AUDIT REPORT 

Audit of NRC’s Power Uprate Program 

OIG-08-A-09 March 28, 2008 

All publicly available OIG reports(including this report) are accessible through 

NRC’s Web site at: 

http:/www.nrc.gov/reading-rm/doc-collections/insp-gen/ 
 March 28, 2008 

MEMORANDUM TO: Luis A. Reyes 

Executive Director for Operations 

FROM: Stephen D. Dingbaum /RA/ 

Assistant Inspector General for Audits 

SUBJECT: AUDIT OF NRC’S POWER UPRATE PROGRAM (OIG-08-A-09) 

Attached is the Office of the Inspector General’s (OIG) audit report titled, Audit of NRC’s 

Power Uprate Program. 

The report presents the results of the subject audit. Agency comments provided at the 

exit conference on February 22, 2008, have been incorporated, as appropriate, into this 

report. 

Please provide information on actions taken or planned on each of the 

recommendations within 30 days of the date of this memorandum. Actions taken or 

planned are subject to OIG follow up as stated in Management Directive 6.1. 

We appreciate the cooperation extended to us by members of your staff during the 

audit. If you have any questions or comments about our report, please contact me at 

415-5915 or Sherri Miotla, Team Leader, Nuclear Safety Team, at 415-5914. 

Attachment: As stated 
Electronic Distribution

Frank P. Gillespie, Executive Director, Advisory Committee on Reactor 

 Safeguards/Advisory Committee on Nuclear Waste 

E. Roy Hawkens, Chief Administrative Judge, Atomic Safety and 

 Licensing Board Panel 

Karen D. Cyr, General Counsel 

John F. Cordes, Jr., Director, Office of Commission Appellate Adjudication 

James E. Dyer, Acting Chief Financial Officer 

Margaret M. Doane, Director, Office of International Programs 

Rebecca L. Schmidt, Director, Office of Congressional Affairs 

Eliot B. Brenner, Director, Office of Public Affairs 

Annette Vietti-Cook, Secretary of the Commission 

Bruce S. Mallett, Deputy Executive Director for Reactor 

 and Preparedness Programs, OEDO 

Martin J. Virgilio, Deputy Executive Director for Materials, Waste, Research, 

 State, Tribal, and Compliance Programs, OEDO 

Darren B. Ash, Deputy Executive Director for Information Services 

 and Chief Information Officer, OEDO 

Vonna L. Ordaz, Assistant for Operations, OEDO 

Timothy F. Hagan, Director, Office of Administration 

Cynthia A. Carpenter, Director, Office of Enforcement 

Charles L. Miller, Director, Office of Federal and State Materials 

 and Environmental Management Programs 

Guy P. Caputo, Director, Office of Investigations 

Thomas M. Boyce, Director, Office of Information Services 

James F. McDermott, Director, Office of Human Resources 

R. William Borchardt, Director, Office of New Reactors 

Michael F. Weber, Director, Office of Nuclear Material Safety and Safeguards 

James T. Wiggins, Acting Director, Office of Nuclear Reactor Regulation 

Brian W. Sheron, Director, Office of Nuclear Regulatory Research 

Corenthis B. Kelley, Director, Office of Small Business and Civil Rights 

Roy P. Zimmerman, Director, Office of Nuclear Security and Incident Response 

Samuel J. Collins, Regional Administrator, Region I 

Victor M. McCree, Acting Regional Administrator, Region II 

James L. Caldwell, Regional Administrator, Region III 

Elmo E. Collins, Jr., Regional Administrator, Region IV 

 

 
Audit of NRC’s Power Uprate Program 

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EXECUTIVE SUMMARY 

BACKGROUND

Power uprate is the process for increasing the maximum power level at 

which a commercial nuclear power plant may operate. Plant components 

must be able to accommodate any new conditions that would exist at 

increased power levels. In some instances, licensees will modify and/or 

replace components in order to accommodate a higher power level. 

Depending on the desired increase in power level and original equipment 

design, this can involve major and costly modifications to the plant. All of 

these factors must be analyzed by the licensee as part of an application 

request for a power uprate. 

In order to make a change to the license of a currently licensed plant, a 

licensee must file with the Nuclear Regulatory Commission (NRC) an 

application for an amendment that fully describes the changes desired. 

NRC’s technical staff, legal counsel, and management are involved with 

the review of the application. After NRC completes its review of the 

application and acts on any applicable public comments, hearing requests, 

or Advisory Committee on Reactor Safeguards (ACRS) recommendations, 

the agency may approve or deny the request on the basis of its findings. 

This process for requesting and approving such changes is specified in 

the Code of Federal Regulations, Title 10, Parts 50.90, 50.91 and 50.92. 

PURPOSE

The overall objective of this audit was to examine the process for 

reviewing and approving power uprate amendment applications. 

RESULTS IN BRIEF

The process for reviewing and approving power uprate amendment 

applications is generally the same as that for other types of license 

amendments. Given the agency’s long-established practices for reviewing 

license amendments, NRC staff often expressed satisfaction with the 

overall process as it is applied to power uprate reviews. However, the 

Office of the Inspector General (OIG) identified power uprate program 

matters needing NRC management attention. Specifically, 
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3⁄4 The power uprate inspection procedure has been implemented and 

documented inconsistently. 

o NRC staff have an inconsistent understanding of the power uprate 

inspection procedure’s use, implementation, and documentation, 

and some staff are not aware of the procedure. This is because the 

inspection procedure lacks specification, implementation, and 

documentation guidance, which results in stakeholders being 

unable to adequately monitor power uprate inspections. 

3⁄4 The circulation and written quality of power uprate safety evaluations 

needs improvement. 

o OIG found that not all regions and resident inspectors are aware of 

the recommended areas for inspection or the regulatory 

commitments sections in the power uprate safety evaluations due 

to a lack of internal controls for distributing safety evaluations. 

Consequently, inspectors risk developing their inspection samples 

and plans without knowledge of recommended inspection areas 

and regulatory commitments in the safety evaluation. In addition, 

NRC staff noted shortcomings in the writing quality of uprate safety 

evaluations that could be improved by strengthening the training for 

writing inputs to the safety evaluations. Poorly written safety 

evaluation inputs hamper a stakeholder’s ability to comprehend 

NRC’s basis for approving an uprate application. 

3⁄4 The power uprate coordinating function could be strengthened to 

ensure program success. 

o The power uprate program does not have a formalized mission 

statement, defined roles and responsibilities, and adequate 

communication and knowledge management tools. A key reason 

for these shortcomings is that the agency lacks an authoritative 

coordinating entity to oversee the entire program. As a result, 

power uprate internal stakeholders are left without clear direction 

and oversight. 

RECOMMENDATIONS

This report makes eight recommendations. A Consolidated List of 

Recommendations appears in Section IV of this report. 
Audit of NRC’s Power Uprate Program 

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OIG ANALYSIS OF AGENCY COMMENTS

The Executive Director for Operations submitted formal written comments 

to this report, which appear in Appendix D. In the written comments, the 

agency generally agrees with the report findings and with six of the eight 

recommendations. The agency indicated that the remaining two 

recommendations were not needed. However, OIG’s recommendations 

were developed to address specific shortcomings discussed in the report, 

and continues to believe agency action is warranted. Appendix E contains 

OIG’s analysis of the agency’s formal response. 
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ABBREVIATIONS AND ACRONYMS 

ACRS Advisory Committee on Reactor Safeguards 

ADAMS Agencywide Documents Access and Management System 

the Branch Generic Communication and Power Uprate Branch 

BWR boiling-water reactor 

CFR Code of Federal Regulations 

EPUs extended power uprates 

the Guide Document Distribution Guide 

IMC Inspection Manual Chapter

IP Inspection Procedure 

MUR measurement uncertainty recapture 

NRC Nuclear Regulatory Commission 

NRR Office of Nuclear Reactor Regulation 

OGC Office of the General Counsel 

OIG Office of the Inspector General 

OMB Office of Management and Budget 

PWR pressurized-water reactor 

RS Review Standard 

SECY Office of the Secretary of the Commission 

SPUs stretch power uprates 

SRM Staff Requirements Memorandum 
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TABLE OF CONTENTS 

