Document NEbyYREJp6akabpQYeMa8ZOLR

FILE NAME: Ameron (AME) DATE: 2016 Apr 1 DOC#: AME003 DOCUMENT DESCRIPTION: Report on Bondstrand PID Bondstrand PID Updated April 1,16 Bondstrand Bondstrand was Ameron's line of corrosion-resistant pipes and.fittings, designed to be a costcompetitive alternative to stainless steel pipes.1 There were several series of Bondstrand pipes, but only the 4000 and 5000 series contained asbestos. Both contained crocidolite. Bondstrand 4000 and 5000 series were first manufactured by Ameron's subsidiary Amercoat, Inc. and then later by Ameron's Corrosion Control Division.2 Years Produced Several primary source documents indicate that the 4000 series began production in 1953, including advertisements and engineering guides from the 1950s. Ameron and its corporate representatives have given conflicting dates of when Bondstrand was first produced. Rog answers state that it was produced during the 1960's and up through the 1970's.3 Corporate representative Ralph "Rocky" Friedrich testified that Ameron began manufacturing Bondstrand in the late 1950's/early 1960's.4 More recently he testified that Ameron licensed Young Development Labs in 1953 for the process of filament winding, but that it didn't produce its first Bondstrand pipe until 1955.5 Initially, Ameron had development issues with the pipe, and Friedrich claimed that the first successful production didn't happen until about I960.6 Another corporate representative, Dalt Bordner, confirmed Ameron's rog answers, testifying that Bondstrand was first sold to the public in the early 1960's.7 1 Deposition testimony of Dalt Bordner (6/17/2003) 13:10-15 2 Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\IL 2012 06 08 MFG AROG-ADOC (#14). See also \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (p. 134) 3 GO 129 am resp POS 12-7-04 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses 4 Deposition testimony of Ralph Friedrich (6/6/2003); 39:23-40:2 5 Friedrich (3/24/2011) 98:19-24 6 Friedrich (3/24/2011) 99:7-22 7 Bordner (9/23/2003) 23:13-24:2 l | Page Updated April 1,16, Friedrich testified in 2003 that Bondstrand did not contain asbestos during the 1950's and that it was added sometime later.8 Bordner also testified that asbestos was first added on an experimental basis sometime in 1960 or 1961.9 Friedrich testified that Ameron removed asbestos from Bondstrand in approximately 1975.10 Another testified that it was 1978.1112Official correspondence indicates that it was late 1979.12 Even after Ameron removed asbestos from Bondstrand, it continued to sell remaining asbestos-containing inventory until it was used up.13 Bondstrand 4000 Bondstrand 4000 pipe products were fiberglass-reinforced epoxy resin pipes designed for use in severe chemical services and corrosive environments, with operational temps ranging as high as 300F.14 The RP-6A adhesive used for the 4000 serie's was also asbestos-containing and produced by Ameron.15 A Bondstrand advertisement stated that the 4000 series had been used in many varied industries since 1953.16An engineering guide for the product confirmed that it had been in production in a variety of industries since that time.17 In 1979, an edition of Ameron News gave an overview of the history of Bondstrand, stating that Amercoat acquired a patented process for tubular filament winding in 1953.18 Bondstrand 5000 8 Friedrich (10/3/2003); 57:7-18 9 Bordner (9/23/2003) 21:14-22:1 10 Friedrich (6/6/2003); 56:8-22 11 Bordner (9/23/2003) 115:3-11 12 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (pgs. 186-188) 13 Deposition testimony of Neil Lambly, 6/15/2011 (93:21-95:12) 14 \\simmons\scanned\ASBESTOS\LIABDOC\A\AIVIERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (p. 205). See also Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses 15 Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses 16 SC-AIC-1550 (p. 3) 17\\simmons\scanned\ASBESTOS\UABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (p. 205) 18 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Documents from Cheryl White - PHH 1 Docs\GIES 1778 - 2254.pdf @ AM-GIESK-01984 2 I Page Updated April 1,16 Bondstrand 5000 products were fiberglass-reinforced polyester resin pipes designed to handle oxidizing agents and highly corrosive solutions that were generally beyond the capability of epoxy-lined pipe.19 The RP-105 adhesive used with the 5000 series was asbestos containing and produced by Ameron (see below).20 Advertisements indicated that Ameron began manufacturing the 5000 series around 1963. The advertisement described the 5000 pipe as product that combined all the benefits of both epoxy and polyester resins in one single unit. It also stated that it was available in matching fittings, from 2 in. to 12 in.21 Other Bondstrand Lines Ameron claims that only the 4000 and 5000 series contained asbestos; however, specification sheets for the Bondstrand 1000 and 2000 series calls for fittings to be lined with c-veil and overwrapped with resinimpregnated asbestos mat. Molded fittings could be used if they were found suitable for the pressure and chemical service requirements.22 Product Description23 For the Bondstrand 4000 and 5000 series, Ameron used crocidolite asbestos because of its longer fiber length and its better chemical resistance.24 Ameron did not make custom Bondstrand pipe for its customers. Pipe products were manufactured to standard specifications, although Friedrich could not rule out that Ameron never made custom asbestoscontaining Bondstrand pipe for its customers.25 Crocidolite asbestos liner: 19 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (p. 215). See also Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses 20 Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses 21 SC-WPC-0300 (p. 330) 22 sc-aic-1860; sc-aic-1861; sc-aic-1870 23 See the following: Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses; GO 129 am resp POS 12-7-04 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses; Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\IL 2012 06 08 MFG AROG-ADOC (#29); Friedrich (6/6/2003); 63:9-14; 67:2-69:11; 79:3-7; 99:5-6 24 Bordner (9/23/2003) 33:15-34:9 25 Friedrich (11/7/2007) 30:24-32:3 3 | Page Updated April 1,16 The crocidolite interior liner had a blue/black appearance. It consisted of 40% blue asbestos and 60% resin.26 It was around 0.050" to 0.060" thick27 o Specification sheets for the 4000 series described the liner as "0.05-inch resinimpregnated asbestos specially produced by Ameron for this purpose."28 During the later years that Bondstrand contained asbestos, the 4000 series liner was a combination of both asbestos and C-veil (C-veil was a chemically-resistant glass).29 o Specification sheets for the 5000 series described it as a "resin-rich liner reinforced with C-veil and crocidolite asbestos fibers. The liner shall have a nominal thickness of 0.050-inches. "30 Depending on the time frame, it was either a felt-like (described as a mat material) or paper material (see below for more details).31 The mat material was supplied by Special Electric; the paper material was supplied by Mead. o NAAC supplied the blue asbestos for both (see below), o Cellulo also supplied the crocidolite mat material. During the process of eliminating asbestos, Ameron switched from the felt material to the paper material. This would have been around the early or mid-1970's.32 o Elsewhere Ameron claimed that it switched to paper material for automation reasons; the blue asbestos mat could not be automated on the multi-mandrel machinery.33 The paper came on rolls and were 18-20" in diameter. The liner was encased in either a thermoset epoxy or polyester resin. 