__________ __ 

 POLICY ISSUE

 (Information) 

June 15, 2012 SECY-12-0084

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-11-0071, “Status Report on Power Uprates,” dated May 25, 2011. 

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 (SRM) dated February 8, 2002, 

entitled “Briefing on Status of Nuclear Reactor Safety” (SRM-M020129). 

DISCUSSION: 

The staff continues to ensure that the goal of protection of public health and safety remains 

paramount throughout its power uprate license application reviews and is not compromised in 

order to meet the associated timeliness and resource performance goals. Since the last update, 

the U.S. Nuclear Regulatory Commission (NRC) staff has approved power uprates for 

four plants. The staff is currently reviewing 17 power uprates. Over the next five years, the staff 

expects that licensees will submit an additional 15 power uprate applications. The enclosed 

status report provides detailed information on the power uprates approved since May 25, 2011; 

applications under review; applications expected in the future; accomplishments; program 

assessment and enhancement opportunities. 

CONTACT: Nicholas J. DiFrancesco, NRR/DORL 

 (301) 415-1115
The Commissioners - 2 - 

The staff has continued to encounter challenges in meeting the 12-month review goal for 

extended power uprates (EPUs) and 6-month review goal for measurement uncertainty 

recaptures (MURs). The staff exceeded the 12-month review goal for Nine Mile Point, Unit 2, 

EPU by 16 months primarily because of delays in receiving the licensee’s supplement adopting 

a revised steam dryer analysis. The staff exceeded the 6-month review goal for the Shearon 

Harris, Unit 1, MUR by five months because of competing staff priorities and time needed to 

resolve staff comments to ensure safety evaluation quality. The staff exceeded the 12-month 

review goal for the Turkey Point, Units 2 and 3, EPUs by three months because of a concern 

relating to significant peak cladding temperature error contained within the emergency core 

cooling system (ECCS) evaluation model. This concern was related to fuel thermal conductivity 

degradation which required a revision to the ECCS evaluation model late in the review. Other 

review delays are mainly due to technical and/or programmatic challenges. These challenges 

are addressed in the enclosed report. 

In spring 2012, the staff assessed various aspects of the program to understand existing 

programmatic challenges with completing reviews within the existing timeliness goals. The staff 

identified opportunities to enhance the program and is considering additional changes for the 

future. Budgeted resource estimates and performance goals also have been revised to allow 

for more effective and efficient use of existing staff resources. 

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 has continued to encounter challenges in meeting the 12-month review goal for 

extended power uprates (EPUs) and 6-month review goal for measurement uncertainty 

recaptures (MURs). The staff exceeded the 12-month review goal for Nine Mile Point, Unit 2, 

EPU by 16 months primarily because of delays in receiving the licensee’s supplement adopting 

a revised steam dryer analysis. The staff exceeded the 6-month review goal for the Shearon 

Harris, Unit 1, MUR by five months because of competing staff priorities and time needed to 

resolve staff comments to ensure safety evaluation quality. The staff exceeded the 12-month 

review goal for the Turkey Point, Units 2 and 3, EPUs by three months because of a concern 

relating to significant peak cladding temperature error contained within the emergency core 

cooling system (ECCS) evaluation model. This concern was related to fuel thermal conductivity 

degradation which required a revision to the ECCS evaluation model late in the review. Other 

review delays are mainly due to technical and/or programmatic challenges. These challenges 

are addressed in the enclosed report. 

In spring 2012, the staff assessed various aspects of the program to understand existing 

programmatic challenges with completing reviews within the existing timeliness goals. The staff 

identified opportunities to enhance the program and is considering additional changes for the 

future. Budgeted resource estimates and performance goals also have been revised to allow 

for more effective and efficient use of existing staff resources. 

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 

WITS 200200020/EDATS: SECY-2011-0335 

ADAMS Accession No.: ML12116A342 *via e-mail 

OFFICE DORL/LPL3-2/PM DORL/LPL3-2/LA TECH ED* NRR/DE/EMCB NRR/DSS/SCVB* 

NAME NDiFrancesco SRohrer CHsu MMurphy RDennig 

DATE 06/11/12 06/11 /12 06/08/12 05/21/12 05/15/12 

OFFICE OGC (NLO) NRR/DORL/LPL3-2/BC NRR/DORL/D NRR/D 

NAME BHarris JZimmerman MEvans ELeeds 

DATE 06/07/12 06/12/12 06/13/12 06/15/12 

OFFICIAL RECORD COPY
Enclosure

Power Uprate Program Status Report 

June 2012

Power uprates are categorized based on the magnitude of the thermal 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 power-level 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 thermal power increases as high as 

20 percent. 

