United States Nuclear Regulatory Commission - Protecting People and the Environment

Removal of Component Lists from Technical Specifications (Generic Letter 91-08)


May 6, 1991 



TO:       ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION PERMITS FOR 
          NUCLEAR POWER REACTORS

SUBJECT:  REMOVAL OF COMPONENT LISTS FROM TECHNICAL SPECIFICATIONS 
          (Generic Letter 91-08)


This generic letter provides guidance for preparing a request for a license 
amendment to remove component lists from technical specifications (TS).  
This guidance provides an acceptable alternative to identifying every 
component by its plant identification number as it is currently listed in 
the tables of TS components.  The removal of component lists is acceptable 
because it does not alter existing TS requirements or those components to 
which they apply.  The nuclear industry and the U.S. Nuclear Regulatory 
Commission (NRC) identified this line-item TS improvement during 
investigations of TS problems.  Previous guidance was provided by Generic 
Letter 84-13 on removing the list of snubbers from TS. 

This guidance includes the incorporation of lists into plant procedures that 
are subject to the change control provisions for plant procedures in the 
Administrative Controls Section of the TS.  The removal of component lists 
from TS permits administrative control of changes to these lists without 
processing a license amendment, as is required to update TS component lists.  
Any change to component lists contained in plant procedures is subject to 
the requirements specified in the Administrative Controls Section of the TS 
on changes to plant procedures.  Therefore, the change control provisions of 
the TS provide an adequate means to control changes to these component 
lists, when they have been incorporated into plant procedures, without 
including them in TS.  

Licensees and applicants that plan to adopt this line-item TS improvement 
are encouraged to propose TS changes that are consistent with the guidance 
provided in Enclosures 1 and 2.  Enclosure 1 provides guidance on the TS 
changes for specific lists of components.  Enclosure 2 provides the 
applicable sections of the current standard technical specification (STS) 
requirements with the TS changes to allow the removal of component lists.  
The NRC project manager for the facility will review conforming amendment 
requests.  Proposed amendments that deviate from this guidance will lengthen 
the time required to complete the review.  Please contact the project 
manager or the contact identified below if you have questions on this 
matter.

This letter does not require any licensee to implement changes to their 
plant procedures or propose changes to their plant TS.  Action taken in 
response to 


Contact:  Tom Dunning, NRR/OTSB 
          (301) 492-1189 

9105020075 
.

Generic Letter 91-08                - 2 -                        May 6, 1991



the guidance provided in this generic letter is voluntary and is not a 
backfit under 10 CFR 50.109.  Therefore, Office of Management and Budget 
clearance is not required. 

However, the NRC staff recommends that licensees who previously requested a 
change to remove the list of containment isolation valves from their plant 
TS may wish to review the impact that this change can have on TS 
requirements as discussed in Enclosure 1.  In some cases, previous TS 
changes may have removed TS provisions that were identified only as part of 
the list of components that was removed from the TS.  If such provisions are 
not retained in the TS, as noted in Enclosures 1 and 2, they will no longer 
apply.  Likewise, some licensees may have TS that inappropriately reference 
other documents, such as the updated safety analysis report, for a list of 
those individual components to which the TS limiting conditions for 
operation apply.   As noted in Enclosure 1, these references do not 
accomplish the intent of the TS change to remove a list of components from 
TS.  Therefore, licensees that find either of these conditions may wish to 
submit a license amendment request to restore any TS provision that was 
inadvertently removed from the TS or to remove an inappropriate reference in 
the TS that would not accomplish the intent of removing the list from the 
TS. 

                                      Sincerely, 


                                      James G. Partlow
                                      Associate Director for Projects
                                      Office of Nuclear Reactor Regulation

Enclosures:
As stated 

.

Generic Letter 91-08                                             Enclosure 1


         REMOVAL OF COMPONENT LISTS FROM TECHNICAL SPECIFICATIONS (TS) 


Background

Generic Letter (GL) 84-13 provided guidance on removing the list of snubbers 
from technical specifications (TS).  After GL 84-13 was issued, many 
licensees submitted proposals on a plant-specific basis to remove other 
component lists from TS.  The nuclear industry has also recommended the 
removal of component lists from TS as a TS improvement.  This guidance for a 
license amendment request to remove component lists from TS is based on the 
experience of both the NRC and the industry.