26 Bordner (9/23/2003) 81:2-18. See also SC-AIC-2485 27 Bordner (9/23/2003) 49:5-21 28 SC-AIC-2485. See also \\simmons\scanned\ASBESTOS\UABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 2011 12 19 SALES SAROG-SADOC (SEARS)\IL 2011 12 19 SALES SAROG-SADOC (SEARS).pdf (pgs. 205; 261-262) 29 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\AMRN150\AMRN150-1856 thru AMRN150-2092.pdf @ AMRN150-1927 30 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 2011 12 19 SALES SAROG-SADOC (SEARS).pdf (p. 213) 31 Bordner (9/23/2003) 43:13-23; 200:2-11 32 Bordner (9/23/2003) 49:5-21 33 Friedrich (10/3/2003); 27:12-21 4 I Page Updated April 1,16 5 | Page Updated April 1,16 Exterior appearance: The exterior color of the pipe was black/gray. o Bordner testified that originally the pipe was manufactured as a golden color, and that it would change to black after environmental exposure. Sometime later the pipe color was changed to black.34 Pipe ends were coated yellow (fter 1977) The structural walls of the Bondstrand pipes and fittings were filament wound.35 34 Bordner (9/23/2003) 83:15-84:3 Updated April 1,16 o 26% resin and 74% fiberglass356 The trademark "Bondstrand" was stamped on Bondstrand pipes.37 Friedrich testified that Ameron also stenciled 4000 or 5000 onto the outside of the pipe.38 Per Ameron rog answers, "Bondstrand pipe also had warning and/or caution labels for certain years."39 See Warning Labels below. Bondstrand specification sheets stated that pipes and fittings should be marked with the manufacturers' name, trade name, series, diameter and date of manufacture. The markings were to remain legible during normal handling and installation practices.40 For pictures, see below. Fittings: Produced in various configurations, including toes, elbows, tapered body reducers and flanges. Bondstrand fittings were compression-molded and also contained asbestos.41 o There were also filament-wound fittings that were made in a similar fashion as the pipe. These were also made out of crocidolite asbestos.42 o According to both Friedrich and Bordner, loose crocidolite asbestos mixed with resin was used to make the molded fittings.43 o Bondstrand asbestos-containing fittings were always manufactured with crocidolite asbestos as long as Bondstrand piping contained asbestos.44 35 SC-AIC-2485 36 Bordner (9/23/2003) 49:5-21 37 Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#38) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses 38 Friedrich (3/24/2011) 275:22-276:9 39 Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\IL 2012 06 08 MFG AROG-ADOC (#29) 40 sc-aic-2485; sc-aic-2500 41 Friedrich (8/30/2004) 80:4-14 42 Friedrich (6/6/2003); 75:24-89:9. See also \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 2011 12 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ AMERON 0782; \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Documents from Cheryl White - PHH 1 Docs\GIES 850 - 1318.pdf @ AM-GIESK-00910 43 Friedrich (11/7/2007) 55:20-56:10. See also Bordner (6/17/2003) 21:15-23:8 44 Bordner (6/17/2003) 23:13-24:4 7 I Page Updated April 1,16 O The molded compound for fittings consisted of 40% crocidolite asbestos and 60% resin.45 The Bondstrand 4000 engineering guide stated that the 4000 series utilized Series "E" fittings, which were epoxy-asbestos lined.456 o For steam condensate lines, the Bondstrand Series 2000 was recommended; however, the 4000 asbestos-containing pipes and fittings could be used interchangeably with the 2000 fittings.47 The Bondstrand 5000 engineering guide stated that the 5000 series used Series "P" fittings, which were produced using the same polyester lining as the pipe, described as a "resin-rich liner reinforced with C-veil and crocidolite asbestos fibers."48 o For 2"-12" pipe diameters, the Series "P" flanges were available in low-cost molded or custom-made glass filament reinforced.49 According to Bordner, the filament-wound lined fittings were made with asbestos mat because it could be formed to the odd shape of the fittings better than the paper could.50 o The mat was cut with a rug-cutter.51 o Filament-wound flanges were made in Brea's Bondstrand plant throughout the 1960's.52 o A lathe was used to dress the outer edges of the filament-wound flanges, which created visible dust/shavings.53 Bondstrand pipe and fittings were joined using either a Quick-Lock bonded joint or a flanged connection. Quick-Lock joints were assembled using a thermosetting adhesive.54 45 Bordner (9/23/2003) 81:7-8 46 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (p. 205) 47\\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (pgs. 457-459) 48 Ibid., 215-222 49 IIUbidJ . 50 Bordner (9/23/203) 45:17-46:2. See also Exhibit #5 to deposition. 51 Ibid., 64:15-24 52 Ibid., 76:20-25 53 Ibid., 77:1-9 54 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\AMRN150\AMRN150-1671 thru AMRN150-1854.pdf @ AMRN150-1729-AMRN150-1731 8 | Page Updated April 1,16 Instructions for bonding joints and mounting flanges were included with every adhesive kit.55 Instructions for bolting up flanges and for mounting saddles were included with each shipment.56 Bondstrand fittings engineering guide57 o Note that the guide refers to an audio-visual training program that Ameron recommended for viewing by everyone assembling Bondstrand. Viewing of the film was arranged by the local Ameron sales office. Assembly instructions for Bondstrand flanges58 Description of how the fittings were manufactured, including the dust created from when rolls of asbestos mat were cut with large scissors or when the flanges were grinded.5960 Easy to install, with choice of lock ing wedge or threaded fittings. Dimensions: Product was produced in 2-12" diameters and up to 20ft in length. 55 Ibid. 56 Ibid. 57 \\simmons\scanned\ASBESTOS\LIABDOC\A\AIVIERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ AMERON 0244-0268 58 Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Bondtstrand Brochure.pdf (pgs. 17-18) 59 Russell Ladd (3/27/2002) pgs. 311-385 60 Q:\ASBESTOS\LIABDOC\H - M\MARINE ENGINEERING\P&H\Log Books\1959\4 April 1959 ocr.pdf (p. 35) 9 | Page Updated April 1,16 o Larger sizes were available upon special request.61 o Note that Ameron claimed it didn't make custom Bondstrand pipe. The 2, 3, and 4" lengths were the most popular size Bondstrand pipe that Ameron produced. Asbestos Content The lining of the Bondstrand Series 4000 and 5000 was crocidol.ite asbestos embedded in either a thermoset epoxy or polyester resin. The liner was 40% crocidolite asbestos. It was approximately 0.050" to 0.060" thick.62 The asbestos paper rolls were 4" wide and about 18-20" in diameter. The rolls had a 3" cardboard core at the center. The paper was 30-50 thousandth of an inch thick. The paper had a matte-like finish. Friedrich described it as resembling felt with visible fibers on its surface.63 Elimination o fAsbestos An October 4,1978 letter from Ameron to one of its customers stated that its plan was to eliminate asbestos from the Series 4000 and 5000 flanges by the first quarter of 1979, and pipe components thereafter. Ameron claimed that normal shaving of the pipe did not expose any asbestos fiber. In the letter Ameron also stated that it cannot provide a recommendation to its customers on ventilation because of the many different conditions that might exist on a jobsite, but it noted, Based on tests conducted by an independent occupational health consultant at our factory and on jobsites, the asbestos dust which results from cutting or sanding our product, when cutting and sanding is done in accordance with our installation instructions, is within the limits established by OSHA.64 This was also Ameron's official response it gave to customers who were concerned about the asbestos in its products.65 With its response, Ameron also enclosed a copy of the Kerr-McGee Chemical Corp. study 61 Q:\ASBESTOS\LIABDOC\H - M\MARINE ENG1NEERING\PUBLICATI0NS\1959 VOLUME 64\1959 volume 64.pdf (p. 634) 62 Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defenslve Discovery Responses 63 Friedrich (8/30/2004) 63:4-65:6 64 SC-AIC-3000. 