ML20245H835
| ML20245H835 | |
| Person / Time | |
|---|---|
| Issue date: | 02/28/1989 |
| From: | Chiramal M, Israel S, Wegner M NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | |
| Shared Package | |
| ML20011C584 | List: |
| References | |
| TASK-AE, TASK-S901 AEOD-S901, NUDOCS 8903060030 | |
| Download: ML20245H835 (36) | |
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.SPECIAL STUDY REPORT..
MAINTENANCE;PROBLENS AT NUCLEAR' POWER PLANTS' c;;
February 1989
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Prepared by:
Mary Wegner Matthew Chiranal y;
Sandy Israel A
Stephen Stern t
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SUMMARY
A measure of operating nuclear plant maintenance deficiencies was obtained by reviewing operational experience reported to the NRC over the last 4 years. The review focused on existing studies and reports by the Office for Analysis and Evaluation of Operational Data, generic communication documents issued by the NRC, feedback documents issued :by the Institute for Nuclear Power Operations (INP0), and licensee event reports issued by the licensees of operating domestic nuclear plants. These documents were reviewed to identify maintenance-related problems and deficiencies, the number of plants involved, the systems and components affected, the human and organizational errors associated with maintenance. The review attempted to ascertain if there has been a discernible trend in the area of maintenance. The study also addressed estimates of the magnitude and trends in the cost of identified maintenance deficiencies to the commercial nuclear industry.
Of the 70 AE0D case studies, special studies, and engineering evaluations issued since 1985, the review identified 15 that specifically addressed maintenance-related problems. We concluded that the maintenance-related problems found in systems such as the service water system, the instrument air system, and other cafety-and non-safety-related systems, and in components like motor-operated valves, inverters, circuit breakers, and pumps, are widespread in the industry.
Problems reflect deficiencies in quality control, procedures, planning, communication, and training.
Since 1985 the NRC has issued 80 bulletins and information notices specifically addressing maintenance deficiencies. The review of these documents provided very similar conclusions to those obtained by the review of the study reports - i.e., problems addressed in these generic communications identified maintenance procedure deficiencies, inadequate post-maintenance testing, maintenance problems of motor-operated valves, emergency diesel generators, pumps, valves, relays, etc. Similar findings were identified in the review of generic feedback documents issued by INP0.
The review of licensee event reports used in the NRC Performance Indicator Program for the last twelve months, found that over 50 percent of the maintenance deficiencies appear to occur in eight safety systems, viz., BWR j
high pressure coolant injection, BWR and PWR primary containment, BWR reactor core isolation cooling, BWR MSIVs, BWR emergency / standby gas treatment, BWR and l
PWR cor. trol building environmental control, PWR emergency onsite power supply, I
and PWR essential service water systems. Trending these events showed a drop-off after the third quarter of 1987.
Trending of data from operating reactors in the Nuclear Documents System and the Sequence Coding and Search System was another approach used in the study.
l This effort did not identify any significant change in the trend of maintenance relateo activities in the industry in the 4-year period beginning with 1985.
Cause code data from the SCSS was also extracted and trended for 12-month j
periods beginning July 1985 to June 1988. The fraction of LERs' attributable 1
to maintenance deficiencies has not changed over this three year period.
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A bounded estimate for the cost of maintenance deficiencies associate with i'
replacement power costs for forced outages was developed from the SINET data base. The upper bound of this estimate shows steadily increasing replacement
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2-power costs-from 1984 to 1987, reaching an annual level of 960 million dollars in 1987. The upper bound for 1988 is currently projected at 720 million dollars per year which is a decrease from 1987. The lower-bound estimates are 120 million dollars in 1987 and a projected 80 million dollars in 1988.
For comparison purposes, the draft Regulatory Analysis for the proposed maintenance rule estimates the cost savings associated with reduced downtime due to.
improvements in maintenance, range from 159 to 239 million do11ers. per year.
This report can provide additional insights for ongoing maintenance team inspections, as well as provide some basis to consider modifications to the inspection modules. Additionally, the results can provide useful data to further an understanding of-the cuality of maintenance at operating plants.
The information in this report can provide insights to assist in preparing a Regulatory Guide. Lastly,.the information regarding financial matters can provide additional information for a realistic assessment of current maintenance costs.
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INTRODUCTION This study was initiated to determine the extent and pervasiveness of maintenance problems in operating nuclear power plants. The study is based on operational' experience reported to the NRC. ' Maintenance is defined as the aggregate of those actions required to preserve and promptly restore operability, reliability, and availability of, or to prevent the failure of plant structures, systems, and components.
The study.is limited to the' review of existing completed AE0D studies, NRC generic communication documents, licensee event reports and licensee responses to NRC inspections that relate to operational experience from 1985 to the present. Automatic scram data for the last four quarters is also included in the review. The review of these documents focuses on maintenance related problems and deficiencies.
The review identifies plant designs that have been affected by maintenance related problems-and deficiencies, the systems involved, and the enmponents that predominate. The study also focuses on the human errors involved in these problems, the extent of such errors, and the adequecy of the maintenance supervision, procedures, and training.
