ML20155J636
| ML20155J636 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 12/03/1984 |
| From: | Russell W Office of Nuclear Reactor Regulation |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20151L202 | List: |
| References | |
| NUDOCS 8605270131 | |
| Download: ML20155J636 (12) | |
Text
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,o e' UNITED STATES Enclosure 5
! % NUCLEAR REGULATORY COMMISSION 5 j wasmmorow. o.c.nossa 0,\.....,/ December 3, 1984 MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation THRU: Hugh L. Thompson, Jr., Director I Division of Human Factors Safety FROM: William T. Russell, Deputy Director j Division of Human Factors Safety j I
SUBJECT:
RESULTS OF JOINT NRR/01 INVESTIGATION AND EVALUATION OF i MARTIN V. COOPER
~
Reference:
- 1. Memorandum from S. J. Chilk (SECY) to B. B. Hayes (01) 1 and W. J. Dircks (EDO), dated April 2, 1984,
Subject:
1 Staff Requirements-Discussion of Pending Investigation-TMI
Subject:
NRR Review of OI i Investigation Materials Concerning Hartman Allegations of l Falsification of Leak Rate Data at TMI, Unit 2 !
Subject:
Request for Information Under 10 CFR 55.10(b)
, 4. Letter from M. V. Cooper (SRO San Onofre 2/3) to H. L. Thompson (DHFS) dated July 2, 1984,
Subject:
Response to Reference 4 The purpose of this memorandum is to document the results of the joint OI/NRR investigation and evaluation of Mr. Martin V. Cooper, currently a Senior Reactor Operator at San Onofre, Units 2 and 3 and to provide a reconnendation regarding whether his current Senior Reactor Operator's license should be revoked, modified, or suspended under 10 CFR 55.50 due to his involvement in preacciden.t leak rate testing irregularities at TMI-2.
NOTE: This memorandum and Enclosure 1 discusses information which is the suSIectofanongoing01 investigation. This memorandum and Enclosure 2 discusses 4nformation that is maintained in the NRC's Privacy Act System of Records (NRC-16). This memorandum and enclosures may not be disseminated O 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 to know" basis.
^
l i ,, 8605270131 860516 l
PDR ADOCK 05000320 i **. P PDR
Harold R. Denton December 3,1984
Background
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As a resu1t 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 leak rate tests at TMI-2 and refer back to OI those matters which required further investigation. The results of NRR's review was i provided in Reference 2. The review determined that follow-up investigation :
by 01 and further evaluation by NRR was needed in the case of seven licensed l operators. Of the seven individuals identified in Reference 2, four are l currently licensed at TMI-2, two are ifcensed at Waterford 3 and one is !
licensed at San Onofre 2 and 3. At a follow-up Commission meeting on May 23, l 1984 NRR proposed joint OI/NRR investigations and evaluations of these individuals. Subsequently, NRR issued letters to the seven individuals under 10 CFR 55.10(b) requesting additional infonnation regarding current perfor-i mance. Based upon an investigation into the individuals' past involvement in improper activities at TMI-2 and an evaluation of the individuals' subsequent performance, NRR would recomend what action, if any, should be taken against the identified. individuals.
Past Involvement in TMI-2 Leak Rate Testing Irregularities
- On the morning of September 28, 1984, a joint OI/NRR interview of Mr. Cooper
! was held in San Clemente, California. The interview was conducted under oath and in the presence of Mr. Cooper's personal attorney. The purpose of the interview was to determine Mr. Cooper's role in improper activities associated with reactor coolant system leak rate surveillance testing at TMI-2 ' prior to the accident on March 28, 1979. At that time, Mr. Cooper was
- a licensed reactor operator (RO) and served as a Control Room Operator (CRO) on shift "C." A detailed evaluation of Mr. Cooper's interview is included as Enclosure 1 to this memorandum.
