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| number = ML15120A570
| number = ML15120A570
| issue date = 04/30/2015
| issue date = 04/30/2015
| title = Seabrook Station, Unit 1 - NRC Integrated Inspection Report 05000443/2015001 (January 1 - March 31, 2015)
| title = NRC Integrated Inspection Report 05000443/2015001 (January 1 - March 31, 2015)
| author name = Dentel G T
| author name = Dentel G
| author affiliation = NRC/RGN-I/DRP/PB3
| author affiliation = NRC/RGN-I/DRP/PB3
| addressee name = Curtland D A
| addressee name = Curtland D
| addressee affiliation = NextEra Energy Seabrook, LLC
| addressee affiliation = NextEra Energy Seabrook, LLC
| docket = 05000443
| docket = 05000443
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter: April 30, 2015 Mr. Dean Curtland Site Vice President - Seabrook Station NextEra Energy Seabrook, LLC c/o Mr. Michael Ossing 626 Lafayette Rd. Seabrook, NH 03874
{{#Wiki_filter: UNITED STATES NUCLEAR REGULATORY COMMISSION


SUBJECT: SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION REPORT 05000443/2015001
==REGION I==
2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 April 30, 2015 Mr. Dean Curtland Site Vice President - Seabrook Station NextEra Energy Seabrook, LLC c/o Mr. Michael Ossing 626 Lafayette Rd.
 
Seabrook, NH 03874 SUBJECT: SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION REPORT 05000443/2015001


==Dear Mr. Curtland:==
==Dear Mr. Curtland:==
On March 31, 2015, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station, Unit No. 1. The enclosed inspection report documents the inspection results, which were discussed on April 16, 2015, with Mr. Ralph Dodds, Plant General Manager, and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliThe inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings were identified. In accordance with Title 10 of the Code of Federal Regulations lic Document Room or from the Publicly System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
On March 31, 2015, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station, Unit No. 1. The enclosed inspection report documents the inspection results, which were discussed on April 16, 2015, with Mr. Ralph Dodds, Plant General Manager, and other members of your staff.


Sincerely,/RA/ Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 50-443 License No: NPF-86  
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
 
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
 
Based on the results of this inspection, no findings were identified.
 
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,
/RA/
Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 50-443 License No: NPF-86


===Enclosure:===
===Enclosure:===
Inspection Report No. 05000443/2015001 w/  
Inspection Report No. 05000443/2015001 w/ Attachment: Supplemental Information


===Attachment:===
REGION I==
Supplemental Information cc w/encl: Distribution via ListServ
Docket No.: 50-443 License No.: NPF-86 Report No.: 05000443/2015001 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station, Unit No.1 Location: Seabrook, New Hampshire 03874 Dates: January 1, 2015 through March 31, 2015 Inspectors: P. Cataldo, Senior Resident Inspector C. Newport, Resident Inspector E. Burket, Emergency Preparedness Inspector Approved by: Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure


ML15120A570  SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME PCataldo /RSB for RBarkley/ RSB GDentel/ GTD DATE 04/30 /15 04/30 /15 04/30/ /15 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket No.: 50-443 License No.: NPF-86 Report No.: 05000443/2015001 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station, Unit No.1 Location: Seabrook, New Hampshire 03874 Dates: January 1, 2015 through March 31, 2015 Inspectors: P. Cataldo, Senior Resident Inspector C. Newport, Resident Inspector E. Burket, Emergency Preparedness Inspector Approved by: Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects 2 Enclosure
=SUMMARY=
IR 05000443/2015001; 01/01/2015-03/31/2015; Seabrook Station, Unit No. 1; Routine
 
Integrated Inspection Report.
 
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.


=SUMMARY=
No findings were identified.
IR 05000443/2015001; 01/01/2015-03/31/2015; Seabrook Station, Unit No. 1; Routine Integrated Inspection Report. This report covered a three-month period of inspection by resident inspectors and announced operation of commercial nuclear power reactors is described in NUREG-  No findings were identified.


=REPORT DETAILS=
=REPORT DETAILS=
Summary of Plant Status Seabrook operated at full power for the quarter, with the exception of a down-power to 94 percent on January 16, 2015, for performance of main turbine control valve testing. Documents reviewed for each section of this inspection report are listed in the Attachment.
 
===Summary of Plant Status===
 
Seabrook operated at full power for the quarter, with the exception of a down-power to 94 percent on January 16, 2015, for performance of main turbine control valve testing. Documents reviewed for each section of this inspection report are listed in the Attachment.


==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity  
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
{{a|1R01}}
{{a|1R01}}
==1R01 Adverse Weather Protection==
==1R01 Adverse Weather Protection==
{{IP sample|IP=IP 71111.01|count=2}}
{{IP sample|IP=IP 71111.01|count=2}}
Line 49: Line 69:


====a. Inspection Scope====
====a. Inspection Scope====
on January 8 to 9, 2015, and a winter storm on January 27 - 28, 2015. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during these adverse weather conditions. The inspectors walked down the essential switch gear and non-essential switch gear rooms, switch yard, cooling tower (CT) general area, supplemental emergency power system (SEPS), demineralized water tank, and the refueling water storage tank area to ensure system availability. The inspectors vmaintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.
The inspectors reviewed NextEras preparations and response to extreme cold weather on January 8 to 9, 2015, and a winter storm on January 27 - 28, 2015. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during these adverse weather conditions. The inspectors walked down the essential switch gear and non-essential switch gear rooms, switch yard, cooling tower (CT) general area, supplemental emergency power system (SEPS), demineralized water tank, and the refueling water storage tank area to ensure system availability. The inspectors verified that operator actions defined in NextEras adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1R04}}
{{a|1R04}}
==1R04 Equipment Alignment==
==1R04 Equipment Alignment==


Line 60: Line 79:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors performed partial walkdowns of the following systems:   'B' emergency feedwater (EFW) pump return to service on February 22, 2015   March 23, 2015 'A' emergency diesel generator (EDG) while 'B' EDG out of service for maintenance on March 31, 2015 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether NextEra staff had properly identified equipment issues and entered them into the corrective action program (CAP) for resolution with the appropriate significance characterization.
The inspectors performed partial walkdowns of the following systems:
          'B' emergency feedwater (EFW) pump return to service on February 22, 2015 A control building air handling system during B train filter maintenance on March 23, 2015
          'A' emergency diesel generator (EDG) while 'B' EDG out of service for maintenance on March 31, 2015 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether NextEra staff had properly identified equipment issues and entered them into the corrective action program (CAP)for resolution with the appropriate significance characterization.


