05000498/FIN-2017010-02
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Finding | |
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Title | Failure to Perform Required 50.54(q) Evaluations prior to Implementing Changes to the Emergency Plan |
Description | The NRC identified a Severity Level IV violation of 10 CFR 50.54(q)(3) for the failure to perform analyses demonstrating that changes to the emergency plan did not reduce the effectiveness of the plan before implementing the changes without prior NRC approval. The failure to perform required evaluations did not have any safety consequences; the inspectors verified that the changes did not reduce the effectiveness of the emergency plan. The issue was entered into the licensees corrective action program as Condition Report 2017-15956. The failure to perform analyses of the effect of changes in processes supporting emergency preparedness is a performance deficiency. The performance deficiency is more than minor because it affected the procedure quality (plan changes) cornerstone attribute and adversely affected the Emergency Preparedness cornerstone objective of being capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The performance deficiency was assessed using traditional enforcement because the licensees failure to perform a required analysis impacted the regulatory process. The issue 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. |
Site: | South Texas |
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Report | IR 05000498/2017010 Section 1EP5 |
Date counted | Sep 30, 2017 (2017Q3) |
Type: | TEV: Severity level IV |
cornerstone | Emergency Prep |
Identified by: | NRC identified |
Inspection Procedure: | IP 71114.05 |
Inspectors (proximate) | L Carson S Money P Elkmann S Hedger H Gepford |
Violation of: | 10 CFR 50.54 10 CFR 50.54(q) |
INPO aspect | |
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Finding - South Texas - IR 05000498/2017010 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (South Texas) @ 2017Q3
Self-Identified List (South Texas)
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