Document evL9reZdVJ76OwNQLM3wkVGbm

IN THE CIRCUIIT COURT OF MOBILE COUNTY, ALABAMA ZEBEDEE YOUNG, Plaintiff, v. FARRELL LINES, INC., et al., Defendants. DEFENDANT COMBUSTION ENGINEERING, INC.'S RESPONSES TO THIRD PARTY PLAINTIFFS AND CROSS CLAIMANTS INTERROGATORIES. REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION PRELIMINARY STATEMENT AND GENERAL OBJECTIONS Defendant Combustion Engineering, Inc.*s responses to these Interrogatories, Requests for Production of Documents ("Document Requests") and Request for Admission each incorporate this Preliminary Statement and these General Objections. Combustion Engineering, Inc. began manufacturing asbestoscontaining insulation products on June 5, 1963 and discontinued the manufacture of all such products on August 30, 1972. As a result, its responses to these Interrogatories, Document Requests and Request for Admission respond within that time frame. To the extent that these Interrogatories, Document Requests and Request for Admission call for information, documents or admissions outside of that time frame, this Defendant objects on the grounds that they are overly broad, unduly burdensome, seek information neither relevant nor material to the subject matter of this case, and are not reasonably calculated to lead to the discovery of admissible evidence. Combustion Engineering, Inc. makes the following additional General Objections to each of these Interrogatories, Document Requests and Request for Admission: 1. This Defendant objects to these Interrogatories to the extent that they purport to require it to "identify" documents on the grounds that such requests to "identify" are overly broad, unduly burdensome and oppressive. 2. This Defendant objects to these Interrogatories, Document Requests and Request for Admission to the extent that information, documents or admissions subject to the attorney/client privilege and/or which constitute privileged attorney work product are sought. 3. This Defendant objects to the definitions provided with these Interrogatories, Document Requests and Request for Admission as being overly broad, unduly burdensome and calculated to harass this Defendant rather than lead to the discovery of admissible evidence. This Defendant asserts that all terms should be given their usual and ordinary interpretation. 4. This Defendant objects to those Interrogatories, Document Requests and Request for Admission that request information, documents or admissions regarding the ultimate sales or distribution of products ever manufactured by this Defendant, which sales did not occur in Alabama and that did not directly affect the sale or distribution of products in Alabama, and which may not lead to the discovery of admissible evidence regarding product shipments that may have been utilized at job sites where Plaintiff is claiming exposure, because information, documents or admissions sought regarding other sales or distribution of Combustion 2 Engineering, Inc.'s products are irrelevant and immaterial and not reasonably calculated to lead to the discovery of admissible evidence. 1. State your correct legal name and identify all subsidiaries, divisions, predecessors and/or successors which come within the meaning of Definition B above and for whom you will respond herein. RESPONSE: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that its correct legal name is Combustion Engineering, Inc. Furthermore, and without waiving this objection, this Defendant states that its asbestos-containing insulation products were manufactured, distributed and sold by a subsidiary, Refractory and Insulation Corporation, a Delaware Corporation, from June, 1963 until 1967, when the name of the subsidiary was changed to R&I Ramtite Corporation. On December 31, 1967, R&I Ramtite merged into Combustion Engineering, Inc., and the asbestos- containing insulation products were thereafter manufactured, distributed and sold by the C.E. Refractories division of Combustion Engineering, Inc. This Defendant does not have any predecessors as it understands that term. 2. State whether you have ever engaged in the marketing, manufacture, mining and/or sale of asbestos containing products, and if so, for each of your divisions, predecessors or affiliates, please provide the following informations (a) The trade name or brand name of each of those products which were mined, manufactured, marketed, and/or sold and the percentage and type of asbestos content; (b) The dates of supply and a description of the physical appearance of the named products, including its color, texture and dimensions and if there was any change in its physical appearance then provide the date of the change and state how it was changed ?' 3 RESPONSE; This Defendant manufactured, sold and distributed asbestos-containing insulation products. This Defendant did not mine asbestos. (a) See Exhibit A. (b) See Exhibit A for dates of supply. For the most part, this Defendant's asbestos-containing insulation products were white or off-white in color; also, see Exhibit A. The only substantive alteration to this Defendant's asbestos-containing insulation products was the deletion of asbestos from all of its manufactured products by August 30, 1972. 3. Were any of the products identified in response to the foregoing Interrogatories used or designed for use in ship construction, boiler insulation or repair, other vessel maintenance, construction or repair? If so, please provide the following additional information: (a) its use; Identify each such product and state, the dates of (b) Identify the shipyards or ship repair facilities to whom each such product was supplied; (c) Identify any Third-Party Plaintiffs, Defendants or other vessel owners or operators to whom each such product was directly supplied. RESPONSE: ' This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence as it is not limited to jobsites or time periods relevant to Plaintiff's employment and alleged exposure. Without waiving this objection, this Defendant states that actual use of its asbestos-containing insulation products varied according to industry practice. The products were generally intended to be used for thermal insulation. 4. Before releasing any asbestos containing products which you sold, manufactured, marketed or mined, were any tests conducted on them to determine potential health hazards involved in the use of the materials contained in those products? If so, please provide the results of such tests. 4 RESPONSE: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome, seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence, and it is improper as to form in that it assumes objectionable facts. Without waiving this objection, this Defendant states that to the best of its knowledge, no such tests were conducted. 5. Please describe fully and in detail the packaging of each asbestos containing product manufactured or sold by this Third Party Defendant or any entity mentioned in response to Interrogatory Number 1, and for each product, set forth in verbatim all wording on each product and the dates of any changes and the changes. RESPONSE: This Defendant has no records regarding packaging used other than Exhibit A which lists type of packaging used and names of products and Exhibit B which is a copy of the warning printed, stamped or stenciled on all the packaging of this Defendants asbestos-containing insulation products beginning in 1969. During the time that this Defendant manufactured asbestos-containing insulation products the warnings were not altered or changed in any manner. 6. You are requested to produce a drawing or photograph of all logos on said container or packaging and the dates of any changes and all changes for the foregoing products. RESPONSE: see Exhibit C which contains the only extant photograph of the asbestos-containing insulation products manufactured by this Defendant of which this Defendant is aware. 7. Do you contend that Plaintiff, Third Party Plaintiff, Cross-Claimant, other Third Party Defendants and/or Defendants improperly used your products? If so, please set out in detail In what respect those products were improperly used, RESPONSE: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this, case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this 5 objection, this Defendant states that it has not been determined that each Plaintiff, Third Party Plaintiff, cross-claimant, other Third Party Defendants and/or Defendants used asbestoscontaining insulation products manufactured by this Defendant* Discovery is ongoing. When discovery is completed, all proper contentions will be made. 8. On what date did you or your insurors first become aware that inhalation of asbestos fibers by human beings could cause adverse health consequences? Please describe fully and in detail the manner in which you acquired such knowledge. RESPONSE; This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome, seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence and also is improper as to form in that it assumes objectionable facts. Without waiving this objection, this Defendant states that it has no records or other information regarding how it first became aware of certain alleged potential health hazards associated with the use and/or fabrication of asbestos-containing products. Nonetheless, this Defendant had become aware of certain alleged potential health hazards associated with the use and/or fabrication of asbestoscontaining products by 1969 when it began to use warnings. 