Th e U.S. N uclear Regu latory C om m ission (NR C) iss ues regu latory gu ides to describe and make available to the public methods that the NRC staff considers acceptable for

use in implementing specific parts of the agency’s regulations, techniques that the staff uses in evaluating specific problems or postulated accidents, and data that the staff need

in reviewing applications for permits and licenses. Regulatory guides are not substitutes for regulations, and compliance with them is not required. Methods and solutions that

differ from those set forth in regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license

by the Comm ission.

Th is guide was issue d after c ons ideration of com m ents received from the pu blic. The NR C staff enc oura ges and welc om es com m ents and sug ges tions in con nec tion with

improv em ents to published regulatory guides, as well as items for inclusion in regulatory guides that are currently being developed. The NR C staff will revise existing guides,

as appropriate, to accommodate comm ents and to reflect new information or experience. W ritten comments may be submitted to the Rules and Directives Branch,

Office of Administration, U.S. Nuclear Regulatory Commission, W ashington, DC 20555-0001.

Re gula tory guides are issued in 10 broad divisions: 1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials Facilities; 4, Environm ental an d Siting; 5, M aterials

and Plant Pro tec tion; 6, Products; 7, T ransportation; 8, Occu pational H ealth; 9, An titrus t and Fina ncial R eview; and 10, G eneral.

Re que sts for single copies of draft or active regulatory guides (which may be reproduced) should be made to the U.S. Nuclear Regulatory Commission, W ashington, DC 20555,

Attention: Reproduction and Distribution Services Section, or by fax to (301) 415-2289; or by email to Distribution@nrc.gov. Ele ctronic c opies o f this g uide an d oth er recently

issued guid es are ava ilable through the NRC’s public W eb site under the Regulatory Guides document collection of the NRC’s Electronic Reading Room

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at http://ww w.nrc .gov /read ing-rm /ada m s.htm l, under Accession No. ML061100174.

U.S. NUCLEAR REGULATORY COMMISSION May 2006

REGULATORY GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 1.205

(Draft was issued as DG-1139, dated September 2004)

RISK-INFORMED, PERFORMANCE-BASED FIRE PROTECTION

FOR EXISTING LIGHT-WATER NUCLEAR POWER PLANTS

A. INTRODUCTION

This regulatory guide provides guidance for use in complying with the requirements that the U.S. Nuclear

Regulatory Commission (NRC) has promulgated for risk-informed, performance-based fire protection programs

that meet the requirements of Title 10, Section 50.48(c), of the Code of Federal Regulations (10 CFR 50.48(c))

and the referenced 2001 Edition of the National Fire Protection Association (NFPA) standard, NFPA 805,

“Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants.”

In accordance with 10 CFR 50.48(a), each operating nuclear power plant must have a fire protection plan

that satisfies General Design Criterion (GDC) 3, “Fire Protection,” of Appendix A, “General Design Criteria

for Nuclear Power Plants,” to 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities.” 

In addition, plants that were licensed to operate before January 1, 1979, must meet the requirements of 10 CFR

Part 50, Appendix R, “Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979,”

except to the extent provided for in 10 CFR 50.48(b). Plants licensed to operate after January 1, 1979, are required

to comply with 10 CFR 50.48(a), as well as any plant-specific fire protection license condition and technical

specifications.

Section 50.48(c), which the Commission adopted in 2004 (69 FR 33536, June 16, 2004), incorporates

NFPA 805 by reference, with certain exceptions, and allows licensees to voluntarily adopt and maintain a fire

protection program that meets the requirements of NFPA 805 as an alternative to meeting the requirements

of 10 CFR 50.48(b) or the plant-specific fire protection license conditions. Licensees who choose to comply with

10 CFR 50.48(c) must submit a license amendment application to the NRC, in accordance with 10 CFR 50.90. 

Section 50.48(c)(3) describes the required content of the application.
RG 1.205, Page 2

Plants (including those licensed after January 1, 1979) that do not adopt an NFPA 805

performance-based fire protection program, but use a risk calculation approach to evaluate plant changes

that affect the fire protection program, must submit a license amendment application for those changes

in accordance with 10 CFR 50.90. Pending NRC review and approval of the licensee’s performancebased methods, the staff cannot accept that these methods will adequately demonstrate that a change

“would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.”

The Nuclear Energy Institute (NEI) has developed NEI 04-02, “Guidance for Implementing a

Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c),” Revision 1, dated

September 2005, to assist licensees in adopting 10 CFR 50.48(c) and making the transition from their

current fire protection program (FPP) to one based on NFPA 805. This regulatory guide endorses

NEI 04-02, Revision 1, because it provides methods acceptable to the NRC for implementing NFPA 805

and complying with 10 CFR 50.48(c), subject to the additional regulatory positions contained in Section C

of this regulatory guide. The regulatory positions in Section C, below, include clarification of the

guidance provided in NEI 04-02, as well as any NRC exceptions to the guidance. The regulatory

positions in Section C take precedence over the NEI 04-02 guidance.

All references to NEI 04-02 in this regulatory guide refer to Revision 1 of that NEI guidance

document. All references to NFPA 805 in this regulatory guide refer to the 2001 Edition of NFPA 805. 

Where “NFPA 805” is used in this regulatory guide to describe the FPP, license, etc., of a nuclear power

plant, it means that the FPP, license, etc., is in accordance with 10 CFR 50.48(c).

This regulatory guide contains information collections that are covered by the requirements

of 10 CFR Part 50 which the Office of Management and Budget (OMB) approved under OMB control

number 3150-0011. The NRC may neither conduct nor sponsor, and a person is not required to respond to,

an information collection request or requirement unless the requesting document displays a currently

valid OMB control number.
RG 1.205, Page 3

B. DISCUSSION

Background

Title 10, Section 50.48(a), of the Code of Federal Regulations, requires all operating nuclear

power plantsto implement an FPP that satisfies GDC 3 of Appendix A to 10 CFR Part 50. In addition to

the requirements of 10 CFR 50.48(a), plants licensed to operate before January 1, 1979, must meet

the requirements of Appendix R to 10 CFR Part 50, to the extent described in 10 CFR 50.48(b). 

Nuclear power plantsthat were licensed to operate after January 1, 1979 (post-79 plants), must comply with

10 CFR 50.48(a), as well as any plant-specific fire protection license conditions and technical specifications.

Fire protection license conditions typically reference NRC safety evaluation reports (SERs), which are

the products of the staff’s initial licensing reviews against either (1) Appendix A to Branch Technical

Position (BTP) Auxiliary Power Conversion Systems Branch (APCSB) 9.5-1, “Guidelines for Fire

Protection for Nuclear Power Plants,” and the criteria in certain sections of Appendix R to 10 CFR

Part 50, or (2) Section 9.5.1, “Fire Protection Program,” of NUREG-0800, “Standard Review Plan

for the Review of Safety Analysis Reports for Nuclear Power Plants” (SRP). The SRP closely follows

the structure and requirements of Appendix R to 10 CFR Part 50.

The fire protection requirements of GDC 3, Appendix R, and the guidance provided in the BTP

and SRP are considered deterministic. The industry and some members of the public have described

these requirements as prescriptive and creating unnecessary regulatory burden. The NRC has issued

approximately 900 plant-specific exemptions to the requirements of Appendix R.

