NUREG-0800

U.S. NUCLEAR REGULATORY COMMISSION

STANDARD REVIEW PLAN

3.6.1 PLANT DESIGN FOR PROTECTION AGAINST POSTULATED PIPING FAILURES IN

FLUID SYSTEMS OUTSIDE CONTAINMENT

REVIEW RESPONSIBILITIES

Primary - Organization responsible for the review of plant design for protection of
structures, systems, and components from internal and external hazards

Secondary - None

I. AREAS OF REVIEW

The plant design for protection against piping failures outside containment is reviewed to
ensure that environmental effects of such failures would not cause the loss of needed functions
of safety-related systems and to ensure that the plant could be safely shut down in the event of
such failures. The review includes high energy and moderate energy fluid system piping
located outside of containment. If such a system penetrates containment (except for the
auxiliary feedwater system) the review starts with the first isolation valve outside of
containment. The review boundary for auxiliary feedwater systems extends either to the steam
generator or to the feedwater (or steam) line, as appropriate. This section includes a reviews of
the plant design to ensure conformance with the requirements of 10 CFR Part 50, Appendix A,
General Design Criteria (GDC) 2, and GDC 4.

The specific areas of review are as follows:

Revision 3 - March 2007

USNRC STANDARD REVIEW PLAN
This Standard Review Plan, NUREG-0800, has been prepared to establish criteria that the U.S. Nuclear Regulatory Commission
staff responsible for the review of applications to construct and operate nuclear power plants intends to use in evaluating whether
an applicant/licensee meets the NRC's regulations. The Standard Review Plan is not a substitute for the NRC's regulations, and
compliance with it is not required. However, an applicant is required to identify differences between the design features, analytical
techniques, and procedural measures proposed for its facility and the SRP acceptance criteria and evaluate how the proposed
alternatives to the SRP acceptance criteria provide an acceptable method of complying with the NRC regulations.
The standard review plan sections are numbered in accordance with corresponding sections in Regulatory Guide 1.70, "Standard
Format and Content of Safety Analysis Reports for Nuclear Power Plants (LWR Edition)." Not all sections of Regulatory Guide 1.70
have a corresponding review plan section. The SRP sections applicable to a combined license application for a new light-water
reactor (LWR) are based on Regulatory Guide 1.206, "Combined License Applications for Nuclear Power Plants (LWR Edition)."
These documents are made available to the public as part of the NRC's policy to inform the nuclear industry and the general public
of regulatory procedures and policies. Individual sections of NUREG-0800 will be revised periodically, as appropriate, to
accommodate comments and to reflect new information and experience. Comments may be submitted electronically by email to
NRR_SRP@nrc.gov.
Requests for single copies of SRP sections (which may be reproduced) should be made to the U.S. Nuclear Regulatory
Commission, Washington, DC 20555, Attention: Reproduction and Distribution Services Section, or by fax to (301) 415-2289; or by
email to DISTRIBUTION@nrc.gov. Electronic copies of this section are available through the NRC's public Web site at
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0800/, or in the NRC's Agencywide Documents Access and
Management System (ADAMS), at http://www.nrc.gov/reading-rm/adams.html, under Accession # ML070550032.
1. Reviews of the general layout of high and moderate energy piping systems with respect
to the plant arrangement criteria of Section B.1. of Branch Technical Position (BTP) 3-3.
Three arrangement situations are covered by the criteria and all three may be
encountered in a single plant. They are:

A. Arrangements where protection of safety-related plant features is provided by

separation of high and moderate energy systems from essential systems and
components.

B. Arrangements where protection of safety-related plant features is provided by

enclosing either the high and moderate energy systems or the safety-related
features in protective structures.

C. Arrangements where neither separation nor protective enclosures are practical

and special protective measures are taken to ensure the operability of
safety-related features.

2. Review of portions of high and moderate energy fluid system piping between
containment isolation valves that are subject to the recommendations of item B.2.c. of
BTP 3-3.

3. Review of analyses and environmental effects of postulated piping failures with respect
to the guidelines of Section B.3. of BTP 3-3.

4. Reviews of the assumptions made in the analyses with regard to:

A. The availability of offsite power.

B. The failure of a single active component in systems used to mitigate the
consequences of the piping failure.
C. The special provisions applicable to certain dual purpose systems.
D. The use of available systems to mitigate the consequences of the piping failure.

