overview of the nsiac initiative in the us for buried and ... · pdf file–development of...

David Smith

EPRI

IAEA Technical Meeting on Ageing Management of Buried and

Underground Piping and Tanks for NPPs

October 13-15, 2014 Charlotte, NC

Overview of the NSIAC Initiative in the US for

Buried and Underground Piping & Tanks

2 © 2012 Electric Power Research Institute, Inc. All rights reserved.

Focus on Buried Pipe in the US

• In May 2007, EPRI sponsored a workshop related to piping

integrity issues

– Buried pipe was rated #1 issue

• Resulted in:

– Formation of Buried Pipe Integrity Group (BPIG) in 2008

– Development of recommendations for buried pipe program

- Dec 2008; current version is report 1021175

– Development of risk ranking software for buried pipe

(BPWORKS Version 1.0) - Dec 2008

– BP101: Training for the Buried Pipe Program Owner

• First class June 2009


Operating Experiences

• In 2009 there were several well publicized leaks of radioactive material

from buried and underground pipe: The US Congress got involved

– Feb 2009 – Indian Point

– April 2009 – Oyster Creek

• Industry looked at other significant leaks of radioactive material:

– Hatch 1986

– Palo Verde 1993

– Seabrook 1999

– Salem 2002

– Dresden 2004

– Brunswick 2007

– Quad Cities 2008

– Vermont Yankee 2010


NSIAC Initiative

• An NSIAC (Nuclear Strategic Issues Advisory Committee)

Initiative was approved in Nov 2009 to address buried1 pipe

– NSIAC is composed of CEOs / CNOs of all US nuclear

plants

• Industry commitment, not regulation

• Goal was to provide “Reasonable Assurance” of structural

and leak integrity of buried pipe with special emphasis on

piping that contained radioactive materials

1 Buried - Piping that is below grade and in direct contact with the soil.


NSIAC Initiative (continued)

• Based on additional operating experience, in September

2010 the initiative was revised to include:

– Underground2 piping and tanks that are outside of a

building if they are safety related or contain radioactive

materials

– Now called the “Underground Piping and Tanks Integrity

Initiative”

– Additional elements or milestones were added for new

scope

2 Underground - piping that is below grade, not accessible, and outside of

buildings (e.g., in tunnels, trenches, vaults).


NSIAC Initiative (continued)

• In January 2013, NSIAC approved another revision to the

initiative based on:

– Progress of the industry’s implementation

– Tier 1 Fukushima related requirements

– Cumulative impact of industry and regulatory activities

• The latest revision includes:

– Scope changes to focus inspections on the most important

components and align the buried and underground

initiatives

– Allows more time to complete the first round of inspections

and the associated asset management plans


Current Initiative Scope

• All buried and underground piping and tanks that are

outside of a building and below grade (whether or not they

are in direct contact with the soil) if they:

– Are safety related,

OR

– Contain licensed material or are known to be

contaminated with licensed materials,

OR

Changes are highlighted!


Current Initiative Milestones

• Buried Piping

– Procedures and Oversight: June 30th, 2010

– Risk Ranking: Dec. 31st, 2010

– Inspection Plans: June 30th, 2011

– Inspection Implementation Start: June 30th, 2012

– Licensed Material Condition Assessment Complete:

– Asset Management Plan:

• Underground Piping and Tanks

– Procedures and Oversight: Dec. 31st, 2011

– Prioritization: June 30th, 2012

– Condition Assessment Plans: Dec. 31st, 2012

– Assessment Plan Implementation: June 30th, 2013

– Licensed Material Condition Assessment Complete:

– Asset Management Plan: Dec. 31st, 2014

Changes are highlighted!


NEI 09-14

• The Nuclear Energy Institute is the regulatory and legislative

interface of the US nuclear industry

– Sister organization to EPRI and INPO

• NEI issued NEI 09-14 in Dec 2009, “Guideline for the Management

of Buried Piping Integrity”

– A Buried Piping Integrity Task Force was formed to provide

input and direction

– Referenced EPRI report 1021175, “Recommendations for an

Effective Program to Control the Degradation of Buried Pipe

(1016456, Revision 1)” for details


Purpose of NEI 09-14

“Guideline for the Management of Buried Piping Integrity”

• Document the text of the Buried Piping Integrity Initiative

• Describe the intent of the Initiative

• Communicate roles and responsibilities of industry

participants

– Utilities, EPRI, INPO, NEI

• Facilitate Implementation

• Describe industry reporting of implementation


NEI 09-14 Revision 1

• NEI 09-14 Revision1-“Guideline for the Management of

Underground Piping and Tank Integrity” was issued in

January of 2011.

• Revision 1:

– Adds text of the revised Initiative

– Clarifies the intent of the Initiative through “shall” statements

– Clarifies Initiative scope

– Adds definitions

– Enhances the process for justifying deviations

– Adds expectations for communication of OE and deviations

– New BPITF responsibilities



• NEI 09-14 Revision 2-“Guideline for the Management of Underground

Piping and Tank Integrity” was issued in January of 2011.

• Revision 2:

– Inspection Planning Guidance incorporated as Appendix C

– All approved initiative interpretations have been reflected where the

information was appropriate. This includes:

• The definition of licensed material

• Components that are within the scope of the initiative

• Implementation of inspection plans

• Start of inspections

• The meaning of condition assessment

• Recognition of INPO’s ICES database as the means for collecting

adverse inspection findings.



• NEI 09-14 Revision 3-“Guideline for the Management of Underground

Piping and Tank Integrity” was issued in May of 2013.

