ML032690082

Amendments 107 to Licenses NPF-87 & NPF-89, Revising FSAR and TS Bases to Indicate Response Time Testing May Be Eliminated for Selected Reactor Trip System and Engineered Safety Features Actuation System Protection of Channel Equipment

ML032690082
Person / Time
Site:	Comanche Peak
Issue date:	09/25/2003
From:	Thadani M NRC/NRR/DLPM/LPD4
To:	Terry C TXU Energy
Thadani M, NRR/DLPM, 415-1476
Shared Package
ML032751033	List: ML032690082
References
TAC MB7984, TAC MB7985
Download: ML032690082 (20)

Text

September 25, 2003 Mr. C. Lance Terry Senior Vice President

& Principal Nuclear Officer TXU Energy ATTN: Regulatory Affairs P. O. Box 1002 Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 & 2 - ISSUANCE OF AMENDMENTS RE: ELIMINATION OF PERIODIC PROTECTION CHANNEL RESPONSE TIME TESTING (TAC NOS. MB7984 AND MB7985)

Dear Mr. Terry:

The Commission has issued the enclosed Amendment No. 107 to Facility Operating License No. NPF-87 and Amendment No. 107 to Facility Operating License No. NPF-89 for Comanche Peak Steam Electric Station (CPSES), Units 1 & 2, respectively. The amendments consist of changes to the Final Safety Analysis Report (FSAR) and Technical Specification (TS) Bases in response to your application dated March 6, 2003, as supplemented by letters dated July 25, August 29, and September 16, 2003.

Pursuant to TS 5.5.14b and 10 CFR 50.59, the amendments revise the CPSES, Units 1 and 2, FSAR and TS Bases to indicate that the response time testing may be eliminated for selected Reactor Trip System and Engineered Safety Features Actuation System protection channel equipment. The response time may be determined using the methodology described in Report WCAP-14036-P-A, Revision 1, Elimination of Protection Channel Response Time Tests.

A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Mohan C. Thadani, Senior Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosures:

1. Amendment No. 107 to NPF-87

2. Amendment No. 107 to NPF-89

3. Safety Evaluation cc w/encls: See next page

September 25, 2003 Mr. C. Lance Terry Senior Vice President

& Principal Nuclear Officer TXU Energy ATTN: Regulatory Affairs P. O. Box 1002 Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 -

ISSUANCE OF AMENDMENTS RE: ELIMINATION OF PERIODIC PROTECTION CHANNEL RESPONSE TIME TESTING (TAC NOS. MB7984 AND MB7985)

Dear Mr. Terry:

The Commission has issued the enclosed Amendment No. 107 to Facility Operating License No. NPF-87 and Amendment No. 107 to Facility Operating License No. NPF-89 for Comanche Peak Steam Electric Station (CPSES), Units 1 & 2, respectively. The amendments consist of changes to the Final Safety Analysis Report (FSAR) and Technical Specification (TS) Bases in response to your application dated March 6, 2003, as supplemented by letters dated July 25, August 29, and September 16, 2003.

Pursuant to TS 5.5.14b and 10 CFR 50.59, the amendments revise the CPSES, Units 1 and 2, FSAR and TS Bases to indicate that the response time testing may be eliminated for selected Reactor Trip System and Engineered Safety Features Actuation System protection channel equipment. The response time may be determined using the methodology described in Report WCAP-14036-P-A, Revision 1, Elimination of Protection Channel Response Time Tests.

A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Mohan C. Thadani, Senior Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosures:

1. Amendment No. 107 to NPF-87

2. Amendment No. 107 to NPF-89

3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC PDIV-1 Reading RidsNrrDlpmPdiv (HBerkow)

RidsNrrDlpmPdivLpdiv1 (RGramm) RidsNrrPMMThadani RidsAcrsAcnwMailCenter RidsNrrLADJohnson RidsOgcRp RidsRgn4MailCenter (AHowell)

G.Hill (4) DRIP/RORP/TSS VHall Package No.: ML032690115 TS Bases: NRR-100 Adams Accession No.: ML032690082 *See previous concurrence **SE dated 8/22/03 NRR-058 OFFICE PDIV-1/PM PDIV-1/LA RORP/SC EEIC/SC OGC PDIV-1/SC NAME MThadani:sab DJohnson CSS for EMarinos** RHoefling* nlo RGramm TBoyce w/changes DATE 9/22/03 9/22/03 9/25/03 08/22/03 09/10/03 9/25/03 OFFICIAL AGENCY RECORD DOCUMENT NAME: C:\ORPCheckout\FileNET\ML032690082.wpd

TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NO. 1 DOCKET NOS. 50-445 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 107 License No. NPF-87

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by TXU Generation Company LP, dated March 6, 2003, as supplemented by letters dated July 25, August 29, and September 16, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, by Amendment No. 107 the license is amended to authorize revision to the Final Safety Analysis Report (FSAR) and Technical Specification Bases pursuant to Technical Specification Section 5.5.14b, as set forth in the application for amendment by TXU Generation Company LP dated March 6, 2003, as supplemented by letters dated July 25, August 29, and September 16, 2003. TXU Generation Company LP shall update the FSAR in accordance with 10 CFR 50.71(e) and operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan to reflect the revised licensing basis authorized by this amendment.

