Document QgOMrRLBLBGLx5deD30d8O9z8
NO. 31506
SHIRLEY HODGE, Individually and as Personal Representative of the and Estate of A. J. Hodge, Jr., Deceased; GREGG A HODGE and ANGELA R. McClain,
IN THE DISTRICT COURT OF
Plaintiffs,
vs. FANNIN COUNTY, TEXAS
TEXAS UTILITIES ELECTRIC COMPANY'(d/b/a VALLEY POWER PLANT), et al
Defendants.
6TH JUDICIAL DISTRICT
VIDEOTAPE ORAL DEPOSITION OF RAYMOND A. HEIT
September 24th, 1996 Houston, Texas
rD)'^7
Taxable Costs $______ Paid by: Plaintiffs Andrew Waters, Esq. SBN 20911450
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2 EXAMINATION INDEX
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4 DIRECT EXAMINATION
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By Mr. Waters.............................................................................................
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8 EXHIBIT INDEX
9 EXHIBITS MARKED FOR IDENTIFICATION
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11 NUMBER
DESCRIPTION
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1 Amended Notice of Intention to Take
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Videotaped Deposition Duces Tecum...............
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2 Copy of excerpt from the book "Thermal
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Insulation"......................................................................
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3 1970 Annual Book of ASTM Standards Part 14 . 146
14 4 1970 Annual Book of ASTM Standards Part 12. 146
5 Industry Standards and Engineering Data. . 146
15 6 An Index of U.S. Voluntary Engineering
Standards...........................................................................
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16 7 Excerpt from The American Educator
Encyclopedia....................................................................
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2 APPEARANCES:
3 FOR THE PLAINTIFFS:
4 Andrew Waters, Esq. Attorney at Law
5 400 South Zang Suite 1420
6 Dallas, Texas 75208 (214) 941-0532
7 and
8 J. Todd Kale, Esq.
9 Silber Pearlman, P.C. 3110 Webb Avenue
10 Dallas, Texas 75205 (214) 528-2000
11 FOR THE THORPE DEFENDANTS:
12 David Fisher, Esq.
13 Miller Thomas, Esq. Fairchild, Price, Thomas & Haley
14 413 Shelbyville Street Center, Texas 75935
15 (409) 598-3317
16 FOR THE BROWN & ROOT DEFENDANTS:
17 Phillip S. Brown, Esq. Fanning, Harper & Martinson, P.C,
18 Third Floor Preston Commons West 8117 Preston Road
19 Dallas, Texas 75225 (214) 369-1300
20 REPORTED BY:
21 Michelle Pfeiffer, CSR
22 Q & A Reporting, Inc. 2700 Post Oak Boulevard
23 Suite 1540 Houston, Texas 77056
24 (713) 439-7441
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1 APPEARANCES CONTINUED:
2 VIDEOGRAPHER:
3 Warren Mullins
4 Legal Eyes, Inc. 220 West Parkway
5 Denton, Texas 76201 (800) 622-7542
6 ALSO PRESENT:
7 Ms. Lynnette G. Adams
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1 2 3 4 5 6 7 On the 24th day of September, 1996, in 8 the offices of Brown & Root, 4100 Clinton Drive, 9 Houston, Harris County, Texas, beginning at 1:10 p.m., 10 RAYMOND A. HEIT appeared before me, Michelle Pfeiffer, a 11 notary public in and for the State of Texas, and being 12 by me first duly sworn, testified by his video oral 13 deposition as hereinafter set out, pursuant to notice 14 and the Texas Rules of Civil Procedure; 15 The deposition may be signed by the 16 witness before any notary public or other officer 17 authorized to administer oaths. 18 19 20 21 22 23 24 25
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1 2 THE VIDEOGRAPHER: Okay. You're on the 3 record. Go ahead. 1:10. 4 5 THE REPORTER: Stipulations? 6 7 MR. WATERS: Just by the Rules. 8 9 THE REPORTER: Signature? 10 11 MR. BROWN: He'll read and sign. I 12 haven't even seen his notice. So if you're gonna 13 ask him about the notice, could someone share it 14 with me. I don't understand that he was asked to 15 bring anything. 16 17 MR. WATERS: Well, the -- the notice 18 pertained to all three of the depositions with 19 respect to the -20 21 MR. BROWN: He's not an industrial 22 hygienist. 23 24 MR. WATERS: I appreciate that, but it 25 would probably --
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1 2 MR. BROWN: So if there's anything other 3 than that 4 5 MR. WATERS: There's nothing other than 6 that, but if -- if you were -- I imagine you have 7 those pulled together. If you could give them to 8 us now, Todd can be looking at them while I'm 9 deposing him. 10 11 MR. BROWN: Mr. Drysdale's gonna bring 12 them. 13 14 MR. WATERS: Okay. 15 16 MR. BROWN: If they can be available any 17 sooner than that. I'll -- I'll certainly at a break 18 make that inquiry. 19 20 MR. WATERS: All right. Let's go ahead 21 and mark the depo notice as Exhibit 1. 22 23 MR. FISHER: Additionally, Michelle, an 24 objection by one would be good for both of the 25 defendants so we don't have to both pipe up during
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1 the same -2 3 MR. WATERS: That's fine. 4 5 MR. FISHER: Okay. 6 7 MR. KALE: Also, Michelle, that's the 8 notice for -- for all three depositions. 9 10 THE REPORTER: Okay. 11 12 MR. WATERS: Okay. 13 14 THE REPORTER: Can we go off the record, 15 please? 16 17 MR. WATERS: You most certainly may. 18 19 (At which time, a short recess was 20 taken.) 21 22 (At this time, the instrument 23 referred to was marked Heit Exhibit No. 1 24 for identification and is attached 25 hereto.)
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1 2 THE VIDEOGRAPHER: Back on the record at 3 1: 12 4 5 DIRECT EXAMINATION 6 7 BY MR. WATERS: 8 Q Would you tell us your full name, sir? 9 A Raymond A. Heit. 10 Q H-E-I-T? 11 A That is correct. 12 Q Mr. Heit, what is your date of birth? 13 A September the 12th, 1936. 14 Q That would make you 59 years of age? 15 A No. 16 Q 60 years of age? 17 A Correct. 18 Q Just had your birthday. Okay. 19 A Correct. 20 Q How long have you been employed with Brown & Root? 21 A Approximately 22 years. 22 Q All right, sir. Have you ever given a deposition 23 before? 24 A Yes, sir, I have. 25 Q On how many occasions?
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1 A Two. 2 Q Did either of those involve asbestos in any way? 3 A No, sir. 4 Q Okay. What did they involve? 5 A One was anelectionsituation up in Ohio, and the 6 other was a resolution of some contract expenses 7 with respect to some work I had been involved with. 8 Q Were either -- Well, the one you spoke of first, I 9 take it, was before you were employed with 10 Brown & Root? 11 A That's correct. 12 Q The second one was a contract dispute? 13 A Contract involved some work I had done prior to 14 coming with Brown & Root. 15 Q Oh, I see. 16 A Yes. 17 Q Okay. All right. Soboth of thosecases were 18 independent and totally separate from your work 19 with Brown & Root? 20 A That is correct. 21 Q Have you -- So therefore, you've never given a 22 deposition while a Brown & Root employee before 23 today? 24 A That is correct. 25 Q All right, sir. Since you're somewhatfamiliar
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1 with the process, I'll just briefly refresh the 2 ground rules, if you will. If for any reason you 3 don't understand my question, will you stop me and 4 ask me to rephrase or repeat the question? 5 A Yes, sir, I will. 6 Q Okay. And you're doing fine so far. If you'll 7 continue to be sure to let me finish my questions 8 before you answer, and likewise, I will let you 9 finish your answers before I start another 10 question. Will that be all right? 11 A Great. 12 Q Okay.. What is your present position with 13 Brown & Root? 14 A I'm manager of engineering procedures and 15 standards. 16 Q How long have you been in that position, 17 approximately? 18 A On and off, essentially my entire career at 19 Brown & Root. 20 Q Okay. From -- Would it be from 1974 to the 21 present? 22 A That's correct, with some project assignments 23 scattered in between. 24 Q Okay. How was it that you -- Well, strike that. 25 Let me ask you first, just very generally.
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1 what are your duties -- what do you consider your 2 duties and responsibilities to be at the present 3 time? 4 A In a nutshell, to a laymen, the best I can describe 5 it is that I recycle intellectual products. 6 Specifically, engineering documents. Now, that 7 covers just a multitude of areas. 8 Q When you say recycle, do you mean that you utilize 9 engineering plans and documents that have 10 previously been used for something and you use them 11 again for some other purpose? 12 A Parts. 13 Q Okay. If I were to ask you what your job 14 description was when you started with the company 15 22 years ago, what would you have said? 16 A Design engineer. As it turns out, I was under 17 review for the job I'm in right now. 18 Q And as a design engineer, what were your duties and 19 responsibilities? 20 A Work with project requirements on a specific task 21 and bring those requirements to completion where 22 they could be used in the actual procurement and 23 construction of the plant or whatever to 24 completion. 25 Q How was it that you came to be hired by
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1 Brown & Root in 1974? 2 A I had just gotten back in from an assignment in 3 Algeria and went back through the interview process 4 here in late 1973, and Brown & Root gave me the 5 best job offer of all the groups that I had talked 6 to. 7 Q Now, how would you have been employed immediately 8 prior to coming to work for Brown & Root? 9 A I was an independent consultant for the five years 10 prior. 11 Q Approximately '69 to '74? 12 A That's correct. 13 Q And just again very generally, describe what sort 14 of consulting services you provided in that time 15 frame. 16 A Among other things, I was a private consultant to 17 the design of the TransAlaska Pipeline. I was 18 design consultant to a local engineering 19 architectural firm on the design of the College of 20 Minerals and Petroleum in Saudi Arabia. I did the 21 safety, fire protection and security consulting 22 work in Algeria in '73. I was the design 23 consultant for a grass roots fiberglass plant, 24 manufacturing plant. I was the owner's consultant 25 for a manufacturing storage facility south of
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1 downtown here where I was able to make use of an 2 existing foundation and floor system. Then, at the 3 same time, I was doing OSHA consulting for various 4 groups around town on an intermittent consultant 5 basis. 6 Q All right. The safety work that you did in 7 Algeria, was that in connection with a particular 8 project, construction project? 9 A No. This originated in Washington, D.C. One of 10 the consultants in Washington was hired or directed 11 by American insurance interests and, I believe, 12 their international insurance interests, also, to 13 review the status of safety, fire protection and 14 security at all Algerian industrial facilities. So 15 I was part of the team that went over to do that 16 task. 17 Q And did you go to a variety of manufacturing or 18 refining complexes? 19 A Yes, sir. Yes, sir. Welooked ateverything of 20 any significance in Algeria. 21 Q Okay. And what -- The Algeria job was in '73? 22 A Yes, sir. 23 Q And I think you said that was the last thingyou 24 did before you came to Brown & Root? 25 A That's correct.
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1 Q Okay. You indicated that you had been a design 2 consultant at a fiberglass plant. 3 A Yes, sir. 4 Q Where was that located? 5 A Galveston, Texas. 6 Q What's the name of the plant, if you remember the 7 owner, perhaps, or the 8 A I believe it was Texas Fiberglass Products. 9 Q And when was that project? 10 A That would have been in early 1969. 11 Q All right, sir. Then you mentioned a Houston 12 manufacturing facility. I think you may have said 13 south of Houston. 14 A Yes, sir. 15 Q What is that called? 16 A I do not recall the name of that concern. 17 Q Do you recall what the plant was set up to 18 manufacture? 19 A It was electrical goods. 20 Q Electrical goods? 21 A Yes, sir. 22 Q What was the time frame you were involved with that 23 project? 24 A That was in mid to late 1969. 25 Q Okay. And you also mentioned that you had done
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1 some OSHA consulting? 2 A That's correct. That's correct. 3 Q How is it that you got involved with OSHA 4 consulting? 5 A OSHA was breaking on the scene. There was a 6 significant amount of concern, frustration, and let 7 me say confusion as to where OSHA was going to take 8 the American construction industry and American 9 business and industry in general. 10 Q All right. 11 A So I saw it as a good extension to things that I 12 had been doing up to this point. 13 Q Okay. Had you previously been involved in 14 occupational health and safety matters? 15 A Remotely. 16 Q Okay. We'll come back to that. 17 A Okay. 18 Q Maybe the better way to go is go back to -- start 19 at the beginning and work our way forward to fill 20 in the gap. 21 A Okay. 22 Q You were born in 1936. Where were youborn? 23 A Norfolk, Virginia. 24 Q Okay. Well, I went to school atWilliam and Mary, 25 and I used --
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1 A Okay. 2 Q -- to spend a lot of time down there. 3 A Okay. 4 Q How long did you take in Norfolk, Virginia? 5 A My family left there in 1946. 6 Q All right. And where did you move? 7 A To a city just outside of Cincinnati known as 8 Hamilton, Ohio. 9 Q Okay. And how long did you reside in Hamilton, 10 Ohio? 11 A Till I went away to college. In fact, I would stay 12 at home with my parents until I graduated. 13 Q Where did you go to college? 14 A University of Cincinnati. 15 Q Okay. When did you graduate from the University of 16 Cincinnati? 17 A 1959. 18 Q What was your degree in? 19 A It's the professional degree ofcivil engineer. 20 It's a little known degree. It ranks between a 21 bachelor's and a master's. 22 Q Okay. 23 A The University of Cincinnati is allowed to award 24 that on the basis of a cooperative education 25 program.
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1 Q Okay. After you graduated in 1959, what did you 2 do? 3 A I went with a group known as Factory Mutual 4 Engineering Division. 5 Q What did they do? 6 A This was the technical arm of the Factory Mutual 7 Insurance Companies. 8 Q And what sort of services did the technical arm of 9 these insurance companies provide? 10 A Factory Mutual was, and is, one of the leaders in 11 preferred risk industrial fire insurance. And 12 accordingly, they backed up their marketplace with 13 a full complement of fire protection related 14 engineering services. So this included everything 15 from review of policyholder plans for expansions, 16 new construction in the words of -- Okay. Just to 17 give you an idea of Factory Mutual's marketplace, 18 at that point in time, they carried all your Blue 19 Ribbon manufacturing facilities and other Blue 20 Ribbon properties. For example -- Go ahead. 21 Q Well, I just want to be clear on one thing. Is the 22 coverage that they provide pretty much limited to 23 fire, or is it more broad than that? 24 A It was fire and what's called use and occupancy. 25 In other words, if one of their insured facilities
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1 was taken out of service as a result of fire or 2 other disaster, such as wind storm or flood or what 3 have you, then they also covered the operating 4 expenses and salaries and profits that would not 5 have been made during that period. 6 Q So it's sort of like a catastrophic loss coverage? 7 A No. 8 Q No? 9 A It depended on the client. For example, most of 10 their policies were full coverage. However, at the 11 other end of the spectrum, there were a few 12 companies, like Union Carbide, that carried as much 13 as a million-dollar deductible. But Union Carbide 14 and other groups that had this kind of deductible 15 wanted the benefit of the fire protection and 16 related engineering services. 17 Q Okay. Did they provide any worker's compensation 18 coverage? 19 A No. 20 Q Okay. 21 A No. 22 Q No general liability coverage? 23 A No. 24 Q Okay. And was that true throughout the entire time 25 you worked with them?
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1 A That is correct. 2 Q And if I understand your position in the position 3 of the Factory Mutual engineering division, y'all 4 would provide the expertise to assist the customers 5 in taking the appropriate precautions that would 6 help them avoid those types of losses? 7 A That is correct. 8 Q Was there a fair amount of travel involved with the 9 job? 10 A Yes, sir. It just so happened that I was the only 11 bachelor at that point in time in the Cleveland, 12 Ohio office, so I got the majority of the road 13 work. 14 Q Okay. Did you travel to Texas during that time 15 frame? 16 A No, sir. 17 Q Okay. For how long a period did -- did you work 18 for Factory Mutual engineering division? 19 A Approximately three and a halfyears. 20 Q And that was out of Cleveland? 21 A Correct. Correct. 22 Q Let me ask you if at -- during that time frame or 23 at any point in time up to, say, 1964, had you ever 24 learned anything about asbestos? 25 A Yes, sir. Are you familiar with asbestos cement
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1 pipe? 2 Q Yes, sir. 3 A Okay. Asbestos cement pipe was very highly 4 regarded 5 Q From a fire -6 A -- for underground water supply. In fact, I can 7 vividly recall one plant up i. central Ohio that 8 had had the misfortune of having a tremendous 9 amount of cinders used as fill material around the 10 plant site. The cinders, in turn, generated fair 11 amounts of acid, which, in turn, attacked the 12 cast-iron fire water mains. So on visits to 13 insured facilities, when the weather permitted, 14 people like myself would run hydraulic tests on the 15 water system. And invariably, at this particular 16 location, when the fire pumps would kick in, it was 17 almost a sure bet you were gonna blow some of the 18 cast-iron water main. So people like myself would 19 stand by, stay on site until that fire main was 20 back in service. So the asbestos cement pipe was 21 the -- the, I guess, hands-down choice to replace 22 the cast-iron pipe. 23 Q Is that your -- at that point in time, in that time 24 frame -- your experience with that product? Was 25 that your first experience or knowledge about any
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1 asbestos-containing products? 2 A No. My parents used to make candy as an art form 3 when I was a youngster, and I can vividly remember 4 the asbestos gloves that my father used in moving 5 the big copper candy pot. And he had other 6 asbestos pads that he used to set things on. So I 7 vividly remember asbestos from my days as -- as a 8 youngster. 9 Q Okay. In the time frame up to 1964, did you ever 10 have any understanding or knowledge about the 11 health hazards of asbestos? 12 A No, sir. 13 Q Okay. Did you ever have any -- any courses, for 14 example, in college that touched on biology or 15 mineralogy that discussed at all asbestos? 16 A I had a basic geology course, and then I did some 17 graduate work in sanitary engineering, and in 18 neither of those programs do I recall anything in 19 regard to asbestos. 20 Q Okay. Now, up to this point in time by 1964, had 21 you received any training, either formal or 22 informal, in industrial hygiene? 23 A No, sir. 24 Q Had you received any training in on-the-job safety? 25 A No, sir.
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1 Q Okay. Why did you decide to -- to leave the 2 Factory Mutual engineering division? 3 A I had the opportunity to take a very unique 4 position with one of the suburbs of Cleveland, 5 Ohio. 6 Q Okay. What was that position? 7 A That was village engineer for the Village of 8 Cuyahoga Heights. 9 Q I need you to spell Cuyahoga for me. 10 A C-U-Y-A-H-O-G-A. 11 Q All right. And tell me again, it was called 12 village engineer? 13 A Village engineer, yes. 14 Q What were the -- what was the nature and duty of 15 your responsibilities in that job? 16 A Essentially, I was thetechnical expertise for the 17 town. It's a very unique situation. At that point 18 in time it had a bedroom population of 19 approximately a thousand people and a working 20 population of something in excess of 50,000 people. 21 In other words, this little town had a lion's share 22 of Cleveland's industry. So I essentially served 23 as the technical arm for the Village. 24 Q And did that require you, for example, to spend 25 time at manufacturing facilities that were operated
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1 in the Village? 2 A That's correct. 3 Q Were you a consultant for the city -- Strike that. 4 Did your duties and responsibilities include 5 inspecting on behalf of the Village the sites to -6 to ensure that operations were safe and met 7 specifications and things of that nature? 8 A That is correct. In addition to being village 9 engineer, I was also the Village building 10 commissioner and the Village zone commissioner. 11 Q How was it that you came across this opportunity or 12 how did it -- how did you -- how were you given 13 this job? 14 A I was approached by -- well, it was known in the 15 industry as a headhunter. 16 Q Okay. Does the Village of Cuyahoga Heights have -17 did it have a mayor, for example? 18 A That's correct. 19 Q Okay. Did you work directly for the mayor? 20 A I was directly employed by a civil engineering firm 21 out of Cleveland, and I was positioned out at the 22 Village. 23 Q Okay. So you were technically not employed by the 24 Village; you were employed by the consulting firm, 25 but your services --
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1 A Yes. 2 Q Okay. 3 A Yes. My full work week was spent out at the 4 Village. 5 Q And for how long a period did you maintain that 6 position? 7 A That was approximatelythree years. 8 Q In those -- During that time frame, did you become 9 familiar with whatever local or state ordinances or 10 regulations may have applied to safety in the 11 workplace? 12 A Yes, sir. 13 Q And in the course of your duties, did you advise 14 facilities or the Village of Cuyahoga Heights if 15 certain regulations or ordinances were not being 16 followed or if there were violations of those 17 requirements? 18 A Yes, sir, I did. 19 Q Was that a significant part of your -- of your job? 20 A It all depends on significant. Among other things, 21 the Village was topographically suited for 22 landfills. So as a result, the majority of 23 Cleveland's industrial refuse was brought out there 24 for dumping and I had to ride heard on the landfill 25 contractors. So typically, once or twice a day the
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1 chief of police would come by and pick me up, and 2 we would probably stop for coffee, and then we 3 would just go visit the landfills. So it's a 4 rather dubious distinction, but it was my 5 responsibility to ensure that noxious materials 6 were not being allowed into the landfills and that 7 things were generally being kept in control. 8 Q Do you recall the specific regulations or 9 requirements that had to be adhered to or had to be 10 followed by the landfill operators, for example? 11 A Just the high points. 12 Q Well, let me -- let me ask the question this way. 13 A Sure. Go ahead. 14 Q Was it, for example, state law or was it local 15 municipal ordinances that had to be followed? Do 16 you recall? 17 A Yes, sir. It was contract requirements with the 18 landfill operators. These -- these were contracts 19 that were prepared by the Village solicitor. 20 Q Okay. So the Village had contracts with the 21 landfill operators which required the landfill 22 operators to follow certain safe practices? 23 A That's correct, yes. 24 Q Okay. Did either the city or the state, to your 25 knowledge, at that time, have any regulations in
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1 place that pertained to these types of operations?
2 A I do not recall anything of that nature.
3 Q Did the city or the state have any regulations in
4 place at that time that pertained to safety and
5 health generally in industrial operations?
6 A The Village had its own code. I do not recall
7 anything in state regulations that I was required
8 to follow in dealing with the industries in the
9 town.
10 Q And the code that the Village had, that was
11 mandatory for that to be followed by the industrial
12 industry -- rather, by industries that were located
13 in the Village?
14 A That's correct.
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Q Okay. And all of thepeople
-- all of the
16 companies that operated facilities in the Village
17 were essentially held to understand that they had
18 to follow those codes?
19 A That is correct.
20 Q Okay. And for the most part did they follow those
21 codes?
22 A Yes, sir.
23 Q Okay. Did you everhave any of the industrial
24 operations out there respond to a violation of
25 codes by merely saying, well, we didn't know about
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1 it, we didn't know that that was a requirement or 2 we didn't know that that was a restriction, 3 something of that nature? 4 A I do not recall any situations like that. 5 Q As -- as a general rule, would you agree with me 6 that companies are required and held to -- to know 7 whatever laws or regulations may be applicable to 8 their operations? 9 10 MR. BROWN: May he limit his answers to 11 his perspective, which is engineering, or are you 12 asking him broader than that? 13 14 MR. WATERS: Well, we -- he's been 15 talking about regulations that pertain to safety 16 and health. 17 18 MR. BROWN: Well, I understand that. But 19 you understand his background, training and 20 experience? 21 22 MR. WATERS: Yeah. I think he -- he's -23 he's -24 25 MR. BROWN: I think your question's
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1 outside his area of expertise, and I want to go 2 ahead and make that objection. 3 4 MR. WATERS: All right. 5 6 MR. FISHER: We also object that it calls 7 for a legal conclusion on the part of this witness 8 and it's outside of his scope. 9 10 BY MR. WATERS: 11 Q Okay. Having said all that, you can answer my 12 question. From time to time there will be 13 objections. Do you want the question read back to 14 you, or do you recall it? 15 A I think it would be a good idea if we went back 16 over it. 17 18 MR. WATERS: Okay. Do you mind reading 19 that back? 20 21 MR. BROWN: Let me, before you do that, 22 tell you, Mr. Heit, that when counsel says to you, 23 "You now can answer the question," you need to 24 understand that that means if you can. 25
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1 THE WITNESS: Okay. 2 3 MR. WATERS: No. I certainly -4 5 MR. BROWN: You're not under any 6 obligation to do more than try to respond as 7 completely and fully as you can to the question 8 that's asked, not to speculate or do anything 9 beyond that. 10 11 BY MR. WATERS: 12 Q Absolutely. Mr. Heit, if you don't know the answer 13 to my question, all you need to tell me is you 14 don't know and we'll move on to something else. 15 I'm only interested in the knowledge that you've 16 acquired in your years of experience and what you 17 know. And if there's something that you don't 18 understand or don't know, just tell me and we'll 19 move on to something else. 20 21 MR. WATERS: Okay. Can you read that 22 back to him? 23 24 THE REPORTER: Can we go off the record, 25 please?
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1 2 MR. WATERS: Sure. 3 4 (At which time, a short recess was 5 taken.) 6 7 RAYMOND A. HEIT, 8 having now been duly sworn, testified as to the 9 following: 10 11 (Whereupon the following was read by 12 the reporter: 13 14 "QUESTION: As -- as a general rule, 15 would you agree with me that companies 16 are required and held to -- to know 17 whatever laws or regulations may be 18 applicable to their operations?") 19 20 THE VIDEOGRAPHER: You're on. 21 22 A That covers a lot of territory. Back in the 60s, 23 from a technical point of view, life was a lot more 24 simple. What it came down to is we didn't know as 25 much then as we do now. By their very nature, laws
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1 and regulations are meant to apply to everybody. 2 But sometimes there is a lag in disseminating this 3 information through the community and through those 4 that need to know. 5 6 BY MR. WATERS: 7 Q All right. I think that's a fair answer. 8 When you say life was more simple then, in 9 fact, in that time frame -- and we're really 10 talking about the early 60s right now, I think. 11 A Mid 60s. 12 Q Mid 60s. Okay. 13 A Uh-huh. 14 Q Okay. There were a lot less regulations concerning 15 safety and health in the workplace than there are 16 today? 17 A That is correct. 18 Q And the regulations that they had in those days 19 tended to be simpler -- that is to say, they were 20 less complex and easier to understand? 21 A That is correct. 22 Q Okay. And you would expect that in terms of the 23 lag time for a company or an individual to 24 recognize and address and follow a regulation, that 25 the larger the -- and more sophisticated the
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1 company, the more able it would be to fairly 2 quickly understand the regulation and follow it to 3 the best of its abilities? 4 A Again, you're -- you're covering a lot of territory 5 there. Today we look at all the regulations that 6 are put out by EPA, NIOSH, OSHA, Internal Revenue. 7 I've had the opportunity to try to keep up with the 8 Federal Register, which -- at the federal level 9 where so much of this is put out. Most businesses 10 cannot afford to dedicate someone to stay right on 11 top of this on a day-to-day basis. It's -- it's 12 just the reality of the situation. Again, the 13 variety of subjects that are under regulation and 14 the variety of requirements. This is why OSHA is 15 still maintaining such a strong inspection posture. 16 Q Okay. And I appreciate what you've said and -- and 17 especially what you're talking about now -18 A Uh-huh. 19 Q -- how we have a lot ofregulation. 20 A Uh-huh. 21 Q But going back to the mid 1960s when there was 22 significantly less regulation, am I correct that 23 the companies that were better able to understand 24 and comply with those regulations would tend to be 25 the larger companies that had the financial
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1 wherewithal to make themselves familiar and be on 2 top of what the requirements were? 3 A I can't guarantee that that would be true. 4 Q Okay. Can you think of any reason why a large 5 company in the early to mid 1960s would not be 6 aware of regulations concerning safety and health 7 in the workplace? 8 A I believe it's a matter of experience and exposure 9 to the sources of these regulations. For example, 10 again, looking at today's situation, the variety of 11 subjects that are being flushed out as being 12 problems. 13 Look at the tobacco industry today. Here we 14 have the tobacco industry that claims that there's 15 no hazard to cigarette smoking. So that you -- you 16 have the -- this gap of credibility. In other 17 words, what -- what -- what are we really-seriously 18 talking about here? And your corporate managers, 19 of course, are committed to their stockholders and 20 to the boards of directors. 21 Q Well, and I guess that presents -- can present a 22 problem in the sense that the corporate managers, 23 in their commitment to the stockholders, they have 24 a direct concern in -- in enhancing the 25 profitability of the enterprise, correct?
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1 A I would believe so. 2 Q Okay. And oftentimes the -- the profit motivation, 3 if you will, or incentive, can outweigh other 4 considerations, such as health and safety, that 5 might -- might be- pushed a little bit aside? 6 A I would probably have to look at that as a broad 7 generalization. 8 Q Yeah. I'm -- and I'm 9 A Go -- go ahead. I'm sorry. 10 Q I -- I wasn't speaking in any specifics, just in 11 general. Absolutely. 12 A There's no doubt that that doeshappen. 13 Q Okay. Do you believe that there's too much 14 regulation at the present time? 15 A That's almost like asking me if -- if I quit 16 beating my wife. It's -- it's a two-edged sword. 17 Q Okay. Do you think that there is adequate 18 regulation in the workplace today so that if the 19 regulations are followed, workers will generally 20 be -- be protected from accidents and industrial 21 exposures and things of that nature? 22 A I do believe that. 23 Q Okay. Do you believe that there was adequate -24 that there were adequate regulations in place in 25 the mid 1960s to properly protect workers from
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1 injuries and exposures in the work place? 2 3 MR. BROWN: Again, is your question 4 limited to his perspective -- that is, from an 5 engineering standpoint? Or are you asking more 6 than that? 7 8 MR. WATERS: I'm asking his perspective 9 based on his world view, if you will. He has a lot 10 of different experiences which we're still working 11 our way through. 12 13 MR. BROWN: Are you asking him for his 14 personal opinion? 15 16 MR. WATERS: Based on his experience and 17 training and background. 18 19 MR. BROWN: Personal opinion? 20 21 MR. WATERS: Well, his opinion. I don't 22 know how personal it is. He's sharing it with us. 23 24 MR. BROWN: Okay. Just as long as you 25 understand it's outside his area of expertise, but
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1 he certainly can share with you any personal 2 opinion he may have. 3 4 BY MR. WATERS: 5 Q All right, sir. 6 A Applying the knowledge and expertise that we have 7 acquired up to this point in time, I have to say 8 that in the mid 60s we probably did not have 9 adequate regulation. 10 Q Okay. 11 A And a real quickexample would thesafety belt and 12 the lumbar belt. 13 Q Okay. In that time frame, mid 1960s, you were 14 personally involved with trying to ensure that 15 companies followed regulatory or other 16 requirements, correct? 17 A That is correct. 18 Q Okay. And at that time, indealing withthe 19 industrial concerns in facilities that you 20 addressed on a continuing basis, would you have 21 been critical of a company that professed ignorance 22 of applicable regulations? 23 A At that point in time it was my responsibility to 24 ensure that the businesses and industries in that 25 municipality were, in deed, following the
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1 regulations that had been enforced. In other 2 words, I -- for lack of a better expression, I was 3 a miniature OSHA. 4 Q All right. 5 A And, to a degree, a -- a miniature EPA. 6 Q All right. Well, and that -- that brings me back 7 to my question. In that capacity in which you 8 found yourself employed at that time, you expected, 9 did you not, that the industrial concerns in 10 facilities would know what the requirements were 11 and would follow the requirements, correct? 12 A If I had expected them to know and follow 13 everything, I would not have had to make rounds to 14 ensure that they were. 15 Q When you made the rounds, the purpose was to -- to 16 determine whether or not they were following the 17 regulations and doing so correctly? 18 A That's correct. 19 Q All right. And before doing so, before you would 20 make those rounds, you anticipated, did you not, 21 that -- that these companies would take the 22 necessary steps and would know about the 23 regulations and at least they should have been 24 following them? 25 A Would you go back over that?
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1 Q Try that one again? Okay.
2 As you went out to make your rounds and make
3 your inspections as a miniature OSHA or EPA, as
4 you've described it, --
5 A Uh-huh.
6 Q -- these -- you anticipated that these companies
7 would know about the regulations and that they
8 should have been following them, correct?
9 A No. I -- I did not anticipate that they did know
10 them. And, in fact, in some cases they did not
11 know.
12 Q Okay. And --
13 A And -- Go ahead.
14 Q And so part of -- of your job description, then,
15 was to educate them on what they didn't know --
16 A Yes.
17 Q -- concerning therequirements?
18 A Yes, that would be correct.
19 Q Okay.
20 A Uh-huh.
21 Q And then once they did know, you would certainly
22 expect them tofollow themthereafter?
23 A Yes.
24 Q Okay.
25
A Yes. Which theydid not always
do.
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1 Q I'm sure that's true. 2 And some of those companies presumably didn't 3 follow the regulations, which they knew about, at 4 least in part because of their commitment to 5 stockholders and to the -- the profit situation? 6 A I really can't answer that. 7 Q Okay. 8 A Again, that -- that's a -- that's a broad 9 generalization. 10 Q All right. Where did you go when you left Cuyahoga 11 Heights ? 12 A I went to the position of assistant county engineer 13 in Lake County, Ohio. 14 Q And what was the approximate time frame that you 15 made that move? 16 A I'm gonna say early 1966 -- excuse me, early 1965. 17 Q All right. Did you continue to operate as a mini 18 OSHA or a mini EPA in your new job as the assistant 19 county engineer. Lake County? 20 A No. For the short time I stayed in that slot, I 21 was looking after county road responsibilities. 22 Q All right. How long did you actually stay there? 23 A Just a matter of a couple of months. 24 Q Okay. And then where did you go after that? 25 A I went with a general contractor there in Lake
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1 County.
2 Q Okay. Where is Lake Countyvis-a-vis Cleveland?
3 A Immediately east.
4 Q Okay.
5 A Cleveland's located in Cuyahoga County, and Lake
6 County is the next county to the east.
7 Q And I'm sorry. What was the name of the
8 engineering company?
9 A In Cleveland?
10 Q The one you went to. Right.
11 A Okay. I went to work for the countyengineer, a
12 gentleman by the name of Frank Riley.
13 Q All right. I've gotten myself confused. You left
14 the Lake County assistant county engineer job --
15
A Okay. No. No -- okay.
Yeah. Yeah. Goahead.
16 Q All right. And -- and that -- and that would have
17 been approximately mid 1965?
18 A Yeah, close to that.
19 Q And then you went -- What was the name of the
20 company you went with then?
21 A I went to Osborne, Incorporated.
22 Q Osborne.
23 All right. And it was -- What was Osborne,
24 Incorporated?
25 A General contractor.
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1 Q What kind of work did they do? 2 A Highway construction, site development, concrete 3 supply and building materials. 4 Q How long were you employed by Osborne? 5 A A little over a year and a half. 6 Q Till approximately the end of 1967? 7 A End of 1966. 8 Q Oh, I'm sorry. What were your duties and 9 responsibilities while employed by Osborne for that 10 year and a half? 11 A My primary responsibility was to keep the 12 construction of about a five-mile stretch of 13 freeway on track. In other words, I had to look 14 after the layout work and the materials testing. 15 Then there were some inconsistencies in the results 16 of the Ohio Department of Highway testing program, 17 so it was necessary to unravel that. So then along 18 the way I was estimating and bidding projects -- 19 and I was chief engineer for Osborne. 20 Q How -- how big a company was Osborne? 21 A Okay. With all the divisions, they probably had 10 22 million dollars worth of equipment, in the dollars 23 at that time. He had -- I guess you'd call it a 24 franchise where he used one of the lake mooring 25 boats to go across Lake Erie to Canada and he would
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1 bring -- the mooring boat would bring back a boat 2 load of crushed limestone. 3 Q Huh. 4 A And this, of course, was the aggregate that was 5 used in the concrete and it was a material that was 6 used in a variety of ways. So that's probably one 7 of the best money machines I've ever seen. But he 8 had the ready mix concrete business -9 Q When you say he -10 A Jerry Osborne, the owner. 11 Q Okay. 12 A Yeah. Yeah. 13 Q Okay. Did Osborne have a safety department? 14 A Not as such. I -- I was the unofficial safety 15 manager. 16 Q Okay. 17 A With that kind of work, the primary concern is 18 cave-ins with your underground. 19 Q Did you familiarize yourself, to the extent you may 20 not have already known them, with whatever 21 requirements, regulations may have applied to 22 digging trenches -- 23 A Yes. 24 Q -- and that sort of thing? 25 A Yes.
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1 Q Okay. 2 A There was not much in place at that point in time. 3 Q All right. Fair enough. To the extent there was, 4 however, information and regulations in place, 5 Osborne made a conscious effort to -- to address 6 that and to follow those rules? 7 A Yes. Yes. 8 Q And was Osborne doing thatbefore you arrived, to 9 the best of your knowledge? 10 A From everything that I can recall, Imaybe brought 11 it up a notch. 12 Q Okay. Kind of tightened up the program? 13 A Yeah. Yeah. Yeah. 14 Q All right. And why was it that you left Osborne? 15 A Had the opportunity to come to Texas. 16 Q Okay. 17 A We had had two weeks ofsubzero weather in 18 Cleveland and I came down here in January of '67 19 and had two of the most beautiful weeks I can ever 20 recall. Nobody told me it was the mildest winter 21 they had had in years. But I was able to interview 22 and on the spot I decided, hey, I had had enough 23 cold weather. So I was able to interview with half 24 a dozen outfits at that point in time and was able 25 to pick up employment. So I went back, packed and
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1 moved south. 2 Q Were you interviewing with construction companies 3 for the most part? 4 A No. I interviewed with Brown & Root. 5 Q Uh-huh. 6 A I interviewed with Exxon and Fluor and Union 7 Carbide, and there were two others, and I don't 8 recall who they were. 9 Q All right. And who did you wind up taking a job 10 with? 11 A Union Carbide. 12 Q Do they have a plant in the Houston area? 13 A Texas City. 14 Q Texas City? 15 A Yeah. Yeah. 16 Q So you began work sometime -- was it in January 17 ' 67? 18 A February of '67. 19 Q February of '67? 20 A Yeah. 21 Q And what was your position at Union Carbide? 22 A Essentially, I was project engineer responsible for 23 civil, structural, architectural, fire protection 24 and safety-related projects. 25 Q Wow. That's a big job description.
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1 A It was a lot of fun. 2 Q Yeah. Now, when did -- when did that plant open, 3 if you know? 4 A Yes, I do. Construction started in the late 30s, 5 early 40s. 6 Q And how many employees did that plant have at the 7 time frame you arrived, approximately? 8 A I would estimate maybe2,000. 9 Q All right. 10 A It was around-the-clock operation. 11 Q Now, in your -- in terms of your safety-related 12 responsibilities, did they have a -- sort of a 13 safety hierarchy at the plant that you fit into or 14 were you hired to -- to, in effect, oversee the 15 safety department, or how did that fit together? 16 A As a project engineer, it was my job to pick up on 17 a need or a problem and work with the unit 18 management to arrive at a solution. Now, one of 19 the surprises on arriving at Union Carbide at that 20 point in time, early '67, was to find that they had 21 an industrial hygienist. The first time I had ever -22 ever come across that particular phrase. And they 23 had a plant doctor, which apparently was pretty 24 common at the larger refineries and chemical plants 25 along the Gulf Coast at that point in time.
