NEI 09-14 [Rev 1] 

GUIDELINE FOR THE 

MANAGEMENT 

OF UNDERGROUND 

PIPING AND TANK 

INTEGRITY 

December 2010 

Nuclear Energy Institute, 1776 I Street N. W., Suite 400, Washington D.C. (202.739.8000) 

NEI 09-14 [Rev 1] 

Nuclear Energy Institute 

Guideline for the 

Management of 

Underground Piping and 

Tank Integrity 

December 2010 

Nuclear Energy Institute, 1776 I Street N. W., Suite 400, Washington D.C. (202.739.8000) 

ACKNOWLEDGEMENTS

NEI appreciates the efforts of the members of the NEI Buried Piping Integrity Working Group 

and Task Force, EPRI’s Equipment Reliability Action Plan Committee, and the EPRI Balance of 

Plant Corrosion Integration Committee for their support and direct participation in the 

development of this guideline. 

Nuclear Energy Institute, 1776 I Street N. W., Suite 400, Washington D.C. (202.739.8000) 

REVISION SUMMARY

Revision Description of Changes 

0 Initial issue 

1 Extensive revision. Most significant changes: 

Included text and intent of the Underground Piping and Tank Integrity Initiative 

Included “shall” statements to designate expectations that must be met or 

deviations from them justified 

Added “Definitions” (Section 4) 

Added an expectation that significant inspection findings and new operating 

experience related to underground piping and tanks be communicated to NEI 

(Section 5.1) 

Expanded the explanation of the intent of the Initiative and included 

clarifications of the Initiative scope (Section 6) 

Expanded guidance for justifying deviations from the Initiative (Section 6.2.6) 

Added Appendix B, a summary of the Initiative requirements in NEI 09-14 

NOTICE

Neither NEI, nor any of its employees, members, supporting organizations, contractors, or 

consultants make any warranty, expressed or implied, or assume any legal responsibility for the 

accuracy or completeness of, or assume any liability for damages resulting from any use of, any 

information apparatus, methods, or process disclosed in this report or that such may not 

infringe privately owned rights. 

TABLE OF CONTENTS

1 BACKGROUND ........................................................................................................... 1

2 INTRODUCTION .......................................................................................................... 3

3 INDUSTRY INITIATIVE ON UNDERGROUND PIPING AND TANK INTEGRITY ............. 5

3.1 SCOPE ..........................................................................................................................5

3.2 INITIATIVE GOAL ...........................................................................................................5

3.3 INITIATIVE ACTIONS ......................................................................................................6

3.4 EXPECTATIONS ...............................................................................................................8

3.5 REQUIREMENTS ..............................................................................................................9

4 DEFINITIONS ............................................................................................................ 10

4.1 ACCESSIBLE ..................................................................................................................10

4.2 ADVERSE INSPECTION FINDINGS .................................................................................10

4.3 BELOW GRADE ..............................................................................................................10

4.4 BURIED PIPING .............................................................................................................10

4.5 ENVIRONMENTALLY HAZARDOUS MATERIALS ..........................................................10

4.6 FAILURE ........................................................................................................................10

4.7 FLUIDS ........................................................................................................................10

4.8 LICENSED MATERIAL ....................................................................................................10

4.9 OUTSIDE OF A BUILDING ..............................................................................................11

4.10 PIPING SEGMENT ..........................................................................................................11

4.11 PRIORITIZATION ...........................................................................................................11

4.12 RUN TO FAILURE ..........................................................................................................11

4.13 SAFETY RELATED .........................................................................................................11

4.14 SIGNIFICANT LEAKAGE ................................................................................................11

4.15 TANK ........................................................................................................................12

4.16 TUNNEL ........................................................................................................................12

4.17 UNDERGROUND TANK ..................................................................................................12

4.18 UNDERGROUND PIPING ................................................................................................12

4.19 VAULT ........................................................................................................................12

5 INDUSTRY ROLES AND RESPONSIBILITIES ........................................................... 13

iii
iv

5.1 UTILITIES ......................................................................................................................13

5.2 EPRI ........................................................................................................................14

5.3 INPO ........................................................................................................................14

5.4 ANI ........................................................................................................................14

5.5 NEI ........................................................................................................................15

6 INTENT OF THE UNDERGROUND PIPING AND TANKS INTEGRITY INITIATIVE ....... 16

6.1 UNDERGROUND PIPING AND TANKS INTEGRITY INITIATIVE SCOPE ...........................16

6.2 UNDERGROUND PIPING AND TANKS INTEGRITY INITIATIVE IMPLEMENTATION .......17

6.2.1 Procedures and Oversight ............................................................................18

6.2.2 Risk Ranking .................................................................................................18

6.2.3 Inspection Plan ..............................................................................................19

6.2.4 Plan Implementation ....................................................................................20

6.2.5 Asset Management Plan ...............................................................................21

6.2.6 Procedure and oversight ..............................................................................23

6.2.7 Prioritization .................................................................................................24

6.2.8 Condition Assessment Plan ..........................................................................25

6.2.9 Plan Implementation ....................................................................................25

6.2.10 Asset Management Plan ...............................................................................26

7 REFERENCES ........................................................................................................... 27

APPENDIX A REPORT TO NSIAC .................................................................................... A-1

APPENDIX B NEI 09-14 REQUIREMENTS ...................................................................... B-1
NEI 09-14 (Rev 1) 

December 2010 

GUIDELINE FOR THE MANAGEMENT

OF UNDERGROUND PIPING AND TANK INTEGRITY

1 BACKGROUND 

This Guideline for the Management of Underground Piping and Tank Integrity describes the 

policy and practices that the industry commits to follow in managing underground piping and 

tanks. The Underground Piping and Tanks Integrity Initiative supersedes the Buried Piping 

Integrity Initiative; it incorporates all of its elements and adds additional scope and milestones. 

The Buried Piping Integrity Initiative was approved by NSIAC (Nuclear Strategic Issues 

Advisory Committee) in November 2009. When the Buried Piping Integrity Initiative was 

approved, the scope was limited to piping that was in direct contact with the soil due to the 

inability to directly inspect this piping and due to the potential impact on the environment and 

public confidence if leakage occurred. However additional operating experience has shown that 

piping that is below grade and is not in direct contact with the soil and underground tanks can 

also degrade with potential adverse consequences. As a result, the Underground Piping and 

Tanks Integrity Initiative was developed to incorporate and expand upon the Buried Piping 

Integrity Initiative: its scope also includes selected underground piping that is not in direct 

contact with the soil and specified underground tanks. The key milestone implementation dates 

in the Underground Piping and Tanks Integrity Initiative were established to reflect the added 

initiative scope and its effect on the station resources that will be required to add these items into 

existing programs. The Underground Piping and Tanks Integrity Initiative was approved by 

NSIAC in September 2010. 

Utility implementation of the Initiative will be verified as directed by the NSIAC. 

This guideline contains the following information: 

The text and scope of the Underground Piping and Tanks Integrity Initiative (the 

“Initiative”). 

The goals that drive the Initiative. 

Key definitions. 

Roles and responsibilities established to ensure implementation of the Initiative. 

Explanation of the intent of the Initiative.

Insights for effective and consistent implementation within the industry.

The content of the report to NSIAC on progress of implementing the Initiative.

The approach to addressing underground piping and tank issues embodied in this Initiative 

compliments the expectations in place under the Ground Water Protection Initiative, which 

was approved by NSIAC in 2006 and which remains in effect (guidance on implementation 

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December 2010 

2

of the Ground Water Protection Initiative is provided in NEI 07-07, Industry Ground Water 

Protection Initiative, Final Guidance Document (Reference 3). The Underground Piping and 

Tanks Integrity Initiative focus is on assessing in-scope components in order to provide 

reasonable assurance of their continued structural and leakage integrity with special emphasis 

on licensed materials. The focus of the Ground Water Protection Initiative (GPI) is on 

improving the management of situations involving inadvertent radiological releases that get 

into ground water and the communications with external stakeholders about those events.

