Free Motion in Limine - District Court of Delaware - Delaware

Case 1:04-cv—O1275-KAJ Document 82-3 Filed 10/O3/2005 Page1 0f3
EXHIBIT "B"

· Qase 1 :04-cv-01275-KAJ Filed 10/O3/2005 Page 2 of 3
. Don’ s Hydraulics, Inc.
RR 7 Box 223C DE 19947 -
_ Phone # (3t)2)856~4545 Fax#(302)856·1874 ll __ I I-} —· Q ,2 O (
Thank you for theopportunity to visit with you and evaluate your three Hydraulic
SYSlZC'l]1S. K _ _ ” {*7
I found many things which need attention and correcting in all three hydraulic systems. .
Many of the thirteen pumps have excessive case drain flow which indicates the pump is
beginning to fail and will need replacing soon. One pump is rattling which should be replaced
immediately. All flow meters have failed and should be removed to reduce back pressure. Ifthey
are replaced they should be installed on a hy·pass loop so the G.P.M. could be checked then shut A
ofli All units should be pumped out, cleaned inside to remove sludge, suction screens cleaned
and or replaced as necessary. All sight! temperature gauges have been damaged by excessive oil
Temperature and need to he replaced. All pumps are required to operate the live present lines,
leaving no spare pumps. In case of a pump or motor failure it would be necessary to operate at
a much slower speed until the pump or motor is replaced. With a properly designed unit, .
downtime would be reduced to the time required to turn on a switch. -
Oil coolers are improperly sized for the present operation. The coolers in the system are - . _ i
plugged with dirt and debris to the point thatthere is very, very little air flow resulting in almost
no cooling. One cooler is improperly installed as another cooler discharges hot air into the intake .
of another cooler. Temperature switches which control the coolers are defective and/or
impr¤p¤r1yars¤a1aa· . ‘ .
. All till caps are either damaged, or missing. · . .
The resevoirs are uadersized either by design and/or additional pumps that have been
installed. This reduces the dwell time which causes heatand doesnft allow the air to escape ` l I
before being pumped again which damage to the pump and prematmepump :1
failure. Seven of the present pumps have horsepower motors where fiiiy horsepower- is `
- adequate. One pump, which was added, has the suction greatly reduced. The till cap was - e
removed and the suction line dropped thru the fill cap hole unsealed. 'I`he dischmge line is · . `
reduced and connected to another case drain line and a check valve installed which must be ‘
removed. " _ - ‘
All units have inadequate Eltration. -
_ _ The individual units downstairs and the individual units upstairs have the return lines n
— _ improperly installed. ‘
The main pressure and return pipes hom the hydraulic power units to the various pieces n
of equipment through out the plat are too small to carry the volume of oil necessaryto operate the _ i
equipment properly. In order to reduce the oil velocity in the piping you would need to add an
_ _ additional 3 inch pressure pipe and a_3 inch return line for each ofthe three systems. The drops to —`
the equipment should then be divided equally from the headers by y@gg not by pieces of I

._ Case 1 :04-cv—O1275-KAJ Document 82-3 Filed tO/O3/2005 Page 3 of 3
The present resevoirs do not have adequate capacity for the volume of oil needed nor are .
they designed to accommodate the required retention time to allow the air to escape from the oil .
before being pumped again as I noted in a previous paragraph This must be designed in the
resevoir toprolong the life of the pumps, motors, hoses, and valves.
The high pressure iilters on the various pieces of equipment have been reduced with
bushings and hoses restricting the volume. These should be increased to full size to allow hill
volumetric flow. - n
These problems did not ar1·ive overnight} They have multiplied over the years by adding J
to the systems with little or no help from the suppliers. ` .
Following this report I’11 send a- quote to correct these problems 1’ve mentioned in this
report. Please feel free to call me any questions you have reguarding this report or any other
. .
I Thank You . _ - `
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