3. The license amendment is effective as of its date of issuance, the Technical Specification Bases shall be implemented within 60 days from the date of issuance, and the FSAR changes shall be implemented in the next periodic update to the FSAR in accordance with 10 CFR 50.71(e).

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Technical Specification Bases Date of Issuance: September 25, 2003

TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NO. 2 DOCKET NO. 50-446 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.107 License No. NPF-89

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by TXU Generation Company LP, dated March 6, 2003, as supplemented by letters dated July 25, August 29, and September 16, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, by Amendment No. 107 the license is amended to authorize revision to the Final Safety Analysis Report (FSAR) and Technical Specification Bases pursuant to Technical Specification Section 5.5.14b, as set forth in the application for amendment by TXU Generation Company LP dated March 6, 2003, as supplemented by letters dated July 25, August 29, and September 16, 2003. TXU Generation Company LP shall update the FSAR in accordance with 10 CFR 50.71(e) and operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan to reflect the revised licensing basis authorized by this amendment.

3. The license amendment is effective as of its date of issuance, the Technical Specification Bases shall be implemented within 60 days from the date of issuance, and the FSAR changes shall be implemented in the next periodic update to the FSAR in accordance with 10 CFR 50.71(e).

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Technical Specification Bases Date of Issuance: Septelmber 25, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 107 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 107 TO FACILITY OPERATING LICENSE NO. NPF-89 DOCKET NOS. 50-445 AND 50-446 Replace the following pages of the Appendix A Technical Specification Bases with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert B 3.3-63 B 3.3-63 B 3.3-118 B 3.3-118 B 3.3-119 B 3.3-119

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 107 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. TO FACILITY OPERATING LICENSE NO. NPF-89 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446

1.0 INTRODUCTION

By application dated March 6, 2003, as supplemented by letters dated July 25, August 29, and September 16, 2003, TXU Generation Company LP (the licensee) requested changes, pursuant to 10 CFR 50.59 and Technical Specification (TS) Section 5.5.14b, to the Final Safety Analysis Report (FSAR) and TS Bases for the Comanche Peak Steam Electric Station (CPSES), Units 1 and 2. The supplemental letters dated July 25, August 29, and September 16, 2003, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no signficant hazards consideration determination as published in the Federal Register on April 15, 2003 (68 FR 18288).

The proposed changes would revise the FSAR and TS Bases to indicate that the response time for selected Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) protection channel equipment may be determined using the methodology described in WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, dated December 1995 (the WCAP). Specifically, the proposed changes would revise the Bases for TS 3.3.1 and TS 3.3.2 to cite this report and also add a new reference on TS Bases pages B 3.3-63 and B 3.3-119.

This safety evaluation addresses the acceptability of the proposed license amendments.

2.0 REGULATORY EVALUATION

The current standard technical specifications require nuclear power plants to periodically perform Response Time Tests (RTT) for instrument channels in the Reactor Protection System, Emergency Core Cooling System, and the Isolation Actuation System. The intent of these tests is to ensure that changes in instrumentation response time beyond the limits assumed in the plants safety analyses are detected and combined with instrument calibrations to ensure that the instrumentation is operating correctly.

The Institute of Electrical and Electronics Engineers (IEEE) Standard 338-1977, "Criteria for the Periodic Surveillance Testing of Nuclear Power Generating Station Safety Systems," which is endorsed in Regulatory Guide 1.118, Revision 2, "Periodic Testing of Electric Power and Protection Systems," defines a basis for eliminating RTT. Specifically, Section 6.3.4 of IEEE Standard 338-1977 states, in part, the following basis:

Response time testing of all safety-related equipment, per se, is not required if, in lieu of response time testing, the response time of the safety system equipment is verified by functional testing, calibration check, or other tests, or both. This is acceptable if it can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine periodic tests.

The Westinghouse Owners Group (WOG) performed two analyses to assess the impact of elimination of RTT for instruments and instrument loops. The first of these analyses was WOG Licensing Topical Report WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," dated August 1995. It was approved by the U.S.

