Document OoXnn0bX3mzqZ5y2pj5Vkjyj

SUPREME COURT OF THE STATE OF NEW YORK SEVENTH JUDICIAL DISTRICT In Re: Seventh Judicial District Asbestos Litigation SEVENTH JUDICIAL DISTRICT ASBESTOS LITIGATION This Document Applies to: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ONTARIO ANNE M. TINKER, Executrix of the Estate of TIMOTHY W. TINKER, Deceased, and Individually as the Surviving Spouse of TIMOTHY W. TINKER. Plaintiff, CASE NO. 83778 vs. A.E. CLEVITE, INC.,; et al.. Defendants DEFENDANT MACK TRUCKS, INC.'S SUPPLEMENTAL RESPONSES TO PLAINTIFF'S SUPPLEMENTAL REQUEST FOR INSPECTION AND PRODUCTION OF DOCUMENTS Defendant, MACK TRUCKS, INC. ("Mack Trucks"), serves this Supplemental Response to Plaintiff's Supplemental Request for Inspection and Production of Documents dated June 3, 1997. INTRODUCTION AND GENERAL RESPONSE Responses provided herein have been prepared pursuant to a reasonable and duly diligent investigation and search for the information requested. In conducting its business, Mack Trucks has each year created thousands of documents that have been kept in numerous locations and have been moved as the organization changed and as employees changed jobs. Accordingly, Mack Trucks cannot represent that these re sponses contained herein provide all information requested; rather, these responses reflect information obtained before this date by Mack Trucks pursuant to a reasonable and duly diligent search and investigation in those areas where responsive information was expected to be found. To the extent that the request purports to require more, Mack Trucks objects on grounds that include that compliance with the request would impose an undue burden and expense. These responses are intended to be accurate to the best of Mack Truck's knowledge and belief as of the time of the service of this response. To the extent that the responses are not consistent with any previous responses made in other cases, these responses are intended to supersede such earlier responses. Mack Trucks reserves the right to supplement these responses should it discover new information. Some of the discovery requests ask for "air documents that may pertain to a subject. Mack Trucks objects to requests for any and all of something on grounds that the requests are overly broad and unduly burdensome. You have served Mack Trucks with discovery and yet you already may have some pertinent information or documents, perhaps even some information or documents not received from Mack Trucks. Mack Trucks objects on the grounds that it would be less burdensome, more convenient and less expensive for you to identify what documents you already have that fall within the scope of these requests. This would accomplish several purposes: (a) it would obviate Mack Trucks having to search 2 for and copy documents already in your possession; (b) it would enable Mack Trucks to use the documents provided by you as guides in looking for related material; and it would, if your purposes were to obtain authentication of particular documents, enable Mack Trucks to authenticate the copies provided by you without having to conduct an uninformed search for those documents in Mack Trucks' files. Mack Trucks further objects to requests where the matter sought is neither relevant to the subject matter involved in the pending action nor reasonably calculated to lead to the discovery of admissible evidence. PEFiNlIlQNS As used in Mack Trucks' objections to these requests: (I) "Lack of Relevance" means that a request calls for information which is not relevant to the subject matter of this action and is not reasonably calculated to lead to the discovery of admissible evidence; (ii) "Unduly Burdensome" means that it would be oppressive, time consuming or expensive to require Mack to compile and furnish the information in light of the degree of its relevance and materiality, if any; (iii) "Overly broad" means that such request is overly broad as to scope, time or location; (iv) "Lack of Particularity" means that a request does not state with reasonable particularity the information to be furnished, is vague and ambiguous or incomprehensible; 3 (v) "Improper Assumption" means that a request assumes facts which are not true or accurate; (vi) "Improper Opinion" means that a request improperly calls for an opinion, conclusion, contention or inference; (vii) "Privileged" means a request calls for information protected by the attorney/client privilege or the work-product doctrine or the rule protecting materials prepared in anticipation of or in connection with litigation; and (viii) "Premature" means that a request calls for opinion or contention that relates to fact or the application of law to fact and should not properly be required to be responded to at this time. These comments and objections are incorporated into each Mack response set forth below as if they were set forth in their entirety as they apply to each response. Responses made after objections are not waivers of objections. RESPONSES 1. All asbestos-containing brake and brake products (including but not limited to brake shoes and brake linings, brake pads and brake assemblies), and clutches, clutch facings, and any other clutch products manufactured, distributed, sold or relabeled by Mack Trucks or placed in their vehicles (except automobiles) between 1970 and 1980. RESPONSE: Objections: unduly burdensome, overly broad, lack of particularity. Subject to and without waiving these objections, Mack Trucks states that, after a reasonably diligent search, exemplar brake components containing asbestos sold during 1970-1980 have not been located. 4 Date 33,1333. >, Florida TO: Michael A. Ponterio, Esq. Lipsitz & Ponterio, LLC 135 Delaware Avenue Suite 506 Buffalo, NY 14202-2410 David M. Lipman, Esq. 5901 S.W. 74 Street Suite 304 Miami, FL 33143-5186 cc: All Counsel of Record CHRIS N. KOLOS, ESQUIRE Florida Bar No.: 438235 MAGUIRE, VOORHIS & WELLS, P.A. / Two South Orange Plaza 2 South Orange Avenue Post Office Box 633 Orlando, Florida 32802-0633 Phone: (407) 244-1100 Fax: (407) 423-8796 Attorneys for Defendant, MACK TRUCKS, INC. 5 CLUTCH REMOVAL NOTE T. i Always mark clutch cover and fly wheel with a center-punch before removing clutch to facilitate rein stalling clutch in same position. 