWER: See response to interrogatory 50, which is adopted and incorporated herein. . 33 Q54. Do you contend that any respirators or other breathing devices would prevent inhalation of the asbestos dust and fibers released from your product? If so, state: a. When the respirator was sold; b. Give the detail description of such respirator or other breathing device; c. tThe first date you reached the conclusion; d. The basis of your claim that use of the respirator will prevent the inhalation of such dust and fibers; e. Identify any relevant tests performed by date, title, author and number. answer: See response to interrogatory 43, which is adopted and incorporated herein. Q55. From the year 1930 to the present, identify: a. The name of each physician in your employ and/or the employ of your subdivision or contract unit; b. The current and/or last known address for each such individual; c. The dates of employment of each such individual; d. The job duties and/or responsibilities for each such individual identified; e. The duration of each such individuals employment, the office address or duty assignment location held by each such individual, and the dates associated with each such assignment. ANSWER i See Attachment G. Q56. Have you, at any time since 1930, maintained any office or department dealing with medical research? If so, state: 34 a. The name and location of such department; and b. The name, address and title of each person who has been in charge of the department. ANSWER: No medical research has been conducted by AWI. Q57. From the year 1930 to the present, state: a. The address of each medial library maintained by you or - your subdivisions and/or contract units; b. When each such library came into existence; c. The custodian of each such library facility records, such as individuals dates of employment and last known address or current address. ANSWER; Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, AWI did not maintain a library or collection of medical * information as described. Documents which may expand upon these responses are available for inspection. An index is available. Q58. For each facility identified in response to the two preceding Interrogatories, state the name or titel of each medical journal or periodical subscribed to and the inclusive dates of each such subscription. awgw^. see responses to interrogatories 56 and 57, which are adopted and incorporated herein. Q59. Other than the medical library facilities referenced in the answers to the immediately preceding three Interrogatories, state the identity of each 35 medical library, from 1930 to date, in which you held a membership, or funded by way of contribution, gift, grant, or any other direct cash or property payments. ANSWER: Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory as argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, none to AWI's knowledge. Q60. State the names and addresses of all professional, trade, industrial, safety, hygiene, or health associations and research foundations or organization you have been a member of since 1930 indicating for each association: a. The inclusive dates of your membership; b. The names of your employees who attended meetings and the dates and designations of such meetings; c. The positions held by any of your employees; d. The location of all minutes, digests, reports and documents received or concerning such association. ANSWER: AWI belonged to the National Mineral Wool Association from 1947 to 1950 and again from 1953 until 1962. AWI has not been a member of any other national trade association or organization whose concern was the manufacture of asbestos-containing insulation products during the relevant time period that AWI manufactured and/or sold asbestos-containing insulation products. As a contractor, AWI's contract department belonged to numerous local contractor associations; AWI ceased such membership by the end of 1957 when it left the contracting business. Later, after AWI no longer manufactured or sold asbestos-containing insulation products, AWI had an associate membership in two national trade associations in order to present its low temperature insulation products such as Armaflex. Documents which may expand upon these responses are available for inspection. An index is available. 36 Q61. When did you first learn that there were health hazards associated with the use and/or fabrication of asbestos containing products? State the date, source, nature and extent of such information. ANSWER; AWI's understanding of the effects of asbestos on the health of workers may be generally summarized as follows: AWI first became aware of a potential risk of asbestosis to certain plant workers who might be exposed to airborne asbestos dust in the 1930s at about the time that the Commonwealth of Pennsylvania listed asbestosis as a compensable disease in its Occupational Disease Act and regulations (1937). The payment of life insurance, weekly sickness and non-occupational benefits, total and permanent disability benefits, and retirement pensions were undertaken by Metropolitan Life Insurance Company in 1931 for AWI and it undertook a number of plant surveys over time in order to determine ratings for premiums and to identify and eliminate any potentially harmful conditions. Air samples were taken in 1939, and one sample was viewed as requiring a reduction of atmospheric dust for safety purposes. A survey in 1948 included a description of asbestosis and stated that "the threshold limit for asbestos dust adopted by the American Conference of Governmental Hygienists at their 1948 meeting is 5 million particles of asbestos per cubic foot of air." AWI now understands that such statement by Metropolitan was consistent with a report of the U.S. Public Health Service, authored by Dr. W. C. Dreessen in 1938, entitled "A Study of Asbestosis in the Asbestos Textile Industry," wherein Dr. Dreessen stated that the threshold concentration of dust should be the highest dust concentration that would not produce pneumoconiosis in an originally healthy workman during his entire working life, and that "S million particles par cubic foot may be regarded tentatively as a threshold value for asbestos dust exposure until better data are available." Dr. Dreessen further stated that "it would seem that if the dust concentration in asbestos factories could be kept below S million particles . . ., new cases of asbestosis probably would not appear." 37 I AWI employed union insulators in its insulation contracting business until the end of 1957. Upon information and belief, AWI "a workers' compensation insurance carrier visited jobs in progress to inspect job conditions and observe if reasonable safety precautions were being taken. AWI is not aware that any such visits resulted in any observation or finding that insulators were exposed to asbestos dust above the threshold limit values or that hazardous conditions relating to asbestos existed on its job sites. AWI was informed that the Massachusetts Department of Health Division of Industrial Hygiene concluded that there did not seem to be an apparent dust hazard in the occupation of pipe covering or in the mixing of cement for pipe and boiler covering. Furthermore, AWI was told by Keasbey & Mattison, the manufacturer of heat insulation materials it was installing, that its employees had been manufacturing the products for years without any ill effects. AWI now understands that the Massachusetts Department of Health Division of Industrial Hygiene Report was consistent with a 1946 study of pipecoverers entitled "A Health Survey of Pipe Covering Operations and Constructing Naval Vessels," authored by Dr. Fleischer, Professor Drinker and others, where they concluded that "it would appear that asbestos pipe covering of naval vessels is a relatively safe occupation." AWI now understands that the Fleischer/Drinker conclusions were not criticized in the American medical literature until about the time of Dr. Selikoff's pioneer publications in the mid-1960s. AWI first became aware of these pioneering studies of Dr. Selikoff in the late 1960s concerning the possible risk of asbestosis, lung cancer and mesothelioma to insulators. Documents which may expand upon these responses are available for inspection. An index in available. Q62. Have you knowledge of any deaths or cases of lung disease or lung impairment prior to 1975 among your employees engaged in the manufacture or use of asbestos products which are attributable to, or were alleged to be caused by. the inhalation of asbestos dust or fibers? If so, please give the name and address of each such employee, identify all medical records possessed in relation 38 to the employee, and state whether reports of occupational disease were furnished to any bureau, branch or governmental body of the relevant state; attach copies of the latter. ANSWER' Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, AWI received a number of workers' compensation claims filed by its former union employees, which claimed health problems from asbestos. The first claim was in 19S2, and eight more were received by AWI while it continued as an employer of union insulators (until the end of 1957). Of the two claims which reached disposition during this period, AWI was dismissed from one and paid benefits in the other. Generally, AWI was only one of a number of employers named. Upon receipt of the first claim in 1952, AWI received a report from the Commonwealth of Massachusetts, Department of Labor and Industries, Division of Occupational Hygiene, that stated there did not seem to be an apparent dust hazard in the occupation of pipecovering or in the mixing of cement for pipe and boiler covering. In reference to a second claim filed, AWI was informed by Keasbey & Mattison, the manufacturer of the heat insulation materials in question, that its employees had been manufacturing such products for years without any ill effects. AWI's Insurance Department, in providing insurance administrative services for ACandS, also received workers' compensation claims by employees of that company (until 1969) and others, including Armstrong Cork Company, alleging pulmonary illness possibly related to asbestos exposure. The Traveler* Insurance Company insured AWI's contract operation, administered workers' compensation claims, and undertook to visit selected jobs in progress to inspect job conditions and observe if reasonable safety precautions were being taken; at no time did Travelers report to AWI that insulators were exposed to asbestos dust above the threshold limit values or that hazardous conditions relating to asbestos existed on its job sites. In early 1957, Travelers advised AWI that its Engineering Department was planning to survey a current insulating job, specifically in reference to an asbestos-related 39 1 workers' compensation claim. AWI left the contracting business at the end of 1957 when-that business was assumed by ACandS. -AWI has no current record of Traveler's findings. In April 1968, Canadian Johns-Manville Company, Ltd., sent a mailing to numerous companies, including AWI, which contained the minutes of the first six meetings of the Scientific Committee of the Institute of Occupational and Environmental Health of the Quebec Asbestos Mining Association. AWI was never a member of QAMA or present at such meetings. This literature was immediately sent on to ACandS with the comment from AWI's insurance manager that, prior to receiving this information, he had no idea of the extent of the research work being done in this field. Soon thereafter, ACandS assumed responsibility for monitoring its own workers' compensation claims. The products at issue in the workers' compensation claims were typically pipe covering and cements, that AWI did not manufacture; no product of any kind manufactured by AWI was ever found to be the cause of any condition of any claimant in any of these workers' compensation claims. See Attachment K. Documents which may expand upon these responses are available for inspection. An index is available. Q63. If any of your employees or officers have testified at trial or by deposition in any litigation or before any Congressional Committee or administrative agency concerning asbestos exposure, pulmonary or asbestos-related diseases or industrial hygiene relating to asbestos use, state: a. The name, address and title of each person who testified; b. The date, location and forum of such testimony; c. Whether the defendant has a copy of such testimony; d. Whether the defendant will voluntarily produce a copy of such testimony. 40 ANSWER: To AWI's knowledge, no such testimony was given before any congressional committee or administrative agency, during the time period that AWI manufactured or sold asbestos-containing insulation products. Q64. Have you or any employee or agent,of yours ever communicated with an agency or department of the United States concerning specifications and/or standard for any asbestos product or thermal insulation product? If so state separately for each product or set of specifications: a. Identify each such product and its military or federal specification or standard; b. The intended purpose or use for the product so specified; c. The date, time and place of each communication including: <1) The name of each of your agents or employees who participated in each communication; (2) The names, titles, and agencies of each individual with whom such communication was had; (3) The subject of the communication; (4) Whether any notes, minutes or memoranda in any form were recorded of such communication or of any meetings between you and the agency; (5) whether any documents were submitted to the agency; (6) If (4) or (5) is answered in the affirmative state the name, and location of the custodian of such records. ANSWERt Neither asbestos-containing insulation products AWI manufactured received military specification approval or was found on a Q.P.L.; as to other asbestos-containing insulation products installed by AWI's contract operation, this interrogatory should be directed to their manufacturers. Q65. Does your company recognize that:- 41 I a. Asbestos causes asbestosis; b. Asbestos exposure leads to an individual contracting asbestosis; c. There is a correlation between exposure to asbestos and the occurrence of asbestosis; d. Asbestos causes lung cancer; e. There is a correlation between exposure and the occurrence of lung cancer; f. Asbestos contributes to the development of gastrointestinal cancer; g. That a portion of inhaled asbestos fibers remain in the lungs after being inhaled into the human body and are not destroyed? h. The symptoms of asbestosis and other asbestos-induced lung diseases or cancers may not manifest themselves until many years after the asbestos was inhaled into the body? i. Prolonged use of the asbestos material can cause or contribute to various occupational diseases, including asbestosis, mesothelioma, cancer and other lung respiratory diseases? j. The use of asbestos insulating products listed in Answer (10) are dangerous and harmful to human health? k. There is a connection between the inhalation of asbestos dust and fibers and the disease mesothelioma? If your answer to any part of this question is "Yes", explain when you came to this knowledge and what, if anything, you have done about it to notify the public or users of your products, if your answer is that your products are not harmful then explain what facts and tests were made upon which you base such conclusion. ANSWER: AW11 a understanding of the effects of asbestos on the health of workers may be generally summarized as follows: 42 AWI first became aware of a potential risk of asbestosis to certain plant workers who might be exposed to airborne asbestos dust in the 1930s at about the time that the Commonwealth of Pennsylvania listed asbestosis as a compensable disease in its Occupational Disease Act and regulations (1937) . The payment of life insurance, weekly sickness and non-occupational benefits, total and permanent disability benefits, and retirement pensions were undertaken by Metropolitan Life Insurance Company in 1931 for AWI and it undertook.a number of plant surveys over time in order to determine ratings for premiums and to identify and eliminate any potentially harmful conditions. Air samples were taken in 1939, and one sample was viewed as requiring a reduction of atmospheric dust for safety purposes. A survey in 1948 included a description of asbestosis and stated that "the threshold limit for asbestos dust adopted by the American Conference of Governmental Hygienists at their 1948 meeting is 5 million particles of asbestos per cubic foot of air." AWI now understands that such statement by Metropolitan was consistent with a report of the U.S. Public Health Service, authored by Dr. W. C. Dreessen in ' 1938, entitled "A Study of Asbestosis in the Asbestos Textile Industry," wherein Dr. Dreessen stated that the threshold concentration of dust should be the highest dust concentration that would not produce pneumoconiosis in an originally healthy workman during his entire working life, and that "5 million particles per cubic foot may be regarded tentatively as a threshold value for asbestos dust exposure until better data are available." Dr. Dreessen further stated that "it would seem that if the dust concentration in asbestos factories could be kept below S million particles . . ., new cases of asbestosis probably would not appear." AWI employed union insulators in its insulation contracting business until the end of 1957; Upon information and belief, AWI's workers' compensation insurance carrier visited jobs in progress to inspect job conditions and observe if reasonable safety precautions were being taken. AWI is not aware that any such visits resulted in any observation or finding that insulators were exposed to asbestos dust above the threshold limit values or that hazardous conditions relating to asbestos existed on its job sites. AWI was informed that the Massachusetts Department of.Health Division of Industrial Hygiene concluded that there did not seem to be am apparent dust hazard in the 43 I occupation of pipe covering or in the mixing of cement for pipe and boiler covering. Furthermore, AMI was told by Keasbey & Mattison, the manufacturer of heat insulation materials it was installing, that its employees had been manufacturing the products for years without any ill effects. AWI now understands that the Massachusetts Department of Health Division of Industrial Hygiene