Nuclear Regulatory Commission (NRC) staff as documented in a safety evaluation report (SER) dated September 5, 1995. The second, WCAP-14036-P-A, Revision 1, was approved by the NRC staff as documented in an SER dated October 6, 1998. Each of these SERs stipulated conditions that individual plant licensees must meet when implementing the guidelines in WCAP-13632 and WCAP-14036 on a plant-specific basis. The SER on WCAP-14036, which the licensee has used to justify the proposed changes, requires that the licensee verify that the Failure Modes and Effects Analysis (FMEA) performed in the WCAP is applicable to the equipment actually installed in the licensees facility, and that the analysis is valid for the versions of the boards used in the protection system.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensees regulatory and technical analyses in support of its proposed license amendment. The detailed evaluation of the TS Bases changes is provided in the following subsections. Corresponding changes to FSAR (Update) are provided by the licensee in Attachment 4 of the March 6, 2003, request for amendment.

3.1 TS Bases Changes The licensee proposed elimination of RTT for the RTS and Engineered Safety Feature systems, and instead will depend upon calibration and other periodic testing, as described in WCAP-14036, in order to determine the proper operation and functioning of the above systems instrumentation. In those cases where the TS Bases require the licensee to verify that a protective system can meet its protective function in a prescribed time, a bounding response time will be added to those portions of the protective system actually tested for response time in order to determine the total system response time. The requirement to actually measure the response times would be eliminated, and instead, the response times will be verified by summing allocated times for the process protection system, the nuclear instrumentation system, and the logic system. These allocated values will be added to the measured times for the sensors and actuated devices, and compared to the overall analysis limits.

Verification of RTT in the place of actual testing requires a TS Bases change. Appendix A of WCAP-14036 lists the TS Bases changes based on the Standard TS wording found in NUREG-0452, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors," and NUREG-1431, "Standard Technical Specifications - Westinghouse Plants."

These modify the following:

• TS Definitions: Add a sentence to the Engineered Safety Features Response Time (ESFRT) and Reactor Protection System Response Time (RPSRT) definitions.

• TS Instrumentation: In the Surveillance Requirements for ESFRT and RPSRT, change the word demonstrated to verified.

• TS Bases Instrumentation: Change the word demonstrated to verified and add two paragraphs.

• TS Bases Surveillance Requirements: In the sections addressing ESFRT and RPSRT, add two paragraphs.

• TS Bases

References:

In the sections addressing ESFRT and RPSRT, add two references.

The TS Bases changes listed in the licensees amendment request differ from those in the WCAP, which are based on Standard TS wording. This is because CPSES has adopted the Improved TSs, which already incorporate the majority of the wording changes.

The actual change to the licensee's TS Bases revises the TS Bases for "Engineered Safety Features (ESF) Response Time" and "Reactor Trip System (RTS) Response Time" to provide for verification of response time for selected components, provided that the components and the methodology for verification have been previously reviewed and approved by the NRC. The TS requirements for response time verification will continue to be implemented by surveillance requirements 3.3.1.16 and 3.3.2.10.

Based on the above, the NRC staff concludes that the proposed changes reflect the adoption of previous NRC-approved methods. They are based on the Westinghouse Report WCAP-14036-P-A, Revision 1, and the NRC staff SER approving the Westinghouse report; the adoption of the wording similar to the NRC staff-approved standard TSs; and addition of the citation of WCAP-14036-P-A, Revision 1, as a reference in the proposed Bases change pages.

Accordingly, the proposed changes to Bases pages B 3.3-63, B 3.3-118, and B 3.3-119 are acceptable.

3.2 Verification of Plant-Specific Conditions The SER approving WCAP-14036, Revision 2, states that licensees submitting plant-specific license amendment (TS Bases change) requests must verify that the FMEA performed by the WOG is applicable to the equipment actually installed in the licensee's facility, and that the analysis is valid for the versions of the boards used in the protection system. Westinghouse letters WOG-98-238, WOG-98-244, and WPT-16357, identify the versions of the 7300 system cards for which the FMEA referenced in WCAP-14036 is applicable. The licensee has confirmed that the FMEA presented in WCAP-14036 is applicable to and valid for the

equipment actually installed at CPSES. The staff has verified that with one exception, the FMEA is applicable to the equipment for which CPSES has requested the elimination of RTT.

The N-16 Power Range Module (PRM) was not included in WCAP-14036, and was therefore not approved for elimination of RTT in the staff SER. The licensee agreed that WCAP-14036 does not apply to this module, and its July 25, 2003, response to the staffs request for additional information (RAI) withdrew their request to eliminate RTT for the PRM. TXU Generation Company LP will continue to perform actual RTTs on the PRM.

