ML20198J729
| ML20198J729 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/10/1998 |
| From: | Hickle B FLORIDA POWER CORP. |
| To: | |
| Shared Package | |
| ML20198J675 | List:
|
| References | |
| NUDOCS 9801140197 | |
| Download: ML20198J729 (30) | |
Text
.
Florida Power C 0 R P O 84 A 1 i 0 N
)
CRYSTAL RIVER U NIT 3 t
i i
4 OVERALL RESTART-READINESS
$d Yk]W i
B. J. tilckle i
Director, Restart Q
A K
N
- t PDR
. - _.. _. _.. p. _. _ _ _... _ _ _
Key issue CR 3 performed a substantial amount of work that covered a broad spectrum of issues. A key issue was ensuring the work was integrated -
such that FPC has confidence that the changes, when considered together, result im meeting restart objectives (e.g., reduced operator burdens, improval e
reliab!!ity, increased margins to safety, resolving long term issues, defense-in<lepth) reasonable assurance that the overall plant condition is consistent e
with the design and licensing bases Executive.
Presented in this section is a broad perspective of the restart activilles on Summary a functional and departmental level that collectively assure a state of readiness for restart in the following areas:
Organizational Readiness Opuations Readiness e
System Readiness e
- Communications Readiness Regulatory Readiness e
As a first step toward improving performance at CR 3 and achieving readiness to restart, FPC established a new, experleaced executive management team. This action was taken to achieve a prompt step-change in nuclear program performance. Since January 1997, FPC has hired a new Senior Vice President Nuclear Operations, Vice President Nuclear Production, Director Site Nuclear Operations, Director Nuclear Plant Operations, Director Nuclear Engineering and Projects, Director Nuclear Regulatory Affairs, Director Nuclear Operations Training, and Director Nuclear Site and Business Support.
Collectively, these individuals bring more than 150 years of nuclear operating, engineering, and management experience to FPC's nuclear organization. This management team has proven its ability to obtain sustained excellent performance at other operating nuclear power plants, including the restart of long-term shutdown units. These units include Davis Besse, Pilgrim, Turkey Point, Brunswick, Salem, and Millstone U_ nit 3, Additional management and supervisory _ expertise was recruited, with the addition of twenty-four personnel from outside
- CR 3. - These new personnel brought a total of 611 years of experience to the team. Many of the new team members were SRO licensed or certified at other plants, with three of these from other B&W plants of similar design as CR 3.
-With these and other personnel changes, FPC focused on restoring compliance, enhancing plant design' margins, improving the case lof
~
plant operation by reducing operator burdens, and strengthening plant 2
i h
defent.e-in depth measures. The objective was to improve the margin of l
safety, whether or not required by regulations. FPC's efforts refkict a way of doing business that means 'Do What is Right," not just for the next operating cycle, but for sustained excellent performance during the remaining life of the plant.
Consistent with this objective, FPC also took action to _ clarify its licensing basis. This, coupled with extensive System Readinest Reviews j
(SRR) - a comprehensive verification that ' plant systems meet their licensing and design bases - has resulted in a significant volume of
~
regulatory correspondence, primarily in the form of emergent
+
Unreviewed Safety Questions (USQs).
Resolving these issues has resulted in approximately twenty five submittals to the NRC, some of which require NRC action to return CR 3 to service.
This discussion summarlies the integated process used at CR 3 to identify issues that individually or collectively have the potential to impact safety, then determine the extent of condition, followed by effective technical and prograrrmatic resolution of these issues to prevent recurrence of similar problems.
These objectives were satisfied using a variety of Interrelated programs, procedures, and work activities, some o' which were modified to accommodate the unique aspects of an extended shutdown and startup.
As an example, efforts such as the Configuration Documentation integration Program (CDIP) and the Emergency Operating Procedure (f 0P) System affirmations provided a vehicle to integrate the results of the various efforts.
in addition to the extensive technical reviews that were performed, CR 3 made numerous cultural and programmatic improvements as part of the Management Corrective Action Plan (MCAP ll).
In summary, FPC has demonstrated through program completions and confirmed through independent oversight that CR 3 is ready for restart from a people, process and equipment perspective. This, in turn, has assured organizational, operational, system, communications, and regulatory readiness. Upon NRC approval of pending licensing issues, CR 3 will request the NRC Region ll Administrator's concurrence to commence reactor startup and entry into Mode 2.
Initiatives Identification of A_ schematic overview of the CR 3 Restart Management Process is tssues/ Extent of provided in Appendix 1. It consists of four elements: Sources of issue Condition.
Discovery and Corrective Actions, Assessments and Affirmations, Recommendation, and Concurrence.
3
Specific Restart Criteria (see Appendix 2) were established and used to screen identified problems documented in IPC's corrective action system.
Problems or issues were identified by System Readinets i
Reviews, NRC Commitment and Docket reviews, review of Plant Programs (e.g., Iquipment Qualification) and other focused reviews and self assessments.
A multi-disciplined Restart issue Screening Panel, chaired by the Director Restart was established to review identified problems against restart criteria. Issues that met restart criteria were placed on the IPC Restart issues list.
The systematic reviews that were conducted to identify conditions requiring screening for restart were collectively referred to as
- discovery," and had specific focus on plant systems, equipment, programs, organitation, human performance, and backlogs in all functional areas. Conditions that were determined to require correction prior to restart were initially documented either on a precursor card (condition report) or a work request (plant maintenance work order).
The use of these two processes ensured that these conditions were consistently documented, tracked, dispositioned and closed. Conditions that were determined to be restart issues were managed using the restart m&nagement program description NOD 57, " Restart Management."
Every restart issue had a Restart issue Manager assigned, who was accountable for developing and implementing an action plan to resolve the issue. A second level manager and director were also assigned to each issue to provide oversight guidance and help where needed. All parties were required to approve the action plan and approve closure of the issue when satisfactorily completed.
Meetings were held on Saturday morning to bring together senior management and the Restart Issue Managers for accountabdity and oversight purposes.
Several thousand individual items were found and documented through the Corrective Action Program. Two hundred eighty (280) restart issues were identified. Restart I: sues were problems of suffic!cnt complexity that they warranted heightened attention. Each Restart issue required numerous and significant corrective actions.