Power Uprates Approved Since May 2011

Power uprates approved since May 25, 2011, have added 1,257 megawatts thermal (MWt) or 

approximately 415 megawatts electric (MWe) to the Nation=s electric generating capacity. This 

brings the total number of power uprates approved since 1977 to 143, resulting in a combined 

increase of about 19,320 MWt (6,440 MWe) to the Nation=s electric generating capacity. 

Table 1 provides information on the power uprates approved since May 25, 2011. 

Table 1 - Power Uprates Approved Since May 25, 2011 

No. Plant % Uprate MWt Application 

Date

Acceptance 

Date

Approval 

Date Type

1 Nine Mile Point 2 15 521 05/27/2009 09/02/2009 12/22/2011 EPU

2 Shearon Harris 1 1.6 48 04/28/2011 07/01/2011 05/30/2012 MUR

3 Turkey Point 3* 15 344 10/21/2010 03/11/2011 06/15/2012 EPU

4 Turkey Point 4* 15 344 10/21/2010 03/11/2011 06/152012 EPU

 Total 1,257 

* Turkey Point’s EPU application included a 1.7% MUR. 

The staff has continued to encounter challenges in meeting the 12-month review goal for EPUs 

and 6-month review goal for MURs.1

 The staff exceeded the 12-month review goal for Nine Mile 

Point, Unit 2, EPU by 16 months because of delays with the submittal of the licensee’s revised 

steam dryer analysis, which used the latest Continuum Dynamics revision to the acoustic circuit 

model version 4.1 to resolve staff technical concerns. The staff exceeded the 6-month review 

goal for the Shearon Harris, Unit 1, MUR by five months because of competing staff priorities 

and time needed to resolve staff comments to ensure safety evaluation quality. The staff 

exceeded the 12-month review goal for the Turkey Point, Units 2 and 3, EPUs by three months 

due to a concern relating to significant peak cladding temperature error contained within the 

emergency core cooling system (ECCS) evaluation model. This concern was related to fuel 

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

receipt of the initial application. 
- 2 - 

thermal conductivity degradation which required a revision to the ECCS evaluation model late in 

the review. The licensee’s subsequent analysis demonstrated acceptable performance against 

the Title 10 of the Code of Federal Regulations (10 CFR) 50.46, “Acceptance Criteria for 

Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors,” acceptance 

criteria. 

Power Uprate Applications Currently Under Staff Review

As illustrated in Table 2, power uprates currently under review could add an additional 

3,742 MWt or approximately 1,247 MWe to the Nation’s electric generating capacity, if 

approved.

Table 2 - Power Uprate Applications Under Staff Review 

No. Plant % Uprate MWt Application 

Date

Projected 

Completion Date Type

1 Browns Ferry 2 14.3 494 06/25/2004 To be determined EPU

2 Browns Ferry 3 14.3 494 06/25/2004 To be determined EPU

3 Browns Ferry 1 14.3 494 06/28/2004 To be determined EPU

4 Monticello 12.9 229 11/05/2008 To be determined EPU

5 Grand Gulf 1 13.1 510 09/08/2010 July 2012 EPU

6 St. Lucie 1* 11.9 320 11/22/2010 2nd Quarter 2012 EPU

7 St. Lucie 2* 11.9 320 02/25/2011 3rd Quarter 2012 EPU

8 Crystal River 3 15.5 405 06/15/2011 June 2013 EPU

9 Braidwood 1 1.6 58.4 06/23/2011 December 2012 MUR

10 Braidwood 2 1.6 58.4 06/23/2011 December 2012 MUR

11 Byron 1 1.6 58.4 06/23/2011 December 2012 MUR

12 Byron 2 1.6 58.4 06/23/2011 December 2012 MUR

13 Oconee 1 1.6 42 09/20/2011 To be determined MUR

14 Oconee 2 1.6 42 09/20/2011 To be determined MUR

15 Oconee 3 1.6 42 09/20/2011 To be determined MUR

16 McGuire 1 1.7 58 03/05/2012 October 2012 MUR

17 McGuire 2 1.7 58 03/05/2012 October 2012 MUR

Total MWt 3,742

* St. Lucie’s EPU applications each include a 1.7% MUR. 