The NRC staff noted that many license amendments had been required in order 
to add, delete, or modify the list of snubbers.  The staff concluded that 
the list of snubbers was not necessary, provided the TS were modified to 
specify those snubbers that are required to be operable.  Also, the staff 
noted that any changes in the quantities, types, or locations of snubbers 
would constitute a change to the facility and thus would be subject to the 
provisions of Section 50.59 of Title 10 of the Code of Federal Regulations 
(10 CFR).  The snubber TS was modified to state that the only snubbers 
excluded from the TS requirements were those installed on nonsafety-related 
systems, and then only if their failure or the failure of the system on 
which they were installed would have no adverse effect on any safety-related 
system.  The table with the list of snubbers and the associated references 
were removed from the limiting condition for operation (LCO) and the 
associated surveillance requirements.

Therefore, specifications may be stated in general terms that describe the 
types of components to which the requirements apply.  This provides an 
acceptable alternative to identifying components by their plant 
identification number as they are currently listed in tables of TS 
components.  The removal of component lists is acceptable because it does 
not alter existing TS requirements or those components to which they apply. 

Guidance on the Removal of Component Lists From TS

The approach taken in GL 84-13 to remove a list of components from TS may 
also be used to remove other component lists from TS.  To implement this 
approach, the TS should be revised to incorporate an explicit description of 
those components for which the TS requirements apply.  A list of those 
components must be included in a plant procedure that is subject to the 
change control provisions for plant procedures in the Administrative 
Controls Section of the TS.  This can be accomplished by incorporating in 
such a procedure the list that identifies all the components for which the 
TS requirements apply or by confirming that an existing procedure includes 
this list of components.  If a specification is revised such that the scope 
of those components to which it applies is increased, the additional 
components shall be added to the TS list when it is incorporated in a plant 
procedure.  Likewise, any list of TS components in existing procedures shall 
also be updated.  When component lists are included in plant procedures, the 
identification of the individual components to which the TS requirements 
apply will be a simple task.

Although some components may be listed in the updated final safety analysis 
report (FSAR), the FSAR should not be the sole means to identify these 
.

Generic Letter 91-08                - 2 -                        Enclosure 1



components.  Licensees are only required to update the FSAR annually, and 
they are only required to reflect changes made 6 months before the date of 
filing.  Thus, the FSAR may be out of date by as much as 18 months.  
However, to highlight the change controls of 10 CFR 50.59 or to clarify 
other issues related to these components, licensees may wish to include 
these component lists in the next update of the FSAR.  The Bases Section of 
the TS may reference the plant procedures where these lists are located; 
however, component lists should not be included in the Bases Section because 
the Bases Section lacks an appropriate regulatory process for change 
control.  Finally, it would be inappropriate for a limiting condition for 
operation of the TS to reference the FSAR or any other document to specify 
those individual components to which the TS requirements apply.  If such 
references were used, a change in those references could constitute a change 
to a TS requirement and such changes should only be made via the license 
amendment process.  This would negate the intent of removing the list from 
the TS which is to allow subsequent changes to the list without having to 
process a license amendment. 

The staff provides the following guidance for changing individual TS 
sections.  This guidance addresses considerations that are unique to 
specific types of component lists.

1.  Containment Isolation Valves

The specification for containment isolation valves applies to those valves 
that are listed in the table referenced in the TS.  The alternative to 
listing these valves in a TS table is the revision of the LCO to state "Each 
containment isolation valve shall be OPERABLE."  The reference to valves 
"specified in Table 3.6-2" should also be deleted from the action statement.  
Similarly, the surveillance requirements for (1) post-maintenance testing, 
(2) demonstrating automatic closure on isolation signals, and (3) confirming 
the isolation time of power-operated or automatic valves, should be revised 
to remove the reference to the TS table and revised to state "Each 
containment isolation valve shall . . ." or ". . . each power-operated or 
automatic containment isolation valve shall . . ."  

The list of containment isolation valves in the TS may not include all 
valves that are classified as containment isolation valves by the plant 
licensing basis.  Generally, the FSAR identifies those valves that are 
classified as containment isolation valves.  With this TS change, the LCO, 
remedial actions, and  surveillance requirements will apply for all valves 
that are classified as containment isolation valves by the plant licensing 
basis.  

The list of containment isolation valves typically includes footnotes that 
modify the TS requirements for these valves.  Such notes must be 
incorporated into the associated LCO so that they will remain in effect when 
the table containing these footnotes is removed from the TS.  One of these 
footnotes involves valves that are exempt from the requirements of TS 3.0.4.  
TS 3.0.4 precludes entry into an operational mode or condition when an LCO 
would not be met without reliance on the provisions of the action 
requirements.  The action requirements for containment isolation valves 
permit continued operation with an inoperable valve when the associated 
penetration is isolated.  Therefore, an exception to the limitation of TS 
3.0.4 on changes in operational modes or conditions is acceptable for this 
specification, and a statement may be added 
.