5. Review of the effects of postulated failures on the habitability of the control room and
access to areas important to safe control of post-accident operations.

6. Review of the effects of piping failures in systems not designed to seismic Category I
standards on essential systems and components.

7. Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC). For design certification
(DC) and combined license (COL) reviews, the staff reviews the applicant's proposed
ITAAC associated with the structures, systems, and components (SSCs) related to this
SRP section in accordance with SRP Section 14.3, "Inspections, Tests, Analyses, and
Acceptance Criteria." The staff recognizes that the review of ITAAC cannot be
completed until after the rest of this portion of the application has been reviewed against
acceptance criteria contained in this SRP section. Furthermore, the staff reviews the
ITAAC to ensure that all SSCs in this area of review are identified and addressed as
appropriate in accordance with SRP Section 14.3.

3.6.1-2 Revision 3 - March 2007

8. COL Action Items and Certification Requirements and Restrictions.
For a DC application, the review will also address COL action items and requirements
and restrictions (e.g., interface requirements and site parameters).

For a COL application referencing a DC, a COL applicant must address COL action
items (referred to as COL license information in certain DCs) included in the referenced
DC. Additionally, a COL applicant must address requirements and restrictions (e.g.,
interface requirements and site parameters) included in the referenced DC.

Review Interfaces

Other SRP sections interface with this section as follows:

1. The acceptability of seismic classification is evaluated in accordance with SRP

Sections 3.2.1 and 3.2.2.

2. The acceptability of design of protective structures (such as those used for protection
against piping failures) in connection with the review of other Category I structures is
evaluated in accordance with SRP Section 3.8.4.

3. The acceptability of the locations and types of piping failures to be considered, the
design of piping restraints and other protective measures, and the resultant dynamic
effects is evaluated in accordance with SRP Section 3.6.2.

4. The adequacy of internal flood protection system from piping failures is evaluated in
accordance with SRP Section 3.4.1.

5. The evaluation of the environmental effects of pipe rupture, (e.g., temperature, humidity,
and spray-wetting) with respect to the functional performance of essential electrical
equipment and instrumentation is in accordance with SRP Section 3.11.

6. Review of leak-before-break technology to exclude the dynamic effects of postulated

pipe ruptures from the design basis of plant SSCs is in accordance with SRP
Section 3.6.3.

7. The acceptability of inservice inspection criteria of piping within protective structures or

guard pipes, between containment isolation valves is evaluated in accordance with
SRP Section 6.6.

8. The acceptability of environmental effects of piping failures inside containment is

evaluated in accordance with SRP Sections 6.2.1 and 3.11.

The specific acceptance criteria and review procedures are contained in the referenced SRP
sections.

3.6.1-3 Revision 3 - March 2007

II. ACCEPTANCE CRITERIA

Requirements

Acceptance criteria are based on meeting the relevant requirements of the following
Commission regulations:

1. 10 CFR Part 50, Appendix A, GDC 2, as it relates to protection against natural

phenomena, such as seismically-induced failures of non-seismic piping. The application
of 10 CFR Part 50, Appendix A, GDC 2 to this section is to incorporate environmental
effects of full-circumferential ruptures of non-seismic moderate energy piping in areas
where effects are not already bounded by failures of high energy piping. Acceptance is
based on conformance to BTP 3-3.

2. GDC 4, as it relates to SSCs important to safety being designed to accommodate the

effects of and to be compatible with the environmental conditions associated with
postulated pipe rupture. Acceptance is based on conformance to BTP 3-3.

3. 10 CFR 52.47(b)(1), which requires that a DC application contain the proposed

inspections, tests, analyses, and acceptance criteria (ITAAC) that are necessary and
sufficient to provide reasonable assurance that, if the inspections, tests, and analyses
are performed and the acceptance criteria met, a plant that incorporates the design
certification is built and will operate in accordance with the design certification, the
provisions of the Atomic Energy Act, and the NRC's regulations;

4. 10 CFR 52.80(a), which requires that a COL application contain the proposed
inspections, tests, and analyses, including those applicable to emergency planning, that
the licensee shall perform, and the acceptance criteria that are necessary and sufficient
to provide reasonable assurance that, if the inspections, tests, and analyses are
performed and the acceptance criteria met, the facility has been constructed and will
operate in conformity with the combined license, the provisions of the Atomic Energy
Act, and the NRC's regulations.

