I looked at the BIFF specification for NOTES (which are actually comments on cells), and there is no limit in itself, only 2048 per NOTES record, but you can have as many of them as you want, they are marked as continuation entries past the first. With that in mind, it seems limitless.
However, to be safe, I am cutting mine at 15,000 (since we don't need more than 1,000 for what we do).
source share