ML20096A691
| ML20096A691 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/30/1984 |
| From: | Farley E HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Brenner L, Ferguson G, Morris P Atomic Safety and Licensing Board Panel |
| References | |
| OL, NUDOCS 8408310218 | |
| Download: ML20096A691 (31) | |
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24566.3 ri c -o oenset oiaw wo aca es.1564 In the Natter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-1 (OL) 1 BY HAND Hon. Lawrence Brenner, Esq.
Hon. Dr. Peter A. Morris Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Hon. Dr. George A. Ferguson Administrative Judge School of Engineering
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Howard University
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2300 - 6th Street, N.W.
Washington, D.C.
20059
Dear Administrative Judges:
I sincerely regret that the attachments *to LILCO's Supplemental Motion To Strike were omitted yesterday.
Here is 4
a set for each of you and service is being made today on everyone else.
I apologize for this inconvenience.
Very truly y urs, r
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G E. Milton Farley, III, Esq.
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Alan Roy Dynner, Esq. (By(Hand) rA y
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D-4 ATTACm4ENT 1 1
OFFICIAL TRANSCRIPT PROCEEDKGS 3EFOE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL
)
(Shoreham Nuclear Power Station
)
)
Unit 1)
)
DEPOSITION OF ROBERT N. ANDERSON i
Washington, D.
C.
Wednesday, May 16, 1984 ALCE2ECN FE;CRTNG (202) 628-9300 440 FIRST STREET, bl.W.
'4 f'
s 91 1
A It may be one of them.
I don't know.
2 Q
Do you consider yourself an expert or 3
qualified in the mechanics cf finite dynamics?
4 A
Finite d ynamics.
No, I seldom work in that 5
area.
6 0
Who did ycu talk to at ANAFET?
7 4
Gordon Laxell, and tne other name escapes me a
at the mcment, but he is the President cf ANAHET.
8 0
Did you cbserve any shot peening of any of the to components or parts that you observed at the TDI 11 f acili ty?
12 A
No, I saw no shot geening operation, nor did I 13 see, thcugh necessarily you wouldn't he able to 14 recognize it without careful inspection, any shot-genned 15 p ar ts.
16 0
Tcu don't knew whether er not they de in fact 17 have a shot pewning capability, process or facility at 18 TDI?
19 A
I did not see one.
It ias not inspected.
20 2
Now, did Rohatoi focus solely on connecting 21 rods?
22 A
The bearings, yes.
ALDGMSON REPORnNG COMPANY.INC.
3B F ST. N.W. WAGNWeGToN. OA 30501 (300 450300
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ATTACIIMENT 2
1 1
i 2
UNITED STATES OF AMERICA 3
NUCLEIR REGULATORY COMMISSION 4
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5
x 6
In the Matter of
- Docket No.
7 LONG ISLAND LIGHTING COMPANY
- 50-322 0.C.
8 (SHOREHAM NUCLEAR POWER STATION, UNIT 1) 9
x 10 11 Deposition of DENNIS ELEY, held at 12 the Shoreham Nuclear Power Plant, Shoreham, 13 New York, on the 3rd day of May, 1984, 14 at 9:50 o' clock a.m.,
before Thomas R.
15 Nichols and John Ianno, Jr.,
Notaries Public 16 of the State of New York.
17 18 19 20 21' 22 23 24 25
.g.
1 Eley 166 2
Q.
Is that the only -- is what you have 3
read dbout the Holzer method in the FaAA report, 4
again, the only knowledge you have about the 5
Holzer method?
6 A.
That is correct'.
7 Q.
Do you know anything, Mr. Eley, about 8
9 A.
I do not.
10 Q.
Have you read anything about the finite 11 element analysis?
12 A.
I have read the finite element analysis 13 reports.
i 14 Q.
Where did you read that, sir?
15 A.
In various reports that are being made 16 available to me.,
17 Q.
Do you understand finite element. analysis?
