Text

Application to Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process
	ML14191B180
Person / Time
Site:	Limerick
Issue date:	07/10/2014
From:	David Helker; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-08-001, TSTF-523
	Download: ML14191B180 (45)
	v • d • e

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10 CFR 50.90 July 10, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Application to Revise Technical Specifications to Adopt TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation," using the Consolidated Line Item Improvement Process

References:

1.

TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation,"

Revision 2, dated February 20, 2013

2.

Notice of Availability of the "TSTF-523, 'Generic Letter 2008-01, Managing Gas Accumulation,' Using the Consolidated Line Item Improvement Process," dated January 15, 2014

3.

Letter from K. R. Jury (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) to U.S. NRC, "Nine-Month Response to Generic Letter 2008-01," dated October 14, 2008 Pursuant to 10 CFR 50.90, Exelon Generation Company, LLC (EGC) is submitting a request for an amendment to the Technical Specifications for Limerick Generating Station, Units 1 and 2 (LGS).

The proposed amendments would modify Technical Specification requirements to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." LGS committed to evaluate the resolution of the Technical Specification issues with respect to the elements contained in the TSTF, and submit a license amendment request, if deemed necessary based on the evaluation, within 180 days following NRC approval of the TSTF (Reference 3). This submittal satisfies the commitment. provides a description and assessment of the proposed change. Attachment 2 provides the existing Technical Specification pages marked up to show the proposed changes. provides Table 1, which identifies the affected Standard Technical Specifications and provides the equivalent LGS Technical Specifications. Attachment 4 provides the existing Technical Specification Bases pages marked up to show the proposed changes. Changes to the existing Technical Specification Bases, consistent with the technical and regulatory analyses, will be implemented under the Technical Specification Bases Control Program.

They are provided in Attachment 4 for information only.

U.S. Nuclear Regulatory Commission July 10, 2014 Page 2 These proposed changes have been reviewed and approved by LGS's 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 July 10, 2015. Once approved, the amendment shall be implemented within 120 days.

There are no regulatory commitments contained in this letter.

In accordance with 10 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 Wendy E. Croft at (61 O) 765-5726.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 101h day of July 2014.

Respectfully, g~ //--~

David P. Helker Manager - Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)

3. Equivalent LGS Technical Specification Nomenclature

4. Proposed Technical Specification Bases Changes (Mark-Up)

(For Information Only) cc:

USNRC Region I, Regional Administrator USNRC Project Manager, LGS USNRC Senior Resident Inspector, LGS Director, Bureau of Radiation Protection, PA Department of Environmental Resources R. R. Janati, Commonwealth of Pennsylvania Description and Assessment Page 1 of 3

1.0 DESCRIPTION

The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification. The changes are being made to address the concerns discussed in Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems."

The proposed amendment is consistent with TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Exelon Generation Company, LLC (EGC) has reviewed the model safety evaluation dated December 23, 2013 as part of the Federal Register Notice of Availability. This review included a review of the NRC Staff's evaluation, as well as the information provided in TSTF-523, Revision 2. As described in the subsequent paragraphs, EGC has concluded that the justifications presented in the TSTF-523, Revision 2 proposal and the model safety evaluation prepared by the NRC Staff are applicable to Limerick Generating Station, Units 1 and 2 (LGS) and justify this amendment for incorporation of the changes to the plant Technical Specifications (TSs).

2.2 Optional Changes and Variations EGC is not proposing any significant variations or deviations from the TS changes described in TSTF-523, Revision 2, or the applicable parts of the NRC Staffs model safety evaluation dated December 23, 2013. EGC is noting the following minor variations from the TS changes described in the TSTF-523, Revision 2:

The LGS TS utilize different formatting, numbering, and titles than the Standard Technical Specifications (STS) on which TSTF-523, Revision 2 was based. Table 1 in Attachment 3 identifies the affected STS number, title, and section (i.e., Surveillance Requirements, LCO Bases, etc.) and provides the equivalent LGS TS number, title, and section.

EGC has reviewed these changes and determined that they are administrative and do not affect the applicability of TSTF-523, Revision 2 to the LGS TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Exelon Generation Company, LLC (EGC) requests adoption of TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," which is an approved change to the Standard Technical Specifications (STS), into the Limerick Generating Station, Units 1 and 2 Technical Specifications (TS).

The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

Description and Assessment Page 2 of 3 EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 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 revises or adds Surveillance Requirements (SRs) that require verification that the Emergency Core Cooling System (ECCS), the Residual Heat Removal (RHR) System, the Shutdown Cooling (SDC) System, the Containment Spray (CS) System, and the Reactor Core Isolation Cooling (RCIC) System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. Gas accumulation in the subject systems is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The proposed SRs ensure that the subject systems continue to be capable of performing their assumed safety function and are not rendered inoperable due to gas accumulation. Thus, the consequences of any accident previously evaluated are not significantly increased.

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 revises or adds SRs that require verification that the ECCS, the RHR, the SDC, the CS, and the RCIC Systems are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the proposed change does not impose any new or different requirements that could initiate an accident. The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions.

