IR 05000454/1985037

Safety Insp Repts 50-454/85-37 & 50-455/85-41 on 850820-21 & 1104-1218.No Violation or Deviation Noted.Major Areas Inspected:Organization & Mgt Controls,Exposure Controls & Control of Radioactive Matls

ML20136J363
Person / Time
Site:	Byron
Issue date:	01/07/1986
From:	France G, Grant W, Greger L, Nicholson N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136J359	List: IR 05000454/1985037 ML20136J355
References
50-454-85-37, 50-455-85-41, IEIN-85-042, IEIN-85-043, IEIN-85-42, IEIN-85-43, NUDOCS 8601130345
Download: ML20136J363 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-454/85037(DRSS); 50-455/85041(DRSS)

Docket Nos.- 50-454; 50-455 Licenses No. NPF-37; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690

, Facility Name: Byron Nuclear Power Station, Units 1 and 2 Inspection At: Byron Site,~ Byron, IL Inspection Conducted: August 20-21, 1985 and between November 4 and December 18, 1985 Inspectors:

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N ic h /h/84-Date W. B. G an //7/6Z Date YY G. M. France III (August 21, 1985 only) //7/84 Date

' Approved By: . ger, Chief //7/#G Facilities Radiation Protection

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Date Section Inspection Summary Inspection on August 20-21 1985 and between November 4 and December 18, 1985-(Reports No. 50-454/85037(DRSS); 50-455/85041(DRSS))

Areas Inspected: Routine, unannounced inspection of the radiation protection program including: ' organization and management controls; training and qualifications; exposure controls; control'of radioactive material; solid radwaste; transportation; an allegation concerning health physics practices; licensee action on previous findings; Unit 1 outage planning; a Unit 2 contamination incident; a contaminated resin transfer to non-licensed vendors; status of Unit.2 radiation monitors; and selected IE Information Notices. The inspection involved 176 inspector-hours onsite by two NRC inspector Results: No violations or deviations were identifie ,

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DETAILS 1. Persons Contacted'

R. Aker, Lead Health Physicist, Zion Station F. Hornbeak, Technical Staff Supervisor

• T. Joyce, Assistant Superintendent Technical Services

• J. Langan, Compliance Staff R. Querio, Station Manager D. St Clair, Operating Engineer, Rad Waste L. Sues, Assistant Superintendent, Operations

• J. Van Laere, Radiation-Chemistry Supervisor

• R. Ward, Services Superintendent K. Weaver, Station Health Physicist

• J. Hinds, NRC Senior Resident Inspector W. Forney, NRC Reactor Projects Section Chief

• Denotes those attending the exit meetin The inspectors also contacted members of the operating, rad / chem, technical, mechanical maintenance, electrical maintenance, training, security, and engineering staffs during this inspectio . General This inspection, which began at 10:00 a.m. on August 20, 1985, was conducted to examine the routine radiation protection, radwaste, and transportation of radioactive material activities; maintenance outage activities for Unit 1; interface between rad-chem and other station organizations; the results of increased management involvement in the radiological control program; and the preoperational status of Unit . Licensee Action on Previous Inspection Findings (Closed) Open Item (454/85014-01; 455/85009-01). Technical Specifications training for RCT The licensee has developed appropriate training which will be offered during the first quarter 1986, as part of the RCT qualification progra (Closed) Open Item (454/85014-02; 455/85009-02): Review neutron dose rates in accordance with the FSAR. A review of.Startup Test 2.61.33 indicated neutron readings at 90-100% power levels exceeded FSAR value To reduce the neutron fields, the nozzle cover plates were lowered flush with the cavity floor during this outage. A licensee Action Item Record No. 6-85-277 has been submitted to conduct surveys at the 90-100% power levels to determine the effect of this new shielding configuratio (Closed) Open Item (454/85014-03; 455/85009-03): Incorporate package receipt instructions for radioactive materials into administrative procedure Instructions have been included in BAP 800-15, Receipt

