BPITF: 

Buried and Underground Components

License Renewal and GALL Update

June 11, 2014

Eric Blocher

NEI License Renewal Task Force
Agenda

• Internal surface inspections of buried and 

underground piping (LR-ISG-2012-02). 

• Subsequent License Renewal Considerations for AMP 

XI.M41, Buried and Underground Piping and Tanks
Two ISGs for Buried Piping Inspections

• LR-ISG-2011-03 was issued on Aug. 2, 2012 and 

revised AMP XI.M41 to included additional aging 

management considerations for the exterior surfaces 

of buried and underground piping and tanks. 

• LR-ISG-2012-02 was issued on Nov. 22, 2013 and 

revised several AMPs to include aging management 

considerations for the interior surfaces of buried and 

underground piping and tanks.
Buried and Underground Pipe Internal Inspections

• XI.M38, Inspection of Internal Surfaces in 

Miscellaneous Piping and Ducting Components:

Inspections can be based on results from interior 

surfaces of accessible piping with similar material 

and environment.

• XI.M27, Fire Water System:

Extrapolation of inspections for above ground 

components with similar material and environment 

to buried and underground components is allowed.
Recurring Internal Corrosion (RIC)

• RIC is identified by both the number of occurrences 

of internal aging effects with the same aging 

mechanism and the extent of degradation at each 

localized site:

- Occurrences: one per refueling outage cycle that has occurred over 

three or more sequential or nonsequential cycles for a 10-year OE 

search, or two or more sequential or nonsequential cycles for a 5-year 

OE search

- Extent of degradation: aging effect resulted in the component not 

meeting either plant-specific acceptance criteria or experiencing a 

reduction in wall thickness of greater than 50 percent (regardless of 

the minimum wall thickness)
Buried and Underground Pipe Internal Inspections

• Applies to AMPs XI.M38, XI.M27 as well as XI.M20 

(Open-Cycle Cooling Water System) and XI.M21A 

(Closed Treated Water System)

• Inspections for loss of material due to RIC requires a 

determination of how inspection for components 

that are not easily accessed (i.e. buried, 

underground) will be conducted and how leaks in 

any involved buried and underground components 

will be identified. 
Other LR-ISG-2012-02 Considerations

• XI.M29, Aboveground Metallic Tanks, allows crediting 

of cathodic protection preventive measures 

consistent with AMP XI.M41 and performance of a 

one-time inspection for tanks founded on soil. 
Subsequent License Renewal (SLR)

• XI.M41 is classified as a Category 2 program 

for SLR (EPRI Report 3002000576)

- No technical data needs relative to projecting 

operating conditions to 80 years

- On-going program and/or relevant operating 

experience used for continuous improvement
SLR Continued

• Changes recommended for GALL Rev 3

- Table 4c footnote 3 (buried tanks) clarification for 

cathodic protection

- Use of ISO 15589-1 to determine cathodic

potential values based on soil resistivity

- Clarify 1200mV cathodic protection limit
Conclusions 

• LR-ISG-2012-02 may require access to buried 

and underground piping for aging 

management of internal surfaces.

• On-going program and/or relevant operating 

experience is recommended for continuous 

improvement of AMP M41.