ML20338A271
| ML20338A271 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/03/2020 |
| From: | Nick Taylor NRC/RGN-IV/DRS/EB-2 |
| To: | Franssen R Entergy Operations |
| References | |
| IR 2020013 | |
| Download: ML20338A271 (20) | |
See also: IR 05000416/2020013
Text
December 3, 2020
Mr. Robert Franssen, Site Vice President
Entergy Operations, Inc.
Grand Gulf Nuclear Station
P.O. Box 756
Port Gibson, MS 39150
SUBJECT: GRAND GULF NUCLEAR STATION - TRIENNIAL FIRE PROTECTION
INSPECTION REPORT 05000416/2020013 AND NOTICE OF VIOLATION
Dear Mr. Franssen:
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.
R. Franssen 2
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.
Sincerely,
Nicholas Digitally signed by
Nicholas H. Taylor
H. Taylor Date: 2020.12.03
12:13:31 -06'00'
Nicholas H. Taylor, Chief
Engineering Branch 2
Division of Reactor Safety
Docket No. 05000416
License No. NPF-29
Enclosures:
1. Notice of Violation
2. Inspection Report 05000416/2020013
cc w/ encl: Distribution via LISTSERV
SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: NPO Yes No Publicly Available Sensitive NRC-002
OFFICE SRI:EB2 RI:EB2 RI:EB2 C:PBC TL:ACES C:EB2
NAME SGraves NOkonkwo SAlferink JKozal JGroom NTaylor
SIGNATURE /RA/ /RA/ /RA/ JWK /RA/ NHT
DATE 11/23/2020 11/30/2020 11/30/2020 12/02/2020 12/1/2020 11/30/2020
OFFICE D:DRS C:EB2
NAME RLantz NTaylor
SIGNATURE /RA/ NHT
DATE 12/3/2020 12/3/2020
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 accordance with the NRC Enforcement Policy, the violation is
listed below:
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.
This violation is associated with a Green Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc., is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001, with a copy to the Director, Division of
Reactor Safety, U.S. Nuclear Regulatory Commission, Region IV, 1600 East Lamar Blvd.,
Arlington, Texas 76011-4511, and a copy to the NRC Resident Inspector at the Grand Gulf
Nuclear Station, and emailed to R4Enforcement@nrc.gov within 30 days of the date of the letter
transmitting this Notice of Violation (Notice). This reply should be clearly marked as a Reply to
a Notice of Violation and should include for the violation: (1) the reason for the violation, or, if
contested, the basis for disputing the violation or severity level; (2) the corrective steps that
have been taken and the results achieved; (3) the corrective steps that will be taken; and (4) the
date when full compliance will be achieved.
Your response may reference or include previous docketed correspondence, if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for Information may be
issued requiring information as to why the license should not be modified, suspended, or
Enclosure 1
revoked, or why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Your response will be made available electronically for public inspection in the NRC Public
Document Room or in the NRCs ADAMS, accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response
should not include any personal privacy or proprietary information so that it can be made
available to the public without redaction.
If personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. If you
request that such material is withheld from public disclosure, you must specifically identify the
portions of your response that you seek to have withheld and provide in detail the bases for your
claim (e.g., explain why the disclosure of information will create an unwarranted invasion of
personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information).
Dated this 3rd day of December 2020
2
U.S. NUCLEAR REGULATORY COMMISSION
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
Enclosure 2
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 Report
Aspect Section
Mitigating Systems Green [H.1] - Resources 71111.21N.0
Open
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.
2
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 completed samples and
2 partial samples)
The inspectors verified that the following systems credited in the approved fire protection
program could perform their licensing basis function:
(1) Fire suppression and detection in Fire Area 11, Auxiliary Building, 139 Ft Elevation
(Fire Zone CA201)
(2) Low Pressure Coolant Injection (LPCI) System (LPCI injection valve lE12-F042A
(3) Fire Suppression and detection in Fire Area 31, Switchgear Room (Fire Zone OC202)
(4) Fire Suppression System - CO2 Cardox System
(5) (Partial Sample)
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. Due to conditions related to COVID-19 in
the area of the licensees site, onsite inspector walkdowns of procedures with
licensee operations personnel could not be performed at this time. An inspector will
visit the licensees site to perform this activity at a later date. The results of the
additional inspection will be documented in a resident inspectors quarterly report.