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1 Q Let me just ask -2 A Sure. 3 Q -- for a point of clarification. Do -- Are you 4 saying it was common to have a plant doctor or it 5 was common to have IH 6 A It was common to have a plant doctor. 7 Q Okay. 8 A Again, the -- this planthygienist-- industrial 9 hygienist was the first time I -- I had come across 10 that particular position. 11 Q Do you recall the name of the industrial hygienist 12 working for Union Carbide in 1967? 13 A I do not. I do not. 14 Q Did you have anopportunity tospend time with -15 with this gentleman and learn something of what his 16 expertise was all about? 17 A Just very limited. 18 Q Okay. 19 A I -- I recall having conversationsabout 20 ventilation problems, fume exposure. That 21 particular plant was a petrochemical facility. 22 Q All right. 23 A And there were all kinds of noxious chemicals in 24 the area. 25 Q Do you know if at that time Union Carbide had
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1 developed some procedures that from an industrial 2 hygiene standpoint would reduce or eliminate 3 asbestos exposures? 4 A No, sir, I don't. In fact, I can vividly recall 5 using cement asbestos siding and cement asbestos 6 pipe with no knowledge of any concern. 7 Q Okay. And this was personally used on your part? 8 A No. No. This was -- 9 Q This was -- the workers? 10 A -- with respect to the projects that I was 11 responsible for. 12 Q All right. And I take it that at that point in 13 time anyway you did not have any knowledge about 14 the potential hazards that could result from dust, 15 dusty operations or inhaling the dust? 16 A That is correct. There was -- there was no 17 knowledge. 18 Q Had you had knowledge at that time that you 19 subsequently developed in your position in -- in -- 20 with respect to your safety-related 21 responsibilities, would you have asked for a change 22 in procedures to try to eliminate those exposures? 23 A Well, I believe that Union Carbide would have 24 handcuffed me. In other words, they flat -- they'd 25 have rode me out of the plant, if -- if, for
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1 example, today I would go and try to use corrugated 2 asbestos. 3 Q Uh-huh. Well, if you had -- if you had known about 4 the hazards of asbestos in '67 and had gone to 5 Union Carbide with your concerns, do you think that 6 they would have responded by trying to adopt some 7 safer practices? 8 A That -- that's a good question. I can't be real 9 sure about the answer. Unfortunately, the Gilbert 10 principle wasn't in effect back then. There were a 11 couple of situations where I had put in what I 12 thought were significant improvements -- not in the 13 safety field, but in -- let me call it engineering 14 economics, and the bureaucracy was able to make 15 sure it didn't get implemented. 16 Q It was hard to make changes, in other words? 17 A That's correct. 18 Q Okay. 19 A That's correct. 20 Q Did you understand that the -- the gentleman -- and 21 I -- I know you can't recall his name, but the 22 gentleman that was employed there was a certified 23 industrial hygienist, or do you know if he was 24 certified? 25 A That, I don't recall.
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1 Q Okay. 2 A I'm not sure that they -- they might have had a 3 certification program that far back. 4 Q All right. Was Brown & Root involved with any of 5 the projects at the Union Carbide facility while 6 you worked there? 7 A At the time that I was on site, there were not any 8 Brown & Root crews there. However, Brown & Root 9 had been one of the major contractors in that 10 plant. 11 Q How long a time frame were you there at Union 12 Carbide? 13 A Approximately two years. 14 15 MR. BROWN: We've been going about an 16 hour. 17 18 MR. WATERS: Yeah. 19 20 MR. BROWN: Do you want to take a break, 21 Mr. Heit? 22 23 MR. WATERS: Sure. We can do that. 24 25 THE WITNESS: Okay. Sounds good.
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1 2 THE VIDEOGRAPHER: Off the record at 3 2 : 10 4 5 (At which time, a short recess was 6 taken.) 7 8 THE VIDEOGRAPHER: Okay. Back on the 9 record at 2:22. 10 11 BY MR. WATERS: 12 Q Mr. Heit, we were talking about your employment 13 from, I guess, '67 to '69 -- early '69 at the Union 14 Carbide facility. 15 A That's correct. 16 Q Okay. And where did you go after that? 17 A The next five years I essentially worked as an 18 independent consultant. 19 Q All right. And that would be early '69 to '74? 20 A Late '73. 21 Q To late '73? 22 A Yes, sir. 23 Q All right. We've come full circle. Tell me, if 24 you will, what -- I assume that it was during the 25 time you were at Union Carbide that you decided you
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1 were gonna go into business for yourself? 2 A That's correct. 3 Q All right. And what was it that you hoped to 4 accomplish or what was -- what was your goal in 5 setting up that business in terms of what sort of 6 customers you wanted to have, what sort of work you 7 intended to do, what sort of services -- services 8 you intended to provide? 9 A I intended for my consulting practice to be 10 primarily civil structural, but to -- to also offer 11 the fire protection and safety consulting. 12 Q Did you anticipate that the safety consulting would 13 generally be in the context of construction 14 operations? 15 A No. 16 Q Okay. 17 A I figured that would be one part of it. 18 Q All right. What other -19 A Go ahead. 20 Q What other parts did you anticipate at that time in 21 addition to -22 A The industrial -- primarily the industrial side. 23 Q And when you say industrial side, you'retalking 24 about manufacturing operations or refining? 25 A Primarily.
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1 Q Okay. 2 A Yes. Yes. 3 Q During your time that --the twoyears at Union 4 Carbide, did you receive any additional training or 5 instruction with respect to safety or industrial 6 hygiene matters? 7 A Nothing that would be classed as formal training. 8 I was interacting with a variety of disciplines. 9 We had a full complement of technical disciplines 10 on site there. 11 Q All right. Including theindustrialhygienist you 12 referenced earlier? 13 A Yes. 14 Q All right. 15 A Yes. Yes. 16 Q During the time frame you were at -- at Union 17 Carbide, did you learn anything about the hazards 18 or potential hazards of asbestos in the workplace? 19 A I did not. 20 Q Okay. When was it that you first learned or 21 understood about the -- developed an understanding 22 about the hazards of asbestos? 23 A To the best of my recollection, that started to 24 come into the picture in 1974, after I had joined 25 Brown & Root.
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1 Q Okay. 2 A And the asbestos picture began to unfold at that 3 point. 4 Q Okay. So is it a fair statement that prior to 5 arriving at Brown & Root you were not yet aware 6 that asbestos was hazardous? 7 A Yes, sir. Yes, sir. 8 Q And you mentioned that you -- one of the things 9 that you did was OSHA consulting? 10 A Yes, sir. 11 Q In that time frame when you were an independent 12 consultant? 13 A Yes, sir. 14 Q Okay. Did youunderstand at that time frame, in, 15 let's say, 1970, that OSHA -- that the -- that the 16 Act had been passed and signed by President Nixon 17 in 1970? 18 A That would have been -- You're referring to the 19 William Stigar? 20 Q Well, I -- I'm not -- What I'm referring to is the 21 Occupational Safety and Health Act, which is what 22 set up the OSHA administration and commenced the -23 the preparation of regulations. 24 A Okay. I believe that's referred to as William 25 Stigar Occupational Safety and Health Act.
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1 Q I think that must be right. 2 A Yes. 3 Q And that was signed into law by President Nixon in 4 1970? 5 A That's correct. Yes. 6 Q Okay. And are you telling me that you did not 7 become aware until 1974 that one of the regulated 8 substances, materials in the implementing regula -9 in the implementing regulations was asbestos? 10 A Okay. I knew that asbestos was in the -- the dust 11 and breathing area, but it was not considered any 12 more unusual than any of the other regulations that 13 came out. You have to understand that when they 14 put together the first two regulation packages -15 okay. Part 1910 is what they called the general 16 industry regulations, and Part 1926 was the 17 construction regulations. Essentially, what they 18 did with those two packages was to pull together a 19 lot of loose consensus standards or voluntary 20 standards that were in existence at that time. 21 Does the term ANSI mean anything to you? 22 Q Uh-huh. 23 A Okay. Most of the material published in 1910 and 24 1926 were existing ANSI regulations. So there were 25 just innumerable loose ends that were included in
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1 those two packages. 2 Q I take it that in the time frame '69 to '74, in 3 your work as an independent consultant, you did not 4 address or encounter the OSHA regulations 5 pertaining to asbestos in the workplace? 6 A It was never an issue. Now, the -- the prime 7 emphasis was on trenching, perimeter protection, 8 hard hats, untidy job sites. At that point in 9 time, there was so much in the elementary area of 10 safety control that needed attention that the more 11 sophisticated ends really did not get significant 12 attention. 13 Q Okay. So just to kind of capsulize what you've 14 just told me, the asbestos regulations that were 15 passed in '70, as you say were more -- the more -16 at the more sophisticated end? 17 A Yes. 18 Q And they tended to be overlooked, for lack of a 19 better word, for a few years until implementation 20 really began to kick in? 21 A Yes, At that point in time, you never saw anything 22 in the way of air sampling on a job site. In other 23 words, there were too many tripping hazards or too 24 many working without hard hats. There were too 25 many obvious shortcomings that needed immediate
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1 attention. 2 Q Okay. So you would not anticipate, for example, 3 that at construction sites in the 1970s time frame 4 Brown & Root, for example, would have completed air 5 monitoring while working with asbestos? 6 A I would have been surprised if they had. 7 Q Okay. 8 A I really would. 9 Q Are you aware of the fact that the State of Texas, 10 as of 1958, had passed regulations that required a 11 minimum -- or excuse me, that required that 12 asbestos exposures be limited to a certain level? 13 A I've learned that -14 Q Okay. 15 A -- since that era. 16 Q Okay. I take it that's not something you knew in 17 the 1960s, for example? 18 A No. No. 19 Q All right. How was it that you learned that Texas, 20 in 1958, had adopted maximum concentrations -- 21 allowable concentrations for workers working with 22 asbestos? 23 A It's just come up in discussions over the years. 24 Q Okay. 25 A In talking with other engineers and -- Of course,
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1 after the cancer connection started coming to the 2 front in the mid 70s, then more and more attention 3 was focused on the finer points. 4 Q Okay. All right. Just -- Have you heard from 5 other people at Brown & Root that you've worked 6 with over the years -- is that how you learned 7 about the 1958 standard? 8 A Yes. Yes. 9 Q Okay. And in the course of those conversations, 10 while you never had any personal knowledge of 11 that -- of those regulations, you came to und -- to 12 understand from talking to older, I guess, or 13 perhaps Brown & Root employees who had been with 14 the company much longer that, in fact, those 15 standards had been in place? 16 17 MR. BROWN: Let me object. That assumes 18 facts not in evidence. He has not identified who 19 he talked to. Could be that some young whipper 20 snapper just joined the job and got out of college 21 and-knew a lot about it. Who knows. So I object 22 to your question. 23 24 BY MR. WATERS: 25 Q All right. You can answer, sir.
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1 2 MR. BROWN: If you can without 3 speculating. 4 5 A Restate that question -6 7 BY MR. WATERS: 8 Q Sure. 9 A -- because it's -- Go ahead. 10 Q What -- what you've told us already -- 11 A Uh-huh. 12 Q -- and I think the record's pretty clear on this, 13 but I just wanted to follow up, is that at some 14 point in time since you started working for 15 Brown & Root in 1974, you've had conversations with 16 other Brown & Root personnel and as a result of 17 those conversations have come to understand about 18 the Texas threshold limits for asbestos that were 19 put into place in 1958? 20 A Uh-huh. 21 Q Is that a fair statement? 22 A Yes, that is. 23 Q Okay. 24 A That is. 25 Q Can you recall the names of any of the individuals
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1 at Brown & Root that you spoke with after 1974 that 2 identified for you the fact that this previous 3 regulation had been in place, starting in 1958? 4 A I recall conversations back in the mid 70s. I was 5 working with some of the disciplines on development 6 and various standards, and insulation was part of 7 what I was involved with, and a big deal was made 8 that, hey, we get rid of the asbestos -9 Q Okay. And so -10 A -- usage. 11 Q -- in that context, y'all were discussing 12 presumably the new regulations, the OSHA 13 regulations that y'all -14 A Primarily, yes. 15 Q Okay. 16 A Yes. 17 Q And it would have come up that, in fact, these 18 gentlemen would have told you -- I understand you 19 can't recall who they were necessarily -- that, in 20 fact, there had been some previous regulations as 21 well that you had not personally been familiar 22 with? 23 A Yes. That -- that did come up. 24 Q Okay. Did you understand from speaking to those 25 gentlemen or just in general that the regulations
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1 that had been in effect since 1958 had not been 2 routinely followed by Brown i Root over the years? 3 A To the best of my recollection, the regulations 4 were not that well known or understood up until the 5 mid 70s. In other words, there was not an intimate 6 knowledge of what was involved there. 7 8 MR. WATERS: Okay. Let me object. And 9 I'm gonna make an objection that your answer was 10 nonresponsive to my question. Don't take that in 11 the wrong way. 12 13 A Okay. No. No. That's all right. 14 15 BY MR. WATERS: 16 Q My -- my specific question was -- and I think you 17 sort of answered it, but my specific question was: 18 As a result of those conversations, did you come to 19 understand that Brown & Root had not routinely 20 followed or had not been focused on the 1958 21 regulations that had been in place? 22 23 MR. BROWN: Excuse me. You've asked two 24 questions. 25
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1 MR. WATERS: I'll -- I'll break it down. 2 3 MR. BROWN: Followed or focused on. 4 5 MR. WATERS: I'll break it down. 6 7 MR. BROWN: I don't mind the -8 9 MR. WATERS: I'll break it up. 10 11 MR. BROWN: -- focused on. 12 13 MR. WATERS: Withdraw the question. 14 15 BY MR. WATERS: 16 Q In the course of those conversations, Mr. Heit, did 17 you come to understand that with respect to the 18 1960s, Brown & Root had not routinely followed the 19 1958 regulation, that there had not been a policy 20 to do so? 21 A We're -- we're looking at two areas here. The -22 My side of the house at that point in time was 23 primarily engineering people. And the engineering 24 people would not have had any direct input to site 25 safety activities so that they would not have had
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1 any direct interest in the monitoring functions at 2 the job site. 3 Q Okay. And the people you had your discussions with 4 in the mid 70s would have been engineering folks? 5 A That's correct, yes. 6 Q All right. 7 A Uh-huh. 8 Q And what you're telling us is that to the extent 9 there may have been asbestos exposures in the 60s, 10 or going back to 1958, that's something the 11 engineering people would not necessarily be 12 concerned or involved with? 13 A That's correct, yes. 14 Q Okay. 15 A Uh-huh. 16 Q And I think you've already told us that at least 17 prior to the early 70s that prior -- you would be 18 very surprised if there was any air monitoring with 19 respect to -20 A Yes. 21 Q -- asbestos levels done? 22 A Yes. Yes. 23 Q Okay. You talked about the -- I think you used the 24 term the cancer connection. 25 A Uh-huh.
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1 Q Do you remember using that term?
2
A Yes.
Yes.
3 Q Okay. Have you been made aware over the course of
4 your experience with Brown & Root that there were
5 some studies completed in the early to mid 1960s
6 that confirmed that asbestos exposure could cause
7 cancer?
8 A I've heard bits and pieces on that. I have not
9 heard or seen anything --
10 Q Okay.
11 A -- that I would use as definitive. In other words,
12 I -- I've never read any -- any reports like that
13 myself.
14 Q This morning in deposition -- Ithink the jury will
15 hear this in trial -- Dr. Cagle, who is testifying
16 on behalf of Brown & Root, testified that as early
17 as the 1930s and on up to the 1960s there were
18 hundreds or even thousands of articles that
19 discussed the fact that asbestos -- people exposed
20 to asbestos could get cancer as a result of that.
21 Have you ever been made aware by Brown & Root of
22 that cancer connection?
23 A I have not. I'm surprised to hear the numbers of
24 articles that he's quoting.
25
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1 MR. BROWN: In fairness to you, Mr. Heit, 2 he didn't say that. Counsel had to remind him of 3 some earlier testimony. 4 5 BY MR. WATERS: 6 Q In any event, the cancer connection was brought to 7 your attention by Brown & Root the first time in 8 the -- approximately the mid 1970s? 9 A I'm not gonna say specifically Brown & Root. 10 Q Okay. 11 A Because I do read a lot of technical journals. In 12 the mid 70s it just all of a sudden came on the 13 scene. 14 Q What you're basically telling us is that from the 15 standpoint of the media and the public at large, 16 there was a lot more information in the latter part 17 of the 1970s about asbestos and cancer? 18 A Yes. Yes. 19 Q Let's talk about your -- Well, let me -- let me 20 back up. I had a couple morequestions. 21 A Sure. 22 Q When you interviewed with Brown & Root in January 23 1967, were you interviewing for the -- a job of 24 project engineer? 25 A No.Primarily, job asspecification engineer or
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1 design engineer. 2 Q At that time was Brown & Root a large company? 3 A Large is relative. 4 Q That's right. 5 A Compared to the organization I had been with, yes, 6 Brown & Root was a large organization. 7 Q Okay. Do you know when Brown & Root first had 8 industrial hygienists on its staff? 9 A I have no idea. 10 Q Do you know if they have industrial hygienists on 11 their staff today? 12 A I know they do today. 13 Q Okay. 14 A Uh-huh. 15 Q Just to clarify, the -- the OSHA consulting that 16 you did up until 1974 when you went to work for 17 Brown & Root -18 A Uh-huh. 19 Q -- did not include work related to asbestos? 20 A That is correct. 21 Q Okay. 22 A I'd gone into an OSHA school in '72, and I do not 23 recall anything specifically being brought up about 24 asbestos at that program. 25
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1 MR. WATERS: Okay. Let me object to the 2 nonresponsive portion of that answer. 3 4 BY MR. WATERS: 5 Q Another one of the companies you interviewed with 6 was Exxon? 7 A Uh-huh. 8 Q Did you come to understand after you began to work 9 for Brown & Root, if you didn't already, that 10 Brown & Root was the most significant contractor 11 working for Exxon in this area? 12 A I've never heard that. 13 Q Okay. 14 A I would not be surprised. 15 Q All right. Have you personally been involved with 16 projects undertaken on behalf of Exxon by 17 Brown & Root at the Baytown facility? 18 A Not directly. 19 Q Okay. Indirectly have -- do you have some 20 knowledge about that? 21 A At the present time, I've supplied a number of 22 engineering standards out to work that's in 23 progress at Baytown, and I -- I've put up material 24 for other Baytown-related projects. 25 Q Is it your understanding, based on your experience
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1 with Brown & Root, that the relationship between -2 between Brown & Root and Exxon, and specifically 3 pertaining to the Baytown facility, goes back all 4 the way to the 1940s? 5 A I'm not familiar with that. 6 Q Okay. Do you know whether or not Brown & Root was 7 involved with construction and maintenance projects 8 at the Exxon facility in the 1950s, 1960s -- or 9 1960s? 10 A I do not have any knowledge of what Brown & Root 11 might have been doing with Exxon at that point. In 12 fact, Exxon did not exist in the 50s and 60s. 13 Q Was it -- What was itcalled.Standard? 14 A No. No. 15 Q ESSO? 16 17 MR. KALE: Humble. 18 19 A Yes, sir. The facilities that we know primarily 20 down here today as Exxon were Humble Oil. 21 22 BY MR. WATERS: 23 Q Okay. 24 A But they were owned by what was then known as 25 Standard of Jersey or Eastern State Standard Oil,
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1 or more better known as ESSO. 2 Q Let me ask the question a different way because I'm 3 glad you brought that up. In -- in the course of 4 your work from '74 to the present, have you come to 5 understand that Brown & Root did work at the 6 Baytown facility, regardless of who -- who they -7 what they called the owner at the time? 8 A Yeah. I knew that there had been work out there. 9 Q Okay. And did you understand that that work went 10 all the way back to 19 -- to the 1940s? 11 A No, I did not know that. 12 Q Okay. How far back did you understand that that 13 work had gone, or do you understand? 14 A To the best of my recall, I have not heard of any 15 work with Exxon prior to the 60s. 16 Q Okay. All right. I'd like to ask you some 17 questions about your work with Exxon from 1974 to 18 the present. And I guess more particularly, let me 19 just ask the question this way, in a general sense. 20 Have you continued to have some involvement with 21 hearth and safety issues from 1974 to the present? 22 A Health and safety issues have always been a 23 companion part of basic engineering work. And with 24 my work in standards and specifications, I have had 25 to pay attention to health and safety issues
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1 wherever they became evident. 2 Q All right, sir. Have you had any involvement with 3 Brown & Root related to health and safety and 4 specifically asbestos or the hazards of asbestos? 5 A Yes. I end up, more or less, being the final check 6 point on the publishing of the -- the company 7 engineering standards, so one of the things that I 8 have kept an eye out for is anything that -- that 9 would specify asbestos. And it's -- it's part of 10 my duty to eliminate that from the standards, or at 11 least control it. 12 Q Just to make sure I'm clear, are you speaking of 13 circumstances where you'd received specifications 14 from a potential customer? 15 A No. No. No. 16 Q Specifications from a supplier of machinery or 17 equipment? 18 A No. 19 Q No? 20 A No. 21 Q All'right. Youbetter explain it. 22 A Okay. It's part of my program to take in 23 specifications from our individual design 24 disciplines. For example, right now I have a brief 25 concrete specification that would be used for
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1 concrete work on small projects. That comes to me 2 ready for final issue. I check it for overall 3 format, general order and general technical 4 accuracy so that if that specification would have 5 called for asbestos fiber as a mineral fiber 6 binder -- by comparison, there -- there are such 7 things as plastic fiber binders -- that had that 8 specification in reference to asbestos, I would 9 have had to call a meeting with the civil people 10 and essentially drawn the line and said no, you 11 can't do that. 12 Q Okay. So you kind of, in that capacity, act as a 13 watchdog to make sure that the specifications don't 14 require the use of something as hazardous as 15 asbestos? 16 A That -- that's one of the things. 17 Q Sure. 18 A That's one of the many. With all due respect to 19 the young lady right here, I've been told that part 20 of my mission is to catch any of the dumb ass 21 mistakes that come across my desk. 22 Q And clearly in this day and time, and I guess, 23 perhaps, any time after 1975, you would 24 characterize specifying the use of asbestos as just 25 one of those kind of mistakes, wouldn't you?
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1 A Yes, but there's exceptions. I had talked about 2 asbestos cement pipe. And in a perfect world, we 3 would say, hey, no more asbestos pipe. So in our 4 underground piping specs today, the national 5 specification for asbestos pipe is listed, but 6 there's a big note that says we do not use this 7 under ordinary circumstances. If the customer or 8 client is requesting this, there has to be 9 coordination through with the Brown & Root legal 10 department. 11 12 MR. WATERS: Okay. Let me just for the 13 record object to everything after yes as -14 15 A Oh, I'm sorry. I -16 17 BY MR. WATERS: 18 Q No. No. You go right ahead and answer the 19 questions as best you can. Don't worry about -- 20 That's just a technical legal thing. 21 A Well, there was a -- an exception to the basic rule 22 is what I was trying to indicate. 23 Q I appreciate that very much. One of the reasons 24 that you, in that watchdog role, watch out for 25 specifications that might require some kind of
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1 asbestos is because you don't want for some 2 future -- for in the future some individual to be 3 exposed to asbestos and run the risk of developing 4 cancer and all that that might entail? 5 A That's correct. That's a good expression. 6 Q Okay. How large was Brown & Root when you arrived 7 as an employee in 1974? And -- and perhaps the 8 best way for me to ask you the question is in terms 9 of number of employees. And I'm just really 10 looking for -11 A That's an illusive number. This is a ballpark 12 guess. I'm gonna say maybe 20, 25,000 employees. 13 Q Wow. Okay. When you became aware after starting 14 with Brown & Root that Brown & Root had known 15 previously of the 1958 standard that we talked 16 about, when you became aware of that, did you 17 consider that given Brown & Root's size, given 18 their significant involvement in the construction 19 industry, that's precisely, the kind of information 20 they probably should have been aware of? 21 22 MR. BROWN: Excuse me. Let me object. 23 There's no evidence that Brown & Root knew. What 24 the man testified to was he may have had some 25 discussions with some employees, but that's not to
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1 say that that ever was communicated to whomever -2 3 MR. WATERS: Let -- let me -4 5 MR. BROWN: -- speaks on behalf of the 6 company. 7 8 MR. WATERS: I'll withdraw the question. 9 Try this -- try this another way. 10 11 BY MR. WATERS: 12 Q Given the size of Brown & Root and the nature of 13 their operations, sir, would you anticipate that a 14 company like Brown & Root would have known about 15 the 1958 asbestos standard? 16 A I'm gonna have to say no. 17 Q Okay. But what you have -18 A Can I tell you why? 19 Q No. That's okay. 20 A Okay. 21 Q I might come back to that. What you do know is, 22 from talking to these various individuals, that, in 23 fact. Brown & Root did know about it. Can you tell 24 us how Brown & Root learned about the 1958 25 standard?
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1
A No, I can't.
Icannot answer that.
2 Q Okay.
3 A I have no idea. 4 Q We'd have to talk tosomebody who was with the
5 company a long time ago in order to determine that,
6 I presume?
7 A I would
8
9 MR. BROWN: Excuse me. That calls for
10 speculation. Object.
11
12 BY MR. WATERS:
13 Q You can answer.
14 A I -- I agree. That would be a logical assumption.
15 Q Are you aware of anyone today that you work with or
16 know at Brown & Root who was employed by the
17 company in the 1950s?
18 A At this point in time, no, I do not.
19 Q Other than your involvement and yourconcerns about
20 specifications that may requirethe use ofasbestos
21 that you just described, --
22 A Uh-huh.
23 Q -- have you had any other involvement with the
24 hazards of asbestos from 1974 to the present?
25 A Not that I can recall.
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1 Q Okay. I'm sorry. I -- I think I asked you this 2 question before, but I don't recall your answer. 3 Did you say that you had been involved with some 4 projects at Exxon Baytown since 1974? 5 A Yes. I have put up specifications and procedures 6 that are used by our people. 7 Q Okay. Are you aware that -- that there's a 8 long-standing policy that when Brown & Root 9 employees, or for that matter other contractors' 10 employees work at the Exxon Baytown facility, they 11 are required to follow Exxon safety regulations? 12 A Yes. Yes. 13 Q Okay. And that's not particularly surprising, I 14 suppose. Isn't that probably true with a lot of 15 the big industrial premises owners when they have 16 contractors come to their facilities, they -- they 17 require them to follow their safety policies? 18 A This day and age, to the best of my knowledge, that 19 is pretty typical. 20 Q Okay. In fact, the Brown & Root crews that worked 21 at Exxon were required to not only follow the Exxon 22 safety regulations, but to actually adopt them as 23 their own? 24 25 MR. BROWN: Excuse me here. There's been
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1 no foundation for this. You're asking the witness 2 to speculate. I didn't understand that he did 3 anything in Exxon other than to send out some 4 engineering standards. And if those, in fact, 5 encompass this, then I withdraw the objection. 6 Other than that, I don't see how he's in a 7 position to know what may have happened if he was 8 not there. 9 10 BY MR. WATERS: 11 Q All right. Let me reask my question, in light of 12 the objection. 13 Have you also understood that there has been a 14 long-standing requirement that Brown & Root crews 15 that work at Exxon -- Exxon Baytown not only are 16 required to follow Exxon safety regulations, as 17 you've testified, but are also required to actually 18 adopt Exxon's safety requirements as their own? 19 A No. I'm not intimately familiar with any kind of 20 relationship like that because I have visited the 21 Baytown job site just maybe once or twice for a 22 short-term visit and was never put through any of 23 the site indoctrinations that typically occurs when 24 a Brown & Root employee goes on a client property. 25 Q Well, you called the process site indoctrination?
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1 A Yes. 2 Q And that's where the -- the premises owner fully 3 instructs the contractor, superintendent and the 4 contracting crews what rules and regulations 5 they're to follow? 6 A Okay. I'm using it in terms of an individual like 7 me going to that job site and I'm gonna go out to a 8 work area. Then, in most cases, my company is 9 required to indoctrinate me and familiarize me with 10 what the site requirements will be. 11 Q Okay. 12 A That's how I'm using indoctrinated. 13 Q All right. Okay. I think I understand. So 14 basically, the Brown & Root policy, in compliance 15 with Exxon's policy, would be to acquaint you, 16 before you go out there and before you get on site, 17 with what the safety rules and requirements are? 18 A I can't answer that for sure because I'm not even 19 remotely familiar with what relationship exists 20 there. 21 Q Okay. 22 A I've neverseen any of that. 23 Q Brown & Root has had a safety department for a -- a 24 long time, correct, before you -25 A To the best of myknowledge, yes.
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1 Q In your experience, has the Brown & Root safety 2 department made every effort to try to be aware of 3 any hazards that its employees might encounter? 4 5 MR. BROWN: Excuse me here. There's no 6 foundation for this, and unless he somehow knows 7 what they've done, you're asking him to speculate. 8 You can answer it if you know. 9 10 A I cannot give you a hard and fast answer on that. 11 I know from company publications that Brown & Root 12 does emphasize workers' safety to a high degree. I 13 do know that Brown & Root realized a long time ago 14 that it's very worthwhile from a monetary point of 15 view to take good care of your employees and 16 promote a strong safety program. The monetary 17 value, of course, is reflected in the lower 18 insurance rates. So there's both an altruistic and 19 a monetary driving force here. 20 21 BY MR. WATERS: 22 Q Did you become aware of that attitude or that 23 policy, if you will, sometime after you came to the 24 company in 1974? 25 A No. I knew a lot of Brown & Root people when I --
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1 when I first got down here in the late 60s and I -2 I picked up on that immediately. 3 Q Okay. Did you understand from that experience and 4 from your experience actually as a Brown & Root 5 employee that Brown & Root wanted to be aware of
f 6 any hazards its employees might encounter so that 7 it could warn those employees and assist them in 8 avoiding injury? 9 10 MR. BROWN: Here again, there's no 11 foundation, and I think you're asking him to 12 speculate unless he has some involvement in that. 13 14 A That -- that's a very complex question. I can't 15 give you any specifics that -- that I could detail 16 out with respect to that question. 17 18 BY MR. WATERS: 19 Q Well, let me just ask in the context of 1974 to the 20 present. Has it been your experience that 21 Brown & Root has made efforts to understand and 22 determine what hazards there are so they can warn 23 their employees and their employees can avoid 24 injury? 25 A Yes.
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1 Q Okay. 2 A Yes. 3 Q And those efforts on the part of Brown & Root, for 4 example, would include determining and 5 understanding what types of exposures could be 6 toxic or hazardous to workers' health? 7 A Yes, sir. 8 Q Do you have any knowledge about the membership of 9 Brown & Root in the National Safety Council? 10 A I do not. 11 Q Okay. Did you know that they were a member of the 12 National Safety Council? 13 A I do not. 14 Q Okay. 15 A Even today I -- I could not answer that question. 16 Q I guess you are aware from your involvement with -17 with the company and your understanding of the 18 nature of their -- that the work that they do, that 19 at least up until the middle 1970s, Brown & Root 20 was involved with numerous projects, either 21 construction or maintenance, that utilized asbestos 22 as a thermal insulating material? 23 A I do not know that for a fact. 24 Q And my question to you is if you are aware of that 25 or do you have an understanding of that based on
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1 what you've learned since 1974 in the context of 2 the historical work that the company's done. Have 3 you come to understand that up until that time 4 frame, approximately when you joined the company, 5 Brown & Root was involved with construction work 6 that utilized asbestos thermal insulation as part 7 of the construction process? 8 A I do know that asbestos was in some of our 9 standards back in that era. 10 Q Okay. 11 A Now, as to what extent asbestos was used, I cannot 12 give you an accurate picture at all. 13 Q Have you reviewed any of the documentation in this 14 case that pertains to the contract for building 15 Units 2 and 3 of the Valley Plant in Savoy, Texas? 16 A Yes. I've had an opportunity to review the cost 17 reports, and cost reports only. 18 Q Okay. Have you not reviewed the contracts? 19 A No, sir, I have not seen the contracts. 20 Q They were not provided to you? 21 A No, sir. 22 Q Did Brown & Root retain or hire insulators on a 23 routine basis to complete insulation work at the 24 various facilities where they performed 25 construction activities?
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1 2 MR. BROWN: At what point in time. 3 Counsel? 4 5 MR. WATERS: Any time that he's familiar 6 with. 7 8 BY MR. WATERS: 9 Q Let's say -- let's say when you started with the 10 company, 1974. 11 A Insulation is -- and I -- I can't guarantee this, 12 but insulation is one of those necessary evils on a 13 project that gets done, depending on the job 14 circumstances. Specifically, you have two parts in 15 the insulation. One is the procurement of the 16 material, and two is the actual insulation or 17 application. So depending on circumstances, as I 18 understand it, one job Brown & Root might buy the 19 insulation and hire the insulators and put it in as 20 a Brown & Root part of the job. Another time they 21 might subcontract out the purchase and the 22 insulation. Another time they might buy the 23 insulating material and then hire an insulation 24 subcontractor to install the material purchased by 25 Brown & Root. And to the best of my knowledge,
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1 there's no direct policy as to how any one given 2 project is going to administer that segment of the 3 contract. 4 Q When Brown & Root did directly employ 5 insulators, -6 A Uh-huh. 7 Q -- would it employ them -- would they be union 8 workers? I'm sorry. Would they be members of a . 9 union? 10 A In all probability, I believe the answer to that 11 would be no. 12 Q In fact, did Brown & Root have a policy of trying 13 to avoid hiring union members in this time frame? 14 A I cannot answer that because I'm not familiar with 15 that end of the business. 16 Q Hiring? 17 A I -- I've never -18 Q When you said in all probability, no that 19 Brown & Root would hire union members to do 20 insulating work, what was the basis of your 21 statement, or why is it that you feel that way? 22 A Brown & Root has always promoted the merit shop 23 philosophy. From the earliest days. Brown & Root 24 has been a merit shop organization. 25 Q So theyhaveessentially, to the extent possible,
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1 avoided hiring union labor for a variety of -- of 2 crafts? 3 A Okay. Maybe I'm not interpreting the question 4 correctly. I don't know that Brown & Root would 5 exclude an individual that put in an application 6 because he was a union member. I don't know -- and 7 again, I'm an innocent in this area. I don't know 8 how Brown & Root could identify a union man if he 9 showed up at the hiring office. Now, when you 10 first started talking unions, I was thinking of 11 union subcontractors. And I doubt that union 12 subcontractors would want to come on a site, and I 13 doubt that union men would want to come on site 14 either. 15 Q Okay. Insulation work, I think you described it as 16 a necessary evil? 17 A Yeah. Yeah. 18 Q Okay. 19 A Yeah. 20 Q It was a dirty job, but somebody had to do it? 21 Fair statement? 22 A Yes. 23 Q Okay. 24 A Like several otherson a typical construction job. 25 Q Okay. Since 1974, have you been involved with the
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1 construction of any power plant or power generating 2 units? 3 A At the construction site, no. I have been involved 4 with some of the design side. 5 Q Have you reviewed the documentation in this case 6 that pertains to the change orders and the actual 7 insulation work done at the Valley Unit No. 3? 8 A I'm totally unfamiliar with what you're talking 9 about. 10 Q Okay. 11 A I didn't see any trace of that in the cost -- final 12 cost reports. 13 Q What is the final cost report, by the way, that -14 that you did review? What -- what is that document 15 so I can understand? 16 A It's a summary of where the money was spent. It's 17 a breakdown of labor and materials for the various 18 parts of the plant. 19 Q At the end of the day? 20 A No -- Well, some of it was prorated by number of 21 workers on a week-to-week basis. The other was -22 was essentially a final summary of how many dollars 23 were spent on insulation, how many dollars were 24 spent on electrical. There were some percentages 25 of over and under. Each one was only less than a
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1 hundred pages each. 2 Q Okay. Have you ever observed construction 3 activities at a power plant at any time? 4 A Yes, I have. 5 Q Where would that have been? 6 A The Parish generating station up here -- I believe 7 it's Route 2 -- was Route 249. I believe it's 149 8 now. 9 Q Somewhere in the Houston vicinity? 10 A Yeah. Yeah. It's down south of the Willowbrook 11 Mall. 12 Q Did Brown & Root build that facility? 13 A At the time I went out there. Brown & Root was 14 doing some additional work. I don't know that we 15 were the original contractor there. 16 Q When was it that you made that trip? 17 A I'm gonna say in '74 or '75. 18 Q Are you familiar with plans for the construction of 19 other power generating units other than the one you 20 just described? 21 A I did some work for the Florida Power & Light. 22 This was early on when I joined Brown & Root in 23 early '74. I was part of a three-man team that 24 designed a huge cooling tower complex. Then I put 25 up other various standard documents, standard
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1 specifications that were used by other power plant
2 projects. Then I was what you might say the point
3 man in getting Brown & Root's first radioactive
4 source license for doing on-site radiography. This
5 was primarily for power plants. I was the point
6 man in getting Brown & Root's initial quality
7 control manual approved by the American Society of
8 Mechanical Engineers. And this was a -- a new
9 requirement that had been promulgated by ASME in
10 '73, then I picked up on it in '74. And of
11 course -- Are you familiar with ASME?
12 Q I think so. It's the American Society of
13 Mechanical Engineers?
14
A Correct.Correct.
Yes.
15 Q In reviewing the -- the documentation that you were
16 provided concerning the construction at Valley 3,
17 did you see anything that was of significance to
18 you concerning this case?
19 A There was one mention of what was apparently a
20 brand name for asbestos insulation, and I think it
21 may have been J-M, or Johns-Manville. As I recall,
22 their trade name was Thermobestos.
23 Q Okay.
24 A And that was in one of the little short
25 descriptions on some of the insulating work.
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1 Q And the document presumably priced out, for 2 example, just how much money was spent on -3 A Yes, sir. 4 Q -- Thermobestos, among other things? 5 A Yes. Yeah. Yeah. 6 Q Do you understand that the J-M Thermobestos that 7 was identified was an asbestos product? 8 A I assume that it probably was. 9 Q Okay. 10 A I have no hard and fast information that would tell 11 me yes, it was or no, it wasn't. 12 Q Do you have any opinions concerning the nature of 13 the work that was done at the Valley Plant Unit 14 No. 3 from 1969 to 1971? 15 A With regard to what? 16 Q With regard to the nature of the work, the way it 17 may have been done, the materials that may have 18 been used, anything of that nature. 19 A The best I can offer is that Brown & Root, by and 20 large, has left a remarkable track record in the 21 work that they have designed, the work that they 22 have constructed and the work that they have 23 designed and constructed. I believe there's very 24 few people who really comprehend the extent of what 25 this company has done over the years.
