ML20127G973
| ML20127G973 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/14/1993 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20127G949 | List:
|
| References | |
| 50-498-92-17, 50-499-92-17, NUDOCS 9301220135 | |
| Download: ML20127G973 (29) | |
See also: IR 05000498/1992017
Text
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AP.PJNDIX A
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-498/92-17
50-499/92-17
Operating Licenses: NPF-76
NPf-80
Licensee: Houston Lighting & Power Company
P.O. Box 1700
Houston, Texas 77251
facility Name: South Texas Project Electric Generating Station (STP), Units 1
and 2
Inspection At: STP, Matagorda County, lexas
inspection Conducted: May 26-29 and August 28 through September 15, 1992
Inspectors: J. I. lapia, Senior Resident inspector, STP,
Project Section D. Division of Reactor Projects
W. f. smith, Senior Resident inspector, Waterford-3,
Project Section A, Division of Reactor Projects
R. A. Kopriva, Senior Resident inspector, Cooper Nuclear Station,
Project Section C,- ivision of Reactor Projects
n /
Approved: 6 Ut I M_
Arthur 1. Howell,1151, Project Section D. Ud[-e 'l N" b
Division of Reactor Projects
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Inspection Summary
Areas inspected: A special inspection was e.onducted to determine the
circumstances surrounding a May 19, 1992, event that resulted from a system
engineer's discovery of a Technical Specificatton Surveillance Requirement
that had never been implemented and to assess the implementatica effectiveness
of licensee's programs and procedures for_ identifying and correcting
conditions adverse to quality. The inspection also reviewed the circumstances
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of a September 3, 1992, event that resulted from a loss of power to the
digital rod position indication system and.the subsequent initiation of plant
shutdown of Unit 1.
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Results:
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= five apr arer,t violations were identified:
(1) The first apparent violation involved a failure to satisfy a
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Technical Specification Surveillance Requirement. Failure to
oerform the required surveillance test of the manual reactor trip
circuit shunt trip coils resulted because the surveillance
procedure did not independently test the shunt trip feature
(Section 1.2). _
(2) The second apparent violation involved the failure of cor * rant
licensee personnel to immediately inform the Shift Supers ars of
a Teshnical Specification surveillance deficiency, once it was
known. This notification was required by the licen;ee's station
i problem reporting procedure (Section 1.3),
(3) The third apparent violation involved a failure to implement
adequate corrective action for a problem identified on April 9,
1992, which concerned a perceived adverse impact associated with
the initiation of station problem reports (SPRs). This failure
contributed to the lack of the initiation of an SPR on May 18-19,
1992 (Section 1.4).
(4) The fourth apparent violation involved a failure on June 8 and
September 3, 1992, to follow procedures for the issuance of
guidance pertaining to Technical Specifications (Section 2.3).
(5) The fifth apparent violation involved a failure to provide -
complete and accurate information to NRC pursuant to 10 CFR 50.9
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(Section 3).
- The lact ,
cedural guidance for requesting a temporary waiver of
complian s . c:nsidered a weakness (Section 1.3).
- The lack of time requirements for determining the operability of safety-
related systems er.d components that are in an indeterminate status was
considered a weakness (Section 1.3).
- The inspectors identified instances in which events that are required to
be reported to NRC pursuant to 10 CFR 50.72 were not reported within the
speci fied time. An additional example was identified by NRC during
another inspection and a Notice of Violation was issued (Section 1.4).
Summary of Inspection Findings:
- Apparent Violation 498;499/9217-01 was opened (Section 1.2).
. Apparent Violation 498:499/9217-02 was opened (Section 1.3).
. Apparent Violatier. 498;499/9217-03 was opened (Section 1.4).
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. Apparent Violation 498:499/9217-04 was opened (Section 2.3).
. Apparent Violation 498;499/9217-05 was opened (Section 3).
Attachments;
e Attachment 1 - Persons Contacted and Exit Meetings
. Attachment 2 - Simplified Diagram of Auto / Manual Reactor Trip Circuit
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DETAllS
1 PLANT SHUTOOWN INITIATED BECAUSE A TECHNICAL SPECIFICATION SURVEILLANCE
REQUIREMENT WAS NOT SATICFIED (UNITS 1 AND 2) (93702)
1.1 Overview
On May 19,1992, at 5:01 and 5:05 p.m., the licensee initiated an orderly
shutdown of Units 2 and 1, respectively, pursuant to Technical
Specification (TS) 3.0.3, which requires, in part, that, when a Limiting
Condition for Operation is not met, except as provided in the associated -
action requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, action shall be initiated to place the
unit in a mode in which the TS does not apply. Both units were operating at
full power. This action was initiated because the licensee identified that a
manual reactor trip system surveillance had not been adequately performed,
thus rendering both trains of the reactor trip system inoperable for both
units.
Technical Specification 3.3.1, Table 3.3-1, specifies that the minimum number ,
of operable channels of the manual reactor trip function is two. To verify
operability of these channels, Table 4.3-1 of TS Surveillance
Requirement 4.3.1.1 requires, in part, that the reactor trip breaker shunt
trip (ST) feature be tested independently at least once per 18 months while
testing the manual reactor trip function. During a review of the applicable
surveillance test procedure, a System Engineer discovered that the independent
test had not been implemented since initial startup of each unit. Not meeting
this surveillance requirement rendered both trains of the reactor trip system
inoperable for eacn unit. At 2:30 p.m., on May 19, 1992, licensee management
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declared both units to be in TS 3.0.3 but did not inform the Shift Supervisor
until approximately 5 p.m., or about 1 1/2 hours beyond the time required by
TS 3.0.3 to initiate action to shut down the units. Further, the licensee
failed to take this action until prompted by NRC (after NRC was informed by
the Plant Manager that the units had been in TS 3.0.3 since 2:30 p.m.) during
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a conference call that the licensee had initiated to request a temporary
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waiver of compliance (TWOC) from the applicable TS Surveillance Requirement.
