IR 05000416/2020013

From kanterella
Jump to navigation Jump to search
Amended - Grand Gulf Nuclear Station - Triennial Fire Protection Inspection Report 05000416/2020013 and Notice of Violation
ML22034A886
Person / Time
Site: Grand Gulf 
Issue date: 02/03/2022
From: Alexandra Siwy
Division of Reactor Safety IV
To: Franssen R
Entergy Operations
References
IR 2020013
Download: ML22034A886 (19)


Text

February 3, 2022

SUBJECT:

AMENDED - GRAND GULF NUCLEAR STATION - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000416/2020013 AND NOTICE OF VIOLATION

Dear Mr. Franssen:

The NRC is issuing this revision to the subject report to accurately reflect the number of samples that were performed under Inspection Procedure 71111.21N.05, Section 03.01 contained in NRC Inspection Report 05000416/2020013, dated December 3, 2020 (ADAMS Accession No. ML20338A271). This section of the original report indicated that two partial samples and four complete samples were documented. This section has been amended to indicate that four partial and zero complete samples were documented.

On November 5, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station and discussed the results of this inspection with Mr. Brad Wertz, General Manager Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.

Enclosure 2 discusses a violation associated with a finding of very low safety significance (Green). The NRC evaluated this violation in accordance Section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in Enclosure 1, Notice of Violation (Notice), and the circumstances surrounding it are described in detail in the subject inspection report (Enclosure 2). The violation is being cited in the Notice because it did not meet the criteria to be treated as a non-cited violation (NCV) since your staff did not restore compliance within a reasonable period of time after a violation was previously identified by the NRC as NCV 05000416/2017008-01, Untimely Corrective Action.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements.

If you contest the violation or the significance or severity of the violation documented in Enclosure 1, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Director, Division of Reactor Safety, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Grand Gulf Nuclear Station and emailed to R4Enforcement@nrc.gov.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Grand Gulf Nuclear Station.

This letter, its enclosures, and your response will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Docket No. 05000416 License No. NPF-29

Enclosures:

1. Notice of Violation 2. Inspection Report 05000416/2020013

ML22034A886 X SUNSI Review By: ADS ADAMS:

X Yes No Sensitive X Non-Sensitive Non-Publicly Available X Publicly Available Keyword NRC-002 OFFICE DRP:C/PBC DRS:C/EB2

NAME JEJosey ADSiwy

SIGNATURE

/RA/

/RA/

DATE 2/3/2022 2/3/2022

Enclosure 1 NOTICE OF VIOLATION

Entergy Operations, Inc.

Docket No. 50-416 Grand Gulf Nuclear Station

License No.: NPF-29

During an NRC inspection conducted from August 10-28, 2020, a violation of NRC requirements was identified. In a

Inspection Report

Docket Number:

05000416

License Number:

NPF-29

Report Number:

05000416/2020013

Enterprise Identifier: I-2020-013-0006

Licensee:

Entergy Operations, Inc.

Facility:

Grand Gulf Nuclear Station

Location:

Port Gibson, MS

Inspection Dates:

August 10, 2020, to August 28, 2020

Inspectors:

S. Alferink, Reactor Inspector

S. Graves, Senior Reactor Inspector

N. Okonkwo, Reactor Inspector, Team Lead

Approved By:

Nicholas H. Taylor, Chief

Engineering Branch 2

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection inspection at Grand Gulf Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Untimely Corrective Actions Associated with Multiple Spurious Operations Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NOV 05000416/2020013-01 Open

[H.1] - Resources 71111.21N.05 The team identified a Green violation of License Condition 2.C.(41) for the failure to correct a condition adverse to fire protection in a timely manner. Specifically, the licensee failed to complete corrective actions for multiple spurious operations concerns previously identified in 2011, for which non-cited violation NCV 05000416/2017008-01 was issued in 2017.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

REACTOR SAFETY

===71111.21N.05 - Fire Protection Team Inspection (FPTI)

Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01) (4 partial samples)

The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA). All sections of 03.01 were completed for the following samples except subsections b and e.

