Issue Date: XX/XX/XX B-1 0612 App B 

APPENDIX B 

Issue Screening 

Use Figure 1 and the questions listed below to determine if a finding has sufficient 

significance to warrant further analysis or documentation. 

Figure 1 

Issues

Performance

Deficiencies? Violation

Stop

Document As Violation per

Enforcement Policy

and provide risk

characterization of issues

No

No

Yes

Issue is now a Finding

Traditional

Enforcement?

Enforcement

Related finding

Requires NRC

Management

Review

Document With

Severity Level and

If Applicable an

SDP Color

Yes

Yes

Potentially Significant

Finding. May Require

Traditional Enforcement

Is Finding

greater than

minor using

 App. E?

No

Is finding greater

than minor using

minor questions?

Evaluate using

SDP?

No

Yes

Yes

Finding is Greater

Than Minor

Do not Document *

* see exception in

Section 05.03

No Finding is

Minor

Document in

accordance with

review results

No Finding is greater than

minor Requires NRC

Management Review

Analyze Using The

Significance

Determination

Process

Document as a

Finding / Violation

(G, W, Y, R)

Assign a

Significance Color

Yes

Request Risk

Assessment When

Applicable

Provide Risk

Assessment To

Enforcement

When Applicable
Issue Date: 09/20/07 B-2 0612 App B 

Page intentionally left blank 
Issue Date: XX/XX/XX B-3 0612 App B

Section 1. Performance Deficiency Question

An issue must be a Aperformance deficiency@ before it can be considered a finding. 

Did the licensee fail to meet a requirement or a standard, where the cause was 

reasonably within the licensee=s ability to foresee and correct and which should 

have been prevented? A performance deficiency can exist if a licensee fails to meet 

a self-imposed standard or a standard required by regulation. 

Section 2. Traditional Enforcement Questions

(1) Does the issue have actual safety consequence (e.g., overexposure, actual 

radiation release greater than 10 CFR Part 20 limits)? 

(2) Does the issue have the potential for impacting the NRC=s ability to perform its 

regulatory function? For example, a failure to provide complete and accurate 

information or failure to receive NRC approval for a change in licensee activity, or 

failure to notify NRC of changes in licensee activities, or failure to perform 10 CFR 

50.59 analyses etc. (see Enforcement Policy IV.A.3). 

(3) Are there any willful aspects of the violation? 

 

Section 3. Minor Questions (A finding should be compared to Appendix E examples to 

determine if it is similar to a minor example. If not, then answer the following 

questions to determine if the finding is more than minor.) 

(1) Could the finding be reasonably viewed as a precursor to a significant event? 

(2) If left uncorrected would the finding become a more significant safety concern? 

(3) Does the finding relate to a performance indicator (PI) that would have caused the 

PI to exceed a threshold? 

(4) Is the finding associated with one of the cornerstone attributes listed at the end of 

this attachment and does the finding affect the associated cornerstone objective? 

(5) Does the finding relate to any of the following maintenance risk assessment and 

risk management issues? 

(a) Licensee risk assessment failed to consider risk significant SSCs and support 

systems (included in Table 2 of the plant specific Phase 2 SDP risk-informed 

inspection notebook) that were unavailable during the maintenance. 

(b) Licensee risk assessment failed to consider unavailable SSCs such as 

Residual Heat Removal Systems (PWR and BWR) that prevent or mitigate 

Interfacing System LOCAs. 
Issue Date: XX/XX/XX B-4 0612 App B

(c) Licensee risk assessment failed to consider SSCs that prevent containment 

failure such as containment isolation valves (BWR & PWR), BWR 

drywell/containment spray/containment flooding systems, and PWR 

containment sprays and fan coolers. 

(d) Licensee risk assessment failed to consider unusual external conditions that 

are present or imminent (e.g, severe weather, offsite power instability). 

(e) Licensee risk assessment failed to consider maintenance activities that could 

increase the likelihood of initiating events such as work in the electrical 

switchyard (increasing the likelihood of a loss of offsite power) and RPS 

testing (increasing the likelihood of a reactor trip). 