A Notification of Unusual Event (NOVE) was declared in accordance with the
licensee's emergency plan at 5:06 p.m. At approximately 5:45 p.m., NRC
granted a TWOC from the provisions of TS 4.3.1.1, Table 4.3-1, Functional
Unit 1, until a one-time emergency TS amendment could be reviewed by NRC. The
shutdown of both units was terminated at approximately 80 percent power, at
which time the licensee exited the NOUE. The licensee was subsequently
granted a one-time, emergency TS amendment on June 2, 1992, to allow continued
operation of both units, without performing the surveillance, until the next
planned or unplanned shutdown of each unit.
1.2 Manual Reactor Trj_p_ Surveillance
lhe inspectors conducted a review of the technical aspects of the surveillance
test omission. TS Surveillance Requirement 4.3.1.1, Table 4.3-1, Functional
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Unit 1, Note 14, requires that a Trip Actuating Device Operational
Test (TAD 01) of the manual reactor trip actuation undervoltage and 51 circuits
be performed. Note 14 requires that these circuits be tested independently.
Attachment 2 of this report is a diagram that depicts an auto / manual reactor .
trip circuit. HS1 and HS2 are the designators for the two manual reactor trip handswitches. Each control room has two manual reactor trip handswitches ,
with two outputs on each switch. One output actuates the Train R reactor trip
breakers and the other actuates the Train S reactor trip breakers. Operation
of either switch deenergizes the undervoltage coils in all the main and bypass
trip breakers through the R and S logic trains. At the same time, the shunt
trip coils on all breakers are energized in order to trip the breakers.
The portion of the diagram within the dotted line represents the modification
which resulted from the Salem Anticipated Transient Without Scram (ATWS)
y
event. This modification was installed in the main breaker ST circuit as
required by Generic Letter 83-28, " Required Actions Based on Generic
Implications of Salem ATWS Events." item 4.3 of Generic Letter 83-28
established the requirements for the automatic actuation of a ST attachment
for Westinghouse plants. The automatic ST modification was based on the
generic design developed by Westinghouse under the sponsorship of the
Westinghouse Owners' Group. The generic design was submitted to the NRC on
June 14, 1983, and a Safety Evaluation Report was issued on August 10, 1983,
endorsing the design. The modification provides for automatic actuation of
the reactor trip breaker ST mechanism on a condition which deenergizes the
undervoltage coils. The " Block" designation within the dotted line represents
the " Block Auto Shunt Irip" switch. This switch is intended to be used during
the TADOT voltage measurements to preclude sensing the application of power to
the ST coil via the automatic ST feature. This switch must be depressed in
order to independently verify the operability of the ST and undervoltage trip
circuits for the manual reactor trip function, as required by TS for the main
trip breakers. The ST circuit on the bypass breakers can be tested
independently by measuring the voltage across the ST coils.
During a biennial review of Surveillance Procedure IPSP03-RS-0002, Revision 2,
" Manual Reactor Trip TAD 0T," a system engineer determined that the' procedure
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did not independently test the manual ST function because. the " Block Auto -
Shunt Trip" switch was not' required to-be manipulated during:the TA00T. This
step is necessary in order to test the set of contacts that directly completes
a current path to the ST device, which trips the breaker. AsLa result, these
contacts had not been independently tested by the manual reactor trip TADOT
procedure. The system engineer also noted that the surveillance procedure
f ailed to independently verify operabil_ity of the ST- circuit _ on the reactor
trip bypass breakers because voltage was not measured across the bypass
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breaker ST' coils during the TAD 0T.
The . inspectors reviewed Generic Letter 85-09, " Technical Specifications for
Generic Letter 83-28, item 4.3." Ge7evic Letter 85-09 was issued to all
Westinghouse pressurized water reactor licensees and applicants, including
South Texas Project (STP), to inform the licensees- and applicants- that. TS
changes should be proposed to explicitly require independent testing of the.
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undervoltage and ST circuits during power operation and independent testing of
the control room manual switch contacts during each refueling outage. The
inspectors noted that Generic Letter 85-09 provided explicit guidance on
independent testing of the ST circuit in that it stated that the " Block Auto
Shunt Trip" switch would have to be used to preclude sensing the application
of power to the ST coil via the automatic ST feature. Although the licensee's
15 reflected this independent testing requirement, the appropriate test
methodology was never incorporated into the subject surveillance procedure.
Licensee personnel could not explain how the omission occurred.
The failure to satisfy the requirements of TS Surveillance Requirement 4.3.1.1 -
is an apparent violation (498;499/9217-01). The licensee has initiated
actions to revise the TADOT procedures in order to properly perform the TADOT
during the next shutdown of each unit.
1.3 ticensee Identification and Correction of Problem
The inspectors reviewed the procedures and programs that the licensee had in
place to disposition the problem described in Section 1.2 and conducted
interviews with involved personnel. After reviewing and evaluating
Interdepartmental Procedure IP-1.450, Revision 8, " Station Problem Reporting,"
the inspectors concluded that the problem reporting process at STP, if
followed, appeared adequate to ensure the prompt identification,
documentation, reporting, and correction of safety-related problems. The
inspectors also reviewed Interdepartmental Procedure IP-1.58Q, Revision 1,
" Preparation of Justifications for Continued Operation (JCO)." This procedure
interfaced with Interdepartmental Procedure IP-1.45Q in that, when an SPR was
submitted to the Shif t Supervisor, the Shif t Supervisor was responsible for
determining whether the deficiency described in the SPR rendered any safety
systems inoperable as defined in the TS. The inspectors noted that, if the -
SPR resulted in an " indeterminate" condition concerning the operability of
safety-related systems or components, the Plant Manager was to be contacted
and the Shift Supervisor was to indicate on the SPR that a JC0 was required.
The inspectors determined that plant operation could continue with safety
systems in an indeterminate condition for an indefinite period since there was
no explicit guidance on when the JC0 must be completed. The inspectors
considered this lack of procedural guidance to be a weakness. However, the
inspectors did not iden-ify any examples in which a TS allowed outage time was
exceeded without appropriate action taken while a JC0 was being processed.
The JC0 procedure addressed the possibility that a TWOC may be appropriate in
certain instances. However, there was no reference made to any procedure to
follow in requesting a TWOC. The inspectors verified that there was no such
procedure in place. The inspectors considered this lack of procedural
guidance to be a weakness.
