Violation: Title
10 CFR 72.150 states The licensee . . . shall prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall require that these instructions, procedures, and drawings be followed. Contrary to the above, on June 5 and 6, 2018, the licensee failed to follow procedures for an activity affecting quality. Specifically, during a dry run in the primary auxiliary building (PAB) over the spent fuel pool (
SFP), the pin lock for the pin which engages the Point Beach pool lift
yoke to the PAB overhead crane was not correctly engaged when lifting the transfer cask (
TC) out of the pool. After the
TC was set down in the decon area, the lift
yoke was then left unattended over the
SFP over spent fuel. This is not in accordance with procedure
RP 17 Part 4, Revision 26, Step 5.1.4 for engagement of the pin lock, and not in accordance with procedure MAAA2121000, Revision 16, Step 4.5.3 for leaving a load suspended and unattended.Severity Level: The inspector determined the violation was more than minor, as informed by
Inspection Manual Chapter (IMC) 0612 Appendix E, Example 4.k., in that there was a credible load drop scenario that could impact safety-related equipment. In accordance with Section 2.2 of the
Enforcement Policy and
IMC 0612, Appendix B, Issue Screening, Independent Spent Fuel Storage Installations are not subject to the
Significance Determination Process and are not subject to the Reactor Oversight Process, so violations identified at
ISFSIs are assessed using traditional enforcement. Consistent with the guidance in Section 1.2.6.D of the Enforcement Manual, if a violation does not fit an example in the
Enforcement Policy Violation Examples, it should be assigned a severity level: (1) commensurate with its safety significance; and (2) informed by similar violations addressed in the Violation Examples. The inspector found no similar violations in the violation examples. This violation was determined to be a
Severity Level IV in that there was no load drop, and that the weight of any load on the pin would contribute to opposing any potential movement of the pin.
