POLICY ISSUE

INFORMATION

June 14, 2002 SECY-02-0106

FOR: The Commissioners

FROM: William D. Travers

Executive Director for Operations

SUBJECT: REVIEW OF ACRS RECOMMENDATION FOR THE STAFF TO DEVELOP A

STANDARD REVIEW PLAN FOR POWER UPRATE REVIEWS 

PURPOSE:

To inform the Commission of the results of the staff’s review of the Advisory Committee on

Reactor Safeguards (ACRS) recommendation to develop a standard review plan (SRP) to

improve the effectiveness of power uprate reviews. This paper meets the Commission’s

direction in a Staff Requirements Memorandum (SRM) dated December 20, 2001.

SUMMARY:

The staff evaluated the ACRS recommendation to develop an SRP for improving the

effectiveness of power uprate reviews and concluded that a greater level of standardization will

improve the effectiveness of extended power uprate (EPU) reviews. The staff believes that

standardization can best be accomplished by developing a review standard that will

conceptually include (1) a clearer definition of the review scope, (2) references to existing

review criteria (i.e., applicable SRP sections, branch technical positions, Office of Nuclear

Reactor Regulation (NRR) office instructions, information notices, generic letters, bulletins,

NUREGs, industry standards, applicable generic topical reports, etc.), and (3) two template

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

reactor (PWR) plants). 

Contact: Mohammed A. Shuaibi, NRR

 (301) 415-2859
 - 2 -

This effort will be undertaken as part of and is consistent with NRR’s new, broader initiative to

develop review standards for a number of higher frequency licensing actions. The development

of review standards is a key initiative that will help the staff meet management’s expectations 

as described in the NRR Organizational Effectiveness Model. Another benefit of this effort will

be the validation of existing review criteria and the identification of areas where additional or

revised guidance may be necessary. If review criteria beyond those which currently exist are

determined to be necessary, or if existing criteria are found in need of revision, the staff will

initiate specific but separate efforts to develop or revise these criteria. The staff will also

develop a communication plan to introduce the new concept of review standards to NRR staff

and key internal and external stakeholders. These efforts will be integrated into NRR’s

centralized work planning processes. 

Based on the staff’s current assessment of the scope of this effort, the staff is targeting

issuance of a draft EPU review standard for interim use and public comment by the end of

calendar year 2002. The staff will seek endorsement from the Advisory Committee on Reactor

Safeguards (ACRS) and the Committee to Review Generic Requirements (CRGR) following

issuance of the draft review standard and prior to issuing the final review standard. 

BACKGROUND:

The staff has been conducting power uprate reviews since the 1970s and has completed over

80 such reviews. Most of these reviews have been for lower power increases (i.e., power

increases of up to 5 percent). The first EPU was approved for the Monticello plant in 1998. 

Since then, the staff has approved EPUs for Hatch Units 1 and 2, Duane Arnold, Dresden

Units 2 and 3, Quad Cities Units 1 and 2, Clinton, Arkansas Nuclear One Unit 2, and

Brunswick Units 1 and 2. The largest percentage increase in power approved by the staff via

a power uprate is 20 percent.

The staff evaluated the development of an SRP for power uprates in early 2001 and provided

the results of that evaluation to the Commission in SECY-01-0124, dated July 9, 2001. The

staff described its process for reviewing power uprates and discussed ongoing activities that

could affect this process. These activities included staff reviews of first-of-a-kind power uprate

applications in the range of 10 to 20 percent, staff evaluation of the power uprate review

process to make it more effective and efficient, and staff review of changes to the power

uprate application process proposed by General Electric Nuclear Energy (GENE) via its

Constant Pressure Power Uprate Topical Report. As a result of these activities, the staff

concluded that the process was still dynamic and could go through several changes. The staff

further concluded that developing an SRP section for power uprate reviews at that time would

have been premature and not cost effective. The staff indicated that it would reevaluate the

benefits of developing an SRP for power uprate reviews at a later date. 

During the ACRS reviews of recent EPUs, the ACRS indicated that the depth and breadth of

the staff’s reviews of these uprates was adequate; however, the staff’s documentation of its 

reviews in the safety evaluations should provide more details concerning the scope and focus

of the reviews as well as the criteria used to reach conclusions. The ACRS further indicated

that development of an SRP would help ensure adequate reviews by the staff of future power

uprate applications and would also clarify to the public and licensees the acceptance criteria

for power uprate applications.
 - 3 -

During the December 5, 2001, Commission meeting, the ACRS recommended that the staff

develop an SRP for power uprates. As a result, in an SRM dated December 20, 2001, the

Commission directed the staff to review this ACRS recommendation and inform

the Commission of the results of the review.

The staff has now completed its reviews of seven EPU applications (including first-of-a-kind

EPUs in the range of 10 to 20 percent), held a public workshop on lessons learned from recent

reviews of EPU applications, received input from NRC staff involved in the reviews as well as

external stakeholders on areas for improvement in the power uprate application and review

processes, and completed a large part of its review of the GENE Constant Pressure Power

Uprate Topical Report. Based on the feedback received, experience gained to date, and the

staff’s assessment that the power uprate process has stabilized, the staff has reevaluated the

benefits of developing review guidance for power uprates.

DISCUSSION:

The staff conducted a public workshop on March 19, 2002, to discuss lessons learned from

recent reviews of EPU applications and obtain feedback on issues that should be pursued by

the staff in process improvement efforts related to EPUs. The workshop included

presentations from the staff and industry on recent experience with EPUs. The workshop also

included breakout sessions during which groups of participants were formed and tasked with

identifying areas that need improvement and ideas for how to improve them. The groups

recommended that some form of guidance be developed for the scope and level of detail of

information that licensees should include in their EPU applications. However, it was suggested

that development of an SRP would be impractical as it would not be completed in time for the

EPUs expected in the near term.

