post-inspection report: failure of a bull...

POST-INSPECTION REPORT:

FAILURE OF A BULL GEAR In the matter of:

Luvata Buffalo, Inc. v. Service Guide, Inc. State of New York, Supreme Court: County of Erie

Index No. 2009-011802 Hurwitz File No. 20091083

Report to:

Earl K. Cantwell, Esq. Hurwitz & Fine, P. C. 1300 Liberty Building

Buffalo, NY 14202-3670 Report by:

Robert H. Wagoner, Managing Member R. Wagoner, LLC

144 Valley Run Place Powell OH 43065

Report dated:

February 4, 2012

R. H. Wagoner Failure of Bull Gear

TABLE OF CONTENTS

TITLE 1 TABLE OF CONTENTS 2 QUALIFICATIONS 3 CHRONOLOGY AND BACKGROUND 4 OPINION 6 BASIS OF OPINION 1 7 BASIS OF OPINION 2 11 LIST OF EXHIBITS 15

Exhibit A: Curriculum Vitae for Robert H. Wagoner Exhibit B: List of Materials Relied On Exhibit C: Inspection of Bull Gear on January 19, 2012, and Subsequent

Analysis on January 23, 2012


QUALIFICATIONS

1. I am Robert H. Wagoner, the George R. Smith Chair and Professor in the

Department of Materials Science and Engineering, and the Department of Mechanical

Engineering, at the Ohio State University. Along with my teaching responsibilities at

Ohio State, I supervise both masters and doctoral theses and conduct sponsored research

for national and international companies and institutions. I also act as an independent

metallurgical and mechanical engineering consultant.

2. I am a member of the National Academy of Engineering and am Fellow or

equivalent of five professional engineering societies, as follows: AIME (American

Institute of Mining, Metallurgical, and Petroleum Engineers), ASM International, ASME

(American Society of Mechanical Engineers), SAE (Society of Automotive Engineers),

and TMS (The Minerals, Metals, and Materials Society).

3. I have been President of TMS and President of AIME. I have also served

as President of the TMS Foundation, Director of the Ohio State University Research

Foundation, and Trustee for the Edward F. Orton Jr. Ceramics Foundation.

4. A copy of my curriculum vitae appears as Exhibit A. My expertise related

to this case includes: knowledge related to metallurgical engineering, mechanical

engineering, forming of metals and alloys, and mechanical and operative properties of

devices constructed of various alloys.

5. I am widely published in the field of materials science and engineering,

and the field of mechanical engineering, including over 300 technical articles, 2

proceedings volumes, 2 combined proceedings and authored books, and 2 textbooks. The

topics of my publications include finite element analysis, micro-mechanisms of


deformation, plasticity theory, material constitutive equations, and sheet metal forming.

A list of publications and a partial list of invited and international presentations on these

topics is included in Exhibit A.

6. I am being compensated for my investigative and expert work in this case

at the rate of $300 per hour, and I am being reimbursed for out-of-pocket expenses I

incur.

CHRONOLOGY AND BACKGROUND

7. On December 7, 2010, I received a call from attorney Earl K. Cantwell of

Hurwitz & Fine PC. The alleged “failure” or degradation of a large bull gear* was

described briefly by Mr. Cantwell. My qualifications for investigating the causes of the

“failure” were discussed. (For the remainder of this report, and in its title, I refer to the

alleged failure or degradation of the bull gear as a “failure” for simplicity and brevity,

without implying an opinion of the bull gear’s condition.)

8. On December 23, 2010, I agreed to be retained by Hurwitz & Fine PC for

forensic consulting and possible expert witness activities. The purposes of these

activities were two-fold: 1) to determine, if possible, whether the bull gear was subjected

to the improper application of heat according to a theory proposed by Luvata and Lufkin

employees, and 2) to determine, if possible, how the gear failed.

9. From December 23, 2010, to today, I received documentation that I have

relied on to analyze the bull gear failure. Those materials are listed in Exhibit B. I have

reviewed this material at various times during that interval, particularly, but not

* There have been at least three bull gears installed on the 44 Mill #2 Stand. Unless otherwise stated, references to the “bull gear” or “gear” in this report refer to the bull gear removed and reinstalled in December 2007.


exclusively, during January 2010, June-July 2010, December 2010, and January 2011.

10. The subject bull gear was a replacement ordered for the 44 Mill, Stand 2

from the Philadelphia Gear Company on July 23, 1990. This order followed a service

inspection report dated July 16, 1990, that noted that the pre-1990 bull gear had a ‘face

runout of the [pre-1990] main gear of 0.080,” ’ indicating that is was “bent or warped,”

but otherwise showed little tooth wear (“light pitting on some teeth, (as noted) surface

finish good, contact good, little wear”)†.

11. The following information is stamped onto the surface of the subject bull

gear that is the subject of the current action:

PO 73536 ORD 448097 HT N0671 VC 69849 11-7-90

12. The plaintiffs’ theory for the failure of the bull gear may be summarized

as follows: When Service Guide heated the subject bull gear to remove it from the shaft,

they improperly, excessively and unevenly heated it at or near the rim, where the ring

gear is installed. This heating was supposedly concentrated at an angular area identified

by what plaintiffs call “heat witness marks” corresponding to black areas on the motor

side‡ face of the bull gear near the rim. Most of the remaining bull gear face presents an

orangish/pinkish color characteristic of a paint or primer. (In his deposition, Mr. Wolf

refers to this as the “original paint color”.) In the plaintiffs theory, this paint or primer

† Citations are to the Field Inspection Letter, Continental Machine and Engineering (C.M.E.) to American Brass, July 16, 1990, including the drawing and inspection notes by C.M.E., July 5, 1990 ‡ There has been some confusion about the motor side and mill side of the subject bull gear. See my inspection report, Exhibit C, for a summary. I have adopted what I believe to be the correct labeling of the bull gear in this report.


was burnt or transformed to a blackened state when the temperature reached a sufficiently

high temperature that was absent at other locations on the bull gear. The concentrated

and uneven heating of the ring gear caused it to expand away from the hub, thus

permanently misaligning the ring gear with respect to the hub, producing unsatisfactory

runout. The same region shows a break in a small weld used to retain a locating pin

between the hub and ring gear of the bull gear, although this is on the other face of the

gear.

