ML20246E812

Rev 1 to Maint Problems at Nuclear Power Plants, Special Study Rept AEOD/S901.Table 2 Withheld

ML20246E812
Person / Time
Issue date:	05/31/1989
From:	Chiramal M, Israel S, Wegner M NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:
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ML19302D821	List: ML20246E807 ML20246E812
References
TASK-AE, TASK-S901 AEOD-S901, NUDOCS 8905120030
Download: ML20246E812 (46)

Text

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t AE00/S901, Rev 1

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l SPECIAL STUDY REPORT AE0D/S901, REVISION 1 MAINTENANCE PROBLEMS AT NUCLEAR POWER PLANTS May 1989 i

Prepared by:

l Mary Wegner Matthew Chiramal Sandy Israel Sal Salah Stephen Stern IRevisions are shown with a colon (:) in the right hand margin of the page.

l 8905220030 890505

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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 communications by the NRC to licensees, feedback documents issued by the Institute of Nuclear Power Operations (INP0),

and Licensee Event Report.s issued by operating domestic nuclear plants.

These documents were reviewed to identify maintenance-related problems and deficien-cies, the number of plants involved, the systems and components affected, and 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 AE00 case studies, special studies, and engineering evaluations issued since 1985, the review identified 15 (about 20% of all studies) that specifically addressed maintenance-related problems. We conclude that the maintenance-related problems found in systems such as the service water system, the instrument air system, and other safety-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 (approximately 20% of a total of about 400). The review of these documents provide similar conclusions to those obtained by the review of the study reports - i.e., problems addressed in these generic communications identified maintenance procedure deficiencies, inade-quate 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.

These documents, i.e., AE00 renorts, and NRC bulletins and information notices, characterize the broad scope of maintenance deficiencies and the significant staff effort to alert licensees of maintenance problems.

Some of:

these documents are based on operating experience over several years, while others are based on one or more safety significant events.

Simple counts of :

the documents cannot be meaningfully used to establish trends.

In order to ascertain trends in reported maintenance deficiencies, we relied on data from:

operating reactors reported in licensee event reports (LERs) contained in the Secuence Coding and Search System (SCSS). This effort identified a gradually improving trend in maintenance-related problems in the industry in :

the 4-year period beginning with 1985. It should be noted that LERs focus on :

safety-related equipment and systems, and hence, trends based up& LERS are primarily associated with such equipment and systems.

Improving trends in forced outage rate and equipment forced outages, and a marked improvement in the scram rate, all support the view that overall plant :

maintenance is improving.

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1 Hence, we conclude that although maintenance proble.ns continue to occur in a broad number of systems and equipment, recent operating experience point to an:

improving trend in safety performance that can be attributed to improvements in maintenance.

A bounded estimate for the cost of maintenance deficiencies associated with replacement power costs for forced outages was developed from the SINET data base. The upper bound of this estimate shows steadily increasing replacement power cost 3 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 dollers in 1988.

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 quality of maintenance at operating plants, and serve as input to a regulatory guide on maintenance. Lastly, the information regarding financial matters can provide additional perspective regarding current maintenance costs.

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INTRODUCTION This stucy was ir.itiated to determine the extent and pervasiveness of maintenance problems in operating nuclear power plants. 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 based on operational experience reported to tLe NRC, and is based on the review of existing completed AE0D studies, NRC generic communica-tions to licensees, and licensee event reports. 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 components that predominate.

Finally, the review attempts to identify any trends in the area of maintenance in the recent years.

AE00 studies based on operating experience are discussed in Section 2.1.

Maintenance related NRC bulletins and information notices are reviewed in Section 2.2, and similar INP0 documents in Section 2.3. Trends based on available licensee event report data bases are discussed in Section 2.4 and 2.5.

Section 2.6 discusses NRC Performance Indicator program data related to maintenance activities. Section 2.7 discusses the economic assessment of maintenance deficiencies.

2.

OPERATIONAL EXPERIENCE REVIEW 2.1. Review of AEOD Reports of Case Studies, Special Studies, and Engineering Evaluations Issued since 1985 AE00 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 warrant further analysis by the staff to determine 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 AE00 study.