Subsection b states verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA)analysis and SSA. Subsection e states Perform a walkdown inspection to identify equipment alignment discrepancies. Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation. Due to conditions related to COVID19 in the area of the licensee, onsite inspector walkdowns of procedures with licensee operations personnel could not be performed at this time. An inspector will visit the licensee's site to perform this activity at a later date. The results of the additional inspection will be documented in a resident inspector's quarterly report.

(1)

(Partial)

Fire suppression and detection in Fire Area 11, Auxiliary Building, 139 Ft Elevation (Fire Zone CA201)

(2)

(Partial)

Low Pressure Coolant Injection (LPCI) System (LPCI injection valve lE12-F042A (3)

(Partial)

Fire Suppression and detection in Fire Area 31, Switchgear Room (Fire Zone OC202)

(4)

(Partial)

Fire Suppression System - CO2 Cardox System Fire Protection Program Administrative Controls (IP Section 03.02)===

The inspectors verified that the following fire protection program administrative controls were implemented in accordance with the current licensing basis:

(1) The inspectors reviewed the licensees control of transient combustibles, fire impairments and compensatory measures.
(2) The inspectors reviewed procedures for fire protection program changes, fire brigade training, procedures, drills, and qualifications.

Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)

The inspectors reviewed the following changes to ensure that they did not constitute an adverse effect on the ability to safely shutdown post-fire and to verify that fire protection program documents and procedures affected by the changes were updated.

(1) The inspectors reviewed EC 73397-Revised Engineering Report GGNS-EE-11-0001, GGNS Appendix R Safe Shutdown Analysis, and EC 86851-Appendix R Updates to Address Non-Cited Violations from the 2017 NRC Triennial Fire Protection Inspection to address the multiple spurious operations (MSO) items.
(2) The inspectors reviewed engineering change EC 79268 - Power Generation Control Complex (PGCC) Halon 1301 Fire Protection System Replacement.

INSPECTION RESULTS

Untimely Corrective Actions Associated with Multiple Spurious Operations Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NOV 05000416/2020013-01 Open

[H.1] - Resources 71111.21N.05 The team identified a Green violation of License Condition 2.C.(41) for the failure to correct a condition adverse to fire protection in a timely manner. Specifically, the licensee failed to complete corrective actions for multiple spurious operations concerns previously identified in 2011, for which non-cited violation NCV 05000416/2017008-01 was issued in 2017.

Description:

In 2011, the licensee convened an expert panel to evaluate multiple spurious operations scenarios identified in NEI 00-01, Guidance for Post Fire Safe Shutdown Circuit Analysis, Revision 3. The panel identified multiple spurious operations scenarios that were not resolved by the evaluations, procedure revisions, and modifications performed based on the earlier guidance in NEI 00-01, Revision 2.

In 2014, the licensee evaluated these additional multiple spurious operations scenarios in Engineering Change EC51550. The licensee resolved most of the scenarios, but identified five scenarios that required additional evaluation. The licensee transferred the five remaining scenarios to Condition Report WT-WTGGN-2015-00090 to be addressed as a plant project.

In 2017, the triennial fire protection inspection team documented a non-cited violation for the failure to correct a condition adverse to fire protection in a timely manner. Specifically, the team documented that the licensee failed to complete the evaluations for the additional multiple spurious operations scenarios that were identified in 2011. In the inspection report, the team noted that the licensee had

approved project funding for 2017 and 2018. The inspection team issued the inspection report on June 2, 2017 as Inspection Report 05000416/2017008 (ML17156A038).

Subsequent to the 2017 inspection, the licensee completed the evaluations for the multiple spurious operations scenarios in Engineering Change EC73397 in July 2019. The licensee combined two of the scenarios into a single scenario, resulting in four multiple spurious operations scenarios to resolve. The licensee resolved two of the scenarios (2-NEW-7 and 2c) through analysis and credited operator manual actions to resolve the remaining two scenarios (2-NEW-6 and 2p). The licensee updated the safe shutdown analysis to reflect the resolution of these scenarios on July 21, 2020.

