ML20155J641

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Partially Withheld Supplemental Results of Joint Nrr/Ofc of Investigations Evaluation of Mv Cooper Re Leak Rate Testing Irregularities.Cooper Conducted Leak Rate Tests W/O Regard for Test Procedures.Mgt Attitudes Lax
ML20155J641
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 10/15/1985
From: Russell W
Office of Nuclear Reactor Regulation
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML20151L202 List:
References
NUDOCS 8605270137
Download: ML20155J641 (11)


Text

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,8 g NUCLEAR REGULATORY COMMISSION I WASHINGTON D. C. 20555 7

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October 15, 1985

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MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation l

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FROM: William T. Russell, Acting Director  :

Division of Muman Factors Safety

SUBJECT:

SUPPLEMENT TO JOINT OI/NRR INVESTIGATION AND EVALUATION OF MARTIN V. COOPER i

Reference:

1. Memorandum from William T. Russell to Harold R. Denton, dated December 3, 1984,

Subject:

Results of Joint 01/NRR j Investigation and Evaluation of Martin V. Cooper

. 2. Memorandum from William T. Russell to Harold R. Denton, ,

dated May 30, 1985

Subject:

Results of Joint 01/hRR 1 Investigation and Evaluation of Joseph R. Ccngden ,

The purpose of this memorandum is to supplement the results of the joint i OI/NRR investigation and evaluation of Mr. Martin V. Cocper, currently a Senior Reactor Operator (SRO) at San Onofre, Units 2 and 3. The results of the investigation and evaluation were provided to you in Reference 1.

Since Mr. Cooper was the first operator interviewed as part of the joint 01/NRR investigation, Reference 1 discussed the possibility that during the remaining interviews, additional evidence could be developed regarding Mr. Cooper's preaccident activities at THI-2 that were not considered in the report. Subsequent to our September 28, 1984 interview with Mr. Cooper, we have interviewed 14 additional fomer TMI-2 Shift Foreman and Control Room Operators (CR0s) on the subject of preaccident reactor coolant system (RCS) leak rate testing irregularities at TM1-2. Included among these -

individuals was Mr. Cooper's former shiftmate, Mr. Joseph R. Congdon. The j results of Mr. Congdon's investigation and evaluation was provided to you in  ;

Reference 2.

As a result of these interviews, new information about leak rate testing ]

practices and test manipulation was developed. Based upcn this new -

infonnation, NRR revised the technical evaluation of several leak rate tests. f As a result of our revised technical evaluation and Mr. Congdon's testimony,  :

it is necessary to supplement the report on Mr. Cooper (Reference 1) in two l areas.

First, Mr. Cooper admitted adding hydrogen to the make-up tank (MUT) during leak rate tests; however, he denied that it was done with the intent of manipulating the outcome of the tests. According to Mr. Cooper, if hydrogen ,

I pressure was low in the operating band, during periods in which leak race

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surveillance tests were being run, he would add hydregen. If the test results were acceptable, Mr. Cooper would retain the test knowing its results j may have been influenced by the addition of hydrogen.

1 8605270137 860516 PDR ADOCK 05000320 P PDR

Harold R. Denton "E" October 15. 1985

0. Acccrding to the testimony of Mr. Ecngdon on January 29, 1985 Congdon did not censider hydrogen additions during leak rate tests to be a violation of -

l the precedure. Yet, he admitted that he added hydrogen to the MUT during  ;

leak rate tests with the intent of influencing the leak rate test results. .

Mr. Congdon also stated that the other CR0s on his shift, including ,

Mr. Cooper,'were aware that this was being done and that both his Shift .

l Foreman and his Shift Superviser were also aware that hydrogen was being i added during tests for the purpose of manipplating test results. -

i .

In Reference 1. I concluded that Mr. Cooper's "postaccident rationalization,"

that he did not intentionally manipulate leak rate test results by the addition of hydrogen did not appear credible. Mr. Congdon's testimony supports this conclusion.

