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 H. Taylor, Chief
Engineering Branch 2
Division of Reactor Safety
Docket No. 05000416
License No. NPF-29
Enclosures:
2. Inspection Report 05000416/2020013
cc w/ encl: Distribution via LISTSERV
Nicholas
H. Taylor
Digitally signed by
Nicholas H. Taylor
Date: 2020.12.03
12:13:31 -06'00'
SUNSI Review
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: NPO
Yes No
Publicly Available
Sensitive
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
Enclosure 1
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
2
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
Enclosure 2
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000416
License Number:
Report Number:
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
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
Aspect
Report
Section
Green
Open
[H.1] - Resources
5
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.
3
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.
4
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
Aspect
Report
Section
Green
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).
5
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
6
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.
7
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.
8
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.
9
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
04
GGNS-NE-16-
00004
Time Critical Operator Actions for Grand Gulf Nuclear
Station
2
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
0
MC-Q1111-
17003
Impact of Spurious HPCS on RHR Alternate Shutdown
Cooling
0
MC-Q1111-
17004
Impact on SSW Basin A Due to Diversion to Suppression
Pool Due to MSO
0
MC-Q1111-
17006
MOV Thrust Evaluation for MSO 2-NEW-6
0
MC-Q1B21-
11001
RPV Inventory Loss Through Outboard MSIV Drain Lines
and RHR NPSH During an Appendix R Control Room Fire
0
MC-Q1B21-
14001
Boiling Off Reactor Inventory through the Steam Line
Drains and MSIV-LCS due to Multiple Spurious
Operations (MSO)
0
MC-Q1E12-
05007
RHR NPSH During an Appendix R Control Room Fire
0
Corrective Action
Documents
CR-GGN-2002-00645 CR-GGN-2017-03996 CR-GGN-
2017-04011 CR-GGN-2017-04028 CR-GGN-2019-
10210 CR-GGN-2019-10214 CR-GGN-2017-03368
Corrective Action
Documents
Resulting from
Inspection
CR-GGN-2020-08956 CR-GGN-2020-09284 CR-GGN-
2020-09285 CR-HQN-2020-01662
10
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
A-0634
Unit 1 Aux & Diesel Gen Bldg and SSW Pump House -
Fire Protection Floor Plans at El. 133'-0" & 139'-0"
5
A-KG0630
Control Building Fire Protection Plan
A
E-1086-001
MCC Tabulation 480 V ESF MCC-16B11, Auxiliary
Building
42
E-1181-036
Schematic Diagram, E12 Residual Heat Removal System
RHR Injection Valve F0426 (F42-B)
06
M-1085C
P&I Diagram, Residual Heat Removal Diagram
20
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
Revised Engineering Report GGNS-EE-11-0001, GGNS
Appendix R safe Shutdown Analysis to address multiple
MSO items
0
Power Generation Control Complex (PGCC) Halon 1301
Fire Protection System Replacement
0
Appendix R Update to Address Non-cited Violations from
the 2017 NRC Triennial Fire Protection Inspection
0
Miscellaneous
460000437
Chemetron Fire Systems
01/08/1979
FB Quals
Fire Brigade Member Qualifications
7/15/2020
Water Suppression Effects Study
01/03/1985
GGNS-ME-19-
00002
Engineering Report Review of the Aboveground Metallic
Tanks Program for License Renewal Implementation
0
11
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
GGNS-ME-19-
00005
Engineering Report Review of the Buried Piping and
Tanks Inspection Program for License Renewal
Implementation
0
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-
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
0
N/A
Licensing Basis Document Change Request LBDCR-
2020-0027
04/08/2020
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
Protection Fluid
01/2020
N/A
Condition Report List - Penetration Seal Work
08/10/2020
Standard on Carbon Dioxide Extinguishing Systems
1973
12
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NFPA-12A
Standard on Halogenated Fire Extinguishing Agent
Systems Halon 1301
1973
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
OBS-2019-67673
CNS Fire Drill Observation
6/28/2019
PR-PRGGN-
2019-01617
Procedure Request PR-PRGGN-2019-01617
PR-PRGGN-
2020-00942
Procedure Request PR-PRGGN-2020-00942
PR-PRGGN-
2020-01018
Procedure Request PR-PRGGN-2020-01018
Operability
Evaluations
Corrective Action Program
42
Procedures
04-1-01-P64-3
Fire Protection Cardox System
028
04-1-02-1H13-
P870
Alarm Response Instruction, Panel No.: 1H13-P870
160
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-
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
13
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
06-EL-SP64-R-
0005-01
111' Control Building CO2 System Panel N1P64D207
Timing Relay Calibration and Functional Test
102
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
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
112
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
112
06-OP-SP64-W-
0045
Weekly Fire Door Check
118
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
14
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Fire Protection Impact Reviews
13
Process Applicability Determination
029
10 CFR 50.59 Evaluations
20
Conduct of Operations
028
Fire Brigade Drills
010
SEP-FPP-GGN-
001
Grand Gulf Nuclear Station Fire Protection Plan
1
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
52259153
06OPSP64-R-0049-07 Fire Rated Sealed Penetrations
Visual Ins
10/06/2015
52655775
06OPSP64-R-0049-02 Fire Rated Sealed Penetrations
Visual Ins
07/01/2017
52716253
06ELSP64-R-0005-01 D207**CNTL BLDG DIV 1 SWGR
ROOM**
01/25/2018
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
BLDG 1
08/21/2018
52805223
06ELSP64-R-0005-01 D207 CNTL BLDG DIV 1 SWGR
RM **DIV 1**
03/20/2019
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
INSPECTION (21 TOTAL )
03/13/2018
52848954
06ELSP64-R-0003-01 1P64D200A**DIV 1 SE SWGR RM
119' A-7
05/16/2020
52850968
06OPSP64-R-0048-06 VISUAL INSPECTION OF FIRE
WRAPPED RACEWAY
05/14/2020
15
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
52859363
06OPSP64-R-0049-01 FIRE RATED SEALED
PENETRATIONS VISUAL INS
06/25/2020
52935304
06OPSP64-M-0043 FIRE DOORS ALARM CHECK
07/30/2020