Scenario 2-NEW-6 was associated with the spurious start of the non-credited residual heat removal and low pressure core spray pumps without a discharge path, resulting in catastrophic seal failure and the subsequent loss of suppression pool inventory and net positive suction head for the credited safe shutdown pumps. The licensee evaluated this scenario in Calculation MC-Q1111-17002, MSO Scenario: Estimated Time for Operator Manual Action After Multiple Pumps Undergo Dead Head Conditions to Affect NPSH of RHR and LPCS Pumps, Revision 0. The licensee determined a limiting time of 12.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (767 minutes) prior to the loss of net positive suction head for the credited safe shutdown pumps. To resolve this scenario, the licensee added operator manual actions to trip the non-credited residual heat removal and low pressure core spray pumps if the suppression pool level was decreasing during a fire.

Scenario 2p was associated with the spurious start of the non-credited standby service water pump and the spurious opening of three valves in the residual heat removal system. The licensee evaluated this scenario in Calculation MC-Q1111-17004, Impact on SSW Basin A Due to Diversion to Suppression Pool Due to MSO, Revision 0. The licensee determined that it would take approximately 309 hours0.00358 days <br />0.0858 hours <br />5.109127e-4 weeks <br />1.175745e-4 months <br /> for the basin to be depleted to the bottom of the siphon inlet. To resolve this scenario, the licensee added an operator manual action to stop the non-credited standby service water pump for fires in Fire Areas 33, 36, 38, 42, and 50 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The licensee issued Condition Report PR-PRGGN-2019-01617 to revise Procedure 10-S-03-2, Response to Fires, on August 6, 2019. This condition report contained Corrective Action 4, which was created to Coordinate review of the proposed procedure changes (attached to CA2) with the GGNS Fire Protection Engineer (owner of 10-S-03-2). Issue next CA for processing the procedure update for EC73397.

Corrective Action 4 was created on November 24, 2019, with an original due date of January 31, 2020. The due date was subsequently extended four times. The due date was extended the first time due to unanticipated turnover in personnel. The due date was extended two additional times due to a lack of input from the action originator. The due date was extended the final time on June 24, 2020, due to the upcoming arrival of the fire protection inspection team. At the beginning on August 10, 2020, the licensee had not updated this procedure to incorporate the operator manual actions to resolve the final two multiple spurious operations scenarios. The licensee subsequently revised the procedure on September 17, 2020, to incorporate these manual actions in response to concerns raised by the inspection team.

The team determined that the licensee failed to correct a condition adverse to fire protection in a timely manner since the licensee failed to incorporate the operator manual actions into the post-fire safe shutdown procedure in a timely manner. The team noted that the multiple spurious operation scenarios were first identified in 2011 and this issue had remained uncorrected for nine years.

The team also reviewed the regulatory requirements associated with multiple spurious operations.

Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants, Revision 3, states that the information included in Appendix H of NEI 00-01 may be used in classifying components on the success path required for hot shutdown and those important to safe shutdown, when applied in conjunction with the regulatory guide. NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 2, Appendix H, Required for Hot Shutdown Versus Important to SSD [Safe Shutdown] Components, provides guidance on the classification of equipment as required for hot shutdown and important to safe shutdown. This guidance states (emphasis added): If the evaluation indicates that there is no impact, for an unlimited amount of time, to the required hot shutdown system to perform its required safe shutdown function, then the flow diversion is classified as non-impacting."

The team noted that the plant could not withstand either of these scenarios for an unlimited amount of time without operator manual actions. Therefore, the flow diversions would not be classified as non--impacting and the flow diversions need to be addressed by the licensee. This provided further evidence that the operator manual actions were required corrective actions and not procedural enhancements.

Corrective Actions: There was no immediate safety concern because the multiple spurious operations scenarios did not prevent the ability to achieve safe shutdown. The licensee subsequently revised the procedure on September 17, 2020, to incorporate these manual actions.

Corrective Action References: CR-GGN-2020-09284 and CR-GGN-2020-09285

Performance Assessment:

Performance Deficiency: The failure to correct a condition adverse to fire protection in a timely manner was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors (Fire) attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Significance: The team evaluated the risk significance of the finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, dated May 2, 2018, because it affected the ability to reach and maintain safe shutdown in case of a fire.

