ML20212C575
| ML20212C575 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/20/1999 |
| From: | Martin T AFFILIATION NOT ASSIGNED, CENTERIOR ENERGY, PENNSYLVANIA POWER CO. |
| To: | |
| Shared Package | |
| ML20212C556 | List: |
| References | |
| LT, NUDOCS 9909220035 | |
| Download: ML20212C575 (8) | |
Text
.
As, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Duquesne Light Company, and
)
FirstEnergy Nuclear Operating Company,
)
Docket Nos. 50-334-LT & 50-412-LT Pennsylvania Power Company
)
)
(Beaver Valley Power Station,
)
Units 1 and 2)
)
)
AFFIDAVIT OF TIM D. MARTIN ON BEAVER VALLEY STAFFING l.
Introduction and Backaround I, Tim D. Martin, President of Tim D. Martin & Associates, Inc., do hereby affirm and state that:
I 1.
I am experienced in all aspects of the nuclear industry, including operations, utility organization, engineering, and the service industry. I have provided a broad spectrum of services to many electric utilities with nuclear power plants, including AmerenUE, American Electric Power, Arizona Public Service, Baltimore Gas &
Electric, Carolina Power & Light, Cleveland Electric illuminating, Commonwealth Edison, Detroit Edison Company, Duquesne Light Company, Entergy, FirstEnergy Operating Company, Florida Power and Light, Florida Power & Light, Gulf States Utilities, GPU Nuclear, Houston Lighting & Power, Illinois Power Company, Iowa Electric Light & Power, Kansas City Power & Light, Louisiana Power & Light, New Hampshire Yankee, Niagara Mohawk Power Company, Northem States Power, Omaha Public Power District, Pacific Gas & Electric Company, Pennsylvania 990922oo35 990921 1
$DR ADOCK 05000334 PDR e
p Power & Light, Philadelphia Electric Company, Southem Califomia Edison, TVA and Yankee Atomic Electric. In addition, I have provided consulting services to nuclear steam supply system vendors, architect-engineers, legal and other service firms in the nuclearindustry.
2.
I received my BS in Engineering from the United States Naval Academy, and his MBA from George Washington University.-I am a licensed Professional Engineer.
3.
As head of Tim D. Martin & Associates, I direct the firm's engagements, specializing in analysis of staffing, organtational design, costs, and business j
i planning at nuclear power plants. In connection therewith, we have developed an established and unique approach and database for examining the staffing situation of nuclear power plants. Tim Martin & Associates is an acknowledged industry expert on nuclear plant staffing, organizational design and costs, and has provided expert testimony on these and other subjects, has been asked to speak and attend industry meetings that deal with staffing and related issues, and been quoted in trade publications.
4.
In addition to staffing and cost analyses, I have been a resource to Presi-dents and Vice Presidents of nuclear utilities to assist in the identification and solution of complex management and technical issues aimed at improving plant performance. I have investigated a myriad ofissues such as career development, incentive compensation programs, reorganizations, and the creation and implementation of management control systems.
2 i
5.
Prior to establishing Tim D. Martin & Associates in 1986, I was the Nuclear Energy Practice leader at Booz, Allen & Hamilton. At Booz, Allen and I directed many projects dealing with reviews and analyses for nuclear plants under construc-tion and in operation, including prudence reviews and providing testimony in support of the utilities constructing nuclear plants.
6.
Prior to joining Booz, Allen & Hamilton, I was General Manager for NUTECH, a nuclear engineering consulting firm, where i managed the Bethesda and Atlanta offices. I directed the nuclear engineering services, including design and implementation of modifications to major plant systems.
7.
I also served in the nuclear navy, the last tour being as Engineer Officer of a nuclear powered submarine where he was responsible for all aspects of the nuclear plant and ship systems. This position was similar to a plant manager of an oper-ating commercial nuclear plant and provided me with a thorough background and experience base in nuclear operations, maintenance and training requirements of a nuclear power plant.
8.
Our services to the nuclear utility industry have included direction of major engineering modifications, such as the Mark I containment program which required significant structural and piping changes to 25 plants, some in operation and others still under construction.
I also developed and implemented major operational programs, such as emergency preparedness and training of licensed operators. I have worked with utilities in preparation for and during their initial plant op? rations, which utilized his complete knowledge of all aspects of nuclear power, including operations and maintenance.
3
I.
II.
Purnose of the Staffina Update -
9.
FENOC has in the past retained Tim D. Martin & Associates, Inc. to conduct staffing analyses, outage studies, organization reviews and other management consulting engagements.
10.
