Buried and 

Underground Pipin

March 30, 2011

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 re

objectives

• NRC is monitoring and responding to events related to buried • NRC is working to understand and assess licensee implementa

Buried Piping Integrity Initiative and the Underground Piping Integrity Initiative
NRC Actions

• May 18, 2010, Buried Piping Action Plan (ML101480739)• September 14, 2010, Buried Piping Action Plan update 

(ML102590171)

• Meetings with industry 8/2009, 9/2009, 2/2010, 9/2010• Letter to industry August 18, 2010 (ML102300270)
Buried Piping Action Plan

• Data collection – Historical rate of incidence

– Affected systems– System classifications– Tritium releases

• Program assessment – Understand Buried Piping Integrity Initiative and Underground Piping a

Integrity InitiativeIntegrity Initiative

– Temporary Instruction for NRC inspection of Initiative activities

– Initiative details (scope, risk ranking, inspection techniques)

• Codes and standards• Regulatory activities

– Website

– License renewal– Commitments– Recommendations for rulemaking
NRC Information Request

• During August, 2010 NRC requested NEI assemble:

– Scope of piping subject to risk ranking

– Listing of degradation events– Mechanisms
Codes and Standards

• ASME Code

– Met with ASME, Section XI management August 6, 2010– In November Section XI established a committee to addre

from buried piping

• Consideration of enhanced inspection requirements• Consideration of extension of scope to nonsafety-related piping tha

tritium

– First meeting of the committee January, 2011

• NACE International (formerly National Association of Corros

Engineers)

– Task group to develop standards for nuclear buried piping– First task group meeting September, 2010– Meets September and March
NRC Actions

• Inspection

– Temporary Instruction for inspection of buried piping activ

• Made decision to generate a TI as part of the action pl• Implementation by June 2011• Temporary Inspection instructions may exist through 2

• Seeking to understand details:

Seeking to understand details:

– Risk ranking processes– Inspection techniques and processes

• License renewal

– Revised buried piping aging management program
NRC Actions

• Groundwater Task Force Report• Senior Management Review Group

– SECY-11-0019 (ML110050525)

– Commission meeting– ACRS sub- and main committee meetings– ACRS Letter (ML110730443)

• GAO Audit
Performance

• Seeking to establish a pre-2010 incidence rate for leaks as a pe

baseline

• Monitoring operating experience• Evaluating need for commitments for initiative
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 

objectives

• NRC is monitoring current events related to buried piping

NRC is monitoring current events related to buried piping

• NRC is performing action plan activities, including monitorin

initiatives