Buried and

Underground Piping Underground Piping

December 5 2012 December 5, 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 – Releases remain below regulatory limits

• Current regulations and industry activities are adequate with 

regard to these objectives regard to these objectives

• NRC is monitoring and responding to events related to buried 

piping

• NRC is working to understand and assess licensee 

implementation of the Buried Piping Integrity Initiative and the Underground Piping and Tanks Integrity Initiative
Buried Piping Action Plan

• Data collection

Historical rate of incidence

– Historical rate of incidence– Affected systems– System classifications– Tritium releases

P

• rogram assessment

– Understand Buried Piping Integrity Initiative and Underground Piping and Tanks 

Integrity Initiative

– Temporary Instruction for NRC inspection of Initiative activities

– Initiative details (sco

p

e, risk ranking, ins

pection techni

ques) ( p , g, p q )

• Codes and standards• Re

gulatory activities g y

– Website

– License renewal– Commitments– Recommendations for rulemaking

3
Ongoing Action Plan Items

• Gather leak and tritium release data• Meet with industry

l id d

• Eva

luate guid

e

d wave 

• Maintain NRC Public Website Buried Piping Page

http://www nrc gov/reactors/operating/ops experience/buried piping activities html

– http://www.nrc.gov/reactors/operating/ops-experience/buried-piping-activities.html

• 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 priority and 

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

• 1-9 Establish pre-2010 rate of occurrence of degradation events

• 2-9 Evaluate risk ranking•

2 10 Stay abreast of ongoing industry research

-10 Stay abreast of ongoing industry research

• 4-8 Evaluate need to change ROP• 4-10 Evaluate the need for regulatory changes
Codes and Standards

• ASME Code

S i XI bli h d i dd l k f b i d – Section XI established a committee to address leaks from buried

piping

• Consideration of enhanced inspection requirements• Consideration of extension of scope to nonsafety-related piping that contains p y pp g

tritium

– Task Group on Buried Components Inspection and Testing

NACE I i l (f l N i l A i i f C i • NACE International (formerly National Association of Corrosion 

Engineers)

– Task groups to develop standards for nuclear buried piping

6
NRC Actions

• License renewal

R i db i d i i i – Revised buried piping aging management program

• GALL XI.M41, “Buried and Underground Piping and Tanks• Internal surfaces

• Inspection

– Temporary Instruction for inspection of buried piping activities

• ML11119A167

• Implementation by December, 2011• Temporary Inspection instructions exists through 2014• Seeking to understand commitment to minimizing leaks• Considering revision to reflect Revision 2 of NEI 09-14

7
Staff Requirements

SECY-11-0019 

• Approved SECY 11-00179

• If the staff finds that the voluntary initiatives are not conducted in a 

committed and enduring fashion, the staff should present information to 

this effect to the Commission which can and if necessary will revisit this this effect to the Commission which can and, if necessary, will revisit this

matter.
Staff Requirements

SECY-11-0076 

• SECY-11-0076 - Improving the Public Radiation Safety Cornerstone of 

the Reactor Oversight Process

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

i l d l k h ld i l h h internal and external stakeholders on potential enhancements to the 

performance indicator program, but has not approved changes to the radiological effluent performance indicator or other modifications to the 

reactor oversight process (ROP) related to groundwater contamination reactor oversight process (ROP) related to groundwater contamination

control...”
Temporary Instruction

• Objectives

– Determine whether industry is implementing initiatives in a “committed 

and enduring fashion....”

– Enable staff to assess whether initiative as implemented provides p p

reasonable assurance of structural and leaktight integrity

– Phase 1

• Compare plant program to initiative p p pg• Assess deadline compliance

– Phase 2

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

– Revision to incorporate Rev 2 of the guidelines and address plants that 

shut down
Conclusions

• NRC’s objectives related to buried piping 

M i t f i t d d f ti • Maintenance of intended function 

• Releases remain below regulatory limits

• Current regulations and industry activities are compatible with g yp

these objectives

• NRC is monitoring current events related to buried piping g pp 

• NRC is performing action plan activities, including monitoring 

industry initiatives

11
Pre Initiative Leak Rate

• Buried Piping Plan 

R i i lk

d i ii i

–

Requ

ires compar

ison 

lea

k rate pre- an

d posti

n

i

t

iat

ive

– Acknowledges potential increase as initiative is 

implemented

• Leak rate defined as

– Actual leak

• Safety Related or• Contains radioactive material or• Contains other hazardous material

• Initiative started in 2010

P i iti ti l k t 2009 d li

– rei

niti

ative 

lea

k ra

te 2009 an

d earlier
Pre Initiative Leak Rate

• EPIX data base

– Source of leak rate data– Changed reporting requirements beginning 2009– 2008 and prior data not comparable to 2009 and later– Historical events still being added to data base

• Current pre-initiative leak rate is 20 events
Risk Ranking Evaluation

• Buried 

p

i

pin

g action 

plan pp g p

– Requires review of initiative risk ranking process

• Review based on feedback from temporary instruction

– All phase 1 results indicate plants have risk ranking– Some phase 2 results indicate risk ranking produces 

bl lt reasonable result

s

• NRC finds risk ranking process employed is reasonable