POLICY ISSUE 

INFORMATION 

May 23, 2011 SECY-11-0068

FOR: The Commissioners 

FROM: Eric J. Leeds, Director 

Office of Nuclear Reactor Regulation 

SUBJECT: LESSONS-LEARNED FROM THE PILOT PLANT TRANSITION TO A 

RISK-INFORMED, PERFORMANCE-BASED FIRE PROTECTION 

LICENSING BASIS 

PURPOSE: 

The purpose of this paper is to provide the Commission with the lessons-learned from the pilot 

plant transitions to the new fire protection licensing basis under the requirements of Title 10 of 

the Code of Federal Regulations (10 CFR) 50.48(c), “National Fire Protection Association 

Standard NFPA 805.” 

BACKGROUND: 

In June 2004, the Commission promulgated a rule change in 10 CFR 50.48, “Fire Protection,” 

adding a new section, 10 CFR 50.48(c), to permit existing reactor licensees to adopt the fire 

protection requirements of National Fire Protection Association (NFPA) Standard 805, 

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

Plants, 2001 Edition,” in place of the fire protection requirements under 10 CFR 50.48(b). 

In spring 2005, two licensees, Oconee Nuclear Station (ONS) and Shearon Harris Nuclear 

Power Plant (HNP), submitted letters of intent to transition to NFPA 805 and volunteered to be 

pilot plants. Between 2005 and 2008, these pilots developed fire probabilistic risk assessments 

(PRAs) and evaluated their facilities for transition. The U.S. Nuclear Regulatory Commission 

(NRC) staff conducted a series of observation visits with the pilots to evaluate their transition 

CONTACTS: Paul W. Lain, NRR/DRA 

 301-415-2346 

 Harold T. Barrett, NRR/DRA 

 301-415-1402 
Commissioners - 2 - 

efforts. The NRC staff also evaluated industry guidance on making the transition and eventually 

endorsed this guidance, with a few exceptions, in Regulatory Guide (RG) 1.205, “Risk-Informed, 

Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants,” Revision 0, 

issued May 2006. In May 2008, both licensees submitted their license amendment requests 

(LARs) to adopt NFPA 805 (10 CFR 50.48(c)). 

In SECY-09-0005, dated January 8, 2009, the NRC staff presented the Commission with 

options for accelerating the pilot LAR reviews. In SRM-SECY-09-0005, the Commission gave 

the following instruction: 

When the staff has completed the ongoing pilots and the pilot plants have successfully 

completed the transition to NFPA 805, the staff should document the results in a paper 

to the Commission. Such a paper should include any lessons-learned to be 

incorporated into the larger tranche of license amendment request reviews. 

In 2010, the NRC staff completed both pilot LAR reviews and issued license amendments for 

HNP and ONS to transition their fire protection licensing basis to NFPA 805 (10 CFR 50.48(c)). 

In early 2011, HNP completed their implementation and modifications to fully transition to an 

NFPA 805 licensing basis. ONS has an NFPA 805 license conditions for implementation and 

modification that are scheduled to be completed for all three units by 2015. 

DISCUSSION: 

The NRC staff has learned numerous lessons during the review of the pilot LARs. The 

enclosure highlights several of the more important lessons. 

The most important lesson-learned from the pilots was that both industry and the NRC staff 

underestimated the complexity and resources necessary to address the technical issues 

associated with the transition to NFPA 805. Issuance of the HNP and ONS license 

amendments represents a major milestone in the NRC and industry efforts that began with the 

development of the consensus standard more than a decade ago. Both HNP and ONS have 

identified and made risk-informed modifications that demonstrate how risk insights can be used 

to enhance fire safety at nuclear power plants. 

In December 2009, the NRC staff incorporated lessons-learned into RG 1.205, Revision 1, and 

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

Power Plants: LWR Edition,” Section 9.5.1.2, “Risk-Informed, Performance-Based Fire 

Protection Program.” In September 2010, Supplement 1, “Fire Probabilistic Risk Assessment 

Methods Enhancements,” to NUREG/CR-6850, “EPRI/NRC-RES Fire PRA Methodology for 

Nuclear Power Facilities,” was issued and documents the pilot fire PRA lessons-learned. In 

February 2011, the Advisory Committee on Nuclear Safeguards (ACRS) reported to the 

Commission that NUREG/CR-6850 and Supplement 1 “provide a sound technical basis for the 

development of fire PRA models and analyses to support the transition to a risk-informed 

licensing framework in accordance with NFPA 805 and 10 CFR 50.48(c).” 

