ML20090C262
| ML20090C262 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/09/1984 |
| From: | Christensen S AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20090C261 | List: |
| References | |
| OL, NUDOCS 8407130226 | |
| Download: ML20090C262 (46) | |
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1984, cannencing at the.: oar J
9:54 c.r.,
at cac e: fices of TRA:!SAMERICA DCLAVAL, 350 4
C 5tn A ven.. L, J2kland, C alifornia, be: ore me, BAR3 ARA 5
7;iv.IAC, c :Ictary luolic in and for tne S tate of e
O a. i i o r r. i c, cc:ron 11y :p;. eared 7
STA!! LEY G. CHRISTENSEN, d
c.lli.d as a sitness ::y LONG ISLAND LICHTING CO '? *s!U, onc 9
t..e saiu wi tness, veing oy ac first duly sworn, was 10 thereu,;on examined anc testified as nercinafter set forth.
11
!!UNTON & ;iILLIAMS, B3 & T Ouiicling, P.O.
Scx 12 los, asleign, North Carolina 27602, re c,res en ted by CDES L.
13 CTRCUPC, J it., 03J., apicared as coansel on behalf cf 14 LONG ISLnNL LIGitTING CO!G) ANY.
A5 KInKPl.TniCR, LOCKIIART, JILL, 032ISTO?:ICR &
4e cliILuIP S, 1905 !! Street, N.W.,
Washington, D.C. 20036, 17 r e,.: v sun ted Dj ALAN ROY DYNtiER, ESQ., app. sated as counsel 16 On ochsir of SUFFOLK COUNTY.
1>
UILLI Ai4 P. PATTERSON, J R., ESQ., 7735 Cid JJ 3eorgeto.n Roac, 3etncsda, Maryland, appearec as coanscl 21 on cenalf of NUCLEAR ROGULATORY STAFF.
22 Alco present was SI!!ON K. CHEN, P0WCR A!!D 23 EN;3GY INTERNATIONAL INC., P.O.
1064, Beloit, Wisconsin.
24 Alau ;, resent was EUGENE MONTGOMERY, LONG ISLAND 25 LIGi: TING CO., 17 3 East Old C ountry Rd., H ick s ville, N.Y.
26 Also pr2sent as: 3CLANO ?A:0, TRANSA!iCRICA 27 D CL.W~AL, 550 85th Avenue, Oakland, California 94621.
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O!IRISTCUSE.,
J aa v i:.y aven fir:t dulf swor., testified a: f o llo'.. s :
3 EX/i'I:lATION O'l !!2. STROUPE 4
.ta. STROUJ O:
- .
- tr. Onristensen, a: I recall.shm 3
-c recessco yost dugosition yesterday, fou and I were s
tal:.ing aucut certain of tne coc.gonents that /cc.,ere in 7
- .e jrocess of ansifzia3, were we not?
2 A.
Cctreet.
Q.
I oclieve you nentioned that you were loc <.nq 40 6t cilinder neswe, pistons, roo 'oearings, crankshafts, il cylinwer aloc43, and liners, I belie ve.
12 A.
Ics.
13 0
Lo yoa recall anftning else that you. men tiene.-
1, thst ;oa aere sefinitely leo:ing at cignt noe?
15 A.
I tn in r. that cciapletes tne main list c~ :nin;,
16 c a.a t I saa losk i:'.g a t, uu t I believe I mentioned 17 yesterde I woulc ico.t at anytning if I consiected it s
id r ele van t.
Is Q.
I uricorstand anat.
All I'm asking fou rignt 20 now is what you're in the ;:rocess of loor.ing at in terra:
21
- of tne components as of today.
22 A.
I'm Jorry I cocidn 't hear foe.
23 iin. STROUPE:
Let the record reflect counsel is ma'ing noise.
24 n
23 NR. DYNNER:
Let the record snos -- All right.
46 P.R. 97D&to"*
q.
Let me re est the qacstion. As of r
27 to:tay, P rof essor Chr istensen, these are the components 2b that jou are worr.ias on analyzing; is that not corre:t?
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1 A.
COrrdOC, 'f e s.
2 30.,
sir, can I ask fcu wita regard to cylin.ier 5
a e o:.3, 4r.et you na ve done in terms of looking at data, 4
r t,7o r t s, or otaur information foc nave received or any 5
faulo tr i,as J oa :.a ve toren to sadcavor to analy s tne a
ef.inaut heads on the TDI closelo?
7 fin. DY;;;iER:
Can we na ve one question at a time, e
,. lease?
3 i:2. STROUPE:
Q.
Do you uncorstand the question?
10 A.
I encerstand the question.
11 il2. DYNNCR:
It's a multiple question.
Are you 14 cer.ing him asoat field trips? Are yoc as: ting him about iJ Lata? A re you asking nam aoout reports? Please ask one 14 question at a tine and he can respos.d to each question 13 d e,u r a t elf.
lo Q.
Mcaid you tell cc about tne data you reviewed
. 'l wita r:gord to cilinder heads.
As A.
Yes.
The drawings of tne cylinder neads.
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Any other data that you can recall reviewing?
20 A.
I' ve also looxeu at the component parts wnich 21 e.a xe the assembly of tne cylinder head.
22 Q.
Wnat parts wouls those be, sir?
23 A.
That was valves, valve strings, valve guides, 24 acAting location.
I tning tnat's about all the areas l -
25 the t I have given attention to.
la 2
Can you think of any other cocuraents or data 27 that foa've looked at?
26 A.
Yes.
I've looXod at re orts fron ?aAA, c
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I na vu looked at input renorts f ro.t
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Do you ae ve any recollection, t.ir, ac to vaat
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ste r.:sni;. linec you have loo;.en at input ressorte fron?
t it
.3 A.
I clain( ane was - I can't recall ita nan:e 4 a-4 a c ia.any.;ases in deustori.
I thinK the otner one
.s uc Jnitet. 0:stes :;t. eel.
f t.e n, I've had documents - I 2d' cGuida't c.ention twe aource of the ciocJcients nc'. - w.-ica 27-
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' nd you can 't recall what those wero?
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1 Q.
A 2
MR. DYNNER:
He Just said he couldn 't recall.
3 MR. STROUP E:
That 's wnat I'm trying to confirm.
4 IIR. DYNNER-The witness said he couldn 't recall, 5
and you tnen say you can't recall.
It's been asked and, 6
anceered.
7 MR. STROUPE:
I'm going to ask it again.
6 Q.
Is that your answer that you can 't recall?
9 A.
I can't recall the origin of the documents or 10 wnen I received them.
11 Q.
Dcos the name Falcon Shipping bring anything to 12 your mind?
13 A.
Y es.
That brings to mind immediately that I 14 worked on them when I was at Cove Shipping and they were 15 tue MSC ships.
They were originally of that name, the 16 name you just mentioned.
17 Q.
Could Falcon Snipping Company be the shipping 18 company you obtained data on f rom Houston, Texan?
19 A.
I can't recall whether that was the name of the 20 company now.
21 Q.
Have you taken any field trips or visits to any 22 places with regard to obtaining information as to 23 cylinder heads?
24 A.
Yes.
I think I can -- Yes, I can recall a 25 visit to Houston, but I can 't recall whether it was on 26 this matter or whether it was another ::tter cc=:ti=0 : *O.
27 Q.
Do you recall whether a Mr. Dennis Eley 26 accompanied you on that trip?
TOOK E3 & ANTZ 681 Market Street San Francisco 94105 415/392-0650
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A.
No.
I haven't oeen on any trips, only to '
2 Wasnington, with Mr. Eley.
3 y.
Have you ootained f rom some source, P rofessor i
4 Christensen, a design drawing of the cylinder heads on L
5 the TDI Shorenam diesels?
6 A.
Yes.
The drawing we received was wnat I would 7
consider a working drawing, and I think that came to me a
from TDI via a rather roundabout process.
