POLICY ISSUE 

INFORMATION 

 

May 13, 2011 SECY-11-0063

FOR: The Commissioners 

FROM: R. W. Borchardt 

Executive Director for Operations 

SUBJECT: CLOSING FIRE PROTECTION ISSUES—SEMIANNUAL 

UPDATE— MAY 2011 

PURPOSE: 

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

Commission (NRC) staff’s progress in 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 the 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 necessary 

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

to the risk-informed, performance-based fire protection regulations and those remaining under 

the traditional deterministic fire protection regulations. On May 22, 2009 (SECY-09-0079, 

“Closing Fire Protection Issues—Semiannual Update”); November 2, 2009 (SECY-09-0161 

(same title as SECY-09-0079)), May 14, 2010 (SECY-10-0060 (same title as SECY-09-0079)), 

and November 12, 2010 (SECY-10-0150 (same title as SECY-09-0079)), the staff updated the 

Commission on milestones that it had completed. This paper provides the fifth semiannual 

update of the stabilization plan, and documents completion of the remaining two tasks. 

CONTACT: Daniel M. Frumkin, NRR/DRA 

 (301) 415-2280 
The Commissioners - 2 - 

DISCUSSION: 

The NRC staff has now closed all eight of the tasks in the stabilization plan. Specifically, since 

the NRC staff updated the stabilization plan on November 12, 2010, it has issued the Oconee 

Nuclear Station safety evaluation report for the adoption of Title 10 of the Code of Federal 

Regulations (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), and has completed work related to the fire protection lessons 

learned. 

As noted above, the staff completed Task 1 by issuing the Oconee safety evaluation report on 

December 29, 2010. The NRC staff is continuing to track the completion of NFPA 805 

implementation actions at Oconee. Another NFPA 805 pilot plant, Shearon Harris Nuclear 

Power Plant, reported completing its implementation in a letter to the NRC dated 

January 19, 2011. The NRC is also working with industry stakeholders to create a stable 

regulatory framework for submittal and review of the nonpilot NFPA 805 licensee applications. 

For Task 6, on April 27, 2011, the staff issued a memorandum summarizing the lessons 

learned. The staff has also developed training to support communicating the lessons learned 

and the staff provided the first lessons learned training session to NRC staff on May 5, 2011. 

The staff is considering the topic of fire protection lessons learned as part of ongoing NRC 

knowledge management activities. This completes Task 6 of the stabilization plan. 

CONCLUSION: 

The enclosure to this paper provides the revised and completed stabilization plan, with changes 

made since the publication of the updated plan on November 12, 2010. Since the staff has 

completed all of the items described in the enclosure, this will be the last update to the plan. 

This completes staff actions in response to the SRM. Normal agency feedback processes, such 

as the Reactor Oversight Process, will help to ensure that the fire protection program 

infrastructure remains stable. 

By memorandum dated October 19, 2008, then-Executive Director for Operations Luis A. Reyes 

formed the Fire Protection Steering Committee to facilitate resolution of key technical and 

regulatory issues related to fire protection and to interface with industry stakeholders on those 

issues. Specifically, the committee charter called for the group to facilitate the predictable and 

efficient implementation of NFPA 805 and the clear and timely resolution of emerging fire 

protection issues, including operator manual actions and multiple spurious operations from 

fire-induced cable faults. With the completion of this plan as documented in the enclosure, the 

Fire Protection Steering Committee is hereby retired. 
The Commissioners - 3 - 

COORDINATION: 

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

 /RA/ 

R. W. Borchardt 

Executive Director 

 for Operations 

Enclosure: 

Plan for Stabilizing Fire Protection 

 Regulatory Infrastructure, Revision 5 
The Commissioners - 3 - 

COORDINATION: 

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

 /RA/ 

R. W. Borchardt 

Executive Director 

 for Operations 

Enclosure: 

Plan for Stabilizing Fire Protection 

 Regulatory Infrastructure, Revision 5 

WITS 200900239/EDATS: SECY-2010-0365 

ADAMS Accession No.: ML110750544 *via email

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

NAME DFrumkin AKlein KAzariah-Kribbs MCheok (SLee for) RCorreia 

DATE 04/27/11 04/27/11 04/18/11 04/28/11 05/03/11 

OFFICE OE OGC NRR EDO 

NAME NHilton(GGulla for) EWilliamson ELeeds 

(BBoger for) RBorchardt 

DATE 04/29/11 05/04/11 05/06/11 05/13/11 

OFFICIAL RECORD COPY 
Enclosure

PLAN FOR STABILIZING FIRE PROTECTION 

REGULATORY INFRASTRUCTURE

Revision 5 

(Schedule changes since November 10, 2010, the last update provided to 

the Commission, are highlighted in blue.) 

 
 

ACRONYMS

CFR Code of Federal Regulations 

CY calendar year 

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 
2 

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 the 

 U.S. Nuclear Regulatory Commission (NRC) risk-informed and 

 performance-based fire protection requirements.

