ML110970066

License Amendment Request to Revise Operability Requirements and Actions for RCS Leakage Instrumentation

ML110970066
Person / Time
Site:	Limerick
Issue date:	04/06/2011
From:	David Helker Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML110970066 (28)

Text

{{#Wiki_filter:Exeen 10 CFR 50.90 10 50.90 April 6, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 USNRC Docket Nos. 50-352 and 50-353

Subject:

License Amendment Request to Revise Operability Requirements and Actions for RCS Leakage Instrumentation

References:

1. TSTF-514-A, Revision 3, "Revised Revised BWR Operability Requirements and Instrumentation, dated November 24, tor RCS Leakage Instrumentation",

Actions for 2010. 24,2010.

2. Notice of Availability of the Models for Plant-Specific Adoption of Technical TSTF514, Revision 3, Revise Specifications Task Force Traveler TSTF-514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation, Instrumentation,"

dated December 17, 2010. Application for amendment of license, construction permit, In accordance with 10 CFR 50.90, "Application permit, Exelon Generation Company, LLC (EGC) requests an amendment to the or early site permit," Technical Specifications (TS) for Limerick Generating Station (LGS), Units 1 1 and 2. The proposed amendment modifies the Actions to be taken when the containment atmosphere gaseous radioactivity monitoring system and the primary containment pressure and temperature monitoring system are the only operable reactor coolant leakage detection monitoring systems. The modified Actions require additional, more frequent monitoring of other indications of Reactor Coolant System (RCS) leakage and provide appropriate time to restore another monitoring system to Operable status. This change is consistent with the U.S. Nuclear Regulatory Commission (USNRC) approved Safety Evaluation on Technical Specification Task Force (TSTF) Traveler, TSTF-514-A, Revision 3, "RevisedRevised BWR Operability Requirements and Instrumentation dated November 24, 2010 (Reference 1), Actions for RCS Leakage Instrumentation" 1), as made available in the Federal Register on December 17, 2010 (Reference 2). 1 of this submittal provides a description of the proposed changes, the requested confirmation of applicability, plant specific verifications, and variations in the proposed LGS TS changes from the approved TSTF-514-A (Reference 1). Affachment Attachment 2 provides the existing TS page markups showing the proposed changes. Attachment 3 provides the associated TS Bases markups for information only. The proposed changes have been reviewed by the LGS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

U.S. Nuclear Regulatory Commission April 6, 2011 201 1 Page 2 EGC requests approval of the proposed amendment by April 6, 2012. Once approved, the amendment shall be .implemented implemented within 60 days. There are no regulatory commitments contained in this letter. In accordance with 10 CFR 50.91, "Notice Notice for public comment; State consultation, consultation," paragraph (b), EGC is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official. Should you have any questions concerning this letter, please contact Ms. Wendy E. Croft at (610) 765-5726. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6th day of April 2011. Respectfully, 97 W. David P. Helker Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Markup of Technical Specifications Pages

3. Markup of Technical Specifications Bases Pages (For Information Only) cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, LGS USNRC Project Manager, LGS A. Janati, Bureau of Radiation Protection R. R.

ATTACHMENT 1 I Evaluation of Proposed Changes I and 2 Limerick Generating Station, Units 1 Facility Operating License Nos. NPF-39 and NPF-85

Subject:

Revise Operability Revise Operability Requirement Requirements and Actions s and Actions for for RCS Leakage Instrumentat RCS Leakage ion Instrumentation 1.0 1.0

SUMMARY

DESCRIPTI

SUMMARY

DESCRIPTIONON 2.0 2,0 DETAILED DESCRIPTI DETAILED DESCRIPTION ON 3.0 TECHNICAL TECHNICA EVALUATION L EVALUATION 4.0 REGULATORY REGULATO RY EVALUATION 4.1 Applicable Regulatory Requirement Requirements/Criteria s/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideratio Considerationn 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

CONSIDERATION

6.0 REFERENCES

REFERENCES

Revise Operability Requirements and Actions for RCS Leakage Leakage Instrumentation Instrumentation : 1: Evaluation of Proposed Changes Page 11 of 5 1.0

SUMMARY

DESCRIPTION DESCRIPTION This evaluation supports a request to amend Operating Licenses NPF-39 NPF-39 andand NPF-85 NPF-85 for Limerick Generating Station (LGS) Units 11 and 2, respectively. The proposed changes would revise the Operating Licenses to modify modify the the Actions to to be be taken taken when the containment atmosphere gaseous radioactivity monitoring system and the primary primary containment pressure and temperature monitoring system are the only operable operable reactor coolant coolant leakage detection monitoring systems. The modified Actions require additional, more frequent monitoring of other Reactor Coolant System (RCS) leakage indications and provide provide appropriate appropriate time to restore another monitoring system to Operable status. This change is is consistent with with the U.S. Nuclear Regulatory Commission (USNRC) approved Safety Evaluation on Technical Specification Task Force (TSTF) Traveler, TSTF-514-A, Revision 3, Revised "Revised BWR Operability Operability Requirements and Actions for RCS Leakage Instrumentation" Instrumentation dated November 24, 2010 2010 (Reference 6.1), as referenced in the Federal Register Notice of Availability on December 17, 17, 2010 (Reference 6.2). Variations from the USNRC-approved TSTF-514-A, Revision 3 are detailed in Section 3.0 of this submittal. submiffal. 2.0 DETAILED DESCRIPTION The background for this application is stated in the referenced model safety evaluation in the USNRCs Federal Register Notice of Availability published on December 17, USNRC's 17, 2010 and TSTF TSTF-514-A, Revision 3. 3, TSTF-5 14-A, Revision 3 the proposed changes are as follows: Consistent with NRC-approved TSTF-514-A,

• Technical Specification (TS) Limiting Condition for Operability (LCO) 3.4.3.1, Leakage"Leakage Detection Systems is revised to add a new Action. The new Action, TS 3.4.3.1 Action F, is Detection Systems" applicable when the containment atmosphere gaseous radioactivity monitoring system and the primary containment pressure and temperature monitoring system are the only operable (i.e., all other monitoring systems are reactor coolant leakage detection monitoring systems (Le.,

inoperable). The new Action requires analyzing grab samples of the primary containment atmosphere and monitoring RCS leakage using administrative means every 12 hours in addition to restoring another monitoring system to Operable status within 7 days. Bases are revised to clearly define the RCS leakage detection instrumentation

• • The TS Bases Operability requirements in the LCO Bases and to eliminate discussion from the TS Bases Operability that could be erroneously construed as Operability requirements. The TS Bases are also reflect the changes to the Technical Specifications and to more accurately reflect revised to reflect revised existing TS.

the existing the NOTE: Proposed revisions to the TS Bases are also included in this application for NOTE: Proposed only. The information only. information changes to the affected TS Bases pages will be incorporated in The changes accordance with the TS Bases Control Program. accordance

Revise Operability Requirements and Actions for RCS Leakage Leakage Instrumentation Instrumentation : Evaluation of Proposed Changes Page 22 of 55

3.0 TECHNICAL EVALUATION

Exelon Generation Company, LLC, (EGC) has reviewed the Federal Federal Register Register Notice Notice of of Availability dated December 17, 2010. This review also included included the referenced information information provided in TSTF-514-A, TSTF5 14-A, Revision 3. EGC has concluded that the justifications presented in justifications presented in the TSTF proposal and the Federal Register Notice of Availability prepared by the USNRC USNRC staff staff are applicable to LGS, Units 1 1 and 2 with the variations noted below, and justify this amendment for the incorporation of the changes to the corresponding TS. Additional reviews have determined that the proposed changes do not not require any exemption or or relief from regulatory requirements other than the TS, and do not affect conformance to any General Design Criteria differently than described in the Updated Final Safety Safety Analysis Report Report (UFSAR). LGS Units 11 and 2 are Standard TS plants and differ from the BWR/4 Improved Standard Technical Specifications (ISTS) used as the TS reference/markup in TSTF-514-A, Revision 3. A list is provided below of the variations in the proposed LGS TS changes from the approved TSTF-514-A, Revision 3:

• Based on the addition of the proposed LGS TS 3.4.3.1 Action FF the currentTS current TS 3.4.3.1 Action F has been renumbered to TS 3.4.3.1 Action G. The change is consistent with the approved TSTF-514-A, TSTF-5 14-A, Revision 3 intent and aligns with the current LGS TS.
• a In order to remain consistent with the current LGS TS 3.4.3.1 Action E, the proposed LGS TS 3.4.3.1 Action F was modified for LGS to require two operable TS LCO monitoring systems (the containment atmosphere gaseous radioactivity monitoring system and the primary containment pressure and temperature monitoring system), as opposed to the single operable TS LCO monitoring system proposed by TSTF-514-A, [0]. This change TSTF-5 14-A, Revision 33 Condition [D].

is TSTF-5 14-A, Revision 3 proposal and aligns with the current is more conservative than the TSTF-514-A, LGS TS.

