IR 05000395/2019011
| ML19178A396 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/27/2019 |
| From: | Randy Musser NRC/RGN-II |
| To: | Stoddard D Dominion Energy Co |
| Geanette D | |
| References | |
| IR 2019011 | |
| Download: ML19178A396 (16) | |
Text
June 27, 2019
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000395/2019011
Dear Mr. Stoddard:
On May 23, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Summer Unit 1 and discussed the results of this inspection with Mr. George Lippard and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
The NRC inspectors documented one finding of very low safety significance (Green) in this report. The finding did not involve a violation of NRC requirements.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 II; and the NRC Resident Inspector at Summer. This letter, its enclosure, 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects
Docket No.: 05000395 License No.: NPF-12
Enclosure:
As stated
Inspection Report
Docket Number:
05000395
License Number:
Report Number:
Enterprise Identifier: I-2019-011-0035
Licensee:
Dominion Energy
Facility:
Virgil C. Summer Nuclear Station
Location:
Jenkinsville, SC
Inspection Dates:
May 6, 2019 to May 23, 2019
Inspectors:
Carey Read, Senior Resident Inspector (Team Leader)
Eliza Hilton, Resident Inspector
Katie McCurry, Fuel Facilities Inspector
Phil Niebaum, Senior Project Engineer
Approved By:
Randall A. Musser, Chief
Reactor Projects Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Virgil C. Summer Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Follow Corrective Action Program Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000395/2019011-01 Open/Closed
[P.3] - Resolution 71152B An NRC-identified Green finding was identified for the licensees failure to follow their corrective action process for condition report CR-12-02287. Specifically, the licensee failed to properly recognize this issue as a condition affecting regulatory compliance (CARC), initiate a level 2 corrective action, and follow the established completion date targets as required by SAP-0999, Rev. 17.
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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Problem Identification and Resolution
The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.
- Operating Experience, Self-Assessments and Audits - The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment - The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Observation: Corrective Action Program 71152B
Corrective Action Program Assessment Based on the samples reviewed, the team determined that the licensees corrective action program (CAP) complied with regulatory requirements and self-imposed standards. The licensees implementation of the CAP adequately supported nuclear safety.
Effectiveness of Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the CAP at the appropriate threshold.
This conclusion was based on a review of the requirements for initiating Condition Reports (CRs) as described in licensee procedure SAP-0999, "Corrective Action Program," and managements expectation that employees were encouraged to initiate CRs for any reason.
Additionally, site management was actively involved in the CAP and focused appropriate attention on significant plant issues. The inspectors performed walk downs, reviewed CRs, and reviewed system health trending for Diesel Generators, DC Batteries, the Component Cooling System, and the Emergency Feedwater System. Based on the inspectors' reviews and walkdowns of accessible portions of those systems, the inspectors determined that deficiencies were being identified and placed in the CAP.
Effectiveness of Prioritization and Evaluation of Issues: Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance the CAP requirements. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had generally conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures, including appropriate cause determinations, and performed adequate levels of analysis based on the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used to evaluate CRs depending on the type and complexity of the issue consistent with the applicable cause evaluation procedures.
Effectiveness of Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that generally corrective actions were effective, timely, and commensurate with the safety significance of the issues. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The team reviewed performance indicators, CRs, and effectiveness reviews, as applicable, to verify that significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective. Inspectors identified several issues associated with condition report or corrective action closure for conditions adverse to quality. Specific issues are identified in this report as a finding, minor performance deficiencies, and an observation. Inspectors identified instances where CRs were closed without proper actions, resulting in delayed corrective actions or the potential to lose track of corrective actions. Inspectors also identified traceability issues resulting from creating multiple CRs on the same issue, which created vulnerabilities to losing track of corrective actions.
