ML20072P544
| ML20072P544 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/13/1994 |
| From: | Stright R HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20072N121 | List: |
| References | |
| NUDOCS 9409080035 | |
| Download: ML20072P544 (38) | |
Text
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DIRECT TESTIMONY OF Robert L.
Stright FOR HOUSTON LIGHTING & POWER 1
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July 13,
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94090B0035 940830 PDR ADOCK 05000498 T
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EEFORE ME, the undersigned notary public, this day person &lly appeared Ecbert L.
Stright, to me kacwn, who being duly sworn acccrding to law, deposes and says:
"My name is Robert L.
Stright.
I am of legal age and a resident of the State of Maryland.
The foregoing testimony and I
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figures and the opinions stated therein are, in my judgment and n\\
based upon my professional experience, true and correct."
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Robert L.
St 'qht 8 M Sub cribed and sworn before me on this day of 1994.
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Notary Public in Tnd'for Harris County, Texas
, e 9sssssenesssssss My Commission expires:
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EXECUTIVE
SUMMARY
OF ROBERT L.
STRIGHT DIRECT TESTIMONY i
HOUSTON LIGHTING & POWER COMPANY Mr. Robert L. Stright testifies about the results of The Liberty-r Censulting Group's (" Liberty") independent review of the prudence of the management of STP. HL&P asked Liberty to perform a prudence investigation focusing cn the issues, areas, and topics addressed in the NRC's DET report. Liberty's objective was to determine whether those issues, areas, and topics indicated that STP had been imprudently managed during the period prior to the extended outage of 1993-94.
Liberty found that neither the DET report nor the issues raised in that report identified matters in which STP's management had made i
ur. reasonable decisions or taken unreasonable actions. Prior to the DET's review, STP's regulatory and economic performance had been solid and neither pointed to imprudent management. While improvements were called for in some areas, each such area had been identified and a plan for implementing such improvements was in place. The information from both internal and external sources, including'the NRC, available to STP would not have placed reasonable management on notice that STP needed to make significant changes to avoid regulatory difficulty.
Mr. Stright compares the NRC's diagnostic evaluatio$1 to a management audit performed for a state regulatory commission. A DET is similar to O
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the first phase Of a management audit in that it identifies areas of r
r concern en the basis of a snapsN t view of current performance. A DET is different frem a typical commission management audit, however, in that in a ecmmission audit there is generally a second, more detailed examinatien by the auditor of the issues identified in the diagnostic phase. The NRC, however, places the burden en the utility to conduct follow-up work on the issues identified by the DET. There is another i
significant difference between a state commission audit and one performed by the NRC. In a retrospective evaluaticn, a state commissien uses the prudence standard to assess management performance, whereas the NRC determines whether management perfo mance is yielding the desired results.
The extended 1993-94 cutage began with overspeed trips of the turbine-driven auxiliary feedwater pumps en both units of STP and a decision by STP's management to keep STP shut down until the cause of the
. trips could be identified and the pumps returned to reliable cperatien.
i Mr Stright testifies that HL&P's handling of the problems associated with the overspeed trips was prudent. A review of the entire history of the pumps led to the conclusien that STP had reason to believe the pumps were reliable and prior mechanical difficulties had been resolved. When i
overspeed trips occurred in early 1993, HL&P acted in a thorough and safety-conservative manner.
Liberty formed its conclusions on the basis of a detailed examination of the issues in the DET report. However, there are several ES-2
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general reascns why the issues addressed in the DET report did not lead s
to a finding of imprudence. First, Liberty found that substantive issues raised in the DET report had already been identified by HL&P in the exercise of reasonable management and that HL&P had taken reasonable steps toward resolving them. Second, HL&P had not had any indications of severe regulatory difficulty before the DET's review. Much of the feedback HL&P had received from the NRC had been very positive. While all prior DET reports on other plants had been very negative, HL&P had no reascn to expect that its operating and regulatory performance had been f
indicative of a trcubled plant. Therefore, STP'.c management had no reason to believe that a significant change in the way STP was being managed or in the pace in which issues were being addressed was required to avoid regulatory difficulties. Third, the DET could use hindsight and applied a rising standard of excellence, the implementation of which was evolving.
Liberty performed a detailed examination of the issues and examples contained in the DET report. Liberty drew conclusions about management's e
actions and decisions in the areas of operations, maintenance and testing, engineering, and management and organization. In each area Liberty found that management's actions and decisions were reasonable.
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1 ES-3
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(N 1
Q.
PLEASE STATE YOUR NAME, EMPLOYER, AND BUSINESS ADDRESS.
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3 A.
My name is Robert L.
Stright, I am employed by The Liberty 4
Censulting Group
(" Liberty")
I am a founder, principal, and 5
officer of the firm. Liberty's main office is located at 250 West 6
Pratt Street, Baltimore, Maryland 21201 7
8 Q.
ON WHOSE BEHALF ARE YOU PRESENTING TESTIMONY?
9 10 A.
I am presenting this testimony en behalf of Houston Lighting &
11 Pcwer Company ("HL&P")
12 13 Q.
WHAT IS THE PURPOSE OF YOUR TESTIMONY?
14 N
15 A.
My testimony presents the results of Liberty's review of the 16 prudence of the management of the South Texas Project ("STP"), a 17 nuclear pcwer plant of which HL&P is an owner and serves as the 18 cperator.
19 20 Both units of STP were out of service during most of 1993 and 21 early 1994. The extended outage began in early February 1993 when 22 HL&P took or kept the units off line as a result of overspeed 23 trips of the turbine-driven auxiliary feedwater pumps. While the 24 units were out of service, the staff of the U.S.
Nuclear 25 Regulatory Commission ("NRC") conducted a Dimgnostic Evaluation i
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26 Team ("DET") review of STP, and on June 10, 1993, the staff issued
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27 a report ("DET report") on that review. Following the issuance of HOUSTON LIGHTING & POWER COMPANY strtent a.s. ca. otr.cs t t - are true ne.
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FAGE 2 0.7 30 the CET repcrt, which was critical of STP, the NRC placed STP cn k,)h 2
its Watch List of plants that are to be given added regulatory 3
attention.
4 5
HL&P asked Liberty to perform a prudence investigatien focusing 6
on the issues, areas, and topics addressed in the DET report.