The inspectors discussed with the licensee the JC0 procedure and its
relationship to the SPR procedure. The licensee stated that they were
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developing a new corrective action program that will replace the SPR -
procedure, and that the two NRC-identified weaknesses already were being
addreased.
The inspectors conducted reviews of the SPRs and other documentation related
to the shutdown event described in Section 1.1 and interviewed key licensee
personnel involved in order to gain an understanding of how the licensee -
handled the problem and whether the actions taken were in accordance with the
licensee's corrective action program. The inspectors identified the following.
event chronology:
. On May 18, 1992, at approximately 3:30 p.m., a system engineer
identified a potential TS surveillance deficiency in: Station.
Procedure IPSP03-RS-0002, Revision 2, " Manual-Reactor Trip TAD 0T " th:t,
if valid, may render both redundant trains of the manual-reactrc t 1?
circuits for both- units-inoperable. Because the' System Enginet*
realized that such a condition may require both units to be. shut uver
he discussed the. issue with his supervisor and a nuclear licensins-
supervisor at approximately 5 p.m. However, since additional ~reiiew vas
needed to determine whether the surveillance deficiency wasfvalie, the y
decided not to work overtime on the potential problem, but agreet to
initiate a thorough study of the issue the following day.
. On May 19, 1992, at approximately 8:15 a.m., the Licensing Manager-was
informed of the potential problem.
- On May 19, 1992, at approximately 8:30 a.m., the Corrective Action.
Group (CAG) Administrator was informed of the potential problem. The
CAG Administrator informed the Plant Manager and the Plant Operations
Manager at approximately 9:40 a.m., after the: plan-of-the-day meeting.
The Plant Operations Manager told- the_ inspectors that_ he did not
understand the shutdown implications of the deficiency at that_ time.and_
went on to other meetings.
. At 10 a.m., a meeting was held to discuss the technical aspects of:the
trip circuit and the requirements for TS surveillance testing, fThe
meeting was attended by plant engineering and licensing personnel. By
12 noon, no conclusive determination had:been made and. individuals were
assigned various tasks in order to obtain-additional-information. They-
decided-to reconvene the meeting at 2 p.m.-
- . At _approximately 12 noon,- the Plant Manager was briefed by the Licensing;
. Manager that there was a likely problem regarding operability of_'the
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reactor trip circuitry.
. At approximately 12:30'p'.m.,;the NRC Senior Resident Inspector'(SRI) was
informed of the potential problem-and was told that there would be a
meeting at 2Jp.m. to further discuss the issue.
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- At 2 p.m., a meeting was held by plant engineering and licensing
personnel. The Plant Manager, the SRI, Institute of Nuclear Power
Operations representatives, and independent Safety Engineering Group
personnel were also present. No Plant Operations Department personnel
were present. Licensee personnel die. cussed the TS surveillance
requirements as they related to the circuits in question. The
applicability of TS 4.0.3, which allows a delay of the applicable TS
action requirements for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (for those TS that have allowed
outage times that are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), to implement a missed
surveillance or obtain a TWOC from NRC, was discussed. The
applicability of TS 4.0.3 was dismissed by the licensee because the ___
subject surveillance requirement had never been performed.
- At 2:30 p.m., with no apparent Plant Operations Department involvement
since 9:30 a.m., the Plant Manager concluded that the manual reactor trip circuit in question had not been tested, as required by TS, and
that both units were not in compliance with TS Surveillance
Requirement 4.3.1.1. As a result, the Plant Manager concluded that a
shutdown of both units was required by TS 3.0.3. The SRI acknowledged
the declaration and departed to inform Region IV management and to
discuss a potential licensee request for a lWOC since the circuits could
not be tested while the reactors were at power.
- At approximately 2:45 p.m., the Licensing Manager directed the issuance
< of an SPR.
- At approximately 2:50 p.m. , the Plant Manager directed that the SPR
(92-0200) be delivered to the Plant Operations Manager with inst ructions
for him to discuss the issue with the Plant Manager before informing
both control rooms. _
- By 3:30 p.m., the Plant Manager and Licensing Manager had briefed the-
Group Vice President, and the decision was made by the licensee to
pursue a TWOC request.
- At approximately 3:40 p.m., the Plant Operations Manager was given the
SPR while he was in route to the SRI's office. This appeared to be the
first time a Plant Operations Department representative became involved
in the process. The Plant Operations Manager told the inspectors that
he still did not recognize the plant shutdown implications of the SPR at
that time.
- At approximately 4 p.m., a conference call commenced between the
licensee, Region IV personnel, and Office of Nuclear Reactor
Regulation (NRR) personnel, to discuss the licensee's request for a
TWOC. The licensee was not prepared to answer NRC's questions, nor had
the Plant Operations Review Committee (PORC) concurred in the TWOC
request as required by NRC guidance that was available to and previously
used by the licensee.
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- At approximately 4:15 p.m., a second conference call was convened in the
SRI's office with licensee management personnel, Region IV personnel,
and NRR personnel. During that conversation, when Region IV management
questioned the licensee as to the status of the actions required by
IS 3.0.3, it became apparent that the Shift Supervisors of both units
had not been informed that TS 3.0.3 had been invoked by the Plant
Manager at approximately 2:30 p.m. As a result, the required plant
shutdowns had not been initiated, nor had an NOVE been declared. The
Shift Supervisors of both units were immediately informed by the Unit 1
Operations Manager following the completion of the conference call. -
- At 5:01 p.m., Unit 2 commenced a shutdown in accordance with TS 3.0.3.
- At 5:05 p.m., Unit I commenced a shutdown in accordance with TS 3.0.3.
- At 5:06 p.m., an NOUE was declared in accordance with the licensee's
- At approximately 5:35 p.m., the'PORC meeting concluded with a
recommendation that the Plant Manager approve the TWOC request.
- At approximately 5:45 p.m., a TWOC was granted by NRC, and power was
levelled at about 80 percent on both units. This TWOC allowed for
continued operation of both units until an emergency TS amendment could
be reviewed by NRC. The one-time TS amendment was subsequently app ;ed
on June 2, 1992.