Mr. Cooper confirmed that preaccident leak rate testing irregularities took I
place at TMI-2. Mr. Cooper admitted his involvement in activities that were in violation of approved procedures and the intent of the TMI-2 Technical Specifications. While he admitted knowingly adding hydrogen to the makeup tank during periods in which leak rate tests were being conducted, he denied that his motive for the hydrogen additions was for. the express purpose of manipulating the leak rate test results. According to Cooper, he only added hydrogen to the makeup tank during a leak rate test if hydrogen pressure was low in the operating band. Cooper also denied that he intentionally added s water to the makeup tank during leak rate tests without including the '
addition in the leak rate test calculations. This is in conflict with technical analysis of the leak rate test records, which show unrecorded water additions. Cooper's statement that he did rate test results is not supported by othernot intentionally manipulate leak evidence.
Other aspicts of his testimony indicate first line supervision and middle level management at TMI-2 were knowledgeable of the difficulties operators were experiencing with leak rate surveillance testing and took-little or no action to correct the situation. While Cooper's actions in many cases were j not in accordance with procedure, these actions were apparently comon
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l Harold R. Denton December 3, 1984 practice among operators at TMI-2. In most cases, these actions were known to be occurring by his first line supervision, and he believes, also by middle level management.
Current Perfonnance N
Conclusions During the period Mr. Cooper was licensed as a Control Room Operator at TMI-2 prior to the accident, he improperly peiformed leak rate surveillance testing by knowingly not following procedures. He has admitted his involvement in these practices; however, he continues to deny that he intentionally manip-ulated or falsified leak rate surveillance test records. While there is
- evidence that he knowingly violated procedares and that'his actions were known by him to effect leak rate test results, the evidence is not conclusive.
Mr. Cooper is the first o seven op'rators e licensed at TMI-2 prior to the
1 I Harold R. Denton December 3, 1984 accident who are undergoing a similar joint OI/NRR investigation and evaluation. It is possible that during the remainder of these investigations, additional evidence could be developed regarding Mr. Cooper's preaccident activities at TMI-2 that were not considered in this report.
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&Ut> l- T & MAA----
William T. Russell. Deputy Dirictor Division of Human Factors Safety -
Office of Nuclear Reactor Regulation
Enclosures:
As stated cc: B. Hayes K. Christopher O
e S
6 e
S u
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NOTE: This enclosure discusses information which is'the subject of an ongoing OI investigation. This enclosure may not be disseminated outside the NRC without coordination with NRR and the permission of the EDO or the O Director, 01.
basis. ,
Internal access and distribution should be on a "need to knew" Enclosure 1 ,
i P st Involvement in TMI-2 Leak Rate Testing Irregularities 4
I. Background On September 28, 1984, a joint Office of Investigations (OI)/ Office of
. Nuclear Reactor Regulation (NRR) interview of Martin V. Cooper'was held at the Seahorse Hotel in San Clemente, California. The purpose of the interview was to determine Mr. Cooper's role in improper activities associated with Reactor Coolant System (RCS) leak rate surveillance testing at Three Mile Island, 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. Cooper at the interview was his personal attorney, Michael McBride of the law firm LeBoeuf, Lamb, Leiby and MacRae, Washington, D.C. A copy of the transcript associated with this interview is provided as Attachment 1.
) Mr. Cooper is currently employed by Southern California Edison Co. as a i licensed Control Room Supervisor at San Onofre, Units 2 and 3. Mr. Cooper O has been employed at San Onofre for approximately one and a half years.
Prior to his current employment, Cooper was employed by General Public i
I Utilities (GPU) and Metropolitan Edison Company (Met-Ed) at TMI-2.
Mr. Cooper was originally hired by Met-Ed as an Auxiliary Operator (AO) and worked in that capacity at THI-2 for approximately one year. He received his Reactor Operator's (RO) license from the NRC in the sumer of 1978. From that period up to the date of the accident Cooper served as a Control Room Operator (CRO) on Shift "C" at TMI-2. Following the accident, Cooper continued to work at THI-2 receiving his Senior Reactor Operator's (SRO) license in March 1980. Cooper served as both Shift Foreman and Shift Supervisor at TMI-2 until he terminated his employment at THI-2 approximately November 1982.
