IR 05000277/1985011

Board Notification 85-070:forwards Enforcement Action Notification Resulting from Insp Repts 50-277/85-11 & 50-352/85-12 Re Radiation Protection at Peach Bottom & Security at Limerick

ML20132B291
Person / Time
Site:	Peach Bottom, Limerick, 05000000
Issue date:	07/22/1985
From:	Novak T Office of Nuclear Reactor Regulation
To:	Edles G, Gotchy R, Kohl C NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
TASK-AS, TASK-BN85-070, TASK-BN85-70 BN-85-070, BN-85-70, EA-85-042, EA-85-42, NUDOCS 8507240247
Download: ML20132B291 (2)

Text

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Docket fios.: 50-352 50-363 MEMORANDUM FOR: The Atomic Safety and Licensing Appeal Bcard for Limerick Christinc U. Kohl, Chairman ' Gary J. Edles Dr. Reginald L. Gotchy , i FR0fi: Thomas M. Novak, Assistant Director for Licensing l Division of Licensing SUBJECT: BOARD NOTIFICATION N0. 85- 070 (LIMERICK SECURITY PROGRAH) In accordance with llRC Proceoures for Board Notification copies of an Enforcement Action resulting from NRC Inspection Reports Nos. 50-277/85-11 and 50-352/85-12 are being provided to the Linerick Board. Although the specific actions identificd in the single Enforcement Action letter to the licensee (PECO) involve dif ferent prograns at two sites (radiation protection at Peach Bottcm, and security at Limerick) the fundamental NRC concern is the san,e in each case; namely, inadequate management control by the licensee of licensed activities performed by contractors. Therefore, the complete package, which addresses both the Peach Bottom issue and the Linerick issue, is provided for the Limerick Board's informatio The matters discussed in the Enforccrient Action relate to the staff's concern relative to PEC0's involvement in the control of contractor performance. Specifically, Inspection Report No. 50-277/85-11 describes deficiencies identified in PEC0's control of contractors responsible for providing health physics coverage and perfonning work activities during an extenced refueling outage for recirculation systen and residual heat removal system pipe replacements at Peach Bottom, Unit 2. Inspection Report No. 50-352/85-12 addresses deficiencies in PEC0's control of licensed activities performed by the contractor guard force at Limeric In a related matter, an Office of Investigations Report (01) No. 1-84-025 addresses apparent falsification of training documents by contract security officers at Limerick. The findings in this 01 Report similarly dcnonstrate that PECO has not adequately monitored the perfonr.ance of their contractor ,..

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The 01 Report has been referred tc the Department of Justice (D0J) for prosecutcrial review. Since the 000 has ir.dicated that it views the 01 Report as a working docurcr t bett.een DCJ and the I4RC the report is not enclesed with this Board liotificatio These issues are being thoroughly reviewed by IE and Region I to deterni sigr.ificance in tems of impact en plant saf ety. These presently active issues should not impact or, the cuc.pletion of the Region I inspection prccrar k Thomas M. Novak, Assistar.t Cirector for Licensing Division of Licensing Enclosure: Letter T. E.1 urley, hkC, to V. Boyer, PECO,140tice of Violation and Proposed Irpcsition of Civil Penalties dated May 30, 156 cc: ACRS (10) ED0 See next page Parties to the Proceeding