Second, I also concluded in Reference 1, that Mr. Cooper may also have  ;

manipulated test results by the addition of water to the MUT during leak rate -

tests by not logging the additions in the Control Room Log and not including 4

the amount of water added in the leak rate test calculation. That conclusion .

t was based principally on the results of the technical evaluation which showed Or. accounted for water additions may have occurred in 12 leak rate tests .

invciving Mr. Cooper. Based upon the reevaluation of those tests, the j evidence is not as convincing.  !

Enclosure 1 provides a sunmary of the MRR evaluation of leak rate tests i l performed by Mr. Cooper during the period September 30, 1978 through Marca 28, 1979. The results show that unrecorded water additions may have occurred in only five of these tests; however, many other actions occurred which impact the validity of 21 out of the 30 tests involving Mr. Cooper

( 70".) . These include: accepting tests that were conducted during feed and bleed cperations or contained water additions.that were not properly -

l acccunted for in the leak rate test calculation; conducting tests with '

unreliable or inaccurate MUT level indication as input to the plant computer; 4

running tests during unstable plant conditions; as well as accepting tests that were conducted while hydrogen was added to the MUT. While most of these  :

action rendered the tests invalid, they did not always produce leak rate '

tests results that were lower than otherwise would have been the case had ,

these actions not been performed.

l Both Mr. Cooper and Mr. Congdon deny that they intentionally added water to manipulate the outcome of leak rate test results. Nevertheless, both

. admitted (1) they ran the test at least one or more times per shift and (2) they had little confidence that the test provided a meaningful measure of actual plant leakage. Based upon their testimony and the testimcny of other .

, . operators on other shifts, coupled with the technical evaluation, it appears ,

that leak rate tests were often conducted in a frivolous manner, such that ,

tests results were accepted as valid as long as the results were less that <

the technical specification limit regardless of the evolutions in progress during the test. Because the test was treated as an " administrative .

requiremento that had to be satisfied every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, little review, if any, was done by CR0's performing the test or the Shift Foreman approving the test.

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Harold R. Denton October 15, 1985 In summary, my original conclusion that Mr. Cooper was involved in leak rate test manipulation by the use of hydrogen additions is supported by the testimony of Mr. Congdon; however, my conclusion that Mr. Cooper knowingly manipulated test results by unaccounted for water additions may not be valid.

Rather than intentiona) test manipulation, it appears 'that Mr. Cooper and

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others co5 ducted leak rate tests wi.thout regard for -the precautions and Ifeitations specified in the test procedure. If test results exceeded the limits of the technical spacifications, they were discarded. If tests results were below the acceptance criteria, they would be kopt with little er .

ne review to assure they were valid tests.

From the testinony of the majority of other CR0s and Shift Foremen -

interviewed, it is clear that management's standards for procedural compliance were 1Ax and permissive. In my opinioc, this was created through negMgence on the part of management. Lack of operator respect for the leak rate test procedure itself, coupled with management's failure to correct leak rate test procedure problems and instill high standards for procedural

complianck lad to conditions where the leak rate test was conducted in a frivolous manner without establis.hing the proper steady-state conditions for the test. In stre casts management s attitude toward this testing motivated operators to manipulate or falsify leak rate test results. '

J O  :

Enclosure 2 provides a comparison of the results cf the original leak rate test evaluation, used as a basis for my conclusions in Reference 1 with the the results of the July 30, 1985 NRR final evaluation. Enclosure 3 is a copy of the tiRR evaluation.

I 4Wu T- /= ""

Willt.tm T. Russell, Acting Directoe  ;

i Divtsion of Human Factors Safety, NPR j Enclesures:

As stated cc: B. Hayec K. Chr1stopher

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i Enclosure 1 TECHNICAL EVALUATION OF LEAX RATE TESTS PERFORMED DY M. V. COOPER e

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In 1983 and early 1984, a technical analysis of the leak rate surveillance tests conducted curing the last six months of operation of TMI-2 was perfomed by the NRC. This analysis was done as technical support to the 4

Department of Justice (DOJ) in its criminal proceeding against Met-Ed.

c' During Mr. Cooper's September 28, 1984 interview, he was questioned on the results of this early evaluation. . In 1985, NRR perfomed a reevaluation of i

that analysis by factoring in additional plant data and information that was learned during inte. views with former TMI-2 operators, including Mr. Cooper's i thiftmate Mr. Joseph R. Congdon. A discussion of results of this revised evaluatien, as it relates to Mr. Cooper, is presented below.