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 proposed change revises or adds SRs that require verification that the ECCS, the RHR, the SDC, the CS, and the RCIC Systems are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change revises or adds new requirements to manage gas accumulation in order to ensure the subject systems are capable of performing their assumed safety functions. The proposed SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis Description and Assessment Page 3 of 3 are protected. The proposed change does not adversely affect any current plant safety margins or the reliability of the equipment assumed in the safety analysis. Therefore, there are no changes being made to any safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed change presents no 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.

3.2 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 to the health and safety of the public.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

ATTACHMENT 2 Proposed Technical Specification Changes (Mark-Up)

Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATIONS PAGES Page 3/4 4-25 Page 3/4 4-26 Page 3/4 5-4 Page 3/4 6-15 Page 3/4 6-16 Page 3/4 7-9 Page 3/4 9-17 Page 3/4 9-18

REACTOR COOLANT SYSTEM 3/4.4.9 RESIDUAL HEAT REMOVAL HOT SHUTDOWN LIMITING CONDITION FOR OPERATION 3.4.9.1 Two (2) independent RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one (1) RHR shutdown cooling subsystem shall be in operation. * ** ***

Each independent RHR shutdown cooling subsystem shall consist of at least:

a.

One OPERABLE RHR pump, and b.

One OPERABLE RHR heat exchanger, not common to the two (2) independent subsystems.

APPLICABILITY:

OPERATIONAL CONDITION 3, with reactor vessel pressure less than the RHR cut-in permissive setpoint.

ACTION:

a.

With less than the above required independent RHR shutdown cooling subsystems OPERABLE, immediately initiate corrective action to return the required independent subsystems to OPERABLE status as soon as possible.

Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify the availability of at least one alternate method capable of decay heat removal for each inoperable independent RHR shutdown cooling subsystem. Be in at least COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .****

b.

With no independent RHR shutdown cooling subsystem in operation, immediately initiate corrective action to return at least one (1) independent subsystem to operation as soon as possible. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months establish reactor coolant circulation by an alternate method and monitor reactor coolant temperature and pressure at least once per hour.

SURVEILLANCE REQUIREMENTS 4.4.9.1 At least one independent RHR shutdown cooling subsystem or alternate method shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

One independent RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other independent subsystem is OPERABLE and in operation.

- The shutdown cooling pump may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8-hour period provided the other independent subsystem is OPERABLE.

- - The independent RHR shutdown cooling subsystem may be removed from operation during hydrostatic testing.

- - - Whenever two or more RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

LIMERICK - UNIT 1 3/4 4-25 Amendment No. 97, 119, 186 Proposed Technical Specification Changes (Mark-Up)

Page 1 of 17 Insert 1 Insert 2 4.4.9.1.1

REACTOR COOLANT SYSTEM 3/4.4.9 RESIDUAL HEAT REMOVAL HOT SHUTDOWN LIMITING CONDITION FOR OPERATION 3.4.9.1 Two (2) independent RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one (1) RHR shutdown cooling subsystem shall be in operation. * ** ***

Each independent RHR shutdown cooling subsystem shall consist of at least:

a.

One OPERABLE RHR pump, and b.

One OPERABLE RHR heat exchanger, not common to the two (2) independent subsystems.

APPLICABILITY:

OPERATIONAL CONDITION 3, with reactor vessel pressure less than the RHR cut-in permissive setpoint.

ACTION:

a.

With less than the above required independent RHR shutdown cooling subsystems OPERABLE, immediately initiate corrective action to return the required independent subsystems to OPERABLE status as soon as possible.

Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify the availability of at least one alternate method capable of decay heat removal for each inoperable independent RHR shutdown cooling subsystem. Be in at least COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .****

b.

With no independent RHR shutdown cooling subsystem in operation, immediately initiate corrective action to return at least one (1) independent subsystem to operation as soon as possible. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months establish reactor coolant circulation by an alternate method and monitor reactor coolant temperature and pressure at least once per hour.

SURVEILLANCE REQUIREMENTS 4.4.9.1 At least one independent RHR shutdown cooling subsystem or alternate method shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

One independent RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other independent subsystem is OPERABLE and in operation.

- The shutdown cooling pump may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8-hour period provided the other independent subsystem is OPERABLE.

- - The independent RHR shutdown cooling subsystem may be removed from operation during hydrostatic testing.

- - - Whenever two or more RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

LIMERICK - UNIT 2 3/4 4-25 Amendment No. 61,82, 147 Proposed Technical Specification Changes (Mark-Up)

Page 2 of 17 Insert 1 Insert 2 4.4.9.1.1

Insert 1 4.4.9.1.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program. *****

Insert 2 Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than the RHR cut-in permissive setpoint.

