ML17115A087

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License Amendment Request - Proposed Relocation of Main Condenser Offgas Monitoring Instrumentation and Gaseous Effluents Technical Specifications
ML17115A087
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 04/24/2017
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML17115A087 (48)
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Text

Exelon Generation 10 CFR 50.90 April 24, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

License Amendment Request - Proposed Relocation of Main Condenser Offgas Monitoring Instrumentation and Gaseous Effluents Technical Specifications In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon}, proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively.

The proposed changes relocate the following operability and surveillance requirements from the LGS TS to the Offsite Dose Calculation Manual (ODCM) or to the LGS Technical Requirements Manual (TRM):

  • Main Condenser Offgas Monitoring Instrumentation, TS Section 3.3. 7.12, "Offgas Monitoring Instrumentation," (Relocate the Noble Gas Activity Monitor to the ODCM, relocate the Hydrogen Monitor to the TRM},

(Relocate to the TRM), and

Associated with the relocation of the Main Condenser Offgas Noble Gas Activity Monitor, SR 4 .11.2.6.2.b is changed to account for the relocated instrument's requirements and to provide for consistency with the improved Standard Technical Specifications issued by the NRC in NUREG-1433, "Standard Technical Specifications - General Electric BWR/4 Plants."

Associated with the relocation of the Explosive Gas Mixture Instrumentation and Gaseous Effluent TS sections, a new TS program section, 6.8.4.1, "Explosive Gas Monitoring Program," is added to TS Section 6.8, "Procedures and Programs."

License Amendment Request Main Condenser Offgas Monitoring Instrumentation Docket Nos. 50-352 and 50-353 April 24, 2017 Page 2 The proposed changes conform to the requirements of 10 CFR 50.36, "Technical specifications,"

for the contents of TS, and are consistent with the improved Standard Technical Specifications issued by the NRC in NUREG-1433.

Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, "Issuance of amendment."

The proposed changes have been reviewed by the LGS Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

This amendment request contains no regulatory commitments. provides the evaluation of the proposed changes. Attachment 2 provides a copy of the marked up TS pages that reflect the proposed changes. Attachment 3 provides a copy of the marked up TS Bases pages that reflect the proposed changes (for information only).

Exelon requests approval of the proposed amendments by April 30, 2018. Upon NRC approval, the amendments shall be implemented within 90 days of issuance.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon 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 submittal, please contact David Neff at 610-765-5631.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 24th day of April 2017.

Respectfully, d~-.UC-James Barstow Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Markup of Proposed Technical Specifications Pages
3. Markup of Proposed Technical Specifications Bases Pages (For Information Only) cc: Regional Administrator - NRC Region I w/ attachments II NRC Senior Resident Inspector - Limerick Generating Station II NRC Project Manager, NRR - Limerick Generating Station Director, Bureau of Radiation Protection - Pennsylvania Department II of Environmental Protection

ATTACHMENT 1 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 EVALUATION OF PROPOSED CHANGES

Subject:

Proposed Relocation of Main Condenser Offgas Monitoring Instrumentation and Gaseous Effluents Technical Specifications 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

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

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 1 of 13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications {TS), Appendix A of Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively.

The proposed changes relocate the operability and surveillance requirements from the LGS TS to the LGS Offsite Dose Calculation Manual (ODCM) or to the LGS Technical Requirements Manual (TRM):

(Relocate to the TRM), and

In accordance with TS Section 6.14, "Offsite Dose Calculation Manual (ODCM)" (Reference 6),

the ODCM is a licensee-controlled document and changes to the ODCM are subject to the regulatory requirements of TS Section 6.14 and 10 CFR 50.90. In accordance with LGS Updated Final Safety Analysis Report (UFSAR), Section 13.5.3 (Reference 1), the TRM is a licensee-controlled procedure described in the UFSAR and, therefore, changes to the TRM are subject to the requirements of 10 CFR 50.59, "Changes, tests and experiments." Accordingly, any future changes to Main Condenser Offgas Monitoring instruments and Main Condenser Explosive Gas Monitoring operability and surveillance requirements will be controlled by the applicable NRC regulatory requirements.

Associated with the relocation of the Main Condenser Offgas Noble Gas Activity Monitor (Radioactivity Monitor), SR 4.11.2.6.2.b is changed to account for the relocated instrument's requirements and to provide for consistency with the improved Standard Technical Specifications (Reference 3), Section 3.7.6, "Main Condenser Offgas, and the associated Bases.

Associated with the relocation of the Explosive Gas Mixture instrumentation and Gaseous Effluent TS sections, a new TS program section, 6.8.4.1, "Explosive Gas Monitoring Program," is added to TS Section 6.8, "Procedures and Programs." This new program will include a limit for the concentration of hydrogen gas downstream of the offgas Recombiner and a surveillance to ensure the limit is maintained. The wording is consistent with the improved Standard Technical Specifications (Reference 3), Section 5.5.8, "Explosive Gas and Storage Tank Radioactivity Monitoring Program."

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 2of13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes 2.0 DETAILED DESCRIPTION The NRC provided guidance for the contents of TS in its "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39132, July 22, 1993; Reference 4). In particular, the NRC indicated that certain items could be relocated from the TS to licensee-controlled documents. The Final Policy Statement identified future criteria to be used in determining whether particular safety functions are required to be included in the TS. The NRC subsequently adopted an amendment to 10 CFR 50.36, "Technical specifications," (60 FR 36953, July 19, 1995; Reference 5) to codify and incorporate these criteria . The criteria are restated below.

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4: A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

The NRC policy statement provides that those existing TS requirements which do not satisfy these four specified criteria may be relocated to licensee-controlled documents, such that future changes could be made to these provisions pursuant to 10 CFR 50.59 or by the regulatory requirements applicable to the licensee-controlled document. In accordance with TS Section 6.14, "Offsite Dose Calculation Manual (ODCM)," the ODCM is a licensee-controlled document and changes to the ODCM are subject to the regulatory requirements of TS Section 6.14 and 10 CFR 50.90. In accordance with LGS UFSAR Section 13.5.3 (Reference 1), the TRM is a licensee-controlled procedure described in the UFSAR and, therefore, changes to the TRM are subject to the requirements of 10 CFR 50.59. Accordingly, any future changes to Main Condenser Offgas Monitoring instruments and Main Condenser Explosive Gas Monitoring operability and surveillance requirements will be controlled by 10 CFR 50.59 or by the regulatory requirements applicable to the licensee-controlled document.

Additionally, the nuclear steam supply system owners' groups and the NRC staff developed improved Standard Technical Specifications (STS) that established models of the Commission's policy for each primary reactor type. The NRC issued the improved STS for General Electric BWR/4 plants as NUREG-1433, which was developed utilizing the guidance and criteria in the Commission's policy statement.

The changes requested by this amendment application, based on the criteria specified in the NRC Final Policy Statement, the requirements of 10 CFR 50.36 and the guidance provided in NUREG-1433, are described below.

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 3 of 13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes

1. TS Index, page x for LGS, Units 1 and 2, under Section 3/4.3.7, "Monitoring Instrumentation,"

will be revised to replace the title "Offgas Monitoring Instrumentation," Table 3.3.7.12-1 and Table 4.3.7.12-1 with words that state the information from pages 3/4 3-103 through 3/4 3-108 have been intentionally omitted and refers to a note added on page 3/4 3-103.

2. TS Index, page xvii for LGS, Units 1 and 2, under Section 3/4 11.2, "Gaseous Effluents," will be revised to replace the title "Explosive Gas Mixture" with words that state the information from page 3/4 11-15 has been intentionally omitted and refers to a note added on page 3/4 11-15.
3. TS Index xix for LGS, Units 1 and 2, under Bases Section 3/4 3.7, "Monitoring Instrumentation," will be revised to replace the title "Offgas Monitoring Instrumentation," with the word "(Deleted)."
4. TS Index xxiii for LGS, Units 1 and 2, under Bases Section 3/4.11.2, "Gaseous Effluents," will be revised to replace the title "Explosive Gas Mixture" with words that state the information from Bases page B 3/4 11-4 has been intentionally omitted and refers to a note added on page B 3/4 11-4.
5. TS Section 3.3.7.12, including Limiting Condition for Operation (LCO) 3.3.7.12, SR 4.3.7.12, Table 3.3.7.12-1 and Table 4.3.7.12-1, on TS pages 3/4 3-103 through 3/4 3-108, for LGS, Units 1 and 2, will be deleted in their entirety. Page 3/4 3-103 will indicate "Section 3/4.3.7 .12 (Deleted)," and will state the information from this TS section has been relocated to the ODCM and TRM and that the pages 3/4 3-104 through 3/4 3-108 have been intentionally omitted.
6. TS Section 3.11 .2.5, including LCO 3.11.2.5 and SR 4.11.2.5, on TS page 3/4 11-15, for LGS, Units 1 and 2, will be deleted in their entirety. Page 3/4 11-15 will indicate "Section 3/4.11.2.5 (Deleted)," and will state the information from this TS section has been relocated to the TRM .
7. TS Section 3.11 .2.6 on TS page 3/4 11-16 for LGS, Units 1 and 2, will be revised to replace the SR 4.11.2.6.1 text with the phrase "Relocated to the ODCM."
8. TS Section 3.11.2.6 on TS page 3/4 11-16 for LGS, Units 1 and 2, will be revised to change SR 4 .11.2.6.2.b to state the noble gas release rate is determined within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following a noted increase. The method for monitoring the release rate is being relocated to the ODCM as noted in SR 4.11 .2.6.1. This change is needed so the SR retained in TS is clear and consistent with the relocated requirements. The intent of the wording is consistent with the improved Standard Technical Specifications (Reference 3), Section 3.7.6, "Main Condenser Offgas," and the associated Bases.
9. TS Section 6.8, "Programs and Procedures," on page 6-14e, will be revised to add a new section 6.8.4.1, "Explosive Gas Monitoring Program ." This new program will include a limit for the concentration of hydrogen gas downstream of the offgas Recombiner and a surveillance to ensure the limit is maintained. The wording is consistent with the improved Standard Technical Specifications (Reference 3), Section 5.5.8, "Explosive Gas and Storage Tank Radioactivity Monitoring Program."

