LR-N25-0097, Inservice Testing Program Relief Requests - Fifth Ten-Year Interval

Inservice Testing Program Relief Requests - Fifth Ten-Year Interval

ML26006A183
Person / Time
Site:	Hope Creek
Issue date:	01/06/2026
From:	Jurek S Public Service Enterprise Group
To:	Office of Nuclear Reactor Regulation
References
LR-N25-0097
Download: ML26006A183 (0)

Text

Shane Jurek Regulatory Programs Manager - Licensing, PSEG Nuclear PO Box 236 Hancocks Bridge, New Jersey 08038-0221 Shane.Jurek@PSEG.com LR-N25-0097 10 CFR 50.55a January 6, 2026 US Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 Subject :

Inservice Testing Program Relief Requests - Fifth Ten-Year Interval In accordance with 10 CFR 50.55a(z)(1), PSEG Nuclear LLC (PSEG), hereby requests NRC approval of the attached relief requests for the fifth ten-year interval of the Inservice Testing (IST) program for the Hope Creek Generating Station. The requests propose alternatives to the requirements of the 2022 Edition of the American Society of Mechanical Engineers Operation and Maintenance Code. As noted in the attachments, two of the requests (PR-02 and VR-01) are approved for the current (fourth) IST ten-year interval. Where applicable, the requests are identified by the same request number for the fourth interval. The fifth IST ten-year interval will begin on December 21, 2026.

PSEG requests approval of this request by December 20, 2026.

There are no new or revised regulatory commitments contained in this submittal.

If there are any questions or if additional information is needed, please contact Eric Otruba at Eric.Otruba@PSEG.com.

Respectfully, Shane Jurek Regulatory Programs Manager - Licensing PSEG Nuclear o PSEG I NUCLEAR

LR-N25-0097 10 CFR 50.55a Page 2 Attachments:

1. 10 CFR 50.55a Request PR-02

2. 10 CFR 50.55a Request PR-03

3. 10 CFR 50.55a Request VR-01

4. 10 CFR 50.55a Request VR-04 cc:

Administrator - Region I - USNRC NRC Project Manager - Hope Creek NRC Senior Resident Inspector - Hope Creek Manager, New Jersey Bureau of Nuclear Engineering PSEG Commitment Tracking Coordinator

LR-N25-0097 Page 1 of 3, 10 CFR 50.55a Request PR-02 RCIC Pump Flow Instrument Accuracy Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

--Alternative Provides Acceptable Level of Quality and Safety--

1 ASME Code Components Affected Reactor Core Isolation Cooling (RCIC) Pump, 10P203 (Class 2 Group B)

While not credited as an Emergency Core Cooling System (ECCS) component, the RCIC Pump is safety-related and provides demineralized make-up water to the reactor vessel in the event that the reactor vessel is isolated.

2

Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code, Operation and Maintenance of Nuclear Power Plants, 2022 Edition, no Addenda.

3

Applicable Code Requirement

Subsection ISTB, Paragraph ISTB-3510, General, subparagraph (a), Accuracy, states, in part, Instrument accuracy shall be within the limits of Table ISTB-3510-1. If a parameter is determined by analytical methods instead of measurement, then the determination shall meet the parameter accuracy requirement of Table ISTB-3510-1 (e.g., flow rate determination shall be accurate to within +/-2% of actual). For individual analog instruments, the required accuracy is percent of full scale.

4

Reason for Request

Pursuant to 10 CFR 50.55a(z)(1), an alternative is proposed to the requirement of ASME OM Code paragraph ISTB-3510(a).

In addition to ISTB-3510(a), instrumentation is addressed in ISTB-3510(b)(1) which requires that the full-scale range of each analog instrument be not greater than three times the reference value. For instruments to be in compliance with the Code, both of these requirements must be met, individually, for each instrument. The combination of the two requirements (i.e., accuracy equal to +/-2 % of full scale and full scale being up to 3 times the reference value) yields a permissible inaccuracy of +/-6% of the reference value.

The permanently installed flow instrument 1 FCFIC-R600-E51 does not meet the 2 percent acceptable instrument accuracy specified in Table ISTB-3510-1.

5 Proposed Alternative and Basis for Use As a proposed alternative, PSEG Nuclear LLC (PSEG) proposes to use the currently installed analog instruments for measurement of flow for the identified equipment. Although this instrument does not explicitly meet the requirements of ISTB-3510(a), it provides better indication accuracy at the reference value than that which is permitted by the Code when taking the requirements of ISTB-3510(a) and ISTB-3510(b)(1) together as a whole.

LR-N25-0097 Page 2 of 3 The supporting data table below lists the actual instrument loop accuracy. This loop accuracy has been calculated from the transmitter to the indicator in the main control room.

