The inspectors identified a violation of
10 CFR 50.54(q) for implementing a change to emergency action levels which decreased the effectiveness of the
emergency plan. Emergency Implementing Plan Procedure EIP-ZZ-00101, Classifying the Emergency, Revision 33, limited application of emergency action Level 3E, Fire within Protected Area Boundary NOT Extinguished with 15 minutes of Verification, so that fires in some plant areas which would be classified under the previous revision may no longer be classifiable.
Implementation of changes to emergency action levels which decreased the effectiveness of the
emergency plan was a performance deficiency. The finding is more than minor because removal of a classifiable condition from licensee emergency action levels has the potential to impact safety, and licensee implementation of a change to their
emergency plan, which decreases the effectiveness of the plan without prior NRC approval, impacts the regulatory process. This finding is a violation of
10 CFR 50.54(q). The licensee has entered this issue into their corrective action system as Corrective Action Report 200510162.
