ENCLOSURE 

NRR ACTION PLAN 

REVISION 2 

November, 2011 

BURIED PIPING 

TAC NO. ME3939 Last Update: September 14, 2010 

Lead Division: DE 

Supporting Division(s): DLR, DIRS, DPR, DRA 

Supporting Office: NRO, RES, Regions, OCA, OPA 

Description: 

Buried piping at some nuclear power plants has degraded to the point that through wall leakage 

has occurred. In a few cases this has led to releases of tritium into groundwater, which has 

generated significant stakeholder interest. Leaks from degraded buried piping are responsible 

for less than approximately 10-20% of recently reported abnormal releases of tritium from 

nuclear power plants. The Nuclear Regulatory Commission (NRC) staff, in SECY 09-0174 

(ML093160004), reviewed codes, standards, regulations and industry practices related to 

degradation of buried piping and identified a number of ongoing activities. This action plan 

tracks those activities. 

Background: 

Leaks from buried piping, particularly of tritiated water, have attracted significant stakeholder 

attention. For example, during 2009 buried piping leaks introduced water that contained low 

levels of tritium into the groundwater at Dresden, Oyster Creek and Peach Bottom nuclear 

plants. The levels of tritium did not exceed any NRC limits (that would be applicable on-site), 

and after additional dilution and decay that would occur as a natural consequence of migration 

toward the site boundary, would not exceed any NRC limit offsite. Although these leaks did not 

exceed any NRC limits, either on-site or offsite, the level of tritium triggered the licensees to 

initiate voluntary communications with local and state officials. In response to these leakage 

events the staff performed a collective significance review of buried piping degradation. In 

September 2009, the Chairman issued a tasking memorandum that required the staff to review 

the adequacy of regulations, codes, standards and industry activities related to degradation of 

buried piping. In response, the staff prepared SECY 09-0174 (ML093160004), which concluded 

that no immediate regulatory changes were necessary to address degradation of buried piping 

because a) leakage from buried piping was of low safety significance with respect to structural 

integrity of the piping, and b) the amount of radioactive material that has been released has 

been a small fraction of regulatory limits. 

The SECY paper described a number of ongoing staff, codes and standards, and industry 

activities. The staff identified plans to review operating experience to continue to validate 

conclusions in the SECY paper. The staff indicated it would continue its participation in codes 

and standards organizations efforts to incorporate changes in the state-of-the-art with respect to 

maintenance and evaluation of buried piping. Independent of the staff’s actions, the nuclear 
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industry developed, and in November 2009, issued their “Buried Piping Integrity Initiative,” an 

executive level inter-utility agreement to address degradation of buried piping. The staff 

identified actions necessary to understand the breadth of implementation and efficaciousness of 

this initiative. The staff also identified actions related to license renewal, new reactors, and the 

need to communicate about buried piping issues with licensees and other stakeholders. 

The NRC defines buried piping as piping that is underground and in contact with soil (or 

encased in concrete). In September 2010, the industry developed the Underground Piping and 

Tanks Integrity Initiative, which extended the objectives and actions in the Buried Piping 

Integrity Initiative to tanks that are partly or entirely below the surface of the ground and piping 

that is below the surface of the ground, but that does not contact soil because the piping is in 

chases, vaults or tunnels. Actions in this plan that previously applied only to the Buried Piping 

Integrity Initiative are now considered to apply to the full scope of both industry initiatives. 

During 2010-2011, the Government Accountability Office performed a review of NRC 

activities related to buried and underground piping. The GAO issued a report, 

“Oversight of Underground Piping Systems Commensurate with Risk, but Proactive Measures 

Could Help Address Future Leaks,” GAO-11-563, June 3, 2011, that contained a 

recommendation for the staff to keep abreast of emerging inspection technology. A milestone 

has been added to the plan to specifically address the GAO recommendation. 

In August, 2011, the Commission issued a staff requirements memorandum addressing SECY 

2011-0019 that approved the staff’s continued efforts to work with industry initiatives and 

consensus standards organizations. This SRM also stated “if, based on its participation in 

consensus standard activities the staff determines that revisions to the agency’s regulations are 

necessary to incorporate changes to the ASME codes related to groundwater protection, the 

staff should seek Commission approval via a notation vote paper.” An action item has been 

added to address this requirement. 

Regulatory Outcome: 

In SECY 09-0174 the staff concluded that current regulations, codes, standards and industry 

activities have been adequate to ensure: a) leakage from buried piping has been of low safety 

significance with respect to structural integrity of the piping, and b) the amount of radioactive 

material that has been released has been a small fraction of regulatory limits. Continued 

validation of these conclusions is one of the potential regulatory outcomes of this action plan. 

In the event that operational experience or other information causes the NRC to revise these 

conclusions, timely regulatory action such as issuing generic communications would be initiated. 

In addition, this plan tracks interaction with industry to understand whether, by 2015, their 

Buried Piping and Underground Piping and Tanks Integrity Initiatives ultimately reduce the 

incidence of degradation and leaks. Finally, because there will be more frequent and rigorous 

inspection there may be, in the short term, an increase in observations of degradation. Since an 

inspection transient is expected, this plan addresses proactive creation of communication tools 

to manage the inspection transient. 

Project success criteria include: 
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Licensees adequately implement the Buried Piping Integrity and Underground Piping and Tanks 

Integrity Initiatives, and the initiative activities are effective in addressing degradation of buried 

piping. 

Stakeholders are informed of and educated about the safety and environmental significance of 

degradation of buried piping, and are adequately and appropriately informed about the potential 

increase in reported degradation expected over the next 3-4 years. 

Current regulations, codes, standards and industry activities continue to be adequate to ensure: 

a) leakage from buried piping has been of low safety significance with respect to structural 

integrity of the piping, and b) the amount of radioactive material that has been released has 

been a small fraction of regulatory limits. If operational or other information becomes available 

that requires a change in these conclusions, appropriate regulatory action is to be initiated via 

generic communication, revision to the NRC inspection activities, or rulemaking, as appropriate. 

The milestones in the action plan, and documents or products that result from completed 

milestones should be publicly available. Planning information, personnel assignments and draft 

documents will not, in general, be made public. 

Milestones, Update Frequency, and Scheduled Dates for Completion: 

The action plan will be updated periodically. 

Number Milestone Date (T=Target)

(C=Complete) 

Lead Support

Phase 1: Collection of reference information 

1-1 Develop list of historical buried piping 

degradation incidents (target 1990-

present) 

8/2010 C DCI DIRS 

1-2 Update list of buried piping 

degradation incidents (Ongoing 

through 12/2015. Milestone is semiannual, update may occur more 

frequently) 

12/2010 C 

6/2011 C 

12/2011 T 

DCI DIRS 

1-3 Acquire from the industry, review and 

assess a listing of buried piping 

systems at nuclear power plants. 

Specifically determine whether there 

is any buried ASME Class 1 piping. 

(request list from Buried Piping 

Initiative Executive) 

5/2011 C DCI DIRS 

1-4 Develop an historical listing of 

abnormal liquid releases of tritium that 

have affected groundwater at nuclear 

power plants (ML101270439) 

(target 1990-present) 

5/2010 C DIRS 
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1-5 Update listing of abnormal tritium 

releases at nuclear power plants 

(Ongoing through 12/2015. Milestone 

is semi-annual, update may occur 

more frequently) 

12/2010 C 

6/2011 C 

12/2011 T 

DIRS 

1-6 Compile and evaluate available buried 

piping degradation and leakage event 

causal information 

5/2011 C DCI DIRS 

1-7 Using output from the Temporary 

Instruction, verify that buried high 

pressure piping (over 275 psi) is 

identified and given appropriate 

inspection priority, and that ASME 

Section XI IWA-5244 Buried 

Component pressure tests have been 

and are being periodically performed 

3/2015 T DE 

1-8 Evaluate the need to issue generic 

communication to collect information 

necessary to complete items 1-6 and 

1-7 

5/2011 C DCI DIRS 

1-9 Using historical buried piping 

degradation event information 

developed in step 1-1, establish a pre2010 rate of occurrence of buried 

piping degradation events 

04/2012 T DE 

1-10 Review the Groundwater 

Contamination task force final report 

for consistency with the buried piping 

action plan. Consider additional 

actions/milestones based on 

recommendations from the GW task 

force pertaining to buried piping. 

7/2010 C DCI 

Phase 2: Assess the industry’s Buried Piping Integrity Initiative 

2-1 Assess the Buried Piping Integrity 

Initiative through a series of public 

meetings with industry (Ongoing 

through 12/2015. Milestone reflects 

public meeting dates) 

2/2010 C 

9/2010 C 

3/2011 C 

10/2011 C 

DCI 

2-2 Identify staff training needs with 

respect to the EPRI buried piping 

program, guided wave ultrasonic 

examination technology, NACE 

standards, cathodic protection system 

assessment, risk ranking and other 

relevant training 

10/2010 C DCI All 

 
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2-3 Evaluate need to develop Temporary 

Instruction for inspection of Buried 

Piping Integrity initiative activities and 

if necessary, develop draft TI 

9/2010 C DCI DIRS 

2-4 If required as outcome of 2-3, issue 

Temporary Instruction for inspection 

of Buried Piping Integrity initiative 

activities 

12/2011 C DIRS DCI 

2-5 If required as outcome of 2-3, 

implement Temporary Instruction 

12/2011 C Regions 

2-6 Using information from 1-9 and 1-2, 

determine whether the incidence of 

degradation of buried piping 

decreases after implementation of the 

Buried Piping Integrity Initiative 

9/2015 T DE 

2-7 Determine whether the Buried Piping 

Integrity Initiative addresses pipe 

systems in vaults that, while not soil 

covered, may be subject to 

degradation similar to buried pipe 

components and/or where the extent 

of inspection or observation is limited 

9/2010 C DCI 

2-8 Evaluate the qualification and 

application of guided wave ultrasonic 

inspection techniques for evaluation of 

piping condition (annual status 

reports) 

5/2011C 

5/2015 T 

DE 

2-9 Assess Buried Piping Integrity 

Initiative risk ranking processes 

5/2012 T DE 

2-10 Stay abreast of ongoing industry 

research to develop technologies for 

structural integrity tests, and when 

they become feasible, analyze costs 

to licensees of implementing these 

tests compared with the likely benefits 

to public health and safety.

5/2015 T DE 

Phase 3: Codes and standards activities 

3-1 Participate in NACE standards 

activities to develop nuclear industryspecific corrosion prevention and 

inspection standards (Ongoing 

through 12/2015. Milestone is semiannual, update may occur more 

frequently) 

12/2010 C 

6/2011 C 

12/2011 T 

DE, 

DLR 

 
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3-2 Participate in ASME standards 

activities to incorporate into the code 

state-of the art design, evaluation and 

inspection technologies (Ongoing 

through 12/2015. Milestone is semiannual, update may occur more 

frequently) 

12/2010 C 

6/2011 C 

12/2011 T 

DE, 

RES, 

NRO 

3-3 Meet with ASME management at the 

August 2010 Code meeting in 

Washington to discuss ASME plans 

with respect to buried piping. 