Identification of The Restart Management Process identified Testart issues and causes Restart Issues that led to the decline in performance at CR 3. The Restart Issues were uegorized in the following five areas:
Design issues Operational issues e
Organizational and Programmatic issues
. Maintenance and mcteriel condition issues Regulatory issues t
1he table below entitled 'CR-3 Restart issues," provides the status of the 280 restart issues, includmg completion of the respective deficiency area:
4
I CR 3 Restart issues Deficiency Area Total FPC Complete Design Issues 157 157 Operational Issues t9 19 Organizational and Pregrammatic issues 54 54 Maintenance arvi Materiel Condition issues 14 14 Regulatory issues 36 35 Total 280 279' F PC will close the remaining open item when NRC approval of License Amendments is complete.
System Readiness in order to evaluate the extent of condition of equipment reliability and Reviews system engineering issues, CR 3 implemented the System Readiness Review Plan (SRRP), This program was a comprehensive and systematic process designed to ensure that plant systems were thoroughly evaluated, modified (if necessary), and maintained to support restart.
The SRRP is described in detall in a separate section.
The SRR assessed CR 3's 105 plant systems using a Safety System functional Inspection (SSfl) methodology including vertical slices. T he level of inspection varied from a complete check of each SSFl attribute in the safety 4 elated systems to selected checks in the balance of plant.
SRR results and subsequent correction of identified deficiencies provided reasonable assurance that the CR-3 systems are capable of meeting their design and licensing basis requirements. This process generated over 1000 precursor cards which were each screened against the restart criteria.
Of these, approximately 300 precursors were identified as being required to be completed prior to restart. These were then integrated into restart issue action plans or the outage schedule, as appropriate, in addition to SRR, 'other focused technical program reviews were conducted which contributed to defining the ' extent of condition' addressed prior to restart. These program reviews complimented the SRR process in that they overlapped at many of the same subject areas, S
L ---
thus providing assurance that no major issues went undiscovered, for i
example, SRR resulted in certain technical specification setpoints being reviewd and validated for the designated system. These same setpoints were also validated in concert with a comprehensive program review of setpoints. Using this approach, confidence was gained that systems and equipment were designed and operated within their licensing and design basis and that interrelationships between procedures, cakulations, designs, configuration documentation, the fSAR and technical specifications were consistent and accurately integrated.
Appendix 3 lists these focused reviews and assessments.
Existing equipment conditions were also reviewed by continuous detalled reviews of the Work Request and Engineering Request backlogs. Over 30,000 corrective rnalntenance activities were incorporated into the i
integrated outage schedule as a result, Prior to restart, each of the 105 systems for unit operation was affirmed by an established multi-disciplined system team. These teams were led by the System Engineer and included a Design Engineer, as well as a Senior Reactor Operator (SRO).
IPC Restart The fPC Restart Panel was established as an oversight committee to Panel review the System Readiness Reviews, Restart Action Plans, work scope to be completed in the outage, and any other issue having the potential to affect restart.
The Restart Panel's purpose was to exercise management oversight and approval of the physical and programmatic work activilles necessary to ensure a safe restart and continued safe and reliable operation of the plant. The Restart Panel was chaired by the Director of Quality Programs, and was comprised of management personnel including the Director Site Nuclear Operations, Director Nuclear Plant Operations, Director Nuclear Engineering and Projects, Director Nuclear Operations Training, Director Nuclear Regulatory Affairs, and the Director Restart. The Restart Panel members were fully knowledgeable and familiar with the content of the CR 3 Restart Plan.
The Restart Panel functions are described in NOD 57 and included establishing expectations for the evaluation of issues and proposed actions according to the restart screening criteria and ensuring that the restart screening criteria were consistently applied by station organliations.
Backlog Various work backlogs were evaluated includir g corrective 4
Reduction maintenance work requests (WR), requests for engineering assistance (REAs), outstanding comments on plant and engineering procedures, control board deficiencies, operator work arounds, precursor cards (Corrective Action Program), temporary modifications and outstanding NRC commitments. Aggressive startup targets were established and resources allocated to reduce the backlogs to acceptable levels.
Examples of levels achieved are as follows:
6
Open Precursor Cards < 1550 with a decreasing trend, down from e
over 2100 Corrective Maintenance work requests < 200 down from 900 e
Temporary Modifications < 5 down from 8 e
Requests for Engineering Assistance < 200 down from over 750 e
Control Board Deficiencies < 10 down from nearly 100 e
Operator Work Arounds < 10 down from over 20 e
Operating procedure comments < 25 down from over 800 7echnical &
Effective technical and programmatic solutions were assured by using l'tograrnmatic re-engineered processes, bringing the right technical expertise to bear Resolution of and establishing effective communication of organizational prioritles issues and solutions.
Extensive re-engineering of the corrective action process, design control, and configuration management process were implemented early in the outage.
Corrective action process improvements included a lower threshold of problem identification (over 8,700 precursor cards were written in 1997), improved comprehensive root cause analysis; and tracking and trending mechanisms and effective closure of issues.
Design control process changes were implemented to strengthen oversight and verification of design work by the establishment of a Design Review Board (DRB). The DRB is chaired by the Manager Nuclear Engineering Design and has multiple cross functional membership.
Other process-related changes were made which collectively elevated standards for design control and brought the process in line with the best industry practices.
The Configuration Management program was re-engineered to provide definition, establish clear responsibilities, detail organizational interfaces, and put a relational database in place. Additionally, processes used to conduct operability assessments and safety analyses were improved by estabbshing a Safety Analy>ls Group and conducting site wide training in these areas.
Due to the extensive challenges of resolving engineering related issues in a timely and effective manner, additional technical expertise was recruited.
Approximately 320 additional temporary and permanent positions were added in the Engineering technical disciplines. This staffing was also intermittently supplemented by the use of ' technical experts" to provide second and third party reviews and verifications of technical work. For example, third part, reviews were conducted on root cause adequacy, emergency diesel generator modification work, 10CfR50.59 Safety Evaluations, Justifications for Continued Operation, Requests for Engineering Assistance and work control processes.
7
l r
i Organizational communications effectiveness-was improved through Implementation; of;the "CR 3 Communications Plan."
The plan j
addressed internal and external communications with the stated purpose i
of ensuring employees.have an. ongoing, workable understanding of i
CR 3's mission, goals, critical issues, regulations, and other information needed to safely and effectively perform their jobs. Communications 1
methods were defined and performance improvement was measured by
~
two separate surveys externally run by Bisconti Research Inc. These j
surveys clearly-showed that communications and the safety 1
consciousness significantly improved during the outage. The results of these surveys are shown in Appendix 4. Each of the criteria measured by - the survey resulted in an Action Plan almed at achieving performance improvement.