In SECY-98-058, “Development of a Risk-Informed, Performance-Based Regulation for Fire

Protection at Nuclear Power Plants,” dated March 26, 1998, the staff proposed to the Commission that

the staff work with the NFPA and industry to develop a risk-informed, performance-based consensus

fire protection standard for nuclear power plants. This consensus standard could be endorsed in future

rulemaking as an alternative set of fire protection requirements to the existing regulations set forth

in 10 CFR 50.48. In SECY-00-0009, “Rulemaking Plan, Reactor Fire Protection Risk-Informed,

Performance-Based Rulemaking,” dated January 13, 2000, the NRC staff requested and received

Commission approval to proceed with a rulemaking to permit reactor licensees to adopt NFPA 805

as a voluntary alternative to existing fire protection requirements. On February 9, 2001, the NFPA

Standards Council approved the 2001 Edition of NFPA 805 as an American National Standard

for performance-based fire protection for light-water nuclear power plants.

Effective July 16, 2004, the Commission amended its fire protection requirements in 10 CFR 50.48

to add 10 CFR 50.48(c), which incorporates by reference the 2001 edition of NFPA 805, with certain

exceptions, and allows licensees to apply for a license amendment to comply with NFPA 805 (69 FR 33536).

The NRC may incorporate by reference future editions of NFPA 805. However, until the NRC does so,

licensees who wish to use specific risk-informed or performance-based alternatives included in future

editions of NFPA 805 mustsubmit a license amendment application, in accordance with 10 CFR 50.48(c)(4).

In parallel with the Commission’s efforts to promulgate a rule endorsing risk-informed,

performance-based fire protection provisions of NFPA 805, NEI worked with the industry and the NRC

staff to develop implementing guidance for the specific provisions of NFPA 805 and 10 CFR 50.48(c). 

The NEI published such guidance in NEI 04-02, Revision 1, in September 2005. This regulatory guide

provides the staff’s position on NEI 04-02 and offers additional information and guidance to supplement

the NEI document and assist licensees in meeting the Commission’s requirements.
1 The NRC considers probabilistic safety analysis (PSA) and probabilistic risk analysis (PRA) to be synonymous. 

PSA will be used in this regulatory guide. The term “fire PSA,” as used in this regulatory guide, encompasses

all levels and types of PSAs, including pre-NUREG/CR-6850-based fire PSAs, fire individual plant examinations

of external events (IPEEEs), and enhanced internal events PSAs.

RG 1.205, Page 4

Interim Enforcement Discretion Policy

The Commission approved and published its interim enforcement discretion policy pertaining to

discretion for licensees transitioning to NFPA 805 in the Federal Register on June 16, 2004 (see 69 FR

33684). In January 2005, the Commission revised that policy to extend the due date for a licensee to submit

a letter stating its intent to adopt NFPA 805 until December 31, 2005 (see 70 FR 2662). In March 2006,

the Commission revised the policy again to extend the available enforcement discretion from 2 to 3 years.

This revision became effective upon publication in the Federal Register on April 18, 2006 (see 71 FR 19905).

Additional information on the NRC enforcement policies can be found at http://www.nrc.gov/

what-we-do/regulatory/enforcement/enforce-pol.html.

Fire Protection Program Changes

Prior to the promulgation of 10 CFR 50.48(c), plants typically adopted a standard fire protection

license condition. Under this condition, the licensee can only make changes to the approved FPP, without

prior Commission approval, if the changes do not adversely affect the plant’s ability to achieve and maintain

safe shutdown in the event of a fire. A new fire protection license condition, which will be imposed

for licensees choosing to adopt NFPA 805, will define the bases for making changes to the approved

NFPA 805 FPP without prior NRC approval. The NFPA 805 standard contains specific requirements

for evaluating changes to the program. See Regulatory Position 3.1 in Section C of this regulatory guide

for an acceptable fire protection license condition for plants adopting NFPA 805.

Appendices to NFPA 805

As discussed in the Statements of Considerations for the final rulemaking, which incorporated

by reference NFPA 805 (69 FR 33536), the appendices to NFPA 805 are not considered part of the rule. 

However, Appendices A–D provide useful information for implementing the requirements of NFPA 805.

The staff finds the specific guidance contained in those appendices to be acceptable to the extent that

the guidance is specifically endorsed within the positions contained in Section C of this regulatory guide.

Fire Probabilistic Safety Assessment

Although a licensee may transition to an NFPA 805-based FPP without a fire probabilistic safety

assessment (PSA)1 model, the NRC anticipates that licensees will develop a plant-specific fire PSA

for this purpose. The NRC recommends that licensees adopting an NFPA 805 license develop a plantspecific fire PSA as an integral part of their transition process. Without a fire PSA, licensees will not

realize the full safety and cost benefits of transitioning to NFPA 805.

The NRC may revise this regulatory guide in the future to endorse, to the extent practical,

specific risk assessment methods for use in implementing NFPA 805 and to provide additional guidance

on PSA quality. That guidance may be based on updates to Regulatory Guide 1.200, the final ANS Fire

PRA Standard, and the knowledge gained during the pilot programs planned for the first two plants

that adopt a performance-based FPP in accordance with 10 CFR 50.48(c).
RG 1.205, Page 5

C. REGULATORY POSITION

1. NEI 04-02

This regulatory guide endorses the guidance of NEI 04-02, Revision 1, which provides methods

acceptable to the staff for adopting an FPP consistent with the 2001 edition of NFPA 805 and 10 CFR 50.48(c),

subject to the regulatory positions and exceptions contained herein. Future revisions of NEI 04-02 may

be evaluated by the NRC, and acceptable revisions will be endorsed in accordance with the appropriate

regulatory process.

NEI 04-02 provides the majority of the guidance applicable to implementing the regulatory

requirements of 10 CFR 50.48(c) and NFPA 805. The guidance included in this regulatory guide

is provided to emphasize certain issues; clarify the requirements of 10 CFR 50.48(c) and NFPA 805;

clarify the guidance in NEI 04-02; and modify the NEI 04-02 guidance where required. Should a conflict

occur between NEI 04-02 and this regulatory guide, the regulatory guide governs.

Since the purpose of this regulatory guide is to provide guidance for implementing the requirements of

10 CFR 50.48(c) and NFPA 805, the NRC’s endorsement of NEI 04-02 excludes Section 6.0,

“Implementing Guidance for Use of Tools and Processes Within Existing Licensing Basis,” which provides

guidance for using the risk-informed methods of NFPA 805 without adopting an NFPA 805 license.

In addition, the NRC’s endorsement of NEI 04-02 does not imply the NRC’s endorsement

of the references cited in NEI 04-02. The guidance provided by these references has not necessarily

been reviewed and approved by the NRC, except where specifically noted in this regulatory guide.

NEI 04-02, Appendix D, “Fire Modeling,” and NFPA 805, Appendix C, “Application of Fire

Modeling in Nuclear Power Plant Fire Hazard Assessments,” contain detailed discussions that are useful

in determining which fire models to use and in applying those fire models within their limitations. 

However, the NRC only endorses these appendices to the extent described in Regulatory Position 4.2. 

Analyses performed by licensees using the information in these appendices should include adequate

technical justification for methodologies and data, as appropriate.