The team assigned the post-fire safe shutdown category to the finding because it involved circuit failure modes and effects (e.g., spurious operation issues).

The team discussed the finding with a senior reactor analyst because the finding involved multiple fire areas. In consultation with the senior reactor analyst, the team determined the risk significance for fire areas outside of the control room and the control room separately.

For fire areas outside of the control room, the team determined the finding was of very low risk significance (Green) in Step 1.4.7 because the impact of the finding was limited to equipment that was not required for the credited safe shutdown success path.

For the control room, the senior reactor analyst performed a Phase 3 evaluation to determine the risk significance because it involved a postulated control room fire that led to control room evacuation. For the control room, the analyst used the fire ignition frequency for the control room listed in the Grand Gulf Nuclear Station Engineering Report for Individual Plant Examination of External Events Summary Report, Revision 1, as the best available information. The analyst multiplied the fire ignition frequency (FIFCR) by a severity factor (SF) and a non-suppression probability indicating that operators failed to extinguish the fire within 20 minutes, assuming 2 minutes for detection, and the fire required a control room evacuation (NPCRE). The resulting control room evacuation frequency (FCR-EVAC) was:

FCR-EVAC = FIFCR

  • SF
  • NPCRE = 9.5E-3
  • 0.1
  • 1.30E-2 = 1.24E-5/yr

The control room had a total of 43 panels and 15 termination cabinets. The analyst determined that four panels and three cabinets were associated with Scenario 2p and four hot shorts were required in at least two independent panels in order for this scenario to occur. The analyst also determined that three panels were associated with Scenario 2-NEW-6 and two hot shorts in a single panel were sufficient for this scenario to occur.

The analyst calculated a bounding change in core damage frequency (CDF) for each scenario by multiplying the control room evacuation frequency by the fraction of panels and termination cabinets containing the affected circuits and the probability of the hot shorts occurring. The analyst calculated a bounding change in core damage frequency for the finding by adding the change in core damage frequency for each scenario.

CDF2p = FCR-EVAC * (7/58)

  • PShort4 = 1.24E-5/yr * (7/58) * (0.64)4 = 2.50E-7/yr

CDF2-NEW-6 = FCR-EVAC * (3/58)

  • PShort2 = 1.24E-5/yr * (3/58) * (0.64)2 = 2.62E-7/yr

CDF = CDF2p + CDF2-NEW-6 = 2.50E-7/yr + 2.62E-7/yr = 5.12E-7/yr

This change in core damage frequency was considered to be bounding because it assumed:

  • The conditional core damage probability given a control room fire with evacuation and the multiple spurious operations scenarios was equal to one
  • The probability a hot short occurred is the maximum value of 0.64 provided in NUREG/CR-7150, Joint Assessment of Cable Damage and Quantification of Effects from Fire (JACQUE-FIRE), Volume 2; and
  • The performance deficiency accounted for the entire change in core damage frequency (i.e., the baseline core damage frequency for this event was zero)

In accordance with Inspection Manual Chapter 0609, Appendix H, Containment Integrity Significance Determination Process, dated March 23, 2020, the analyst screened the finding for its potential risk contribution to large early release frequency because the bounding change in core damage frequency provided a risk significance estimate greater than 1E-7/yr.

Given that Grand Gulf Nuclear Station has a Mark III containment, the control room evacuation scenarios of concern do not include intersystem loss of coolant accidents or station blackouts, and the control room evacuation scenarios of concern do not result in a high reactor coolant system pressure, the analyst determined that this finding was not significant with respect to large early release frequency. The analyst determined the finding was of very low risk significance (Green).

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. The team assigned a cross-cutting aspect in the area of human performance associated with resources because the licensee failed to provide sufficient resources to complete the corrective actions in a timely manner. Specifically, the licensee failed provide sufficient resources to update the analyses and procedures for multiple spurious operations scenarios in a timely manner.

Enforcement:

Violation: License Condition 2.C.(41) requires, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in Revision 5 to the Updated Final Safety Analysis Report and as approved in the Safety Evaluations, dated August 23, 1991, and September 29, 2006.