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 4of13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes The marked up pages that reflect the proposed changes are provided in Attachment 2 (TS pages) and Attachment 3 (TS Bases pages - information only). Prior to implementation of the amendment, relocated requirements for the Main Condenser Offgas Monitoring Instruments and Gaseous Effluents will be incorporated into the LGS ODCM and LGS TRM, as indicated above.

Any subsequent changes to the LGS ODCM will be performed in accordance with LGS TS Section 6.14, "Offsite Dose Calculation Manual (ODCM)," ODCM Section 6.4, "Changes to the ODCM," station procedures and 10 CFR 50.90. Any subsequent changes to the LGS TRM requirements will be performed in accordance with 10 CFR 50.59 and station procedures.

3.0 TECHNICAL EVALUATION

The proposed license amendment relocates the Main Condenser Offgas Monitoring Instruments and Gaseous Effluents operability and surveillance requirements from the LGS TS to the LGS ODCM and the LGS TRM. The ODCM is a licensee-controlled document with changes controlled in accordance with TS Section 6.14 and 10 CFR 50.90. In accordance with LGS UFSAR, Section 13.5.3, the TRM is a licensee-controlled document with changes controlled as a procedure described in the LGS UFSAR and, therefore, changes are subject to the requirements of 10 CFR 50.59. The ODCM and TRM have been used to capture and control other previously relocated TS requirements.

As discussed previously, the NRC concluded that those existing TS requirements which do not satisfy the screening criteria specified in 10 CFR 50.36 may be deleted from the TS, and the requirements established in licensee-controlled documents that are subject to the controls of 10 CFR 50.59 or another change control process governed by NRC change control requirements.

An assessment of the subject Main Condenser Offgas Radioactivity and Hydrogen Monitors and Main Condenser Explosive Gas Mixture concentration limits against the four criteria of 10 CFR 50.36 is provided below.

The primary function of the Main Condenser Offgas Radioactivity Monitors is to show conformance to the discharge limits of 10 CFR 20, "Standards for Protection Against Radiation."

This instrumentation is not installed to detect excessive reactor coolant leakage. The Main Condenser Offgas Radioactivity Monitors are used routinely to provide a continuous check on the release of radioactive gaseous effluents from the Main Condenser Steam Jet Air Ejector. These TSs require the licensee to maintain Operability of the Main Condenser Offgas Radioactivity Monitors and established setpoints. The alarm/trip setpoints are established to ensure that the alarm/trip will occur to prevent exceeding the limits of 10 CFR 20.

The non-safety related Main Condenser Offgas System is a gaseous radwaste removal system.

The Main Condenser Offgas Radioactivity Monitors measure the radioactivity in the Main Condenser Offgas effluent. Radioactivity levels are continuously indicated and recorded, and abnormal conditions are annunciated in the Main Control Room. The Main Condenser Offgas Radioactivity Monitors provide indication to the Control Room of radioactivity in the Main Condenser Offgas effluent. Increased radioactivity levels in the Main Condenser Offgas effluent may be an indication of fuel cladding deterioration that warrants further investigation. There are

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 5of13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes no automatic actions associated with Main Condenser Offgas Radioactivity Monitor design and the Main Condenser Offgas radioactivity levels are not used as assumptions in any accident analysis or transient analysis.

The non-safety-related Main Condenser Offgas Treatment System Explosive Gas Monitoring System Hydrogen Monitors provide indications to the Control Room of hydrogen gas concentration to confirm proper operation of Gaseous Radwaste Catalytic Hydrogen Recombiner and to detect a potentially flammable/explosive hydrogen gas concentration to allow operators to take appropriate action. The offgas hydrogen gas concentration values are not used as assumptions in any accident analysis or transient analysis. The Gaseous Radwaste Recombination System portion of the Offgas System and the Gaseous Radwaste Ambient Charcoal Treatment System are designed to withstand the effects of a hydrogen detonation without breach of the pressure boundary during startup, normal power operation, or shutdown. A new TS Section 6.8.4.1 is added to require that explosive gas concentration limits and associated surveillance program are maintained.

Criterion 1: Installed instrumentation that is used to detect. and indicate in the control room. a significant abnormal degradation of the reactor coolant pressure boundary.

This criterion addresses instrumentation installed to detect excessive reactor coolant system (RCS) leakage. LGS TS Sections 3.3.7.12, 3.11.2.5, SR 4.11.2.6.1 and 6.8.4.1 do not cover installed instrumentation that is used to detect and indicate in the control room, a significant degradation of the reactor coolant pressure boundary. The Main Condenser Offgas Radioactivity Monitors are used for operators to monitor Offgas radioactivity levels and initiate actions to investigate increases in radioactivity levels that may be related to fuel cladding deterioration. The Main Condenser Offgas Hydrogen Monitors are used for operators to monitor Offgas hydrogen concentration levels and initiate actions to avoid a potentially flammable/explosive hydrogen concentration in the offgas system. These instruments do not satisfy Criterion 1.

Criterion 2: A process variable. design feature. or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The purpose of this criterion is to capture those process variables that have initial values assumed in the design basis accident and transient analyses, and that are monitored and controlled during power operation. This criterion also includes active design features (e.g., high-pressure/low-pressure system valves and interlocks) and operating restrictions (pressure/temperature limits) needed to preclude unanalyzed accidents and transients.

The Main Condenser Offgas radioactivity level and hydrogen concentration are not process variables, design features, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. The OffGas Radioactivity Monitors provide indication

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 6of13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes of radioactivity in the Main Condenser Offgas effluent which may be an early indication of fuel cladding deterioration at levels well below those assumed in the accident and transient analysis. These instruments do not satisfy Criterion 2.

Criterion 3: A structure. system. or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The purpose of this criterion is to capture only those structures, systems, and components that are part of the primary success path of the safety analysis (an examination of the actions required to mitigate the consequences of the design basis accident and transients). The primary success path of a safety analysis consists of the combinations and sequences of equipment needed to operate so that the plant response to the design basis accident and the transients limits the consequences of these events to within the appropriate acceptance criteria. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function, but the criterion does not include backup and diverse equipment.

The Main Condenser Offgas Radioactivity and Hydrogen Monitors are not a structure, system, or component that is part of the primary success path whose function or actuation mitigates a design basis accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. Thus, the Main Condenser Offgas Radioactivity and Hydrogen Monitors do not satisfy Criterion 3.

The Main Condenser Offgas Radioactivity Monitors provide indication of radioactivity in the Main Condenser Offgas effluent and increases in radioactivity levels may be an early indication of fuel cladding deterioration at levels well below those assumed in the accident and transient analysis. Operators monitor this radioactivity level and initiate actions to investigate increases in radioactivity levels that may be related to fuel cladding deterioration.

There are no automatic actions associated with Main Condenser Offgas Radioactivity Monitor design and the Main Condenser Offgas radioactivity values are not used as assumptions in any accident analysis or transient analysis.

The Main Condenser Offgas Hydrogen Monitors provide indication of hydrogen concentration in the Main Condenser Offgas effluent which may be an early indication of increasing levels of explosive gases in the Offgas system. Operators monitor this hydrogen concentration level and initiate actions to address increases that may be related to degrading operation of the Gaseous Radwaste Recombination System. There are no automatic actions associated with Main Condenser Offgas Hydrogen Monitor design and the Offgas hydrogen concentration values are not used as assumptions in any accident analysis or transient analysis.

