ML19351A702

Intervenors Motion to Modify Hearing Schedule.* Requests That Hearing Be Rescheduled During Period of 900219-0302 Due to Inability of Expert Witness,G Sih,To Testify at 900110 Hearing.W/Certificate of Svc

ML19351A702
Person / Time
Site:	Turkey Point
Issue date:	12/04/1989
From:	Lorion J CENTER FOR NUCLEAR RESPONSIBILITY
To:	Atomic Safety and Licensing Board Panel
References
CON-#489-9588 OLA-4, NUDOCS 8912260124
Download: ML19351A702 (9)

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'::':iiU-UNITED STATES OF AMERICA 4 NUCLEAR REGULATORY COMMISSION

'89 0F -8 P 2 :46 l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .]

l In the Matter of )

Florida Power & Light Company Docket Nos. 50-250 OLA-4

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(Turkey Point Plant ) (Pressure / Temperature Limits) l Units 3 and 4) ) {

) H INTERVENORS' MOTION TO MODIFY HEARING SCHEDULE Intervenors, the Center for Nuclear Responsibility-and Joette Lorion,.hereby file this Motion to Modify Hearing Schedule <

pursuant to-10 C.F.R. 2.711 and request that the hearing in the above captioned proceeding be rescheduled some time during the period February 19 through March 2, 1990.

In support of this motion to modify the hearing schedule Intervenors list the following good cause reasons:

1. Intervenors who have been unable to retain Dr. George Sih, Director of Fracture Mechanics, Lehigh University, as an expert witness for financial reasons have received a commitment from persons in the local community that they will raise the funds necessary for Dr. Sih to testify. Upon receiving this commitment a little over a week ago, Intervenors contacted Dr. Sih to inquire whether he would be able to testify at the January 10, 1990 hearing.

8912260124 891204 PDR ADOCK 05000250 0 PDR

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Dr. Sih informed Intervenors that he would not mind coming down

-to testify on Intervenors' beFalf but he would be out-of'the country on the hearing date. Intervenors then requested that Dr. Sih provide.them with alternative dates-that he would be i

available to testify and were informed that due to his professional responsibilities, the only dates that Dr. Sih could appear as an expert witness would be any day during~the period beginning on February 19, 1990 and ending on March 2, 1990.

Intervenors' contend that the slight delay that modification of the hearing schedule would cause is justified by the fact that D . George Sih, who is an eminent scientist and expert in the field of fracture mechanics would assist Intervenors in developing a sound and balanced record in this proceeding. It is no doubt that without the expertise that Dr. Sih can provide, Intervenors case will be severely limited.

2. The slight delay requested by Intervenors will not hardship the parties, since the license amendments that are the subject of this proceeding have already been granted. Additionally, this proceeding has been pending just over a year. This is not a long time considering the complexity and gravity of the technical issues involved - technical issues that deserve a full airing.

Thus, for all the above reasons, Intervenors request that this Board grant Intervenors' Motion to Modify Hearing Schedule and reschedule the hearing some time during the period beginning February 19, 1990 and ending March 2, 1990. Intervenors contend

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( 3) they have met the good cause requirements for requesting that-the Board take this action and respectfully request that their motion should be granted.

Finally, Intervenors contend that modifying the hearing schedule so that Dr. George Sih can provide expert witness testimony on behalf of the' Intervenors in this proceeding is in the interest'of the public health and safety and would provide a' forum that would allow the serious technical issues involved in this proceeding to be aired before the public in a fair and balanced manner, Respectfully submitted, 4-b Joette Lorion Director, Center for Nuclear Responsibility l

7210 Red Road #217 Miami, Florida 33143 (305) 661-2165 L (305) 662-2600 I

. Dated: ' December 4, 1989 1

Enclosure:

. Biography of Dr. C.M. Sih l

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Biography- l of Dr. George C. M. Sih l Professor of Mechanics and Director of the Institute of Fracture and Solid Mechanics Dr. Sih is currently Professor of Mechanics and- Director of the Institute l

-1 of Fracture and Solid Mechanics at Lehigh University, Bethlehem, Pennsylvania.

