Amicus Curiae Brief — Air and Liquid Systems Corp., et al., Petitioners v. Roberta G. DeVries, Individually and as Administratrix of the Estate of John B. DeVries, Deceased, et al.

App. 1

GENERAL [LOGO] ELECTRIC

DIAL

PLASTICS ENGINEERING DEPARTMENT COMM

ONE PLASTICS AVENUE

8*236

PITTSFIELD, MASS. 01201

January 23, 1979

Mr. G. Hiner

Office

Subject: Medical Evaluation of GENAL Asbestos Free

Brochures

I expect the first reaction of the average person to the

attached brochures would be that GE has done a very

good thing to eliminate asbestos from its products,

starting in 1972; and that GENAL certainly is a better

product to purchase than competitive phenolics containing asbestos. The brochures are very effective marketing tools.

However, there is a major problem and risk to PBD in

using this advertising and sales approach. While we

can be proud that we stopped using asbestos in 1972,

how do we justify our use before 1972 when the suggestion that a relationship existed between asbestos

and cancer was made in 1935 and confirmed in 1955?

We lay ourselves open to attack on issues such as:

•

Why did we continue to use asbestos

when it was a known health risk?

•

What have our medical examinations on

exposed workers shown (PBD did not do

exams religiously or at all over the

years)?

App. 2

•

What special efforts is PBD making for

retired exposed workers?

•

What efforts have we made to track down

and inform/examine workers exposed

long ago who have left GE or transferred

to other organizations?

•

What has GE done for exposed workers

who have died of asbestos induced cancer

and their families?

Any of these issues could potentially give us very negative publicity in spite of the fact that we are doing a

better job than our competitiors [sic]. On a relative

scale we are doing fine. On an absolute scale, our performance leaves much to be desired. Consider that

•

Asbestos exposure in industry is one of

the most serious issues facing American

industry today. Heavy exposure to asbestos may lead to a related death rate of

approximately 46%. Disease follows exposure by a period of 15-20 years. The disease that follows (cancer of the lung,

pleura or peritoneum) is fatal. No effective therapy exists. Cessation of use in

1972 does not relieve the issue of dangerous exposure to workers and consumers

in 1965, for instance.

•

All MD’s in the nation have received a

Physician’s Advisory Letter describing

the effects of asbestos exposure (see attachment #1).

App. 3

•

All Social Security recipients have received such an advisory letter from the

Secretary of Health, Education and Welfare.

•

A national TV campaign stating the

dangers of asbestos exposure is being

planned.

•

A $20,000,000 out of court settlement has

been made to 455 asbestos workers and

more are predicted to come (see attachment #2).

In my view, the risks outweigh the benefits and my recommendation would be to discontinue this marketing

strategy. I would use the “asbestos free” approach verbally with purchasing agents and molders. I would not

use it in media advertising, on truck sides or in our

mailing campaigns.

/s/ Wm. J. Taylor, M.D.

William J. Taylor, M.D.

-W

Attach.

App. 4

GABRIEL A. JACKSON, State Bar No. 98119

C.J. MANOLI, State Bar No. 147342

COURTNEY M. KING, State Bar No. 221239

JACKSON & WALLACE LLP

55 Francisco Street, 6th Floor

San Francisco, CA 94133

Tel: 415.982.6300

Fax: 415.982.6700

Attorneys for Defendant

BUFFALO PUMPS, INC.

IN THE SUPERIOR COURT OF THE

STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF LOS ANGELES

CONRAD BEAUCHAMP

and OPAL GERALDINE

BEAUCHAMP,

Plaintiffs,

v.

ALLIS-CHALMERS

CORPORATION PRODUCT

LIABILITY TRUST, et al.,

Case No. BC-357289

RESPONSES OF

DEFENDANT

BUFFALO PUMPS,

INC. TO PLAINTIFFS’

STANDARD INTERROGATORIES

Defendants.

PROPOUNDING PARTY: Plaintiffs CONRAD

BEAUCHAMP and

OPAL GERALDINE

BEAUCHAMP,

App. 5

RESPONDING PARTY:

Defendant BUFFALO

PUMPS, INC.