NFPA 805 refers to “the authority having jurisdiction (AHJ)” The NRC is the AHJ for purposes

of nuclear health and safety and common defense and security.

2. License Transition Process

2.1 General

Neither 10 CFR 50.48(c) nor NEI 04-02 mandates a specific schedule for implementing an FPP

that meetsthe provisions of NFPA 805. However, licensees who wish to take advantage of the Commission’s

interim enforcement discretion policy for fire protection will need to establish an implementation schedule

consistent with the enforcement policy.

2.2 License Amendment Request

Section 4.6.1 of NEI 04-02 provides a list of key items that should be included in the license

amendment request. In addition to the items listed in NEI 04-02, the submittal should include a description

of all FPP changes, as defined in Regulatory Position 3.2.1, that are to be included in the transition

to the NFPA 805 license.
RG 1.205, Page 6

Certain aspects of the plant’s FPP may not have been specifically approved by the NRC

(e.g., through an approved 10 CFR 50.12 exemption request). This has resulted in uncertainty in licensees’

fire protection licensing bases. Licensees may elect to submit uncertain elements of their plant’s FPP,

such as the crediting of operator manual actions and circuit analysis methods, in order to obtain explicit

approval of these elements under 10 CFR 50.48(c). NEI 04-02 provides guidance on elements of the FPP

that licensees may want to address in the license amendment request for this purpose. The submittals

addressing these FPP elements should include sufficient detail to allow the NRC to adequately assess

whether the licensee’s treatment of these elements meets 10 CFR 50.48(c) requirements.

10 CFR 50.48(c)(2)(vii) allows a licensee to request NRC approval (by license amendment)

of the use of NFPA 805 performance-based methods in determining the licensee’s compliance with

the fire protection program elements and minimum design requirements in Chapter 3 of NFPA 805. 

10 CFR 50.48(c)(4), allows a licensee to request NRC approval (by license amendment) of the use

of alternative risk-informed or performance-based methods (i.e., methods that differ from those prescribed

by NFPA 805) to demonstrate compliance with 10 CFR 50.48(c). Regulatory Position 3.2.3 provides

guidance for including such requests in the license amendment request for transitioning to NFPA 805.

The total risk increase associated with all FPP noncompliances (based on current deterministic

FPP regulations) that the licensee does not intend to bring into compliance and the total risk change

associated with plant changes planned for the transition to NFPA 805 should be estimated and reported

in the license amendment request. The baseline FPP risk for the estimate of the net risk change is that

for a plant that is fully compliant with the current deterministic regulations for the FPP, including

NRC-approved exemptions/deviations. The risk increase may be combined with risk decreases associated

with retaining or making changes to fire protection features (fire protection systems and procedures

relied upon to meet FPP nuclear safety and radioactive release performance criteria) not required by

NFPA 805 when estimating the total risk change to be reported in the license amendment request.

Systems and features not required by NFPA 805 but credited in the risk assessment to meet

NFPA 805 performance criteria should be included in the FPP monitoring program. The total change

in risk associated with the transition to NFPA 805 should be consistent with the acceptance guidelines

in Regulatory Guide 1.174, “An Approach for Using Probabilistic Risk Assessment in Risk-Informed

Decisions on Plant-Specific Changes to the Licensing Basis.”

Upon completing the transition to an NFPA 805 licensing basis, the baseline FPP risk will be

the risk of the plant as-designed and operated according to the NRC-approved FPP licensing basis.

2.3 Existing Engineering Equivalency Evaluations

Section 2.2.7 of NFPA 805 describes the application of existing engineering equivalency evaluations

(EEEEs) when using a deterministic approach during the transition to an NFPA 805 FPP. One type

of EEEE, commonly referred to as a “Generic Letter 86-10 (GL 86-10) evaluation,” allows licensees

who have adopted the standard fire protection license condition (under their current FPP and in accordance

with GL 86-10) to make changes to the approved FPP without prior NRC approval if those changes

would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. 

With the exception of evaluations of certain recovery actions and any deviations from NFPA 805

requirements, a GL 86-10 evaluation showing no adverse effect on safe shutdown and permitted under

the licensee’s current licensing basis is one acceptable means of meeting the NFPA 805 EEEE acceptance

criterion of “an equivalent level of fire protection compared to the deterministic requirements.” However,

EEEEs performed prior to transitioning to a performance-based FPP must be based on deterministic methods.

If based on a risk calculation, the EEEE will have to be evaluated using the licensee’s approved NFPA 805

change evaluation process.
RG 1.205, Page 7

Operator manual actions credited for protection of redundant trains, in lieu of Appendix R

III.G.2 protection, do not meet the deterministic requirements in Chapter 4 of NFPA 805. Consequently,

unless specifically approved by the NRC, these operator manual actions should be addressed as plant changes

in accordance with Section 2.4.4 of NFPA 805 using performance-based methods. The change process

must include an evaluation of the risk impact associated with the operator manual action (either qualitative

or quantitative), as appropriate. Quantitative risk calculations should be in accordance with Section 4.2.4.2

of NFPA 805 (a bounding calculation approach is acceptable). Recovery actions (NFPA 805 terminology

for operator manual actions and repairs) that meet the required performance criteria of NFPA 805

and the criteria in this regulatory guide for making changes without prior NRC review and approval

do not need to be submitted to the NRC for approval.

NEI 04-02, Section 4.1.1, “Transition Process Overview,” notes that the licensee will review

EEEEs during the transition process to ensure the quality level and basis for acceptability are still valid. 

Except as noted above, satisfactory resultsfrom this review will provide adequate basis to transition EEEEs

as meeting the deterministic requirements of Chapter 4 of NFPA 805. Guidance for acceptable EEEEs

is provided in NUREG-0800, Section 9.5.1, “Fire Protection,” and in Regulatory Guide 1.189,

“Fire Protection for Operating Nuclear Power Plants.”

EEEEs that support deviations from the requirements and methods of NFPA 805 must be submitted

for NRC approval in accordance with 10 CFR 50.48(c) and NFPA 805. Regulatory Position 3.2.4

also provides specific guidance regarding submittal requirements. Of the EEEEs that must be approved

by the NRC, those that are preexisting and those performed during the transition to an NFPA 805

licensing basis should be submitted with the fire protection license amendment request.

2.4 Documentation of Prior NRC Approval

Chapter 3 of NFPA 805 notes that alternatives to the fundamental FPP attributes of Chapter 3,

which were previously approved by the NRC, take precedence over the requirements in Chapter 3. 

The documentation which demonstrates prior NRC approval of an alternative to Chapter 3 requirements,

as well as approval of noncompliances with existing license regulatory requirements, includes NRC approvals

of exemption or deviation requests. Inspection reports, meeting minutes, and letters from licensees

without a corresponding written NRC approval are examples of documents that do not represent NRC

approval for this purpose. Documents listed in NEI 04-02, but not addressed in this regulatory position,

do not necessarily represent NRC approval and must be evaluated by the NRC on a case-by-case basis. 

Changes to the approved FPP that have not been specifically reviewed and approved by the NRC

are subject to review through the Reactor Oversight Process.

