December 3, 2015 

MEMORANDUM TO: Marissa G. Bailey, 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: BURIED PIPING ACTION PLAN UPDATE 

In SECY-09-0174 (Agencywide Documents Access and Management System (ADAMS) 

Accession Number ML093160004) dated December 2, 2009, the staff reviewed codes, 

standards, regulations and industry practices related to degradation of buried piping and 

identified a number of ongoing activities. The Buried Piping Action Plan (initial plan ADAMS 

Accession Number ML101380697, Revision 1 ADAMS Accession Number ML102590171, 

Revision 2 Adams Accession Number ML11332A122, and Revision 3 Adams Accession 

Number ML13107A984) described and tracked the ongoing activities related to buried piping. 

The enclosure to this memorandum provides an updated plan that reflects completion of all 

activities and closure of the action plan. 

Enclosure: 

NRR Action Plan 

CONTACT: Robert O. Hardies, NRR/DE 

 (301)-415-5802 
December 3, 2015 

MEMORANDUM TO: Marissa G. Bailey, 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: BURIED PIPING ACTION PLAN UPDATE 

 In SECY-09-0174 (Agencywide Documents Access and Management System (ADAMS) 

Accession Number ML093160004) dated December 2, 2009, the staff reviewed codes, 

standards, regulations and industry practices related to degradation of buried piping and 

identified a number of ongoing activities. The Buried Piping Action Plan (initial plan ADAMS 

Accession Number ML101380697, Revision 1 ADAMS Accession Number ML102590171, 

Revision 2 Adams Accession Number ML11332A122, and Revision 3 Adams Accession 

Number ML13107A984) described and tracked the ongoing activities related to buried piping. 

The enclosure to this memorandum provides an updated plan that reflects completion of all 

activities and closure of the action plan. 

Enclosure: 

NRR Action Plan 

CONTACT: Robert O. Hardies, NRR/DE 

 (301)-415-5802 

DISTRIBUTION: 

KHoffman MKing RLaVera WHolston DHills SVias 

DE R/F AShaikh HGray IAnchondo ASengupta MGray 

SWalker HGepford 

ADAMS ACCESSION NO.: ML15316A847

OFFICE NRR/DE NRR/DE 

NAME RHardies MRoss-Lee 

DATE 11/16/2015 12/03/2015 

 OFFICIAL RECORD COPY
ENCLOSURE 

NRR ACTION PLAN 

Complete 

November, 2015 

BURIED PIPING 

TAC NO. ME3939 Last Update: April, 2013 

Lead Division: DE 

Supporting Division(s): DLR, DIRS, DPR, DRA 

Supporting Office: NRO, RES, Regions, OCA, OPA 

Description: 

Some sections of buried piping at some nuclear power plants degraded to the point that through 

wall leakage occurred. In most cases leakage has been observed in non-safety related, nonnuclear applications. In a few cases leaks have occurred through safety related piping or piping 

that contained radioactive material. In a few cases this led to releases of tritium into 

groundwater, which generated significant stakeholder interest. Leaks from degraded buried 

piping are responsible for less than approximately 10% of reported abnormal releases of tritium 

from nuclear power plants. The U.S. Nuclear Regulatory Commission (NRC) staff, in SECY 09-

0174 (ML093160004), reviewed codes, standards, regulations and industry practices related to 

degradation of buried piping and identified a number of ongoing activities. This action plan 

tracked those activities. 

Background: 

Leaks from buried piping, particularly of tritiated water, have attracted significant stakeholder 

attention. For example, during 2009 buried piping leaks introduced water that contained low 

levels of tritium into the groundwater at Dresden, Oyster Creek and Peach Bottom nuclear 

plants. The levels of tritium did not exceed any NRC limits (that would be applicable on-site) 

and, after additional dilution and decay that would occur as a natural consequence of migration 

toward the site boundary, would not exceed any NRC limit offsite. Although these leaks did not 

exceed any NRC limits, either on-site or offsite, the level of tritium triggered the licensees to 

initiate voluntary communications with local and state officials. In response to these leakage 

events the staff performed a collective significance review of buried piping degradation. In 

September 2009, the Chairman issued a tasking memorandum that required the staff to review 

the adequacy of regulations, codes, standards and industry activities related to degradation of 

buried piping. In response, the staff prepared SECY 09-0174 (ML093160004), which concluded 

that no immediate regulatory changes were necessary to address degradation of buried piping 

because a) leakage from buried piping was of low safety significance with respect to structural 

integrity of the piping, and b) the amount of radioactive material that has been released has 

been a small fraction of regulatory limits. 

