IR 05000445/2020011
| ML22034A825 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/07/2022 |
| From: | Alexandra Siwy Division of Reactor Safety IV |
| To: | Peters K Vistra Operations Company |
| References | |
| IR 2020011 | |
| Download: ML22034A825 (17) | |
Text
February 7, 2022
SUBJECT:
AMENDED - COMANCHE PEAK NUCLEAR POWER PLANT - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000445/2020011 AND 05000446/2020011 AND NOTICE OF VIOLATION
Dear Mr. Peters:
The NRC is issuing this revision to the subject report to accurately reflect the number of samples that were performed under Inspection Procedure 71111.21N.05, Section 03.01 contained in NRC Inspection Report 05000445/2020011 AND 05000446/2020011, dated September 21, 2020 (ADAMS Accession No. ML20265A042). This section of the original report indicated that two partial samples and four complete samples were documented. This section has been amended to indicate that four partial and zero complete samples were documented.
On August 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant and discussed the results of this inspection with Mr. T. McCool, Site Vice President, 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. We determined that this violation did not meet the criteria to be treated as a non-cited violation because your staff did not restore compliance within a reasonable period of time after a violation was previously identified by the NRC as NCV 05000445/2017008-01; 05000446/2017008-01.
The NRC has concluded that information regarding: (1) the reason for the violations; (2) the corrective actions that have been taken and the results achieved; and (3) the date when full compliance was achieved is already adequately addressed on the docket in the inspection report (Enclosure 2). Therefore, you are not required to respond to this letter unless the record does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the Notice of Violation (Enclosure 1).
If you contest the violation or the significance or severity of the violation documented in this inspection report, 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 Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Comanche Peak Nuclear Power Plant.
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 Comanche Peak Nuclear Power Plant.
This letter, its enclosures, and your response (if any) 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, Signed by Siwy, Andrew on 02/07/22 Andrew D. Siwy, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 05000445 and 05000446 License Nos. NPF-87 and NPF-89
Enclosures:
1. Notice of Violation 2. Inspection Report
ML22034A825 X SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: ADS X Yes No X Non-Sensitive X Publicly Available NRC-002 OFFICE DRP:C/PBB DRS:C/EB2 NAME GEWerner ADSiwy SIGNATURE GEW ADS DATE 02/07/2022 2/7/2022
NOTICE OF VIOLATION Vistra Operations Company LLC Docket Nos.: 05000445 and 05000446 Comanche Peak Nuclear Power Plant, License Nos.: NPF-87 and NPF-89 Units 1 and 2 During an NRC inspection completed on August 27, 2020, a violation of NRC requirements was identified. In a
Inspection Report
Docket Numbers: 05000445 and 05000446 License Numbers: NPF-87 and NPF-89 Report Numbers: 05000445/2020011 and 05000446/2020011 Enterprise Identifier: I-2020-011-0039 Licensee: Vistra Operations Company LLC Facility: Comanche Peak Nuclear Power Plant Location: Glen Rose, Texas Inspection Dates: June 8, 2020 to August 27, 2020 Inspectors: S. Alferink, Reactor Inspector J. Drake, Senior Reactor Inspector J. Mateychick, Senior Reactor Inspector 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 Comanche Peak Nuclear Power Plant, 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
Failure to Implement and Maintain Adequate Inspection Procedures for Penetration Sealing Devices Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green H.8 - Procedure 71111.21N.
Systems NOV 05000445;05000446/2020011-01 Adherence 05 Opened/Closed The team identified a Green violation of License Condition 2.G for the licensees failure to maintain adequate procedures for the inspection of penetration sealing devices as required by the licensees Fire Protection Report, Section IV-2.1.c.1. Specifically, the licensee implemented a revision to Fire Protection Procedure FIR-310, Penetration Seal Inspection, in 2020 to provide corrective actions for an NCV issued in 2017 due to the procedure not ensuring that all penetrations seals would be inspected during the required 15-year cycle.
However, the revised procedure incorrectly excluded from the inspection schedule all penetration seals in the auxiliary building.
