ML20155J684

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Partially Withheld Results of Joint Ofc of Investigations/ NRR Evaluation of Tf Illjes Re Leak Rate Testing Irregularities.Denial of Knowledge of Manipulation of Test Results Questioned.Evaluation Encl.W/O Encl 2
ML20155J684
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 08/20/1985
From: Russell W
Office of Nuclear Reactor Regulation
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML20151L202 List:
References
NUDOCS 8605270157
Download: ML20155J684 (20)


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m g NUCLEAR REGULATORY COMMISSION

,  ;; y WASHINGTON, D. C. 20655 August 20, 1985

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MEMORAND'UMTFOR: 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 OI/NRR INVESTIGATION AND EVALUATION OF THE0DORE F. ILLJES l

Reference:

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

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

Subject:

Staff Requirements-Discussion of Pending Investigation- i TMI -

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2. Memorandum from H. R. Denton (NRR) to B. B. Hayes (01) dated May 3, 1984.

Subject:

NRR Review of.01 Investi-gation Materials Concerning Hartman Allegations of  !

Falsification of Leak Rate Data at TMI, Unit 2

3. Memorandum from W. T. P.ussell (DHFS) to H.R. Denton (NRR)datedJanuary 24, 1985,

Subject:

Follow-up O Action on Additional TMI-2 Operators The purpose of this memorandum is to document the results of the joint 01/NRR investigation and evaluation of Mr. Theodore F. Illjes, currently a licensed Senior Reactor Operator (SRO) at Three Mile Island, Unit 2 assigned as a Shift Supervisor, and to provide a' recommendation regarding whether his current SRO license should be revoked, modified or suspended under 10 CFR 55.40 or other enforcement action taken under 10 CFR Part 55.50, due to his involvement in preaccident leak rate testing irregularities at TMI-2.

Background 1 As a result of a Connission meeting on March 23, 1984, NRR was directed by i Reference 1 to review OI investigative materials concerning falsification of l reactor coolant system (RCS) leak rate tests at TMI-2 and refer back to 01 l l

l NOTE: This memorandum and Enclosure 1 discuss information which is the subiect of an ongoing OI investigation. This memorandum and Enclosure 2 discuss information that is maintained in the NRC's Privacy Act System of Records (NRC-16). This memorandum and enclosures may not be djsseminated outside the NRC without coordination with NRR and the peniilssion of the ED0 or ~the Director. 01. Internal access and distribution should be on a "need to know" basis.

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Harold R. Denton August 20, 1985 those' matters which requ' ired further investigation. The results of NRR's review was provided in Reference 2. The review determined that follow-up investigation by 01 and fu'rther evaluation by NRR was needed in the case of seven currently licensed operators. T. F. Illjes was one of these seven s individua1s. At a follow-up Commission meeting on May 23, 1984, NRR proposed.

joint DI/NRR investigations and evaluations of these individuals.

Subsequently, NRR issues letters to these individuals under 10 CFR 55.10(b)

! requesting additional information regarding current performance. Based upon - J i

the joint investigation into the individuals' past involvement in improper l 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 operators. As a result of some of the early interviews with l

, these individuals and further technical analysis, Reference 3 recomunended l 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 on TMI-2, two are licensed on Waterford 3 and one is licensed on San Onofre 2 j and 3.

j Past Involvement in TMI-2 Leak Rate Testing Irregularities On January 29, 1985, a joint 01/NRR interview of Theodore F. Illjes was held  ;

l in the law offices of Killian & Gephart, Harrisburg, Pennsylvania. The interview was conducted in the presence of Mr. Illjes' attorneys. The purpose of the interview was to detennine Mr. Illjes' role, if any, in 1 improper activities associated with RCS leak rate surveillance testing at i O TMI-2 prior to the accident on March 28, 1979. At that time Mr. Illjes was 4 '

a licensed Reactor Operator (RO) and served as a Control Room Operator (CRO) on Shift "B." A detailed evaluation of Mr. Illjes' interview and a summary of the technical analysis of-leak rate surveillance tests involving Mr. Illjes 4

are provided in Enclosure 1 to this memorandum.

1 During the interview, many of Mr. Illjes' responses to general questions 1

. associated with leak rate surveillance test problems at TMI-2 were consistent I with statements made to the NRC by other licensed operators; however, the l majority of his responses regarding his personal involvement in or knowledge

, at leak rate test manipulation do not appear credible. Bas'ed upon the l results of NRR's technical evaluation and Mr. Illjes' responses during the intervies the following sununary of findings and conclusions are drawn.

1. Although Surveillance Requirement 4.4.6.2 required RCS leak rate j surveillance tests to be conducted 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, leak rate tests were run routinely run at least l once per shift. Mr. Illjes stated that they "always had a leak rate on
the computer." Sometimes, they ran three or four tests during the j course of a shift. -
2. Only-satisfactory leak rate test results were logged in the CRO's Log.

Test results which exceeded the technical specification limit were not i

logged. Note: These actions were contrary to TMI Administrative l Procedure TOT 7, " Shift Relief and Log Entries," which required the title, i number, start and completion time of all periodic tests required by the l technical specifications (i.e., leak rate tests) to be log'ged in the

] CRO's Log.

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Harold R. Denton August 20, 1985 l l

3. Because his shift ran so many tests, bad leak rate tests (i.e., net i' unidentified leakage greater than the technical specification limit of 1 gpm) were either thrown away directly by Mr. Illjes, or signed and placed on the Shift Foreman's desk or left on the computer for the next s shift. Regardless of Illjes' original disposition of the test, any test.

indicating a value in excess of the technical specification limit, was eventually discarded. Note: This action was contrary to TMI-2 Technical SpecificationT.TU.1.d, " Record Retention," which required '

that records of surveillance activities required by the technical specifications be retained for a period of at least 5 years.

