ML20155J599

Partially Withheld Results of Joint Nrr/Ofc of Investigations Evaluation of RR Booher.Booher Not Truthful Re Knowledge of Leak Rate Test Manipulation at TMI-2 During 780930-790328.Evaluation of Interview Encl

ML20155J599
Person / Time
Site:	Three Mile Island
Issue date:	12/14/1984
From:	Russell W Office of Nuclear Reactor Regulation
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
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References
NUDOCS 8605270117
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Text

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Enclosure 3

[o u,,,'\,, UNITED STATES

g NUCLEAR REGULATORY COMMISSION mr. a wAsMmorow.o.c.soses December 14, 1984

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- MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation THRU: Hugh L. Thompson, Jr., Director Division of Human Factors Safety NRR 4dp# iq FROM: William T. Russell, Deputy Director Division of Human Factors Safety, NRR

SUBJECT:

RESULTS OF JOINT NRR/01 INVESTIGATION AND EVALUATION OF RAYMOND R. B00HER

Reference:

1. Memorandum from S. J. Chilk (SECY) to B. B. Hayes (01)-

and W. J. Dircks (EDO) dated April 2, 1984.

Subject:

Staff Requirements-Discussion ~of Pending Investigation-TMI -

2. Memorandum from H. R. Denton (NRR) to B. B. Hayes (01) ,

dated May 3, 1984.

Subject:

NRR Review of OI Investigation Materials Concerning Hartman Allegations of Falsification of Leak Rate Data at TMI, Unit 2 The purpose of this memorandum is to document the results of the joint 01/NRR investigation and evaluation of Mr. Raymond R. Bocher, currently a Senior Reactor Operator (SRO) at Waterford Generating Station, Unit 3 and to provide a recomendation-regarding whether his current SR0 license should be revoked, modified, or suspended under 10 CFR 55.40 due to his involvement in preacci-dent leak rate testing irregularities at TMI-2.

Background

As a result of a Comission meeting on March 23, 1984 NRR was directed by l Reference 1 to review OI investigative materials concerning falsification of reactor coolant system (RCS) leak rate tests at THI-2 and refer back to 01 those matters which required further investigation. The results of NRR's review was provided in Reference 2. The revtew determined that follow-up investigation by OI and further evaluation by NRR was needed in the case of 1 NOTE: This memorandum and Enclosure 1 discusses information which is the sutdect of an ongoing 01 investigation. Th.is memorandum and Enclosure 3 -

discusses information that is maintained in the NRC's Privacy Act System of Records (NRC-16). This memorandum and enclosures may not be disseminated outside the NRC without coordination with NRR and the permission of the EDO or the Director. 01. Internal access and distribution should be on a "need O to know" basis.

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, i Harold R. Denton December 14, 1984 i

seven licensed operators. Of the seven individuals identified in Reference 2, four are currently licensed at TMI-2, two are licensed at Waterford 3 and .

one is licensed at San Onofre 2 and 3. At a follow-up Connission meeting on May 23, 1984, NRR proposed joint 01/NRR investigations and evaluations of

, these individuals. Subsequently, NRR issued letters to the seven individuals under 10 CFR 50.10(b) requesting additional information regarding current performance. Based upon investigation into the individuals' past involvement 1 in improper activities at TMI-2 and an evaluation of the individuals' -

subsequent performance, NRR would recommend what action, if any, should be taken against the identified operators.

Past Involvement in THI-2 Leak Rate Testing Irregularities i'

On the afternoon of November 15, 1984, a joint OI/NRR interview of Mr. Raymond R. Booher was held in New Orleans, Louisiana. The interview was conducted under oath and in the presence of Mr. Booher's personal attorneys.

.I Tne purpose of the interview was to determine Mr. Booher's role in improper activities associated with RCS leak rate surveillance testing at TMI-2 prior to the accident on March 28, 1979. At that time, Mr. Bocher was a licensed Reactor Operator (RO) and served as a Control Room Operator (CRO) on shift l "E." A detailed evaluation of Mr. Booher's interview is included as  ;

Enclosure 1 to this memorandum.

i O While many of Mr. Bocher's responses to questions associated with leak rate surveillance test problems at THI-2 are consistent with statements made to the NRC by other licensed operators, the majority of his responses regarding his personal involvement in or knowledge of leak rate test manipulation do not appear credible. During the interview Mr. Booher relayed the following information.

4 1. Leak rate tests were routinely run at least once per shift. At times

the tests had to be run several times before a satisfactory result was obtained (i.e., unidentified leakage within the Technical Specification i limit of 1 gpm).