65 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ AMERON 0558 10 | Page Updated April 1,16 (see "Air Sampling" in Mindy's Ameron outline), MSDS's for Bondstrand 4000 and 5000, and a pamphlet titled "Dust, Fume and Mist Respirators."66 A 1983 letter confirmed that Ameron stopped producing Bondstrand with asbestos in 1979.67 An August 31,1979 letter stated that the process was on track to be completed in late fall of that year.68 Documents produced by Ameron indicate that it didn't start experimenting with substitute liners until the mid-to-late 1970's.69 Bordner testified that it was 1972.70 A July 22 1976 memo stated the goal of the liner research program was to eliminate asbestos.71 A June 22,1976 internal memo revealed that two of Ameron's corporate representatives--Dalt Bordner and Gordon Robertson--felt that the asbestos liners were what gave Bondstrand pipes their performance advantage and that a significant portion of the Bondstrand business was a result of that advantage. As the memo notes, "It seems likely, therefore, that any nonasbestos substitute we might develop would have to perform about as well as asbestos in important types of service to be considered satisfactory." During the 1970's, Bondstrand liners were made with a combination of C-veil and asbestos. Eventually, C-veil completely replaced asbestos.72 Bondstrand Application Bondstrand was used in the following industries73: Chemical Paper Mining 66 Ibid. See also \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (pgs. 168-171) 67\\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (pgs. 186-187) 68 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (p. 188) 69 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Docs produced In Spelcher\Bonstrand Products Internal Price List.pdf. See also \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\AMRN150\AMRN150-1856 thru AMRN150-2092.pdf @ AMRN150-2032; Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\AMRN150\AMRN150-2093 thru AMRN150-2608.pdf; Friedrich (8/30/2004) 55:9-23 70 Bordner (9/23/2003) 119:5-19 71 Exhibit #9 to Bordner (9/23/2003) 72 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&FI\Docs produced in Speicher\Bonstrand Products Internal Price List.pdf @ AMRN150-1909; AMRN150-1923--AMRN150-1928 73 SC-AIC-1550 (p. 5) 11 | Page Updated April 1,16 Petroleum Production Oil Refineries Food-related industries Marine applications74 Electrical Water/Sewage Condensate lines Nuclear Energy Bondstrand's suggested applications were fresh/salt water lines, tanker vent lines, product pumping lines, gaging tubes, sea water pumping lines and handrails.7576 Logos .FIB ER G L A SS REIN FO RC E P LA STIC P IP E 76 74 Q:\ASBESTOS\LIABDOC\H - M\MARINE ENGINEERING\PUBLICATIONS\1959 VOLUME 64\1959 volume 64.pdf (p. 634) 75 Q:\ASBESTOS\LIABDOC\H - M\MARINE ENGINEERING\P&H\Log Books\1959\4 April 1959 ocr.pdf (p. 35) 76 SC-AIC-1550 77 SC-AIC-2425 12 I Page Pictures78 Updated April 1,16 78 Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\PID\Bondstrand Photos from ESL visit. See also Ameron photos from brochures @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\PID\Brochuresfrom Old Ameron Site 13 Updated April 1,16 14 | Page Updated April 1,16 IOO0M& VrCDK did ^ s ml wi#> sp-ostei spoil# s fe is im 0 ?*t9 flan ^aas m mi at pips- 15 | Page Updated April 1,16 PIPE INSERTED info fitting and pressed firmly so that end of., pipe contact bottom of socket. Same principle Is used for elbows* tees and - ofher fecking-wedtge fittings79 79 \\simmons\scanned\ASBESTOS\LIABDOC\H - M\MARINE ENGINEERING\PUBLICATIONS\1959\9 September 1959 ocr.pdf (p. 106/108) 16 | Page Updated April 1,16 81 Q:\ASBESTOS\LIABDOC\N - U\POWERPOINT PRES\Asbestos Contaning Product Identification ll-2 4 -0 9 [l] by Placitella pdf (p. 280) 17 | Page Updated April 1,16 18. | Page Updated April 1,16 19 | Page Updated April 1,16 20 | Page Updated April 1, 16 82 Q:\ASBESTOS\EXPERTS\_ P Experts\_Longo-Hatfield-MAS\201111 00 Bondstrand Pipe Cutting, Sanding and Cleanup\REPORT 21 | Page Updated April 1,16 83 Ibid. 22 | Page Updated April l, 16 84 Ibid. 23 | Page Updated April 1,16 Photograph M Pine Section Labeled Samnfc 019I4K . V ip; n f lnm*r ^sirl^s**** 85 Ibid. 24 | Page Updated April 1,16 86 Ibid. 25 | Page Updated April 1,16 RP-6A Adhesive The RP-6A and the RP-105 adhesives were manufactured to be used with the asbestos-containing Bondstrand pipes and fittings. The RP-6A adhesive was used with the 4000 series.87 The adhesive was a black, chemically resistant epoxy formulated for use with Bondstrand pipe up to a maximum service temperature of 200F.88 RP-6A contained 5% asbestos.89 It was manufactured with JM 7TF-1 asbestos.90 The technical sheet that Ameron supplied with this product did not contain a warning about asbestos.91 It was available in 3 and 6-oz kits.92 RP-105 Adhesive The RP-105 was a polyester adhesive that was used with the Bondstrand 5000 series pipes, fittings and flanges. The adhesive consisted of two components, the resin base and the catalyst powder, which were mixed only after the pipe and the fittings were ready to be assembled.93 The amount of asbestos in this product is not known, although Ameron claims that it was a very minor percentage.94 The resin base was beige, the catalyst powder was gray and the mix was black. The kits were available in 6-oz. or 3-oz., depending on the diameter of the fittings and the pipes being joined. The contents were added to a large container and stirred carefully and thoroughly for at least 1 minute, or until uniform and the mix had turned black.95 For assembly instructions, see SC-AIC-2731. 87 Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses 88 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ AMERON 0194 89 Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses 90 Bordner (6/17/2003) 27:1-10; 32:4-11 91 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ AMERON 0194 92 Ibid. 93 Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses. See also O:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Bondtstrand Brochure.pdf (pgs. 19-20) 94 Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#31) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P8tH\Defensive Discovery Responses 95 Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P81H\Bondtstrand Brochure.pdf (pgs. 19-20) Updated April 1,16 The instruction manual for this product had a caution warning about breathing dust, but no indication that it contained asbestos.96 Use o fAsbestos Material in Bondstrand Flanges The instructions for the RP-48 Epoxy Adhesive, which was used in the bell and spigot assembly of Bondstrand pipe and fittings, calls for a blanket of asbestos material or fiberglass insulation for the flange mounting. A rolled blanket material was inserted into the pipe. The space inside the rolled blanket was filled with the asbestos material to insure that the blanket remained snugly against the inside of the joint surface.97* Insulated Bondstrand Pipeline The Bondstrand 2000 series pipe (non-asbestos) was used for steam condensate transfer lines. Either the 2000 fittings or the 4000 fittings (asbestos-containing) could be used. The technical data sheet for this product stated that the pipes could be insulated or not insulated depending on the service requirements.qa Asbestos Suppliers for Bondstrand Asbestos Mat (Felt) During the years when Ameron used an asbestos-containing mat in the Bondstrand pipe, Bordner testified that Special Electric was the only supplier of the mat material. Special Electric purchased the raw asbestos fiber used to make the mat material from NAAC.99 However, the minutes of the special meeting of NAAC directors on December 11,1958 indicate that a company called Plastics and Fibers, Inc. out of South River, NJ made the asbestos mat for Ameron. The minutes of the meeting also indicate that Plastics and Fibers, Inc. was in the process of being sold or merged with another (unnamed) company. The asbestos fiber used for the mat was supplied by NAAC.100 96 ibid. 97 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CpRP\P&H\AMRN150\AMRN150-1671 thru AMRN150-1854.pdf @ AMRN150-1834 qo Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Bondtstrand Brochure.pdf (pgs. 185-187) 99 Bordner (9/23/2003) 47:5-9; 59:22-60:11; 183:5-25; 237:14-23; sc-aic-1710 100\\simmons\scanned\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\GALIHER\27 CDs from Galiherfrom Jim Walker\NAAC 68B\Johns Manville Corp Civil Action\Johns Manville Corp Civil Action_OCR.pdf (pgs. 308-310). Updated April 1,16 The minutes of a February 22,1962 meeting note that the plant in Mundelein, IL was being used to make the asbestos mats for Amercoat in California. This was the plant's primary function and business.101 A September 18,1964 internal NAAC memo