EXECUTIVE SUMMARY....................................................................................i 

ABBREVIATIONS AND ACRONYMS ...............................................................v 

I. BACKGROUND ....................................................................................... 1 

II. PURPOSE................................................................................................ 6 

III. FINDINGS................................................................................................ 7 

 A. THE POWER UPRATE INSPECTION PROCEDURE HAS BEEN IMPLEMENTED 

AND DOCUMENTED INCONSISTENTLY.................................................... 7 

 B. ISSUES RELATED TO NRC STAFF AWARENESS AND DEVELOPMENT 

 OF THE SAFETY EVALUATION ............................................................. 15 

 C. POWER UPRATE COORDINATING FUNCTION COULD BE

 STRENGTHENED ............................................................................... 22 

 

IV. CONSOLIDATED LIST OF RECOMMENDATIONS .............................. 28 

APPENDICES

A. SCOPE AND METHODOLOGY ............................................................... 29 

B. NRC LETTERS TO PUBLIC EMPHASIZING IMPORTANCE OF 

IP 71004 .................................................................................................. 31 

C. NRR ORGANIZATION CHART ................................................................ 33 

D. FORMAL AGENCY COMMENTS............................................................. 35 

E. OIG ANALYSIS OF AGENCY COMMENTS............................................. 37 
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I. BACKGROUND 

Power uprate is the process for increasing the maximum power level at which 

a commercial nuclear power plant may operate. A plant may increase its 

power level after the Nuclear Regulatory Commission (NRC) has reviewed 

and approved an application for a license amendment submitted by the 

licensee. NRC has approved 118 power uprate amendment applications 

since 1977, permitting licensees to generate an additional 5,263 megawatts 

electric, which is the equivalent of adding 3 to 4 additional power plants.1

 

A power uprate typically involves the use of more highly enriched uranium 

fuel and/or the installation of additional fresh fuel. This enables the reactor to 

produce more thermal energy and therefore more steam, driving a turbine 

generator to 

produce 

electricity. 

Plant 

components 

must be able 

to 

accommodate 

any new 

conditions that 

would exist at 

increased 

power levels. 

For example, a 

higher power 

level usually 

involves 

greater steam 

and water flow through the systems used in converting thermal power into 

electric power. These systems must be capable of accommodating the 

higher flows that result from the uprate. 

In some instances, licensees will modify and/or replace components in order 

to accommodate a higher power level. Depending on the desired increase in 

power level and original equipment design, this can involve major and costly 

modifications to the plant, such as the replacement of main turbines. All of 

 

1

 The average power rating for proposed new plants is 1,380 megawatts electric. 

Figure 1: 

Power Plant Turbine

Source: NRC
Audit of NRC’s Power Uprate Program 

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these factors must be analyzed by the licensee as part of an application 

request for a power uprate. 

Types of Power Uprates 

There are three categories of power uprates: 

A. Measurement uncertainty recapture (MUR) are increases in power less 

than 2 percent from the previous power level and are achieved by 

implementing enhanced techniques for calculating reactor power. This 

involves the use of state-of-the-art flow measurement devices to more 

precisely measure feedwater flow, which is used to calculate reactor 

power. More precise measurements reduce the degree of uncertainty in 

the power level, which is used by analysts to predict the ability of the 

reactor to be safely shutdown under postulated accident conditions. 

B. Stretch power uprates (SPUs) are increases in power typically up to 7 

percent from the previous power level and are within the design capacity 

of the plant. The actual percentage increase value that a power plant can 

achieve in this category is plant-specific and depends on the operating 

margins included in the design of a particular plant. Stretch power uprates 

usually involve changes to instrumentation setpoints, but do not involve 

major plant modifications. 

C. Extended power uprates (EPUs) are greater than stretch power uprates 

and have been approved for increases as high as 20 percent from the 

previous power level. These uprates require significant modifications to 

major balance-of-plant equipment, such as the high pressure turbines, 

condensate pumps and motors, main generators, and/or transformers. 

The License Amendment Review Process 

In order to make a change to the license of a currently licensed plant, a 

licensee must file with the NRC an application for an amendment that fully 

describes the changes desired. NRC’s technical staff, legal counsel, and 

management are involved with the review of the application. In addition, for 

EPU applications, the Advisory Committee on Reactor Safeguards (ACRS) 

performs an independent technical review of the application. After NRC 

completes its review of the application and acts on any public comments, 

hearing requests, or ACRS recommendations, the agency may approve or 

deny the request on the basis of its findings. This process for requesting and 

approving such changes is specified in the Code of Federal Regulations 
Audit of NRC’s Power Uprate Program 

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(CFR), Title 10, Parts 50.90, 50.91 and 50.92. The process for amending a 

commercial nuclear power plant license for a power uprate is governed by the 

same regulations. 

NRC’s Office of Nuclear Reactor Regulation (NRR) has the bulk of 

responsibility for reviewing the licensee’s power uprate application. Technical 

staff review the licensee’s analyses to determine if the application 

demonstrates that the plant will remain safe and that measures will continue 

to be in place to protect public health and safety when changes to 

accommodate an uprate are made. Project managers in NRR compile the 

technical analyses into a safety evaluation, which documents the agency’s 

findings regarding site safety characteristics and emergency planning for the 

licensee’s plant. Furthermore, staff at the NRC regions and in the plants are 

responsible for carrying out inspections related to power uprates. 

The Inspection Process 

One objective of the NRC’s reactor inspection program is to obtain factual 

information providing objective evidence that power reactor facilities are 

operated safely and licensee activities do not pose an undue risk to public 

health and safety. NRC Inspection Manual Chapter (IMC)2

 2515 establishes 

the agency’s policy for the light-water operating reactor inspection program. 

However, IMC 2515 does not provide guidance for the conduct or timing of 

inspections related to the license amendment review process. 

IMC 2515 describes the following three inspection programs for nuclear 

reactor inspection: 

3⁄4 the baseline inspection program, which provides examination of the 

plants and licensee activities to determine whether licensees are 

meeting safety objectives and to identify indications of performance 

problems; 

3⁄4 the supplemental inspection program, which describe inspections that 

are only performed as a result of performance issues that are identified 

by baseline inspections, event analysis, or other indicators of 

performance; and 

 

2

 NRC Inspection Manual Chapters are documents containing written administrative or inspection program 

statements of policy. An IMC for an inspection program defines the program through a listing of inspection 

procedures, which is normally appended to the IMC. 
Audit of NRC’s Power Uprate Program 

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3⁄4 special and infrequently performed inspections, which may be 

performed in response to events, infrequent major activities at nuclear 

power plants, or to fulfill the NRC’s obligations under interagency 

memoranda of understanding. 

Power uprates are inspected through a combination of special and 

infrequently performed inspections, and baseline inspections. Inspection 

Procedure (IP) 71004, “Power Uprate,” which is intended to be used to 

inspect extended power uprates and is considered a special and infrequently 

performed inspection, provides cross-references to other baseline inspection 

procedures.3

 According to IMC 2515, a special or infrequently performed 

inspection would be employed to address a major plant evolution. 

History and Status of Power Uprate Applications 

Of the 118 power uprates that NRC has approved since 1977, 38 have been 

measurement uncertainty recapture power uprates, 61 have been stretch 

power uprates, and 19 have been extended power uprates, as shown in 

Table 1 below. 

