Document QMg41DaoZgGqa850QZLDnQark

PLAINTIFF'S EXHIBIT GF-1620 ISS Mtfk IM WHflM omu iO *NCI4, CMirOHNW top'i wire m#o *M err. TWUfwOMC <*>! MIDI law ornets or Paul.Bastings. Janofsky & Walker a aantncm*** imcluoi** *ontMOMAL cowomtiow 10*0 Thomas jC'fcNSOn STUCCT, N. w. SUCTN ruoon WASHINGTON, O. C. 20007 TCLSrMQMC 1200 333-ABOO CAOLC AOOACSS: *VkM*T WM TWA: 7tOUI*OM August 41 1982 H*wi cowwrr orrck MVtMTtttHM rioo* M it*n cimia oma m*ta H(M.eAi,ieMti* VtbCmwOM (VmM MIT UM ANHUI erriec rtfTM rkoo* MM OCA** *WCVC . Santa momica.cautonnia m*o> TtUMigm am !> ON* TILS NO. Mr. Wolfgang H. Schmidt Spencar, Fane, Britt 6 Browne 1000 Power and Light Building 106 West 14th Street Kansas City, Missouri 64105 Re: Norman Van Bebber, et al. v. GAF Corporation, et al. Dear Mr. Schmidt: Enclosed are various materials to assist in responding to interrogatories concerning the development of asbestos-free insulation products by GAF Corporation. Also attached is a brief summary of these enclosures. The memoranda prepared by Paul Zevnik describe the history of GAF's asbestos-free Calsilite (Enclosure A) while the remaining documents provide somewhat of a chronology of the products' development and eventual discontinuance. Please remember that some of these documents are sensitive in nature, and that they are being provided solely for the purpose of responding to those relevant interrogatories. GAF manufactured Calsilite Block and Calsilite Pipe Covering in compliance with M1L-I-2819E and MXL-X-2781D, respectively, and all predecessors of these specifications. "MIL" indicates Military Specifications which set government standards for products used in military projects and facilities. Although asbestos was not expressly required as an ingredient under these specifications, as a practical nutter, only an asbestos-containing product could meet essential performance criteria, principally, (1) changes under soaking heat, (2) loss in weight, (3) linear shrinkage, and (4) resistance to abrasion. NUCH09052 Paul. Hastings. Janofsky k Valker Mr. Wolfgang E. Schmidt August 4, 1982 Page Two The Navy's insistence upon inclusion of asbestos in thermal pipe covering and block for its vessels is demonstrated by the Navy's refusal to revise its specifications in minor fashion to permit the use of the non-asbestos insulation product GAF developed in 1970 for use on Navy ships (See Enclosure J). GAF's non-asbestos calcium silicate pipe covering ("Calsilite II") met virtually all applicable govern ment specifications. GAF sought to have this product approved by the Navy and placed on the applicable "Qualified Products Lists." GAF even engaged independent experts to demonstrate that the non-asbestos product could satisfy effectively govern ment requirements and, where applicable, sought a slight modification in the heat soaking criterion (See Enclosure X). The Navy, however, refused to approve GAF's non-asbestos pro duct and continued to insist upon inclusion of asbestos in its thermal insulation. I hope these materials provide you with the necessary background information to respond to plaintiff's interrogatories. If you should have any questions or comments regarding the enclosed documents, do not hesitate to call. Very truly yours, Jill A. Franklin Litigation Legal Assistant JAF/mm Enclosures cc: Edward D. Tanenhaus, Esq. (w/o end.) Ms. Vanessa Morgan (w/o end.) NUCH09053