9. At any time have you or any entity mentioned in response to Interrogatory Number 1 placed any warning, caution or other statement on any asbestos containing product which you sold, distributed or manufactured, advising anyone of a potential health hazard associated with the use of said product? If so, please provide the following information for each such asbestos product: (a) The precise location of such statement or warning, including size and color? (b) The exact contents, including all changes or modifications ? (c) The dates of its appearance on each said product on which it was placed. RESPONSE: Yes. (a) The warnings were prominently displayed on the packaging. : 6 (b) See Exhibit B. During the time that this Defendant manufactured asbestos-containing insulation products the warnings were not altered or changed in any manner. (c) This Defendant began using the warnings in 1969 (exact date unknown) and continued to use them until the products no longer contained asbestos or were discontinued. 10. Identify all ship chandlers, shipyards, vessel operators, and marine contractors to which you sold or distributed asbestos or asbestos insulation materials at any time up to the present. RESPONSE: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence as it is not limited to jobsites or time periods relevant to Plaintiff's employment and alleged exposure. 11. Please state whether you ever provided a warning directly to the marine industry, steamship companies, seamen's unions, other unions, or shipyards, concerning the danger of exposure to asbestos fiber inhalation as a result of the use of your asbestos products. If so, please state for each such occasion: (a) The date(s) and content of each such warning; (b) The means of communication and identification of the persons providing the warning. RESPONSE: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, see response to Interrogatory No. 9. 12. Do you admit that exposure to asbestos dust by human beings is a health hazard? RESPONSE: This Defendant objects to the form of this request on the grounds that it improperly requires this Defendant to express an expert medical opinion 7 which this Defendant is not qualified to do. Therefore, this Defendant cannot admit or deny this request. 13. If you do not admit that exposure to asbestos dust is a health hazard, state the facts upon which you base your opinion. RESPONSE: See response to Request No. 12. 14. Please state whether this Third Party Defendant or anybody on behalf of this Third Party Defendant ever conducted or sponsored or contributed financially to any studies or research to determine if the inhalation of asbestos fibers may be harmful. If so, please identify the researcher and the results of said research. You are requested to produce documentation of the foregoing. RESPONSE: This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that to the best of its knowledge, its response is no. 15. Do you contend that while the Plaintiff worked in or around insulation products containing asbestos he/she was aware, or should have been aware that the inhalation of asbestos fibers was associated with pulmonary disease, injury or damage? If so, please state: (a) The specific manner in which you contend or believe he/she first became aware; (b) The specific source upon which you rely to support such belief or contention. RESPONSE: When discovery is completed, all proper contentions will be made. 16. Do you contend that Plaintiff, Defendants, Third Party Plaintiff, Cross-Claimant, and/or Third Party Defendants were aware or should have been aware of the dangers associated with the use of your products, and nevertheless proceeded unreasonably to make use of the product? If so, please state each and every fact and the source of same upon which you base this contention. 8 RESPONSE: - This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome and seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, this Defendant states that it has not been determined that each Plaintiff, Third Party Plaintiff, cross-claimant, other Third Party Defendants and/or Defendants used asbestos- containing insulation products manufactured by this Defendant. Discovery is ongoing. When discovery is completed, all proper contentions will be made. 17. Please identify any person you expect to call as an expert witness at the trial of this case and with respect to each, please state: (a) His specialty or field of expertise and a summary of his education, training and experience; (b) The subject matter on which the expert is expected to testify; and the substance of the facts and opinions upon which the expert is expected to testify; (c) A summary of the grounds for each such opinion; (d) Whether a written or oral report was rendered, and if so, designate which and state the date or dates of the report. You are requested to produce copies of each written report. (e) Whether this expert has testified on your behalf on any other occasion, and if so, the date, style of the case and court. responses Because discovery in this matter is ongoing, this Defendant is unable to identify its witnesses at this time, but will timely identify such witnesses and relevant information regarding their testimony and produce the requested documents prior to trial. 18. Please identify all witnesses (excluding experts listed in response to the foregoing interrogatory) you expect to call at trial of this case, and all other persons believed to be knowledgeable with respect to the allegations of your affirmative defenses. RESPONSE; Because discovery in this matter is ongoing, this Defendant is unable to identify its witnesses at 9 this time, but will timely identify such witnesses prior to trial. 19. You are requested to produce copies of all documents supplied to your experts, or other witnesses, which are used in preparing their opinions or other testimony. RESPONSE; See response to Interrogatory Nos. 17 and 18. 20. Do you contend that the United States of America, through its agents, servants or employees, contributed in any way to the injuries or illnesses complained of in Plaintiff's Complaint? If so, please provide each and every fact upon which you base this contention. RESPONSE; When discovery is completed, all proper contentions will be made. 21. Do you contend that Third Party Plaintiffs and/or Defendants through acts or omissions contributed to the injuries and illnesses complained of in the Plaintiffs' Complaint? If so, please state all facts upon which you base this contention. RESPONSE; When discovery is completed, all proper contentions will be made. 22. State the names, present employer and addresses of all individuals contributing information to the answers to these Interrogatories. RESPONSE; This Defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and violates the privileges accorded to attorney- client communications and to attorney work product. Moreover, in preparing these responses, reference has been made to responses prepared in the course of litigation pending over many years. These responses were based on conversations and document reviews occurring throughout this period. 23. Identify each physician, epidemiologist, or other expert that you have contacted or consulted with the intent to use such person as an expert witness or medical consultant. . 10 RESPONSE: This Defendant objects to this interrogatory on the grounds that it is vague, overly broad, unduly burdensome, seeks information which is neither relevant to the subject matter of this case nor reasonably calculated to lead to the discovery of admissible evidence and seeks protected attorney work product. AS TO OBJECTIONS: ATTORNEYS FOR COMBUSTION ENGINEERING, INC. Address of Said Attorneys: Post Office Drawer 1532 121 North State Street Jackson, Mississippi 39215-1532 OF COUNSEL: THOMAS, PRICE, ALSTON, JONES & DAVIS 121 North State Street Post Office Drawer 1532 Jackson, Mississippi 39215-1532 Telephone: (601) 948-6882 BETH McFADDEN ROUSE, ESQ. McFADDEN, LYON, WILLOUGHBY & ROUSE 718 Downtowner Boulevard Mobile, Alabama 36609 Telephone: (205) 342-9172 11 VERIFICATION STATE OF CONNECTICUT COUNTY OF HARTFORD ) ss: ) M. John Hornik, of Combustion Engineering, Inc., being first duly sworn, says that he is authorized to execute this affidavit on behalf of Combustion Engineering, Inc. and that the foregoing Responses of Defendant Combustion Engineering, Inc. to Inter rogatories, Request for Admissions and Request for Production by Third Party Plaintiffs and Cross Claimants are true based upon his information and belief. 