As indicated in the table below, the installed instrumentation has a full-scale range of 700 gpm, which only slightly exceeds the pump flow reference value of 600 gpm (full scale equals 1.17 times reference) with an accuracy of +/-2.49% of full scale. This results in flow rate measurements accurate to +/-2.9% of indicated flow at reference conditions (600 gpm), which is more conservative than the 6 percent minimum accuracy allowed by the combination of instrument full-scale range and accuracy allowed in Subsection ISTB. The current instrumentation provides sufficient repeatability to allow for an evaluation of the pump hydraulic condition and detect pump degradation.

Supporting Data Table Instrument Number: 1 FCFIC-R600-E51 Actual Instrument Range: 0-700 gpm Actual Gauge (Loop) Accuracy: +/-2.49%

Test Reference Value: 600 gpm Code Allowable Instrument Range: 1,800 gpm (3X ref. value)

Code Allowable Instrument Tolerance: +/-36 gpm (2% of full scale at 3X reference value)

Actual Instrument Tolerance: +/-17.43 gpm Actual Indicated Accuracy: +/-2.9% (at reference value)

NUREG-1482, Revision 4 (Reference 1), Section 5.5.1, states, in part, the NRC staff may grant relief or authorize an alternative when the combination of the range and accuracy yields a reading that is as at least equivalent to that achieved using instruments that meet the OM Code requirements (i.e., up to +/-6 percent for Group A and B tests, and the use of any available instruments that meet the intent of the OM Code requirements for the actual reading would yield an acceptable level of quality and safety for testing. Based on Section 5.5.1 of NUREG-1482, and the information provided herein, the existing permanently installed pump flow instrumentation is considered acceptable in meeting the intent of the ASME OM-2022 Paragraphs ISTB-3510(a) and ISTB-3510(b)(1).

6 Duration of Proposed Alternative This proposed alternative will be utilized for the entire Inservice Testing (IST) Code of Record interval that uses the 2022 Edition of the ASME OM Code (scheduled to begin December 21, 2026).

7 Precedent

1. NRC letter to Northern States Power Company, "Monticello Nuclear Generating Plant -

Authorization and Safety Evaluation for Alternative Request No. PR-04," dated May 11, 2022 (ADAMS Accession No. ML22130A656)

2. NRC letter to PSEG, "Hope Creek Generating Station - Requests for Relief GR-01, PR-01, PR-02, VR-01, and VR-02, for the Fourth Inservice Testing Interval," dated December 20, 2016 (ADAMS Accession No. ML16343A057)

LR-N25-0097 Page 3 of 3

3. NRC letter to Exelon, "Limerick Generating Station, Units 1 and 2 - Revised Safety Evaluation of Relief Requests GVRR-8, 11-PRR-1, 90-PRR-1, and 47-VRR-2 Regarding the Fourth 10-Year Interval of the Inservice Testing Program," dated November 5, 2020 (ADAMS Accession No. ML20280A757) 8 References

1. NRC NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, Revision 4, dated September 2025 (ADAMS Accession No. ML25267A104)

LR-N25-0097 Page 1 of 5, 10 CFR 50.55a Request PR-03 Alternative Request to Utilize Code Case OMN-32 Revision 1, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

--Alternative Provides Acceptable Level of Quality and Safety--

1 ASME Code Component(s) Affected All pumps at Hope Creek Generating Station (Hope Creek) in the Inservice Testing (IST)

Program within the scope of ISTA-1100 and ISTB-1100 are covered by this Code Case, except for the pump parameter listed below.

The following pump parameter shall be excluded from Code Case OMN-32, Revision 1:

H1BD-10-P-203, Reactor Core Isolation Cooling (RCIC) Pump flow measurement only -

See PR-02 2

Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code, Operation and Maintenance of Nuclear Power Plants, 2022 Edition, no Addenda.

3

Applicable Code Requirement

ISTB-3510, General, paragraph (a), "Accuracy," states that, Instrument accuracy shall be within the limits of Table ISTB-3510-1. If a parameter is determined by analytical methods instead of measurement, then the determination shall meet the parameter accuracy requirement of Table ISTB-3510-1 (e.g., flow rate determination shall be accurate to within +/-2% of actual).

For individual analog instruments, the required accuracy is percent of full-scale. For digital instruments, the required accuracy is over the calibrated range. For a combination of instruments, the required accuracy is loop accuracy.

ISTB-3510, General, paragraph (b), Range, states, in part, (1) The full-scale range of each analog instrument shall not be greater than three times the reference value. (2) Digital instruments shall be selected such that the reference value does not exceed 90 percent of the calibrated range of the instrument.

