ML20052G821
| ML20052G821 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1982 |
| From: | Boone J, Catron N, Regan J NRC - PEER REVIEW GROUP |
| To: | |
| Shared Package | |
| ML20052G815 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8205190028 | |
| Download: ML20052G821 (20) | |
Text
., --
/-
Report of the Peer Advisory Panel and the Nuclear Regulatory Conunission on Operator Qualifications Dr. James J. Regan, Chairman Dr. James O. Boone Mr. Nick Catron Dr. R. Bruce Gould Mr. Paul Katz Lt. Cdr. Jerry Owens March 1982 I
i 8205190028 820513 i
4 6
Introduction Panel $1embersandConsultants The Peer Advisory Panel on Operator Qualfications to the Nuclear
, Regulatory Commission was, with one exception, selected on the -basis of
]
their expertise.in human resources management in general, and selection, qualification standards, and job task analysis in particular.
They were i
intentional'ly not selected for expertise in nuclear operations so as to allow a fresh perspective on the-issue of operator qualifications.
The
~
sixth panel member is an individual with current operational experience at a nuclear power plant.
All Panel members are federal employees.
The Panel was* assisted by seven consultants.
Two of these were selected for their knowledge of nuclear power plant operations, training, and organization.
A third consultant was selected 'because of his involvement l-with the Human Factors Society assistance to the NRC.
A fourth was A
chosen because of his knowledge of union concerns vis-a-vis the question of operator qualifications, while a fifth was asked to serve because of his first hand knowledge of INPO's programs in areas of relevance to..the Panel's concerns.
A sixth consultant was chosen for his overall general
~
sensitivity to issues involving nuclear power, while a seventh consultant was selected for the academic orientation he would bring to bear on the l
dis cus s ions.
The complete list of Panel members and consultants is shown i
in Appendix A.
Panel Activities The Panel had two meetings.
The first was in Seattle, Washington on November 16-18, 1981; the second was in San Diego, California on e
e D
e e
n
-,-,-,w,--
~g e,, - -,, -. -,
--,------,--,,r,,n
,-_.,--e-,-an--e,-n-,,
-.r--,
e 2
January 12-13, 1982.
Prior to the Seattle meeting, the Panel received and reviewed a background report prepared specifically for the Panel by Bai:telle staff (see Appendix B).
The report detailed current qualification requirements for RO's, SRO's, SS's, and STA's as well as proposed revisions to the requirements.
The proposed revisions included those discussed by Commissioner Gilinsky and by Commissioner lhearne, and those detailed in Secy 81-84, NRC staff position #1 (7/27/81), NRC staff position #2 (7/27/81), NUREC/CR-1280, NUREG/CR-1750, A"NS 3.1 (1978),
Proposed Requirements ANS 3.1 (4/10/81), and INPO GPG-03.
In addition, the report highlighted current practices in several other high stress, high vigilance occupations such as Air Traffic Controllers, Commercial.
Airline Pilots, Navy Aircraf t Pilots, Navy Nuclear Power Plant Operators, and Registered Nurses.
The first Panel meeting served the general purpose of reviewing the,
background report, familiarizing the Panel members with the issues involved in this area, and allowing the Panel members to share with one another the standard practices in their own organizations.
The following additional materials were requested by the Panel and distributed at the first Panel meeting:
relevant sections of NUREG 0737, including the Denton letter of March 28; model job description materials for operators, and STA's, as prepared by Analysis and Technology, Inc. for INPO and Sandia Laboratories (October,1981); an INPO report on the job task analysis for Shift Supervisors entitled "The Shift Supervisor Position in the Nuclear Power Industry" (INPO, September 1981, 2 volumes); and a Position Paper prepared by one of the consultants to the Pane'1, Paul r
Shoop of the International Brotheshood of Electrical Workers.
N 3
In addition, the Panel members also identified the need to visit a nuclear power plant and simulator, and requested some additional reports.
'Ihus, subsequent to the first Panel meeting each Panel member who had not previously done so visited a nuclear power plant and simulator.
Anong the facilities visited were the McGuire plant and
~
simulator,'the Sequoyah plant and simulator, the S*an Onofre plant and the Palo Verde plant and simulator. 'In addition, one Panel member visited INPO in Atlanta to review their job cask analysis program in detail.
The Panel shared the resu.Its of these visits with one another during the second Panel meeting.