Integral to the Ground Water Protection Initiative is an evaluation of the potential for 

unintended leaks of licensed materials resulting from work activities and components that 

contain or could contain licensed material, including some components that are within the 

Underground Piping and Tanks Integrity Initiative scoping. In addition, under the GPI, early 

detection measures are established. If licensed material is detected by early detection 

measures, plant personnel are expected to appropriately investigate, remediate and 

communicate with external stakeholders. Utilities should establish governance to ensure that 

the activities under the two Initiatives are communicated and coordinated.
NEI 09-14 (Rev 1) 

December 2010 

2 INTRODUCTION 

Underground piping and tanks are used in several applications at plants with different governing 

requirements: 

safety related pipe and tanks 

o governed by plant Technical Specifications and ASME Code,

non-safety related pipe and tanks containing licensed material in liquids or gases 

o governed by NRC regulations and within the scope of NEI’s Ground Water 

Protection Initiative 

other pipes and tanks in non-safety related systems containing water, fuel oils, gases or 

other media 

o may be governed by local, State and EPA regulations.

The material condition of underground piping and tanks may not be fully characterized, and one 

of the means of protecting buried components, cathodic protection, may not have been properly 

maintained at some stations. In recent years, some self revealing leaks have occurred that could 

impact public confidence, regulatory margin, and, in some cases, plant operation. Additional 

impacts that could occur if performance is not improved could be: 

safety and operational challenges 

environmental impacts 

increased regulatory requirements for new and existing plants 

EPA violations with stakeholder or media interest 

license renewal delays 

heightened public opposition to new plant construction 

As noted in the executive endorsement of this initiative, the leaders in the nuclear industry 

recognize that additional industry action directed at assessing the condition of underground 

piping and tanks within the nuclear fleet is warranted. Implementation of an assessment program 

for underground piping and tanks is designed to limit the potential for unintended leaks or 

integrity breaches. The industry’s goal is to proactively address the integrity of underground 

piping and tanks and where possible, prevent leakage before it occurs using available 

technologies and other control and evaluative processes. To assure consistent and measured 

progress in this area an NSIAC Initiative addressing underground piping and tank integrity was 

approved to commit commercial nuclear power plants to specific program elements. The scope 

of the Underground Piping and Tanks Integrity Initiative includes selected piping and tanks on 

the site that are below grade and outside of buildings.

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December 2010 

4

The EPRI Document “Recommendations for an Effective Program to Control the Degradation of 

Buried Pipe” (Reference 1) provides important additional considerations for successful 

implementation of the buried piping aspect of the Initiative.

NSIAC provides oversight of industry implementation of the Underground Piping and Tanks 

Integrity Initiative. Periodic reports will be prepared for NSIAC addressing: 

Progress on implementation of the elements of this initiative and any deviations. 

Industry experience and lessons learned. 

Progress of technology development. 

Specific guidance on the periodic report is included in Appendix A.
NEI 09-14 (Rev 1) 

December 2010 

3 INDUSTRY INITIATIVE ON UNDERGROUND PIPING AND TANK 

INTEGRITY 

The Buried Piping Integrity Initiative was approved by NSIAC in November 2009. An 

extension of the Buried Piping Integrity Initiative that addresses selected underground piping and 

tanks was approved in September, 2010. The revised Initiative is known as the Underground 

Piping and Tanks Integrity Initiative.

The expected actions and milestone dates relevant to a given component depend upon whether 

the component was in the original scope of the Buried Piping Integrity Initiative or in the scope 

of the revised and renamed Underground Piping and Tanks Integrity Initiative.

3.1 SCOPE

The scope of the Underground Piping and Tanks Integrity Initiative includes the following. 

A. Those within the scope of the original Buried Piping Integrity Initiative: 

All piping that is below grade and

o Contains any fluid and 

o Is in direct contact with the soil 

B. And the following additional components: 

Underground piping and tanks that are outside of a building and below grade (whether or 

not they are in direct contact with the soil) if they 

o Are safety related 

- Or - 

o Contain licensed material or are known to be contaminated with licensed material. 

3.2 INITIATIVE GOAL

The goal of the Underground Piping and Tanks Integrity Initiative is to provide reasonable 

assurance of structural and leakage integrity of in-scope underground piping and tanks with 

special emphasis on piping and tanks that contain licensed materials. 

The Underground Piping and Tanks Integrity Initiative will: 

Drive proactive assessment and management of the condition of piping and tanks that fall 

within the Initiative scope. 

Ensure sharing of industry experience. 

Drive technology development to improve available techniques for inspecting and 

analyzing underground piping and tanks. 

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December 2010 

Improve regulatory and public confidence in the industry’s management of the material 

condition of its underground tanks and piping systems. 

3.3 INITIATIVE ACTIONS

In order to meet these goals, every utility shall implement measures or program(s) to satisfy the 

elements and associated key attributes in Sections 3.3.A and B. The language in Sections 3.3.A 

and B below documents the text of the Underground Piping and Tanks Initiative as approved by 

NSIAC. 

A. Original Buried Piping Integrity Initiative Elements 

The components governed by the original Buried Piping Integrity Initiative are described in Part 

A of Section 3.1 (Scope). The following elements, attributes, and milestones were established by 

the original Buried Piping Integrity Initiative when it was approved in November 2009. The 

EPRI document “Recommendations for an Effective Program to Control the Degradation of 

Buried Pipe” provides additional details on these elements and attributes. 

Some changes are included in the Initiative description below (as compared to the version 

approved in November 2009) to clarify meaning, but their intent is unchanged and they remain in 

effect under the Underground Piping and Tanks Integrity Initiative.

1. Procedures and Oversight – By June, 30, 2010: 

Ensure clear roles and responsibilities including senior level accountability for the 

Buried Pipe Integrity Program. 

Develop a Buried Pipe Integrity Program document and implementing 

procedures.

2. Risk Ranking – Risk Rank buried piping segments by December 31, 2010. Risk 

Ranking shall incorporate the following attributes: 

Pipe function 

Pipe locations and layout 

Pipe materials and design 

Health of cathodic protection systems, if applicable 

Based on the above data and other information, determine: 

o The likelihood of failure of each piping segment 

o The consequences of failure of each piping segment 

A means to update the risk ranking as necessary 

A database to track key program data, inspection results, and trends 

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December 2010 

3. Inspection Plan – By June 30, 2011, develop an inspection plan to provide reasonable 

assurance of integrity of buried piping. This plan shall include the following key 

attributes:

Identification of piping segments to be inspected 

Potential inspection techniques 

Inspection schedule for buried piping segments based on risk ranking 

Assessment of cathodic protection, if applicable 

4. Plan Implementation – Implementation of the Inspection Plan shall start no later than 

June 30, 2012. The condition assessment of buried piping containing radioactive material 

shall be completed by June 30, 2013.

5. Asset Management Plan – Inspection results shall be used as input to the development 

of an asset management plan for buried piping. This plan shall receive a high level of 

review and approval and will be in place by December 31, 2013. 

B. Underground Piping and Tanks Integrity Initiative Elements 

The components falling within the scope of the Underground Piping and Tanks Integrity 

Initiative are described in Part B of Section 3.1 (Scope). The elements, attributes, and milestones 

described below are established for the additional scope of the Underground Piping and Tanks 

Integrity Initiative. 

1. Procedures and Oversight – By December 31, 2011 

Identify the plant programs or measures that manage the material condition of 

components within the scope of the Underground Piping and Tanks Integrity 

Initiative. 

Establish the necessary controls and implementing process to coordinate the 

applicable programs and measures and ensure they meet the intent of the Initiative. 