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1 Q All right, sir. And if I understand you correctly, 2 what you're saying is from the documentation that 3 you've reviewed, from an engineering standpoint, it 4 would appear that the construction was done the way 5 that it should be done? 6 A Yes, sir. 7 Q Okay. 8 A Yes, sir. There's -- there's a lot of key things 9 that I could spot in the -- just in the final cost 10 report. I could see the exotic materials that were 11 used in some of the piping and some of the valves. 12 I recognize some of the premium subcontractors that 13 were involved there, Babcock and Wilcox, and I 14 believe there were some General Electric 15 generators. When you see those kind of names in 16 the order to the overall package, it fits with what 17 I've worked with in other standard documents. In 18 other words, this is where a standard document 19 should end up. So just with a few minutes of 20 review, I could see it was a typical project. 21 Q So your opinion would be that the project was well 22 designed and apparently well constructed? 23 A Yes, sir. Yes, sir. Based on what I've had an 24 opportunity to look at. 25 Q Sure. And you've told us a little bit about that.
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1 Do you have any other opinions that you derived 2 from reviewing any of the -- of the documents that 3 were provided to you by Brown & Root or by 4 Brown & Root attorneys? 5 A With regard to anything special or -6 Q Anything else you may have seen in that 7 documentation or been asked to look for or look at? 8 A Other than that the job was done the way I believe 9 it should have been done. 10 Q Okay. 11 A I'm not sure what else I might need to be looking 12 for. 13 Q Let's take one break. He's got to switch the tape 14 and then I'll -- 15 A Okay. Okay. 16 17 (At which time, a short recess was 18 taken.) 19 20 THE VIDEOGRAPHER: We'll go back on the 21 record at 3:44. 22 23 BY MR. WATERS: 24 Q Mr. Heit, let me ask you a few more questions about 25 the job, the work at the Valley Plant. Am I
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1 correct that your only knowledge about that plant, 2 that project, that work was what you gleaned from 3 reviewing the cost breakdown? 4 A Correct. Yes. 5 Q Okay. Have youhad any interviews --excuse me. 6 Have you had any conversations with anybody else at 7 Brown & Root concerning that job? 8 A Just thesuperficial conversations that I've had 9 with Mr. Brown and the Brown & Root paralegals. 10 Q Okay. Have you learned anything about the job 11 that's of significance to you other than what you 12 learned from that documentation? 13 A No, sir. 14 Q Okay. 15 A No. 16 Q Am I correct that when Brown & Root contracts to 17 build a facility such as a power plant, they 18 typically contract to do all of the work that's 19 involved or at least to be responsible for all of 20 the work that's done? 21 A That tends to vary all over the map. We talk about 22 EPC prices -- EPC, and that's engineering 23 procurement and construction. Now, in a lot of 24 cases we do all -- we do the whole shooting match. 25 But then in a -- again, I'm gonna say a significant
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1 number of cases, the client may pick selected parts 2 of the project that they take care of themselves. 3 Q All right. EPC. "E" is engineering. That's the 4 design, correct? 5 A Correct. 6 Q "P" is procurement. That's the acquiring of 7 necessary materials to do the work? 8 A Procurement covers both purchasing and 9 subcontracts. 10 Q Okay. 11 A Then there's a lot of subservices with that. 12 Q All right.And I forgot what the "C" stood for. 13 A Construction. 14 Q Actual construction? 15 A Yes. Yes. 16 Q All right. From your review of the documentation 17 that was provided to you by the Brown & Root 18 attorneys, did you determine or did it appear to 19 you that the Valley Unit 3 job was an EPC job? 20 A It was not readily clear. 21 Q Okay. At this point in time are you unclear as to 22 whether or not that was an EPC job? 23 A I would have to say I'munclear. 24 Q Okay. There have been some contracts produced in 25 this case, contracts between Brown & Root and TPL,
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1 Texas Power & Light -2 A Uh-huh. 3 Q -- for the construction of Unit 2 and then later 4 Unit 3. The contracts appear to require 5 Brown & Root to put together the engineering 6 designs and specifications for the construction 7 projects. Is that a typical arrangement that you 8 have seen Brown & Root have in the past? 9 A No. Most often you have a starting point of your 10 design criteria document and your flow diagrams. 11 Now, your design criteria -- in fact, I have an 12 obsolete design criteria form that was used in the 13 power division up until we pulled it here a couple 14 of years ago, because it needs upgrading. But this 15 walks through all the bits and pieces that go into 16 the design of a power plant. So then that is typed 17 up with a -- a flow diagram. This essentially is a 18 pictorial representation of what you're doing. For 19 example, back in the late 60s, early 70s, it was 20 real common to have a boiler where you heated water 21 to get steam. The steam went over to what's known 22 as a steam turbine. The steam turned the -- the 23 wheels on the turbine. The steam is then pulled 24 through a cooling system, which is why you need 25 these huge cooling towers. Today, you'll most
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1 often hear about cogeneration plants. Are y'all 2 familiar with that? 3 Q I think so, but go ahead. Explain it, if you will. 4 A Okay. A cogeneration plant typically is the 5 equivalent of a jet engine like you'd have on an 6 airliner. In fact, there's one aircraft class of, 7 I guess, turbine that is used in this situation. 8 But anyway, this is a gas-fired turbine. Instead 9 of steam, you're firing natural gas in there. So 10 the -- the combustion turns the wheels. The 11 turbine itself is direct connected to a generator 12 which is generating electricity. Then you have 13 what's called a heat recovery unit on the jet 14 engine or the gas turbine. The heat is drawn off 15 the exhaust from that turbine. It's like the 16 exhaust coming off a jet airplane. That heat is 17 used to heat water, which in turn becomes steam and 18 drives a -- a steam turbine connected to a -19 another generator. That's where they come up with 20 the co -21 Q Co -22 A -- generation. So in either case, you start out 23 with this pictorial picture. Okay. This is gonna 24 be the heat source, here's the size of the 25 generator we want. Okay. Here in this part of the
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1 country lignite coal is our best fuel. So then you 2 set up your pictorial layout. You'll have a coal 3 unloader, you'll have a coal storage, et cetera, 4 and all the other pieces. So there's enough 5 definition between the design criteria document and 6 the flow diagrams that the engineer constructor and 7 the client can arrive at a reasonable cost and then 8 they have categories of estimates. They get 9 refined as the work progresses. Does that -10 Q I think that's very helpful to me. Have you -11 have you had -- other than this case, obviously, 12 have you had an opportunity at any point in time 13 since 1974 to review cost analyses or other 14 documents that relate to the specification and 15 what's to be used in the construction process? 16 A From a cost point of view, I don't recall any 17 direct cost analyses that I've been involved with 18 in any real detail. 19 Q Okay. When you looked at the -- the cost document 20 with respect to the Valley No. 3 unit, -- 21 A Uh-huh. Uh-huh. 22 Q -- did it appear to you that the -- the -- the 23 component parts and materials that were used were 24 typical for a Brown & Root project of that time 25 frame?
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1 A I cannot give you a definitive answer to that 2 because I have not looked at cost details of any 3 other power plants from that era. Just in -- in 4 broad terms, I do not see any numbers that seem out 5 of the ordinary. 6 Q Okay. You mentioned, for example, that the 7 Johns-Manville Thermobestos -8 A Uh-huh. 9 Q -- product had been used. Was that a product that 10 had been used on other occasions by Brown & Root, 11 standard insulating material that they used for 12 high temperature applications? 13 A I can't answer that. I do have some of our 14 standard specifications that go back to that era 15 and they are based on national standards and there 16 were -- I don't recall the Thermobestos being noted 17 in any of those. 18 Q Okay. Now, do you recall a product called 19 Unibestos? 20 A No. 21 Q Okay. 22 A No. 23 Q Do you recall a product called Kaylo? 24 A No. 25 Q No. Okay.
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1 A No. 2 Q Since you've come to work at Brown & Root, have 3 you -- have you learned that asbestos exposure can 4 cause the -- a disease called asbestosis? 5 A Yes. Yes. 6 Q Have you learned that asbestos exposure can cause 7 lung cancer? 8 A Yes. 9 Q Have you learned that asbestos can cause the 10 disease that is -- that is at issue in this case, 11 mesothelioma? 12 A I have to say that I've never heard that term 13 before. 14 Q Okay. 15 A That's brand new to me. 16 Q All right. So at least in the context of your work 17 at Brown & Root from 1974 here to 1996, you do not 18 recall ever being told or learning in training 19 sessions or anything of that nature that 20 mesothelioma is a cancer that can be caused by 21 asbestos? 22 A I have not -- never heard that before. It's 23 totally new to me. 24 Q What you have learned, however, sir, is -- I think 25 you'll agree with me that asbestos is an extremely
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1 hazardous substance? 2 A There's much evidence to that effect. 3 Q All right, sir. 4 A And -- Okay. Go ahead. 5 6 MR. BROWN: No. You finish your answer. 7 What else were you gonna say? 8 9 A I marvel at the exposure that automobile mechanics 10 have been subjected to in dealing with brakes. And 11 it's just been a couple years now that asbestos has 12 been taken out of brake linings. And I vividly 13 remember time and time again seeing a mechanic blow 14 out a brake lining, either when there was brake 15 work being done or when I had mentioned squeaking 16 in my brakes. And this is typically an 17 accumulation of dust. And I can vividly remember 18 many times seeing these people blow that stuff out 19 and a big puff of what had to be heavily 20 contaminated air. Yet, I'm sure they exist, but I 21 have not heard -- and now, I do not follow the 22 cancer patients, but I have not come across any 23 lung cancer cases occurring from that brake lining 24 exposure. So in my mind, that's a question mark. 25 Q As to whether brake lining exposure can cause
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1 cancer? 2 A Yes. Specifically, the asbestos that would be -3 would probably be in that dust. 4 Q The -- the situation you described with -- with the 5 clouds of dust coming from brake work, is that 6 something you observed at Brown & Root? 7 A No. No. This is in -- in having my own personal 8 automobiles serviced. 9 Q Based on what you've learned since you joined 10 Brown & Root in 1974, do you consider asbestos to 11 be dangerous? 12 A I do. I do. I personally at this point in time 13 would not make use of any asbestos product unless a 14 client insisted on it and, of course, took the -15 the liability on it. This is at the same time that 16 the technical community continues to publish 17 national consensus standards for asbestos products. 18 Q And, in fact, if you had a customer come to you and 19 specifically ask and request that a certain project 20 be completed asbestos free -- that is to say 21 asbestos not be used in the construction -- you 22 would make every effort possible to avoid using 23 asbestos in that project? 24 A Yeah. That's correct. Yes. Yes. I believe it 25 would be foolhardy to -- to take any other tact but
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1 that. 2 Q All right. And if that tacc -- if, in fact, 3 despite a customer's request asbestos was used in 4 the construction of a certain facility, that would 5 be very poor corporatepractice, would it not? 6 7 MR. BROWN: Excuse me here. You're -8 you're assuming that it's possible for a customer 9 to make that statement and -- and not be aware of 10 what actually is going on there and I think 11 that's -- that's an incorrect assumption. I want 12 to object to it. 13 14 BY MR. WATERS: 15 Q Let me ask the question again since I kind of broke 16 it up. 17 A Okay. 18 Q If, in fact, a customer specifically requested and 19 anticipated that their project would be completed 20 asbestos free, -- 21 A Yes .22 Q -- but despite that, astestos -- extensive amounts 23 of asbestos were used in the project and the 24 customer was not informed of that, under those 25 circumstances would you believe that the contractor
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1 should be responsible for any problems that result 2 from that? 3 A That's a complex question. You got a lot of parts 4 there. Let me get this straight. The customer has 5 come to me and asked for an asbestos free plant or 6 project? 7 Q Sure. 8 A I, in turn, have turned around and loaded the 9 project with asbestos? Sir, I find that is a 10 non-real situation. 11 Q You've never encountered that situation yourself 12 that you're aware of? 13 A No, sir. In all my years, I don't ever recall 14 working with an engineer that would fly into a 15 client's face in that manner. Every so often there 16 is a charlatan will come along that will parade as 17 a registered P.E. who will pull a stunt like what 18 you're talking about. Sometimes the engineering 19 community gets painted with the paint brush that 20 comes out of that. But in my 42 years of 21 experience in construction and engineering work, I 22 have not ever seen an engineer that would pull 23 anything close to that. 24 Q If that -- if that were to happen, that would just 25 indicate that engineer or the contractor just
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1 really didn't care about the safety and welfare of 2 the people that were gonna have to work in that 3 plant in the future? 4 A I can imagine there would be all kinds of 5 motivations for a move like that and they would all 6 be out of the norm of what I have seen over the 7 years. Again, I -- I cannot conceive of a scenario 8 like that. Engineers are pretty conservative 9 animals. Typically, they want to play their work 10 close to the vest. They know the -- the hazards of 11 going out on a limb. 12 13 MR. WATERS: Let me -- let me just 14 object -- 15 16 A Sure. 17 18 MR. WATERS: -- to the nonresponsive 19 portion. 20 21 A Sure. 22 23 BY MR. WATERS: 24 Q Let me ask you ifyou can envision this scenario 25 where a customermakes an informal request.
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1 informal, not in writing. 2 A Uh-huh. 3 Q Informalrequest that aproduct-- project be 4 asbestos free. 5 A Uh-huh. 6 Q For whateverreason, theproject is built using 7 asbestos. And it may be that the information 8 didn't get passed along or no one knows why or 9 perhaps it was one of those other motivations you 10 were describing earlier, I don't know. If that 11 were to happen, would you agree with me that the 12 contractor would be responsible for any resulting 13 injuries that might occur? 14 15 MR. BROWN: Well, I need to object to 16 that because you've -- you've assumed that the 17 information wasn't even passed along to the 18 contractor. 19 20 MR. WATERS: No. No. No. No. No I 21 did'not assume that. I said -22 23 MR. BROWN: I heard you say that. 24 25 MR. WATERS: I said it didn't get
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1 followed. 2 3 MR. BROWN: Well -4 5 MR. WATERS: I said the request was made 6 and not -7 8 MR. BROWN: Well, you're assuming facts 9 not in evidence. 10 11 MR. WATERS: That's fine. 12 13 MR. BROWN: And this witness has an 14 opinion quite to the contrary about that. 15 16 MR. WATERS: Well, he can -- I've asked 17 him the question. 18 19 MR. BROWN: Well, before we get through, 20 so you don't get sandbagged, we will state for you 21 what that is, if I have to ask the question rather 22 than you. 23 24 BY MR. WATERS: 25 Q Can you answer my question, Mr. Heit?
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1 A Okay. Let's get this straight. We've got a 2 client 3 Q Who's made an informal request. 4 A Who's made an informal request. 5 Q Orally, not in writing. 6 A Okay. Who -- who has he made it to? 7 Q To a representative of the contractor. 8 A Okay. Who's the representative of the contractor? 9 Q An engineer, perhaps. I don't know the answer to 10 that. Someone who has been told that they would 11 like the plant to be asbestos free. 12 A Okay. This -- this is a common problem, especially 13 on EPC jobs, because typically they are in the 14 realm of what's called cost plus. Client people -15 client reps are notorious for requesting something 16 on the site and, hey, we don't want it in writing. 17 It -- it's a real whipsaw. 18 Q Especially if it costs more, I imagine? 19 A Especially, yes. Yes. So the basic rule is that 20 you get it in writing. We have an elaborate 21 procedure for this. It starts out as a project 22 deviation notice, and it's spelled out what the 23 client has requested or one of our people has 24 identified as a problem. So a preliminary cost 25 comparison is made, the Brown & Root project
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1 manager decides is this worthy of reviewing with 2 the client in the client hierarchy. If he says 3 yes, then it is upgraded to the status of a project 4 variance notice. So at this point we sit down and 5 review the details with the client. If the client 6 agrees to the change and the cost differences, then 7 that becomes a contract change order, and that's 8 the formal route that such a change should be 9 accomplished. 10 Q Okay. 11 A Now, we've had jobs where verbal requests have been 12 honored and they always come back to haunt you at 13 the end of the job when the accountants come in and 14 want to know why we've had all these overrides. 15 Q So it's not uncommon for a customer to come to 16 Brown & Root, or a contractor, like I said, orally, 17 and say, well, we'd like you to do it a little bit 18 different way this time? That is something that 19 happens from time to time, I take it? 20 A It does happen. It's adangerous situation. 21 Q And`the proper procedure, if that does happen, is 22 for the contractor to issue a project deviation 23 notice which may become a project variance -24 A Variance. 25 Q -- notice?
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1 A Yes. Yes. Which -2 Q And that then becomes a change order? 3 A Contract change order, yes. 4 Q All right. And that's the proper way to deal with 5 a -- an oral request of that nature? 6 A Yes. 7 Q Okay. 8 A Yes. 9 Q And that'5 -- that's been the policy at 10 Brown & Root since at least '74? 11 A That's correct. 12 Q Okay. 13 A No. No. Let me back up. That probably came into 14 effect maybe in the late 70s -- 15 Q Okay. 16 A -- as we started to refine our project management 17 approach. 18 Q And in the late 70s, you established that new 19 approach, if you will, I guess in large part 20 because you were having problems with not having a 21 formal structure to deal with these informal or 22 oral requests from customers? 23 A Yes. Not only customers, but in managing our own 24 people. 25 Q Okay. And I guess that was a problem that you
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1 became aware of shortly after you joined in '74? 2 A No. 3 Q Not till later? 4 A Actually, it was maybe about the later 70s. 5 Q That you became aware of theproblem? 6 A Where I became involved in the problem. 7 Q Oh, I'm sorry. 8 A I was assigned to some design work and there were a 9 lot of changes being implemented that were not 10 being properly controlled so that -- I recall 11 procedures being implemented there to pick up on 12 changes. 13 Q It strikes me that there could be two results of 14 the old policy, both of them bad. One of them you 15 mentioned was that you follow the oral requests and 16 you wind up with cost overrides. Correct? 17 A Uh-huh. Uh-huh. 18 Q And the second possibility is that you don't follow 19 the customer's oral request and you maybe wind up 20 getting the customer upset with you for not 21 following the oral request. Is that the other 22 possibility that you've encountered? 23 A Not necessarily. The fact that you upset a client 24 rep, but keep his home office happy, may be a 25 credit.
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1 Q Okay. 2 A The idea of following an individual's -- a client 3 rep's oral request may end up disturbing relations 4 with his home office. If he's asked for something 5 that they really don't want, okay, that's gonna be 6 a source of conflict, too. 7 Q Okay. I appreciate that. When you -8 A Let -- let me mention this. 9 Q Sure. 10 A There's no carbon copy for all of this. It's 11 amazing the variations that will pop up on a 12 project. 13 Q Just to switch gears, when you arrived in 1974, 14 were they still using asbestos at Brown & Root for 15 insulation purposes? 16 A I don't think so. 17 Q Okay. 18 A From what I recall, I do not think so. 19 Q Okay. Your best recollection is sometime before 20 you got there in 1974, Brown & Root had decided to 21 stop using asbestos for insulation purposes? 22 A Yes. Yes. 23 Q Okay. 24 A And the discussions were in progress there in '74. 25 Q Okay. And, in fact, you may have become aware that
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1 asbestos thermal insulation, such as pipe covering 2 and block and cement, became unavailable after 1972 3 and 1973- It was no longer on the market. Did you 4 know that? 5 A No, I did not know that. 6 Q Okay. Well, I -- There's a whole bunch of 7 questions I don't have to ask you because you 8 weren't at the job site, so we can skip through 9 those. 10 I think you told me earlier that you would -11 given the time frame of this work, that you would 12 not anticipate that safety precautions concerning 13 the asbestos dust would have been taken by 14 Brown & Root -- been taken by Brown & Root in the 15 1969 to 1971 time frame? 16 A In my opinion, there -- there probably would not 17 have been any attention directed towards that. 18 Q All right. So, for example, they wouldn't have 19 used a wetting method or masks or ventilation or 20 barriers or warning signs, protective clothing, nor 21 would they have probably taken measurements, dust 22 measurements in that time frame? 23 A Okay. My honest opinion is I would have been 24 surprised as hell to have seen any of that taken 25 place out there --
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1 Q Okay. 2 A -- at that particulartime frame. 3 Q Tell me this, because this is something that I -4 from a technical standpoint, I've been unable to 5 fully understand. When a job like that is -- is 6 worked on over the course of a couple of years, -7 A Uh-huh. 8 Q -- do they doinsulation work intermittently 9 throughout the time frame, or is insulation work 10 done all at once in a given time frame, or how does 11 that generally work? 12 A Okay. With respect to a power plant, you have 13 essentially two major work areas for insulation. 14 One is to insulate the steam turbine and its 15 appurtenances. And the other task is to insulate 16 the pipe, okay, and -- and insulate the boiler. 17 Q Okay. So the boiler, the steam pipe and the 18 turbine? 19 A That's correct. So typically, you would wait until 20 each of these items is in place. And one of the 21 last' things you would do would be to apply the 22 insulation. For example, on your piping, it has to 23 be flushed and then hydrostatically tested. And 24 it's a mandatory requirement that all the joints be 25 visible. So just by the nature of the beast,
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1 insulation comes down towards the later stage of 2 the project. 3 Q All right. Given the nature of the project and 4 what you know about it from the documentation you 5 were provided by Brown & Root attorneys -6 A Uh-huh. 7 Q -- and given what you've told us about what safety 8 precautions might have been taken or were not 9 taken, do you believe, sir, that Brown & Root 10 workers would have been exposed to asbestos during 11 that project? 12 13 MR. BROWN: And here there's no 14 foundation for this. The gentleman was not there, 15 so you're asking him to speculate. 16 17 MR. WATERS: No. I'm asking him based on 18 the documentation reviewed and all of his 19 experience. 20 21 MR. BROWN: You're asking him about a 22 specific job site and a specific time frame, if not 23 mistaken. Counsel. 24 25 MR. WATERS: That's right.
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1 2 MR. BROWN: Did I miss something? 3 4 MR. WATERS: I don't -- Perhaps you did, 5 but I can't speak for your missing or not 6 missing -7 8 MR. BROWN: Well, if he wasn't there, I 9 think you're asking him to speculate. 10 11 MR. WATERS: Well, I don't think I am. 12 13 BY MR. WATERS: 14 Q But you can answer, sir, if you can. 15 16 MR. BROWN: If you can answer that 17 without speculating, please do so. 18 19 A Okay. One of the things that surprise me in those 20 cost reports and a little blurb on insulation, 21 apparently there was some fiberglass insulation, 22 and I believe it was mineral rock. 23 24 BY MR. WATERS: 25 Q Mineral wool?
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1 A Mineral wool insulation. And there was one other 2 non -- I believe it may have been cellular glass, 3 but I was surprised -- okay, and calcium silicate 4 was used, and this -- this is out of the cost 5 reports, so I cannot give you any indication as to 6 what extent asbestos-containing insulation was used 7 because there are these other products and there's 8 no clue there as to how much of each one was used. 9 10 MR. WATERS: All right. Let me object to 11 the nonresponsive portion. 12 13 BY MR. WATERS: 14 Q You have told us that asbestos -- Thermobestos was 15 used on the job. Correct, sir? 16 A Yes, I have. That was in the report. 17 Q Right. And you know about the use, and I think you 18 used the word application or fabrication of that 19 type of product to know that it will produce dust 20 when it's sawed or cut? 21 A Okay. Now -- now, Thermobestos, I indicated was a 22 trade name and, I believe, of Johns-Manville. I 23 have no knowledge of what percent asbestos might 24 have been in that product, if there was any 25 asbestos in there.
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1 Q Okay. 2 A Now -- now, had that product been described by an 3 ASTM requirement, I could go back to the -- Are you 4 familiar with ASTM? 5 Q Uh-huh. 6 A I could go back tothe ASTMfromthat eraand tell 7 you the percent of asbestos that would have been in 8 those materials. 9 10 MR. WATERS: All right. Let me -- let me 11 object to the nonresponsiveness. 12 13 BY MR. WATERS: 14 Q Let's go back a second. 15 A No, sir. No, sir. I would like to state I am 16 trying my level best to answer directly the 17 question you've laid on me. 18 Q Oh, that's fine, but I didn't get to finish my 19 question because you interrupted me in the middle. 20 A I'm sorry. 21 Q Let'me -- let me go back and ask it again. My 22 question to you is, sir: You've told us that 23 asbestos was used on this job, correct? You do not 24 recall testifying to that effect? 25 A I testified that I saw the reference to
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1 Thermobestos. 2 Q Let's do this. Are you telling us now at this 3 point in time, sir, that you do not believe 4 asbestos was used on that job? 5 A No, I didn't say that. 6 Q Okay. 7 A No. No, I'm not saying that. 8 Q All right. 9 A That -- that's yourstatement. 10 Q All right. Let's do this. Assume with me for a 11 moment that asbestos thermal insulation was used on 12 that job. Can you? 13 A No. No, I -- I refuse to make an assumption like 14 that. 15 Q Okay. Do you have any reason to think that 16 asbestos was not used on that job? 17 A No. 18 Q Okay. 19 A Again, I don't have anything to put my thinking on 20 it. 21 22 MR. BROWN: It's 4:15. I've got another 23 witness that's out in the hall. 24 25 MR. WATERS: I'm almost there.
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1 2 MR. BROWN: Can you give me some idea how 3 much longer we might be? 4 5 MR. WATERS: Oh, probably five or ten. 6 7 MR. BROWN: Otherwise, I'm gonna send him 8 home. 9 10 MR. WATERS: Well, we'll be almost done. 11 We won't have to -- we can start right on him. 12 13 MR. BROWN: All right. 14 15 BY MR. WATERS: 16 Q All right. Fair statement that you don't have an 17 opinion as to whether or not people would have been 18 exposed during the operation? 19 A Yes. Yes. That's correct. 20 Q All right. Okay. Likewise, you don't have an 21 opinion as to whether or not subcontractors' 22 employees may have been exposed during the project? 23 A No, sir, I do not. 24 Q All right. And similarly, you don't have an 25 opinion one way or another as to whether or not
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1 employees of the Texas Power & Light Company may 2 have been exposed to asbestos during the course of 3 the project operations? 4 A No, sir. 5 Q Okay. You will agree with me, sir, that OSHA, 6 which we've talked about before, you consider them 7 to be a reliable authority with respect to asbestos 8 and the hazards of asbestos? 9 A At what point in time? 10 Q At the present point in time. 11 A Today, yes. 12 Q Okay. Did you consider OSHA to be a reliable 13 authority on asbestos when you first became 14 cognizant of the OSHA asbestos regulations in the 15 early 1970s? 16 A I -- I think the record's pretty clear they were 17 not -- they were not an authority. 18 Q Okay. What criticisms do you have of OSHA and 19 their work with asbestos or concerning asbestos in 20 the early 1970s? 21 A It's not my opinion. It's out of the -- I don't 22 have them here. If you go back to the Federal 23 Register from that era -- okay. Let me back up. 24 Are you familiar with Walsh-Healy? 25 Q Uh-huh.
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1 A Okay. First the Federal Register states that the
2 Walsh-Healy monitoring requirements were apparently
3 inadequate, and then there's similar wording for
4 OSHA requirements. It is clearly stated that OSHA
5 was in confusion about the subject at the time.
6 Q About which -- which standard should apply?
7 A That's correct.
8 Q Okay.
9 A And there was not any regulation against asbestos
10 itself. The regulation dealt with the employee
11 protection.
12 Q The actual exposure?
13 A The actual exposure, yes.
14 Q Okay.
15
A So it's on up into the 80s.
In fact, I believe
16 that it's 1986 before OSHA came out with that
17 huge -- let me call it the Bible, and that remained
18 under attack. And I believe that was under attack
19 on up into the early 90s. So again, it's not my
20 opinion, but I'm simply looking at the Federal
21 Register --
22 Q All right.
23 A -- and reading the government's statements.
24
25 MR. WATERS: Okay. And let me object, to
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1 the extent you may have exceeded my question, as 2 nonresponsive. 3 4 BY MR. WATERS: 5 Q You mentioned the Walsh-Healy Act. Did 6 Brown & Root do work -- contracting work for the 7 United States Government in the 1960s, to your 8 knowledge? 9 A Yes, sir, I believe they did. 10 Q Okay. And as a result of that, they would have 11 been aware of the application of the Walsh-Healy 12 Act to health and safety practices on those federal 13 contract jobs in that time frame? 14 A I can't say definitively because I wasn't there. 15 I've never had conversations with any of the 16 Brown & Root people with regard to Walsh-Healy. I 17 do know that Walsh-Healy was not that well 18 published or disseminated in the community and it 19 was really the William Stigar Act that brought 20 Walsh-Healy to the forefront. 21 Q Were you aware that contracts with the United 22 States Government for construction projects 23 specifically stated that the Walsh-Healy Act would 24 apply to the work that was done? 25 A Yes. Yes, I know that.
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1 Q Okay. 2 A Yes. Yes. 3 Q And to the extent that Brown & Root had contracts 4 with the United States Government in the 1950s and 5 1960sr the Walsh-Healy Act would have been part of 6 those contracts, wouldn't it? 7 A I can't say for sure. I don't recall that 8 Walsh-Healy goes that far back. 9 Q All right. In any event, I guess you -10 A And I -11 Q Go ahead. 12 A If you -- if you know the date of initiation on 13 Walsh-Healy -14 Q I think it's '52, but I don't recall specifically. 15 A Okay. Okay. Now, I do know that, again, 16 Walsh-Healy did not prohibit the use of asbestos. 17 Q Right. 18 A It merely set the exposure limit. 19 Q The Walsh-Healy Act, as you've just stated, just to 20 repeat it, merely set a standard or a maximum level 21 of exposure -22 A Yes. 23 Q -- that workers working oncontracts with the U.S. 24 Government were supposed to belimited to? 25 A Yes.
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1 Q Okay. 2 A Yes. Yes. 3 Q Do you have any familiarity with Thorpe Products 4 Company? 5 A I do not. 6 Q Okay. 7 A I saw their name in the final cost report, I 8 believe, on Valley No. 3. 9 Q Okay. 10 A And I'm -- I'm attempting an educated guess there. 11 I believe it was 3. 12 Q All right. Did you look at some other plans other 13 than 3? 14 A I looked at thefinal cost report from 2. 15 Q Okay. What other documents have you looked at in 16 regards to this case or in preparation for your 17 deposition? 18 A Valley 2 or 3documents? 19 Q Yes, sir. 20 A That's it. 21 Q Have you looked at any other documents? I noticed 22 you picked up a document and were looking for a 23 reference here a few moments ago. Have you looked 24 at any other documents in preparation for your 25 deposition that may not have been related to Valley
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1 2 and 3? 2 A Yes. 3 Q And what were those? 4 A Okay. The one I found was just sort of indicative 5 of the times, and this is from the 1965 edition of 6 the American Educator Encyclopedia and they have a 7 discussion here on asbestos. Do you want me to B read the whole thing? 9 Q No. Let me -- Actually, I -- I may shortcut this 10 and just attach it to your deposition. 11 A Okay. 12 Q Is this something that you had at home? 13 A No. I -- I was able to acquire it. But 14 essentially, it describes asbestos as a harmless, 15 very utilitarian material. It goes back to the 16 days of Marco Polo and it gives all the household 17 uses that asbestos has been subjected to or 18 utilized for. 19 Q Okay. 20 A And I'd have -- I'd have to say that this is a good 21 representation of my outlook on asbestos at that 22 point in time. 23 24 MR. WATERS: All right. Let me object to 25 it as nonresponsive.
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1
2 BY MR. WATERS:
3 Q The -- what is the American Educator
4 Encyclopedia?
5 A It's one of the encyclopedia sets that has been
6 published.
7 Q Are you familiar with the Encyclopedia Britannica?
8 A Yes, I am.
9 Q And will you agree with me that of the various
10 encyclopedias that are published. Encyclopedia
11 Britannica is more well-respected, certainly, than
12 the American Educator Encyclopedia?
13 A I can't say that.
14
Q Okay.Are you
familiar with the fact that
15 Encyclopedia Britannica, in the 1940s, identified a
16 number of diseases, including cancer, as being
17 caused by asbestos, if you were to happen to look
18 up asbestos in that encyclopedia?
19 A I have not had the opportunity to look that one up.
20 Q Okay.
21 A I have no idea of what you're commenting on here.
22 Q What other documents hnve you -- have you looked at
23 in preparation for your deposition or for
24 testifying today?
25 A Okay. These are some odds and ends. This is a
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1 reference book that goes back to the 60s put out 2 by -- okay. This one was issued in '71. It's a 3 key word index to the various national standards, 4 and you can see there's many, many asbestos 5 products that were described by National Voluntary 6 Consensus Standards. 7 Q And it doesn't anywhere in this document, for 8 example, indicate how those products may be used 9 safely or how to avoid injury with those products? 10 A No, sir. This is merely a listing of titles that 11 have been simplified to allow quick access. 12 Q All right, sir. Andwhat elsehave you got? 13 A This is a listing of the asbestos products that are 14 described by National Standards, products and other 15 related activities. I have to admit I was 16 surprised to see how much there is published in 17 asbestos products even today. A few of those have 18 been updated within just the last year or so. This 19 is -- These are shots out of one of the reference 20 catalogs I use. 21 Q All'right, sir. 22 A Then this is a -- These are a couple of indexes 23 from the 1970 ASTM books, parts 12 and 14, and 24 there's some asbestos products identified there. 25 In other words, these are standards that are
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1 produced by these voluntary committees and 2 represent essentially state-of-the-art thinking. 3 Q All right. What these documents are not, however, 4 is a reflection of or discussion or presentation of 5 any of the hazards of asbestos or cancer or 6 anything of that nature? 7 A No, sir. They're -- there's no reference that I've 8 ever come across in any of the material in that era 9 that -- that denoted any hazards of the material. 10 11 MR. WATERS: All right. Let me object -12 13 A And -14 15 BY MR. WATERS: 16 Q Go ahead. 17 A Okay. Now, you'rethrowing mewith yourcomment 18 about not answering properly or -- 19 Q Nonresponsive. 20 A Nonresponsive. Well, wouldyouexplain to me what 21 you mean by nonresponsive? 22 23 MR. WATERS: As soon as I finish making 24 the same objection one more time that you've been 25 nonresponsive.
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1 2 THE WITNESS: Okay. 3 4 BY MR. WATERS: 5 Q My specific question to you, Mr. Heit, was only 6 that these documents did not appear to make any 7 reference with respect to the hazards of asbestos, 8 including asbestos. The answer to that was no, 9 they do not. 10 A Okay. 11 Q And then you went on to say some additional 12 information, which I appreciated, but I had to make 13 that objection. 14 A Okay. Okay. 15 Q All right. It looks to me like you've done -- as 16 part of your involvement with this case, you've 17 taken it upon yourself to do a little bit of 18 independent research. 19 A That's 20 Q Okay. 21 A -- correct. 22 Q All right. 23 A Do you want this last one? 24 Q I have one more question. 25 A Sure.
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1 Q I take it, however, that you did not go look in the 2 library and find any of the literally thousands of 3 articles and the medical and scientific literature 4 that discuss people dying by the hundreds of 5 asbestos-related diseases and cancers in this 6 country since the 1930s? 7 8 MR. BROWN: That assumes facts not in 9 evidence. 10 11 BY MR. WATERS: 12 Q That's not -13 14 MR. BROWN: I object. It calls for 15 speculation. 16 17 BY MR. WATERS: 18 Q That was not the type of information you were 19 looking for when you did your research, was it, 20 sir? 21 22 MR. BROWN: Counsel, the purpose for 23 these documents is in support of his opinion that 24 the use of asbestos in the power plants, such as 25 Valley, in 1967 to 1971 is proper, meets with good
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1 construction engineering standards, which is one of 2 the opinions he's going to have. That's why he has 3 that. Also to show you some evidence of the 4 knowledge as it existed under the same or similar 5 circumstances under which this project was designed 6 and built, or one like it. That's why he brought 7 you these. 8 9 MR. WATERS: I appreciate that. Thank 10 you, Phil, for telling us why he brought it, 11 12 A Now -13 14 BY MR. WATERS: 15 Q But -- but I need an answer to my question, which 16 is that you did not do that type of research when 17 you went -- research, you weren't looking for 18 information in the literature, scientific and 19 medical literature about those hazards? 20 21 MR. BROWN: And -- and you're assuming 22 that such information existed -- 23 24 MR. WATERS: Dr. Cagel testified it 25 existed.
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1 2 MR. BROWN: -- at a particular time. I 3 don't remember any particular time frame being 4 mentioned this morning, Andy. 5 6 MR. WATERS: Well, whatever. 7 8 A Let me say that I believe Brown & Root has one of 9 the most complete engineering libraries of any of 10 the engineering companies in town, and I'm not 11 aware of any medical documents that we keep out 12 there. So that -- the medical area is not 13 something that I -- I would have been attempting to 14 research. 15 16 BY MR. WATERS: 17 Q Okay. I think you've answered it. 18 A In other words, I've -- I've approached it from an 19 engineer's point of view. 20 Q What's your last document there, sir? 21 A These are some shots out of a book published or 22 copyrighted in 1969 and the title of the book is 23 "Thermal Insulation." And this is part of the Von 24 Nostrand Reinhold Environmental Engineering Series 25 and they talk about their environmental engineering
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1 series as dedicated to the presentation of current 2 and vital information relative to the engineering 3 aspects of controlling man's physical environment, 4 et cetera, et cetera. 5 But anyway, they cover all your various kinds 6 of insulations, and I've gone ahead and xeroxed 7 sheets that have reference to asbestos and a lot of 8 related material. This book was co-authored by a 9 number of insulation people. I thought that was in 10 here. 11 Q Let me take a look at it. Maybe we can just short 12 circuit this. 13 A Sure. Sure. Oh, okay. On Page 204, they talk 14 about safety requirements and it's all with respect 15 to the operating requirements for insulation, but 16 there's no mention of any -- any hazards whatsoever 17 in relation to asbestos, and this -- this 18 particular book was probably the primary insulation 19 textbook at the time. And like I say, it was 20 copyrighted in 1969. 21 22 MR. WATERS: All right. Let me object to 23 the portion that was nonresponsive. 24 25
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1 BY MR. WATERS:
2 Q This is essentially a textbook for engineers.
3 Correct, sir?
4
A Yes, sir. Yeah.That's
a good description.
5 Q It's forpeople that are involved with drawing
6 and -- the drawings and the practical applications
7 necessary to construct power plants or refineries?
8 A This is more basic. This would be used by the
9 people who were selecting the materials --
10 Q Okay.
11 A -- to be used in the particular project.
12 Q All right. If it's all right with you and your 13 lawyer, what we'll do is attach these documents as
14 exhibits to the deposition.
15
16 MR. BROWN: That's fine.
17
18 MR. WATERS: Okay.
19 20 MR. BROWN: And it's 4:30. I'm just
21 gonna release this other witness unless we're
22 finished here pretty quick.
23
24 MR. WATERS: Let me think. I think I may
25 be finished.