• Revision 3:

– Revises the Initiative scope and milestones in accordance with the

January 2013 changes

– Adds guidance for crediting inspections performed in other

programs

– Moves the description of the deviation process into its own section

– Restates that the content of reports to EPRI (BPIRD) and INPO

(ICES) on inspection findings and leaks includes all buried and

underground piping and tanks even though the scope of the

initiative changed.

– Adds an expectation for performing periodic self assessments


NEI Inspection Planning Guidance or

Reasonable Assurance Document

• Purpose was to develop an approach to meet the intent of

the Industry Initiative

• Reasonable Assurance Technical Advisory Group

– Subgroup of NEI BPITF

• Approach had been developed by 2 Utilities

• Draft reviews, webcast and conference calls

• Several levels of review and approval

• Incorporated into NEI 09-14 Revision 2 as an appendix


Inspection Planning- Overall Approach

•Reasonable Assurance / Inspection Planning Guidance is a Graded Process that involves: – Inventory and Risk Ranking

– Create Line Groupings

– Indirect inspection samples

– Direct examinations

– Feedback for overall program

Effective use of resources through graded process, focused and quality inspections


Programmatic Guidance

• Consensus document of what to do is contained in EPRI

report 1021175, “Recommendations for an Effective

Program to Control the Degradation of Buried and

Underground Piping and Tanks (1016456, Revision 1)”

– Considered to be a living document, to be periodically

revised as technology and experience evolve

– Download from EPRIweb

– Risk based approach


US Regulatory Requirements

• US regulatory requirements are mostly coming through the license renewal process

– NUREG-1801, Generic Aging Lessons Learned (GALL report)

• Each revision of GALL has increased the inspection requirements (not retroactive)

• Buried pipe is considered to be within scope of aging management

– 10 CFR 50.65, Maintenance Rule

– 10 CFR 54, License renewal

– LR-ISG-2011-03, which supplements/replaces the guidance in rev 2 of the GALL report

– NRC Inspection Manual 62002

– NUREG/CR-6679, Assessment of Age-Related Degradation …….

– NUREG/CR-6786, Risk Informed Assessment of Degraded Buried Pipes….

• NRR Action Plan for Buried Piping; TAC No. ME3939


INPO Assessments

• INPO has been conducting assessments at many plants of their buried pipe program

– “How-to” document

• Questions the evaluators will ask the plants

– Many sites have received Areas for Improvement (AFIs) or Performance Deficiencies (PDs)

• Common AFIs or PDs

– Deficiencies in the CP system

• The CP system is not tested and maintained

• Equipment problems reduce the protection of buried piping

– Monitoring has not received high priority

– Predictive inspections are not performed and analyses are not based on current information

– Long-term strategies do not address known vulnerabilities


Together…Shaping the Future of

Electricity


Why Was a Special Initiative Required - What

Makes Underground Pipe Unique?

• Not readily accessible for inspection and leak detection

• Are subject to degradation mechanisms from the outside

(soil side) as well as from the inside (fluid side)

– Also subject to occlusions

• Burial conditions can have chemical, geotechnical and

civil-structural considerations that can be unique to each

installation and/or site

• Backfill materials vary by their nature and degree of

inspection or verification during the installation process


What Makes Underground Pipe Unique?

• Encompass a variety of services such as raw, treated and

demin water; gases; chemicals; fuel oil; lube oil

• May contain radioactive fluids

• Encompass a wide range of materials: steel, cast iron,

copper alloys, stainless, concrete, asbestos, PVC,

polyethylene, FRP, etc.

• Encompass a wide range of sizes, from over 10 ft

diameter to small bore piping

• Wide range of connection types: butt-welded, socket

welded, flanged, threaded, bell & spigot, victaulic

couplings, etc.


What Makes Underground Pipe Unique?

• Pipes may be bare or they may have a variety of external

coatings and internal linings

• May or may not be cathodically protected

– Different types of CP systems

• Because the pipes are not readily accessible, buried pipe

inspections have not been as common as above-ground

inspections

• The design formulas and corresponding design margins

for soil and surface loads are not defined in US codes

such as ASME

– Loads for aboveground, buried, and underground are

all different


Systems that often Contain Underground Pipes

• Active Drainage

• Auxiliary Feedwater

• Auxiliary Gas

• Building Drains

• Chemical Injection

• Chlorination

• Circulating Water

• CO2

• Condensate and Feedwater

• Control room air supply/ventilation

• Cooling Oil

• Demineralized Water

• Diesel Generator Fuel Oil

• Domestic Water


Systems that often Contain Underground Pipes (continued)

• Emergency Coolant Injection

• Emergency Storage Water

• Essential Service Water

• Fire Protection

• Frazil Ice Protection

• Fuel Oil

• High Pressure Coolant Injection (HPCI)

• Hydrogen

• Instrument Air

• Liquid Effluent Sampling and Monitoring

• Lubrication Oil

• Lubrication Oil Waste Disposal

• Make-up Water


Systems that Often Contain Underground Pipes (continued)

• Non-essential Service Water

• Off-gas

• Pipe Trench Inactive Drainage

• Radwaste

• Reactor Core Isolation Cooling (RCIC)

• Refueling Water

• Roof Drainage

• Service Air

• Sewage System

• Steam Generator Blowdown

• Tempering Water

• Trash Removal

• Turbine bearing cooling

• Yard Fire Protection


Other Buried Commodities that may be

Susceptible to Degradation

• Intake structure

• Traveling screens

• Tanks

• Electrical cables

• Phone cables

• Manways

• Abandoned lines

• Grounding grid

• Security equipment

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