July 7, 2014 

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 JUNE 11, 2014 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 INITIATIVE 

On June 11, 2014, 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 (EPRI), the Institute for Nuclear Power Operations (INPO), 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 and underground piping and tanks. Minutes of previous meetings are available at 

Agencywide Document Access and Management System (ADAMS) Accession Numbers 

ML093070162, ML100810295, ML103230366, ML11137A171, ML113210661, ML12116A043, 

ML13050A590, ML13133A206, and ML13301A792. A list of meeting attendees is enclosed. 

The meeting notice and agenda is available at ADAMS Accession Number ML14147A341. 

Meeting presentations are available at ADAMS Accession Number ML14184B374. 

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

Action Plan. The staff described the action plan activities, schedule for action, and reiterated 

NRC objectives with respect to buried piping. The staff described the temporary instruction (TI182) for NRC to perform inspections of licensee activities related to the Buried Piping and 

Underground Piping and Tanks Integrity Initiatives. Phase I inspections are complete. Phase II 

inspections are approximately 90 percent complete. Results from the Phase II inspections that 

have been completed seem to indicate uniform implementation of the initiatives. 

Enclosure: 

Attendance list 

CONTACT: Robert O. Hardies, NRR/DE 

 (301) 415-5802 
P. Hiland - 2 - 

NEI provided an update of Underground Piping and Tanks Initiative activities including initiative 

changes, treatment of outliers and overall implementation status. The NEI presentation 

indicated that all plants have met the Initiative milestones to date and are on track to meet future 

milestones. There was a discussion about the role of the initiative at plants that permanently 

shut down. The industry indicated that those plants would cease to be participants in the 

initiative once they declared that they had permanently ceased operations. This was a change 

from previous guidance that those plants would continue to be subject to the initiative until the 

decommissioning plan is implemented. Industry is still defining the timing of the transition. 

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

respect to the initiatives. INPO provided a historical overview of inspection findings and 

recommendations, and also summarized currently available operating experience. 

EPRI discussed progress and plans related to development and deployment of nondestructive 

examination equipment, processes and procedures. Highlights included descriptions of buried 

pipe inspection technology, tank inspection technology, guided wave for direct inspections, 

future research plans and currently available publications. 

A representative of 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. 

A representative of 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. 

The following action items were recorded at previous meetings, with the current status noted: 

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

(ongoing). 

2) NEI, INPO and NRC will discuss changing the graphical depiction of industry events 

such as leaks and significant degradation with the objective of more effectively 

demonstrating trends in the performance of piping and tanks that are safety related or 

contain radiologic or environmentally hazardous materials (ongoing). 

3) NRC and NEI to discuss examples of regulatory methods used in some previous 

applications for qualification or demonstration of NDE techniques (ongoing). 

The following new action items were recorded at this meeting: 

1. Industry will provide more details about the industry process to formally transfer licensee 

jurisdiction of the underground components from the underground piping and tanks 

initiative to the decommissioning transition plan. 

2. EPRI will ensure the relationship between license renewal and the initiative will be 

discussed at the Buried Piping Integrity Group meeting in July, 2014.
P. Hiland - 3 - 

3. The industry will provide feedback to the NRC about whether the guided wave guidance 

document will be published in time to be considered for incorporation into the next 

revision of interim staff guidance on buried and underground piping. 

The next meeting is tentatively scheduled for mid-January, 2015, at NRC headquarters. 
P. Hiland - 3 - 

3) The industry will provide feedback to the NRC about whether the guided wave guidance 

document will be published in time to be considered for incorporation into the next 

revision of interim staff guidance on buried and underground piping. 

The next meeting is scheduled for mid-January, 2015, at NRC headquarters. 

DISTRIBUTION: 

DCI R/F DE R/F DAlley SGarry RConatser 

WHolston AShaikh HGray KHoffman TLupold 

IAnchondo ASengupta MRoss-Lee 

dsmith@epri.com 

dwittas@apsc.com

Gabriel.OGUNDELE@kinectrics.com 

searsjt@inpo.org 

 

 

Herbertm@dnfsb.gov

dlamond@aesengineering.com

mar@nei.org 

skenefick@epri.com 

 

ADAMS ACCESSION NO. 

PACKAGE: ML14184B374 

SUMMARY: ML14169A285 

NOTICE: ML14147A341 

OFFICE NRR/DE 

NAME RHardies 

DATE 07/07/2014 

 OFFICIAL RECORD COPY 
ENCLOSURE 

List of Attendees 

Name Email Affiliation 

David Alley David.Alley@nrc.gov NRC 

Steve Kenefick skenefic@epri.com EPRI 

Mark Richter mar@nei.org NEI 

Daniel Wittas dwittas@apsc.com APS 

Keith Hoffman Keith.hoffman@nrc.gov NRC 

Bob Hardies Robert.Hardies@nrc.gov NRC 

David Smith dsmith@epri.com EPRI 

Chris Earls (phone) cee@nei.org NEI 

Joseph Sears searsjt@inpo.org INPO 

Steve Vitto Steven.vitto@nrc.gov NRC 

Steve Biagiotti (phone) SBiagiotti@Structint.com SAI 

Luis Terrazas Lterraz@entergy.com Entergy 

Herb Massie Herbertm@dnfsb.gov DNFSB 

Abdul Sheikh abdulhaisheikh@nrc.gov Private Citizen 

Phil Kohn Philip.kohn@dule-energy.com Duke