CRYSTAL RIVER UNIT 3 - FINAL SIGNIFICANCE DETERMINATION OF A WHITE FINDING
Failure to Maintain a Standard Emergency Action Level Scheme , is updated as VIO 05000302/2011501-01 with a safety significance of White, and a human performance cross-cutting element of Decision-making for ensuring that risk-significant decisions are made using a systematic process and obtaining interdisciplinary input and reviews. The NRC determined the performance at Crystal River Nuclear Plant Unit 3 to be in the Regulatory Response Column of the Reactor Oversight Process Action Matrix beginning the third quarter of 2011. Therefore, the NRC plans to conduct a supplemental inspection in accordance with Inspection Procedure 95001, “Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area,” to provide assurance that the root causes and contributing causes of risk-significant performance issues are understood, that the extent of cause is identified and that your corrective action for risk-significant performance issues are sufficient to address the root and contributing causes and prevent recurrence. The NRC requests that your staff provide notification of your readiness for the NRC to conduct a supplemental inspection to review the actions taken to address the White inspection finding. At Cyrstal River's request, a Regulatory Conference was held on November 7, 2011, to discuss the stations views on this issue. During the meeting the stations staff described the assessment of the significance of the finding, and the corrective actions taken to resolve it, including the root cause evaluation of the finding. Crystal River's root cause analysis found that establishment of the inappropriate radiation monitor threshold value was due to insufficient procedural guidance for the EAL change process. Contributing causes were found to be failures to validate assumptions and to conduct adequate reviews. Finally, the station presented its assessment of the risk associated with this finding and determined it to be Green based on the availability of other means to evaluate gaseous effluent releases and fission-product barrier EALs to declare a timely and accurate General Emergency. Cyrstal River's staff stated that the Inspection Manual Chapter (IMC) 0609, Appendix B, Emergency Preparedness Significance Determination Process result should be Green since even with the improper radiation monitor threshold value, the risk-significant planning standard function was not degraded. In accordance with the NRC Enforcement Policy, the Notice is considered an escalated enforcement action because it is associated with a White finding.