18 A.
I would not have the capability of 19 completing a finite element analysis myself.
4 20 Q.
Why is that, sir?
21 A.
I do not have that capability.
I have 22 not done this task before.
23 Q.
Is it because you have some limitation 24 in mathematics or physics or solid mechanics o r --
25 A.
I don't
i 1
Eley 167 2
Q.
That makes that im po s s ib le?
3 h.
I don' t really know.
I have not 4
investigated it.
I have not researched it far 5
enough.
6 Q.
You are not saying you couldn't do it 7
if you spent the time to research it?
8 A.
That's right.
9 Q.
You are saying you j us t, ca n' t do it today?
10 A.
Tha t's right.
t 11 Q.
Because you don' t have a full 12 understanding of it?
1 13 A.
Tha t's correct.
14 Q.
Do you know what a torsiograph is?
15 A.
Yes.
16 Q.
Have you ever seen a torsiograph?
17 A.
Yes.
18 Q.
What is it?
19 A.
Things that measure torsion.
20 Q.
Have you ever had occasion to do a 21 torsiograph yourself?
22 A.
I have not done one myself.
23 Q.
Did you ever have occasion to have 24 someone do one for you?
25 A.
I have seen the results of torstograph
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ATTACHMENT 3
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOAPE 4
.-...___________x 5
In the Matter ofa a
S LONG ISLAND LIGHTING COMP ANY Docket Nc.
7 (Shoreham Nuclear Power Station a
50-322-01 8
Unit 1) 9
__________________x 10 gashington, C.C.
11 Tuesday, May 15, 1984 12 Deposition of RICHARD B. HUBB ARD, called for 13 examin ation by counsel for long Island lighting Company 14 in the above-entitled action, pursuant to notice, at the 15 of fices of Hunton and Williams, 2000 Pennsylvania 16 Av e nu e, N. W., Washington, D.C., commencing at 10:08 a.m., on Tuesday, May 15, 1984, the-witness being.first 17 18 duly sworn by SUSAN HARRIS, a Notary Public in and f er 18 the District of Columbia, and the proceedings being 20 taken down by Stenomask by SUSAN HARRIS, and tra nsc ribe d 21 under her direction.
22 l
As. cannon napownne coup 4NY,inc.
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def ect, based on a report?
2 A
In general, that would be the case.
Eut.also 3
workin g with Dr. A nderson tc analyze the various service 4
re scrt s.
5 0
What qualifications do you have in terms of a
cas tin g ?
Have you ever worked in a foundry?
7 A
No, I have not.
8 Q
Have you ever studied the foundry process, the 8
cas tin g crecess?
10 A
No.
11 Q
Do you have any background in metalurgy?
12 A
I've tak en courses in aetalurgy ?
13 Q
Do you have a degree in metalurgy?
14 A
No, I don't.
15 Q
A bachelor 's degree in me talurg y?
16 A
go, 17 Q
We have identified two areas in which you have I'm not going to use the words " preliminary opinien" 18 18 every more, because every time I ask ycu that you say 20 it's not really a preliminary cpinion -- but areas that 21 you're going to examine further.
You indicated one was 22 the DRQR and the second was the manuf acturing process.
l ALDERSON REPORDMG COMPANY,INC.
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63 i
1 A-I don't have an crinien on that.
2 Q
Do you know how to do a finite element 3
analysis, Mr. Hubbard?
4 g
yo, 5
g 1.d like you to look at page 5-8 of the 6
rescrt, please.
Secticn 5-3 discusses fatigue crack g ro wth analysis.
The first paragraph in Section in 5-3, 7
8 in the middle of the paragraph states, "The presence of 8
a crack in the piston skirt does not necessarily lead tc 10 unsati sf actory performance of the piston because the 11 initated cracks may not grew.
Even if they do grew, 12 they may arrest as they grow out the localized region of 13 high s tress.
Ihe behavior cf any cracks that do net 14 initia te can be analyzed by use of" -- I'm sorry -- "Th e 15 behavior of any cracks that do initiate can be analyzed 16 by use of f racture mechanics principles."