Eventually it 9
arrived.
l 10 Q.
Do you know, sir, whether that working drawing 11 is a drawing of the modified cylinder head?
12 A.
There were --
13 MR. DYNNER:
Excuse me.
Do you know what hc means t
14 ny modified cylinder head?
15
- !R. STROUPE:
Q.
Do you understand the question?
16 A.
Yes.
I was going to answer it in respect to 17 the fact that there were, if I can recall correctly, le amendments shown on that drawing, in the normal drawing 19 procedure, which would be used in the drawing office.
20 Thcre were amendments shown on the drawing.
l i
21 Q.
Do you recall, P rofessor Christensen, whether 22 tnose amendments had any date written upon them?
23 MR. DYNNER:
I'm going to object to this line of I
24 questioning, Mr. Stroupe, unless you can show the witness 25 the drawing you're referring to.
If you're going to ask 26 him detailed questions aoouc une drawing, it 's' only 27 commonplace fairness to let his look at the drawings so 28 ne can answer the questions properly, i
TOOK ER & ANTZ 681 Market Street San Francisco 94105 415/392-0650
173 l
!!R. STROUPE:
Mr. Dynner, I do not have access to'
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2 tae drawing, No. 1, and, N o. 2, I'm trying to determine 3
wha t P rofessor Christensen has looked at to formalate any 4
opinions that he nas.
To the extent he cannot r e menbe r i
5 chings, he is certainly free to tell me he cannot 6
remuascr, but I think I am entitled to know wnat he has t
7 looked at and what he recalla of what he has looked at.
8 MR. DYNNER:
All you're doing is testing his memory 9
about the details of a complex and detailed drawing which 10 I don't think anybody can be expected to remember all the i
11 cetails about.
So with that caveat, you can probe the 12 depth and recesses of his formidabic memory. You can go 13 ahead and answer, if you can recall.
t 14 THE WITNESS:
A.
The answer I was going to givet 15 At Dest I can remember tne main points on drawings.
I 16 cannot remember in detail the amendments because I've 17 been looking at so many drawings.
18 MR. STROUPE:
Q.
Can you recall anything else that 19 you have looked at in an effort to assist you in
(
20 formalating an opinion on the cylinder heads?
I
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21 A.
Yes.
I' ve been in and checked details from the
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22 ASTil books on materials, mainly to get the physical 23 properties of the materials.
I' ve ref erenced back to t
24 that.
I can't rememDer the actual figures I got of this l
25 now.
I looked up the likely stellite alloy which would 26 he'= kaen ased on tne valve f acings.
I looked at the 27 cross sectional areas of cooling water passages.
I 3
l 28 looked at the inlet points for the cooling water to the TUOd ER & ANT:
681 Market Street San Francisco 94105 415/392-0650 1
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1 cylinder n'ead.
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I thinK that about sumnarizes what I've looked at on 3
the cylinder head crawings.
4 Q.
Let me ask you, sir, when you indicated in your 5
testimony that you looked at cross sectional areas of 6
water passages, did you look at an actual cylinder nead?
i 7
A.
Not at an actual cylinder head, but I can read a
a drawing.
I can assure you on that I do,n't need to look 9
at the cylinder head to get an idea of what the drawing 10 tells me.
11 Q.
P rofessor Christensen, have you been able to 12 come to any opinions or conclusions, whether they be 13 preliminary or final, with regard to the reliability of 14 the cylinoer heads on the Shoreham ZDGs?
15 A.
I've made some preliminary conclusions.
Imay l
16 add that I nevet ever make final conclusions because one 17 is always getting new data to add to things, so one is
[
18 elweys upgrading one's ideas in technical matters.
One 19 may form an opinion about a certain point up to a certain l
20 time anc that is the end of the input information.
If i
21 later information comes up, one may amend one's ideas.
i, 22 Q.
Could you tell me, sir, what the preliminary 23 opinion or opinions that you have made are with regard to i
24 the cylinder heada?
25 A.
Yes.
I don't think that they're suitable for 26 the jou whien they have to do.
27 Q.
And what is your basis, sir, for that i
28 conclusion or opinion?
TOOKER & ANTZ 681 Market Street San Francisco 94105 415/392-0050 l
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175 1
A.
' General proportions of the parts.
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2 Q.
Which parts, sir, are you talking about?
3 A.
Well, I'm looking at the cooling, I'm looking 4
at fire deck thickness, I'm looning at the total heat 5
11oerated in thg cylinder, and then wondering why they 6
never ever changed the design for the higner posered 7
ratings which they have on that engine now.
I ha ve 8
compared it with the designs of engines.
9 Q.
Excuse me, I didn't hear that.
10 A.
I have compared the design of this head with 11 the design of other engine heads.
12 Q.
What is your concern, Professor Christensen, 13 relative to tne heads as to cooling?
14 A.
I'm concerned possibly with sooe of the water 15 velocity in the way of the higher temperature parts on 16 tnc exhaust side of the head.
17 May I go on?
18 Q.
Yes, sir, by all means.
19 A.
I'm also concerned with the actual heat flow 20 rates through the cylinoer head, which could be 21 ascertained to some extent if a plan had been drawn up 22 showing the isothermals through the cylinder head 23 material, particularly in the way of the fire deck area, 24 and the exhaust valve pocket area.
25 Q.
Why are you concerned about this, P rofessor 26 Christensen?
27 A.
Because tue fact arises that in much of the 28 data that I've looxod at on exhaust temperatures, I find TOCKER & ANT: 681 Market Street San Frcqcisco 94105 415/392-0650 l
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tnat originally tne allowable exhaust temperature on that a
ungine has been stated to be 1,050 by the engine builders 3
and tncn at some later time was upgraded to 1,100 degrees 4
F.
For an exhaust valve pocket, the construction that is 5
shown on the TDI engines, I would consider that the 6
wxnaust valve pocket there and the cooling of the seat 7
was totally inadequate for 1100 degrees P.
8 3
How. Professor Christensen, would you determine 9
the isothermal of the head?
10 A.
There are various ways of doing that.
It can 11 De dealt with by plugs, wnich are screwed into the -- You 12 make drillings.
I'm sorry, I'd like to go back to base 13 one.
14 You make drillings in certain parts of the cylinder 15 head, with a flat bottom drill preferably. You then 16 insert a plug with a certain degree of hardness, which is 17 susceptible to change in haraness by the temperature to 13 which it is elevated.
After the engine nas been tested, 19 the plugs are removed, and the hardness is tested by one 20 of the standard methods f rom wnich they can get the 21 change in hardness related to the temperature to which 22 that part has been subbed.
That is one way.
23 Another way is drilling and the insertion of 24 thermocouples.
25 Another way is drilling and using pellets over 26 varying temperature melting points so that tha** ara 27 inserted and one can then, from the results of these 2d tests, draw the isothermais.
TOCKE3 & ANTt 681 Market Street San Francisco 94105 415/392-0650 O
177 1
I am surprised that no isothermals have been 2
produced for un to exam, not only in the areas of the 3
cy A inder covers, but in the areas of the piston crown.
4 The fact whether Enese isothermals exist or not, I don't 5
knos.
If they nad been produced for us, it would ha ve 6
been mucn easier for us to make some assessments.
It 7
woulo also nave been caster for the engine builders to 8
make some assessment of the thermal loading on these very 9
very critical parts.
10 v.
Does that complete your answer, Professor 11 Carlstensen?
12 A.
It certainly does.
I'm sorry I'm long-winded, 13 but that is quite a process to trace isothermals.
14 Q.
Have you made an attempt, P rofessor Christensen, 15 to determine satisf actorily to yourself what the 16 isothermals of the heads are?
17 A.
No.
With the data that I have available, it 18 would be impossible for me to come to any real conclusion, 19 but one may say that around the exhaust valve pocket area, 20 from the form of' construction, that there must be a high 21 state of thermal stress around that pocket from the 22 temperature througn the exhaust games passing through.