SET NO.:

One

Preliminary Statement

The following responses are based upon the information that is presently known and available to

Buffalo Pumps, Inc. based upon a reasonable investigation. Buffalo Pumps, Inc. believes that these responses are accurate as of the date made. However,

many of the matters inquired about in Plaintiffs’ Discovery took place decades ago, therefore, information

may be incomplete or no longer available due to the

passage of time. Although Buffalo Pumps, Inc. has endeavored to conduct a reasonable investigation, Buffalo Pumps, Inc. cannot exclude the

*

*

*

[5] 14. Have you, at any time, engaged in the processing, marketing, and sale of [illegible] containing

asbestos fibers?

RESPONSE

Buffalo Pumps, Inc. incorporates by reference

herein the foregoing Preliminary Statement and General Objections. Buffalo Pumps, Inc. further objects to

this request on the grounds that it is overly broad, unduly burdensome, vague and ambiguous, and seeks information that is neither relevant nor reasonably

calculated to lead to the discovery of admissible

App. 6

evidence. Without waiver of and subject to its objections, Buffalo Pumps, Inc. responds as follows:

Buffalo Pumps, Inc. is a manufacturer of centrifugal pumps. Buffalo Pumps, Inc. understands that, at

various times, centrifugal and perhaps certain other

types of pumps were manufactured at the North Tonawanda facility by the Buffalo Pumps Division of the

Buffalo Forge Company and the Buffalo Steam Pump

Co. Buffalo Pumps, Inc. believes that the pumps were

made of metal alloys, and that the pumps themselves

contained no asbestos materials. Typically, however,

the metal components of certain of these pumps would

have required packing and gaskets. Upon manufacture, the original pump typically would be supplied to

a customer with the appropriate packing and gaskets.

Between 1955 and 1985, and during at least some periods of time prior to 1955, gaskets and packing supplied in certain original pumps manufactured by the

Buffalo Pumps Division of the Buffalo Forge Company

and the Buffalo Steam Pump Co. contained asbestos.

Upon a reasonable investigation, neither the Buffalo

Pumps Division of the Buffalo Forge Company nor the

Buffalo Steam Pump Co. manufactured the gasket or

packing material installed in any of their respective

pumps; to the contrary, such materials were mined,

manufactured, marketed, sold, and supplied by others.

Buffalo Pumps, Inc. believes that the Buffalo Pumps

Division of the Buffalo Forge Company on some occasions provided small numbers of gaskets to certain customers along with other replacement parts for certain

pumps.

App. 7

Buffalo Pumps, Inc. has not engaged in the mining, processing, or manufacturing of any asbestos-containing product as it understands those terms in the

context of Plaintiffs’ Discovery. In 1987, Buffalo

Pumps, Inc. filled an order for a United States Navy

vessel for which the [6] pertinent specifications required the use of asbestos-containing gaskets. Since

Buffalo Pumps, Inc. was not using asbestos-containing

gaskets, the customer provided the gaskets. Buffalo

Pumps, Inc. affixed warning labels to the pumps containing the customer-supplied gaskets prior to shipment. See Response to Standard Interrogatory 28.

Buffalo Pumps, Inc. has come to understand that

certain pumps manufactured by the Buffalo Pumps

Division of the Buffalo Forge Company and/or by the

Buffalo Steam Pump Co. may have been insulated in

their ultimate applications, and that in some instances

the insulation contained asbestos as an ingredient.

Upon a reasonable investigation, Buffalo Pumps,

Inc. is not aware that any gasket and packing materials installed on its pumps or those of the Buffalo

Pumps Division of the Buffalo Forge Company and/or

Buffalo Steam Pump Co. bore any product or trade

name. Buffalo Pumps, Inc. has not located specific information with respect to the content, including the

type of asbestos fiber, if any, in much of the gasket and

packing material supplied with pumps by the Buffalo

Pumps Division of the Buffalo Forge Company or the

Buffalo Steam Pump Co. To the extent that Buffalo

Pumps, Inc. is aware of and/or has located military or

other customer specifications that reference the type of

App. 8

asbestos fiber in any gasket or packing materials, the

referenced fiber type is chrysotile.

