Text

Proposed Tech Specs Section 3/4.4.3, RCS Leakage,Leakage Detection Systems, Clarifying Action Statement Re Inoperative Reactor Coolant Leakage Detection Systems
	ML20195G048
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Site:	Limerick
Issue date:	06/07/1999
From:	; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
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ATTACHMENT 2 J

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LIMERICK GENERATING STATION UNITS 1 and 2 i

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i DOCKET NO. 50-352 50-353 LICENSE NO. NPF-39 NPF-85 l

l TECHNICAL SPECIFICATIONS CHANGE REQUEST NO. 98-09-0 l

LIST OF AFFECTED PAGES

. UNIT 1 3/4 4-8 B 3/4 4-3 UNIT 2 3/4 4-8 B3/4 4-3 9906150199 990607 PDR ADOCK 05000352 P PDR ,

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-CTOR - Sm< Refer to 3 ORC 3/4.4.3 REACTOR COOLANT SYSTEM LEAKAGE LEAKAGE DETECTION SYSTEMS Position # '

@S LIMITING CONDITION FOR OPERATION

, , e 4.3.1 The following reactor coolant system leakage detection systems shall b OPERABLE:

. The primary containment atmosphere gaseous radioactivity monitori system, b

b. The drywell floor drain sump and drywell equipment drain tank ow

( nitoring system, j

) c. The rywell unit coolers condensate flow rate monitoring stem, and

d. The pr ry containment pressure and temperature moni ing system. f I APPLICABILITY: OPERA CONDITIONS 1, 2, and 3.* ,

i I ACTION:

With only three of the above ired leakage detection ystems 0PERABLE, ,

operation may be continue for to 30 days provided samples of the contain-ment atmosphere are obtained and alyzed at le'ast per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the required gaseous radioactive monit ing system, p ry containment pressure and l temperature monitoring system and/o drywell it coolers condensate flow , i rate monitoring system is inoperable; therwise 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 thin the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REOUIREMENTS

= 4.4.3.1 The reactor coolant system akage etection systems shall be' demonstrated operable by:

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a. Primary containment a sphere gaseous loactivity monitoring systems-performance a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a CHANNEL FUNCTIONAL at least once per days and a CHANNEL CALIBRATION at le t once per 24 months. l

b. The primary ainment pressure shall be monito at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and he primary containment temperature all be monitored at least once r 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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c. Drywell oor drain sump and Drywell equipment drain ta flow monitor-ing s ten-performance of a CHANNEL FUNCTIONAL TEST, at ast once per 31 ys and a CHANNEL CALIBRATION TEST at least once per 2 months. l D. ywell unit coolers condensate flow rate monitoring system-performance of a CHANNEL FUNCTIONAL TEST at least once per 31 d s and a CHANNEL CALIBRATION at least once per 24 months. l

T primary containment atmosphere gaseous radioactivity monitor is not -

IH t 50 fl JEL 2 81994

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P A3E' 3.-4.3.1 he following reactor coolant leakage detection systems snall be OPERABLE:

a. The primary containment atmosphere gaseous radioactivity monitoring system,

b. The drywell floor drain sump flow monitoring system,

c. The drywell unit. coolers condensate flow rate monitoring system, and

d. The primary containment pressure and temperature monitoring system.

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

- "he primary containment gaseous radioactivity monitor is not required to be

. operable until Operational Concition 2.

ACTIONS:

' NOTE: The provisions of 3.0.4 do not apply to ACTIONS A, B, D and E below.

A. With the primary containment atmosphere gaseous radioactivity monitoring system ;

inoperable, analyze grab samples of primary containment atmosphere at least once !

per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND restore primary containment atmosphere gaseous radioactivity monitor 1ng system to OPERABLE status within 30 days.

B. With the drywell floor drain sump flow monitoring system IN0PERABLE, restore the drywell floor drain sump flow monitoring system to OPERABLE status within 30 days AND increase monitoring frequency of drywell unit cooler condensate flow rate (SR 4.4.3.2.1.c) to once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

C. With the orywell unit coolers condensate flow rate monitoring system IN0PERABLE, AND the :rimary containment atmosphere gaseous radioactivity monitoring system 3PERABLE. perform a channel cneck of the primary containment atmosonere gaseous adioact vity monitoring system (SR 4.4.3.1.c) once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

D. ,iith the :rimary containment :ressure and temperature monitoring system IN0PERABLE. restore the primary containment pressure and temperature monitoring ,

system to OPERABLE status within 30 days. NOTE: All other Tech Soec Limitino Conditien_1 For Ooeration and Surveillance Reouirements associated with the crimary containment Dressure/temoerature monitor' no system still acDIV. Affected Tech Soec Sections include: 3/4.3.7.5. 4.4.3.2. . 3/4.6.1.6. and 3/4.6.1.7 E. With the crimary containment atmosphere gaseous radioactivity monitoring system IN0PERABLE AND the drywell unit coolers condensate flow rate monitoring system ;

INOPERABLE, restore the primary containment atmosphere gaseous raoicactivity monitoring system to OPERABLE status within 30 days OR restore the drywell unit coolers :endensate flow rate .onitoring system to OPERABLE status within 30 days.

With the primary containment atmospnere gaseous radioactivity monitoring system inoperaole, analyze _ grab samples of primary containment atmosphere at least once per 12 rours.

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seat A

?^f L F. With any other two or more leak detection systems inoperable other than ACTION E above OR with required Actions and associateo Completion Time of ACTIONS A, B, C, D or E not met, be in H0T 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 REOUIREMENTS 4.4.3.1 The reactor coolant system leakage detection systems shall be demonstrated operable by:

a. Perform a CHANNEL CHECK of the primary containment atmosphere gaseous radioactivity monitoring system at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. Perform a CHANNEL FUNCTIONAL TEST of required leakage detection instrumentation at least once per 31 days. This does not apply to containment pressure and temperature monitoring system.

c. Perform a CHANNEL CALIBRATION of required leakage detection instrumentation at least once per 24 months. This does not apply to containment pressure and temperature monitoring system,

d. Monitor primary containment pressure once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A.NJN monitor primary containment temperature at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

~ REACTOR COOLANT SYSTEM .

BASES Swd 3/4.4.3 REACTOR COOLANT SYSTEM LEAKAGE e

3/4.4.3.1 LEAKAGE DETECTION SYSTEMS .

leakage detection systems required by this specification ar monitor and de e from.the reactor coolant pressure bou inese detection systems are consistent wit 1. . ..

ndations of uide l'.45, " Reactor Coolant Pressure Boundary Leakage Det > " May 1973. 'In conformance.with Regulatory Guide'1.45 ca ibration tests the ability to detect a 1 gpm le an 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and an atmospheric gaseous rad o stem ty of.10~ pC/cc.

3/4.4.3.2 OPERATIONAL LEAKAGE The allowable leakage rates from the reactor coolant system have been based on the predicted and experimentally observed behavior of cracks in pipes. The normally

exp2cted background leakage due to equipment design and the detection capability of the instrumentation for determining system leakage was also considered. The evidence obtained from experiments suggests that for leakage somewhat greater than that specified for UNIDENTIFIED LEAKAGE the probability is small that the imperfection or crack associated with such leakage would grow rapidly. However, in all cases, if the leakage rates exceed the values specified or the leakage is located and known to be PRESSURE BOUNDARY LEAKAGE, the reactor will be shutdown to allow further investigation and corrective action. The limit of 2 gpm increase in UNIDENTIFIED LEAKAGE over a 24-ir period and the monitoring of drywell floor drain sump and drywell equipment drain

.ank flow rate at least once every eight (8) h'ours conforms with NRC staff positions specified in NRC Generic Letter 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping," as revised by NRC Safety Evaluation dated March 6,1990. The ACTION requirement for the 2 gpm increase in UNIDENTIFIED LEAKAGE limit ensures that such. leakage is identified or a plant shutdown is initiated to allow further investigation and corrective action. Once identified, reactor operation may continue dependent upon the impact on total leakage.

The ACTION requirements for pressure isolation valves (PIVs) are used in conjunction with the system specifications for which PIVs are listed in Table 3.4.3.2-1 and with primary containment isolation valve requirements to ensure that plant operation is appropriately limited.

The Surveillance Requirements for the RCS pressure isolation valves provide added assurance of valve integrity thereby reducing the probability of gross valve f ailure and consequent intersystem LOCA. Leakage from the RCS pressure isolation valves is IDENTIFIED LEAKAGE and will be considered as a portion of the all' owed limit.

3/4.4.4 CHEMISTRY The water chemistry limits of the reactor coolant system are established to prevent damage to the reactor materials in contact with the coolant. Chloride limits

-are specified to prevent stress corrosion cracking of the stainless steel. The effect of chloride is not as great when the oxygen concentration in the coolant is low, thus

? 0.2 ppm limit on chlorides is permitted during POWER OPERATION. During shutdown J refueling operations, the temperature necessary for stress corrosion to occur is not present so a 0.5 ppm concentration of chlorides is not considered harmful during these periods..

