POLICY ISSUE

(Information)

June 27, 2002 SECY-02-0115

FOR: The Commissioners

FROM: William D. Travers

Executive Director for Operations /RA/

SUBJECT: EFFECTIVENESS AND EFFICIENCY PLAN FOR POWER UPRATES

PURPOSE:

To provide the Commission an integrated plan for improving the effectiveness and efficiency of

power uprate reviews. This paper meets the Commission’s direction in Staff Requirements

Memorandum (SRM) M020129 dated February 8, 2002.

SUMMARY:

The staff has identified several areas where the effectiveness and efficiency of power uprate

application and review processes can be improved and has formulated a plan to achieve these

improvements. In formulating the plan, the staff considered its experience with license renewal

processes, lessons learned from previous power uprate reviews, and feedback from internal

and external stakeholders. The plan will include: (1) enhanced planning and scheduling tools,

(2) more effective utilization of resources, (3) enhanced techniques for managing the power

uprate program, (4) assessments of past reviews and lessons learned, (5) efforts to further

standardize power uprate processes, including an assessment of the scope of the current

review methodology, and (6) a communication plan for the power uprate program. In its 

Contact:
 - 2 -

Mohammed A. Shuaibi, NRR

(301) 415-2859
 - 3 -

letters on recent power uprate reviews, the Advisory Committee on Reactor Safeguards

(ACRS) highlighted certain areas where additional improvements could be made. The staff will

consider the ACRS comments as part of the assessment of past reviews and lessons learned

to date. The staff will also assess the current baseline review scope for extended power

uprates (EPUs). The staff has been actively working on many of the elements of the plan and

has targeted completion by the end of calendar year 2002. The effectiveness and efficiency

plan is consistent with the Agency’s four performance goals of maintaining safety, improving

internal effectiveness and efficiency, increasing public confidence, and reducing unnecessary

regulatory burden.

BACKGROUND:

By an SRM dated May 24, 2001, the Commission directed the staff to assign power uprates a

high priority and conduct power uprate reviews in the most effective and efficient manner

practical. The Commission also directed the staff to take steps to better understand licensees’

intentions for submitting power uprate applications in order to facilitate planning. The

Commission further stated that the staff, in consultation with stakeholders, should identify

potential areas for improvement in current power uprate processes in order to ensure that the

processes do not cause unnecessary delays. In addition, the Commission directed the staff to

keep the Commission informed of significant matters related to power uprates, track the status

of power uprate activities in the Chairman’s Tasking Memorandum (CTM), and promptly inform

the Commission of any delays in the staff’s power uprate activities.

In SECY-01-0124, dated July 9, 2001, the staff provided the Commission a status of power

uprate reviews and the staff’s plans for implementing the directions in the May 24, 2001, SRM. 

The staff has completed many of the initiatives discussed in SECY-01-0124. The staff has

(1) launched an internet Web site (http://www.nrc.gov/reactors/operating/licensing/poweruprates.html) to provide internal and external stakeholders information related to power uprates,

(2) conducted two public workshops (one for MUR power uprates and one for EPUs) to discuss

ways to improve power uprate application and review processes, (3) conducted a power uprate

session at the NRC’s 2002 Regulatory Information Conference to provide information on power

uprate programs at the NRC, nuclear steam supply vendors, and domestic and foreign plants,

(4) issued Regulatory Issue Summary 2002-03, “Guidance on the Content of Measurement

Uncertainty Recapture Power Uprate Applications,” dated January 31, 2002, (5) conducted

briefings to the ACRS on several EPU reviews, (6) conducted surveys in June 2001 and

January 2002 of all operating reactor licensees to obtain information regarding the number,

type (i.e., MUR power uprate, stretch power uprate, and EPU), and timing of future power

uprate applications, and informed the Commission of the results of these surveys, (7) initiated

efforts to develop a review standard for EPUs to increase the standardization and effectiveness

of EPU reviews, (8) initiated efforts to monitor, trend timeliness and resource expenditures, and

report the progress of power uprate reviews, (9) implemented the use of status reports to track

individual power uprate reviews, and (10) kept the Commission informed of the status of power

uprate reviews through updates to the CTM and other means (e.g., a memorandum to the

Commission dated March 4, 2002).
 - 4 -

DISCUSSION:

The staff is continuing its efforts to improve power uprate application and review processes. 

