LR-N26-0013, Supplement to Inservice Testing Program Relief Requests - Fifth Ten-Year Interval
| ML26051A005 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  (NPF-057) |
| Issue date: | 02/20/2026 |
| From: | Jurek S Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N26-0013 | |
| Download: ML26051A005 (0) | |
Text
Shane Jurek Regulatory Programs Manager - Licensing, PSEG Nuclear PO Box 236 Hancocks Bridge, New Jersey 08038-0221 Shane.Jurek@PSEG.com LR-N26-0013 10 CFR 50.55a February 20, 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 :
Supplement to Inservice Testing Program Relief Requests - Fifth Ten-Year Interval
References:
1.
PSEG Letter to the NRC, Inservice Testing Program Relief Requests - Fifth Ten-Year Interval, dated January 6, 2026 (ADAMS Accession No. ML26006A183) 2.
NRC Letter to PSEG, Hope Creek Generating Station - Supplemental Information Needed for Acceptance of Alternate Request Re: Containment Isolation Valves, dated February 9, 2026 (ADAMS Accession No. ML26034A400) 3.
ASME OM Code Applicability Index, Revised August 1, 2025 (ADAMS Accession No. ML25349A093)
On January 6, 2026, PSEG Nuclear LLC (PSEG) submitted multiple relief requests associated with the fifth ten-year Inservice Testing program interval for the Hope Creek Generating Station (Hope Creek) (Reference 1). On February 9, 2026, PSEG received notice from the NRC that additional information was needed for acceptance of the Alternative Request VR-04 (Reference 2). Additionally, at the time that the original request was written, OMN-30, the pertinent Code Case, was not listed as applicable to Hope Creeks American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code of Record, 2022 Edition, in the ASME OM Code Applicability Index. The 2022 Edition of the ASME OM Code has since been included in the ASME OM Code Applicability Index (Reference 3) for this Code Case.
This letter provides the supplemental information needed for the NRCs acceptance review and associated changes as Revision 1 to VR-04 in the Attachment.
There are no new or revised regulatory commitments contained in this submittal.
LR-N26-0013 10 CFR 50.55a Page 2 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
Attachment:
10 CFR 50.55a Request VR-04, Revision 1 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-N26-0013 Attachment Page 1 of 3 10 CFR 50.55a Request VR-04, Revision 1 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 All Primary Containment Isolation Valves (PCIVs) in the Inservice Testing (IST) Program that are subject to the requirements of 10 CFR 50, Appendix J, Type C leak rate testing and are provided with remote position indication.
PSEG transmits a list of valves in the IST program and required testing to the NRC as part of the IST Program interval update (Reference 1). The affected valves are listed in Table 3 of Reference 1 and are identified by Required Test LJ. PSEG has verified that no additional valves have been added to the 10 CFR 50, Appendix J, Type C testing since the most recent IST Program interval update.
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-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 of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section, licensees must 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 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,"
LR-N26-0013 Attachment Page 2 of 3 Revision 5, (Reference 2) Table 1, identifies Code Case OMN-30 as an acceptable Code Case for implementation in the IST Program.
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 a modified version of ASME OM Code Case OMN-30 for Appendix J, Type C tested PCIVs.
PSEG proposes to modify the Code Case to allow its use on 10 CFR 50, Appendix J, Type C tested PCIVs (Category A valves) where the performance-based leakage test program only includes observations of closed valve operation, not open, if the valves are open during plant operation, including shutdown conditions. This is acceptable because PCIVs that are open during plant operation are verified in the open position through observation of evidence, such as changes in system pressure, flow rate, level, temperature, or the use of test data that represent valve operation including obturator movement. Requiring an additional verification during the leak testing as stipulated in Section 1.4 of the Code Case is redundant and unnecessary.
OMN-30 excludes valves that are determined to be susceptible to stem-disk separation based on Operating Experience unless corrective actions have been completed to eliminate the stem-disk separation vulnerability or an evaluation has been completed to document why the Operating Experience is not applicable.
In addition, per ISTC-3700 Where practicable, this local observation should be supplemented by other indication such as use of flow meters or other suitable instrumentation to verify obturator position. These observations need not be concurrent. The use of other supplemented methods that verify the component is open may be implemented.
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 confirmed open routinely through plant 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 PCIVs 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-N26-0013 Attachment Page 3 of 3 7
References
- 1. PSEG Letter to the NRC, Submittal of Program for Hope Creek Fourth Ten-Year Interval Inservice Testing Program, dated February 12, 2018 (ADAMS Accession No. ML18043A089)
- 2. NRC Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," Revision 5, dated March 2024 (ADAMS Accession No. ML23291A006)
- 3. NRC NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, Revision 4, dated September 2025 (ADAMS Accession No. ML25267A104)