3.3 Bounding Response Times When a plant accident analysis determines that a mitigation system is required to actuate in a certain response time, the testing for that response time is generally required by TS. The licensees amendment request will eliminate some of the testing previously required. The WCAP mentioned above provides adequate justification that calibrations and other surveillance testing will prove that the instruments are functioning properly. When the testing is not done to a portion of the instrument loop, but the TS Bases requires the verification of assumptions made in the accident analysis, some assumed or bounding value for the untested portion of the loop must be added to the tested portion, to arrive at a total system response time.

WCAP-14036 includes these maximum or bounding response times for the equipment which was analyzed in that report. Table 1 lists the values taken from section 4.5 of the WCAP which were used to determine the channel allocations. Tables 2 and 3 list the bounding sensor response times for CPSES which were included in Enclosure 3 of the July 25, 2003, TXU Generation Company LP RAI response.

The staff has verified that the values listed in the tables have been previously approved in the SER approving WCAP-14036, and are therefore acceptable.

3.4 FSAR (Updates) Changes The FSAR (Updates) changes provided by the licensee in Attachment 4 of the March 6, 2003, request for amendment correspond to the changes evaluated for TS Bases above. The proposed changes are, therefore, acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Texas State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration (68 FR 40721, published July 8, 2003) and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no

environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (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 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.

Principal Contributor: V. Hall Date: September 25, 2003

TABLE 1 SELECTED RESPONSE TIMES FROM WCAP-14036-P-A, REVISION 1 Board WCAP Allocation 7300 Process Protection System Multiplier/Divider - NMD 0.104 RTD Amplifier - NRA 0.213 Summing Amplifier - NSA 0.0381 Function Generator - NCH 0.0681 Loop Power Supply - NLP 0.060 Comparator - NAL 0.005 Westinghouse NIS Level Trip 0.065 Westinghouse Solid State Protection System All Reactor Trips 0.020 ESFAS Through Master Relay 0.088 ESFAS Slave Relays 0.0362 NOTES:

1 The licensee rounded up this number from 0.0375 2 Allocated time for each relay in series

TABLE 2 PROPOSED BOUNDING VALUES FOR COMANCHE PEAK STEAM ELECTRIC STATION REACTOR TRIP FUNCTIONS Function1 Nuclear Instrumentation/ SSPS Total 7300 System WCAP Process String WCAP SSPS String WCAP Allocation2 for which WCAP Allocation2 for which Allocation2 times are WCAP times credited are credited Power Range Neutron Flux NIS 0.065 Input+Logic 0.020 0.085 High Setpoint Power Range Neutron Flux NIS 0.065 Input+Logic 0.020 0.085 Low Setpoint Overtemperature N-16 NSA+NSA+NSA+ 0.119 Input+Logic 0.020 0.139 (Delta Flux Upper-Lower) NAL Overtemperature N-16 NSA+NSA+NSA+ 0.119 Input+Logic 0.020 0.139 (Delta Flux Lower-Upper) NAL Overtemperature N-16 NRA+NSA+NAL 0.256 Input+Logic 0.020 0.276 (Tcold)

Overtermperature N-16 NLP+NSA+NSA+ 0.141 Input+Logic 0.020 0.161 (Pressurizer Pressure) NAL Overtemperature N-16 NSA+NMD+NSA+ 0.329 Input+Logic 0.020 0.349 (N-16 Power) NSA+NCH+NSA+

NAL Overpower N-16 NSA+NMD+NSA+ 0.329 Input+Logic 0.020 0.349 NSA+NCH+NSA+

NAL Pressurizer Pressure Low NLP+NAL 0.065 Input+Logic 0.020 0.085 Pressurizer Pressure High NLP+NAL 0.065 Input+Logic 0.020 0.085 Reactor Coolant Flow Low NLP+NAL 0.065 Input+Logic 0.020 0.085 Undervoltage - Reactor N/A N/A Input+Logic 0.020 0.020 Coolant Pumps Underfrequency - Reactor N/A N/A Input+Logic 0.020 0.020 Coolant Pumps Steam Generator Water NLP+NAL 0.065 Input+Logic 0.020 0.085 Level Low - Low NOTES:

1 Reference CPSES Technical Requirements Manual, Table 13.3.1-1.

2 All response times presented in this table are specified in seconds.

TABLE 3 PROPOSED BOUNDING VALUES FOR CPSES ESFAS FUNCTIONS Function1 7300 System SSPS Total WCAP Process String WCAP SSPS String for WCAP Allocation4 for which Allocation which WCAP times Allocation4 4