 

3

 Inspection procedures—which are statements of objectives, requirements, and guidance—describe the 

activities to be performed by an inspector. 
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Table 1: Power Uprates Approved by NRC 

Fiscal 

Year 

MUR 

Power 

Uprate 

Stretch 

Power 

Uprate 

Extended 

Power 

Uprate Totals 

1977 -1998 0 42 1 43 

1999 1 0 2 3 

2000 0 3 0 3 

2001 10 6 0 16 

2002 7 1 9 17 

2003 15 2 0 17 

2004 1 1 0 2 

2005 0 3 1 4 

2006 1 2 4 7 

2007 0 1 0 1 

2008 3 0 2 5 

Total 38 61 19 118 

 Source: NRC, as of February 27, 2008. 

There are 9 power uprate applications currently being reviewed by NRC. Of 

these, 2 are measurement uncertainty recapture power uprates, 3 are stretch 

power uprates, and 4 are extended power uprates. The power that will be 

generated from the pending uprates will total 871 megawatts electric. 

Furthermore, NRC expects to receive 24 power uprate applications for the 

time period between fiscal years 2008 and 2012. The agency expects that 7 

of the uprate applications will be for measurement uncertainty recapture 

power uprates, and the remaining 17 applications to be for extended power 

uprates. The power that could be generated from the requested uprates 

could total approximately 1,751 megawatts electric, or the equivalent of over 

one new plant. 
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II. PURPOSE 

The overall objective of this audit was to examine the process for reviewing 

and approving power uprate amendment applications. This audit did not 

examine the technical content of the staff’s final safety evaluations for power 

uprates. Given that extended power uprates require significant plant 

modifications, the Office of the Inspector General (OIG) focused the bulk of its 

review on extended power uprates. Appendix A provides information on the 

audit scope and methodology. 
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III. FINDINGS 

The process for reviewing and approving power uprate amendment 

applications is generally the same as that for other types of license 

amendments. Given the agency’s long-established practices for reviewing 

license amendments, NRC staff often expressed satisfaction with the overall 

process as it is applied to power uprate reviews. However, OIG identified 

power uprate program4 matters needing NRC management attention. 

Specifically: 

A. the power uprate inspection procedure has been implemented and 

documented inconsistently; 

B. the circulation and written quality of power uprate safety evaluations 

needs improvement; and 

C. the power uprate coordinating function could be strengthened to 

ensure program success. 

A. The Power Uprate Inspection Procedure Has Been Implemented and 

Documented Inconsistently 

 

NRC staff have implemented and documented Inspection Procedure (IP) 

71004 inconsistently. In the midst of external stakeholder interest on the 

status of nuclear power plants that had conducted a power uprate, NRC 

officials wrote letters to members of Congress and the public which 

emphasized the importance of power uprate inspections, including IP 71004. 

Nonetheless, NRC staff have an inconsistent understanding of IP 71004 use, 

implementation, and documentation, and some staff are not aware of the 

procedure. This is because IP 71004 lacks specification, implementation, and 

documentation guidance, which results in stakeholders being unable to 

adequately monitor power uprate inspections. 

 

4

 During discussions with the agency, NRC management stated that the word "program" should not be used 

when talking about the power uprate license amendment process, because power uprates are considered 

part of the NRC overall license amendment program. However, NRC documents and staff have commonly 

used the word “program” to describe the entirety of power uprate activities, which includes the application 

review process as well as uprate-related inspections. For purposes of this audit, OIG will refer to it as a 

program. 
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 NRC Emphasizes the Importance of Power Uprate Inspections

Since February 2004, NRC has written several letters to members of 

Congress and the public that have emphasized the importance of power 

uprate inspections, including IP 71004. These letters state that NRC will use 

IP 71004, “Power Uprates,” as well as a number of baseline inspection 

procedures to inspect issues specifically related to power uprate. NRC senior 

officials, including two Chairmen, have signed letters stating that IP 71004 

verifies that licensees have taken the required actions to alleviate or prevent 

the effects of new or likely initiating events that were caused by plant 

modifications related to a power uprate. A list of these letters is provided in 

Appendix B. 

 NRC Staff Implement and Document IP 71004 Inconsistently 

Despite the agency’s public emphasis on power uprate inspections, NRC staff 

have implemented and documented these inspections inconsistently. 

Specifically: 

3⁄4 NRC staff have an inconsistent understanding of IP 71004 

implementation; and 

3⁄4 Internal and external stakeholders cannot easily find results of power 

uprate-related inspections. 

Inconsistent Understanding of IP 71004 Implementation

NRC staff have an inconsistent understanding of IP 71004 implementation 

with regard to time, frequency, and permission to conduct the procedure. 

Staff are unsure when to start and stop the inspections called for in IP 71004. 

NRC regional staff and resident inspectors are also uncertain whether IP 

71004 is a one-time or ongoing inspection. Furthermore, NRC staff are not 

sure if they need to request permission from regional administrators to 

conduct the procedure. 

Most resident inspectors were aware that baseline inspection procedures 

address some of the plant modifications performed during a power uprate; 

however, they had an inconsistent understanding of IP 71004. During the 

audit, OIG interviewed resident inspectors for all of the nuclear power plant 

sites that had conducted an extended power uprate. Approximately one-third 

of these resident inspectors were not aware that IP 71004 existed. Several of 

them were not sure if power uprate-related inspections had been performed 
Audit of NRC’s Power Uprate Program 

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at their assigned nuclear power plant or plants. Lastly, resident inspectors 

had inconsistent answers as to who is in charge of scheduling power upraterelated inspections. 

NRC regional staff also had an inconsistent understanding of IP 71004. OIG 

interviewed the assigned points of contact for power uprates in each region. 

The regions are unclear as to when power uprate inspections should be 

conducted. Some points of contact said that it is a one-time inspection while 

others stated that it might be performed more than once. Regional points of 

contact were not sure if power uprate-related inspections were to be 

performed: 

3⁄4 before the receipt of a license amendment request for an extended 

power uprate, 

3⁄4 after the license amendment request is received, 

3⁄4 during NRC’s review of the request, 

3⁄4 after NRC’s review of the request is complete, or 

3⁄4 for any of these occasions. 

Further, staff at one region stated that they were not sure if regional 

administrator permission to conduct IP 71004 inspections was needed, yet 

another region stated that regional administrator permission was not required. 

Power Uprate-Related Inspection Results Are Not Easily Found

NRC internal and external stakeholders cannot easily find results of power 

uprate-related inspections. Inspection reports for nuclear power plants 

regulated by NRC are available on the agency’s public website. However, 

any mention of IP 71004 and power uprate-related inspections having been 

conducted, or related uprate inspection results, are not easily found within 

these reports or cannot be found at all. 

One way for the public and external stakeholders to find documents related to 

NRC’s regulatory activities is through the Agencywide Documents Access 

and Management System (ADAMS). A search performed by OIG for 

inspection reports that address power uprates in ADAMS yielded hundreds of 

documents, which makes it hard for the public to find information about power 

uprate inspections that have been conducted. OIG searched on “uprate,” 
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“EPU,” and “71004” in public ADAMS. These searches produced a variety of 

documents, such as license amendment requests for power uprates, change 

notices for Inspection Manual Chapters (IMCs), and communication memos. 

The inspection reports were also produced from these searches, but were 

hard to find because they were interspersed with hundreds of other 

documents. This is inconsistent with the agency’s public stance on the 

importance of these inspections. 

OIG reviewed a sample of inspection reports for each nuclear power plant 

that had received or applied for an extended power uprate,5

 and only 15 out 

of 154 inspection reports sampled mention IP 71004 by name (see Figure 2). 

Most of the sampled inspection reports address findings related to power 

uprate modifications, but there is no consistency in the way that the 

information is presented within the reports. Power uprate findings are 

commingled with the results of other inspection procedures. Also, inspection 

reports found on the public website are sorted by nuclear power plant and 

report number only, making it extremely hard for the public to identify reports 

that address special inspection procedures, such as IP 71004.6

 

5

 The sample consisted of every inspection report published for each plant that had received or applied for an 

extended power uprate from 1 to 2 years before the plant submitted its power uprate application until mid2007. 