1. Use three spring retention tools (17-T1123 for CL-28, 40 and 50 series, 17-T1766 for CL-47 series) or retaining cups as shown in Figure 4 -1, when removing a clutch assembly from the flywheel. NOTE Three retaining cups and screws are used to hold a new clutch as sembly together until it is in stalled on the flywheel. Spring cups are pressed into the clutch cover hence the retaining cups are necessary to prevent spring cups loosening and slipping out of the cover during handling. Re taining cups and screws must be removed after the clutch is as sembled to the flywheel. A tag is attached to new clutches (CL-28, 40 and 50 Series) calling attention to this fact and cups and screws are painted red for ready identi fication. Figure 4-1. Retaining Cups To use spring retention tools, bottom screws in tapped holes in pressure plate. Set tool nuts up snugly against tool bracket. Tighten tool nuts evenly to relieve spring tension on pressure plate. Not used on CL-58 Series. 2. Remove two clutch-to-flywheel cap screws with lockwashers at the ten o'clock and two o'clock positions of the flywheel and install two long headless guide studs to support the clutch assembly during re moval of the remaining attaching capscrews. 3. After removal of all capscrew fasten ers, carefully remove heavy clutch and disc assembly from flywheel counterbore and place on bench. Be careful not to drop driven disc assembly which is now free. Also remove the temporary guide studs from flywheel. CLUTCH INSTALLATION 1. Using spring retention tools, bottom screws in tapped holes in pressure plate. Set tool nuts up snugly against tool brack et. Not used on CL-58 Series. 2. Engage splined end of clutch disc align ing mandrel or a spare main driving pinion with hub splines of driven disc from rear of long hub side. Then position driven disc assembly in flywheel so that spigot end of shaft engages inner race of clutch pilot bearing mounted in flywheel. This arrangement positions the disc assembly in proper alignment until clutch is com pletely assembled and secured in flywheel. 3. Install two long guide studs in the ten and two o'clock positions in flywheel rim. Mount clutch assembly on guide studs and push unit into flywheel bore until clutch cover flange enters counterbored pilot pro vided. Be careful not to disturb disc aligning mandrel. 4. Lubricate and installcover-to-flywheel capscrews with their lockwashers. Tighten capscrews a few turns at a time so that cover will not be misaligned and forced into flywheel pilot by the tightening of the cap screws. Remove the two guide studs and re place with capscrews and their lock wash ers. Remove aligning mandrel. CL-28 and 40 SERIES Description CL-28, -40 Series assemblies are single plate, dry disc pusher type clutches. They consist of a pressure plate, a cover, and a driven disc which is splined to the trans mission main driving pinion shaft. When 4-3 ^engaged. the driven disc is clamped between ^fHe" pressure plate and the flywheel by the pressure of coil springs which are mounted in cups on the cover. Drive is transmitted to the pressure plate by pressure plate lugs which fit in the cover openings. Six re lease levers have ball pivots and are linked to the pressure plate by eyebolts. The in ner ends of the levers are held by the notched release thrust washer. See Figure 4-2. 1. Clutch Spring 12. Washer (outer) 13. Fulcrum Adjust 2. Clutch Spring (in ment Nut ner, where used) 14. Lock Nut 3. Release Bearing 15. Eyebolt 4. Release Collar 16. Eyebolt Pin 5. Thrust Washer 17. Cover Plate 6. Release Lever 18. Pressure Plate 7. Lever Spring 19. Flywheel 8. Spring Washer 20. Pilot Bearing 9. Lever Pivot 21. Driven Disc 10. Lever Bushing Assembly 11. Eyebolt Ful 22. Driven Disc crum Facings Figure 4-2. Sectional View of CL-28. 40 Series Clutch 4-4 Disas^mblv NOTE. _ Before disassembly of the various parts, it is good practice to mark these parts with a center-punch, so that at reassembly, they can be re assembled in their original posi tions. This is necessary in order not to disturb the dynamic balance of the clutch. 1. Before removing the three spring re tention tools, compress clutch release lever springs, remove washer pins, then remove washers and release lever springs. Pry off snap ring from thrust washer. Remove eyebolt nuts, fulcrums, and clutch release levers. CAUTION : If retaining cups are used instead of tool (17-T-1123), clamp the cover in a press before removing the cups. This is necessary be cause the screw used does not have sufficient thread length to com pletely release the spring load before coming out of the pressure plate. 2. While holding spring retention tool screws, back off tool nuts alternately mak ing one turn at a time. When spring is entirely relieved, back out the three tool screws. 3. Remove clutch cover and springs. If heat-insulating washers are removed from pressure plate spring pockets, retain them for reassembly. The eyebolts need not be removed unless inspection reveals distor tion or loose fit on pins. Inspection and Repair Remove all traces of dirt and oil with a suitable safe solvent. Inspect parts care fully for cracks, distortion or excessive wear. 1. If cover is cracked or distorted, re place. Tack-weld loose spring cups (on covers having this construction) replace worn or loose ball-fulcrums. Replace loose or bent pin rivets. ~ assembled in their original posif tions. This is necessary in order ^ -- not to disturb the dynamic balance of.the clutch. . 1. Equally space three steel blocks 3/8 inch thick, on bed of arbor or drill press. 2. Place clutch with pressure plate side down, on blocks. (This is done in order to raise clutch to permit disassembly). 3. Place a block of wood, such as a two by four, across cover plate in a position that does not interfere with tips of release levers, as shown in Figure 4-10. Compress clutch assembly slightly, removing lever adjusting screw locknuts. Figure 4-10. Compressing Clutch 4. Turn each lever adjusting screw down (clockwise), a few turns with a screw driver, releasing spring tension a small amount. Repeat operation until all lever adjusting screws are entirely free of cover plate. Release remaining spring tension, and lift cover plate off pressure springs. 