Table ISTB-3510-1, "Required Instrument Accuracy," provides the pressure, flow rate, speed, vibration and differential pressure instrument accuracy requirement for Group A, Group B, comprehensive, baseline, and preservice pump tests.1 Pump Periodic Verification Tests (PPVTs) are not covered by Code Case OMN-32 or included in this alternative request since instrument accuracies for PPVTs are not explicitly listed within Table ISTB-3510-1. While Table ISTB-3510-1 does not specify instrument accuracy or ranges, Table ISTB-3510-1, Note 1 requires instrument accuracies to be accounted for in the test acceptance criteria. Therefore, alternate range and accuracy gauges are permitted to be used 1 Speed and vibration listed in Table ISTB-3510-1 are not covered by Code Case OMN-32, Revision 1, or included in this alternative request.

LR-N25-0097 Page 2 of 5 for PPVTs as long as the required instrument accuracy is taken into account for the PPVT flow and pressure.

4

Reason for Request

Pursuant to 10 CFR 50.55a(z)(1), an alternative is proposed to the requirements of ASME OM Code paragraphs ISTB-3510(a), ISTB-3510(b)(1), ISTB-3510(b)(2), and Table ISTB-3510-1 for the accuracy and range of flow, pressure, and differential pressure instruments used for Group A, Group B, comprehensive, baseline, and preservice pump tests.

Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests, Revision 1, has determined the following requirements may be applied to instruments used to measure pump pressure, flow rate, and differential pressure in lieu of ISTB-3510(a), ISTB-3510(b)(1), ISTB-3510(b)(2), and Table ISTB-3510-1:

4.1 Required Instrument Accuracy and Range (a) Accuracy. The analog or digital instrument(s) shall be calibrated within the limits specified in Table 1 for the respective test quantity. For an instrument loop, the required accuracy is instrument loop accuracy as defined in ISTA-2000. If a parameter is determined by analytical methods instead of measurement, then the determination shall meet the parameter accuracy requirements of Table 1.

(b) Range. The analog or digital instrument(s) shall be designed and calibrated in the range for use at the expected reading to be measured or recorded during the test (e.g.,

reference value and applicable acceptance criteria).

Table 4.1 Required Instrument Accuracy Quantity Group A and Group B Tests

% of Reading Comprehensive, Baseline, and Preservice Tests

% of Reading Pressure

+/-6

+/-11/2 Flow rate

+/-6

+/-6 Differential Pressure

+/-6

+/-11/2 5

Proposed Alternative and Basis for Use In lieu of compliance with ISTB-3510(a), ISTB-3510(b)(1), ISTB-3510(b)(2), and Table ISTB-3510-1, PSEG proposes to implement Code Case OMN-32, Revision 1, on the basis that it provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a(z)(1).

The proposed alternative testing instrument accuracy and range requirements may be applied to Group A, Group B, comprehensive, baseline, and preservice pump tests of all pumps in the IST Program within the scope of ISTA-1100 and ISTB-1100.

LR-N25-0097 Page 3 of 5 The following pump parameter shall be excluded from Code Case OMN-32, Revision 1:

H1BD-10-P-203, RCIC Pump flow measurement only - See PR-02 Instruments used for speed and vibration testing for Group A, Group B, comprehensive, baseline, and preservice pump tests shall continue to meet the instrument accuracy and range requirements in ISTB-3510(a), ISTB-3510(b)(1), ISTB-3510(b)(2), and Table ISTB-3510-1, in accordance with regulatory requirements.

Code Case OMN-32, Revision 1, was issued by ASME on February 11, 2025. PSEG does not propose any deviations from the Code Case.

Code Case OMN-32, Revision 1, simplifies the analog or digital instrument selection criteria to allow use of any range and accuracy combination designed and calibrated for use at the expected reading and ensures the maximum difference between actual value and reading is within the limits derived from previous OM Code analog instrument range and accuracy requirements.

Using ISTB-3510(a) and ISTB-3510(b) for analog instruments, without applying Code Case OMN-32, the maximum full-scale range is three times the reference value (ISTB-3510(b)(1))

and the required instrument accuracy is stated in Table ISTB-3510-1 (ISTB-3510(a)). Since the instrument range is a multiplier of the reference value, the current code required accuracy at reference value is calculated by multiplying the required instrument accuracy in Table ISTB-3510-1 by three. The calculated reference value maximum error for analog instrument accuracy based on existing code requirements is shown in Tables 5.1 and 5.2.