(f) Licensee risk assessment failed to consider the uncompensated removal or 

impairment of plant internal and/or external flood barriers. 

(g) Licensee risk assessment failed to account for any unavailability of a single 

train of a system (primary or back-up) that provides a shutdown key safety 

function. 

(h) Licensee=s risk assessment has known errors or incorrect assumptions that 

has the potential to change the outcome of the assessment. 

(i) Licensee failed to implement any prescribed significant compensatory 

measures or failed to effectively manage those measures. 

Section 4. SDP Questions

REACTOR SAFETY 

CORNERSTONES C Initiating Events, Mitigating Systems, & Barrier Integrity

(1) Is the finding associated with an increase in the likelihood of an initiating event? 

(2) Is the finding associated with the operability, availability, reliability, or function of a 

system or train in a mitigating system? 

(3) Is the finding associated with the integrity of fuel cladding, the reactor coolant 

system, reactor containment, control room envelope, auxiliary building (PWR), or 

standby gas treatment system (BWR)? 

(4) Is the finding associated with degraded conditions that could concurrently influence 

any mitigation equipment and an initiating event? 

(5) Is the finding associated with or involve impairment or degradation of a fire 

protection feature? 
Issue Date: XX/XX/XX B-5 0612 App B

(6) Is the finding associated with the spent fuel pool cooling system radiological 

barrier? 

(7) Is the finding associated with inadequate 10 CFR 50.65 (a)(4) risk assessment 

(quantitative only) and/or risk management? 

Emergency Planning: 

(1) Is the finding associated with a failure to meet or implement a regulatory 

requirement? 

(2) Is the finding associated with a drill or exercise critique problem? 

(3) Is the finding associated with an actual event implementation problem? 

Operator Requalification:

(1) Is the finding related to licensee=s grading of exams? 

(2) Is the finding related to written exams? 

(3) Is the finding related to an individual operating test? 

(4) Is the finding related to simulator fidelity? 

(5) Is the finding related to simulator scenario quality? 

(6) Is the finding related to scenario security? 

(7) Is the finding related to crew performance? 

(8) Is the finding related to operator pass/fail rate? 

(9) Is the finding related to operator license conditions? 

RADIATION SAFETY

CORNERSTONE C Occupational Radiation Safety (ALARA): 

(1) Does the occurrence involve a failure to maintain or implement, to the extent 

practical, procedures or engineering controls, needed to achieve occupational 

doses that are ALARA1

, and that resulted in unplanned, unintended occupational 

collective dose for a work activity? 

(2) Does the occurrence involve an individual worker(s) unplanned, unintended dose(s) 

that resulted from actions or conditions contrary to licensee procedures, radiation 

work permit, technical specifications or NRC regulations? 
Issue Date: XX/XX/XX B-6 0612 App B

(3) Does the occurrence involve an individual worker(s) unplanned, unintended dose(s) 

or potential of such a dose (resulting from actions or conditions contrary to licensee 

procedures, radiation work permit, technical specifications or NRC regulations) 

which could have been significantly greater as a result of a single minor, 

reasonable alteration of the circumstances? 

(4) Does the occurrence involve conditions contrary to licensee procedures, technical 

specifications or NRC regulations which impact radiation monitors, instrumentation 

and/or personnel dosimetry, related to measuring worker dose? 

CORNERSTONE C Public Radiation Safety

(1) Does the finding involve an occurrence in the licensee's radiological effluent 

monitoring program that is contrary to NRC regulations or the licensee's TS, Offsite 

Dose Calculation Manual (ODCM), or procedures? 

(2) Does the finding involve an occurrence in the licensee=s radiological environmental 

monitoring program that is contrary to NRC regulations or the licensee=s TS, 

ODCM, or procedures? 

(3) Does the finding involve an occurrence in the licensee's radioactive material control 

program that is contrary to NRC regulations or the licensee=s procedures? 

(4) Does the finding involve an occurrence in the licensee=s radioactive material 

transportation program that is contrary to NRC or Department of Transportation 

(DOT) regulations or licensee procedures? 