7 Liberty's objective was to determine whether, during the period a
prior to the extended outage, STP had been managed prudently with 9
respect to the issues in the DET report. Liberty sought to 10 determine whether STP's management should have been on notice 11 that a significant change was required in the way STP was being 12 managed or the pace at which issues were being addressed in order 13 to avoid significant regulatory difficulties.
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15 With respect to the issues addressed in the DET report, Liberty 16 found that STP's management had been prudent according to the 17 standard of prudence used by the Texas Public Utility Commission 18 and by utility commissions in general.
19 20 Liberty concluded that decisions made and actions taken by STP's 21 management during the period prior to the DET's review had been 1
22 reasonable. While improvements were called for in some areas, 2'
each such area had been identified and a plan for implementing 24 such improvements was in place. Furthermore, the information 25 available to STP's management from both internal and external 26 sources, including the NRC, did not indicate that STP needed to 1
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27 make significant changes to avoid regulatory difficulty.
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FAGE 3 CF 3 Q.
PLEASE SUMMARIZE YOUR EDUCATIONAL BACKGROUND.
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3 A.
I have a Bachelor of Science in Science Engineering degree from 4
Northwestern University.
I also hold a Master of Business j
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Administration degree from the University of Maryland.
6 7
Q.
PLEASE DESCRIBE YOUR BACKGROUND AND PROFESSIONAL EXPERIENCE 8
INSOFAR AS IT IS RELEVANT TO YOUR TESTIMONY.
e 9
10 A.
I have served as a management and technical censultant, primarily 11 in the public utility industry, since 1984. Most of my clients 12 have been public service commissions and electric and gas 13 utilities, and most of my work has concerned management and costs O
14 in the electric utility and telecommunications businesses. Prior 15 to beginning my consulting career, I served on nuclear submarines 16 in the U.S.
Navy, worked for Bechtel, a major architectural and 17 engineering firm, was a project manager for the NRC, and was the 18 licensing manager for a group of utilities that were ccnstructing 19 and operating standardized nuclear plants.
20 21 Much of my professional career has been associated with the 22 planning and management of complex operations and technical 23 projects. Most relevant to this testimony is my experience with 24 (1) the engineering, construction, operation, and maintenance of 25 commercial nuclear power plants, and (2) management audits of 26 utilities.
I have reviewed and consulted on nuclear plant
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27 management for both utilities and commissions. I have conducted HOUSTON LIGHTING & POWER COMPANY strs et m.t. c... zur.ct r.t - m erua..
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PAGE 4 CF 30 p
i effectiveness reviews of cutage management, regulatory i
2 management, and quality programs. ! have helped nuclear utilities 3
assess their own performance frcm many perspectives, including 4
those of the NRC and INFO, and have identified opportunities and 5
methods for improvement. I have worked on and managed a number of 6
prudence evaluations.
I have prepared work plans
- for, 7
participated in, and managed several management audits for state B
regulatory commissions.
9 10 My rssums is included with this testimony as Figure RLS-1, il 12 Q.
HAVE YOU PREVIOUSLY TESTIFIED BEFORE REGULATORY COMMISSIONS 7 13
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14 A.
Yes. I have testified before the commissions in Georgia and Ns 15 Texas. In Texas I submitted testimony as part of a panel in 16 Docket 6668. That rejoinder testimony responded to rebuttal and 17 surrebuttal testimony of six other witnesses who had testified 18 about the costs and schedule of the construction of STP.
19 20 Q.
WHO ASSISTED YOU IN THIS EVALUATION 7 21 22 A.
James Mallay and Leonard Owsenek assisted me.
23 24 Mr.
Mallay has had responsibility for a wide variety of 25 engir.eering projects in the commercial nuclear industry f or more
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26 than 30 years. He held successively more responsible engineering i\\
27 management positions for a major reactor manufacturer (Babcock &
HOUSTON LIGHTING & POWER COMPANY 8tright Aete Case Direct Tet a #TP frudence
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.n icox) over a 20-year period. He directed risk assessment l
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2 studies cf safety-related events for the EPRI Nuclear Safety l
3 Analysis Center.
He also served as Director for Eurcpean 1
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Cperations, Manager of Licensing, Manager of Performance l
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Analysis, and Manager of Safety Analysis.
6 7
In the consulting field, Mr. Mallay has had responsibility for a
project management and consulting services related to engineering 9
suppert of plant construction and operation, organizaticnal 10 diagnostics, nuclear and industrial safety, plant security, 11 configuration management, licensing, field engineering, control 12 room design enhancements, and reviews of management prudence. He 13 has performed cperatienal efficiency reviews, effectiveness b
r 14 reviews, and mid-term SALP reviews for a number of operating
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15 nuclear plants. Mr. Mallay served as (1) Director for the joint 16 NRC and industry program to develop and maintain a procedures 17 guide on probabilistic risk assessment and (2) Chairman of the 18 American Nuclear Society Standards Steering Committee.
19 20 Mr. Owsenek has 27 yeart of experience in engineering management,
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21 design, and consulting. His experience includes 13 years at 22 General Dynamics in managing equipment design development for 23 nuclear submarines and 14 years managing engineering design and 24 performing consulting work related to the development of design 25 modifications and maintenance process improvements for nuclear 26 and fossil power plants.
N 27 HOUSTON LIGHTING & POWER COMPANY Stright Rete Case Direct Tet. #T? Frudence
PAGE 6 OF 30 "r. Owsenek's nuclear pcwer plant experience directly related to Ih 2
the maintenance section of this work and was developed through 3
projects performed at a nunber of commercial nuclear power 4
plants. It included: (1) development of analysis concepts and 5
management of the successful maintenance department-based EPRI 6
full scale reliability-centered maintenance ("RCM") demonstration 7
project at the Ginna nuclear plant, (2) management of various e
EPRI periodic nuclear industry group RCM technology transfer 9
meetings and management of RCM projects at Commonwealth Edison 10 and Toledo
- Edison, (3) management of computerized post-11 maintenance testing program development, (4) individual plant 12 evaluation database design using equipment maintenance and 13 failure
- history, and (5) predictive maintenance program b
14 development for acoustic monitoring.
15 16 Mr. Owsenek's commercial nuclear plant experience also includes 17 engineering and maintenance work process evaluations and 18 procedures upgrades, management of plant life extension technical 19 reviews, development of a thermographic monitoring program to 20 monitor age-related degradation of critical components in the 21 containment environment, and computerized schedules for a major 22 component refurbishment program.
23 24 Q.
PLEASE DESCRIBE THE LIBERTY CONSULTING GROUP.