13. The sole indication supporting this theory is the apparent angular

correlation of black regions near the rim on the motor side of the bull gear with the area

of maximum separation between the ring gear and hub.

14. The evidentiary material provided by the plaintiffs is incomplete and much

of material provided is of poor quality. Among other items, many historical records of

the subject bull gear and Mill 44 are missing, as are records for previous and subsequent

bull gears installed on Mill 44. Engineering drawings and specifications, maintenance

and transport procedures, and other such records are absent. The photos provided are of

poor quality, although it appears that electronic files are available (Luke Wolf

deposition). Runout measurements of the bull gear before removal for transport in 2007

have not been provided. The bearings removed from the roto-pinion shaft in 2007 have

not been produced for inspection.

15. In view of the absence of important evidence and the poor quality of other

evidence, I reserve the right to revise my analysis and opinion if and when additional or

improved-quality evidence is provided.

16. On January 19 and January 20, 2012, I organized and carried out an


inspection visit to Luvata Buffalo. On January 23, I carried out analytical scanning

electron microscopy (SEM) and energy dispersive spectroscopy (EDS) to determine the

composition of the black areas on the subject bull gear. The results of the inspection and

analytical work appear as Exhibit C.

OPINION

17. OPINION 1: The bull gear was not subjected to improper, excessive, or

uneven heating during its removal at Service Guide. The black regions are not

indications of high temperature, and the black material is not burnt or transformed paint.

18. OPINION 2: The most likely cause and sequence of failure was

identified. The ring gear became deformed and the hub / ring gear interface was

weakened by cyclic fatigue in extended normal service. Aggravated by the weakened

state, transport of the bull gear assembly without sufficient care deformed the ring gear

where it rested on the minimally-padded floor of the transport truck.

BASIS OF OPINION 1

19. To restate the plaintiff’s theory, with more precision: Service Guide

personnel applied excessive heat near the ring gear portion of the bull gear over an

angular region roughly between Load Pads E and A. (This same angular region can

alternatively be described as including Holes 1 and 6, or being oriented between 225o and

315o using Mr. Wolf’s arbitrary angular orientation. Figure 7 of the inspection report

shows the region as labeled the “Heat Zone” by Mr. Wolf in the LW drawing§.) This

application of heat caused the ring gear to expand away from the hub to such an extent § The “LW drawing” refers to a drawing titled and marked as follows: 44 MILL 2 STAND BULL GEAR FIELD MEASUREMENT / OBSERVATION RECORDING (Luke Wolf, 9-29-09)


that it became permanently deformed and misaligned on the hub in this region.

20. The plaintiffs’ theory rests on one point: the apparent matching of angular

location of two features: 1) blackened areas on the motor side of the bull gear near or on

the ring gear, and 2) the area of maximum gap between the ring gear and hub (which is

near the area of the broken pin weld). The blackened areas on the bull gear (which

appear in many locations) are associated by the plaintiffs with the burning of paint such

as to leave a black residue that is visible today. These blackened areas are referred to as

“heat witness marks” corresponding to what is called a “heat zone.”

21. Many aspects of the evidence are contrary to the plaintiffs’ theory. It

would take a high temperature differential between the ring gear and the hub to cause

plastic deformation of the ring gear. It is very unlikely that permanent deformation as is

now observed could have occurred unless a large radial load on or a concentrated axial

load on one angular position of the ring gear was applied, separately or concurrently with

the application of heat. Even if high heat were applied unevenly causing uneven

expansion, cooling would have brought ring gear and hub back into registry in the

absence of the application of a large external force. The locating pins would have

assured this. The magnitude of the force required can be understood by the fact that a

400 ton press was found insufficient to remove the bull gear from the shaft even with the

application of heat. The area of contact between shaft and bull gear is smaller than

between the ring hear and the hub.

22. The plaintiffs’ theory is also contradicted by the appearance of the bull

gear itself. First, unless a portion of the hub was exposed to a very high temperature (in

excess of approximately 400 deg. C, the range in which typical heat guns for paint


removal operate), paint is unlikely to burn off. Such a high temperature would take a

long time to reach using gas burners. It would have been unnecessary to attain such a

temperature for the removal of the shaft using a sufficiently large press. The original

paint color (orange/pink depending on the light) appears to cover the majority of the bull

gear surfaces on both sides, thus indicating that high temperatures were not reached over

most or all of the bull gear surface.

23. It would normally be expected that black portions of the bull gear

correspond to relatively cool regions during heating. This is consistent with the overall

aspect of the bull gear in this case as well. Comparison of photographs of the bull gear at

the removal in 2007 show a coating of black sludge (although the current photos are quite

poor, this appears to be the case) on the surface of the bull gear that was mostly absent

upon its return after heating for its removal from the shaft.

24. Figure 1 of my inspection report shows a semi-circular pink area

surrounded by highly contrasting black area at approximately 4 o’clock as shown on the

figure. This configuration is reminiscent of how the soot from a candle deposits around

the hot flame region when held under a piece of metal. It appears that a gas torch was

either started while aimed at the center of that circle and then the gear was rotated

counter-clockwise, or else that the torch was started elsewhere and the gear was rotated

clockwise until the torch came to a rest at the center of the orange/pink circle and then

was shut off. The pink region thus corresponds to the hottest region during the operation

(which would need to be well below the paint burn-off temperature), with the black

regions cooler.

25. The maximum temperature reached at the center of the orange/pink


circular area would have been well below the paint burn-off temperature. This

interpretation is consistent with what would be normally expected in terms of heating for

removal of the bull gear, i.e. the heat would be applied near the center of the space

between the central collar and the rim in order to maximize the temperature differential

between the collar and the shaft.