(6) (Partial Sample)
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 licensees site, onsite inspector walkdowns of fire protection systems with
licensee fire protection personnel could not be performed at this time. An inspector
will visit the licensees 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.
3
Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)
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 Report
Aspect Section
Mitigating Systems Green [H.1] - Resources 71111.21N.05
Open
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).
4
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
5
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.
6
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:
- Fire damage in the applicable cabinets would create circuit faults such that the multiple
spurious operations scenarios would occur;
- 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.
7
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
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.
8
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N.05 Calculations GGNS-EE-11- GGNS Appendix R Safe Shutdown Analysis (FPP-1) 004
00001
GGNS-NE-10- GGNS EPU Appendix R - Fire Protection 04
00003
GGNS-NE-16- Time Critical Operator Actions for Grand Gulf Nuclear 2
00004 Station
MC-Q1111- MSO Scenarios: Estimated Time for Operator Manual 0
17002 Action After Multiple Pumps Undergo Dead Head
Conditions to Affect NPSH or RHR and LPCS Pumps
MC-Q1111- Impact of Spurious HPCS on RHR Alternate Shutdown 0
17003 Cooling
MC-Q1111- Impact on SSW Basin A Due to Diversion to Suppression 0
17004 Pool Due to MSO
MC-Q1111- MOV Thrust Evaluation for MSO 2-NEW-6 0
17006
MC-Q1B21- RPV Inventory Loss Through Outboard MSIV Drain Lines 0
11001 and RHR NPSH During an Appendix R Control Room Fire
MC-Q1B21- Boiling Off Reactor Inventory through the Steam Line 0
14001 Drains and MSIV-LCS due to Multiple Spurious
Operations (MSO)
MC-Q1E12- RHR NPSH During an Appendix R Control Room Fire 0
05007
Corrective Action CR-GGN-2002-00645 CR-GGN-2017-03996 CR-GGN-
Documents 2017-04011 CR-GGN-2017-04028 CR-GGN-2019-
10210 CR-GGN-2019-10214 CR-GGN-2017-03368
Corrective Action CR-GGN-2020-08956 CR-GGN-2020-09284 CR-GGN-
Documents 2020-09285 CR-HQN-2020-01662
Resulting from
Inspection
9
Inspection Type Designation Description or Title Revision or
Procedure Date
Drawings A-0634 Unit 1 Aux & Diesel Gen Bldg and SSW Pump House - 5
Fire Protection Floor Plans at El. 133'-0" & 139'-0"
A-KG0630 Control Building Fire Protection Plan A
E-1086-001 MCC Tabulation 480 V ESF MCC-16B11, Auxiliary 42
Building
E-1181-036 Schematic Diagram, E12 Residual Heat Removal System 06
RHR Injection Valve F0426 (F42-B)
M-1085C P&I Diagram, Residual Heat Removal Diagram 20
M-652.0-NS-1.1- Low Pressure CO2 Fire Extinguishing System Building
6-C Lay-Out Elev. 113 _ 119FT
M-652.0-NS-1.1- Low Pressure CO2 Fire Extinguishing System Building
7-G Lay-Out Elev. 113 _ 119FT
M-652.0-NS-1.1- Low Pressure CO2 Fire Extinguishing System One
8-F Hazard Details
M652.0-NS-1.1- Low Pressure CO2 Fire Extinguishing System One
10-E Hazard Details
M652.0-NS-1.1- Low Pressure CO2 Fire Extinguishing System
3-2
M652.0-NS-1.1- Low Pressure CO2 Fire Extinguishing System
4-D
Engineering EC-73397 Revised Engineering Report GGNS-EE-11-0001, GGNS 0
Changes Appendix R safe Shutdown Analysis to address multiple
MSO items
EC 79268 Power Generation Control Complex (PGCC) Halon 1301 0
Fire Protection System Replacement
EC86851 Appendix R Update to Address Non-cited Violations from 0
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- Engineering Report Review of the Aboveground Metallic 0
00002 Tanks Program for License Renewal Implementation
10
Inspection Type Designation Description or Title Revision or
Procedure Date
GGNS-ME-19- Engineering Report Review of the Buried Piping and 0
00005 Tanks Inspection Program for License Renewal
Implementation
GLP-FB-ELEC Fighting Electrical Fires 01
GLP-FB-INTRO Introduction to Grand Gulf Nuclear Fire 01
GLP-FB-PPE Fire Brigade Protective Equipment 01
GLP-FB-SUPRS Fire Suppression Techniques 01
LO-GLO-2018- GGNS Pre-FPTI (Fire Protection Team Inspection) Self-
00175 Assessment
MSO White The NRC Inspection Team requested a discussion of the N/A
Paper #1 timeliness of corrective actions for the violations
documented in the 2017 NRC Fire Protection Inspection
Report.