Report was consistent with a 1946 study of pipecoverers entitled "A Health Survey of Pipe Covering Operations and Constructing Naval Vessels," authored by Dr. Fleischer, Professor Drinker and others, where they concluded that "it would appear that asbestos pipe covering of naval vessels is a relatively safe occupation." AMI now understands that the Fleischer/Drinker conclusions were not criticized in the American medical literature until about the time of Dr. Selikoff's pioneer publications in the mid-1960s. AMI first became aware of these pioneering studies of Dr. Selikoff in the late 1960s concerning the possible risk of asbestosis, lung cancer and mesothelioma to insulators. AMI is unaware that a causal association between asbestos and other types of cancer has been established. ' Documents which may expand upon these responses are available for inspection. An index is available. Q66. Have any workman's compensation claims based on asbestosis, mesothelioma, lung cancer, other cancers, asbestos-induced diseases, or lung diseases been filed against you? If so, for each claim state: a. The date, place filed, reference numbers and outcome of each claim; b. Whether you advised your workers, compensation carrier of the claims; ' c. The location and custodian of all records of claims and correspondence with your compensation carrier. answer: see response to interrogatory 62, which is adopted and incorporated herein. Q67. Have you as part of your business ever employed any steam 44 plane operators, boiler repair workers, insulator or had a division or unit which installed insulation materials on a contract by contract basis (e.g., a "contract unit1')? If so, state: a. The location where such persons or unit was based; b. The names of the operators or managers of the contract units; c. Whether there existed rules, regulations and/or work practices which were to be followed by such employees: d. Were such employees ever required to wear respirators. If so, please state: (1) Whether the requirement was by written regulation or oral direction; (2) the names of the people in your firm originating such a requirement and/or in charge of enforcing it; (3) The date the requirement was imposed for the first time. e. Have such former employees ever filed workmen's compensation claims due to lung or coronary illness. If so, for each such claim, state the date, jurisdiction and docket number and outcome of the claims. ANSWER: Until late 1957, AWI had an Insulation Contract Department which operated under the Insulation Division. Insulation products, including some which contained asbestos and were manufactured by other companies, were installed by the Insulation Contract Department. In late 1957, ACandS. was formed as a wholly-owned subsidiary of AWI for the purpose of assuming the contract insulation business effective January 1, 1958. This former subsidiary, which operated independently of AWI, was sold in 1969 to the North Lime Corporation, 120 North Lime Street, Lancaster, Pennsylvania. ACandS was involved in the installation of insulation products. See response to interrogatory 66, which is adopted and incorporated herein. Documents which may expand upon these responses are available for inspection. An index is available. 45 Q68. State the total number of employees of your or your contract unit receiving benefits under any Occupational Disease or Workers Compensation statute for asbestosis, mesothelioma, bronchogenic carcinoma and/or cancer of the stomach, colon or rectum for each year, from the date that you first manufactured, distributed or sold any asbestos-containing products until the present time. ANSWSR: See response to interrogatory 62, which is adopted and incorporated herein. Q69. State by year the total dollar amount paid out by you, your contract unit and/or your insurance carrier as a result of claims under any Occupational Disease or Workers' Compensation statute for asbestosis, mesothelioma, bronchogenic carcinoma and/or cancer of the stomach, colon or rectum. . ANSWKR: See response to interrogatory 62, which is adopted and incorporated herein. Q70. Identify any action, other than workers' compensation claims, brought against you by claimants injured as a result of exposure to asbestos and asbestos-containing products prior to 1970, stating the-.court in which the action was brought, the date of filing, case style, and case number. niaimt Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, none. Q71. State separately for each calendar year for the period 1928 to the present: a. The total amount of asbestos- mined by your company; 46 b. The total pound volume of asbestos fibre purchased by your company; c. The total pound volume of asbestos used by your company in its manufacturing processes; d. The total pound volume of asbestos sold by your company; e. The total pound volume of asbestos acquired by your company in any manner other than mining or purchase, and identify the manner of acquisition for each year; f. The total dollar value of asbestos mined by your company; g. The total dollar value of asbestos purchased by your company; h. The total dollar value of asbestos used by your company in its manufacturing process; i. The total dollar value of asbestos sold by your company; j - The total dollar value of all asbestos-containing products sold by you; k. The total number of pounds or linear feet of each asbestos product sold by you and the dollar value of such sales; l. The percentage of sales by dollar value and by linear foot and weight of your asbestos as compared to all asbestos sold in the United States; m. The percentage of sales by dollar value and by linear foot and weight of your asbestos-containing materials as compared to all asbestos-containing materials sold in the United States; answer: objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, AWI was not in the business of mining asbestos. Quantities of asbestos purchased from suppliers for use in the manufacture of Armaspray were: Lake Asbestos of Quebec, Ltd - 26,350 pounds of 605 Chrysotile North American Asbestos Corporation - 19,000 pounds of A.W. Amosite - 16,400 pounds of S/33/65 Chrysotile 47 Documents which may expand upon these responses are available for inspection. An index is available. Q72. Did you in any way finance, assist or participate in: a. The Metropolitan Life Insurance Company studies of asbestos conducted from 1929-1950; b. The Trudeau Foundation Saranac Lake studies from 19291950; c. The Quebec Asbestos Mining Association Study of Asbestos and Health between 1949 and 1970. If so, state what role or action you took and identify all documents relevant to such activities by name, date, title, file number and present location. ANSWER: Objection. This interrogatory contains an implicit assumption' of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, AWI did not direct to be performed, sponsor, finance or receive the results of any such tests or studies. Q73. Has your firm ever been cited or admonished by any government agency (federal, state or local) for dust levels in excess of any threshold limit value (TLV) or other predetermined number? If so, please state: ' a. The date the government agency and the dust and TLV or number involved; b. The means of identifying any document related to such an . occurrence; c. Any action taken by the agency involved. ANSWER: Objection. This interrogatory is overly broad, vague and ambiguous. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving 48 hiAm same, threshold limit values were not applicable to the asbestos-containing insulation products AWI manufactured; LT Cork Covering did not produce dust sufficient to be of concern (see Gracedel v. Fihrehoard), and respirators were used in all applications of Armaspray. Q74. State whether from 1930 to date y ou promulgated any rules, written or oral for the handling of asbestos or asbestos products by your own employees? If so, state: a. When such rules were promulgated; b. The substance of the rules, if oral, and the name, address and title of the person who disseminated them;. c. If in writing,either attach acopy of the rules or identify the written rules by date, title, identification number, present location and the name and address of the custodian thereof; . d. Whether any such material was provided to any users of your asbestos products and, if so, when and to whom. ANSWER; See response to interrogatory 22, which is adopted and incorporated herein. Q75. Have any of your employees been reassigned to other duties because of pulmonary or coronary health problems? If so, please state for each such reassignment: a. The date and reason for reassignment; b. The jobs prior to and after reassignment; c. The age and health problem of the person reassigned. ANSWER: Objection. This interrogatory is overly broad, vague and ambiguous. 49 Q76. Prior to 1972, have your employees ever been subject to periodic medical examinations? If so, please state: a. Whether the examinations were performed by your firm, its agents or employees or by outside personnel either private or governmental; b. whether the examination were performed as a result of an internal corporate decision or to comply with some governmental rule; c. whether any person was rejected for employment as a result of such examination. If so, state the date and reason for such rejection; d. Whether any employee was reassigned, terminated or pensioned as the result of such examination and the date and reason for each such occurrence. ANSWBR: It is believed that AWI provided pre-employment physical examinations, testing, and chest x-rays to all potential employees. Annual . chest x-rays were also made available to employees through local health agencies during certain time periods. Workers in certain departments and/or with certain job duties were required to wear respirators, and have annual chest x-rays and physical examinations. Process specifications, which contained information concerning health hazards and safeguards, were available to the workers as well as oral and written instructions regarding chest x- rays, physical exams, and respirators. The percentage of workers who participated in chest x-ray programs cannot be accurately determined, but it is believed that the policies regarding chest x-rays and physical examinations were enforced. Documents which may expand upon these responses are available for inspection. An index is available. Q77. Have you ever removed or had removed any asbestos insulation or other asbestos containing material from any building, plant or facility which you owned, operated, leased or maintained? If so, identify the building or SO facility, state the date the asbestos material was removed and who removed the asbestos, and. identify all documents relating to or referring to the removal. ANSWER: Objection. The information sought is irrelevant to matters between plaintiff and AWI. Q78. Was the monitoring of dust levels required by any Government regulation or rule of any government, agency, or insurance company? If so, state the substance of the rule, the source imposing it and the date it was first imposed. ANSWER: Objection. This interrogatory is overly broad, vague and ambiguous, without waiving same, see response to interrogatory 65, which is adopted and incorporated herein. Q79. Do you agree that the possibility of exposure to asbestos dust and fibers extends not only to workers actually handling the asbestos products but also to: a. Other workers in the area where the asbestos products are being used; b. Members of the families of workers. AMgwittt* AWI Objects to this interrogatory on the grounds that it is argumentative. Q80. Does your company have a record or document "retention" policy, plan or program? If so, please describe such plan. If the plan is different for separate categories of records, please describe the plan for each category. Please include in the descriptions the following: 51 a. The name and title of the custodian of the records; b. The length of time for which records are retained; c. The titles and names of the personnel responsible for determining the policy or plan from 1935 to the present; d. The titles and names of the personnel responsible for the removal and destruction of any records, pursuant to any such plans from 1935 to the present. ANSWER: AWI uses record retention schedules and records custodian; some records are disposed of after a short period of time and others are microfilmed for more permanent storage. Sales records from the contract operations were turned over to ACandS upon its formation in late 1957. AWI has sought to ensure that all documents relevant to the asbestos litigation have been excepted from destruction under the record retention schedules. . The following individuals have served as record retention custodians: Name and Title H. w. Habroker, Office Manager Richard Baumann, General Manager, Administrative Services J. w. Hughes, Manager, Office Administrative Services Gordon Walker, Manager, Financial Administrative Services Date 1937 - 1957 1957 - 1977 1977 - 1984 1984 - present Q81. Have you destroyed any documents, records or writings pertaining to a. Health hazards of asbestos; b. Workmen's-Compensation claims arising out of asbestos, lung cancer, mesothelioma, cor pulmonale, pneumoconiosis, or pulmonary fibrosis; - c. Placing warning labels on your products; 52 d. Hazardous conditions in your plants or factories; e. Funding of studies about health hazards of asbestos; f. Lawsuits arising out of injuries alleged to having been caused by asbestos. If so, list every such document destroyed by author, date and subject matter. ANSWER; See response to interrogatory 80, which is adopted and incorporated herein. Q82. Have you ever had a division or subsidiary engaged in the business of abating, removing or encapsulating asbestos materials? If so, state: a. The name of the unit of all personnel involved; b. The location where such persons or units were based; c. The dates such person or units functioned; d. The sites where such abatement, repair, encapsulation or removal occurred. ANSWER: Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, not as AWI understands these terms. Q83. Identify and produce all Minutes of each meeting of the Board of Directors or of any committee of the Board at which meeting the hazards of asbestos exposure, and/or the possible application of warning labels on asbestos-containing products were discussed. ANSWER: Objection. This interrogatory contains an implicit assumption of matters not otherwise established, which renders the interrogatory as 53 argumentative, incapable of fair and correct answer, and without foundation. Without waiving same, none. Q84. If there is any person whom the defendant expects to call as an expert witness at trial, please provide a copy of the witness' curriculum vitae, or summary of the witness' qualifications if there is no vitae, and please state for each such expert witness: . a. The person's identity , giving name, profession or occupation and address; b. The subject matter on which each such expert is to testify; c. The substance of all facts and opinions regarding which each such expert is to testify.; d. A summary of the grounds for each opinion of each such expert; . e. Whether the facts and opinions listed in (c) above are contained in a written report, memorandum or transcript and if they are, produce the same pursuant to the Maryland Rule 4-222 Notice of Production of Documents; f. If the opinion of any expert listed above is based in whole or in part on any code or regulation, governmental otherwise, identify said code or regulation and specifically set forth the section relied upon; g. Whether each such expert intends to base his or her testimony on any book, treatise, article, study , or any other document, and, if so, identify all such documents; and h. Whether the witness has testified at trial or by deposition in other asbestos-related personal injury or wrongful death cases, and if so, state for each such case: (1) the name and docket number,- (2) the court in which each such case was pending; and (3) the party for whom the witness testified. '54 answer* AWI objects to this interrogatory to the extent that it calls for information protected from discovery by the attorney work-product doctrine. To the extent that it does not request such information, expert witnesses and fact witnesses will be identified in accordance with the pretrial schedule. Q85. Identify the name and address of each nonexpert witness whom you intend to call at trial, and specifically set forth the nature and substance of the matters to which each such person will testify and summarize the facts to which such person will testify. ANSWER: AWI objects to this interrogatory to the extent that it calls for information protected from discovery by the attorney work-product doctrine. To the extent that it does not request such information, expert witnesses and fact witnesses will be identified in accordance with the pretrial schedule. Q86. Identify and produce each exhibit that you intend to rely upon at trial. answer? AWI will produce an exhibit list in accordance with the pretrial schedule. Q87. Identify all persons, other than your attorneys, who provided you with any information used in answering these interrogatories, and state the particular information each person supplied. ANSWER; objection. It is impossible for AWI to answer this interrogatory. AWI has been involved in the asbestos litigation for many years. Daring the course of said litigation, its legal representatives have reviewed voluminous records of itself and others, have conferred with many current and former employees of AWI and others, and have conferred with legal 55 representatives of others. It has thus become impossible to distinguish sources of information in an accurate and meaningful way. Q88. At any time prior to 1972, did you learn of any recommended levels of asbestos proposed by The American Conference of Governmental and Industrial Hygienists (ACGIH)? If so, state: a. The exact date you first learned of any ACGIH recommended levels; b. How you first learned of it; c. Which of your employees or agents f first learned of it; d. The steps or action you I took to advise your sales personnel of the recommendation; e. The steps or action you took to advise your customers, dealers, distributors and contractors of the AGGIH recommendation; . f. Any comment you filed or submitted to ACGIH; g. Identify all-documents related to ACGIH; ANSWER: AWI cannot precisely