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| Litigation Support Introduction ABZ has evaluated management practices at nuclear power plants. ABZ has also provided expert testimony for utilities and other in rate cases and contract litigation. The following provide a brief description of a selection of ABZ’s 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). Mr. Edward C. Abbott also testified as an expert in the proceeding. As a result, PG&E received a substantial award. 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. Maintenance Program Review at Diablo Canyon ABZ performed a detailed review of the maintenance program at Diablo Canyon Power Plant for Pacific Gas and Electric. This included comparing the program elements with the regulations, review of specific work packages and implementation of work in the field. In addition, interviews with work planners, supervisors and management were conducted. Specific recommendations were developed and implemented. Quality Assurance Program at Nine Mile Point Units 1 and 2 ABZ participated in a comprehensive review of the nuclear training program at the Nine Mile Point, Units 1 and 2 sites for the site independent safety committee. The audit performed by the Quality Assurance Department consisted of comparing the standards and regulations with the programs and procedures in place at the time of the audit. Several significant issues were noted during the audit, including problems associated with compliance with Nuclear Regulatory Commission training regulations, coordination of training and day-to-day work, insufficient detail in describing interfaces within the Department and needed technical improvements in several of the Department's lesson plans. In addition, a review of the plant's simulator training of plant operators was performed. The findings of the effort were issued by the Quality Assurance Department to plant management. Organization Evaluation of the Arizona Nuclear Power Project ABZ participated in a comprehensive review and evaluation of the Arizona Nuclear Power Project (ANPP), which is a wholly-owned subsidiary of Arizona Public Service Company (APS). In response to increasing costs and poor performance, the APS Board of Directors and President requested an in-depth analysis of the functions, effectiveness and staffing of ANPP. ABZ reviewed and evaluated the maintenance, operations, quality assurance and engineering as part of a team of consultants hired by APS. Several significant organizational changes were recommended and implemented, including consolidation of responsibilities in each operating unit, establishing a standardization group to assure all units operated in the same manner and an outage/maintenance support group to review the units. The final organization was patterned after the naval reactors program and remains in place today. Rate Case Review of Pre-Operational Testing at Hope Creek ABZ evaluated the pre-operational and start-up test program for the Hope Creek Station. This review concentrated on the overall quality of the test programs in comparison with other facilities and the utility's response to various technical issues. Several significant safety features unique to Hope Creek were evaluated as to need, cost and impact on operations. A detailed review of the solid-state emergency safety features actuation system (ESFAS) was performed to understand the effect of its unique design on plant reliability. The ESFAS review included comparison of the as-built design to applicable regulatory standards and codes. In addition, evaluation of the utility's corrective action on ESFAS failures was performed to determine its adequacy to prevent future problems. Rate Case Review of the Pilgrim Nuclear Power Station ABZ provided Commonwealth Electric Company (CECO), a co-owner of the Pilgrim Nuclear Power Plant (PNPP), with a comprehensive and detailed review of the plant's personnel, organization, regulatory effectiveness and various improvement programs. As part of the review, several "vertical audits" were performed in technical areas, including design modifications, technical procedure adequacy and implementation of the plant's test program. These reviews 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. Safety Evaluation of the Maine Yankee Nuclear Power Plant Two members of ABZ's staff participated as members of the Maine Yankee Nuclear Oversight Committee (MYNOC). MYNOC was chartered to identify problems at the Maine Yankee Nuclear Power Station (MYNPS) and report them to the Board of Directors. The committee met quarterly at the station, interviewed members of the plant staff, toured the station, met with the Maine Yankee Atomic Power Company (MYAPC) President and prepared a detailed report. An overall assessment of the station performance was made and important safety issues identified. The Committee reviews, although brief, were in-depth. The ABZ experts possess the background and experience to know to what depth a particular issue needed following before it would be found satisfactory. In addition, the reviewers had a "sense," based on experience, where potential problems could be found. Finally, the Committee obtained consensus on the issues based on knowledge of the station, its people and the standards imposed on the station. Congressional Study of the US Nuclear Power Program ABZ reviewed the decommissioning funding, spent fuel disposal plans and preparations for nine nuclear power plants as part of an overall study of the nuclear power plants as requested by the United States Congress. ABZ conducted interviews with upper management and technical personnel. Two panel meetings were held to review the findings of the report. The panel members included intervenors, public utility commissioners, industry representatives and university professors. The results of the report were presented to the Nuclear Regulatory Commission Commissioners.
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