Nuclear engineer Pissed No Clear Definition of "Important To Safety"?

He is complaining to the NRC. Why did it take so long?

From: Kurt Schaefer

To: Rule making Comments Resource

Subject: [External_Sender] Request for Rule Making - Defining “Important to Safety”

Date: Monday, July 20, 2015 4:07:25 AM

Attachments: Request for Rule Making.pdf

Office of the Secretary;

I have been performing nuclear power plant (NPP) licensing since in 1980, and have never met two people that agree about what nonsafety-related structures, systems and components (SSCs) should be categorized as "important to safety." That is because there is only a general description of what is "important to safety" in 10 CFR 50 Appendix A, and the regulations do not provide a specific set of criteria for determining which SSCs are "important to safety."

The term “important to safety” is used in numerous regulations and NRC guidance documents. In addition, one of the regulations most used at NPPs, 10 CFR 50.59, has used and after a number of revisions still uses that term for evaluating changes to determine if a license amendment is required before making a change. Therefore, there are regulations, regulatory guidance and routinely generated regulatory evaluations, based on SSCs with no specific criteria that determines what are the applicable SSCs.

Since 1984, there have been differences of opinion on what SSCs are “important to safety.” The nuclear industry is on its third generation of engineers and regulators with no clear definition of what is “important to safety.” At this point, there is no excuse for not having a concise set of functional criteria defining such a used term. The attachment provides a request for rule making to define (i.e., provide criteria for determining) "important to safety."
Regard;
--
Kurt Schaefer

Principal Licensing Engineer

ktschaefer@gmail.com

P.S. I am currently working in Korea, and my cell phone does not function here.

Therefore, please contact me by email.