Generic Letter 91-08                - 3 -                        Enclosure 1



to the LCO under the action requirements to state "The provisions of 
Specification 3.0.4 do not apply."  This exception will apply to all 
containment isolation valves.  The increase in the scope of this exception 
is acceptable because it is consistent with the guidance provided in Generic 
Letter 87-09.  However, this statement is not necessary if TS 3.0.4 has been 
revised as allowed by Generic Letter 87-09. 

The list of containment isolation valves may also include a footnote that 
addresses an operational consideration for specific valves that may be 
opened on an intermittent basis under administrative control.  This 
provision applies to valves that are locked or sealed closed consistent with 
the design requirements of General Design Criteria (GDC) 55, 56, and 57 of 
Appendix A to 10 CFR Part 50.  The design of these valves includes positive 
control features to ensure that they are maintained closed.  Therefore, in 
the absence of this provision, the opening of these locked or sealed closed 
valves would be contrary to the operability requirements for these valves 
that are currently listed in the TS table of containment isolation valves.  
With the removal of the TS list of valves, the operability requirements will 
apply to all containment isolation valves that have the locked or sealed 
closed feature as required by these GDC.  

The staff concludes that an acceptable alternative to identifying specific 
valves that may be opened under administrative control would be the addition 
of a footnote to the LCO to state "Locked or sealed closed valves may be 
opened on an intermittent basis under administrative control."  With this 
change, the definition of Containment Integrity and the surveillance 
requirements for demonstrating containment integrity in Specification 
4.6.1.1 should be revised to remove the reference to the table of 
containment isolation valves.  These sections of the TS should be revised to 
state ". . . , except for valves that are open under administrative control 
as permitted by Specification 3.6.4." 

The footnote on opening valves under administrative control also may have 
been used in some plant TS for remote-manual valves associated with closed 
systems.  A remote-manual valve is an acceptable alternative to a locked or 
sealed closed valve for closed systems as stated in GDC 57 in Appendix A to 
10 CFR Part 50.  Therefore, this footnote need not remain in the TS to allow 
operators to open any remote-manual containment isolation valve associated 
with closed systems because such action is not contrary to the operability 
requirements for these valves. 

However, the NRC staff wishes to restate its position on considerations that 
constitute an acceptable administrative control for opening locked or sealed 
closed containment isolation valves.  Furthermore, these considerations 
should be stated in the Bases Section for this specification as the 
following and an updated copy of this section should be provided with the 
license amendment request. 

     The opening of locked or sealed closed containment isolation 
     valves on an intermittent basis under administrative control 
     includes the following considerations: (1) stationing an 
     operator, who is in constant communication with control room, 
     at the valve controls, (2) instructing this operator to close 
     these valves in an accident situation, and (3) assuring that 
.

Generic Letter 91-08                - 4 -                        Enclosure 1



     environmental conditions will not preclude access to close the 
     valves and that this action will prevent the release of radio-
     activity outside the containment.

Some plant TS may not have included provisions for opening locked or sealed 
closed valves on an intermittent basis under administrative control.  In 
this case, these containment isolation valves probably were not listed in 
the table being removed from the TS.  However as noted above, the removal of 
the list of valves from the TS results in the LCO operability requirements 
being applicable to all containment isolation valves.  This extends the 
operability requirements to those valves that utilize locked or sealed 
closed features to comply with the requirements of the GDC.  Therefore, if 
any of these valves are opened during the operational modes for which the 
LCO applies, the license amendment request should include the above footnote 
allowing these valves to be opened on an intermittent basis under 
administrative control as a proposed TS change. Also, the Bases Section 
should be updated to include the clarification of what constitutes 
appropriate administrative control for opening these valves. 

Another clarifying note used in the list of containment isolation valves 
identifies those valves that are not subject to Type C leak testing 
requirements of Appendix J to 10 CFR Part 50.  In this case, this notation 
does not alter the requirements of Appendix J but rather only clarifies 
where the NRC has granted exemptions to Type C leak testing or where 
Appendix J does not require this testing.  Therefore, the TS need not 
address this clarification, but it may be included with a list of these 
valves in the FSAR if it is desired to clarify the applicability of Appendix 
J requirements.  However, placing the current TS list of containment 
isolation valves in the FSAR would not restrict the applicability of the TS 
requirements to only the valves on that list.  As previously noted, the TS 
requirements would apply to all valves that have been defined as containment 
isolation valves in the plant licensing basis. 