• The current LGS TS 3.4.3.1 Action F (proposed TS 3.4.3.1 Action G) requires HOT SHUTDOWN within 12 hours if two or more leakage detection instruments are inoperable with the exception of TS 3.4.3.1 Action E. TS 3.4.3.1 Action E allows two inoperable monitoring systems (the primary containment atmosphere gaseous radioactivity monitoring system and unit coolers condensate flow rate monitoring system) for 30 days with 12 hour the drywell unit compensatory grab samples. The proposed LGS TS 3.4.3.1 Action F allows two inoperable compensatory monitoring systems (the drywell floor drain sump flow monitoring system and the drywell unit monitoring systems coolers condensate flow rate monitoring system) for 7 days with 12 hour compensatory grab coolers samples of the primary containment atmosphere and 12 hour administrative monitoring of RCS RCS leakage.

leakage. A review of past operating experience from 1/1/2006 to 2/9/2011 2/9/20 1 1 at LGS Units 11 and and 2 identified identified that the proposed Action F would have been entered three times for a total of 6 hours and 34 minutes. Although the proposed change to the LGS TS is an increase in the amount of the amount plant is of time the plant is allowed to operate with the drywell floor drain sump flow system and monitoring system monitoring and the drywell unit coolers condensate flow rate monitoring system inoperable, the inoperable, proposed Action F is more conservative than TS 3.4.3.1 Action E, is the proposed the approved with the consistent with consistent TSTF-5 14-A, Revision 3 intent, and has operating experience to approved TSTF-514-A, will be suggest itit will suggest an infrequently be an infrequently entered Action statement.

Revise Operability Requirements and Actions for RCS Leakage Leakage Instrumentation Instrumentation : 1: Evaluation of Proposed Changes Changes Page Page3of53 of 5

• The current LGS TS 3.4.3.1 Action FF (proposed TS 3.4.3.1 Action G) G) requires HOTHOT SHUTDOWN within 12 hours if two or more leakage detection detection instruments instruments areare inoperable inoperable with with the exception of TS 3.4.3.1 Action E. The current LGS TS 3.4.3.13.4.3.1 Action FF (proposed (proposed TS TS 3.4.3.1 Action G) is being modified to include the exception exception of the proposed proposed LGS LGS TSTS 3.4.3.1 3.4.3.1 Action F. The change is consistent with the approved TSTF-5TSTF-514-A, 14-A, Revision 33 intent intent and and aligns with the current LGS TS.
• The current LGS TS 3.4.3.1 Action F F (proposed TS 3.4.3.1 Action G) requires HOT HOT SHUTDOWN within 12 hours if the associated Completion Time of Actions A, B, B, C, D or C, D or EE are are not met. The current LGS TS 3.4.3.1 Action F F (proposed TS 3.4.3.1 Action G) G) is is being being modified to include proposed LGS TS 3.4.3.1 Action F. The change is is consistent with the approved TSTF-514-A, TSTF-5 14-A, Revision 3 intent and aligns with the current LGS LGS TS.
• The proposed LGS TS Bases have been edited from the TSTF-514-A, Revision 33 Bases Bases changes to reflect the specific LGS configuration and any variations from TSTF-5 14-A, TSTF-514-A, Revision 3 described above and to correct previously existing typographical errors.

TSTF-5 14-A, Revision 3 for the LGS submittal have been evaluated in These changes to the TSTF-514-A, in the LGS-specific No Significant Hazards Consideration Determination in Section 4.3. The only variations or deviations in EGC'sEGCs proposal have been delineated above. The remainder of the EGC proposed changes are consistent with the TS changes described in the Federal Register Notice of Availability dated December 17, 2010 or the referenced information provided in TSTF-514-A, TSTF514-A, Revision 3.

4.0 REGULATORY EVALUATION

4.1 Applicable Aplicable Regulatory Requirements / Criteria A description of the proposed changes and their relationship to applicable regulatory requirements and guidance was provided in the December 17, 2010, Federal Register Notice of TSTF514-A, Revision 3. Availability referenced information in TSTF-514-A, 4.2 Precedent This change is consistent with the U.S. Nuclear Regulatory Commission (USNRC) approved Evaluation on Technical Specification Task Force (TSTF) Traveler, TSTF-514-A, Revision Safety Evaluation 3, 3, "Revised Revised BWR Instrumentation BWR Operability Requirements and Actions for RCS Leakage Instrumentation" November 24, 2010 , as referenced in the Federal Register Notice Availability on dated November , of December December 17, 17, 2010. 4.3 No Significant Hazards Consideration Determination No In In accordance Application for amendment of license, construction permit, accordance with 10 CFR 50.90, "Application early site or early or site permit," Generation Company, LLC (EGC) requests an amendment to the Exelon Generation permit, Exelon Specifications (TS) Technical Specifications Technical Limerick Generating Station, Units 11 and 2. The proposed (TS) for Limerick modifies the Actions to be taken when the containment atmosphere gaseous amendment modifies amendment radioactivity monitoring radioactivity and the primary containment pressure and temperature monitoring system and monitoring system are monitoring are the only operable reactor coolant leakage detection monitoring systems. The modified The require additional, more frequent monitoring of other Reactor Coolant modified Actions require

Revise Operability Requirements and Actions for RCS Leakage Leakage Instrumentation Instrumentation : 1: Evaluation of Proposed Changes Page 4 of 5 Page4of5 System (RCS) (ROS) leakage indications and provide appropriate time to restore another another monitoring monitoring system to Operable status. EGO has evaluated whether or not aa significant hazards consideration is is involved involved with with the the proposed amendment by focusing on the three standards set forth in in 10 10 CFR 50.92, 50.92, Issuance "Issuance of amendment," amendment, as discussed below:

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

Response: No. The proposed changes clarify the Operability requirements for the RCS leakage leakage detection instrumentation and modify the time allowed for the plant to operate when when the only operable RCS leakage detection instrumentation monitors are the containment atmosphere gaseous radioactivity monitoring system and the primary containment pressure and temperature monitoring system. The monitoring of ROS RCS leakage is not aa precursor to any accident previously evaluated. The monitoring of RCS leakage is not aa direct method used to mitigate the consequences of any accident previously evaluated. Therefore, the proposed amendment does not involve aa significant increase in the probability or consequences of an accident previously evaluated. The proposed changes also renumber the current TS Actions to accommodate the new TS Action. This change is administrative in nature and does not involve aa significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No. The proposed changes clarify the Operability requirements for the RCS leakage detection instrumentation and modify the time allowed for the plant to operate when the only operable RCS leakage detection instrumentation monitor monitors are the containment atmosphere gaseous radioactivity monitoring system and the primary containment pressure and temperature monitoring system. The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, be installed) proposed amendment does not create the possibility of a new or different kind of the proposed accident from any accident previously evaluated. The proposed changes also renumber the current TS Actions to accommodate the new The TS Action. This change is administrative in nature and does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3.

3. Does Does the proposed amendment involve a significant reduction in a margin of safety?

the proposed Response: No. Response: No. proposed changes clarify the Operability requirements for the RCS leakage The proposed The detection instrumentation detection increase the time allowed for the drywell floor drain sump instrumentation and increase

Revise Operability Requirements and Actions for RCS Leakage Leakage Instrumentation Instrumentation : Evaluation of ProposedProposed Changes Changes 5 of 5 Page 5of5 flow monitoring system and the drywell unit coolers condensate condensate flow rate rate monitoring monitoring system to be inoperable concurrently from 12 12 hours hours to 77 days. days. Increasing Increasing the amount of the amount of time the plant is allowed to operate with these two leakage leakage detection detection monitors monitors inoperable does not significantly decrease the margin margin of safety due due to the the addition addition ofof compensatory actions to analyze grab samples of the primary containment atmosphere atmosphere once per 12 hours and monitor RCS leakage by administrative means once once per per 1212 leakage will be detected before itit hours. The overall likelihood that an increase in RCS leakage potentially results in gross failure is maintained with the addition of the actions. actions. Therefore, the proposed amendment does not involve aa significant reduction in in aa margin margin of safety. accommodate the new The proposed changes also renumber the current TS Actions to accommodate new TS Action. This change is administrative in nature and does not involve aa significant reduction in a margin of safety. Based on the above, EGC concludes that the proposed amendment does not involve aa significant hazards consideration under the standards set forth in 10 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified. 4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

EGC has reviewed the environmental evaluation included in the model safety evaluation EGC provided in the December 17, 2010 Federal Register Notice of Availability referenced information in in TSTF-514-A, TSTF-5 14-A, Revision 3. ECG has concluded that the staffs staffs findings presented in that evaluation are applicable to LGS, Units 11 and 2, and the evaluation is hereby in incorporated incorporated by reference for this application.