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

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

plants. The NRC considers the review and approval of subsequent license 

amendment requests (LARs) to be routine staff activities. 

Status The staff completed this task in the fourth quarter of calendar year (CY) 2010. 

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

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

Regulations (10 CFR) 50.48(c) by reference through Staff Requirements 

Memorandum (SRM)-SECY-04-0233, “Proposed Rulemaking—Post-Fire 

Operator Manual Actions,” dated May 11, 2004. The NRC published the rule on 

June 16, 2004, and it became effective on 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 Power Plant (Shearon Harris) and Oconee Nuclear 

Station (Oconee), respectively, to become pilot plants for the transition to 

NFPA 805. 

 

The NRC issued regulatory 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,” in May 2006. The 

NRC revised this guidance to incorporate lessons learned from its license 

amendment reviews for the pilot plants and issued Revision 2 in December 2009. 

Also, the staff endorsed the industry proposal to establish a frequently asked 

questions 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. However, Monticello Nuclear 

Generating Plant and Nine Mile Point Nuclear Station Unit 2 have since 

withdrawn their intent to adopt NFPA 805, thus reducing the number of plants 

that are adopting NFPA 805 from 51 to 49. 

 
3 

STEPS TO CLOSURE DUE CY QUARTER

Establish Regulatory Foundation 

NFPA 805 is issued. Complete: January 2001

The NRC issues 10 CFR 50.48(c). Complete: June 2004 

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 the revised 

enforcement discretion policy, thus 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 the Electric Power Research Institute 

(EPRI) jointly issue NUREG/CR-6850, 

“EPRI/NRC-RES 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 10 CFR 50.48(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 a draft of 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 Nuclear 

Power Plants: LWR Edition,” 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 
4 

The staff clarifies NUREG/CR-6850 to include the 

current issues identified through the frequently 

asked questions program. 

Complete: December 2009 

The staff issues a revised RG 1.205 and the 

standard review plan for NFPA 805 

implementation. 

Complete: December 2009 

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).

Complete: June 2010

The staff issues the pilot plant SER (Oconee). Complete: December 2010 
5 

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 Closure is achieved when the staff issues a report documenting the closeout

Closure of Hemyc and MT barrier issues. 

Status The staff completed this task in May 2010. 

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. 

Task 2 has been closed based on the issuance of the December 17, 2008, 

memorandum that documents the closeout of Hemyc and MT fire barrier issues. 

Following the completion of this task, in May 2010, the NRC staff finalized 

NUREG-1924, “Electric Raceway Fire Barrier Systems in U.S. Nuclear Power 

Plants,” to document the history and to provide an overview of the use of 

electrical raceway fire barriers at U.S. nuclear power plants. 

 
6 

STEPS TO CLOSURE DUE CY QUARTER

Establish Regulatory Foundation

The staff issues 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 exists 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

Validate Implementation 

The staff responds to all GL 2006-03 information 

requests.

Complete: December 2007

The staff confirms closure through inspections related 

to GL 2006-03 (Hemyc and MT).

Complete: December 2008

Final Closure 

The staff issues final closeout documentation. Complete: December 2008
7 

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 when the 

Closure staff completes the validation of an application of the circuit resolution 

methodology. The NRC considers the review and approval of the subsequent 

use of the circuit failure resolution methodology by individual licensees to be 

routine staff activities. 

Status The staff completed this task in October 2010. 

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. These rules 

include an important requirement to protect redundant equipment and cables 

necessary to place the plant in a safe-shutdown state and 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 require clarification 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. 

The completion of Task 3 involved the validation of the implementing guidance 

for fire-induced circuit failures described in RG 1.189, “Fire Protection for Nuclear 

Power Plants,” Revision 2, issued October 2009. RG 1.189 endorses portions of 

the implementing guidance in NEI 00-01, “Guidance for Post-Fire Safe Shutdown 

Circuit Analysis,” Revision 2, issued January 2005, for fire-induced circuit 

failures. The NRC staff validated the guidance with inspections at Millstone 

Power Station and Vogtle Electric Generating Plant. Based on the results of 

those inspections, the staff is confident that the guidance is sufficient for 

licensees to implement. As with any complex technical issue, the staff expects to 

receive implementation issues from licensees and to disposition these issues. 

The disposition of implementing issues does not affect the NRC staff’s 

conclusion that it has stabilized the regulatory framework. 
8 

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

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) 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 

Safe-Shutdown Circuit Inspections,” Revision 1. 

Complete: December 2004

Industry publishes NEI 00-01. Complete: January 2005

The staff issues RIS 2005-30, “Clarification of 

Post-Fire Safe-Shutdown Circuit Regulatory 

Requirements.” 

Complete: December 2005

The commission issues SRM-SECY-2006-0196, 

“Issuance of Generic Letter 2006-xx, ‘Post-Fire 

Safe-Shutdown Circuits Analysis Spurious 

Actuations.’” 

Complete: December 2006

The staff completes additional testing for RIS 2004-03 

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 for comment. Complete: April 2009
9 

The staff publishes the RIS and attached draft RG 

clarification of circuit expectations.