5. Pressure springs may nowberemoved. After extracting cotter pins and lever pins, remove release levers. Inspection and Repair Clean all parts thoroughly with a suitable safe solvent, then inspect carefully for ex- 4-8 cessiv^wear. distortion, or cracks as out lined bjiow: 1. Cbfjjk- cover plate-for distortion, ex cessive wear at indentations which register between drive bosses on pressure plate, and for stripped threads in holes accommodating release lever adjusting screws. If the above mentioned conditions are apparent, replacement of cover plate is required. 2. Replace springs if cracked or defective. Check all springs on a spring tester. Re place all that do not meet specifications. 3. Replace release levers that are badly worn on tips (this is an indication of a stick ing release bearing), worn threads on lever adjusting screws and nuts, or where bind ing appears to be present, which retards free back and forth movement. NOTE Release levers are serviced as a subassembly only, and consist of lever, adjusting screw, roller, rol ler block, lever spring and spring retaining pin. 4. If pressure plate shows signs of scor ing, excessive wear at lever pin holes, inside of drive bosses, heat checking, or if warped more than .020 inch, plate must be refaced or replaced. (When refacing pressure plate, remove only sufficient metal to obtain a smooth flat surface.) NOTE When pressure plate thickness be comes less than 1.141 inch, re placement is necessary. 5. If flywheel is warped or heat checked and surface is refinished, maintain the 1.188 inch dimension between disc surface and bolting face for proper release lever adjustment. No more than .070 inch maxi mum may be removed by grinding. 6. Inspect driven disc assembly for cracks, loose rivets, worn splines, warped or dished condition. If cracked, or hub splines are worn excessively, replace disc assembly. If facings are worn down nearly even with countersunk, facing-retaining rivet heads and provided assembly is in otherwise good condition, it may be rebuilt. 7. Pilot bearing should be removed, clean ed and checked each time clutch or engine is removed. Discard bearing if balls or races are chipped or scored. After in spection, hand-pack bearing with clutch pilot bearing grease and install bearing in flywheel. Tap into place with shielded side toward clutch. After bearing is properly installed, pack the entire cavity in back of the bearing with the same specified clutch pilot grease. NOTE To prevent damage to the bearing seal when the transmission is as sembled to the engine, the space occupied by the main driving pinion pilot must not be filled with grease. See Figure 4-11. 2. Place pressure springs in position on pressure plate, as shown in Figure 4-12. FLYWHEEL lAHAf-RiNG tyPEI WITH BUILT-IN GREASE SEAL HANO-PACK CAVITY EXACTLY AS SHOWN AFTER BALL BEARING INSTALLATION, central AREA MUST BE CLEAR CFGREASE BEARING SNAP-Ring COUNTERBORE Figure 4 -11. Cut-away View of Clutch Pilot Bearing Grease Reservoir Correctly Packed Use only the recommended pilot bearings specified. These bearings will function without premature failure where slight misalignment exists between engine and transmission. Reassembly 1. Mount release lever assemblies on pressure plate. Set pressure plate as sembly on three equally spaced steel blocks 3/8 inch thick, on bed of arbor or drill press, plate side down. 3. Lay cover plate over springs, being sure that all springs are seated on bosses of pressure plate, and around indentations on inside of cover. 4. If pressure plate was refaced, it will be necessary at assembly, to add shims under each pressure spring equal to total metal removed. 5. Compress assembly slowly, aligning lever adjusting screws with threaded holes in cover plate. (The indentations inside cover, should enter the spaces between drive bosses on pressure plate freely.) With screwdriver, thread ends of adjust ing screws into cover evenly, until screws protrude about 1/2 inch. Hold assembly compressed, while placing locknuts in posi tion, but do not tighten. 6. To facilitate installation on flywheel, place wood blocks approximately 3/8 inch thick, between the tops of release levers and inner rim of cover plate. (Be sure these stay in position as all tension is released). 7. Insert the three spring retention tools (17-T-1766), through cover and bottom in tapped holes in pressure plate (center hole of each five series in cover). With pres- 4-9 -sfe- plate face down on smooth surface, iyert three clutch cover spacer gages (fT-T-1767) (3/4 inch) at three equidistant pq^ftts around, edge of cover. These gages may be held with bolts, but do not allow bolts to extend beyond lower face of gages. 8. Holding bolt head of spring retention tool, draw up nuts evenly until blocks can be removed from between release levers and cover. After removing blocks, re lease tension by backing off nuts until pres sure plate and cover spacers rest evenly on smooth surface. Using lever setting gage (17-T-l 768), check distance from release lever tips to smooth surface. Ad just screws until desired setting is obtained. See specifications. Then lock screws in position with locknuts. CL-50 SERIES Description CL-50 Series assemblies are two-plate, dry disc pusher type clutches. In engage ment, the two driven discs and the inter mediate plate are clamped between the pressure plate and the flywheel by the force of multiple-helical springs backed up by the cover which is bolted to the flywheel. Six lugs in the flywheel, drive the inter mediate plate, but permit free longitudinal movement. Pressure plate drive is trans mitted by six cleft lugs which fit openings in the cover. The release levers have ball pivots and are linked to the pressure plate by eyebolts. The inner ends of the levers are held by the notched release thrust washer. See Figure 4-13. Disassembly NOTE Before disassembly of the various parts, it is good practice to mark these parts with a centerpunch, so that at reassembly, they can be reassembled in their original posi tions. This is necessary in order not to disturb the dynamic balance of the clutch. 