ML20041F088
| ML20041F088 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 03/09/1982 |
| From: | Rozzell S BAKER & BOTTS |
| To: | Stephens C NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 8203160178 | |
| Download: ML20041F088 (19) | |
Text
{{#Wiki_filter:-. .,..,.s. BAKER & BOTTS ONE SHELL PLAZA HOUSTON. TEXAS 77oo2 ~ TELEX 76 2779 WASHINGTON OFFICE 8 701 PE N N 5YLVANI A AVE.. N W T EL E CO M M U NICATIO N WASHINGTON. O C 20006 (713) 229-1523 HOUSTON g TELEPHON E (202) d 57-5500 (202)457-5538W ASHINGTON. D. C. [, ,,,g,.- March 9, 1982 c A' D Mr. Chase R. Stephens [ REC 6Qsg,)f Docketing and Service Station 2 $4gI8/pgg U.S. Nuclear Regulatory Commission l C' 3 - k Washington, D.C. 20555 Re: Docket No. 50-466 k f,
Dear Mr. Stephens:
M Enclosed is Attachment 1 to Applicant's Answers to Doherty's First Set of Interrogatories Re Quadrex which was inadvertently omitted from the materials transmitted to you yesterday. We regret any inconvenience this omission may have caused. Very truly yours Scott E. Rozzell Attorney for Houston Lighting & Power Company SER: 128 Attachment cc: All Parties d u 8203160179 B20309 PDR ADOCK 05000466 O PDR u
Attachm'nt No. 1 N -3 1 He's a fine gentleman, and I am sure that when I 2 it: comes to construction activities, very little is a strang'er 3 to him; but I believe that one of the ingredienti tha: 4 one must have is an absolute determination to stick to. .m 5 thing less. f ,the requirements at all times and not accept any%y e 7w ~ nc j 6f And I just sensed that we needed a stronger R i ~ 7' person to provide the leadership to our team on that site. A j 8 g You talked a lot about replacing HL&P people d 9 on the site. Have you inquired into what your authori'cies zog 10 are to have Brown & Root people replaced on the s.te? E h 11 l BY WITNESS GOLDBERG: 3 y 12 A By inquiring into my authorities, I endeavor = f 13 i to press my interest, and until such time as Brown & Root f" x., = I m g 14 is non-responsive, I would assume that I have the authority e= I E 15 ' to work with their management and point to clear areas a t\\ s j 16, in my judgment that need strengthening; and to that end, s.(';.}. ~ W j u d 17 i and with considerable support from my executive management, l 5 I w i a 18 ! we've identified to Brown & Root a number of areas that u 5 h 19 we believe they are in need of strengthening, both in terms n 20 of talent, as well as in terms of depth of talent. 21l G What are these areas? i 22 ! BY WITNESS GOLDBERG: 23 ' A. The more important area that we've identified 24 is the need to broaden both numbers and quality of engineering ) 25 ; management, and we believe that this has some bearing on i ALDERSON REPORTING COMPANY. INC.
~ g 2387 c, i s ~~ quality in this respect: There are a number of problems. \\, 4 1 3 u 2 that have occurred at the job' site. s 3 Virtually every problem, whether it originates I 5 4 with er.;ineeril?g, invariably ends up at engineering's doorstep. s 1 o 5i Every mistake committed by construction requires A N 8 6 an evalcation by engineers to determine the course of corrective a \\l Q 7, action. , d _, M 8 8 We believe that Brown & Root is 2nquestionably?+- h a o. i d 9 trying to meet this challenge with too few key people;' \\ z o A g 10 j and between my own assessmentsand those of some of Brown a Z 5 11 & Root's engineering management, we have ' identified a number , t ; t 3 / r d 12 l of keh areas that need to be ocistered. r z s = i '] f 13 Some af,th6se specifigdisciplines are design k Q s p r E 14 of cabi.ft,; tray _ s ssupports, design df seismic pipe supports, 'n
- a l
E i 2 15 l general increase' vin thes aumber hf technical managers th ;t 3 i, ) 16 i direct the acti'/iti$s of' resourbes they already have;, a'equisition I ui j,< g 17 j of a more ' senior technical leadhr.sto provide over-all technical r w*% Q =s . ss 18 direction to thei,r' project te a[t '; and'we've suggested some ( =b ,.\\ N y- \\ \\\\ i -{ R other changes relative to the way they ark structured in M order to brin'g more fdcus bf management attention to the '20l V I 21 needs of the South Texas Prcject. i> 22 G Have these suggestions been made over a period i s. t *f time or were they made at one particular time? 23 I o i l-24 i BY WITNESS.GOLDBERG: l ] l 25l A. They've been kind of accumulating over a period l l. num=e o