1 GENERAL 4

In order to demenstrate that reactor coolant system (RCS) leakage did not .
exceed the limiting conditions for operation. TMI-2 Technical Specification 3/4.4.6.2, "Reacto~r Coolant System Operational Leakage," directed that a RCS water inventcry balance (leak rate test) be performed at least once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during steady-state operation, while in Modes 1 through 4.

. THI-2 Surveillance Procedure-2301-3DI, "RC System Inventory," was the

! approved procedure governing the conduct of leak rate tests. The procedure cautioned the operator to avoid the addition and removal of water from the RC and make-up systems during the test including make.-up or chemical addition to the make-up system or boration/deboration. In addition, the operator was cautioned to maintain the RC and make-up systems in a steady-state condition

! during the test by avoiding changes in valve line-ups, coolers-in-service, j p:mps-in-seryt:e, etc. The procedure also cautioned that power level changes were to be minimized and for the most accurate detemination of RCS leak rate, the initial and final conditions of reactor power, RCS temperature.

l pressure and pressurizer level should be identical. '

The vast majority of leak rate tests performed at TMI-2 were done by using the plant computer. The computer-generated leak rate surveillance test sheet would be signed by the control room operator (CRO) performing the test and approved by a Senior Reactor Operator (SRO). In most cases, the Shift l Foreman approved the tests run on his shift. The test records show that of

, the 151 leak. rate surveillance tests retained by the licensee during the period under investigation, Mr. Cooper was involved in 30 leak rate l surveillance tests. During these tests, Mr. Cooper was either the operator

performing the test or the operator assigned to the control panel. The table below shows a breakdown of NRR's overall conclusions regarding these tests.

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Breakdown of Leak Rate Tests Involving M. V. Cooper Evaluation Category Number of Tests ~

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Total number of tests on fi1e..................................... 30 l Tests wi th no a ppa rent probl ems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Unstable or out-of-service makeup tank (MUT) level transmitter..... 7 Water additions to MUT (not included in the calculation)........... 5 Feed and bleed operations (not included in the calculation)........ 4 Hydrogen addi ti ons to the' MUT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Water or hydrogen addition (unable to differentiate)............... 3 Unidentified leakage greater than the TS limit of 1 gpm............ 3 Unstable plant conditions.......................................... 1 Note: As will be discussed below, three tests (#12E, #29, and #43) fall into two evaluation categories and one test (#36) falls into three evaluation categories.

l As can be seen from the table above, only nine of the 30 tests involving Mr. Cooper appear to have been conducted in accordance with the requirements 4

and precautions of the surveillance procedure governing the conduct of leak

, rate tests (SP 2301-3D1). The 21 remaining tests involve either actions that violate the limits and precautions of the procedure or were performed with unreliable or inaccurate data being supplied to the plant computer, thus, l 4

yielding questionable or invalid results. The basis for the evaluation of '

each test is presented below. l i .

NORMAL TESTS j

The nine tests that appear to have been conducted in accordance with the surveillance procedure and yielded test results less than the technical specification limit of 1 gpm for unidentified leakage are tests:

  1. 2 (09/30/78), #5 (10/02/78), #8 (10/05/78), #15 (10/19/78), #26 (10/27/78),
  1. 42 (12/01/78), #49 (12/06/78), #55 (12/11/78), and #95 (01/15/79).