3. NFPA 805 Fire Protection Program

3.1 Standard License Condition

As specified in 10 CFR 50.48(c)(3)(i), the license amendment request must identify any

license conditions to be revised or superceded. 10 CFR 50.48(c) and NFPA 805 identify aspects

of a performance-based FPP that must be specifically approved by the NRC (referred to as the AHJ

in NFPA 805) via a license amendment. It is the intent of 10 CFR 50.48(c) that certain changes may be

made to the FPP without prior NRC review and approval. This intent is reflected in the regulatory

analysis for 10 CFR 50.48(c), which states, “Licensees choosing to use the flexibilities provided by

the rulemaking could use risk-informed and performance-based approaches and methods in NFPA 805,

rather than submitting an exemption or deviation request each time they wish to depart from current

requirements.”
RG 1.205, Page 8

The NRC intends to provide thisflexibility to make changes without prior NRC review and approval

for licensees that transition to 10 CFR 50.48(c) by adopting the following fire protection license condition,

which includes acceptance criteria for making changes to the licensee’s fire protection program without

prior NRC review and approval. The application of these risk acceptance criteria requires that the plant

have an acceptable fire PSA that is in accordance with the guidance in Regulatory Position 4.3 and has been

subjected to a peer or NRC review process assessed against a standard or set of acceptance criteria that is

endorsed by the NRC:

(Name of Licensee) shall implement and maintain in effect all provisions of the approved fire

protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c) as specified in

the licensee amendment request dated and as approved in the safety evaluation report

dated (and supplements dated ). Except where NRC (AHJ) approval

for changes or deviations is required by 10 CFR 50.48(c) and NFPA 805, the licensee may make

changes to the fire protection program without prior approval of the Commission if those changes

satisfy the provisions set forth in 10 CFR 50.48(a), 10 CFR 50.48(c), and the following:

(a) Prior NRC review and approval is not required for a change that results in a net decrease in risk

for both CDF and LERF. The proposed change must also be consistent with the defense-in-depth

philosophy and must maintain sufficient safety margins. The change may be implemented

following completion of the change evaluation.

(b) Prior NRC review and approval is not required if the change results in a net calculated risk

increase less than 1E-7/yr for CDF and less than 1E-8/yr for LERF. The proposed change

must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety

margins. The change may be implemented following completion of the change evaluation. 

Change reports need not be submitted to the NRC for these changes.

(c) Where the calculated plant change risk increase is <1E-6/yr, but $1E-7/yr for CDF or <1E-7/yr,

but $1E-8/yr for LERF, the licensee must submit a summary description of the change to the NRC

following completion of the change evaluation. The proposed change must also be consistent with

the defense-in-depth philosophy and must maintain sufficient safety margins. If the NRC does not

object to the change within 90 days, the licensee may proceed with implementation of the proposed

change.

3.2 NFPA 805 Fire Protection Program Change Evaluation Process

3.2.1 Definition of a Change

NFPA 805 includes provisions for licensees to make changes to their approved FPP

(once the transition to an NFPA 805 license is complete). In the context of an NFPA 805 FPP

that complies with 10 CFR 50.48(c), a change may be any of the following:

(a) a physical plant modification that affects the FPP

(b) a programmatic change (e.g., change to a procedure, assumption or analysis) that affects the FPP

(c) an in situ condition (physical or programmatic) that is an FPP regulatory noncompliance

or a fire protection licensing-basis noncompliance, which the licensee does not intend to correct

via a plant or programmatic modification

Noncompliances are based on the regulations that were applicable to the licensee prior to

the transition to a 10 CFR 50.48(c) FPP. The requirements of 10 CFR 50.48(c) and the guidance provided

in this regulatory guide for evaluating changes are applicable regardless of when the noncompliance

is identified (during or after the transition to an NFPA 805 license).
RG 1.205, Page 9

For “changes” that involve acceptance of an existing unapproved condition (i.e., a noncompliance),

appropriate compensatory measures should be established and should remain in place until the condition

is accepted via applicable plant change processes, including the change process in the standard fire protection

license condition.

3.2.2 Fire Protection Program Change Evaluations

The licensee should perform an engineering evaluation to demonstrate acceptability of the change

in terms of the plant change evaluation criteria and compliance with the fire protection requirements

of 10 CFR 50.48(a) and NFPA 805. The plant change evaluation process includes an integrated assessment

of the acceptability of risk, defense-in-depth (DID), and safety margins, regardless of the methods

or approaches used to evaluate the change.

3.2.3 Deviations from NFPA 805 Chapter 3 Requirements and Alternative Change Evaluation

Methodologies

10 CFR 50.48(c)(2)(vii) allows a licensee to request NRC approval (by license amendment)

of the use of NFPA 805 performance-based methods in determining the licensee’s compliance with

the fire protection program elements and minimum design requirements in Chapter 3 of NFPA 805. 

10 CFR 50.48(c)(4) allows a licensee to request NRC approval (by license amendment) of the use of

alternative risk-informed or performance-based methods (i.e., methods that differ from those prescribed

by NFPA 805, to demonstrate compliance with 10 CFR 50.48(c).

Performance-based methods, including proposed alternative methods, applied to the licensee’s FPP,

including evaluation of changes to the program, must ensure the following:

(a) The required NFPA 805 performance goals, performance objectives, and performance criteria

are satisfied.

(b) Safety margins are maintained.

(c) Fire protection defense-in-depth is maintained.

Alternative risk-informed, performance-based methods should be described in a license amendment

request and must be approved by the NRC prior to incorporation in the licensee’s FPP. In addition to

the guidance in NEI 04-02, Section 2.4, the license amendment request should include, as a minimum,

the following:

(a) detailed description of the alternative risk-informed, performance-based method

(b) description of how the method will be applied, the aspects of the FPP to which it will applied,

and the circumstances under which it will be applied

(c) acceptance criteria, including risk increase acceptance criteria, that the licensee will apply when

determining whether the results of an evaluation that uses this methodology meet the required

NFPA 805 performance goals, performance objectives, and performance criteria

(d) for PSA-based methodologies, an explanation of how the PSA is of sufficient technical adequacy

for evaluation of the changes to which it will be applied

(e) for PSA-based methodologies, a description of the peer review and how the review findings

have been addressed
RG 1.205, Page 10

The license amendment request should include complete and concise details of the proposed

methodology to minimize the potential for misinterpretations. Where the alternative methods have been

adequately described in the license amendment request and have been accepted by the NRC in an SER,

these methods may be applied to the licensee’s FPP. A licensee may apply these approved methods

within the limits specifically described in the licensing basis to implement plant changes that affect

the FPP without prior NRC review and approval.

The types of plant changes that may be approved without prior review and approval will be

limited to those for which the risk assessment methods are adequate to demonstrate that any increase

in risk will be below the appropriate thresholds. In addition, subsequent changes to the approved

alternative methodology must be submitted for NRC review and approval (via a license amendment request)

prior to being applied to the licensee’s FPP.

3.2.4 NRC Approval of Fire Protection Program Changes

The following FPP changes must be submitted for NRC review and approval (via a license

amendment request) prior to implementation, except where otherwise permitted by the approved

fire protection license condition:

(a) changes that are alternatives to the fundamental FPP attributes required by Chapter 3 of NFPA 805,

which have not previously been approved by the NRC

(b) changes that do not meet the acceptance criteria of the approved license condition

(c) changes that have been evaluated using performance-based methods other than those described

in Regulatory Position 4, included in NFPA 805, or described in the NRC-approved plant FPP

(d) changes that involve, or require conforming changes to, a license condition or the plant’s

technical specifications

Following completion of the licensee’s change evaluation, the licensee shall submit the request

for approval of the change(s) to the NRC pursuant to 10 CFR 50.48(c) and 10 CFR 50.90. For “changes”

that involve acceptance of an existing condition (i.e., a noncompliance), appropriate compensatory measures

should be established and should remain in place until the license amendment is approved by the NRC.