Table 5.1: Calculated analog instrument maximum reference value error for Group A and Group B tests Quantity Maximum Full Scale (ISTB-3510(b))

Group A and Group B Tests (ISTB-3510(a) and Table ISTB-3510-1)

Maximum Error at Reference Value (Reading)

Pressure 3 (times ref. value)

+/- 2% full scale 3 x 2 = +/-6% of ref. value Flow rate 3 (times ref. value)

+/- 2% full scale 3 x 2 = +/-6% of ref. value Differential Pressure 3 (times ref. value)

+/- 2% full scale 3 x 2 = +/-6% of ref. value Table 5.2: Calculated analog instrument maximum reference value error for comprehensive, baseline, and preservice tests Quantity Maximum Full Scale (ISTB-3510(b))

Group A and Group B Tests (ISTB-3510(a) and Table ISTB-3510-1)

Maximum Error at Reference Value (Reading)

Pressure 3 (times ref. value)

+/-1/2% full scale 3 x 1/2 = +/-1-1/2% of ref. value Flow rate 3 (times ref. value)

+/- 2% full scale 3 x 2 = +/-6% of ref. value Differential Pressure 3 (times ref. value)

+/-1/2% full scale 3 x 1/2 = +/-1-1/2% of ref. value

LR-N25-0097 Page 4 of 5 The calculated analog instrument maximum reference value error above is the basis for the required instrument accuracy and range in Code Case OMN-32.

Using ISTB-3510(a) and ISTB-3510(b)(2) for digital instruments, without applying Code Case OMN-32, there is no maximum calibrated range. ISTB-3510(b)(2) requires that the reference value does not exceed 90 percent of the calibrated range. When combining an unlimited maximum calibrated range for a digital instrument with the accuracy statement of ISTB-3510(a) which states, in part, for digital instruments, the required accuracy is over the calibrated range, there is essentially no limit of the allowed accuracy at the reference value. Therefore, the use of Code Case OMN-32 for digital instruments is more prescriptive for accuracy and range.

Instrument accuracy at the reference value and applicable acceptance criteria is the key parameter for selecting an instrument; whereas the instrument range is not the critical parameter provided the instrument is designed and intended to be used at the reference value.

Therefore, the use of Code Case OMN-32 as an alternative is acceptable as it maintains the original intent of the OM Code because the maximum possible instrument error at the reference value is unchanged.

Implementation of Code Case OMN-32, Revision 1, will allow PSEG to utilize permanently installed plant instrumentation to support pump testing which will eliminate the need to install temporary instruments. This will reduce personnel dose and allow maintenance resources to focus on more risk significant activities. Additionally, implementation of Code Case OMN-32, Revision 1, will allow additional flexibility to utilize alternate instrumentation should an issue occur with the primary instrument.

In certain tests, PSEG utilizes analytical methods to determine pump test parameters. However, PSEG will not utilize Code Case OMN-32 for parameters determined by analytical methods.

PSEG will follow the OM Code requirements or pre-authorized alternatives as approved without modification when a pump test parameter is determined by analytical methods instead of measurement. PSEG will include guidance in governance procedures to ensure Code Case OMN-32, Revision 1 is not applied to pump test parameters determined by analytical methods.

6 Duration of Proposed Alternative This proposed alternative will be utilized for the entire IST Code of Record interval that uses the 2022 Edition of the ASME OM Code (scheduled to begin December 21, 2026).

7 Precedent

1. NRC letter to Constellation, Byron Station, Unit Nos. 1 and 2 - Issuance of Alternative Request RP-3 to Use American Society of Mechanical Engineers Boiler and Pressure Vessel Code Case OMN-32, Revision 1, dated September 4, 2025 (ADAMS Accession No. ML25237A240)

2. NRC letter to Constellation, Braidwood Station, Units 1 and 2; Byron Station, Unit Nos.

1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit 1; Dresden Nuclear Power Station, Units 2 and 3; James A. Fitzpatrick Nuclear Power Plant; Lasalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and R.E. Ginna

LR-N25-0097 Page 5 of 5 Nuclear Power Plant - Alternative Request to Use American Society of Mechanical Engineers Boiler and Pressure Vessel Code Case OMN-32, dated December 19, 2024.