UNIDENTIFIED LEAKAGE GREATER THAN 1 GPM -

During a routine inspection of TMI-2 operations on October 18, 1978, an NRC inspector discovered several unsigned and unapproved leak rate tests lying in

! the control room. These tests indicated unidentified leakage in excess of l the technical specification limit of 1 gpm. The inspector also determined l

-that TMI-2 had been operating for an extended period of time without entering  :

0 the action statement of the technical specifications. The incident resulted in the submittal of Licensee Event Report (LER) 78-62/1T on, November 1, 1978.

_ __ _.-__..______,.____m_ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _

Ci Mr. Cooper's shift (Shift "C") was on watch during the day shift (from 0700 to 15001 on October 18, 1978. Mr. Cooper was assigned as the panel operator l

and his shiftmate, Mr. Congdon, was assigned surveillance duties. During their watch, four leak rate tests were conducted. The results of three of the tests-(#12E, #120, and #13) indicated unidentified leakage in excess of

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l the technical specification limit. l l

All three tests were later rounded off to 1.0 gpm by the Supervisor of  !

Operations (Mr. Jim Floyd). Tests 12E and 12D were not signed by the l operator performing the test or approved by the Shift Foreman (Mr. Chuck l Adams). Test #13 was signed by the Shift Foreman, as the operator performing l the test, and approved by the Shift Supervisor (Mr. Brian Mehler). During Mr. Cooper's September 28, 1984 01/NRR interview, he stated that the CR0s were not aware of an " authorized round-off policy," and refused to sign leak i rate tests indicating leakage in excess of the technical specifications.

1 UNSTABLE PLANT CONDITIONS l

. 1 As stated above, the procedure cautioned the operator to maintain the reactor coolant and mak'e-up systems in a steady-state condition during the test by avoiding equipment line-up changes. In order to determine RCS leakage accurately, the initial and final conditions of reactor power, RCS temperature, pressure and pressurizer level should be identical. Contrary to O the procedure, test #29 (10/29/78) was conducted during a shutdown, while the the plant was not in a steady-state condition. During the tes.t. pressurizer level increased 8.8", Tave increased 1.4'F and make-up tank level varied 26". The large change in MUT level is believed to be caused by a large feed ,

and bleed operation during the test period. '

l INSTRUMENTATION PROBLEMS At TMI-2 there are two level transmitters (LT-1 and LT-2) that provide MUT level indicaticn. The output of one of the level transmitters drives the MUT level strip chart recorder in the control room while the other level transmitter provides MUT level indication to the plant computer. A selector switch in the control room allows the operator to switch level transmitters feeding the strip chart recorder and the plant computer. When the selecter .,

switch is. positioned to LT-1, the strip chart recorder would be driven by the )

output of LT-1 and LT-2 would provide automatic input to the plant computer for leak rate test calculations. When the selector switch was changed to LT-2, the opposite would occur.

Between October 30 and November 6, 1978, operators experienced problems with both level. transmitters. At various . times during this period, the level transmitters were reading radically different levels in the MUT and both were taken out-of-service for maintenance work and recalibration. During this O time period, Mr. Cooper was the panel operator during two tests completed on the same shift (mid-shift 2300 to 0700). Test #36 was completed at 2315 on 11/05/78 and test #37 was completed at 0304 on 11/06/78., During these tests.

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. C l the LT providing input to the plant computer was reading approximately 15" lower than the LT driving the strip chart recorder in the control room. The LTs weri switched between LT-1 and LT-2 several times during the watch, indicating the operators were aware of the instrumentation problems at the time. As.will be discussed below, test #36 also contains a hydrogen addition -

and possible water addition to the MUT during the test period.

Beginning in early December,1978, and continuing through January 11, 1979, the output.of LT-1 became very erratic and unreliable. Because of the erratic nature of the output of LT-1 during this period, any leak rate test's

, performed with the use of LT-1 providing input to the computer must be considered questionable or invalid. Of the 50 tests conducted by all shifts during this period, only 16 were performed with the stable level transmitter (LT-2) providing input to the computer during the test. During this period, Mr. Cooper was involved in eight tests. Three were run using stable LT-2 providing input te the computer and five were run with the unstable level transmitter. The tests run with LT-2 are: #49 (12/06/78), #55.(12/11/78),

and #62 (12/15/78). The tests run with the unstable LT-1 are: #43

, (12/02/78), #44 (12/02/78), #48 (12/05/78), #51 (12/08/78), and #59 j (12/12/78).