26. With this interpretation in mind, at least two sources of the blackening can

be envisioned: 1) dirty oil left on bull gear after removal would have been baked on by

the heating torches to form the blackened regions (and conversely, removed from hotter

regions in contact with the flame), or 2) soot from a rich natural gas / air burner (or

similar type) could have deposited in cooler areas adjacent to the heat application (similar

to the candle analog). The paper copies photos provided by the plaintiffs showing the

original removal of the bull gear are of very poor quality, but the surface appears to be

caked with some kind of sludge from oil. This sludge would normally be expected to be

solidified and baked on at lower temperatures, and to be removed at higher temperatures,

similar to how cooking fats are baked onto the inside of a household oven during normal

operation (typically 150-250 deg. C), but are removed when cleaned at higher

temperatures (typically around 500 deg. C).

27. The central question is thus: do the blackened regions visible on the bull

gear correspond to “heat zones” as named by Mr. Wolf, or do they represent instead

cooler regions adjacent to the normally-expected path of the heating torch? This question

was answered conclusively by several tests performed during the inspection and the

subsequent analysis, Exhibit C.

28. If high temperatures were applied to the ring gear in one area for sufficient


time to deform it permanently (it would need to be heated throughout its width over a

significant angular sector to accomplish this), the hardened steel would be softened by a

process known as tempering. This would be particularly noticeable at the surface, where

the temperatures would have been highest by the action of the surface heating.

29. The hardness tests conducted on the ring gear around its periphery show

no variation of Rockwell hardness, as would be expected by local application of high

temperatures. Hardness measurements of unknown type as recorded (but unreported) by

Mr. Wolf on the bull gear show a small variation in one area (contrary to his statement

that they are all the same), but the scatter of those measurements is unknown. The area

of slightly lower hardness is not in the so-called “heat zone,” but instead is in a region

approximately 90 to 180 degrees removed from the heat zone. Thus, there is no indication

of high heat applied locally in the so-called “heat zone,” where the separation occurred.

30. A second way to test the accuracy of the plaintiffs’ theory is to determine

whether the blackened areas represent material deposited on top of the paint, or whether

the paint has been burned there to form the blackened material. In order to test this,

solvents and sanding were used to remove the black material from a region on the bull

gear (see inspection report, Figures 8-11. These figures clearly show that the blackened

material is on top of paint that has the original color and appearance of the surrounding

areas. Thus, the blackened areas are not burned paint.

31. As a final test, chips of the black material were removed by scraping

(Figures 12-14 of the inspection report). Some of these chips, once removed, had a black

side and a reddish side (presumably related to the corroded iron substrate in this area).

Scanning electron microscopy (SEM) and energy dispersive spectroscopy (EDS) were


used to reveal the nature of the black material. The black chips were determined to be

composed predominantly of the element carbon, with traces of oxygen and iron. Most

significantly, there were no indications of typical paint or primer components such as Ca,

Si, Mg, Cr, and Zn. Thus, the black material is not burned or otherwise corrupted paint.

32. Therefore, it is clear that the blackened material visible on the bull gear

was deposited during normal mill operation (oil sludge) or during the heating to remove

the shaft (torch soot), or both. Its presence represents areas adjacent to the application of

the flame of a torch, i.e. cooler regions where the temperature was insufficient to remove

the hydrocarbons from the surface, or where the lower temperature allowed deposition of

hydrocarbons from the flame.

BASIS OF OPINION 2

33. As noted above, there is no evidence indicating misapplication of heat

during removal of the bull gear at Service Guide. On the contrary, I concluded that the

application of heat was appropriate, in the appropriate areas, and with appropriate peak

temperatures as indicated by the presence of undamaged paint on the surface and by

uniform hardness measurements of the ring gear. Mr. Wolf noted in his deposition that

he expected Service Guide to use heat to remove the bull gear, and he expected to see

signs of the expected heating on the surfaces of the bull gear.

34. As noted above, deformation of the ring gear to its condition would have

likely required the application of large, concentrated loads. (The magnitude of the

required load would depend on the extent of weakening of the hub / ring gear interface by

fatigue over extended operation, among other things.) The ring gear shows a peak gap

differential of 0.113” across the gear face at approximately 90/270o (angle based on LW


drawing) and an axial runout differential of 0.314” at approximately 0/180 degrees, i.e.

90 degrees away from the maximum gap differential.

35. Either a large radial compressive load occurred at the 270o position (270o

is roughly the center of the so-called “heat zone”) or a large concentrated axial load (or

moment as applied by the shaft in this direction) would be required at either the 0o or

360o locations. Neither such load would normally be encountered during normal

operations nor during gear removal from the shaft.

36. The radial loading could be expected to have occurred during transport if,

for example, the gear were transported with the 270o position against the load floor of the

truck. The postulated orientation would have been such that the keyway pointed almost

vertically downward. Unfortunately, the quality of the existing photos cannot be used to

determine the orientation of the bull gear as mounted in the truck.

37. It is difficult to envision how large concentrated loads would be applied to

the gear assembly except by transport or mishap such as dropping from a crane.

However, there are no signs on the ring gear that the gear assembly was dropped,

improperly pressed, or otherwise abused.

38. There is little information about the quality of the transport or the quality

of the mounting of the bull gear assembly for transport. Such information, if available,

could be used to estimate the magnitude of the stresses in the gear during transport. The

existing photos are of exceedingly poor quality. Descriptions of the mounting in Mr.

Wolf’s deposition correspond to what is shown in Figures 1 and 2 of Exhibit C, with


additional elements of a long, heavy** shaft installed in the collar supported at one end by

stacked pallets and chains to hold the assembly down. The amount of play possible and

the condition of the mounting upon arrival at Service Guide are not known.

39. Bottom support of the bull gear such as is shown in Figures 1 and 2 of

Exhibit C can create large concentrated stresses at the ring gear / hub interface in a local

area where the bull gear rests on the plywood and then on the floor of the truck. These

stresses will be larger for thinner wood cushioning and for less-compliant trailer floors.