Updated Final Safety Analysis Report, Section 9.5.1.3 states, in part, that, as noted in the Safety Evaluation Report (NUREG 0831), the NRC staffs Safety Evaluation Report concluded, based on evaluation of the fire protection program and related commitments, that the fire protection program meets the applicable guidelines of Branch Technical Position APCSB 9.5-1, dated August 23, 1978.

Branch Technical Position APCSB 9.5-1, Position C.8, states, in part, that measures should be established to assure that conditions adverse to fire protection are promptly identified and corrected.

Contrary to the above, from August 2011 to September 17, 2020, the licensee failed to promptly correct a condition adverse to fire protection. Specifically, the licensee failed to complete corrective actions for multiple spurious operation concerns identified in 2011 and documented as non-cited violation, NCV 05000416/2017008-01, Untimely Corrective Action. The licensee failed to incorporate operator manual actions into the post-fire safe shutdown procedure.

Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On November 5, 2020, the inspectors presented the triennial fire protection inspection results to Mr. B. Wertz, General Manager Plant Operations, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.21N.05 Calculations

GGNS-EE-11-

00001

GGNS Appendix R Safe Shutdown Analysis (FPP-1)

004

GGNS-NE-10-

00003

GGNS EPU Appendix R - Fire Protection

GGNS-NE-16-

00004

Time Critical Operator Actions for Grand Gulf Nuclear

Station

MC-Q1111-

17002

MSO Scenarios: Estimated Time for Operator Manual

Action After Multiple Pumps Undergo Dead Head

Conditions to Affect NPSH or RHR and LPCS Pumps

MC-Q1111-

17003

Impact of Spurious HPCS on RHR Alternate Shutdown

Cooling

MC-Q1111-

17004

Impact on SSW Basin A Due to Diversion to Suppression

Pool Due to MSO

MC-Q1111-

17006

MOV Thrust Evaluation for MSO 2-NEW-6

MC-Q1B21-

11001

RPV Inventory Loss Through Outboard MSIV Drain Lines

and RHR NPSH During an Appendix R Control Room Fire

MC-Q1B21-

14001

Boiling Off Reactor Inventory through the Steam Line

Drains and MSIV-LCS due to Multiple Spurious

Operations (MSO)

MC-Q1E12-

05007

RHR NPSH During an Appendix R Control Room Fire

Corrective Action

Documents

CR-GGN-2002-00645 CR-GGN-2017-03996 CR-GGN-

2017-04011 CR-GGN-2017-04028 CR-GGN-2019-

210 CR-GGN-2019-10214 CR-GGN-2017-03368

Corrective Action

Documents

Resulting from

Inspection

CR-GGN-2020-08956 CR-GGN-2020-09284 CR-GGN-

20-09285 CR-HQN-2020-01662

Drawings

A-0634

Unit 1 Aux & Diesel Gen Bldg and SSW Pump House -

Fire Protection Floor Plans at El. 133-0 & 139-0

A-KG0630

Control Building Fire Protection Plan

A

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

E-1086-001

MCC Tabulation 480 V ESF MCC-16B11, Auxiliary

Building

E-1181-036

Schematic Diagram, E12 Residual Heat Removal System

RHR Injection Valve F0426 (F42-B)

