ML22055A601

License Amendment Request - Proposed Changes to Technical Specification 3.3.7.4, Remote Shutdown System Instrumentation and Controls

ML22055A601
Person / Time
Site:	Limerick
Issue date:	02/24/2022
From:	David Helker Constellation Energy Generation
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML22055A601 (32)

Text

200 Exelon Way Kennett Square, PA 19348 www.ConstellationEnergy.com 10 CFR 50.90 February 24, 2022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

License Amendment Request - Proposed Changes to Technical Specification 3.3.7.4, Remote Shutdown System Instrumentation and Controls In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (Limerick), Units 1 and 2, respectively.

This license amendment request proposes changes to TS 3.3.7.4, Remote Shutdown System Instrumentation and Controls. The proposed changes will increase the allowed outage time for inoperable Remote Shutdown System components to a time that is more consistent with their safety significance. They will also delete Table 3.3.7.4-1, Remote Shutdown System Instrumentation and Controls, to be relocated to the Technical Requirements Manual (TRM) where it will be directly controlled by CEG under the requirements of 10 CFR 50.59.

The proposed changes would make the Limerick TS requirements consistent with NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants, TS 3.3.3.2, Remote Shutdown System.

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

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

This amendment request contains no regulatory commitments.

provides the evaluation of the proposed changes. Attachment 2 provides a copy of the marked-up TS pages that reflect the proposed changes. Attachment 3 provides a copy of the marked-up TS Bases pages that reflect the proposed changes for information only.

CEG requests approval of the proposed amendments by February 24, 2023. Upon NRC approval, the amendments shall be implemented within 60 days of issuance.

License Amendment Request Proposed Changes to TS 3.3.7.4 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 February 24, 2022 Page 2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), CEG is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

Should you have any questions concerning this submittal, please contact Glenn Stewart at 610-765-5529.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 24th day of February 2022.

Respectfully, David P. Helker Sr. Manager, Licensing Constellation Energy Generation, LLC Attachments:

1.

Evaluation of Proposed Changes

2.

Markup of Proposed Technical Specifications Pages

3.

Markup of Proposed Technical Specifications Bases Pages cc:

Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - Limerick Generating Station NRC Project Manager, NRR - Limerick Generating Station Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection

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

Subject:

Proposed Changes to Technical Specification 3.3.7.4, Remote Shutdown System Instrumentation and Controls 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for the Proposed Changes 2.4 Description of the Proposed Changes

4.0 REGULATORY EVALUATION

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

6.0 REFERENCES

License Amendment Request Proposed Changes to TS 3.3.7.4 Page 1 of 10 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes 1.0

SUMMARY

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

This license amendment request proposes changes to TS 3.3.7.4, Remote Shutdown System Instrumentation and Controls. The proposed changes will increase the allowed outage time for inoperable Remote Shutdown System components to a time that is more consistent with their safety significance. They will also delete Table 3.3.7.4-1, Remote Shutdown System Instrumentation and Controls, to be relocated to the Technical Requirements Manual (TRM) where it will be directly controlled by CEG under the requirements of 10 CFR 50.59.

The proposed changes would make the Limerick TS requirements consistent with the Improved Standard Technical Specifications (ISTS) specified in NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants, TS 3.3.3.2, Remote Shutdown System.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The Remote Shutdown System (RSS) provides the means for achieving and maintaining safe shutdown conditions from outside the main control room in the unlikely event the main control room becomes uninhabitable.

The primary control station for the RSS is the remote shutdown panel (RSP). In the event of a failure at the RSP, sufficient redundant safety grade instrumentation and controls are available remote from both the main control room and the RSP to ensure that safe shutdown of the reactor can be achieved in accordance with the requirements of 10 CFR 50, Appendix A, General Design Criteria (GDC) 19. The systems for which the RSP provides remote instrumentation and controls to accomplish this function are as follows:

Reactor Core Isolation Cooling (RCIC) system to maintain reactor vessel water level.

Main steam line safety/relief valves (manual actuation) to reduce reactor vessel pressure.

Nuclear boiler instrumentation to monitor reactor vessel pressure and level.

Residual Heat Removal (RHR) system for suppression pool cooling and shutdown cooling.

RHR Service Water system to supply cooling water to the RHR heat exchanger.

Emergency Service Water (ESW) system to supply cooling water to RCIC and RHR room coolers, RHR motor oil and seal coolers, and the emergency diesel generator.

Containment and suppression pool system monitoring instrumentation.

Standby AC power that supplies power to the above systems.

License Amendment Request Proposed Changes to TS 3.3.7.4 Page 2 of 10 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes 2.2 Current Technical Specification Requirements The current TS 3.3.7.4, Remote Shutdown System Instrumentation and Controls, Limiting Condition for Operability (LCO) states, The remote shutdown system instrumentation and controls shown in Table 3.3.7.4-1 shall be OPERABLE.

TS 3.3.7.4 ACTIONS a. and b. state:

a.

With the number of OPERABLE remote shutdown system instrumentation channels less than required by Table 3.3.7.4-1, restore the inoperable channel(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b.

With the number of OPERABLE remote shutdown system controls less than required in Table 3.3.7.4-1, restore the inoperable control(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SURVEILLANCE REQUIREMENT 4.3.7.4.1 states, Each of the above required remote shutdown monitoring instrumentation channels shall be demonstrated OPERABLE by performance of the CHANNEL CHECK* and CHANNEL CALIBRATION operations at the frequencies specified in the Surveillance Frequency Control Program.

