IR 05000255/1991015
| ML18057B313 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/03/1991 |
| From: | Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057B312 | List: |
| References | |
| 50-255-91-15, NUDOCS 9110140086 | |
| Download: ML18057B313 (14) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report N ~255/91015(DRP)
Docket No. 50-255 Licensee: Consumers Power Company 212 West Michfgan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating.Plant Inspection At:
Palisades Site, Covert, MI Inspection Conducted:
August 13 through September 23, 1991 Inspectors:
J. K. Heller J. R. Roton C. H. Brown Z. Falevits Approved By:
Reactor Inspection Summary Chief Section 2A DATE License No. DPR-20 DCT t Inspection on August 13 through September 23, 1991 * (Report N /91015(DRP))
Areas Inspected:
Routine unannounced safety inspection by resident and Region III based inspectors of actions on previously identified items, plant operations, maintenance, surveillance, reportable events, NRC Region III requests and a management meetin There were no Safety Issues Management System (SIMS) items reviewe Results: No violations or deviations were identifie Strengths were identified in improving plant cleanliness, in publishing plant philosophy on maintenance activities during operating conditions, in critiquing a simulator exercise, in involving multiple disciplines to address a backshift instrument operability issue, and in maintaining a control room annunciator 11 black board.
No weaknesses were identifie One Unresolved Item was identified relating to a pote~tially unauthorized temporary modification resulting from maintenance (paragraph 3).
91 10140086 911003 EDR ADOCK 05000255 w
DETAILS Persons Contacted Consumers Power Company
- D. P. Hoffman, Vice President, Nuclear Operations
- D. W. Joos, Vice President, Energy Supply
- G. 8. Slade, Plant General Manager R. M. Rice, Plant Operations Manager
- D. J. VandeWalle, Engineering Programs Manager
- T. J. Palmisano, Administrative and Pl~nning Manager
- R. D. Orosz, Nuclear Engineering & Construction Manager
- P. M. Donnelly, Safety & Licensing Director
- T. W. Bowes, Manager, Mechanical, Civil/Structural
- J. L. Kuemin, Palisades Licensing Administrator
- G. J. Gerling, Safety Analysis Supervisor
- 8. D. Meredith, Senior Engineer
- R. 8. Jenkins, Senior Engineer
- 8. A. Low, Supervisor, 8.0.P. Systems Engineering
- M. A. Ferens, Project Manager
- P. A. Harden, Associate Engineer
- K. M. Haas, Radiological Services Manager J. L. Hanson, Operations Superintendent
- R. 8. Kasper, Maintenance Superintendent
- K. E. Osborne, System Engineering Superintendent D. D. Hice, Chemistry Superintendent L. J. Kenaga, Health Physics Superintendent C. S. Kozup, Technical Engineer
~W. L. Roberts, Senior Licensing Anilyst R. -w. Smedley, Staff Licensing Engineer Nuclear Regulatory Commission (NRC)
- A. 8. Davis, Regional Administrator
- E. G. Greenman, Director, Division of Reactor Projects
- T. 0. Martin, Deputy Director, Division of Reactor Safety*
- H. B. Clayton, Chief, Projects Branch 2
- B. -E. Holian, Licensing Project Manager, NRR
- M. P. Phillips, Chief, Operational Programs Section
- B. L. Jorgensen, Chief, Projects Section 2A
- J. H. Neisler, Team Leader, Palisades EDSFI
- McConnell, Geologist
- J. K. Heller, Senior Resident Inspector
- J. R. Roton, Resident Inspector C. H. Brown, Project Engineer E. R. Schweibinz, Project Engineer
- Denotes some of those present at the Management Meeting on August 20, 199 *Denotes some of those present at the Exit Interview on September 30, 199 *
Other members of the plant staff and several members of the contract security* force were also contacted during the inspection perio.