Delayed Ongoing Reviews

The Browns Ferry, Units 1, 2, and 3, and Monticello EPU reviews have been delayed primarily 

because of staff concerns and licensee delays with providing revised steam dryer analyses and 

analyses that take credit for containment accident pressure (CAP). General discussion of these 

issues appear in the following “Technical Challenges” section of this report. 
- 3 - 

The staff plans to resume the CAP portion of the Browns Ferry, Units 1, 2, and 3, and Monticello 

EPU reviews. With respect to the Browns Ferry EPU review, the licensee informed the staff in a 

September 15, 2011, public meeting that it intends to submit a supplement addressing CAP 

credit once Boiling Water Reactor Owners’ Group (BWROG) guidance is finalized. Similarly, 

the licensee for Monticello informed the staff in an April 3, 2012, public meeting that it will submit 

a supplement addressing CAP in September 2012, that is consistent with Option 1 from 

SECY 11-0014, “Use of Containment Accident Pressure in Analyzing Emergency Core Cooling 

System Pump Performance in Postulated Accidents.” At the time of submission, the staff will 

resume the CAP portion of these applications. 

Regarding the steam dryer portion of the delayed EPU reviews, the Monticello steam dryer was 

replaced in spring 2011. Monticello provided a supplemental response dated January 13, 2012, 

containing updated technical data and analyses that support steam dryer operations under EPU 

conditions. The response partially addressed open staff requests for additional information 

(RAIs) and audit action items from July 8, 2011. The staff plans to resume review of the 

Monticello steam dryer analysis following receipt of the outstanding steam dryer technical 

analyses and the CAP analysis supplements. 

The licensee for Browns Ferry, Units 1, 2, and 3, plans to replace the steam dryers following 

NRC approval of their EPU amendment request. The licensee informed the staff in a 

September 15, 2011, public meeting that it intends to provide replacement steam dryer analyses 

in spring 2014. At that time, the staff will resume the steam dryer portion of the Browns Ferry 

EPU review. 

The Grand Gulf, Unit 1, EPU review has been delayed primarily to resolve concerns with the 

licensee’s steam dryer analyses. The staff identified concerns with the licensee’s application of 

the plant based load evaluation methodology for determining the steam dryer loading. The staff 

also identified concerns with structural finite element modeling. Subsequently, the licensee 

revised the methodology and modeling. The staff completed its safety review of the steam dryer 

analyses and presented the results to the Advisory Committee on Reactor Safeguards (ACRS) 

subcommittee on May 24, 2012, and ACRS full committee on June 6, 2012. 

The St. Lucie, Unit 1, EPU review was delayed primarily to resolve staff and ACRS concerns 

associated with fuel thermal conductivity degradation in safety analysis models. Additional 

delays in staff’s review resulted from the licensee requiring seven months to provide RAI 

responses revising stress analyses for modifications to structures, systems, and components. 

The Crystal River, Unit 3, EPU review was scheduled for a one to two year review depending on 

the development of repair plans for the containment by the licensee. The application includes 

crediting a new safety-related fast cooldown system to assist ECCS performance during a 

small-break loss-of-coolant accident. 

The Braidwood, Units 1 and 2, and Byron Unit Nos. 1 and 2, MUR reviews were scheduled for a 

one year review with completion in June 2012. The one year schedule was established 

because of the beyond-MUR review scope requests revising steam generator tube rupture 

(SGTR) and margin to overfill (MTO) analyses, and the use of subchannel analysis code with 

updated departure from nucleate boiling correlations. Subsequently, the licensee informed the 

NRC that the power operated relief valve flow rates assumed in the SGTR MTO analysis were 
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non-conservative. The NRC plans to resume the SGTR MTO review upon receipt of the revised 

evaluation from the licensee, currently scheduled for submittal in August 2012. 