LIMERICX '- UNIT 1 B 3/4 4-3 Amendment No. H. 49 APR 0 41991 I

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l 3/4.4 3.1 LEAKAGE DETECTION SYSTEMS BACKGROUND

'UFSAR Safety Design Basis.(Ref. 1), requires means for detecting and, to the extent practical, identifying the location of the source of Reactor Coolant System (RCS)

PRESSURE B0'JNDARY LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Limits on leakage from the reactor coolant pressure boundary (RCPB)are required so that i

. appropriate action can be taken before the integrity of the RCPB is impaired (Ref. 2).

Leakage detection systems for the RCS are provided to alert the operators whan leakage rates above normal background levels are detected and alsa to supply quantitative measurement of leakage rates.

Systems for separating the leakage of an identified source from a6 unidentined source cre necessary to provide prompt and quantitative information to the operators to permit them to take immediate corrective action. Leakage from the RCPB inside the drywell is detected by at least one of four(4) independently monitored variables which include drywell drain sump level changes over time yielding drain flow rates, and drywell gaseousradioactivitylevels.drywell pressure / temperature Theunit cooler primary condensate means flow rateleakage of quantifying and drywell in the drywell are the drywell floor drain sump flow monitoring system for UNIDENTIFIED LEAKAGE and the drywell equipment drain tank flow monitoring system for IDENTIFIED LEAKAGE.

1DENTIFIED leakage is not germane to this Tech Spec and the associated drywell equipment drain tank flow monitoring system is not included.

The drywell floor drain sump flow monitoring system monitors UNIDENTIFIED LEAKAGE ;

collected in the floor drain sump. UNIDENTIFIED LEAKAGE consists of leakage from RCPB !

components inside the drywell which are not normally subject to leakage and otherwise routed to the drywell equipment drain sump. The primary containment floor drain sump has transmitters that supply level indication to the main control room via the plant ,

monitoring system. The floor drain sump level transmitters are associated with ;

High/ Low level switches that coen/close the sump tank drain valves automatically. The i level instrument processing unit calculates an average leak rate (gpm) for a given measurement period wnich resets whenever the sc.pp drain valve closes. The level processing unit provides an alarm to the main control room each time the average leak rate changes by a predetermined value since the last time the alarm was reset. For the drywell floor drain sump flow monitoring system, the setpoint basis is a 1 gpm change !

in UNIDENTIFIED LEAKAGE.

In addition-to the drywell floor drain sump flow monitoring system described above, the discharge of each sump is monitored by an independent flow element. The measured flow rate from the flow element is integrated and recorded. A main control room alarm is also provided to indicate an excessive sump discharge rate measured via the flow element. This system, referred to as the "drywell floor drain flow totalizer", is not

. credited for drywell flocr drain sump flow monitoring system operability.

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The' primary containment atmospheric gaseous radioactivity monitoring system.

continuously monitors the ~ primary containment atmosphere for gaseous radioactivity 1evels. A sudden increase of. raoloactivity, which may be attributed to RCPB steam or reactor water leakage, is annunciated in the main control room. The primary containment atmospheric gaseous radioactivity monitoring system is not capable of quantifying

. leakage rates, but-is sensitive enough to' detect increased leakage rates of I gpa ftsithin 1-hour. Larger changes in leakage rates are detected in prt,portionally shorter

-times (Ref.ca).

Condensate from'the eight drywell' air coolers is routed to the drywell floor drain sump and is monitored by a series of flow transmitters that provide indication and alarms in the main control room... The outputs from the flow transmitters are added together by summing units to provide a total continuous condensate drain flow rate. The high flow alarm setpoint is based on condensate drain flow rate in excess of I gpm over the currently. identified preset leak rate. The drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of RCS UNIDENTIFIED LEAKAGE (Ref. 5).

-The drywell temperature and pressure monitoring systems provide an indirect method for detecting RCPB leakage. A temperature and/or pressure rise in the drywell above normal

. levels may be indicative of a reactor coolant or steam leakage. (Ref.6)

APPLICABLE SAFETY ANALYSES A threat of significant compromise to the RCPB exists if the barrier contains a crack that is large enough to' propagate rapidly. Leakage rate limits are set-low enough to detect the leakage emitted from a single crack in the RCPB (Refs. 7 and 8). Each of the leakage detection systems inside the:drywell is designed with the capability of detecting leakage less than the establisned leakage rate limits and providing appropriate alarms of excess leaxage'in the control room.

A control room alarm allows'the coerators to. evaluate the-significance of the indicated leakage and, if necessary, shut :own. the reactor _ for further investigation and corrective' action. The allowea leakage rates are well below the rates predicted for critical' crack sizes (Ref. 8). Therefore, these actions provide. adequate response

.before;a significant break in the RCPB can occur.

RCS leakage detection. instrumentation satisfies Criterion 1 of the NRC Policy Statement.

. LIMITING CONDITION FOR OPERATION ILCO)

The drywell floor drain sump flew monitoring system is required to quantify the UNIDENTIFIED LEAKAGE from the RCS. The other monitoring systems provide early alarms to the-operators so closer examination of other detection systems will be made to dettrmine the extent of any corrective action that may be required. With any leakage ,

detection system inoperable, monitoring for leakage in the RCPB is degraded. i j

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'EPPLICABIOTY-In OPERATIONAL CONDIT'.AS 1, 2.'and 3. leakage detection systems are required to be !

OPERABLE.to support LCO 3.4.3.2. This applicability is. consistent with that for LCO i 3.4.3.2.

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ACTIONS A. With the crimary containment atmosphere gaseous monitoring system inoperable, grab l samples;of-the primary containment atmosphere must be taken and analyzed to provide !

periodicLleakage. information.-[Provided a sample :is obtained and analyzed once every 1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the plant may be' operated for up to 30 days to allow restoration of the radioactivity monitoring system. The plant may continue operation since other forms of drywell leakage detection are available.)

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval provides periodic information that is adequate to detect

. leakage. The 30. day Completion Time for Restoration recognizes other forms of

-leakage detection are available.-The Required ACTIONS are modified by a Note that states that the provisions of LC0 3.0.4 are not applicable. As a result, an

, OPERATIONAL CONDITION change is allowed when the primary containment atmospheric gaseous monitoring system is inoperable. This allowance is provided because other l instrumentation is available to monitor RCS leakage.

B. With the drywell floor drain sump flow monitoring system inoperable, no other form of sampling can provide the equivalent information to quantify leakage at the

. required 1. gps / hour sensitivity. However, the primary containment atmospheric gaseous monitor [ano the primary containment air cooler condensate flow rate monitor] will provide indication of changes in leakage.

With the drywell . floor drain sump' flow monitoring system inoperable, drywell

, condensate flow rate monitoring frequency increased from 12 to every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and UNIDENTIFIED LEAKAGE and total leakage being etermined every 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s-(Ref: SR 4.4.3.2.lb) operation may continue for 30 days. To the extent practical, the surveillance frequency change associated with the drywell condensate flow rate monitoring system, makes uo for the loss of the drywell floor drain sump monitoring system wnich had a normal surveillance requirement to monitor leakage every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Also note that in this instance, the drywell floor drain tank flow totalizer will be used to comply with SR 4.4.3.2.lb. The 30 day Completion Time of the required ACTION is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available. The required ACTION is modified by a Note that states that the provisions of LCO 3.0.4 are not applicable. As.a result, an OPERATIONAL CONDITION change is allowed when the drywell floor drain sump monitoring system is inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage.

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Sih 0 PT f ACTIONS (Continued)

C. With the required primary containment air cooler condensate flow rate monitoring system inoperable, SR 4.4.3.1.a must be performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to provide periodic information of activity in the primary containment at a more frequent interval than the routine frequency of every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval provides periodic information that is adequate to detect leakage and recognizes that other forms of leakage detection are available. The required ACTION has been clarified to state that the additional surveillance requirement is not applicable if the required primary containment atmosphere gaseous radioactivity monitoring system is also inoperable. Consistent with SR 4.0.3, surveillances are not required to be performed on inoperable equipment. In this case, ACTION Statement A. and E. requirements apply.

D. With the primary containment pressure and temperature monitoring system inoperable, operation may continue for up to 30 days given the system's indirect capability to detect RCS leakage. However, other more limiting Tech Spec requirements associated with the primary containment pressure / temperature monitoring system will still apply.

E. With both the primary :ontainment atmosphere gaseous radioactivity monitor and the primary containment air cooler condensate flow rate monitor inoperable, the only means of detecting leakage is the drywell floor drain sump monitor and the drywell pressure / temperature instrumentation. This condition does not provide the required diverse means of leakage detection. The required ACTION is to restore either of the inoperable monitors to OPERABLE status within 30 days to regain tte intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period. The requirea ACTIONS are modified by a Note that states that the provisions of LCO 3.0.4 are not applicable. As a result, an OPERATIONAL CONDITION change is allowed when both the primary containment atmosphere gaseous radioactivity monitor and air cooler condensate flow rate monitors are inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage. While the primary containment atmosonere gaseous radioactivity monitor is IN0PERABLE, Primary containment atmoseneric grab samples will be taken and analyzed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months since ACTION Statement A. requirements also apply.

F. If any reauired ACTION of Conditions A, B, C, D or E cannot be met within the associated Completion Time, the plant must be brought to an OPERATIONAL CONDITION in which the LCO does not apply. To achieve this status, the plant must be brought to at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and COLD SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The allowed Completion Times are reasonable, based on operating experience, to perform *.ne ACTIONS in an orderly manner and without challenging plant systems.