1. Before removing the three spring re tention tools, compress clutch release lever springs, remove washer pins, then remove washers and release lever springs. Pry off snap ring from thrust washer. Remove eyebolt nuts, fulcrums. and clutch release lev ers. 4-10 1. Flywheel 13. Lever Bushing 2. Intermediate 14. Eyebolt Fulcrum Plate Drive Pin 15. Adjusting Nut 3. Adjusting Spacer Washer 4. Clutch Spring 16. Eyebolt Adjust- 5. Spring Cup ing Nut 6. Insulating Washer 17. Eyebolt Lock 7. Driven Disc Nut 8. Thrust Washer 18. Eyebolt 9. Release Bearing 19. Clutch Cover 10. Release Lever 20. Pressure Plate 11. Lever Spring 21. Intermediate 12. Lever Pivot Plate 22. Pilot Bearing Figure 4-13. Sectional View of CL-50 Series Clutch CAUTION ; If retaining cups are used instead of tool (17-T-1123), clampthecover in a press before removing the cups. This is necessary because the screw used does not have suf ficient thread length to completely release the spring load before coming out of the pressure plate. early bearing failure and consider able-damage to costly components. Use only the recommended snap ring type bearings specified. These bearings will function with out premature failure where slight misalignment exists between en gine and transmission. Before assembling the clutch, a positive wear check should be made to insure that it will provide maximum disc wear. This check will uncover any interference that might prevent full release lever travel and allow corrections to be made before the clutch is assembled. Place the pressure plate assembly and cov er (without springs) into position as shown in Figure 4-19, making sure that shims of the correct thickness (-'250) are inserted between cover and spacer (17-T-1763). In stall each release lever and while pressing firmly on the fulcrum, measure distance (1) inboard end of lever is raised above cover. Correct height is 3-11/32 inches. Remove any interference that prevents ob taining this dimension. Figure 4-19. Wear Check Reassembly 1. Remove the shims used for the wear check. Lightly lubricate pivot ball bush ing, fulcrum groove, eyebolt pin and in board end of release lever with clutch lever grease. 2. Place the pressure plate on a surface plate with the spring pockets of the pres sure plate up. Place heat-insulating wash ers and the springs in the pressure plate spring'pockets. NOTE If pressure plate and intermediate plate were refaced, insert wash ers into the spring cups of a thick ness equal to the metal removed from the pressure plate and inter mediate plate. Shellac the wash ers in place to facilitate retention. 3. Place the cover in position, align the springs in the pockets. Bottom the screws of the three spring retention tools into the threaded holes of the pressure plate and bring the tool nuts down snugly against the tool bracket. Tighten the tool nuts alter nately, one turn at a time, guiding the pres sure plate lugs into the clutch cover holes until the inside face of the cover is 1.1875 inch from the face of the pressure plate. Special tool (17-T-1763) and a 1/16 inch spacer (17-T-11337), is used to facilitate obtaining this dimension. See Figure 4-20. NOTE If the intermediate driving plate is worn or has been machined, the consequent reduction in thickness will produce the same effect as worn clutch discs when the clutch assembly is installed in a vehicle. In an extreme case, one-half the available release collar wear travel may be used up before the vehicle is put back into service. To compensate for this condition, shims of appropriate thickness must be inserted be tween cover and spacers (17-T-1763) while the clutch is adjusted. Measure thickness of the intermediate driving plate which will be used with clutch being adjusted and com pare with new thickness as shown in speci fications. If plate is .010 inch or more below new thickness, secure shims equal in thickness' to amount of metal removed and insert them between clutch cover and spacers (17-T-1763) at equally spaced in tervals. See Figure 4-20. 4. Place the clutch release levers on the ball fulcrums and eyebolt shanks. Place the lever springs on the spring pins with the small diameter against the release levers. Place the spring washers in position, com- SHIM TO COMPENSATE FOR INTERMEDIATE PLATE WEAR MACHINING ONLY. THICXNESS TO EQUAL AMOUNT MACHINED FROM PLATE. USE i EQUALLY PLACED. Figure 4-20. Method of Setting Clutch press, and insert the washer lock pins. In stall the fulcrums and adjust the nuts until the distance between the convex surface of each lever to the pressure plate (dimen sion (1), Figure 4-20) agrees with specifi cations. Special tools (17-T-11307) and a 1/16 inch spacer (17-T-11337) are used to facilitate obtaining this dimension. See Figure 4-20 showing use of these tools. Torque eyebolt locknut 40 to 45 lbs. ft. Install the thrust washer on the release levers and lock it in place with the snap ring. CL-58 SERIES Description The CL-58 Series clutches are of the con ventional single-plate, dry-disc pushertype. They consist of a cast iron pressure plate, a cast iron cover and a rigid-type driven disc which is splined to the trans mission main driving pinion shaft. When engaged, the driven disc is clamped be tween the pressure plate and flywheel web by the pressure of thirty-six compressed helical main springs reacting on the rigid cast iron cover. The springs are arranged symmetrically in groups of six between each pair of levers. Drive from cover-topressure plate is by engagement of six pairs of integral lugs on the pressure plate which are straddled by six pairs of mating lugs integral with the cover. The six forged and hardened steel release lev ers have anti-friction needle roller bearing mounting to the plate at the drive lugs and pivot in similar anti-friction needle roller bearings supported by yokes bolted to the cover. All six release levers are pro vided with individual anti-rattle springs. The notched release lever thrust washer ring is held in engagement with the lever tips by wire clamp extensions of three alternate lever anti-rattle springs. See Figure 4-21. Disassembly NOTE Before disassembly of the various parts, it is good practice to mark these parts with a centerpunch, so that at reassembly, they can be reassembled in their original posi tions. This is necessary in order not to disturb the dynamic balance of the clutch. 