23 I would expect to have seen a separately caged valve 24 in a need of this type wnich is subject to the pressures 25 wnich have been mentioned f rom the f act that the valvo 26 case gives very adequate su yott to the gas pressure e
27 loading on the head.
It is possible with a cage valve to 26 introduce cooling right down to the valve seat 's sur f ace T00KZ3 & ANTZ 681 Market Street San Francisco 94105 415/392-0650 m
179 1
so that th'e valve seat is maintained at a much loser ~
2 tusape r a tu re.
3 I am surprised, wnile tnis is irrelevant here, it 4
nac some rulevancy that they have not done that on their b
eng tnes whien are barning heavy fuel that have the same 6
configuration of vaive or possibly some rotators or 7
things like that I don't know - f or the hea vy f uel, and 8
I would have liked to have seen those components which 9
eney used for heavy fuel engines incorporated in an 10 engine which is going to be used in a nuclear power plant 11 waere a very very hign degree of reliability is a 12 requirement.
yes answer or a no answer, P rofessor 13 Q.
Is that 4 14 Christensen?
15 Ita. DYt!NER:
The answer stands as it is.
He doesn't 16 have to answer yes or no to a complex question aoout a 17 difficult engineering issue.
la MR. STROUPE:
Mr. Dynner, I think I asked a very 19 simple question as to whether or not P rofessor 20 Cnristensen had determined satisfactorily to himself what 21
' the icothermals on the cylinder heads were.
I think I'm 22 entitled to a yes or no answer and he is perfectly free 23 to explain his answer af ter he gives se that.
I think he 24 has explained his answer.
I would now like a yes or no.
25 MR. DYNNER:
I think you can tell from his answer 76 west te was, and I just want the witness to know he can 27 answer if ne can, if it's possible to give a yes or no 28 answer to that question, but you can 't force him to, tir.
TOOKER & ANT:
681 Market S treet San Francisco 94105 415/392-0650 L
179 1
Stroupe.
2 MR. STROUP":
If the witness per.91sts in giving 3
answers as he 's given this morning, Mr. Dynner, de 're 4
goins to be here till the end of time.
5 MR. DYNNER:
Ha 's giving very accurate and complete 6
and relevant answers to your difficult questions, Mr.
7 Stroupe. You well knos this is not a simple area.
It 's a
not s question of sitting down and having the witness say 9
yes or no to all your questions.
He 's being completely 1G responsive and trying to the best of his ability to 11 ansser your questions.
I think he 's doing an excellent 12 jon.
13 MR. STROUPE:
That's your opinion, Mr. Dynner.
14 MR. DYNNER:
I t certainly is.
15 MR. STROUPE:
You are perfectly entitled to it.
I 1G woald like c yes or no answer to that question.
17 MR. DYNNER:
You can answer, if you 're able to.
18 THE WITNESS:
A.
Could I have the question again, 19 because --
20 MR. STROUPE:
Yes, sir.
I will undertake to try to 21 give you the question again.
22 Q.
Have you been able to reach a conclusion 23 satisf actory to yourself, Professor Christensen, as to 24 wuat the isothermals on the head of the cylinder nead are?
25 A.
I have just stated the reasons why I cannot 26 arrive at what I would consider a yes or no answer.
The 27 answer is that I have enough technical expertise to form 25 a very valic opinion in this area which is a very complex TOOK ER & ANT 2 681 Market Street San Francisco 94105 415/392-0650 O
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1 area to diacuss.
You cannot give yes and no answers to 2
complex technical questions because we must view the 1
J thing over a very very wide spectrum. At one end of the l
f 4
spectrum the answer may be yes; at the other end of the j
5 spectrum, the answer may be no.
i 6
Coming oack to the valve pockets, there is a serious l
7 problem whicn arises out of manufacture, and that is that 6
castings change their size wnen they cool off. The valve f
i i
f 9
pocket area there has a curved surf ace at the bottom to 10 allow for tne cooling of the casting in the sold, without i
11 fracture occurring or without cold tears occurring.
This 12 is done by making a curved form or a dog leg at the f
13 bottom of the valve pocket.
Where you have a dog leg, I
f 14 you immediately create a bending moment and you have a 15 high stress region tros the areas of that bending moment le wnere the dog leg is.
When you have an insert valve, you i
17 can overcome that problem with the material which is in i
18 the detachable valve, and this I consider a factor wnich 19 tne designer is on the borns of a dilemma with.
He has f
20 to face whether he's going to fit a valve pocket, which 21 will increase the cost of the engine, or he has to say 22 I'a going to make it that way and run the risk of an l
23 inherent fault with the design which comes about from the 24 manufacturer.
I 25 Q.
Are you saying, sir, that that is an inherent i
2G fault in the design of the cylinder head?
27 A.
It is, yes.
28 Q.
Have you formed an opinion, Professor i
TOOKER & ANTZ 681 Market S treet San Francisco 94105 415/392-0650 I
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1 Christensen, as to what a safe isothermal would be for 2
these cylinuer heads?
3 A.
One cannot talk in terms of safe isothermals.
4 One nas to look at the crowding or the spacing apart of 5
the isothermals:
wnether they are horizontal, whether 6
they are radial.
One cannot give a simple answer to a
{
~
7 complex question like that.
8 Q.
Have you formed an opinion, Professor 9
Christensen, as to what is an acceptable isothermal for 10 these hesds?
b 11 A.
No, I h ave na isothermals so, therefore, I 12 don't know whether they 're acceptable or not.
I can only i
13 form opinions on what the things would possibly be like l
14
' from the design as I review it on the drawing.
15 Q.
.You can't give me an opinion, sir, based on i
16 your experience as to what a safe isothermal would be for 17 this c/linder head?
18 MR. DYNNER:
He's answered chat question twice, Mr.
19 Stroupe, and I think you just keep asking the same l
20 question over and over again, using slightly dif ferent 21 phraseology. The question 's been asked and answsred.
If 22 he wants to answer it or can answer it for the third time, j
23 he can certainly go ahead and try.
24 MR. STROUPE:
I want to put on the record that I 25 oca't think I've asked the question more than twice.
I 26 have asked it twice because, in nf opinien, I get what at 27 best was an evasive answer, and I think I am entitled to 26 an answer.
i i
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1 MR. DYN;3CRs It was not evasive.
It was responsive.
2 Yoa asked the question first, is it safe?
Professor 3
Cnristensen explained wny that could not ce determined 4
ano why your terminology safe was inaccurate. You then 5
askea the question, were they acceptable? He answereal 6
that question.
Then you sent back and said, is it safe?
7 Nos, tnat's not evasiveness on the witness ' part.
I t 's 8
repetitiveness on your part.
9 MR. STROUPE:
That is not what I said, Mr. Dynner.
10 Your memory is faulty.
11 MR. DYNNER:
The transcript will show that.
12 MR. STROUPE:
I indicated I wanted him to give me an 13 opinion, if he could, based on his experience.
14 MR. DYNNCRs Well, you certainly can ask those 15 quustions, Mr. S troupe.
I'm trying to ask you to please 16 not como cack and ask the same question over and over 17 again.
Let's move on.
18 THE WITNESS:
A.
When you speak of safe isothermals, 19 could you givs me what you are really meaning in your 20 gaestion, because I don't understand wnat you mean by a 21 safe isothermal.
22 MR. STROUPE:
Q.
I'm saying acceptable and I'm 23 using your term isothermal.
24 A.
Wnen I speak of isothermal, there are many 25 isothermal lines on a drawing which are showing you lines 26 of constant temper-ture.
From these lines of constant 27 temperature and the direction in which they flow, their 28 closeness, their spaces apart, one can formulate an TOOK Ea & ANTZ 681 Market Street San Francisco 94105 415/392-0650 w
9
IS3 1
opinion.
