ML111650563

License Amendment Request to Include Alternate Method of Verifying Drywell Unidentified Leakage

ML111650563
Person / Time
Site:	Limerick
Issue date:	06/14/2011
From:	Jesse M Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML111650563 (36)

Text

{{#Wiki_filter:I 10 CFR 50.90 June 14, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 USNRC Docket Nos. 50-352 and 50-353

Subject:

License Amendment Request to Include an Alternate Method of Verifying Drywell Unidentified Leakage

References:

1) Letter from P. R. Simpson (Exelon Generation Company, LLC for Dresden Nuclear Power Station) to U.S. NRC, Request for Emergency License Amendment Regarding Drywell Floor Drain Sump Monitoring System, dated August 18, 2008 2) Letter from C. Gratton (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), Dresden Nuclear Power Station, Unit 3 Issuance of Emergency Amendment Regarding Drywell Floor Drain Sump Monitoring System (TAC No. MD9467), dated August 22, 2008 3) Letter from J. L. Hansen (Exelon Generation Company, LLC for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station) to U.S. NRC, Request for License Amendment to Revise Technical Specification 3.4.5, RCS Leakage Detection Instrumentation, to Allow Alternate Method of Verifying Drywell Leakage dated August 28, 2009 4) Letter from C. Gratton (U.S. NRC) to M. J. Pacilio (Exelon Generation Company, LLC), Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 - Issuance of Amendments RE: Authorizing Alternative Methods of Verifying Leakage within the Drywell (TAC NOS. ME2148 thru ME2151), dated August 16, 2010 In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS) for Limerick Generating Station (LGS), Units 1 and 2. The proposed amendment revises Technical Specification (TS) 3.4.3.1, LEAKAGE DETECTION SYSTEMS, to support addition of an alternative method of verifying that unidentified leakage in the drywell is within limits. In Reference 1, EGC requested a temporary emergency license amendment for Dresden Nuclear Power Station (DNPS), Unit 3 to allow the reconfiguration of the drywell floor drain sump (DWFDS) flow monitoring system such that the drywell equipment drain sump (DWEDS) could be used as an alternate method to verify that Reactor Coolant System (RCS) leakage in the drywell is within TS limits. The emergency license amendment request was reviewed and approved by the NRC in Reference 2. Following the emergency license amendment approval by the NRC, EGC submitted a request for a permanent license change for both DNPS and Quad Cities Nuclear Power Station (QCNPS) in Reference 3. The NRC approved the license 10 June 1 2011 U.S. Nuclear ATTN: Washington, Limerick Generating Station, Units 1 and 2 Facility Operating Nos. NPF-85 License Amendment Request to Include an Alternate Method of Verifying Drywell Unidentified LealKa(le 1) from P. R. Simpson (Exelon Generation Company, LLC for Dresden Nuclear Power Station) to U.S. NRC, IIRequest for Emergency License Amendment Regarding Drywell Floor Drain Sump Monitoring System,lI dated August 18, 2008 2) Letter from C. Gratton (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), IIDresden Nuclear Power Station, Unit 3 -Issuance of Emergency Amendment Regarding Drywell Floor Drain Sump Monitoring System (TAC No. MD9467)," August 2008 3) Letter from J. L. Hansen (Exelon Generation Company, LLC for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station) to U.S. NRC, "Request for License Amendment to Revise Technical Specification 3.4.5, "RCS Leakage Detection Instrumentation," to Allow Alternate Method of Verifying Drywell Leakage" dated August 28,2009 4) Letter from C. Gratton (U.S. NRC) to M. J. Pacilio (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 - Issuance of Amendments RE: Authorizing Alternative Methods of Verifying Leakage within the Drywell (TAC NOS. ME2148 thru ME2151)," dated August 16, 2010 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS) for Limerick Generating Station (LGS), Units 1 and 2. The proposed amendment revises Technical Specification (TS) 3.4.3.1, "LEAKAGE DETECTION SYSTEMS," to support addition of an alternative method of verifying that unidentified leakage in the drywell is within limits. In Reference 1, EGC requested a temporary emergency license amendment for Dresden Nuclear Power Station (DNPS), Unit 3 to allow the reconfiguration of the drywell floor drain sump (DWFDS) flow monitoring system such that the drywell equipment drain sump (DWEDS) could be used as an alternate method to verify that Reactor Coolant System (RCS) leakage in the drywell is within TS limits. The emergency license amendment request was reviewed and approved by the NRC in Reference 2. Following the emergency license amendment approval by the NRC, EGC submitted a request for a permanent license change for both DNPS and Quad Cities Nuclear Power Station (QCNPS) in Reference 3. The NRC approved the license

U.S. Nuclear Regulatory Commission June 14, 2011 Page 2 amendment for both DNPS and QCNPS in the Reference 4 Safety Evaluation Report. The changes proposed in this license amendment request seek to incorporate the alternate method approved for DNPS and QCNPS into the LGS TS for Units 1 and 2. The changes proposed in this license amendment request have wording and justification similar to the changes approved for DNPS and QCNPS. The DNPS and QCNPS submiffal and Safety Evaluation Report were verified for applicability and utilized as the template for this submittal. provides a description of the proposed change. Attachment 2 provides the existing TS page markups showing the proposed changes. Attachment 3 provides the associated TS Bases markups for information only. There are two regulatory commitments contained in this letter, detailed in Attachment 4. Attachment 5 contains drywell sump level monitoring system configuration drawings for information only. The proposed changes have been reviewed by the LGS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program. EGC requests approval of the proposed amendment by June 14, 2012. Once approved, the amendment shall be implemented within 60 days of issuance. In accordance with 1 0 CFR 50.91, Notice for public comment; State consultation, paragraph (b), EGC is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official. Should you have any questions concerning this letter, please contact Ms. Wendy E. Croft at (61 0) 765-5726. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1 4 th dayof June2011. / Michael D. Director, Licentn6d Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes 2. Markup of Technical Specification Pages 3. Markup of Technical Specifications Bases Pages (For Information Only) 4. List of Commitments 5. Drywell Sump Level Monitoring System Configuration Drawings (For Information Only) cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, LGS USNRC Project Manager, LGS R. R. Janati, Bureau of Radiation Protection Respectfully u.s. Nuclear Regulatory Commission June 14, 2011 Page 2 amendment for both DNPS and QCNPS in the Reference 4 Safety Evaluation Report. The changes proposed in this license amendment request seek to incorporate the alternate method approved for DNPS and QCNPS into the LGS TS for Units 1 and 2. The changes proposed in this license amendment request have wording and justification similar to the changes approved for DNPS and QCNPS. The DNPS and QCNPS submittal and Safety Evaluation Report were verified for applicability and utilized as the template for this submittal. provides a description of the proposed change. Attachment 2 provides the existing TS page markups showing the proposed changes. Attachment 3 provides the associated TS Bases markups for information only. There are two regulatory commitments contained in this letter, detailed in Attachment 4. Attachment 5 contains drywell sump level monitoring system configuration drawings for information only. The proposed changes have been reviewed by the LGS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program. EGC requests approval of the proposed amendment by June 14, 2012. Once approved, the amendment shall be implemented within 60 days of issuance. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation, II paragraph (b), EGC is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official. Should you have any questions concerning this letter, please contact Ms. Wendy E. Croft at (610) 765-5726. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day of June 2011.

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Michael D. Je se Director, Licen On d Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. 2. 3. 4. 5. Evaluation of Proposed Changes Markup of Technical Specification Pages Markup of Technical Specifications Bases Pages (For Information Only) List of Commitments Drywell Sump Level Monitoring System Configuration Drawings (For Information Only) cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, LGS USNRC Project Manager, LGS R. R. Janati, Bureau of Radiation Protection u.s. Nuclear Regulatory Commission June 14, 2011 Page 2 amendment for both DNPS and QCNPS in the Reference 4 Safety Evaluation Report. The changes proposed in this license amendment request seek to incorporate the alternate method approved for DNPS and QCNPS into the LGS TS for Units 1 and 2. The changes proposed in this license amendment request have wording and justification similar to the changes approved for DNPS and QCNPS. The DNPS and QCNPS submittal and Safety Evaluation Report were verified for applicability and utilized as the template for this submittal. provides a description of the proposed change. Attachment 2 provides the existing TS page markups showing the proposed changes. Attachment 3 provides the associated TS Bases markups for information only. There are two regulatory commitments contained in this letter, detailed in Attachment 4. Attachment 5 contains drywell sump level monitoring system configuration drawings for information only. The proposed changes have been reviewed by the LGS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program. EGC requests approval of the proposed amendment by June 14, 2012. Once approved, the amendment shall be implemented within 60 days of issuance. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation, II paragraph (b), EGC is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official. Should you have any questions concerning this letter, please contact Ms. Wendy E. Croft at (610) 765-5726. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day of June 2011.

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Michael D. Je se Director, Licen On d Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. 2. 3. 4. 5. Evaluation of Proposed Changes Markup of Technical Specification Pages Markup of Technical Specifications Bases Pages (For Information Only) List of Commitments Drywell Sump Level Monitoring System Configuration Drawings (For Information Only) cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, LGS USNRC Project Manager, LGS R. R. Janati, Bureau of Radiation Protection

-n 0 Om m 00 0) 0 -4i Co C, CD(,) 0 0 m Co Co .0 CD0. C, 0) cCO Cl) za. -or) -p Co ai ATTACHMENT 1 Evaluation of Proposed Changes Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 ATTACHMENT 1 Evaluation of Proposed Changes Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85

Subject:

License Amendment Request to Include an Alternate Method of Verifying Drywell Unidentified Leakage 1o

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

3.1 Drywell Sump Level Monitoring System Description 3.2 RCS Leakage Limits 3.3 RCS Leakage Detection While Filling the DWFDS 3.4 Summary

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

Subject:

License Amendment Request to Include an Alternate Method of Verifying Drywell Unidentified Leakage 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

3.1 Drywell Sump Level Monitoring System Description 3.2 RCS Leakage Limits 3.3 RCS Leakage Detection While Filling the DWFDS 3.4 Summary

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

Subject:

License Amendment Request to Include an Alternate Method of Verifying Drywell Unidentified Leakage 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

3.1 Drywell Sump Level Monitoring System Description 3.2 RCS Leakage Limits 3.3 RCS Leakage Detection While Filling the DWFDS 3.4 Summary

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 1 of 10 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Operating Licenses NPF-39 and NPF-85 for Limerick Generating Station (LGS) Units 1 and 2, respectively. The proposed changes would amend the Operating Licenses by revising Technical Specification (TS) 3.4.3.1, LEAKAGE DETECTION SYSTEMS, to add an alternative method to verify Reactor Coolant System (RCS) unidentified leakage in the drywell is within limits. The proposed amendment revises TS 3.4.3.1, LEAKAGE DETECTION SYSTEMS, to support implementation of an alternate method to quantify Reactor Coolant System (RCS) leakage in the primary containment (i.e., the drywell). The proposed alternate method uses the installed drywell equipment drain sump (DWEDS) monitoring system, with the drywell floor drain sump (DWFDS) overflowing to the DWEDS, to verify that RCS leakage in the drywell is within TS 3.4.3.2, OPERATIONAL LEAKAGE, limits. This configuration would only be used when the DWFDS monitoring system is unavailable. The purpose of the proposed license amendment is to increase operating flexibility and avoid unnecessary plant transients due to extended inoperability of the DWFDS monitoring system (e.g., inoperability caused by a component failure). The proposed change will enable each unit to reconfigure the DWFDS flow monitoring system such that it is overflowing into the DWEDS. The reconfigured drywell sump monitoring system can then be used to verify that drywell leakage is within the limits specified in TS 3.4.3.2. This operating configuration is conservative to the normal configuration in that the TS 3.4.3.2.b unidentified leakage limit of less than or equal to 5 gallons per minute (gpm) will be applied to total leakage, as opposed to the TS 3.4.3.2.c limit of less than or equal to 30 gpm. 2.0 DETAILED DESCRIPTION This proposed amendment is consistent with the License Amendment Request and subsequent NRC Safety Evaluation Report for Dresden Nuclear Power Station (DNPS) and Quad Cities Nuclear Power Station (QCNPS) pertaining to an alternate method of verifying drywell leakage, References 6.1 and 6.2, respectively. The proposed TS and TS Bases changes are: TS Limiting Condition for Operation (LCO) 3.4.3.1.b is revised to state that, the drywell sump monitoring system is required to be operable. TS 3.4.3.1, Action B is revised to remove the specific references to the DWFDS monitoring system and replaces this with a reference to the drywell sump monitoring system. TS BASES 3/4.4.3.1 is revised to define the drywell sump monitoring system as either the DWFDS monitoring system or the DWEDS monitoring system with the DWFDS overflowing to the DWEDS. A markup of the proposed TS and TS Bases page changes are provided in Attachments 2 and 3, respectively. The TS Bases page changes are provided for information only. Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 1 of 10 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Operating Licenses NPF-39 and NPF-85 for Limerick Generating Station (LGS) Units 1 and 2, respectively. The proposed changes would amend the Operating Licenses by revising Technical Specification (TS) 3.4.3.1, "LEAKAGE DETECTION SYSTEMS," to add an alternative method to verify Reactor Coolant System (RCS) unidentified leakage in the drywell is within limits. The proposed amendment revises TS 3.4.3.1, "LEAKAGE DETECTION SYSTEMS," to support implementation of an alternate method to quantify Reactor Coolant System (RCS) leakage in the primary containment (Le., the drywell). The proposed alternate method uses the installed drywell equipment drain sump (DWEDS) monitoring system, with the drywell floor drain sump (DWFDS) overflowing to the DWEDS, to verify that RCS leakage in the drywell is within TS 3.4.3.2, "OPERATIONAL LEAKAGE," limits. This configuration would only be used when the DWFDS monitoring system is unavailable. The purpose of the proposed license amendment is to increase operating flexibility and avoid unnecessary plant transients due to extended inoperability of the DWFDS monitoring system (e.g., inoperability caused by a component failure). The proposed change will enable each unit to reconfigure the DWFDS flow monitoring system such that it is overflowing into the DWEDS. The reconfigured drywell sump monitoring system can then be used to verify that drywell leakage is within the limits specified in TS 3.4.3.2. This operating configuration is conservative to the normal configuration in that the TS 3.4.3.2.b unidentified leakage limit of less than or equal to 5 gallons per minute (gpm) will be applied to total leakage, as opposed to the TS 3.4.3.2.c limit of less than or equal to 30 gpm. 2.0 DETAILED DESCRIPTION This proposed amendment is consistent with the License Amendment Request and subsequent NRC Safety Evaluation Report for Dresden Nuclear Power Station (DNPS) and Quad Cities Nuclear Power Station (QCNPS) pertaining to an alternate method of verifying drywell leakage, References 6.1 and 6.2, respectively. The proposed TS and TS Bases changes are: TS Limiting Condition for Operation (LCO) 3.4.3.1.b is revised to state that, "the drywell sump monitoring system" is required to be operable. TS 3.4.3.1, Action B is revised to remove the specific references to the DWFDS monitoring system and replaces this with a reference to the drywell sump monitoring system. TS BASES 3/4.4.3.1 is revised to define the drywell sump monitoring system as either the DWFDS monitoring system or the DWEDS monitoring system with the DWFDS overflowing to the DWEDS. A markup of the proposed TS and TS Bases page changes are provided in Attachments 2 and 3, respectively. The TS Bases page changes are provided for information only. Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 1 of 10 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Operating Licenses NPF-39 and NPF-85 for Limerick Generating Station (LGS) Units 1 and 2, respectively. The proposed changes would amend the Operating Licenses by revising Technical Specification (TS) 3.4.3.1, "LEAKAGE DETECTION SYSTEMS," to add an alternative method to verify Reactor Coolant System (RCS) unidentified leakage in the drywell is within limits. The proposed amendment revises TS 3.4.3.1, "LEAKAGE DETECTION SYSTEMS," to support implementation of an alternate method to quantify Reactor Coolant System (RCS) leakage in the primary containment (Le., the drywell). The proposed alternate method uses the installed drywell equipment drain sump (DWEDS) monitoring system, with the drywell floor drain sump (DWFDS) overflowing to the DWEDS, to verify that RCS leakage in the drywell is within TS 3.4.3.2, "OPERATIONAL LEAKAGE," limits. This configuration would only be used when the DWFDS monitoring system is unavailable. The purpose of the proposed license amendment is to increase operating flexibility and avoid unnecessary plant transients due to extended inoperability of the DWFDS monitoring system (e.g., inoperability caused by a component failure). The proposed change will enable each unit to reconfigure the DWFDS flow monitoring system such that it is overflowing into the DWEDS. The reconfigured drywell sump monitoring system can then be used to verify that drywell leakage is within the limits specified in TS 3.4.3.2. This operating configuration is conservative to the normal configuration in that the TS 3.4.3.2.b unidentified leakage limit of less than or equal to 5 gallons per minute (gpm) will be applied to total leakage, as opposed to the TS 3.4.3.2.c limit of less than or equal to 30 gpm. 2.0 DETAILED DESCRIPTION This proposed amendment is consistent with the License Amendment Request and subsequent NRC Safety Evaluation Report for Dresden Nuclear Power Station (DNPS) and Quad Cities Nuclear Power Station (QCNPS) pertaining to an alternate method of verifying drywell leakage, References 6.1 and 6.2, respectively. The proposed TS and TS Bases changes are: TS Limiting Condition for Operation (LCO) 3.4.3.1.b is revised to state that, "the drywell sump monitoring system" is required to be operable. TS 3.4.3.1, Action B is revised to remove the specific references to the DWFDS monitoring system and replaces this with a reference to the drywell sump monitoring system. TS BASES 3/4.4.3.1 is revised to define the drywell sump monitoring system as either the DWFDS monitoring system or the DWEDS monitoring system with the DWFDS overflowing to the DWEDS. A markup of the proposed TS and TS Bases page changes are provided in Attachments 2 and 3, respectively. The TS Bases page changes are provided for information only.

