Between March 3 and April 25, 2003, the licensee implemented a change to Emergency Action Level C3 which constituted a decrease in effectiveness of the
emergency plan because two conditions which would previously have resulted in site area emergency classification would not be classified by the revised emergency action level. Implementation without prior NRC approval of changes to the
emergency plan which constitute reduction in the effectiveness of the plan was a noncited violation of
10 CFR 50.54(q)
The finding was evaluated using
NUREG-1600, "General Statement of Policy and Procedure for NRC Enforcement Actions,"
Section IV, because licensee reductions in the effectiveness of its
emergency plan impact the regulatory process. The finding had greater than minor significance because deletion of conditions indicative of a site area emergency has the potential to impact safety. The finding was determined to be a noncited
Severity Level IV violation because the emergency action level change constituted a failure to implement an emergency planning standard and did not constitute a failure to meet an emergency planning standard as defined by
10 CFR 50.47(b). This finding has been entered into the licensee's corrective action program as Action Request 030400514.