3.2.5 Plant Changes Without Prior NRC Approval

This regulatory guide provides one acceptable approach for licensees to make FPP changes

without prior NRC review and approval. NFPA 805 Section 2.4.4.1, “Risk Acceptance Criteria,” notes

that the change in public health risk from any plant change shall be acceptable to the AHJ. The risk

acceptance criteria for plant changes as provided in the standard license condition in Regulatory Position 3.1

are acceptable to the NRC. 

Where permitted by the approved fire protection license condition, plants that have an acceptable

fire PSA that is in accordance with the guidance in Regulatory Position 4.3 and has been subjected to

a peer review process assessed against a standard or set of acceptance criteria that is endorsed by the NRC,

may make changes without prior NRC review and approval based on the criteria in Regulatory Position 3.1.
RG 1.205, Page 11

When comparing the risk impact of a change to the risk thresholds, licensees should use

the combined change in risk in accordance with Regulatory Position 3.2.6. The guidance for combining

changes, provided in Section 2.1.2 of Regulatory Guide 1.174, is applicable. For changes with

a calculated plant change risk increase of <1E-6/yr, but $1E-7/yr for core damage frequency (CDF),

or <1E-7/yr, but $1E-8/yr for large early release frequency (LERF), the licensee must submit a summary

description of the change to the NRC following completion of the change evaluation. The proposed

change must also be consistent with the DID philosophy and must maintain sufficient safety margins. 

The summary description required for reporting changes should include the following information:

• summary of the change evaluation

• assumptions

• description of programmatic control elements (e.g., hot work permitting/fire watches

and combustibles control) in place that support the analysis

• change ()) in CDF/LERF, including the change in individual parameters used to calculate

the )CDF/)LERF

• effect of the change on safety margin

• effect of the change on defense-in-depth

The change description should be submitted in accordance with 10 CFR 50.4(a) and (b)(1). 

The submittal should be signed by the responsible officer for the licensee’s FPP. If the NRC does not

object to the change within 90 calendar days, the licensee may proceed with implementation of

the proposed change.

3.2.6 Cumulative Risk of Changes

Section 2.4.4.1 of NFPA 805 requires licensees to evaluate the cumulative effect of plant changes

(including all previous changes that have increased risk) on overall risk. Evaluation of the cumulative

risks shall be performed in accordance with Section 3.3.2 of Regulatory Guide 1.174.

Section 2.4.4.1 further states that if more than one plant change is combined into a group

for the purposes of evaluating acceptable risk, the evaluation of each individual change shall be performed

along with the evaluation of combined changes. Following the transition to the NFPA 805 license,

the total risk associated with multiple changes should be combined in accordance with Sections 2.1.1

and 2.1.2 of Regulatory Guide 1.174, when evaluating the combined change against the risk thresholds

provided in this regulatory guide or the plant’s fire protection license condition. For plants using

PSA methods, approved changes should be incorporated in the periodic updates of the PSA model. 

Cumulative risk increase associated with all changes made after the transition is complete does not need

to be calculated. Acceptability of total plant risk will be judged according to Regulatory Guide 1.174. 

Post-transition risk reductions for plant changes that are not related to the FPP may be used to offset

risk increases attributable to FPP-related changes in accordance with Section 2.1.2 of RG 1.174,

but must be pre-approved by the NRC as required by the standard fire protection license condition. 

Risk reductions for changes related to the FPP may be used as offsets without pre-approval by the NRC.
RG 1.205, Page 12

In accordance with the definition of a change in Regulatory Position 3.2.1, the licensee is required

to track the net risk increase associated with any series of changes related to the same FPP issue,

for all FPP changes that affect the same fire area of the plant, or for all FPP changes related to the same

fire scenario, as applicable. For example, assume a licensee transitions with an automatically actuated

suppression system in a particular area of the plant. Then the licensee subsequently makes two changes

to this system at different times, first converting the automatic actuation to manual actuation, and later

eliminating the system altogether. When calculating the net risk increase due to eliminating the system,

the licensee should calculate the total risk increase from both changes (i.e., the increase in risk between

an automatically actuated system and no system) when comparing the risk change to the risk thresholds. 

This applies no matter how distant in time the changes have been made relative to the date of the transition

or to each other, whether or not each was performed prior to different periodic updates of the fire PSA.

3.3 Circuit Analysis

Industry guidance document NEI 00-01, Revision 1, “Guidance for Post-Fire Safe Shutdown

Circuit Analysis,” used in conjunction with NFPA 805 and this regulatory guide, provides one acceptable

approach to circuit analysis for a plant that has transitioned to a 10 CFR 50.48(c) licensing basis. 

Where the deterministic requirements in Chapter 4 of NFPA 805 cannot be met for the protection

of required circuits, circuit analysis assumptions regarding the number of spurious actuations, the manner

in which they occur (e.g., sequentially or simultaneously), and the time between spurious actuations

should be supported by engineering analysis and/or test results that are accepted by industry and the NRC.

Aspects of circuit protection that do not conform to the deterministic requirements in Chapter 4

of NFPA 805 and were not previously approved by the NRC in accordance with Regulatory Position 2.4

may be evaluated using the NFPA 805 plant change process. Those evaluations of nonconformances

that adequately demonstrate that the required performance criteria of NFPA 805 are met in accordance

with this regulatory guide, do not need to be submitted to the NRC for approval.

Section B.2.1 of NEI 04-02 describes three thresholds that are applicable to the change in risk

associated with multiple spurious actuations when performing the post-fire safe-shutdown circuit analysis,

including change evaluations. The staff accepts the NEI thresholds for screening (<1E-8/yr for )CDF

and <1E-9/yr for )LERF) and for circuit protection (<1E-6/yr for )CDF and <1E-7/yr for )LERF). 

However, for a risk increase $1E-7/yr but <1E-6/yr for CDF, or $1E-8/yr but <1E-7/yr for LERF,

the actions required should be in accordance with the standard license condition in Regulatory Position 3.1.

Although the NEI 04-02 thresholds assume no credit for recovery actions, the thresholds in the standard

license condition may be applied after appropriate credit is given to feasible and reliable recovery actions.

Quantitative risk calculations must use the approach described in Section 4.2.4.2 of NFPA 805

(compare the noncompliance risk to the compliance risk based on the deterministic approach in Section 4.2.3

of NFPA 805). A bounding calculation approach reviewed and approved by the NRC is acceptable. 

New scenarios resulting from multiple spurious actuations that are identified should be entered into

the corrective action program and evaluated for inclusion into the fire protection licensing basis.