25 26 A.
The Liberty Consulting Group is a management and technical g
?7 consulting firm that provides services primarily in the public i
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utility ;ndustry I co-fcunded Liberty in July 1987 New in its h
2 seventh year of operation, Liberty has an extensive censulting 3
practice in the electric, gas, and telecommunications businesses.
4 Liberty's clients have included over forty utilities and eight 5
public service commissions.
The services that Liberty has 6
provided include:
Retrospective reviews of utility management decisions 7
a and processes.
Comprehensive management audits of electric and gas 9
10 utilities.
Audits of affiliate relationships and transactions at 11 12 telecommunications and energy companies.
13 Assistance in achieving measurable improvements in
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- safety, reliability, and cost-effectiveness at (m
15 operating power plants.
Independent studies, economic analyses, diagnostics, 16 17 and assessments of management performance.
Evaluation of the effectiveness of quality assurance 18 19 programs in helping to achieve goals and objectives.
Advice and recommendations for improving cost and 20 21 schedule monitoring systems used in managing power i
22 plant outages and complex projects.
23 24 Liberty has performed reviews and provided consulting services 25 for utility clients in twenty states. Liberty has also been 26 retained by the utility commissions of Connecticut, the District k
HOUSTON LIGHTING & POWER COMPANY serient m.t. c... str.et tot - srr erv4.ne.
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cf Cciriia, Illinois, Maryland, New Jersey, New York, Ohio, and
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2 Pennsylvania to perform studies of seventeen utilities.
3 4
Q.
WHAT IS A DET REVIEW AND HOW DOES IT COMPARE WITH MANAGEMENT 5
AUDITS CONDUCTED FOR STATE UTILITY COMMISSIONS?
6 7
A.
According to the NRC, a diagnostic evaluation is a comprehensive 8
assessment of current performance. The DET at STP included 15 NRC 9
evaluators in a 5-week evaluation. In some ways a DET review 10 resembles a state commission management audit but in other ways 11 it is very different.
12 13 In many of the management audits that Liberty has performed for 14 state utility commissions, a first phase of the study is
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l 15 diagnostic in that it identifies issues and areas that merit 16 further study. During this phase of an audit, a broad examination 17 of current performance is undertaken to determine potential areas 18 for improved quality or cost of service or for further study. In 19 the second phase of a typical management ardit, particular areas 20 are examined in more detail, facts are verified, and hypotheses 21 about areas needing improvement are tested.
22 23 The ' NRC's DET was similar to the first phase of a management 24 audit in that it identified areas of concern on the basis of a 25 snapshot view of current performance. In a typical commission p
26 management audit, however, the auditor then performs a more i
\\s 27 detailed examination of the identified issues. In a DET, the NRC HOUSTON LIGHTING is POWER COMPANY Stright Rate Case Direct Tat = STP Prudence
e PAGE 9 CF 30 1
places the burden on the utility to conduct any folicw-up work en the issues identified by the DET and to prcpose a respense. The 2
s 3
utility has the cption to contest the DET's finding or persuade 4
the NRC t hr.: actions taken or proposed will satisfactorily 5
resolve the issue. Most utilities choose the second course of 6
action en the grounds that it is more cost effective and 7
ultimately more comprehensive to do so.
8 l
9 There is another significant difference between a
state 10 commission audit and one performed by the NRC. In a retrospective 11 evaluation, a state commission uses the prudence standard to 12 determine whether the decisions made and actions taken by 13 management wave reasonable given the infomatien available at the
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14 time. The NRC examines the outcome of the decision-making process t
15 to determine whether the decisions made or actions taken have 16 been effective in achieving the desired results.
17 18 Q.
PLEASE EXPLAIN THE RELEVANCE OF THE RESULTS OF THE DET'S REVIEW 19 IN THE CONTEXT OF THIS PROCEEDING.
20 21 A.
The NRC decided to perform the DET r2 view at STP in late January 22 1993 and informed HL&P of that decision on February 12. While the 23 NRC had perfomed diagnostic evaluations prior to the one at STP, 24 it had not performed any for over a year. HL&P recognized that 25 this was an unusual regulatory action and one that in other cases 26 had been the precursor of regulatory difficulty. The announcement
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27 that the NRC planned to perform a DET at STP came as a surprise HOUSTON LIGHTING & POWER COMPANY 8tright Rate Case Direct Tat - STP Prudence
PAGE 10 CF 3C 1
to the owners because STP's regulatory and operational 2
performance had been solid. Just three months before the NRC 3
decided to perform the DET, it had issued a SALP report in which 4
STP continued its streak of SALP reports with all functional I
areas rated either "1"
(superior) or "2"
(good) and no functional 5
6 areas rated "3"
(adequate). Even though the SALP report on STP was 7
good, HL&P had developed action plans for those areas identified 0
as offering opportunities for improvement. The historical record 9
of NRC correspondence and inspection reports did not suggest 10 performance needed to be significantly altered to avoid 11 regulatory difficulty. Finally, STP had just completed a year in 12 which Unit I had a 66 percent capacity factor despite a refueling 13 outage, and Unit 2 had produced more power than any other single O
14 generating station in the U.S.
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15 16 The DET performed its review during the month of April 1993. On i
17 June 3, 1993, the NRC held a public exit meeting to review the 18 results of its evaluation. As I mentioned before, the NRC issued 19 the DET report on June 10, 1993. The report raised no substantive 20 issues that had not previously been identified by HL&P but the 21 tone of the DET report was particularly harsh, 22 23 The results of the DET's review of STP were a significant factor 24 in actions taken by the NRC beginning in May 1993. During that 25 month, the NRC issued a confirmatory acticn letter supplement 26 that listed certain matters that had to be resolved to the NRC's d
27 satisfaction before either unit at STP could resume operation.
HOUSTON LIGHTING & POWER COMPANY Stright Rate Case Direct Tst - STF Frudence
FASE 11 OF 33 1
These same matters had just been addressed as part of the CET's k
2 review. Later, the NRC placed STP on its so-called Natch 1:st cf 3
plants requiring additional NRC attention. The transcript of the 4
meeting of the NRC Commissioners on June 25, 1993 shows that the 5
results of the DET's review played a significant role in the 6
NRC's decision to place STP on the Watch List.