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MAY 301955 Docket No ' License Nos. OPR-44 NPF-27 EA 85-42 Philadelphia Electric Company ATTN: Mr. V. Boyer Senior Vice President Nuclear Power 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen: Subjects: Notice of Violation and Proposed Imposition of Civil Penalties / Peach Bottom (NRC Inspection No. 50-277/85-11) Notice of Violation and Proposed Imposition of Civil Penalties / Limerick (NRC Inspection No. 50-352/85-12) During recent inspections conducted in February,1985 at the Peach Bottom Atomic Power Station and the Limerick Generating Station, violations of NRC requirements were identified involving inadequate performance of licensed activities by contractor employees. The violations raise serious questions regarding the adequacy of management oversight provided by Philadelphia Electric Company (PECo) to monitor and control the performance of contractors engaged in licensed activities at your nuclear power plant .. The first inspection was conducted at Peach Bottom Unit 2 on February 13-15, _ 1985 during an extended refueling outage for Recirculatien Systen and Residual Heat Removal System pipe replacement. The inspection wt: condu ed to review radiological concerns involving two related radiologica' 'ncider . in which contractor employees were contaminated with radice.ctive .:erial and received unplanned occupational radiation exposures. Alth sgh tN exposures were determined not to be in excess of regulatory limits, a potential for such exposures existed. These personnel exposures may have been prevented had licensee management provided an effective administrative radiological control system to ensure that personnel responsible for providing radiological controls were made aware of the scope of the maintenance activitie PECo's management oversight of the radiological activities was inadequate in that deficiencies in contractor planning, supervision, surveillance, communications. radiological controls, and training were not identified prior to the first incidert, nor corrected in time to prevent the second inciden In addition, a licensee supervisor approved the Radiation Work Permit which did not adequately control the radiological hazards associated with either inciden CERTIFIED MAIL ACTURN RROM REQUESTED mlg .

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Philadelphia Electric Company -2- NAY 3 0 285 Itese deficiencies were discussed at an enforcement conference with Mr. J. Cooney a'id other members of the PEco staf f on March 4,1985. The specific violations

:ssociated with these incidents are documented in an irspe: tion report sent to your staf f on February 27,19SS, and are described in Appendix The second inspection was conducted at Limerick on February 4-8 and 13, 1985, during which five violations of NRC physical protection requirements were identified. The results of the inspG tion were discussed with you and other members of the pEco staff during an enforcement conference held on March 11, 1985. Tne violations, which were decumented in an inspe: tion report sent to your staff on March 4, 1985 and which are described in Appendix B, represent a significant degradation in the security program at the Limerick site. PECo's management oversight of these activities was inadequate in that deficiencies in contractor guard force personnel training, supervision, communication, and performance were not promptly identified, allowing adverse conditions to exist for several days without implementation of required contingency measures, notifications and corrective action In addition to our discussions of the security violations at Limerick during the enforcement conference on March II, 1985, we also discussed our concerns which developed as a result of the NRC's investigation of alleged guard force training records falsification by contractor employees in 1984. This issue was discussed with your staff at the enforcement conference to reinforce our concern that PECo has not provided adequate oversight of the Limerick guard force contractor and to obtain assurance that corrective actions for known problems are promptly initiated. This matter may be the subject of further enforcement action in the futur * These violations and those at the Peach Bottom facility demonstrate that inadequate oversight and control of contractor activities is not limited to the particular facility management, but also involves corporate management. Further, the violations at Limerick represent the second instance in a year of PEco's inadequate control of contractor guard force activities. On October 25, 1984, a Notice of Violation was issued for several violations of physical protection requirements by the contractor guard force at the Peach Bottom Atomic Power Station. On previous occasions, the NRC has expressed concern regarding the adequacy of your control of contractors. For example, in the Systematic Assessment of Licensee Performance (SALP) Report for Peach Bottom covering the period March 1, 1983 through December 31, 1983, the NRC described several incidents which indicated the need for improvement in control of contractor In your March 27, 1984 response to the SALP Report, you acknowledged the need for additional overview of contractor work, and you indicated that certain actions were taken to improve performance in this area. The recent events at Peach Bottom and Limerick indicate that your actions ap;arently were not effective in improving management eve * sight of contra:t: performanc .
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   -3- MAY 3 01985 lo emphasize the need for increased PECo management oversight and control of contractor performance of licensed activities I have been authorized, after consultation with the Director, Office of Inspection ard Enforcement, to issue the enclosed Notices of Violation and Proposed Impositions of Civil Penalties in the cumulative amount of Seventy-Five Thousand Dallars ($75,000) for the violations set forth in Appendices A and B. In each case, the violations have been categorized in the aggregate as Severity Level III problems in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1985). The base civil penalty for a Severity Level Ill violation or problem is 550,000. As set forth in Appendix A, the penalties associated with the health physics violations at the Peach Bottom facility have been reduced by 50*, because of your comprehensive corrective action However, as set forth in Appendix B, the penalties associated with the security violations at Limerick do not warrant mitigatio You are required to respond to this letter and should follow the instructions specified in the enclosed Notices when preparing your response. In addition, to enable NRC to determine what actions, if any, should be taken with respect to your license, you are required to submit within 30 days, under the provisions of 10 CFR 50.54(f), a report of your investigation of the incidents of Limerick guard force training records falsification; an explanation of whether these incidents occurred without PECo knowledge, and if so how; a determination of the causes of the falsification, including the responsible individuals; and a description of the actions taken or planned to prevent recurrence of similar incidents. Your written reply to this letter and the results of future inspections will be considered in determining whether further enforcement action is appropriat Sections of Appendix B contain details of your security program that have been determined to be exempt from public disclosure in accordance with either 10 CFR 73.21 (Safeguards Information) or 10 CFR 9.5(a)(4) (Commercial or Financial Information). Therefore, the sections so identified will not be placed in the NRC Public Document Room and will receive limited distribution. In your response to this letter and Appendix B, place all Safeguards Information and Commercial or Financial Information in a separate enclosure so that your letter may be placed in the Public Document Roo The response directed by this letter and the enclosed Notices are not subject to the clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely - Thomas E. Mu iey Regional Admin .. or