After a reasonable investigation, Buffalo Pumps,

Inc. is not aware that the Buffalo Pumps Division of

the Buffalo Forge Company utilized any packaging or

containers, as that term is reasonably understood in

the context of pump manufacture and supply, for its

pumps.

After a reasonable investigation, Buffalo Pumps,

Inc. believes that gaskets and packing materials used

by the Buffalo Pumps Division of the Buffalo Forge

Company were manufactured and/or supplied by: John

Crane Company, Sealing Devices, Inc., and/or Ace-OPax.

The only manufacturing plant ever operated by

Buffalo Pumps, Inc. or, to its knowledge, the Buffalo

Pumps Division of the Buffalo Forge Company, is a facility located in North Tonawanda, New York.

The business of Buffalo Pumps, Inc. and, before it,

the Buffalo Pumps Division of the Buffalo Forge Company and the Buffalo Steam Pump Co., has at all times

been the manufacture

*

*

*

[13] Buffalo Pumps, Inc. states that in 1987, Buffalo Pumps, Inc. filled an order for a United States

Navy vessel for which the pertinent specifications required the use of asbestos-containing gaskets. Since

Buffalo Pumps, Inc. was not using asbestos-containing

gaskets, the customer provided the gaskets. Buffalo

App. 9

Pumps, Inc. affixed warning labels to the pumps containing the customer-supplied gaskets prior to shipment. The text of these labels read as follows:

DANGER

GASKET MATERIAL CONTAINS ASBESTOS

AVOID OPERATIONS TO IT THAT

WILL CREATE DUST

CANCER AND LUNG DISEASE HAZARD

After a reasonable investigation, Buffalo Pumps,

Inc. is not aware that the Buffalo Pumps Division of

the Buffalo Forge Company published or distributed

any printed material containing any warnings concerning the possibility of injury resulting from the use

of asbestos-containing component products. To the extent it has located responsive documents, Buffalo

Pumps, Inc. will make them available for inspection

and copying at a mutually convenient time.

See also Response to Standard Interrogatory 14.

29. If so, please state:

(a)

When did the warning first appear?

(b) What was the precise wording of the

warning, when it first appeared?

(c) Was the warning altered, amended

or changed in any manner? If so, how and

when?

(d) Where was the warning located on

the product or packaging?

App. 10

(e) When did you become aware of warnings placed on products distributed by other

manufacturers or suppliers of asbestos or asbestos containing products?

(f ) State the manner in which your

product is shipped and the type of container

in which it is shipped to retailers;

(g) State whether any industrial psychologists or human factors engineers were

consulted prior to utilizing such warnings,

cautions, etc.

*

*

*

App. 11

STANDARD FORM 30,

JULY 1966

GENERAL SERVICES

ADMINISTRATION

AMENDMENT OR

SOLICITATION/

MODIFICATION

OF CONTRACT

Page

1

of

7

FED PROC REG.

(41 CIR) 1-16.101

1. AMENDMENT/MODIFICATION NO. 2. EFFECTIVE DATE

75 mar 25

P00002

4. PROJECT NO.

3. PRODUCTION/PURCHASE

REQUEST NO.

(If applicable)

N65540-3044-1277

5. ISSUED BY P40:DJC

CODE

N00140

Naval Regional Procurement Office

U. S. Naval Base, Bldg. 600

Philadelphia, Pa. 19112

6. ADMINISTERED BY (If other

CODE

than block 3)

Commander, DCASD Springfield

240 Route 22

Springfield, NJ 07081

7. CONTRACTOR

CODE 23230 FACILITY

NAME AND ADDRESS

CODE

(Street,

Foster Wheeler Corp.