External communications -were also enhanced through a - series of 1
community meetings, with the general public and by meetings with i
various civic gro ips and government organizations. _ The purpose of these meetings wks to communicate our restart plans and progess.
l Plant tours were also used to enhance communications, t
i
. Comprehensive Oversight and assessment activities were provided by multiple methods i
Oversight and and levels with the intent being an !ntegation of activities to achieve fifectiveness cohesive and effective results.
Assessment of
-Restart Processes Some of these oversignt activities have been focused on key processes i
which ensure effective implemeritation of restart objectives. Examples include the Corrective Action Review Board (CARB), chaired by the Director Nuclear Plant Operations, which is charged with overseeing the adequacy of root cause evaluations and corrective action plans, and i
the Design Review Board (DRB), chaired by the Manager Nuclear Engineering Design, which is responsible for reviewing the adequacy of conceptual and final designs. Another process level oversight goup was the Restart issue Screening Panel (RISP), chaired by the Director Restart, which was responsible for overseeing the proper application of restart issue screening criteria.
Broader progam level oversight has been provided by the CR-3 Restart i
?
Panel, chaired by the Director Quality Progams, which is responsible for providing management oversight of the entire restart progarn and-j implementation _ of' NOD-57, " Restart Management." Progam level assessment of, plant startup. and powerL ascension is provided _by
' Administrative E lnstruction"Al 256, Station Readiness for Restart Sequence, Reactor Restart and Power Ascension Plan." This procedure-commences with the drawing of vacuum'in the main condenser and 1
ends after 100% power is achieved. Restart Panel oversight culminates 3
with the Panel's recommendation for startup of the reactor to the Senior'
'8
.1
-... a.. - -.
., a = -, =.a -,
,. a-
?
Vice President Nuclear Operations and the Vice President Nudear Production.
in addition to the above, independent oversight and assessment of restart activities is provided by the Plant Review Committee (PRC),
chaired by the Assistant Plant Director Nuclear Safety, Nuclear General Review Committee (NGRC) which includes several former NRC, INPO and Utility executives, and the Quality Assurance organ',zation (QA).
Also, the NRC performed specific inspections of the Corrective Action Pr ogram, 10CFR50.59 process, root cause adequacy, Emergency Operating Procedures and conducted an Operational Safety Team inspection (OSTI). All of these assessments and inspections, in the aggregate, ensure our programs were effective and continue to be effective.
A separate section entitled, " Assessing Performance and Organizational Roles," discusses these assessments and their results in detail.
Self Assessment /
The CR 3 Restart Plan includes a series of self assessments to test and independent affirm the readiness of plant, people, and processes to support restart.
Assessment These assessments encompass the following areas:
MCAP ll: Programs, organization, and human f.erformance were Management Corrective Action reviewed and conditions identified through several self assessrnent Plan, Phase 11 programs. The program that was originally put in place just prior to (MCAP II) the shutdown of the plant is "MCAP 11." This effort had identified 148 issues,32 of which were required to be resolved prior to restart.
T hese issues covered such broad conditions as operator performance, management oversight, safety
- culture, and configuration management, in addition to the self assessments, Quality Assurance conducted frequent audits and surveillances of the effectiveness of the closcout of this program's issues. A third party review was conducted that included industry peers.
This assessment was followed by an NRC team inspection of the MCAP ll program. Conclusions supported that these issues were acceptably resolved for restart.
Department Routine self-assessments were performed for support departments to e
Readiness establish an integrated linemanagement asse>sment and affirmation of system, departmental, and operational readiness for restart. These self assessments were then presented in summary form to the Director of Nuclear Plant Operations using the Al 256 procedure to ensure completeness.
Departments including Operations, Engineering,
- Training, licensing, and Security affirmed their restart readiness in accordance with the Operational Readiness Self-Assessment Program. As part of this process, each department confirmed that its assigned restart actions were complete, programs / processes were sufficient to 9
support restart and safe plant operation, and post-restart work and improvement efforts were adequately
- defined, prioritized, scheduled.
and controlled, initial Department Readiness Affirmations were completed prior to the NRC Operational Safety Team inspection. A third party assessment, that included former NRC inspectors, was then completed to ensure the self assessments were adequate, final department readiness affirmations will address developments subsequent to the initial affirmations. All affirmations are reviewed by the Restart Panel.
Operational f ach Senior Nuclear Shift Manager, Supervisor, and operating crew Readiness assessed and affirmed that the Operating Shift is satisfied with the plant materiel condition and they, as a crew, are ready to operate the unit in a safe and reliable manner.1hese affirmations, which were reviewed and approved by tht. Restart Panel and the Director of Nuclear Operations, also included a verification of Operator Training programs, establishment of an acceptable control room working environment, and verification that Operations performance expectations had been established and effectively communicated.
Restart Panel The Restart Panel reviews and evaluates several overlapping and Review o/ Restart interfacing readiness assessment results. These include the systcm, Affirmations operational, and departmental readiness affirmations; the disposition and close-out of restart items specified in each of the Restart Action Plans; the review of organizatiorul and per:,onncl readiness; other input from personnel and management; and NRC restart issues.
NRC Operational The NRC Staff conducted an independent OSTI to measure the Safety Team readiness of CR-3 for restart. Other than two potential violations in Inspection (OSTI) the Health Physics area, no potential violations were cited in the eut meeting.
Completion of After the Restart Panel completes its review of the inputs resulting from Restart Readiness the restart readiness a sessments and affirmations, the Panel will generate a letter to the Vice President Nuclear Production identifying the results of the Panel review Based on his readiness assessment, the Vice President Nuclear Production will provide recommendation to the Senior Vice President Nuclear Operations regarding the restart readiness of CR 3.
The Director Quality Programs makes an independent, written restart recommendation to the Senior Vice President Nuclear Operations based on the results of the QA Assessments and the NGRC Assessment.
Restart When the Senior Vice President Nuclear Operations believes, based on Concurrence the recommendations of the Vice President Nuclear Production, the Restart Panel, and others, that CR 3 is ready for restart, a letter. vill be written to request concurrence for restart from the NRC Region ll 10
Administrator.