300:777 (Al/Uhite) Notary Public SUSAN M. THOMPSON NOTARY PUBLIC My Commission Expires March 31,1993 12 INSULATING BLOCK EXHIBIT A C-E ESTIMATED START STOP PERCENT AND nn OF ASBESTOS CONTAINER (.) #12 Inaulatint Block (R) (a) #19 Inaulatint Block (R) (a) Griptex* Mineral Wool Block (It) (a) Kaiser H. Block (D) 1963 1963 1964 Unknown 1966 1966 1972 1971 6.2(A) 4.6(A) 2.0(0 2.0(C) Cardboard Carton Cardboard Careon Cardboard Carton Cardboard Carton INSULATING CEMENTS <a) Stic-tite* (R)-(D) 1963 8/30/72 (a) Super Stie-tite (R)-(D) (a) Super Finish Stie-tite (R) 1963 1963 8/30/72 6/27/72 (a) Super Finish (R) 8/10/65 1/10/68 Cm) Super 711 (D) 1964 6/27/72 (a) Kaiser Plastic Insulation (0) 1964 1971 ,*) Utility Thermal Finish Cement (D) 1964 2/28/72 Cm) Kaiser Hard Top (D) 1964 2/28/72 (a) Cesint Cement (D) 1964 1969 (a) MHD Finishing Cement (0) 1964 1968 (a) Pyroeeat* Fireproofint Cement (0) 1964 6/8/72 (a) Bilite Inaulatint Cement (D) 1964 1968 A-1199 Iosulitint Cement (R) 1963 1966 38.6-42.2(0 9.89-10.2(0 11.5-13.1(0 14.2(0 13.7(0 13.7(C) 5.0(0 5.0(C) 5.0(0 68.03(0 3.0(0 9.1(C) 43.4(0 50 lb. bail 50 lb. bi(i 50 lb. ba^a 40 lb. beta 50 lb. base 50 lb. bats 50 lb. bats 50 lb. beta 50 lb. bats 50 lb. bat* 50 lb. bate 50 lb. bate 50 lb. bate INSULATING REFRACTORIES Lit* Vat* 22 <W) Lit* w*e* 50 (u) PRODUCTS DISTRIBUTED BY C-E A*b**tO Sop* < Pr*i**al (fiber* in taulaion) Vaatharkota (fiber* in *ul*ion) (Tharmalkote tine* 1976) 1 Duriaaal (fiber* in taulaion) > Thermal Coat (fibtr* in aaulaion) 1 Air Chaek (fibrs in aul*ion) C-E START 1969 ESTIMATED STOP 6/26/72 1969 1972 PERCENT AND TYPE OF ASBESTOS CONTAINER 10.0(0/ 27.0(C) 50 lb. bag* 10.0(C) 50 lb. bag* 1964 1964 1963 1965 1974 1977 1964 1964 1963 1973 1964 1971 100.00(C) Approx. 3.0(C) Approx. 3.0(C) eitd 100 ft. 5 & 54 gal. ataal contain*;* 5, 30 & 55 gal. *tttl container* Approx. 3.0(C) Approx. 3.0(C) Approx. 3.0(C) 5, 30 6 55 gal. ataal container* 5, 30 & 55 gal. ataal container* 5, 30 6 55 gal. ataal container* CXI: .anidi i c 86\3DUSTRJAL IftJSULATIOSMs t TECHNICAL DATA REFRACTORIES A DIVISION Of COMSUSTION CNCJNCtHING. INC. ir- 'ii * REFRACTORIES a division e# eoMust)ON cNcNtt*iNC. me. ASBESTOS POPE " " *%* WO* RO IS A COMMERCIAL CRAOE. WHITE CHRYSOTILE ASBESTOS FIBER. 1000* ROFE IS A PURE 98/100* WHITE CHRYSOTILE ASBESTOS f lER. APPLICATIONS OF C-E ASBESTOS ROPE . . HERE ARE SOME OF THE MANY SERVICES STEEL MILLS AND FOUNDRIES Ui for C-E Asbestos Ropt are almost endless. Sealing molds. vacuum-pouring equipment (where leakage cm win an tntirt billet), sand molds ff from pouting ladles, diking Joints In Urge corn which must be segmented. ATOMIC ENERGY ' ' 1000* is standard in the Industry because it withstands an Integrated neutron flux of 10,% nYv units. MARINE SERVICE . C-E Asbestos Rope is essential in the Engine Room for general boiler servlet such ts calking, filling and expansion joints, mapping hard-to-reach steam lines and in emergencies, for quick repair of damaged su*m lines. GENERAL INDUSTRY j Anywhere heat sealing is required, whether heat-treating furnaces, boilers or processing operations. POWER PLANTS * Between boiler walls and brick-work to allow for expansion and contraction, wrapping steam and exhaust lines where space limitations preclude formed insulation, covering small ducts, calking hard-to-reach spaces. Insulating hot pipes passing through fire-walls and bulkheads. It b the standard for use in grooves for door sealing, between boiler sections, expansion joints and in handling hot gases. ASBESTOS ROPE CAN HANOLE EFFICIENTLY ANO ECONOMICALLY CHEMICAL INDUSTRIES C-E 1000* rope is successfully used es calking rope tor bell end spigot Joints in chemical lines. Because it contains no organic components, it is used es yarning rope for water tines. In addition to Its heat-resistance, the chemically inert characteristics have made h a 'standard*' in other chemical-handling operations such t pecking for carboy-stoppers, and in Cryogenic services, and other applications where this property Is required. ALUMINUM PLANTS Anywhere the control of heat and waling is needed-heat-treating ovens, grooves for door sealing, pouring ladles, veuum seals on crucibles, and in many othar dry heat-waling sppticationt, C-E Rope b recommended. REFRACTORIES division or eoMusTiOH (Msmctume. twc. firfetax* b a major developmant 1ft inaulatiofl fleeing a Uft*Qy combi***0" f eharacur'nc*. Special mirwil combined with high temperature bonding materials, provide practical drftty. Th# mboiMd herd finish jrtef orovide* auperior handling strength ard sttongar adhesion of mant flexibility m* high sl/ength make impaling over wdded pins taey, witho/t y!L eom^A*t!drt * "**>.Th* T** ** Gripttx Stock assueas against corrosive action. This particularly k Irnportaot whi tad tOftjwnetiofi wish aluminum Jacketing. ** * * / ' Hydraulic setting eemtnts and castable refractories may be applied directly to Oript** 81ock without premature te of mixing water needed for proper hydration. EFFICIENT Tht felted fiber core of Griptex Block offers the maximum buffering eetioft ageinst heat penetration up to 1B00V. The thermal conductivity at 200*F. meant temperature k 37 8TU; at B00*F. h b .49 6TU. APPLICATION METHODS . Griptex may be simply impaled over itandtrd welded pins end secured with speed dips or mey be secured in place with metet bends. A sharp knife k the only tool needed to fabricate Griptex to fit irregular shaped equipment Simply press over bolt heads and projections without additional cutting. Outdoor applications dtould be weatherproofed. ' RECOMMENDED USES BOILERS Drums Headers Walls Economizers Air Preheaters FURNACES Heating Heat Treating Forging Annealing Normalising . OVENS, KILNS A DRYERS FIREPROOFING TANKS & VESSELS TURBINES & PUMPS FAN HOUSING DUCTS & BREECHINGS SPECIFICATION REFERENCES High Temperature mineral fiber block insulation shall be GRIPTEX complying with the performance requirements of ASTM C39?, Class 2; Federal Specification HH* 1*564 and/or Commercial Standard CS-117 .of the U. S. Department of Commerce. A C* uad* name. ljW.*3S0 : --------- S10660-4437  ,0 A Vtl<P* or COM9UST10* CMOINCCKIMO. INC. SUPER FINISH STIC-TITE A SMOOTH, ONE-COAT PLASTIC FINISH INSULATION Super Finbh Stie-Titt provide* a vnoorh. hard, fibrous finish cowing (or {mutating blankets, Wort, Sik-Tiu and other insulations. It b dry. finely ground, pure whits mixture of high quality miners* ^ diatomaceous earth which, whan mixed with th* proper amount of water, b ready for Instant use. Uk stared StiC'Tht. h forms a spongy mau of dead air cells which stops air innitration and resultant heat Ion. NO ROUGHING COAT-FINISHES SMOOTH Super Finish St*>Tit b applied in a single coat. It un be troweled eery smooth for pleasing white appearance. No roughing coat is needed, thereby saving materials and labor, (t does not rfsr'mk or crack. There b no pointing up or patching neeessary after Super Fmidi Stlc TItt has dried. USE SUPER FINISH STIC-TITE WHEN a perfectly smoor/t, c*i*<ee/ plastic finish insulation is eptcificd for temperatures up to 1700*F. . WHEN neeessary to cover blankets, block or standard Stlc-Tite In order to provide a smooth, hard, white surface. . DOESN'T COME OFF ^ ,i Super Finish Stie-Tita adheres strongly to overhead, vertical and eurvod surfaces and rounded comers. Once it has dried, the bond is unaffected by vibretion. Impact or moisture. . CAN BE APPLIED ON COLD OR HOT SURFACES . Because it doesn't shrink during drying. Super Finish Stie-Tite can be applied directly re cold or hot metal or brick surfaces up to I7$*F. It dries hard, without shrinking, in about 2 hours. When applied to hotter surfaces, a rough coat of standard Stic*Tu b recommended. * GOES A LONG WAY * . Super Finish Stic-The gives excellent coverage. One hundred pounds cover an 80 sq. ft surface with a 1/2** thick layer; 130 sq* h. with a 3/8" thick layer; or t$0 sq* ft. with a 1/4" thick layer. This b by far the lowest cost coverage of any other one-caat finish insulation available. HOW TO APPLY SUPER FINISH STIC-TITE 1. MU Super Finish Stie-Titt thoroughly with 5 to 6 gats, fresh water per 2S lb. bag. 2. Allow the cement mix to soak for one-half hour before using to aneure maximum workability. * X Mix no more than will be applied in 4 hours. 4. If any of the batch has dried out. do not remix it with water or fretfi, dry material as the resultant finish will not be hard. Use only fredt batches. 