Finally, the review attempts.to identify any trends in the area of maintenance in the recent years.
AEOD studies based on operating experience are discussed in Section 2.1.
Maintenance related NRC bulletins and information notices are reviewed l
in Section 2.2, and similar INP0 documents in Section 2.3. Broad trends' based
-on available data bases are discussed in Section 2.4 and a more detailed data analysis in Section 2.5.
Section 2.6 discusses the economic assessment of I
maintenance deficiencies.
2.
OPERATIONAL EXPERIENCE REVIEW I
2.1. Review of AEOD Reports of Case Studies, Special Studies. and Engineering Evaluations Issued since 1985 AEOD has issued 70 reports since 1985 which discuss important safety concerns brought to light by reactor operating experience.
Licensee event reports and other related documents are screened to identify significant issues which l
warrant further analysis by the staff to deternine the salient factors involved in the issue including the underlying causes and the extent of industry exposure. Once a suitable topic has been identified, all reports of similar experience are amassed to provide a knowledge base for the AE0D study.
Reports issued by AEOD since 1985 were screened to identify those issues where i
the quality of maintenance was directly related to the issue. The reports selected for review are:
1.
C801 - Service Water System Failures and Degradations in Light Water Reactors.
2.
5801 - Significant Events Involving Procedures.
i 3.
NUREG-1275, Vol. 2 - Operating Experience Feedback Report - Air Systems Problems.
4.
E702 - MOV Failure due to Hydraulic Lockup from Excessive Grease in Spring Pack.
5.
C603 - A Review of Motor-0perated Valve Performance.
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_4 6.- 5503 - Evaluation of Recent Valve Operator Motor Burnout Events.
7.
C502 - Overpressurization of Emergency Core Cooling Systems in BWRs.
8.
C504 - Loss of Safety System Function Events.
9.
P701 - Trends and Patterns Program Report - Operational Experience Feedback on Main Feedwater Flow Control and Main Feedwater Flow Bypass Valves and Valve Operators.
- 10. E802 - Single Failure and Other Deficiencies Noted in Control Room Emergency Ventilation Systems.
- 11. E804 - Reliability of Recirculation Pump Trip Breaker During an ATWS.
- 12. E708 - Depressurization of Reactor Coolant Systems in PWRs.
- 13. C605 - Operational Experience Involving Losses of Electrical Inverters.
- 14. E504 - Loss or Actuation of Various Safety-Related Equipment Due to Removal of Fuses or Opening of Circuit Breakers.
- 15. E512 - Failure of Safety-Related Pumps Due to Debris.
The details of the review are discussed as follows:
" Service Water System Failures and Degradations in Light Water Reactors" (AE0D/C801) is a case study that compiled almost 1000 reactor events related to the subject from 1980 to 1987. About 25 percent of the events were judged to have generic safety significance. Systems and components adversely affected by a service water system failure or degradation include the component cooling water system, emergency diesel generators, emergency core cooling system pumps and heat exchangers, the residual heat removal system, containment spray and fan coolers, control room chillers, and reactor building cooling units. Risk estimates indicate that the safety significance of service water system failures and degradations is relatively high.
System fouling caused a majority (58%) of the 276 events that had potential generic significance. This degradation, which is a chronic maintenance problem, includes sediment deposition, biofouling, corrosion / erosion, pipe coating failure / carbonate deposition, and foreign material / debris intrusion.
Although some modifications were made at some plants to correct some of the problems in this area, the major long term solution appears to be effective surveillance and preventive maintenance practices. Personnel and procedural errors related to maintenance activities accounted for another 13 percent of the rajor events. These events include leaving the system misaligned after maintenance, improperly installing components, and inadequate coordination with operational requirements. These situations reflect problems with quality control, procedures, and communications.
The events caused by maintenance related deficiencies cited in the report occurred at about half of the plant sites. Thus, these problems are wide spread. Since the service water system is the primary conduit to the plant heat sink, degradation of the capacity of the heat exchangers in the various safety systems supported by service water is important. None of the plant Technical Specifications reviewed, however, requires licensees to perform any type of heat exchanger testing.
It is important to note that several affected plants have instituted significant surveillance programs to monitor service water degradation in selected components. At one plant the tests are performed weekly while at another they are performed monthly. These frequencies are higher than some of tM required tests on safety systems and attest to the i
l severity of the probitm.
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, " Operating Experience Feedback Report - Air Systems Preblems" (NUREG-1275 v.2) compiled about 160 events involving failure of safety related equipment caused by degraded or malfunctioning non-safety grade air systems. Approximately 40 percent of these events are t 1. icerned with deficiencies in the maintenance of air actuated components or the air system itself. The safety systens affected by tre air-system events include the reactor trip system, auxiliary feedwater, residual heat removal, emergency ccre cooling system, containment. isolation, main steam isolation valves, control room ventilation, waste gas treatment, and emergency electric power. Because of the potential for common cause failures, these problems represent a significant safety concern.
