ML25338A100
| ML25338A100 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/09/2025 |
| From: | Markley M Plant Licensing Branch II |
| To: | Coleman J Southern Nuclear Operating Co |
| Kalathiveettil, D | |
| References | |
| EPID L-2025-LLR-0081 | |
| Download: ML25338A100 (0) | |
Text
December 9, 2025 Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.
3535 Colonnade Parkway Birmingham, AL 35243
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 - AUTHORIZATION OF ALTERNATIVE REQUEST RR-V SIXTH INSERVICE TESTING INTERVAL (EPID L-2025-LLR-0081)
Dear Jamie Coleman:
By letter dated August 26, 2025, Southern Nuclear Operating Company (SNC, the licensee) submitted Alternative Request RR-V-5 for the Sixth Inservice Testing (IST) interval at the Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2, which is scheduled to begin on January 1, 2026.
The licensee requested Alternative Request RR-V-5 for Hatch, Units 1 and 2, on the basis that the proposed alternative provides an acceptable level of quality and safety for the affected components within the scope American Society of Mechanical Engineers (ASME), Subsection ISTC, paragraph ISTC-3700. The U.S. Nuclear Regulatory Commission (NRC) staff has completed its review and concludes that SNC has adequately addressed the regulatory requirements set forth in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a, Codes and standards, paragraph (z)(1) and that RR-V-5 provides an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(z)(1), the NRC staff authorizes the use of this alternative to the 2022 Edition of the ASME Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code), as incorporated by reference in 10 CFR 50.55a, for the Code of Record interval, as defined in 10 CFR 50.55a(y), Definitions, that implements the 2022 Edition of the ASME OM Code, for Hatch, Units 1 and 2. Use of this alternative with other Codes of Record is not authorized.
All other ASME OM Code requirements as incorporated by reference in 10 CFR 50.55a for which relief or an alternative was not specifically requested, and granted or authorized (as appropriate), in the subject request remain applicable.
If you have any questions, please contact the Project Manager, Dawnmathews Kalathiveettil at Dawnmathews.Kalathiveettil@nrc.gov or 301-415-5905.
Sincerely, Michael Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366
Enclosure:
Safety Evaluation cc: Listserv MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2025.12.09 06:38:45 -05'00'
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION AUTHORIZATION OF VALVE ALTERNATIVE REQUEST RR-V-5 SIXTH INSERVICE TESTING INTERVAL SOUTHERN NUCLEAR OPERATING COMPANY EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-321 AND 50-366
1.0 INTRODUCTION
By letter dated August 26, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25238A190), Southern Nuclear Operating Company (SNC, the licensee) submitted RR-V-5 to the U.S. Nuclear Regulatory Commission (NRC) requesting authorization for a proposed alternative for specific affected valves in lieu of certain inservice testing (IST) requirements of the 2022 Edition of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code:
Section IST (OM Code), Subsection ISTC, paragraph ISTC-3700, as incorporated by reference in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a, Codes and standards, for the Sixth Inservice Testing (IST) interval at the Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2, that begins January 1, 2026.
The licensee submitted Alternative Request RR-V-5 pursuant to 10 CFR 50.55a(z)(1),
Acceptable level of quality and safety, on the basis that the proposed alternative will provide an acceptable level of quality and safety for IST activities applied to the specific affected valves within the scope of this request.
2.0 REGULATORY EVALUATION
The NRC regulations in 10 CFR 50.55a(f)(4), Inservice testing standards requirement for operating plants, state, in part, that:
Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the inservice test requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs (f)(2) and (3) of this section
[10 CFR 50.55a] and that are incorporated by reference in paragraph (a)(1)(iv) of this section [10 CFR 50.55a], to the extent practical within the limitations of design, geometry, and materials of construction of the components.
The regulations in 10 CFR 50.55a(z), Alternative to codes and standards requirements, state, in part, that alternatives to the requirements of paragraphs (b) through (h) of 10 CFR 50.55a or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation. A proposed alternative must be submitted and authorized prior to implementation.