MSO White Timeliness of Corrective Actions for 2017 NRC Fire N/A
Paper #2 Protection Inspection Violations
MSO White The NRC Inspection Team requested a discussion of the N/A
Paper #3 timeliness of corrective actions for the violations
documented in the 2017 NRC Fire Protection Inspection
Report
MSO #4 Fourth Response from GG on NOV for untimely MSO 10/13/2020
Response resolution Procedure revision
N/A 50.59 Evaluation 2020-002 for EC85716 0
N/A Licensing Basis Document Change Request LBDCR- 04/08/2020
2020-0027
N/A Process Applicability Determination Form for EC86851 0
N/A Process Applicability Determination Form for EC85716 0
N/A Technical Data Sheet - 3M' Novec' 1230 Fire 01/2020
Protection Fluid
N/A Condition Report List - Penetration Seal Work 08/10/2020
NFPA-12 Standard on Carbon Dioxide Extinguishing Systems 1973
11
Inspection Type Designation Description or Title Revision or
Procedure Date
NFPA-12A Standard on Halogenated Fire Extinguishing Agent 1973
Systems Halon 1301
NFPA-2001 Standard on Clean Agent Fire Extinguishing Systems 2018
NUC2018139- Fire Water Storage Tank A (Interior) As-Found Visual 08/20/2018
NSR-CIF-001 Coating Condition Assessment Report
NUC2018139- Fire Water Storage Tank B (Interior) As-Found Visual 08/20/2018
NSR-CIF-002 Coating Condition Assessment Report
OBS-2019-67673 CNS Fire Drill Observation 6/28/2019
PR-PRGGN- Procedure Request PR-PRGGN-2019-01617
2019-01617
PR-PRGGN- Procedure Request PR-PRGGN-2020-00942
2020-00942
PR-PRGGN- Procedure Request PR-PRGGN-2020-01018
2020-01018
Operability EN-LI-102 Corrective Action Program 42
Evaluations
Procedures 04-1-01-P64-3 Fire Protection Cardox System 028
04-1-02-1H13- Alarm Response Instruction, Panel No.: 1H13-P870 160
P870
04-S-01-P64-1 Fire Protection Water System 67
05-1-02-II-1 Shutdown from The Remote Shutdown Panel 052
05-1-02-II-1 Shutdown from Remote Shutdown Panel 51
05-S-01-EP-3 Emergency Procedure Containment Control 031
06-EL-SP64-R- CO2 SYSTEMS TIMING RELAY CALIBRATION AND 104
0002 FUNCTIONAL TEST
06-EL-SP64-R- SURVEILLANCE PROCEDURE Auxiliary Building CO² 103
0003 Systems Timing Relay Calibration and Functional Test
06-EL-SP64-R- 111' Control Building CO2 System Panel N1 P64D207 101
0005-01 Timing Relay Calibration and Functional Test
12
Inspection Type Designation Description or Title Revision or
Procedure Date
06-EL-SP64-R- 111' Control Building CO2 System Panel N1P64D207 102
0005-01 Timing Relay Calibration and Functional Test
06-EL-SP64-SA- Novec 1230 Detectors and Supervisory Panels Functional 107
0001 Test
06-EL-SP64-SA- CO2 System Thermal Detectors And Supervisory Panel 106
1001 Functional Test