7 8
The results of the DET's review clearly brought increased NRC 9
regulatory scrutiny and influenced the length of the extended 10 outages at STP in 1993 and early 1994. This was confirmed again 11 in February 1994 in comments by the Chairman of the NRC, who 12 noted that the issues that needed to be resolved before the NRC 13 would permit STP to resume operations were those identified in 14 the DET report.
15 16 In light of the importance of the DET's review to the NRC's 17 regulatory actions and the extended outages at STP, an inquiry 18 into the issues raised in the DET report is of obvious relevance.
19 Since the DET applied a far different standard than would be 20 applied in a prudence review, Liberty's task was to evaluate 21 whether HL&P was prudent in its decision-making and management 22 performance in the areas addressed by the DET report.
23 24 Q.
YOU SAID THAT THE 1993 OUTAGES STARTED AS A RESULT OF TRIPS OF 25 THE TURBINE-DRIVEN AUXILIARY FEEDWATER PUMPS. WERE THOSE TRIPS 26 fg THE RESULT OF IMPRUDENT MANAGEMENT 7 27 HOUSTON LIGHTING & POWER COMPANY strsos e.t. e... etr.es 2.s - en erve.ne.
I PAGE 12 cr 33 A.
'*. The trips were the result of mechanical pr blems. Mereover, 2
HL&P's handling of the prcblems associated with the overspeed 3
trips was prudent. A review of the entire history of the turbine-4 driven auxiliary feedwater pumps led to the conclusien that STP 5
had ample reason to believe the pumps were reliable and prior difficulties had been resolved. When overspeed trips occurred in 6
7 early 1993, HL&P acted in a thorough and safety-censervative 8
manner. Only by applying hindsight can it be said that different 9
actions should have been taken earlier, t
10 11 Q.
PLEASE SUMMARIZE YOUR OVERALL CONCLUSIONS.
12 13 A.
Liberty found that HL&P's management decisions and performance in 14 the areas addressed by the DET had been reasonable. Liberty 15 concluded that the DET report did not point to areas of 16 imprudence by HL&P in the management of STP and that none of the 17 problems or issues identified in the DET report were the result 18 of unreasonable decisions made or actions taken by STP's 19 management. The detailed results of Liberty's review and the
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20 bases for Liberty's conclusions are presented in a report, Figure 21 RLS-2, "An Assessment of HL&P Management Prudence at the South 22 Texas Project." This report presents the results of Liberty's 23 independent investigation and evaluation of the prudence of 24 HL&P's management decisiens and performance, prior to the 25 issuance of the DET report, in the areas addressed by the DET 26 report.
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Liberty found that the substantive issues identified in the OET 2
report had been identified by HL&P. F'Nthermore, with respect to 3
identified areas needing improvement, HL&P had taken reasonable 4
steps to make improvements and had made substantial progress 5
before the OET's review was conducted. HL&P's specific corrective 6
actions and progress in implementing improvements were not 7
discussed in the DET report, since that report focused on results B
and used the benefit of hindsight. As is proper in a prudence 9
investigation, however, all of HL&P's activities, including self-10 assessment, problem identification, and improvement initiatives, 11 have been evaluated in the context of what was known at the time 12 decisions were made and actions were taken.
13 14 HL&P could not have reasonably anticipated the harsh criticism 15 contained in the DET report and should not have been, in the 16 exercise of prudent management, on notice that significant 17 changes were immediately necessary if STP was to avoid regulatory 18 criticism.
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1 20 In concluding that STP's management had made reasonable decisions 21 and taken reasonable actions in the months preceding the extended 22 outage, Liberty does not mean to imply that improvements could 23 not be made. To do so would be to argue that STP's management was 24 perfect. It was not and can never be. It is the NRC's task to 25 push its licensees closer to that elusive goal of perfection. It 26 is this Commission's task to determine whether STP's management
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27 acted reasonably in pursuing that goal while generating economic HOUSTON LIGHTING & POWER COMPANY seriot... e... nr..
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PAGE 14 OF 3 0 electrical p wer. It is Liberty's professional opinien that i s
2 did sc.
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4 Finally, it is not Liberty's intention to question the NRC's 5
motives in conducting the DET or its intentions in writing the 6
DET report. In arriving at Liberty's opinions, we are mindful of 7
the NRC's preeminent mandate to protect the public health and a
safety. Nevertheless, we believe it important for this Commission 9
to look closely at all the facts surrounding the extended outage 10 and the reactions of both the NRC and STP's management to them.
11 It is even more important that the commission, in reviewing these 12 facts, evaluate them in light of the Commission's standards of 13 review and not those of the NRC.
14
.D 15 Q.
SHOULD THE DET REPORT ALONE LEAD TO A CONCLUSION THAT HL&P WAS 16 IMPRUDENT IN ITS MANAGEMENT OF STP?
17 18 A.
No. First of all, it is important to recognize that the DET's 19 review was never intended to be an evaluation of management 20 prudence. The criticisms of STP contained in the DET report 21 should be taken for what they are, namely, contemporaneous 22 opinions and findings based en hindsight regarding the outcome of 1
23 actions taken and decisions made. While the DET report is an I
24 important NRC document, it is not the only report issued by the i
25 NRC with respect to STP. It is also not the only document 26 relevant to the issues raised by the DET report.
k 27 HOUSTON LIGHTING & POWER COMPANY Stright Rate Case Direct Tat. ST? Prudence
PAGE 15 OF 30 Diberty found no indicatiens of significant NRC regulatory 2
problems at STP prior to the DET's review. For that reason, the 3
DET's review stands out as a surprisingly critical report 4
cc= pared to prior NRC assessments and inspection reports.
5 Furthermore, as is clearly shown in the attached report, full 6
consideration of the available information, and application of 7
appropriate criteria for judging prudence, reveal that the 8
decisiens made and actions taken by STP's management had been j
9 reasonable, even though the results of those decisiens were i
10 criticized in the DET report.
11 i
12 In fact, no NRC document can or should be used, in and of itself,
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13 as the basis for a conclusion regarding management prudence. The 14 NRC's inspections and assessments are not prudence evaluations.
15 The NRC is solely concerned with nuclear safety. Unlike a 16 prudence review, the NRC's inspection activities can and should 17 rely en hindsight and the evaluation of results.