The staff has identified several areas where the effectiveness and efficiency of power uprate

application and review processes can be improved and has formulated a plan to achieve these

improvements. In formulating the plan, the staff considered its experience with license renewal

processes, lessons learned from previous power uprate reviews, and feedback from internal

and external stakeholders. The staff’s plan to enhance the effectiveness and efficiency of

power uprate processes includes: (1) implementing tools to plan, schedule, and forecast

resource needs for power uprate reviews, (2) to the extent possible, relying on the same set of

experienced reviewers to perform power uprate reviews, which will promote better

communication and coordination among reviewers, provide an experience base more specific to

power uprates, and improve the consistency of power uprate reviews, (3) implementing

enhanced techniques for monitoring, trending timeliness and resource expenditures, and

reporting the progress of individual power uprate reviews and the overall power uprate program,

(4) conducting assessments of past reviews, requests for additional information, the

Maine Yankee Lessons Learned Task Group Report, internal and external stakeholder

feedback, and ACRS letters on past power uprate reviews, (5) completing the development of a

review standard for EPUs that will better define the scope and depth of these reviews, and

(6) developing a formal communication plan to ensure that the staff’s goals and efforts to

achieve them are communicated with internal and external stakeholders. The staff will also

consider ACRS comments on recent power uprate reviews as part of the assessment of past

reviews and lessons learned, and as part of the development of the review standard.

The effectiveness and efficiency plan is consistent with the Agency’s four performance goals

of maintaining safety, increasing public confidence, improving internal effectiveness and

efficiency, and reducing unnecessary regulatory burden. The staff has been actively working

on many of the elements of the plan and has targeted completion of them by the end of

calendar year 2002. The staff will inform the Commission of any changes to this schedule. 

The attachment to this paper includes a detailed discussion of each of the elements of the

plan. In the FY 2004 - FY 2005 Budget Request, NRR assumed efficiencies in processing

licensing actions of 6 percent in FY 2004 and 4 percent in FY 2005. The staff’s goal for power

uprates is to exceed these efficiency gains. However, achieving this goal will depend on the

results of the assessment of power uprate processes and whether the scope and depth of

reviews will be changed. In implementing the plan, the staff will ensure that safety remains

paramount and quality of the staff’s products will continue at a high level. Efficiency will not be

achieved at the expense of quality.

RESOURCES:

Resources to develop and implement the effectiveness and efficiency plan discussed in this

paper are included in the FY 2002 and FY 2003 budgets. No additional resources will be

required.
 - 5 -

COORDINATION:

The Office of the Chief Financial Officer has reviewed this paper for resource implications and

has no objections. The Office of the General Counsel has reviewed this paper and has no

legal objection.

/RA/

William D. Travers

Executive Director

 for Operations

Attachment: Effectiveness and Efficiency Plan

 for Power Uprates
 - 4 -

COORDINATION:

The Office of the Chief Financial Officer has reviewed this paper for resource implications and

has no objections. The Office of the General Counsel has reviewed this paper and has no

legal objection.

/RA/

William D. Travers

Executive Director

 for Operations

Attachment: Effectiveness and Efficiency Plan

 for Power Uprates

ADAMS Accession No. ML021570557 *Previously Concurred

OFFICE PDIII-1/PM PDIII-1/LA TECH EDITOR* PDIII-1/SC PDIII/D DLPM/D*

NAME MShuaibi RBouling PKleene LRaghavan SBajwa JZwolinski

DATE 6/14/02 6/14/02 06/05/02 6/14/02 6/14/02 06/14/02

OFFICE OCFO* OGC* NRR/ADPT* NRR/D* EDO

NAME JMurphy JMoore BSheron SCollins WTravers

DATE 06/11/02 06/11/02 6/14/02 6/14/02 06/27/02

OFFICIAL RECORD COPY
EFFECTIVENESS AND EFFICIENCY PLAN FOR POWER UPRATES

Introduction

By Staff Requirements Memorandum (SRM) M020129 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 has developed such a plan in its continuing efforts to

improve power uprate application and review processes.