Interdepartmental Procedure IP-1.45Q, Revision 8, " Station Problem Reporting,"
Step 6.1.1, requires that any person who discovers a condition that may impact
the safe and reliable operation of the plant shall originate an SFR and, if -
the condition appears to require immediate response, the originator shall
report the condition immediately to the Shift Supervisor. Contrary to this
requirement, on May 18, 1992, a condition that had the potential to impact the
safe and reliable operation of the plant was discovered during the review of
Surveillance Procedure IPSP03-RS-0002, Revision 2, " Manual Reactor Trip
TA00T," and an SPR was not originated. In addition, on May 19, 1992, after
generating an SPR and knowing that the condition required immediate response,
cognizant licensee personnel did not report the condition immediately to the
Shift Supervisor. Failure to follow Interdepartmental Procedure IP-1.45Q is
an apparent violation (498:499/9217-02).
1.4 Review of SPRs
The inspectors reviewed other completed and in-process SPR records in order to
assess the degree of compliance with the established programs and procedures.
The inspectors reviewed operability and reportability determinations and
evaluated the acceptability and timeliness of corrective actions taken or
planned by the licensee.
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The inspectors reviewed Procedures IP-1.45Q, IP-1.58Q, and OPGP03-ZA-0088,
Revision 1, " Station Procedure for Nonsafety-Related Request for Action
Program." Ten SPR packages that had been issued during 1991 and 1992 were
reviewed, of which the majority had been completed. Some SPRs reviewed
required operability and reportability determinations. Operability
determinations of equipment appeared to be accurate and timely and complied
with TS and plant procedures. Some of the SPRs reviewed included JC0 reports
which had been generated as a result of particular operability determinations.
The JCOs complied with the licensee's procedure and appeared to be adequate.
Upon completion of the SPR reviews, the inspectors found that the scope of the -
licensee's corrective actions program appeared to be adequate. The
inspectors, however, made the following observations pertaining to the
implementation of the SPR program. First, there were approximately 495 SPRs
written in 1991, and 214 SPRs written (as of the time of the May 26-29 portion
of the inspection) in 1992. The inspectors determined that there were
numerous extensions requested, and granted, to complete the SPRs. The
inspectors noted that numerous extensions, resulting in delayed corrective
actions, could lead to repetitive problems. Second, the inspectors identified
that certain events were not reported to NRC in a timely manner. The
inspectors identified a few SPRs in which it took the licensee several days to
determine whether a system actuation (e.g., an engineered safety feature
system actuation) was required to be reported to NRC in accordance with
10 CFR 50.72 and 50.73. On several occasions, reporting of certain actuations
to NRC was required, but they were reported late. This issue was previously
identified by NRC (refer to NRC Inspection Report 50-498/91-30; 50-499/91-30).
An additional example of failing to satisfy the 10 CFR 50.72 time requirements
was identified by NRC in August 1992 during the conduct of a routine resident
inspection. A Notice of Violation was issued for this occurrence (refer to -
NRC Inspection Report 50-498/92-26; 50-499/92-26).
The inspectors also reviewed SPR 92-0128. which was issued on April 9, 1992,
to investigate the cause of a reactor coolant system excessive couldown
transient. As a result of the investigation, the licensee determined that
there was a reluctance on the part of plant personnel to use the station
problem reporting process. Several statements by personnel knowledgeable of
the transient indicated that, in their opinion, the problem resolution system
did not solve problems and that the adverse impact associated with the
initiation of an SPR was not conducive to its use. The corrective action
planned to address this issue was to reiterate the requirement for personnel
to initiate an SPR when events occur or issues arise that need management
attention to ensure that the appropriate evaluations are performed. The
inspectors considered this corrective action to be inadequate because it did
not address the underlying causes of the perceived adverse impact associated
with the initiation of an SPR. The inspectors concluded the failure to
initiate an SPR in a timely manner for the May 18-19, 1992, event also to have
been caused, in part, by a reluctance of some station personnel to initiate an
SPR because of a perceived adverse impact. The failure to implement effective
corrective actions is considered an apparent violation of the requirements of
10 CFR 50, Appendix B, Criterion XVI (498:499/9217-03).
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2 PLANT SHUTDOWN INITIATED BECAUSE OF A LOSS OF DIGITAL R0D POSITION
INDICATION (93702)
2.1 Overview
On September 3,1992, the Digital Rod Position Indication (DRPI) system in
Unit I was declared inoperable because of a f ailure of both power supplies.
As a result, the action statements of TS 3.1.3.2 could not be met and TS 3.0.3
was entered at 10:49 a.m. Attempts to repair the system within the 1-hour
allowance of TS 3.0.3 were unsuccessful and, at 11:49 a.m., an NOUE was
declared and operators began taking actions to shut down the reactor. At -
1:52 p.m., reactor power reduction was commenced from 86 percent. The unit
had been in a power coastdown in preparation for the upcoming refueling
outage. While continuing with the reactor shutdown, instrumentation and
control personnel were able to identify the source of the problem and
initiated the replacement of one of two power supplies. At 2:15 p.m., the
power supply replacement was completed, and the DRPI system was returned to
operabl e . Also at this time, the reactor power reduction was terminated after
reaching 75 percent. TS 3.0.3 was exited at 2:26 p.m. and, at 3:04 p.m.,
operators commenced increasing reactor power at 5 percent per hour. The
reactor was returned to 85 percent power during the morning of September 4,
1992.
2.2 Licensee Identification and Correction of the Problem
The DRPI system is powered by two power supplies with an auctioneering
function to permit power supply transfer in the event of a failure of one
power supply. Power supply failure, as sensed by low output voltage, is
annunciated to alert control room operators of a power supply problem. During
this event, both power supplies failed and there was no indication on the main
control haard of a power supply failure. Preliminary investigation into the
cause of the failure indicated that the backup power supply was in a degraded
condition, such that output voltage was sufficient to indicate satisfactory
standby operation but, when loaded, was not able to maintain rated voltage.
At the end of the inspection, the licensee was continuing to investigate the
cause of the failure of both power supplies.
