POLICY ISSUE 

INFORMATION 

November 2, 2009 SECY-09-0161

FOR: The Commissioners 

FROM: Eric J. Leeds, Director 

Office of Nuclear Reactor Regulation 

SUBJECT: CLOSING FIRE PROTECTION ISSUES—SEMIANNUAL UPDATE 

PURPOSE: 

To provide the Commission with the semiannual update on the U.S. Nuclear Regulatory 

Commission (NRC) staff’s plan for closing fire protection issues. 

BACKGROUND: 

In Staff Requirements Memorandum (SRM) M080717, “Briefing on Fire Protection Issues,” 

dated July 29, 2008, the Commission directed the staff to provide a fire protection closure plan, 

including milestones and deliverables. 

In response to SRM M080717, the staff prepared Commission paper SECY 08-0171, “Plan for 

Stabilizing Fire Protection Regulatory Infrastructure,” dated November 5, 2008. That 

stabilization plan delineated eight tasks with associated milestones and deliverables to complete 

the stabilization of the regulatory infrastructure for those nuclear plants transitioning to the risk 

informed and performance based fire protection regulations as well as those remaining under 

the traditional deterministic fire protection regulations. On May 22, 2009, the staff updated the 

Commission on milestones that had been completed in Commission paper SECY 09-0079, 

“Closing Fire Protection Issues—Semiannual Update.” This paper provides the second 

semiannual update of completed tasks in the stabilization plan. 

DISCUSSION: 

The NRC staff has now closed three of the eight tasks in the stabilization plan and has made 

substantial progress on the remaining tasks since the last update. 

CONTACT: Daniel M. Frumkin, NRR/DRA 

 (301) 415-2280 
The Commissioners - 2 - 

The three tasks that have been completed are Task 2 concerning electrical raceway fire 

barriers, Task 5 concerning regulatory effectiveness assessments, and Task 8 concerning 

evaluation of past fire protection issues. 

Below is a brief summary of the progress of the remaining tasks. The enclosure to this paper 

includes Revision 2 of the Plan for Stabilizing Fire Protection Regulatory Infrastructure reflecting 

the current status: 

• Task 1: Transition to Risk Informed and Performance Based Fire Protection 

Requirements. Sixteen of the twenty milestones and deliverables have been completed, 

and the task is expected to be closed by mid calendar year 2010. The noteworthy 

accomplishments that have occurred since the last update of the Commission include: 

3⁄4 The staff has collaborated closely with the industry to finalize a revision to the 

regulatory guide for 10 CFR 50.48(c) – National Fire Protection Association Standard 

805 (NFPA 805) transition and the companion revision to the standard review plan. 

Both documents are expected to be published late this year or early next year. 

3⁄4 The staff implemented more effective and timely resolution of NFPA 805 

implementation challenges utilizing the frequently asked questions process. 

• Task 3: Fire-Induced Circuit Failures. Fifteen of the nineteen milestones and 

deliverables have been completed, and the task is expected to be closed by mid 

calendar year 2010. One noteworthy accomplishment that has occurred since the last 

update of the Commission is: 

3⁄4 The staff has collaborated closely with the industry to finalize a revision to Regulatory 

Guide 1.189, Fire Protection for Nuclear Power Plants. That guide includes 

guidance for analyzing and addressing fire-induced circuit failures. The guide was 

published in November 2009. 

• Task 4: Operator Manual Actions. Six of the nine milestones and deliverables have 

been completed, and the task is expected to be closed by mid calendar year 2010. The 

staff adjusted priorities for completing the remaining interim milestones for this task 

based on higher priority work associated with Task 1. 

• Task 6: Lessons Learned Training. One of the five milestones and deliverables has 

been completed, and the task is expected to be closed by mid calendar year 2010. One 

noteworthy accomplishment that has occurred since the last update of the Commission 

is: 

3⁄4 The method for evaluating lessons learned has been developed and will be used in 

the development of lessons and training. 
The Commissioners - 3 - 

• Task 7: Exemption Database. One of the three milestones and deliverables has been 

completed, and the task is expected to be closed by early calendar year 2010. One 

noteworthy accomplishment that has occurred since the last update of the Commission 

is: 

3⁄4 All fire protection exemptions have been added to the Agencywide Documents 

Access and Management System facilitating development of a user friendly 

database of exemptions. 