18 19 However, NRC inspection and enforcement documents can be relevant 20 in conducting a proper investigation of prudence. The NRC's view 21 as to the important issues provides an appropriate basis for 22 inquiry as to the reasonableness of management's actions and 23 decisions related to those issues. The NRC's view as to the cause 24 of problems can also be instructive. Another important inquiry is 25 whether issues identified in NRC documents were recurrent or were 26 allowed to continue unaddressed for unreasonable lengths of time, s
27 However, the existence of a p.roblem, and its citation in an NRC HOUSTON LIGHTING & FOWER COMPANY Stright Rate Case Direct Tot. STr Prudance
FAGE 16 CF 30 repcrt or any other document, does not constitute dispcsitive I
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2 evidence that management was unreasonable or imprudent in failing 3
to anticipate and prevent or to recognize and immediately correct 4
a problem. On the centrary, determination of prudence requires 5
full consideration of the circumstances in which management made 6
decisions and acted, and evaluation of the reasonableness of 7
management processes, procedures, plans, controls, and actions e
under those circumstances. NRC reports typically use results or 9
outcomes as the basis for their conclusions. Clearly this cannot 10 be the basis for drawing conclusions concerning management 11 prudence.
12 13 Q.
PLEASE DESCRIBE THE METHOD LIBERTY USED TO PERFORM ITS 14 EVALUATION.
w 15 16 A.
Liberty exarined the statements, conclusions, analyses, and many 17 of the supporting examples presented in the DET report. Using 18 both the information that was provided or available to the CET 19 and, in some cases, more current data, Liberty investigated I
20 whether management had behaved prudently in the areas discussed i
21 in the DET report. Liberty focused its efforts on determining 22 what information had been or should have been available to STP's 23 management at the time decisions were made and what actions 24 management had taken in response to that information. For each 25 significant problem or issue identified in the DET report, 26 Liberty sought to determine whether STP had been aware of the f
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HOUSTON LIGHTING f POWER COMPANY Stright Rate Cass Direct Tat - STP Prudence
PAGE 17 OF 30 matter and whether the actions taken in respense to it had been I(
2 reasenable.
3 4
Q.
DID LIBERTY HAVE ACCESS TO INFORMATION THAT HAD NOT BEEN i
5 AVAILABLE TO THE DET?
6 7
A.
Yes. Liberty conducted its review nearly a year after the DET's a
review. Therefore, Liberty had the advantage of having some i
information not available to the DET. This was important in a few 9
1 10 cases in which the DET had formed conclusions on the basis of i
inf ormation that was preliminary. Evaluations performed af ter the 11 12 CET had completed its review shed new light on the nature and 13 significance of a few matters addressed in the DET report.
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14 Moreover, Liberty had the benefit of more time than was available
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15 to the DET to assimilate and evaluate information. In some ways, 16 Liberty's review was like the second phase of a management audit 17 in which the issues and concerns identified during the diagnostic 18 phase were examined in greater detail.
19 20 Q.
DID THE DET REPORT MAKE ANY POSITIVE COMMENTS ABOUT STP?
21 22 A.
Yes. The DET made several favorable comments about STP. For 23 example, the DET said that STP had a dedicated operations staff, 24 excellent maintenance facilities, and a
comprehensive 25 modification program. The DET also said that STP had identified 26 "most of the problems" included in the DET report. (Ref.
DET l
[D f
27
- report, p.
38.) However, in general, the DET's assessment was I
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cr:tical. The DET repcrt was even critical of areas that had k
2 censistently received goed performance assessments in prier 3
reviews conducted by others, including prior NRC inspecticn 4
teams.
5 6
Q.
DOES THE SHEER NUMBER OF PROBLEMS IDENTIFIED IN THE DET REPORT 7
PROVIDE AN INDICATION THAT THERE WERE SERIOUS MANAGEMEITI e
WEAKNESSES AT STP7 9
10 A.
No. All commercial nuclear power plants in the United States are 11 complex facilities that must abide by strict rules like the 12 Technical Specifications and all work must be performed in 13 accordance with detailed procedures. Any deviation from the rules 14 or procedures must be documented. In addition, one of the primary 15 methods of ensuring safe operation at a nuclear plant is to have 16 a comprehensive assessment program. These assessments come from 17 both internal and external sources.
- Audits, inspections, 18 surveillances, self-assessments, and evaluations are constantly 19 being conducted at nuclear plants. In fact, one of the reasons 20 nuclear plants are so expensive to operate is that many people 21 spend all or a large portion of their time either performing or 22 responding to such assessments. All of the assessments record 23 findings relating to issues that need to be resolved or areas 24 that can be improved. Problems and issues do not eventually go 25 away because the standards keep rising, the reviews are so 26 detailed, and people will always make some mistakes. For this
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27 inquiry, the important issue was not whether the number of HOUSTON LIGHTING & POWER COMPANY q
8tright Rate Case Direct Tat - #TP Prudence
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2 these problems indicated imprudent management by HL&P.
3 4
Q.
DID YOU FIND THAT STP'S OPERATIONAL RECORD PRIOR TO THE DET 5
EVALUATION FORESHADOWED THE KINDS OF CRITICISMS CONTAINED IN THE 6
DET REPORT?
7 8
A.
No. Prior to the DET's review, STP had a good operational record 9
and appeared to be in good standing with the NRC. Other plants 10 that have been placed on the NRC's Watch List have either 11 experienced significant operational events or had continual 12 warnings about certain aspects of plant operation or support that 13 were not performing well. STP had neither of these signs. Even 14 the Chaiman of the NRC said that STP was very unusual in that it 15 did not present the indications of being a " problem plant" that 16 ordinarily "just hit you in the face " (Ref.- Ivan Selin press 17 conference, February 16, 1994.)
18 19 Q.
IF TRAT WAS THE CASE, WHY DID THE NRC CONDUCT THE DET REVIEW AT 20 STP?
21 22 A.
The letter from the NRC that informed HL&P of the plans to 23 conduct the DET review did not contain specific reasons why the 24 DET was to be perfomed. The DET report, however, cited a decline 25 in STP's SALP performance in its introduction. However, this 26 decline did not appear to be a significant one, HL&P had taken
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PAGE 23 0F 30 s
SALP reptrt as needing imprevement, and insufficient time had
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3 4
The DET report also said that hardware prcblems and personnel 5
errors had resulted in reactor trips and plant transients.
6 However, STP's performance in this area had improved considerably 7
from its initial years of operatien. The DET report noted that an 8
NRC Cperational Safety Team Inspection ("OSTI")
conducted in 9
December 1992 found that the issues associated with hardware 10 problems had not been resolved. While the OSTI had expressed 11 concerns related to the identification and resolution of hardware 12 deficiencies, it also found that STP was staffed by " competent 13 knowledgeable persennel who executed their duties in a
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14 professicnal manner. Several notable strengths were identified in 15 the area of plant operations." (Ref.
