IR 05000400/2024002

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– Integrated Inspection Report 05000400/2024002
ML24205A002
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 07/29/2024
From: Matthew Fannon
Division Reactor Projects II
To: Haaf T
Duke Energy Progress
References
IR 2024002
Download: ML24205A002 (17)


Text

SUBJECT:

SHEARON HARRIS NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000400/2024002

Dear Thomas Haaf:

On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Shearon Harris Nuclear Plant. On July 17, 2024, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No. 05000400 License No. NPF-63

Enclosure:

As stated

Inspection Report

Docket Number: 05000400

License Number: NPF-63

Report Number: 05000400/2024002

Enterprise Identifier: I-2024-002-0016

Licensee: Duke Energy Progress, LLC

Facility: Shearon Harris Nuclear Plant

Location: New Hill, North Carolina

Inspection Dates: April 01, 2024 to June 30, 2024

Inspectors: P. Boguszewski, Senior Resident Inspector J. Diaz-Velez, Senior Health Physicist J. Hickey, Senior Project Engineer M. Kay, Resident Inspector B. Kellner, Senior Health Physicist S. Kennedy, Senior Resident Inspector M. Magyar, Allegations/Enforcement Specialist D. Neal, Health Physicist J. Rivera, Health Physicist A. Wilson, Senior Project Engineer

Approved By: Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Shearon Harris Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 started the inspection period at 87 percent rated thermal power due to a planned end of core life power coast down in preparation for a planned refueling outage. On April 10, 2024, the unit was shutdown to begin the planned refueling outage. On May 12, 2024, operators commenced a normal plant startup following completion of the refueling outage. The unit was returned to rated thermal power on May 15, 2024, and remained at or near rated thermal power until May 30th, 2024, when Unit 1 tripped offline due to an electrical fault that caused a turbine trip and subsequent reactor trip. Following the trip, operators commenced a normal plant startup on June 1, 2024, and reached rated thermal power on June 2, 2024. The unit remained at or near rated thermal power for the remainder of the inspection period.

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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures, for the following systems:

Emergency batteries Emergency diesel generators

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Motor driven auxiliary feedwater pumps while the turbine driven auxiliary feedwater pump was inoperable on April 3, 2024
(2) 'B' emergency diesel generator during 'A' safety bus outage on April 24, 2024
(3) 'A' emergency service water system during 'A' startup transformer outage on May 20, 2024
(4) A residual heat removal system on June 13, 2024
(5) B residual heat removal system on June 13, 2024

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Reactor containment on April 25, 2024
(2) 'A' emergency diesel generator area on June 11, 2024
(3) 'B' emergency diesel generator area on June 11, 2024
(4) Central alarm station on June 11, 2024
(5) Cable spreading rooms on June 11, 2024

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 'A' component cooling water heat exchanger the week of April 14, 2024

===71111.08P - Inservice Inspection Activities (PWR)

The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities during refueling outage H1R25 from April 15 to April 18.

PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===

The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:

(1) Ultrasonic Examination (UT)
  • Weld II-MS-001MS-FW-256, elbow to pipe

Magnetic Particle Examination (MT)

  • Weld 1-SW-529-3-VW-1. This included a review of the associated welding activity.
  • Weld 1-SW-529-3-VW-10. This included a review of the associated welding activity.

Visual Examination (VT)

  • Bare metal visual of the reactor vessel closure head (RVCH)

PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection

Activities (IP Section 03.02) (1 Sample)

The inspectors verified that the licensee conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:

(1)

  • Bare metal visual of the RVCH

PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)

The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:

(1)

  • Work Request (WR) 20267364
  • Action Request (AR) 02489951

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during unit shutdown activities including turbine load reduction, transition from main feedwater control to bypass feedwater control, reactor trip, turbine trip, and placing residual heat removal in service in preparation for a refueling outage on April 9 and 10, 2024.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated training involving taking the reactor coolant system solid and shutdown cooling manipulations while solid on April 4, 2024.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Nuclear Condition Report (NCR) 02508062, turbine driven auxiliary feedwater pump steam supply valve, 1MS-72, failure to close on April 5, 2024
(2) NCR 02513351, pressurizer level transmitter, LT-460, calibration not repeatable on May 1, 2024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Refueling outage yellow risk due to reduced reactor coolant level in preparation for reactor head removal on April 12, 2024
(2) Refueling outage yellow risk due to planned 'A' safety bus maintenance outage on April 15, 2024, and April 16, 2024
(3) Refueling outage yellow risk due to reduced reactor coolant inventory to support reactor reassembly on April 26, 2024
(4) Elevated risk and implementation of risk informed completion time due to 'A' startup transformer maintenance on May 16, 2024
(5) Application of Technical Specification (TS) 3.0.4.b during startup with 1MS-70, main steam line 'B' steam supply to turbine driven auxiliary feedwater, inoperable on May 11, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) NCR 02512745, change in manipulator crane load cell calibration methodology on April 16, 2024
(2) NCR 02513154, anticipated trip without scram digital indicator out of tolerance on April 22, 2024
(3) NCR 02514271, 'A' sequencer SAB/1106 time delay relay as found value outside of acceptance criteria on May 1, 2024
(4) NCR 02514815, functionality of electrical penetration seal following 'A' reactor coolant pump cable failure on May 30, 2024
(5) WR 20270099, 1FW-159 accumulator leak on June 4, 2024

