Severity Level IV. The inspectors identified a
Severity Level IV Non-Cited Violation associated with the licensees failure to perform an adequate safety evaluation per
10 CFR 50.59. Contrary to
10 CFR 50.59, a screening safety evaluation for handling of a 35 ton cask in the Reactor Building did not provide an adequate basis to demonstrate that the evaluation for use of a heavier cask did not change the evaluation methods approved by the NRC staff in 1985 for the
control of heavy loads per
NUREG 0612 commitments, as described in the
UFSAR and the Pilgrim licensing basis. The licensee made significant enhancements to the original 50.59 safety evaluation and entered this issue into the corrective action program. The finding was determined to be more than minor because the inspectors could not reasonably determine that the methodology used to evaluate the use of a heavier cask did not constitute a change that would have required NRC approval. The conditions associated with the finding (i.e., the potential drop of a loaded cask) were determined to be of very low safety significance because they did not result in the loss of operability of a safety system. Because the issue affected the NRCs ability to perform its regulatory function, this finding was evaluated using the traditional enforcement process and was classified at
Severity Level IV because the violation of
10 CFR 50.59 involved conditions evaluated as having very low safety significance by the
SDP. This finding has a cross-cutting aspect in the area of human performance because Entergy did not fully evaluate the licensing basis to develop the 50.59 safety evaluation, and thereby failed to assure a design document was complete and accurate.