SAFEGUARDS

CORNERSTONE C Physical Protection 

(1) Is the finding associated with or involve a failure to meet the requirements of 10 

CFR 73.55 (b)-(h), or associated plans, procedures, orders, or rules? 

(2) Is the finding associated with or impact any key attribute of the Security cornerstone 

to meet its intended function whether in performance, design or implementation? 

Section 5. Screen for Cross-Cutting Aspect(s) 

a. Based on the information developed during the inspection, identify the most

significant contributor that provides the most meaningful insight into the 

performance deficiency. Refer to the guidance in IMC 0305, section 06.07. There 

should typically be only one principal cause and one cross-cutting aspect 

associated with each finding. However, on rare occasion it may be appropriate for 

some unique or complex inspection findings with multiple root causes to be 

associated with more than one cross-cutting aspect. In these cases, the regional 
Issue Date: XX/XX/XX B-7 0612 App B

office must obtain concurrence from the NRR Performance Assessment Branch 

Chief. For the case of a finding with multiple examples, consistent with the 

Enforcement Manual guidance (section 2.3.17), it is appropriate for the multiple 

examples to have the same cross-cutting aspect. 

b. Answer the following questions with respect to the most significant contributor of 

the performance deficiency to determine if the finding has a cross-cutting aspect: 

(1) Is there a reason why the most significant contributor of the performance deficiency 

is not reflective of current licensee performance? 

Consider the following questions: 

 - When did the performance deficiency or event occur? 

 - If the performance deficiency or event was the result of a latent issue, when 

did the cause of the performance deficiency occur? 

 - If the performance deficiency or event was the result of a latent issue, did the 

licensee have reasonable opportunities to identify the problem? 

 - Have programs, processes or organization changed such that the problem 

would not reasonably occur today? 

 If the most significant contributor is not reflective of current performance, the finding 

does not have a cross-cutting aspect. 

(2) Is the most significant contributor of the performance deficiency related to a crosscutting area (Human Performance, Problem Identification and Resolution, or Safety 

Conscious Work Environment) and similar to one of the cross-cutting aspects 

described in section 06.07.c of IMC 0305? 

If so, and the most significant contributor reflects current performance, the finding has 

a cross-cutting aspect.
Issue Date: XX/XX/XX B-8 0612 App B

CORNERSTONE OBJECTIVES AND ATTRIBUTES

(related to Section 3, Minor Questions) 

Cornerstone: REACTOR SAFETY / Initiating Events 

Objective: To limit the likelihood of those events that upset plant stability and challenge 

critical safety functions during shutdown as well as power operations. 

Attributes: Examples: 

Design Control: Initial Design and Plant Modifications 

Protection Against 

External Factors: Flood Hazard, Fire, Loss of Heat Sink, Toxic Hazard, 

 Switchyard Activities, Grid Stability 

Configuration Control: Shutdown Equipment Lineup, Operating Equipment 

Lineup, 

Equipment Performance: Availability, Reliability, Maintenance; Barrier Integrity 

(SGTR, ISLOCA, LOCA (S,M,L)), Refueling/Fuel 

Handling Equipment 

Procedure Quality: Procedure Adequacy 

Human Performance: Human Error 

Cornerstone: REACTOR SAFETY / Mitigating Systems 

Objective: To ensure the availability, reliability, and capability of systems that respond to 

initiating events to prevent undesirable consequences (i.e., core damage). 

Attributes: Examples: 

Design Control: Initial Design and Plant Modifications 

Protection Against 

External Factors: Flood Hazard, Fire, Loss of Heat Sink, Toxic Hazard, 

Seismic 

Configuration Control: Shutdown Equipment Lineup, Operating Equipment 

Lineup, 

Equipment Performance: Availability, Reliability 

Procedure Quality: Operating (Post Event) Procedure (AOPs, SOPs, 

EOPs); Maintenance and Testing (Pre-event) 

Procedures 

Human Performance: Human Error (Post Event), Human Error (Pre-event) 
Issue Date: XX/XX/XX B-9 0612 App B

Cornerstone: REACTOR SAFETY / Barrier Integrity 

Objective: To provide reasonable assurance that physical design barriers (fuel cladding, 

reactor coolant system, and containment) protect the public from radio nuclide releases 

caused by accidents or events. 