5. For smoothest finish, vowel the cement to at least 3/8" thickness* . Where used as a finbh coat over an insulating cement roughing coat, be cure the undercoat has set Overnight before applying Super Finish SticTitt. 7. Where a given area cannot be finished in a continuous application, the Joints should be feather-edged *,.-*C'.ReWlACTOfUESrA 0IV4S10N- C, H vyatejivA'CirfiyCBtig:; t SUMMARY OF PHYSICAL PROPERTIES Us* Limit Strutting Temperature Thermal Conductivity Compressive Strength Ocnilty Stability Resistance to Moisture Resistance to Corrosion Handling Characteristic* Up to 1800*F. 2100*F. Sot Accompanying Graph 18 pet 1.25 IbiTbd. ft. Inert durable Water-repellent Non-corrosive Excellent THERMAL conductivity-giiftex ItOCK STANDARD SIZES 6"* 12** e-*ir* 6"*36*^ - - ir*air iriir 12*'x24" 12*W ir*2424-X36** thicknesses range from 1** to 4**--in 1/2" increment*. TEAR TAPE CARTON Griptes block h packaged in tht new . . . easy open ... Ur tape carton. This eesy open carton simply tips in half, forming two convenient container* ... less waste ... less damage ,.. less lost tone. Cu>- REFRAET0R3ES A IVt*N 0 eOMtUSTlON CNCtNKCIHC. IMC. nnjc^^tT:r SUPER 711 INSULATING CEMENT ' SUPER 711 Isolating Cement (s mixture of h*h %*mp*r$tun mineral f*** *p#ciy processed Into resilient wool nodules. combing with asbestos and uitabie binder* to form a high imp***** pltic Inflation. Wtar added according to direction* give* a trowtlable consistenQy that It ready for application on equipment to b* operated at tanpamtufts up to 1800*F. . WIDE USAGE SUPER 711 U a versatile material for many typts of inmjlatiofl requirements. Applied over block or blanket Insulations, It fill* open Joint* and provide* monolithic surface for whatever type of mzbseouent finish is specified. Its ptaitk flexibility permits application directly to regular or curved aurfaees - such as valves. fittings, tank* and vassals. EASY TO APPLY SUPER 711 has excellent adhesive Qualities. Its increased stickability means a better Job in less time, from wet to dry. Will not slip or roil under trowel application and may be easily gun applied. This euperior workability is a result of fine mineral nodules, special manufacturing methods and quality control. . MAXIMUM COVERAGE LOW SHRINKAGE .. SUPER 711 Insulating Cement tsmirts maximum coverage and tow shrinkage. The resilient nodules of mineral fiber do not collapse when mixed with water. See table of Physical Properties for coverage. RECOMMENDED USES BOILERS . Drums * Headers Walls Economizers Air Preheaters OVENS, KILNS A ORYERS VALVES & FITTINGS TANKS A VESSELS FURNACES Huting Hut Treating Forging Anr*s!tng Normalizing TURBINES A PUMPS FAN HOUSINGS DUCTS A BREECHINGS SPECIFICATION REFERENCES SUPER 711 Mineral Fiber Insulating Cement conforms to ASTM 0*195-48; Federal Specification HH-C-163 (Oat* Cl; and/or Commercial Standard CS-117 of the U. S. Department of Commerce. PHYSICAL PROPERTIES OF SUPER 711 INSULATING CEMENT Service Temperature Watt* Ratio Ory Centrage Materia) Requirements Compressive Strength Oenefty (Applied end Dried) Shrinkage (Wet to Dry, by Volume) Thermal Conductivity ftedafanabtc to AdKion to Steel (Wet) Adhaeion to Steel (Ory) Corrosion Resistance to Steel Shipping Container* (Sewn Closure) 1800`f. 12 gels, per 50 lbs. beg 60 *. ft 1" thick per 100 lb*. 2 lb*, per aq. ft. 1** Vtkk 4$ ps) 24 the. per cubic foot 1S% SeeChrt 1000*F. 6 (Hi psi Non-corrosive 50 lb. paper beg* Tabulated values represent typical performance levels of SUPER 711 Insulating Cement Trowel Grade. SUPER 711 Grads Cement consists of the same basic materials that smaller mineral woo) nodules are utilized to facilitate application. THERMAL CONDUCTIVITY - (BTO in . / e q . f t . / F . / h r . ) 200 400 600 800 1000 1200 wo KEAN TEMPERATURE t. I A OIVttlOM or COMOUtTiON CHOI Nil A INC, INC. ^^UTIUTY THERMAL FINISH CEMENT UUiry Thermal FMtfi Cvnt H composed of high quality mineral fiber, hydraufie binders, end other suitable sneterisli. UtBIty combines On flexibility, high temperature reiistence, arid cxeetioftt insulating qualities uniformly nodulated -mineral Tiber with the strength, low shrinkage, and smooth firwdi of hydraulic setting cement. The mult Is a Quiek setting, smooth finish, thermal resistant, single layer Moulding finish cement. For temperatures up to l?00*F. QUICK SETTING Utility Insulating Finish Cement d^eJops a smooth, durable, protective finish within a few hours eh#r application and without the pretence of heat. Subsequent drying produces no excessive surface cracking $r shrinkage in thickness, and occasional wetting does no damage after hydraulic eet Long drying periods under normal conditions are eliminated. Saves time in applying weatherproofing paint, or ether finish^. Jobs are easier to schedule; scaffolding costs are reduced. ONE COAT APPLICATION Utility b normally applied m a single layer applieetion. A second layer ts needed only when multiple layer thicknesses are specified. Utility is virtually an all-purpose Insulating finish cement, designed primarily for use over Griptcx block or blanket insulstions. Utility Is widely used for insulating valves, fittings, heated equipment, and as an anti-sweat insulation for cold water tanks, pumps, etc. Utility trowels with a good key on block Insulation, blanket Insulation and Insulating cement. It has good wet adhesion to elean steel surfaces, such as valves and fittings. PLEASING* APPEARANCE .- Utility dries to a pnooth, light reflectant surface which as an Interior finish, requires no further Vestment. Utility, bmvrver, b easily painted If desired. Outdoor applications should be weather protected. Low temperature applications require a vapor sea! type fintds. ' EXCELLENT THERMAL QUALITIES Utility has a "K" factor of .79 at 60Q*F, mean temperature. This excellent insulating value as compared to ether finish cements H every desirable edvantage when figuring job and operating eosts. PHYSICAL PROPERTIES Service Temperature Watn Patio (Trowel Application) Dry Coverage (Trowel Application) Setting Time Material Requirements (Trowel Application) Compressive Strength (Air Cured) Compressive Strength ( 1200*fJ Density (Applied and Dried) Shrinkage (Wet to Dry) "A" Factor at S00*F. Mean Temperature Corrosion Resistance to Steel Surface Treatment Shipping Containers (Sewn Qoerrt MIXING - 1200*F. 7 gals, per SO lb. bag 37 sq. h. 1/2" thick per 50 lb. bag 2 to 4 hours average conditions. . U tbs. per Q. ft. 1/2" thick. 135 pti. 105 psi. 35 lbs. per cubic foot. Negligible. .79 Btu. Non-corrosive. Easily painted or weatherproofed when required. 50 lbs. paper bag. Utility Thermal Fini* Cement should be mixed in e clean mortar box or mixer, using approximately 7 geilons of water per 59 lbs. bag for a good troweling consistency over most Mocks, blankets, or insulating cements. Because of the hydraulic binder. Utility should not be mixed with water more than two hours in advance of Its application. With cold mixing water (below 50 FJ It remains workable up to 4 hr*. STORAGE . Store in e coot, dry location until ready to use. REFRACTORIES A DIVISION or COU*TlOWTNGlNt*(N, INC. Basically there w three type* of asphalt mastics used In the Insulation (Md. They art wmrtfJy danifierf K mutton, aokrant cutback, or chemical dispersion type*. The thinning agent or dkpersion chemical determines which bask classification win b given $ particular product, and dictates tha and use of the resuftam produet. It k important to know which thinning agent k used to determine tha useful qualities of a particularly blended asphalt mastic. Tha quality and/or type of bask asphalt datarminas ft* service lempertttft of tha product involved. WATER EMULSION ASPHALT MASTICS Tha watar emulsion type of asphalt weather coating auch as Thermal Coat, k normally a bland of petroleum asphalt, asbestos fiber and Bentonite day. emulsified in water. . Water emulsions art primarily used as a breathing mettle, La^ tt auftabla pressure k built up beneath itx surface, moisture peasant will pass trough to the etmosph*#. However, atmospheric precaurt k normally not sufficient to pat* moistura back through to the insulation, except, of course, on low tamparatury work! In this case, a vapor barrier type mastic such as Ourisaal h essential. . Summer grade water emulsions, becuate of the watar present, wftt freeze and should be protected at all times prior to and during application. Alcohol is usually added to Winter grade emulsions. Tha amount used determines the resistance to freezing of the resultant product. Watar emuWorn dsoutd always be stored and used at temperatures above freezing in any event A watar emulsion diet has bean frozen k useless and wilt "alligator** if appliad. Watar emulsions uxuslly are suitable only for trowel application and are used wherever a breathing mastic k required. Because they lack tKe adhesive Qualities and resiliency of a outbade type mastic, they rftould be mechanically bonded to poultry netting except