What version of Ubuntu was he installing? GRUB is supposed to work fine
on XFS these days, and it certainly isn't restricted to just ext[234].
The reason you didn't find any documentation about prerequisite
filesystems is that there aren't supposed to be any. :-)

** Package changed: ubiquity (Ubuntu) => grub-installer (Ubuntu)

** Changed in: grub-installer (Ubuntu)
       Status: New => Incomplete

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Installing Ubuntu with manual partition allows grub-incompatible filesystems on 
/boot
https://bugs.launchpad.net/bugs/438246
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