DEPOSITION OF ADMIRAL DAVID W. TAYLOR.
DISTRICT COURT OF THE UNITED STATES
For the Southern District of New York,
In the Matter
The Petition of the Oceanic Steam
Navigation Company, Limited, for
limitation of its liability as owner
of the Steamship
Deposition of ADMIRAL DAVID W. TAYLOR, Chief Constructor, United States Navy, taken in pursuance of notice, at the City of Washington, D. C., this 4th day of June, 1915.
A p p e a r a n c e s:
HUNT, HILL & BETTS, (FRANCIS H. KINNICUTT, ESQ., of Counsel), Proctors for Claimants;
BENJAMIN MICOU, ESQ., Counsel for Claimants;
A. LEONARD BROUGHAM, ESQ., Proctor for Claimants;
BURLINGHAM, MONTGOMERY & BEECHER (BENJAMIN W. WELLS, ESQ., of Counsel), Proctors for Petitioner.
It is hereby stipulated that the deposition is taken subject to all legal objections to be taken at the trial of this proceeding, except objections as to form of questions and answers. Certification of the deposition is hereby waived by all parties.
DAVID W. TAYLOR, being duly sworn, deposes as follows:
DIRECT EXAMINATION BY MR. KINNICUTT:
Q. Admiral Taylor, kindly state your present position in the United States Navy.
- Chief Constructor, Bureau of Construction and Repair, Navy Department.
Q. How long have you been connected with that department?
- Since October, 1881, in the Navy Department.
Q. Will you kindly state in what naval schools you graduated.
- I graduated from the Naval Academy at Annapolis, Md., in 1885; and the Royal Naval College, at Greenwich, England, in 1888.
Q. Will you kindly tell me your duties as Chief Constructor?
- My duties as Chief Constructor comprise, broadly, the responsibility for the design and construction, and also repair, of the hulls of naval vessels.
Q. What is your experience, which will enable you to testify as an expert with regard to the construction of ships?
- As a part of my professional duty in the Navy Department I have had charge of the design and construction of a number of vessels of the United States Navy.
Q. Have you acted on any committees the duty of which was to examine into the practical construction of merchant vessels with reference to making them safe as against under-water damage?
- In 1913 I was appointed on a committee under the Department of Commerce and Labor to do preliminary work in this country in connection with the International Conference for the Safety of Life at Sea.
Q. Did you while on this committee make a study of ship construction with reference to safety at sea?
- The main duty of this committee was to obtain information in connection with the question of ship construction, for the use of the American delegates to the International Conference. This required a good deal of investigation of the matters you refer to.
Q. Did you make such an investigation?
Q. Had you previously a general knowledge of the construction of ships generally, under both the Navy and otherwise?
- Generally, I had.
Q. Now at the time the Titanic was built, will you describe the means which were used in the shipbuilding art for providing against the foundering of a vessel in consequence of anticipatable injuries to the hull?
- The principal method in use at that time was subdivision of the interior of the hull by means of watertight bulkheads and flats, or decks; also the use of inner skins, with watertight subdivisions between the skins.
Q. In the use of the term "inner skins" do you mean to include double bottoms?
Q. In the use of the term "flats or decks" in the next to the last question and answer, do you refer to watertight decks or flats?
Q. And watertight bulkheads?
- Watertight bulkheads.
Q. Were these various devices known as far back as the Great Eastern, in 1858, or since that time?
- They were known for a great many years, and to the best of my recollection they were all incorporated in that ship.
Q. Do these various devices, generally speaking, serve to protect the ship in case of under-water damage?
- Yes; the object of all of them is to limit the water which may pass through the bottom, when damaged, and prevent its indefinite entry into the hull.
Q. You mean to limit it to the bottom?
- In speaking of bottom I meant the whole outer skin of the ship below water.
Q. Have watertight decks or flats and watertight longitudinal bulkheads been used in the United States Navy?
Q. Are both devices usually employed in the ships of the United States Navy?
- Yes, in all vessels of any size.
Q. Have they proved to be advantageous for the purposes mentioned?
Q. Is there any reason that you know of why these same devices which are useful for the protection of battleships would not be useful for the protection of merchant ships, against under-water damage?
Q. Will you state the advantages of watertight decks with respect to limiting the flooded portion of the vessel in the case of under-water damage?
