NRC Generic Letter 84-01, NRC Use Of The Terms "Important To Safety" and "Safety Related"

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JANUARY 5, 1984

TO ALL HOLDERS OF OPERATING LICENSES, APPLICANTS FOR OPERATING LICENSES AND HOLDERS OF CONSTRUCTION PERMITS FOR POWER REACTORS

Gentlemen:

Subject: NRC use of the terms, "Important to Safety" and "Safety Related" (Generic letter 84-01)

As you may know, there has been concern expressed recently by the utility classification group over NRC use of the terms "important to safety" and "safety-related." The concern appears to be principally derived from recent licensing cases in which the meaning of the terms in regard to NRC quality assurance requirements has been at issue, and from a memorandum from the Director, Office of Nuclear Reactor Regulation, to NRR personnel dated November 20, 1981.

Enclosed for your information are two letters to the NRC from this group, and the NRC response dated December 19, 1983. In particular, you should note that the NRC reply makes it very clear that NRC regulatory jurisdiction involving a safety matter is not controlled by the use of terms such as "safety-related" and "important to safety," and our conclusion that pur-

suant to our regulations, nuclear power plant permittees or licensees are responsible for developing and implementing quality assurance programs for plant design and construction or for plant operation which meet the more general requirements of General Design Criterion for plant equipment "important to safety," and the more prescriptive requirements of Appendix B to 10 CFR part 50 for "safety-related" plant equipment.

While previous staff licensing reviews were not specifically directed towards determining whether, in fact permittees, or licensees have developed quality assurance programs which adequately address all structures, systems and components important to safety, this was not because of any concern over the lack of regulatory requirements for this class of equipment. Rather, our practice was based upon the staff view that normal industry practice is generally acceptable for most equipment not covered by Appendix B within this class. Nevertheless, in specific situations in the past where we have found that quality assurance requirements beyond normal industry practice were needed for equipment "important to safety," we have not hesitated in imposing additional requirements commensurate with the importance to safety of the equipment involved. We intend to continue that practice.

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The NRC staff is interested in your comments and views on whether further guidance is needed related to this issue. If you are interested in participating in a meeting with NRC to discuss this subject please contact Mr. James M. Taylor, Deputy Director, Office of Inspection and Enforcement.

Sincerely,

Darrell G. Eisenhut, Director Division of Licensing

Enclosure:

1. Two Letters from Utility Safety Classification Group
2. NRC Response dated December 19, 1983