The interview with Mr. Cooper concentrated on the period September 30, 1978
, through March 28, 1979. During the majority of this timeframe, Mr. Cooper's shift consisted of the following individuals:
Shift "C" Shift Supervisor Brian Mehler Shift Foreman Charles Adams CR0 Joseph Congdon CR0 Martin Cooper CR0 (in training) Mark Phillippe O
Mr. Cooper and Mr. Congdon were previously interviewed on this subject on April 10, 1980 during a joint investigation into the "Harte:an Allegations."
Copies of the reports of.these interviews are included as Attachments 2 and 3, respectively, to this enclosure.
i
.z.
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 support to the Department of Justice. --The results of Dr. Chung's analysis were utilized in questioning Mr. Cooper during this 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, 29 involve Mr. Cooper. During these 29 tests, Mr. Cooper was either the CR0 who signed the surveillance test record or he i was the CR0 who signed the CR0's Log for the period during which the test was
, conducted. Of the 29 tests involving Mr. Cooper, Dr. Chung's analysis
+
identifies 15 tests involving possib,e water and/or hydrogen additions to the
- makeup tank during the one hour time period in which the leak rate tests were conducted. This includes 13 possible water additions and 4 hydrogen additions (2 hydrogen additions were combined with tests that involved possible water additions). A sumary of leak rate tests at TMI-2 involving Mr. Cooper, along with the surveillance tests sheets, CR0 Log extracts, and I. makeup tank strip charts for the 15 questionable tests, are included as Attachment 4 to this Enclosure.
A sumary of the interview with Mr. Cooper is provided in Section II below.
A citation to the page number of the transcript in which this information was
- discussed is also provided. Overall conclusions regardino Mr. Cooper's involvement in improper activities associated with TMI-2 'eak rate surveillance testing is contained in Section III.
II. Interview Sumary In describing how his shift was organized during the 1978/1979 timeframe, Mr. Cooper stated one CR0 was assigned duties as the panel operator, where the CR0 Log was kept. This individual was in overall charge of operations on the shift. A second CR0 was assigned duties as the " switching and tagging" i operator and was in charge of surveillance tests for the shift. If a third CRO, not in a training status, was assigned to the shift, this individual would perform surveillance tracking duties. See pages 12 and 13. On a routine basis, at the beginning of each shift, the operators would perform a calimetric check of the Nuclear Instrumentation, which took about 10 minutes and then would commence a one hour leak rate test. See page 13. Although the Technical Specifications (TS) required a satisfactory leak rate test only once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, it was-comon practice to try and obtain a satisfactory leak rate test every shift (i.e., every eight hours). There were times when leak rate tests had to be run several times a shift until one with a satis-
- factory result (within the 1 gpm limit for unidentified leakage required by the TS) could be obtained. See page 15. If, leak rate tests came out bad
. (greater than 1 gpm or a large negative number) a new leak rate test was started and the bad leak rate test would be thrown away. See page 16.
3 According to Cooper, the logic for throwing away bad tests and accepting good tests as valid was that operators could tel.1 from looking at other instru-nentation and keeping the plant stable that they had not developed a leak.
