ML20248G930

Testimony of H Harris on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re JI-13 & Mag EX-11 (Training).* Harris Resume Encl.Related Correspondence

ML20248G930
Person / Time
Site:	Seabrook
Issue date:	04/10/1989
From:	Harris H CORPORATE RESPONSE GROUP, MASSACHUSETTS, COMMONWEALTH OF
To:
Shared Package
ML20248G923	List: ML20248G919 ML20248G925 ML20248G930 ML20248G934 ML20248G943 ML20248G946 ML20248G960 ML20248H161 ML20248H205 ML20248H267 ML20248H319 ML20248H661 ML20248H688
References
OL, NUDOCS 8904140007
Download: ML20248G930 (20)

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REtATED CUggtWOMM DOCKETED UWC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIOf. 9 Am 11 P5 :58 ATOMIC SAFETY AND LICENSING BOARD; Before the Administrative Judges:

Ivan W. Smith, Chairman Dr.' Richard F. Cole Kenneth A. McCollom

) .

In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP)

OF NEW HAMPSHIRE, EI AL. )

)

(Seabrook Station, Units 1 and 2) ) April 10, 1989

)

TESTIMONY OF DR. HOWARD HARRIS-ON BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH'OF MASSACHUSETTS, CONCERNING JI-13 AND MAG EX-11 (TRAINING)

Department of the Attorney General Nuclear Safety Unit Public-Protection Bureau One'Ashburton Place Boston, Massachusetts;'02108 (517) 727-2200 8904140007'890410 PDR ADOCK 05000443 T PDR I- - . _ _ . _ _ _ _ _ _ _ _ _ . _ _

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i UNITED STATES OF AMERICA ]

NUCLEAR REGULATORY COMMISSION i 1

ATOMIC SAFETY AND LICENSING BOARD i i

Before the Administrative Judges:

Ivan W. Smith, Chairman i

.Dr. Richard F. Cole q Kenneth A. McCollom ]

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In the Matter of ) Docket Nos. 50-443-OL j

) 50-444-OL. l PUBLIC SERVICE COMPANY ) (Off-Site EP) j OF NEW HAMPSHIRE, EI AL. )

)

( (Seabrook Station, Units 1 and 2) ) April 10, 1989

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TESTIMONY OF DR. HOWARD HARRIS ON BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS, CONCERNING JI-13 AND MAG EX-ll (TRAINING) l  !

SUMMARY

OF TESTIMONY '

I In this testimony, Dr. Howard Harris, an expert in the )

field of curricular and instructional design, development, and implementation, as well as the evaluation of training, offers j

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l his assessment of the overall design of the SPMC's training for protective action decision-making, traffic and access control, and EBS message drafting. In his opinion, the design of this-training is fragmented structurally. The available training design documents which pertain to these tasks do not provide-reasonable assurance of linkages between the needs of trainees, the information transmitted'in the classroom, the-drill and-l

_-__________.-____-__O

exercise activities, and'the tasks to be performed in a real

+ emergency. In addition, the classroom testing program is not adequate to provide. reasonable assurance of actual-learning.

He concludes that the SPMC's training for these three tasks is inadequate'and needs to be, redesigned and that, after that redesign occurs and further' training is conducted, the extent of learning needs.to be tested through another exercise which requires those performing these tasks to demonstrate and apply the knowledge learned.  !

l TESTIMONY Q.l. What is your name and current position?

A.1. My name is Howard Harris and I am the Executive Vice i

President of the Corporate Response Group, 1146 19th Street, i

N.W., Suite 500, Washington, DC 20036. '

Q.2. Is a copy of your resume attached to your testimony as Attachment "A"?

A.2. Yes.

Q.3. Would you please summarize your relevant pt-)fessional qualifications and background?

A.3. Certainly. I have more than 22 years experience in management, training, and education. I completed my doctoral; program in education at the Department'of Curriculum-and 1

Teaching at Teachers College, Columbia University (1974). In I

the last 22 years, I have acquired extensive theoretical and i practical experience in curricular and instructional design, development, 'and implementation, as well as the evaluation of training and educational programs at all-levels. Since 1982, I have spent a significant amount of time working in the emergency management training field. Presently, I am responsible for the

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design, development, delivery, and evaluation of all training and education programs at the Corporate Response Group

("CRG"). CRG specializes in worlwide crisis management services that include: risk management, contingency planning, I I

plant and personal security, employee relocation and evacuation, crisis communications, facility recovery and 11 relocation, and training and exercising. j i

I In 1982, I.became the project director for the

.1 Federal Emergency Management Agency's professional development-curriculum project at the National Emergency Training Center.