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Verification Checklist, for storeroom personnel to contact the Rad / Chem Department upon receipt of radioactive labelled packages and retain all shipping papers with the package until Rad /Che'n representatives have completed the required inspectio . Management As a followup to the weaknesses identified during the previous inspection (50-454/85022; 50-455/85020), the inspectors concentrated on the-implementation of the radiation controls program (RCP). This inspection included a review of management involvement and program support; effectiveness of the Rad / Chem Department in implementing this program; and worker adherence to radiation protection procedures and good health physics practices. In general, programmatic improvements were observed by the inspectors and noted in discussions with onsite personnel as addressed belo These improvements reflected increased worker experience levels, worker initiative, and the impact of the Radiation Awareness program. Radiation Awareness sessions were conducted by upper plant management, rad / chem, and training personnel for all CECO site personnel and contractor supervisory personnel to promote worker support for the

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RC These sessions reemphasized good health physics techniques addressed i

in NGET training and the worker's requirement to adhere to radiation protection procedures and RWP provision Upper management's participation conveyed its support for the RCP and the necessity for individuals to adhere to radiation protection criteri The licensee plans to expand these sessions to include contractor personnel als To determine the perception of the RCP among workers, the inspectors interviewed members of the operating, mechanical maintenance, electrical maintenance, contract health physics, contract worker, and station rad / chem staffs at working and supervisory levels. The consensus was that strong management backing has had a positive impact on worker support of the RCP and the Rad / Chem Department's performanc Based on these discussions, it appears that a good working rapport exists between the Rad / Chem Department and other departments and that workers are using good health physics practices. The inspectors' observations confirmed the workers' comments. Additionally the inspectors noted: (1) increased worker inquisitiveness regarding radiological parameters associated with jobs; (2) RCT attentiveness to workers' inquiries and responses; (3) good frisking techniques; and (4) improved communication and interfaces between departments and the rad / chem staff. The inspectors also noted that the addition of contract radiation protection technicians during the current maintenance outage has had a positive effect by easing the workload pressure and also by providing valuable operational experience for.the licensee RCT staff. In general, it appears that the combination of increased operating experience and increased management support has had a significant impact on the effectiveness of the radiation protection program and its support by the plant workers. In discussions with upper plant management representatives, the inspectors stressed the need to maintain the current level of management backin The recent CECO reorganization resulted in insertion of two manager /

supervisors between the Rad / Chem Supervisor (RPM) and the Station Manage _ _ _ _ - _ _ _ . _ _ .

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Based on discussions with the Station Manager and RPM, it appears that direct access remains available and direct communication between the station manager and RPM occurs whenever either person considers it necessary,

! although routine meetings are not regularly scheduled.

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L The inspectors reviewed the licensee's audit program. A comprehensive I

audit of the radiation protection program was conducted by the corporate i office July 15-19, 1985. A station Radiation Protection Task Force was established to implement approximately forty corrective actions generated from the audit. Approximately thirty-nine corrective actions had been implemented and considered closed by December 5, 1985. Two audits of the rad / chem and radwaste programs were condsted in 1985 by the onsite QA department. Corrective action was taken on two minor finding No problems were note No violations or deviations were identifie . Training and Qualifications The inspector reviewed radiological systems training conducted by the station training department for the Rad / Chem staff. This training Las developed in response to weaknesses identified during the previous inspection, specifically, the RCT's inexperience with reactor system This session provides an overview of eleven reactor systems, addressing system function, design and radiological hazards associated with systems operation. Lesson plans were reviewed; no problems were noted. All currently qualified RCTs have completed this day-long session according to licensee records reviewed. The reactor systems training is included in the RCT certification program for incoming RCTs, but not in the continuing training sessions for RCTs. Based on RCT experience level, licensee representatives acknowledged a need for retraining in this area and agreed to include systems training in continuing RCT training sessions (0 pen Item 50-454/85037-01; 50-455/85041-01).

