**NRC INSPECTION MANUAL**IRIB

INSPECTION PROCEDURE 71004

# POWER UPRATE

Effective Date: 02/09/2022

PROGRAM APPLICABILITY:  2515 Appendix C

# 71004-01	INSPECTION OBJECTIVES

01.01	To verify the risk-significant aspects of the following when applicable:

a. That tests and experiments not described in the FSAR and changes to the facility or procedures as described in the UFSAR for power uprate were evaluated in accordance with 10 CFR 50.59 as appropriate. 

b. That the licensee took the required actions to alleviate or prevent the effects of new or likely initiating events, in accordance with the license amendment or NRC safety evaluation (SE), that were due to changes such as higher core power densities, increased flow in primary or secondary systems including their interfacing systems, and the synergistic effects of multiple initiating events (e.g., higher primary flow rates coupled with greater fuel burnup leading to new potential problems). 

c. That plant modifications for power uprate are in accordance with licensing and design bases, licensee commitments, and the FSAR. 

d. That mitigating systems can initiate and perform their safety function in accordance with the timelines in new accident analyses, acceptance tests for plant modifications for power uprate, and applicable surveillance tests. 

e. That individual components in mitigating systems that were altered or replaced can perform their intended safety function. 

f. That new operator actions (normal, abnormal, and emergency) for power uprate are administered procedurally and have an appropriate basis.  Appropriate training should be provided to operators on the new procedures. 

g. That the licensee monitors changes, in accordance with NRC SE, made on systems and their effects on those systems and interfacing systems including potential problems  that  are  slow in  developing and  issues  that  could  not be immediately  tested  (e.g.,  erosion  corrosion  or flow accelerated corrosion).

# 71004-02	INSPECTION REQUIREMENTS

Inspect samples that were developed as part of the inspection plan (and its revisions).

# 71004-03	INSPECTION GUIDANCE

This inspection procedure should be performed for power uprates greater than 7.5% of current licensed thermal power, including those implemented in phases (i.e., when the total power increase approved by a single licensing action will be greater than 7.5%, but the initial power increase is less than 7.5%).  Partial or complete implementation of this inspection procedure may be considered for power uprates less than 7.5% of current licensed thermal power.  Inspection planning should begin after a licensee submits an amendment request for a power uprate.

Inspection Plan.  A site-specific inspection plan should be developed in order to select and review appropriate aspects of a power uprate.  The resident inspection office (RIO) and regional staff should work closely together to identify areas for inspection, and to discuss the resources required to perform the inspections.  A regional extended power uprate (EPU) point of contact should be identified by regional management early in the process.  This individual should be contacted for assistance in developing the inspection plan.  Inspection planning, execution, and tracking should generally follow the guidance provided in this IP.  However, it is recognized that unique situations will necessitate slight deviations from this procedure. It may be useful to consult the other regions or the program office for suggestions.  Regional management should be made aware of significant deviations from this IP.

a. The inspection staff should review IP 71004 soon after the power uprate application is submitted by the licensee.  The associated NRC SE should be reviewed as soon as it is available (the RIO should keep in close communication with the NRR project manager to obtain a copy).  The purpose of the review is to identify changes in plant hardware, integrated plant response characteristics, operator procedures, and margins to plant safety.  Per Section 4.1 of Review Standard RS-001, “Review Standard for Extended Power Uprates,” the recommendations in the final SE do not constitute inspection requirements, but are provided to give the inspectors insight into important bases the NRC staff used for approving the EPU.

b. Once the IP 71004 samples are selected, the inspection staff should identify the types of resources necessary to complete IP 71004, and an estimate of schedule dates.  Some inspection dates may take place before power increases above the previously licensed power setpoint, whereas some inspection may need to occur during power ascension testing, and at the new licensing limit for rated power output.  To the extent possible, inspectors should evaluate plant changes and major tests prior to their implementation to ensure that plant safety is maintained.

c. Several samples are likely suited for resident inspector skills and may suffice for baseline IP samples, but the inspection plan should consider additional resources based on resident staff workload, and conflict with other foreseeable resident staff activities. 

d. Once the IP 71004 samples and resources have been identified, the inspection staff should provide the inspection plan to the regional EPU point of contact.  The sample inspection plan, provided as Attachment 1, is a recommended example.  The regional EPU point of contact should review the inspection plan for IP 71004 requirements and should work with the appropriate regional engineering / technical branches to assign all necessary resources outside of the resident inspector staff. 

e. The branch chief responsible for the affected plant should review and approve the inspection plan.  Regional management should be briefed on the plan at the next available opportunity (e.g., end-of cycle meeting).  In accordance with IMC 2515, Appendix C, Regional Administrator authorization is required to implement IP 71004.  The process for this authorization may vary from region to region; but the date that authorization is given should be clearly annotated in the inspection plan (see example in Attachment 1).   

f. The branch chief responsible for the affected plant and RIO should track completion of IP 71004.  Attachment 1, Table 1 is a sample that may be used to ensure inspection requirements will be completed, and necessary coordination obtained.