9/2010 C DCI 

Phase 4: Regulatory products 

4-1 Issue draft revision of aging 

management programs for buried 

piping and buried tanks in GALL for 

public comment 

5/2010 C DLR 

4-2 Issue GALL revision 1/2011 C DLR 

4-3 Develop RAIs for all current LRA 

applicants to address augmented 

requirements in Buried Pipe Programs 

based on industry OE 

11/2010 C DLR 

4-4 Provide OE data on buried and 

underground pipe leakage or 

degradation to the PI&R Inspection 

Teams to inform that inspection 

process 

10/2010 C DLR/ 

DIRS 

4-5 Evaluate the need to issue generic 

communication soliciting licensee 

commitments to the Buried Piping 

Integrity Initiative (Ongoing through 

12/2015. Milestone is semi-annual, 

update may occur more frequently) 

11/2010 C 

5/2011 C 

12/2011 C 

6/2012 T 

DE/ 

DIRS 

4-6 Evaluate the staff’s treatment of 

licensee commitments with respect to 

Regulatory Guide 1.143 

12/2011 C DE/ 

DIRS/ 

RES 

4-7 Update buried piping website bimonthly current DE 

4-8 Evaluate the need to make changes 

to the Reactor Oversight Process 

based on results of the TI inspections 

7/2013 T DIRS, 

DE 

4-9 Develop and post on website a 

description of the expected increase 

in leak discovery due to an increase 

in inspection 

9/2010 C DCI 

 
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4-10 Evaluate the need to recommend 

rulemaking to require enhanced 

maintenance, corrective action, and 

aging management programs for 

these systems, structures and 

components that contain radioactive 

materials. Consider the interim 

results of item 2-10. 

5/2013 T DE DIRS 

4-11 In accordance with Staff 

Requirements Memorandum for 

SECY 2011-0019, revise LIC-300 to 

capture the requirement, for certain 

rulemakings related to the ASME 

Code updates that affect groundwater 

protection, for the responsible 

technical organization to prepare a 

notation vote paper (separate from the 

rule package) for Commission 

consideration. 

5/2014T DPR 

Current Status: As noted in table 

Contacts: 

 

DE: R. Hardies, T. Lupold, D. Alley 

DIRS: J. Isom, M. King 

DRA R. Conatser 

DPR: S. Helton 

DLR: W. Holston 

NRO: J. Strnisha, R. LaVera 

OPA: S. Burnell 

OCA: E. Dicus 

Region I: R. Conte 

Region II: M. Franke 

Region III: A. Shaihk 

Region IV: G. Werner 

References: 

EVALUATION OF BURIED PIPING AT NUCLEAR REACTOR FACILITIES, September 3, 2009 

(ML092460648) 

STAFF PROGRESS IN EVALUATION OF BURIED PIPING AT NUCLEAR REACTOR 

FACILITIES, SECY 09-0174, December 2, 2009 (ML093160004) 
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Industry Initiative on Buried Piping Integrity, November 20, 2009 (ML093350032) 

Industry Initiative on Groundwater Protection, July 31, 2006 (ML062260198) 

SUMMARY OF CATEGORY 2 PUBLIC MEETING BETWEEN THE U.S. NUCLEAR 

REGULATORY COMMISSION AND INDUSTRY REPRESENTATIVES TO DISCUSS BURIED 

PIPING ISSUES, November 2, 2009 (ML093070150) 

SUMMARY OF CATEGORY 2 PUBLIC MEETING BETWEEN THE U.S. NUCLEAR 

REGULATORY COMMISSION AND INDUSTRY REPRESENTATIVES TO DISCUSS THE 

INDUSTRY’S BURIED PIPING INTEGRITY INITIATIVE, March 24, 2010 (ML100820453) 

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 INTEGRITY INITIATIVE, September 21, 

2010 (ML103230366) 

Underground Piping and Tanks Integrity Initiative, September 27, 2010 (ML110700121) 

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, March 30, 2011 (ML11137A160) 

GAO Report “Oversight of Underground Piping Systems Commensurate with Risk, but 

Proactive measures Could Help Address Further Leaks,” GAO-11-563, June 2011 

NRR Yellow Ticket Number: YT20100098, Buried Piping Action Plan 

Staff Requirements Memorandum, SECY 2011-0019