indicates that a plant was established in Mundelein, IL to produce the asbestos mats for Amercoat. The memo also notes that this business will end soon because Amercoat planned on changing its pipe process in early 1965 from the use of blue asbestos mat to an extruded composition of its own manufacture, which would include blue asbestos.102 According to Dalt Bordner, Ameron eventually bought the equipment from Special Electric to make the mat itself. This was possibly in the late 1960's.103 The notes of the annual Special Electric meeting on May 28,1966 indicate that Amercoat of Brea, CA purchased the blue asbestos felt plant from NAAC.104 The May 23,1970 minutes of the annual meeting of directors of Special Asbestos Co., Inc. note that Amercoat was the prime producer of blue felt in the United States, and consequently, charged an inflated price for the product.105 Sales from Special Electric to Amercoat/Ameron See Exhibits #11, 15, and 15 to Robert Carlson deposition (9/30/2003) \\simmons\scanned\ASBESTOS\DEPOS\1P&L DEPOS\Exhibit A - P & L Transcripts for DE disclosure 2012 01 20 - Frary\SPECIAL ELECTRIQHEIDER, FREDERICK 2003 10 01\Exhibits\2.pdf Cape Asbestos On July 18,1972, Ameron sent a letter to Cape Asbestos stating that the blue asbestos fiber mat used in the production of Bondstrand had previously been manufactured at Ameron's plant in Ardmore, OK. Since the plant had recently been sold, Ameron could no longer get that product. Ameron inquired if Cape could supply annually 20K-30K lbs. of crocidolite asbestos to be delivered to its plants in Brea, CA and Buffalo, NY.106 101 Ibid., pgs. 313; 329-331. See also \\simmons\scanned\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\WALKER LF\ORIGINAL NAAC BOXES (WLF)\NAAC Documents\Complete\lmages\Box027\Dir01\NAAC-SF-0005131.pdf (pgs. 2-4) 102 Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\LIABILITY OUTLINES\Chemical Pipe Fiber Suppliers (Summary by Karoline). See also \\simmons\scanned\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\GAUHER\27 CDs from Gallher from Jim Walker\NAAC 64A\Business Procedures Flle\Business Procedures File_OCR.pdf 103 Bordner (2/23/2007) 41:20-42:14 104 \\simmons\scanned\ASBESTOS\EXHIBITS\TEXT SEARCHABLE\N-Z\SPECIAL ELECTRIC COMPANY\SC EXHIBITS\SC-SEC2540\Bates Stamped Documents SIRA 9659 - 014302\Special Electric documents produced in Sira 07-07-2009 BATES# SIRA 12401 - SIRA 13625.PDF @ SIRA 13066-69 105 \\simmons\scanned\ASBESTOS\LIABDOC\N - U\SPECIAL ELECTRIC\P&H\Sira Docs\Pertlnent MSJOP Exhibits as Individual Files\40-QQQ. Minutes SE Shareholders 1970.pdf 106 \\simmons\scanned\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\GALIHER\27 CDs from Galiher from Jim Walker\NAAC 64B\General Amercoat Corporation 1972\General Amercoat Corporation 1972_OCR.pdf (pgs. 12-14) 28 | Page- Updated April 1,16 JM The mat material has also been described as felt. In 1973 JM supplied Ameron Pipe Coatings Division with pipe line felt pallets. Some of the invoices are for blue flag. It's not clear if these were asbestoscontaining.107 Cellulo A material procurement sheet produced by Ameron, dated May 1973, has Cellulo as a supplier of Asbestos mat.108 North American Asbestos According to NAAC invoices, Ameron purchased several thousands of tons of blue asbestos fiber between the years of 1963-1978. See "Ameron NAAC Invoices" in liability documents. NAAC documents show that Amercoat purchased blue felt (Noramite) and was considered one of NAAC's high volume customers.109 An Amercoat promotional article (year is redacted) indicates that Ameron used NAAC Noramite crocidolite in the manufacture of Bondstrand 5000 series. The plant showcased in the article (also redacted) was a chlorine and caustic soda plant.110 A similar promotional article from Plastics World in October 1963 describes how 2200' of Bondstrand 4000,12" in diameter, was installed as a continuous section in Shell Chemical Company's Woodbury, NJ plant. This article also states that Ameron's Bondstrand pipe was made with NAAC's Noramite asbestos fibers.111 NAAC documents also show that Ameron purchased several thousand pounds of blue asbestos yarn during the 1970's.112 107 Q:\ASBESTOS\LIABDOC\H - M\JOHNS MANVILLE\INVOICES &-OR SALES\JM SALES\JM US Fiber Sales 2011 05 25\CRMC Denver Files - MT-KAZAN-FIBER-000001-151977\CRMC Denver MT-KAZAN-FIBER-022125-079041\MT-KAZAN-FIBER-038776MT-KAZAN-FIBER-038991.PDF (pgs. 139-147) 108 sc-aic-2120; sc-aic-2180 109 Special Electric documents produced in Sira 07-07-2009 BATES# SIRA 12401 - SIRA 13625.pdf (SIRA 13314-15) @ Q:\ASBESTOS\LIABDOC\N - U\SPECIAL ELECTRIC\KAZAN MCCLAIN\2010 01 CD 110 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (p. 159) 111 CON 0380 112 sc-aic-2150. See also the following: \\simmons\scanned\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\WALKER LF\ORIGINAL NAAC (WLF) Scanned by Mayer Brown 2013 09)\005\0029229.pdf; \\simmons\scanned\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\GALIHER\27 CDs from Galiher from Jim Walker\NAAC 58B\Garlock lnc\Garlock lnc_OCR.pdf (pgs. 552-554); Q:\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\GALIHER\27 CDs from Galiher from Jim Walker\NAAC 63A\Japanese Yarn and Cloth Customers\Japanese Yarn and Cloth Customers_OCR.pdf; Q:\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\WALKER LF\ORIGINAL NAAC BOXES (WLF)\NAAC Documents\Complete\lmages\Boxl02\Dir03\NAAC-SF-0043805.pdf; Q:\ASBESTOS\LIABDOC\N - U\NORTH 29 | Page Updated April 1,16 Blue asbestos was also shipped to Ameron's Irwindale, CA and Azusa, CA facilities.113 Crocidolite Paper When Ameron switched to the paper material for the Bondstrand liner in the early 1970's, it purchased the asbestos paper from Mead, and like the mat material, the paper also contained crocidolite asbestos.114 Mead purchased fibers from Special Electric, NAAC and JM.115 The crocidolite paper that Ameron used was 100% blue asbestos.116 The former operations manager of Mead declared in an affidavit that the Specialty Paper Division of Mead manufactured an asbestos-containing pipe liner paper on a special order basis exclusively for Ameron in Brea, CA, beginning in late 1972 and ending in 1977. This paper was used to line the interior ' of certain Bondstrand pipes, although it was not used in pipe elbows, joints, and other bends.117 According to Mead's corporate representative Dirk Krouskop,the crocidolite paper that was sold to Ameron came on small rolls--almost like toilet paper rolls, although the actual width of the product was much wider. The rolls came in widths of 3.6" and 5.7". The paper was shipped to Ameron in cartons, with several rolls in each.118 However, purchase documents between Ameron and Mead show that the paper Mead shipped to Ameron was much bigger than toilet paper rolls. These documents show that the paper was more like 25" wide.119 The following is a summary of the available correspondence between Mead and Ameron120: 8/16/1972- Mead memo regarding Ameron's request of sample rolls similar to the samples, that Mead made for NAAC. Ameron requested rolls with a fiber content of 100%121 AMERICAN ASBESTOS CORP\WALKER LF\ORIGINAL NAAC BOXES (WLF)\NAAC Documents\Complete\lmages\Boxl23\Dir01\NAAC-SF-0077751.pdf; Q:\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\WALKER LF\ORIGINAL NAAC BOXES (WLF)\NAAC Documents\Complete\lmages\Boxl23\Dir01\NAAC-SF0077785.pdf; Q:\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\WALKER LF\ORIGINAL NAAC BOXES (WLF)\NAAC Documents\Complete\lmages\Boxl23\Dir01\NAAC-SF-0077786.pdf; Q:\ASBESTOS\LIABDOC\N - U\NORTH AMERICAN ASBESTOS CORP\GALIHER\27 CDs from Gallher from Jim Walker\NAAC 74A\PO 2873\PO 2873_OCR.pdf 113 SC-DH-0250 (p. 21) 114 Bordner (9/23/2003) 55:23-56:4; 58:11-59:2; 59:10-13 Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\LIABILITY OUTLINES\Chemical Pipe Fiber Suppliers (Summary by Karoline) 116 Deposition testimony of Dennis Hankey (3/2/2011) 37:4-11 117 Q:\ASBESTOS\LIABDOC\H - M\MEAD WESTVACO CORP\AFFIDAVIT\HANKEY, DENNIS DECLARATION 118 Deposition testimony of Dirk Krouskop (5/30/2014) 362:3-365:10 119 SC-AIC-2605 120 Unless otherwise cited, see Q:\ASBESTOS\LIABDOC\H - M\MEAD WESTVACO CORP\AFFIDAVIT\HANKEY, DENNIS