Finally, some TS have included valve closure times in the list of 
containment isolation valves.  The inservice testing (IST) requirements 
referenced by Specification 4.0.5 include the verification of valve stroke 
times for a broader class of valves than those containment isolation valves 
that have been listed in the TS.  The removal of valve closure times that 
are included in some plant TS would not alter the TS requirements to verify 
that valve stroke times are within their limits.  Therefore, removal of 
these closure times is acceptable. 

Because plant-specific considerations may have required that these tables 
include other notes modifying the TS requirements for specific valves, any 
such exceptions should be stated in terms that identify the valves by 
function rather than by component number, if practical.  This guidance also 
applies to any other component list removed from TS that includes notes that 
alter the TS requirements.  If notes in these tables are only included for 
information and do not alter any TS requirement, the removal of these notes 
with the list of components would not affect the applicability of the TS 
requirements. 

2.  Reactor Coolant System Pressure Isolation Valves

Guidance on removing from the TS the list of reactor coolant system pressure 
isolation valves is pending the NRC staff's resolution of generic concerns 
with 
.

Generic Letter 91-08                - 5 -                        Enclosure 1



existing lists for these valves.  In the interim, licensees should not 
submit proposals to remove this list from the TS.


3.  Secondary Containment Bypass Leakage Paths

The TS on containment leakage includes a list of secondary containment 
bypass leakage paths.  The list identifies these leakage paths by 
penetration number for dual containment plants.  The combined leakage rate 
for all penetrations identified as secondary containment bypass leakage 
paths is specified.  

As part of the plant licensing basis, the FSAR defines the penetrations that 
are secondary containment bypass leakage paths.  This definition of 
"secondary containment bypass leakage paths" is adequate such that the TS 
requirements do not require further clarification upon the removal of this 
list from the TS.  Therefore, the TS requirements may be stated in terms of 
secondary containment bypass leakage paths without further clarification.  
For example, the limitation of TS 3.6.1.2.c on containment leakage rates 
should be revised to state the following: 

     A combined leakage rate of less than or equal to [0.10] La for all 
     penetrations that are secondary containment bypass leakage paths when 
     pressurized to Pa.


4.  Containment Penetration Conductor Overcurrent Protective Devices

The list of containment penetration conductor overcurrent protective devices 
includes those primary and backup fuses and breakers that preclude faults of  
a magnitude and duration that could compromise the integrity of electrical 
penetrations.  Because the number of overcurrent protective devices 
associated with electrical circuits penetrating containment may exceed the 
basic requirements for primary and backup protection, the description of 
these components should be stated to clarify those components to which the 
TS requirements apply.  Also, these requirements exclude circuits for which 
credible fault currents would not exceed the electrical penetration design 
rating.  For example, these requirements exclude thermocouple and other 
low-power-level signal circuits.  An alternative to listing these components 
in a TS table is the following LCO statement:  

     Primary and backup containment penetration conductor overcurrent 
     protective devices associated with each containment electrical 
     penetration circuit shall be OPERABLE.  The scope of these protective 
     devices excludes those circuits for which credible fault currents would 
     not exceed the electrical penetration design rating.  

In addition, the surveillance requirements should state "The above noted 
primary and backup containment penetration conductor overcurrent protective 
devices . . ." rather than referring to those components listed in Table 
8.3-1. 
.

Generic Letter 91-08                - 6 -                        Enclosure 1



5.  Motor-Operated Valves Thermal Overload Protection 

The TS contain a list of valves that have thermal overload protection and 
bypass devices integral with the motor starter.  The table in the TS lists 
the valves by number, the bypass device, and the system affected.  With the 
removal of this list of valves from the TS, the LCO should state "The 
thermal overload protection and bypassed devices, integral with the motor 
starter, of each valve used in safety systems shall be OPERABLE."   This 
statement for the LCO adequately defines the scope of the valves that 
include these features to which the TS requirements apply. 


6.  Other Component Lists

Component lists other than those previously described herein may be 
candidates for removal from TS on a plant-specific basis.  A proposal to 
remove any other TS component list should be based on this guidance and any 
considerations that may be unique to a particular list.


