The inspectors identified that the licensee had changed its standard emergency action level (
EAL) scheme by revising one
EAL's criteria for a
Unusual Event declaration due to the initiation of the Steam and Feedwater Rupture Control System as a result of a rapid depressurization o
the secondary side. The inspectors determined that this EAL change decreased the effectiveness of the emergency plan, and that the license
did not obtain prior NRC approval for this change, contrary to the requirements of 10 CFR 50.54(q). Because the issue affected the NRC'
ability to perform its regulatory function, it was evaluated with the traditional enforcement process as specified in Section IV.A.3 of the Enforcement Policy. According to Supplement VIII of the Enforcement Policy, this finding was determined to be a Severity Level IV becaus
it involved a failure to meet a requirement not directly related to assessment and notification. Further, this problem was isolated to one EA
and was not indicative of a functional problem with the EAL scheme. Additionally, because the licensee entered this issue into its correctiv
action program and completed adequate corrective actions, this finding is being treated as a Severity Level IV Non-Cited Violation of 10 CF
50.54(q).