Expected Power Uprate Applications

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

conducted in December 2011. 

Table 3 - Projected Future Power Uprate Applications 

Fiscal 

Year

Power Uprates 

Expected

MUR Power

Uprates SPUs EPUs MWt MWe

2012 5 1 0 4 1814 605

2013 6 6 0 0 302 101

2014 0 0 0 0 0 0

2015 3 1 0 2 930 310

2016 1 0 0 1 435 145

TOTAL 15 8 0 7 3481 1160

Accomplishments Since May 25, 2011

The NRC staff accomplishments since May 25, 2011, are as follows: 

• Approved four plant-specific power uprates, specifically, one MUR power uprate 

(Shearon Harris, Unit 1) and three EPUs (Turkey Point, Units 3 and 4, and Nine Mile 

Point, Unit 2). 

• Presented safety review results on the St. Lucie, Unit 1, and Grand Gulf, Unit 1, EPU 

applications to the ACRS Subcommittee on Power Uprates and the ACRS Full 

Committee. 

• Conducted public meetings with Monticello and the Pressurized Water Reactor Owners 

Group (PWROG) supporting resolution of the CAP credit concern. 

• Evaluated revisions to the power uprate review duration performance goals and 

resource budget model to improve power uprate staffing plans and schedule execution. 

• Issued acceptance letters for the EPU applications for St. Lucie, Unit 2, and Crystal 

River, Unit 3. 

• Conducted pre-application public meetings with LaSalle, Units 1 and 2, on a proposed 

12.5 percent EPU and Peach Bottom, Units 2 and 3, on a proposed 12.4 percent EPU. 

 
- 5 - 

Program Assessment

In January 2012, the lead responsibility for program management and oversight of the Office of 

Nuclear Reactor Regulation (NRR) Power Uprate Program was transferred from the Division of 

Policy and Rulemaking to the Division of Operating Reactor Licensing. This transfer was done 

to better align the program lead responsibility with the individual licensing project management 

responsibility for power uprate reviews. 

As part of the transfer, the staff assessed various aspects of the program to understand its 

current state. The assessment covered several aspects of the program including (1) resources 

budgeted and actual expenditures, (2) historic review timeliness and schedules, (3) staff 

requests for additional information, (4) supplemental responses from licensees, (5) safety 

evaluation documentation, and (6) resolution of long-standing technical issues specific to power 

uprate reviews. The assessment reconfirmed the existing technical challenges and identified 

some historical programmatic challenges, and opportunities for enhancement to the power 

uprate program. 

Technical Challenges

Power uprate applications, dependent on the facility and type of uprate request, must consider 

the resolution of technical issues related to CAP credit and adverse flow effects on structures, 

systems, and components. Given the importance and complexity of power uprate reviews, 

careful consideration of sequencing of non-power uprate licensing applications is necessary to 

avoid the unintentional introduction of technical complexities into power uprate application 

reviews and the potential for subsequent impacts to outage-related activities. The progress 

made by the staff and stakeholders is discussed below. 

Update on Containment Accident Pressure Credit 

EPUs result in an increase in the temperature of the sump water (in pressurized-water reactors) 

and suppression pool water (in boiling-water reactors [BWRs]) during certain postulated 

accidents or abnormal events. This could affect the performance of the ECCS pumps taking 

suction from these water sources. In some cases, licensees have included CAP in their safety 

analyses to demonstrate acceptable performance of the ECCS pumps. The ACRS 

recommended changes to this practice by letter to the Executive Director for Operations dated 

March 18, 2009. 

On June 25, 2010, staff requirements memorandum (SRM) M100609B, “Meeting with the 

Advisory Committee on Reactor Safeguards,” was issued. It directed that the staff’s 

forthcoming paper on CAP should discuss where the staff aligns or disagrees with the ACRS 

regarding CAP credit, including use of risk information, defense-in-depth implications, and need 

to assess the practicality of hardware changes to eliminate the need for CAP credit. 