Analysis of Historical Data

The first MUR power uprate was approved for Comanche Peak Unit 2 in September 1999. 

The staff’s review of this MUR power uprate application required approximately 0.9 FTE and

9 months to complete. Since completing its review of the Comanche Peak Unit 2 MUR power

uprate application, the staff has completed reviews of 10 MUR power uprate applications

covering 17 units. The staff analyzed the duration and resource expenditure data for these

reviews and determined that on average, the review of MUR power uprate applications require

about 0.8 FTE and 8 months to complete.

The staff has been reviewing stretch power uprate applications since the 1970s and has

completed reviews of stretch power uprate applications for over 50 units. The review process

for stretch power uprates is well established. Reviews of recent stretch power uprate

applications have required approximately 1.1 FTE and 9 to 14 months to complete.

The first EPU for a boiling-water reactor (BWR) plant was approved for the Monticello plant in

September 1998. The review of this EPU application required approximately 1.9 FTE and

26 months to complete. Soon after the Monticello EPU license amendment was issued, the

staff issued an EPU for Hatch Units 1 and 2 in October 1998. The review for the Hatch EPU

application required approximately 2.1 FTE and 14 months to complete. More recently, the

staff has completed the review of first-of-a-kind EPU applications for much higher increases in

power for Duane Arnold, Dresden Units 2 and 3, Quad Cities Units 1 and 2, Clinton, and

Brunswick Units 1 and 2. The reviews of these EPU applications required approximately

2.2 FTE and were completed within 12 months. Over time, the duration of reviews for BWR

EPU applications has been reduced by more than 50 percent by increasing the number of

technical review staff and management involved in these high priority licensing actions.

The first EPU for a pressurized-water reactor plant was approved for Arkansas Nuclear One

Unit 2 in April 2002. The staff’s review of this EPU application required approximately 3.2 FTE

and 16 months to complete.

Plan for Further Improvement

The staff has completed several initiatives to improve power uprate processes consistent with

the Agency’s four performance goals (i.e., maintaining safety, increasing public confidence,

improving internal effectiveness and efficiency, and reducing unnecessary regulatory burden). 

The staff has identified additional areas where the effectiveness and efficiency of power uprate

application and review processes can be further improved and has formulated a plan to

achieve these improvements. In formulating the plan, the staff considered insights gained

from 

ATTACHMENT
 - 2 -

experience with license renewal processes, lessons learned from previous power uprate

reviews, and feedback received from internal and external stakeholders. The staff is continually

assessing ways to improve power uprate processes and will continue to seek input from internal

and external stakeholders on ways to improve these processes. If additional improvements are

identified during the staff’s ongoing efforts, the plan will be updated to include them. A

discussion of each of the elements of the plan is provided below. 

(1) Planning and Scheduling Tools

The staff will continue to survey licensees on a semiannual basis regarding their plans to submit

power uprate applications. This information will enable the staff to plan ahead for future work in

this area and thereby prevent delays in its reviews.

The staff is currently developing detailed models of power uprate processes. The models will

utilize the results of the surveys to forecast resource needs and generate schedules for ongoing

and future power uprate activities. The models will be integrated into the Office of Nuclear

Reactor Regulation's (NRR’s) centralized work planning activities. The staff will use these

models to ensure that resources are available to promptly start the reviews upon receipt of the

applications and complete the reviews on schedule. Completion of the reviews on schedule

could reduce unnecessary regulatory burden by reducing costs associated with delays in

implementing the power uprates. The staff will also use these models to generate detailed

schedules with appropriate milestones to allow enhanced monitoring of the reviews and early

identification and resolution of problems. This is expected to reduce the duration of the reviews

and prevent unnecessary delays in schedules.