1. With a screwdriver, unhook the wire clamps that retain slotted thrust washer ring to the lever tips and remove ring. 2. With pressure plate side down, position clutch assembly on rebuild machine table. With a suitable clamping device, compress the spring-loaded cover assembly. Remove nut lock plate retaining screws, lockwashers, nut lock plates and lever adjusting nuts from cover and put aside for use at reas sembly. See Figure 4-22. Clamping pres sure on the clutch cover may now be re lieved. 3. Remove inverted leaf springs from lev er yoke stems, helical main springs, and 3. Release Lever 12. Thrust Washer Pin Clamp 4. Needle Bearings 13. Lever Thrust 5. Release Lever Washer Ring Yoke 14. Pressure Plate 6. Yoke Leaf 15. Helical, Main Spring Spring 7. Lever Adjust 16. Heat Insulator ing Nut Ring 8. Adjusting Nut 17. Driven Disc Lock Plate Assembly 9. Lock Plate Lock 18. Facing Rivet Screw 19. Driven Disc 10. Yoke Clevis Pin Facings Figure 4-21. Sectional View of CL-58 Series Clutch Figure 4-22. Removing Lever Adjusting Nut Lock Plates main spring insulator washers from pres sure plate bosses. NOTE Do not remove the six lever anti rattle springs from the cover un less replacement is necessary. 4. Lay pressure plate on bench and with a soft metal drift, drive hardened lever pins out of pressure plate drive lugs to free re lease levers. With a pair of pliers, remove cotter pin from each lever yoke clevis pin and then press out each yoke clevis pin by hand. NOTE When removing levers from pres sure plate drive lugs and lever yoke, be very careful not to lose any of the small uncaged needle rollers. Inspection and Repair Remove all traces of dirt and oil with a suitable safe solvent. Inspect parts care fully for cracks, distortion or excessive wear as follows: 1. Replace springs if cracked or defective. Check all springs on a spring tester. Re place all that do not meet specifications. 2. If pressure plate is scored, heat check ed, or warped more than .025 inch, it must be replaced or refaced. Remove only enough metal to obtain a smooth flat surface. No more than .070 inch maximum may be re moved by grinding. T. * 1. Pressure Plate 2. Return Spring 3. Pivot Pin 4. Spring Clip 5. Adjusting Ring 6. Lever 7. Snap Ring 8. Release Sleeve Ring 9. Release Sleeve Retainer 10. Spring Pivot 11. Pressure Spring 12. Flywheel Ring 13. Adjusting Ring Lock 14. Bolt Si Lock Washer Assy 15. Release Bearing & Bearing Assy 16. Driven Rear Disc 17. Intermediate Plate 18. Driven Front Disc Figure 4-33. Exploded View AS-1550 Series Clutch Assembly Removal and Disassembly A suitable ''sling" or transmission jack should be used to properly support andmaintain the engine/transmission alignment when removing or installing a transmission on an engine. DO NOT let the rear end of the transmission drop downand hang unsupported in the splined hubs of the clutch discs to avoid bending or distorting the friction discs. Disconnect the external linkage from the clutch release arm to permit the release yoke to turn up and pull free of the release bearing thrust pads. 1. Prior to actual clutch removal, assemble a clutch disc aligning tool to the driven disc and release bearing assembly. It is important that two 3/4 inch blocks of wood as shown in Figures 4-34 and 4-35 be inserted between the clutch release bearing housing and clutch flywheel ringas the dutch mounting bolts are loosened around the fly wheel. These blocks will relieve the heavy internal spring load, preventing cocking and bending within the clutch and insure easy re moval of remaining mounting bolts. 2. When all bolts have been removed, slide clutch assembly back and off using caution to keep aligning tool in place to retain discs and intermediate plate. 3. Carefully remove aligning tool, rear disc, intermediate plate and front disc. 4-29 Remaining Clutch Life Chart - % r.: Figure 4-43. Removing Retainer Clip Inspection and Repair Clean all parts thoroughly with a suitable safe solvent. Many clutches are replacedas a preventative maintenance item at low mileage during re pairs of the transmission or engine. Before the Clutch Assembly is replaced, the unit should be inspected for the following items: REMAINING CLUTCH LIFE 163.74 Driven Discs Inspect disc assembly for cracks, loose ri vets, worn splines, warped or dished condi tion. Re-straighten if dished or warped 0.015 inch maximum runout. Replace if hub is cracked, or splines are worn excessively. 1. Heat cracks in the pressure plate. 2. Excessive wear in all drive slots. 3. Broken springs. 4. Dry or damaged release bearing. 5. Broken intermediate plate. 6. Excessive driven disc hub spline wear. 7. Burned facings. 8. Excessive wear on drive pins or inter mediate plate slots. If the preceding list has been inspected and looks to be in good condition, use the chart to determine the approximate remaining clutch life by measuring the thickness of the rear driven disc assembly. Find thickness of rear disc on column to left then follow curve on right then drop this point down to read% of clutch life remaining. Replace facings if they are glazed, scored, worn down to rivet heads, burned, or if grease or oil are on them. The riveted asbestos facing driven discs, use high-quality facings riveted to the steel disc. They may be furnished with rigid disc or damper type. Used discs can be reworked in the field by drilling out the rivets to re move old facings. Use the correct size drill when removing old rivets to avoid enlarging holes in disc. Use proper facings andastar set anvil to reline used discs. Ceramic friction material, a combination of metal and ceramic, is relatively new to the clutch facing industry. It is used in pro ducing