6.0 REFERENCES

6.1 6.1 TSTF-514-A, TSTF-514-A, Revision Revised BWR Operability Requirements and Actions for RCS Revision 3, "Revised Leakage Instrumentation dated November 24, 2010. Leakage Instrumentation" 6.2 6.2 Notice Notice of Availability of the Models for Plant-Specific Adoption of Technical Specifications Traveler TSTF-514, Force Traveler Task Force Revise BWR Operability Requirements and TSTF514, Revision 3, "Revise Instrumentation, dated December 17, 2010. RCS Leakage Instrumentation," Actions for RCS

ATTACHMENT ATTACHME NT 2 Specifications Pages Markup of Technical Specifications Limerick Generating Station, Units 1I and 2 Facility Operating License Nos. NPF-39 and NPF-85 SPECIFICATIONS PAGES TECHNICAL SPECIFICATIONS REVISED TECHNICAL 3/4 4-8 3/4 4-8a 3/44-8a

Ri AC OR COOLAN 31% LM r:.j .4.3 P140 FOR 001 AN lY FM IIAKA(E C:DLTLl L1MLllt1OG JON jjJPLifAjjiL LI .1.1 ml110wi wino reactor tor uo lant ant Iloakioe detection ion ystLms ilhl 111 F t PP RAP L F:

a. I nrri rna maryry un tainrnent tmosphrre qius raeji to omen P a tmos rod i oa 00(21 iI vi vi ty rnoni non tori ri ng n yscem,

b. Iho Irywell I loorr drain sumpump flow low monitoring system, tern, The cJryvvell Irywel 1 unit coolers I r coneien condensate f1 rate monitoring system, and ow ra Plow nd d.1. he primary containmenconLiinment pres ure and temperature pressure ture monitoring rnoni toring sy tern.

system. APPLICABILI [1: OPERATIONAL OPERAtIONAL CONDITIONS CONDI LIONS 1, 2,, aid nd 3. mary containment

                )i ((flit y     out imnmm nt ga    ji our     radioactivi id oactivi ty monitor mmii br         not   requiredd to b(

ir (1111 i( be operable until intl I Operational tional Condition Condi tion 2. AC F IONS: A. With the primary pr i ma ry containment contai nment a tmosphere gaseous radioactivity radi oacti vi ty monitoring system inoperable, 1 , analyze grab samples of primary containment aatmosphere at least once norr 12 12 hours AND restore primary containment atmosphere a gaseous radioactivity radioactivi monitoring non i tori ng ystem tem to OPERABLE status tus wi within thi ii 30 days. B. B, With the dryweli1 floor drain sump ump flow monitoring system inoperable, restore the drywel11I floorr drain sump low monitoring system surnp flow stem to OPERABLE status tatus within 30 30 (layss AND inc increase monitormonitoring ng Frequency of drywel II unit cooler condensate con den flow rate (SR (SR 4.4 4.4.3.2.. . . 1.i.c)) to once every 8 8 Y1OUrs. hours, C. With the drywell drywol 1 unit cool ers condensate flow monitoring 110w rate mnoni tori rig system inoperable, AND the primary mary containment atmosphere gaseous radioactivity monitoring system system OPERABLE, perform a a channel check of mary containment atmosphere of the primary a re gaseous gaseous radioactivity monitoring system (SR 4.4.3.1.a) 4.4 . . 1.a) once once per per 88 hours. D. IL With the primary mary containment pressure and temperature rature monitoring system system inoperable, restore the primary containment pressure and temperature ture monitoring system to OPERABLE status within 30 days. NOTE: All other tech Spec Limiting Conch tioris For 0eration and Surveillance Roqui rements associ ated with the primary containment oressure/temperature monitoring system still anply. Affected Loch Spec Sections include: 3/4.3.7.5, 4.4.3.2.1, 3/4.6.1.6. and 3/4.6.1.7. E. With the primary containment atmosphere gaseous radioactivity radioactivity monitoring monitoring system system inoperabl inoperable AND the drywell 11 unit coolers condensate flow rate monitoring monitoring system iinoperable,rabIe, restore the primary containment atmosphere a radioactivity gaseous radioactivity monitoring taring system to OPERABLE status within 3D 30 days OR OR restore the the dryweil drywell unit unit coolers condensate flow flow rate monitoring system to OPERABLE OPERABLE status status within within 30 30 days. days. With the primary With containment atmosphere gaseous radioactivity primary containment radioactivi monitoring system system inoperable, analyze grab grab samples of primary containment atmosphere atmosphere at at least least once once per 12 hours. LIMERICK - liMIT - UNIT 11 3/4 4-8 3/4 4 8 Amendment +-l-, -+/-4Q., -l&9-, ~ Amendment , , ,

RJiillLQAtL+/-iLU4 1/4 .1 .1 liLAC ICR COOLANI )Y)l EM LEALAC I iALJLLLLJJLLiLLMS lil1LI_LNQ J(JNL)1iiON. ILl. I no t/l lowin recctrr noulI mt n loikajo tote tion ysrms hi 11 I 001 RABIE

1. hi rna ry :eritai rnnont it.mnphero ppr iiTiiiiry trno jreous r id iomct ii vi ty mon ri nq motHi tori nj nystim, tern, l).

0. I hi drywe rvwi I I t loor leer clOrciinii sump ump tlnw low moni miii toiri mmmi cyc tern, lh irywe II I I unit coolers cur lermtite How rate unnm turing system, mud d.1. Iht?

the pr mdry containment primary inment pressure md temperature ratu moni rinq sy muni tnrmnq tern. system. APPI I CAll LIlY: OPERArrONAL OPERA ii ONAL CONDI I IONS , 2, and I. the primary ontai nment gaseous roiL omctiv ty monitor ainment moni tor is not required ired to be operable mint II (Jperationa rationalI Condition 2. 4CTiN 1\A.. With WI th the primarymr i mary containment contai nment atmos atmosphere gaseous radi oacti vi ty mon monitoring i tori rig system inoperabr i noperab le,, analyzeceo 1 yze grabrab sampl samples 0(31 pr i mary containment atmosphere re at least once per 12 12 houhours AND restore primary containment atmosphere gaseous radioactivity radioactivi moni tori ng system to OPERABLE status within 30 Uays. monitoring B. With trle

         \~ith     the drywell floor      loor drain sump flow     low moni       rinq system monitoring         tern inoperabl inoperable,, restore the drywell drywe II floor El oor clra dra iinn sump ump fl    ow mon flow   moni tori nq ng sys tern to OPERABLE status  tatus within 30 days f\ND ANt) incincrease moni         tori nq frequency of drywe 11 unit monitoring                                      uni cool orr condensate concJc2nsd         fl ow rate flow    ra te (SR 4.4.3.2.i.c) 4.4.3     . . 1. ) to once every 8 hours.