SURVEILLANCE RE0VIREPENTS SR 4.4.3.1.a This SR is for the performance of a CHANNEL CHECK of the required primary containment atmospheric onitoring system. The check gives reasonable confidence that the :nannel is operatina properly. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonaole for detacting off normal conditions.

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Lesent 6 PA3c F SURVEILLANCE RE0VIREMENTS (Continued)

SR 4.4.3.1.b This SR is-for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The test also verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper for detecting degradation. .

SR 4.4.3.1.c This SR is for the performance of a CHANNEL CALIBRATION of required leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The-Frequency of 24 months is for a typical refueling cycle and considers channel reliability. Operating experience has proven this frequency to be acceptable.

SR 4.4.3.1.d This SR provides a routine check of primary containment pressure and temperature for indirect evidence of RCS leakage. Operating experience has proven this frequency to be acceptable.

REFERENCES

1. LGS UFSAR, Section 5.2.5.1.

2. Regulatory Guide 1.45, May 1973.

~3. LG$ UFSAR, Section 5.2.5.2.1.3.

4. LGS UFSAR, Section 5.2.5.2.) .5

5. LGS UFSAR, Section 5.2.5.2.;.4

6. LGS UFSAR, Section 5.2.5.2.1.1(2)

7. GEAP-5620, April 1968.

8. NUREG-75/067, October 1975.

9. LGS UFSAR, Section 5.2.5.6.

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r l REACTOR COOLANT SYSTEM i

3/4.4.3' REACTOR COOLANT SYSTEM LEAKAGE l

LEAKAGE DETECTION SYSTEMS j LIMITING CONDITION FOR OPERATION

3.4.3.1 The following reactor coolant leakage detection systems shall l- be 3PERABLE

a. The primary containment atmosphere gaseous radioactivity monitoring system, b.- The drywell floor drain sump flow monitoring system,

c. The drywell unit coolers condensate flow rate monitoring system, and

d. The primary containment pressure and temperature monitoring system.

l APPL::CABIL::TY: OPERATIONAL CONDITIONS 1, 2, and 3.*

he pr mary containment gaseous radioactivity monitor is not required to be operable until Operational Condition 2.

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N TE: - The provisions of 3.0.4 do not apply to ACTIONS A, B, D and E below.

t A. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND restore primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days.

'B. With the drywell floor drain sump flow monitoring system INOPERABLE, restore the

, drywell floor drain sump flow monitoring system to OPERABLE status within 30 days i AND increase monitoring frequency of drywell unit cooler condensate flow rate (SR 4.4.3.2.1.c) to once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

C. With the drywell unit coolers condensate flow rate monitoring system INOPERABLE, I AND the primary containment atmosphere gaseous radioactivity monitoring system OPERA 8LE perform a channel check of the primar radioactivitymonitoringsystem(SR4.4.3.1.c)ycontainmentatmospheregaseous-once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ;

, D. With the primary containment pressure and temperature monitoring system INOPERABLE restore the primary containment )ressure and temperature monitoring systemto6PERABLEstatuswithin30 days. NOTE: All other ech Soon Li nitina Conditions For One-ation and Surveillance Reauiroments assoc' r.od w' '.h t ie nrimary containmen'; orossure/ temperature moni';or' no sys'.em st '

ano' v. Affected "ech Soec Sections inc' ude: 3/4.3.7.5. 4.4.3.2.1. 3/4.6.1.6. and 3/4.6.1.7.

E. With the primary containment atmosphere gaseous radioactivity monitoring system INOPERABLE AND the drywell unit coolers condensate flow rate monitoring system INOPERABLE, restore the >rimary containment atmosphere gaseous radioactivity monitoring system to OPELABLE status within 30 days OR restore the drywell unit coolers condensate flow rate monitoring system to OPERABLE status within 30 days.

With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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' LIMERICK - UNIT 1 3/4 4-8 l

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REACTOR COOLANT SYSTEM BASES BACKGROUND (Continued)

The primary containment atmospheric gaseous radioactivity monitoring system continuously monitors the primary containment atmosphere for gaseous radioactivity levels. A sudden increase of radioactivity, which may be attributed to RCPB steam or reactor water leakage, is annunciated in the main control room. The primary containment atmospheric gaseous radioactivity monitoring system is not capable of quantifying leakage rates, but is sensitive enough to detect increased leakage rates of I gpa within I hour. . Larger changes in leakage rates are detected in proportionally shorter times (Ref. 4).

Condensate from the eight drywell air coolers is routed to the drywell floor drain sump and is monitored by a series of flow transmitters that provide indication and alarms in the main control room. The outputs from the flow transmitters are added together by summing units to provide a total continuous condensate drain flow rate. The high flow alarm setpoint is based on condensate drain flow rate in excess of I gpa over the currently identified preset leak rate. The drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of RCS UNIDENTIFIED LEAKAGE (Ref. 5).

The drywell temperature and pressure monitoring systems provide an indirect method for detecting RCPB leakage. A temperature and/or pressure rise in the drywell above nor;aal levels may be indicative of a reactor coolant.or steam leakage (Ref. 6).

APPLICABLE SAFETY ANALYSES A threat of significant compromise to the RCPB exists if the barrier contains a crack that is large enough to propagate rapidly. Leakage rate limits are set low enough to detect the leakage emitted from a single crack in the RCPB (Refs. 7 and 8). Each of the leakage detection systems inside the drywell is designed with the capability.of detecting leakage less than the established leakage rate liaits and providing appropriate alarms of excess leakage in the control room.

A control room alarm allows the operators to evaluate the significance of the indicated leakage and, if necessary shut down the reactor for further investigation and corrective action. The allowed leakage rates are well below the rates predicted for critical crack sizes (Ref. 8). Therefore, these actions provide adequate response before a-significant break in the RCPB can occur.

RCS leakage' detection instrumentation satisfies Criterion 1 of the NRC Policy Statement.

LIMITING CONDITION FOR OPERATION (LCO)

The drywell floor drain sump flow monitoring system is required to quantify the UNIDENTIFIED LEAKAGE from the RCS. The other monitoring systems provide early alarms to the operators so closer examination of other detection systems will be made to determine the extent of any corrective action that may be required. With any leakage detection system inoperable, monitoring for leakage in the RCPB is degrt ted.

LIMERICK'- UNIT 2 B 3/4 4-3a

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l REACTOR COOLANT SYSTEM f BASES' -

APPLICABILITY In OPERATIONAL CONDITIONS 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO 3.4.3.2. This applicability is consistent with that for LC0 3.4.3.2.

ACTIONS A. With the primary containment. atmosphere gaseous monitoring system inoperable, grab samples of the primary containment atmosphere must be taken and analyzed to provide periodic leakage information. [Provided a sample is obtained and analyzed once every l

l 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the plant may be operated for up to 30 days to allow restoration of the i

radioactivity monitoring system. The plant may continue operation since other forms I of drywell . leakage detection are available.] -

l l The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval provides periodic information that is adequate to detect leakage. The 30 day Completion Time for Restoration recognizes other forms of leakage detection are available. The Required ACTIONS are modified by a Note that states' that the provisions of LC0 3.0.4 are not applicable. As a result, an OPERATIONAL CONDITION change is a11' owed when the primary containment atmospheric

, gaseous monitoring system is inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage.

B. With the drywell floor drain sump flow monitoring system inoperable, no other form

of sampling can provide the equivalent information to quantify leakage at the

! required 1 gps / hour sensitivity. However, the primary containment atmospheric l gaseous monitor [and the primary containment air cooler condensate flow rate l monitor] will provide indication of changes in leakage.

l With the drywell floor drain sump flow monitoring system inoperable, drywell l

condensate flow rate monitoring frequency increased from 12 to every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and UNIDENTIFIED LEAKAGE and total leakage being determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (Ref: SR l 4.4.3.2.1.b) operation may continue for 30 days. To the extent practical, the '

t surveillance frequency change associated with the drywell condensate flow rate l l monitoring system, makes up for the loss of the drywell floor drain sump monitoring l_ system which.had a normal surveillance requirement to monitor leakage-every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . !

Also note that in this instance, the drywell floor drain tank flow totalizer will be l used to comply with SR 4.4.3.2.1.b. The 30 day Completion Time of the required l ACTION is acceptable, based on operating experience, considering the multiple forms l

of leakage detection that are still available. The required ACTION is modified by a Note that states that the )rovisions of LCO 3.0.4 are not applicable. As a result, an OPERATIONAL CONDITION ciange is allowed when the drywell floor drain sump i monitoring system is inoperable. This allowance is provided because other l instrumentation is available to monitor RCS leakage, l

LIMERICK - UNIT 2 B 3/4 4-3b

F ,

. REACTOR COOLANT SYSTEM BASES ACTIONS 1 Continued)

C.- With the required primary containment air cooler condensate flow rate monitoring system inoperable, SR 4.4.3.1.a must be performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to provide periodic information of activity in the primary containment at- a more frequent interval than the routine frequency of every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval provides periodic information that is adequate to detect leakage and recognizes that other forms of leakage detection are available. The required ACTION has been clarified to state that the additional surveillance requirement is not applicable if the required primary containment atmosphere gaseous radioactivity monitoring system is also inoperable. Consistent with SR 4.0.3, surveillances are not required to be performed on inoperable equipment. In this case, ACTION Statement A. and E. requirements apply.