SRP Acceptance Criteria

Specific SRP acceptance criteria acceptable to meet the relevant requirements of the NRC’s
regulations identified above are as follows for the review described in this SRP section. The
SRP is not a substitute for the NRC’s regulations, and compliance with it is not required.
However, an applicant is required to identify differences between the design features, analytical
techniques, and procedural measures proposed for its facility and the SRP acceptance criteria
and evaluate how the proposed alternatives to the SRP acceptance criteria provide acceptable
methods of compliance with the NRC regulations.

The application of GDC 2 to this section is to incorporate environmental effects of full-

circumferential ruptures of non-seismic moderate energy piping in areas where effects are not
already bounded by failures of high energy piping. The application of GDC 4 to this section is
that the design of SSCs important to safety will accommodate the effects of the environmental
conditions associated with postulated pipe ruptures of high and moderate energy piping.
Acceptance is based on conformance to BTP 3-3.

3.6.1-4 Revision 3 - March 2007

1. High and moderate energy fluid systems are separated from essential systems and
components, as described in Appendix B to BTP 3-3.

2. High and moderate energy fluid systems, or portions thereof, are enclosed as described
in item B.1.b of BTP 3-3.

3. For cases where neither physical separation nor protective enclosures are considered
practical by the applicant, the reviewer will verify the following:

A. The reasons for which the applicant judged both physical separation and
system enclosure to be impractical as means of protection are consistent
with item B.1.c. of BTP 3-3.

B. Redundant design features or additional protections (assuming a single

active failure in any required system) have been provided such that
failure modes and effects analyses for all failure situations ensure the
performance of safety features. These analyses are done under the
criteria and assumptions of item B.3. of BTP 3-3.

4. Design Features are in accordance with item B.2 of BTP 3-3.

5. The effects of postulated failures on essential equipment and the ability of the plant to
be safely shut down are analyzed in accordance with item B.3. of BTP 3-3.

Technical Rationale

The technical rationale for application of these acceptance criteria to the areas of review
addressed by this SRP section is discussed in the following paragraphs:

1. Compliance with GDC 2 requires that SSCs important to safety be designed to

withstand the effects of natural phenomena such as earthquakes, tornadoes,
hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety
function.

Meeting the requirements of 10 CFR 50, Appendix A, GDC 2 is necessary to ensure that
environmental effects due to failures of non-seismic piping do not affect the ability of the
plant to shut down safely and remain in safe shutdown condition. The application of
GDC 2 to this SRP Section is to ensure that consideration is given to full-circumferential
ruptures of non-seismic moderate energy piping. Such ruptures are not postulated for
dynamic considerations under SRP Section 3.6.2 since that section only applies for
normal plant conditions, not seismic events; however, environmental effects from these
ruptures should be considered. In many cases, the limiting bound on environmental
effects will be from failures of high-energy piping in the same area. However, the
applicant should consider the effects on safety-related SSCs in areas where moderate
energy failures may be the source of the most extreme postulated environmental
effects.

3.6.1-5 Revision 3 - March 2007

2. Compliance with 10 CFR Part 50, Appendix A, GDC 4 requires that SSCs important to
safety shall be designed to accommodate the effects of, and be compatible with,
environmental conditions associated with normal operations, maintenance, testing, and
postulated accidents, including loss-of-coolant accidents. These SSCs should be
appropriately protected against dynamic effects (including those of missiles, pipe
whipping, and discharge fluids) that may result from equipment failures and from events
outside the nuclear power unit. However, dynamic effects associated with postulated
pipe ruptures in nuclear power units may be excluded from the design basis when
analyses reviewed and approved by the Commission demonstrate that the probability of
fluid system piping rupture is extremely low under conditions consistent with the design
basis for piping.

GDC 4 requirements are applicable to this SRP section because the reviewer verifies
that a suitable and controlled operating environment will be provided for SSCs during
normal operations, during anticipated operational occurrences, and during and after
postulated accidents, including loss-of-coolant accidents. These requirements are
imposed to ensure (a) that piping failures in fluid systems outside the containment will
not cause the loss of needed function in safety-related systems and (b) that the plant
could be safely shut down in the event of such a failure.

