IR 05000373/1987003

Insp Repts 50-373/87-03 & 50-374/87-04 on 870202-27. Deficiencies Noted:Lack of Technical Justification for Failure to Perform Maint on Environmentally Qualified Thermocouple 2TE-CM058

ML20207T964
Person / Time
Site:	LaSalle
Issue date:	03/13/1987
From:	Gardner R, Gautam A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207T875	List: ML20207T873 ML20207T964
References
50-373-87-03, 50-373-87-04, 50-373-87-3, 50-373-87-4, NUDOCS 8703240449
Download: ML20207T964 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-373/87003(DRS); 50-374/87004(DRS)

Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: LaSalle County Station, Units 1 and 2 Inspection At: LaSalle Site, Marseilles, Illinois Glen Ellyn, Illinois Inspection Conducted: February 2-27, 1987 VE Inspector: A. S. Gautam 1) 3-/3-37 Reactor Inspector, Region III Date Also participating in the inspection and contributing to the report were:

R. Smeenge, RIII M. Kopp, RIII L. Bustard, Sandia National Labs D. Brosseau, Sandia National Labs D. Jackson, INEL H. Stromberg, INEL J. McGhee, INEL R. Lasky, VPB, IE k. h . <

Approved By: R. N. Gardner, Section Chief 3 -13- M Plant Systems Section, Region III Date Inspection Summary Inspection on February 2-27, 1987 (Reports No. 50-373/87003(DRS);

50-374/87004(DRS))

Areas Inspected: Special announced safety inspection of the environmental qualification (EQ) of electric equipment within the scope of 10 CFR 50.4 The inspection included licensee action on SER/TER commitments; EQ program compliance to 10 CFR 50.49; adequacy of EQ documentation; and a plant physical inspection of EQ equipment (Modules No. 30703 and No. 25576).

Results: The licensee has implemented a program to meet the requirements of 10 CFR 50.49. Deficiencies in the areas inspected are summarized below:

G703240449 870313

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o POTENTIALLY ENFORCEABLE / UNRESOLVED ITEM Item Numbe Description Report Section 50-374/87004-03(DRS) Lack of technical justification in 5a the EQ binder L9029 regarding the Itcensee's failure to perform maintenance on environmentally qualified (EQ) thermocouple 2TE-CM05 OPEN ITEMS 50-373/87003-01(DRS) Qualification of Comsip 3 50-373/87004-01(DRS) Hydrogen oxygen analyzers to be completed by end of second outage of both unit /87003-02(DRS) Lack of formal EQ training 4e 50-374/87004-02(DRS) for craftspeople performing EQ activities.

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DETAILS 1. Persons Contacted Commonwealth Edison Company (CECO)

• J. Dietrich, Station Manager

• R. D. Bishop, Services Superintendent

• J. C. Renwick, Production Superintendent R. W. Stobert, Quality Assurance Superintendent W. E. Sheldon, Assistant Superintendent, Technical Services

• P. F. Manning, Assistant Superintendent, Technical Services

• C. M. Allen, Licensing Administrator

• T. A. Hammerich, Technical Staff Supervisor

• R. Gramms, SNED/E&Q Group

• J. Clark, SNED/E&Q Group

• H. L. Masin, Project Engineer

• M. Martinovich, EQ Coordinator, Technical Staff

+*W. Marcis, SNED Engineer

• D. Spencer, Lead Electrical Engineer

• D. A. Winchester, Senior QA Inspector

• M. L. Musser, QA Engineer K. C. Wittenburg, Technical Staff Engineer

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• Sharma, Electrical Engineer, Technical Staff l *J. Roth, Braidwood Technical Staff l D. Kruger, EQ Coordinator, Byron

• J. L. Spangler, Electrical Maintenance R. Lingo, Instrument Department J. Clark, EQ SNED Engineer J. Kolanowsky, SNED LaSalle Group

• J. L. Payton, Master Electrician

• S. J. Laughlin, Storekeeper

• C. Sanfora, Assistant Storekeeper Sargent & Lundy (S&L)

• J. Sinnappan, Supervisor

• B. Pikelny, Senior Engineer

• A. Behera, Consultant

• R. Tjernlund, Senior Project Engineer

• J. D. Regan, Electrical Project Engineer USNRC

• J. Malloy, Resident Inspector

• Denotes those attending the interim site exit interview on February 6,198 + Denotes those attending the exit interview on February 27, 1987, at the conclusion of the inspectio ;

