DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES

A.10 CTS 4.6.3.1..a requires testing of each containment isolation valve that is a weight or spring loaded check valve testable during unit operation every 92 days. The ITS does not contain this Surveillance. This changes the CTS by eliminating this Surveillance. This change is acceptable because the technical requirements have not changed. North Anna does not contain any containment isolation valves that are weight or spring loaded check valves which are testable during unit operation. Therefore, this surveillance is never performed. This change is designated as administrative because it does not result in technical changes to the CTS. A. 11 CTS 3.6.3.1 Action states, "With one or more of the isolation valves inoperable, CAT maintain at least one isolation valve OPERABLE in each affected penetration that is 3. 63- b open... " ITS Conditions A and B Notes state, "Only applicable to penetration flow paths with two containment isolation valves. " ITS Condition C Note states, "Only applicable to penetration flow paths with only one containment isolation valve and a closed system. " ITS Condition ITS 3.6.3 Required Actions A. 1 and C. 1 require the associated flow path be isolated by one of the means specified with one or mor