For tests #43, #44, and #51, there do not appea'r to be large differences between LT-1 and LT-2 for the initial and final values of MUT level and; therefore, the use of LT-1 may not have produced a significant error in the leak rate calculation. For test #48, the use of LT-1 provided the computer

! with a change in MUT level of approximately -3.0" instead of an actual value i of approximately -2.0" as shown by LT-2. In this case, using LT-1 may have led to a higher value of calculated leakage than would have been the case with stable LT-2. In test #59 the opposite occurred, LT-1 provided the computer with a change in MUT level of +0.28", and did not reflect the actual drop in MUT level of approxima.tely -1.0".

Thus, during the entire period of time LT-1 was essentially "out-of-comission," all shifts, including Mr. Cooper's, continued to run leak rate tests (34 out of 50) with LT-1 providing MUT level indication to the computer. In most cases, this action resulted in a meaningless calculation of unidentified leakage that could not demonstrate conformance with the  !

technical specification limit of I gpm.

FEED AND BLEED OPERATIONS 1

Four tests contain possible feed and bleed operations that were not taken into account in the leak rate test calculation. These tests are:

  1. 6 (10/04/78),12E (10/18/78), #29 (10/29/78), and #43 (12/02/78).

During test #6, a feed and bleed operation' of approximately 160 gallons was performed during'the test. Since the amount feed appears to be equal to the amount bled and the entire operation was completed during the test, the overall effect on test results appears negligible. .

Test #12E contains a possible feed and bleed operation approximately 20 minutes befor.e the end of the test. In this case, the amount feed appears to

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O be approximately 40 gallons more than was bled from the system.

discussed above, results of this test exceeded the technical specification As i limit for_ unidentified leakage (1.32 gpm).

! Test #29 contains a large feed and bleed operation of approximately 800.

gallons that is not included in the leak rate calculation. This test was 1

also conducted during a period of unstable plant conditions causing large oscillations in MUT and pressurizer levels.

l Test #43 contains a feed and bleed operation of approximately 200 gallons during the middle of the test. Approximately 40 more gallons was bled from the system than was added during the test. Because this test was also run using the unstable level transmitter LT-1 providing input to the computer, the net effect on leak rate test results is uncertain.

HYDROGEN ADDITIONS In order to limit the oxygen content in the RCS and to provide an increased net positive suction tead for the RCS makeup pumps, a hydrogen overpressure was maintained in the MUT. When hydrogen pressure decreased near the low end of the operating band, the CR0 would add hydrogen to the tank.

Theoretically, the addition of hydrogen should not have affected MUT level; i however, because of the configuration and environment of the MUT level detection instrumentation system at TMI-2, water could collect in the low-pressure (dry) reference leg of the level transmitters. Under these conditions, the resultant water slug or " loop seal" could cause a temporary

increase in the indicated MUT level when hydrogen pressure was increased in the MUT. Thus, the addition of hydrogen at the appropriate time (after the computer collected its initial data and shortly before the final data -

readings were taken) could affect the leak rate results in a nonconservative manner (i.e., the calculated leak rate would be less.than the actual leak

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rate).

Three tests involving Mr. Cooper include logged hydrogen additions. These are tests: #36 (11/05/78), #39 (11/09/78), and #120 (02/15/79).

Tests #36 was started on Shift "D" and ccmpleted by Shift "C." In addition to the logged hydrogen addition approximately 15 minutes into the test, which produced a small effect, the test was started during a 500 gallon water i addition. Approximately 150 gallons were added during the test. As

discussed above, this test was also run while operators were experiencing obvious MUT level instrumentation problems. The difference in readings between LT-1 and LT-2 is approximately 15". Both the water addition and
hydrogen additions were done prior to Mr. Cooper's shift relieving Shift "D."