determine when it first became aware of threshold limit values for exposure to asbestos dust. The payment of life insurance, weekly sickness and non-occupational benefits, total and permanent disability benefits, and retirement pensions were undertaken by Metropolitan Life Insurance Company for AWI in 1931, and it undertook a number of plant surveys over time, in order to determine ratings for premiums, and to identify and eliminate any potentially harmful conditions. Air samples were taken in 1939, and one sample was viewed as requiring a reduction of atmospheric dust for safety purposes. A survey in 1948 included a description of asbestosis and stated that "the threshold limit for asbestos dust adopted by the American Conference of Governmental Hygienists at their 1948 meeting is 5 million particles of asbestos per cubic foot of air." 56 AHZ now understands that such statement by Metropolitan was consistent with a report of the. U.S. Public Health Service, authored by Dr. W. C. Dreessen in 1938, entitled "A Study of Asbestosis in the Asbestos Textile Industry," wherein Dr. Dreessen stated that the threshold concentration of dust should be the highest dust concentration that would not produce pneumoconiosis in an originally healthy workman during his entire working life, and that "S million particles per cubic foot may be regarded tentatively as a threshold value for asbestos dust exposure until better data are available." Dr. Dreessen further stated that "it would seem that if the dust concentration in asbestos factories could be kept below S million particles .... new cases of asbestosis probably would not appear." AWI employed union insulators in its insulation contracting business until the end of 1957. Upon information and belief, AWI's worker's compensation insurance carrier visited jobs in progress to inspect job conditions and observe if reasonable safety precautions were being taken. AWI is not aware that any such visits resulted in any observation or finding that insulation was exposed to asbestos dust above the dust limit values or that hazardous conditions relating to asbestos existed on its job sites. AWI was informed that the Massachusetts Department of Health, Division of Industrial Hygiene concluded that there did not seem to be an apparent dust hazard in the occupation of pipe covering or in the mixing of cement for pipe and boiler covering. Furthermore, AWI was told by Keasbey & Mattison, the manufacturer of heat insulation materials it was installing, that its employees had been manufacturing the products for years without any ill effects. AWI now understands that the Massachusetts Department of Health Division of Industrial Hygiene Report was consistent with a 1946 study of pipecoverers entitled "A Health Survey of Pipe Covering Operations and Constructing Naval Vessels," authored by Dr. Fleischer, Professor Drinker and others, where they concluded that "it would appear that asbestos pipe covering of naval vessels is a relatively safe occupation." AWI now understands that the Fleischer/Drinker conclusions were not criticized in the American medical literature until about the time of Dr. Selikoff's pioneer publications in the mid-1960s. AWI first became aware of these pioneering studies of Dr. Selikoff in the late 1960s concerning the possible risk of asbestosis, lung cancer and 57 mesothelioma to insulators. Documents which may expand upon these responses are available Cor inspection. An index is available. Q89. Do you contend that there is a minimum safe threshold level of exposure to asbestos below which there is no risk in developing mesothelioma or lung cancer? If so, specify the minimum safe threshold level of exposure for each disease, the date you claim the threshold was arrived at, and the precise basis for your contention. AMSWBR: Objection. This interrogatory requires an expert medical opinion which AHI is not equipped to render. Q90. Do you contend that there is any difference between chrysotile fiber, amosite fiber, crocidolite fiber, and/or tremolite fiber in the development of (a) mesothelioma; and (b) lung cancer? If so, explain in detail your contention as to the distinction between or among fiber types in the development of each disease and the medical authority you rely on. ANSWER: Objection. This interrogatory requires an expert medical opinion which AWI is not equipped to render. Church & Houff, P.A. 117 Water Street Suite 700 Baltimore, Maryland 21202 (410) 539-3900 Attorneys for Armstrong World Industries, Inc. COMMONWEALTH OF PENNSY' "ANIA COUNTY OF LANCASTER SS I, the undersigned, D. 0. Wilson, being first duly sworn according to law, depose and say that I am an Assistant Secretary o Armstrong World Industries, Inc. The information contained in the responses hereto was gathered pursuant to my overall guidance by employees o this Company. I have no personal knowledge o same but am informed and therefore believe the answers to be true and correct. The responses have been prepared by counsel. I am executing this affidavit solely for the purpose of affixing the Company's signature hereto. DATED: ), iWC, ARMSTRONG WORLD INDUSTRIES, INC. A Pennsylvania Corporation BY: Assistant Secretary On this ) day of , 1996, before me personally appeared D. D. Wilson, to me known to be the person described herein, and who executed the foregoing instrument and who acknowledged that Jae voluntarily executed the same. , 1 7, Notary Publis- \ x ' : I Attachment a ARMSTRONG'S CONTRACT DEPARTMENT Armstrong historically was a low temperature insulation manufacturer and contractor, supplying cork insulation products which were installed by its employees in dairies, ice houses, etc. Except for a limited product line manufactured from approximately 1910-1933, Armstrong's main involvement with high-temperature asbestos-containing insulation products began at the beginning of World War II, when its Contract Department first obtained the right to install products manufactured by Keasbey & Mattison. Armstrong remained an insulation contractor until the end of 1957, when the contracting business was taken over by ACandS. Documents which may expand upon these responses are available for inspection. PRODUCTS MANUFACTURED BY OTHER COMPANIES AND INSTALLED BY ARMSTRONG CONTRACT EMPLOYEES Keasbey & Mattison (1939-1957) The following products were sold by Keasbey & Mattison Company for installation by Armstrong's Contract Department at various times and locations; not every product was available at all times and at every location. 85V Magnesia Pipe Covering & Block and Cement were used to insulate pipes and surfaces with temperatures up to 600F. Hy-Temp Pipe Covering & Block and Cement were used to insulate heat lines and surfaces with temperatures ranging from 600F to 1900F. Kamatt Pipe Covering was used to insulate pipes with temperatures up to 750"F. Kaytherm Block was used to insulate surfaces with temperatures up to 1500F. Mani-Ply Insulation were used to insulate pipes with temperatures up to. 500F. ,, . Bestfelt Pipe & Block ( Sheet was used to insulate temperatures up to . 700#F. The pipe covering was used on lines subject to vibrations. Air Cell Insulations were used on lines or surfaces with temperatures up to 300F. Simplex Pipe Insulations were used to insulate lines with temperatures up to 300*F where a water-repellent surface was needed. Duplex Wool Felt Pipe Insulation was used to insulate hot or cold water lines 40F to 210F. K&M Asbestos Insulating Cements: No. 151 - smooth, hard surface,- No. 152 - general utility cement; Velvet Hard Finish - hard gloss finish over blocks or cements; Mineral Wool - used in place of block insulation; Amblerex No. 2 - up to 1000F0. K. P. Asbestos Floats were used to give a dense, tough, hard quality to the final asphalt plastic finish bn walls of low temperature rooms (EX 25 asbestos in earlier years). Unarco (19S4-19S6): Armabestos Pipe Covering 6 Block was used to insulate pipes with temperatures up to 750F or 1200F, or surfaces up to 1200F. Ehret Magnesia (1957): 85% Magnesia Pipe Covering and Block (and Calcium Silicate Pipecovering for use as an inner layer with 85% magnesia) was used to insulate pipes and surfaces with temperatures ranging from SOOF (85% Magnesia alone) to 1200F (both layers). Page 1 of 2 Baldwin-Hill (1951-1956): Baldwin-Hill #1 Insulating Cement was used for plastic insulation on irregular surfaces up to 1800F. Owens-Illinois (19SS-19S7): Kaylo Pipe Covering & Block was used to insulate pipes and surfaces with temperatures up to 1200F; Kaylo-20, up to 1800*F. Eagle-Picher (1954-1957) : Armatemp 166 Cement was used as an all-purpose insulating material on surfaces up to 1800F. At the time AMI relabeled Armatemp 166 (1954-1957), AHI was unaware that it contained asbestos. Through the course of litigation, Eagle-Picher has provided information that suggests Armatemp 166 contained asbestos. PRODUCTS MANUFACTURED BY ARMSTRONG LT Cork Covering (1956-1959) was a pipe insulation, -120*F to 200F. Armaspray (1966-1968) was used by AC&S to insulate large irregular surfaces, up to 1600F. Page 2 of 2 I Attachment E ARMSTRONG* S CONTRACT DEPARTMENT Armstrong historically was a low temperature insulation manufacturer and contractor, supplying cork insulation products which were installed by its employees in dairies, ice houses, etc. Except for a limited product line manufactured from approximately 1910-1933, Armstrong's main involvement with high-temperature asbestos-containing insulation products began at the beginning of World War IX, when its Contract Department first obtained the right to install products manufactured by Keasbey & Mattison. Armstrong remained an insulation contractor until the end of 1957, when the contracting business was taken over by ACandS. Documents which may expand upon these responses are available for inspection. I. PRODUCTS MANUFACTURED BY OTHER COMPANIES AND INSTALLED BY ARMSTRONG CONTRACT EMPLOYEES Packaging Armstrong Cork Company was primarily an insulation contractor whose employees installed insulation products at specific job sites. Most of these' asbestos-containing insulation products were manufactured by other companies. These products were packaged by the manufacturer according to its own specifications. Pipe coverings, block and sheet were packaged in cartons; cements and floats in bags. Labeling ' Most of these asbestos-containing insulation products were manufactured by the Keasbey-Mattison Company and labeled with the Keasbey and Kattison name. They were not labeled with the Armstrong Cork Company name. Kaylo was labeled by Owens-Corning Fiberglas with its name. A limited number of asbestos-containing insulation products were relabeled by the manufacturers to include the Armstrong Cork Company trade name: Armabestos in 1954 - 1956 (manufactured by Unarco) 95% ' Magnesia Pipe Covering (included Calcium Silicate inner layer) in 19S7 (manufactured by Ehret Magnesia Manufacturing Company) and Armatemp 166 Cement in 1954-1957 (manufactured by Eagle-Picher). XX. PRODUCTS MANPFACTTTPwn nr ARMSTRONG Packaging and raheHna LT Cork Covering (1956-1959) was packaged in cardboard cartons with the trademark "Armstrong" with the letter "A" centered in a colored disc. Armaspray (1966-1968) was packaged in SO lb. kraft paper bags printed with th* name Armstrong Contracting 6 Supply Corporation, Lancaster, Pennsylvania. Page 1 of 1 Attachment G Armstrong has employed physicians and nurses at its plants Cor many years to provide emergency first aid and other on-site medication and care to employees who would be later referred to their own Camily physician for further treatment as necessary. Documents which may expand upon these responses are available for inspection. An index is available. Beaver Falls Plant: Dr. L. P. Atwell -- until 1966 (deceased) Dr. J. C. Sutton, Jr. -- 1966 to present Braintree Plant: Dr. Jason Loche -- 1957 to 1991 Fulton Plant: Dr. William Fivaz -- 19S2 to 1980 Jackson Plant: Doctors Offerrell, Safley and Williams served from the 1950s through the early 1980s. ' Lancaster Plant: Dr. Schaeffer -- 07/28/52 to 07/01/84 Dr. William Bakken -- 07/01/84 to 07/01/89 Dr. David Frederick Dr. william Roberts Dr. Gary Gehman Dr. Lehman -- 10/01/51 to 01/01/91 Dr. J. William Parke -- 02/27/89 to 06/90 Dr. Randy Westgate Dr. James Bernheisel . Dr. Dr. Dr. Dr. Dr. Dwight Kauffman -- 6/90 to 1993 Kenneth Burst -- 6/90 to 12/92 John Wolgemuth -- 6/90 to 1993 Ksb Brubaker -- 1990 to 1993 Mai Hamley -- 1993 Page 1 of 1 BO 0 o c o 1 i %4 g P % JJ aC Jj ft) V hIl an -i * u T) Vl E B b 090U > M -H IM aouciMi B E d B id ft) (J O JJ d >, O 3 B 3 JJ d 4 01 *H C >4 6 0 0 *H Vi M CD Jj CD 0 0 EE 5 -H M o vi IA JJ CO d V) rH CM C w E B t E Eo BV B V 10 1*0 *o rH rH H 6 u JJ 10 JJ CD B0 B 3 JJ * JJ ID H JJ H jl o\ * Q Q < CO CO C 4<H 9) D 0 <0 C W d rH C ft) ft) B H 0D.30 Q d B1MU a uje e o a o><h i H H V) 3 Cl C B E B ft) ft) c *0 -h a -H ft) c JJ #) ti JJ d B d ift U JJ JJ Vi E AJ d Od E d d E a > jj * O ID ft) d JJ d ft) ft) d >i O d ft) O ft) O E d Vl ft) a JJ H OX 19 300 *0 3 0 0 O *H v* E B E H c 0 H J) H f BJ IA VD rH IA H CD \0 in Vo N* E 4) ft) Vi -- O ft) |s d C 3 in B o oi a 0* Vl Q -H C X *0 0U -HOC rH 0 c S.C B H Q O rH Nft, IA CD CD N* IA d ft) d JJ H 0 UrIO d 0 B Vj <0 id *0 -H O B i> 0. 0) BBS B B33 d Vi 0 *0 >, 0 *> *J V* B HMtCOt a B ) jj a au E o X 3 a a jj b ft) a ) b vi i< 0 B JJ X ' X aB B Ij W Jj ft) 0 E 0 -H o u JJ * O JJ c u O JJ O O-rt Vi JJ B Bd JJ ft) V Vi JJ > B E JJ B 0 * ft) B <H B 0 a > 0 3 JJ ft) rH U 8 B TI B O E ft) E 3 > Bd E B 0 B JJ 3 dd S (J V. 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In d . A c c id . Comm. 1 2 /3 0 /5 9 O a k la n d H o. 59 OAK 1367 B 0 C co OH H A> JJ rt E u 0< a 00 *r4 JJ o o *0 fcj JJ *u *H o 0c Z *H H B -H .. 6 0 Q H B n B H E B H Q * JJ aj a em B H i-t m JJ r4 JJ d 0 0* 1 AJ c .s E0 > H AJ * JJ d H 00 c 0 H AJ -*H JJ 0 ao *r4 O g &. Cl O TJ 0 U Vi -rH JJ u <Ou U JJ U Q a 3 xa o0 00 N* r* o d *H \ r- H - O U H o0 u0 fCtD . O U. d c w e M Vt VO b. in . rH C ao U co K r* CD 8d rN 0 M C Cn M0 B fid *H B TJ H 0 XXX 00 00 N*. 0 dH oO H 0 S* 5* 0 d uo 0d JH0 0 M >< IM 30 zaz O 0 gd 1A 00 U0 a u 0 Xz JJ c E0 VH iH d JJ jj d H 00 JJ C0 d H rH 0 JJ CD JJ % 0 00 H 0 0 H 0 H Q O 0 Hd -N* 0 0 d V* CD r* H\ rH 0 0 CD W to r CD H AJ AJ #H * Qtr* 3 0 da c0 <0 HTJ B COO UHJ2 O 0 o < -H 2 u u<c JoJ O B c0 mm 0d o 0 uo 30 ah 0 az jj C o rH 0 AJ JJ d 00 H 0 0 H 0 d o 0 0 t* d s* r*> 1 O 0 M V0 rt I U Od U O CD " ' H O bi d Bn e h Ih r b. in r-l e <8 o o to z V 3 JJ 0 > C - *0 V t> rH 4J c > -m u 0 JJ < JJ >. JC H U JS M Ei 3 JJ 0 V U AJ < < H Ch 0 v> O nuu Vi Vi - 0) V V AJ N -rl & . * M C 0> c X- C *0 Vi -Ji c m C 3 C -H C S RJ 0)3 3 E (0 0) ik rot O -r4 EM3 AJ rH X ^3 c rH Vi o E 0 VO RJ EO it 0P)<-< n ->H- X c u Z w X CQ 0 O am 3 C 3 0 c X c 3. p 3 o p X c 3 JJ 0 *0 *< 00* rH *0 0 JS >iH * Q m m *H V4 <H rH JS U AJ < woo b a 0i rH 0* * p 0 cu 3 rH T3 * *H C 0 0* JS h< p 3 rH AJ rH X Einn HHJ< p d JS Eo 3 0 01 0 0 o Unknown 6 /5 9 T h o rste d , Roy (address unknown) AJ *6H1 aj a B *r| H w u H U Uw <w ao 0 0 \ 0 0 0 d r^ r- 0 00 o n rH d CO CO 00 0 CD in CD o u TJ U W0 a* * H M u rH 0 3 2 *J*J4 XUI a*a E O AJ 0 UZZ > rl Wl WQ C TJ < JS 0 u 00 ^ ? * 0 >4 JJ jj in C 3 OS E JJ uo u o u *o WdW AJ U u AJ 0 JS >*AJ U*W Cdz zr * jj * fc 0 0* h Z 9 i aj n > V4 rH rH 0 ^4 S rH > H V4 a o> Z jj *o cc UH 0 c H > % > 0 rH AJ O* rH rH 0 O d JS U r* U > H H ^ QO * 0T3 >TJ U U tH 0 V4 ct JJ X >*U c -CX 3 * 0 JJ B Wd Zd0 < u U V O UTJ Vi 0 *J 0 un $ * rl lV>4 rl rl rH RJ 0 aa Vi Vi in X Amu U n Vi OrnH 2O z-- d 5 0 EC * ^c 3 TJ kH B j: k4 a*o *o JS 0^ . *3 z E 0e JS 5 H0 jj d a u at e u tH C O rH H a co a 3 ' AJ 0 o u S< JJ W0 % a0 JS jj 0 n *D W -H COD >c rH * rH U UHlli H 0 Uc JJ 0 0d0 I No aw ard In d ic a te d W ash. 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S p o k a n e , WA 8 /6 1 G ro n e n th a l, John 1116 F ifth Avenue S p o k a n e , WA XX ft) H 0 x) c co * fUt) 0 X -H 4 ft) C 4J rH B 0 c U B XJ 4 "S E H . < *o o 4 rH ft) cn C ft) CN 4 o a rH CO a X) X ft) -- *oS S5 ao c cc 03 B X) B XB ft) ft) 0 x JS *0 X) TJ 34 Uw x) B ft) Z O > r- (N O 4 OX H rH X) b X3 o to n rH C rH in Ih 40 4 H 4 ft) > in a < X) U ft) ft) u0 x) x) U Xi CO B ft) H XU 0^c a34 HM *a -H 4 C0 c H rH 4 tQ m CO 0 3 ^) C ft) > J< wC< X> H u B0 MU * 0 C TJ X-H c X) J Q H E ft) P- X U rt U u ve h co w a 0) 3 c ft) > a< >< c ft) 4 b> *CHD H 4X S ZU -H Z In B t) H IS X) x) rH B xmx U3 <CND Hc ft) 3 C ft) > < ft) E *0 4 *H >< H B Z rH *0 rH 0 * H O ft) z z -*Ho o C O TJ 4O ft) rH 0 Q to * a *0 Xt ft) 03 bn C < MH ft) u *rH > rH <4 Do ft) XJ .* c O) 0 ft) CX E H 4 TJ Xi o UO 44 4 X rH CO ft) 3 c ft) > < Z ft) c B3 Eft) *0 5< 4 JJ OQ ft) E * Z *H >*. ft) ft) to x rH 0 4 Hin c a rH < I S e ttle m e n t $300 C a l. In d . A c c id . 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A E r c jfc j.g n g ... V FILED u. L center cost tAuansusas e ium is t=s nsmss stress district cccrt ran css district or tzxas bzagmckt qivzsics -~x ii re? wnut c ;//< ZSBS:/ CRACESEI. S. r3KS20Asn cDRsoRAncs, : al S s S s s *s Civil Actien Ha.. 3-30-558-0. . ORDER * On this day case an to be considered Defendant, Armstrong `arid Industries. Inc.'s Motion far Judgment Kotwishatnnd5.rg e Verdict of the jury In regard to one af Ins products (chslsscd to the jury, to wit: EE Carle Covering, and It eppearlag ta the Court that said Kotlas should be granted in. 'tat the jury's finding that IS Csrk Covering was defectively designed and defectively carketed Is against the great weight and preponderance af the evidence; it is therefore ORDERED that said defendant's Motion is granted and * the verdict of the jury csscerrlng defendant Amsorsng world * Industries, Inc.'s product LC Cork Covering is hereby set aside and held fer caught, and said defendant shall act be liable ta the plaintiff for any exposure ts plaintiff, if any, front LT Cork Covering. -** Page 3 of 3 ARMSTRONG'S INDUSTRIAL INSULATIONS ARMSTRONG CORK COMPANY LANCASTER PENNSYLVANIA tdsafe__ *S I 85-yo Magnesia Pipe Covering and Block e Armstrong Cork Company furnishes and installs the 855 Magnesia Pipe Covering and Block and other heat insulation products of the ,Keasbcy and Mattism Company in most of the 'nations leading industrial centers. 