The inspector identified a finding of very low safety significance involving a
Severity Level IV NCV of
10 CFR 50.54(q) for failing to obtain prior approval for an
emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (
EAL) Basis in
EAL HU6, Revision 26, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the
emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the
emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a
Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the
EAL basis to restore compliance. The finding was more than minor using
IMC 0612, because it is associated with the
emergency preparedness cornerstone attribute of procedure quality for
EAL and
emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using
IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with
10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event Classification