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1 2 MR. BROWN: Have you got anything? 3 4 MR. FISHER: (Shaking head). 5 6 MR. BROWN: We'll reserve our questions. 7 8 MR. WATERS: I'm sorry. I -- I was just 9 looking over my notes. I have one more -- one or 10 two more questions. 11 12 BY MR. WATERS: 13 Q I went through a list with you sometime earlier of 14 some precautions and -- that might have been taken, 15 and you indicated they probably were not taken in 16 that time frame. 17 A Uh-huh. 18 Q Do you recall that? 19 A Yes, sir, I do. 20 Q Are you aware that all of those precautions -- 21 precautionary measures that I read off to you were 22 suggested in the medical and scientific literature 23 back in the 1930s to avoid asbestos disease? 24 25 MR. BROWN: Again, I -- Excuse me. That
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1 assumes facts not in evidence. 2 3 MR. WATERS: Okay. 4 5 MR. BROWN: And you're asking him to 6 speculate. He's told you he hasn't made that kind 7 of analysis, so how could he be in a position to 8 respond to that? 9 10 MR. WATERS: Well, if he's not aware of 11 it, he can so answer. 12 13 A I'm not aware of that. 14 15 BY MR. WATERS: 16 Q Knowing what you know today, sir, will you agree 17 with me that asbestos products are defective -18 were defective and dangerous? 19 20 MR. BROWN: Wait a minute. Wait a 21 minute. Wait a minute. That's -- You don't define 22 defective. You certainly don't limit it to the 23 time frame at issue in this case. 24 25 MR. WATERS: I said knowing --
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1 2 MR. BROWN: It's a highly improper 3 question. You're asking for a legal conclusion, 4 and this witness, I don't believe, is qualified to 5 answer that, even if he understood the question. 6 7 BY MR. WATERS: 8 Q All right. Let me take it in pieces. 9 10 MR. BROWN: He's not gonna respond to 11 that question, Andy. 12 13 MR. WATERS: Well, then you can instruct 14 him not to answer the question. 15 16 MR. BROWN: I'll instruct you not to 17 answer. 18 19 THE WITNESS: Okay. 20 21 MR. WATERS: I haven't asked it yet. 22 23 MR. BROWN: Are you gonna ask him that? 24 25 MR. WATERS: Did you hear me? I said let
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1 me do it in pieces. And you said no, he's not 2 gonna answer it. I haven't even put the question 3 forth yet. 4 5 BY MR. WATERS: 6 Q Will you agree with me -7 8 MR. BROWN: Well, I'm gonna let the next 9 witness go unless you hurry up. 10 11 BY MR. WATERS: 12 Q Will you agree with me, sir, that knowing what you 13 know today, that asbestos thermal insulation 14 products that were used in the early 70s were 15 dangerous? 16 17 MR. BROWN: I'm gonna object. Asks for a 18 legal conclusion. You haven't framed it within the 19 area of his expertise and you haven't tied it down 20 to any specific time frame or made it relevant to 21 any of the issues at trial in this case. Nor have 22 you defined the term defective or dangerous. 23 24 MR. WATERS: I think dangerous was. I 25 was --
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1 2 MR. BROWN: You certainly haven't cited 3 any circumstances or description of what the 4 particular products are. So without any of these 5 basic elemental things, how can this witness do 6 anything but speculate? 7 8 BY MR. WATERS: 9 Q Mr. Heit, can you answer my question, sir? 10 11 MR. BROWN: And I object. 12 13 A Only if I qualify it. 14 15 BY MR. WATERS: 16 Q All right. 17 A Okay. I believe probably everyone of us in here 18 uses gasoline on a regular basis. 19 Q Probably. 20 A Okay. Would you consider gasoline to be dangerous? 21 22 MR. BROWN: It's not his deposition, 23 Mr. Heit. 24 25 THE WITNESS: Oh, I'm sorry.
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1 2 MR. BROWN: It's your deposition. 3 4 THE WITNESS: I'm sorry. I'm sorry. 5 6 MR. BROWN: If you can answer the 7 question without speculating, please do so. We 8 haven't -- One of your colleagues has been cooling 9 his heels out there for 35 minutes. 10 11 MR. WATERS: Well, let's just get one 12 answer to this final question and see if we can -13 14 MR. BROWN: If he can answer it. And I 15 think he cannot answer it. It calls for 16 speculation. 17 18 A It -- it's too broad-based a question. I can't 19 answer it. 20 21 BY MR. WATERS: 22 Q Okay. You have told us previously that you 23 considered asbestos to be dangerous, correct, sir? 24 25 MR. BROWN: Well, again, he -- you've
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1 misstated his prior testimony. 2 3 MR. WATERS: No, I'm not. 4 5 MR. BROWN: He said earlier about what 6 you think today -- some opinion, blah, blah, blah. 7 Here your question's not tied to any particular 8 time frame or any circumstances under which the 9 product may be used. And therefore, it's not 10 relevant to any issue. n 12 BY MR. WATERS: 13 Q All right. Let me see if I can clear up 14 Mr. Brown's objections. 15 Knowing what you know today, sir, will you 16 agree with me that asbestos thermal insulation 17 products that were used in the early 1970s and when 18 their use created asbestos-containing dust, that 19 those products were dangerous? 20 A I would have to qualify that kind of an answer. If 21 the .worker were wearing a -- a face protector or if 22 the material was damp, then it probably wouldn't be 23 dangerous, same as the gasoline. 24 Q All right. Fair enough. And if those two things 25 were not taking place, if the worker was not using
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1 a respirator/ if wetting had not taken place, under 2 those circumstances you would consider it to be 3 dangerous? 4 5 MR. BROWN: And again, I need to object. 6 It's -- You're just -- you're asking this question 7 without tying it down to any specific issue in this 8 case. You haven't described what the products are 9 or the circumstances. You haven't -- you haven't 10 put the worker in any proximity to the product. 11 You're asking this witness to speculate. 12 13 BY MR. WATERS: 14 Q Can you answer? 15 16 MR. BROWN: And he's not been put up as a 17 witness on the question of industrial hygiene and 18 matters such that -- such as that. He is here to 19 give you his opinions from an engineering 20 standpoint about the design, construction and use 21 of asbestos and that at the times relevant to this 22 issue. And it's outside his designation and you're 23 asking him to speculate and it's something he's 24 already told you he doesn't have expertise about. 25 Now, if you want to ask him for his personal
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1 opinion -2 3 MR. WATERS: I want an answer to my 4 question, Phil. Are you finished with your 5 objection? 6 7 MR. BROWN: If you want to ask him a 8 personal opinion, that's different. 9 10 BY MR. WATERS: 11 Q Well, can you tell me the answer to my question, 12 sir, so we can get this over with? 13 A I don't feel it would be an accurate answer or a 14 reasonable answer. 15 Q All right. Let's -- let's go back over this. 16 You've told us that you would not consider asbestos 17 producing dust to be hazardous in the early 70s if 18 the person was using protection, respiratory 19 protection or if the material was wetted down. Do 20 you recall that testimony? 21 A Yes. 22 Q All right. 23 A Yes. Yes. 24 Q I want you to assume now that neither of those two 25 protections were being taken. Under those
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1 circumstances, would you consider it to be 2 dangerous? 3 A I still can't give a reasonable answer because I 4 don't know how much of the asbestos has been 5 disturbed. I don't know how close the employee is. 6 Q Okay. But you do know one thing, and that is that 7 in the time frame 1969 to 1971, those precautions 8 were not being taken. Correct, sir? 9 10 MR. BRC'7N: Well, again -- again, if 11 you're trying to tie it to this case, there's no 12 foundation for that. You're asking him to 13 speculate. 14 15 BY MR. WATERS: 16 Q Can you answer, Mr. Heit? 17 18 MR. BROWN: He didn't even start with the 19 company until 1974. 20 21 A I do not have any hard and fast information or 22 knowledge of what occurred at that job site. 23 24 BY MR. WATERS: 25 Q All right. What you have --
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1 A I really don't. 2 Q What you have told us earlier, Mr. Heit, is that 3 under the circumstances, you don't believe probably 4 that those precautions would have been taken in 5 that time frame. Correct, sir? Do you recall 6 that? 7 8 MR. BROWN: He didn't say that. 9 10 BY MR. WATERS: 11 Q Do you recall that testimony? 12 13 MR. BROWN: That's an incorrect statement 14 of his earlier testimony. 15 16 MR. WATERS: Well, then he can tell me 17 that. 18 19 BY MR. WATERS: 20 Q But do you recall that testimony, sir? 21 A Okay. Now, I'm -- I'm afraid some words are 22 getting shifted around here. 23 Q Do you recall testifying earlier, sir, that based 24 on your experience and understanding of the work 25 that was done and the precautions that may have
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1 been taken, that this laundry list of precautions 2 probably were not taken in the 1969 to 1971 time 3 frame? Do you recall testifying -4 A Yes. 5 Q All right. 6 A Okay. 7 8 MR. BROWN: And he explained to you why, 9 too. Counsel. 10 11 MR. WATERS: Thank you, Mr. Brown. And 12 no further questions, Mr. Heit. Thank you, very 13 much. 14 15 THE WITNESS: Thank you. 16 17 MR. BROWN: Do you have any questions? 18 19 MR. FISHER: (Shakes head). 20 21 MR. BROWN: We reserve our questions. 22 23 MR. KALE: Thank you, Mr. Heit. 24 25 THE WITNESS: Thank you.
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1 2 THE VIDEOGRAPHER: Okay. Off the record 3 at 4:45. 4 5 (At this time, the instruments 6 referred to were marked Heit Exhibit 7 Nos. 2 through 7 for identification and 8 are attached hereto.) 9 10 (Signature required.) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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1 2 THE STATE OF TEXAS : 3 I, Michelle Pfeiffer, a Certified 4 Shorthand Reporter and the undersigned notary public in 5 and of the State of Texas, certify that the caption to 6 this video deposition correctly states the facts set 7 forth therein; that the examination of the witness named 8 in said caption was correctly reported in shorthand by 9 me at the time and place and under the agreement set 10 forth in said caption. 11 I further certify that this transcription 12 has been transcribed from shorthand into typewriting 13 through stenographically computer-aided transcription 14 and under my supervision in the foregoing transcript; 15 and that said transcript' contains a correct record of 16 the proceedings had at said time and place. 17 Given under my hand and seal of office 18 of , 1996. 19 20 21 22 Notary Public in ana fo
The State of Texas' 23
My Commission Expires: 7-18-98 24 25
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1 CHANGE/CORRECTION AND WITNESS SIGNATURE PAGE
2 Please indicate changes on this sheet of paper, giving the page and line number, the change and the
3 reason for the change. Please sign each page of changes.
4 Reasons for changes are: (1) To clarify the record; (2) To conform to the facts; (3) To correct
5 transcription errors.
6
PAGE LINE CHANGE FROM/CHANGE TO
REASON FOR CHANGE
7
8
9
10
11
12
13
14
15
16 I, RAYMOND A. HEIT, have read the foregoing
17 deposition and hereby affix my signature that same is true and correct, except as noted herein.
18
19 RAYMOND A. HEIT
20 THE STATE OF TEXAS :
21 SUBSCRIBED AND SWORN to before me this the day of , 1996 .
22
23 Notary Public in and for
24 The State of Texas
25 My Commission Expires:
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1
NO. 31506 2
SHIRLEY HODGE, Individually
IN THE DISTRICT COURT OF
3 and as Personal
Representative of the and
4 Estate of A. J. Hodge, Jr.,
Deceased; GREGG A HODGE and
5 ANGELA R. McClain,
6 Plaintiffs,
7 VS.
FANNIN COUNTY, TEXAS
8 TEXAS UTILITIES ELECTRIC COMPANY (d/b/a VALLEY POWER
9 PLANT), et al
10
Defendants.
6TH JUDICIAL DISTRICT
11 CERTIFICATE FOR THE VIDEOTAPE ORAL DEPOSITION OF RAYMOND A. HEIT
12 September 24th, 1996
13
Taxable Costs:
14
Charged to:
Andrew Waters, Esq.
Bar Number:
20911450
15 For:
Plaintiffs
16 I, Michelle Pfeiffer, a Certified
17 Shorthand Reporter for the State of Texas, hereby certify, pursuant to the Rules and/or agreement of the
18 parties present, to the following:
19 That this deposition transcript is a true record of the testimony given by the witness named herein, after
20 said witness was duly sworn by me;
21 ______ That signature was waived by the witness.
22 ______ That signature is in process of being obtained, but filing was requested before time allowable for
23 signature.
24 ______ That the deposition transcript by way of was submitted on to
25 for examination, signature and return to Q & A Reporting, Inc.
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1 _______ That attached is the signature page and
2 Change/Correction Sheet containing changes, if any, and the reasons therefor, made by the witness.
3 _______ That the deposition transcript and/or signature
4 page was not returned to the deposition officer by the witness.
5 That the witness failed to appear to read and
6 sign the deposition.
7 That the original deposition transcript, or a copy thereof, together with copies of all exhibits
8 provided to the reporter, was delivered on to the attorney or party who asked
9 the first question appearing in the transcript.
10 That a copy of this certificate is being sent to: the following includes all parties of record:
11 FOR THE PLAINTIFFS:
12 Andrew Waters, Esq.
13 Attorney at Law 400 South Zang
14 Suite 1420 Dallas, Texas 75208
15 (214) 941-0532 and
16 J. Todd Kale, Esq. Silber Pearlman, P.C.
17 3110 Webb Avenue Dallas, Texas 75205
18 (214) 528-2000
19 FOR THE THORPE DEFENDANTS:
20 David Fisher, Esq. Miller Thomas, Esq.
21 Fairchild, Price, Thomas & Haley 413 Shelbyville Street
22 Center, Texas 75935 (409) 598-3317
23
24
25
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1 FOR THE BROWN & ROOT DEFENDANTS:
2 Phillip S. Brown, Esq.
3 Fanning, Harper & Martinson, P.C. Third Floor Preston Commons West
4 8117 Preston Road Dallas, Texas 75225
5 (214) 369-1300
6 THE STATE OF TEXAS:
COUNTY OF HARRIS:
7
SUBSCRIBED and SWORN TO on this the
8 day of
1996 .
9
10
KICHEUI PFEIFFER
Michelle Pfeiffer \
notary public
Certification No. 32E.2J'
11
State of Texas Comm Exp. 07-16-98
Cert. Expires: 12-31-96
Commission Expires: 7-18-98
12
Q & A Reporting, Inc.
13 2700 Post Oak Boulevard
Suite 1540
14 Houston, Texas 77056
(713) 439-7441
15
16
17
18
19
20
21
22
23
24
25
Q & A REPORTING, INC. (713) 439-7441
'
NO. 31506
SHIRLEY HODGE, Individually and as Personal Representative of the and Estate of A. J. Hodge, Jr., Deceased; GREGG A HODGE and ANGELA R. McClain,
IN THE DISTRICT COURT OF
Plaintiffs,
VS.
FANNIN COUNTY, TEXAS
TEXAS UTILITIES ELECTRIC COMPANY (d/b/a VALLEY POWER PLANT), et al
Defendants.
6TH JUDICIAL DISTRICT
EXHIBITS TO THE VIDEOTAPE
ORAL DEPOSITION OF RAYMOND A. HEIT September 24th, 1996
Q & A REPORTING, INC. (713) 439-7441
NO. 31506
SHIRLEY HODGE. Individually and as Personal Representative of the and Estate of A J HODGE, JR., Deceased; GREGG A. HODGE and ANGELA R. McCLATN,
Plaintiffs, vs.
TEXAS UTILITIES ELECTRIC COMPANY (d/b/a VALLEY POWER PLANT); CSR, LTD.; BROWN & ROOT USA, INC.; BROWN & ROOT, INC. (A DELAWARE CORPORATION)and as successor to BROW & ROOT, INC. (A TEXAS CORPORATION), individually and as successor to BROWN & ROOT, INC.; THORPE PRODUCTS COMPANY; THORPE CORPORATION; J. T. THORPE COMPANY (Individually and as successor-in-interest to THORPE INSULATION COMPANY) and THORPE INSULATION SERVICES COMPANY,
Defendants.
IN THE DISTRICT COURT OF FANNIN COUNTY, TEXAS 6TH JUDICIAL DISTRICT
AMENDED NOTICE OF INTENTION TO TAKE VIDEOTAPED DEPOSITION DUCES TECUM
Vysivy EXHIBIT NO.-l--
TO ALL DEFENDANTS AND THEIR COUNSEL OF RECORD:
M PFEIFFER______
PLEASE TAKE NOTICE that, pursuant to the Texas Rules of Civil Procedure, Plaintiff,
Shirley Hodge, Individually and as Personal Representative of the Heirs and Estate of A. J. Hodge,
Jr.. Deceased, will take the following rescheduled videotaped depositions at the offices of Brown
&. Root, 4100 Clinton Dr., Houston, Texas before a certified court reporter and videotape technician:
NAME
DATE
TIME
Raymond Heit Dale Drvsdale
September 24, 1996 September 24, 1996
l :00 p.m.
Immediately
following
Mr Hell's deposition
Delbert Gaines
September 24, 1996
Immediately
following
Mr. Drysdaie's deposition
The depositions will continue from day to day until completed. .All counsel of record are invited to
attend.and cross-examine. The previously noticed depositions of Francis Weir for September 23,
1996 at 10:00 a m. and Jimmy Kubeck for September 27, 1996 at 10:00 a.m. are cancelled.
Each Deponent will produce at the time of this deposition the items listed on Exhibit "A"
attached hereto and incorporated herein.
Respectfully submitted,
SILBER PEARLMAN, P C.
3110 Webb Avenue Dallas, Texas 75205 (214) 528-2000 (214)522-7400 FAX
NOTICE OF DEPOSITION - Page 2 F 'IIOME'ANDVM'flODCE'DEPO NOT
CERTIFICATE OF SERVICE
NOTICE OF DEPOSITION - Page 3 F HON IF.'AND VWIiODGE'DEPO NOT
EXHIBIT "A"
The Ini lowing uems from Broun & Root's Industrial Hygiene Library are to be produced at eneb witness' deposition Hen-w brine the following reference books or materials-
| TITLE OF | !'i IBI.ICATION
publisher
author; EDITOR
DATE
Am Contaminants - Perm. OSHA Exposure Limits
OSHA
1989
Asbestos Alternatives
Asbestos Analyses
Asbestos Controls
Asbestos Federal Reg. & Guid. Doc.
Asbestos Information
UTHCal Tyler
UTHC at Tyler
1986
Asbestos Information
Benzene
Carcinogens Dust/Dust Controls
Tech. Resources
DHHS
1991
Epidemiology Man and Macmillian
Disease
Company
Fox, Hall, Elveback
Health Effects of Exp. To NAP Diesel Exhaust
NRC
Industrial Hygiene and Toxicology, Vol. 1-2
Wiley & Sons Patty, F. A.
MMMF - TOX & EPI
1970 1981 48-58
Occupational Diseases
Recordkeeping Guide lines for Occ. [niur.
Toxicological Profile for Asbestos
NIOSH OSHA
Clement Int. Corp.
NIOSH OSHA
1977 1970
Henriques/ 1993 Kiman
B/F/l-'O G
PCS "3
OWNER CSH
LOCATIONLSi
03-1 I7B
DTD
File ~l
F
DTD
03-120/
File # 1
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483 CSH
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DTD
03-120/
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481 CSH
03-1188
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03-120/
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339 DTD
03-120
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169 CSH
03-120
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830 CSH
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03-120/
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B
606 CSH
03-120
B
82 DTD
03-120
B
200 CSH
03-i17B
NOTICE OF DEPOSITION - Page 4 F't tO\ IF ANDYU'HODGE'.DEI'O NOT
COPYRIGHT 1969 BY REINHOLD BOOK CORPORATION All nghu ratarvad. No pan ot thti work covarad by tha copyright haraon may ba raproducad or usad in any form or try any maans --graphic. alactroruc. or macnaracal. including photocopying. racording. taping, or in formation and ratnaval ryatama--without wnttan parmiaaion from tha pubfeanar. Manufacrurad m tha Urutad Statat of Amanca.
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MALVERN F. OBRECHT. PH.D.. P.E. Consulting Editor
VAN NOSTRAND REINHOLD ENVIRONMENTAL ENGINEERING SERIES
Malvern F Obrecht. Ph D.. P. E.. Consulting Editor
Runkle
Malloy Thermal Insulation Ross Industrial Waste Disposal Microbial Contamination Control Facilities
4 Properties
of Thermal Insulation
Basic Types of Thermal Insulation
The characteristics of a thermal insulation are mainly determined by its composition For that reason thermal insulations are divided into five major types, although m many in stances particular insulations are hybrids of these types
The five maior types are
1 Flake 2. Fibrous 3. Granular 4. Cellular 5. Reflective
Flake insulation is composed of small par ticles or flakes which finely Civide the air space. These flakes may or may not be bonded to gether Vermiculite. or expanded mica, is commonly used for flake insulation.
Fibrous insulation is composed of small diameter fibers which finely divrde the air space. These fibers may be organic or inor ganic and may or may not be bonded together. Organic fibers may be of hair, wood or cane, or synthetic. The inorganic fibers may be of glass, rock wool, slag wool alumina silica, as bestos. or carbon.
Granular insulation is composed of small nodules which contain voids or hollow spaces. It is not considered a true cellular material since gas can be transferred between the individual spaces. The material may be magnesia. calcium silicate. diatomaceous earth, and vegetable cork.
Cellular insulation is composed of small in dividual cells sealed from each other. It is pro duced of glass, rubber, and plastics.
Reflective insulation is composed of paral lel thin sheets, or foil, of high thermal reflec tance and spaced to reflect radiant heat back toward its source. The spaang also is designed to provide restncted air (or gas) spaces. The restricted air space reduces heat transfer which would be caused by convection and con duction. In most instances the thin reflective sheets are made of aluminum or stainless steel.
H7
148 Thermal Insulation
Reflective insulation obtains ns results from us design and construction, it is a system rather than a single homogeneous matenal For this reason us properties wifi be discussed separa tely from those of the mass insulations
Forms of Mass Insulation
nomic installation, service life, and ther-nai efficiency
The large number of types of insulation anc forms in which it is produced almost ensures that their comparative properties will vary widely This is to be expected and desireo. as the uses of the material also vary widely
Many mass insulations are produced using
Properties of mass insulations
two or more of the types listed above. For example, fibers are added to granular material to increase the tensile strength of the product.
To obtain desired properties, frequently one type of insulation is used m combination with others, such as systems using lightweight fibers to separate reflective sheets. Another method used to reduce heat transfer is to in stall various types of insulation m a system by which the amount of air is reduced to small Quantities. These systems of insulation will be discussed further on m the Manual.
The numerous mass insulations produced have varied characteristics and are intended for many uses. For this reason insulations are produced in many forms. Some of these are:
Knowledge of the properties of insulations :s necessary for selection of the proper insula tion for specific uses. Many times, m a given installation, a certain property may be of little importance, whereas that same property may be of utmost importance m a different applica tion One of the problems in the insulation industry is that some of the manufacturers re sist providing information as to their material s properties. They feel that this information may limit the use of their material; this is an error Without this information their materials may be misused, resulting m failures and'a loss of money to the manufacturer, the contractor and the user
Many of the following listed properties are
1 Rigid boards, blocks, sheets, and pre
not -reeiy available from tne manuiact-rers cr
formed shapes such as pipe covering,
in their published literature; therefore they
curved segments, etc. 2. Semi-ngid boards, sheets, and preformed
have not been included in the Tables of Prop erties 30-38. which follow later m this chapter
shapes 3. Flexible boards, sheets and preformed
Upon occasion, however, soma of the omined properties may assume extreme importance
shapes 4 Blankets
In this case effort should be made to obtain them on an individual basis from the appropriate
5. Batts
manufacturers
6. Felts
7. Tapes 8. Ropes 9. Cements
Properties land Their Significance) of Rigid and Semi-Rigid Insulations
10. Loose 11. Fill
12. Mastics 1
The basic properties of mass insulations and the significance of these properties m choosng an insulation are as follows;
Eventually each of these forms of insulation
Abrasion resistance The property of a ma
is installed and becomes a part of an insula
terial measuring its ability to withstand abra
tion system. Its properties then become im
sion without wearing away. Abrasion is caused
portant to ensure that it will function prooerly
by the rubbing together of two abutting oo-
in the system. Thus the insulation's proper
jects or by an external force or object rubbmg
ties become of utmost importance to ns eco
against the surface of one of the objects.
Alkalinity (pH) or acidity The tendency ~>i a material to have a basic (alkafineJ or acidic reaction It is measured on the pH scale, with all readings above 7 0 alkaline and be low 7 0 acidic A reading of 7 0 indicates neutral This mcicates to which metals the ma terial may be aophed without causing corrosion
Breaking toad The property of a material which indicates its strengtn m flexure when loaded as a simply supported beam with a constantly increasing concentrated load at its center.
This property is of significance m installations where the material must ''bridge " over a dis continuity m ns support
Capillarity The property of a material which enables it to suck liquid up into or through it self.
Should a water leak occur m installed in sulation. high capillarity will spread the damage
Chemical reaction The property of a material which measures its tendency to chemically combine (or react) with other materials which may come into contact with or be absorbed by it.
This information is very important as sucn reaction may cause a fire hazard. In addition to holding the combustible liquids, the inter mixing may change the combustibility of the chemicals by lowering their flash, fire, and self-igmtion points.
Coefficient of expansion (Contraction) The property of a material which measures its dimensional change corresponding to tempera ture change.
This is necessary information in solving problems related to spacing and design of ex pansion and contraction joints in the insulation system.
Combustibility The property of a material which measures (on an arbitrary scale referred to some common material) its tendency to burn.
This information is vital in determining any possible fire hazard. If a material is combustible
Properties of Thermal Insulation 149
us potential contribution to a fire hazard is determined by the combmat'cn of the following.
1. Plash point 2. Fire pomt 3 Self-ignition point l/f any) 4 Burning rate 5 Rate of flame travel 6 Heat contribution 7 Explosion mcex 8. Self-mternal heating 9. Toxicity of products of combustion 10. Smoke index 1 1 Melting point
Compressive strength The property of a material which measures ns aDuity to resist a load tending to squeeze or shorten it.
It is one of the properties of insulation which determines its performance in service. The desirable compressive strength may be high or low. Where the insulation should support a load without crushing, high compression strength is needed. Conversely when insula tion is used to take up dimensional change, a low compressive strength may be needed. In the latter case the percentage of recovery to original size upon tne reuei of stress becomes important.
Corrosion to substrates The property of a material which indicates its chemical effect on various metals upon which it may be installed. (See "Corrosion Effect." Chapter 15.)
This is of upmost importance. If an insulation may cause corrosion to a substrate metal. either another insulation should be selected or the substrate metal should be protected by a proper coating. The fact that certain combina tions of insulations and metals may cause a corrosion of the metal makes it necessary to determine the corrosive effect of each insula tion on. for example, carbon steel, stainless steel, monel, copper, and aluminum. Of particu lar importance is the stress-corrosion effect on austenitic stainless steels.
Density The weight of a unit volume of in sulation. such as lb cu ft.
It is necessary to know the density to calcu
150 Thermal Insulation
late loadings and the heating rate when mass is one of the functions.
Dimensional stabi/ity The property of a material which indicates its ability to retain its size or shape after aging, cutting, or being subiected to temperature or moisture.
As every insulation must be installed to given dimensions, this property affects the ease of installation and also its service life
Flexural strength The property of a ma terial which measures its ability to resist bend ing (flexing) without breaking.
It is one of the mechanical properties whicn determines the suitability of an insulation dur ing application and in service.
Hardness The property of a material which measures its ability to resist penetration.
In some applications a hard surface is needed, while in others a soft surface is de sired. It is. again, one of the mechanical prop erties to be considered m the selection of a material for a given application.
Hygroscopicity The property of a material which measures ns ability to absorb and re tain water, in either the liquid or vapor state from tne ambient air. with said retained mois ture being in a state of equilibrium with the moisture in the surrounding air.
This property points up the fact that water m insulation, however it got there, must be allowed to escape without damage to the outer insulation protection. In other words, the higher the hygroscopioty. the more water the insulation will initially absorb and eventu ally have to reiect when subjected to heat. This emphasizes the need for near-perfect moisture protection in the first place. If moisture does get in. however, then the outer barrier must be of the "breathing" type to let it back out when heated.
Incidence of cracking The property of a ma terial which indicates its tendency to crack when applied to a hot surface at its recom mended maximum temperature.
This cracking affects the strength of the in sulation and its thermal conductivity.
Resistance to acids The property of a ma renal whicn indicates its abiiity to resist oe composition by various acids to wnicn it mav be subjected.
As insulation is used m all kinds of atmos pheres and conditions of chemical contamina tion. ns resistance to the acids to whicn t may be subjected affects ns service life.
Resistance to caustics The definition and significance of resistance to caustics is the same as that given for 'resistance to acics. but it is paraphrased to read "caustics" nstead of "acids."
Resistance to solvents The definition and significance of resistance to solvents is the same as that given for "resistance to acids " but it is paraphrased to read "solvents'" in stead of ""acids."
Shear strength The prooerty of a material wmch indicates its ability to resist cleavage
It is another of the mechanical properties which indicates the suitability of an"insulation during application and in service.
Shrinkage The property of a material wnicr indicates its proportionate loss in dimensions or volume when its temperature is changed
It is a major cause of cracks m high-temper ature applications. It will occur both as linear (length and width) and volumetric loss. Insula tion's shrinkage m relation to temperature should be determined m order to properly de sign insulation expansion-contraction |omts for vessels and piping.
Specific gravity--apparent The ratio of tne specific weight of a material, including all its voids, to the weight of an equal volume of water. This can be obtained by the sjmpie device of dividing the weight/cu ft of the ma terial (density) by the weight of a cubic foot of water.
Specific gravity--real The ratio of the specific weight of the mass of solids making up a material to the weight of an equal volume of water.
To illustrate the difference between these two specific gravities, glass fiber insulation
wtll have an approximate apparent specific gravity of 0 05 and a real specific gravity of 25
Specific heat The ratio of the amount of heat required to raise a unit mass of material 1 F to that required to raise a unn mass of water 1 F at some specified temperature it is essennal to know this property for solution of problems related to hea: storage and tem perature-time lag.
Temperature limits The maximum temper atures. as determined by its properties, up to and down to which a material will experience no essential change m its properties.
Within its limits a material should not fail mechanically, chemically, or thermally. These limits are determined by the effect of the tem perature on the properties listed m this chap ter. Time exposure to temperature and the number of changes m temperature have an effect on some materials. For this reason, in most instances, it is necessary to determine the following:
Max. temp.--continuous operation Max. temp.--intermittent operation Max. temp.--cycle operation Min. temp. --cycle operation Mm. temp --continuous cycle operation
Temperature rise--self-internal heating A property of some materials indicating that when heated above a certain temperature an internal reaction will occur, causing an inter nal temperature rise far m excess of the tem peratures to which they are subjected.
This internal temperature not only causes damage to the material itself, but can be very hazardous, as serious fires can result.
Tensile strength The property of a material which measures its ability to resist a stress tending to pull it apart.
It is another of the mechanical properties which evaluate the service performance of the insulation.
Thermal conductivity The property of a ma terial which indicates the relative ease or dif ficulty by which heat is transmitted through
Properties of Thermal Insulation 151
the material due to a temperature difference existing between its two surfaces (See Chap ter 1 51
As the property varies with mean tempera ture it is esseniial to know the conductivity curve of an insulation to calculate heat trans fer However, the prime value oI insulation is its resistance to heat transfer The "thermal resistivity"' of a material is the reciprocal of thermal conductivity and as it is more mean ingful should be the fundamental property listed for insulations For example An insula tion with a conductivity of 0 25 as compared to another of 0.45 appears to be not too much different. Whereas if the thermal resistivity was stated it would be 4 00 for the first ma terial and 2.22 for the second.
Thermal diffusivity The property of a ma terial which measures the time rate of tem perature movement through it. It is not a mea sure of amount of heat or heat transfer.
In many cases this is an important factor For example, in cycle operations wnere rapid dissipation of temperature is desired a high rate of thermal diffusivity is important. Con versely. when insulation is used as fire protec tion a slow rate of thermal diffusivity is most important. This little understood factor is of utmost importance in engineering these types of applications.
Thermal shock resistance The property of a material which indicates ns ability to be subjected to rapid temperature changes with out physical failure.
Th-- property is important when insulations are used on cycle operations, fast heat ups. and for fire protection.
Vapor migration The property of a material which measures the rate at which water vapor will penetrate it due to vapor pressure differ ences between its surfaces.
The water vapor which enters insulation has serious effects on ns thermal conductivity and on some of its physical and chemical prop erties. It is well known that water vapor en tering low temperature insulation will at some point condense into liquid or free2e into ice and
1 52 Thermal Insulation
will avantually destroy the thermal efficiency of the insulation However, vapor migration into insulation on ambient and hot service may cause swelling of the insulation and contribute to rusting of steel or stress corrosion of stain less steel.
Vibration resistance The property of a ma terial which indicates its ability to resist me chanical vibration, without wearing away, settling, or dusting off
Almost any insulation used in an industrial application will be subjected to some vibration, such as compressor vibration, fan pulsations, or vibrations caused by the fluids or gases passing through the lines or vessels.
Warpaga The change >n dimension of one surface of insulation as compared to that of another surface due to difference m tempera ture of the two surfaces.
Warpage will cause cracks in the finished insulation and damage to the weather and vapor barriers.
Water absorption The property of a ma terial which measures the amount of water it will soak up when submerged in water.
It is a measure of the amount of water which may be taxen into an insulation due to water leaks in weather barrier or during construction.
ft is also important as an indicator of the amount of combustible or toxic liquids which an insulation could absorb in case of spillage. However, a material may be water repellent and still be Quite absorptive when subjected to hydrocarbons, .solvents, or other penetrat ing liquids. In special cases like these, the ab sorptivity of insulations must be tested with the chemical to which n may be subjected.
Properties of Insulating Cements. Foams, and Insulating Mastics
After they are applied and dried, insulating cements, insulating mastics, foamed in place insulations, sprayed foam, and sprayed inor ganic insulations all become rigid or semi rigid and their properties are the same as those listed for the rigid or semi-rigid material. However, from the wet state to dried lor cured)
state additional properties must be consicerec as follows:
Adhesion -- wet The property of a material wnich indicates its ability to stick to the sur face to which it has been applied without slid ing or falling off.
As the temperature at the time of applica tion and the temperature of the surface to winch the material is applied affect the adhe sion. either the limns of these rwo tempera tures must be established or the adhesion lor various temperatures determined. This prop erty has direct bearing on the capability and cost of an installation.
Adhesion--dry The property of a material wnich indicates its ability to bond to the sur face to which it is applied and remain m place in service.
Temperature may alsoaffect this surface ad hesion so limits must be set. or adhesion must be determined at various temperatures.
Shrinkage--wef to dry The property of a material which measures the difference in vol umetric and linear change which occurs m the drying of insulating cements and mastics.
This change affects not only the quantities of material required, but it can also affect the finished, dried material if cracks or breaks de velop because of excessive shrinkage.
Expansion--wet state to cured state The property of a material which measures tne dif ference m volumetric change tn poured or sprayed, foamed -m -place organics.
This information is necessary in the calcula tion of quantities of material necessary to ob tain a given amount of mass insulation.
Coverage--*vf The property of a material which measures the amount of material neces sary to cover a given area to obtain a specific dried or cured thickness.
Of course this information is necessary for calculation of quantities necessary for a partic ular application
Properties of 8tanket and Ban Insulation
Since blankets and batt insulations are essen tially non-rigid, such physical properties as
flexural strength and shear, listed as properties of rigid materials, are not appfcaDie However, jther properties given for rigid materials are also properties of the non-ngid materials These include:
Alkalinity (pHI Capillarity Combustibility lor non-combustibility) Chemical reaction Compressive strength (although generally
of relatively low value as compared to rigid material) Corrosion to substrates Density Hygroscopicuy Resistance to acids Resistance to caustics Resistance to solvents Specific gravity--apparent Specific gravity--real Specific heat Tensile strength Thermal conductivity Thermal diffusivity Temperture limits Temperature rise (self internal heating) Vapor migration Vibration resistance Water absorption
In addition, properties other than those listed for rigid materials do become important m this form of insulation, namely:
Compaction or settling The property of the blankets or batts which measures their change m density and thickness resulting from loading or vibration thus producing change of thermal efficiency.
Some materials tend to fluff up when sub jected to vibration whereas others tend to compact. This factor has a definite relation to suitability of the insulation for certain installa tions.
Recovery of thickness after compression of blankets or baits after having been com pressed is a vital factor in the use of material as cushion blankets, or in expansion joints.
Resistance to air movement The property which indicates the ability of a blanket-type
Properties of Thermal Insulation T S3
material io resist erosion by air currents over ns surface
The importance of a blanket being able to resist air velocities across its surface is dem onstrated most freouently when blankets are used to line the inside of ducts.
Properties of Fill Insulations
Although the particular set of properties which is important to fill material ts slightly different from the forms of insulation previously dis cussed. each of the individual properties have already been mentioned. The important prop erties of fill insulations follows:
Adsorptivity Alkalinity Capillarity Combustibility
(or non-com bility) Chemical reaction Compaction or settling Corrosion to sub strates Hygroscopicity Resistance to acids Resistance to caustics Resistance to solvents Specific gravity -- apparent Specific gravity-- real Specific heat Thermal conduc tivity Thermal diffusivity Temperature limits Temperature rise-- self internal heating Vapor migration
Measurement of Properties of Thermal Insulation
Determining what insulation properties are important only indicates the information
154 Thermal Insulation
neeced and provides the basis of investigation The next question then becomes, how can these properties be measured and under wnat conditions should they be measured' Another question which follows u wnether or not measurements made by laboratory test are truly indicative of the properties of the mate rial m service. Does aging affect the properties' If so. how much and at what rate? What effect does temperature have on test results? What effect does moisture content have on the prop erties?
Unfortunately, testing methods and studies of properties of material are not yet able to answer all these questions. Nor is there a laboratory available which is accepted as the authority on testing of properties of insulation materials. This statement does not imply that there are no standard test methods and lab oratories to perform these standard test methods, but it does mean that the insulation industry lacks even the minimum requirements to provide reliable information. In many in stances the manufacturers of insulation have developed their own test methods and can furnish some information regarding thetr ma terials. However, the test method used by one manufacturer ts not always identical with that of another, so that the values of one cannot be compared with the results obtained by an other. This makes direct comparison of ma terial properties quite difficult. Another prob lem is that most of the mechanical properties are measured at atmospheric conditions and not at the temperatures to which the material is subjected m service. Inadequate informa tion leads to poor design, the use of improper materials, and the installation failures to which the insulation industry has become accus tomed.
In recent years progress has been made in correcting this confusion and presently there exists a number of American Society of Testing and Materials Standard Test Methods. How ever. even with standard test methods, some times it is necessary, because of the wide range m characteristics, to perform more than one test for a single property, as one test may be incapable of measuring ail the characteris
tics for the wide variety of insulation materials Thus, duplication ol test methods for a smgie property of insulations does exist and ihe proper selection must be made for the insula tion being tested. Following is a list of Ameri can Society of Testing and Materials Test Methods for various properties.