Sample Selection and Inspection.  Samples should be selected in order to verify that the power uprate can be achieved in a safe manner.  Samples should be risk-informed and focused on items concerning new integrated plant response characteristics, new operator procedures, and plant safety during any required tests. 

The samples selected should be inspected per the referenced baseline inspection procedures (except for those covered by this inspection procedure and IP 49001).  The intention is not to replace the requirements of baseline inspection activities.  Credit should be given to the normal baseline samples when performing those activities as a power uprate inspection sample under IP 71004 whenever possible (to prevent duplication of inspection efforts).  It is important to take credit for those normal baseline samples under IP 71004.  In certain instances, the IP 71004 inspection sample may not correlate 100 percent with the referenced baseline inspection procedure.  In these situations, it may be appropriate to perform the inspection requirements necessary for the power uprate inspection and to credit the corollary baseline sample as complete, even if the sample was modified slightly from the definition in the baseline IP.  However, the overall intent of the baseline inspection procedure must continue to be met, and these situations should be discussed with appropriate regional management.

For sites where there are multiple units undergoing an EPU (under one license amendment request), performing an inspection sample on one unit and crediting that sample for both units may be warranted.  This will depend on the nature of the EPU, the design of the plant and, the specifics of the inspection.

A sample should be selected from each of the following areas, as available:

a. 10 CFR 50.59 evaluations that are required for power uprate from the following:

1. Changes to facility as described in UFSAR

2. Changes to procedures as described in UFSAR

3. Tests or experiments not described in UFSAR

Consider implementing IP 71111.17T, IP 71111.18, or IP 71111.21M.  The inspection sample selection should evaluate the impact of extended power uprates on safety analysis margins.  Some inspection may take place before power increases above the previously licensed power setpoint, whereas testing of some modifications, power ascension testing, and integrated system testing may not be conducted until the original licensing limit for rated power output is exceeded, and the new licensing limit for rated power output approached and even reached.

b. Risk-significant plant modifications implemented for the power uprate.  Risk-significant modifications may include the following:

1. Modifications which impact Emergency Core Cooling System (ECCS) initiation, or the ability of an ECCS system to mitigate an event.

2. Modifications which impact heat exchanger performance.

3. Modifications which could contribute to the initiation of an event following installation (e.g., higher core power densities; increased flow in primary, secondary, or their interfacing systems; and synergistic effects).

Consider changes to balance of plant systems or components that could increase the likelihood of an initiating event (such as a loss of offsite power, a reactor trip, or a reactor trip without heat sink).

Consider flow rates and whether the licensee is analyzing the long-term effects and adopting a means to monitor those effects in accordance with NRC SE.  Preferably the inspector should witness an actual flow test when verifying flow rates but the review of flow test results is acceptable.

Consider changes that impact the integrity of barriers (e.g., higher flow rates in a primary or secondary system which increases flow-accelerated corrosion on internal piping surfaces and vibration at specific support points which then results in increased likelihood of leaks).

Consider changes which result in higher flow rates internal to the core / inside the reactor vessel, which can cause components to degrade / fail due to flow induced / acoustic vibrations.  Licensees should be aware of industry experience regarding these issues, analyze impacts of EPU on reactor vessel components, and monitor vibrations / structural integrity of vessel components.

4. Modifications which implement new equipment set points on risk-significant equipment. This includes the effects on design margins, instrument inaccuracy assumptions, accident analysis assumptions, and operator responses.

5. Modifications which caused unexpected problems when installed at another plant.

Consider implementing IP 71111.17T, or IP 71111.18; and consider performing IP 71111.07 for heat exchangers in mitigating systems included in samples selected.  Consider concentrating on changes to systems, e.g., RHR system, ECCS systems, or secondary systems with changes that may adversely impact primary systems plant safety.

c. Mitigating systems or components modified for power uprate for which surveillance testing or startup testing will be performed.

For post-maintenance or surveillance tests conducted by licensee for mitigating systems or radiation barriers, consider implementing IP 71111.19 or IP 71111.22.  Consider focusing on those surveillance tests that affect core or containment cooling, higher flow rates in primary system or an ECCS, etc.

d. Major tests to be monitored and evaluated (e.g., turbine load reject trip, runback, Main Steam Isolation Valve (MSIV) closure from full power, or Loss of Offsite Power tests).