- The object of a watertight deck is to prevent the water rising vertically in the vessel, the watertight deck constituting a horizontal barrier; with transverse bulkheads alone the water in the pierced compartment will always rise in the interior to the level of the water outside. If there is a watertight flat or deck in this compartment, the water will not rise above this watertight flat in case the damage is below this flat, and will not pass below the flat in case the damage is above the flat.
BY MR. BROUGHAM:
Q. Assuming a continuous watertight deck placed just above the waterline in the ship, the watertight deck then would confine the water below, if the damage occurred below the waterline, would it not?
Q. And assuming the same kind of deck, if the damage occurred above the watertight deck it would be, necessarily, above the waterline, and the water would not get in at all; is that so?
Q. And assuming the same kind of a deck, if the damage was both above and below the watertight deck, the water would enter the compartment first below the watertight deck, and then, if the submergence was great enough, the water would then enter the compartment above the watertight deck, would it not?
Q. But the only effect of that would be to destroy the watertightness of the watertight deck for that one compartment, or two, at most, and the result would be the same as, and no more serious than it would be had the watertight deck not been made watertight; is not that so?
I object, for the reason that this question and the several preceding questions are absolutely leading, and the witness should be allowed to make his own answers and not have the lead of counsel.
Q. So that with a watertight deck raised above the waterline, wherever the watertight deck serves its purpose, the purpose for which it was intended, it would be a measure of safety to the ship, would it not?
- Wherever it prevented the water rising above its level, it would undoubtedly add to the safety of the ship.
Q. Now in your opinion is it or is it not advisable, from the standpoint of safety to the ship, to have the watertight deck placed above the waterline?
- That depends somewhat upon the type of vessel.
Q. Will you extend your answer so that we may understand the specific point you have in mind?
- In the case of a vessel such as an ordinary cargo vessel of comparatively low freeboard, there would be little advantage from a watertight deck above the waterline, for the reason that the volume of reserve buoyancy between such a deck and the upper deck of the vessel would be comparatively small, and hardly worth protecting. In the case of a vessel of the passenger type, or any vessel with a high freeboard forward such as passenger vessels have, the reserve buoyancy between a watertight deck a short distance above the waterline, and the upper deck, or decks, at the height of the bulkheads, would be large and well worth protecting, from the point of view of safety.
Q. Now it has been suggested in the evidence that if the watertight deck were placed below the waterline there would be danger of the ship turning turtle, in case of injury to the hull above the deck but below the waterline. What is your opinion as to that, with reference to the necessary extent of injury to the hull required to bring into the situation any danger of turning turtle?
- In the case you have described, there would undoubtedly be a reduction of stability of the vessel due to the presence of the water on the top of the watertight deck, but the amount of danger would depend upon two factors: the horizontal area of the compartment to which the water is admitted, and the original stability of the vessel. In case of a small compartment, with a vessel having an ample margin of stability, the danger would be negligible. In the case of a margin of stability so small that it would be wiped out by the loss due to the admission of the water, the danger would of course be great.
Q. Now with a passenger vessel of about forty-six thousand tons, subdivided into sixteen compartments and designed to float with any two compartments flooded, would an injury which occurred below the waterline but above a watertight deck placed below the waterline, so as to let the water into those two compartments, have the effect of causing the ship to turn turtle because of the imprisoned air below the watertight deck, in those two compartments?
I object to the question, because it does not accurately describe the construction of the Titanic, as there were fifteen transverse watertight bulkheads, but there were more than sixteen watertight compartments in the ship.
- That would depend very largely upon the initial metacentric height of the vessel and its freeboard. It is a question which could be answered positively only by an investigation with these factors known.
Q. Then as I understand it, there is more or less difficulty in placing watertight decks below the waterline in such a position as to guard against the possible danger of the ship turning turtle under certain conditions of injury; is that right?
- A watertight deck in such a position would undoubtedly materially diminish the stability of the ship in case of damage allowing water on top of it, and would increase the danger of the ship turning turtle. Whether it would actually cause the ship to turn turtle would depend upon the detailed conditions, as already referred to.
Q. Would these same objections exist if the watertight deck were placed above the waterline, in a large passenger steamer, with plenty of freeboard and reserve buoyancy above the waterline and above the watertight deck?
- In my opinion a watertight deck in such a vessel, at a height above the waterline of say a quarter of the draft of the vessel, would in practically all possible cases of damage add materially to the safety of the ship, and not involve any risk of turning turtle.