The applicant or licensee must demonstrate that:
(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
3.0 TECHNICAL EVALUATION
The applicable Code of Record for the Hatch, Units 1 and 2, Sixth IST interval is the 2022 Edition of the ASME OM Code. The Hatch, Units 1 and 2, Sixth IST interval is scheduled to begin on January 1, 2026.
3.1 Licensees Alternative Request RR-V-5 3.1.1 Applicable ASME OM Code Requirements ASME OM Code, Subsection ISTC, Inservice Testing of Valves in Water-Cooled Reactor Nuclear Power Plants, paragraph ISTC-3700, Position Verification Testing, states:
Valves with remote position indicators shall be observed locally at least once every 2 yr
[years] to verify that valve operation is accurately indicated. Where practicable, this local observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. These observations need not be concurrent. Where local observation is not possible, other indications shall be used for verification of valve operation.
Position verification for active MOVs [motor-operated valves] shall be tested in accordance with Division 1, Mandatory Appendix III.
The NRC regulations in 10 CFR 50.55a(b)(3)(xi), OM condition: Valve Position Indication, state:
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. For valves not susceptible to stem-disk separation, licensees may implement ASME OM Code Case OMN-28, Alternative Valve Position Verification Approach to Satisfy ISTC-3700 for Valves Not Susceptible to Stem-Disk Separation, which is incorporated by reference in paragraph (a)(1)(iii)(H) of this section. Where plant conditions make it impractical to perform the initial ISTC-3700 test as supplemented by paragraph (b)(3)(xi) of this section by the date 2 years following the previously performed ISTC-3700 test, a licensee may justify an extension of this initial supplemental valve position verification provided the ISTC-3700 test as supplemented by paragraph (b)(3)(xi) of this section is performed at the next available opportunity and no later than the next plant shutdown. This one-time extension of the ISTC-3700 test schedule as supplemented by paragraph (b)(3)(xi) of this section is acceptable provided the licensee has available for NRC review documented justification based on information obtained over the previous 5 years of the structural integrity of the stem-disk connection for the applicable valves. The licensee's justification could be based on, for example, verification of the valve stem-disk connection through an appropriate weak link analysis, appropriate disk motion confirmed during diagnostic testing, or allowance and cessation of flow through the valves. The licensee's justification must provide reasonable assurance that the remote indicating lights accurately reveal the position of the valve obturator until the next ISTC-3700 test as supplemented by paragraph (b)(3)(xi) of this section is performed.
3.1.2 Components for Which Alternative is Requested The licensee states that all the valves in the IST Program at Hatch, Units 1 and 2, within the scope of ASME OM Code, Subsection ISTC, paragraph ISTC-3700, are covered in this proposed alternative.
3.1.3 Licensees Proposed Alternative and Basis for Use In its submittal dated August 26, 2025, the licensee states, in part, that:
As an alternative to ISTC-3700 and the condition in paragraph 50.55a(b)(3)(xi), SNC proposes the following for Position Verification Testing:
Valves with remote position indicators shall be exercised to verify valve operation is accurately indicated for both the open and closed positions. Observation shall be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. These observations need not be concurrent.
The position verification test may be extended from at least once every 2 yr to a frequency of once per four (4) years, unless historical data requires more frequent testing.
Position verification for active MOVs, shall be performed in accordance with Mandatory Appendix III.
The alternative clarifies implementation instructions for definitive verification of obturator to stem connection integrity in conjunction with valve position indication as required by the condition in 10 CFR 50.55a(b)(3)(xi). Normal valve operations, other IST testing such as stroke time testing, and diagnostic testing are not changed by this alternative and will also provide assurance of proper component operation and valve position. This alternative also provides a benefit that eliminates the need for local observation which reduces radiation exposure (ALARA). This approach provides reasonable assurance that valve position indication and obturator to stem connection integrity is verified.
This alternative also provides an approach to extend the test frequency from 24 months to 48 months. The decision to extend the position verification frequency will be based on historical data consistent with similar methodology as applied to pressure relief valves in ASME OM Code Division 1, Mandatory Appendix I. This approach provides reasonable assurance that a loss of position indication, including obturator to stem connection, is detected.
The above proposed alternative provides an acceptable alternative in quality and safety in lieu of ISTC-3700 and the condition in 10 CFR 50.55a(b)(3)(xi) and should be authorized pursuant to 10 CFR 50.55a(z)(1).