~
=
2 I am surpriseo, as I c.entioned earlier, that the 3
engine builders have not studied the isothermals in tne 4
nead occause if they had done so, I'is sure they could 5
have produced e document for us and then I would have 6
ceen aole to say whether they are safe or otherwise.
I s
7 4m not being evasive here.
I don 't have to because I 6
know my sub3ect.
9 Q.
Professor Christensen, I think you stated 10 earlier in your testimony, did you not sir, that whether 11 the change in exhaust gases temperature went from 1,050 12 degrees to 1,100 degrees Fahrenheit, that concerned you 13 Decause you considered that temperature to be unsafe.
14 Isn't that basically what you said?
15 A.
I didn't say that.
16 Q.
What did you say?
17 A.
I saio that that temperature was a very hign 18 exhaust gas temperature for the configuration of the 19 design of the cylinder head.
That is what I said or 20 words to the same meaning if they were dif ferent words.
21 Q.
Was that answer based at all upon any 22 assumption that you made with regard to isothermals of 23 che cylinder head?
24 A.
No, it was not.
It was based on the ability of 25 a material to hold its strength at these elevated
?. '
- =amperatures.
Isothermals would play some part in it, 27 out the part that is played is the auility of the 28 immediate pocket around that base connection between the TOOK ER & ANTZ 681 Marnet Street San Francisco 94105 415/392-0650 B
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184 1
valve pock'et anc the fire deck on the heat flow rates' in 2
that area.
They've cut the particular thickness down 3
enere which does tend to reduce tne heat flow rates.
4 All these factors are the f actors f rom which the i
5 isothermals are drawn.
It is quite a complicated subject 6
because we're dealing not onl/ with thermal stresses, wo 7
are also dealing with mechanical stresses arising out of 8
pressure.
9 In some cases, if you have isothermals, accurate 10 isotneraals, you can say whether the thermal stress will 11 aid in mechanical stresses or whether that will become 12 additive or suetractive, which f rom that you can f orm an 13 opinion.
Unless you have the actual isothernals of that 14 head, one can surmise, but the accuracy of any surmising 15 in based on the input data ycu can got in the first place.
16 Q.
Have you requested of anyone, P rofessor 17 Christwnsen, the isothermal data that you've indicated 18 you desire?
19 A.
It was requested and was recorded, I think, in 2G a letter to tne concerned parties, and I think it's on 21 record somewnere that they had asked for this data.
22 Q.
And --
23 MR. DYNNER:
It was requested on behalf of Suf folk 24 Coanty.
It wasn't necessarily requested by Professor 25 Christensen directly.
But, Mr. Stroupe, you 're well 26 aware of the County's request for discovery, and I think 27 if you examine them, you'll find that this material would 28 have been covered by the documentary requests which were TOOSER & ANT 3 681 Market S treet San Francisco 94105 415/392-0650
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185 1
given to LILCO.
2 MR. STROUPE:
Q.
Do you know, P rof essor Christensen, 3
that the isothermal data is not contained within the six 4
Doxes or so of data that you testified yesterday that you 5
had 6
A.
T he --
7 Q.
Let me finish, Professor.
The court reporter 8
c an ' t take down both of us talking at the same time.
9 Do you know the question now?
15 A.
The question was are the isothermal --
11 MR. DYNNER:
Let him finish the question.
He hasn't 12 finished the question. He just said he didn't finish and 13 then he askec, do you know the question?
It's a little 14 trick. Let him finish the question, Professor, and when 15 ne signifies he's finished, then you can answer.
16 MR. STROUPE:
There's no trick intended, Mr. Dynner.
17 MR. DYNNER:
I didn't mean to say that in a IU uerogatory way.
19 hR. STROUPE:
Q.
What I'm asking you, P rofessor 20 Christensen is, do you know, sir, that the data that you 21 nave indicated that you desire with regard to the 22 isothermals in the cylinder heads is not contained within 23 the boxes of documents that you indicated yesterday were 24 in your possession?
25 A.
I am reasonably certain that that material is 26 not within the material which I have received f rom nr.y 27 source I can recall receiving a document from which dealt 23 with some investigation into temperatures of piston crown TOOKER & ANTZ 681 Market Street San Francisco 94105 415/392-0650 9
186 1
ms ter ial, 'bu t this was found waan we were investigating 2
uccuments here at TDI, and I have since testified that 1
3 ws.ile tnat was not exactly wnst I would look for in terms 4
of isothermals of a piston crown, it certainly shows that j
5 TDI have some concerns for the temperatures experienced 6
within their pistons.
7 MR. DYNNER:
Mr. Stroupe, let me interrupt for a 8
moment. We can do this on the record or off the record, 9
but I'd like to have a little discussion with you about 10 the seating arrangements.
11 MR. STROUPE:
The seating arrangements?
12 MR. DYNNER:
Yes, during this deposition. Would you 13 like to stay on the record or do you want to go off the 14 record?
15 MR. STROUPE:
It makes no cif ference to me.
16 MR. DYNNER:
Let's go off the record for a minute.
t 17 (Discussion off the record.)
18 MR. STROUPE:
Q.
Professor Christensen, I believe I
19 you indicated, did you not, that you also have a concern 20 aDout tne fire deck area of the cylinder heads; is that 21 correct?
22 A.
Correct.
23 Q.
What are you concerned about with regard to the 24 fire deck area?
25 A.
The thickness variations in the fire deck area.
26 That is the main concern I have. and the effects on 27 thermal stress, the effects on mecnanical stress and the 28 creation of stress raiserc on the boundaries between the TOCKC3 & ANT: 681 Market S treet San Francisco 94105 415/392-0650
187 i
1 tnic4 and'the thin.
j
~
2 We uon't know whether the bouncary is a quick f
J cransition or wnether it is a nico easy transition.
Witn 4
that knowledge lacking, we must obviously in an engine 5
which as going to be used for a hign degree of 6
relismility, take the worst case as we always do in l
7 ongineering, and there we would assume it was a quick
[
8 transition and was therefore dangerous and was creating a 9
heac which was very unsuitable for an engine where a high 10 Jegree of reliaDility is required.
11 Q.
You do not know, sir, that that is in fact an 12 oxistent condition with regacd to the cylinder heads?
13 A.
When you don't know anything in engineering and 14 safety is involved, we must always look at it from the i
15 worst came point of view, not the best case, because i
16 we're running risks if we take the best case.
17 Q.
Yoa're taking a worst case assumption, ia other 10 words?
19 A.
I always do in safety.
I think this case out 20 yesterday when I was speaking.
21 Q.
Do you know, P rof essor Christensen, what TDI's 22 permitted range of variation is in the thickness of the 23 fire deck?
24 A.
I think I have seen figures.
I may be 25 misquoting f rom memory, but I think the figures that I 26 Pave seen vary hetueen.4 of an inch and.83 of an inch 27 on a thickness of nalf inch, and I think the tolerances 28 are far too great for an important piece of machinery TOOKER & A!!T" 681 Market street San Francisco 94105 415/392-0650 I
i 6
i Ida 1
sacn as this.
2 Q.
Is there any other concern that you have with 3
the fire deck area of the cylinder head?
4 A.
Yes.
The variation in the angular distance 5
setween the cylinder head f asteners is such that you are 6
tencing to create a bending moment on the fire deck when 7
the head is bolteo down under normal conditions for e
operation.
The fact that it has created an initial 9
stress, which is compressive on the bottom, is to some --
10 I've got to snink this out.
It's been some time since I 11 f ormulated in this my mind -- Yes.
q 12 The stress on the base would be compressive.
Tha t 13 is, increasing the tensile stresses on the cool side of i
14 the fire deck, which can be perhaps slightly helpful, but l
15 tne over.11 ef fect I think is bad because of the fact 16 that we co not nave a uniform circumf erential stress 17 cistribution around the head.
le Q.
Have you had an opportunity or an occasion, 19 Professor Christensen, to measure the actual stresses, i
20 secnanical stresses, bending moments on the fire deck?
i 21 A.
