Underground Piping and Ta

Initiative - Update

Jim Riley, NEI

Joe Sears, INPO

October 9 2013 October

9, 2013
Overview

 Initiative Change Initiative Change Identif O yingutliers Initiative Implementation Report
UPTI Changes

 UPTI revision approved by NSIAC in Ja

2013

 NEI 09-14 rev 3 issued in May

– Main changes Main changes

• Incorporated Initiative changes• G id f diti i ti f 

Guidance for crediting inspections perfo

other programs

• D i ti i it ti Deviation process in its own section

• Emphasizes sharing of significant OE a

program issues program issues
Identifying Programmatic Outl

 How do we identify

– Differences in Initiative conformance Differences in Initiative conformance– Outliers in Initiative implementation or 

interpretation

 Methods

– Utilities communicate OE and program 

issues (NEI 09-14, section 5.1) to NEI BPITF

– INPO plant evaluation feedback

– OE discussion at BPIG
Overall Implementation Statu

Overall Implementation Statu
Overall Implementation Statu

 All plants have completed the first ei

milestones. 

– Initiative revision changed some milest

from

“at risk at risk

” to

“on schedule on schedule

”

 Positive or stable trends are indicate

each milestone

 Applicability of Initiative to shutdown 

must be determined
Milestone Trends Milestone Trends
NEI 09-14 INPO R ibil

14 INPO Responsibil

ibil

• Evaluate programs Evaluate programs• Communicate issues to the 

industry

• Comp pp g ile and re ile and report operating

experience to NSIAC

© 2013 Institute of Nuclear Power Operations 
Operating Experience
September 2013 Number of Reporte

E t b Y d F il M d Even

ts 

by 

Year an

d

F

ailure 

M

o

d

e

15

120

Advfi d

103

107

8

15

8

5

100

fi

nd

immOthor mSign

78

89

107

6080 Sign

Lea

40

5

12

4 4

2

4 15

2

0

20

© 2013 Institute of Nuclear Power Operations 

2009 2010 2011 2012 201
Operating Experience

 Decline in reported leaks due to remediatio

possibl t tt ti t th di t ti ibly 

to attention 

to cath

odic pro

tection

 Number of reported inspection findings ha

– Not all systems inspected yet– Possible inspection transient– Lag in reporting events (50 day expectation)

 Events should not be interpreted as definit

indication of a trend yet
Operating Experience

Most Commonly Most Commonly

Affected Systems Relative to NEI 09-14
Most Commonly y Affected Systems

250150200100

50

0

Potable 

Water 

Fire 

Protection 

Essential 

Service 

No Industry 

Std. Name 

Sanitary 

Waste 

Liquid Waste 

Management 

CVC/Makeup 

and 

Circulating 

Water 

Cond

Stora

© 2013 Institute of Nuclear Power Operations 

Distribution 

System

System 

(Water)

Water 

System

for this 

system

Processing 

System

System Purification 

Sys. (PWR)

Structures Tra

Sys
Most Commonly Affected Systems 

Relative to NEI 09 Relative Relative to NEI 09

-14

455035402530101520

05

© 2013 Institute of Nuclear Power Operations 

Essential Service 

Water System

Sanitary Waste 

Processing System

Liquid Waste 

Management System

CVC/Makeup and 

Purification Sys. (PWR)

Condensate Storage 

and Transfer System

W
Operating Experience

Operating Experience

 Plants characterize systems differently; especially 

systems are systems are

“run to failure run to failure

”

. This different charac

This different charac

makes interpretation of this data imprecise, but gobservations are possible

• The majority of buried and underground piping de

occurring on low risk or “run to failure” systems

• Ab t 20% f th i i d d ti h b 

Abou

t 20% o

f the piping 

degra

d

ation 

has 

been on 

is within the scope of the Initiative (safety related, licensed or environmentally sensitive materials)

• The relative percentages shown in the chart have 

significantly since the industry began reporting the 
Operating Experience
UPTI Failure Codes

Flange, seal, or 

mechanical joint 

failure Me

UPTI Failure Codes

Selective Leaching

0%

2% Other

40%

Me

Cracking

8%

Other Internal Internal

18%

General General Corrosion Corrosion

20%

Galvan

© 2013 Institute of Nuclear Power Operations 
Operating Experience

 The major reported failure cause is “o

 Use of this categorization (essentiall

of this categorization (essentiall

default) makes an evaluation of failu

t d ren

ds diffi lt difficult

 BPITF considering changes to “caus

codes” to provide better feedback on data 
AFI Review

Catego

 Leaks

– 

to address Program 

implemenimplemen

found in thindustry in

U/G & CP U/G

& CP 

Combinatprogram, protection CP - Excgaps in thprotection equipmen
Areas for Improvement Areas for Improvement

12

Leaks Program U/G & CP CP TO

Performance deficienc

8

10

6402

© 2013 Institute of Nuclear Power Operations 

2007 2008 2009 2010 2011 2012 
AFI Review

 General AFI observations

– 2007 – 2009: lack 2009: lack of underground pipin

of underground pipin

program monitoring and health assess

– 2011 and 2012: focused 2012: focused on implement

on implement

NEI 09-14 , safety related service wate

radioactive piping radioactive piping leaks, and mitigation 

and mitigation 

leaks 

– Gaps in the CP (cathodic protection) p

in the CP (cathodic protection) p

have increased as the role of cathodic 

protection is better understood protection is better understood
AFI Review AFI Review

 In 2012 In 2012, 4 AFIs on 4 AFIs on cathodic protectio

cathodic protectio

and 5 on underground piping

– I t dd mprovement needed on

• Risk ranking review • Extent of condition determination• Source of leaks• Inputting results in ICES • Cathodic protection health or none inst
2013 AFI Summary 2013 AFI Summary

• Four AFIs; Six Performance Deficiencies

– Two

– underground piping underground piping

– Eight – cathodic protection cathodic protection

• Improvement needed Improvement needed

– Degraded coatings and cathodic protectio

working

– Cathodic protection equipment work 

prioritization

– Cathodic Cathodic protection site knowledge weak

protection site knowledge weak

– Leaks occurring and the source is not occurring and the source is not 

determined

© 2013 Institute of Nuclear Power Operations 
AFI Review AFI Review

 Positive Findings

– Zero leak tolerance Zero leak tolerance – especially in pipin

especially in pipin

containing radioactive fluids

– Failure causes are being Failure causes are being identified identified– Risk ranking challenge boards are bein

established

– Cathodic protection installed– Effective station and corporate Effective station and corporate oversigh

oversigh

– Healthy collaboration between UP, CP 

GW

– Effective use of corrective action progra
EPRI NDE Technology Updat

 10 UPT NDE projects focusing on development, 

assessment, and implementation of NDE techno

 Acquiring UPT research results from the Pipelin

Acquiring UPT research results from the Pipelin

Research Council International (PRCI) 

 Establishing a framework to assess the reliability 

a framework to assess the reliability 

guided wave inspection results 

– Use as an examination method instead of screening to– Concept presented to the industry and to NRC staff

– Positive feedback



“Buried Pipe Nondestructive Evaluation Referen

Buried Pipe Nondestructive Evaluation Referen

Guide—Revision 2” publically available at no co

 Continued interest Continued interest in using in in using in

-line inspection line inspection tec

tec

– Use limited due to contingency considerations
Overall Observations

 Initiative change has reduced the risk 

missed milestones missed milestones

 No major new observations on leakag

or Initiative im

plementation

 Development of guided wave UT is im BPITF emphasizing ways to identify In

BPITF emphasizing ways to identify In

“outliers”

– INPO report– BPIG feedback– NEI 09-14 reporting
Overall Observations

 A li bilit f U d d Pi i 

Applicability o

f

U

n

dergroun

d Pi

ping 

Tanks Integrity Initiative to shutdown 

– UPTI not applicable to plants that have 

permanently shutdown once their 

decommissioning plan addresses comthat would otherwise be in-scope