(2) Utilization of Resources

The staff has seen a decrease in resource expenditures when experienced reviewers are

repeatedly used. Therefore, the staff will continue to seek ways to plan work such that where

and when appropriate, experienced reviewers are involved in power uprate reviews. If less

experienced reviewers are assigned to these reviews, the staff will ensure that they are

appropriately trained to minimize any adverse impacts on schedules. Efforts will be made to

use the same set of experienced reviewers for power uprate reviews to make the reviews more

consistent, facilitate better communication and coordination among reviewers, and build an

experience base more specific to power uprates. 

The use of the same set of experienced reviewers should result in power uprate reviews that

are more consistent, complete, and thorough (i.e., reviews that are effective and maintain

safety). The use of the same set of reviewers will increase the reviewers' familiarity with power

uprate processes. Over time, this should reduce the level of effort and time required to

perform reviews of these applications (i.e., improve efficiency of the reviews). Reductions in

the staff’s review time could reduce costs associated with any delays in implementing the

power uprates (i.e., reduce unnecessary regulatory burden).
 - 3 -

(3) Monitoring, Trending, and Project Management

The staff has initiated efforts to (1) monitor, trend timeliness and resource expenditures, and

report progress of individual power uprate reviews and (2) evaluate the need for process

improvements. Periodic reports are currently being used to inform line managers of the status

of individual power uprate reviews, including milestones and potential problem areas, and to

ensure that appropriate management attention is being given to these reviews. This is

consistent with the Commission’s direction to assign power uprate reviews a high priority. The

staff will consider enhancements to the current methods of monitoring individual power uprate

reviews and will develop new methods as necessary to monitor and trend the progress of the

overall power uprate program. These methods will further assist management in its oversight

of the power uprate program.

Stronger management oversight is expected to result in early identification and resolution of

problems, thereby reducing the duration of the reviews and preventing unnecessary delays in

schedules. The staff expects this to lead to more efficient power uprate reviews and a

reduction of unnecessary regulatory burden associated with delays. 

(4) Assessment of Past Reviews and Lessons Learned

In its efforts to identify additional areas for improvement in power uprate processes, the staff

will perform assessments of recently completed EPU reviews, RAIs, the Maine Yankee Lessons

Learned Task Group Report, and feedback received from internal and external stakeholders. In

ACRS letters on recent power uprate reviews, the ACRS commented that although the depth

and breadth of the staff’s power uprate reviews have been adequate, several improvements

could be made. The ACRS recommended that the staff (1) develop a Standard Review Plan for

power uprates, (2) develop criteria for use in determining when independent calculations should

be performed by the staff, (3) improve the documentation of its reviews in safety evaluations,

(4) assess the need for more detailed thermal-hydraulic models, (5) conduct more detailed

reviews of risk information, and (6) review reload safety analyses for transitional core reloads. 

As part of this effort, the staff will consider the ACRS comments. Based on the results of these

assessments, the staff will reexamine the scope of review to determine if it is appropriate and

effective. The staff will also examine RAIs to identify areas where repeat RAIs are being

generated (i.e., where licensees have not been able to improve their applications based on past

experience). The staff will share the results of these efforts with internal and external

stakeholders and will use the findings in developing the review standard for EPUs. 

The effort described above will help the staff develop a review standard that is appropriately

focused and that effectively addresses areas important to maintaining safety. Based on the

results of this effort, the review scope for power uprates may be changed. The staff will utilize

the elements of the plan to ensure that reviews are conducted in a manner consistent with the

Agency’s four performance goals of maintaining safety, improving internal effectiveness and

efficiency, increasing public confidence, and reducing unnecessary regulatory burden.