City,

110 South Orange Ave.

County,

Livingston, NJ 07039

State, and

351-2195

ZIP Code)

CONTRACT FILE

8. ⬜ amendment of

solicitation no. N00140

dated _____________ (See blank 9)

☒

modification of

contract/order no. N00140-73-C-0885

dated 73 JUN 25 (See blank 11)

App. 12

9. THIS BLOCK APPLIES ONLY TO AMENDMENTS

OF SOLICITATION

⬜ The above numbered solicitation is amended or

set forth in block 12. The hour and date specified

for receipt of Offers ⬜ is extended ⬜ is not

extended

Offerors must acknowledge receipt of this amendment prior to the hour and date specified in the

solicitation, or as amended, by one of the following

methods

(a) By signing and returning 2 copies of this

amendment; (b) By acknowledging receipt of this

amendment on each copy of the offer submitted; or

(c) By separate letter or telegram which includes a

reference to the solicitation and amendment number. FAILURE OF YOUR ACKNOWLEDGMENT

TO BE RECEIVED AT THE ISSUING OFFICE

PRIOR TO THE HOUR AND DATE SPECIFIED

MAY RESULT IN REJECTION OF YOUR OFFER.

If, by virtue of this amendment you decide to

change an offer already submitted, such change

may be made by telegram or letter, provided such

telegram or letter makes reference to the solicitation and this amendment, and is received prior to

the opening hour and date specified.

10. [Illegible] and

Obj. Ct. Bureau

Sub.

[Illegible]

Conf. No.

Allot.

(RCP No. 301-301-3-040) 000

00024A

AA 1731804.2472

Authentication

Trans

Property

Acct’g Acct’y

Type

Acct’g Acct’y

065872

2D

000000

App. 13

County

Cost Code

007208000FFQ

Amount

decrease

$8,329.62

11. THIS BLOCK APPLIES ONLY TO MODIFICATIONS OF

CONTRACTS/ORDERS

(a) ⬜ This Change Order is issued pursuant to

__________________________

The Changes set forth in block 12 are made to the

above numbered contract/order

(b) ⬜ The above numbered contract/order is

modified to reflect the administrative changes, or

changes in paying office, appropriation date, etc.)

set forth in block 12.

(c) ☒ This Supplemental Agreement is entered

into pursuant to authority of GENERAL CONTRACTUAL AUTHORITY It modifies the above

numbered contract as set forth in block 12.

12. DESCRIPTION OF AMENDMENT/MODIFICATION

THIS SUPPLEMENTAL AGREEMENT OF SETTLEMENT, entered into this 25 day of March , 1975

between the UNITED STATES OF AMERICA (hereinafter called “the Government”), represented by the

Contracting Officer executing this contract, and Foster Wheeler Corporation.

a Corporation organized and existing under the

Laws of the State of New York; (hereinafter called “the

Contractor”).

WITNESSETH THAT:

WHEREAS, the Contractor and the Government

have entered into Contract No N00140-73-C-0885

under date of 25 June 1973 which, together with any

and all amendments, changes, modifications and

App. 14

supplements thereto, is hereinafter referred to as

“the contract”; and

WHEREAS, the contract provides that the performance of work thereunder may at the convenience

or option of the Government be terminated by the

Government in whole or from time to time, in part,

whenever any such termination is determined to be

for the best interest of the government, and that the

Contractor and Contracting Officer may agree upon

the whole or any part of the amount or amounts to be

paid to the Contractor by reason of such termination,

and

WHEREAS, the Contractor is willing to waive

unconditionally any claim against the Government

by reason of such termination.

NOW, THEREFORE, the parties hereto agree as

follows:

ARTICLE 1. The terminated portion of the contract is designated as follows:

Except as provided herein, all terms and conditions

of the document referenced in block 8, as heretofore,

changed, remain unchanged and in full force and effect.

13. ⬜ CONTRACTOR/OFFERORS IS NOT REQUIRED TO

SIGN THIS DOCUMENT

☒

CONTRACTOR/OFFEROR IS REQUIRED TO SIGN THIS

DOCUMENT AND RETURN 2 COPIES TO ISSUING OFFICE

14. NAME OF CONTRACTOR/ 17. UNITED STATES

OFFEROR

OF AMERICA

BY ____________________

BY _[Illegible]__________

(Signature of person

authorized to sign)

(Signature of

Contracting Officer)

App. 15

15. NAME AND

16. DATE 18. NAME OF

19. DATE

TITLE OF SIGNED

SIGNED

CONTRACTING

SIGNED

OFFICER (Type

75 Mar 25

(Type or print)

or print)

W. E. GOULD

*

*

*

(6) NAVSHIPS 0351-065-1000 (for main boilers

used on CVA-64)

(7) NAVSHIPS 0351-065-2000 (for main boilers

used on CV-63)

A.