Conclusion lhe CR 3 Restart Program has been effective in assuring that program objectives were met as follows:
issues affecting plant restart have been thoroughly identified and e
discovery methods were diverse and carefully integrated such that
" extent of condition" was clearly identified Effective technical and programmatic resolution of restart is:ues was achieved by tication of experienced personnel, re-engineered processes an<1 aund organizational communications e
Restart program oversight and effect!veness assessments have provided extensive assurance that intended results have been D
achieved Accomplishment of these restart objectives provides reasonable assurance that CR-3 will be operated safely and reliably within its design and licensing basis, furthermore, changes that were made to g
organliation, pme, rams, processes and materiel condition provide the foundation for the next twenty, ars of operation.
In short, this extended outage has resulted in:
improved Safety Margin e
improved Safety Analysis Process e
Improved Understanding and Documentation of the Design and e
Licensing Basis improveu Corrective Action Process e
Improved Operator Performance e
Improved Resolution cf Safety and :.icensing issues improved Materiel Condition e
improved Configuration Management e
improved Resolution of Engineering Backlog e
Improved Organization improved Internal and External Communications e
Improved long Term Planning in Place e
Appendix 5 provides specific examples and results of these improvements. Appendix 6 provides a summary of the performance indicators that were used to measure organizational, system, operations, regulatory and communications readiness. These indicators, along with improvements noted above, provide clear evidence that CR-3 is ready to restart.
l I1
. APPENDIX 1 CR-3 RESTART MANAGEMENT PROCESS MANAGEMEKr
- SYSIEM EMERGING CORREC11VE R13 TART OPERATIONS DEPARTMENT ISSUES ACTION P!AN -
REVIEW READINESS REVIEW REVII:W (MCAP)Il I.lST REVIEW I
I I
I I
I SCIIEDULE &
P!:lW0kM WORK d
MANAGE PROGRESS
& ACCOUNTABII.lTY 1
DEVELOP STATION DOCUMENT WORK READINESS FOR COMPLimON & APPROVAL RESTART SEQUENCE.
IlY Rl3PONSillLE RESTART REACTOR RESTART PANEL MEMilER AND POWER ASCENSION PLAN FORM STARTUP IIiPl.EMI:NT STATION ORGAN 17.ATION READNESS FOR RESTART SEQUENCE, REACTOR RESTART MODE RESTART AND POWER RESTRAINTS I QA OVERSIOlff ASCENSION l OF STARTUP ir RESTART PANEL OVERSIOllT ASSESSMENT A RECOMMEND REJECT o
QAINPUT SVP REVIEW A APPROVE READINESS 2
FOR RESTART A OBTAIN NRC REOK)N D REJECT CONCURRENCE NORC INPtTF 1
RESUME FUI.L POWER OPERATION 12
-. =
Y W
' APPENDIX 2 ISSUE SCREENING CRITERIA V
issues must be resolved prior to restart if they are!
1.
Required to address an operabTty issus.
2.
Required to restore acceptable design margiri or corJormance with the design bases.
3.
Required to meet restart licensing commitments or to resolve USQs needed to restore conformance with the licensing bases.
4.
Required to address an organizational, programmatic, or process deficiency that could prevent maintenance of adequate design margins or conformance with the design or licensing bases.
5.
Required to address significant equipment materiel condition deficiencies singly or in aggregate, or repetitive failures that could affect safety system availability, impact plant reliability, or reduce the ability of operators to operate the plant safely.
Issues not meeting criteria 1 through 5 above are not restart issues and will be classified as follows:
6.
a.
- Item can be scheduled for a subsequent outage.
b.
Item can be readily. worked on line, does not affect safe and reliable operations, does not represent a significant challenge to Maintenance Rule Goals or LCO Allowed Outage Time, and does not impair operations necessary to perform surveillance or monitoring.
c.
-Item is classified as minor maintenance, cosmetic niaintenance, or housekeeping, and does not affect plant operation.
d.
Item is an administrative issue.
- e. -
ltem requires disposition through System Readiness Review (s).
13 i
n APPENDIX 3 FOCUSED REVIEWS AND ASSESSMENTS-
!N rt! GRATED TECHNICAL SPECIFICATION Improved Tech. Spec. project (March 1934) '
- EFW/EDG Team Reviews & EvrJustions FSAR & RELATED CH.14 SAFETY ANALYSIS & ANALYSIS BASIS DOCUMENTS Failure Modes & Effects Analysis (FMEA) of the DC electrical system EOP Enhancement Program.
Safety Analysis 10 CFR 50.59 Reviews Integrated Safety Assessment of Outage Modifications Configuration Document integration Project Emergency Feedwater and Emergency Diesel Generator (EFW/EDG) Team Reviews
& Evaluations System Reariiness Review P!an (SRRP) Implementation FSAR Operttional Review DESIGN BASIS DOCUMENTATION EFW/EDG Team Review & Evaluation EOP Enhancement Program SRRP Implementation FSAR Operational Review ANALYSIS & CALCULATIONS EFW/EDG Team
- Solution paths analysis & Safety Assessment
- Integrated safety assessment of outage modifications
- Cooling time requirements for Small Break Lou of Coolaat Accident (SBLOCA) &
single failure Pipe Support Review Project FMEA of the DC electrical system
- - SRRP Implementation Startup Team validation of Ch.14 single failure accident scenarios
. Instrumentation & Controls (l&C) Calculation Upgrades Electrical Calculation Upgrades Net Positive Suction Head (NPSH) & Tank Calculation Instrument Uncertainty Calculation Analysis Program ketpoint calc. verification)
- EDG Load Calculation Main Steam Line Breaks Letdown Line Break Analysis E
14
t SPECIAL ENGINEERING PROGRAMS & SPs, EOPs, ops
.' Upgrade to inservice _ Testing / inservice inspection (IST/ISI) Team Self Assessment of ASME Sect. XI Class,1,2,- & 3 Non-Destructive Evaluation (NDE)
Program '
Containment Integrity Program Appendix "R" Review Configuration Management
- - Configuration Document Integration Project
-.. Regulatory Guide 1.97 Program instrumentation Uncertainty Calculatiran Analysis Program (setpoint calculation e
verification)
_ Pipe. Support Review Project
- EOP Enhancement Program 1 SRRP Implementation GL96-01 Testing of EDG load shedding, sequencing & actuation logic circuits for e
i safety features system against surveillance test procedures Validation of CR-3 operating curves in OP-103 A&B e
Safety Analysis Group 10 CFR 50.59 Reviews e
- EQUIPMENT & MODIFICATIONS GL96-01 Testing of EDG load shedding, sequencing & actuation logic circuits for e
safety features system apinst surveillance test procedures SRRP Implementation OTSG 100% Eddy Current Testing Mode / Power Ascension & Post Modific.ation Testing e
- EOP Enhancement Program (simulator)
EFW/EDG Integrated Safety Assessment of Outage Modifications
- Reviews & Evaluations (simulator) l L
i:
15
l l
l i
i l
l A ppendix 4 5
C om m unicatio n E ffectiv en ess In dicators m1 s t Setwoy Mey 97 532md Setvey Oct 97 A re a i A re a II A re a til A re a IV A re a V A rea 1 - M y dire ct su perviso r k ees.s m e in form ed.