2. Only satisfactory leak rate test results were logged in the CR0 Log. l Test results which exceeded the Technical Specification limit were not l logged. NOTE: These actions were contrary to TMI Administrative Proce- l l dure 1012. " Shift Relief and Log Entries," which required the start and stop times of all surveillance tests to be logged in the CR0 Log.

3. Only satisfactory leak rates were retained. All bad leak rate tests (i.e., unidentified leakage greater than the Technical Specification limit of 1 gpm). NOTE: These actions were contrary to TMI-2 Technical

Specification 6.10 " Record Retention," which required that records of surveillance activities required by the Technical Specifications be -

retained for a period of at least 5 years.

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4. Mr. Booher's first line supervision (Shift Foreman and Shift Supervisor) '

, were knowledgeable of the difficulties operators were experiencing in obtaining satisfactory test results. These same individuals directed i the throwing away of bad leak rate test results. l

5. Contrary to the commitment contained in the narrative of LER 78-62/1T, I Booher's shift was not instructed in the requirements of applicable sections of the Technical Specifications or in the requirement to

! immediately invoke the Technical Specification Action Statement when the ,

associated Limiting Conditions for Operation was exceeded. Booher 1 stated that they did not abide by the shutdown requirements of the  ;

Technical Specification because "that was more or less in the hands of j management." " NOTE: These actions are contrary to TMI-2 Technical ,

Specification TC6.2, " Reactor Coolant System Operational Leakage  ;

Limiting Condition for Operation," and are contrary to the licensee's ,

stated corrective action in LER 78-62/1T of November 1, 1978.

6. Mr. Bocher stated that he was unaware that hydrogen additions to the make-up tank could affect make-up tank level indication and, thus, favorably influence leak rate test results. NOTE: Mr. Booher's state-ment is in conflict with statements made by the two other CR0s on i Mr. Bocher's shift. Mr. Hartman and Mr. Blessing both admitted that I they added hydrogen to the make-up tank to influence leak rate test i results. They also indicated that it was comon knowledge among operators at TMI-2.that hydrogen could alter leak rate test results. It was also Mr. Blessing's opinion that it was connon knowledge up to the level of Shift Fareman and Shift Supervisor that cperators were altering

leak rate tests using hydrogen. 1 1 7. Mr. Bocher stated that he never added water to the make-up tank for the  ;

purpose of altering leak rate test results. NOTE: Mr. Booher's state-  ;

ment is in conflict with both the technical analysis and statements made l

by Mr. Hartman. The technical analysis shows that during every leak rate test in which Mr. Booher took part from December 26, 1978 through the date of the accident (8 tests), all include water additions to the ,

make-up tank that were not accounted for in the leak rate test calcula- l l tion. Mr. Hartman has stated under oath that he personally witnessed l Mr. Booher add water to the make-up tank in order to manipulate leak l l rate tests. The methods described by Mr. Hartman for adding water are )

i the same methods which appear in the technical analysis. i In sumary, the weight of evidence, including technical analysis and state- .

ments by other operators on Mr. Booher's shift, strongly suggest that Mr. Bocher was not truthful in answering questions regarding his participation in or knowledge of leak rate. test manipulation at TMI-2 during the period September 30, 1978 to March 28, 1979.

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l Harold R. Denton December 14, 1984 I

Past Involvement in Breach of Security at TMI-2 l

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Conclusions l During the period Mr. Booher was licensed as a Control Room Operator at THI-2

. prior to the accident, he admitted he was involved in some activities associ-

. ated with leak rate testing irregularities. However, he denies that he was involved in other actions including leak rate test manipulation or falsifica-tion or knowledge that such. activities were going on around him. The weight of evidence, including statements by other operators on his shift and the i technical analysis, strongly suggests that Mr. Bocher was not truthful in answering questions regarding his role in leak rate test manipulation.

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Enclosures:

As stated i

! ce; B, Hayes i K. Christopher , RI

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h0TE: This enclosure discusses information which is the subject of an ongoing 01 investigation. This enclosure may not be disseminated cutside the NRC without cocrdination with NRR and the permission of i

the EDO or the Director 01. Internal access and distribution should be on a "need to know" basis.

Enclosure 1 PAST INVOLVEMENT IN THI-2 LEAK RATE TESTING IRREGULARITIES I. Background t

On November 15, 19E4, a joint Office of Investigations (OI)/ Office of Nuclear Reactor Regulation (NRR) interview of Raymond R. Booher was held in the.

