Overview of the NSIAC Initiative in the US for Buried and Underground Piping & Tanks

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Morris Blair
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1 Overview of the NSIAC Initiative in the US for Buried and Underground Piping & Tanks David Smith EPRI IAEA Technical Meeting on Ageing Management of Buried and Underground Piping and Tanks for NPPs October 13-15, 2014 Charlotte, NC

2 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 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

3 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

4 NSIAC Initiative An NSIAC (Nuclear Strategic Issues Advisory Committee) Initiative was approved in Nov 2009 to address buried 1 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. 4

5 NSIAC Initiative (continued) Based on additional operating experience, in September 2010 the initiative was revised to include: Underground 2 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). 5

6 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 6

7 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 Changes are highlighted! Contain licensed material or are known to be contaminated with licensed materials, OR 7

8 Current Initiative Milestones Buried Piping Changes are highlighted! Procedures and Oversight: June 30 th, 2010 Risk Ranking: Dec. 31 st, 2010 Inspection Plans: June 30 th, 2011 Inspection Implementation Start: June 30 th, 2012 Licensed Material Condition Assessment Complete: Asset Management Plan: Underground Piping and Tanks Procedures and Oversight: Dec. 31 st, 2011 Prioritization: June 30 th, 2012 Condition Assessment Plans: Dec. 31 st, 2012 Assessment Plan Implementation: June 30 th, 2013 Licensed Material Condition Assessment Complete: Asset Management Plan: Dec. 31 st,

9 NEI The Nuclear Energy Institute is the regulatory and legislative interface of the US nuclear industry Sister organization to EPRI and INPO NEI issued NEI 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 , Recommendations for an Effective Program to Control the Degradation of Buried Pipe ( , Revision 1) for details 9

10 Purpose of NEI 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 10

11 NEI Revision 1 NEI Revision1- Guideline for the Management of Underground Piping and Tank Integrity was issued in January of 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 11

12 NEI Revision 2 NEI Revision 2- Guideline for the Management of Underground Piping and Tank Integrity was issued in January of 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. 12

13 NEI Revision 3 NEI Revision 3- Guideline for the Management of Underground Piping and Tank Integrity was issued in May of 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 13

14 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 Revision 2 as an appendix 14

Inspection Planning- Overall Approach Reasonable Assurance / Inspection Planning Guidance is a Graded Process that involves: Inventory and Risk Ranking Create Line

15 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 15

16 Programmatic Guidance Consensus document of what to do is contained in EPRI report , Recommendations for an Effective Program to Control the Degradation of Buried and Underground Piping and Tanks ( , Revision 1) Considered to be a living document, to be periodically revised as technology and experience evolve Download from EPRIweb Risk based approach 16

17 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 , which supplements/replaces the guidance in rev 2 of the GALL report NRC Inspection Manual 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. ME

18 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 18

19 Together Shaping the Future of Electricity 19

20 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 20

21 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. 21

22 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 22

23 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 23

24 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 24

25 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 25

26 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 26

INPO Perspective Groundwater Protection and RETS/REMP Meeting June 2014

Institute of Nuclear Power Operations INPO Perspective Groundwater Protection and RETS/REMP Meeting June 2014 Joe Sears Manager, Nuclear Asset Protection Key Topics Groundwater protection Underground piping