The Gaseous Radwaste Recombination System portion of the Offgas System and the Gaseous Radwaste Ambient Charcoal Treatment System are designed to withstand the effects of a hydrogen detonation without breach of the pressure boundary during startup, normal power operation, or shutdown. Therefore, an explosive mixture in the Offgas system piping would not result in a release of radioactive material from a breach of this system if a detonation would occur.

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 7of13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Criterion 4: A structure. system. or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The purpose of this criterion is to capture only those structures, systems, and components that operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The Main Condenser Offgas Radioactivity and Hydrogen Monitors are not a structure, system, or component that operating experience or probabilistic risk assessment has shown to be significant to public health and safety. This equipment is not covered by the Maintenance Rule (10 CFR 50.65) at LGS. In addition, a review of industry operating experience did not produce any examples where the failure of the Main Condenser Offgas Radioactivity or Hydrogen Monitors had a significant adverse effect on public health and safety. The Main Condenser Offgas Radioactivity and Hydrogen Monitors are not modeled in the LGS probabilistic risk assessment. Thus, the Main Condenser Offgas Radioactivity and Hydrogen Monitors do not meet Criterion 4.

The requirements contained in the TS Sections 3.3. 7 .12, 3.11.2.5 and TS SR 4.11.2.6.1 do not meet any of the 10 CFR 50.36(c)(2)(ii) criteria for items that must be in the TS. In addition, NUREG-1433 identifies improved TS that were developed based on the screening criteria in the "Final Commission Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors," that were subsequently codified in 10 CFR 50.36. NUREG-1433 does not contain any operability or surveillance requirements for the Main Condenser Offgas Monitoring instrumentation or for the Main Condenser Gaseous Effluents.

This amendment request includes the addition of a new TS Section 6.8.4.I to require that explosive gas concentration limits and associated surveillance program are maintained so as to provide consistency with NUREG 1433.

This amendment request includes a change to SR 4.11.2.6.2.b to state the noble gas release rate is determined within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following a noted increase. The method for monitoring the release rate is being relocated to the ODCM as noted in SR 4.11 .2.6.1. This change is needed so the SR retained in TS is clear and consistent with the relocated requirements. The intent of the proposed wording is consistent with the improved Standard Technical Specifications (Reference 3), Section 3.7.6, "Main Condenser Offgas," and the associated Bases. Operators will be able to identify changes in the noble gas release rate by monitoring the Main Condenser Offgas Radioactivity Monitor readings on the Control Room recorder, by responding to the radioactivity monitor alarm and by monitoring other increases in other plant parameters such as reactor coolant activity and Area Radiation Monitors.

As required by 10 CFR 50.36(c)(2)(ii) Criterion 2 and consistent with NUREG-1433, TS Section

3. 7 .6, the operability requirements for the Main Condenser Radiological Gaseous Effluent in LGS TS Section 3.11.2.6 and the SR 4.11.2.6.2 are retained in the TS for LGS Units 1 and 2.

The proposed changes do not alter the physical design of any plant structure, system, or component; therefore, the proposed changes have no adverse effect on plant operation, or the availability or operation of any accident mitigation equipment. The plant response to the design basis accidents does not change. The proposed changes do not require any new or unusual

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 8of13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes operator actions. The proposed changes do not introduce any new failure modes that could result in a new accident. There is no change being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes.

Therefore, the Main Condenser Offgas Monitoring Instruments and Gaseous Effluents operability and surveillance requirements may be relocated to the TRM .

TS Bases Sections B 3/4.3.7.12 and B 3/4.11.2.5 The TS Bases for the Main Condenser Offgas Monitoring Instrumentation (TS Section 3/4.3.7.12) associated with the noble gas activity monitor contained in TS Bases Sections B 3/4.3. 7.12, "Offgas Monitoring Instrumentation," will be relocated to the ODCM. The TS Bases for the Main Condenser Offgas Monitoring Instrumentation (TS Section 3/4.3.7.12) associated with the Main Condenser Offgas Hydrogen Monitor contained in TS Bases Sections B 3/4.3.7.12, "Offgas Monitoring Instrumentation," will be relocated to the TRM. The Main Condenser Explosive Gas Mixture (TS Section 3/4.11.2.5) contained in TS Bases B 3/4.11 .2.5, "Explosive Gas Mixture," will be relocated to the TRM. The changes to the ODCM and the TRM will be made to reflect the proposed changes to the respective TS. The marked up TS Bases pages that reflect the proposed changes are provided in Attachment 3 for information purposes only.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The NRC provided guidance for the contents of TS in its "Final Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors" (58 FR 39132, July 22, 1993). In particular, the NRC indicated that certain items could be relocated from the TS to licensee-controlled documents, and identified criteria to be used to determine the functions to be included in the TS. The NRC adopted revisions to 10 CFR 50.36 to codify and incorporate these criteria.

Section 50.36c(2)(ii) of Title 10 of the Code of Federal Regulations (10 CFR 50.36c(2)(ii))

contains the requirements for items that must be in TS. This regulation provides the four criteria that can be used to determine the requirements that must be included in the TS .

A TS limiting condition for operation (LCO) of a nuclear reactor must be established for each item meeting one or more of the following criteria:

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 9of13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4: A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Items not meeting any of these four criteria can be relocated from the TS to a licensee-controlled document. The licensee can then change the relocated requirements, if necessary, in accordance with 10 CFR 50.59 or by the regulatory requirements applicable to the licensee-controlled document.

The NRC published improved Standard Technical Specifications in NUREG-1433. The TS requirements proposed for relocation do not meet the four screening criteria, and therefore, are not included in NUREG-1433. The relocation of these TS requirements are also consistent with the guidance in NRC Generic Letter 89-01, regarding relocation of radiological effluent TS (Reference 9), and NUREG-1302, regarding the standards for the ODCM (Reference 10). Operability and surveillance requirements for the Main Condenser Offgas Monitoring Instrumentation and Gaseous Effluents limits will be maintained in licensee-controlled documents (i.e., the LGS ODCM and TRM), such that future changes could be made to these provisions pursuant to 10 CFR 50.59 or by the regulatory requirements applicable to the licensee-controlled document.

4.2 Precedence A similar change, to relocate the operability and surveillance requirements for the Main Condenser Offgas Radioactivity Monitors from TS to a licensee-controlled document, was approved by the NRC by issuance of Amendment No. 274 for James A. FitzPatrick Nuclear Power Plant by letter dated July 3, 2002 (Reference 7).

A similar change, to relocate the operability and surveillance requirements for the Main Condenser Offgas Gaseous Effluents limits from the LGS TS to the TRM and create a new Explosive Gas Monitoring Program specified in the Procedures and Program Section of TS, was approved by the NRC by issuance of Amendment Nos. 147 and 133 for LaSalle County Station, Units 1 and 2, respectively, by letter dated March 30, 2001 (Reference 8).

Both changes are consistent with the improved Standard Technical Specifications issued by the NRC in NUREG-1433 (Reference 3).

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 10of13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes 4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of the Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS),

Units 1 and 2, respectively.

The proposed changes relocate certain operability and surveillance requirements for the Main Condenser Offgas Monitoring Instrumentation and Gaseous Effluents limits from the LGS TS to a licensee-controlled document. An Explosive Gas Monitoring Program is proposed to be added to the Administrative Section of the TS. This new program will include a limit for the concentration of hydrogen downstream of the offgas Recombiner and a surveillance to ensure the limit is maintained. The proposed changes conform to the requirements of 10 CFR 50.36, "Technical specifications," for the contents of TS, and are consistent with the improved Standard Technical Specifications issued by the NRC in NUREG-1433, "Standard Technical Specifications - General Electric BWR/4 Plants."

Exelon has evaluated the proposed changes, using the criteria in 10 CFR 50.92, "Issuance of amendment," and has determined that the proposed changes do not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

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

Response: No The proposed changes relocate certain operability and surveillance requirements for the Main Condenser Offgas Monitoring Instrumentation and Gaseous Effluents limits from the Limerick Generating Station (LGS) Technical Specifications (TS) to a licensee-controlled document under the control of 10 CFR 50.59 or under the control of regulatory requirements applicable to the licensee-controlled document.

A new TS Administrative Program is proposed to be added to ensure the limit for Main Condenser Offgas hydrogen concentration is maintained.

The proposed changes do not alter the physical design of any plant structure, system, or component; therefore, the proposed changes have no adverse effect on plant operation, or the availability or operation of any accident mitigation equipment. The plant response to the design basis accidents does not change.

Operation or failure of the Main Condenser Offgas Radioactivity and Hydrogen Monitors capability are not assumed to be an initiator of any analyzed event in the Updated Final Safety Analysis Report (UFSAR) and cannot cause an accident.

Whether the requirements for the Main Condenser Offgas Radioactivity and Hydrogen Monitor capability are located in TS or another licensee-controlled document has no effect on the probability or consequences of any accident previously evaluated.