D. With' the primary containment pressure and temperature monitoring system inoperable, operation may continue for up to 30 days given the system's indirect capability to detect RCS leakage. However, other more limiting Tech Spec requirements associated with the primary containment pressure / temperature monitoring system will still apply.

E. With both the primary containment atmosphere gaseous radioactivity monitor and the primary containment air cooler condensate flow rate monitor inoperable, the only means of detecting leakage is the drywell floor drain sump monitor and the drywell !

pressure / temperature instrumentation. This condition does not provide the required diverse means of leakage detection. The required ACTION is to restore either of the inoperable monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the )lant will not be operated in a degraded configuration for a lengthy time period. Tie required ACTIONS are modified by a Note that states that the provisions of LC0 3.0.4 are not applicable. As a result,.an OPERATIONAL CONDITION change is allowed when both the primary containment atmosphere gaseous radioactivity monitor and air cooler

. condensate flow rate monitors are inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage. While the primary containment atmosphere gaseous radioactivity monitor is INOPERABLE, Primary containment atmospheric grab samples will be taken and analyzed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months since ACTION Statement A. requirements also apply.

F. If any required ACTION of Conditions A, B, C, D or E cannot be met within the associated Completion Time, the plant must be brought to an OPERATIONAL CONDITION in which the LC0 does not ap)ly. To achieve this status, the plant must be brought to at least HOT SHUTDOWN wit 11n 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and COLD SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The allowed Completion Times are reasonable, based on operating experience, to perform the ACTIONS in an orderly manner and without challenging plant systems.

SURVEILLANCE RECUIREMENTS SR 4.4.3.1.a This SR is.for the performance of a CHANNEL CHECK of the required primary containment atmospheric monitoring system. The check gives reasonable confidence that the channel is operating properly. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

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p ,

REACTOR COOLANT SYSTEM BASES SURVEILLANCE REQUIREMENTS (Continued)

S t 4.4.3.1.b Tits SR is for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The test also verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 31 days considers instrument reliability, and operating experience h?s shown it proper for detecting degradation.

SR 4.4.3.1,q ..

This SR is for the performance of a. CHANNEL CALIBRATION of required leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 2a months is for a typical refueling cycle and considers channel reliability. Operating experience has proven this frequency to be acceptable.

St 4.4.3.1.d Tiis SR provides a routine check of primary containment )ressure and temperature for indirect evidence of RCS leakage. Operating experience las proven this frequency to be acceptable.

REFERENCES

1. LGS UFSAR, Section 5.2.5.1.

2. Regulatory Guide 1.45, May 1973.

.3. LGS UFSAR, Sectica 5.2.5.2.1.3.

4. LGS'UFSAR, Section 5.2.5.2.1.5.

5. LGS UFSAR, Section 5.2.5.2.1.4. l

6. LGS UFSAR, Section 5.2.5.2.1.1(2). ;

7. GEAP-5620,-April 1968. '

8. NUREG-75/067, October 1975.

9. LGS OFSAR, Section 5.2.5.6.

3/4.4.3.2 OPERATIONAL LEAKAGE The allowable leakage rates from the reactor coolant system have been based on the I predicted and experimentally observed behavior of cracks in pipes. The normally expected background leakage due to equipment design and the detection capability of the instrumentation for determining system leakage was also considered. The evidence obtained from experiments suggests that for leakage somewhat greater than that specified for UNIDENTIFIED L AKAGE the probability is small that the imperfection or ,

crack associated with such leakage would grow rapidly. However, in all cases, if the l leakage rates exceed the values specified or the leakage is located and known to be PRESSURE BOUNDARY LEAKAGE, the reactor. will be shutdown to allow further investigation and corrective action. The limit of 2 gpm increase'in UNIDENTIFIED LEAKAGE over a 24-hour period. and the monitoring of drywell floor drain sump and drywell equipment drain tank flow rate at least once every eight (8) hours conforms with NRC staff positions specified in NRC Generic Letter 88-01, "NRC Position on IGSCC in BWR Austenitic

. St&inless Steel Piping," as. revised by NRC Safety Evaluation dated March 6,1990. The ACTION requirement for the 2 gpm increase in UNIDENTIFIED LEAKAGE limit ensures that such leakage is identified or a plant shutdown is initiated to allow further investigation and corrective action. Once identified, reactor operation may continue dependent upon the impact on total leakage.

-LIMERICK - UNIT 2 B 3/4 4-3d

Y REACTOR COOLANT SYSTEM BASES l 3/4.4.3.2 OPERATIONAL LEAKAGE (Continued)

The ACTION requirements for pressure isolation valves (PIVs) are used'in conjunction with the system specifications for which PIVs are listed in Table 3.4.3.2-1 and with primary containment isolation valve requirements to ensure that plant cperation is appropriately. limited.

The Surveillance Requirements for the RCS )ressure isolation valves provide added assurance of valve integrity thereby reducing tle probability of gross valve failure and consequent intersystem LOCA. Leakage from the RCS pressure isolation valves is IDENTIFIED LEAKAGE and will be considered as a portion of the allowed limit. ;

4 3/4.4.4 CHEMISTRY The water chemistry limits of the reactor coolant system are established to p event damage to the reactor materials in contact with the coolant. Chloride limits are specified to prevent stress corrosion cracking of the stainless steel.

Ine effect of chloride is not as great when the oxygen concentration in the coolant is low, thus the 0.2 ppm limit on chlorides is )ermitted during POWER OPERATION. During shutdown and refueling operations, tie temperature necessary for stress corrosion to occur is not present so a 0.5 ppm concentration of chlorides is not considered harmful during these periods.

Conductivity measurements are required on a continuous basis since changes in this parameter are an indication of abnormal conditions. When the conductivity is within limits,.the pH, chlorides and other impurities affecting conductivity must also be within their acceptable limits. With the conductivity meter inoperable, l additional samples must be analyzed to ensure that the chlorides are not exceeding the limits. l

'The surveillance requirements provide adequate assurance that concentrations )

in excess of the limits will be detected in sufficient time to take corrective '

action.

LIMERICK - UNIT 2 B 3/4 4-3e

REACTOR COOLANT SYSTEM

. ACTIONS (Continued)

F. With any other two or more leak detection systems inoperable other than ACTION E above OR with required Actions and associated Completion Time of ACTIONS A, B C DorEnotmet,beinHOTSHUTDOWNwithin12hoursANDinCOLDSHUTDOWNwitbin tbenext24 hours.

SURVEILLANCE REQUIREMENTS 4.4.3.1 The reactor coolant system leakage detection systems shall be demonstrated operable by:

a. Perform a CHANNEL CHECK of the primary containment atmosphere gaseous radioactivity monitoring system at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. Perform a CHANNEL FUNCTIONAL TEST of required leakage detection instrumentation at least once per 31 days. This does not apply to containment pressure and temperature monitoring system.

c. Perform a CHANNEL CALIBRATION of required leakage detection instrumentation at least once per 24 nonths. This does not apply to containment pressure and ,

temperature monitoring system.

d. Monitor primary containment pressure once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 680 monitor primary l containment temperature at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

l l

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REACTOR COOLANT SYSTEM

< BASES 3/4.4.3 REACTOR COOLANT SYSTEM LEAKAGE 3/4.4.3.1 LEAKAGE DETECTION SYSTEMS BACKGROUND UFSAR Safety Design Basis (Ref. 1), requires means for detecting and, to the extent practical, identifying the location of the source of Reactor Coolant System RCS PRESSURE BOUNDARY LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptab e me)th j fcr selecting leakage detection systems.

Limits on leakage from the reactor coolant pressure boundary (RCPB) are required so that appropriate action can be taken before the integrity of the RCPB is impaired (Ref.

2). Leakage detection systems for the RCS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitative measurement of leakage rates.

Systems for separating the leakage of an identified source from an unidentified source are necessary to provide prompt and quantitative information to the operators to permit them to take immediate corrective' action. Leakage from the RCPB inside the drywell is detected by at least one of four (4) independently monitored variables which include drywell drain sump level changes over time yielding drain flow rates, and drywell gaseous radioactivity, drywell unit cooler condensate flow rate and drywell pressure / temperature levels. The primary means of quantifying leakage in the drywell are the drywell floor drain sum) flow monitoring system for UNIDENTIFIED LEAKAGE and the drywell equipment drain tan ( flow monitoring system for IDENTIFIED LEAKAGE.

IDENTIFIED leakage is not germane to this Tech Spec and the associated drywell equipment drain tank flow monitoring system is not included.

The drywell floor drain sump flow monitoring system monitors UNIDENTIFIED LEAKAGE collected in the floor drain sump. UNIDENTIFIED LEAKAGE consists of leakage from RCPB components inside the.drywell which are not normally subject to leakage and otherwise i routed to the drywell equipment drain sump. The primary containment floor drain sump has transmitters that supply level indication to the main control-room via the plant monitoring system. The floor drain sump level transmitters are associated with High/ Low level switches that open/close the sump tank drain valves automatically. The level instrument processing unit calculates an average leak rate (gpm '

measurement period which resets whenever the sump drain valve closes.) The icvelfor a given processing unit provides an alarm to the main control room each time the average leak rate changes by a predetermined value since the last time the alarm was reset. For the drywell floor drain su'np flow monitoring system, the setpoint basis is a 1 gpm change in UNIDENTIFIED LEAKAGE.