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change (EC) 420531, replacement of 'A' startup transformer on May 2, 2024
(2) EC 422071, feedwater flow control valve replacement and digital controls upgrade on May 4, 2024
(3) EC 424217 and EC 424218, 'A' reactor coolant pump electrical cable repair and modification on May 10, 2024

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated refueling outage activities from April 10, 2024, to May 12, 2024.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (7 Samples)

(1) MPT-E005, "Westinghouse Model DS-416," following undervoltage trip relay replacement on April 17, 2024
(2) MST-I0072, "Train A 18-Month Manual Reactor Trip Solid State Protection System Actuation Logic & Master Relay Test," following terminal board repair on April 28, 2024
(3) OST-1099, "Emergency Safeguards Sequencer 1A-SA Response Time Test,"

following relay PRX2/1102 adjustment on April 29, 2024

(4) Work Order (WO) 20660431, testing of 1CS-278, emergency boration flow isolation valve, following repairs on April 13, 2024
(5) WO 20662906, 'A' containment spray discharge valve testing after valve repairs on April 29, 2024
(6) WO 20566796, 1RH-2, reactor coolant system loop to 'A' residual heat removal isolation valve, post maintenance stroke time testing on April 25, 2024
(7) OST-1191, Steam Generator Power Operated Relief Valve (PORV) and Block Valve Operability Testing, following repair of 1MS-60, A steam generator PORV, on June 5, 2024

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) OST-1097, "MDAFWP Flow Control Valves High Differential Pressure Stroke Test,"

on April 10, 2024

(2) OST-1046, "Main Steam Isolation Valve Operability Test," on April 10, 2024
(3) EPT-138, "Auxiliary Feedwater Pump 1X-SAB Turbine Overspeed Trip Test," on April 20, 2024

Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)

(1) 1SW-240, containment fan coil units service water return, local leak rate testing on April 21, 2024

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (1 Sample)

The inspectors evaluated:

(1) An emergency preparedness training exercise involving a seismic event and reactor coolant pump seal failure on May 28,

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA)
(2) Workers exiting the RCA during a refueling outage
(3) Workers exiting the reactor containment building (RCB) [contaminated area] during a refueling outage

Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) Seal table activities, ALARA Plan 2024HNPH125R1-002, radiation work permit (RWP) 1013 & 1040, Revisions 0 and 1
(2) Refueling activities, ALARA Plan#: 2024HNPH125R1-001, RWP 1010 & 1024, Revision 0
(3) N43 detector replacement, ALARA Plan#: 2024HNPH125Rl-004, RWP 1032, Revision 0
(4) Cavity decon, ALARA Plan#: 2024HNPH125Rl-003, RWP 1016 and 1036, Revision 0
(5) Diving activities associated with the 1-4 transfer canal, ALARA Plan#:

2024HNPH125R1-005, RWP 1042, Revision 0

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)

The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):

(1) Waste processing building (WPB) 261' elevation fuel transfer tube hatch [VHRA]
(2) RCB 236' elevation regenerative heat exchanger [Locked High Radiation Area (LHRA)]
(3) RCB 221' elevation incore sump [VHRA]
(4) WPB 211' elevation waste holdup tank [LHRA]
(5) WPB 261' elevation room 144A - high rad storage room [LHRA]

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (2 Samples)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Reactor auxiliary building ventilation system
(2) Control room emergency ventilation system

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) HEPA unit #3, tested on January 11, 2024

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the following internal dose assessments:

(1) Sample collection documentation of baseline in-vitro bioassays related to pre-diving activities (April 19, 2024)
(2) Sample collection documentation of in-vitro bioassay related to a post-diving activity (April 21, 2024)

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Declared pregnant worker, declared in 2023
(2) Diver multi-badging performed on April 19, 2024

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (8 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Area radiation monitors (ARMs) in the fuel handling building
(2) ARMs in the auxiliary building
(3) Portal monitors at the RCA exit
(4) Personnel contamination monitors at the RCA exit
(5) Small articles / tools monitors at the RCA exit
(6) Continuous air monitors in the auxiliary building
(7) Wide range portable telescopic survey meters in the instrumentation room
(8) Portable ion chambers in the instrumentation room

Calibration and Testing Program (IP Section 03.02) (14 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Containment high range radiation monitors, RM-1-3589SA and RM-1-3590SB
(2) GEM-5, SN 10800
(3) Cronos-4, SN 2555
(4) Argos-5AB, SN 12268
(5) Telepole, SN 07595
(6) RadEye B20-ER, SN 16016
(7) RDS-31, SN 13581
(8) Ludlum 9-3, SN 11927
(9) Ludlum 177, SN 07113
(10) Ludlum 12-4 / Remball, SN 02828
(11) iCAM, SN 07894
(12) Tri-Carb 3110TR liquid scintillation counter, SN 129087
(13) Germanium Detector No. 3
(14) Tennelec Counter No. 1

Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Plant vent stack accident monitor, RM-21AV-3509-1SA
(2) Waste monitor tanks discharge monitor, REM-3541
(3) Laundry and hot shower tank pump discharge monitor, REM-3540

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) April 1, 2023, through March 31, 2024

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) April 1, 2023, through March 31, 2024

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) April 1, 2023, through March 31, 2024

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) June 1, 2023, through March 31, 2024

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) July 1, 2023, through March 31, 2024

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Instrument bus 1 and 3 inverters failed to carry load on DC supply on April 26, 2024 (NCRs 02512713 and 02512716)

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program to identify potential trends that might be indicative of a more significant safety issue.

71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)

(1) The inspectors evaluated an automatic reactor trip that was caused by a turbine trip that was the result of an electrical fault on the B unit auxiliary transformer on May 30,

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On July 17, 2024, the inspectors presented the integrated inspection results to Thomas Haaf, Site Vice President, and other members of the licensee staff.
  • On April 30, 2024, the inspectors presented the ISI inspection results to Thomas Haaf, Site Vice President, and other members of the licensee staff.
  • On April 30, 2024, the inspectors presented the radiation protection inspection results to Thomas Haaf, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.18 Miscellaneous VM-PPO Electrical Penetrations Vendor Manual Revision 9

71124.01 ALARA Plans 2024HNPH125R1- Refueling Activities In-Progress Review - 50% 04/17/2024

001

24HNPH125R1- Seal Table In-Progress Review - 50% [Pull and Park 04/17/2024

2 Thimbles completed]

Corrective Action The following Corrective Action Documents were reviewed Various

Documents during the inspection: AR 02494339, AR 02508735, AR

2508739 and AR 02512561.

Corrective Action AR 02513818 RadWaste Control Room door to RCA entrance found 04/24/2024

Documents blocked open

Resulting from

Inspection

Miscellaneous Station ALARA Committee Meeting Minutes - 3/25/2024 03/25/2024

[Outage Dose and Individual ALARA Plan Approval]

Procedures AD-RP-ALL-0004 Radiological Posting and Labeling Revision 7

AD-RP-ALL-1000 Conduct of Radiation Protection Revision 6

AD-RP-ALL-2013 Beta Radiation Characterization Revision 5

AD-RP-ALL-2014 Work in Alpha Environments Revision 10

HPP-517 Decontamination of the Upper and Lower Refueling CavitiesRevision 14

HPP-625 Performance of Radiological Surveys Revision 50

HPP-625 Performance of Radiological Surveys Revision 50

PLP-511 Radiation Control and Protection Program [Harris site Revision 37

specific]

Radiation HNP-M- RCB 261' Elevation Upper and Lower Seal Table Rooms 04/10/2024

Surveys 20240410-29

HNP-M- RCB 261' Elevation Upper and Lower Seal Table Rooms - 04/11/2024

240411-21 Post Decon

HNP-M- RCB 221' Elevation Incore sump downpost from LHRA to 04/11/2024

240411-25 HRA

HNP-M- RCB 250' Elevation Upper Cavity Post-Shielding Removal 04/11/2024

240411-30 Inside Title: Rx Head Shroud

HNP-M- RCB 261' Elevation Lower Seal Table Room - Tube leak 04/13/2024

Inspection Type Designation Description or Title Revision or

Procedure Date

240413-22 repairs

HNP-M- Reactor Head Move to the Reactor Head Stand 04/13/2024

240413-24

HNP-M- Transfer Canal Pre Flush Survey Underwater Survey [Pre- 04/18/2024

240418-39 Dive]

HNP-M- Transfer Canal Post Vacuuming Underwater Survey [Pre- 04/19/2024

240419-21 Dive]

HNP-M- Transfer Canal Post-Flush Underwater Survey [Pre-Dive] 04/19/2024

240419-7

HNP-M- Diving Operations for Fuel Cart Repair - Job Coverage 04/19/2024

240420-3

Self-Assessments AR 02346343 2023 EPRI Alpha Assessment 09/06/2023

AR 02449739 10CFR20 Radiation Protection program content and 03/11/2024

implementation

71124.03 Miscellaneous HNP Alpha Characterization Report Cycle 24 04/13/2023

HNP Beta Radiation Characterization 04/23/2023

71124.05 Corrective Action 02513938 Corrections to calibration records. 04/24/2024

Documents

Resulting from

Inspection

71151 Miscellaneous Electronic Dosimeter dose and dose rate alarm logs Various

5/1/2023 through 3/26/2024

71152A Corrective Action 2512713

Documents 2512716

2431026

2447811

2498471

Drawings 2166-B-041 Power Distribution and Motor Data 480V MCC 1A21-SA Revision 38

6-B-401 Control Wiring Diagram 7.5KVA Inverter Interconnection Revision 13

Channels I, II, III, IV

14