Section 50.54(q)(2) of 10 CFR requires, in part, that a licensee shall follow and maintain the effectiveness of an
emergency plan which meets the planning standards of
10 CFR 50.47(b) and the requirements of
10 CFR Part 50, Appendix E . Section 50.47(b)(4) of 10 CFR requires that a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures. Contrary to the above, from April 2010 to May 2017, the licensee failed to maintain the effectiveness of its
emergency plan. Specifically, the licensee's emergency classification scheme action levels for Category F Fission Product Barrier
EAL , contained declaration threshold values for the
containment high range radiation monitor , which were lower than the correct values due to an improper methodology used in calculating the loss of fuel clad barrier and potential loss of containment barrier threshold values and rendered the
EALs ineffective. The licensee implemented compensatory actions by issuing Standing Instruction 2017- 017 to inform operators and emergency response organization decision- makers of the proper application of the
EAL scheme and appropriate threshold values to be implemented until a permanent change can be made to the license. The issue was entered into the licensees
CAP as
NCR 02123373. The inspectors evaluated this issue as an ineffective
EAL per
IMC 0609, Appendix B,
Emergency Preparedness Significance Determination Process , Figure 5.4 -1. The inspectors concluded that the violation was of very low safety significance (Green). Although the incorrect
EAL would alone render an early
EAL classification of a General Emergency (
GE) based upon the specific radiation monitor, other
EALs would provide a
GE classification in an accurate and timely manner aligned with the incorrect threshold values of the
containment high range radiation monitor .
