ML20084P065

Affidavit of Gc Sih Re Licensee 840224 Motion for Summary Disposition on Each of TMI Alert & Joint Intervenor Contentions.Certificate of Svc Encl.Related Correspondence

ML20084P065
Person / Time
Site:	Three Mile Island
Issue date:	05/03/1984
From:	Sih G LEHIGH UNIV., BETHLEHEM, PA
To:
References
OLA, NUDOCS 8405170392
Download: ML20084P065 (9)

Text

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• a qtUT:D CC  ; EOF;DENCE DOCKETED UNITED STATES OF AMERICA G PC NUCLEAR REGULATORY COMMISSION "84 MY 17 Al0:09 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD xFFCE cp u0 N T p <;3 g. p ..r 3g In the Matter of )

ufU NCH METROPOLITAN EDISON COMPANY ) Docket No. 50-289 ()(J I

) (Steam Generator Repair )

(Three Mile Island Nuclear )

Station, Unit No. 1) )

AFFIDAVIT OF DR. GEORGE C. SIH I, Dr. George C. Sih, being duly sworn do depose and state that:

1. I am Director of the Institute of Fracture and Solid Mechanics, Lehigh University. A copy of my professional qualifications is attached.

2. During the week of March 19, 1984, I was requested by Joanne Doroshow of Three Mile Island Alert to examine pages 27-32 of

" Licensee's Motion for Summary Disposition on Each of TMIA's and Joint Intervenors' Contentions," dated February 24, 1984, and if said document contained facts or opinions with which I professionally disagreed, to furnish Three Mile Island Alert with comments on said document.

3. I prepared such comments, which are set forth in the attached

" Comments on Response by TPR and the Staff: Ref: pp. 27-32", which makes reference to the pages within Licensee's Motion for Summary Disposition on Each of TMIA's and Joint Intervenors' Contentions, dated February 24, 1984, and sent them to Three' Mile Island Alert on March 27, 1984.

8405170392 840503 pO N PDR ADOCK 05000289 G PDR

4. I certify that I have personal knowledge of the matters set forth in the above-referenced comments, and in the attached " Statement to Hearing on TMI Restart: Steam Generator Tube Repair" which I presented in testimony before Senator Arlen Specter during U.S. Senate hearings held in Harrisburg on December 16, 1984.

3. I certify that the statements made in the above-referenced attachments are true and correct to the best of =y-knowledge and belief.

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' /s l Dr. George C. Sih Subscribed and sworn to before me this c 4 day of May, 1984.

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Notary Public

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Biography of Dr. George C. v. Sih Professor of Mecnarics and Director of the Institute of Fracture and Solid Mechanics Dr. Sih is currently Frofessor o' Mechanics and Director of the Institute of Fracture and Solid Mechanics at Lerigh University, Bethlehem, Pennsylvania.

Pe also holds the apacirstrent of Adf r:t Orc'essor at Tne Hahnenann Medical Col-lege ar.d Hcscital of Fnilaceip"ia s r:e 1972. Fe receivec nis 5.5. a :ne Uni-

'sersi:y of Por ar::, Oreg:r.,1952; r.is v.5. a: 'e. York University, 1957; and Pn.D. at Lehigh Uriversity,1960; all of these degrees in Mechanical Engineering.

Dr. Sih has e . gaged ir researhh in ne interaction of rechar.ical de#omation and heat flow (1960} sur:c-ted by the Ko:cers Foundation, in Fracture vechanics (1960 and 1961) foe the Eceing Corpary Transport Division and (1962 to 1965) for the National Science Four.dation, and as a menber of the Technical Staff, Bell Telephone Laboratory (Surrer 1961). He has been engaged as Principal Investigator 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 Amy, etc., all of which are concerned with opti-mizing the use of high performance material with design, a discipline that has been frequently referred to as " Fracture Mechanics". Much of his work has been concerned with estirating the remaining life of raterial and structural components damaged 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 act;vities are concerned with the influence of moisture and tenperature in composite materials, laser glazing techniques and non-destructive testing methods involving high-voltage .

electrophotography. _)_

l From 1953 to 1957, Dr. Sih was employed by Radio Corporation of America as a project and research engineer. He *crked on the research and develcomnt of input and output devices for the first gererat or. "Biznark" corouter system.

Among the significant patents he obtained were:

1. Adjustable optical system for line printing.

2. Automatic magnetic disc printing device for the Xerox process.

I '95' and '952, ; . SiF -etur.ed :: tre arice-tc life and served at the City College of Ne,c verk as Lecturer in we :tanical Engineerinc. He cam to Lehigh University in 195E as Instructcr in Encineering Mechanics and was 2Doointed Assistant Professor after completion of his doctorate. From 19E5 to 19EE, Dr. Sih i held the position of Visiting Professor in teronautics at the California Institute of Technology and partici ated in an Air Fcece research croject on the dynamics of craci prcpagation and si:e effects in t'ie fracture o' 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 Pechanics. 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.

i 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 rienber of the International Cooperative Fracture Institute, an organization established to promote the interchange of ideas and infonnation among active researchers in I

fracture mechanics.