round or trapezoidal buttons which are riveted to steel discs. These clutch 4-32 r i# f discs, available with either rigid or damper r pressure plate. Smooth and flat pressure hubs, offer many advantages for heavy-duty / plate surfaces must be used for satisfactory applications. Reworking these discs in the clutch life, field is not re commended because the ceram- -^r - -- ic buttons must be assembled and ground to Check drive lugs for wear per Specification hold thickness as well as squareness with Chart. splines. Super-duty discs have six trapezoidal cer amic buttons and are available with rigid or damper hubs. These S-D discs are thinner than standard discs while the intermediate plate is thicker. This combination of more ceramic buttons and thicker intermediate plate provides longer life and increased torque capacity. A super-duty kit consisting of two driven discs and an intermediate plate is available for converting a standard Angle-Spring clutch into a super-duty A-S clutch. It is very im portant that the kit be installed as a unit and its components should never be intermixed with standard components. Intermediate Plate Inspect friction surfaces of intermediate plate for heat checks, scoring or distortion. If friction surface is badly scored, heat checked, warped or dished in excess of 0.020 inch, resurface or replace with new intermediate plate. Smooth and flat inter mediate plate surfaces must be used for sat isfactory clutch life. Inspect driving slots of intermediate plate for wear per Specifi cation Chart. Release Levers Flywheel Ring Inspect the flywheel ring for cracks. Re place if cracks are visible. Check slots for indentation caused by wear of pressure plate driving lugs. See Specification Chart for slot limits. Inspect bolt circle face and pilot for nicks and burrs due to removal or handling. Re move burrs with file to insure proper seat ing andsquareness when clutch is mounted to flywheel. Inspect levers for excessive wear at points of contact with pressure plate, release sleeve retainer, and pivot pin. If levers are bent or worn, replace with new levers. It is good preventive maintenance to replace levers during clutch rebuild. Release Sleeve Retainer Inspect for wear in lever groove and internal splines. Refer to specifications for driving slot clearance between flywheel ring drive slots and release sleeve retainer drive lugs. Adjusting Ring Check pivot pin holes for wear. Clearance may not exceed 0.010 inch between pin and hole. Inspect for cracks; replace if cracks are visible. Pressure Plate Inspect fulcrum for wear. If wear exceeds 0.015 inch, remachine. See Specification Chart for maximum rework. Inspect friction surface of pressure plate for scoring, burning, heat checking or distor tion. If friction surface is badly scored, heat checked, warped or dished in excess of 0.010 inch, resurface or replace with new Spring Pivots Inspect for cracks; if visible, replace. Release Sleeve Sub-Assembly Check bushing for excessive wear. Check bearing diameter for tight fit. Refer to Specifications Chart and replace if nece ssary. Release Bearing and Sleeve Assembly It is recommended that the release bearing and sleeve assembly be replaced as a unit at the time of clutch rebuild. Assemblies are available as service replacement items. 4-33 3/8 inch capscrews. 7/16 inch capscrews^ are used for 15-1/2 inch - 2 applications. ' The pressure plate is driven by means of driving lugs extending into mating slots of the flywheel ring (cover). The intermediate plate is driven by drivepins located in the engine flywheel. Depressing the clutch pedal pulls the release bearing toward the transmission. The re lease bearing being connected to the release levers thus retracts the pressure plate from contact with the driven disc assembly, there by relieving the pressure on the intermediate plate and the forward driven disc assembly which disengages the clutch. heads are perfectly square to the friction surface. Drive pins must be square to pro vide proper clearance for the drive slots in the intermediate plate. A machinist's square and feeler gage may be used to check for squareness. After the pins are installed and properly squared, try the intermediate plate for fit over the pins. With new pins and a new in termediate plate, there should be from 0.006 inch to 0.014 inch clearance. Try the plate in different positions and select the position which provides the greatest freedom of move ment. Mark the plate for location to the fly wheel. Lock the drive pins in place with the socket head or Allen set screws. Releasing the clutch pedal allows the release bearing assembly to move toward the engine permitting the pressure plate to move to ward the flywheel gripping the discs, causing engagement. Clutch Installation Before installing the clutch on the flywheel, check for free fit of cover assembly to fly wheel and flywheel alignment before proceed ing with installation. See Figures 4-80, 481, 4-82 and 4-83. Driven discs are marked, "Pressure Plate Side" and "Flywheel Side", to indicate their proper positions. Install as indicated. The cover assembly may now be installed on the flywheel but, before tightening cap screws, install an aligning , shaft through the two hubs and into pilot bearing. Cover capscrews may now be tightened pro gressively around the flywheel using 35 to 40 ft. lbs. of torque. Be sure that intermediate drive pins are a press fit inholes inflywheel rim and that the Remove the three hold down bolts from cover before removing splined aligning shaft or disc assemblies may fall out of position. 4-51 X /Disc Brakes Ho manual adjustment required. Brakes adjust automatically during braking oper ation. The square-cut piston seal is dis torted when pressure is applied to piston. When braking pressure is released, the seal returns to its normal condition and pulls the piston away from the lining. This action, plus some slight rotor lateral runout ("wob ble"), considered normal, provides adequate running clearance. Disassembly and Assembly When brakes are relined or disassembled for other repairs, all parts should be in spected for wear and worn parts should be replaced as required. Cam Brakes - (See Figure 8-10) Disassembly 1. Remove shoe return spring. 