ML24110A141
ML24110A141 | |
Person / Time | |
---|---|
Issue date: | 06/06/2024 |
From: | Theresa Clark, Mike Franovich, Martinez-Navedo T, Bo Pham NRC/NRR/DEX, Division of Operating Reactor Licensing, NRC/NRR/DRA, NRC/NRR/DSS |
To: | Mark King, Andrea Kock Office of Nuclear Reactor Regulation |
Rankin J, NRR/DORL/LPL4 | |
References | |
Download: ML24110A141 (1) | |
Text
June 6, 2024 MEMORANDUM TO:
Michael F. King, Deputy Director Office of Nuclear Reactor Regulation Andrea L. Kock, Deputy Director Office of Nuclear Reactor Regulation FROM:
Bo M. Pham, Director
/RA/
Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Theresa Clark, Director
/RA/
Division of Safety Systems Office of Nuclear Reactor Regulation Michael X. Franovich, Director /RA Meena Khanna for/
Division of Risk Assessment Office of Nuclear Reactor Regulation Tania Martinez Navedo, Acting Director
/RA/
Division of Engineering and External Hazards Office of Nuclear Reactor Regulation
SUBJECT:
ISSUANCE OF THE POWER UPRATE PROJECT PLAN, REVISION 0 This memorandum transmits the enclosed Power Uprate Project Plan. This Project Plan focuses on the U.S. Nuclear Regulatory Commissions (NRC) preparations to conduct efficient and effective reviews of power uprate (PUR) applications. Specifically, the NRC staff is currently working toward the following deliverables:
- 1. PUR Project Plan: This document represents the high-level strategy to prepare the NRC for conducting efficient and effective reviews of PUR licensing actions.
- 2. PUR Core Team Charter: Guides the staff in establishing and maintaining a core team that will be responsible for reviewing upcoming PUR applications.
- 3. PUR Regulatory Issues Summary: Requests information on planned PUR related licensing submittals for all power reactor licensees.
- 4. PUR Communication Plan: Internal NRC document used in conjunction with the PUR Project Plan to engage internal and external stakeholders.
- 5. Staff Recommendations to Streamline/Improve PUR Reviews: Review of NRC licensing processes and guidance to streamline, focus, and prepare for future PUR reviews.
CONTACT: Thomas J. Byrd, NRR/DORL 301-415-3719
M. King, et al.
The Project Plan also provides a schedule for deliverables and includes targeted public interactions in addition to those listed in the PUR Communication Plan. The Project Plan will be revised following the issuance of the staffs recommendations to streamline/improve the PUR process as the staff moves toward implementation of recommendations.
Enclosure:
Power Uprate Project Plan, Revision 0
Enclosure POWER UPRATE PROJECT PLAN REVSION 0 JUNE 2024
1.0 INTRODUCTION
The U.S. Nuclear Regulatory Commission (NRC) is committed to improving and optimizing our reviews such that the review time and hours reflect the best use of resources, commensurate with the safety significance. The NRC is optimistic that its preparation strategy for the future review of power uprates (PURs) will support licensee schedules, while still providing reasonable assurance of public health and safety at U.S. nuclear power facilities. The NRC understands that it may face challenges in its preparations, technical, and licensing reviews, but it is committed to working through such challenges in a thoughtful, deliberative, and timely manner.
The staff has developed this plan to increase regulatory stability and certainty, as well as to enhance and optimize the staffs reviews of PURs. The staff believes that adherence to this strategy will benefit the agencys stakeholders in the future reviews of PURs.
The NRC staff intends to conduct targeted engagement with its stakeholders in the development and finalization of each version of the Project Plan, consistent with the NRCs Principles of Good Regulation. The staff will hold public meetings with external stakeholders, including licensees and their vendors, industry groups, and non-governmental organizations, as detailed in this Project Plan.
This Project Plan presents the high-level strategy that the staff will follow to ensure that it is ready to review PUR licensing actions. At this point, the strategy is concept-and technology-independent.
2.0 BACKGROUND
The NRC regulates the maximum allowable heat output of commercial nuclear power plant reactor cores. This output, or power level, is used with other data in many of the licensing analyses that demonstrate the safety of the plant. This power level is included in the license for each plant. The NRC controls any changes to a license or technical specifications, and the licensee may only change these documents after the NRC approves the licensees application for change. The process of increasing a reactors maximum heat output is called a PUR. The three categories of PURs are: measurement uncertainty recapture (MUR), stretch PUR (SPU),
and extended PUR (EPU).
