JAMES H. RILEY

Technical Advisor

1201 F Street, NW, Suite 1100

Washington, DC 20004

P: 202.739.8130

jhr@nei.org

nei.org

APC 13-11

May 1, 2013

To: Administrative Points of Contact

Subject: Issuance of Revision 3 to NEI 09-14, Guideline for the Management of Buried Piping 

Integrity 

Please distribute this letter to managers in your Design and Systems engineering departments, 

as well as personnel responsible for buried piping programs.

The NSIAC approved the Buried Piping Integrity Initiative in November, 2009 and the Underground Piping 

and Tanks Integrity Initiative in September, 2010. Since that time, the industry has been challenged by a 

number of new activities that have significantly increased licensee burden. As part of an effort to 

concentrate utility resources on safe plant operation and the most safety significant issues, late last year the 

Buried Piping Integrity Task Force recommended changes to the Underground Piping and Tanks Integrity 

Initiative that reduce its scope and defer some of its milestones. The NSIAC approved the recommended 

changes on January 30, 2013. This letter distributes Revision 3 to NEI 09-14 (the document that guides 

implementation of the Underground Piping and Tanks Integrity Initiative) which reflects the Initiative 

change. Revision 3 to NEI 09-14 should be incorporated within utility buried piping programs within 6 

months of the date of this letter.

NEI 09-14, Revision 3 includes the following changes:

• Revises the Initiative scope and milestones in accordance with the January 2013 Initiative change 

(Sections 3.1 and 3.3)

• Adds guidance for crediting inspections performed in other programs (Section 6.2.4)

• Moves the description of the Initiative deviation process into its own section (6.3)

• Maintains the content of reports to EPRI and INPO on inspection findings and leaks so that even 

with the Initiative scope change, all leaks are reported to INPO, and EPRI continues to receive all 

relevant inspection information (Section 5.1 and Appendix A)

• Adds an expectation for performing periodic self-assessments of Buried Piping or Underground 

Piping and Tank Integrity Programs and reporting significant problems discovered to NEI or EPRI 

(Section 5.1)
Administrative Points of Contact

May 1, 2013

Page 2

• Makes the June 30, 2013, milestone for starting inspections of underground piping and tanks not 

applicable to components added by the January, 2013, revision to the Initiative (6.2.9)

• Includes other administrative and editorial changes denoted by side bars in the margin

Although not changed as part of Revision 3, there are two expectations within NEI 09-14 that were 

discussed at length during the revision process. A summary of these items follows.

• Communicating Experience: The deviation process described in Section 6.3.2 includes the 

following statement (italics added for emphasis): "If a utility finds itself outside of a required 

Initiative element and takes immediate action to meet the element, a deviation justification is not 

required, but the condition should be entered into the corrective action program and the Buried 

Piping Integrity Task Force should be notified." The task force is specifically interested in hearing 

about situations when the discovered condition is significant. Knowledge of significant items and 

sharing of their generic implications can help everyone make a more accurate assessment of the 

consistency of Initiative implementation across the industry.

• Reporting Leaks and Inspection Findings: It is expected that utilities will continue to report all 

leakage and adverse inspection findings from buried and underground piping and tanks to INPO 

through their ICES system, and all inspection findings to EPRI's Buried Piping Integrity Group, even 

though the affected systems may no longer be within the scope of the Initiative (see Section 5.1 

and Appendix A). We have always required that all leaks and inspection findings be reported and 

this expectation is unchanged in order to maintain the accuracy and completeness of the information 

we accumulate. The information provides valuable operating experience, aids in inspection 

planning, and illustrates the effect of the Initiative. If the reports were limited to components and 

systems that are governed by the Initiative, different classifications of systems and components 

between utilities would result in different reporting scopes and "fuzzy" data.

We appreciate your support of the Underground Piping and Tanks Integrity Initiative. We expect that our 

proactive response to this issue will have positive effects on both public confidence and future NRC activities 

in this area. If you have any questions, please contact me at (202) 739-8137; jhr@nei.org.

Sincerely, 

James H. Riley

Attachment

c: Buried Piping Integrity Task Force 

Buried Piping Points of Contact