6

 The most common type of inspection report is an integrated inspection report. However, there are standalone inspection reports that address other baseline inspections. For example, there is a component design 

basis inspection report and fire protection triennial baseline inspection report. 
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Figure 2: Number of Inspection Reports that Mention IP 71004 for Plants Approved or 

Under Review for an Extended Power Uprate (EPU)7

0 5 10 15 20 25 30 35

Hope Creek (awaiting approval)

Browns Ferry (awaiting approval)

Susquehanna (01/30/2008)

Beaver Valley (07/19/2006)

Ginna (07/11/2006)

Vermont Yankee (03/02/2006)

Waterford (04/15/2005)

Brunswick (05/31/2002) 

Arkansas Nuclear One (04/24/2002)

Clinton (04/05/2002)

Quad Cities (12/21/2001)

Dresden (12/21/2001)

Duane Arnold (11/06/2001)

Hatch (10/22/1998)

EPU Power Plants with Application Approval Date

Number of Inspection Reports

reports sampled

sampled reports that mention

IP 71004

Source: OIG analysis of NRC inspection reports. 

 

7

 IP 71004 was first issued in July 2002. Even though some nuclear power plants had their power uprate 

applications approved before IP 71004 was issued, this does not preclude NRC inspectors from conducting IP 

71004 inspections at these plants. For example, IP 71004 was used at Quad Cities and Dresden because the 

steam dryers were replaced due to EPU-related damage. Furthermore, plants do not always have all the 

modifications they need in place to achieve full uprated power upon approval from NRC. For example, the 

Duane Arnold extended power uprate was approved in 2001, but is currently operating below the approved 

power uprate level pending additional modifications and testing before full implementation. 
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 IP 71004 Lacks Specification and Implementation Guidance

IP 71004 does not clearly specify inspection frequency and timing, and 

requirements for the regional administrator’s permission to conduct the 

inspection procedure. Moreover, the procedure is not cross-referenced from 

other inspection procedures, and the results and records of IP 71004 being 

conducted are not documented or indexed in a centralized location or in an 

easily retrievable way so that staff and the public can easily find the results. 

Appendix C of IMC 2515 states that IP 71004 is a “Special and Infrequently 

Performed Inspection;” however, neither IMC 2515 nor IP 71004 specify when 

to start and stop power uprate inspections or how frequent they should be 

conducted. NRC regions prepare quarterly inspection plans, and many of 

them have scheduled power uprate-related inspections. Still, there are 

inconsistencies between the regions as to how much staff time is needed to 

conduct these inspections and how many times they will perform it. For 

example, one region scheduled a power uprate inspection for 2 months with 

one full-time equivalent employee, while another region scheduled the same 

inspection for 9 months with two full-time equivalent employees.8

 Also, IMC 

2515, Appendix C, specifies that special and infrequent inspections, such as 

IP 71004, require regional administrator permission.9 Yet, one region is not 

asking its regional administrator for permission to conduct the inspection, and 

another region is not sure whether they are asking for regional administrator 

approval. However, IP 71004 does not address this requirement. 

IP 71004 is also not cross-referenced from other inspection procedures. A 

unique aspect of IP 71004 is that it references baseline and other inspection 

procedures that could satisfy the requirements of IP 71004. However, those 

other inspection procedures do not cross-reference back to IP 71004. Thus, 

even if some of those other inspections procedures are performed, NRC 

inspectors would not be made aware of the applicability of the other 

procedures to satisfy portions of IP 71004. Including the cross-references in 

the baseline and other procedures would also help inform NRC’s inspector 

community of the existence of IP 71004. 

 

8

 The length of an inspection can be affected by the licensee’s implementation schedule. 

9

 According to Appendix C in IMC 2515, “These inspections are to be performed only when authorized by the 

Regional Administrator after a review and assessment of plant events or conditions, or to fulfill NRC’s 

obligations under domestic interagency memoranda of understanding, or because of participation in 

international agencies.” 
Audit of NRC’s Power Uprate Program 

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Moreover, power uprate-related inspection results and records are not 

documented or indexed in a centralized location or in an easily retrievable 

way so that internal and external stakeholders can easily find the results. 

Instead, power uprate-related findings are inconsistently documented within 

NRC inspection reports. Since many of the baseline inspection procedures 

performed by NRC inspectors cover aspects of IP 71004, power uprate 

inspection results are found commingled with the results of other inspection 

procedures. In many instances, an inspection report had a section that 

specifically addressed power uprate inspections conducted. Yet, these 

reports also had other power uprate-related findings addressed in other 

sections that discussed baseline procedures performed. The ability to locate 

power uprate-related results is further complicated by the fact that inspection 

findings might be addressed in baseline inspection reports as well as other 

inspection reports that address annual, biannual, or triennial inspection 

procedures. NRC currently does not have an inspection report that 

aggregates power uprate-related findings. 

Stakeholders Are Unable to Effectively Monitor Power Uprate 

Inspections 

Inconsistencies in how IP 71004 is implemented and documented hamper 

internal and external stakeholders’ ability to adequately monitor power uprate 

inspections. A better method for retrieving uprate inspection-related 

documents would help NRC staff keep track of power uprate implementation 

activities and related inspection findings. Agency employees that have not 

worked on power uprate inspections, such as resident inspectors newly 

assigned to a previously uprated plant, do not currently have access to a 

quick and simple process to track the power uprate inspections that were 

conducted and reported in previous years. Consequently, important follow-on 

inspection activities could be missed or inspectors could unknowingly 

duplicate previous inspection efforts. 

OIG found a good practice for documenting uprate inspections among the 

NRC resident inspectors at the Beaver Valley Power Station. The resident 

inspectors have developed a document that tracks the power uprate-related 

inspection activities conducted under baseline inspection procedures. They 

also keep track of the plant management’s implementation of the power 

uprate. These documents, which are held by Beaver Valley resident 

inspectors, provide current and future inspectors at Beaver Valley with quick 

access to the power uprate-related activities conducted at their site. 
Audit of NRC’s Power Uprate Program 

14

The performance and results of power uprate-related inspections are also 

important to external stakeholders who are interested in power uprate 

activities at plants, especially after NRC senior officials, including two 

Chairmen, have emphasized the importance of IP 71004. However, those 

who want to track the status of power uprate inspections may be left confused 

as to where to find documentation related to these inspections. Providing a 

centralized location or an easily retrievable way for internal and external 

stakeholders to retrieve power uprate-related inspection documents would 

help NRC continue to improve transparency of its regulatory activities. 

RECOMMENDATIONS:

OIG recommends that the Executive Director for Operations: 

1. Revise IP 71004 to provide more specificity with regard to the use of the 

inspection procedure. 

2. Provide cross-references from baseline and other inspection procedures 

that are called for in IP 71004. 

3. Document or index cumulative IP 71004 and other uprate-related 

inspection activities in a centralized location or in an easily retrievable way 

so that internal and external stakeholders can easily find the results. 
Audit of NRC’s Power Uprate Program 

15

B. Issues Related to NRC Staff Awareness and Development of the Safety 

Evaluation 

Notwithstanding the availability of agency guidance for circulating and 

developing safety evaluations,10 OIG found that not all regions and resident 

inspectors are aware of the recommended areas for inspection or the 

regulatory commitments sections in the power uprate safety evaluations due 

to a lack of internal controls11 for distributing safety evaluations. 

Consequently, inspectors risk developing their inspection samples and plans 

without knowledge of recommended inspection areas and regulatory 

commitments in the safety evaluation. In addition, NRC staff noted 

shortcomings in the writing quality of uprate safety evaluations that could be 

improved by strengthening the training for writing the safety evaluations. 

Poorly written safety evaluation inputs hamper a stakeholder’s ability to 

comprehend NRC’s basis for approving an uprate application. 