Federal Building, New Orleans, Louisiana. The purpose of the interview was to determine Mr. 01 son's role in improper activities associated with Reactor Coolant System (RC) leak rate curveillance testing at Three Mile Island, i Unit 2 (TMI-2) prior to the accident on March 28, 1979. Present during the interview representing the NRC were: Keith Christopher Director Office of Investigations, Region I; William Russell, Deputy Director, Division of Human Factors Safety; and Robert Capra, Technical Assistant. Division of Systems Integration. Representing Mr. Bocher at the interview were his personal attorneys: Jane Penny of the law firm Killian & Gephart, Harrisburg, Pennsylvania and William Marcoux of the law firm LeBoeuf, Lamb, Leiby and MacRae, Washington, D.C. Mr. Bocher was placed under oath for the interview.

A copy of the transcript associated with this interview is provided as O

Attachment 1. l i

Mr. Bocher is currently employed by Louisiana Power & Light Co. as a Senior 1 Reactor Operator (SRO) at Waterford Generating Station, Unit 3. Mr. Booher l

! has been employed at Waterford 3 since 1981. Prior to his current l employment, Mr. Booher was employed by General Public Utilities (GPU) and  !

Metropolitan Edison Cogany (Met-Ed). Mr. Bocher was originally hired by Met-Ed Program.inMr.

1971 after worked Bocher servingas 6 years in the Operator an Auxiliary U.S. Navy ('s for AO) Nuclear Submarine approximately 6 years before transferring to THI-2 as a licensed operator. He received his

' Reactor Operator's (RO) license in 1976 and maintained it until his -

termination at TMI in 1981.

The interview with Mr. Booher concentrated on the period September 30, 1976 through March 28, 1979. During this time period he served as a Control Room Operator at TMI-2. He was assigned to Shift "E." At that time, Shift "E" consisted of the following licensed individuals:

SHIFT "E" Shift Supervisor: Bernard Smith Shift Foreman: Kenneth Hoyt CRO: Raymond Bocher CRO: Harold Hartman CRO: John Blessing l

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Mr. Bocher and Mr. Blessing were interviewed previously on this Subject on April 10, 1980 during an NRC investigation into the "Hartman Allegation."

Copies of these reports of interview are included as Attachments 2 and 3, respectively. Mr. Hartman has been interviewed on this subject numerous times. A copy of his last interview with OI, dated July 26, 1983, is included as Attachment 4.

A sumary of the technical analysis of the leak rate tests involving Mr. Bocher is provided in.Section II of this enclosure. A sumary of the interview with Mr. Bocher is provided asSection III of this enclosure. The sumary of interview in Section III includes citations to the page numbers of i transcript in which the sumarized information was discussed. Overall conclusions regarcing Mr. Bocher's involvement in improper activities associated with TMI-2 leak rate surveillance testing is contained in i Section IV of this enclosure.

II. Sumary of the Technical Analysis A technical analysis of the TMI-2 leak rate surveillance records was performed by Dr. Jin Chung of the Office of Inspection and Enforcement,

, Region I. This analysis was originally done as technical support to the Department of Justice in the criminal trial against Met-Ed. The results of Dr. Chung's analysis were used in questioning Mr. Bocher during the interview. While 'a mo~ re detailed sumary of the leak rate tests at THI-2 -

involving Mr. Bacher, along with the surveillance test sheets, CR0 Log extracts, and the make-up tank (MUT) strip charts for the questionable tests, are provided as Attachment 5 to this enclosura, a brief sumary of the results of the technical analysis will help the reader understand the basis for the questions posed to Mr. Booher during the interview. -

A review of the test records show that of the 156 leak rate surveillance

, tests retained by the licensee during the period under investigation.

l Mr. Bocher was involved in 12 of the tests. During these 12 tests he was i either the individual who signed the surveillance test record or he was the l

, operator on watch who signed the CR0 Log for the period during which the test

was conducted. Of these 12 tests, the analysis shows that 9 tests involved possible water or hydrogen additions to the MUT during the one hour time period in which the leak rate tests were conducted. The table below shows

! the breakdown of water / hydrogen additions.

Breakdown of LR Tests Involving - R. Booher Total Number of Tests on File 12 Tests Involving Hydrogen Additions 2*

i Tests Involving Logged Water Additions 3 Tests Involving Uniogged Water Additions 5*

• 0n a test performed on 12/26/78 involved a hydrogen ,

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addition and an unrecorded water addition during the same test.