2. Licensee Action on Previous Inspection Findings (Closed) Open Item (373/86034-02(DRS); 374/86035-02(DRS)): This item addressed unqualified Raychem and Okonite splices, which had been identified by Licensee Event Report (LER)86-102. The licensee has performed 100 percent walkdown inspections of all EQ splices in both Units 1 and 2. During the walkdown inspections, splices were examined for proper length, oversize or undersize shrink tubing, improper heating, exposed wires, splice bend radius, cracks or other abnormalitie Inspection findings for Unit I were identified in Sargent & Lundy Report No. SL-4427 and the inspection findings for Unit 2 were identified in Work Request L-59133. All unqualified splices identified have been reworked, replaced or qualified through testing and analysi To preclude future unqualified splices, the licensee has revised Procedures LEP-GM-113, " Termination and Taping," and LEP-GM-112, " Cable Acceptance and Repair," to require that splices are to be installed using the vendors recommended installation procedure In addition, the licensee has implen'ented new Procedures LEP-GM-136, "Raychem Heat Shrink Installation," and LEP-GM-137, " Methods of Taping Terminations," which provide the vendors recommended installation procedures and also identify QC check points to be used during the installation of EQ splice During this inspection, the NRC inspectors reviewed the results of the licensee's walkdown inspections, the EQ files for Raychem splices and Okonite splicing tapes, and the licensee procedures for splice Installed splices were examined by the NRC inspectors during the plant walkdown including the stockroom supply of qualified Okonite tapes and adhesives for expiration dates and proper storage. No further concerns were identified.

3. Licensee Action on SER/TER Commitments The NRC inspection team evaluated the implementation of the licensee's EQ corrective action commitments made as a result of EQ deficiencies identified by the NRC in their March 1981 Safety Evaluation Report (SER)

NUREG-0519 and subsequent SER Supplements 1 and 5, for the environmental qualification of safety-related electrical equipmen The majority of the deficiencies identified in the SERs addressed documentation, similarity, aging, qualified life and replacement schedules. All open items identified in the SERs were discussed with the NRC staff, and the licensee's proposed resolutions to these items were found acceptable by the NRC, as stated in their NUREG-0519 Supplement 5, March 25, 1985 SER. The primary objective of the Region III EQ Audit in this area was to verify that appropriate analyses and necessary documentation to support the licensee's proposed and accepted resolutions to NRR were contained in the licensee's EQ files, and that appropriate modifications or replacement < of equipment had been implemente _-. - _-

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During this review, the NRC inspection team selectively reviewed EQ documentation and examined equipment in the plant relevant to prior discrepancies identified in the SERs, including licensee corrective action on Limitorque actuators, Comsip Hydrogen oxygen analyzers, Klockner-Moeller AC motor control centers, Magnetrol level switches, and Terminal Boards. Relevant details are noted below: I In a November 6, 1985, letter the NRC allowed an extension of the deadline for the environmental qualification of the Klockner-Moeller MCCs till November 30, 1985. These MCCs were tested successfully prior to this deadlin The NRC allowed an extension for the qualification of the Comsip Hydrogen Oxygen analyzers till August 1986, as this item was part of the licensee's Regulatory Guide 1.97 review. The licensee later in a March 10, 1986 letter, responded with a commitment to qualify these analyzers prior to startup after the second refueling outage in both units, and submitted a justification for the continued operation of the plant for postulated failures of these analyzers. The NRC found the licensee's approach acceptable, and pending the licensee's qualification of the analyzers, this is an Open Item (50-373/87003-01; 50-374/87004-01).

4. EQ Program Compliance to 10 CFR 50.49 The inspectors reviewed selected areas of the licensee's EQ program to verify compliance to 10 CFR 50.49. The licensee's EQ program was found to identify methods of equipment qualification; provide for evaluation and maintenance of EQ documentation in an auditable form, including maintenance records; provide for updating of replacement equipment, and control of plant modifications. Based on their review, the inspectors determined that the licensee had established an adequate EQ program in compliance with the requirements of 10 CFR 50.49. The licensee's methods for establishing and maintaining the environmental qualification of ( electrical equipment were reviewed in the following areas: EQ Program Procedures l The inspectors examined the adequacy of the licensee's policies and procedures for establishing and maintaining the environmental qualifications of equipment within the scope of 10 CFR 50.49. The licensee's EQ program was reviewed for procurement of qualified equipment; maintenance of qualified equipment; modifications to the plant that could affect qualified equipment; updating of the EQ master list; and review and approval of EQ documentatio Procedures reviewed included the following documents:

