Four Points Group staff has evaluated management practices at nuclear power plants. Four Points Group staff has also provided expert testimony for Federal, State and private industry clients in lawsuits, administrative hearings, and arbitrations.
Four Points Group 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
Four Points Group 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 Four Points Group staff’s work:
Pacific Gas and Electric versus Sacramento Utility District
Four Points Group staff 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, Four Points Group staff 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.
Engineering Analysis Of the Salem Unit 1 Failure to Restart Following the Athos I Oil Spill
Four Points Group staff 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. Four Points Group staff evaluated the claim and its supporting documentation to understand the technical aspects of the claim. Four Points Group staff 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, Four Points Group staff evaluated and verified the causal relationship between the technical issues in the claim and the effects of the oil spill.
Diablo Canyon Rate Case
Four Points Group staff 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. Four Points Group staff 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, Four Points Group staff 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, Four Points Group staff reviewed the effectiveness of the nuclear organization in responding to these issues to the satisfaction of the regulator and the public.