Neither of these factors can be assessed quantitatively today based on available

information. Nonetheless, with 22,000 pounds of weight and a long moment arm, very

high local stresses (as applied repeatedly, as road bumps are traversed) are conceivable at

the contact area of the bull gear with the truck floor. The quality of the roads and the

trailer suspension would also have an effect on the peak stresses involved. Impact

accelerations exceeding 10 g’s during truck transport on U.S. roads can have been

reported††.

40. Damage during transport would have been more likely if the bull gear

were in a weakened condition from the application of excessive numbers of cyclical loads

during normal operation. As Mr. Wolf noted during the inspection visit, the 44 Mill

typically operates around the clock, and the bull gear operated for 17 years under those

conditions. Large numbers of cyclic loads that could be well within normal allowances

can degrade a mechanical structure.

** The weight of the shaft can be estimated at 12,000 pounds in view of the gear assembly weight (gear plus shaft plus center bearing) of 22,000 pounds recorded during shipment and 10,000 pounds for the replacement bull gear recorded during shipping. †† Investigation of the Shock / Acceleration Loads on Carbon Filters during Transportation and Handling, D. R. Peterson, C. A Betten, L. L. Dauber, J. A. Savel,. Proc. 26th DOE/NRC Nuclear Air Cleaning and Treatment Conference, Richland, Washington, September 11-12, 2000.


41. It should be noted that there are signs that the bull gear was weakened and

misaligned before removal. Uneven gear wear and vibrations were noted approximately

12 months before it was removed from service. In December 2006, an inspection report‡‡

noted a “definite problem area with the roto gear set” and recommended “to review this

issue immediately and act as soon as possible.” While these problems have been

attributed by Mr. Wolf to bearing wear, they could also have indicated degradation of the

bull gear structure. This question could possibly be resolved by examination of the

bearings from the roto pinion shaft. If they were in good condition (contrary to the

assumption of Mr. Wolf), it would be a strong indication that the problem identified in

2006 was with the bull gear. Unfortunately, Luvata has not produced the bearings for

inspection and testing. Similarly, excessive runout would indicate damage to the bull

gear structure, but runout measurements prior to the 2007 removal have not been

produced.

42. In terms of broader evidence, it appears that the 44 Mill had a series of

gearbox problems including rebuilding of gearboxes for various stands for several years

around 2007. This makes the failure of the bull gear likely during this period from

extensive normal operation. Unfortunately, coherent records of what was done, when,

and for what reason have not been made available. Little information has been provided

about the history of maintenance for 44 Mill or even its age or hours of usage.

43. In view of the missing evidence, it seems unlikely that an unequivocal

determination of the exact sequence of events leading to the current state of the bull gear

can be made. In addition, the bull gear has been transported since the failure was noted,

and heated to remove it from the shaft again, thus further changing appearances and ‡‡ Field Service Report, Sam A. Reneau, December 29, 2006.


conditions since the 2007 removal.

44. It would be most helpful to have access to the following information in

order to determine the failure sequence with more precision:

• runout measurements of the bull gear prior to removal in 2007

• electronic files for photos

• angular orientation of the bull gear mounted in the truck for transport in 2007

• years and hours of operation of 44 Mill, including bull gears for each stand

• maintenance manual for gearbox and mill

• recommended shipping procedures for bull gear

• bearings removed from the roto-pinion shart in 2007

• engineering drawings with dimensions and clearances of gearbox and bull gear

• field inspection report immediately preceding removal of the bull gear in 2007

Notwithstanding the potential benefits of additional information of the foregoing kinds,

the mostly likely sequence of failure of the bull gear has been concluded as presented

above.

LIST OF EXHIBITS Exhibit A: Curriculum Vitae for Robert H. Wagoner Exhibit B: List of Materials Relied On Exhibit C: Inspection of Bull Gear on January 19, 2012, and Subsequent Analysis on

January 23, 2012

Exhibit A: Curriculum Vitae for Robert H. Wagoner

ROBERT H. WAGONER George R. Smith Chair

The Ohio State University Dept. Materials Science and Engineering 2041 College Road Columbus OH 43210

phone: (614) 292-2079 fax: (614) 292-6530 e-mail: [email protected] http://kcgl1.eng.ohio-state.edu/~wagoner/

EMPLOYMENT

2001- George R. Smith Chair, Dept. Mat. Sci. & Enrg, Ohio State University 1998- Professor, Dept. Mechanical Engineering, Ohio State University 1994- Director, CAMMAC (Center for Adv. Matls. & Mfg. of Auto. Components) 1999-01 Distinguished Professor of Engineering, College of Engineering, Ohio State University 1992-96 Chair, Department of Materials Science and Engineering. 1990-91 Maître de Récherche, Ecole des Mines de Paris, Sophia Antipolis, France. 1983- Professor (‘86- ), Assoc. Professor (‘83-‘86), MSE Dept., Ohio State University 1977-83 Staff Research Scientist, General Motors Research Laboratories, Warren, MI.

SELECTED PROFESSIONAL ACTIVITIES Adjunct Professor, Pohang University of Science and Technology, 2007- . President, Amer. Inst. of Mining, Metall. And Petro. Engrs (AIME), 2003-04. Trustee, United Engineering Foundation (UEF), 2002-05 Organizer: NAE Frontiers of Engineering, Japan-American Frontiers of Engrg., NAE Chair: Gordon Cte. (’04), Matls. Peer Cte (’03), Materials Section (’03) NAE Cte. Member: Committee on Membership ‘(04-‘07) Board of Governors, Acta Materialia (1999-2002) President, The Minerals, Metals and Materials Society (TMS) (1997-98) President, TMS Foundation (1998-99) Board of Trustees, Edward F. Orton Jr. Ceramics Foundation (1992-96) Board of Directors, O.S.U. Research Foundation (1990-94) Co-founder, NUMISHEEET international conferences (USA 89, Switzerland 91, Japan 93,

USA 96, France 99, Korea 02, USA 05) Panel Member, Evaluation of Norwegian Research in Engineering (’04) Member: NAE (Life), TMS (Fellow), ASM (Fellow), ASME (Fellow), SAE (Fellow)

SUMMARY ACCOMPLISHMENTS

27 Ph.D. dissertations and 23 M.S. theses advised; 16 post-doctoral researchers advised 300 research publications (210 peer-reviewed), 2 edited vols., 2 books 110 international and invited presentations, 30 distinguished scholars & post-docs hosted

mailto:[email protected]

http://kcgl1.eng.ohio-state.edu/~wagoner/

July 22, 2011 R. H. Wagoner Page 2

AWARDS AND HONORS 2011 Khan International Medal (Int. J. Plasticity): Outstanding life-long contribution to the

field of plasticity.