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LAP-100-11, "LaSalle County Station General Surveillance Program," Revision 8, dated May 8, 198 *

LAP-300-6, "LaSalle County Station Instrument Surveillance Program," Revision 1, dated November 21, 198 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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LAP-300-11, " Computerized Maintenance History Program,"

Revision 6, dated August 20, 198 * LAP-400-5, " Technical Evaluation of Parts Used in Safety-Related Components," Revision 3, dated January 21, 198 *

LAP-400-6, " Maintenance and Surveillance of Environmentally Qualified Plant Equipment," Revision 1, dated November 14, 198 *

LAP-400-7, " Potential Environmental Qualification (EQ)

Variation," Revision 0, dated January 15, 198 *

LAP-400-8, " Environmentally Qualified NUREG-0588 Category II Equipment Replacement Procedure," Revision 0, dated January 27, 198 *

LAP-500-7, " Request for Purchase," Revision 10, dated December 5, 198 *

LAP-1300-1, " Work Requests," Revision 34, dated December 5, 198 *

LAP-1300-2, " Plant Modifications," Revision 21, dated January 2, 198 *

SNED Procedure Q.6, " Modifications Originated by Station Technical Staff," Revision 14, dated December 1, 198 *

SNED/PE Procedure Q.42, " Environmental Qualified Documentation Preparation, Control and Acceptance," Revision 4, dated May 23, 198 *

Instruction PI-LSNS-10, " Environmental Qualification of Safety-Related Equipment," Revision 2, dated February 22, 198 *

Instruction PI-LSNS-17, " Preparation and Maintenance of the Q-List," Revision 3, dated January 28, 198 *

Instruction PI-LSNS-44, " Classification of Components,"

Revision 0, dated January 21, 198 Specific areas reviewed in these procedures included definitions of harsh and mild environments, equipment qualified life, service conditions, periodic testing, maintenance and surveillance, and upgrading of replacement equipment purchased after February 22, 198 I i

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b. 10 CFR 50.49 Master Equipment List (MEL) of EQ Equipment IE Bulletin No.79-01B required licensees of all power reactor facilities with an operating license to provide a MEL that identified each Class IE electrical equipment item relied upon to perform a safety function during a design basis event. 10 CFR 50.49, Paragraph (d), requires licensees to prepare a list of electric equipment important to safety and within the scope of the rul The NRC inspectors reviewed the MEL for compliance to 10 CFR 50.4 Areas reviewed included adequacy of the MEL, technic.; justifications for removal of items from the MEL, and licensee reviews of the MEL for changes due to field modification The inspectors verified the completeness / adequacy of the list in terms of equipment needed under accident conditions through review of Piping and Instrumentation Drawings (P& ids), Emergency Procedures, Technical Specifications and FSAR Since the LaSalle Emergency Operating Procedures do not reference specific plant instrument or equipment when describing required operator actions, safety-related equipment used by the operators to accomplish plant shutdown was selected for review. Plant emergency operating procedures compared to the Master EQ Lists included Reactor Level / Pressure Control (LGA-01), Secondary Containment Control (LGA-02), Primary Containment Control (LGA-03),

and the procedure for Primary Containment Level Determination, (LOA PC-05) P& ids for the Nuclear Boiler Instrumentation System, Low Pressure Core Spray (LPCS) System, Residual Heat Removal (RHR)

System, High Pressure Core Spray (HPCS) System, and Leak Detection System were also reviewed and compared to the Master EQ Lis No violations of NRC requirements were identifie c. EQ Maintenance and Surveillance Program The inspector reviewed specific maintenance, replacement, surveillance tests, and inspections necessary to preserve the environmental qualification of EQ equipment identified on the ME The NRC inspectors compared the requirements of the licensee's maintenance procedures for compliance to EQ requirements in the Maintenance Section of the licensee's EQ binders for selected components. The inspectors also reviewed maintenance records to verify performance of maintenance and surveillance activities at prescribed intervals, including gasket inspection, lubrication, torque of housing covers and installation of replacement part During review of maintenance records for specific equipment, the inspectors noted that required EQ maintenance activities listed in the EQ binder had not been performed on the WEED thermocouple 2TE-CM05 The licensee took immediate corrective action and performed the required maintenance on the thermocouple. This deficiency is further addressed in Section 5a of this repor __

