August 18, 2011 

Mr. Alex Marion, 

Vice President Nuclear Operations 

1776 Street, NW, Suite 400 

Washington, DC 20006-3708 

Dear Mr. Marion, 

On December 2, 2009, the Nuclear Regulatory Commission (NRC) staff issued SECY 09-0174, 

“Staff Progress in Evaluation of Buried Piping at Nuclear Reactor Facilities” (Agencywide 

Document Access Management System (ADAMS) Accession number ML093160004). This 

evaluation discussed a number of ongoing staff activities to address the issue of buried piping 

degradation, including the industry’s initiatives. On May 18, 2010, the staff issued a Buried 

Piping Action Plan (ADAMS Accession Number ML101590171) that identifies and tracks these 

ongoing activities. In particular, the plan includes several activities intended to enable the staff 

to develop an understanding of the industry’s “Buried Piping Integrity Initiative” and 

“Underground Piping and Tanks Integrity Initiative.” The action plan also includes activities that 

involve collection of information that the staff may use to evaluate ongoing buried piping 

degradation. 

In an effort to better understand the scope of buried piping subject to degradation and leakage, 

the staff requested, via letter to Mr. Anthony R. Pietrangelo, dated August 18, 2010, that the 

Nuclear Energy Institute (NEI) provide information related to the design and leakage history of 

underground piping at nuclear power plants. The NEI Buried Piping Integrity Task Force 

worked with NRC staff to clearly define the information requested and to develop a spreadsheet 

to capture the desired data. By letter to Michele Evans, dated May 17, 2011, you provided the 

requested information. Additionally, on September 27, 2010, by letter to William Borchardt, NEI 

forwarded the Underground Piping and Tanks Integrity Initiative. This proposed initiative 

revised the previously issued Buried Piping Integrity Initiative and extended its scope to 

underground components. By letter to Eric Leeds, dated November 3, 2010, NEI provided NEI 

09-14, Guideline for the Management of Buried Piping Integrity. This guideline explained details 

about the intent of the Buried Piping Integrity Initiative. Finally, on March 7, 2011, by letter to 

Eric Leeds, you provided NEI 09-14, Revision 1, which was updated to reflect the additional 

scope included in the Underground Piping and Tanks Integrity Initiative. This letter also 

provided the Nuclear Strategic Issue Advisory Committee reports that summarize industry 

progress related to the piping and tanks initiatives. The information you have provided via this 

series of letters has helped the staff understand the industry’s plans and progress related to 

buried and underground piping. All of these communications are publically available in ADAMS. 

Over the past two years, the staff has periodically met with members of the NEI Buried Piping 

Integrity Task Force, the Institute of Nuclear Power Operations, and the Electric Power 

Research Institute’s Buried Piping Integrity Group to discuss the initiatives, industry 

arrangements for collection, documentation and sharing of operational experience information 

and industry’s existing and planned research programs to support inspection of buried piping. 

We expect to continue to meet on a routine basis with the next meeting tentatively scheduled for 

early fall, 2011.
- 2 - 

In accordance with our buried piping action plan, we are currently developing a temporary 

instruction to assess licensee performance with respect to the industry initiatives. We intend to 

solicit your comments before implementing the temporary instruction. 

We would like to convey our appreciation to NEI and the industry for addressing the issue of 

buried and underground piping integrity. We appreciate the industry’s development of the 

initiatives, continuing communication with NRC and, in particular, the collection of operating 

experience and program scope information you provided in the letter dated May 17, 2011. We 

encourage you to continue to apply appropriate focus on inspection and preventive 

maintenance of buried and underground piping or tanks that are safety-related or that contain 

radioactive materials. 

We look forward to receiving regular updates on your progress in this area. If you have any 

questions, please contact Robert O. Hardies of my staff at 301-415-5802. 

 Sincerely, 

 /RA/ 

 Michele G. Evans, Director 

Division of Component Integrity 

Office of Nuclear Reactor Regulation 

cc: J. Riley, Nuclear Energy Institute 

 M. Korsnick, Chief Nuclear Officer, Constellation Energy
 - 2 -

In accordance with our buried piping action plan, we are currently developing a temporary 

instruction to assess licensee performance with respect to the Industry initiatives. We intend to 

solicit your comments before implementing the temporary instruction. 

We would like to convey our appreciation to NEI and the industry for addressing the issue of 

buried and underground piping integrity. We appreciate the industry’s development of the 

initiatives, continuing communication with NRC and, in particular, the collection of operating 

experience and program scope information you provided in the letter dated May 17, 2011. We 

encourage you to continue to apply appropriate focus on inspection and preventive 

maintenance of buried and underground piping or tanks that are safety-related or that contain 

radioactive materials. 

We look forward to receiving regular updates on your progress in this area. If you have any 

questions, please contact Robert O. Hardies of my staff at 301-415-5802. 

 Sincerely, 

 /RA/

 Michele G. Evans, Director 

Division of Component Integrity 

Office of Nuclear Reactor Regulation 

cc: J. Riley, Nuclear Energy Institute 

 M. Korsnick, Chief Nuclear Officer, Constellation Energy 

DISTRIBUTION: 

DCI R/F ELeeds JGrobe DAlley TLupold

ADAMS ACCESSION NO.: ML11230B338 

OFFICE NRR/DCI NRR/DCI 

NAME RHardies MEvans 

DATE 8/18/11 8/18/11 

 OFFICIAL RECORD COPY