Summary 

A request to remove component lists from TS should address the following 
issues: 

1.   Each TS should include an appropriate description of the scope of the 
     components to which the TS requirements apply.  Components that are 
     defined by regulatory requirements or guidance need not be clarified 
     further.  However, the Bases Section of the TS should reference the 
     applicable requirements or guidance. 
     
2.   If the removal of a component list results in the loss of notes that 
     modify or provide an exception to the TS requirements, the 
     specification should be revised to incorporate that modification or 
     exception.  The modification or exception should be stated in terms 
     that identify any group of components by function rather than by plant 
     identification number, if practical.  

3.   Licensees should confirm that the lists of components removed from the 
     TS are located in appropriately controlled plant procedures.  The list 
     of components may be included in the next update of the FSAR.  The 
     Bases Section of individual specifications also may reference the plant 
     procedures or other documents that identify each component list.  The 
     Bases Section for the containment isolation valve TS should be updated 
     to describe the intent of opening valves under administrative control.

This guidance is not to be used to remove from TS any table that addresses 
information or requirements other than a list of components to which a 
specification applies.  Enclosure 2 provides the applicable sections of the 
current STS requirements and the associated TS changes that are necessary to 
allow the removal of the components lists.   
.

Generic Letter 91-08                - 1 -                       Enclosure  2


                 EXISTING STS REQUIREMENTS AND CHANGES TO ALLOW 
                         THE REMOVAL OF COMPONENT LISTS 


3/4.6.4  CONTAINMENT ISOLATION VALVES (Existing) 

3.6.4  The containment isolation valves specified in Table 3.6-2 shall be 
OPERABLE with isolation times as shown in Table 3.6-2. 

ACTION: 

With one or more of the isolation valve(s) specified in Table 3.6-2 inoper-
able, maintain at least one isolation valve OPERABLE in each affected 
penetration that is open and: 

     a.   . . . . 


ALTERNATIVE: (Changes high-lighted by underline or shown with (_) for 
deletions.) 

3.6.4  Each containment isolation valve shall be OPERABLE.* 

ACTION: 

With one or more of of the isolation valves(s) (_) inoperable, maintain at 
least one isolation valve OPERABLE in each affected penetration that is open 
and: 

     a.   . . . . 

(New statement under ACTION requirements.) 

The provisions of Specification 3.0.4 do not apply. 

(New footnote for TS 3.6.4.) 

*Locked or sealed closed valves may be opened on an intermittent basis under
administrative control. 

SURVEILLANCE REQUIREMENTS (Existing) 

4.6.4.1  The isolation valves specified in Table 3.6-2 shall be demonstrated 
OPERABLE prior to returning the valve to service after maintenance, repair, 
or replacement work is performed on the valve or its associated actuator, 
control, or power circuit by performance of a cycling test and verification 
of isolation time. 

4.6.4.2  Each isolation valve specified in Table 3.6-2 shall be demonstrated 
OPERABLE during the COLD SHUTDOWN or REFUELING MODE at least once per 18 
months by: 

     a.   . . . . 

4.6.4.3  The isolation time of each power-operated or automatic valve of 
Table 3.6-2 shall be determined to be within its limit when tested pursuant 
to Specification 4.0.5. 
.

Generic Letter 91-08                - 2 -                       Enclosure  2



ALTERNATIVE: 

4.6.4.1  Each containment isolation valve (_) shall be demonstrated OPERABLE 
prior to returning the valve to service after maintenance, repair, or 
replacement work is performed on the valve or its associated actuator, 
control, or power circuit by performance of a cycling test and verification 
of isolation time. 

4.6.4.2  Each containment isolation valve (_) shall be demonstrated OPERABLE 
during the COLD SHUTDOWN or REFUELING MODE at least once per 18 months by: 

     a.        . . . . 

4.6.4.3  The isolation time of each power-operated or automatic containment 
isolation valve (_) shall be determined to be within its limit when tested 
pursuant to Specification 4.0.5. 


DEFINITIONS 

CONTAINMENT INTEGRITY (Existing) 

1.7  CONTAINMENT INTEGRITY shall exist when: 

     a.   All penetrations required to be closed during accident conditions 
          are either: 
     
          1)   Capable of being closed by an OPERABLE containment automatic 
               isolation valve system, or

          2)   Closed by manual valves, blind flanges, or deactivated 
               automatic valves secured in their closed positions, except as 
               provided in Table 3.6-2 of Specification 3.6.4.

     b.   . . . . 