Cooper bad little faith in the calculation performed by the computer because for the saTne plant conditions, the results were erratic. The leak rate test 1
was not telling the operators what the plant was really doing. See pages 16 end 17. Cooper stated that it was common practice to throw away bad leak rate tests. He did not recall being specifically instructed by supervisors to throw bad leak rate tests away, but he was confident that it was common
, practice en all shifts. It had been the operating policy, ever since Cooper was licensed. See pages 18 and 19. l Cocper was.. questioned regarding his interpretation of the TS associated with leak rate surveillance testing. According to Cooper' once a satisfactory, leak rate Test was obtained, operators had 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in which to obtain another satisfactory leak rate test before having to enter the required action statement of the TS. Cooper said that was the interpretation of the requirement, regardless of how many bad leak rate tests were obtained in the interim. 1 Cooper did not know who started that interpretation but that was the general practice. He recalled that everyone followed that practice. See pages 18 and 19. Cooper stated that operators were required by TS to perform
- this surveillance every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in order to keep the plant on the line. In retrospect, Cooper said "[W]e were trying to comply with the letter of the specification, and looking back on it, we really weren't complying with the spirit." Cooper indicated "I have a new understanding of how all this works now. At the time I had a different understanding and I thought it was perfectly okay so long as you got one leak rate satisfactory every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and we had met the regulations." See pages 19 and 20. Cooper was questioned about whether there was any change in interpretation of that policy after the October 18, 1978 incident in which an NRC inspector found several bad leak rate tests lying around the control room and inquired why the operators had not entered the action statement of the Technical Specifications. As a result of that incident, the licensee submitted a Licensee Event Report (LER) to the NRC on November 1, 1978 (LER 78-62/1T). According to the LER the incident was caused by a " misinterpretation of the requirements of the T.S."
O The LER further stated:
, "The appropriate personnel will be instructed on the re-d quirements of the applicable sections of the T.S. and the requirement to immediately invoke applicable action state-ments when the provisions of the LCOs [ limiting conditions
- for operation] are not met."
In recalling the October 18, 1978 incident, Cooper stated:
i "My recollection, you know, I wasn't there when it hap-pened, and the way I heard about it is we were coming on in the evening relieving B-shift, and they told us about i the NRC inspector Don Havercamp finding these things lying on the desk by the computer, and part of the turn-over from the control operator I w'as relieving that this had happened. That from now on if you are throwing awa~y bad ones, make sure you throw them away, just don't leave them lying around." See page 64. ;
When asked if his interpretation, with respect to needing a good leak rate test only once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, regardless of how many bad leak rate tests were obtained in the interim, had changed following the October 18, 1978 incident, Cooper responded, "That was carried forward, it was the same, and I l believe that is the general interpretation in the department and nothing j b
O ever changed." See page 68.
According to Cooper it was difficult at times to get good leak rate test results. There was no pattern " rhyme or reason" as to why it was hard one
l 4
time and easy the next. Cooper stated it was common knowledge at the supervisory level that operators were having difficulty obtaining good leak rates. ' Cooper's Shift Supervisor, Brian Mehler, was aware that they were having a problem with getting good leak rates, and that the results were ,
inconsistent. Mehler was aware that unsuccessful tests were run and that additional-tests had to be initiated. Cooper stated that there was a lot of pressure to get good leak rate test results. There was constant questioning by the shift supervisors regarding leak rate test results. See pages 24 and
- 25. According to Cooper, although there was pressure to get a good leak rate, he did not feel that the pressure was at his level. He stated he never had the feeling that if he did not come up with a good leak rate, that something." bad" was going to happen to him or that it would cast doubt on his competence as an operator. See pages 27 and 28.
Cooper was also questioned regarding the motive for not logging both the start and stop times of leak rate tests as required by TMI Administrative Procedure (AP-1012). Cooper said that, although the requirement existed, i operators did not normally log the start and completion times for tests that were run once or more per shift, such as leak rate tests. Only completion times were logged. Cooper stated, however, that not logging both times was not acceptable to the QA organization at TMI. When questioned why unsuccessful tests were not logged, Cooper stated "we we're just treating them as if they never occurred, so therefore there was nothing to log." Cooper indicated, however, that he had never been told by his supervisors not to log unsuccessful tests as an effort to hide the fact that they were having O problems in this area. See pages 20 and 21.
