February 3, 1997
Mr. George Usova
USNRC
Washington, DC 20555
Dear Sir:
In your call of January 13, 1997, you stated that because we disagree about whether certain test items in The INPO Generic Fundamentals Test Item Catalog are erroneous, I, as the alleger, must provide specific instances of a documentable link to a safety significant event that has occurred in a U.S. nuclear plant in order to prove my allegation. I submit that such a safety linkage requirement is seriously misguided and totally inappropriate, for the following reasons:
1. Linkage is not a sensible means for resolution: Technical disagreement is amenable to settlement by several accepted methods, including - reasoning, logic, judgment, common sense, conventional knowledge, expert advice, professional consultation, referral to valid references, mathematical proof, application of the scientific method, demonstration, and by mere fact. The test items, references, and other alleged erroneous training material are either correct or they are wrong, and this is no more dependent on events occurring in nuclear plants than it is on events occurring on the other 8 planets in our solar system.
2. Linkage does not exist for most training problems: Class Room fundamentals training deals with subject matter that provides the student with background information, a common knowledge base, and the prerequisite learning on which to build subsequent plant specific training. Very little of the fundamentals subject matter has, or can ever be shown to have, any direct linkage to safety significant events. Therefore, erroneous fundamentals training material cannot legitimately be held to the linkage requirement.
3. Linkage was not an NRC requirement during development of fundamentals material: Never was there a requirement that only material capable of causing safety significant events be included in fundamentals training. To impose this requirement after the fundamentals material is formalized is tantamount to a declaration that no correction of erroneous training will ever be authorized. Perhaps this explains why this erroneous material has survived for over 40 years.
4. Linkage is totally inconsistent with the nuclear industry’s proactive practices: Preventive maintenance of nuclear plant equipment is focused on fixing problems before they become significant. Also, the nuclear industry is dedicated to the proposition that improving human performance is essential to improved plant safety and reliability. It seems that the time for some preventive maintenance on training problems might be long overdue.
In addition to the above, Stuart Richard’s letter of December 23, 1996, transmitted two documents in response to my request for information about the "allegation review process." These were NUREG/BR-0240, Reporting Safety Concerns to the NRC and Volume 8, Licensee Oversight Programs Management of Allegations, Directive 8.8 and Handbook 8.8. In the first document there are statements about "technical safety concerns ... potential safety issues ... and ... identifying safety concerns." In the second document there are several statements related to "the validity and safety significance of allegations." Neither of these documents provides a definition of a "safety significant event." And, neither states that any kind of safety concern, training or otherwise, must be linked to a safety significant event. It would be helpful if you sent me the definition of a "safety significant event" and the NRC regulation that requires each individual erroneous test item to be linked to a safety significant event.
At this point, your call on January 13, 1997, leaves me uncertain as to whether I am awaiting an NRC response to my letters of October 23 and 25, 1996, or whether the NRC is expecting me to submit safety significant events in support of the erroneous test items. If the latter be the case, then I must inform you that I do not intend to submit linkage, nor do I withdraw my allegation.
The real issue is whether the test items, references, Instructor Lesson Plans, and Student Handouts are wrong. The issue is not whether erroneous training material can be linked to a safety significant event. As indicated in my letter of January 8, 1997, there are over 500 flaws in the INPO Exam Bank section on Reactor Theory and in the GE BWR reference document. This wholesale error is the major safety significant issue that we should be addressing.
Sincerely yours,
Robert G. Stater