Establish clear roles and responsibilities including senior level accountability for 

implementation of the Underground Piping and Tanks Integrity Initiative.

2. Prioritization – Prioritize underground piping and tanks by June 30, 2012. Prioritization 

shall consider the following attributes: 

Function

Locations and layout 

Materials and design 

Process fluid

Health of cathodic protection systems, if applicable 

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December 2010 

Based on the above data and other information, determine: 

o The likelihood of failure of each component 

o The consequences of failure of each component 

A means to update the prioritization scheme as necessary 

Process(es) to allow retrieval of key program data 

3. Condition Assessment Plan(s) – By December 31, 2012 develop or identify existing 

condition assessment plans that will provide reasonable assurance of integrity of components 

within the additional scope of the Underground Piping and Tanks Integrity Initiative. These 

plans shall include the following key attributes: 

Identification of underground piping and tanks to be assessed 

Potential assessment techniques 

Assessment schedules that take into account the relative priority of components. This 

schedule should be coordinated with the schedule developed for the original Buried 

Piping Integrity Initiative to ensure that the components with the highest overall 

priority are addressed first. 

Assessment of cathodic protection, if applicable 

4. Plan Implementation – Implementation of the Condition Assessment Plan for underground 

piping and tanks shall start no later than June 30, 2013. The condition assessment of 

underground piping and tanks containing radioactive material shall be completed by June 

30, 2014.

5. Asset Management Plan – Inspection results shall be used as input to the development of 

asset management plans for components within the scope of the Underground Piping and 

Tanks Integrity Initiative. These plans shall receive a high level of review and approval and 

will be in place by December 31, 2014. 

3.4 EXPECTATIONS

The expected outcome of the Underground Piping and Tanks Integrity Initiative is improved 

regulatory and public confidence in: 

The Industry’s management of the material condition of its underground tanks and piping 

systems and 

The appropriateness of actions taken to establish reasonable assurance of their structural 

and leakage integrity. 

Significant leaks from underground piping and tanks across the industry will be trended as a 

means of determining the Initiative’s affect on the condition of these components. 

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9

In order to meet the goals of the Initiative, every utility should engage in industry 

activities (such as the Buried Piping Integrity Group) that support implementation of the 

Underground Piping and Tanks Integrity Initiative. 

Industry organizations (EPRI, ANI, INPO, and NEI) cooperate in the manner described in this 

guideline and provide the information necessary to prepare periodic updates to NSIAC. 

3.5 REQUIREMENTS

Every utility shall ensure that activities associated with the Underground Piping and 

Tanks Integrity Initiative and this document are implemented at its nuclear power plants 

in accordance with the intent of the Initiative and the implementation dates specified 

therein. Whenever the word “shall” is used in this document it indicates an action that is 

required under the Buried Piping and Tanks Integrity Initiative. If a plant cannot or will 

not implement any part of the Initiative (Sections 3.3.A and B) or a “shall” statement in 

this document, a justification for deviation from the Initiative shall be developed and 

processed in accordance with Sections 6.2.1 and 6.2.6. 

Appendix B captures all the required elements of this document. Users should not rely on this 

appendix alone, but should read the document to ensure that the context of the requirements is 

fully understood. 
NEI 09-14 (Rev 1) 

December 2010 

4 DEFINITIONS 

4.1 ACCESSIBLE

Piping and tanks that can be routinely observed without the required support of special tools or 

other assistance. Activities that would indicate inaccessibility include removal of security 

devices or manways, use of lifting rigs, and performance of excavation, or modification of 

building structures, armored embedments or encasements. 

4.2 ADVERSE INSPECTION FINDINGS

Indications from inspections that require immediate repair or repair within one cycle. 

4.3 BELOW GRADE

Locations below standard ground elevation as defined at the station. 

4.4 BURIED PIPING

Piping that is below grade and in direct contact with the soil. 

4.5 ENVIRONMENTALLY HAZARDOUS MATERIALS

Materials that are subject to EPA or EPA-authorized State regulations or that are specifically 

addressed in a plant’s environmental program(s). 

4.6 FAILURE

Unexpected system leakage or loss of structural integrity of piping or a tank.

4.7 FLUIDS

Fluids include both liquids and gases (including instrument air). 

4.8 LICENSED MATERIAL

Licensed material (from 10 CFR 20.1003) (or licensed radioactive material as used in this 

document) means source material, special nuclear material, or byproduct material received, 

possessed, used, transferred or disposed of under a general or specific license issued by the 

Commission. Components containing licensed material covered under NEI 09-14 should be 

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December 2010 

consistent with those identified in NEI 07-07 (Reference 3) – see the discussion under scope for 

additional clarification. 

4.9 OUTSIDE OF A BUILDING

A component is outside of a building if it is beyond the outside surface of all exterior walls and 

floors in the building.

4.10 PIPING SEGMENT

Portions of buried piping systems that are grouped together for risk ranking purposes based on 

similarities such as installation, manufacture, or environmental conditions. Some risk ranking 

methods may use other terms to refer to piping segments, such as zones. 

4.11 PRIORITIZATION

The process of assigning relative importance of scoped components as determined by a set of 

parameters that reflect design and in situ conditions. The intent of the word “prioritization” as 

used in this document is to imply a process that is less formal than risk ranking. 

4.12 RUN TO FAILURE

A strategy focused on repairing piping or tanks after leakage is discovered as opposed to 

assessing these items over time with the goal of preventing leakage. 

4.13 SAFETY RELATED

Structures, systems, and components that are relied upon to remain functional during and 

following design basis events to ensure the integrity of the reactor coolant pressure boundary, the 

capability to shut down the reactor and maintain it in a safe shutdown condition, or the capability 

to prevent or mitigate the consequences of accidents that could result in potential offsite 

exposure comparable to the guidelines in 10CFR50 section 34(a)(1), 67(b)(2) or 10CFR100.11. 

4.14 SIGNIFICANT LEAKAGE

Leaks which meet any of the following criteria 

Result in concentrations that could exceed the regulatory concentrations or limits 

established by the NRC or EPA, or

Result in voluntary communication under the industry Ground Water Protection 

Initiative, or

Result in the system or component being out of service 

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12

4.15 TANK

A fully enclosed stationary vessel used to hold or store fluids for distribution. Tanks are 

constructed primarily of non-earthen materials (e.g., wood, concrete, steel, or plastic) which 

provide structural support. Tanks do not include basins, ponds or reservoirs. 

4.16 TUNNEL

A structure that is outside of a building, below grade, designed to accommodate personnel, and 

not routinely accessible. 

4.17 UNDERGROUND TANK

All tanks that are outside of buildings and sufficiently below grade such that there is a reasonable 

possibility that leakage from inaccessible portions of the tank may not be detected. Detection 

can be accomplished by direct observation or by instrumentation that is capable of reliably 

detecting leakage before it becomes significant (see definition of Significant Leakage). The 

tanks may be in direct contact with concrete or located in trenches, underground vaults or 

tunnels. Within the context of this Initiative, underground tanks include abandoned tanks 

connected to active systems. (Note that the word “underground” has a different meaning when 

used within the context of the Underground Piping and Tanks Integrity Initiative as compared to 

its meaning when used within the NRC’s Generic Aging Lessons Learned report (GALL, NUREG 

1801). Chapter IX of GALL defines underground as below grade and not in direct contact with 

the soil. NEI 09-14 defines underground as including both components that are buried (in direct 

contact with the soil) plus those that are not indirect contact with the soil.) 

4.18 UNDERGROUND PIPING

All piping that is below grade, not accessible, and outside of buildings. Buried piping (below 

grade and in direct contact with the soil) is considered to be a subset of underground piping.