Additional Tracking Items
None
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
===71111.21N.05 - Fire Protection Team Inspection (FPTI) SSC Credited for Fire Prevention, Detection, Suppression, or Post-Fire SSD Review (IP Section 03.01) (4 Partial Samples)
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA). All sections of 03.01 were completed for the following samples except subsections b and e.
Subsection b states Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA)analysis and SSA. Subsection e states Perform a walkdown inspection to identify equipment alignment discrepancies. Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation. Due to conditions related to COVID19 in the area of the licensee, onsite inspector walkdowns of procedures with licensee operations personnel could not be performed at this time. An inspector will visit the 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.
(1) (Partial)
The auxiliary feedwater system and the steam generator power-operated relief valves.
(2) (Partial)
The fire water system including the fire water tanks, fire pumps, and yard loop distribution piping system.
(3) (Partial)
The fire detection systems and fire suppression systems installed in Fire Area EN, Unit 1 Cable Spreading Room.
(4) (Partial)
The fire detection systems and fire suppression systems installed in Fire Area EM, Unit 2 Cable Spreading Room.
Fire Protection Program Administrative Controls (IP Section 03.02) ===
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees fire protection program contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
- (1) The inspectors reviewed the licensees administrative controls of hot work, transient combustibles, and fire impairments.
- (2) The inspectors reviewed the licensees fire brigade training program.
Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)
- (1) The inspectors reviewed changes to the approved fire protection program concerning the inspection of fire rated penetration sealing devices.
- (2) The inspectors reviewed the changes to the approved fire protection program incorporated into the Comanche Peak Nuclear Power Plant Fire Protection Report Units 1 and 2, Revision
INSPECTION RESULTS
Failure to Implement and Maintain Adequate Inspection Procedures for Penetration Sealing Devices Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green H.8 - Procedure 71111.21N.0 Systems NOV 05000445; 05000446/2020011- Adherence 5 Opened/Closed The team identified a Green violation of License Condition 2.G for the licensees failure to maintain adequate procedures for the inspection of penetration sealing devices as required by the licensees Fire Protection Report, Section IV-2.1.c.1. Specifically, the licensee implemented a revision to Fire Protection Procedure FIR-310, Penetration Seal Inspection, in 2020 to provide corrective actions for an NCV issued in 2017 due to the procedure not ensuring that all penetrations seals would be inspected during the required 15-year cycle.
However, the revised procedure incorrectly excluded from the inspection schedule all penetration seal devices in the auxiliary building.
Description:
During the 2017 triennial fire protection inspection, the NRC identified a Green non-cited violation for the failure to maintain adequate procedures for the inspection of fire penetration seals. As part of this violation, the NRC noted that the licensee used an automated random sampling process for selection of penetration seals for inspection and this process failed to ensure that all required penetration seals were inspected within their 15-year sampling plan interval.
The team documented this violation as NCV 05000445/2017008-01; 05000446/2017008-01, Failure to Implement and Maintain Adequate Inspection Procedures for Penetration Sealing Devices, on July 31, 2017. The licensee documented this issue in the corrective action program in Condition Report CR-2017-007746.
In response to this violation, the licensee generated a list of over 16,000 fire penetration seals that required inspection. The licensee divided this list into different groups based on the penetration seal location. The licensee associated these groups with 15 repetitive preventive maintenance tasks. The licensee then updated Procedure FIR-310, Penetration Seal Inspection, to require the inspection of penetration seals using one of these 15 preventive maintenance tasks each year over a 15-year period, thereby ensuring that each penetration seal would be inspected once during the 15-year period. The licensee revised this procedure on February 6, 2020.
During the current inspection, the team reviewed the revised inspection procedure and the repetitive preventive maintenance tasks. The team identified that the fire penetration seal group associated with the auxiliary building was not included in any of the 15 repetitive preventive maintenance tasks. This group contained 1,956 penetration seals. Since this group was not included in any of the 15 preventive maintenance tasks, the team determined that these 1,956 penetration seals were not scheduled to be inspected during the current 15-year period.
In response to the teams questions, the licensee reviewed the previous fire penetration seal inspections for the penetration seals associated with the auxiliary building. The licensee identified that 1,192 of the penetration seals were inspected and 764 of the penetration seals were not inspected during the previous 15-year period. Of the penetration seals that were inspected, the licensee determined that only two of them failed the inspection.