The inspector reviewed the resumes of the contract radiation protection personnel: 17 senior technicians, 20 junior technicians, four control point clerks and an onsite coordinator. The senior technicians appear to meet or exceed the technician selection criteria in ANSI 3.1 - 1978, and have extensive operational nuclear plant experience. The junior technicians and control point clerks appear to have training and experience commensurate with their assigned responsibilities.

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In addition to the contract technicians, the licensee has augmented the radiation protection staff with five contract health physicists (HPs).

The function of the contract HPs is to provide feedback and advice on HP practices and implementation. The inspector reviewed the contract HPs'

resumes; they have extensive operational nuclear plant experience and are adequately qualifle A contractor (Hunter) supplies about 34 people who are committed to decontamination and general cleanup of plant areas. The decontamination activities are currently conducted under the supervision of the contract radiation protection technicians. Most plant areas appeared remarkably clean for a plant in a maintenance outag L

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-No violations or deviations were identified.

>a 6 ~. ! Exposure Controls

- a .- External Controls

The-inspectors reviewed the' licensee's external exposure control and

_ _ personal dosimetry programs, including: administrative-measures for controlling access and stay times in radiation. areas during normal

.and emergency operations; adequacy of-dosimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs; and experience concerning_self-identification and correction of program implementation weaknesse The inspector reviewed exposure results for the third and fourth quarter 1985, through November.24, 1985; no exposures exceeding NRC

< limits were identified._ Approximately 3700 individuals are currently

whole body badged with additional extremity and multiple badgin The: licensee has reduced the number of people. requiring film badges s

from a high of 4300. This-reduction effort is continuing. The total-dose for 1985 through October was about 44 person-rem. This period includes a short maintenance outage in July and the current maintenance outage which began October 2 HPs review daily = exposure: updates to identify individuals approaching their limit, and contact the appropriate work supervisor and access control personnel when limits are' approached. Updates are maintained at access control. No problems were noted.-

No violations or deviations were note Internal Dosimetry Whole body count (WBC) results from June'to October were reviewe No results approaching the 40 MPC-hour _ evaluation level were note Bi-weekly reports generated by the contractor are reviewed by a health physicist to assure anomalous results and results exceeding the licensee's investigation. level are identifie Calibration of the standup NaI' scintillation counter indicated no problems, nor have daily check _ source readings (Co-60 and Co-137) identified instrument drift or abnormalities. Random tritium bioassay results were reviewe Results were comparable; no intakes approaching MPBB were note The WBC computer program converts Maximum Permissible Body Burdens (MPBB) to MPC-hours when the prescribed licensee's investigation level.(3% MPBB for one isotope; 5% MPBB total) is reached. However,.

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this conversion'is not proceduralized in the BRP's-nor in informal procedures used by the HP staf A consultant is available for consultation if the computer fails. To determine compliance with 10 CFR 20.103, licensee representatives must be able to make the conversion. Licensee representatives agreed to proceduralize this methodology (0 pen Item 50-454/85022-09; 50-455/85020-01).

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.The? inspectors reviewed the respiratory protection program

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including:- mask fit test records, medical qualification; type L '

and availability of respiratory protection equipment, and the respiratory' protection equipment cleaning and issue facilit The respiratory protection equipment cleaning and issue facility is l- located on the.426' elevation, in the. auxiliary building. The room

, ' appeared well equipped for cleaning and issuing respiratory protection equipment. Supplies of-masks,' filters, hoses and spare parts appeared

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to-be adequate. The. inspector observed respirators being issued to

ensure.that procedures for verification of medical qualifications and mask fit test were followed. The RCT on duty knew the requirements ifor issuing respirators and was familiar with the operation of the respirator cleaning facilit The RCT stated that the practice of-the worker leaving his NGET card as collateral when issued a-respirator has been working well. No problems were noted. No violations or deviations were identifie ;7.- Control-of Radioactive Materials and Contamination, Surveys, and Monitoring I The' inspectors reviewed the licensee's program for control of radioactive

