ML20203L465

Prepared Statement of RR Booher Re Leak Rate Data Falsification.Related Correspondence

ML20203L465
Person / Time
Site:	Three Mile Island
Issue date:	08/22/1986
From:	Booher R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20203L462	List: ML20203L460 ML20203L465 ML20203L469 ML20203L473
References
LRP, NUDOCS 8608260278
Download: ML20203L465 (6)

Text

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e' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 11 AUS 22 P4 2 BEFORE THE PRESIDING BOARD tt KfTSpff["TAl<Y VICl.

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In the Matter of )

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INQUIRY INTO THREE MILE ISLAND ) Docket No. LRP UNIT 2 LEAK RATE DATA )

FALSIFICATION )

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PREPARED STATEMENT OF RAYMOND R. BOOHER My name is Raymond R. Booher. I currently reside in South Haven, Michigan. I am not licensed to operate a nuclear power plant.

Prior to joining Metropolitan Edison in 1971, I was with the United States Navy for six years. From 1971 to 1981, I was employed by Met Ed, first as an auxiliary operator in TMI Unit 1, then as a control room operator in TMI Unit 2. I obtained my TMI-2 license in 1977 and retained it until I terminated my employment with Met Ed in 1981. I then became employed by Louisiana Power & Light (LP&L) as a control room supervisor, licensed as a Senior Reactor Operator. In 1985, I terminated my employment with LP&L. I am now employed as, Training Consultant at Palisades Nuclear Power Plant in Michigan.

While I was a control room operator at TMI 2, John Blessing was a trainee and Harold Hartman was an operator on my shift.

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Kenneth Hoyt was the foreman and Bernard Smith the shift supervisor. According to technical specifications, we had to perform one successful 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 />. My employer required us to perform the tests more frequently, but I no longer recall how often we actually did run the test. I have no reason to doubt that we ran the tests on a shiftly basis. Tests that did not come out within the specified limit for unidentified leakage were discarded. I discarded them because I believed that I only needed one acceptable test with less than 1 gpm unidentified leakage during the 72-hour period. I do not know who taught me this interpretation of the technical specification; all I can remember is that that was how I operated.

I recall that generally my shift performed either one or two leak rate tests in order to obtain a successful one. There were times when we had to run the test more frequently, and times when we did not get one for an entire shift. I recall that satisfactory leak rate test results became more difficult to obtain as 1979 progressed.

I tended to show tests with over 1 gpm unidentified leakage to the shift foreman. While he initially might have told me to run another ona, it did become a habit for me to run another one without his directive. The foreman also sent the control room operators or the auxiliary operators to search for leaks if plant instruments showed that there might be leakage.

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Although I cannot remember specific values, I do recall submitting negative leak rates to the shift foreman for filing. At scme point, however, I was told that negative test results would no longer be accepted. I do not know who told me this or why.

I attributed problems I had in obtaining a good leak rate test to variations in instrument accuracy and then to increasing leakage from either the pressure operated relief

, valv,e or the code safety valves. This increase in leakage did cause me to experience some concern as to whether I would be able to obtain a satisfactory leak rate test; however, I never felt that my job would be in jeopardy if I did not produce a successful test result. All that I can recall hearing from my superiors on the subject was that I should keep trying to get a good test.

I remember logging only the completion time of the surveillances that my shift performed. I do not believe that I ever logged the start time of a surveillance, and I do not recall anyone bringing the matter to my attention. I have learned, of course, that my practice was not in compliance with the NRC's interpretation of the administrative procedure l

governing logging practices.

I no longer recall the November 1, 1978 Licensee Event Report other than from investigators showing it to me. I know that my interpretation of the technical specifications for leak i

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e rates did not change, so I can only conclude that the LER had no effect on me.

I recall that I added hydrogen to the makeup tank on my own initiative to maintain a specified pressure band. I do not think that I would have considered adding hydrogen during a leak rate test to have been prohibited by the leak rate test procedures. I no longer recall whether I thought hydrogen had an actual effect on leak rate tests. I do recall some discussion on this subject, although I can no longer pinpoint the time. I am certain that I never deliberately added hydrogen to affect the makeup tank level.

I am aware that there is one " definite" leak rate test that I filed where hydrogen was added during the test. This test, dated October 20, 1978, was signed by me, but Leonard Germer was on the panel. He logged the addition of hydrogen. I am not sure that if I had seen the hydrogen entry in the log, I would have invalidated the test because I do not remember being aware that a hydrogen addition could affect a test result.

Edwin Stier claims that another test dated, March 15, 1979, shows a possible hydrogen addition. Although I performed this test I was not assigned to the panel and I did not collaborate in manipulating this test, or any other, by adding hydrogen.

We were required to log water additions made during the performance of a leak rate test. The operator performing the test was supposed to check the log for water additions.

Although the NRC has accused me of deliberately adding water 4

during the leak rate tests to affect the results, I never did this, and I believe that I have been unfairly accused. For s

three of the tests where I was allegedly involved in manipulation, specifically, January 13, 1979, February 2, 1979, and February 23, 1979, I logged the water entry as I was supposed to. The operators who performed those tests did not enter the water additions on the computer printout. I did not

" jog" water, as the NRC claims, for tests dated March 10, 12, 13, and 15, 1979 (two of which I signed). I really cannot understand how the NRC experts distinguished supposed jogged additions on strip charts showing similar effects for the entire day, but I do know that I did not engage in the practices they attributed to me by their analysis of these documents.

I do not know why Harold Hartman stated I added water to falsify leak rate tests. According to the NRC investigators, he believed that I was not a good operator; perhaps that is why he feels that I was involved in the conduct similar to his.

All I can ask of the Presiding Board is that it fairly l

scrutinize the evidence compiled against me, and conclude that I did not participate in leak rate falsification. While the l

evidence shows that my shift discarded tests and made mistakes in recording information on the computer printout or the log, i

it does not show that I willfully falsified leak rate tests.

What that evidence really proves is that the NRC investigators gave a highly subjective and questionable interpretation to my I

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four signed leak rate tests, and the strip charts from my shift's tests, to fit this data into the Hartman allegations.

In conclusion, I would like the Presiding Board to know that I sincerely regret the mistakes I made as a control room operator at TMI-2. My experience as a shift supervisor at LP&L's Waterford 3 has taught me that I was far too casual about the interpretation of the technical specifications at TMI-2. At Waterford, I learned the absolute necessity for strict compliance with the technical specifications and plant administrative procedures. Because of what I have been through, I am confident that I could do an excellent job if I can preserve my option to apply at a future date for an NRC license.

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