Meeting the requirements of 10 CFR Part 50, Appendix A, GDC 4 provides assurance
that safety-related SSCs will be able to maintain their safety-related functions in the
environmental conditions resulting from a postulated piping failure.

III. REVIEW PROCEDURES

The reviewer will select material from the procedures described below, as may be appropriate
for a particular case.

These review procedures are based on the identified SRP acceptance criteria. For deviations
from these acceptance criteria, the staff should review the applicant’s evaluation of how the
proposed alternatives provide an acceptable method of complying with the relevant NRC
requirements identified in Subsection II.

All the systems of concern in this section have been reviewed under other SRP sections with
respect to design functions for normal operation and for the prevention or mitigation of
accidents. The review under this SRP section does not deal with individual system design
criteria necessary to ensure that each system performs as intended, but rather considers the
protection necessary to ensure the operation of such systems in the event of nearby piping
failures.

1. A review of the information presented in the Safety Analysis Report (SAR) identifying all
high and moderate energy fluid systems, and verification of individual system
temperatures and pressures to ensure that they have been correctly identified. The
reviewer evaluates for adequacy the system descriptions of the high and moderate
energy piping runs and by reviewing the appropriate system arrangement and piping
drawings, examines the plant arrangement measures that were taken to ensure
protection from the effects of postulated pipe breaks of high energy systems and
non-seismic moderate energy systems, or of leakage cracks for seismically-designed

3.6.1-6 Revision 3 - March 2007

 moderate energy systems. The reviewer will determine from the SAR that the following
configurations, either by itself or in combination, have been used by the applicant to
achieve this protection:

A. High and moderate energy fluid systems are separated from essential systems
and components, as described in Appendix B to BTP 3-3. The reviewer inspects
plant arrangement drawings and other information to verify conformance to
Appendix B to BTP 3-3.

B. High and moderate energy fluid systems, or portions thereof, are enclosed within
structures or compartments designed to protect nearby essential systems or
components, or the essential systems and components are enclosed in
protective structures. The reviewer traces the routing of the systems identified in
the SAR as high or moderate energy systems on appropriate plant arrangement
drawings, locates the postulated break locations specified in the applicant's
analyses, and determines all locations where the effects from the breaks or leaks
interface with safety-related equipment. The reviewer then determines that at
these locations enclosures have been provided that protect the safety-related
equipment. Any questions related to the location of the break are conveyed to
the organization responsible for the review of SRP Section 3.6.2 for a
determination of the proper locations.

C. For cases where neither physical separation nor protective enclosures are
considered practical by the applicant, the reviewer will analyze the SAR
information to verify the following:

i. The reasons for which the applicant judged both physical separation and
system enclosure to be impractical as means of protection are consistent
with item B.1.c. of BTP 3-3.

ii. Redundant design features or additional protections (assuming a single

active failure in any required system) have been provided such that
failure modes and effects analyses for all failure situations ensure the
performance of safety features. These analyses are done under the
criteria and assumptions of item B.3. of BTP 3-3. Special measures
taken to provide additional protection are reviewed on a case by case
basis, with assistance from other staff as needed.

2. Review the information presented in the SAR that identifies the principal design
features. The reviewer performs the evaluation by comparing the design basis
information given in the SAR with that described in item B.2. of BTP 3-3. By this
comparison of individual design features, the reviewer verifies that the following
necessary measures have been provided by the applicant's design.

A. Design features provided for protective structures or compartments and other

protective measures are reviewed as described in item B.2.b. of BTP 3-3. The
reviewer compares the design features and bases given in the SAR with the
stated item in BTP 3-3. The comparative review may include the use of plant
arrangement and layout drawings as necessary to clarify the design intentions

3.6.1-7 Revision 3 - March 2007

 and implementation. In the majority of case reviews, SAR statements and
drawings indicating that the design meets the intent of the acceptance criteria
are accepted. However, there may be cases where engineering judgment and
independent staff analyses are needed to verify the capability of structures and
components to withstand the effects of a pipe rupture.