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materials and contamination' including: provisions for calibration,

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performance checks and setting alarm points for radiation monitors, availability,of portable survey, sampling and contamination monitoring

, instruments; adequacy:of procedures-for calibration and use of survey and I sampling instruments; effectiveness of methods of control of radioactive

, and contaminated materials; and management techniques used-to implement l- the program and correct program weaknesse .The inspectors witnessed the preparation for the gasket replacement on

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the Unit 1A. letdown heat exchanger.- The gasket replacement involved work in a high radiation area, a relatively high contamination area, and a potentially high airborne area. Preparations included building a HEPA filtered exhausted tent enclosure with step-off pads and a frisker statio Adequate supplies of protective clothing and respiratory protection were L

provided as required by the RWP. No problems were note The inspectors reviewed records of routine and special radiation and contamination surveys conducted during the outage. All surveys, routine

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and special, are reviewed by an HP_ foreman for completeness and any unusual conditions. Except as'noted in Section 14, no problems were identified.

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Supplies of protective clothing appeared to be adequate for the maintenance activities in progress. The laundry facilities did not appear to have large backlogs of soiled protective clothing. If shortages I occur at any time, additional supplies can be drawn from the stockroom /

warehous No problems were note The inspectors selectively reviewed survey instrument calibration

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records. Instruments appeared to be calibrated in accordance with L . procedures. Calibration ranges reflected applicable ranges encountered

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h5 in the fiel Responses were within tolerance level A computer-tracking system is used to identify upcoming calibration date No problems were note No violations or deviations were identified.

P Solid Radwaste The inspectors-reviewed the licensee's solid radioactive waste management program, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality assurance programs; adequacy of required records, reports, and notifications; experience concerning identification and correction of .

programmatic weaknesse i The licensee uses a contracted mobile solidification service for the ,

packaging of spent resins as radwaste. All other solid dry active waste

'(DAW) is sorted in a HEPA filtered hood, and designated as compressible, noncompressible, combustible, noncombustible, or wet wast The combustible material, which must contain no vinyls, is set aside for volume reduction (VR) when that system becomes operational. According to the licensee about 200 55 gallon drums of combustible DAW are in storage for V The wet DAW is dried and stored for VR if it is combustibl Noncombustibles and noncompressibles are packaged and shipped to a licensed burial sit The inspectors observed limited startup testing of the volume reduction system; however, mechanical problems forced postponement of the test to after the inspection was complete The inspectors observed a DAW shipment of 32 drums and six LSA boxes on November 6, 1985. Licensee surveys were conducted in accordance with applicable procedures. No problems were identified with the shipping papers. Vehicle posting and radiation readings were in accordance with NRC regulation No violations or deviations were identifie . Transportation of Radioactive Materials The inspectors reviewed the licensee's transportation of radioactive materials program, including determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience covering identification and correction of programmatic weaknesse Records of radioactive material shipments made during 1985 to date were reviewe During this period 17 shipments were made including nine

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shipments of spent resins and DAW to licensed burial sites. No problems with shipment documentation, quality assurance or procedures were identifie No violations or deviations were identifie . Radiation Occurrence Reports (RORs)

R0Rs are written for violations 10 CFR 20, Ceco Radiation Protection Standards or Byron Radiation Protection Procedures. Thirty-eight RORs have been written at the station for 1985, through November. RORs were reviewed for significance, corrective actions, and timeliness of corrective actions. The reports appeared to have adequate and timely corrective action. Disciplinary action was taken on two occasions. RORs are trended and a report is submitted to management on a monthly basi The inspectors reviewed ROR 85-38 regarding an electrician who was burned

