POLICY ISSUE 

INFORMATION 

May 20, 2009 SECY-09-0078

FOR: The Commissioners 

FROM: Eric J. Leeds, Director 

 Office of Nuclear Reactor Regulation 

SUBJECT: STATUS REPORT ON POWER UPRATES 

PURPOSE: 

This information paper summarizes the power uprate program accomplishments and challenges 

since the last update in SECY-08-0078, “Status Report on Power Uprates,” dated June 3, 2008. 

This paper does not address any new commitments or resource implications. 

BACKGROUND: 

The staff provides the Commission with an annual update of significant power uprate activities, 

in accordance with the staff requirements memorandum dated February 8, 2002 

(SRM-M020129). 

DISCUSSION: 

Since the last update, the U.S. Nuclear Regulatory Commission (NRC) staff has approved 

five plant-specific power uprates. The staff is currently reviewing ten power uprates. Over the 

next 5 years, the staff expects that licensees will submit an additional 38 power uprate 

applications. The enclosed status report provides detailed information on the power uprates 

approved since June 3, 2008; applications under review; applications expected in the future; 

accomplishments; operating experience; and program performance. 

CONTACTS: Thomas W. Alexion, NRR/DPR 

 (301) 415-1326 

 Andrea P. Russell, NRR/DPR 

 (301) 415-8553
The Commissioners -2- 

The staff met its timeliness goals for two of the five power uprates approved since June 3, 2008 

(the Comanche Peak Units 1 and 2 stretch power uprates). The staff exceeded the 6-month 

review goal for the Cooper measurement uncertainty recapture power uprate by 10 days due to

a combination of insufficient licensee responses to NRC questions, the need to re-ask for 

information, and the availability of the NRC staff when the final supplemental response was 

provided. The staff exceeded the 9-month review goal for the Millstone Unit 3 stretch power 

uprate by 4 weeks due to the licensee’s late responses to NRC questions. The staff’s review of 

the Davis-Besse measurement uncertainty recapture power uprate (duration of about 

14 months) was also delayed due to the licensee’s late responses to NRC questions. 

Two independent industry topical reports have been submitted and are under review, which 

should ultimately provide the industry with two independent integrated evaluation approaches 

and acceptance criteria for steam dryers. Upon evaluation and approval of the reports by the 

NRC, the staff expects improvements in the timeliness of future boiling water reactor extended 

power uprate reviews. 

On March 28, 2008, the Office of the Inspector General (OIG) issued Audit Report OIG-08-A-09, 

“Audit of NRC’s Power Uprate Program.” The recommendations in the report identified that the 

NRC’s power uprate program could be enhanced in areas of the power uprate inspection 

procedure documentation and implementation, the circulation and written quality of safety 

evaluations, and the power uprate coordinating function. The staff addressed the OIG 

recommendations by revising Inspection Procedure 71004, “Power Uprate” on July 1, 2008, and 

on February 2, 2009, and by issuing a new internal office instruction, LIC-112, "Power Uprate 

Process," on February 17, 2009. 

The continuing goal is for the staff to conduct timely power uprate reviews of appropriate scope 

and depth for each of the technical areas while ensuring that safety is maintained. 

COORDINATION: 

The Office of the General Counsel reviewed this report and has no legal objection. 

/RA/ 

Eric J. Leeds, Director 

Office of Nuclear Reactor Regulation 

Enclosure: 

Power Uprate Program Status Report 
The Commissioners -2- 

The staff met its timeliness goals for two of the five power uprates approved since June 3, 2008 

(the Comanche Peak Units 1 and 2 stretch power uprates). The staff exceeded the 6-month 

review goal for the Cooper measurement uncertainty recapture power uprate by 10 days due to

a combination of insufficient licensee responses to NRC questions, the need to re-ask for 

information, and the availability of the NRC staff when the final supplemental response was 

provided. The staff exceeded the 9-month review goal for the Millstone Unit 3 stretch power 

uprate by 4 weeks due to the licensee’s late responses to NRC questions. The staff’s review of 

the Davis-Besse measurement uncertainty recapture power uprate (duration of about 

14 months) was also delayed due to the licensee’s late responses to NRC questions. 

Two independent industry topical reports have been submitted and are under review, which 

should ultimately provide the industry with two independent integrated evaluation approaches 

and acceptance criteria for steam dryers. Upon evaluation and approval of the reports by the 

NRC, the staff expects improvements in the timeliness of future boiling water reactor extended 

power uprate reviews. 