Actions on Previously Identified Items (92701, 92702) (Closed) Violation.255/89018-2b(DRP): Failure to process a Temporary Modification when a water-tight door to the East safeguards room was blocked ope The licensee acknowledged this violation and stated that the violation was caused by personnel erro Training has been provide In addition, administrative procedures were revised to more effectively control the integrity of the flooding and ventilation envelope of both safeguards room The inspector has observed that the doors are controlled in accordance with plant procedure (Closed) Unresolved Item 255/89034-03(DRP):
Unanalyzed method used to test t_he containment spray pump The licensee determined that a high volume flow path used to test the containment spray pumps was unacceptable during power operation. The flow path did not have automatic isolation capabilities when recirculating to the Refueling Water Storage Tank (RWST) and could become an unmonitored release path during an acciden The licensee discontinued use of the high volume recirculation line. *A low volume flow line equipped with automatic isolation valves is now being used instea The inspector questioned if the test methodology with the high volume flow rate was an unreviewed safety question when used during power operatio The licensee agreed and asked the NRC Office of Nuclear Reactor Regulation (NRR)~by letter dated December 28, 1989, to review the issu Currently the licensee uses both a high and low volume flow to test the pum The high volume flow path is used during cold shutdown and the low volume flow path is used during power operatio During the management interview, the inspector informed the licensee that the December 28, 1989; letter was not being reviewed by NR The letter did not provide the information requi~ed for NRR to process an unreviewed safety questio This information had previously been discussed with the license No violations, deviations, unresolved or open items were identifie.
Operational Safety Verification (71707, 71710, 42700)
Steady state facility operating activities were observed as conducted in the plant and from the main control roo This included the performance of reactor operators and senior reactor operators, shift engineers, and auxiliary equipment operator These observations also included procedure use and adherence, records and logs, communications, shift/duty turnover, and the degree of professionalism of control room activitie Observations of the control room monitors, indicators, and recorders were made to verify the operability of emergency systems, radiation monitoring systems, and nuclear reactor protection system Reviews of surveillance, equipment condition, and tagout logs were conducted.
Proper return to service of selected components was verifie **
- General The unit began and ended the reporting period at essentially 100 percent powe Boron Sample c.
The inspector routinely reviewed the shift supervisor log On August 22, the logs documented that a chemistry technician manipulated the wrong valve during safety injection tank samplin The chemistry technician had sampled the safety injection and refueling water (SIRW) storage tank instead of the four safety injection tank The valving erro~ was the subject of corrective action document D-PAL-91-13 The inspector noted that the four boron readings documented the correct boron concentration in the SIRW tank but varied over a range of approximately 1.5 percen This appeared to be excessiv The results were discussed with the chemistry superintendent, who acknowledged that the differences in readings were excessive for a SIRW tank at steady stat However, the tank was being mixed because a large quantity of water had been added the previous shif The mixing takes approximately 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The inspector had no additional questions pertaining to the reading The valving error will be resolved by the corrective action progra Tours (1)
During a previous inspection period, the inspector noted a declining trend in the cleanliness of the turbine building and diesel generator room During this inspection period, the inspector observed that personnel have cleaned the turbine building and diesel generator room The licensee has maintained a high cleanliness standard in the auxiliary buildin (2) Tours of the control room were routinely mad During these visits the inspector observed that manning requtrements were always met, that the plant operated with essentially a black board, that the operators were cognizant of changing plant conditions, the equipment status board and LCO board were maintained up-to-date and the operators were performing assigned tasks in accordance with plant procedure Activities observed were:
(a)
Control rod exercising (b)
Safety injection bottle sampling (c)
Daily and shift control room surveillances (d)
Primary coolant leak rate calculations