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on the hands by an electrical source and exited the Unit 2 restricted i area without performing a hand and shoe frisk and without informing rad / chem that she was injured. The electrician exited the station through the guard house portal monitor and was taken to a Rockford hospital. When the rad / chem foreman was later notified, he dispatched an RCT to the hospital to survey the electricia The foreman also called the Station Health Physicist (HP) at home (Rockford) and requested he provide assistanc at the hospital. The station HP and the RCT both reported no detectable levels of contamination on the electrician. Station management is still investigating the incident. The electrician was assisted from the station and driven to the hospital by other station workers who should have known the procedure for frisking and notification of rad / chem. This will be reviewed during a future inspection. (0 pen Item 50-455/85041-02).

ROR-85-35 was written on September 5, 1985, after it was discovered that the Unit 1 containment had been above MPC for noble gases for about eight day A daily containment air sample is taken prior to allowing operator entry. Respiratory protection was not required at the levels foun However, the concern was the length of time between the initial high sample and the HPs understanding of the possible problem. Licensee corrective action was to issue a rad / chem memo dictating an improved method for reviewing sample results. Discussions of the memo and its importance were held with all HPs and with the HP foremen. A spot check of the air sample Jata sheets throughout the inspection showed the air sample data is reviewed by a chemist and an HP on a timely basi No violations or deviations were identifie One open item was established for future revie . Personal Contamination Reports Personal contamination reports were selectively reviewed. Ninety-six reports have been written from January 1 through November 10, 198 Corrective action appeared to be appropriate and timely. A frequent cause of personal contamination is drain backup. Rad / Chem representatives

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estimate approximately 75% of all problems the department encounters are related to floor drains. Station management has assigned a high priority to cleaning the drains and installing loop seals where warranted. The effect of these measures on contamination control will be monitored during future inspection No violations or deviations were identifie . (Closed) Allegation (RIII-85-A-0188)

The inspectors reviewed allegations submitted on November 5, 1985, concerning the licensee's health physics practice The results of the review are presented belo Allegation The alleger stated that scrap steel from inside Unit 1 was being transported in uncovered containers and stored inside a " roped off area" in the Unit 2 Fuel Handling Building, and that employees in the area had not had NGET training and were not issued film badges. According to the alleger, employees could get contaminated from the scrap steel and exit the site through the unmonitored construction gat Discussion The scrap steel from Unit 1 was contaminated with low level fixed activit Since the contamination was not " removable", it did not pose a contamination hazard to workers, nor were the direct radiation levels high enough to require " Radiation Area" posting. It was stored in a roped off area normally used for the short term storage of bags of used protective clothing prior to placing them inside the Hydro Nuclear laundry traile The roped off area and the trailer which have since been removed, were properly posted with " Caution Radioactive Material" and " Authorized Personnel Only, RWP Needed for Entry", signs. According to the licensee the steel was stored in the roped off area, under the direct surveillance of a security guard, for only a few days and then it was moved to a locked caged area on the mezzanine level of the Fuel Handling Building. Since the Unit 2 Fuel Handling Building was an unrestricted area and access to the radioactive material was controlled by rope, signs, and a security guard, NGET training of workers frequenting the Unit 2 Fuel Handling Buildings was not require While the alleger was correct in his assertions concerning the transporta-tion and storage of contaminated scrap steel in the Unit 2 Fuel Handing Building, the allegation that workers could get contaminated from the steel was not substantiate Allegation The alleger was concerned that bags of radioactive waste reading 10 to 30 mr/hr were moved through the construction portal, 401' elevation, between the turbine building and the auxiliary building, while workers were also using the portal for exit. The alleger thought the bags might rupture and contaminate people nearb ,