Proposed Technical Specification Changes (Mark-Up)

Page 3 of 17

REACTOR COOLANT SYSTEM COLD SHUTDOWN LIMITING CONDITION FOR OPERATION _

3.4.9.2 Two (2) RHR shutdown cooling subsystems shall be OPERABLE, and with no recirculation pump in operation, at least one (1) RHR shutdown cooling subsystem shall be in operation. * ** ***

APPLICABILITY: OPERATIONAL CONDITION 4.

ACTION: #

a.

With one (1) or two (2) RHR shutdown cooling subsystems inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

b.

With no RHR shutdown cooling subsystems in operation and no recirculation pump in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulating by an alternate method; and 2.

Once per hour monitor reactor coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS 4.4.9.2 At least one (1) RHR shutdown cooling subsystem or recirculation pump is operating or an alternate method shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up two (2) hours per eight (8) hour period.

One (1) RHR shutdown cooling subsystem may be inoperable for up to two (2) hours for the performance of Surveillances.

The shutdown cooling subsystem may be removed from operation during hydrostatic testing.

Separate Action entry is allowed for each shutdown cooling subsystem.

LIMERICK - UNIT 1 3/4 4-26 Amendment No. 97, 119, 186 Proposed Technical Specification Changes (Mark-Up)

Page 4 of 17 4.4.9.2.2 Verify RHR Shutdown Cooling Subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

4.4.9.2.1

REACTOR COOLANT SYSTEM COLD SHUTDOWN LIMITING CONDITION FOR OPERATION 3.4.9.2 Two (2) RHR shutdown cooling subsystems shall be OPERABLE, and with no recirculation pump in operation, at least one (1) RHR shutdown cooling subsystem shall be in operation. * ** ***

APPLICABILITY: OPERATIONAL CONDITION 4.

ACTION: #

a.

With one (1) or two (2) RHR shutdown cooling subsystems inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

b.

With no RHR shutdown cooling subsystems in operation and no recirculation pump in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulating by an alternate method; and 2.

Once per hour monitor reactor coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS 4.4.9.2 At least one (1) RHR shutdown cooling subsystem or recirculation pump is operating or an alternate method shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up two (2) hours per eight hour (8) period.

One (1) RHR shutdown cooling subsystem may be inoperable for up to two (2) hours for the performance of Surveillances.

The shutdown cooling subsystem may be removed from operation during hydrostatic testing.

Separate Action entry is allowed for each shutdown cooling subsystem.

LIMERICK - UNIT 2 3/4 4-26 Amendment No. 61, 82, 147 Proposed Technical Specification Changes (Mark-Up)

Page 5 of 17 4.4.9.2.2 Verify RHR Shutdown Cooling Subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

4.4.9.2.1

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.1 The emergency core cooling systems shall be demonstrated OPERABLE by:

a.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system:

a)

Verifying by venting at the high point vents that the system piping from the pump discharge valve to the system isolation valve is filled with water.

b)

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct* position.

2.

For the LPCI system, verifying that both LPCI system subsystem cross-tie valves (HV-51-182 A, B) are closed with power removed from the valve operators.

3.

For the HPCI system, verifying that the HPCI pump flow controller is in the correct position.

4.

For the CSS and LPCI system, performance of a CHANNEL FUNCTIONAL TEST of the injection header P instrumentation.

b.

Verifying that, when tested pursuant to Specification 4.0.5:

1.

Each CSS pump in each subsystem develops a flow of at least 3175 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of 105 psid plus head and line losses.

2.

Each LPCI pump in each subsystem develops a flow of at least 10,000 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of 20 psid plus head and line losses.

3.

The HPCI pump develops a flow of at least 5600 gpm against a test line pressure which corresponds to a reactor vessel pressure of 1040 psig plus head and line losses when steam is being supplied to the turbine at 1040, +13, -120 psig.**

c.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system, performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence and verifying that each automatic valve in the flow path actuates to its correct position. Actual injection of coolant into the reactor vessel may be excluded from this test.

Except that an automatic valve capable of automatic return to its ECCS position when an ECCS signal is present may be in position for another mode of operation.

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test. If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam dome pressure to less than 200 psig within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

LIMERICK - UNIT 1 3/4 5-4 Amendment No. 29, 71, 106, 186 Proposed Technical Specification Changes (Mark-Up)

Page 6 of 17 Verifying locations susceptible to gas accumulation are sufficiently filled with water.

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

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.1 The emergency core cooling systems shall be demonstrated OPERABLE by:

a.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system:

a)

Verifying by venting at the high point vents that the system piping from the pump discharge valve to the system isolation valve is filled with water.

b)

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct* position.

2.

For the LPCI system, verifying that both LPCI system subsystem cross-tie valves (HV-51-282 A, B) are closed with power removed from the valve operators.

3.

For the HPCI system, verifying that the HPCI pump flow controller is in the correct position.

4.

For the CSS and LPCI system, performance of a CHANNEL FUNCTIONAL TEST of the injection header P instrumentation.

b.

Verifying that, when tested pursuant to Specification 4.0.5:

1.

Each CSS pump in each subsystem develops a flow of at least 3175 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of = 105 psid plus head and line losses.

2.

