January 31, 1996
Mr. Stewart Richards
USNRC
Washington, DC 20555
Dear Sir:
As you requested in our phone conversation on January 30, 1996, the Generic Fundamentals Test Exam Bank questions which were identified to INPO as being flawed are enclosed. Seven questions were submitted via INPO feedback forms. However, eleven related questions were identified which suffered the same, or similar, weakness. The question numbers are based on Academy Document 89-004. In these few examples we have a misdefinition of keff, a misapplication of subcritical multiplication, and a misuse of reactor rate, all fundamental concepts of reactor behavior.
In any case, these seven questions represent but the tip of the iceberg. After discovering that subsequent issues of the Exam Bank contained the same errors, it became obvious that I was wasting my time. Further planned submittals were terminated. In the subject area of Reactor Theory, I estimate that twenty-five percent of the Exam Bank questions are flawed.
I am puzzled to learn that upgrading of fundamentals training material must be justified on the basis that it will prevent operator error in the Control Room. My impression is that fundamentals training provides the student with the necessary prerequisites, background, and knowledge base needed for subsequent training, including systems and simulator training, as well as for general job performance. If, in fact, this is the official criteria, then how were the erroneous concepts justified as preventing operator error in the Control Room? And, how is classical physics or the six-factor formula justified as preventing operator error in the Control Room?
You are correct in stating that there is little, if any, room in the class schedule for additional subject matter. Of course, this does not preclude correcting erroneous training material. In fact, this is a very good opportunity to conduct a long overdue review aimed at upgrading the content of Reactor Theory so as to provide the Reactor Operator with the fundamentals he really needs to know to do his job.
Sincerely yours,
Robert G. Stater
(Note 5/3/98: the seven test items are not included herein because they are contained in the NRC response to this letter.)