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

1. Society of Sigma Ai

2. ASTM Corrittee E-24 on Fracture Testing of Materials

3. Irteenational Society of Engireering Science

4. American Society of Civil Engir.eering

5. American Society of Mechanical Engir.eering

f. Inte- a:4c-!? So:iety f::- :ne :t:e-c::io c' Mechar.ics and Ma he atics Dr. S4h is tne Edi:cr of th-ee ec6 se-ies. Seven volu,es on the Me:*ar.ics of Fracture series have been or are ascat ic be Dublished:

Volume I - Methods of Analysis and Solutions to Crack Froblems,1973 Volume II - Tnree-Dinensional Crack Prcblems,1974 Volu e III - Flates and Shells aitn Cra:Ls, 1976 Volume IV - Elastodyr.anic Crack Proble-s,1976 Volume V - Stress Analysis of Notch Problens,1976 Volume VI - Cracks in Composite Materials, 1980 Volume VII - Experinental Evaluation L. Stress Concentration and Intensity Factors, 1980 The two other series are Fatigue and Fracture:

Volume I - Fatigue and Fracture, S. Kocanda, 1978 Volume II - Fracture Micronechanics of Polymer Materials, V. S. Kukshenko and V. P. Tamuzh, 1980 and Engineering Application of Fracture Mechanics:

I Volume I - Fracture Mechanics Methodology: Evaluation of Structural Compo- )

nents Integrity, edited by G. C. Sih and L. Faria

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Volume II - Mixed Mode Crack Extension by E. E. Gdoutos Volume III - Fracture Mechanics cf Concrete: Material Characterization and Testing, edited by A. Carpir,teri and A. Ingraffea Volume IV - Fracture Mechanics of Concrete: Numerical Analysis and Structural Application by G. C. Sih and A. DiTorraso 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 E-i :le Fracture by A. Cartir:ed Dr. Sin tas also ser.ed as princical orgarizer and editor of proceedings of several conferer:es:

1. International Conference on " Dynamic Crack Propagation", (1972), Lehigh University

2. Ir:ere.atw.a1 Ccrference or. *Frespects of Fracture Mechanics", (19M),

The Netherlands

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

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

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-t l tions", (1979), India

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 Cor.ference on "M'=ed vo de Crack Fropa9ation", (1930),

, Greece l'.  :- errati:tal :: #ere :e c '*:s:-re: Erecc a-d/c- 5:ecifi: 5:-air E-er; De-s':. Criterior.', (1930', Fa :ary r

l '. 2 . Ir:er a i: a' Conferer.:e or ' De#e::s, Fra :ure anc Fatigae, (1952),

Canata

13. International Conferer.:e en "Fra::ure Mechanics Technolocy Applied to Material Eva'ua # e an: 5rs::;<e :es':r', (19E2), Aus tral'a

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2. Tr.ree Dirersic a' :ra:k Pr:t'e s (with v. M. Kassir),197a

3. Cracks in Co posite Materials (witn E. D. Chen),1933 Dr. Sih received the 1975 Achieve ert A ard fror the Chinese Irstitute of Engineers in the United States and the 1934 Achievement Award from the Chinese Engineers and Scientists Assoc'iation of Southern California for his accomplishments in research and teaching in fracture ar.d solid r.e:hanics.

3 Cr. Sir nas als: tes active ir service as +-bers of ratior.al conr.ittees.

i Among ther,are the .Natfor.a1 Materials Advisory Board cor. erning with the Dynanic Response of Materials Subjected to High Strain Rate Loading; Ship Materials Fab-rication and Inspection; and other committees concerning Nuclear Reactor Compo-1 nents.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

In the Matter of )

l )

METROPOLITAN EDISON COMPANY, ET AL. ) Docket No. 50-289-OLA

) ASLBP 83-491-04-OLA (Three Mile Island Nuclear ) (Steam Generator Repair)

Station, Unit No. 1) )

i SERVICE LIST Sheldon J. Wolfe> -  :.

Administrative Judge l Chairman, Atomic Safety and .

l Licensing Board i U.S. Nuclear Regulatory Commission Docketing and Service Section Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Dr. David L. Hetrick Washington, D.C. 20555 Administrative Judge _ _ _

Atomic Safety and Licensing Board Professor of Nuclear Engineering George F. Trowbridge, Esq.. ,

University of Arizona Shaw, Pittman, Potts & Trowbridge Tucson, Arizona 85271 1900 M St., N.W.

Washington, D.C. 20036 Dr. Jr.mes C. Lamb, III Administrative Judge Jane Lee Atomic Safety and Licensing Board 183 Valley Road 313 Woodhaven Road Etters, Pennsylvania 17319 Chapel Hill, North Carolina 27514 Norman Aamodt Richard J. Rawson, Esq. R.'D. 5, Box 428 Mary E. Wagner, Esq. Coatesville, Pennsylvania 19320 office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 en e 6 y # @

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of j

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

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(Three Mile Island Nuclear Station, Unit No. 1)

CERTIFICATE OF SERVICE I hereby certify that copies of the attached Affidavit of of Dr. George Sih and Statement of Qualifications dated May 8,1984, were served this 8th day of May,1984, by deposit in the U.S. Mail, first class, postage prepaid to those on the attached service list.

A Ec h cA Louise Br&dford //

May 8, 1984