Breaking Load--Calculated Flexural Strength Block insulation -- C-203 Pipe Insulation--C-446 Organic Foam -- D-790
Closed Cell Content Organic Foam Insulations--D-194Q
Coefficient of Expansion Organic Foam Insulation---D-696
Combustibility Test for Flash Point by Tag Closed Tester-- D-56 Test for Flash and Fire Point by Open Cup-- D-92 Test for Flash Point by Pensky (Martens Closed Tester) -- D-1310 Ignition Properties of Plastics--0-1929 Determining Noncombustibility of Elemen tary Materials--E -13 6 Burning Extent of Plastic Foams--D-1692 Flame Spread--C-209 part 32
Compressive Strength Compressive Strength of Insulation Ma terial--C-165. C-354 Compressive Strength of Foam (nsulapon -0-1692
Deflection Strength Deflection Strength--C-209 (parts 14 ihru 16)
Density
Block Insulation--C-303 Pipe Insulation--C-302 Blanket Insulation--C-167 Organic Foam Insulation--0-1622 Hardness--C-569 Hot Surface Performance--C-41 1 Maximum Use Temperature--C-447 Resistance to Abrasion--C-42 1 Resistance to Dropping--C-487 Shear Strength--C-273 Shrinkage after Heat Soaking -- C-356 Specific Heat--C-35 1
Tensile Strength C-446 Tensile Strength C-209 (parts 18 thru 24) Thermal Conductivity C-177 Thermal Conductivity C-335 Thermal Conductivity C-420 Thermal Conductivity C-518 Water Absorption--C-209 (parts 26 thru 28) Water Vapor Transmission C-355
As can be seen from the above, standard test methods do not exist for all the properties of insulation listed previously. One reason is tnat some of these properties are difficult to determine, in other cases test equipment is quite expensive, few manufacturers or lab oratories have the required equipment, and an industry standard has never been devised.
It should be remembered that any labora tory test is a measure of a small sample. For certain characteristics, a small sample will provide an accurate appraisal, whereas for other materials the answer may only indicate the characteristics of that insulation. Other tests may attempt to predict the service life of insulation. Such service life tests are quite dif ficult to devise and evaluate. Yet this type of test is essential, and as the demand for it in creases. eventually such tests will Oe aevised by the industry.
Service records also assist in evaluating ma terials. Unfortunately, an early failure is costly and a successful installation requires many years to prove ns success. There is no one method of engineering all insulation instal lations. and the really difficult applications still depend upon engineenng judgment. An engi neer with an extensive knowledge of the prop erties of many insulations is m a position to make the best decision, based on available knowledge at the time of the decision.
Reflective Insulation
Reflective insulation, which consists of metal lic sheets spaced to direct the heat back to its source, must be constructed to provide space between each of the reflective sheets. As ns efficiency depends upon the arrangement of
Properties of Thermal Insulation 155
the sheets and their means of supoort. a sys tem of construction is necessary Its effec tiveness and properties are those of the sys tem and not the properties of any single ma terial used m its construction
Reflective insulation systems have been employed m the side walls and ceilings of building, and when proper spacing of layers and methods of construction are used they have proven to be extreme/y efficient.
Another use of reflective insulations has been in the construction of cold storage rooms, This type of construction is similar to that used for insulation of buildings, the only difference being that tight vapor seals must be con structed on the warm side for cold service
Reflective insulation used to insulate pipes and vessels, is a factory made product, and more closely approaches a form which can be evaluated by a list of properties. This type of re flective insulation is formed into sectional pipe insulation, fitting covers, and shaped seg ments to fit equipment. These shapes consist of reflective sheets of aluminum, or stainless steel, so formed as to have little direct contact between the sheets, or with spacers of a low conductive metal or ether material ;c form isolated air chambers between the sheets and end closures.
As a finished product these formed reflec tive insulation structures can be evaluated to have certain characteristics as follows:
Aklalinity (pH) Capillarity Coefficient of expansion Combustibility (or non-combustibility) Corrosion to substrates Cracking (in service) Hygroscopic! ty Leachabie material content Resistance to acids Resistance to caustics Resistance to solvents Resistance to nuclear radiation effects
1. Damage to material 2. Loss in thermal efficienty 3. "HalMife"
1 58 Thermal Insulation
Strength 1 Crushing a Perpendicular to longitudinal b. Parallel to longitudinal axis 2. Flexural--beam across supports 3- Impact resistance
Specific gravity--apparent Specific gravity--real
Temperature limns 1. Maximum--continuous 2. Maximum--cyclic 3. Maximum--mtermittemt 4. Minimum--continuous 5. Minimum--cyclic
Thermal emntance 1. Inner surfaces 2. Outer surfaces
Thermal conductance 1. Across total thickness 2. Per inch displacement
Thermal shock resistance Vibration resistance Water vapor transmission
axis
The reflective insulation systems are fabri cated insulation structures and do not lend themselves as easily to testing as do homo geneous materials. Thus there does not exist a senes of standard test methods for their evaluation, as exists for other materials. Since these are designed systems, the physical properties and strength required for any given installation can be engineered into the finished product, whereas with homogeneous ma terials a product naturally having the proper ties must be selected to fulfill the installation requirements.
Although each of the individual materials used in the construction may be tested by standard test methods, there presently exist few ASTM test methods which are suitable for the testing of reflective insulation systems. However as these and other cryogenic in sulation systems increase in importance tests will be devefoped.
Cryogenic Insulation
When the term cryogenic insulation is used it does not designate a specific type or system
of msuiation. put relers to tne use of msuiation in controlling heat gams to cryogenic liquids There is no established temperature below which insulation ts termed cryogenic However, it is generally understood to be m the range of -- 1 50 * F down to absolute zero 1-459 6* r)
Although homogeneous mass insulations are used for applications at the upper par; of the cryogenic temperature range, to obtam the efficiency necessary for proper control of very low temperatures, a system of msuiation using more than one material is generally em ployed Maximum efficiency to retard the flow of heat by the combined action of all heat transfer mechanisms (radiation, conduction and convection) is the aim of the cryogenic insulation systems.
Combining the principles of the control of heat transfer by mass, by reflective suostances, and by vacuum, systems have been designed to obtain thermal resistances unob tainable with ordinary mass insulations De velopment of these efficient insulations es sentially started with the discovery of the Dewar Flask by James Dewar m 1898 Further contributions to the development of these systems were made by I. A. Black. A A. rowfe and P. E. Glaser of Arthur 0 Little Company; and by P. S. Riede. 0. Wang. 1. C. Matsch. C. R. Undquist and L. R. Ntendorf of the Linde Company.
The systems of cryogenic insulations made possible by these developments are basically of two types--one type is composed of pow ders m a partial vacuum and the other mul tilayered. spaced reflective sheets in a partial vacuum.
Powders such as perlite and "Santocd" used in vacuum have a conductivity of approxi mately 0 012 Biu/sq ft. hr. in.. *F at tempera tures from 70*F to --300*F. Powders used with reflective and absorptive opacifiers of the proper formula can improve the perfor mance. Such a formula, developed by Linde, using "Santocei" and cooper powder in a vacuum has a conductivity of 0 0026 Btu/sq ft. hr. m.. *F in a vacuum of 0 05 to 5 0, mi crons of mercury, absolute pressure.
RIGID AND SEMI-RIGID INSULATIONS
Material identification
number
Insulation maienal. generic type
1 Alumina-silica fibers, combined with binders.
2 Alumina-silica fibers, combined with binaers.
3 Refractory-fiber molded, pre dominantly alumina and silica.
4 Amosite fibers and silica bind ers.
5 Asbestos sponge felts lami nated together.
6 Asbestos paper, plain and cor rugated. cemented together.
7 Catcium-siiicate. hydrous, rein forced witn small amounts of asbestos fiber.
8 Calcium-silicate, hydrous, rein forced wun small amounts of asbestos fiber, extra high tem peratures.
9 Cork, vegetable, compressed.
TO Diatomaceous silica, blended and bonded. Class I.
1 1 Diatomaceous silica, blended and bonded. Extra high tem perature. Class II.
12 Diatomaceous silica, asbestos fibers and inorganic binder.
13 Diatomaceous silica, asbestos fibers and inorganic binder.
Properties of Thermal Insulation 157
Description and general characteristics
Block insulation for exceptionally high temperature service, resists thermal shock. Block insulation -- stronger than (1) above For exceptionally high temperature services. Resists thermal shock. High temperature lightweight board.
Formed rigid pipe covering. Resists frac ture. Good cutting characteristics. Water absorbent. Formed semi-rigid block and pipe cover ing. Soft. Water absorbent. Formed semi-rigid pipe covering. Soft. Water absorbent. Molded into rigid block and pipe covering. Strong, for its weight. Good cutting char acteristics. Water absorbent, but retains most of its strength when wet. Molded into rigid block and pipe covering. Strong, lor ns weignt. Gooo cutting char acteristics. Water absorbent.
Molded into rigid blacks or sheets Strong, for its weight. Good cutting char acteristics. Will resist liquid water, but has relatively high rate of vapor transmission. Formed into rigid block and pipe covering. Good for high temperatures. Excellent thermal shock resistance. Formed into rigid block and pipe covering. Good for higher temperatures than m3tenal (10). Higher density. Excellent ther mal shock resistance. Light density rigid sheet. Good cutting characteristics. Moderate density rigid sheet, excellent strength for tts weight. Excellent cutting characteristics. Good for panels where needed in high temperatures Also serves as fire protective material.
1 58 Thermal Insulation
Material identification
nwmoer 14 15
16 17
18
19
20 21
22
23 24 25
26 27
Insulation material generic type Diatomaceous silica, asbestos fibers and inorganic binder Glass, cellular
Glass, cellular, between layers of felt.
Glass, fiber, with organic binder.
Glass, fiber, with organic binder.
Glass, fiber, with organic binder -- higher temperature limit
Glass, fiber, with organic binder.
Glass, fiber, with high temper ature binder.
Glass, fiber, with organic binders with asphalt attached facings on both sides. Glass, fiber, with organic binder with one surface coated or Treated. Glass, fiber, with inorganic binder, faced one side with vapor resistant facing.
Description and general characteristics
Heavy density rigid sheet Similar to M2) and (13! except harder and stronger
Rigid block and pipe covering Gcoc strength characteristics. Poor abrasion resistance Can be formed and fabricated rapidly Water resistant. Has almost per fect resistance to the migration of mois ture vapor
Same as material (15) except it is fabri cated into sheets between layers of felt for roof insulation.
Semi-rigid formed pipe covering Light density pipe insulation. Available with various types of factory attached jacket ing.
Formed into rigid pipe covering. Heavy density pipe insulation. Available witn various types of factory attached jacket ing.
Semi-ngid formed pipe covering, moder ate density with slightly higher temper ature limit than (17! and MS! Availaoie with various types of factory attacned jacketing.
Semi-rigid formed board or sheets of vari ous denstties. The higher the density the stronger the materia/. The higher densi ties also provide a lesser conductivity Available with various types of factory attached outer facings.
Formed semi-rigid board and sheets. Suit able for higher temperatures than (201. (211. (22). Formed into rigid sheets, for roof deck insulation.
Semi-rigid formed sheets for use m insu lating interiors of air conditioning or heat ing ducts. One side, facing the air stream, coated to resist air erosion. Formed into rigid sheets for constructing air conditioning and heating ducts No. 27 is a higher density material than (26). for use where additional strength is required
Properties of Thermal Insulation 159
Material identification
numfler 28
29 30 31 32 33 34 35 36
37 38
39 40 41 42
Insulation material, generic tyoe Glass, fiber, with inorganic binder faced with aluminum sheet metal-factory attached.
Magnesium carbonate, with asbestos fibers and binders 180% Magnesia) Mineral fiber, with inorganic binders. Mineral fiber, with inorganic binders. Perlite, expanded, blended and bonded with binders. Water repellent. Polystyrene, expanded beads, molded to shape.
Polystyrene, cellular foam. molded. Polystyrene, cellular foam.
Polystyrene, cellular foam, selfextinguishing.
Polyurethane, cellular foam.
Polyurethane, cellular foam, self-extinguishing
Rubber resin, cellular foam -- self-extinguishing.
Siliceous fibers and binders with factory attached sheet aluminum facing. Vinyl chloride cellular foam.
Wood fiber and binder.
Description ann -nerai characterises
Formed into semi-rigid panels for appli cation to large diameter or flat surfaces. Aluminum facing provides basic weatherbarrier Formed into rigid block and pipe covering Relatively soft.
Formed rigid block.
Formed semi-rigid block. Made in various densities. Rigid board and pipe covering. Low shrinkage at high temperatures. Water repellent. Formed into rigid block, board and pipe covering. Light weight, excellent cutting characteristics. Molded rigid board and pipe covering. Light weight. Rigid board, sheets and pipe covering cut from slab stock. Light weight. Good cut ting cnaracteristics. Combustible. Rigid boards, sheets and pipe covering. Lightweight. Good cutting characteristics. Will not continue burning after removal of fire.
Formed into rigid boards, sheets, and pipe covering. Light weight. Good cutting char acteristics. Formed into rigid boards, sheets and pipe covering, Light weight. Good cutting char acteristics. Will not continue burning after fire is removed. Rigid board and pipe covering. Good cut ting characteristics. Will not continue burning after fire is removed. 4'x8' (approx.) semi-rigid panels for insu lation of larg.- diameter and flat surfaces.
Formed into rigid block and pipe covering. Easily cut. Light weight. Will not continue to burn when fire is removed. Formed into rigid panels for roof deck insulation.
160 Thermal Insulation
FLEXIBLE INSULATION
Material identification
number
Insulation material, generic type
43 Asbestos braid inner and outer tubing, filled with glass fiber.
44 Glass fiber and inorganic 45 binder, available with various 46 facings. 47
48 Polystyrene foam.
49 Rubber restn. cellular foam. self-extinguishing.
Descnotion and general characteristics
Seamless flexible tubular insulation.
Flexible rolls or sheets. All are of similar material except for density. As the oensity affects both strength and flexibility and also conductivity, divisions in denstry were provided to estabiisn the relation ships. Roll foam, flexible. Light weight Molded into flexible sheets and pipe covering. Resilient. Will not continue to burn when fire is removed.
BLANKET, FELT AND BATT INSULATION
Matenal identification
number
Insulation material, generic type
50 Alumina-silica fiber.
51 Alumina-siiica fiber.
52 Alumina-silica fiber and asbestos fiber with binder.
53 Asbestos fiber. 54 Asbestos woven fibers. 55 Glass fiber, batts with various
facings.
56 Glass fiber, banded with thermosetting organic binders. Available in various facings.
57 Glass fiber, faced on one or both sides with metal mesh.
58 Glass fiber, blanket, coated one side.
59 Glass fiber, woven felt.
Description and general characteristics
Formed into blanket for high temperature service. Formed into felt for high temperature service. Formed into blanket for high temperature service. Formed into blanket. Formed into felts. Formed into batts and encased in various facings. Mainly used for building ceiling and wall cavity insulation. Formed into blankets. Numerous densities available. General purpose blanket.
Formed into blankets. Expanded metal lath or 1" hexagonal wire facings on one or both sides. General purpose high tem perature blankets. Blanket specially coated on one side to resist air erosion. For lining heating or air conditioning ducts Formed into woven felt for high temperature installations.
Properties of Thermal Insulation 161
Material identification
number 60
61
62 63
64
65
Insulation material, generic type
Glass fiber (high temperature glass}, needled glass matt.
Mineral fibers, faced on one or both sides with metal mesh.
Mineral fibers, with various binders. Mineral fibers, secured by 1" hexagonal wire netting precut and edged for various pipe sizes. Refractory fibers predomi nantly alumina and silica.
Silica fibers.
Description and general characteristics
Specially needled matt of high temper ature glass fibers--without binders. Soft and resilient. Formed into blankets. Expanded metal lath or 1" hexagonal wire facings on one or both sides. General purpose high tem perature blanket. Formed into blankets.
Formed into blankets to be wrapped around pipe. Facing precut and edged and equipped with fasteners to secure around pipe. Felts available in various densities from 3 to 24 lbs/cu ft and thicknesses 1/8 m. to 2 in.
Formed into felts or blankets.
INSULATING AND FINISHING CEMENTS
Material identification
number
Insulation material, generic type
66 Alumina-silica, semi-rigid, hydraulic setting cement.
67 Alumina-silica, asbestos fibers and binder.
68 Asbestos fibers, and bonding clays.
69 Asbestots fibers, and binders. 70 Asbestos fibers, bonding clays
and binders.
71 Asbestos fibers, with special binders for adhesion to water repellent insulation.
72 Calcium silicate with binders.
73 Diatomaceous silica powder with binder.
74 Magnesium carbonate and asbestos fibers.
Description and general characteristics
Semi-refractory and insulating cement. Water mix -- hydraulic setting. High temperature--water mix--cement.
Water mix. insulating and finishing cement. Water mix. finishing cement. Water mix. hard surface finishing cement.
Water mix. finishing cement.
Water mix. insulating and finishing cement. High temperature--water mix--msulating cement. Water mix insulating cement. High shrinkage.
102 Thermal Insulation
M atenal identification
number 75
76
77 78
Insulation material, generic type Mineral fiber with hydraulic setting binder
Mineral fiber with hydraulic setting binder-high adhesion.
Mineral fibers, asbestos fibers and hydraulic setting binder Verrruculite and binder
Description and general cnaraciensncs
Water mix, insulating cement. Hydraulic, setting. General purpose msuiatmg cement. Water mix, insulating cement Hydraulic setting. Similar to 175) with special bind ers to increase initial wet adhesion Water mix. insulating cement. Formulated for use as a fire protection insulation Water mix. msufating cement.
FORMED OR FOAMED SPRAYED-IN-PLACE INSULATIONS
Material identification
number
Insulation material, generic type
Description and general cnaractensncs
79
Asbestos fibers, Amosite, and
Sprayable insulation cement mix. Water
inorganic binders.
added by spray gun. Compressed after
being applied to surface.
80
Asbestos fibers. Crocidolite.
Sprayable insulation cement mix. Water
and inorganic binders.
added by spray gun. Compressed after
being applied to surface. Similar to (79)
except will withstand higher service tem
peratures.
81
Bituminous material, cork or
Premixed mastic. Available in consisten-
mica filled mastic.
cies suitaDle for application by spray or
trowel. Used to control condensate.
82
Ceramic fiber and inorganic
Sprayable mix. Semi-refractory insulation
fibers.
83
Mineral wool granules, as-
Sprayable insulation cement mix. Water
bestos and inorganic binders.
added by spray gun. Formulated to be
used as a fire protection and high temper
ature insulation.
84
Polyvinyl acetate cork filled
Premtxed mastic. Can be applied by spray.
mastic.
trowel or palm. Used to control conden
sation.
85
Urethane, two pan liquid mix.
Liquids mixed by spray gun. Liquid on sur-
rigid foam. Self-extinguishing,
face foams to form rigid insulation. For
mulas obtainable for insulation will not
continue burning after fire is removed.
Properties of Thermal Insulation 163
FILL AND LOOSE INSULATION
Material identification
number
Insulation material, generic type
86 Alumina-silica fibers, bulk.
87 Alumina-silica, chopped and milled.
88 Alumina-silica, long fibers 89 Asbestos fibers. 90 Cork, granulated.
91 Diatomaceous silica, coarse powder.
92 Diatomaceous silica, fine pow der.
93 Diatomaceous silica, calcined.
94 Diatomaceous silica and as bestos fibers.
95 Giisomte granules.
96 Glass fibers, loose or shredded. 97 Glass fibers, wool. 98 Glass, cellular, pellets.
99 100 101
102 103 104
105 106
107
Gypsum pellets. Lampblack Mineral fibers, with small amount of o*l lubricant. Mineral fibers, oil free. Mineral fiber, granulated. Perlite, expanded, loose.
Silica fibers. Silica-aerogel spheres.
Vermiculite flakes.
Description and genital cnaractenstics
For fill applications such as packing fur nace joints. Same as (861
Same as (86). Available in various grades and densities. Available m various grades and panicle sites. Milled to a coarse powder, for filling cavi ties. Milled to a fine powder, for filling cavities.
Calcined to withstand higher tempera tures. Used as fill, or with concrete to form insulating concrete. Mixture for fill installations.
Available m various grades for various service temperatures. Used as fill around underground hot piping. Various grades available. For pouring or blowing into cavity spaces. Available in various sized pellets. Each pellet formed with hermetically sealed cells. For pouring into cavity spaces. Powder for pouring into cavity spaces. Fibers in loose form for filling cavity spaces. Loose fiber for filling cavity spaces. For pouring or blowing m cavity spaces. Loose for filling cavity spaces. Available in vanous size spheres. Soft fibers for high temperature service. Small spheres. Very low conductivity. Will flow through a very small opening. Expanded mica. Available in various sizes. For filling cavity spaces.
164 Thermal Insulation
REFLECTIVE INSULATION/FOILS AND SHEETS
Material identification
number
Insulation material, generic tyoe
Descriotion and general characteristics
108 Aluminum Sheet.
Polished sheet, thickness as required for
strength. Installed to enclose and sepa rate air spaces.
109 Aluminum Foil.
Thickness as required for strength, in stalled to enclose or separate air spaces.
no
Aluminum Foil on membrane
Foil with various reinforcements.
paper, or other reinforcements
Installed to enclose or separate air
such as glass fiber.
spaces.
111
Preformed aluminum with kraft
Preformed into strips or rolls, then when
paper, accordian formed. Wall
opened and installed, layers of foil will
and ceiling insulation.
form enclosed spaces in cavity installation.
REFLECTIVE INSULATION/PREFORMED PIPE AND EQUIPMENT INSULATION
Material identification
number
Insulation material, generic type
Descriotion and general characteristics
112 113a 113b
Preformed stainless steel case with stainless steel reflective sheets. Preformed stainless steel case with aluminum reflective sheets.
Preformed aluminum case with aluminum reflective sheets.
Custom formed to fit piping or equipment Non absorbent. Can be removed and re placed rapidly. Light weight. Same as above. Slightly more efficient, but limned to lesser service temperatures
Same as 11 3a above.
REFLECTIVE INSULATION/PREFORMED PIPE AND EQUIPMENT INSULATION
Material identification
number
Insulation material, generic type
Description and general characteristics
114
115
116 117 1 18 119
120
Aluminum foil, spaced with glass mat -- In vacuum.
Aluminum foil, spaced with glass paper. In vacuum. Carbon*silica in vacuum. Perlite in vacuum. "Santocel" m vacuum. "Saniocel" and aluminum powder in vacuum. "Santocel" and copper pow der m vacuum.
Multilayers of aluminum reflective foil m vacuum cavity. Very low thermal conduc tivity. Same as above.
Powder in vacuum cavity. Same as above. Same as above. "Santocel" opacified with aluminum pow der m vacuum cavity "Santocel" opacified with copper pow der in vacuum cavity
^uitifeyered reflective sheets consist of yets of reflective sheets such as aluminum
foil or metal-coated plastics film, separated by micro glass-fiber mats m a vacuum space, can attain even lower thermal conductivity than opacified powders. However, their af fectiveness is much more dependent upon the almost complete absence of pressure than the powders. Depending upon the layers per inch, conductivities of 0.001 OB to 0 00012 Blu/sq ft. hr. in.. *F can be attained when in spaces under a vacuum of 0.5. or less, mi crons of mercury, absolute pressure.
Of course, the problem is to provide the vacuumtzed space for these insulations to function. This is done by utilizing double shell vessels, with the insulation installed be tween the two shells and the vacuum gen erated in the insulated space. "Permanent vacuum" vessels of such extremely low leak rate that they do not require any re-evacuation for many years have been developed.
As with reflective insulations, the cryogenic vacuum insulated vessels are designed and constructed to withstand any mechanical and chemical abuses to which they may be sub
acted. Thus the properties are those of a de sign rather than that of a material. A chart of thermal conductivities of the cryogenics will be given later in this chapter.
Underground Insulation Systems
Pipe or equipment located underground, which must be insulated, m most instances uses the more conventional mass insulations in some system which not only insulates, but also protects the insulation from water.
As these systems use many combinations of conduit and thermal insulations, they are not a "class" of insulation m themselves. The properties of the insulation used in their con struction can be obtained from the properties of that insulation as listed. These systems will be discussed in a later chapter.
Properties of Thermal Insulation 165
Property Tables --Not Including Conductivity
The properties in Tables 30 through 38 are not all of the relevant properties of the materials listed previously in this Chapter The tables do list, however, the most important properties ana those most commonly neeoed to make an intelligent selection of an insulation for a specific purpose.
Note that many of the materials have only a few properties listed and that none of them are complete. The properties were compiled from information obtained from many sources, but most were secured directly from the manu facturers of the insulations, or from their pub lished literature. As can easily be understood, further testing and checking by the author of each individual value obtained, involved a task much beyond the scope of this book. How ever. based upon the author's knowledge of insulation materials, the values presented were reviewed to establish that each one was ap parently reasonable for that particular insu lation and that particular property.
All properties listed are not significant for all materials. For example, the water vapor trans mission rate of an insulation used for high tem perature service is unimportant because the high temperature pipe or vessel causes a high vapor pressure which drives moisture outward and the insulation remains dry and effective. For this reason, the vapor transmission rate on high temperature materials is seldom measured.
For certain properties, such as alkalinity, there has been no test method agreed upon by the insulation industry. Some manufac turers provide the information in terms of pH and others in respect to percentage of NajO. Again because of these limitations, despite the fact that this may cause confusion, the only recourse was to list the values obtainable.
Another factor which should be remembered m the use of these tables is that a particular generic material may be made by several
(Tit cootimiKJ oo p 192)
166 Thrma(lnsutation
TABLE 30 Rigid and wml-rigid iniulatlom
Mutritl Oannli*
n^mcw
Gana*< ryp #nd Cta 0' OncnotMXi o< <n*uiaion mat*ri*i
Prm
Maairnwr* l*m0 (mill *?
CpntiAgOui Shon
1
Aiumin>t*tica fiMn
8<oct
comrwnad
bnoa*n
Aigmin.g<ca ft bar*
3
COm0*A*0 ncn &rt0*r|
Bloc*
3
Atfraciory f4bar*no*dad LtflM w**grit
Board
7700 7000 7300
2300 7000 2300
4 Amoaitt tumoi i**ri
Mlh vituit bmloi
Covarmg
Ajbaarot ipooy faru
Stock
i lammaiad lO^nMi
and
*C
Aitwnot paom, pcatn
6 and corrggtfad.
*pa Coarng
Camaniaa to^rmar.
Calcium ulicaia. fivarow* Btock
7 AMltOreM > Am04 and
l*mr.
PC
Calcium uiicaia. nvoroui- Block
8 ISama n 71
and
*C
Gor*. v9atftbi 9 cmpr**#d
Bloc*
3tarpmacow !.<*.
3 too
10 tvanoad and bondad
and
o* 1
w:
Otatomacaout ul<ca,
Bloc*
11 blanoad and boraMd
and
Qa II
PC
OiatrwTiauaoui >ia,
U adaartoa Tabari and
Board
Morgan* btnoan.
Odtornacaom 13 adjaatoa libar* and
Morgan* Mi
Board
Oiairmai aim alira.
14 tm*nem fibari and
Board
aorfMc tMttrl
Glad, cdlviv,
Block
IS
Mamwtae^ly aaatad catti
and
>C
GIme. cMIuMr. IS IWnTwtujilY mm call* Board
Banyan avr 0* Ivic
Gi*0k. libar. tan* *17
organ* bmoar
PC
1200 550 to 700 300 1200 1800 700 1600 1900 1700
1700 1700
800
700 370
1200 550
to 700 300 1200 1800 700
1600 1900 1700
1200 1200
800
300 370
GUaa, fibar. *wtn 18 organ* bmoar
PC 450 450
19
Gia*. libar. bonaad, min organ* bandar.
PC
500 500
Ovnt'fy eg tt
Ab*ion raainjAc* X p*gnt iom by
tgfflOling/
1f1 10 min t\jn
2nd 10 mm fgn
13
10 u
71
M
TO to 16
26 to 33
9 IQ 13
10 70 40 to to to 13 50 80
10 7.5 IB to to to 1* 20 40
6 to
9
2\ X
to to n SS
so
to 90
24 X so to to to 76 55 80
73
36
65
7 to 9.5
7 ta
9.5
3 to 4
7.0
3.0 to 5
Aik*. Unify
pH
Cao<9/ity
a
TO
10 5
9 to 10
TO to (1
a
to 12 S
8 to T2.S
6.5 to 75
; to
9
7 to
9
9
to 11
9
to 11
9 to 11
7 to 8
7 to 8
75 to
9
75 to
9
7.S to 9
wm IN*! MMl wk
Mill twick
MtJI MlCk Mill MKk Mill MC
N*g.
Mill M*C Ml( 1 M*ck Mill ***ck
Will w*ck
MlJI
N*X
.
Nag.
N*.
N*X
Prooerties of Thermal Insulation 167
Ce/f'Ouf1t>** ` o
?!/*
flm W*--4 MOIK
SOM JlfHYl mu o#nrr
nO*
*0,V com-
Itr tftflin/lbt/
10 at % M<<KHh4tn
Hrrotcoocity l
iMtf t#ft
linear
*#* V it m* limo F
$ooc< not/ btu p*r lb br f
T nt**i itr^iK/ lb/0 .
Thr m*i OiWutrany /
H/hr icateutattdl
Wur lO0<ptiOn/
\ .Of, 24 hr iubrrnr**o
Wat* vioor trim* (himon perm <och
NC *c *C NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
25 50 O* or i*a lB n so or or la i*n 35 *0 <y or ira ion
US at 5%
75 to 1S5 *i
5% 1 10 to 130 it
5% 6 to 10 it 5% 50 to 120 it 5* 65 to 120 it 5% 800
it 10% 1500
t 10% 2500
M tc%
100
100
7 to 5 It 70 F 90 H
10% by Wgr. 1.5
1.0 2 to 8 by Wgv 2 to 8 bv !Nt.
9
9
9
0
0
10
5
2.2
.22 .25 to
.25
4 to .25 55
3 to 7
1 5 .20 to to 2 .21
\ 6 .25 to to 2.5 .28
*3
2.0
2.7 to 3.5
t to 2
1 to 2
1 to 2
.0000046 6*0. Co.
.22 to 28
.22 to .28
.25 to 34
.25 to
.34
.25 to 34
.20
00000*6 *d. Co.
.20
.2
N*.
20
67
10 to 30
10 to 20 15 to 20 18 460
750 so
SO
.2 .20
.3 .20
009
.005
16
016
006
.008 to 01 009 to
.012 .006
to 01 006 to 01 .006 to ,01 .13
.18
.02
015
.018
91 90 B4 85 85 90 90
85 83
93 92 93
2 to 7
16 8
168 Thermal Inflation
TABLE 30 Rigid rvd term-rigid insulation* (continued)
MllWial
idannl" CANOn
numwr
Ganarie c> and
CMS 01 OatCnolOn
of `mulatto malarial
f orm
G(a.
r*th
70 OrginK >rt0*e Avitto< Board
*tft v snout tso/v^s
fbsc. wiih 21 organic bmoar AvaiUbl# Board
Min var<M tcii>gL
Clan, fibar. mDi 22 organic bmdar Availada Board
9i vanoul facmga.
Gian, fibar. aonoad
23
*wtn hr^rt umeoritwrt
Board
bmdar.
GUru.
with
24 twxtr. Aaonait attacnad Board
toil lacing (Root boo'd)
Boo'd
Cion. fibar. oootoa ona
25
woo 10 roam aw arotion
(Duct lining)
Cion. fibar. bonoad iin Boarq
28
organic town, -itii vaoor
4
raawtant lacing (Ducn) Round
Clan, fibor. bondad with Boo'd
27
organic totMi. mtn vaoor
4
raamant facing I Ducnl Round
Clan, fdaar. bonoad min 4*8,, 2S organic btnoar. rntft factory .
Panaia aeotiad aluminum facing
Bloc* Magnaaiwm carbonata. antR 29 and aabano* fibn amt bmoan
PC
Mwwrai fibar
X
wrtn morgana: buda.
Bloc*
Mnaral fibar. wtn *iargan< bmdar. Sdmangd
Block
Partita. aapanoad.
Blob*
X
Blanoad and bonoad by
and
baidarg Wgtar raoaflant
PC
Pofvnyrana. aaoandad
Block.
X
band*. Moidad to dtapa
Board.
PC
Pdfvttyrana. caflular foam. Block.
34 Mo*dad to rvaoa.
Board.
PC
Block.
Pofyatyrana. catlwlar
35 foam
Board.
PC
Potyttyrana. catlutar
Black.
X Board.
gunning
PC
Maximum lamp Ima *f
ConnnuOut Sfcon
*50 *50
*50 450
*50 450
1000
1000
100 IX
250 250 250 250 250 2S0
<50 450
600 800
1800
850 to 11X0
(500
1800
850 to
1000
1500
IB 180
185 166 to to ITS 175
165 165
165 165
Oa"ity
iba/
ew ft
4 to 5
5 (0 7
7 10 9
Ao/aiio >*aitunca
X wa^it i<m or tumoimg/
---
!*t 2nd 10 ffim 10 min
fun run
3A
S
1.5
to
6
3
5
Inawl. only 3 to 5
11 10 13
15 to 18
4 to
n
9.5 to 11.5
1
1.5 to 3.3
1.5
TO
2.3
1.0 to 2.2
25 to 50
35 to 40
so
to
64
TO
70
Aika-
iioiry
pm
75
TO
9
75 to 9
7.5 to 9
8.5 to 9
8.5
IO
9-5
8.5
io
9.5
8-5 . to 9.5
8.5 io 9.5
Nag
Nag N#*
Nag.
N *g Nag.
7 10 10.5
7 to 9
7 to 9
7 to
8
8.5 to 7.5
6.5 to 7.5
6.5 to 7.5
5.5
IO
7.5
*ag
Nona Nona Nona Nona
Properties of Thermal Iniulauon 169
ComovftJO'litv
4 larr%0 KIM/ llm* kkh4 Ml
$iTW>* i
vtvoII <*4urr
>nO*>
N"' c<>m' bwii'O'*
Comer raw nrr***/lCnJ
M |l % Or/ ormauo*
Hyyro*
*C00*0 ty/ \ vplym* VTtff twt
Ljf*ar
fr+ a % T rn*9 tffTO e*
25 OT lt
25 or Wm
25 or i
25 or IM>
25 or
25 or IMS
25 or '
25 or ion
so
or
so
or KO
50 (K Ww
so
or tu
50 or lau
so
or in
so
or
so
or HBa
1.2 *1 2 Nf*
to%
2.7 It .2 *4* 10% IS ft .2 10%
.2 **
.2 0
.2 0
.2 0
.2 0
SocH H*S1/ Mu pm lb pm
Tamil* nrvr^ift/ <0*JQ *.
Thrmf Oiffwtrviry/
IQ ft/hr IcMcwJftadl
Wfitr *0Or01rW
X 04. 24 rw ityriHio
Wlttr vapor Iran**
mfllrOii prm ,r<
.20 018 93
.20 02 92
.20 .02 91
.20 03 93
.01
.20
.009
93 to
05
.20
.018
93
.01 .20 018 93 to
.10
01
.20
.017
93 to
.10
NC HC
NC
than 25 *
25
*ai thon 350
>-- tnan 350
Comb. Come. Come.
taH 0IOA 25 400
SO t 10%
2 to 18 ft
10%
1 io 1.5 t
10%
B0 ft 5%
eras ft s%
14 ft 5%
10 30 m
5%
8 io Xn
5%
10 bv up. .2
.2
.5
2 .X
1.8 .22
4 .22
1.25
.216
6*0. Co.
21
.000035 6*0- Co.
.27
.000035 E*o. Co.
.27
.000035 E*o. Co.
2
.008 to
.012 MS to .010 .01 to 02
X .014
.083
225 ,017
70 .017
70 .017
90
85
85 to 93 3.5 to 4
2.5
0.1 to 1.25 0.1 to 1.25 0.1 to 1.25
18
10 1.0 m 2.0 1.0
1.0
170 Thermal Insulation
TABLE 30 Rigid and semi-rigid insulations (continued!
Maim#* *(!<> cai*<J"
Gtntfric FV04 4*4 ClAw Or pf nn^aio* m*ir4i
Form
J7 Poiywtth*** room
6l<Xk, Boars.
PC
Pojyorttnano loom 38
*tf <o 1 roqu ivt *r*q
Block. Boars.
PC
Autob*r rtjrv N miuipr room.
Block end PC
StrCkOv* flbars and
4' > s'
*0 frnom, rmxlt factory M> Paneii
Dfrad uwmuium facing.
Block Vi*vl ChioriO*. cotkltor 41 r>s room. SaN^itiitguitAmf.
PC
<2
Mood frbor ind btooor
Boor0
Mptimum tamp imiti *F
CO noavow*
Short
25C 250
200 <0 300 250
220 220
450 450
22 212 to to 275 275
175 175
Oansitv cu h
A^tlOO rHtJA(| \ low Pv
Mi 10 mm ryn
10 mi* run
1.5 3 to to 55 15
t.o 6 to to 4.0 20
5 to 8
Al** lmty
PH
i^pTr
9.5 to **0*>4 75
65 io Mona 75
Non#
4X null rues
1.5 to No*# 3
IS to mill ta A<t
TABLE 31 Flexible insulations
Irvtor pro) outr 4] pjtx>f lilifO wrtfl
pw fsbor.
Soomiro livsibi*
TUCM
Glow, fibrous. Mrnll
FUaifc**
44 or^Mvec bmoor.
Roil
ArotloMl **ift
or moots
vrut t*t*9*.
Ohm. fibrous, witn 45 Organic binoar.
Amlabta with vinoul facings.
Glsa. fibrous, mtn organic bmoar. 48 Available will! various teeing*
Glass. fibrous. nih 47 organic bmoer.
Available Mntfl various facing*
Polystyrene, 48 cellular foam.
Fteaibte
FltkiOl* Viootl
F4*xiOi sftoou
Floxtoto moots
Roil form
49 Atao
Rubber rnin, cellular foam. Fteiible
mat* 0.#% *1 NajO
Sheas and PC
500 400 400 400 400 165 720
10
500
10
14
.6 400 to
1.5
1.5 <00 to
2.0
400 400
2 to 3
3 10 4
0.9 165 to
1.2
s 220 to
11
7 will
to
a *<
3a.s
to 9
N*p.
:a.s
to 9
:e.s to 9.0
=8-5 u> 90
6.5 to Non* 7.5
No**
Properties of Thermal Insulation 171
Co<Ovii6iiirY
f
llm* wxno >nO*.
STM>*
V"0* aanfi* ino*>
co,n` bvti'Oi*
Comer atanrv nr fnftn/ib*/
%Q <n at % dalormat^n
VfT0*. ICOOOTV / \ volwma
rtt* tart
Lif^f ''f'49/
I mai ttfflO .
Soaotic ha#t/
btu oar
ib oar p
T anula rtra ib/q tn.
Tharma*
Qiff utrvtry/ IQ H/*r
(c*JCwti*dJ
*eooiior/ X *01. 24 *V tu&
Wattr oor
trimmiQton
arm men
CqitiO. Cofro.
Co fro.
*0 10 ss
as .25 to
42
on to 027
1.5 l.S to 10 32
Aoof. 25
and uo
Ifll tnan soo
16 to 100
2% E id.
20 .on
1 2 SO F
.23
to
to
125 027
2 1.2 to to 3 27
Wan so
*oo#o. SCO
40 It 10%
2 10 10 *i 220
.19 to 27
82
1 0.1
nC 0 .2
tnan 20
son tnan 100
28 10 50 >1 5%
.00005 E*o. Co.