Each LPCI pump in each subsystem develops a flow of at least 10,000 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of 20 psid plus head and line losses.

3.

The HPCI pump develops a flow of at least 5600 gpm against a test line pressure which corresponds to a reactor vessel pressure of 1040 psig plus head and line losses when steam is being supplied to the turbine at 1040, +13, -120 psig.**

c.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system, performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence and verifying that each automatic valve in the flow path actuates to its correct position. Actual injection of coolant into the reactor vessel may be excluded from this test.

Except that an automatic valve capable of automatic return to its ECCS position when an ECCS signal is present may be in position for another mode of operation.

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test. If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam dome pressure to less than 200 psig within the following 72-hours.

LIMERICK - UNIT 2 3/4 5-4 Amendment No. 34, 51, 147 Proposed Technical Specification Changes (Mark-Up)

Page 7 of 17 Verifying locations susceptible to gas accumulation are sufficiently filled with water.

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

CONTAINMENT SYSTEMS SUPPRESSION POOL SPRAY LIMITING CONDITION FOR OPERATION 3.6.2.2 The suppression pool spray mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a.

One OPERABLE RHR pump, and b.

An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger and the suppression pool spray sparger(s).

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a.

With one suppression pool spray loop inoperable, restore the inoperable loop to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With both suppression pool spray loops inoperable, restore at least one loop to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN* within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.6.2.2 The suppression pool spray mode of the RHR system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

By verifying that each of the required RHR pumps develops a flow of at least 500 gpm on recirculation flow through the RHR heat exchanger and the suppression pool spray sparger when tested pursuant to Speci-fication 4.0.5.

Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

LIMERICK - UNIT 1 3/4 6-15 Amendment No. 86, 131, 186 Proposed Technical Specification Changes (Mark-Up)

Page 8 of 17

c. By verifying RHR suppression pool spray subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

CONTAINMENT SYSTEMS SUPPRESSION POOL SPRAY LIMITING CONDITION FOR OPERATION 3.6.2.2 The suppression pool spray mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a.

One OPERABLE RHR pump, and

b.

An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger and the suppression pool spray sparger(s).

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a.

With one suppression pool spray loop inoperable, restore the inoperable loop to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With both suppression pool spray loops inoperable, restore at least one loop to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN* within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.6.2.2 The suppression pool spray mode of the RHR system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

By verifying that each of the required RHR pumps develops a flow of at least 500 gpm on recirculation flow through the RHR heat exchanger and the suppression pool spray sparger when tested pursuant to Speci-fication 4.0.5.

Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

LIMERICK - UNIT 2 3/4 6-15 Amendment No. 30, 70, 92, 147 Proposed Technical Specification Changes (Mark-Up)

Page 9 of 17

c. By verifying RHR suppression pool spray subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

CONTAINMENT SYSTEMS SUPPRESSION POOL COOLING LIMITING CONDITION FOR OPERATION 3.6.2.3 The suppression pool cooling mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a.

One OPERABLE RHR pump, and

b.

An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger.

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a.

With one suppression pool cooling loop inoperable, restore the inoperable loop to OPERABLE status within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s** or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With both suppression pool cooling loops inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN* within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.6.2.3 The suppression pool cooling mode of the RHR system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

By verifying that each of the required RHR pumps develops a flow of at least 10,000 gpm on recirculation flow through the flow path including the RHR heat exchanger and its associated closed bypass valve, the suppression pool and the full flow test line when tested pursuant to Specification 4.0.5.

Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

- During the extended 7-day Allowed Outage Time (AOT) specified by TS LCO 3.7.1.1, Action a.3.a) or a.3.b) to allow for RHRSW subsystem piping repairs, the 72-hour AOT for one inoperable suppression pool cooling loop may also be extended to 7 days for the same 7-day period.

LIMERICK - UNIT 1 3/4 6-16 Amendment No. 57,58,86,131,186, 203 Proposed Technical Specification Changes (Mark-Up)

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c. By verifying RHR suppression pool cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

CONTAINMENT SYSTEMS SUPPRESSION POOL COOLING LIMITING CONDITION FOR OPERATION 3.6.2.3 The suppression pool cooling mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a.

One OPERABLE RHR pump, and

b.

An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger.

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a.

With one suppression pool cooling loop inoperable, restore the inoperable loop to OPERABLE status within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s** or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With both suppression pool cooling loops inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN* within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.6.2.3 The suppression pool cooling mode of the RHR system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

By verifying that each of the required RHR pumps develops a flow of at least 10,000 gpm on recirculation flow through the flow path including the RHR heat exchanger and its associated closed bypass valve, the suppression pool and the full flow test line when tested pursuant to Specification 4.0.5.

Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

- During the extended 7-day Allowed Outage Time (AOT) specified by TS LCO 3.7.1.1, Action a.3.a) or a.3.b) to allow for RHRSW subsystem piping repairs, the 72-hour AOT for one inoperable suppression pool cooling loop may also be extended to 7 days for the same 7-day period.