Alternate Method of Verifying Drywefl Unidentified Leakage : Evaluation of Proposed Changes Page 2 of 10 2.1 Backciround On August 16, 2008, at approximately 2000 hours, operations personnel at DNPS attempted to pump the DNPS Unit 3 DWFDS utilizing Dresden Operating Procedure (DOP) 2000-24, Drywell Sump Operation. Successful completion of DOP 2000-24 is used, in part, to satisfy DNPS Surveillance Requirement (SR) 3.4.4.1, Verify RCS unidentified and total LEAKAGE and unidentified LEAKAGE increase are within limits. The pumps started as expected; however, the integrator indicated no flow. During a second attempt to operate the pumps, DNPS operations personnel observed the position indicators for the two containment isolation valves, which indicated that the valves were in their proper position. DNPS maintenance personnel also inspected the pump breakers and measured pump motor current, with no abnormalities identified. The drywell floor drain sump pumps had been successfully pumped previously at 1 600 hours, and every four hours prior. DNPS conducted troubleshooting actions to identify possible malfunctions. These troubleshooting actions indicated that the containment isolation valve (i.e., one of two drywell floor drain sump pump discharge valves) may have failed closed. Since the drywell floor drain sump could not be pumped, DNPS was not able to satisfy the acceptance criteria of SR 3.4.4.1 for DNPS Unit 3. Therefore, TS LCO 3.4.4 for unidentified leakage could not be verified to be within limits. The applicable TS action requires thatthe unit be placed in Mode 3 within 12 hours and Mode 4 within 36 hours. In that the containment isolation valve is part of primary containment, the valve could not be repaired during unit operation. As such, DNPS requested, and the U.S. Nuclear Regulatory Commission (USNRC) granted, a Notice of Enforcement Discretion (NOED) for TS 3.4.4, Condition C and TS 3.4.5, Condition C (i.e., References 6.3 and 6.4, respectively). Specifically, the NOED provided a seven-day extension to the TS Completion Times to place the unit in Mode 3 within 12 hours and Mode 4 within 36 hours. The extension provided sufficient time to reconfigure the DWFDS monitoring system such that the DWEDS monitoring system could be physically utilized to quantify unidentified drywell leakage. In addition, the seven-day extension provided sufficient time for DNPS to request, and the USNRC to review and approve, an emergency license amendment to revise TS 3.4.5, on a temporary basis, to approve the use of the DWEDS monitoring system as an alternate method to quantify unidentified leakage (i.e., References 6.5 and 6.6, respectively). Subsequently, DNPS and Quad Cities Nuclear Power Station (QCNPS) submitted an additional license amendment request, Reference 6.1, requesting the emergency license amendment changes be made permanent for both stations. The USNRC requested additional information to support the license amendment request review in the Reference 6.7 letter. The DNPS and QCNPS responses were provided in the Reference 6.8 and 6.9 submittals. The license amendment request was approved by the USNRC in August 2010 (Reference 6.2). To prevent the need for a similar emergency license amendment, the changes proposed in this request seek to incorporate the alternate method of verifying drywell leakage into the LGS TS for Unit 1 and Unit 2. Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 2 of 10

2.1 Background

On August 16, 2008, at approximately 2000 hours, operations personnel at DNPS attempted to pump the DNPS Unit 3 DWFDS utilizing Dresden Operating Procedure (DOP) 2000-24, "Drywell Sump Operation. II Successful completion of DOP 2000-24 is used, in part, to satisfy DNPS Surveillance Requirement (SR) 3.4.4.1, "Verify RCS unidentified and total LEAKAGE and unidentified LEAKAGE increase are within limits." The pumps started as expected; however, the integrator indicated no flow. During a second attempt to operate the pumps, DNPS operations personnel observed the position indicators for the two containment isolation valves, which indicated that the valves were in their proper position. DNPS maintenance personnel also inspected the pump breakers and measured pump motor current, with no abnormalities identified. The drywell floor drain sump pumps had been successfully pumped previously at 1600 hours, and every four hours prior. DNPS conducted troubleshooting actions to identify possible malfunctions. These troubleshooting actions indicated that the containment isolation valve (Le., one of two drywell floor drain sump pump discharge valves) may have failed closed. Since the drywell floor drain sump could not be pumped, DNPS was not able to satisfy the acceptance criteria of SR 3.4.4.1 for DNPS Unit 3. Therefore, TS LCO 3.4.4 for unidentified leakage could not be verified to be within limits. The applicable TS action requires that the unit be placed in Mode 3 within 12 hours and Mode 4 within 36 hours. In that the containment isolation valve is part of primary containment, the valve could not be repaired during unit operation. As such, DNPS requested, and the U.S. Nuclear Regulatory Commission (USNRC) granted, a Notice of Enforcement Discretion (NOED) for TS 3.4.4, Condition C and TS 3.4.5, Condition C (Le., References 6.3 and 6.4, respectively). Specifically, the NOED provided a seven-day extension to the TS Completion Times to place the unit in Mode 3 within 12 hours and Mode 4 within 36 hours. The extension provided sufficient time to reconfigure the DWFDS monitoring system such that the DWEDS monitoring system could be physically utilized to quantify unidentified drywell leakage. In addition, the seven-day extension provided sufficient time for DNPS to request, and the USNRC to review and approve, an emergency license amendment to revise TS 3.4.5, on a temporary basis, to approve the use of the DWEDS monitoring system as an alternate method to quantify unidentified leakage (Le., References 6.5 and 6.6, respectively). Subsequently, DNPS and Quad Cities Nuclear Power Station (QCNPS) submitted an additional license amendment request, Reference 6.1, requesting the emergency license amendment changes be made permanent for both stations. The USNRC requested additional information to support the license amendment request review in the Reference 6.7 letter. The DNPS and QCNPS responses were provided in the Reference 6.8 and 6.9 submittals. The license amendment request was approved by the USNRC in August 2010 (Reference 6.2). To prevent the need for a similar emergency license amendment, the changes proposed in this request seek to incorporate the alternate method of verifying drywell leakage into the LGS TS for Unit 1 and Unit 2. Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 2 of 10

2.1 Background

On August 16, 2008, at approximately 2000 hours, operations personnel at DNPS attempted to pump the DNPS Unit 3 DWFDS utilizing Dresden Operating Procedure (DOP) 2000-24, "Drywell Sump Operation. II Successful completion of DOP 2000-24 is used, in part, to satisfy DNPS Surveillance Requirement (SR) 3.4.4.1, "Verify RCS unidentified and total LEAKAGE and unidentified LEAKAGE increase are within limits." The pumps started as expected; however, the integrator indicated no flow. During a second attempt to operate the pumps, DNPS operations personnel observed the position indicators for the two containment isolation valves, which indicated that the valves were in their proper position. DNPS maintenance personnel also inspected the pump breakers and measured pump motor current, with no abnormalities identified. The drywell floor drain sump pumps had been successfully pumped previously at 1600 hours, and every four hours prior. DNPS conducted troubleshooting actions to identify possible malfunctions. These troubleshooting actions indicated that the containment isolation valve (Le., one of two drywell floor drain sump pump discharge valves) may have failed closed. Since the drywell floor drain sump could not be pumped, DNPS was not able to satisfy the acceptance criteria of SR 3.4.4.1 for DNPS Unit 3. Therefore, TS LCO 3.4.4 for unidentified leakage could not be verified to be within limits. The applicable TS action requires that the unit be placed in Mode 3 within 12 hours and Mode 4 within 36 hours. In that the containment isolation valve is part of primary containment, the valve could not be repaired during unit operation. As such, DNPS requested, and the U.S. Nuclear Regulatory Commission (USNRC) granted, a Notice of Enforcement Discretion (NOED) for TS 3.4.4, Condition C and TS 3.4.5, Condition C (Le., References 6.3 and 6.4, respectively). Specifically, the NOED provided a seven-day extension to the TS Completion Times to place the unit in Mode 3 within 12 hours and Mode 4 within 36 hours. The extension provided sufficient time to reconfigure the DWFDS monitoring system such that the DWEDS monitoring system could be physically utilized to quantify unidentified drywell leakage. In addition, the seven-day extension provided sufficient time for DNPS to request, and the USNRC to review and approve, an emergency license amendment to revise TS 3.4.5, on a temporary basis, to approve the use of the DWEDS monitoring system as an alternate method to quantify unidentified leakage (Le., References 6.5 and 6.6, respectively). Subsequently, DNPS and Quad Cities Nuclear Power Station (QCNPS) submitted an additional license amendment request, Reference 6.1, requesting the emergency license amendment changes be made permanent for both stations. The USNRC requested additional information to support the license amendment request review in the Reference 6.7 letter. The DNPS and QCNPS responses were provided in the Reference 6.8 and 6.9 submittals. The license amendment request was approved by the USNRC in August 2010 (Reference 6.2). To prevent the need for a similar emergency license amendment, the changes proposed in this request seek to incorporate the alternate method of verifying drywell leakage into the LGS TS for Unit 1 and Unit 2.

Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 3 of 10

3.0 TECHNICAL EVALUATION

3.1 pjywell Sump Level Monitoring System DescriOtQfl The DWEDS at LGS is located immediately adjacent to the DWFDS, with the top of both sumps (tanks) at the same elevation, approximately seven feet apart. There are no obstructions between the two sumps to prevent or divert drywell floor drain sump overflow from reaching the drywell equipment drain sump. Based on the sump configurations, an engineering computation determined that approximately 550 gallons are required in the DWFDS for overflow into the DWEDS. Attachment 5 contains drawings detailing the physical configuration of the sumps. LGS has verified that the sump configuration and sump volumes for LGS Units 1 and 2 (i.e., both DWEDS and DWFDS) are equivalent to the DNPS Unit 3 DWFDS and DWEDS sump configuration and volume (i.e., approximately 1000 gallons full capacity each). All leakage from Reactor Coolant Pressure Boundary (RCPB) components inside the drywell, with the exception of leakage from the Main Steam Relief Valves (MSRV5) (Updated Final Safety Analysis Report (UFSAR) Section 5.2.5.2.1.8), flows directly to either the drywell equipment drain sump or the drywell floor drain sump. There are no other reservoirs in the drywell of sufficient capacity to prevent leakage from draining directly to either of these sumps. Both drain sumps are identically sized, horizontal cylindrical tanks located inside the reactor vessel pedestal below the diaphragm slab and vented to the drywell atmosphere. Leakage from RCPB components inside the primary containment which are not normally subject to leakage is collected by the DWFDS. This leakage, which may originate from any number of sources within the drywell, is transported to the sump via the floor drain network within the drywell. Thus, separation of unidentified leakage from the identifiable leakage routed to the equipment drain sump ensures that a small unidentified leakage that is of concern will not be masked by a larger, acceptable, identified leakage. The DWEDS monitoring system is similar to the DWFDS monitoring system. Certain RCPB components within the drywell are, by the nature of their design, normally subject to a limited amount of leakage. These components include pump seals, valve stem packings, and other equipment that cannot practicably be made to be completely leak-tight. These leakages are piped directly to the drywell equipment drain sump. All of the various drains are open only to the equipment they serve, thereby receiving leakage only from identified sources. Background leakage to this sump is determined during initial plant operation. Rates of leakage collection in excess of background indicates abnormal RCPB leakage. The control circuits for the two monitoring systems pertorm the same functions, and sump instrumentation consists of the same components and performs a similar function. Instruments for both monitoring systems are calibrated using similar plant procedures to satisfy TS Surveillance Requirements (SR5) for functional testing and calibration. Each sump tank has its own level transmitter which is monitored by a dedicated processing unit. Normally closed drain valves are provided, enabling the level in each tank to increase as leakage drains into them. The processing unit calculates an average leak rate for a given measurement period by establishing the amount of increase in level that occurred during the period, and converting that value into volumetric terms (gpm). The processing units provide an alarm in the main control room each time the average leak rate changes by a predetermined value since the last time that alarm was reset. The setpoint is a 1 gpm change in unidentified Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 3 of 10

3.0 TECHNICAL EVALUATION

3.1 Drywell Sump Level Monitoring System Description The DWEDS at LGS is located immediately adjacent to the DWFDS, with the top of both sumps (tanks) at the same elevation, approximately seven feet apart. There are no obstructions between the two sumps to prevent or divert drywell floor drain sump overflow from reaching the drywell equipment drain sump. Based on the sump configurations, an engineering computation determined that approximately 550 gallons are required in the DWFDS for overflow into the DWEDS. Attachment 5 contains drawings detailing the physical configuration of the sumps. LGS has verified that the sump configuration and sump volumes for LGS Units 1 and 2 (i.e., both DWEDS and DWFDS) are equivalent to the DNPS Unit 3 DWFDS and DWEDS sump configuration and volume (Le., approximately 1000 gallons full capacity each). All leakage from Reactor Coolant Pressure Boundary (RCPB) components inside the drywell, with the exception of leakage from the Main Steam Relief Valves (MSRVs) (Updated Final Safety Analysis Report (UFSAR) Section 5.2.5.2.1.8), flows directly to either the drywell equipment drain sump or the drywell floor drain sump. There are no other reservoirs in the drywell of sufficient capacity to prevent leakage from draining directly to either of these sumps. Both drain sumps are identically sized, horizontal cylindrical tanks located inside the reactor vessel pedestal below the diaphragm slab and vented to the drywell atmosphere. Leakage from RCPS components inside the primary containment which are not normally subject to leakage is collected by the DWFDS. This leakage, which may originate from any number of sources within the drywell, is transported to the sump via the floor drain network within the drywell. Thus, separation of unidentified leakage from the identifiable leakage routed to the equipment drain sump ensures that a small unidentified leakage that is of concern will not be masked by a larger, acceptable, identified leakage. The DWEDS monitoring system is similar to the DWFDS monitoring system. Certain RCPB components within the drywell are, by the nature of their design, normally subject to a limited amount of leakage. These components include pump seals, valve stem packings, and other equipment that cannot practicably be made to be completely leak-tight. These leakages are piped directly to the drywell equipment drain sump. All of the various drains are open only to the equipment they serve, thereby receiving leakage only from identified sources. Background leakage to this sump is determined during initial plant operation. Rates of leakage collection in excess of background indicates abnormal RCPB leakage. The control circuits for the two monitoring systems perform the same functions, and sump instrumentation consists of the same components and performs a similar function. Instruments for both monitoring systems are calibrated using similar plant procedures to satisfy TS Surveillance Requirements (SRs) for functional testing and calibration. Each sump tank has its own level transmitter which is monitored by a dedicated processing unit. Normally closed drain valves are provided, enabling the level in each tank to increase as leakage drains into them. The processing unit calculates an average leak rate for a given measurement period by establishing the amount of increase in level that occurred during the period, and converting that value into volumetric terms (gpm). The processing units provide an alarm in the main control room each time the average leak rate changes by a predetermined value since the last time that alarm was reset. The setpoint is a 1 gpm change in unidentified Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 3 of 10

3.0 TECHNICAL EVALUATION

3.1 Drywell Sump Level Monitoring System Description The DWEDS at LGS is located immediately adjacent to the DWFDS, with the top of both sumps (tanks) at the same elevation, approximately seven feet apart. There are no obstructions between the two sumps to prevent or divert drywell floor drain sump overflow from reaching the drywell equipment drain sump. Based on the sump configurations, an engineering computation determined that approximately 550 gallons are required in the DWFDS for overflow into the DWEDS. Attachment 5 contains drawings detailing the physical configuration of the sumps. LGS has verified that the sump configuration and sump volumes for LGS Units 1 and 2 (i.e., both DWEDS and DWFDS) are equivalent to the DNPS Unit 3 DWFDS and DWEDS sump configuration and volume (Le., approximately 1000 gallons full capacity each). All leakage from Reactor Coolant Pressure Boundary (RCPB) components inside the drywell, with the exception of leakage from the Main Steam Relief Valves (MSRVs) (Updated Final Safety Analysis Report (UFSAR) Section 5.2.5.2.1.8), flows directly to either the drywell equipment drain sump or the drywell floor drain sump. There are no other reservoirs in the drywell of sufficient capacity to prevent leakage from draining directly to either of these sumps. Both drain sumps are identically sized, horizontal cylindrical tanks located inside the reactor vessel pedestal below the diaphragm slab and vented to the drywell atmosphere. Leakage from RCPS components inside the primary containment which are not normally subject to leakage is collected by the DWFDS. This leakage, which may originate from any number of sources within the drywell, is transported to the sump via the floor drain network within the drywell. Thus, separation of unidentified leakage from the identifiable leakage routed to the equipment drain sump ensures that a small unidentified leakage that is of concern will not be masked by a larger, acceptable, identified leakage. The DWEDS monitoring system is similar to the DWFDS monitoring system. Certain RCPB components within the drywell are, by the nature of their design, normally subject to a limited amount of leakage. These components include pump seals, valve stem packings, and other equipment that cannot practicably be made to be completely leak-tight. These leakages are piped directly to the drywell equipment drain sump. All of the various drains are open only to the equipment they serve, thereby receiving leakage only from identified sources. Background leakage to this sump is determined during initial plant operation. Rates of leakage collection in excess of background indicates abnormal RCPB leakage. The control circuits for the two monitoring systems perform the same functions, and sump instrumentation consists of the same components and performs a similar function. Instruments for both monitoring systems are calibrated using similar plant procedures to satisfy TS Surveillance Requirements (SRs) for functional testing and calibration. Each sump tank has its own level transmitter which is monitored by a dedicated processing unit. Normally closed drain valves are provided, enabling the level in each tank to increase as leakage drains into them. The processing unit calculates an average leak rate for a given measurement period by establishing the amount of increase in level that occurred during the period, and converting that value into volumetric terms (gpm). The processing units provide an alarm in the main control room each time the average leak rate changes by a predetermined value since the last time that alarm was reset. The setpoint is a 1 gpm change in unidentified

Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 4of 10 leakage collected in the drywell floor drain sump tank, and a 2 gpm change in identified leakage collected in the drywell equipment drain tank. Alarms are also generated in the main control room for high total average leak rate. The high total average leak rate alarm setpoints can be adjusted at the processing unit, which is located in the main control room, as the amount of acceptable identified leakage changes during operation. Indication of the leakage rates is provided in the main control room on panel-mounted indicators. Sump tank levels (in gallons) are provided on monitors from the Plant Monitoring System. Level switches, which are independent of the level transmitters, open the sump tank drain valves when the level increases to an upper setpoint value and keep them open until the level decreases to the lower setpoint value. The level switches then close the drain valves and reset the processing units to start a new measurement period. The measurement period must be long enough to ensure that the level transmitter loop can adequately detect the increase in level that would correspond to the 1 gpm and 2 gpm changes in leak rates described above, and yet short enough to ensure that such a leak rate will be detected within an hour. The measurement period will be less than 1 hour. The transmitters which are located in the reactor enclosure and the processing units which are located in the main control room are accessible during normal plant operation for calibration. The transmitters can be isolated from the sump tanks by existing bypass manifolds. Zero and span adjustments can be made using portable test equipment. The processing unit functions can be calibrated by applying known input levels at the unit and observing the response. The Drywell Sump Level Monitoring System (DSLMS) is comprised of the processing units, level transmitters, control room leakage flow indicators and interconnecting raceway and cables. The DSLMS has been demonstrated to remain operational after a Safe Shutdown Earthquake. The DSLMS is energized by Class 1 E power. The Class 1 E power to the panel is provided with a Class 1 E fuse and circuit breaker in series to meet separation requirements. The DSLMS is automatically shed from the Class 1 E power in the event of a Loss of Coolant Accident (the load shedding relay, however, is not qualified for Class 1 E service). In additionto the sump level monitoring system described above, the discharge from each sump is monitored by a flow element. The measured flow rate is integrated and recorded in the control room. A control room alarm is also provided to indicate excessive discharge rates. These indications and alarms are provided in accordance with Regulatory Guide 1.45. 3.2 RCS Leakage Limits TS 3.4.3.2, OPERATIONAL LEAKAGE, specifies the leakage limits for the RCS. The leakage limits require, in part, unidentified leakage to be less than or equal to 5 gpm, total leakage averaged over the previous 24-hour period to be less than or equal to 25 gpm, and the increase in unidentified leakage within the previous 24-hour period to be less than 2 gpm. Section 5.2.5 of the LGS UFSAR describes the methods used for detection of leakage through the RCPB, and specifies use of the drywell sumps (i.e., DWFDS and DWEDS) as the primary methods that can be used. The leakage collected in the DWEDS is identified leakage, and the leakage collected in the DWFDS is unidentified leakage. TS 3.4.3.1 currently requires the DWFDS be operable as a RCS leakage detection system. The proposed change revises TS 3.4.3.1 to support the addition of an alternative method to use the Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 4 of 10 leakage collected in the drywell floor drain sump tank, and a 2 gpm change in identified leakage collected in the drywell equipment drain tank. Alarms are also generated in the main control room for high total average leak rate. The high total average leak rate alarm setpoints can be adjusted at the processing unit, which is located in the main control room, as the amount of acceptable identified leakage changes during operation. Indication of the leakage rates is provided in the main control room on panel-mounted indicators. Sump tank levels (in gallons) are provided on monitors from the Plant Monitoring System. Level switches, which are independent of the level transmitters, open the sump tank drain valves when the level increases to an upper setpoint value and keep them open until the level decreases to the lower setpoint value. The level switches then close the drain valves and reset the processing units to start a new measurement period. The measurement period must be long enough to ensure that the level transmitter loop can adequately detect the increase in level that would correspond to the 1 gpm and 2 gpm changes in leak rates described above, and yet short enough to ensure that such a leak rate will be detected within an hour. The measurement period will be less than 1 hour. The transmitters which are located in the reactor enclosure and the processing units which are located in the main control room are accessible during normal plant operation for calibration. The transmitters can be isolated from the sump tanks by existing bypass manifolds. Zero and span adjustments can be made using portable test equipment. The processing unit functions can be calibrated by applying known input levels at the unit and observing the response. The Drywell Sump Level Monitoring System (DSLMS) is comprised of the processing units, level transmitters, control room leakage flow indicators and interconnecting raceway and cables. The DSLMS has been demonstrated to remain operational after a Safe Shutdown Earthquake. The DSLMS is energized by Class 1E power. The Class 1E power to the panel is provided with a Class 1E fuse and circuit breaker in series to meet separation requirements. The DSLMS is automatically shed from the Class 1E power in the event of a Loss of Coolant Accident (the load shedding relay, however, is not qualified for Class 1E service). In addition, to the sump level monitoring system described above, the discharge from each sump is monitored by a flow element. The measured flow rate is integrated and recorded in the control room. A control room alarm is also provided to indicate excessive discharge rates. These indications and alarms are provided in accordance with Regulatory Guide 1.45. 3.2 RCS Leakage Limits TS 3.4.3.2, "OPERATIONAL LEAKAGE,II specifies the leakage limits for the RCS. The leakage limits require, in part, unidentified leakage to be less than or equal to 5 gpm, total leakage averaged over the previous 24-hour period to be less than or equal to 25 gpm, and the increase in unidentified leakage within the previous 24-hour period to be less than 2 gpm. Section 5.2.5 of the LGS UFSAR describes the methods used for detection of leakage through the RCPS, and specifies use of the drywell sumps (Le., DWFDS and DWEDS) as the primary methods that can be used. The leakage collected in the DWEDS is identified leakage, and the leakage collected in the DWFDS is unidentified leakage. TS 3.4.3.1 currently requires the DWFDS be operable as a RCS leakage detection system. The proposed change revises TS 3.4.3.1 to support the addition of an alternative method to use the Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 4 of 10 leakage collected in the drywell floor drain sump tank, and a 2 gpm change in identified leakage collected in the drywell equipment drain tank. Alarms are also generated in the main control room for high total average leak rate. The high total average leak rate alarm setpoints can be adjusted at the processing unit, which is located in the main control room, as the amount of acceptable identified leakage changes during operation. Indication of the leakage rates is provided in the main control room on panel-mounted indicators. Sump tank levels (in gallons) are provided on monitors from the Plant Monitoring System. Level switches, which are independent of the level transmitters, open the sump tank drain valves when the level increases to an upper setpoint value and keep them open until the level decreases to the lower setpoint value. The level switches then close the drain valves and reset the processing units to start a new measurement period. The measurement period must be long enough to ensure that the level transmitter loop can adequately detect the increase in level that would correspond to the 1 gpm and 2 gpm changes in leak rates described above, and yet short enough to ensure that such a leak rate will be detected within an hour. The measurement period will be less than 1 hour. The transmitters which are located in the reactor enclosure and the processing units which are located in the main control room are accessible during normal plant operation for calibration. The transmitters can be isolated from the sump tanks by existing bypass manifolds. Zero and span adjustments can be made using portable test equipment. The processing unit functions can be calibrated by applying known input levels at the unit and observing the response. The Drywell Sump Level Monitoring System (DSLMS) is comprised of the processing units, level transmitters, control room leakage flow indicators and interconnecting raceway and cables. The DSLMS has been demonstrated to remain operational after a Safe Shutdown Earthquake. The DSLMS is energized by Class 1E power. The Class 1E power to the panel is provided with a Class 1E fuse and circuit breaker in series to meet separation requirements. The DSLMS is automatically shed from the Class 1E power in the event of a Loss of Coolant Accident (the load shedding relay, however, is not qualified for Class 1E service). In addition, to the sump level monitoring system described above, the discharge from each sump is monitored by a flow element. The measured flow rate is integrated and recorded in the control room. A control room alarm is also provided to indicate excessive discharge rates. These indications and alarms are provided in accordance with Regulatory Guide 1.45. 3.2 RCS Leakage Limits TS 3.4.3.2, "OPERATIONAL LEAKAGE," specifies the leakage limits for the RCS. The leakage limits require, in part, unidentified leakage to be less than or equal to 5 gpm, total leakage averaged over the previous 24-hour period to be less than or equal to 25 gpm, and the increase in unidentified leakage within the previous 24-hour period to be less than 2 gpm. Section 5.2.5 of the LGS UFSAR describes the methods used for detection of leakage through the RCPS, and specifies use of the drywell sumps (Le., DWFDS and DWEDS) as the primary methods that can be used. The leakage collected in the DWEDS is identified leakage, and the leakage collected in the DWFDS is unidentified leakage. TS 3.4.3.1 currently requires the DWFDS be operable as a RCS leakage detection system. The proposed change revises TS 3.4.3.1 to support the addition of an alternative method to use the

Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 5 of 10 installed DWEDS in the situation that the DWFDS is inoperable and the DWEDS is operable. In this situation the inoperable DWFDS would overflow into the DWEDS which would be capable of quantifying total RCS leakage (i e , unidentified plus identified leakage) The resultant value of total RCS leakage would be conservatively verified to be less than the TS 3.4.3.2.b unidentified leakage limit of 5 gpm and TS 3 4 3 2 f unidentified leakage increase limit of 2 gpm within the previous 24 hours. 3.3 13_c_s Leakacie Detection While Filling the DWFL LGS TS SR 4.4.3.2.1.b requires the verification every 8 hours that RCS leakage measured by the DWFDS and DWEDS is within the specified limits of TS 3.4.3.2 (unidentified leakage to be less than or equal to 5 gpm and the increase in unidentified leakage within the previous 24 hour period to be less than 2 gpm). As described above, after the DWFDS begins overflowing into the DWEDS, the DWEDS can be used to measure total leakage (i.e., unidentified plus identified leakage). Overflow into the DWEDS was determined by an engineering evaluation to occur after accumulation of approximately 550 gallons in the DWFDS. In order for the DWFDS to overflow into the DWEDS, LGS personnel would either have to manually fill the DWFDS with an external water source or allow unidentified RCS leakage to fill the DWFDS. The use of unidentified RCS leakage to fill the DWFDS at or above 550 gallons in an 8 hour time period would require: 1. A minimum unidentified leakage rate of approximately 1.14 gpm, and 2. The regulatory commitments delineated in this submittal for LGS, Units 1 and 2 (i.e., verification of flow from the DWFDS to the DWEDS, prior to the initial use of the alternate monitoring method for a specific unit) have been satisfied. The minimum unidentified leakage rate of approximately 1.14 gpm is based on the leakage rate required to fill approximately 550 gallons in the DWFDS in 8 hours. The 8 hour period represents the TS-required surveillance interval as specified in SR 4.4.3.2.1.b but does not included the additional 25% grace, or 2 hours, allowed by SR 4.0.2. This minimum leakage rate 1.14 gpm would cause the DWFDS to overflow into the DWEDS within the required SR 4.4.3.2.1.b interval. TS 3.4.3.2.f requires that a2 gpm increase in unidentified leakage over a 24-hour period is able to be detected. Conservatively assuming an empty DWFDS and a minimum, immediate increase in unidentified leak rate of 2 gpm the DWFDS would fill up to approximately 550 gallons and begin to overflow to the DWEDS in 4.6 hours. As stated above in Section 3.1 of this Attachment, the level switches will detect a 2 gpm change in leak rates in the DWEDS and provide an alarm in the main control room. This meets the TS 3.4.3.2.f requirement to detect a 2 gpm increase in unidentified leakage over a 24-hour period. TS 3.4.3.2.b imposes a leakage limit of 5 gpm of unidentified leakage. Conservatively assuming an empty DWFDS and a minimum, immediate increase in unidentified leak rate of 5 gpm the DWFDS would fill up to approximately 550 gallons and begin to overflow to the DWEDS in 1.83 hours. As stated above in Section 3.1 of this Attachment, the level switches will detect a 2 gpm change in leak rates in the DWEDS and provide an alarm in the main control room. This amount of time is less than the TS Completion Time for TS 3.4.3.2, Action B which reduces unidentified leakage rate to within limits in 4 hours and the completion time for TS 3.4.3.1, Action B which restores the drywell sump monitoring system to Operable status within 30 days. Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 5 of 10 installed DWEDS in the situation that the DWFDS is inoperable and the DWEDS is operable. In this situation the inoperable DWFDS would overflow into the DWEDS which would be capable of quantifying total RCS leakage (Le., unidentified plus identified leakage). The resultant value of total RCS leakage would be conservatively verified to be less than the TS 3.4.3.2.b unidentified leakage limit of 5 gpm and TS 3.4.3.2.1 unidentified leakage increase limit of 2 gpm within the previous 24 hours. 3.3 RCS Leakage Detection While Filling the DWFDS LGS TS SR 4.4.3.2.1.b requires the verification every 8 hours that RCS leakage measured by the DWFDS and DWEDS is within the specified limits of TS 3.4.3.2 (unidentified leakage to be less than or equal to 5 gpm and the increase in unidentified leakage within the previous 24 hour period to be less than 2 gpm). As described above, after the DWFDS begins overflowing into the DWEDS, the DWEDS can be used to measure total leakage (Le., unidentified plus identified leakage). Overflow into the DWEDS was determined by an engineering evaluation to occur after accumulation of approximately 550 gallons in the DWFDS. In order for the DWFDS to overflow into the DWEDS, LGS personnel would either have to manually fill the DWFDS with an external water source or allow unidentified RCS leakage to fill the DWFDS. The use of unidentified RCS leakage to fill the DWFDS at or above 550 gallons in an 8 hour time period would require: 1. A minimum unidentified leakage rate of approximately 1.14 gpm, and 2. The regulatory commitments delineated in this submittal for LGS, Units 1 and 2 (Le., verification of flow from the DWFDS to the DWEDS, prior to the initial use of the alternate monitoring method for a specific unit) have been satisfied. The minimum unidentified leakage rate of approximately 1.14 gpm is based on the leakage rate required to fill approximately 550 gallons in the DWFDS in 8 hours. The 8 hour period represents the TS-required surveillance interval as specified in SR 4.4.3.2.1.b but does not included the additional 25% grace, or 2 hours, allowed by SR 4.0.2. This minimum leakage rate 1.14 gpm would cause the DWFDS to overflow into the DWEDS within the required SR 4.4.3.2.1.b interval. TS 3.4.3.2.1 requires that a'2 gpm increase in unidentified leakage over a 24-hour period is able to be detected. Conservatively assuming an empty DWFDS and a minimum, immediate increase in unidentified leak rate of 2 gpm the DWFDS would fill up to approximately 550 gallons and begin to overflow to the DWEDS in 4.6 hours. As stated above in Section 3.1 of this Attachment, the level switches will detect a 2 gpm change in leak rates in the DWEDS and provide an alarm in the main control room. This meets the TS 3.4.3.2.1 requirement to detect a 2 gpm increase in unidentified leakage over a 24-hour period. TS 3.4.3.2.b imposes a leakage limit of 5 gpm of unidentified leakage. Conservatively assuming an empty DWFDS and a minimum, immediate increase in unidentified leak rate of 5 gpm the DWFDS would fill up to approximately 550 gallons and begin to overflow to the DWEDS in 1.83 hours. As stated above in Section 3.1 of this Attachment, the level switches will detect a 2 gpm change in leak rates in the DWEDS and provide an alarm in the main control room. This amount of time is less than the TS Completion Time for TS 3.4.3.2, Action B which reduces unidentified leakage rate to within limits in 4 hours and the completion time for TS 3.4.3.1, Action B which restores the drywell sump monitoring system to Operable status within 30 days. Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 5 of 10 installed DWEDS in the situation that the DWFDS is inoperable and the DWEDS is operable. In this situation the inoperable DWFDS would overflow into the DWEDS which would be capable of quantifying total RCS leakage (Le., unidentified plus identified leakage). The resultant value of total RCS leakage would be conservatively verified to be less than the TS 3.4.3.2.b unidentified leakage limit of 5 gpm and TS 3.4.3.2.1 unidentified leakage increase limit of 2 gpm within the previous 24 hours. 3.3 RCS Leakage Detection While Filling the DWFDS LGS TS SR 4.4.3.2.1.b requires the verification every 8 hours that RCS leakage measured by the DWFDS and DWEDS is within the specified limits of TS 3.4.3.2 (unidentified leakage to be less than or equal to 5 gpm and the increase in unidentified leakage within the previous 24 hour period to be less than 2 gpm). As described above, after the DWFDS begins overflowing into the DWEDS, the DWEDS can be used to measure total leakage (Le., unidentified plus identified leakage). Overflow into the DWEDS was determined by an engineering evaluation to occur after accumulation of approximately 550 gallons in the DWFDS. In order for the DWFDS to overflow into the DWEDS, LGS personnel would either have to manually fill the DWFDS with an external water source or allow unidentified RCS leakage to fill the DWFDS. The use of unidentified RCS leakage to fill the DWFDS at or above 550 gallons in an 8 hour time period would require: 1. A minimum unidentified leakage rate of approximately 1.14 gpm, and 2. The regulatory commitments delineated in this submittal for LGS, Units 1 and 2 (Le., verification of flow from the DWFDS to the DWEDS, prior to the initial use of the alternate monitoring method for a specific unit) have been satisfied. The minimum unidentified leakage rate of approximately 1.14 gpm is based on the leakage rate required to fill approximately 550 gallons in the DWFDS in 8 hours. The 8 hour period represents the TS-required surveillance interval as specified in SR 4.4.3.2.1.b but does not included the additional 25% grace, or 2 hours, allowed by SR 4.0.2. This minimum leakage rate 1.14 gpm would cause the DWFDS to overflow into the DWEDS within the required SR 4.4.3.2.1.b interval. TS 3.4.3.2.1 requires that a'2 gpm increase in unidentified leakage over a 24-hour period is able to be detected. Conservatively assuming an empty DWFDS and a minimum, immediate increase in unidentified leak rate of 2 gpm the DWFDS would fill up to approximately 550 gallons and begin to overflow to the DWEDS in 4.6 hours. As stated above in Section 3.1 of this Attachment, the level switches will detect a 2 gpm change in leak rates in the DWEDS and provide an alarm in the main control room. This meets the TS 3.4.3.2.1 requirement to detect a 2 gpm increase in unidentified leakage over a 24-hour period. TS 3.4.3.2.b imposes a leakage limit of 5 gpm of unidentified leakage. Conservatively assuming an empty DWFDS and a minimum, immediate increase in unidentified leak rate of 5 gpm the DWFDS would fill up to approximately 550 gallons and begin to overflow to the DWEDS in 1.83 hours. As stated above in Section 3.1 of this Attachment, the level switches will detect a 2 gpm change in leak rates in the DWEDS and provide an alarm in the main control room. This amount of time is less than the TS Completion Time for TS 3.4.3.2, Action B which reduces unidentified leakage rate to within limits in 4 hours and the completion time for TS 3.4.3.1, Action B which restores the drywell sump monitoring system to Operable status within 30 days.

Alternate Method of Verifying Drywell Unidentified Leakage Evaluation of Proposed Changes Page 6 of 10 Therefore, depending upon the specific operational circumstances, filling of the DWFDS and ensuring flow from the DWFDS to the DWEDS would be established either manually with an external water source, or remotely, using the existing unidentified RCS leakage. In both circumstances the TS SR and TS Requirements in TS SR 3.4.3.2.1 and TS 3.4.3.2 will be met within the allotted completion times. 3.4 Summary By allowing the drywell floor drain sump to overflow into the drywell equipment drain sump, Operations personnel are not able to differentiate between the identified and unidentified leakage inputs. As such, all leakage in the drywell sumps will be conservatively treated as unidentified leakage in accordance with the TS 3.4.3.2 limits. Ensuring flow from the DWFDS to the DWEDS would be established either manually with an external water source, or remotely, using the existing unidentified RCS leakage. In both circumstances the TS SR and TS Requirements in TS SR 3.4.3.2.1 and TS 3.4.3.2 will be met within the allotted completion times. Therefore, the addition of an alternative method to quantify unidentified leakage in the drywell is conservative with respect to the current TS limits.