ALTERNATIVE 

1.7  CONTAINMENT INTEGRITY shall exist when: 

     a.   All penetrations required to be closed during accident conditions 
          are either: 
     
          1)   Capable of being closed by an OPERABLE containment automatic 
               isolation valve system, or

          2)   Closed by manual valves, blind flanges, or deactivated 
               automatic valves secured in their closed positions, except 
               for valves that are open under administrative control as 
               permitted by Specification 3.6.4.

     b.   . . . . 
.

Generic Letter 91-08                - 3 -                       Enclosure  2



3/4.6.1  PRIMARY CONTAINMENT  (Existing) 

4.6.1.1  Primary Containment Integrity shall be demonstrated: 

     a.   At least once per 31 days by verifying that all penetrations* not 
          capable of being closed by OPERABLE containment automatic 
          isolation valves and required to be closed during accident 
          conditions are closed by valves, blind flanges, or deactivated 
          automatic valves secured in their positions, except as provided in 
          Table 3.6-2 of Specification 3.6.4.

     b.   . . . . 


ALTERNATIVE: 

4.6.1.1  Primary Containment Integrity shall be demonstrated: 

     a.   At least once per 31 days by verifying that all penetrations* not 
          capable of being closed by OPERABLE containment automatic 
          isolation valves and required to be closed during accident 
          conditions are closed by valves, blind flanges, or deactivated 
          automatic valves secured in their positions, except 
          for valves that are open under administrative control as 
          permitted by Specification 3.6.4.

     b.   . . . . 


CONTAINMENT LEAKAGE (Existing) 

3.6.1.2  Containment leakage rates shall be limited to: 

     a.   . . . . 

     b.   . . . . 

     c.   A combined leakage rate of less than or equal to [0.10] La for all
          penetrations identified in Table 3.6-1 as secondary containment 
          bypass leakage paths when pressurized to Pa. 
          

ALTERNATIVE: 

3.6.1.2  Containment leakage rates shall be limited to: 

     a.   . . . . 

     b.   . . . . 

     c.   A combined leakage rate of less than or equal to [0.10] La for all
          penetrations that are secondary containment bypass leakage paths 
          when pressurized to Pa.
.

Generic Letter 91-08                - 4 -                       Enclosure  2



ELECTRICAL EQUIPMENT PROTECTIVE DEVICES (Existing) 

3.8.4.2  All containment penetration conductor overcurrent protective 
devices given in Table 3.8-1 shall be OPERABLE.  

ACTION: 

With one or more of the containment penetration conductor overcurrent 
protective device(s) given in Table 3.8-1 inoperable: 

     a.   . . . . 

ALTERNATIVE: 

3.8.4.2  Primary and backup containment penetration conductor overcurrent 
protective devices associated with each containment electrical penetration 
circuit shall be OPERABLE.  The scope of these protective devices excludes 
those circuits for which credible fault currents would not exceed the 
electrical penetration design rating. 

ACTION: 

With one or more of the containment penetration conductor overcurrent 
protective device(s) (_) inoperable: 

     a.   . . . . 

SURVEILLANCE REQUIREMENTS (Existing) 

4.8.4.2  All containment penetration conductor overcurrent protective 
devices given in Table 3.8-1 shall be demonstrated OPERABLE: 

     a.   . . . . 

ALTERNATIVE 

4.8.4.2  All containment penetration conductor overcurrent protective 
devices (_) shall be demonstrated OPERABLE: 

     a.   . . . . 



MOTOR-OPERATED VALVES THERMAL OVERLOAD PROTECTION AND BYPASS DEVICES 
(Existing) 

3.8.4.3  The thermal overload protection and bypass devices, integral with 
the motor starter, of each valve listed in Table 3.8-2 shall be OPERABLE. 

ALTERNATIVE: 

3.8.4.3  The thermal overload protection and bypass devices, integral with 
the motor starter, of each valve used in safety systems shall be OPERABLE. 
.

Generic Letter 91-08                - 5 -                       Enclosure  2



With the above changes, the associated tables are to be removed from the TS.  
This should be done by removing the table title, name, and its contents.  
The associated pages of the TS should be noted as "Not used"  and can be 
accomplished using a single page that notes those pages that are no longer 
used.  It would not be appropriate to retain the table name and number with 
a reference to a document that contains a list of components to which the 
associated TS applies.  If such references are desired, they can be 
incorporated into the Bases Section of the associated TS.  As a 
house-keeping measure, the TS index should be likewise updated to remove all 
references to tables of component lists that have been removed from the TS.  


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