("NETC") in Emmitsburg, Maryland. While there, my activities included line responsibility for the design, development, pilot testing, and evaluation of NETC's core curriculum. This contract covered a four-year period and included numerous course presentations and emergency planning conferences throughout the United States. These experiences provided me with an extensive knowledge of the training needs of emergency service personnel.

Over the years, I have served as a consultant on many projects and have worked in a variety of adult t.r eir.i ng and education settings. For exampls, I was DeputyLDirector of the National Academy in the Fublic Service at Georgetown University, Washington, D.C. In addition, I conducted' teacher education programs at pace University, Fordham University, and Brooklyn College of the City. University of New York. Finally,

.I have worked in the Ohio and New York public school systems as an administrator, supervisor, and teacher.

i Q.4. What is the purpose of this testimony? I A.4. In this testimony I will address aspects of JI Contention 13, which asserts that the prerequisite experience

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for and the training provided to the NHY-ORO Traffic Guides, l l

the EDS message drafters, protective action decision-makers, and bus drivers are inadequate to provide reasonable assurance that the ORO can and will implement adequate protective 1

measures in the event of a radiological emergency at Seabrook l Station. Specifically, I have assessed the everall design of  ;

the SPMC's training for Traffic Guides, the EBS message l

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l drafters, and protective action decision-makers. (I have not examined the bus driver training.) To the extent that MAG l Ex-11 also raises a challenge to the adequacy of training for l l protective action decision-makers, this testimony is relevant l l to that Exercise Contention as well. I want to emphasize that my testimony addresses the overall training design and not training content. I understand that the Massachusetts Attorney I

General is presenting three other witnesses, each of whom has substantive expertise 1.n one of these three fields, who are critical of the content of the training for these ORO positions and claim generally that the content is inadequate given the minimal prerequisite experience that those recruited for these positions must have.

Q.5. What materials have your reviewed in order to assess the overall design of the SpMC's training for the three ORO functions you mentioned?

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4 A.S. Specifically, I' focused on the training design of three sets of training materials that were prepared for those who are to implement the Seabrook Plan for Massachusetts Communities ("SPMC"). The materials reviewed were: Traffic l

and_. ACnesIL.fDntial, Eublic InformatinD, and - EIntactive Antinn De.cisinns.. I also' reviewed a number of other documents that-  !

i were made available to.me through the Massachusetts Attorney 1 i

General's' Office. They included regulatory items, the.SPMC, other SPMC instructional materials, and the deposition of Donald R. Tai 11eart. He'was the Manager of' Specialty Training.

at New Hampshire Yankee and has signed off: as Training Manager ,

l on many of the SPMC's training modules. I was told that he was the person the Applicants offered when the Massachusetts Attorney General sought to depose the person most knowledgeable I l

about the SPMC's training program.

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Q.6. What did you do next, after reviewing these i

materials?

A.6. After completing an initial review of these documents, I concluded that the SPMC traiping requirements established the need for meaningful verbal learning situations--

which means the basic method of instruction is lecture and discussion. To have meaningful verbal learning situations, a training program needs to be designed'.from start to finish to reflect the intent'of the training and what is known about how we learn. Learning is the desired outcome of any training and education program. I then-sought to determine if the training for these positions met this requirement.

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[- 7 Q.7. How did.you conduct this evaluation?-

-A.7. Three SPMC-related documents were1used as the. basis for evaluating the. training packages referenced above.

Together they describe the SPMC's training intent.and methodology. They were: SPMC, Part 6; SPMC, Appendix K; and Mr..Tailleart's deposition of. November. 10,.1988. SPMC,'Part 6 includes the NHY-ORO training matrix, which describes the training modules provided to each of the NHY ORO positions.

SPMC,JAppendix~K, outlines the requirements for materials development, classroom instruction, tabletops, walkthroughs, drills, and testing. Mr. Tailleart's deposition (p.68) identifies the Institute of Nuclear Power Operations' Training System Development process ("TSD") as the design criteria for the development of ~ the SPMC training materials. SPMC, Appendix K, also identifies TSD as the development methodology (p. I K-9). It is my opinion that Appendix K establishes a training program that is based on verbal learning. A training methodology like the TSD approach still needs to take into 1 I

l consideration the trainees' experience to determine the best I way to facilitate the learning and evaluation process. )

I Therefore, using these documents as my guide to what j the training intent and design criteria were, I evaluated the

' three SPMC training modules--Traffic & Access Control, Public #

information, and Protective Action Decisions-- from the TSD l perspective as described by Mr. Tailleart (pp.69-78) to see if ,

the training which was prepared met those intentions and design '

criteria. However, in doing this evalucation, I have placed i l

l TSD within a broader conceptual framework based on the l

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psychology of meaningful. verbal'1 earning. Learning.is the mental act of understanding new material in the context of how it relates to.or modifies the_ trainees' pre-training knowledge and experience.

Q.8. Do you know which. positions in the NHY-ORO take the r three modules youLhave~just' menti'oned, and are y'ou' familiar with the prerequisite experience and qualificati'ons the SPMC requies for each of these positions?

A.8. Yes. According to the SPMC,'there is no prerequisite experience required for training and qualification as a Traffic Guide. SPMC, $2.1.1, .p.2.1-28. The.Public l Notification Coordinator, who is responsible for the development of EBS messages and the timely and coordinated I d

activation of the public alert _and notification system, is required to have only " experience in public information." Id.

at 2.1-13. There are about six'ORO positions which comprise -!

i the group which engages in protective action decision-making.

.1 There is, first, the ORO Director. The prerequisite experience j l

for this position is " experience as a Vice President or Director." Idm at 2.1-3. Next, there are the-twoIAssistant Directors (one for Response Implementation and one for Support Liaison). The prerequisite experience for these positions is

" experience as_a Director or Manager." Lit at:2.1-5. Then 1 there is the Radiological Health Advisor-, the person in the ORO who is responsible for providing direction and control to the r

ORO radiological assessment staff'and exposure control personnel. The prerequisite experience for this position are u E__ __ ____ - . - - _ - - - - - . - _ - - - - - -

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" experience as a Radiological Department Manager." .Ldm at i 2.1-6. Next'is the Technical Advisor, the person in the ORO )

1 who is responsible.for interpreting plant, operational R i

conditions during an emergency. The prerequisite' experience 1 1

1 for this position is "[k]nowledge of plant operations and systems." Id at 2.1-5. Finally ~.there is the Public-Notification Coordinator, whose prerequisite experienced I noted'above.

Q.9. Should those designing a training program for these three tasks take the prerequisite experience into account and, )

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if so, how?- l A.9. Yes. The focus of any training needs to be on the-difference between what the trainee knows and what the task 1

requires. .Obviously, with this kind of generally' described }

l prerequisite experience, one cannot assume that all trainees  !

bring significant relevant experience to the training for these three specific tasks.

While attendance pre-supposes a-desire on the part of trainees to relate new knowledge to what they'already know, the training materials need to be designed in a way that facilitates this mental process through' verbal interchange and various activities. I believe the TSD approach is compatible

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with the role that learning theory plays in any training design.

Q.10. Is there a psychological learning theory or model l

ohat you applied in doing your assessment?

A.10. Yes. It is a theoretical'model called the psycology of meaningful verbal learning. It is a.model which is based on

. learning research. The basis for the psychology of meaningful

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verbal learning is as follows: The more complex and extensive a body of knowledge, the more difficult it will be to learn.

But, with careful design of the scope and sequence of material, moving from general information (i.e., facts and concepts) to specific issues (i.e., problems and conclusions) difficult learning tasks can be made manageable. Thic approach recognizes at each step that potentially meaningful material is always learned in relation to the relevant concepts, principles and information presented earlier in the training. Thus new l information is acquired through presentation, repetition, l l

l review, reinforcement and directness. During the course of l

repeated exposure--with feedback--to new concepts and ideas and j information, trainees will learn new concepts and skills and ,

l l relate them to their background by seeing, hearing, writing, l

and actually practicing the new concepts and skills. As a i

result, training evaluation procedures can be designed that  !

will aid in refining the training materials, as well as provide feedback that identifies the trainees' strengths and weaknesses. These learning related concerns are consistent with the TSD concepts that were used in the SPMC training requirements as outlined in Appendix K.

