ML19332F179

Ro:Air Ejector Exhaust Treatment Sys Inoperable for More than 31 Days.Sys Declared Inoperable.Failure to Implement Reporting Requirement Attributed to Inadequate Guidance in Interpretation of Intent & Requirement of Tech Spec

ML19332F179
Person / Time
Site:	San Onofre
Issue date:	11/30/1989
From:	Nandy F SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8912130501
Download: ML19332F179 (2)

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f saa,7-l' Southem Califomia Edison Company 23 PARKER STREET 1 Hp , IRVINC. CALIFORNIA 927 le li" ]

.comS",a"*c"bcom_ November 30,-1989 fffyy. I 1

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, U. S.: Nuclear Regulatory Commission l

.- Document Control Desk l

' Washington, D. C. 20555

Subject:

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Docket-No. 50-361- -

a -- Special: Report ,

. San Onofre Nuclear Generating Station, Unit 2 The purpose of this~-letter is to provide the Special Report required by l

" - ' Technical Specification (TS) 3.11.2.4, Action a, of Facility Operating License  ?

NPF-10-for' San Onofre Nuclear Generating Station, Unit 2, involving the air .

g ejector.. exhaust treatment system being inoperable for greater than 31 days. "

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+ :TS'3.11.2.4 governs the Ventilation Exhaust Treatment System-(VETS). The VETS 6 fincludecthe Condenser Evacuation System (CES) and its associated air ejector exhaust; treatment subsystem. .'This CES subsystem includes A-361 filtration' unit provided-with charcoal adsorbers and-high efficiency' particulate air filters ,

_;, -(HEPA) for the-purpose of removing. iodine or particulates from the gaseous air ejector exhaust: prior'to its: release to the. environment. During normal

-operations, A-361_is not utilized and the air ejector exhaust discharges through .

aTradiation monitor to the atmosphere.

sin the event of a primary-to-secondary steam generator tube leak, this discharge t may'be' radioactive. Under these circumstances, the activity detected by the monitor is annunciated in the control room, where control operators' are ,

idirected by procedures to divert the air ejector exhaust flow through A-361 before its release to the environment.

TS 4til.2.4.2 Surveillance Requirements specifies that the VETS be demonstrated operable:by o)erating the system equipment for 15 minutes at least once per 92

=daysfunless tie appropriate system has been utilized to process radioactive gaseous' effluents during the previous 92 days. On 10/01/89, with Unit 2 in Mode 6 -(Cycle:5 refueling outage), this surveillance became due. In Modes 5 or 6 the 4 -main condenser:is not in service and therefore the air ejector and vacuum pump are not in service. Without air ejector or vacuum discharge flow, the

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' surveillance for the air ejector exhaust treatment system could not be i completed. Consequently, the air ejector exhaust treatment system was declared inoperable in accordance with the surveillance procedure.

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L Document Control Desk Movember 30, 1989 i'

TS 3.11.2.4, Action a, requires a Special Report be submitted within 30-days of.  !

the VETS becoming inoperable. Our review of previous instances where the VETS was inoperable during Modes 5 or 6 outage concluded,that Southern California Edison Company (SCE) may not have implemented the reporting requirement in the i past for both Units 2 and 3. However, as discussed above the air ejector is not i

~in service in Modes 5 and 6, so there is no potential for releases through this pathway.

The failure to implement the reporting requirement has been attributed to inadequate guidance in interpretation of the intent and requirement of the TS.

As corrective action, appropriate guidance will be provided to Station and Licensing personnel.

On 11/24/89, the air ejector exhaust treatment system surveillance was satisfactorily completed. If you require any additional information, please

' advise.

Very truly yours, cc: J. B. Martin (Regional Administrator, USNRC Region V)

C. W. Caldwell (USNRC Senior Resident Inspector, Units 1, 2, and 3)

Institute of Nuclear Power Operations (INP0)

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