The NRC staff has worked with the Nuclear Energy Institute (NEI) to use lessons-learned from 

the pilot LAR reviews to update NEI’s NFPA 805 LAR template and the NRC’s NFPA 805 safety 

evaluation (SE) template. The LAR template is scheduled to be added to industry guidance, 

and the SE template will be added to the next revision of NUREG-0800, Chapter 9.5.1.2. The 

NRC staff determined there is sufficient guidance for non-pilot plants to complete their LARs, 

but has requested and received Commission approval to provide additional resources and 
Commissioners - 3 -

enforcement discretion to allow a staggered LAR submittal schedule (SRM-SECY-11-0033). 

COORDINATION: 

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

Office of Nuclear Regulatory Research has reviewed this paper and concurs. 

 /RA by William H. Ruland for 

Eric J. Leeds, Director 

Office of Nuclear Reactor Regulation 

Enclosure: 

Lessons-Learned from the Pilot Plant Transition 

to a Risk-Informed Fire Protection License Basis 
Commissioners - 3 - 

enforcement discretion to allow a staggered LAR submittal schedule (SRM-SECY-11-0033). 

COORDINATION: 

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

Office of Nuclear Regulatory Research has reviewed this paper and concurs. 

 /RA by William H. Ruland for

Eric J. Leeds, Director 

Office of Nuclear Reactor Regulation 

Enclosure: 

Lessons-Learned from the Pilot Plant Transition 

to a Risk-Informed Fire Protection License Basis 

WITS 200900119/EDATS: SECY-2009-0241 

ADAMS Accession Number: ML111120161 *via email 

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

NAME PLain HBarrett AKlein DHarrison KAzariahKribbs 

DATE 04/21/11 04/21/11 04/26/11 04/26/11 04/21/11 

OFFICE RES/DRA* OGC NLO NRR/DRA NRR 

NAME RCorreia EWilliamson MCheok ELeeds (WRuland for) 

DATE 05/03/11 05/10/11 05/02/11 05/ 23 /11 

OFFICIAL RECORD COPY
ENCLOSURE

Lessons-Learned from the Pilot Plant Transition 

to a Risk-Informed Fire Protection Licensing Basis 

On June 16, 2004, the U.S. Nuclear Regulatory Commission (NRC) promulgated the 

risk-informed, performance-based rule for fire protection, Final Rule, “Voluntary Fire Protection 

Requirements for Light-Water Reactors; Adoption of NFPA 805 as a Risk-Informed, 

Performance-Based Alternative,” (69 FR 33536; June 16, 2004). This added 10 CFR 50.48(c), 

“National Fire Protection Association Standard NFPA 805.” With minor exceptions and 

clarifications, 10 CFR 50.48(c) incorporated by reference the risk-informed, performance-based 

standard developed by the National Fire Protection Association (NFPA), NFPA 805, 

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

Plants, 2001 Edition.” An accompanying enforcement discretion policy revision provided 

incentives to the licensees to adopt the new approach; “NRC Enforcement Actions: Fire 

protection programs at operating nuclear power plants; policy statement; revision, 

69 FR 33684.” Two plants, consisting of four reactor units (Oconee Nuclear Station, Units 1, 2, 

and 3 (ONS), and Shearon Harris Nuclear Power Plant (HNP)) volunteered to become the 

NFPA 805 pilot plants. 

On May 29, 2008, HNP filed a license amendment request (LAR) to transition to NFPA 805, and 

on April 5, 2010, HNP submitted a final supplement to its LAR to resolve the NRC staff’s 

requests for additional information. In June 2010, the NRC staff completed its LAR review and 

issued a safety evaluation approving the HNP license amendment to transition to NFPA 805. 