NRC OSTI report, March 3, 16 1993.)
17 18 Q.
EVEN THOUGH THE DET'S EVALUATION WAS NOT A PRUDENCE REVIEW, IS IT 19 NOT THE CASE THAT A REPORT THAT WAS SO CRITICAL OF STP'S 20 MANAGEMENT MUST HAVE IDENTIFIED AREAS IN WHICH MANAGEMENT HAD 21 BEEN IMPRUDENT 7 22 23 A.
No. Liberty formed its conclusions on the basis of a detailed 24 examination of the issues addressed in the DET report. There are 25 also several general reasons why the issues addressed in the DET p
26 report should not lead to a finding of imprudence. First, Liberty I(
27 found that issues raised in the DET report had already been HOUSTON LIGHTING & POWER COMPANY j
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identified by HL&P and that HL&P had already taken reasonable
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2 steps toward resolving them Except for a single all-encompassing 3
statement, the DET report made little mention of HL&P's prior 4
identification of areas that needed improvement. Furthermore, the 5
CET report did not discuss the actions HL&P had taken to resolve 6
these problems or the progress it had made toward achieving 7
worthwhile improvements.
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9 second, HL&P did not receive any indications of severe regulatory 10 difficulty before the DET's review. Much of the feedback HL&P had 11 received from the NRC had been very positive. While areas that
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12 required attention had been identified, there had also been clear 13 indicatiens that improvements were being made and that STP was a r
IV solid performer. While all prior DET reports on other plants had 14 15 been very negative, HL&P had had no reason to expect that its 16 cperating and regulatory perfonnance had been indicative of a so-17 called troubled plant. Therefore, STP's managtment had no reason 18 to believe that a significant change in the way STP was being 19 managed was required to avoid regulatory difficulties.
20 21 Third, the DET used hindsight and applied a rising standard of 22 excellence, the implementation of which was evolving.
i 23 24 Q.
PLEASE DESCRIEE THE ORGANIZATION OF YOUR REPORT, FIGURE RLS-2.
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26 A.
Liberty's report consists of five chapters.
These are:
27 Introduction, Cperations, Maintenance, Engineering, and HOUSTON LIGHTING & POWER COMPANY i
Stright Bate Case Direct Tat. STP Prudence j
PAGE 22 CF 30 1
Mana ement.
The first chapter prcvides seme backgrcund 2
information, explains hcw Liberty conducted its review, and 3
su = arizes Liberty's conclusions. The last four chapters parallel 4
the DET report's crganization and present Liberty's evaluatien cf 5
management prudence with respect to the issues raised in the DET 6
report in each of these functional areas.
7 8
Q.
WHAT WERE YOUR FINDINGS IN THE AREA OF OPERATIONS?
9 10 A.
With respect to the issues identified by the DET, Liberty found 11 that the decisions made and the actions taken in the operations 12 area of STP had been reasonable and prudent. For example, Liberty 13 concluded that the decisions made regarding operator staffing S
14 were reasonable. The bases for such decisions were not only the 15 experience and judgment of STP's management but also independent 16 staffing studies that were regularly conducted in order to 17 provide further guidance en staffing issues. NRC evaluations 18 ccnducted prior to the DET's review, as well as independent i
19 staffing studies performed for STP, indicated that the size of 1
20 the staff was adequate.
STP assign.d licensed operations 21 personnel to other parts of the organization, and there was i
22 substantial operational experience in the organizations that 23 interfaced with operations. The issues discussed in the DET 24 report did not indicate that decisiens with respect to operator i
25 st:if fing had been unreasonable because such decisions f ailed to 26 account properly for the plant-specific work load.
27 s
HOUSTON LIGHTING & POWER COMPANY Stright Rate Case Direct Tat - STP Prudence
PAGE 23 2F 30 1
Support to cperatiens was reascnable. For example, STP had placed Q
2 emphasis, and had achieved progress, on reducing the number of 3
inoperable automatic functicas.
The problems that the DET 4
attributed to the use of a computer system were more likely 5
caused by c:mpeting requirements in the NRC Technical 6
specificatiens than by inadequate support to operations.
7 8
In May
- 1992, STP took aggressive actions to improve 9
communicatiens between management and the control room staff 10 after the discovery that an incomplete test procedure was not 11 immediately reported to the plant operators.
12 13 The DET used the example of inadequate labeling of plant 14 equipment to support several of its conclusions. However, Liberty
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15 found that, prior to the DET's review.
HL&P had applied 16 considerable resources to labeling of plant equipment after it 17 became apparent that labeling could have contributed to personnel is errors.
l 19 20 Operator performance at STP was consistently praised by the NRC 21 and other evaluators. The DET's conclusion to the contrary 22 represented a marked departure from these other assessments and 23 prior NRC inspection reports. Liberty's conclusion, which was 24 formed on che basis of a detailed review of the examples used by 25 the DET, was that in light of the positive evaluations of the NRC 26 and others, the DET report's criticisms of operator performance,
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support assertiens of imprudent management.
3 4
Finally, the DET did not identify any substantive issues that 5
STP's management had not already identified, implemented 6
effective corrective actions on, or made progress toward 7
resolving by the time the DET performed its evaluation. With e
respect to some matters, Liberty found that more accurate or 9
complete information led to conclusions with respect to the 10 reasonableness of management's decision and actions that were il significantly different from those that might be inferred from 12 the DET report.
13
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14 Q.
WHAT WERE YOUR FINDINGS IN THE AREA OF MAINTENANCE AND TESTING?
U 15 16 A.
Liberty found that while the DET report did identify areas in 17 which improvement was needed, an evaluatien of those areas did 18 not show that STP's management had made unreasonable decisions or 19 taken unreasonable actions in the area of maintenance.
20 Particularly noteworthy were HL&P'c ongoing efforts to identify 21 areas that needed improvement, the measures taken by HL&P to make 22 such improvements, and the progress actually made. Liberty also 23 found that prior NRC assecaments and inspections would not have 24 caused reasonable management to conclude that significant changes 25 in the way maintenance was managed were necessary in order to 26 avoid adverse regulatory action.