====b. Findings====
====b. Findings====
Line 72: Line 93:


====b. Findings====
====b. Findings====
No findings were identified.  
No findings were identified. {{a|1R05}}
{{a|1R05}}
==1R05 Fire Protection==
==1R05 Fire Protection   Resident Inspector Quarterly Walkdowns==
 
{{IP sample|IP=IP 71111.05Q|count=5}}
Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that NextEra controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that NextEra controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.


'A' electrical tunnel east end (ET-F-1A-A) on February 4, 2015   'A' electrical tunnel west end (ET-F-1B-A) on February 9, 2015   PAB-F-2A-Z, PAB-F-2B-Z, PAB-F-2C-Z) on March 25, 2015 Non-essential switchgear (NES-F-1A-Z) on March 25, 2015 Control building battery room A/B/C/D (CB-F-1D-A, CB-F-1E-A, CB-F-1F-A, CB-F-1G-A) on March 30, 2015
'A' electrical tunnel east end (ET-F-1A-A) on February 4, 2015
          'A' electrical tunnel west end (ET-F-1B-A) on February 9, 2015 Primary auxiliary building 25 (PAB-F-2A-Z, PAB-F-2B-Z, PAB-F-2C-Z)on March 25, 2015 Non-essential switchgear (NES-F-1A-Z) on March 25, 2015 Control building battery room A/B/C/D (CB-F-1D-A, CB-F-1E-A, CB-F-1F-A, CB-F-1G-A) on March 30, 2015


====b. Findings====
====b. Findings====
No findings were identified.  
No findings were identified.
{{a|1R06}}
 
{{a|1R06}}
==1R06 Flood Protection Measures==
==1R06 Flood Protection Measures==
{{IP sample|IP=IP 71111.06|count=1}}
{{IP sample|IP=IP 71111.06|count=1}}
Line 90: Line 113:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if NextEra identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the mechanical penetration room to verify the adequacy of equipment seals located below the flood line, flood and water penetration seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.
The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if NextEra identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the mechanical penetration room to verify the adequacy of equipment seals located below the flood line, flood and water penetration seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.


====b. Findings====
====b. Findings====
No findings were identified.  
No findings were identified.
{{a|1R07}}
 
{{a|1R07}}
==1R07 Heat Sink Performance==
==1R07 Heat Sink Performance==
{{IP sample|IP=IP 71111.07A|count=1}}
{{IP sample|IP=IP 71111.07A|count=1}}


====a. Inspection Scope====
====a. Inspection Scope====
availability to perform its safety functions. The inspectors reviewed the design basis -13.
The inspectors reviewed the A EDG heat exchanger to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified NextEras commitments to NRC Generic Letter 89-13.


The inspectors reviewed results discussed results of the most recent inspection with NextEra staff. The inspectors also verified that NextEra initiated appropriate corrective actions for identified deficiencies.
The inspectors reviewed results of previous inspections of the A EDG heat exchanger, reviewed performance data obtained during recent operation of the A EDG heat exchanger, observed the most recent inspection of the A EDG heat exchanger, and discussed results of the most recent inspection with NextEra staff. The inspectors also verified that NextEra initiated appropriate corrective actions for identified deficiencies.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.


{{a|1R11}}
{{a|1R11}}
==1R11 Licensed Operator Requalification Program==
==1R11 Licensed Operator Requalification Program==
{{IP sample|IP=IP 71111.11Q|count=2}}
{{IP sample|IP=IP 71111.11Q|count=2}}
Line 113: Line 137:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors observed licensed operator simulator training on February 9, 2015, which included a steam generator tube rupture coincident with a loss of offsite power and the failure of select components to respond as required. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implement-tation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the unit supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
The inspectors observed licensed operator simulator training on February 9, 2015, which included a steam generator tube rupture coincident with a loss of offsite power and the failure of select components to respond as required. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures.
 
The inspectors assessed the clarity and effectiveness of communications, implement-tation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the unit supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.


===.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
===.2 Quarterly Review of Licensed Operator Performance in the Main Control Room===


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors observed general control room activities on January 12, 2015, reactor control systems being placed in manual by operators, and containment air handling fan swaps on February 18, 2015, and control room shift turnover on March 4, 2015. tandpipe fill operations, control board chart recorder paper change-out, and main unit generator EDG outage on March 31, 2015. During these control room observations, the inspectors verified that procedure use and adherence, general control room conduct, alarm response, test performance, and coordination of activities between work groups met established expectations and standards.
The inspectors observed general control room activities on January 12, 2015, reactor control systems being placed in manual by operators, and containment air handling fan swaps on February 18, 2015, and control room shift turnover on March 4, 2015.
 
Additionally, inspectors observed A' EDG operations, reactor coolant pump standpipe fill operations, control board chart recorder paper change-out, and main unit generator MVAR adjustment of line 369 on March 27, 2015, and general activities during the B EDG outage on March 31, 2015. During these control room observations, the inspectors verified that procedure use and adherence, general control room conduct, alarm response, test performance, and coordination of activities between work groups met established expectations and standards.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|1R12}}
 
{{a|1R12}}
==1R12 Maintenance Effectiveness==
==1R12 Maintenance Effectiveness==
===
{{IP sample|IP=IP 71111.12Q|count=2}}
{{IP sample|IP=IP 71111.12Q|count=2}}


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that NextEra was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by NextEra staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that NextEra staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that NextEra was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with 10 CFR 50.65 and verified that the (a)(2)performance criteria established by NextEra staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that NextEra staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.


