ML20155J649
| ML20155J649 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 05/30/1985 |
| From: | Russell W Office of Nuclear Reactor Regulation |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20151L202 | List: |
| References | |
| NUDOCS 8605270143 | |
| Download: ML20155J649 (16) | |
Text
-_ - - - - - - - -_ _ _ _ _ _ _ - - -
Enclosure 6
/ 'o
~,, UNITED STATES
! n NUCLEAR REGULATORY COMMISSION '
,E wAsHWOTON, D. C. 20665 May 30,1985
...../ . ,
~
r MEMORANDUit-FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation __
FROM: . William T. Russell, Acting Director Division of Human Factors Safety, NRR
SUBJECT:
RESULTS OF JOINT 01/NRR INVESTIGATION AND EVALUATION OF CRAIG C. FAUST
Reference:
- 1. Memorandum from S. J. Chilk (SECY) to B. R. 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) l dated May 3, 1984, Subject NRR Review of OI Investi-gation Materials Concerning Hartman Allegations of Falsification of Leak Rate Data at TMI, Unit 2 1
- 3. Memorandum from W. T. Russell (DHFS) to H. R. Denton i (hRR) dated January 24, 1985,
Subject:
Follow-up Action on Additional TMI-2 Operators The purpose of this memorandum is to document the results of the joint 01/NRR l investigation and evaluation of Mr. Craig C. Faust, currently a Senior !
Reactor Operator (SRO) at Three Mile Island, Unit 2 assigned to the Training )
Department, and to provide a recomendation regarding whether his current SRO license should be revoked, modified, or suspended under 10 CFR 55.40 or other I enforcement action taken under 10 CFR Part 55.50, due to his involvement in )
preaccident leak rate testing irregularities at TMI-2.
Background
As a result of a Comission meeting on March 23, 1984, NRR was directed by Reference 1 to review OI investigative materials concerning falsification of ,
reactor coolant system (RCS) leak rate tests at TMI-2 and refer back to OI those matters which required further investigation. The results of NRR's NOTE: This memorandum and Enclosure 1 discusses information which is the subject of an ongoing OI investigation. This memorandum and Enclosure 2 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 coordi-O nation with NRR and the permission of the EDO or the Director, 01.
Internal access and distribution should be on a "need to know" basis.
8605270143 860516 PDR ADOCK 05000320
)bl$. P PDR
l l
Harold R. Denton May 30,1985
- review wat 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 currently licensed operators. C. G. Faust was one of these seven -
individuals. At a follow-up Commission meeting on May 23, 1984 NRR pro-posed joint 01/NRR investigations and evaluations of these individuals. ~
Subsequently, NRR issued letters to these individuals under 10 CFR 55.10(b) requesting additional information regarding current performance. Based upon the joint investigation into the individuals' past involvement in improper activities at TMI-2 and an evaluation-on the individuals' subsequent per-formance, NRR would recommend what action, if any, should be taken against the identified operators. As a result of some of the early interviews with these individuals and further technical analysis, Reference 3 recommended that three additional currently licensed operators also be interviewed. NRR issued similar letters to these individuals under 10 CFR 55.10(b). Of the ten individuals identified for investigation, seven are currently licensed j at Three Mile Island, Unit 2, two are licensed at Waterford 3 and one is ,,
licensed at San Onofre 2 and 3. .
Past Involvement in THI-2 Leak Rate Testing Irregularities On January 30, 1985, a joint OI/NRR interview of Mr. Craig C. Faust was held O in Harrisburg, Pennsylvania. The interview was conducted in the presence of Mr. Faust's personal attorney. The purpose of the interview was to deter-mine Mr. Faust's role, if any, in improper activities associated with Reactor Coolant System (RCS) leak rate surveillance testing at TMI-2 prior to the accident on March 28, 1979. At the time, Mr. Faust was a licensed Reactor Operator (RO) and served as a Control Room Operator (CRO)'on Shift "A." A detailed evaluation of Mr. Faust's interview is included as Enclosure i to
~
this memorandum.
'The majority of Mr. Faust's responses to questions associated with leak rate surveillance test performance at THI-2 were consistent with statements made to the NRC by other former operatcrs. However, Mr. Faust denied that he personally attempted to influence or manipulate the outcome of leak rate '
test results by the addition of water and/or hydrogen to the make-up tank (MUT) during the tests. Mr. Faust's testimony appears to be consistent with the technical analysis of leak rate tests in which he was involved. :
i Mr. Faust also denied that he had personal knowledge of cr was aware of other !
