UPTI Initiative Revision 

and

Revision 3 to NEI 09-14

Jim Riley

April 25, 2013
UPTI Initiative Changes

 Proposed by the BPITF in response to 

cumulative effects

 Guiding thoughts

– Minimize effect on public confidence goal and 

regulatory credibility

– Achieve cost savings or deferral

– Maintain planning or inspection start 

milestones

 Supported by inspections completed with no 

significant findings to date
UPTI Changes

 Scope: Both BPI and UPTI applicable to buried 

and underground piping and tanks that are 

– Below grade and 

– Outside of buildings and

– Safety related or 

– Contain licensed material or

– Contain environmentally sensitive material

•No intended change from “environmentally 

hazardous” 
UPTI Changes

 Milestones

– BPI inspection of piping containing licensed 

material by 12/31/14 (18 month delay)

– UPTI inspection of piping and tanks containing 

licensed material by 12/31/14 (6 month delay)

– Buried Piping asset management plan complete 

by 12/31/14 (12 month delay)
UPTI Changes

 NSIAC approved on January 30th

 Another revision to NEI 09-14 is underway
NEI 09-14 Rev 3

 Revision incudes:

– UPTI changes

– Guidance for crediting inspections 

performed in other programs

– Clarified reporting expectations

– Moved guidance on deviations to its own 

section

– Editorial changes
Definitions

 Buried and underground

– Did not change definitions

– Programs are established and relationship to 

GALL is understood

 Environmentally hazardous

– Revised Initiative uses the term 

“environmentally sensitive” instead of 

“environmentally hazardous” 

– Difference was inadvertent

– “Environmentally hazardous” is used
Scope

 All buried and underground piping and tanks 

that are outside of a building and below 

grade (whether or not they are in direct 

contact with the soil) if they

– Are safety related 

 Or 

– Contain licensed material or are known to be 

contaminated with licensed material

 Or

– Contain environmentally hazardous material.
Milestones

 3.3.A.4 - Plan Implementation – Implementation of the Inspection 

Plan shall start no later than June 30, 2012. The condition 

assessment of buried piping containing radioactive material shall be 

completed by December 31, 2014.

 3.3.A.5 - Asset Management Plan – Inspection results shall be used 

as input to the development of an asset management plan for buried 

piping. This plan shall receive a high level of review and approval and 

will be in place by December 31, 2014.

 3.3.B.4 - Plan Implementation – Implementation of the Condition 

Assessment Plan for underground piping and tanks shall start no 

later than June 30, 2013. The condition assessment of underground 

piping and tanks containing radioactive material shall be completed 

by December 31, 2014.
Reporting

 Clarified reporting expectations affected by 

UPTI scope change

– “Shall” report

•Results from inspections of piping and tanks 

within the scope of the Initiative to EPRI (BPIG)

•All occurrences of leakage to INPO’s 

Consolidated Event System (ICES) 

•Adverse inspection findings to ICES
Reporting

 Clarifications (continued)

– “Should”

•Report relevant information from inspections of all

underground or buried piping and tanks to EPRI 

(BPIG)

•Perform periodic program self assessments

•Contact NEI and EPRI (BPIG) in a timely manner 

with

– Instances of significant buried piping program problems, 

– Significant leakage or adverse inspection findings of piping 

and tanks within the scope of the Initiative 
Initiative Intent

 6.2.4 Plan Implementation (BPI and UPTI)

– Inspections performed under other site 

requirements or processes may be used to 

meet this milestone as long as they meet 

the intent of Appendix C. This judgment 

should be documented and retained within 

the buried piping or underground piping 

and tanks programs.
Initiative Intent

 6.2.9 Plan Implementation (UPTI)

– January 2013 revision may have added scope 

– Starting inspections by June 30, 2013 may not 

allow adequate time for planning 

– Start date does not apply to the components 

added by the January 2013 change
Issue and Implementation

 Revision 3 will be issued soon

 Implementation expected within 6 months of 

issue

 Changes in milestone dates were applicable 

upon NSIAC approval of the Initiative 

(January 30, 2013)