A principle maintenance deficiency pointed out by this study is the lack of effective monitoring and maintenance of the air system which resulted in water and other contaminants building up in the system and failing air actuated components.
In this regard, the air solenoid valves appear to be particularly l
susceptible to contamir. ants because of small clearances. The study finds that maintenance personnel frequently did not understand the potential consequences of degraded air systems. They are often unaware of the potential for comon cause failure of redundant safety related equipment that rely upon air systems.
Significant events which occurred at 26 plant sites are documented in the study and cover older plants as well as recently licensed plants.
Current motor operated valve (MOV) problems were reported in a number of studies that find maintenance a principle contributor to equipment degradation I
and failure. Most recently, motor operated valves received considerable attention because of chronic and pervasive problems. The following reports were issued on this topic:
MOV Failure Due to Hydraulic Lockup from Excessive Grease in Spring pack (AEOD/E702)
A Review of Motor-operated Valve Performance (AE0D/C603) l Evaluation of Recent Valve Operator Motor Burnout Events (AE0D/S503) j
'Since motor operated velves exist in most fluid systems in the plant, the problems are widespread.
Five hundred and sixty five LERs involved problems I
with NOVs in the time period 1981 through mid-1985.
The NPRDS data base, i
which is managed by the Institute of Nuclear Power Operations, yielded just over 1100 entries in the same time period. The data have not been analyzed to determine which events were strictly maintenance related; however, the evidence suggests that between 50 and 80 percent of the events fall into this category. Because flawed maintenance practices involving MOVs pervade all systems, the potential for common cause failure of redundant safety 1
equipment is sign 1ficant.
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Improper torque / limit switch settings is a major contributor to degraded valve l
operation.
It is hypothesized that torque switch " corrective action" replaced I
definitive identification of the underlying valve inoperability problem. Thus l
the flexibility to make adjustments rather than perform a root cause analysis may have bred bad maintenance habits. One of the studies addresseo the use of a new environmentally qualified grease which had a lower viscosity. The lower viscosity grease could migrate more easily to an area where a spring must compress to provide thrust to operate the fiOV. Due to inadequate grease relief l
in the spring area, the spring could not compress. Thus, inadequate design 1
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evaluation resulted in addressing one problem (equipr.ent qualification) while creating another problem (spring pack or hydraulic lockup). MOV events have, occurred at virtually every plant site.
"0verpressurization of Emergency Core Cooling Systems in Boiling Water Reactors" (AE0D/C502) is a case study of potential intersystem loss-of-c.oolant-accidents caused by loss of the pressure boundary configuration at the interface.
Eight events are cited which involve a stuck open isolation check valve at the pressure boundary. Five of the these events were caused by maintenance errors. The safety significance of this issue is the potential for an unisolable LOCA outside containment. The maintenance errors include equipment misalignment and inadequate preventive maintenance. The report cites occurrences at four of the 26 BWR sites.
" Loss of Safety System Function Events" (AE0D/C504) is a case study that compiled 87 events of loss of safety system function involving human factors in the time period 1981 to 1984 Approximately 28 percent of these events occurred durir.g maintenance activities. Most of the events cited involved the residual heat removal system or the ECCS. The types of human errors that occurred during maintenance include failure to follow procedures, inadequate plar.ning, defective procedures, and failure to perform work correctly. These evants occurred at 20 different plant sites.
In a related study, "Significant Events Involving Procedures" (AE0D/5801), the review indicates that procedure errors account for about ten per cent of the significant events.
" Trends and Patterns Program Report - Operational Experience Feedback on Main Feedwater Flow Control and Main Feedwater Flow Bypass Valves and Valve Operators" (AE0D/P701) provides an engineering analysis of reported failures in these components. The report finds that the main source of variation in failure rate is due to the differences in maintenance practices among units and statiors. The evaluation shows that proper maintenance and the use of appropriate subcomponents are dominant positive actions to avoid problems in the main feedwater system. Valve operator failures were caused by poorly naintained air systems.which allowed water, oil, and foreign particles to enter the system. These types of problems are discussed above in the air system report.
Poor maintenance procedures in some plants caused repeated failures.
Detailed procedures, use of routine maintenance schedules, and assistance of manufacturer's representatives were used to correct the problems of these valves.
" Single Failures and Other Deficiencies Noted in Control Room Emergency Ventilation Systems" (AE0D/E802) is a review of nine events involving an inadequate emergency ventilatico system.
Four of the events were caused by maintenance errors - misaligned systems or reversed leads. A failed emergency ventilation system could imperil the operating staff and impair the response to certain accidents such as a toxic gas release. The events occurred at four different plant sites.
" Reliability of Recirculation Pump Trip Breaker during an ATWS" (AE0D/E804) compiled 22 breaker failures for the time frame 1979 to 1987. According to the manufacturer, most of the failures to trip on demand were caused by circuit breaker misadjustment or lubrication problems. The frecuency of reports appears to have decreased subsequent to the manufacturer issuing a service information letter to the utilities. This problem was reported at 8 of the 26 BWR plant sites.