No.
I never have and I don't think anybody 22 else has f rom the point of view of the f act that no 23 figures have been produced in this area.
24 Q.
I believe you indicated, did you not, P rof essor 43 Cnristensen, that you also had a concern about the heat 16 lioeratou in the cylinder?
27 A.
Correct.
26 Q.
What is that concern, sir ?
700KEA 6 AN7E 681 tarket street San Francisco 94105 415/392-0650 4
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189 L
1 A.
'The liberation of heat is another name for the 2
thermal loacing on the engine.
The tnernal loading is 3
cirectly related to heat liberation during the combustion I
4 process.
5 Part of the heat liberator goes into useful work.
Tne other part of the heat liberator goes out in the G
7 exnaust and part of it goes into the cooling water.
T he 8
part wnich is going into the cooling water is giving you 9
some idea of the thermal stresses which are coming on the 10 cylinder head fire deck.
11 Q.
Wnat is your concern with the heat liberated in 12 the cylinder specifically?
13 A.
My concern here is that I would have considered.
14 for the power that this engine is developing, that it 15 would have required a whole new design of the cylinder l
16 head. Tnia is related w"olly to the, areas of thermal t
17 loading.
18 Q.
Do you know, sir,1or have you -- strike that.
19 Do f ou know the amount or quantity of the heat that 1
20 is liberated in the cylinder?
al A.
I did do a punchout of figures on my calculator, 22 jos.
I can't recall what the figures were.
I looked at 23 thus relative to another engine for comparison purposes 24 and they appeared hign to me.
25 Q.
Do you know the amount of the heat liberated in 26 the earlier model TDI engine?
27 A.
It would be obviously considerably less.
I 24 dion't put a quantitative value on it, but looking at it, l
T03RE3 6 ANT 2 601 Market street San Francisco 94105 415/392-0650 I
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i 130 1
if you ine'rvase the poser, onc must increaso the tuv1' 2
consusption in a similarly relative manner, not i
3 necessarily going to collow a straight line law, out as i
i 4
you douole the power, you must couble the heat liberated, 5
and you are increasing the thermal loading on the engine,.
6 Where this has been done by other engine builders, 7
they have ordered the whole of the construction 4
arrangement of the cylinder need and other parts of the 9
up;er end of the cylinder.
10 Q.
Is it always true, Professor Christensen, that 11 when you douole the power in an engine, you double the 12 nvat tnat is in tne cylinder?
13 A.
Approximately correct, yes.
i 14 Q.
Are there ways of increasing the horsepower of 15 an engine, Professor christensen, witnout increasing the i
16 fuwl injected?
17 A.
We would all love to know if that was possible.
la That is the engine designer 's ais, to increase the power 19 without increasing tne thermal loading, without l
20 ancreasing the fuel consumption.
21 Q.
Is that possible?
{
22 flA. DYNNER:
It's a theoretical question, of course.
23 Tno witness can answer if he wants to delve into the 24 theoretical possibilities of engine design and 25 development, but I think that's hardly relevant to the l
26 issues at nand.
27 MR. STROUPE:
Q.
Do you have an opinion, P rofessor 28 cnristensen, as to whether it's possible to increase the l
i TOCKER & Al;T 6 81 Market S treet San Francisco 94105 415/392-0650 I
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s 3 ~
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__________________u______________
191 1
horsepower of a given engine without increasing the
~
2 thermal load or the heat lioerated in the cylinder?
~
3 HR.'DYNUER:
'I object to the form of the question.
4 Mr. Stroupe, you and I both know that anything is 5
possible.
6 MR. STROUPE:
Q.
Can you answer the question?
^
7 MR. DYNNER: Try to formulate tr e question in a more 8
understandable way.
t 9
MR. STROUPE:
I'm not going to reformulate the 10 question.
I asked the question as I asked it.
11 MR. DYNNER:
If the witness wants to delve into 12 wnat's possibla and what 's.not possible, it's all 13 con]ecture and. speculation.
He can try to answer the 14 question.
I will not instruct him not to answer.
15 MR. STROUPE:
You say you will instruct him not to 16 answer?
17 MR, DYNNER:
I will,not' instruct him not to answer.
l L
18 THE WITNESS:
Woald you read the question again.
19 (Record read. )
20 THE WITNESS:
A.
If you are going to increase the 21 horsepower of any given engine - we're speaking of the 22 same engine - the only way you can do that is by
[
23 increasing the f uel consumption.
When you increase the l
i 24 f uel injection to obtain more power, you are increasing f
I 25 the heat liberated.
26 Q.
Other then what you'wa *estified to this
(
27 morning, do you have any other concerns with regard to t
28 the heat liberated in the cylinder?
i P
TCOXCR & ANTI 681 14arket S treet San Francisco 94105 415/392-0650 I
i i
l
...f
192
.Yes.
In the areas of the piston crown and in 1
A.
2 the areas of the upper part of the cylinder liner.
3 Q.
Does that rela te to your concerns about 4
cylincer heads themacives, because that 's the context of 5
my question.
6 A.
The way that I'm understanding your question is, i
7 is the neat liberated affecting these parts in some 8
relationship?
Is that what your question --
9 Q.
No, sir.
My question is, you gave me a list of 10 concerns that you had, I belie ve, about the cylinder 11 heads.
12 A.
Correct.
13 Q.
Ano I am asking you if there are any other 14 concerns or bases for your concerns aeout the heat 15 liberateJ in the cylinder that af fects your opinion about 16 tne cylinder heads?
17 A.
Not directly because, as I've mentioned earlier, 18 enere is a very very fine interrelationship between these 19 parts.
If you liberate more heat in the combustion area, 20 then' you have got to deal with a greater thermal loading 21 on the upper part of the cylinder liner and a greater 22 amount of thermal loading on the piston crown.
23 Q.
I believe you also indicated to me that you 24 were concerned about there being no design change for the t
25 higner power rating.
N ow, is the basis for that concern 26 reisted te Nh:t we have just gone over or are there other 27 factors that concern you about there being no design 2d cnange?
TOOKCR & ANT" 681 Market S treet San Francisco 94105 415/392-0650 l
133
~
it's very hard for me to say waen.
I've 1
A.
- Well, 2
had those concerns right from the start when I was 3
reviewing the case history of these engines.
When I
'4 reviewed the case history of these engines in the marine 5
field, I've had an enormous amount of concern as to what 6
tney did with the engine to increase the power.
7 Looking at trade brochures and cross sections of the I
6 engines which have been produced in various places before 9
I nad access to drawings, I was concerned that no readily i
lu apparent design changes had been made to increase this 11 pow e r.
I would have expected to have seen certain things 12 there increase the capacity for keeping the fire deck 13 cool in higher rated engines. What I ha vr known in the 14 past from other engine builders who have increased power 15 by increasing the capacity of the fuel pump to inject 16 more fuel, the end result has been usually disastrous.
17 Q.
Disastrous in what respect?
18 A.
Disastrous in very very poor reliability due to 19 increased thermal loading.
In fact, we may say that 20 around - how many years ago, I'd have to cast my mind 21
- bacx - possibly in the order of ten years ago we had 22 reached a plateau where we could not push up the power of 23 a cylinder in a slow speed engine any more.
This came 24 about from the mechanical stresses or the boot stresses 25 on the cylinder liner and the fact that we had a problem j
26 in dealing with the increased thicknesses of the liner I
27 _
and maintaining the temperature of the inner surface of 28 the liner cool.
TCOKER & ANT 2 681 Market Street San Francisco 94105 415/392-0650 P
194 1
out of tnis came the bore cooling concept.
We shy 2
increase the cooling by increasing the air flow througn 3
the cylinder head, in increasing the air flow througn the 4
ccanustion space in a four-stroke engine by playing 5
around with superqbarger capacities, making the exhaust 6
valve open earlier.