35% Magnesia insulation is Hie most widely used material in the heat insulation field for temperatures up to 600 F. This material com* bines the high insulatiag properties of basic carbonate of magnesia with the proper amount of clean asbestos fiber as a binding agent resulting in an insulation that is exceptionally light and highly efficient It consists of not less than 955 by weight of a mixture of hydrated basic carbon* ate of magnesia and long fiber asbestos. The magnesia and asbestos mixture is homogeneous and not less them 89^ of the total is hydrated basic carbonate of magnesia and not less than 10^i is asbestos fibert- Through many yean' of dependable service, 85^ Magnesia insulation has demonstrated that it is the most efficient and durable molded type heat insulation material manufactured today. In addition to its light weight and high insulating efficiency, it is absolutely fireproof and has the mechanical strength necessary to withstand alt ordinary usage to which Insulations of this type are subjected. Water has no deteriorating effect on 85^e Magnesia. It can become completely water soaked, and when dried out regains its original strength and efficiency characteristics. When properly applied and maintained, it will not crack, crumble, or fail mechanically. 857 Magnesia is manufactured in jectiooal or seg mental forms for application to pipes, and in block form for fiat surfaces. 85% Magnesia Pipe Insulation 857e Magnesia pipe insulation is manufactured in half sections and in sets of segmental blocks 3 feet long, in the following thicknesses: Standard, 1%*, 2m Double Standanl (supplied in two layers) and Three Inch Thick (supplied Hi two layers) (See table. "SS^fc Magnesia Insulation Thick nesses" on Pago I1L) Half sections of pipe insulation are split hori zontally and furnished with factory applied can vas jackets, forming hinge and lap. They are shipped with necessary brass lacquered hands for proper application. Segmental blocks for in sulation of piping are supplied without jackets. 110 Physical Characteristics of 85% Magnesia Pipe Insulation (AJI properties arc on the hone dry basis with the exception of Shipping Density) Shipping Density, Ibo/cu- ft, avenge..........13.3 plus or minus 10% Thermal Conductivity (k) BTU/hr./sq. ft/(F./ in.), average Mean Temperature 100 F....................... 0J6 Mean Temperature 300 F....................... 0,42 Modulus of Rupture, psi, average............. 50.0 Heat Tests (6 hrs. at 500 F.) % linear shrinkage, average..................... 0.2 % loss in weight average.........................RQ Minimum Thicknesses for 85% Magnesia Pipe Insulation Temperatun in decrees P. Pnaaun ia lbs. per sq. ia. ltt* and smaller Pipe Sites 2* te 4* W* and ever Hot Water and Up to 207 Ida te 337 3M toM7 MCto 499 MO to MO 0-25 25-100 101-200 Lew Superheat Superheat Standard Standard Standard V*' 2' Standard __ Standard IV4'- a* Double Standard Standard U4' 2' Double Standard a* _ When the Insulation ia to he applied on weather- exposed stir* facia or extremely lens lines, or when it is highly desirable to mini mise steam condensa tion. increase thickness at least treater then these shews ia able. Ill Heat (am Bare Pipes and Efficiencies of 55Magnesia Pipe Insulation Noiuiul I Insulation Pipe Sue, {Thickacaa, ' Temperature difference between pipe end umoundinc air. *F. SO* 100* ISO* 200* 250* 300' 3SO* 400' 410* 300* Temperature at pipe, *F. (Temperature l rurroundin* air, 7S* P.) IIS* 17J* MS* 273* MS' 37S' 41S* 47S* MS* S7S* Heat Losses per linear foot at bare pipe per hour and Efficiencies at insulatiea Std. m DbLStd. 2 3 Bare pipe loss, B.LU.. 3X0 74.0 Efficiency %.............. * %.......... " %............. - %............. - %.......... 64.14 72.10 7SJI 7744 7T.44 17941 j 7X69 11043 0X00 0344 Bara pipe loaa, B.LH... 4X7 1074 1234 103.4 2S3.7 | 337.4 | 4364 I 33X2 j 490.61 (40.2 T" 74.60 76.63 70.44 i <0.11 <1.77! <X2<> <4.SS! <3.73 74.70 <1.40 ! <2.94; <447 <3.73 ! 3646; <X02! U.94 <1.07 <2.60 ; <4.10 8349 16.44 <7.79 *8.80 ` <9.60 <2.04 <340 i <3.92 <6.16 <746 > <X47 <9.41 9044 <440 SX10 I <743 ' 3<44 ; <940,9040' 91.00! 92.60 ----------------- --------- 1---------|---------1-------- ;------------------ 1794 ! 26X4 ! 3674 | 407.0; 6314! <0341 999.7| 1223.1 Std. DbLStd. 2 3 Std. 2 DbLStd. 3 Std. 3 DbLStd. 3 Efficiency %............... - %............... " %............ " %............... ** %............... 73.lt 7343 17743 1949 6040! <2.36- <340 <3.14! <643 <7.46 7940 <1.01 <3.47 <4.14 I <3.46 <6.39; 7.73! SX73 89.69; 90.44 <0.74 <341 I 634< ; is4<! <640* <7.37 <X63! <9.63 90.461 91.1S <1.91 ! <343 i <444 i 3X14 , <749 <640 1943 90.23' 91421 91.74 <4.97 <643 i 3X44 : 3X37 <9.31 i 9046' 9I.K; 91.94! 92.62 93.17 -------- (_ Bera pipe lan, Eta.. 604 j 133.9 ! 23X9 [ 3314 43X7} 6004; 719.2; 1003.9; 114X4 1330.1 Efficiency %... r...177.14 ; 79.93 ;<0.<3 I <242 <3.62 1 14.81 <6.12! <746! 8X46 <943 % ...: 30.93 ! <3.43 ! <3.90 i <344; <6.33 ' <7.33 8X66 <9.63' 90.44! 91.lt - %%...... .:<X63 :<4.m , 1X24 ' <7.40 , 1X44 194# 9041 91.09' 9143' 92.46 163.73 i <3.10 <640 <7.30 ; 8X60 <9.30; 9049 9t.lt 9143; 93.34 10641 ! <740 11X70 <9.09 I 9045! 9141. 9243 j 92.74 9342i 9340 Bara pipe loaa, &U.. T 7X6 1161.0 ! 270.4 4004 ; 3334 7344. 9324 1213.1! 1<i3#4161a4;| 1032.4 nid 7X23 179.93 <1.04 1X17 <4.40! <3.04 1X33; <7.94 OXU 19.73 0243 i 0342 ! <3.03 1X27 j 4X40 <940 9049 91.06! 91.74 - %........... 04.71 ; 03.90 i <7.17 0049 i 09.24 90.10: 90.901 91.72! 9249' 93.90 - %........... 0441 ;U44 <743 <X43 ; <940 9040! 91.00, 9141' 92.46 9X07 - %........... 0740 0043 , <9.63 9043 9144 92.031 92.72! 9344! 9347 9443 Bara pipe loaa, BXu. 194 1974 3304 4004 0704 19X3'110X4 !l400.0! 10404'' 22334 Std. 1W 2 DbLStd. 3 --Efficiency "** %%%%............ %... 7947 ! <0.92 112.40 0340 I 1X19! <0421 <7.401 0X40 <*40j 9X19 0X14 >0442 : <342 , 0..7...04 ' 0_X__0_7. <9.02;. 19.90. 9042- 91.J4| 9240 0X09 J 0X77 <7.90 ! <940 . 1943 90.11' 91.49 9141: 9240! 9X42 3X96 <7.00 <042 ` <9.23; 9040! 9041 91.00 924S; 92.94: 9342 U49 1*941 ; 90.43 > 9147 1 91.94' 92.42 . 93.22 : 9X79 94.37': 94.33 a. 3V4 Bara pipe lam, Bxn.. 1024 2234 ! 37X9 33X1 7724;1024.0.132X4 1639.9 21014; 2373.0 Std. Efficiency 12940 >1.44 1 03.01 | <4.47 ---------1--~!1 03.60 1 0X60 ; 0744! <044;' 0099..7744!! 9044 J* DM. ML : 1:::::::: 10344 <3.15 <040 i 0743 1143 1 19.401 90441 91.13 i 91.79! *2.40 .i 64.26 <7.40 0X40 : <9.47 : 9043i 91.131 9140 9240! 9X17J 9X70 - ...... .10X74 0740 <045 I <9.70 ` 90.00 ` 9140' 9140' *3.70! 9344 9340 - %........... 19.15 <9.92 9049 , 91.66 I 92441 9243: 9343: 94.07 . 94.33; 9440 -L. _L SbX 1* DbLStd. 3 pipe iaaa, 84*. %%.. %. %%.. 11X1 2334 J 424.2 > 0274 16X1 !uS24 14944 .'190t4 ';2364.t: M9T.9 1 . 1 . l. 1--\--i--'r 0147 1241 ! <443 1543 tXN 07.07* 0047! 39.43! 90.41, 91.13 :<449 1341 00.00 <749 3X07 '<9.74 : 90.62'. 91.40- 9247. *1.7# 10X74 ; <7.03 0040 ! <944 i 9X70 I 91.45' 92.10, 9242' 93.40 *3.*l !<T4* ;<X79 <9.72 I 9X33 : 9144 ! 92.03* 91.60' 934* 93.04. 440 <944 190.41 9L10 I 9243 92.00 : *3.23 93.22 . 9444 94.79 XI0 -------- ,------- 1----------!---------!---------1-------- W Bara pip* loaa, &U.. 127.9 2214 47X9 6974 904.7 12794 .103*4 lllt.l 120274 222X1 Std. iw 2 DbLStdL J "Efficiency -- %%%%............ - %... "I------------------ 1-------<1.91 346 4.73 <3.96 <7.90 ' 1X93 <9.09 39.93* 90.Jl! ft <4.60 <547 '<7.00 M40 1 <941 19.90 ton 914#! 92.27 n 14 <742 '3X16 ;<tJ0 9X16 90.94 : 9147 9240' 9X02: 9349 9* 10 .37.94 ;<X93 *9<7 ! 90.73 91.49 9249 *2.92 1 9X43! 9X97 *4 a* ><940 90.72 ,9143 192.20 9249 9X47 ' 944* * 9445 . 94.97, *146 lit Nominal Insulation Pipe Sire. Thickness. Temperature difference between pipe end unroundin* eir. ' F. S3* 100* ISO- 200* 250* 200' JSO* 400* 4SO' J00* Temperature at pipe, *F. (Temperature at eurreundinc air. 73* F.) 123* 173* 223* 273* 123* 173* 423* 473* 323* 373* Meat I.oeeee per linear foot at bare pipe per hour end Efficiencies at insulation Std. m 2 DM. Std. 3 Bare pipe loss, &u Efficiency %, - %. -" %%.. ** %. 1434 32.04 I3J4 37.44 33.44 9043 113.1 33.44 3*41 33.43 3943 91.04 3224 733.5 1073.01 1424.0| 1344.01 2343.4! 2921.9! 3531.3 90.33^ 34441 33.121 3742 37.40 ! 33.411 3943! 39.44- 90471 91.14. 9042! 91.171 9143! 91.33! 92.75! 93.14 3341 9040; 91.901 92431 93.74 19.13$ 91.04* 92.37-, 91.151 9444i 90.10! 9140: 9340: 93.73, 94.74 92.43. 93.71 94411 91.54 93.02 9444 94.45 93.34 Bara pipe lass, B.LU.. Std. Vi 2 DbL Std. 3 Efficiency %. " %. " %. " %. - % 149.4 371.9 423.9 923.711273.1 1494.9; 2198.7! 27974] 3480.9. 4245.4 3243 83.44 37.93 33.97 90.72 33.94 1449 83.94 3943 91.45 3541! 36.50 ' 8748) 33.571 89.73! 9047, 37.74 , 33.84 ; 39.731 90.50 39.94 90.32-*9144 ! 9243j 90.74: 9144! 92.19! 92.31, 92.<-23 1 91l.8a9nl 9ik3e.47e1e! n9a4.m0a1! 91.44. 92.071 93.43| A9n414*,1 92.03: 92.99 93.93; 4 an* 91.13! 91.63 92.40. 9344 94.00$ 94.48 94.47: 94.90 A9*3.a4n0. n9o3a.7*7 Std. m 2 DM. Std. 3 Bara pipe loss. 8-t.u.. %.Efficiency %. %. %%.. 193.0 8449 33.72 3341 8942 91.03 430.4 33.43 86.93 3944 90.73 9140 720.0 1044.0 1473.6 1944.0 2539.0! 3228.0: 4006.9 49104 --I----------1--I--------- 1---------- 86.72! 37.30 38.73' 899..161* 90.46) 91.12! 91.91. 92.52 83.07 89.10 ' 89.96< 90.77. 91.53* 9246j 9249: 93.43 9041: 91.04' 91.761 92.44* 93.07! 9347i 94.131 94.63 91431 9240 9242| 93.47 *4.04! 944S| 94.97 9346 9243! 93.17 93.751 9444! 94.74! 93.19, 934* 93.92 Std. *V4 2 DM. Std. 3 Bora pipe loss, B.Un. Efficiency %. - m %%.. - %. " % Bara pipe loco, Ets.. 220.6 84J3 3848 8844 9040 9143 433.7 3124 1203.0 16644! 220741 2363.6 3642.81 45204. 35324 ----- 1---------- 83.60 3343' 8748 8347' 3943 , 90.45 ! 9140 ! 91.78' 92.04 1 92.73 j 37.94! 88491 39J8; 9041 9148; 92.00 92.49j 93.101 9343 9343] 39.74' 90491 9I46i 9243. 92.63 91.00= 91.78! 92.47* 93.0* 93.65 92.631 9343: 93441 9443- 94.78 9347, 94.21; 94.70' 93.121 9340 94.42) 94.91 9345 93.721 9647 243.0 3424 907.0 13434'18304! 24354 32004; 40704! 30S441 6193.7 Std. >V4 3 DM. Std. 3 %.%.Efficiency %. " m %.- " %. 34.81 33.73 91.44 9144 3343 87.43 39.63 9142 9346 87.03 1 88.13 3343! 89.47 90.33 ! 91.43 9241, 93.71 92.94 ! 9347 1947 3941. 90.74) 91.49) 92.17*. 92.77 9043 91.13! 91.83* 9243) 93.121 93.63 92.131 9244* 9347! 9343' 94.43* 9447 9349 93431 9443! 9443! 9343! 93.60 94.11 9449,j 939.30.30]3, 93.49' 93.34, 93.17 19 Bara pipe lata. Eta. 373.4 603.2 1014.1 13014 20774! 2773.6:3374.1 J 4346.6; 56334*. 69294 Std. Efficiency 34.73 83.93 1 87.13 ! 33.211 39.14 M.Otl T 9i4*r 90.33' 9243- 92.34 3 DbL Std. 3 ** - ** %.. - 8340 8347 9043 9L72 8747 33.73; 89.60 ' 9041 8947 j 90.771 91.33 9349 9141 | 92.17 9244, 93.44 92.33 93.10 ! 93.711 *444 *i4r 72.00! 92.70' 9)43- 93.79 9249) 9342*. 9447*. 9443: 93.00 93.97, 94.49; 94.93! 9347; 93.73 94.721 93.18. 9144J 9343! 9348 12 DbL St* 2234 7194 12034 !l 7804 24334 32884 42334 33934 8700.9* 32114 *. sl 9247! 9244! 8743! 33.93 ! 3944 93.70) 91.43) 9247] 9244! 93.43'. 93.94 %. 3944 99.10 ; 91.00 '. 9141 92.47 ! 9349) 93.701 94.24: 94.69* 93.11 %. 9143 9249 ; 93.289343 94431 94.<7i *341,' *3.711 *3.04] *344 -----------r--------7 14 r pipe lata. Eta. 3774 7134 {131*0 {1*30412700.0{33304' 4343.0! 3*034 73334 Ml 1.1 StdL 2 DM. Std. 11 M.Ol! M4a! 914s! 9248! 92.93 %. tt-tt \ IMS 93.48. 94.01 %. 1943 M.19'91.40 . 91.90 . 9243: 93.13' *3.77 9443 94.79! 93.20 %. 9141 I 93.431 9349 i 94.49 i 94.93; 9343 9349*. 94.141 *6.47 -} 1 ' 1 18 pipe lata, EU.. 4034 Ml.0 13104 '22374 '3093.0>41004!SJ204 67334A1!o*4li0l9744 10102 M.to! 90.91! 91.63, *2411 93.0o| *347{ 94.08 It::rStd. EflUioacv %. 3747 13.13 19.13 3 ** %. 3944 90.41 91.67 :' 92..0000, 92.74 `' 9144' 9341) `94.4'4' 9..*....9...2..i....9...1..4...3. DbL Std. " %. 92.24 9249 9343 * 94.13 1 *4.61, *3.09j 9343] 9340| 9341; 93.34 113 Nominal Pipe Sim Inch-- Packaging Data--35% Magnesia Pipe Insulation Carton Contents Nominal Waitfu Par Saetiam r---------C--a--r-t-o--n-----.---- Nominal . Nat Waiht ! j Pat Carton No. Par Cartoa Lba. Lba. Nominal Grom Wright Par Cartaa Lba. Table X.--Standard Thick W y* i 1J* IJI 1.70 w* 2J>7 IV* 2.21 X Ut m 3J4 3 4J3 iW 4.64 4 3.09 W 4.19 3 4.73 7J7 7 10.07 > 11.04 12J2 10 13.43 44' 43 44 33 34 14 13 IS 9 4 4 4 4 4 3 3. 3 A ftWIV 4H-I 7J Aim W *i t 3.14 LM 3J4 31 . 14 14 m . 4J4 m 4J4 3 3.34 It IS 13 JW U1 9 3 4.73 4 3W 7J4 4 4 4JH 7. 4.70 4 3 3.43 4 4 10J4 4 7 I1J4 4 < 13J9 3 1104 10 :ui Table 3.-2 Inch TTiti-lr . W ut H U4 l SJ4 3 3 .. ' 10 to* 13 m 444 iw 4J7 * f 7JS ' 0 0 0 XW L- 4.71 3 ^ Ul >H 10J0 7 0 4 4 1U7 4 13.43 4 s 13.44 4. 13.41 4 T 17.17 3 S 14J3 3 9 20J4 10 . 1341 3 3 334 124 130 130 134 no 120 230 120 120 230 120 203 239 240 230 120 234 . 234 120 120 120 120 120 120 130 234 130 303 230 240 240 330 237 240 240 120 240 120 120 120 237 120 103 303 230 200 244 334 237 234 47 71 71 44 43 34 S3 43 42 44 SO 41 33 40 . 22 23 27 73 71 71 rt 44 44 41 70 44 32 57 47 34 47 27 31 11 47 71 43 ' 49 49 73 49 73 49 73 43 49 S3 39 34 40 39 45 34 43 S3 34 34 44 44 31 49 37 27 32 34 34 33 39 31 33 73 S3 43 41 41 39 44 44 34 34 43 14 34 . 42 43 5 34 40 74 34 99 49 47 43 74 32 34 1 70 19 44 44 31 114 I Nominal Pipe Sira tnckoa | Nominal Wbt* *5^ Stctiont Par Carton Table 4.--Double Standard Thick *4 SJ2 a 3.10 i 140 1*4 132 1V4 7.14 1 ITS m 9.14 3 10.70 m 13M 4 13.03 s *4 17.03 1103 lf.lt T 32.03 S 3440 It It 9 9 9 t 7 0 4 4 4 4 3 3 3 Carton No, 3S4 330 330 3SO 130 130 139 130 330 330 ' 303 303 34* 330 337 - Nominal NotWaisht Par Carton Lba. 03 03 30 34 04 70 oa 44 33 33 oa 04 30 43 30 Nominal Grata Weight Par Carton Lba. 09 oa 04 43 70 74 74 70 03 39 74 70 43 31 30 Carton No, 340 330 337 130 33S 303 330 300 Key Table to Carton Sizes Isolde Dunanaiocu lactam Outaido Dimcnaieoa loctioa ' Ilf* *33tf 39 U x30 Jtl0 14 x 30 a 34 14*4 s 37*4*30 13 X 30*4 *30 It ill >30 3044x30*4*30 33 x33 *30 J2'/ *34*4x10*4 13*4* 30*4 B 30*4 14*4 < 30*4 * 30*4 IS *37*4*30*4 13*4 <31 *30*4 10*4 <ts*4*30*4 3114*31*4*30*4 33*4 * 33*4 * 30*4 Tara WL Lba. 3 0 0 0 7 0 7 85% Magnesia Blocks and Lagging 85% Magnesia Blocks and Lagging are light, efficient insulating materials for flat, curved, and irregular surfaces such as boilers, breecnings, 63T Hilts, tanks, and other heated equipment; where the temperature does not exceed 600* F. Where temperatures are in excess of 600* F., 85% Mag* nesia should be used in combination with HyTemp Blocks, 85% Magnesia Bocks are furnished in stand* aid 38* lengths7 hi 3*. 8*. 9*. a> ! IT widths. Thicknesses range from 1* to 4* inclusive. Thermal Conductivity (k) BTU/hr./sq. ft/(F./ in.), average Mean Temperature 100* F...................... 0.38 Mean Temperature 300* F...................... 0.42 Modulus of Rupture, psi., average............. 50.0 Heat Tests--8 hr*, at 500* F. . % linear shrinkage, average................... 01 % loss in weight average.......................14.0 Recommended Minimum Thicknesses Temperature *7. 03% Itncaaaia Btocka Physical Characteristics of 85% Magnesia Blocks and Lagging (All properties are on the bone dry basis with exception of shipping density) Shipping Density, Iba/cu. ft, average.......... 112 plus or minus 10% Hot Water 312* to 204* 107* ta 337* 334* ta 3X7* 300* te 490* 300* ta 000* 1* V4* 2* 3V*P JV4* NOTK: Ne tfcicfcmw leceeuncadariM cm PP<r to all caaditiaat. Tfcma rrcemmtndatiatn Have been found ta he aatiafactary a<d Noaaarioi lot am caaei, 115 Iloot Losses and Efficiencies of 85% Mugnoia Blocks and Laggng ~------- :---- ^ 1' a 1* a 34' 1*4* a 1* a 30' Ui'il'all* IVi' il'iM* l'l*M* 114'iTair 214* a 3' a J' 1* al* a 30" IM'al'ill* 4* a J* a 34" | Packaging Information--85% Magnesia Blocks Wd}>t par Blade. Iba. Carat or Crata No. Blades par j Carta* or Crata 0.74 OJS 1.14 Ull ut 1.72 1.S1 iM 147 3.04 114 114 114 114 114 114 114 114 114 72 . SO 40 42 34 22 20 24 10 Greta Wt par Carton or Grata 60 60 60 41 60 40 42 60 64 1'tl'aM* jy/il'iM* 114' *4* a 14* 144* a 4' a 14* 2* a 4* a 14" 2V4* a 4* a 14* 1*4* a 4* a 14" I'a4'a30* IH'al'aM!^ : 4*a4'alO* > m u> 147 IK 141 MS 4JI us 4J4 . 114 114 114 114 114 > 114 114 114 lie-- 114 so 20 24 21 IS to IS 12 20 0 40 40 40 41 <0 60 42 60 174 40 l'aM'aSO* 1 m'aii'aier 1H* 12'a 14" 144'a 11'a 14* 2' a 12' a 14* 2Vi" a 12' a 14* 214' a 11' a 14* 1' a 12' a 14' 114* * >2' 34* 4' a 12* a 14* 144 . SJI 447 142 444 4J4 7.02 4.14 1047 1244 114 114 114 114 114 114 - 114 114 <nm era. 10 40 14 SO 12 40 10 SO 0 40 0 40 7 SO 0 40 14 174 12 : * 171 Crata-LO. 24' a 24ft' a 34tt*--Tare Waifht 21 Iba. Cartaa No. 114--LX). 12ft* a lVt' a 14*--OJ). U* a 1*H` a 14V**--Tar* WaigM 2 lb*. 11 ' -JEsI?? Hy-Temp Pipe Covering and Block Hy-temp insulation is recommended for heated line* and surfaces where temperatures range from above 600 F. to 1900 F. This material is made from calcined diatomaceou* earth, asbestos fiber, magnesia carbonate, and binders. Hy-temp insulation is generally used as an in ner layer in combination with an outer layer of 85% Magnesia. The inner layer of Hy-Temp is used in a thickness sufficient to reduce the tem perature at the 85% Magnesia to within safe limits for that product Because hy-temp insula tion will withstand higher temperatures than 85% Magnesia, but is not so efficient an insulator as 85% Magnesia, a combination of the two ma terials utilizes (ft* high heat resistance of the high temperatuarinsulation and the greater effi ciency of 85% Magnesia to best advantage. Hytemp insulation possesses sufficient strength so that it can be handled without breakage. Physical Characteristics of Hy-Temp Pipe and Block Insulation (All properties on bone dry basis with exception of shipping density) Shipping Density, lbs./cu. ft, average.... 23.6 plus or minus 10% Thermal Conductivity (k). BTU/hr./sq. ft/(F./in.) average Mean Temperature 550 F....................... 0.72 Mean Temperature 800 F....................... 0.80 Modulus of Rupture, psi, avenge....................70 Heat Tests (6 hours at 1500 F.) % linear shrinkage...................................... 1.0 % loss in weight........................................ 9.0 Hy-Temp Pipe Insulation Hy-Temp Pipe Insulation is furnished in tubu lar half sections and sets of curved segmental blocks 3 ft in length and in thicknesses from 1" to 3". Half sections are furnished for pipe sizes of 10" and smaller. Insulation for pipe sizes larger than 10" in single layer or inner layer only of double standard thick or 3" thick broken joint construction is furnished in segments. The 12" size can be furnished iu sectional covering l?i' and thick on specific order. In most applications Ily-Temp Pipe Insulation Is wired on as an inner layer, in combination with an outer layer of 85% Magnesia. It is furnished without canvas jacket and 1Kinds. 