In addition to the drywell floor drain sump flow monitoring system described above, the

. discharge of each sump is monitored by an independent flow element. The measured flow rate from the flow element is integrated snd recorded. A main control room alarm is also provided to indicate an excessive sump discharge rate measured via the flow element. This system, referred to as the "drywell floor drain flow totalizer", is not l credited for drywell floor drain sump flow monitoring-system operability.

L l

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LIMERICK - UNIT 1- B 3/4 4-3 l

REACTOR COOLANT SYSTEM RSES-BACKGROUND (Continued)

The primary containment atmospheric gaseous radioactivity monitoring system continuously monitors the primary containment atmosphere for gaseous radioactivity levels. A sudden increase of radioactivity, which may be attributed to RCPB steam or reactor water leakage, is annunciated in the main control room. The primary containment atmospheric gaseous radioactivity monitoring system is not capable of quantifying ,

leakage rates, but is sensitive enough to detect increased leakage rates of I gpm )

within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Larger changes in leakage rates are detected in proportionally shorter times (Ref. 4).

' Condensate from the eight drywell air coolers is routed to the drywell floor drain sump i and is monitored by a series of flow transmitters that provide indication and alarms in !

the main control room. The outputs from the flow transmitters are added together by summing units to provide a total continuous condensate drain flow rate. The high flow

-alarm setpoint is based on condensate drain flow rate in excess of I gpm over the currently identified preset leak rate. The drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of RCS UNIDENTIFIED l LEAKAGE (Ref. 5). l The drywell temperature and pressure monitoring systems provide an indirect method for I detecting RCPB leakage. A temperature and/or pressure rise in the drywell above normal levels may be indicative of a reactor coolant or steam leakage (Ref. 6).

APPLICABLE SAFETY ANALYSES A threat of significant compromise to the RCPB exists if the barrier contains a crack that is large enough to propagate rapidly. Leakage rate limits are set low enough to detect the leakage emitted from a single crack in the RCPB (Refs. 7 and 8). Each of the leakage detection systems inside the drywell is designed with the capability of.

detecting leakage less than the established leakage rate limits and providing.

appropriate alarms of excess leakage in the control room.

A control room alarm allows the operators to evaluate the significance of the indicated leakage and, if necessary shut down the reactor for further investigation and correctiveaction.Theallowedleakageratesarewellbelowtheratespredictedfor critical crack sizes (Ref. 8). Therefore, these actions provide adequate response before a significant break in the RCPB can occur.

RCS leakage detection instrumentation satisfies Criterion 1 of the NRC Policy Statement.

LIMITING CONDITION FOR OPERATION (LCO)

The drywell floor drain sum) flow monitoring system is required to quantify the >

UNIDENTIFIED LEAKAGE from tie RCS. The other monitoring systems provide early alarms to the operators so closer examination of other detection systems will be made to determine the extent of any corrective action that may be required. Witt any leakage ;

detection system inoperable, monitoring for leakage in the RCPB is degraded.

LIMERICK - UNIT 1 B 3/4 4-3a

REACTOR COOLANT SYSTEM

. BASES APfMCABILITY 1

In OPERATIONAL CONDITIONS 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO 3.4.3.2. This applicability is consistent with that for LCO 3.4.3.2.

ACTIONS A. With the primary containment atmosphere gaseous monitoring system inoperable, grab 1 samples of the primary containment atmosphere must be taken and analyzed to provide j periodic leakage information. [Provided a sample is obtained and analyzed once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the plant may be operated for up to 30 days to allow restoration of the radioactivity monitoring system. The plant may continue operation since other forms i of drywell leakage detection are available.]

)

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval provides periodic information that is adequate to detect' leakage. The 30 day Completion Time for Restoration recognizes other forms of leakage detection are available. The Required ACTIONS are modified by a Note that states that the provisions of LC0 3.0.4 are not applicable. As a result, an OPERATIONAL CONDITION change is allowed when the primary containment atmospheric gaseous monitoring system is inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage.

B. With the drywell floor drain sump flow monitoring system inoperable, no other form of sampling can provide the equivalent information to quantify leakage at the required 1 gpa/ hour sensitivity. However, the primary containment atmospheric gaseous monitor [and the primary containment air cooler condensate flow rate monitor] will provide indication of changes in leakage.

With the drywell floor drain sump flow monitoring system inoperable, drywell condensate flow rate monitoring frequency increased from 12 to every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and UNIDENTIFIED LEAKAGE and total leakage being determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (Ref: SR 4.4.3.2.1.b) operation may continue for 30 days. To the extent practical, the ,

surveillance frequency change associated with the drywell condensate flow rate '

monitoring system, makes up for the loss of the drywell floor drain sump monitoring i system which had a normal surveillance requirement to monitor leakage every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . l Also note that in this instance, the drywell floor drain tank flow totalizer will be used to comply with SR 4.4.3.2.1.b. The 30 day Completion Time of the required ACTION is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available. The required ACTION is modified by a Note that states that the provisions of LC0 3.0.4 are not applicable. As a result, an OPERATIONAL CONDITION change is allowed when the drywell floor drain sump monitoring system is inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage.

LIMERICK - UNIT 1 B 3/4 4-3b

4+ ,

REACTOR COOLANT SYSTEM i BASES ACTIONS (Continued)

C. With the required primary containment air cooler condensate flow rate monitoring system inoperable, SR 4.4.3.1.a must be performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to provide periodic information of activity in the primary containment at a more frequent interval than 4 the routine frequency of every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval provides periodic I information that is adequate to detect leakage and recognizes that other forms of leakage detection are available. The required ACTION has been clarified to state that the additional surveillance requirement is not applicable if the required primary containment atmosphere gaseous radioactivity monitoring system is also inoperable. Consistent with SR 4.0.3, surveillances are not required to be performed on inoperable equipment. In this case, ACTION Statement'A. and E. requirements apply.

D. With the primary containment pressure and temperature monitoring system inoperable, operation may continue for up to 30 days given the system's indirect capability to detect RCS leakage. However,.other more limiting Tech Spec requirements associated '

with the primary containment pressure / temperature monitoring system will still apply.

E. With both the primary containment atmosphere gaseous radioactivity monitor and the primary containment air cooler condensate flow rate monitor inoperable, the only 1 means of detecting leakage is the drywell floor drain sump monitor and the drywell pressure / temperature instrumentation. This condition does not provide the required diverse means of leakage detection. The required ACTION is to restore either of the inoperable monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the )lant will not be operated in a degraded configuration for a lengthy time period. T1e required ACTIONS are modified by a Note that states that the provisions of LC0 3.0.4 are not applicable. As a result, an OPERATIONAL CONDITION change is allowed when both the primary containment atmosphere gaseous radioactivity monitor and air cooler condensate flow rate monitors are inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage. While the primary containment atmosphere gaseous radioactivity monitor is INOPERABLE, Primary containment atmospheric grab samples will be taken and analyzed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months since ACTION Statement A. requirements also apply.

F. If any: required ACTION of Conditions A, B, C, D or E cannot be met within the associated Completion Time t whichtheLCOdoesnotapdy.heplantmustbebroughttoanOPERATIONALCONDITIONin To achieve this status, the plant must be brought to at least HOT SHUTDOWN wit.11n 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and COLD SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The allowed Completion Times are reasonable, based on operating experience, to perform the ACTIONS in an orderly manner and without challenging plant systems.

SURVEILLANCE REQUIREMENTS St 4.4.3.1.a T11s SR is for the performance of a CHANNEL CHECK of the required primary containment atmospheric monitoring system. The check gives reasonable confidence that the channel is operating properly. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

LIMERICK - UNIT 1 B 3/4 4-3c

, , 1 REACTOR COOLANT SYSTEM BASES SURVEILLANCE REQUIREMENTS (Continued)

S t 4.4.3.1.b T11s SR is for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The test also verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper for detecting degradation.

SR 4.4.3.1.c This SR is for the performance of a CHANNEL CALIBRATION of required leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the. instruments located inside containment. The Frequency of 24 months is for_ a typical refueling cycle and considers channel reliability. Operating experience has proven this frequency to be acceptable.

S t 4.4.3.1.d Tiis SR provides a routine check of primary containment )ressure and temperature for indirect evidence of RCS leakage. Operating experience las proven this frequency to be acceptable.