When questioned about possible unrecorded water additions as a mechanism to I manipulate leak rate tests results, Cooper stated that he never added water
! during a leak rate test that was not accounted for in the computer calcu-
- lation. See page 34. According to Cooper, if an addition was made and not l entered into the computer, it was caused by miscomunication between the operators: "[T]he best I can tell you is that it wasn't done on purpose and it wasn't done with any malicious intent to fool the computer or anything like that. It could only have been a lack of communication..." See pages 40 ,
j and 41. Cooper indicated that "[t]here were numerous instances when we got I
- fouled up and had to stop a leak rate that we had in progress because we had altered the conditions of the test." Cooper said, it got to the point i sometimes, because they were so busy and they were running the tests a couple 1
! of times a shift, that they put up 3x5 cards by the reactor coolant drain tank and the makeup tank controls that indicated a leak rate test was in l progress (i.e., don't add water or pump down the drain tank). See page 38.
i When asked if he was aware of other operators that used unrecorded water additions to insure themselves the margin of getting a good leak rate test result, Cooper replied that he knew it did not happen on his shift, but he had the feeling that it was happening on Hartman's shift. This was based i upon innuendoes or things that Hartman or Booher might have said (Note:
Harold Battman and Raymond Bocher were CR0s.on Shift "E.") See page 34.
I Cooper was then questioned in detail about the effects of hydrogen additions to the makeup tank on leak rate test results. Cooper was read an excerpt of an NRC interview conducted with Joseph Congden in 1980 in which Congdon admitted that hydrogen was added to the makeup tank for the purpose of i
I
affecting leak rate test calculations. According to the report of interview with Congdon (Attachment 3), Congdon stated "the entire shift, himself, Cooper and Adams (Shift Foreman), knew that hydrogen affected the leak rate and that it was his belief it was a group decision to satisfy surveillance .
requirements." See page 43. Regardless of Congdon's admission. Cooper stated that~he does not believe that Congdon added hydrogen to affect leak rates. He said he did not know why Congdon made those admissions. See page
- 56. According to Cooper, "we did believe that hydrogen could affect the outcome of the leak rate, but the methodology, how we did it, or if it would do it consistently, we didn't know and we didn't have any technical basis for
- understanding what was going on." See page 48.
l Cooper stated during the interview:
"We did, I did, believe that there was some effect when you added hydrogen to the make-up tank level indication. I am pretty sure there are occasions when the leak rate was in progress that we added hydrogen and we looked to see if it affected a leak rate result, and lo and behold it did. You know, it was operator curiosity to see if really that was true because we couldn't figure out any reason why that should .
happen with the way the level transmitter was supposed to work ;
with a dry reference leg, adding that hydrogen would have an effect." See page 48.
l Cooper did not consider his actions to be a willful attempt to manipulate test results. Instead, Cooper rationalized his actions in the following manner:
"It may be splitting hairs. I think the final line is it 4
wasn't, okay, we are doing a leak rate, let's add hydrogen
. and maybe we'll get a good leak rate out of it. It is more ~
1 like okay, we've got a leak rate in progress, the hydrogen is low, I've got to add hydrogen, lets see how that affects the result. If the result came out good, we accepted it."
See page 49.
In describing other members of his shift, Cooper characterized his Shift Foreman, Charles Adams as: "a real stickler for detail, and, you know, making sure th~at things were done right. He wanted to make sure that everything was done; he wanted to satisfy management. He wanted to satisfy the procedures; he wanted to satisfy the tech specs. Chuck never led you to believe that cutting corners was okay, or, you know, a little subterfuge here was okay."
See page 57. Cooper said that he was not aware of Mark Phillippe ever manipulating test results. See page 58.