Reports issued by AE0D since 1985 were screened to identify those issues where the quality of maintenance was directly related tosthe 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.

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.

6.

S503 - Evaluation of Recent Valve Operator Motor Burnout Events.

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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 di6sel 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.

Systemfoulingcausedamajority(58%)ofthe276eventsthathadpotential 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 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 major events.

These events include leaving the system misaligned after maintenance, improperly instc11ing 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 plants. Thus, these problems are wide spread.

Since the service water system is a direct 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 reviewad, however, requires licensees to perform any type of heat exchanger testing.

It is important to note that severabaffected plants have instituted comprehensive surveillance programs to monitor service water degradation in selected components. At one plant the tests are performed

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weekly while at another they are performed monthly. These frequencies are higher than some of the required tests on safety systems and attest to the importarce of the concern and severity of the problem.

" Operating Experience Feedback Report - Air Systems Problems" (NUREG-1275 v.2) compiled about 160 events involving failure of safety related equipment caused by degraded or malfunctioning non-safety grade air systemt. Approximately 40 percent of these events are concerned with deficiencies in the maintenance of air actuated components or the air system itself. The safety systems affected by the air-system events include the reactor trip system, auxiliary feedwater, residual heat removal, emergency core 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 principal maintenance deficiency pointed out by this study is the lack of l

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 susceptible to contaminants because of small clearances. The study finds that maintenance personnel frequently did not understand the potential safety consequences of degraded air systems. They are often unaware of the potential for common cause failure of redundant safety related equipment that rely upon air systems. Significant events which occurred at 31 plants are documented in the study and cover older plants as well as recently licensed plants.

Motor operated valve (NOV) problems were reported in a number of studies that find maintenance a principal contributor to equipment degradation and failure.

flost recentlys 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 (AE00/E702)

A Peview of Motor-operated Valve Performance (AE0D/C603)

Evaluation of Recent Valve Operator Motor Burnout Events (AE0D/S503)

Since motor operated valves exist in most fluio systems in the plant, the problems are widespread.

Five hundred and sixty five LERs involved problems with MOVs in the time period 1981 through mid-1985.

The NPRDS data base, 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 specifically analyzed to determine which events were strictly maintenance related; however, the l

evidence suggests that between 50 and 80 percent of the events fall into this ca tegory. Because flawed maintenance practices involving MOVs pervade all systems, the potential for common cause failure of redundant safety equipment is significant.

Improper torque / limit switch settings is a major contributor to degraded valve operation.

It is hypothesized that torque switch " corrective action" may have substituted for definitive identification of the underlying valve inoperability

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I problem. Thus, it is conjectures that the flexibility to make adjustments rather than perform a root cause analysis may have bred bad maintenance habits.

Une of the studies addressed the use of a new environmentally cualified grease which had a lower viscosity. The lower viscosity grease could migrate more I

easily to an area where a spring must compress to provide thrust to operate the POV. Due to inadequate grease relief in the spring area, the spring could not compress. Thus, inadequate design evaluation resulted in addressing one problem (equipment qualificaj. ion) while creating another problem (spring pack or hydraulic lockup). MOV events have occurred at virtually every plant.

I "0verpressurization of Emergency Core Cooling Systems in Boiling Water Reactors" (AE0D/C502) is a case study of potential intersystem loss-of-coolant-accidents caused overpressurization of low pressure sytems due tJ N,e pressure boundary interface problems.

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 re'> ort cites occurrences at four of the 26 BWR sites.

" Loss of Safety System Function Events" (AE0D/C504) is 3 case study that compiled 87 events of loss of safety cystem function involving human factors in the time period 1981 to 1984. Approximately 28 percent of these events occurred during maintenance activities. Most of the events cited involved the residual heat removal system or the ECCS. The types of human errors that occurred during maint m nce include failure tt, follow procedures, inadequate planning, defective ;socedures, and failure to perform work correctly. These events occurred at 20 different plant sites.

