POLICY ISSUE 

INFORMATION 

May 14, 2010 SECY-10-0060

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 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 to complete 

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

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

traditional deterministic fire protection regulations. On May 22, 2009, and November 2, 2009, 

the staff updated the Commission on milestones that had been completed in Commission 

papers SECY-09-0079, “Closing Fire Protection Issues—Semiannual Update,” dated 

May 20, 2009, and SECY-09-0161, “Closing Fire Protection Issues—Semiannual Update,” 

dated November 2, 2009. This paper provides the third semiannual update of completed tasks 

in the stabilization plan. 

CONTACT: Daniel M. Frumkin, NRR/DRA 

 (301) 415-2280 
The Commissioners - 2 - 

DISCUSSION: 

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

substantial progress on the remaining tasks since the last update, including the completion of 

two significant deliverables. 

The four tasks that have been completed are Task 2 concerning electrical raceway fire barriers, 

Task 5 concerning regulatory effectiveness assessments, Task 7 concerning the development 

of an exemption database, and Task 8 concerning the evaluation of past fire protection issues. 

The two significant deliverables that have been completed are (1) the issuance of Revision 2 to 

Regulatory Guide 1.205, “Risk-Informed, Performance-Based Fire Protection for Existing 

Light-Water Nuclear Power Plants,” which incorporates lessons learned from pilot plant reviews, 

and (2) the completion of the fire protection exemption database. The completion of these 

activities constitutes two significant accomplishments since the staff provided the last update to 

the Commission in November 2009. 

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

entitled, “Plan for Stabilizing Fire Protection Regulatory Infrastructure,” Revision 3, reflects the 

current status as follows: 

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

Requirements Title 10 of the Code of Federal Regulations (10 CFR) 50.48(c), “National 

Fire Protection Association Standard NFPA 805,” (NFPA 805). The staff has completed 

18 of the 20 milestones and deliverables and expects to close Task 1 in the fourth 

quarter of calendar year (CY) 2010. The decision regarding the license amendment for 

Shearon Harris is expected to occur in May 2010. Other noteworthy accomplishments 

that have occurred since the last update to the Commission include the following: 

– The issuance of a revision to Regulatory Guide 1.205 in December 2009. 

– The issuance of a new standard review plan to support Regulatory Guide 1.205. 

– The staff is continuing to work with industry to enhance implementing 

information, such as a license amendment template, to smooth the transition for 

plants that adopt NFPA 805. 

• Task 3: Fire-Induced Circuit Failures. The staff has completed 18 of the 19 milestones 

and deliverables and expects to close Task 3 by the end of CY 2010. Since the last 

update to the Commission, the staff participated in an industry workshop on the 

resolution of this issue and noted that licensees should plan to complete their 

identification of multiple spurious actuation issues by May 2, 2010. 

• Task 4: Operator Manual Actions. The staff has completed seven of the nine 

milestones and deliverables and expects to close Task 4 by late CY 2010. 

• Task 6: Fire Protection Lessons Learned. The staff has completed one of the five 

milestones and deliverables and expects to close Task 6 by third quarter CY 2010. 
The Commissioners - 3 - 

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

publication of the updated plan on November 2, 2009. The remaining tasks are all scheduled to 

be completed by the end of CY 2010. The NRC staff plans to issue the next and final 

Commission paper on this topic when all of the remaining tasks are completed. 

COORDINATION: 

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

 /RA/ 

Eric J. Leeds, Director 

Office of Nuclear Reactor Regulation 

Enclosure: 

Plan for Stabilizing Fire Protection 

 Regulatory Infrastructure, Revision 3 
The Commissioners - 3 - 

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

publication of the updated plan on November 2, 2009. The remaining tasks are all scheduled to 

be completed by the end of CY 2010. The NRC staff plans to issue the next and final 

Commission paper on this topic when all of the remaining tasks are completed. 

COORDINATION: 

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

 

Eric J. Leeds, Director 

Office of Nuclear Reactor Regulation 

Enclosure: 

Plan for Stabilizing Fire Protection 

 Regulatory Infrastructure, Revision 3 

WITS 200900239/EDATS: SECY-2009-0509 

ADAMS Accession No.: ML101020095 *via email 

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

NAME DFrumkin AKlein KKriebs MCunningham CLui 

DATE 04/ 19 /10 04/ 20 /10 04/16/10 04/ 21 /10 04/ 30 /10 

OFFICE OE OGC – NLO NRR 

NAME NHilton GGulla for EWilliamson ELeeds 

DATE 04/ 23 /10 04/ 26 /10 05/14/10 

OFFICIAL RECORD COPY
Enclosure

PLAN FOR STABILIZING FIRE PROTECTION 

REGULATORY INFRASTRUCTURE

Revision 3 

(Changes since November 2, 2009, the last update provided to the 

Commission are highlighted in blue.) 
 - 2 -

ACRONYMS

2Q second quarter 

3Q third 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 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) of the NFPA 805 pilot 

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

amendment requests (LARs) routine staff activities. 

Status The staff expects to complete this task in the fourth quarter (4Q) 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 via a staff requirements 

memorandum (SRM) on May 11, 2004 (SRM-SECY-04-0233). The rule was 

published on June 16, 2004, and 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 Generating 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 using lessons learned from its license amendment 

reviews for the pilot plants and issued Revision 2 to this guidance, incorporating 

insights from the pilot plant reviews, 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, and licensees for 50 of those units 

have initiated their transition. 

 
- 4 - 

STEPS TO CLOSURE DUE CY QUARTER

Establish Regulatory Foundation 

NFPA 805 issued Complete: January 2001

The NRC promulgates 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, 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 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 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 
- 5 - 

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 

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) 

2010 2nd Q 

The staff issues the pilot plant SER (Oconee) 2010 3Q or 4Q 
- 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. 

Status The staff completed this task in December 2008. 

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. 

In May 2010, the NRC staff finalized a NUREG series document, NUREG-1924, 

“Electrical 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 in use at U.S. nuclear power plants.

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
- 7 - 

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 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 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 plans to complete this task in the 4Q of CY 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 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 

The 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 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 

Safe-Shutdown 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 to be needed 

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

The NRC issues the final RG for fire-induced circuit 

failures 

Complete: November 2009

Validate Implementation 

The staff establishes a method to validate the Complete: December 2009
- 10 - 

disposition of circuit issues 

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 

2010 4Q 
- 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. The NRC 

considers the review and approval of those applications routine staff activities. 

Status The staff plans to complete this task in the 4Q of CY 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 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.

 

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’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 

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 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: December 2004

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, “Enforcement Discretion For 

Post-Fire Manual Actions Used as Compensatory 

Measures for Fire Induced Circuit Failures,” June 30, 

2007, 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 

2010 4Q 

Final Closure 

Infrastructure stabilized and validated 2010 4Q 
- 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 when the baseline 

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

routine staff activity. 

Status The staff completed this task in the 4Q 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.

 

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, 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 part of routine staff activities. 

Status The staff plans to complete this task in the third quarter (3Q) of CY 2010. 

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 2010 2Q

Develop Knowledge Management/Training Tool

The staff develops training on lessons learned 2010 3Q 

The staff conducts pilot training on fire protection 

lessons learned

2010 3Q 

Final Closure

The staff incorporates lessons learned from pilot 

training

2010 3Q 
- 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 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 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 a routine staff activity. 

Status The staff completed this task in the 3Q 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