17 Do you agree with the statements that I,just 18 read, sir?
And we can take them one by one if you want.
19 A
Well, we ought to go through them one by one.
20 I uculd agree that the cracks may not grow.
You have to 21 get in to a time period and in an envirenment and lets of 22 other things, and really, you know, what caused the ALDER 0oN MePoRDNG COMPANY,INC.
t.
V 64 9
cracks,, whether they a re a manuf acturing defect or as a 1
2 result ' of opera tion.
So the werd "may" there, ycu know,
~
3 it's conceivable that they might not grow.
They aisc 4
may stop growing.
The "may" there is also true.
That 5
may ha ppen.
It also say net happen, and again, it has e
to do, you know, with all the things I mentioned bef ore,
7 wha t caused the cracks initially.
8 Q
Are you f amiliar with f racture mechanics?
I 8
A No.
I would rely on Dr. Anderson for that.
10 Q
So then you would not be prepared to comment 11 on a' conclusion that was reached in this report based on 12 the application of f racture nochanics analysis?
18 A
Yes.
Other than that the behavior of any f
14 cracks -- I menn it seems-to me that it is an infinite 16 number of types of cracks and locations, so one of the i
18 first questions I would have of Dr. Anderson is is it q
17 true that this analysis would really go to any cracks or 18 just some cracks.
18 0
Mr. Hubbard, have you done any work on push 20 coda that are in the TEI emergency diesel generaters at 21 Shoreh am?
i 22 A
Nc, other than the general gathering of field i
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ATTAC1 DENT 4 1
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2 BEFORE THE ATOMIC SAFETY AND AND LICENSING DOARD 3
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Inttbmatterof.
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4 LONG ISLAND LIGHTING COMPANY,
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5
)
(Shoreham Nuclear Power
)
6 Station, Unit 1)
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)
DOCK ET NO. SC-332-OL 6
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DEPOSITION OF STANLEY G. CHRISTENSEN 12 13
- tAY 9, 19 8 4 14 VOLUME IV, Af tecnoon Session
~15 16 17 la REPORTZD 3Y:
DANUTA WARNOCK, C.S.R. 30 4782 L) 20 21 TOOKER &' ANTZ CERTIFIED SHORTHAND REPORTERS 22 6 01 MARK ET STREET, SUITE 925 SAN FRANCISCO, CALIFORNIA-94105
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FREDERIC R. TOOK ER KEMBLE ANTZ
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1 torslographs in connection witn your analysis of 2
replacement crankshafts?
3-A.
I did look at them, yes.
1 4
'Q.
Do you recall what you determined, if anything, 5
f rom looking at them?
6 A.
No, I just looked at them.
I t was some time 7
ago now since I looked at them and as I had come up with 8
these'valaes and as they had shown what they had come up 9
with later on, I didn't'take that thing any further.
I 10 can't exactly say how I would view that now oecause I am 11 going uack now to thu early days of the receipt of the 12 first report or second report on the crankshaft.
13 Q.
Did you have occasion, Professor Christensen, 14 to review tae FaAA finite element analysis of the 13 ruplacement crankshafts?
16 A.
I dio look at that, yes.
17 Q.
What if anything, sir, did you determine after lu you had looked at that?
l')
A.
We will, I will be quite frank.
I went back to 20 cy textbooks on finite element analysis because it is not 21 an area in which I would consider myself as an expert, 22 not in any way.
23 Q.
When you went back to ycur textbooks on finite 24
- element analysis were you able to gain an understanding 25 so that you could analyze the methodology --
26 A.
Yes.
27 Q.
Let me finish the question.
28 A.
I thought you had finished.
T00KER-6 ANTZ 681 Market S treet San Francisco 94105 415/392-0650
.--------------------------------..1
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MR. DYNNER:
The record should show Prof essor 4
2-Christensen is not ' attempting to interupt but because of 3
the phraseology of the questions from time to time it's 4
difficult to tell whether Mr. Stroupe has finished 3
phrasing the question.