He also holds the appointment of Adjunct Professor at The Hahnemann Medical Col-l 1ege and Hospital of Philadelphia since 1972. He received his B.S. at the Uni-versity of Portland, Oregon,1953; his M.S. at New York University,1957; and Ph.D. at Lehigh University,1960; all of these degrees in Mechanical Engineering.

Dr. Sih has engaged in research in the interaction of mechanical defonnation and heat flow (1960) supported by the Koppers Foundation, in Fracture Mechanics (1960 and 1961) for >ae Boeing Company Transport Division and (1962 to 1965) for the National Science Foundation, and as a member of the Technical Staff, Bell Telephone Laboratory (Sununer 1961). He has been engaged as Principal Investigator-t in more than fifty projects at Lehigh University sponsored by the Office of Naval Research, Naval Research Laboratory, the National Aeronautics and Space Adminis-tration, the Air Force, the Army, etc., all of which are cancerned with opti-i mizing the use of high performance material with design, a discipline that has l'

- been frequently referred to as " Fracture Mechanics". Much of his work has been L-I concerned with estimating the remaining life of material and structural components damageo by yielding and/or fracture. He specializes in developing computer soft-ware for predicting the mechanical behavior of structures and the stability of objects moving through fluid media. His more recent activities are concerned with the influence of moisture and temperature in composite materials, laser glazing techniques and non-destructive testing methods involving high-voltage electrophotography. ,3,

from.19S3 to 1967, Dr. Sih was employed by Radio Corporation of America as a project and research engineer. He worked on the research and development of

input and output devices for the first generation "Bizmark"L computer system.

Among the significant patents he obtained were:  ;

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.1. Adjustable optical system for line printing.

2. Automatic magnetic disc printing device for the Xerox process In 1957 and 1958, Dr. Sih returned to the academic life and served at the City College of New York as Lecturer in Mechanical ~ Engineering. He came to Lehigh University in 1958 as Instructor in Engineering Mechanics and was appointed

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Assistant Professor after completion of his doctorate. From 1965 to 1966, Dr. . Sih held the position of Visiting Professor in Aeronautics at the California Institute of Technology and participated in an Air Force research project on the dynamics of crack propagation and size effects in the fracture of- plates.

Dr. Sih assumed in 1970 the duties of Regional Editor, International Journal of Fracture Mechanics, and the responsibilities of soliciting and reviewing papers in the field of Fracture Mechanics. From 1971 to 1975, he served as an Associate Editor of the ASME ' Journal of Applied Mechanics. He is also on the Editorial Ad-visory Board of the Journal of Engineering Fracture Mechanics. He is also Editor-in-Chief of an International Journal of Theoretical and Applied Fracture Mechanics.

Dr. Sih is a Fellow of the American Society of Mechanical Engineers and Honorary Fellow of the International Congress of Fracture. He is also a founding member of the International Cooperative Fracture Institute, an organization established to promote the interchange of ideas and infonnation among active researchers in fracture mechanics.

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. Dr. Sih is also a mImber of the following societies:

l'. Society of Sigt.a Xi r

2. ASTM Committee E-24 on Fracture Testing of Materials r 3.. International Society of Engineering Science

4. American Society of Civil Engineering-

5. . American Society of Mechanical Engineering

6. International Society for the Interaction of Mechanics and Mathematics Dr. Sih is the Editor of three book series. Seven volumes on the Mechanics of Fracture series have been or are about to be published:

Volume I - Methods of Analysis and Solutions to Crack Problems,1973 Volume II - Three-Dimensional Crack Problems,1974 Volume III - Plates and Shells with Cracks,1976 Volume IV - Elastodynamic Crack Problems,1976 Volume V Stress Analysis of Notch Problems,1976 l Volume VI - Cracks in Composite Materials,1980 L

Volume VII - Experimental Evaluation of Stress Concentration and' Intensity L

Factors, 1980 L

The two other series are Fatigue and Fracture:

Volume I - Fatigue and Fracture, S. Kocanda,1978

' Volume II - Fracture Micromechanics of Polymer Materials, V. S. Kukshenko and V. P. Tamuzh, 1980 l- and Engineering Application of Fracture Mechanics:

1 l Volume I - Fracture Mechanics Methodology: Evaluation of Structural Compo-nents Integrity, edited by G. C. Sih and L. Faria 1

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?? I Volume II - Mixed Mode Crack Extension by E. C. Gdoutos Volume III - Fracture Mechanics of Concrete: Material Characterization and Testing, edited by A. Carpinteri and A. Ingraffea-  !

