November 17, 2011 

MEMORANDUM TO: Timothy R. Lupold, Chief 

 Piping and NDE Branch 

 Division of Engineering 

 Office of Nuclear Reactor Regulation 

FROM: David W. Alley, Senior Materials Engineer /RA/ 

 Piping and NDE Branch 

 Division of Engineering

 Office of Nuclear Reactor Regulation

SUBJECT: SUMMARY OF CATEGORY 2 PUBLIC MEETING BETWEEN THE 

U.S. NUCLEAR REGULATORY COMMISSION AND INDUSTRY 

REPRESENTATIVES TO DISCUSS THE PROGRESS ON THE 

INDUSTRY’S BURIED PIPING AND UNDERGROUND PIPING AND 

TANKS INTEGRITY INITIATIVES 

On October 20, 2011, the Nuclear Regulatory Commission (NRC) staff held a Category 2 public 

meeting with representatives from the Nuclear Energy Institute (NEI), the Electric Power 

Research Institute, the Institute for Nuclear Power Operations, the American Society of 

Mechanical Engineers, NACE International (formerly known as the National Association of 

Corrosion Engineers) and other industry representatives at NRC Headquarters in Rockville, MD. 

This public meeting was one in an ongoing series of interactions between NRC staff, industry 

representatives and other stakeholders to understand the scope and schedule for industry 

activities related to degradation of buried piping. Minutes of previous meetings are available at 

Agencywide Document Access and Management System (ADAMS) Accession Numbers 

ML093070162, ML100810295, ML103230366, and ML11137A171. A list of meeting attendees 

is enclosed. The meeting notice and agenda is available at ADAMS Accession Number

ML112790020. 

At the beginning of the meeting, NRC staff reviewed the status of the NRC’s Buried Piping 

Action Plan (ADAMS Accession number ML110910462). The staff described the action plan 

activities, schedule for action, and reiterated NRC objectives with respect to buried piping: the 

safety-related function of buried piping continues to be maintained and any releases of 

radioactive material from buried piping remain well below NRC regulatory limits. Current 

regulations and industry activities remain compatible with those objectives. The staff will 

continue to monitor operating experience to verify the objectives are being met. The staff 

described a temporary instruction for NRC to perform inspections of licensee activities related to 

the Buried Piping and Underground Piping and Tanks Integrity Initiatives. Staff and industry 

discussed comments on the draft temporary instruction. 

Enclosure: 

As stated 

CONTACT: David W. Alley, NRR/DE/EPNB 

 (301) 415-2178 
- 2 - 

The industry provided updates on the implementation status of the current Buried Piping and 

Underground Piping and Tanks Integrity Initiatives and discussed future changes to “Guidelines 

for the Management of Piping Integrity,” NEI buried piping initiative administrative document NEI 

09-14. 

The industry discussed its “Reasonable Assurance Document’” which describes a graded 

process that permits risk ranking and line grouping to inform the selection of indirect and direct 

inspection samples. Current plans are to include this document as an appendix to NEI-09-14 

when NEI 09-14 is next revised. EPRI and INPO reviewed operating experience related to 

degradation of buried piping. EPRI reviewed the status of activities to develop non-destructive 

inspection techniques and processes for buried and underground piping. EPRI plans to publish 

a revision to their Buried Pipe Nondestructive Examination Reference Guide. 

NEI discussed efforts to coordinate activities between the Groundwater Protection Initiative and 

the Buried Piping and Underground Piping and Tanks Integrity Initiatives. NEI indicated they 

would consider any staff comments. 

The NRC staff summarized its efforts to use industry and NRC information to determine a rate 

of occurrence for significant buried piping degradation events. The NRC is trying to determine a 

pre-initiative rate of occurrence as a baseline to evaluate the overall management of buried and 

underground piping. Compatibility issues between databases and changing recording 

standards have complicated this effort. 

NACE International described ongoing activities in NACE Task Group 404, “Nuclear Buried 

Piping,” to develop buried piping inspection, assessment and corrosion prevention standards 

optimized for nuclear power plant applications. ASME discussed the status of Section XI buried 

piping activities, including plans and progress in the “Task Group Buried Component Inspection 

and Testing.” This task group is developing potential changes to the ASME Boiler and Pressure 

Vessel Code. 

All presentations made at the meeting are available in ADAMS Accession number 

ML11297A001 (part of the package). 

Since the previous meeting, the following actions item were completed: 

1) Staff requested a response to its August 18, 2010 information request to NEI. NEI 

submit a response on May 17, 2011 (ML111470630). 

2) Industry was afforded an opportunity to review the temporary instruction. 
- 3 - 

During this meeting the following new action items were recorded: 

1) The NRC will continue discussions with industry related to determining a pre-initiative 

rate of occurrence of significant buried piping degradation events. 

2) The NRC will continue discussion with industry related to recording criteria for tabulating, 

categorizing and sorting instances of degradation of buried and underground piping. 

3) NEI will provide the NRC an opportunity to comment on the Groundwater/Underground 

Piping Initiative coordination document. A draft of this document was sent to the NRC 

on October 20, 2011. 

Enclosure: 

As stated 

CONTACT: David W. Alley, NRR/DE/EPNB 

 (301) 415-2178 
- 3 - 

During this meeting the following new action items were recorded: 

1) The NRC will continue discussions with industry related to determining a pre-initiative 

rate of occurrence of significant buried piping degradation events. 

2) The NRC will continue discussion with industry related to recording criteria for tabulating, 

categorizing and sorting instances of degradation of buried and underground piping. 

3) NEI will provide the NRC an opportunity to comment on the Groundwater/Underground 

Piping Initiative coordination document. A draft of this document was sent to the NRC on 

October 20, 2011. 

Enclosure: 

As stated 

CONTACT: David W. Alley, NRR/DE/EPNB 

 (301) 415-2178 

DISTRIBUTION: 

DCI R/F DE R/F RLaVera JIsom RConatser 

JStrishna AShaikh HGray RHardies 

MKing WHolston TKobetz 

Richard.hall@exeloncorp.com searsjt@inpo.org 

jhr@nei.org jabisam@entergy.com

geschinzel@stpegs.com Richard.hall@exeloncorp.com

dsmith@epri.com

ADAMS PACAKGE ACCESSION NO.: ML113210661 

OFFICE NRR/DE/EPNB NRR/DE/EPNB 

NAME DAlley TLupold(for John Tsao) 

DATE 11/17/2011 11/17/2011 

OFFICIAL RECORD COPY