- *Equipment Control The licensee has published a policy memo (JLH 91*084) pertaining to maintenance activities during power operation The policy placed controls on the planning, s~heduling, LCD time management, redundant component control and parts.management for non-emergency corrective maintenance activitie In addition, strict controls were established for preventive maintenance activities to require justification or to combine the preventive maintenance activity with non-emergency corrective maintenance activitie The policy appears to be a logical approach to minimize the risk associated with conducting maintenance activities during power operatio Simula tor The inspector observed two crews during simulator trainin The training exercise pertained to a reactivity anomaly during startu Both crews properly diagnosed the problem and implemented the appropriate corrective actio The inspector attended the post exercise critique for one of the crew The critique was well managed and provided for student and instructor evaluation (strength and weaknesses) of operator performance and a discussion of administrative duties such as visitor contro.72 Notification On August 5, the licensee determined that a potential inter-system loss-of-coolant-accident (LOCA) scenario existed in which a postulated break* in the primary coolant pump integral heat exchanger could result in an over-pressurization of the component cooling water (CCW) syste This could potentially cause a break in the CCW piping outside containment and provide a path for primary coolant leakage outside containmen A preliminary evaluation of the radiological consequences of this inter-system LOCA indicated the site boundary thyroid dose limit, as specified in 10 CFR 100, would be exceeded in approximately 90 minutes if the leak were not isolate Licensee corrective action included determining if the postulated failure must be addressed as part of the design basis, determining the appropriate modifications to mitigate the consequences of the potential inter-system LOCA, providing operator training on identification and mitigation of this inter-system LOCA and documenting the radiological consequences of this inter-system LOC The inspector had no additional question However, this issue will be evaluated when Licensee Event Report 91017 is reviewed by the NR Safety System Walkdown The inspector verified operability of the Service Water System by verifying system alignment using Palisades 11Service Water System Checklist 11, CL No. 15.l; piping and instrumentation diagram
M-208, sheets lA and lB; and p1p1ng and instrumentation diagram M-21 This walkdown included a verification that major flow pat~ valves were in their correct positio No items were found that degraded the syste Removal From Service of Pressure Switch-0918 The inspector reviewed Deviation Report D-PAL-91-147, which details the removal from service of Pressure Switch PS-0918, 11Component Cooling Water Pump Discharge Pressure.
On August 27, 1991, Work Order (WO) 24104127 was initiated to investigate a ground in PS-0918 which had caused spurious starts of the P-52A and P-52C Component Cooling.Water (CCW) pumps when the *pumps were placed in the standby condition.. As a result of this investigation, the control links between points Xl and Xl4 on scheme 13TVA were opened, removing PS-0918 from servic PS-0918 was designed to automatically start the P-52C CCW pump on coincident loss cif offsite power, a Safety Injection Actuation Signal (SIAS), and a low CCW pump discharge pressur Palisa.des Technical Specification 3.4.1.c requires that heat exchangers, valves, piping and interlocks associated with the containment cooling system and required to function during accident conditions be operable during plant operation PS-0918 may be an interlock addressed by this Technical Specificatio On September 9, a Shift Engineer who was reviewing the system lineup in preparation to perform a*back shift surveillance test questioned whether PS-0918 was an interlock addressed by Technical Specification 3.4. He addressed the question to the Operations Superintendent and to personnel from the licensing and accident analysis grou From subsequent interviews, the inspector established that considerable manpower was spent to deter~ine operability of PS-091 The licensee personnel determined that PS-0918 was not captured by the Technical Specification because the accident analysis only credits one component cooling water pump during the injection phase of an acciden As a result of the operability question, however, the Operation Superintendent requested that a deviation report be prepared to address this issu On September 10, D-PAL-91-147 was reviewed by the Corrective Action Review Board (CARB).
The jmmediate corrective actions were:
(1)
To add PS-0918 to the LCO Board to alert the Shift Supervisors of 11 the potential sensitivity of P-52A in relation to P-52C.
(2)
To revise caution tags on P-52A and P-52C control switches to reflect the lack of a standby feature with PS-0918 remove **
Additionally, Temporary Modification (TM)91-069 was authorized to allow for the opening of the links on PS-091 On September 12, 1991, authorization for TM 91-069 was removed and PS~0918 was replace Operating restrictions on P-52A and P-52C were lifte Whether Technical Specification 3.4.1.c applies to the interlocks that are designed to function during an accident, or only to interlocks credited in the accident analysis, remains under inspector revie In this case, the licensee does not take credit for P-52C during the injection phase of an acciden The inspector will review the operability question furthe Also, the inspector continues to evaluate whether a Temporary Modification was required when WO 24104127 removed PS-0918 from service on August 27, 1991, rather than well after the fact on September 1 This is an unresolved item pending further review (Unresolved Item 255/91015-0l(DRP)).
One unresolved item was identifie No violations, deviations, or open items were identifie.