LIMERICK - UNIT 2 3/4 6-16 Amendment No. 30,70,92,147, 165 Proposed Technical Specification Changes (Mark-Up)

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c. By verifying RHR suppression pool cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

PLANT SYSTEMS 3/4.7.3 REACTOR CORE ISOLATION COOLING SYSTEM LIMITING CONDITION FOR OPERATION _

3.7.3 The reactor core isolation cooling (RCIC) system shall be OPERABLE with an OPERABLE flow path capable of automatically taking suction from the suppression pool and transferring the water to the reactor pressure vessel.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3 with reactor steam dome pressure greater than 150 psig.

ACTION:

a.

With the RCIC system inoperable, operation may continue provided the HPCI system is OPERABLE; restore the RCIC system to OPERABLE status within 14 days. Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reduce reactor steam dome pressure to less than or equal to 150 psig within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

In the event the RCIC system is actuated and injects water into the reactor coolant system, a Special Report shall be prepared and sub-mitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date.

c.

Specification 3.0.4.b is not applicable to RCIC.

SURVEILLANCE REQUIREMENTS 4.7.3 The RCIC system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by:

1.

Verifying by venting at the high point vents that the system piping from the pump discharge valve to the system isolation valve is filled with water.

2.

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

3.

Verifying that the pump flow controller is in the correct position.

b.

In accordance with the Surveillance Frequency Control Program by verifying that the RCIC pump develops a flow of greater than or equal to 600 gpm in the test flow path with a system head corresponding to reactor vessel operating pressure when steam is being supplied to the turbine at 1040 + 13, - 120 psig.*

The provisions of Specification 4.0.4 are not applicable, provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test. If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam pressure to less than 150 psig within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

LIMERICK - UNIT 1 3/4 7-9 Amendment No. 29, 106, 169, 186 Proposed Technical Specification Changes (Mark-Up)

Page 12 of 17 Verifying locations susceptible to gas accumulation are sufficiently filled with water.

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

PLANT SYSTEMS 3/4.7.3 REACTOR CORE ISOLATION COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.3 The reactor core isolation cooling (RCIC) system shall be OPERABLE with an OPERABLE flow path capable of automatically taking suction from the suppression pool and transferring the water to the reactor pressure vessel.

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3 with reactor steam dome pressure greater than 150 psig.

ACTION:

a.

With the RCIC system inoperable, operation may continue provided the HPCI system is OPERABLE; restore the RCIC system to OPERABLE status within 14 days. Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reduce reactor steam dome pressure to less than or equal to 150 psig within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

In the event the RCIC system is actuated and injects water into the reactor coolant system, a Special Report shall be prepared and sub-mitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date.

c.

Specification 3.0.4.b is not applicable to RCIC.

SURVEILLANCE REQUIREMENTS 4.7.3 The RCIC system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by:

1.

Verifying by venting at the high point vents that the system piping from the pump discharge valve to the system isolation valve is filled with water.

2.

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

3.

Verifying that the pump flow controller is in the correct position.

b.

In accordance with the Surveillance Frequency Control Program by verifying that the RCIC pump develops a flow of greater than or equal to 600 gpm in the test flow path with a system head corresponding to reactor vessel operating pressure when steam is being supplied to the turbine at 1040 + 13, - 120 psig.*

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test. If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam dome pressure to less than 150 psig within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

LIMERICK - UNIT 2 3/4 7-9 Amendment No. 51, 132, 147 Proposed Technical Specification Changes (Mark-Up)

Page 13 of 17

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

Verifying locations susceptible to gas accumulation are sufficiently filled with water.

REFUELING OPERATIONS 3/4.9.11 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.11.1 One (1) RHR shutdown cooling subsystem shall be OPERABLE and in operation.

APPLICABILITY:

OPERATIONAL CONDITION 5, when irradiated fuel is in the reactor vessel and the water level is greater than or equal to 22 feet above the top of the reactor pressure vessel flange.

ACTION:

a.

With the required RHR shutdown cooling subsystem inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available.

b.

With the required action and associated completion time of Action "a" above not met.

1.

Immediately suspend loading of irradiated fuel assemblies into the reactor pressure vessel; and

2.

Immediately initiate action to restore REFUELING FLOOR SECONDARY CONTAINMENT INTEGRITY to OPERABLE status; and

3.

Immediately initiate action to restore one (1) Standby Gas Treatment subsystem to OPERABLE status; and

4.

Immediately initiate action to restore isolation capability in each required Refueling Floor secondary containment penetration flow path not isolated.

c.

With no RHR shutdown cooling subsystem in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulation by an alternate method; and

2.

Once per hour monitor reactor coolant temperature.

SURVEILLANCE REQUIREMENTS 4.9.11.1 At least one (1) RHR shutdown cooling subsystem, or an alternate method, shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

The required RHR shutdown cooling subsystem may be removed from operation for up to two (2) hours per eight (8) hour period.