REFERENCES

1. LGS UFSAR, Section 5.2.5.1.

2. Regulatory Guide 1.45, May 1973.

3. LGS UFSAR, Section 5.2.5.2.1.3.

4. LGS UFSAR, Section 5.2.5.2.1.5. l 5._ LGS UFSAR, Section 5.2.5.2.1.4.

6. LGS UFSAR, Section 5.2.5.2.1.1(2).

7. GEAP-5620, April 1968.

8. NUREG-75/067, October 1975.

9. LGS UFSAR, Section 5.2.5.6. ;

3/4.4.3.2 OPERATIONAL LEAKAGE The allowable leakage rates from the reactor coolant system have been based on the predicted and experimentally observed behavior of cracks in pipes. The normally expected background leakage due to equipment design and the detection capability of the instrumentation for determining system leakage was also considered. The evidence obtained from experiments suggests that for leakage somewhat greater than that specified for UNIDENTIFIED LEAKAGE the probability is small that the imperfection or crack associated with such leakage would grow rapidly. However, in all cases, if the leakage rates exceed the value.s specified or the leakage is located and known to be PRESSURE BOUNDARY LEAKAGE, the reactor will be shutdown to allow further investigation and corrective action. The limit of 2 gpm increase in UNIDENTIFIED LEAKAGE over a 24-hour period and the monitoring of drywell floor drain sump and drywell equipment drain tank flow in specified rate at least NRC once Generic every88-01, Letter eight "NRC (8) Position on IGSCC in BWR Austenitichours conforms wi Stainless Steel Piping," as revised by NRC Safety Evaluation dated March 6, 1990. The ACTION requirement for the 2 gpm increase in UNIDENTIFIED LEAKAGE limit ensures that such leakage is identified or a plant shutdown is initiated to allow further investigation and corrective action. Once identified, reactor operation may continue dependent upon the impact on total leakage.

LIMERICK - UNIT 1 B 3/4 4-3d l

REACTOR COOLANT SYSTEM BASES 3/4.4.3.2 OPERATIONAL LEAKAGE (Continued)

.The ACTION requirements for pressure isolation valves (PIVs) are used in conjunction with the system specifications for which PIVs are listed in Table 3.4.3.2-1 and with primary containment isolation valve requirements to ensure that plant operation is appropriately limited.

The Surveillance Requirements for the RCS )ressure isolation valves provide added assurance of valve integrity thereby reducing tie probability of gross valve failure and consequent intersystem LOCA. Leakage from the RCS pressure isolation valves is IDENTIFIED LEAKAGE and will be considered as a portion of the allowed limit.

.3/4.4.4 CHEMISTRY The water chemistry limits of the reactor coolant system are established to prevent damage to the reactor meterials in contact with the coolant. Chloride limits are specified to prevent stress corrosion cracking of the stainless steel. The effect of chloride is not as great when the oxygen concentration in the coolant is low, thus the 0.2 p p limit on chlorides is permitted during POWER OP' RATION.

c During shutdown and refueling operations, the temperature necessary for stress coriosion to occur is not present so a 0.5 ppm concentration of chlorides is not considered harmful during these periods.

l 1

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I LIMERICK - UNIT I B 3/4 4-3e

i i

l REACTOR COOLANT 9YSTEM g 3 /4.4.3 REACTOR COOLANT SYSTEM LEAKAGE Refer to ,30Ru

'"*^""""'-

LIMITING CONDITION FOR OPERATION Position # e v4 w

.4.3.1 The following reactor coolant system leakage detection systems shall N

b OPERABLE:

a. The primary containment atmosphere gaseous radioaci.ivity monitorin system, l

b. The drywell floor drain sump and drywell equipment drain tank ow itoring system, )

Th drywell unit coolers condensate flow rate monitoring ystem, and c.

l

d. The pr ry containment pressure and temperature meni ring system. I APPLICABILITY: OP TIONAL CONDITIONS 1, 2, and 3.*

I h ACTION:

i f With only three of the above quired leakage detectio systems OPERABLE, i operation may be continue for to 30 days provi rab samples of the contain- I ment atmosphere are obtained analyzed at least ce per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the I required gaseous radioactive mont ring system, mary containment pressure and I temperature monitoring system and/o the drywe unit coolers condensate flow /

rate monitoring system is inoperable, otherwi , be in at least HDT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . K ,

i SURVEILLANCE REOUIREMENTS 4.4.3.1 The reactor coolant syst leaka detection systems shall be-demonstrated operable by:

a. Primary containment sphere gaseous adioactivity monitoring '

/ 4 i

systems-performan of a CHANNEL CHECK least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a I CHANNEL FUNCTI TEST at least once per 1 days and a CHANNEL l CALIBRATION at east once per 24 months. -

l 1

b. The primary ntainment pressure shall be moni at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months the primary containment temperature hall be monitored at least o e per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c. 1 floor drain sump and Drywell equipment drain k flow monitor-i system-performance of a CHANNEL FUNCTIONAL TEST, at east once per i I days and a CHANNEL CALIBRATION TEST at least once per 4 months. l D. Drywell unit coolers condensate flow rate monitoring system- l perfomance of a CHANNEL FUNCTIONAL TEST at least once per 31 ys and a CHANNEL CALIBRATION at least once per 24 months. l The primary centainment atmosphere gaseous radioactivity monitor is not JUL 2 8 BM

hd A P^y 1 l

l 3.4.3.1 ~he following reactor ecolant leakage detection systems snall be OPERABLE:

a. The primary containment' atmosphere gaseous radioactivity monitoring system,

b. The drywell floor drain sump flow monitoring system.

.c. The drywell unit coolers condensate flow rate monitoring system, and

d. The primary containment pressure and temperature monitoring system. ;

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

- ~~he primary containment gaseous radioactivity monitor is not required to be operable until Operational Concition 2.

he provisions of 3.0.4 do not apply to ACTIONS A, B, D and E below.

A. With the primary containment atmosphere gaseous radioactivity monitoring system I inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND restore primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days.

B. With the drywell floor drain sump flow monitoring system IN0PERABLE, restore.the !

drywell floor drain sump flow monitoring system to OPERABLE status within 30 days i AND increase monitoring frequency of drywell unit cooler condensate flow rate (SR 4.4.3.2.1.c) to once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

1 C. With the drywell unit coolers :endensate flow rate monitoring system IN0PERABLE, i AND the crimary containment atmosobere gaseous radioactivity monitoring system JPERABLE. perform a channel cneck of'the primary containment atmoschere gaseous radioactivity monitoring system (SR 4.4.3.l.c) once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

D. With the crimary containment :ressure and temperature monitoring system I IN0PERABLE, restore the primary containment pressure and temperature monitoring system to OPERABLE status within 30 days. NOTE: All other Tech Soec limitina Conditions For Ooeration and Surveillance Reouirements associated with the crimary containment Dressure/temoerature monitorina system still aco' v. Affected ,

Tech Spec Sections include: 3/4.3.7.5. 4.L .3.2.1. 3/4.6.1.6. and 3/4.6.1.7 E. With the primary containment atmosphere gaseous radioactivity monitoring system INOPERABLE AND the drywell unit coolers condensate flow rate monitoring system INOPERABLE, restore the primary containment atmosphere gaseous racioactivity l monitoring system to OPERABLE status within 30 days OR restore the drywell unit i coolers condensate flow rate .onitoring system to OPERABLE status within 30 days.

With the primary containment atmosphere gaseous radioactivity monitoring system inoperaole, analyze grab samples of primary containment atmosphere at least once per 12 nours.

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'F With any other two or more leak detection systems inoperable other than ACTION E i above OR with required Actions and associated Completion Time of ACTIONS A, 8, C, D or E not met, be in 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 RE0VIREMENTS 4.4.3.1 The reactor coolant system leakage detection systems shall be demonstrated operable by:

a. Perform a CHANNEL. CHECX of the primary containment atmosphere gaseous radioactivity monitoring system at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. Perform a CHANNEL FUNCTIONAL TEST of required leakage detection instrumentation at least once per 31 days. This does not apply to containment pressure and temperature monitoring system.

c. Perform a CHANNEL CALIBRATION of required leakage detection instrumentation at least once per 24 montns. This does not apply to containment pressure and temperature monitoring system.

d. Monitor primary containment pressure once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND monitor primary containment temperature at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , l

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4 REACTOR COOLANT SYSTEM'

'SASES h ERf 3/4.4.3 REACTOR COOLANT SYSTEM LEAKAGE f5 N

% 4.3.1 LEAKAGE DETECTION SYSTEMS The RCS : detection systems required by this specification are '

to monitor and detect lea m the reactor coolant pressure b .

hese detection systems are consistent with the ndations of Guide 1.45, " Reactor i

Coolant Pressure Boundary Leakage Data - . . ens," May 1973. In conformance with Regulatory Guide 1.45, th calibration tes verify the ability to detect a 1 gpm lea an 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and an atmospheric gaseous tivity system s y of 10 pC/cc.

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9 3/4.4.3.2 OPERATIONAL LEAKAGE The allowable leakage rates from the reactor coolant system have been based on the predicted and experimentally observed behavior of cracks in pipes. The normally expected background leakage due to equipment design and the detection capability of the instrumentation for determining systam leakage was also c:nsidered. The evidence obtained fr m experiments suggests that for 1_eakage semewhat greater than that specified for UNIDENTIFIED LEAXAGE the probability is small that the imperfection or crack associated with such leakage would grow ranidly. Hewever, in all cases, if the leakage rates exceed the values specified or the leakage is located and known to be PRESSURE EOUNDARY LEAXAGE, the reactor will be shutdown to allow further investication ~

and corrective action. The limit of 2 gpm incrsasa in UNIDENTIFIED LEAXAGE over a 24-hour period and the monitoring of drywell floor crain sump and drywell equipment drain tank flow rate at least ence every eight (8) hours conforms with NRC staff positions specified in NRC Generic Letter 88-01, "NRC Position en IGSCC in SWR Austenitic Stainless Steel Piping," as revised by HRC Safety Evaluation dated March 6,1990. The ACTION requirement for the 2 gpm increase in UNIDENTIFIED LEAXAGE limit ensures that such leakace is identified or a plant shutdcwn is initiated to allow further investication and corrective action. Once identified, reactor operation may c:ntinue dependeilt upon the impact on total leakage.

xihe ACTION requirements for pressure isolation valves (PIVs) are used in conjunction with the system specifications for which PIVs are listed in Table 3.4.3.2-1 and with primary containment isolation valve requirements to ensure that plant operation is appropriately limited.