Voltme IV - Fracture Mechanics of, Concrete: Numerical Analysis and Structural- Application by G. C. Sih and A. DiTommaso Volume V

- Bonded Repair of- Aircraft Structure by A. A. Baker and R. Jones Volume VI - Crack Growth and Material Damage in Concrete: Limit Load and Brittle Fracture by A. Carpinteri Dr. Sih has also served as principal organizer and editor of proceedings of several conferences:

1. International Conference on " Dynamic Crack Propagation", (1972), Leh5 a j University t 2.

L International Conference on " Prospects of Fracture Mechanics", (1974),

The Netherland:

3. Conference on " Linear Fracture Mechanics", (1975), Lehigh University L

4. International Conference on " Fracture Mechanics and Technology", (1976), 4

' Hong Kong

5. 14th Annual Meeting of the Society of Engineering Science, (1977), Le-

! high University

6. First USA-USSR Symposium on " Fracture of Composite Materials", (1978),

USSR

7. International Conference on " Fracture Mechanics in Engineering Applica-tions",(1979), India l

8. International Conference on " Analytical and Experimental Fracture Me-l- chanics", (1980), Italy

9. International Conference on " Defects and Fracture", (1980), Poland

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10. International Conference on " Mixed Mode Crack Propagation" -(1980),

Greece

11. International Conference on " Absorbed Energy and/or Specific Strain En-ergy Density Criterion", (1980), Hungary

12. International Conference on " Defects Fracture and Fatigue", (1982),

Canada

13. International Conference on " Fracture Mechanics Technology Applied to Material Evaluation and Structure Design", (1982), Australia

14. International Conference on " Application of Fracture Mechanics to Ma-terials and Structures". (1983), Germany Dr. Sih has approximately two hundred publications principally in the area of solid and fracture mechanics. He has authored and co-authored a total of three books. .

1. Handbook of Stress Intensity Factors,1973

2. Three Dimensional Crack Problems (with M. K. Xassir),1974

3. Cracks in Composite Materials (with E. P. Chen),1980 E- Dr. Sih received the 1975 Achievement Award from the Chinese Institute of Engineers in the United States and the 1984 Achievement Award from the Chinese Engineers and Scientists Association of Southern California for his accomplishments L in research and teaching in fracture and solid mechanics.

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Dr. Sih has also been active in serving as members of national comittees.

Among them are the National Materials Advisory Board concerning with thc Dynamic L=

l Response of Materials Subjected to High Strain Rate Loading; Ship Materials Fab-rication and Inspection; and other comittees concerning Nuclear Reactor Compo-nents.

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..si,. I UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION l BEFORE THE ATOMIC SAFETY AND LICENSING BOA p OEC -8 P2 :46 I In the Matter of ) yM . ,

vCC r.:. ,. >, -

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) Docket Nos. 50-250 OI AY -

FLORIDA POWER & LIGHT CO. )- 50-251 OLA

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u (Pressure / Temperature Amendments) n s nd CERTIFICATE OF SERVICE I hereby certify that copies of "Intervenors' Motion to Modify Hearing Schedule" and "Intervenors' Supplemental Response to Licensee's Discovery Requests, Interrogatory I. ( A-B) " have been served on the following parties by deposit in the United States Mail, First Class,. Postage Prepaid on the date shown below:

Dr. Paul Cotter John T. Butler Atomic Safety & Licensing Board Steel, . Hector & Davis LU.S. Nuclear Regulatory Commission 4000 SE Financial Center Washington, D.C. 20555 Miami, Florida 33131 Glenn O. Bright .' Steven P. Frantz Newman & Holtzinger.P.C.

Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission 1615 L. Street NW Washington, D.C. 20555 - . Suite 1000 Washington, DC 20036 Jerry Harbour Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Janice Moore W C%

Office of General Counsel Joette Lorion U.S. Nuclear Regulatory Commission Director, Center for Washington, D.C. 20555 Nuclear Responsibility Dated: December 4, 1989 Miami, Florida 33143 (305) 661-2165