The nuclear safety circuit analysis should address possible equipment damage caused by spurious

actuation, as well as the inability to restore equipment operability, including the types of failures

described in NRC Information Notice (IN) 92-18, “Potential for Loss of Remote Shutdown Capability

During a Control Room Fire,” dated February 1992, and Regulatory Guide 1.106, “Thermal Overload

Protection for Electric Motors on Motor-Operated Valves,” dated November 1975. The type of failure

described in IN 92-18 is an example of a failure mechanism that may not have been considered during

the post-fire safe-shutdown analysis. Protecting against this one type of failure does not preclude

the requirement to address other possible fire-induced failure mechanisms.
RG 1.205, Page 13

3.4 Physical Protection and Security Orders

NRC requirements for physical protection of nuclear power plants are set forth in 10 CFR Part 73,

“Physical Protection of Plant and Materials.” Those physical protection requirements are further

supplemented by various security-related orders (e.g., EA-02-026, “Interim Safeguards and Security

Compensatory Measures,” dated February 25, 2002; EA-03-086, “Revised Design-Basis Threat

for Operating Power Reactors,” dated April 29, 2003; and other security-related orders for operating

reactors, as applicable), advisories, other generic communications, and plant-specific security commitments.

Licensees who implement changes to their plants shall ensure that compliance with the physical protection

requirements, security orders and subsequent rulemaking, and adherence to commitments applicable to

their plant are maintained.

4. NFPA 805 Analytical Methods and Tools

4.1 General

Engineering analyses and associated methods that the licensee applies to demonstrate compliance

with the nuclear safety and radioactive release performance criteria should have the requisite degree

of technical and defensible justification, as dictated by the scope and complexity of the specific application.

Persons qualified in the specific analytical methods should perform these analyses.

4.2 Fire Models

Section 1.6.18 of NFPA 805 defines a fire model as the “mathematical prediction of fire growth,

environmental conditions, and potential effects on structures, systems, or components based on

the conservation equations or empirical data.” Section 2.4.1.2.1 of NFPA 805 requires that only fire models

acceptable to the AHJ (NRC) be used in fire modeling calculations. Further, Sections 2.4.1.2.2 and 2.4.1.2.3

of NFPA 805 require that the fire models shall be applied within their limitations and shall be verified

and validated (V&V’d)..

Licensees are required to document that the fire models and methods used meet NRC requirements.

Licensees shall also document that the models and methods used in performance-based analyses are used

within their limitations and with the rigor required by the nature and scope of the analyses. These analyses

may use simple hand calculations or more complex computer models, depending on the specific conditions

of the scenario being evaluated. Appendix C to NFPA 805 and Appendix D to NEI 04-02 contain

discussions that are useful in determining which fire models to use and applying those fire models

within their limitations; however, the NRC only endorses the fire models, methodologies, data,

and examples in those appendices to the extent that they have been (or can be) adequately V&V’d,

or to the extent that they are appropriate for the specific application.

The NRC’s Office of Nuclear Regulatory Research (RES) and the Electric Power Research Institute

(EPRI) have documented the V&V for parts of five fire models in draft NUREG-1824/EPRI 1011999,

“Verification and Validation of Selected Fire Models for Nuclear Power Plant Applications.”

The specific fire models documented are (1) NUREG-1805, “Fire Dynamics Tools (FDTs),”

(2) Fire-Induced Vulnerability Evaluation (FIVE), Revision 1, (3) the National Institute of Standards

and Technology (NIST) Consolidated Model of Fire Growth and Smoke Transport (CFAST),

(4) the Electricité de France (EdF) MAGIC code, and (5) the NIST Fire Dynamics Simulator (FDS).
RG 1.205, Page 14

Licensees may propose the use of fire models that have not been specifically V&V’d by the NRC;

however, licensees are responsible for providing acceptable V&V of these fire models. The V&V

documents for licensee-proposed fire models are subject to NRC review and approval under the provisions

of 10 CFR 50.48(c)(4).

4.3 Fire Probabilistic Safety Assessment/Risk Analysis

Section 2.4.3.3 of NFPA 805 requires that the PSA approach, methods, and data must be acceptable

to the AHJ. This regulatory position provides guidance with respect to acceptability of the approaches,

methods and data used for the PSA approach. Additional guidance for the PSA approach is provided

by NEI 04-02, including Sections 5.1.3, 5.3.4, J.4, and J.5.

Licensees should justify that the methods that the NRC finds acceptable for use in meeting

NFPA 805 requirements are appropriate for each specific application. These analyses may use screening

methods or more complex quantitative PSA methods, depending on the specific conditions of the scenario

being evaluated.

When licensees choose to rely on information in an internal events-based PSA model to quantify

risk associated with fires, they should review the analysis to ensure that the model addresses applicable

NFPA 805 requirements, including the engineering analysis requirements in Section 2.4.2 of NFPA 805. 

Based on the review, the licensee should modify its internal events-based PSA model, as necessary,

to meet applicable NFPA 805 requirements.

Where licensees choose to rely on past fire protection PSAs [e.g., individual plant examination

of external events (IPEEE) for fires], the licensees should review these past analyses to determine their

continued applicability and adequacy (e.g., inputs, assumptions, data) to meet the NFPA 805 requirements.

Licensees should reconsider scenarios previously screened from analysis, if changes associated with

NFPA 805 implementation or compliance alter the scope of the original analysis or the screening conclusions.

Some detailed fire PSAs implicitly model failure of fire detectors and manual/automatic suppression

per fire area and scenario when assigning the fire initiation frequency to that particular scenario. If so,

any “modification factor,” typically called a “severity factor” and employed to compensate for the fire

initiation frequency not implicitly accounting for detection or suppression, should not include

considerations of detection or suppression in order to avoid any nonconservative double-counting.

RES and EPRI have documented fire PSA methods, tools, and data to support risk assessments

in NUREG/CR-6850/EPRI 1011989, “EPRI/NRC-RES Fire PRA Methodology for Nuclear Power

Facilities,” which discusses methods to perform fire risk analyses. Additional guidance on PSA quality

is provided in Regulatory Guide 1.174 and Regulatory Guide 1.200, “An Approach for Determining

the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities,”

dated February 2004 (for trial use). The American Nuclear Society (ANS) plans to issue a standard

for evaluating the technical adequacy of each plant’s fire risk assessment for regulatory applications. 

The ANS standard is intended to provide the necessary information for determining the technical adequacy

of the licensee’s fire risk analyses for regulatory applications.

The fire PSAs developed by the licensees that participate in the NFPA 805 Pilot Program will be

reviewed by the NRC over the course of the program, such that a separate peer review of the fire PSA

will not be required. Plants that do not participate in the Pilot Program should subject their fire PSA

to a peer review to the extent that adequate industry guidance is available in a timely manner to support

the transition process. The industry guidance will be reviewed and accepted by the NRC prior to its

application to specific fire PSAs.
RG 1.205, Page 15

The NRC will also review the results of the plant-specific peer reviews. A peer review should be

conducted for all types and levels of fire PSAs, including pre-NUREG/CR- 6850-based fire PSAs,

fire IPEEEs, and enhanced internal events PSAs. (In the event that adequate industry guidance is not

available for conducting a fire PSA peer review, the NRC will review the fire PSA for acceptability.)

The licensee should submit the documented high-level findings from the fire PSA peer review

with the 10 CFR 50.48(c) license amendment request, including the resolution (or proposed resolution)

of potentially risk-significant findings. Actions required as a result of the review may be completed later,

but a schedule for completion should be provided prior to license amendment request approval. 

Incomplete actions that could have a nonconservative effect on the outcome of a plant change evaluation,

should be completed before the licensee’s fire PSA is applied to the evaluation of the plant change.