" Trends and Patterns Program Report - Operational Experience feedback on Main Feedwater Flow Control and Main Feedwater Flow Bypass Valves and Valve Operators" (AEOD/P701) provides an engineering analysis of reported failures in these components. The report finds that 'N main source of variation in failure rate is due to the differences in maintenance practices among units and stations. The evaluation shows that proper maintenance and the use of appro-priate subcomponents are dominant positive actions to avoid problems in the main feedwater system. Valve operator failures were caused by poorly maintained 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 manufac-turer's representatives were used to correct the problems of these valves.

" Single Failures and Other Deficiencies Noted in U ntrol DF m Emergency Ventilation Systems" (AE0D/E802) is a review of nine evets fnvolving an inadequate emergency ventilation system.

Four of the vent,were caused by maintenance errors - misaligned systems or reversed leaos. 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 plants.

" Reliability of Recirculation Pump Trip Breaker during an ATWS" (AE0D/f804) 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

5-breaker misadjustment or lubrication problems. The frequency 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 plants.

"Depressurization of Reaci.or Coolant Systems in PWRs" (AEOD/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 pressbre were out of service for extended periods of time prior to the Salem event because corrective maintenance was deferred until the next refueling (expected tobeseveralweekshence).

In addition, several other pieces of non-safety grade equipment were also inoperative because of deferred maintenance. This situation could have distracted an operator, responding to a more challenging event, because of missing process information and faulty equipment that would require aoditional operator attention. Much of the equipment were not in the limiting conditions for operation in the plant Technical 3 ecifications 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 loverters" (AE0D/C605) examines 142 events for 1982 to 1984.

Personnel actions wete 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 instrumentation 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 plants.

"Less or Actuation of Various Safety Related Equipment Due to Removal of Fuses or Opening of Circuit Breakers" (AE00/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" (AE00/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 AEOD in this time period identified issues where maintenance was a significant causative factor. These studies showed that maintenance problems and deficiencies occurred at a large number of plants and affect a large number of plant systems. More importantly, these studies are judged to have generic safety significance.

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The maintenance problems vary among the studies reviewed.

They include inadequate 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 boundary configurations in SWRs and control ventilation systems.

2.2. Review of NRC Bulletins and Information Notices Issued Since 1985 Review and analysis of NRC generic communication docurents, 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 e 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 nalntenance related problems involved, the system or component affected and the plants involved. The details of this review are shown in Table 1.

NRC 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 addressed by the documents in Table 1, are problems that are considered generic and potentially applicable to many, and perhaps all 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 inadequate 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 variousssystems and components, such as auxiliary feedwater pumps, plant air systems, instrument transmitters, relays, dc batteries, circuit breakers, 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

3 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 operati r experience reports (SOERs), 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 problem involved, the system or component affected, and the plants where the event occurred. The details of this review are shown in Table 2.

Of the 45 reports in Table 2, 14 involved inadequate planning and procedures, 12 pertained to preventive maintenance deficiencies, 10 concerned human errors committed, and 5 involved inadequate testing of equipment and systems. The remaining reports dealt with various equipment and component problems.

2.4.

Licensee Event Report Database Review Analysis of databases that capture various reports on nuclear power plant experience was cone to estimate the trend of maintenance-related activities in:

the industry.

We relied heavily on LERs encoded in the Sequence Coding and Search System (SCSS).

We also used data from the NRC Performance Indicator :

(PI) program and from the licensee monthly operating data reports.

(NOTE:

The original report included information from the Nuclear Document System (NUDOCS), the NRC's automated, searchable document system that contains all documents generated by the regulatory process.

Trending of maintenance-related documents contained in NUDOCS is a measure of maintenance deficiencies at nuclear plants as well as a measure of NRC staff's focus on maintenance issues.

Since we could not readily sort these aspects of the data, we deleted the NUDOCSdatafromthisrevisedreport.)

SCSS is a detailed data base of encoded LERs which includes information about systems and components challenged during an event and the transient aspects of the event. The system primarily captures safety-related deficiencies. While :

balance-of-plant (B0P) initiated trips are reported, events involving B0P equipment may not need to be reported by licensees. Nevertheless, since the :

SCSS is a data base system that undergoes rigorous quality assurance checks, its consistency lends itself to trending (time dependent) analyses.