4. Mr. Illjes stated that operators questioned the validity of the computer program used for running leak rate tests. At times, test results could not be explained (e.g., different results for the same set of conditions). Overall, however, Illjes thought it was a useful tool. At
times they were able to obtain a satisfactory test result the first time they ran the test and other times they might go an entire shift without

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obtaining an acceptable test result. When they were busy, they did not take time to pursue what changes were taking place in the plant that j might cause them to obtain unsatisfactory test results.

l~ 5. Although the acceptance criteria of Surveillance Procedure 2301-3D1,

" Reactor Coolant System Inventory," required the operators to enter the action statement of Technical Specification 3.4.6.2, if unidentified leakage exceeded 1 gpm, Illjes stated that they did not interpret the

! requirement that way back then. He said, since the test was required only once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, they did not believe it was necessary to enter i

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the action statement unless they exceeded the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without obtaining a satisfactory test result. Note: The action statement required leakage to be reduced within TTiiits 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 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in cold shutdown within the

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following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. -

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6. Although Mr. Illjes had initialed the routing sheet for Licensee Event Report (LER) 78-62/1T, he stated that he did not have a preaccident recall of the LER; therefore, the LER neither altered his interpretation of the technical specification nor did it change the way he performed

. the test or handled the test results. Note: Mr. Illjes statements are

- in conflict with the LER submitted to thDIRC on November 1.1978. The LER stated that the event was caused by misinterpretation of the requirements of the technical specifications and'that appropriate personnel would be instructed on the requirements of applicable sections of the technical specifications and the requirement to immediately invoke applicable action statements when the provisions of the limiting conditions for operation were not met.

7. Mr. Illjes believed that as the date of the accident approached, it was harder to get good leak rate test results because of high identified

^ leakage through either the PORY or code safety valves. He stated that although he was concerned with operating the plant wi*h high identified j' leakage, he did-not recomend that the plant be shut.*an. At the time, he did not believe that was his judgement to make. He discussed the leakage with his Shift Foreman and his Shift Supervisor and was told i

j O that "they were going to do something about it." Note: Identified leakage did not exceed the technical specification TTiiTt of 10 gpm prior to the accident.

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i Harold R. Denton August 20, 1985 l

O 8. Mr. Illjes stated that prior to the accident, he was unaware that hydrogen additions to the make-up tank (MUT) could affect MUT level indication and thus, favorably influence leak rate test results. Note: s Mr. 'Illjes' Shift Supervisor (Mr. Joseph Chwastyk) was deposed on --

1 Apri-1 24, 1984, as part of the TMI-1 leak rate investigation prepared i

{ for T= PUN by Mr. Edwin Stier. During his deposition Mr. Chwastyk stated-,

4 that he first became aware of the effect of hydrogen on leak rate test i

results at TMI-2 in late 1978 and that he believed this phenomenon was brought to his attention by one of his CR0s, specifically, Mr. Illjes.

1 9. Mr. Illjes testified that he never added hydrogen for the purpose of

! affecting leak rate test results and that he was not aware of this effect until sometime in 1980, after Hartman's allegations were made public. Note: Mr. Chwastyk stated that he conducted a test and personally observed the hydrogen effect on leak rate test results and implied the test was done when it was first brought to his attention.

Mr. Chwastyk also stated the he gave his operators directions not to add hydrogen when they were doing leak rate tests until he could determine what was causing the problem.

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10. Mr.111jes testified that he never intentionally added water for the purpose of affecting leak rate test results. If water was added during a test and not included in the calcul'ation, it was most likely caused by miscommunication between the operator perfonning the test and the operator on the panel who added the water. If water was added and the amount of water included in the leak rate calculation was less than

' amount indicated on the MUT strip chart, it was caused by instrumen-tation errors between the totalizer and the strip chart. He was not aware that the two fratruments might read differently. He stated that i he was also not aware that pressure changes in the MUT caused by the addition of water to the tank could be used to his advantage during the

! perfonnance of a leak rate test. -

11. Mr. Illjes stated that since there were two level transmitters for MUT j

level indication (i.e., one feeding the strip chart and one pro'viding input to the computer for leak rate calculations), it was possible to affect leak rate test results by switching between level transmitters during the test. However, he stated he did not become aware of this phenomenon until after the accident.

12. The technical analysis shows that between 09/30/78 and 03/28/79, 13 of the 18 tests (72%) involving Mr. Illjes included actions that were contrary to the precautions and limitations of Surveillance Procedure 2301-3D1. These actions included: unstable plant conditions; use of an unstable MUT level transmitter to provide input to the computer; water i

additions that were not properly included in the calculation, and hydrogen additions to the MUT. During the period where identified leakage was high (01/01/79 to 03/28/79), 7 out of 8 tests (88%)

, involving Mr. Illjes included these procedural errors. These are the same type of " procedural errors" that other operators have admitted using to manipulate or influence the outcome of leak rate tests.

4 In sununary, while Mr. Illjes' now considers that some of his actions regarding the conduct of leak rate tests were contrary to TMI-2 written procedures and technical specifications; he denies that he performed i

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Harold R. Denton August 20, 1985

% evolutions with the intent of influencing the outcome of leak rate test tesults. Based upon the weight of the available evidence, including the high number of invalid or questionable tests involving Mr. Illjes, and the testimony.of Mr. Chwastyk, it appears that either Mr. Illjes was not truthful -

regarding his knowledge of or involvement in leak rate test manipulation or i he was grossly negligent in that he ran many leak rate tests and would  !

knowingly accept only test results less than the technical specification _

l limit, regardless of the evolutions in progress during the test.

Current Perfomance 1

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Harold R. Denton August 20. 1985 i

Conclusions During the period Mr. Illjes was licensed as a Control Room Operator at TMI-2 prior to the accident, he admitted he was involved in activities associated j i with reactor coolant system leak rate testing that were in violation of  !

approved plant procedures and the TMI-2 Technical Specification. These i actions included: the throwing away of leak rate test results in excess of i

the technical specification limit; not logging unsatisfactory test results; and on occasion, not pursuing what changes were taking place in the plant  !

that might be causing them to obtain unsatisfactory test results. However,

' he denies that he was involved in other actions. including leak rate test manipulation or falsification or knowledge that such activities were going on around him. The weight of available evidence, including statements by his former Shift Supervisor (Mr. Chwastyk) and the technical analysis, strongly )

suggests that Mr. Illjes was either not truthful in answering questions regarding his role in or knowledge of leak rate test manipulation or he was grossly negligent in perfonning leak rate tests.

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Based 'upon the testimony of the )

majority of other CRO's and Shift Foremen interviewed to date, it is clear i that management's standards for procedural compliance were lax and pennissive. In my opinion, this was created through nagligence on the part of management. Lack of operator respect for the leak rate test procedure i

coupled with management's failure to correct test procedure problems and to instill high standards for procedural compliance led to conditions that motivated some operators to falsify leak rate test results.