,. operators intentionally manipulating leak rate surveillance tests. During the interview, Mr. Faust relayed the following information:
- 1. Leak rate tests were routinely run once per shift, plant conditions l
- permitting. 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). There were periods of time when 4e was not able to get a satisfactory leak rate test result by the end of his shift.
- 2. Only satisfactory leak rate test results were retained. All bad leak rate tests were thrown away. In most cases, Mr. Faust was able to justify why the tests were " invalid." When he was not able to justify
I Harold R. Denton , tiay 30,1985 why ar particular test was invalid, he would give the te'st to his Shift Foreman. 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, i
- 3. Mr. Faust did not log satisfactory or unsatisfactory leak rate tests in the CRO's Log. He considered them to be routine in nature and did not normally log items of a routine nature. Note: This action was contrary to TMI Administrative Procedure 1012. "Sh W Relief and Log Entries,"
which required the test title, number of the test, and the start and completion tirnes of all surveillance tests be logged in the CR0's Log.
- 4. Mr. Faust'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 were aware that invalid test results were being thrown away.
- 5. Contrary to the commitment contained in the narrative of LER 78-62/1T, Faust does not recall being given guidance or instruction regarding the proper interpretation of Technical Specification 3.4.6.2, " Reactor O Coolant System Operational Leakage." Following this incident, Mr. Faust was not instructed to invoke the Action Statement of the TS when a leak rate test result exceeded the TS Limits for unidentified leakage. Note: l These actions are contrary to TMI-2 TS 3.4.6.2 and the licensee's stated corrective action in LER 78-62/1T of November 1, 1978.
- 6. Although Mr. Faust could recall one discussion with other operators.
regarding the possible influence of hydrogen additions on leak rate ;
tests, Mr. Faust was not aware whether hydrogen could influence the !
outcome of the test. He did not. personally add hydrogen to affect leak l rate test results. He was not aware of other operators adding hydrogen l for that purpose.
- 7. Mr. Faust was aware of methods that could be used by operators to affect the cutcome of a leak rate test by either water additions that were not included in the calculations or by the switching of level transmitters i for make-up tank (MUT) level indication during the performance of leak rate test. He stated he did not personally use either of these or any other methods to affect the outcome of leak rate tests. -
In summary, Mr. Faust appeared to answer all questions in a straightforward and honest manner and while some of his actions regarding the conduct of leak rate surveillance testing were contrary to.the TMI-2 written procedures and Technical Specifications, the technical analysis of leak rate surveillance tests supports a finding that Mr. Faust did not intentionally perform evolutions that would improperly influence the outcome of leak rate tests.
Harold R. Denton May 30,1985 a- l Current 'Peformance ,
l i
l l
l 1
i O
Conclusions During the period Mr. Faust was licensed as a Control Room Operator at TMI-2 prior to the accident, he admitted he was involved in some activities associated with leak rate testing which were contrary to plant procedures and app:Oved Technical Specifications. However, he denies that he was involved ;
in other actions including leak rate test manipulation or falsification or i knowledge that such actions were going on around him. The technical eval- I uation of leak rate tests involving Mr. Faust tends to support his statements that he was not personally involved in leak rate falsifications. Based upon the consistency of his testimony with subsequent technical analysis and plant records, his statements concerning lack of knowledge of other operators actions ttr influence leak rate testing is credible.
~
. . - . - - , , . , ,-.-..,..,e-.-n.. .,- , - , - - - _ , , . . , , . _ _ , _ _ , , _ , , , , ._,{,.N.,,,,n ,r_
._,__a,v. ,,,e-ma-.a.,.n_,,.,'i.,_, ,
l Harold R. Denton 'Mai 30,1985 i i .
i l
1 I
! l
! I
- h. T; Williaml. Russell,ActingDirector !
Division of Human Factors Safety l
- Office of Nuclear Reactor Regulation l
Enclosures:
- As stated
! cc: B. Hayes K. Christopher I
I l
~
u l 1 .
l l
t
I 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 Director, 01. Internal access and distribution should be.on a "need to know" basis.
l Enclosure 1 - - l PAST INVOLVEMENT IN TMI-2 LEAX RATE TESTING IRREGULARITIES
- 1. Background On January 30, 1985, a joint Office of Investigations (OI)/ Office of Nuclear Reactor Regulation (NRR) interview of Craig C. Faust was held in the law '
office of Killian & Gephart, Harrisburg, Pennsylvania. The purpose of the interview was to determine Mr. Faust's role, if any, 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: R. Keith Christopher, Director Office of Investigations Region I; William T.