On May 30, 2008, ONS filed a LAR to transition to NFPA 805. On April 14, 2010, ONS revised 

its LAR to reflect insights from the revised Regulatory Guide (RG) 1.205, “Risk-Informed, 

Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants,” Revision 1, 

issued December 2009. In December 2010, the NRC staff completed its LAR review and 

issued a safety evaluation approving the ONS license amendment to transition to NFPA 805. 

The pilot LAR reviews generated the following results and major lessons learned: 

• The experience with the pilot plants confirms that although plants are safe, the 

transition to the new licensing basis can result in further reductions in plant risk. 

– Both ONS and HNP expended significant resources to evaluate and install 

modifications using risk insights. These modifications improved fire safety and 

enhanced nuclear safety. For example, HNP moved at-risk safe-shutdown 

cables, installed new 3-hour-rated cable, and installed very early warning fire 

detection (incipient smoke detection) systems in risk-critical electrical cabinets 

that are designed to alert plant personnel before a fire develops beyond the initial 

preignition stage. 

– Some plant improvements implemented to reduce fire risk resulted in significant 

reduction in plant risk. For example, HNP installed an alternate reactor coolant 

pump seal injection system that will significantly improve reactor safety, not only 

from fire but also from other events such as station blackout. 

– ONS is committed to install a protected service water system, which should 

significantly improve reactor safety from fire as well as reduce the overall risk 

from other types of events. 
- 2 -

• The frequently asked question (FAQ) process was instrumental in resolving 

regulatory and technical implementation issues in an open, collaborative, and timely 

manner. 

– The NRC established an FAQ process to provide interim NRC staff positions in a 

timely manner on technical issues identified by pilot and non-pilot plants. 

Regulatory Issue Summary 2007-19, “Process for Communicating Clarifications 

of Staff Positions Provided in Regulatory Guide 1.205 Concerning Issues 

Identified During the Pilot Application of National Fire Protection Association 

Standard 805,” dated August 20, 2007, established the FAQ process and 

describes the process in detail. 

– The industry and NRC staff resolved technical and regulatory challenges during 

the pilot transition period. To date, industry has submitted more than 45 FAQs 

related to NFPA 805. The NRC has dispositioned almost all of these FAQs and 

continues to work on the remainder. 

 The interim NRC staff positions that the FAQ process generates provide a 

measure of regulatory stability to licensees who are transitioning to 

NFPA 805. The staff finalizes these positions by formally incorporating 

them into regulatory documents. 

 In December 2009, the staff incorporated most of the resolved interim 

NRC staff positions into Revision 1 of RG 1.205. 

– The NRC staff intends to continue the FAQ process through the pilot 

implementation phase and into the non-pilot LAR review period as a process for 

identifying and addressing any remaining technical issues in a timely manner. 

– The NRC staff has seen a reduction in the number of FAQs submitted. This is an 

indication of the increased stability in the NFPA 805 regulatory infrastructure. 

• The pilot plants used and advanced current technologies in fire probabilistic risk 

assessment (PRA) and fire modeling.

– In September 2005, the Office of Nuclear Regulatory Research (RES), working 

under a Memorandum of Understanding (MOU) with the Electric Power Research 

Institute (EPRI), published NUREG/CR-6850, “EPRI/NRC-RES Fire PRA 

Methodology for Nuclear Power Facilities.” 

– Fire models used for performance-based evaluations are required to be 

acceptable to the NRC as well as verified and validated (NFPA 805, 

Section 2.4.1.2). In May 2007, RES, working in collaboration with EPRI, 

published NUREG-1824, “Verification and Validation of Selected Fire Models for 

Nuclear Power Plant Applications,” to provide the industry with a variety of 

acceptable fire models for their use. 

– The pilot plants made extensive use of the fire PRA methods given in 

NUREG/CR-6850 and used the FAQ process to resolve identified issues, such 

as the development of a new method to provide fire PRA credit for installing very 
- 3 -

early warning fire detection (incipient smoke detection) systems in high-risk 

electrical cabinets. 

– The NRC staff and industry agree that the current fire PRA techniques would 

benefit from continued refinement. RES and EPRI continue to work together 

under the MOU to address these issues. 

– The agency will incorporate future fire PRA-related FAQ resolutions into 

supplements or revisions of NUREG/CR-6850. 