Guidance for Developing and Circulating the Safety Evaluation 

NRC’s review of power uprate applications are documented in a safety 

evaluation, and the agency has provided guidance on the development and 

circulation of the safety evaluation from several sources, as follows: 

3⁄4 Review Standard 

(RS) for Extended 

Power Uprates, RS001, issued in 

December 2003, 

identifies the project 

manager as 

responsible for 

preparing and 

finalizing the safety 

evaluation, including 

consolidating 

technical review 

inputs received from 

 

10 The safety evaluation report documents the NRC's findings regarding site safety characteristics and 

emergency planning for plants applying to NRC for a license amendment. 

11 Internal controls are integral components of an organization’s management that provides reasonable 

assurance that the effectiveness and efficiency of operations is being achieved. 

Figure 3: RS-001 Safety Evaluation 

Templates 

Source: NRC. 
Audit of NRC’s Power Uprate Program 

16

other branches. Furthermore, the Review Standard supplies specific 

instructions for the format and content of the safety evaluations, including 

a recommended areas for inspection section and a regulatory 

commitments section. As an aid to NRC staff, RS-001 also provides two 

template safety evaluations for use in generating plant-specific safety 

evaluations—one for boiling-water reactor (BWR) plants and one for 

pressurized-water reactor (PWR) plants (see Figure 3). 

3⁄4 The Division of Operating Reactor Licensing Handbook is a Web-based 

resource that provides guidance on NRC processes and references, often 

in the form of NRC intranet hyperlinks to the source guidance for a 

particular topic. It includes reference sections for project managers and 

other staff on documenting staff decisions, preparing the safety evaluation, 

and issuing the license amendment package—including the safety 

evaluation—via e-mail distribution lists. 

3⁄4 NRR Office Instruction LIC-101, Revision 3, “License Amendment Review 

Procedures,” provides guidance on the safety evaluation format, with 

some additional detail on the structure of the regulatory and technical 

evaluation sections. While guidance on the content of the safety 

evaluation is not detailed, LIC-101 does state that the evaluation should 

contain the staff's specific conclusion that the proposed change is 

acceptable in terms of public health and safety and provide sufficient 

justification for approving the licensing action. 

NRC’s Office of the General Counsel (OGC) also provides safety evaluation 

review guidance in the form of a review checklist. The checklist requires the 

OGC reviewer to decide whether the staff’s conclusions in the safety 

evaluation are supported by a clearly articulated basis and that it is an 

independent review that does more than merely quote the licensee’s power 

uprate application. The OGC reviewer is also required to judge whether the 

staff have properly reflected the licensee actions necessary for approval of 

the license amendment. 

Some Staff Unaware of Safety Evaluation Content 

Two sections—one titled recommended areas for inspection and another 

listing regulatory commitments—have regularly appeared in the extended 

power uprate safety evaluations since 2005. However, not all regions and 

resident inspectors are aware of these sections in the safety evaluations. 

 
Audit of NRC’s Power Uprate Program 

17

OIG contacted NRC resident inspectors at all of the plants that had 

undergone or had applied for an extended power uprate. Some resident 

inspectors were not aware of the recommended areas for inspection section 

or the section that lists the regulatory commitments in the safety evaluation. 

Additionally, some resident inspectors were unaware of any requirements to 

look at the safety evaluation or review the recommended inspection areas. 

One resident inspector stated that he relies on the project manager to alert 

him to this type of inspection guidance located in the back of a safety 

evaluation. The inspector had never heard of a list of recommended 

inspections being placed in a safety evaluation, and considered it highly 

unusual. 

Similarly, several points of contact for power uprates in the NRC regions were 

unaware of the recommended areas for inspection in the safety evaluation. 

One of the regional points of contact stated that there should not be any 

recommended areas for inspection in the safety evaluation and that anything 

the regions need to inspect should be an action item. A point of contact at 

another region was also unaware of the recommended areas for inspection in 

the safety evaluation, because most safety evaluations do not have a list of 

recommended inspections. 

Inconsistent Quality of Safety Evaluation Inputs 

NRR project managers who have worked on a power uprate review have 

noted an inconsistent quality in the written inputs to the safety evaluation 

provided by NRR’s technical branches. The project manager is charged with 

overall preparation of the safety evaluation, including writing specific sections 

of the evaluation and coordinating and reviewing the input of other staff for 

some of the technical sections of the safety evaluation.12 Given their 

coordinating role in the safety evaluation, project managers are among the 

most qualified NRR staff members to comment on the overall quality of the 

inputs received from technical staff. 

Project managers provided a variety of views with regard to the quality of the 

writing in the safety evaluation. These included the use of different writing 

styles and repetitive language, and the lack of consistency between technical 

 

12 NRR management, OGC, and the ACRS all have responsibilities to review the final draft safety evaluation, 

with the goal of providing consistency in the final report. 
Audit of NRC’s Power Uprate Program 

18

groups in what should be included in the evaluation. One project manager 

asserted that some of the technical groups do not know how to write a safety 

evaluation. 

Moreover, the project managers were not necessarily in agreement with 

regard to the purpose of the safety evaluation. For example, one project 

manager said that the safety evaluation is a review of the licensee's proposal 

against the regulations and that the technical staff’s input to the safety 

evaluation is too technically oriented. The project manager said he “doesn’t 

want to know if something is technically adequate," and stated that the 

regulations are a technical justification that the plant is safe and therefore 

NRC’s power uprate review is a compliance review with the regulations. Yet, 

another project manager indicated that the inputs received from technical 

reviewers were not technical enough. Specifically, the project manager 

stated that the technical reviewers tended to exclude the reasons for judging 

the application acceptable other than to designate it a “technically acceptable 

finding” in the safety evaluation. 

NRC Lacks Internal Controls and Training for Safety Evaluations 

OIG observed a lack of adequate internal controls to ensure that the unique 

recommended areas for inspection and regulatory commitments sections in 

the power uprate safety evaluation are communicated and highlighted to 

regional staff and resident inspectors. Furthermore, enhanced training for 

technical reviewers and project managers for writing the safety evaluation 

would be beneficial. 

Internal Controls Over Safety Evaluation Circulation Needed

The agency does not have adequate internal controls to ensure that the 

recommended areas for inspection and regulatory commitments sections in 

the power uprate safety evaluations are communicated and highlighted to 

regional staff and resident inspectors. NRR’s guidance for the distribution of 

the safety evaluation does not ensure that staff in the regions and at the 

plants receive, and are made aware of, important information in the safety 

evaluation. 

The Division of Operating Reactor Licensing’s Document Distribution Guide

(the Guide) provides e-mail distribution lists for various types of documents, 

including the safety evaluation. According to the Guide, the safety evaluation 
Audit of NRC’s Power Uprate Program 

19

is to be circulated to generic region and plant e-mail lists. However, 

inspection points of contact in the regions and the resident inspectors are not 

specifically identified by the Guide for receipt of safety evaluations. 

Project managers stated their belief that regional points of contact and 

resident inspectors receive the safety evaluation through the distribution list, 

even though they are not specifically identified as recipients on the 

distribution lists. Project managers are not required to confirm that the 

regional points of contact and resident inspectors have received the 

document, or are aware of the recommended areas for inspection and the list 

of licensee commitments. As one project manager acknowledged, there is no 

known mechanism that relays such information to these important internal 

stakeholders. 

Training for Writing the Safety Evaluation Could Be Improved

Training for technical reviewers and project managers that is focused on 

writing the safety evaluation could be improved. Such training provided 

simultaneously to technical reviewers and project managers could help 

address writing issues observed by NRC staff. Specifically, it could help to: 

3⁄4 ensure that staff have a common understanding of the safety 

evaluation’s purpose, including the degree to which it should include a 

specific amount of technical information and independent analysis to 

help the reader understand why NRC concluded that the licensee’s 

application is acceptable; and 

3⁄4 bring consistency to the various writing styles developed by the 

separate engineering branches and individual project managers. 