Attributes: Examples: 

(Maintain Functionality of Fuel Cladding) 

Design Control: Physics Testing; Core Design Analysis (Thermal 

Limits, Core Operating Limit Report, Reload Analysis, 

10 CFR50.46) 

Configuration Control: Reactivity Control (Control Rod Position, Reactor 

Manipulation, Reactor Control Systems); Primary 

Chemistry Control; Core Configuration (Loading) 

Cladding Performance: Loose Parts (Common Cause Issues); RCS Activity 

Level 

Procedure Quality: Procedures which could impact cladding 

Human Performance: Procedure Adherence (FME, Core Loading, Physics 

Testing, Vessel; Assembly, Chemistry, Reactor 

Manipulation); FME Loose Parts, Common Cause 

Issues 

Attributes: Examples: 

(Maintain functionality of RCS) 

Design Control: Plant Modifications 

Configuration Control: System Alignment; Primary Secondary Chemistry 

RCS Equipment and Barrier 

Performance: RCS Leakage; Active Components of Boundary 

(Valves, Seals); ISI Results 

Procedure Quality: Routine OPS/Maintenance procedures; EOPs and 

related Normal Procedures invoked by EOPs 

Human Performance: Routine OPS/Maintenance Performance; Post 

Accident or Event Performance 

Attributes: Examples: 

(Maintain Functionality of Containment) 

Design Control: Plant Modifications; Structural Integrity; Operational 

Capability 

Configuration Control: Containment Boundary Preserved; Containment 

Design Parameters Maintained 

SSC and Barrier Performance: S/G Tube Integrity, ISLOCA Prevention; Containment 

Isolation SSC Reliability /Availability, Risk Important 

Systems Function 

Procedure Quality: Emergency Operating Procedures; Risk Important 

Procedures (OPS, Maintenance, Surveillance) 
Issue Date: XX/XX/XX B-10 0612 App B

Human Performance: Post Accident or Event Performance; Routine 

OPS/Maintenance Performance 

Attributes: Examples: 

(Maintain Radiological Barrier Functionality of Control Room and Auxiliary Building - PWR, 

and Standby Gas Trains - BWR only) 

Design Control: Plant Modifications; Structural Integrity 

Configuration Control: Building Boundaries Preserved 

SSC and Barrier Performance: Door, Dampers, Fans, Seals, Instrumentation 

Procedure Quality: EOPs, Abnormal and Routine Operating Procedures, 

Surveillance Instructions, Maintenance Procedures 

Human Performance: Post Accident or Event performance; Routine 

OPS/Maintenance Performance 

Attributes: Examples: 

(Maintain Functionality of Spent Fuel Pool Cooling System) 

Design Control Plant Modifications; Structural Integrity 

Configuration Control: System Alignment 

SSC Performance: Pumps, Valves, Instrumentation 

Procedure Quality: EOPs, Abnormal and Routine Operating Procedures, 

Surveillance Instructions, Maintenance Procedures 

Human Performance: Post Accident or Event Performance; Routine 

OPS/Maintenance Performance 

Cornerstone: REACTOR SAFETY / Emergency Preparedness 

Objective: To ensure that the licensee is capable of implementing adequate measures to 

protect the health and safety of the public in the event of a radiological emergency. 

Attributes: Examples: 

ERO Readiness: Duty Roster; ERO Augmentation System; ERO 

Augmentation Testing; Training 

Facilities and Equipment: ANS Testing; Maintenance Surveillance and Testing of 

Facilities, Equipment and Communications Systems; 

Availability of ANS, Use in Drills and Exercises. 

Procedure Quality: EAL Changes, Plan Changes; Use in Drills and 

Exercises 

RO Performance: Program Elements Meet 50.47(b) Planning 

Standards, Actual Event Response; Training, Drills, 

Exercises 

Offsite EP: FEMA Evaluation 

Cornerstone: RADIATION SAFETY / Occupational Radiation Safety 
Issue Date: XX/XX/XX B-11 0612 App B

Objective: To ensure the adequate protection of the worker health and safety from 

exposure to radiation from radioactive material during routine civilian nuclear reactor 

operation. 