~ l 2388 -5 1 of time, i 2 g When did you start to tell them that they needed 3 people in these positions? 4 BY WITNESS GOLDBERG: e 5 A I think'maybe it started about the en'd of the 3n d 6I first week that I joined HL&P. } { 7 G How many of these pecple have they recruited 8! and put on the staff since then? d d 9 BY WITNESS GOLDBERG: i h 10 A. Well, in terms of key people that come to mind E 5 11 first, they've brought aboard two assistant technical managers,- <3 6 12 which in my personal opinion are very streng capable people. 3= r' d They recently brought a third one, who I personally 13 l \\' E E 14 l don't have much prior knowledge about, but that person w 2 15 ' looks strong as well. 5 g 16 They are currently out recruiting for their A d 17 ; new technical head. w i = 5 18 l They are in the process of -- well, they are e [ 19 not in the process. Let me revise that. A 20 They have recently put in place a new resident 21 consitruction manager, which carries the title of deputy 22 project manager. This is a Mr. Jim Thompson, who replaced their 23l 24 l previous site manager, Mr. Ron Leasburg. s l 25l Now, Mr. Leasburg left voluntarily, but my 1 N
l 'dOOO E \\ l perception is that Mr. Thompson will provide a stronger -6 1 r' 2! hand in that he is a career construction man. Mr. Leasburg 3 was an engineer, whose experience in construction is somewhat l l 4 less than Mr. Thompson's. \\ g 5I Mr. Thompson has joined Brow'n & Root, having N i + 2 5 l; recently participated in the management of construction R I i 7j of another pressurized water reactor plant, and he brings s 8 8l fresh, very applicable experience to the job. [ d l d 9 He's a results-oriented fellow, and he's very i z i O g 10 l uncompromising. He manifests the qualities that I think j E l = y II will help Brown & Root's construction activities. 3 I I2 These represent at least the current major E i[ IS changes. I do know that there are some 22 positions that = i m i 6 I4 i Brown & Root is currently endeavoring to fill at va rious e _j 15 middle technical management levels. = g 16 I've seen the list. I just don't happen to a d I7 ' have it with me. x s = g 18 l,1 u I Q. Now, you mentioned a number of problems at E i I9 g the job site. Did those problems involve the placement n 20f of concrete? i 21 l BY WITNESS GOLDBERG: 22 A. There certainly were some problems with placing 23l concrete. These are -- I'm now quoting from just the history 24 I that preceded my personal observation. 25 I have no personal observations about problems b f AL DERSON RFPORTING COMP A NY INF
14300 1 -7 1 in placing concrete. 2l G And were there also problems in welding? i 3 BY WITNESS GOLDBERG: 4 A That appears to be, also, a matter of record. 5 G Now, do"you -- When you first came on board, 4 ~1 3 6 Mr. Goldberg, was HL&P properly overseeing Brown & Root's R 7 engineering staff, in your opinion? A j 8 BY WITNESS GOLDBERG: O d 9 A I think in terms of the program, I would certainly z ! say yes. C 10 In terms of whether or not the program was being 3 h 11 fully implemented, I think mechanistically, the answer f 3 y 12 to that would also be yes. E {' y 13 ; But I sensed that some activities that were t j = l 14 surfacing perhaps"were not recognized in the seriousness ~ 2 15 i that they portended to my view versus perhaps the view w i = g 16 of others. m d 17 i G Can you expand on that last sentence of yours 5 I 18 ' more? =b 19 BY WITNESS GOLDBERG: n 20 A Well, I think the first day I was on the job 21 I met with my staff of engineer: -hat were assigned to 22 the project, and I was very interested in how they insured 23 j that the design criteria that applied to the various systems, 3 24 l including the safety-related systems, was being properly d 25 ' implemented and reflected in the Brown & Root designs. t I h
2331 i 1 l I i -8 1 In particular, I was vitally interested in 2 whether this criteria was clearl r written down on a system-3I by-system basis, whether or not this design considered 4, all modes of operation, start-up, normal operation, shut-I g 5 down, emergency, faulted and upset; and I was assured that E j 6 ! that was the case. 7l That kind of aseurance did cause me some concern, Al 8 because if that were true, this would truly be the first d
- [
9 nuclear powerplant which was in that good a shape. zog 10 So we probed further, and together we were Z )_ 11 able to discern that there were some areas that were not 5 I 12 consistently being covered to that degree; and this represented, ~=a s~ 13 ' at least, the observation to me, that some of my people 5 (_. = i 5 14j; didn' t apprecia te the importance of that aspect of the m b i 15 l engineering effort, and it certainly also suggested that = y 16, they didn' t have the depth or experience that I've accumulated l d 17 1, over the years to appreciate how important that matter uz 18 ! was. = l w 8 i g 19 l Subsequent discussions with Brown & Root's R i 20 head of engineering indicated that they were also, in parallel, 21, becoming very sensitive to this prospect and had already I 22 l undertaken a comolete review of these design criteria, 23 l and that review is in progress. 24 l But it certainly, in the context' of your question, I 25 formed an opportunity to recognize that we needed to enhance i i l ALDER _ SOW 1 REPO@TDNG COM P ANY, INC,