4.0 REGULATORY EVALUATION

4.1 Arplicable Regulatory Requirements I Criteria LGS Units 1 and 2 were originally designed and constructed following the issuance of the General Design Criteria (GDC). The GDC proposed criteria were adopted as regulatory requirements at both LGS Units. Details regarding the reactor coolant system leakage detection systems are provided in UFSAR Section 5.2.5, Reactor Coolant Pressure Boundary Leak Detection System. One of the leakage detection systems discussed is the drywell sumps (i.e., DWFDS and DWEDS). The UFSAR states that various leak detection systems and capabilities collectively detect reactor coolant pressure boundary leakage, both identified and unidentified. These indications and alarms are provided in accordance with Regulatory Guide 1.45. The proposed change does not involve physical changes to the RCS leakage detection systems. Rather, the proposed change allows use of the drywell equipment drain monitoring system to perform the function of the drywell floor drain monitoring system in quantifying unidentified leakage within the LGS Units 1 and 2 drywells. The design function of the RCS leakage detection systems is not affected by the proposed change. In addition, the alternative method conservatively assumes that all leakage in the drywell is unidentified leakage. Therefore, there is no impact to EGGs ability to meet the applicable regulatory requirements discussed above. 4.2 Precedent The proposed alternate method has been incorporated into the TSs for the Monticello Nuclear Generating Plant (References 6.10 and 6.11), the Peach Bottom Atomic Power Station, Unit 2 and Unit 3 (References 6.12 and 6.13). In addition, the NRC has previously approved similar Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 6 of 10 Therefore, depending upon the specific operational circumstances, filling of the DWFDS and ensuring flow from the DWFDS to the DWEDS would be established either manually with an external water source, or remotely, using the existing unidentified RCS leakage. In both circumstances the TS SR and TS Requirements in TS SR 3.4.3.2.1 and TS 3.4.3.2 will be met within the allotted completion times. 3.4 Summary By allowing the drywell floor drain sump to overflow into the drywell equipment drain sump, Operations personnel are not able to differentiate between the identified and unidentified leakage inputs. As such, all leakage in the drywell sumps will be conservatively treated as unidentified leakage in accordance with the TS 3.4.3.2 limits. Ensuring flow from the DWFDS to the DWEDS would be established either manually with an external water source, or remotely, using the existing unidentified RCS leakage. In both circumstances the TS SR and TS Requirements in TS SR 3.4.3.2.1 and TS 3.4.3.2 will be met within the allotted completion times. Therefore, the addition of an alternative method to quantify unidentified leakage in the drywell is conservative with respect to the current TS limits.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria LGS Units 1 and 2 were originally designed and constructed following the issuance of the General Design Criteria (GDC). The GDC proposed criteria were adopted as regulatory requirements at both LGS Units. Details regarding the reactor coolant system leakage detection systems are provided in UFSAR Section 5.2.5,11 Reactor Coolant Pressure Boundary Leak Detection System. 1I One of the leakage detection systems discussed is the drywell sumps (Le., DWFDS and DWEDS). The UFSAR states that various leak detection systems and capabilities collectively detect reactor coolant pressure boundary leakage, both identified and unidentified. These indications and alarms are provided in accordance with Regulatory Guide 1.45. The proposed change does not involve physical changes to the RCS leakage detection systems. Rather, the proposed change allows use of the drywell equipment drain monitoring system to perform the function of the drywell floor drain monitoring system in quantifying unidentified leakage within the LGS Units 1 and 2 drywells. The design function of the RCS leakage detection systems is not affected by the proposed change. In addition, the alternative method conservatively assumes that all leakage in the drywell is unidentified leakage. Therefore, there is no impact to EGC's ability to meet the applicable regulatory requirements discussed above. 4.2 Precedent The proposed alternate method has been incorporated into the TSs for the Monticello Nuclear Generating Plant (References 6.10 and 6.11), the Peach Bottom Atomic Power Station, Unit 2 and Unit 3 (References 6.12 and 6.13). In addition, the NRC has previously approved similar Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 6 of 10 Therefore, depending upon the specific operational circumstances, filling of the DWFDS and ensuring flow from the DWFDS to the DWEDS would be established either manually with an external water source, or remotely, using the existing unidentified RCS leakage. In both circumstances the TS SR and TS Requirements in TS SR 3.4.3.2.1 and TS 3.4.3.2 will be met within the allotted completion times. 3.4 Summary By allowing the drywell floor drain sump to overflow into the drywell equipment drain sump, Operations personnel are not able to differentiate between the identified and unidentified leakage inputs. As such, all leakage in the drywell sumps will be conservatively treated as unidentified leakage in accordance with the TS 3.4.3.2 limits. Ensuring flow from the DWFDS to the DWEDS would be established either manually with an external water source, or remotely, using the existing unidentified RCS leakage. In both circumstances the TS SR and TS Requirements in TS SR 3.4.3.2.1 and TS 3.4.3.2 will be met within the allotted completion times. Therefore, the addition of an alternative method to quantify unidentified leakage in the drywell is conservative with respect to the current TS limits.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria LGS Units 1 and 2 were originally designed and constructed following the issuance of the General Design Criteria (GDC). The GDC proposed criteria were adopted as regulatory requirements at both LGS Units. Details regarding the reactor coolant system leakage detection systems are provided in UFSAR Section 5.2.5,11 Reactor Coolant Pressure Boundary Leak Detection System. 1I One of the leakage detection systems discussed is the drywell sumps (Le., DWFDS and DWEDS). The UFSAR states that various leak detection systems and capabilities collectively detect reactor coolant pressure boundary leakage, both identified and unidentified. These indications and alarms are provided in accordance with Regulatory Guide 1.45. The proposed change does not involve physical changes to the RCS leakage detection systems. Rather, the proposed change allows use of the drywell equipment drain monitoring system to perform the function of the drywell floor drain monitoring system in quantifying unidentified leakage within the LGS Units 1 and 2 drywells. The design function of the RCS leakage detection systems is not affected by the proposed change. In addition, the alternative method conservatively assumes that all leakage in the drywell is unidentified leakage. Therefore, there is no impact to EGC's ability to meet the applicable regulatory requirements discussed above. 4.2 Precedent The proposed alternate method has been incorporated into the TSs for the Monticello Nuclear Generating Plant (References 6.10 and 6.11), the Peach Bottom Atomic Power Station, Unit 2 and Unit 3 (References 6.12 and 6.13). In addition, the NRC has previously approved similar

Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 7 of 10 amendment requests to the TS for Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2 (References 6.1 and 6.3 ). The subject license amendment request proposes to adopt revisions consistent with those proposed in the previously approved amendments. 4.3 Nc Significant Hazards ConsideratiQil In accordance with 10 CFR 50.90, ApplicatiOn for amendment of license, construction permit, or early site permit, Exelon Generation Company, LLC (EGC) requests an amendment to Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively. Specifically, the proposed change revises the Technical Specifications (TS) to support implementation of an alternative method of verifying that leakage into the drywell floor drain sump is within limits. The alternative method involves use of the installed drywell equipment drain sump monitoring system to quantify unidentified leakage in the drywell. EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 1 0 CFR 50.92, Issuance of amendment, as discussed below: (1 ) Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? Response: No. The proposed change does not involve physical changes to any plant structure, system, or component. As a result, no new failure modes of the Reactor Coolant System (RCS) leakage detection systems are being introduced. Additionally, the RCS leakage detection systems have no impact on any initiating event frequency. The consequences of a previously analyzed accident are dependent on the initial conditions assumed for the analysis, the behavior of the fuel during the analyzed accident, the availability and successful functioning of the equipment assumed to operate in response to the analyzed event, and the setpoints at which these actions are initiated. The RCS leakage detection systems do not perform an accident mitigating function. Emergency Core Cooling System, Reactor Protection System, and primary and secondary containment isolation actuations are not affected by the proposed change. The proposed change has no impact on any setpoints or functions related to these actuations. There are no changes in the types or significant increase in the amounts of any effluents released offsite. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. (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 allows use of the drywell equipment drain system as an alternative method of quantifying unidentified leakage in the drywell. The drywell Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 7 of 10 amendment requests to the TS for Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2 (References 6.1 and 6.3). The subject license amendment request proposes to adopt revisions consistent with those proposed in the previously approved amendments. 4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit, II Exelon Generation Company, LLC (EGC) requests an amendment to Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively. Specifically, the proposed change revises the Technical Specifications (TS) to support implementation of an alternative method of verifying that leakage into the drywell floor drain sump is within limits. The alternative method involves use of the installed drywell equipment drain sump monitoring system to quantify unidentified leakage in the drywell. EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "lssuance of amendment, II as discussed below: (1) Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? Response: No. The proposed change does not involve physical changes to any plant structure, system, or component. As a result, no new failure modes of the Reactor Coolant System (RCS) leakage detection systems are being introduced. Additionally, the RCS leakage detection systems have no impact on any initiating event frequency. The consequences of a previously analyzed accident are dependent on the initial conditions assumed for the analysis, the behavior of the fuel during the analyzed accident, the availability and successful functioning of the equipment assumed to operate in response to the analyzed event, and the setpoints at which these actions are initiated. The ReS leakage detection systems do not perform an accident mitigating function. Emergency Core Cooling System, Reactor Protection System, and primary and secondary containment isolation actuations are not affected by the proposed change. The proposed change has no impact on any setpoints or functions related to these actuations. There are no changes in the types or significant increase in the amounts of any effluents released offsite. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. (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 allows use of the drywell equipment drain system as an alternative method of quantifying unidentified leakage in the drywell. The drywell Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 7 of 10 amendment requests to the TS for Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2 (References 6.1 and 6.3). The subject license amendment request proposes to adopt revisions consistent with those proposed in the previously approved amendments. 4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit, II Exelon Generation Company, LLC (EGC) requests an amendment to Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively. Specifically, the proposed change revises the Technical Specifications (TS) to support implementation of an alternative method of verifying that leakage into the drywell floor drain sump is within limits. The alternative method involves use of the installed drywell equipment drain sump monitoring system to quantify unidentified leakage in the drywell. EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "lssuance of amendment, II as discussed below: (1) Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? Response: No. The proposed change does not involve physical changes to any plant structure, system, or component. As a result, no new failure modes of the Reactor Coolant System (RCS) leakage detection systems are being introduced. Additionally, the RCS leakage detection systems have no impact on any initiating event frequency. The consequences of a previously analyzed accident are dependent on the initial conditions assumed for the analysis, the behavior of the fuel during the analyzed accident, the availability and successful functioning of the equipment assumed to operate in response to the analyzed event, and the setpoints at which these actions are initiated. The ReS leakage detection systems do not perform an accident mitigating function. Emergency Core Cooling System, Reactor Protection System, and primary and secondary containment isolation actuations are not affected by the proposed change. The proposed change has no impact on any setpoints or functions related to these actuations. There are no changes in the types or significant increase in the amounts of any effluents released offsite. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. (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 allows use of the drywell equipment drain system as an alternative method of quantifying unidentified leakage in the drywell. The drywell

Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 8 of 10 equipment drain system will continue to be used for leakage collection and quantification. There is no alteration to the parameters within which the plant is normally operated or in the setpoints that initiate protective or mitigative actions As a result, no new failure modes are being introduced. Therefore, the proposed 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 current TS require a periodic measurement of RCS leakage. The proposed change maintains the existing level of safety by allowing use of the drywell equipment drain sump system to quantify unidentified leakage in the drywell. No changes are being made to any of the RCS leakage limits specified in the TS. The impact of the change is that measured unidentified and identified leakage within the drywell will be quantified as equivalent values since the drywell equipment drain sump monitoring system will also be used to measure leakage into the drywell floor drain sump. In addition, the alternative method conservatively assumes that all leakage in the drywell is unidentified leakage. Therefore, the proposed change does not involve a significant reduction in a margin of safety. Based on the above, EGC concludes that the proposed amendment does not involve a significant hazards consideration under the standards setforth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified. 4.4 Conclusions In 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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public. 5.0 ENVI RONMENTAL CONSIDERATION A review has determined that 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 1 0 CFR 20, Standards for Protection Against Radiation. 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 effluent 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 needs to be prepared in connection with the proposed amendment. Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 8 of 10 equipment drain system will continue to be used for leakage collection and quantification. There is no alteration to the parameters within which the plant is normally operated or in the setpoints that initiate protective or mitigative actions. As a result, no new failure modes are being introduced. Therefore, the proposed 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 current TS require a periodic measurement of RCS leakage. The proposed change maintains the existing level of safety by allowing use of the drywell equipment drain sump system to quantify unidentified leakage in the drywell. No changes are being made to any of the RCS leakage limits specified in the TS. The impact of the change is that measured unidentified and identified leakage within the drywell will be quantified as equivalent values since the drywell equipment drain sump monitoring system will also be used to measure leakage into the drywell floor drain sump. In addition, the alternative method conservatively assumes that all leakage in the drywell is unidentified leakage. Therefore, the proposed change does not involve a significant reduction in a margin of safety. Based on the above, EGC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified. 4.4 Conclusions In 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 the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that 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, "Standards for Protection Against Radiation." 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 effluent 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, purs.uant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment. Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 8 of 10 equipment drain system will continue to be used for leakage collection and quantification. There is no alteration to the parameters within which the plant is normally operated or in the setpoints that initiate protective or mitigative actions. As a result, no new failure modes are being introduced. Therefore, the proposed 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 current TS require a periodic measurement of RCS leakage. The proposed change maintains the existing level of safety by allowing use of the drywell equipment drain sump system to quantify unidentified leakage in the drywell. No changes are being made to any of the RCS leakage limits specified in the TS. The impact of the change is that measured unidentified and identified leakage within the drywell will be quantified as equivalent values since the drywell equipment drain sump monitoring system will also be used to measure leakage into the drywell floor drain sump. In addition, the alternative method conservatively assumes that all leakage in the drywell is unidentified leakage. Therefore, the proposed change does not involve a significant reduction in a margin of safety. Based on the above, EGC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified. 4.4 Conclusions In 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 the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that 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, "Standards for Protection Against Radiation." 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 effluent 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, purs.uant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 9 of 10

6.0 REFERENCES

6i Letter from J. L. Hansen (Exelon Generation Company, LLC for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station) to U.S. NRC, Request for License Amendment to Revise Technical Specification 3.4.5, RCS Leakage Detection Instrumentation, to Allow Alternate Method of Verifying Drywell Leakage dated August 28, 2009 6.2. Letter from C. Gratton (U.S. NRC) to M. J. Pacilio (Exelon Generation Company, LLC), Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 -Issuance of Amendments RE: Authorizing Alternative Methods of Verifying Leakage within the Drywell (TAC NOS. ME21 48 THRU ME21 51 ), dated August 16, 2010 6.3. Letter from D. B. Wozniak (Exelon Generation Company, LLC for Dresden Nuclear Power Station) to U.S. NRC, Request for Enforcement Discretion for Technical Specifications (TS) 3.4.4, RCS Operational Leakage and TS 3.4.5, RCS Leakage Detection Instrumentation, dated August 1 9, 2008 6.4. Letter from C. Pederson (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), Notice of Enforcement Discretion for Exelon Generation Company LLC Regarding Dresden Nuclear Power Station, Unit 3 (NOED 08-3-002), dated August 21, 2008 6.5. Letter from P. R. Simpson (Exelon Generation Company, LLC for Dresden Nuclear Power Station) to U.S. NRC, Request for Emergency License Amendment Regarding Drywell Floor Drain Sump Monitoring System, dated August 18, 2008 6.6. Letter from C. Gratton (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), Dresden Nuclear Power Station, Unit 3 Issuance of Emergency Amendment Regarding Drywell Floor Drain Sump Monitoring System (TAC No. MD9467), dated August 22, 2008 6.7. Letter from C. Gratton (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 - Request for Additional Information Related to Alternate Method of Verifying Drywell Leakage (TAC Nos. ME2148 thru ME2151), dated January 15, 2010. 6.8. Letter from J. L. Hansen (Exelon Generation Company, LLC for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station) to U.S. NRC, Supplemental Information Concerning Request for License Amendment to Revise Technical Specification 3.4.5, RCS Leakage Detection Instrumentation, dated February 5, 2010 6.9. Letter from J. L. Hansen (Exelon Generation Company, LLC for Quad Cities Nuclear Power Station) to U.S. NRC, Supplemental Information Concerning Request for License Amendment to Revise Technical Specification 3.4.5, RCS Leakage Detection Instrumentation dated June 2, 2010 6.10. Letter from L. M. Padovan (U.S. NRC) to D. L. Wilson (Nuclear Management Company, LLC), Monticello Nuclear Generating Plant Issuance of Amendment Re: Drywell Leakage and Sump Monitoring Detection System (TAC No. MB7945), dated August 21, 2003 Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 9 of 10

6.0 REFERENCES

6.1. Letter from J. L. Hansen (Exelon Generation Company, LLC for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station) to U.S. NRC, "Request for License Amendment to Revise Technical Specification 3.4.5, IIRCS Leakage Detection Instrumentation,1I to Allow Alternate Method of Verifying Drywell Leakage" dated August 28,2009 6.2. Letter from C. Gratton (U.S. NRC) to M. J. Pacilio (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 -Issuance of Amendments RE: Authorizing Alternative Methods of Verifying Leakage within the Drywell (TAC NOS. ME2148 THRU ME2151 )," dated August 16,2010 6.3. Letter from D. B. Wozniak (Exelon Generation Company, LLC for Dresden Nuclear Power Station) to U.S. NRC, IIRequest for Enforcement Discretion for Technical Specifications (TS) 3.4.4, IRCS Operational Leakage l and TS 3.4.5, IRCS Leakage Detection Instrumentation:" dated August 19, 2008 6.4. Letter from C. Pederson (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), "Notice of Enforcement Discretion for Exelon Generation Company LLC Regarding Dresden Nuclear Power Station; Unit 3 (NOED 08-3-002), II dated August 21, 2008 6.5. Letter from P. R. Simpson (Exelon Generation Company, LLC for Dresden Nuclear Power Station) to U.S. NRC, "Request for Emergency License Amendment Regarding Drywell Floor Drain Sump Monitoring System," dated August 18, 2008 6.6. Letter from C. Gratton (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Unit 3 - Issuance of Emergency Amendment Regarding Drywell Floor Drain Sump Monitoring System (TAC No. MD9467)," dated August22,2008 6.7. Letter from C. Gratton (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 - Request for Additional Information Related to Alternate Method of Verifying Drywell Leakage (TAC Nos. ME2148 thru ME2151)," dated January 15, 2010. 6.8. Letter from J. L. Hansen (Exelon Generation Company, LLC for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station) to U.S. NRC, "Supplemental Information Concerning Request for License Amendment to Revise Technical Specification 3.4.5, 'RCS Leakage Detection Instrumentation"', dated February 5,2010 6.9. Letter from J. L. Hansen (Exelon Generation Company, LLC for Quad Cities Nuclear Power Station) to U.S. NRC, Supplemental Information Concerning Request for License Amendment to Revise Technical Specification 3.4.5, "RCS Leakage Detection Instrumentation" dated June 2, 2010 6.10. Letter from L. M. Padovan (U.S. NRC) to D. L. Wilson (Nuclear Management Company, LLC), "Monticello Nuclear Generating Plant - Issuance of Amendment Re: Drywell Leakage and Sump Monitoring Detection System (TAC No. MB7945),1I dated August 21, 2003 Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 9 of 10

6.0 REFERENCES

6.1. Letter from J. L. Hansen (Exelon Generation Company, LLC for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station) to U.S. NRC, "Request for License Amendment to Revise Technical Specification 3.4.5, IIRCS Leakage Detection Instrumentation,1I to Allow Alternate Method of Verifying Drywell Leakage" dated August 28,2009 6.2. Letter from C. Gratton (U.S. NRC) to M. J. Pacilio (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 -Issuance of Amendments RE: Authorizing Alternative Methods of Verifying Leakage within the Drywell (TAC NOS. ME2148 THRU ME2151 )," dated August 16,2010 6.3. Letter from D. B. Wozniak (Exelon Generation Company, LLC for Dresden Nuclear Power Station) to U.S. NRC, IIRequest for Enforcement Discretion for Technical Specifications (TS) 3.4.4, IRCS Operational Leakage l and TS 3.4.5, IRCS Leakage Detection Instrumentation:" dated August 19, 2008 6.4. Letter from C. Pederson (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), "Notice of Enforcement Discretion for Exelon Generation Company LLC Regarding Dresden Nuclear Power Station; Unit 3 (NOED 08-3-002), II dated August 21, 2008 6.5. Letter from P. R. Simpson (Exelon Generation Company, LLC for Dresden Nuclear Power Station) to U.S. NRC, "Request for Emergency License Amendment Regarding Drywell Floor Drain Sump Monitoring System," dated August 18, 2008 6.6. Letter from C. Gratton (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Unit 3 - Issuance of Emergency Amendment Regarding Drywell Floor Drain Sump Monitoring System (TAC No. MD9467)," dated August22,2008 6.7. Letter from C. Gratton (U.S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 - Request for Additional Information Related to Alternate Method of Verifying Drywell Leakage (TAC Nos. ME2148 thru ME2151)," dated January 15, 2010. 6.8. Letter from J. L. Hansen (Exelon Generation Company, LLC for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station) to U.S. NRC, "Supplemental Information Concerning Request for License Amendment to Revise Technical Specification 3.4.5, 'RCS Leakage Detection Instrumentation"', dated February 5,2010 6.9. Letter from J. L. Hansen (Exelon Generation Company, LLC for Quad Cities Nuclear Power Station) to U.S. NRC, Supplemental Information Concerning Request for License Amendment to Revise Technical Specification 3.4.5, "RCS Leakage Detection Instrumentation" dated June 2, 2010 6.10. Letter from L. M. Padovan (U.S. NRC) to D. L. Wilson (Nuclear Management Company, LLC), "Monticello Nuclear Generating Plant - Issuance of Amendment Re: Drywell Leakage and Sump Monitoring Detection System (TAC No. MB7945),1I dated August 21, 2003

Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 1 0 of 10 6.1 1. Letter from T. A. Beltz (U.S. NRC) to J. T. Conway (Nuclear Management Company, LLC), Monticello Nuclear Generating Plant (MGNP) Issuance of Amendment for the Conversion to the Improved Technical Specifications with Beyond-Scope Issues (TAC Nos. MC7505, MC7597, through MC761 1, and MC8887), dated June 5, 2006 6.12. Letter from G. Gears (US. NRC) to E. G. Bauer (Philadelphia Electric Company), Technical Specification Amendments Pertaining to the Monitoring of Coolant Leakage and the Providing of Limitations on Iodine Concentrations in the Reactor Coolant, dated February 27, 1985 6.13. Letter from J. W Shea (U.S. NRC) to G. A. Hunger, Jr., (PECO Energy Company, Issuance of Improved Technical Specifications, Peach Bottom Atomic Power Station, Unit Nos. 2 and 3, (TAC Nos. M90746 and M90747), dated August 30, 1995 Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 10 of 10 6.11. Letter from T. A. Beltz (U.S. NRC) to J. T. Conway (Nuclear Management Company, LLC), IIMonticelio Nuclear Generating Plant (MGNP) - Issuance of Amendment for the Conversion to the Improved Technical Specifications with Beyond-Scope Issues (TAC Nos. MC7505, MC7597, through MC7611, and MC8887),1I dated June 5,2006 6.12. Letter from G. Gears (U.S. NRC) to E. G. Bauer (Philadelphia Electric Company), IITechnical Specification Amendments Pertaining to the Monitoring of Coolant Leakage and the Providing of Limitations on Iodine Concentrations in the Reactor Coolant, II dated February 27, 1985 6.13. Letter from J. W Shea (U.S. NRC) to G. A. Hunger, Jr., (PECO Energy Company, IIlssuance of Improved Technical Specifications, Peach Bottom Atomic Power Station, Unit Nos. 2 and 3, (TAG Nos. M90746 and M90747),1I dated August 30, 1995 Alternate Method of Verifying Drywell Unidentified Leakage : Evaluation of Proposed Changes Page 10 of 10 6.11. Letter from T. A. Beltz (U.S. NRC) to J. T. Conway (Nuclear Management Company, LLC), IIMonticelio Nuclear Generating Plant (MGNP) - Issuance of Amendment for the Conversion to the Improved Technical Specifications with Beyond-Scope Issues (TAC Nos. MC7505, MC7597, through MC7611, and MC8887),1I dated June 5,2006 6.12. Letter from G. Gears (U.S. NRC) to E. G. Bauer (Philadelphia Electric Company), IITechnical Specification Amendments Pertaining to the Monitoring of Coolant Leakage and the Providing of Limitations on Iodine Concentrations in the Reactor Coolant, II dated February 27, 1985 6.13. Letter from J. W Shea (U.S. NRC) to G. A. Hunger, Jr., (PECO Energy Company, IIlssuance of Improved Technical Specifications, Peach Bottom Atomic Power Station, Unit Nos. 2 and 3, (TAG Nos. M90746 and M90747),1I dated August 30, 1995

-n

JJm 2

(rim i CDC m C) 0 -4% z -4 CD ci) C, -o CD C, o I o o* z cC1) p 1 ATTACHMENT 2 Markup of Technical Specifications Pages Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATIONS PAGES 3/44-8 ATTACHMENT 2 Markup of Technical Specifications Pages Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATIONS PAGES 3/44-8

.314.4.,,3 flEAC[Q!JQOLANT SYSIEM LEAKAGE EAKAGE UEFECIIQN SYS EEMS 34.3.1 The following reactor coolant leakage detection systems shall be OPERABLE: a. The primary containment atmosphere gaseous radioactivity monitoring system, b. The drywell +I-tor dr-kisump flow-onitoring system, c. The drywell unit coolers condensate flow rate monitoring system, and d. The primary containment pressure and temperature monitoring system. APPLI.CAIULLFY; OPERATIONAL CONDITIONS 1, 2, and 3,* The primary containment gaseous radioactivity monitor is not required to be operable until Operational Condition 2. ACTIONS.: A. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours AND restore primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days. B. With the drywell +oordrain-ump f+ewmonitoring system inoperable, restore the drywell floor ra-itsump #+wmonitoring system to OPERABLE status within 30 days AND increase monitoring frequency of dryweli unit cooler condensate flow rate (SR 4.4.3.2.1.c) to once every 8 hours. C. With the drywell unit coolers condensate flow rate monitoring system inoperable, AND the primary containment atmosphere gaseous radioactivity monitoring system OPERABLE, perform a channel check of the primary containment atmosphere gaseous radioactivity monitoring system (SR 4.4.3.1.a) once per 8 hours. D. With the primary containment pressure and temperature monitoring system inoperable, restore the primary containment pressure and temperature monitoring system to OPERABLE status within 30 days. NOTE: All other Tech Spec Limiting Conditions For Qperation and Surveillance. Requirements associated with the priinary containment pressure/temperaturemonitoring system still apply. Affected TechSpecSections include: 3/4.3.7.5. 4.4.3.2.1. 3/4.6.L6. and 3/4.6.1.7. E. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable AND the drywell unit coolers condensate flow rate monitoring system inoperable, restore the primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days OR restore the drywell unit coolers condensate flow rate monitoring system to OPERABLE status within 30 days. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours. LIMERICK uNIT 1 3/4 4-8 Amendment 4, BEACTOR COQLANTSYSTEM .3/4.4.3 REACTQR COOLANT SYSTEM LEAKAGE LEAKAGE DETECrION SYSTEMS 3.4.3.1 The following reactor coolant leakage detection systems shall be OPERABLE: a. The pr'imary containment atmosphere gaseous radioactivity monitoring system, b. The drywell floor draiNJsump ~onitoring system, c. The drywell unit coo'l ers condensate flow rate monitoring system, and d. The primary containment pressure and temperature monitoring system. APPLICABILITY; OPERATIONAL CONDITIONS 1, 2, and 3.*

• - The primary containment gaseous radioactivity monitor is not required to be operable until Operational Condition 2.

ACTIONS: A. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours AND restore primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days. B. With the drywell floor drai~ump ~monitoring system inoperable, restore the drywell floor drai~sump,f1-ew'monitoringsystem to OPERABLE status within 30 days AND increase monitoring frequency of drywel'l unit cooler condensate flow rate (SR 4.4.3.2.1.c) to once every 8 hours. c. With the drywell unit coolers condensate flow rate monitoring system inoperable, AND the primary containment atmosphere gaseous radioactivity monitoring system OPERABLE, perform a channel check of the primary containment atmosphere gaseous radioactivity monitoring system CSR 4.4.3.1.a) once per 8 hours. D. With the primary containment pressure and temperature monitoring system inoperable, restore the primary containment pressure and temperature monitoring system to OPERABLE status within 30 days. NOTE: All other Tech Spec Limiting Conditions For Operation and Surveillance ReqUirements associated with the primary containment pressure/temperature monitoring system still apply. Affected Tech Spec Sections include: 3/4.3.7.5, 4.4.3.2.1, 3/4.6.1.6, and 3/4.6.1.7. E. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable AND the drywel1 unit coolers condensate flow rate monitoring system inoperable, restore the primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days OR restore the drywell unit coolers condensate flow rate monitoring system to OPERABLE status within 30 days. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours. LIMERICK - UNIT 1 3/4 4-8 Amendment ++/-, 14Q, ~, ~ BEACTOR COQLANTSYSTEM .3/4.4.3 REACTQR COOLANT SYSTEM LEAKAGE LEAKAGE DETECrION SYSTEMS 3.4.3.1 The following reactor coolant leakage detection systems shall be OPERABLE: a. The pr'imary containment atmosphere gaseous radioactivity monitoring system, b. The drywell floor draiNJsump ~onitoring system, c. The drywell unit coo'l ers condensate flow rate monitoring system, and d. The primary containment pressure and temperature monitoring system. APPLICABILITY; OPERATIONAL CONDITIONS 1, 2, and 3.*

• - The primary containment gaseous radioactivity monitor is not required to be operable until Operational Condition 2.

ACTIONS: A. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours AND restore primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days. B. With the drywell floor drai~ump ~monitoring system inoperable, restore the drywell floor drai~sump,f1-ew'monitoringsystem to OPERABLE status within 30 days AND increase monitoring frequency of drywel'l unit cooler condensate flow rate (SR 4.4.3.2.1.c) to once every 8 hours. c. With the drywell unit coolers condensate flow rate monitoring system inoperable, AND the primary containment atmosphere gaseous radioactivity monitoring system OPERABLE, perform a channel check of the primary containment atmosphere gaseous radioactivity monitoring system CSR 4.4.3.1.a) once per 8 hours. D. With the primary containment pressure and temperature monitoring system inoperable, restore the primary containment pressure and temperature monitoring system to OPERABLE status within 30 days. NOTE: All other Tech Spec Limiting Conditions For Operation and Surveillance ReqUirements associated with the primary containment pressure/temperature monitoring system still apply. Affected Tech Spec Sections include: 3/4.3.7.5, 4.4.3.2.1, 3/4.6.1.6, and 3/4.6.1.7. E. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable AND the drywel1 unit coolers condensate flow rate monitoring system inoperable, restore the primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days OR restore the drywell unit coolers condensate flow rate monitoring system to OPERABLE status within 30 days. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours. LIMERICK - UNIT 1 3/4 4-8 Amendment ++/-, 14Q, ~, ~

JjA(II1iLCQOLAN V S YST LN

3/1...4 J REACTOR J:OOLANI.SYSTEM.LEAKAGE 3.43.1 The following reactor coolant leakage detection systems shall be OPERABLE:

a. The primary containment atmosphere gaseous radioactivity monitoring system, b. The drywel 1

system, C.

The drywel 1 urn t cool ers condensa te fl (3W rate riion tor 1 fl system, and d. The primary containment pressure arid temperature monitoring system. APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3k k The primary containment gaseous radioactivity monitor is not required to be operable until Operational Condition 2. ACT.I ONS A. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours AND restore primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days. B. With the drywell frr+isump 9-rWionitoring system inoperable, restore the drywell +eed-t-4-risump ++wmonitoring system to OPERABLE status within 30 days AND increase monitoring frequency of drywell unit cooler condensate flow rate (SR 4.4.3.2.1.c) to once every 8 hours. C. With the drywell unit coolers condensate flow rate monitoring system inoperable, AND the primary containment atmosphere gaseous radioactivity monitoring system OPERABLE, perform a channel check of the primary containment atmosphere gaseous radioactivity monitoring system (SR 4.4.3.1.a) once per 8 hours. D. With the primary containment pressure and temperature monitoring system inoperable, restore the primary containment pressure and temperature monitoring system to OPERABLE status within 30 days. Note: All other Tech Spec Limiting Conditions For Operation and Surveillance Requirements associated with the primary containment pressure/temperature monitoring system still apply. Affected Tech Spec Sections include: 3/4.3.7.5. 4.4.3.2.1. 3/4.6.1.6. and 3/4.6.1.7. E. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable AND the drywell unit coolers condensate flow rate monitoring system inoperable, restore the primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days OR restore the drywell unit coolers condensate flow rate monitoring system to OPERABLE status within 30 days. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours. LIMERICK UNIT 2 3/4 4-8 Amendment No.,,, REACTOR COOLANT SYSTEM JLAK8GE DETECTION SYSTEMS 3.4.3.1 The following reactor coolant leakage detection systems shall be OPERABLE: a. The primary containment atmosphere gaseous rad'; oacti vi ty rnonitor'ing system, b. The drywe-Il floci dt ~i I~ump~oni tori ng system, c. The drywe'll un'j t coolers condensate f'low rate rnanit 0 ri n9 system, and d. The primary containment pressure and temperature monitor"jng system. APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.*

• - The primary containment gaseous radioactivity monitor is not required to be operable until Operational Condition 2.

ACTIONS; A. B. c. D. E. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours AND restore primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days. With the drywell floc" dt elirt'sump ~monitoring system inoperable, restore the drywell ~~eor draiMasump ~mon;toring system to OPERABLE status within 30 days AND increase monitoring frequency of drywell unit cooler condensate flow rate (SR 4.4.3.2.1.c) to once every 8 hours. With the drywell unit coolers condensate flow rate monitoring system inoperable, AND the primary containment atmosphere gaseous radioactivity monitoring system OPERABLE, perform a channel check of the primary containment atmosphere gaseous radioactivity monitoring system (SR 4.4.3.1.a) once per 8 hours. With the primary containment pressure and temperature monitoring system inoperable, restore the primary containment pressure and temperature monitoring system to OPERABLE status within 30 days. Note: All other Tech Spec Limiting Conditions For Operation and Surveillance Requirements associated with the primary containment pressure/temperature monitoring system sti)) apply. Affected Tech Spec Sections include: 3/4.3.7.5. 4.4.3.2.1. 3/4.6.1.6. and 3/4.6.1.7. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable AND the drywell unit coolers condensate flow rate monitoring system inoperable, restore the primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days OR restore the drywell unit coolers condensate flow rate monitoring system to OPERABLE status within 30 days. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours. LIMERICK - UNIT 2 3/4 4-8 Amendment No. J4, ~, ~, ~ REACTOR COOLANT SYSTEM JLAK8GE DETECTION SYSTEMS 3.4.3.1 The following reactor coolant leakage detection systems shall be OPERABLE: a. The primary containment atmosphere gaseous rad'; oacti vi ty rnonitor'ing system, b. The drywe-Il floci dt ~i I~ump~oni tori ng system, c. The drywe'll un'j t coolers condensate f'low rate rnanit 0 ri n9 system, and d. The primary containment pressure and temperature monitor"jng system. APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.*

• - The primary containment gaseous radioactivity monitor is not required to be operable until Operational Condition 2.

ACTIONS; A. B. c. D. E. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours AND restore primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days. With the drywell floc" d' elirt'sump ~monitoring system inoperable, restore the drywell ~~eor draiMasump ~mon;toring system to OPERABLE status within 30 days AND increase monitoring frequency of drywell unit cooler condensate flow rate (SR 4.4.3.2.1.c) to once every 8 hours. With the drywell unit coolers condensate flow rate monitoring system inoperable, AND the primary containment atmosphere gaseous radioactivity monitoring system OPERABLE, perform a channel check of the primary containment atmosphere gaseous radioactivity monitoring system (SR 4.4.3.1.a) once per 8 hours. With the primary containment pressure and temperature monitoring system inoperable, restore the primary containment pressure and temperature monitoring system to OPERABLE status within 30 days. Note: All other Tech Spec Limiting Conditions For Operation and Surveillance Requirements associated with the primary containment pressure/temperature monitoring system sti)) apply. Affected Tech Spec Sections include: 3/4.3.7.5. 4.4.3.2.1. 3/4.6.1.6. and 3/4.6.1.7. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable AND the drywell unit coolers condensate flow rate monitoring system inoperable, restore the primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days OR restore the drywell unit coolers condensate flow rate monitoring system to OPERABLE status within 30 days. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours. LIMERICK - UNIT 2 3/4 4-8 Amendment No. J4, ~, ~, ~

ATTACHMENT 3 Markup of Technical Specifications Bases Pages (For Information Only) Limerick Generating Station Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3/4 4-3 B 3/4 4-3a B 3/4 4-3b ATTACHMENT 3 Markup of Technical Specifications Bases Pages (For Information Only) Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3/44-3 B 3/44-3a B 3/44-3b ATTACHMENT 3 Markup of Technical Specifications Bases Pages (For Information Only) Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3/44-3 B 3/44-3a B 3/44-3b