on extremely small surfaces* They should be used in conjunction with a cutback or dispersion type flashing compound. Water emulsions can only be repaired with such types of mastics since they do not bond to themselves, tt h imperative that they be repaired as soon as possible if a break in tht applied surface should occur to insure anics Ufa of tha product. % * Thermal Cost may be applied at temperatures up to 200#F. and wilt withstand a maximum temperature of 45C*F. after drying. . CAUTION: Water emulsions are soluble in water and should not be appliad if there b a possibility of rain washing the product within twelve hours of the initial application time. Keep Winter Grade abort 20 F. CHEMICAL DISPERSION TYPE ASPHALT MASTICS . ` Chemical dispersion type asphalt mastics, such as PERMISEAL, incorporate a unique combination of the desirable qualities of the watar emulsion and cutback types. They normally^ consist of petroleum asphalt dispersed in a non-flammable chemical with suitable fillers, blended m one consistency tillable for brvdt, trowel or spray applications. Containing non-flammable solvents, they are fire-sale for use around open flame, welding torches and similar hazardous job conditions. They have the breathing characteristic of a watar emulsion for a period of sixty to ninety days after application. This controlled curing process prevents shrinkage of the airface film and permits trapped moisture to eseape. The result k a flexible, blister free, vapor teal type coating of exccptioAaf toughness. A good chemical dispersion product is net affected by freezing and mists most Kids and alkalies. However, solubility in water is a factor, depending upon humidity conditions, for a period of eight to twelve hours or longer after applkatkn. The anodiiing and rust inhibiting agents contained in PERMISEAL make this product excellent for metal protection purposes. PERMISEAL has a useful service temperature up to 30Q*F. and a maximum of 40G*F. CAUTION: Okpersion Type mastics should be treated the same as water emulsion types, in that they should not be applied if there b a danger of rain washing within eight to twelve hours of tha application time. Under proper temperature and humidity conditions. PERMISEAL will be dry to touch in four hours or Ian. CLASSIFICATION AppTcatiP* UathPd IAaiMW TawparatM# A)limi>fi Tamparatwra CMnifFit Ti+mtt i Flash CMl irv* r Spray C*at PtinFawwmawt whan raqwitap GMr* Utt Atftav** Strangth Caring for int Anurtt Pirn* Aavttanc* frtaat Fmuntt Crwiaw flttrsiarica Vipo ftttiuanct Fck*ad Shipping Weight WEATHER COATINGS AND SEALERS WATEft EMULSION_________'___________ CHEMICAL 01SMASJC* THERMAL COAT KAMlSfAL Trawal 440 *. 40V. tp sooV. MM.M/l'Aid/N. S4.ft^ 1/t" xhick/gd. 1/4" thick nt Trpnaf pniy ' Fawirr hatting Sraathar yp* <ttar coating Shoaitf b bohdrt to poultry mr!a| A*o*4 IP* tamptralwra and high humidify condition* Non-<i*mmbt* Ptatact from fnming Not inhibited W.u b/Mtht $ Cal. SO Car. Staal Container SS Ids. SS0 tb. |<vF>Tnwl Iru 44fl0V 40 *.*900V. 10cp.1t, \Hm tNidt/gal. 10 . (1,1/1** Ftkk/fF. 70 4- <wint- thich/gai. 1/4" chick m rvdt or Spray two 1/1* *k* mi mu ihAfarcai rop'd. Suhapit fabric IVaathar coating and cmU* fpr lnwtatiort.ma0nrY itaai.aUnn. Ccciflanf ftr curing pa clean Pry wKm Avoid few tamparctura and high (tumidity condition* Mondlammoblt Not iKmM inhfeitad cga'fAM vc* Wcorrode* WiU braatha during 7-0 montfi curing period, than b*toma wpor a**l 1 |p, Mtf 14 gal. Ipintk finer) mat centaWr ASIbc 4IOki. "M REFRACTORIES J A Yl*lOH P COM9USTION CNCINCCRIM6, INC. OURISEAt f*OTECTIVE COATINGS Type T078. T-278 Ourteal Frotecti* Coatings are special bind, of mastics, wnb^J J*** wJT prrwide an " *"' ApptW ONtr masonry f^L^^Igbn^ 0u7X f**esiftat air-tight fiCm that H impervious to water expose. ***** tn** <** SCoTatSm TalsloSififcupsedtninlcnonfj,u.nctio. n. wcitihtinOgatrcicokmThpeerml.al Coatfowrhetroe- >* l~W * t*pqru*.lr.*md corrosion. STANDARO TEMPERATURE GRADES (To 400 F) - For surface temperatures that will not b operated m excess of 35CM00*F the Standard Grades art recommended. Standard Type 7078 is made to a semi-viscous, troweling consistency. HIGH TEMPERATURE GRACES (To 700 F) When surface temperatures will exceed 400*F during operation, but not tn excess of 7X*F. Ouriseal High Temptratury Coatings should be used. EASY TO APPLY OwriseaJ Coatings may be applied over any coot, clean, dry surface, using suitable membrane between spray coats and for patching purposes. Where used, membrane should be fepped 4** at all joints or around patch applications. For ease of application, the best workable temperature range h 60*F to 10Q*F Storage temperature should not exceed 10Q*F.0urisel Protective Coatings require no thinning. . COVERAGE Material requirements are estimated on wet coverage of approximately 5 to 6 square feet (1/4" thick) per gallon. ' CONTAINERS Ourtseaf Protective Coatings art dipped in 5 or 55 gallon steel containers. CAUTION: Surface during application should be above 100*F for indoor applications or 130*F for outdoor applications. Provide adequate ventilation and do not apply in vicinity of open flame, welding arcs, etc. C . .A^'E.REFRACTORtES -.A DIVISION4 Or COMBUSTION E NGlN 6 ER|NG^JNCj. * *V>'f2:.>Xt^r^,VALLEY'FbR`GE: *9gN NSYLVAN IA'1946\ \\+ >jraA&A*? ^ *- S10-6604&37 .S\ t&atlSREFRACTGRIES A OtVKJOM Of COMSUtTlON INGHJCC*IN, INC. FOR FIREFROOFING STRUCTURAL STEEL Pyroieat k a apecUt formulation of high-tamperaturc aggregates, asbestot fiber*. hydraulic binder vd ether miUriah. These ingredient* art factory biendad to a uniform dry mixture that k ready for application after mixing with water at tha Job site. Fyroaut k adapted to application by graying, casting and trowelling techniques, depending on job condition*. USES: Pyroscat provides a lightweight, firwetardent protaetiv* traatmant for Structural statl columns, beams, tower drirts, IP gat tanks, ard other exposed applications In refineries and chemical plant*. Pryscat set: up to a hard, durable sheath capable of withstanding for hours the 3000*F. flame temperatures and high-pressure water streams commonly encountered In Industrial fires. RECOMMENDED THICKNESSES: Fire-retardent materials ere customarily rated in Hours, based on a given thickness wsad and on the method of application. For example, fire ratings for steel columns represent tha number of hours required for heat from a ''standard fire" to penatrata tha protective treatment ts applied, and to increase the steel column temperature to a critical leva! (1200*FJ Tha thermal conductivity and hast capacity of a matarial are of some import*net In an ASTM Fir* Test. But the ability of the complete treatment to withstand thermal shock without destruction k one of the most significant factors In determining practical fire ratings in industrial installations. The Pyroscat thicknesses recommended below were determined by physical tests on a aeries of sprayed, cast and trowelled applications. Tests included direct exposure to tOO pa! hose pressure, boih before end aher subjecting the Pyroscat treatment to severe flame conditions. THICKNESS OF PYROSCAT '_3M APPRO*. FIRE RESISTANCE RATING 2 Hour* 43 HHoouurr.. WUR-3SMI ADVANTAGES OF PYROSCAT SAFER WHILE FIGHTING FIRES ... Many concrete eggregatn end common bricks used for fireproofing purposes will spall and shatter when they are heated end subjected to hose streem. Pryoicat remains virtually unaffected after direct flame* exposure end saturation with e 300 psi hose stream. LIGHTER WEIGHT . . . Pyroscat weighs loss than $5 IbsVcu. ft In place, compered to approximately 150 IbsJcu. ft. for conventional concrete fireproofing. Exeess dead weight is eliminated. As usually sprayed or trowelled in a protective sheath, Pyroscat weights about 1/10 as much as formed concrete at equivalent thickness per running foot. *A C-E trade name. ... OE REFRACTOfllESrA OIVlSION OF,.COM8UST.ipN-ENCINE6RING, INC.;-,;. W, ft-r;V*.-^5w^*VALL^FORGC'P^NSYLVANIA.l948iy`rf7ri^**.S.*:.