Buried and 

Underground Pipin

April 4, 2012

Bob Hardies

Senior Level Advisor, NRR
Summary

• NRC’s objectives related to buried piping 

– Maintenance of intended nuclear operations safety function 

– Releases remain below regulatory limits

• Current regulations and industry activities are adequate with re

objectives

• NRC is monitoring and responding to events related to buried • NRC is working to understand and assess licensee implementa

Buried Piping Integrity Initiative and the Underground Piping Integrity Initiative
Background

• Industry establishes the Buried Piping Integrity Initiative, Nov• December 3, 2009, SECY 09-0174 (ML093160004)

– Look at regulations, codes and standards and industry activities

k k i 2010 f d d i i (i

• Leaks at Vermont Yankee in 2010 from underground piping (in 

vault) generated significant stakeholder interest

• September 27, 2010, Underground Piping and Tanks Integrity 

(ML110700121)
Background

• November 30, 2011, Buried Piping Action Plan Revision 2 

(ML11332A122)

• Meetings with industry 10/2009, 2/2010, 9/2010, 3/2011, 10/2

4/2012

• Senior Management Review of Overall Regulatory Approach t

Groundwater Protection, SECY-11-0019, February 9, 2011 
Background

• GAO Report: Oversight of Underground Piping Systems 

Commensurate with Risk, but Proactive Measures Could Help Future Leaks, June, 2011

• Commission Staff requirements memorandum, SECY-11-0019

15, 2011

• NRC Public Website Buried Piping Page

– http://www.nrc.gov/reactors/operating/ops-experience/buried-piping-acti
Buried Piping Action Plan

• Data collection – Historical rate of incidence

– Affected systems– System classifications– Tritium releases

• Program assessment – Understand Buried Piping Integrity Initiative and Underground Piping a

Integrity InitiativeIntegrity Initiative

– Temporary Instruction for NRC inspection of Initiative activities

– Initiative details (scope, risk ranking, inspection techniques)

• Codes and standards• Regulatory activities

– Website

– License renewal– Commitments– Recommendations for rulemaking
Ongoing Action Plan Items

• Gather leak and tritium release data• Meet with industry• Evaluate guided wave and risk ranking• Maintain web page• Participate in ASME and NACE activities• Evaluate the need for regulatory changes
Open Action Plan Items

• 1-7 High pressure piping is given appropriate inspection priorit

ASME Section XI IWA-5244 tests are being performed as requ

• 1-9 Establish pre-2010 rate of occurrence of degradation event• 4-8 Evaluate need to chan

ge ROP

• 4-10 Evaluate the need for regulatory changes
New Action Plan Items

• 2-10 Stay abreast of ongoing industry research to develop techn

structural integrity tests, and when they become feasible, analyzlicensees of implementing these tests compared with the likely bpublic health and safety.

• 4-11 Revise rulemakin

gp g rocedures to ensure rulemakin

g for 

10CFR50.55a is reviewed by the Commission when any changeASME Code include changes related to buried or underground p
Codes and Standards

• ASME Code

– Met with ASME, Section XI management August 6, 2010– In November Section XI established a committee to addre

from buried piping

• Consideration of enhanced inspection requirements• Consideration of extension of scope to nonsafety-related piping tha

tritium

– Task Group on Buried Components Inspection and Testing

• NACE International (formerly National Association of Corros

Engineers)

– Task group to develop standards for nuclear buried piping
NRC Actions

• License renewal

– Revised buried piping aging management program

• GALL XI.M29, “Aboveground Metallic Tanks”• GALL XI.M41, “Buried and Underground Piping and Tanks”

• Inspection

– Temporary Instruction for inspection of buried piping activ

Temporary Instruction for inspection of buried piping activ

• ML11119A167• Implementation by December, 2011• Temporary Inspection instructions exists through 2014• Seeking to understand commitment to minimizing leak
Staff Requirements

SECY-11-0019 

• Approved SECY 11-00179

• The Commission has approved the SMRG recommendation n

incorporate the voluntary industry initiative on groundwater pthe regulatory framework. 

• The staff should, instead, monitor the effectiveness of the indu

initiatives.

• Th t ff h ld k it l i it t k h ld t 

The staff should make it clear in its stakeholder engagements 

the agency will continue to monitor the industry’s voluntary inchanges to the regulatory framework are currently being conte

• The staff is cautioned to remember that its purpose is to monit

efforts, not to regulate them. 

• If the staff finds that the voluntary initiatives are not conducte

committed and enduring fashion, the staff should present infothis effect to the Commission which can and, if necessary, wilmatter.
Staff Requirements

SECY-11-0019 

• If, based on its participation in consensus standard activities the 

determines that revisions to the agency’s regulations are necessaincorporate changes to the ASME codes related to groundwater the staff should seek Commission approval via a notation vote p

• Additionally, y 

 the staff should continue to work with industry in 

protocols for the NRC to remain aware of industry progress in implementing and overseeing its self-imposed initiative. 
Staff Requirements

SECY-11-0076 

• SECY-11-0076 - Improving the Public Radiation Safety Corne

the Reactor Oversight Process

• “The Commission has approved the staff’s commitment to work 

internal and external stakeholders on potential enhancements to 

p p g , pp g erformance indicator program, but has not approved changes tradiological effluent performance indicator or other modificatioreactor oversight process (ROP) related to groundwater contamcontrol...”
Temporary Instruction

• Objectives

– Determine whether industry is implementing initiatives in a 

and enduring fashion....”

– Enable staff to assess whether initiative as implemented pro

reasonable assurance of structural and leaktight integrity

– Phase 1

• Compare plant program to initiative• Assess deadline compliance

– Phase 2

• Assess deadline compliance• Assesses “committed and enduring fashion”
Current Activities

• Preparing Commission vote paper• Action plan activities• Implementing TI• Participating in ASME and NACE• Meeting with industry• Monitoring operating experience• Evaluating need for commitments for initiative
Conclusions

• NRC’s objectives related to buried piping 

• Maintenance of intended function • Releases remain below regulatory limits

• Current regulations and industry activities are compatible with 

objectives

• NRC is monitoring current events related to buried piping

NRC is monitoring current events related to buried piping

• NRC is performing action plan activities, including monitorin

initiatives