Regulatory Effectiveness Assessment of Generic Issue 43 and Generic Letter 88-14 (NUREG-1837)
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Manuscript Completed: September 2005
Date Published: October 2005
J.V. Kauffman, NRC Project Manager
Division of Systems Analysis and Regulatory Effectiveness
Office of Nuclear Regulatory Research
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
This report documents an assessment of Generic Issue 43, "Contamination of Instrument Air Lines," and Generic Letter 88-14, "Instrument Air Supply System Problems Affecting Safety-Related Equipment." This assessment is part of an ongoing initiative through which the U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Regulatory Research, is reviewing selected agency regulations and decisions to determine whether they are achieving the desired results. For this assessment, the staff compared expectations with outcomes. Whenever outcomes fell short of expectations, the staff attempted to identify ways to enhance the effectiveness, efficiency, and realism of the NRC's regulatory process.
On the basis of its assessment, the staff concluded that licensee and agency activities, such as the Maintenance Rule, Generic Letter 88-14, design-basis reconstitution, and others, have significantly improved air system and component performance and, thereby, resulted in improved reactor safety. Moreover, issuance of Generic Letter 88-14 and targeted NRC inspections led to the identification and resolution of air system design issues impacting safety-related systems and components, again resulting in improved reactor safety. As a result, based on data for pressurized-water reactors, major losses of instrument air are now infrequent, and prompt recovery from such losses is typical, which supports the staff's conclusion that reactor safety has improved. In addition, as evidenced by the ongoing discovery and correction of air system issues, licensee programs and NRC oversight activities provide assurance that the NRC and its licensees are effectively maintaining reactor safety in this area.