Severity Level IV. The licensee changed its emergency action level schemes such that there would be a reduction in declarable events as the emphasis shifted from personnel safety to equipment status. The changes were determined to be a decrease in the effectiveness of the
emergency plans. Decreases in the effectiveness of an
emergency plan must Page 7 of 8 receive NRC review prior to implementation. The changes were implemented without NRC approval.
The finding was determined to be more than minor as its significance was related to the impact it would have on the mobilization of the emergency response organization and preclude offsite agencies from being aware of adverse conditions on site. The licensee accepted the NRC's position and entered this issue into its corrective action program (Condition Report 139997) and will change the emergency action levels back to the original wording. The implementation of the changes which decreased the effectiveness of the
emergency plans, without NRC review, is being treated as a non-cited violations consistent with Section VI.A of the
Enforcement Policy, issued on May 1, 2000 (
65 FR 25388).