14 5.4
60
600
pani.
to gram
son. Ail fan *ith orf*n,c pin#?i hit
iiil>Aity aorawad 10 t#m at **30 of law man 0 6%.
11 4.5 to
1.0
2.8 to 5.4
5
HC
90 F
0
.24
21
90 flH
25 50 Of or >n IMS
75 50 or or
UD to .02 it 10S
uo to 03 it 10%
2 125 F 95 RH
.2 125 F 95 RH
0 0
.20 .20
25 50 or or
ion
25 so
Or or :*
Ud to .07 it
10%
O0 to 5 i
10%
2 125 F 96 RM
2 125 F 95 RH
0 0
.20 20
7 It \ 5%
\
2 to 6 it 25 %
3.5 IO 36 10
.9 to 1.2
Non: Moiviot Num&tn 43 throw?* 49 *1 otl ojfToondv flifciWa (0 Mind 180 Oo^Nt around a H intft 0.0. manor*.
10 to 24
05 to 28
1 72 Thermal Insulation
TABLE 32, Blanket, felt or bett Insutatiom
Materiel identiftcation number
Generic type end dai or otmiiia" ol Inaulelion materiel
SO AJumma-vlio fiber
SI Ahirrarunaiiice liber
S3
AistmmaeilicA. Ion* liber and binder
S3 AM Itel
54 Aabaana woven tan
56
GUat. fibraut'betta. with venou* facmgi
Ol--. fibroin. bonded SA UK tMarmoaenmg ream.
AvakabM widi uncut facing.
Gl--. fibroua. 57 Faced one or both tidea
mnM mMl
Gl--. fiber. Caetad St oneodr
(Curt linart
Form Blank n
Feeing
Uaavnum leno. limit* *F
ContiikiOut Short
2300
2300
f mt
2300
2300
Blanket
2300
2300
Blanaat
750 750
Pm
Bart Blanket Blanket Blanket
Foe* or om*r teeing*
Fo4-KnH Akjnwxjm
lo4
Mato lath or Hen. *ro nrniflf
On* ltd* trattod to rwvt or
750
200
250 to 450
tooo
ISO to 250
750
200
*50
tooo
180 10 250
Otnuty ibarcu ft
Aik* Unity Gapklenty 0M
3 to 24
will MCk
4 to
wiJI
6
will S n*ek
9 to
will wa
12
will 10 pnCfc
.65 7 to to Nag. 2.0 9
&7 to TO Nag 10 9
2.4 7 to to N** 69
15 8 to to Nag. 39
59 Gtaw, fiber, woven tdt
F*n Nona
60 St ^ 62 <3 64 63
Glaaa fiber, needled. H>gn tamo. (No binder)
Uan Nona
Miner* rt*i BlankM bmictn rendue rvM of metal fabrc.
Mineral ffeert Mtti bandarL
Blanket
1 * hex. #>t netting or metat lath
Blanket
None
Miner* fiber. Marred by t hate mwe netting, oracut and ed*ed forvanoue poe turn
Befreciory libera, praoornmendy of AJumme and Silica
Silica, fiben
FC
Fact
Fart nd Blanket
W None Non*
1100
1200
1200 450 to 800 1200
2300
1800
1100 9
1200 h,
1200 450 to 500 1200
2300
1800
6 to 11
5 to 8
3
TO 9-y
6
to \7
3 to 24
8
TO
9.5
ft
to 8.
7 to 9
7 to 9
7 to 9
7 to 9
Nag.
Properties of Thermal Insulation 1 73
Conoi/TiiOiiirr
riM Wdl flam*
m)i
5 mo**
d***tv/ rnoM a****ry inOii
No**ton> bun Mi
ConpnuM nranftfi/lb*/
tq m. i % ortonrunoA
Fla*itliry Mxiity 19 band *00
NY*rO KOO<ny/ % voiwma ilia la*t
Law hnmaqa/
<"aa % (t mn came r
Seaolc Nai
Blu par to Da* f
Mna
Tiwii
ax
Thrpr\*J
itr*nqtr</
lion
&ttvafc*riTY
ib*/q in.
W*.24
Q tVh# >v IUO
Fafann Fimod<cuiar (c^cut*i*dl mamon
NC JO
NC NC NC NC
IT*** 25
> dun 25
50
t*n tt>*n
50
5
n 3%
.20
3 Y * .2
.30 .28 a .28 0 .20
Y 123 F 95 BM
No 2
0 0
.20 .20
.016
96
99
035 96
tfvan 23
man SO
NC
20 at S3*
Y 125 F 95 RH
0
Y 2
0
v
.20 .20
14.7
10 0 .22
NC
to NC t
50%
10 .2* t d 0 J2 5
$ 5J
.018
99
.02
.012 .01 026
96 96
96
174 Thermal Insulation
TABLE 33 Insulating and finishing cements
40*01+fiCJIKjn
Ganaric tvpa no class
datcr.ptiem of intgifliOfl matanal
Alumina-til tea. 66 Mmt-rrfracTory.
f>rOrL*nc atting camant
Aiuminiics, and 67 aabarto* ffcan and
bindar
Aabanoa fiban 63
and bonding cfr*
Asoastos long fiban 69 and bmdart.
Finishing camant
Ajbanot fiban 70 and bonding days.
Finishing camani
Aabanoa fiban min 71 paciai bindan for adhasion
to watar moailam surtacas
n Calcium uiicata camant
73 Oiatomacaous silica, powdarad. with bindan
Magnauum carbonaca 74 and asoastos fibart
Minaral fibar. with 75 inorganic bmdar
Minaral fibar, with 76 hydraulic tatting bindar.
High adhsion Mtnarsi fibar. aitoatios 77 fiban and hytraulic tatting bindar.
78 Varmiculrta and bindan
Uiiimwm imp. V
Continuous Short
Oansity cjriad ibsicu fi
Abrtton rasittanca \ waight loss by tumbling
in 10 mm
r\jn
10 min /urt
7000
3000
48 10 70
1900
1900
64 to 66
1000
1000
35 to 60
1000 1000 1000 1300
1000 1000 1000 120Q
40 to 70
40 to 55
SO to eo
19 to 22
to X to to X 40
1900 600
1900 600
18 to X
15 to 30
>500
1500
18 to 34
1300
1300
40
1400 1800
1400
X to 42
15 25 55
1800
CO
to to
30 35 65
Adhasion
Hiding Ibs/SQ ft
flnad tbs/tq ft
Aiks-
I|P>T> pH
7 to 11
7 1.8 to
11
5.0 to 10.5
8 to 9
5 to 7
5 J -3
8.5 to 9.5
10 to 11
8.5 to 11
8-5 to 11
3 to 11.5
Properties of Thermal Insulation 175
ComQwltibililv
Flam*
UX*mc31 Mom*
ipraod
iMti
Smo*
OOYWHy/ tmoki
<J*nmv
m<J**
NoncombultOK
Comortow* min^th/ibi/
M> in ll %
aiformoiion
O'r cpyorinfl
c>ooc>tv/lbi/
100 id rt
1 men m<l(
400
to
650
Slwifikiji
<* to arr
% '-3<um*
Ching*
t
Linoor
inrmkkpo
mo* %
tim1 me i*cF
600 1
Sooeitic
hoi* Btu pot
6 pot
e
Th*r m*i
diftuintiiv/ o tvnt
Iciieuuiod)
YrilW IDlOtDIiO" \N 2*
hr two-
moruon
NC
NC
100 to NC ISO it
5%
NC NC NC nC NC NC NC
100 It 5%
50 It 10%
150 It 10% ISO 11 10%
:io to SCO
130 to 580
370 to 525
240 to 250
155 to 190
150 to 240
125 to 165
160 ra 200
330
240 to 350
150 to 165
1 to .25 5
2
1 1 to 2 5 22
22 2
10 2
.23 0055
.25 01
.28 .0055 .22 008 to TO .23 .012 ,23 ,007
10 2
27 011
015
176 Thermalinsula non
TABLE 34 Sprayed, formed, or foamed-In-place insulations
H
ejtio*
CAr< typo #rwj ctatt oe omcrtouor*
Oi mauUmon rrviitf
ftmg limtTl F
CoAHnuOvt Sho*1
Dn*fy dr wo/
ibt/cu ft
AdKtoA
Driad
ttn/til ft
ibt/m n
AJk-
Unity 0*
ComDutifeiirry
f l*m# tpraad/ flama
Smoa
danaity/
V^OM
NOA-
com-
irvclai
nox
amhoi fibart, mmH, 79 nd kAOrparnc txr^Owv
Sorry mi*.
Axbanot libart. goctdoBO 111*. and morjanic
bMMn Sor*V mix.
Siturmnout malarial*. SI cork or mica fillad.
Mane.
Garam< fibar 83 and inorganic btndon.
Sony mi*.
Minor* fibar ^ingM, B3 CRICK fibri and
inorganic bmoan.
Polyvinyl acatatt. B4
cone fillad. Mattie
Uratftana, 2 part mu.
as rp*d foom.
Salf-axunguuftmb
750 1350 100 7200
iaoo
750 1350 200 2200 1800
S to 13
ID is
*4 to
so
12 tD 13
11 to IS
no 170
1.8 750 250 to
3
9 10 10
9 TO 10
Comb. Comb
NC NC --
NC
7 >aa to than ?.S 35
tas
so
NC
TABLE 35 Loose and fill insulations
*3*1 lift* CXtlOfl mjoom
Ganaric typa and baa or daacnption
of <mutation matarel
Form
ee
AKiffufti n<<i (ibftl
Bulk ftbart
a?
Afumma-ailica ftean
Choooad and rmllad
Mimmaalci 89
ton* ffean
Bulk Ifeart
89 Aabaataa fiban
Bulk fibart
Max tnd mm % yofvma on
dillrtm tut
A*rtf>ti or fibar ui
Short to H* ton. Subrrucron ta 10 mesb
50-1000 mown konb Submcron 10 10 microm.
St* id 10* ten*. 1 to 25 rmcnonk
Vanowt rypaa nd yidt
Muimum T*mD*rwturo
rrutl eF
Comrttioua Short
7300
2300
2300
2300
2300
2300
1000
1000
Cor*. xiqlllbli, 90 Gmnukatad
Oanuiatad. Surobta tD b* poured 'o pLxc*.
Variout avanabfa
300 200
91 Diatomacaoua alica Coam powdar
1600
1600
Omrmrry
iMOVCufl
i mi Picked
3 CD 6 4
7.5 7.5
36
20 20 tD
50 tD 12 25 20 tD to 27 31
Properties of Thermal Insulation 177
Comprv*v rtrpnyth/ib*/
tQ (Ar 41 %
deformation
0* caoacttv /ibt/
100w n
1 inch lhe
ShrinfclQt Wat 10 dry/ % *0um
Chr>9
s
It 5* 1.5 io 5 *i 5%
0.6 5%
47 to 120
67 to 120
15-20 9*1.
7100 f
*' Iti*.
100 to
no
IS VI vaid
IS-20 gM. /100 * %* ttlfc.
20
tt
30
30
teonet 0OTOK. 30 1T>
Lmeer m*i % It mil
ttmo
1.5 to 2 < 2000 .63
91 1200
0
Umc*i< n*at/
8 tb oar ib oar *
.23 to .27
.23 to .27
Th*#mal <Mtu*vity/
*q h/hr ItatcuHfadl
01 to 0t7
01 to .017
W*iar aeaO'DtKVW % WOt, 74
hf Kl> mmton
Witar vaoor tr**ttmru*oA/
Omm men
.25
Alkalinity pH
Gomoumoiirv
Flam* prmacJ/ Ram* pr--0 ind>i
Smet* oanury/
mok oarmty inou
Nor* cov butiibto
NC
Hygrtncoo<TTy/ % actum* ahtr ton
So*cifte haat/
Btu Mr 4 0*r*F
.20
Tharmai di Huvivify/
ai. fl/hr (eaicumtad)
Wat ar Otorption % vol, 24 hr
NC .20
NC JO
9
to
NC 3
J7
11
5.5 to 7.5
S 10 NC .25 .0009
7
178 Thermallnsulation
TABLE 35 Loom and fill injuiatiom (continued)
UdWilt
Gao#.* lycx And <lmt or omcnonon
Ol irnuiAtiOn
f grm
Mi 4
mm \
OJwflM 0*
iwt
wrat
Aggr+gtii 0* (bar |4/
92 0lAlOm*COut ItllrCI. F ma owear PtnA pomotr.
0*4tomcoj| whCA. 93 PowOAT
G*i<i*ad,
imoa >tu< )ir>*u F
Continuous Shon
Dantnv 04* CW tx
At trcr-ruo P Kt *0
1600
1600
10
to 13
12 to 17
2000
2000
25
72
OiAtemactout vlo 94
And Movttot fiOan.
Loom
Oilaonn* grtnuin.
GrtnulM. lor PActnng
Varoui
98 Vaooua 7KM
around unoergraund
bias.
varioui 4motur.
0IOA.
Sh/tOMO. Of
94
Gtei libaf, unixyvMd.
loot* fiban.
Gum libar. 97 Pouring yvOC<
Pouring or Wowing moo*
96 Gian, edluiar.
PtllAM
Various mat avwtaOJa
99 Gycnum. m o*licti.
Bulk
100 Lmobic*
MiATIl tibari.
101 ri(T\ m*4l amount
Ol OH hjtrcam
102 Miners fibvv Oil tr*.
103 M.nrl libori
PartitA, AapanOMl. 104 Soham,
Powd*r Loom Loom GranutAtAd. Loom pomoar.
105 Srlics. fibm.
106
S*lica erogM. GranwMn
Loom *>bv Gionuivt
.01 to 4
m*o*o*S
Adiimm in ermi gram am.
8 m*an 1% 4Q mam 35%
107 VArmiculitt
F IMN
1800
300 to 460
1000
1800
300 to 460
1000
250 2 SO
800 800
800 800
1200
1000 to
1200
1000 to
1200
1000 to
1200
1400
1200
1000 to
1200
1000 to
1200
1000
to 1200
1400
1800
1800
1300
1300
7000
2000
6
12
to 20
4.7 to 18 4 to
11
4 to
n
s
3 to 9
3.5 to 5.5
4 to
10
18
44 33 50
2 to 12 0.5 to
15
6
4 to
12
10
to
15
7
3
6
to
12
4 TO
5-5 5 ra
10
AUJnily pH
5
ro
7
6 to 7
a
to 7
S to 10
a
to 10 7 to 8
Con'tMilitxIilv
$ l4m
1c*9mCf ttsm4
1*011
SmOM
mokt 0***ir*
KtMl
Non* com* OuttlOlf
nc
NC
NC
NC NC NC NC
Progenies of Thermal Insulation
1 79
MygroKOOKHv/ X vOtuivx #*( (Ml
Spc>i<
*1/
Blw pm <0 PM 'F
T
Itf^f ICJICuHtlO)
Wl(t ofot*o \ }4 *r UiOm*'tOn
.2 125 F 95 Rm
0
:s oi
:
25
.17 .20 to
.24 .20 .20 .IB
Lorn
NC
7 to .22 9
7 to .22 9
7 to .22 9
NC
5 10t
to
NC 70 F
.2 .054 98
7 90 RH
as 10-15
to NC M 71 F .21 .02 4 90 RH
6 2 H .20
to
NC 70 F
to .025
s
90 RH
2
180 Thermal Insulation
TABLE 36 Reflective iniulatlon/folli and iheets
Moiartoi
eation
Aummr
GanarM tyoa
ar*3 clU
O'
daaenot*on of
U|l irfiyr^ lamo.
Porm
Uftiut
Oamity CJO`iba/cu h
Co^MAvOwt Shoal
ice
Akimir^m Shaat
Shoat. Any thteknau.
MOO
169 1100 {matatl
*
109
Aiumirum foil Vanout mcknanai
Aom.
600 600
Aluminum (oil. on
Rnfl or afeaiiot
110
mrnrorana p* or
oaoar min loJ
700 700
otfwr f*n%*o*CTm*nt RIKN4.
AKimmun-knh.
ftaftactiva matt.
111
Accord**n format).
saeartiad (0 form
700
700
Roil inouiation
air toacm
*9 Naij
TABLE 37 Reflective insulatiorvpnsformed to fit piping and equipmer
Motor Ganar Ty04
and dan or
IdantifV
cation
daacnetto*
nutnMr of insulation
matar iai
Form
Uarngm
tamo
Lmj f
Danairy
(AooartrM)
>b/cu ft
Continuous Short
AltiUnity
OH
Cao<lariry
Stamlan itM) 112 cmtrq and SS
irflcn d*aao
Stages nad 113 caame and A aluminum
raftactiv# thaw
cactory fieri-
caiad to In omnm of oionuni or porno lyllBfT*.
Aluminum
113 caune and B dummum
nlliciiyt mo.
1500
1S00
1000
1000
a to 10
6 to a
1000
1000
5 to 7
7Q 70 70
TABLE 38 Cryogenic insulations
Matwiatf
Idantifmraon
nufTM
Oanarte Typo <nd Clan or
P--rrcition of
Inmilanon Maiand
Comtruction
Racommonoad
Vacuum
Numdar of
Layan
Abaofu ra Prtoura
Danaity faJcu ft.
m
Mcrona of Hf
114
Aluminum loti, pan mat
Flu fly F*1 mm taodrtmf fo4 dura
10 to 20
0.1
114 114 115 115 115
AJumwajm foil, 0 am mot AJumimjm fo4. 0m mot
AkMtunum fo4. foi paev
Aluminum toil. ^aa poor CorVomtificA
San a abort
15 to 30
Sama m ikm
35 to 70
Cion
a^araond Oumirum foil tfioaii 50 to 100
Soma m. aooro GtftKavadiea o&t *' mnwra
75 to 150 -
0.1 0.1 0.1 0.1 7.0
117 Parli?a
Partita powrtor
- 2.0
IIS Santocd
5an toed oommt
2.0
119
<5 Santoeai. ammmum
Qpjciftaa Santoeai and dumimim pewor rpujdT
-
7.0
2.5 2.0 4.7 5.5 75 B.O 8.0
6.0
10 0
Samocat cDeov 120
Santoetf and copoar oowoar
Oaocifiad Porrdar
-
70
11-0
CombwtlibilitY
Flsma danairy/ flam# pTMd
Inoa*
Srr<CM danany/ Noncommot bwitibf* Oanairy
mdax
Hmi rmtwtfy
Hast rtflscianca
NC .05
95
NC .06
95
tfWA 25
tuan
25
NC .06
.95
.06 atf raflac.
.95 MCfl
raflac-
Properties of Thermal Insulation 181
Coral rot ton
Inatallad to form (if oca which an anctoaae and/or laoaratsd bv tfiaaa of avmHk/m,
pmC*r.
To ba inataffad into cavity toacas.
CamtfcantxIiTY
Flam# Sonad/
Fiama Spraad iroax
Smeaa Oamiryf NoncomSmoaa
bunibfa Oanwry indm
Expansion 9.
ifUmJ r
f+y aro seoouty
\ Voiu ma
attar Taat
Unsar
Watar
Spacific Ttiarmaf
Shrinkaf*
Absorption
Hast DiHutiyiiy
Mu %
% vof.,
8tu oar K) ft/hr
at Mu
74 hr
Tamo *F
lb oar
F (caiculrtad) bj om anion
NC .000001 0
0 . t2
0
NC .ooooot
0
0 .16
0
NC .000001
0
0 .17
0
182 Thermal Insulation
Tibi* 39 Thormal conductivities of Insulation (Btu/tq ft, hr, Inch, F) (continued)
ldn||(icallon Aumbaf
Gaoatlc lyp. cUMOf daacrlpllon ol
Iniuliilort maiatlii
form
Max lamp 0 anally f Ibvtcu _20Q -100
0
100
200
Mean 1empe*eiure V 300 400 600 600 700
600
900
1000 1100 1200
1 Alumina atlice faber*. combined with Uintiiti
Alumloa alltce lAiei i combined with binders
Raliaciory liber molded 3 Light weight
Block 2000
16
Block 2000
21
Board 2300
11
0 39 0 43 O 46 0 63 U * .1 0 63 069 0 74 0 80 060 0 65 0 70 0 75 0 80 0 85 093 1 11
0 36 0 40 0 46 0 60 056 062 0 68 0 74 0 81 0 88 096
Amoeile aebaeioa flbee 4
end ilbceu binder.
PC 1200
14 to 16
Amoeile sponge felie, s laminated together
Block
end PC
660 to 700
26 to 33
e
Aebeelo pipo, plein end
PC
coirugcled. Cemented together.
300
9 to Y3
Calcium ilkale, 1 reinforced **lih
aebeetoe flbere.
Block and PC
1200
10 to 13
Calcium atlicaie. reinforced a with al>aua fiberc
lEild high temperature!
Block and PC
1800
10 to 14
0 32 037 0 42 0.4 7 0 52 0 57 036 0.42 0.48 0 50 066 0.33 0 37 0 41 0 46 0 61 0 57 060 0-45 051 0 65 060 0 64 0 69 0 74 0 80
0 Cork, vegetable
Block 200
6 to 9
0 74 0.28
Dtetomeceoui niter, 10 bleitdrd end bonded
Clau 1
Block end PC
1600
74
0.61 0.62 0 64 0.66 068 0 69 0 71 0 74
DietomaceOui *H*ce, blended
Block
11 and bonded Cleaa 11
end 1900
26
Itairehlgh Umpetalufel
PC
Oteiomeceou* all ice.
12 aebaaioa fiber* and Inorganic binder
Boetd 1200
23
Diatomaceoua alike
13 asteato* libera and Inorgenk binder
Boat d 1200
36
067 0 69 0 71 0 73 0.76 0 77 0 79 082 0 69 0 60 061 0 62 0 63 0 65 0 66 0 67 0 78 0 7tt 0 60 0 81 082 0 84 0 85 0 86
OlflomacMui silica. 14 aabiatos libMi tod
Inorganic bln<J.
Board 1200 66
16
GImi, ullular, Mumuktlly iMldc4li
Bloch and PC
000
9 10 10
Glaaa, tabular
ie Harmettcaliy saalad cadi
BdwMft Uyin ol (alt
Board 200
9 to 10
u
Glass, fibrous, with organic bind***.
PC 370
3 to 4
ie Glaaa. Ilbioui,
with organic binder.
PC 460 7 0
Olaee, iUwii, 19 **4lh organic binder.
3
PC
600
to
6
Glaaa. Ilbroui, wUh 20 organic blndar. Available
with various facings
Sami rigid Board
460
4 to 6
Glaaa. (Uhoui, with 21 organic blndar. Available
with various lecinp
Sam) rigkl Board
460
6 to 7
Glaaa. fibrous, with ,2/ organic binder Available
kvith various facings.
23 Glaaa, fibrous, with high temperature blndar.
Samirigid Board
460
Board 1000
7 to 9
3K
Glaaa, fibrous, with organic 24 blndar. Aaphatl attached
facings, (roof board)
Board 100
6
Glass, fibrous 28 Coat ad one side 10
leslsl air aruaion
Board Duct tlnar
260
16 to 6
Glass. lbou, organic 20 blndar. With vector
fsslalant lacing (Ducii)
Glaaa, fibrous, organic 37 binder With vapor
raslsiani facing. (Ducts)
Cylindrical and 250 Board
Cylindrical and 260 Board
3 6
1.70 1 76 1 60 0 20 0 26 0 32 0 39 0 47 0 66 0 64 0 74 066 094
0.39 047 0 66 0 23 027 0.32 0 26 0.30 034 0 23 0 27 0 32 0 24 0 30 0 37 0 24 0 26 034 0 41 0 23 0.27 0 33 0 39 0 26 0 32 0 39 0.46 0 63 0 30 0 26 030 024 0 23
Properties of Therm al Insulation t 83
TABLE 30 Thermal conductivities of Insulations (Btu/sq ft, hr, inch, F|
584 Thermal Insulation
Idenillocation number
Generic type. cleet or description of
Insulation material
Mm
.
Form lamp Oensity
Mean Itmpeiluti r
*F toi/cu f| -200 -1001 o too 200 300 400 600 600 700 800 900 10OO 1100 1300
Gleat, llbfOui, bootM 39 lo iht ilumlmim.
4 m fl'
Panels
Insul
460 only
3 to 6
0 26 0 32 o aa
MaQMikiffl urbofMl*. Mtlh 29 ofewtix fiber* and binder*.
Block
11
and 600 lo
PC 13
0.36 0 39 0 43 0.46
30 Min*at llb end Inorganic binder.
Mineral Ifeer and 31
Inorfpnle binder.
Perlite, a* pendad and
32 bonded. Treated to be
eetir repellent.
Block 1800
16 to 18
Block 1300
4 to
a
Block
a6
and 1600 lo
PC 11 6
0 36 039 0 42 0 47 0.61
a ib density Ib4 dentity
029 0 34 0.40 0.48 0.66 0 66 0 32 0.41 0.60 060
0 34 0 40 0 46 0 60 0.64 0 60 0 64 0 70 0 76 0 80
Block,
18013
Pofyityrane, p*nded bredt. Motdrd lo rftepe
Board, PC
I
0.22 0.37
34 Polyity'ene. cellular foam Molded lo thape.
Block. Board.
PC
175
0 lo 1.2
0 22 0.26
36 Polystyrene, cellular loam. 30 Polystyrene. cellular foam,
tall axIIngjliMn^
31 Polyurethane town 38 PoJyrulhana foam.
S el 1 a* 1 In kahing.
39 Rubber reeln. foented
Block, Board.
PC
166
Block Boer d.
PC
106
Block. Board.
PC
360
Block. Board,
PC
360
Block. 220 PC
16 lo 33
10
IO 72
16 10
26
19
lo 4
4 lo
e
0 22 0.26 0.22 0.27 0 IS 0 16 0.19 0 17 0 16 0 19
0 29
46
Siliceous ltt>e*, with laciusy 4 m 8
460 lbo40 applied aluminum laulng
Panel*
0 26 0 3?
712 16
41
Vinyl ttdorkJa. caJJuta* loam.
54lnllo0uliMn<|
PC(Hock,
lo 27ft
to 7
01ft O.lftO.lft
*(R**o*o*t*I)fear Irwulatlna
Bo-d , ?6 i,g0
0 30
Aj*mUm, brakJad. Inna* and f
43 ouiw lublH FHId wUti
pQ
0m llbart.
061 0 69 002
Olaaa, I Ibara. with (MBnic 44 bi/Vtar. Av*fl6la evlih
vmIoui fecln^i.
Fllbl#
flail
400
& Hoard
06 to 16
0 ft lb. danaity 0 32 0 47 1.6 lb danaity 0.26 0 32
4ft $emi m 44
71**1614 400 Board
16 io ` 2
1.6 lb. domliy 0 16 0.32 2 lb. danaity 0 26 0.30
40 S<m 44
FUalbJa 400 0od
2 10 3
7 lb. damlty 0 2ft 0 30 3 lb. danaity 0.24 039
47 $arn aa 44
Flibl# 400 Board
3 to 4
3 lb. danaity 0.24 0.29 4 lb. danaity 0.23 0,20
Nyilynni, callula* foam. FUhlbU
P>oil
Oft 166 IO
n
0 22 0 27
Rubb (Min. loaned. 40 FlaaibJ*. 60 Alumlnaulict flUr
ShMt, 220 PC
Btankel 2300
ft to ft
3
0.77
3 lb Oanalty 4 lb 6 lb B lb.
0 36 013 0 30 0 26
0 40 041
036 034
060 060 044 040
0 73 0 60 0 63 0 47
066 0 73 067 065
1 03 0 69 0 72 063
1 20 097 063 0 70
1 36 1 13 004
060
1 51 1 26 f Oft a o
01 Alumlnaillici (I0
Fall 2300
i Io t
0 66 0 66 0 76 0 65 096 1 16
Akimin* lilki. long 61 IN( and bind*
Blank ti 1300
a
036 041 0 47 oh 0 62 0 70 0 78 067 007
W A4>#ioe fibar. W A4iww ytfOwan fall
Blank ai 760 Fall 760
ft to 12
10
060 066 061 067 0 74 060 066 oei 0.67 0 72
Properties of Thermal Insulation i 85
186 Thermal Insulation
Table 39 Thermal conductivities of Insulation (Btu/sq ft, hr, Inch, FI (continued)
Idinll' (ici)on nuntlMf
Ganarlc lypa, claai or daacilpiion ol
IniuUllon tnaiailil
Fonts
Mu limp Dantlty
ItWcu It -200 -100
0
100
200
MMni*i)oriui F 300 400 600 600 700
BOO 900
IOOO 1100 1200
ClM, llbfOUl
fllli In roll form.
filtii
260 00
Gum, liliiOul blrnkiu
Blank*!* io60 Availably Mlih vwioui lacing
460
io
3
031
0 32 0 42 0 26 0 32 0 24 0 29
0 6 io 1 6 (family 1 6 iO 2 lb
7 to 3 Jl) "
Glaaa, flbrOui, facad on 67 On# or both lda* with
m*t#J m#*h.
Mala! mttb 1000 Blank#!
24 to 6
0 24 0 32 0 40 0 60 0 61
G*#u Itbrpui blankai. 68 Traalad on on# uda
(Duel IlnaO
60 Glaaa, wovan fall
On# aid* Iraatad 180 to raalat Io MOMOA 260 Frfl 1200
16 Io 3
B
0 26
0 26 0 32 036 on 0 46 0 so 0 66
Glaaa, fib#!, naaUlad, no
60 bindk.
Tarnpatatwftl
Mai 1200
0 to 11
0 27 0 34 041 0 46 0 62
Mlnaraf fibar blankatt 61 baiwiin v*#l<xt lypta
of mataf labrk.
Blankal 1000
26 to 12
0 26 0 32 0 39 047 0 64
62 with bmd#i.
Minaral fibar, *cui *0 by 03 aepandad maial maah
Pracuf for p<p# cuvaruso
Raftaciory fiban 64 pradominantly
Alumina *r>J Silica
66 Silk* fibaia
Roll fall
460 600
Sac Horn for PC
1200
Fall
2300
Fait and Blank*!
1600
3 3 lb density to 8 6 lb. dannty
6 6 lb (family io 17
3 3 lb density 10 12 lb. damiiy 24 24 lb density
46 to 6
0 28 0 36 060 0 24 0 29 a 34 0 26 0 31 0 37 0 43 0 49
0 40 0 33 0 31
0 46 0 37 0 36
0 67 0 42 0 39
0 66 047 0 44
0 60 0 S3 0 46
0 93 0 59 0 53
1 06 0 65 0 56
1 25 0 >2 062
0 40 0 4S 0 53 0 60 0 >0
Alumina illka, a*m 66 raftaciory, hydraulic
tatting camam.
Cam#nl 2000
48 IO 70
1 42 1 47 1 52 1 68 1 64 1 70 1 ?d
64
Alumina alike* and
67 69aabaiiM liOrn and blndar.
Cam ant 1900
to
I6
40
60
AiimiM Ii04)i wh1 tondmg Camani 1000 clayt FmiihiA9cmnl.
lo 60
Aitwim. long lit>ai 60
md bindwi
Camani 1000
40 lo 70
45
70
Aabaaloa tibai* and bonding Camani 1000 (lyi hnliMi^cimini
IO
66
Aibalw IHii Mlih apacial
60
7> blndr( F(V Uh**ton lo
Camani 1000
IO
WlIM lapaUant mIk
60
72 Cicium nlKtli camani
Camani 1200
19 IO 22
Oiaiomacaoua 73 pOwd, mth binOl
Camani 11700
10 lo
30
CMbOnall 74 #TKf MbMIO* fib*!
Caenanl 600
16 IO 70
22
76 MlAMtl I6r, with binlt'l Camani 1600 10 24
Min#*a! fit**, tHh 76 hydraulic Mllingbinda
Hitfl Jhlon,
Camani 1700
38 IO 43
MInara! llbar, Mbaatoa 77 fibart. **ltl hydraulic
ailing binder.
Camani >400
30 IO 42
78 Varnkuilii and btodai
Camani 1BO0
16 to 70
Amim. Ibai. AmMln 70 ad Inorganic binder*
Spray mJa
760
B IO 17
a
60
A4>mIm, libai, CfOcldoJiie arm Inorgenk binder*.
Spiay mla
1360
IO
12
21 16 21 1 70 1 30 1 40 0 40 0 43 0 40 0 63 0 67 007 0 68 0 74
O 16 0 77 0 79 087 0 (M O IKJ 0 09 091 0 94 0 48 0 61 064
0 49 067 0 72 0 76 001 086 0 91 1 06 0 70 0 76 081 0S6 092
0.75 080 0 06 0 90 0 85 0 74 0 79 083 0 88 0 92 0 97 1 02 1 06 1H
0 34 0 39 0 43 0 48 0 62 0 68 O 71 0 34 0 39 0 43 048 0 67 0 66 0 71
Properties of Thermal Insulation 187
Tab)* 39
Idantlkitlott numbat
Thermal conductivities ot iniuieuoti idiu/h i,,, mw., <----.
Qnilc |yp. cUm or daacrIptlon o$
inuUilon
Mas Form lamp Oamliy
Maan tanpaaion F
h -100 - >00 0 100 700 0 400 600 600 700
800 900
1000 1100 1700
6p<vy or
Bliwmlnoo* maiarlala, cork
uowal
40
61 or mid (Iliad. Mastic.
conak tancy
200
to 60
manic
Camlc tibar and 82 lootpanic blndar.
Mlnaral fiber, gianilM. 63 aibwiot flbar* and
inorpanlc blndai.
Polyvinyl acatsta. 84 cork flillad. Mattie.
Urathan# 2 pvl mli.
Spray mU
2300
5pr*V mix
1BO0
Spray or (iomnI
cooalt Incy mantle
180
2 pin pun min 260
17 lo 13 11 lo 13
2 10 3
60 Alvmln*illlCd flUti
67 Alumlnatidca
Bulk ftbar*
Chopped
and millad
2200 2300
0
76
66 A(umlnMilic long fKxn BO AjbeilM fH>r
tong ultct
tlbm
Bulk
ftt>ari
2300 6
1000
20
to
60
Gtanol
90 C*h. vaptiaUi. pianuliinl
for
200
pouring
0.90
0.44 0 4# 0 47 0 68 060 064 0.37 038 0 40 0.44 0 61 0 60 0 68 O 74
0 69
0.17 0 10
A|i sy*
0t6o0
1 87
0 31
060 000 110 122 1.35 155 0 65 0 66 0 76 0 85 0 06 116 0 40 0 60 0.70 0 So i 06 I TO I 36 I 60
91 Diatomacaoui nisca
Comm powdar
1000
70 lo 30
77 ll> daniily 26 <t> dan*ily
17 17 6 lb danniy
Una
97
Olaiomacaoua arlka. Ilna
powdar
1600 lo
W 1 7 lb dans^y
0 48 0 63 0 36 047
0 58 0 77 0 44 0 48
063 0 97 0 53 0 55
0 70
U
0 64 0 63
0 77 f 77
0 69
0 97 f 47
0 B4
Thermal Insulation
0000
Dlatomacaoul 4lic. cafelnad.
3000
26 It 21
2ll ii>, (iiniily 31 lb (tonally
o 6a o ib UH3 o.tn i oo in i 2J 1 Jb 092 091 1 03 106 114 118 1.26 1 31
DiMQlMCiOul #Hlc* 94 and Htwloi (Kmi
GUaonlU, flinulaa. 96 Varlout piaatoa
lo* viiloui tamparaiurti
90 Glaaa, fbaa, urbondaJ
OlM. fibwt.
Ppuilnf wool.
90 Giaaa, cfkilr. paMata
Loom
1800 1u9
Grant*-
litid
300 lo 460
Shiaifctod
tn loOM 1000
IliMlt
Pouring or tilling 2t>0
ivpa
Vwl<kJI
<*#
pailiU
44 lo 60
2 lo 12
0.6
lo
16
99 Oypaum, cailular pallau
4 lb. danally 6 lb (tonally
069 0.61 002 063 0.66 0 06 066 0 60
0 06
lo
0 60
0 24 0 22 0 40 0 61
0 2 4 0 21 0.20 0 46
0 20
0.40
044
IQ
1.00
Properties of Therm al insulanon 189
Lampblack
Mineral llbara, with 101 mall amount ot
oU lutxlcani. Mlnaval Itban 102 Oil IrM
103 Minoral llbart far(il, Mpandad.
104 Spbaraa 106 6mc* fibara
106 Silica aaropai pranulaa
107 VarmlcoMta
Varlout
1200
42 lo
pada*
18
Loom
1200
4 10 11
Loom
1200
10 IO 16
litad
10O0 lo
1200
6 lo te
Loom
1400
3
Loom fiban
1600
3 lo 9
Varioua ija
panulaa
1300
4 IO 86
Fiafcaa
2000
8 IO 10
0 20 to
0.26
10 lb. (tonaily
0.28 0.34 0.42 0 61 061 0.72 063 094
10 lb. danal'v
0 63 068 0 64 0 70 O.lfi 0 83 091
101b. (tonally
028 034 0.42 061 0.81 0.72 063 094
3 lb. (tonally 9 lb (tonally
0.27 0 36
066 0 78 000 1 06 r to t 38 167 040 O 47 0 66 0 66 0 76 0 82 090
6 3 lb (tonally 0 120.10 0 10 0 71
6 lb. (tonally 10 lb (tonally
0.4 7 066 0.44 064 062 071 060 069 0.99 1 10 l 21 1 32
TABLE 40 Thermal conductance! of reflective Insulation* (Btu/iq. ft, hr., inch, F|
Malarial (dtntill-
cation numbtf
Gangrk typo god data or daactlpilon ol Intulation malarial
f wm
Oliachon ol pu.ivn hM|
Conilucianca
al 75 F Mean tampaittun
Au iptctf K
f m Q 05 (Alumimm)
Air apacaa ancloaad and wtuitd by lallacuvt thi#id
Numbti of tptcti
1
33
4
66 7
89
to
108 Aluminum Shaat
Varloua thicknataaa
Varikai
Acroti
0 35 0 18 0 12 0 09 0 07 0 06 0 05 0 045 0 04 0 035
109 Aluminum Foil
Varioug thick nttaa*
Aluminum loll (both iid|
no on mamba ana ptpar or
lamlnata
thar ffinlofctmiAi.
Aluminum (oil. m accocdlan formad
roll Intulation
* pandabU roll lor cwiiiaa
Not*: Hail trenifw l given In CONDUCTANCE, not Cont^cflvliy
Horizontal Upward
0.48 0 25 0 17 0 12 0.10 0 06 0 0 7 0 06 0 065 005
Horltonlal Downward 0 35 0.18 0 12 0 09 0 08 0 0 ? 0 0050 04b 0 04 0 035
TABLE 41 Thermal conductlvitlei of intuletlons (Btu/sq. ft, hr., inch, F)
Idtntlflcation numbar
Ganar k lypa, claaa or daacriptlonof
intulation malarial
Form
Mu. lamp.
f
Dan ally Ibi/cu It
-200
100 0 100
200
------------------------------- tr-- ------------------------------------------------------------- Maan tamparaiura F 300 400 600 600 700 800 900 10OO 1100 1200
Sttmlaaa itaal tatlng
Cuttom
112 and SS fallacik* iIihU built 1500
8 lo 10
Vtriad lo auit naad
Stainlaaa >taai caalr^ 113
and aluminum fallacfWa ihaaia
Cutiom 1000
built
6 lo a
0 206 0 378 0 400 0 466 0 637 0 600
Aluminum eating 113
and aluminum raflacitva thaaia
Coatom
built
1000
6 10 7
0 250 0307 0 378 0.444 0 507 0 670
ConckJCtMtW* ki flKrar. |n "ippartril" k valuta
"Appaeam" fc vtlut It tha aQuIvtlaot tutragt fharrntl conductivity of ftl non homopantout lr>aul*llon, lor comparUun with th V eiu* Of ftomog-enOut mei*<iell a* Oitennined toy A3TM Tot' Mtlhod C 336
TABLE 42 Thermal conductivities of Insulations (Btu/sq. ft., hr.. Inch, F)
ldnlllklloA numb*
Gwlc lypa, cltti o< daicflplion ol
tabulation malarial
Form
Man. D amity lamp.