Initially a narrow search for maintenance deficiencies was performed using the:

SCSS data base with 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 1

adjustment or positioning. This does not include improper setting 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.

We found 120 records in 1985, 135 in 1986, 160 in 1987, and 108 in 1988.

The trend here shows an increase till 1987, and a decrease :

in 1988. However, it should be noted that the data average about one per plant per year, and hence, there is insufficient data to support an indication:

of industry trend.

Broad searches involving thousands of records and using large number of codes :

- codes in the order of 20s - provide more meaningful trends. Such an effort :

is described in the remainder of this section.

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LERs in the SCSS were used in a program by the Oak Ridge National' Laboratory :

(ORNL) to extract cause and corrective action data.* This cause data is distributed among the following seven cause codes:

(1) administrative control:

(AC), (2) random equipment failures (REF), (3) design, fabrication, construction, and installation error (DFCI), (4) licensed operator error (L0E),

(5 other personnel error (OPE), (6) maintenance 1 error (MI), and (7 maintenance 2 error (M2).

The cause code data are extracted as numbers of counts in each of the seven cause codes. An LER containing more than one of the seven cause codes is counted in each cause code category. An LER containing multiple counts of the:

same cause code is counted only once for that code. On an average, about two :

causal factors (counts) are associated with each LER.

Twomaintenance-relatedcausecodesareused-maintenance 1(M)1and maintenance 2 (M2). M1 and M2 are mutually exclusive and, hence, may be summed. Both measures are expansive and, in total, are intended to capture all aspects of a maintenance program. M1 captures those deficiencies clearly :

related to implementation of a maintenance program. M2 ( vtures equipment' failures that may be indicative of a maintenance program ceficiency.

The maintenance 1 error cause code intends to reflect deficiencies that are attributable to poor maintenance practices or maintenance personnel errors, Data under this code is obtained >y finding and counting, avoiding double counting, (1) all LERs coded in the SCSS as personnel activity errors in the maintenance, surveillance, radiation protection, or " unknown" category, and (2) all LERs with one of the following causes: missing, mispositioned, improper separation, loose, tight, wrong part, wrong material, improper repair, ineffective repair, impact, dropped, worn, boron precipitation, corrosion, erosion, open circuit, short circuit, drift, aquatic organism, weld-related flaw, foreign object, or lubrication-related problem. Of these :

LERs only those in which repair or adjustment is required is counted as an M1 :

category event.

The maintenance 2 error cause code reflects problems which are potentially indicative of a maintenance problem.

It is clearly intended to capture events:

beyond those identified by M1. Data for this code is obtained by first finding all LERs in the SCSS encoded as: temporary modification, overload, fatigue, vibration, air / steam binding, cavitation, loss of pump suction, pressure pulse, high temperature, freezing condition, high thermal change rate, overcurrent, undercurrent, overvoltage, undervoltage, instrument repeatability problem, electrical noise, water spray, high humidity, smoke, radiation, high ambient temperature, cladding degradation, and various "other":

codes. Also included are " unknown" causes for non-solid state type components. Failures attributable to an environmental factor, such as lightning, are excluded. Events which were linked back to a previous personnel error and events which involve postulated or potential failures are :

• 0RNL/NOAC-244. Results from Trial Program for Use >f Cause and Corrective Action Data as Programmatic Performance Indicators. January 13, 1989, Oak Ridge National Laboratory /NRC.

4.

removed from the data. Then, from the remaining, only those events in which repair or adjustment is required are counted as M2.

In the original report, the cause code counts for three 12-month periods (1) July 1, 1985 - June 30, 1986, (2) July 1, 1986 - June 30, 1987, and (3) :

July 1,1987 - June 30,1988_ were displayed to show the distribution of the :

counts as pie charts with percentages for each cause code. The total number :

of LERs for each 12-month period was also given.

In that report the three charts indicated that the distribution of maintenance 1 and maintenance 2 errors remained rather constant (M1 ranged between 31 and 32 percent, and M2 between 11 and 15 percent), while the number of LERs over the three periods showed a decreasing trend (from 2815 to 2550).

