The inspector identified a
SL IV
NCV of
10 CFR 50.54(q) because the licensee decreased the effectiveness of its
emergency plan in one area by removing a provision to provide volunteer bus drivers to two school districts within the 10 mile Emergency Planning Zone for evacuating students during a radiological event. The change was implemented without NRC approval
Changing
emergency plan provisions without prior NRC approval impacts the NRC's ability to perform its regulatory function and is therefore processed through traditional enforcement as specified in Section IV.A.3 of the
Enforcement Policy, issued May 1, 2000 (
65 FR 25388). According to Supplement VIII of the
Enforcement Policy, this finding was determined to be a
SL IV violation because it involved a failure to meet a requirement not directly related to assessment and notification. This
NCV was also determined to have very low safety significance since Exelon had maintained a list of volunteers that would have been able to perform the function if needed.