! When questioned funer regarding Cooper's earlier statement that he suspected leak rate test manipulation may have occurred on Shift "E," Cooper stated: , ,
"It is a general feeling about the way those guys operated, l O shoot from the hip--a lot of it is just strictly, you know, personalities of the guys, you know, the rules be damned,
you know, nobody is going to tell me what to do, I'll do what I want. Both of those individuals are head-strong, unpredictable, and they are going to do whatever makes them feel good at the moment, and if they got a kick out of having us come on shift and relieve them and telling us we -
got a-good _ leak rate-- nobody else can do it, we got one--
that kind of gives you the feeling that they did something besides just run the test to make that occur." See page 60.
Cooper also was asked about John Blessing, the other CR0 (in training) on Shift "E." Blessing was one of the individual's who previously admitted to the NRC that he added hydrogen to manipulate leak rate test results. Cooper said, "I have heard since that he has supposedly admitted to this. Joh,n didn't fit in with those two guys. He had a lot more integrity." See page 62.
Cooper was asked if he personally brought leak rate test problems to the attention of management. Cooper said that he discussed problems regarding leak rate tests with other CR0s and his supervisors, but did not discuss them with management personnel. When specifically asked if he had conversations regarding leak rate problems with Jim Floyd, Mike Ross, George Kunder, Gary Miller or Jim Seelinger, Cooper responded "no" to all of the above.
When asked if any of these individuals were aware of the problems operators were having with leak rate tests Cooper responded, "I know that Jim Floyd was, the supervisor of operations. He was getting feedback from the shift O supervisor. Whatever conversations they were having, he was aware of it."
See page 81.
In closing the interview, Cooper said that to the best of his knowledge, Joe Congdon and Mark Phillippe never added hydrogen to improve the results of a leak rate test and he did not believe they would. He also confirmed, that beside his suspicion of what was happening on Hartman and Bocher's shift, he was not personally aware of any other operator, senior reactor operator, shift foreman, shift supervisor or management personnel who purposely manipulated leak rate tests results. See page 87.
III. Conclusions Throughout Mr. Cooper's interview he appeared to answer questions in a straightforward manner. Mr. Cooper's testimony confirmed many of the preaccident leak rate surveillance test irregularities that were originally brought to light by former TMI-2 CR0 H. Hartman. Mr. Cooper's statements -
were al.so consistent with D0J's Statement of Facts and evidence developed by 01 during its earlier TMI-2 Leak Rate Investigation. During the course of the interview, Mr. Cooper confirmed the following items:
- 1. Cooper had little faith in reactor coolant system leak rate test calculations which were performed to show compliance with the Technical Specifications..
- 2. Leak rate test results were erratic even when tests were run back to back with the same stable plant conditions.
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.- -- - _ -. - - _ . - _ _ - . - - . - - - _ . - . . = - _ - _ - . . - - . - - - ~ -
- 3. It was comon practice to run leak rate tests several times per shift until an acceptable result was obtained. The acceptable tests
- were retained and- the unacceptable tests were thrown away.
- 4. Ecoper felt pressured to obtain an acceptable leak rate test on -
i' itach shift; however, he did not feel that if he was unable to get an
~
acceptable test by the end of the shift that any adverse action would be taken against him or that his competence as an operator '
would be called into question.
- 5. In spite of pressure to obtain satisfactory leak rate test results.
Cooper was never asked or directed by his supervision to manipulate test results. ;
[ -
- 6. Cooper's first line supervision (Shift Foreman and Shift Supervisor) and he believed middle level management (Supervisor of Operations) were knowledgeable of the difficulties operators were experiencing ,
in obtaining satisfactory test results.
- 7. Contrary to the commitment contained in the narrative of LER 78-62/1T, Cooper'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 associated Limiting Condition for Operation was exceeded. Note: This statement is consistent with the prosecuting attorney's Ttafement of Fact read into the record as part of the O 8.
trial settlement.
The only instruction Cooper received following the October 18, 1978 i incident, associated with LER 78-62/IT, was to insure that bad leak
, rate test surveillance sheets were thrown away and not left lying
- around the control room where the NRC could find them.
i
- 9. Cooper was aware that hydrogen additions to the makeup tank would affect makeup tank level indication and thus affect leak rate i surveillance test results. However, he felt the effect was not always consistent.