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~ Plant Procurement and Upgrading of Replacement Equipment Licensee procedures were _found to adequately address upgrading of replacement equipment purchased after February 22, 198 Procurement procedures and documents were found to adequately, address appropriate quality and regulatory requirements'regarding the environmental qualification of equipment within the scope of 10 CFR 50.49. Checklists were observed to have been used to provide evidence of. reviews and approvals. .For example, procurement packages for replacement Rosemount transmitters, transmitter amplifier boards and ASCO solenoid valves were found to properly-address upgrading of replacement equipment to requirements of IEEE 323-197 No violations of NRC requirements were' identifie Quality Assurance (QA) and Training Program During this. review, the inspectors determined that the licensee

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had implemented a program to monitor the quality of EQ activities through surveillance, audits, and reviews of the records and files for plant modifications and equipment procurement. NRC inspectors reviewed the licensee's QA Audit 01-86-15 conducted in June 1986, and 01-87-35 conducted in January 1987, and found the audit methodology, results and followup of audit findings acceptabl The NRC' inspectors also-reviewed the licensee's staff training program and associated records relative to the performance of EQ activities. The training program was found to address key aspects of 10 CFR 50.49 requirements and training records. indicated that key personnel in management,-operations and maintenance had been.given EQ training. The following exception was note The NRC inspectors observed that no formal EQ training had been given to crafts personnel performing field activities on EQ equipment. The licensee stated that plant safety had not been compromised as EQ requirements were identified in work requests and procedures. .The licensee has a program in place to provide EQ training to all-new personnel, and during this review agreed to provide formal training to all appropriate craft personne Pending NRC review of the- licensee's action in this area, this is a Open Item I (50-373/87003-02(DRS); 50-374/87004-02(DRS)).

[ 5. Detailed Review of Qualification Files

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The licensee qualified their EQ equipment to requirements of the NUREG-0588 Category II (10 CFR 50.49, Paragraph K). The inspectors

reviewed over 42 equipment qualification files for evidence of the j environmental qualification of equipment within the scope of 10 CFR 50.49

and evidence of equipment qualification to NUREG-0588 Category II. Files

! were found to include a full description of the equipment; similarity I analysis of tested equipment to that installed in the plant; allowed

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mounting methods an'd orientation; qualification of interfaces (conduit housing, seal, etc.); evaluation of aging effects on equipment; description

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, of test sequence and methodology; environmental conditions for the equipment during an accident; qualification for submergence of applicable

equipment; resolution of test anomalies; and maintenance / surveillance criteria for the preservation of the qualified status of the equipment.

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The inspectors selectively reviewed the above areas, as applicable, including special reviews for the required duration of operability of equipment; licensee evaluation of tested materials and configurations

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relative to actual plant installations; adequacy of test conditions;

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aging calculations for qualified life and replacement intervals; effects

.of decreases in insulation resistance on equipment performance; adequacy of demonstrated accuracy of equipment and interfaces during an accident; and licensee evaluations of discrepancies identified in IE Notices and Bulletins.

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EQ files were reviewed for electrical cables, cable splices, . terminations, *

terminal blocks, electric motors, solenoid valves, electrical penetrations,

seals, lubricants,. transmitters, detectors, radiation monitors, protection, control and indication switches, switch gear; control panels and miscellaneous Electrical devices. The inspectors found that the files allowed verification of equipment qualification to a specified performance-for accident conditions. Details are noted below:

WEED Thermocouples, EQ Binders LS029

During review of maintenance requirements for the environmental qualification of the WEED thermocouple, the. inspectors noted that

i specified maintenance activities in the EQ binder included applying sealant to the thermocouple housing threads and the housing gaske During a review of the implementation of these instructions, the i inspectors noted that the housing of the WEED thermocouple

No. 2TE-CM058 had been opened but that appropriate maintenance i activities had not been performed. The licensee stated that

] sufficient information existed in their files to confirm that these

! maintenance activities did not affect the EQ of the thermocoupl , Based on additional NRC review of the testing of PYC0 thermocouples,

the inspectors accepted the licensee's justification for the EQ of the WEED thermocouple in its installed configuratio t 10 CFR 50.49, Paragraph (j) states that a record of qualification,

including documentation, must be maintained in an auditable form for

the entire period during which the covered item is installed in the

! plant to permit verification that the equipment is qualified for its application and meets its performance requirements during an acciden The licensee was informed that their EQ file on the WEED thermocouple

, was not auditable, in that it did not permit verification that the i thermocouples were qualified in their installed configuration. To

permit verification, a similarity analysis of the testing done on

] the PYC0 thermocouples and its application to the WEED thermocouple

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needed to be inserted in the EQ files. The licensee was informed that enforcement action may be taken in that they failed to maintain an auditable EQ file for the WEED thermocouple past the November 30, 1985 EQ_ deadline. Pending further NRC review, this is considered a Potential Enforceable / Unresolved Item (50-374/87004-03(DRS)). Beta Radiation Accident Analysis During the inspection, the Sandia consultants noted that individual qualification files for various cables did not include an analysis of beta radiation effects on cable performance. The licensee stated that the Class IE equipment installed inside the containment was qualified to accident conditions specified in the FSAR and Qualification Document EQ-LS001. The cccident radiation analysis performed in EQ-LS001 was based on an assumption that all Class IE equipment would be protected by at least 35 mils of material. The analysis concluded that with this protection, the combined gamma plus beta accident dose for the harshest location inside the containment would be 200 Mrd or less. In response to NRC questions, the licensee stated that beta doses in excess of 500 Mrd would be experienced at the center of the drywell. The NRC inspectors determined that without accident protection of a metal enclosure doses in excess of 1000 Mrd would be experienced and that a 35 mil

. cable jacket would not provide adequate protection to the cable to survive these levels of beta radiatio In response to this concern, the licensee stated that cables inside the drywell were installed in conduit or covered cable trays. The NRC inspectors determined that this protection would adequately protect the cables from large accident beta doses. The licensee also stated that drawings and instructions required cables to be in raceways or enclosures and during their inspection of the EQ equipment inside the Unit 2 drywell, the inspectors noted that cables were protected by conduit or covered cable trays. No further concerns were identified.

. General Electric (GE) Heaters EQ File Number EQ-LS018 These heaters are a component part of the MSIV Leakage Control System (MSIV-LCS). The licensee considers these heaters qualified to NUREG-0588, Category II. The file system component evaluation worksheet (SCEW) listed the submergence qualification as "N/A" or not applicable. During the plant walkdown, the heater area (Reactor Building basement) was observed to be vulnerable to flooding from

, large line breaks as several safety systems have piping in the are The licensee provided FSAR references and stated that no flooding would occur in the area of the heater due to an accident within the scope of 10 CFR 50.49. The licensee took corrective action and added references to the EQ file SCEW sheet to address submergence.

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. Rosemount Model 1153 Series B Transmitter, Binder EQ-LS027 The inspectors noted that the EQ file did not properly address the plant acceptance criteria for accuracy, in that the file SCEW sheets listed accuracy as N/A (not applicable). The licensee addressed this concern by demonstrating through calculations and analysis, that the accuracies demonstrated in the test report were adequate for LaSalle. The licensee took immediate corrective action to reference plant specific accuracy requirements on the SCEW sheet, or note appropriate references. No further concerns were identifie RHR Pump Motor, Binder EQ-LS006 The inspectors noted that the EQ Binder LS006 did not properly address the qualification of the RHR pump motor for submergence, in that the SCEW sheet indicated N/A for submergence. The licensee stated that no significant flooding occurs in the cubicle rooms where the RHR pumps are located during an accident. The LaSalle FSAR Amendment 64, March 1984, Section 3.11.1.4.2c states that the flooding threat to any of these areas is not directly connected to the accidents used to establish harsh environmental zones at the plant. No further concerns were identifie Discrepancies in EQ Documentation

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During review of the files, the inspectors identified several minor text errors. Two are identified below:

(1) The Master Equipment List did not include Rosemount Transmitter 2B21-N4020 for Unit 2. The licensee took immediate corrective action and added this transmitter to the Master Lis (2) The Master Equipment List erroneously stated H4 to be the environmental zone for some equipment. The licensee took immediate corrective action and corrected the environmental Zone H4 to H4A on the Master Lis No violations of NRC requirements were identifie . Plant Physical Inspection The NRC inspectors selected over 47 items on the MEL for examination in the plant. The EQ file of each item had been reviewed, and information regarding the location, manufacturer, model/ serial number, mounting, orientation, environment, and interfaces had been noted. The inspectors examined the selected items in the field, as accessible, and verified that the method of installation of each item was not in conflict with its environmental qualificatio Specific areas reviewed included traceability of installed items to EQ files, ambient environmental conditions, qualification of interfaces (connectors, wires, seals,