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 11 of 13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes The proposed changes conform to NRC regulatory requirements regarding the content of plant TS as identified in 10 CFR 50.36, and also the guidance as approved by the NRC in NUREG-1433, "Standard Technical Specifications-General Electric BWR/4 Plants."

Therefore, the proposed changes do 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 changes relocate certain operability and surveillance requirements for the Main Condenser Offgas Monitoring Instrumentation and Gaseous Effluents limits from the LGS TS to a licensee-controlled document under the control of 10 CFR 50.59 or under the control of regulatory requirements applicable to the licensee-controlled document. A new TS Administrative Program is proposed to be added to ensure the limit for Main Condenser Offgas hydrogen concentration is maintained.

The proposed changes do not alter the plant configuration (no new or different type of equipment is being installed) or require any new or unusual operator actions. The proposed changes do not alter the safety limits or safety analysis assumptions associated with the operation of the plant. The proposed changes do not introduce any new failure modes that could result in a new accident. The proposed changes do not reduce or adversely affect the capabilities of any plant structure, system, or component in the performance of their safety function.

Also, the response of the plant and the operators following the design basis accidents is unaffected by the proposed changes.

Therefore, the proposed changes do 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 changes relocate certain operability and surveillance requirements for the Main Condenser Offgas Monitoring Instrumentation and Gaseous Effluents limits from the LGS TS to a licensee-controlled document under the control of 10 CFR 50.59 or under the control of regulatory requirements applicable to the licensee-controlled document. A new TS Administrative Program is proposed to be added to ensure the limit for the Main Condenser Offgas hydrogen concentration is maintained. The relocated TS requirements do not meet any of the 10 CFR 50.36c(2)(ii) criteria on items for which a TS must be established .

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 12of13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes The proposed changes have no adverse effect on plant operation, or the availability or operation of any accident mitigation equipment. The plant response to the design basis accidents does not change. The proposed changes do not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses. There is no change being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above evaluation, Exelon concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (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

Exelon 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, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review,"

paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Limerick Generating Station, Updated Final Safety Analysis Report, Section 13.5.3, "Operations Technical Requirements Manual (TRM)."
2. 10 CFR 50.36, 'Technical Specifications."

License Amendment Request Attachment 1 Main Condenser Offgas Monitoring Instrumentation Page 13of13 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes

3. NUREG-1433, "Standard Technical Specifications-General Electric BWR/4 Plants,"

Revision 4.0, dated April 2012.

4. NRC "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," 58 FR 39132, dated July 22, 1993.
5. NRC Final Rule, 10 CFR 50.36, "Technical Specifications," 60 FR 36953 (July 19, 1995).
6. Limerick Generating Station, Offsite Dose Calculation Manual, CY-LG-170-301.
7. Letter dated July 3, 2002, from G. S. Vissing (USNRC) to M. Kansler (Entergy),

"James A. FitzPatrick Nuclear Power Plant - Amendment RE: Conversion to Improved Technical Specifications (TAC No. MA5049)," (ADAMS Accession No. ML021620504, Amendment 274).

8. Letter dated March 30, 2001, from S. N. Bailey (USNRC) to 0 . D. Kingsley (Exelon),

LaSalle "Issuance of Amendments (TAC Nos. MA8388 and MA8390)," (ADAMS Accession No. MLO 11130202, Amendments 147/133).

9. NRC Generic Letter 89-01, "Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program (Generic Letter 89-01)," dated January 31, 1989.
10. NUREG-1302, "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors, Generic Letter 89-01, Supplement No.

1," dated April 1991.

ATTACHMENT 2 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Changes to the Main Condenser Offgas Monitoring Instrumentation Technical Specifications Markup of Proposed Technical Specifications Pages Unit 1 TS Pages x

xvii xix xxiii 3/4 3-103 3/4 3-104 3/4 3-105 3/4 3-106 3/4 3-107 3/4 3-108 3/4 11-15 3/411-16 6-14e Unit 2 TS Pages x

xvii xix xxiii 3/4 3-103 3/4 3-104 3/4 3-105 3/4 3-106 3/4 3-107 3/4 3-108 3/4 11-15 3/411-16 6-14e

LIMITING CONDITIONS FOR OPERATION AND SlJRVEII lANCE REQUIREMENTS SECTION INSTRUMENTATION (Continued)

(Deleted) ...................................................... 3/4 3-97 The information from pages 3/4 3-98 through 3/4 3-101 has been intentionally omitted . Refer to note on page 3/4 3-98 ....................... 3/4 3-98 Offgas MoRitoriR§ lRstn.1F11eRtation .............................. 3/4 3-103 lRstrumeRtatien .................... 31 4 3 104 Menitoring lnstruFRentatieR Survei 11 ance Requi refflents ..................... 3/4 3 107 3/4.3.8 (Deleted) The information on pages 3/4 3-110 and 3/4 3-111 has been intentionally omitted.

Refer to note on page 3/4 3-110 ............... 3/4 3-110 3/4.3.9 FEEDWATER/MAIN TURBINE TRIP SYSTEM ACTUATION INSTRUMENTATION ........................................... 3/4 3-112 able 3.3.9-1 Feedwater/Main Turbine Trip System Actuation Instrumentation .............. 3/4 3-113 able 3.3.9-2 Feedwater/Main Turbine Trip System Actuation Instrumen-tation Setpoints .. ............................ 3/4 3-114 able 4.3.9.1-1 (Deleted) ..................................... 3/4 3-115

/4.4 3/4.4.1 RECIRCULATION SYSTEM R circulation Loops ..... . ....................................... 3/4 4-1 The information from pages 3/4 3-103 through 3/4 3-108 has been intentionally omitted . Refer to note on page 3/4 3-103.

LIMERICK - UNIT 1 x Amendment No. 4g, ~. -+/-J.+/-., ~. 186

LIMITING CONDITIONS FOR OPERATION AND SLJRVEILlANCE REQUIREMENTS SECTION RADIOACTIVE EFFLUENTS (Continued)

E:x13 l es i vc Gas Mixture ...................................... 3/4 11-15 I~

~ ai n Condenser ............................................. 3/4 11-16 The information on page 3/4 11-17 has been intentionally omitted. Refer to note on this page ... . .... . ................. . ... . ................... 3/4 11-17 3/4.11.3 (Deleted) The information on pages 3/4 11-18 through 3/4 11-20 has been intentionally omitted. Refer to note on page 3/4 11-18.

3/4.11.4 (Deleted) .................................................. 3/4 11-18 3/4.12 (Deleted) The information on pages 3/4 12-1 through 3/4 12-14 has been intentionally omitted.

Refer to note on page 3/4 12-1 ................... 3/4 12-1

-The information from page 3/4 11-15 has been intentionally omitted . Refer to note paQe 3/4 11-15.

LIMERICK - UNIT 1 xvii Amendment No. 48 I

SECTION INSTRUMENTATION (Continued)

(Deleted) .................................................. B 3/4 3-5 (Deleted) .... . ............. . ........ . ... . .................. B 3/4 3-5 Remote Shutdown System Instrumentation and Controls ........ B 3/4 3-5 Accident Monitoring Instrumentation . . ........ .. ............ B 3/4 3-5 Source Range Monitors ............... . ...................... B 3/4 3-5 (Deleted) .................................................. B 3/4 3-6 Chlorine and Toxic Gas Detection Systems ................... B 3/4 3-6 (Deleted) (Deleted) .... . ............................................. B 3/4 3-6 (Deleted) .................................................. B 3/4 3-7

.*.*...**.*.*........**..**.*.*...**...**..**...** B 3/4 3- 7 3/4.3.8 (Deleted) ......................................... . ........ B 3/4 3-7 3/4.3.9 FEEDWATER/MAIN TURBINE TRIP SYSTEM ACTUATION INSTRUMENTATION ............................................ B 3/4 3- 7 Bases Figure B 3/4. 3-1 Reactor Vessel Water Level .................. . .... B 3/4 3-8 3/4.4 REACTOR COOLANT SYSTEM 3/4.4.1 RECIRCULATION SYSTEM ....................................... B 3/4 4-1 3/4.4.2 SAFETY/RELIEF VALVES ....................................... B 3/4 4-2 3/4.4.3 REACTOR COOLANT SYSTEM LEAKAGE Leakage Detection Systems .................................. B 3/4 4-3 Operational Leakage ........................................ B 3/4 4-3 3/4.4.4 CHEMISTRY ........................ . ......................... B 3/4 4-3 LIMERICK - UNIT 1 xix Amendment No. 48, ~ * .&g, 9,

-+/--04' -+/--+/-+' +/-J-+/-' 153

SECTION RADIOACTIVE EFFLUENTS (Continued) j(Deleted)

Main er .................................... . ..... B 3/4 11-5

.............................................. B 3/ 4 11- 5 3/4. 11.4 (Deleted ............................................... B 3/4 11-5 3/4.12 The information from pages B 3/4 12-1 through B 3/4 12-2 has been inten-tionally omitted. Refer to note on page B 3/4 12-1 .............................. B 3/4 12-1 The information from page B 3/4 11-4 has been intentionally omitted. Refer to note on page B 3/4 11-4.