The enclosure to this paper provides the revised stabilization plan with changes since 

publication of the updated plan on May 20, 2009. 

COORDINATION: 

The Office of the General Counsel has reviewed this paper and has no legal objections. 

 /RA/ (John A. Grobe for) 

Eric J. Leeds, Director 

Office of Nuclear Reactor Regulation 

Enclosure: 

Plan for Stabilizing Fire Protection 

 Regulatory Infrastructure, Revision 2 
The Commissioners - 3 - 

• Task 7: Exemption Database. One of the three milestones and deliverables has been 

completed, and the task is expected to be closed by early calendar year 2010. One 

noteworthy accomplishment that has occurred since the last update of the Commission 

is: 

3⁄4 All fire protection exemptions have been added to the Agencywide Documents 

Access and Management System facilitating development of a user friendly 

database of exemptions. 

The enclosure to this paper provides the revised stabilization plan with changes since 

publication of the updated plan on May 20, 2009. 

COORDINATION: 

The Office of the General Counsel has reviewed this paper and has no legal objections. 

 /RA/ (John A. Grobe for) 

Eric J. Leeds, Director 

Office of Nuclear Reactor Regulation 

Enclosure: 

Plan for Stabilizing Fire Protection 

 Regulatory Infrastructure, Revision 2 

ADAMS Accession No.: ML092750183 *via email 

OFFICE NRR/DRA/AFPB NRR/DRA/AFPB Tech Editor* NRR/DRA RES* 

NAME DFrumkin AKlein(DFrumkin for) KKribbs MCunningham CLui 

DATE 10/22/2009 10/22/2009 10/21/2009 10/22/2009 10/30/2009 

OFFICE OE* OGC - NLO NRR 

NAME NHilton 

(GGulla for) BJones ELeeds (JGrobe for) 

DATE 10/30/2009 10/31/2009 11/02/2009 

OFFICIAL RECORD COPY
Enclosure

PLAN FOR STABILIZING FIRE PROTECTION 

REGULATORY INFRASTRUCTURE

Revision 2 

(Changes since May 20, 2009, are highlighted in blue.) 
ACRONYMS

1Q first quarter 

2Q second quarter 

4Q fourth quarter 

CY calendar year 

CFR Code of Federal Regulations 

EGM enforcement guidance memorandum 

EPRI Electric Power Research Institute 

ERFBS electrical raceway fire barrier system 

GAO U.S. Government Accountability Office 

GL generic letter 

IN information notice 

LAR license amendment request 

NEI Nuclear Energy Institute 

NFPA National Fire Protection Association 

NRC U.S. Nuclear Regulatory Commission 

NUREG NRC technical report designation 

NUREG/CR NUREG contractor report 

OMA operator manual action 

RG regulatory guide 

RIS regulatory issue summary 

PRA probabilistic risk assessment 

SER safety evaluation report 

SRM staff requirements memorandum 
3 

Task 1 Stabilize the Regulatory Infrastructure Supporting the Transition to 

 Risk-Informed and Performance-Based Fire Protection Regulation—

10 CFR 50.48(c) and National Fire Protection Association Standard 805, 

“Performance-Based Standard for Fire Protection for Light-Water Reactor 

Electric Generating Plants, 2001 Edition” (NFPA 805) 

Objective To develop and validate the regulatory processes that facilitate the predictable, 

efficient, and effective transition of operating nuclear power plants to 

U.S. Nuclear Regulatory Commission (NRC) risk-informed and performancebased fire protection requirements.

Definition of Closure is achieved when the regulatory infrastructure is in place and 

Closure the NRC issues the safety evaluation reports (SERs) of the NFPA 805 pilot 

plants. Review and approval of subsequent license amendment requests (LARs) 

is considered a routine staff activity. 

