Pinpointing Liabilities in Litigation Using Finite Element Mathematical

Simulations and Materials Science to Quantify Degrees of Liability

O’Donnell Consulting Engineers2940 South Park Road Bethel Park, PA 15102Phone: (412) 835-5007www.odonnellconsulting.com

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

byWilliam J. O’Donnell, Ph.D., P.E.Qualified Expert in State, Federal and International Courts

Make sure your Expert:

1.Has real experience and responsibility for design and not only teaching or expert witness experience. 2.Can communicate highly technical material to lay jurors.3.Has the necessary engineering software and scientific knowledge to present sound conclusions.4.Has technical credentials to support the opinions presented.

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

The precise causes of structural and equipment failures are often difficult to quantify. However, such quantification is necessary in order to assess the relative liability between the designer, fabricator / constructor, material supplier, and the owner / user.

New developments in mathematical simulations and materials science described herein provide accurate quantifications.

Causes of Structural and Equipment Failures are Difficult to Quantify

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

O’Donnell Consulting Engineers has used this technology successfully as Experts in hundreds of mediations, arbitrations and State, Federal and International Court cases as it has evolved since the late 1970s.

Finite Element Mathematical Simulations and Materials Science

Q. What are Finite Element Mathematical Simulations?R. It is the most effective tool for the failure causation

evaluation of systems and structures. It provides results by breaking the subject hardware into a finite number of pieces or elements in order to mathematically perform rigorous engineering calculations.

Q. Why do I need Finite Element Mathematical Simulations and Materials Science?

R. To evaluate the contribution of defects in the cause of failure: in the design, in the materials of construction, in the fabrication, and in the operating conditions.

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

Finite Element Mathematical Simulations

Courts Accept Finite Element Mathematical Simulations

In Litigation, Claims and Dispute Resolution

Finite element mathematical simulations determine precise causes of failure by quantifying the contribution of defective design, materials, fabrication and operating conditions.

Finite element software has been verified and is widely used in the Federal Safety Regulatory Process. It is accepted in State, Federal and International Courts.

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

(1) Designer

(2) Constructor / Fabricator

(3) Material Supplier

(4) Owner / User

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

Potential Liable Parties

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

Mathematical Finite Element Simulations Quantify:

(i) Stresses for comparison with code allowables for strength

(ii) Fracture design safety margins

(iii) Safety margins for buckling for comparison with code safety margins

(iv) Fatigue damage

(1) Designer’s Responsibilities

Large-furnace ductwork failed because fillet welds were not suitable for cyclic thermal service

■ Redundant design of restraining system $7.2 M awarded by Court from American Air Filter to Northwest Alloys

CONSTRUCTION DESIGN ERRORS

► Failure analysis of a NASA heat exchanger discovered multiple cracks at the flange bolt holes of the inlet and outlet tubesheets

■ Design did not meet thermal-fatigue limits

● OCE performed comprehensive finite element analyses and made corrective design changes

EQUIPMENT DESIGN ERRORS

► Fatigue failure of cloth treating steam drums at stainless steel cylinder to carbon steel end cap-welds

■ Failure to inspect welds subjected to thermal fatigue in a New Jersey “sweat shop” resulted in a worker losing his arm

EQUIPMENT MATERIALS SELECTION DESIGN ERRORS

■ Change from carbon steel to stainless steel with no redesign proved fatal: Stainless steel has higher thermal expansion, lower thermal conductivity and lower strength

■ Damages exceeded $1 M

STRUCTURAL MATERIALS DESIGN ERRORS

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

The four legs of the central tower of the New San Francisco Oakland Bay Bridge expand differently as the earth and sun move, creating high

stresses in connecting welds.

FABRICATION (WELDING) PROCESS COMPLEXITIES

► This represents the failed pedestal of the 15th Century Venetian Statue of Adam in New York Museum of Art

■ The strength of wood deteriorates over time, so the testing of new wooden pedestals does not assure they will hold two years later, when the strength deteriorates about 50%

MATERIALS SCIENCE PROVES CAUSE OF FAILURE OF WOODEN

PEDESTAL

►Failure of an elevated floor plate over a cyclone that was subjected to corrosion and dynamic loads

■ The lack of corrosion allowance in the design of a highly corrosive vapor atmosphere resulted in a fatality

CORRISION IGNORED IN DESIGN ERROR

►Failure investigation of an elevated steel-mill track support subjected to dynamic loads and corner wrap-around welds that are not allowed. This caused loss of production costing $ Millions■ Contributing factors included weld design and quality problems, and structural engineers’ overlooking dynamic loads

DESIGN ERRORS DUE ToDYNAMIC LOADS & WRAP AROUND WELDS

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

Finite Element Simulations Quantify:

(i) Loss of structural strength

(ii) Increase in local stresses and corresponding reduction in fracture loads and fatigue life

(iii) Reduction in buckling loads

(2) Constructor/ Fabricator Responsibilities

● OCE performed comprehensive engineering 2-D, 3-D, elastic, and elastic-plastic finite element analysis of different scales of the coke-oven battery. Determined it was structurally sound, despite various technical concerns.

DEMONSTRATED LONG LIFE OFCOKE OVEN BATTERY WITHOUT REBUILD

■ Finite element analysis of a cable damaged during installation resulted in a “hot short” and subsequent fire

Damages exceeded $ 5 Million

Finite Element Mathematical SimulationDetermined Cause of Electrical Fire

► Failure analysis of floodgate No. 2 at Porce II Dam, Medellin, Colombia.