06-EL-SP65-SA- Surveillance Procedure Control Building Fire Detector And 106
0001 Supervisory Panel Functional Test
06-ME-SP64-R- Surveillance Procedure Unit 1 Fire Hose Check 109
0016
06-ME-SP64-R- Surveillance Procedure Ventilation System Fire Dampers 113
0045 Inspection
06-OP-1M61-V- Surveillance Procedure Local Leak Rate Test - Low 009
0003 Pressure Water
06-OP-SP64-D- Fire Door Check 119
0044
06-OP-SP64-M- Surveillance Procedure Fire Protection System Valve 116
0011 Lineup Verification
06-OP-SP64-M- Fire Door Alarm Check 115
0043
06-OP-SP64-M- Surveillance Procedure Unit I Fire Hose Station And Fire 119
0047 Extinguisher Maintenance
06-OP-SP64-R- 10 Ton CO2 Systems Puff Test 112
0002
06-OP-SP64-R- Visual Inspection of Fire Wrapped Raceways 108
0048
06-OP-SP64-R- Surveillance Procedure Fire Rated Sealed Penetrations 112
0049 Visual Inspection
06-OP-SP64-W- Weekly Fire Door Check 118
0045
07-1-24-P64-5 Carbon Dioxide Storage Unit Safety Valve Setpoint 2
10-S-03-2 Response To Fires 030
10-S-03-2 Response to Fires 28
10-S-03-7 Fire Protection Training Program 016
13
Inspection Type Designation Description or Title Revision or
Procedure Date
EN-DC-128 Fire Protection Impact Reviews 13
EN-LI-100 Process Applicability Determination 029
EN-LI-101 10 CFR 50.59 Evaluations 20
EN-OP-115 Conduct of Operations 028
EN-TQ-125 Fire Brigade Drills 010
SEP-FPP-GGN- Grand Gulf Nuclear Station Fire Protection Plan 1
001
Work Orders 00492605 SP64F469 Replace CO2 Storage Unit Pressure Relief 11/12/2019
Valve
00492606 SP64F470 Replace CO2 Storage Unit Pressure Relief 11/12/2019
Valve
52259153 06OPSP64-R-0049-07 Fire Rated Sealed Penetrations 10/06/2015
Visual Ins
52655775 06OPSP64-R-0049-02 Fire Rated Sealed Penetrations 07/01/2017
Visual Ins
52716253 06ELSP64-R-0005-01 D207**CNTL BLDG DIV 1 SWGR 01/25/2018
ROOM**
52720762 06OPSP64-R-0002 10 TON CO2 SYSTEM PUFF TESTS 03/24/2018
52745113 06ELSP64-R-0005-04 D212**REMOTE S/D DIV 1 & 2 07/24/2018
52751208 06ELSP65-SA-0001-04 TEST ZONE: 1-04 / CONTROL 08/21/2018
BLDG 1
52805223 06ELSP64-R-0005-01 D207 CNTL BLDG DIV 1 SWGR 03/20/2019
RM **DIV 1**
52814441 06OPSP64-R-0002 10 TON CO2 System Puff Tests 06/09/2019
52833271 06ELSP64-R-0005-04 D212**REMOTE S/D DIV 1 & 2 09/26/2019
52842514 06MESP64-R-0045-01 CNTL BLDG DAMPER 03/13/2018
INSPECTION (21 TOTAL )
52848954 06ELSP64-R-0003-01 1P64D200A**DIV 1 SE SWGR RM 05/16/2020
119' A-7
52850968 06OPSP64-R-0048-06 VISUAL INSPECTION OF FIRE 05/14/2020
WRAPPED RACEWAY
14
Inspection Type Designation Description or Title Revision or
Procedure Date
52859363 06OPSP64-R-0049-01 FIRE RATED SEALED 06/25/2020
PENETRATIONS VISUAL INS
52935304 06OPSP64-M-0043 FIRE DOORS ALARM CHECK 07/30/2020
15