LIMERICK - UNIT 1 xxiii Amendment No. 48 I

INSTRllMENTATION ~<:._--------ilsection 3/4.3. 7 .1 2 (Deleted)

OFFGAS GAS MONITORING INSTRYMENTATION

3. 3. 7 .12 The off gas mo Ai tori Ag i Ast r1::1111eAtatieA cha AR els showA i A Taal e 3 . 3.7.12 1 shall ee OPERABLE with their alarm/trip setpoiRts set to eRs1::1re that the limits of SpecificatioRs 3.11.2.S aRcl 3.11.2.6 respectively, are Rot e>Eceeeleel.

APPL I CAB! LIT¥: As showA i R Table 3. 3. 7 .12 1 ACTION:

'3-T With aR offgas moAitoriAg iRstr1::1meRtatioR chaARel alarm/trip setpoiRt less coRservative thaA req1::1ireEI by the above S13ecifieatioA, cleclare the chaARel iReperable, aAEI tal<e the ACTION showR iR Table 3.3.7.12 1.

&... With less thaR the miRim1::1m R1::1meer of offgas moRitoriAg i Rst r1::1meAtati OR chaRRel s OPERABLE, tal(e the ACTION shewR i A Tael e

3. 3' 7 .12 1. Restore the i Ro19erable i RStr1::1meRtatioR to OPERABLE stat1:1s wi thi A tl:ie ti ffle s19eci fi ecl i A the ACTION or e>(J91 ai A why this iRoperability was Rot eorreetea iR a timely maRAeF iR the Ae)(t ARR1::1al Raai oacti ve Effl 1::1cRt Rel case Report.

-c-:- The provisioRs of SpecificatioR 3.Q.3 arc Rot applicaele.

4.3.7.12 Each offgas fflORitoriRg iRstr1::1meRtatioR chaRRCl shall be elemeAstrateEI OPERABLE ey performaRce of the CHANNEL CHECK, SOURCE CHECK, CHA.~NEL CALIBRATION, aREI CHANNEL FUNCTIONAL TEST 013erati0Rs at the freq1:JeReies specifieEI iA the S1::1r¥eillaRce Freq1::1eRey CoRtrol Program 1:1Aless othePwise AoteEI iA Taele 4.3.7.12 1.

11\

THE INFORMATION FROM THIS TECHNICAL SPECIFICATIONS SECTION HAS BEEN RELOCATED TO THE ODCM AND THE TRM . TECHNICAL SPECIFICATIONS PAGES 3/4 3-104 THROUGH 3/4 3-108 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITTED .

LIMERICK - UNIT 1 3/4 3-103 Amendment No. 4-8, B-3:, -!69, 186

IABu; a.3.z.12 i GFEGAS MlilNfFGRHlG INSJRYMEPffAUQ!l MINIMIJM CMANN!i.LS INSIRYMEN+/- OPERABLE APPLlCft.BILIIY

~  !'AIN CQN9ENSE:R QFFGAS TBE:A=P1E!R' S¥5T91 E:XPLQSPJE GAS MQNIT9RING S¥STe1 a... UyllF9!10R MeRi ter

~ (9eletee)

~ (Qeleted) 4-.,- ~IN CQNQENSE:R QFFGAS PRE TR~li.N+/-

RAfHQAffiVIT¥ MQNIWA a-.,. !lelll e Gas Aeti vi ty lleRi ter

.;.... (9e1 etee)

LI!IERICK lmIT 1 3/4 3 194 AnleRd111e11t Ne . ~3 , 48

TABLE 3.3.7.12 1 (CeAtiAt:1eel)

TABLE NOTATIONS is. (Del etea)

.xx Dt:1FiRg er:ieratieA ef the maiA eoReleAseF steam jet aiF ejeeter aAel effgas treatmeAt system.

AU (Qel etea)

ACTION STATEMENTS ACTION 110 WitR tRe At:1mber ef ERaAAels OPERABLE less thaA req1;1irea by tRe MiAim1;1m CRaAAels OPERABLE req1;1iremeAt, or:ieratieA ef maiR eoRaeAser effgas treatmeRt system may e0RtiA1;1e for 1;1~ to 30 says r:ireviaea grab sam,:iles aFe eelleetea at least eAee per 4 ROt:IFS aRel aRalyzeel v:ithiA the fellewiAg 4 he1;1rs.

ACTION 111 114 (Del etea)

ACTION HS With die Rt:1meer ef ehaAAels OPERABLE less thaR req1;1i red by die Mi Aim1;1m ChaRRel s OPERABLE req1;1i remeAt, rel eases to tRe eAviroRmeRt may eoRtiA1;1e fer t:lf'J te 72 he1;1rs r:irevielea that the North Stael< Efflt:1eRt Noele Gas Aeti¥ity MoRitor is OPERABLE; otherwise, be i A at 1east HOT SHl:JTOO'.vN wi thi A 12 ho1;1rs.

LIMERICK l:JNIT 1 3/4 3 105 AmeAelmeRt Ne. 48 I

INUNTIONALLY LEFT BLANK LIMERICK UNIT 1 3/4 3 106 AmeAaffleAt No. 48 I

TABLE 4,3.z.12 1 QFFGAS MQllHQRUIG UISTRV.mr+AHQN SVIWEILLANCE REQVIRetmi:rs

~ MQgg IN WHICH

~ ~ ~ FYNCTIQNAL SYRVEILL:MlCE INSJBV~mff CHECK(S) CHECKCS) CALIBMTIQNCSl iliFf-0 IS REO\IIREE>

~ MAIN CQ~lQ~SER QFFGA.S TREA'ENT

$¥STEM ~PLQS!IJE CA5 MQNITQRING

~

a. HysFegeR MeRiteF

~ (Deletes)

~ (Deletes)

+.- MAIN CQNDENSER OFFGAS

~E TREA+MEPIT RAEJIOACTIVTIY MQNITQR (5+EA'4 JET AIR

[)[CTQR) a... Pleele gas activity 111eRiteF h (EleleteEl)

LIMERJCK YNIT l 3/4 3 1Q7 Al!!eRElllleRt Ne, -48, 186

TABLE 4.3.7.12 1 (CeRtiRued)

TABLE: NOTATIONS (Oeletea)

DuFing epeFatieR ef the maiR ceRdeAseF steam jet aiF ejeeter aAd effgas treatmeAt system.

(Deleteel)

The CHANNEL Fl:J~lmONAL TEST shal 1 al se demeAstra~e _that c~ntFel ream al aFm aRRuReiatioR occurs if aRy of the followiRg e0Rd1t10Rs eM1st:

IRstrumeRt i Reii eates 111easu reei 1evel s aee\le the a1, armrtn I

  • P set ,:Jo1* A t
  • Circuit failure.

IRstrumeRt indicates a dewAscale fai l ure .

IAstrumeAt eeAtrels Rat set iA eperate mode .

The initial CHANNEL CALIBRATION shall be perfermed.usiAg eAe or mere of the FefeFence standards certified ey the Natienal !Ast1t1::1te ef StaRdards .

and Teel=lnelegy (NIST) , previ01:Jsly NatioRal B1:Jreau ef StaRd~r~s, or .1:Js1Ag staAdaFds tl=lat l=lave beeR obtained ff'om Sl:!ppliers tl=lat part1c1pate in .

measuFemeRt assuFaAce acti>.*ities with NIST. These staRdarels shall per1111t eali erati Ag the system over its i RteAdes raRge of energy aRd 111eas1::1remeRt raRge. For subseEfl:JCRt CHANNEL CALIBRATION, SOl:!FCes that ha>re beeA relates to the iRitial calibratioA shall be uses.

Tl=le CMA."JNEL CALIBRATION sl:!al l iAeh1se the 1:1se ef staAdarel gas sam13l es EORtaiRiRg a AOllliAal:

+/---,. O.O volume perceAt hydrogeA , balaAee AitrogeA, aAel ih- 4 vol 1:Jme perceRt hyei FogeA, eal ance Ai trogeA (Del eteei)

Freeiuencies are speeifiea in tl:!e SurveillaRee Frequency CeRtrol Program uR1ess otherwise Roteel in tl'le table.

LIMERICK UNIT 1 3/4 3 108 Amenelment Ne. -48 , 186

RADIOACTIVE EFFLUENTS ~<----,jsection 3/4 .11 .2.5 (Deleted)'

EXPLOSIVE GAS MIXTURE LIMITING CONDITION fOB OPERATION

3. 11.2 .§ The conceAtFatioR of hyare§eR iA the maiR coAaeAser off§as treatmeAt system shall ee limited to less thaA er e~~al to 4% ey vol~me .

APPLICABILITY: WheAever the maiA coAdeAser aiF ejectoF system is iA o~eratioA .