Tim D. Martin & Associates has conducted over 130 staffing analyses at nuclear plants in the past 12 years, and I am familiar with Beaver Valley and the Perry Nuclear Power Plant and Davis-Besse Nuclear Power Station both of which are operated by FENOC. Our staffing database includes detailed staffing information from virtually every U.S. utility that operates a nuclear plant and several foreign utilities.
11.
In December 1998, Tim D. Martin & Associates was asked by FENOC to conduct a Nuclear Staffing Analysis Update of the Staffing Benchmarking Analysis that was completed on February 27,1998 for the Beaver Valley Power Station at the request of the current operator, Duquesne Light. Staffing is a significant part of non-fuel operations and maintenance costs and should be included in examinations of nuclear plant performance. FE was examining the staffing situation at Beaver Valley as part of a total plant review in association with the larger Asset Exchange transaction between FirstEnergy and Duquesne Light.
4 4
p.
111.
Anoroach and Methodoloav -
12.
Our approach to the staffing analysis was similar to that used in the other 130 staffing analyses conducted by Tim Martin & Associates. This approach consisted of four basic steps:
- 1. Assigning the Beaver Valley personnel to one of 45 work functions that are performed by staff at all nuclear plants,
- 2. Developing benchmark staffing values that are customized to the Beaver-Valley plant,
- 3. Comparing the actual numbers to the benchmark staffing values, and
- 4. Identifying specific functions for management attention by comparing the Beaver Valley overall situation to other nuclear plants.
13.
Assigning each Beaver Valley person and contractor to one of the 45 functions in our database allowed direct comparison of the Beaver Valley staffing to the benchmark staffing. To assign Beaver Valley personnel to these functions required examination of the latest organization charts and interviews with selected personnel at the plant.
Since a similar staffing analysis had been completed earlier in 1998, the update required identifying the changes in both Duquesne Light and contractor personnel.
14.
Benchmark staffing levels were then developed for each function using the methodology employed in past staffing analyses. Using regression analysis, a model was developed for each of the 45 functions required to operate and maintain a nuclear plant. Each regressiori model identified the independent 5
Vz
/
variables that explain the variation in the functional staffing among the best performing nuclear plants in the database. These independent variables include 1
factors such as age of the plant, capacity in MW, NSSS vendor, union status of each function, and other factors that can be measured at each plant.
15.
The model provides a quantitative method to normalize the design and 4
operating parameters of the best performing nuclear plants to those of Beaver Valley. Best performer plants are those US nuclear plants that have a 3-year record of being in the best half of capacity factor, non-fuel O&M costs and SALP scores. By substituting Beaver Valley values into the regression models, the average staffing in each function at best performing plants, normalized to Beaver Valley, was developed.
16.
In addition to the Best Performer benchmark, a Lowest Staffing benchmark was developed. This benchmark represents the staffing at the lowest i
staffed best performing plant normalized to the characteristics of Beaver Valley.
A separate Lowest Staffed benchmark was developed for each of the 45 functions being performed at Beaver Valley. This process produced benchmark staffing levels for a virtual plant because no plant has all the lowest values.
17.
To conduct the staffing analysis update in December 1998, Tim D. Martin
& Associates interviewed the officers at Beaver Valley and individuals in the Human Resources organization. We also reviewed relevant documents including the following documents:
Beaver Valley Staffing Analysis dated-February,1998 conducted by Tim D. Martin & Associates 6
e
[.
l Beaver Valley organization charts dated October 28,1998 Contractor listing dated October 31,1998.
18.
This information was used to assign Beaver Valley personnel, including contractors, to one of 45 functional categories required to operate and maintain a nuclear plant.
Once the total count was complete, the' Beaver Valley staff l
assigned to the 45 functions, and the benchmarks developed, the actual functional count was compared to the benchmark values.
i IV.
Results of the Staffina Undate and Cone!"-bn -
19.
Results of the Beaver Valley Nuclear Plant Staffing Analysis Update in December 1998 were:
Total staffing was 1,420 personnel, which included 1,222 Duquesne Light employees and 198 long-term contractors.
Benchmark Best Performer Staffing was 1,304, and benchmark Lowest Staffing was 980.
Beaver Valley actual staffing was 9% above the best performer benchmark and 45% above the lowest benchmark.
20.
These results indicate that Beaver Valley staffing reductions can be made by FENOC as it works toward improving Beaver Valley's overall performance.
I i
r
- l d,p\\ L L9 7
[h3 l
l State of U po M v h
. County of Liv e u.
Subscribed and sworn before me a Notary Public this, day ofS tlin.,a 2.
1999.
My ommission expires (0 s'N(4 nn'IT1.r/bufInnl I
i Notary J
ANN M. HURLBU C Notary PuWee. Staic of New in4 Monroe Cnunty No. 506798 Vly Commi non Empires 10/2 i
Notary Public in and for the state of OLtd %r k l
4 p
l e