^^i?bVTWX SlQ-g60-4837 - . ,1: A ADVANTAGES OF PYROSCAT (Continued) SPRAY, CAST OR TROWEL . . * Pyrotcet Is specially formulated to permit installation by trwt nd casting ttebol&H, depending a local job conditions. No tf*r (reproofing material U vtrwt.U from an application atindpoint. Employs conventional eupporiing materials end pJacemint. Only tfi o fireproofing material t* required * no need lor subsequent finishing layer* nor heavy monk coatings. DURABLE ANO WEATHER-RESISTANT . . , Pyrotcet develops great ttnngth from Its selected high-tempe/etur# aggregates and hydraulic-setting binder*. It with*t*sds continued cycles f saturated fnioieend-thaw weathering tests. SUMMARY OF PHYSICAL PROPERTIES Coverage (Trowelled) Material Required (Trowel Application) Air-Cured Weight (After Hydration and Drying) Compressive Strength - Air-Cured Compressive Strength After Firing at 1$00*F. 1.1 cu. fUSO lb. beg 45 lbs. per cu. ft 54.5 lbs. per cu. It. 16S0 psi 1.5V Lintel Shrinkage * Air Cured . Lineal Shrinkage After Firing at 1500*F. Density After Firing at 1500*f, Fusion Temperature Thermal Conductivity (k) at 1000*F..Mesn Temp. Setting Time Mixing Water: Leo then IV 1.SV 39.1 lbs. per cu. ft. 2200 F 1.50 Bui 4 to 6 hours For Spray & Trowel Consistency For Casting Consistency 3-1/2 Gel. water/50 lbs. beg 5 Gel. water/50 tbs. beg Curing: Pyroscat U a cementitious material and should be kept moist during the curing period of 72 hours or longer. ' $4<? TET Va i **%+*+ REFRACTORIES A DIVISION O' COMSUCTIOM CNClHCtRINC. INC. BOILER WALL COATING CEMENT ELIMINATES AIR INFILTRATION PREVENTS HEAT LEAKAGE SAVES FUEL INCREASES BOILER EFFICIENCY j Air-Check Cement H an asphaltic-asbestos fibre mfcrturt in plastic form for covering the outside of both fire bride and red brick boiler walls. It it also used for pointing up crack* in boiler walls. Its ufe, effective limit of usefulness is 350*F. Air-Chack Cement a tough, rubbery, plank, easy to apply. A 3/16" thick coat troweled over the surface,' dries to a thickness of slightly more than 1/8". It remains semi-plastic even though in service for a number of years. ..j'cE REF RACTOKIES A 01V^lO^F .Q^TuVruS'^^i^^2 kauui ureses A DtVttlON o* COMIUITlON CNQIHCCAtMd. HC. Alt PURPOSE PLASTIC INSULATION wS__atktae-rT., treli.g. h. at nodnStfutepe|rebS.tftchTe. iyiea..dp.h_lae_sr_etic.toinsa_ un_ lyatd_ioei_na_sn_a_sr_ut rt<fha_e_ctm-e_on_fdtvM..e.r7saot.il*e-eint. sot>(at. tt.ienmg_p_me_r_aat.teurriaefset.okn_1o_8w_0n0..*FM. .iuTehef yywnin, light, strong nd unusually durable. *. ^ to* Stie Thts or* a powerful barrier against Mat loss. Composed of special mtxhjr* of minor* *ooI and *Utomettis earth. the applied end dried material forms a spongy man of billions of desd afr cetts. uniform in k* and well isolated from each other. This stops air infiltration and roultant hoot iraronkuofl. HOW TO SELECT THE RIGHT THICKNESS ' Estimate the oporsting temperate* of your installation. fhot foes). Follow the hot face temperature (bottom of chart) vertically until It Intersects the line connecting the cool feet (left hand column) or B.t_u. lots (right hand column), list tht amount of SticTita indicated on the curve nearest the point of intersection. For example, assume operating temperature is B2S*F. end a cool fee of 139* or 126 B.tu. loo I* desired. Follow the MS* line vertically until It intersects the horizontal 139* end 129 B.tu. loo lino. The intersection -it nearest the 3-1/2" Sik-Tite curve. Therefore. 31/2~ of Stk-Tit* dtould be mad. At the same operating temperature if a cool face of 124* or B.tu. Iocs of 99 Is Mi"*, the intersection would be nearest the 5" Stk-Tit* curve. Therefore. 5" of $t<-THe Would be used. * I I I fill I {| ||I I MS* NO tUVUUUO MC. JML WHERE STIC-TITE IS USEO Air Heaters Burner eatings Boiler, front, side and rear walls Breechings Cookers > Orum heads - Elbows Flanges Feed water heaters Furnace end Oven; weds, floors, roofs Gas generators Hot air ducts Hot air lines Hot piping Hot water heaters Kettles Reaction vessels Regenerator faces Steam heaters Steam pumps Tanks Tube doors Uptakes Valves and finings AS irregular urfeces CAN BE USED ON ALL SURFACES Stic-Tite adheres strongly and permanently to metal (special Mbitors help parent rutting of metal surface), tile, brick, insulating block ere* blankets or other clean surfaces, hot or cold. It can be used in difficult places where other types of insulation ere unsuitable-on intricate piping, on elbows and Ranges, on slanting vertical or curved surfaces and rounded corners. Stic-Tile provides a monolithic, seamless, jointless cohering which can be troweled perfectly smooth for appearance. excellent ADHESION-REALLY -STAYS ON" Stic-Tit* adhere* permanently without lifting Off or dtaking.feos* yn whan ubjeetad to s*r abrasion or impact aT'or> STOPS HEAT LOSS The spongy mass of dead air calls chocks air infiltration-prevents hut tots. Sine* dry Stic-Tiw tot% not dtrinfc or term crocks, th* high Insulating efficiency never impaired. EASY TO APPLY SticTIta, mixed with th* proper amount of water. forms an easily workable, plastic man which can be Vowviad or fafy applied with tha bare hands. Tht u**al practice h to apply frit a roughing coat vr th va to bt covered, than vowel smooth around Joints, our th* aurfac* and ofbows, curves, ate. LARGE COVERAGE . ' Sinca Stic-Tita dries with practically no dsrtnkagt (an inch of SticTIta applied wtt rtmainj practically an inch thick whan dry), leu Is required to provide sufficient Insulating thicfcnm. Mixed and applied as directed, 100 lb*, of tha malarial cover 45 sq. ft. with a f thick layer. CAN BE REUSED * If usd at temperatures balow 900*F., old $t*c-TU can ba removed from equipment. crudwd. mixed with clean water and reapplied like new SticTit*. This 'makes equipment repairs tes* costly since tha insulation can b* saved. Reclaimed Stic-Tit* Is equal to tha n*w produet In insulating efficiency, adhesion and plasticity, SAVES LABOR AND MATERIALS * Stic-Tit* is so easy to apply on all types of regular and Irregular sjrfeecs and our other (nutations that labor cost is vary low. Skilled man art not needed. Since Stie-Tite adheres to strongly, reinforcing wires and other supports are unnecessary whan used up to t-1/2" thick. . CONVENIENT PACKING : Stic-Tita Is shipped dry in heevy, lined, dustless paper bags containing 2$ tbs. and SO lbs. each. It does not deteriorate in dry storage-can be kept indefinitely If dampness or wet places arc avoided. HOW TO APPLY 1. Each SO# bag should be mixed with (2 gallons 1100 lbs.) of fresh water. 2. After thoroughly mixing. Stie-Tite can be applied immediately, but better results can be obtained by allowing it to soak for at (east a half hour or longer. . 3. AH surfaces to be covered dtoufd ba fra* of paint, dust, dirt and grease. 4. Houghing coats can ba applied by hand or trowel or combination of hand and trowel. 5. If hot surfaces are to bt insulated with StieTita, the material should be spotted in place with a trowel and dragged down to a feather edge. The spotted material will dry quickly ond then a rough coat about 1" thick can be applied over and between the ^ots. . 6. On cote* surfaces for covering up to 1*1ITT thick, after being mixed according to directions on the bag. Stic-Tita should be applied by spreading ft over tht surface to as mren a thickness ss possible. After the rough coat has dried out, e fWrfi coat up to 1/7* thick can bt applied over the rough surface and finidted with a trowel to a smooth, attractive finish. Stie-Titt can be used up to M/2** thick without reinforcing. 7. For covering over 1-1/2** thick, apply a rough coat about 1** thick. When rough coat is dry apply another 1** coat and continut until desired thickness is obtained. Each coat should be dried before additional coats are applied. Prior to application of flnidt coat, we recommend reinforcing with #20 gauge 2" mesh chicken wire. S. Finish coats should be applied from 1/4" to 1/2" thick, troweled to a smooth, hard finish. Where desired, Stk-Tite finish can be painted. Best results are obtained by painting with a glue siting end paint over this, - 9. If mort Stic-Tita H mixed than can be used, the left over material can.be laid aside and nmixed with water at a later date when it is required. `' ~ At\- , . ... * aiurs uoor* .Water Ratio (Trowel {Application) 7 gals, per SO lb. bag. Dry Coverage (Trowel Application) ' .. J7 sq.ft. 1/2" thick per 50 lb. bag . Setting Time 2 to 4 hrs. average conditions. Material Requirement* (Trowel Application) 1.3 lbs. per sq.ft. 1/3" thick. Compressive Strength (Air Cured) 135 psi. *. Compressive Strength (@U0Crf*J 105 psi* Abrasion Factor (Air Cured) 38 seconds (MHD Method 102). Density (Applied end Dried) 3$ lbs* per eubfe foot* Shrinkage (wet to Dry) Negligible. . *. "K" Factor at 600F. Mean Temperature . 79 Btu. . * Corrosion Resistance to Steel . Non-corrosive* ,,. ^ .. Surface Treatment -'-*.