Concerns about safety evaluation quality is not a new issue to the agency 

and, to its credit, the agency has taken this issue seriously. According to 

project managers, the agency instituted a safety evaluation quality initiative in 

the past. However, one of the project managers commented that writing and 

formatting problems were not addressed. 

In NRR, the technical branches and the Division of Operating Reactor 

Licensing have used mentoring partnerships between junior and senior staff 

to help address quality issues. For example, some engineering branches 

have an informal peer review process whereby the work of newer staff is 
Audit of NRC’s Power Uprate Program 

20

reviewed by more experienced staff. A similar arrangement appears to exist 

among project managers. Yet, there may be difficulty in making such 

arrangements given the turnover among staff in NRR. 

In October 2006, NRR issued Office Instruction ADM-504, which outlined a 

qualification program for NRR staff. The office instruction presents positionspecific requirements and tasks. For example, it provides a specific task for 

technical reviewers to write a safety evaluation according to the guidance in 

LIC-101. However, LIC-101 provides guidance primarily on the format and 

structure of the safety evaluation, but does not demonstrate how to write a 

quality safety evaluation. Furthermore, of the 12 study activities and 15 onthe-job training activities outlined for a project manager’s qualification in ADM504, none of them focus on the important activity of writing or compiling the 

safety evaluation. 

The lack of training that is focused specifically on writing the safety evaluation 

prompted one project manager to assert that a course for writing safety 

evaluations would be very helpful. The project manager pointed out that this 

was particularly important because writing safety evaluations is one of the 

main things that NRR does. 

Implications for Uprate Stakeholders and Inspections 

If not corrected, shortcomings in inspector awareness of recommended areas 

for inspections and the writing quality in power uprate safety evaluations 

could have significant implications for internal and external uprate 

stakeholders. 

First, inspectors risk developing their inspection samples and plans without 

knowledge of recommended inspection areas and regulatory commitments in 

the safety evaluation. Therefore, it remains possible that a suggested 

inspection will not be performed or may be overlooked. Several inspectors 

expressed the need for NRR to highlight important items in the safety 

evaluation or otherwise coordinate with regional and resident inspectors. 

Among other things, this would help inspectors understand what NRR is 

asking, whether it needs to be done, the impact on inspection resources, and 

whether any expert support would be needed to conduct the inspection. 

Second, shortcomings in the writing quality of safety evaluation inputs may 

hamper a stakeholder’s ability to comprehend NRC’s basis for approving a 

power uprate application. Project managers were sometimes confused by the 

written evaluations received from technical reviewers. Furthermore, an 
Audit of NRC’s Power Uprate Program 

21

inconsistent approach among technical reviewers and project managers could 

lead to inconsistent review results. Without training for both reviewers and 

project managers that is specifically focused on writing or contributing to the 

safety evaluation, such inconsistencies are likely to continue and may be 

institutionalized through the mentoring of junior staff by their more 

experienced colleagues. Ultimately, confusing and inconsistent power uprate 

safety evaluations may hinder the inspectors’ and public’s comprehension of 

the NRC’s review of power uprate applications. 

RECOMMENDATIONS:

OIG recommends that the Executive Director for Operations: 

4. Develop training for technical reviewers and project managers that is 

specifically focused on writing or contributing to a safety evaluation. 

5. Implement internal controls to ensure communication of the safety 

evaluation, highlighting the recommended areas of inspection and 

regulatory commitments sections to the regions and resident inspectors. 
Audit of NRC’s Power Uprate Program 

22

C. Power Uprate Coordinating Function Could Be Strengthened 

Effective programs should have certain elements to ensure program efficiencies, yet 

the power uprate coordinating function could be strengthened to ensure that the 

program includes these elements. For example, the power uprate program does not 

have a formalized mission statement, defined roles and responsibilities, and 

adequate communication and knowledge management tools. A key reason for 

these shortcomings is that the agency lacks an authoritative coordinating entity to 

oversee the entire program. As a result, power uprate internal stakeholders are left 

without clear direction and oversight. 

Effective Programs Should Have Certain Elements 

An effective program should embody certain elements to ensure program 

success and efficiencies. According to Federal guidelines13 on approving 

accountability and effectiveness of Federal programs and operations, 

programs must have the following elements to ensure long-term success: 

3⁄4 Clearly defined policies and procedures in place to help ensure that 

program objectives are met; 

3⁄4 Defined roles, responsibilities, and appropriate delegations of authority 

throughout the program; and 

3⁄4 Well-defined documentation processes. 

In 2002, NRC staff developed the Effectiveness and Efficiency Plan for Power 

Uprates,14 which identified several areas where the power uprate application 

and review process can be improved. In the plan, the agency recognizes that 

strong management oversight is expected to result in early identification and 

resolution of problems, and lead to more efficient power uprate reviews and a 

reduction of unnecessary regulatory burden associated with delays. 

 

13 The Federal guideline discussed is OMB (Office of Management and Budget) Circular No. A-123, 

“Management’s Responsibility for Internal Control,” effective Fiscal Year 2006. 

14 By Staff Requirements Memorandum (SRM) dated February 8, 2002, the staff was directed to provide the 

Commission with a plan for improving the effectiveness and efficiency of power uprate reviews. The staff met 

the Commission’s direction by developing the Effectiveness and Efficiency Plan for Power Uprates (SECY-02-

0115) dated June 27, 2002. 
Audit of NRC’s Power Uprate Program 

23

Furthermore, NRR staff have developed a Communication Plan for the Power 

Uprate Program outlining the staff’s communication strategies for power 

uprates, specifically: 

3⁄4 Key messages and other information related to power uprates are 

communicated to all stakeholders; and 

3⁄4 Information is communicated clearly, accurately, and in a timely 

manner. 

Power Uprate Program is Missing Some Key Elements to Ensure 

Program Success 

The power uprate program is missing some of the key elements that could 

help ensure program success. For example, the uprate program does not 

have a formalized mission statement, defined roles and responsibilities for 

headquarters and regional points of contact, and adequate communication 

and knowledge management tools. 

Mission, Roles, and Responsibilities Not Defined

The power uprate program does not have a formalized mission statement. 

While the Generic Communication and Power Uprate Branch (the Branch) 

has a functional statement posted to its NRC intranet Web page, it is a 

generic statement of responsibilities for the entire Branch. It states that the 

Branch “provides project management for programs, projects, processes, and 

other tasks that are beyond the scope of plant-specific licensing issues.” In 

addition to power uprates, the Branch coordinates the Generic Safety Issues 

Program; the 10 CFR 50.109 Backfit Process; the Operability Determination 

Process; and NRR coordination of the NRR Pandemic Response Plan. The 

statement does not offer much insight into the possible coordinating or 

oversight functions of the Branch with regard to power uprates. 

Roles and responsibilities for the Branch have not been formally identified 

and communicated. Staff contends that the Branch is the programmatic lead 

for power uprates, providing oversight and guidance for anything having to do 

with power uprates, yet this has not been communicated to all stakeholders. 

For the public and licensees, the “Power Uprates” page on NRC's Web site15

makes no mention of a programmatic lead for the power uprate program. Nor 

 

15 Web site last updated as of February 28, 2008. 
Audit of NRC’s Power Uprate Program 

24

has the Branch adequately communicated its roles and responsibilities to 

NRC staff. In fact, a number of NRC staff are unaware that the Branch exists. 

Those staff who are aware of the Branch have widely varying understandings 

of the Branch’s roles and responsibilities. For example, some project 

managers believe the role of the Branch is to be the focal point for all power 

uprates while ensuring consistency between reviews, whereas others see the 

Branch as a scheduler with the role of tracking application review hours. 

Some of the roles for the Branch that internal stakeholders desired or already 

believed to exist, included: 

3⁄4 monitoring all power uprate activities, 

3⁄4 providing formal communication guidance on how to communicate with 

the power uprate branch, 

3⁄4 helping project managers communicate with other NRR branches 

during the application process, 

3⁄4 assisting staff with questions on completing the amendment process, 

3⁄4 communicating lessons learned on power uprate issues, and 

3⁄4 documenting and disseminating power uprate changes. 