Observation: Operating Experience, Self-Assessments and Audits 71152B
The inspectors examined the licensee's program for obtaining and using industry operating experience. This included review of procedure SAP-1351, "Operating Experience (OE)
Program," selected corrective action program action requests, and the licensees operating experience (OE) database to assess the effectiveness of how external and internal OE data was evaluated at the plant. Additionally, the inspectors selected OE documents such as NRC generic communications, licensee event reports, vendor notifications, and plant internal OE items which had been issued since January 2016 to verify whether the licensee had appropriately evaluated each notification for applicability to the station, and whether issues identified through these reviews were entered into the CAP.
The inspectors determined that licensee's processes for the use of industry and NRC operating experience information and for the performance of audits and self-assessments were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed. The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance.
Observation: Safety Conscious Work Environment 71152B
Based on a sample of 16 people interviewed from a cross-section of plant employees, the team found no evidence of challenges to a safety-conscious work environment. Employees interviewed appeared knowledgeable of avenues to raise safety concerns and appeared willing to raise nuclear safety concerns through at least one of the several means available.
Minor Performance Deficiency 71152B
Minor Performance Deficiency: In January 2014, during the preventive maintenance (PM)task of the refurbishment of Service Water (SW) pump XPP0039B, the licensee found out of tolerance gaps on the seismic restraints and initiated CR-14-00112. The apparent cause evaluation (ACE) associated with the CR determined that an extent of condition (EOC)inspection should be performed on the other trains of SW pumps (XPP0039A and XPP0039C), and existing PM tasks, Work Orders (WO) 1301830 and 1100910, were selected to inspect those seismic restraints. However, the WO for the A pump was closed with no work being performed due to a change in the preventative maintenance frequency, and a later due date was established. The new WO (1709218), generated to perform that maintenance, was completed in February 2019, and found three seismic gaps out of tolerance, resulting in CR-19-00393. The operability determination stated that it this condition likely existed since the pump re-build performance in September 2002. Therefore, had the EOC inspection been adequately performed through the initial WO, this issue would have been identified sooner.
SAP-1356, "Cause Determination," Section 7.2.3, states in part, "the ACE shall perform an extent of condition determination using SAP-1356 CDG-01." SAP-1356 CDG-01, "Cause Determination Guidelines," states in part, "it is expected that once the scope of the Extent of Condition has been identified, it may be reduced only based on the actual or potential nuclear safety consequence. Document the basis for a reduction in the scope of the EOC." Contrary to SAP-1356 CDG-01 and SAP-1356, the licensee failed to complete an adequate EOC inspection for several years. A contributing cause was the missing tie between the EOC of the CR and the implementing procedures.
Screening: The inspectors determined the performance deficiency was minor. The performance deficiency was screened in accordance with Inspection Manual Chapter 0612 Appendix B and determined to be minor because the pump was determined to be operable but degraded with substantial safety margin in the gaps analyzed. This issue was captured in CR-19-01910.
Observation: CR Action Traceability 71152B
The inspectors found two examples of CRs that identified actions that were not completed before CR closure. In both cases, the CR actions were addressed in different CRs and not tied back coherently to the original CR before closure. Specifically:
1. CR-17-02713 was initiated to capture leaking tube welds associated with Emergency
Feedwater (EF) System modifications. The evaluation adequately identified a cause, but the CR was closed without initiating an action to address the cause. However, adequate corrective actions were later taken in CRs 17-03479 and 17-04657, but those CRs were not traceable back to the original CR.
2. CR-17-00662, associated with surface rust observed on EF piping, assigned an action
to perform ultrasonic testing. The CR was closed without adequate justification for why the testing was not performed. Justification was later provided in CR-18-04549, but that CR was not readily traceable back to the original CR.
By not having complete traceability between CRs, the site was vulnerable to corrective actions being missed and inadequate CR closure. This observation was captured in CR-19-01906.