The staff evaluated the EPU application and review processes in light of the ACRS

recommendation and stakeholder feedback received during the workshop and concluded that

increased standardization of the staff’s review processes could enhance the consistency,

quality, and timeliness of the reviews. The staff believes that standardization can best be

accomplished by developing a review standard that will conceptually include (1) a clearer

definition of the review scope, (2) references to existing review criteria (i.e., applicable

SRP sections, branch technical positions, NRR office instructions, information notices, generic

letters, bulletins, NUREGs, industry standards, applicable generic topical reports, etc.), and

(3) two template safety evaluations (one for BWR plants and one for PWR plants). Providing a

clearer definition of the review scope for EPUs will allow the staff to focus its review efforts on

the areas important to EPUs. Providing the staff with references to existing review criteria will

allow the staff to more easily identify the criteria applicable to EPUs and complete the reviews

more effectively and efficiently. References will be established by evaluating existing review

criteria, including the current SRP, to validate their applicability to and currency for EPU

reviews. If review criteria beyond those which currently exist are determined to be necessary,

or if existing review criteria need to be updated and/or modified, the staff will initiate specific

but separate efforts to develop and/or revise these criteria. In addition, results from ongoing

work by the Office of Nuclear Regulatory Research related to high burnup fuel and its

relationship to power uprates will be considered in the development of review criteria. The use

of template safety evaluations will reinforce the appropriate scope and depth of review and

provide the staff with the proper form and content of safety evaluations for EPUs. The staff

believes that this will also improve the documentation of the staff’s EPU reviews in the

associated safety evaluations.
 - 4 -

The staff’s effort described above will be undertaken as part of and is consistent with NRR’s

new, broader initiative to develop review standards for a number of higher frequency licensing

actions. In addition, the development of review standards is a key initiative that will help the

staff meet management’s expectations as described in the NRR Organizational Effectiveness

Model. The staff will develop a communication plan to introduce the new concept of review

standards to NRR staff and key internal and external stakeholders. These efforts will be

integrated into NRR’s centralized work planning processes. 

Based on the staff’s current assessment of the scope of this effort, the staff is targeting

issuance of a draft EPU review standard for interim use and public comment by the end of

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

staff believes that issuing the draft review standard for interim use during the public comment

period will address stakeholders’ feedback regarding the need for guidance. The staff will seek

endorsement from ACRS and CRGR following issuance of the draft review standard and prior

to issuing the final review standard. The staff will consider internal and external stakeholder

feedback in finalizing the review standard. In addition, inspection guidance will be developed

within the Reactor Oversight Process to address EPUs in a risk-informed manner. Resources

for the development of the review standard have been budgeted.

Development and use of the review standard will help the staff achieve its goal to conduct

power uprate reviews in the most effective and efficient manner while maintaining safety. This

is consistent with the Commission’s direction contained in SRM COMNJD-01-0001, dated

May 24, 2001. In addition, inspection guidance will be developed within the Reactor Oversight

Process to address EPUs in a risk-informed manner. The staff also expects to gain a greater

level of efficiency through the use of appropriate planning and scheduling tools. 

RESOURCES:

Resources to develop this review standard are included in the FY 2002 and FY 2003 budgets. 

No additional resources will be required.

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
 - 4 -

The staff’s effort described above will be undertaken as part of and is consistent with NRR’s

new, broader initiative to develop review standards for a number of higher frequency licensing

actions. In addition, the development of review standards is a key initiative that will help the

staff meet management’s expectations as described in the NRR Organizational Effectiveness

Model. The staff will develop a communication plan to introduce the new concept of review

standards to NRR staff and key internal and external stakeholders. These efforts will be

integrated into NRR’s centralized work planning processes. 

Based on the staff’s current assessment of the scope of this effort, the staff is targeting

issuance of a draft EPU review standard for interim use and public comment by the end of

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

staff believes that issuing the draft review standard for interim use during the public comment

period will address stakeholders’ feedback regarding the need for guidance. The staff will seek

endorsement from ACRS and CRGR following issuance of the draft review standard and prior

to issuing the final review standard. The staff will consider internal and external stakeholder

feedback in finalizing the review standard. In addition, inspection guidance will be developed

within the Reactor Oversight Process to address EPUs in a risk-informed manner. Resources

for the development of the review standard have been budgeted.

Development and use of the review standard will help the staff achieve its goal to conduct

power uprate reviews in the most effective and efficient manner while maintaining safety. This

is consistent with the Commission’s direction contained in SRM COMNJD-01-0001, dated

May 24, 2001. In addition, inspection guidance will be developed within the Reactor Oversight

Process to address EPUs in a risk-informed manner. The staff also expects to gain a greater

level of efficiency through the use of appropriate planning and scheduling tools. 

RESOURCES:

Resources to develop this review standard are included in the FY 2002 and FY 2003 budgets. 

No additional resources will be required.

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

ADAMS Accession No. ML020910165 *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 5/12/02 5/17/02 04/15/02 5/17/02 5/17/02 04/26/02

OFFICE OCFO OGC NRR/ADPT NRR/D RES EDO

NAME TPulliam* LChandler* BSheron* SCollins* AThadani* WTravers

DATE 04/30/02 04/29/02 05/01/02 05/03/02 5/21/02 6/14/02

OFFICIAL RECORD COPY