2.3 Licensee Policy for Complying with TS 3.0.3
As a result of the event on May 19, 1992, the Plant Operations Manager issued
a memorandum on June 8, 1992, to the Policies and Practices Manual providing
guidance to plant operators upon entering TS 3.0.3. This memarandum stated
that, "It is the policy of the Plant Operations Department that when we enter
a Technical Specification statement requiring the unit to be placed in Mode 3
in the next six hours we will immediately upon entry into that six hour time
block:
- Declare an unusual Event based on a shutdown required by Technical
Specifications, and
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- Commence an orderly plant shutdown in accordance with OPGP-ZG-0006, e
' Plant Shutdown from 100% to Hot Standby' at a rate of approximately 20X
per hour.
- The ramp rate may be adjusted with the permission of the Unit Operations
Manager."
During this event, control room operators were in the process of implementing
this guidance when, at 11:48 a.m., 2 minutes before entry into the 6-hour time
block, a f acsimile was received in the control room from the Plant Operations
Manager This facsimile was a memorandum, dated September 3, 1992, which was -
intended to supersede the June 8, 1992, memorandum, it stated, "It is the
policy of the Plant Operations Department that when we enter a Technical
Specification action statement requiring the unit to be placed in Mode 3 in
the next six hours we will upon entry into the six hour time block:
- Up to two hours may be used for emergency repair or troubleshooting at
the Shift Supervisor's discretion. In all cases the Shift Supervisor
shall allow sufficient time for a controlled and orderly shutdown,
- After the two hours have expired or earlier at the discretion of the
Shif t Supervisor, declare an Unusual Event based on a shutdown required
by Technical Specifications, and
. Commence an orderly plant shutdown in accordance with OPGP-ZG-0006,
' Plant Shutdown from 100X to Hot Standby' at a rate of approximately 20X
per hour.
. The ramp rate may be adjusted with the permission of the Unit Operations
Manager."
-
This second memorandum resulted in a certain degree of confusion on the part
of some operators because they were being directed to change the method of
TS 3.0.3 implementation while they were preparing to implement the June 8,
1992, guidance. There was no basis provided with the memorandum and it
appeared to have contradicted the requirements of Procedure OERP01-ZV-IN01,
" Emergency Classification," which, according to plant operators, they had been
trained to interpret as requiring the declaration of an NOUE after the
expiration of the TS allowed outage time for those TS that require a plant
shutdown. For this event, the Shift Supervisor declared an NOUE at the end of
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, consistent with past practice.
The inspector conducted interviews of various licensed operators subsequent to
the event and determined that there was a general feeling that the change to
existing policy during an event was inappropriate. Most operators interviewed
also believed that the contents of the memorandum should have been more
appropriately handled through a formal TS Interpretation.
The inspector reviewed the licensee's procedures for the control of formal
interpretations of TS requirements. Procedure OPGP03-ZO-0018 Revision 4,
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" Technical Specification Interpretation Control," is required to be used for
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those situations which are not clearly or specifically addressed by wording in
the TS. The procedure also states that its purpose is to provide'a mechanism
for approving clarifications and formal interpretations of the TS. In
addition, Procedure OPGP03-Z0-0040, Revision 0, " Maintenance of the Operations
Policies and Practices Manual," states that memoranda from whatever source
that are potentially TS interpretations should be formally routed by the
initiating authority through the formal evaluation process for inclusion in
Addendum 1 of the TS. Addendum I is the document that contains all TS
Interpretations. Both the June 8 and the September 3, 1992, memoranda
provided guidance which is not clearly or specifically addressed by the
-
wording in TS 3.0.3. As a result, the Plant Operations Manager should have
utilized Procedure OPGP03-ZO-0018 instead of issuing memoranda to provide
guidance to the control room operators for implementing TS 3.0.3. The failure
to follow the procedural requirements of Procedures OPG03-ZO-00lG and
OPG03-ZO-0040 is considered an apparent violation (498;499/9217-04).
3 MANAGEMENT MEETING (30702)
As a result of the special inspection on May 26-29, 1992, a meeting was held
on August 28, 1992, in the Region IV office to permit the NRC to gain a better-
understanding of tre licensee's actions relative to the May 19, 1992, event.
NRC requested that the following issues.be addressed:
- Provide a detailed chronology as well as a description of the facts
surrounding the period from the initial identification of the potential
deficiency by the System Engineer, apparently'at 3:30 p.m. on May 18,
1992, until the Shift Supervisors were notified of the condition on
May 19, 1992. Given the implications associated with the potentially
missed surveillance (i.e., apparent TS violation and potential for-plant
-
shutdown), why was this issue not pursued until conclusion during the
evening of May 18, 1992.
- Given that the Plant Manager was directly involved in the operability
determination and that there apparently was a piocess in place to ensure
that theRShift Supervisors are informed of contitions such as this
(i.e., the SPR procedure), why were the Shift Supervisors not informed
of this condition until prompting by the NRC?
- Given that STP managers and staff have successfully utilized the.TWOC
process-on several occasions in the past and have at least requested the
use of the process more than any other facility in Region IV, why was
the process not followed for this particular event? Describe the-nature
of any deliberations specific to-the TWOC process that occurred prior to
initiating a conference call-with NRC on May 19, 1992.
- Provide a full description of senior management's expectations relative
to issues that have the potential.for plant shutdown. In' addition,
describe senior management's understanding of-and involvement-in the
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issue on May lo, 1992. What are the corrective actions taken or planned
to prevent recurrence of this and similar events?-
- What was the process for making the operab'ility. determination and
subsequent determination of the applicability of the appropriate-TS?
Did this process conform to established guidance? What is management's
expectation and guidance relative to implementing the requirements nf
The licensee presented.a chronology of the event and detailed the corrective
actions that were taken or planned. Appendix B is a copy of the material that
the licensee presented at this meeting. During this meeting, the licensee
acknowledged that the SPR procedure had not been properly implemented. The
licensee stated that an SPR should have been originated on May 10, 1992, and
that the control room operators should have been informed of the problem at
the time of discovery. The former plant manager indicated that the licensed
control room operators should have been informed of the condition at
2:30 p.m.: however, he stated that his priorities were to make the best safety-
judgement (i.e., there was adequate safety basis for not shutting down both
units because of this condition), to request a TWOC from NRC as soon as
possible, and then inform the licensed operators. He stated, that on May 19,
1992, he was convinced that he could comply with the license requirements and
still get a TWOC before it was necessary to direct a shutdown of both units.