Minor Performance Deficiency 71152B
Minor Performance Deficiency: The licensee completed an Equipment Apparent Cause Evaluation (E-ACE) in CR-17-05860 on a reactor trip that was caused by the failure of an inverter gate drive card. A level 2 corrective action (action 9) from the E-ACE was created to replace the card in the next refueling outage. SAP-0999, "Corrective Action Program," Enclosure D prevents the licensee from closing level 2 actions to work orders that have not been completed. Contrary to the requirement, the licensee closed a level 2 action that was assigned from the E-ACE without the work being completed in WO1705755. By closing the level 2 action, the station lost administrative corrective action program controls over timely completion of corrective actions.
Screening: The inspectors determined the performance deficiency was minor. The performance deficiency was screened in accordance with Inspection Manual Chapter 0612 Appendix B and determined to be minor because the licensee completed the work in the next refueling outage, and there were no additional equipment failures. This issue was captured in CR-19-01907.
Minor Performance Deficiency 71152B
Minor Performance Deficiency: In January 2017, the licensee completed an Apparent Cause Evaluation for condition report CR-16-06015, which identified a process deficiency when addressing minor work activities on safety-related components. The corrective action to fix the process deficiency was closed on February 14, 2019, without revising or issuing new procedures to resolve the deficiency.
SAP-0999, "Corrective Action Program," Section 6.3.9 requires that "when performing evaluations or documenting actions taken, do not use open-ended or promissory type statements to close the issue." Contrary to SAP-0999, the licensee closed CR-16-06015 Action 1 to a promissory statement for a procedure that was under development. The licensee subsequently expanded an existing nonconformance procedure to cover the process deficiency.
Screening: The inspectors determined the performance deficiency was minor. The performance deficiency was screened in accordance with Inspection Manual Chapter 0612 Appendix B and determined to be minor because since January 2017, no safety-related components had been adversely affected. This issue was documented in CR-19-01899.
Failure to Follow Corrective Action Program Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green FIN 05000395/2019011-01 Open/Closed
[P.3] -
Resolution 71152B An NRC-identified Green finding was identified for the licensees failure to follow their corrective action process for condition report CR-12-02287. Specifically, the licensee failed to properly recognize this issue as a condition affecting regulatory compliance (CARC), initiate a level 2 corrective action, and follow the established completion date targets as required by SAP-0999, Rev. 17.
Description:
Condition report CR-12-02287 was created on June 5, 2012, to review the impacts of revision 3 of RG 1.160, "Monitoring the Effectiveness of Nuclear Power Plants." On March 12, 2013, Action 005 was created to conduct the evaluation to scope non-safety related (NSR)structures, systems, and components (SSCs) used in emergency operating procedures (EOPs) into the maintenance rule. Action 005 stated in part, compare non safety related SSCs used in the EOPs against current maintenance rule scoping to ensure our maintenance rule scoping is correct. The inspectors found that action 005 was extended 23 times over approximately 5 years even though there was enough information as early as March 2013 for the station to recognize this maintenance rule scoping issue as a potential regulatory non-compliance. Paragraph 6.3.1 of licensee procedure SAP-0999, revision 17, also stated that if new issues are identified, separate CRs should be initiated to capture these (new) issues.
The inspectors determined that the licensee could have initiated another CR to identify the potential regulatory non-compliance with the maintenance rule. A newly initiated CR would have been subjected to a screening review process which could have screened this issue into a higher category. Action 005 of CR-12-02287 was closed on January 25, 2018, and this action did not completely resolve the issue. Additional actions were opened and closed under this CR to continue to evaluate and determine the need to scope non-safety related SSCs used in the stations EOP within the maintenance rule.
On January 12, 2018, revision 17 of licensee procedure SAP-0999, "Corrective Action Program," became effective at the station. This version introduced the condition adverse to regulatory compliance (CARC) and established a 240-day completion time for level 2 actions that are expected to correct the CARC. The inspectors determined that upon implementation of SAP-0999, revision 17, the issue described in CR-12-02287 should have been recognized as a CARC, and a level 2 corrective action should have been completed to address the CARC within 240 days as stated in Enclosure B. This would have driven the licensee to complete the maintenance rule evaluations to scope non-safety related SCCs used in the EOPs by September 9, 2018. The inspectors acknowledged that the target completion dates of level 2 actions can be extended per SAP-0999, but extensions are controlled administratively by the management review team (MRT) or the corrective action review board (CARB). During their review, the inspectors found that Action 010 of CR-12-02287 was open with a planned completion date of June 26, 2019. Because Action 010 was characterized as a level 3 action, it could be extended indefinitely by the same group responsible for closing the action.