.. "Depressurization of Reactor Coolant Systems in PWRs" (AE0D/E708) examined the impact of selected systems that were out of service during a loss of power event at Salem in 1986. Several components that could control system pressure were out of service for extended periods of time prior to the Salem event because corrective maintenance was deferred until the next refueling (expected to be several weeks hence).
In addition, several other pieces of non-safety grade equipment, that were also inoperative because of deferred maintenance, could have distracted an operator, responding to a more challenging event, because of missing process information or faulty equipment that would require additional operator attention. Much of the equipment were not in the limiting conditions for operation in the plant Technical Specifications and thus were permitted to be disabled for an extended time.
Similar deferred maintenance activities were noted at other plants.
" Operational Experience Involving Losses of Electrical Inverters" (AE0D/C605) examines 142 events for 1982 to 1984.
Personnel actions were responsible for 35 percent of these losses. These types of losses have significant safety impact because they represent the degradation of the vital instrument power supply and potentially the common cause loss of the entire system. The types of personnel activity that have affected the inverters include opening incorrect circuit breakers, connecting faulty test equipment to the inverter, causing short circuits during maintenance or testing, and removing the wrong unit from service. The observed problems suggest that improvements are needed in planning, procedures, verification methods, and training practices regarding testing and maintenance activities. These events occurred at 25 plant sites.
" Loss or Actuation of Various Safety Related Equipment Due to Removal of Fuses or Opening of Circuit Breakers" (AE0D/E504) discusses six events which occurred in 1981 to 1984. All of these events are related to system misalignment which occurred during testing or maintenance activities. The report asserts that the number of events are understated because of the limited reporting requirements.
This type of personnel error leaves the equipment in a failed state that will not be caught until the component is challenged or effective post maintenance verification is performed.
" Failure of Safety-Related Pumps due to Debris" (AE0D/E512) is a report on potential common cause failures from sloppy maintenance activities. The study cites five events where debris caused component failure and three other events that flagged poor housekeeping inside of containment following maintenance activities.
Roughly 20 per cent of the reports issued by AE0D in this time period generally identified issues where maintenance is a significant causative factor. These studies show that maintenance problems and deficiencies occur at a large number of plants and affect a large number of plant systems. More importantly, these studies, which are generally caused by maintenance errors, are judged to have generic safety significance.
The maintenance problems vary among the studies reviewed. They include inadeauate preventive maintenance as illustrated by the chronic problems with the service water system and the air systems, improper maintenance as shown by the problems with the motor operated valves and the electrical inverters, and system misalignment after maintenance as discussed in the reports on pressure bourdary configurations in BWRs and control ventilation systems.
i
4 2.2. Review of NRC Bulletins and Information Notices Issued Since 1985 Review and analysis of NRC generic communication documents, such as bulletins and information notices, is another approach to identifying the maintenance-related problems that are being experienced in operating nuclear plants. These documents alert the industry of problems and the need for corrective actions on specific items that are identified by operational experience at one or more nuclear plants. All NRC bulletins and information notices issued since 1985
-were screened to select those involving a maintenance related issue. During this period a total of 23 bulletins and 369 information notices were issued -
in 1985 four bulletins and 101 information notices, in 1986 four bulletins and 123 information notices, in 1987 two bulletins and 69 information notices, and by November 1988 12 bulletins and 86 information notices.
The screening effort identified 27 maintenance related bulletins and information notices in 1985, 36 in 1986, 12 in 1987, and 10 in 1988. These documents were reviewed for the maintenance related problems involved, the system or component affected and the plants involved.
The details of this review are shown in Table 1.
HRC information notices and bulletins generally discuss industry-wide problems which are of sufficient safety significance and concern to merit both NRC and industry attention. They are issued to all operating nuclear plants for information and action, as appropriate.
Hence, the maintenance problems that are adoressed by the documents in Table 1, are problems that apply to nearly all operating nuclear plants.
Of the approximately 80 documents listed in Table 1, 10 dealt with maintenance related problems of motor-operated valves, 10 involved maintenance procedure deficiencies, 5 addressed ir. adequate post-maintenance problems, 5 each related to maintenance related problems of the control rod drive systems and the emergency diesel generator system of PWRs and BWRs, 4 each involved inadequate inservice testing, maintenance problems of safety valves, and human errors during maintenance activities, and 3 each addressed maintenance related problems of steam generators and containment systems. The remainder of the notices dealt with maintenance problems of various systems and components, such as auxiliary feedwater pumps, plant air systems, instrument transmitters, relays, de batteries, circuit breders, relief valves, solenoid valves, pump seals, and service water systems. The maintenance related problems of components and equipment such as motor-operated valves, control rod drives, emergency diesel generators, safety valves, pumps, circuit breakers, etc.,
can be jointly considered as deficiencies in the plant preventive maintenance and housekeeping programs, 2.3. Review of Industry Reports The INP0 reports, like the NRC bulletins and information notices, are nuclear plant operational experience feedback documents that address industry-wide problems that are deemed sufficiently significant by INP0 and the industry to merit attention. Although the maintenance related problems addressed by these documents occurred at specific plant sites, the problems are potentially generic to all operating nuclear plants.