EAcroR COQ.LANF SYStEM 3/L43 REACtOR COOLANF 3/443 L.EAKAGEDETECTION SYSTEMS BACKGROUND [JESAR Sa1ety Design Bdsis (Ref. 1), requires medlis for detecting and, to the extent prdctical, identifying the location of the source of Reactor CooIint System (RCS) PRESSURE BOUN[)ARY LEAKAGE. Regulatory Guide 145 (Ref. 2) describes dcceptable methods for selecting eokaqe detection systems. Limits on ledkaqe from the reactor coolant pressure boundary (RCPB) are required so that approprHlte action can he taken before the integrity of the RCPB is impaired (Ref. 2). Leakage detection systems for the RCS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitative nt of leakage rates. Systems forsepara the leakage o identifid ourc from n unidntifid ourc (we necessary to provide prompt and quantitative information to the operators to permit them to take immediate corrective action. Leakage from the RCPB Inside the drywell is detected by at least one of four (4) independently monitored variables which include /N56p.:7i ktrywell drain sump )evel 4me yi&dinj d-roi fow rate idrywell gaseous radioactivity, drywell unit cooler condensate flow rate and drywell pressure/temperature levels. The primary means of quantifying leakage in the drywell t5 &#the drywell floor dra+/-m-ump lowonitoring system for UN[OENTIEIED LEAKAGE and the drywell equipment drain tank flow monitoring system for IDENTIFIED LEAKAGE. IDENTIFIED leakage is not germane to this Tech Spec and the associated drywell equipment drain tank flow monitoring system is not included. The drywell floor drain sump flow monitoring system monitors UNIDENTIFIED LEAKAGE collected in the floor drain sump. UNIDENTIFIED LEAKAGE consists of leakage from RCPB components inside the drywell which are not normally subject to leakage and otherwise routed to the drywell equipment drain sump, The primary containment floor drain sump has transmitters that supply level indication to the main control room via the plant monitoring system. [he floor drain sump level transmitters are associated with High/Low level switches that open/close the sump tank drain valves automatical ly. Ehe level instrument processing unit calculates an average leak rate (gpm) for a given measurement period which resets whenever the sump drain valve closes. The level processing unit provides an alarm to the main control room each time the average leak rate changes by a predetermined value since the last time the alarm was reset. For the drywell floor drain sump flow monitoring system, the setpoint basis is a 1 gpm change in IJNIDENTIFIED LEAKAGE. (N5EIZTZ - In addition to the drywell ROiJi dair/ump turonitoring systerTdescribed above, the discharge of each sump is monitored by an independent flow element. The measured flow rate from the flow element is integrated and recorded. A main control room alarm is also provided to indicate an excessive sump discharge rate measured via the flow element. This system, referred to as the drywell floor drain flow totalizer, is not credited for drywell floor drain sump flow monitoring system operability. LIMERICK UNIT 1 B 3/4 4-3 Amendment 44, i4, f<EACTOR COOLANT SYSTEM 3/4,4.3 REACTOR COOLANT SYSTEM LEAKAGE 3/4.4.3.1 LEAKAGE DETECTION SYSTEMS BACK(JROUND UFSAR Safety Design Basis (J{ef. 1), requires means for detecting and, to the extent practical, identifying the location of ttle source of Heactor Cootant System (ReS) PRESSURE BOUNDARY LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems. Limits on leakage from the reactor coolant pressure boundary (RePB) are required so that appropriate action can be taken before the integrity of the RepS is impaired (Ref. 2). Leakage detection systems for the ReS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitativ~ of leakage rates. ~f~"l1 Systems forl\\~ the leakage of aA identified sOblPce from Qn blnidQntifiQd iO'lrC~ are necessary to provide prompt and quantitative information to the operators to permit them to take immediate corrective action. Leakage from the RepS inside the drywell is ~ detected by at least one of four (4) independently monitored variables which include 1I'J$!<Ti :-*fPY'14CII draifl 5Uffl~ level eMdrt'de:3 ev~r time yield;n~ dr6;t flow 16te~ ~drywel J gaseous radioactivity, drywel1 unit cooler condensate flow rate and drywel1 pressure/temperaturelevels.TheP.rimarymeans of quantifying leakage in the drywell is J\\aJthe drywell floor drail't"9$ump ~on;toring system for UN[DENTIFIED LEAKAGE and the drywel I equipment drain tank flow monitoring system for IDENTIFIED LEAKAGE. IDENTIFIED leakage is not germane to this Tech Spec and the associated drywel I equipment drain tank flow monitoring system is not included. The drywell floor drain sump flow monitoring system monitors UNIDENTIFIED LEAKAGE cot lected in the floor drain sump. UNIDENTIFIED LEAKAGE consists of leakage from RCPB components inside the drywell which are not normally subject to leakage and otherwise routed to the drywell equipment drain sump. The primary containment floor drain sump has transmitters that supply level indication to the main control room via the plant monitoring system. fhe floor drain sump level transmitters are associated with High/Low level switches that open/close the sump tank drain valves automatically. The level instrument processing unit calculates an average leak rate (gpm) for a given measurement period which resets whenever the sump drain valve closes. The level processing unit provides an alarm to the main control room each time the average leak rate changes by a predetermined value since the last time the alarm was reset. For the drywell floor drain sump flow monitoring system, the setpoint basis is a 1 gpm change [§f3 in UNIDENTIFIED LEAKAGE. IN5E1<.T 2...., In add'; t i on to the drywe 1'1 ("loor draj,,'Sump ~oni tori ng sys terl\\\\descri bed above, the discharge of each sump is monitored by an independent flow element. The measured flow rate from the flow element is integrated and recorded. A main control room alarm is also provided to indicate an excessive sump discharge rate measured via the flow element. This system, referred to as the "drywell floor drain flow tota'lizer", is not credited for drywell floor drain sump flow monitoring system operabi lity. LIMERICK - UNIT 1 B 3/4 4-3 Amendment ~, ~, ~I f<EACTOR COOLANT SYSTEM 3/4,4.3 REACTOR COOLANT SYSTEM LEAKAGE 3/4.4.3.1 LEAKAGE DETECTION SYSTEMS BACK(JROUND UFSAR Safety Design Basis (J{ef. 1), requires means for detecting and, to the extent practical, identifying the location of ttle source of Heactor Cootant System (ReS) PRESSURE BOUNDARY LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems. Limits on leakage from the reactor coolant pressure boundary (RePB) are required so that appropriate action can be taken before the integrity of the RepS is impaired (Ref. 2). Leakage detection systems for the ReS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitativ~ of leakage rates. ~f~"l1 Systems forl\\~ the leakage of aA identified sOblPce from Qn blnidQntifiQd iO'lrC~ are necessary to provide prompt and quantitative information to the operators to permit them to take immediate corrective action. Leakage from the RepS inside the drywell is ~ detected by at least one of four (4) independently monitored variables which include 1I'J$!<Ti :-*fPY'14CII draifl 5Uffl~ level eMdrt'de:3 ev~r time yield;n~ dr6;t flow 16te~ ~drywel J gaseous radioactivity, drywel1 unit cooler condensate flow rate and drywel1 pressure/temperaturelevels.TheP.rimarymeans of quantifying leakage in the drywell is J\\aJthe drywell floor drail't"9$ump ~on;toring system for UN[DENTIFIED LEAKAGE and the drywel I equipment drain tank flow monitoring system for IDENTIFIED LEAKAGE. IDENTIFIED leakage is not germane to this Tech Spec and the associated drywel I equipment drain tank flow monitoring system is not included. The drywell floor drain sump flow monitoring system monitors UNIDENTIFIED LEAKAGE cot lected in the floor drain sump. UNIDENTIFIED LEAKAGE consists of leakage from RCPB components inside the drywell which are not normally subject to leakage and otherwise routed to the drywell equipment drain sump. The primary containment floor drain sump has transmitters that supply level indication to the main control room via the plant monitoring system. fhe floor drain sump level transmitters are associated with High/Low level switches that open/close the sump tank drain valves automatically. The level instrument processing unit calculates an average leak rate (gpm) for a given measurement period which resets whenever the sump drain valve closes. The level processing unit provides an alarm to the main control room each time the average leak rate changes by a predetermined value since the last time the alarm was reset. For the drywell floor drain sump flow monitoring system, the setpoint basis is a 1 gpm change [§f3 in UNIDENTIFIED LEAKAGE. IN5E1<.T 2...., In add'; t i on to the drywe 1'1 ("loor draj,,'Sump ~oni tori ng sys terl\\\\descri bed above, the discharge of each sump is monitored by an independent flow element. The measured flow rate from the flow element is integrated and recorded. A main control room alarm is also provided to indicate an excessive sump discharge rate measured via the flow element. This system, referred to as the "drywell floor drain flow tota'lizer", is not credited for drywell floor drain sump flow monitoring system operabi lity. LIMERICK - UNIT 1 B 3/4 4-3 Amendment ~, ~, ~I

REAC I OR 3/4 4.,JiIEAGrQR COOLAN 1SYS rELLLAKAGE 3J4L3 i IJAKAGE OEJECrJVlL 5Y5IEP1 OA(;K(:1ROuNj) U1:SAR SLitety Des I qn 3as s ( Ref 1 ) requl res means for deecti nq and, to the extent practi c I idcnti yi nq the 1 octi on ot the source of ke(ctor Coo 1 rint System ( RCS) PRESSURE BOUNDARY LEAKAGE. Regulatory Guide 1.4 (Ref.

2) describes acceptable methods for selecting Iekaqe detection systcms.

Limi ts on Ikdqe troin the rector coolant pressure boundary (RCPB) re required so that appropriate iction C]fl he taken before the integrity of the RCPB is impaired (Ref. 2). Lekge detection systems for the RCS (we provided to otert the operators when 1ekoqe rates hove normal b3ckqround levels ore detected and also to supply qudnti tdti ye ii nt of ledkaqe rctes. Systems leakage re necessary to provide prompt and quantitative information to the operators to permit them to take immedite corrective action. Leakage rrom the RCPB inside the drywell is detected by it least one of four (4) independently monitored variables whch include /N5ET yw&}-&r-ir-urnpFetet-ehnqe over time yi&c14nqdra-ftf-oi rates, drywell qaseous radioactivity, dryweli unit cooler condensate flow rate and drywell pressure/temperature levels. The primary means of quantifying leakage in the drywel I 5 .43ithe dryweli ordroirtump f-4-ewFnonitoring system for UNIDENTIFIED LEAKAGE and the drywel 1 equipment drain tank Iow monitoring system for IDENTIFIED LEAKAGE. IDENTIFIED leakoge is not germane to this Tech Spec and the associated drywell e(luiprnent drain tank flow moni turing system is not included. The drywel 1 floor drum sump flow monitoring system monitors UNIDENTIFIED LEAKAGE collected in the floor drain sump. UNIDENTIFIED LEAKAGE consists of leakage from RCPB components inside the drywell which are not normally subject to leakage and otherwise routed to the drywell equipment drain sump. Ihe primary containment floor drain sump has transmitters that supply level indication to the main control room via the plant monitoring system. The floor drain sump level transmitters are associated with High/Low level switches that open/close the surnp tank drain valves automatically. The level instrument processing unit calculates an average leak rate (gpm) for a given measurement period which resets whenever the sump drain valve closes. The level processing unit provides an alarm to the main control room each time the average leak rate changes by a predetermined value since the last time the alarm was reset. For the dryweli floor drain sump flow monitoring system, the setpoint basis is a 1 gpm change in UNIDENTIFIED LEAKAGE. addition to the drywell floor drsumpf+omonitoring system described above, the discharge of each sump is monitored by an independent flow element. The measured flow rate from the flow element is integrated and recorded. A main control room alarm is also provided to indicate an excessive sump discharge rate measured via the flow element. Fhis system, referred to as the drywell floor drain flow totalizer, is not credited for drywell floor drain sumo flow monitoring system operability. LIMERICK UNIT 2 B 3/4 4-3 Amendment 414, gE/\\c*rOB COOLANT SYS rEtl 3/1.4.3 REACTOR COOLANt sysrEM LEAKAGE 13ACKGRQUND UFSAR Safety Desiqn Basis (H(~f. 1), requires means for detecting and, to the extent practicdl. identifying the location of the source of Heactor Coolant System (HCS) PRESSURE BOUNDARY LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection sy terns. limits on t~~dkdqe from the reactor coolant prl~ssur'e boundary (RepS) are required so that appropriate action can be taken before the integrity of the RCPB is impaired (Ref. 2). Leakage detection systems for the ReS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply qUd nt ; t d t 'j ve n I~ ,:') r nt 0 f 1ed kaqera t es. 'f.lA."'l-tl' I Systems forA. the leakage of ,3M idel,t;f;~d source flnil' dn uJiidefiLlfred sourc~ are necessary to provide prompt and quantitative information to the operators to permit them to take immediate corrective action. Leakage from the RepS inside the drywell is detected by at least one of four (4) independently monitored variables wh'ch include drywell gaseous radioactivity, drywell unit cooler condensate flow rate and drywell pre ssure/ tempera t ur e )eve Is. The primary means of qua nt i fyingl eakage 1n the dr ywe 'II fViSi,,~he drywell ~Ioo,. (1raiFl"sump HWmonitoring system for UNIDENTIFIED LEAKAGE and ~ the drywel 1 equipment drain tank flow monitoring system for lDENTIFIED LEAKAGE. IDENTIFIED leakage is not germane to this Tech Spec and the associated drywell t~qU'j Prnen t dr ain t dnk fl ow monit 0 r 'j n9 sYst emi s noti nc1uded. The drywell floor drain sump flow monitoring system monitors UNIDENTIFIED LEAKAGE collected in the floor drain sump. UNIDENTIFIED LEAKAGE consists of leakage from RCPS components inside the drywell which are not normally subject to leakage and otherwise routed to the drywell equipment drain sump. fhe primary containment floor drain sump has transmitters that supply level indication to the main control room via the plant monitoring system. The floor drain sump level transmitters are associated with High/Low level switches that open/close the sump tank drain valves automatically. The leve) instrument processing unit calculates an average leak rate (gpm) for a given measurement period which resets whenever the sump drain valve closes. The level processing unit provides an alarm to the main control room each time the average leak rate changes by a predetermined value since the last time the alarm was reset. For the drywell floor drain sump flow monitoring system, the setpoint basis is a 1 gpm change in UNIDENTIFIED LEAKAGE. ~~ addition to the drywell Floci dl ~;n"sump ~monitoring system described above, the discharge of each sump is monitored by an independent flow element. The measured flow rate from the flow element is integrated and recorded. A main control room alarm is also provided to indicate an excessive sump discharge rate measured via the flow e1ement. rh; s syst em ~ referredt 0 as the "drywell fl 00r drai n flow totali zer", i s not credited for drywel1 floor drain sump flow monitoring system operability. LIMERICK - UNIT 2 B 3/4 4-3 Amendment -14, ~ gE/\\c*rOB COOLANT SYS rEtl 3/1.4.3 REACTOR COOLANt sysrEM LEAKAGE 13ACKGRQUND UFSAR Safety Desiqn Basis (H(~f. 1), requires means for detecting and, to the extent practicdl. identifying the location of the source of Heactor Coolant System (HCS) PRESSURE BOUNDARY LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection sy terns. limits on t~~dkdqe from the reactor coolant prl~ssur'e boundary (RepS) are required so that appropriate action can be taken before the integrity of the RCPB is impaired (Ref. 2). Leakage detection systems for the ReS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply qUd nt ; t d t 'j ve n I~ ,:') r nt 0 f 1ed kaqera t es. 'f.lA."'l-tl' I Systems forA. the leakage of ,3M idel,t;f;~d source flnil' dn uJiidefiLlfred sourc~ are necessary to provide prompt and quantitative information to the operators to permit them to take immediate corrective action. Leakage from the RepS inside the drywell is detected by at least one of four (4) independently monitored variables wh'ch include drywell gaseous radioactivity, drywell unit cooler condensate flow rate and drywell pre ssure/ tempera t ur e )eve Is. The primary means of qua nt i fyingl eakage 1n the dr ywe 'II fViSi,,~he drywell ~Ioo,. (1raiFl"sump HWmonitoring system for UNIDENTIFIED LEAKAGE and ~ the drywel 1 equipment drain tank flow monitoring system for lDENTIFIED LEAKAGE. IDENTIFIED leakage is not germane to this Tech Spec and the associated drywell t~qU'j Prnen t dr ain t dnk fl ow monit 0 r 'j n9 sYst emi s noti nc1uded. The drywell floor drain sump flow monitoring system monitors UNIDENTIFIED LEAKAGE collected in the floor drain sump. UNIDENTIFIED LEAKAGE consists of leakage from RCPS components inside the drywell which are not normally subject to leakage and otherwise routed to the drywell equipment drain sump. fhe primary containment floor drain sump has transmitters that supply level indication to the main control room via the plant monitoring system. The floor drain sump level transmitters are associated with High/Low level switches that open/close the sump tank drain valves automatically. The leve) instrument processing unit calculates an average leak rate (gpm) for a given measurement period which resets whenever the sump drain valve closes. The level processing unit provides an alarm to the main control room each time the average leak rate changes by a predetermined value since the last time the alarm was reset. For the drywell floor drain sump flow monitoring system, the setpoint basis is a 1 gpm change in UNIDENTIFIED LEAKAGE. ~~ addition to the drywell Floci dl ~;n"sump ~monitoring system described above, the discharge of each sump is monitored by an independent flow element. The measured flow rate from the flow element is integrated and recorded. A main control room alarm is also provided to indicate an excessive sump discharge rate measured via the flow e1ement. rh; s syst em ~ referredt 0 as the "drywell fl 00r drai n flow totali zer", i s not credited for drywel1 floor drain sump flow monitoring system operability. LIMERICK - UNIT 2 B 3/4 4-3 Amendment -14, ~

Insert 1 drywell sump flow monitoring equipment with the required RCS leakage detection instrumentation (i.e., the drywell floor drain sump flow monitoring system, or, the drywell equipment drain sump monitoring system with the drywell floor drain sump overflowing to the drywell equipment drain sump), Insert 2 An alternate to the drywell floor drain sump flow monitoring system for quantifying UNIDENTIFIED LEAKAGE is the drywell equipment drain sump monitoring system, if the drywell floor drain sump is overflowing to the drywell equipment drain sump. In this configuration, the drywell equipment drain sump collects all leakage into the drywell equipment drain sump and the overflow from the drywell floor drain sump. Therefore, if the drywell floor drain sump is overflowing to the drywell equipment drain sump, the drywell equipment drain sump monitoring system can be used to quantify UNIDENTIFIED LEAKAGE. In this condition, all leakage measured by the drywell equipment drain sump monitoring system is assumed to be UNIDENTIFIED LEAKAGE. The leakage determination process, including the transition to and use of the alternate method is described in station procedures. The alternate method would only be used when the drywell floor drain sump flow monitoring system is unavailable. Insert 1 drywell sump flow monitoring equipment with the required ReS leakage detection instrumentation (Le., the drywell floor drain sump flow monitoring system, or, the drywell equipment drain sump monitoring system with the drywell floor drain sump overflowing to the drywell equipment drain sump), Insert 2 An alternate to the drywell floor drain sump flow monitoring system for quantifying UNIDENTIFIED LEAKAGE is the drywell equipment drain sump monitoring system, if the drywell floor drain sump is overflowing to the drywell equipment drain sump. In this configuration, the drywell equipment drain sump collects all leakage into the drywell equipment drain sump and the overflow from the drywell floor drain sump. Therefore, if the drywell floor drain sump is overflowing to the drywell equipment drain sump, the drywell equipment drain sump monitoring system can be used to quantify UNIDENTIFIED LEAKAGE. In this condition, all leakage measured by the drywell equipment drain sump monitoring system is assumed to be UNIDENTIFIED LEAKAGE. The leakage determination process, including the transition to and use of the alternate method is described in station procedures. The alternate method would only be used when the drywell floor drain sump flow monitoring system is unavailable. Insert 1 drywell sump flow monitoring equipment with the required ReS leakage detection instrumentation (Le., the drywell floor drain sump flow monitoring system, or, the drywell equipment drain sump monitoring system with the drywell floor drain sump overflowing to the drywell equipment drain sump), Insert 2 An alternate to the drywell floor drain sump flow monitoring system for quantifying UNIDENTIFIED LEAKAGE is the drywell equipment drain sump monitoring system, if the drywell floor drain sump is overflowing to the drywell equipment drain sump. In this configuration, the drywell equipment drain sump collects all leakage into the drywell equipment drain sump and the overflow from the drywell floor drain sump. Therefore, if the drywell floor drain sump is overflowing to the drywell equipment drain sump, the drywell equipment drain sump monitoring system can be used to quantify UNIDENTIFIED LEAKAGE. In this condition, all leakage measured by the drywell equipment drain sump monitoring system is assumed to be UNIDENTIFIED LEAKAGE. The leakage determination process, including the transition to and use of the alternate method is described in station procedures. The alternate method would only be used when the drywell floor drain sump flow monitoring system is unavailable.

