ML20055F602

Affidavit of Hs Phillips.* Advises That Vermont Yankee Needs Documents in Order to Adequately Develop Case.W/Certificate of Svc

ML20055F602
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	07/02/1990
From:	Phillips H PHILTEC SERVICES, INC.
To:
Shared Package
ML20055F601	List: ML20055F602
References
OLA-4, NUDOCS 9007180140
Download: ML20055F602 (4)

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UNITED STATES OF AMERICA 0 CpgCEO NUCLEAR REGULATORY COMMISSION

- before the

. ATOMIC SAFETY Al!D LICENSING BOARD '90 JJi. -9 A10:33 I

c. - -.

In the _ Matter of '

)

)

VERMONT YANKEE NUCLEAR

)

Docket No. 50 271-OLA-4 i

POWER CORPORATION

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(Operating License-t

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Extension)

(Vermont Yankee Nuclear '

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- Power Station)

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- AFFIDAVIT OF H. SHANNON PHILLIPS H. Shannon Phillips, being first duly sworn, deposes and says as follows:

1 1.

' im President of Philtec Services, Inc. of Granbury, Texas. In this capacity I have provided management and tecnnical expertise -

to a public intere'st group monitoring the activities of the i

Comanche Peak Steam Electric Station. As shown on my resume, which has been provided in Response to Vermont Yankee j

Interrogatories (Set No.1), I formerly held various positions with the Nuclear Regulatory Commission (NRC) and Department of j

Defense.

2.

In the course of my work at Comanche Peak and with NRC, I have become= generally familiar with the INPO documents identified in Requests Nos.~ 2 through-10 and Nos.12 through 25 -

of " Document Production Request Propounded by the State of Vermont to the Vermont Yankee Nuclear Power Corporation (Set i

No. 2)."

I am specifically familiar with the documents requested in Request No.18, INPO 85-038, " Guidelines for the Conduct of Maintenance at Nuclear Power Stations"; Request No.17, INPO 1

9007180140 900705 gDR ADOCK 05000271 PDR

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s85-032, " Preventive Maintenance"; and Request No. 25, INPO 89 09, " Plant Predictive Maintenance", which I have reviewed within

. 7 the past year. I have none' of the documents in my possession.

3.~

From my review and knowledge of these documents, I can say f

that these documents are in'the form of Guidelines or Good.

3 Practices (INPO "Gwd Practices" include the statem mt that a--

Good Practice'is or.e et*ective method for accomplishing elements of nuclear plant manageme.nt 'and operation). The regt.ested -

. j documents are.simila. to-NUREGs,.NRC Regulatory Guides and 3

Electric Power Research Institute '(EPRI) reports. They provide i

an acceptable anci effectise method-for accomplishing a

. maintenance or maintenance related activity.

f 4.

To the best of my. knowledge, none of the requested INPO l

documents pertains toLany issue involving th'e candor of an INPO-source or to any issue involving insights as.to " root causes" of-events and experiences which are frequently found to involve human error.

5.

It is my judgement that these documents provide the_ most 1

insightful thinking of the best informed people within the industry on matters of maintenance which are the subject of this proceeding.

3 6.

The requested documents contain the industry's best information on maintenance topics. As a result of the NRC Commissioriers' interest in maintenance (Policy Statement on Maintenance of Nuclear Power Plants, March 23,1988 (53 FR.9430), Proposed Rule Ensuring the Effectiveness of Maintenance Programs for -

Nuclear Power Plants, November'28,1988 (53 FR 47822) and the 2

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Maintenance of Nuclear Power Plants,. Revised Policy Statement, December 8,1989 (54 FR 60511) and INPO's involvement in that process, I consider it highly unlikely that.INPO would abandon '

1 the effort to prepare such documents if Vermont was granted its; request to inspect and copy such documents. Even if INPO were ~

to cease wch document preparation, the industry would most -

likely continue to produce the information~ through other ~

organizational means (for example, The Nuclear Management and-1 Resources Council (NUMARC) or EPRI) in order to address the-Commissioners'. maintenance concerns.

7.

It is also my expert judgment that Vermont, in its role as a party to this proceeding, needs these documents which represent the standard for the industry. Without these documents, it may not be possible for Vermont to adequately develop its case;

]I Dated at _ M dm,,4,a

, Texas, on this A / day of July,1990.

H. SHiinnon Phillips

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e Sworn and subscribed before me this Mday of July,1990.

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M SHERRfE BOASE jm u '

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7 NOTARY PUBUC.

Notary Public-f l STATE OF TEXAS

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UNITED STATES OF AMERICA 00CMETED USHRC j

NUCLEAR REGULATORY COMMISSION before the:

ATOMIC SAFETY AND LICENSING BOAR

% R -9 A10:33

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In the Matter of

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OFMCE OT KCRE TARY VERMONT YANKEE NUCLEAR

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Docket Fo. 50-271COIJEF^4% Si 9 VIE 3

"h>

POWER CORPORATION

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(Operat!.ng License

)

Extension)

(Vermont Yankee Nuclear

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Power Station)

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CERTIFICATE OF BERVICE I hereby certify that on July 5, 1990, I made service of-

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" Affidavit of H. Shannon Phillips"'and." Motion to Compel Answers tc Document-Production Requests (Vermont Set No'2)", in accordance with rules of the Commission by mailing a copy thereof postage prepaid to the following:-

j Administrative Judge Administrative Judge Robert M.

Lazo, Chairman Jerry R. Kline Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Washington, DC 20555 U.S. Nuclear Regulatory i

Commission Washington, DC 20555 Administrative Judge Ann _P.

Hodgdon, Esq.

Fredtrick J. Shon Patricia A. Jehle, Esq.

Atomic Safety and.Licensir.g Board Office of the General Counsel U.S. Nuclear Regulatory Conmission U.S. Nuclear Regulatory Washington,.DC 20555 Commission Washington, DC 20555-R. K. Gad, III, Esq.

_ Anthony Z. Roisman, Esq.

Ropes & Gray Cohen, Milstein,-Hausfeld &

One. International Place Toll Boston, MA 02110 Suite 600 1401 New York Avenue, N.W.

_ Adjudicatory File Washington, D.C.,20005 Atomic Safety and Licensing Board Panel U.S.N.R.C.

Washington, DC 20555

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7 4Lr#e s Kurt Janson U Special Assistant Attorney General Dated: July 5, 1990

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