Document gbXeqmMEgZOE0zLbyDqx4EZje

FILE NAME Manville JMA DATE 1979 DOC JMA324 DOCUMENT DESCRIPTION Legal - Answers to Plaintiff's Interrogatories - Railroad Friction Products Tests VICTOR DERRICK VS. GRIFFIN WHEEL ET AL COURT OF COMMON PLEAS DIVISION OCTOBER TERM 1979 No. 1298 ANSWERS OF DEFENDANTS MANVILLE CORPORATION MANVILLE SALES CORPORATION TO PLAINTIFF'S INTERROGATORIES AND Coup 1. Describe in detail the corporate relations between Manville and Railroad Friction Products RFPC ANSWER Manville Corporation owns 50 of the shares of stock of Railroad Friction Products Corporation 2. Does or did Manville own a percentage of the stock of RFPC ANSWER See Answer to Interrogatory No. 1 3. What is that percentage ANSWER See Answer to Interrogatory No. 1 4 Does Manville control RFPC ANSWER No. 5. Does RFPC manufacture railroad engine brake shoes for Manville If no did it do so and during what years ANSWER No. -1- PRODUCEDPRODUCED PRODUCED M 33 M 11. If the answer to 10 is yes what percentage of the dust is asbestos How many particles of asbestos dust per million particles dust and air are emitted ANSWER Not applicable 12 Do these railroad engine brake shoes deteriorate ANSWER Not applicable 13. When they deteriorate do they become cracked and broken ANSWER Not applicable 14. Is dust containing asbestos emitted of asbestos dust per million are emitted How many particles ANSWER Not applicable - 15. Have you ever tested the asbestos dust emissions of your railroad engine brake shoes ANSWER Not applicable 16. Have you ever tested the asbestos dust emissions of railraod brake shoes manufactured by Railroad Friction Products ANSWER Yes 17 If the answer to 15 or 16 is yes please set forth a time place and date of tests ANSWER July 26-30 1971 Wilmerding Pennsylvania b nature of tests ANSWER A series of tests were run on a dynammeter simultating a wide range of braking conditions Wear dust from the various phases was collected the subsequently analyzed for asbestos fiber content C. conclusions of the tests -3- PRODUCED PRODUCED ANSWER Results of these tests showed that less than % of the fiber originally in the brake shoes appears as undegraded fiber in the wear dust under most conditions and that less than 1/10 of that amount becomes airborne d where results were published or filed ANSWER To Defendants'knowledge the results were not published @. how Plaintiff may obtain those results ANSWER Defendants object to this subpart on the grounds that this is an inappropriate question Dated this day of June 1982 MARSHALL DENNEHEY COLEMAN and GOGGIN WARNER 06-03-82 By Attorneys for Defendants Manville Corporation and Manville Sales Corporation 1515 Locust Street Philadelphia PA 19102 215 893-3800