(5) Standardization of Application and Review Processes

The staff issued guidance to licensees on the content of MUR power uprate applications in

RIS 2002-03. The staff will utilize RIS 2002-03 for guidance on the scope and depth of review

for these applications. Appropriate use of the RIS is expected to improve the effectiveness and

efficiency of MUR power uprate reviews while maintaining safety. The more focused review

scope provided in RIS 2002-03 and improvements in the efficiency of MUR power uprate
 - 4 -

reviews are expected to result in a reduction of unnecessary regulatory burden. In addition, to

ensure that the public was involved in development of this RIS, the staff conducted a public

workshop on the guidance in August 2001. The staff has received several applications for 

MUR power uprates that referenced RIS 2002-03. The staff will monitor the reviews of these

applications to assess the impact of RIS 2002-03 on the effectiveness and efficiency of

MUR power uprate reviews. 

The staff is currently reviewing two General Electric Nuclear Energy (GENE) topical reports for

power uprates. One is for MUR power uprates. The second is for EPUs that are achieved

without changing the reactor steam dome pressure. The staff’s reviews of these topical reports

are nearing completion. The staff believes that use of topical reports promotes higher levels of

standardization and quality of plant-specific submittals, and usually improves the effectiveness

and efficiency of the staff’s reviews.

In a recently proposed Commission Paper, the staff indicated that it will develop a review

standard for EPUs. The review standard will include (1) a clearer definition of the review scope,

(2) references to existing review criteria, and (3) template safety evaluations. The staff will

incorporate lessons learned during past reviews in the review standard to ensure that adequate

guidance is included on the scope and depth of review. The staff will consider comments

received to date from internal and external stakeholders, including the ACRS in the

development of the review standard. Development of the review standard will also (1) help

NRR retain institutional knowledge being lost to retirement, (2) provide guidance for the large

number of new hires expected over the next few years, (3) update the current Standard Review

Plan, and (4) establish a sustainable legacy of review criteria, methods, and procedures. This

review standard will be consistent with NRR’s vision for having a fully operational Centralized

Work Planning Center to plan, schedule, and monitor NRR work.

In addition to the above efforts by the staff, the Nuclear Energy Institute (NEI) has expressed

interest in developing white papers under the auspices of the Licensing Action Task Force to

provide guidance for licensees on preparing power uprate applications that is consistent with

the review standard initiative. The staff believes that these efforts could further improve the

efficiency of power uprate reviews by making licensee applications more complete. The staff is

supportive of NEI’s efforts and is planning to have further dialogue with NEI on these matters.

Development and use of the review standard for the scope and depth of reviews for power

uprate applications would ensure that consistent, complete, and thorough reviews are

performed and that such reviews are commensurate with the safety significance of the technical

areas under review. Therefore, development and use of such a review standard should

continue to maintain safety and improve the effectiveness of power uprate reviews. In addition,

during a March 19, 2002, workshop, external stakeholders indicated that a large number of

requests for additional information are being generated during staff reviews of power uprates. 

The participants expressed their desire for additional guidance on the scope and level of detail

that should be included in power uprate applications. This guidance would allow licensees to

provide the information needed for the staff’s reviews in their initial power uprate applications

and thereby improve the efficiency of the reviews. The review standard will better define the

review scope and review criteria for EPU applications. This will make EPU reviews more

transparent and should therefore increase public confidence. In developing the review

standard, the staff will provide an opportunity for public involvement through the public

comment process, which should also lead to increased public confidence. 
 - 5 -

(6) Communication Plan

The staff will develop a formal communication plan to ensure that its goals for the

power uprate program and the efforts to achieve these goals are communicated with internal

and external stakeholders. The staff will continue to use the NRC Web site, generic

communications (i.e., RISs, information notices, etc.), status reports, and workshops to

communicate with internal and external stakeholders. The staff will evaluate options for

enhancing communications. The communication plan will identify (1) internal and external

stakeholders, (2) the information needs of the various stakeholders, and (3) methods for

communicating the different types of information with the various stakeholders.