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Philadelphia Electric Company -4- SM30B% Enclosures: Appendix A (Notice of Violation and Proposed Imposition of Civil penalties - Peach Bottom) Appendix B (Notice of Violation and Proposed Imposition of Civil Penalties - Limerick) (Contains Safeguards, Commercial or Financial Information) cc w/encls (w/o Safeguards, Commercial or Financial Information): R. S. Fleischmann, Station Superintendent, Peach Bottom Shields Daltroff, Vice President, Electric Production Raymond L. Hovis, Esquire Thomas Magette, Power Plant Siting, Nuclear Evaluations John S. Kemper, Vice President, Engineering and Research G. Leitch, Station Superintendent, Limerick Troy B. Conner, Jr., Esquire (w/ entire Appendix B) Eugene J. Bradley, Esquire, Assistant General Counsel ' Limerick Hearing Service List NRC Resident Inspector / Peach Bottom (including entire Appendix B) NRC Resident Inspector / Limerick (including entire Appendix B) Commonwealth of Pennsylvania \ ..

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APPENDIX A N011CE OF VIOLATION

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AND PROPOSED IMPOSITION OF CIVIL PENALTIES Philadelphia Electric Company Docket No. 50-277 Peach Bottom Atomic Power Station License No. DPR-44 Unit 2 . EA 85-42 On February 13-15, 1985, an NRC special safety inspection was conducted to review the circumstances associated with two incidents involving radioactive , contamination of contractor employees performing work on weld joints inside a valve and associated piping in the drywell. Although the contamination levels and associated radiation exposures were not in excess of the regulatory limits, a substantial potential for such exposures did exis In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985) and pursuant to Section

* 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C., 2282, PL 96-295 and 10 CFR 2.205, the violations and the associated civil penalties are
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set forth below: ' Technical Specification 6.11 requires adherence to radiation protection procedures for all operations involving personnel radiation exposure.

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 , Radiation protection procedure HP0/CO-4, " Radiation Work Permits,"
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 . performed in high radiation area Cnntrary to the above, on Fe'bruary 10, 1985, work was performed on the interior of valve 81A in the Residual Heat Removal System, a high radiation area, and' Radiation Work Permit No. 02-10-5008, " Fit and Weld RHR' Pipe and Valves," did not provide specific requirements for radiological exposure control for work performed inside the valv ' ALARA Program Instruction 2, a radiation protection procedure, requires, in part, that radiological controls personnel ensure that workers are aware of the radiological status (radiation, contamination and airborne radioactivity levels) of the work are Contrary to the above, on February 3 and 10,1985, at least 7 workers performed inspection, welding, grinding and other activities on weld

joint 206 while inside valve 81A or adjacent piping, and radiological ! controls personnel did not ensure that these worbers were aware of the radiological status of that area. This cccurred because the radiological controls personnel were not aware of the radiological l status within the valve or adjacent piping until after the completion of the work activitie ? -n i m yr '> r U 2spzovr w" ffrb

