NEI - Buried Pipe Integrity Task For

Underground Piping and Tanks Integrity 

David Smith

Program Manager-Balance of Plant Corrosion

NRC/Industry Meeting on Buried Pipe

April 4th, 2012 White Flint, MD

Underground Piping and Tanks Integrity 

Inquiries and Interpretations 
Today’s Discussion

• Inquiry Processes

– Submitting– Scope

© 2012 Electric Power Research Institute, Inc. All rights reserved.

2

– Methods of Evaluation

• Communication• Inquiries to Date
Inquiry Process

•How requests are submitted:

– Individual Task Force Members– Industry Program Owners

© 2012 Electric Power Research Institute, Inc. All rights reserved. 3

– Discussions at EPRI BPIG Meetings
Inquiry Process

•Scope of Inquiries

– NEI 09-14 – Inspection Planning Guidance Document

© 2012 Electric Power Research Institute, Inc. All rights reserved. 4

– Subject Categories

• Definitions• Technical Interpretations• Deviations
Inquiry Process

• Methods of Evaluation

– Based on the complexity of the Inquiry

• E-mail

© 2012 Electric Power Research Institute, Inc. All rights reserved. 5

• Webcast

– Reviewed by the NEI BPITF– Cycled for Concurrence– Consensus Agreement
Inquiries Communications

• 14 Inquiries and Interpretations•Responses provided by NEI BPITF•NEI post inquiries and responses on the N

B i d Pi i W b B d

© 2012 Electric Power Research Institute, Inc. All rights reserved.

6

Burie

d Pi

ping 

W

e

b

Boar

d

–Access the website to register

•Updates provided to the industry at BPIG M•New Inquiries in process
UPTI Inquiries to Date

Inaccessible Piping • Can you credit guided wave and an engineering evaluation 

with no access to excavate?

– Not in conformance with the RA document, document th

basis, but not a deviation from NEI 09-14

In Scope Tanks (2)

• Are tanks whose bottoms are in direct contact with the soil 

b l d ) i f th UPTI?

© 2012 Electric Power Research Institute, Inc. All rights reserved.

7

b

elow gra

d

e

) in scope 

for the UPTI?

• Are above ground tanks that contain licensed material in th

scope?

– No, per the definition of NEI 09-14 these tanks are not in 

UPTI. 

Condition Assessment

• Can guided wave inspection be credited for starting conditio

assessment of high risk licensed material lines by 6/30/12?

– No, NEI 09-14 and the Inspection Planning document re

one direct examination. 
UPTI Inquiries to Date

Pipe Encased in Concrete• Is an inspection required by 6/30/2013 for a pipe encased i

to satisfy NEI 09-14 for buried piping containing licensed m

– No, by definition, this piping would be considered underg

the condition assessment is required by 6/30/2014. 

Missed Piping• Some small sections of piping were missed during scoping 

k d b th i d UPTI d d t Thi it i 

© 2012 Electric Power Research Institute, Inc. All rights reserved.

8

ran

k

e

d

by the require

d UPTI

due 

d

a

te. This item was imme

entered into the corrective action program. Is this a deviatio

– No, these conditions are considered discovery and do n

intent of a deviation. 

Implementation of an Inspection or Condition Assessment Pl

• What is the definition of “start” for Inspection and Condition 

Assessment plans?

– Start should include one direct examination of piping inc

inspection plans. 
UPTI Inquiries to Date

Inspection and Examination Technologies (4)• Is an APEC Survey considered a direct or indirect inspection

– This technique cannot be credited as direct examination o

inspection for the purpose of Initiative inspection planning

• Can pulsed eddy current or remote field eddy current techno

used as a direct examination method?

© 2012 Electric Power Research Institute, Inc. All rights reserved.

9

– If the Station can demonstrate that the capabilities meet t

requirements for assessing condition they may be useablsituations. 

• Can pressure testing be used as a direct inspection?

– Hydrostatic testing is a potential exemption from inclusion 

inspection program and not considered a direct or indirec

• Do you need to perform direct examinations on medium risk 

– No, focus initial inspections on high risk ranked groups. 
UPTI Inquiries to Date

Licensed Material• What level of radioactivity is required to be classified a

material?

– The determination of licensed material must be ma

appropriate station personnel. 

UPTI Teams

• Are Buried and Underground Piping Team meetings a

© 2012 Electric Power Research Institute, Inc. All rights reserved. 10

Are Buried and Underground Piping Team meetings a

composition, as described in the EPRI recommendatiodocument, a requirement for the Initiative?

– No, the proposed team meetings are not a requirem

09-14. 

Adverse Inspection Findings Definition

• The INPO EPIX and NEI 09-14 definition of adverse in

findings are different, so which governs for the Initiativ

– The NEI 09-14 definition applies. 
Together...Shaping the Future of Elect

© 2012 Electric Power Research Institute, Inc. All rights reserved. 11