B. SAR information, as supplemented by engineering sketches or drawings where

necessary, is reviewed to determine that fluid system piping between
containment isolation valves conforms to item B.2.c. of BTP 3-3. This includes
piping penetrations between single and dual barrier containments that may have
enclosing protective structures. The review is mainly performed on a
comparative basis in this SRP Section. These piping details are reviewed to
verify the design limits, break locations, and dynamic effects under SRP
Section 3.6.2 and BTP 3-4

3. The results of the applicant's evaluation of the environmental consequences of

postulated piping failures of high and moderate energy fluid piping systems are
reviewed. The type and location of each postulated piping failure (i.e., longitudinal or
circumferential) in either a high or moderate energy system will be reviewed by the
organization responsible for the mechanical engineering reviews on the basis of
BTP 3-4; however, full-circumferential breaks in non-seismic moderate energy piping
should be considered in addition to the breaks postulated in BTP 3-4. The review will be
based upon the information provided by applicants in the SAR concerning the effects of
postulated failures on essential equipment and the ability of the plant to be safely shut
down, as described in item B.3. of BTP 3-3.

The reviewer verifies that the applicant's evaluation has properly considered the
following points, and in certain cases, as necessary, performs an independent
evaluation, especially with regard to single failure analyses.

A. The reviewer verifies the applicant's plant arrangements and design features
using layout drawings to ensure that all potentially affected essential systems
and components have been considered with respect to the effects of an
assumed pipe break.

B. The reviewer evaluates the effects of postulated piping failures as determined

from the information given in the SAR. The reviewer will confirm the results of
the applicant's evaluations by performing a comparative, but abbreviated as
appropriate, failure modes and effects analysis that includes the considerations
given in item B.3.b. of BTP 3-3 for the following effects:

i. The availability of offsite power.

ii. The effects of a single active component failure in systems necessary to

mitigate consequences of the postulated piping break.

iii. Permissible exclusions to (ii.) above based upon the provision given in
item B.3.b.(3) of BTP 3-3 for certain dual purpose moderate energy
systems.

3.6.1-8 Revision 3 - March 2007

 iv. The considerations involved in the selection of available systems to
mitigate the consequences of the piping failure.

C. The reviewer will verify from a review of arrangement drawings that control room
habitability or access to necessary surrounding areas is not jeopardized as a
consequence of the postulated piping failure.

D. The reviewer evaluates the applicant's analysis of the postulated failure of

non-seismic Category I piping systems by performing a failure modes and effects
analysis using SAR information and engineering sketches as necessary.

4. Systems defined in Appendix A to BTP 3-3 as "essential systems" are those that are
needed to shut down the reactor and mitigate the consequences of the pipe break for a
given postulated piping break without offsite power. However, depending upon the type
and location of the postulated pipe break, certain safety equipment may not be classified
as "essential" for that particular event (e.g., emergency power system or high and low
pressure core spray systems). On the other hand, some safety equipment will be
"essential" for almost all cases (e.g., service water to ultimate heat sink). Table 3.6.1-1
is a list of those essential systems generally in the latter category.

5. For review of a DC application, the reviewer should follow the above procedures to verify
that the design, including requirements and restrictions (e.g., interface requirements and
site parameters), set forth in the final safety analysis report (FSAR) meets the
acceptance criteria. DCs have referred to the FSAR as the design control document
(DCD). The reviewer should also consider the appropriateness of identified COL action
items. The reviewer may identify additional COL action items; however, to ensure these
COL action items are addressed during a COL application, they should be added to the
DC FSAR.

For review of a COL application, the scope of the review is dependent on whether the
COL applicant references a DC, an ESP or other NRC approvals (e.g., manufacturing
license, site suitability report or topical report).

For review of both DC and COL applications, SRP Section 14.3 should be followed for
the review of ITAAC. The review of ITAAC cannot be completed until after the
completion of this section.

3.6.1-9 Revision 3 - March 2007

 TABLE 3.6.1-1

SYSTEMS USUALLY REQUIRED FOR SAFE SHUTDOWN

PWR BWR

Service Water System Service Water System

Auxiliary Feedwater System Reactor Coolant Injection System
Volume Control System Automatic Depressurization System
Decay Heat Removal System Residual Heat Removal System
Component Cooling Water System Component Cooling Water System
(if provided)

Table 3.6.1-2 is a listing of systems typically classified as either high or moderate energy
systems that are located outside the primary containment in pressurized water reactor (PWR)
and boiling water reactor (BWR) plants.