117 lU'commcnded Minimum Thicknesses of Combination Hy-Temp and 85% Magnesia Pipe Insulation--Indoor Piping Temperature Nominal Pipe Sixes, l.'i fc smaller 2 s 3 3K 4 4H S b larger W--499* P. Hy-Temp IK IK . IK IK IK IK IK IK IK IK IK IK IK IK 700*-- 799* P. *00*--1000* P. Tbicknno of Insulation--Inches | Hy-Temp -Z* | Hy-Temp ACM* Single layer only of Hy-Temp, 2* thick IK 2 IK IK * 2 2 IK 2 IK 2 IK 2 IK 2 IK IK IK IK IK IK 2 IK IK iK IK iK 2 2 All insulation on pipes I'A' and smaller shall be single layer aI Hy-Temp Pipe Insulation. Where insulation is to be applied an weather-exposed surface* or extremely long lines, or where it it desirable to mini mise lost of superheat, inertsac thickness at least Vi* creatsr then those shown in tabic. Heat Losses from Bare Pipes and Efficiencies of Hy-Temp Combination Pipe Insulation (Hy-Temp tnsuletion with "Peetherwcight** U% Magnesia aa outer layer) MttMsel 2Z TUcfc. K/m*Ttmmi fmmU lathes .Plat Site fun M.satis, iashss Thicka4U% Oar TThsissX*. afCeSn. [ente ' ' t are pips Itet, hu s <<aaaa osaattasrr llaappsser)) ISX Matteay % Mrimiy* Ht an pips lam. a.sua 3x f(aaee swawaasrr llaayirewr)) lIX Mateaay% 1 Pare stye tees, hu. sx ((aaan asaettatrr llaayyawr)) IIX 'Mrfaaqr % IX e ate pine laea. Eta, >s X ((aasaumsetrllaayratrr)) I1X > MdnarS lit neats * IX e # erv pipe teats 8.1^ i>X gasafer leywj * 1>x A Vrima % I e e an pine leas. Ota. IX iid X 2 !( *K at Mrinry % IX IS IS S S e e an ftps laaa. .tab l<X tiKS BMdaef a SMaMV % s mylyilanhUb IS IS I. . 1>x IJSS MWanty g T--yarimn OUTaraace hetesaa ny* aa4 U< Teemuyr!rrrteur'taiSralaej faPiri,pIDel.la*Oe. n9.. 9. TM* see* see* roe* ter (Samandine air taayuaisw H* F.) Kan* Inaas yer tiaaar Seat a( hen pint yar hear aee glirlaneiae tTietaledn ' ma tUi.-eMs HU stae uao tsra teas srae uua ii.n Mt e?j tut MJI rata tut tue toua tI9i.jMi MU t9eUaS* UU MS4.JFSI ma 47.9# taa* ueea su> eat irsaa wfU.M ISU SC.IS *131 SI 7th* NuaJe4 tim IUtaxI maa 9C.M fleU MU mas tea# uaaa SS.M aaa : isaaa eae tat IUU fl.44 M.M una StUaMr isaaa n.ye tsaa uaaa Mas MJX ausa e.ii IS.M utu tus 0X1 mra aiae so.im 1MU aa* ear ]MU ilm IMJ 1UU sue u.n MIU M*4,JXI MU 1 Mat 1 Mas 447U till II.M lit I Heat Losses from Bare Pipes and Efficiencies of Hy-Temp Combination Pipe Insulation (con't) (Hf-Tamp Insulation with "Fcathotwcicht" 11% Mscoaii as outer layer) JfmtoMI MSnioamss.* Thfek* hI/l.ohtochttaioSI,bom yj? HMgJa. Tkfafe. afU% Mas- TTksfeati. ahttTiaacaSlbsaaa- Tifrinnifii*mDiMilflcMrmi c*i,bDtlmw,wf. pip* ad H4MomoOt**OwhlfTotMBp#f*rrfm4lfiH4ou0cp**mw#r(otmofmmRiowfM7vfo9t,4otur0*rr*o<p.7*Fp3*.* m* pFm.)MtOo*ur toO IWciiito of luiw SH 4 S T t M 11 14 is is M la M h; a4 IH IHKa 7 7 IH Ha 7 1 IH s . 1 4 IH t 3 IH IS IH u t 4 i IK IS i S% 1% 14 s a IH is s a tH IT s a IM M S e**-. IH -: * It t a i a IH a s aa tH IT s a tH IS t Sara fie* ka. 0.1.a. It flT Tflrlncr % taau HU.MM SS3SB 944JJOO msib M3.B0S3 U4SB 9994..4043 Bata Mo* loaa. eta. HMat KMdaanr g tins MMJSl 41UJ 94.70 M.1S 4441J 9933.4447 OOtOJ 9934.-9U4 Bata piss lao. eta. U4SJ 3334-9 444IB 0477J Ha ESkiaacy % *' hjs . 93.39 MBS MBl Boro 9*90 ton. E.La NIU HIU . SUTB 741IB 1H EflUaacy %* >4.74 3J4 MI4 94J7 Oars pipe laaa. Sta 3134.4 4MU SMSB 4443-4 TH BSMaaay % MBS M.79 904 MTS Im 919* Ink Lit. M04.0 U97J 79*34 10104J SH (Mart MBS MM MBS in a Bata pipe teas. B.ta. 4ST1B sissb ISSTB IUU.0 *H MMue* a Bara ptpa laaa eta. >ua 4S4TJ MM saspB pass MSIB MM I7U4B SH UdoMrft a 3m |^| iMBa ubs MU raiTB MT1 1STUB 747 14M4B SH Moot MTS MBT MB4 MBS a Sara ptpa laa. Baa. MIU mu tSTSSB | tiassB SH SMaonr* MBS M44 MM 97.34 Bata ptpa tea. eta. ooflco Mats 1SMTB 1S444J SH IMH> % a Bara pipt laaa. eta. MBS 7USJ MSI 1ISS4B MST UM1B MBS 3U4M SH TSidiar % MM MS# VTB1 TBS a Bata ptpa laaa. B.ta. tSS4B I1T4IB I71SB 34441.9 SH BBWaoay % MB4 MBS ST.M 97.43 a * Bara ptpa laa. eta. 444TB I4IMJ | tsaisB SM1SB SH BBWaoay % SSBi MTS | MBS TT.4S 1- a aw ikm Im* B>ti I1SSBB tasstB SSMBB ! 3303U SH BBWaaay % MIS MTB . M.TS j 47BS a Bata plea laaa. eta. 141 TIB It1MB 7944U 't 44479.4 SH laaao % | MSS Mas MBT Mja 119 I Hy-Tcmp Combination Pipe Covering TmimiWW to 100* T. Hy-Temp Approximately thick inner layer OUTER LAYER Hy-Tcmp (3Mocosm} Nominal Pipe Sires laches Appm. Thickness Inches Nominsl Pips Saw Inchss Hy-Temp Combination Pipe Covering Temperature* <00' to 1000* F. Hy-Tcmp Approximately 1* thick -- ' INNER LAYER OUTER LAYER Hy-Tcmp (Sift Macros) Nominal Pipe Sires Inches Appro*. Thickness Inches Nominal Pips Sires Inches X X i iH m 9 *x 3 iH 4 *H s 6 7 S 9 to n u *14 ojL IS out. MS 04. MOo-d. *34 ad. *30 oui. IX iH 154 154 IX 154 154 IX IX IX >x ix tx IX x x , IX IX ix IX IX IX x ix tX 3 3X 4 4 4X 4X S s s 7 .7 S 9 10 Mi Ml M4 Mi MS M7 M* 91 MS *97 33 .X x 1 IX IX 9 3X 3 3X 4 X s s 7 1 9 10 u M9 *14 od. MSOyd. *10 Odd. 2. IX 2- IX JX 2 IX 2 . x 2 2 2- 2X 2 2 9X JX 2 >X 2 2 3. H 4.X s s s 0 0 7 7 t 0 9 10 Mi M9 M4 MS *10 M7 IS M0 M3 **y-Tmp nd Msfnena for pipe uo Imm than 10* is farnUhcd in Sag--ntol blocks. Number and Sizes of Segments of 85% Magnesia and Hy-Tetnp Segmental Pipe Insulation SlpsSUs lochs* 1-- IM*lMdh A. MV Imss r fV as 41 *ST i S'TMSh - Siataf sr 1** nip : o las s U4 las i us 14* 1ST 0 us sen US s Ml IP 1S .9 us a on t US a US 10* to* MIlUl 14) a IAS IT* ir to UllUl to UftlM 10* ir 10 S.T9s40t 10 SJiiut ir tr It lUlUt tt UllUl is* IS* 11 s.ns4t 11 LISaLM n* it* It U4S0J2 12 U4 1 US tr II* 12 ussua u us* sac *i* u* U UlaUl u US a US 24* 14* U UlsUt u UllUS IS IT 14 LMsUl 14 UTs4.1T IS* IS* IS USaUl IS sjosen JO* J4* ts UlsUI 10 Ul s US OeehlsOM.se JTMskWI Merkel T ....... < Ut Cceres Sssaf lepneoe Cams tad Coens SaaM a sasshjs T uissas a usiin to UllUl ' * t UllUl 10 UllUl 9 UllUl tt usssja to UlaUl 11 LTV s S.SS to LNsLOS u UllUS IS UllUl IS lu i sat 11 us staa IS UlsUI ta UllUl u S47 i Uf is ua s ua 14 s.u Ui is sjasus 14 III s US u UllUh * 14 UllUS 14 ITS a US IS LIT s Lit IS ITS a 4-M M Lit s LIS 10 Lit s Ul to Ills sue ISO I Packaging Data--Hy-Temp and Combination Pipe Insulation (Cota Ho. Tl U uh4 unlearn otherwiae noted) Sections per crate--Jacketed Hy-Temp Pipe Insulation Thtchncta of Xoaulfttiaa tH'Thick r Thick Nominal Ffpe Sues H u 1 IK Ut 2 3 3U 4 U S S 7 S 9 10 so 44 3* M IS 24 20 IS 14 14 tl 9 4-770 6-770 6-772 4-773 u 32 2t 34 24 20 IS 14 14 11 11 9 6-770 6 6-773 4-773 S-7201 Sections per crate--Hy-Temp Combination Pipe Insulation Outer Layer Standard IK' 3* DbLStd. DhLlH' 3 3H 4 S . 4 7 S 9 10 2S 24 19 IS 14 11 7 4-770 4 10-772 20 10 14 14 11 9 4-770 4-770 4-772 6-773 14 14 11 11 9 4-770 4 4-772 4-773 S-7201 14 11 11 7 7 4-770 4-772 4-773 x X 9 0 4-770 4-770 6 4-7T2 4-773 X X X Sections per crate--Hy-Temp Inner Layer of Combination Pipe Insulation (When Outer Layer Is Segmental Block) . Thictaif of Inner Layer IK* V S 13 f' Namkill PSpa She of HV-TIMP Inner Layer 7 S9 9 S 10-772 S 10-772 10-772 10 10-772 10-772 Oats No- - 300 . 201 70 71 72 73 Key to Crate Dimensions Xarid^DImmiaaa Outairfji OtmwMiiw 34Ka36 a M) 37 a 3S*i a MU 34.U a 23 s M.U 37 a 23 a MU 41 a 37 a MU 42 a 20 a MU 37 U a 33 a 37 U 40 a MU a 37 U 37K a 24 a 37.U 40 a 20 a 37J* 44 a 3S a 37U . 4S a 29 a37jf 121 Tare WeichtOha.) SS 60 40 4S S3 40 I Hy-Temp Mock Insulation 1 ly-Teinp Blocks art* furnished in standard widths of 3", 6", 9", and 12" and in 30" lengths Hat. Thicknesses range from 1" to 4". Curved blocks an* furnished in standard 6" widths and 30" lengths. Thicknesses range from i'/a" to 2". I Iy-Temp Blocks are usually used in combina tion with an outer layer of S5^1 Magnesia Blocks. Hie Hy-Temp Blocks are applied as an inner layer to bring the temperature at the magnesia down to the limits of that product This main strain header, carrying supcrhntal steam at 400 pounds pressure (mm the Imiler in the background tit tlie power plant turbine, U insulated with l'** thick Hy-Temp Covering and a similar tlikkncs* el 85% Mag nesia Covering. My-Tcinp Block b used under the steel shell to reduce heat losses titmugh the boiler wails. Recommended Minimum Thickness of Combination Hy-Temp and 85^1 Magnesia Block Insulation . Maximum Temperature on Ky-Temp Thickness at Hy-Temp I&dbfS Thichneae of Magnesia Inches Total Thickness IqcIms TSd 900 1000 1200 IV* 2 3V* ' V* 1 2 v* When msoladoa is to be applied ee weathcr-eaposcd surfaces, inertaas thichwcsaai at leastgreeter than those shown in table. 4 v* s s Empty carton weigh* I Ran Approsimate graae weighs--U lbs. for Hy-Temp Blache Outside dimensions of carton 13* e IJ"te* z 17*. Hy-Temp Carton Contents Seek* Inches Thichneae in Tnrhsa T1.,1 i ii 1 I U< 4 2 34 4 1 s Id Blochs par Carton............. 40 Id 32 2 24 2d 20 10 It Sq. Ft. par Carton............. 3d 1*H 24 21 id IS 15 12 ltd Blocks per Carton............. 24 I* Id 14 12 id 10 Sq. ft. per Carton............. Id 4 24 21 It i l> IS 12 12 aid Blocks par Carton............. 13 Sq. Ft. par Carton............. 27 K 7 * 1 15 1 *24 21 it 14 IS 12 1 Bestfelt Pipe Covering and Block - n Destfclt Insulation is made in pipe covering and block form of built-up layers of crimped as bestos paper. There are approximately 33 layers of paper per inch of insulation thickness. The ma terial is suitable for use on heated pipes and sur faces where temperatures do not exceed 700 F. K is often specified in place of 83% Magnesia for applications where the insulation is subjected to excessive conditions of vibration or where it must be removed and replaced frequently. For example, removable flange covers made of Bestfelt have the high strength necessary to resist damage that occurs to many insulations when the covers are removed and replaced. For thermal conductivity of Bestfelt Insula tion, see curve on Page 128. Bestfelt Pipe Insulation Bestfelt Pipe Covering is supplied in threefoot sections with canvas jackets and brass lac quered bands for application. It is available for pipe sizes from to 24**. Standard Thickness approximates 1". Thick nesses of l", 1V4*! 2". and 2K" are furnished in single layer construction. A 3* thickness is supplied with broken joint construction in two equal thicknesses. Recommended Minimum Thickness of Bestfelt Pipe Insulation--Indoor Conditions Steam Pressure . or conditio* . Hoc Water 0- 13 Ibo. as-ioo ib*. . 100-iOO Ibo. Ua Superheat Superheat Hi(h Superheat i Temp * --. m to im 267 to 337 331 to 3S7 3SS to 4*t 306 to St* 600 to 700 Up to IV's* I' r li' m* 2* 2* Pipe Sires 2* to 4' 1' l* iVT 2' m* 3* 4V4" and ever 1* 1' 2* m* ' i* 3' m Heat Losses from Bare Pipes and Efficiencies of Bcstfdt Insulation Nominal Pipe Sue, inches H X Inaulartm `hj-jinMa mrhae 1 K 3 *4 3 1 3 *K 3 Temperature of pipe--dex. Fahr. 123 17S US 27S US S7S 422 47S sas S7S glttciency 9 % ** m 9m * SO 100 ISO 71.46 73.91 7640 1 7647 8043 7X21 76.11 73.70 77.80 7X43 0.10 0.10 1.80 147 83*10 Y~ - 74.00 7X70 76.70 7X13 79.30 ! 80.83 ! 81.12 1 12.40 82.62 83.12 77.61 7942 8247 13.80 <3.14 200 7741 7940 81.80 83.10 84.41 79.30 8143 83.62 83.07 8640 230 79.00 80.7! 3.00 <447 340 80.70 2.72 4.80 86.13 7.17 300 1 an3Od3C0Aair--I d4ae0Mx0. FIah4ar3.a 0 8047 3.17 84.10 8343 8X60 1.90 83.40 3.40 8647 7.33 2.9< 84.69 8X41 >7.60 8X31 447 340 7.30 8X31 $9.47 81.00 83.97 83.90 7.12 8X10 347 3.10 (7.00 88.13 9.00 4.79 8640 7.93 9.13 943 3.93 7.21 9.00 9.91 9042 300 6X76 6.91 8X60 941 9.99 641 8.11 89.61 90.63 9142 m i 1 IK 3 J.4 3 1 Hi 3 m 3 9 9 9 9 9 77.23 7X12 80.00 81.27 83.37 i 83.90 440 3.41 0.30 2.73 4.99 8X32 63.00 83.99 6X17 87.31 83.09 13.13 87.12 86.42 8440 86.13 8X03 8941 8341 741 86.96 90.02 8X67 8X23 8942 9042 7.30 88.99 9043 91.43 8849 941 9142 91.03 * * !t 83.70 $6.79 17.89 8X62 - 89.43 90.12 90.90 91.61 9343 91.67 * 41 i 7X80 0.22 81.73 63.03 8442 . 342 8X43 6742 <841 89.11 1.31 ; <241 84.03 83.23 649 87.19 <6.13 69.03 9.79 90.31 9 9 4.02 : *3.13 8X33 87.31 8X20 | 89.03 <9.90 90.70 9141 91.93 3.73 I X7I 87.80 6X70 <9.30 9042 9047 91.66 92.33 92.7* <6.99 j <744 8X83 9.69 90.42 91.08 91.77 9347 93.91 93.40 3 3M 4 K t iK 2 7.4" 3 1 IK 2 7K 3 1 K 2 7K 3 _ 1 iK 2 7K 3 1 u* fc. 9 9 f9.90 ! 1143 X7I 63.97 3.06 80.10 ! <7.13 8X11 8X96 <9.71 * i 82.43 I 63.83 3.03 8X14 87.12 8X00 : 8X91 89.77 90.47 91.13 ; 83.10 i 8X16 740 SX17 69.01 9.78 9043 9140 91.86 9240 * 8X76 7.69 8.67 9.34 9048 90.99 i 9149 9X33 96.90 9X41 j 8744 1640 19.70 9X46 91.17 91.77 91.40 93.00 9340 93.95 .. " " ! 80.97 244 6X80 8440 3.90 86.83 87.90 sxso <9.60 9040 * 4.63 ! 8X09 ! 17.03 <3.13 8X03 647 6X93 S7.SQ 19.66 8X66 90.42 940 91.14 9041 9143 91.00 9149 9141 9242 ` ; 87.79 <XS9 1 <940 9047 90.93 9149 9242 9344 9X33 9340 - ' ! 81.90 <9.67 9X43 91.16 | 91.79 9349 1 9X96 9340 9343 9447 ---- 8143 8249 4.16 6344 SX26 17.20 8X13 943 <9.60 9040 * * I 84.17 <343 8X37 747 6.26 <9.07 947 9047 9140 91.90 * 1 8X33 743 8X47 8946 90.13 9043 9143 93.13 93.72 9342 ` * i8642 9.11 89.93 90.66 9143 9143 9X33 9X13 9X61 94.04 9.34 90.23 * 91.02 | 91.69 9X26 92.83 9343 i mi 9446 94.66 ----------- 1-----------1----------- -- m 9 9 9 m 3.07 0.17 S4.S3 > 15.63 0.63 ! 7.S7 ' 86.50 I 1949 90.11 90.77 4.63 SS.S7 i 0.73 i S7.73 i 0.57 ! $949 . 90.19 > 90.93 9147 92.16 7.10 7.9* i 0.90 | 89.74 ; 90.47 , 9i.i3 : 9141 : 92.45 92.97 93.47 , <*:9 m U.73 w.sa 9042 | 91.07 ; 91.69 . 91.27 9146 93.41 9347 9440 9.91 9049 9U1 91.96 i Mil 9347 9446 94.30 9446 9 0 0 341 U.S4 , 14.70 543 ! 7.77 | 6647 I <941 9047 90.93 3.10 0.10 ! 87.13 0.09 ! 091 i *9.66 ! 90.45 < 91.16 I 91.76 9346 m m 7.47 ' 0.19 ; 90.00 i 90.71 9146 j 92.02 92.67 93.20 9X67 0 89 9.04 <941 ! 90.61 I 9143 I 9143 91.30 i 93.06 ! 9341 | 94.06 94.47 90.23 90.9S i 91.61 ! 9146 I 9141 9341 i 93.79 9440'9447 95.02 1 0 2.73 63.91 f IS.11 641 <7.16 1 0.07 ! <647 <944 I 9043 91.19 * 0 9 6347 643 j 6747 0.37 9.11 89.0 : 9043 ! 9147 91.97 9243 32 0 741 643 I 19.54 9041 90.99 : 91.64 ! 9346 9347 9347 9343 JK 0 9.41 90.13 90.90 9149 93.lt i 93.76 j 9347 1 9341 ; 9443 94.63 3 0 9043 9141 9147 9340 93.01 j 9340 94.03 j 9440 94.16 9S.21 1 0 0 34S 447 <343 743 U49 ! <9.39 90.10 i 90.77 91.46 IK 177 6.79 7.77 0.67 I 9.50 90.31 ' 90.93 91.64 ! 9341 92.73 63 <644 9.11 9.93 9041 ; 9146 91.97 ! 92.60 . 9X16 i 93.63 94.10 7K * ` i (947 | 9049 9143 9X00 i 93.34 93.09 ; 9340 94.19 ! 94.31 9446 3 ` j 91.00 I 91.63 9341 9247 9349 9346 . 94.41 94.76 j 9X10 9X43 J______ Nominal Pip* Sics. iadMa 7 9 10 12 14 14 14 Insulation thickness. inches 1 `K t K 3 1 IK } K 3 1 IK 3 JK -3 1 iK 3 K 3 IK 3 *K 3 IK 3 JK 3 *K 3 3V* IK 3 *K 3 Efficiency % aa a aa aa aa Temperature of pipe--dec. Fehr. in 173 333 273 323 37S 423 473 323 373 Ternperature di/Tersne* between pipe and air--dec. Fehr. 10 100` ISO | 200 | ISO 300 3SO | 400 430 j 300 IMO 0643 SS.S3 9044 9147 4.63 7.17 <9.43 90.93 91.90 <3.71 00.03 07.73 113 i 0199 i 09.77 90.33 i 91.00 I 91.03 9143 1 9347 | 9341 9340 ! 9113 j 93.03 160 9.72 | 90.24 9041 91.20 j 9147 93.23 92.83 : 93J 9342 1 9343 i 9442 94.09 94.33 J 94.93 90.93 1 91.33 93.44 i 93.90 93.80 94.27 94.71 93.00 9341 93.03 033 0.47 M4I 90.10 9147 S4.01 1643 9.11 90.09 91.77 4.99 17.40 947 91.1S 9340 113 7.33 943 9140 9347 till j 17.13 1 8103 i U.S7 <9.60 ! 90.30 91.11 i 91.72 1137 : 19.33 i 8947 9047 9147 ! 92.03 9247 I 93.10 90.43 ; 91.17 | 9141 93.41 1 93.97 1 9342 l 93.97 . 9447 9143 1 93.40 j 93.99 9341 1 93.99 ! 94.47 94.03 9341 93.77 j 93J7 i 93JU 94.27 94.67 | 9110 9143,95.73 133 I 07.33 I 1110 149 | 943 1 90.09 90.66 , 9143 : 91.93 93.04 : 92.63 | 93.10 93.93 j 9341 j 93.97 00.93 ! 89.73 ! 9042 91.10 i 91.70 90.78 ! 91.46 1 92.13 92.69 : 93.19 9242 93.09 : 9341 : 94.03 ' 94.30 9347 94.13 94.38 94.93 1 9340 9449 9443 1 9342 9343 ; 9347 103 0.93 *941 9049 91.96 7.11 943 91.17 9143 3.99 741 9043 91.33 9343 749 9047 91.77 93.79 07.03 0112 ' S9.03 947 9043 ! 91.07 9103 1 9171 0173 i *943 9040,90.99 1 91.64 9340 92.03 ' 9345 9043 : 91.31 - 93.11 93.69 93.21 1 93.77 9440 94.61 93.30 .' 9340 ; 9340 93.77 94.23 : 94.72 I 93.07 93.41 93.17! 93.70 ; 94.13 9447 | 94.99 ; 9347 95.60 : 93.99 0191 1 09.74 i 9040 91.04 > 91.70 9341 9349 ' 93.97 i 93.31 ---------- ,---------91.15 i 91.70 i 93.43 93.90 , 93.43 9346 ! 9349'9191 9443 1 94.72 9195 94.41 : 9446 9133 i 9343 9347 ! 9347,9441 ; 94.73 ( 9111 j 9342 } 9343 : 9043 743 947 9143 9343 740 941 9141 9349 113 90.41 9140 9340 043 90.47 91.93 9347 09.03 ! 0947 ! 9040 91.23 1 9149 9343 ! 9104 t 9342 91.16 . 9143 i 92.40 i 9349 9343 1 94.03 ! 94.40 ` 9443 9341 : 03.00 ; 9340 94.00 ; 9441.94.93 : 93.37 . 9160 9140 j 9349 ; 94.41 9441 :IM41 '! 95.6l0 9l541.96.19 09.11 ' 09.93 ' 90.03 9141 ! 9149 1 92.60 > 93.11 1 93.39 91.19 * 91.90 . 9140 9103'93.50 i 94.09 i 9440 i 9449 9340 93.10 : 93.00 I 94.10 > 9447 9449 9345 93.67 9344 j 94.00 i 9443 94.90 . 9340 1 9347 9547 ; 9643 7.40 19.73 91.47 9144 443 9041 9349 9340 09.33 1 90.00 ! 90.70 ' 91.40 ' 93.06 9166 i 9117 9345 9140 : 9t.9 . 9340 . 93.09 ; 9J.64 ! 94.13 ! 9443 94.93 93.69 ' 93.39.9173 94.23 ' 94.67 . 95.10 : 93.44 ; 9173 934.; 94.15 J 9447 j 94.97 j 9347 j 9173 ! 96.03 j 9643 Pipe Slap K 1i** w; ial** 3V*P V4*P V3*P * *Ciapy carton wt. 5 lbs. Packaging Information Cntsa Contents of Bestfelt Pipe Insulation Standard Thickness Peat S retime Cram Wt. pet Carta*. Lba.* 01 73 6* . St . 43 30 37 at 10 . to 15 13 0 37 134 34 124 30 no 17 113 IS 101 13 tot to 7 . 9 00 0 70 0 S3 . 5 73 4 07 a 41 Outieda dimension* ot caeten 14'a JOy,' J7'. 125 - '' ^mtiOsr' Bestfelt Sheets and Blocks--Heat Losses, Surface Temperature, and Conductivity Mar rot* s-T.u. rt to. rr. or sumacs Hi nous 160 140 170 100 SO 60 40 20 0 100* 200* 300* TSMWAWM OS HOT MM OP MSUUtnON PH Bestfelt Sheets and Blocks Bestfelt sheets and blocks, for the insulation of flat; curved and irregular surfaces, are avail* able in standard widths of 6". 9*, 12", IS*. 24", and 36". All are 36* in length and thicknesses are 1". I'/a". 2". 2%", 3", 3%", and 4". The laminations ran the length of the block, allowing for greater flexibility and ease of application to curve surfaces. Weight of Bestfelt Block is ap proximately 3 lbs. per sq. ft per inch of thickness. Rccoraaanded Thkknesses-Bestfdt Sheets and Blocks or Condition Ho* Water o- as ibe IS-IOO lte. 100-200 lbc Low Suporfcaat Supcriwot Hi(k Supirtnot oSnmW. 