Q.11. What is the Training Systems Design, or TSD, process?

A.11. As described by Mr. Tailleart, TSD is a five-step training design process. The steps are: analysis, design, development, implementation, and evaluation. The process is a straightforward and systematic approach to designing training that emphasizes learning from the standpoint of terminal and l

enabling objectives. This approach was, apparently, used by

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the_SpMC' training groups in designing the materials for the three training modules that: I' reviewed--Iraf fic & Access Cont'rol, Public Information, and Protective Action Decisions.

Q.12. Have you assessed the SpMC's training for the three tasks you described with respect to this TSD process?

A.12. .Yes. I would like to explain my findings-by taking the TSD steps one'at a time.

ANALYSIS

. Analysis is the first TSD phase. One needs to take the jobs whi'h c you seek to have the trainees perform and break' them down into their component parts. Although Mr. Tailleart referred to a " paper" job analysis in his deposition, I found no other references to a NHY-ORO job analysis in the materials that I reviewed, nor did I find.any references.to needs or task analysis. More importantly, I found no references to any analysis of the trainees' experience.or their training needs.

In other words, I found no indication that the trainees' pre-training knowledge about the; job requirements were ever ,

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' determined. This is an important fact when you consider that.

the trainees were not professional public safety personnel. I Unless a thorough and complete job analysis has been conducted I

for each of these three SpMC tasks, and the trainees'

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experience and needs have been analyzed, there can be no-reasonable assurance that the training is adequate.

DESIGN i

In this phase, an overall instructional plan is to ,

be developed. However, I found no' references to any overall  ;

instructional plan in any of the SpMC-related training i

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Lb documents that I reviewed. This could mean that no overall i instructional plan existed to describe how the modules will be i

developed, implemented, or evaluated, or how all key l t

information presented in the classroom will be specifically 1 reinforced through walkthroughs, drills, and exercises. It l should be noted that SpMC, Part 6, and Appendix K, explain the training requirements, not the specifics of how they will be completed. A training design document of this type is l considered to be standard procedure in the training and i education field. TSD seems to reinforce this position by emphasizing design after analysis. If the analysis reflects the trainees' needs, the training design should reflect how the needs will be met. As a result, learning theory is critical to meeting the trainees' needs. Since there is, apparently, no overall instructional plan, there is no way to determine if, and no reasonable assurance that, both the the training requirements and learning requirement are being taken into I l

consideration at each step in the SpMC training for these three ]

I tasks.

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DEVELOPMENT I concluded from Mr. Tailleart's deposition that the l I

SpMC's lesson plans developed during this phase were developed to address certain terminal and enabling objectives which were derived from the " paper" job analysis that Mr. Tailleart j i

described. In the instructor guides, the objectives are stated j first, followed by references, then a list of l

materials / equipment, and finally a content presentation outline I i

2 that explains what teaching points to make with each of the j i

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4 transparencies that comprise the student handout. This is

-. clearly a verbal learning situation.>'However, I did not find.

any information that addressed the trainees' needs in a verbal l 1 earning environment. The student handouts contain the objectives'and paper copies of the overhead transparencies, indicating clearlyfthat the training approach;being used here is strictly short term recall. Neither the. instructor guides

nor the student handouts are designed to1 facilitate meaningful ,

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verbal learning within the context' described above. :There l's no design that moves from general to specific, nor'is there

. consistent repetition, review, reinforcement, or concept' consolidation' outlined-in the instructor guides.

IMPLEMENTATION  !

Except for the training matrices in SpMC,.part 6,  ;

and the description of the overall training components in  !

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Appendix K, I found no information describing the instructional linkages that take the information presented during classroom L instruction and apply the information in tabletops, walkthroughs, drills, or exercises. There is no reasonable assurance, therefore, that such linkages exist. In addition, Appendix K does mention instructor skills development, but the emphasis is on guidelines and policies, not learningftheory or .

. specific instructional methodology. Verbal learning depends on.

the instructor. Consequently, instructor training isLa critical.part of any training program. I found no information that would lead me to believe that an adequate a train-the-trainer program exists.

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. 1 EVALUATION l'

.This phase is critical to ensure that learning has occurred and that feedback can be incorporated into the il i

instructional planning process. Appendix K describes the testing requirements. As to the SpMC's testing' procedures, remedial training isEsupposed to.be scheduled for trainees who 1

receive less than 80% on a test. The test' cover sheets present the general examination, instructions.- However, Mr. Tai 11eart states'in his deposition that the tests at the end of the training sessions are open book. An.open book test distorts the value of the test data. No-other. follow-up testing progam appears to exist to determine the retention rate for the recall materials presented during the training' sessions. Such a testingfprogram offers no way to determine if, and no reasonable assurance that, the new information was actually learned or just copied from the handout and other reference material.

Q.13. What are your overall conclusions about the design of the SpMC's training for these positions?

A.13. My overall conclusion is that the training program related to the three modules that I reviewed is' fragmented and therefore offers no reasonable assurance that it is adequate.

Thele is nocreasonable assurance that the three modules were .

designed and* developed from the standpoint of the trainees'  ;

l needs. There is also no reasonable assurance that there'are

,g exact instructional linkages between classroom. instruction, drills, walkthroughs, tabletops, and exercises for the three tasks I have reviewed.

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'h A training design document is critical to the '

success of any training program, and one doesn't seem to exist for this program.

The testing program does not provide an accurate representation of what is being learned. There is no reasonable assurance that the psychology of meaningful verbal learning was ever taken into consideration in the development

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of these modules. Nor is there reasonable assurance of any 1

l instructional link between classroom instruction and specific drill and exercise activities. All of these items are critical to an evaluation program.

L e a r n i n g t h.:. ry has to be a critical element of a I training program if trainee learning is to be taken seriously.

In my judgment, the three training modules are fragmented l structurally. There are no linkages between information and application. The most critical question to ask is whether this 1

information was in any way applied during the Federal Emergency Management Agency (FEMA) exerci 97 There is no reasonable assurance that it was. In my opinion, the SpMC's training for I

these three tasks is inadequate and needs to be redesigned. I Then, after the training is redesigned, and it is provided to s

i the relevant ORO members, the extent of their learning needs to l be tested through another exercise which requires those who perform these tasks to demonstrate and apply the knowledge 1

l l learned.

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0 ATTACHMENT 1 l l

BONARD HARRIS l CORPORATE RESPONSE CROUP 1146 19th St., N.W., Suite 500 Washington, D.C. 20036 (202) 775-0177 EDUCATION Ed.D., Supervision and Leadership, Columbia University, 1975 Ed.M., Supervision and' Leadership, Columbia University, 1974 M.A., Educational Administration, University of Akron, 1969 A.B., History and Speech, West Liberty State College, 1964 '

AREAS OF EXPERTISE o Administration o Training o Project management o Marketing o Emergency management o Media relations i o Curriculum development o Policy analysis o Instructional design o Research  !

e organizational development o Applied learning  ;

technology EXPERIENCE

SUMMARY

l More than 22 years of experience in management, training and education, community relations, development of public policy, and local government. Adept at working with elected and appointed 4

officials, executives, managers, and content and technical experts in diverse situations. Extensive experience in public speaking and facilitating large and small groups in a variety of mattings.

SPECIFIC _EZoERIENCE Executive Vice President, Corporate Response Group. Executive responsibility lar administration, marketing, and training and education prograts. Corporate activities' include assisting private and public sector organizations in preventing, preparing for, managing, and recovering from crisis situations. Areas of expertise include: risk analysis, contingency planning, government affairs, media relations, plant and personal security, employee relocation and evacuation, emergency medical evacuation, crisis communications, facility recovery and relocation, negotiation and litigation support, and training and exercising. l Client projects have included emergency preparedness audit for a l major oil company, internal and external communications audit for the National Institute of Drug Abuse, and design and development of training and course materials for the U.S. Department of State's Senior Crisis Management Course.