2009 Doctor Honoris Causa (Honorary Doctorate): University of Cluj-Napoca, Romania. For outstanding achievements…

2008 Honorary Member, AIME: For research accomplishments…, as an educator…

2007 Fellow of the Society of Automotive Engineers (SAE). For important engineering, scientific, and leadership achievements … significance of and impact of …

2007 Distinguished Service Award of the American Institute of Mining, Metallurgical, and Petroleum Engineers (AIME). For his leadership and dedication …

2006 Fellow of the American Society of Mechanical Engineers (ASME). For exceptional engineering achievements and contributions to the engineering profession.

2006 Scott Faculty Award (Engineering College, OSU) – For excellence in teaching and the qualitative aspects of teaching… (OSU)

2004 Distinguished Service Award – For outstanding contributions to TMS. (TMS)

2003 Fellow of the Minerals, Metals and Materials Society (TMS) – For outstanding contributions to the practice of metallurgy or materials science and technology

2001 George R. Smith Chair in Engineering - Endowed Chair (1999-01, Dist. Prof. Engrg.)

2001 S. H. Melbourne Award (SAE) - For most outstanding single contribution in 2000: "Springback Analysis with a Modified Hardening Model" (w/ Lumin Geng).

2000 THERMEC 2000 Distinguished Award - For outstanding contributions…

1995 National Academy of Engineering - For important contributions to engineering theory and practice including...unusual accomplishment...

2008 Lumley Research Award (Engineering College, OSU) - Based on the quality of sponsored research and graduate student advising activities. (Also 2001, 1997, 93, 87)

1990 Fellow of ASM International - Recognizes distinguished contributions in the field of Materials Science and Engineering.

1990 Distinguished Scholar Award (Ohio State University) - For a substantial and continuing record of excellence in scholarly activities.

1988 Harrison Faculty Award for Excellence in Engineering (Engineering College, OSU) For noteworthy accomplishments...contributions to engineering education.

1988 Champion H. Mathewson Gold Medal (The Metallurgical Society) - For the most notable contribution to metallurgical science during the period under review.

1984 Presidential Young Investigator Award (National Science Foundation) - For the most promising young science and engineering faculty.

1983 Rossiter W. Raymond Memorial Award (Am. Inst. Mining, Metallurgical Petroleum Engineers) - For the best paper published by AIME in a given period. (Also 1981)

1981 Robert Lansing Hardy Gold Medal (Metallurgical Society) - For outstanding promise for a successful career in the field of metallurgy.

July 22, 2011 R. H. Wagoner Page 3

BIOGRAPHICAL SKETCH

(More information is available at http://www.mse.eng.ohio-state.edu/~wagoner/ ) Robert H. Wagoner is the George R. Smith Chair at The Ohio State University. With principal appointment in the Department of Materials Science and Engineering, he is also Professor of Mechanical Engineering, and Director of CAMMAC: the Center for Advanced Materials and Manufacturing of Automotive Components. From 1992 to 1996, he was Chairman of the MSE Department. Professor Wagoner is a member of the National Academy of Engineering (NAE) and Fellow of five professional societies in materials engineering, mechanical engineering, and automotive engineering: TMS, ASM International, ASME, SAE, and AIME. Before joining Ohio State, he was Staff Research Scientist at the G. M. Research Laboratories, 1977-83, and NSF Postdoctoral Fellow at the University of Oxford, 1976-77. He received B.S., M.S., and Ph.D. degrees in Metallurgical Engineering from Ohio State University in 1974, 1975, and 1976. Dr. Wagoner's group performs a variety of research related to metal forming: experimental and analytical, applied and basic. He is the author of more than 300 technical articles, 2 proceedings volumes, 2 combined proceedings and authored books, and 2 text books in the areas of metal forming, plasticity theory, finite element analysis, mechanical behavior of materials and micro-mechanisms of deformation. He has presented over 100 international and invited papers on these research topics, and has advised 22 masters and 22 doctoral student theses. Dr. Wagoner serves as a consultant to industry with regard to mechanical and materials engineering, particularly regarding die forming, sheet materials, medical devices and automotive applications. His research has received national recognition, including the Robert Lansing Hardy Gold Medal, Rossiter W. Raymond Memorial Award (twice), Presidential Young Investigator Award, SAE Melbourne Award, and the Champion H. Mathewson Gold Medal. At OSU, Dr. Wagoner was named Distinguished Professor of Engineering in 1999 and Distinguished Scholar in 1990; he received the Harrison Faculty Award for Excellence in Engineering Education in 1988, and won College of Engineering Research Awards in 1987, 1993, 1997, 2001 and 2008. Dr. Wagoner was President of AIME (The American Institute of Mining, Metallurgical, and Petroleum Engineers) in 2003-204, President of TMS (The Minerals, Metals, and Materials Society) in 1997-98 and President of the TMS Foundation in 1998-99. He was the co-organizer of the first and second Japan-America Frontiers of Engineering for the National Academy of Engineering. Other service work includes: Trustee of AIME, 1997-99; Trustee of Orton Ceramic Foundation, 1992-96; Governor of Acta Materialia, 1999-2002; and Director of the OSU Research Foundation, 1990-94. Recent service work for the National Academy of Engineering includes chairing the Gordon Prize Committee, chairing the Materials Section, and chairing the Materials Peer Committee, as well as being a member of the NAE-wide Committee on Membership.

