ML20213F111
| ML20213F111 | |
| Person / Time | |
|---|---|
| Site: | North Anna, Duane Arnold, 05000000 |
| Issue date: | 01/09/1985 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Bernero R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8501230625 | |
| Download: ML20213F111 (3) | |
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8 NUCLEAR REGULATORY COMMISSION WASHf NCTON, D. C. 20555 January 9,1985 MEMORANDUM FOR:
Robert M. Bernero, Director, Division of Systems Integration, NRR FROM:
Darrell G. Eisenhut, Director, Division of Licensing, NRR
SUBJECT:
DIVISION OF LICENSING POSITION ON POWER UPRATING By memorandum dated October 23, 1984 you requested that the Division of Licensing take the lead to develop an NRC policy on review of power uprating. The action was initiated by a Westinghouse report (WCAP-10263) on the subject.
NRC's records reveal that power uprating is not a novel idea. _Several operating plants have requested and obtained amendments to their licenses to allow increased thennal power levels, and the staff is currently evaluating similar applications on others (Duane Arnold and North Anna). We note that in all these cases, the requested power increases have been bound by the
" stretch power" level, the level to which the plant has been evaluated by the licensee and the staff prior to license issuance.
This " stretch power" has been termed " Engineered Safeguards Design Ratina (ESDR)" in the Westinghouse report. We understand that only minimal modifications (minor adjustments) need to be done to a plant in order to allow it to operate up to the " stretch power" level.
For power increases beyond " stretch power",
major hardware changes would probably be required and would entail considerable work on the part of an interested licensee.
No such application is envisioned in the foreseeable future.
If any licensee contemplates uprating to beyond " stretch power", he is encouraged to discuss the matter, prior to any major resource expenditure, with his DL project manager who will then arrange a meeting with other NRC staff members.
For plants whose reviews did not involve " stretch power" but do have such capability, the request would still be reviewed according to the positions stated in this memo; understandably, such a review would involve more work than one which has already been reviewed at the " stretch power" level.
With such facts in mind, we take the position that a power uprating amendment request should be treated as a plant-specific action and be reviewed according to current codes, standards, Regulatory Guides, calculational models, etc.
In order to issue an amendment, there must be a current finding of compliance with regulations applicable to the amendment for the higher power.
For those plants that have been reviewed at the
" stretch power" level, the review for power uprating should be relatively simple.
We have studied the major points of the W report. We in general agree with the report but do have the following major concerns:
Contact:
P. Tam 2-7829
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g Robert M. Bernero January 9, 1985 The W report does not appear to be limited to stretch power applications only. As discussed in your memo, an application involving substantial alterations in the facility involves a number of complex issues. Our position is as stated in the paragraphs above.
We disagree with Westinghouse's proposition on page 5 of the report.
As indicated above, in order to issue an amendment to an operating license the staff must make a current finding of compliance with Comission ' regulations applicable to the amendment.
For the staff to accept the original licensing. basis for a system affected by the change in power level, the staff must either find that the original licensing basis continues to-be in compliance with the current regulations (and current understanding or interpretation of what the regulations involved mean),.or must determine that the licensee's system is adequate to warrant an exemption. For example, if the models used in the original licensing basis were more conservative than current models, they presumably would still be an adequate basis for a present finding of compliance.
If newer models are more conservative than older models the question becomes "why?".
If it is because there is new information demonstrating that the older models are incorrect,-then older models probably could not support a current finding of compliance.
Similiarly, if a staff interpretation of a regulation has changed over the course of years principally involving clarity, it may well be that a design based on an old interpretation would still be adequate to support a current finding of compliance.
On the other hand, if the new information (ge in staff interpretation of. regulation _ is based.on reason for a channew from the time the plant was originally licensed) which would indicate that the old interpretation is not correct or may lead to unsafe conditions, the old-interpretation may not be able to support a current finding of compliance.
In addition, th.e "backfit policy" might need to be addressed.
We do not believe it appropriate for the staff to develop a review policy for W plants only. Our position on power uprating, as stated in this memo, should be applicable to plants of all vendors.
We do not regard the W report as a technical report.
It basically suggested a -policy and standard format and content guide to the staff covering review of power uprating u'p to about 110% of power.
We, therefore, cannot recommend that the staff issue an SER on this report.-
Instead, with the concurrence of other NRR divisions, we propose to issue a letter to Westinghouse communicating all the points in this memorandum.
Regarding your specific questions, following are our answers:
- 1) Part 51 (NEPA) - If the staff has issued a Final Environmnetal Statement (FES) in connection with the operating license which analyzes plant operation at the " stretch power" level, the increase in power up to stretch power alone would not require a new EIS. However, other aspects of the
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Robert M. Bernero January 9, 1985 amendment may, for other reasons, require an Environmental Assessment or an EIS in accordance with Part 51.
If the increase in power is not bounded by the. power level addressed in the OL FES, all environmental impacts affected by the higher power level would have to be redone and a revised FES would be needed.
- 2) and 3) Hearing - The Comission has determined that any action involving an increase in authorized power level is one that involves significant hazards considerations (48 FR 14870). Members of the public may request a hearing on the action.
- 4) Section 50.92, Issuance of Amendment - Power uprating will be treated in the same way as other amendments when the increase is bounded by " stretch power" level.
If the requested level exceeds " stretch power", there may be need for hardware changes to the plant and the staff may decide that such would constitute " material alteration of a licensed facility".
The provision of this Section would govern.
We have consulted with OELD and have incorporated OELD's conrnents into this memo.
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.Eibnhu, Director
> Division of Licensing, NRR
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