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$DBcTFIC EYDERTEMcE (cantinnad_)

Division Vice President; IMR Systems Corporation; Communication, Management and Training Division. Executive responsibility for directing all division activities within a $6 million corporation. Corporate activities included: marketing, contracting, budgeting, recruiting, wage and salary, and employee relations. Client activities included such projects as dynamic simulation for the U.S. Air Ferce, crisis management for the American~Public Works Association, and leadership training for the Division of Transit Services, Montgomery County, Maryland.

Participated in development and delivery of the Washington Metropolitan Area Transit Authority's Effective Management Training Program. Conducted a' series of Public Policy in-Emergang Management seminars in cooperation with numerous institutions and organizations, includings o School of Administration, University of Southern California; o School of Justice, University of Alaska; o Carl Vinson Institute of Government, University of Georgia; j o John F. Kennedy School of Government, Harvard University; o L.P. Cookingham Institute of Public Affairs, University of Missouri; o Lyndon B. Johnson School of Public Affairs, University of Texas; o National Association of Counties; o and the International City Management Association.

Managed and conducted emergency management courses and conferences in all 10 federal regions and Puerto Rico. Managed the delivery of supervisory and emergency management training programs in numerous states including: Delaware, Iowa, Maryland, Minnesota, and Oregon, and the District of Columbia. Served as project director for the Federal Emergency Management Agency's professional development curriculum project at the National Emergency Training Center (NETC). ' Served as senior associate faculty member at NETC's Senior Executive Policy Center.

Designed, developed, pilot tested, and conducted NETC's l Formulating Public Policy in Ruarcancy Manme===nt course.

Designed, developed, and conducted portions of NETC's Intearated Enareancv Manacament course dealing with public policy and media relations. Conducted Public Policy in Emergency Management presentations for senior-level cabinet ministers from Costa Rica and senior staff members of the Egyptian Army.

J Howard Harris (Page 3)

EPff;IFIC EYDNBTENCE (continuam Deputy Director National Academy in The Public Servios, Georgetown University Granuate School. Designed, developed, conducted, evaluated, and marketed a nationwide training and consulting program to improve state and local government by responding to the needs of citizen politicians--those holding elective or appointive office while still maintaining full-time privats careers independent of their community leadership roles.

Materials and services increased citizen awareness of the importance of citizen politics as a critical part of the democratic process within the federal system and encouraged greater citizen participation in community decisionmaking.

Served as managing editor of a series of publications on state and local government that included: Education for en==unftv LSadershin, Financina Local Government, Innrovina Manaaerial Skills in Local Gevarnment, Indiana Etate Government, Lgggl Economic Plannina and Manacament, Local Govern =mnt Accountancy, Local Government Budaat Pranaration, Local Government Productivity, Public and Media Relations in Local Government, and Undarstandina Federal Assistance Procramm.

Consulting Experience. Designed, developed, and conducted management- and economic-related training seminars for The communications Workers of America. served as a staff member of The Communications Workers of America Annual Leadership School at Pennsylvania State University. Completed a personal and family financial planning project in teacher education for the American Council of Life Insurance. Designed a series of energy assistance training seminars for minority elected officials at the center for Urban Environmental studies. Designed and developed career education programs for the New York state Department of Education. Designed and developed a career education performance-based teacher education program for Marymount Manhattan college, completed a nationwide survey of nonprofit management training programs for the United Way of America.

Additional Higher Education Experiences Pace University, Fordham University, and Brooklyn college of the City University of New York. Served as administrative assistant to the dean. Taught courses related to history, philosophy, sociology, research, supervision, leadership, curriculum development, and instructional desi Designed a competency-based teacher education program.gn. Supervised teacher education programs in the ,

l New York City public schools. l 1

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Howard Harris (Page 4)

I Public Education Experiences Chio and New York. Served as administrative assistant to the superintendent. Directed activities related to all aspects of school system management.

Served as media relations director. Hosted a monthly educational television program. Managed campaigns to obtain voter approval of operating levies and bond issues. Served as a program j director and department chairman, served as supervisor of l curriculum and in truction. Participated in adult and community )

education programs. Taught American Government and American i History. l Other Experience. Served on numerous community boards and  ;

committees over a 22-year period. Served in the U.S. Navy. l Member of Phi' Delta Kappa, Columbia University chapter, and the j American Defense Preparedness Association.

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