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Discussion According to the licensee, plastic bags of radioactive waste and contaminated clothing were transported through the construction portal, on the 401' '

elevation, in the early days of operation.. However, for the past several months, all transfers of radioactive material through this access point have been made in fully enclosed cart Although there may have been a remote possibility of contamination being. spread by rupture of the plastic bags, the use of plastic bags is not contrary to regulatory requirements. Nevertheless, this practice has been eliminated by the licensee. No radiation safety concerns or regulatory problems were identified since all persons frequenting the area are required to have NGET training and must pass through a portal monitor or a frisking station prior to leaving the sit Allegation The alleger stated that radioactive spills had occurred inside the turbine building and that it was possible to spread contamination because there was no monitoring at the turbine building porta Discussion The licensee has:a routine program for surveying the turbine buildin If areas of contamination are found they are either decontaminated or roped off and posted. The inspectors observed one such area in the turbine building. All persons frequenting the turbine building are required to have NGET training. All persons exiting the turbine building must either pass through a frisking station or exit through the guard house portal monitor r The licensee's efforts to identify and control possible contaminated ;

areas in the turbine building combined with frisker stations and portal monitors for contamination detection was found to be an acceptable method for control of potential contamination in this area. The allegation was not substantiate . Outage Planning The inspectors also reviewed the licensee's outage planning and preparation activitie The following measures were take ;

• The number of onsite contractor HP technicians for outage coverage was almost double Before job assignments, these technicians spent :

one week in training on station radiation protection procedure * General areas of containment were decontaminated immediately after shutdown, before job activities commenced.-  !

• -The Rad / Chem Department was represented at outage planning session ,

A rad / chem outage coordinator was assigned to review RWPs and outage activitie _ _ _ _ _ _ _ - _ - _ _ .

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• The lead RCT foreman reemphasized the importance of good health physics practices and RWP conformance at station departmental meetings before the outag * Additional respiratory protection equipment and anti contamination clothing were ordered. Additional laundry support was contracted for the outag i No violations or deviations were identifie . Unit 2 Contamination On November 19, 1985, the licensee identified a contamination and radiation area in a portion of the Unit 2 auxiliary building which is not radiologically controlled. This contamination was identified during a routine survey. The OC radwaste evaporator filter skids in the electrical penetration area of the 414' level had smearable contamination levels of 2,500 dpm/100cm2 and a maximum direct contact reading of 20 mR/h Contamination and direct levels were primarily confined to the filters, not the general areas of the room. The licensee took the following access / contamination control measures: (1) the area was secured and properly posted; (2) a posted security guard restricted access to NGET trained individuals with appropriate dosimetry; (3) a step-off pad and frisker were set up at the room's only access point such that all individuals must monitor themselves before exiting; (4) the contaminated OC evaporator filters were changed and the area decontaminate Investigative surveys of Unit 2 tool cribs and general areas did not j indicate contamination migration to other uncontrolled areas. According l

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to a listing of licensee work requests, no specific work was conducted on the OC radwaste filters. Licensee representatives stated the RCT noted slightly elevated readings around the filters during the previous week's i routine survey and alerted the RCT foreman. No action was taken at that time because the foreman did not recognize that the electrical penetration

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area was in the unprotected area. Rad / Chem management discussed this matter individually with the involved foreman and collectively with the other foremen and RCTs, emphasizing the need to recognize unusual radiological f conditions in any area and especially in the unprotected are To prevent future occurrences, the licensee and contractors made an evaluation of other Unit 2 areas to determihe the potential for contamination occurrences. An expanded routine survey program of areas with the above potential has been implemented. A memo from the Rad / Chem Supervisor instructs startup testing personnel to notify the Rad / Chem Department of any test or work activities with crossover systems that may introduce contamination potential. This will be reviewed in future inspections (0 pen Item 50-455/85041-02).

No violations or deviations were identifie . Resin Transfer The licensee notified the NRC on August 15, 1985, that low level contami-nated resins had been transferred to two non-licensed vendors via an 11 ..