C. Wi Withth the drywe drywel111 un! unitt coolers I rs concJen condensate a flow rate monitoring mon i tori ng system sy tem i i, inoperable, AND the primary J\ND rimary containment atmosphere gaseous radioactivity monitoring system system OPERABLE,, perform rform aa channel chec check of the pri primary containment aa tmosphere nary containment re gaseous qaseous radioactivity monitoring system radioactiv stern (SR 4.4 . . l.a) once per 88 hours. 4.4.3.1.a) hour. 0. D. With the the primary pr i nary containment pres u and temperature contai nment pressure rature moni monitoring system tori rig system inoperabl, inoperable, restore tore the primary containment pressure arid and temperature ture monitoring system to OPERABLE status within 30 days. Note: All other loch Spec Limiting Lend i ti ens or Operati on and Survei lance Regui rements associ ated with the primary containment Eressure/telflperatLlre 110111 tori no system sti 11 apply. Affected tech :pec Sections md ude: 3/4.3. / .5. 4.4.3.2.1. 3/4.6.1 .6, and 3/4.6.1.7. E. With the primary containment atmosphere re gaseous qaseous radioactivity radioactivi monitoring moni system tori rig system inoperable AND the d inoperable drywel 1 uniit coolers 1 nmn cool rs condensa condensate to flow rate mon monitoring system i tori rig system I noperab I c,, restore the primary conta inoperabl containment i nment atmosphere gaseous radi radioactivity cacti vi ty mcmii tori rmg system to OPERABLE status within 30 monitoring 30 days OR restore the drywel drywell1 unit unit coolers condensate flow rate monitoring system to OPERABLE status within within 30 30 days. With the primary containment atmosphere re gaseous radioactivity monitoringmonitoring system system inoperable, analyze grab samples of primary primary containment containment atmosphere atmosphere at at least once least once per 12 hours.

  ~

LIMERICK - UNiT LIMERICK - UNIT 22 3/4 4-8 3/4 Amendment No. Amendment No . 03,

                                                                                                                            .;4, 4-03,
                                                                                                                                  -l-GJ, 4-33, ~
                                                                                                                                         *, f3--

Insert I1 F. With the drywell drywell floor drain drain sump sump monitoring monitoring system system inoperable inoperable AND the drywell unit the drywell unit coolers condensate 1"'1"\'.... IO'1"C' rate monitoring 1"""'t'\rlot'\C'-:::.1'o flow rate monitoring system system inoperable inoperable analyze analyze grab grab samples samples of of the the primary containment atmosphere atmosphere once once per 12 hours, per 12 hours, AND AND monitor monitor Reactor Coolant System Reactor Coolant System leaKaCle by administrative means leakage means once once per per 12 12 hours hours AND restore restore either either the drywell floor the drywell floor drain sump monitoring system system to OPERABLE OPERABLE status status within within 77 days OR restore days OR the drywell restore the drywell unit coolers condensate flow rate monitoring system system to OPERABLE status to OPERABLE status within within 77 days. days.

REAC FOR COOLANT SYSTEM AC [IONS (Continued) any other two or more 1leakk detection systems inoperable otherr than trla n ACl1O ACflOr4S F tWitl1 Action and above OR with required Actions ncl associated Completion Time of AC lIONS ONS A,, B, and F (;, I) . riot met, be in fl0T 1101 SHIJIDOWN SHUTDOltJN within SHUTDO~~N within 12 hours AND in COLD SHUIDOWN Vi hours.

                                                                      -.....
   .4 . . 1 rh(~

4.4.3.1 lhe reactor coolant system leakage ka on systems shall detection demon tra 11 be demonstrated rabl by: opmable

a. conta nment atmosphere gaseous Perform a CHANNEL CHECK of the primary containment radioactivity monitoring system inn accordancerda with the Surveillance lrequency Control Program.

b. Perform a CHANNEL FUNCTIONAL lEST at required leakage detectiondetect on rumentation in accordance with the Surveillance Frequency instrumentation requency Control Program.

[his does not apply to containment pressure p ratu monitoring system. and temperature sy tem. c:. form a CHANNEL CALIBRATION of required lea Perform leakage detection instrumentation in rdance with the Surveillance Frequency Control Program. rhis accordance fhi does not pply to containment pressure and temperature apply ture monitoring system.

d. Monitor primary containment pressures pressu s AND primary containment temperature ture in ccordance with the Surveillance Irequency accordance Frequency Control Program.

LIMERICK - UNIT 11

              -                                    3/4 4-8a                      Amendment No. 444,+4G, ~

IL/\((Uli i:optrii (1[l1 ACIiUitiJent i;ii,sj) WIth my st her to mure leak lotect uii system; oupermbl e other than mhove (JR with requ I red Actions and issoci ated Lompletion I lee ot AC ((iNC A, B, p be In HUE COO DOWN within L hours AND in COLD SHU I DOWN within U1VLiLLANCL PL1JUIRLMLTIL L:LI. I the nostor cool ant n ystun 1akage detection ion systems chat I he ra I [liOns tratcdt uperah e by:

a. Prturm a CHANNEL CHECK ot the prj inment atmosphere gaseous primary containment m11actlVl Li ;norii torroj ystem in accordance vii wi th to the Sjrvei lance rJemiry (nt ro I P roqrarn.

b. LJ. Pertorm a CHANNEL FUNCTIONAL VEST of oF required requi red I eakaqe detection detecti on instrumentation in accordance with tthe Surveillance Survei Ii once Frequency Control Program. this does not apply to containment p sure and temperature pressure ture non i tori ng system.

c. Pertorm a CHANNEL CALIBRAT [ON of requi red leaKage detection in rumentation detecti on instrumentation toe survei II once Frequency Control Program.

in accordance I;vw i th the ram. rhi does his does iot apply to containment pressure and temperature ture moni monitoring tori ng system. sys tern.

1. tvJonitor Monitor primary urimary containment pressure AND primary containment temperature rature inin accordance wi withh the Curve i ((once Frequency Control Program.

Progr'am. LIMERICK LIMERICK - UNIt-UNIT 22 3/4 4-Ba 3/4 4-8a Amendment No. Amendment No. D3,

                                                                                                   -+/--W, 44A,   ~
                                                                                                           +4+, 4-53

ATTACHMENT 33 Markup of Technical Specifications Bases Pages (For Information Only) Station, Units I1 and 22 Limerick Generating Station. Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3/4 4-3 3/4 4-3a B 3/44-3a B 3/4 4-3c B 3/4 4-3d

Li

1. Li. I LHARACL ULILCI ION OYiEM lA[ KI lLI NI)

IN AR Catety Nesi go i3asi s (Ret. I), roqur res means for detect inn and, to the extont ci deriti tying the location it the sourco ot Reactor Cool ant System (RES) PRFSSIJRF IIULJNI)ARY ILAKAUL. Rogirl a tory Guide I .45 (Ref. N) der hes acceptab e methods to eleLt1nj eakage (Ietectiin :/St005.

                                                                                           )

1111 ts n leakage trcrn the reactor coo Hit pressure boundary tRCPB) are rnqui red so that ippropriate acti on can be taken betore the integrity of the RCPI3 is impa rod (Ref. N). leakage detect) on systems to r tho RCS a cc prov i ded to a 1 ert the opera torn when I eakage rd tes above normal background levels are detected and a I so to supply quantitative measurement ot leakage rates. Systems for soparati ng the leakage of an identifi I denti Lied source from an uni unidentified denti fled source are necessary to provide prompt and quantitative tative information to the operators to permit thorn to take mmcdi ate corrective action. Leakage from the RCPB iris) in idede the drywe I 1 is detected by at least one of four (4) independently tly monitored vari bl mon i tored variables which iinclude nd ode drywel I drain sump level changes over time yi lding drain flow rates,, arid yielding and drywel drywellI gaseous radioactivity, drywel 11 unit cooler conden condensatete flow rate and drywe drywellI pressure/temperature u levels, fhe the primary mean means of quantifying i ing leakage lea drywellI in the drywel arere tr1e the drywell floor drain sump ump flow low monitoring system for UNIDENTIFIED UNIDENTI lED LEAKAGE LEAKAGE and ttie the (jrywell drywel 1 equiequipment drain tank flow monitoring system for IDENTIFIED LLAKAGE. LEAKAGE. IDENTIF IDENFIFEED ED 1leakage ka iis not germane to this Tech and the associated drywell tech Spec arid equipment drain tank flow monitoring system is not included. equi (he drywell dryweli floor drain sump ump flow monitoring sy tem monitors UNIDENTIFIED LEAKAGE system colI collected in the loor drain sump. the floor ump. UNIDENTIFIED LEAKAGE consists con i ts of leakage from RCPB RCPB componen components in ide the drywell which are not inside riot normally subject ect to leakage lea and otherwise routed to the drywel II equi equipment drain sump. surnp. Ihe primary The mary containment floor drain sump ha has transmitters that supply upply level indication rid i cation to the mdi mainn control room via the plant monitoring system. The rhe floor drain sumpump level transmitters are re as a sociated soci ated with Hi High/Low Low 1levelI switches that open/close the sump tank drain valves automatically. The fhe level instrument instrument processing unit calculates an average leak rate (gpm) for aa given given measurement pen ad which resets whenever the sump drain valve closes. loses. The level processing unit provides ann alarm to the main control room each time the average leak rate changes by aa predetermined ned value since ince the last time the alarm was reset. For For the drywell loor dra 11 floor drainn sump flow monitoring system, the setpoint int basis is aa 11 gpm change inin UNIDENTIFIED lJN[l)l-NlIFIEI) 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 lement is iintegrated and recorded. AA main control room alarm is also provided to indicate an excessive sump discharge rate measured via the flow e-Iement. clement. ihis fhis system, referred to as the "drywell totalizer", is not drywell floor drain flow totalizer, credited for for d dryweil1 floor drain sump flow monitoring system operabi operabillity. ity. LIMERICK - UNIT 11