A rea II - I unde rsta nd c ritical te stos t issue s.
A rea III - I und ersta n d safety regu La tion s and sta nd ard s.
A rea IV - I know w hat is expected of m e and how I fit into the " big picture' j
AreaV
- S upport com m unications m aterials enhance m y understanding o f C R -3 issue s.
I i
l 16 i
APPENDlX 5 OUTAGEIMPROVEMENTS Plant FPC has made substantial enhancernents during this outage to its improvements Engineering, Operations, Maintenance and Plant Support areas.
While undertaking these efforts, FPC has focused on enhancing plant design margins, improving the ease of plant operation by reducing operator burdens, and strengthening defense-in-depth measures. As a result, FPC has improved significantly the CR-3 Engineering and Operations areas.
Numerous upgrades were made to plant equipment and systems.
The following reflect only a few of the significant improvements made to date:
Equipment Since January 1,1997, over 11,000 work activities. including post-Repairs maintenance tests and re-tests, to repair and modify plant equipment at CR-3 were or will be performed. Included in this scope of work is the close-out of many NRC issues.
Emergency FPC upgraded capacity and reduced loads on the diesel generators DieselGenerators to increase the operating margins and reliability. The modifications (EDGs) and analyses included: upgraded turbochargers, upgraded cooling
- system, improved instrumentation, electrical protective trip improvements and detailed reviews of F.ngineered Safeguards system initiation and load sequence. The results of this work have increased the emergency diesel generators' 200-hour rating by 250 kW, thereby, increasing margin for accidents involving a loss of offsite power.
Emergency FPC installed cavitating vsnturis in the emergency feedwater system Feedwater to improve the ability of operators to manage flow through the system Cavitating during certain postulated accidents by increasing the pumps' margin Venturis of safety. This modification has reduced operator actions and burden during certain postulated accidents and has increased the plant safety margin Emergency FPC completed improvements and upgrades to the EFIC system so Feedwater that, with the exception of a very few, low probability emergency Initiation and situations, the system will manage emergency feedwater w!thout Control (EFIC) operator intervention in most emergency situations.
These - few situations that require operator action are covered by the emergency operating procedures.
This improvement reduces the operator burden during postulated emergency situations.
17
Feedwater Pump FPC added a diesel generator driver for an existing feedwater pump DriverAddition (FWP-7) capable of providing cooling water flow to the steam generators and consequently cooling the reactor under station blackout conditions. This activity has _ improved the plant's margin of safety as well as built in a defense-in depth. This conservative step has also improved operators' ability and confidence to deal with potential emergencies that involve a loss of feedwater.
100% Steam FPC, for the first time, at CR-3, performed a 100% tube inspection of Generator the steam generators. The results were excellent.
Although not Inspections required, in keeping with the principle of preparing the plant for the next 20 years, we chose to inspect 100% of the tubes to establish a reliablo degradation baseline and increase safety and reliability by minimizing the need for mid-cycle or future shutdown due to tube integrity issues.
Control Complex FPC performed a leak rate test on the control complex for the first Habitability time. Using the results of this test, FPC improved the leak tightness of the control complex by sealing penetrations, adding dampers, and changing flow paths. This effort significantly reduced the in-leakage into the Control Complex.
Open Responsiveness and reduced turnaround time to " Requests for Engineering Engineering Assistance" (REAs) have reduced the backlog of open Requests REAs from over 800 to less than 200. Processes are in place to Reduction ensure that requests are properly prioritized and resolved in a timely manner. This change has resulted in Engineering becoming an active partner in plant operations and decision-making.
Safety Analysis FPC, to ensure oversight of license and design changes to the plant, Group / Design has established a Safety Analysis Group and Design Review Board to Review Board ensure oversight of license and design changes to the plant. These new teams were created to ensure tne reviews of proposed modifications take into account the integrated effects as well as the specific effects of the plant changes as well as the specific effects of chcages proposed.
They also provide independent review of engineering, licensing, and operating changes to l',e plant adding defense-in-depth to the FPC process.
Their work reduces the likelihood of a pending modification having an undesirable o*
unforeseen impact and ensures that the operator and other department viewpoints are considered.
Operations In addition to the Engineering upgrades, numerous changes were made to improve plant operations. Some of the most significant improvements are described below:
18
Emergency FPC rewrote and upgraded the EOPs and APs. Validation of the Operating EOPs included field walkdowns to ensure equipment was accessible Procedures and available. The EOP effort involved more than 30,000 man-hours (EOP)/ Abnormal and included direct Operations involvement. The process verified the Procedures (AP)
EOPs with the current plant configuration and the design basis. As a Upgrade and result of this effort, operators have greater confidence in performing Training EOPs and APs in postulated emergency situations. This confidence has been demonstrated during operating crew requalification in the CR-3 simulator.
The NRC has reviewed EOP execution and deviations from the Babcock and Wilcox Owners Group standard EOPs.
Contro/ Room The control room was re-insulated to reduce background noise and Noise Abatement improve the working environment for operators. This, coupled with reducing the administrative burden on the operators by moving the work control center out of the control room, has improved focus on operating the plant.
Operator Work Work has been completed which reduced the number of operator Around Reduction work arounds from nearly 100 to less than 10. This represents a significantly reduced turnaround time from identification of a problem to correction and improves plant operability by reducing operator burden.
ControlBoard The number of control board deficiencies has been reduced to less Deficiencies than 10. Maintaining the control boards in a high state of readiness Reduction reduces operator burden and improves operator confidence in the plant's instrumentation and equipment. This effort also demonstrates the improved working relationship between Engineering and Operations.
Operating FPC has reduced the backlog of procedure comments from more than Procedure 800 to less than 25.