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The analysis shews that starting on December 26, 1978 through ths date of the accident on March 28, 1979, all 8 tests involving Mr. Bocher involved water additions that were not compensated for in computer calculation of leak rate. l In one case (December 26, 1964), both hydrogen and water were added during the l leak rate test period.

The analysis relies to some degree of subjective judgment in some cases  !

(i.e., interpretation of the MUT level strip chart recorder trace). However, I in the majority of tests involving Mr. Booher, there is a high confidence '

level that these water and/or hydrogen additions were made during the same i period the leak rate tests were being conducted. Three of the water '

additions involved the addition of large amounts of water (117 gallons to 300 gallons) and were logged into the CR0 Log as being added during the test, but none were taken into account by the operator performing the leak rate test. In each case the satisfactory completion of the test was also logged into the CR0 Loq. Mr. Bocher was the panel operator during these three tests and signed the log at the end of his watch, indicating he was responsible for these entries.

On ene occasion a large amount of water (150 gallons) was added to the MUT and neither logged into the CR0 Log or compensated for in the leak rate test.

N On four occasions, it appears that water was jogged into the make-up tank over longer intervals. The jogged additions may have been an attempt to hide the fact water was being added during the test. Two of these jogged adcitions involved Mr. Bocher and Mr. Hartman and two involved Mr. Bocher and Mr. Blessing. ,

NOTE: During Mr. Hartman's July 26, 1.983 interview with OI, Hartman stated that he had personally witnessed operators use three methods to manipulate leak rate test result:

1. water addition in small undetectable amounts over the period of the test;

2. adding hydrogen to the MUT during the test; and

3. rerunning the computer leak rate until sati'sfactory results were obtained.

During this same interview, Mr. Hartman stated that he had witnessed Mr. Bocher add water to the make-up tank in order to manipulate leak rate test result.

In sunmary, the technical analysis confirms what Mr. Hartman told 0I on July 26, 1983. All eight tests (100%) involving Mr. Booher from December 26, ,

1978 on, involved actions that were not in accordance with approved l procedures. .

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III. Interview Sumary After being placed under oath, Mr. Bocher was asked to describe his-employment history prior to joining Louisiana Power & Light Co. Mr. 3ccher stated that he had served six years in the U.S. Navy prior to joining Met-Ed in 1971. Mr. Bocher spent approximately 6 years as an Auxiliary Operator (AO) at THI-1 prior to moving to TMI-2 as a licensed R0. See page 4. During the majority of the period under investigation Mr. Bocher 7 ated he was assigned to Shift "E" consisting of the following licensed individuals:

SHIFT "E" Shift Supervisor: Bernie Smith Shift Foreran: Ken Hoyt CRO: Ray Booher CRO: Harold Hartman CRO: John Blessing See pages 5 and 6.

Mr. Socher was provided a copy of TMI-2 Surveillance Procedure 2301-3D1, O " Reactor Coolant System Inventery" and a copy of TMI-2 Technical Specification (TS) 3.4.6.2, " Reactor Coolant System Operational Leakage Limiting Condition for Operation." See page 6. After reviewing the documents, Mr. Bocher stated that he had performed leak rate tests at TMI-2.

The TS required that a leak rate test be performed every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; however, they normally ran at least one every shift. See pages 7 and 36. Some shifts had to run more than one because the leak rate results did not meet the tolerance of the Limiting Condition for Operation (i.e., unidentified leakage in excess of the TS limits of 1 gpm). When bad results were received on a leak rate test, Bocher stated that they initially took them to the Shift Foreman. The bad. leak rate tests would typically be thrown away based upon ,

verbal instructions from either the Shift Foreman or the Shift Supervisor. l See pages 11 and 12. '

When asked of the reason they were thrown away was so the NRC would not see them. Bocher stated it was never Edd to him that way. It was "just throw it away and perform another o % *

When asked if it was implied .7% V t was the reason to throw it away?

Bocher stated:

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"Not to me, it wasn't. That wasn't implied until'the grand jury. And then I remember seeing.a letter evidently, the superintendent of operations wrote a letter saying, ' Dispose -

of them more correctly.'"

See page 13'. '

Later in the interview, Mr. Bocher was asked if he could explain this document a little bit more. Bocher said:

"I don't remember at the site. But I remember of reading it in the grand jury, the fact that something was written to the effect to dispose of papers more accordingly into the trash I

cans instead of letting material lie around, to throw it away." See pages 35 and 36.