Background The Commission approved the final rule incorporating the 2001 revision of the 

national consensus standard NFPA 805 into Title 10 of the Code of Federal 

Regulations (10 CFR) 50.48(c) by reference via a staff requirements 

memorandum (SRM) on May 11, 2004. The rule was published on 

June 16, 2004, and became effective July 16, 2004. The Commission provided 

certain enforcement discretion as an incentive for licensees to adopt NFPA 805. 

Two licensees, Progress Energy and Duke Energy, volunteered the Shearon 

Harris Nuclear Generating Plant (Shearon Harris) and Oconee Nuclear Station 

(Oconee), respectively, to become pilot plants for the transition to NFPA 805. 

 

The NRC has prepared guidance for licensees adopting NFPA 805 in Regulatory 

Guide (RG) 1.205, “Risk-Informed, Performance-Based Fire Protection for 

Existing Light-Water Nuclear Power Plants,” issued May 2006. Also, the staff 

endorsed the industry proposal to establish a frequently asked question program 

to promptly clarify issues emerging at plants in transition to NFPA 805. The staff 

holds monthly public meetings with the industry to discuss emerging issues. 

As of today, operators of 51 reactor units have sent letters of intent indicating 

their commitment to transition to NFPA 805, and licensees for 50 of those units 

have initiated their transition. 

STEPS TO CLOSURE DUE CALENDAR YEAR (CY) 

QUARTER

Establish Regulatory Foundation 

NFPA 805 issued Complete: January 2001

The NRC promulgates 10 CFR 50.48(c) Complete: June 2004 
4 

Structure for Enforcement

New enforcement policy for NFPA 805 under 

10 CFR 50.48, “Fire Protection,” provides a 2-year 

enforcement discretion period 

Complete: June 2004 

The staff revises the NFPA 805 enforcement policy 

to address licensee budgetary cycles to the end of 

2005 for existing noncompliances 

Complete: January 2005 

The staff revises the NFPA 805 enforcement policy 

to provide a 3-year enforcement discretion period 

Complete: April 2006 

The Commission approves revised enforcement 

discretion policy, allowing discretion to extend 

6 months past the issuance of the second pilot 

plant’s SER 

Complete: September 2008 

Develop Implementation Guidance

The NRC and Electric Power Research Institute 

(EPRI) jointly issue NUREG/CR-6850, “EPRI/NRCRES Fire PRA Methodology for Nuclear Power 

Facilities” 

Complete: September 2005 

The Nuclear Energy Institute (NEI) issues industry 

implementation guidance NEI 04-02, “Guidance for 

Implementing a Risk-Informed, Performance-Based 

Fire Protection Program under 10CFR50.48(c),” 

Revision 1 

Complete: September 2005 

The staff issues RG 1.205 as guidance for plants 

adopting NFPA 805 

Complete: May 2006 

The staff issues draft Section 9.5.1.2, “RiskInformed, Performance-Based Fire Protection 

Program,” of Chapter 9, “Auxiliary Systems,” of 

NUREG-0800, “Standard Review Plan for the 

Review of Safety Analysis Reports,” for public 

comment 

Complete: March 2009 

The staff completes the triennial procedure for pilot 

testing 

Complete: March 2009 

The staff issues draft RG 1.205 for public comment Complete: April 2009 

The staff clarifies NUREG/CR-6850 to include the 

current issues identified through the frequently 

asked questions 

2009 4Q

The staff issues a revised RG 1.205 and the 

Standard Review Plan for NFPA 805 

2009 4Q 
5 

Validate Implementation

Duke Energy sends the first letter of intent 

(Oconee) 

Complete: February 2005 

Progress Energy sends the second letter of intent 

(Shearon Harris) 

Complete: June 2005 

The NRC receives the pilot plant LAR for Shearon 

Harris 

Complete: May 2008 

The NRC reviews the pilot plant SER for Oconee Complete: June 2008 

Final Closure

The staff issues the pilot plant SER (Shearon 

Harris) 

2010 1Q

The staff issues the pilot plant SER (Oconee) 2010 2Q 
6 

Task 2 Close Out Hemyc and MT Electrical Raceway Fire Barrier System (ERFBS) 

Issues for Plants Transitioning to NFPA 805

Objective To evaluate and document the actions taken to address ERFBS questions, 

including the specific actions taken to address issues related to Hemyc.