Russell, Deputy Director, Division of Human Factors Safety; and Robert Capra,
, Senior Program Manager, Staff of the Executive Director for Operations.
Representing Mr. Faust at the interview was his personal attorney, Mr. Harry H. Voight of the law firm LeBoeuf. Lamb, Leiby and MacRae, Washington, D.C.
A copy of the transcript associated with this interview is provided as O Attachment 1 to this enclosure. '
Mr. Faust is currently employed by General Public Utilities Nuclear (GPUN) as a Senior Reactor Operator (SRO) assigned to the Training Department and currently holds the position of Instructor IV at TMI-2. Prior to his current employment, Mr. Faust served seven years in the U.S. Navy's Nuclear Power _
Program. Mr. Faust was hired by Metropolitan Edison Company (Met-Ed) upon leaving the Navy in December 1973. For the next three years, Mr. Faust served as an Auxiliary Operator (AO) both at TMI-1 and TMI-2. In 1976, he became a CR0 in training at THI-2 and eventually received his Reactor i
Operator's (RO) License in October 1977. From this period until he transferred to the Training Department in March 1983, he served as a CR0 at TMI-2. He received his Senior Reactor Operator's License in October 1983.
The interview with Mr. Faust concentrated on the period September 30, 1978 through March 28, 1979. During this time period, he served as a Control Room i Operator at THI-2 assigned to Shift "A." At that time, Shift "A" consisted i of the following licensed individuals:
SHIFT "A"
, Shift Supervisor: Bill Zewe Shift Foreman: Fred Scheimann
- ~ CRO: Craig Faust CRO: Ed Frederick l A sumary of the technical analysis of leak rate tests involving Mr. Faust is provided in Section II of this enclosure. A summary of the interview with !
Mr. Faust is contained in Section III of this enclosure. The summary of I l
l 1
. - . , _ , , - - . . , - , . - ~ , - . - - .,- , - - - - , - - - - - - , - - . , , , , - - - - - - - , - - - - - ,- ,,nnr-,- --- - - , - - - - - - - - , - - - - - - - - - - - - - - - - - - - - < - - - '
i' 1
1 interview -in Section III includes citations to the page numbers of the -
transcript from which the sumarized information was extracted. Overall conclusions regarding Mr. Faust's involvement in improper activities -
associated with THI-2 leak rate surveillance testing are contained in Section IV of this enclosure.
II. Sumary of the Technical Analysis i
In late 1983 and early 1984, a technical analysis of the leak rate surveillance tests performed during the last six months of operation of TMI-2 )
, was performed by the NRC. This analysis was done as technical support to the !
Department of Justice (DOJ) in its criminal proceeding against Met-Ed. The !
results of this analysis were used in questioning Mr. Faust during his interview. However, based upon information obtained during the 13 interviews of former CRO's conducted to date, a reanalysis was performed during February and March 1985. The sumary of technical analysis provided in this section l
relies on the updated 1985 analysis. The major differences between the two analyses, with respect to Mr. Faust will be explained at the end of this
- section. While the complete 1985 evaluation of leak rate tests at TMI-2 is provided as Attachment 2 to this enclosure, a sumary of the conclusions of
- the technical analysis regarding tests involving Mr. Faust is provided below to help the reader understand the basis for the questions posed to him during the interview. -
I The test records show that of the 161 leak rate surveillance tests retained
, by the licensee during the period under investigation, Mr. Faust was involved in 20 of the tests. During the 20 tests, he was either the individual who
- performed the surveillance test or was the operator on watch (i.e., the panel
{ operator) who signed the CRO's Log for the period during which the test was i
conducted. The table below shows a breakdown of the overall conclusions .
regarding Mr. Faust's tests.
Breakdown of Leak Rate Tests Involving C. C. Faust Total number of tests on fi1e............................. 20 Tests with no apparent problem............................ 12 .
Tests involving unstable plant conditions.................. 1 Tests involving use of an unstable make-up tank level transmitter as input to the computer.............. 4 Water additions (not included in the calculation)......... 1 Water additions (partially included in the calculation)... 1 Tests indicating unidentified leakage greater than the 1 gpm Technical Specification limit............ 1 Tests involving hydrogen additions......................... O i
As can b'e seen from the above table, 12 of the 20 tests involving Mr. Faust 2
appear to have been conducted in accordance with the requirements and i precautions of the surveillance procedure governing the conduct of leak rate j tests (SP 2301-3D1). The remairiing 8 tests, while yielding questionable or perhaps invalid results, do not indicate a pattern of leak rate test manipulation. The basis for this conclusion in presented below.