As a result of this meeting, the licensee committed to provide additional
information requested by NRC and respond, in writing, to several questions
asked by NRC. These included:
- At what time on May 18, 1992, did the individuals stop investigating the
possibility that surveillance of the ST circuitry had not been
performed? Was overtime a consideration in not continuing to
investigate this potential problem on May 18, 1992?
- On May 18, 1992, did the individuals working on the ST surveillance
issue recognize the possibility that a plant shutdown might be required
if the surveillance had not been performed?.
- When and under what circumstances did the Shift Supervisors or any other
licensed operator become aware of the ST surveillance testing issue?
What did thev learn at'that time?
. Was Generic Letter 85-09 referenced in the ST ' surveillance procedure
that existed on May 18, 1992? Were the individuals who were reviewing-
the issue on May 18, 1992, aware of the applicability of Generic
letter 85-09 before the 10 a.m. meeting on May 19, 1992? Provide the
specific details of determining the inoperability of the ST circuit as
pursued by the Nuclear Licensing and Plant Engineering Departments.
Was the need to write an SPR (or the fact that one had not been
prepared) discussed any time prior to 2:30 p.m. on May 19, 1992,
particularly at the 10 a.m. meeting on May 19, 1992?
. . - - . . - - . . - - . .. .- - . - .. . . . -
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- Did anyone from the control room-(shift supervisor) attempt to contact
station management regarding the ST surveillance-issue? If so, describe
the circumstances and response provided.
- Provide a copy of the procedural guidance that existed on May 19, 1992,
regarding the implementation of TS 3.0.3.
- Provide a copy of the licensee investigation of the May 19, 1992, event.
_
The licensee provided a written response 05. September 11, 1992 (Appendix C).
At the September 15, 1992, exit meeting, NRC noted, in general terms, that
there were some inconsistencies between the September 11, 1992,: written
response and previous verbal responses to NRC questions at the August 28,-
1992, management meeting and information obtained by the inspectors during the
conduct of the special inspection.. The details of these discrepancies are .
provided in the following paragraphs.
3.1 Decision to Discontinue Investigation on Ma_y 18. 19_92
During the first portion of the special inspection that was conducted _during__
the period of May 26-29, 1992, the inspectors determined from interviews with
licensee personnel, that, since additional reviews were needed to determine
whether or not the-licensee was complying with the applicable TS Surveillance
Requirement, they would not work overtime but pursue the issue the following-
morning. At the August 28, 1992, management meeting, licensee management
personnel stated that the bases for not pursuing the issue on the evening of
May 18, 1992, were: (1) the' safety <ignificance was low because there was
multiple redundancy associated with the reactor trip system; and'(2)-the
individuals involved were not certain of the TS Surveillance Requirement.
However, in the supplemental response of September 11, 1992, the. licensee
indicated that these individuals believed that the subject surveillance
procedure satisfied- the applicable TS Surveillanc'e Requirement, and -the only_
valid issue of concern was whether the surveillance procedure test methodology *
was appropriate.
Subsequent to the August 28, 1992,- management meeting,_ discussions with the '
two System Engineers who were reviewing the potential surveillance deficiency
on May 18, 1992, revealed-that only one of- these individuals believed that the =
1 surveillance procedure satisfied the TS Surveillance Requirement, while the
System Engineer who identified the surveillance deficiency believed that there-
was a potential that the TS Surveillance Requirement was not satisfied by. the
surveillance procedure. _10 CFR 50.9 requires,;in part, that-information
provided to NRC shall be complete and-accurate.in all material' respects. _The
failure to accurately respond-to_NRC's request for.informatio_n relative tol the
discontinuation of:the licensee's review of the shunt trip devicelsurveillance
deficiency on May 18,:1992, constitutes an example of an' apparent violation of
10 CFR 50.9 (498;499/9217-03).
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'3.2 Procedural Requirements for implement-ing TS 3.0.3
During the August 28, 1992, management meeting, the former-Plant Manager
stated that there was a procedure-that-implemented the requirements of
TS 3.0.3 that prevented-him from directing the licensed operators to not-
initiate--a power reduction-immediately after the expiration of I hour _-
following the entry into TS 3.0.3. When questioned further by NRC, he stated
it would have taken longer than I hour to implement the procedure revision-
process in order to change the guidance to the operators. The former Plant
Manager stated that, as a result, the operators would have commenced the
shutdowns of both units before a procedure revision could be implemented,
thereby making unnecessary the need for.a TWOC.
In the September 11 1992, response, the licensee indicated that.the only t
guidance in effect during the May 19, 1992, event that pertained to TS 3.0.3l
was contained in the Plant Operations Department Policies and-Practices
Manual. Although this policy provided management expectations regarding the
voluntary entry into TS 3.0.3 and restated the action requirements, it did not
provide specific implementation steps to be taken following entry into
TS 3.0.3. Although not specified in the licensee's response, NRC determined <
that the same guidance (in the form of a TS Interpretation) is also contained
in Addendum 1 of the Houston Lighting & Power Company TS. The inspectors
concluded that the information provided at.the management meeting was. ,
inaccurate. The failure to provide accurate.information to NRC constituted-
'
the second example of an apparent violation of 10'CFR 50.9 (498;499/9217-05).
3.3 Initiation of an SPR
During the August 28, 1992, managemcnt-meeting, NRC-asked whether the
initiation of an-SPR was discussedoat any time on May 19, 1992, prior to-
2:30 p.m., particularly at the 10 a.m. meeting which was attended by the
Nuclear Licensing Manager. The Nuclear Licensing. Manager stated that he did
not ask about-the initiation of an SPR after he became aware of the issue at
approximately 8:15 a.m., on May 19, 1992,- and_he was not certain-whether._an
_
'SPR was discussed at the 10 a.m. meeting. On the basis _ of the information'
provided in the September 11, 199T, response, the status of a draft SPR was
discussed at'the beginning of the 10 a.m. meeting.
3.4 Additional Supplementary Information
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'
-The licensee submitted an additional written response on September 18, 1992,
(Appendix D), to provide clarification of the apparent discrepancies that- were
- identified following the September 15, 1992, exit meeting. NRC reviewed this,
additional information 'and: found that it provided no additional pertinent
information relative to the issues discussed in Sections 3.1-3.3.