All INP0 significant operating experience reports (S0ERs), significant event reports (SERs), and operation and maintenance reports (0&MRs) issued in 1987 and 1988 were screened to identify those related to a maintenance problem. The 3 SOERs, 24 SERs, and 18 0&MRs thus identified were reviewed for the type of
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.g-problem in.volved, the system or component affected, and the plants where the event occurred. The details of this review are shown in Table 2.
i Of the 45 reports in Table 2, 14 involved inadequate planning and procedures, 12 pertained to preventive maintenance deficiencies, 10 concerned human errors connitted, and 5 involved inadequate testing of equipment and systems. The remaining reports dealt with various equipment and component problems.
2.4. Database Survey Analysis of databases that capture various reports on nuclear power plant experience is another approach to estimating the trend of. maintenance related activities in the industry. Document searches related to maintenance activities were performed with the Nuclear Documents System (NUDOCS) and the
. Sequence Coding and Search System (SCSS). The results of these searches do not show that the number of documents on maintenance related subjects is changing significantly over the four years examined.
SCSS is a detailed data' base of encoded LERs which includes information about systems and components demanded during the event and the transient aspects of the event. NUDOCS uses all documents generated by the regulatory process whether initiated by the staff, the licensee, or a third party.
Keywords for these documents are generally based on the title of the report or a separate keyword list if available. The NUDOCS data base is being enlarged to permit abstract or text searches for selected documents.
The basic keyword used to search NUDOCS was "maint" appearing in titles of letters sent from the utilities to the NRC. The search was refined to eliminate those documents related to security, SALP, and bulletins. The resulting documents included LERs, responses to inspection reports, and responses to ad hoc staff inquiries on maintenance activities. The resultant database is called NUDOCS 1 in Figure 1.
The number of documents for 1988 is an estimate based on doubling the the number for the first six months of the year. As can be seen, there is only a small perturbation over the 1986 to 1988 time frame. NUDOCS 2 shown in Figure 1 is a subset of NUDOCS 1 that includes only responses to maintenance related violations noted in inspection reports.
Here again changes over the years ao not appear significant.
The maintenance related documents identified in the SCSS database were captured by the codes "AB", "AU", and "AW."
"AB" refers to a component or part that is present, but is not in its proper location due to improper adjustn:ent er positioning. This does not include valve out of position or miscalibrated instrument.
It does include valve installed backwards.
"AU" refers to an improper previous repair while, "AW" describes a previous repair that was done correctly but was ineffective at preventing recurrence of the component failure.
The resulting database, shown as SCSS in Figure 1, appears to show a decrease in the number of documents in 1988 (estimated from six inonths data).
The databases are imperfect because they capture some documents that do not reflect actual maintenance work while at the same time, net all activities may be captured. These deficiencies are ameliorated somewhat by the fact that the reporting practices may not vary significantly from year to year so that a trend in maintenance activity may be observed. Considering the uncertainty involved, there does not appear to be any definitive trend indicated by the charts in Figure 1.
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-(ORNL), to compile cause andl corrective action data from LERs distributed among seven broao cause codes for three 12-month periods beginning July 1985.
The seven cause codes are:
(1) administrative. control (AC), (2) random equip-mentfailures(REF),(3) design, fabrication, construction,andinstallation
-(DFCI), (4) licensed operator error (L0E), (5) other personnel errors'(OPE),
.(6) maintenance 1-error (MI),and(7) maintenance 2 error'(M2). Maintenance 1 error code reflects deficiencies in a maintenance program that are clearly attributable to poor maintenance practices or errors made by maintenance personnel, and Maintenance 2 error cause code includes those events where a deficiency in implementing the maintenance program was not obvious, but where assignment as a maintenance cause code would be plausible. The distribution of the cause code counts as pie charts giving the percentages of each cause code for the period July 1, 1985 to June 30, 1986 is shown in Figure 1A; for the period July 1, 1986 to June 30, 1987 is shown in Figure 18, and for the period July 1,1987 to June 30, 1988 is shown in Figure 10. The charts indicate that the distribution of maintenance error causes, M1 and MP, remains relatively unchanged over the three periods.
2.5. Review of Events Identified as Maintenance-Related Safety System Failures Th.e NRC Performance Indicator (PI) program classifies and tracks those LERs at operating plants which are automatic scrams, safety system failures, safety system actuations and significant events. These PI events represent those LERs which are of a higher safety significance to the NRC than other LERs. By trending those LERs which are both tracked by the PI program and can be attributable to maintenance deficiencies, one should have an estimate of the trend in significant maintenance related events.
In addition, safety system failures which can be attributed to maintenance will be evaluated to identify safety systems which are particularly vulnerable to maintenance problems.