This represents a significantly reduced Change Requests turnaround time from comment identification to resolution, which has Closure improved operators' confidence in and consequently use of the procedures.
FSAR FSAR Update: The FSAR has been updated and placed on a Availability CD-Rom disc.
The FSAR update reflects a significant effort of venfication of factual information with actual plant equipment and system operation. This allows operators and engineers ready access to the FSAR, as well as supporting drawings, from a computer work station. FPC believes that making the FSAR, along with supporting drawings, easier to reference and access will improve staff knowledge and use of the information.
19
Maintenance Many improvements wers' also made. in the Maintenance areas.
Some of the most significant improvements are as follows:
Elimination of -
FPC reduced the number of overdue PMs from over 1,000 to less Overdue than 25. There will be no overdue PMs by startup of the plant. This
--Preventive effort provides improved plant reliability as well as improved operator Maintenance confidence in plant equipment.
(PM)-
Corrective FPC has reduced the CR-3 corrective maintenance backlog from Maintenance approximately 900 items to less than the station goal of 200. An Backlog operating goal has been established to ensure corrective Reduction maintenance is completed within the 12 week rolling system maintenance window. Low backlogs of corrective maintenance and timely correction of deficiencies improve plant reliability and safety, reduce operator burden, and improve operator confidence in equipment.
Plant Support Numerous improvements were made to plant support efforts Some of the more important changes are as follows:
Employee The ECP has been strengthened to include site-wide visibility of the Concerns program as an alternative for raising safety issues. A video has been Program (ECP) made for use in indoctrinating newly reporting employees as part of the site's General Employee Training program and seminars have been held with supervisors on methods of reinforcing use of the program with both employees and contrcctors. Five alternatives are now available for raising safety issues:
- a. Directly with supervisors
- b. Through the Corrective Action Program
- c. Through the CR-3 Employee Concerns Program d Through FPC's Ethics and Concern Line (a "1-800" telephone program), and/or
- e. Directly to the NRC's attention A third party assessment of the ECP was performed by a firm that has completed over 40 evaluations at other utilities, The CR-3 safety culture was noted to have significantly improved. In addition, the number of allegations has been reduced from the pre-outage value even though over 1000 people were added for outage support.
Corrective Action CR-3's program for. documenting conditions adverse to quality has Program (CAP) been significantly improved by initiation of a single, graded precursor card system. Using a single input document, each issue is evaluated
)
(graded) on a daily basis by a multi-discipline precursor screening committee, which is comprised - of representatives from site 20
operations, maintenance, engineering, licensing, nuclear safety assessment team, and quality departments.
Use of a graded approach allows CR-3 to better prioritize issues and efficierily apply resources to most significant conditions. The new interdisciplinary committee brings enhanced expertise from all major plant areas to more effectively evaluate issues at an early stage.
Both a third party assessment and a targeted NRC inspection confirmed that this program is functioning well.
In additicn, a summary of each precursor card is provided to senior site management and discussed as appropriate at the site morning meeting.
Nuclear General The NGRC is comprised of three utility executives, a former INPO Review executive and a former NRC Executive Director of Operations. This Committee offsite review group provides an on-going assessment of the overall (NGRC) status and results of CR-3 restart activities, in addition to reviewing Assessment Technical Specification Change requests, License Amendments and Unreviewed Safety Questions, subcommittees conduct a detailed functional review each quarter. The NGRC was tasked with providing an overall assessment of Restart Readiness to the Senior Vice President Nuclear Operations and determined that CR-3 was ready for restart.
Hand Geometry FPC installed and implemented hand geometry access control to the protected area which improves access control and reduces security force administrative duties.
Security The security computer hardware and software was upgraded to Computer simplify security operations and reduce security administrative Upgrade burden.
Security Process FPC implemented a security improvement plan which has resulted in improvement hardware upgrades, the hiring of new Security Manager, and centralizing of safeguards material.
Plant Support The sampling and surveillance procedures for Chemistry were revised Chemistry to enhance plant configuration control and improve field use by Procedure technicians. This upgrade included approximately 150 procedures Upgrades involving system sampling and effluent releases.
Chemistry Chemistry laboratory instrumentation and sampling apparatus Instrumentation upgrades included new lon Chromatography instruments, a Liquid Upgrades Scintillation Detector, Diesel Fuel Analytical equlpment, and a Total Gas Stripping Apparatus. These upgrades improve the performance and quality of analytical analyses performed in the laboratory.
21
Radiation Portable radiation survey instruments, ten years of age or greater, Protection were replaced. This required the purchase of approximately 175 new Improvements instruments. The new equipment is more accurate and easier to use, which will enhance CR-3's radiation survey capabilities.
Electronic A new electronic alarming dosimeter system has been purchased.
Alarming This system is expected to improve both the reliability and accuracy Dosimeter of the plant's dosimetry system.
Upgrade Integration of Configuration Document integration Project (CDIP) was implemented Efforts in July 1997 to provide a structured, documented process which ensured that key configuration-related document, systems, and component modifications would not adversely impact each other.
CDIP constituted an expanded effort to integrate the resolution of previous NRC findings with the Extent of Condition reviews being performed during the outage. The CDIP process was discussed with the NRC Restart Panel on May 9,1997 and June 19,1997.
CDIP Scope Processes included:
System Information Set Coordination (SISCO)
Technical Resolution Process (TRG)
Document Integration Process (DIG)
System Ownership Team (SOT) Acceptance Process Integrated Assessment Team (IAT)
Document Approval Process Document issue Process e issue Prioritization Process in concert with the System Readiness Reviews (SRR), CDIP integrated these changes to the facility and the resolution of the problems identified from both the FSAR review and the SRRs into the main configuration control documents at CR-3. Key personnel were assigned to integrate the design and licensing basis related outage issues.
The Integrated Verification Team (IVT) was a group assigned to i
reviewed FSAR Chapter 14 accidents and events relative to operator actions / burden and safety margins. The safety assessments from all of the EOPs were reviewed along with modifications which affected the mitigation strategy of accidents and events. The IVT report was issued on November 26, 1997 and forwarded to the NRC on December 3,1997.
The report concluded that the Chapter 14 accidents were adequately covered in the modifications and EOP revisions made this outage.
22
APPENDIX 6 RESTART PERFORMANCE INDICATORS The Restart Performance Indicators are divided into the followino five areas:
Organizational Readiness -- Those Startup Performance Indicators that will show
_ that Nuclear Operations as an organization is ready to safely operate CR-3.