Maintenance (62703, 42700)
Maintenance activities in the plant were routinely inspected, including both corrective maintenance (repairs) and preventive maintenanc Mechanical, electrical, and instrument and control group maintenance activities were included as availabl The focus of the inspection was to ensure the maintenance activitie reviewed were conducted in accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with Technical Specification The following items were considered during this review: the Limiting Conditions for Operation were met while components or systems were removed from service, approvals were obtained prior to initiating the work, activities were accomplished using approved procedures, and post maintenance testing was performed as applicabl The following activities were inspected: Work Order (~iO) 24100025, 11Spent Fuel Pool Level and Temperature Ca l i brat ion.
WO 24104176, "Deluge VLV To Main Transformer Sprinkler."
WO 24104517, "Fuel Pool Building Crane."
WO 24103307, "Field Verification of Cable G06R/C04R-G30/9" The inspector accompanied the electrical craft during their field walkdown of cable circuit No. ID-G06R/C04R-G30/9 for scheme No. G06 Walkdown results of this circuit indicated that seven of the twelve VIAs "Routing Cards" were incorrect for electrical
schedule E3 Further review of completed circuit walkdown coversheets and plant electrical schedule (E33) sheets associated with corrective action package E-PAL-91-016 indicated that the majority of the routing information shown on these documents did not conform with field installation The licensee continues to evaluate these discrepancie The evaluations included Appendix R consideration No violations, deviations, unresolved or open items were identifie.
Surveillance (61726, 42700)
The inspector reviewed Technical Specifications required surveillance
- testing as described below and verified* that testing was performed in accordance with adequate procedure Additionally, test instrumentation was calibrated, Limiting Conditions for Operation were met, removal and restoration of the affected components were properly accomplished, and test results conformed with Technical Specifications and procedure requirement The results were reviewed by personnel other than the individual directing the test and deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The following activities were observed: Q0-17 DW0-13 M0-29 Inservice Test Procedure Charging Pump*P-55 LLRT Inner/Outer Personnel Air Lock Sea Engineer Safety System Alignmen (Service Water System Positions)
~or the following, the inspector performed a detailed review of the procedure using drawing M-208 (sheets IA and lB), drawing M-213, FSAR section 9.1, Standard Order 54, and the applicable Technical Specificatio In addition, a detailed review of selected completed surveillances produced no examples of incorrectly completed checklist All steps were correctly completed or properly resolve MR-36 Service Water Collection and Calibration Q0-14 Inservice Test Procedure: Service Water Pumps RT-BC Engineered Safeguards System - Left Channe RT-80 Engineered Safeguards System -Right Channe R0-71G-l Service Water System Inservice Leak Tes No violations, deviations, unresolved or open items were identifie.
Reportable Events (92700, 92720)
The inspector reviewed the following Licensee Event Reports (LERs) by means of direct observation, discussions with licensee personnel, and
,.
r2view of record The review addressed compliance to reporting requirements and, as applicable, that immediate corrective action and appropriate action to prevent recurrence had been accomplishe (Closed) LER 255/91012:
Reactor Trip Caused By Two Failed Components In The Reactor Protective System (RPS).