I
}-
~ - _ - . - _ - - . . - _ _ - - . - ._ - - . . - . _ . - . - . - . - . . - - - . - . , - . .
One test, 10 (10/14/78) was performed when the plant was not in a steady state condition. SP 2301-3D1 directs that the test be performed once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during steady state operation. The procedure also cautions the -
operator to maintain the RCS and make-up system in a steady state condition during the test by avoiding changes in valve line-ups, coolers-in-service, pumps-in-service, etc. Power level changes should be minimized and the operator should avoid additions or removal of water from the RCS and make-up system during the test. For the most accurate determination of the RCS leak rate, the initial and final conditions of reactor power, RCS temperature, pressure and pressurizer level should be identical. Test #10 was performed during the middle of a reactor start-up following a reactor trip when the plant was not in a steady state condition. One test, #12A (10/16/78),
performed while Mr. Faust was on watch as the panel operator, was an unsigned, unapproved test indicating unidentified leakage of 2.56 gpm which is in excess of the 1.0 gpm Technicai Specification limit for unidentified leakage. No water or hydrogen additions were made during this test that would influence the outcome of the test. This test was not' filed with the other surveillance tests maintained by the licensee. Instead, this test was filed with a set of tests that lead up to the submission of LER 78-62/1T on November 1, 1978. The significance of this particular LER is discussed during the interview with Mr. Faust (S_ee. Transcript pages 29-35).
O During the months of December 1978 and January 1979, one of the two level transmitters that provide make-up tank (MUT) level indication had a very erratic and unreliable output. The output of one of the level transmitters would drive the MUT strip chart recorder in the control room while the other level transmi.tter would provide MUT level indication to the plant computer.
The plant computer was used to run RCS leak rate surveillance test's at TMI-2.
A selector switch in the control room allowed the operator to switch level transmitters feeding the strip chart recorder and plant computer. When the selector switch was selected to LT-1, the strip chart recorder would be driven by LT-1 and LT-2 would provide input to the plant computer. When the selector switch was changed to LT-2, the strip chart recorder would be driven by LT-2 and the computer would receive its MUT level indication from LT-1.
Because of the erratic nature of the output of LT-1 during this period, any leak rate test that was performing with the use of LT-1 providing input to the computer must be considered questionable. Of the 54 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. Faust was involved in 5 tests, 4 of which used unstable LT-1 as input to the computer. These tests are: #74 (12/24/78), #83 (01/02/79),
- 84 (01/04/79) and #85 (01/05/79). Test #74 does not appear to have been affei:ted to a significant degree by the use of LT-1; however, the other three tests do show significant differences between the output of LT-1 and LT-2.
Because of the erratic nature of LT-1, the use of LT-1 as input to the computer'we'uld not provide assurance to an operator that actual. unidentified
. reactor coolant system leak rate was less than the Technical Specification i
i O limit of 1.0 gpm.
The remaining two tests involve water additions tL t may net have been properly compensated for in the leak rate test calculations. The
l surveillance procedure governing leak rate testing cautions the operator to avoid adding or removing water from the reactor coolant system during the period of the test. However, if water must be added or removed, the procedure states that.the amount of the change must be manually inserted into the computer after the plant data has been collected, but prior to the computer performing the actual leak rate computations. l l
i Test #98 (02/02/79) was begun on Shift B and completed on Shift A. The test contains a possible water addition of 110 gallons about 6 minutes before the l
end of the test. No log entry was made in the CR0's Log and no water ,
addition was included in the computation. For test #98, it is not clear '
I whether or not water was actually added during the test, since the slope of the MUT level rise does not exhibit the " normal" characteristics of a water 3
addition. The evaluation relies on the offset in slope of the MUT level 1
indication between the beginning and the end of the test. Changes in pressurizer level and Tave do not account for the offset. This test is not i
conclusive from the standpoint of high confidence in the analysis.
Test #149 (03/16/79) involves two water additions during the test. The actual change in MUT level indicates two additions were made of 120 gallons each. The CRO's Log shows one addition of 200 gal. The amount of water
! included in the computer calculation is 204 gal. Since Mr. Faust was involved in four other tests where water was added and properly accounted for, this test appears to be an isolated incident. It is believed that either Mr. Faust's interpretation of the rise in MUT level indication (30 gal /in) was incorrect or Mr. Faust intended to type "240" into the computer and transposed the numbers and actually typed in "204." Thus, the underrecorded water addition is considered to be a simple human error.