SCOPE OF WORK

1. The contractor shall perform shipchecking,

writing, editing, art and production services to accomplish a major revision of each of the above manuals: NAVSECPHILADIV shall either furnish to the

contractor all basic information (raw material) necessary to accomplish the revisions, or instruct the contractor as to where some information can be readily

obtained. For each manual revision, this information

will include such items as the existing manual; new

or revised procedures for boiler maintenance; description, operation and maintenance information for

newly installed equipment; and photographs of boiler

equipment. The contractor shall use new technical

manual stock numbers, to be supplied by

NAVSECPHILADIV, in lieu of the original manual

numbers referenced above on all tasks. Each manual

will be prepared as a two volume set. A different

number will be assigned to each volume. The acronym “NAVSEA” shall be used in the manual stock

number located on the front cover, spine, title page,

marginal copy and/or text references instead of

App. 16

“NAVSHIPS” used in original manuals. The command authorization on the front cover and title page

shall read “Published by Direction of Commander,

Naval Sea Systems Command”. The Hull designation

CV should be used in lieu of CVA on manual (7)

above.

Services required from the contractor are described

as follows, and shall be furnished for each manual revision to the extent specified in paragraph A3 below:

(1) Page 2, paragraph e(3) Each manual shall

consist of two volumes containing approximately 550

pages of text and text illustrations and 115 fold-out

drawings.

(2) Page 2, paragraph e(5) substitute “Univers

Bold Type” for “Classified News Type”.

(3) Page 3 paragraphs 2 and 3, and pages 4 and

5 in their entirety, are hereby superseded by the following:

2. Each revised manual shall include the following elements, in the order shown. Each text section shall have a divider sheet.

VOLUME I

a.

Cover and Spine

b.

Front matter

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

Title page

List of effective pages

Change record

Approval and procurement record page

Content assurance page

Safety summary

Quick index page

Table of contents

App. 17

(9) List of text illustrations

(10) List of engineering drawings (plans) in

volume II

c. Section A – Boiler Description and Design

Data

d. Section B – Boiler Operation

e. Section C – Boiler Planned Maintenance

f. Section D – Boiler Corrective Maintenance

g. Section F – Fuel Oil Burners

h. Section G – Flame Scanner (if required)

i. Section H – Smoke indicators

j. Section J – Soot Blowers

k. Section K – Draft Gage

l. Section M – Water Level Indicators

m. Section N – Safety Valves

n. Section P – Hydrostatic Pump and Test

Methods

o. Section R – Repair Parts List

p. Section S – Special Tools and Equipment List

q. Section T – Maintenance Materials List

r. Appendices (if required)

s. Glossary

t. User Activity Comment Sheets (3)

VOLUME II

a.

Cover and spine

b.

Front matter

(1)

(2)

(3)

(4)

(5)

volume II

Title page

List of effective pages

Change record

Approval and procurement record page

List of engineering drawings (plans) in

App. 18

c. Engineering Drawings (plans)

d. User Activity Comment Sheets (3)

3. For each manual revision, the contractor shall

perform the shipchecking described in paragraph C1

below. The extent of other contractor services required for each manual revision is as follows:

SEE FOLLOWING PAGE

*

*

*

(4) Page 7 paragraph B 4 b – Superseded by the

following:

Line art text illustrations should be incorporated

into text camera ready copy properly sized. Photographic text illustrations must be separately

mounted, covered, and marked to indicate cropping

and percent reduction required.

(5) Page 8 – paragraph C – In order to provide

for the deletion of the manuals required for the

DD937 and DD948 boiler classes and the rescheduling of the remaining manuals, the tabulation

shown for shipchecking on page 8 is deleted and the

following substitution is hereby incorporated:

Shipchecks should be conducted on one (1) ship

in each boiler class except for the DLG-19 and DDG4 classes which will require checking two (2) ships

each. By the terms of the contract, four (4) shipchecks will be required to be conducted on the west

coast and five on the east coast.