M-1085C

P&I Diagram, Residual Heat Removal Diagram

M-652.0-NS-1.1-

6-C

Low Pressure CO2 Fire Extinguishing System Building

Lay-Out Elev. 113 _ 119FT

M-652.0-NS-1.1-

7-G

Low Pressure CO2 Fire Extinguishing System Building

Lay-Out Elev. 113 _ 119FT

M-652.0-NS-1.1-

8-F

Low Pressure CO2 Fire Extinguishing System One

Hazard Details

M652.0-NS-1.1-

10-E

Low Pressure CO2 Fire Extinguishing System One

Hazard Details

M652.0-NS-1.1-

3-2

Low Pressure CO2 Fire Extinguishing System

M652.0-NS-1.1-

4-D

Low Pressure CO2 Fire Extinguishing System

Engineering

Changes

EC-73397

Revised Engineering Report GGNS-EE-11-0001, GGNS

Appendix R safe Shutdown Analysis to address multiple

MSO items

EC 79268

Power Generation Control Complex (PGCC) Halon 1301

Fire Protection System Replacement

EC86851

Appendix R Update to Address Non-cited Violations from

the 2017 NRC Triennial Fire Protection Inspection

Miscellaneous

460000437

Chemetron Fire Systems

01/08/1979

FB Quals

Fire Brigade Member Qualifications

7/15/2020

FPP-1-WSES

Water Suppression Effects Study

01/03/1985

GGNS-ME-19-

00002

Engineering Report Review of the Aboveground Metallic

Tanks Program for License Renewal Implementation

GGNS-ME-19-

00005

Engineering Report Review of the Buried Piping and

Tanks Inspection Program for License Renewal

Implementation

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

GLP-FB-ELEC

Fighting Electrical Fires

GLP-FB-INTRO

Introduction to Grand Gulf Nuclear Fire

GLP-FB-PPE

Fire Brigade Protective Equipment

GLP-FB-SUPRS

Fire Suppression Techniques

LO-GLO-2018-

00175

GGNS Pre-FPTI (Fire Protection Team Inspection) Self-

Assessment

MSO White

Paper #1

The NRC Inspection Team requested a discussion of the

timeliness of corrective actions for the violations

documented in the 2017 NRC Fire Protection Inspection

Report.