Definition of The safety issue has been closed. This task remains open until the 

Closure staff issues a report documenting the closeout of Hemyc and MT barrier issues. 

Background To meet fire protection regulations, licensees often installed an ERFBS to 

achieve the required separation of redundant trains of cables and equipment 

located in the same room or fire area. The NRC found that two of these systems 

may be nonconforming and issued Generic Letter (GL) 2006-03, “Potentially 

Nonconforming Hemyc and MT Fire Barrier Configurations,” dated April 10, 2006. 

GL 2006-03 asked licensees to describe how Hemyc, MT, and other fire barrier 

materials are capable of providing the appropriate fire resistance rating. By the 

end of CY 2007, the NRC had accepted all responses to GL 2006-03 and had 

approved all the licensing actions to address Hemyc issues of non-NFPA 805 

plants. 

 

On December 17, 2008, the NRC staff issued a memorandum describing the 

status of all plants that rely on Hemyc ERFBS. All plants have either resolved 

their Hemyc issues or are in transition to 10 CFR 50.48(c) and NFPA 805.

 

STEPS TO CLOSURE DUE CY QUARTER

Establish Regulatory Foundation

The staff promulgates Section III.G, “Fire Protection of 

Safe Shutdown Capability,” of Appendix R, “Fire 

Protection Program for Nuclear Power Facilities 

Operating Prior to January 1, 1979,” to 

10 CFR Part 50, “Domestic Licensing of Production 

and Utilization Facilities” 

Complete: January 1980

Structure for Enforcement 

No enforcement discretion for barrier issues Not applicable 

Develop Implementation Guidance 

The staff issues Information Notice (IN) 2005-07, 

“Results of HEMYC Electrical Raceway Fire Barrier 

System Full Scale Fire Testing”

Complete: April 2005

The staff issues GL 2006-03 Complete: April 2006
7 

Validate Implementation 

The staff responds to all GL 2006-03 information 

requests

Complete: December 2007

The staff confirms closure via inspections related 

to GL 2006-03 (Hemyc and MT)

Complete: December 2008

Final Closure 

The staff issues final closeout documentation Complete: December 2008
8 

Task 3 Stabilize Regulatory Infrastructure To Resolve Fire-Induced Circuit Failure 

Issue

Objective To implement a predictable, efficient, and effective process to ensure that 

licensees complete specific actions related to possible fire-induced circuit 

failures.

Definition of Closure is achieved when the regulatory infrastructure is in place and the staff

Closure completes the validation of an application of the circuit resolution methodology. 

Review and approval of the subsequent use of the circuit failure resolution 

methodology by individual licensees is considered a routine staff activity.

Background To meet fire protection regulations, nuclear power plants must be able to 

demonstrate that they can be safely shut down in the event of a fire. An 

important requirement of these rules was the protection of redundant equipment 

and cables required to place the plant in a safe-shutdown state. This included a 

requirement to protect circuits such that plant equipment does not fail or 

malfunction.

Beginning in 1997, a series of licensee event reports identified plant-specific 

problems related to potential fire-induced electrical circuit failures that could 

affect equipment necessary to achieve and maintain safe shutdown. The NRC 

staff issued IN 99-17, “Problems Associated with Post-Fire Safe-Shutdown 

Circuit Analyses,” on June 3, 1999, to document additional problems.

In 2001, EPRI and NEI performed a series of cable functionality fire tests to 

enhance the nuclear industry’s understanding of fire-induced circuit failures, 

particularly spurious equipment actuations initiated by circuit failures. Based on 

the test results and continued interactions with industry, the NRC staff concluded 

that regulatory expectations needed to be clarified to ensure safety; to provide 

clear regulatory expectations in the area of fire-induced circuit failures; and 

where appropriate, to make plant changes to mitigate such failures. 