(6) Delivery schedule set forth in modification

P00001 to the contract is superseded by the following:

App. 19

SHIPS CLASS

TASK #

--Re

DLG-19

CVA-66🗸🗸

DDG-23🗸🗸

DDG-4🗸🗸

CVA-64🗸🗸

CV-63🗸

DDG-35🗸🗸

I

II

VI

IV

V

VII

X

XIII

FINAL TASK #

CONTRACTOR

SUBMITTAL

PRELIMINARY DRAFT

Completed

Completed

16 JUN 1975

15 MAR 1975

15 MAY 1975

15 JUL 1975

15 OCT 1975

15 DEC 1975

CONTRACTOR

SUBMITTAL FINAL

COPIES

--Sixty Days from Final

Approval of Preliminary

Draft

↓

Re: --1/75

10/10/75

🗸III

🗸🗸XI

9/1/75

🗸🗸VIII

11/75

4/76

🗸IX

🗸🗸XII

XIV

XV

The Government shall be allowed 90 days from receipt to review and comment on the preliminary

draft of each manual. The Government is at liberty

to make comments on any aspect of the preliminary

draft at this time and to require any changes desired

in scope, content, wording, format and editorial treatment as long as such changes do not cause the contractor to perform work beyond the scope of the

contract. If in the Government’s opinion the preliminary draft requires changes or additions, the contractor will be required to revise and resubmit the

preliminary draft or portions thereof for re-review by

App. 20

the Government. The contractor shall resubmit the

preliminary draft or portions thereof within 30 days

from the termination of the 90 day Government review period.

Once the Government has approved the preliminary

draft it may not subsequently require the contractor

to make changes without claim by the contractor. The

contractor continues to be responsible to correct

spelling, grammatical and typographical errors even

if discovered after the preliminary draft approval

date. In addition, the Government may require

changes to the final artwork and drawings, since in

the preliminary manual this material is only required in rough form.

All additional cost associated with revision and resubmittal of preliminary and final task material,

within the scope or the contract, will be borne by the

contractor. The Government reserves the right to require adequate consideration from the contractor for

any extension of the delivery schedule necessitated

by the resubmission.

*

*

*

App. 21

NAVSEA 0951-LP-039-7010

VOLUME I OF II

TECHNICAL MANUAL

DESCRIPTION, OPERATION AND

MAINTENANCE INSTRUCTIONS

1200 PSI MAIN BOILER

FOSTER WHEELER CORPORATION, D TYPE

[SEAL]

USS DAVIS (DD 937)

USS JONAS INGRAM (DD 938)

USS BLANDY (DD 943)

USS MULLINNIX (DD 944)

USS DECATUR (DDG 31)

Each transmittal of this document outside

the Department of Defense must have the approval of NAVSEA (Code 522).

This publication and Volume II,

NAVSEA 0351-LP-039-7020, supersede

NAVSEA 0351-LP-055-3003 dated July 1969.

Published by direction of Commander,

Naval Sea Systems Command.

15 MAY 1980

*

*

*

SUMMARY OF SAFETY PRECAUTIONS

Boiler operation and maintenance is serious business because it is the ship’s power source. Improper operation will cause delay of the ship. But more

important, improper operation can result in damaged

equipment, injury and/or loss of human life

App. 22

Most of the material in this manual referred to as

lagging, insulation, insulating board, packing,

sheet/compressed or spiral wound gaskets contains asbestos. Asbestos is a major health hazard. All suspected material must be ripped-out, and disposed of in

accordance with NSTM Chapter 635 and approved

shipyard procedures when replacement is necessary.

This technical manual contains many NOTES,

CAUTIONS and WARNINGS located where they will

do the most good. Believe in them. They are important

and could save your life.

The following is a summary of precautions:

Before removing any fittings or parts subject to

pressure, or loosening a manhole or handhole plate fitting of a boiler after it has been under steam, steps

should be taken to insure a complete absence of pressure by opening the drum vent.

It should always be borne in mind that a fall in

steam pressure, unless there is some apparent reason

for it, is a possible indication of low water.