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4 /A/ h =M1 3

William T. Russell, Acting Director -

l Division of Human Factors Safety Office of Nuclear Reactor Regulation

Enclosures:

,l As stated

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. cc: B. Hayes l K. Christopher l

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1 NOTE: This enclosure discusses information which is the subject of an

' engoing 01 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.

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Enclosure 1 FAST INVOLVEMENT IN TMI-2 '.EAK RATE TESTING IRREGULARITIES I. Background On January 29, 1985, a joint Office of Investigations (OI)/ Office of Nucle'r a Reactor Regulation (NRR) interview of Theodore F.111jes was held in the law offices of Killian & Gephart Harrisburg, Pennsylvania. The purpose of the
interview was to determine Mr.111jes' 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 A. Capra, Senior Program Manager, Staff of the Executive Director-for Operations.

Representing Mr. Illjes at the interview were his personal attorneys. Mr.

Smith 8. Gephart of the law fim Killian & Gephart Harrisburg, Pennsylvania

, and Mr. Harry H. Voigt 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 to this enclosure.

Mr.111jes is currently employed by General Public Utilities Nuclear Corporation (GPUN) as a Shift Supervisor and holds a Senior Reactor Operator's (SRO) license for THI-2. Prior to joining Metropolitan Edison Company (Met-Ed) in January 1971, Mr.111jes served for seven years in the U.S. Navy's nuclear submarine program. His first few months with Met-Ed were spent working at Crawford Station. He was then transferred to Three Mile

.sland and worked as an Auxiliary Operator (AO) at TMI-1. He remained in that position until he was placed in the cold licensing operator training group for Control Room Operators (CR0s) at TMI-2. He received his Reactor

, Operator's (RO) license in October 1977 and served as a CR0 at TMI-2 until late 1979, when he was promoted to Radwaste Shift Foreman. He later served as a Shift Foreman in the Control Room and in 1982 was promoted to his l present position of Shift Supervisor. Mr.111jes received his initial SRO license in April 1980.

The interview with Mr.111jes concentrated on the period September 30, 1978 through March 28, 1979. During this time period, he served as a CR0 at TMI-2 assigned to Shift "B." At that time, Shift "B" consisted of the following licensed individuals:

,, SHIFT "B"- .,

Shift Supervisor SRO Joe Chwastyk O- Shift Foreman CR0 CR0 SRO R0 R0 Bill Conaway John Kidwell Ted 111jes l CR0 (in training) --

Chuck Mall

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A sumary of the technical knalysis of the leak rate tests involving Mr.

Illjes is provided in Section II of this enclosure. A sumary of the intervi.aw with Mr. Illjes is provided in Section III. The sumary of -

interview includes citations to the page numbers of the transcript from which the sumarized information was extracted. Overall conclusions regarding Mr.

111jes' involvement in improper activities associated with TMI-2 leak rate surveillance testing are presented in Section IV of this enclosure.

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II. Sumary of the Technical Analysis 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 (00J) in its criminal proceeding against Met-Ed. The results of this analysis were used in questioning Mr.111jes during his interview. However, based upon infonnation obtained during interviews with former TMI-2 operators, a reevaluation was performed during the summer of 1985. The sumary of technical analysis provided in this section relies on the updated 1985 analysis. The major differences between the two analyses, with respect to Mr.111jes' tests, will be explained at the end of this section. While the complete 1985 evaluation of leak rate tests at TNI-2 is provided as Attachment 2 to this enclosure, a sumary of the conclusions regarding Mr. Illjes' tests is provided here to help the reader understand the basis for the questions posed to him during his interview and the basis for the conclusions shown in Section IV.

The test records show that of the 161 leak rate surveillance tests retained by the licensee during the period under investigation, Mr.111jes was

I involved in 18 of these tests. During the 18 tests, he was either the j

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 j which the test was conducted. The table below shows a breakdown of the j overall conclusions regarding Mr. Illjes' tests.

Breakdown of Leak Rate Tests Involving'T.F. Ill.ies i Evaluation Category Number of Tests

, To ta l numb e r o f te s ts o n fi l e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 l Tests with no apparent problems.................................... 5 Tests involving unstable plant condi tions . . . . . . . . . . . . . . . . . . . . . . . . . . 3 l Tests involving the use of an unstable make-up tank level transmi tter as input to the plant computer. . . . . . . . . . . . . . . . . . . . . . . 6 Water additions that were not included in the calculation.......... ~

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Water additions where the amount of water added was only J partially included in the calculation..... ...................... 1 Hydrogen additions to the make-up tank during the test............. 3 Hydrogert or water additions during the test (unable to differentiate)................................................... 1 l Noter Four tests fall into more than.one evaluation category.

Test 28 contains both unstable plant conditions and a water j .

addition that was not included in the calculation.

Test 31 contains both unstable plant conditions and was run with the make-up tank (NUT) level transmitter providing input to the computer reading 13" lower than the level transmitter feeding the MUT level strip chart recorder.

Test 56 contains both a possible water addition that was i ~

not included in the calculation and was run with the

. unstable make-up tank level transmitter (LT-1) providing input '

~ to the computer. ~~

- Test 69 contains a possible hydrogen addition and was run with

-unstable LT-1 providing input to the computer.

As can be seen from the table above, only five of the 18 tests involving Mr.

111jes during the last six months of operation at TMI-2 appear to be conducted in accordance with the requirements and precautions of the I

surveillance procedure governing the conduct of leak rate tests (SP 2301-301). The emaining 13 tests involve actions that violate the limits and precautions of the procedure, thus, yielding questionable or invalid results. For some tests, actions may have been taken in an attempt to manipulate or influence the outcome of the leak rate test results. The basis for our evaluation of each test is presented below.

The five tests that appear to have been conducted in accordance the -

surveillance procedure are tests #11 (10/15/78), #22 (10/24/78), #32 (11/02/78), #46 (12/04/78) and #117 (02/13/79).