2332 i -9 1 i by bringing aboard more experience the awareness of our .I
- p.
2 engineers of what was really important. 3 0 What was the tracking mechanism by which the 4' engineers at that time assured themselves that the design g 5 criteria were being met in the actual design? A.] 6 BY WITNESS GOLDBERG: R 7 L Well, there are a number of key documents that a j 8 would reflect the design, if in fact it was being reflected d 9 properly. z 9g 10 These would be system design descriptions; 3 li 11 the process and instrwment diagrams, which epresent 3 y 12 diagrammatically the design of the systems; the logic diagrams E y 13 that report the mode of operation of a system; and the = u x 5 I4 l elementary electrical one-line wiring diagrams. 8 g 15 Now, our people are in fact in the review and = p' I6 approval circuit of each of these documents. So that did a g 17 ! represent the key mechanism by which our people could review W = 18 j and endeavor to assure themselves that the design criteria _c 19 g was being implemented properly. i. 20 'i g Were these reviews being properly carried out? l 2I I BY WITNESS GOLDBERG: 22 A To the extent that the procedures called for, i t 23 : I believe that the program was being carried out. I believe, 24 however, that some of the engineers' awareness of some ~' 25, of the omissions or inadequacies was not always being recognized. f i ALDERSON REPORTING COMPANY, INC.
2 31)3 1 1 'p 1 0 So there was a limitation in the capability of p.> t .W. 2. the engineers doing the revi.ewc? 3I BY WITNESS GOLDBERG: i 4l1 A Yes, sir, i 5 0 In the relation to the dutics of Mr. Briskin U i j 6l and your site manager, who will be Mr. Williams, who has R 7 more authority within the organization, or are they on an K j 8 equal par? d d 9, BY WITNESS GOLDBERG: i C i g 10 - A I believe they would bc judged certainly on an 3 h 11, equa. par. 3 I j 12 O You talked about the actions of Brown & Root 4 (- g 13 j before in replacing or looking to adding positions. 14 ;i m 3 Has Brown & Root been -- Hon responsive has b 15 l Brown & Root been to your concerns? Has it been a fight, or M_ j 16, have they been responsive -- or have they been readily ^ I d 17 responsive? w= 5 18 BY WITNESS GOLDBERG: 5 I E 19 1 A I think in the balance I believe thev've been 5 n 20 most responsive certainly over the last, I'd estimate three 21 months, and before that time, I really wasn't making too 22 many demands on them because I was trying to understand where i 23 ! the problems lie and what types of changes might be effected l 24 l that could make a difference in dealing with those problems. 25 l 0 We've had several people talk about programmatic i I i ALD ERSON REEORTING COM RANY INC
i 2394 .w Il direction, and you used the term yourself on page 10 of your l g-2 testimony at line~17 -- 18. i 3l What does programmatic direction mean to you? 4 BY WITNESS GOLDBERG: i g 5 A It is basicaily to provide the policies of how N h 6f we're going to carry out our relationship to insure that we R I 7' are satisfying our licensing commitments. Aj 8 0 And when you talk about the direction, what ad 9 controls are there that you exercise to see that -- Must that ,z C g 10 First of all, must that direction be followed by E h 11 the contractor -- by the constructor? 3 I f I2 l BY WITNESS GOLDBERG: a i (^ 13 l A When we provide direction the contractor is (_, E a i 5 14 obligated to satisfy that direction. However, speaking from wej 15 past personal experience, whenever a contractor is of the = g 16 l opinion that the direction he's being given will result in w d 17 either a product for which he's convinced will not satisfy a l = } 18 l the requirements or might pose some personal safety hazard to G I g I9 l its employees, they unquestionably will take issue with such n l 20 direction. 21 Beyond those cavaats, I think it is the 22 ! responsibility of a contractor to carry out the wishes of the i 23 ' licensee. 24 l 0 How have you -- Have you taken any steps to i 25, assure that the contractor is carrying out the programmatic i. 4 ALDERSOM REPOST0fMG COMP ANY, QNC.