■ Contributing factors: As-fabricated welded sections failed to meet design specifications; construction methodology errors; dynamic loads not consideredTwo fatalities and delay costing $ Millions

DYNAMIC LOADS AND DEFECTIVE WELDING

CAUSED TWO FATALITIES

► Cracks initiated at welds on a Vibro-Fluidizer@, that uses counter-rotating shafts to mix fluids

■ Contributing factors – Dynamic loads machining tolerances, and weld defects resulted in fatigue failure and loss of production

LOCAL STRESS CONCENTRATIONSRESULTED IN FATIGUE FAILURE

►Failure of a conveyor chain resulted in shutdown and major loss of production

■ Contributing factors included geometric stress raisers and poor weld design

CONVEYOR CHAIN FAILUREPLUS DEFECTIVE WELD DESIGN

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

Finite Element Simulations Quantify:

(i) Loss of structural strength property deficiencies

(ii) Reduction in brittle and ductile fracture loads due to deficient ductility and toughness

(iii) Reduction in buckling loads due to deficient material properties

(iv) Reduction in fatigue life due to deficient yield strength, ultimate strength and ductility

(3) MATERIAL SUPPLIER RESPONSIBILITIES

► Corrosion cracking in circumferential piping butt welds due to high residual stresses from welding ● Pipelock was designed to handle blowdown loads using Finite Element Mathematical Simulations with no credit for weld strength

<< Nuclear Quality Assurance approval by US NRC allowed installation, saving Commonwealth Edison $100 M >>

DESIGN REPAIRSPipelock Installed in Commonwealth

Edison Boiling Water Reactor

Roof Truss Failure due to design and welding defects

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

ROOF TRUSS FAILUREMARGINAL DESIGN AND POOR WELDING

► Failure analysis of a hollow steel structural steel (HSS) rack supported building - $63 M damages and a fatality

■ Contributing factors - design issues; weld quality issues of electric resistance welded HSS tubes with lack of full thickness fusion

● OCE determined flexural torsional buckling of resulting open section columns

FABRICATION ERRORS RESULTNG IN FATALITY

Photos of open section of square columns caused by lack of fusion near in automatic welding

COLUMNS FAILED LONGITUDINALLYDUE TO FABRICATION DEFICIENCIES

►Failure analysis of a U.S. Army fuel heater subjected to thermal loads

■ Contributing factors - Manufacturing processes: Purging - caused rough weld profiles. Tooling - induced high strains and surface roughness; Welding: Preparation & high welding heat input

ARMY HEATER WELD FAILURESFABRICATION DEFICIENCIES

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

Mathematical, Finite Element Simulations Quantify:

(i) Reduction in structural strength due to higher applied loads

(ii) Reduction in brittle and ductile fracture loads for higher applied loads

(iii) Reduction in buckling safety margins due to higher applied loads

(iv) Reduction in fatigue life due to higher applied loads, the higher the number of operating cycles, and potentially higher dynamic loads

(4) OWNER / USER RESPONSIBILITIES

► Power generator failure determined that maintenance personnel failed to tighten longitudinal bolts per requirements. Vibrations wore off insulating surface materials, resulting in a short circuit & fire

● Wyoming Public Service Commission refused to allow $30 M cost of replacement power to be charged to ratepayer

ELECTRICAL PLANT GENERATOR FIREDUE TO LACK OF MAINTENANCE

► Failure analysis of a hot blast Blowpipe at Tuyere 16, Blast Furnace No.7, Ispat Island Steel Chicago, Illinois.

■ Inspection Quality Assurance - Operators failed to notice predictable burn-back of fuel injection lance through the site glass

BLAST FURNACE FAILURE

► Explosion of largest copper oven in the world due operating errors that were quantified based on Finite Element Mathematical

Analyses

COPPER OVEN EXPLOSION

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

Mathematical Modeling Uses inState, Federal and International Courts

Automotive / Truck AccidentsBolted Joint Failures

Brittle FracturesChemical Equip. Failures

Codes & StandardsCompressors, Pumps

Construction EquipmentCorrosion Fatigue

Due Diligence EvaluationsElectrical Shorts

Elevated Temp. FracturesExplosions

Fatalities and InjuriesFires and Explosions

Flow Induced Vibrations

Gas Line FailuresHome Tool Injuries

Industrial PlantIndustrial Process

Ladders MalfunctioningMaterial Defects

Materials Hauling Equip.Mediations

Medical ImplantsOSHA

Personal InjuryPiping

Safety EvaluationsScaffolding Accidents

Welding Defects

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

Clients Using Mathematical Simulation Technology

NationalAK SteelALCOA

American Electric PowerAMOCO

Autoclave EngineersBabcock & Wilcox

Bechtel IncorporatedCelanese Chemicals

DC FabricatorsDow Chemical

General ElectricKvaerner Songer

Long Island RailroadMississippi Power & Light

NJ Div. of Public Safety

InternationalArevaCITIC

DragadosHitachi

NIRO, Inc.Northeast Utilities

Oak Ridge National LabOhio EdisonRolls Royce

Sargent ControlsUS Steel

US Dept. of EnergyWestinghouse Electric

MitsubishiRio Tinto

O’Donnell Consulting Engineers, Inc.2940 South Park Road Bethel Park, PA 15102Phone: 412.835.5007Fax 412.835.5017www.odonnellconsulting.com

Bill O’Donnell, Ph.D., P.E.wjo@odonnellconsulting.com

O ’ D o n n e l l C o n s u l t i n g E n g i n e e r s, I n c.

The results of these finite element mathematical simulations provide a quantitative basis for determining the degree of liability and allocation of liability among defendants.

Finite Element Mathematical Simulations and Materials Science Results