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Appendix A -

   -2- Radiation protection procedure HP0/CO-100, " Health Physics Guide Used in the Control of Exposure to Radioactive Material," requires, in part, that individuals wear a filter respirator if removable contamination levels are greater than 15 mrad /hr per square foo Contrary to the above, on February 10, 1985, a worker inserted his head and torso into valve 81A where removable contamination levels up to 24,000 mrad /hr per square foot were present, and the worker was not wearing a filter respirato Technical Specification 6.13 requires, in part, that personnel be made knowledgeable of predetermined dose rate levels if an audible-alarming dosimeter is used to provide primary radiological exposure control during entries into high radiation area Contrary to the above, on February 3 and 10, 1985, audible alarming dost-meters were used to provide primary radiological exposure control during entries into valve 81A, a high radiation area. The dose rates were not established until the completion of the work activities and thus workers were not made knowledgeable of the dose rates prior to their work activitie CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in 10 CFR Part 20, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be presen CFR 20.201(a) defines a survey as an evaluation of the radiation hazards incident, among other things, to the presence of
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radioactive materials under a specific set of condition _ Contrary to the above, on February 3 and 10, 1985, repeated entries were made by workers into valve 81A to complete work on weld joint 206 and, prior to the entries, an evaluation was not performed of the radiation hazards incident to the presence of radioactive material inside valve 81 CFR 20.103(a)(3) requires, in part, for purposes of determining compliance with that section that the licensee use suitable measurements of the concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted area Contrary to the above, suitable measurements of the concentrations of radioactive materials in air in the valve bonnet of valve BlA were not made during the entries by workers on February 10, 1985. Specifically, the air sample taken fror 0810 to 1415 on February 10, 1985 (1) was not representative of the breathing zones of workers; and (2) it averaged air concentrations during periods of inactivity as well as during grinding and welding operations anc thus did not record peak concentrations potentially present durie; those operation r

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, Appendix A -3-t CFR 20.202(a)(1) requires in part, that tie licensee supply appro-priate personnel monitoring equipment to and require the use of the equipment by each individual who enters a restricted area under such circumstances that he receives, or is likely to receive a dose in any calendar quarter in excess of 25*. of the applicable value specified in paragraph (a) of 10 CFR 20.101.

l Contrary to the above, appropriate personnel monitoring equipment was not supplied and used during grinding and welding of weld joint 206 on February 10. 19S5 and workers were likely to receive a dose in excess of 25*. of the applicable value specified in paragraph (a) of 10 CFR 2.101, in the following instances:

 (1) Extremity monitoring equipment was not supplied to four workers grinding and welding the weld joint; and (2) Supplemental monitoring equipment was not supplied to monitor exposure to the lens of the eyes of those worker These violations have been categorized in the aggregate as a Severity level III problem (Supplement IV).

(Cumulative Civil Penalties - $25,000 - assessed equally among the violations) Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission,

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Region I, 631 Park Avenue, King of prussia, PA 19406, within 30 days of the date of this Notice, a written statement or explanation, including for each - alleged violation: (1) admission or denial; (2) the reasons for the violation, if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may issue an Order to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be,given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmatio Within the same time as provided for the response required under 10 CFR 2.201, Philadelphia Electric Company may pay the civil penalties by letter addressed to the Director, Office of Inspection and Enforcement, with a check, draf t, or money order payable to the Treasurer of the United States in the arrount of 525,000 or may protest imposition of the civil penalties, in whole or in part, by a written answer addressed to the Director, Office of Inspection and Enfercement. Should Fhiladelphia Ele:tric Company fail to answer within the time specified, the Director, Of fice of Inspe: tion and Enforcement, will issue an Order imposing the civil penalties proposed abov Should Philadelphia i _