STEPS TO CLOSURE DUE CY QUARTER

Establish Regulatory Foundation 

S. Collins (NRC) issues a letter to R. Beedle (NEI) on 

spurious actuations

Complete: March 1997

Structure for Enforcement 

The staff issues Enforcement Guidance Memorandum 

(EGM) 98-002, “Disposition of Violations of 

Appendix R, Sections III.G and III.L, Regarding Circuit 

Failures”

Complete: March 1998

The staff issues an updated EGM, including 

Commission direction for fire-induced circuit failures 

Complete: May 2009
9 

Develop Implementation Guidance 

EPRI and NEI complete circuit failure testing at

Omega Point Laboratories, Inc., Elmendorf, TX 

Complete: June 2001

The staff and industry publish (through EPRI) Report 

No. 1006961, “Spurious Actuation of Electrical 

Circuits Due to Cable Fires: Results of an Expert 

Elicitation”

Complete: May 2002

The staff issues Regulatory Issue Summary (RIS) 

2004-03, “Risk-Informed Approach for Post-Fire SafeShutdown Associated Circuit Inspections,” Revision 1 

Complete: December 2004

Industry publishes NEI 00-01, “Guidance for Post-Fire 

Safe-Shutdown Circuit Analysis,” Revision 1

Complete: January 2005 

The staff issues RIS 2005-30, “Clarification of PostFire Safe-Shutdown Circuit Regulatory Requirements” Complete: December 2005

The commission issues SRM SECY-2006-0196, 

“Issuance of Generic Letter 2006-xx, ‘Post-Fire SafeShutdown Circuits Analysis Spurious Actuations’” 

Complete: December 2006

The staff completes additional testing for RIS 2004-

03, “Risk-Informed Approach for Post-Fire SafeShutdown Circuit Inspections,” Revision 1, dated 

December 29, 2004, and issues NUREG/CR-6931, 

“Cable Response to Live Fire (CAROLFIRE),” 

Volume 1, “Test Descriptions and Analysis of Circuit 

Response Data”; Volume 2, “Cable Fire Response 

Data for Fire Model Improvement”; and Volume 3, 

“Thermally-Induced Electrical Failure (THIEF) Model”

Complete: April 2008

The staff transmits SECY-2008-0093, “Resolution of 

Issues Related to Fire-Induced Circuit Failures,” to the 

Commission for action

Complete: June 2008

The staff issues a draft of RG 1.189, “Fire Protection 

for Nuclear Power Plants,” for comment

Complete: April 2009

The staff publishes the RIS and attached draft RG 

clarification of circuit expectations

Determined not needed

Industry revises NEI 00-01, Revision 2 Complete: June 2009

The NRC issues the final RG for fire-induced circuit 

failures 

2009 4Q
10 

Validate Implementation 

The staff establishes a method to validate the 

disposition of circuit issues 

2009 4Q

The staff informs the Commission of the status of 

circuit closure

Complete: August 2009

Licensees begin work to resolve circuit issues 2009 4Q

Final Closure

The staff completes the validation of the circuit issue 

disposition method 

2010 2Q
11 

Task 4 Stabilize Regulatory Infrastructure To Resolve Postfire Operator 

 Manual Action (OMAs) Issues

Objective To ensure that licensees complete appropriate actions related to the 

inappropriate crediting of postfire OMAs.

Definition Closure is achieved when the regulatory infrastructure is in place and when the 

of Closure licensees submit LARs or exemption requests or when they complete 

modifications that validate the effectiveness of the infrastructure. Review and 

approval of those applications is considered a routine staff activity.

Background To meet fire protection regulations, licensees of nuclear power plants must 

demonstrate that the plant can be safely shut down in the event of a fire. An 

important requirement of these rules was the protection of redundant equipment 

and cables required to place the plant in a safe-shutdown state. In areas where 

redundant equipment could not be separated, the NRC permitted licensees, 

under certain conditions, to use postfire OMAs to mitigate the effects of the fire.