1 Test #39 contains a hydrogen addition at the beginning of the test; however, because of the time of the addition, the small effect produced appears to be insignificant with respect to the final value of the calculated leak rate.

According to the testimony of Mr. Congdon, test #120 involved an experimental addition of hydrogen to determine the its effect on MUT level and leak rate

. l test results. The Shift Foreman (Mr. Chuck Adams) participated in the

. experiment. The test was conducted by Mr. Cooper. According to the Control Room Log, hydrogen was added 26 minutes before the end of the test; producing approximately a +2.0" rise in MUT level. At the time of the hydrogen '

addition,-the Shift Foreman wrote: " Pressurized MUT" on the MUT level strip chart recorder..

WATER OR HYDROGEN ADDITIONS In addition to the three logged hydrogen additions, three other tests contain possible hydrogen or water additions. These are tests: #62 (12/15/78), #126 (02/19/79) and #130 (02/26/79).

Test #62 was conducted during the period LT-1 was unstable. The test used stable LT-2 as input to the computer, thus, during the test, the strip chart recorder shows the output of LT-1. Before and during the test, LT-1 shows regular peak to peak oscillations of approximately e 12". There is a large break in the regular pattern approximately halfway through the test. It is

. not possible to determine if this break was caused by plant oscillations, instrumentation fluctuations or a possible water or hydrogen addition during the test. The Control Room Log does not contain any entries regarding plant evolutions during the test period.

Approximately 17 minutes after the start of test #126, MUT level increases approximately +2.0" (60 gallons) and remains offset throughout the test period. Again, no logged additions of water or hydrogen are recorded in the Control Room Log. Changes in Tave and pressurizer level do not appear to account for this difference.

Before and after test #130 the slope of MUT level trace is -7.0"/ hour.

Shortly after the start of the test, the slope shifts to -4.0"/ hour. The Control Room Log does not record plant evolutions which explain the change. .

The change in slope is not consistent with changes in pressurizer level or Tave.

UNRECORDED WATER. ADDITIONS There are five tests which contain possible water additions that are neither recorded in the Control Room Log nor included in the leak rate test calculation. These tests are: #14(10/18/78),#18(10/21/78),#24 (10/26/78), #36 (11/05/78), and #135 (03/02/79).

There are no water additions apparent on the MUT strip chart for Test #14; however, due to changes in pressurizer level and Tave during the test, it appears that approximately 100 gallons of water may have been added during the test. Gross leakage before and after the test is approximately 1.5 gpm.

During the test, gross leakage drops to approximately 1.22 gpm. No water O' additions are included in the Control Room Log or included in the test calculation.

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O There are large changes in MUT level and pressurizer level during Test #18.

Nineteen minutes into the test (1258), there appears to be a 50 gallon water addition to the MUT. The trace is similar to small (50 to 100 gallons) -

legged add.itions of boric acid at 0700, 0730, 0830, 1125, and 1209.

During Test #24, the MUT strip chart shows a possible water addition six minutes after the start of the test (2013). The trace is similar to small (25 gallon)loggedadditionsofboricacidat 1800, 1830, and 2116.

As discussed earlier in this evaluation, Test #36 appears to have been started prior to the completion of a 500 gallon water addition.

Approximately 150 gallons of water was added during the test period. This test also contains a logged hydrogen addition and obvious MUT level indication problems.

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The MUT level trace during test #135 exhibits unusual characteristics.

Before and after the test, the MUT level slope is approximately -6.0"/ hour.

Shortly after the start of the test, the slope changes to +4.O k/ hour for the first half of the test and then returns to the original slope. Based upon changes in pressurizer level and Tave, it appears that approxiestely 30 to 60 gallons of water may have been added during the test.

SUMMRY The technical evaluation shows that between September 30, 1978 and March 28 .