As discussed in the beginning of this section, when Mr. Faust was interviewed in January 1985, he was questioned prior to NRC's updated analysis of the 161 leak rate tests. The earlier analysis included two tests where it appeared hydrogen was added during the test. The 1985 analysis concluded that the spikes were not caused by hydrogen additions but by switching level transmitters between LT-2 and LT-1. The 1985 analysis includes leak rate tests performed during December 1978 and January 1979, which used unstable LT-1 as input to the computer as " questionable." Prior analysis included these types of tests in the " questionable" category only if it appeared water 4
and/or hydrogen additions were made during the tests. Thus, Mr. Faust was not questioned during his interview regarding his knowledge of using the .
unstable level transmitter as input to the computer. Finally, the unsigned, l
- unapproved leak rate test (#12A) associated with LER 78-62/1T was not l i included in the package of leak rate tests discussed with Mr. Faust.
! In summary, the overall results of the NRC analysis for DOJ used to question Mr. Faust'and the revised 1985 analysis support a finding that Mr. Faust did not intentionally manipulated leak rate surveillance tests during the period 4
investigated. Although some of the tests contain elements that call the valid.ity of the results into question, such as the tests performed using LT-1 as input to the computer during its unstable period, there is no pattern of 1
l .. .
O.
1 l
manipulation, as is evident on some other shifts. This is particularly -
significant-during the months of February and March 1979, when identified leakage was high, resulting in it becoming more difficult to get acceptable -
test results for unidentified leakage. During this two month peH od, only 16 l of the 60 tests retained, that were conducted by all six shifts, appear to have been accomplished in accordance with SP 2301-3D1. Whereas, 7 of the 9 i tests run by Mr. Faust meet this criteria. 1 III. Interview Sumary During the period under investigation, September 30, 1978 through March 28, 1979, Mr. Faust indicated that he was primarily assigned to "A" shift. The licensed members of his shift included: Shift Supervisor, W. Zewe; Shift Foreman, F. Scheimann; and Control Room Operators (CR0s) E. Frederick and himself. See page 5.
l-4 In describing his shift organization, Mr. Faust stated that one of the twe CR0s took the panel or desk. This individual would handle the routine evolutions associated with running the plant as well as directing the duties of the Auxiliary Operators (A0s). The other individual would take the required log readings, handle switching and tagging operations, run certain O surveillance tests and take care of.most of the paper work requirements of the watch. The CR0s and A0s operated under the direction of the Shift Foreman and the Shift Supervisor. The Shift Foreman was directly responsible for THI-2, while the Shift Supervisor split his time between THI-1 and TMI-2.
See pages 5-6. .
Mr. Faust stated that his shift members all got along and comunicated very well with each other. He stated that he had little contact with Mr. Floyd, then Supervisor of Operations for THI-2. He stated he would talk to Mr. Floyd if Floyd were in the control room; however, he would bring operational problems or questions to his Shift Foreman or Shift Supervisor rather than Mr. Floyd. Mr. Faust stated that he also had little or no contact on a routine basis with other members of on-site management such as Mr. Seelinger (Superintendent of Technical Support prior to December 1978);
Mr. Kunder (Superintendent of Technical Support after December 1978);
Mr. Logan, (Superintendent THI-2); or Mr. Miller (Station Manager). See pages 7-10.
Mr. Faust was provided a copy of THI-2 Surveillance Procedure 2301-3D1,
" Reactor Coolant System Inventory" and a copy of TMI-2 Technical Specification (TS) 3.4.6.2, " Reactor Coolant System Operational Leakage."
2 After reviewing the documents, Mr. Faust stated that the TS required that a leak rate test be run every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Their shift performed them more frequently If a bad leak rate test result (i.e., unidentified leakage greater than the TS limits of 1.0 gpm) was received, they would throw the bad l
O test result Away. As long as a good result was obtained once during the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, it did not matter how many bad tests were run, they did not have to enter the Action Statement of the TS. See pages 10-12.
1 b
__.m _ _ _ _ _ . _. _ .. _
O. - .
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 BOUNDARY 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 />."
In discussing the policy regarding throwing away bad leak rate test results, '
- Mr. Faust stated that it may have come from management (Supervisor of r
Operations) since that would be the type of thing that they would want handled the same on all shifts. However, Mr. Faust had no first hand
! knowledge that that was the case. However, he stated the policy was in effect when he started as a CRO. Others were doing it, so he started doing it also. See pages 12-14.
Mr. Faust stated that as the date of the accident got closer, it was more difficult to get a good leak rate. He stated that the trend of the MUT went from something close to a straight line to where you gradually had a slope.