Attributes: Examples: 

Plant Facilities/Equipment Plant Equipment, ARM Cals & Availability, 

and Instrumentation: Source Term Control; Procedures (Radiation and 

Maintenance) 

Program & Process: Procedures (HPT, Rad Worker, ALARA); 

Exposure/Contamination Control and Monitoring 

(Monitoring and RP Controls); ALARA Planning 

(Management Goals, Measures - Projected Dose) 

Human Performance: Training (Contractor HPT Quals, Radiation Worker 

Training, Proficiency) 

Cornerstone: RADIATION SAFETY / Public Radiation Safety 

Objective: To ensure adequate protection of public health and safety from exposure to 

radioactive materials released into the public domain as a result of routine civilian nuclear 

reactor operation. 

Attributes: Examples: 

Plant Facilities/Equipment Process Radiation Monitors (RMS) 

and Instrumentation: (Modifications, Calibrations, Reliability, Availability), 

REMP Equipment, Meteorology Equipment, 

Transportation Packaging; Procedures 

(Design/Modifications, Equipment Calculations, 

Transportation Packages, Counting Labs) 

Program & Process: Procedures; (Process RMS & REMP, Effluent 

Measurement OC, Transportation Program, Material 

Release, Meteorological Program, Dose Estimates); 

Exposure and Radioactivity Material Monitoring and 

Control (Projected Offsite Dose, Abnormal Release, 

DOT Package Radiation Limits, Measured Dose) 

Human Performance: Training (Technician Qualifications, Radiation & 

Chemical Technician Performance. 
Issue Date: XX/XX/XX B-12 0612 App B

Cornerstone: SAFEGUARDS /Security 

Objective: To provide assurance that the licensee=s security system and material control 

and accountability program use a defense-in-depth approach and can protect against 

(1) the design basis threat of radiological sabotage from external and internal threats, and 

(2) the theft or loss of radiological materials 

Attributes: Examples: 

Physical Protection System: Protected Areas (Barriers and Alarms, Assessment); 

Vital Areas (Barriers and Alarms, Assessment) 

Access Authorization System: Personnel Screening; Behavior Observations; 

Fitness for Duty 

Access Control System: Search; Identification 

Response to Contingency Events: Protective Strategy; Implementation of Protective 

Strategy 
Issue Date: XX/XX/XX Att1-1 

ATTACHMENT 1 

Revision History for APPENDIX B to IMC 0612 - Issue Screening 

Commitment Tracking Number 

Issue Date Description of Change Training 

Needed 

Training Completion Date 

CRA

N/A 11/01/2006 Revision history reviewed for the last four 

years. 

NO N/A N

N/A 04/29/2002 

CN 02-021 

Appendix B was removed as an attachment to IMC-0612 and was issued as stand alone document. 

NO N/A N

N/A 05/19/2005 

CN 05-014 

Revised to add Question No. 5 to Minor Questions in Section 3 and Question No. 6 to the SDP Questions in Section 4 to reflect the new maintenance risk assessment and risk management SDP, IMC 0609, Appendix K, AMaintenance 

Rule Risk Assessment and Risk Management.@

NO N/A N

N/A 09/30/2005 

CN 05-028 

Revised to clarify the definition of a performance deficiency and a functionality of the control room. Also, the auxiliary building attribute was added to the cornerstone and objective section. 

NO N/A N
Issue Date: XX/XX/XX Att1-2 

N/A 11/02/06 

CN 06-033 

Revised definition of performance deficiency to bring the definition in 

alignment with the basis for performance deficiency as described in ROP basis document, IMC-0308 attachment 3, ASignificance Determination Process Basis Document.@

YES 09/06/2006 M

N/A 09/20/07 

CN 07-029 

Revised flow chart and Section 3 guidance to address feedback forms. Corrected formatting error on page B-7. 

NO N/A N