DECLARATION 30 | Page Updated April 1,16 11 /21 /1-972- Trial request from Ameron for 5000 lbs. of asbestos paper 11/29/1972- Memo regarding the trial run 12/13/1972- Correspondence regarding specifications for the paper1222 12/21/1972- Internal Mead memo noting that Ameron is satisfied with the asbestos paper product123 1/3/1973- As a result of successful trial evaluations by Ameron, it placed a 5,000-lb order for 100% blue asbestos paper from Mead.124 1/18/1973- Mead declines to produce asbestos mat material for Ameron125 1/23/1973- Letter from Mead to Dalt Bordner of Ameron stating that Mead will attempt to produce Ameron's 10,000-lb order of crocidolite asbestos paper as closely as possible to the 5,000-lb order Ameron placed earlier that month.126 3/7/1973- Mead memo regarding Ameron's request for another 20,000-lbs of blue asbestos paper.127 4/9/1973- Letter from Mead to Dalt Bordner re test results of 100% blue asbestos paper using Ameron's specifications.128 1/9/1975- Correspondence between Ameron and Mead about new binder for use with the crocidolite asbestos paper129 4/14/1975- Mead responds to Ameron's request for MSDS's for asbestos paper. According to Mead, the forms that Ameron was requesting were not applicable for description and status of paper materials. Instead, Mead issued a statement claiming that its products were manufactured in compliance with OSHA standards.130 4/12/1976-11/23/1977- Other purchase documents between Mead and Ameron regarding the sale of asbestos paper.131 121 Exhibit #13; #14 to Dennis Hankey (3/2/2011); sc-aic-1950 122 sc-aic-2010 123 sc-aic-2020 124 Exhibit #29; #30 to Dennis Hankey (3/2/2011) 125 sc-aic-204. 5r 126 sc-aic-m205r 5r 127 Exhibit #39 in Dennis Hankey (3/2/2011) 19R sc-aic-2095 129 SC-AIC-2375 130 SC-AIC-2415 131 SC-AIC-2605 31 Page Updated April 1,16 There are several other correspondence documents and invoices referenced in a Panatier deposition of Mead's corporate representative taken on 5/30/2014132: 3/6/1973- Telephone order from Ameron for 10,000-lbs of three and three-fifth inch crocidolite paper and 10,000-lbs of five and seven-tenths paper. 11 /7/1973- Mead is confident that it can produce crocidolite per commercially if Ameron is able to achieve successful results with the product.133 1/21 /1975- Ameron ordered 4,956-lbs and 12,279-lbs of crocidolite paper. 3/30/1974- Ameron ordered 8,600-lbs of crocidolite paper. 1/21 /1975- Ameron ordered 17r397-lbs and 7820-lbs of crocidolite paper. 1/28/1975- Order for Ameron for 1,692-lbs of crocidolite paper. 2/18/1975- Two orders for Ameron-one for 10,000-lbs and one for 20,000-lbs. 12/15/1975- Letter from John Nolan of Mead to Phil Forbes of Ameron stating that Mead will buy 25,500-lbs of crocidolite asbestos from Ameron if Ameron purchases the corresponding poundage of paper. 4/13/1976- Mead document indicating Ameron ordered 10,000-lbs of crocidolite paper. 4/16/1976- 10,000-lbs each for two different widths of crocidolite paper. 7/29/1976- Three different orders for crocidolite paper totaling 22,667-lbs. 4/21 /1977- Ameron received 13,393-lbs of crocidolite paper. 6/30/1977- Ameron ordered 15,000-lbs of crocidolite paper. Ameron was the only customer that Mead produced the crocidolite asbestos paper for.134 Bondstrand Manufacturing Process135 To assemble Bondstrand pipe, Ameron workers performed the following steps: Crocidolite asbestos felt liner was rolled over a 20x4 table. Dirk Krouskop (5/30/2014) 370:3-388:7 133 sc-aic-2210 134. Dennis Hankey (3/2/2011) 77:4-16 135 Friedrich (6/6/2003); 75:24-89:9 32 | Page Updated April 1,16 The material was saturated with an epoxy resin. 4-5 workers rolled the finished material onto a steel mandrel. A crane transported the mandrel to a winding station, where fiberglass roving was helically wound on the outside of the liner material. The pipe was then moved again by a crane to a cure oven. Curing the resin in the pipe gave it its rigid structure. The pipe was then hydraulically stripped. During this process, a wet-saw was used to cut off the ends. Bordner testified that the ends were cut with either a carbide or diamond blade spinning at high velocity and going around the pipe to cut off the ends. He testified that Ameron used water during this particular operation to keep the dust levels down.136 After the pipe was tested, one end of it was mechanically shaved in preparation for bonding in the field. The other end was sand-blasted. Friedrich testified that the crocidolite liner was sandblasted in the female bell area of the pipe to prepare for bonding.137 o He also testified that prior to the addition of c-veil, if the felt material was sanded, asbestos fibers were released. This would have been prior to 1973.138 In order for the felt-material to fit to the dimensions of the pipe, it would have to be cut. Note that once Ameron switched to a more efficient mandrel machine, it switched from the mat to asbestos paper because the paper could be automated.139 Friedrich testified that the blue asbestos paper would be loaded onto a carriage that ran the paper through a resin bath, if the paper wasn't already pre-saturated. Once the paper was saturated with resin, it was then cut to fit the dimensions of the pipe by breaking the paper on the machine and tearing it by hand. The c-veil was first wound onto the pipe and then the layer of asbestos paper, which was then cut to fit the length of the pipe. The glass roving was then wound on the outside for structural reinforcement.140 For detailed testimony of how the pipe was made by a former Ameron worker, see the deposition testimony of Russell Ladd (3/27/2002) 390:23-397:13. According to Ladd, all the workers along the line were exposed to asbestos dust when another worker would cut/grind the pipe during the manufacturing process. Ameron had the capacity of making around ten pipes per hour. 136 Bordner (9/23/2003) 78:11-79:12 137 Friedrich (10/3/2003); 152:4-9 130 Friedrich (4/4/2005) 125:3-126:5 laq Friedrich (8/30/2004) 62:13-63:3 140 Friedrich (8/30/2004) 66:10-71:5 33 | Page Updated April 1,16, Bondstrand filament wound fittings were made in a similar fashion as the pipe. Some fittings were also compression molded. These were also made out of crocidolite asbestos. Bondstrand Assembly/Installation Bondstrand was assembled in the following manner141: The desired length was measured and scribed using a pipe fitter's wrap-around. Pipe was cut using a standard hacksaw or abrasive wheel. The cut end of the pipe was shaved prior to bonding. The spigot ends, prepared at the factory beforehand, were re-sanded before assembly. Fittings and sockets were also sanded prior to assembly. Sanded sockets and spigots were wiped with a clean, dry cloth to remove dust particles from the sanding operation. Instructions emphasize that it was essential that all dust be removed. Bondstrand adhesive was mixed thoroughly. A thin layer of adhesive was applied to the surface of the socket, including the pipe stop. Adhesive was liberally applied to the entire spigot surface and a thin layer to the cut edge of the pipe. Adhesive was thoroughly worked into the shaved surface of the spigot with a troweling action. Pipe was inserted slowly into the socket until the spigot end rested firmly against the pipe stop. Assembly was examined for proper alignment and seating. Joints were cured before pipe was placed into service. Later instructions were modified to include a sabre saw to cut the pipe.142 A September 1959 advertisement in Marine Engineering noted that the pipe was. easily cut and joined in the field, requiring no special tools. 