For BWRs, 61 percent of maintenance related safety system failures were clustered in six safety systems. For PWRs, 44 percent of these failures were clustered in only four safety systems. The trend in the number of such events which are attributable to maintenance demonstrated a considerable drop after the third quarter of 1987 and then remained fairly constant through the fourth quarter of 1987 and first quarter of 1988.
The approach used'to identify safety system failures involved with maintenance deficiencies was to screen all LERs issued by operating plant licensees during the third quarter of 1987 through the first quarter of 1988 to identify those due to deficient maintenance. The screening was performed by the Oak Ridge National Laboratory (ORNL) using the Sequence Coding and Search System (SCSS) to identify those events which involved:
- Personnel errors associated with the performance of surveillance, testing, calibration, or radiation protectico activities; or
- Equipment failures involving factors that are strongly indicative of j
maintenance problems such as corrosion, improper lubrication, boric acid precipitation, improper prior repairs, etc.
l To identify those safety systems problems with maintenance deficiencies, the 1
l LERs identified by ORNL as maintenance related were then compared with LERs identifieo as Safety System Failures by the Performance Indicator Program.
One hundred and fifty six LERs were identified as being Safety System Failures involving maintenance deficiencies with 73 events at BWRs and 83 events at PWRs.
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s For. the BWRs,/45fof the 73 (61.6%) maintenance-related Safety-System Failures events in this period involved six safety. systems:
1 High: Pressure: Coolant Injection
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this period involved four. safety systems:
Contro1LBuilding/ Control-Ccmplex Enviro. Control -'14 events (16.9%)
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Reactor Containment' Building - 5 events (6.0%)-
qm A trend for LERs attributable to maintenance deficiencies was developed by comparing.the LERs classified by ORNL as maintenance deficiencies with events failures-(SSFs), significant events (SEs) ystem actuations -(SSAs), safety system classified.by the PI program as: safety s and automatic scrams (Scrams). Three
' hundred and fifty three (353) LERs in between third ' quarter 1987 and first quarter 1988 were identified as being both maintenance deficiencies and PI events (SSAs, SSFs, SEs, or Scrams). When examined on a quarterly basis, A
these events show a considerable drop off from the total-of 160 events in e
third quarter of 1987 to 91 events in the fourth quarter of 1987 and 102 events
.in the first quarter of 1988.
Figure 2 presents the quarterly breakout of these events by PI cate90ry..The decrease in these events after the third quarter of 1987 is.due to the sharp drop in scrams and safety system failures, while significant events remained constant'and safety system actuations dropped at a slower rate during this period.
2.6. Economic Assessment of the Cost of Maintenance Deficiencies This section presents rough estimates of the magnitude and trends in the cost of maintenance deficiencies to the commercial nuclear power industry. These estimates represent an attempt to bracket maintenance costs and their refinement will be the subject of further study as the factors. influencing
. maintenance costs are beyond the scope of this paper.. The results of these L
estimates are then compared with estimates in two other recent papers on the subject and the differences among the estimates delineated.
Two approaches were used to develop estimates of the cost and trends of maintenance' deficiencies. One approach is based on the cost of replacement power during forced outages. Since the agency data bases on the root causes of forced outages are not precise, a range in cost estimates is presented as a range of cost estimates for maintenance deficiencies. The upper end of this estiniate is that the forced outages due to maintenance for all commercial nuclear plants have been between 50,000 and 60,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per annum in the years 1981 through 1987. In 1987 this upper-bound estimate for these maintenance related forced outage was 54,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, but dropped significantly to a
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i projected 39,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for 1988. The replacement power costs for these upper-bound estimates are 960 millien dollars in 1987 and a projected 720 million dollars in 1988. The lower-bound estimates are considerably smaller being 120 millicn dollars in 1987 and a projected 80 million dollars in 1988.
Another approach examined forced outages associated with maintenance related trips. These outages were estimated to be running at the rate of 115 million dollars per year between mid-1987 and mid-1988. The trend in replacement power costs for PWRs was flat in this time period while the similar costs for BWRs fluctuated widely.
i For comparison purposes, the draft Regulatory Analysis for the proposed j
maintenance rule estimates the cost savings associated with reduced downtime due to improvements in maintenance range from 159 to 239 million dollars per year.
2.6.1 The Trend in the Economic Costs of Maintenance Related Trips 4
The cost of replacement power for forced outages associated with automatic scrams which can be attributable to maintenance deficiencies were estimated from'the automatic scrams traded by the Performance Indicator program, the licensee event reports contained in SCSS, and outage time from the SINET data base. While it is recognized that forced outages associated with automatic scrams due to maintenance would only be a portion of the consequences of maintenance deficiencies, the agency data on scrams is well complete and can be used to establish trends.
Forced outage times associated with automatic scrams which are attributable to the Nuclear Operations Analysis maintenance deficiencies were estimated by(ORNL) using SCSS to classify those Center.of Oak Ridge National Laboratories automatic scrams attributable to maintenance deficiencies.* Forced outage times were then associated with individual maintenance-related scrams using the SINET data base.