2. Remove lock rings, retainers, and felts from brake shoe anchor pins. 3. Cut lock wire and remove anchor pin lock screws. 4. Remove anchor pins and shoe assemblies. 5. Remove brake shoe roller retaining clip (or screw) and remove roller. 6. Remove slack adjuster lock ring and spacing washers. 7. Remove camshaft, washer, and felt seal (if used ). 8. Remove nylon bushings if replacement is necessary. Use suitable tool for both re moval and installation of bushing. See Figure 8-17. NOTE On brakes where lip type seals are used, these will have to be removed and replaced if nylon bushings are replaced. Figure 8-17. Bushing Removal and Installation Tool AssembTly. 1. Instatt/oiew- nylon bushings, if required, using suitable tool. (Install new lip type seal if used.) 2. Install brake shoe rollers and retainers. Make certain rollers are of proper size. See instructions relative to brake shoe "Cam Roll-Over." 3. Install camshaft, washer, and felt seals, (if used.) 4. Position brake shoe assembly over spi der and tap anchor pin into position with brass punch, "flat" in line with lock screw hole. 5. Install lock screws, tighten securely and thread with lockwire. 6. Position felts, retainers, and lock rings on anchor pins. 7. Install shoe return spring. New springs should be used with each brake reline. Ten sion loss occurs from normal use and heat build up. New springs will ensure that shoes are returned to fully relaxed position, and not in contact with drum, which would cause premature wear. 8. Assemble slack adjuster on splined end of camshaft; using spacers and washers on each side of adjuster to obtain .030-. 060 end play. Wedge Brakes - (See Figure 8-12) Disassembly 1. Remove shoe return springs. Use brake spring pliers. (Do Not use screwdriver.) 2. Remove brake shoe assembly. 3. Remove plunger guide screws and gaskets from plunger housing. If brake is automatic adjusting, remove hollow capscrew, gaskets, spring and adjusting pawl. It may be neces sary to use a magnet to remove the adjusting pawl. 4. Using a suitable screwdriver, pry the seals loose and remove anchor (solid) plungers, adjusting plungers, adjusting sleeves (actuators) and adjusting bolts. 5. Thoroughly inspect and clean all parts including the housing plunger and seal bores and shoe rest pads. DO NOT solvent clean any rubber parts (plunger seals or gaskets). __4- Lift the caliper off the hub and rotor. See Figure 8-23. Figure 8-23. Removing Caliper NOTE It is not necessary to remove the hydraulic line when replacing shoe and lining assemblies. How ever, do not let the caliper hang on the hydraulic line. Lay the caliper on the suspension. Figure 8-25. Remove Outer Shoe and Lining Assembly. Inspecting Caliper 1. Check the inside of caliper for hydraulic fluid leak. If evidence of fluid leak is noted, the caliper should be overhauled. 2. Wipe the inside of the caliper, clean and check the dust boots for cuts, cracks or other damage. If damage is noted the caliper should be overhauled. See Figure 8-26. Removing Shoe and Lining Assembly 1. Remove the inner shoe and lining assem bly from the anchor plate. 2. Remove outer shoe and lining hold-down spring, pin and cup. See Figure 8-24. Figure 8-26. Inspecting Boots for Cracks and Cuts. Figure 8-24. Removing Spring, Pin, and Cup. 3. Remove outer shoe and liningassembly. See Figure 8-25.- Assembly Installing Shoe and Lining Assemblies 1. Install new inner shoe and lining as sembly into anchor plate. 2. Push the pistons to the bottom of the pis ton bore. This is done by takinga small block of wood and placing it over the pistons and boots. With a "C" clamp, push the pistons to the bottom of the piston bores. 3. This will provide clearance for the caliper to fit over the hub and rotor when new shoe and linings are installed. See Figure 8-27 -"i * n 19. Install new shoe and lining assemblies, and caliper as previously described. 20. Connect the brake hose to the caliper. felease of air pressure reverses the cycle. rake adjustment to compensate for lining Bear is provided at the slack adjuster. See. Figure 8-35. 21. Bleed the system. Allow the caliper to fill with brake fluid. After all air bubbles have escaped and fluid runs clear from bleeder, close the bleeder screw. Replenish the brake fluid in the hydraulic fluid reservoir. Slack Adjusters There are two types of manual slack adjust ers and two types of automatic slack adjust ers in use. 22. ''Pump" the brake pedal several times Manual Type to actuate the piston seals and position the shoe and lining assemblies. The two manual types of slack adjusters shown in Figure 8-35 differ primarily in the 23. C heck for fluid leakage at all c onnections adjustment screw locking device. Type I under maximum pressure. Refill fluid res features a lock ball and detent adjustment ervoir as necessary. lock while Type U has a sliding sleeve lock. This difference must be recognized as cer 24. Install front wheels and lower vehicle. tain adjustment procedures will vary accord ingly. 25. Always check the hub and rotor braking surface for deep scores, cracks, and heat The brakes are adjusted by turning the ad checks. See Figure 8-34. justing screw (1) until the brake shoes are against the brake drum with the brake cham ber push rod in the released position. With the Type I lock, a distinct click will be heard each time the spring loaded ball seats in the indent. With the Type n no click will be evident. The adjusting screw cannot be turned until the locking sleeve has been de pressed, freeing the adjustment screw hex i head for necessary movement. Upon com pletion of adjustment the locking sleeve is released and engages the head of the adjust ing screw, locking the adjustment. With this exception, the procedure is essentially Figure 8-34. Checking Rotor Surface the same. 26. Always check hub and rotor lateral run out ("wobble"). Lateral runout must not ex ceed . 