6 HR. STROUPE:
Thank you.
7 If P rof essor Christensen would give me ten 8
seconds or so af ter I start a question I don't think we 9
will nave 'that problem.
10 MR. DYNNER:
There is, of course, no intention 11 here to interrupt you, Mr. Stroupe, 'and it's important 12 that De on the transcript because someone reading the 13 transcript cannot listen to the phrasing of your 14 questions.
15 MR. STROUPE:
Let me see if I can repeat the 16 question.
17 Q.
Professor Christensen, after going back to your la textbooks on finite element analysis, were you able to 19 gain an understanding as to tne methodology utilized by 20 FaAA in applying finito element analysis to replacement 21 crankshafts?
22 A.
Yes.
I wondered -- we will, the first thing we 23 had in the book -- I can ' t quote the book but it's from 24 the McG raw Hill Enginecra ' Section, library books on 25 engineering, Mecnanical Engineering Series, I think the 26 first thing that hit me there was finite -- I'm not 27 condemning finite element analysis < en I say this, 28 please let me get that straight.
Toad ER & ANTE 681 Market Street San Francisco 94105 415/392-0650
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First thing it said there was it was an art and 2
not a science, and this is obvious to any engineer
'3 because the locations of the various points around the 4
syst'em would require a considerable amount of knowledge 5
to locate correctly.
6 Tne next thing I would comment on would be that 7
if you are using a standard computer program for this l
8 analysis, then you would have to see that the dimensions 9
of the crankshaft coincided witn the basic parts on what 10 tnat computer program was oased on.
This is relative to 11 stem.
12 The acxt thing tnat would be required is a 13 knowledge of the various stresses that a crankshaf t is 14 saojected to during its 720 degrees of rotation.
As I 15 mentioned earlier, I'm not an expert on finite element 16 analysis, three dimensional finite element analysis, but 17 I think I know enougn of it to be very cautious in its 18 usage.
And where I would comment further is it could be 19 an ideal thing perhaps to be used as a cor.iparitive, but 20 not something to be used to find the definite figure for 21 a stress value.
22 Q.
Do you recall, P rof essor C hristensen, the title 23 of the publications, or if they were in fact plural in 24 nunner, the publications that you looked at to gain on 25 understanding of finite element analysis?
26 A.
I again --
27 MR. DYNNER:
Let's not characterize his 2d tes ti mo ny.
I t wasn't to gain an understanding, was it?
700 DER & ANT 2 681 4arket Street San trancisco 94105 415/392-0650 i
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If you want to ask him which books he was referring to, 2
if he remembers the title, fine.
Let's not characterize 3
incorrectly his testimony.
4 MR. STROUPE:
I did not mean to characterize 5
your testimony.
Mr. Dynner obviously has a photographic 6
memory.
So I do the best I can based on the memory I 7
ha ve.
8 MR. DYNNER:
Thank you.
9
- lR. STROUPE:
And I-will ask the questions 10 based on tne memory that I' have and not Mr. Dynner's 11 me mo ry.
12 Q.
And I will ask you if you can recall the name 13.
of those textbooks.
14 A.
I think the name of tne series was McGraw Hill 15 Mechanical Engineers' Series of books.. We might call 15 them textuooks because that is virtually what they are.
17 The name of the book within the series, I think, was 18 Introduction' to Finite Element Analysis.
The preface of 19 the book, which is the reason that I bought the book, it 20
.12 not a methodology to se able to carry out a finite 21 element analysis of calcalations, it is a book which is 22 more or less telling you tne whys and wherefores of it, 23 as the book says in the introduction.
' 24 I wanted tnis to review certain ideas that I 25 had about this from reading stuff earlier in technical 26 journals, mathematical Journals and various place where 27 one acquires knowledge.
Here I had most of the things 2d togetner in one book, that is why I went to that book.