http://www.mse.eng.ohio-state.edu/~wagoner/

Exhibit B: List of Materials Relied On

LIST OF MATERIALS RELIED ON Summons, Luvata Buffalo v. Service Guide, Inc., State of New York Supreme Court: County of Erie, Index No. 2009-011802, received October 16, 2009. Quotation, Service Guide to Luvata, December 2, 2007. Purchase Order 262517, Luvata to Service Guide, December 12, 2007. Work Order Detail, 071666-001, Service Guide, December 26, 2007 (ship) Bill of Lading, December 17, 2007 Received receipt, Luvato to Service Guide, Black Rock Trucking, December 12, 2007 (unclear) Packing List, Service Guide to Luvata, December 20, 2007 Invoice, Service Guide to Luvata, December 21, 2007 Metallurgical Report MET 08-01, P. Terry, Lufkin, February 14, 2008 Letter, Art Nelson (Lufkin) to Luke Wolf (Luvata), March 14, 2008 44 Role 2 Stand Bull Gear Cost analysis Drawing: 44 MILL 2 STAND BULL GEAR FIELD MEASUREMENT / OBSERVATION RECORDING (Luke Wolf, 9-29-09) Time line for 44-roll #2 stand gearbox repair, Luke Wolf, September 29, 2009. Various unlabeled photographs apparently taken at Luvata, Buffalo, and Lufkin, Lufkin, Texas Precision in Motion, Service Guide Incorporated, Industrial Equipment Repair. (Brochure?) Plaintiff’s Responses to Defendant’s First Set of Interrogatories, May 10, 2011 Outokumpu American Brass, #44 Rolling Mill Operator’s Handbook, June, 1993 Letter, Diane Blanton (Lufkin) to Charles Hugar (Luvata), February 2, 2007

Field Service Report, Lufkin, Peru IN, December 29, 2006 Field Service Report, Lufkin, Lufkin, TX, February 28, 2005 Field Inspection Letter, Continental Machine and Engineering (C.M.E.) to American Brass, July 16, 1990 Drawing and inspection notes by C.M.E., July 5, 1990 Purchase order 47846, American Brass to Philadelphia Gear, July 23, 1990 Invoice 4667, Grove Roofing Services to Luvata, December 31, 2007 Invoice 019388, Hohl Industrial to Luvata Buffalo, February 29, 2008 Invoice 21894, Horsburgh & Scott to Luvata Buffalo, March 27, 2009 Bill of Lading, Horsburgh&Scott to Luvata Buffalo, March 28, 2009 Invoice 593, Grove Roofing Services to Luvata Buffalo, July 13, 2010 Invoice , Grove Roofing Services to Luvata Buffalo, June 28, 2010 Invoice 23979, Horsburgh & Scott to Luvata Buffalo, July 12, 2010 Invoice 22395, Hohl Industrial to Luvata Buffalo, July 14, 2010 Invoice 24119, Horsburgh & Scott to Luvata Buffalo, August 6, 2010 Purchase Order Inquiry, $27011.56, 4/14/08 Invoice SA119730, Lufkin Industries to Luvata Buffalo, March 31, 2008 Bill of Lading, Lufkin to Luvata Buffalo, undated Plaintiffs exhibits dated 11-18-11: Numbers 1-3, 5-8, 10, 11 Defendants exhibits dates 11-17-11: Letters B-L, N, O

Falk Bull Gear Manual Transcript, Luke Wolf deposition dated November 17, 2011 Article: “Why the Red/Gray Chips are Not Primer Paint,” Niels Harrit, May 2009 Material Safety Data Sheet, Rustoleum Flat Red Primer, May 5, 2011 Investigation of the Shock / Acceleration Loads on Carbon Filters during Transportation and Handling, D. R. Peterson, C. A Betten, L. L. Dauber, J. A. Savel,. Proc. 26th DOE/NRC Nuclear Air Cleaning and Treatment Conference, Richland, Washington, September 11-12, 2000. (http://www.hss.doe.gov/nuclearsafety/qa/hepa/nureg_26th/016a.pdf)

http://www.hss.doe.gov/nuclearsafety/qa/hepa/nureg_26th/016a.pdf

Exhibit C: Inspection of Bull Gear on January 19, 2012, and Subsequent Analysis on January 23, 2012

R. H. Wagoner January 31, 2012

INSPECTION NOTES OF BULL GEAR ON JANUARY 19, 2012 AND

SUBSEQUENT ANALYSIS ON JANUARY 23, 2012.

The following summarizes an inspection visit at Luvata Buffalo, 70 Sayre St., Buffalo, NY carried out on January 19, 2012. The inspection was organized and carried out by Robert H. Wagoner, with technical assistance of Kenneth Waeber, Stress Engineering Services, 5380 Courseview Drive, Mason, Ohio 45040. Also in attendance throughout the inspection were attorneys Earl K. Cantwell and Ryan Cummings. In attendance for part of the time were Luke Wolf of Luvata and two unidentified crane operators of Luvata.

NOTE: LABELING OF THE FACES OF THE BULL GEAR

In a document entitled Time line for 44-roll #2 stand gearbox repair (presented by Luke Wolf, 9-29-09) there are photos purporting to identify the two sides of the bull gear by “motor side” and “mill side.” In particular, LW Figures 14-17 show both sides of the bull gear, but all are labeled as “mill side.” 3 out of 4 of these are apparently labeled incorrectly (LW Figures 15-17). (The figures are unnumbered in the original document, but are counted from the beginning to arrive at the numbers shown here). During his deposition, Mr. Wolf said that LW Figure 14 was correct, but LW Figure 15 was incorrectly marked “mill side.” The caption should have said “motor side.” However, LW Figures 16 and 17 show the same side of the bull gear, and are also incorrectly labelled “mill side.” These were not corrected during the deposition.