fEACTOR COOLANT SYSFEM BACKGROUND (Continuedi The primary containment atmospheric gaseous radioactivity monitoring system continuously monitors the primary containment atmosphere for gaseous radioactivity levels. A sudden increase of radioactivity, which may be attributed to RCPB steam or reactor water leakage, is annunciated in the main control room. The primary containment atmospheric gaseous radioactivity monitoring system is not capable of quantifying leakage rates, but is sensitive enough to detect increased leakage rates of 1 gpm within 1 hour. Larger changes in leakage rates are detected in proportionally shorter times (Ref. 4). Condensate from the eight drywell air coolers is routed to the drywell floor drain sump and is monitored by a series of flow transmitters that provide indication and alarms in the main control room. The outputs from the flow transmitters are added together by summing units to provide a total continuous condensate drain flow rate. The high flow alarm setpoint is based on condensate drain flow rate in excess of 1 gpm over the currently identified preset leak rate. The drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of RCS UNIDENTIFIED LEAKAGE (Ref. 5). The dryweil temperature and pressure monitoring system provide an indirect method for detecting RCPB ieakge. A temperature and/or pressure rise in the drywell above normal levels may be indicative of a reactor coolant or steam leakage (Ref. 6). APPLICABLE SAFETY ANALYSES A threat of significant compromise to the RCPB exists if the barrier contains a crack that is large enough to propagate rapidly. Leakage rate limits are set low enough to detect the leakage emitted from a single crack in the RCPB (Refs. 7 and 8). Each of the leakage detection systems inside the drywell is designed with the capability of detecting leakage less than the established leakage rate limits and providing appropriate alarms of excess leakage in the control room. A control room alarm allows the operators to evaluate the significance of the indicated leakage and, if necessary, shut down the reactor for further investigation and corrective action. The allowed leakage rates are well below the rates predicted for critical crack sizes (Ref. 8). Therefore, these actions provide adequate responses before a significant break in the RCPB can occur. RCS leakage detection instrumentation satisfies (Criterion 1 of the NRC Policy Statement. LIMITING CONDITION FOR OPERATION (LCD) T-e-drywell fl-r drpin sunip flow monitoring system is regtrFred to quantify the- -UN-IDEN-IIFIED LLAI(AGL from the RCS The other monitoring systems provide early alarms to the operator so closer examination of other detection systems will be made to determine the extent of any corrective action that my be required. With any leakage detection system inoperable, monitoring for leakage in the RCPB is degraded. LIMERICK UNIT I B 3/ 4 4-3a Amendment REACTOR COOLANT SYSTEM BACKGROUND (Continued) The primary containment atmospheric gaseous radioactivity monitoring system continuously monitors the primary containment atmosphere for gaseous radioactivity levels. A sudden increase of radioactivity, which may be attributed to RCPB steam or reactor water leakage, is annunciated in the main control room. The primary containment atmospheric gaseous radioactivity monitoring system is not capable of quantifying leakage rates, but is sensitive enough to detect increased leakage rates of 1 gpm within 1 hour. Larger changes in leakage rates are detected in proportionally shorter times (Ref. 4). Condensate from the eight drywell air coolers is routed to the drywell floor drain sump and is monitored by a series of flow transmitters that provide indication and alarms in the main control room. The outputs from the flow transmitters are added together by summing units to provide a total continuous condensate drain flow rate. The high flow alarm setpoint is based on condensate drain flow rate in excess of 1 gpm over the currently identified preset leak rate. The drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of RCS UNIDENTIFIED LEAKAGE (Ref. 5). The drywe'll temperature and pressure monitoring system provide an indirect method for detecting RepS "Ieakge. A temperature and/or pressure rise in the drywell above normal levels may be indicative of a reactor coolant or steam leakage (Ref. 6). APPLICABLE SAFETY ANALYSES A threat of significant compromise to the RCPS exists if the barrier contains a crack that is large enough to propagate rapidly. Leakage rate limits are set low enough to detect the leakage emitted from a single crack in the RCPB (Refs. 7 and 8). Each of the leakage detection systems inside the drywell is designed with the capability of detecting leakage less than the established leakage rate limits and providing appropriate alarms of excess leakage in the control room. A control room alarm allows the operators to evaluate the significance of the indicated leakage and, if necessary, shut down the reactor for further investigation and corrective action. The allowed leakage rates are well below the rates predicted for critical crack sizes (Ref. 8). Therefore, these actions provide adequate responses before a significant break in the RCPS can occur. RCS leakage detection instrumentation satisfies (Criterion 1 of the NRC Policy Statement. LIMITING CONDITION FOR OPERATIQ~ (LCO) ~11 rhe dlywell flC~t dl ~in ~ump flow mo"itol*il,g 3Y3tem 15 I equireei to qual9tifythe"...J2-bJN I DE~rT IFI ED LEAKAGE from the RCS-!- The other mon; tori ng systems provi de ea rl y a1arms to the operator so closer examination of other detection systems will be made to determine the extent of any corrective action that my be required. With any leakage detection system inoperable, monitoring for leakage in the RepS is degraded. LIMERICK - UNIT 1 B 3/ 4 4-3a Amendment M1fI REACTOR COOLANT SYSTEM BACKGROUND (Continued) The primary containment atmospheric gaseous radioactivity monitoring system continuously monitors the primary containment atmosphere for gaseous radioactivity levels. A sudden increase of radioactivity, which may be attributed to RCPB steam or reactor water leakage, is annunciated in the main control room. The primary containment atmospheric gaseous radioactivity monitoring system is not capable of quantifying leakage rates, but is sensitive enough to detect increased leakage rates of 1 gpm within 1 hour. Larger changes in leakage rates are detected in proportionally shorter times (Ref. 4). Condensate from the eight drywell air coolers is routed to the drywell floor drain sump and is monitored by a series of flow transmitters that provide indication and alarms in the main control room. The outputs from the flow transmitters are added together by summing units to provide a total continuous condensate drain flow rate. The high flow alarm setpoint is based on condensate drain flow rate in excess of 1 gpm over the currently identified preset leak rate. The drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of RCS UNIDENTIFIED LEAKAGE (Ref. 5). The drywe'll temperature and pressure monitoring system provide an indirect method for detecting RepS "Ieakge. A temperature and/or pressure rise in the drywell above normal levels may be indicative of a reactor coolant or steam leakage (Ref. 6). APPLICABLE SAFETY ANALYSES A threat of significant compromise to the RCPS exists if the barrier contains a crack that is large enough to propagate rapidly. Leakage rate limits are set low enough to detect the leakage emitted from a single crack in the RCPB (Refs. 7 and 8). Each of the leakage detection systems inside the drywell is designed with the capability of detecting leakage less than the established leakage rate limits and providing appropriate alarms of excess leakage in the control room. A control room alarm allows the operators to evaluate the significance of the indicated leakage and, if necessary, shut down the reactor for further investigation and corrective action. The allowed leakage rates are well below the rates predicted for critical crack sizes (Ref. 8). Therefore, these actions provide adequate responses before a significant break in the RCPS can occur. RCS leakage detection instrumentation satisfies (Criterion 1 of the NRC Policy Statement. LIMITING CONDITION FOR OPERATIQ~ (LCO) ~11 rhe dlywell flC~t dl ~in ~ump flow mo"itol*il,g 3Y3tem 15 I equireei to qual9tifythe"...J2-bJN I DE~rT IFI ED LEAKAGE from the RCS-!- The other mon; tori ng systems provi de ea rl y a1arms to the operator so closer examination of other detection systems will be made to determine the extent of any corrective action that my be required. With any leakage detection system inoperable, monitoring for leakage in the RepS is degraded. LIMERICK - UNIT 1 B 3/ 4 4-3a Amendment M1fI

13ASLS .aAC.K ...&ROUND ( Gon.t nued). The primary containment atmospheric gaseous radioactivity moni toring system continuously monitors the primary containment atmosphere for qaseous radioactivity levels. A sudden increase of radioactivity, which may be attributed to RCPB steam or reactor water leakage, is annunciated in the main control room. The primary containment atmospheric gaseous radioactivity monitoring system is not capable of quantifying leakage rates, but is sensitive enough to detect increased leakage rates of 1 gpm within 1 hour. Larger changes in leakage rates are detected in proportionally shorter times (Ref. 4). Condensate from the eight dryweil air coolers is routed to the drywell floor drain sump and is monitored by a series of flow transmitters that provide indication and alarms in the main control room. The outputs from the flow transmitters are added together by summing units to provide a total continuous condensate drain flow rate. The high flow alarm setpoint is based on condensate drain flow rate in excess of 1 gpm over the currently identified preset leak rate. The drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of RCS UNIDENTIFIED LEAKAGE (Ref. 5). The drywell temperature and pressure monitoring systems provide an indirect method for detecting RCPB leakage. A temperature and/or pressure rise in the dryweil above normal levels may be indicative of a reactor coolant or steam leakage (Ref. 6). APPLICABLE SAFETY ANALYSES A threat of significant compromise to the RCPB exists if the barrier contains a crack that is large enough to propagate rapidly. Leakage rate limits are set low enough to detect the leakage emitted from a single crack in the RCPB (Refs. 7 and 8). Each of the leakage detection systems inside the drywell is designed with the capability of detecting leakage less than the established leakage rate limits and providing appropriate alarms of excess leakage in the control room. A control room alarm allow the operators to evaluate the significance of the indicated leakage and, if necessary, shut down the reactor for further investigation and corrective action. The allowed leakage rates are well below the rates predicted for critical crack sizes (Ref. 8). Therefore, these actions provide adequate response before a significant break in the RCPB can occur. RCS leakage detection instrumentation satisfies Criterion 1 of the NRC Policy Statement. LIMITING CONDITION FOR OPERATION (LCO) /NST 3 T4edrywcl1floordrainsurnp fow montormngsys i.3 required to-guantifyth U-N4-DLN-TIFIL LEAKAGE Furii tti RC. The other monitoring systems provide early alarms to the operators so closer examination of other detection systems will be made to determine the extent of any corrective action that may be required. With any leakage detection system inoperable, monitoring for leakage in the RCPB is degraded. LIMERICK UNIT 2 B 3/4 4-3a Amendment BACKGROUND (Continued) The primary containment a ic gaseous radioactivity monitoring system continuously monitors the primary containment atmosphere for gaseous radioactivity levels. A sudden increase of radioactivity, which may be attributed to RCPS steam or reactor water leakage, is annunciated in the main control room. The primary containment atmospheric gaseous radioactivity monitoring system is not capable of quantifying leakage rates, but is sensitive enough to detect increased leakage rates of 1 gpm within 1 hour. Larger changes in leakage rates are detected in proportionally shorter times (I~ef. '1.). Condensate from the eight drywell air coolers is routed to the drywell floor drain sump and ;s monitored by a series of flow transmitters that provide indication and alarms in the main control room. Trle outputs from trle flow transmitter's are added together by summing units to provide a total continuous condensate drain flow rate. The high flow alarm setpoint is based on condensate drain flow rate in excess of 1 gpm over the currently identified preset leak rate. The drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of ReS UNIDENTIFIED LEAKAGE (Ref. 5). The drywell temperature and pressure monitoring systems provide an indirect method for detecting RepS leakage. A temperature and/or pressure rise in the drywell above normal levels may be indicative of a reactor coolant or steam leakage (Ref. 6). APPLICABLE SAFETY ANALYSES A threat of significant compromise to the RePB exists if the barrier contains a crack that is large enough to propagate rapidly. Leakage rate limits are set low enough to detect the leakage emitted from a single crack in the RePB (Refs. 7 and 8). Each of the leakage detection systems inside the drywell is designed with the capability of detecting leakage less than the established leakage rate limits and providing appropriate alarms of excess leakage in the control room. A control room alarm allow the operators to evaluate the significance of the indicated leakage and, if necessary, shut down the reactor for further investigation and corrective action. The allowed leakage rates are well below the rates predicted for critical crack sizes (Ref. 8). Therefore, these actions provide adequate response before a significant break in the RePB can occur. Res leakage detection instrumentation satisfies Criterion 1 of the NRC Policy Statement. ~~:I::::e~~N::~::Nd:~~n O::::T~~:\\~(~::~t~~ui red to quantif1 th~ I:JNIDENTIFIED LEAKAGE fro,,, Llle RC~~ The other monitoring systems provide early alarms to the operators so closer examination of other detection systems will be made to determine the extent of any corrective action that may be required. With any leakage detection system inoperable, monitoring for leakage in the RepS is degraded. LIMERICK - UNIT 2 B 3/4 4-3a Amendment ~ BACKGROUND (Continued) The primary containment a ic gaseous radioactivity monitoring system continuously monitors the primary containment atmosphere for gaseous radioactivity levels. A sudden increase of radioactivity, which may be attributed to RCPS steam or reactor water leakage, is annunciated in the main control room. The primary containment atmospheric gaseous radioactivity monitoring system is not capable of quantifying leakage rates, but is sensitive enough to detect increased leakage rates of 1 gpm within 1 hour. Larger changes in leakage rates are detected in proportionally shorter times (I~ef. '1.). Condensate from the eight drywell air coolers is routed to the drywell floor drain sump and ;s monitored by a series of flow transmitters that provide indication and alarms in the main control room. Trle outputs from trle flow transmitter's are added together by summing units to provide a total continuous condensate drain flow rate. The high flow alarm setpoint is based on condensate drain flow rate in excess of 1 gpm over the currently identified preset leak rate. The drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of ReS UNIDENTIFIED LEAKAGE (Ref. 5). The drywell temperature and pressure monitoring systems provide an indirect method for detecting RepS leakage. A temperature and/or pressure rise in the drywell above normal levels may be indicative of a reactor coolant or steam leakage (Ref. 6). APPLICABLE SAFETY ANALYSES A threat of significant compromise to the RePB exists if the barrier contains a crack that is large enough to propagate rapidly. Leakage rate limits are set low enough to detect the leakage emitted from a single crack in the RePB (Refs. 7 and 8). Each of the leakage detection systems inside the drywell is designed with the capability of detecting leakage less than the established leakage rate limits and providing appropriate alarms of excess leakage in the control room. A control room alarm allow the operators to evaluate the significance of the indicated leakage and, if necessary, shut down the reactor for further investigation and corrective action. The allowed leakage rates are well below the rates predicted for critical crack sizes (Ref. 8). Therefore, these actions provide adequate response before a significant break in the RePB can occur. Res leakage detection instrumentation satisfies Criterion 1 of the NRC Policy Statement. ~~:I::::e~~N::~::Nd:~~n O::::T~~:\\~(~::~t~~ui red to quantif1 th~ I:JNIDENTIFIED LEAKAGE fro,,, Llle RC~~ The other monitoring systems provide early alarms to the operators so closer examination of other detection systems will be made to determine the extent of any corrective action that may be required. With any leakage detection system inoperable, monitoring for leakage in the RepS is degraded. LIMERICK - UNIT 2 B 3/4 4-3a Amendment ~

Insert 3 The required instrumentation to quantify UNIDENTIFIED LEAKAGE from the RCS consists of either the drywell floor drain sump flow monitoring system, or, the drywell equipment drain sump monitoring system with the drywell floor drain sump overflowing to the drywell equipment drain sump. For either system to be considered operable, the flow monitoring portion of the system must be operable. Insert 3 The required instrumentation to quantify UNIDENTIFIED LEAKAGE from the ReS consists of either the drywell floor drain sump flow monitoring system, or, the drywell equipment drain sump monitoring system with the drywell floor drain sump overflowing to the drywell equipment drain sump. For either system to be considered operable, the flow monitoring portion of the system must be operable. Insert 3 The required instrumentation to quantify UNIDENTIFIED LEAKAGE from the ReS consists of either the drywell floor drain sump flow monitoring system, or, the drywell equipment drain sump monitoring system with the drywell floor drain sump overflowing to the drywell equipment drain sump. For either system to be considered operable, the flow monitoring portion of the system must be operable.

PLA(; [OR (;OOLAN F SYS EM A P P L [ CAB I L I 1 V I n oPERA F I ONAL (::OND I E IONS I 2 rid : I eCik(qe (1(tC t 011 SYS terns 1 re requi r(j tø h OPERABLE to support LEO 34.3. [his Ippi icibi lity consistent with thdt Eor LEO .3 . 4 . 3 ACEION A. With Ehe primary containment atmosphere (j(seous monitoring system inoperable, grab dITIpI S at Lh(? prriary COfltai nment atmosphere must be taken and aria lyzed to provide pen odi C I((]kage i nformati on. [Provided a sample i s obtal ned arid ana lyzed once every 12 hours, the plant may he operated for up to 30 (jays to allow restoration oE the radioactivit.y monitoring system. rhe plant may continue operation since other forms at-drywel I leakage detection are avai lable.] Flie 12 hour interval provides periodic information that i s adequate to detect leakage. rhe 30 day Completion rifle for Restoration recognizes other ftrms of leakage d I e available. IN5t?, I B. With the oor--df-umpf1owmonitoringsystminoperabie, no other form of sampling can provide the equivalent information to quantify leakage at the required 1 gpm/hour sensitivity.

However, the primary containment atmospheric gaseous monitor [and the primary containment air cooler condensate flow rate monitor] wil rovide indication of changes in leakage.

,NSE7zTS With : e* r we-fToordai-n ttmpfiow monitorin ys-teWinoperable, drywell condensate flow rate monitoring frequency increased from 12 to every 8 hours, and UNIDENTIFIED LEAKAGE and total leakage being determined every 8 hours (Ref. SR 4.43.2.l.h) operation may continue for 30 days. To the extent practical, the surveillance Frequency change associated with the drywell condensate flow rate monitoring system, makes up for the loss of the drywell Floor drain monitoring system which had a normal surveillance requirement to monitor leakage every 8 hours. Also note that in this instance, the drywell floor drain tank flow totalizer will be used to comply with SR 4.4.3.2.1.b. The 30 day Completion Time oF the required ACTION is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available. LIMERICK UNIT 1 B 3/4 4-3b Amendment, l~.EACr0Reo0LAN r sys rEM I\\PPLlC;\\B[Llry [n () PEH1\\ r[0NALe0NDI T[()NS 1, 2, () nd 3, led kdqe c1etee t i (]n sy st ems () rerequi re(j to be OPERABLE to support LCD 3.4.3.2. fhis applicabi lity is consistent with that for LCO

).4.3.2.

ACTION A. With the primary containment atmosphere qaseous monitoring system inoperable, lJrdb ~;drnp I es of the pri rna fy conta i nmen t dtmosptlere rnus t be ta ken dnd dnd 1yled to prov i de periodic leakage information. [Provided a sample is obtained dnd analyzed once every 12 ~10urs f trle pIant may be operated for up to 30 days to d11 ow restorat i on of the radioactivity monitoring system. rhe plant may continue operation since other forms of dr ywe I 11 t~ d kage detection are ava i 1ab1e* ] form B. rhe 12 hour interval provides periodic information that is adequate to detect leakage. fhe 30 day Completion Time for Restoration recognizes other forms of leakaqe ~~available. With the~ drill" 5ump Flow rnonitci ;l1g "ystem-'inoperable. no other of sampling can provide the equivalent information to quantify leakage at the required 1 gpm/hour sensitivity. However, the primary containment atmospheric gaseous monitor [and the primary containment air cooler condensate flow rate monitor] wil rovide indication of changes in leakage. ,NSer<TS With inoperable, drywell condensate flow rate monitoring frequency increased from 12 to every 8 hours, and UNIDENTIFIED LEAKAGE and total leakage being determined every 8 hours (Ref. SR 4.4.3.2.1.b) operation may continue for 30 days. To the extent practical, the surveillance frequency change associated with the drywell condensate flow rate monitoring system, makes up for the loss of the drywell floor drain monitoring system which had a normal surveillance requirement to monitor leakage every 8 hours. Also note that in this instance, the drywell floor drain tank flow totalizer will be used to comply with SR 4.4.3.2.1.b. fhe 30 day Completion Time of the required ACTION is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available. LIMERICK - UNIT 1 B 3/4 4-3b Amendment ~, ~ l~.EACr0Reo0LAN r sys rEM I\\PPLlC;\\B[Llry [n () PEH1\\ r[0NALe0NDI T[()NS 1, 2, () nd 3, led kdqe c1etee t i (]n sy st ems () rerequi re(j to be OPERABLE to support LCD 3.4.3.2. fhis applicabi lity is consistent with that for LCO

).4.3.2.