212 to 204 207 toU7 324 to SS7 344 to 4*0 300 to see 600 to 700 1* I* iyb* r s* i* 120 400* 500* a.i.i a t Air Cell Insulations cell insulations are recommended for use do steam, hot water lines, and other heated sur faces where temperatures do not exceed 300 F. Pipe covering and blocks are made of alternate layers of corrugated and flat asbestos felt bonded together by a special laminating process. In air cell block insulation, the corrugated layers are crossed at right angles to give the block greater rigidity and durability. Air cell insulation is light in weight, rigid, and sufficiently strong for appli cations where service conditions are not severe. Air cell insulation is available fat three types: air cell, fine corrugated air cell, and special fine air celL The difference in the three types lies in the number of layers of corrugated asbestos felt used per inch of thickness. The greater the num ber of corrugations per inch, the higher is the strength end insulating efficiency of the product. Air Cell Pipe Insulation (Four Plies per Inch) Air cell pipe insulation is furnished in stand ard thicknesses of 4 plies, each ply being approxi mately >4" thick. Greater thicknesses will be furnished when requested. Pipe covering sec tions are three feet long and are shipped com plete with canvas jacket and lacquered bands for application to all standard sizes of pipes. Temperature Rup Up te 179 Up te 11] 212-MO Recommended Thicknesses--Air Cell Pipe Insulation DatcHptlan Hat water, tandemite return Beet, etc YS-i ply Hat water, bailee (cad water ruppiy, ttc. : K'-* Phr Law premura ittarn 1 ' -*Pr 2* te 4* pr l* - 9tr i ` 9*r 137 vtr Pr ,, * *4'"* pir l' - PT _ Efficiencies <rf Air Ceil Pipe Insulation Nominal Pipe lisa, inthfi 71 w* * vs *71 *yi 4 4'7L14 j 4 7 | i to Number o/ pUea 1 1 J J* 3 4 > 3 4 i 4 2 3 4 2 3 4 2 3 4 2 3 2 3 4 2 3 3 s 3 ' 3 3 2 4 2 3 Tempinature did erenee betvreal pipe and surrouadine air, *]r. JO* 100* 120* 200* 234* 300* Tempinature at *ipe. *F. (1 remperatuire at wirroudial air, n*) 122* 172* 122* 272* 123* 373* ESdado %............................ - %............................ " %............................ " %............................ " %............................ " %............................ * %............................ " %............................ " %............................ - %............ ............... * %............................ " %............................ - %............................ " %............................ * %............................ " %............................ " %............................ " %............................. - %............................. %............................. * %............................. - %............................. " %................... ` %............................. - %............................. " %............................. " %............................. - %............................. " %............................. " %............................. " %............................. " %............................. " %............................. " %............................. " %............................. ** %......... .................. " *............................. * %............................. * %............................. " %............................. * %............................. * %............................. : s............................. * ................... * %............................. - %............................. * %............................. * %............................. 2: %.......................................................... %............................. 494 344 340 SM 344 2.0 374 24 2.7 39.9 4.0 . 1.4 M4 70.1 61.4 6*-4 72.1 64J 70.0 73.* 4.0 7IJ 74.9 44 nj 72.4 <7.1 72.7 744 7.7 73.1 74.7 4.0 73J 774 Sit 74J 774 9.1 744 744 9.4 724 744 9.7 724 744 9.9 724 794 21.1 24.0 294 24.9 294 3.4 244 3.2 7.0 1.1 <4.2 9.9 2.9 7.2 71.2 4.4 94 734 2.7 71.0 744 <44 724 73.9 7.4 734 744 <74 734 77.1 04 74.0 774 4.7 74.4 74.0 9.4 74.9 74.4 9.7 73.4 79.0 79.9 734 79.4 704 73.9 79.7 79.4 744 74.9 234 244 1.7 27.1 1.9 2.1 <04 <34 4.7 <2.9 7.9 71.4 . <4.2 94 72.9 2.9 71.1 744 74 72.4 734 44 734 77.0 4.7 74.2 77.7 94 744 744 94 734 74.7 70.0 734 79.1 704 744 79.7 70.9 744 094 714 744 404 714 77.0 40.7 714 774 414 334 604 3.4 344 61.7 4.9 <1.7 44 704 4.0 <94 724 <34 704 74.1 7.0 72.4 73.7 644 734 774 94 744 744 94 73.4 744 704 734 794 704 744 79.7 71.0 704 94 714 774 404 714 774 414 724 774 414- 724 744 414 724 744 414 344 244 624 3.4 62.4 <44 <0.1 <14 34 <7.0 1.4 94 24 44 <44 9.7 71.7 72.4 44 64.0 704 724 73.9 73.1 44 7.9 714 734 734 74.2 74 694 734 734 744 744 694 71.1. 744 744 744 79.0 704 72.1 73.7 77.1 79.1 <04 704 72.7 744 74.0 794 04 714 734 744 70.4 04 14 714 73.4 774 74 04 1.7 724 774 114 744 794 2.1 72.4 744 <14 72.7 74.4 1.9 744 j_M7944 ---- ---- 74.9 04 <1.0 734 74.7 <2.1 724 04 U.4 734 734 794 0.9 24 U.7 734 7S. 79.1 1.1 24 U.9 12S Nominal Pip* Six* Packaging In/ormatioa--Air Cell Pipe Insulation Carton Contents -------------- --------r-------------- Thraa Ply (Par Carton) Pour Ply (Par Carton) Ft Sac Gram Wt lba. Ft. S*c Greta Wt lba. H* y*m i* Hi* IW* f r 3K* 4* J* (* s* 10* ISO iss 13S 10S M 73 S4 45 31 43 U 31 13 13 Shipped knocked dawn. Empty carton weitht--0 lba. M <1 35 04 40 04 30 3f 33 37 34 SO IS 43 13 43 IT S3 IS 33 11 40 T 30 3 33. 4 33 133 130 90 11 T3 34 43 30 43 33 31 IS 13 . 9 44 40 33 37 14 IS . 13 13 14 11 7 0 4 3 00 03 00 37 so so 47 44 SO 49 30 39 33 31 16y*".Outaida dimanaiona of carton IS' z 1J)4* z Simplex "Super Shrunk" Pipe Insulation This pipe insulation is identical to four-ply air cell, except that instead of a pasted canvas outer jacket it is supplied with an outer casing of white asbestos felt This outer felt is specially processed to produce a water repellent surface. It can be readily painted and easily cleaned with a damp doth. Super shrunk pipe insulation is furnished in three-ply and four-ply only and is shipped complete with bands aud fasteners. Efficiencies for Simplex Pipe Insulation are the same as those given for Air Cell Pipe Insula tion on Page 128. '* Packaging Information--Simplex Pipe Insulation Carton Contents Nominal Pip* Stzta V4* Y\ 1* Hi* Vi* 3* *H* 3* 3Vi* 4* 3* 0" S* Ft ISO _ 13 13S - ISO 90 71 34 43 30 37 31 It 13 Tbtta Pty (Par Carton) 4 40 33 40 34 33 14 10 15 13 7 S .4 Otaaa Wt lba. 01 04 04 39 37 49 44 44 30 33 33 33 30 Four Pty (Per Carton) Ft Groat Wt lba. U3 44 >30 40 M . 33 OS 03 SO SI 27 37 73 34 SO 34 IS so 43 IS 47 34 13 . 44 37 9 3S 34 S 37 13 3 29 . IS 3 33 - 3 Empty carton waicht--0 lba. Outaida dimamiana at carton IS* z 11\ z 1H*. 129 Fine Corrugated-Air Cell Pipe Insulation The greater strength of fine corrugated air cell pipe covering mokes it specially suited for in* sulating medium and low pressure steam and hot water lines subject to excessive vibration. This sturdy material is unaffected by rough usage and cun be removed and replaced many times without damage or loss of insulating properties. Fine corrugated air cell is furnished in stand* ard thickness of 4 and 8 plies, and each ply is approximately thick. Creator thicknesses will be furnished when requested. Pipe covering see* tions are 3 feet long complete with canvas jacket and brass lacquered bands for application on all standard sizes of pipe. Photograph shows purt of the strain halting system at the V. S. Veterans* Hospital at Ft Custer, Michigan. Flue corrugated Air Cell Covering was applied, then finished with a 4-oz. rewrapped canvas Jacket sized and painted with lead and oil point. Metal hands were then applied. Thidowat r apir Approx. Net Weights in Pounds per Standard 3 Foot Section Nominal Pipe Sizes, Inches HH t 1 JJ4 3 3V4 4 0.91 IM 1.33 1.44 1.55 1.36 2.15 U3 Ml 3.13 t.at Lax 144 US U3 5.94 3J9 3.93 4JS 4.79 * 3.73 4.43 L_ 3.69 (.63 Special Fine Corrugated Air Cell Pipe Insulation Special fine corrugated air cell Insulation, con* structcd with 8 plies per inch, provides high me* chanical strength, greater efficiency with mini mum heat loss for temperatures up to 300* F. Be cause it will withstand rougher handling and more severe service conditions, this covering is widely used in place of regular air cell in indus trial appUcatfq^&r Insulation of medium and low pressure steam and hot water lines. Special fine corrugated air cell is furnished in thicknesses of 4, 8. and 8 plies. Each ply is ap proximately V*" thick. Creater thicknesses can be supplied on special order. Individual pipe covering sections are 3' long and are shipped complete with canvas jackets and brass lacquered bands, for application. Air Cell Sheers and Blocks Air cell sheets and blocks ere used for the in sulation of low pressure boilers, feed water heaters, dry kilns, warm air ducts, boiler room ceilings, partitions, ovens, and staves operating at medium and low temperatures. Sheets and blocks are furnished in standard Q", 9-, 12", 18*. 36". and 72" lengths. They are 36" wide and thicknesses range from V"" to 4". Other sizes and thicknesses can be specially or dered. Each corrugated ply of the material is a full Vi* thick. Air cell shrrts and blocks weigh approximately 1 lb. per sq. ft. per 1" thickness. 130 - 9 Thickness of insulation, inches 0 1 m a V4 3 m 4 Heat Losses and Efficiencies of Air Cell Sheets and Blocks Temperature difference between hot surface and surrounding sir. Oct F. so* loo* iso* aoo* iso* Temperature of hot surface (Temperature of surrounding air. IS* F.) US* ITS* IIS* ITS* SIS* Hast 1oasts par square foot of boro surface per hour; and Efficiencies of insulation Boro surface loot, B-tu. Efficiency %................ - %................. " %................. " %................. - %................. - %................ %.............. 74 TMS 13.02 U.T4 *0.74 92.17 *3.19 94.0S 213J S0.S9 lilt 1921 - 91.0* 92.41 93.40 94.20 360.0 31.13 16.40 6949 91.14 91 JO 93.49 94.13 i S33.0 SIJ7 1643 19.47 9143 91.60 93.32 9444 7374 SI.S0 1110 (9.60 9142 91.74 93.71 94.43 Fine Corrugated Air Cell Sheets and Blocks These sheets and blocks are mechanically stronger and possess higher insulating efficiency than the ordinary four-ply air cell material. They are furnished in standard 8", 9", 12", .18*. 36", and 72" lengths and in 36" widths, in thicknesses of z", 1" 1%*. 2*. 2Vt", 3", 3Vs". and 4". Other sizes and thicknesses can be fur nished on request Each ply is a full <" thick. Fine corrugated air cell sheets and blocks weigh approximately 1.3 lbs. per sq. ft per 1* thickness. Heat Losses and Efficiencies of line Corrugated Air Cel! Sheets and Blocks Thickness of insulation. Temperature difference between hot surface and surrounding air. Deg. F. so* too* no* 1001 iso* ' Temperature at hot surface (Temperature of surrounding air. 73* F.) 123* 173* 133* 173* 323* Hoot lease* per square feet of bore surface per hour; and Efficiencies ef insulation Bat surface lea* BAu. 1 Efficiency %................. 74 (0l67 1* " *........... V Mil 2 - %................. IU9 * " %................. 914* 3 - %................. 92.44 jvs " %................. 9X33 4 - %................. 94.44 213.2 81.96 7.00 NJ4 91.63 92.66 9342 4JI 360.0 I3J9 * 17JO *0.1* *144 *3.13 4.(3 94.73 333.0 (3.10 I7JI 9044 9241 9X43 Ut ` 94.93 7374 UJ1 Mil 9040 9241 93.60 94.43 9S.66 131 Packaging Information--Carton Contents Air Cell and Fine Corrugated Air Cell Slice ts and Blocks Si* of Shnea and Block* * ii' * H* IS' * 11' 4* x 3d* . Sq. Pect par Carton a;-* A-i 33 dt 13S tar w-1 13 4S M 133 Thickno* inchro--Ply l'-4 l'-d 1V*'-J 1 Vi'-d iw -* Number ot Shccu or Blocks per Carton 12 3d 31 n S4 d 14 4S 10S . SI 73 m*-r 7 11 41 d3 Air CQ Sheen and Block*. Pine Corrugated Air Ceil Sheet* and Block*. Grot* Weight appro*.--40 lb*, per carton lor Air Cell Sheet* and Block*. Croat Weight appro*.--110 lb* per carton lot Pine Corrugated Air Cell Sheet* and Block* Empty Carton weight--S lb* Outside Dimension o! Carton--4df4* * M)4" * U*. 2'-* 2'-tl d It 3d 34 Special Fine Corrugated Air Cell Sheets and Blocks Special fine corrugated air cell sheets and blocks possess high mechanical strength and in sulating efficiency. *They are furnished in stand ard thicknesses of 9, 12, IS, 36, and 72* lcngtlis and in 36* widths. Thicknesses are 4-ply, 6-ply, and S-ply. Each ply is approximately Vo" thick. Other sizes and thicknesses of Air Cell Sheets and Blacks can be supplied on special order. Two layers of Air Cell Baud, each 1* thick wen used to insulate then hot water con verter* Finishing cement then was trowelled on over hexagonal wfr*L*Mlh. 13S .* fr * ' Duplex Pipe Insulation Uuplcx Pipe Insulation is adaptable for the in sulation of either hot or cold water service lines. Its top temperature limit is 212 F. This material is composed of a special interliner of saturated felt impregnated with waterproofing compound, followed by a continuous wrapping of specially ^ creped felt. An outer wrapping of asbestos paper is* then applied over the felt and the covering is finished with a canvas jacket When applied to the line; it has a white appearance similar to magnesia and air cell pipe covering. Single layer Duplex Pipe Insulation is manufactured in 3 feet long sections in thicknesses of *4", and 1*. It is supplied complete with canvas jacket and the necessary lacquered hands for application. Double layer Duplex Pipe Insulation is manu factured in two layers of equal thickness to a total thickness of 1", l'V*, and 2". Duplex Pipe Insulation is furnished with a canvas jacket and necessary bawls for application. Heat Transmission Through Duplex BTlTi par sg. ft. at papa *air<aea/h./degra F. temperaCura 4U7a*cnea between papa end saaxtn'indiag air Pipe Sase VS' y,` l* * 1*4* IVS* J* i3VPS' 3VS* vs* S' t* Tbtefcaau ol Covering Inches VS .m .719 .670 .6U .610 ill ill 44S JUS 417 JN JM JOS V4 iM .60S ISO 410 .49$ .440 .440 .430 .410 .411 40S J9 JM 1. 4SS 430 .4gJ .440 .414 490 470 461 4S0 443 430 431 411 IVS .499 .444 490 462 443 416 490 .161 471 464 457 4SI 443 Packaging Information--Carton Contents Duplex Pipe Insulation Non-Frost Pipe Insulation N on-Frost Pipe limil.ition is applied to retard freezing in cold water and dram pipes in un healed rooms or where they are exposed to out side temperatures under normal conditions. This insulation is constructed of layers of hair felt covered with several layers of paper felt and lined with a layer of specially treated paper felt to prevent the hair felt from coming In direct contact with the pipe surface. The hair felt because of its excellent insulating properties, is used to retard the escape of heat from the water in the pipes to the colder surrounding air. The paper felt jacket and the inner layer of treated paper felt protects the hair felt from infiltration of moisture that would impair its insu lating efficiency. Non-Frost Pipe Insulation should be used only on cold water pipes that are exposed to moderate rather than tJidnidtly low temperatures, or where die tim thai the surrounding air would be below die freezing point is of short duration. When Xou-Frast Pipe Insulation is applied to outdoor piping, special provisions must be made for weatherproofing and protecting it. Pipe covering is furnished in 3* sections, with canvas jacket and brass lacquered bands for application. It is manufactured in one thickness. 1%", for all pipe sizes from up. ' Heat Transmission of Non-Frost Pipe Insulation Heat Tranaranaon of Non-Frot Pipe Covcrinc <l`i" thick) in B. T. U. per hour, per dc*. F. temperature dif- .' Terence between pipe end air. (Bated on SO* temperature difftitnca between pipe and turroundina air.) Pipe Siae V4! * 1 lVi* r V4* s* (l* Per lin. (L .133 .131 .170 .190 .111 .349 .314 _uo JM .400 .433 .471 .330 Packaging Information--Carton Contents Nominal Pipa Sira Ft Sac Grata Wt Iba. Vi" *4* 1* 1Vi* !> r U 11 34 IS 43 IS 41 14 34 11 33 11 14 s IS IS : 11 St S3 79 14 77 B 6f 39 43 49 Empty carton wcibt--3 tba. , Ouliidc dimension* at carton 14 i 30V4 . 134 I Non-Sweat Pipe Insulation ^ on-S\vat Pipe Insulation is a combination of insulating and waterproofing felts used to pre vent condensation on cold water lines. The in sulating felts protect the flow of heat to the pipe. The waterproofing felt protects the insulation from the moisture in the air. Non-Sweat Pipe Insulation is furnished in single and double layer construction. Single layer Non-Sweat is made in thicknesses of 14* and %*". Double layer is made in thicknesses of 1", IVi", 2~. The illustration on this page shows double layer or broken joint construction used in thicknesses of 1" and over. This construc tion eliminates the longitudinal and abutting joints that in ordinary pipe covering extend from the outside of the covering to the pipe. Recommended Thicknesses-- '' Non-Sweat Pipe Insulation Air Temperature under 100 dec* * i ......i '1 ......... i Pipe Humidity Thickness of Thickness Temp. Range. Non-Sweat of Hair Felt Deg. F. % on Pipes on Fitting Over 50 Over 50 32 to 50 Under 7J TStoSO Under 75 Yf-1* \-Wi IW-J* $*-* i-IVi* 14-1 Insulation Pipe we. tncbm 4 X t Da 14 3 34 3 34 4 Heat Transmission Through Non-Sweat Pipe Insulation Raws at beat tranandsaioa in given in B-C-u. per hour, per deg. F. temperature difference, per Linear foot and per square foot of pipe surface. : H'thk* &UB. aTft. P n.lt V thick I 1* thick B.fc.0. pnr tin. It. B.t.a. ag. It at.ii. ! BJtM. P*r Un. ft. a*ft. 14'thick at-u. 1 at.n. pw ! Un. ft tqp.*ft .313 .34S .JS4 .338 .374 .443 .518 .611 .663 .757 .MS .Ml .CM .777 .731 .713 .613 .666 .633 .643 .133 .313 .343 .334 .313 .367 .433 .497 .333 .611 .341 .770 .706 .633 .637 .391 .364 .343 .333 .313 .137 .IN .313 .349 .373 .313 .364 .433 .466 .SIS .738 .637 .633 .373 .346 .313 .464 .463 .447 .143 .160 .110 .206 .233 .137 .193 .337 .369 .404 .649 .331 .333 .473 .443 .413 .333 .367 .333 :343 r thick aio. pw Un. ft at-u. Pr ag. ft .133 .143 .133 .1M .194 .331 '* .349 .234 .311 .333 .531 .513 .460 .413 .349 .356 .331 .310 .297 .267 las Packaging Information--Non-Sweat Pipe Insulation . Carton Contents Nominal Pip* Six* Vi` V* 1' i w; IV*' %m m' 3' 3V4* Yx" Thick Grots n. See. Wt. lb*. iso SO SO tso SO S3 12S 41 S3 90 32 SO *4 2S SO SO 20 40 43 IS 44 30 12 42 17 9 30 Ft. 114 90 14 69 SO 43 30 27 21 Note--Double )' thicknon not stocked. Shipped in crate*. M* Thick* Grot* See Wt. lb*. 34 74 32 72 10 73 23 70 20 SO 13 30 13 S3 . 9 49 7 43 l* h Doubt* yi" Thick Gross Ft Sec. Wt lbs. SI 27 si 72 24 si SO 20 ?s 31 17 73 43 IS 71 30 12 67 27 9 S9 U 7 S3 IS S 31 Approximate Net Weights of Pipe Insulations (Pounds Per Three Foot Section) lamledao MmW Me* Slw. fade |* 1 ** ladM* H* X* l* IX* IX* r ax* 1* * X* 1* ** r r r 14* 19* MS * UlMumb US M.coi. USUumU MS M.male St*. LM 14* L.7* 137 LSI 14* S3* .94 *.**, LM LI* L7S 7St 1449 11.44 IU1 14.44 14.74 IX Ml s4e U4 4J4 444 144 Ml) in 74* M4 L7*| S.65 a.is, mt ILM 1*44 14*74 1 . tie U4 S3* Ml MT' 731 4.71 10.4* 1137 19.44* U.44i IS.4I 17.17* 14.11 ILM IMS ILM dm. see. Ml S4S 141 LM 744 4.74 4.74 i I*.:*: UM U4S 1731 ILM.11.1* 1X*1 14J 1 IM4 1144 is.es IS.4S 1144 143* 14JI 17.** iua J4 1*31 SMS 1131 1*31 KrTa* Kr-T*np . IX Mt LIT 4.1* 74* M4 Ml Ml 113* 1*47 14.4* 1134 1*41:11.11 11.41 1X77 M4* RM a Ml 9.7* 1037 11.71 tut 1434 1134 1744 IM1 1*34 ILM M.4* 17.44 SLS4 ILM 1*31 *141 kC4 Air am in St 13* 140 L4 140 1.79 LI* 14* LH LM 144 LM 441 431 LM LW L71 7.44 ur 1.47 144 13* 1.1* Ml L7S LIS 147 13* 44* 431 X4* 431 Lll 737 Ui 4.77 nuCamma 4 Fly St 137 143 134 143 13* LI4 141 Mt Lll L4I L7S 4.41 FbtCennut Hr l.l 131 134 MS MS 134 14* 131 441 4.7* 14* S3* *31 tpmdmt Rm SpHtalPhM Fir ft 0 1JS >34 I.7S MS 14S MS 13* 141 Ml 437 L7* LIS 4*14 L47 7.7* LIT f.lt tU4 137 241 MO S3S 111 1.74 *4* L44 S44 LIS 73* LSI IL7I tL47 I 439 434 S44 440 *43 434 LSI 1M7 113* ILM 1437 1X44 ILM till 1L74 SL4* ILM 114* Wm S.m FT-- 111 KmkIvM r,",ntt Paplie He*!