2 2335 1 : directions of.HL&P since you assumed your position? ?~' l 2 BY WITNESS GOLDBERG: 3; A Yes. And that's been done in a number of ways. I i 4l We talked last week about certain reviews that l e 5 HL&P conducts with Brown & Root relative to various engineering A N 6l and construction activities, and, in particular, emphasis R .I 2 7 is placed on dealing with problematic type issues. Aj 8 I tend to want to manage by exception'in terms of d 9l the real-term concerns, and, of course, we've already talked d ioy 10 about some of the things in terms of planning the activities 3 5 11 to preclude the occurrence of problems. <m y 12 ! These meetings focus on the real issues affecting _= { "s y 13 i the project, whether they be issues of procedure,, issues of = l 14 procedure execution, issues of reported deficiencies and 2 15 what types of corrective actions will be undertaken to resolve w I g 16 l those deficiencies. He cover virtually the spectrum from ^ l d 17 engineering, design, construction, and resolution of reported 5 18 problems. ~ 5 E 19 BY MR. FRAZAR: A. 29 A Mr. Reis, I don't want to interrupt your 21 cross-examination too lengthy of Mr. Goldberg. But I wish to 22 point out that the term programmatic direction has a rather 23, special connotation as it pertains to the quality assurance 24l program, and I'm sure that I'll get questions on that later, ~ u/ 25; But I just want to point that out. I t
~ 4 2336 l 1; O When you -- You talk here on page 10 of your t' 2 testimony of the -- and that's question 11 and the answer 3 thereto -- of reviews designed to insure that Brown & Root 4, has considered the applicabic industrial codes and standards, l g 5 regulatory requirements and HL&P's preferences. To some N g 6l extent you said you depend upon engineers to check the R CS 7 diagrams and the documents that come forward. Mj 8 Are' there any checklists or matrixes performed d 0[ 9 to assure that these matters are met? zo 10 BY WITNESS GOLDBERG: E 11 A I believe in the context of identifying attributes 3 12 that need to be looked at, yes. We do identify in procedural = (m ~ 13 fashion the elements that an engineer should examine these ~ l 'A = 5 14 I documents for. b l = 15 l, While I do not believe they actually check off g 16 l a checklist, they do provide or we have provided them a laundry W b. 17 ll list of features for which they should be examining the w= l { 18 l documents for, and they do provide written comments to the c l 8 19 l contractor on a per document basis. g n 20 0 Now, going down to question and answer 12, you 21 talk about the project engineering group reviews and approves 22 basic design documents. 23 Does your organization have any responsibility 24 to review implementing procedures that the -- that might be sJ l 25, used by the people in the ficid? ~ i a
2403 )~2 1 l The procedures then implement those design criteria i e-2' during the quality assurance review of the procedures. I 3 recognize that many of us are degreed engineers as well as 4 experienced in codes and standards and in some cases design g 5 ourselves. ~ a. j 6 We review the procedures against the requirements 7l R of the pertinent codes and standards and the specifications, K 8 and we also review those procedures to verify that included in d C 9S z, the procedures are clear acceptance and rejection criteria that c 10 form the basis for the actions to be performed by both the E j_ 11 construction and the quality control personnel as the work j 12 . proceeds in the field. E t'- l 13 JUDGE BECHHOEFER: If you should veto a proposed j m i zg 14 change, would you normally suggest what alternative should be 2 15 followed? f 16 l WITNESS FRAZAR: Yes, sir, we endeavor to work in g ~^ \\ d 17 ! a professional manner with the construction and engineering l w 3 18 personnel to resolve any apparent conflicts that have developed P 19 i out of our review of the procedures. 5 1 20 JUDGE BECHHOEFER: Thank you. 21 Sorry for the interruption. 22 MR. REIS : That's all right, Your Honor. 23 sy gn, agIs: 24 4 Mr. Goldberg, on Page 12, in Question 14 you're 25 asked a question about HL&P. I'd like to rephrase the question I i ALDERSON REPORTING COMPANYn INC. ~
