ML20072N157
| ML20072N157 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/25/1994 |
| From: | Cottle W HOUSTON LIGHTING & POWER CO. |
| To: | Bateman W NRC |
| Shared Package | |
| ML20072N121 | List: |
| References | |
| NUDOCS 9409060021 | |
| Download: ML20072N157 (325) | |
Text
The Li ht 9
g1 company 1
llouston Lighting & Powerfat ject ectric e crat W stat u O. Box m Wadsworth, Texas mu exas AllG 2 51994 ST-HL-AE-4877 File No..
G25 10CFR2 W.
H.
Bateman Team Leader, Effectiveness Review Team U.
S.
Nuclear Regulatory Commission Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498; STN 50-499 Testimony by Liberty Consultino Group In response to your verbal request, attached is a copy of the testimony prepared by Liberty Consulting Group in connection with the rate case / fuel reconciliation proceeding now pending before the Public Utility Commission of Texas. In that proceeding, issues have (p) been raised as to the prudence of the management of South Texas x_/
Project (STP) operations and the extent to which Houston Lighting
& Power Company (HL&P) may recover replacement fuel costs incurred during the recent extended outage at STP.
Liberty Consulting Group was engaged to provide an independent assessment of management prudence, utilizing the standard adopted by the Public Utility Commission of Texas:
The exercise of that judgment and the choosing of one of that select range of options which a reasonable utility manager would exercise or choose in the same or similar circumstances given the information or alternatives available at the point in time such judgment is exercised or option is chosen.
This prudence review was particularly important gi"en the extensive attention surrounding the 1993 NRC Diagnostic Evaluation Team Report.
As you know, there are significant differences between the standards utilized by the NRC as a safety regulator and those used by an economic regulator such as the Public Utility Commission of Texas.
The most significant differences between the Diagnostic Evaluation and a prudence review are that the former focuses on results and takes full advantage of all available facts to identify weaknesses and areas needing improvement in licensee performance.
A prudence review of management, on the other hand, g
must evaluate the reasonableness of decisions and actions of b
management only in light of the information and options reasonably available at the time those decisions were made and actions were taken.
Project Manager on Behalf of the Participants in the South Texas Project x:sc-94ss4 237 9409060021 940825 PDR ADOCK 05000498
'T~~
Houston Lighting & Power Company South Texas Project Electric Generating Station ST-HL-AE-4877
[
File No.: G25
\\
Page 2 While HL&P believes that, based upon the information available at the time, its management actions and decisions were reasonable under the standards established by the Public Utility Commission of Texas, HL&P has aggressively pursued performance improvement at
- STP, These improvement efforts have been documented in the Operational Readiness Plans executed in connection with the restart of each STP unit and in the STP Business Plan, which collectively address the issues described in the Diagnostic Evaluation Team Report.
These efforts have also been subject to extensive NRC review through multiple team inspections and real-time monitoring.
HL&P is committed to continuing these performance improvement efforts.
Please call me should you require additional information or wish to discuss these matters further.
Sincerely,
- e.. c > ~ c%.
x W.
T.
Cottle Group Vice President, Nuclear l
l e
k r
Attachment:
Direct Testimony of Robert L.
Stright I
s e
MISC-94\\94-237.002
r-Houston Lighting & Power Company South Texas Project Electric Generating Station ST-HL-AE-4877 p
File No.: G25 i
Page 3
(
c: Without Attachments L.
J.
Callan Rufus S.
Scott Regional Administrator, Region IV Associate General Counsel U.
S.
Nuclear Regulatory Commission Houston Lighting & Power Company 611 Ryan Plaza Drive, Suite 400 P.
O.
Box 61867 Arlington, TX 76011-8084 Houston, TX 77208 Lawrence E.
Kokajko Institute of Nuclear Power Project Manager Operations - Records Center U.
S.
Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555 13H15 Atlanta, GA 30339-5957 David P.
Loveless Dr. Joseph M.
Hendrie Sr. Resident Inspector 50 Bellport Lane c/o U.S.
Nuclear Regulatory Comm.
Bellport, NY 11713 P.
D.
Box 910 Bay City, TX 77404-910 R.
Newman, Esquire Richard A.
Ratliff i
twman, Bouknight & Edgar, P.C.,
Bureau of Radiation Control 6,TE 1000, 1615 L Street, N.W.
Texas Department of Health 1615 L Street, N.W.
1100 West 49th Street Washington, DC 20036 Austin, TX 78756-3189 K.
J. Fiedler/M.
T.
Hardt U.
S. Nuclear Regulatory Comm.
City Public Service Attn:
Document Control Desk P.
O.
Box 1771 Washington, DC 20555 San Antonio, TX 78296 J.
C. Lanier/M.
B.
Lee Joseph R.
Egan, Esq.
City of Austin Egan & Associates, P.C.
Electric Utility Department 2300 N Street, NW 721 Barton Springs Road Washington, DC 20037 Austin, TX 78704 G.
E. Vaughn/C.
A. Johnson Central Power and Light Company P.
O.
Box 2121 Corpus Christi, TX 78403 0
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