* . Ejigily "painted, or weatherproofed ' required. . * C"." Shipping Containers (Sewn Closure) "50 lb; paper bag. ` MIXING Utility Thermal Finish Cement should be mixed in a clean mortar box or mixer, using approximately 7 gallons of water per 50 lb. bag for a good troweling consistency over most blocks, blankets, or in sulating cements. Because of the hydraulic binder. Utility should not be mixed with water more than two hours in advance of its application. With cold mixing water (below60F),/it remains workable up to 4 hrs. . STORAGE % * Store in a cool, dry location' until ready to use. Utility Gunned on Balloon Flue! * . . REFRACTORY & INSULATION CORPORATJON 625 ILLINOIS AVE. AURORA, ILLINOIS PORT KENNEDY , PENNSYLVANIA oMj; flEFRACTOKlf & INSULATION CORPORATION UTILITY THERMAL FINISH CEMENT Utility Thermal Finish Cement is composed of hi|h quality mineral Cher, hydraulic hinders, end ether suitable materials. Utility combines the flexibility, high temper* ature resistance, and excellent Insulating qualities of uniformly nodulated mineral fiber with the strength, low shrinkage, and smooth finish of hydraulic setting cement. The result is a quick setting, smooth finish,, thermal resistant, single layer insulating finish cement. For temperatures up to 1200F. QUICK SETTING Utility Insulating Finish Cement develops a smooth, durable, protective finish within a few hours after application and without the presence of heat. Subsequent drying produces no excessive surface cracking or shrinkages thickness, and occasional wetting does no damage after hydraulic set. Long drying periods under normal conditions are eliminated. Saves time in applying weatherproofing, paint, or .her finishes. Jobs are easier to schedule; scaffolding costs are reduced. ONE COAT APPLICATION Utility is normally applied in a single layer application. A second layer is needed only when multiple layer thicknesses are specified. Utility is virtually an all -purpose insulating finish cement, designed primarily for use ever Griptex block or blanket insulations. Utility Is widely used for insulating valves, fittings, heated equipment, and as an anti-sweat insulation for cold water tanks, pumps, etc. ,, . Utility trowels with a good.key on block insulation; blanket insulation and insu lating cement. It has good wet adhesion to clean steel surfaces, such as valves and fittings. . ^^ . .. PLEASING APPEARANCE ' *' ` * ' Utility dries to a smooth, light reflectant surface which ss an Interior finish, requires no further treatment. Utility, however, is easily painted if desired. Outdoor applications should be weather protected. Low temperature applications require a vapor seal type finish. * , ^CSLLENT THERMAL QUALITIES Utility has a "KV factor of .79 at600F.mean temperature. This excellent insu lating value as compared to other finish cements is a very desirable advantage wMrhflgurifig'jdb and operating costs. . May. 1964 SEFRACTORX-4 INSULATION CORPORATION : ; , SUM* 7l iiiiotATINO CIMINT.j jVr-.. , , '*I <***'f'*.--"--v--'---*--V---/-.-,Tfo- w- i./--o---r <?ve Gr-a-d*i 17--fv~' ; x| * i" -f *-- ' UWflf. ^ 0AU T* * SUPER 7)1 Inaulating Cement is a mixture of high temperature mineral fibers specially processed into resilient wool nodules* combined with asbestos and suitable binders to form a Mgb temperature plastie Insulation. Water added according to directions fives a trowelable consistency that is ready for application on equipment to be operated at temperatures up to 1600?. WIDE USAGE SUPER 711 is a versatile material for many types of insulation requirements. Applied over block or blan ket insulations, it fills open joints and provides a mono* Uthic surface for whatever type of subsequent finish Is specified. Its plastic flexibility permits application directly to regular or curved surfaces ** such as valves, fittings, tanks and vessels. EASY TO APPLY * tPER 711 has excellent adhesive qualities. Its increased stiekabftlty means a -<tter job in less time, from wet to dry. Will not slip or roll under trowel appli cation and may be easily gun applied. This superior workability is a result of fine mineral nodules, special manufacturing methods and quality control. MAXIMUM COVERAGE - LOW SHRINKAGE SUPER 711 Insulating Cement assures maximum coverage and low shrinkage. The resilient nodules of mineral fiber do not collapse when mixed with water. See table of Physical Properties for coverage. RECOMMENDED USES BOILERS Drums Headers Walls Economisers Air Preheaters FURNACES Heating* Heat Treating Forging * Annealing Normalising OVENS, KILNS It DRYERS VALVES k FITTINGS TANKS k VESSELS ' TURBINES k PUMPS FAN HOUSINGS DUCTS k BREECHINGS SPECIFICATION REFERENCES SWER711 Mineral Fiber Insulating Cement conforms to ASTM C-195-48; Federal Specification HH-C-168 (Out C); and/or Commercial Standard CS-117 of the U&tDepartAeQp? Commerce. ` ~ AW May/1964 % . . PHYSICAL PROPERTIES OF SUPER 711 INSULATING CEMENT Service Temperature Water Ratio Dry Coverage Material Requirements Compreaaive Strength Density (Applied and Dried) Shrinkage (Wet to Dry* by Volume) Thermal Conductivity Reelaimable to * Adhesion to Steel (Wet) * Adhesion to Steel (Dry) * Corrosion Resistance to Steel ' Shipping Containers (Sewn Closure) . 1S00J\ 12 gals, per SO lb. bag SO sq.ft. X" thick oer 100 lb. 2 lbs. per sq.ft. 1* thick 45 psi 24 lbs. per cubic foot 15% See Chari - *1000F. 6 pai 9 pai Non-corrosive . 50 lb. paper bags . Tabulated values represent typical performance levels of SUPER 111 Insulating Cement - Trowel Grade. SUPER 711 "Gun" Crade'Cement consists of the same basic materials that smaller mineral wool nodules are utilised to facilitate appli cation. * C * H / * io / * * J #W #yl f t U ) * U U l Kean nxrmruu - r. * REFRACTORY & INSULATION CORPORATION *' 625 ILLINOIS AVE. . f * AURORA, ILLINOIS - PORT KENNEOY PENNSYLVANIA technical data A* Surface Preparation 1. Remove dirt, scale or loose paint from the surface to be treated, then apply rust preventative paint or coating when specified. 2. For trowel applications to columns and beams, form 3/2" rib lath (or paper-backed lath) to box-in the member. Apply rib*lath with ribs turned in and spanned from flange to flange. On members 14" and ` larger, first weld 1/4" rods across the flanges approximately 12" to U" on centers to provide additional support for the lath. Secure the lath in place with wire or bands. For gun application, use 2 x 2 #16 paper-backed*lath such as Steeltex. a) Provide 2"firestopi on columns at 6* to 12* intervals (or as other wise specified). Form the metal lath into a horixontal shelf ex tending to and supported at the web. Apply F*yroseat 2'* thick in the opening. Provide similar stops at the top elevation of the fire proofing. . b) Plasterer's corner bead may be wired to the metal lath, forming and supporting it to attain the total Pyroseat thickness specified. Corner bead shall be of the type having open-mesh legs to ftcili. tate complete filling of the corners. The corner bead may be spaced the proper distance from the flanges by means of corner clips, rods, studs; or Pyroseat may be spotted-in to space the corner bead at specified fireproofing thickness. B. Application of Pyroseat 1. Mix ^roscat to recommended consistency with clean, fresh water, before application. Refer to mixing instructions on the bag and use so more water than called for. Mix Pyroseat to a homogeneous plastic mass; avoid over-mixing, particularly with mechanical mixers. a) Apply Pyroseat well into the metal lath, installing approximately 1/2 the total thickness la the scratch coat. Leave the first coat rough or scratch the surface. 0 b) On the underside of beams, the application may be In three coats. Apply a thin scratch coat first to improve adhesion. c) If corner bead was not applied previously, wire it in place when the scratch coat has set. 2. Let the scratch coat harden until well set (4 to 6 hours or longer), then double-back with the finish coat. Apply it flush with the corner bead. Sponge-float the surface to a textured finish or as otherwise specified. ,, -- r 2 t* ' .. . ?T * * a) When application of the finish coatis-deferred overnight or longr,y^~ r\ ? wet down the scratch coat thoroughly before proceeding with Uv^ Ay) * finish coat* (< O- Curing Pyroscat \ - . * Pyrocctt is * cementitious material; to develop its strength, keep it moiat for 72 hour# or longer* Depending on atmospheric condition# when applied the requiredwater retention may be accomplished with wet burlap, periodic water s pray or a hydrosatatic (resin-base) sealer. 2. Following the curing period and when visual moisture has dried, apply a suitable flashing material at all intersecting joints and exposed ends of members treated (Duriseal T-17$ Costing). * 3. ^rroscet may be painted with (1) masonry paint, (2) two coat# of asphalt* base aluminum paint, or (3) other finishes a# specified for operating conditions involved. {Note: When conventional masonry paint of the hydra- ting-type is used, wet down the Fyroscat before painting to insure proper . hydration). * . ALTERNATES FOR TOWER SKIRTS (VERTICAL) A-2 Attach a layer of 1" x 1" square mesh reinforcing, positioned 1" away from the * skirt, i.e., at the approximate center of the fireproofing thickness specified. a) Trowel or gun Fyroscat solidly through openings in the square mesh, bringing the scratch coat out approximately 1" thick. Start at the bottom of the skirt and work upward. Leave the surface rough, or scratch it when trowel applied. ' ' b) Screed strips may be attached temporarily over the square mesh reinforc ing, to accurately gauge the thickness of the second layer* c) When fireproofing is applied to skirts of heated vessels while they are in operation, heat conducted to the skirt may prematurely dry the initial layer of Pyroscat. Wet the first coat thoroughly, particularly at the top, before applying the final layer. ' ALTERNATES FOR HORIZONTAL TANKS A-2 * Bolster bars are preferred for anchorage of the reinforcing mesh. The bolster bar selected would have legs extending from the tank surface approximately one-half of the total thickness of Pyroscat to be applied. Form the bolster bars to fit the tank curvature, then weld or wire in place circumferentially approxi mately 3* on centers. Wire the reinforcing mesh to the bolster bars, C-3 When tanks so fireproofed are to be operated below ambient temperature, suit able vapor-sealingtreatmentis recommended after the Pyroscat has been cured, dried and flashed. `-REFRACTORY A1 fNSUl?AlTION`CORPORATION 625 ILLINOIS AVE. AURORA, ILLINOIS .