< Three tests, #9 (10/13/78), #28 (10/29/78) and #31 (10/31/78),' were performed when the plant was not in a steady state condition. SP 2301-301 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 when in j Modes 1 through 4. The procedure also cautions the operator to maintain the i 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 deterr.ination of the RCS leak rate, the initial and

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final conditions of reactor power, RCS temperature, pressure and pressurizer 4 level should be identical. Test #9 was conducted during a secondary plant j startup. The spray valve (plant wasTave RC-V-1). experiencing varied approximately problems with 4.5'Fthe during Tave controller the test. Test and results showed net unidentified leak rate as -8.5 gpm. Test #28 was also

conducted during a secondary plant startup. Large oscillations occurred

] during the test in Tave, pressurizer level and make-up tank (MUT) level

indication. In addition, a 330 gal water addition was made to the MUT, l logged in CRO's Log, but not included in the leak rate calculation. Test #31 was conducted in Mode 3 (hot standby) with primary plant testing in progress.
Large changes in pressurizer level (+10.5") and MUT (-7") occurred during the l test. While these tests do not represent examples of intentional i manipulation, they do represent examples of tests that may have been retained because the results were less than technical specification limit even though j stable plant conditions did not exist. These tests are considered invalid.

i At TMI-2 there are two level transmitters (LT-1 and LT-2) that provide MUT level indication. The output of one of the level transmitters drives the MUT level recorder strip chart in the control room while the other level transmi.tter provides MUT level indication to the p.lant 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 selector i

. switch is positioned to LT-1, the strip chart recorder would be driven by the cutput of LT-1 and LT-2 would provide autcmatic input to the plant computer l

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for leak rate test calculations. When the selector switch was changed to O LT-2, the strip chart recorder would be driven by LT-2 and the computer would recejve its MUT level indication from LT-1.  ;

BetweeN 0ctober 30 and Novetbar 6, 1978, operators experienced problems with '

both level transmitters. At various times during this period the level '

transm'itters.were reading radically different levels in the MUT and both were taken out of service for maintenance work and recalibration. During this '

4 period Mr. Illjes was involved in leak rate test #31 (10/31/78). This test was not only performed during unstable plant conditions but the level transmitter providing input to the plant computer was reading approximately 13" lower than the level transmitter driving the strip chart recorder.

Beginning December 1, 1978 and continuing through January 11, 1979 the output

, of LT-1 became erratic and unreliable. Because of the erratic nature of the

! output of LT-1 during this period, any leak rate tests 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 durin were perfonned with the stable level transmitter (LT-2)gproviding this period input only to 16 the computer during the test. During this period, Mr. Illjes was involved in 6 tests, 5 of which used unstable LT-1 as input to the computer. These 6

tests are: #46 (12/04/78), #47 (12/05/78), #56 (12/11/78) #69 (12/20/78),

l #90(01/07/79)and#91(01/08/79). .

Test #46 was the only test involving Mr.111jes that used stable LT-2 as input to the computer during this period. The test was started on Mr.

Illjes' shift and was completed by Shift "D."

i' O Approximately five minutes before the beginning of leak rate test #47 the level transmitter was shifted such that LT-1 would provide input to the computer. The data shows a significant difference between the output of LT-1

and LT-2 during the test. This was the same shift that the Shift Foreman

{ (Bill Conaway) submitted a work request to repair LT-1 due to level r

oscillations.

During leak rate test #56, MUT level should have decreased approximately 2";

however, because LT-1 was used, the test indicates MUT level actually increased 2". It is also possible that a small amount of water (60 gal) may have been added during this test. There is no log entry for a water addition and no water addition is included in the calculation. During leak rate test

  1. 69, final MUT level is higher than initial level. From the trace on the

, strip chart it appears that either hydrogen was added approximately ten minutes before.the end of the test or the level transmitters were switched

! one or more times near the end or the test. The net effect during the one

hour test was approximately +3.5" or 100 gal.

When test #90 was conducted, the slope of the MUT was approximately ~3"/hr.

indicating substantial gross leakage. However, because of the use of LT-1 the net unidentified leakage calculated by the computer was as .22 gpm.

The following day test #91 was conducted in a similar manner. Instead of MUT level decreasing 3" during the test, the level seen by the computer increased 1.2", again giving a negative valve for net unidentified leakage.

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During the entire period of time LT-1 was essentially out of comission, all

shifts, including Mr. Illjes' shift, continued to run leak rate tests (34 out i

of 50) with LT-1 providing MUT level indication to the computer resulting in s ,

j a meaningless calculation of unidentified reactor coolant system leak rate - 1 i which' c5uld not demonstrate conformance with the technical specification l i limit of 1 gpm. _. i

, Threetests,#28(10/29/78),#56(12/11/78)and#115(02/12/79) included i i

possible water additions that were not accounted for in the leak rate test  !

calculation. Test #29, as discussed above, was perfomed during a period of l i unstable plant conditions; however, the test also included a water addition l i of 330 gal that was not included in the calculation. The water addition is l

! logged in the CR0's Log. Test #56, also discussed above, possibly contains a '

{ small water addition of approximately 60 gal. There is no log entry that -

1 water was added. If water was not added during the test, the test is still l

considered in<alid because of the use of unstable LT-1. Test #115 contains a '

! 150 gal water addition near the beginning of the test. The water addition is i neither logged in the CRO's nor taken into account in the test calculation.  !

Also during this test, it appears that the reactor coolant drain tank (RCOT)

! was pumped down. This evolution is also not logged or taken into account in i

'. the calculation. .

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! Thereisalsoonetest,#147(03/14/79) where the amount of water added

according the MUT strip chart is significantly d{fferent from the amount logged in the CRO's lo ,

gal and 210 gal at 123!.and The1250, MUTrespectively.

strip chart shows The CR0's water additions Log of 390 shows water l additions of 300 gal and 200 gal at 1230 and 1250, respectively. A 500 gal  !

l addition was included in the calculation; however, it was included in the l wrong step, i.e., water deletions not water additions. Because of possible i 1 instrument inaccuracies between the totalizer (digital readout of amount of j water added) and the M,UT stiip chart recorder, it is not possible to )

- determine whether this test was intentional under-recorded or whether Mr.

, Illjes was a victim of instrument error. Nevertheless, because the water j addition was not entered into the computer properly, the test is invalid.

One of the possible mechanisms for MUT level instrument inaccuracies during l water additions is discussed below.

As discussed in other reports involving TMI-2 leak rate test investigations.

4 the addition of hydrogen to the MUT theoretically should not alter MUT level

!' indication. 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 this l condition, 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 without actually adding water to the tank. Thus, the addition of i hydrogen at the appropriate time (after the computer collected its initial 1 data and shortly before the final data readings were taken) could affect the

. leak rate results in a nonconservative manner (e.g., the calculated leak rate i would be less than the actual leak rate). Also because adding water to the MUT compresses the hydrogen gas in the top of the MUT water additions to the i MUT shortly before the computer obtained its final data set would thus have the same effect as a hydrogen addition.

i .

