The following violation of very low concern was identified (
Severity Level IV) by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the
NRC Enforcement Policy,
NUREG-1600, for being dispositioned as an
NCV.
10 CFR 50.54(q) states in part that the licensee may make changes to these plans without Commission approval only if the changes do not decrease the effectiveness of the plans. Proposed changes that decrease the effectiveness of the approved
emergency plans may not be implemented without application to and approval by the Commission. Contrary to the above, on October 06, 2000, the licensee made changes to their
Emergency Plan with Revision 23, which resulted a decrease in effectiveness (
DIE) of the
emergency plan. The change replaced the licensees previous standard minimum Protective Action Recommendation (
PAR) based on NRC and
FEMA guidance, which used the keyhole approach (i.e., evacuate all sectors to 2 miles and downwind sectors 2- 5 miles) with an evacuation to 5 miles in all directions. The change may be overly conservative in such a way as to place members of the public at unnecessary risk during evacuation of an area unaffected by a radiological release which would be more appropriately recommended for sheltering. These changes were not submitted to the NRC for approval prior to implementation. This finding is documented in the licensee's corrective action program as N2006-0568.