O 27 HOUSTON LIGHTING & POWER COMPANY Stright Rete case Direct Tat - STP Prudence
PAGE 25 CF 30 1
In seme cases, the CET reached conclusiens on the basis of (m
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2 preliminary infc=ati:n. Facts that became kncwn after the DET's 3
evaluation caused Liberty to reach conclusiens as to the 1
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reasonableness of management different from those that might be 5
inferred from the DET report. In other cases, a review of the facts related to a particular example resulted in Liberty drawing 6
7 different conclusions and formulating different 8
characteri:ations. The DET sometimes cited dated examples from 9
years past without discussing the corrective actions taken in the 10 meantime. The way in which the DET presented some information 11 could give the impression that it had analyzed the issues at STP 12 in isolation and failed to take into account an industry-wide l
13 perspective. That perspective often revealed that difficulties 14 encountered at STP, with preventive maintenance, for example, had k
15 not been unique but characteristic of the nuclear industry as a 16 whole.
17 18 Perhaps the criticism that most heavily influenced the outcome of 19 the DET report in the area of maintenance was related to the size 20 of the maintenance backlog. In evaluating the reasonableness of 21 management's decisions and actions that may have af fected the 22 size of the backlog, several factors must be kept in mind.
23 24 First, the size of the backlog can be related to the plant's 25 operational history and, at the time of the DET's review, STP 26 Unit 2 had just completed a run in which it operated virtually 27 continuously for over a year. Second, STP's three-train design HOUSTON LIGHTING & POWER COMPANY seriene nat. c... etr.es r.
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than a twc-train plant. Third, the backlog at the time of the 3
CET's review was not inconsistent in size with the backlogs that existed when maintenance practices at STP had been praised by the 5
';R C. Ecurth, the great bulk cf the maintenance backlog was in low 6
priority, non-safety related tasks. Fifth, STP had implemented 7
measures that had continued to improve the efficiency of the 8
maintenance work control process and thus facilitate a reducticn 9
in the backlog.
10 11 Prudent management responds to the best inf ormation available to 12 it at the time. Pricr to the DET's review, STP's management 13 reasonably ccncluded that the size of the maintenance backlog and
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15 backlog was not causing operaticnal or reliability concerns. Once 16 it became cbvicus that the NRC would require STP to operate with 17 a much icwer backleg level, STP's management responded reasonably 18 to the new standard.
19 20 Q.
WHAT WERE YO' FINDINGS IN THE AREA OF ENGINEERING?
21 22 A.
Liberty reviewed the engineering activities criticized by the DET 23 and, in the centext of the prudence standard, determined that STP 24 management had made reascnable decisions and taken reasonable 25 actions given the knowledge and circumstances that existed at the 26 time. Moreover, in many cases Liberty found that the information l,
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- nccmplete cr preltminary Liberty determined that HLtP had i
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2 identified the significant issues, and had taken acticns to 3
resclve those issues. It is the use cf hindsight (which is 4
inappropriate in a prudence audit) that allowed the DET to 5
ccnclude that engineering's actions had not been effective.
6 Finally, Liberty concluded that some of the matters discussed in 7
the DET report need to be examined in light of industry e
experience and the significance of the issues presented in the i
9 DET report needs to be carefully considered.
10 11 Management recognized that STP's system engineers had a heavy 12 work lead and, prior to the DET's evaluatien, had made 13 adjustments in the divisien of responsibilities. Liberty found n
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21 22 The DET's criticisms of engineering support at STP stood in stark 23 centrast to prior NRC views. Given the litany of praise from 24 previous NRC inspections, it is easy to understand the surprise 25 with which HL&P received the harsh criticisms contained in the 26 DET report. Taking into censideration that the DET's review may n
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PAGE 28 CF 30 1
that the decisions made and actions taken by STP's management in 2
this area were reasonable.
3 4
Liberty's analysis of the issues in the DET report demonstrated 5
that HL&P had conducted its affairs in a sound, business-like 6
manner. It managed engineering resources very closely, making 7
sure they were sufficient to support plant operations and 8
maintenance activities. HL&P kept engineering resources at a size 9
that was cost-effective.
- Safety, quality, and operational 10 readiness were held paramount in the management of resources.
11 12 Engineering at STP was very conscious of the importance of having 13 independent evaluations made to help enhance its performance and 14 internal processes and to provide technical assistance in t
15 properly addressing equipment performance and reliability issues.
16 In the two-year period prior to the time of the DET's 17 investigation, 15 individual studies were performed for 18 engineering, either alene or in conjunction with other 19 departments. HL&P carefully evaluated the results presented in 20 each report and implemented beneficial actions on the basis of 21 the insights and technical advice that were offered. In Liberty's 22 view, the regular studies of engineering and the fact that 23 actions were taken as a result was strong evidence of prudent 24 management.
25 1
w 26 Q.
WHAT WERE YOUR FINDINGS IN THE AREA OF MANAGEMENT AND
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27 ORGANIZATION?
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PAGE 29 OF 30 s
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- espite the critical nature of the CET repert, Liberty's analysis showed that HL&P had made retsonable decisiens and taken 3
reasonable acticns in the areas examined by the DET. Two points 4
are worthy of note in this regard. First, the NRC in its role as 5
safety regulator is primarily concerned with outcomes. Thus the 6
NRC is not content that a licensee choose from among reasonable 7
options. The NRC is concerned with whether the cptien chosen 8
achieved the desired result. This is a fundamental distinction 9
between the NRC's diagnostic evaluation and a PUC diagnostic.
10 Second, like all diagnostic evaluations, the DET took a snapshot 11 of the project and identified areas of possible concern and areas 12 in which performance appeared to be deficient or could be 13 improved.
15 Liberty examined the DET's findings, and the facts that were used 16 as support for them to see if the issues raised showed that STP's 17 management had made unreasonable choices or taken unreasonable 18 actions and not to determine if the choices or actions had been 19 effective.
l 20 21 In many instances Liberty could not substantiate the DET's 22 original concerns. For example, the DET indicated there was a 23 lack of experience at other nuclear facilities; yet the objective 24 evidence showed that experience at other nuclear facilities had 25 been ample.
26 HOUSTON LIGHTING & POWER COMPANY striot a.t. e... car.et ret - m erua.nc.
PAGE 30 CF 30 7--
1 The CET indicated that insufficient resources were being
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2 dedicated to STP. Liberty found that STP's budgeting process and 3
practices were reascnable and realistic. A proposed budget line 4
item does not become reasonable just because it is accompanied by 5
a written justification; management does not behave unreasonably 6
just because it rejects such a justification. In fact, management 7
could be viewed as unreasonable if it approved every budget a
request just because it was accompanied by a justification. Nor 9
is it unreasonable to delete a previously approved budget item in 10 the face of changed circumstances.