                -                                   B 3/4 4-3 B                                         Amendment 4G, ,    ~, ~
                                                                                                                 ,

KAL i/l,L i. [ IFAKAGE DELECIlUN YGFIMS KACE(R OHND II CAR Citety Us rn has I Ret. () , requl res mean; for detecting and, to the extent prict ci , ilenti ty rig the Iooiti err ot the ;ource of Rea:tor coolant System I. itS) lIjRE BOUNDARY lEAKAGE. Regul it ory (in do .lh (Ref. B) dccc ibes acceptable methods or solting leakage detection ;ystlns. >evtsor > line ts cri leakage trem the roictor eel ant pressure boundary (RCPS) (RCPB) are required regui red soa thi t ippropr (ito ic t on carl be ti ken be fore the in ri integrity of ot the RCPS RCPI3 i s impaired spa red (Ref. (Ref. B). leakage dot ectiori systems tor the hitS are re provided to alert the operators when leakage rates above normal background levels ire detected and also to supply lunti titi ye measurement of leakage rites.Ryl

ytems tor eparati ng the leakage ut an ident i fled 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 RCPS RCPB inside the drywell drywel 1 is detected by at least one of four (4) independently Iy monitored variables which include drywel 1 drain somp level changes over time yi lding drain flow rates, and drywel yielding drywellI gaseous radioactivity, drywell 11 unit coolcooler conden ate flow rate and drywell condensate pre:ur c/temperature levels. fhe the pr imary i mary means of quanti guanti fyiing ng leakage in the drywel drywell1 are the drywel I floor drain in sump ump flow low monitoring sy em for UNIDENTIFIED LEAKAGE and system the dryweil equipment drain tank flow monitoring system for IDENTIFIED LEAKAGE.

IDENF[FIED leakage is not germane to thi fech Spec and the associated this Tech associ ted drywell equipment drain tank flow low monitoring sy tern iis not included. system fhe (he drywell drywel 1 floorI r ddrainin sump ump flow low mon monitoring toring system monitors UNIDENTIFIED LEAKAGE coil collectedted in Ule the floor drain sump. ump. UNIDENTIFIED consi ts of leakage from RCPB IJNIDENTIFIED LEAKAGE consists RCPS components inside n the drywel drywellI which (ire riot not normally subject ect to leakage lea nd otherwise arid routed to the drywelldrywel 1 equi equipment drain sumnp.sump. The primary containment containment floor drain drain sump sump ha ransmit has transmitters tha upp y level indication to the main control that supply control room room via via the the plant plant monitoring moni tori rig system. The fhe floor dra drainin sump level transmitransmitters associated tters are associ with ated with Hi /Low 1level switches that open/close High/Low lose the sump tank drain valves automatically. automatically. The The level in rument processing instrument proces 1ng unit un t calculates calculates an averageaverage leak leak rate rate (gpm) (gpm) for aa given given measurement period which resets whenever the sump sump drain drain valve valve closes. closes. the fhe level level processing unit provides an alarm to the main main control room each each time the the average average leak leak rate changes by a predetermined rmined value since ince the last time the alarm was reset. reset. ForFor thethe drywell rywell floor drain sump flow monitoring system, the setpoint jnt basis basis is is aa 11 gpm gpm change change in UNIDENTIFIED in UNlDENTI lED LEAKAGE. addi ion to the dryweli In addition drywell floor drain sump sump flow monitoring monitoring system system described described above, above, the the discharge oF of each ch sump is monitored by by an independent i t flow element. element. Tire The measured measured flow flow rate from the flow element element is integrated j rated arid and recorded. recorded. AA mainmain control control room room alarm alarm is is also provided to indicate an excessive excessive sump sump discharge discharge rate rate measured measured via via the the flow flow lement. This system,, referred to as clement. as the the drywell "drywell floor draindrain flow flow totalizer, totalizer", is is not not credited for drywehidrywell floor drain drain surnp sump flow monitoring monitoring system system operability. operabil ity. liMERICK LIMERICK -

             - ((NIL UNIf 22                              BS 3/4 3/4 4-3 4-3                             Amendment 4, Amendment     ~, 1D3~

Insert 22 meeting the OPERABILITY In addition to meeting OPERABILITY requirements, requirements, the the monitors are typically monitors are typically set to provide set to provide an excessive the most sensitive response without causing an excessive number number of spurious alarms. of spurious alarms.

AC C R f[lAN ICYS EM lie pr mary conta neent a tmospheri C (Jaseous adi oacti vi ty mon i tori op system cunti nuousl v moni tors toe primary containment atmosphere Par qaseous radioacti v ty Civil A ,ui(t(n lncrr isa ot ridioict.i Vi ty, in ih iiiiy Do i5tribited to RCPB stoam or rictor water I rakago, I ; onnunc ited hír toe ina ri control room. i-he primary COfltiflmO trphi 10 ifeui- rtd-a- tivity- monitor +/-nig yi+-mi t -ri-rJp ,l,-} t- point ryrr i ciLwi , -but I ntiv Ietet Fncra-s-ecl I ratje a-too of I ithn I wir. irgnr rhuruje; in heakajo -at-c; uu- Itctod n proportionally ohoFtw ir; (het Ccrdensate from the eight drywe II 11 air i r coolers is routed to to the drywei 1 P oor (Ira in in sump sump mi is mom tored by a series at low tow n transmi t tters that provi crovide indication and rms alarms in in the ma in coritro I room. [lie outputs trom from the the Plow flow transmi tters are added together by by summing mi to to provide a total continuous continuous condensate con den drain flow rate. he high flow flow a I arm setpoi nt is based on condensate drain d r a in Plow fl ow rate ra in excess of I ppm over the current 1 y i denti tied preset leak rate. [he drywe ii 11 a ii rr coo I er condensate flow rate moni turing syst.rn serves as an added indicator,tor, but hut not quanti Pier, of RCS UNIDENI IFIED not LLAKAhE (Ret. [he drywell temperature and pressure pre sure monitoringmonitoring system sy tem provide provide an indirect indirect method method for detecti op PCPB I eakge . A temperature re and/or pressure rise ri drywell1 above in the drywel above normal levels may be indicative of a a reactor coolant coo 1ant or steam 1f~akage (Ref. ~. team leakage . APP LI CEEfJYANALYSE @ A threat of 5 l (ml fi cant compromi si to the RCPB cxi sts if the harrier contains a crack that i s large enough to propagate rapidly. Leakage rate limits are set low enough to detect the leakage cmi tted Prom a single crack in the RCPB (Refs, Jand . Eh-ef th Ecakaqe detection systems inside the drywel 1- i-s designed with the ca-pabi i ty dturtinp Iakag lacc than the uctahlished leakage ratc limits aid provdin mjrpri te al arms of excess Icakage i-n t-h-e ontroI ro-&- 7 AA control control room room alarm allows the operators to evaluate the significance of the indicated the indicated Ileakage and,and, if if necessary, shut down down the the reactorctor for further further investi investigation on and rrective action. corrective action. fhe The allallowed Ileakage rates are well below the rates predicted for icted for riti 1 cra critical crack k sizes izes (Ref. (Ref. ( . Therefore, Therefore, these actions actions provide de adequate responses responses before ignificant break before aa significant break ln in the the RCPBRCPB can occur. RCS RCS lealeakage detection detection If ii rumentation satisfies (Criterion 11 of the fies (Criterion the NRC Policy Pal icy Sta temen t. Ctatement. [MIT INC CONDITION FOR OPERAIjlL,OQj rhere jr)'ldcll drywcl 1 floor floor draindrain SUFflP Plow Fflonitoring oump flo'ii monitoring S)'stCFfl system is is rcquired:o quantify tt~@" rcqui red so quaAtif)' t-- UNIOErnIFIED UD[NfII[D LEAI<AGE LEAKAGE flom from the the ReS. PEE. fMC other Awnitoring The otAcr monitoring systems provide early sytemc pro',idc aIarms early alarmsf7 to the thQ of]Qr61tor oprakor gO so (loser closer exam; nat; on of eimination other detect; of other detection on S)ystem stCfflS wiwill 11 bebe lila de L~ R d!tellfli rmine nc the the cxh:nt extent of of anyany correct; corrective action