Emergency air handling fan 5B bearing inspections on February 18, 2015 Primary close latch replacement activities associated with ABB breakers on March 9, 2015
Emergency air handling fan 5B bearing inspections on February 18, 2015 Primary close latch replacement activities associated with ABB breakers on March 9, 2015


====b. Findings====
====b. Findings====
No findings were identified.  
No findings were identified.
{{a|1R13}}
 
{{a|1R13}}
==1R13 Maintenance Risk Assessments and Emergent Work Control==
==1R13 Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13|count=5}}
{{IP sample|IP=IP 71111.13|count=5}}


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that NextEra performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that NextEra personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When NextEra performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stwere consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that NextEra performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that NextEra personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When NextEra performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.


Startup feed pump maintenance on January 20, 2015 'D' service water (SW) pump maintenance on February 3, 2015 Transfer to SW cooling tower (CT) operations on February 26, 2015 'A' EDG maintenance on March 9, 2015 'B' EDG maintenance on March 31, 2015
Startup feed pump maintenance on January 20, 2015
          'D' service water (SW) pump maintenance on February 3, 2015 Transfer to SW cooling tower (CT) operations on February 26, 2015
          'A' EDG maintenance on March 9, 2015
          'B' EDG maintenance on March 31, 2015


====b. Findings====
====b. Findings====
No findings were identified.  
No findings were identified.
{{a|1R15}}
 
{{a|1R15}}
==1R15 Operability Determinations and Functionality Assessments==
==1R15 Operability Determinations and Functionality Assessments==
{{IP sample|IP=IP 71111.15|count=5}}
{{IP sample|IP=IP 71111.15|count=5}}
Line 154: Line 187:
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Seismic supports for a SW pump and the control rod drive mechanisms, American Society of Mechanical Engineers, Section XI compliance, on February 19, 2015   Wetted insulation removal on RHR system piping on February 24, 2015 SEPS glycol level fluctuation on February 26, 2015   The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by NextEra. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
B SW discharge tubing support corrosion on January 15, 2015 Seismic supports for a SW pump and the control rod drive mechanisms, American Society of Mechanical Engineers, Section XI compliance, on February 19, 2015 Wetted insulation removal on RHR system piping on February 24, 2015 SEPS glycol level fluctuation on February 26, 2015 B vital battery cell cover cracks on March 30, 2015 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to NextEras evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by NextEra. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.


====b. Findings====
====b. Findings====
No findings were identified.  
No findings were identified.
{{a|1R18}}
 
{{a|1R18}}
==1R18 Plant Modifications==
==1R18 Plant Modifications==
{{IP sample|IP=IP 71111.18|count=1}}
{{IP sample|IP=IP 71111.18|count=1}}
Line 164: Line 198:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors evaluated a modification to install a primary chemistry zinc injection skid implemeinspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors conducted walkdowns and reviewed modification documents associated with the upgrade and design change, including associated engineering changes, calculations, communication with the vendor, and industry operating experience.
The inspectors evaluated a modification to install a primary chemistry zinc injection skid implemented by Engineering Change 280335, Primary System Zinc Addition. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors conducted walkdowns and reviewed modification documents associated with the upgrade and design change, including associated engineering changes, calculations, communication with the vendor, and industry operating experience.


====b. Findings====
====b. Findings====
No findings were identified.  
No findings were identified.
{{a|1R19}}
 
{{a|1R19}}
==1R19 Post-Maintenance Testing==
==1R19 Post-Maintenance Testing==
{{IP sample|IP=IP 71111.19|count=7}}
{{IP sample|IP=IP 71111.19|count=7}}


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.


Containment enclosure ventilation fan, EAH-FN-5B, vibration isolator replacement on January 6, 2015 RH-FCV-610 thermal overload protection relay replacement on January 13, 2015 on January 30, 2015 Emergency air handling fan, EAH-FN-5A, maintenance on February 19, 2015 -611 on February 24, 2015 Pressurizer backup heater supply breaker trip latch replacement on March 3, 2015 arch 18, 2015
Containment enclosure ventilation fan, EAH-FN-5B, vibration isolator replacement on January 6, 2015 RH-FCV-610 thermal overload protection relay replacement on January 13, 2015 B steam generator atmospheric steam dump supply air solenoid valve replacement on January 30, 2015 Emergency air handling fan, EAH-FN-5A, maintenance on February 19, 2015 Replacement of B RHR flow switch F-611 on February 24, 2015 Pressurizer backup heater supply breaker trip latch replacement on March 3, 2015 A EDG temperature control valve rebuild on March 18, 2015


====b. Findings====
====b. Findings====
No findings were identified.  
No findings were identified.
{{a|1R22}}
 
{{a|1R22}}
==1R22 Surveillance Testing==
==1R22 Surveillance Testing==
{{IP sample|IP=IP 71111.22|count=7}}
{{IP sample|IP=IP 71111.22|count=7}}


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and NextEra procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:   'A' SW CT agastat relay time delay testing on January 15, 2015 'A' solid state protection system Mode 1 actuation logic test on January 22, 2015 'A' SW valve quarterly in-service test on February 10, 2015 (IST) Auctioneered reactor coolant system average temperature calibration on February 18, 2015 SEPS monthly availability surveillance on March 23, 2015 surveillance testing on March 24, 2015 RCS steady state leak rate calculation on March 27, 2015 (RCS)
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and NextEra procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
          'A' SW CT agastat relay time delay testing on January 15, 2015
          'A' solid state protection system Mode 1 actuation logic test on January 22, 2015
          'A' SW valve quarterly in-service test on February 10, 2015 (IST)
Auctioneered reactor coolant system average temperature calibration on February 18, 2015 SEPS monthly availability surveillance on March 23, 2015 B train emergency cleanup filter surveillance testing on March 24, 2015 RCS steady state leak rate calculation on March 27, 2015 (RCS)


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.


