Underground Piping and Ta

Integrity Initiative

NEI 09-14, Rev 1

March 30, 2011
Initiative Revision

 Buried Piping Integrity Initiative applies t

buried piping that is in direct contact with 

 Experience indicated a need for expans

– Degradation of piping in vaults and tunn

occur

 VY leak came from piping in a vault

– Buried Piping Integrity Initiative does not 

tanks
Revised Initiative

 NSIAC approved the Underground Pip

Tank Integrity Initiative in November 20

– Added scope

• Underground piping and tanks whether 

they are in direct contact with the soil if they are in direct contact with the soil if 

outside of buildings and

– Contain licensed radioactive material or– Are safety related 

– Includes new milestones
Milestones

 Applicable to the added scope

1. Procedures and oversight by December 32. Prioritization by June 30, 20123. Condition assessment p y lan b December 

2012

4. Plan implementation by June 30, 20135. Condition assessment of components co

licensed material by June 30, 2014

6. Asset management plan by December 31
NEI 09-14 Revision 1
NEI 09-14 Revision

 NEI 09-14 rev 1 issued in January 201

– Adds text of the revised Initiative– Clarifies the intent of the Initiative throu

“shall” statements

– Clarifies Initiative scope Clarifies Initiative scope– Adds definitions– Enhances the process for justifying dev– Adds expectations for communication o

and deviations

– New BPITF responsibilities
NEI 09-14, Section 3: Initiativ

 Documents the text of the Initiative Establishes the expectation for “shall” 

statements:

“Whenever the word “shall” is used in this 

document it indicates an action that is re

q

under the Buried Piping and Tanks IntegriInitiative. If a plant cannot or will not impleany part of the Initiative (Sections 3.3.A anor a “shall” statement in this document, a justification for deviation from the Initiative shall be developed and processed in accordance with Sections 6.2.1 and 6.2.6
NEI 09-14, Section 4: Definitio

 Accessible – routinely observed Environmentally hazardous – defined b

environmental programs

 Underground tank Underground tank

– outside and outside and

sufficiently below grade such that a reasonable possibility exists that leakawill not be detected
NEI 09-14, Section 5: Responsib

 Utility expectations

– Implement the Initiative– Process justifications for deviation– Report implementation status to NEI– Communicate significant leakage and 

inspection findings to NEI and Buried Integrity Group (BPIG)
NEI 09-14, Section 5: Responsib

 Other responsibilities

– EPRI

• Venue for sharing OE and program exp• NDE d l t NDE

developmen

t

• Inspection results

– INPO

• Communicate OE• Focus area for plant evaluations 
NEI 09-14, Section 5: Responsib

 Other responsibilities

– NEI

• Regulatory interface• T k f d ki ti Tas

k

force an

d working group operatio

• Nuclear Strategic Issues Advisory Com

(NSIAC) report 
BPITF Responsibilities

 BPITF focus in 2011

– NRC interface– Reasonable assurance document– “Enhanced Ins

pection and Environmen

Monitoring Initiatives” coordination document

– Monitoring OE– Initiative interpretation– Deviation assessment
NEI 09-14, Section 6: Intent

 Initiative scope

– Utility owned buried/underground pipin

and tanks within site boundaries

– Inaccessible– Underground piping outside of the exte

surface of buildings

 Reasonable assurance goal
NEI 09-14, Section 6: Intent

 Deviations

– Verbatim conformance with the text of the Ini

all “shall” statements in NEI 09-14 rev 1 is ex

– Contact BPITF with questions on interpretatio– Deviations must be justified

• Technical reasons, not convenience• A d b tilit ti Approve

d

by utility executive

• Sent to NEI for review by the BPITF

– General assessment, not approval– Evaluation of meeting Initiative intent

• Utility will be informed of result• Deviations that do not meet the intent of the In

be tracked in report to NSIAC
NEI 09-14, Section 6: Intent

 Significant new operating experience: BP

• Disseminate information• Facilitate plant assistance if needed• Assess generic implications• E l t ff t id Evalua

te effec

t on guidance

 EPIX reports

– Adverse inspection findings and significan

leakage

– Input to semi-annual report to NSIAC