ACTION A. With the primary containment atmosphere qaseous monitoring system inoperable, lJrdb ~;drnp I es of the pri rna fy conta i nmen t dtmosptlere rnus t be ta ken dnd dnd 1yled to prov i de periodic leakage information. [Provided a sample is obtained dnd analyzed once every 12 ~10urs f trle pIant may be operated for up to 30 days to d11 ow restorat i on of the radioactivity monitoring system. rhe plant may continue operation since other forms of dr ywe I 11 t~ d kage detection are ava i 1ab1e* ] form B. rhe 12 hour interval provides periodic information that is adequate to detect leakage. fhe 30 day Completion Time for Restoration recognizes other forms of leakaqe ~~available. With the~ drill" 5ump Flow rnonitci ;l1g "ystem-'inoperable. no other of sampling can provide the equivalent information to quantify leakage at the required 1 gpm/hour sensitivity. However, the primary containment atmospheric gaseous monitor [and the primary containment air cooler condensate flow rate monitor] wil rovide indication of changes in leakage. ,NSer<TS With inoperable, drywell condensate flow rate monitoring frequency increased from 12 to every 8 hours, and UNIDENTIFIED LEAKAGE and total leakage being determined every 8 hours (Ref. SR 4.4.3.2.1.b) operation may continue for 30 days. To the extent practical, the surveillance frequency change associated with the drywell condensate flow rate monitoring system, makes up for the loss of the drywell floor drain monitoring system which had a normal surveillance requirement to monitor leakage every 8 hours. Also note that in this instance, the drywell floor drain tank flow totalizer will be used to comply with SR 4.4.3.2.1.b. fhe 30 day Completion Time of the required ACTION is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available. LIMERICK - UNIT 1 B 3/4 4-3b Amendment ~, ~

REACTOR COOLANLSXSJLM &.___== --=

=====_ -* --= iPPLICAt3I LITY. In OPERATIONAL CONDitONS 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO :3.4.3.2. This applicability is consistent with that for LCO 3.4.3.2. _cIi OiS A. With the primary containment atmosphere gaseous monitoring system inoperable, grab samples of the primary containment atmosphere must he taken and analyzed to provide periodic leakage information. [Provided a sample is obtained and analyzed once every 12 hours, the plant may be operated for up to 30 days to allow restoration of the radioactivity monitoring system. The plant may continue operation since other forms of dryweil leakage detection are available.] The 12 hours interval provides periodic information that is adequate to detect leakage. the 30 day Completion Time for Restoration recognizes other forms of leak e n are available. (t%lsErrj 13.

With,

• r*

Floor drainumpfow monitoiing ysteWinoperable, no other form of sampling can provide the equivalent information to quantify leakage at the required 1 gpm/hour sensitivity. However, the primary containment atmospheric gaseous monitor [and the primary containment air cooler condensate flow rate monitor] will rovide indication of changes in leakage. /NSr5 4; WithA floor 4rai-n-surnflow rnon4toning systeiwinoperable, drywell condensate flow rate monitoring frequency increased from 12 to every 8 hours, and UNIDENTIFIED LEAKAGE and total leakage being determined every 8 hours (Ref: SR 4.4.3.2.1.b) operation may continue for 30 days. To the extent practical , the surveillance frequency change associated with the drywell condensate flow rate monitoring system, makes up for the loss of the drywell floor drain sump monitoring system which had a normal surveillance requirement to monitor leakage every 8 hours. Also note that in this instance, the drywell floor drain tank flow totalizer will be used to comply with SR 4.4.3.2.1.b. The 30 day Completion Time of the required ACTION is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available. LIMERICK UNIT 2 B 3/4 4-3b Amendment 4-Q, ~PPLICABILITY In OPERATIONAL CONDITIONS 1, 2, and 3, leakage detection systems are required to be OPERABLE to upport LCO 3.4.3.2. This applicability is consistent with that for LCO 3.4.3.2. A. 8. With the primary containment atmosphere gaseous monitoring system inoperable, grab samples of the primary containment atmosphere must be taken and analyzed to provide periodic leakage information. [Provided a sample is obtained and analyzed once every 12 hours, the plant may be operated for up to 30 days to allow restoration of the radioactivity monitoring system. The plant may continue operation since other forms of drywell leakage detection are available.] The 12 hours interval provides periodic information that is adequate to detect leakage. fhe 30 day Completion Time for Restoration recognizes other forms of leak~ are available. (N$~T4 WithA~fl OCI dtfl f1; 1'1 ~UfflP fl O~4 !ftOfll te-ri ng systeR1i noperabl e, no other form of sampling can provide the equivalent information to quantify leakage at the required 1 gpm/hour sensitivity. However, the primary containment atmospheric gaseous monitor [and the primary containment air cooler condensate flow rate moni~ide indication of changes in leakage. INSE1<T 5 Withl\\~loor drain SUFAJ3 flo'iJ Iflonitoring systeH1inoperable, drywell condensate flow rate monitoring frequency increased from 12 to every 8 hours, and UNIDENTIFIED LEAKAGE and total leakage being determined every 8 hours (Ref: SR 4.4.3.2.1.b) operation may continue for 30 days. To the extent practical, the surveillance frequency change associated with the drywell condensate flow rate monitoring system, makes up for the loss of the drywell floor drain sump monitoring system which had a normal surveillance requirement to monitor leakage every 8 hours. Also note that in this instance, the drywell floor drain tank flow totalizer will be used to comply with SR 4.4.3.2.1.b. The 30 day Completion Time of the required ACTION is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available. LIMERICK - UNIT 2 B 3/4 4-3b Amendment ~, ~ ~PPLICABILITY In OPERATIONAL CONDITIONS 1, 2, and 3, leakage detection systems are required to be OPERABLE to upport LCO 3.4.3.2. This applicability is consistent with that for LCO 3.4.3.2. A. 8. With the primary containment atmosphere gaseous monitoring system inoperable, grab samples of the primary containment atmosphere must be taken and analyzed to provide periodic leakage information. [Provided a sample is obtained and analyzed once every 12 hours, the plant may be operated for up to 30 days to allow restoration of the radioactivity monitoring system. The plant may continue operation since other forms of drywell leakage detection are available.] The 12 hours interval provides periodic information that is adequate to detect leakage. fhe 30 day Completion Time for Restoration recognizes other forms of leak~ are available. (N$~T4 WithA~fl OCI dtfl f1; 1'1 ~UfflP fl O~4 !ftOfll te-ri ng systeR1i noperabl e, no other form of sampling can provide the equivalent information to quantify leakage at the required 1 gpm/hour sensitivity. However, the primary containment atmospheric gaseous monitor [and the primary containment air cooler condensate flow rate moni~ide indication of changes in leakage. INSE1<T 5 Withl\\~loor drain SUFAJ3 flo'iJ Iflonitoring systeH1inoperable, drywell condensate flow rate monitoring frequency increased from 12 to every 8 hours, and UNIDENTIFIED LEAKAGE and total leakage being determined every 8 hours (Ref: SR 4.4.3.2.1.b) operation may continue for 30 days. To the extent practical, the surveillance frequency change associated with the drywell condensate flow rate monitoring system, makes up for the loss of the drywell floor drain sump monitoring system which had a normal surveillance requirement to monitor leakage every 8 hours. Also note that in this instance, the drywell floor drain tank flow totalizer will be used to comply with SR 4.4.3.2.1.b. The 30 day Completion Time of the required ACTION is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available. LIMERICK - UNIT 2 B 3/4 4-3b Amendment ~, ~

Insert4 required drywell sump monitoring system Insert 5 required drywell sump monitoring system Insert 4 required drywell sump monitoring system Insert 5 required drywell sump monitoring system Insert 4 required drywell sump monitoring system Insert 5 required drywell sump monitoring system

-n 0) C) Cm 000 0 -4 Cl) 3 m 0+/-

z 3m z-oc 71 CDCI) za. 0I) -p CD Cl ATTACHMENT 4 List of Commitments Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 ATTACHMENT 4 List of Commitments Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85

The following table identifies those actions committed to by EGC for Limerick Generating Station (LGS), Units 1 and 2 as part of the License Amendment Request Any other statements in this submittal are provided for information purposes and are not regulatory commitments. Commitment Commitment Commitment Number Date One-Time Programmatic Action (Yes/No) (Yes/No) CM-i EGC will verify through Prior to initial Yes No historical or new test data that use of the the drywell floor drain sump alternate sump overflows into the drywell monitoring equipment drain sump at method for LGS, LGS, Unit 1 Unit 1. CM-2 EGC will verify through Prior to initial Yes No historical or new test data that use of the the drywell floor drain sump alternate sump overflows into the drywell monitoring equipment drain sump at method for LGS, LGS, Unit 2. Unit 2. The following table identifies those actions committed to by EGG for Limerick Generating Station (LGS), Units 1 and 2 as part of the License Amendment Request. Any other statements in this submittal are provided for information purposes and are not regulatory commitments. Commitment Commitment Commitment Event Number Date One-Time Programmatic Action (Yes/No) (Yes/No) CM-1 EGG will verify through Prior to initial Yes No historical or new test data that use of the the drywell floor drain sump alternate sump overflows into the drywell monitoring equipment drain sump at method for LGS, LGS, Unit 1. Unit 1. CM-2 EGG will verify through Prior to initial Yes No historical or new test data that use of the the drywell floor drain sump alternate sump overflows into the drywell monitoring equipment drain sump at method for LGS, LGS, Unit 2. Unit 2. The following table identifies those actions committed to by EGG for Limerick Generating Station (LGS), Units 1 and 2 as part of the License Amendment Request. Any other statements in this submittal are provided for information purposes and are not regulatory commitments. Commitment Commitment Commitment Event Number Date One-Time Programmatic Action (Yes/No) (Yes/No) CM-1 EGG will verify through Prior to initial Yes No historical or new test data that use of the the drywell floor drain sump alternate sump overflows into the drywell monitoring equipment drain sump at method for LGS, LGS, Unit 1. Unit 1. CM-2 EGG will verify through Prior to initial Yes No historical or new test data that use of the the drywell floor drain sump alternate sump overflows into the drywell monitoring equipment drain sump at method for LGS, LGS, Unit 2. Unit 2.

ATTACHMENT 5 Drywell Sump Level Monitoring System Configuration Drawings (For Information Only) Limerick Generating Stationg Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 Drywell Sumo Level Monitoring System Configuration Drawings HBB-1 63-1, Reactor BIdg Liquid & Solid Radwaste Unit-i, Revision 4 HBB-263-i, Liquid & Solid Radwaste Reactor Building Unit 2, Revision 6 8031 -M-61, Sheet 1, Liquid Radwaste Collection (Unit 1), Revision 37 8031 -M-61, Sheet 4, Liquid Radwaste Collection (Unit 2), Revision 15 M-247, Reactor Bldg. Unit No. 1 Misc. Plans & Sections Area 11 & 12, Revision 23 M-328, Reactor Bldg. Unit No. 2 Misc. Plans & Sections Area 13 & 14, Revision 11 ATTACHMENT 5 Drywell Sump Level Monitoring System Configuration Drawings (For Information Only) Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 Drywell Sump Level Monitoring System Configuration Drawings HBB-163-1, "Reactor Bld'g Liquid & Solid Radwaste - Unit-1," Revision 4 HBB-263-1, "Liquid & Solid Radwaste Reactor Building Unit 2," Revision 6 8031-M-61, Sheet 1, "Liquid Radwaste Collection (Unit 1)," Revision 37 8031-M-61, Sheet 4, "Liquid Radwaste Collection (Unit 2)," Revision 15 M-247, "Reactor Bldg. Unit No. 1 Misc. Plans & Sections - Area 11 & 12," Revision 23 M-328, "Reactor Bldg. Unit No.2 Misc. Plans & Sections - Area 13 & 14," Revision 11 ATTACHMENT 5 Drywell Sump Level Monitoring System Configuration Drawings (For Information Only) Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 Drywell Sump Level Monitoring System Configuration Drawings HBB-163-1, "Reactor Bld'g Liquid & Solid Radwaste - Unit-1," Revision 4 HBB-263-1, "Liquid & Solid Radwaste Reactor Building Unit 2," Revision 6 8031-M-61, Sheet 1, "Liquid Radwaste Collection (Unit 1)," Revision 37 8031-M-61, Sheet 4, "Liquid Radwaste Collection (Unit 2)," Revision 15 M-247, "Reactor Bldg. Unit No. 1 Misc. Plans & Sections - Area 11 & 12," Revision 23 M-328, "Reactor Bldg. Unit No.2 Misc. Plans & Sections - Area 13 & 14," Revision 11

4 LF. ICCN REVJ2. CALC. NO43zQ? EV 4 Ni Ar12r2 1 7 E1CE DRAWIMS 1-1 P4IL)

• 247 PIPIkJ& PLAN ARE H

SK-M-6411 STRESS ISO Il* v wP siiE1 d1 frLj i/?dSSUED FOR FA. iT J ,... I o*iL I I I c4i tRtR am iD -V

2aAu 1 aiaw Cjt SE1SPA1CCLSI BECHTEL SAN FRANCISCO FabcaiecI By: LIMERICK GENERATING STATION SOUTHWEST FA8RICATING AND WELDING COMPANY PHILADELPHIA ELECTRIC COMPANY 1SOv1.TR1C-REACTOR BLD. LIQUiD £ SOLID RADWATE - UNIT-I t Li ML

I [ 8031 BB-1-I SPccL SHé7 29J { 14 L.r:. f(ev. 4 NOTE: AI?OEO 1Z.~F'~utJ.::.e ~'" M-~"JZ~f', Atoll? 11o.LGOlZ.p. ~k:. ~Iolr J UN* 7. 1<EI'ERENCE 'DRoIl.WI"e, ~Hpl pdlD Ivl* Z47 PIPING PLAN ARU, II.; 12 SK-M-64IL 5Tii:ESS ISO I2eYD ~ ,.;rJl 01)11' ~:/ t:~p -{'..J~ ""Uti 012 Ir-J* 012/'0,,1.:1-10'('" ~ y ~ 1 " '-6> ~ 1" O**{P'b !j.'l- >( ,Jp~l.-' CCN REVJ2.. CALC. NO i-43-0CP m 5EI5>IV1IC CLASS I Fabricated Bv: SOUTHWEST FABRICATING ANO WELDING COMPANY __.\\_. J._ fCIZ-" M' ~'!)'Z? f BECHTEL SAN FRANCISCO LIMERICK GENERAnNG STATION UNITS 1.2 PHI~AOELPHIAELECmlC COMPANY 150ME. TR\\C - REACTOR BLD'G. LIQUiD ~ SOLID RADWASTE - UNIT-I ,S,PooL 5Hce:r IJ'29/3 tl9 J.... 143*"r::>.......... I... 8031 I HBB'I~~-I 14 \\l'i<.-( 14 1-.F. CCN REV_Q... CALC. NO i-43*0Co f(.ev. 4 NOTE: AOO~O 12.~F'~UtJ"e' ~'" "M-~~Z~f, ll,1ol0 11oJ.GOiZ.p. f'O'lC. "..\\.If. I U>J. 7* ~EFERct-JCE 'DR.o.WIt-JGf:, ~Hpl PelD ~1' Z47 PIPING PLAN AREI', II t, 12 SK-M-6412. STI<:ESS ISO I2eVD SEISMIC-CLASS I Fabricaled Bv: SOUTHWEST FABRICATING AND WELDING COMPANY -s__ BECHTEL SAN FRANCISCO LIMERICK GENERAnNG STATION UNITS 1.2 PHI!.AllELPHIA ELECTP.IC COMPANY ISOME TR1C - RE.AC. TOR BLD'G. LIQUiD ~ SOLID RADWASTE - UNIT-I 8031 HBB'I~::'-I 4

14 LF. REV. 5 NOTE: ADDEO S/U SYSEM NO. REDRAWN AND REISSUED FOR coNsTRucT:CN. SUPERSEDES ALL PREVIOUS REVISIONS. REV. SF1 NOTE: ADDED LAST WELD & SPOOL 4 . ADDED PSI/ISI SCOPE BLODK. REV. 6 NOTE: INCORP. FCN PA-572 REF. REOL1NE

1. ADDED FW 3 SPOOL 45 1A AND lB (WAS SPOOL U. AS BUILT FOR PIPE, ADDED STRESS CALC NO. & 0-LISTED.

RECEIVED SEP 02 1966 BECHTEL SPOCL NUMBER SOURCE -EAT NUMBER (___ I SEISMIC CLASS I sa NONE a.&i4 CADO/REC

/) STRESS CALC 2-43-006 ) BECHTEL SAN FRANCISCO SOUTHWEST FABRICATING WELDING COMPANY LIMERICK GENERATING STATION UNITS I & 2 PNLADELPi4IA Fi.ECTRIC COUPANY FEVISION AFFECTS PSI/ISI SCb1 I YES ND ORIGINATOR I tSOMETRIC 1F1 INITIAL CORRECT LIQUID & SOLID RDwSTE E-REV. No. REACTOR BUILDING UNIT 2 L___J BLOCK I ce s AV2C N REVIEWED BY: FLi..> I [E: / / PS&II ENGINJ 8031 HBB-263-I SPOOL SHEET 4953 R S BOP I LAST WELD #3 S/li 2-63U I LAST SPOOL #18 REV. 1 NOTE: ADDED SPOOL, FW&M NUMBERS ISSUED FOR CONSTRUCTiON REV.2 NOTE: ISSUED OR HOLU PER EMF-1961 10-13-75 REV.3 NOTE: RELEASED -iDLC PER EMF-4667 DATED 6-15-79 REV.4 NOTE: REVIEWED PER UNIT 1 AS BUILT CONDITION AND P&IO M-S: REV.17 N-SI P&ID M-328 PIPING PLAN AREA 13 & 14 SK-M-2812 STRESS ISOMETRIC No. I I I SEE REV. S NOTE.

i. JRC I

ur I S/U 2-690 ILAST WELD -3 LAST SPOOL -1B 14 L.F. ADDED S/U SYS~EM NO. REDRAWN !\\ND REISSUED FOR CONSTRUCTICN. SUPERSEDES ALL PREVIOUS ::lEVISIONS, REV.5Fl NOTE: ADDED LAST WELD 8< SPDOL",ADDED PSI/lSI SCOPE BLOCK. REV. 6 NOTE: INCORP. FCN PA-572 REF. REDLINE 1.ADDEC FW -3 & SPOOL **S 1A AND 1B (WAS SPOOL ll. AS BUlL T FOR PIPE. ADDED STRESS CALC NO. 8< Q-LISTED. REV. 1 NOTE: ADDED SPOOL. FW&M \\JU~!BERS ISSUED FOR CONSTRUCTION REV.2 NOTE: ISSUED FOR 'HOLD'PER EMF-1961 10-13-75 REV.3 NOTE: RELEASED ':-iOLC' PER Et~F-4667 DATED 6-15-79 REV.4 NOTE: REVIEWED P:::R UNIT 1 AS 6UILT CONDITION "lND P8<lD M-6: REV.1? REV.5 NOTE: "'\\9.. ",\\'.:0 ~}:O ...,,,,~) .... / "1-e~11rl /~/ ~/~ ~ g()IJ!p#r* 2 j..... >",~ ....,..~ REFERENCE DRAWINGS (tIet-;IJ~P o~ll1~ P 8< ID D~ ~=~~8 PIPING PLAN AREA 13 8< 14 SK-M-2812 STRESS ISOMETRIC "'\\\\<ii ~~~. d ....\\'t- ~h RECEtVED S:fP 02 1986

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