Since 2000, the NRC has approved over 120 PURs. Guidance currently exists for PUR reviews via the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-112: Power Uprate Process (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19254A627), which provides guidance for the coordination of all aspects of PUR activities and identifies roles and responsibilities for PUR reviews.
Multiple divisions in NRR will be involved in the PUR application reviews. The Division of Operating Reactor Licensing (DORL) has the lead for project management of these reviews, which consists of developing guidance, tracking, and managing reviews of all applications for
operating reactors. DORL, utilizing the guidance in LIC-112, will coordinate with the applicable NRR technical divisions for the review of these applications. To optimize future PUR reviews, implementation of a core team concept builds on efficiencies within LIC-112s existing infrastructure by delineating specific duties and responsibilities for complex reviews. Refer to the PUR core team charter (ML24156A109) for additional information, regarding duties and responsibilities.
The Inflation Reduction Act production tax credits (available through 2032), along with the Civil Nuclear Credit Program and Bipartisan Infrastructure Bill of 2021, have generated significant industry interest in PURs. In June 2023, the NRC issued Regulatory Issue Summary (RIS) 2023-02, Scheduling Information for the Licensing of Accident Tolerant, Increased Enrichment, and Higher Burnup Fuels (ML23123A166). A 2023 Nuclear Energy Institute (NEI) survey indicated that licensees for over 50 percent of the reactor sites have shown interest in pursuing PURs for their sites. In August 2023, Idaho National Laboratory (INL), in coordination with MPR Associates and NEI, published INL/RPT-23-74681, Assessing the Impact of the Inflation Reduction Act on Nuclear Power Uprate and Hydrogen Cogeneration (ML23276B406).
The report provides a financial assessment and modeling tool for decisions regarding the timing and types of PURs, given the tax credits in the Inflation Reduction Act.
3.0 LICENSING PROCESSES This Project Plan focuses on the NRCs preparations to conduct efficient and effective reviews of PUR applications and internal NRC timelines for these reviews.
A licensee must submit a plant-specific license amendment request (LAR) to modify its license to allow for the use of an emerging technology or methodology to enable PURs. The licensees address all plant-specific aspects of implementation in these LARs. The latest timeliness goals established for PUR LARs are 9 months for MURs, 12 months for SPUs, and 18 months for EPUs; however, prior to delays experienced during the 2011-2012 timeframe, the staff had been able to target 6, 9, and 12 month reviews for MUR, SPU, and EPU LARs, respectively.
Ultimately, the length of time required to review a new PUR application will be heavily dependent on many factors, including the quality of the application, number of aspects of the request (e.g., PUR combined with an accident tolerant fuel concept such as higher burnup or increased enrichment), and other relevant submittal information. Approximate LAR review timelines can only be provided to industry when applications are received, and an acceptance review is performed to determine the scope of the review. LARs that combine PURs with other licensing actions will need to be evaluated by staff on a case-by-case basis.
4.0 STAKEHOLDER INTERACTIONS The NRC employs early communications with stakeholders to maintain transparency and provide regulatory stability through the issuance of documents and proactive discussions during public meetings, conferences, and NRC-led workshops. The NRC is committed to actively engage in industry project update meetings to maintain awareness of industry efforts to prepare for regulatory reviews. The staff will continue to follow existing NRC policies for all stakeholder interactions.
The NRCs stakeholder communications are designed to:
Allow NRC staff to gain stakeholder feedback on the PUR review process and suggested areas for process enhancements including areas where PUR reviews can be graded based on safety significance.
Allow NRC staff to become more familiar with PURs and related licensing actions, which will help enable more efficient reviews or associated applications.
Remain closely engaged with the relevant organizations and entities and adjust this Project Plan as new information becomes available.
Prevent delayed recognition of required guidance changes to reduce schedule risk. The staff has initiated dialogue with stakeholders to communicate timelines required for modifications to the regulatory infrastructure and to solicit input for changes that may be necessary for the different types of PURs.
Allow for a more efficient NRC resource reallocation, as needed, due to industry changes in direction and schedules.
Allow for coordination with licensees to ensure applications for PURs are received and processed to allow concurrent reviews while mitigating schedule risks.