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' Appendix A -4-Electric Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violations listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other' reasons why the

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penalties should not be impose In addition to protesting the civil penalties, in whole or in part, such answer may request mitigation of the proposed penaltie In requesting mitigation of the proposed penalties, the five factors contained in Section V(B) of 10 CFR Part 2, Appendix C (1985) sheuld be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately f rom the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate statements or explanations by specific reference (e.g., citing page and paragraph numbers) to avoid repetitio Philadelphia Electric Company's , attention is directed to the other provisions of 10 CFR 2.205, regarding the procedures for imposing a civil penaltie Upon failure to pay any civil penalties due, which have been subsequently ' determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 228 , FOR THE NUCLEAR REGULATORY COMMISSION

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Thomas E. Murley

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Regional Administrator _ Dated at King of Prussia, Pennsylvania this 30" day of May 1985 i s

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,    APPENDIX B
   .N.0ll.CE. O. f V.10t ATION
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PROPOSED IMP 051T10fiOF CIVIL PENA'. TIES Philadelphia Electric Company Docket No. 50-352 Limerick Generating Station License No. NPF 47 Unit 1 EA 85-42 On February 4-8 and 13, 1985, the NRC conducted an inspection of the physical protection program at Limerick. During the inspectior., five violations of NRC requirements were identifie Collectively, the violations indicate inadequate performance by the contractor guard force, including inadequate supervisory response to degraded conditions, and they further demonstrate inadequate man-agement oversight of the guard force by Philadelphia Electric Company (PECo).

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42 U.S.C. 2282, PL 96-295 and 10 CFR 2.205, the violations and the associated civil penalties are set forth below: Il!!S PAfilJ.M A '.ONI AINS S*,5[flNC , I'lyi?:/ l'c :.?if,.:,!3f,pggtlC Di!Cth'jU;.i.110 ;!:!ENiiON ALLY

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I THIS PARAGRAPH CONIAINS 2.790(d) INFORYATION AND IS NOT FOR PUBLIC DISCLOSUTI. I; 13 INIE!*IIO;; ALLY LET EL?.:,"- , f l}.

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l . Appendia B -2-l l U::.e ' t.T.r::." :9NIN;3 snEn'je.a:3

l .'c" . * '".' G NN Fi1R PUBLl; l':.'.r.!~;.W:1.11 l3 INTEN1;0N!llV

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l l Philadelphia Electric Company Limerick Generating Station Physical Security Plan, Chapter 12, dated October 1984 states, in part, " Records and reports , required by 10 CFR 73.71(c) will be generated, maintained and forwarded to the NRC as mandated by the regulations."- 10 CFR 73.7)(c), Reporting of Physical Security Events states, in part, !

 "Each licensee under either a specific or general license shall notify the NRC Operations Center via the Emergency Notification System as soon as possible, and in all cases within one hour, of any event which signifi-cantly threatens or lessens the effectiveness of a physical security system as established by regulations in this chapter, or by the licensee's approved physical security, contingency, and security personnel qualifi-

, cation and training plans, or by both." - Contrary to the above, on February 2,1985, an event occurred which ! significantly lessened the effectiveness of the physical security plan, and as of February 4, 1985, the NRC Operations Center was not notified via

.. the Emergency Notification System of the occurrence.

l CONTAINS 2.790(d) INFOR. INTENTIONALLY LEFT BLANK thereby lessening the effectiveness of the physical security plan, and telephone notification was not made to the NRC Operations Cente l Philadelphia Electric Company Limerick Generating Station Physical Security Plan, Chapter 1, dated August 1984, states, in part, "All commitments con-I tained in... Safeguards Contingency Plan will be in place and fully imple-mented by the date of receipt of the Limerick Generating Station (LGS) l Operating License."

