ML20055D253

Provides Status of Q-list Development at Plant & Revises Completion Date for Effort.Implementation of Q-list Would Cause Unnecessary & Costly Delays in Replanning Maint,Mod, outage-related Activities & Associated Procedure Revs

ML20055D253
Person / Time
Site:	Sequoyah
Issue date:	07/02/1990
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9007060045
Download: ML20055D253 (4)

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, f o TENNESSEE VALLEY = AUTHORITY

', CHATTANOOGA 4 TENNESSEE 374ol SN 157B' Lookout Place JUL 021990 1

U.S. Nuclear Regulatory Commission

-ATTN: . Document Control Desk Washington, D.C. 20555 a Gentlemen:

In the Matter of ) Docket Nos. 50-327 f .TetAessee . Valley Authority ) 50-328 i t

SEQUOYAH NUCLEAR PLANT (SQN) - REVISION OF THE COMPLETION DATE FOR THE Q-LIST-This letter provides the status of the Q-list development at SQN and revises {

'the completion date for this effort. '

TVA committed-to develop a-Q-list as an enhancement to existing processes, 3 specifically Sequoyah Standard Practice SQA134, " Critical Structures. Systems 1 and' Components (CSSC) List." In April 1989, TVA committed to have systems selected and components classified with data sheets prepared, and to have the Q-list. issued and incorporated in controlled binders by January 30, 1990.

_SQN has made significant progress toward the accomp1'ishment of this j commitment; however,:the January 30, 1990, completion.date could not be achieved. It was determined in January 1990 that it would take an additional ~

six weeks to' complete the classification of the remaining components, the  !

h interface' review, and the concurrence process. This status was' discussed:with 1

,the NRC' senior resident inspector at that time. TVA completed the- '

classification ofLthe components.and development of a list-of.these components  !

cn March 20, 1990. However during the review and concurrence process,

. potential problems were identified affecting implementation and commitment closure. l The first major problem affects implementation and involves component toverclassification. During the interface review and approval process of the -i components on the Q-list, it was determined that overclassification of a L number of components had occurred. The overclassification was the result of  ;

>the= mechanistic-based classification process that was used in lieu of a functional-based-classification prccess, for establishing a complete list of

. safety-related' components for the Q-list (e.g., all components associated with i LTVA Class lA, B, C, or D piping and all components receiving 1E power were '

classified as safety-related regardless'of function).- TVA recognized that-the mechanistic-based classification process would result in some over-classification of-components; however, when the. decision was made in 1988, the overclassification was not expected to.have such a significant impact. This overclassification resulted in needlessly changing many designations of components from nonsafety-related to safety-related; therefore causing changes 4 in the documentation requirements such that routine maintenance activities 9007060045 900702 '

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would have to be replanned to incorporate additional requirements (e.g'.,

materials, paperwork, and hold points). Under closer review, it was determined =that the impact on maintenance activities would have been significant and unnecessary. Functional reviews will be necessary to determine appropriate declassification.

The second major problem affects commitment closure, and involves the categorization of components field-installed since the initial ~ classification effort. In September 1988, the Q-list was baselined. Since then, TVA has implemented a significant number of modifications including the modifications ,

for the Unit 2 Cycle 3 and the Unit 1 Cycle 4 refueling outages. A mechanism did not exist to incorporate review of these modifications back into the ongoing baseline classification effort. Procedures are being established to provide for future maintenance and updating of the Q-list. Evaluation of design changes implemented since the initial baseline, up to the date-of.

issuance of the aforementioned procedures, is considered necessary prior to closure of the commitment.

In summary, implementation of the Q-list "as is" would cause_ unnecessary and costly delays in replanning maintenance, modification, outage-related activities, and associated unnecessary revision of procedures. Additionally, TVA considers evaluation and incorporation of past modifications, since the baseline, necessary to close the commitment. TVA willresolve both the overclassification issue and the categorization of design changes that have been field-completed since the September 1988 baseline. ?he resultant Q-list will'be implemented by January 4, 1991. The revised completion date for-the

,Q-list commitment is contained in the enclosure.

8 If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-6651. i Very truly yours TEhWESSEE VALLEY AUTHORITY

• b Mark O. Medford, Vice President Nuclear Technology and Licensing Enclosure cc: 'See Page 3

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cc (Enclosure): .

Ms. S. C. Black, Deputy Director Project Directorate II U.S. Nuclear Regulatory Commission One White Flint, North 11555'Rockv111e Pike, MS 13H2 Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road 3 Soddy Daisy, Tennessee 37379 Jack'N. Donohew U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville,. Maryland 20852 Mr. B. A. Wilson, Project Chief U.S.. Nuclear. Regulatory! Commission

, Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 l

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ENCLOSURE Commitment

' The Q-list will be issued'and implemented by January 4, 1991.

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