LIMERICK - UNIT 1 3/4 9-17 Amendment No. 97, 119, 186 Proposed Technical Specification Changes (Mark-Up)

Page 14 of 17 4.9.11.1.2 Verify required RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

4.9.11.1.1

REFUELING OPERATIONS 3/4.9.11 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.11.1 One (1) RHR shutdown cooling subsystem shall be OPERABLE and in operation.

APPLICABILITY: OPERATIONAL CONDITION 5, when irradiated fuel is in the reactor vessel and the water level is greater than or equal to 22 feet above the top of the reactor pressure vessel flange.

ACTION:

a.

With the required RHR shutdown cooling subsystem inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available.

b.

With the required action and associated completion time of Action "a above not met.

1.

Immediately suspend loading of irradiated fuel assemblies into the reactor pressure vessel; and

2.

Immediately initiate action to restore REFUELING FLOOR SECONDARY CONTAINMENT INTEGRITY to OPERABLE status; and

3.

Immediately initiate action to restore one (1) Standby Gas Treatment subsystem to OPERABLE status; and

4.

Immediately initiate action to restore isolation capability in each required Refueling Floor secondary containment penetration flow path not isolated.

c.

With no RHR shutdown cooling subsystem in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulation by an alternate method; and

2.

Once per hour monitor reactor coolant temperature.

SURVEILLANCE REQUIREMENTS 4.9.11.1 At least one (1) RHR shutdown cooling subsystem, or an alternate method, shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

The required RHR shutdown cooling subsystem may be removed from operation for up to two (2) hours per eight (8) hour period.

LIMERICK - UNIT 2 3/4 9-17 Amendment No. 61, 82, 147 Proposed Technical Specification Changes (Mark-Up)

Page 15 of 17 4.9.11.1.2 Verify required RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

4.9.11.1.1

REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.11.2 Two (2) RHR shutdown cooling subsystems shall be OPERABLE, and one (1)

RHR shutdown cooling subsystem shall be in operation.

APPLICABILITY:

OPERATIONAL CONDITION 5, when irradiated fuel is in the reactor vessel and the water level is less than 22 feet above the top of the reactor pressure vessel flange.

ACTION:

a.

With one (1) or two (2) required RHR shutdown cooling subsystems inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available for each inoperable required RHR shutdown cooling subsystem.

b.

With the required action and associated completion time of Action "a" above not met:

1.

Immediately initiate action to restore REFUELING FLOOR SECONDARY CONTAINMENT INTEGRITY to OPERABLE status; and

2.

Immediately initiate action to restore one (1) Standby Gas Treatment subsystem to OPERABLE status; and

3.

Immediately initiate action to restore isolation capability in each required Refueling Floor secondary containment penetration flow path not isolated.

c.

With no RHR shutdown cooling subsystem in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulation by an alternate method; and

2.

Once per hour monitor reactor coolant temperature.

SURVEILLANCE REQUIREMENTS 4.9.11.2 At least one (1) RHR shutdown cooling subsystem, or an alternate method, shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

The required operating shutdown cooling subsystem may be removed from operation for up to two (2) hours per eight (8) hour period.

LIMERICK - UNIT 1 3/4 9-18 Amendment No. 97, 119, 186.

Proposed Technical Specification Changes (Mark-Up)

Page 16 of 17 4.9.11.2.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

4.9.11.2.1

REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.11.2 Two (2) RHR shutdown cooling subsystems shall be OPERABLE, and one (1)

RHR shutdown cooling subsystem shall be in operation.

APPLICABILITY: OPERATIONAL CONDITION 5, when irradiated fuel is in the reactor vessel and the water level is less than 22 feet above the top of the reactor pressure vessel flange.

ACTION:

a.

With one (1) or two (2) required RHR shutdown cooling subsystems inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available for each inoperable required RHR shutdown cooling subsystem.

b.

With the required action and associated completion time of Action "a" above not met:

1.

Immediately initiate action to restore REFUELING FLOOR SECONDARY CONTAINMENT INTEGRITY to OPERABLE status; and

2.

Immediately initiate action to restore one (1) Standby Gas Treatment subsystem to OPERABLE status; and

3.

Immediately initiate action to restore isolation capability in each required Refueling Floor secondary containment penetration flow path not isolated.

c.

With no RHR shutdown cooling subsystem in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulation by an alternate method; and

2.

Once per hour monitor reactor coolant temperature.

SURVEILLANCE REQUIREMENTS _

4.9.11.2 At least one (1) RHR shutdown cooling subsystem, or an alternate method, shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

The required operating shutdown cooling subsystem may be removed from operation for up to two (2) hours per eight (8) hour period.

