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stango_deposition_comments - Comments on Mooney...

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Unformatted text preview: Comments on Mooney Engineers’ Calculations sundatedz RTR 7/24/2006 THERE APPEAR TO BE NO CALCULATIONS AT ALL RELATED TO VERTICAL LOAD TRANSFER ACROSS THE WELDED STEEL CONNECTION BETWEEN ADJACENT DOUBLE-Ts IN THE DESIGN CALCULATIONS. Comments on Victor Stango’s deposition of July 14, 2004 Q & A regarding Mooney Engineers’ design calculations begins on page 104. Q & A regarding TT-to-TT connection begins on page 119. Page 123: 20 Q. All right. Do you see any 21 calculations which would address the question of 22 bearing loads? 23 A. I did not see any in here, no. Page 182: 18 Q. So now we're talking about vertical 19 loads as the traffic goes across? 20 A. Yes. 21 Q. Now, anywhere in the calculations 22 that you did -- Victor, when I was looking . 23 through them, I could not find any calculations Page 183: 1 having to do with the suEerimEosition of 2 vertical loads as the traffic went across the 3 double tees. Are there any such calculations 4 among your dgcgments? 5 A' EWQEQLEMEEQEL 6 Q. Do you remember making those 7 calculations? 8 A. I do not remember making those 9 calculations. HE DID NOT DO VERTICAL LOAD TRANSFER DESIGN CALCULATIONS. Page 188: 14 Q. What would you say that allowable 15 stress is? 21 THE WITNESS: 20,000 PSI. 22 Q. (By Mr. Carbone) 20,000 PSI. So 23 if you do that arithmetic and multiply by 20,000 21,000 is probably more Q. What would the strength of that weld be? THE WITNESS: I would have to multiply out these numbers. Q. (By Mr. Carbone) Let's see. If we had a .7, three times, that's .75. So .7 times .75 is what, .5? So .5 times twenty-one is ten? Page 190: A. About .52 times twenty—one would be about 11,000 pounds. Page 193: If it is actually installed as designed, there's substantiallx more capacity in one of those connecting plate connections to carry more than 2,500 pound wheel load; is that right? A. Yes. All right. Allowable stress times weld area is tension or shear allowable. HE NEGLECTS THE BENDING ACROSS THE WELD, WHICH CREATES VERY LARGE FLEXURAL STRESSES. THE STRENGTH OF THE WELD TO TRANSMIT A VERTICAL LOAD IS FAR LESS THAN 11,000 POUNDS. HE NEGLECTS THE IMPACT FACTOR. ALSO, HE NEGLECTS THE FACT THAT THE LOAD APPLICATION IS REPEATED THOUSANDS OF TIMES AND THE F ATIQUE STRENGTH OF THE WELD UNDER REPEATED LOADS IS FAR LESS THAN THE STATIC STRENGTH. HE IS EITHER IGNORANT TO STRESS ANALYSIS AND FATIGUE STRENGTH OR MISLEADING IN HIS ANSWERS. THE QUESTIONING ATTORNEY IS NOT ASKING THE RIGHT QUESTIONS HERE. CommentsOnMooneyEngrsCaIcuIations ...
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