B ried u and

Underground PipinUnderground Pipin

and Tanks and Tanks

Bob Hardies

Senior Level Advisor, NRR

Document June 30, 2014
B ried u and

Underground PipinUnderground Pipin

and Tanks and Tanks

Bob Hardies

Senior Level Advisor, NRR

Meeting Date June 11, 2014
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• Will update to reflect item closures Will update to reflect item closures
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 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 ISG complete• Coatings ISG in progress

• Inspection

• Temporary Instruction for inspection of buried piping 

activities

• Temporary Inspection instructions exists through 201• Seeking to understand commitment to minimizing lea

• R i i 8/8/2013 t fl t i iti ti d h d l h 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 complete.

– All licensees participating in the Underground Piping a

Integrity Initiative
TI 182 Preliminary Results

• Phase II more II more than 90% of sites reported 90% of sites reported• Some observations: Some observations:

– No deviations– Relativel

y low turnover in buried 

pp g y i in

g s

yste

responsible individual

– System health reports useful–

As built configuration knowledge sufficient
TI 182 Preliminary Results

• Some observations: Some observations:

– risk ranking software or programs assessed t

objectives of the initiatives

• Variability

– have completed their risk ranking in a manne

characterized as appropriate characterized as appropriate

• Some plants have no high risk piping• Some plants seem to have buried carbon steel pip

tritiated water with a history of leakage and have ra

water with

a history of leakage and have ra

other than high
TI 182 Preliminary Results

• Some observations: Some observations:

– ~4/5 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.

• Using NACE certification, in house or vend

• Not necessarily on piping and not necessa

Not necessarily on piping and not necessa

all piping

– ~1/5 no cathodic

protection installed.
TI 182 Preliminary Results

• Some observations Some observations

– All licensees have inspection plans

• Some inspections have been deferred Some inspections have been deferred

– Those who had had leaks took approp

action

– Inspection procedures are appropriate 

are followed; p pp p dis

position is appro

priate
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 fashion.
HDPE Pipe

• ASME

– Progress on modification of Section III– Work continues on Section XI Code Case– Probably several years before completed and 

implemented in NRC Regulatory Guide

– NRC ill t t i li f t NRC will entertain relief requests

– One relief request has been submitted, withd

and will be resubmitted and will be resubmitted

• NRC guidance on relief requests has bee

p yp g rovided in January public meeting
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