According to Faust, the increased identified leakage was caused by a leaking Code Safety Valve at the top of the pressurizer. As identified leakage increased, it would become more difficult to get an acceptable leak rate O result within 1.0 gpm for unidentified leakage. Faust said that Plant Engineering would make modifications to the oak rate forms in order to make the leak rate test more accurate. Mr. Faust believed that modifications were made in order to take credit for nonconservatisms in the procedure. When identified leakage was not as high, these nonconservatisms did not matter;
! however, as leak rate tests became harder to run, it became necessary to take
-credit for them. Mr. Faust specifically remembered one change that was made
- to the leak rate procedure to account for the difference in densities between I
water in the reactor coolant system and. water in the Reactor Coolant Drain Tank (RCDT). See pages 15-17.
Mr. Faust described the way leak rate tests were run on his shift. He stated that leak rate tests were run using the plant computer. When he would start a leak rate test, he would try and inform the other operator that a leak rate j test was in progress and not to make any water additions. If a water addition was made and he did not include it in the calculation, he would 1
invalidate the test, throw it away, and run another test. Faust stated that j
as the date of the accident approached, they ended up throwing away more leak rate tests because they were adding water to the reactor coolant system on a more frequent basis. See pages 18-20.
Mr. Faust was next interviewed regarding an incident that occurred on October 18, 1978. i NOTE: The incident referred to occurred during a routine
- operational inspection of the TMI-2. control ro9m by i an NRC inspector. The inspector discovered that THI-2 had been operating for a period of two or three days l with several leak rate tests indicating unidentified
~ ' - - - - ' - -- -- - - -
~d-i
' - leakage was in excess of the TS limit. The incident
- resulted in the submittal of Licensee Event Report
' (LER) 78-62/1T dated November 1, 1978. The narrative of the LER states, in part, that "This event was caused by misinterpretation of the requirements of the tech-
! nical specifications. The appropriate personnel will
, be instructed on the requirements of applicable sections of the T.S. and the requirement to inmediately invoke
- applicable action statements when the provisions of the LCOs are not met."
i Mr. Faust was shown a copy of the draft LER with an attached routing sheet
, with the typewritten names and handwritten initials of control room personnel. Mr. Faust confirmed that the routing sheet was the normal method by which operators were kept informed of events such as this. He did not i recall seeing the LER prior to the accident, although his initials were on the routing sheet. Mr. Faust stated that there was a reading file in the
, control room for operators. Operators documented their reading of the information by initialing the routing sheet. See pages 29-30. Contrary to the statements in the iER Faust did not reca1T ever receiving guidance or any formal instruction with respect to the correct interpretation of the TS ,
j following the October 1978 incident. See page 35. l
! When asked if anything had changed with respect to the way leak rate tests i were conducted after the incident, Faust stated that he did not believe so. '
i He stated that he continued to throw away leak rate tests, if he believed the ;
test was invalid. He would rerun the leak rate test but would not enter the i Action Statement of TS. If there was a leak rate test indicating greater
! than 1.0 gpm that he could not invalidate, he would give it to his Shift 1 Foreman. The Shift Foreman would then give direction to the oserators such !
i as having the A0s go out in the plant and look for leakage. Tie CR0s
- i. specifically would get direction to observe the trend recorder or other l instrumentation in the control room in order to discern any changes that i
- might account for the increased leakage. Faust believes the Shift Foreman l must have been able to invalidate the tests or "otherwise we would have shut I
- down." See pages 34-35.
When asked if he had ever gone an entire 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift without getting a valid
- leak rate test, Faust responded that that had happened.. Mr. Faust was asked i if he ever had to invalidate a leak rate test because of operator-induced
! actions. He recalled invalidating tests because of water additions and feed
! and' bleed operations. He said as the accident approached, this happened
! quite frequently. "It was hard to get a period of time where you could actually run a leak rate and not be affecting it somehow." He said that this l happened-frequently because of the increased leakage through the code safety 4
valves. He stated that water had to be added frequently to make up for the lost inventory and th.ey had to cycle the pressurizer in order to equalize the baron concentration in the plant that was accumulating in the pressurizer.