(Note that the word “underground” has a different meaning when used within the context of the 

Underground Piping and Tanks Integrity Initiative as compared to its meaning when used within 

the NRC’s Generic Aging Lessons Learned report (GALL, NUREG 1801). Chapter IX of GALL 

defines underground as below grade and not in direct contact with the soil.)

4.19 VAULT

A structure that is outside of a building, below grade, not designed to accommodate personnel 

and not routinely accessible.
NEI 09-14 (Rev 1) 

December 2010 

5 INDUSTRY ROLES AND RESPONSIBILITIES 

This guideline will be implemented through the activities outlined below. These activities have 

the following intended purpose: 

Implementing the Underground Piping and Tanks Integrity Initiative 

Supporting the intent of the Initiative

Verifying implementation of the Initiative through maintenance and monitoring of a set 

of metrics described in the report to NSIAC (Appendix A) 

Ensuring that operating experience related to underground piping and tank integrity is 

communicated

Continuing research to identify and develop new techniques for inspection and 

maintenance/replacement of buried piping and tanks 

5.1 UTILITIES

Utilities shall perform the following actions in support of the Initiative: 

Implement the actions required by the Initiative (Section 3.3 and all “shall” statements in 

this document). 

Process a justification for deviation (Section 6.2.6) whenever an action required by the 

Initiative or a “shall” statement in this document cannot be met. 

Report all results from inspections performed in accordance with the Initiative in the 

manner proscribed by the EPRI project manager responsible for the Buried Piping 

Integrity Group. 

Report to NEI the status of meeting the Initiative Implementation dates and any active 

deviations that do not meet the intent of the Initiative as required for the report to NSIAC 

(Appendix A) 

Report to INPO (EPIX) occurrences of leakage or adverse inspection findings in piping, 

and tanks within the scope of this Initiative as required for the report to NSIAC 

(Appendix A) 

In order to meet the intent of the Initiative, utilities should: 

Participate in the industry programs that support the Initiative 

Contribute technical resources and executive leadership to industry efforts 

Communicate questions regarding the intent of the Initiative or the interpretation of this 

guideline to the Buried Piping Integrity Initiative Task Force. If a question relates to the 

text of the Initiative or a “shall” statement in this guideline, task force feedback on the 

questions would typically precede the development of a justification for deviation. 

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Communicate instances of significant leakage or adverse inspection findings of piping 

and tanks within the scope of the Initiative to the NEI and the EPRI Buried Piping 

Integrity Group Project Managers in a timely manner for the purpose of rapid 

dissemination of preliminary operating experience and to request immediate assistance as 

needed. 

5.2 EPRI 

EPRI performs the following functions in support of the Initiative: 

Support the real time assessment of operating experience as reported by utilities. 

Collect underground piping and tank inspection data obtained from utilities and evaluate 

its implications annually. 

Manage the research necessary to improve inspection technology for underground piping 

and tanks 

Support repair/replacement technology as appropriate 

Provide a venue for identifying research and development needs, sharing operating 

experience, and other issues that have the potential for impact on the industry 

Compile and report to NEI the information necessary to make periodic reports to NSIAC 

(Appendix A) on progress in the development of inspection technology 

5.3 INPO

INPO performs the following functions in support of the Initiative: 

Incorporate within their plant evaluations a review of buried/underground piping and tank 

programs as applicable. The review should include piping and tanks that may not be 

safety related but are important to safety or contain potentially radiologically 

contaminated fluids. 

Communicate operating experience relative to underground piping and tank integrity 

issues and other relevant information to the industry. 

Compile and report to NEI the operating experience information necessary to make 

periodic reports to NSIAC (Appendix A). 

5.4 ANI 

ANI performs the following function in support of the Initiative: 

Report significant recommendations from inspections related to underground piping and 

tank integrity and observations on Initiative implementation to NEI in support of the 

periodic report to NSIAC (Appendix A). 

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15

5.5 NEI 

NEI performs the following functions in support of the Initiative: 

Manage the industry’s regulatory interface on underground piping and tank issues of 

generic regulatory significance. 

Manage the operation of the Buried Piping Integrity Working Group and Task Force. 

Task Force responsibilities include: 

o Addressing questions regarding the interpretation of the Initiative 

o Judging whether deviations from Initiative requirements meet the intent of the 

Initiative

o Evaluating important operating experience 

o Evaluating the overall status of Initiative implementation as part of the report to 

NSIAC 

Communicate information relative to the Underground Piping and Tanks Integrity 

Initiative to the industry. 

Compile the information necessary to make periodic reports to NSIAC (Appendix A) on 

implementation of the Initiative. 

Communicate the periodic report to NSIAC on implementation of the Underground 

Piping and Tanks Integrity Initiative, industry operating experience, and inspection 

technology developments (Appendix A). 

Coordinate activities with utilities, EPRI, ANI, and INPO. 
NEI 09-14 (Rev 1) 

December 2010 

6 INTENT OF THE UNDERGROUND PIPING AND TANKS INTEGRITY 

INITIATIVE 

The following sections describe the activities and commitments that implement the Initiative 

actions presented in Section 3.3 of this document. Additional activities may also be necessary as 

industry experience and technology evolves.

Additional information on the intent of the Initiative is provided by EPRI document, 

“Recommendations for an Effective Program to Control the Degradation of Buried Pipe” 

(Reference 1). Although verbatim compliance with the EPRI guideline is not a commitment 

under the Initiative, the EPRI guidance forms the basis for the Initiative and provides additional 

details on the Initiative’s attributes and elements. References to the applicable sections of the 

EPRI document, where applicable, are provided in the descriptions in Section 6.2. 

6.1 UNDERGROUND PIPING AND TANKS INTEGRITY INITIATIVE SCOPE

The following are clarifications and explanations of the intent of the scope of the Initiative: 

In general, the piping and tanks that are subject to the Underground Piping and Tanks 

Integrity Initiative are determined by starting with the total population of utility owned 

piping and tanks within the site boundaries and adjusting this population using the scope 

statement in section 3.1 and the clarifications in this section. This will result in some low 

consequence components such as those associated with water and sewage treatment 

facilities and storm drains to be subject to the Initiative, but the components may not need 

to be inspected if categorized as “run to failure”. 

Abandoned piping and tanks that are drained, not connected to an active system, and that 

are not known to be contaminated with licensed material are not within the scope of the 

Initiative. 

Piping and tanks that are below grade are excluded from the scope of the Initiative if they 

are accessible for direct inspection (see definition of Accessible). 

Portions of piping systems that are contained within building walls or basemats are not 

considered “underground” and are not within the scope of the Initiative.

Underground piping includes buried piping, and piping in vaults, trenches, tunnels, 

beneath buildings, or encased in concrete. 

Piping owned by others that runs inside of the owner controlled area is not within the 

scope of the Initiative. 

If a vault is not accessible from inside a building, piping or tanks within the vault are 

considered outside of the building and within the scope of the Initiative even if the vault 

shares a wall with the building. 

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Owner’s piping located outside of the owner controlled area is not within the scope of the 

Initiative unless it is safety related or contains licensed material. 

Licensed material (from 10 CFR 20.1003) means source material, special nuclear 

material, or byproduct material received, possessed, used, transferred or disposed of 

under a general or specific license issued by the Commission.10 CFR 20.1003 . The term 

“licensed material” as used in this document is intended to be consistent with its meaning 

in the Ground Water Protection Initiative (NEI 07-07, Reference 3, Objective 2.2, Source 

Containing Licensed Material). Consistent with Regulatory Issue Summary RIS 2008-03 

“Return/Re-use of Previously Discharged Licensed Material” “licensed material” as 

applied in the Underground Piping and Tank Integrity Initiative does not include the 

concentration(s) of radioactive material previously released as a controlled, planned 

airborne or liquid radioactive effluent when it is returned to the facility in concentrations 

below the exempt concentration limits in 10 CFR 30. 