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unmonitored release pathway. These resins were shipped offsite to be regenerated. In both cases the following actions were taken and findings verified: (1) licensee and NRC representatives were dispatched to the vendor facilities; (2) representative samples collected by both NRC and licensee representatives indicated resin concentrations were less than

those specified by 10 CFR 20, Appendix B, for liquid release to unrestricted areas; (3) resins and associated sludge were returned to the Byron site; and (4) no detectable contamination remained at the two vendor facilitie The first case involved slightly contaminated Unit 2 flushing demineralizer resins that were identified during a non-routine survey of a resin filte No contamination source has been identifie The licensee discontinued shipment of Unit 2 flushing resins until October 2, 198 Since then, seven shipments have been made under a surveillance program that requires representative sampling and isotopic analysis of resins before shipment; resin with detectable contamination remains onsite. The inspector verified these levels by record review of resin samples. A gross cleanup system is onsite to reduce contamination levels of resin before transfer to the vendo The second case involved Unit 1 condensate polished demineralizer resins (secondary side) that were identified during an expanded licensee monitoring program as followup to the Unit 2 resin discovery. Again, no contamination source was identified. Some resin had been processed by the vendor; however the waste water released to the sanitary sewer would have been less than 10 CFR 20 limits for unrestricted releases and did not pose a public health or safety problem. The licensee no longer regenerates these resins; instead upon resin exhaustion, they are shipped out as radwast No violations or deviations were identifie . Unit 2 Preoperations The inspectors reviewed the status of radiation monitors exclusive to Unit 2 operations. According to licensee representatives, parts are currently on order for most Unit 2 monitors to replace parts needed to repair Unit 1 monitors. No preoperational testing has been conducte Common radiation protection facilities, procedures, and staff serve both units. These topics have been previously reviewed in conjunction with Unit 1 preoperational inspectio No violations or deviations were identifie . I&E Information Notices The inspectors reviewed licensee responses to the following selected l

I&E Information Notices:

• I&E Notice 85-42: Loose Phosphor in Panasonic 800 Series TLD The licensee has procedures for visual inspection of Panasonic l

UD 802 badges when incorporated into the dosimetry progra All i

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badges failing the station's acceptance criteria will be returned to the vendo (Byron Letter 85-1116).

• I&E Notice 85-43: Radiography Events at Power Reactor No licensee procedures specifically address radiography activitie Contract radiographers must comply with station radiation protectivn procedure (Byron Letter 85-1152).

No violations or deviations were identifie . Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on December 5, 1985. The scope and findings of the inspection were summarized. Tiic inspectors also discussed the likely information content of the inspection repcrt. with regard to documents and processes reviewed during the inspection. The licensee identified no such documents / processes as proprietary. In response to certain items discussed by the inspectors the license: Acknowledged the inspectors comments concerning the positive effects of strong management support of the radiation protection program and the need to continue that suppor Agreed to include systems training in the continuing RCT training sessions (Section 5). Will continue to review ROR 85-35 and evaluate potential for contamination in the uncontrolled area (Sections 10 and 14).

1 Monthly NRC Briefing At the December 18, 1985 monthly NRC briefing, the licensee summarized the status of their program for improving the plants' radiation protection performance. A licensee task force has been established to respond to recommendations for radiation protection improvements from a corporate (CECO) assessment performed in July 1985 in response to previously documented NRC findings, and an INP0 evaluation performed in August 1985. Thirty-nine of the forty recommendations from the corporate assessment were reported to have been completed; three of the seven INP0 findings were reported to have been completed. Three of the eight additional action items generated by the task force itself were reported to have been completed. Licensee efforts to complete the remaining items were reported to be continuing, with most remaining items due for completion in early 198 The licensee's efforts to identify and correct radiation protection program weaknesses is commendable; these efforts appear reflective of significant improvement in management support for the radiation protection progra Additional items discussed in the December 18, 1985 monthly NRC briefing, including meeting attendees, are documented in NRC Inspection Report No. 50-454/85053(DRP),

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