Finally, the outage times were converted to replacement power costs on a reactor by reactor basis using seasonal replacement power costs provided in NUREG/CR-4012.**
Using the methodology described above, the total cost of maintenance-related 4
scran forced outages *** was estimated to be $85.1 million dollars for the 9-month period beginning With-the third quarter of 1987, which represents 5146.8 forced outage hours.****
(The average replacement power cost for these erreactor.) Of this $85.1 million replacement events is $404,000 per day p(52.4% of the total) is attributed to BWRs and $41.5 power costs, $44.6 million
' million (47.6%) to PWRs. Figure 3 presents the cost of these maintenance forced outages for PURs and BWRs on a quarter by quarter basis for this time period. The cost of these maintenance forced outages was comparatively
- Transmittal letter, G. T. May (ORNL) to S. Stern (AE00), LERs on Maintenance-Related Problems, Nov. 7, 1988.
- NUREG/CR-4012, Replacement Energy Costs for Nuclear Electricity Generating Units in the United States:
1987-1981, Argonne National Laboratories /NRC.
- The costs of these forced outages was taken to be the replacement power cost, only. NUREG/CR-4627 estimates restart costs from cold shutdown as less than $20,000 which is much less than the typical replacement power cost.
- The PI data for the second quarter of 1988 was incomplete at the time this analysis was performed.
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. constant for PWRs, varying from $12.4 to $14.8 million per quarter. On the l
other hand, the maintenance outage cost for BWRs varied from $18.11 million in the third quarter of 1987 down to $6.8 million for the fourth quarter and up to $19.7 million for the first ouerter of 1988. Thus, on the basis of these quarterly replacement cost estimates for maintenance outages, one cannot identify a trend for BWRs and the trend for PWRs is level.
)
l 2.6.2 The Economic Costs of Maintenance Related Forced Outages l
The annual cost of replacement power for forced outages associated with maintenance deficiencies were estimated from forced outage times for operating plants stored in the SIN!:T data base for 1981 through 1988.* SINET classifies forced outages as being cue to " maintenance and test," and " equipment failure,"
as well as six other categories. All forced outages associated with the maintenance and test category are clearly attributable to maintenance. A brief audit of forced outage events associated with the equipment failure category indicates the majority of these events are also associated with maintenance deficiencies. Therefore, for the purposes of this economic estimate, the forced outages associated with the SINET maintenance and test category will be taken as the lower-bound of the cost of maintenance deficiencies. The forced outages associated with both the SINET " equipment failures" and " maintenance and test" categories will be taken as the upper-bound of the cost of maintenance deficiencies.
Figure 4 shows the bounded estimate for the forced outages associated with maintenance deficiencies from 1981 to 1988, excluding those plants in long term shutdown. The upper-bound estimate concludes that maintenance related forced outages varied between 50,000 and 60,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per year between 1981 and 1987.
However, the upper-bound estimate shows a considerable drop in 1988, going from 54,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> in 1987 to a projected 39,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> in 1988.**
Using the
$443,000 per day replacement power cost utilitzed in the draft Regulatory Analysis for the proposed Maintenance Rule, the upper-bound estimates for the impact of maintenance translate into 960 million dollars in 1987 and a projected 720 million dollars in 1988. The lower-bound of maintenance related forced outages shows an irregular drop from 11,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> in 1981 to a projected 4,400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> in 1988. The replacement power costs associated with these lower bound estimates are 120 million dollars in 1987 and a projected 80 million dollars in 1988.
For reference purposes, Figure 5 shows these same bounded estimates for maintenance related forced outages with all plants including those in long term shutdown. The differences between Figures 4 and 5 are due to the practice of some units to consider their long term shutdowns as forced outages. SINET reflects the licensee categorization of their outages. The upper-bound of the outage estimate in Figure 5 shows a sharp drop in forced outage hours between 1986 and 1988. liuch of this trend should be properly ascribed to restart of plants under long term shutdown or reclassification of their outages by the licensees.
Figure 4 should be regarded as the more accurate reflection of maintenance outage trends, i
- 1988 estimate is based on data for the first nine months of 1988.
- The projected estimate for 1988 is a linear extrapolation of the data for I
the first nine months of 1988.
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2.6.3 Other Economic Estimates Associated with Maintenance f
l For comparison purposes, two other economic estimates associated with maintenance are examined: the NRC draf t Regulatory Analysis for the proposed maintenance rule
- and a recent article on plant maintenance by Theodore Marston of EPRI.**
The estimated economic benefit to industry and rate payers of the Maintenance l
)
Rule in the draft Regulatory Analysis is based on an postulated improvement of five percentage point improvement ir annual capacity factor at 20 to 30 plants.
These plants have substantial room for improvement in maintenance and are experiencing poor capacity factor largely due to maintenance weaknesses. This 5 percentage points in capacity factor translates into 360 to 540 plant-days of increased power generation. The avoided cost of purchase power would be 159 to 239 million dollars per year.
(The draft regulatory analysis then computes the present value of this annual cost savings discounted at 10% per annum over 30 years and concludes that savings to be 1.5 to 2.3 billion dollars.)***
The Marston article identifies an average increase in operations and maintenance cost of 60 percent in the last 5 years. Maintenance is identified as being a relatively constant 25 percent of operations, maintenance and fuel costs. Maintenance costs at individual units are identified as varying consi-derably from 9 to 45 million dollars per year. Marston compares 1985-86 plant operating data with average data in the 1968-84 period and concludes that plant capacity factor performance has improved by about 1.8 percentage points due to maintenance related improvements in steam generator reliability and thermal efficiency. This 1.8 percentage point improvement in capacity factor would translates into about 720 plant days of increated power generation for 110 plants currently operating or about 320 million dollars per annum.****
Thus using Marston's data one can conclude the value of historic improvements in maintenance at about 320 million dollars per annum or an average 3 million dollars per unit.
2.6.4 Comparison of Economic Estimates Assec_iated with Maintenance The various cost estimates presented in this section are quite different in their focus. The Marston data yields an estimate of 350 million dollars as a cost saving for present plants associated with past efforts to improve maintenance, but does not' address potential savings associated with future
- "Draf t Regulatory Analysis for the Proposed Maintenance Rule," Office of Research, NRC (to be published).
- Theodore U. Marston, " Plant maintenance trends in the United States,"
Nuclear News, December 1988.
- This present value technique can be used to translate the annual savings calculated to a present worth.
- A December 22, 1988 memorandum to J. L. Blaha, OEDO, from R. A. Hartfield, ARM, " Chairman's Office Questions on Plant Performance Improvements" identified an industry wide 1% increase in plant capacity factor as having a cost savings of 240 million dollars. This ARM estimate is higher than an approximately 180 million dollars for a 1% increase in capacity 1 actor from the assumption in the draf t Regulatory Analysis. The analysis in this paper will use the same assumptions as the draft regulatory analysis for consistency.
4 actions. The draft Regulatory Analysis presents an effort to realistically estimate the impact of the proposed Maintenance Rule by examining those plants with degraded capacity factors due to maintenance and estimating the impact of the proposed rule on improving the capacity factors for those plant (159 to 239' i
million dollars per year).
The upper bound cost estimates developed from forced outages in SINET run at an annual rate approaching I billion dollars. This estimate represents the potential savings if all forced outages identified with maintenance deficien-cies and equipment failures were eliminated by improved maintenance. Thus, this estimate differs from that in that of the draft Regulatory Analysis as it makes no allowance for the irrpact of the proposed rule and only identifies the consequences of eliminating all forced outages of certain classes. The lower bound cost estimates developed from forced cutages in SINET run at an annual rate of about 100 million dollars considerably lower than the upper bound estimates. The lower bound estimate also represents a potential improve-ment, but this estimate is limited to those forced outages identified as maintenance related in SINET. The rationale for these lower bound and upper bound estimates is that the data in NUREG 0020 and SINET may not be consistently reported and the AE00 analysts believe that many forced outages identified in SINET as " equipment failures" may indeed be due, in part, to maintenance deficiencies.
Lastly, an estimate of the replacement power costs associated with forced outages due to trips caused by maintenance deficiencies ran at about 119 million dollars per year from mid-1987 to mid-1988. This estimate is clearly on the low side as trips are only one of many potential causes of maintenance related forced outages.
In summary, the cost of maintenance deficiencies to the utilities and the ratepayers is running in the hundreds of millions of dollars per annum or multiple millions of dollars per annum per unit, while the licensee expenditures on maintenance is estimated to range from 9 to 45 million per annum per unit.
3.
FINDINGS AND CONCLUSIONS Based on the reviews of operational experience, the following findings and conclusions are reached:
1.
Maintenance-related problems have been identified in many systems and components in several operating nuclear plants. The type of components and i
systems involved, such as motor-operated valves, solenoid valves, plant air systems, and service water systems, point out the pervasiveness of the problem and the potential for common cause failure of redundant safety equipment and systems.
2.
Inadequate preventive maintenance practices account for a number of the
{
maintenance-related problems identified in the event reports and generic l
communication documents.
1 3.
Deficient maintenance procedures are also a major contributor to maintenance problems.
1 i
l
' 4.
Human errors occurring during maintenance activities are also identified as part of the problem, and they point out the need for improved planning and personnel training.
5.
Over 50 percent of the maintenance deficiencies in safety systems appear to occur in eight safety systems.
6.
The trend for those events tracked by the Performance Indicator Program which can be attributed to mair,tenance deficiencies showed a dropoff after the Third Quarter of 1987.
7.
The cost of purchased power to replace generation lost by forced outages associated with automatic scrams due to maintenance deficiencies is estimated to be at an annual rate of over 100 million dollars in the period from Mid-1987 to Mid 1988. No discernible trend of improvement in these purchase power costs were evident during this period.
8.
An upper-bound estimate of the cost of replacement power for all maintenaner related forced outages is 960 million dollars in 1987 and a projected 720 millicn dollars in 1988.
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