Buried Piping Integrity Initia

Implementation Status

Chris Burton, FENOC

Joe Sears, INPO

September 21, 2010
History

 Buried piping leaks have occurred and 

continue to happen

 Industry had recognized the importanc

– INPO focus area– NEI Ground Water Protection Initiative– EPRI Balance of Plant Corrosion and B

• EPRI Buried Piping Program Guideline
Perspective

 Leaks have not resulted in nuclear safety 

concerns or significant radiological consequences

 However, leaks from buried piping could 

the potential to be nuclear safety, radiolog

and environmental concernsand environmental concerns

 Issue is experiencing public and political  The public may not understand distinction

system function

 This is a public confidence issue
Industry Response

 Buried Piping Integrity Initiative approve

industry Chief Nuclear Officers (CNO) oNovember 18, 2009

– Scope: below grade piping that is in dire

cont t ith th il tac

t with the soil

 Implementation is proceeding as planne
Buried Piping Integrity Initiative

 Goal: Reasonable assurance of leakage and stru

integrity with emphasis on piping containing radiol

material

 Six implementation milestones

1. Procedures and oversight by June 30, 2010 -

COMPLETE

2. Risk ranking of piping by December 31, 20103. Inspection plan by June 30, 20114. Begin inspections by June 30, 20125. Condition assessment by June 30, 20136. Asset management plan by December 31, 20
Understanding an NSIAC Initiativ

 NSIAC (Nuclear Strategic Issues Advisor

Committee) is an NEI standing committee members include the CNO of every utility operating a nuclear power plant in the US

 Initiative is a formal commitment between 

t f ll d fi d li l f tito 

follow a 

d

efine

d policy or plan o

f action

– Large regulatory credibility, but not a 

regulatory commitment

 Buried Piping Integrity Initiative was ap

unanimously (100%) on November 18, 
Industry Activities

 Formed Buried Piping Integrity Work

Group and Task Force

 Issued rev 0 of NEI Guideline (NEI 0 Ongoing interaction with NRC to exp

Initiative and industry activitiesInitiative and industry activities

 In response to OE, revised the Initia

expand scope
Initiative Implementation: 

Milestone Status for 104 Plan

80

100

July 2010

0

204060

Procedures and 

oversight 6/30/10

Risk ranking 

12/31/10

Inspection plan 

6/30/11

Inspection start 

6/30/12

Inspection of rad 

systems 

6/30/13

Asset 

management p

12/31/13

Responses

Milestone
Operating Experience

 Recent inspection OE

– Example

• Inspections performed per buried pipin

integrity program and in response to thInitiative

• AFW line corrosion due to lack of coati

 Leakage events (INPO data) 

– See following slides for trends

• Data for all leaks reported: includes 

significant leaks as well as insignificant 
EPIX Reporting

 NEI: report leak data to 1/2009 by 6/30/201

establish baseline for trends

 Reporting basis: NEI 09-014 Appendix A
Reporting

 Reporting of all leaks expected beginn

in 2009

 Recent leakage trends

– 2009 ~ 70– 2010 ~ 32 through August
Leakage Breakdown

 System breakdown

– Safety related ~ 5%– Contains licensed radioactive material – Environmentally sensitive ~ 10%– Other systems ~ 80%
NDE Technology Developmen

 Currently available technology

– Direct inspection (excavation)– Guided wave UT for screening– Internal inspection tools if accessible– Remote field eddy current

• Large diameter robotic inspection vehicle 

 Recent industry report summarizes availab

technologies from other industries

– Evaluation for applicability in progress
Implementation Observation

 Plants are implementing the Initiative

– All plants have met the first Initiative 

milestone: no deviations taken

 Positive impact on program and proces OE i di t th t l t i l 

OE indica

tes th

a

t plan

ts are implemen

Initiative expectations

 Emphasizing development of new insp

technologies as alternatives to direct inspection by excavation