The SECY paper described a number of ongoing staff, codes and standards, and industry 

activities. The staff identified plans to review operating experience to continue to validate 

conclusions in the SECY paper. The staff indicated it would continue its participation in codes 

and standards organizations efforts to incorporate changes in the state-of-the-art with respect to 

maintenance and evaluation of buried piping. Independent of the staff’s actions, the nuclear 
- 2 - 

industry developed, and in November 2009, issued their “Buried Piping Integrity Initiative,” an 

executive level inter-utility agreement to address degradation of buried piping. The staff 

identified actions necessary to understand the breadth of implementation and effectiveness of 

this initiative. The staff also identified actions related to license renewal, new reactors, and the 

need to communicate about buried piping issues with licensees and other stakeholders. 

The NRC defines buried piping as piping that is underground and in contact with soil or 

concrete. In September 2010, the industry developed the Underground Piping and Tanks 

Integrity Initiative, which extended the objectives and actions in the Buried Piping Integrity 

Initiative to tanks that are partly or entirely below the surface of the ground and piping that is 

below the surface of the ground, but that does not contact soil because the piping is in chases, 

vaults or tunnels. Actions in this plan that previously applied only to the Buried Piping Integrity 

Initiative applied to the full scope of both industry initiatives. 

During 2010-2011, the Government Accountability Office (GAO) performed a review of NRC 

activities related to buried and underground piping. The GAO issued a report, 

“Oversight of Underground Piping Systems Commensurate with Risk, but Proactive 

Measures Could Help Address Future Leaks,” GAO-11-563, June 3, 2011, that contained a 

recommendation for the staff to keep abreast of emerging inspection technology. A 

milestone was added to the plan to specifically address the GAO recommendation. 

In August, 2011, the Commission issued a staff requirements memorandum (SRM) addressing 

SECY 2011-0019 that approved the staff’s continued efforts to work with industry initiatives and 

consensus standards organizations. This SRM also stated “if, based on its participation in 

consensus standard activities the staff determines that revisions to the agency’s regulations are 

necessary to incorporate changes to the ASME codes related to groundwater protection, the 

staff should seek Commission approval via a notation vote paper.” An action item was added to 

address this requirement. 

In February, 2013, the industry issued revisions to the Buried Piping Integrity Initiative and 

Underground Piping and Tanks Integrity Initiatives. The revisions changed dates for actions in 

the initiatives; the changes did not affect due dates for activities in this action plan. 

In July, 2014 the NRC completed activities associated with Temporary Instruction TI-182 and 

verified all plants were following the industry’s Buried Piping Integrity Initiative and Underground 

Piping and Tanks Integrity Initiatives. 

In November, 2015 the NRC had completed all action items and closed the action plan. Certain 

activities will continue, such as maintaining the website, participating in codes and standards 

activities, and periodically meeting with industry, but the activities no longer need to be tracked 

by an action plan. 

Regulatory Outcome: 

In SECY 09-0174 the staff concluded that current regulations, codes, standards and industry 

activities had been adequate to ensure: a) leakage from buried piping has been of low safety 

significance with respect to structural integrity of the piping, and b) the amount of radioactive 
- 3 - 

material that has been released has been a small fraction of regulatory limits. Continued 

validation of these conclusions is one of the outcomes of this action plan. In addition, this plan 

tracked interaction with industry to understand whether, by 2015, their Buried Piping and 

Underground Piping and Tanks Integrity Initiatives ultimately reduce the incidence of 

degradation and leaks. 