SURVEILLANCE REQUIREMENT 4.3.7.4.2 states, Each of the above remote shutdown control switch(es) and control circuits shall be demonstrated OPERABLE by verifying its capability to perform its intended function(s) in accordance with the Surveillance Frequency Control Program.

2.3 Reason for the Proposed Changes The proposed changes, as shown in Section 2.4 and described in Section 3.0 below, revise TS 3.3.7.4 to be consistent with ISTS 3.3.3.2. In doing so they remove unnecessary information and relocate it to a licensee controlled document preventing needless expenditure of licensee and NRC resources processing license amendments to revise tables when the licensee can adequately control the information.

The proposed changes also increase the Allowed Outage Time for inoperable Remote Shutdown System components from 7 days to 30 days which is more consistent with their safety significance and is consistent with the ISTS 3.3.3.2, REQUIRED ACTION A.1, COMPLETION TIME.

2.4 Description of the Proposed Changes TS 3.3.7.4 is being revised as shown below:

License Amendment Request Proposed Changes to TS 3.3.7.4 Page 3 of 10 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes LCO:

3.3.7.4 The remote shutdown system instrumentation and controls shown in Table 3.3.7.4.1 functions shall be OPERABLE.

ACTION**:

a.

With one or more of the number of OPERABLE remote shutdown system instrumentation channels less than required by Table 3.3.7.4-1 required functions inoperable, restore the inoperable channel(s) function(s) to OPERABLE status within 7 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b.

With the number of OPERABLE remote shutdown system controls less than required in Table 3.3.7.4-1, restore the inoperable control(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SURVEILLANCE REQUIREMENTS:

4.3.7.4.1 Each of the above normally energized required remote shutdown monitoring instrumentation channels shall be demonstrated OPERABLE by performance of the a CHANNEL CHECK* and CHANNEL CALIBRATION operations at the frequencies frequency specified in the Surveillance Frequency Control Program.

4.3.7.4.2 Each required control circuit and transfer switch of the above remote shutdown control switch(es) and control circuits shall be demonstrated OPERABLE by verifying its capability to perform its intended function(s) in accordance with the Surveillance Frequency Control Program.

4.3.7.4.3 Each required instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CALIBRATION at the frequency specified in the Surveillance Frequency Control Program.

• • NOTE: Separate ACTION entry is allowed for each function.

Table 3.3.7.4-1 is being deleted and relocated to the Technical Requirements Manual (TRM) where it will be directly controlled by CEG. Revisions to the TRM are reviewed pursuant to 10 CFR 50.59. The APPLICABILITY for LCO 3.3.7.4 is not being revised.

The marked-up TS pages that reflect the proposed changes are provided in Attachment 2. provides a copy of the marked-up TS Bases pages that reflect the proposed changes for information only. Upon approval the TS Bases will be revised in accordance with the TS Bases Control Program.

3.0 TECHNICAL EVALUATION

The technical basis for each proposed change listed in Section 2.4 is provided below.

License Amendment Request Proposed Changes to TS 3.3.7.4 Page 4 of 10 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes 3.1 Revision to TS 3.3.7.4 LCO for the Remote Shutdown System The proposed change revises TS 3.3.7.4 Limiting Condition for Operation (LCO) to simply state that the Remote Shutdown System functions shall be OPERABLE. Reference to instrumentation as shown in the associated Table 3.3.7.4-1 is deleted.

Current TS 3.3.7.4, Table 3.3.7.4-1 lists the specific instruments and controls for the remote shutdown system. The proposed change will relocate this information to licensee controlled documents.

The definition of OPERABLE - OPERABILITY in TS states that a system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s) and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function(s) are also capable of performing their related support function(s).

This definition provides adequate guidance for determining what instrumentation and controls are necessary for a particular Remote Shutdown System function. The ability to transfer control of a function from the main control room to the remote shutdown panel is a required support function by the TS definition of operable. Therefore, listing specific instrumentation and controls in the TS is unnecessary to provide adequate assurance that the functions can be performed.

GDC 19 requires that remote shutdown capability be provided. The functions will be described in the TRM, which is sufficient to assure that the system will be OPERABLE. Listing specific instrumentation and controls in TS may lead to needless expenditure of licensee and NRC resources processing license amendments to revise the table when the licensee can adequately control the information. These details are not necessary to adequately describe the actual regulatory requirement.

In addition, SR 4.3.7.4.2 still requires the remote shutdown panel transfer function to be tested, which is sufficient to assure that the system will be operable. Relocation of the list to the TRM is acceptable because the TRM is consistent with the design basis as described in the Updated Final Safety Analysis Report. Revisions to the TRM are reviewed pursuant to 10 CFR 50.59 as described in UFSAR Section 13.5.3. Changes to the TRM will not affect the requirements of the LCO for the Remote Shutdown System In addition, precedent for the relocation has been established with Technical Specifications Task Force (TSTF) Traveler TSTF-266, "Eliminate the Remote Shutdown System Table of Instrumentation and Controls," and Revision 2 of NUREG-1433, which incorporated TSTF-266 into the ISTS. Moreover, relocation of the subject list to the TRM is acceptable because its inclusion in the TS does not fall within the criteria for mandatory inclusion in the TS in 10 CFR 50.36(c)(2)(ii). Sufficient regulatory controls exist under the regulations to maintain the effect of the provisions in the TRM.

License Amendment Request Proposed Changes to TS 3.3.7.4 Page 5 of 10 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Therefore, the list can be moved to a licensee controlled document without a significant impact on safety. Placing these details in controlled documents provides adequate assurance that they will be maintained.

3.2 Revision to TS 3.3.7.4 ACTION a.

The proposed change revises TS 3.3.7.4, ACTION a. to delete the reference to monitoring instrumentation channels as shown in the associated Table 3.3.7.4-1. The ACTION will be simplified to state the entry condition for the action as "one or more of the required functions inoperable." In addition, the proposed change adds a note to permit separate condition entry for each function.

Table 3.3.7.4-1 is being deleted as discussed in Section 3.1. above. This proposed change to TS 3.3.7.4, ACTION a. is consistent with the ISTS 3.3.3.2, CONDITION A. wording.

The proposed note is also consistent with ISTS. Without the proposed note, the proposed new wording could be interpreted as not allowing separate entry for each function. Consequently, the proposed change is considered to be an administrative change.

3.3 TS 3.3.7.4 ACTION a. Time Change The proposed change revises TS 3.3.7.4, ACTION a. to change the allowed outage time from 7 days to 30 days.

Extending the allowed outage time to 30 days is reasonable based on operating experience and the low probability of an event occurring that would require the control room to be evacuated.

This proposed change is consistent with the ISTS 3.3.3.2, CONDITION A, COMPLETION TIME.

3.4 Deletion of TS 3.3.7.4 ACTION b.

The proposed change deletes TS 3.3.7.4, ACTION b.

Table 3.3.7.4-1 is being deleted and relocated to a licensee controlled document; therefore, reference to it is no longer applicable. In addition, the action is encompassed by ACTION a.

through rewording to now state one or more required functions.

3.5 Deletion of Table 3.3.7.4-1 The proposed change deletes Table 3.3.7.4-1 and relocates the Remote Shutdown System equipment information to the TRM.

Deletion of the table is discussed in Section 3.1. above. In addition, the Table was removed from NUREG-1433 by the adoption of TSTF-266 as described in Section 3.1 above.

License Amendment Request Proposed Changes to TS 3.3.7.4 Page 6 of 10 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes 3.6 Revisions to SR 4.3.7.4.1 and Addition of SR 4.3.7.4.3 The proposed change revises Surveillance Requirement (SR) 4.3.7.4.1 and adds SR 4.3.7.4.3 to:

a) Delete reference to Table 4.3.7.4-1 which is being deleted, b) Relocate CHANNEL CALIBRATION to a new SR 4.3.7.4.3, c) Require the channel check only for normally energized Remote Shutdown System instrumentation, and d) Replace the with a.

Evaluation of the respective proposed changes is provided below.

a. Table 4.3.7.4-1 deletion is described in Section 3.1 above.

b. Splitting out the CHANNEL CALIBRATION into a new SR and rewording the SR makes them consistent with ISTS SR 3.3.3.2. Relocating the channel calibration to SR 4.3.7.4.3 continues to meet the requirements of 10 CFR 50.36(c)(3) for channel calibration of instrument channels because the proposed SR effectively maintains the existing TS requirement for channel calibration.

c. Performing a channel check of normally de-energized instrumentation is not practical or feasible during power operation. This change is consistent with ISTS SR 3.3.3.2.1.

d. This proposed change is an administrative change to ensure that, with the revisions mentioned above, the SR wording remains grammatically correct.

3.7 Revision to SR 4.3.7.4.2 The proposed change revises SR 4.3.7.4.2 replacing, Each of the above remote shutdown switch(es) and control circuits with Each required control circuit and transfer switch.

These changes make the SR wording consistent with ISTS SR 3.3.3.2 and reflect the removal of TS Table 3.3.7.4-1. The proposed change is functionally equivalent to the existing SR and demonstrates that the required control circuit and control switch are operable.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36, Technical Specifications, identifies the requirements for the Technical Specification categories for operating power plants: (1) Safety limits, limiting safety system settings, and limiting control settings, (2) Limiting conditions for operation, (3)

Surveillance requirements, (4) Design features, (5) Administrative controls, (6)

Decommissioning and (7) Initial notification, and (8) Written Reports. For Limiting conditions for operation, 10 CFR 50.36 states: Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. For Surveillance

License Amendment Request Proposed Changes to TS 3.3.7.4 Page 7 of 10 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Requirements, 10 CFR 50.36 states: Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The Remote Shutdown System is required to provide equipment at appropriate locations outside the control room with a capability to promptly shut down and maintain the unit in a safe condition thus satisfying Criterion 4 of 10 CFR 50.36(c)(2)(ii). Limerick UFSAR Section 7.4.1.4 describes the design of the Remote Shutdown System and its design bases. The proposed changes to TS 3/4.3.7.4 do not affect the UFSAR description of the Limerick Remote Shutdown System, its design bases, or performance.

10 CFR 50 Appendix A, GDC 19, "Control Room," states that equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures. Since no physical changes are being made, and current design bases are not being affected, there is no impact on compliance with GDC 19.

4.2 Precedents The changes proposed herein to the Remote Shutdown System are similar to those previously approved by the NRC for the South Texas Project Electric Generating Station and Hope Creek Generating Station as discussed below.

South Texas Project Electric Generating Station By letter dated November 4, 2003 (ADAMS Accession ML033140308), as supplemented by letter dated June 29, 2004 (ML041890388), STP Nuclear Operating Company requested NRC approval of a South Texas Project Generating Station TS change to the Remote Shutdown System to be consistent with the requirements of NUREG-1431. The NRC approved the change in License Amendment Nos. 163/152 for STP Units 1 and 2, issued August 20, 2004 (ML042370841). The amendment issued for STP was substantively equivalent to the amendment requested herein for Limerick, in that it revised the TS associated with the Remote Shutdown System to be consistent with the requirements of NUREG-1431, which is substantively equivalent to the NUREG-1433 TS for the Remote Shutdown System.

Hope Creek Generating Station By letter dated October 20, 2018 (ADAMS Accession ML18304A191), PSEG Nuclear LLC requested NRC approval of a Hope Creek Generating Station (HCGS) TS change to the Remote Shutdown System to be consistent with the requirements of NUREG-1433. The NRC approved the change in License Amendment No. 217 for HCGS, issued August 6, 2019 (ML19186A205). The amendment issued for HCGS was substantively equivalent to the amendment requested herein for Limerick, in that it revised the TS

License Amendment Request Proposed Changes to TS 3.3.7.4 Page 8 of 10 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes associated with the Remote Shutdown System to be consistent with the requirements of NUREG-1433.

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (Limerick), Units 1 and 2, respectively.

This license amendment request proposes changes to TS 3.3.7.4, Remote Shutdown System Instrumentation and Controls. The proposed changes will increase the allowed outage time for inoperable Remote Shutdown System components to a time that is more consistent with their safety significance. They will also delete Table 3.3.7.4-1, Remote Shutdown System Instrumentation and Controls, to be relocated to the Technical Requirements Manual (TRM) where it will be directly controlled by CEG under the requirements of 10 CFR 50.59.

The proposed changes would make the Limerick TS requirements consistent with NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants, TS 3.3.3.2, Remote Shutdown System.

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

1.

Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed TS amendment does not involve potential accident initiators; therefore, there is no significant increase in the probability of an accident previously evaluated. There is no proposed change to the design basis or configuration of the plant, and the extension of the allowed outage time of the Remote Shutdown System functions is consistent with the low probability of an event requiring control room evacuation during the allowed outage time and does not have a significant effect on safety.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

License Amendment Request Proposed Changes to TS 3.3.7.4 Page 9 of 10 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Response: No The proposed amendment does not involve physical alteration of the plant. No new equipment is being introduced, and installed equipment is not being operated in a new or different manner. There is no change being made to the parameters within which the plant is operated. There are no setpoints at which protective or mitigating actions are initiated that are affected by this proposed action. The changes do not alter assumptions made in the safety analysis. This proposed action will not alter the manner in which equipment operation is initiated, nor will the functional demands on credited equipment be changed. No alteration is proposed to the procedures that ensure the plant remains within analyzed limits, and no change is being made to procedures relied upon to respond to an off-normal event. As such, no new failure modes are being introduced.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Do the proposed changes involve a significant reduction in a margin of safety?

Response: No Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident.

These barriers include the fuel cladding, the reactor coolant system, and the containment system. The proposed changes, which make the Limerick TS for Remote Shutdown System consistent with the requirements of NUREG-1433, do not exceed or alter a setpoint, design basis or safety limit.

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

Based on the above evaluation, CEG concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c), and accordingly, a finding of "no significant hazards consideration" is justified.

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

License Amendment Request Proposed Changes to TS 3.3.7.4 Page 10 of 10 Remote Shutdown System Instrumentation and Controls Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes

5.0 ENVIRONMENTAL CONSIDERATION

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

6.0 REFERENCES

See Section 4.2 above.

ATTACHMENT 2 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Changes to Technical Specification 3.3.7.4, Remote Shutdown System Instrumentation and Controls Markup of Proposed Technical Specifications Pages Unit 1 TS Page 3/4 3-76 3/4 3-77 3/4 3-78 3/4 3-79 3/4 3-80 3/4 3-81 3/4 3-82 Unit 2 TS Page 3/4 3-76 3/4 3-77 3/4 3-78 3/4 3-79 3/4 3-80 3/4 3-81 3/4 3-82

INSTRUMENTATION REMOTE SHUTDOWN SYSTEM INSTRUMENTATION AND CONTROLS LIMITING CONDITION FOR OPERATION 3.3.7.4 The remote shutdown system instrumentation and controls shown in Table 3.3.7.4-1 shall be OPERABLE.

APPLICABILITY:

OPERATIONAL CONDITIONS 1 and 2.

ACTION:

a.

With the number of OPERABLE remote shutdown system instrumentation channels less than required by Table 3.3.7.4-1, restore the inoperable channel(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b.

With the number of OPERABLE remote shutdown system controls less than required in Table 3.3.7.4-1, restore the inoperable control(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.3.7.4.1 Each of the above required remote shutdown monitoring instrumentation channels shall be demonstrated OPERABLE by performance of the CHANNEL CHECK*

and CHANNEL CALIBRATION operations at the frequencies specified in the Surveillance Frequency Control Program.

4.3.7.4.2 Each of the above remote shutdown control switch(es) and control circuits shall be demonstrated OPERABLE by verifying its capability to perform its intended function(s) in accordance with the Surveillance Frequency Control Program.

• Control is not required to be transferred to perform the CHANNEL CHECK.

LIMERICK - UNIT 1 3/4 3-76 Amendment No. 71, 169, 186 functions one or more of required functions inoperable

• • NOTE: Separate ACTION entry is allowed for each function.

function(s) 30 normally energized a

frequency required control circuit and transfer switch 4.3.7.4.3 Each required instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CALIBRATION at the frequency specified in the Surveillance Frequency Control Program.

INSERT

TABLE 3.3.7.4-1 REMOTE SHUTDOWN SYSTEM INSTRUMENTATION AND CONTROLS MINIMUM INSTRUMENTS INSTRUMENT OPERABLE

1.

Reactor Vessel Pressure 1

2.

Reactor Vessel Water Level 1

3.

Safety/Relief Valve Position, 3 valves 1/valve

4.

Suppression Chamber Water Level 1

5.

Suppression Chamber Water Temperature 1

6.

Drywell Pressure 1

7.

Drywell Temperature 1

8.

RHR System Flow 1

9.

RHR Service Water Pump Discharge Pressure 1

10.

RHR Heat Exchanger Service Water Outlet Pressure 1

11.

RCIC System Flow 1

12.

RCIC Turbine Speed 1

13.

Emergency Service Water Pump Discharge Pressure 1

14.

Condensate Storage Tank Level 1

15.

RHR Heat Exchanger Bypass Valve (HV51-1F048A) Position Indication (0 - 100%)

1

16.

RCIC Turbine Tripped Indication 1

17.

RCIC Turbine Bearing Oil Pressure Low Indication 1

18.

RCIC LP Bearing Oil Temperature High Indication 1

19.

RHR Heat Exchanger Discharge Line High Radiation Indication 1

LIMERICK - UNIT 1 3/4 3-77 Amendment No. 45 THE INFORMATION FROM THIS TECHNICAL SPECIFICATIONS SECTION HAS BEEN RELOCATED TO THE TRM. TECHNICAL SPECIFICATIONS PAGES 3/4 3-78 THROUGH 3/4 3-82 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITTED.

TABLE 3.3.7.4-1 (Continued)

REMOTE SHUTDOWN SYSTEM CONTROLS RCIC SYSTEM HSS-49-191 Control-Transfer Switch HSS-49-192 Control-Transfer Switch HSS-49-193 Control-Transfer Switch HSS-49-195 Control-Transfer Switch HSS-49-196 Control-Transfer Switch HV-49-1F076 Control-Steam Line warmup bypass valve HV-49-1F060 Control-RCIC turb exhaust to suppression pool isolation HV-50-112 Control-Turb trip throttle valve HV-50-1F045 Control-Turbine steam supply valve HV-49-1F008 Control-Turbine steam line outboard isolation valve HV-49-1F007 Control-Turbine steam line inboard isolation valve HV-49-1F031 Control-RCIC pump suction from suppression pool HV-49-1F029 Control-RCIC pump suction from suppression pool HV-49-1F010 Control-RCIC pump suction from condensate storage tank HV-49-1F019 Control-Minimum flow bypass to suppression pool HV-49-1F022 Control-Test return to condensate storage tank HV-50-1F046 Control-RCIC turbine cooling water valve HV-49-1F012 Control-RCIC pump disch valve HV-49-1F013 Control-RCIC pump disch valve 10P220 Control-Vacuum tank condensate pump 10P219 Control-Barometric condenser vacuum pump HV-49-1F002 Control-Barometric condenser vacuum pump disch LIMERICK - UNIT 1 3/4 3-78 Amendment No. 33

Table 3.3.7.4-1 (Continued)

RCIC SYSTEM (Continued)

HV-49-1F080 Control-Vacuum breaker outboard isolation valve HV-49-1F084 Control-Vacuum breaker inboard isolation valve FIC-49-1R001 Controller-RCIC discharge flow control E51-545 RCIC Turbine Trip Bypass NUCLEAR BOILER SYSTEM HSS-41-191 Control-Transfer switch PSV-41-1F013A Control-Main steam line safety/relief valve PSV-41-1F013C Control-Main steam line safety/relief valve PSV-41-1F013N Control-Main steam line safety/relief valve RHR SYSTEM HSS-51-192 Control-Transfer switch HSS-51-193 Control-Transfer switch HSS-51-194 Control-Transfer switch HSS-51-195 Control-Transfer switch HSS-51-196 Control-Transfer switch HSS-51-197 Control-Transfer switch HSS-51-198 Control-Transfer switch HV-51-1F009 Control-RHR pump shutdown cooling suction inboard isolation HV-51-1F008 Control-RHR shutdown cooling suction outboard isolation HV-51-1F006A Control-1A RHR loop shutdown cooling suction HV-51-1F006B Control-1B RHR loop shutdown cooling suction HV-51-1F004A Control-1A RHR pump suction 1AP202 Control-1A RHR pump LIMERICK - UNIT 1 3/4 3-79

TABLE 3.3.7.4-1 (Continued)

RHR SYSTEM (Continued)

HV-43-1F023A Control-Recirculation pump A suction valve HSS-43-191 Control-Transfer switch HV-51-1F007A Control-1A RHR pump minimum flow bypass valve HV-51-1F048A Control-1A heat exchanger shell side bypass HV-51-1F015A Control-1A shutdown cooling injection valve HV-51-1F016A Control-Reactor containment spray HV-51-1F017A Control-1A RHR loop injection valve HV-51-1F024A Control-1A RHR loop test return HV-51-1F027A Control-Suppression pool sparger isolation HV-51-1F047A Control-1A Heat exchanger shell side inlet HV-51-1F003A Control-1A Heat exchanger shell side outlet HV-51-1F049 Control-RHR Discharge to radwaste outboard isolation HV-51-125A Control-1A/1C test return line to suppression pool RHR SERVICE WATER SYSTEM HSS-12-015A-2 Control-Spray pond/cooling tower select HSS-12-015C-2 Control-Spray pond/cooling tower select HSS-12-016A-2 Control-Spray/bypass select HSS-12-016C-2 Control-Spray/bypass select LIMERICK - UNIT 1 3/4 3-80 Amendment No. 14, 65, 74

Table 3.3.7.4-1 (Continued)

RHR SERVICE WATER SYSTEM (Continued)

HSS-12-094 Control-Transfer switch HSS-12-093 Control-Transfer switch HV-51-1F014A Control-1A RHR heat exchanger tube side inlet OAP506 Control-RHR Service Water pump HV-51-1F068A Control-1A RHR Heat exchanger tube side outlet EMERGENCY SERVICE WATER SYSTEM OAP548 Control-A emergency service water pump HV-11-011A Control-A emergency service water disch to RHR service water HSS-11-091 Control-Transfer switch HSS-11-092 Control-Transfer switch HSS-11-093 Control-Transfer switch The following valves of the ESW and RHRSW system are actuated by signals from the transfer switches:

HV-12-005 ESW and RHRSW pumps wetwell intertie gate HV-11-015A ESW loop A discharge to RHRSW loop B HV-12-017A ESW and RHRSW cooling tower return cross-tie STANDBY AC POWER SUPPLY 152-11509/CSR 101-D11 Safeguard SWGR feeder bkr.

152-11609/CSR 101-D12 Safeguard SWGR feeder bkr.

152-11709/CSR 101-D13 Safeguard SWGR feeder bkr.

152-11502/CSR 201-D11 Safeguard SWGR feeder bkr.

152-11602/CSR 201-D12 Safeguard SWGR feeder bkr.

152-11702/CSR 201-D13 Safeguard SWGR feeder bkr.

152-11505/CSR D114 Safeguard LC XFMR breaker LIMERICK - UNIT 1 3/4 3-81 Amendment No. 33

Table 3.3.7.4-1 (Continued)

STANDBY AC POWER SUPPLY (Continued) 152-11605/CSR D124 Safeguard LC XFMR breaker 152-11705/CSR D134 Safeguard LC XFMR breaker 143-115/CS Transfer switch 143-116/CS Transfer switch 143-117/CS Transfer switch LIMERICK - UNIT 1 3/4 3-82

INSTRUMENTATION REMOTE SHUTDOWN SYSTEM INSTRUMENTATION AND CONTROLS LIMITING CONDITION FOR OPERATION 3.3.7.4 The remote shutdown system instrumentation and controls shown in Table 3.3.7.4-1 shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1 and 2.

ACTION:

a.

With the number of OPERABLE remote shutdown system instrumentation channels less than required by Table 3.3.7.4-1, restore the inoperable channel(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b.

With the number of OPERABLE remote shutdown system controls less than required in Table 3.3.7.4-1, restore the inoperable control(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.3.7.4.1 Each of the above required remote shutdown monitoring instrumentation channels shall be demonstrated OPERABLE by performance of the CHANNEL CHECK*

and CHANNEL CALIBRATION operations at the frequencies specified in the Surveillance Frequency Control Program.

4.3.7.4.2 Each of the above remote shutdown control switch(es) and control circuits shall be demonstrated OPERABLE by verifying its capability to perform its intended function(s) in accordance with the Surveillance Frequency Control Program.

• Control is not required to be transferred to perform the CHANNEL CHECK.

LIMERICK - UNIT 2 3/4 3-76 Amendment No. 34, 132, 147 functions one or more of required functions inoperable function(s) 30 normally energized a

frequency required control circuit and transfer switch 4.3.7.4.3 Each required instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CALIBRATION at the frequency specified in the Surveillance Frequency Control Program.

INSERT

• • NOTE: Separate ACTION entry is allowed for each function.

TABLE 3.3.7.4-1 REMOTE SHUTDOWN SYSTEM INSTRUMENTATION AND CONTROLS MINIMUM INSTRUMENTS INSTRUMENT OPERABLE

1. Reactor Vessel Pressure 1

2. Reactor Vessel Water Level 1

3. Safety/Relief Valve Position, 3 valves 1/valve

4. Suppression Chamber Water Level 1

5. Suppression Chamber Water Temperature 1

6. Drywell Pressure 1

7. Drywell Temperature 1

8. RHR System Flow 1

9. RHR Service Water Pump Discharge Pressure 1

10. RHR Heat Exchanger Service Water Outlet Pressure 1

11. RCIC System Flow 1

12. RCIC Turbine Speed 1

13. Emergency Service Water Pump Discharge Pressure 1

14. Condensate Storage Tank Level 1

15. RHR Heat Exchanger Bypass Valve (HV-C-51-2F048A) Position Indication (0 - 100%)

1

16. RCIC Turbine Tripped Indication 1

17. RCIC Turbine Bearing Oil Pressure Low Indication 1

18. RCIC Bearing Oil Temperature High Indication 1

19. RHR Heat Exchanger Discharge Line High Radiation Indication 1

LIMERICK - UNIT 2 3/4 3-77 THE INFORMATION FROM THIS TECHNICAL SPECIFICATIONS SECTION HAS BEEN RELOCATED TO THE TRM. TECHNICAL SPECIFICATIONS PAGES 3/4 3-78 THROUGH 3/4 3-82 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITTED.

Amendment No.

TABLE 3.3.7.4-1 (Continued)

REMOTE SHUTDOWN SYSTEM CONTROLS RCIC SYSTEM HSS-49-291 Control-Transfer Switch HSS-49-292 Control-Transfer Switch HSS-49-293 Control-Transfer Switch HSS-49-295 Control-Transfer Switch HSS-49-296 Control-Transfer Switch HV-49-2F076 Control-Steam Line warmup bypass valve HV-49-2F060 Control-RCIC turb exhaust to suppression pool isolation HV-50-212 Control-Turb trip throttle valve HV-50-2F045 Control-Turbine steam supply valve HV-49-2F008 Control-Turbine steam line outboard isolation valve HV-49-2F007 Control-Turbine steam line inboard isolation valve HV-49-2F031 Control-RCIC pump suction from suppression pool HV-49-2F029 Control-RCIC pump suction from suppression pool HV-49-2F010 Control-RCIC pump suction from condensate storage tank HV-49-2F019 Control-Minimum flow bypass to suppression pool HV-49-2F022 Control-Test return to condensate storage tank HV-50-2F046 Control-RCIC turbine cooling water valve HV-49-2F012 Control-RCIC pump disch valve HV-49-2F013 Control-RCIC pump disch valve 20P220 Control-Vacuum tank condensate pump 20P219 Control-Barometric condenser vacuum pump HV-49-2F002 Control-Barometric condenser vacuum pump disch LIMERICK - UNIT 2 3/4 3-78

Table 3.3.7.4-1 (Continued)

RCIC SYSTEM (Continued)

HV-49-2F080 Control-Vacuum breaker outboard isolation valve HV-49-2F084 Control-Vacuum breaker inboard isolation valve FIC-49-2R001 Controller-RCIC discharge flow control E51-S45 RCIC Turbine Trip Bypass NUCLEAR BOILER SYSTEM HSS-41-291 Control-Transfer switch PSV-41-2F013A Control-Main steam line safety/relief valve PSV-41-2F013C Control-Main steam line safety/relief valve PSV-41-2F013N Control-Main steam line safety/relief valve RHR SYSTEM HSS-51-195 Control-Transfer switch HSS-51-196 Control-Transfer switch HSS-51-292 Control-Transfer switch HSS-51-293 Control-Transfer switch HSS-51-294 Control-Transfer switch HSS-51-295 Control-Transfer switch HSS-51-296 Control-Transfer switch HSS-51-297 Control-Transfer switch HSS-51-298 Control-Transfer switch HV-51-2F009 Control-RHR pump shutdown cooling suction inboard isolation HV-51-2F008 Control-RHR shutdown cooling suction outboard isolation HV-51-2F006A Control-2A RHR loop shutdown cooling suction HV-51-2F006B Control-2B RHR loop shutdown cooling suction HV-51-2F004A Control-2A RHR pump suction 2AP202 Control-2A RHR pump LIMERICK - UNIT 2 3/4 3-79

Table 3.3.7.4-1 (Continued)

RHR SYSTEM (Continued)

HV-43-2F023A Control-Recirculation pump A suction valve HSS-43-291 Control-Transfer switch HV-51-2F007A Control-2A RHR pump minimum flow bypass valve HV-51-2F048A Control-2A heat exchanger shell side bypass HV-51-2F015A Control-2A shutdown cooling injection valve HV-51-2F016A Control-Reactor containment spray HV-51-2F017A Control-2A RHR loop injection valve HV-51-2F024A Control-2A RHR loop test return HV-51-2F027A Control-Suppression pool sparger isolation HV-51-2F047A Control-2A Heat exchanger shell side inlet HV-51-2F003A Control-2A Heat exchanger shell side outlet HV-51-2F049 Control-RHR Discharge to radwaste outboard isolation HV-51-225A Control-2A/2C test return line to suppression pool RHR SERVICE WATER SYSTEM HSS-12-015A-2 Control-Spray pond/cooling tower select HSS-12-015C-2 Control-Spray pond/cooling tower select HSS-12-016A-2 Control-Spray/bypass select HSS-12-016C-2 Control-Spray/bypass select LIMERICK - UNIT 2 3/4 3-80 Amendment No. 47

Table 3.3.7.4-1 (Continued)

RHR SERVICE WATER SYSTEM (Continued)

HSS-12-094 Control-Transfer switch HSS-12-093 Control-Transfer switch HV-51-2F014A Control-2A RHR heat exchanger tube side inlet OCP506 Control-RHR Service Water pump HV-51-2F068A Control-2A RHR Heat exchanger tube side outlet EMERGENCY SERVICE WATER SYSTEM OAP548 Control-A emergency service water pump HV-11-011A Control-A emergency service water disch to RHR service water HSS-11-091 Control-Transfer switch HSS-11-092 Control-Transfer switch HSS-11-093 Control-Transfer switch The following valves of the ESW and RHRSW systems are actuated by signals from the transfer switches:

HV-12-005 ESW and RHRSW pumps wetwell intertie gate HV-11-015A ESW loop A discharge to RHRSW loop B HV-12-017A ESW and RHRSW cooling tower return cross-tie STANDBY AC POWER SUPPLY 152-11509/CSR 101-D21 Safeguard SWGR feeder bkr.

152-11609/CSR 101-D22 Safeguard SWGR feeder bkr.

152-11709/CSR 101-D23 Safeguard SWGR feeder bkr.

152-11502/CSR 201-D21 Safeguard SWGR feeder bkr.

152-11602/CSR 201-D22 Safeguard SWGR feeder bkr.

152-11702/CSR 201-D23 Safeguard SWGR feeder bkr.

152-11505/CSR D214 Safeguard LC XFMR breaker LIMERICK - UNIT 2 3/4 3-81

Table 3.3.7.4-1 (Continued)

STANDBY AC POWER SUPPLY (Continued) 152-11605/CSR D224 Safeguard LC XFMR breaker 152-11705/CSR D234 Safeguard LC XFMR breaker 143-115/CS Transfer switch 143-116/CS Transfer switch 143-117/CS Transfer switch LIMERICK - UNIT 2 3/4 3-82

ATTACHMENT 3 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Changes to Technical Specification 3.3.7.4, Remote Shutdown System Instrumentation and Controls Markup of Proposed Technical Specifications Bases Pages Unit 1 TS Bases Page 3/4 3-5 Unit 2 TS Bases Page 3/4 3-5

INSTRUMENTATION BASES 3/4.3.7 MONITORING INSTRUMENTATION 3/4.3.7.1 RADIATION MONITORING INSTRUMENTATION The OPERABILITY of the radiation monitoring instrumentation ensures that:

(1) the radiation levels are continually measured in the areas served by the individual channels, and (2) the alarm or automatic action is initiated when the radiation level trip setpoint is exceeded, and (3) sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. This capability is consistent with 10 CFR Part 50, Appendix A, General Design Criteria 19, 41, 60, 61, 63, and 64.

The surveillance interval for the Main Control Room Normal Fresh Air Supply Radiation Monitor is determined in accordance with the Surveillance Frequency Control Program.

3/4.3.7.2 (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE UFSAR.

3/4.3.7.3 (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE ODCM.

3/4.3.7.4 REMOTE SHUTDOWN SYSTEM INSTRUMENTATION AND CONTROLS The OPERABILITY of the remote shutdown system instrumentation and controls ensures that sufficient capability is available to permit shutdown and maintenance of HOT SHUTDOWN of the unit from locations outside of the control room. This capability is required in the event control room habitability is lost and is consistent with General Design Criterion 19 of 10 CFR Part 50, Appendix A.

3/4.3.7.5 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess important variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, "Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident,"

December 1975 and NUREG-0737, "Clarification of TMI Action Plan Requirements,"

November 1980.

Table 3.3.7.5-1, Accident Monitoring Instrumentation, Item 2, requires two OPERABLE channels of Reactor Vessel Water Level monitoring from each of two overlapping instrumentation loops to ensure monitoring of Reactor Vessel Water Level over the range of -350 inches to +60 inches. Each channel is comprised of one OPERABLE Wide Range Level instrument loop (-150 inches to +60 inches) and one OPERABLE Fuel Zone Range instrument loop (-350 inches to -100 inches). Both instrument loops, Wide Range and Fuel Zone Range, are required by Tech. Spec. 3.3.7.5 to provide sufficient overlap to bound the required range as described in UFSAR Section 7.5.

Action 80 is applicable if the required number of instrument loops per channel (Wide Range and Fuel Zone Range) is not maintained.

LIMERICK - UNIT 1 B 3/4 3-5 Amendment No. 48,53,70,75,151, ECR 02-00470,173,186, ECR LG 09-00585 INSERT

INSTRUMENTATION BASES 3/4.3.7 MONITORING INSTRUMENTATION 3/4.3.7.1 RADIATION MONITORING INSTRUMENTATION The OPERABILITY of the radiation monitoring instrumentation ensures that:

(1) the radiation levels are continually measured in the areas served by the individual channels, and (2) the alarm or automatic action is initiated when the radiation level trip setpoint is exceeded, and (3) sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. This capability is consistent with 10 CFR Part 50, Appendix A, General Design Criteria 19, 41, 60, 61, 63, and 64.

The surveillance interval for the Main Control Room Normal Fresh Air Supply Radiation Monitor is determined in accordance with the Surveillance Frequency Control Program.

3/4.3.7.2 (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE UFSAR.

3/4.3.7.3 (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE ODCM.

3/4.3.7.4 REMOTE SHUTDOWN SYSTEM INSTRUMENTATION AND CONTROLS The OPERABILITY of the remote shutdown system instrumentation and controls ensures that sufficient capability is available to permit shutdown and maintenance of HOT SHUTDOWN of the unit from locations outside of the control room. This capability is required in the event control room habitability is lost and is consistent with General Design Criterion 19 of 10 CFR Part 50, Appendix A. The Unit 1 RHR transfer switches are included only due to their potential impact on the RHRSW system, which is common to both units.

3/4.3.7.5 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess important variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, "Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident,"

December 1975 and NUREG-0737, "Clarification of TMI Action Plan Requirements,"

November 1980.

Table 3.3.7.5-1, Accident Monitoring Instrumentation, Item 2, requires two OPERABLE channels of Reactor Vessel Water Level monitoring from each of two overlapping instrumentation loops to ensure monitoring of Reactor Vessel Water Level over the range of -350 inches to +60 inches. Each channel is comprised of one OPERABLE Wide Range Level instrument loop (-150 inches to +60 inches) and one OPERABLE Fuel Zone Range instrument loop (-350 inches to -100 inches). Both instrument loops, Wide Range and Fuel Zone Range, are required by Tech. Spec. 3.3.7.5 to provide sufficient overlap to bound the required range as described in UFSAR Section 7.5.

Action 80 is applicable if the required number of instrument loops per channel (Wide Range and Fuel Zone Range) is not maintained.

LIMERICK - UNIT 2 B 3/4 3-5 Amendment No. 11,17,33,36,115, ECR 02-00470,135,147, ECR LG 09-00585 INSERT

TS BASES 3/4.3.7.4 INSERT The systems/functions for which the RSP provides remote instrumentation and controls to accomplish this purpose are as follows:

Reactor Core Isolation Cooling (RCIC) system to maintain reactor vessel water level.

Main steam line safety/relief valves (manual actuation) to reduce reactor vessel pressure.

Nuclear boiler instrumentation to monitor reactor vessel pressure and level.

Residual Heat Removal (RHR) system for suppression pool cooling and shutdown cooling.

RHR Service Water system to supply cooling water to the RHR heat exchanger.

Emergency Service Water (ESW) system to supply cooling water to RCIC and RHR room coolers, RHR motor oil and seal coolers, and the emergency diesel generator.

Containment and suppression pool system monitoring instrumentation.

Standby AC power that supplies power to the above systems.