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)

Text

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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 ) (Operating License- t

) Extension)

(Vermont Yankee Nuclear ' ).  ;

- Power Station) )

I

- 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

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1l rc .. j 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 ,

~

1 i) ) e i 1,.

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

c l

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

, 7-- - :-_::

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SHERRfE BOASE jm u '

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NOTARY PUBUC .

f Notary Public-l STATE OF TEXAS ,

. L_____

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UNITED STATES OF AMERICA 00CMETED NUCLEAR REGULATORY COMMISSION USHRC j before the:

ATOMIC SAFETY AND LICENSING BOAR  % R -9 A10:33 'l

)

In the Matter of ) . OFMCE OT KCRE TARY VERMONT YANKEE NUCLEAR ,)

Docket Fo. 50-271COIJEF^4%

(Operat!.ng License "h> Si 9 VIE 3

POWER CORPORATION )

) Extension)

(Vermont Yankee Nuclear )

Power Station) )

)

CERTIFICATE OF BERVICE  ;

I hereby certify that on July 5, 1990, I made service of- "j

" 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 )

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

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