The licensee is required to maintain the quality of the fire PSA in accordance with the resolution

commitments in the approved license amendment request, ensuring that updates to this fire PSA

(e.g., updates to incorporate post-transition plant changes) conform to the quality of the approved fire PSA.

One acceptable means to maintain fire PSA quality is by periodically (e.g., no less frequent than

the periodic review for the full plant PSA) performing a reduced-scope peer review, analogous to what

was performed for the license amendment request. The results of these periodic licensee peer reviews

should be made available to NRC inspectors for their review.
RG 1.205, Page 16

D. IMPLEMENTATION

The purpose of this section is to provide information to licensees regarding the NRC staff’s plans

for using this regulatory guide. No backfitting is intended or approved in connection with the issuance

of this guide.

Except in those cases in which a licensee proposes or has previously established an acceptable

alternative method for complying with specified portions of the NRC’sregulations, the NRC staff will use

the methods described in this guide to evaluate licensee compliance with the requirements of 10 CFR

50.48(c), as presented in (1) submittals in connection with applications for construction permits,

standard plant design certifications, operating licenses, early site permits, and combined licenses;

and (2) submittals from operating reactor licensees who voluntarily propose to initiate system modifications

that have a clear nexus with the subject for which guidance is provided herein.

REGULATORY ANALYSIS

The NRC staff did not prepare a separate regulatory analysis for this regulatory guide. 

The regulatory basis for this guide is the regulatory analysis prepared for the amendments to 10 CFR

Part 50, “Voluntary Fire Protection Requirements for Light-Water Reactors; Adoption of NFPA 805

as a Risk-Informed, Performance-Based Alternative,” issued on June 16, 2004 (see 69 FR 33536),

which examines the costs and benefits of the rule as implemented by this guide. A copy of that regulatory

analysis is available for inspection and may be copied (for a fee) at the NRC’s Public Document Room,

located at One White Flint North, 11555 Rockville Pike, Room O1-F15, Rockville, Maryland.

BACKFIT ANALYSIS

As stated in the backfit analysis for the rulemaking (see 69 FR 33536), the rulemaking does not

involve a backfit because it does not impose new regulatory requirements, because it provides a voluntary

alternative to the existing fire protection requirements in 10 CFR 50.48. This regulatory guide also

does not involve a backfit because it does not impose requirements on licensees, and does not contain

changed positions on compliance with 10 CFR 50.48(c).
2 Copies may be purchased from the Electric Power Research Institute (EPRI), 3420 Hillview Ave., Palo Alto, CA 94304;

telephone (800) 313-3774; fax (925) 609-1310.

3 Copies may be purchased from Electricité de France (EDF), 22-30 Avenue de Wagram, 75382, Paris Cedex 8, France. 

4 Copies may be purchased from the National Fire Protection Association (NFPA), 1 Batterymarch Park, Quincy, MA

[phone: (800) 344-3555; fax: (800) 593-NFPA (6372)]. Purchase information is available through the NFPA’s

Web-based store at http://www.nfpa.org/catalog/product.asp?category%5Fname=&pid=80501&target%5Fpid=80501

&src%5Fpid=&link%5Ftype=search.

RG 1.205, Page 17

REFERENCES

EPRI TR-1002981, “FIVE Rev. 1 Fire Modeling Guide for Nuclear Power Plant Applications,”

Electric Power Research Institute, Palo Alto, California, August 2002.2

Gay. L., and C. Epiard, “Magic Software Version 4.1.1: Mathematical Model,” HI82/04/024/P,

Electricité de France (EDF), December 2004.3

GL 86-10, “Implementation of Fire Protection Requirements,” U.S. Nuclear Regulatory Commission,

Washington, DC, April 24, 1986, available electronically through the NRC’s public Web site,

at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/gen-letters/1986/gl86010.html.

IN 92-18, “Potential for Loss of Remote Shutdown Capability During a Control Room Fire,”

U.S. Nuclear Regulatory Commission, Washington, DC, February 1992, available electronically

through the NRC’s public Web site, at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/

info-notices/1992/in92018.html.

McGrattan, K.B., “Fire Dynamics Simulator (Version 4): User’s Guide,” NIST SP 1019, National Institute

of Standards and Technology (NIST), Gaithersburg, Maryland, July 2004, available electronically

through NIST’s public Web site, at http://fire.nist.gov/bfrlpubs/fire04/PDF/f04099.pdf.

McGrattan, K.B., “Fire Dynamics Simulator (Version 4): Technical Reference Guide,” NIST SP 1018,

National Institute of Standards and Technology (NIST), Gaithersburg, Maryland, July 2004, available

electronically through NIST’s public Web site, at http://fire.nist.gov/bfrlpubs/fire04/PDF/f04100.pdf.

NEI 00-01, “Guidance for Post-Fire Safe-Shutdown Circuit Analysis,” Revision 1, Nuclear Energy

Institute, Washington, DC, January 2005, available electronically through the NRC’s public Web site,

at http://adamswebsearch2.nrc.gov/idmws/doccontent.dll?library=PU_ADAMS^PBNTAD01&ID=05301

0826:2.

NEI 04-02, “Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program

Under 10 CFR 50.48(c),” Revision 1, Nuclear Energy Institute, Washington, DC, September 2005,

available electronically through the NRC’s Agencywide Documents Access and Management System

(ADAMS), http://www.nrc.gov/reading-rm/adams.html, under Accession #ML052590476.

NFPA 805, “Performance-Based Standard for Fire Protection for Light-Water Reactor Electric

Generating Plants,” 2001 Edition, National Fire Protection Association, Quincy, MA.4
5 All NUREG-series reports listed herein were published by the U.S. Nuclear Regulatory Commission, and are available

electronically through the Public Electronic Reading Room on the NRC’s public Web site, at http://www.nrc.gov/

reading-rm/doc-collections/nuregs/. Copies are also available for inspection or copying for a fee from the NRC’s

Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR’s mailing address is USNRC PDR,

Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email PDR@nrc.gov. 

In addition, copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082,

Washington, DC 20402-9328, telephone (202) 512-1800; or from the National Technical Information Service (NTIS),

5285 Port Royal Road, Springfield, VA 22161, http://www.ntis.gov, telephone (703) 487-4650.

6 All regulatory guides listed herein were published by the U.S. Nuclear Regulatory Commission. Where an ADAMS

accession number is identified, the specified regulatory guide is available electronically through the NRC’s

Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html. 

All other regulatory guides are available electronically through the Public Electronic Reading Room on the NRC’s

public Web site, at http://www.nrc.gov/reading-rm/doc-collections/reg-guides/. Single copies of regulatory guides may

also be obtained free of charge by writing the Reproduction and Distribution Services Section, ADM, USNRC,

Washington, DC 20555-0001, or by fax to (301)415-2289, or by email to DISTRIBUTION@nrc.gov. Active guides

may also be purchased from the National Technical Information Service (NTIS)on a standing order basis. Details on

this service may be obtained by contacting NTIS at 5285 Port Royal Road, Springfield, Virginia 22161, online at

http://www.ntis.gov, or by telephone at (703) 487-4650. Copies are also available for inspection or copying for a fee

from the NRC’s Public Document Room (PDR), which is located at 11555 Rockville Pike, Rockville, Maryland;

the PDR’s mailing address is USNRC PDR, Washington, DC 20555-0001. The PDR can also be reached by telephone

at (301) 415-4737 or (800) 397-4205, by fax at (301) 415-3548, and by email to PDR@nrc.gov.

