Underground Piping and Tank Integrity Initiative

Update

Mark Richter

Senior Project Manager-NEI

USNRC/Industry Public Meeting: Underground Piping and Tanks Initiative Update

January 21, 2015 • Rockville, MD
Overview

• Initiative Implementation Status

• Updates from INPO, EPRI, and ASME 

• Buried Pipe Integrity Task Force Update
Implementation Status

104 104 104 104 104 104 104 104

29

2

16

2

104 104 104 104 104 104 104 104

0

20

40

60

80

100

120

Responses

Milestone

Status as of June 2014 

(left bar in each pair is status from 6 months ago)

Will miss

At risk

On schedule

Complete
Implementation Status

• Plants have completed the first eight milestones. 

• Positive trends are indicated on each of the 

remaining milestones for survey responses 

received to date.

- A few plants have yet to respond to the survey 

(responses in progress.)

- Five units permanently ceased operations for 

decommissioning.

- Complete survey results expected by the February, 

2015 BPIG meeting.
Implementation Status

• Interim guidance for management of 

underground assets for future plants that enter 

the decommissioning transition process is 

complete.

• One deviation for inspection completion 

milestone. Conservative analysis supports 

closure by August 31, 2015.

• BPITF continues to meet with NRC staff. 

• The Asset Management Plans capture future 

inspections and related activities.
INPO Update
© Copyright 2015 Institute of Nuclear Power Operations

INPO Perspectives

NRC Buried and Underground Piping Meeting

January 21, 2015 

Joe Sears

Manager, Nuclear Asset Protection
© Copyright 2015 Institute of Nuclear Power Operations

Key Topics

•INPO’s NEI 09-14 role 

•Industry Performance 

–Plant evaluations

–Operating experience

•ICES reporting

• Questions
© Copyright 2015 Institute of Nuclear Power Operations

NEI 09-14 INPO’s Role

• Evaluate programs.

• Communicate issues to the industry.

• Compile and report operating 

experience.
© Copyright 2015 Institute of Nuclear Power Operations

Key Topics

•INPO’s NEI 09-14 role 

•Industry Performance 

–Plant evaluations

–Operating experience

•ICES reporting

• Questions
© Copyright 2015 Institute of Nuclear Power Operations 11

Areas for Improvement

0

2

4

6

8

10

12

2007 2008 2009 2010 2011 2012 2013 2014

Leaks Program U/G & CP CP TOTAL AFIs
© Copyright 2015 Institute of Nuclear Power Operations

2014 Summary

• Program implementation remains effective

• Improvement needed:

– Cathodic protection not properly maintained

– Cathodic protection equipment work 

prioritization and completion

– Cathodic protection site knowledge weaknesses

– Leaks occurring and the source is not determined

Areas for 

Improvement

Performance

Deficiencies

Underground Piping 

and Tanks

2 1

Cathodic Protection 2 4
© Copyright 2015 Institute of Nuclear Power Operations

Good Underground Piping 

Program Attributes

• Comprehensive asset management plan

• ICES reporting quality improvement

• Zero leak tolerance – especially in piping 

containing radioactive fluids

• Cathodic protection installed and maintained

• Failure causes identified

• Effective station and corporate oversight

• Effective use of corrective action program 
© Copyright 2015 Institute of Nuclear Power Operations 14

2015 Evaluation Focus Area

• Asset Management Plan Review

–Does it meet the intent of NEI 09-14? 

–Does it meet the needs of the station?

–Has it been reviewed by an 

appropriate level of management?

– Is it maintained based on changing 

station priorities?
© Copyright 2015 Institute of Nuclear Power Operations

Key Topics

•INPO’s NEI 09-14 role 

•Industry Performance 

–Plant evaluations

–Operating experience

•ICES reporting

• Questions
© Copyright 2015 Institute of Nuclear Power Operations

2014 Number of Reported Events by Year and 

Failure Mode

80 106 101 117 115

85

8

15 8

5 4

3

6

12 7 5 5 7

2

4 13 3

4

1

0

20

40

60

80

100

120

2009 2010 2011 2012 2013 2014

Adverse inspection 

finding (requires 

immediate repair)

Other degradation or 

maintenance

Significant leak

Leak

Source: ICES
© Copyright 2015 Institute of Nuclear Power Operations

Most Commonly Affected Systems 

Relative to NEI 09-14

0

10

20

30

40

50

60

Essential Service

Water System

Sanitary Waste

Processing System

Equipment and

Floor Drain system

Liquid Waste

Management

System

CVC/Makeup and

Purification Sys.

(PWR)

Wastewater

Disposal system

Condensate

Storage and

Transfer System

Source: ICES 2008 -2014
© Copyright 2015 Institute of Nuclear Power Operations

Updated UPTI Failure Cause Codes

18

Source: 2014 ICES Data

Internal 

diameter 3%

Outer diameter 

3%

Design 4%

Operation 3%

Age-related 7%

Mechanical 61%

Corrosion 18%

Coating 

Degradation 1%
© Copyright 2015 Institute of Nuclear Power Operations

Contains 

Licensed Material

5%

Safety Related

7%

Contains 

Environmentally 

Hazardous Fluid

5%

Other Buried 

Piping-run to 

failure

72%

Other Buried 

Piping-not run to 

failure

11%

Buried Pipe Events 

Classification
© Copyright 2015 Institute of Nuclear Power Operations

ICES Reporting
© Copyright 2015 Institute of Nuclear Power Operations

Buried Tanks Reporting 

Requirements

• NEI 09-14 Rev. 3, Appendix A, licensees 

will enter operating experience into 

INPO’s ICES database when events occur. 

Entries shall be made in a timeframe 

consistent with ICES timing requirements. 
© Copyright 2015 Institute of Nuclear Power Operations

Buried Tanks Reporting 

Requirements

• The ICES database has been revised to 

facilitate entry of operating experience 

for underground tanks. 

• Retroactive to January 1, 2012, the 

requirements of NEI 09-14, Revision 3 

pertaining to the recording of operating 

experience of underground tanks shall be 

met. 
© Copyright 2015 Institute of Nuclear Power Operations

Buried Tanks Reporting

• Two reported leaks in ICES for the period 

2012 – 2014.

– One condensate storage tank bottom 2014

– One outdoor radwaste sample tank 2012

– Has a record search to identify all historical 

tank leaks within scope been performed and 

reported in ICES? 
© Copyright 2015 Institute of Nuclear Power Operations

Buried Tanks Reporting

•
© Copyright 2015 Institute of Nuclear Power Operations

Questions
EPRI Update
ASME Update
BPITF Status

• BPITF mission success:

- Plant underground pipe and tank integrity programs are 

established.

- Asset Management Plan drives ongoing program 

activities. 

• Continue to provide oversight and guidance to the 

plants through 2015 as part of the transition from a 

milestone based initiative to programmatic 

management of underground assets.
BPITF 2015 Actions

• Complete final revision of NEI 09-14 to capture 

interim guidance, future responsibilities, and 

other changes.

• Prepare a white paper documenting 

accomplishments and leak performance for the 

NSIAC.