** Dopiai thrnim mr * ** H * l IH 143 U1 43S M0 1.SS 131 Ml SJt 134 ill 4.7* M0 1.14 ua S.17 M0 1.11 340 1.77 Ml Ltl 4.** LI* L71 Ml 434 43* L44 S44 741 lit *37 330 030 444 7.71 LM 14.14 41.41 IM7 9177 IMS 11.74 IU.44 IL1S 1741 1LM|M4* ... | I1.41 LN I4SI U1 L44 LM 1.41 r*-Mt Ml 14*1 144 4.17 43* 331 LM S4T LU 4.41 3.17 1.43 S3* 731 (47 MO 74* 7.7* LM 1434 114* ILM 1X71 1*31 1X71 143*. 1L17 1L1* 1134 14.1t lira* IM7{ILM 14.74 1731 SLI*jff37 114* JS43* 1*34 414* _____1_____ Lit 431 ! V4 LM 74S- L44 M7 ilm; ti.7i ILSI ILM L1 1L71 IL71 * SO. <.*> 431 4.40 4.M M7 431 Ml 7.94 931 134 1*39 - 136 / Mineral Wool Blankets A^inerai Wool Blankets ore suitable for insula* tion of hot surfaces up to 1200 F. These blankets are made by felling high temperature and mois* ture resistant insulating wool in large flat sheets between various styles of metal fabrics. These blankets are flexible, and can be ap plied to equipment having curved or irregular surfaces at minimum cost Mineral Wool Blankets are manufactured in standard sizes of 2 x 4 feet and 2x3 feet and in thicknesses of 1" to 8**. Special sizes can be made upon request . Standard stvles of Mineral Wool Blankets are: 5 Stucco lath and ribbed lath (rib turned in) 5-A Stucco lath and %" ribbed lath ' (rib turned put)' 6 ribbed lath both sides * (rib turned in) Conductivity vs Mean Temperature Mineral Wool Blanket Style Description 1 1" wire meakboth sides 2 1* wire medfcand stucco lath 2-A 1" wire mesh and expanded metal lath 3 Stucco lath both sides 3-A Expanded metal lath both sides 3-B Stucco lath one side-expemled metal lath other side 4 Stucco lath and ribbed lath (rib turned in) . 4-A Stucco lath and ribbed lath (rib turned out) . mam mmnw Mown mmsmoi ' MTWUN MM* IMS OUTM HMMCH 137 Surface Temperatures and Ilcnt Loss for Mineral Wool Blanket Insulation Heat Loss Chart--To determine the surface tem perature of a given thickness of Blanket, read the chart as follows: Under table of recommended thicknesses, a 3-in. Blanket is suggested for equipment having a hot surface temperature of 800 F. Therefore follow vertically from the 800 F. point until that line intercepts the 3-in. curve. At that point, follow in a horizontal line to the left until it intercepts the margin, and it will be seen that at that point the figure is 133, which is the temperature in. degrees Fahrenheit of the cold surface on the outside of the mineral wool blanket. Similarly, t* determine the heat loss for a given conditioat- refer again to the example on the chart Follow vertically from the 800* F. mark, to an intersection with the 3-in. curve. From that point follow horizontally to the right until intercepting the heat loss curve. At this point, go vertically to the upper margin which is calibrated in terms of b.Lu. heat loss, tnd it will be seen tliat the heat loss for this particular condition is 93b.Lu. per sq. ft. per hour. 138 r' Hair Felt Insulation (Navy Standard) Flair Felt is composed of 100% selected cattle hair processed into roll blankets. The primary use of hair felt insulation is to prevent water pipes ' from freezing. This material is used in a specified number of built-up layers of 1* thicknesses, bound in place on the pipe with heavy jute twine and protected on die outer surface with a weatherproof jacket Hair Felt is furnished in standard rolls of S' x 10P, y x SOT, O' x 50T, and y x SO* in the thick nesses and weights shown in the table below: certain amount of circulation. With no circula tion, if the air remains at low temperature for only a short period of time freezing can be pre vented by the insulation. The table on Page 140 gives rates of heat trans mission through 2 layer. 3 layer, and 4 layer built-up hair felt insulation on pipes from W to 12* in diameter. - ThkkMMt >; V4* i* i' ivt* i* Appro*. waigfct Appraa araight par tq. ft. par 300 sg. It rail 4 m, M m. M m. U sa UM tZ. n a TS Iba IM Iba. 100 Iba ItO Iba 1U Iba 300 Iba 309 tba It must be remembered that no insulation, regardless of thickness or effectiveness, will prevent water in pipes from freezing when in* sufficient circulation of water exists, or where the outside temperature remains sufficiently low for any appreciable length of time. Insulation will retard freezing of water in pipes if there is a Kitting* * the line *mg>lyiitg cold watrr b llti* hot grnrrutur w insulat'd with huikmp hair Wt N*mSwnrt Pipe Covering was used. straight pipe nua 130 Nominal pipo*f Vi i 1*4 2 S 4 S 9 a 10 12 Duta on Frccva'nj* of Water ir. Pipes Inralatioa. No. of layer* each 1 in. thick B.T.U. per deg. T temp. dill, per hour 1 per luu (t Hour, to cool to freexins point Lb. water fleer per hr. per tin. ft. to prevent frerxiaf 2 3 4 2 3 4 2 3 4 2 3 4 2 3 4 1 3 4 2 4 2 3 2 ^ 4 2 4 2 34 .QtM .0747 .0440 .1113 ' .0011 .0790 .1440 .1120 .0977 . .1300 .1244 .1003 .20*2 .1372 .1322 J4M .1090 .1J4S 4407 ' .2140 .1704 JM1 .2434 .1904 .4100 .2900 0390 .4900 J339 4030 4720 .4090 4223 .417 400 445 423 1.02 MO 1.40 1.74 2.02 144 2.4S 340 343 447 5.00 443 4.02 740 542 7.90 9.69 743 940 1340 10.03 1340 1743 13.00 10.10 22.70 1540 2240 2S.10 437 44fl 490 473 44 .4(0 440 470 433 . .952 .747 .050 1.237 .943 .793 1.470 1.110 429 1.733 1409 1459 1.901 1.400 . 1.191 2.444 1.770 1.434 2.960 2.123 1.490 3.432 \ 2.494 LOU Figures are given to show the time required for the water in a pipe to cool 10 F. from 42 to 32 F.. but a difference in temperature be* tween water and air at 60* F, which would correspond to an air temperature of 18* below zero. Water should not be allowed to remain in the pipes without circulation for longer than % the time mentioned. The last column of figures in the table indi* cates the minimum amount of water that should be supplied pee hour at 42? F, per each lineal foot of pipe haerder to prevent the temperature of the water from dropping to the freezing point As a safety fader to provide against temporary reduction of flow due to lower pressure or other causes, the rate of flow should be at least double that given in the table. Figures on time and flow apply only to the given conditions. For example, if water enters the pipes at 52* Fh instead of 42* F. it will take double the given time to cool the water to the freezing point and only half the amount of water will be re* quired to circulate to prevent freezing. On the other hand, if water enters at 33 F. it will be cooled to 32 F. in V^g the time given in the table and 10 times as much water will have to be circulated to prevent freezing. The times shown in the table are those re* quired to lower the water to the freezing point. Actually, longer times would be required to freeze all the water In the pipes, but once the water starts to freeze the danger point has been reached. If frozen at only one point, flow will be stopped and the entire line endangered. If die water remains without circulation longer than the safe time Indicated, the only positive way to protect the line is to provide a small steam or hat water line along side the cold water line and then apply insulation so that it entirely surrounds both lines. 140 I Insulating Cements and Finishes /' Insulating cements are used os insulation and gs finishes. They are applied as iusulation to fittings too small to be insulated with blocks, and on irregular surfaces or inaccessible surfaces that cannot be practically covered with pipe insula* tion or blocks. Insulating cements, like other heat insulating materials, have top temperature limits at which they may be expected to perform efficiently. Other important physical charac teristics that must be considered in the choke of a cement are outlined under the descriptive ma terial on each cement Hy-Temp Cement This cement is similar in composition to Hytemp insulation in powder form and can be used on surfaces up to temperatures of 1900 F. It is recommended for use on irregular or small surfaces where tlie application of Hy-temp blocks or pipe insulation is impractical, and for pointing up of Hy-temp block and pipe insulation applica tions. Because of its relatively porous nature, Hy-temp cement is not recommended as a finish ing cement. Nos UQAsbestos Tills is an ioeagnsfre; high-grade insulating cement made of asbestos fibers and binding ma terials. It may be applied to hot surfaces Up to 600 F. As a finishing cement it produces a hard, durable and smooth finislt This is a natural colored cement which dries to a very light gray shade. Where extra hard finish is required. Port land Cement may lie added to No. 152 Asbestos Cement mixing three parts asbestos cement and one port Portland Cement lay weight. No. 152 Asbestos Cement is also used for roughing in. . 85% Magnesia Cement This cement is similar in composition to 85^& Magnesia Pipe Covering and Block Insulation but it b made in powder form. Efficiency of AS1/* Magnesia Cement b higher tluui that of any other plastic insulation, it b also extremely light in wcigltt The cement may be used on heated surfaces up to 000 F. Thb cement b not ordinarily used as a finish ing cement Usually a layer ai asbestos cement b used over SS- Magnesia Cviueut as a finish. When on extra liard finish b mptired, Portland 141 Cement is added to the asbestos cement (See "No. 152 Asbestos Cement") cracking. Due to its high adhesive strength it can be installed witliout wire reinforcement Ambierex No. 2 Cement This insulating cement is particularly recom mended fur roughing in. It is composed of as bestos fibers, 85/o Magnesia, and binders. It is ideal for use on fittings, irregular surfaces, and other places where liighly efficient insulation is desired at a cost that is considerably below that of 85^o Magnesia Cement It may be used for temperatures up to 1000 F. Mineral Wool Cement Mineral Wool Cement is a plastic insulation made of heat resisting mineral wool combined with asbestos fiber and special clays. It will with stand temperatures up to 1800 F. It can be reclaimed if the temperatures have not exceeded 1200 F. It is an ideal plastic insulation for in sulating surfaces not suited to preformed types of insulation. . Power House Cement Power House Cement is manufactured by the Baldwin Ilill Company and is a hydraulic setting mineral wool cement It is both a finishing and an insulating cement It has exceptionally low shrinkage and can be applied in one coat without Fibrous Adhesive Fibrous Adhesive is a plastic material for use as an adhesive tn temporarily hold in place in sulation sheets. Mocks, and segmental covering until permanent outer binding support is com pleted. This material is of thin trowclliug con sistency and is recommended for use where in sulation is applied to brick, concrete, metal, or other surfaces. It is also used for binding insulat ing blocks together in multiple layer construc tion. Fibrous Adhesive is applied to the surface of the insulation and then pressed in place against the surface to be insulated. A spotting of the adhesive on the material is generally sufficient for this purpose. It is necessary to remove all paint on surfaces to be insulated before applying insulation and fibrous adhesive. Otherwise the insulation will loosen after the adhesive dries out. The surface also must be dean, dry, and free of grease. Fibrous Adhesive is furnished ready for use in 73 lb, 173 lb, 350 lb, and 600 lb. metal drums. Givering capacity is as follows 1. Insulation against metal surfaces--50 lbs. per 100 sq.ft of surfaces 2. Insulation against masonry surfaces--To lbs. per 100 sq. ft. of surface. 1TPOVCI Use isa Kiiiw-- r FfafaMec Hy-Temp*- Insulating Cement Data Tjfra Temperature Limit Album DtaemMMa 1000* 1900* Avaroca Cavanac Capacity 3. fb/tao the. Ona la. Thick J Mixiae ; j rTOponiwi Ceilooa water per 100 the. 20 1SVS tab. 4S It Kala. Lb*. per he* too 71 U% Miewh Ambteroa N, 1 Miami Wool Power Hows* Tnailatiws Ineulatiac XaMlftttac ant Fteiahiac U% Utpou AlbatMUnmil Miami Waal HyOraaUa Settiac Miami Waal 400* <00* 1M0* 1700* 47 43 Sale. SO 10 14,; gala. to SO 34 (ala. so IS 10 (ala. so 142 r Outdoor Finishes Factory Applied Weatherproof Jackets For Pipe Insulations Three types of weatherproof jackets applied at the factory on special order are available. They include Standard Weatherproof Jackets. Heavy Weight Weatherproof Jackets, and 50 lb. As bestos Jackets. All three types include 6" wide strips or collars for covering the circumferential joints at the ends of the sectional covering. The weatherproof jackets are lapped along the longi tudinal joints, but the lap is loose so that the in sulation can be applied over the pipe in the usual manner. Standard Weatherproof Jackets are made from a rag felt saturated and coated with asphalt They weigh 35 lbs. per 108 sq. ft. Heavy Weight Weatherproof Jackets are made from a rag felt saturated and coated with asphalt. They are almost twice as heavy as the Standard Weatherproof Jackets, weighing approximately 60 Dm. per 108 sq. ft. 50 lb. Asbestos Jackets are made from asbestos felt saturated and coated on both sides with asphalt and given a final coat of talc and mica on $>oth sides. These jackets weigh approximately 58 Am. per 108 sq. ft. When specifying weatherproof jackets for pipe insulation, the exact type required should lie mentioned. Unless this is done, all orders for pipe insulation calling for "roofing jackets"or"weather proof jackets" without detailed specifications as to weight and quality will be made up with Standard Weatherproof Jackets. Where the specifications call fur "roofing jackets" or "weatherproof jackets" weighing in excess of 35 lbs. per 108 sq. ft, orders will be made up with Heavy Weight Weatherproof Jackets. . When factory applied weatherproof jackets are ordered, the necessary lap cement for sealing joints, and wire or bands, are furnished. _ Armstrongs Insulmastic Insulmastic is a factory-mixed combination of Armstrong's Asphalt Emulsion with special fibers and fillers. It is recommended for use where a fire-resistant finish is required. Applied in two coats, each approximately Vs" thick. Insulmastic is an excellent finishing material for low-tem perature insulation exposed to the weather. On high towers, vessels, elevated lines, large ducts, breechings, etc., galvanized wire mesh should be applied directly to die insulation before Arm strong's Insulmastic is troweled on. Armstrong's Insulmastic possesses Hie tensile strength necessary* to withstand normal move ment without cracking or rupturing, is not af fected by temperature changes, does not slip or sag at high temperatures, and bonds well with the corkboard insulation surface. * When Insulmastic is applied in two coats, each about Ik" thick, the .two coats will dry to a final thickness of Armstrong'* Insulmastic is an escetlrut bush far rspanMna loops and Suing* an nutduur itesm lines. It will withstand rauvrmrot without rupturing at radial and dors ant dip ur sag. I L 143 i N*w typi a# Hp Cotriaf h high imulitiiM vala*. rigid sttaagA, aad leag III* *1 molded can cavariay, bid coot* far b* to buy aad iastafl. Mad* la Hikfcainil caloalated * pravoat cap daotaHaa rim mod iadaara aadar narmal daslga coadMoaa aad rilbh raoamaiaodod tomporatur* raago*. Oa aotdaar Kao* aadar sevoro sorvico coa. dtHaaa. addWaari Ibhboaoi may ba aarawary. Alberta* aad Alanriaaas Papa Sacfclag praridaa firrpeaol aad nparpnri flaisil. aa 19a *.* ^-mstrong LANCASTER. PA. ARMASPRAY Hlgh-Temperalure Spray-on insulation (TO BE APPLIED ONLY WITH ARMSTRONG APPROVED EQUIPMENT) 1 3167 (Armstrong ,, CONTRACT1NO AND SUPPLY CORPORATION LANCASTER. PENNSYLVANIA Net weight 50 lb. MAOE IN UNITEO STATES OP AMERICA XT % & \' *  .for fast, low-cost application plus the proved performance of cork CORK COVERING *w ^^rdoct of VP- tlV* O&ER 1N G pto*rra7llrlrow~femperature .line  for fist, low-cost application plus the proved performance of cork ong CORK^gVERING LT-Thirty Cork Covering LT-Zero Cork Covering LT-Mlnua Thirty Cork Covering Armstrong LT Cork Covering is a new type of pipe insulation, developed by Armstrong Research for use on all low-temperature lines. It gives you the high insulating value, rigid strength, and long life of molded type cork covering, yet can be benight and installed at much lower oott MA0C Of MIOH-OUAUTY CORK--LT Covering is made from precision-cut segments of Armstrong Coskboazd, having a thermal conductivity of ia Btu per square foot per hour per degree tempera ture difference per inch thirfaiera at 00* F. mean temperature. Segments are adhered to a backing of asbestoa paper and aluminum foil laminate. /Ill- AMO VAPOP-USISTANT--The asbestoa 'paper provides a highly fire-resistant Snish and the aluminum foil seals out moisture vapor. A THKXNISS rot KVmr CONDITION--LT Cov ering is made in thicknesses <wl<nU--d to prevent condensation when used indoocs under de sign conditions and within rseommeoded temper- tuse ranges. On outdoor lines, under severe service tbicknesm fluty bt occttstfy* IT-TMrfy--Made in J* thickness, for use on lines operating at 30* F. or higher. LT-Zara*--Made in IH* thirlmsw, for use on lines operating at temperatures as low as 0* F. LT-Mlnee Thirty*--Made in Hi* thlchneia for pipes thrmigh Ittf IPS, 2* tbJdmaa for pipes to 8" UPS, and 2%* fhtoftneirfac laifnr pipe ran. Far use on lines opattfag at temperatures as low as 30* below zero. AH three types are made in 30* lengths sad will St accurately all sizes of hen pipe or copper tubing from h" up. For temperatures below minus 30*. LT Cork Covering will be made in Minus Sixty, Minus Ninety, and Minus One-Rundred-Twenty Thick nesses on order. APPUCATIOM IS PAST AMO (AST--Armstrong LT Covering is manufactured with a lap of the as bestos-aluminum paper backing at the longitudinal joint In application to straight piping, the lap is sealed in place with Armstrong 320 Adhesive, and the end joints are sealed with Armstrong LT Sealing Tape. As no wiring, pointing, or painting is needed, Lt Covering goes on the piping with remarkable speed and ease. Fittings are insulated with pieces of LT Covering, fabricated right on the jo or with Armstrong Plasticork*. Plasticork is a eock-and-rabber com position material that is molded by hand over the W*hg By using the proper size of LT Covering and w--Ihwj i faw simple saw cuts, coven for any string can be fabricated easily and tepidly. Voids between fitting and fitting cover are filled with Armstrong Plasticork, sad exposed ends are seeled with Arm strong LT Senior and LT Sealing Tape for a vapor- K|jt ln^PillaHniL Field fabrication of fitting coven speeds the job. Workmen can insulate the entire line as they go. with no waits for factory shipments of fitting covers. VAPOD tAJUtlOt UNWOSOM--As no nails or staples are needed to install LT Covering, the vapor seal formed by the paper backing is un broken. There are on punctures where infiltrating vapor can cause condensation or frost formation within the insulation. CAN M UMOVID AMD UUUD^-When lines are relocated, or taken out of service, the asbestos-andilummum paper can be cut and LT Covering sal vaged without damage to the cork. The covering can be applied again, using Armstrong LT Sealing Tape to hold it in placn. SAVCS STODAOf SPAO--Inventories of LT Cork Covering take up no more storage space than board-form material, as the insulation comes in fiat sheets rather than to curved sections. POD A DC WXM fIMUH--For a durable, easy-to- winHin or where color identification of the line is desired, Armstrong Insulcolor* can be ap plied over the vaporprocF paper becking on LT Covering. On outdoor installations. 