• The process for reviewing the LARs for HNP and ONS enabled improved 

alignment among NRC staff and with licensees on the types of analyses that must 

be performed in support of the transition to NFPA 805.

– RG 1.205, Revision 0, issued May 2006, provided general guidance on several 

required risk assessment calculations. 

– The pilot process illustrated the need for further clarity and prompted additional 

discussions among NRC staff and licensees. In December 2009, the staff 

revised RG 1.205 to capture these lessons-learned. 

– The NRC staff used a draft section of NUREG-0800, “Standard Review Plan for 

the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition,” 

during the early portion of the LAR reviews to capture lessons-learned. In 

December 2009, the staff formally published Section 9.5.1.2, “Risk-Informed, 

Performance-Based Fire Protection Program,” of NUREG-0800 to formalize the 

NFPA 805 LAR review process. 

– The NRC staff used the request for additional information process to ensure that 

the HNP LAR met the guidance of the revised RG 1.205. ONS was able to 

revise its LAR to address the revision to RG 1.205. 

• The issuance of the pilot license amendments confirmed that transition to 

NFPA 805 can provide a clear and stable licensing basis for a risk-informed fire 

protection program. 

– The pretransition licensing bases of both plants were complex and ambiguous. 

For example, the NRC staff and industry had different views on whether the 

licensees were required to postulate and mitigate fire-induced concurrent multiple 

spurious actuations (MSAs). The licensees currently rely on either an exemption 

from 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,” or the NRC staff’s approval of deviations 

from their licensing basis.

– While transitioning to NFPA 805, the pilot plants used their fire PRAs to identify 

and disposition MSA issues in a risk-informed manner. Transition to NFPA 805 

has enabled both pilot plants to be in compliance with 10 CFR 50.48 

requirements without relying on these exemptions or deviations by incorporating 

the resolution of the MSAs into their new licensing basis. 
- 4 -

• The implementation of the new rule and the review of the pilot LARs demonstrate 

the viability of risk-informing NRC regulations with reliance on consensus 

standards.

– The risk-informed fire protection rule is an example of the use of consensus 

standards in the NRC’s regulatory activities. The rule was implemented without 

taking more than minimal exceptions to the NFPA standard. 

– Since risk evaluations and the use of established risk acceptance guidelines are 

integral aspects of 10 CFR 50.48(c), the approved amendments constitute 

successful applications of a rule consistent with the Commission’s PRA policy. 

– The risk-informed lessons-learned from 10 CFR 50.48(c) are being reflected in 

another draft rule, 10 CFR 50.46a, “Acceptance Criteria for Emergency Core 

Cooling Systems for Light-Water Nuclear Power Reactors.” 

• Both industry and the NRC staff underestimated the complexity and resources it 

takes to transition to NFPA 805.

– The level of analysis and required review time for the two pilot plants greatly 

exceeded industry and NRC staff expectations. 

– The NRC staff anticipates that the review time will decrease as experience is 

gained from additional LAR reviews. 

Additionally, NRC interactions with industry groups prompted a significant change in the fire 

safety programs of about half of the Nation’s nuclear power plants and caused them to 

voluntarily transition to a risk-informed, performance-based licensing basis. Industry took a 

strong role in this initiative by developing NEI 04-02, “Guidance for Implementing a RiskInformed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c),” Revision 2, 

issued April 2008. This guide provides detailed instructions for licensees transitioning to 

NFPA 805. Industry also developed NEI 00-01, “Guidance for Post Fire Safe Shutdown Circuit 

Analysis,” Revision 2, issued May 2009. This guidance also provides detailed instructions for 

analyzing postfire safe-shutdown circuit analysis. RG 1.205 endorsed NEI 04-02 (with 

exceptions and clarifications), as well as a portion of NEI 00-01, to provide one method of 

complying with 10 CFR 50.48(c). NUREG/CR-6850, prepared under a memorandum of 

understanding between RES and EPRI, provided fire PRA methods acceptable to the NRC. 

The NFPA 805 FAQ process involves monthly public meetings with an NEI NFPA 805 task force 

to discuss emerging issues and develop solutions in an open collaborative forum. This effort is 

a model for pooling the expertise of the NRC and stakeholders to develop and implement 

risk-informed regulations.