While the licensee was evaluating a thermal margin/low pressure*problem associated with the 11A 11 channel, a faulted electrical path occurre This caused the 11 Hi 11 pressurizer pressure contacts in channels 11A11 and 110 11 to open, resulting in a reactor tri The electrical fault was apparently associated with the age of the reactor protective syste The trip and plant response were discussed in Inspection Report No. 50-255/9101 Part of the corrective action included changeout of the RPS during the next outag At the request of the Resident Inspector, this was*the topic of telephone conversations between the licensee and NRR to ensure that problems encountered by other utilities during changeout of the RPS were resolved prior to the start of the changeou The other utility had planned to change out the RPS under 10 CFR 50.59 until the NRC advised them that a license amendment was require The amendment requires prior NRC review and approval, whereas 50.59 changes do no Additional corrective actions included bypassing all the trips on a channel when working on a channe This was observed during surveillance and repair activitie In addition, the licensee has developed a method to monitor the integrity of the RPS during surveillance testin The inspector observed the development of this metho As a result of this trip and other unusual indications associated with the RPS, the licensee has increased the operator awareness and lowered the threshold of management involvemen (Open) LER 255/91014: Safety Related Circuits Routed With Opposite Channel Circuit The licensee started a cable and raceway upgrade program in May 1990, to update the Circuit and Raceway Schedule data bas The data base was missing important design data such as channel numbers, scheme numbers and routing informatio This upgraded data base documentation was then used to identify potential routing discrepancie The licensee internal corrective action document E-PAL-91-016, documented a condition outside the design basis of the plan Thirty-eight safety related circuits were identified as being routed in the opposite (redundant) channel racewa Left channel circuits were routed in right channel raceways and vice vers FSAR Section 8.5.31 stated that circuits belonging to safety-related power distribution channels, reactor protection system channels, engineered safeguard channels, or other safety-related system channels would be placed in separate
raceway system The FSAR*also stated that physical separation (distance) would be considered the most reliable method of providing circuit separation and isolatio An NRC electrical specialist was on site on July 15 and August 7, 1991, to evaluate the licensee 1 s actions regarding this issu The inspector reviewed engineering documents and design drawings, interviewed engineering personnel, and observed field cable walkdown/verification activitie Based on his i~itial evaluation, the inspector determined that the conclusions reached in E-PAL-91-016 were based solely on inconsistencies found in design documentatio Actual field verification, to confirm the cable misroutings, has not been accomplishe During subsequent discussions between the licensee and NRC management, the NRC confirmed that the thirty-eight cables were being field verifie The licensee performed the field verifications using a cable electromagnetic signal inducer to determine the routing of the cabl The walkdowns determined that the majority of the thirty-eight cables originally reported as misrouted were, in fact, correctly routed in the plan However, the drawings and data base (which were also used as the basis for the event report) were incorrec The field walkdowns identified seven misrouted cables - five RPS circuits and two for V-24C, 11 EDG 1-2 room cooling fan.
The licensee performed an operability evaluation for the misrouted circuits and concluded that the d~sign deficiency did not affect operability of the reactor protection system because of their fail safe logic desig However, the misrouting of the V-24C circuits resulted in the EOG being declared inoperable because of conditionally inadequate ventilation in the DG roo The licensee provided alternate cooling to the room by implementing a temporary modification to block open the exhaust and recirculation dampers associated with V-24C and issued instructions on how to provide DG room cooling in the event V-24C is los Review of past occurrences relative to this issue indfcated that in 1978, Nuclear Service Corporation had identified that there existed left channel cabling in right channel trays and right channel cabling in left channel trays. In addition, event reports PAL-89-147, PAL-90-040, PAL-90-221 and PAL-90-222 were issued in the past to document and address misrouted circuit On August 2, 1991, the licensee informed the inspector that the number of cables to be walked down had increased from thirty-eight to seventy-on This increase was due to additional findings discovered during cable walkdown Some field routed cables were found missing from the design drawings and data bas These cables needed to be walked down in their entirety before
- they could be added to the-design document The licensee stated that an engineering evaluation would be performed for every discrepant or misrouted cable., This w.ill determine the actual classification (safety or non-safety related) of the cable and its impact on plant operability, and will ensure that deficiencies will be appropriately dispositione The licensee issued LER 91-014 on August 8, 1991, describing this even The LER included future corrective actions to be taken to address circuit channelization and separation deficiencie The physical separation and channelization deficiencies that have been identified so far appear to result from: (1) lack of documentation of routing activities during construction; (2) lack of adequate design document updates for modifications; and (3)
lack of uniform design criteria and design documents for separation and routing of electrical circuit The licensee has taken some corrective actions to address the noted deficiencies by revising administrative procedures and engineering guidelines to prevent recurrenc Licensee remedial actions to address the identified discrepancies are noted in LER 91-01.
Following the initial findings, the licensee stated that strong consideration will be given to expanding the sample of cables to be field verified in order to identify installations that do not meet design requirements. The inspector believes that a much larger sample of installed cables needs to be field verified to determine the extent of the problem (misrouted cables vs. wrong drawings). (Closed) LER 255/91015: Plant Trip Following a Trip of the 11A
Main Feedwater Pum The plant response to the reactor trip was discussed in Inspection Report No. 50-255/9101 The most probable cause of the 11A 11 feedwater pump trip was a high resistive short across the reset push button contact This was also believed to be the most probable cause of two plant trips during 199 Part of the corrective action implemented included rep 1 acement of the push button. on both the 11A 11 and 118 11 Main feedwater pump No violations, deviations, unresolved or open items were identifie.