                                                                 'rfe acti          that Ffly Of! that      my be     required.

he requi red. II';[11th th M1) any IIek-a-P eEikEigeP' j2::~eable, lstccti on system i nonerable, omerti tori ng for I eakaoe in the IftDniteeing fee leakage in tl.e REPS i2 degloded.*' REED is degrde& LIMERICK LIMERICK - UNIT UNI[ 11 BB 3/ 4-3a 3/ 44 4-3a Amendment Amendment ~I

E[AiH)R UPIANI t75lfM he primary conta I rment atmospheric gaseous radiouctivi ty monitoring system continuously moni tors the primary containment atmosphere for gaseous radioectity evel s, A sudden increase ot radioactivity, which nay be attributed to RCPB steam or reactor water lakaqe, is annunciated in the main control room. fe primary continm etniusphori r :i115 radfoact. iv ty inoni torin yskem is not u:apob In af rtanti f skg #tS hot . t i v noogh 0) inrrasd rat ot I ni i n I heo-t. larger hoatetto n inakap rates or detected 10 prenortiona I ly short 5-4 mu s I Pet- i--+ indonsato rum the erght drywel I air coolers is routed rout(~d toto the the irywel rywell1 floor drain (jrain suinp sump jilil i ; wont tored by a series ot flow transmitters that ttld t provide prov i i ndi indication ion andnd alarms 1arms inn the main control room. I he outputs from rom the flow transmitter transmi tters are added added together her byby sumini rig uni ts to provide a total continuous con den ate drain flOW coriti nuous condensate low rate, ra fhe high the high hi flow ow alarm setpoint is based on conden condensate a dra drainn flowlow rate ra in excess of 11 ppm in gpm over the currently identit red preset Ileakk ra rate, The drywell air ai r cooler cool r condensate flow rate morn tori ng system serves as an added indicator, but riot not guanti quantifiTier, r, of RCS RCS l.JNIDENTIFIED UNIDENTIFIED LEAKAGE (Ref. [he Irywe I I tempera ture and nd pres pressure ure moni monitoring tori rig systems provide an iindirect ndi rect method for detecting RCPB leakage. A levels may he indicative of a reactor rature and/or A temperature ctor coo nd/or pressure pres ure rise I ant or steam coolant ri lea kage (Ref. M. team leakage f.@ in the drywell above normal APPL [CABLE S Al El ( ANALYSES A threat of si gui hi cant compromise to the RCPS RCPB exists cxi sts if the barrier contains aa crack that iis Ilarge enough to propaga propagate rapidly. Lea Leakage rate 1imits limits are set low enough to etee t the 1eakage

      ; :!

(jdetect ~ ~::m~:::~:::~:~ ikg dtction leakage em itt ed fro emitted T ~:i:;~::::~~::;:g:<~~~E from

H t ';1 ~~;~:H e-ctincj leakage less than r the tpropr ate mas i n91 e era a single crackckin RCPS (Ref in the RCPB

                                                                              . ; ;~L!;'::;1; inside the 4ryw-il is designed with the aped ty
                                                    .; established leakage i rate I aries of mxces s I eakage in the control rooi A control room alarm allow the operators

s. and.

(Refs.

t= ==:~ ~fP

                                                                                           -; limits or
                                                                                                                      =:

j l and ~ . foe I i ~ F f provdin rs to evaluate the significance of the indicated t IH: Jl 1leakage and, iif necessary, ry, shut hut down the reactor for further investigation and corrective corrective action. ction. fhe Ihe al lowed lea allowed leakage rates are well below the rates predicted for ritical crack sizes critical i (Ref. 2i, Therefore, these actions provide adequate response (Ref.~. before a significant i go if i nt brea break~ n the RePBRCPB can occur. RCS lea leakage detection ins~entation inst umentation sati fies Criterion 11 of the NRC Policy satisfies Statement. LIMITING CONDITION FOR OPERA1ION (LCO) rho drysel I floor I-h drY1dclj floor dra i n,::uffip drain flow [flOAi surnp f13\tf tori ng 5ysteffl monitoring systcm is required rcqui red to guantiquaflti f, fy tid: tI JZ ~~jID~NTr~I~D 4iDEN[iF1ED L~AKAGE from the ReS. LEAKAGE froffi I1CS. The other ffionitoring monitoring systeffis systems provide early a1arffis alat-m L to the operators cperators 50 1oscr p)(Jffli so Cclosor flati Ofl of other detecti examination detection systcrns ~9'i Ofl SystCfflS will11 be made A'lade te.Q.. termi ne thQ Jf!!ltH'ftlinQ extent of dny the ext8nt any corrective correcti ye action acti on that thpt ffiay requi red, IJith may be required. any lcal<a~4 With an) 1 eaka

.j~tt~Ltiofl detection '5dt~m system illepel        obl~, mtM1toi inoperable          monitoring         for l~okElg~

111t:'1 fel leakage 11iin tli~ the RePB RCPD 13 is d~gl degrad ~d~d~ ~ LIMERICK LIMERICK - UNIT- iJNJT 22 B 3/4 4-3a B Amendment ~

Insert 33 This LCO requires instruments instruments ofof diverse diverse monitoring monitoring principles principles to to be OPERABLE to be OPERABLE to provide provide amounts of confidence that small amounts of UNIDENTIFIED UNIDENTIFIED LEAKAGE LEAKAGE are detected in are detected in time to allow time to allow actions to place the plant in in a safe condition, when when RCS RCS leakage leakage indicates possible RCPB indicates possible RCPB degradation. The LCO requires four instruments to be OPERABLE. OPERABLE. The drywell floor drain sump monitoring system is is required to quantify the UNIDENTIFIED quantify the UNIDENTIFIED LEAKAGE rate from the RCS. The identification identification of an increase in an increase UNIDENTIFIED LEAKAGE in UNIDENTIFIED LEAKAGE UNIDENTIFIED LEAKAGE to travel to the drywell will be delayed by the time required for the UNIDENTIFIED drywell floor drain sump and it may take longer than one hour to detect detect aa 11 gpm increase in gpm increase in UNIDENTIFIED LEAKAGE, depending on the origin and magnitude of the leakage. leakage. This This sensitivity is acceptable for containment sump monitor OPERABILITY. The reactor coolant contains radioactivity that, when released to the primary containment, can can be detected by the gaseous primary containment atmospheric radioactivity monitor. monitor. A radioactivity detection system is included for monitoring gaseous activities because of its sensitivity and rapid response to RCS leakage, but it has recognized limitations. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects. If there are few fuel element products, it may not be possible for the gaseous cladding defects and low levels of activation prOducts, primary containment atmospheric radioactivity monitor to detect a 1 1 gpm increase within 11 hour during normal operation. However, the gaseous primary containment atmospheric radioactivity monitor is OPERABLE when it is capable of detecting a 1 1 gpm increase in UNIDENTIFIED LEAKAGE LEAKAGE within 1 1 hour given an RCS activity equivalent to that assumed in the design calculations calculations for the monitors (Reference 9). The The LCO LCO is is satisfied when monitors of diverse measurement means are available. Thus, the drywell floor drain sump monitoring system in combination with a gaseous primary containment drywell atmospheric atmospheric radioactivity monitor, a primary containment air cooler condensate flow rate monitoring monitoring system, system, and a primary containment pressure and temperature monitoring system provides provides anan acceptable minimum. acceptable minimum.

thAc I 011 hOOLAN  ; I1 N 40 rIONS iONS coot i nued)

0. WI th the requ I red pri Fury con ti i nrnent a I r coo or condensi to t ow rite mon i tori nq system inooerble, 31 1:1,3,1.1 must be performed every 0 hours to provide periodic F ntormnit on t ic t v Lv time urimarv eon mmert Ot 11010 trequerit ntervi I Loan the routi rio troquency ot every I flour, ho 3 hour intervu 1 provides peri 0(1 (C irmtornmti on that is adequate to detect I eakiqe and rocnqrii /es that other turms ot loikige det*tmon ire aval lahie. 10 requr red ALE ION has been clan Lied to state that the addi tional survel I lance requi cement is not applicable if the requi red pr wary conti I nmnent atmosphere aseous radioactivity moni torinq system i salso inoperable. Lonsi stent with SR 4.0.3, surveillances are not requi red to he performed on inoperable equipment. In this case, ACtION Statement A. and H. requirements p ply.

D. U. With the urinary r' mary conconta i runent pres sure and tempera rature tore monitoring moni tori nq system inoperable, operation may cantin continue Lor up to 10 lays q von the systems tem' indirect mdi rect capabiility1 i ty to detect RLS Ilea ka qe. I luweve r, of me r immore I mitmi t i ng rig rech tech Spec requirements req iii rements a as sociated soc i a ted with the primary con containment pressure/temperature rature monitoring system will will stiill 11 op p1 y. H. Wi th both the P11 mary contai nment atmosphere gaseous radioactivity radi ctivity moni monitor tor aridnd the primary containment air cooler condensate flow rate monitor inoperable, the only only nouns of detecting leakage is the drywel I tinur loor drain surnp ump rnonr monitor the drywel tar and the drywell1 pressure/tempera Lure i nstrumeri tat ion. ilil s condi ti on does riot provide the requi red diverse means of leakage detection. Ihe requi red ACtION ACTION is i to restore restore either ither of the immoperabl e non I tors to OPERABLE status within 30 days to to regain the intended leakage detection diversity. Ihe 30 day Completion Lime ensures ures that the plant will not not bebe operited in i dcgraded cont gut ation for a lonqthy time period period. WWile ~the primary ile the primary containment atrnos here radioactivity monitor is i INOPERABLE, rimary containment containment atmospheric grab samples will he taken and analyzed every 12 hours since since ACTION ACTION f atemei A requirements also apply. iNS , f? tn" F' any requl red ACt ACTION ION of of Conditions Condition A, S, B, C, C, UD .annot be met annot met within within the the associated Completion etion Time,time, the plant must be brought to arm an OPERAtIONAL OPERATIONAL CONDITION CONDITION in in which the LCO does not apply. fo achieve this status, lo tatus, the plant must must be be brought brought to to at least 1101 SHUTDOWN SHUTOOWN within 12 12 hours and COLD SHUTDOWN within the the next next 24 24 hours. hours. the allowed Completion letion Timeslimes are reasonable, based based on on operating operating experience, experience, to to pertorm the ACtIONS in in an orderly manner and without challenging challenging plant plant systems. systems. SuRVEILLANCE REQUIREMENTS SR 4.4.3.1.a this SR is for for the performance performance of of aa CHANNEL CHANNEL CHECK CHECK of of thethe required required primary primary containment containment aatmospheric ri monitoring monitoring system. The rhe check gives gives reasonable reasonable confidence confidence thatthat the the channel channel is is operating operating properly. p y. LIMERICK LH1ERICK - UNIT~

               - IJNIt                                   BB 3/4 3/4 4-3c 4-3c                               Amendment -+/-4G, Amendment     ,      ~, ~
                                                                                                                        ,

II ACIIJC COIlLAfIF $?SILM W. ALjIi3iLiLorLLi C. With the rqui rod primary containment air cooler condensate H ow rote moni toring system noperahie, SR 4.4.3 l.a must be pertormed every 8 hours to provide periodic itirifla 1H1 ;r icr ivi ty fl the pr mary contal nment at a more trquent I ritervo I than toe rout 110 trr ouenrv it every 12 hours, lie 4 hour interval provides periodic ii to rina t i on the t i s adegua to to ietec t I ea kage and recogn i zes the t other to rrns of leakage detection are available, the required ACtION has been clan tied to state toot the add I H ona I survei ii once requi rement is not applicable if the requl red primary conita iniment. atmosphere qaseous radioactivity mon tori rnij system is at so inoperable. Cunsi stout with SR 1.0.3, survei 11 ances are not requi red to be perr'formed tormed on inoperable equipment. In this case, ACTION Statement A, and E. requl rements I y. D. With U. ItJi th the primary containment inment pressure and temperature monitoring system inoperable, rabIe, operation may continue inue forfor up to 30 (lays given gi veil the sy tern' i rid i rect capabi systems capab i Iii t,y to to detect RCS leakage. However, However, other other more limiting limiting Tech tech Spec regui rements ssociated rements associ a ted with vvi ttl Uletine primary containment contai nment pn:ssure/ pressure/temperature rature monitoring system will ti 11 will still app ly. pply. C. With both the primary containment atmosphere tmo gaseous radioactivity monitor monitor and nd thethe primary conta inment. air ir cool cooler condensate How low rate monitor moni tor inoperable, the the only only means of detect i rig leakage kage iis the drywell drywel I flour loor drain ump monitor and the drai n rump drywell1 the drywel pressure/ temperature in ins trumentation. trumentati on. fhi lb I s condition condi ti on does not not provide provide the required the requl red diverse, means of of Ileakage detection. ion. The file requii red ACTION is i to restore restore either ither of of the the inoperable monitors mon i tons to OPERABLE status within wi n 30 clays to regain the intended intended leakage leakage detect ion diversity. diversity. fhe [he 30 day letion time da,y Completion fime ensures en ures that the the plant plant will wi 1I not not he be operated inn a degraded co configurat n f i !] lH' a tiion 0 n torr aa 1 lengthy time ri 0 d . Whi time period. ~J hi Ic letthe he primer pri mar contaiinment nment atmosphere gaseous radioactivity moni monitor tor is i INOPERABLE,, ......rimary rimary

                                                                                                                              ~~--"JI-,.-

containment atmospheric grab samples will be taken containment anal taken and analyzed every 12 every hours since 12 hours Slnce AC' r ;lnt A. requirementsrements also a Iso apply. ~ lNSE'((.T ~ ~ cr ~ ~

II n runlred associated ia which the LCO which red ACTION Completion ACTION of LCO does riot of Conditions A, B. time, the plant letion fime, not apply. Iy. To plant must fo achieve B, C, Ocann must be achieve this DA~cannot be brought brought to this status, ot be to an tus, the be met met within an OPERATION OPERATIONAL the plant plant muSt within the must be the CONDITION in AL CONDiTION be brought to to in att 1 leastt HOt HOT SHIJFDOWN SHUTDOWN withinwi in 12 hours arid 12 hours and COLDCOLD SHUTDOWN SHUTDOWN within within thethe next next 24 hours. 24 hours. Ide fhe atI lowed owed Completionletion Irimes lines are are reasonable, reasonable, based based on on operating operating experience, experience, to to perform perform the the ACTIONS IONS in in an orderly orderly manner manner and and without without challenging challenging piantplant systems. ci n F II AM F [)[flH r flLA[EM rc

 )tJr\VLILLI,II,,L       RL,4UiRLlLiLL, SR 4.4.3.1.a

[his SR is for the performance rformance of of aa CHANNEL CHANNEL CHECKCHECK of of the the required required primary primary containment containment atmosphericc monitoringmonitor ng system. The The check check gives gives reasonable reasonable confidence confidence that that the the channel channel is operating operating properly.properly. LIMERICK LIMERICK - UNIt UNlf 22 BB 3/4 3/4 4-3c4 3c Amendment +GJ, Amendment , ,~, ~

Insert 4 F. With the drywell drywell floor drain drain sump sump monitoring monitoring system system inoperable inoperable and and the the drywell drywell unit unit coolers coolers condensate flow rate monitoring system inoperable, inoperable, one one of of the the two two remaining means of remaining means of detecting leakage is the primary primary containment atmospheric atmospheric gaseous gaseous radiation monitor. The radiation monitor. The primary containment atmospheric atmospheric gaseous gaseous radiation radiation monitor monitor typically typically cannot detect aa 11 gpm cannot detect gpm leak within one hour when RCS activity is is low. low. Indirect Indirect methods methods ofof monitoring RCS leakage monitoring RCS leakage must be implemented. Grab samples of the primary containment atmosphere primary containment atmosphere mustmust bebe taken taken and analyzed and monitoring of RCS leakage leakage by by administrative administrative means means mustmust bebe performed performed every 12 hours to provide alternate periodic information. information. Administrative means of monitoring RCS leakage include monitoring and trending trending parameters that may indicate an increase in RCS leakage. There There are diverse alternative are diverse mechanisms from which appropriate indicators may be selected based based on plant conditions. on plant conditions. methods should be It is not necessary to utilize all of these methods, but aa method or methods be selected considering the current plant conditions and historical or expected sources of expected sources of UNIDENTIFIED LEAKAGE. The administrative methods drywell cooling fan methods are the drywell inlet/outlet temperatures, drywell equipment drain sump temperature indicator, indicator, drywell drywell equipment drain tank hi temperature indicator, and drywell equipment drain tank flow indicator. These indications, coupled with the atmospheric grab samples, are sufficient to alert the operating staff to an unexpected increase in UNIDENTIFIED LEAKAGE. In addition to the primary containment atmospheric gaseous radiation monitor and indirect methods of monitoring RCS leakage, the primary containment pressure and temperature monitoring system is also available to alert the operating staff to an unexpected increase increase in UNIDENTIFIED LEAKAGE. The 12 12 hour interval is sufficient to detect increasing RCS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to regain the intended leakage detection diversity. The 7-day Completion Time ensures that the plant will intended not not bebe operated in a degraded configuration for a lengthy time period.