There is always danger that steam may leak to an

idle or open boiler through a leaky blow valve, when

the blow valve of another boiler connected to the common blow line is opened. This same danger exists with

respect to stop valves, feed valves, etc. To prevent injury to personnel, the practice of entering a boiler under these circumstances should be avoided, unless

necessary to do so in emergency situations. In those

App. 23

situations, extreme caution shall be observed, especially if double valve protection is not provided.

Tag-out in accordance with OPNAVINST 3120.32

article 630.17 and wire shut the supply valves of steam

smothering systems while men are working in the vicinity thereof. To guarantee that these valves will not

be opened, consideration may be given to the use of

chains or padlocks while men are working.

Do not use open flames in oil-burning firerooms

(except as authorized), oil tanks, or near oil hose, oil

vents, etc.

Remove atomizer from register as soon as possible

after securing oil to burner.

The temperature of any fuel should never be

raised to or above the flash point in any part of the system.

Observe the following precautions to reduce danger

of flarebacks:

Purge the furnace before each light-off.

Do not allow oil to accumulate in furnace. Fuel oil

root valves and safety shut-off valves must be tested

periodically and maintained tight.

When a burner is secured, both its root valve and

safety shut-off valve must be shut.

Never attempt to relight an atomizer from hot

brick wall. Use a torch.

App. 24

When lighting off with a torch, stand well clear of

the light-off port, to avoid injury in case of flareback.

Do not use oil from a tank in which there is more

than 0.1% of BS&W in the oil.

*

*

*

Castable refractory and insulation layers are installed over the furnace drain. During boiler operation,

the bricks protect the drain and casing in this area

from damage by radiant heat. When water washing

procedures are required, the castable and insulation

are removed and drain is uncapped to facilitate removal of water. (For drain location, see Plan A-3.)

D-7-3. BAKING OUT PROCEDURES

a. Drying Out Mortar. This requires no consideration because of the small amount of moisture involved, and because plastic or castable refractory

installed after brickwork governs drying and baking

out procedure.

b. Baking Out Plastic Fireclay Refractory. Air

drying prior to firing is unnecessary and, in fact, is undesirable since shrinkage is increased. The method of

firing must necessarily be that which suits the condition existing at the time of installation; firing initially

at a rate sufficient to form steam within the plastic

mass should be carefully avoided. The necessity for

baking out plastic presents an inconvenient situation

especially during building or overhaul periods. This is

one reason why use of castable is preferred. Careful

App. 25

planning of work is required in preparing to bake out

plastic. The following procedure will give optimum results and should be followed, whenever practical, for

burner fronts rebuilt completely with plastic refractory

in lieu of burner tile:

NOTE

It is not possible to bake out plastic refractory

properly without firing the boiler. Castable refractory must be used if the service available

and the condition of the boiler do not permit

operation.

1. The boiler should be lit off within 24 hours of

completion of the plastic installation. If this is not possible, the plastic should be kept moist by covering with

damp cloths or plastic film until just before lighting off.

2. The superheater must be protected while baking out. Superheater protection steam, when available,

should always be used. If no steam is available, the procedure and cautions for cold light off in Section B

should be observed.

CAUTION

Superheater outlet temperature should not

exceed 850 degrees F while raising steam.

3. One burner with a standard VP-12-2855 atomizer should be lit off (in accordance with Section B-5-1)

for one hour at the minimum oil rate (about 65 psi supply pressure). Then slowly increase boiler firing rate so

App. 26

that boiler operating pressure is maintained about

three to four additional hours.

4. To develop strength, furnace temperature

should be gradually increased to the maximum attainable temperature for the steam demand conditions

(normally maximum port auxiliary load). Firing at the

boiler full-power rating is desirable if permitted by the

steaming conditions.

5. Firing of the boiler at the maximum practical

temperature should be continued for a period of several hours to develop bonding in the plastic.

If time is available, after completion of baking out

procedure and when brickwork has cooled sufficiently,

it is advisable to open furnace and inspect settings.

c. Baking Out of Castable Refractory. Castable

refractory should be allowed to dry (cure) for at least

one, but preferably two days before baking out. Indefinitely long drying periods are not harmful. Baking out

of castable refractory should be performed in the same

manner as for plastic refractory.