I 7EIS FAF.AGRAPH CO: !AI!;S 2.790(d)

     :::.7RL:1.!I0:: A:;3 IE I;?! FOR Fi":.LIC LISCLDEL'FE. I IS 1;;;;;;;10:: ALLY LE7! ELA _ _ _ _ _ _ _ _ _ _ _ _

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. Appendix B    -3-THIS PARAGRAPH CONTAINS 2.793(d)

INFOR::AT101: A! D IS NOT FOR PUBLIC DISCLOSURE. IT IS l IN!ENTIO :.* LLY LEFI ELA!!X, THIS PARI.CRAPH CONTAINS 2.790(d) INFOR'!). TION AND IS NOT FOR PUBLIC DISCLO3URE. IT IS INIE!!IIO:' ALLY LIFI BLA:: l These violations have been categorized in the aggregate as a Severity Level III 4 problem (Supplement 111).

(Cumulative Civil Penalties - 550,000 - assessed equally among the violations.)

Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, , with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region I, 631 Park Avenue, King of Prussia, PA 19406, within 30 days of the date of this alleged Notice, a written statement or explanation, including for each violation: (1) admission or denial of the alleged violation; (2) the

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reasons for the violation, if admitted; (3) the corrective steps which have _ been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may issue an Order to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be take Consideration may be given to extending the response time for good cause show Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this responsa shall be submitted under oath or affirmatio Within the same time as provided for the response required under 10 CFR 2.201, Philadelphia Electric Company may pay the civil penalties by letter to the i Director, Office of Inspection and Enforcement, with a check, draft, or money ! order payable to the Treasurer of the United States in the amount of $50,000 I or may protest imposition of the civil penalties, in whole or in part, by a writter, answer a:: dressed to the Director, Office of Inspection and Enforcemen Should Philadelphia Electric Company fail to answer within the time specified, I the Director, Office of Inspection and Enforcement, will issue an Order irrposing the civil penalties proposed above. Should Philadelphia Electric Company elect

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Appendia B ,

   -4-to fileanswer such an answer may: in accordance with 10 CFR 2.205 protesting the civil penalties (1) deny the violations listed in this Notice in whole or in ,

part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalties should not be imposed, in addition to protesting the civil penalties, mitigation of the proposed penalties. in whole or in part, such answer may request In requesting mitigation of the proposed penalties, the five factors contained in Secticn V(B) of 10 CFR Part 2, Appendix C (1985) should be addresse Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate and paragraph statements numbers) tooravoid explanations repetition.by Philadelphia specific reference (e.g., citing page Electric Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedures for imposing civil penaltie Upon failure to pay any civil penalties due, which have been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties unless com-promised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 228 FOR THE NUCLEAR REGULATORY COMMISSION Thomas E. Murl Regional Administrator _ Dated a King of Prussia, Pennsylvania this ay of May 1985

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. DISTRIBUTION LIST FOR BOARD NOTIFICATION Limerick, Units 1&2, Docket No. 50-352/353 Mr. Robert L. Anthony Director, PA Emergency Mr. Edward G. Bauer, J Management Agency Mr. Timothy R. S. Campbell Dr. Richard F. Cole Atomic Safety and Licensing Troy B. Conner, Jr., Es Board Panel Charles W. Elliott, Es Atomic Safety and Licensing Zori G. Ferkin Appeal Panel Mr. Thomas Gerusky Docketing and Service Section Jay Gutierrez, Es Document Management Branch Dr. Jerry Harbour Steven P. Hershey, Es LIMERICK DOCKET Helen F. Hoyt, Es Kathryn S. Lewis, Es Frederic M. Wentz Mr. Marvin I. Lewis Eugene J. Bradley Angus Love, Es Mr. Vincent Boyer Mr. Gregory Minor Mr. Karl Abraham Spence Perry, Es Mr. Suresh Chaudhary Mr. Frank R. Romano ' Steven P. Hershey, Es Robert J. Sugarman, Es Mr. J. T. Robb, N2-1 Mr. David Wersan Governor's Office of State Planning Mr. Joseph H. White, III and Development, PA Mr. James Wiggins Department of Environmental Resources, PA Ms. Phyllis Zitzer Chairman, Board of Supervisors of Limerick Township i U.S. Environmental Protection Agency, PA

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