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ATTACHMu 1
1~ PERSONS CONTACTED
1.1. Licensee Personnel
- C. Ayala, Supervising Engineer, Nuclear Licensing
- J. Blevins, Supervisor, Procedure Control
- C. Bowman, Corrective Action Group (CAG) Administrator
'
- M. Chakravorty, Executive Director, Nuclear Safety Review Board
- R, Chewning, Vice President, Nuclear Support
- R. Dally-Piggott, Engineering Specialist, Nuclear Licensing
,
- D. Denver, Manager, Nuclear Engineering
- S'. Eldridge, Senior Consulting Saecialist, Quality Assurance
- R. Garris, Manager, Nuclear Purciasing and Material Management- .
- J. Gruber, Director, Independent Safety Engineering Group
.
+ *D. Hall, Group Vice President
- A. Harrison, Supervising Engineer, Nuclear Licensing
- S. Head, Consulting Engineer, CAG
- T. Jordan, General Manager, Nuclear Assurance
+#*W. Jump, Manager, Nuclear Licensing
.
- W. Kinsey, Vice President, Nuclear Generation
- D. Leazar.. Manager, Plant Engineering
+ *J. Ledgerwood, Consulting Engineering Specialist, CAG
- J. Lovell, Director, Nuclear Generation Projects
- M. Ludwig, Administrative Participant Services
- M. McBurnett, Manager, Integrated Planning and Scheduling
- T. Meinicke, Senior Consultant, Planning and Assessment
- G. Midkiff, Manager, Plant Operations
- H. Pacy, Division Manager, Design Engineering Department
+#*G. -Parkey, Plant Manager
- G. Ralston, Manager, Facilities-
- K. Richards, Division Manager, Maintenance
- S. Rosen, Vice' President, Nuclear Engineering
- J. Sharpe, Manager, Maintenance
- B. ledder, Supervisor, Procurement- Quality - Assurance -
- L. Weldon,-Manager,' Operations Training
+ *M. Wisenburg, Special Assistant to Group Vice President
1.2 Contractor Personnel (Newman and Holtzinger)-
' #G.~ Edgar
- J. Newman
+W. Baer
- 1.3 Owner Representative .
+M. Hardt,. Director, Nuclear Division, City Public-Service Board San Antonio-
~
l.4 NRC Personnel
- A. Beach, Director, Division of Reactor Projects (DRP), Region IV
+S. Black Director, Project Directorate IV-2 (PDIV-2), 0ffice of-Nuclear
.
i Reactor Regulation (NRR)
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40. Boal, investigator, Region-lV Office of Investigations
+W. Brown, Regional Counsel, Region IV
+S. Collins, Director, Division of Reactor Safety, Region IV
+G. Dick, Senior-Project Manager, NRR
- +R. Evans, Resident inspector, DRP, Region IV
+#J. Gilliland, Public Affairs Officer, Region IV
- G. Guerra, Radiation Specialist. Intern, DRP, Region IV
+T. Gwynn, Deputy Director, DRP, Region IV
B. Hayes, Director, Office of Investigations
+#A. Howell,_ Chief, Project Section D, DRP, Region IV
- R. Kopriva, Senior Resident inspector, DRP, Region IV
+J. Milhoan, Regional Administrator, Region IV
+J. Montgomery, Deputy Regional Administration, Region IV
+G. Sanborn, Enforcement 0fficer, Region IV
- W. Smith, Senior Resident inspector, DRP, Region IV
- J. Tapia, Senior Resident inspector, DRP, Region IV
- Denotes personnel that attended the exit meeting on May 19, 1992.
- Denotes personnel that attended the exit meeting on September , 1992.
+ Denotes personnel that attended the management meeting on August ~ 28,.1992.
In addition to the personnel listed above, the inspecto'rs contacted other-
personnel during this inspection period.
2 EXIT MEETING
An exit meeting was conducted on May 29 and again on September 15, 1992.
During these meetings, the inspector reviewed the scope and findings of the
report. On January 4,1993, durit g a telephone conversation conducted betwee:
NRC and the licensee, the licensee was informed of an additional apparent
violation that is documented in Section 3 of this report. The licensee did
not identify as proprietary any information provided to, or reviewed by, the
inspectors,
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ATTACFJ4ENT 2:
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APPENDIX B ,
,
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION j
,
HL&P - NRC MANAGEMENT MEETING j
TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992 j
AUGUST 28,1992
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HL&P - NRC MANAGEMENT MEETING
TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992
AUGUST 28,1992
AGENDA
_
e Opening Remarks D. P. Hall
e Event Chronology .W.J. Jump
e Specific Information. M. R. Wisenburg
- f
e Corrective Actions G. L Parkey
'
e Closing Remarks D. P. Hall
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TECHNICAL SPECIFICATION O.0.3 ENTRY ON MAY 19,1992
EVENT CHRONOLOG1
Monday, May 18 =1530 e System Engineer discovered possibility that a portion of the shunt trip
circuit may not be tested in accordance with Technical Specification
requirements
- Not sure whether this' portion of circuit may have been tested under
other procedures
- Uncertainty as to precise scope / meaning of Technical Specification
e issue discussed with immediate supervisor
'
=1700 e issue discussed with Nuclear Licensing
e Review of procedures and drawings not yet complete; Technical
Specification' requirements still not fully understood; Insufficient
information to conclude that a probiera actually existed -
Tuesday, May 19 = 0815 e Licensing Manager informed of potential problem
0830 e Corrective Action Group (CAG) Informed of potential problem
0940 e CAG informed Plant Manager and Plant Operations Manager of
potential problem > ,
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TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992
E_ VENT CHRONOL _OGY (Continued)
Tuesday, May 19 1000 e Meeting conducted with attendance by Plant Engineering Department,
Design Engineering Department, Nuclear Engineering Department, CAG,
and Nuclear Licensing
e Conclusion reached that the contacts should be tested; however,
whether testing was required by Technical Specifications was still
unknown
1200 e Meeting adjourned with plans to meet again at 1400
e Four actions discussed in meeting were to be completed:
- Contact Westinghouse concerning bases for Technical Specification
- Review relevant WCAP in detail
- Review Maintenance records for testing of shunt trip
- Review Generic Letter
e Nuclear Licensing Manager briefed Plant Manager on status, pending
actions, and 1400 meeting
1230 e Nuclear Licensing Manager briefed NRC Senior Resident inspector on
situation
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TECHNICAL SPECIFICATION 3.0.3 ENTHY ON MAY 19,1992
i EVENT CHRONOL _OJX (Continued)
Tuesday, May 19 1400 e Meeting reconvened with additional attendance by: Plant Manager,
INPO, independent Safety Engineering Group (ISEG), and NRC Senior
Resident inspector
e Plant Operations Department not present at meeting
1430 e Conclusion reached that shunt trip portion of the reactor trip circuitry
had not been tested and that it was required to be tested
e Licensee determined to be operating outside of 8ts required boundaries,
and that Technical Specification 3.0.3 was applicable
e NRC Senior Resident Inspector informed of this conclusion, and notes
that 1430 was the time at which it was determined that Technical
Specification 3.0.3 was applicable
1435 e Senior Resident inspector left meetireg to brief other NRC personnel.