RG 1.205, Page 18

NUREG-0800, “Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power

Plants,” Section 9.5.1, “Fire Protection Program,” U.S. Nuclear Regulatory Commission, Washington,

DC, October 2003.5

NUREG-1805, “Fire Dynamics Tools (FDTs) Quantitative Fire Hazard Analysis Methods for the U.S.

Nuclear Regulatory Commission Fire Protection Inspection Program,” U.S. Nuclear Regulatory

Commission, Washington, DC, December 2004.

NUREG-1824/EPRI 1011999, “Verification and Validation of Selected Fire Models for Nuclear Power

Plant Applications,” U.S. Nuclear Regulatory Commission, Washington, DC, December 2005

(Draft for Comment).

NUREG/CR-6850/EPRI 1011989, “EPRI/NRC-RES Fire PRA Methodology for Nuclear Power

Facilities,” Volume 1: Summary and Overview, Volume 2: Detailed Methodology, Office of Nuclear

Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC, September 2005.

Peacock, R.D., W.W. Jones, and G.P. Forney, “CFAST: Consolidated Model of Fire Growth and Smoke

Transport (Version 5), User’s Guide.,” NIST SP 1034, National Institute of Standards and Technology

(NIST), Gaithersburg, Maryland, December 2004 2004, available electronically through NIST’s public

Web site, at http://fire.nist.gov/bfrlpubs/fire04/PDF/f04091.pdf.

Regulatory Guide 1.106, “Thermal Overload Protection for Electric Motors on Motor-Operated

Valves,” U.S. Nuclear Regulatory Commission, Washington, DC, November 1975,” available in

ADAMS under Accession #ML003740323.6

Regulatory Guide 1.174, “An Approach for Using Probabilistic Risk Assessment in Risk-Informed

Decisions on Plant-Specific Changes to the Licensing Basis,” Revision 1, U.S. Nuclear Regulatory

Commission, Washington, DC, November 2002.
7 All Commission papers (SECYs) listed herein were published by the U.S. Nuclear Regulatory Commission, and are

available electronically through the Public Electronic Reading Room on the NRC’s public Web site,

at http://www.nrc.gov/reading-rm/doc-collections/commission/secys/. Copies are also available for inspection

or copying for a fee from the NRC’s Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR’s

mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209;

fax (301) 415-3548; email PDR@nrc.gov.

8 All NRC regulations listed herein are available electronically through the Public Electronic Reading Room on the

NRC’s public Web site, at http://www.nrc.gov/reading-rm/doc-collections/cfr/. Copies are also available for inspection

or copying for a fee from the NRC’s Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR’s

mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209;

fax (301) 415-3548; email PDR@nrc.gov.

RG 1.205, Page 19

Regulatory Guide 1.189, “Fire Protection for Operating Nuclear Power Plants,” U.S. Nuclear

Regulatory Commission, Washington, DC, April 2001.

Regulatory Guide 1.200, “An Approach for Determining the Technical Adequacy of Probabilistic Risk

Assessment Results for Risk-Informed Activities,” U.S. Nuclear Regulatory Commission, Washington,

DC, February 2004 (for trial use).

RIS 2005-30, “NRC Regulatory Issue Summary 2005-30: Clarification of Post-Fire Safe-Shutdown

Circuit Regulatory Requirements,” U.S. Nuclear Regulatory Commission, Washington, DC,

December 20, 2005, available electronically through the NRC’s public Web site,

at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2005/ri200530.pdf.

SECY-98-0058, “Development of a Risk-Informed, Performance-Based Regulation for Fire Protection

at Nuclear Power Plants,” U.S. Nuclear Regulatory Commission, Washington, DC, March 26, 1998.

7

SECY-00-0009, “Rulemaking Plan, Reactor Fire Protection Risk-Informed, Performance-Based

Rulemaking,” U.S. Nuclear Regulatory Commission, Washington, DC, January 13, 2000.

SECY-02-0132, “Proposed Rule: Revision of 10 CFR 50.48 to Permit Light-Water Reactors to

Voluntarily Adopt National Fire Protection Association (NFPA) Standard 805, ‘Performance-Based

Standard for Fire Protection for Light-Water Reactor Electric Generating Plants,’ 2001 Edition

(NFPA 805), as an Alternative Set of Risk-Informed, Performance-Based Fire Protection Requirements,”

U.S. Nuclear Regulatory Commission, Washington, DC, July 15, 2002.

SECY-04-0050, “Final Rule: Revision of 10 CFR 50.48 to Allow Performance-Based Approaches Using

National Fire Protection Association (NFPA) Standard 805 (NFPA 805), ‘Performance-Based Standard

for Fire Protection for Light-Water Reactor Electric Generating Plants,’ 2001 Edition,” U.S. Nuclear

Regulatory Commission, Washington, DC, March 29, 2004.

U.S. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of Production

and Utilization Facilities.”

8

U.S. Code of Federal Regulations, Title 10, Energy, Part 50, Appendix A, “General Design Criteria

for Nuclear Power Plants.”

U.S. Code of Federal Regulations, Title 10, Energy, Part 50, Appendix R, “Fire Protection Program

for Nuclear Power Facilities Operation Prior to January 1, 1979.”
9 All Federal Register notices listed herein were issued by the U.S. Nuclear Regulatory Commission, and are available

electronically through the Federal Register Main Page of the public GPOAccess Web site, which the U.S. Government

Printing Office maintains at http://www.gpoaccess.gov/fr/index.html. Copies are also available for inspection

or copying for a fee from the NRC’s Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR’s

mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209;

fax (301) 415-3548; email PDR@nrc.gov.

RG 1.205, Page 20

U.S. Code of Federal Regulations, Title 10, Section 50.48, “Fire Protection.”

U.S. Nuclear Regulatory Commission, “Voluntary Fire Protection Requirements for Light-Water

Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative,” Proposed Rule,

Federal Register, Vol. 67, No. 212, November 1, 2002, pp. 66578–66588.9

U.S. Nuclear Regulatory Commission, “Voluntary Fire Protection Requirement for Light-Water

Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative,” Final Rule,

Federal Register, Vol. 69, No. 115, June 16, 2004, pp. 33536–33551.

U.S. Nuclear Regulatory Commission, “NRC Enforcement Policy,” Policy Statement: Revision,

Federal Register, Vol. 69, No. 115, June 16, 2004, pp. 33684–33685.

U.S. Nuclear Regulatory Commission, “NRC Enforcement Policy; Extension of Enforcement

Discretion of Interim Policy,” Policy Statement: Revision, Federal Register, Vol. 70, No. 10,

January 14, 2005, pp. 2662–2664.

GLOSSARY

NFPA 805, Section 1.6, contains definitions applicable to terminology used in the standard. 

Regulatory Guide 1.189 also contains a substantial list of definitions of fire protection terminology

applicable to nuclear power generating stations. Where potential differences or conflicts exist between

definitions in NFPA 805 and other fire protection regulatory documents, and where these definitions

are important to the licensing basis, the licensee’s documentation should clearly identify the definition

that is being applied.