Buried and 

Underground Piping

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

• Current regulations and industry activities are adequate with 

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
3

Buried Piping Action Plan

• Revision 3 with updated completion dates to be 

issued presently

• No new action items
Ongoing Action Plan Items

• Gather leak and tritium release data

• Meet with industry

• Evaluate guided wave 

• Maintain NRC Public Website Buried Piping Page

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

• Participate in ASME and NACE activities

• Evaluate the need for regulatory changes
Ongoing Action Plan Items

• High pressure piping is given appropriate inspection priority and ASME 

Section XI IWA-5244 tests are being performed as required

• Stay abreast of ongoing industry research

• Evaluate need to change ROP

• Evaluate the need for regulatory changes
6

Codes and Standards

• ASME Code

– 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 

tritium

– Task Group on Buried Components Inspection and Testing

• NACE International (formerly National Association of Corrosion 

Engineers)

– Task groups to develop standards for nuclear buried piping
7

NRC Action

• License renewal

– 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

• Revision to reflect initiative and schedule changes to be 

issued 
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 

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 

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 

control...”
10

Conclusions

• NRC’s objectives related to buried piping 

• Maintenance of intended function 

• Releases remain below regulatory limits

• Current regulations and industry activities are compatible with 

these objectives

• NRC is monitoring current events related to buried piping

• NRC is performing action plan activities, including monitoring 

industry initiatives