The notes taken during the inspection of January 19, 2012, adopted labeling consistent with the original labeling of LW Figures 15-17, although this now appears to be incorrect.

Because Luvata has not provided a sketch or engineering drawing of the gearbox or bull gear, the proper orientation cannot be assured. However, inspection of Figure 1 of the same document, while not 100% conclusive because of its poor quality, appears to show the motor in the foreground to the left of the bull gear, with the high speed pinion engaged with the bull gear. This side of the bull gear clearly has a short stub of a shaft shown inside a bearing and thus this side is presumably the “motor side” of the bull gear. Thus, LW Figures 15-17 are all of the motor side and are all apparently mislabeled in the Time line document. Therefore, the convention adopted during the inspection visit appears to be opposite of the correct one.

In this report, the stub end of the shaft protruding from the bull gear is identified as the motor side of the gear, and the motor side of the current bull gear (with shaft removed) is identified by the motor-side by marks applied by Luke Wolf as shown in Figures 16 and 17, some of which are visible today. (Compare Figure 1 of this report, with LW’s Figures 16 and 17; particularly note the arrows and labels 315o and 270o.) The so-called “heat witness” markings incorporated

R. H. Wagoner Inspection of Bull Gear Page 2

in the plaintiffs’ theory of the failure cannot be readily used to identify the sides unequivocally because of the quality of the original photos and the possibility that black/orange patterns were changed during removal of the shaft by the heating to bull gear at Lufkin after LW Figures 14-17 were taken.

The mill side of the bull gear, Figure 2, has few markings but does have the broken weld holding the pin in place.

INSPECTION RESULTS

Appearance

Figures 1 and 2 show the overall appearance of the bull gear on January 19, 2012. Note the way it ise supported on the shop floor, with plywood underneath the ring gear teeth and wooden chocks to prevent rolling. This method is similar to the one described by Mr. Wolf as used for truck transport of the bull gear. Figure 1 shows the motor side of the bull gear; Figure 2 shows the mill side.

Figure 1 shows several kinds of marks applied by Mr. Wolf to the motor side of the gear. The numbers just inside the ring gear represent clearances between the ring gear and the hub. For example, near the bottom of the photo can be seen .113, corresponding to a clearance of 0.113” measured at that location. These numbers correspond to those included in Mr. Wolf’s drawing called 44 MILL 2 STAND BULL GEAR FIELD MEASUREMENT / OBSERVATION RECORDING (Luke Wolf, 9-29-09), hereinafter referred to as the LW drawing.

Numbers can be seen on the ring gear itself, for example, see the number “625” near the clearance value of 0.113”. According to Mr. Wolf, these represent micro hardness measurements that he made. When asked why these were not reported with his other data, he stated that they were all the same, so he didn’t include them.

There are two labels of “Heat ZONe” on Figure 1. One is near the rim centered near the floor in the orientation pictured there. This location is also close to the keyway location, and according to Mr. Wolf’s orientation system, this would be at approximately 240 degrees. (The keyway is at approximately 280-290 degrees in Mr. Wolf’s system.) The other “Heat ZONe” label is diametrically opposed to the previous one, i.e. at about 60 degrees, and is applied on the inner collar, where the shaft connects to the bull gear. These labels correspond to the red portions of the LW drawing, and presumably to blackened portions of the bull gear as seen by Mr. Wolf in September 2009. (These blackened portions, while still recognizable, are not as clearly delineated today, presumably because of oil on the surface in some locations, and heating by Lufkin subsequent to Mr. Wolf’s photgraphs being taken.)


Figure 2 shows the mill side of the bull gear. A few markings are apparent on this side as well. Labels of “225o” and “270o” are visible and correspond to the 225 degree and 270 degree labels on the motor side. (The orientation of the gear was unchanged between Figures 1 and 2.) A label of “heat ZONe” is oriented approximately between this labels, at approximately 250-260 degrees.

There is a partial box drawn around a stamped identification of the bull gear near the top of Figure 2. This identifying marking is shown in Figure 3 (flipped top to bottom to make it more readily readable). There are 124 teeth on the gear..

The remaining marking on the mill side of the gear indicates the location of the broken weld at the locating pin, Figures 1, 4, and 5.

Part of the mill side of the gear has a wet appearance. The liquid feels like light oil. The pattern suggests the appearance of leaking out of the interior of the bull gear around Holes 2 and 3, which would presumably be sealed normally.

Orientation

Figure 7 presents a figure orienting and labeling the various features of the bull gear using the keyway as an angular location feature. The holes are labeled with numbers, starting with “1” at the keyway orientation. The load pads are labeled with letters, starting from “A” approximately 30 degrees clockwise from the keyway location.

The arbitrary 0o baseline location used by Mr. Wolf is approximately 60 degrees clockwise from the keyway orientation, as viewed on the motor side of the bull gear.

The so-called “heat zones” as labelled on the physical bull gear by Mr. Wolf (and corresponding to red regions on the LW drawing) are shown by blue arrows and labels. The broken weld on a locating pin is shown although this feature is on the mill side of the bull gear.

Clearance Measurements

The clearance between the ring gear and the hub were measured using a feeler gage at four locations near those measured by Mr. Luke Wolf, as recorded in the LW drawing. Each new measurement was the same as the ones reported by Mr. Wolf, within 0.002”.

Hardness Testing

Rockwell indentation hardness testing was performed on the ring gear motor-side face. The portable hardness device was first calibrated with a certified gage block of Rockwell C hardness of 44.87.

Small areas were ground to remove surface corrosion products at radial locations corresponding to the holes 1 through 6, on the ring gear approximately 1” from the ring gear / hub interface.


These locations are approximately the same as tested by Mr. Wolf using an alternate hardness testing device and scale. The results are compared in Table 1.

Table 1. Hardness testing results.

Keyway LW Scale? Rockwell C Std.