2404 9-3 1 l and ask you, are you able to express an opinion on how f 2 l Brown & Root's current management of design, and I might add 3 engineering and construction on this project ccmpares to 4 generally accepted practices for nuclear construction? j I i = 5 BY WITNESS GOLDBERG: An 3 6 A I think I tried to characterize last week that N I 7 I'm pretty much of the school that however things are there's j 8 always opportunities to make them better. d o[ 9 Now, I believe that Brown & Root has cade some z O 10 substantial improvements, and most of this improvement has 3 h 11 centered around the introduction of certain people. B y 12 j As I mentioned earlier, there is still a number 4 5 13 ; of spots that they have yet to provide some additional z 5 14 ! required resources, so I certainly would have to state that i 2 15 I'm not satisfied. I would hope that their management is not w= \\ g 16 satisfied because I think there is substantial improvements u b 17 l that can yet be made. i { 18 l In terms of whether or not they're meeting the P h 19 ; minimum standards necessary, I would say that in any case where n 20 we have identified they're not, whether it be by an engineering 21 review and observation or whether it has been by a quality 22 assurance review and observation, these matters are being 23 ' - brought to the attention of their management and they will be 24 l corrected. i 25 l We stand to get this job done faster and more l l' ALDERSON REPORTING COMPANYo INCo
2@5 9-4 1 efficiently as fewer mistakes are made, so *' at end we 're m 2 i determined to encourage Brown & Root to acquire the resources 3 to. improve the quality of their effort. 4 G Now, as to design, what are the principal areas 5 where you have found them lacking? a 39 3 6 BY WITNESS GOLDBERG: a l "8 7 A We and Brown & Root have identified some areas in s 8 8 need relative to heating, ventilation and air conditioning. n dc 9 We have identified some specific areas whereby io g 10 certain faulted condition loads were not considered in some of E j 11 the designs. These designs will have to be re-examined, taking 3 d 12 into account these additional heat loads. E c y 13 l We've identified some areas and Brown & Root has ~- = " y
- 14 l also independently identified some areas where shielding a
i e 2 15 analyses were performed with the premise that they did not a= g 16 relate to something that was safety related, and certain m d 17 j chielding calculations may very well not be safety related B 18 l I. C but unfortunately there are some that are, and to the extent M 5 19 { that there are these calculations that were not treated as 8n 20 safet related, they have to be re-examined because there is a 21 difference in the review process of calculations if you treat it 22 l as safety related versus non-safety related. 1 23 ' So those areas are being re-examined by Brown & 24 f Root. We have no knowledge that the calculations are wrong, 25 but we question the veracity of the review process, and i I i i l AL.DERSON REPORTIN G COMPANY INC. 2
2406 ) 9-5 1 therefore there is a chance that it could turn up something ^ 2 j that has previously gone undetected. 3 G In order to clear up the record, you said 4 veracity. You don't mean veracity in the sense of honesty? 5 BY WITNESS GOLDBERG: a A4 3 6 1 No. I'm sorry. I may have chosen the wrong word. e R 7 .I meant in terms of reliability or validity of the review. A j 8 G Now, as far as construction in contrast with d = 9 design, where have you found principal deficiencies in the I E 10 Brown & Root operations? z= l E 11 A I've been disappointed, as I said earlier, with <3 d 12 I the procedural aspect, which I think certainly can be a very l = d' 13 ! counterproductive element. It certainly can be contributing l ~- i d 1 = E 14 to some of' the frustrations of the work force. N i = 2 15l Once you ask a group of men to build something
- =
j 16 l and you hand them the procedure and the material and the s d 17 l drawings and you've trained them and they're ready to roll, w= 5 18 and this is that long-awaited day to get started, and then, =H l 19 lo and behold, they're 15 minutes into the job and they 8 20 encounter a problem that requires a procedural change. 21 If they have to stand around and wait a couple of 22 days while the -- what do I call it the infinite wheels of 23 ! - progress grind away, they get frustrated. So we see that as a 24 l very important element that contributes not only to the quality 25 ' of the job but to the attitudes of the people that are trying i i i ALDERSON REPORTING COMPANY. INC. I