===Cornerstone:===
===Cornerstone: Emergency Preparedness===
Emergency Preparedness
 
{{a|1EP4}}
{{a|1EP4}}
==1EP4 Emergency Action Level and Emergency Plan Changes==
==1EP4 Emergency Action Level and Emergency Plan Changes==
Line 201: Line 241:


====b. Findings====
====b. Findings====
No findings were identified.  
No findings were identified.
{{a|1EP6}}
 
{{a|1EP6}}
==1EP6 Drill Evaluation==
==1EP6 Drill Evaluation==
{{IP sample|IP=IP 71114.06|count=1}}
{{IP sample|IP=IP 71114.06|count=1}}
Line 208: Line 249:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors observed a simulator training evolution for licensed operators on February 9, 2015 which required emergency plan implementation by an operations crew. NextEra planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post- performance and ensure that NextEra evaluators noted the same issues and entered them into the CAP.
The inspectors observed a simulator training evolution for licensed operators on February 9, 2015 which required emergency plan implementation by an operations crew.
 
NextEra planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that NextEra evaluators noted the same issues and entered them into the CAP.


====b. Findings====
====b. Findings====
Line 217: Line 260:
==4OA1 Performance Indicator Verification==
==4OA1 Performance Indicator Verification==
{{IP sample|IP=IP 71151}}
{{IP sample|IP=IP 71151}}
Unplanned Scrams, Unplanned Power Changes, and Unplanned Scrams with Complications (3 samples)
Unplanned Scrams, Unplanned Power Changes, and Unplanned Scrams with
 
===Complications (3 samples)===


====a. Inspection Scope====
====a. Inspection Scope====
Cornerstone performance indicators for the period of January 1, 2014 to December 31, 2014:   Unplanned scrams per 7,000 critical hours (IE01) Unplanned power changes per 7,000 critical hours (IE03) Unplanned scrams with complications (IE04) To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02,   The inspectors submittals, and NRC integrated inspection reports to validate the accuracy of the submittals.
The inspectors reviewed NextEras submittals for the following Initiating Events Cornerstone performance indicators for the period of January 1, 2014 to December 31, 2014:
Unplanned scrams per 7,000 critical hours (IE01)
Unplanned power changes per 7,000 critical hours (IE03)
Unplanned scrams with complications (IE04)
To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed NextEras operator narrative logs, event reports, performance indicator submittals, and NRC integrated inspection reports to validate the accuracy of the submittals.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|4OA2}}
{{a|4OA2}}
==4OA2 Problem Identification and Resolution==
==4OA2 Problem Identification and Resolution==
{{IP sample|IP=IP 71152}}
{{IP sample|IP=IP 71152}}
Line 230: Line 278:


====a. Inspection Scope====
====a. Inspection Scope====
the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that NextEra entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended condition report screening meetings.
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that NextEra entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended condition report screening meetings.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|4OA5}}
==4OA5 Other Activities==
Administrative Corrections to NRC Integrated Inspection Report 05000443/2014005 Two samples associated with section 1R12, Maintenance Effectiveness, inspections of
: (1) MR program assessment on November 20, 2014, and
: (2) cumulative review of breaker maintenance and retests on December 8, 2014, were inadvertently omitted from the final inspection report issued February 6, 2015.
One sample associated with section 1R19, Post-Maintenance Testing, inspection of safety injection pump 6A static baker testing on September 9, 2014, was included in error in the final inspection report issued February 6, 2015.


{{a|4OA5}}
==4OA5 Other Activities==
Administrative Corrections to NRC Integrated Inspection Report 05000443/2014005  Two samples associated with section 1R12, Maintenance Effectiveness, inspections of  (1) MR program assessment on November 20, 2014, and (2) cumulative review of breaker maintenance and retests on December 8, 2014, were inadvertently omitted from the final inspection report issued February 6, 2015. One sample associated with section 1R19, Post-Maintenance Testing, inspection of safety injection pump 6A static baker testing on September 9, 2014, was included in error in the final inspection report issued February 6, 2015.
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==
On April 16, 2015, the inspectors presented the inspection results to Mr. Ralph Dodds, Plant General Manager, and other members of the Seabrook Station staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
On April 16, 2015, the inspectors presented the inspection results to Mr. Ralph Dodds, Plant General Manager, and other members of the Seabrook Station staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.


Line 249: Line 303:


===Licensee Personnel===
===Licensee Personnel===
: [[contact::D. Curtland]], Site Vice President  
: [[contact::D. Curtland]], Site Vice President
: [[contact::R. Dodds]], Plant General Manager  
: [[contact::R. Dodds]], Plant General Manager
: [[contact::V. Brown]], Senior Licensing Engineer  
: [[contact::V. Brown]], Senior Licensing Engineer
: [[contact::D. Currier]], Emergency Planning Manager  
: [[contact::D. Currier]], Emergency Planning Manager
: [[contact::K. Douglas]], Maintenance Director  
: [[contact::K. Douglas]], Maintenance Director
: [[contact::D. Flahardy]], Radiation Protection Manager  
: [[contact::D. Flahardy]], Radiation Protection Manager
: [[contact::M. Haidul]], Nuclear Engineer  
: [[contact::M. Haidul]], Nuclear Engineer
: [[contact::M. Ossing]], Licensing Manager  
: [[contact::M. Ossing]], Licensing Manager
: [[contact::D. Ritter]], Site Operations Director  
: [[contact::D. Ritter]], Site Operations Director
: [[contact::D. Robinson]], Chemistry Manager  
: [[contact::D. Robinson]], Chemistry Manager
 
==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED==
==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED==


===Opened/Closed===
===Opened/Closed===
None 
===Opened===
None 
===Closed===
: None 
==LIST OF DOCUMENTS REVIEWED==
==Section 1R01: Adverse Weather Protection==