6.2 UNDERGROUND PIPING AND TANKS INTEGRITY INITIATIVE IMPLEMENTATION

The goal of the Underground Piping and Tanks Integrity Initiative is to provide reasonable 

assurance of structural and leakage integrity of in-scope underground piping and tanks with 

special emphasis on components that contain licensed materials. The concept of reasonable 

assurance within the context of the Initiative means establishing and maintaining confidence in 

underground piping and tank integrity based on engineering judgment supported by facts, 

actions, knowledge, experience, and/or observations. It defines a level of confidence which is 

deemed to be adequate to support a particular position. 

The approach used to establish reasonable assurance should include leakage prevention by means 

of inspection as a key part of its process. It should be systematic and based on defined programs 

and processes that produce consistent results. The approach should be documented and 

supported by engineering evaluation, governing procedures, and risk ranking. It should be 

continuously validated by the results of examinations and fitness-for-service evaluations, and by 

the experience gained from required repairs and applied mitigation methods. 

Although the Underground Piping and Tanks Integrity Initiative will provide a high level of 

confidence in the integrity of underground piping and tanks, it is not possible to guarantee that 

there will be no leakage or no structural degradation in these components. This initiative is 

intended to reduce the probability and consequences of underground piping and tank issues as 

low as reasonably achievable. 

Some utilities include tanks in the same program as buried piping and some have separate 

programs for tanks. The objective of the Underground Piping and Tanks Integrity Initiative is 

not to dictate a specific approach; rather it is to ensure that by whatever means utilities manage 

these components, the applicable guidance in the programs meet the intent of the Initiative as 

explained in this document. 

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A. Activities within the Buried Piping Integrity Initiative Scope 

6.2.1 Procedures and Oversight 

The necessary governance and oversight responsibilities shall be in place by June 30, 2010. 

These include the procedures and oversight elements in section 3.3 and the following items. 

Clear lines of responsibility

The Buried Piping Integrity Program shall be established including the identification of a 

responsible executive who will carry out the senior level functions specified in the 

Initiative and this guideline. 

Process for justifying and approving exceptions to the Initiative

When a utility determines that a required element of the Initiative cannot be met, a 

technical justification for deviation shall be developed and retained with the utility’s 

program documentation. The technical justification should provide the basis for 

determining that the proposed deviation meets the same objective, or level of 

conservatism exhibited by the original work product, and should clearly state how long 

the deviation will be in effect. Justifications for deviation shall be reviewed and 

approved in accordance with the applicable plant procedures with concurrence from the 

responsible utility executive.

Each utility shall report all approved justifications for deviation that are currently active 

at each of its plants to NEI semi-annually as part of the utility’s input to the NSIAC 

report.

Note that the deviation process has been expanded in revision 1 of NEI 09-14. The entire 

process for justifying deviations is described in Section 6.2.6. The process in Section 

6.2.6 will supersede the process in this section on December 31, 2011. 

Program Documents and Implementing Procedures

A Program Plan and associated procedures shall be developed to implement the 

Underground Piping and Tanks Integrity Initiative. The program documents and 

implementing procedures shall implement, as a minimum, the elements of the 

Underground Piping and Tanks Integrity Initiative (Section 3.3) and requirements in this 

document. Guidance for the specific content of the program document may be obtained 

from Sections 1.4.1 and 1.4.2 in the EPRI document on buried piping, 

“Recommendations for an Effective Program to Control the Degradation of Buried Pipe 

(Reference 1).” 

6.2.2 Risk Ranking 

A risk ranking process shall be used to understand site vulnerabilities and to help prioritize the 

selection of inspection locations. Risk ranking is performed by determining the likelihood of 

failure of each segment of applicable piping and combining that failure probability with the 

consequences of failure of that item. Components with high likelihood of failure and high 

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NEI 09-14 (Rev 1) 

December 2010 

consequences of failure should receive more attention than low ranked components. A 

description of a risk ranking process for buried piping is provided in Reference 1.

Risk Ranking may be performed using software tools; several different software tools are 

available for this application. This guideline does not recommend or discourage any software 

system; but, regardless of the tool that is used, utilities should review the risk ranking results to 

ensure they reflect relative system priorities and are appropriate from an engineering judgment 

perspective.

The risk ranking process shall incorporate the attributes listed in Section 3.3.A.2 of this 

document as augmented by the “shall” statement below as a minimum. 

The risk ranking shall be periodically reviewed and updated as necessary to reflect 

inspection results, changes in operating conditions, and design modifications. 

The initial risk ranking process shall be complete by December 31, 2010. 

The risk ranking process shall determine the likelihood and consequence of failure for each 

piping segment in order to prioritize inspections or other actions and should also consider the 

following:

Soil analysis data, when available to assess the likelihood of OD corrosion 

The potential for ID (fluid-side) corrosion and fouling

The “health” of the cathodic protection system. “Health” should be interpreted in the 

context of whether the system is performing its function as designed. 

Over the line survey results. These results help assess the likelihood of OD corrosion. 

Whether piping and tanks contain fluids with licensed material. The risk ranking process 

should place sufficient priority on these components such that the intent of the Initiative 

is met. 

The results of the Ground Water Protection Initiative risk ranking process. The NEI 

Ground Water Protection Initiative also contains a risk ranking process for systems, 

structures, and components, including underground piping and tanks, containing 

radioactive materials. The results of the Ground Water Protection risk ranking process 

should also be used as an input in inspection plan development. 

6.2.3 Inspection Plan

The goal of the inspection plan is to support an assessment of the pipe’s structural and leakage 

integrity and provide reasonable assurance that a piping segment will maintain this integrity 

between successive inspections. The results of risk ranking along with plant and industry 

experience, plant licensing commitments, and trending of past inspection data should be 

considered to define inspection locations, inspection methods, and inspection schedules (see 

reference 1). Other considerations such as access may also be considered when the relative risk 

rankings are similar. 

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The inspection plan shall incorporate the attributes listed in Section 3.3.A.3 of this document as 

augmented by the “shall” statement below. 

Where buried pipes are protected by a cathodic protection (CP) system, the CP system 

shall be periodically inspected and tested to assess its continued adequacy.

The inspection plan shall be in place by June 30, 2011. 

Development of an inspection plan should consider the following: 

The capabilities of the inspection techniques used 

Industry and internal operating experience

Piping design characteristics 

The condition of the piping inspected (if inspected previously)

The results of risk ranking performed for the Ground Water Protection Initiative 

Contingency plans that include 

o Methods and criteria to assess the significance of inspection results considering 

the damage mechanism and licensing commitments. 

o Repair and replacement options 

Input from a coating specialist 

Whether a CP system should be added to systems containing materials susceptible to 

degradation.

Sampling techniques and engineering evaluations based on known conditions of piping are an 

acceptable means of achieving reasonable assurance. 

6.2.4 Plan Implementation 

Plan implementation should consist of performing a condition assessment based on both 

inspection results and engineering evaluations. The inspections should be conducted at the most 

vulnerable locations determined using methods such as the risk ranking, results of cathodic 

protection and coating surveys, plant experience, etc. The combination of evaluations and 

inspections performed should provide reasonable assurance that the piping segment will maintain 

structural and leakage integrity until the next planned inspection. The inspection results should 

be documented and relevant photographs or video, when taken, should be filed to support 

inspection results. All inspection results (whether degradation exists or not) shall be reported to 

EPRI in the manner proscribed by the Buried Piping Integrity Group project manager. 

Buried piping segments whose failures are inconsequential, and would cause no direct or 

collateral damage (such as potable water), may be considered “run to failure” and dispositioned 

accordingly. Safety related lines and those containing licensed materials should never be 

characterized as “run to failure”. Reference 1 provides more guidance on this categorization. 