Corrective Actions: The licensee initiated a new condition report and planned to create an level 2 action to ensure the necessary scoping evaluations are reviewed by the maintenance rule expert panel in accordance with the timeliness targets stated in licensee procedure, SAP-0999, "Corrective Action Program."
Corrective Action References: CRs-19-01897 and 19-01898.
Performance Assessment:
Performance Deficiency: Failure to follow the stations CAP procedure, SAP-0999, Rev. 17 was the PD. CR-12-02287 was not identified as a CARC upon implementation of this procedure on January 12, 2018. As a result, a level 2 corrective action was not created and the associated timeliness targets (or appropriate due date extension controls) of Enclosure B were not followed.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The licensee has not completed the MR scoping effort of NSR SSCs used in the EOPs and cannot sufficiently demonstrate monitoring of the functions/components have been effective.
Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The finding was screened using Exhibit 2, "Mitigating Systems Screening Questions" since CR-12-02287 was related to SSCs used in the EOPs to mitigate events. The inspectors determined the finding screened to Green, very low safety significance, because the associated screening questions were answered "No."
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. The finding has a cross-cutting aspect of resolution in the problem identification and resolution (PI&R)area (P.3) because action 005 was extended 23 times over an approximately 5 year period even though there was sufficient information as early as March 2013 to reasonably conclude that this issue was a potential regulatory non-compliance associated with the maintenance rule. This issue should have been resolved before the implementation of Rev. 17 of SAP-0999, which would have prevented this finding.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 23, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Mr. George Lippard and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-12-00771
CR-12-02287
CR-14-00112
CR-16-00972
CR-16-01863
CR-16-04546
CR-16-04550
CR-16-04621
CR-16-04645
CR-16-04664
CR-16-04946
CR-16-05107
CR-16-06015
CR-17-00223
CR-17-00537
CR-17-00662
CR-17-00719
CR-17-01602
CR-17-01611
CR-17-01956
CR-17-02095
CR-17-02097
CR-17-02428
CR-17-02586
CR-17-02587
CR-17-02713
CR-17-02759
CR-17-02797
CR-17-03086
CR-17-03117
CR-17-03479
CR-17-03492
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-17-03614
CR-17-03942
CR-17-04096
CR-17-04261
CR-17-04460
CR-17-04657
CR-17-05192
CR-17-05231
CR-17-05095
CR-17-05300
CR-17-05534
CR-17-05588
CR-17-05860
CR-17-05877
CR-18-00571
CR-18-00623
CR-18-00685
CR-18-00686
CR-18-00872
CR-18-01088
CR-18-01112
CR-18-01116
CR-18-01394
CR-18-01427
CR-18-01428
CR-18-01475
CR-18-02378
CR-18-03105
CR-18-03208
CR-18-03442
CR-18-03940
CR-18-04083
CR-18-04237
CR-18-05037
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-18-05336
CR-19-00337
CR-19-00393
CR-19-01213
CR-19-01436
CR-19-01653
CR-19-01735
Corrective Action
Documents
RCA-16-04801
Inadequate Isolation Between Chiller Room and Chilled Water
Pump Room
11/01/2016
Corrective Action
Documents
RCA-17-04195
Issues with Licensed Operator Training Programs
1/22/2018
Corrective Action
Documents
Resulting from
Inspection
CR-19-01707
CR-19-01732
CR-19-01735
CR-19-01738
CR-19-01817
CR-19-01867
CR-19-01868
CR-19-01870
CR-19-01891
CR-19-01896
CR-19-01897
CR-19-01898
CR-19-01899
CR-19-01906
CR-19-01907
CR-19-01910
Drawings
D-302-085
Piping System Flow Diagram - Emergency Feedwater
Drawings
D-302-611
Piping and System Flow Diagram - Component Cooling
Drawings
D-302-612
Piping and System Flow Diagram - Component Cooling
Drawings
D-302-613
Piping and System Flow Diagram - Component Cooling
Drawings
D-302-614
Piping and System Flow Diagram - Component Cooling
Drawings
E-206-061
Vital AC-DC System, Sheets 1, 2 and 3
Drawings
E-206-062
Electrical One Line and Relay Diagram, Vital DC System,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Sheets 3 and 4
Engineering
Changes
ECR 50695E
EFW Flow Margin Improvement
07/07/2016
Miscellaneous
Welder Performance Qualification Record for Welded ID No.