===Procedures===
None
: OS1200.03, Severe Weather Conditions, Revision 23 ON1090.13, Response to Natural Phenomenon Affecting Plant Operations, Revision 5
===Condition Reports===
: 02011269
: 02016967
: 02020857
: 02020958
: 02021079
: 02021083
: 02021095
: 02021161 02022287


==Section 1R04: Equipment Alignment==
===Opened===


===Procedures===
None
: LS0569.20, Lubrication PM and Starter Inspection for Motor Operated Valve Actuators,
: Revision 8 OS1013.03, Residual Heat Removal Train A Startup and Operation, Revision 27 OS1013.04, Residual Heat Removal Train B Startup and Operation, Revision 25 OS1023.74, Maintenance of Safety Related HVAC Systems
: Compensatory Ventilation
: Procedure, Revision 15 
: Attachment OS1026.01, Operation of
: DG-1A, Revision 23 OS1036.01, Aligning the Emergency Feedwater System for Automatic Initiation, Revision 18 OX1436.03, Electric EFW Pump Quarterly, 18 Month/30 Days Cold Shutdown and
: Comprehensive Pump Tests, and Monthly Valve Verification Surveillance, Revision 18
===Condition Reports===
: 01647943
: 02027144
: 02027306
: 02031628
: 02031702*
: 02032234
: 02034415
: 02036697
: 02036700*
: 02036817*
: Maintenance Orders/Work Orders
: 40078054
: 40103650
: 40348654
: 40355801
===Miscellaneous===
: Seabrook Station Updated Final Safety Analysis Report, Revision 16
===Drawings===
: 1-CBA-B20304, Control Building Air Handling Mechanical Room Elevation -
: Revision 17 1-NHY-310887, Sheet B59b,
: RH-E-9B to SI PP ISO VALVE 1-V-35, Revision 8 1-NHY-310887, Sheet B66b,
: RH-E-9B to SI PP ISO VALVE 1-V-36, Revision 7


==Section 1R05: Fire Protection==
===Closed===


===Procedures===
None
: SSFP, Fire Protection Manual, Revision 37
===Condition Reports===
: 02023318*
: 02036220
: 02036466
: Maintenance Orders/Work Orders
: 40201248
: 94115852
===Miscellaneous===
: Seabrook Station Fire Protection Pre-Fire Strategies, Volume I,
: ET-F-1A-A Seabrook Station Fire Protection Pre-Fire Strategies, Volume I,
: ET-F-1B-A Seabrook Station Fire Protection Pre-Fire Strategies, Volume I,
: PAB-F-2A-Z Seabrook Station Fire Protection Pre-Fire Strategies, Volume I,
: PAB-F-2B-Z Seabrook Station Fire Protection Pre-Fire Strategies, Volume I,
: PAB-F-2C-Z Seabrook Station Fire Protection Pre-Fire Strategies, Volume II,
: NES-F-1A-Z
===Drawings===
: CB-F-1D-A, Control Building Switchgear Rooms Battery Room 1A, Train A, Revision 0


==Section 1R06: Flood Protection Measures==
==LIST OF DOCUMENTS REVIEWED==
 
===Condition Reports===
: 01655411
: 01686889
: 01754848
: 01901728
: 01923653
: 02010963
===Miscellaneous===
: TP-7, Seabrook Station Moderate Energy Line Break Study, Revision 5 Seabrook Station UFSAR, Revision 16 
: Attachment
===Drawings===
: PID-1-WLD-B20222, Waste Processing Liquid Drains Primary Auxiliary Building, Sheet 1 of 2, Revision 20
: PID-1-WLD-B20223, Waste Liquid Drains Primary Auxiliary Building, Sheet 2 of 2, Revision 13
 
==Section 1R07: Heat Sink Performance==
 
===Procedures===
: PEG-268, Heat Exchanger and NRC
: GL 89-13 Program, Revision 0
===Condition Reports===
: 01957744
===Miscellaneous===
: Heat Exchanger E-42A Non-Destructive Testing Preliminary Report dated March 11, 2015
 
==Section 1R11: Licensed Operator Requalification Program==
 
===Procedures===
: TR-AA-230-1003-F06, Simulator Exercise Guide, Revision 0
===Miscellaneous===
: Individual and Crew Simulator Evaluation Forms
 
==Section 1R12: Maintenance Effectiveness==
 
===Procedures===
: MA 9.2B, PM Technical Basis Template, Revision 8 ES1850.002, Vibration Program, Revision 3
: EQ 522-01-01, Environmental Qualification of Electrical Equipment, Revision 5
===Condition Reports===
: 00221826
: 01624211
: 01885474
: 01931532
: 01988737
: 02029647
: Maintenance Orders/Work Orders
: 40308863
===Miscellaneous===
: 10
: CFR 21.21(d)(3)(i) Notice of Deviation Regarding K-Line Circuit Breaker Secondary Close
: Latch, dated August 15, 2014 10
: CFR 21.21(d)(4) Notice of Deviation re. K-Line Circuit Breaker Primary Close Latch, dated
: November 25, 2013 Specification 9763.006-522-1, United Engineers & Constructors Specification for Cooling Units,
: Revision 8                       
: Attachment
 
==Section 1R13: Maintenance Risk Assessments and Emergent Work Control==
 
===Procedures===
: OP-AA-102-1003, Guarded Equipment, Revision 5
===Condition Reports===
: 02019670*
: 02021682
: Maintenance Orders/Work Orders
: 40279960
: 40299653
===Miscellaneous===
: Maintenance Rule a(4) Risk Profile for Work Week 1505-10 Maintenance Rule a(4) Risk Profile for Work Week 1510-03
: OP-AA-102-1003-F01, Guarded/Protected Equipment Work Approval Form, Revision 0
===Drawings===
: PID-1-FW-B20688, Emergency Feedwater System, Revision 20
 