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NEI 09-14 (Rev 1) 

December 2010 

Consider benchmarking piping segments characterized as “run to failure” against programs at 

other utilities to check for consistent application. Note that segments categorized as “run to 

failure” are still considered within the scope of the Initiative and leaks and adverse inspection 

findings in these segments shall be reported in accordance with Appendix A.

Implementation of the inspection plan shall start no later than June 30, 2012 and the condition 

assessment of buried piping containing licensed materials shall be completed by June 30, 2013. 

Inspections should consider the following: 

Inspecting the coating when a buried pipe is uncovered 

Performing a visual inspection of buried pipe when it is uncovered or entered for any 

reason in order to look for evidence of corrosion or damage. 

In situations where system operability or functionality is in question due to wall or weld 

degradation, examining the piping to determine remaining thickness. 

Estimating a projection of future damage based on current inspection results and the time 

to the next planned inspection or repair. 

Categorizing the inspection results in support of a remaining life calculation. 

Using the knowledge gained through the inspection and integrity assessment process to 

review and adjust as necessary the risk-informed ranking and the inspection plan. 

The results of condition assessments should be an input to the Asset Management Plan. 

6.2.5 Asset Management Plan 

An asset management plan or plans addressing buried piping shall be developed and maintained. 

An asset management plan is a long range plan for managing the structural and leakage integrity 

of buried piping. Where the risk of failure is unacceptable, preventive and mitigative options 

should be implemented as part of the long range strategy. 

The asset management plan for buried piping may be part of the overall site or fleet asset 

management plan. 

Te asset management plan should be a living document that is periodically reviewed and updated 

as more plant data becomes available through physical assessments and other means and as 

industry knowledge and technology evolve.

The asset management plan shall be reviewed and approved by an appropriate high level 

organization within the utility (such as the plant health committee). 

The Asset Management Plan for buried piping shall be in place by December 31, 2013.

Key elements of an Assessment Management Plan should include: 

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December 2010 

Inspection plans 

Planned maintenance activities 

Plans for repair 

Anticipated replacement 

One method to develop an asset management plan would be to categorize each buried line based 

on its risk rank, contents (licensed material, diesel oil, raw or minimally treated water, hazardous 

chemicals, off gas, etc), importance to power generation, results of cathodic protection testing, 

and coating surveys, plant experience, etc. For example, each line would then be placed into 

categories such as: 

Components to be repaired or replaced with a planned schedule within an implementation 

plan.

Components that need to be periodically inspected or monitored with a planned schedule. 

Components that are acceptable to run to leak and then repaired as needed (e.g., piping 

with low risk or low environmental impact. Plants should also consider public 

confidence concerns in applying this categorization.). 

The plan should consider additional actions for a line such as: 

Inspect to determine the need to repair or replace. 

Add or enhance the cathodic protection. 

Add or enhance coating protection. 

Actions to minimize the degradation of the inner surface of the piping. 

Add protection against heavy surface loads. 

B. Activities within the Underground Piping and Tanks Integrity Initiative 

Scope

The expectations described in Section 6.2.A above (regarding procedures and oversight, risk 

ranking, inspection plans, plan implementation, and asset management) are applicable to the 

components added by the Underground Piping and Tanks Integrity Initiative unless specifically 

stated otherwise below. The following sections (6.2.6 through 6.2.10) explain the intent of the 

Underground Piping and Tanks Initiative and provide additional guidance where appropriate.

Note that the activities and milestones in sections 6.2.6 through 6.2.10 apply only to the 

additional components that were added by the Underground Piping and Tank Integrity Initiative 

when it extended the Buried Piping Integrity Initiative. 

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December 2010 

6.2.6 Procedure and oversight 

Procedure and oversight responsibilities applicable to the Underground Piping and Tanks 

Integrity Initiative, including associated plant programs, shall be revised to include in-scope 

tanks and piping by December 31, 2011. The following steps are one method of approaching 

this process. 

Identify the piping and tanks that fall within the scope added by the Underground Piping 

and Tanks Integrity Initiative. 

Identify the programs or processes in place, or develop new ones if necessary, to manage 

the leakage and structural integrity of these components. 

Develop or amend existing overarching program or process documents to ensure that all 

the relevant programs are associated with the Underground Piping and Tanks Integrity 

Initiative and coordinated to control changes so that Initiative intent is managed and not 

inadvertently compromised. 

Identify roles and responsibilities for the new program/process 

Develop a process for justifying any deviations to the Initiative elements documented in 

this guideline. Ensure the process meets the intent of Section A.6.2.1 and this section. 

Procedures and oversight shall incorporate the attributes listed in Section 3.3.B.1 plus the “shall” 

statements in the following paragraphs. 

Process for obtaining review of Initiative and NEI 09-14 interpretations

Questions regarding the intent of the Initiative or the guidance in this document should be 

communicated to NEI for review by the Buried Piping Integrity Task Force. The task 

force will reply to the questioner in a timely manner. The task force will also 

communicate interpretations of significant generic applicability to the industry as a 

means of facilitating consistent implementation of the Initiative. 

If a utility proceeds with an activity that does not meet the language of the Initiative or a 

“shall” statement in this document, a justification for deviation shall be processed in 

accordance with the remainder of this section. Note that a deviation may still meet the 

intent of the Initiative (see below) even if it does not meet the exact language of the 

Initiative. For example, it may be possible to risk rank buried piping without addressing 

every parameter in Section 3.3.A.2. 

Process for justifying and approving exceptions to the Initiative

When a utility determines that a required element of the Initiative or a “shall” statement 

in this document will not or cannot be met, a justification for deviation shall be developed 

and retained with the utility’s corrective action program. If a utility finds itself outside of 

a required Initiative element and takes immediate action to meet the element, a deviation 

justification is not required, but the condition should be entered into the corrective action 

program and the Buried Piping Integrity Task Force should be notified. Required 

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December 2010 

elements of the Initiative include the entire text of the Initiative (Sections 3.3.A and 

3.3.B) and all “shall” statements in this document (summarized in Appendix B). 

The justification shall provide the basis for determining that the proposed deviation meets 

the same objective, or level of conservatism exhibited by the original requirement, and 

should clearly state how long the deviation will be in effect. Justifications for deviation 

shall be approved by the responsible utility executive.

To maintain the integrity of the deviation process and ensure a consistent approach to 

guideline implementation (or inability to implement), it is important for utilities to share 

deviations with the industry in an open and timely manner. Timely notification of 

deviations allows the industry to systematically review the issue for potential generic 

implications and take appropriate actions to facilitate consistent and appropriate 

implementation of guidance. The following guidance applies: 

Approved deviations shall be sent to NEI in a timely manner for review by the 

Buried Piping Integrity Task Force (BPITF). 

o The BPITF review is not an independent review or an approval. Their 

assessment is based on engineering judgment and experience. 

The BPITF will review the justification for deviation for the following items. 

o Effect on guidance. 

o Whether the deviation meets the intent of the Initiative. 

o Generic applicability. 

Generically applicable information relative to the justifications will be 

communicated to the industry. 

When the BPITF finds that the deviation does not meet the intent of the Initiative, 

the applicable utility and the Buried Piping Integrity Working Group will be 

informed. Semi-annually each utility shall report to NEI all active justifications 

for deviation at each of its plants that are judged to not meet the intent of the 

Initiative. This report is made as part of the utility’s input to the NSIAC report 

(Appendix A).

If the BPITF finds that the deviation does meet the intent of the Initiative, the 

utility will be informed but the deviation will not be reported to NSIAC. The 

justification should be retained with utility program documentation. 

All requirements described in Section A. 6.2.1 are relevant to this section of the Underground 

Piping and Tanks Integrity Initiative except for implementation schedules. 