Corrective Actions: There was no immediate safety concern since the licensee had observed a very low failure rate of penetration seals during the previous 15-year cycle. The licensee entered this issue into the corrective action program for resolution and incorporated the auxiliary building penetration seals into eight of the preventive maintenance tasks required by procedure FIR-310. The licensee restored compliance with the approved fire protection program on June 25, 2020 and performed an Organizational Effectiveness Investigation to determine the cause of the violation. The licensee identified a lack of attention to detail and verbatim compliance with Procedure STA-422, Corrective Action Program, as causes. The verification of the lists of penetration seals to be inspected was not completed and was transferred to future actions. This was not in compliance with Procedure STA-442, Section 6.6, Condition Report Closure to Future Actions, which states that when the condition report documents a Licensing Basis Deviation the condition report may not close to future actions. The licensee provided coaching for the personnel involved.
Corrective Action References: Condition Report CR-2020-004473
Performance Assessment:
Performance Deficiency: The failure to ensure that fire protection program procedures used to establish inspection criteria for penetration sealing devices appropriately captured all required penetration sealing devices for visual inspection using a site approved sampling plan 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 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 inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The team assigned the fire confinement category to the finding since it involved fire rated penetration seals. The team noted that the licensee observed a very low failure rate of the auxiliary building penetration seals during the past 15 years.
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 assigned a low degradation rating to the finding because of the very low failure rate and the fact that a majority of the auxiliary building penetration seals have been previously inspected.
The team determined the finding was of very low risk significance (Green) in Step 1.3 since the finding was assigned a low degradation rating.
H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions.
Specifically, the licensee failed to complete required verifications of corrective actions to assure adequacy.
Enforcement:
Violation: License Condition 2.G for Unit 1 requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 78 and as approved in the Safety Evaluation Report and its supplements through Supplement 24.
License Condition 2.G for Unit 2 requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 87 and as approved in the Safety Evaluation Report and its supplements through Supplement 27.
The Fire Protection Report was included as part of the licensees approved fire protection program for both units, and states, in part, that administrative control of the fire protection program is provided through station procedures to assure that the fire protection equipment and systems are operable and properly maintained. This includes periodic tests and inspections, compensatory measures concerning items which may be inoperable, and quality assurance audits. Section IV-2.1.c.1 of the Fire Protection Report required, in part, that the required fire rated assemblies and penetration sealing devices are confirmed operable by visually inspecting the exposed surfaces using a site approved sampling plan every 18 months.
Contrary to this requirement, from 2009 to June 25, 2020, the licensee failed to ensure that fire protection program procedures used to establish inspection criteria for penetration sealing devices appropriately captured all required penetration sealing devices for visual inspection using a site approved sampling plan every 18 months. Specifically, Procedure FIR-310, Penetration Seal Inspection, revised in response to NCV 05000445/2017008-01; 05000446/2017008-01, Failure to Implement and Maintain Adequate Inspection Procedures for Penetration Sealing Devices, did not ensure that all required penetration sealing devices would be inspected within the licensees sampling plan interval. Consequently, the licensee failed to restore compliance to the previous NCV since the revised procedure did not ensure the fire rated penetration seals in the auxiliary building were included in the maintenance list so they would be scheduled for inspection.
Enforcement Action: This violation is being cited because the licensee failed to restore compliance after the violation was previously 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 June 25, 2020, the inspectors presented the triennial fire protection inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff in a debrief meeting.