141 SC-AIC-1980 142 SC-AIC-2425 34' | Page Updated Aprii 1,16 The following Bondstrand advertisement illustrates how easy and economical it was to install Bondstrand piping: 35 | Page  t Updated April 1,16 143 See the following: sc-aic-1980 and \\slmmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL 36 | Page Updated April 1,16 ASSEMBLE BONDSRANO PIPE AND QUICK-LOCK FITTINGS IN THE FOLLOWING MANNER. * fttauve ra r tiu rs(n fwn p ip e am p to to tojrfett. Sand pH*Kl* Maty ill fWnd until U P S* will Ser I ito m p it> tn pip* stop I. ths (tiilg, mtln sr HSinlfc Use fm um utt MwiuaBr- eparated band ih r a r m el*W te gwa*r **H *n or SI) wtJrnsry small l i lt m tA r stippcd with a d ial (.oMector, CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 2011 12 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf (p. 143) 37 I Page Updated April 1,16 144 Bondstrand was marketed as a cost-saving alternative with an assembly process that would "result in substantial savings in installation costs" for its customers. One of these cost-saving measures was that the "pipe was simply cut to size on the job using an ordinary hacksaw." A promotional brochure claimed that this time-saving technique allowed the job of installing Bondstrand to be made in onefourth the time as ordinary steel pipe.4145146 The following Instructions and pictures are taken from manuals written after asbestos was removed from Bondstrand, but they nevertheless gi\7e a good idea of how the product would have been used/manipulated by end users: 146 144 Ibid., p. 149 145 sc-aic-1550 (p. 4) 146 FP170A @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\PID\Brochures from Old Ameron Site 38 Page Updated April 1,16 147 Ibid. Updated April 1,16 149 An article titled "How About a Ph.D. in BONDSTRAND" printed in a 1974 edition of Ameron's The Bondstrand Pipeline explained that Bondstrand training sessions were regularly held for customers to make the installation of Bondstrand as easy as possible, To make sure Bondstrand customers know the proper steps for assembling and installing our pipe, we regularly conduct training sessions at many customers' plants for their workmen. These sessions are designed to show the workmen how to correctly assemble FRP pipe and fittings and how to make reliable, fail-safe joints.1489 148 FP170F @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\PID\Brochures from Old Ameron Site 149\\simmons\scanned\ASBESTOS\UABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 ' SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ AMERON 0288-0293 40 | Page Updated April 1, 16" Star-Kist Foods, Inc., located near Long Beach, California, was the site of a recent Bondstrand training session. Eight men from Pipefitters Local #250 spent more than two hours learning the Bondstrand method for installing FRP pipe. All facets of installing Bondstrand were demonstrated including such fine points as how to adjust the shaving tool for proper tolerances and how to properly use the heating blanket when curing joint adhesives. The session was conducted by our Los Angeles Bondstrand distributor, Harrington Industrial Plastics. Bill East, the Harrington salesman was in charge of the session. After demonstrating all the proper procedures, Bill helped all the "trainees" actually perform the assembly and joining steps themselves.150* The picture that accompanied the article showed several men standing around a Bondstrand pipe while it was being shaved. While it's unclear if the actual shaver is wearing a mask, the men standing directly next to him are not: Bit! E m fr.} o f th n fn p o n Industrial Plastits and Bondstrand `'trainees** took m in a demonstration o f the use o f Bondstrand Pipe Sharer* Ameron recommended its customers a Bondstrand Pipe Shaver, which it also sold. The shaver was a tool that shaved the outside of the pipe at the spigot end to match up with the female bell.152 In July 1976 Ameron sent an interoffice memo noting that the operating instructions to the shaver were revised to include caution statements, 150 SC-AIC-2240 151 Ibid. 1R2 Friedrich (4/4/2005) 103:6-13 41 | Page Updated April 1,16 On approval, these w ill be printed on adhesive labels and added to all new shavers prior to shipment. A supply of caution labels w ill also be furnished to Bondstrand field service and sales personnel for application to shavers now in use by customers. We do not propose to make the major effort required to identify ail owners and locate all shavers for this purpose. A le tter w ith labels to all catalog holders is possible.153 In a promotional article on Bondstrand, Arrteron claimed that the customer "will need Bondstrand's pipe shaver for shaving pipe ends to correct joint diameters."154 The pipe shaver was called the Bondstrand M74 Pipe Shaver.155 Even though the picture below is taken frm a more recent installation manual after Bondstrand no longer contained asbestos, note the amount of dust created: 153 SC-AIC-2670 154 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ AMERON 0213 155 Ibid., @ AMERON 0240-0243. See also \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\AMRN150\AMRN 150-1671 thru AMRN150-1854.pdf @ AMRN 150-1839-AMRN 150-1842 and FP696A@ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\PID\Brochures from Old Ameron Site 42 | Page Updated April 1,16 156 156 FP170F @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\PID\Brochures from Old Ameron Site 43 | Page Updated April 1,16 Sanding o f sp ig ot 157 Ameron photos from brochures @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\PID\Brochures from Old Ameron Site 44 Page. Updated April 1,16 In some situations, Ameron provided field service technicians for the installation of Bondstrand piping.158 Ameron issued a Bondstrand technical service agreement to its customers whereby Ameron would provide a field service technician. The technician provided technical advice and instructional services. The agreement required the owner/contractor/installation sub-contractor to indemnify and hold Ameron harmless from any and all liabilities which may arise by virtue of furnishing of such Field Service Representative's rendering of advice.159 Friedrich testified that field-service technicians could be hired by the customer to go onsite and provide training on Bondstrand installation. This was to ensure that Bondstrand pipe was installed properly.160 A former Ameron sales manager testified that, upon the purchase of any Bondstrand product, Ameron offered free technical service for job start and proper instruction for the workers installing the pipe. Included in the free technical service was a practical demonstration on how to install a pipe on-site that was led by an Ameron employee while the Bondstrand customer was present. He testified that in terms of documenting the process, the technical service representative and the Bondstrand customer would both sign off on a document indicating that they both were present on-site during the demonstration. These records were kept by Ameron.161162 In 1975 Ameron created a Bondstrand certification program designed to "provide a higher level of competence in those who install Bondstrand in the field..." The program was specifically aimed to train workers to assemble Bondstrand joints.152 Note: One particular guide for installing buried Bondstrand pipe noted that "These instructions are intended to be used as a guide and should b e am ended and expanded to m eet the requirem ents o f the specific jo b ." 163 None of the Bondstrand instruction guides during the time that the product contained asbestos had any warnings about asbestos. Bondstrand Customers/Distribution According to one of Ameron's corporate representatives (a former Bondstrand salesman), Bondstrand was only sold through industrial distributors. The authorized distributor in California was Harrington 1co * SC-AIC-2560 159 SC-AIC-0028 160 Friedrich (3/24/2011) 288:4-289:4 161 Lambly ( 6/15/2011) 89:7-91:8 162 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\AMRN150\AMRN150-1671 thru AMRN150-1854.pdf @ AMRN150-1794 163 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 2011 12 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ AMERON 0186; 0225-0234 45 | Page Updated April 1,16 Industrial Plastics. He testified that during the entire time that the Bondstrand product line contained asbestos, Harrington was the exclusive distributor for Ameron in California.164 If a customer approached Ameron, Ameron would not make a direct sale to them, but would instead refer them to Harrington.165 Ameron provided Harrington with standard Bondstrand trade literature, as well as samples of Bondstrand pipe products that were 2" in diameter and around 8" long.166 The only way that a customer in California could