In response to SRM M100609B, the staff provided Commission paper SECY-11-0014, “Use of 

Containment Accident Pressure in Analyzing Emergency Core Cooling System and 

Containment Heat Removal System Pump Performance in Postulated Accidents” on January 

31, 2011. The staff provided two options to resolve the policy issues. In response to 

SECY-11-0014, SRM-SECY-11-0014 was issued on March 15, 2011. The SRM approved the 
- 6 - 

staff’s recommended Option 1 and directed the staff to conduct CAP reviews consistent with the 

current practice of accepting CAP credit while also implementing new staff deterministic 

guidance. The staff guidance was developed based on ACRS recommendations to quantify 

uncertainty and margins in net positive suction head calculations. The Commission also 

directed the staff to ensure that the defense-in-depth philosophy is interpreted and implemented 

consistently in Regulatory Guide 1.174, “An Approach for Using Probabilistic Risk Assessment 

in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis,” and other staff 

guidance. The staff is therefore proceeding with Option 1 and plans to resume the CAP portion 

of the delayed EPU reviews. 

The staff over the past year has continued to engage stakeholders on the draft guidance by 

soliciting input prior to finalizing guidance. In letters dated April 5, 2011, to Monticello and 

May 15, 2011, to Browns Ferry, the licensees were informed that the staff was prepared to 

resume the reviews of their EPU applications. These applications had been delayed pending 

the resolution of the CAP credit policy issues. In a September 15, 2011, meeting, Browns Ferry 

informed the staff of its intent to submit a supplement addressing CAP credit once BWROG 

guidance is finalized. In an April 3, 2012, meeting, Monticello informed the staff of its intent to 

submit an EPU CAP supplement to the NRC in September 2012, based on the draft guidance 

and Boiling Water Reactor Owners’ Group efforts completed. In a teleconference on 

April 10, 2012, the staff provided clarifications requested by the PWROG on the draft guidance 

and solicited their input in finalizing the guidance. 

On October 13, 2011, ACRS in its initial review of the NRC near-term task force report on 

Fukushima, recommended that licensing actions requiring the granting of CAP credit should be 

suspended until the implications of post-Fukushima containment pressure control measures are 

understood. The staff believes that there is no clear nexus between the CAP issue and 

Fukushima, but it will continue to evaluate the lessons learned from the Fukushima accident and 

will seek Commission guidance if any insights gained necessitate a change in previous 

Commission direction on the use of CAP. 

Update on Adverse Flow Effects 

Steam flow velocities at nuclear power plants increase under power uprate conditions. 

Operating experience has shown that as the higher velocity main steam line flow passes over 

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

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

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

steam dryer in BWRs with significant force. This force could cause the stresses in the steam 

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

acoustic resonance also can cause excessive vibration that may damage steamline and 

feedwater line components, such as relief valves and piping. To address this issue, BWR 

applicants for EPUs have provided complex steam dryer analyses to demonstrate the structural 

integrity of the steam dryers at uprated power levels. 

These plant-specific reviews have remained challenging and contributed to the delays in the 

EPU reviews for several BWR plants (e.g., Grand Gulf, Nine Mile Point, and Monticello). The 

delays are typically caused by licensees introducing new refinements into analytical methods 

not used in previous EPU applications, the NRC identifying new issues with licensees’ analytical 
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models, licensees needing to make steam dryer modifications to address analysis issues, and 

lack of adequate plant measurement data needed for the steam dryer analyses. 

Two independent industry topical reports have been submitted to the NRC for review and 

approval. These reports present two independent integrated evaluation approaches and 

acceptance criteria for steam dryers. The Electric Power Research Institute resubmitted 

BWRVIP-194, “Methodologies for Demonstrating Steam Dryer Integrity for Power Uprate,” on 

December 18, 2008. By letter dated September 8, 2011, EPRI provided supplemental 

information for BWRVIP-194 which is currently under staff review. General Electric [GE] Hitachi 

Nuclear Energy submitted NEDC-33436P, “GEH Boiling Water Reactor Steam Dryer - Plant 

Based Load Evaluation,” on November 7, 2008. The NRC staff review of NEDC-33436P has 

been suspended at GE’s request to support ongoing plant-specific EPU analyses. 