~
i See pages 35-37.
i g v, r p--p--w--+m4,v,,-r-,,--e,---- ---
-,,_v,m ., ,.,,,,,n, -
w--,,,-- -,y, ,,---~~--w, - - - , , , r w ,, m e w w w , _w,,-
,p-,,,ame,.-,m+ m g- e- wev-w~,w,a-u ew-->
= -. . - _- . -. - - -_ _ _ _
I Mr. Faust.was asked if he took any action with respect to the difficulty this -
problem was. causing. Faust said:
! "I am sure we felt we were going to get to a point where we
- couldn't meet the limit. We just weren't going to be able
! to get a leak rate. I think Fred (Shift Foreman) agreed i with us. We just will get to a point where you couldn't get ,
one, and end up entering the action statement and shutting I down." .See page 38. l Faust was asked if this possibility was discussed with anyone from their '
i Shift Supervisor on up. Faust responded, "Not that I know of." When asked j if he had ever recommended that the plant be shut down to repair the leakage, Faust said:
li
) "I didn't even make an interpretation like that myself. I don't j think Ed (Frederick) did either. We just -- you know, at least from my point of view, the way we operated was we operated within i the limits that were provided by the tech specs. When you reached
! those limits, that was cause for shutting down the plant due to a component problem; unless for some reason the site ops director
- decided that he needed to shut the plant down for an outage, or j some scheduled outage." See 39-40.
l Faust said that high identified leakage was not the only problem. They were
- also having problems with the Turbine Generator and the polishing and t
regeneration systems. See pages 40-41.
In discussing water additions to the MUT, Mr. Faust was asked how he would i make a water addition. He described the various sources of water and valve i line-ups that were possible and that he watched the MUT 1evel indicator to determine how much water was being added using the ratio of 30 gal./in. level l change. When asked if he felt that he was able to accurately report how much 1 water was added to the system using this method, Faust stated that he never
- had a problem with the amount of water he was adding. See page 42. ,
l Mr. Faust stated that there were times that water was added to the MUT during leak rate tests. The amount of water added would need to be manually inserted into the computer calculation. If it was not included, it would i show up as a negative leak rate. Faust stated that was not the only reason i
for a negative leak rate. Thus, he would accept a negative leak rate if the numbers looked reasonable. He attributed.some of the negative leak rates to instrument tolerances and varying plant conditions. S_ee e pages 51-54.
Farst was aske'd how an operator could use water additions to influence the l
- outcome of a leak rate test. Faust stated that you could either add water i and not tell the computer or you could switch level transmitters for the MUT ,
4 level indication. Faust said that since the level indicators did not always l read.the same, you could start off the test on the lowest reading transmitter l and switch to the higher reading transmitter for the final set of readings, i
f This would_ appear to be a water addition. Faust also said that the water source for demineralized water was outside and that by putting cold water into the MUT, which was around 80*F, the water would expand. Thus, you would .
get an added " bonus." Faust said he did not become aware of this latter effect until after the accident. See pages 54-55. However, Mr. Faust stated )
that he had never used any of these methods to assist himself in obtaining a good leak rate test results. See page 55.
Mr. Faust was asked about Hartman's allegations regarding hydrogen additions influencing the outcome of leak rate tests. Faust stated that he recalled
- having a discussion with other operators about whether hydrogen could affect the outcome. He did not recall any specifics other than it was another shift ;
and that the discussion probably took place during watch turnover. See pages -
i 63-64.
Mr. Faust did not believe that hydrogen would affect the outcome of a leak rate test. He was asked if,he had ever checked out the theory by adding hydrogen to the MUT and observing MUT level indication on the panel. Faust said that he never carried it out that far. He stated the way he added i hydrogen was to tell the A0 to add hydrogen when he was making his rounds, but to let him know when it.was added. See pages 64-65. Faust recalled that i
O at one time hydrogen could be added fromTe control room; however, for a substantial period of time hydrogen had to be added locally. He could not recall the time period in which hydrogen could be added from the control room. See page 67.,
Mr. Faust stated that he did not know if the " hydrogen effect" was comon _
kna ledge. All he recalled was the one discussion during watch turnover. He did not know if the subject was ever discussed amongst the Shift Foremen or g the Shift Supervisors. See pages 65-66. - -
1 Faust stated that he probably added hydrogen during leak rat'e tests; however,
) it was not for the purpose of getting a good leak rate test results. He did
! not recall ever being told by any operators that they were adding hydrogen in j order to assist in getting good test results. See pages 65-66.
! Next Mr. Faust was shown a copy of the technical analysis of the leak rate
] tests in which he was involved. He was also shown copies of the leak rate
- l surveillance t'est sheets, extracts from the CRO's and Shift Foreman's Logs i and copies of the MUT strip charts associated with these leak rate tests. A i detailed discussion of the individual leak rate tests involving Mr. Faust I took place. It was pointed out to Mr. Faust that the results of his testimony was consistent with the technical analysis. Neither his testimony nor the analysis indicated that Mr. Faust was involved in leak rate test manipulation. See pages 68-88.