008 ", SLACK ADJUSTERS, BRAKE CHAMBERS AND POWER CYLINDERS Despite differences in construction, the wide variety of brake actuators, brake chambers or power cylinders in use perform an identicalfunction. Basically, appliedair pressure is converted into the mechanical force and motion required to expand brake shoes. The slack adjuster, in conjunction with the brake camshaft, serves as mechanical leverage for brake shoe application. Air pressure exertedagainst a diaphragm in the brake cham ber or power cylinder moves a push rod linked to the slack adjuster. The brake cam shaft, through splined engagement with the slack adjuster, rotates with slack adjuster movement and the integral constant lift cam spreads the brake shoes, applying the brakes. Check push rod travel. Keep stroke (2) as short as possible without brakes dragging. With push rods in full-released position, turn adjusting screw (1) until linings are tight against drum. With Type I locking device, back off screw to first notch (a distinct click will be heard) and then three additional notches. CAUTION Make sure locking ball is seated in notch. With Type II position the wrench over the adjusting screw and depress adjusting lock sleeve BEFORE attempting to turn adjusting screw. After linings are tight against drum, back off adjusting screw until wheel rotates freely. When the adjustment is completed, be sure the locking sleeve is returned to its locked position by permitting the sleeve to engage the hex head of the adjusting screw. Leading to the bottom of the container. The iiMheir rises through the alcohol and passes tnrtJ the line to the compressor, carrying ilcohbl in the form* of vapor with it. The alcohol, thus introduced into the air system acts as an anti-freeze. Check to bKsure all connections are tight. Check condifion of filler cap gasket and cover gasket. RELINING & RECONDITIONING Drum-Type Brakes After supporting the axle on stands, cage the springs in the spring brake chambers. Re move the tires, wheels, and drums as an assembly, and inspection drums for heat checks, cracks, distortion or other damage Figure 8-55. Alcohol Evaporator Preventive Maintenance Every 1, 000 Miles or as Determined by Actlal Usage Eheck alcohol level and if necessary replenish vith 188 proof methanol alcohol. In cold veather, alcohol level should be at least 2/3 ull. NOTE If alcohol is not being consumed, it indicates the evaporator is in operative and shouldbe inspected. "very 1.800 Operating Hours or 50,000 Miles temove strainer if present in bottom of evapirator body and clean thoroughly in solvent. Every Year, 3,600 Operating Hours or 100,000 fliles )isassembly evaporator unit and clean horoughly. Inspect all parts for cracks nd be sure evaporator tube is not clogged /ith dirt. Replace ail gaskets and rubber jarts. nspection Vhen the compressor is compressing air, ir bubbles should be passing through the .lcohol. If air bubbles are not present when he compressor is compressing air, then the lcohol evaporator is not functioning properly. Close inspection of all worn brake parts may lead to clues for corrective action to improve lining life and future drum damage. Scored Drum Only the tops of the ridges will contact brake lining. Since a small percentage of the brake lining is required to do all the work, hard pedal and fade will result. A scored drum must be reconditioned in a lathe. See Figure 8-56. Hard Spots Hard spots are "islands" of steel in the cast iron surface. They result from a change in metallurgy caused by the heat of braking Hard spots must be ground out or brake perform ance will be poor and erratic. See Figure 8-57. Bell-Mouthed Drum If a drum is bell-mouthed or flared, full lin ing to drum contact cannot be achieved. Hard pedal, fade and noise can be expected. A bell-mouthed drum must be trued in a lathe in order to procure full lining to drum contact. See Figure 8-58. <-34 Figure 8-58. Bell Mouthed Drum. Heat checking and discoloration, if only superficial, can be corrected by resurfacing the drum, otherwise replace drum. Drums having more than .010" out of round, or any of the conditions described above should be resurfaced. Use only those drums which produce a satisfactory surface finish. CAUTION Drum manufacturer and state vehicle inspection laws (where applicable) govern the amount of drum diameter increase allowed when resurfacing. Most drums are stamped by manufacturers as to maximum oversize allowable. Excessive removal of drum mat erial could result in drum failure or unsatisfactory brake perform ance and is illegal in some states. NOTE When reconditioning brakes, it is important that thebrake assem blies on each side of the same axle be serviced in exactly the same manner. This will avoid unequal braking performance. (Drums on the same axle should be resurfacedwithin. 010 of each other. Cam Roll-Over Increasing the drum diameter will permit the cam to rotate beyond its maximum lift when the lining becomes worn. To prevent cam "Roll-Over, " oversize roller cam fol lowers are available. Standard (1.250" O. D.) Standard rollers are used when installing standard linings with standard drums, "X" lining (1/16 oversize) with 1/16 oversize drums, and "XX" lining (1/8 oversize) with 1/8 overside drums. 1/8" Oversize (1.375") 1/8" oversize rollers are to be used with the installation of standard linings with worn or trued drums which are 1/32" oversize. 1/8" oversize rollers should be installed and the liners circle ground a few thousandths less than drum diameter. 1/4" Oversize (1. 500") Where "X" linings have been installed with 1/16" oversize drums and standard rollers, these rollers should be removed and 1/4" oversize installed before the lining becomes worn to a point where the brake cam is no longer effective with the standard rollers. 1/2" Oversize (1.750") Where "XX"linings and 1/8" oversize drums have been used, the standard rollers should be removed when the linings become approx imately 50% worn and 1/2" oversize rollers installed. Brake Linings Linings must be the correct material for a specific application, and the same type lining should be used for each wheel on the same axle. Handle lining carefully to prevent grease, oil, or any other type of contamination to come in contact with lining surface.