There are many things we can do, but 7
you always finish up with the increased thermal loading.
8 We may do things with the turboblower to increase 9
the air flow through, which will help, but eventually we 10 come to the f act that we' ve got to take more heat away in 11 tne cooling water.
Out of this arose the bore cooling 12 concept, both for the upper parts of cylinder liners, for 13 cylinder covers and these areas which are subject to very 14 very high thermal loading.
15 I think that answers the question fully.
16 Q.
Is'that the disastrous consequences that you 17 referred to ?
16 A.
Yes.
Other companies have tried to upgrade 19 their engines by increasing the capacity of the fuel pump 20 and making what one could only call minor changes in the 21 turooblower capacity by playing around with overlap 22 periods when the exhaust valve opens.
But invariably it 23 has led to the loss of the good name of the engine 24 builder.
25 MR. STROUPE:
Can we that a break now.
26 MR. DYNNER:
Yes, certainly.
27 (B rie f recess taken at 10:4 5 a.m. )
28 Resumed 11:0 0 a.m.
TOOKER & ANTZ 681 Market Street San Francisco 94105 415/392-0650
195 1
MR. STROUPE:
Q.
Prof essor Christensen, I belie ve 2
you inoicated that you had made some comparison of design 3
of tne heads on the TDI engines with the design of heads 4
on other engines; is that correct?
5 A.
Correct.
6 Q.
What engines did you compare the cylinder heads i
7 on tne TDI engines with?
8 A.
I looked for engines with as near ratings and 1
9 size, rpm, which were as near to tnese engines as I didn't find any engine which was 10 possible.
I cannot 11 near to these, so I took a lighter loaded engine, if I t
12 remember correctly, and compared it with a lighter loaded l-13 engine and found, then, that much better cooling 14 arrangements would have been made upon the cylinder head.
15 Q.
Do you recall, sir, what engine or engines by 16 manufacturer's name you compared the TDI engine cylinder 17 heads with?
i 18 A.
No, I don't recall.
I could repeat the 19 cxercise, but I have access to diesel engine catalogs 20 going bacx over tne years and to a multiple number of 21 textbocks which give engine details, and I use these to l
22 cross reference back.
23 0
Do you have any general recollection, sir, as 24 to wnether the engine or engines you used compared with j
25 American manufactured engines or non-American 26 manufactured engines?
t
'27 A.
I looked at the American built Peal Stick l
26 (pnonetic) or Colt Peal Stick (phone tic), but although t
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that is American built, it is foreign design.
I did 'tanc l
2 a quic4 loo's at tne GMEMD engine, but again that was a 3
such higher speed engine sc, therefore, the things were 4
not relevant.
I think the nearect engine I came to it -
5 I'm quoting f rom memory; I might be nopelessly wrong -
6 but I think tne engine that came near to it was one of 7
the Mirries range made in Britain.
8 Q.
How is that s pelled?
9 A.
M-i -r -r e -s.
I think I' ve got the spelling 10 correct 11 Q.
Do you have any general recollection as to the 12 configuration of the Mirries engine?
13 A.
Yes.
It was a four-valve engine, the same as 54 tne TDI engine.
15 Q.
Was it an in-line engine?
10 A.
It doesn't really matter whether it's an 17 in-line engine or a V engine.
The head, the loading are t
18 things that count.
19 Q.
That's not my question, sir.
20 was it an in-line engine?
21 A.
These engines are made in both an in-line and V l
22 range.
23 Q.
Do you recall which one you used for comparison?
l 24 A.
The cylinder heads are identical on both 25 engines, V and in-line.
26 Q.
Do yon have any recollection, any further L
I 27 recollection, P rof essor Christensen, as to any other 28 engine or engines you used for comparison purposes?
l TOOKER & At:TZ 681 Market S treet San Francisco 94105 415/392-0650
197 1
A.
'N c.
2 Q.
What, if anything, cid your comparison indicate 3
to y ou ?
4 A.
Generally, that tne head was not suitable for 5
the loading that it had to sustain.
6 Q.
And what specifically, if anything, as a result 7
or this comparison you made, showed you that the head was 8
not suitable for the load that it had to sustain?
9 MR. DYNNER:
Asked and answered.
That was the first 10 question about thirty minutes ago, wasn't it, Mr. Stroupe, 11 or am I mistaken?
12 MR. STROUP I asked that, yes.
I am asking the 13 question now, Mr. Dynner, in the context of what he 14 learneo in the comparison.
15 11R. DYNNER:
Your question was not clear.
Thank you 16 for the clarification.
17 MR. DYNNER:
The question is what he learned by the l
18 specific comparison that he might recall.
19 MR. STROUPE: That gave his the opinio.: that the 20 head was not suitacle for the load that it had to sustain?
21 MR. DYNNER:
That contributed to his opinion, right.
22 21R. STROUPE:
If, indeed, it contributed to his 23 opinion.
I j
24 MR. DYNNER:
Go ahead.
25 THC WITNESS:
A.
The Mirries engine has detachabic 26 v:lvt: etica are fitted in pockets in the cylinder head, 27 ano I nad mentioned earlier that where you have p
l 28 detachable valves, you can get a lot of support for the l
I TOOK E3 & ANrz 681 Market Street San Francisco 94105 415/392-0650 l
199 1
mechanical' loacing on the fire deck from the insert v11ve 2
whicr. is put in there.
It does also mean that you can 3
carry a macn thicker upper deck and transf er loading from 4
ene tainner fire deck to a tnicker upper deck through 5
your valve pocke'ts because they act as columns or 6
supports to resist the maximum firing pressures which 7
come on the head.
8 Q.
Do you recall, P rofessor Christensen, what the 9
maximum firing pressures were on the Mirries engines 7 10 A.
No, I cannot recall.
I have such a mass of 11 figures in my head which I recall, but there is so much 12 variation in these pressures, that I couldn't even hazard 13 a guess, but I think it was of the order of the maximum 14 pressures I would have expected on the TDI heads, 15 somewhat of similar order, because I was looking for 16 samtlarities, as I explained earlier.
17 Q.
Have you had occasion, Professor Christensen, 18 to acquaint yourself with operating data or history of 19 ene Transamerica Delaval modified cylinder head?
l 20 MR. DYNNER:
Excuse me.
Could you clarify what you l
21 mean by a modified cylinder head? His testimony 22 previously, as you may recall, Mr. Stroupe, was that he 23 did not believe there were any design changes at all in 24 the TDI cylinder nead.
25 What do you mean ny a modified head?
26 MR. STROUPE:
Q.
Professor Christensen, do you know 27 whether the TDI cylinder head on the R-4 engine has been 28
=ucified cince the mid 1970 c?
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1 MR. D'YNNER:
dould you clarify your question? DC 2
you maan codified in design?
Do you mean modified in 3
manufacture? Do you mean modified in inspection?
4 l1R. STROUPE:
In any respect.
5
.4R. DYNNER: You can answer, if you understand the 6
question.
7 THE WITNESS:
A.
I understand tne question, yes.
o Yes, if I remancer rightly on the drawing that I 9
loosed at on the cylinder head, it may have been on that 10 drawing or I may have arrived at this information f rom 11 anotner source.
There was mention of the thickness being 12 increased on the closing plates covering the core holes 13 in ene cylincer head.
They had also welded those plates 14 on the outer circumference of the cylinder head.
So that 15 there was some support affordeo on the outer surface.
16 Tnat is I think the only - if we may call it that; it's 17 ocviously related to design - I think that is the only 18 design modification that I have been able to track back 19 on.
20 MR. STROUPE:
Q.
Are you generally aware or have 21 you generally acquainted yourself, Professor Christensen, 22 with operating experience or histories of the TDI R-4 23 cylinder heads?
24 A.
Yes.