System Readiness -- Those Startup Performance Indicators that will show that the CR-3 systems are ready to operate safely and reliably.
Operations Readiness -- Those Startup Performance Indicators that will show that the CR-3 Operations organization is ready to operate CR-3.
Regulatory Readiness - Those Startup Performance Indicators that will show that CR-3 is ready to operate from a regulatory perspective.
Communications Readiness - Those Startup Performance Indicators that will show that FPC / Nuclear Operations / CR-3 has communicated both inside and outside of Florida Power about why CR-3 was down, what we have done to correct h, and how we are ready to resume safe operation of CR-3.
The Startup Performance Indicators in each area are listed on the next page along with the Goal at Startup, and when the remaining startup performance indicators will achieve its target for startup.
23
.i Performance Indicators (Itahes shows Performance Indicators that has been rJnieved)
Perfergeance " _" N.
Goal at StMeas 4t%iew Tarset E. SWEARAZATIONAL READSESS A. Restart Besase Oesure 9
Jasemary R. NCef M Restat Meser Gesenre O
AONOtD C. SeN4dentined Prearrsors*
60 % or Greater
- D. SsW6dentnited $1olations
- 33 % or Greater
- AOIKMD E Totaf Alunseer e(spers Preraarsers Decreashqt Trend AOMMD
- u. sysviou aEAmesEBS
' A. Corrective Mahstenanos 299 spear fMart AGNEMD
- cqueers er Lees
- 8. TeunpararyMedHcardens 5 or Less AseraNed AOMMD C Reqasents por EM 200 er Lees l> err AONtKB Aesdefarace.
' D. Restart 28edincations 0
. Janssary E Spetessrs Acerahaing te he A&MMD Acceptedby D>erations
. su. erERAisens mEASWdESS A. CentrolBoard Dendendes 10 er Lees AORtHD
' B. Operator Werk Arounds 7 or Lees C (WeratAng' Procedures 25 Ossessents apr Lees AGNEMD D. Eneertency Operating incorprwate leeues Janssary Premdures frees 8 CAR. Desidn leesses All Approval Steps Consplete E. Abnorneal Procedures 15 Cesnenents or Lees IV. BEEMEAleRY REASHESS A. License Ansessenants '
O AOMMD arad Tedt Spec SohnrMrds
' B. Otteer idIRC Restart Subsenttals O
. !_ _ ri C. Total 1997 NftC lieues*
O*
Post-Restart D. $nnhcrMtaf QuaNty index of 5 or Greater AOMMD t
W.
COMMLSACATIORIS REASWESS A. E-, ^_,,- Snarwys Anpreee RenaNs AQMHD B. C-
..y Leaders MeetIVier to Martsp AQM179 C State & Federaf StRdds/ Matt Neet PNor to Matap AUREHD D. d$pertardry to Tsar Pfant Beded SWIIcfaAr arsaf Maff AONEMD drnMedto Tear E iperr Cesenreandcar# err Ediferfaf Seards, Antersdeers, arad AGNEMD p1WP Nedfa PFant Tears Condurfeuf Asr These 9the Ceser DV-3 Routinely J
- Internal Targets 24
L THE PURPOSE. BASIS. AND OBJECTIVE FOR EACH PERFORMANCE INDICATOR ARE:
- 1. -
Oraanizational Readiness
' A.
Restart Issue Closure -
Purpose:
Measures closure of restart action plans _ and work items that require closure before CR-3 restart.
Basis: NRC / FPC Restart List - Additions are made per FPC procedure-NOD-57. Closures are monitored by Quality Assurance.
Objective: Apply resources as required for timely closure of issues.
B.
MCAP ll Restart item Closure -
Purpose:
Measure completion of improvement actions defined in MCAP 11.
Tracks successful closure of programmatic issues associated with Restart.
Basis:
Management Corrective Action Plan - Commitments made to address issues in the Confirmatory Action Letter. Closures are monitored by the Quality Programs Group.
Objective:
Ensure program improvements are implemented in time to demonstrate improved process performance prior to start-up.
C-Self identified Precursors * --
Purpose:
Measure the organization's questioning attitude and willingness to self-identify problems.
Basis: Compares Precursor Cards written by a plant organization against itself and assigned to that same department for resolution as a percentage of all the cards written each month. The 60% target was set based on Failura Prevention International experience.
Objective: This measure of effectiveness of efforts to create a culture that identifies and corrects its own issues. This measure is expected to show an improving trend over time.
D.
Self-identified Violations * -
Purpose:
Measure the capability and willingness of CR-3 staff to identify and promptly correct issues that would be classified as violations.
Basis: This is' the number of violations classified as non-cited by the NRC compared to the total number of violations issued. This trend will be for violations resulting from 1997 work activities only.
The 67% goal was recommended by Failure Prevention Internationa! using industry data.
25
Objective: Improve the culture that identifies and promptly corrects issues that lead to violations being classified as non-cited violations.
E.
Total Number of Open Precursors --
Purpose:
Measures management's effectiveness in solving problems in a timely manner This is achieved by measuring Precursor Cards initiated per i
week, closed per week, and total number open. Data is given as monthly
-totals.
Basis: The data is taken directly from the Precursor Card data base.
Objective:
Reduce the backlog short term by having a closure rate exceeding initiations and maintain it as low as reasonably achievable in the future.
II.
System Readiness A.
_Q_orrective Maintenance --
Purpose:
Measure the materiel condition of the plant through the backlog of open corrective maintenance work requests.
Basis: The data describes the total number of open corrective maintenance work requests yet to be worked. This indicator includes equipment that is broken and equipment that is in a condition or state that is less than the original specification, (e.g., valves with seat leakage, instrumentation reading incorrectly, frayed electrical wires, etc.).
This trend includes all shops. This parameter is updated weekly. The goal of 200 was based on survey of SALP 1 plants.
Objective: Maintain a trend that will reduce the work request backlog to less than 200 before. secondary plant start-up with a long term goal of maintaining this backlog at a normalized 90-day work load of on line work plus accumulated outage work.
B.
Temocrary Modifications --
Purpose:
Measure configuration management and the health of systems.
This measure maintains visibility by tracking the progress of removing temporary modifications from the plant.
Basis:~
Temporary modifications are defined in Nuclear Engineering Procedure 210, " Modification and Approval Records " This indicator shows
-the number of installed temporary modifications and those resulting from leak repairs. The goal was set based on improving previous operating experience.