Next Mr. Faust was shown t. comparison of his shift, " Shift A," with the other five shifts. It was pointed out that overall the pattern shows that Shift A was doing things substantially different from other shifts with respect to leak rate tests. He was asked if leak rate testing practices had been en- -,m-,.. - - --- -,,,.,--.w..,---. -
y,-- __y wm , . - , . - ymm-w,,-,_-.--,.-,ynyc,y-%,--,-e, ---,--w--.g
.~ -
1 i
discussed limongst the members of his shift and if they had developed any 1 attitudes toward these tests that might be different from other stifts.
l Mr. Faust could not provide any explanation. He was surprised that there was i a significant difference in results between leak rate tests performed by I
different shifts. See pages 88-93.
I Mr. Faust could not explain why it appeared that his shift was able to get good leak rate test results without water and/or hydrogen additions and j; others were not. He said that there were times when they were not able to get a good test result. In those cases they turned it over to the next shift. When. asked if he felt pressured to get a good leak rate test, Faust stated that he did not. "It just means you shut down. We shut down enough in the past." See pages 93-94.
IV. Conclusions ;
,The majority of Mr. Faust's responses to questions associated with ' leak rate surveillance test problems at THI-2 were consistent with statements made to the NRC by other former operators. Mr. Faust denied that he personally attempted to influence the outcome of leak rate test results by the addition of water and/or hydrogen during the tests. His testimony was consistent with the technical analysis of the oak rate tests in which he was involved.
O Mr. Faust also denied that he had personal knowledge of or was aware of other operators intentionally manipulating leak rate surveillance tests.
During the interview, Mr. Faust relayed the following information:
j 1. Leak rate tests were routinely run at least once per shift, plant i conditions permitting. At times the tests had to be run several times l before a satisfactory result was obtained (i.e., unidentified leakage !
j within the Technical Specification limit of 1 gpm). There were periods - '
of time when he was not able to get a satisfactory leak rate test result l by the end of his shift. j l
j 2. Only satisfactory leak rate test results were retained. All bad leak l j rate tests were thrown away. In most cases, Mr. Faust was able to i j justify why the tests were " invalid." When he was not able to justify *l why a particular test was invalid, he would give the test to his Shift Foreman. Note: These actions were contrary to TMI-2 Technical Specification 6.10. " Record Retention," which required that records of i surveillance activities required by the Technical Specifications be l retained for a period of at least 5 years.
i 3. Mr. Faust did not log satisfactory or. unsatisfactory leak rate tests i in the CRO's Log. He considered them to be routine in nature and did i- not normally log items of a routine nature. Note: This action was,
! contrary to TMI Administrative Procedure 1012 ' 5hift Relief and Log
- Entries," which required the test title, number of the test, and the start and completion times of all surveillance tests be logged in the i
CRO's Log.
1 i
l 4. Hr.- Faust'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 were aware that invalid test result were being thrown away.
- 5. Contrary to the comitment contained in the narrative of LER 78-62/1T, Faust does not recall being given guidance or instruction regarding the i proper interpretation of Technical Specification 3.4.6.2, " Reactor
- Coolant System Operational Leakage." Following this incident, Mr. Faust was not instructed to invoke the Action Statement of the TS when a leak rate test exceeded the TS Limit for unidentified leakage. Note: These
- actions are contrary to THI-2 TS 3.4.6.2 and to the licensee's stated corrective action in LER 78-62/1T of November 1, 1978.
- 6. Although Mr. Faust could recall one discussion with other operators 3
regarding the possible influence of hydrogen additions on leak rate i tests, Mr. Faust was not aware whether a hydrogen addition to the MUT j could change the outcome of the test. He did not personally add j hydrogen to affect leak rate test results. He was not aware of other operators adding hydregen for that purpose.
, 7. Mr. Faust was aware of methods that could be used by operators to affect ;
- the outcome of a leak rate test by either water additions that were not included in the calculations or by the switching of level transmitters for MUT level indication during the serformance of a leak rate test. He stated he did not personally use eitier of these .or other methods to affect the' outcome of leak rate tests. -
l In sumary, Mr. Faust appeared to be straightforward and honest during the j interview and while some of his actions regarding the conduct of leak rate j surveillance testing were contrary to the THI-2 written procedures and '
i
, Technical Specification, the technical analysis of leak rate surveillance j tests supports a finding that Mr. Faust did not intentionally perform i evolutions that would improperly influe. ice the outcome of leak rate tests.
l l
l j 3
. 1
! J
! l
.-.__ _ _.- _ -_