Of note, some of these functions are those that the Branch already performs 

or has stated an intention to perform, but has not clearly defined and 

communicated throughout the agency. 

Prior to OIG’s review, most of the regional offices had not identified power 

uprate program leads and formally defined and communicated their roles and 

responsibilities. NRR officials stated that each region has a designated 

power uprate lead identified on regional Web sites, yet a technical inspection 

contact was noted on only one regional Web site. Furthermore, three of the 

four regions acknowledged that, prior to OIG's review, they did not have a 

formal power uprate point of contact. OIG noted that a manager in one of the 

regions identified a contact for power uprates, yet the staff member appointed 

was unaware that they were the point of contact. The region with a technical 

point of contact stated that they provide coordination and oversight for power 

uprates, educate staff on power uprates, and provide counsel to resident 

inspectors. Other regions, however, consider their newly identified points of 

contact’s roles and responsibilities as informal or non-structured. 
Audit of NRC’s Power Uprate Program 

25

Communication and Knowledge Management Tools Not Adequate

Project managers do not have adequate communication and knowledge 

management tools to support the variety of functions and breadth of 

knowledge for which they have responsibility. Currently, NRR project 

managers share information with each other largely on an ad hoc basis. 

Managing information and knowledge among NRR’s 48 different project 

managers is a critically important function. Many external and internal power 

uprate stakeholders are dependent on the project manager as a conduit of 

information. For example, the project manager is the licensee's primary point 

of contact with NRC headquarters. Technical reviewers in NRR funnel their 

questions and requests for additional information from the licensee through 

the project manager. Similarly, the project manager serves as headquarters’ 

primary point of contact for region staff, who generally become aware of 

issues being reviewed by NRR's technical reviewers through the project 

manager. Furthermore, the perceived effectiveness of a project manager can 

be tied to his or her experience or knowledge. A resident inspector located at 

an uprated plant, for example, noted differences in the quality of the 

communications and coordination effort provided by different project 

managers. 

Currently, project managers engage in information sharing and knowledge 

management by word of mouth. This practice is dependent on project 

managers turning to their peers to fill gaps in their own knowledge and 

experience. For less experienced project managers, or those who are 

assigned a plant for which they have little knowledge, these project managers 

have the challenge of mastering a wide variety of licensing and technical 

issues associated with a given plant. Some project managers acknowledged 

that the current information sharing and knowledge management process is 

not very structured, and that less experienced project managers are at a 

disadvantage in obtaining this information. 

Power Uprate Program Lacks an Authoritative Coordinating Entity

The power uprate program is missing some key program elements, in part, 

because the agency does not have an authoritative coordinating entity to 

oversee all aspects of power uprate activities. In 2002, the Executive Director 

for Operations wrote to the Commission that NRR adopted enhanced 

management oversight by assigning a Senior Executive Service manager to 

be responsible for all aspects of the power uprate licensing process. Instead, 

the agency today has a lead project manager for power uprates located within 
Audit of NRC’s Power Uprate Program 

26

the Generic Communication and Power Uprate Branch in NRR. The Branch 

provides power uprate updates to NRC management, and claims to provide 

power uprate review guidance to project managers with plants that have 

applied for a power uprate, as well as direction and support to staff reviewing 

power uprate applications. However, the Branch does not direct program 

activities for all aspects of the power uprate licensing process. For example, 

the Branch does not operate in an authoritative capacity to proactively provide 

direction and support to staff contributing to power uprate reviews, which was 

corroborated by project managers and staff. 

In providing a strengthened power uprate coordinating entity, the agency 

could better manage, oversee, and facilitate improvements in the entire power 

uprate program. This would help ensure that uprate policies and procedures 

are in place, roles and responsibilities are defined, and issues communicated, 

and help ensure that staff has access to adequate documentation and 

knowledge management tools. 

Program Stakeholders Are Left Without Direction and Oversight

Without an authoritative coordinating entity, power uprate program internal 

stakeholders are left without clear direction and oversight. NRR branches are 

hierarchically organized into separate directorates and divisions, with no 

authoritative coordinating entity, other than the NRR Director, to attend to the 

details of the power uprate program. Appendix C illustrates the branches 

involved in a recent power uprate safety evaluation published by the agency 

in March 2007. 

NRR’s organizational arrangement requires clarification of the roles and 

responsibilities of the various program participants. It is quite possible that 

the Generic Communication and Power Uprate Branch is serving the purpose 

it was intended by agency managers. Yet, there are inconsistent 

understandings among the staff with regard to the purpose and role of the 

Branch. In any case, it does not appear that the Branch has a managerial or 

directional role for promulgating policies to coordinate efforts among different 

power uprate stakeholders. 

Without an authoritative coordinating entity, NRR staff are left to troubleshoot 

power uprate-related organizational and managerial challenges that they 

encounter. This is evident in the way that project managers share information 

on an ad hoc basis, and has the effect of leaving knowledge management to 
Audit of NRC’s Power Uprate Program 

27

chance. An authoritative coordinating entity would improve the staff’s 

efficiency and effectiveness in other areas as well. For example, it could 

have: 

3⁄4 ensured consistency in the staff’s interpretation and use of IP 71004; 

3⁄4 ensured implementation of a tool or documenting procedure that could 

have helped NRC staff and the public find power uprate-related 

inspection results with ease; 

3⁄4 provided enhanced direction and training to staff to address the quality 

of written inputs to the safety evaluation; and 

3⁄4 provided management controls to ensure that key results of the safety 

evaluation were communicated to all power uprate stakeholders. 

Management attention to the program weaknesses presented in this report 

could help minimize future challenges to agency managers and staff. 

RECOMMENDATIONS:

OIG recommends that the Executive Director for Operations: 

6. Strengthen and communicate the coordinating authority of the Power 

Uprate and Generic Communications Branch or assign a coordinating 

authority to be responsible for all aspects of power uprate activities. 

7. Identify and communicate roles and responsibilities for headquarters and 

regional points of contact for power uprates. 

8. Develop a tool for project managers to share and record information, 

monitor trends, and capture best practices and lessons learned. 
Audit of NRC’s Power Uprate Program 

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IV. CONSOLIDATED LIST OF RECOMMENDATIONS 

OIG recommends that the Executive Director for Operations: 

1. Revise IP 71004 to provide more specificity with regard to the use of the 

inspection procedure. 

2. Provide cross-references from baseline and other inspection procedures 

that are called for in IP 71004. 

3. Document or index cumulative IP 71004 and other uprate-related 

inspection activities in a centralized location or in an easily retrievable way 

so that internal and external stakeholders can easily find the results. 

4. Develop training for technical reviewers and project managers that is 

specifically focused on writing or contributing to a safety evaluation. 

5. Implement internal controls to ensure communication of the safety 

evaluation, highlighting the recommended areas of inspection and 

regulatory commitments sections to the regions and resident inspectors. 

6. Strengthen and communicate the coordinating authority of the Power 

Uprate and Generic Communications Branch or assign a coordinating 

authority to be responsible for all aspects of power uprate activities. 

7. Identify and communicate roles and responsibilities for headquarters and 

regional points of contact for power uprates. 

8. Develop a tool for project managers to share and record information, 

monitor trends, and capture best practices and lessons learned. 
Audit of NRC’s Power Uprate Program 

29

Appendix A 

SCOPE AND METHODOLOGY 

The overall objective of this audit was to examine the process for reviewing 

and approving power uprate amendment applications. However, this audit 

did not examine the technical content of the staff’s final safety evaluations for 

power uprates. Given that extended power uprates require significant plant 

modifications, OIG focused the bulk of its audit on extended power uprates. 