==Section 1R15: Operability Determinations and Functionality Assessments==
 
===Procedures===
: EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 18
: EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 19 ON1061.01, Operation of SEPS, Revision 5 OX1461.03, SEPS Operational Readiness Status Surveillance, Revision 1
: PI-AA-104-1000, Corrective Action, Revision 2 SSFP, Fire Protection Manual, Revision 37
===Condition Reports===
: 00585511
: 00586876
: 01807257
: 01900764
: 01992648
: 02008094
: 02015018
: 02016670
: 02018848
: 02019331
: 02019419
: 02019420
: 02024277
: 02026569
: 02026570
: 02027196
: 02027246
: 02028651*
: 02030882
: Maintenance Orders/Work Orders
: 40268467
: 40308888
: 40369729
===Miscellaneous===
: 2004 ASME Boiler and Pressure Code, Section XI
===Drawings===
: 1-NHY-504607, I&C Supports, Notes and Details, Revision 0 1-NHY-300219, Service Environment Chart, Revision 28
 
==Section 1R18: Plant Modifications==
 
===Condition Reports===
: 02033817*           
: Attachment Miscellaneous
: EC 280335, Primary System Zinc Addition, Revision 3
: PE-07-42, Zinc Implementation Risk Assessment, Revision 2 Westinghouse Chemistry and Materials Input for Seabrook Zinc Addition 10CFR50.59
: Documentation dated September 24, 2014 Westinghouse Nuclear Fuel Input to 10CFR50.59 Evaluation for Seabrook Unit 1 Zinc
: Injection Program dated May 8, 2014
===Drawings===
: PID-1-CS-B20720, Chemical and Volume Control System Zinc Addition, Revision 0
: PID-1-CS-B20725, Chemical and Volume Control Charging System Detail, Revision 31
: PID-1-SS-B20519, Sample System Primary Sample Panel, Revision 11
 
==Section 1R19: Post-Maintenance Testing==
 
===Procedures===
: IS0603.005, Equipment Qualification for ASCO Solenoid Valves, Revision 11 IS1664.111,
: RH-F-611,
: RH-P-8B Discharge Flow Indication Calibration, Revision 4 LS0569.20, Lubrication PM and Starter Inspection for Motor Operated Valve Actuators,
: Revision 8 LX0557.03, Thermal Overload Protection Relay Replacement for Motor Operated Valves,
: Revision 12 MS0517.11, HVAC Duct Repair, Fabrication and Installation, Revision 6 MS0519.42, Robertshaw 3-Way Temperature Control Valve Maintenance, Revision 10 MX0539.42, Emergency Diesel Generator Post Maintenance Testing (Power Cylinder Run In),
: Revision 4 OS1026.08, DG1A Maintenance Starting, Revision 17 OS1423.09, Containment Enclosure Cooling System 31 Day Surveillance, Revision 7
: OX1413.01, A Train RHR Quarterly Flow and Valve Stroke Test and 18 Month Valve Stroke
: Observation, Revision 20 OX1456.81, Operability Testing of IST Valves, Revision 21
===Condition Reports===
: 01836523
: 02016679
: 02018161
: 02026717
: 02027947
: 02031368
: Maintenance Orders/Work Orders
: 40209102
: 40279978
: 40289590
: 40302326
: 40305034
: 40309422
: 40310432
: 40355801
: 40362902
: 40374839
===Miscellaneous===
: 97-0048, Metrology Laboratory Evaluation, Revision 4 Fairbanks Morse Service Information Letter, PC Series, Volume C, Issue 17, Revision 3
: FP 73297, Model 581A-0 Differential Pressure Indicating Switch Installation and Operation
: Manual, Revision 0
===Drawings===
: 1-MAH-B20495, Miscellaneous Air Handling, PAB & Containment Enclosure Ventilation Area
: Detail, Revision 18 1-MS-B20581, Main Steam System Headers Detail, Revision 12 1-NHY-250000, Data Sheet
: RH System, Revision 79 1-RH-B20662, Residual Heat Removal System, Train A, Revision 17 
: Attachment
 
==Section 1R22: Surveillance Testing==
 
===Procedures===
: IS1662.496,
: RC-T-412T, Auctioneered Average Tave Calibration, Revision 10 IX1680.931, Solid State Protection System Train A Mode 1 Actuation Logic Test, Revision 3 LS0550.09, Timing Relay Acceptance Testing and Maintenance Program, Revision 16 LS0563.11, Testing of Agastat 125VDC (7000 Series) TDPU Timing Relays, Revision 7 OS1001.04, RCS Unidentified Leak Rate Action Level Exceedance, Revision 0 OX1401.02, RCS Steady State Leakage Calculation, Revision 9 OX1416.04, Service Water Quarterly Pump and Discharge Valve Test and Comprehensive
: Pump Test, Revision 19 OX1416.10, Service Water Quarterly Valve Test, Revision 8 OX1423.27, Control Room Area Ventilation System Surveillance, Revision 5 OX1456.47, Train A ESFAS Slave Relay K615 Quarterly Go Test, Revision 8 OX1456.81, Operability Testing of IST Valves, Revision 21 OX1461.04, SEPS Monthly Availability Surveillance, Revision 9
===Condition Reports===
: 02015633
: 02017179
: 02018619
: 02027779
: 02034406*
: Maintenance Orders/Work Orders
: 40302133
: 40307350
: 40307354
: 40308859
: 40309425
: 40309976
: 40316104
: 40317214
: 40367811
: 40370055
: 94110550
===Miscellaneous===
: ASME OM Code-2004 PM Technical Basis, 1-RC-T-412-T-CAL-1-000, dated September 2003
===Drawings===
: 1-NHY-301107, Sheet E87, Service Water A Train Loop A Cooling Tower Actuation Signal,
: Revision 0 1-SW-B20794, Service Water System, Revision 36 1-SW-B20795, Service Water System, Revision 42
 
==Section 1EP4: Emergency Action Level and Emergency Plan Changes==
 
===Procedures===
: ER 1.2, Emergency Plan Activation, Revision 64 ER 5.4, Protective Action Recommendations, Revision 34
===Miscellaneous===
: Radiological Emergency Plan (SSREP), Revision 68
 