11 12 The overwhelming evidence indicated that staffing decisions had 13 been reasonably made 'on the basis of adequate study and expert N
14 advice. The DET was critical of the use of task forces at STP.
15 Liberty's review of the task forces that were active at the time 16 of the DET's review showed that their use had been a reasonable 17 supplement to, not a substitute for, an adequate permanent 18 organization. In the area of quality ove:: sight, the great weight 19 of the evidence received by STP's management indicated it had 20 made reasonable decisions and that this function was performing 21 well.
22 23 Q.
DOES THAT CONCLUDE YOUR TESTIMONY?
24 25 A.
- Yes, e-~s 26
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2 Resumd of:
3 ROBERT L. STRJGHT 4
Areas of Specialization 5
Project management; regulatory management; management auditing; training and organizational 6
development: affiliate relations and fnancial transactions; operations performance assessments:
quality assurance effectiveness; cost and schedule analysis; microcomputer applications; 7
8 engineering and construction management evaluations.
9 Relevant Experience 10 Robert Stright is one of the founders of The Liberty Consulting Group and has had over twenty-1I seven years of professional experience. Mr. Stright served in the nuclear navy, including a tour as 12 engineer officer aboard a nuclear submarine. He worked for a major architect-engineering firm, 13 was a project manager with the Nuclear Regulatory Commission (NRC), and was a principal la member of a nuclear project owners' management group responsible for licensing and overseeing 15 the activities of contractors in the design and construction of a standardized plant for several 16 utilities. Mr. Stright has had overall management responsibility for Liberty's engagements where U) 17 the objectives were to improve critical self-assessment capabilities, identify performance
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18 improvement opportunities, recommend specific actions to improve performance as measured by 19 NRC and INPO standards, and enhance regulatory relations.
20 Mr. Stright has played key roles in Liberty's management audits and was Liberty's representative 21 ori a three-party steering committee with oversight responsibility for an audit.
22 As consultant to two major utilities, he led the efforts to prioritize all work remaining from 23 construction and preoperational test phases of the projects. This effort involved resolution of 24 deferral of work and licensing issues with the NRC. He served as the utility's prime contact with 25 NRC resident inspectors.
26 As Project Leader, he was responsible for an assessment of a major utility's management activities 27 and decisions. Areas of evaluation included cost and schedule, organization and staffing, 28 procurement, executive management, engineering, and construction. He prepared and presented 29
. testimony for filing with a public utilities commission. Mr. Stright was responsible for an 30 assessment of costs related to contractor performance at a large nuclear power project. This 31 included an assessment of litigation claims and defenses. He identified issues that adversely 32 affected project ccsts and determined costs attributable to issues related to performance.
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m He deseloped a methodology for utilizing computerized data bases for projects that required 1
2 digesting. storage, and retrieval oflarge numbers of documents and information data. He also has 3
developed microcomputer applications for analytical modeling, graphical analysis and 4
presentation, and communications.
5 51r. Stright was the Task Area Leader for the development of a transaction database of the affiliate transactions of a telephone company. He led a review of affiliate interests of a major electric and 6
gas utility and managed the review of affiliate transactions of two other telephone companies.
7 h1r. Stright assisted in a retrospective review of the management of a significant outage at a 8
two-unit nuclear station. He served in a lead role in the analysis and evaluation and testified before 9
two state regulatory commissions on costs and schedules of major construction projects.
10 Nir. Stright has overall responsibility for the administration of The Liberty Consulting Group, 11 12 including all financial and contractual relationships, as well as personnel transactions and facilities 13 management.
He performed an :ffectiveness review of the quality, independent safety, and regulatory functions 14 15 for a utility and has performed several mid-term SALP reviews at nuclear plants.
Nir. Stright assisted in the direction and control (including organization, staffing. and business 16 17 development) of the SNUPPS project management team and coordination of the SNUPPS p) 18 utilities in directing major contractors for the Callaway and Wolf Creek projects. He was
'g 19 responsible for various special projects, including marketing of materials from canceled nuclear 20 units, development and implementation of a construction quality action plan, and development 21 of strategic corporate plans. As Licensing hianager, he was responsible for planning and 22 coordinating activities required to obtain federal licenses for the operation of the SNUPPS 23 plants. This included preparation of Safety Analysis Reports, representing the SNUPPS utilities 24 in technical meetings with the NRC, and performing technical reviews of safety analysis.
25 hir. Stright was Project Nianager with the U.S. Nuclear Regulatory Commission. He was 26 responsible radiological safety reviews of construction and operation applications and represented j
27 the regulatory stafT in meetings with utilities, in public hearings, and before the Advisory i
28 Committee on Reactor Safeguards. He received an NRC Commendation for professional
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29 performance in management of a unique safety analysis review method.
30 As a Senior Engineer with Bechtel, hir. Stright was responsible for licensing and safety analysis 31 for the company's nuclear projects. He was also responsible for a computerized licensing 32 information retrieval system. In this capacity, he interfaced with all engineering disciplines and 33 was assigned as the licensing engineer for Bechtel's standardized design for a five-unit nuclear 34 plant.
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l 1
i Mr. Stright served as a Line Officer in the U.S. Navy. He served on three nuclear submarines 2
including tours as weapons officer, as lead engineering watch officer during construction and 3
testing of a new ship, and as engineer officer. During this last assignment, he supervised approximately 75 people and was responsible for the operation, maintenance, and radiological 4
5 controls of the nuclear propulsion plant and the ship's auxiliary equipment. Mr. Stright was twice 6
awarded the Navy Achievement Medal for professional and meritorious ser ice.
7 Education 8
M.B.A., Finance / Operations Research - University of Maryland 9
B.S., Science Engineering - Northwestern University 10 Affiliations iI Registered Professional Engineer, Virginia 12 Member, American Nuclear Society 13 Member, American Management Association 14 Employment 15 U.S. Navy, Line Officer 16 Bechtel Power Corporation, Senior Engineer 17 U.S. Nuclear Regulatory Commission, Project Manager 18 Nuclear Projects, Inc., Licensing Manager 19 Management Analysis Company, Consultant t
20 The Liberty Consulting Group, Founder and Principal 4
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