ACTION:

-a-:- Witl'l the COACeAtFatioA of hyElro§eA iA the maiA CoAeleRser Off§aS tFeatmcAt system e>(eeediA§ the limit, restore the coAceAtratioA to witRiA the limit withiR 48 ho~rs .

9-:-- Tl'le ~rovisioAs of S~ecificatioA 3 . 0. 3 are Aot applicaele.

4.11 .2.S The COACeRtratieA of AYSFO§eR iA tRe maiA C9R el eRSeF off§aS treatmeAt system sh all be aetermiAee to ee withiA the aeeve limits ey coAtiR~o~sly moAitorin§ tRe waste §ases iA tRe maiA coAEleAser off§as treatmeAt system witR the hydFO§CA ffiORitOFS re~~iFeEl OPERABLE ~y Taele 3. 3.7. 12 1 of SpecificatioA 3.3. 7. 12 .

THE INFORMATION FROM THIS TECHNICAL SPECIFICATIONS SECTION HAS BEEN RELOCATED TO THE TRM .

LIMERICK - UNIT 1 3/4 11-15 Amendment No. 11 I

RADIOACTIVE EFFLUENTS MAIN CONDENSER LIMITING CONDITION FOR OPERATION 3.11.2.6 The rate of the sum of the activities of the noble gases Kr-85m, Kr -87, Kr-88, Xe-133, Xe-135, and Xe-138 measured at the recombiner after-condenser discharge shall be limited to less than or equal to 330 millicuries/second.

APPLICABILITY: OPERATIONAL CONDITIONS l, 2*, and 3*.

ACTION:

With the rate of the sum of the activities of the specified noble gases at the recombiner after-condenser discharge exceeding 330 millicuries/second, restore the gross radioactivity rate to within its limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SURVEILLANCE REQUIREMENTS

4. 11 . 2. 6. 1 T~.-~-=-10-sc-~:-t-~-~-t~-l'-l:h_e_ac-~-~-vC-it-~-~-s-of---.Jel e gases at tf:~e recoffibiAer after coAdeAser discharge shall ee coAtiAo~sly moAitored iA accor daAce with S~ecificatioR 3.3.7.12.

4.11.2.6.2 The rate of the sum of the activities of the specified noble gases from the recombiner after-condenser discharge shall be determined to be within the limits of Specification 3.11.2.6 at the following frequencies by performing an isotopic analysis of a representative sample of gases taken at the recombiner after condenser discharge:

noted

a. In accordance with the Surveill
b. Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following aft ncrease, as iRdicated ey the MaiR CoAdeRser Off Gas PretreatffieAt Radioactivity MoAitor, of greater than 50%, after factoring out increases due to changes in THERMAL POWER level or air in -leakage, in the nominal steady-state fission gas release from the primary coolant.
c. The provisions of Specification 4.0.4 are not applicable.

LIMERICK - UNIT 1 3/4 11-16 Amendment No. 186

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

c. The program shall, as allowed by 10 CFR 50.55a, meet Subsection !STA, "General Requirements," and Subsection !STD, "Preservice and lnservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," in lieu of Section XI of the ASME B&PV Code !SI requirements for snubbers, or meet authorized alternatives pursuant to 10 CFR 50.55a.
d. The 120-month program updates shall be made in accordance with 10 CFR 50.55a subject to the limitations and conditions listed therein.

Explosive Gas Monitoring Program This program provides controls for potentially explosive gas mixtures contained downstream of the off-gas recombiners .

The program shall include:

a. The limit for the concentration of hydrogen downstream of the offgas recombiners and a surveillance program to ensure the limit is maintained. This limit shall be appropriate to the system's design criteria {i.e .. whether or not the system is designed to withstand a hydrogen explosion);

The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Explosive Gas Monitoring Program surveillance frequencies.

LIMERICK - UNIT 1 6-14e Amendment No. 223

LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE INSTRUMENTATION (Continued)

C Deleted) ........................................................ 3/4 3-97 The information from pages 3/4 3-98 through 3/4 3-101 has been intentionally omitted. Refer to note on page 3/4 3-98 ......................... 3/4 3-98 Off§as IRstrl:lfRCAtati BA ................................. 3;q 3 104 3 107 3/4.3.8 ( The information on pages 3/4 3-110 and 3/4 3-111 has been intentionally omitted.

Refer to note on page 3/4 3-110 ...................... 3/4 3-110 3/4.3.9 FEEDWATER/MAIN TURBINE TRIP SYSTEM ACTUATION INSTRUMENTATION ........................................... 3/4 3-112 3.3.9-1 Feedwater/Main Turbine Trip System Actuation Instrumentation ............... 3/4 3-113 3.3.9-2 Feedwater/Main Turbine Trip System Actuation Instrumen-tation Setpoints ............................... 3/4 3-114 (Deleted) ...................................... 3/4 3-115 3/ .4 3/4.4.1 RECIRCULATION SYSTEM Re irculation Loops .............................................. 3/4 4-1 he information from pages 3/4 3-103 through 3/4 3-108 has been intentionally omitted . Refer o note on page 3/4 3-103.

LIMERICK - UNIT 2 x Amendment No. -!-+/-, .&4, ~. -+/--+/-+, 147

LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION RADIOACTIVE EFFLUENTS (Continued)

E°><J'llosive Gas Mi>(tt*ffe ........................................ 3/4 11-15 I\

~ ain Condenser ............................................... 3/4 11-16 The information on page 3/4 11-17 has been intentionally omitted. Refer to note on this page ................................................... 3/4 11-17 3/4.11.3 I Deleted) The information on pages 3/4 11-18 through 3/4 11-20 has been intentionally omitted.

Refer to note on page 3/4 11-18.

3/4.11.4 10eleted) ................................................... 3/4 11-18 3/4.12 10eleted) The information on pages 3/4 12-1 through 3/4 12-14 has been intentionally omitted.

Refer to note on page 3/4 12-1 ..................... 3/4 12-1

~The information from page 3/4 11-15 has been intentionally omitted. Refer to note on paqe 3/4 11-15.

LIMERICK - UNIT 2 xvii Amendment No. 11

SECTION INSTRUMENTATION (Continued)

(Deleted) .................................................. B 3/4 3-5 (Deleted) .................................................. B 3/4 3-5 Remote Shutdown System Instrumentation and Controls ........ B 3/4 3-5 Accident Monitoring Instrumentation ........................ B 3/4 3-5 Source Range Monitors ...................................... B 3/4 3-5 (Deleted) .................................................. B 3/4 3-6 Chlorine and Toxic Gas Detection Systems ............. . ..... B 3/4 3-6 (Deleted) (Deleted) .................................................. B 3/4 3-6 (Deleted) .................................................. B 3/4 3-7 (Deleted) .................................................. B 3/4 3-7 3/4.3.8 (Deleted) .................................................. B 3/4 3-7 3/4.3.9 FEEDWATER/MAIN TURBINE TRIP SYSTEM ACTUATION INSTRUMENTATION ............................................ B 3/4 3- 7 Bases Figure B 3/4.3-1 Reactor Vessel Water Level ........................ B 3/4 3-8 3/4.4 REACTOR COOLANT SYSTEM 3/4.4.1 RECIRCULATION SYSTEM ....................................... B 3/4 4-1 3/4.4.2 SAFETY/RELIEF VALVES ....................................... B 3/4 4-2 3/4.4.3 REACTOR COOLANT SYSTEM LEAKAGE Leakage Detection Systems .................................. B 3/4 4-3 Operational Leakage .............................. . ......... B 3/4 4-3 3/4.4.4 CHEMISTRY .................................................. B 3/4 4-3a LIMERICK - UNIT 2 xi x Amendment No. -+/--+/--, ~. +7, ~.

Ja, ~. 9, ~. 117

SECTION RADIOACTIVE EFFLUENTS (Continued) j(Deleted) i---7-:? ~xplesive Gas Mixt1:1re ................................... B 3/4 11-4 Main Conde ser .......................................... B 3/4 11-5 (Deleted) ............................................... B 3/4 11-5 3/4.11.3 ................*.*.............*............** B 3/4 11-5 3/4.11.4 ******...**.....*...***..***...**..*.**...***.* B 3/4 11-5 3/4.12 The information from pages B 3/4 12-1 through B 3/4 12-2 has been intentionally omitted. Refer to note on page B 3/4 12-1 ................. . ................. B 3/4 12-1 The information from page B 3/4 11-4 has been intentionally omitted . Refer to note on page B 3/4 11-4.

LIMERICK - UNIT 2 xxiii Amendment No. 11 I

INSTRUMENTATION ~<------------1lsection 3/4.3.7 .12 (Deleted)

OFFGAS GAS MONITORING INSTRl;JMENTATION

3. 3. 7 .12 The effgas R10Ai ta Fi Rg i Rstn1R1eRtati eR ehaRRel s sheh'R i R Tael e 3. 3. 7 .12 1 shall be OPERABLE with theiF alaPlll/tFip setpeiRtS set te eRS1:1Pe that the li111its of Speeifi eati eRs 3 .11. 2 . 5 aRa 3 .11. 2 . 6 respectit.*el y, are Rot e)(ceeaea.