==Section 1EP6: Drill Evaluation==
 
===Procedures===
: EP-AA-101-1000, Nuclear Division Drill and Exercise Procedure, Revision 5 ER 1.1, Classification of Emergencies, Revision 52 ER 1.1, Classification of Emergencies, Revision 55 ER 1.2, Emergency Action Plan Activation, Revision 61 
: Attachment ER 2.0B, Seabrook Station State Notification Fact Sheet, Revision 31 ER 3.1, Technical Support Center Operations, Revision 53
===Miscellaneous===
: Form
: EPDP-03A, EP Cornerstone Reporting and Information Form, Revision 25
 
==Section 4OA1: Performance Indicator Verification==


===Procedures===
: NAP-206, NRC Performance Indicators, Revision 7
===Miscellaneous===
: LIC-15004, Documentation Supporting the Seabrook Station NRC 4th Quarter 2014
: Performance Indicator Submittal
: LIC-14039, Documentation Supporting the Seabrook Station NRC 3rd Quarter 2014
: Performance Indicator Submittal
: LIC-14031, Documentation Supporting the Seabrook Station NRC 2nd Quarter 2014
: Performance Indicator Submittal
: LIC-14018, Documentation Supporting the Seabrook Station NRC 1st Quarter 2014
: Performance Indicator Submittal
: NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7  *NRC Identified
==LIST OF ACRONYMS==
: [[ADAMS]] [[Agencywide Document Access and Management System]]
: [[CAP]] [[corrective action program]]
: [[CFR]] [[Code of Federal Regulations]]
: [[CR]] [[condition report]]
: [[CT]] [[cooling tower]]
: [[EAL]] [[emergency action level]]
: [[EDG]] [[emergency diesel generator]]
: [[EFW]] [[emergency feedwater]]
: [[MR]] [[maintenance rule]]
: [[NRC]] [[Nuclear Regulatory Commission]]
: [[RHR]] [[residual heat removal]]
: [[SEPS]] [[supplemental emergency power system]]
: [[SSC]] [[structure, system, and component]]
: [[SW]] [[service water]]
: [[TS]] [[technical specification]]
: [[UFSAR]] [[Updated Final Safety Analysis Report  WO  work order]]
}}
}}

Latest revision as of 05:31, 20 December 2019

NRC Integrated Inspection Report 05000443/2015001 (January 1 - March 31, 2015)
ML15120A570
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 04/30/2015
From: Glenn Dentel
Reactor Projects Branch 3
To: Dean Curtland
NextEra Energy Seabrook
dentel, gt
References
IR 2015001
Download: ML15120A570 (23)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 April 30, 2015 Mr. Dean Curtland Site Vice President - Seabrook Station NextEra Energy Seabrook, LLC c/o Mr. Michael Ossing 626 Lafayette Rd.

Seabrook, NH 03874 SUBJECT: SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION REPORT 05000443/2015001

Dear Mr. Curtland:

On March 31, 2015, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station, Unit No. 1. The enclosed inspection report documents the inspection results, which were discussed on April 16, 2015, with Mr. Ralph Dodds, Plant General Manager, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings were identified.

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 50-443 License No: NPF-86

Enclosure:

Inspection Report No. 05000443/2015001 w/ Attachment: Supplemental Information

REGION I==

Docket No.: 50-443 License No.: NPF-86 Report No.: 05000443/2015001 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station, Unit No.1 Location: Seabrook, New Hampshire 03874 Dates: January 1, 2015 through March 31, 2015 Inspectors: P. Cataldo, Senior Resident Inspector C. Newport, Resident Inspector E. Burket, Emergency Preparedness Inspector Approved by: Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY

IR 05000443/2015001; 01/01/2015-03/31/2015; Seabrook Station, Unit No. 1; Routine

Integrated Inspection Report.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

No findings were identified.

REPORT DETAILS

Summary of Plant Status

Seabrook operated at full power for the quarter, with the exception of a down-power to 94 percent on January 16, 2015, for performance of main turbine control valve testing. Documents reviewed for each section of this inspection report are listed in the Attachment.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed NextEras preparations and response to extreme cold weather on January 8 to 9, 2015, and a winter storm on January 27 - 28, 2015. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during these adverse weather conditions. The inspectors walked down the essential switch gear and non-essential switch gear rooms, switch yard, cooling tower (CT) general area, supplemental emergency power system (SEPS), demineralized water tank, and the refueling water storage tank area to ensure system availability. The inspectors verified that operator actions defined in NextEras adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

Main article: IP 71111.04Q

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

'B' emergency feedwater (EFW) pump return to service on February 22, 2015 A control building air handling system during B train filter maintenance on March 23, 2015

'A' emergency diesel generator (EDG) while 'B' EDG out of service for maintenance on March 31, 2015 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether NextEra staff had properly identified equipment issues and entered them into the corrective action program (CAP)for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

Main article: IP 71111.04S

a. Inspection Scope

On March 3, 2015, the inspectors performed a complete system walkdown of accessible portions of the residual heat removal (RHR) system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs and WOs to ensure NextEra appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified.

1R05 Fire Protection

Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that NextEra controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

'A' electrical tunnel east end (ET-F-1A-A) on February 4, 2015

'A' electrical tunnel west end (ET-F-1B-A) on February 9, 2015 Primary auxiliary building 25 (PAB-F-2A-Z, PAB-F-2B-Z, PAB-F-2C-Z)on March 25, 2015 Non-essential switchgear (NES-F-1A-Z) on March 25, 2015 Control building battery room A/B/C/D (CB-F-1D-A, CB-F-1E-A, CB-F-1F-A, CB-F-1G-A) on March 30, 2015

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Main article: IP 71111.06

Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if NextEra identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the mechanical penetration room to verify the adequacy of equipment seals located below the flood line, flood and water penetration seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

Main article: IP 71111.07A

a. Inspection Scope

The inspectors reviewed the A EDG heat exchanger to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified NextEras commitments to NRC Generic Letter 89-13.