6-1 I

Three tests, #69 (12/20/78), #123 (02/17/79) and #124 02/19/79) involving Mr.

Illjes appear to include hydrogen additions during the test. Test #69 l exhibits characteristics similar to other known hydrogen additions; however, because this test also involved the possible switching of level transmitters ,

between LT-1 and LT-2, a firm conclusion can not be drawn. There is no log-entry indicating a hydrogen addition. Nevertheless, an evolution was perfonmid approximately 10 minutes before the end of the test which affected .

MUT level +3.5". Test #123 contained a hydrogen addition shortly before the end of the test. While no log entry appears in the CR0's Log, the A0's log indicates hydrogen was added approximately 11 minutes before the end of the test. MUT level was affected approximately +1" to +2". Test #124 also exhibits characteristics similar to other known hydrogen additions. The hydrogen appears to have been added approximately 1 minute before the end of the test. No log entry was made. Again MUT level indication was affected approximately +1" to +2".

Finally, Test #125(02/19/79), which was started by Mr. 111jes shift only 35 minutes after completing test #124, also contains a possible hydrogen addition. While the characteristics are similar to other hydrogen additions, the MUT level remains higher following the transitory response seen with other hydrogen additions. This characteristic could also represent a small water addition of approximately 3.0 gal. .Thus, this test was evaluated as either a hydrogen addition or water addition. .

As discussed in the beginning of this section, when Mr. Illjes was interviewed by OI/NRR in January 1985, he was questioned prior to NRR's O reevaluation of the 161 leak rate tests. The differences between the "sumary of tests" discussed with Mr. Illjas and the revised analysis include the following:

1. Two tests were added to the list: #9(unstableplantconditions)and#22 (no apparent problems).
2. The significance of LT-1 during its unstable period has now been highlighted. Thus, tests #47, 90 and 91 were reclassified from "no water / hydrogen additions" to " unstable LT-1." Tests #56 and #69 were run on= unstable LT-1 but also contained a possible water and hydrogen addition, respectively and thus were already considered invalid. Mr.

Illjes' personal knowledge regarding level transmitter problems was not discussed with him during the interview.

3. Test #31 was reclassified from "no apparent problems" to " unstable plant conditions."

4 Test #46 was reclassified from " water addition" to "no apparent problems and LT problems." .

5. Test #125 was reclassified from " water addition" to " water or hydrogen addition." .

In sumary, the technical analysis shows that between 09/30/78 and 03/28/79, 13 of the 18 tests (72%) involving Mr. Illjes included actions that were contrary to the precautions and limitations of Surveillance Procedure 2301-301. These actions included: unstable plant conditions; use of an unstable MUT level transmitter to provide input to the computer; water additions that were not properly included in the calculation, and hydrogen O, additions to the MUT. During the period where identified leakage was high (01/01/79 to 03/28/79), 7 out of.8 tests (88%) involving Mr. Illjes included

7 these procedural errors. Based upon the high number of questionable or )

inval4d tests, it appears that the tests were accepted as valid as long as the result was less than the technical specification limit, regardless of the .

evolutions in progress during the test. For some of these tests, evolutions- )

i were idantified which other operators admitted utilizing to manipulate or i influence the test results. _. l III. Interview Sunnary

! During the period under investigation, September 30, 1978 through March 28, 1979, Mr.111jes indicated that he was assigned primarily to "B" Shift. The ,

I licensed members of his shift included: Shift Supervisor, Joe Chwastyk; Shift l l -

Foreman, Bill Conaway; and Control Room Operators (CR0s), John Kidwell and j l himself. In addition, Charles Mall was an unlicensed CRO-in-training ,

assigned to their shift. ee

.S_e.e, pages 5-6. l 111jes stated that he had a close working relationship with his Shift Foreman. Both his Shift Foreman and his Shift Supervisor were knowledgeable l about operations that occurred during the shift, although Conaway, being in

, Unit 2 more that Chwastyk, was a little more familiar with the details.

l Illjes had little day-to-day contact with management personnel such as the i

Supervisor of Operations (J. Floyd), the TMI-2 Superintendent (J. Logan) or the Station Manager (G. Miller). See,pages e 6-7., l In describing how his shift was organized. Illjes stated, that one man would l

l O have the panel. The panel operator would be responsible for controlling the plant, maintaining the CRO's Log, and directing evolutions performed by the AuxiliaryOperators(A0s). One CR0 would take charge of perfoming the

" switching and tagging" duties and the third CR0 would usually take care of the paperwork. They would normally rotate positions each day. S_ee,pages 10-11. ,

The panel operator was the individual who nomally would make any water additions to the reactor coolant system (RCS) or hydrogen additions to the j MUT although, the panel operator could ask either of the other CRos to perform the evolution, if he were busy. See page 12.

a I

, NOTE: The CR0 performing the leak rate surveillance test

was normally one of the CR0s who did not have the j panel. -

1 l After reviewing copies of TMI-2 Technical Specification 3/4.4.6.2, " Reactor j Coolant System Operational Leakage," and Surveillance Procedure 2301-3D1,

" Reactor Coolant System Inventory," 111jes stated that the Technical i

Specifications required them to perform a RCS leak rate test at least once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; however, they normally performed the test every shift.. He stated that they "always had a leak rate on the computer." Sometimes, they ran three or four tests during the course of a shift. See,pages 8, 10, 13.

$0TE: ' Surveillance Procedure 2301-3D1 was used at TMI-2 to

, demonstrate compliance with Technical Specification - 3.4.6.2. The technical specification required, among O,- other limits, that RCS unidentified leakage be limited to 1 gpm. Technical Specification 4.4.6.2 required RCS leakages to be tiemenstrated to be within limits by performance of a RCS water inventory balance (leak i rate test) at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during steady l state operation.

- - _ _ _ _ , ,__._.__..____.m.. . . _ _

' ~

O Because his shift ran so many tests, all results were not retained. Some were_ thrown away, some were put on the Shift Foreman's desk, and some were left on the computer for the next shift. When unacceptable test results were.

obtainet (i.e., unidentified leakage in excess of I gpm) Illjes said he _.'

would try to detemine the cause of the problem. In some cases, it was i discovered r that the panel operator may have added water during the test or i pumped down the reactor coolant drain tank (RCDT) and these evolutions had '

not been taken into consideration in the computer calculation. See,pages 13-14.