Hi/cu U F -200 ~ 100 0
Mean temparalure F 100 200 300 400 600 600 700 800 900
1GU0
1100
1200
>14
114
114
116
IIS ne 117 118 119 120
Aluminum foil, gleil nul
Aluminum foil, gliu m#i
Aluminum foil,
mar
Aluminum foil, gleai papar
Aluminum foil, gleu paper
Carbon-alllc* Pwllu Santocal Sentooel, aluminum Saniocal. copper
laminate 10 lo 12 lay*'*
tinklraif 16 to 30 layer*
lamlnata 36 io 70 layer*
limlfMii 60 lo 100 Uyer*
kmiruii 75 lo 160 Uyari
powdtr mUiura
Povrder
Powder
OpacifUd pOVMlff
Opacified pondw
36 0 00100
2.0 000078 4.7 0.00024
ss 0 00022
7.6 0 00012
8 0 0 00480
B0 0 00066 6 0 001160
10.0
0 00204
11.0
0 00270
Properties of Thermal Insulation
to
192 Thermal Insulation
manufacturers. As there are differences m ine properties of a generic material produced by different manufacturers, the properties are a mean of the values listed for the products of the various manufacturers. Thus, for those products made by several manufacturers, no single manufacturer 5 product will have exactly the values as listed. It follows then, that these tables are presented to serve as a guide for selection of the correct generic material for an installation. However, the final choice of the particular manufactured product must be made by the individual by comparing competitive products.
The property "Maximum Temperature Limits" is given first as this is the first require ment that must be fulfilled. "Density" is sec ond. as it frequently identifies or classifies a particular material as being in a given generic ^ class, and within a generic class it affects the thermal conductivity.
All other properties are listed in alphabetical order.
Property Tables--Conductivity
The thermal conductivities given in Tables 39 through 42 have been gathered from various sources and whiie deemed accurate, are not the result of tests by the author. In most cases, they are the results of tests performed upon laboratory-dried samples by the manufac turers. They are based upon representative values for generic material within their ranges of densities and are neither the highest nor the lowest of a particular listing of competitive matenais. They represent mean averages which we expect will provide relatively ac curate information for use in heat transfer calculations.
As all values listed are taken as representa tive of the means of generic materials avail able and are provided for engineering calcula tion only, they are not deemed suitable for use as material specification limits Any one par ticular manufacturer's product is not likely to have the mean values of all the materials manufactured in that particular generic classi fication.
For a particular installation, the materia/ specification must be written by deciding what property values are essential and. with knowl edge of materials available, the specification must be written to obtain those essential properties within the ranges of the materia/s available.
Hopefully, this book will indicate the need for more complete information on properties of matenais and that any missing information will be made available by the manufacturers When insulation consumers understand the need for designing insulation systems on a scientific basis the manufacturers will quickly respond by providing the necessary technical information.
The abbreviations in the Tables have the following meanings:
amts. Exp. Co. Comb. hex. Insul. Neg. NC PC RH Temp. thk_ SS
amounts Coefficient of expansion Combustible hexagon Insulation Negligible Noncombustible Pipe Covering Relative HumidiTy Temperature thickness stainless steel
Installation Requirements
$
"Installation Requirements'' per $e may be mis understood to mean only the reauirements during the application or service life of an "in stallation." What is intended, however, is a discussion of the requirements that an insula tion must fulfill from the time it is manufactured until it is m service. After insulation is produced, it passes through several phases, i.e.. it is shipped, stored, possibly fabricated, reshipped to the |Ob. installed, and finally used m the serv ice for which it was originally specified.
For lack of a more descriptive term, these various operations that the insulation must pass through from the time of its production until its ultimate discard will be called "phases." They may differ, depending upon the method of manufacture, type of material, and use. but in general they may be listed as follows:
Shipping Storage Fabrication Application Service
Each of these phases imposes a set of re quirements upon the insulating material. It must meet these requirements in order to ful fill successfully its economic function. Evalua tion of these requirements and the selection of the insulating material which will best perform the specified function is an engineering design problem. This problem is complicated, not only by the large number of requirements, but also by the lack of reliable data on the requirements themselves. Because of this lack of data, it is impossible to provide both an exact fist of the requirements and of the properties whereby a precise selection of material can be determined. Therefore, this discussion must be kept general, for the final selection will be determined by engineering judgment. This chapter will be helpful in determining the factors affecting that judgment. It must be understood that an error m judgment here may make the difference be tween a successful or an unsuccessful instal lation--a profitable or unprofitable operation.
Other than the purely technical aspects, there are reasons of business and procurement (such as availability) which influence the selec-
193
204 Thermal Insulation
sation and drip. A general rule to remember: the lower the emittance. the closer the outer sur face temperature will be to the temperature of the surface under the insulation Conversely, the higher the emittance. the closer the outer surface temperature will be to the temperature of the ambient air.
Moisture requirements
Insulation, to be efficient, must be kept dry. Moisture m two forms, the liquid or the vapor state, can saturate the insulation. It can enter by vanous means, water pressure, vapor pres sure. in-gassing, and simple leeks. The protec tion required will be determined by the installa tion conditions.
When insulated piping or equipment is sub merged in water, a completely water-tight outer shell is required around the insulation. Such systems must be encased in metal, fabri cated by welded sections, and/or flanged with jacketed flanges, so that the outer jacket is suf ficiently tight and strong to withstand the water pressure.
Underground installations where insulation systems may not be directly subjected to defi nite water pressure must still be protected to prevent the entry of water. Such protection must not only prevent the said entry, but it must also resist corrosion to remain water-tight. The corrosion may be ordinary rust, chemical corrosion, or galvanic corrosion.
If the function of the two previously men tioned examples is the insulation of hot sur faces. vapor migration will be of no concern. However, if the installation is for low tempera ture service, water vapor migration will be an additional problem. Many conduit systems may be water-tight and not be vapor-nght. Practi cally. it is relatively easy to construct water tight systems, but almost impossible to con struct vapor-light ones. For this reason, it is suggested that, wherever possible, the cold equipment and piping be installed above grade.
The moisture protection necessary on equip ment and piping located above grade is de termined by whether the location is indoors or
outdoors, and the operating temperature above or pelow ambient.
Hign temperature insulated equipment and piping located indoors and not subjected to rain. snow, or sleet does not require water or moisture protection A word of caution--the insulation must be adequately protected from moisture due to possible spillage or the washing down of vessels.
Low temperature insulated equipment and piping located indoors must be protected against moisture vapor The necessity for such protection was explained m Chapter 3. and il lustrated m Figure 33.
High temperature insulated equipment and piping located outdoors must be protected from liquid moisture in the form of rain, s/eet. or snow.
Low temperature insulated equipment and piping located outdoors must be protected both from liquid water, and also moisture m the vapor phase.
These moisture reauirements are summa rized below:
Sarwea
Motmr* Porction
Tmrtur) iDCJOOA
Wir pfOtlorc
VlOOf
uma Unaavwataf Aodvirod
Not douitoO
Cro*c t*mo. Undavwataf RoOOtrxS
RoOvtfod
umo. Undt'vvai*' Aoowod H*9Jt timo. Bww grMt Oapavuj*
AoOvnoO A*du*rd Not r+ouirvO
Cvok img
Ipwumo. Htqrt tamo.
Balov* vom Oaoandi
RopuirxJ Aoouirtd
B alow graoa Daeandt
A+Ouir*d Aoouwod
Abova gvaoa Mol ragwaad Depooo) Not rtouirod
indoor?
lino. A60k 9fM Not fOOutfOd Oiooftd) ftoouirod indoor)
low timp. AOovo 90*) Not rvouvoO Oaoands Rtoutrto
Own Hj^fi ime Wova graOa Nol rvouvad Atowvd Not routr*d
outdoor)
CrOK ttmp Abov* QT+Q+ Hot r*qutf*0
A)Qu*)4
outdoor*
Ufmr tn>o. AOou
Not raquvad A*Our<2 Aoouwod
Outdoor)
Safety requirements
The major safety requirements may be sepa rated into the following divisions:
Safe surface temperature for personnel pro tection or ignition.
Safety from radioactivity or chemicaf reacn.
oafety from toxic conditions. fire protection.
When hot equipment or piping is located where ns insulation may be touched by per sonnel. the insulation should be so designed that its thermal resistance, surface emntance, and jacket conductivity together create a con dition which will not produce skin burns whan *ts outer surface is accidentally touched. In gen eral. metallic surfaces at a temperature over 145*F can cause skin burns. A specific figure is not possible as this depends upon the indi vidual. the roughness of the surface, the clean ness of the surface, and the conductivity and mass of the metal. The higher the conductivity of the metal, the smoother the surface, the cleaner the surface, and the greater the mass of metal, the more likely a person is to be burned at a particular temperature.
Where combustible materials are present and chances of leakage or spillage prevail, a suitable low surface temperature of insulated vessels and piping may be very important in preventing
gmtion of these materials. When this con ic i prevails, it becomes necessary that all not surfaces, such as valves, flanges, and metal projections, be insulated so as to maintain all exposed surfaces below the maximum allow able surface temperature. Some areas which cannot be insulated, such as valve bonnets and stuffing boxes, may require shielding to prevent contact with the chemical.
As previously mentioned, non-combustible but absorptive insulation may be a fire hazard tn two ways. First, in the case of combustible material leaks, the insulation's tremendous in ternal surface area can assist tn causing rapid oxidation which will result in spontaneous com bustion Second, also in the case of leaks, any absorbent can hold large quantities of com bustibles and. if an accidental fire occurs, the saturated insulation will feed and spread it. To illustrate the potential hazard--a cubic foot of saturated insulation can hold approximately six gallons of combustible matsnal. In case of ignition, the insulation then acts like the wick of
Installation Requirements 205
a lantern. Even though it does not itself burn, it conveys the vaporizing combustible to the sur face where U can burn For these reasons, it is evident that the process, the materials being processed, the potential of leaks, ana the degree of hazard of the location, all must be considered m the selection and design of an insulation sys tem.
The potential fire hazard of an insulation, as related to an installation, has been shown. However, properly used insulation can be used as fire protection. An installation on equipment and piping must be considered from rwo basi cally different viewpdtnts. First, the combusti bility of the insulation must be considered, in cluding the speed at which the insulation will spread fire, or the amount of heat and smoke it will contribute. Second, the time rate at which temperature will pass through the insulation from the fire side to the vessel or pipe must be thought of.
Where fire spread is hazardous, the system should be of non-combustible insulations which do not contribute fuel to the fire. In many in stances light weight insulations and thin me tallic jackets will meet these requirements.
If vessels and piping are to be protected for a period of time from accidental fire, then the time required for the high temperature of the fire to pass through the insulation to the pipe or vessel is of utmost importance. Where this is a requirement, light weight materials of high diffusivity are of little advantage even though they are incombustible. To illustrate: a piece of wood will provide much greater time-temperature protection to a vessel than any insulation of 2 to 3 lbs. density, even while burning on its outer surface. Of course, the use of wood is not rec ommended for fire protection as it can add con siderable fuel to a fire. It was mentioned only to show that, for temperature retardation, the rate of diffusivity and mass are the deciding factors, not conductivity (by itselfi or combusti bility.
Economic requirements
The economic value of the insulation depends upon the installation requirements, and. as this
1970 ANNUAL BOOK OF ASTM STANDARDS
PART 14
Thermal and Cryogenic Insulating Materials;
/ 'I Materials; Building Joint Sealants;
f . Tests; Building Constructions
>T 0/
--i
* U
Includes Standards of:
Committee C-16on Thermal and Cryogenic Insulating Materials C-20on Acoustical Materials C-24 on Building Joint Sealants -5 on Fire Tests of Matenals and Construction E-6on Performance of Building Constructions
Price Si9.00
AMERICAN SOCIETY FOR TESTING AND MATERIALS
1916 Race St.. Philadelphia, Pa. 19103
EXHIBIT MO
LIST BY SUBJECTS, PART 14
Thermal and Cryogenic Insulating Materials, Acoustical Materials, Building Joint Sealants, Fere Tests, Building Constructions
Since the standards in this book are arranged in alphanumerical sequence, no page num bers are given in this list.
THERMAL AND CRYOGENIC INSULATING MATERIALS
Specificoiions for:
*C 391 - 64
Amosite Asbestos Thermal Insulation for Pipes
c 194 - 64
Asbestos Thermal Insulating and Finishing Cement
c 533 - 67
Calcium Silicate Block and Pipe Thermal Insulation
c 298-56 (1965) Cellular Asbestos Paper Thermal Insulation for Pipes
c 552 - 66
Cellular Glass Block and Pipe Thermal Insulation
c 640 - 69
Corkboard and Cork Pipe Insulation for Low Temperature Thermal
c 517-64
Insulation Diatomaceous Earth Block and Pipe Thermal Insulation
c 197 - 61 (1967) Diatomaceous Silica Thermal Insulating Cement
c 489 - 64
85 Per Cent Magnesia Block and Pipe Thermal Insulation
c 196 - 61 (1967) Expanded or Exfoliated Vcrmiculite Thermal Insulating Cement
c 610 - 67
Expanded Perlite Block and Pipe Thermal Insulation
c 299 - 56 (1965) Laminated Asbestos Thermal Insulation for Pipes
c 193 - 64
Magnesia Thermal Insulating Cement
c 262 - 64
Mineral Fiber Batt Insulation (Industrial Type)
c 553- 70
Mineral Fiber Blanket and Felt Insulation (Industrial Type)
c 592 - 70
Mineral Fiber Blanket Insulation and Blanket-Type Pipe Insulation
c 665 - 70
(Metal-Mesh Covered) (Industrial Type) Mineral Fiber Blanket Thermal Insulation for Wood Frame and
c 612 - 70 c 449-64
Light Construction Buildings Mineral Fiber Block and Board Thermal Insulation Mineral Fiber Hydraulic-Setting Thermal Insulating and Finishing
c 547 - 67 c 195 - 64 c 549 - 67 c 578 - 69 c 534- 70
Cement Mineral Fiber Preformed Pipe Insulation Mineral Fiber Thermal Insulating Cement Perlite Loose Fill Insulation Preformed, Block-Type Cellular Polystyrene Thermal Insulation Preformed Flexible Elastomeric Cellular Thermal Insulation
in
Sheet and Tubular Form
c 591 - 69 c 656 - 70
Rigid Preformed Cellular Urethane Thermal Insulation Structural Insulating Board, Calcium Silicate
c 208-60 (1966) Structural Insulating Board Made from Vegetable Fibers
c 532 - 66
Structural Insulating Formboard Made from Vegetable Fibers
c 516 - 67
Vermiculite Loose Fill Insulation
*E 11-70
Wire-Cloth Sieves for Testing Purposes*
* Approved as American National Standard by American National Standards Insti tute.
xv
Method] oj Test for;
C 590-69
Action on Subatrate* by Coatings, Adhesives, and Joint Sealants
Used on or with Thermal Insulations
C 353 - 56 (1965) Adhesion of Dried Thermal Insulating Cement
C 383 - 58 (1967) Adhesion, Wet, of Thermal Insulating Cements to Metal
C 589 - 68
Apparent Impact Strength of Preformed Block-Type Insulating
Materials
C 203 - 58 (1965) Breaking Load and Calculated Flexural Strength of Preformed
Block-Type Thermal Insulation
C 446 - 64
Breaking Load and Calculated Modulus of Rupture of Preformed
Insulation for Pipes
C 240 - 61
Cellular Glass Insulating Black (see Bart IS)
C 165 - 54 (1970) Compressive Strength of Preformed Block-Type Thermal Insulation
*C 354- 56 (1965) Compressive Strength of Thermal Insulating Cement
C 405 - 60 (1967) Consistency of Wet-Mixed Thermal Insulating Cement
'C 464-64
Corrosion Effect of Thermal Insulating Cements on Base Metal
*C 166-61 (1967) Covering Capacity and Volume Change Upon Drying of Thermal
Insulating Cement
C 519 - 65
Density of fibrous Loose Fill Building Insulation
C 520 - 65
Density of Granular Loose Fill Insulations
C 303 - 56 (1965) Density of Preformed Block-Type Thermal Insulation
C 302 - 56 (1965) Density of Preformed Pipe-Covering-Type Thermal Insulation
C 548 - 69
Dimensional Stability of Low-Temperature Thermal Block and Pipe
Insulation
C 487 - 64
Dropping of Preformed Block-Type Thermal Insulation, Resistance
to
*C 445-61 (1967) Emmittance, Normal Total, of Surfaces of Materials 0.01 in. or
Less in Thickness at Approximately Room Temperature
*C 488 - 64 (1970) Exposure Tests of Finishes for Thermal Insulation, Conducting
Exterior C 411 - 61 (1967) Hot-Surface Performance of High-Temperature Thermal Insulations
C 569 - 68
Indentation Hardness of Preformed Thermal Insulations
*C 461 - 64
Mastic Coatings Used in Conjunction with Thermal Insulation
*C 447 - 64 .
Maximum Use Temperature of Preformed High-Temperature In
sulation, Determining
C 421 - 61 (1967) Mechanical Stability of Preformed Thermal Insulation by Tumbling
C 163 - 64
Muring Thermal Insulating Cement Samples
C 390 - 60 (1967) Sampling Preformed Thermal Insulation
C 356 - 60 (1967) Shrinkage, Linear, of Preformed High-Temperature Thermal In
sulation Subj'ected to Soaking Heat
C 351 - 61 (1967) Specific Heat, Mean, of Thermal Insulation
C 209 - 60 (1966) Structural Insulating Board Made from Vegetable Fibers
C 419 - 65
Test Specimens of Mastic Thermal Insulation Coatings, Making
and Curing
*C 236-66
Thermal Conductance and Transmittance of Built-Up Sections by
Means of the Guarded Hot Box
*C 177 - 63 (1968) Thermal Conductivity of Materials by Means of the Guarded Hot
C 518-70
Plate Thermal Conductivity of Materials by Means of the Heat Flow Meter
C 335 - 69
Thermal Conductivity of Pipe Insulation
*C 167 - 64 (1970) Thickness and Density of Blanket- or Batt-Type Thermal Insulating
Materials
C 550 - 68
Trueness and Squareness of Block Thermal Insulation
E 96-66
Water Vapor Transmission of Materials in Sheet Form
C 355 - 64
Water Vapor Transmission of Thick Materials
Recommended Practices jor:
C 585 - 68
Inner and Outer Diameters of Rigid Thermal Insulation for Nominal
C 450 - 68
Sizes of Pipes and Tubing (NPS System) Prefabrication and Field Fabrication of Thermal Insulating Fitting
Covers tor NPS Piping, Vessel Lagging, and Dished Head Seg
C 653 - 70
ments Thermal Resistance of Low-Density Mineral-Fiber Blanket-Type
Building Insulation, Determination of
41-17
List by Subjects
xvii
Definitions of Terms Relating to:
C 168-67
Thermal Insulating Materials
Guide for: C 647 - 69
Properties and Tests of Mastic Coatings for Thermal Insulation
ACOUSTICAL MATERIALS
Specifications for: C 635- 69
Metal Suspension Systems for Acoustical Tile and Lay-In Panel Ceilings
M ethods of Test for:
C 522-69 C 384-58
C 523 - 68
C 643 - 69 C 423-66
C 367-57
Airflow Resistance of Acoustical Materials Impedance and Absorption of Acoustical Materials by the Tube
Method Light Reflectance of Acoustical Materials by the Integrating Sphere
Reflectometer Painting Ceiling Materials for Acoustical Absorption Tests Sound Absorption of Acoustical Materials in Reverberation Rooms Strength Properties of Prefabricated Architectural Acoustical Ma
terials
Recommended Practices for:
E 90-70 C 636-69 E 336 - 67 T
Airborne Sound Transmission Loss of Building Partitions, Labora tory Measurement of
Installation of Metal Ceiling Suspension Systems for Acoustical
Tile and Lay-In. Panels Measurement of Airborne Sound Insulation in Buildings
Definition of Terms Relating to:
C 634 - 69
Acoustical Tests of Building Constructions and Materials
BUILDING JOINT SEALANTS
Specifications for:
C 509-70 C 542 - 69 C 564-70 C 510-66
Cellular Elastomeric Preformed Gasket and Sealing Material Elastomeric Structural Glaring and Panel Gaskets Rubber Gaskets for Cast Iron Soil Pipe and Fittings Staining and Color Change of One- or Two-Part Joint Sealants
Methods of Test for:
D 2450 - 69 D 2451 - 69 D 2452 - 69 C 603 - 69
C 661-70
D 2249 - 67
C 639-69
D 2453-69 D 2376 - 67 D 2202-66 D 2203-66 D 2377 - 67
Bond of Oil and Resin-Base Caulking Compounds Degree of Set for Glazing Compounds on Sash Extrudability of Oil and Resin-Base Caulking Compounds Extrusion Rate of One- and Two-Part Joint Sealants and Applica
tion Life of Two-Part Joints Sealants Indentation Hardness of Elastomeric Type Sealants by Means of a
Durometer
Predicting the Effect of Vreathering on Face Glaring and Bedding Compounds on Metal Sash
Rheological (Flow) Properties of One- and Two-Part Joint Sealants
to Be Used in Building Construction Shrinkage and Tenacity of Oil and Resin-Base Caulking.Compounds
Slump of Face Glaring and Bedding Compounds on Metal Sash Slump of Oil and Resin-Base Caulking Compounds Staining of Oil and Resin-Base Caulking Compounds Tack-Free Time of Oil and Resin-Base Caulking Compounds
FIRE TESTS
Methods of Test for:
"E 119-69 *D 1230 - 61
Building Construction and Materials, Fixe Tests of Clothing Textiles, Flammability of (see Part 2d)
n--t:
A ' A A-*
Methods of Test for:
*E 152-66
Door Assemblies, Fire Testa of
D 1433 - 58 (1966) Flexible Thin Plastic Sheeting, Flammability of (see Pari 27)
E 136-65
Noncombustibility of Elementary Materials
D 1360 - 58 (1965) Paints, Fire Retardancy of (Cabinet Method) (see Part 21)
D 1361 - 58 (1965) Paints, Fire Retardancy of (Stick and Wick Method) (see Part 21)
D 777 - 46 (1965) Paper and Paperboard, Treated, Flammability of (see Part 15)
D1692 - 68
Plastic Sheeting and Cellular Plastics, Flammability of (see Part 27)
D 568 - 68
Plastics, Flexible, Flammability of (see Part Z7)
D 757 - 65
Plastics, Self-Extinguishing Type, Flammability of (see Pari 27)
D 635 - 68
Plastics, Self-Supporting, Flammability of (see Part 27)
E 108 - 58 (1970) Roof Coverings, Fire Testa of
E 84-68
Surface Burning Characteristics of Building Materials
E 286-69
Surface Flammability of Building Material! Using an 8-ft (2.44-m)
Tunnel Furnace
E 162 - 67
Surface Flammability of Materials Using a Radiant Heat Energy
Source
E 160 - 50 (1969) Treated Wood, Combustible Properties of, by the Crib Test
E 69-50 (1969) Treated Wood, Combustible Properties of, by the Fire-Tube Ap
paratus
E 163 - 65
Window Assemblies, Fire Tests of
Definitions of Terms Relating to:
E 176 - 66
Fire Testa of Building Construction and Materials
PERFORMANCE OF BUILDING CONSTRUCTIONS
Methods of Test for:
E 149-66 E 73-70 E 196-66 E 72-68
E 283 - 68 E 330 - 70
E 154-68
E 331-70
*C 355-64 E 405 - 70
Bond Strength of Mortar to Masonry Units Truss Assemblies Load Tests of Floors and Flat Roofs
Panels for Building Construction, Conducting Strength Tests of Rate of Air Leakage Through Windows
Structural Performance of Exterior Windows, Curtain Walls, and Doors Under the Influence of Wind Loads
Vapor Barriers, Materials for Use as, Under Concrete Slabs and as Ground Cover in Crawl Spaces
Water Penetration of Exterior Windows, Curtain Walls, and Doors by Uniform Static Air Pressure Differential
Water Vapor Transmission of Thick Materials Wear Testing Rotary Operators for Windows
Recommended Practices for:
E 241-68 E 90-70 E 336 - 67 T
Increasing Durability of Building Constructions Against Water Damage
Laboratory Measurement of Airborne Sound Transmission Loss of Building Partitions
Measurement of Airborne Sound Insulation in Buildings
Classification for: E 413 - 70 T
Sound Transmission Class, Determination of
380 - 70
METRIC PRACTICE GUIDE
Metric Practice Guide (Excerpts) (see Related Materials section)
NEW AND REVISED STANDARDS RECEIVED TOO LATE FOR PUBLICATION
(Available as Separate Reprints)
New Standards:
C 667 - 70, Recommended Practice for Prefabricated Reflective Insulation Systems for Equipment and Pipe Operating at Temperatures Above Ambient Air
C 669- 70, Specifications for Glazing Compounds for Back Bedding and Face Glazing of Metal Sash
37-43
RcAsion of Standards:
C 517-70 E 84 - 68
Reapproval of Standards:
C 165-64 (1970) C 193 - 64 (1970) C 194 - 64 (1970) C 195 - 64 (1970) C 449 - 64 (1970) C 464 - 64 (1970)
List by Subjects
xix
C53-W X
1970 ANNUAL BOOK OF ASTM STANDARDS
PART 12
Chemical-Resistant Nonmetallic Materials; Clay and Concrete Pipe and Tile; Masonry Mortars
and Units; Asbestos-Cement Products; Natural Building Stones
Includes standards of:
Committee C-3 on Chemical-Resistant Nonmetallic Materials C-4 on Clay Pipe C-12 on Mortars for Unit Masonry C-13 on Concrete Pipe C-15 on Manufactured Masonry Units C-17 on Asbestos-Cement Products C-18 on Natural Building Stones
property of
brown 8: ROOT, INC.
TEOH i\il C'.u. J i `Rradv TA-tC1/.Ac5/1970/p t. 12 American Society for Teeti Annual book of ASTM
tandards. YM c. 1 Ah Historical
Price S16.00
AMERICAN SOCIETY FOR TESTING AND MATERIALS
1916 Race St., Philadelphia, Pa. 19103
CD in
CONTENTS
1970 ANNUAL BOOK OF ASTM STANDARDS, PART 12
ASTM Standards and Tentatives Relating to Chemical-Resistant Nonmetallic Materials; Clay and Concrete Pipe and Tile; Masonry Mortars and Uniis; Asbestos - Cement Products; Natural Building Stones
A complete Subject Index appears on p. 479.
This contents includes only those standards and tentafives in thl book and those standards in the area covered by Part 12 that have been superseded or dis continued during the past five years. Since the standards in this book are arranged in numeric sequencer no page numbers are given in this contents.
In the serial designations prefixed to the following titles, the initial letter, indicative of the general classification, and the first number are permanent. The number following the dash indicates the year of original issue as tentative or of adoption as standard or, in the case of revision, the year of last revision. Thus, standards adopted or revised during the year 1969 have as their final number, 69. A letter following this number indicates more than one revision during that year, that is 69a indicates the second revision in 1969, 69b the third revirion, etc. Tentatives are identified by the letter T. Standards that have been reap proved without change are indicated by the year of last approval in parentheses as part of the designation number, for example, (1969).
C 4-62
Spec, for Clay Drain Tfle
C 7-42 (1965) Spec, for Paving Brick
*C 12-64
Rec. Practice for Installing Vitrified Clay Sewer Pipe
C 13 -- 69
Spec, for Standard Strength day Sewer Pipe
C 14-68
Spec, for Concrete Sewer, Storm Drain, ana Culvert Pipe
*C 32 - 69
Spec, for Sewer and Manhole Brick (Made from Clay or Shale)
*C 34 - 62
Spec, for Structural day Load-Bearing Wall Tile
C 43 - 65 T Def. of Terms Relating to Structural day Products
C 52-34 (1965) Spec, for Gypsum Partition Tile or Block
C 55 - 66 T Spec, for Concrete Building Brick
C 56 - 62
Spec, for Structural day Non-Load-Bearing Tfle
C 57 - 57 (1965) Spec, for Structural day Floor Tfle
*C 62 - 69
Spec, for Building Brick (Solid Masonry Units Made from day or
Shale)
C 67 - 66
Sampling and Testing Brick
C 73 - 67
Spec, for CaJdum Silicate Face Brick (Sand-Lime Brick)
C 76 - 69
Spec, for Reinforced Concrete Culvert, Storm Drain, and Sewer Pipe
*C 90 - 66 T Spec, for Hollow Load-Bearing Concrete Masonry Units
C 97-47 (1970) Tests for Absorption and Bulk Specific Gravity of Natural Building
Stone
C 99-32 (1970) Test for Modulus of Rupture of Natural Building Stone
*C 112 - 60
Sampling and Testing Structural Clay Tfle
C 118-69
Spec, for Concrete Pipe for Irrigation or Drainage
C 119 - 50 (1958) Def. of Terms Relating to Natural Building Stones*
* Approved &a American National Standard by the American National Standards Institute.
c 120 - 52 (1970) ; iexure Testing of Slate (Modulus of Rupture, Modulus of Elasticity)
c 121 - (1970) `
c 126-69
Spec for Ceramic Glazed Structural Clay Facing Tile, Facing Brick,
and Solid Masonry Units
c 129 - 64 T Spec for Hollow Non-Load-Bearing Concrete Masonry Unit*
c 139-65
Spec for Concrete Masonry Units for Construction of Catch Basins and Manholes
c 140 - 65 T Sampling and Toting Concrete Masonry Units
c 144-69
Spec for Aggregate for Masonry Mortar
c 145 - 66 T Spec for Solid Load-Bearing Concrete Masonry Units
c 159-63
Spec for Vitrified Clay Filter Block for Trickling Filters
c 170 - 50(1970)'Test for Compressive Strength of Natural Building Stone
c 200 - 69
Spec for Extra Strength Clay Pipe
c 211-68
:Spec for Standard and Extra Strength Perforated Clay Pipe
c 212-60
Spec for Structural Clay Facing Tile
c 216-69
Spec for Facing Brick (Solid Masonry Units Made from Clay or
Shale)
c 217 - 58 (1970) Test for Weather Resistance of Natural Slate
c 218
(Test for Effect of Combined Temperature Cycles and Weak Salt Solu
tions on Natural Buildini Slone) Discontinued 1965
*c 220-67
Spec for Flat Asbestos-Cement Sheets
*c 221-61 (1968) Spec and Methods of Test for Corrugated Asbestos-Cement Sheets
*c 222 - 66
Spec for Asbestos-Cement Roofing Shingles
c 223 - 66
Spec for Asbestos-Cement Siding
c 241 - 51 (1970) 'Test for Abrasion Resistance of Stone Subjected to Foot Traffic
c 267-65
Test for Chemical Resistance of Mortars
c 270-68
Spec for Mortar for Unit Masonry
c 279-54 (1965) Spec for Chemical-Resistant Masonry Units
c 287-67
Spec for Chemical-Resistant Sulfur Mortar
c 296-69a
Spec for Asbestos-Cement Pressure Pipe
*c 301-68
Testing Clay Pipe
c 306 - 60
c 307-61
Test for Compressive Strength of Chemical-Resistant Resin Mortars Test for Tensile Strength of Chemical-Resistant Resin Mortars
c 308 - 64
Testa for Working and Setting Times of Chemical-Resistant Resin
Mortars
c 315 - 56(1965) Spec for day Flue Linings
c 321-64
Test for Bona Strength of Chemical-Resistant Mortars
c 331-69
Spec for Lightweight Aggregates for Concrete Masonry Units
c 361-70
Spec for Reinforced Concrete Low-Head Pressure Pipe
c 386-60
Rec Practice for Use of Chemical-Resistant Sulfur Mortars
c 395-64
Spec for Chemical-Resistant Resin Mortars
C 396
(Test for Compressne Strenrfh of Chemically Setting, Silicate and
Silica Chennai-Resistant Mortars) Discontinued 1968--Replaced
c 397 - 67
by Method C 579
Rec Practice for Use of Chemically Setting Chemical-Resistant Sili
cate and Silica Mortars
c 398 - 65
Rec Practic* for Use of Hydraulic Cement Mortars in Chemical-
Resistant Masonry
c 399 - 67
Rec Practice for Use of Chemical-Resistant Resin Mortars
c 404 - 61 (1969) Spec for Aggregates for Masonry Grout
c 406 - 58
Spec for Roofing Slat*
c 410-60
Spec for Industrial Floor Brick
c 412-65
Spec for Concrete Drain Tile
c 413-66
Teat for Absorption of Chemical-Resistant Mort 5
c 414-65 `
Testa for Working and Setting Times of Chennai Resistant Silicate
and Silica Mortars
c 425 - 66 T c 426 - 66 T c 427 - 64
Spec for Compression Joints for Vitrified Clay Bell and Spigot Pipe Test for Drying Shrinkage of Concrete Block
Test for Moisture Condition of Hardened Concrete by the Relative
c 428 - 69a c 443 -70
Humidity Method Spec for Asbestos-Cement Nonpressure Sewer Pipe Spec for Joints for Circular Concrete Sewer and Culvert Pipe, Using
c 444 - 68
Rubber Gaskets Spec for Perforated Concrete Pipe
JW
Contents
XI
C 453
{Test for FUzwoi Strength of Chemically Setting Silicate-Type Chemi-
cal-Rcsistani Mortars) Discontinued 1967--Replaced try Method
C 5S0
C 458 - 62 (1968) Test lor Organic Fiber Content of Asbestos-Cement Products
C 459-63
Sampling and Testing Asbestos-Cement Flat Sheets, Roofing and
Siding Shingles, ana Clapboards
C 460 - 69
DeL of Terms Relating to Asbestos-Cement and Related Products
C 466 - 64
Spec, for Chemically Setting Silicate and Silica Chemical-Resistant
Mortars
C 476-63(1969) Spec, for Mortar and Grout for Reinforced Masonry
C 477
(Spec, for Cast-in-Place Nonreinjcreed Concrete Agricultural Pipe
line) Discontinued 1970
C 478-69
Spec, for Precast Reinforced Concrete Manhole Sections
C 479-68
Spec, for'Vitrified Clay Liner Plates
C 497 - 70
Tests for Determining Physical Properties of Concrete Pipe or Tile
C 498-65
Spec, for Perforated Clay Drain Tile
C 500 - 69a
Testing Asbestos - Cement Pipe
C 503-67
Spec, for Exterior Marble
C 505 - 70
Spec for Nonreinforced Concrete Irrigation Pipe with Rubber
Gasket Joints
C 506-69
Spec for Reinforced Concrete Arch Culvert, Storm Drain, and
Sewer Pipe
C 507 - 69
Spec for Reinforced Concrete Elliptical Culvert, Storm Drain, and
Sewer Pipe
C 508-67
Spec for Asbestos - Cement Perforated Underdrain Pipe
C 515-63 T
Spec for Chemical-Resistant Ceramic Tower Packings
C 530 - 63 T
Spec for Structural Clay Non-Load-Beaxing Screen Tile
*C 531-68
Test for Shrinkage and Coefficient of Thermal Expansion of Chemi
cal-Resistant Mortars
C 541-67
Spec for linings for Asbestos-Cement Pipe
C 543 - 67
Spec for Slate Blackboards
C 551-67
Spec for Asbestos-Cement FIberboard Insulating Panels
C 568-67
Spec for Dimension limestone
*C 579-68
Test for Compressive Strength of Chemical-Resistant Mortars
*C 580-68
Test for Flexural Strength and Modulus of Elasticity of Chemical-
Resistant Mortars
C 581-68
Test for Chemical Resistance of Thermosetting Resins Used in Glass
Fiber Reinforced Structures
*C 582-68
Spec for Reinforced Plastic Laminates for Self-Supporting Struc
tures for Use in a Chemical Environment
C 594 - 66 T
Spec for Compression Couplings for Vitrified Clay Plain-End Pipe
C 608-67 T
Test for Brittle Ring TensOe Strength of Chemically Setting Silicate
and Silica Chemical-Resistant Mortars
C 615-68
Spec for Structural Granite
C 616-68 C 619-68 T
Spec for Building Sandstone Test for Chemical Resistance of Asbestos Fiber-Reinforced Thermo
setting Resins Used in Self-Supporting Structures
C 629 - 68
Spec for Structural Slate
C 644 - 69
Spec for Asbestos-Cement Nonpressure Small-Diameter Sewer Pipe
D1869 - 66
Spec for Rubber Rings for Asbestos - Cement Pipe
RELATED MATERIAL
PACE
Metric Practice Guide (Excerpts) (E 380)...................................................................... Related ASTM Publications.................................................................................................
Index.......................................................................................................................................... ASTM Membership Application Blanks
469 477 479
TENTATIVE REVISIONS
Under the standardization procedure of the Society, Tentative Revisions of ASTM Standards are published for one or more years with a view of eliciting criticisms of which the committee concerned will take due cognizance before recommending final action.