- 10. Cooper did not understand the technical reason why hydrogen addition 4 effected makeup tank level indication.
- 11. Cooper admitted knowingly adding hydrogen to the makeup tank, if hydrogen was low in the operating band, during periods in which leak rate surveillance tests were being run. If the test result came out
- acceptable, Cooper retained the test as documented evidence of i demonstrating conformance with the Technical Specifications.
l . .
- 12. Cooper stated that he never intentionally added water to the makeup tank to effect leak rate test results. If water was added and not ipcluded in the calculation, he felt it was because of operator miscomunication between the operator performing the test and the operator doing the water addition. Note: In some tests Co,oper held O
- both positions.
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, 13. Cooper suspected at the time that Shift "E" involving H. Hartman and
] - R. Bacher may have been manipulating leak rate test results;
- however, he had no proof to confirn his suspicions.
- 14. Other than his suspicions regarding Shift "E," Cooper was not aware of any operator, supervisor or manager who intentionally manipulated or directed manipulation of leak rate test results.
I The only area in which Mr. Cooper's statements are not credible concern his
, direct involvement in leak rate test manipulation. Cooper admitted knowing hydrogen additions during leak rate tests could (and sometimes did) alter leak rate test results. Cooper also admitted adding hydrogen during leak rate tests and observing makeup tank level indication to see if the hydrogen j addition had any effect. Cooper stated that if the test result came out within the allowable Technical Specification acceptance criteria, he accepted ,
the test as valid. Based upon Mr. Congdon's admission on April 10, 1980 that hydrogen was added for the purpose of effecting the leak rate calculation and ;
that this was a group decision (Congdon, Cooper and Adams), Cooper's explanation that he only added hydrogen during a leak rate test if hydrogen was low in the operating band and not for the purpose of altering leak rate test results is not credible. Regardless of his postaccident
- rationalization, Cooper knowingly affected leak rate tests by the addition of hydrogen to the makeup tank.
O Cooper's statement that he never added water to the makeup tank during periods in which leak rate tests were being conducted without including the additions in the leak rate test calculations also does not appear credible.
Cooper's explanation that if such an addition did take place and was not included in the test calculation, it was due to miscommunication between-the
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j operators does not appear to be supported by the facts. Between September 30,
! 1978 and March 24, 1979 Mr. Cooper was involved in 29 leak rate surveillance ;
tests. (By Mr. Cooper's own admission, he was involved in many more; I however, these test records were not retained). Water additions appear to !
have been made during 14 of these tests. In only one instance, was the water i addition logged in the CR0 Log and included in the test calculation. The l other 13 water additions were neither logged in the CR0 Log nor provided as !
- input to the computer. It does not appear reasonable to assume operator ,
i miscomunication occurred during 13 out of 14 tests. In addition, four of j the 13 tests records show that Mr. Cooper signed both the CR0 Log and the :
leak rate surveillance sheet. !
- In sumary, Mr. Cooper confimed many of the preaccident leak rate testing l i irregularities that took place at TMI-2. While it is not clear whether Mr. Cooper's statement that he did not intentionally manipulate leak rate !
test results is true, or whether it is a postaccident rationalization, the !
- staff believes that Mr. Cooper did intentionally manipulate leak rate test l' results based upon his knowledge that hydrogen and water additions would
- alter the results and the fact that he made both types of additions.during i leak rate tests. It is clear from other aspects of his testimony that first
- line supervision and middle level management at THI-2 were knowledgeable of O
- the difficulties operators were experiencing with leak rate survei.llance I
- testing and took no action to correct the situation. Mr. Cooper was a ;
- relatively junior member of the Operations Department at the time of the i
accident, and while his actions in many cases were known to be wrong, these actions were apparently comon practice among operators at THI-2. .
_ _ _ _ _ . _ __ __. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _