Buried Pipe Initiative and Guideline Comparison

Buried Pipe Integrity NSIAC Initiative GuidelineThursday, February 24, 2010

Nuclear Regulatory Commission (NRC), Buried Pipe Update 

Chris Burton, -FENOCDavid Smith, -Duke 

Comparison

Provide an overview of the NSIAC Initiative details:◦ Initiative Goal◦ Purpose of the NEI Guideline  Document : NEI 09-14

I iti ti E ti l P El t d◦ Initiative Essential Program Elements and Implementation  Dates

The goal of the Buried Piping Integrity Initiative is to provide “reasonable assurance” of structural and leakage integrity of all buried piping with special emphasis on piping that contains radioactive materials.Building upon the existing Ground Water Protection g p gInitiative (NEI 07-07) the Buried Piping Integrity Initiative will:◦ Drive proactive assessment and management of the 

condition of buried piping systems.◦ Ensure sharing of industry experience◦ Drive technology development to improve upon available 

techniques for inspecting and analyzing underground piping.

Reasonable assurance within the context of the Buried Piping Integrity InitiativeAttributes include◦ Best estimate◦ Graded approach◦ Engineering judgment based on experience and 

d b fsupported by facts◦ Systematic approach◦ Prevention◦ Not a guarantee

4

“Every utility shall implement a Buried Piping Integrity Program that incorporates the elements and associated key attributes in this section”◦ Procedures and Oversight – By June 30, 2010◦ Risk Ranking – By December 31, 2010◦ Inspection Plan – By June 30, 2011◦ Plan Implementation – Inspection Plan shall start no 

later than June 30, 2012 and the condition assessment of buried piping containing radioactive material shall be completed by June 30, 2013

◦ Asset Management Plan – By December 31, 2013

The Industry Guideline for the Management of Buried Piping Integrity describes the policy and practices that the industry commits to follow in managing buried piping.  These guidelines support the Industry Initiative on Buried Piping Integrity adopted by the NEI Nuclear Strategic Issues Advisory Committee (NSIAC) on November 18, 2009.The guideline:◦ Documents the scope of the formal Industry Initiative on Buried 

Piping Integrity (the “Initiative”).◦ Sets the goals that drive the Initiative.◦ Defines the roles and responsibilities established to ensure 

implementation of the Initiative.◦ Defines the content and responsibilities for creating reports to NSIAC

on Initiative implementation.

The necessary procedure and oversight responsibilities shall be in place by June 30, 2010.◦ Clear lines of responsibility

◦ Buried Pipe Integrity Program Documents and Implementing ProceduresImplementing Procedures

◦ Report to NSIAC

◦ Process for justifying and approving exceptions to the provisions of the Initiative

Identifies site vulnerabilities Prioritizes the selection of inspection locations.  Performed by determining◦ The likelihood of failure of each segment and ◦ The consequences of failure of that segment.  Incorporates other attributesIncorporates other attributes◦ Pipe function◦ Pipe locations and layout◦ Pipe materials and design◦ Health of cathodic protection system (if applicable)Considers the following as a minimum:◦ Emphasis on piping containing radioactive fluids.  

Includes 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◦ Assessment of cathodic protection, if applicableSampling techniques and engineering evaluations based on known conditions of piping are an acceptable means of achieving reasonable assurance

Start no later than June 30, 2012.  Complete buried piping containing radioactive material by June 30, 2013.Condition assessmento Based on both inspection results and engineeringo Based on both inspection results and engineering 

evaluations.  o Locations prioritized based on risko Provides “Reasonable assurance” that the piping 

segment will maintain structural and leakage integrity until the next planned inspection.

Long range plan for managing the structural and leakage integrity of buried piping.  Key elements include:◦ Inspection plans,◦ Planned maintenance activities, ◦ Plans for repair, and ◦ Anticipated replacement.  ◦ The asset management plan for buried piping may be part ofThe asset management plan for buried piping may be part of 

the overall site or fleet asset management plan.  Living document that will be periodically reviewed as more plant data becomes available through physical assessments and other means and as industry knowledge and technology evolveRevisions reviewed by an appropriate high level organization within the utility 

??