Over the course of the six years while the action plan was in place leakage associated with 

buried piping and underground tanks, when it has occurred, a) has been of low safety 

significance with respect to structural integrity, and b) the amount of radioactive material that 

has been released has been a small fraction of regulatory limits. Furthermore, over that time 

period rates of significant leakage events as tracked by the Institute of Nuclear Power 

Operations initially increased, and has since exhibited a decreasing trend consistent with 

improved maintenance and inspection practices. Reported significant leaks, those in safety 

related piping or in piping containing environmentally hazardous material, increased from 8 to 

15 from 2009 to 2010, but have since decreased to 8 in 2011, 5 in 2012, 4 in 2013, and 3 in 

2014 (ML15023A499). 

Project success criteria include: 

Licensees adequately implement the Buried Piping Integrity and Underground Piping and Tanks 

Integrity Initiatives, and the initiative activities are effective in addressing degradation of buried 

piping. 

Stakeholders are informed of and educated about the safety and environmental significance of 

degradation of buried piping, and are adequately and appropriately informed about the potential 

increase in reported degradation expected over the next 3-4 years. 

Current regulations, codes, standards and industry activities continue to be adequate to ensure: 

a) leakage from buried piping has been of low safety significance with respect to structural 

integrity of the piping, and b) the amount of radioactive material that has been released has 

been a small fraction of regulatory limits. If operational or other information becomes available 

that requires a change in these conclusions, appropriate regulatory action is to be initiated via 

generic communication, revision to the NRC inspection activities, or rulemaking, as appropriate. 

The milestones in the action plan, and documents or products that result from completed 

milestones should be publicly available. Planning information, personnel assignments and draft 

documents will not, in general, be made public. 

Assessment: 

Over the course of the six years while the action plan was in place leakage associated with 

buried piping and underground tanks, when it has occurred, a) has been of low safety 

significance with respect to structural integrity, and b) the amount of radioactive material that 

has been released has been a small fraction of regulatory limits. Furthermore, over that time 

period rates of significant leakage events as tracked by the Institute of Nuclear Power 

Operations initially increased, and has since exhibited a decreasing trend consistent with 

improved maintenance and inspection practices. Reported significant leaks, those in safety 
- 4 - 

related piping or in piping containing environmentally hazardous material, increased from 8 to 

15 from 2009 to 2010, but have since decreased to 8 in 2011, 5 in 2012, 4 in 2013, and 3 in 

2014 (ML15023A499). 

Milestones, Update Frequency, and Scheduled Dates for Completion: 

The action plan will no longer be updated. 

Number Milestone Date (T=Target)

(C=Complete) 

1-1 Develop list of historical buried piping 

degradation incidents (target 1990-

present) 

8/2010 C 

1-2 Update list of buried piping 

degradation incidents (Ongoing 

through 12/2015. Milestone is semiannual, update may occur more 

frequently) 

5/2015 C 

1-3 Acquire from the industry, review and 

assess a listing of buried piping 

systems at nuclear power plants. 

Specifically determine whether there 

is any buried ASME Class 1 piping. 

(request list from Buried Piping 

Initiative Executive) 

5/2011 C 

1-4 Develop an historical listing of 

abnormal liquid releases of tritium that 

have affected groundwater at nuclear 

power plants (ML101270439) 

(target 1990-present) 

12/2012 C 

1-5 Update listing of abnormal tritium 

releases at nuclear power plants 

(Ongoing through 12/2015. Milestone 

is semi-annual, update may occur 

more frequently) (ML101270439) 

12/2010 C 

6/2011 C 

12/2011 C 

6/2012 C 

12/2012 C 

11/2015 C 

1-6 Compile and evaluate available buried 

piping degradation and leakage event 

causal information 

6/2011 C 

1-7 Using output from the Temporary 

Instruction, verify that buried high 

pressure piping (over 275 psi) is 

identified and given appropriate 

inspection priority, and that ASME 

Section XI IWA-5244 Buried 

Component pressure tests have been 

3/2015 C 
- 5 - 

and are being periodically performed 

1-8 Evaluate the need to issue generic 

communication to collect information 

necessary to complete items 1-6 and 

1-7 

5/2011 C 

1-9 Using historical buried piping 

degradation event information 

developed in step 1-1, establish a pre2010 rate of occurrence of buried 

piping degradation events 

4/2013 C 

1-10 Review the Groundwater 

Contamination task force final report 

for consistency with the buried piping 

action plan. Consider additional 

actions/milestones based on 

recommendations from the GW task 

force pertaining to buried piping. 