Consider witnessing or reviewing test results of any major plant tests including MSIV closure.  A partial test may consist of verifying the operation of control and protective circuitry for either a turbine load reject or loss of offsite power test without actually putting the plant through an actual transient or actually demonstrating excess decay heat removal.    The inspector should evaluate the major test procedures, prior to their being performed, to ensure the test can be conducted.  The inspector should also witness or review the results of any power ascension tests to ensure that the licensee correctly predicted plant response, and charge that effort to this IP (IP 71004).  The testing portion of the approved license amendment or NRC SE should provide guidance on major test details like installation of sensors, requisite plant conditions, and prescribed actions.

e. Operator actions during integrated plant evolutions (e.g., power changes) being conducted by the licensee during initial power ascension and at the uprated power level.

Consider witnessing initial power ascension after implementing changes for power uprate and observing operator actions in accordance with IP 71111.20.  Also, as appropriate consider using IP 71111.11 under requalification training as a means to observe plant evolutions.  The inspector should focus on those operator actions that affect risk-significant mitigating systems or radiation barriers.  The inspector may also observe any modified operator actions for BOP systems that may initiate plant transient events.

f. Risk-significant concerns identified by licensee’s flow accelerated corrosion (FAC) and erosion corrosion programs which could be exacerbated by power uprate changes or evolutions.

Consider implementing IP 49001 to review the licensee’s erosion and FAC programs, as required, and charge that effort to this IP (IP 71004).  The concerns selected can be from BOP systems if they are risk significant.  If there are concerns from multiple systems, then consider selecting the one that is the most risk significant so that estimated resources for this sample will be approximately 25 hours.  For assistance in selecting samples, inspectors may refer to the FAC section of the NRC SE (Section 2.1.8 for Pressurized Water Reactors, and Section 2.1.6 for Boiling Water Reactors).

g. Licensee required actions.  Consider obtaining a copy of the NRC SE and reviewing Section 4.0, “Regulatory Commitments” and Section 5.0, “Recommended Areas for Inspection” for any licensee actions.  In addition, consider reviewing any license conditions related to the power uprate.  Consider if the licensee has taken all required actions to address the effects of new or more probable initiating events as stated in license amendment, licensee commitments, or in the NRC SE, and charge that effort to the most applicable baseline IP or to this IP (IP 71004) if necessary.  The inspector should merely confirm the sample items to verify that the licensee has performed the required actions.  The inspector should not repeat the initial analysis, or the evaluation found in the NRC SE.

Identification and Resolution of Problems.  Consider verifying that the licensee is identifying problems related to power uprate, at an appropriate threshold, and entering them in the corrective action program (CAP).  Consider selecting a sample of problems documented in the CAP (focusing mainly on mitigating systems) to verify that the licensee has appropriately resolved the technical concerns and regulatory requirements.  See Inspection Procedure 71152, “Identification and Resolution of Problems,” for additional guidance.

# 71004-04	RESOURCES ESTIMATE

The estimated resource expenditure for this inspection procedure is 32 to 64 hours.  This does not include the baseline inspection effort referenced by this procedure.  Approximately 100-150 hours are expected to be credited toward baseline inspections as part of the normal conduct of those procedures.  These are general estimates, provided for planning purposes only; they should not be viewed as requirements.  Inspectors should use their experience and expertise (along with input from management) to determine how much time should be dedicated to specific inspection efforts.

This inspection procedure integrates the results of several baseline inspection procedures being performed under the established risk-informed baseline inspection program and that are related to plant modifications and testing associated with an approved increase in licensed reactor power.  Most inspection activities for a power uprate should be conducted within the normal resource constraints of the baseline procedures being implemented.  The types of samples selected for those baseline procedures should be as stated in this inspection procedure.  Whenever possible, the sample size stated in that particular baseline procedure should be adhered to on an annualized basis.  In certain instances, the IP 71004 inspection sample may not correlate 100 percent with the referenced baseline inspection procedure.  In these situations, it may be appropriate to perform the inspection requirements necessary for the power uprate inspection and to credit the corollary baseline sample as complete, even if the sample was modified slightly from the definition in the baseline IP.  However, the overall intent of the baseline inspection procedure must continue to be met, and these situations should be discussed with appropriate regional management.

The intent is not to redirect baseline inspection efforts, but to complete the requirements of this inspection procedure concurrently when possible.  Every effort should be made to schedule baseline inspection procedures that have a frequency of greater than annually to coincide with the licensee’s EPU activities.  However, scheduling of such inspections, and the allotment of required resources, remains the discretion of regional management.

This inspection should be performed by inspectors (e.g., engineering specialists) knowledgeable in the affected subject areas.