(ADAMS Accession No. ML24344A274)

LR-N25-0097 Page 1 of 7

, 10 CFR 50.55a Request VR-01 Excess Flow Check Valves Test Frequency Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

--Alternative Provides Acceptable Level of Quality and Safety--

1 ASME Code Components Affected Excess flow check valves (EFCVs) in the following table:

Component ID ASME Class Category P&ID (Sh #)

1ABXV-3666A 1

C M41-1(1) 1ABXV-3666B 1

C M41-1(2) 1ABXV-3666C 1

C M41-1(2) 1ABXV-3666D 1

C M41-1(2) 1ABXV-3667A 1

C M41-1(1) 1ABXV-3667B 1

C M41-1(2) 1ABXV-3667C 1

C M41-1(2) 1ABXV-3667D 1

C M41-1(2) 1ABXV-3668A 1

C M41-1(1) 1ABXV-3668B 1

C M41-1(2) 1ABXV-3668C 1

C M41-1(2) 1ABXV-3668D 1

C M41-1(2) 1ABXV-3669A 1

C M41-1(1) 1ABXV-3669B 1

C M41-1(2) 1ABXV-3669C 1

C M41-1(2) 1ABXV-3669D 1

C M41-1(2) 1BBXV-3621 1

C M42-1(1) 1BBXV-3725 1

C M42-1(1) 1BBXV-3726A 1

C M42-1(1) 1BBXV-3726B 1

C M42-1(1) 1BBXV-3727A 1

C M42-1(1) 1BBXV-3727B 1

C M42-1(1) 1BBXV-3728A 1

C M42-1(1) 1BBXV-3728B 1

C M42-1(1) 1BBXV-3729A 1

C M42-1(1) 1BBXV-3729B 1

C M42-1(1)

LR-N25-0097 Page 2 of 7 Component ID ASME Class Category P&ID (Sh #)

1BBXV-3730A 1

C M42-1(1) 1BBXV-3730B 1

C M42-1(1) 1BBXV-3731A 1

C M42-1(1) 1BBXV-3731B 1

C M42-1(1) 1BBXV-3732A 1

C M42-1(1) 1BBXV-3732B 1

C M42-1(1) 1BBXV-3732C 1

C M42-1(1) 1BBXV-3732D 1

C M42-1(1) 1BBXV-3732E 1

C M42-1(1) 1BBXV-3732F 1

C M42-1(1) 1BBXV-3732G 1

C M42-1(1) 1BBXV-3732H 1

C M42-1(1) 1BBXV-3732J 1

C M42-1(1) 1BBXV-3732K 1

C M42-1(1) 1BBXV-3732L 1

C M42-1(1) 1BBXV-3732M 1

C M42-1(1) 1BBXV-3732N 1

C M42-1(1) 1BBXV-3732P 1

C M42-1(1) 1BBXV-3732R 1

C M42-1(1) 1BBXV-3732S 1

C M42-1(1) 1BBXV-3732T 1

C M42-1(1) 1BBXV-3732U 1

C M42-1(1) 1BBXV-3732V 1

C M42-1(1) 1BBXV-3732W 1

C M42-1(1) 1BBXV-3734A 1

C M42-1(1) 1BBXV-3734B 1

C M42-1(1) 1BBXV-3734C 1

C M42-1(1) 1BBXV-3734D 1

C M42-1(1) 1BBXV-3737A 1

C M42-1(1) 1BBXV-3737B 1

C M42-1(1) 1BBXV-3738A 1

C M42-1(1) 1BBXV-3738B 1

C M42-1(1) 1BBXV-3783 1

C M43-1(1)

LR-N25-0097 Page 3 of 7 Component ID ASME Class Category P&ID (Sh #)

1BBXV-3785 1

C M43-1(1) 1BBXV-3787 1

C M43-1(1) 1BBXV-3789 1

C M43-1(1) 1BBXV-3801A 1

C M43-1(1) 1BBXV-3801B 1

C M43-1(1) 1BBXV-3801C 1

C M43-1(1) 1BBXV-3801D 1

C M43-1(1) 1BBXV-3802A 1

C M43-1(1) 1BBXV-3802B 1

C M43-1(1) 1BBXV-3802C 1

C M43-1(1) 1BBXV-3802D 1

C M43-1(1) 1BBXV-3803A 1

C M43-1(1) 1BBXV-3803B 1

C M43-1(1) 1BBXV-3803C 1

C M43-1(1) 1BBXV-3803D 1

C M43-1(1) 1BBXV-3804A 1

C M43-1(1) 1BBXV-3804B 1

C M43-1(1) 1BBXV-3804C 1

C M43-1(1) 1BBXV-3804D 1

C M43-1(1) 1BBXV-3820 1

C M43-1(1) 1BBXV-3821 1

C M43-1(1) 1BBXV-3826 1

C M43-1(1) 1BBXV-3827 1

C M43-1(1) 1BCXV-4411A 1

C M51-1(2) 1BCXV-4411B 1

C M51-1(1) 1BCXV-4411C 1

C M51-1(2) 1BCXV-4411D 1

C M51-1(1) 1BCXV-4429A 1

C M51-1(2) 1BCXV-4429B 1

C M51-1(1) 1BCXV-4429C 1

C M51-1(2) 1BCXV-4429D 1

C M51-1(1) 1BEXV-F018A 1

C M52-1(1) 1BEXV-F018B 1

C M52-1(1)