Determined not to be needed 

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

The NRC issues the Revision 2 of RG 1.189 for 

fire-induced circuit failures. 

Complete: November 2009 

Validate Implementation 

The staff establishes a method to validate the 

disposition of circuit issues. 

Complete: December 2009 

The staff informs the Commission of the status of 

circuit closure.

Complete: August 2009 

Licensees begin work to resolve circuit issues. Complete: December 2009 

Final Closure

The staff completes the validation of the circuit issue 

disposition method. 

Complete: October 2010 
10 

Task 4 Stabilize Regulatory Infrastructure to Resolve Postfire Operator 

 Manual Action (OMA) 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. The NRC 

considers the review and approval of those applications to be routine staff 

activities. 

Status The staff completed this task in October 2010. 

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 provision 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.

 

The NRC issued enforcement discretion for licensee-identified unapproved 

postfire OMAs with the intention of giving licensees an opportunity to find and 

correct 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 taking 

enforcement action. The NRC expects licensees to resolve the unapproved 

postfire OMAs through reanalysis, procedure changes or modifications, or 

through a request for NRC approval. 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 the 

NRC staff in reviewing postfire OMA applications under conditions permitted by 

the agency. 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 EGM 07-004, “Enforcement Discretion for Post-Fire 

Manual Actions Used as Compensatory Measures for Fire-Induced Circuit 

Failures,” dated June 30, 2007, ended on March 6, 2009, for plants that did not 

have exemptions or had not submitted license amendments to the NRC for 

review. 
11 

The staff reviewed the completion of Task 4 as part of the inspections at 

Millstone and Vogtle. The inspections concluded that the NRC had stabilized the 

regulatory framework in a manner that provided licensees with sufficient 

information to properly disposition the use of postfire OMAs at their stations.

STEPS TO CLOSURE DUE CY QUARTER

Establish Regulatory Foundation 

The Commission issues SRM-SECY-04-0233. Complete: December 2004

The staff issues “Fire Protection Program—Post-Fire 

Operator Manual Actions,” in the Federal Register

(FR) (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 07-004 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.

Complete: December 2009

The staff validates the effectiveness of the 

infrastructure by completing a review of one licensee’s 

resolution of the issue. 

Complete: October 2010 

Final Closure 

The infrastructure is stabilized and validated. Complete: October 2010 
12 

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 when the baseline 

Of Closure is established. The NRC considers the ongoing implementation of the process to 

be a routine staff activity. 

Status The staff completed this task in the fourth quarter of CY 2009. 

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.

 

U.S. Government Accountability Office (GAO) 08-747, “Nuclear Safety: NRC’s 

Oversight of Fire Protection at U.S. Commercial Nuclear Reactor Units Could Be 

Strengthened,” issued June 2008, includes 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. 

The NRC staff considers this an ongoing activity and will continue to assess the 

effectiveness of the fire protection framework through monitoring until such time 

as the staff has determined that additional monitoring is no longer warranted. 

Currently, the monitoring is documented in a publicly available memorandum 

from the NRC Office of Nuclear Regulatory Research. The most recent 

memorandum was dated April 5, 2011. 

 
13 

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, when lessons 

Of Closure are incorporated into a knowledge management or training program, and when 

the adequacy of that program is validated using a pilot application. The NRC 

considers ongoing staff awareness and training to be part of routine staff 

activities. 

Status The staff completed this task in the second quarter of CY 2011. 

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. 

 The NRC staff researched the historical lessons learned from the implementation 

of fire protection issues at the NRC and prepared the list of lessons learned. 

Following the pilot training to the Office of Nuclear Reactor Regulation’s Division 

of Risk Assessment, improvements to the training were incorporated into the 

training. The lessons learned as a result of performing this review will continue to 

be shared with agency staff. Based on the actions taken by NRC staff, this task 

is closed. 

STEPS TO CLOSURE DUE CY QUARTER

Perform Lessons Learned Evaluation

The staff compiles the history. Complete: March 2009

The staff develops lessons learned. Complete: April 2011

Develop Knowledge Management/Training Tool

The staff develops training on the lessons learned. Complete: May 2011 

The staff conducts pilot training on the fire protection 

lessons learned.

Complete: May 2011 

Final Closure

The staff incorporates lessons learned from the pilot 

training.

Complete: May 2011 
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 when 

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

The NRC considers periodic updates to the database to be a routine staff 

activity. 

Status The staff completed this task in the second quarter of CY 2010. 

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 the development of the database. Complete: December 2009 

Final Closure

The staff establishes procedures for updates. Complete: April 2010 
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 when appropriate actions 

Of Closure are taken to address any fire protection regulatory issues identified. The NRC 

considers addressing any additional issues identified to be a routine staff activity. 

Status The staff completed this task in the third quarter of CY 2009. 

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 that 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 an enhanced 

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 the review. Complete: April 2009

The staff evaluates responses. Complete: July 2009 

Final Closure

The staff identifies issues and develops 

recommendations.

Complete: July 2009