The inspectors reviewed results of previous inspections of the A EDG heat exchanger, reviewed performance data obtained during recent operation of the A EDG heat exchanger, observed the most recent inspection of the A EDG heat exchanger, and discussed results of the most recent inspection with NextEra staff. The inspectors also verified that NextEra initiated appropriate corrective actions for identified deficiencies.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11Q

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on February 9, 2015, which included a steam generator tube rupture coincident with a loss of offsite power and the failure of select components to respond as required. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures.

The inspectors assessed the clarity and effectiveness of communications, implement-tation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the unit supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed general control room activities on January 12, 2015, reactor control systems being placed in manual by operators, and containment air handling fan swaps on February 18, 2015, and control room shift turnover on March 4, 2015.

Additionally, inspectors observed A' EDG operations, reactor coolant pump standpipe fill operations, control board chart recorder paper change-out, and main unit generator MVAR adjustment of line 369 on March 27, 2015, and general activities during the B EDG outage on March 31, 2015. During these control room observations, the inspectors verified that procedure use and adherence, general control room conduct, alarm response, test performance, and coordination of activities between work groups met established expectations and standards.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12Q

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that NextEra was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with 10 CFR 50.65 and verified that the (a)(2)performance criteria established by NextEra staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that NextEra staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.

Emergency air handling fan 5B bearing inspections on February 18, 2015 Primary close latch replacement activities associated with ABB breakers on March 9, 2015

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that NextEra performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that NextEra personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When NextEra performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Startup feed pump maintenance on January 20, 2015

'D' service water (SW) pump maintenance on February 3, 2015 Transfer to SW cooling tower (CT) operations on February 26, 2015

'A' EDG maintenance on March 9, 2015

'B' EDG maintenance on March 31, 2015

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

B SW discharge tubing support corrosion on January 15, 2015 Seismic supports for a SW pump and the control rod drive mechanisms, American Society of Mechanical Engineers,Section XI compliance, on February 19, 2015 Wetted insulation removal on RHR system piping on February 24, 2015 SEPS glycol level fluctuation on February 26, 2015 B vital battery cell cover cracks on March 30, 2015 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to NextEras evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by NextEra. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

No findings were identified.

1R18 Plant Modifications

Main article: IP 71111.18

Permanent Modifications

a. Inspection Scope

The inspectors evaluated a modification to install a primary chemistry zinc injection skid implemented by Engineering Change 280335, Primary System Zinc Addition. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors conducted walkdowns and reviewed modification documents associated with the upgrade and design change, including associated engineering changes, calculations, communication with the vendor, and industry operating experience.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

Containment enclosure ventilation fan, EAH-FN-5B, vibration isolator replacement on January 6, 2015 RH-FCV-610 thermal overload protection relay replacement on January 13, 2015 B steam generator atmospheric steam dump supply air solenoid valve replacement on January 30, 2015 Emergency air handling fan, EAH-FN-5A, maintenance on February 19, 2015 Replacement of B RHR flow switch F-611 on February 24, 2015 Pressurizer backup heater supply breaker trip latch replacement on March 3, 2015 A EDG temperature control valve rebuild on March 18, 2015

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and NextEra procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

'A' SW CT agastat relay time delay testing on January 15, 2015

'A' solid state protection system Mode 1 actuation logic test on January 22, 2015

'A' SW valve quarterly in-service test on February 10, 2015 (IST)

Auctioneered reactor coolant system average temperature calibration on February 18, 2015 SEPS monthly availability surveillance on March 23, 2015 B train emergency cleanup filter surveillance testing on March 24, 2015 RCS steady state leak rate calculation on March 27, 2015 (RCS)

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes

Main article: IP 71114.04

a. Inspection Scope

NextEra implemented various changes to the Seabrook Emergency Action Levels (EALs), Emergency Plan, and Implementing Procedures. NextEra had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, Emergency Plan, and its lower-tier implementing procedures, had not resulted in any reduction in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50 Appendix E.

The inspectors performed an in-office review of all EAL and Emergency Plan changes submitted by NextEra as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Main article: IP 71114.06

Emergency Preparedness Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on February 9, 2015 which required emergency plan implementation by an operations crew.

NextEra planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that NextEra evaluators noted the same issues and entered them into the CAP.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

Main article: IP 71151

Unplanned Scrams, Unplanned Power Changes, and Unplanned Scrams with

Complications (3 samples)

a. Inspection Scope

The inspectors reviewed NextEras submittals for the following Initiating Events Cornerstone performance indicators for the period of January 1, 2014 to December 31, 2014:

Unplanned scrams per 7,000 critical hours (IE01)

Unplanned power changes per 7,000 critical hours (IE03)

Unplanned scrams with complications (IE04)

To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed NextEras operator narrative logs, event reports, performance indicator submittals, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

Main article: IP 71152

Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that NextEra entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended condition report screening meetings.

b. Findings

No findings were identified.

4OA5 Other Activities

Administrative Corrections to NRC Integrated Inspection Report 05000443/2014005 Two samples associated with section 1R12, Maintenance Effectiveness, inspections of

(1) MR program assessment on November 20, 2014, and
(2) cumulative review of breaker maintenance and retests on December 8, 2014, were inadvertently omitted from the final inspection report issued February 6, 2015.

One sample associated with section 1R19, Post-Maintenance Testing, inspection of safety injection pump 6A static baker testing on September 9, 2014, was included in error in the final inspection report issued February 6, 2015.

4OA6 Meetings, Including Exit

On April 16, 2015, the inspectors presented the inspection results to Mr. Ralph Dodds, Plant General Manager, and other members of the Seabrook Station staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Curtland, Site Vice President
R. Dodds, Plant General Manager
V. Brown, Senior Licensing Engineer
D. Currier, Emergency Planning Manager
K. Douglas, Maintenance Director
D. Flahardy, Radiation Protection Manager
M. Haidul, Nuclear Engineer
M. Ossing, Licensing Manager
D. Ritter, Site Operations Director
D. Robinson, Chemistry Manager

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

None

Opened

None

Closed

None

LIST OF DOCUMENTS REVIEWED

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