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insulation, lubricants, etc.), evidence of significant temperature rise from process, drainage, mounting methods, physical conditions and housekeepin In almost all cases, items examined in the field during this walkdown were found to meet their appropriate EQ requirements with the following exception:

During examination of equipment inside the drywell, the inspectors noted that the insulation of one jumper wire in the Limitorque Operator 2WR179 operator housing was cut through to the conducto The licensee stated that this discrepancy may have occurred during the outage maintenance currently in progress at the plant. The licensee took immediate corrective action and replaced the wir No further concerns were identifie . Evaluation of Fyrquel EHC Fluid Spray on Unit 1,10 CFR 50.49 Components On February 4,1987, during the EQ audit, the licensee informed the NRC team of a Fyrquel hydraulic fluid spray in the Unit 1 drywell, which had resulted from a leak in the Recirculation Pump 1B33-00016 lubricant system. As a result of the leak, Unit 1 was brought to cold shutdown on February 6, 1987, for investigatio The licensee performed an evaluation, Calculation No. CQD-035097, dated February 17, 1987, of all 10 CFR 50.49 components located in the area of the leak. Components included cables, Limitorque valve actuators, electrical penetrations, temperature elements, and steam isolation control device In their evaluation, the licensee considered the mechanical construction of the equipment enclosures, compatibility of seals with the Fyrquel fluid, and performed a physical inspection for seepage. The licensee concluded that the Fyrquel fluid had had no effect on the qualification of the 10 CFR 50.49 components evaluated. A clean up effort was completed in the area of the leak, and Unit I was brought back on lin No violations of NRC requirements were identifie . Effect of the LaSalle High Temperature Transient on Equipment Life During the initial fuel cycle for LaSalle Unit 1, higher than expected temperatures were experienced. A less severe temperature transient was also experienced during the initial operation of LaSalle Unit The causes were attributed to poor air flow distribution, unanticipated heat loads, inadequately sealed penetrations, damaged metallic reflective insulation, and various uninsulated heat sources. Modifications made to LaSalle Unit 2 prior to startup reduced the magnitude of its high temperature transient. Field walkdowns following the high temperature transient for LaSalle Unit I noted degraded cables (non-EQ) in the upper portion of the drywell.

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The licensee reviewed equipment in the drywell based on its safety application. This analysis indicated that 10 CFR 50.49 EQ designated cabling was not located in the upper elevations of the drywell where degraded cables had been found. To verify the qualification of EQ cables exposed to the tenperature transient, the licensee removed selected lengths of Class 1E cable from the drywell and performed a "LOCA" qualification test which established the continued operability of the cable A more comprehensive drywell temperature monitoring program was also initiated. The most severe temperature / time combinations were determined based on information from existing temperature monitoring equipment for appropriate EQ equipment. This evaluation indicated that the maximum temperature experienced by the EQ 1E cabling was 202 F (94 C).

LaSalle also performed a thermal aging analysis to demonstrate that the maximum temperature experienced during the temperature excursion was less than that used for accelerated aging during equipment qualification tests, and that the thermal life of EQ equipment and cables consumed by the temperature excursion was small compared to the equipment's total thermal life. This analysis was consistent with NUREG-0588, Category II requirements, and established an acceptable qualified life for EQ cables and equipment reviewed during the audi No violations of NRC requirements were identifie . Open Items Open Items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open Items disclosed during this inspection are discussed in Paragraphs 3 and 4 . Potentially Enforceable / Unresolved Item An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violation. Potentially Enforceable / Unresolved Items are unresolved items which, if ascertained to be a violation, will be followed up with enforcement action in accordance with NRC enforcement guidance on environmental qualification. A Potentially Enforceable / Unresolved Item is discussed in Paragraph S . Exit Interview The Region III inspectors met with the licensee's representatives (denoted under Paragraph 1) during an interim exit on February 6,1987, and discussed findings by phone at the conclusion of the inspection on February 27, 1987. The inspectors summarized the purpose and findings of the inspection and the licensee acknowledged this information. The licensee did not identify any documents / processes reviewed during the inspection as proprietar _ _ _ _ . .- -