- The Surveillance Requirements for the RCS pressure isolation valves provide added assurance of valve integrity thereby reducing tse probability of gross valve failure and consecuent intersystes LOCA. Leakage from the RCS pressure isolation valves is IDENTIFIED LEAKAGE and will be considered as a portion of the allowed limit.

. LIMERICK - UNIT 2 8 3/4 4-3 Amendment No.12 #R 0 41991

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3/4.'4:3.1 LEAKAGE DETECTION SYSTEMS' BACKGROUND l 1

!UFSAR Safety Design Basis (Ref. '1), . requires means. for detecting and,- to the extent ,

practical, identifying the location of the source of Reactor. Coolant System (RCS) !

PRESSURE BOUNDARY LEAKAGE. Regulatory Guide 1.45.-(Ref. 2) describes acceptable methods l for selecting leakage detection systems.

Limits on-leakage from the. reactor. coolant pressure boundary (RCPB)are required so that appropriate action'can be.taken before.the integrity of the RCPB is impaired. (Ref. 2).

! Leakage detection systems- for the RCS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitative measurement of leakage rates.

l Systems for separating the leakage of an identified source from an unidentified source -

l .are necessary to provide prompt and quantitative information to the operators to permit-them to take immediate corrective action. Leakage from the RCPB inside the drywell is

detected by at;least one of four(4) independently monitored variables which include

' drywell drain sump level changes over time yielding drain flow rates, and drywell

. gaseous radioactivity, drywell unit cooler condensate flow rate and drywell ,

pressure / temperature levels. The primary means of quantifying leakage in the drywell j L are the'drywell floor drain sump flow monitoring system for UNIDENTIFIED LEAKAGE and !

the-drywell equipment drain tank flow monitoring system for IDENTIFIED LEAKAGE. i IDENTIFIED leakage is not germane to this Tech. Spec and the associated drywell )

. equipment drain tank flow monitoring system is not included.

i The drywell floor drain sump flow monitoring system monitors UNIDENTIFIED LEAKAGE I collected ,in the floor drain sump. . UNIDENTIFIED LEAKAGE consists of leakage from RCPB components inside the drywell which are not normally subject to leakage and otherwise routed to the drywell equipment drain sump. The primary containment floor drain sump has transmitters that supply -level indication to the main control room via the plant

. monitoring' system. The floor drain semp level transmitters are associated with ;

High/ Low level switches that open/close the sump tank drain valves automatically. The

. level instrument processing unit calculates an average leak rate (gpm) for a given

measurement period which resets whenever the sump drain valve closes. The level !

- processing unit provides an ' alarm to the main-control room each time the average leak '

rate changes by a predetermined value since the last time the alarm was reset. For the drywell floor drain sump flow monitoring system, the setpoint basis is a 1 gpa change in UNIDENTIFIED LEAKAGE.

In addition to the drywell floor drain sump flow monitoring system described above, the discharge of each sump is monitored by an independent flow element. The measured flow

rate from the flow element is integrated and recorded. A main control room alam is

! -also provided to indicate an excessive sump discharge rate measured via the' flow

,. element. This system, referred to as the "drywell floor drain flow totalizer", is not L credited for. drywell floor drain sump flow monitoring system operability.

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! The primary containment' atmospheric gaseous radioactivity monitoring system continuously monitors the primary containment atmosphere for gaseous radioactivity levels. A sudden increase of raoloactivity, which may be attributed to RCPB steam or reactor water leakage, .is annunciated in the main control room. The primary containment atmospheric gaseous radioactivity monitoring system is not capable of quantifying leakage rates, but is sensitive enough to detect increased leakage rates of 1 gpm within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Larger changes in leakage rates are detected in proportionally shorter times.(Ref. 4). 1 Condensate from the eight drywell air coolers is routed to the drywell floor drain sump and .is monitored by a-. series of flow transmitters that provide indication and alarms in the main control room. The outputs from the flow transmitters are added together by summing units to. provide a total continuous condensate drain flow rate. The high flow 1

alarm setpoint is based on condensate drain flow rate in excess of 1 gpm over the currently identified preset leak rate. - The drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of RCS UNIDENTIFIED LEAKAGE (Ref. 5).

The drywell temperature and pressure monitoring systems provide an indirect method for '

detecting RCPB leakage. A temperature and/or pressure rise in the drywell above normal levels may be indicative of a reactor coolant or steam leakage. (Ref 6)1 APPLICABLE SAFETY ANALYSES A threat of- significant compromise to the RCPB exists if the barrier contains a crack that -is large.enough to propagate rapidly. Leakage rate limits are set low enough to detect the leakage emitted from a single crack in the RCPB (Refs. 7 and 8). Each of the leakage detection systems inside the drywell is designed with the capability of I detecting leakage less than the-established leakage rate limits and providing appropriate alarms of. excess leakage in the control room.

A control room alarm allows the coerators to evaluate the significance of the indicated leakage and, if necessary, shut :own the reactor for further investigation and corrective action. The' allowed leakage rates are well below the rates predicted for L

critical crack sizes (Ref. 8). Therefore, these actions provide adequate response before a significant break in the RCPB can occur.

RCS leakage detection instrumentation satisfies Criterion 1 of the NRC Policy Statement.

LIMITING CONDITION FOR OPERATION (LC01 The drywell floor drain sump flow monitoring system is required to quantify the l

UNIDENTIFIED LEAKAGE from the RCS. The other monitoring systems provide early alarms to the operators so closer examination of other detection systems will be made to determine the extent of any corrective action that may be required. With any leakage detection system inoperable, monitoring for leakage in the RCPB is degraded.

l+

%wh Q pge 3 APPLICABILITY In OPERATIONAL' CONDITIONS 1, 2. and 3. leakage detection systems are required to be OPERABLE to support LCO 3.4.3.2. This applicability is consistent with that for LCO 3.4.3.2.

ACTIONS-A.~ With the primary containment atmosphere gaseous monitoring system inoperable, grab samples. of the primary containment' atmosphere must be taken and analyzed to provide periodic leakage information. [Provided a sample is obtained-and analyzed once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,' the plant may be operated for up to 30 days to allow restoration of the radioactivity monitoring system. The plant may continue operation since other forms of drywell leakage detection are available.]

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval provides' periodic -information that is adequate to detect leakage. The .30 day Completion Time for Restoration recognizes other forms of

. leakage detection are. available. The Required ACTIONS are modified by a Note that states'that the provisions of LC0 3.0.4 are not applicable. As a result, an '

OPERATIONAL CONDITION change _is allowed when the primary containment atmospheric gaseous monitoring system is inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage.

B. With the drywell floor drain sump flow monitoring system inoperable, no other form of sampling can provide the equivalant information to quantify leakage at the 4 required 1 gps / hour sensitivity. Rraver, the primary containment atmospheric l

-gaseous monitor (and the primary containment air cooler condensate flow rate monitor] will.. provide indication of changes in leakage.

With the drywell floor drain sump . flow monitoring system inoperable, drywell condensate flow rate monitoring frequency increased from 12 to every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and UNIDENTIFIED LEAKAGE and total leakage being determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (Ref: SR 4.4.3.2.lb)-operation may continue for 30 days. To-the extent practical, the surveillance frequency change associated with the drywell condensate flow rate monitoring system, makes up for the loss of the drywell floor drain sump monitoring system which had a normal surveillance requirement to monitor leakage every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Also note that in this instance, the drywell floor drain tank flow totalizer will be used to comply _ with SR 4.4.3.2.lb. The 30 day Completion Time of the required ACTION is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available. The required ACTION is modified by a

- Note that states that the provisions of LCO 3.0.4 are not applicable. As a result, ,

an OPERATIONAL CONDITION change is allowed when the drywell floor drain sump l

~ monitoring system is inoperable. This allowance is provided because other '

-instrumentation is available to monitor RCS leakage.

i J

EE b pac j ACTIONS (Continued)

C. With the required primary containment air cooler condensate flow rate monitoring system inoperable, SR 4.4.3.1.a must be performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to provide periodic information of activity in the primary containment at a more frequent interval than the routine frequency of every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval provides periodic information that is adequate to detect leakage and recognizes that other forms of leakage detection are available. The required ACTION has been clarified to state that the additional surveillance requirement is not applicable if the required primary containment atrosphere gaseous radioactivity monitoring system is also inoperable. Consistent with SR 4.0.3, surveillances are not required to be performed on inoperable equipment. In this case, ACTION Statement A. and E. requirements apply.

D. With the primary containment pressure and temperature monitoring system inoperable, operation may continue for up to 30 days given the system's indirect capability to detect RCS leakage. However, other more limiting Tech Spec requirements associated with the primary containment pressure / temperature monitoring system will still apply.