LR-N25-0097 Page 4 of 7 Component ID ASME Class Category P&ID (Sh #)

1BGXV-3882 1

C M44-1(1) 1BGXV-3884A 1

C M44-1(1) 1BGXV-3884B 1

C M44-1(1) 1BGXV-3884C 1

C M44-1(1) 1BGXV-3884D 1

C M44-1(1) 1FCXV-4150A 1

C M49-1(1) 1FCXV-4150B 1

C M49-1(1) 1FCXV-4150C 1

C M49-1(1) 1FCXV-4150D 1

C M49-1(1) 1FDXV-4800A 1

C M55-1(1) 1FDXV-4800B 1

C M55-1(1) 1FDXV-4800C 1

C M55-1(1) 1FDXV-4800D 1

C M55-1(1) 2

Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code, Operation and Maintenance of Nuclear Power Plants, 2022 Edition, no Addenda.

3

Applicable Code Requirement

ISTC-3522, Category C Check Valves, subparagraph (c) states, If exercising is not practicable during operation at power and cold shutdown outages, it shall be performed during refueling outages.

ISTC-3700, Position Verification Testing, states, in part, Valves with remote position indicators shall be observed locally at least once every 2 yr to verify that valve operation is accurately indicated.

10 CFR 50.55a(b)(3)(xi), states, When implementing paragraph ISTC-3700, Position Verification Testing, in the ASME OM Code, 2012 Edition through the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section, licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation to provide assurance of proper obturator position for valves with remote position indication within the scope of Subsection ISTC including its mandatory appendices and their verification methods and frequencies.

LR-N25-0097 Page 5 of 7 4

Reason For Request Pursuant to 10 CFR 50.55a(z)(1), an alternative is proposed to the requirements of ASME OM Code ISTC-3522(c), ISTC-3700, and 10 CFR 50.55a(b)(3)(xi) for the subject valves. The basis of this request is that the proposed alternative would provide an acceptable level of quality and safety.

The OM Code requires check valves to be exercised quarterly during plant operation, or if valve exercising is not practicable during plant operation and cold shutdown, it shall be performed during refueling outages. The OM Code also requires verification of valve position indication at least once every 2 years. 10 CFR 50.55a(b)(3)(xi) requires supplementing the ISTC-3700 testing with other indications to ensure valve position indicating lights accurately reflect valve operation.

The major components of EFCVs are the poppet and spring. The spring holds the poppet open under static conditions. The valve will close upon sufficient differential pressure across the poppet. Functional testing of the valve is accomplished by venting the instrument side of the valve. The resultant increase in flow imposes a differential pressure across the poppet, which compresses the spring and decreases flow through the valve.

The testing described above requires removal of the associated instrument or instruments from service. Since these instruments are in use during plant operation, removal of any of these instruments from service may cause a spurious signal, which could result in a plant trip or an unnecessary challenge to safety systems. Additionally, process fluid will be contaminated to some degree, requiring special measures to collect flow from the vented instrument side and also contribute to an increase in personnel radiation exposure.

The EFCVs are classified as ASME Code Category C and are also containment isolation valves. However, these valves are excluded from 10 CFR 50, Appendix J, Type C leak rate testing due to the size of the instrument lines and upstream orifices. Therefore, they have no safety-related seat leakage criterion.

5 Proposed Alternative and Basis for Use As an alternative to testing all EFCVs during a single refueling outage, EFCVs will be tested on a representative sample basis at the frequency in accordance with the Surveillance Frequency Control Program (SFCP) as stated in Technical Specification (TS) Surveillance Requirement (SR) 3.6.1.3.9.

PSEG Nuclear LLC (PSEG) tests a representative sample of EFCVs at the Hope Creek Generating Station (Hope Creek) every refueling outage such that all valves (except for EFCV 1BBXV-3649, (penetration J5C - reactor vessel head seal leak detection), as exempted by TS note) are tested once in 10 years per the Hope Creek SFCP. The representative sampling will encompass approximately equal numbers every refueling outage with all EFCVs being tested at least once within 10 years (nominal).

Industry experience as documented in NEDO-32977-A (Reference 1) indicates that EFCVs have a very low failure rate. A review of the maintenance history for Hope Creek EFCVs has shown that they have been extremely reliable over the life of the plant, showing less than 1 percent failure rate associated with testing of these valves. Examples of causes for the failures include alarm problems, position indication (limit switch adjustment), and bent

LR-N25-0097 Page 6 of 7 instrument tubing. Review of surveillance test history shows no evidence of time-based failure mechanisms or common mode failures associated with EFCVs. The test experience at Hope Creek is consistent with the findings in Reference 1. Reference 1 indicates similarly that many reported test failures at other plants were related to test methodologies and not actual EFCV failures. Thus, the EFCVs at Hope Creek, consistent with the industry, have exhibited a high degree of reliability, availability, and provide an acceptable level of quality and safety.

The EFCVs have position indication at local panels in the reactor building. Check valve remote position indication is excluded from Regulatory Guide 1.97 as a required parameter for evaluating containment isolation. The remote position indication will be verified in the closed direction at the same frequency as the exercise test, which will be performed at the frequency prescribed in the SFCP per SR 3.6.1.3.9. After the close position test, the valve will be reset, and the remote open position indication will be verified. 10 CFR 50.55a(b)(3)(xi) requires obturator verification at the same frequency as ISTC-3700 (2-years). Obturator verification for EFCVs equates to the position of the poppet assembly which is detected by switches to change the status of indicating lights. The current methodology used for functional testing of the EFCVs will be credited to meet the obturator verification requirements. However, this obturator verification for the EFCVs will be performed on the same sampling frequency as the functional testing prescribed in SR 3.6.1.3.9. Although inadvertent actuation of an EFCV during operation is highly unlikely due to the spring poppet design, corrective action documents are initiated for any EFCVs with abnormal position indication displays and repairs are scheduled for the next refueling outage.

In accordance with the Inservice Testing (IST) Program Plan, EFCV failures will be evaluated to determine if additional testing in that test interval is warranted to ensure overall reliability.

Adverse trends and EFCV performance are identified and dispositioned in the Corrective Action Program.

SR 3.6.1.3.9 requires demonstration that a representative sample of reactor instrumentation line EFCVs are tested to demonstrate that the valve actuates to check flow on a simulated instrument line break. This SR provides assurance that the instrument line EFCVs will perform so that the predicted radiological consequences will not be exceeded during a postulated instrument line break event as evaluated in the Updated Final Safety Analysis Report (UFSAR).

The surveillance frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the SFCP (TS 5.5.13). Operating experience has demonstrated that these components are highly reliable and that failures to isolate are very infrequent. Therefore, testing of a representative sample was concluded to be acceptable from a reliability standpoint.

In summary, considering the extremely low failure rate along with personnel and plant safety concerns to perform testing, the proposed alternative to perform EFCV testing on a sampling basis will continue to provide assurance of the EFCVs operational readiness and provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(z)(1).

6 Duration of Proposed Alternative This proposed alternative will be utilized for the entire IST Code of Record interval that uses the 2022 Edition of the ASME OM Code (scheduled to begin December 21, 2026).

LR-N25-0097 Page 7 of 7 7

Precedent 1.

NRC letter to Susquehanna, Susquehanna Steam Electric Station, Units 1 and 2 -

Authorization and Safety Evaluation for Alternative Request RR01 for Fifth 10-Year Inservice Testing Program, dated March 27, 2024 (ADAMS Accession No. ML24080A502) 2.

NRC letter to Constellation, Nine Mile Point Nuclear Station, Unit 2 - Relief Request Associated with Excess Flow Check Valves, dated March 11, 2022 (ADAMS Accession No. ML22061A040) 3.

NRC letter to DTE, "Fermi 2 - Proposed Alternative to the Required Examination Associated with Valves," dated October 3, 2019 (ADAMS Accession No. ML19248C707) 4.

NRC letter to Exelon, LaSalle County Station, Units 1 and 2 - Relief from the Requirements of the ASME Code for Operations and Maintenance of Nuclear Power Plants, dated July 3, 2018 (ADAMS Accession No. ML18163A054)

5. NRC letter to PSEG, "Hope Creek Generating Station - Requests for Relief GR-01, PR-01, PR-02, VR-01, and VR-02, for the Fourth Inservice Testing Interval," dated December 20, 2016 (ADAMS Accession No. ML16343A057) 8 References 1.

GE Topical Report NEDO-32977-A, DRF B21-00658-01, Class I, Excess Flow Check Valve Testing Relaxation, dated June 2000 2.

NRC Regulatory Guide 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, dated December 1980 (ADAMS Accession No. ML060750525)

LR-N25-0097 Page 1 of 3

, 10 CFR 50.55a Request VR-04 Containment Isolation Valves Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

--Alternative Provides Acceptable Level of Quality and Safety--

1 ASME Code Components Affected Normally open Containment Isolation Valves (CIVs).

2

Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code, Operation and Maintenance of Nuclear Power Plants, 2022 Edition, no Addenda.

3

Applicable Code Requirement

ISTA-3130, Application of Code Cases, subparagraph (b) states, Code Cases shall be applicable to the edition and addenda specified in the test plan.