Bundling of Non-Power Uprate Licensing Requests 

Licensees have used power uprate requests as an opportunity to include (i.e., bundle) nonpower uprate related requests not directly associated with the power uprate review. Many of 

these requests could have been submitted separately by the licensee and reviewed by the 

NRC. The staff believes that these non-power uprate requests could be better sequenced 

around power uprate reviews to facilitate timely NRC review with available resources. Their 

inclusion introduces significant project risk in the timing and acceptability of power uprate 

applications. Facility changes which are needed to support plant modification for routine outage 

related changes or to resolve current licensing issues should be developed independent of the 

power uprate application and sequenced accordingly, consistent with NRC regulations, 

guidance, and with consultation of the assigned NRR operating reactor project manager. 

Two recent examples of licensee bundling are the Byron and Braidwood (B&B) MUR and the 

St. Lucie EPU. In the B&B MUR, the licensee’s June 2011, submittal, included a request to 

modify departure from nucleate boiling ratio (DNBR) correlations. This request improved fuel 

design flexibility and was not directly required for operation at the MUR increased thermal 

power. The licensee utilized the revised DNBR correlations in analysis for their fuel design 

calculations and subsequently purchased new fuel for the upcoming fall 2012 refueling outages, 

prior to NRC approving the plant-specific use of additional DNBR correlations. In May 2012, the 

staff was informed by the licensee that SGTR MTO analysis would have to be supplemented to 

correct non-conservative assumptions. As a result, staff approval of the MUR application with 

DNBR correlation changes is now targeted for completion after the fall 2012 refueling outages 

for Byron, Unit No. 1, and Braidwood, Unit 2. The licensee is currently evaluating options to 

separate out the staff’s DNBR review from the MUR review or to perform reanalysis utilizing the 

currently licensed DNBR correlations. At the time of St. Lucie’s EPU submittal, the licensee had 

not resolved a station blackout coping analysis concern identified during a 2007 Component 

Design Bases Inspection. This resulted in the withdrawal of the St. Lucie EPU application until 

the concern was evaluated by the licensee, and when resubmitted for review in November 

2010, it added complexity to the application. Licensees are encouraged to fully disposition 

significant current licensing and design basis corrective actions prior to submitting power uprate 

requests for NRC review for technical areas within power uprate review scope. 

Licensees have included other significant requests that should not be included in power uprate 

applications (e.g., digital instrumentation and control upgrades, use of alternate source term, 
- 8 - 

auxiliary feedwater modifications, and revisions to various analyses, high-energy line break, 

spent fuel pool criticality, other significant noncompliance or current licensing basis issues, and 

SGTR). 

Bundling impacts staff reviews and resources since beyond-scope requests require the 

development of custom review schedules and safety evaluations. The performance goals 

continue to be predicated on licensees’ submittals being consistent with established guidelines. 

On occasion, the staff has accommodated unrelated requests within the normal power uprate 

review schedule. However, in most cases, bundling causes review duration delays that are 

significantly longer than would otherwise be the case. 

Programmatic Challenges

The staff evaluated various aspects of the program to understand programmatic challenges. 

These challenges include: budget resources for current review schedules, limited availability of 

expertise in key technical areas to simultaneously review multiple applications, expectation for 

staff review documentation, and, most importantly, the agency’s safety mission priorities. 

Staff Mission Priorities 

NRR continues to focus staff resources to ensure timely resolution of emergent safety concerns 

(e.g., effects resulting from nuclear fuel thermal conductivity degradation), support to Fukushima 

lessons learned activities, and to ensure safe plant operation (e.g., response to earthquake near 

North Anna in fall 2011). Although power uprate reviews are high priority licensing actions, they 

are appropriately balanced against these other safety activities. 

Resources and Schedules 

Power uprate reviews require significant resources. Most recently, in March 2011, the staff reevaluated the budget model for each of the three types of power uprate application reviews and 

concluded that additional resources were required. Beginning in fiscal year 2012, the budgeted 

resources for power uprate application reviews were modified. Staff review hours for MUR, 

SPU, and EPU applications were increased to 1,200, 3,500, and 7,500 hours, respectively. The 

prior resource estimates for staff review hours were 1,000, 1,840, and 5,040 hours, 

respectively. However, the timeliness goals for the staff’s review of MUR, SPU, and EPU 

applications remained unchanged. The timeliness goal for MUR, SPU, and EPU application 

reviews is 6, 9, and 12 months, respectively. 