2407 i 9-4 1 to build the plant. [' 2 Another area that we have had some concerns about, 3 which at the moment represent a larger concern for the economics 4 rather than for quality, deal with the work sequencing. o 5 Whenever engineering information'is lacking there X N 6 are two ways of dealing with it. You either wait for the o Rg 7 information or you try to work around it. s j 8 There have been too many instances where people dc 9 have been working around some of these missing elements, and io g 10 this is a very inefficient way of trying to build the power 3_ E 11 i plant. You just can't commit resources in a very orderly and B c' 12 businesslike fashion. Ec .eg y 13 We've certainly been concerned about this, and r., y 14 certainly if we didn't do something about it, perhaps years $j 15 down the road it might have been at least contributory to some = J 16 l future problem of maybe denying adequate access to man to G 6 17 i perform some of the tasks that are now being performed out of c 18 ' sequence by having worked aro6nd some of these bottlnecks. i i s E 19 : So we're working with 3rown & Root construction i 5 20 j management to bring a stronger discipline to the people 21 ' responsible for deciding the work sequencing. 22 To Brown & Root's credit, they have certainly 23 - brought to bear a far more seasoned planning team to help l 24 l perform the work planning, to try to put the engineering and i 25 ' construction activities in better synchronization, and it also l I I i ALDERSON REPORTING COMPANY. INC.
2408 9-5 i 1! serves to provide some visibility to quality control so that l f' 2' they can plan for their support, so that they, needless to say, i 3I do not become in a situation where the resources needed for l 4 their support have not been defined in sufficient time to 5 enable them to provide those resources. 8 3 6 G Does this sequence and coordination of engineering E i 7 and construction, and I take it from what you're saying in X 8 8 some instances construction was getting ahead of engineering; d c 9 is that what you're generally saying? 2o 10 BY WITNESS GOLDBERG: 2= l j 11 A They never get ahead, but certainly when they 5 y 12 reach the point where they're waiting on engineering, that's 5 7'] g 13 certainly a very inefficient situation. s., > = i l 14 ! O Can that have any effects on the safety of the b 15 construction of~the project? i
- =
j 16 BY WITNESS GOLDBERG: W d 17 l A I would not think that should normally be a w u u 5 18 concern, but construction always has to be sensitive to =H h 19 performance of work that cannot be completed and they have 5 20, to establish to what degree they can proceed without 21 completion and still have a situation which does not pose a 22 ; safety concern. i 23 ' Now, we're talking about physical safety to 24 l workers, I assume. s 25 l G No, I was talking about an ultimate safety from l l ALDERSON REPORTING COMPANY, INC.
2409 .9-6 1 l rhe point of view of the responsibilities of the NRC, health l [ 2I and safety matters. 3 BY WITNESS GOLDBERG: i l l 4i A Only to the extent that I observed previously, I g 5 that in the event you don't work in proper sequence you might 2 j 6 create a situation where you increase the difficulty for R 7 construction to perform the task properly. A j 8 For example, if a certain valve, for example, was d c 9 z, missing and work was allowed to continue around that work-area og 10 to the extent that access for properly welding that valve at a E h 11 later date became extremely congested, this increases the 5 ( 12 likelihood for workmanship errors which undoubtedly would be 5 f-y 13, picked up by quality assurance by the quality control \\v: i 5 14l; inspections, but notwithstanding we're just taxing the whole .o t j 15 operation by allowing the work to proceed in that fashion. I g 16 l d 17 ; W w 18 : i E 19 I aM 20, t 21 22 l 23 ! 24 : 25 l l i ALDERSON REPORTING COMPANY, INC. ,}}