TOOK ER - & ANTE 681 Market Street San Francisco 94105 415/392-0650
-._- - - - - - -_._ m _ - - - - - _ _ - - - - - - - - _ - _ _ _ - _ m.
i 1
Q.
Do you know the author of that book, Professor 2
Christensen?
3 MR. DYNNER:
Personally?
4 MR. STROUPE:
No.
5 Q.
Sir, are you acquainted witn his name?
G' MR. DYNNER:
Thank you.
7 THE WITNESS:
I'a' not acquainted with anybody 's a
n a me.
I cannot remember the name of the man, but I will 9
certainly give it to the lawyer here if you desire me to 10 g i ve it to him.
li MR. STROUPE:
Q.
Do you recall, P rof essor 12 Christensen, the year of publication of that book?
13 A.
It's a very, very recent publication.
I 14 couldn 't give you the exact year.
I think finite element 15 analysis has only been out ever the last ten or 15 years, 16 and then it was only used in very limited areas in the 17 first instances.
18 Q.
Did you have occasion, P rofessor Christensen, 19 to, in reviewing the FsAA report, tc compare the finite 20 element analysis of torsional stress upon the crankshaft 21 witn the experimentally obtained data?
l 22 A.
I don't goite understand your question.
I'm 23 sorry.
24 Q.
Do you recall, P rofessor Christensen, a l
.25 reference in the FaAA report to strain gauge testing of 26 the replacement crankshaf ts?
27 A.
I remember reading about the strain gauge 28 testing, yes.
TOOKER 6 ANT 3 681 Narket S treet San Francisco 94105 415/392-0650
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.1 Q.
Do you recall having sade any comparison 2
between the results produced by the strain gauge testing, 3'
e.g., esperimental testing as opposed to the figures 4
obta4ned through the use.of finite element analysis?
5' A.
Yes.
There was some inaccuracy thera, I 6
oelieve, because if my memory serves me correctly there 7
was a correlation f actor used which I thought introduced 8
some further douot about one or the other sets of figures.
9 Wnat the correlation factor was, I cannot remember now.
10 I got a feeling it was in the order of maybe seven 11 percent, but again, I am using my memory which may be 12 elaying tricks with me.
13 HR. STROUPE:
Let's take a break.
14 (snort break f rom 3 :00 until 5 :20. )
15 MR. STROUPE:
Q.
Professor Christensen, are
~
16 fou aware of any requirement that the Nuclear Regulatory 17 Commission has which says that either Lloyd's rules, 10 ABS's rules or DEMA's rales have to be complied with?
13 A.
I am not aware of anything in their rules that 20 says that.
~
21 Q.
Are you generally familiar with the NRC 22 regulations as they apply to omergency diesel. generators 23 in nuclear service?
24 A..
I won't say I know those regulations down to 25 the last' cross on the "T" and dot on the "I," but I think 26 I have a broad idea of them.
One of the things that I 27 have noted is that most of those regulations are directed 28 to safety, and I thought that they were good regulations l
1
~ TOOKER & ANT 3 681 Market S treet San Francisco 94105 415/392-0650
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ATTACHMENT 5
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
--oOo--
In'the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
)
Docket No. 50-322-OL (Shoreham Nuclear Power
)
Station, Unit 1)
)
)
DEPOSITION OF ROBERT NEIL ANDERSON MAY 10, 1984 1
I Reported by:
KEMBLE ANTZ, CSR 669 s
i TOOKER & ANTZ cearisico swont wa o aspontras
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1 G
Uhat type of work did you do for them?
2 A
In the past, I have worked in the nucicar area, 3.I principally availability'of uranium.
Some problems on 4
extraction of uranium.
New techniques for extraction of 5
uraniun.
/
6
[
G Cxtraction of material is your jrincipal expertise 7
in the field of metallurgy, isn't it?
8 A
Chemical, temperature, chemical thermodynactes of i
i 9
metals.