On August 27, 2020, the inspectors presented the triennial fire protection inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff in an exit meeting.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N.05 Calculations 0210-063-0031 Unit 1 and Common Hydraulic Calculation Verification 1
Calculations 2-FP-0006 Determination of the Pressure and Flow at the Fire Pump 1
Discharge
Calculations DBD-ME-003 Control Room Habitability 13
Calculations DBD-ME-027 Radiological Accident Analysis 13
71111.21N.05 Corrective Action CR-2010-004331 CR-2013-001933 CR-2015-004590
Documents CR-2016-002210 CR-2017-001410 CR-2017-001552
CR-2017-002011 CR-2017-002035 CR-2017-003949
CR-2017-004235 CR-2017-004324 CR-2017-004560
CR-2017-004691 CR-2017-007536 CR-2017-007745
CR-2017-007746 CR-2017-008728 CR-2017-008890
CR-2017-008961 CR-2018-006426 CR-2018-007079
CR-2018-007442 CR-2018-008405 CR-2019-003625
CR-2019-005334 CR-2019-009310 CR-2020-000558
CR-2020-000864 CR-2020-001701 CR-2020-002817
CR-2020-003204 TR-2014-010354 TR-2014-010370
TR-2014-012160 TR-2016-003548 TR-2017-003590
TR-2017-008741 TR-2017-012520 TR-2018-006427
TR-2019-003269 TR-2020-000040 TR-2020-001999
TR-2020-004586 TR-2917-009888
71111.21N.05 Corrective Action CR-2020-004397 CR-2020-004473 IR-2020-004760
Documents
Resulting from
Inspection
71111.21N.05 Fire Plans FPI - 504 Electrical & Control Building Elevation 807-0 1
Unit 2 Cable Spreading Room
Fire Plans FPI - 505 Electrical & Control Building 3
Unit 1 Cable Spreading Room Elevation 807-0
71111.21N.05 Miscellaneous Comanche Peak Nuclear Power Plant Fire Protection 32 & 33
Report Unit 1 and Unit 2
Miscellaneous Comanche Peak Fire PRA Summary 1
Miscellaneous AO5407 Response to Fire in the Control Room or Cable Spreading 02/21/03
Inspection Type Designation Description or Title Revision or
Procedure Date
Room, Perform AO #1 Actions
Miscellaneous 20023 Transient Combustible Permit 0
Miscellaneous 20060 Transient Combustible Permit 0
Miscellaneous 20079 Transient Combustible Permit 0
Miscellaneous 20085 Transient Combustible Permit 0
Miscellaneous 20088 Transient Combustible Permit 0
Miscellaneous 2323-AS-18 Specification Hollow Metal Doors and Frames 1
Miscellaneous 5527599 Fire Permit 0
Miscellaneous 5563972 Fire Permit 0
Miscellaneous 5595567 Fire Permit 0
Miscellaneous 5611222 Fire Permit 0
Miscellaneous 5832506 Fire Permit 0
Miscellaneous AO6413 Response to fire in Control Room or Cable spreading 13
room
Miscellaneous AO6414 Response to a fire in the Control Room or Cable 12/19/01
Spreading Room opening pressurizer PORV MOV 8000A
Miscellaneous AO6415 Align Alternate Auxiliary Feedwater Supply from Station
Miscellaneous DBD-ME-001 CPSES Fire Protection Program Design Basis Document 12
Miscellaneous DBD-ME-225 Fire Suppression System 27
Miscellaneous FB44.FBR.193 FBR - 2019 Live Fire Requal Training 0
Miscellaneous FB44FBR196 FBR - 2020 Live Fire Requal Training 0
Miscellaneous FBD2FBI103 Portable Fire Extinguishers 1 0
Miscellaneous FBD2FBI107 Fire Hose 0
Miscellaneous FBD2FBI108 Fire Streams and Nozzles 0
Miscellaneous FBD2FBI109 Hoselines and Master Streams 0
Miscellaneous FBD2FBI201 Personal Protective Equipment (Fire Brigade) 0
Miscellaneous FBD2FBI204 Search and Rescue 0
Miscellaneous FBD2FBI207 Handling Hoselines 0
Miscellaneous FBD2FBI208 Foam Operations (Fire Brigade) 0
Miscellaneous FBDSFBI102 Combustion and Fire Behavior 0
Miscellaneous Final Safety Emergency Planning Amendment
Analysis Report No. 109
Inspection Type Designation Description or Title Revision or
Procedure Date
Section 13.3
Miscellaneous Final Safety Fire Protection Program Amendment
Analysis Report No. 109
Section 9.5.1
