ML20338A271

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Triennial Fire Protection Inspection Report 05000416/2020013 and Notice of Violation
ML20338A271
Person / Time
Site: Grand Gulf Entergy icon.png
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

ML20338A271

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

NOV 05000416/2020013-01 5

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

NOV 05000416/2020013-01

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

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.

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