Q. In the case of longitudinal bulkheads placed at the side of the vessel, in the position generally in which they are in the Mauretania, is it an advantage to have the watertight deck placed at the top of the longitudinal bulkheads forming the inner sides of the coal bunkers?
- It would be an advantage in the case of damage below the deck; in case the deck was so located that damage permitted the water to enter on top of it, it would be open to the same objection as the watertight deck below the waterline, already referred to.
Q. In case such longitudinal bulkheads at the side are placed (in a large passenger steamer with plenty of freeboard and reserve buoyancy above the waterline) in such a way as to extend well above the waterline, and are topped by watertight decks, would an injury to the side of the vessel below the waterline, flooding the compartments on one side of the vessel which are bounded by the longitudinal bulkheads, cause the ship to turn turtle?
- It would cause the ship to incline towards the damaged side. Whether it would cause the ship to turn turtle or not would depend upon the original stability and the amount of water admitted by the damage. In other words, upon the number and size of the compartments to which the water was admitted.
Q. Is or is there not any difficulty, as a matter of practical shipbuilding, in designing a ship so as to guard against the danger of a ship having such longitudinal watertight bulkheads turning turtle in case of injury to the hull?
- That is a matter which we have to consider a good deal in connection with vessels of war subject to under-water damage by torpedoes, or shells. It is our practice when we believe that flooding a wing compartment, as we call it, would produce objectionable heel, or list, to cross-connect this compartment with the corresponding compartment on the other side. In this way we get double sinkage, which is usually negligible, and no resulting heel.
Q. How is that done, specifically?
- Simply by pipes of suitable size connecting the lower parts of the compartments in question.
Q. Is there any difficulty, and if so what, in getting bulkhead doors to close, through the coal that may be in compartments enclosed by these longitudinal bulkheads?
- If there is coal over the sills, or bottoms of the watertight bulkhead doors, there is difficulty, due to the fact that the door is obstructed in closing, or prevented from closing.
Q. Does that furnish a practicable objection to the use of such longitudinal bulkheads, having such bulkhead doors?
- I do not understand what you mean by "practicable".
Q. I meant to say practical objection.
- That is undoubtedly a practical objection.
Q. To what; to the use of such bulkheads?
- To the use of such doors -- I would like to modify that to make it to the use of such bulkheads having such doors liable to obstruction. Any door in a bulkhead is a source of danger to the integrity of the bulkhead, and if it is liable to be obstructed by coal or rubbish it is a greater objection than a door not exposed to such danger.
Q. Now how do you prevent exposing the bulkhead doors in such longitudinal bulkheads to such danger, as a practical matter?
- As a practical matter we try to keep the bottoms of these doors well above the bottom of the bunkers, so that there is no reason for coal to accumulate on the sill, except through carelessness. We also try to provide special hoods inside of the doors, so that coal will not, naturally, roll down against the doors.
Q. In ships of the United States Navy do they have coal bunkers at the side between the hull of the vessel and longitudinal bulkheads containing watertight bulkhead doors?
- In vessels of the Navy in practically all cases we have outboard of the boiler rooms coal bunkers separated from the boiler rooms by longitudinal bulkheads. In some cases these bankers extend to the outer hull of the vessel; in other cases they do not, there being intermediate bulkheads. These are intended to provide additional safety against external explosion.
BY MR. KINNICUTT:
Q. In regard to the accidents that may happen to a large passenger ship on the Atlantic Ocean, are there accidents of a nature reasonably to be anticipated which would open the vessel to a considerable distance along the side, and below the waterline?
- Such accidents are very possible of course.
Q. Will you enumerate the kinds of accident that would make such damage possible?
- A collision with a derelict, for instance stance, is one case where there would be danger of such damage, or a collision with an iceberg, or a scraping collision with another vessel.
Q. Well I suppose in mentioning icebergs you would include low-lying floating ice, of sufficient size to damage a vessel, would you not?
- Yes; any floating body of sufficient size is liable to cause such damage.
Q. Having in mind an ocean liner carrying passengers on the Atlantic, and a vessel over 800 feet in length, divided into sixteen or more compartments by transverse watertight bulkheads, what is your opinion as to whether the construction of such a vessel so that it would float with any two adjacent compartments flooded, would be sufficient to protect the vessel from foundering in case of accidents such as you have enumerated in answer to the last question?
- If the vessel was safe with only two compartments flooded, an accident such as is referred to in the last answer which admitted water freely to more than two compartments would undoubtedly cause the foundering of the vessel.