NOTE: The surveillance procedure cautioned the operators to avoid such operations during the perfomance of leak rate tests; however, if changes to RCS inventory had to be made during the performance of a test, they had to be accounted for by inputting the data into the plant cceputer before the leak rate calculation was i obtained.

Mr. Illjes could not recall the rationale he used for determining which tests he would retain and which tests he would throw away. Although he remembered throwing away test results that were " ridiculous," he thought that he signed most of the tests and.put them on the Shift Foreman's desk even if the

- results were unacceptable. He did not believe th,ere was a consistent practice on their shift for retaining or throwing away test results. he

pages 14-17.

O NOTE: Technical Specification 6.10.1.d required that records of surveillance activities required by the technical specifications (i.e., leak rate surveillance tests) be retained for a period of five years.

When asked if he had faith in the results of the computer program for

! perfortning the surveillance test, Illjes said that the operators questioned

the program because sometimes test results could not be explained (e.g.,

obtaining different results for the same set of conditions). Overall, j' however, he thought it was a useful tool. He said there were times when they were busy and they did not take the time to pursue what changes were taking place in the plant that might cause them to obtain an unsatisfactory test

result. Occasionally they were able to get a satisfactory test result the 1

first time they ran the test and other. times they might go an entire shift

{ without obtaining an acceptable test result, he,pages17-19.

l Mr. Illjes stated that he was not aware of the requirement in Administrative

Procedure 1012. " Shift Relief and Log Entries," to log the start and stop
time for all surveillance tests. He recalled logging the completion time in i

the CRO's Log for test results that were satisfactory; however, unsatisfactory results were not logged. He said that.no one ever directed ,

him not to log test results as an attempt to hide the fact they were having to run so many tests. See pages 19-20.

I - -

~

j NOTE: Section 3.3.17 of AP-1012 required that the title, number, j start and completion time of all periodic tests required i

, by the technical specifications (i.e., leak rate tests)

, be logged in the CR0's Log.

l i

_ __ _ _ _ _ _ _ _ _ u_..

.. .g.

i O Although the acceptance criteria of Surveillance Procedure 2301-301 required the operators to enter the action statement of Technical Specification 3.4.6.2, if unidentified leakage exceeded 1 gpm,111jes said that they did not interpret the requirement that way back then. He said, since the .

j surveillance test only had to be run once ever 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, they did not believe it wasJtecessary to enter the action statement unless they exceeded the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without obtaining a satisfactory test result. Illjes stated that their.

, interpretation would be different today, "but at the time, unfortunately, -

! that was our interpretation." See pages 21-22.

NOTE: The action statement of Technical Specification 3.4.6.2

stated
"With any Reactor Coolant System leakage greater i i than any one of the above limits, excluding PRESSURE I BOUNDARY LEAKAGE, reduce the leakage rate to 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 STAND 8Y within the -

! next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."

Mr. Illjes was asked to review a copy of Licensee Event Report (LER) 78-62/1T. The LER described an event which occurred in October 1978 in which an NRC inspector found several leak rate surveillance tests lying in the

~ Control Room which indicated the unidentified leak rate was in excess of the requirements of the technical specifications. It was pointed out to Mr.

Illjes that the narrative section of the LER stated the event was caused by a

, misinterpretation of the requirements of the technical specifications and

that appropriate personnel ~would be instructed on the requirements of the
technical specifications (i.e., the requirement to immediately invoke the 1 action statement when the provisions of the limiting condition for operation

! arenotmet). Although Mr. Illjes had initialed the routing sheet for the LER, he stated that he did not have a preaccident recollection of the l

. incident and did not recall any receiving any specific instruction on the

! proper interpretation of the technical specifications. See pages 23-28.

i Mr.111jes stated that following this incident he did not receive I

instructions from anyone to ensure that unacceptable leak rate test results were thrown away and not left lying around where the NRC could find them.

j Mr. Illjes was informed that on April 24, 1984, his Shift Supervisor (Mr.

Chwastyk) testified that he did provide direction to his shift to throw away invalid leak rate tests. Mr. Illjes said that while he did recall throwing i

test results away, he did not recall doing that as a result of directions from Mr. Chwastyk and did not remember any heightened sensitivity to ensuring

! invalid t;sts were thrown away. See pages 28-30 and Chwastyk Dep. at pages j 24-25.

NOTE: Mr. Chwastyk was deposed as part of the TMI-1 leak i rate investigation prepared for GPUN by Mr. Edwin i

H. Stier. Mr. Chwastyk's deposition appears as

" Witness Statement C" of Appendix C to the Main Report. Excerpts of Mr. Chwastyk's April 24, 1g84 deposition are included as Attachment 3 to j -

this Enclosure.

  • l . Illjes did not believe is was necessary to. rely on leak rate test results to determine if the plant was leaking. He stated that if there was a problem, 1

. __ :~ ' L__ ;r::D-~~_ L_ _

i X:" 22:D--. L::

i l l. .'

the operators could tell by looking at the change in slope of the MUT level recorder. The slope would change for any significant leakage. See pages 30-31. -

! Mr.111jes believed that as the date of the accident approached, it was i harder to get. good leak rate test results because of high identified leakage through either the PORV or code safety valves. He reca led that one of the-valves was leaking but did not know which valve was causing the problem. He l recalled tail pipe temperatures downstream of the valves being higher than normal and that they were planning on changing out one of the relief valves j during the next scheduled outage. Be;pages31-33.

NOTE:

While leakage the (i.e., technical 10 gpm wassfecification not exceeded, the limit highfor identified leak .

rate and errors in the procedure made it more difficult to obtain a test result for unidentified leakage within l- 1 gpm.

I Mr. Illjes stated that he was concerned with operating the plant with high

! identified leakage; however, he did not recommend that the plant be shutdown.

l He said at the time, that was not his judgement to make. He believed he discussed the problem with his Shift Foreman and his Shift Supervisor. He said he knew they had a problem, but he was told,they were going to do something about it. 111jes said, "maybe that was justification enough for me." See pages 33-35.

