Severity Level IV. The inspectors identified a
Severity Level IV non- cited violation for the licensees failure to perform an analysis of a change to processes supporting the emergency preparedness program that demonstrated the change did not reduce the effectiveness of the
emergency plan in accordance with the requirements of
10 CFR 50.54(q)(3). There were no immediate safety concerns associated with this violation because less than 10 percent of the public address speakers were determined to be degraded or non- functional. This issue has been placed in the licensees corrective action system as Condition Report 201702343. The failure to perform an analysis of the effect of changes in processes supporting
emergency preparedness is a performance deficiency within the licensees ability to foresee and correct. The finding was more than minor because the finding was associated with the Facilities and Equipment Cornerstone attribute and adversely affected the Emergency Preparedness Cornerstone objective. The finding was assessed using traditional enforcement because the licensees failure to perform a required analysis impacted the regulatory process . The finding was evaluated using the NRCs
Enforcement Policy, dated November 1, 2016, Section 6.6(d) , and was determined to be a
Severity Level IV violation because the violation did not affect radiological assessment or offsite notification. Traditional enforcement violations are not assessed for cross -cutting aspects.