APPLICABILil¥: As shewR iR Taele 3.3.7.12 1 ACTION:

a-:- With aA offgas IR0Ri ta Fi A§ i RStFl:llReRtati OA ehaRAel al aFRl/tri p setpei At 1ess eoRservati *1e thaA Feei1:1i red ey tf:ie al:Jove Speci fi eati oR, declare the ehaRRel iAeperal:Jle, aRd take tf:ie ACTION showA iA Taele

3. 3 ,7 .12 1.

&-... With less thaR the miRi1R1:1111 A1:1111eeF ef offgas meRitoriRg iAstr1:1meRtatioR ehaARel s OPERABLE, tal(e tf::le ACTION sf::lewA i A Taal e 3, 3. 7 .12 1. Restere the iAepeFaele iAstr1:11ReAtati0A to OPERABLE stat1:1s withiA t"1e time speei fi ea i A the ACTION eF e)(pl ai n why tf:ii s i Aoperaei li ty was net eorreetea i A a tifflely FRaAAer i A tf::le Re)(t AAR1:1al Raai eaetive Effl1:1eRt Release RepoFt.

-e. The provi si eRs of Speei fi eati oR 3. Q. 3 are Rot appli eael e, 4.3.7.12 Eacf::l offgas fflORiteriAg iRStf'l:lffleRtatiOR chaRRel shall ee aemeAStPatea OPERABLE by peFforFRaRee of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, aAEf CHANNEL FUNCTIONAL TEST opeFatiORS at the freei1:1eRcies speeifieel iR the S1:1FveillaRee FFeei1:1eRcy CeRtrel Program 1:1Rless otheFWise Roted iR Taele 4.3.7.12 1.

THE INFORMATION FROM THIS TECHNICAL SPECIFICATIONS SECTION HAS BEEN RELOCATED TO THE ODCM AND THE TRM. TECHNICAL SPECIFICATIONS PAGES 3/4 3-104 THROUGH 3/4 3-108 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITIED.

LIMERICK - UNIT 2 3/4 3-103 Amendment No. -ii:, 92, -13r, 147

TABLE 3'3 , 7.12 1 QEEGAS MQNH'.QRING INSTRYMENTATION MINJMl:ltl CHANNELS INSH!llMEN+ QPEAABLE

~ AAIN CQNQENStR QEEGAS TREA:i:Jl9ff SVSTt~I EXPLOSIVE CAS MQNIT-ORING SVSTB4

~ (Qeletee)

~ (Qe1etefl) 4-r AAIN C.QNQE~ISER Q~EGAS PRE TR~tNT RAQIQACTIVIlY ~4Q~IUOR a-.- Neale Gas Aetivity MeniteF h (Qeletefl) llMERICJ< YNIT 2 3/4 3 194 ARlenElMeRt Ne. 11 I

TABLE 3.3.7 .12 1 (CoAtiAued)

TABLE NOTATIONS x (Elel etee)

k.:k. OuFiAg epeFatieA of tRe maiA eeAeeAseF steam jet aiF ejecteF aAe effgas trcatmeAt system.

u.x. (Elel eteel)

ACIION STATEMENTS ACTION 110 WitR tRe AUmBeF ef chaAAels OPERA8LE less tRaA Peetuired ey tRe MiAimum ChaAAels OPERABLE reeiuiremeAt, operatieA of maiA eeAtkAser effgas treatmeAt system may eoAti Aue fer up to 30 elays pre>ri eed grae samples are cell eetee at 1east eRce per 4 k01:1FS aAEI aRalyzed withiA the fellewiAg 4 he1:1rs.

ACTION 111 114 (Deleted)

ACTION 115 '/Ji th tl:ie Al:lmBe F of dlaRRel s OPERABLE 1ess tAaR reeiui red B'.)'

the ~4i Ailtn,1111 ChaARel s OPERABLE reeiui remeAt , rel eases te the eAvi reRmeAt may eeAti Aue fop up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> pFevi eleel that the North Staci< Effh1eAt Neel e Gas Aeti vi ty MoRi tor is OPE:RABLE; etheFwi se, ee i A at 1east HOT SHblTQOWN wi tl=li A 12 lieUPS.

LIMERICK YNIT 2 3/4 3 lOS AmeRdmeRt No . 11 I

INTE:NTIONALLY LE:FT BLANK LIMERICK ~NIT 2 3/4 3 106 AmeAameAt Ne. 11 I

TABLE 4.3.7.12 l Ol=FGAS MQ'IIIQRING HJSJBl!fml+A+HlN SllR\'HLLMJCE REOllIRE,~EPJ:rS fHANNCt MOGES IN WHICH

~ ~ QWINQ,, RINGIO~L SllRVEH:LNjCE INSTRllMENT CHECK (5) CHECK (5) CALIBRAIION(S) TEST m IS REO!HREfJ l-r MAIN CONQENSER OFF'GAS TREA+MEN:r SYs+EM 8'PLOSWE GAS m;mITORING

~

i. (Qel eted)

~ (Qeletee) 4-.- II.AHi CONfJENSER Ol=FGAS PRE TIU;A+MENT RAD*0°GIVITY MONIIQR (STeAN JET AIR EJECTOR) a-.. Ne~le gas activity meRiter

.;... (Qeleteet)

LIMERICK llNIT 2 3/4 3 1Q7 AmeRetmeAt Ne. i!i, 147

TABLE 4.3.7.12 1 (Centin1:1ed)

TABLE NOfATIONS (Deleted)

D1:1Fing epeFatien ef tke maiA eeAdeAseF steam jet air ejeeteF and effgas treatmeAt S)'Ste111 .

(Deleted)

.f>> Tke CHANNEL FYNCTIONAL TEST sl'lal1 alse d~monstFa~e. tl'lat e~ntF~l Peem alarm aAn1:1nci ati en 0CEl:I FS if aAy of the fel 1OWl Ag EOAdlt1 ORS em sts.

!Ast r1:1meRt i Adi cates measureEI l e¥el s abo¥e the al aFlfl-rtP1 I

  • P se t porn
  • t
  • Ci rc1:1i t failure.

InstFumeRt iRdieates a downscale fail1:1re.

4-.-- IRstrumeRt centrals Rot set in operate made.

Tile iRitial CHANNEL CALIBRATION skall be.perfermed.using ORe OF Rl0Fe of tRe refereAce staAElards certified by tke Nat10nal !Rst1tute ef StaAdards .

anEI Tecl=inelogy (NIST), previo1:1sly ~latieAal 81:1reau ef Stand~r~s, er _1:1s1n§ standards tkat kave been ebtained fFem s1:1ppliers that paFt1c1pate 1R .

meas1:1rellleAt assurance acth*ities witl=i NIST. These stanElards skall permit calieratiAg the syste111 0*1er its inteRdeEI Fange ef energy and meas1:1Fe111ent range. FeF s1:1bse~1:1ent CHA'INEL CALIBRATION, so1:1rees that l:iave eeen Felated te tl'le initial ealibratien sllall be used.

-(# The CHANNEL CALIBRATION shal 1 i nel 1:1de the 1:1se ef staRdard gas samples containing a nominal:

+/-... o.o ¥0l1:1R1e percent hydregen, balance Aitregen, aAd

~ 4 vel 1:1Rle percent hyEI regen, eal ance ni tregen.

-t4). (Del eted)

Freei1:1enc1es

  • are speeifieEI in tl=ie S1:1rveillancc Fre~1:1eney CeAtrol Pregram 1:1nless otherwise noted in the table .

LIMERICK YNIT 2 3/4 3 108 Amenement Ne . H: , 147

RADIOACTIVE EEELUHITS ~<-----1lsection 3/4.11 .2.5 (Deleted)'

EXPLOSIVE GAS MIXTURE LIMITING CONDITION FOR OPERATION

3. 11 . 2. S The cencentratien of hydPogen in the FRain consenseP offgas tFeatFRent systeFR shall be liFRites te less than OP C~tJal to 4% by YOltJffi.

APPLICABILITY. llheneveF the FRain consenseF aiP ejectoF systeFR is in opeFation.

ACT Im!:

~ llith Hie concentFation of hydrogen in the FRain coneenseP offgas treatFRent systeffi eKceeding the liFRit , restoFe the concentration to within the limit within 48 hotJFS .

&-:- The provisions of Si;ecification 3.0 . 3 aPe not applicable.

4.11.2.S The concentration ef hydPogen in the FRain coneenseF offgas tFeatment systeffi shall ee determinee to be within the aeove liffiits ey contintJotJsly monitoring the waste gases in the main condenser offgas treatffient systeFR with tt:1e hydrogen fflenitors re~tJiree OPERABLE by Table 3.3.7.12 1 ef Specifica tion 3.3 . 7.12.