7/2010 C 

2-1 Assess the Buried Piping Integrity 

Initiative through a series of public 

meetings with industry (Summaries on 

website) 

2/2010 C 

9/2010 C 

3/2011 C 

10/2011 C 

4/2012 C 

12/2012 C 

2/2015C 

2-2 Identify staff training needs with 

respect to the EPRI buried piping 

program, guided wave ultrasonic 

examination technology, NACE 

standards, cathodic protection system 

assessment, risk ranking and other 

relevant training 

10/2010 C 

2-3 Evaluate need to develop Temporary 

Instruction for inspection of Buried 

Piping Integrity initiative activities and 

if necessary, develop draft TI 

9/2010 C 

2-4 If required as outcome of 2-3, issue 

Temporary Instruction for inspection 

of Buried Piping Integrity initiative 

activities 

12/2011 C 

2-5 If required as outcome of 2-3, 

implement Temporary Instruction 

12/2011 C 

2-6 Using information from 1-9 and 1-2, 

determine whether the incidence of 

degradation of buried piping 

decreases after implementation of the 

Buried Piping Integrity Initiative 

9/2015 C 

2-7 Determine whether the Buried Piping 9/2010 C 
- 6 - 

Integrity Initiative addresses pipe 

systems in vaults that, while not soil 

covered, may be subject to 

degradation similar to buried pipe 

components and/or where the extent 

of inspection or observation is limited 

2-8 Evaluate the qualification and 

application of guided wave ultrasonic 

inspection techniques for evaluation of 

piping condition (annual status 

reports) 

5/2011C 

5/2012 C 

5/2015 C 

2-9 Assess Buried Piping Integrity 

Initiative risk ranking processes 

12/2012 C 

2-10 Stay abreast of ongoing industry 

research to develop technologies for 

structural integrity tests, and when 

they become feasible, analyze costs 

to licensees of implementing these 

tests compared with the likely benefits 

to public health and safety.

5/2015 C 

3-1 Participate in NACE standards 

activities to develop nuclear industryspecific corrosion prevention and 

inspection standards (Ongoing 

through 12/2015. Milestone is semiannual, update may occur more 

frequently) 

12/2010 C 

6/2011 C 

12/2011 C 

6/2012 C 

12/2012 C 

11/2015 C 

3-2 Participate in ASME standards 

activities to incorporate into the code 

state-of the art design, evaluation and 

inspection technologies (Ongoing 

through 12/2015. Milestone is semiannual, update may occur more 

frequently) 

12/2010 C 

6/2011 C 

12/2011 C 

6/2012 C 

12/2012 C 

11/2015 C 

3-3 Meet with ASME management at the 

August 2010 Code meeting in 

Washington to discuss ASME plans 

with respect to buried piping. 

9/2010 C 

4-1 Issue draft revision of aging 

management programs for buried 

piping and buried tanks in GALL for 

public comment 

5/2010 C 

4-2 Issue GALL revision 1/2011 C 

4-3 Develop RAIs for all current LRA 

applicants to address augmented 

requirements in Buried Pipe Programs 

based on industry OE 

11/2010 C 
- 7 - 

4-4 Provide OE data on buried and 

underground pipe leakage or 

degradation to the PI&R Inspection 

Teams to inform that inspection 

process 

10/2010 C 

4-5 Evaluate the need to issue generic 

communication soliciting licensee 

commitments to the Buried Piping 

Integrity Initiative (Ongoing through 

12/2015. Milestone is semi-annual, 

update may occur more frequently) 

11/2010 C 

5/2011 C 

12/2011 C 

6/2012 C 

12/2012 C 

5/2015 C 

4-6 Evaluate the staff’s treatment of 

licensee commitments with respect to 

Regulatory Guide 1.143 

12/2011 C 

4-7 Update buried piping website bimonthly 11/2015 C 

4-8 Evaluate the need to make changes 

to the Reactor Oversight Process 

based on results of the TI inspections 

7/2013 C 

4-9 Develop and post on website a 

description of the expected increase 

in leak discovery due to an increase 

in inspection 

9/2010 C 

4-10 Evaluate the need to recommend 

rulemaking to require enhanced 

maintenance, corrective action, and 

aging management programs for 

these systems, structures and 

components that contain radioactive 

materials. Consider the interim 

results of item 2-10. 