E. With both the primary containment atmosphere gaseous radioactivity monitor and the primary containment air cooler condensate flow rate monitor inoperable, the only means of detecting leakage is the drywell floor drain sump monitor and the drywell pressure / temperature instrumentation. This condition does not provide the required diverse means of leakage detection. The required ACTION is to restore either of the inoperable monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period. The required ACTIONS are modified by a Note that states that the provisions of LCO 3.0.4 are not applicable. As a result, an OPERATIONAL CONDITION change is allowed when both the primary containment atmosphere gaseous radioactivity monitor and air cooler condensate flow rate monitors ~are inoperable. This allowance is provided because other instrumentation is available to monitor RCS leakage. While the primary containment atmospnere gaseous radioactivity monitor is INOPERABLE, Primary containment atmospheric grab samples will be taken and analyzed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months since ACTION Statement A. requirements also apply.

F. If any recuired ACTION of Conditions A, B, C, D or E cannot be met within the associated Completion Time, the plant must be brought to an OPERATIONAL CONDITION in which the LCO does not apply. To achieve this status, the plant must be brought to at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and COLD SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The allowed Completion Times are reasonable, based on operating experience, to perform the ACTIONS in an orderly manner ano without challenging plant systems.

SURVEILLANCE RE0VIREMENTS SR 4.4.3.i.a This SR is for the performance of a CHANNEL CHECK of the required primary containment atmospheric monitoring system. The check gives reasonable confidence that the Onannel is operatino properly. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonaole for detecting off normal conditions.

g E3ERk ' O P^oc

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' SURVEILLANCE REQUIREMENTS (Continued)

SR 4.4.3.1.b This SR is for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The test also verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper for detecting degradation.

SR 4.4.3.1.c This SR is for the performance of a CHANNEL CALIBRATION of required leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument-string, including the instruments located inside containment. The Frequency of 24 months is for a typical refueling cycle and considers channel reliability. Operating experience has proven this frequency to be acceptable.

SR 4.4.3 M This SR provides a routine check of primary containment pressure and temperature for indirect evidence of RCS leakage. Operating experience has proven this frequency to be acceptable.

REFERENCES

1. LGS UFSAR, Section 5.2.5.1.

2. Regulatory Guide 1.45, May 1973.

3. LGS UFSAR, Section 5.2.5.2.1.3. 1

4. LGS UFSAR, Section 5.2.5.2.1.5 1

5. LGS UFSAR, Section 5.2.5.2.1.4

6. LGS UFSAR, Section 5.2.5.2.1.l(2)

7. GEAP-5620, April 1968.

8. NUREG-75/067, October 1975. i l

9. LGS UFSAR, Section 5.2.5.6.

i

o, REACTOR COOLANT SYSTEM j 3/4.4.3 REACTOR COOLANT SYSTEM LEAKAGE

[fg /.GE DETECTION SYSTEMS LIMITING CONDITION FOR OPERATION

-3.4.3.1 The following reactor coolant leakage detection systams shall be OPERABLE:

a. The primary containment atmosphere gaseous radioactivity monitoring system, ;

1

b. The drywell floor drain sump flow monitoring system,

c. The drywell unit coolers condensate flow rate monitoring system, and l

d. The primary containment pressure and temperature monitoring' system. >

and 3.*

APPLLCABILLTY:-

OPERATIONAL "he pr mary containment CONDITIONS 1, 2,ivity monitor is not required to be gaseous radioact operable until Operational Condition 2. ;

AC" IONS:

N0"E: The provisions of 3.0.4 do not apply to ACTIONS A, B, D and E below.

A. With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND restore primary containment atmosphere gaseous radioactivity monitoring system to OPERABLE status within 30 days.

restore the B. drywell With the drywell floor floor drain drain sump sump flowsystem flow monitoring monitoring system INOPERABLE,ithin to OPERABLE status w 30 days AND increase monitoring frequency of drywell unit cooler condensate flow rate (SR 4.4.3.2.1.c) to once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

C. With the drywell unit' coolers condensate flow rate monitoring system INOPERABLE, AND the primary containment. atmosphere gaseous radioactivity monitoring system OPERABLE perform a channel check of the primar radioactIvitymonitoringsystem(SR4.4.3.1.c)ycontainmentatmospheregaseous once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

D. With the primary containment pressure and temperature monitoring system INOPERABLE restore the primary containment pressure and temp'erature monitoring systemtobPERABLEstatuswithin30 days. NOTE: All other ech Sonc Liinitina Conditions For Ooeration and Surveillance Reauirements assoc- med w< ;h t 1e primary containmen : pressure / temperature monitorino system st 1 ano' v. Affected Tech Spec Sections inc' ude: 3/4.3.7.5. 4.4.3.2.1. 1/4.6.1.6. and 3/4.6.1.7.

E. With the primary containment atmosphere gaseous radioactivity monitoring system INOPERABLE AND the drywell unit coolers condensate flow rate monitoring system INOPERABLE, restore the >rimary containment atmosphere gaseous radioactivity monitoring system to OPEMBLE status within 30 days OR restore the drywell unit coolers condensate flow rate monitoring system to OPERABLE status within 30 days.

With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, analyze grab samples of primary containment atmosphere at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

LIMERICK - UNI'T 2 3/4 4-8 a

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REACTOR COOLANT SYSTEM ACTIONS (Continued)

F. With any other two or more leak detection systems inoparable other than ACTION E above OR with required Actions and associated Complet.on Time of ACTIONS A, B 1 C DorEnotmet,beinHOTSHUTDOWNwithin12hoursANDinCOLD;HUTDOWNwitbin

.tbenext24 hours.

S'JRVEILLANCE REOUIREMENTS 4.4.3.1 The reactor coolant system leakage detection systems shall be demonstrated operable by:

a. Perform a CHANNEL CHECK of the primary containment atmosphere gaseous radioactivity monitoring system at.least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. Perform a CHANNEL FUNCTIONAL TEST of required leakage detection instrumentation at least once per 31 days. This does not apply to containment pressure and temperature monitoring system.

c. Perform a CHANNEL CALIBRATION of required leakage detection instrumentation at

.least once per 24 months. This does not apply to containment pressure and temperature monitoring system.

d. Monitor primary containment pressure once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months MQ monitor primary containment temperature at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , i

LIMERICK - UNIT 2 3/4 4-Ba

E ,,;.

REACTOR COOLANT SYSTEM BASES 3/4.4.3 REACTOR COOLANT SYSTEM LEAKAGE 3/4.4.3.1 LEAKAGE DETECTION SYSTDj1 BACKGROUND

'UFSAR Safety Design Basis (Ref. 1), requires means for detecting a'nd, to the extent practical, PRESSUREidentifying BOUNDARYthe location LEAKAGE. of the source Regulatory of (Ref.

Guide 1.45 Reactor Coolant

2) describes Systemmet acceptable (RCS) hods for selecting leakage detection systems.

l Limits on leakage from the reactor coolant pressure boundary (RCPB) are required so that appropriate action can be taken before the integrity of the RCPB is impai' red (Ref.

2). Leakage detection systems for the RCS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitative measurement of leakage rates.

Systems for separating the leakage of an identified source from an unidentified source are necessary to provide prompt and quantitative information to the operators to permit them to taki immediate corrective action. Leakage from the RCPB inside the drywell is detected by at least one of four (4) independently monitored variables which include drywell drain sump level changes over time yielding drain flow rates, and drywell '

1 gaseousradioactivitylevels.~

pressure / temperature drywell unit cooler The primary condensate means flow rate of quantifying and drywell leakage in the drywell !

are the'drywell floor drain sum) flow monitoring system for UNIDENTIFIED LEAKAGE and the drywell equipment drain tan ( flow monitoring system for IDENTIFIED LEAKAGE.

IDENTIFIED leakage is not germane to this Tech Spec and the associated drywell equipment drain tank flow monitoring system is not included.

The drywell floor drain sump flow monitoring system monitors UNIDENTIFIED LEAKAGE 4 collected 'in the floor drain sump. UNIDENTIFIED LEAKAGE consists of leakage from RCPB components inside the drywell which are not normally subject to leakage and otherwise routed to the drywell equipment drain sump. The primary containment floor drain sump has transmitters that supply level indication to the main control room via the plant monitoring system. The floor drain sump level transmitters we associated with High/ Low level switches that open/close the sump tank drain valves automatically. The level instrument processing unit calculates an average leak rate (gpm

measurement period which resets whenever the sump drain valve closes.) The levelfor a given processing unit provides an alarm to the main control room each time the average leak i rate' changes by a predetermined value since the last time the alarm was reset. For the !'

drywcl1 floor drain sump flow monitoring system, the setpoint basis is a 1 gpm change in UNIDENTIFIED LEAKAGE.

In addition-to the 'drywell floor drain sump flow monitoring system described above, tho ,

discharge:of each sump is monitored by an independent flow element. The measured flow !

rate from the flow element is integrated and recorded. A main control room alarm is also provided to indicate an excessive sump discharge rate measured via the flow element. This system, referred to as the "drywell floor drain flow totalizer", is not credited for drywell floor drain sump flow monitoring system operability.

LIMERICK - UNIT-2 B 3/4 4-3

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ML20195G048

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