NRC use of the terms, "Important to Safety" and "Safety Related" (Generic Letter No. 84-01)

                                UNITED STATES
                       NUCLEAR REGULATORY COMMISSION 
                           WASHINGTON, D.C. 20555 

                              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. 


8401050382 

                                     -2- 

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