November 30, 1996
Mr. Stuart A. Richards
USNRC
Washington, DC 20555
Dear Sir:
Your letter dated November 21, 1996, indicates that certain issues I have raised, specifically concerning a sampling of erroneous Reactor Theory questions in INPO’s Generic Fundamentals Catalog and the subsequent identification of errors in an important supporting General Electric reference for these questions, are to be addressed in your allegation review process. In addition, your understanding of my concerns are tabulated as five separate allegations. Since I am not familiar with the allegations review process, I must respectfully request more information about how this procedure works. I would appreciate answers to the following questions:
a. How does this process differ from the exchange of letters used to date?
b. Why is the allegations review process being implemented at this particular time?
c. What are the advantages of the allegations review process that will expedite a real resolution?
d. Who conducts the detailed review?
e. What reference material is to be used in lieu of the flawed GE document under review?
f. Since the errors submitted are but a small sampling of the total problem, how will this review provide any real resolution (see following paragraph)?
g. How is corrective action to be accomplished ... and by whom?
h. Does the review provide me with opportunities for input, or for response, during review?
i. Do I receive a draft of the review, for comment, before it is officially issued?
j. Can I attach a dissenting opinion to the review for determinations with which I disagree?
l. What avenues of appeal are available in the event I disagree with the review results?
m. Do I have any legal rights in this review, other than optional confidentiality?
Unfortunately, the five items listed as your understanding of my concerns are a disappointing start to implementing any allegation review process. These concerns greatly understate the problem at hand because of their focus on a few flawed test items, which constitute but a small part, an example, of the overall error. The real issue, as raised with my first letter to Chairman Jackson, dated January 10, 1996, is “the glaring omissions of important subject matter and the fact that nearly all of the basic concepts being taught about reactor behavior are incorrect.” A subsequent letter, dated November 12, 1996, categorized the Class Room training material as “filled with error, misinformation, incorrect equations, flawed graphics, false concepts, and mangled theory.” If the allegation review process does not address these broader concerns, then it amounts to nothing more than did rearranging the deck chairs on the Titanic. On receipt of your answers to the above questions, and of any other clarifications you feel appropriate, as to what we’re dealing with, and how, I will submit a listing of concerns to you by letter.
As separate items, please note that in your letter of November 21, 1996:
1. You state that the Nuclear Regulatory Commission takes safety and wrongdoing issues very seriously. The issues raised with respect to reactor behavior training are certainly vital to plant and reactor safety, regardless of what the ACRS says. However, no issue of wrongdoing has been raised with respect to the flawed material itself.
2. The date of the General Electric, BWR Academic Series, Reactor Theory is incorrectly given as 1994. I do not have the date of issue of this document, but in your letter of May 14, 1996, it was given as 1984.
Despite the fact that I will not soon forget the discourtesy and lack of professionalism displayed by the ACRS in 1989, I am willing to work with you on any serious effort to resolve the subject matter mess that pertains to reactor behavior in commercial nuclear training.
Sincerely yours,
Robert G. Stater