I ha ve looked at this in the field where i
25 I think we shoald look at it, because we have the hours 26 run which will give us a good idea of how the thing 27 behaves long term and after all, we are interested in 28 long-term behavior rather than short-term behavior, and I TOCK ER & ANTZ 681 :tarket Street San Francisco 94105 415/392-0650
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feel enat'the recorc of the cylinder heads for the TDI 2
engines used in tae marine field is appalling.
T ha t is 3
tne only word I can uses appalling.
4 When I was in Europe, I heard of a thing which went 5
cn in the United States which was described as in-built 6
ousolescence, and I did really wonder if this was a case 7
of in-bailt obsolescence, so that one got an income from 8
wnat was nappening in the cylinder heads because it would 9
appear that people are making a living repairing cylinder 10 neads.
11 I must also say that when I walked through the 12 engine works, when I was here last July, one of the 13 things which did astound me was the number of cylinoer 14 heads whien were being manuf actured, when I knew from 15 records in the technical press that there were very few 16 engines on order at TDI.
The two didn't seem to bear any 17 relationship to me except that I just wondered whether it-18 was in-built obsolescence.
19 Q.
You used the ters, P rofessor Christensen, 20 appalling, I believe --
21 A.
I did.
in describing the experience you're aware of 22 Q.
23 with TDI cylinder heads and in the marine field, I 24 believe.
25 What do you oelieve is appalling about enese 26 histories?
27 A.
What is appalling is the financial load wnich 28 it has placed on the ship owner.
As an American citizen, TOOKER & At!T: 481 turket S treet San Francisco 94105 415/392-0650 b
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1 I?m very very interested in a good U.S. Merchant Marine, 2
and when you have a record like this, it doesn 't help the 3
ship owner in his international competition in the field 4
of shipping, and we do require good reliable engines.
5+
I can give you some reasons why I say this is 6
appalling.
Over the number of ships tha t I have been 7
responsible for over my working life, I think when I was 8
with Sugar Line, I only had occasion on one occasion to 9
repair a cylinder hwad.
The cause of this cylinder head 10 repair was a faulty fuel in3ector.
It didn 't make a lot 11 of dif ference to the exhaust gas temperature.
It was in 12 a ship with a manned engine room with a limited amount of 13 instrumentation.
The faulty injector allowed a bad 14 temperature distrimution in the head and the head cracked.
15 That is one head out of a fleet of -- I can't recall how 16 many engines we had now, but quite a large fleet.
B&W 17 cyltador heads:
I don 't recall of one failure with those.
le I go onck to f ailures of cylinder heads in the days when 19 they were made of cast iron prior to the enangeover to 20 cast steel, and then in those early days where diesel 21 engines were more experimental than they are now we did 22 run into problems between the temperature dif f erential i
23 between the air inlet pocket and the exhaust valve 24 pockets and that was the cause of some of the cylinder 25 head failures.
When, we went to cast steel with greater 26 strength to make the things thinner, I don't know if thic 27 succession of cylinder head failures had anything to 20 coopare with these engines here.
TOOKER & A!!?Z 681 Market Street San Francisco 94105 415/392-0650
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Q.
'Wnat in the operating history or experience T 2
that yoa're aware of, sir, with regard to the TDI J
' cylinder neads?
(
4 A.
That too many of them have to be repaired.
5 Their expected life is very very snort.
6 Q.
Do you 'know generally, sir, what the hours of I
7 service have oeen upon these cylinder heads that had to l
r 8
be repaired?
9 A.
Yes.
A very very low number, a low digit in r
10 front of the thousands of hours.
I think some of them, 11 1,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />, some of them in the order of 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.
12 Q.
Do you know, sir, whether these cylinder heads 13 you're speaking about generally were of the original 14 design for thu R-4 or the modified design?
15 HR. DYNNER:
You haven't ascertained whether there t
16 was a modified design and what he means by it and what 17 you scan by it.
Perhaps you would clarify that.
18 MR. STROUPE:
Mr. Dynner, I believe the witness 13 testified a few minutes ago he was aware of changes that 20 were made in the cylinder head from the drawing he looked 21 at.
22 MR. DYNNER:
Have you established what you've 23 cefined?
Is that what you're calling a modified design, f
24 the drawing that he is seeing?
23 MR. STROUPE:
I as asking him, based on the 26 etttement he made, to give me the knowledge that he has.
27 MR. DYNNER:
50 didn't use the word modified design.
23 You used it twice, and I want to be sure the witness T00i: E3 & ANT 2 681 Market Street San Francisco 94105 415/392-0650 k
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understands, if he can, what yea're talking aoout.
If 2
yoa 're talking unout tne drawing of the cylinder heads 3
tnat he nas seen, that 's one thing.
If you're talking 4
aucat some other modifications that you have in mind that b
naven 't been identified -- Let 's find out what we ' re 6
talking aoout.
7 MR. STRDUPE:
I assume, Mr. Dynner, since P rofessor 0
Christensen is being held out to be the expert on 9
cylinder heads, that he is aware of any design changes 10 that have been made to the cylinder heads.
11 MR. DYNNER:
He should be aware, but he isn't 12 necessarily aware of the terminology that you're using.
13 I'm sust asking you to be clear in your questions so that 14 1 and the witness can understand the question.
15 MR. STROUPE:
Let se try it thia way, Mr. Dynner.
16 MR. D'.'NNER:
Thank you.
17 MR. STROUPE:
I'll try to rephrase my question.
18 C.
Are you aware of the design of the latest 19 Shorenas cylinder nead?
20 A.
The only design changes that I'm aware of are 21 the ones that have been given to me in the form of 22 communication.
The design changes that I think I recall 23 on the cylinder head drawing were the ones I mentioned 24 earlier, which was the thicker covering plates over the 25 core holes and the fact that they were welded on.
2e I th ought tne other changes were made more in the 27 areas of quality control, in quality assurance.
But if 28 you can tell me what these design changen are, then ! can TJ0KER & ANT" 681 Varnet S treet San Francisco 94105 415/392-0650
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forr.alete k better opinion.
But I think we ha ve had
- J extreau dif ficalty in getting information f ece the engine J
outiders, and this does not help m/ investigation.
If 4
yoa coalc tuli me or list for me theso design changes 5
here nos, then I can give a better response in my answer s.
6 Q.
Professor Christensen, havc you had occasion or 7
an opportunity to look at tne cylinder heads that oxist b
on tne Snoreham ED3s?
9 A.
flo.
i I
10 Q.
Did you ha ve occasion, sir, last week in Wading l
11 River, New York to examine the 103 engine?
12 A.
I had a chance to examine the cracks in the 13 cylinder bloct. We were presented with this examination 14 at ver/ very r.hort notice.
I didn't have any protective I
15 clotning to wear.
I didn't have a flasalight.
1 didn't 16 have muacuring instruments.
I didn't have stronger 17 glasses th.it I use when I'm esamining things, and usually lu we nave oven rushed in and rushed out of that turbine 19 nouse.
l 20 The occasion that I was there before when Mr.
I 21 Youngling was with us, I asked to look at certain things, 22 and the response I got was they were locked away in somo 23 cage and the keys sere not ootainable.
If somebody tells f
24 you the noys are not ontainab?m well, one can come to 25 two conclusions and that is, A, they're not attainable or 26 sumocody is giving you some f alsehood.
27 aut I think there 's an empression, estracting l
t 20 information nas been like drawing teeth from a hen, is it, TOOK ER & ANT
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t I
1 or nave I 'got the location wrong?
It has been very
[
2 difficult for us to estain information both at the J
Shorehas plant and f rom TDI.
f 4
Q.
So you do not know whetner tne cylinder heads 5
tnat are existent upon the Snoreham CDGs today are of the i
6 same design as the cylinder heads that you have looked at 7
operating experience on?
8 A.
I can only go by what I as told.
I as told I
9 that the new cylinder heads which have been fitted in the 10 Shotenas engines are of a different design.
The only 11 recollection I have of that design is the f act that it 12 nas a thicker side plate.