The Tentative Revisions pending of standards in this part are listed below.
in
c 126-69 *C 56-62
C 14-68
Manufactured Masonry Units
Specifications for Ceramic Glared Structural Clay Facing Tile, Facing Brick, and Solid Masonry Units
Specifications for Structural Clay Non-Load-Bearing Tile
Pipe and Drain Tile
Specifications for Concrete Sewer, Storm Drain, and Culvert Pipe
0*4
aridIng Su6/e peeringIndeJ^er, oatg
A
Industry Standards and Engineering Data
Subject Index To:
INDUSTRY STANDARDS AA-Tha Aksrwujsi Association AASHTO-Amancan Association ol Suite Hx;rrwiy eno Transoortaoon Ottotil AATCC-Amancan Aisooabon ol Ttrtila ClWTBB an) Cotonitl ABMA-Amancan Baarrg Manuiaeturars Assooaoon
ABS-Amancan Bursau ol Smcom ACl-Amanean Comrtt* irisotuta A.Q_A.-Amancan Gas Assoaaoon AGMA-Amancan Gear Manatacturars Assoaaoon
AIA/NAS*Aaroaoaca nouitnes Association ol America AhAaonatt nsotuta AlASWThe American instrtuta ol Arervtects AlChE-Amencan nstmna ol Chemcal Engnaars AIIM-Assoaanon tor Wormaoon am image Managamant AISC*Amancan Institute ol Steel Construction AISKAmencan iron am Steel institute ANS-American Nuaaar Sooery AN 54-American Naoonal Sunoaros instmne APt-Amancan Petroieun nsotuie AREA-Amencan Raitwey Engmeemg Assoaaoon Afll-A*-Conditionng am Aelngenoon ins mute
ARINC-Aeronauocal Raao ASA-Acousacal Sooery ol America ASAE-The American Sooery ol Agricultural Engneers ASCE-Amencan Sooery ol Civil Engnaars
A$HRA*A/nf<an Sooery of Mrmg, Refngenfirg *r*d *jrCo^On<nr>g Engagers
ASME*A/T*rc*n Sooery of Mecnemcai Er>gineers
ASNTArwic*n Sooery for Noooestructrve Testing
ASQC'Amencan Sooery for Qualify Conirof
ASSE-Amencan Sooery ol Sanrtary Engrteermg
ASTW-Amencan Sooery for Testing and Uaienaa AWS^A/nercan Wsicmg Society
AWWA-Amenean Water works Association
A2LA*A^ercan Auooabon for Laboratory Accredfts&on
BHMA-6uk>eri narOware Manufacturers Assooaaon
CQA<cmorss] Gas Assooaoon
CTJ-Cooing Tower institute ElA-Wcron< inousinas Assooation
QPA-Gas Processors Assooa&on
lEEE-tnsxrtute ol ElectncaJ and Electronics Engr>eers lESHA-femmeting Engnoemg Sooety of Ncrtn America
IFWoustnai Fasteners institute I PC-The institute tor tmercorviecting and Packagng Electron* Orcuts
ISA-tnstrvnent Sooety of America ISHM-memabonal Sooery lor Kyonc M*foe*ectfomcs MSS-Uanutacturer Stanoardoabon Sooety of tne VaNe and Fittings industry
NACE^rauonal Assooaipon of Corrosion Engneen NE8&-Mabonal Environmeniai Balancing Bureau NEMA-frauonai Electncai Manufacturers Assocauon NFPA-Neuonaf Fire Protection Ajsooauon NFPfAJ-Naoonai fiukj Power Association NISO-Naiioruj information Sunoaros Qrgancaiton NSF-Nauonai Saniiaiion Foundation PFl*Px>e Fabncanon institute PPMMsocs Pg* institute RTCA-Raoo Tecnmcal Commission for Aeronautics RWMA-Resistance We*oer Manufacturers Association SAE*Sooery of Automotive Engineers SEM(-Sem<onductor Eoi^omeni and Matena* international SJhSteef Joat institute SMACNA-Sheel Meut and Air Ccndroormg Contraoori' National Aasooa&on SSPC-S'eef Structures Pamung Counof TAPP! UL-Underwriting Laboratories Inc
ENGINEERING DATA CED-CrW Engneerag Gaia MCtC-Meoi and Cerames information Center NTIAC-Nonoestmctive Testing information Analysis Center PLASTEC-Ptasacs Tecm-icai Evaluation Center RAC-RefiaoUily Analysis Center
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Historical Industry Standards
A.GJk.-Amencsn Gu Assoaaoon ANS-Amancan Nuaear Sooaiy ANSt-Amencan National Standards nsotuta APV-Amencan Petroleum institute
ASME-Amencan Sooaty of Meenaracai Engineers
ASTM-Amenean Sooaty lor Ttsong am Maienns
AWS-Amencan WaWrg Sooaty
lEEEHnsmute o< Electrical am Elacironcs Engnaars
NEMA-NaoonaJ ElactncaJ Manulaeiureri Assoaaoon
NFPA-NaOoral Rra Proiacoon Aaaooatxxi
International and Non-U.S. National Standards
AECMA-Asaoaaaon c Eurooaan Avcrafl am Comoonants Mamtacturars
AFNOR-Pranen Sunoaros
BSt-Qnwn Standarot institution CAA-Ontati ON Aviation Autnonty
CCIR-traamaaonal Ratio Consunaova Commmaa
CCrTT-tntamational Consunaova Commmaa on Talagraon am Tatatsnona
CECC-Canatac Elaarorvc Comtionano Commmaa
CEN-EtAooaan Commmaa tor Stamarauanon
CENELEC-Eurooaan Commmaa tor Elacvotacnracal Stama/daaoon
CEPT-Contaranca ol Eurooaan Postal am Talacomrrvrvcaflora AOmnsnson
CGSB-Cana<San Ganarai Samards Board
CNS-Owiasa |ROC) Naoonal Sianoaras
CPPA-Carjtlao Paoar am Pu)o Assoaaoon
CSA<anadan Stamaros Association
DIN-Gatman Stamaros
ECMA-Eurooaan Comoutar Uarvjfaouran Assoaaoon
EC-tmoati Coiatal/Commasan Lagislaova DocLxnara
ETSI-Eurooaan Taiacnrmxrvcaoora Stanaarai nsotuw
EUROCAE-Eurooaan Orgaraaoon for CaN Awaoon Elactraraes ICAO-aitamaoonaJ ON Avia non Organzaoon ISC-nwmaocnal Elaciroleavacal Commanon ISO-tntamaoonai O'ganaaoon tor Siamarooaoon JIS'Gaoanasa noustnai Stamaros OSI-Opan Sysiams iniarcomacoon SAA-Stamaros Assoaaoon o< Australia SASO-Sauti Araoan Sunoaros Orgarvaaoon SBAC'Sooaty oI Brmsn Aarosoaca ComoanvS VDE-Assoaaoon ol Carman ElactncaJ Engnaars
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Car U|H( Tea|--AmTiciaJ
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--Abruion Taring
ASTM F10I344. Slteda/d Tai Method fa KUu Abrumn of SymteiK Tarf Plajrmi Surfaen fF 1191V
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ASTM Fl231*44. Suited Te* Mctbadi far Caatpreterur** CWwmunw of
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{Jac Ean/oftmental Tottfift
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Stvpt Pfafar Um ft tnort ipeefic tens Sots Architectural Scrm A/i Supplier Handicraft*;
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5cp* Atoe For addiuooaj hmp- tee ipccirtc proOoeu made from abate Sm Abac Ajbota Canesa; Ateclir* Coeteal Ateyw Aabotoi Fabr^ Aftbenoa Tftpcc AftM&oa Yana; Fiber*
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PLASTEC F3ft 44 Ffecr Faafaroad uo: Apyftkauau. Mokbng . tad fafarman Data.
2017*023
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--Chloride loo Coteat--Leachate Ejrtrkctio. Vefaaetrle Anatnti ASTM C122ML Suanrf Tm Malm tar Solukta CUenta* a fwtmm
--Oarificadoa ATTM C721I7-1A Jnatart Tm Mctbok tar MeMcn fWn^. of Man F4ar (It 1*11
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ASTM 0943-41 Standard Tc* Melted far Ccter at AOaei
--Coaprodrt Propcda
ASTM OU3-VX Stteard Tai Method d t.tmury of
2140.1743 3130 9-14
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2243-001 1430 0-07 >447 D-12
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2245-140 1430 on M4 0*03
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2017*1223 1341 007
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ASTM tlrte-ei. Saadard Tneaa far > to 5*rar- ar-Tiaata-
KM-MU 1112 C-OS
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ASTM P1M.1A Prepend Tor Mated tar Adi tel. raM| Marel r Potetanl Li(M Mkraeopy.
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ASTM Cl 132*401 Saacfcrt Tat Mated > <d AjteooA
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ASTM D2733-U. teafard Tot Metbafa far Ar hnaftdi arf Ajbeaa Ffean
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ASTM 0241743. Sunterd Ten Mcited
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ASTM Cl 11344. Sunterd Tai Mctted far Pw>auw iwu at * dyrra
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ASTM 1333-40. Saadvd Pnoka far lapacnea at Ajttatec
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2140*1743 3130 9-14
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ASTM 01590*91. Sutead Tat Mated far Stapfcaft QhryHBkb lharr*
ASTM D3*74-91. Staadud Tai Mabod
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ASTM 0220*4!. If fan! Tte Mated far Wa9 Tot at idiaia
ASTM 0121-40. StMterd Tat Mated far Tear ate Nad (T ate N) Va4aiO QaiAeMM of ***
ASTM D2947-U. Stated Tat Mafeod far Vtwi Atepia at Ateta Rban CF im\
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Lfae Afttocnoi Cbpoi Sadia*
Asbestos Cement Panel Siding
EJter Asfatmo6 Crtbtai Sadfa*
Asbestos Cement Pipes
Sm Ahm ASTM <
ASTM 073-52.' SteteJV
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far AbteB^tete Ctecfad. AWWA M>4*7F Wat Fnctiem far
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ASTM CS9-a Steted ! far .
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ASTM C34341. Steted :
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ASTM C434*41. 1mted Tai Matexfa Fte
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ASTM C111MQ. Sfaated Ta far Ve
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AJTM 03442-11. SiarwUrd Tra Melted hr Major te Minor Lkmcna m Coal and Coil Ate fa Atomic Ateorpian.
AJTM 0344944. Standard Tra Mated far Tnci Daoenu ut Coni and Coke Ate fa Aiorac Alaorpuen.
AJTM 0*412-44. Standard Tra Mated far Ate a Aanfara of twtmeam Com.
AJTM 0901911 Standard Tra Mated far Sntfu a Ate tram Coni and Coke Umnf Hite- Trapcmnrt Tuba farmer Caenbtaoaa Meted vte Isfrvte A--orpuaoL
A2LA. Arani Wihorb Mm, Xnmibari. 1L rdrraary at Accradaad
LteonaorraX AlLA Cypna faatoia ConJ Labontofa.
Free. UT (Dvooory at Aoendiand
A1LA. SoMtten Utah Fwd Compnay. Sakna. UT CDtroaory at Acorauad
AllA. Standard Laboraiorra. Inc. Wkwnrari. KY (Dwratory of Am iifearaj Laboruonal.
--Coke--Imi mntatti AaaJjrxii
AJTM DJUMQ. Juadwtf Tal Mtlhodi far Froarania Aan)ym at ike Aaalyra Stefa <d Coni and Caka fa laairmaiul Fraeadarci (X I994X
--Corrocioa Lthibitors
AJTM 0111443. Standard Tra Meted far Ate Control e/ Lnpnt Cootaaa and Anamra (X ]H0X
--Dryiss OQi
f AJTM 0)13104. Standard Tra Mebod far Ate fa Dryma Otis and Fray Ae* <X 1W) (BM919X
--Csglac Caolaati
AJTM DIMM). SiukIuiI Tot Method far Ate Content at Pf--- Cooraia and Anorora (X 1190*
--Fabrics
AATCC 7101. Ate Content at Blmrted Ofelrar TcLOte.
--Fata
t AJTM D9S47-99. Standard Tra Meted far ffairiaiiiji.a at tb Ate Canted at Fia and O(fa.
--Fatty Adda
t AJTM Dmt-14. Standard Tra Meted far Ate a Dryma Otta and Fany Aenfa (X J113j (XM995V
--Craphlta
AJTM 04101. Standard Tra Meted far Ate a a Orapkita Saspic.
--Laboratories
AHA A !
AllA A Hafata In -Akron.
Akira. OH.
AllA A
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Item. OH.
AllA AJbta Crapornoon Qnaliiy
Conerfa Laternaon. f mrnhw^ TX
fara Sara Inc. Qrakry
I Labernaary. Ontario,
Ash Comer,-
i3n0i4s1-2r22i
30*1-227 2 SO t D-o
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3047-141 2302
20*7-Or 230) A*
20*7 .fal 2313 Oc
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La6eriorn
AlLA Oer^'
lw>ei oT .1
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f AlLA ONV TnarrC V/
AUA EMS--
taawf. SC
AllA Gem
KanoaaJ Lt`
^
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taUTM C
AllA 1C r
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2047-rJC 2313 94)
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2101-423 2760 a-n.
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00394111 2411 A-d
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f
Lator* tcr> AllA. Okc
mi Maters
ham. OH
AllA Hier
Caero* L* *
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Loespan
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All A Sta--^ faiiiei".
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--Laxter
ajtm c:t far Tata. (Anencxj
Stendars
f AJTM ZU
1far Lanot w ratwr
t AJTM 0-=*
far TouUmnar
JS31-or 4264 F-U
2101-00
2740 4-4
--OQ*
AJTM DA`* Innrent Total Lr?
1 9 rVtai ' aJTML'J : far Dor* at fra ,,
!7^rs 1)4* 911
2*71-0041 me c-oi >m-oo*2 1060 C-C2 2471-00*2 9060 C-Oi um*r* Xfa) D-!0 2471-0*72 1060 D-D
--ftprbo. *)Tu Dr Uo.: T*jfi r. to.
--h|m
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TAW1 T.
thm
tArr cMd E--
AllA ABad Stfnal Corponoon
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IteonnoryX HeprmSL VA AllA ABnd Sfanal Corporation Sparta.
Traacaaaa ^nu Qrakry Comrd 1 terrran], Spnra. TM. AllA I fa) pqfr'niin lac. fjckmonA, VA
AllA Anna Vahnih Mina. Xaratenry. IL fTkrim f at Aoondnad
All A
late
TX
A2UA
OH.
Buaaaj-MorHr. lac. Dayton.
OH (Dwcaory at Acrmiital
fatrai, LA Dr CV. Omoal
All, A Cfantara CBcmaenfa Compnny Lakaraaory Serrvsv Swnru. LA.
A! LA CenacranJ Tooa| A ; Co. Hraunfton. UT.
3471-OT* 1060 VCO
3*71-0*71 1060 *
3471-0*42 9CCJ A-3 2471-00*1 1060 -1-
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2471-41X2 1061 F-0*
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--Petroie'.
AJTM CIte Ak VII if
-Pitch ?
AJTM C fcn Alj^ mi.
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AJTM :
a a^.
no
UNITED STATES DEPARTMENT OF COMMERCE Maurice H. Stans. Secret ary NATIONAL BUREAU OF STANDARDS Lewis M. Bhanscomb. Director
An Index of U.S. Voluntary Engineering Standards
Covering those Standards. Specifications, Test Methods, and Recommended Practices Issued by National Standardization Organizations in the United States
William J. Slattery, Editor
Institute for Applied Technology National Bureau of Standards Washington, D.C. 20234
National Bureau of Standards Special Publication 329
Nit. Bur. Stand. <U_S.). Spec. PubL 329. 1.000 page* [Mar. 1971) CODEN: XNBSA
lulled March 1971
Exuisrr no.--
M. PFBFFgl
for **ie by the Stapwwmdwt U Docibwii. U-5. Cwvemmrai Pnotuif Oftct, W&ahiaxto*. D.C 20402 IOrder by SD r
Na. C 12.10-329\. Pric 19.00
National Bureau of Standards KW1C Index of Engineering Standards
Standard Dimenaiooi lor Graphic Arts Sheet Film (inch and Centimeter Sines) 0961)
ANS PHI.I6
ticni lot Film la Rolli lor Recording Initnimenu, Graphic Arts. Photo Typesetting. Portrait, X-Ray and Related Use (1
ANS PHI.30
OH Mentha Atyetuis (dementholixed (1962)
eoa 199
'fctlina. Aluminum Allov and Ccrttmoiy grilling Steel. A$A Pipe Flanges 119681
/ CotTOlWO-Resisyt StwL-Gnk nsa .3310 ,
Combinauoo Built-Up Kool Loomting ol Aiphalt Saturated Asbestos and Rag Felts and Asphalt Over haiuok Decxs-Smoo aRe XYZmT
->Ung Towen (1966)
Asbestos Cement Materials (or Applicauon On Industrial Wat
CTl 127
Standard Specification* lor Rubber Ringi lor Asbestos Cement Pipe (1966)
AST D1869
liuuliauon ol Asbestos Cement Water Pipe (1964)
AWW C603
Asbestos Cement Wster Pipe (1965)
AWW C400
Standard Specification and Tolerancej lor Woven Asbestos Goth (1967) ANS LOI4.I33
AST D1571
. .Standard Method ol Test lor Asbestos Content of Asbestos Textile Materials (1967) ANS L
J|J I '
Determining Asbestos Dust Concentration (1964)
AST D1918 ATI XY21
ure Molding (I960
Asbestos FeJting- B Slapc Phenolic Resm Impregnated. Low P
SAE 3858AMS
;c crete. Poured Gypsum/ Specificalion* for Asphalt-Saturated Asbestos Feils and Aspnait, Smooth Surface, Over Poured Con ARE XYZ14I
Precast Gypsum or 01 Specification* (or Asphalt-Saturaud Asbestos Fella and Asphalt, Smooth Surface. Over Wood Deck, ARE XYZI40
ons for Dead-Level Roofing Consisting of AsphaJt-Situriied Asbestos Feils and Special Asphalt Over Nailable Dechs-Smoo
ARE XYZI43
ooi lor Dead-Level Roofing Consisting ol Asphalt-Saturated Asbestos Felts and Special Asphalt Over Noo-Nailable Decks-
ARE XYZ144
I Standard Specifications lor Asphalt-Saturated and Coaled Asbestos Fells for Use In Constructing Built-Up Roofs (1963
AST D635
Built-Up R/ Standard Specifications lor Asphalt-Saturated Asbestos Felts for Use In Waterproofing and In Constructing
AST DI50
Tentative Method ol Sampling Asbestos Fiber for Testing (I967t)
AST D2590
f-Supporting St/ Method ol Test (or Chemical Resistance ol Asbestos Fiber Reinforced Thermosetting Resins Used In Sel
AST C6I9
, Fluorocarbon Resm (1961)
Asbestos Fiber Reinforced-Polytetrafluoroethyleise Sheet, Tf
SAE 3842A.MS
' Fluorocarbon Resin-High Compressibility (1962)
Asbestos Fiber Reinforeed-Poiytetrafhioroethyleoe Sheet. Tf
SAE 3843AMS
live Method ot Test lor Bauer-Mcnett Wet Classification of Asbestos Fiber (1967i)
Tema AST D2389
Testing Procedures for Chrysotik Asbestos Fibre (1966)
ATI XYZJ
Current-Carrying Capacities lor Asbestos itnniaieH Cooper Nickel and Monel Conductors (1948
NEM AIS
Standard Specification for Asbestos Lap (1968) ANS L14.232 Asbestos Paper and Asbestos Millboard (1937)
Asbestos Paper and Asbestos Millboard (1937)
AuuSsseTe
DI06I R19 R19
Standard Specifications for Cellular Asbestos Paper Thermal Insulation for Pipes (1965)
AST C298
Specifications for Saturated Asbestos Pipeline Felt (1969)
NPC BUL5
Standard Specifications for Asbestos Roving (1968) ANS LI4.230 Standard Methods of Testing Compressed Asbestos Sheet Packing (1939)
AST D375 AST F39
Standard Specification and Tolerances for Woven Asbestos Tape 11967) ANS LI4.2IS
AST D315
Standard Method ol Test lor Asbestos Content ol Asbestos Textile Materials (1967) aNS LOU.141
AST DI9IS
;968l ANS CI9.61
Specification lor Asbestos Textiles Used for Electrical Insulating Purposes (
AST Dll 00
Standard Method ol Test for Heat Aging ol Asbestos Textiles (1961)
AST D1573
Standard Specifications (or Asbestos Thermal Insulating and Finishing Cement (1964)
AST 0194
Standard Specification (or Amosite Asbestos Thermal Insulation for Pipes (1964) ANS 0011.2
AST 091
Standard Specifications lor Laminated Asbestos Thermal Insulation for Pipes (1965)
AST 099
Maintenance of Vinyl Asbestos Tile and Asphalt Tile Floors (1960)
AVA XYZ10
Color Charts for Vinyl Asbestos Tile and Asphalt THe (1966)
AVA XYZ13
Areas In Which One Sixteenth Inch Vinyl Asbestos THe Can Be Used (1965)
AVA XYZI4
Installation of Vinyl Asbestos THe Flooring and Asphalt THe Flooring (1964)
AVA XYZ3
Cleaners for Use On Asphalt and Vinyl Asbestos THe Floors (1960)
AVA XYZ5
Water Emulsion Floor Polish for Use On Asphalt or Vinyl Asbestos THe Floors (1964) Installation of Asphalt Tile and Vinyt Asbestos THe With Hardboard Underlayment (1961)
AVA XYZ6 AVa XYZ9
Waier Emu'non Type Adhesive lor Asphalt and Vinyl Asbestos THe (I960
AVA XYZ4
Standard Methods of Testing Asbestos Tubular Sleeving (1952) ANS L0W.4I
AST D628
Standard Method ol Test (or Magnetic Rating ol Asbestos Used for Electrical Purposes (1957) ANS C039J8
AST Dill*
Standard Specifications lor Asbestos Yams (1968) ANS L14.18
AST D299
Method ol Test lor Air PermeabHiry of Asbestos (1968t)
AST D2752
ic Insulated Wires and Cables (1961) NEM WcOl, ANS 0X58.3/ Asbestos, Asbestos-Varnished Goth and Asbestos-Thermopiasl IPC S-28-357
ic Insulated Wires and Cables (196}) ANS CSJ6 IPC S-28-3/ Asbestos, Asbestos-Varnished Cloth and Asbestos-Thermoplast NEM WC)
Asbestos-And Asbestos-Varsrshcd-Clotb-Insulated Wires (1963
UL 115
Standard Definitions of Terms Relating To Asbestos-Cement and Related Products (1967) ANS AI30.1
AST C460
Standard Specification for Asbestos-Cement FIberboard Insulating Panels (1967)
AST C351
d Clapboards (19/ Standard Methods of Sampling and Testing Asbestos-Cement Flat Sheets. Roofing and Siding Shingles An
AST C459
Standard Specifications lor Asbestos-Cement Noepressure Sewer Pipe (1967)
AST C42S
Standard Specifications (or Asbestos-Cement Perforated Underdrak Pipe (1967) ASH M189 AST C508
Plastic Lined Asbestos-Cement Pipe and Couplings for Sewers (1964)
NSF C7
Asbestos-Cemetu Pipe and Couplings (1967)
UL 107
Standard Methods of Testing Asbestos-Cement Pipe (1967)
AST C500
Standard Specification for 1 kings for Asbestos-Cement Pipe (1967)
AST C541
Standard Specifications for Asbestos-Cement Pressure Pipe (1967)
AST 096
Standard Method of Test for Organic Fiber Content of Asbestos-Cement Products (196) ANS A) 28.1
AST C458
Standard Specifications for Asbestos-Cement Roofing Shingles (1966) ANS A126.I
AST 022
Standard Soedficationa for Flat Asbestos-Cement Sheets (1967) ANS A124.1
AST 020
standard Specifications and Methods of Test for Corrupted Asbestos-Cement Sheets (1968) ANS AI25.1
AST 021
berkg Tests of Latex and Emui/ Standard Specification for Asbestos-Cement Shingle Blanks To Be Used As Panels In Weal AST D1911
Asbestos-Cement Shingles (1970)
ICB UBC32-9
tio/ Specification for Fourpoint Two loch Pitch Corrupted Asbestos-Cement Siding and Roofing Sheets and Their Appiica Standard Specifications (or Asbestos-Cement Siding (1966) ANS A127.1
ARE XYZ151 AST 023
Specifications lor Application of Asbestos-Cement Siding. Shingles, and Clapboards (1954)
ARE XYZ150
Selection of Asbestos-Cement Water Pipe (1964)
AWW' H2
Asbestos-Polytetiafluorocthyleoe Impregnated, Sintered (195
SAE 3840AMS
C1.36 IPC S-28-3/ Asbestos. Asbestos-Varnished Goth and Asbcsios-Thermopfcisiic Insulated Wires and Cables 119631 ANS NEM WC1
WeOI, ANS C00t.il Asbestos. Asbestos-Varnished Goth and AibesiovThermoplastic Insulated Wires and Cables (1963) NEM IPC S-28-357
ed Wires sod Cables (196J) NEM WcOl. ANS COOS.}/ Asbestos, Asbestos-Varanbed Qoth and Asbestos-Tbermoplasuc Insulat
IPC S-2S-3J7
ed Wires and Cables (1963) ANS CS.J6 IPC S-2S-3/ Asbestos. Asbestos-Varnished Goth and Asbestos-Thermoplastic Insulat
NEM WC1
U! 114________________ ______________________________ Asbestos-And Asbestos-Varnished-Cloth-Insulalal Wires (1963)_________________
Ascoroyl Paimitale (1963)
tga 95
Specifications for Ash and Hjcionr Handles for Track Tools (1962)
ARE XYZ107
Tentative Specification for Fly Ash and Other Pozzolans for Use With 1 ins* (19660
AST C593
Office of Engineering Standards Services
49
3tt-U O-LT - 11 - 5
d&"
AMERICAN EDUCATOR
/?ficjpcIo/jerfa
965
VZCL
CZ/rCC&f && G/
GZZ>&<Zt<y CGuy
rn it 'NiTiti
EVERErrr edgar sentman
Editor in Chief B.S.^ Uoivciotcp of llltooio; !)ni( l)., Loyola U., Antikao CooKiTttoiy; WliWr, Lccioicr; Aulbo*,
1\* 'mxyeUOmdim--J KfJ U //kAN TemeAinr
Loonumg
EDWIN C. REICHERT
Advisory Editor fk.D., Uoivcroiiy of Uiiiocioaj Quirnin, DcpulMal of Llucxio*, Lit fotctfl Colic|c
LARRY D. SAMPSON
Art Director B.FA-, Ohio 5*mu UMmWy
CROSBY J. LISKE
Production Director Cia^MU, Act ImUiuU of Qiidfo
ELIZABETH R. JOHNSON
Chief Associate Editor B.3., Si. A-Uooc College; Foe--lj Co cr.l U,
AmJ^iI, AkUu UbofiMw. rai--< UiciHiiMMl MiotfiW oJ QmmI Gupk
Associate Editors LUCY R, WALZ M.A., UiMrfi<jr of Ui(ki|iii
MARTHA E. CAREY B.A., Lake Foroal College
JOSEPHINE II. IIALPERIN BA., NMlkvului Uoimiilf
Assistant Editors BARBARA DAVIS B.A., UoimMir of Mitkipat MA. T-*re College, Cilai^n U.
ANN M KOLETSKY B.A., Miotuiuft0< Cotttfi of ika Sopol Hwi
NORTH A V. EDWARDS Picture Editor
B.A., Lake Fmji College
uirrn w. crecory
Chief Biblioi t'afhj Editor R.A., Uimui7 of Nck<uJU{ GrtduiU, U. of Wiecooaio lilxoif School; Ckiff LiWixuB, Wewkcgao (1U.) FukUo LiUwfi Ueabu, Luculin Bock). Aaoiaa titxwy
Aioociilioo (IMd-IMO)
VICTORIA S. JOHNSON
Director of Educational Research and Senates Special Stodiu, Noeihocilcio Unlvmil;, A--<rtce
CoaKTiilorfi AmIiukI Duccio*. 11m Oata|o
TtibuM MIimI* of Book*; Coluoaiii, Elnmsutory Em^UaJi
DONALD KIRCHNEJt
Assistant Art Director loatiluU of Dcaiga, Hliooi* loeiUutc of Tick--|y|
Ujtoo ScIm) of Ait
BESS PORTER ADAMS
Chief Grading Editor
M A., Univcrotir of RtdlixU; A--nr--Qo frok--x.
Depot meal of EoglieK, UairaiMr of BlJ^a <i.
Aulboe,
J4j oof Chitdnm
MARILYN ROBB TRIER.
World Topics Tear Book Editor
B.A., IJiivaiitf of Ckkifo; Ail JoetMaOe of Qmi lulilulr of {>M|a; Awlboe, 7krf tf+riU h 7--/
DEBORAH ULANKSITN
Director of Library Services
MA, No4(hr ium Upimiiif; Fotn^il) RckmcK Litxiiilo, U.3. Lilxorf of (xtn|itM
llll'f AlOIIS. INI*.. /*f f/F r V if t tr v
I * if tf
acturoM anioirtrah gwn.
jft rO fpeed, oWtvde, and
>d thoaU h down.
ry try blasting the enemy'* J ''-'ring attacks, diarupt-
and transport*bon iu troops, destroying hia
and Laying down imokt is, which are highly mo* ed on trucks, drawn by or he self-propelled, The .he United States Field mm. howitzer, which can ads daring its first hoar ran poor oat shells at a r brief periods {overtcst; too rapidly for too long rstroys artillery). Other >ona melude the 7&-nun. ity 76-mm. gun, 155-nun.
3-in, hovitxers and gun*, and the 280-mm. atom
The task of the eoett ect seaports- It does not :t like the field artillery, earier gun*. Its largest
njsu i UO
piece, th* lfi-ln. rifla, is permanently mplaoed. Other hserr pleoea, rueb as 10-, 13-, and 14-ln. gone and the 16-in, howiUer, may be either cm placed or mounted aa railway
run*. Smaller artillery alio Is used in coastal defenses, hut large-caliber, higb-veloeity pieces that throw hags tbslls for great dis tances art mors typical of coast artillery.
Antiaircraft Artillery, of rital importance
ia the air age, has reached a high state of development. See AKTLtmaurr Detthsk.
Naval Artillery. Naval vessels ose guns of many kinds, ranging from 40-mm. antiair
craft gun* to mighty lfi-in. rifiea. A battle-
ihip may carry as many aa ten 14- or 18-in.
?ona, besides a large number of smaller pieces. he iarger guns are mounted in heavily ar mored turrets, which are mechanically tamed in the desired direction. Naval vessels may also carry equipment for launching torpe does or depth enargea. See Darra Chame; N*vr; Totrroo.
History. The ose of artillery began early
in the fourteenth century. By the fifteenth century the typical gun was a huge, onwield ly weapon suited only to sieges. Aa extreme vs* reached in the guns Mohammed H used in the siege of Constantinople in 1453. Made
of brass, seventeen feet long, and weighing almost nineteen tons, they fired a stone ball 25 inches in diameter and weighing 600 pound*. Smaller, lighter guns appeared in the sixteenth century, and the gun carriage, on which the gun could be fired as well as drawn, was invented. The cannon ball of solid iron also tame into common use. With the iron cannon ball came the system of clas sifying guns as 8-pounders, 12-pounders, and ao on, according to the weight of the shot.
In the seventeenth century, Sweden's mili tary genius, Onatavus Adolphus, established a true field artillery -- one capable of main taining pace with the infantry and acting in its rapport. To attain the neeessarT mo bility, he used light guns mounted on norsedrasru carriages. He also speeded up the rate of fire by using doth cartridges of powder instead of the old method of measuring out
each charge of powder with a ladle. The outstanding artillerist of the eight
eenth century was the French general Jean Baptiste GribeauvaL Ha established sepa rate field, siege, and eoast artillery organizatiocs and provided different types of weapons for each. Hs standardized guns and carriages, making the parts of etch type in terchangeable.
Stronger guns, lighter for their caliber, came with the development of steel alloys and Improved methods of manufacture in the nineteenth century. Soon after the middle of the eentury the rifled gun, spirally grooved within its barrel, and the cylindrical projec tile came into ose. The cylindrical projectile.
presenting less turfaea to the air, eoulA at
tain a greater range than the cannon
Th* rifliog In the banal caused the projectile
to apln, preventing U from tumbling and over end in flight.
A problem that had vexed artillerists
ainca tha fourteenth eentury, that of pre
venting tha propellant gases from escaping
through an openabie breech (roar of the oar-
rtl), was finally solved, ana breech-loading
guns became practicable. Near the end of the
century, guamakar* began to equip gun car
riages with mechanisms consisting of by-
draolia braking devices and springe to ab
sorb the shock of recoil and return the gun
to its firing poaition. Previously recoil had
driven tha gun carriage backward, and it
was neceaaary for tha gunners to replace
the gun in pemtion after every shot. Smoke
less powder alio was invented. The improved
guna and ammunition made possible rangea
formerly believed to be unattainable. Longer
ranges created a demand for more efficient
aiming device*. To meet the need, telescopic
range finders were invented.
Urged on by two world wars, artillery has
made further great advances during the pres
ent century. Radar and other electronic aim
ing devices have greatly increased the apeed
and accuracy of artillery and have made it
effectively usable in fog and darkneaa. The
motorization of artillery has enabled it to
maintain pace with the rwiltest-moving
forces (in aircraft and tanks, indeed, it has
become part of the swiftest forces). It has made it possible alio to regard tueh gigan
tic weapons as the S5-ton atom gun aa field
artillery. The development of easily portable
light mortars, rocket launchers, ana reccfl-
ieu rifiea has placed artillery in the hands
of the infantry. Bee also AmruNmov; Bit
umen; Dmxcrtov Find**; Guncotton; OoNrowDEE; Ran**; 8kkatwxi,; Tank, Moitast; TNT._____
ARTIODACTYLA, air tA oi dak'tA lui,
the order of eloven-hoofed
to which
many of our common wild and domesticated
animals belong. Included in this large group
are swine, cattle, sheep, goats, deer, antelope,
eamela, giraffes, hippopotamuses, and re
lated forma.
ARYAN, itir'A aw. See Racks or Man.
ASBESTOS, the common name of a
number of kind* of remarkable rocks com
posed of fibers that will not bum, invaluable
for their uses in fireproofing and aa insula-
tioo. The kind of asbestos most widely used, eirytotUt, is found in eraeks in a rock called ttrprmtim, whets it has been formed by the
action of underground water or steam on
the reek. ChrysotOe occurs aa silky fibers
extending across the cracks; they range from
a fraction of an ineh to several inches in
length. The 1auger fibers may be separated,
A-370
ASCETIC
LONG, Sn-KY ASBESTOS F3SEXS may b* tpvn and wxrrm Into materials that will resist fir*, water,
chemical action, and decoy.
pan, and made into doth, (traps, cord*, ropem, and tobet. Several other kind* of as bestos may bo similarlt processed, hot tb fiber* of *ons* ut too brittle, wesi, or stiff
to bo spun. Uses. When Marco Polo, beck from hi*
travel* ia Asia, spoke of seeing handkerchief* that could be cleaned in * fire without burning, people listened in disbelief. Bat asbestos fabnes bad been known in Europe loaf before the thirteenth century. They were known to the ancient Homans, who used asbestos lamp wicks, napkins, and a doth in which bodies were wrapped before eremsUoo so as to keep their ashes separate from those of the fire. Charlemagne ia said to hare had on asbestos tablecloth that was cleaned in fire.
Asbestoa is now put to many uses. It is made into suits for fire fighters and into flares, aprons, and other clothing to pro tect workers in mills sad foundries. It is naed in the safety esertoin* of theaters, and, often mixed with other fibers, in fire-resistant draperies, upholstery fabrics, and run. As bestos is used also to make store ana lamp wieks, faakets, and packing for steam en gine*, and it ia employed to insulate and fireproof electric wires. Combined with strands of metal, it is naed in the brake linings and elnteh facing* of automobile*.
Asbestos fibers onredted to spinning are
owed in a variety of ways. They art felted, suoilariT to paper, for use ta heatproof nuts and pads roeh as those need in kitchens and dining rooms. They are mixed with other eubstsaee* to make fireproof plasterboard, flberfooord, roofing felt, thingles, and floor tiles. Finely ground, they are need ia fire proof points. Hogs quantities of asbestos are used as insulation to prevent the loas of beat from boiler*, water heater^ and steam and hot-water pipe*. Proof against all adds, asbestos is used in tad filters and in the walls and floors of laboratories.
Soarea*. About 75 per cent of the world'*
annual (apply of asbeatos is quarried is
Canada, cruefly in Quebec- Other leading
producers of asbestoa are Airies (Southern
Rhodesia, the Republic of Sooth Africa.
Swaziland), the Soviet Union, and the Unitea
States (Vermont and Arizona). See also
SxnrxwTm.
i.l*l x. wxixxs
AS'BUBT, Fuji exs (1745-1815), known
as the first bishop of the Methodist Episcopal
Church in America, was bom near Birming
ham, England. In 1771 John Wesley sent
Aobury to America as a Ttiisconiry; the oert
yeat be made him general superintendent of
the American organisation, a post which *
few months later Wesley assigned to Thomas
Rankin. When the Revolutionary War began,
Asbory'i colleague*, some of whom were
suspected of Loyalist sympathies, returned
to England, but he remained is the colonies.
Within a few years Asbunr became the rir-
tual head af American Methodism, and in
1784, at a conference in Baltimore, he tu
consecrated as superintendent. Thereafter be
called himself bisnop. Although not s great
preacher, Asbury was a forceful leader and
a master of organisation. Be advocated s
strong central church government and in
stituted the dreuit-rider system, which en
abled him to reaeh the frontier radons. Trav
eling on horseback, he covered some fire
thousand miles s year for fire years and
went as far as the Mississippi River. See also MjCTHOOfSTl; Wtaurr, John Wesley.
ABOI2?'8IOH DAT, one of the great fes
tival* in moat Christian churches, commem
orates the ascension of Christ into heaven,
forty days after His resurrection. It faU* a*
th% Thursday after tha fifth Sunday after
Easter. In the Anglican churches it is called
Holy Thursday,
ABGET10, a aet'ik, one who turns *wsy
from worldly pleasures in favor of thorn of
the spirit, for the purpose of attaining **!
or religious perfection. Various religiom
orders require their members to lead live* of
rigid self-denial, and many individual med
ics hare spent years in fasting and sobtirr
contemplation. Asceticism was widespread
in medieval Europe and has ahrsyt been
prominent among the Hindu of India. 1
the New World the Puritan* followed o**0*
principles in h*atng el] (vrnamenUtKm of
their riothea, their homes, and their ehBid**
and in forbidding all idle pleasures. Today
not only those who practice extreme ***
terjty for religious reasons but also tkeer
wwheo ccahloleodsealsicreaticso.f TehxtsraoorSdienaVrysyemptf5*?"
may be choosn for intellectual a* w*0 *
spiritual rewords, far sheer lore of dZ"P*f bring, and for the power of self-mss*?' Bee also Pain* or Aiama, Boarc; BUnt**1* Mom am one.
ASOH, 8houex as gnaun, Yiddish author wheet work* hi read in English translations, village near Warsaw, Pound, ik education in the Bebre* began to write after muring
28v9> and within a fewjo*n i familiar to reader* of Yiddish of the Atlantic. After the octb:
War I he went to the United
k_______ ______
shortly before his death. Asci short stories, most of which t with European Jew*, art drams : tad impressive in their tntheatk sfm (1939) ia a story of Jem other works available ia Eaglis. Oe Thief, TU God of Tnyec %oe Thr04 Cities, CkOdrr* of AbeakatU, and A Possoy* * ths ffifht.
A800BBIQ, * tkswr'bik, VmaczvB.
ABOARD, aXt'gokrd, in Hon
the abode of the godt, <omOtympon, home of the gods of ir.
Hera Odin, god of war, was eh: tbo was Valhalla, hall af he; battle. Bee also Onur; Vjujeuul^
ASH, the common name of
tira of the cJiTe family. The Pinnate (featherlike} eoopounc (mall, pointed leaflet*, and they
tot of tiny flowen before their Par. Their fruits are dry, cme-v W About twenty of the dzty rpeaee af tahes are aati* America. Largest and finest is th* whieh grows best in the Ohio V *. trow 120 feet tall and six feet L-
sped mens of this sire are rar "*owa, cloee-gnined wood is cz Wagh and springy. It is u*ed ( bt, akio, oars, tennis rackets *udl*, and alao for interior tr **binetm*king, The wood of the -
red ashes is timDarly used