In discussing the effect of hydrogen o'n leak rate test results, Mr.111jes stated that they were required to maintain a certain hydrogen overpressure on the MUT. When hydrogen pressure dropped to the low end of the operating band, they would add hydrogen. Illjes stated that he knows now that adding *

, hydrogen to the MUT could influence MUT level indication and consequently leak rate test results. However, he said that he was not aware of this

' phenomenon prior to the accident. It was pointed out that several operators have testified that the hydrogen effect was consnon knowledge on all shifts.

Nevertheless,111jes maintained his position that he was not aware of this until after the accident. See pages 37-38.

It was pointed out to Mr. Illjes, that his Shift Supervisor (Joe Chwastyk) testified on April 24, 1984 that he first became aware of the effect of hydrogen on leak rate test results in late 1978 and that he believed this phenomenon was brought to his attention by Ted Illjes'. Chwastyk said he personally observed the phenomenon, did not understand why it was happening and contacted Instrumentation & Control (I&C) personnel to investigate the .

matter. Chwastyk also stated that he gave his operators directions not to
add hydrogen when they were performing a leak rate test until he could
determine what what was causing the problem. In spite of Mr. Chwastyk's j testimony, Mr.111jes stated, that he did recall bringing this matter to j Chwastyk's attention and he did not remember running an experiment to show Chwastyk the phenomenon. He said that if he would have done something like j that._ hg_would remember it. See pages 39-40 and Chwastyk Dep. pages 27-35.

I i .

I

_ _ _ _ _ . . _ . _ . _ _ _ _ _ . _ . _ . _ _ . _ _a . _ . . _ . - . _ _

i NOTE: While Chwastyk stated that he conducted a test and personally observed the hydrogen effect on leak rate test

results and implied the test was done when it was first brought to his attention, Chwastyk did not specifically ,, ?

! -- state that Mr. Illjes was involved in the experiment.

i

- As discussed in Section II of this report, it is believed l

! that hydrogen was added during leak rate test #69. This - '

test was perfomed by Mr. Illjes on December 20, 1978. j

, This tia~e frame is consistent with Mr. Chwastyk's i

. testimony that he was made aware of the hydrogen effect l in late 1978.

i Mr. Illjes testified tHat he never added hydrogen for the purpose of influencing leak rate test results and that he was not aware of this effect"  !

until sometime in 1980, after Hartman's allegations were made public. See -

[ pages 41-42.  ;

( At this point in the interview, Mr. Illjes was provided a package of material  !

associated with leak rate tests he was involved in during the period being '

i investigated. The package included a summary sheet, leak rate surveillance  :

I . test data sheets, extracts from the CR0's Log, and copies of the strip chart. I recorder trace for MUT level indication. After explaining the material in

detail, Mr. 111jes was allowed to review the package in private with his attorney. 53 pages 42-46.

l Following his review of the leak rate test material, five of the tests were ,

discussed with Mr.111jes. These tests showed examples of two water '

additions where the amount of water added was either not included or only partially included in the test calculation and three cases where hydrogen was added to the MUT during the course of the leak rate test. Se,e pages 46-64 In discussing water add'itions during leak rate tests, Mr.111jes was asked if i he was aware that the amount of water added in gallons, as read off the totalizer, could be different from the amount of water added, as shown by the

change in MUT level indication and that that difference could be used to l
influence the leak rate test results. If water were added during a leak rate l 1- test,111jes said he would use the amount of water indicated on the totalizer i as input to the computer as opposed to using the amount indicated on the MUT strip chart. Mr. Illjes stated that he was aware that they had experienced 3 some problems with water in the loop seal of the MUT 1evel transmitters;
however, he said he was not aware that pressure changes in the MUT caused by the addition of water to the tank could be used to his advantage during the 1

perfomance of a leak rate test. Sge pages 59-64.

During the review of Mr. 'Illjes' leak rate tests, he lid not agree with all of the conclusions of the technical evaluation. Ne. ,theless, sufficient questiouble evolutions occurred during these tests snat caused Mr. Illjes to

state that in operations today, he wou d pay a lot more attention to ensuring
that the individual perfoming the leak rate test and the individual on the panel _wg_re aware of what each other was doing. According to Mr. Illjes, if water and/or hydrogen were added during the course of a leak rate test and
not properly included in the calculation, it was not done intentionally to

. manipulate the. outcome of the test. See page 58.

l l

i l

l

. . e

., . . . . . ._ . _ , . . . ......m . . . . . . _ .

4 . .

i O It was pointed out to Mr. Illjes that based upon Chwastyk's testimony, the

, testimcry of several former operators who admitted their involvement in activities that influenced the outcome of leak rate tests, and the technical .

evaluatjon of all leak rate tests performed at TMI-2, it was difficult to understand how he could not have been aware of what was going on around him. i Mr. Illjes stated: "You can take it for what it is worth. You know, it is

I j ' going on six years. I am saying I didn't intentionally manipulate a leak
rate. I can say that. It is safe in my mind that I didn't do something to consciously cheat on a leak rate." Illjes also reiterated the fact that he ,

l was not aware of any operator manipulating leak rate test results until after '

l the accident. ' See pages 65-66.

. Mr. Illjes was asked if he could provide any additiral infomation regarding

leak rate testing practices that he may have had 6 .:" edge about but was not

, questioned about during the interview. Mr. Illjn ; .ted that since there were two level transmitters for MUT level indication (i.e., one feeding the strip chart and the other feeding the computer), it was possible to affect leak rate test results by switching between level transmitters during the test. Illjes stated, however, he was also not aware of this phenomenon until after the accident. S,ee,pages e 76-77.

1 IV. Conclusions . -

While many of Mr. Illjes' responses to questions associated with leak rate O surveillance test problems at TMI-2 were consistent with statements made to the NRC by other licensed operators, the majority of his responses regarding his personal involvement in or knowledge of leak rate test manipulation do i not appear credible. Based upori the results of NRR's technical evaluation

! and Mr. Illjes' responses during the interview, the following conclusions are l drawn.

i l 1. Although Surveillance Requirement 4.4.6.2 required leak rata l surveillance tests to be conducted 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, leak rate tests were run routinely run at least

! once per shift. Mr. Illjes stated that they "always had a leak rate on

{ the computer." Sometimes, they ran three or four tests during the J course of a shift.

i

! 2. Only satisfactory leak rate test results were logged in the CR0's Log.

f Test results .which exceeded the technical specification limit were not logged. Note: These actions were. contrary to TMI Administrative j ProcedureM, " Shift Relief and Log Entries," which required the title, number, start and completion time of all periodic tests required by the technical specifications (i.e., leak rate tests) to be logged in the

CRO's Log. ,
3. Becausehisshiftransomanytests,badleakratetests(i.e., net l unidentified leakage greater than the technical specification limit of 1 gpH were either thrown away directly by Mr. Illjes, or signed and i placed on the Shift Foreman's desk or left on the computer for. the next shift. Regardless of Illjes original disposition of the test, any test indicating a value in excess of the technical specification limit, was

. eventually discarded. Note: This action was contrary to THI-2 Technical SpecificationTT5.I.d. " Record Retention," which required that records of surveillance activities required by the technical specifications be retained for a period of at least 5 years.

s-13 l

4 Mr. Illjes stated that operators questioned the validity of the computer

-prcgram used for running leak rate tests since test results could not be i explained (e.g., different results for the same set of conditions). .