Mr. Booher stated that once they got a bad leak rate test result, they would continue to run the test until they received a good one. His rationale for accepting the good ones and rejecting the bad ones was that the leak rate tests not only came out positive, but came out negative as well, which was impossible. Thus, he said with the accuracy of the instrumentation, you ,

could either believe what you got or not. The ones that were within limits '

would be kept; the ones that were not would be thrown out. See pages 13 and 14.

When asked if he knew what to believe in the way of leak rates Booher stated: l 1

O "I believe we had leakage, from experience, moreso from experience than from what the computer printout. Plus or minus or within spec. Because I could remember sending people '

out, like I used to in Unit 1 to take drainages from fan coolers or to look for leaks. We had leaks, sure." See  ;

page 14. ,

When Mr. Bocher was asked if he recalled ever entering the action statement on any of the leak rate tests that were outside the limits of the Technical .

l Specifications, he responded that they did and they didn't. He said he could recall telling the Shift Foreman that the test results did not meet the Limiting Condition for Operation (LCO) and that they were in the action statement. However, he further stated"

...we really didn't really abide by the shutting down L

requirement though because that was more or less in the hands of management. Today, I would insist upon abiding by the action statement as it strictly said. Back then, we didn't."

See page 15.

Bocher was then asked if he felt that he could rely on the RCS leak rate test calculation to tell him what kind of leakage they had. He said, "Not an '

accurate one but we could use it for a trend." He was asked if he ever brought this to the attention of his supervisqgy personnel. Booher stated that they were the ones who made him aware of the instrument inaccuracies.

See pages 15 to 17.

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Mr. Booher was asked why h'e could now remember throwing away bad leak rate tests, yet, when he was interviewed in 1980, he could not recall what was done with bad leak rate tests? Bocher said that he had come into the control

, room one morning and was told by Joe Chwastyk (a former Shift Supervisor) i that the NRC wanted to talk to him about leak rates. Booher said:

! "I went down there and I walked into this room and I see all these people, you know, and they all had note pads and were writing up a storm and I got somewhat nervous, to tell you the truth." See pages 18 and 19.

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Mr. Bocher was then asked about how he interpreted the requirements of Technical Specification 3.4.6.2.

NOTE: Part b of the Action Statement reads as follows: "With any Reactor-Coolant System leakage greater than any one of the above limits, excluding PRESSURE B0UNDARY ~

LEAKAGE, reduce the leakage rate within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."

Mr. Bocher stated that the operating philosophy was that regardless of how many bad leak rate tests were received during the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period, as long as they received a valid one within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, they considered that they had met the Technical Specification requirements. See pages 20 and 21; .

Mr. Bocher was then asked if he recalled an incident involving leak rate tests that occurred on October 18, 1978. Bocher recalled that he remembered the incident from being questioned about it during the grand jury investigation; however, he did not recall the incident when he was at TMI.

NOTE: The incident referred to occurred on October 18, 1978.

During a routine inspection of THI-2 operations, an NRC inspector discovered that TH1-2 had been operating for a period of two or three days with unidentified leakage exceeding the Technical Specification limit. The incident resulted in the submittal of Licensee Event 4

Report (LER) 76-62/1T dated November 1,1978.- The narrative of the LER states that "This event was caused by misinterpretation of the requirements of the technical specifications. The appropriate personnel will be instructed on the requirements of applicable sections of the T.S. and the requirement to immediately invoke applicable action statements when the provisions of the LCOs are not met."

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. e Mr. Bocher was shown a copy of the LER along with a routing sheet with the typewritten names and handwritten initials of control room personnel.

Mr. Bocher confirmed that the routing sheet was the normal method by which operators were kept informed of events such as this. He could not confirm if the initials beside his name were his, which would indicate that he had seen the LER at one time. He stated they could be his; however, that was not his usual method of initialing. See pages 24 and 25. ,

Mr. Bocher stated since he did not remember the incident, he did not believe that he was instructed, as the LER states, in the preper interpretation.of the TS. He stated from the date of the incident up to the date of the accident, his interpretation of the TS did not change. As long as he received a valid leak rate test within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, he would not take the action required by the Action Statement. See pages 23 and 24.

When questioned about the mechanics of performing a leak rate test, Mr. Bocher stated that there were norma 11y.3 CRos on watch. One was the panel operator for the primary plant, one took care of the secondary plant

and one was assigned duties such as hanging danger tags and surveillance tests. He stated that the operator assigned these duties (i.e., the administrative duties) was the individual who normally performed the leak rate tests. He could not recall whether the primary or secondary panel O operator maintained the CR0 Log. See pages 26 and 27. According to Bocher, the operator doing the leak rate test would try and keep the other operators informed that a leak rate test was in progress and not to change power, acd water, etc. See pages 27 and 26. Bocher recalled; however, that they were not as good at. communications between operators as they should have been.

See page 28.

Bocher said they logged only good leak rate tests in the CR0 Log. He could not recall ever logging the start times of any leak rate tests (good or bad).

Mr. Bocher was provided with a copy of TMI Administrative Procedure 1012

" Shift Relief and Long Entries." Mr. Booher confirmed that the procedure required the start and stop times of all surveillance tests be logged.

Mr. Bacher said that it was out of ignorance of this requirement that ,

operator did not log the start time of leak rate tests. He did not believe l that they were intentionally kept from being logged in an attempt to deceive someone into not realizing how many leak rate tests were being performed.

See pages 29 to 33.

Mr. Bocher stated that he was not aware of any cther surveillance test where bad results were thrown away. He stated leak rate tests were thrown away because they were so numerous. See page 34. Bocher stated that his Shift Foreman and his Shift Supervisor were aware that leak rate tests were being thrown away. He was never instructed to perform the leak rate test differently or not to throw away bad leak rate tests. See pages 34 and 35.

! O Mr. Bocher indicated that they would run at least one or two leak rate tests per shift. Hewever, it was more difficult to get good leak rate test results~

as the date of the accident approached. See page 37.

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When questioned about the computer program for calculating leak tate results.

Bocher stated that he was comfortable that he knew what was happening with

! leakage in the RCS. He did not have a problem with the computer program.

Booher stated that he did not attribute all of the problems with leak rate i tests as being caused by instrument inaccuracies however. He attributed some

of the problem with the leaking PORV or code safety valves. See -

pages 37 and 38.

The interview then concentrated on hydrogen additions. Mr. Booher stated that hydrogen was added from the control room when ever pressure in the MUT was low in the operating band or when it was necessary in order to maintain RCS chemistry within specifications. See pages 40 and 41. Although Booher 1

considered the addition of hydrogen a W emical addition," he did not consider it the type of " chemical addition" that was precluded by the surveillance procedure for performing leak rate tests. See pages 42 and 43.

Mr. Bocher was reminded of the allegations made by Harold Hartman that hydrogen additions were used to manipulate leak rate test results and that l Hartman had said, on more than one occasion, that he had observed Mr. Booher '

add hydrogen to alter leak rate tests. Mr. Booher was also informed that Mr

O leak rate con. tests. Thus,also Blessing two out of the three that admitted CRO'shydrogen on Mr. Booher's was shiftused by oper firmed that this action was done. Mr. Bocher was asked to what extent be had been involved in this type of activity. He responded:

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! "Like 1 testified in the grand jury. I personally don't ever l remember of adding hydrogen to affect the make up tank level. I I remember of hearing discussions. I don't remember when the discussions were. But I thought it was kind of ridiculous, to tell you the truth, to have some kind of a gas make a level change. I still believe that, to tell you the truth. I don't understand how adding hydrogen to a tank would make the level change." See 45 and 46.

Mr. Bocher was questioned further about when the discussions he referred to above took place. Mr. Bocher could not recall. He did not know if it was during his April 1980 interview or at some time prior to the accident. See page 47.

Mr. Bocher stated that he did not understand, even today, how MUT level could be altered by the addition of hydrogen. He was informed that it did not matter if an operator understood wh adding hydroJen produced a change in MUT level, as long as the operator knew that there was a cause and effect relationship. Many operators did not understand why it happened, but nonetheless used the phenomenon to get good leak rate test result. See pages 47 and 48.

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Mr. Bocher stated that he did not recall Mr. Blessing telling him that he ever added hydrogen to effect test results. He said he had a good relationship with Hartman and, thus, did not know why Hartman would state

, that he had personally witnessed Bocher-add hydrogen to effect leak rate tests. Bocher could also not recall if Hartman and he ever entered into a discussion about whether hydrogen could change MUT level. Booher was not aware of any operator making hydrogen additions to alter leak rate test results. See pages 48 to 52.

NOTE: In his April 1960 interview, Mr. Blessing stated, C it was no secret that hydrogen was being added to the makeup tank during the running of the reactor coolant surveillance test and it was totally comon practice. In this

same interview, however, Mr. Blessing stated that while he knew from personal knowledge that Hartman had added hydrogen to the makeup tank to get good leak rates, he could not say for a fact that Ray Bocher had added hydrogen or water or in any other way falsified the leak rate.

When asked if he was ever directed to make hydrogen additions for the purpose of altering leak rate tests, Eooher responded, no. He stated that he would O definitely remember being told that. See pages 53 and 54.

Mr. Bocher admitted that there was pressure to get good leak rates; however, he did not recall any particular supervisor applying pressure. There was pressure, he said, because good leak rate test results were hard to get. See page 54 While Booher admitted that there was pressure, he did not feel his i

job was in jeopardy if he was not able to obtain a satisfactory leak rate test by the end of his eight hour shift. See page 55.

Bocher stated that he could not recall any discussions by management i personnel or supervisors about problems with leak rate tests. He stated that

{ discussions of that nature would normally be held in the Shift Supervisor's i Office and not in the Control Room. See page 56. He did not recall having l any discussions about leak rate test E h anyone except the other operators j on his shift and with other operators during watch relief. M pages 56 and 57.

Mr. Bocher believes that had Hartman added hydrogen to manipulate leak rate tests that Hartman would have told him; however, he does not recall any such discussions. Bocher also said it would be possible for one operator to add hydrogen during a leak rate test without the other operators being aware of it. See pages 59 and 60.

In sumarizing Mr. Bocher's testimony regarding hydrogen:

He was not aware, at the time, that either Hartman or Blessing or any O 1.

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other operators were adding hydrogen to manipulate leak rate tests.

He has no reason to believe that tests were altered by the addition cf hydrogen. -

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1 l 3. He did not ever recall aiscussing with other operators the ' possibility of altering leak rate tests by the addition of hydro

4. There was no individual (management and supervisory) whogen indicaten to the that MUT.

they should add hydrogen to alter leak rate tests. See pages 61 and 62.

The next' portion of the interview concentrated on the use of water additions to manipulate leak rate tests. Mr. Booher stated that water additions were required to be logged in the CR0 Log. He stated that it was possible to add

, water during the performance of leak rate test and properly account for it by 1 ,. entering the proper amount into the computer at the end of the leak rate test. He stated that if he added water, that is what he would do. It is also possible, according to Booher, that water was added during a test and not properly accounted for in the test. But he did not think that that ever happened. W pages 63 to 65.

Booher stated that he did not remember making a water addition during the I performance of a leak rate test for the purpose of intentionally altering a i leak rate test. He was then asked if "by don't remember," he meant he could I have done it, but did not remember or did he mean that he didn't do it. '

i Bocher responded: "Of course, anything is possible but I don't remember adding water to influence a leak rate." See page 66.

An excerpt of Mr. Hartman's July 26, 1983 interview with OI was read to -

Mr. Bocher.

Question to Mr. Hartman: "What specific operators did you witness add water to the make up tank in order to manipulate leak rate tests?" -

Answer by Mr. Hartman: " Ray Bocher, because he was on my ,

shift."

Mr. Bocher responded to Mr. Hartman's allegations by stating: "If I remembered, I would tell you but I don't remember. See page 73.

Mr. Bocher was provided with a copy of the technical analysis of his leak rate tests. After a short break to allow him to review the document, a detailed discussion of several of the leak rate test results took place. In almost all cases reviewed Mr. Bocher disagreed that the analysis.showed water had been added during the tests. However, no credible explanations were offered to explain the phenomena that are present on the MUT level strip

. charts. It was pointed out to Mr. Bocher, in a few cases the technical analysis is subject to judgment; however, in the majority of cases the water additions were quite apparent. In three cases water was added to the MUT and legged in the'CR0 Log by Mr. Booher, yet these water additions were not included in the computation of leak rate results. See pages 71 to 110.

Mr. Eccher was informed that in Mr. Blessing's 1980 interview, Blessing stated that it was cccr:on practice by a large portion of the Control Rocm Operators to add hydrogen to the make-up tank while rerunning leak rate

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surveillance tests in order to assist in getting a good leak rate test .

result. Blessing emphasized that it was no secret that hydrogen was being added to the make-up tank during tests and that it was his opinion that Shift Supervisors and Shift Foreman were well aware of this practice. Booher was thenasked,withstatementslikeMr. Blessing's,howcouldhedenythathe had no knowledge that this practice was going on. Bocher's response (although referring to Harold Hartman) was

" Evidently, Harold didn't like me a hell of a lot either because I read a statement in the grand jury where Ray wasn't a very good operator." See pages 15 to 117.

NOTE: While referred to at this point in the interview, but not read to Mr. Bocher, a statement was made in a i

recent interview with another former TMI-2 CR0 l M. V. Cooper on September 28, 1984. During Mr. Cooper's interview, he stated that he strongly suspected Mr. Hartman and Mr. Bocher of manipulating leak rate test results during the period under

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investigation. A copy this portion of Mr. Cooper's interview is included as Attachment 6 to this enclosure.

Mr. Bocher again stated for the record that he had no knowledge of anyone manipulating leak rate tests at TMI-2. This included Messrs. Hartman, Blessing, Cocper, Congdon and Coleman. See page 121.

At the close of the interview, Mr. Booher was- informed that based upon his ~

testimony and the testimony of others, it was difficult to reach a conclusion that he was not involved in leak rate manipulation or that he had no kncwledge of what was going on around him. See page 122.

IV. Conclusions i

While many of Mr. Booher's responses to questions associated with leak rate surveillance test problems at TMI-2 were consistent with statements made to

' the NRC by other licensed operators, the majority of his responses regarding his personal involvement in or knowledge'of leak rate test manipulation do not appear credible. During the interview Mr. Bocher relayed tie following information.

1. Leak rate tests were routinely run at least once per shift. At times the tests had to be run several times before a satisfactory result was obtained (i.e., unidentified leakage within the Technical Specification limit of 1 gpm).

2. OnlysatisfactoryleakratetestresultswerekoggedintheCR0 Log.

O Test results which exceeded the Technical Specification limit were not legged. Note: These actions were contrary to TMI Administrative

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Procedure 1012. " Shift Relief and Log Entries," which required the start and stop times of all surveillance tests be logged in the CR0 Log'.

3. Only satisfactory leak rate tests were retained. All bad leak rate tests (i.e., unidentified leakage greater than the Technical Specification limit of 1 gpm). Note: These actions were contrary to TMI-2 Technical Specification 6.T C " Record Retention," which required that records of surveillance activities required by the Technical Specifications be retained for a period of at least 5 years.

4. Mr. Bocher's first line supervision (Shift Foreman and Shift Supervisor) were knowledgeable of the difficulties operators were experiencing in obtaining satisfactory test results. These same individuals directed the throwing away of bad leak rate test results.

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5. Contrary to the comitment contained in the narrative of LER 78-62/1T, Booher's shift was not instructed in the requirements of applicable sections of the Technical Specifications or in the requirement to imediately invoke the Technical Specification Action Statement when the t

associated Limiting Condition for Operation was exceeded. Booher stated j that they did not abide by the shutdown requirements of the Technical

! Specitication because "that was more or less in the hands of ,

i management." Note: These actions are contrary to THI-2 Technical Specification E 6.2, " Reactor Coolant System Operational Leakage Limiting Condition for Operation," and are contrary to the licensee's stated corrective action in LER 78-62/1T of November 1, 1978.

6. Mr. Bocher stated that he was unaware that hydrogen additions to the )

make-up tank could affect make-up tank level indication and, thus,  !

) favorably influence leak rate test results. Note: Mr. Bocher's j

] statement is in conflict with statements made Dy the two other CR0s on i

Mr. Bocher's shift. Mr. Hartman and Mr. Blessing both admitted that

) they added hydrogen to the make-up tank to influence leak rate test i results. They.also indicated that it was common knowledge among

l operators at TMI-2 that hydrogen could alter leak rate test results. It 1 was also Mr. Blessing's opinion that it was comon knowledge up to the l level of Shift Foreman and Shift Supervisor that operators were altering l 1eak rate tests using hydrogen.

I 7. Mr. Bocher stated that he never added water to the make-up tank for the l

purpose of altering leak rate test results. Note: Mr. Bocher's I statement is in conflict with both the technical analysis and statements i made by Mr. Hartman. The technical an'alysis shows,that during every l 1eak rate test in which Mr. Bocher took part from December 26, 1978

! through the date of the accident (8 tests), included water additions to i l

the make-up tank that-were not accounted for in the leak rate test l calculation. Mr. Hartman has stated under oath that he personally -

l witnessed Mr. Bocher add water to the make-up tank in order to l

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manipulate leak rate tests. The methods described by Mr. Hartma'n for adding water are the same methods which appear in the technical analysis.

In summary, the weight of evidence, including technical analysis and statements by other operators on Mr. Booher's shift, strongly suggests that j Mr. Bocher was not truthful in answering questions regarding his l

participation in or knowledge of leak rate test manipulation at TMI-2 during  :

the period September 30, 1978 to March 28, 1979. l 4

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