It AL FOR 000LAN I SYS EM SR l.4.31.b hi; SR 1S tur the perormanc? of a CHANNEL CHANNEL CONE FUNCTIONAL F IONAL fESI o of the requ i j red red RCS RCS I eakageka itect on nstrtuiientati on. oe test ensures that the moni monitor tors cancan perform rm their their function in the desi rod manner. ho test a so verities ri i the alarm the a1 rm setpoint i nt and and relative I a ti ve iccuracy ot the instrument string. ho SR is for the performance of aa CHANNEL CHANN L CALIBRAF CALIBRATION ION ofof requi required lea red leakage detection detection 1 ostrumentati on channels. the ccl1i brati bration accuracy of on von Ci os the accuracy of the the instrument instrument string, including the instruments ruments located I ted inside in i i nment. containment. SR 4.4.3.1 .d his SR provides a routine check of primary primary contai containment pres ure and nment pressure and temperature temperature for indirect ev i Hence of RCS leakage. RE F ER ENC ES LOS UFSAR, Section 5.2.5.1. Regulatory Guide 1.45, . IN3ErY5 _L4 LOS UFSAR, Section 5.2.5.2.1.4. LOS UFSAR, Section 5.2.5.2.1.1(2). GEAP -5520, Apri I 1968 NUREG- 75/067, October 1975. UFSA Section 5.2.5.6. 3/4.4.3,2 OPERAtIONAL LEAKAGE fhe allowable lea The leakage rates from from the reactor coolant system have been based on the predicted and nd experimentally observed behavior of cracks in pipes. The fhe normally expected background round leakage due to equipment design and the detection capability of the instrumentation instrumentation for determining system lea leakage was also considered. The evidence obtained obtained from experiments suggestss that for leakage leakage somewhat greater than that specified specified for for UNlDENTI IJNIDENT1I lED lEE) LEAKAGE the probability is small that the imperfection or rack associated with such lea crack leakage would grow rapidly. However, in all cases, if the leakage rates exceed exceed the values specified or the leakage is located and known to be PRESSURE PRESSURE BOUNDARY LEAKAGE, the reactor will be shutdown to al low further investigation allow and and corrective corrective action. action. The limitlimit of 2 2 gpm increase in UNIDENTIFIED UNIDENtIFIED LEAKAGE over a a 2424-hour hour periodriod andand the monitoring of drywell floor drain sump and drywel1 dryweli equipment drain tank tank flow ow rate at at least least once every eighteight (8) hours conforms with NRC staff positions specified specified in in NRC NRC Generic Generic Letter 88-01, 88-01, "NRC NRC Position on IGSCC in BWR Austenitic Stainless Stainless Steel Steel Piping," Piping, as as revised by NRC Sa Safety Evaluation dated March 6, 1990. The ACTION ACTION requirement requirement for for the 2 2 gpm gpmn increase in UNIDENTIFIED LEAKAGE limit limit ensures that such such leakage leakage is is identified identified or or a plant plant shutdown is initiated to allow further investigation investigation and and corrective corrective action. action. Once Once identified, identified, reactor operation may continue dependent dependent upon upon the the impact impact onon tota total1 lea ka ge. leakage. LIMERICK LIMERICK - UNIT

              -  UNIT 11                               B 3/4 B      4-3d 3/4 4-3d                         Amendment No.      -+/-4-{},
                                                                                                              ,         .~

REAC 10k [00 LAN I [YE I EM ll/V3LS Li[s3LtJ.LLoUCLLLCiJJL+/-J1iJL1L illtIL!!OIU ER 1 .1 1 .1 k ter the prteiinance of a CHANNEL FUNCTIONAL IIJNC I I0NAL IELEE off the roqu rod REE I ka delert ion ristrmnrarion. Ihe test ensures trlat that the moni tor can oerform their non I tors

nt len ii he fei red abner. he test il so von j t ilea thet tj a 1I arm setpoi nt and relative rccuri C y ot the instrument string.

[hi a ER a forr the performance rforma of it aa CHANNEL CAL BRATION CAL IBRAI of requl ION ot required red leakaqe detection natrumnenitatmun rhanrielI a.. libra ion vyenrifi he calibration ties Ule (curacy of the accuracy of the instrument string, including the in trument loca instruments located ininside containment. 1.3. I his ER prey desa tout no check of mary containment primary cunita nment pressure and temperature ra tu for for indirect evidence of RCS 1 eakage. REF ER E N C E S LOS U[SAR, .. 5.1*~=5

2. Regu 1 a tory i;io t

i( . Hay iCY .~~ [CS UFSAR, Seition 5 2 5 2 1 3 4 I ( UI SAR ,- ten L ) f) LGS LOS UFSAR, Section 5.2.5.2.1.4 LGS LOS U UI aAR Sf rtion ion 5 . / . 5 . 2 .1.1 1( 1(2) GE/\P GEAP562O,,April r i I 1968.968. NUREG-75/067, NlJREGi5/O6/, October 1975. [975. L i o n 5.2.5.6. .2. .6.

        ,1T             J 3/4 4 3 2 EWfWA1 IONAL LEAKACE fhe     Ilowabl leakage rates from the reactor coolant system have been based

[he allowable based on on the predicted and experimentally observed behavior of cracks in pipes. pes. The normally normally expected ba round Ileakage due to equi pment design and the detection background ion capabili capability of the instrumentation ins trumenta [ion for for determining determi ni rig system leakage ea was also a iso considered. The evidence ubta I nod from obtained trout 1 xperi rimen merits suggests that for lea leakage somewhat greater than that aped ifiedLied for UNIDENTIFIED IJNIDENFIFIED LEAKAGE the probability is i small that the imperfection i ion or sociated with such rack aassociated crack uchlea leakage would grow rapidly. However, in all cases, if the Ileakage rates exceed the values specified or the lea leakage is located and known to be PRESSURE BOUNDARYBOIJNDARY LEAKAGE, the reactor will wi 11 be he shutdown to allow al low further investigation and corrective action. tion. The limit 1 imi t of 2 2 gpm increa UNIDENTI lED LEAKAGE over aa 24-increase in UNIDENTIFIED 24-hour period and the monitoring of drywell floor drain sump and drywell equipment equi drain tank flow flow rate at least once every eight (8) hours conforms with NRC staff positions peci ied in NRC Generic Letter 88 specified 01, "NRC 88-01, NRC Position on IGSCC in BWR Austenitic Stainl Stainlesss SteelI Piping," Piping, as revised by NRC Sa Safety Evaluation dated March 6, 1990. 1990. [he The ACTION requirement for the 2 UNIDENTIFIED LEAKAGE limit ensures that 2 gpm increase in IJNIDENTIFIED such 1leakage kage is identified or aa plant shutdown is initiated to allow further investigation and corrective action. Once identified, reactor operation may continue dependent upon the the impact on total leakage. LIMERICK - UNIT UNIE 2 2 B B 3/4 4-3d Amendment 403, ~

                                                                                                                          +GJ, +
                                                                                                                               .R_

4

Insert 55 Insert 0, Reactor Revision 0, "Reactor Coolant Coolant Pressure Pressure Boundary Boundary Leakage Leakage Detection Detection Systems, May 1973. Systems," May 1973. Insert 66 Insert 9.

9. LGS UFSAR, UFSAR, Section Section 5,2,52.1,5 5.2.5.2.1.5}}