26 7
Objective:
_ Keep focus on permanent repairs versus temporary rnodifications. The target is to have less than 5 temporary mooifications in place (excluding " leak repair" modifications) and no temporary modifications older than one fuel cycle.
C; Reauests for Enaineerino Assistance.--
Purpose:
- This indicator provides a measurement of the effectiveness and timeliness of Nuclear Engineering Design to respond to technical questi.ons, requests for information / assistance, and suggestions / requests for plant modifications from Operations.
Basis: This indicator provides data that is intended to reflect the backlog of Requests for Engineering Assistance (REAs) for all of Nuclear Engineering.
This includes Design, Systems, Procurement, Programs, Projects, and Configuration Management. This data is extracted from the REA database.
The goal of less than 200 is based on operating experience and is believed to be achievable.
Objective:
Provide prompt engineering assistance to Operations and -
Maintenance.
D.
Restart Modifications -
Purpose:
Measure progress towards completing modifications.
This indicator reflects " Ready to Return to-Service" as the point at which a restart modification has 1) design and construction complete,2) functional testing complete (including power ascension testing),3) required drawing revisions in place,4) required procedure revisions in place and 5) operator training completed. At this point the modification is ready to be operable, pending completion of licensing issues.
Basis: Tracks the modifications resulting from the Confirmatory Action Letter commitment regarding bight design issues"and adds modifications per our restart criteria.
Objectivo: Provide focus on resolution of issues for start-up. The Restart Modification Goal is zero prior to Mode 2.
E.
Systems Remainina to be Accepted by Operations -
Purpose:
Measures system readiness to support heatup and startup.
Acceptance signifies that after Design and Systems Engineering ano Maintenance have completed their action plans that the physical condition of the systems are acceptable to Operations.
Basis: Operations Manager sign off that system will support safe and reliable operations.
i 27
Objective: Build Operations ownership and accountability for the physical condition of the system. Target is to have all systems certified on schedule.
111.
Operations Readiness A.
Control Board Deficiencies --
Purpose:
Measures the total number of control board deficiencies that place additional burdens on operators in performance of their duties.
Basis: Definition - A control board deficiency exists whenever an instrument or a control located on any panel in the control room is incapable of performing its desired function.
The goal was established based on operating experience.
Objective: Maintain focus by Maintenance, Scheduling, Engineering and Operations on the condition of the control boards.
B.
Qoerator Work Arounds -
Purpose:
Measures the number of Operator Work Around' Conditions on a monthly basis. This indicator represents a snapshot of the total number of Work Arounds that are currently not fully closed out.
Baisis: A tolerated, but economically correctable, practice or a condition that negatively impacts transient response; or is caused by a procedure, process, or equipment not petforming as designed, or needed, and additional work o.equired to achieve the necessary result. Additional work is further definec e work where significant additional time or resources are required or puts wNs at an increased radiological or safety risk. It is a l
measure of situations that are considered to be correctable by Operations.
2 Objective: Focus Maintenance, Scheduling, Engineering and Operations efforts to resolve non-standard plant line-ups.
C.
Operatina Procedures -
Purpose:
Measure effectiveness in keeping operating procedures up-to-date.
Basis: _ Procedure revisions must be in place to support restart of the unit.
Objective: Ensure the schedule for operating procedures supports training, testing and operations.
D.
Emeraency Operatina Procedures --
Purpose:
Measure the total number of Emergency Operating Procedures (EOPs) to be revised.
28
- Basis:
Tracks the revisions of the Emergency Operating Procedures resulting from the Confirmatory Action Letter commitment regarding bight design issues," comments, and other inputs.
Objective: Maintain management's focus on meeting the Restart Schedule to ensure successful completion of EOP revisions. The goal is to have zero left prior to Heat Up.
E.
Abnormal Procedures --
Purpose:
- Monitor the total number of comments to be considered for incorporation into Abnormal Operating Procedure (AP).
Basis: Open Abnormal Procedure change request.
Objective: Maintain Abnormal Procedures up-to-date with a timely turn-around for change requests. The goal is to have zero left prior to Heat Up.
-IV.
Reaulatory Re,adiness A.
License Amendments and Technical Specification Submittals --
Purpose:
Measures NRC submittals required to support startup and any varianca from the Restart Schedule.
Basis: This tracking mechanism supports completion of commitments made that require improved Technical Specification and/or license changes.
Objective: Provide adequate time for NRC reviews to be completed in support of the Restart Schedule. The original goal was to have zero due by the end of August. Due to emerging issues and RAls, we are currently managing submittals by mode change restraint.
B.
,Other NRC Restart Submittals -
Purpose:
Measure support of the Restart Schedule.
. Basis: This is a tracking mechanism that supports completion of submittals requirea to close issues, information requests and commitments.
Objective: Provide adequate time for NRC reviews to be completed in support of the Restart Schedule.
C.
Total 19.97 NRC ltems * -
Purpose:
Measure effectiveness in meeting external commitments for action. This is achieved by measuring resolution of commitments due to be completed in 1997.
Basis: This indicator shows the number of open regulatory commitments (e.g., NOV responses, LERs) to be made to external agencies that are in 29
addition to our restart issues list. The data comes from the Regulatory Commitment Tracking System, Objective:-- Organizational accountability to do what we say we will do, when we say we will do it.
D.
Submittal Qualitv -
Purpose:
. Measures management's ability to submit accurate and completa information to the NRC in support of licensed activities. This indicator is based on responses to violations (NOVs), licensee event reports (LERs) and 6
supplements.
This is measured by using the number of. Requests for Additional Information and LER supplements. Measures timely, complete and accurate submittals to the NRC.
Basis: Licensing correspondence is braded"for quality and timeliness.
The target is based on management's expectations.
Objective: Improve the quality of licensing correspondence to approach "zero defects".
V.
Communications Readiness A.
Employee Surveys --
Purpose:
To ensure that employees are receiving information about CR-3.
Basis: Random surveys of employees by an outside organization.
Objective: To have increasing trends of communications to employees for the areas surveyed.
B.
Community Leaders C.
State and Federal Officials / Staff D.
Oooortunity to Tour Plant E.
Open Communication with Media
Purpose:
To ensure the public receives and understands the communications about CR-3.
Basis: Direct contact with various leaders, officials, media representatives, and the public.
Objective: To develop an understanding of what FPC has completed and what we intend to do in the future.
- Internal Targets 30