Miscellaneous OER-2017- IER L4-17-6 Fire Event Trend and Causes 06/13/17
007276
Miscellaneous OER-2017- NRC IN-2917-04 High Energy Arching Faults In Electrical 08/29/17
009751 Equipment Containing Aluminum Components
Miscellaneous OER-2018- NRC Information Notice 2018-09; Electrical Arc Flash 09/20/18
006316 Caused by Foreign Material Damages Fire Door
Miscellaneous RO4406 Respond To Fire In Control Room Or Cable Spread Room 08/31/08
71111.21N.05 Procedures ABN-803A Response To A Fire In The Control Room Or Cable 13
Spreading Room
Procedures ABN-803B Response To A Fire In The Control Room Or Cable 10
Spreading Room
Procedures ABN-804A Response To Fire In The Safeguards Building 6
Procedures ABN-804B Response To Fire In The Safeguards Building 4
Procedures ABN-805A Response To Fire In The Auxiliary Building Or The Fuel 8
Building
Procedures ABN-805B Response To Fire In The Auxiliary Building Or The Fuel 8
Building
Procedures ABN-806A Response To Fire In The Electrical And Control Building 8
Procedures ABN-806B Response To Fire In The Electrical And Control Building 6
Procedures ABN-807A Response To Fire In The Containment Building 8
Procedures ABN-807B Response To Fire In The Containment Building 6
Procedures ABN-808A Response To Fire In Service Water Intake Structure 6
Procedures ABN-808B Response To Fire In Service Water Intake Structure 4
Procedures ABN-809A Response To Oil Leak Or Fire In The Turbine Building 8
Procedures ABN-809B Response To Oil Leak Or Fire In The Turbine Building 5
Procedures ABN-901 Fire Protection System Alarms or Malfunctions 9
Procedures FBD2FBI104 Portable Fire Extinguishers 2 0
Procedures FBD2ICS111 Incident Management 0
Procedures FIR-201 Preparation, Control, Review and Use of Fire Preplan 9
Inspection Type Designation Description or Title Revision or
Procedure Date
Instructions
Procedures FIR-302 Fire Door Tests and Inspections 8
Procedures FIR-308 Fire Brigade Equipment 4
Procedures FIR-310 Penetration Seal Inspection 4
Procedures FIR-PX-3200 Fire Suppression Loop Flow Test 3
Procedures FIR-PX-3801 Electric Driven Fire Protection Pump CPX-FPAPFP-04 4
Operability Test
Procedures FIR-PX-3802 Diesel Driven Fire Protection Pump CPX-FPAPFP-05 4
Operability Test
Procedures FIR-PX-3803 Diesel Driven Fire Protection Pump CPX-FPAPFP-06 4
Operability Test
Procedures INC-3020 Maintenance and Rework of Plant Doors 2
Procedures OPT-220 Fire Suppression Water System Operability Test 13
Procedures STA-202 Nuclear Generation Procedure Change Process 39
Procedures STA-421 Control of Issue Reports 21
Procedures STA-422 Corrective Action Program 34
Procedures STA-602 Temporary Modifications and Transient Equipment 20
Placements
Procedures STA-716 Modification Process 27
Procedures STA-722 Fire Protection Program 7
Procedures STA-723 Fire Protection Systems/Equipment Requirements 5
Procedures STA-724 Fire Reporting and Response 4
Procedures STA-727 Fire Brigade 6
Procedures STA-729 Control of Transient Combustibles, Ignition Sources and 12
Fire Watches
Procedures STA-738 Fire Protection Systems/Equipment Impairments 7
Procedures STI-422.03 Performing Coaching and Investigations 2
Procedures STI-422.04 Processing of Condition Reports 0
Procedures STI-423.01 Processing Tracking Reports 0
Procedures TRA-104 Fire Protection Training 16
71111.21N.05 Self- EVAL-2018-010 Fire Protection Program 12/15/18
Assessments
Self- IR-2019-005207 Fire Protection Self-Assessment Report 0
Inspection Type Designation Description or Title Revision or
Procedure Date
Assessments
71111.21N.05 Work Orders 5209230, 5329355, 5511184, 5557316, 5558257,
5578521, 5655850, 5668385, 5747089, 5749736,
5757975, 5821733, 5840282, 5841173, 5856117,
5861142, 5920545
2