1979, 21 of the 30 tests (70%) involving Mr. Cooper appear to contain actions that were contrary to the requirements of TMI-2 Technical Specification 3/4.4.6.2 and the precautions, limitations and requirements of Surveillance P.acedure 2301-3DI. These actions included: Ignoring test results greater than the technical specification limit; accepting tests that were conducted

during feed and bleed operations or contained water additions that were not

, properly accounted for in the leak rate test calculation; conducting tests

! that used unreliable or inaccurate MUT level indication as input to the plant computer; ccnducting tests during unstable plant conditions; and accepting tests that were conducted while hydrogen was added to the MUT.

Mr. Cooper and Mr. Congdon have both admitted that they signed and submitted leak rate tests, knowing that the results of thue tests may have been favorably influenced by hydrogen additions during the tests. However, both 1 individuals deny that they used any other method, including unaccounted for l water additions, to manipulate the outcome of leak rate test results. From i l the technical evaluation, it is not possible to prove that these other l actions were done with the intent of wrongfully influencing the outcome of 4 tests. There is no clear pattern of test manipulation and in some cases, while the actions challenge the validity of the test, they did not always produce leak rate test results that were lower than would otherwise have been the case. It does appear clear; however, based upon the high number of questionable or invalid tests, that Mr. Cooper accepted test results as valid as lon as the results were less than the technical. specification limit, regard ess of the evolutions in progress during the tests. ,

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,. Enclosure 2 l l

. COMPARISON OF TEST EVALUATION DIFFERENCES FOR M. V. COOPER Overall Evaluation Original Final Number of Tests included in evaluation. . . . . . . . . . . . . . . . . . . . . . . . . 29 30 N o ma l Te s t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 9 Questionable Tests.......................................'...... 16 21 .

Evaluation Category 0f Questionable Tests Code Unstable or Unreliable MUT LT used as input to computer.. LT 0 7 Water addition not included in calculation............... WAN 12 5 Feed and Bleed operation not included in calculation..... F&B 1 4 Water or hydrogen addition (unable to differentiate)..... WorH O' 3 Hydrogen additions to MUT................................ H 4 3 Unidentified leakage greater than TS limit of 1 gpm...... 1GPM 1 3

Unstabl e pl ant condi ti ons. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . USPC 2 1
  • Note: Original evaluation includes four tests in 2 categories and the Tinal evaluation includes 3 tests in 2 categories & 1 test in 3 categories.

Individual Breakdown of Tests By Evaluation Category

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Test Number Date ' Original Evaluation -Final Evaluation 2 097JU778 Nomal Test Normal Test 5 10/02/78 Nomal Test Nomal Test 6 10/04/78 Nomal Test F&B 8 10/05/78 Nomal Test Normal Test 12D 10/18/78 Not Included IGPM 12E 10/18/78 Not Included 1GPM/Possible F&B 13 10/18/78 1GPM/WAN . 1GPM 14 10/18/78 WAN Possible WAN 15 10/19/78 Nomal Test Nomal Test 18 10/21/78 WAN WAN 24 10/26/78 WAN Possible WAN 26 10/27/78 Nomal Test Nomal Test 29 10/29/78 USPC/WAN USPC/F&B 36 11/05/78 WAN/H WAN/H/LT 37 11/06/78 Normal Test LT 39 11/09/78 H H 42 12/01/78 USPC Nomal Test 43 12/02/78 F&B/H F&B/LT 44 12/02/78 Nomal Test LT 48 12/05/78 Normal Test LT 49 12/06/78 WAN Nomal Test 51 12/08/78 Nomal Test LT ,

55 12/11/78 Normal Test Nomal Test  !

59 12/12/78 WAN LT 62 12/15/78 WAN Possible WorH 95 01/15/79 WAN Nomal Test 120 02/15/79 H H 126_ 02/19/79 Normal Test WorH 130 02/26/79 WAN WorH O 135 154 03/02/79 03/24/79 WAN Normal Test Possible WAN Not Included Note: Original evaluation refe'rs to 1983/1984 NRC evaluation of leak rate testsCooper.

Mr. used in December Final evalua 3, tion refers to 1985 NRR Evaluation dated 1984 joint OI/NRR investigatio 07/30/85.

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