B ried u and

Underground PipinUnderground Pipin

and Tanks and Tanks

Bob Hardies

Senior Level Advisor, NRR

October 9, 2013
Summary

• NRC’s objectives related to buried piping 

– Maintenance of intended nuclear operations safety fu– R l i b l l t li it Releases remain below regulatory limits

• Current regulations and industry activities are a

with regard to these objectives

• NRC is monitoring and responding to events re

NRC is monitoring and responding to events re

buried piping

• NRC is working to understand and assess licen

NRC is working to understand and assess licen

implementation of the Underground Piping and Integrity Initiative 
Buried Piping Action Plan

• Revision 3 Updated April, 17, 2013• No new action items
Ongoing Action Plan Items

• Gather leak and tritium release data• Meet with industry• Evaluate guided wave Evaluate guided wave

• Maintain NRC Public Website Buried Piping Page

• htt

p g p gp ://www.nrc.

gov/reactors/o

peratin

g/o

ps-ex

perience/b

piping-activities.html

• Participate in ASME and NACE activities
Ongoing Action Plan Items

• Hi

g p p p g g pp p p h 

pressure 

pipin

g is 

given appro

priate ins

pec

priority and ASME Section XI IWA-5244 tests arperformed as required

• Stay abreast of ongoing industry research• Evaluate need to change R

O

P

– Closed with no need to change ROP

• Evaluate the need for regulatory changes
Codes and Standards

• ASME Code

• Section XI established a committee to address leaks 

buried piping

» Consideration of enhanced inspection requireme

» C id ti f t i f t f t Consideration o

f ex

tension o

f scope 

to nonsa

f

e

t

related piping that contains tritium

• Task Group on Buried Components Inspection and T

• NACE International (formerly National Associat

Corrosion Engineers)

• Task groups to develop standards for nuclear buried 
NRC Action

• License renewal

• Revised buried piping aging management program• Internal corrosion and coatings ISGs under developm

• Inspection

• Temporary Instruction for inspection of buried piping 

activities

• Temporary Inspection instructions exists through 201• Seeking to understand commitment to minimizing lea• Revision 8/8/2013 to reflect initiative and schedule ch
TI 182

• The objective of the TI is to assess whether licen

are following the industry initiatives in a committenduring fashion

• Phase I is essentially complete.

– All licensees participating in the Underground Piping a

Integrity Initiative
TI 182 Preliminary Results

• Phase II less II less than

~20% percent complet

20% percent complet

• Some observations: Some observations:

– Relatively low turnover in buried piping syste

responsible individual

– System health reports useful
TI 182 Preliminary Results

• Some observations: Some observations:

– All plants inspected so far plants inspected so far

• risk ranking software or programs assessed to mat

objectives of the initiatives

• have completed their risk ranking in a manner that 

have completed their risk ranking in

a manner that 

characterized as appropriate
TI 182 Preliminary Results

• Some observations: Some observations:

– ~2/3 have cathodic protection

• Licensees with CP have generally either Licensees with CP have generally either

consistently maintained it, are actively refuor improving it, or have plans to replace or 

th t e sys

tem.

– ~1/3 never have had cathodic protectio

installed.
TI 182 Preliminary Results

• Some plants have no high risk piping or t

Some plants have no high risk piping or t
TI 182 Preliminary Results

• Some observations: Some observations:

– All plants inspected are performing the ASME 

pressure testing, or are performing approved alternatives.

– Th ll l i t thi i t i ti i 

The overall conclusion a

t this poin

t in time is 

licensees seem to be implementing the initiatcommitted and effective fashion.
HDPE Pipe

• ASME still working on code cases ASME still working on code cases

– Probably several years before completed and 

implemented in NRC Regulatory Guide

• NRC will entertain relief requests• NRC intends to develop guidance for relie

requests

– E h d l bli i i N b Expect to schedule public meeting in Novemb
Conclusions

• NRC’s objectives related to buried piping 

• M i t f i t d d f ti Maintenance of intended function 

• Releases remain below regulatory limits

• Current regulations and industry activities are c

Current regulations and industry activities are c

with these objectives

• NRC is monitoring current events related to bu

NRC is monitoring current events related to bu

• NRC is performing action plan activities, includ

monitoring industry initiatives monitoring industry initiatives