HL&P believed his intent was to discuss the 3.0.3 condition and HL&P's
consideration of request for Temporary Waiver of Compliance. -
1445 e Meeting concludes with Nuclear Licensing Manager directing the
issuance of a Station Problem Report (SPR)
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. _ _ . -_- _ _ _ _ _ . _ _ _
TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992
EVENT CHRONOLOGY (Continued)
Tuesday, May 19 1450 e Plant Manager directs that SPR be delivered to Plant Operations ,
Manager with instructions to discuss issues with the Plant Manager
before informing the Control Rooms
1500 e Plant Manager and Nuclear Licensing Manager brief Group Vice
President on the situation and plan to request Temporary Waiver of
Compliance
i
1540 e SPR delivered to Plant Operations Manager en route to Senior Resident
inspector's office for conference call with NRR and Region IV
o Conference call conducted to discuss HL&P plans to request a
Temporary Waiver of Compliance
e Conference call attendees include Plant Manager, Nuclear Licensing
Manager, Plant Operations Manager, and Senicr Resident inspector
~1600 e Plant Operations Manager concerned about operability of shunt trip ~
contacts
e Plant Operations Manager contacts Unit 1 Operations Manager
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TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992
EVENT CHRONOLOGX (Continued)
NRC advised
Tuesday, May 19 1605 e Conference call ends for NRC closed discussion.
Licensee that call would be resumed after the NRC discussion.
e Licensee attendees retire to Plant Manager's office
1615 e Second conference call occun in Senior Resident inspector's office
e Unit 1 Operations Manager is present for second conference call
e Method for requesting Temporary Waiver of Compliance was initially
discussed, with conversation later turning to plant shutdown status
=1630 e Statements made during conference call lead Plant Operations
representatives to conclude that affected circuitry should have been
declared inoperable at 1430
1640 e Plant Operations determines that Technical Specification 3.0.3 was
applicable and a shutdown of both units should immediately commence
=1650 e Unit 1 Operations Manager contacts Unit 2 Shift Supervisor to inform
him of the situation and directs unit shutdown
5
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TECHNICAL. SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992
EVENT CHRONOLOGY (Continued)
Tuesday, May 19 ~1655 e Unit 1 Operations Manager contacts Unit 1 Shift Supervisor to inform
him of the situation and directs unit shutdown
1701 e Unit 2 Control Room declares entry into Technical Specification 3.0.3
and commences shutdown
1705 e Unit 1 Control Room declares entry into Technical Specification 3.0.3
and commences shutdown
e Plant Operations Review Committee meeting commences
1706 e Unusual Event declared
1735 e Plant Operations Review Committee meeting concludes with
recommendation that Plant Manager epprove Temporary Walver of .
Compliance
1745 e NRC grants Temporary Waiver of Compliance
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TECHN'ICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992
EVENT CHRONOLOGY (Continued)
-Tuesday, May 19 1751 e Unit 1 terminates shutdown
5 1752 e Unit 2 terminates shutdown
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1753 e Unusual Event terminated
.
SPECIFIC INFORMATION
o Control Room Notification ,
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TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992
CORRECTIVE ACTIONS
e Testing of the manual shunt trip will be performed during the next outage where the plant is
in MODE 3 or lower for each unit. Testing of the manual shunt trip will be performed
periodically during future refueling outages.
e A verbal Temporary Waiver of Compliance was granted by the NRC on May 19,1992, followed
by a written authorization on May 21, 1992. A license amendment to the Technical
Specifications was approved by the NRC on June 2,1992.
e As an immediate action, the surveillance procedures which test the trip function of tiie reactor
trip and bypass breakers were reviewed for similar deficiencies with no adverse findings.
e . An indepth review of ESFAS and reactor trip surveillance procedures for one train of one unit
is underway to ensure they adequately meet Technical Specification requirements. In each
instance where a discrepancy has been noted, an SPR has been promptly provided to the
control room. This review will be completed by November 3,1992.
e Written guidance was developed regarding the implementation of Technical Specification 3.0.3.
8
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TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992 ;
_C_ORRECTIVE ACTIONS (Continued)
!
e Instructions dealing with " potential operability" problems and promptly informir.g the Shift
Supervisor have been included in the new Corrective Action Process which becomes effective
on September 9,1992.
e Formal procedures are being developed which address the handling of unresolved problems i
from an operations standpoint and how operability decisions are made and implemented.
These procedures will be developed by September 25,1992.
. A formal procedure is being developed governing the processes inv ilved with obtaining a
Temporary Waiver of Compliance. This procedure will be completed by September 25,1992. ,
I
e The Vice President, Nuclear Generation, discussed the lessons learned from this event with
the licensed operators. i
e An evaluation of the timeliness of problem identification has been conducted to determine
whether issues are normally provided to the control room in a timely manner.
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TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992
.
CORRECTIVE ACTIONS (Continued)
o -The event was discussed at the regular site management status meeting to emphasize
Executive . Management's support of the role of the Shift Supervisor in making operability
determinations. t
e Licensing processes were reviewed to determine the need to provide formal guidance on how
to perform other non-routine activities such as the Temporary Waiver of Compliance.
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