No Color: The inspectors identified a
Severity Level IV non-cited violation (
NCV) of
10 CFR 50.54(q) for implementing a change which decreased the effectiveness of the
emergency plan without prior NRC approval. The licensee implemented an
Emergency Plan change that modified the default Protective Action Recommendation (
PAR) for the General Emergency classification to evacuate to 5 miles in all directions. The finding was evaluated using the NRCs
Enforcement Policy because licensee reductions in the effectiveness of its
emergency plan impacted the regulatory process, in that, NRC approval was not requested prior to licensee implementation of the change. This finding is of more than minor concern because the change made may be overly conservative in such a way as to place members of the public at unnecessary risk during evacuation of an area unaffected by a radiological release which would be more appropriately recommended for sheltering. The finding was determined to be a noncited
Severity Level IV violation in accordance with Supplement VIII of the
Enforcement Policy because it involved licensee failure to meet an emergency planning requirement not directly related to assessment and notification.