May 21, 2013 

MEMORANDUM TO: Patrick L. Hiland, Director 

 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 25, 2013, the U. S. 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 (INPO), 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, ML113210661, ML12116A043, 

and ML13050A590. A list of meeting attendees is enclosed. The meeting notice and agenda is 

available at ADAMS Accession Number ML13094A426. 

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

Action Plan which was scheduled to be updated to reflect completion of items. The update, 

revision 3, is available at ADAMS Accession number ML13107A984. The staff described the 

action plan activities, schedule for action, and reiterated NRC objectives with respect to buried 

piping. 

CONTACT: Robert O. Hardies, NRR/DE 

 (301) 415-5802 
- 2 - 

The industry discussed NEI Buried Piping Integrity Task Force activities including the 

implementation status of the current Buried Piping and Underground Piping and Tanks Integrity 

initiatives. The Nuclear Strategic Issues Advisory Council of NEI recently issued a revision to 

the initiative that aligned action item completion dates and scope between the initiatives. NEI 

planned to issue a revision to NEI 09-14 to reflect changes in the initiatives, clarify reporting 

expectations and revise the document structure. 

INPO described its assessment role, summarized industry performance and findings with 

respect to the initiatives, and reviewed the transition to a new operating experience database. 

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

and deployment of nondestructive examination equipment, processes and procedures. EPRI 

indicated they would be making the Buried Piping Nondestructive Examination Reference Guide 

publically available on the EPRI web site. EPRI requested further interaction with NRC staff to 

discuss the evolution of guided wave practices. The staff agreed to set up a meeting to review 

guided wave research progress. 

EPRI also reviewed the Buried Piping Integrity Group activities, including progress in populating 

the buried piping inspection results database. Insights from the database were provided. EPRI 

also discussed the activities of the Cathodic Protection Users Group. 

The staff discussed changes to interim staff guidance: “Aging Management of Internal Surfaces, 

Service Level III and Other Coatings, Atmospheric Storage Tanks, and Corrosion Under 

Insulation.” A notice of request for public comment on Draft LR-ISG-2012-02 was published in 

the Federal Register on April 12, 2013 (78 FR 21980). The public has until June 16, 2013 to 

comment on the draft LR-ISG. 

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. Phase I inspections were nearly completed. Phase II inspections have just started. 

Results from the few Phase II inspections that have been completed seem to indicate uniform 

implementation of the initiatives. The staff and industry discussed the impact on a plant’s 

decision to permanently shut down on their commitment to the initiative. The industry is still 

evaluating this situation. The NRC may address this issue on a plant specific basis. 

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. 

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. 

Staff from the NRC Office of Research presented an international regulators activity to 

catalogue regulatory practices at nuclear sites in a variety of countries. 

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

ML13133A206 (part of the package). 
- 3 - 

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

noted: 

1) Industry will discuss and address whether the initiative continues to be applicable to a 

plant that decides to cease permanent operations (discussed at this meeting). 

2) EPRI will determine whether EPRI report 1025220 can be made publically available (the 

report has been made publically available on the EPRI web site). 

3) The NRC will revise TI-182 to reference revision 2 of NEI-09-14 (the staff is in the 

process of incorporating revision 3). 

4) NRC and EPRI staff will initiate communications on guided wave inspections (discussed 

at this meeting). 

5) NRC and EPRI staff will exchange information on saturated eddy current examination 

(ongoing). 

During this meeting the following new action items were recorded: 

1) NRC and EPRI to establish a date to discuss guided wave practices. 

The next meeting is scheduled for October 9, 2013, at NRC headquarters. 

Enclosure: 

List of Attendees 

CONTACT: Robert O. Hardies, NRR/DE 

 (301) 415-5802 
- 3 - 

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

noted: 

6) Industry will discuss and address whether the initiative continues to be applicable to a 

plant that decides to cease permanent operations (discussed at this meeting). 

7) EPRI will determine whether EPRI report 1025220 can be made publically available (the 

report has been made publically available on the EPRI web site). 

8) The NRC will revise TI-182 to reference revision 2 of NEI-09-14 (the staff is in the 

process of incorporating revision 3). 

9) NRC and EPRI staff will initiate communications on guided wave inspections (discussed 

at this meeting). 

10) NRC and EPRI staff will exchange information on saturated eddy current examination 

(ongoing). 

During this meeting the following new action items were recorded: 

2) NRC and EPRI to establish a date to discuss guided wave practices. 

The next meeting is scheduled for October 9, 2013, at NRC headquarters. 

Enclosure: 

List of Attendees 

CONTACT: Robert O. Hardies, NRR/DE 

 (301) 415-5802 

DISTRIBUTION: 

DCI R/F DE R/F DAlley SGarry RConatser 

WHolston AShaikh HGray 

dsmith@epri.com jabisam@entergy.com

Michael.sears@exeloncorp.com dwittas@apsc.com

dlamond@aesengineering.com Gabriel.OGUNDELE@kinectrics.com

curtiss.blackwelder@duke-energy.com jhr@nei.org

searsjt@inpo.org 

ADAMS PACKAGE ACCESSION NO.: ML13133A206 

OFFICE NRR/DE 

NAME RHardies 

DATE 05/21/2013 

OFFICIAL RECORD COPY 
Enclosure 

List of Attendees 

Name Email Affiliation

David Alley David.Alley@nrc.gov NRC 

Tim Lupold Timothy.Lupold@nrc.gov NRC 

Rob Tregoning Robert.Tregonign@nrc.gov NRC 

James Isom James.Isom@nrc.gov NRC 

Richard Conatser Richard.Conatser@nrc.gov NRC 

Bob Hardies Robert.Hardies@nrc.gov NRC 

Curtis Blackwelder Curtiss.Blackwelder@Duke-energy.com Duke 

Michael Sears Michael.Sears@exeloncorp.com Exelon 

Doug Jones Djones7@entergy.com Entergy 

Daniel Wittas dwittas@apsc.com APS 

Viki Armentrout Viki.Armentrout@dom.com Dominion 

Ronald Chrzanowski chrzanowskira@inpo.org INPO 

Joseph Sears searsjt@inpo.org INPO 

Amy Hull Amy.hull@nrc.gov NRC 

Steve Kenefick skenefic@epri.com EPRI 

Mike Quarry mquarry@epri.com EPRI 

David Smith dsmith@epri.com EPRI 

Jim Riley jhr@nei.org NEI 

Dan Lamond dlamond@aesengineering.com AES