10 3
Were any of these publications that you list in your I
11 Exhibit 3 submitted for review prior to publication or were l
i 12 they just sent to particular magazines?
13 A.
Most of those that are there were sent for profes-14 sional review and were accepted.
15 G
Uhat else had you done in connection with the diesel 16 generators at Shoreham prior to the end of 1933 that you I
I i
17 haven' t already told me about?
l r
4 18 l
A.
I can't think of anything else.
19 G
!!ow did 1984 start out?
It was a good year.
I got an nvitation to go to j
20 21 l
India and work on the Taj ':a ha l.
And then cane back and 22 ;
I had more boxes of materi.al on this case to read.
1 1
23 i G
Uhen did you come back' 24 A
Toward the end of February.
25 Q.
Okay.
And you received this material from either 26 Mr. Dynner or Mr. Miller?
27 i A
Or Mr. Scheidt.
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28 l G
Have you reviewed all that material?
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-UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION j
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
---o0o---
5 6
7 8
In the Matter of 9
LONG ISLAND LIGHTING COMPANY (SHOREHAM NUCLEAR POWER STATION, No. 50-322 0.C.
10.
UNIT 1.)
11 Deposition of 12 ROBERT N. ANDERSON 13 August 4, 1983 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Reported by ADELE I. NOLAN, CSR No. 1641
.28 i
M9 HAM REPORTIIIS SERVISE IIIt.
1533 Pine Street. San Francesco. CA 94109
. Te'eonome 14:56 928-8001
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1 received, approximately July 19th, do you know how many hours 2
~you spent reviewing that package?
3 You said you received it in Hawaii?
4 A Yes, I did.
5 Again, without the notes that I have made, I may not be 6
exact, but it would be on the order of three or four hours.
7 G And with respect to the final package of documents 8
that you received from Mr. Avery, can you just estimate how much 9
time you spent on that?
10 A Okay.
Now this presumes that I have only -- I only 11 stay with the documents once and never reread them, or refresh 12 my memory, so that I would say on the package I received from 13 Mr. Avery, I believe there was about two, two and a half hours 14 in that package, in the initial reading.
15 g
Professor, would you consider yourself an expert in 16 foundry practices?
17 A No.
18 0
Have you ever been employed by a foundry?
19 A No.
20 0
Have you ever done any consulting work for a foundry?
21 A Yes.
22 g And could you describe that work, please?
23 A Well, let's see.
24 There was one business that had a small casting 25 operation -- I mean small compared to what you have.
I believe 26 they were in belt buckles, and I straightened up their 27 procedures, developed mold washes, and extended the life of the 28 molds that they were using.
WGLAN REPORTIM SERVICE IM.
is33 mee street. San Francisco. CA 94109 Teiephone (4151926-8001
0 16 1
I have had -- let's see -- I have had a number of 2
casting problems, and it's not clear to me that I was working 3
for the plaintiff or the defendant in those cases.-
4 If
.t was the plaintiff, I was clearly working for the 5
company as a consultant.
6 I can recall one -- there's a neat little casting firm 7
back East that makes the Harley-Davidson handles -- brake 8
handles -- and they had a problem, and one of them broke, and 9
when it breaks, there's no way you can put a brake on, and it 10 was a fatal accident, and I had to go through their casting 11 procedures and characterize what they were doing compared to 12 all the other motorcycle castings that are currently on the 13 market, and that was for the manufacturar.
14 (Mr. Pratt entered the deposition room.]
15 MR. EARLEY:
G So lot me review.
16 You have done consulting work for a foundry that dealt 17 in small castings, and you have indicated that you have been 18 involved in a number of casting problems.
19 Could you estimate the number of times you have had --
20 given consulting services dealing with casting problems?'
21 A That's difficult.
22 I would say I have had over 500 cases, independently 23 consulting for corporations, and I just don't keep track of it.
24 There have been a number of casting problems.
25 There have been some spring hangers on trucks, White 26 Truck -- Trucking Company -- there was some failures there that 27 I had to look at, and examine the casting procedures.