Power uprate reviews are resource intensive for technical disciplines in NRR. The number of 

current power uprate applications and the significant overlap of Fukushima lessons learned 

activities have periodically constrained the same groups of technical experts. Currently, the 

staff is simultaneously reviewing eight plant-specific EPU applications. This has resulted in 

resource and schedule constraints associated with aligning staff and supporting subsequent 

meetings with ACRS. The staff has largely overcome these challenges by prioritizing EPU 

reviews, when possible, to support licensees’ implementation schedules. Furthermore, 

recruiting new staff in these technical areas has been challenging given the limited number of 

qualified applicants and the time required to develop the necessary regulatory skills required. 
- 9 - 

Resources for application reviews and programmatic enhancements continue to be assessed 

and adjusted during the annual budget process. 

Documentation of Staff Review 

Openness is an important objective in the NRC’s Strategic Plan and helps to maintain and 

enhance the public’s confidence and build trust in the agency as a good regulator. An important 

element of openness is transparency which promotes accountability by providing the public with 

information about the NRC’s activities. More specifically, this means that public stakeholders 

must have timely access to clear and understandable information about the NRC’s role, 

processes, activities, and decision-making. 

In concert with meeting our openness objective and a recommendation in the Office of Inspector 

Generals, “Audit of NRC’s Power Uprate Program” (March 2008), improvements in the 

documentation of the staff’s safety review associated with power uprate applications was 

addressed. A new internal office instruction, LIC-112, “Power Uprate Process” 

(February 17, 2009), was developed, which among other things focused on enhancements to 

improve the written quality and level of detail in the staff’s safety evaluations. Although 

appropriately justified and supported by positive feedback from ACRS members, the emphasis 

on quality and level of detail has increased the time and effort associated with performing and 

documenting the staff’s review. The corresponding increase in the level of effort was not initially 

considered with the issuance of LIC-112, but was ultimately addressed in 2011 when the staff 

increased the required resources to perform a power uprate review. 

Opportunities for Enhancement

The staff has begun a series of enhancements to the power uprate program. These include 

enhancing operational reporting to management, improved communication of lessons learned, 

enhancements to meetings with internal stakeholders, and revisions to the staff resource 

models for reviews. Additional enhancements are also being evaluated to include (1) the review 

standard (RS)-001, “Review Standard for Extended Power Uprates,” (2) safety evaluation 

templates, (3) revisions to the review schedule templates, and (4) procedures associated with 

the power uprate process. The staff will continue to work with internal and external 

stakeholders to identify areas to enhance the effectiveness and efficiency of the program. 

Revision to Program Performance Goals

The staff continues to ensure that the goal of protection of public health and safety remains 

paramount throughout its power uprate license application reviews and is not compromised in 

order to meet the associated timeliness and resource performance goals. To that end, the staff 

believes the review timeliness goals should be lengthened for approved MUR, SPU, and EPU 

power uprate applications from application acceptance to 9, 12, and 18 months, respectively. 

The new timeliness goals will be applied to review schedules for applications submitted after 

June 2012. Review schedules for uprate applications currently under review will not change. 

A revision to the timeliness goals was prudent considering the technical and programmatic 

challenges outlined in this paper. The increased time will provide staff the necessary flexibility 
- 10 - 

to manage concurrent power uprate reviews, resolve unexpected or emerging technical issues 

identified during reviews, discrepancies identified in applications, and disposition of unrelated 

requests included in power uprate applications. In addition, it will provide the flexibility to 

manage program challenges with increased staff hours required for each review, expectations 

for documenting staff decisions and availability of key technical expertise working on higher 

priority activities. Furthermore, the staff believes that the changes to the timeliness goals and 

planned program enhancements will improve the overall stability, consistency, and predictability 

of power uprate reviews. 

Power uprate application reviews remain a high priority. However, the staff will always maintain 

its strong safety focus and commitment to higher priorities associated with operating nuclear 

power reactors, most notably, Fukushima lessons-learned activities and emergent safety issues, 

and the changes further demonstrate this. 

The staff will continue to evaluate the appropriateness of power uprate performance goals and 

explore enhancements to the power uprate program annually through interactions with internal 

and external stakeholders.