The licensee states that this alternative will be implemented during the Code of record interval that uses the 2022 Edition of the ASME OM Code.
3.1.4 Licensees Reason for its Request In its August 26, 2025, submittal, the licensee states, in part:
Pursuant to 10 CFR 50.55a(z)(1), an alternative to the requirements of the ASME OM Code, 2022 Edition, Subsection ISTC-3700 is requested. In addition, the frequency of these tests, along with NRC Condition 10 CFR 50.55a(b)(3)(xi), would be performed every four (4) years.
Resulting from an industry event where a valves stem-disc connection failed (NRC Information Notice (IN) 2012-14), the NRC placed Condition 10 CFR 50.55a(b)(3)(xi) on OM Code Subsection ISTC-3700 to require licensees to verify that the 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.
This alternative simplifies the implementation instructions for remote position indication verification. The existing requirement to verify valve operation is accurately indicated includes local verification of indication that the valve is either in or out of its required safety position(s). The requirement to verify all indicated positions is unaltered by this proposed alternative.
In addition, extending the frequency of these tests would support a divisional outage strategy in which only one division of safety systems is removed from service during an outage. This strategy would improve safety system availability during outages and reduce the potential for human performance issues and reduce personnel radiation exposure.
3.2
NRC Staff Evaluation
In RR-V-5, the licensee has proposed an alternative approach to the requirements of ASME OM Code, Subsection ISTC, paragraph ISTC-3700, as supplemented by 10 CFR 50.55a(b)(3)(xi), for verification of valve position indication for valves within the scope of ISTC-3700 in the IST Program at Hatch, Units 1 and 2. The licensee proposes that this alternative be implemented during the Code of Record interval that uses the 2022 Edition of the ASME OM Code at Hatch, Units 1 and 2.
For all valves within the scope of ISTC-3700 in the IST Program at Hatch, Units 1 and 2, Alternative Request RR-V-5 specifies that valves with remote position indicators shall be exercised to verify valve operation is accurately indicated for both the open and closed positions. Further, Alternative Request RR-V-5 requires that the observation shall be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. As with the ASME OM Code, Alternative Request RR-V-5 allows that these observations need not be concurrent. Alternative Request RR-V-5 specifies that the position verification test may be extended from at least once every 2 years to a frequency of once per 4 years, unless historical data requires more frequent testing. Consistent with the ASME OM Code, Alternative Request RR-V-5 specifies that position verification for active MOVs shall be performed in accordance with Mandatory Appendix III.
The NRC staff considers the proposed approach for valve position indication in Alternative Request RR-V-5 to resolve a weakness in the language in ASME OM Code, Subsection ISTC, paragraph ISTC-3700, which states that where practicable, the local observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. The use of the term should in paragraph ISTC-3700 in the ASME OM Code has caused confusion among nuclear power plant licensees. As a result, the NRC supplemented paragraph ISTC-3700 in 10 CFR 50.55a(b)(3)(xi) to address the use of the term should in the ASME OM Code. Beyond the language in paragraph ISTC-3700, Alternative Request RR-V-5 requires that the observation of valve position indication shall be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. The NRC staff finds that Alternative Request RR-V-5 satisfies the requirement in 10 CFR 50.55a(b)(3)(xi) that 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. The staff notes that 10 CFR 50.55a(b)(3)(xi) references the valve position indication requirements in the mandatory appendices of the ASME OM Code and their verification methods and frequencies In lieu of the current 2-year position verification interval specified in paragraph ISTC-3700, Alternative Request RR-V-5 specifies that the position verification test may be extended from at least once every 2 years to a frequency of once per 4 years, unless historical data require more frequent testing. With the scope of Alternative Request RR-V-5 applying to valves in the IST Program within the scope of ISTC-3700, the NRC staff finds that the extension of the valve position verification interval from 2 years to 4 years is reasonable considering the supplemental actions to verify valve position indication required by Alternative Request RR-V-5. With respect to the required actions under Alternative Request RR-V-5 where historical data require more frequent testing, the ASME OM Code, Subsection ISTA, General Requirements, paragraph ISTA-3300, Corrective Actions, specifies that corrective actions shall be performed in accordance with the Owners Quality Assurance (QA) Program, which is required by 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plant, at Hatch, Units 1 and 2. In accordance with the ASME OM Code and 10 CFR Part 50, Appendix B, the NRC staff expects these corrective actions will include assessment of the cause of an adverse position indication for a valve and the applicability of the cause of the adverse indications to other valves within the scope of the IST Program.
The licensee specifies that all the valves in the IST Program at Hatch, Units 1 and 2, within the scope of ASME OM Code, Subsection ISTC, paragraph ISTC-3700, are within the scope of Alternative Request RR-V-5. On April 2, 2019, the licensee submitted the Fifth 10-Year IST Program Update (ML19094A592) listing all valves within the scope of the IST Program for that IST Program interval at Hatch, Units 1 and 2. The NRC regulations in 10 CFR 50.55a(f)(7),
Inservice testing reporting requirements, require the Hatch licensee to submit its IST Program Plan for pumps, valves, and dynamic restraints (snubbers) to meet the requirements of the ASME OM Code within 90 days of implementation of the Sixth IST interval at Hatch, Units 1 and 2. The licensee has specified that the scope of Alternative Request RR-V-5 applies to all valves within the scope of ISTC-3700 with position indication requirements included in the IST Program in accordance with the ASME OM Code, 2022 Edition, as incorporated by reference in 10 CFR 50.55a.
Based on the above, the NRC staff has determined that Alternative Request RR-V-5 may be authorized pursuant to 10 CFR 50.55a(z)(1) on the basis that the proposed alternative provides an acceptable level of quality and safety for verifying valve position indication in lieu of the applicable valve IST requirements in the ASME OM Code, Subsection ISTC, paragraph ISTC-3700, as supplemented by 10 CFR 50.55a(b)(3)(xi).
The NRC staff notes that the applicable Code of Record for the Hatch, Units 1 and 2, Sixth IST interval, is the 2022 Edition of the ASME OM Code, as incorporated by reference in 10 CFR 50.55a. The Hatch, Units 1 and 2, Sixth IST interval, is scheduled to begin on January 1, 2026.
The ASME OM Code (2022 Edition), Subsection ISTA, General Requirements, paragraph ISTA-3120, Inservice Examination and Test Interval, as incorporated by reference in 10 CFR 50.55a, requires that licensees implement 10-year intervals for their IST programs. Although not requested, the NRC regulations in 10 CFR 50.55a allow licensees to implement the same ASME OM Code as their Code of Record for two consecutive IST program intervals.
4.0 CONCLUSION
As set forth above, the NRC staff determined that proposed alternative numbered RR-V-5 for Hatch, Units 1 and 2, provides an acceptable level of quality and safety for IST activities for the affected components. Accordingly, the NRC staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(z)(1) for this proposed alternative. Therefore, pursuant to 10 CFR 50.55a(z)(1), the NRC staff authorizes RR-V-5 for the Sixth IST Interval that begins January 1, 2026, for the specified valves within the scope of the request in lieu of the applicable IST requirements in the 2022 Edition of the ASME OM Code, as incorporated by reference in 10 CFR 50.55a, for Hatch, Units 1 and 2, for the Code of Record interval, as defined in 10 CFR 50.55a(y), Definitions, that implements the 2022 Edition of the ASME OM Code. Use of this alternative with other codes of record is not authorized.
All other ASME OM Code requirements as incorporated by reference in 10 CFR 50.55a for which relief or an alternative was not specifically requested, and granted or authorized (as appropriate), in the subject request remain applicable.
Principal Contributors: T. Scarbrough, NRR N. Hansing, NRR Date: December 9, 2025
- via eConcurrence NRR-028 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA*
NRR/DEX/EMIB/BC*
NAME DKalathiveettil KZeleznock SBailey DATE 12/03/2025 12/05/2025 11/19/2025 OFFICE NRR/DORL/LPL2-1/BC*
NRR/DORL/LPL2-1/PM*
NAME MMarkley DKalathiveettil DATE 12/09/2025 12/08/2025