RS-23-032, Application to Move SR 3.5.1.2 Note to LCO 3.5.1 in Accordance with TSTF-416, LPCI Valve Alignment Verification Note Location

Application to Move SR 3.5.1.2 Note to LCO 3.5.1 in Accordance with TSTF-416, LPCI Valve Alignment Verification Note Location

ML23034A219
Person / Time
Site:	Quad Cities
Issue date:	02/03/2023
From:	Simpson P Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-23-032
Download: ML23034A219 (1)

Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office 10 CFR 50.90 RS-23-032 February 3, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Application to Move SR 3.5.1.2 Note to LCO 3.5.1 in Accordance with TSTF-416, "LPCI Valve Alignment Verification Note Location"

Reference:

TSTF-416, Revision 0, "LPCI Value Alignment Verification Note Location," dated August 12, 2002 (ADAMS Accession No. ML022240526)

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests amendments to Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. Specifically, CEG requests adoption of TSTF-416, Revision 0, "Low Pressure Coolant Injection (LPCI) Valve Alignment Verification Note Location," (Reference), an approved change to the Standard Technical Specifications (STS), into the QCNPS TS.

The proposed change would revise TS 3.5.1, "ECCS - Operating" by moving the LPCI valve alignment note presently located in Surveillance Requirement (SR) 3.5.1.2 to Limiting Condition for Operation (LCO) 3.5.1. provides a description and assessment of the proposed change. Attachment 2 provides the existing TS pages marked-up to show the proposed TS change. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides the corresponding marked-up TS Bases pages and is provided for information only.

The proposed change has been reviewed by the QCNPS Plant Operations Review Committees, in accordance with the requirements of the CEG Quality Assurance Program.

CEG requests approval of the proposed license amendment by February 2, 2024. Once approved, the amendment shall be implemented within 90 days.

February 3, 2023 U.S. Nuclear Regulatory Commission Page 2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this submittal, please contact Ms. Rebecca L. Steinman at (630) 657-2831.

I declare under penalty of perjury that the foregoing is true and correct. This statement was executed on the 3rd day of February 2023.

Respectfully, Patrick R. Simpson Sr. Manager Licensing Constellation Energy Generation, LLC Attachments:

1. Evaluation of Proposed Changes

2. Mark-up of Technical Specifications Pages

3. Clean Technical Specifications Pages

4. Mark-up of Technical Specifications Bases Pages - For Information Only cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector, Quad Cities Nuclear Power Station NRC Project Manager, Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 Evaluation of Proposed Changes

Subject:

Application to Move SR 3.5.1.2 Note to LCO 3.5.1 in Accordance with TSTF-416, "LPCI Valve Alignment Verification Note Location" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Applicability 2.2 Variations 2.3 Detailed Description of Proposed Change

4.0 REGULATORY EVALUATION

4.1 Precedents 4.2 No Significant Hazards Consideration 4.3 Conclusion

6.0 REFERENCES

ATTACHMENT 1 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests amendments to Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. Specifically, CEG requests adoption of TSTF-416, Revision 0, "Low Pressure Coolant Injection (LPCI) Valve Alignment Verification Note Location," (Reference 6.1),

an approved change to the Standard Technical Specifications (STS), into the QCNPS TS.

The proposed change would revise TS 3.5.1, "ECCS - Operating" by moving the LPCI valve alignment note presently located in Surveillance Requirement (SR) 3.5.1.2 to Limiting Condition for Operation (LCO) 3.5.1.

2.0 DETAILED DESCRIPTION 2.1 Applicability The NRC documented their approval of TSTF-416, Revision 0 in Reference 6.1, which stated that moving the valve alignment note is an administrative change that does not change the design or function of any safety or non-safety related systems or components previously reviewed by the NRC. CEG has reviewed TSTF-416, Revision 0 and has determined that the proposed change and associated justification is applicable to QCNPS, Units 1 and 2 and justify this amendment for incorporation.

2.2 Variations The approved Traveler includes moving the notes located in SR 3.5.1.2 and SR 3.5.2.4 to LCO 3.5.1 and 3.5.2, respectively. However, QCNPS has already incorporated the relocation of the note in TS 3.5.2 as part of Amendments 273/268 related to the adoption of TSTF-542, "Reactor Pressure Vessel Water Inventory Control" (Reference 6.2). As a result, this amendment only requests relocation of the note currently in SR 3.5.1.2.

2.3 Detailed Description of Change On August 12, 2002, the NRC approved TSTF-416, a traveler that relocated the LPCI valve alignment notes from SRs 3.5.1.2 and 3.5.2.4 to LCO 3.5.1 "ECCS -Operating" and LCO 3.5.2, "ECCS-Shutdown," respectively. As noted in Section 2.2, only the SR 3.5.1.2 note requires relocation at QCNPS since the SR 3.5.2.4 note has already been moved. contains a marked-up version of the TS showing the proposed change. provides the revised (clean) TS pages. Supporting changes to the QCNPS TS Bases will be made in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program." Attachment 4 provides the marked-up TS Bases pages. The TS Bases mark-up pages are being submitted for information only.

Page 2

ATTACHMENT 1 Evaluation of Proposed Changes

3.0 TECHNICAL EVALUATION

SR 3.5.1.2 for the verification of proper valve position currently includes a note that allows both LCPI subsystems to be considered operable during the alignment and operation for decay heat removal if the subsystems are capable of being manually realigned and otherwise operable.

The note also includes the restriction that the note is only applicable with reactor steam dome pressure less than the residual heat removal (RHR) cut-in permissive pressure in MODE 3.

This note, along with the related note in LCO 3.5.2, were included in the QCNPS TS to allow the LPCI subsystems to be considered operable when the RHR System is being used for shutdown cooling.

As described in the Bases, the note is intended to apply to all LPCI/RHR subsystem shared components; however, the note proposed for relocation is currently located in the SR that only addresses valve operability. Additionally, a similar note is not included with other SRs that are not met when an RHR subsystem is aligned in the shutdown cooling mode; specifically, SR 3.5.1.5 and SR 3.5.2.6 for automatic actuation tests. Without this change, it could be interpreted that, even though the note to SR 3.5.1.2 allows LPCI subsystems to be considered OPERABLE during alignment, the affected LPCI subsystems would have to be declared inoperable due to failure to meet the other SRs that do not contain a similar note. As a result, it is preferred to relocate the note to the LCO to ensure it applies to all SRs consistent with the LCO Bases.

4.0 REGULATORY EVALUATION

4.1 Precedents The NRC approved TSTF-416, Revision 0, on August 12, 2002 (Reference 6.1) and is reflected in NUREG-1433, "Standard Technical Specifications General Electric Plants." As indicated previously, QCNPS already moved a similar note from SR 3.5.2.4 to LCO 3.5.2 as part of Amendments 273/268, so this change would improve consistency within the QCNPS TS as well as match the STS.

4.2 No Significant Hazards Consideration Overview CEG requests adoption of TSTF-416, Revision 0, "Low Pressure Coolant Injection (LPCI) Valve Alignment Verification Note Location," an approved change to the Standard Technical Specifications (STS), into the QCNPS TS. The proposed change would revise TS 3.5.1, "ECCS

- Operating" by moving the LPCI valve alignment note presently located in Surveillance Requirement (SR) 3.5.1.2 to Limiting Condition for Operation (LCO) 3.5.1.

CEG has evaluated the proposed change against the criteria of 10 CFR 50.92(c) to determine if the proposed changes result in any significant hazards. The following is the evaluation of each of the 10 CFR 50.92(c) criteria:

Page 3

ATTACHMENT 1 Evaluation of Proposed Changes

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change makes the STS and STS Bases consistent in their consideration of an LPCI subsystem aligned for decay heat removal being considered OPERABLE for ECCS. The LCO 3.5.1 Bases state than an LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal. As a result, no initiators to accidents previously evaluated are affected and no mitigating equipment assumed in accidents previously evaluated are affected. Consequently, the probability or consequences of an accident previously evaluated is not significantly increased.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change makes the STS and STS Bases consistent in their consideration of an LPCI subsystem aligned for decay heat removal being considered OPERABLE for ECCS. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change makes the STS and STS Bases consistent in their consideration of an LPCI subsystem aligned for decay heat removal being considered OPERABLE for ECCS. As stated in the LCO 3.5.1 Bases, an LPCI subsystem is considered OPERABLE when aligned for decay heat removal. As the OPERABILITY requirements of the LPCI subsystem are unaffected, the margin of safety is unaffected. Therefore, this change does not involve a significant reduction in a margin of safety.

4.3 Conclusion Based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change Page 4

ATTACHMENT 1 Evaluation of Proposed Changes an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 TSTF-416, Revision 0, "LPCI Value Alignment Verification Note Location," dated August 12, 2002 (ADAMS Accession No. ML022240526) 6.2 Letter from Kimberly J. Green, Senior Project Manager, Office of Nuclear Reactor Regulation, to Mr. Bryan C. Hanson Senior Vice President and Chief Nuclear Officer Exelon Generation Company, LLC, " Quad Cities Nuclear Power Station, Units 1 and 2 -

Issuance of Amendment Nos. 273 and 268 Regarding Adoption of TSTF-542, 'Reactor Pressure Vessel Water Inventory Control' (EPID L-2018-LLA-0049)," dated January 28, 2019 (ADAMS Accession No. ML18353A229)

Page 5

ATTACHMENT 2 QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 Docket Nos. 50-254 and 50-265 Facility Operating License Nos. DPR-29 and DPR-30 MARK-UP OF TECHNICAL SPECIFICATIONS PAGES

---

NOTE----------------------------------------------------

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut-in ECCSOperating permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable. 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.1 ECCSOperating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS

---

NOTE---------------------------------

LCO 3.0.4.b is not applicable to HPCI.

CONDITION REQUIRED ACTION COMPLETION TIME A. One Low Pressure A.1 Restore LPCI pump to 30 days Coolant Injection OPERABLE status.

(LPCI) pump inoperable.

B. One LPCI subsystem B.1 Restore low pressure 7 days inoperable for reasons ECCS injection/spray other than Condition subsystem to OPERABLE A. status.

OR One Core Spray subsystem inoperable.

C. One LPCI pump in each C.1 Restore one LPCI pump 7 days subsystem inoperable. to OPERABLE status.

D. Required Action and --------------NOTE------------

associated Completion LCO 3.0.4.a is not applicable Time of Condition A, when entering MODE 3.

B, or C not met. ------------------------------

D.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued)

Quad Cities 1 and 2 3.5.1-1 Amendment No. 273/268

ECCSOperating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray In accordance subsystem, locations susceptible to gas with the accumulation are sufficiently filled with Surveillance water. Frequency Control Program SR 3.5.1.2 -------------------NOTES-------------------

1. Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut-in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

2. Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS injection/spray subsystem In accordance manual, power operated, and automatic valve with the in the flow path, that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position. Control Program SR 3.5.1.3 Verify correct breaker alignment to the In accordance LPCI swing bus. with the Surveillance Frequency Control Program SR 3.5.1.4 Verify each recirculation pump discharge In accordance valve cycles through one complete cycle of with the full travel or is de-energized in the INSERVICE closed position. TESTING PROGRAM (continued)

Quad Cities 1 and 2 3.5.1-4 Amendment No. 266/2615

ATTACHMENT 3 QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 Docket Nos. 50-254 and 50-265 Facility Operating License Nos. DPR-29 and DPR-30 CLEAN TECHNICAL SPECIFICATIONS PAGES

ECCSOperating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.1 ECCSOperating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five relief valves shall be OPERABLE.

---

NOTE---------------------------

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut-in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS

---

NOTE---------------------------------

LCO 3.0.4.b is not applicable to HPCI.

CONDITION REQUIRED ACTION COMPLETION TIME A. One Low Pressure A.1 Restore LPCI pump to 30 days Coolant Injection OPERABLE status.

(LPCI) pump inoperable.

B. One LPCI subsystem B.1 Restore low pressure 7 days inoperable for reasons ECCS injection/spray other than Condition subsystem to OPERABLE A. status.

OR One Core Spray subsystem inoperable.

C. One LPCI pump in each C.1 Restore one LPCI pump 7 days subsystem inoperable. to OPERABLE status.

(continued)

Quad Cities 1 and 2 3.5.1-1 Amendment No. 273/268

ECCSOperating 3.5.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and --------------NOTE-----------

associated Completion LCO 3.0.4.a is not applicable Time of Condition A, when entering MODE 3.

B, or C not met. -----------------------------

D.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> E. Two LPCI subsystems E.1 Restore one LPCI 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable for reasons subsystem to OPERABLE other than Condition status.

C.

F. Required Action and F.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition E AND not met.

F.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G. HPCI System G.1 Verify by Immediately inoperable. administrative means RCIC System is OPERABLE.

AND G.2 Restore HPCI System 14 days to OPERABLE status.

H. One ADS valve H.1 Restore ADS valve to 14 days inoperable. OPERABLE status.

I. Required Action and --------------NOTE-----------

associated Completion LCO 3.0.4.a is not applicable Time of Condition G or when entering MODE 3.

H not met. -----------------------------

I.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued)

Quad Cities 1 and 2 3.5.1-2 Amendment No. 245/240

ECCSOperating 3.5.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME J. Two or more ADS valves J.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> inoperable.

AND J.2 Reduce reactor steam 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> dome pressure to

< 150 psig.

K. Two or more low K.1 Enter LCO 3.0.3 Immediately pressure ECCS injection/spray subsystems inoperable for reasons other than Condition C or E.

OR HPCI System and one or more ADS valves inoperable.

OR One or more low pressure ECCS injection/spray subsystems inoperable and one or more ADS valves inoperable.

OR HPCI System inoperable and either one low pressure ECCS injection/spray subsystem is inoperable or Condition C entered.

Quad Cities 1 and 2 3.5.1-3 Amendment No. 245/240

ECCSOperating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray In accordance subsystem, locations susceptible to gas with the accumulation are sufficiently filled with Surveillance water. Frequency Control Program SR 3.5.1.2 -------------------NOTE-------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS injection/spray subsystem In accordance manual, power operated, and automatic valve with the in the flow path, that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position. Control Program SR 3.5.1.3 Verify correct breaker alignment to the In accordance LPCI swing bus. with the Surveillance Frequency Control Program SR 3.5.1.4 Verify each recirculation pump discharge In accordance valve cycles through one complete cycle of with the full travel or is de-energized in the INSERVICE closed position. TESTING PROGRAM (continued)

Quad Cities 1 and 2 3.5.1-4 Amendment No. 266/2615

ATTACHMENT 4 QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 Docket Nos. 50-254 and 50-265 Facility Operating License Nos. DPR-29 and DPR-30 MARK-UP OF TECHNICAL SPECIFICATIONS BASES PAGES - For Information Only

ECCSOperating B 3.5.1 BASES LCO the limits specified in Reference 9 could be exceeded. All (continued) ECCS subsystems must therefore be OPERABLE to satisfy the single failure criterion required by Reference 9.

As noted, LPCI subsystems may be considered OPERABLE during alignment and operation for decay heat removal when below the actual RHR cut-in permissive pressure in MODE 3, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. Alignment and operation for decay heat removal includes: a) when the system is being realigned to or from the RHR shutdown cooling mode and; b) when the system is in the RHR shutdown cooling mode, whether or not the RHR pump is operating. At these low pressures and decay heat levels, a reduced complement of ECCS subsystems should provide the required core cooling, thereby allowing operation of RHR shutdown cooling when necessary.

APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is 150 psig, ADS and HPCI are not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. Requirements for MODES 4 and 5 are specified in LCO 3.5.2, "RPV Water Inventory Control."

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI System. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI System and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 If any one LPCI pump is inoperable, the inoperable pump must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE pumps provide adequate core cooling during a LOCA. However, overall ECCS (continued)

Quad Cities 1 and 2 B 3.5.1-6 Revision 61

ECCSOperating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.1 (continued)

REQUIREMENTS environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

SR 3.5.1.2 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. For the HPCI System, this SR also includes the steam flow path for the turbine and the flow controller position.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

In MODE 3 with reactor steam dome pressure less than the actual RHR cut-in permissive pressure, the RHR System may be required to operate in the shutdown cooling mode to remove (continued)

Quad Cities 1 and 2 B 3.5.1-13 Revision 50

ECCSOperating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.2 (continued)

REQUIREMENTS decay heat and sensible heat from the reactor. Therefore, this SR is modified by Note 1 that allows LPCI subsystems to be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. Alignment and operation for decay heat removal includes: a) when the system is being realigned to or from the RHR shutdown cooling mode and; b) when the system is in the RHR shutdown cooling mode, whether or not the RHR pump is operating. At the low pressures and decay heat loads associated with operation in MODE 3 with reactor steam dome pressure less than the RHR cut-in permissive pressure, a reduced complement of low pressure ECCS subsystems should provide the required core cooling, thereby allowing operation of RHR shutdown cooling, when necessary.

The Note 2 exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

SR 3.5.1.3 Verification of the correct breaker alignment to the LPCI swing bus demonstrates that the AC electrical power is available to ensure proper operation of the associated LPCI injection valves and the recirculation pump discharge valves. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.1.4 Cycling the recirculation pump discharge valves through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will close when required.

Upon initiation of an automatic LPCI subsystem injection signal, these valves are required to be closed to ensure full LPCI subsystem flow injection in the reactor via the recirculation jet pumps. De-energizing the valve in the (continued)

Quad Cities 1 and 2 B 3.5.1-14 Revision 50