On March 28, 2008, the Office of the Inspector General (OIG) issued Audit Report OIG-08-A-09, 

“Audit of NRC’s Power Uprate Program.” The recommendations in the report identified that the 

NRC’s power uprate program could be enhanced in areas of the power uprate inspection 

procedure documentation and implementation, the circulation and written quality of safety 

evaluations, and the power uprate coordinating function. The staff addressed the OIG 

recommendations by revising Inspection Procedure 71004, “Power Uprate” on July 1, 2008, and 

on February 2, 2009, and by issuing a new internal office instruction, LIC-112, "Power Uprate 

Process," on February 17, 2009. 

The continuing goal is for the staff to conduct timely power uprate reviews of appropriate scope 

and depth for each of the technical areas while ensuring that safety is maintained. 

COORDINATION: 

The Office of the General Counsel reviewed this report and has no legal objection. 

Eric J. Leeds, Director 

Office of Nuclear Reactor Regulation 

Enclosure: 

Power Uprate Program Status Report 

ADAMS Accession No.: ML090750336 WITS 200200020/EDATS: SECY-2008-0412 

 *via e-mail 

OFFICE PGCB/PM PGCB/PM PGCB/LA TECH ED* EMCB/BC PGCB/BC 

NAME ARussell TAlexion CHawes KAzariah-Kribbs MKhanna MMurphy 

DATE 03/13/09 03/13/09 03/16/09 03/09/09 03/16/09 04/22/09 

OFFICE OGC (NLO) DOLR/D DPR/D NRR/D 

NAME DRoth JGiitter TMcGinty ELeeds 

DATE 04/09/09 03/30/09 03/30/09 05/20/09 

OFFICIAL RECORD COPY 
Enclosure 

Power Uprate Program Status Report 

May 2009

Power uprates are categorized based on the magnitude of the power increase and the methods 

used to achieve the increase. Measurement uncertainty recapture (MUR) power uprates result 

in power-level increases of less than 2 percent and are achieved by implementing enhanced 

techniques for calculating reactor power. Stretch power uprates (SPUs) typically result in powerlevel increases of up to 7 percent and generally do not involve major plant modifications; 

extended power uprates (EPUs) result in greater power-level increases than SPUs and usually 

require significant modifications to major plant equipment. The U.S. Nuclear Regulatory 

Commission (NRC) has approved EPUs for increases as high as 20 percent. 

Power Uprates Approved Since June 2008

Power uprates approved since June 3, 2008, have added 630 megawatts thermal (MWt) or 

approximately 210 megawatts electric (MWe) to the Nation=s electric generating capacity. This 

brings the total number of power uprates approved since 1977 to 124, resulting in a combined 

increase of about 16,919 MWt (5,640 MWe) in the Nation=s electric generating capacity. Table 1 

provides information on the power uprates approved since June 3, 2008; details on program 

performance versus established goals for these approved power uprates appear later in this 

enclosure. 

Table 1 - Power Uprates Approved Since June 3, 2008

No. Plant % Uprate MWt Application Date Approval Date Type 

1 Comanche Peak 1 4.5 154 08/28/2007 06/27/2008 SPU 

2 Comanche Peak 2 4.5 154 08/28/2007 06/27/2008 SPU 

3 Cooper 1.6 38 11/19/2007 06/30/2008 MUR 

4 Davis-Besse 1.6 45 04/12/2007 06/30/2008 MUR 

5 Millstone 3 7 239 07/13/2007 08/12/2008 SPU 

 Total 630 
-2- 

Power Uprate Applications Currently under Staff Review

As noted in Table 2, power uprates currently under review could add an additional 2,399 MWt or 

800 MWe to the Nation’s electric generating capacity, if approved. 

Table 2 - Power Uprate Applications under Review

No. Plant % Uprate MWt Submittal 

Date 

Projected 

Completion Date Type 

1 Browns Ferry 2 15 494 06/25/2004 To Be Determined EPU 

2 Browns Ferry 3 15 494 06/25/2004 To Be Determined EPU 

3 Browns Ferry 1 15 494 06/28/2004 Summer 2009 EPU 

4 Calvert Cliffs 1 1.4 37 08/29/2008 August 2009 MUR 

5 Calvert Cliffs 2 1.4 37 08/29/2008 August 2009 MUR 

6 Monticello 12.9 229 11/05/2008 December 2009 EPU 

7 North Anna 1* 1.6 47 03/26/2009 To Be Determined MUR 

8 North Anna 2* 1.6 47 03/26/2009 To Be Determined MUR 

9 Point Beach 1* 17 260 04/07/2009 To Be Determined EPU 

10 Point Beach 2* 17 260 04/07/2009 To Be Determined EPU 

 Total 2,399 

* These applications are currently undergoing NRC acceptance review. 

Expected Power Uprate Applications

Table 3 estimates future power uprate applications based on a survey of all licensees conducted 

in October 2008. 

Table 3 - Projected Future Power Uprate Applications

Fiscal 

Year 

Power Uprates 

Expected 

MUR Power 

Uprates SPUs EPUs MWt MWe 

2009 6 4 0 2 1,066 355 

2010 20 12 1 7 2,880 960 

2011 10 2 0 8 3,127 1,042 

2012 1 0 0 1 522 174 

2013 1 0 0 1 470 157 

Total 38 18 1 19 8,065 2,688 
-3- 

Accomplishments Since June 3, 2008

The NRC staff accomplishments since June 3, 2008, are as follows: 

• Approved five plant-specific power uprates, specifically two MUR power uprates (Cooper 

and Davis-Besse) and three SPUs (Comanche Peak Units 1 and 2 and Millstone Unit 3). 

• Participated in the Nuclear Energy Institute EPU workshop on December 2-3, 2008, in 

New Orleans, LA and presented a "Regulatory Perspective" on power uprates. 

• Issued acceptance letters for the MUR power uprate applications for Calvert Cliffs 

Units 1 and 2, and the resubmitted EPU application for Monticello. 

• Presented information on the Millstone Unit 3 SPU application to the Advisory Committee 

on Reactor Safeguards (ACRS) and the ACRS Subcommittee on Power Uprates. 

• Revised Inspection Procedure (IP) 71004, "Power Uprate," with regard to the use of the 

inspection procedure, the tracking of other inspection procedures related to power 

uprates, and the documentation of inspection activities related to power uprates. 

• Issued a new internal office instruction entitled "Power Uprate Process" that strengthens 

the coordination of all aspects of power uprate activities and identifies roles and 

responsibilities for headquarters and regional points of contact for power uprates. 

Operating Experience Related to Power Uprates

Potential Adverse Flow Effects 

At power uprate conditions, nuclear power plants can experience significant increases in steam 

flow velocities. Plant experience has shown that as the higher main steamline flow passes over 

branch lines, it can create an acoustic resonance in the steamlines that can vary greatly from 

one plant to another, depending on the routing of the main steamlines and the steam dryer 

vintage and geometry. The acoustic resonance can create pressure waves that strike the steam 

dryer in boiling-water reactors (BWRs) with sufficient force to cause the stress in the steam dryer 

to exceed the material fatigue limits, which may result in steam dryer cracking. The acoustic 

resonance can also cause excessive vibration that may damage steamline components, such as 

relief valves and piping. 

To address this issue, BWR EPU applicants have provided a steam dryer analysis to 

demonstrate the structural integrity of the steam dryers at the uprated power level. However, the 

challenge of providing an acceptable steam dryer analysis delayed the EPU review for Hope 

Creek (approved in 2008) and continues to delay the EPU reviews for Browns Ferry Units 1, 2, 

and 3. 

The reviews for Browns Ferry Units 1, 2, and 3 were delayed because the licensee introduced 

several new refinements to the analytical methods, which had not been used in previous EPU 

applications (e.g., noise subtraction methodology, sub-modeling techniques, and crediting 

perforated plate damping). The delay also stemmed from the staff’s identification of an issue 

with the licensee’s acoustic circuit model with respect to under-prediction of loads on the dryer 
-4- 

within a specific frequency range. The licensee submitted supplemental information to address 

these issues on March 11, 2009. The staff is currently reviewing this information to complete its 

safety evaluation for Unit 1. The Unit 2 review is suspended pending the licensee development 

of steam dryer modifications needed to address a signal filter issue in the relief valve resonance 

frequency range. The Unit 3 review is suspended because strain gauge failures at the plant 

have resulted in a lack of data needed for the steam dryer analysis. 

Two independent industry topical reports have been submitted and are under review, which 

should ultimately provide the industry with two independent integrated evaluation approaches 

and acceptance criteria for steam dryers. GE Hitachi Nuclear Energy submitted NEDC-33436P, 

“GEH Boiling Water Reactor Steam Dryer - Plant Based Load Evaluation,” on November 7, 

2008. The Electric Power Research Institute submitted BWRVIP-194, “Methodologies for 

Demonstrating Steam Dryer Integrity for Power Uprate,” on October 31, 2008. The NRC will 

review these topical reports and subject to approval, develop plant-specific items that licensees 

will need to address if they reference the topical reports. Upon approval of the reports by the 

NRC, the staff expects improvements in the timeliness of future boiling water reactor extended 

power uprate reviews. 