D-8. CASING

D-8-1. REPLACEMENT OF CASING GASKETS

a.

Types of Gaskets

1. During original construction 1/8-inch

thick copper clad asbestos gaskets were used for all

casing seals. Two types of replacement gaskets are

commonly used to seal access doors and panels. A

App. 27

“tadpole’’ or bulb-type gasket is used with access doors

that are installed with clamps and a flat ribbon-type

gasket is used with bolted-on panels. The flat ribbontype gasket is usually 1/8-inch thick. Gaskets made of

asbestos material must not be used; they must be replaced with gasket made of ceramic or fiberglass material.

2. A 3/8-inch ceramic fiber rope can be used

as a temporary gasket by itself or can be used to supplement other gaskets in stopping air leaks due to casing distortion or warpage. When using ceramic fiber

rope as a gasket on a bolted door, the rope should be

laced between studs.

b. Gasket Installation. Inner or outer casing surfaces where gaskets seat should be inspected before

panel or door gasket installation to insure satisfactory

surface conditions are present. Corrosion deposits or

remains of old gasket material should be removed by

scraping and wire brushing. If casing frames have been

repaired or replaced, and welding has been accomplished in a gasket seating area, excess weld should be

removed by grinding to insure surface is entirely

smooth. Also remove any weld splatter by grinding. If

stud replacement has been accomplished, remove any

excess weld at stud base by grinding to insure panel

will fit tightly against seating surface.

Gaskets can be held in the proper position when

refitting a panel by the use of small pieces of masking

tape.

App. 28

The complete gasket for an access door or panel

will generally be made up by using strips of gasket material which must be joined together properly to prevent air leakage where the pieces come together. The

preferred method of joining gasket strips at the corners

is with a “dove tail” joint. The male dove tail should be

cut 1-inch wide at the top, and tapered to 5/8-inch wide

at the bottom. The female joint should be traced and

matched to each male end. Mark all gasket pieces to

avoid mis-matching dove tails during installation.

Using boiler sealing compound (see Section R) at

the gasket joint is a more common and simpler method

of sealing a joint but is not as effective as dove tails

since sealing compound after exposure to high heat for

a period of time becomes hard and brittle and thus

loses its sealing properties. To seal a joint with compound, first cut the gasket strips the desired lengths

and place on the boiler. Take a small amount of compound and press it into the joint of the gasket strips.

When the panel is replaced, the compound will be compressed into the joint. Boiler sealing compound can

also be used to temporarily seal a panel where distortion beyond the sealing capability of a regular gasket

material exists.

D-8-2. REPAIR OF CASING FASTENERS.

Frequent removal and installation of access panels for

inspection and cleaning will most likely necessitate repair of the fasteners which will hold the panels to the

boiler. Studs will be sheared off or their threads will

App. 29

become stripped. These conditions usually result from

an overtightening of the nut. Panels which are not frequently removed or those which have been exposed to

moisture may be difficult to remove because the nuts

have become “frozen” from corrosion.

NOTE

The use of an anti-seize compound (see Section T) on all threaded surfaces should be

standard procedure when installing casing.

This compound will withstand the temperatures of the boiler and resist corrosion and

thereby make removal easier. Application can

be accomplished with a thin acid brush since

only enough compound is needed to lightly

coat the threads of the stud or bolt.

a. Studs. Since the casing must be maintained

airtight, repair of broken or missing studs must be accomplished. A panel which is difficult to remove or install may have one or more bent studs. Determine

which direction the stud must travel in order to move

free in the panel bolt hole. Thread the proper size nut

on the end of the stud. Tap the nut lightly with a hammer to straighten the stud.

A die nut (see Section S) can be used to repair

threads which are not severely damaged. The die nut

should be threaded on as in tightening a regular nut.

Back the tool off 1/2 turn every two revolutions or even

more frequently if resistance is encountered. This allows the metal chips (if any) to become free of the cutting surfaces. If the nut is extremely loose on the stud

App. 30

(indicating shallow threads) after rethreading, the

stud should be replaced.

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