get Bondstrand pipe products was through Harrington.167 Bondstrand Installations Bondstrand 4000 installations: Amalgamated Sugar Company (Nampa, ID)168 o Installed in 1963. Still in use in 1974 R.D. Nixon Power Plant (Colorado Springs)169 Public Service Company of New Mexico (San Juan Station)170 Utah Power and Light (Huntington, U T)171 McAlester Fuel Co. (Kirkland Junction, AZ)172 Holly Sugar (Brawley, CA)173 o Installed in 1964 Pennsalt Chemicals Corporation (Wyandotte, Ml)174 Lambly, 6/15/2011 (19:25-22:23) 165 Ibid., 134:3-17 166 Ibid., 23:21-25:4 167 Ibid., 38:23-40:10 168 SC-AIC-2240 169 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SCV_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ 0583 1 7 0 lIU bi'dJ. 171 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\AMRN150\AMRN150-1671 thru AMRN150-1854.pdf @ AMRN150-1787 177 Ibid., AMRN150-1790 173 Ibid., AMRN150-1797 174 \\simmons\scanned\ASBESTOS\LIABDOC\N - U\PLASTIC WORLD\PUBLICATIONS\(Vol 23) Aug-Dec 1965\(voi 23) aug-dec 1965.pdf (p. 52) Updated April 1,16 o Installed throughout the early 1960's Shell Chemical (Woodbury, NJ)'J5 o Installed sometime in the early 1960's Bondstrand 5000 installations: Diamond Shamrock Oil 8t Gas Co. (Amarillo, TX)'7& o Installed in the late 1960's. Bunker Hill Company (Kellogg, ID)751677 o Installed in 1964 Cincinnati Water Works (California, OH)178 Bluebird Mine (Miami, AZ)179 o Installed in 1968 Note: Ameron produced detailed list of customers that gives information about the year, place, and type of Bondstrand product installed. This list includes military, federal and state government, chemical, petroleum and other installations. See Ameron Bondstrand List <> Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\PID Bondstrand Assembly Film Former Bondstrand salesman Neil Lambly testified that Ameron had a briefcase that contained a film strip with information about the Bondstrand product line including a description of the product and assembly instructions. Specifically, it showed how the product was fabricated and joined by using adhesive to bond the joints (note that asbestos-containing adhesive was used. See above). The film also demonstrated how the asbestos-containing fittings and flanges were assembled. A man was filmed demonstrating how to cut the pipe, although Lambly couldn't recall if he was wearing any respiratory protection. There was no caution or warning in the film about any potential hazards associated with asbestos-containing Bondstrand, nor was there any mention of asbestos. There also was no mention of 175 Q:\ASBESTOS\LIABDOC\H - M\MODERN PLASTICS\PUBLICATiONS\MAGAZINE\VOL 41-1 SEPT 1963 - FEB 1964\VOL 41-1 SEPT 1963 - FEB 1964.pdf (p. 210) 176 SC-AIC-2240 177 \\simmons\scanned\ASBESTOS\LIABDOC\A\AIVIERON INTERNATIONAL CORP\P&H\AMRN150\AMRN150-1671 thru AMRN150-1854.pdf @ AMRN150-1795 1 7 8Ib...id.. 179 Ibid., <>AMRN150-1797 Updated April 1,16 necessary precautions to take, i.e., ventilation or respiratory protection. The entire film was about 20 minutes long. If Ameron customers wanted to see the film, Ameron showed it to them.180 Bondstrand Warning Labels Ameron placed warning labels on its pipe products, fittings and adhesives in the mid-to-late 1970's.181 A Bondstrand MSDS dated 1972 carried an asbestos warning about lung cancer.182 Ameron also claims that it supplied MSDS's to its customers, which had asbestos warnings.183 A MSDS for Bondstrand 4000 and 5000 pipe and fittings stated the following, Bondstrand Series 4000 and 5000 Pipe and Fittings contain up to 5% crocidolite asbestos by weight. The limits of asbestos exposure permitted by government regulations are delineated in Section S208, Title 8 of Calif. Division of Industrial Safety Regulation. The law requires employers to maintain asbestos dust exposure below OSHA limits. Because of the many different conditions which may exist on a job site, we cannot provide a recommendation for ventilation. However, based on tests conducted by an independent occupational health consultant at the factory, the asbestos dust which results from cutting or sanding our current product, when cutting and sanding is done in accordance with installation instructions, is within the limits established by OSHA.184 MSDS's were sent to Ameron's distributors and customers "upon request."185186 Internal memos reveal that Ameron did not start placing warnings on its asbestos-containing products until the middle of 1977.185A May 1977 memo stated that asbestos-containing Bondstrand products had been labeled with the following,187 CAUTION 1Rf) Lambly (6/15/2011) 40:11-48:12 181 Static copy of DEFDOC 043836 AMERON G0129 RSP ROGS1 (#37) <Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses lOT sc-aic-0026 183 GO 129 am resp POS 12-7-04 (#49) @ Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\P&H\Defensive Discovery Responses 184 sc-aic-1920 185 Lambly, 6/15/2011 (70:6-18) 186 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 2011 12 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ AMERON 0558 1R7 SC-AIC-3000 48 | Page Updated April 1,16 This product contains asbestos fibers impregnated with resin, the inhalation of which may cause lung or other injury. Cut or sand this product only with adequate ventilation and in strict accordance with installation instructions. IF YOU DO NOT COMPLETELY UNDERSTAND THESE INSTRUCTIONS OR ARE UNABLE TO COMPLY WITH THEM. CONTACT YOUR SUPERVISOR BEFORE USING THIS PRODUCT. This warning was also on the Bondstrand 4000 and 5000 Series pipes and fittings MSDS's.188 Bondstrand molded products and filament wound epoxy flanges were coated with yellow after 1977 and also had a yellow warning label stating the following: For the proper assembly of Bondstrand Quick-Lock joints, remove yellow coating from all bonding surfaces by sanding not more than two hours prior to assembly to remove surface oxidation and to obtain surfaces suitable for bonding. Do not sand through the light gray layer underneath the yellow coating.189 Air Sampling The test results done in June are not available, but in early May 1976, Health Science Associates collected the following sample results showing high levels of asbestos fibers in the air during the cutting and manipulation of Bondstrand pipe: 188 sc-aic-1920 189 Ibid. 49 | Page Updated April 1,16 a lt li fence/ iatcs IABQRATOK K 3R? Mr. S . Bwwr Hot*: watow coMOstow corrupt Division Bspert No. : g Q 6 2 oaftt1 n d f Bate feasdes; JB ..IB ...1976 Method o f an a ly sis:: Phas. c o stru it rlcraicaav frisait Sample No. 651-2*5 651-245 BS1-247 631-246 651-245 SSL-250 SK I-2 5 1 B Sl-252 651-253 8SL-254 631-25$ Type M Bit e r m m m m W m m m Analysed fo r A sb esto s m * m m ns* m m m m m fib e rs m m m m m m m m m m Ftesu.lt ( f/ c e ) * 0 .5 S i.7 2 .8 5 3 .6 1 6 .2 1 5 .2 3 .0 1 .6 3*0 4 .4 1 .5 Beraariks: * n ite rs par cubic c e a tlM te r e f s i r R esu lts based m s i r sampling data supplied by Aa.ro** te s II. Uyreabck 10941 BlotnEeii St. Suite B Los Alamifos, C A '90720 213/430-1031 B ate: "y 1* W 8 190 The sampling also noted "excessive amounts of dust" when operations used portable saws and abrasive _ wheels.*191 In addition, in October 1977, Health Science Associates conducted a test concerning manipulation of Bondstrand pipe at Kerr-McGee Chemical Corporation in California to determine, under field iqn Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\LIABILITY OUTLINES\Somastic Research (2.2014 Mindy)\Ameron\1976 - HSA - Amron sampling data 5-10-76.pdf 191 Ibid. Updated April 1,16 conditions, worker exposure to airborne asbestos during cutting and sanding operations on Bondstrand 4000 and 5000 series pipes and fittings. The Kerr-McGee report recommended the following: stationary saws should be equipped with local exhaust ventilation; lunch areas should be isolated from asbestos cutting areas; sanding operations had the potential for greater asbestos exposures during cutting operations; significant exposure was possible due to the flapper sanding at the edge of the spigot end and that hand sanding could reduce this.192 Ameron never issued any warnings regarding high-speed abrasive wheels or flapper sanders.193 Former Bondstrand salesman Neal Lambly testified that Bondstrand 4000 assembly instructions recommended the use of flapper sanders.194 The Kerr-McGee report determined that with proper use, the exposure levels were below the OSHA and CAL/OSHA limits.195 Note: One particular guide for installing buried Bondstrand pipe noted that "These instructions are intended to be used as a guide and should be am ended and expanded to m eet the requirem ents o f th e specific jo b ." 