11/2015 C 

4-11 In accordance with Staff 

Requirements Memorandum for 

SECY 2011-0019, revise LIC-300 to 

capture the requirement, for certain 

rulemakings related to the ASME 

Code updates that affect groundwater 

protection, for the responsible 

technical organization to prepare a 

notation vote paper (separate from the 

rule package) for Commission 

consideration. 

9/2012 C 

Current Status: Complete 
- 8 - 

Contacts: 

 

DE: R. Hardies, D. Alley 

DIRS: M. King 

DRA S. Garry 

DPR: T. Inverso 

DLR: W. Holston, B Allik 

NRO: R. LaVera 

OPA: S. Burnell 

OCA: E. Dicus 

Region I: M. Gray, E. Gray 

Region II: S. Walker,A. Sengupta 

Region III: D. Hills, A. Shaikh 

Region IV: H. Gepford, I. Anchondo 

References: 

EVALUATION OF BURIED PIPING AT NUCLEAR REACTOR FACILITIES, September 3, 2009 

(ML092460648) 

STAFF PROGRESS IN EVALUATION OF BURIED PIPING AT NUCLEAR REACTOR 

FACILITIES, SECY 09-0174, December 2, 2009 (ML093160004) 

 

Industry Initiative on Buried Piping Integrity, November 20, 2009 (ML093350032) 

Industry Initiative on Groundwater Protection, July 31, 2006 (ML062260198) 

SUMMARY OF CATEGORY 2 PUBLIC MEETING BETWEEN THE U.S. NUCLEAR 

REGULATORY COMMISSION AND INDUSTRY REPRESENTATIVES TO DISCUSS BURIED 

PIPING ISSUES, November 2, 2009 (ML093070150) 

SUMMARY OF CATEGORY 2 PUBLIC MEETING BETWEEN THE U.S. NUCLEAR 

REGULATORY COMMISSION AND INDUSTRY REPRESENTATIVES TO DISCUSS THE 

INDUSTRY’S BURIED PIPING INTEGRITY INITIATIVE, March 24, 2010 (ML100820453) 

SUMMARY OF CATEGORY 2 PUBLIC MEETING BETWEEN THE U.S. NUCLEAR 

REGULATORY COMMISSION AND INDUSTRY REPRESENTATIVES TO DISCUSS THE 

PROGRESS ON THE INDUSTRY’S BURIED PIPING INTEGRITY INITIATIVE, September 21, 

2010 (ML103230366) 

Underground Piping and Tanks Integrity Initiative, September 27, 2010 (ML110700121) 

SUMMARY OF 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 INTEGRITY INITIATIVES, March 30, 2011 (ML11137A160) 
- 9 - 

GAO Report “Oversight of Underground Piping Systems Commensurate with Risk, but 

Proactive measures Could Help Address Further Leaks,” GAO-11-563, June 2011 

NRR Yellow Ticket Number: YT20100098, Buried Piping Action Plan 

Staff Requirements Memorandum, SECY 2011-0019 

SUMMARY OF 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 INTEGRITY INITIATIVES, October 20, 2011 (ML113210661) 

SUMMARY OF 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 INTEGRITY INITIATIVES, April 4, 2012 (ML12116A043) 

SUMMARY OF 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 INTEGRITY INITIATIVES, December 5, 2012 (ML13050A590) 

NEI 09-14, Rev 2, “GUIDELINE FOR THE MANAGEMENT OF UNDERGROUND PIPING AND 

TANK INTEGRITY” (ML13086A086 and ML13086A089)

NEI Revision to the Industry Initiative on Underground Piping and Tanks Integrity, February 8, 

2013 (ML13079A318) 

SUMMARY OF 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 INTEGRITY INITIATIVES, May 21, 2013 (ML13133A253) 

SUMMARY OF 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, October 30, 2013 (ML13301A792) 

SUMMARY OF 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 July 11, 2013 (ML14184B374) 
- 10 - 

SUMMARY OF 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, April 2, 2015 (ML15092A805)