Refer to the PUR communications plan for additional information on stakeholder communications (Package ML24025A160; not publicly available).
5.0 PREPARATORY ACTIVITIES The NRC PUR Project Team is led by the DORL Front Office. The DORL staff will use the Power Uprate SharePoint site and Power Uprate Dashboard to organize documents and manage milestones and deliverables. These internal tools will be used during the bi-weekly Project Team meetings as well as monthly meetings with the NRR Executive Team.
The NRC staff is currently working toward the following deliverables:
- 1. PUR Project Plan: Represents the high-level strategy to prepare the NRC for conducting efficient and effective reviews of PUR licensing actions.
- 2. PUR Core Team Charter: Guides the staff in establishing and maintaining a core team that will be responsible for reviewing upcoming PUR applications.
- 3. PUR Regulatory Issue Summary: Requests information on planned PUR related licensing submittals for all power reactor licensees.
- 4. PUR Communication Plan: Internal NRC document used in conjunction with the PUR Project Plan to engage internal and external stakeholders.
- 5. Staff Recommendations to Streamline/Improve PUR Reviews: Review of NRC licensing processes and guidance to streamline and focus the PUR reviews on the most safety significant aspects consistent with the NRC principles of good regulation and the Be riskSMART framework for integrating risk insights into NRC decisions, as appropriate.
6.0 PATH FORWARD This Project Plan is intended to be a living document that may evolve as industry plans are refined and the state of knowledge for PURs advance. The staff will continue to utilize industry interactions and evaluate internal processes to increase efficiency and timeliness associated with PUR reviews, while still maintaining its safety mission.
The staffs priority is to: (1) engage directly with the nuclear industry on plans to utilize the incentives, technology, and processes to seek PUR licensing actions; (2) streamline PUR reviews while utilizing modern project management tools and focus the PUR review process using the Be riskSMART framework, as appropriate; and (3) understand the areas of margin recovery or operational flexibility that licensees plan to seek so that staff can begin to proactively refine the regulatory review framework for PUR reviews, where necessary.
PROPOSED PROJECT PLAN Activity Target Date Estimated Level of Effort Develop draft PUR Project Plan, Core Team Charter, and Communication Plan May 2024 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> Introduce the staffs plan at the May Industry Meetings May 2024 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> Finalize PUR Project Plan, Core Team Charter, and Communication Plan.
June 2024 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> Conduct Public Meeting #1: Introduce the NRCs PUR improvement efforts. Discuss Core Team Charter, Communications Plan, Project Plan, PUR RIS, and NRC actions pertaining to expected PUR applications.
June 2024 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> (includes staff support during the meeting)
Complete draft recommendations for streamlining/improving the PUR review process Early August 2024 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> Conduct Public Meeting #2: Interactive workshop for stakeholders to provide comments on areas of potential improvement on PUR evaluations.
Mid-August 2024 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> (includes staff support during the meeting)
Public provide any additional written feedback to NRC following Public Meeting #2.
Early September 2024 N/A Issue the staffs recommendations to streamline/improve the PUR review process September 2024 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> Issue the RIS Tentatively August/September 2024 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> Conduct Public Meeting #3: Discuss responses received for the PUR RIS, expected burden on NRC staff, and scheduling of licensee submittals to minimize scheduling conflicts.
~6 months after RIS Issuance (tentatively February 2025 pending RIS issuance) 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> Update and Maintain Public Webpage as necessary
~6 months after RIS issuance and on an ongoing basis 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per update Update and/or add pages to Nuclepedia to describe PURs, streamlining and improvements, references developed for Agency usage.
March 2025, update as necessary on ongoing basis 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> per page Familiarize DORL project managers with streamlined PUR review approach.
At division meeting prior to first expected application 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Revise LIC-112 and associated guidance Following the completion of at least one EPU review 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />
ML24110A141 NRR-106 OFFICE NRR/DORL/PM NRR/DORL/LA NRR/DORL/BC NRR/DSS/D NAME TByrd PBlechman JRankin TClarke DATE 4/22/2024 4/24/2024 4/25/2024 6/4/2024 OFFICE NRR/DRA/D NRR/DEX/D (A)
NRR/DORL/D NAME MFranovich (MKhanna for) TNavedo BPham DATE 6/4/2024 6/4/2024 6/6/2024