Overall, however, he thought it was a useful tool. At times they were--

able to obtain a satisfactory test result the first time they ran the test and other times they might go an entire shift without obtaining an ,

acceptable test result. When they were busy, they did not take time td-

  • pursue what changes were taking place in the plant that might cause them '

l to obtain unsatisfactory test results.

5. Although the acceptance criteria of Surveillance Procedure 2301-301, t

" Reactor Coolant System Inventory " required the operators to enter the  :

i

' action statement of Technical Specification 3.4.6.2, if unidentified '

3 leakage exceeded 1 gpm. Illjes stated that they did not interpret the

requirement that way back then. He said,'since the test was required i i only once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, they did not believe it _was necessary to enter
the action statement unless they exceeded the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without obtaining a satisfactory test result. Note
The action statement required leakage to be reduced within TTiiiTts 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 j following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. .

. 6. Although Mr. Illjes had initialed the routing sheet for LER 78-62/1T, 1 '

he stated that he did not have a preaccident recall of the LER;

) therefore, the LER neither altered his interpretation of the technical specification nor did it change the way he performed the test or handled i

O the test results. Note: Mr. Illjes statements are in conflict with the LER submitted to the H C on November 1, 1978. The LER stated that the event was caused by misinterpretation of the requirements of the technical specifications and that appropriate personnel would be instructed on the requirements of applicable sections of the technical specifications and the requirement to imediately invoke applicable action statements when the provisions of the limiting conditions for

! operation are not met.

L l 7. Mr. Illjes believed that as the date of the accident approached, it was j harder to get good leak rate test results because of high identified i j , leakage through either the PORY or code safety valves. He stated that l although he was concerned with operating the plant with high identified j leakage, he did not recomend that the plant be shutdown. At the time,

he did not believe that was his judgement to make. He discussed the i leakage with his Shift Foreman and his Shift Supervisor and was told i that "they were going to do something about it." Note
Identified l

leakage did not exceed the technical specification Tiiiirt of 10 gpm for l identified leakage prior to the accident.

4 l 8. Mr.-Illjes stated that prior to the accident, he was unaware that I hydrogen additions to the MUT could affect MUT level indication and i thus, favorably influence leak rate test results. Note: Mr. Illjes' i Shift Supervisor (Mr. Joseph Chwastyk) was deposed on April 24, 1984, as l part of the TMI-1 leak rate investigation prepared for GPUN by Mr. Edwin

! Stier. During his deposition, Mr. Chwastyk stated that he first became l , aware of the effect of hydrogen on leak rate test results at TMI-2 in.

{ late 1978 and that he believed this phenomenon was brou

attention by one of his CR0s, specifically, Mr. Illjes.ght to his i

I

~-. , - . _ . . _ . - _ -. , , . _ _ _ - _ , . .

14 i

!O l

i

9. Mr.111jes testified that he never 'added hydrogen for the purpose of Tnfluencing leak rate test results and that he was not aware of this i effect until sometime in 1980, after Hartman's allegations were made -

i puhlic. Note: Mr. Chwestyk stated that he conducted a test and -~

l personally observed the hydrogen effect on leak rate test results and j i implied the test was done when it was first brought to his attention. __ - 1 l Mr. Chwastyk also stated the he gave his operators directions not to add i hydrogen when they were doing leak rate tests until Chwestyk could j detemine what was causing the problem. l 1

1

10. Mr. Illjes testified that he never intentionally added water for the I

purpose of altering leak rate test results. If water was added during a test and not included in the caiculation, it was most likely caused by l miscomunication between the operator performing the test and the i operator on the panel who added the water. If water was added and the i amount of water included in the loak rate calculation was less than i amount indicated on the MUT strip chart, it was caused by ,

l instrumentation errors between the totalizer and the strip chart. He {

was not aware that the two instruments might read differently. He i

! stated that he was not aware that pressure changes in the MUT caused by the addition of water to the tank could be used to his advantage during the performance of a leak rate test.

11. Mr. 111jes stated that since there were two fevel transmitters for MUT

^

! level indication (i.e., one feeding the strip chart and one providing l input to the computer for leak rate calculations), it was possible to i

! affect leak rate test results ty switching between level transmitters  !

during the test. However, he stated he did not become aware of this l

! phenomenon until after the accident. l

12. The technical analysis shows that between 09/30/78 and 03/28/79, 13 of the 18 tests (72%) involving Mr.111jes included actions that were l l contrary to the precautions and limitations of Surveillance Procedure l

) 2301-301. These actions included: unstable plant conditions; use of an '

4 unstable MUT level transmitter to provide input to the computer; water i additions that were not properly included in the calculation, and hydrogen additions to the MUT. During the period where identi!!ad l' leakage involvingwas Mr. hifh iljes (01/01/79 includedtothese 03/28/79), 7 out of procedural 8 tests errors. These (88%) are the same type of " procedural errors" that other operators have admitted to l using to manipulate or influence the outcome of leak rato tests.

1 1 In sumary, While Mr.111jes' now considers that semel of his actions

! regarding the conduct of leak rate tests were contrary to THI-2 written

! procedures and technical specifications; he denies that he performed

! evoluties with the intent of influencing the outcome of leak rate test results. Based upon the weight of the available evioence, including the high number of invalid or questionable tests involving Mr.111jes, and the I

testisiony of Mr. Chwastyk, it appears that either Mr.111jes was not truthful regarding his knowledge of or involvement in leak rate test manipulation or

he was grossly negligent in that he ran many tests and would knowingly accept i' only test results less than the technical specification limit, regardless of the evolutions in progress during the test.
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