Finally, the Panel members were sent NUREG/CR-1270, Volume I, which provided a human factors overview of the TMI accident, and a draf t report by Au, DiSalvo, and Mershoff of Nuclear Regulatory Research at the NRC entitled "Results cf Survey,of Foreign Reactor Operator Qualification, Training and Staffing Requirements."
The day prior to the second Panel meeting, a workshop of nuclear industry personnel from Region 5 was conducted by Battelle staff.
The participants were selected so as to be representative of operational, re cruitment, and training aspects of nuclear power plants.
All but two l
l of the Panel members observed this workshop, and they were joined by three of the consultants.
The workshop specifically addressed various aspects of operator qualifications and involved a great deal of l
discussion on the part of the participants.
The workshop was structured so as to allow the Panel and consultants to interact directly with the workshop participants during the last two hours.
There were also two formal presentations made to the Panel.
The firdt, during the first Panel meeting., was by Hal Tucker and " Red" Thonias
4 who described the Atomic Industrial Forum's position to the Panel.
The second, given during the second Panel meeting, was by Harold Denton of the NRC, and described the background leading up to the formation of the Panel and detailed a recent (January, 1982) NRC staff position.
In addition, the results of the prior day's workshop were summarized and presented to all the panelists and consultants at the second Panel meeting.
Finally, two additional position papers prepared by Mr. Shoop of the IBEW were distributed to' the Panel.
Thus, by the second Panel meeting there was consensus on the part of the Panel that they were sufficiently well versed with the, issues and positions that they could make their recannendations to the NRC.
This report contains the Panel's recemmendations'and' justification for them.
The next section enumerates the Panel's reco=mendations.
The Discussion section gives the justifications for the reccmmendations and a.lso highlights some of the other considerations discussed by the Panel.
Recommendations Underiving Principles In their considerations, the. Panel agreed upon three guiding principles which would underlie their recommendations:
1.
Do not degrade the overall level of experience on-shift and in, command of nuclear power plant operations.
2.
Enhance the technical capabilities of the crew on shif t.
3.
Enhance training of nuclear power plant operations personnel.
The Panel also agreed that any requirements recommended would be accompanied by considerations of. the benefits and costs of the G
e
S re commenda tion.
The Panel strongly concurred that recommendations in line with these principles would enhance public safety.
Re commenda tion 1 A bachelor's level degree requirement should not be imposed on the RO, SRO, or'SS position.
Recommendation 2 The' STA' position should not be required.
Recommendation 3 Assurance of ' appropriate engineering expertise should be implemented via creation of' a '"shif t ' engineer." This would be a person with a baccalaurea*te in engineering or a related degree plus engi' eering n
experience, who would also be certified to be at an RO le el at the facility, and would have two years of relevant engineering experience.
The training requirements for this individual would be the same as those proposed for the STA in NUREG 0737.
The shift engineer would be an engineer on shift who carries out routine operational support engineering duties and is available and reports to the Shift Supervisor should the SS require engineering assistance.
Recommendation 4 The NRC should be involved in the accreditation of utility training programs and their' training staf fs, as well as individuals successfully completing such programs.
e e
..___,m,
6 Recemr. endation 5 The experience requirements for an SRO with a technical B.S. degree should be'less stringent than for an SRO without one.
This is shown on page 17.
Discussion Considerations'in Degree Requirements for RO,'SRO, SS,
One of the key questiohs facing the Panel was whether a baccalaureate level degree should be required for any of 'the positions of RO, SRO, and SS. 'Due Panel considered this question in some detail and concluded that imposition of such a requirement, without evide.nce that the requirement is ne
_.a t'o perform the job, is likely to result in a decrement in overall performance and thus impair public safety.
Specifically, the following disadvantages are seen to accrue to an unnecessary imposition of a degree requirement:
j 1.
Poor Performance:
The shift-work nature of the positions in question lacks appeal in general, and are not especially likely to appeal to baccaleureate level engineers.
In addition, there would be little opportunity for engineers to use their training, I
resulting in lack of job challenge, frustration, and poor performance.
2.
Inexoerienced Operators:
The factors discussed above will result in difficulty in filling the positions with engineers of high quality.
Moreover, those who take the position are likely to have an "up and out" orientation, rather than view the operations position as a career goal.
Eventually, this would 6
l
7 have the negative ef fect of decreasing' the average amount of experience of individuals in key control room decision making roles.
3.
High Turnover:
Those degree candidates who do not advance to the managerial ranks are likely to have their career objectives frustrated and therefore change occupations, thus resulting in higher turnover rates.
Having an unstable core of operational personn'el is not in the best interest of pubric safety.
4.
Drive Out capable operators: -In the short run, imposing a
' degree requirement would result in preference given to formal education over years 'of experience in filling SRO and SS positions.
Given that very few of the operator - corps are currently degreed, this would result in key decision making positions being filled. by individuals with more education but less experience, despite the fact that education and experience are not substitutable. Moreover, this is likely to drive out the individuals without degrees from the industry.
The Panel has seen no evidence that a formal degree is indeed necessary for job performance, and thus prefers to see experience receiving more weight than formal education in these positions.
This preference is based on the widely held dictum that the best predictor of performance on a job is immediate past' performance, i.e., positive job experience.
5.
Invalid Curtailment of Selection Pool:
It is a well established finding in personnel research tha t inclusion of a selection 1,,, goe ex,,pt, g, t, Blum and J. C. Naylor', Industrial 3
Psychology:
Its theoretical and social foundations, Harper and Row:
New York, 1968.
4
,,-,____.--__.,-,___,y
...,-_y--_
,. ~ _, _,.. -.,.. _,., _
-.m,
e n
8 standard that is not in fact related to performance will likely result in a decrement in the overall quality of personnel selected for the position.
In the present conte xt, this would be manifested by the exclusion of the large pool of non-degreed individuals who would otherwise perform well on the job.
In essence what the imposition of an invalid selection eriterion does is to needlessly stlect out individuals who have the ability to perform the job.
In real world ap~plications, where the pool of potential applicants is finite and the number of positions to fill is large, this will result in selection decisions of lower quality than if the invalid criterion was not used.
6.
Mispla ced
- Emphasis.
The emphasis on a baccalaureate degree _ is s
mis pla ced.
The emphasis should be directed. coward th.e specific training requirements needed to perform the job.
As discussed in a later section, job task analysis is an important source of information for determining the content and extent of a training l
program.
If job task analyses, indicate that the knowledge l
requirements for the job are best accommodated by a baccalaureate degree program, then such a requirement should be cons idered.
7.
Little Scientific Basis:
The scientific evidence which can be' brought to bear on the issue from similar, high vigilance, high stress occupations indicates that a degrced individual does not necessarily perform better than a non-degreed individual.
For e
e
.-+m-------w--..
,---n
a a
9 example, research on air traffic controllers has shown that college graduates have had the highest training and job attrition rates, while high school graduates had the lowest rates.. Results from the nursing profession are not as clear cut.
as those for air traffic controllers; nonetheless, there is not a' consistent body of literature that shtows baccalaureate level nurses perform better than non-degreed nurses.
The ' Shif t
- Te chni cal ' Advis or ' and ' the Shif t ' Engineer The Panel is persuaded by the January,1982 NRC staff position argument presented to the Panel by Mr. Denton that engineering expertise must be available to the shift supervisor in many off-normal situations.
In additio'n, as discussed in a later section, the Panel recognizes that job task analyses may form an incomplete basis for task de'scriptions for entirely novel situations.
Thus, the Panel feels that the judicious course of action is to assure the availability of engineering expertise on shift by creation of a position entitled " shift engineer." This" is l'*
envisioned as an engineer who has experience at, and in-depth knowledge
~
of, the operations of the particular facility and who rotates with the shift.
However, for this job' function to be of optimal use to the shift supervisor, the position should be defined so that the reporting lines t
are unambiguous.
Specifically, the position incumbent should be 1
2Cobb, B.
B., Young, C.
L.,
and Rizzuti, B. L.
Education as a Fa ctor in Selection of Air Traf fic Controller Trainees.
FAA Of fice of Aviation Medi cinc, FAA-AM-76-6.
See Melber, B. D., Wood, M. T., Buller, P. F., and Shikiar, R.
~ 3 Alternative Approaches to Establishing Personnel Qualification f
Requirements:
Considerations for Nuclear Power Plant Operations.
Battelle Human Affairs Resedrch Centers, 1980.
This is the background report prepared for the Panel and is shown in Appendix B.
l l
(
m;;
e.
x o
-T s
s
- 10. L' i
1 repor, ting to the person mos't directly_ responsibic 'for the plant safety, i.e., - th e shi f t supervisor, whenever a situation arises auch that the SS judges engineering expertise is required.- It is also recognized that there are n,ot likely to be sufficient engineering related functions to be performed routinely on shift in the control room.
Thus, there is no need to require the position to be in the control room at all times.
To the contrary, under normal operating conditions it is expected that the individual would be performing tasks of an engineering nature.
The routine engineering functions the shift engineer would perfona would be determined by the individual utility; it is recognized that there is likely to be variability in the job duties of shift engineers at different. utilities.
However, whenever his or her assistance is requested by the shift supervisor, the person reports to, and takes directions from, the shift supervisor.
There should be little s variability among utilities in this aspect of the shift engineer's duties.
For the job position to be optimal for the position incumbe'nt, it'
-should be part of an attractive career path.
For exenple, the position l
l s-l could be defined so that it affords an upwardly mobile engineer an l
opportunity to serve for a period of time on shif t.
With this type of l
operational experience in the engineer's background, he or she should be that much more attractive for higher level positions in the utility.
The position of shift engineer is definitely viewed as a career step rather l
.than a: career goal.
Nonetheless, the Panel deems it e:sential that the e-i inecmb ent of' this ' position have both relevant engineering experience and l
)
I
' training, and to have demonstrated knowledge of operations. by at least l
s j
l being certified as equivalent to an RO.
i i
,.-c_
11 In sum, the Panel views the positior m.dn ' cussion to be so different from the current STA position in terms of reporting requirement, operational knowledge, engineering experience, and career path that it simply recommends abandoning the present STA requirement and instead replacing it with a " shift engineer" requirement having the featurer described above and detailed in the chart on page 17.
The Panel recognizes that tite shift aspect of. the shift engineer.
position is likely to be unappealing to potential candidates for the job.
However, whereas it is desirable to have the RO, SRO, and SS positions' be careers for individuals, this is not necessarily the case for the shif t-engineer position.
Thus, the negative effects of high turnover and recruitment difficulties which, in part, led the Panel to recommend -against degree requirements for any of the current operations crew, are not likely to be problematic for the shift engineer position.
An individual would be at the shift engineer career step for only a relatively brief period in his or her career.
Finally, it should be noted that the Panel considered whether the required engineering expertise could be fulfilled by having the SS be a degreed engineer. ~0n the basis of the information available, the Panel t
felt that the SS was likely to be too occupied during an off-normal situation to utilize his engineering expertise optimally, and thereby concluded that the engineering expertise should reside in tlie shift engineer, even if the SS also has engineering expertise.
However, it is also recogni cd that the job task analyses currently being perforced for SS positions will result in additional information which can be brought to bear on 'this issue.
A
e d
12 Accreditation of Training Programs With respect to training, the present Penel members are not experts in designing training curricula for nuclear power plant operations personnel, and indeed were selected for entirely different reasons.
There fore, the Panel would not be so presumptuous as to recommend the specific courses and course contents for nuclear power plant training programs.
However, the Panel strongly suggests that utility training -
programs should be accredited and that the NRC should be involved in the accreditation program. ' The nature of the NRC involvement in this accreditation process can take a variety of forms, from actual NRC accreditation to NRC oversight of the accreditation activities of some other crganization (e.g., INPO).
In any arrangement, the job-relatedness a
of the training program should be an important part of the accreditation 3
evaluation.
As indicated in a later section, job task an lysis can play an instrumental role in evaluating the job-relatedness of a training program.
It is through such an accreditation process that public confidence can be built concerning the qualifications and training of nuclear power p1' ant personnel.
Lnposition of a degree requirement is not a substitute for this accreditation.
I
{
l Experience Requirements f6r begreed Shift Supervisors l
The Panel. recognizes that a college education in a relevant field is not without value in understanding and operating a nuclear power plant.
Mo'reover, there currently exists and is likely to continue to exist a small percentage of baccalaureate level engineers who do find nuclear power plant operations to be an intrinsically interesting and rewarding Hence, the Panel's frfth recommendation serves b'oth to allow career.
e
13 recognition of the value of an appropriate baccalaureate degree and to act as an incentive to degreed individuals.
Spe cifically, for an SRO without a technical baccalaureate degree, the requirement is three years nuclear power plant experience, one year as an RO, and six months as an i
RO at the facility for which he will be licensed.
An SRO with a technical baccalaureate degree requires only two years of nuclear power plant experience, six months experience at the facility, and six mondhs.
on the job training as an RO at the facility.
The tra'ining requirements for the two different types of SRO are the same:
the accredited (see Recommendation 4) SRO training program, simulator training, and three months on the job training as an SRO.
It is worth reemphasizing, however, that wh'ile the Panel believes a mild incentive for the relatively few degree holders who want to pursue a career in nuclear power plant operations is of value, the Panel also believes, for reasons elready discussed, that the imposition of a degree requirement is ill-advised.
Job' Task Analysis t
Job task analyses, includi g procedures for specifying task-level n
knowledge requirements, form a ' finn technical basis for making informed decisions concerning job design, experience requirements, training requirements, qualification standards, testing, licensing, and requalification programs, and other aspects of the personnel system.
In the opinion of the Panel, the INPO analyses will provide an acceptable description of the generic operator knowledge requirements for a large proportion of all operator task requirements.
However, job task analyses are not usually capable of providing detailed task descriptions of tasks 4
7
,,,,.-,,y
~,, - -, -
-w
~
w
-=
- -- -^'-~' ~'*'*
- " " - - - - ' ^ ^ ^ ^ ^ ^ ^
14 l
required in the performance of functions which are unexpected or novel.
In addition, a more complete listing of knowledge recairements at a given site will require that the individual utilities perform site specific job task analyses to obtain the site-specific knowledge requirements.
These should then form the basis for utility training programs.
As part of the process of accrediting training programs, the relation between training content and job task analysis derived knowledge requirements should be investigated.
The sense of the Panel is that their recommendations be reevaluated once the results of the job task analyses being performed by INPO and' being sponsored by the NRC are complete.
If the job task analyses strongly indicate that the knowledge requirements or task demands for any of the positions of RO, SRO, or SS are best accommodated by imposition of a baccalaureate degree, the Panel recognizes that such a judgment would 2
i be based on more and better information than was currently available.
However, in the absence of the job task analyses data, it is the st'rong sense of the Panel that the potential disadvantages of imposing a baccalaureate requirement for operators far outweigh the possible benefits of such an action.
l Issues Related to Qualifications In the course of its deliberations, the Panel perforce examined a number of issues other than operator qualifications.
It must be il recogni=ed that qualifications issues are inextricably tied to other I
aspects of nuclear power plant operations, e.g., the control room design and configuration, training practices, licensing and requalification examinations, turnover, etc. -Recommendations concerning 'any one part of
,--r
,,,-.,.--,-..---,,,i--c
---..r--v-y
~,-r-,v-
,, - - - - + - - -
--m-w,
15 the system may have an ef fect on other ' parts of the system.
Thus, it is imperative that the IRC examine system effects in all of its recommendations, including those for personnel qualifications.
One aspect of the system that is closely related to personnel qualification.- is the licensing examination program.
Like many other
~ 'consnantators of this program 'the Panel is concerned iaith the
~ ~ - - - ~
psychometric soundness of these ' examinations.
The examination should be,
~
job-related (based on job task
- analyses, when availabl'e), standardized, and place heavier reliance on simulators.
The Panel endorses NRC actions to upgrad'e this program.
Another thread common to many aspects of the qualifications and related issues is that of operator performence measures.
The NRC should support research and development of operator performance measures that are standardized, objective, and job related (based on job task ' analyses, when available).
Such measures are essential for evaluating qualifications requirements, training outcomes, and job performance.
Similarly, research to determine the extent, effects of, and l/*
mitigating strategies for vigilance and stress problems in nuclear power plants should be undertaken.
Research performed in other contexts on
'such topics as short-term memory, multi-modal processing, and job aids might be an appropriate starting place.
Compounding the potential stress l
and. vigilance problems, and indeed central to much of the previous discussion, is the shift-work aspect of running nuclear power plants.
The NRC should encourage utilit: aanagement action to alleviate shift l
work-problems in the industry and to use an increased number of shifts.
4 e
l i
l
~
J 16 Finally, the Panel took as a given the control room jobs as currently implemented.
The NRC should support a fresh look at these positions via an examination of the job design involved in operating a control room.
This can lead to a consideration of reorganization of crew functions in the control room.
Summary' Chart of ' Recommended Qualifications for'RO;'SRO, SS; 'and Shi ft ' Engin'eer ' (SE)
The Panel adapted its chart from the one presented' to the Panel at its January meeting by'Mr. Denton as part of his explanation of the January,1982 Staff Position.
The present chart differs only slightly from the 1/82 staff p~osition in the RO and SRO positions.
The Panel's.
chart does not contain a line for SS, since' assumed in the Panel's recommendation is that an SS is an SRO appointed by utili y management to the supervisory position.
Thus, requirements for an SS are the same as those for an SRO.
The Panel's chart also includes the proposed qualifications for the shift engineer position.
l l
l l
I I
I l
l
17 I
l Position Education Requirements Experience Requirements Training Requirements RO High School Diploma 2 Years NPP RO Training Program 1 Year at Facility Simulator Training 6 Months Auxiliary 3 Months OJT as RO Operator at Facility SRO With High School 3 Years NPP SRO Training Program Diploma l' Year RO
~
' Simulator Training c_
6 Months RO at Facility.
3' Months 0JT as SRO With Technical B.S.
2 Years NPP SRO Training Program Degree 6 Months'at Facility Simulator Training 6 Months OJT as RO at 3 Months OJT as SRO Facility 2
SE Baccalaureate in 2 Years Relevant RO Certification at Engineering or Engineering Experience
, Facility Related Field With Current STA Training Engineering Experience Requirements Note:
SS has same requirements as SRO.
The position is filled at utility discretion.
The only additional training requirements should be an accredited management training program.
(See Recommendation 4 regarding accreditation.)
1
~~2-"
.Unless specified 'othe' wise, experience and training requirements are as r
~~ ~
opecified in the Denton letter of March.28, 1980.
For example, the RO training program is one which satisfies 'the requirements set forth in the Denton letter.-
2For purposes of the shift engineer, relevant can be defined as two years post-baccalaureate engineering experience at a nuclear or fossil power plant or other experience which can be shown to be directly relevant to NPP operations.
e 9
O e
a'
~- -
1 1
e APPENDIX A f
9
\\ /
e S
O e
e
CONSULTANTS PANEL FIEMBERS Dr. James 0. Boone Mr. James Bohannon Chief, Systems Analysis Research Manager, Nuclear Training Section Aviation ' Psychology Laboratory Carolina Power and Light Civil Aeromedical Institute (FAA)
HE&EC P.O. Box 25082 Route 1, Box 327 oklahoma City, OK 73125 New Hill, NC 27562 (405).686-4846 (919) 362-8633 Mr. Nick Catron Dr. Thoms.s Cochran TVA POTC Natural Resources Defense Council Box 2000 1725 I Street, N.W.
Dnisy, T1t 37319 Washington, D.C.
20006 (615) 842.0148 (202) 223-8210 Dr. R..Bruca. Gould Mr. Bruce Diest
- ChieffPerformance.*Ev=1"="+an__
Manager, Nuclear Operations
~-
Section Power Authority of the State of Manpower and-Personnel:.Research New York Division 10 Columbus Circle USAFi Human 1tesources T=har=*ary New York; NY 10018 Brtoks Air Torce Base (212) 397-2397 S n Antonio, TI 78235 (512) 536-3570 Dr. D. Wayne Jones Center for Nuclear Studies Mr. Paul Katz Memphis State University Assistant.. Director for Memphis, TN 38111 Standards Development (901) 454-2687 Office of Personnel Management 1900 E Street N.W.
Dr. Robert Mackie Wrahington, D.C.
20415 Human Pactors Research (202) 632-4516 5775 Dawson Street Galeta,.CA 93117 Lt. Cdr. Jerry.0 wens (805)964-0591 i
Head, Human *=darznance Sciences Department.
Dr. Randall Pack NLval Aerospace Medical Research.
Institute for Nuclear Power Laboratory Operations Ntval Air Station 1820 Water Place Prnsacola, FL 32508' Atlanta, GA,30339 (904) '452-3656 (404) 953-3600
.Dr. James Regan (ch=4v==n)
Mr. Paul Shoop Navy Personnel Research and International Brotherhood of Development Center Electrical Worke'rs Code P00 1125 15th Street, N.W.
Sen Diego, CA 92152 Washington, D.C.
20005 (714) 225-7106 (202) 833-7000 i
l
(
e a
e,~_,,4, m,
y y.,..,
y
i i
APPENDIX B 2
~
r O
e O
4 6
e 4
h-.--..-,-
g t-. - -.,--w- -.., _ _- -.,,
..m
.,v.-,
.m.
--+
r, c.----.