* - PORT KENNEDY ' . " 4 1 PENNSYLVANIA * vrtniwAi y Aj A Pyroscat is s special formulation of hlgh-temperature aggregatta, asbestos fibers, hydraulic binder and ether materials. These ingredients are factory Mended to a uniform dry mixture that is ready for application afUr mixing with water at the job site. Pyroscat is adapted to application by spraying casting and trowelling techniques, depending on job conditions. USES: Pyroscat provides a lightweight, fire-retardent protective treatment for structural steel columns, beams, tower skirts, LP gas tanks, and ether exposed applications in refineries and chemical plants. Pyroscat sets up to a hard, durable sheath capable of withstanding for hours the 200Qf\ flame temperatures and High-pressure water streams commonly encoun tered in industrial fires. :* , RECOMMENDED THICKNESSES: Fire-retardent materlalsare customarily rated in Hours, based on agiven thickness used and on the method of application. For example, fire ratings /or steel columns represent the number of hours required for heat from a "standard fire" to penetrate' the protective treatment as applied, and to increase the steel column temperature to a critical level (1200F/. The thermal conductivity and heat capacity of a material are of some impor tance in an ASTM Fire Test. But the ability of the complete treatment to withstand thermal shock without destruction is one of the most significant factors in determining practical fire ratings in Industrial installations. The Pyroscat thicknesses recommendedbelow were determined by physical tests on a series of sprayed, cast and trowelled applications. Tests in cluded direct exposure to 200 psi hose pressure, both before and after subjecting the Pyroscat treatment to severe flame conditions. Thickness of Pyroscat i" 1-3/4" ** : Approx. Fire Resistance Rating 2 Hours 3 Hours - (UL-R4 Hours ADVANTAGES OF PYROSCAT Safer While-Ftthting Fires Many concrete aggregates and common ricks used for fireproofing^purposes will spall and shatter when they are seated and subjected to a hose stream , Pyroses/ remains virtually unaf fected flame exjfrsure andlsaturation wxftra lOOpaihote stream. _' * * * -"'j't'. - May, 1564.: 3 *An trade na me. ADVANTAGES OF PYRClSCAT (Contlnu.d) ' UgUerW^ht. > Pyreiot wtlght I*. th*n S$ Xbijcu. ft. In ple. compr,d Sipproxur. ielyl SO lb*. / eu. ft. for convention*! concrt flr*profin. Exenc dd w.jjht it *llminted. A* u*uUy tpr.yed or trowelled to protective eheiof Pyroeeet weijh* about 1/10 as much as formed concrete * at equivalent thickness per foci* *t fpr*y> Trowel.... Fyroscatl* specially formulated to permit installation *Pr*/' irow*i and ceetinf techniques, depending on local job conditions. Ho other fireproofing material is as versatile, from an application standpoint, a. ploys TMPPrUn* * P^cement. Only the one fireproofing material is required no need for subsequent finishing layers nor heavy mastic costings* Pyabl j w_e*V*er"Resistant.... Pyrotcat develops great strength from its selected high-temperature aggregates and hydraulic-setting binders. It with- * stands continued cycles of saturated freese-and-thaw weathering tests. SUMMARY OF PHYSICAL PROPERTIES: Coverage (Trowelled) 1.1 cu. ft. /50 lb. bag . Material Required (lYowel Application) * 45 lbs. per cu. ft. Air-Qjred Weight (After Hydration and Drying) 54. 5 lbs. per cu. ft. Compressive Strength - Air-Cured 1650 psi Compressive Strength After Firing at 1500F. Lineal Shrinkage - Air Cured 1.5% Less than 1% Lineal Shrinkage After Firing at 1500F. 1.5% Density After Firing at 1500F. 49.1 lbs. per cu. ft. Fusion Temperature 2200 F Thermal Conductivity (k) at 1000 F.Mean Temp. 1.50 Btu ' Setting Time 4 to 6 hours Mixing Water: For Spray 4 Trowel Consistency 3-1/2 Gal. water/50 lb. bag For Casting Consistency 5 Gal. water/50 lb, bag Curing: Pyroscat is a cementitious material and should be kept moist during the curing period hours or longer. - ?i - : _ REFRAQTQRy & INSOLATION CORPORATION 625 ILLINOIS AVE. AURORA. ILLINOIS PORT KENNEDY PENNSYLVANIA REFRACTORY & INSULATION CORPORATION UTILITY THERMAL FINISH CEMENT utility Thermal Finish Cement is composed of high quality mineral fiber, hydraulic binders, and ether suitable materials. Utility combines the flexibility, high temper ature resistance, and excellent insulating qualities of uniformly nodulated mineral fiber with the strength, low shrinkage, and smooth finish of hydraulic setting cement. The result is a quick setting, smooth finish, thermal resistant, single layer insulating finish cement. For temperatures up to 1200F. QUICK SETTING Utility Insulating Finish Cement develops a smooth, durable, protective finish within a few hours after application and without the presence of heat. Subsequent drying produces no excessive surface cracking or shrinkagein thickness, and occasional watting dots no damage after hydraulic set. Long drying periods under normal conditions are eliminated. Saves time in applying weatherproofing, paint, or Iher finishes. Jobs are easier to schedule; scaffolding costa art reduced. ONE COAT APPLICATION Utility U normally applied in a single layer application. A second layer is needed only when multiple layer thicknesses are specified. Utility ia virtually as all purpose insulating finish cement, designed primarily for use over Oriptex block or blanket insulations. Utility is widely used for insulating valves, fittings, heated equipment, and as an anti-sweat insulation for cold water tanks, pumps, etc. , Utility trowels with a good.key on block insulation, blanket insulation and insu lating cement. It has good wet adhesion to dean steel surfaces, such as valves and fittings. . PLEASING APPEARANCE '' Utility dries to a smooth, light reflectant surface which as an interior finish, requires no further treatment. Utility, however. Is easily painted if desired. Outdoor applications should be weather protected. Low temperature applications require a vapor seal type finish. * EXCELLENT THERMAL QUALITIES utility has a "K" factor of .79 at600F.mean temperature. This excellent insu lating value as compared to other finish cements Is a very desirable advantage when figuring job and operating coats* - -C : \ A. May, 1964 PHYSICAL PROPERTIES Servlet Temperature 1200F. Water Ratio (Trowel Application) 7 gals, per SO lb. bag. Dry Coverage (Trowel Application) 37 sq.ft. 1/2" thick per 501b. b*e Setting Time 2 to 4 hrs. average conditiont. * Material Requirement* (TYowel Application) 1.3 lbs. per sq.ft. 1/2" thick. Compreaeive Strength (Air Cured) 135 psi. . Compressive Strength (1200F.) 105 psi. Abraeion Factor (Air Cured) 88 seconds (MHO Method 102). Penalty (Applied and Dried) 35 lbs. per cubic foot. Shrinkage (Wet to Dry) Negligible. . "K" Factor at 600 F, Mean Temperature 79 Btu. Corrosion Resistance to Steel . Non-corrosive. ... _ . Surface Treatment *: \ . Easily "painted, or weatherproofed # # when required. Shipping Containers (Sewn Closure) 50 lb. paper bag. '* MIXING Utility Thermal Finish Cement should be mixed in a clean mortar box or mixer, using approximately 7 gallons of water per 50 lb. bag for a good troweling consistency over most blocks, blankets, or in sulating cements. Because of the hydraulic binder. Utility should not be mixed with water more than two hours in advance of its application. With cold mixing water (below 60F),/it remains workable up to 4 hrs. STORAGE Store in a cool, dry locationuntil ready to use. Utility Gunned on Balloon Fluel . r. REFRACTORY & INSULATION CORPORATION 625 ILLINOIS AVE. PORT KENNEDY* AURORA, ILLINOIS PENNSYLVANIA; CERTIFICATE 07 SERVICE I, the undersigned attorney for Third-Party Defendant Combustion Engineering, Inc., do hereby certify that I have this day mailed, by United States mail, postage prepaid, a true and correct copy of the above and foregoing Combustion Engineering, Inc.'s Responses to Third-Party Plaintiffs and Cross-Claimants' Interrogatories, Requests for Admissions and Request for Product^n to all counsel of record. THIS 1992