WCAP times are credited are credited Safety Injection Containment Pressure NLP+NAL 0.065 High-1 ECCS Input+Logic+Master 0.124 0.189

+Slave+Slave Reactor Trip Input+Logic 0.020 0.085 Emergency DG Input+Logic+ 0.088 0.153 Operation Master+Slave Containment Spray Input+Logic+ 0.088 0.153 Pump Master+Slave Pressurizer Pressure Low NLP+NAL 0.065 ECCS Input+Logic+ 0.124 0.189 Master+Slave+

Slave Reactor Trip Input+Logic 0.020 0.085 Containment Ventilation Input+Logic+ 0.124 0.189 Isolation Master+Slave+

Slave Emergency DG Input+Logic+ 0.088 0.153 Operation Master+Slave Steamline Pressure Low NLP+NAL 0.065 ECCS Input+Logic+ 0.124 0.189 Master+Slave+

Slave Reactor Trip Input+Logic 0.020 0.085 Emergency DG Input+Logic+ 0.088 0.153 Operation Master+Slave

TABLE 3 (Continued)

Function1 7300 System SSPS Total WCAP Process String WCAP SSPS String for WCAP Allocation4 for which Allocation4 which WCAP times Allocation4 WCAP times are credited are credited Containment Spray Containment Pressure NLP+NAL 0.065 High-3 Containment Spray Input+Logic+ 0.088 0.153 Header Isolation Valves Master+Slave Containment Isolation Phase A Isolation Safety Injection Longest SI 0.065 Input+Logic+ 0.124 0.189 Signal Master+Slave+

Slave Steamline Isolation Containment Pressure NLP+NAL 0.065 Input+Logic+ 0.088 0.153 High-2 Master+Slave Steamline Pressure Steamline Pressure Low NLP+NAL 0.065 Input+Logic+ 0.088 0.153 Master+Slave Steamline Pressure High NLP+NAL 0.065 Input+Logic+ 0.088 0.153 Master+Slave Turbine Trip2 and Feedwater Isolation Steam Generator Water NLP+NAL 0.065 Input+Logic+ 0.088 0.153 Level High-High Master+Slave Safety Injection Longest SI 0.065 Input+Logic+ 0.088 0.153 Signal Master+Slave Auxiliary Feedwater Steam Generator Water NLP+NAL 0.065 Level Low-Low Motor Driven AFW Input+Logic+ 0.124 0.189 Master+Slave+

Slave Turbine Driven AFW Input+Logic+ 0.124 0.189 Master+Slave+Slave Safety Injection Longest SI 0.065 Input+Logic+Master 0.124 0.189 Signal +Slave+Slave Loss of Offsite Power3

TABLE 3 (Continued)

Function1 7300 System SSPS Total WCAP Process String WCAP SSPS String for WCAP Allocation4 for which Allocation4 which WCAP times Allocation4 WCAP times are credited are credited Auto Switchover to Containment Sump RWST Level Low-Low NLP+NAL 0.065 Input+Logic+Master 0.088 0.153 Coincident with Safety +Slave Injection NOTES:

1 Reference CPSES Technical Requirements Manual, Table 13.3.2-1.

2 Response time testing is not required for the Turbine Trip function.

3 The Loss of Offsite Power signal does not pass through the 7300 System or SSPS. This function is included in this table for completeness 4 All response times presented in this table are specified in seconds.

Comanche Peak Steam Electric Station, Units 1 & 2 cc:

Senior Resident Inspector Mr. Brian Almon U.S. Nuclear Regulatory Commission Public Utility Commission P. O. Box 2159 William B. Travis Building Glen Rose, TX 76403-2159 P. O. Box 13326 1701 North Congress Avenue Regional Administrator, Region IV Austin, TX 78701-3326 U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Ms. Susan M. Jablonski Arlington, TX 76011 Office of Permitting, Remediation and Registration Mr. Roger D. Walker Texas Commission on Environmental Regulatory Affairs Manager Quality TXU Generation Company LP MC-122 P. O. Box 1002 P. O. Box 13087 Glen Rose, TX 76043 Austin, TX 78711-3087 George L. Edgar, Esq. Terry Parks, Chief Inspector Morgan Lewis Texas Department of Licensing 1111 Pennsylvania Avenue, NW and Regulation Washington, DC 20004 Boiler Program P. O. Box 12157 County Judge Austin, TX 78711 P. O. Box 851 Glen Rose, TX 76043 Environmental and Natural Resources Policy Director Office of the Governor P. O. Box 12428 Austin, TX 78711-3189 Mr. Richard A. Ratliff, Chief Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, TX 78756-3189