TABLE 3.6.1-2

TYPICAL HIGH ENERGY SYSTEMS OUTSIDE CONTAINMENT

PWR BWR

Main Steam Line System Main Steam Line System

Main Feedwater Line System Main Feedwater Line System
Auxiliary Feedwater System High Pressure Core Spray System
Volume Control System Process Sampling System
Process Sampling System Condensate System
Condensate System Reactor Cleanup System
Steam Generator Blowdown Line Standby Liquid Control System

TYPICAL MODERATE ENERGY SYSTEMS OUTSIDE CONTAINMENT

PWR BWR

Service Water System Service Water System

Decay Heat Removal System Residual Heat Removal System
(outside of reactor coolant (outside of reactor coolant
pressure boundary) pressure boundary)
Circulating Water System Circulating Water System
Fire Protection System Fire Protection System
Component Cooling Water System Component Cooling Water System

3.6.1-10 Revision 3 - March 2007

IV. EVALUATION FINDINGS

The reviewer verifies that the applicant has provided sufficient information and that the review
and calculations (if applicable) support conclusions of the following type to be included in the
staff's safety evaluation report. The reviewer also states the bases for those conclusions.

The review of the plant design for protection against postulated piping failures outside
containment included all high and moderate energy piping systems located outside
containment. The review of these high and moderate energy systems for the ________ plant
included layout drawings, piping and instrumentation diagrams, and descriptive information.

The staff concludes that the facility design for protection against postulated piping failures
outside containment is acceptable and therefore meets the requirements of 10 CFR Part 50,
Appendix A, GDC 2, GDC 4, 10 CFR 52.47(b)(1), and 10 CFR 52.80(a) with respect to
accommodating the environmental effects of postulated pipe ruptures. The applicant has met
the requirement of GDC 2 by considering the environmental effects from the rupture of
non-seismic piping, and the applicant has met the requirement of GDC 4 with respect to
postulated pipe ruptures by conforming to BTP 3-3.

For DC and COL reviews, the findings will also summarize the staff’s evaluation of
requirements and restrictions (e.g., interface requirements and site parameters) and COL
action items relevant to this SRP section.

In addition, to the extent that the review is not discussed in other SER sections, the findings will
summarize the staff's evaluation of the ITAAC, including design acceptance criteria, as
applicable.

V. IMPLEMENTATION

The staff will use this SRP section in performing safety evaluations of DC applications and
license applications submitted by applicants pursuant to 10 CFR Part 50 or 10 CFR Part 52.
Except when the applicant proposes an acceptable alternative method for complying with
specified portions of the Commission’s regulations, the staff will use the method described
herein to evaluate conformance with Commission regulations.

The provisions of this SRP section apply to reviews of applications submitted six months or
more after the date of issuance of this SRP section, unless superseded by a later revision.
Implementation schedules for conformance to parts of the method discussed herein are
contained in the referenced Branch Technical Positions.

VI. REFERENCES

1. 10 CFR Part 50, Appendix A, General Design Criterion 4, "Environmental and Dynamic
Effects Design Bases."

2. 10 CFR Part 50, Appendix A, General Design Criterion 2, “Design Bases for Protection
Against Natural Phenomena.”

3.6.1-11 Revision 3 - March 2007

3. Branch Technical Position 3-3, "Protection Against Postulated Piping Failures in Fluid
Systems Outside Containment."

4. Branch Technical Position 3-4, "Postulated Rupture Locations in Fluid System Piping
Inside and Outside Containment."

5. 10 CFR 52.47, “Contents of applications.”

6. 10 CFR 52.80, “Issuance of combined licenses.”

PAPERWORK REDUCTION ACT STATEMENT

The information collections contained in the Standard Review Plan are covered by the requirements of 10 CFR Part 50 and
10 CFR Part 52, and were approved by the Office of Management and Budget, approval number 3150-0011 and 3150-0151.

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information
collection requirement unless the requesting document displays a currently valid OMB control number.

3.6.1-12 Revision 3 - March 2007