THE INFORMATION FROM THIS TECHNICAL SPECIFICATIONS SECTION HAS BEEN RELOCATED TO THE TRM .

LIMERICK - UNIT 2 3/4 11-15

RADIOACTIVE EFFLUENTS MAIN CONDENSER LIMITING CONDITION FOR OPERATION 3.11.2.6 The rate of the sum of the activities of the noble gases Kr-85m, Kr-87, Kr-88, Xe-133, Xe-135, and Xe-138 measured at the recombiner after-condenser discharge shall be limited to less than or equal to 330 millicuries/second.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2*, and 3*.

ACTION:

With the rate of the sum of the activities of the specified noble gases at the recombiner after-condenser discharge exceeding 330 millicuries/second, restore the gross radioactivity rate to within its limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SURVEILLANCE Relocated to the ODCM .

4.11.2.6.1 TRe Pate ef tRe s~m ef tAe activities ef Reale gases at tRe recomBiRer after COAdCASCP discMarge SRall Be CORtiR~O~sly ffiORitered iR acceP daRce witR S~ecificatieR 3.3.7.12.

4.11.2.6.2 The rate of the sum of the activities of the specified noble gases from the recombiner after-condenser discharge shall be determined to be within the limits of Specification 3.11.2.6 at the following frequencies by performing an isotopic analysis of a representative sample of gases taken at the recombiner after condenser discharge: noted

a. In accordance with the Surveill Program.
b. Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following aff increase, as iAdieated By the MaiA CeRdeRser Off Gas PretreatmeRt Radioactivity MeRiter, of greater than 50%, after factoring out increases due to changes in THERMAL POWER level or air in-leakage, in the nominal steady-state fission gas release from the primary coolant.
c. The provisons of Specification 4.0.4 are not applicable.

LIMERICK - UNIT 2 3/4 11-16 Amendment No. 147

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

c. The program shall, as allowed by 10 CFR 50.55a, meet Subsection !STA, "General Requirements," and Subsection !STD, "Preservice and lnservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," in lieu of Section XI of the ASME B&PV Code ISI requirements for snubbers, or meet authorized alternatives pursuant to 10 CFR 50.55a.
d. The 120-month program updates shall be made in accordance with 10 CFR 50.55a subject to the limitations and conditions listed therein.

Explosive Gas Monitoring Program This program provides controls for potentially explosive gas mixtures contained downstream of the off-gas recombiners.

The program shall include:

a. The limit for the concentration of hydrogen downstream of the offgas recombiners and a surveillance program to ensure the limit is maintained. This limit shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion);

The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Explosive Gas Monitoring Program surveillance frequencies .

LIMERICK - UNIT 2 6-14e Amendment No. 184

ATTACHMENT 3 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Changes to the Main Condenser Offgas Monitoring Instrumentation Technical Specifications Markup of Proposed Technical Specifications Bases Pages Unit 1 TS Bases Pages B 3/4 3-7 B 3/4 11-4 Unit 2 TS Bases Pages B 3/4 3-7 B 3/4 11-4

INSTRUMENTATION 3/4.3.7.10 (Deleted) (Deleted} - INFORMATION FROM THIS SECTION RELOCATED TO THE ODCM AND THE TRM.

3/4.3.7.11 - INFORMATION FROM THIS SECTION RELOCATED TO THE ODCM.

3/4.3.7.12 OFFGAS MONITORING INSTRUMENTATION T~is iAstr~ffieRtatioR iRcludes provisioRs fer moRitoriRg t~e coAcentrations of potentially explosive gas mixtures and no~le gases in t~e off gas system.

3/4.3.8 (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE UFSAR.

3/4.3.9 FEEDWATER/MAIN TURBINE TRIP SYSTEM ACTUATION INSTRUMENTATION The feedwater/main turbine trip system actuation instrumentation is provided to initiate action of the feedwater system/main turbine trip system in the event of failure of feedwater controller under maximum demand.

RE FERENC ES:

1. NEDC-30851P-A, "Technical Specification Improvement Analyses for BWR Reactor Protection System," March 1988.
2. NEDC-32410P-A, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor CNUMAC PRNM) Retrofit Plus Option III Stability Trip Function," October 1995.
3. NEDC-32410P-A, Supplement 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," November 1997.
4. NED0-31960-A, "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology," November 1995.
5. NED0-31960-A, Supplement 1, "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology," November 1995.
6. NED0-32465-A, "Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications," August 1996.
7. Letter, L.A. England CBWROG) to M. J. Virgilio, "BWR Owners' Group Guidelines for Stability Interim Corrective Action," June 6, 1994.
8. GE Service Information Letter No. 516, "Core Flow Measurement - GE BWR/3, 4, 5 and 6 Plants," July 26, 1990.
9. GE Letter NSA 00-433, Alan Chung (GE) to Sujit Chakraborty (GE),

"Minimum Number of Operable OPRM Cells for Option III Stability at Limerick 1 & 2," May 02, 2001.

LIMERICK - UNIT 1 B 3/4 3-7 Amendment No. ~. 48, Q,

~. -144, ~. 177

RADIOACTIVE EFFLUENTS (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE TRM .

This specificatieA is previded te eAs~re that the ceAceAtratieA ef peteA tially explesive gas ffiixt~res CBAtaiAea iA the fflaiA CBAdeAser Bffgas treat ff!eAt S)'S teffi i 5 ff!J i Ata i ACS ael B'i' the fl JffiffiJ a i1 ity li ff!itS ef h)'dPegeA aAd 8J()'geA .

MaiAtaiAiAg the CBAceAtratiBA Bf hydrBgeA ael~1 its flamff!al:lility liff!it provides ass~raAce that the releases Bf radiBactive materials will be CBAtrBlled iA coAformaAce with the re~~iremeAts Bf GeAeral DesigA CriterieA 60 Bf AppeAdi~ A to 10 GFR Part SO .

LIMERICK - UNIT 1 B 3/4 11-4 Amendment No. 48 I

INSTRUMENTATION 3/4.3.7.10 (Deleted) (Deleted)- INFORMATION FROM THIS SECTION RELOCATED TO THE ODCM AND THE TRM .

3/4.3.7.11 T~is iRstr~ffiCRtatiOR iRCl~~es prOV1510AS for ffiOAitoFiAg t~e COAECAtFatiORS of poteAtially explosive gas mixt~res aA~ Ao~le gases iA t~e off gas systeffi .

3/4.3.8 (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE UFSAR.

3/4.3.9 FEEDWATER/MAIN TURBINE TRIP SYSTEM ACTUATION INSTRUMENTATION The feedwater/main turbine trip system actuation instrumentation is provided to initiate action of the feedwater system/main turbine trip system in the event of failure of feedwater controller under maximum demand.

RE FERENC ES:

1. NEDC-30851P-A, "Technical Specification Improvement Analyses for BWR Reactor Protection System," March 1988.
2. NEDC-32410P-A, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor CNUMAC PRNM) Retrofit Plus Option III Stability Trip Function," October 1995.
3. NEDC-32410P-A, Supplement 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor CNUMAC PRNM) Retrofit Plus Option III Stability Trip Function," November 1997.
4. NED0-31960-A, "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology," November 1995.
5. NED0-31960-A, Supplement 1, "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology," November 1995.
6. NED0-32465-A, "Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications," August 1996.
7. Letter, L. A. England CBWROG) to M. J. Virgilio, "BWR Owners' Group Guidelines for Stability Interim Corrective Action," June 6, 1994.
8. GE Service Information Letter No. 516, "Core Flow Measurement - GE BWR/3, 4, 5 and 6 Plants," July 26, 1990.
9. GE Letter NSA 00-433, Alan Chung CGE) to Sujit Chakraborty CGE),

"Minimum Number of Operable OPRM Cells for Option III Stability at Limerick 1 & 2," May 02, 2001.

LIMERICK - UNIT 2 B 3/4 3-7 Amendment No. +/-+/-, ~. JJ, 4, .eg,

.W, 139

RADIOACTIVE EFFLUENTS (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE TRM.

This specificatieA is pPe~ided te eAs~Pe tAat tAe coAceAtPatioA of poteA tially explosive gas mixt~res coAtaiAed iA tAe maiA coAdeAser offgas tPeat meAt system is maiAtaiAed below the flammability limits of AydrogeA aAd o*ygeA .

MaiAtaiAiAg the ceRceAtratioA ef hydregeR below its flammability limit pPovides ass~raAce that the releases of radieactive materials will be coRtrolled iA coRformaRce with the req~iremeAts of GeAeral Design GriterioA 60 of AppeAdi* A to 10 GFR Part SO.

LIMERICK - UNIT 2 B 3/4 11-4 Amendment No.11 I

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