For this revision, the data for the seven cause codes are expanded to cover all four quarters of 1985, 1986, and 1987, and the first two quarters of 1988.:

The distribution of the cause code count data as a function of time in years :

is shown in Figure 1A and IB. The same data is shown in Figures 2A, 28, 2C, and 2D as pie charts for the three years 1985, 1986, 1987, and for two quarters of 1988. (In Figures 1A and 18, the data for 1988 is obtained by projecting the data of the first No quarters of 1968.) These figures are for:

the industry as a whole and have not been normalized for the growth in the number of operating plants, nor have the data from plants in extended shutdown been excluded. As seen in these figures, the number of LERs have remained generally constant (around 2750 to 2800) during 1985,1986 and 1987, but the number of cause code counts show an increasing pattern till 1988. The:

projected numbers for 1988 show a decrease in both the number of LERs and the :

number of cause code counts.

Because of the broad definitions of M1 and M2, and of the inaccuracies in reporting and coding, the aholute values of the data in these figures should :

not be used to reach any conclusions.

The pie charts in Figures 2A,28, 2C, and 2D which depict the distribution of the seven cause codes for 1985, 1986, 1987, and the first two quarters of 1988, show that M1 has remained around 31 percent, and M2 has decreased from :

16 percent to il percent. These figures (Figures IA, 18, 2A, 2B, 20, and 2D) :

indicate that the fraction of maintenance error M1 has remained relatively unchanged and the fraction of maintenance error M2 Sas shown a decline.

Overall one may conclude that maintenance problems have continued to represent:

a substantive fraction of all problems reported in'LERs.

It should be noted that the number of plants licensed to operate have increased since 1985 - 95 in 1985, 104 in 1986 and 109 in 1987 and 1988.

Taking this into consideration, the maintenance related cause code data M1 and:

M2 for the four cuarters of 1986 and 1987, and for the two quarters of 1988, are normalized and an industry average maintenance indicator trend for M1 and :

M2 is obtained as shown in Figures 3A and 38.

Figure 3A shows the data from :

all operating nuclear plants while Figure 3B shows data for plants licensed prior to 1984. The graph of M1 shows a declining trend of this indicator of about 6 percent pey/ -year span.

year for all plants and 4 percent per year for mature plants over the 2 Indicator M2 shows a sharper decline of 2

about 18 percent per year for both sets of plants. These indicator trends show that nuclear plant maintenance programs for safety-related systems,

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equipment, and components are effecting a decrease in the number of reported events involving failures of such systems, equipment, and components.

The overall conclusion reached in reviewing the various aspects of the maintenance error cause codes extracted from LERs is that in the past 3 years :

maintenance-related problems experienced by operating nuclear plants have been:

decreasing.

2.5 Review of Events Identified as Ma ttenance-Related Safety System Failures In Section 2.4 data based on all LERs was presented.

In this section, we focus on that subset of LERs used in the NRC Performance Indicator (PI) program. The PI program classifies and tracks those LERs which involve automatic scrams (scrams), safety system failures (SSFs), safety system actuations(SSAs),andsignificantevents(SEs). These PI LERs are considered:

to be of a higher safety significance by the NRC than other LERs.

By trending those LERs which are in the PI program and which can be attributable to maintenance deficiencies as identified by the SCSS cause code :

extraction scheme (M1 and M2), an estimate of the trend in significant maintenance related events can be obtained. Such a trend for three quarters of data was included in the original report.

For this revision, the trend for six quarters, beginning the first quarter of 1987 and ending the second quarter of 1988, is obtained.

Figure 4.1A and Figure 4.1B show the distribution of events in the PI programs:

which were classified as describing an M1 error. Figures 4.2A and 4.2B show :

the data distribution for M2 events. The figures show a decrease in the fourth quarter of 1987 and followed by a small decrease in the two quarters of:

1988. As seen in Figures 4.18 and 4.2B, the decrease is mainly due to the drop in the number of scrams and safety system failures starting in the fourth:

l quarter of 1987. The trends can be interpreted to mean that the industry programs for reducing scrams and safety system failures include effective maintenance improvements.

