The inspectors identified that the licensee had changed its standard emergency action level (
EAL) scheme by revising one
EALs criteria for an Unusual Event declaration that addressed an unplanned radiological release in excess of effluent radiation monitor readings unless the release could be determined to be below
Offsite Dose Calculation Manual limits within 15 minutes for releases that could not be terminated in 60 minutes or less. The inspectors determined that this
EAL change decreased the effectiveness of the
emergency plan, and that the licensee did not obtain prior NRC approval for this change, contrary to the requirements of
10 CFR 50.54(q). The licensee is evaluating the options to correct the
EAL
This finding was more than minor because extending the time period required for the appropriate emergency classification of a radiological release could adversely affect the performance of both onsite and offsite emergency actions. Because the issue affected the NRCs 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 because it involved a failure to meet a requirement not directly related to assessment and notification. Further, this problem was isolated to one
EAL and was not indicative of a functional problem with the
EAL scheme. Additionally, because the violation was a
Severity Level IV and the licensee entered this issue into its corrective action program this finding is being treated as a
Severity Level IV Non-Cited Violation of
10 CFR 50.54(q).