In 2000, NRC inspections found that some licensees relied on OMAs under 

conditions that were not permitted by the NRC to compensate for the lack of 

approved separation. On June 30, 2006, the NRC issued RIS 2006-10, 

“Regulatory Expectations with Appendix R, Paragraph III.G.2, Operator Manual 

Actions,” dated June 30, 2006, to clarify expectations.

 

With the intention of giving licensees an opportunity to find and correct 

unapproved postfire OMAs, the NRC issued enforcement discretion for licenseeidentified unapproved postfire OMAs. This discretion provided a period of time 

for licensees to self-identify unapproved postfire OMAs and also allowed them 

time to bring those unapproved postfire OMAs into compliance without the NRC’s 

taking enforcement action. The NRC expects the unapproved postfire OMAs to 

be resolved through reanalysis, procedure changes, or modifications or by 

requesting approval from the NRC. Facilities in transition to NFPA 805 will 

address OMAs as part of the transition.

 

In October 2007, the NRC issued NUREG-1852, “Demonstrating the Feasibility 

and Reliability of Operator Manual Actions in Response to Fire,” to assist NRC 

staff in reviewing postfire OMA applications under conditions permitted by the 

NRC. NUREG-1852 is publicly available to allow licensees to examine the 

factors that the NRC staff will review.

The enforcement discretion for manual actions related to single spurious 

actuations described in Enforcement Guidance Memorandum 07-004, ended on 

March 6, 2009, for plants that did not have exemptions or had not submitted 

license amendments to the NRC for review. 
12 

STEPS TO CLOSURE DUE CY QUARTER

Establish Regulatory Foundation 

The Commission issues SRM SECY-04-0233, 

“Proposed Rulemaking—Post-Fire Operator Manual 

Actions,” dated December 23, 2004

Complete: January 2005

The staff issues “Fire Protection Program—Post-Fire 

Operator Manual Actions,” Federal Register (FR) 

notice (71 FR 11169; March 1, 2005); the proposed 

rule is withdrawn 

Complete: March 2005

Structure for Enforcement 

The staff issues enforcement discretion for OMAs as 

part of EGM 2007-004 for OMAs; enforcement 

discretion ends March 2009 

Complete: June 2007

Develop Implementation Guidance 

The staff publishes RIS 2006-10 Complete: June 2006 

The staff publishes NUREG-1852 Complete: October 2007

Validate Implementation 

Licensees complete corrective actions, LARs, or 

requests for exemptions 

Complete: March 2009

The staff develops a plan to validate the effectiveness

of the closure of OMA issues for utilities that are not 

transitioning to NFPA 805 and that do not have an 

active licensing action

2009 4Q

The staff validates the effectiveness of the 

infrastructure by completing a review of one licensee’s 

resolution of the issue 

2010 2Q

Final Closure 

Infrastructure stabilized and validated 2010 2Q
13 

Task 5 Assess Regulatory Effectiveness

Objective To assess the effectiveness of the ongoing improvements to the fire protection 

regulatory framework.

Definition Closure is achieved when a monitoring process is in place and the baseline is 

of Closure established. Ongoing implementation of the process is considered a routine staff 

activity.

Background On July 29, 2008, the Commission directed the staff in SRM M080717, “Briefing 

on Fire Protection Issues,” to provide it with a plan to assess the effectiveness of 

the ongoing improvements to the fire protection regulatory framework, using 

recent plant data to establish a baseline. Such a baseline could be, for example, 

the number and general types of all open fire protection deficiencies that were 

compensated and the manner of compensation used in 2007.

 

The U.S. Government Accountability Office (GAO), in GAO 08-747, “Nuclear 

Safety: NRC’s Oversight of Fire Protection at U.S. Commercial Nuclear Reactor 

Units Could Be Strengthened,” issued June 2008, included a recommendation to 

“develop a central database for tracking the status of exemptions, compensatory 

measures, and manual actions in place nationwide and at individual commercial 

nuclear units.” 