LIMERICK - UNIT 2 3/4 9-18 Amendment No. 61, 82, 147 Proposed Technical Specification Changes (Mark-Up)

Page 17 of 17 4.9.11.2.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

4.9.11.2.1

ATTACHMENT 3 Equivalent LGS Technical Specification Nomenclature Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85

Table 1. Equivalent LGS Technical Specification Nomenclature Number Title Part Number Title Part 3.4.8 RHR Shutdown Cooling System-Hot Shutdown SR 4.4.9.1 Residual Heat Removal Hot Shutdown SR 3.4.8 RHR Shutdown Cooling System-Hot Shutdown LCO Bases 3/4.4.9 Residual Heat Removal Bases 3.4.8 RHR Shutdown Cooling System-Hot Shutdown SR Bases 3/4.4.9 Residual Heat Removal Bases 3.4.9 RHR Shutdown Cooling System-Cold Shutdown SR 4.4.9.2 Residual Heat Removal Cold Shutdown SR 3.4.9 RHR Shutdown Cooling System-Cold Shutdown LCO Bases 3/4.4.9 Residual Heat Removal Bases 3.4.9 RHR Shutdown Cooling System-Cold Shutdown SR Bases 3/4.4.9 Residual Heat Removal Bases 3.5.1 ECCS - Operating SR 4.5.1 ECCS - Operating SR 3.5.1 ECCS - Operating LCO Bases 3/4.5.1 ECCS - Operating and Shutdown Bases 3.5.1 ECCS - Operating SR Bases 3/4.5.1 ECCS - Operating and Shutdown Bases 3.5.2 ECCS - Shutdown SR 4.5.2 TS SR 4.5.2.1 redirects to the SRs in 4.5.1. No changes were made in TS 4.5.2 SR 3.5.2 ECCS - Shutdown LCO Bases 3.5.2 ECCS - Shutdown SR Bases 3.5.3 RCIC System SR 4.7.3 Reactor Core Isolation Cooling System SR 3.5.3 RCIC System LCO Bases 3/4.7.3 Reactor Core Isolation Cooling System Bases 3.5.3 RCIC System SR Bases 3/4.7.3 Reactor Core Isolation Cooling System Bases 3.6.2.3 RHR Suppression Pool Cooling SR 4.6.2.3 Containment Systems Suppression Pool Cooling SR 3.6.2.3 RHR Suppression Pool Cooling LCO Bases 3/4.6.2 Depressurization Systems Bases 3.6.2.3 RHR Suppression Pool Cooling SR Bases 3/4.6.2 Depressurization Systems Bases 3.6.2.4 RHR Suppression Pool Spray SR 4.6.2.2 Containment Systems Suppression Pool Spray SR 3.6.2.4 RHR Suppression Pool Spray LCO Bases 3/4.6.2 Depressurization Systems Bases 3.6.2.4 RHR Suppression Pool Spray SR Bases 3/4.6.2 Depressurization Systems Bases 3.9.8 RHR High Water Level SR 4.9.11.1 Residual Heat Removal and Coolant Circulation High Water Level SR 3.9.8 RHR High Water Level LCO Bases 3/4.9.11 Residual Heat Removal and Coolant Circulation Bases 3.9.8 RHR High Water Level SR Bases 3/4.9.11 Residual Heat Removal and Coolant Circulation Bases 3.9.9 RHR Low Water Level SR 4.9.11.2 Low Water Level SR 3.9.9 RHR Low Water Level LCO Bases 3/4.9.11 Residual Heat Removal and Coolant Circulation Bases 3.9.9 RHR Low Water Level SR Bases 3/4.9.11 Residual Heat Removal and Coolant Circulation Bases LGS, Unit 1/2 TS STS Equivalent LGS Technical Specification Nomenclature Page 1 of 1

ATTACHMENT 4 Proposed Technical Specification Bases Changes (Mark-Up)

(For Information Only)

Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATION BASES PAGES Page B 3/4 4-6a Page B 3/4 5-1 Page B 3/4 5-2 Page B 3/4 6-3 Page B 3/4 6-3a Page B 3/4 7-1c Page B 3/4 9-2a

3/4.4.9 RESIDUAL HEAT REMOVAL (Cont'd) required to be OPERABLE for that independent subsystem to be OPERABLE. During COLD SHUTDOWN and REFUELING conditions, however, the subsystems not only have a common suction source, but are allowed to have a common heat exchanger and common discharge piping. To meet the LCO of two (2) OPERABLE subsystems, both pumps in one (1) loop or one (1) pump in each of the two (2) loops must be OPERABLE. Since the piping and heat exchangers are passive components, that are assumed not to fail, they are allowed to be common to both subsystems. Additionally, each RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. Operation (either continuous or intermittent) of one (1) subsystem can maintain and reduce the reactor coolant temperature as required. However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

Alternate decay heat removal methods are available to operators. These alternate methods of decay heat removal can be verified available either by calculation (which includes a review of component and system availability to verify that an alternate decay heat removal method is available) or by demonstration, and that a method of coolant mixing be operational. Decay heat removal capability by ambient losses can be considered in evaluating alternate decay heat removal capability.