6.2.7 Prioritization 

The risk ranking process for buried piping will have been established as part of the Buried Piping 

Integrity Initiative. This process may not be able to incorporate underground piping or tanks 

because of the different parameters of concern. The process of risk ranking is referred to as 

“prioritization” within the Underground Piping and Tanks Integrity Initiative in recognition of 

this situation and the possibility that a risk ranking tool may not be in place when utilities start 

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December 2010 

the process. Greater use of engineering judgment is expected in the development of 

prioritization results.

Prioritization shall incorporate the attributes listed in Section 3.3.B.2. Attributes that should also 

be considered when prioritizing components include: 

Age

Relevant industry operating experience 

Piping flow rate 

Tank volume 

Contents

Soil condition and chemistry 

Plant operating history 

Leakage history 

Internal corrosion consideration (such as flow accelerated corrosion for piping only, and 

microbiologically induced corrosion) 

Coating and lining 

Wet or alternately dry 

Prioritization should be adjusted as appropriate to apply engineering judgment to the results. 

All requirements described in Section A. 6.2.2 are relevant to the Underground Piping and Tanks 

Integrity Initiative, except for implementation schedules. Prioritization of components that fall 

within the scope of the Underground Piping and Tanks Integrity Initiative shall be complete by 

June 30, 2012. 

6.2.8 Condition Assessment Plan 

The results of prioritization along with plant and industry experience, plant licensing 

commitments, and trending of past inspection data should be used to define inspection locations, 

inspection methods, and inspection schedules. Condition assessment plans shall incorporate the 

attributes listed in Section 3.3.B.3. The Condition Assessment Plan shall be in place by 

December 31, 2012. All requirements described in Section A. 6.2.3 are relevant to the 

Underground Piping and Tanks Integrity Initiative, except for implementation schedules. 

6.2.9 Plan Implementation 

Implementation of the Condition Assessment plan for components included within the scope 

added by the Underground Piping and Tanks Integrity Initiative shall start no later than June 30, 

2013. The condition assessment of underground piping and tanks containing licensed material 

shall be completed by June 30, 2014.

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26

After prioritization is performed, the inspection process should address all piping and tanks 

within the scope of both the initial Buried Piping Integrity Initiative and the Underground Piping 

and Tanks Integrity Initiative in order to ensure the relative importance of the components are 

recognized and the more important components are inspected first when possible. 

All requirements described in Section A. 6.2.4 are relevant to the Underground Piping and Tanks 

Integrity Initiative, except for implementation schedules. 

6.2.10 Asset Management Plan 

The Asset Management Plan for underground piping and tanks shall be in place by December 31, 

2014. All requirements described in Section A. 6.2.5 are relevant to the Underground Piping and 

Tanks Integrity Initiative, except for implementation schedule. 
NEI 09-14 (Rev 1) 

December 2010 

7 REFERENCES 

1. EPRI document, Recommendations for an Effective Program to Control the Degradation 

of Buried Pipe , December 2008 

2. NACE (National Association of Corrosion Engineers) documents 

a. SP0502-2008 (formerly RP0502), Pipeline External Corrosion Direct Assessment 

Methodology

b. SP0169-2007 (formerly RP0169), Control of External Corrosion on Underground 

or Submerged Metallic Piping Systems

c. RP0102-2002, In-Line Inspection of Pipelines

d. SP0207-2007, Performing Close-Interval Potential Surveys and DC Surface 

Potential Gradient Surveys on Buried or Submerged Metallic Pipelines

e. RP0288, "Standard Recommended Practice: Inspection of Linings on Steel and 

Concrete Tanks"

3. NEI 07-07, Industry Ground Water Protection Initiative – Final Guidance Document, 

August 2007

4. INPO 98-001, Equipment Performance and Information Exchange System (EPIX) 

Reporting Requirements 

5. NUREG 1801, Volume 2 Section X1.M34, Generic Aging Lessons Learned (GALL) 

Report, Buried Piping and Tanks Inspection 

6. ASTM G 158, "Standard Guide for Three Methods of Assessing Buried Steel Tanks"

7. ASTM E 1990, "Standard Guide for Performing Evaluations of Underground Storage 

Tank Systems for Operational Conformance with 40 CFR, Part 280 Regulations"

8. NLPA Standard 631, "Entry, Cleaning, Interior Inspection, Repair, and Lining of 

Underground Storage Tanks"

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NEI 09-14 (Rev 1) 

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APPENDIX A 

REPORT TO NSIAC 

REPORT CONTENT

A report to NSIAC will be prepared semi-annually addressing the following four items: 

1. Overview – developed by NEI semi-annually on the following topics as appropriate:

o Notable information: 

Incidents that attract media or industry stakeholder attention

INPO feedback from plant evaluations 

Important ANI feedback from plant evaluations 

Major piping or tank replacements and repairs as determined by NEI 

Buried Piping Integrity Task Force. Examples are major piping 

improvement projects where portions of service water systems were 

replaced with high density polyethylene piping or 6% molybdenum 

stainless steel) 

o Assessment of availability of technology to support inspections 

o Overall status of Initiative implementation, including the effect of active approved 

deviations to Initiative elements. 

2. Progress on Initiative implementation and exceptions – utilities will report to NEI the 

status of implementation of each Initiative element at each of their plants using the 

approach described below. The report will be made semiannually (by January 31 and 

July 31) to NEI. NEI will collect and assemble the information. 

o Report implementation status for each Initiative element and for each plant. The 

elements and the expected implementation dates are repeated below: 

Buried piping procedures and oversight in place by 6/30/10 

Buried piping risk ranking complete by 12/31/10 

Buried piping inspection plan in place by 6/30/11

Underground piping and tanks procedures and oversight in place by 

12/31/11

Buried piping inspection start by 6/30/12 

Underground piping and tanks prioritization complete by 6/30/12 

Underground piping and tanks condition assessment plan in place by 

12/31/12

Condition assessment of buried piping containing radioactive materials 

complete by 6/30/13 

Underground piping and tanks inspection start by 6/30/13 

Buried piping asset management plan in place by 12/31/13 

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NEI 09-14 (Rev 1) 

December 2010 

Condition assessment of underground piping and tanks containing 

radioactive materials complete by 6/30/14 

Underground piping and tanks asset management plan in place by 

12/31/14

o Document the status for each implementation date as follows: 

Will extend the implementation date or have extended 

Implementation by the due date is at risk 

On schedule to meet date 

Complete 

o Describe each active deviation that does not meet the intent of the Underground 

Piping and Tanks Integrity Initiative . Note that the existence of an approved 

deviation to an implementation date does not change the fact that the date will not 

be met. If an implementation date is not going to be met, it shall be reported as 

such until the implementation is completed. 

3. Industry experience and learning – Utilities will report the information below to INPO. 

INPO will collect the information and report the results to NEI. 

o Utilities will enter operating experience related to the items below into the INPO 

EPIX database when instances occur. Entries should be made in a timeframe 

consistent with EPIX timing requirements (Reference 4). 

Every leak from underground piping and tanks within the scope of this 

Initiative 

Significant leaks from underground piping and tanks that are within the 

scope of this Initiative: Significant leaks are defined as those which meet 

either of the following criteria 

- Result in concentrations that could exceed the regulatory 

concentrations or limits established by the NRC or EPA., or

- Result in voluntary communication under the industry Ground 

Water Protection Initiative, or

- Result in the system or component being out of service 

Adverse inspection findings: defined as indications from inspections that 

require immediate repair or repair within one cycle 

o Each instance will be categorized into one of the following five areas depending 

upon the piping segment or tank affected (where more than one area applies, use 

the one that appears highest in the list below). 

Safety related 

Contains licensed material 

Contains environmentally hazardous fluids (e.g., oils, chemicals, nonradioactive fluids)

Components categorized as not “run to failure” 

Components categorized as “run to failure” 

4. Progress on inspection technology development – EPRI will assemble the information 

below and report the results to NEI. 

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A-3

o Identify each technology that is being researched for possible use in inspections

o Describe the development and implementation status of each identified inspection 

technology.

GENERAL

Information on leakage from applicable buried/underground piping and tanks using the above 

criteria will be collected beginning for events that occurred in 2009. Information on Initiative 

implementation and inspection technology will be collected beginning in 2010. 

Information will be collected from utilities, INPO, ANI, and EPRI and sent to NEI semiannually. NEI will assemble a report for Buried Piping Integrity Task Force review and 

assessment. The objective is to: 

Prepare an NSIAC presentation. 

Share implementation status and operating experience with the industry as appropriate. 

NEI 09-14 (Rev 1) 

December 2010 

APPENDIX B 

NEI 09-14 REQUIREMENTS 

Section Requirement

3.3 In order to meet these goals, every utility shall implement measures or program(s) to 

satisfy the elements and associated key attributes in Sections 3.3.A and B. The 

language in sections 3.3.A and B below documents the text of the Underground 

Piping and Tanks Initiative as approved by NSIAC... 

Note that the entire text of sections 3.3.A.1 thru 3.3.A.5 and 3.3.B.1 thru 

3.3.B.10 is a requirement under the Underground Piping and Tanks 

Integrity Initiative since these sections constitute the text of the Initiative 

as approved by NSIAC. In the interest of brevity, the text from these 

sections is not captured in this table.

3.5 Every utility shall ensure that activities associated with the Underground Piping and 

Tanks Integrity Initiative and this document are implemented at its nuclear power 

plants in accordance with the intent of the Initiative and the implementation dates 

specified therein. 

3.5 If a plant cannot or will not implement any part of the Initiative (Sections 3.3.A and 

B) or a “shall” statement in this document, a justification for deviation from the 

Initiative shall be developed and processed in accordance with Section 6.1. 

5.1 Utilities shall perform the following actions in support of the Initiative: 

Implement the actions required by the Initiative (Section 3.3 and all “shall” 

statements in this document). 

Process a justification for deviation (Section 6.1.1) whenever an action 

required by the Initiative or a “shall” statement in this document cannot be 

met. 

Report all results from inspections performed in accordance with the Initiative 

in the manner proscribed by the EPRI project manager responsible for the 

Buried Piping Integrity Group. 

Report to NEI the status of meeting the Initiative Implementation dates and 

any active deviations that do not meet the intent of the Initiative as required 

for the report to NSIAC (Appendix A) 

Report to INPO (EPIX) occurrences of leakage or adverse inspection findings 

in piping, and tanks within the scope of this Initiative as required for the 

report to NSIAC (Appendix A) 

6.2.1 The necessary governance and oversight responsibilities shall be in place by June 30, 

2010.

6.2.1 The Buried Piping Integrity Program shall be established including the identification 

of a responsible executive who will carry out the senior level functions specified in 

the Initiative and this guideline. 

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NEI 09-14 (Rev 1) 

December 2010 

Section Requirement

6.2.1 When a utility determines that a required element of the Initiative cannot be met, a 

technical justification for deviation shall be developed and retained with the utility’s 

program documentation. 

6.2.1 Justifications for deviation shall be reviewed and approved in accordance with the 

applicable plant procedures with concurrence from the responsible utility executive. 

6.2.1 Each utility shall report all approved justifications for deviation that are currently 

active at each of its plants to NEI semi-annually as part of the utility’s input to the 

NSIAC report. 

6.2.1 A Program Plan and associated procedures shall be developed to implement the 

Underground Piping and Tanks Integrity Initiative. 

6.2.1 The program documents and implementing procedures shall implement, as a 

minimum, the elements of the Underground Piping and Tanks Integrity Initiative 

(Section 3.3) and requirements in this document. 

6.2.2 A risk ranking process shall be used to understand site vulnerabilities and to help 

prioritize the selection of inspection locations. 

6.2.2 The risk ranking process shall incorporate the attributes listed in Section 3.3.A.2 of 

this document as augmented by the “shall” statement below as a minimum. 

The risk ranking shall be periodically reviewed and updated as necessary to 

reflect inspection results, changes in operating conditions, and design 

modifications.

6.2.2 The initial risk ranking process shall be complete by December 31, 2010. 

6.2.2 The risk ranking process shall determine the likelihood and consequence of failure 

for each piping segment in order to prioritize inspections or other actions 

6.2.3 The inspection plan shall incorporate the attributes listed in Section 3.3.A.3 of this 

document as augmented by the “shall” statement below. 

Where buried pipes are protected by a cathodic protection (CP) system, the 

CP system shall be periodically inspected and tested to assess its continued 

adequacy. 

6.2.3 The inspection plan shall be in place by June 30, 2011. 

6.2.4 Note that segments categorized as “run to failure” are still considered within the 

scope of the Initiative and leaks and adverse inspection findings in these segments 

shall be reported in accordance with Appendix A. 

6.2.4 All inspection results (whether degradation exists or not) shall be reported to EPRI in 

the manner proscribed by the Buried Piping Integrity Group project manager. 

6.2.4 Implementation of the inspection plan shall start no later than June 30, 2012 and the 

condition assessment of buried piping containing licensed materials shall be 

completed by June 30, 2013. 

6.2.5 An asset management plan or plans addressing buried piping shall be developed and 

maintained. 

6.2.5 The asset management plan shall be reviewed and approved by an appropriate high 

level organization within the utility (such as the plant health committee). 

6.2.5 The Asset Management Plan for buried piping shall be in place by December 31, 

2013.

6.2.6 Procedure and oversight responsibilities applicable to the Underground Piping and 

Tanks Integrity Initiative, including associated plant programs, shall be revised to 

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NEI 09-14 (Rev 1) 

December 2010 

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Section Requirement

include in-scope tanks and piping by December 31, 2011. 

6.2.6 Procedures and oversight shall incorporate the attributes listed in Section 3.3.B.1 plus 

the “shall” statements in the following paragraphs. 

6.2.6 If a utility proceeds with an activity that does not meet the language of the Initiative 

or a “shall” statement in this document, a justification for deviation shall be 

processed in accordance with the remainder of this section. 

6.2.6 When a utility determines that a required element of the Initiative will not or cannot 

be met, a justification for deviation shall be developed and retained with the utility’s 

corrective action program.

6.2.6 The justification shall provide the basis for determining that the proposed deviation 

meets the same objective, or level of conservatism exhibited by the original 

requirement, and should clearly state how long the deviation will be in effect. 

6.2.6 Justifications for deviation shall be approved by the responsible utility executive. 

6.2.6 Approved deviations shall be sent to NEI in a timely manner for review by the Buried 

Piping Integrity Task Force (BPITF). 

6.2.6 Semi-annually each utility shall report to NEI all active justifications for deviation at 

each of its plants that are judged to not meet the intent of the Initiative. 

6.2.7 Prioritization shall incorporate the attributes listed in Section 3.3.B.2.

6.2.7 Prioritization of components that fall within the scope of the Underground Piping and 

Tanks Integrity Initiative shall be complete by June 30, 2012. 

6.2.8 Condition assessment plans shall incorporate the attributes listed in Section 3.3.B.3. 

6.2.8 The Condition Assessment Plan shall be in place by December 31, 2012. 

6.2.9 Implementation of the Condition Assessment plan for components included within 

the scope added by the Underground Piping and Tanks Integrity Initiative shall start 

no later than June 30, 2013.

6.2.9 The condition assessment of underground piping and tanks containing licensed 

material shall be completed by June 30, 2014. 

6.2.10 The Asset Management Plan for underground piping and tanks shall be in place by 

December 31, 2014. 

App A If an implementation date is not going to be met, it shall be reported as such until the 

implementation is completed.