To address the audit objective, OIG reviewed power uprate Inspection 

Procedure 71004, the development and distribution of the safety evaluation, 

and the extent to which the power uprate activities have been coordinated to 

ensure program efficiencies. Additionally, OIG analyzed program documents, 

and reviewed relevant management controls, related documentation from 

internal and external sources, and Federal guidance. Some of the key 

documents reviewed include: 

3⁄4 Code of Federal Regulations, Title 10, Part 50 

3⁄4 NRR Communication Plan for the Power Uprate Program

3⁄4 NRR Division of Operating Reactor Licensing Handbook, Review 

Standard for Extended Power Uprates (RS-001), and other NRR 

guidance 

3⁄4 Inspection Manual Chapter 2515, Appendix C, Special and Infrequently 

Performed Inspections

3⁄4 Inspection Procedure 71004, Power Uprate

3⁄4 NUREG 0800, Standard Review Plan for the Review of Safety Analysis 

Reports for Nuclear Power Plants 

3⁄4 Management Directive 6.8, Lessons-Learned Program 

3⁄4 Quarterly Inspection Plans for each plant that had received or applied 

for an extended power uprate from up to 6 quarters before a power 

uprate application was approved 

3⁄4 Inspection Reports for each plant that had received or applied for an 

extended power uprate from 1 to 2 years before the plant submitted its 

power uprate application until mid-2007 

Auditors also conducted interviews with more than 75 agency and industry 

individuals including NRC senior managers and staff from headquarters, the 

regions, and the plants; OGC and Advisory Committee on Reactor 

Safeguards (ACRS); and industry representatives and plant personnel. 

OIG conducted this audit between March 2007 and October 2007 in 

accordance with generally accepted Government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, 
Audit of NRC’s Power Uprate Program 

30

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based 

on our audit objectives. 

Major contributors to this report are Sherri Miotla, Team Leader; RK Wild, 

Audit Manager; Dan Livermore, Technical Advisor; Eric Rivera, Senior 

Auditor; and Andrea Ferkile, Management Analyst. 
Audit of NRC’s Power Uprate Program 

31

Appendix B 

NRC LETTERS TO PUBLIC EMPHASIZING IMPORTANCE OF IP 71004 

3⁄4 Letter from the NRC Executive Director for Operations to the Honorable 

Patrick Leahy of the United States Senate, February 20, 2004 

3⁄4 Letters from the NRC Executive Director for Operations to the Honorable 

Patrick Leahy and the Honorable James Jeffords of the United States 

Senate, March 29, 2004 

3⁄4 Letter from the NRC Chairman to Michael Dworkin, Chairman of the 

Vermont Public Service Board, May 4, 2004 

3⁄4 Letter from the Director, Project Directorate I, Division of Licensing Project 

Management in NRR to Mr. Theodore Lewis, member of The Town of 

Wendell Selectboard, May 20, 2004 

3⁄4 Letter from the Director, Project Directorate I, Division of Licensing Project 

Management in NRR to Ms. Mariel Kinsey, May 27, 2004 

3⁄4 Letter from the Director of NRR to Mr. David Lochbaum, Nuclear Safety 

Engineer, Union of Concerned Scientists, July 12, 2004 

3⁄4 Letters from the NRC Executive Director for Operations to The Honorable 

Christopher Donelan, the Commonwealth of Massachusetts House of 

Representatives; The Honorable Stan Rosenberg, Commonwealth of 

Massachusetts Senate; The Honorable Andrea Nuciforo, Commonwealth 

of Massachusetts Senate; The Honorable Denis Guyer, Commonwealth of 

Massachusetts House of Representatives; The Honorable Stephen Kulik, 

Commonwealth of Massachusetts House of Representatives; and The 

Honorable Daniel Bosley, Commonwealth of Massachusetts House of 

Representatives, 

April 27, 2006 

3⁄4 Letter from the NRC Chairman to Congressman Maurice Hinchey, 

February 15, 2007 

3⁄4 Letter from the NRC Chairman to the Honorable Eliot Spitzer, Governor of 

New York, June 28, 2007 

3⁄4 Letter from the Director of NRR to Mr. Ned Sullivan, President of Scenic 

Hudson, Inc., July 2, 2007 
Audit of NRC’s Power Uprate Program 

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[Page intentionally left blank.] 
Audit of NRC’s Power Uprate Program 

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Appendix C 

NRR ORGANIZATION CHART 

The chart on the following page depicts NRR’s divisional and branch 

organization as of November 28, 2007. Note that the Generic 

Communication and Power Uprate Branch is designated in blue on the 

chart. The organizations designated in yellow on the chart were those that 

concurred on one of the agency’s recent power uprate safety evaluations; 

specifically, for Browns Ferry Unit 1 in March 2007. Three additional 

branches concurred on the safety evaluation that are not shown on the 

current NRR organizational chart in the same name format.16 They are: 

3⁄4 SBWB, the Boiling Water Reactor Systems Branch; 

3⁄4 IHPB, the Health Physics Branch; and 

3⁄4 EEMB, the Engineering Mechanics Branch. 

The above illustrates that organizational consolidations and name 

changes have occurred since NRR’s Review Standard for Extended 

Power Uprates (RS-001) was published in December 2003. In fact, 

RS-001 has not been revised to reflect any of NRR’s organizational 

changes since that time.17 Of the eight branches specified for having 

review responsibility in RS-001, only one branch appears to exist in the 

same form within the NRR organization today. 

 

16 The applicable region and resident inspectors are also stakeholders on a given power uprate. 

However, NRC concurrence process for the Safety Evaluation does not currently include these 

stakeholders. 

17 An internal NRR February 2006 memo titled “Power Uprate Review Guidance” provides a table 

showing anticipated number of hours for a power uprate review arranged by technical branch, based on 

NRR’s organization at that time. 
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Appendix D 

FORMAL AGENCY COMMENTS 
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Appendix E 

OIG ANALYSIS OF AGENCY COMMENTS 

OIG met with managers from the Office of Nuclear Reactor Regulation on 

February 6, 2008, and again during an exit meeting on February 22, 2008, 

to address agency concerns with a draft of this report. OIG modified the 

report as appropriate in response to comments made by agency officials. 

On March 24, 2008, the Executive Director for Operations provided a 

formal response to this report, in which the agency generally agrees with 

the report findings and six of the eight recommendations. The agency 

commented on the following two recommendations: 

3⁄4 Recommendation 2: Provide cross-references from baseline and 

other inspection procedures that are called for in IP 71004. 

3⁄4 Recommendation 4: Develop training for technical reviewers and 

project managers that is specifically focused on writing or 

contributing to a safety evaluation. 

Below is OIG’s analysis of the agency’s formal written comments. 

NRC Comments 

Regarding recommendation 2, revisions to the baseline and other 

inspection procedures are not needed to cross-reference back to IP 

71004. Planned enhancements to IP 71004 coupled with strengthened 

coordination of all aspects of power uprate activities (Recommendation 6), 

will enhance coordination of power uprate-related inspection activities. 

OIG Response 

The Office of the Inspector General (OIG) agrees that revising IP 71004 and 

strengthening the coordinating aspect of power uprate activities should enhance 

power uprate-related inspection efforts. However, the purpose of this 

recommendation is to increase awareness of IP 71004 among NRC inspectors, 

particularly those in the regions and located at the plants. Based on the analysis 

provided in this report, OIG concludes that providing cross-references from 

baseline and other inspection procedures that are called for in IP 71004 would 

significantly enhance awareness of the procedure among the NRC inspector 

community. 

Recommendation 4 pertains to training on writing a safety evaluation. 

Training for this task already exists, but the staff believes this training can 

be enhanced. 
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OIG Response 

In the report, OIG acknowledged that the agency has some training available in 

the form of mentoring partnerships and a qualification program for NRR staff, but 

that this training does not focus specifically on writing the safety evaluation. 

Therefore, OIG agrees with the agency that this training can be enhanced, and the 

recommendation is provided to the agency as a way to enhance the training by 

addressing the shortcomings specifically identified by OIG in its finding.