There may be some other things 13 there which I'm not aware of or whien I naven 't been 14 infersec of.
15 Q.
So that you wouldn't know, I take it, whether 16 there nas been any cracking of cylinder heads of the 17 design that are presently on the Shorenam CDGs anywnero 18 in the field?
r 19 HR. DYNNER:
The question doesn't follow wnen you
(
r 20 start the question with so that.
[
21 MR. STROUPE:
I'm just asking him if he knows.
l 22 MR. DYNNER:
You can ask him, Do you know.
The way 23 you phrased the question was implied that it was by l
1 24 reason of his previous answer, which doesn't fit.
i 25 MR. STROUPCs Q.
Do you know, P rof essor Christensen?
r 26 A.
Coald I have that back 7 6
27 MR. STROUPCs Yes, sir.
I will rephrase the i
28 question to satisf y Mr. Dynner.
l f
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Q.
'Do you knos of any cylinder needs of the design 2
tnat are presently upon the Shoreham CD0s, that have 3
experienced cracking in the field?
4 A.
Yes.
I think I have seen a morning report 5
wntch refers to what I would call a suspected crack, 6
which I think goes under the terminology of indication in 1
ene Unites S tates.
I think some of these things were 6
- 21ated to material def ects, but again I have looked at 9
so many reports I cannot remember fine details in thic 10 area.
11 c.
Do you have any recollection, P rofessor 12 Christensen, as to what this report was entitled or what 13 it concerned?
14 A.
I tnink this was in a morning report, a 15 decament which is referred to as a morning report, but I 16 cannot be sure of that.
I only just think that as well 17 as my memory serves me.
18 Q.
Do you have any recollection, sir, as to where 19 the cylinder head that was referred to as having an 20 anJication or crack in the morning report was located?
21 A.
I think it was located on an outer surface.
22 Q.
I'm sorry, you misunderstand my question.
23 Located in terms of, not on the component itself, but in 24 teraa of geographical location within the United S tates 25 or the world for that matter.
26 MR. DYNNER. You mean on what engine was the 27 cylinder head located?
28 MR. STROUPE:
Yes, sir.
TOCKEa & ANTI 681 Market Street San Francisco 94105 415/392-0650
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e 1
THE WITNESS:
A.
I tnought you were speaking of the 2
Snorcham engines earlier and I addressed this.
3 MR. STROUPE:
Q.
Are you referring, then, to a 4
morning report that indicated, to your best recollection, 5
titat a. crack or an indication had occurred on a Shorehsm-6 cylindur hvad?
7 A.
I think this was given as an indication.
b Q.
Do you recall, sir, the date of that morning 9
report?
10 A.
Goodness, gracious, no.
tic, I can't recall 11 that.
12 Q.
Dc you recall how long ago you saw the morning 13 report?
14 A.
I cannot recall that.
15 Q.
Prof essor Christensen, have we generally 16 covered your concerns with the cylinder heads on the 17 Shorcham EDGs, or do you have other concerns?
18 A.
You have covered my concerns within the areas 19 of the amount of material which I have received on the 20 cylinder covers.
If I receive more material on the 21 cylinder covers, then I may modify my views.
22 G.
You are, I take it, in the midst or in the 23 process of reaching or vorning towards a final conclusion 14 or determinati,on with regard to the cylinder heads?
25 A.
Correct.
25 Q.
Do you ha ve, sir, any timetable for reaching 27 your final conclusion or opinion?
23 A.
I've been told that I've got to move very TOCXEa 6 $5172 681 Market Street San Francisco 94105 415/392-0650 l
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200 L
6
~
1 quicnly.
2 Q.
Basec on wnat you've noen told, na ve you 3
determinec, in your osn mind, when you are going to try i
4 to come to a final conclusion or opinion?
5 A.
No.
I believe - ard I'm not being evasive nov -
6 I mentioned earlier that I can only come to a final 7
conclusion within the light of information received up to 8
that time.
If I receive subsequent information, then I h
9 may modify my conclusion.
One can only make a conclusion 10 on information received and data input up to that point 11 in time. You receive further information later that may
[
12 well alter your opinion.
13 Q.
You may or may not change your preliminary 14 conclusion?
15 HR. DYNNER:
He said -- You know he said this so 16 nany times, hasn 't he, Odes ? He keeps telling you if he i
17 guts some new information.
I can rephrase what he said I la tnink seventeen times this morning and you keep saying, t
19 is it final?
He keeps te11119 you tnat if some new 20 significant information came before him, it may ha ve an 21 impact on nis conclusions.
It's per f ectly logical.
He's 22 said it seventeen times or so.
23 Do you want him to say it again?
He'll say it again.
24 HR. STROUPE:
We can put you under oath and let you 25 testify, Mr. Dynner, if you want to do so.
26 liR. DYNNER:
I don 't want to testify.
I just don 't 27 want these repetitious questions you keep asking.
You 2h know the oojection is asked and answered.
I'm just i
TOOKEa & ANT 2 681 Market Street San Francisco 94105 415/392-0650
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-- -. - -,, -,.. - -,.,.,. - ~.,
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trying to wxplain what pornaps you don't reali:o you're 2
doing.
3 MR. STROUP E:
I believe I know what I'm doing, Mr.
4 Dynner.
5 MR. DYNMER:
I didn't mean it in a derogator/ way 6
out just in a helpful way.
7 MR. STROUPE:
Q.
Do you understand the question, 8
sir?
9 A.
Could we have the question read again?
10 Q.
I can give you the question again.
It would be 11 quicker.
12 You may or may not chango your opinion with regard 13 to cylincer neads?
14 A.
I may or I may not.
15 Q.
Professor Christensen, do you have any other 16 person who is assisting you in coming to a determination 17 or conclusion with rugard to the reliability of the i
la cylinder heads on the EDGs at Shoreham?
19 A.
I worked with my colleagues, Mr. Dennis Eley 20 and Mr. Bakshi.
21 Q.
Are either one of those two gentlemen, in fact, j
22 assisting you in your analysis of the cylinder heads?
f 23 A.
No.
I think we are each coming to an 24 inuependent conclusion on this.
25 Q.
Are all three of you in the process of coming 26 to an independent conclusion on cylinder he4J.7 27 A.
I'm just trying to think back now to see if I 28 have given any input information to them.
Again, it's so TOOKER & ANT 2 681 Market 5treet San Francisco 94105 415/392-0650 i
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datticult for me to recall.
Tecnnical things - technical, 2
not numbers out tecnnical things - in the course of my 3
work I would remember Decause I have to remember.
4 I think there has been come exchange of information 5
between us on the cylinder heads.
6 Q.
Is there, Professor Christensen, a particular 7
area or part of the cylinder heads that either Mr. Bakshi 8
or Mr. Elwy are involved with analyzing?
9 A.
I couldn't recall that.
10 HR. DYNNER: The record should show that, of course, 11 Mr. Stroupe had an opportunity to ask those questions 12 directly to Mr. Eley and Mr. Bakshi when he deposed them
.13 roviousi.
e f
14 MR. STROUPCs Q.
P rof essor Christensen, I belio ve 15 you indicated that fou dere in the process of attempting 16 to reach a conclasion or opinion with regard to the 17 reliaoility of the pistons --
18 A.
Correct.
l')
Q.
-- in the Shoreham EDGs; is that correct?
20 A.
Correct.
21 Q.
Have you, sir, reached any preliminary 22 conclusion or opinions with regard to the pistons in the 23 Shoreham EDCs?
24 A.
I took a pressure, I took a connecting rod 25 angle, somewhere where the inertia ef fect was being 26 redaced, and I soughed out a f igu ra for the side thrust 27 on the piston skirt.
We had an arbitrary figure of 2d cosaowhere around 85 psi for a design figure maximum TOOK ER & ANTZ 681 tlarket Street San Francisco 94105 415/392-0650 N