Introduction

ABZ has evaluated management practices at nuclear power plants. ABZ has also provided expert testimony for Federal, state and private industry clients in law suits, administrative hearings, and arbitrations.

ABZ assists the legal team with:

• Rapid Identification and Analysis of Key Technical Issues
• Preparation of Deposition and Trial Examinations for Technical Witnesses
• Document Review, with a Focus on Identifying and Developing Technical Issues and Exhibits Critical to the Case
• Obtaining Critical Evidence During the Discovery Process

ABZ also provides expert testimony in support of litigation issues. Our team of experts offers assistance with:

• Expert Testimony on Technical Issues to Support the Fact Finder's Understanding of Complex Issues.
• Substantial Court Testimony Experience Including Regulatory Agencies and Arbitration Panels.

The following provides a brief description of a selection of ABZ's commercial litigation case work:

Pacific Gas and Electric versus Sacramento Utility District

ABZ reviewed all aspects of the nuclear organization responsible for the Rancho Seco Station. This included a review of the performance of the organization in response to difficult technical problems, such as pressurized thermal shock, modifying the turbine control system, incorporating vendor-recommended design changes and nuclear regulatory inspections. Detailed performance criteria were developed for each functional area in the plant and comparisons were made to other facilities. These functional areas included radiation protection, quality assurance, design control, maintenance, operation and regulatory compliance.

To perform the review, ABZ reviewed the nearly eight years of plant data, Institute of Nuclear Power Operations (INPO) reports, Nuclear Regulatory Commission (NRC) evaluations, design changes, utility correspondence and licensee event reports. In addition, specific relationships were developed between the plant performance and the effectiveness of the Board of Directors. The analysis was submitted as expert testimony by the Pacific Gas and Electric Company (PG&E) to the Federal Energy Regulatory Commission (FERC).

Engineering Analysis Of the Salem Unit 1 Failure to Restart Following the Athos I Oil Spill

ABZ evaluated the technical aspects of a utility's claim that an oil spill caused the shutdown and delayed the startup of two nuclear power plants. ABZ evaluated the claim and its supporting documentation to understand the technical aspects of the claim. ABZ developed inquiries to obtain additional data and information needed to understand the causal relationship between the technical events described in the claim and the oil spill. Finally, ABZ evaluated and verified the causal relationship between the technical issues in the claim and the effects of the oil spill.

Diablo Canyon Rate Case

ABZ reviewed and evaluated the regulatory responsiveness of the Pacific Gas and Electric Company (PG&E) to the changing Nuclear Regulatory Commission (NRC) requirements during the construction of the Diablo Canyon Power Plant. Specific emphasis was placed on PG&E's efforts to show that the plant would respond safely during an earthquake. ABZ reviewed the modifications to the plant's response spectra as the design basis earthquake changed over time from the original design to the final spectra as determined by the HOSGRI fault.

In addition, ABZ evaluated the root causes of the so-called mirror image problems on the containments. This analysis included a detailed review of the nature of the problem, its overall effect on the plant's ability to withstand a design basis earthquake and the adequacy of the design changes proposed. Finally, ABZ reviewed the effectiveness of the nuclear organization in responding to these issues to the satisfaction of the regulator and the public.

Evaluation of Pilgrim Nuclear Power Plant

ABZ provided Commonwealth Electric Company (CECO), a co-owner of the Pilgrim Nuclear Power Plant (PNPP), with a comprehensive and detailed evaluation of the plant's personnel, organization, regulatory effectiveness, and improvement programs. As part of the evaluation, ABZ performed several "vertical audits" in technical areas, including design modifications, technical procedure adequacy, and implementation of the plant's test program. These audits revealed several inadequacies, which predicted the continued poor performance of the facility. The information gathered allowed CECO to renegotiate its agreement and obtain a large settlement from the plant's owner. In addition, ABZ assisted CECO in establishing a periodic review program to protect its remaining interests in the facility. Finally, ABZ provided CECO with an analysis of the plant's past performance using indicators which clearly showed fundamental changes in the organization were needed. Much of ABZ's analysis used commercial nuclear power standards and regulations as measures of performance.