 

The NRC Chairman responded to GAO 08-747 in a letter to Congress dated 

September 11, 2008. The letter committed to “implement a Fire Protection 

Closure Plan to resolve the issues contributing to the long-term use of 

compensatory measures. The Commission has directed the staff to include 

meaningful metrics to gauge progress in implementation of the Closure Plan.” 

This action will resolve the issues of long-term compensatory measures and 

unapproved manual actions that have associated compensatory measures. 

STEPS TO CLOSURE DUE CY QUARTER

Commission Commitments 

The staff determines the metric for 

measuring the effectiveness of ongoing 

improvements

Complete: December 2008

The staff develops a metric monitoring 

methodology 

Complete: March 2009

Final Closure

The staff collects information and 

establishes monitoring 

Complete: November 2009
14 

Task 6 Develop Training on Historical Lessons Learned from Fire 

 Protection

Objective To train appropriate staff on the important historical lessons learned from the fire 

protection issue resolution activities since the establishment of Appendix R to 

10 CFR Part 50.

Definition Closure is achieved when a lessons-learned review is completed, lessons are 

of Closure incorporated into a knowledge management or training program, and the 

adequacy of that program is validated using a pilot application. Ongoing staff 

awareness and training are considered part of routine staff activity.

Background On July 29, 2008, the Commission directed the staff in SRM M080717 to provide 

it with a closure plan that includes training for appropriate staff on the important 

historical lessons learned from the fire protection issue resolution activities since 

the establishment of Appendix R to 10 CFR Part 50. 

STEPS TO CLOSURE DUE CY QUARTER

Perform Lessons Learned Evaluation

The staff compiles history Complete: March 2009

The staff develops lessons learned 2009 4Q

Develop Knowledge Management/Training Tool

The staff develops training on lessons learned 2010 1Q

The staff conducts pilot training on fire protection 

lessons learned

2010 1Q 

Final Closure

The staff incorporates lessons learned from pilot 

training

2010 2Q 
15 

Task 7 Develop an Exemption Database

Objective To develop a centralized database of fire protection exemptions for operating 

nuclear reactors.

Definition Closure is achieved when the exemption database is established and procedures

of Closure and plans are in place for the periodic updating of that database. Periodic

updates to the database are considered a routine staff activity.

Background GAO 08-747 included a recommendation to “develop a central database for 

tracking the status of exemptions.” 

 

The NRC Chairman responded to GAO 08-747 in a letter to Congress dated 

September 11, 2008, which contained a commitment to “develop a centralized 

database of fire protection exemptions for operating nuclear reactors.” 

STEPS TO CLOSURE DUE CY QUARTER

Commission Commitments

The staff collects data on fire protection exemptions Complete: June 2009

The staff completes development of the database 2009 4Q

Final Closure

The staff establishes procedures for updates 2010 1Q 
16 

Task 8 Establish Reasonable Assurance that All Past Regulatory Infrastructure 

 Instabilities Are Identified

Objective To identify any additional fire protection issues that require further action.

Definition Closure is achieved when the review is complete and appropriate actions are 

of Closure taken to address any fire protection regulatory issues identified. Addressing any

additional issues identified is considered a routine staff activity.

Background Since the publication of the fire protection rule in 1981, the NRC has identified 

and addressed many issues by using regulatory practices that were deemed 

appropriate at the time these issues were identified. 

 

The NRC staff has initiated an effort to identify any outstanding fire protection 

issues by surveying cognizant NRC staff concerning the regulatory history of fire 

protection. The identification of additional issues will give the staff a more 

complete understanding of the issues and confidence that the agency is 

addressing all the necessary issues. The staff’s activities for this effort include 

methodically surveying past and present NRC staff with knowledge of fire 

protection issues, evaluating their responses, and recommending followup 

actions. 

STEPS TO CLOSURE DUE CY QUARTER

Commission Commitments

The staff completes review Complete: April 2009

The staff evaluates responses Complete: July 2009

Final Closure

The staff identifies issues and develops 

recommendations

Complete: July 2009