N/A

MSO White

Paper #2

Timeliness of Corrective Actions for 2017 NRC Fire

Protection Inspection Violations

N/A

MSO White

Paper #3

The NRC Inspection Team requested a discussion of the

timeliness of corrective actions for the violations

documented in the 2017 NRC Fire Protection Inspection

Report

N/A

MSO #4

Response

Fourth Response from GG on NOV for untimely MSO

resolution Procedure revision

10/13/2020

N/A

50.59 Evaluation 2020-002 for EC85716

N/A

Licensing Basis Document Change Request LBDCR-

20-0027

04/08/2020

N/A

Process Applicability Determination Form for EC86851

N/A

Process Applicability Determination Form for EC85716

N/A

Technical Data Sheet - 3M' Novec' 1230 Fire

Protection Fluid

01/2020

N/A

Condition Report List - Penetration Seal Work

08/10/2020

NFPA-12

Standard on Carbon Dioxide Extinguishing Systems

1973

NFPA-12A

Standard on Halogenated Fire Extinguishing Agent

Systems Halon 1301

1973

NFPA-2001

Standard on Clean Agent Fire Extinguishing Systems

2018

NUC2018139-

NSR-CIF-001

Fire Water Storage Tank A (Interior) As-Found Visual

Coating Condition Assessment Report

08/20/2018

NUC2018139-

NSR-CIF-002

Fire Water Storage Tank B (Interior) As-Found Visual

Coating Condition Assessment Report

08/20/2018

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

OBS-2019-67673 CNS Fire Drill Observation

6/28/2019

PR-PRGGN-

2019-01617

Procedure Request PR-PRGGN-2019-01617

PR-PRGGN-

20-00942

Procedure Request PR-PRGGN-2020-00942

PR-PRGGN-

20-01018

Procedure Request PR-PRGGN-2020-01018

Operability

Evaluations

EN-LI-102

Corrective Action Program

Procedures

04-1-01-P64-3

Fire Protection Cardox System

28

04-1-02-1H13-

P870

Alarm Response Instruction, Panel No.: 1H13-P870

160

04-S-01-P64-1

Fire Protection Water System

05-1-02-II-1

Shutdown from The Remote Shutdown Panel

2

05-1-02-II-1

Shutdown from Remote Shutdown Panel

05-S-01-EP-3

Emergency Procedure Containment Control

031

06-EL-SP64-R-

0002

CO2 SYSTEMS TIMING RELAY CALIBRATION AND

FUNCTIONAL TEST

104

06-EL-SP64-R-

0003

SURVEILLANCE PROCEDURE Auxiliary Building CO²

Systems Timing Relay Calibration and Functional Test

103

06-EL-SP64-R-

0005-01

111 Control Building CO2 System Panel N1 P64D207

Timing Relay Calibration and Functional Test

101

06-EL-SP64-R-

0005-01

111 Control Building CO2 System Panel N1P64D207

Timing Relay Calibration and Functional Test

2

06-EL-SP64-SA-

0001

Novec 1230 Detectors and Supervisory Panels Functional

Test

107

06-EL-SP64-SA-

1001

CO2 System Thermal Detectors And Supervisory Panel

Functional Test

106

06-EL-SP65-SA-

0001

Surveillance Procedure Control Building Fire Detector And

Supervisory Panel Functional Test

106

06-ME-SP64-R-

0016

Surveillance Procedure Unit 1 Fire Hose Check

109

06-ME-SP64-R-

0045

Surveillance Procedure Ventilation System Fire Dampers

Inspection

113

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

06-OP-1M61-V-

0003

Surveillance Procedure Local Leak Rate Test - Low

Pressure Water

009

06-OP-SP64-D-

0044

Fire Door Check

119

06-OP-SP64-M-

0011

Surveillance Procedure Fire Protection System Valve

Lineup Verification

116

06-OP-SP64-M-

0043

Fire Door Alarm Check

115

06-OP-SP64-M-

0047

Surveillance Procedure Unit I Fire Hose Station And Fire

Extinguisher Maintenance

119

06-OP-SP64-R-

0002

Ton CO2 Systems Puff Test

2

06-OP-SP64-R-

0048

Visual Inspection of Fire Wrapped Raceways

108

06-OP-SP64-R-

0049

Surveillance Procedure Fire Rated Sealed Penetrations

Visual Inspection

2

06-OP-SP64-W-

0045

Weekly Fire Door Check

118

07-1-24-P64-5

Carbon Dioxide Storage Unit Safety Valve Setpoint

10-S-03-2

Response To Fires

030

10-S-03-2

Response to Fires

10-S-03-7

Fire Protection Training Program

016

EN-DC-128

Fire Protection Impact Reviews

EN-LI-100

Process Applicability Determination

29

EN-LI-101

CFR 50.59 Evaluations

EN-OP-115

Conduct of Operations

28

EN-TQ-125

Fire Brigade Drills

010

SEP-FPP-GGN-

001

Grand Gulf Nuclear Station Fire Protection Plan

Work Orders

00492605

SP64F469 Replace CO2 Storage Unit Pressure Relief

Valve

11/12/2019

00492606

SP64F470 Replace CO2 Storage Unit Pressure Relief

Valve

11/12/2019

259153

06OPSP64-R-0049-07 Fire Rated Sealed Penetrations

10/06/2015

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Visual Ins

2655775

06OPSP64-R-0049-02 Fire Rated Sealed Penetrations

Visual Ins

07/01/2017

2716253

06ELSP64-R-0005-01 D207**CNTL BLDG DIV 1 SWGR

ROOM**

01/25/2018

2720762

06OPSP64-R-0002 10 TON CO2 SYSTEM PUFF TESTS 03/24/2018

2745113

06ELSP64-R-0005-04 D212**REMOTE S/D DIV 1 & 2

07/24/2018

2751208

06ELSP65-SA-0001-04 TEST ZONE: 1-04 / CONTROL

BLDG 1

08/21/2018

2805223

06ELSP64-R-0005-01 D207 CNTL BLDG DIV 1 SWGR

RM **DIV 1**

03/20/2019

2814441

06OPSP64-R-0002 10 TON CO2 System Puff Tests

06/09/2019

2833271

06ELSP64-R-0005-04 D212**REMOTE S/D DIV 1 & 2

09/26/2019

2842514

06MESP64-R-0045-01 CNTL BLDG DAMPER

INSPECTION (21 TOTAL )

03/13/2018

2848954

06ELSP64-R-0003-01 1P64D200A**DIV 1 SE SWGR RM

119 A-7

05/16/2020

2850968

06OPSP64-R-0048-06 VISUAL INSPECTION OF FIRE

WRAPPED RACEWAY

05/14/2020

2859363

06OPSP64-R-0049-01 FIRE RATED SEALED

PENETRATIONS VISUAL INS

06/25/2020

2935304

06OPSP64-M-0043 FIRE DOORS ALARM CHECK

07/30/2020