# 71004-05	PROCEDURE COMPLETION

Samples selected for inspection should verify that the power uprate can be achieved in a safe manner.  Inspection of the samples that were developed as part of the inspection plan (and its revisions) constitutes completion of this procedure.  Completion of the samples shall be described in the roadmap documentation of an integrated inspection report.  An example of a roadmap documentation of an integrated inspection report can be found in ADAMS under ML20042C802.

Issues will be documented as required by IMC 0611 in the integrated inspection report for the time period when the inspection occurred.  Because IP 71004 integrates several baseline and other inspection procedures, the inspection scope is key in recording the NRC effort to complete IP 71004.  The scope should accurately describe the activities inspected consistent with the inspection plan. 

Section, “Other Activities – Temporary Instructions, Infrequent and Abnormal,” of the report should contain all IP 71004 samples that were completed, regardless of an associated baseline inspection procedure.  The idea is to maintain a single inspection report entry point for all IP 71004 samples within section “Other Activities – Temporary Instructions, Infrequent and Abnormal.”  Those IP 71004 samples that also suffice for baseline inspection samples should be documented in the applicable section of the integrated inspection report and referenced in section “Other Activities – Temporary Instructions, Infrequent and Abnormal.”  For example, a surveillance inspection activity should be primarily documented in Section  “71111.22 –  Surveillance Testing.”  Meanwhile, the activity should also be listed in section “Other Activities – Temporary Instructions, Infrequent and Abnormal,” as a sample performed for IP 71004; and refer the reader to Section 71111.22 for more information on the details of the surveillance inspection activity.

Separately, once it has been verified that all IP 71004 sample requirements have been completed and recorded, consistent with the inspection plan, a summary of the inspection activities should be provided in section “Other Activities – Temporary Instructions, Infrequent and Abnormal,” of the integrated inspection report. The summary should include a description of each sample, the inspection procedure used to inspect the sample, and the applicable inspection report(s) the samples were documented in.  The intent is to provide a roadmap to all inspection reports that document power uprate-related inspection activities. 

Findings associated with the performance of IP 71004 (including those identified through a referenced baseline procedure) should include the words “power uprate” (preferably in the title) in order to facilitate tracking and trending efforts.

# 71004-06	REFERENCES

IP 49001, “Inspection of Erosion-Corrosion / Flow-Accelerated-Corrosion Monitoring Programs”

IP 71111.07, “Heat Exchanger/Sink Performance”

IP 71111.11, “Licensed Operator Requalification Program and Licensed Operator Performance”

IP 71111.17T, “Evaluations of Changes, Tests, and Experiments”

IP 71111.18, “Plant Modifications”

IP 71111.19, “Post-Maintenance Testing”

IP 71111.20, “Refueling and Other Outage Activities”

IP 71111.21M, “Design Bases Assurance Inspection (Team)”

IP 71111.22, “Surveillance Testing”

IP 71152, “Problem Identification and Resolution”

Review Standard RS-001, “Review Standard for Extended Power Uprates”

# END

71004		Issue Date: 05/09/06

Issue Date:  02/09/22	1	71004

Attachment 1:  Example EPU Inspection Plan

Background:

In *month, year*, the NRC accepted a power uprate license amendment application from *licensee* for *plant name*.  The proposed amendment will increase the thermal power output of *plant name* from *xxxx* megawatts thermal (MWt) to *xxxx* MWt, which is an increase of approximately *xx* percent.  The power level increase is considered an extended power uprate (EPU), and is within the scope of Inspection Procedure 71004, “Power Uprate.”  It is projected that *plant name* will implement the EPU in *month, year*, following NRC approval of the license amendment.  To facilitate the power increase, *licensee* has installed, or plans to install the following modifications:

*Modifications and expected schedule dates*.

Inspection Requirements:

NRC Inspection Procedure 71004, “Power Uprate,” requires several samples for inspection.  Table 1 provides an inspection schedule.  Some inspection samples will be determined following a review of the NRC Safety Evaluation Report which is projected to be issued in *month, year*.

Resource Recommendations:

As shown in Table 1, the inspection activities for IP 71004 will be an integrated effort utilizing the resident staff and staff from appropriate regional engineering / technical branches.  Table 1 lists the minimum required inspection activities, as well as a recommendation as to who should perform those inspections.  The resource expenditure for IP 71004 is 32 to 64 hours, without regard to the number of units at a site and does not include the baseline inspection effort.  Approximately 100-150 hours are expected to be credited toward baseline inspection procedures. 

Issued Date:  02/09/22	Att1-1		71004

Issued Date:  02/09/22		Att1-1		71004

Attachment 2:  Revision History for IP 71004

Issue Date:  02/09/22	Att2-1	71004