ISTC-3700, Position Verification Testing, states, in part, Valves with remote position indicators shall be observed locally at least once every 2 yr to verify that valve operation is accurately indicated.

10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication, states When implementing paragraph ISTC-3700, Position Verification Testing, in the ASME OM Code, 2012 Edition through the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section, licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation to provide assurance of proper obturator position for valves with remote position indication within the scope of Subsection ISTC including its mandatory appendices and their verification methods and frequencies.

4 Reason For Request Pursuant to 10 CFR 50.55a(z)(1), an alternative is proposed to the requirements of ASME OM Code ISTA-3130(b), ISTC-3700, and 10 CFR 50.55a(b)(3)(xi) for the subject valves. The basis of this request is that the proposed alternative would provide an acceptable level of quality and safety.

The OM Code requires verification of valve position indication at least once every 2 years.

10 CFR 50.55a(b)(3)(xi) requires supplementing the ISTC-3700 testing with other indications to ensure valve position indicating lights accurately reflect valve operation.

The ASME OM Committee developed Code Case OMN-30, Alternative Valve Position Verification Approach to Satisfy ISTC3700, which was issued on April 4, 2022. Regulatory Guide (RG) 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code,"

Revision 5, Table 1, identifies Code Case OMN-30 as an acceptable Code Case for implementation in the Inservice Testing (IST) Program. However, the applicability within Code Case OMN-30 refers to the ASME OM Code Case Applicability Index. The latest issue of the Index dated February 11, 2025, indicates that the Cases applicability to the OM Code is to the 1998 Edition through the 2020 Edition and does not extend to the 2022 Edition. ISTA-3130(b)

LR-N25-0097 Page 2 of 3 requires Code Cases to be applicable to the edition and addenda specified in the test plan, which for the Hope Creek Generating Station (Hope Creek) would be the 2022 Edition.

Therefore, NRC authorization is needed to use Code Case OMN-30 for testing of the subject valves.

Additionally, Code Case OMN-30, in Section 1.4, Testing interval, subparagraph (a) stipulates that Category A valves that are tested in accordance with a regulatory approved performance-based leakage test program and include observations of both open and closed valve operation may use the performance-based leakage testing interval.

5 Proposed Alternative and Basis for Use As an alternative to the testing required by ISTC3700 and 10 CFR 50.55a(b)(3)(xi), PSEG Nuclear LLC (PSEG) proposes to implement ASME OM Code Case OMN-30 for normally open CIVs.

Relief from ISTA-3130(b) is requested to implement Code Case OMN-30, since the Code Case applicability, as listed in the Code Case Applicability Index, is to the 1998 Edition through the 2020 Edition. ISTA-3130(b) requires Code Cases to be applicable to the edition and addenda specified in the test plan. The ASME OM Code that applies to the Hope Creek fifth ten-year IST interval is the 2022 Edition with no Addenda. A review of the 2022 Edition of the OM Code and Code Case OMN-30 confirmed that there are no changes that would affect use of this Code Case relative to the applicable Code section referenced within the Code Case when comparing the 2020 Edition to the 2022 Edition.

Additionally, PSEG proposes to modify Code Case OMN-30, Section 1.4 to allow its use on normally open CIVs where the performance-based leakage test program only includes observations of closed valve operation, not open and closed as stipulated by the Code Case.

This is acceptable because CIVs that are normally open are verified in the open position routinely through normal plant operations. Requiring an additional verification during the leak testing as stipulated in Section 1.4 of the Code Case is redundant and unnecessary.

As identified in OM Code paragraph ISTC-3522 and NUREG-1482 (Reference 3), Section 4.1.6, open and close exercise tests for check valves are not required to be performed at the same time provided they are both performed within the same interval. Since separate open and close exercise tests are acceptable for check valves, there is no reason not to allow separate open and close tests for other valves that are normally open and are confirmed open routinely through system operation.

In summary, the use of Code Case OMN-30, as modified, as a proposed alternative to performing testing per ISTC-3700, will continue to provide assurance of the operational readiness of CIVs and provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(z)(1).

6 Duration of Proposed Alternative This proposed alternative will be utilized for the entire IST Code of Record interval that uses the 2022 Edition of the ASME OM Code (scheduled to begin December 21, 2026).

LR-N25-0097 Page 3 of 3 7

References

1. NRC Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," Revision 5, dated March 2024 (ADAMS Accession No. ML23291A006)

2. ASME OM Code Case Applicability Index, dated February 11, 2025

3. NRC NUREG 1482, Guidelines for Inservice Testing at Nuclear Power Plants, Revision 4, dated September 2025 (ADAMS Accession No. ML25267A104)