Hole #

angle (o)

angle (o)

LW reading Avg. Dev. 1 2 3 4 5 6

1 0 285 625 41 1 41 41 42 2 60 345 645 42 3 44 45 42 38 38 42

3 120 45 618 41 1 40 40 42 4 180 105 576 41 3 38 44 44 40 41 36

5 240 165 596 37 2 36 37 39 6 300 225 613 40 2 38 40 44 39 41

Black Material Removal Tests

A fairly narrow black area was examined and treated to test whether the black material was on top of the orange/pink paint, or whether the orange/pink paint had been converted to the black layer. The region can be seen on Figure 2 on the mill side of the bull gear, approximately ½ the distance from the bull gear center to the ring gear, in the sector having Hole 5 and Load Pad D. Figure 8 is a close-up of Figure 2 showing this region, with Hole 5 and Load Pad D visible. This region was selected because the black material appeared to be fairly thin there, hence it was hoped to be removable more readily.

Figure 9 shows a higher-resolution view of the same region (i.e. taken from a position closer to the bull gear) with a scale marker to provide a fixed location within the field of view.

Figure 10 shows the same location, but after cleaning along roughly horizontal lines using sand paper alone (bottom of the figure), lacquer thinner alone (applied and vigorously rubbed with a household scrubber), and brake cleaner (applied and vigorously rubbed with a household scrubber). It can be seen that where the black material has been removed, the orange/pink appearance has been recovered. That is, the black material is on top of the orange/pink paint or primer.

Figure 11 is of the same area, but the area previously cleaned with brake cleaner alone was subsequently sanded lightly using brake cleaner. It shows further removal of the black material, along the entire length of the scrubbing line.

Black Material Scraping

A region of black material was selected for further analysis as shown in Figures 12 and 13. This area was selected because the black material remained in the form if islands, some of which appeared to be peeling off. This promotes the removal of whole chips of the black material,


down to the metal or paint. In fact, this can be seen readily in Figure 13, where some of the black islands have been removed to the bare metal which has then rusted in the shape of the island. Black chips were collected as shown in Figure 14 by scraping with a putty knive into a clean paper towel, which was then folded and placed in a Ziploc bag.

Black Chip Analysis (January 23, 2012)

The chips bagged on January 19, 2012, were removed from the bag on January 23, 2012, in the Central Electron Optics Facility at the Ohio State University, Figure 15. Figure 16 shows the chips in a closer view, and shows that one side of the chips is a rusty/reddish color and the other side is black. Specimen preparation and SEM operation was performed by Cameron Begg, of the Central Electron Optics Facility.

One large chip was selected and was broken into two with a pair of tweezers. The shape of the broken edge was noted, and one of the broken pieces was cleaned ultrasonically in methanol, then mounted onto a scanning electron microscopy (SEM) stub, as shown in Figure 17. The broken chip, in the foreground of Figure 17, was placed vertically on the stage so that the broken edge pointed upward. The stub was then placed in a Philips XL 30 environmental scanning electron microscope with field emission gun.

Figure 18 shows a low-magnification view of the broken edge of the chip. Near the horizontal center of the chip is a vertical crack that can been in this overall view. This feature was used for location further analysis, and is visible in Figure 19 at higher magnification toward the upper left part of the field of view.

Two EDS (energy dispersive x-ray spectroscopy) spectra were taken, as shown in Figures 20 and 21. Figure 20 is from the elliptical feature on the broken surface just to the right of the crack, near the top surface of the chip. Figure 21 is from the region on the broken surface marked by a white “X”, near the bottom surface of the chip.

Figure 20 shows that the top part of the broken surface (as viewed in Figures 18 and 19) is composed predominantly of the elements iron and oxygen with traces of manganese (found in nearly all steels, typically around 1% by composition) and carbon.

Figure 21 shows that the bottom part of the broken surface (as viewed in Figures 18 and 19) is composed predominantly of carbon, with traces of oxygen, and iron.


Figure 1. Bull gear, motor side. (DSC02283.JPG)

Figure 2. Bull gear, mill side. (DSC02282.JPG)


Figure 3. Bull gear identification. (DSC02289 - Flipped Vertically.JPG)

Figure 4. Close-up of area of Figure 2. (DSC02282 - Crop1.jpg)


Figure 5. Alternate, higher-resolution view of Figure 4. (DSC_0385.jpg)

Figure 6. Close-up of black islands on orange/pink background. (DSC02273.JPG)


Figure 7. Schematic showing orientation of bull gear features.


Figure 8. Close-up of Figure 2 of region used to remove black layer. (DSC02282 - Crop2.JPG)

Figure 9. Alternate high-resolution close-up of Figure 7. (DSC02296.JPG)


Figure 10. Region of Figures 8 and 9 after cleaning. (DSC02309.JPG)

Figure 11. Region of Figures 8 and 9 after cleaning. (DSC02311.JPG)


Figure 12. Close-up of Figure 2 area for scraping. (DSC02282 - Crop3.jpg)

Figure 13. Alternate high-resolution view in region of Figure 2. (DSC_0398.jpg)


Figure 14. Collection of black chips. (DSC_0400.jpg)

Figure 15. Opening of bagged black chips, January 23, 2012. (DSC02320.JPG)


Figure 16. Close-up of black chips. (DSC02321.JPG)

Figure 17. Broken chip mounted on SEM stub (broken edge up). (DSC02323 Crop.jpg)


Figure 18. SEM low-magnification view of broken surface of black chip. (RW3.TIF)

Figure 19. SEM image of broken edge. Note crack at upper left of figure. The oval feature just the right of the crack is the location of EDS1. The white X near the right edge, center, of the view is the

location of EDS2. (RW7.TIF)


Figure 20. Energy –dispersive spectrum in the elliptical feature just right of the crack shown in Figures 18 and 19. (RWEDS1.tif)


Figure 21. Energy –dispersive spectrum at the location marked with an X in Figure 19. (RWEDS2.tif)

post-inspection report: failure of a bull...

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