196 The results of the Kerr-McGee report are as follows: Stationary Abrasive Wheel During Cutting of 3-inch Diameter Lined Pipe (4000 Series) 10/24/1977 Location Sample No. Duration Asbestos f/cc Personal Sample,.first KM-1 2 0.72 set Personal sample, first KM-2 2 0.72 set Personal sample, second KM-8 1 1.43 set Personal sample, second KM-13 1 1.43 set Personal sample, third KM-11 2 4.69 set iq j Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\IL 2012 06 08 MFG AROG-ADOC (#43). See also SC-AIC-2875 103 Friedrich (3/25/2011) 414:8-11 and exh. #49 194Lambly (6/15/2011) 87:14-88:3 195 Q:\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\IL 2012 06 08 MFG AROG-ADOC (#43). See also SC-AIC-2875 196 \\simmons\scanned\ASBESTOS\LIABDOC\A\AMERON INTERNATIONAL CORP\DISCOVERY\SC\_CASE SPECIFIC\IL 201112 19 SALES SAROG-SADOC (SEARS)\IL 201112 19 SALES SAROG-SADOC (SEARS).pdf @ AMERON 0186; 0225-0234 51 I Page' Personal sample, third KM-12 2 set Area sample: 10 ft from KM-4 8 saw; 90 degrees to right of cutter Area sample: welder's KM-6 8 table; 17 feet from saw, behind cutter Area sample: lunch area; KM-7 8 17 feet from saw Updated April 1,16 2.14 0.72 0.53 0.23 Stationary Abrasive Wheel During Cutting of 8-inch Diameter Lined Pipe (5000 Series) . 10/24/1977 Location Sample No. Personal Sample, first set *cutting technique different from proper procedure KM-10 Personal sample, first set ^cutting technique different from proper procedure KM-14 Personal sample, second set * proper cutting method used KM-15 Personal sample, second set *proper cutting method used KM-16 Area sample: 10 ft from saw; 90 degrees to right of cutter KM-3 Duration 7.5 7.5 9 9 9.5 Asbestos f/cc 1.33 1.33 0.79 0.95 1.05 Area sample: welder's KM-5 9.5 table; 17 feet from saw, behind cutter Area sample: lunch area; KM-9 9.5 17 feet from saw Area sample: 10 ft from KM-18 11 saw; 90 degrees to right of cutter (second set) Area sample: welder's KM-17 11 table; 17 feet from saw, behind cutter (second set) Area sample: lunch area; KIM-19 11 17 feet from saw (second set) Updated April 1,16 0.50 0.75 1.04 0.26 0.78 PortibT Abrtstw lfe--1 At Ctrr-nc&Ni C&rp_. Tran, CA OttoUr 24, 1ST? T i l l III toc*!ls70itf|st1e# S**p!e Durstton Asbestos Jto. (irtaotw) (f/CC)- Cartttnt 8 tetfe t***tar TIwk* frtpo (9000 series); tbr** cuts 0JfeCain Cotter Xjfcaa* MS * 4.0 m-2i 4 1.78 Cottles 3 focft Is U r V m 4 pip* (4800 serias); t t m cots * UtCsIm, Cotter A.Osen, Afl*t*nt QM2 IH tM Wb& Vt 4.71 - * ftbtr* 5 artcrae or longer, p*r raMe cawttwtar of If, 53 | Page Updated April 1, 16 Seadtao totratlga At arMteSa* Carp.. Trena* C4 October 24* 1377 TABLE IV Loe* ties/Oft*art pHas Staple to. Donties Asbesto* (tw it) {f/ccj* ItoaHts pipe iondlnp-both ball 4 $pl$at ndt; bell ad a tnafde flaarter spigot ead on aopa* nod 3 lata flapper lander cm, 3/B* d rill t o r (o-ZSOO RPH) Tost l i B*fcCa1s Test 2i iJteClrfa 01-24 0M3 Flifige sending 3 Inch m rn n si (4000 H as) 3,ttxfn W - 4 inch ffit flange (4090 sartas) B.NcCaSft . Ot-27 6 lads sided Hnp (pear) S.cCtB m-TS a Indi m flaaga (Sa w rits) B.HcCafn W-23 3 3*80 3 4,73 I 18.53 8td bat sanded BW baftort; osii tip fm w ai. 3" flapper andar ok 2 U S 3" .f1*pprr Sander 1% 0.35 F flipper sander 1 3/4 1*13 5* flipper saftdtr Socolor as ft na l.P. * fibers, 5 aft* or longer* par otblt astiaotar e# a ir. Ameron sent this report to customers who inquired about the health hazards associated with asbestoscontaining Bondstrand.197 5/2007 Dr. Longo Reports 197 Exhibit # 6 in Neal Lambly ( 6/15/2011) 54 | Page Updated April 1,16 Analysis of asbestos mat manufactured at Ameron's Ardmore, Oklahoma facility, in addition to one roll of small rope-like yarn purportedly used as a gap filler prior to gluing flanges together and two fiberglass-composite flanges. The mat was 100% crocidolite; the light blue yarn was 100% crocidolite and the composite flanges were 40% crocidolite and 20% anthophyllite. November 2011 Seven Bonstrand pipe samples were collected from a home. All samples contained a 30% layer of crocidolite paper..198 The strategy used to measure the samples yvas to perform typical work activity that a worker would engage in when cutting then sanding the inside surface of the Bondstrand pipe. There is also a video that shows what the pipe looked like when it was cut, as well as the excessive amount of dust it created. See Julie/Geri for a copy of the DVD. 198 Q:\ASBESTOS\EXPERTS\_ P Experts\_Longo-Hatfield-MAS\201111 00 Bondstrand Pipe Cutting, Sanding and Cleanup\REPORT 55 | Pdge Updated April 1,16 Sample # Background A-1Q-A A* 10-8 A-10-C A-10D Bondstrand Pipe Cutting of Bondsirand Pip W illi Skill Saw Analytical Data Sum mary M54152 Location * PCM F iberstoe TEM 7402 Asbestos % <0.002 <0.002 < 0.002 <0.002 0 0 -- PCME Hbtmfcc <0.002 <0,002 -- -- Area Samples A-1-A A-1-B A-1-C A-1-0 * -- * -- * --- --- Sr -- PersgnajSamgjes P-1-A (right) fWA 2.6 -- --- P-1-B (left) IWA 2.3 98.3 2.8 P-1-C (right) IWA 3.0 -- -- P-1-D (left) IWA 3.S 83.1 2.9 field Blanks PCM Fibers Counted TEM 7402 Asbestos % FB-1-1 <7 0 FB-1-2 <7 0 Fabric Samples SiffiEla# FAB-1-1 tasiiiaa. Before (Background) Asbestos Structures/2 <263 thousand Asbestos StructurestonV <283 FAB-2-2 After 53.1 million * Too heavily loaded to count ** Too heavily loaded with crocidolite fibers to count 57.2 thousand 56 I Page Updated April 1,16 Sample # Background A-20-A A-2.0-B A-20-C A-20-D Bondstrand Pipe Sanding of inside Bondstrand Pipe Analytical Data Summary AU$41SS Location PCM EM ssM TEM 7402 Asbestos % <0.002 0 <0.002 0 <0.002 -- <0.002 -- PCME Fibers/cc <0.002 <0,002 --- Area Samples A-2-A -2-B. A-2-C A-2-D 0-2 100 0.2 0.3 100 0.3 0.2 -- -- 0.2 -- -- Personal Samples P-2-A (right) IWA 09 -- -- P-2-B (left) IWA 1.1 100 1.1 P-2-C (right) IWA 0.9 -- P-2-D (left) IWA 0.5 100 0,5 Field Blanks FB-2-1 FB-2-2 Fabric Samples Sample # Location FAB-2-1 FAB-2-2 FAB-2-3 FAB-2-4 Before (Background) After Oust Rag (before) Oust Rag (after) PCM Fibers QouqM <7 <7 TEM 7402 Asbestos % 0 0 Asbestos Structurea/ft2 <438.5 thousand 95.3 million <309.5 thousand 69.9 million Asbestos Structures/cm2 <472 102,6 thousand <333.20 thousand 721.1 thousand 57 I Page Updated April 1,16 Sample # Background . A-30-A A-30-B A-30-C A-30-D Bondstrand Pipe Sanding of Inside Bondstrand Pipe II A nalytical Data Summary M54171 Location PCM Fibers/cc TEM 7402 Asbestos % IWA 0.002 0 IWA ' 0.004 0 IWA 0.005 -- IWA 0.002 - POME Frbers/cc <0,002 <0.004 -- -- Area Samples A-3-A IWA 2.2 100 2.2 A-3-B IWA 2.2 94 2 1 A-3-C IWA 2.1 -- A-3-D IWA 2.5 -- -- Pedonai Samples P-3-A (right) IWA 8.4 97 8.2 P-3-B (left) IWA 12.6 -- -- P-3-C (right) IWA 16.1 98 15.8 P-3-D (left) IWA * -- -- Field Blanks FB-3-1 FB-3-2 PCM Fibers Counted - <7 <7 TEM 7402 Asbestos % 0 0 Fabric Samples Sana s i FAB-3-1 Location Before (Background) Asbestos Structures^ <250 thousand FAB-3-2 After 43.8 million FAB-3-2 Dust Rag (after) 2,3 billion ` Sample voided-sampling tube came off sampling pump Asbestos Structures/cm2 <289,7 47.2 thousand 2.5 million 58 | Page Updated April 1,16 Bondstrand Pipe Cleanup After Cutting and Sanding of Bondstrand Pipe Analytical Data Summary M54176 Sample# Background A-40-A A-40-B A-40-C A-30-0 location PCM Fibers/cc 0,003 0.003 Q.003 0,003 TEMI 7402 Asbestos % 11 43 -- .... PCME Fibers/cc 0.0003 0.001 -- ... Area Samples -4-A iWA 0.9 100 0,9 A-4-B IWA 1,2 84 1.0 A-4-C IWA 0.6 -- --- A-4-0 IWA 1.1 -- Personal Samoles P-4-A (right) !WA 1.2 -- -- P-4-B (left) IWA 1.3 38 11 P-4-C (right) iWA 1.1 P-4-D (left) IWA 1.1 100 11 Field Blanks F8-4-1 FB-4-2 PCM Fibers Counted <7 <7 TEM 7402 Asbestos % 0 0 Fabric Samples Sam ple# FAB+1 FA8-4-2 Location {Background} After Asbestos Struclures/ft2 8 . 4 thousand 332 midton Asbestos Stmctures/cm2 <673.3 357,4 thousand 59 I Page