Containment Accident Pressure Credit 

Extended power uprates result in an increase in the temperature of the sump water (in 

pressurized water reactors) and suppression pool water (in BWRs) during certain postulated 

accident scenarios and/or abnormal events. This can have an adverse impact on the 

performance of the emergency core cooling system (ECCS) pumps taking suction from these 

water sources. In some cases, licensees have proposed use of containment accident pressure 

to ensure acceptable performance of the ECCS pumps. The ACRS has detailed its concerns 

with this practice in a letter to the Executive Director for Operations, dated March 18, 2009. The 

staff is preparing a response to the ACRS and is working with the ACRS to resolve these issues. 

Program Performance versus Established Goals

The established performance goals are: 6 months for reviewing MUR power uprate 

applications, 9 months for reviewing SPU applications, and 12 months for reviewing EPU 

applications.1

 The staff will continue to ensure that protection of public health and safety is not 

compromised through its efforts to meet these timeliness goals. Individual applications may 

require more or less review time, depending on the nature of the technical issues. 

The staff met its timeliness goals for two of the five power uprates approved since June 3, 2008 

(the Comanche Peak Units 1 and 2 SPUs). The staff exceeded the 6-month review goal for the 

Cooper MUR power uprate by 10 days due to a combination of insufficient licensee responses to 

NRC questions, the need to re-ask for information, and the availability of the NRC staff when the 

final supplemental response was provided. The staff exceeded the 9-month review goal for the 

Millstone Unit 3 SPU by 4 weeks due to the licensee’s late responses to NRC questions. The 

staff’s review of the Davis-Besse MUR power uprate (duration of about 14 months) was also 

delayed due to the licensee’s late responses to NRC questions. 

 1 These goals do not include the duration of the staff's acceptance review, which the staff conducts upon 

receipt of the initial application.
-5- 

The delays in the Browns Ferry EPU reviews, due to staff concerns with their steam dryer 

analysis, have been discussed previously in the operating experience section of this paper. In 

addition, taking credit for containment accident pressure to ensure acceptable performance of 

the ECCS pumps, is an area of discussion between ACRS and the staff, and it is a potential 

challenge to completing the Browns Ferry EPU reviews. 

The Calvert Cliffs Units 1 and 2 MUR power uprate reviews have been delayed due to the 

licensee’s late responses to NRC questions. In addition, the staff has concerns with the 

proposed installation of the ultrasonic flow meters and the associated uncertainty calculations. 

Office of the Inspector General Audit Report on Power Uprates

On March 28, 2008, the Office of the Inspector General (OIG) issued Audit Report OIG-08-A-09, 

“Audit of NRC’s Power Uprate Program.” The recommendations in the report identified that the 

NRC’s power uprate program could be enhanced in areas of the power uprate inspection 

procedure documentation and implementation, the circulation and written quality of safety 

evaluations, and the power uprate coordinating function. 

The staff addressed the OIG recommendations by revising Inspection Procedure (IP) 71004, 

“Power Uprate” on July 1, 2008, and on February 2, 2009, and by issuing a new internal office 

instruction, LIC-112, "Power Uprate Process," on February 17, 2009. 

The NRC revised IP 71004 to (1) provide more specificity with regard to the use of the inspection 

procedure, (2) require that all planned team inspections that are selected to support completion 

of IP 71004 sample requirements be annotated as such in the Regional Reactor Program 

System, and (3) revise documentation requirements so that inspection activities related to power 

uprates are easily identified. 

 

The new internal office instruction, LIC-112, strengthens the coordination of all aspects of power 

uprate activities, identifies roles and responsibilities for headquarters and regional points of 

contact for power uprates, and focuses on detailed staff guidance that is unique to processing 

power uprate applications. The guidance also includes enhancements to improve the 

distribution of safety evaluations supporting the power uprate and the awareness of certain 

sections within the safety evaluations, with internal NRC stakeholders. The guidance also 

includes enhancements to improve the written quality of safety evaluations. 

On April 1, 2009, the OIG updated its September 24, 2008, analysis and status of the staff’s 

response to the OIG recommendations. The OIG has concluded that all recommendations 

related to OIG-08-A-09 are now resolved and closed.