1776 I Street, NW l Suite 400 l Washington, DC l 20006-3708 l P: 202.739.8080 l F: 202.533.0164 l axm@nei.org l www.nei.org 

Alexander Marion 

VICE PRESIDENT

NUCLEAR OPERATIONS

NUCLEAR GENERATION DIVISION

March 7, 2011 

Mr. Eric J. Leeds 

Director, Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Subject: Underground Piping and Tanks Integrity Initiative 

Project Number: 689 

Dear Mr. Leeds: 

The NEI Nuclear Strategic Issues Advisory Committee (NSIAC) approved the Underground Piping 

and Tanks Integrity Initiative in September, 2010. This Initiative expanded the scope of the Buried 

Piping Integrity Initiative which had been approved in November 2009. Please note that this 

Initiative results in an enhanced inspection program for these components. The document that 

guides the implementation of this program, NEI 09-14, Guideline for the Management of Buried 

Piping Integrity, was recently revised to reflect the new Initiative. A copy of Revision 1 of the 

document is attached for your information. Revision 1 includes the following changes: 

• The text of the revised Initiative 

• Clarification of the intent through “shall” statements 

• Guidance on the program scope 

• A section on definitions 

• Enhancements to the process for justifying deviations 

• Expectations for communication of operating experience and deviations 

One of the requirements in NEI 09-14 is the preparation of semi-annual reports to NSIAC on 

implementation status, operating experience related to buried piping, and developments in NDE 

technology. The January 2011 report on these matters was presented to NSIAC during its meeting 

earlier this month. A copy of the NSIAC report is attached for your information. You will note that 
Mr. Eric J. Leeds 

March 7, 2011 

Page 2 

as of the time we completed the implementation survey, all 104 plants were on schedule for 

implementation of the indentified program milestones. 

We will continue to keep you and your staff informed of the status of industry activities associated 

with this important program. If you have any questions, please contact me at 202.739.8080; 

axm@nei.org or Jim Riley at 202.739.8137; jhr@nei.org. 

Sincerely, 

Alexander Marion 

Attachments 

c: Mr. Jack Grobe, NRR, NRC 

 Ms. Michele G. Evans, NRR/DCI, NRC 

Mr. Robert O. Hardies, NRR/DCI, NRC 
Report to NSIAC - Summary

Status of Implementation of Buried Piping Integrity Initiative Milestones 

• Procedures and oversight by June 30, 2010 

o 104 plants complete 

• Risk ranking by December 31, 2010 

o 47 plants complete 

o 57 plants on schedule 

• Inspection plans by June 30, 2011 

o 1 plant complete 

o 103 plants on schedule 

• Inspection start by June 30, 2012 

o 6 plants complete 

o 98 plants on schedule 

• Complete condition assessment of piping containing radioactive material by June 30, 2013 

o 2 plants complete 

o 102 plants on schedule 

• Complete asset management plan by December 31, 2013 

o 104 plants on schedule 

• No plants have identified any deviations to the Buried Piping Integrity Initiative 

Industry Buried Piping Leakage Trends (source INPO EPIX data base) 

• Less than 10 leaks per year reported from 2000 to 2008 

• 67 leaks reported in 2009 

• 28 leaks reported in 2010 as of July 

• The spike in reported leaks in 2009 and 2010 is a direct result of a request to the CNOs to 

report all leaks from buried piping beginning in 2009 

• Of the 130 buried piping leaks reported from 2000 to the present: 

o 10% were in safety-related systems 

o 13% were in systems containing radioactive materials 

o 10% were in systems containing environmentally sensitive fluids 

o 57% were in low priority systems categorized as “run to failure” under the applicable 

program 

o 10% were in other systems
2 

o The number of leaks in safety related systems and in piping containing radioactive 

materials in 2009 and 2010 was about 11%. This percentage is much lower that 

reported from 2000 to 2010. This difference may be due to the tendency to report 

only more important leaks prior to 2009. 

NDE Technology Development 

• Currently available technology 

o Direct excavation 

o Guided wave UT (screening only) 

o Internal “PIGs” and robotic vehicles if piping ID is accessible 

• EPRI identifying and investigating other commercially available technologies 

Overall Observations 

• All plants have met the first Initiative milestone and there are no deviations to Initiative 

elements 

o Positive impact on program and processes is evident 

o OE and inspection results indicate that plants are implementing the Initiative 

expectations 

• Too early to assess the impact of the Initiative on piping integrity 

• Communication among ground water protection staff, NDE, and buried piping staff is 

important, expected, and improving 

• Improvement is needed in the following areas: 

o New inspection technologies as alternatives to direct inspection by excavation 

o Better source identification of water samples with low tritium levels below reporting 

threshold 

o Improved operation and maintenance of installed cathodic protection systems