The NRC Reviews the Package
The process for amending commercial nuclear power plant licenses and technical specifications for power uprates is the same as the process used for other license amendments. Therefore, EPU requests are submitted to the NRC as a License Amendment Request. This process is governed by 10 CFR 50.4, 10 CFR 50.90, 10 CFR 50.91, and 10 CRF 50.92.
After a licensee submits an application to change the power level at which it operates its plant, the NRC notifies the public by issuing a public notice in the Federal Register, stating that the NRC is considering the application. The public has 30 days to comment on the licensee’s request and 60 days to request a hearing.
The NRC thoroughly reviews the application, any public comments, and any requests for hearings received from the public. Additional information will surely be requested on the application through the NRC Request for Additional Information process.
After the NRC accepts the owner’s application, the NRC issues a public notice in the Federal Register stating that the NRC is considering the application. The public has 30 days to comment on the licensee’s request and 60 days to request a hearing.
Additional information for the LAR is expected to be requested through the NRC Request for Additional Information process. All EPU submittals will then require an Advisory Committee on Reactor Safety (ACRS) meeting. After the NRC and ACRS complete their review, and consider and address any public comments and requests for hearings related to the application, the NRC will issue its findings in a safety evaluation report. The NRC may approve or deny the power uprate request. A notice will then be placed in the Federal Register regarding the NRC decision.
The LAR for an EPU is an extensive evaluation of virtually every aspect of a plant’s operating experience, and it could expose the licensee to questions about the current licensing basis, including public hearings. The licensee has to manage the risk that its LAR may bring attention to unique features that may be reevaluated by the NRC and be subject to public hearings.
The LAR for an EPU is extensive, involves evaluating virtually every aspect of a plant’s operating experience, and exposes the licensee to questions about the current licensing basis, including public hearings. The licensee has to manage the risk that its LAR may bring attention to unique features that may be reevaluated by the NRC and be subject to public hearings. NRC commitments to review the LAR include a 12-month review cycle for acceptance of the EPU submittal.
Perform the Uprates
Implementation of the modifications requires extremely focused management planning and execution processes that are more complex than those of typical maintenance outage activities. Modifications are typically prepared in the form of design change packages. Some EPU programs require more than 50 major design change packages, all under the purview of a strict quality assurance program. These packages include detailed design documents and a step-by-step process for field implementation.
Engineers, procurement staff, and construction experts work hand-in-hand to provide the design details to ensure that the configuration management and design control process required by the utility are maintained. Equally important, they ensure that the modification can be completed in a safe and efficient manner that results in a quality product, often in very confined quarters. Care must be taken to ensure that no damage occurs to adjacent equipment outside the boundaries of the modification.
INPO guidance suggests that each design package is completed and approved by designated plant personnel one year in advance of the planned outage, and utilities typically work toward this goal. Actual hardware implementation is generally performed over two or more refueling outages to minimize plant downtime. Because major portions of the plant, particularly the BOP, will be subject to major rework, execution of the outage plays a major role in the overall success of the EPU.
Work in an operating plant introduces a whole new set of complexities, compared to new construction. During each plant outage the utility must purchase replacement power. Outages are performed during off-peak periods, when electrical demand is low. Based on weather conditions and what other units the utility may own (for example, less-efficient coal plants or gas turbines), there may either not be a need for replacement power, or the utility may operate less-efficient assets (and purchase replacement power). To keep the costs of replacement power as low as possible, it is important to keep outage time to a minimum.
The success of an EPU program relies heavily on the quality of the management team and their ability to develop an effective integrated implementation plan, to schedule the work effectively, and to provide controls to ensure that those schedules are carried out.
The scheduling effort is a critical component in controlling implementation costs. Minute details are included in the schedule, identifying construction installation activities that occur on each outage shift. Each of the work packages is integrated with all of the other packages, as well as with other unrelated but required outage activities, so that the availability of cranes, access to space, and the availability of critical tools and other resources are met for all of the required tasks. It is also critical that the necessary trained human resources are available on a 24/7 basis during all of the implementation outages.
A detailed power ascension testing and monitoring program needs to be developed early in the process to allow its implementation following completion of the outage, ensuring that each system and component performs its intended functions.
—Eugene W. Thomas (ewthomas@bechtel.com) is an engineering manager for Bechtel Power Corp.
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