SI-68
04/03/2017
Miscellaneous
System Health Reports for Emergency Feedwater
03/14/2017,
08/21/2017,
03/26/2018,
09/13/18,
2/28/2019
Miscellaneous
Cycle 23 Maintenance Rule 50.65(a)(3) Evaluation
10/06/2018
Miscellaneous
System Health Report - DC Distribution
08/01/2016
Miscellaneous
2019 Pre-PI&R Self-Assessment
4/2/2019
Miscellaneous
VC Summer Unit 1 Quality Assurance Program Description
Miscellaneous
System Health Reports for Component Cooling System
3/14/2017,
8/21/2017,
3/22/2018,
9/13/2018,
2/28/2019
Miscellaneous
QA-AUD-
201810
Quality Assurance Audit of Station Operations
10/2/2018
Operability
Evaluations
CR-17-05534,
Action 001
Procedures
EMP-115.005
Removal and Reinstallation of Battery Cells
Procedures
Implementation of the Maintenance Rule
Procedures
Maintenance Rule - Performance Monitoring
Procedures
Maintenance Rule - Periodic (a)(3) Assessment
Procedures
MMP-101.002
Minor Corrective Maintenance
Procedures
MMP-320.001
Component Alignment and Coupling Maintenance
Procedures
Processing Regulatory Documents
Procedures
OEG-01
Operating Experience Guidelines
Procedures
PMP-300
ECR Work Order Development and Planning
Procedures
QSG-011
Employee Concerns Program Process
Procedures
QSP-106
Nuclear Oversight Audit and Surveillance Activities
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
QSP-204
Quality Control Inspection
Procedures
Design Control Implementation and Interface
Procedures
Procedures
Corrective Action Program
Revs 11 and
through
Procedures
CAPG-01
Corrective Action Program Guidelines
and 20
Procedures
CR Review Team (CRRT)
and 1
Procedures
Management Review Team (MRT)
Procedures
Resolution of Quality Assurance Issues
and 2
Procedures
Corrective Action Review Board (CARB)
Procedures
Employee Concerns Program
Procedures
Self-Assessment and Benchmarking
and 11
Procedures
Operating Experience (OE) Program
Procedures
Cause Determination
and 8
Procedures
CDG-01
Cause Determination Guideline
through
Procedures
SOP-210
Feedwater System
Procedures
SOP-211
Procedures
SOP-311
25 VDC System
Procedures
STP-220.002
Turbine Driven Emergency Feedwater Pump and Valve Test
Procedures
VCS-NL-102
Processing Regulatory Documents
Procedures
WM-1.0
Welding Manual Procedure
Self-Assessments
SAP-1351 Operation Experience Program Self-Assessment
10/08/2018
Self-Assessments
Maintenance Rule Program Health Reports
June 2016,
Sept. 2016,
Jan. 2018,
June 2018
Self-Assessments
Station Trend Report, Third Trimester 2018, Aggregate
Analysis
Work Orders
Work order to replace inverter gate drive card during outage