April 25, 2012 

MEMORANDUM TO: David W. Alley, Acting Chief 

 Piping and NDE Branch 

 Division of Engineering

 Office of Nuclear Reactor Regulation

 

FROM: Robert O. Hardies, Senior Level Advisor /RA/ 

 Division of Engineering

 Office of Nuclear Reactor Regulation

SUBJECT: 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 

On April 4, 2012, the Nuclear Regulatory Commission (NRC) staff held a Category 2 public 

meeting with representatives from the Nuclear Energy Institute (NEI), the Electric Power 

Research Institute, the Institute for Nuclear Power Operations, the American Society of 

Mechanical Engineers, NACE International (formerly known as the National Association of 

Corrosion Engineers) and other industry representatives at NRC Headquarters in Rockville, MD. 

This public meeting was one in an ongoing series of interactions between NRC staff, industry 

representatives and other stakeholders to understand the scope and schedule for industry 

activities related to degradation of buried piping. Minutes of previous meetings are available at 

Agencywide Document Access and Management System (ADAMS) Accession Numbers 

ML093070162, ML100810295, ML103230366, ML11137A171, and ML113210661. A list of 

meeting attendees is enclosed. The meeting notice and agenda is available at ADAMS 

Accession Number ML12079A167. 

At the beginning of the meeting, NRC staff reviewed the status of the NRC’s Buried Piping 

Action Plan, which is available at ADAMS Accession Number ML11332A122. The staff 

described the action plan activities, schedule for action, and reiterated NRC objectives with 

respect to buried piping. The staff described the temporary instruction (TI-182) for NRC to 

perform inspections of licensee activities related to the Buried Piping and Underground Piping 

and Tanks Integrity Initiatives. The staff indicated that SECY-12-0046, “OPTIONS FOR 

REVISING THE REGULATORY APPROACH TO GROUND WATER PROTECTION,” which is 

available at ADAMS Accession Number ML12025A113 is currently under Commission 

consideration. This SECY paper was prepared in response to the staff requirements 

memorandum for SECY-11-0019. 

Enclosure: 

As stated 

CONTACT: Robert O. Hardies, NRR/DE 

 (301) 415-5802 
D. Alley - 2 -

The industry provided updates on the implementation status of the current Buried Piping and 

Underground Piping and Tanks Integrity initiatives and discussed operating experience. The 

Electric Power Research Institute discussed progress and plans related to development and 

deployment of nondestructive examination equipment, processes and procedures. 

EPRI described the Buried Piping Integrity Task Force effort to collect and evaluate inquiries 

related to the Buried Piping and Underground Piping and Tanks Integrity initiatives. Task force 

members or industry program owners may submit questions to the task force seeking 

clarification or interpretation of the intent of the initiatives. The task force publishes its 

interpretations on the Nuclear Energy Institute website. Following the EPRI presentation, INPO 

reviewed operating experience related to degradation of buried and underground piping. 

The staff discussed changes to the Generic Aging Lessons Learned report, Revision 2, Aging 

Management Program XI.M41, “Buried and Underground Piping and Tanks.” Interim staff 

guidance has been issued for public comment. The industry discussed the draft guidance and 

requested additional time to gather and process comments related to the interim staff guidance. 

The staff agreed to consider the request. 

The American Society of Mechanical Engineers (ASME) discussed the status of Section XI 

buried piping activities, including plans and progress in the “Task Group Buried Component 

Inspection and Testing.” This task group is developing potential changes to the ASME Boiler 

and Pressure Vessel Code to address inspection, testing, mitigation, repair, replacement and 

design of buried and underground piping. Task Group action item status was reviewed. 

Meeting attendees were encouraged to participate in the Task Group. 

NACE International described ongoing activities in NACE Task Group 404, “Nuclear Buried 

Piping,” to develop buried piping inspection, assessment and corrosion prevention standards 

optimized for nuclear power plant applications. The Task Group has issued a draft summary 

report. Once the final report is issued, the Task Group will be retired and a new Task Group will 

be established to develop standards for cathodic protection, coatings, materials selection, NDE 

and training related to buried piping at nuclear plants. 

All presentations made at the meeting are available in ADAMS Accession number 

ML12094A004. 

During the previous meeting the following action items were recorded, with the current status 

noted: 

1) The NRC will continue discussions with industry related to determining a pre-initiative 

rate of occurrence of significant buried piping degradation events. (ongoing) 

2) The NRC will continue discussion with industry related to recording criteria for tabulating, 

categorizing and sorting instances of degradation of buried and underground piping. 

(ongoing) 

3) NEI will provide the NRC an opportunity to comment on the Groundwater/Underground 

Piping Initiative coordination document. A draft of this document was sent to the NRC 

on October 20, 2011. (complete) 
D. Alley - 3 -

During this meeting the following new action items were recorded: 

1) The staff will provide examples of events in EPIX that could be categorized in more than 

one manner and will discuss recommendations for prioritizing categories. 

2) The staff will discuss with NEI the possible uses of the “cause code” information being 

gathered in the EPIX database. 

3) The staff will notify industry when SECY-12-0046 becomes publically available. 

(completed after the meeting) 

The next meeting was tentatively scheduled for September, 2012. 
D. Alley - 3 -

During this meeting the following new action items were recorded: 

1) The staff will provide examples of events in EPIX that could be categorized in more than 

one manner and will discuss recommendations for prioritizing categories. 

2) The staff will discuss with NEI the possible uses of the “cause code” information being 

gathered in the EPIX database. 

3) The staff will notify industry when SECY-12-0046 becomes publically available. 

(completed after the meeting) 

The next meeting was tentatively scheduled for September, 2012. 

DISTRIBUTION: 

DCI R/F DE R/F RLaVera JIsom RConatser 

JStrishna AShaikh HGray RHardies MKing 

WHolston TKobetz 

Richard.hall@exeloncorp.com searsjt@inpo.org 

jhr@nei.org jabisam@entergy.com

geschinzel@stpegs.com Richard.hall@exeloncorp.com

dsmith@epri.com dlamond@aesengineering.com

Gabriel.OGUNDELE@kinectrics.com

ADAMS ACCESSION NO.: ML12116A043 

OFFICE NRR/DE 

NAME RHardies 

DATE 4/ 25 /2012 

 OFFICIAL RECORD COPY
 ENCLOSURE 

ATTENDANCE LIST

NAME AFFILIATION EMAIL

Robert Hadies NRC Robert.hardies@nrc.gov

David Alley NRC David.Alley@nrc.gov

Dan Lamond AES dlamond@aesengineering.com

Richard Hall Exelon Richard.hall@exeloncorp.com

Keith Hoffman NRC Keith.hoffman@nrc.gov

William Holston NRC William.Holston@nrc.gov

Mike Cheok NRC Michael.Cheok@nrc.gov

Richard Conatser NRC Richard.Conatser@nrc.gov

Bill Campbell Constellation William.Campbell@cengllc.com

Jason Grant Constellation Jason.Grant@cengllc.com

John Eastman FIRSTENERGY Jeastman@firstenergycorp.com

Jana Bergman CWFC/Scientech JBergman@curtisswright.com

Raj Auluck NRC Rajender.Auluck@nrc.gov

Cassandra Bitler INPO bitlercj@inpo.org

Viki Armentrout Dominion Viki.Armentrout@DOM.com

Ted Clark Entergy TIvy@entergy.com

Bo Clark EPRI BHClark@epri.com

Ron LaVera NRC Ronald.LaVera@nrc.gov

Dylan Cimock Exelon Dylan.Cimock@exeloncorp.com

Albert Piha Exelon Albert.Piha@exeloncorp.com

Craig McWhorter SNC jcmcwhor@southernco.com

Jim Riley NEI jhr@nei.org

Joe Sears INPO searsit@inpo.org

Eric Blocher STARS eric.blocher@aps.com

Davis Smith EPRI dsmith@epri.com

Steve Kenefick EPRI SKenefick@epri.com

Matthew Golliet Westinghouse GollieM@westinghouse.com