The pie charts in Figurec 4.3A and 4.3B show the distribution of the seven cause codes for the subset of LERs in the PI progran for 1987 and 1988. M1 is:

remaining around 28 percent, and M2 around 15 percent. These figures indicate:

that the fraction of maintenance errors in the subset of events for these two :

time frames, has remained unchanged.

(These fractions can be compared with those that apply to the larger set of all LERs in F.igures 2C and 2D, where M1 :

is around 31 percent and M2 about 11 percent.)

2.6 Review of PI Data on Forced Outage Rate and Equipment Forced Outages There are seven indicators in the NRC Performance Indicator Program for (1) automatic scrams while critical, (2) safety operating nuclear p(lants:3) significant events, (4) safety system failures,:

system actuations, (5) forced cutage rate, (6) equipment forced outages per 1000scritical hours, :

and (7) collective radiation exposures.

Figure 5 shows the annual industry :

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Quarterly Report of February 1989.

Of the seven indicators those for forced outage rate and equipment forced outages per 1000 critical hours (Figure 5, Blocks 5 and 6) are considered to :

i be the ones most closely associated with overall plant maintenance.

Forced outage rate (FOR) is defined as the number of forced outage hours divided by j

the sum of forced outage hours and generator on-line hours.

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outages per 1000 critical hours (EF0) is the inverse of the mean time between :

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number of hours the reactor is critical in a period divided by the number of forced outages caused by equipment failures in that period.

Both.these Indicators are used only for plants that are in commercial operation. To the :

extent these indicators reflect maintenance activities, there is a recognizable improvement in the 1988 industry performance in the area of maintenance compared to the previous 3 years.

Figure 5, 81ock 8 shows unit availability factor for 1985 to 1988.

Unit availability is not a performance indicator. Data was obtained from NUREG 0020 and shows an increasing trend consistent with declining forced outage rates and equipment forced outages per 1000 critical hours.

1 2.7. Economic Assessment of the Cost of Maintenance Deficiencies This section presents rough estimates of the magnitude and trends in the cost-i 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 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 estimate 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 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 million dollars in 1987 and a projected 720 million dollars in 1988. The lower-bound estimates are considerably smaller being 120 million 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.

For comparison purposes, the draft Regulatory Analysis for the proposed maintenance rule estimates the w,t savings associated with reduced downtime due to improvements in maintenance range from 159 to 239 million dollars per year.

2.7.1 The Trend in the Economic Costs of Maintenance Related Trips 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 tracked 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 complete and can be used to establish trends.

Automatic scrams which are attributable to maintenance deficiencies were estimated by the Nuclear Operations Analysis Center of Oak Ridge National Laboratories (0RNL) using SCSS to classify those 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 scram forced outages *** was estimated to be $85.1 millicn 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 events is $404,000 per day per reactor.) Of this $85.1 million replacement power costs, $44.6 million (52.4% of the total) is attributed to BWRs and $41.5 million (47.6%) to PWRs.

Figure 6 presents the cost of these maintenance forced outages for PWRs and BWRs on a quarter by quarter basis for this time period. The cost of these maintenance forced outages was comparatively constant for PWRs, varying from $12.4 to $14.8 million per quarter. On the other hand, the maintenance outage cost for EWRs 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 quarter 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.

• Transmittal letter, G. T. May (0RNL) to S. Stern (AE0D), 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.

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• • • 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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2.7.2 The Economic Costs of Maintenance Related Forced Outages 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 SINET data base for 1981 through 1988.* SINET classifies forced outages as being due 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 aucit of forced outage events associated with the equipment failure category indicates the majority of these events are also associated with maintenance i

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 riaintenance deficiencies.

Figure 7 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 utilized 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 ar.d a projected 80 million dollars in 1988.

For reference purposes, Figure 8 shows these same bounded estimates for maintenance related forced outages with all plants including those in long term shutdown. The differences between Figures 7 and 8 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 8 shows a sharp drop in forced outage hours between 1986 and 1988. Much of this trend should be properly ascribed to restart of plants under long term shutdown or reclassification of their outages by the licensees. Figure 7 should be regarded as the more accurate reflection of maintenance outage trends.

• 1968 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 the first nine months of 1988.

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