4-ox. canvas must be applied over LT Sealing Tape at joints ftwiAtng with Insulcolor. (For complete in formation on Armstrong Insulcolor, call or wnte for free booklet) SUNDRIES FOR APPLYING (Sfmstrong lt CORK COVERING Armstrong 320 Adhesive--This all-purpose dve form* a strong, resilient bond between abort aajr clean, dry rurfacea. The bond ii aa eicwBent vapor seal and groan rtrocger with time. Available in ~irhatf pint, pint, quart, and gallon container*. Coverage ia 29 to 30 Ua. ft. p plat Arnutrmg WaiHwrfc For om to r**J,+"g A* space between LT Fitting Coven and pipe fittings, and for band (adding fitting ooven. This is a granolated coekaad-rabbar composition, supplied in sheets about one foot square and rme-httf inch thick. Packaged in card board cartons cootabling 9, 19. and 30 Dbe. Armstrong IT Senior Far uae in nmlfng joints and ads of LT Fitting Coven. This white seeler is the onedstsney of rauflrtog compound. It is a vapor-bantrt coating that meets the fire redstaace rsqiitiwoeiU of U. S. Spedfieutton M1L-P-476A. Peeksgad in It jdig pint, quart, 1* and 5-gaUoa oaataimn. Armsfreeg IT Snnllng TaprHJitd to seal and joints of Aimsoung LTGoric Covering Thfctt a vapor-buskr. preome-sensittve adhesive tape. Supplied in rufls 2 wide, 3 and 30 yards long, white in oolar. UMtatrilJSafc|hto prUtetatriGnh| (IkM* lftretettf t Z* Up> .1 w V Vi* V 1' 1V4* iVi* r IVi' r IVi* * r r 1 ir tr 1 ir ter tr ur tf.isoe J 4 4 3 4^ A*-: A4 3 3 A .7 A 1A 13 1.4 14 1A 13 LO 14 S4 Mm 'A A A A 3 4 4 A A .7 .7 .7 4 .9 1.1 14 14 14 14 1.9 1.1 14 14 ' new'-, A A A A 3 3 A .7 .7 .7 4 J .9 14 14 1.4 14 1.7 1.9 11 14 14 14 ' APPLICATION OF (^rnstrong lt CORK COVERING IS FAST AND EASY The speed with which rmnlatino mechanics can ap ply Armstrong LT Cock Covering results in substantial daw and tabor savings, compared with conventional application methods. With LT Covering there are oo wires or bands to apply, no sealers or seam fillers are required, and on doth, twine, or paper must be wrapped around tfan insulation. Indoors, oo further Rwfakieg is necessary, except where desired for decora*0^1 tff ri,WlU.RM.. Fitting covers are fabricated on the job from sections of LT Covering or am be built up with Armstrong Ftesdeark. A brief description of fitting cover fabrica tion iHvyi* is contained on Pages 9 and 7. Com plete details are available in a booklet entitled. "General Instructions for Fabricates of Fitting Coven of Arm strong LT Cock Covering" which is available from Armstrong on request. Data on application of Plasticork fitting covers is contained on Pages 10 and 1L I V The surfaces of the backing paper that coma in Icontact with each other an coated with Aim* stroag 520 Adhesive, la this picture, the adhesive baa been applied to the undenide at the longitudinal .. fiapt and the workman is coating the ana ol the as* bettor paper that will be covered by the flap. After the 520 Adhesive has dried to the touch, 2 Armstrong LT Covering is positioned on the pipe with the flap downward. When the coveting is in place, the cork isgmenti fit together without gaps or voids. No adhesive need be applied to them With the covering held firmly to place, the flap 3 is sealed down by the workman running his thumb along the papar at the longitudinal joint. The rest of the flap is than sealed to place. Waterproof adhesive and vapor-banter papar fora a moisture impervious outer wragfe After the muss and cash ngmrnti have been 4 aligned, end joints an sealed amply by snapping them with Armstrong LT Sealing Tape. This vaporproof tape completes the vapor-benter and pro vides a oeat looking joint between lengths of Ann* strong LT Cork Covering. Cutting at short lengths, when required, should 5 be done with a miter bos or with a mechanical saw. End joints must be squan cut for snug fit so that there is ao danger of condensation and frost for mation at those points. Both the cork segments sad the paper cut cleanly. UUUUCATION 09 90' AMO ** lu COWS ON-THE-JOB FABRICATION OF FITTING COVERS SPEEDS APPLICATION of (Xfmstrong LT CORK COVERING Fitting covon (or LT Cock Cowing installartons uv fabricated on the job. Lengths of LT Cowing of a size that will eadrdo tfao fitting at its point of maximum art uaodL By making a low finplc cots with a saw and miter box, any fitting can bo aaaity and quickly insulated. Except for iciewed fittings, space between the fitting and the cow la packed with Aim- strang Plastleock, eliminating voids and increasing tbe efHdeocj* of the tnatailation. Armstrong LT Sealer la applied to the irpoaed ends of the LT Cork Cowing and joints in the StMf.cow an cemented with Aim- strang 520 Adhesive fat a completely vapocpraof in- ttallarton. . Field fabrication does away with the delay censed when cows for special fittings most be made op at the factory and shipped to the job site, la all cases, regardless of tbe fitting encountered, it can be insu lated along with straight piping as the job progresses. RTTM rot *0* BL mrem roi d' u raamcMtoM or m urn vaivt caws \ \ V ra ce vuvt cow MMUCATMM O# % 'T V 2 men cut--aoy rat ajsimw I Cross Sections of Typical Fabricated Fitting Covers for Screwed Fittings Without cottar--'When LT-Thirty Cattriaf li and at the pipe ran, do coflan era required. Void be tween fitting ted fitting ooeer need not be filled 530 AOMBIW nAsncocx <mama httino rat uratu r it-zbo ot ir-Moea THtsrr oNmsM With cotter--When LT-Zro or LT-Mfaee That Conrhp tie need a pipe ne, cottar* of L" Thfctjr Caeeritg an applied at shewe at (he dm' fag above. Spece between fitting and Ittfag coe b fitted with AmsOong Flastfcorfc. UNEAL FEET OF LT CORK COVERING AND QUANTITIES OF SUNDRY MATERIALS REQUIRED FOR FITTING COVERS Motes: | Who* two lengths are shown ia the mow column. um figure printid in black for mwfafd fittings (12S lb.--ISO lb.). Um figuro printed in color for extra hnavy and ammonia fittinp (230 lb.--300 lb.). 2 Armstrong 320 Adhesive quunritWi urimate 1 pc. for each 23 lineal feet of pipe run. Count each fitting or valve aa l'B" of piping. J LT Sealing Tape required per lineal foot of LT Cork Covering is shown on table on Page 4. | Tables on thcM pages ore for estimating quantities only. For fabrication details and dtaensioas, see booklet, "General Instructions for Fabrication of Fitting Coven from Armstrong LT Cork Covering," 5 On aO valve bonnets, reinforce LT Sealer with white glass fabric, muslin or scrim dock SCREWED FITI..4G AND VALVE COVERS- UWW TOT Of CQVWSie HQUIOT Ml MTTlNe oa VAiyi tUR --- IUfiRItmog **25* --H HH HH tH t t 4 4 4 4 4 4 HH H H 1 H tH tH 1H 4 4 47 4 4 4 m 1% H -- t tH t IH H .? T .7 1.0 1.0 1.0 tH tH 1 1H tH 4H 4 tH 4H 14 IA IA 1.0 14 14 4 1-- * wee 4 H e IA 14 14 U 14 14 14 10 -- It -- it it 14 14 14 M M M .M nom WU end Sweat Fitting Covers Fabricate cocenr from wm erfes covering e* ujed on pipe rum. Tsae and Creases to eS pipe Man require no Flntieork. RANGED PITTING AND VALVE COVERS- UMtt nr or covmeso unusasa sen imissn oa vaavc WmS^ mm iSL a LR f* at VUmm < 1 1 1 - w iNn iCr m m vavpi - G4m ^T EMM* NAmk** Lfvl^A t* 4 nt liu IA IA IA IA iaia .71.0 IA IAU IA U 1.711 u Ul< U1.0 u IA 1.0 i S iv 1M i uu IA IA IA IA IA .71A IA IA IAU 1.7 tJ u Ult UM IA IA 1.01 ] iV IH 4H IA IA IA IA IA SA IA .7i.O IAU IA 1.71. 1.7 tl u L4 IA M IA 1.0 1 5 r 4H * IA tv m H IA r m IA J* IA IA IA IA UU UU 1A1A IA Um IA IA IA IA IA IA IA IAU IA UU IA IA IAiA IA IA 1.7 IS U UM UM M MO IA U U SA M MO 4A IA IA UM IA IA MO AM IA 1.0 i } u MM M 1J tv 10 IA IA IA IA IA IA IAU IA IA UM M IA MO 4A AM Mil U O' it te 1AM IA IA IA IA IA IA IA iaia M IA IA 4A 4A AM 1J U r IA IA in IA IA IA IA IA u M IA 4A AM 4A 4040 M 1.1 U U 1J er < it IA IA IA r 14 IA IA IA ir 1* tt IA IA IA ir to 14 IA IA IA t# u M IA IA 4.01 4A ur u IA 4.0 4A 4A IA IA IA IA IA JJ IA IA AM 4A IA tAte 1AM U Ul] 4A 1J to A M M1 u 4A IA1.0 1AM M 4A u 4A AM Oao 40 UU 4A U 4A 4A 40 U Ul 3 I to 1J to 1-1 to to ! il t-0 4A AM*i 4At| 1AM IA M 4A 4A U to AM 40 4010 to to 1 i 1 . to 4A UU 4A1.0 IA IA M U it Uil AM AM 1.9 4010 7.0 te to J 1M j!I_IA IA IA IA IA IA 4A4A an AM 4470 TA TA L0 --STANDARD, EXTRA HEAVY AND AMMONIA Ml | m m nut IMw -- to-- 1ffc.MftM--V -- 1 -- ITS-- ---- j 4 .7 .7 14 14 j 4 .7 .7 14 14 j 4 .7 .7 1411 141.1 WUkfMM-- | ___ to-- I1MMI--M -- N-- j4 ---- 4 4 14 14 J 4 SUNMIU M-- <Al MMV--to to w+mm 1 1----M, to ^ Vo-- -- -- r--r. | O-- 1 Mi M--m ov to-- .1 .1 44 44 44 44 .1 .1 .01 M .01 j 4 t 4 .0 4 4 1.11-1 1.111 14 10 A 4 4 4 a 4 4 4 14 14 14 14 A 4 4 4 a 4 414 414 141.4 141* 14 14 A 4 44 AA 44 4A At .91 .01 A .7 14 14 14 14 A 1 .71.0 1414 1.1 1414 14 .7 14 1414 1414 14 14 14 14 ' A 4 A 4 14 10 A 4 A 4 14 14 .7 .7 4 4 A4 4 14 4 14 .01 .01 41 .7 14 .7 14 .71.0 14 14 14 1414 14 14 14 14 14 1410 14 14 14 14 14 .7 .7 .7 .7 14 14 .7 .7 14 4 -- -- -- -- 14 J 14 14 14 14 14 14 .01 .01 41 14 1414 14 1414 14 14 14 mm 14 . 14 14 14 14 14 14 -- -- -- -- 44 14 14 14 t4 14 1414 1444 -- -- -- -- *4 14 <4 44 74 4 *4 104 44 .04 M 14 14 141.0 14 14 44 14 14 14 14 44 44 14 14 14 44 44 44 144 14 -- -- -- -- no 14 -- -- -- -- 174 14 HO 174 104 404 114 MO 4* 40 .10 --STANDARD, EXTRA HEAVY AND AMMONIA 1 II j " -- wm It MAN iiem nsr WW--1 Mat 4 4 4 14 1410 14 4 4 4 14- 1410 14 A A 4 "" 14 14 it i-- iar - -- *- 14 14 14 14 14 14 14 14 13 17 44 14 14 14 13 14 44 14 A4 A 4 14 14 14 14 14 04 14 74 4 4 A 4 414 14 14 1404 14 13 13 74 114 114 4 4 4 4 414 14 1404 1404 14 13 14 74 114 144 i*rm ir-itow 04-- -- 10 14 40 -- 10 13 13 n .04 .00 14 04 .00 44 04 .07 74 SO * J A 4 414 1404 44 04 14 14 10 10 114 174 no 74 14 .00 J 4 14 1404 44 04 13 10 14 174 14 140 04 00 .1 J .4 4 14 04 44 04 13 14 14 174 no 144 014 104 TO 1 4 -4 4 41 4 14 04 04 40 4 4 4 14 04 40 04 M4 004 in 114 14 14 04 104 M4 004 114 14 04 04 no 014 714 04 114 o 114 no 4 .4 4 14 04 041.0 0410 04 04 04 004 ooo too 101.0 H4 no 4 4 4 14 047.0 4010 7410 04 44 04 744 M4 too 1*70 tt41'1 no 4 4 14 74 74 10 44 44 04 no 1-- 1014 111-0 04)11 104 11 .11 .11 .! 1 J APPLICATION OF strong p tASTI CORK TO FITTINGS Insulation of cold line fittings is rapid and eco nomical with Armstrong Plasticork. The fit ting first is primed with a brash ooat of Atm* strong 520 Adhesive. Small pieces of Plasti cork am used to fill out hollows and form an even contour. Sheets of Plasticork then are built up to the dashed thidmsM around the fitting and held in phn with twine. For a do luxe finish, a V*T cosBof Seme's Cement is trowelled smoothlp over the Plasticork fol lowed by 2 coats of Aimstroog Weatherproof Plastic or LT Sealer to provide a vapoebarrier. Other finishes include white industrial tape and LT Sealer, friction tape and Weather proof Plastic, or Armstrong LT Sealing Tape. This tape requires no further finish indoors. HOW TO DETERMINE PLASTICORK USAGE By using the data on these pages, you can determine the amount of Plastioork and sundries needed for insulation of ail fittings. Insulation thicknesses are based on the Table of Recommended Thicknesses* immediately be low. The three tables that follow indicate the number of pounds of Plasticork required to insulate cold line fittings on piping insulated with LT-Thirty, LT-Zero, and LTMinus Thirty Cork Covering. The areas shown in the three tables represent the num ber of square feet of Plasticork surface after the insuladon has been applied and should be used in estimating Keene's Cement, Weatherproof Plastic, and Friction Tape or LT Sealing Tape requirements. When estimating primer requirements, (Armstrong 320 Adhesive) use only 30% of tbe total area shown. In estimating rundry requirements, use tbe following coverage data: Keene's Cement: 2Vfc lbs. per sq. ft (V thick) Weatherproof Plastic: 45 sq. ft per giL (2 coats) SMAdhtrivo (primer): 723sq.ft pergaL e\ i-A !***** Friction Tape or LT Sealing Tape: 1" width for fittings through 2" IPS approx. 23 lin. ft per sq. ft surface, or 3d sq. ft per TS-ft roil 2* width for fittings through fT IPS approx. S lin. ft per sq. ft surface, or 9.4 sq. ft per 73-ft roll Soft: for unices add 10% for tap* flashing red RfCOMMCNDCD THICKNKSSIS of Armstrong plasticork sris 1 m4m*m S s 4 4 ta it t# 1* f t* 1- * t* t# r Ufa* IV IV IV iV V tV tV IV tv tv tv tv tv *v tv*' tv Mam IbHS <MWiM rn IIWW-- Ua* Wm Jor. ytat 4 Mkw* of MUM 23% CTHWr (Am tho thteAnew of tty* LT Cwrig m (A* p*e tom. j m4 V H V* H 1 IV. tv* tv* I tv* 4 5 * 10 tt 1 .1 '* .1 I -> .1 4 .1 .4 .4 .4 44 44 .7 4 .9 1.0 t.t 14 14 l.f l.f IS <4 t* 10 14 1 l ft 4ft* wi row * i si J1 B [ii * 1 ii 1 m * J mm B tab * tf%t. .1 '4 .t .1 .i .7 4 4 4 .1 4 4 .1 .i .7 4 .4 4 4 4 4 4 4 .7 .4 4 4 4 4 .4 4 4 4 4 .7 .4 4 4 4 4 .4 .9 4 1.0 4 .4 4 4 .7 4 1.0 .9 14 .7 .4 1.0 .7 4 4 14 1.0 14 4 4 1.S 4 1.0 .7 1.4 1.4 1.9 1.1 .7 14 14 14 .9 14 1.9 14 14 4 10 14 1.7 1.1 13 14 IS 1.9 1.0 11 11 14 14 14 10 4.7 It 14 14 14 1* 1.9 14 34 04 It 1.7 U 14 It 14 11 94 IIS 74 10 14 44 44 1.0 19 113 144 10.0 ft VtfM [1 1 1] J1 l ta. u ft. *--* ft. Jf .9 4 .9 14 .9 1.0 14 14 .9 14 1.3 1.3 1.0 14 14 1.7 14 10 13 1.9 1.4 13 19 11 14 1.0 13 13 17 13 It 11 11 14 44 1.7 4.0 44 341 44 44 3.0 34 4.4 34 34 1* 3.0 7.0 74 14 9.4 t.4 9.0 104 104 110 14.0 14.0 134 110 19.0 19.0 no 14.0 4 1.0 13 1.0 1.1 13 14 1.1 11 14! 10 14 14 1.1 17 14 4.41 19 44 34 1.1 3.0 13 14 10 74 It 74 9.4 3.1 13 117 3.7 94 IIS 13 114 144 11 14.0 174 9.0 1B4 no 111 114 no 11.9 174 144 113 m ! 4 j ta. ft. i .1 1.3 .4 : 4i t.t .4 3 1.3 .3 .6 1.1 4 .9 1.1 .9 14 1.4 14 1.1 1.4 1.1 1.3 1.4 14 14 13 14 *> t. 1.9 IS 14 11 14 1.1 13 19 1.3 19' 1.4 1.4 1.1: 4.1 4.3 , 19 3.7 3.0 j 34 7.0 ITTHIRr V* 4 4 .1 .7 4 4 4 4 4 4 .4 1.0 14 1.7 1.7 14 10 13 .s: .ft 1.3 H 4 .3 4 .7 4 .4 4 4 4 4 4 14 10 13 1.7 10 13 13 .7 1.3 V* .4 4 .3 .7 4 4 .4 4 4 1.0 4 1.0 13 19 1.7 10 13 IS 4* .9 1.3 * 4 .7 4 4 4 .9 4 .9 1.0 14 4 1.1 14 17 1.9 10 10 17 1.0 > 14 1 '1.4 1 4 . 4 4 4 14 14 4 14 14 1.9 1.1 1.4 10 44 11 34 13 34 14- 1.7 1.4 IV* .9 1.0 .7 .9 14 1.4 .9 1.1 1.1 13 1.4 14 34 34 13 74 10 IS 14 10 1.ft tv* 14 1.1 4 1.1 14 14 14 14 10 14 14 10 44 19 14 10 104 IS 10 13 l.ft .-t 1.4 14 14 14 14 14 14 14 It 14 11 10 13 74 11 104 113 IS 13: 19 14 1.7 10 1.3 1.7 13 14 1.7 10 It It 19 3.4 74 t4 11 110 19.0 3.0. t? t.t 3 13 14 14 IS 14 14 IS U 34 13 It 14 9.0 104 It 194 104 17 34- 11 19 IV* 14 17 10 14 IS It IS It 74 9.4 94 11 104 114 19 174 114 13 It 14 3.3 4 14 14 IS 19 34 94 It 19 110 110 74 IS 114 119 34 194 114 74 Hi 44 1.4 5 34 34 13 34 17 7.7 10 14 194 114 144 74 134 174 10.4 no S9.0 94 3.0- 3.1 l.ft * 10 7.0 19 13 10 94 10 13 113 310 19.9 94 110 isi.o 114 no 334 104 9.1: 17 14 0 no no 194 17.0 410 1114 7.9 1ft IT 10 314 no S1.0 410 344(111 13 94 13 IS 104 (410 17.0 910 494 |17.0 10.0 11.3 74 V* 4 4 V* 4 4 V* .4 .4 H 4 .9 1 1.1 14 tv* 14 14 IV* 1.7 14 s 13 14 tvt It IS 3 14 19 IV* 13 9.0 4 3.1 17 s IS 9.4 4 104 11.3 t 10 IS 4J 444 4 4 4 4 4 4 4 .4 Mr tM 14 14 4 M 14 "14 1.7 1.1 14 14 14 10 14 14 14 14 14 1.7 1.7 14 10 13 13 10 14 It 13 It 14 17 IS IS 14 14 It 10 7.0 13 14 IS 74 9.0 9.0 IS *10 39.0 110 13 74 3.0 113 110 IOlO .9 4 1.0 .9 1.0 1.1 4 t.i 10 13 14 14 1.9 13 4 i.i 10 13 14 13 11 34 .3 4 6*!1 10 10 .9 14 1.9 1.1 14 10 1ft 1.9 10 3.0 M 1.3 1.7 1.0 14 10 13 14 1.4 10 It IS 10 no 13 10 13 11 1.1 13 11 1.9 1.7 13 74 14 110 1S4 10 13 19 13 14 10 14 13 11 10 94 10 114 114 94 1.0 1.3 1.1 14 13 14 1ft 1* 94 119 14 13 34 14 10 110 lit 13 10 74 19 13 110 110 34 74 9.4 34 13 113 119 9.3 104 110 7.9 74 19.0 no 10 110 17.3 113 t.7 S1.0 no 3.0 13.0 31.0 lit 10.0 13.0 m 13 110 113 13 14 10 10 110 ns 7.0 13 1.3 13 no 174 9.0 3.3 11 34 S74 .314 i 74 10 19 10 114 i 39.4)110 7.0 10 13 lift 413*10.3 ! 9.0 74 413 i 913 <113 ' 9.0 114 1ft 14 4.0 44 3.1 1.1 17 9.1 310 40.9 no lit S9.S '310 9.0 3101 43.011 IS .11.0 111 7.4 410 1410 113 413 . tiomo 113 11 1 1.0 310 ino 110 no ioio mo 110 <14 9.0 *7.0177.0 19.0 toioinoino 11.0 117 j 4 0.0 For farther information on Armstrong Insulations, sad for samples of these produces, writs Armstrong Cork Company, Lancaster, Pennsylvania, or get in touch with the Armstrong Office nearest yon. Albany, N. Y. Atlanta, Go. lolHniore, Md. linuingkeai, Ale. lulVale.N. Y. Oieriette, N. C CMcage, III. Cfaidnaeif, OMe Oevolaad. OMe CelseibeA OMe Dellas, Teaas Denver, Cole. Detroit, Mlsfc. Harrisburg, Pa. rib___ rWTiVTlf VffiMIe HmjfWe %!fm Houston, Teaas Indianapolis. led. Jacksonville, Re. Kansas Oty, Me. ' let Angeles. Ceilf. Louisville, Ky. MeanMs. Tens. Milwaukee, Wts. Minneapolis. Minn. Nesbrille, Teen. New Orleans, Is. New York. N. Y. PMIedeipMe. Pe. Plmbergk, Pa. DrwmsrsllIffaiPof^fif Providence, R. L ttckuwnd. Ve. Iscksstsr. N. Y. Si# loviis M$t iManlnnu Seattle. Weak. Spokane. Wash. Tulsa, Okie. Workington, 0. C Wnu'wpton. Del. INSULATION DIVISION LANCASTER. PENNSYLVANIA BALTIMORE OFFICE Telephone (410) 5398404 Fax (410) 539-8407 Law Offices J^fyeparh A- |29nffnwm 36 S. Charles Street Suite 2200 Baltimore, MD 21201 3100 Monticello Avenue Suite 750 Dallas, Texas 75205 August 24, 2000 DALLAS OFFICE Telephone: (214) 443-4319 Fax: (214) 4434)358 REPLY TO DALLAS Ms. Ivy Jones Baron & Budd, P.C. 3102 Oak Lawn Avenue, Suite 1100 Dallas, Texas 75219 RE: AWI's Responses to Liability Interrogatories In Re: Baltimore City Asbestos Litigation Dear Ms. Jones: Pursuant to your request, enclosed is a copy ofthe Responses ofArmstrong World Industries, Inc. to Plaintiff s First Standard Set ofLiability Interrogatories which were discussed during one of Shep's presentations at the PALS 2000 seminar in Ft. Lauderdale, Florida. If I can be of further assistance, please do not hesitate to contact me. Sincerely, It Enclosure Linda Tolson Legal Secretary