28 0
Well, would you estimate that it is more or less than WebAM REPORTIMS SERYitE IMt.
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10 percent of those 500 cases?
2 A You must be reading my mind.
3 I was going to say it would probably, if I had to make an 4
- estimate, ot going back through my files,10 percent might be 5
reasonable of the 10 percent of the metallurgical consulting 6
work associated with the casting failures.
7 This would be ferrous base and nonferrous, too.
8 G
So have you dealt with casting problems relating to 9
steel castings?
10 A Yes.
11 4 Have you ever dealt with a case involving steel 12 castings of cylinder heads?
13 A As represented in this case here?
14 G
This case is the limit of your experience in dealing 15 with steel casting -- steel cylinder heads?
16 A No.
I can't recall any similar case.
17 MR. DYNNER:
Off the record.
18 (Discussion off the record.]
19 MR. EARLEY:
G Professor, have you ever conducted a 20 failure analysis?
21 A
Failure analysis?
22 4
Yes.
23 A Yes, I have -- lots of them.
24 G
And have you conducted failure analysis on a steel 25 casting?
26 A Yes.
27 G
Can you estimate how many failure analyses on steel 28 castings you have performed?
MekAM REPORTIIts SERVICE 1984.
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I 18 1
A Well, let's see.
2 If I had about 500 metallurgical cases, roughly 10 3
percent, my most honest guess, were castings, and if you'll 4
look at th'e market, most of the castings are, I'm afraid, 5
nonferrous, that have problems.
6 Ferrous is fairly reliable.
7 I would say'that I would have to say -- I would say about 8
a third of those castings would be of ferrous material.
9 G
Do you remember the precise subject matter of any of 10 that -- the number of steel casting failure analyses you have 11 done?
12 A I can tell you wonderful war stories --
13 G
Just -- due to the lateness of the hour, can you give 14 me a list of those you can remember?
15 A
I can remember Bigfoot. [ phonetic]
16 I think I had developed a hernia carrying that casting 17 around.
18 There was a truck that was working, I believe it was a 19 logging truck, and it was working up in the hills, and apparently 20 went out of control.
21 It was a brake failure or something.
The driver said his 22 brakes didn't work, but this big truck went out of control, and 23 I believe hit another car, innocent car, and big truck, small 24 car.
Small car had severe injuries.
25 There was a failure in a very large casting associated 26 with the rear end of that vehicle, and there was a question, 27 because of its location so close to the stress point.
28 In other words, there is curvature problems --
M9 HAM REPORTING SERT 185 IMS.
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If I could -- if you could just give me a list, for 2
~ example, a large casting in the rear of the truck, so we can 3
expedite,- can you recall the -- just the general subject 4
without going into the description of any others?
5 A Okay.
There has been some -- there is a cast part 6
which is associated with spring hangers on large trucks, and 7
that failed, dropped the truck down so it went out of control, 8
went across the road, killed somebody.
9 That was ferrous base.
10 There has been some really -- and I believe those are 11 the two most recent.
I just can' t recall.
12 I do extensive aircraft, automobile investigation, and 13 also some nonmetallic investigation, like breast implants.
14 G
Professor, have you -- are you familiar with hot tears 15 in a casting?
16 A Yes.
17 G Have you ever seen a hot tear?
18 A Yes.
19 G
Would it be fair to say that someone who is familiar 20 with hot tears and has seen a number of hot tears can recognize 21 a hot tear in a casting when they see one?
l 22 A Yes.
I think that's a fair statement, as long -- in l
23 order to keep it totally fair we say that it's a clean -- it's l
24 close to -- it has been used, in other words, it's close to the 25 time of manufacture, so that there is nothing obscuring the 26 surface.
27 No corrosion products, no debris of any type.
If it's 28 on the casting floor, then certainly you should have a clear W9 HAM REPORTIt0S SERVICE IIIC.
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