Region III Requests (92705 and TI 2515/112)
By memorandum dated July 9, 1991, NRC Region III management requested a review of the methodology used by the licensee to evaluate public health and safety issues (Temporary Instruction (TI) 2515/112) resulting from changes in population distribution or in industrial, military, or transportation hazards that could arise on or near the sit The inspector conducted the review, in accordance with guidelines provided in TI 2515/112, and found that the licensee has no formal program
designed to address the aforementioned issue Further, there are no administrative requirements to conduct periodic evaluations of changes to the environs around the site. This information was provided to Region III for evaluatio Any additional questions will be handled by separate correspondenc No violations, deviations, unresolved or open items were identifie.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviation An unresolved item identified during the inspection is discussed in Paragraph.
Management Meeting (30702)
1 A routine management meeting, attended as indicated in Paragraph 1, was conducted in the NRC Region III offices on August 20, 199 The licensee made presentations on the following topics: Engineering - the status of selected projects, a summary of results from a contracted self-assessment in the piping and support engineering area, and resolution proposals for various problems were discusse Configuration Control Project - project status and a summary of findings were discusse Unreviewed Safety Question - actions already taken and actions under consideration to mitigate against a design vulnerability involving piping to the Safety Injection Refueling Water (SIRW) tank were discusse Reactor Trip July 3, 1991 - the event, its root cause and corrective actions were discusse Reactor Protection System (RPS) Modification - the scope, schedule, and selected safety review and engineering_
implications of the replacement of RPS relays planned for April 1992, were discusse NRC Region III staff asked questions on selecte&-topics, which licensee staff answere No violations, deviations, unresolved or open items were identifie Manaaement Interview
~
The inspectors met with licensee representatives - denoted in Paragraph 1 - on September 30, 1991 to discuss the scope and findings of the inspectio In addition, the likely informational content of the inspection report with regard to documents or processes reviewed
,.
)
by the inspectors during the inspection was also discusse The licensee did not identify any such documents/processes as proprietar Highlights of the exit interview are discussed below: Discussed closure of Unresolved Item 255/89034-03(DRP) and informed the licensee that the unreviewed safety question associated with the pump flow path was not a current review item with NRR (paragraph 2.b).
The site licensing department acknowledged that they had placed the requested evaluation on hold pending further site evaluatio Discussed LER 9101 This LER was assigned to a Region III specialist and will remain open pending additional reviews by Region III (paragraph 6.b). Strengths noted:
(1)
Improvements in the cleanliness standards of the Diesel Generator rooms and Turbine Building (paragraph 3.c(l). The acting plant manager acknowledged the observation and stated t~at the size of the cleaning staff had recently been increase (2)
Published plant philosophy on maintenance activities during power operations (paragraph 3.d).
(3)
Post simulator exercise critique (paragraph 3.e).
(4)
Involvement of multiple plant disciplines when operability of PS-0918 was questioned on the back shift (paragraph 3.)
(5)
Essentially a 11 black board 11 during plant operations 3.c(2). There were no weaknesses identifie The 10 CFR 50.72 notification was discusse Additional review will be perfor~ed when the LER is evaluated (paragraph 3.f). The unresolved item pertaining to pressure switch PS-0918 was discusse Basically, the inspector was not convinced that the licensee interpretation of interlock for accident conditions was correc This requires additional research by the inspecto A second part of this item pertains to the need for a temporary modification when a work order was still open'but the work coul~
not be completed (paragraph 3.h). The Region III request pertaining to how the licensee evaluates changes to the surrounding environmen Any additional follow up will be handled by separate correspondence (paragraph 7). An item that was discussed at the exit and not documented in the report pertained to waiver-of-complianc The licensee was informed that Region III expects that a utility will research and
evaluate all options, effectively manage the waiver-of-compliance time limit and disseminate the provisions of the NRC guidance on waiver-of-compliance to the staf Good and poor examples of how other utilities have managed waiver-of-compliance were discussed.
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