LIMERICK - UNIT 1 B 3/4 4-6a Amendment No. 119 Proposed Technical Specification Bases Changes (Mark-Up)

(For Information Only)

Page 1 of 19 Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

Insert 3

3/4.4.9 RESIDUAL HEAT REMOVAL (Cont'd) required to be OPERABLE for that independent subsystem to be OPERABLE. During COLD SHUTDOWN and REFUELING conditions, however, the subsystems not only have a common suction source, but are allowed to have a common heat exchanger and common discharge piping. To meet the LCO of two (2) OPERABLE subsystems, both pumps in one (1) loop or one (1) pump in each of the two (2) loops must be OPERABLE. Since the piping and heat exchangers are passive components, that are assumed not to fail, they are allowed to be common to both subsystems. Additionally, each RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. Operation (either continuous or intermittent) of one (1) subsystem can maintain and reduce the reactor coolant temperature as required. However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

Alternate decay heat removal methods are available to operators. These alternate methods of decay heat removal can be verified available either by calculation (which includes a review of component and system availability to verify that an alternate decay heat removal method is available) or by demonstration, and that a method of coolant mixing be operational. Decay heat removal capability by ambient losses can be considered in evaluating alternate decay heat removal capability.

LIMERICK - UNIT 2 B 3/4 4-6a Amendment No. 82 Proposed Technical Specification Bases Changes (Mark-Up)

(For Information Only)

Page 2 of 19 Insert 3 Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

Insert 3 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of non-condensable gas into the reactor vessel. This surveillance verifies that the RHR Shutdown Cooling System piping is sufficiently filled with water prior to initially placing the system in operation during reactor shutdown. The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water to ensure that it can reliably perform its intended function.

The RHR Shutdown Cooling System is a manually initiated mode of the RHR System whose use is typically preceded by system piping flushes that disturb both the RHR pump suction and discharge piping. RHR Shutdown Cooling System is flushed and manually aligned for service using system operating procedures that ensure the RHR shutdown cooling suction and discharge flow paths are sufficiently filled with water. In the event that RHR Shutdown Cooling is required for emergency service, the system operating procedures that align and start the RHR System in shutdown cooling mode include the flexibility to eliminate piping flushes while maintaining minimum requirements to ensure that the suction and discharge flow paths are sufficiently filled with water. The RHR Shutdown Cooling System surveillance is met through the performance of the operating procedures that initially place the RHR shutdown cooling sub-system in service.

This surveillance requirement is modified by a Note allowing sufficient time (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) to align the RHR System for Shutdown Cooling operation after reactor dome pressure is less than the RHR cut-in permissive set point.

Proposed Technical Specification Bases Changes (Mark-Up)

(For Information Only)

Page 3 of 19

3/4.5 EMERGENCY CORE COOLING SYSTEM BASES 3/4.5.1 and 3/4.5.2 ECCS - OPERATING and SHUTDOWN The core spray system (CSS), together with the LPCI mode of the RHR system, is provided to assure that the core is adequately cooled following a loss-of-coolant accident and provides adequate core cooling capacity for all break sizes up to and including the double-ended reactor recirculation line break, and for smaller breaks following depressurization by the ADS.

The CSS is a primary source of emergency core cooling after the reactor vessel is depressurized and a source for flooding of the core in case of accidental draining.

The surveillance requirements provide adequate assurance that the CSS will be OPERABLE when required. Although all active components are testable and full flow can be demonstrated by recirculation through a test loop during reactor operation, a complete functional test requires reactor shutdown. The pump discharge piping is maintained full to prevent water hammer damage to piping and to start cooling at the earliest moment.

The low pressure coolant injection (LPCI) mode of the RHR system is provided to assure that the core is adequately cooled following a loss-of-coolant accident. Four subsystems, each with one pump, provide adequate core flooding for all break sizes up to and including the double-ended reactor recirculation line break, and for small breaks following depressurization by the ADS.

The surveillance requirements provide adequate assurance that the LPCI system will be OPERABLE when required. Although all active components are testable and full flow can be demonstrated by recirculation through a test loop during reactor operation, a complete functional test requires reactor shutdown. The pump discharge piping is maintained full to prevent water hammer damage to piping and to start cooling at the earliest moment.

The high pressure coolant injection (HPCI) system is provided to assure that the reactor core is adequately cooled to limit fuel clad temperature in the event of a small break in the reactor coolant system and loss of coolant which does not result in rapid depressurization of the reactor vessel. The HPCI system permits the reactor to be shut down while maintaining sufficient reactor vessel water level inventory until the vessel is depressurized. The HCPI system continues to operate until reactor vessel pressure is below the pressure at which CSS operation or LPCI mode of the RHR system operation maintains core cooling.

The capacity of the system is selected to provide the required core cooling.

The HPCI pump is designed to deliver greater than or equal to 5600 gpm at reactor pressures between 1182 and 200 psig and is capable of delivering at least 5000 gpm between 1182 and 1205 psig. In the systems normal alignment, water from the condensate storage tank is used instead of injecting water from the suppression pool into the reactor, but no credit is taken in the safety analyses for the condensate storage tank water.

LIMERICK - UNIT 1 B 3/4 5-1 Amendment No. 106, 137 ECR 00-00177 Proposed Technical Specification Bases Changes (Mark-Up)

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Page 4 of 19 Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY.