ML20108A847

Supplemental Response to Licensee Interrogatories U-15,U-20 & U-43.Certificate of Svc Encl.Related Correspondence

ML20108A847
Person / Time
Site:	Crane
Issue date:	11/09/1984
From:	Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:	GENERAL PUBLIC UTILITIES CORP.
References
CON-#484-148 SP, NUDOCS 8411150229
Download: ML20108A847 (20)

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November 9,.1984-Skbi!!O

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-UNITED STATES 10F AMERICA NUCLEAR REGULATORY COMMISSION'

'84 K! 15 ' A!125 I-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD CIFICE CF SECREiARv 000XEitNu r SEPvir.C 58MNH

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j In the Matter of-

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METROPOLITAN EDISON CCMPANY-

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Docket No. 50-289"SP" ~ ~ ~"

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(Restart - Management Phase)

(Three Mile Island Nuclear

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Station,' Unit No. 1)

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UCS' SUPPLEMENTAL RESPONSE TO LICENSEE'S INTERROGATORIES U-15, U-20 AND U-43 UCS has reviewed Licensee's Interrogatories and UCS' previous responses fer the purpose of determining which responses UCS can supplement at this time.

Based upon:that review, UCS provides the following supplemental responses:

U-15.

Yes.

UCS believes that simulator training is necessary because it is the only testing of assessment mechanism that approaches actual plant experience for these operators.

By this response UCS does not intend to state any opinicn as to the adequacy of GPU's particular simulator testing.

U-20.

UCS believes that the examinations are not properly validated nor is their reliability established.

UCS also

' believes that Licensee's oral examinations.are administered by individuals who are not adequately trained to do so, and that the criteria for grading oral examinations are unstated and

]

apparently utterly subjective.

l 8411150229 841109 i

PDR ADOCK 05000289 j

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U-43.

UCS intends to call.Dr. James J.

Regan.

(a)'

Dr. Regan's : testimony concerns the ' design and evaluation of-a personnel performance system.

(b)

Dr. Regan's resume is attached.

(c)

Dr. Regan h,as has no prior relationship to or 4

contracts with UCS.

Dr. Regan's sole relationship to UCS is his agreement to prepare testimony for this case.

~

(d)

Dr. Regan has drawn on h'is background, experience and knowledge.

He has been provided to date with a number of documents in this proceeding.

While these are not'" technical" n--

is it yet finally determined how many will be specifically reviewed for the purpose of preparation of the testimony, UCS nonetheless identifies them:

1.

The Special Master's decision of April, 1982 and the ASLB decision of July, 1982.

Pages 3-19 and 62-72 of the ALAB-772.

2.

The Special Report of the Reconstituted OARP Review Committee, June 12, 1984.

3.

The testimony on training issues filed by GPU in this remanded proceeding.

4.

The depositions of Mssrs. Uhrig, Gardner, Ross, Long, Coe, Newton, Leonard.

l3 5.

Memorandum from B.P.

Leonard, Operator Training Manager Ij to Operator Training Section, January 27, 1984.

6.

Operator Training Instructor Indoctrination Qualification i

f' Training Program, Rev. 1, April 26, 1983.

li 7.

GPUM Instructor Development Program, Draf t May 15, 1984 N

8.

TMI Training Department Instructor Evaluation Procedure, ii Rev.

1, August 9, 1983.

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9.

Licensed ~ Operator Requalification Program Description, f

. June 12, 1984, 6211-ADM-2611.01.

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10. Replacement Operator ~ Training Program Description,

.i approved. July' 31, 1981, 6211-ADM-2611.04.

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11. GPU internal memoranda concerning Mssrs. Frederick and-olive.

(e)

Dr. Regan has 'not' consulted with anyone concerning the substance of his testimony.

He has'been provided some i

?

reference material by William Montague.

1 tj (f)

See above.

?

(g) - While his testimony is not yet written, Dr. Regan a

/

currently intends to make some use of the following:

John Joyner, et al., Handbook for Individualized Instruction, Human Resources Research Organization, Carmel, Cal., July, -1983 William E. Montague, et al.,

Instructional Quality Inventory,.

4 Navy Personnel Research Development Center, August, 1983.

John Ellis and Wallace H. Wulfeck II, " Criterion-Refenced Measurement in Military Technical Training", Chapter in The Role of Training in Military Personnel Systems (tentative title),

Praeger Press (in press), 1985.

Robert Glaser and Lloyd Bond, eds., " Testing:

Concepts, Policy, Practice and Research," American Psychologist, Vol. 36, No. 10, October, 1981.

In addition, he may refer to some of the material listed in response to (d) above.

(u)

Dr. Regan has these documents.

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By-E lyn R. Weiss HARMON, WEISS, & JORDAN 2001 S Street, N.W.

Suite 430 I

Washington, D.C.

20009 (202) 328-3500 Dated:. November 9, 1984

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RESUME' r

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{*t r t-James J. Regan q

9804 Bonnie Vista Drive La' !esa,. California 92041 Tel:

(619) 460-3681 Date of Birth: 27 August 1924 i

EDUCATION Institution.

Years Degree /Date Major Minor University of Detroit 1942-48 Ph.B. 1948 Psychology English Philosophy Fordham University 1948-57 MA 1951 Psychology None Ph.D. 1957 Psychology None

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University of San Diego

..j f FQ3ITIGN TITLE:

Lecturer.

t "ATES:

Fall '82-W d:

DUTIES:

Teach course in personnel'mana6ement in School of Businers Administratior

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EMPLCYER:

Battelle Human Affairs Research Center.

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POGITION TITLE: Visiting Scientist

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1/83topresent DUTIES:

Technical consultatioit in personnel and mana6ement Sciences and Simulatior.. ;

'a EMPLGYER:

Self POSITION TITLE: Consultant DATES:

8/82topresent DUTIES:

Technical consultation with various industrial and academic organizations in the areas of personnel selection, assignment, training, productivity, appraisal, job design, and simulation for personnel training and performance measurement.

EMPLOYER:

Navy Personnel Re A:.h and Development Center, San Diego, Ca.

1cory Board POSITION TITLE:

Member of S.u

? s DATES:

1982/83 DUTIES:

Assist Navy Personnel Research and Development Center on the formulation and appraisal, of its research program.

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EMPLOYER:

Navy Personnel Research and. Development Center, San Diego, a-California

PdSITION TITLE: Founding-Technical Director DATES:

9/73 to'7/82 t

j-DUTIES:

Provide executive technical direction in the planning, con-duct, and coordination of research?and development activities directed.toward the advancement of the Navy's technological j

- base in the social, education, psychological and management sciences.

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EMPLOYER:

Naval Training Equipment Center, Orlando, Florida r

POSITION TITLE: Chief Psychologist and Head, Human Factors Laboratory; Founding Director, Training Analysis and Evaluation Group

-DATES:

7/66'to 9/73 DUTIES:

Was fully responsible' for developing and managing a program of psychological research, consultation and evaluation in the area of human factors and human learning.- This program included laboratory research, consultation to -engineers, research and development in adaptive training and computer-assisted instruction and experimental field evaluations of training systems.

The staff was made up of experimental and engineering research psychologists. Projects were accomplished both "in-house" and under contract. Originated some proj ects, evaluated and approved submissions from the professional staff, monitored progress and evaluated the final product.

I represented the laboratory 'to the research community and agencies of ~ government.

I functioned as prin-cipal consultant re human f actors in training equipment to various agencies of the Anny and Navy.

As Head of the Training Analysis and Evaluation Group, organized and direc-ted a multidisciplinary (engineers, educators, and psychol-ogists) group of 40 scientists whose purpose was to develop and exploit new analytic techniques f rom various disciplines (e.g., systems engineering) in designing and evaluating major new training systems. These systems embodied what was being learned in the. area of modern educational technology and cost effectiveness techniques.

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JEMPLOYER:

Office of Naval' Research, Navy Department, Washington, D.C.

'p Assistant Head, Personnel and Training Branch j

POSITION' TITLE:-

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DATES:

4/65 to.7/66 e

d personnel.and Training Branch of ONR develops and directs -

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DUTIES:

The H

the' Navy's. contract program in. personnel' research and 'its.

members function 'as principal advisors to 'the Navy and other My duties involved participation with the Branch

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,6 Head. in the' planning and implementation of. the principal '

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'I fundamental personnel research program in the. Navy.

g served,as principal consultant to various government agencies

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in.the area of_ training systems.research; with the Branch

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' ' Head, selected research areas.in-need of special emphasis and

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organized and conducted ~ working conferences of specialists-N-

and edited proceedings; prepared syntheses of personnel fij research and wrote results for publication; managed major

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cooperative operational research programs; and joined with

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Branch Head in developing the major.research program the D0D had in the area. of computer-aided instruction. Functioned as Scientific Of ficer for major programs in criterion research and automated instructional research. Served as alternate.

Study Director, Personnel.Research' Study for the Assistant-Secretary of Def ense(M)'s Consolidated-Training and Education Program Review. This involved a D0D-wide survey of evaluation of personnel research.-

U.S. Naval Training Device Center, Port Washington, New York EMPLOYER:

POSITION TITLE:

Psychologist to Head, Systems Psychology Division DATES:

10/51 to 4/65 In addition to the duties of Systems Psychology Div"ision Head DUTIES:

described immediately.below, I served as principal consultant to the Chief Psychologist, Commanding Officer and Director of the Naval Training Device Center, and other agencies in the area of training' systems research.

I functioned as the tech-nical leader in a Center-wide methodological R&D effort in the area of training system development; functioned with the Chief Psychologist in formulating department-wide research goals.

As Head of Systems Psychology Division, I was responsible for technical and administrative planning, development, assign-control and evaluation of research and consultation

ment, These programs were in operating areas such as programs.

special weapons, guided missiles, tactical and team operations, Research and consultation were in such and nuclear power.

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i areas as human engineering (human servo-systems), educational' b;\\

'e psychology,- training analysis, systems analysis. information g.

theory, decision-making, small ~ group behavior, perceptual

' skills, and complex sensory motor skills.

In addition, vary--

ing amounts of time were spent as Acting Chief Psychologist.

't Indirectly supervised about 40 contract psychologists.

Prior to these. duties, served as Project ' Manager.

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i Dunlap and Associates, 429 Atlantic St., Stamford, Conn.

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' EMPLOYER:

POSITION TITLE:

Junior Research' Associate j-4 3;

DATES:

3/15 to 10/51

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Developed experimental designs for research projects in human.

j DUTIES:

engineering for government and industry, implemented projects d;

I by conducting experiments, field work, writing questionnaires; organized, analyzed and reported psychological data, ~ and wrote i

S technical reports.

EMPLOYER:

Fordham University, New York, New York r

r POSITION TITLE:

Junior Research Associate i

DATES:

6/49 to 2/51 Duties included statistical analysis of data, construction of DUTIES:

systens for qualitative analysis of kinescope recordings, tech-participation in conferences on data analysis techniques, nical report writing and editing. Conducted testing and tele-vision sessions at Kings Point Merchant Marine Academy, constructed, administered and analyzed achievement tests, observed and critiqued educational television sessions.

1 EMPLOYER:

Fordham University, New York, New York POSITION TITLE:

Research Assistant t

DATES:

9/49 to 6/50 This was an honorary appointment on the basis of scholastic DUTIES,:

achievement.

Duties included substitute teaching, organizing graduate school entrance exams, assisting in psychological laboratory courses, and constructing college examinations.

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-EMPLOYER:

Fordham _ University - New York, New York

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POSITION TITLE:

'Research' Assistant h.

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DUTIES:

Honorary appointment on basis of scholastic achievement.-

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Laboratory assistant, examination proctor and grader; reorganized test library.

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PUBLICATIONS n-3 N-Crissy, W.=J.

E. &'Regan, J. J.

. Halo in the employme'nt interview.

Journal of Applied Psychology, 1951,.35_, 338-341.

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' Regan, J. -J.,' Ely, J. H. & Kelley, C.R.

Flying-the submarine.

In Office of N

Naval Research, A decade of basic and applied science in the Navy. Washington:

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ONR, 1957.

Pp. 535-539.

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Regan, J. J.

Tracking performance related to display control configurations.

t; Unpublished doctoral dissertation, Fordham University,.1957.

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?Regan, J. J. L Tracking performance related to display control configurations.

ti Technical Report 322-1-2, January.1959, U.S. NavaCTraining Device Center.

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Regan, J. J.

Tracking ' performance related to display control configurations.

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1960, 4_4,, 310-314.

4 Journal of Applied' Psychology, a

A method for determining training device requirements.

Office Regan, J. J.

of Naval Research: Proceedin'gs of the Fif th Navy Science Symposium, April 1961.

Vol. 2, Pp. 740-749.

w Regan, J. J. & Bishop, C. K s Progccmmed instruction in the Armed Forces--an In S. Margulies & L. D. Eigen (Eds.), Applied Programmed Instruc-overview.

t io n.

New York: Wiley, 1962.

Pp. 59-69.

Regan, J. J.

Automated instructional hardware and software: An overview.

Proceedings of the American Institute of Industrial Engineers,. Inc.,1964.

Pp. 325-330.

Regan, J. J.

Navy plans for computer-assisted instruction (CAI). National Security Industrial Association:

Proceedings of the Engineering Systems for Education and Training Conf erence, 1966. Pp. 145-147.

Regan, J. J.

Computer-assisted instruction (CAI): Some facts and fancies.

Washington University, School 'of Continuing Education, Research Publication Number 11, 1967.

Pp. 38-49.

Regan, J. J.

New outlooks in training:

A discussion. Manpower Research, N. A. B. Wilson (Ed.) London:

English University Press, Ltd.,1969.

Pp.

364-375.

Regan, J. J.

Special Editor, Special Issue: Adaptive Training, Journal of the Human Factors Society, Dec. 1969, Vol. II, Number 6.

Blaiwes, A. S. & Regan, J. J.

An integrated approach to the study of learn-ing, retention and transf er--a key issue in training device research and development. Technical Report IH-178, August 1970, Naval Training Device Center.

Engineering systems in education and training. A report on Regan, J. J.

the.1970 (Lith) Annual IEEE Man-Machine Systems Symposium, November 1970.

. Applied ErLonomics, London, June 1971.

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A roundtable by mail. Human Factors:. Theory and Practice, j

David Meister (Ed.).

New York: Wiley-Interscience, 1971.

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I Bryan, G. L. & Regan, J. J.

Training system design. ' Human engineering j

guide to equipment design. Washington: GPO, 1972.

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Blaiwes, A.

S., Puig, J. A. & Regan, J. J.

Transfer of training and the 1

Human Factors, December 1973.

measurenent of training effectiveness.

Regan,' J. J.

Components of human-performance and training system design.

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Presentations and Technical Notes from the Applied Learning Systems Cur--

l riculum Requirements Symposium, Washington: American University, 11-12

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March 1975.

j-Military Training. Devices - Progress and i-Blaiwes, A. S. & Regan, J. J.

Chapter in The Role of Training in Military Personnel Systems 1

Issues.

(Tentative title). New York:

Praeger Press (in press), 1985 l

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d PRESENTATIONS 1960.The Role.of the Monitor in Federal Research.

Paper read at'the Ill..

.j American Psychological Association Convention, Chicago, 1961 Training Analysis Methods. Paper read,at Anti-Submarine Warfare Symposium, New York, N.Y.

. Human Engineering at the Naval Training Device ' Center. Paper read at 1962 the-Human Factors Society meeting, New York, N.Y.

1962 A Scheme-for Training Systems Analysis.

Paper read at Anti-Air Warfare Symposium, Norfolk, VA.

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' 1964 Methods for Task Analysis. Paper read at. Hwnan Factors Society annual meeting, Washington, D.C.

1966 Computer'-Assisted Instruction.

Presentation'to American Management Association's Continuing Seminar on Management Information Systems, Boca Raton, FL.

1967 Computer-Assisted Instruction.

Presentation to Naval Research Reserve Unit, Orlando, FL.

1967 Computer-Assisted Instruction. Presentation made to Industrial College of the Armed Forces /U.S. Military Academy Computer Workshop sponsored by the ICAF and USMA and held at West Point.

Remarks videotaped for subsequent review by interested activities.

r 1967 Participated.in a Symposium at the North Atlantic Treaty Organization Conference on Manpower Research in the Defense Context.

London, England.

1967 Educational Technology. Presentation to Data Processing Management Association, Winter Park, FL.

1967 Changing World of Training Research.

Invited lecture given at Naval Academy.

Presentation to State 1968 Computer-Assisted Instruction--An Overview.

I Conf erence, American Society for Training and Development, Orlando; FL.

1968 Learning Research and Training Practice. Presentation to Central Division, American Society for Training and Development, Orlando, FL.

4 1969 Workshop on Programmed Instruction given at American Hospital Association Regional meeting, Miami, FL.

1969 Faculty member and lecturer, American Hospital Association seninar on Leadership f or Florida Hospital Auxiliary presidents.

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19.70;. Motivation and Interpersonal Relations in a Leadership Context. 'Presen-

.tation to American Hospital Association seminar, Orlando, FL.

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.1970 Learning and Transf er Issues in the Design of Training Systems.

h tation to the NATO ' Advanced Study ' Institute, " Greenwich, England.

.1972 - Organized and ' chaired. a Symposium on Special Skill Training at the annual meeting of the Southeastern Psychological Association,. Atlanta',

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1973 Learning Theory 'and Training Practice.

Invited address at annual meeting of American Psychological Association, Montreal, Canada.

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19%/85 One-day" seminars at University of Csstral Florida.

Title:

'The

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Design of Training Systems.

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.1-N PROFESSIONAL SOCIETIES t

American Association for the Advancement of Scienc'e t,.

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Nl New York State Psychological Association 3.

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Eastern Psychological Association j

i Senior Member.. Institute 'of E1cetrical and Electronic. Engineers if.

R Human Factors Society 0

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The American Educational Research Association

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Nj-Sigma Xi-

.?ellow, American Psychological' Association Ergonomics-Research Society

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' MISCELLANEOUS-RECOGNITION (e'.g., Honors, Awards, & Committee Appointments) 1949-51 Graduate Research Assistant; three appoints--Spring ~ 1949, academic ly' ear 1949-50, academic year. 1950-51.

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1962' Chairman, Symposium on Special Training Problems, New England Psychological Association,- Boston, Mass.

lI 1962-63 Member Program Committee of the Society of Engineering Psychologists of the American Psychological Association.

19641 Chairman Program Committee of the Society of Engineering Psychol-ogists of the American Psychological Association.

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1968 Chairman of Plenary Session on Adaptive Training, New England Psychological-Association annual meeting, Boston, Mass.

ja 1969 Invited to ' address joint meeting of IEEE (GMMS) and Ergonomics Society held.at Cambridge University, United Kingdom. -(declined)

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1970 General Chairman 1970 IEEE Man-Machine System Annual Symposium, Winter Park, FL.

1971 IEEE Engineer of the Year for Central Florida.

Current Registered Psychologist, New York State 1966-69 Member, Computer-Assisted Education Advisoryz Board, Naval Academy, Annapolis, MD.

1968-71 Member, Administrative Committee of the Systems, Man and Cybernetics Group of the Institute of Electrical and Electronic Engineers.

1970-73 Member, National Academy of Sciences, National Research Council.

Armed yorces - NRC Committee on Vision: Working Group on Visual-Requirements for Cockpit Simulators.

1971 Member, The U.S. Army Armor School Advisory Committee, Fort Knox, KY.

1971 Chairman, Session on the Roles and Controls of Personnel Research and Development in the D0D at a Symposium / Seminar on Personnel Research and Development Planning and Management at Temple University in Philadelphia, PA.

1972 Session Chairman, Target Acquisition Symposium, Office of Naval Research sponsored meeting, Orlando, FL.

1973-75 Member Membership Committee, Society of Engineering Psychologists, i

American Psychological Association.

5 1974 Member, Advisory Committee on Human Resources Research and Develop-ment, Naval Air Systems Command, Washington, D.C.

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i 1974!

~ United States Representative to 10th dpplied Military Psychology Symposium, West Germany.

1975 Chairman of Sympo'sium, Evaluation of Basic and Applied Research,

. American Psychological Association of ' Elgnty-Third Annual Convention, i'

Chica go, IL.

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'1980-Chainnan, Fellows Committee,' Society of Engineering Psychologists,

- American Psychological-Association.

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Chairman, Membership Committee, Society of Engineering Psychologists, r

1981 j ' American Psychological Association.

t 1981-82 Chairman of National Advisory Committee to Nuclear Regulatory

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Commission-Committee advises on personqol qualifications matters.

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Member of National Advisory Committee to Nuclear Regulatory Commission;-

1983 i -

Coanittee addresses our simulator requirements for nuclear pcwer plant -

operators.

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Current Licensed Psycholo6 st, California.

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HONORS, AWARDS IN THE FEDERAL SERVICE v.

Federal Service Outstanding Perf ormance Rating:

.1956-

'1976 s

$. J 1960 1977 1961 1978

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is 1962 1979 jj 1975 1980 Sustained Superior Performance:

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1974 1979

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_f Naval Training Device Center moninee for Federal Business Association's 1960 Award for Outstanding Federal Service 3;.

E 1960 Naval Training Device Center nominee for William A. Jump Memorial Award Naval Training Device Center nominee for Federal BuYiness Association's

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1961

'I Award for Outstanding Federal Service -

1961 Naval Training Device Center Alternate ncminee for National Civil Service League Career Service Award 1962 Naval Training Device Center and Office of Naval Research nominee for Arthur S. Fleming Award l

1982 Navy Superior Civilian Service Award

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November 9, 1984 1,

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• &f' o,.iO UNITED STATES OF AMERICA hl,*3

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NUCLEAR' REGULATORY COMMISSION

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In the Matter of

)

j

)

j METROPOLITAN EDISON COMPANY '

).

Docket.No. 50-289

)

)

(Restart Remand on.,

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d (Three Mile. Island Nuclear

)

'Ma nag ement)

)

Station,' Unit No. 1)

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1

j CERTIFICATE OF SERVICE I hereby certify that copies of the UCS' SUPPLEMENTAL RESPONSE TO LICENSEE'S INTERROGATORIES U-15, U-20 AND U-43, were served on the following by deposit in The United States mail, first class, postage prepaid, on/ November 9, 1984.

Ellyn R. Weiss

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- '4 UNITED STATES OF AMERICA NUCLEAR REGULATORY. COMMISSION

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BEFORE THE ATOMIC-SAFETY AND LICENSING BOARD

'In'the Matter of

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)

il METROPOLITAN EDISON COMPANY

)

Docket No. 50-289 j

)

(RestartfRemand on J(Three Mile Island Nuclear

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Management)

Station, Unit No. 1)

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SERVICE LIST

~~

h'AdministrativeJudge l Gary J.

Edles, Chairman Jack R..Goldberg, Esq.

i Atomic Safety & Licensing Appeal Bd.

Office of the Executive Legal Dir.

i U.S. Nuc' lear Regulatory Commission U.S. Nuclear Regulatory Commission j,Wesnington, D.C.

20555 Washington, D.C.

20555 j

Administrative Judge

,Jonn H.

Buck Ernest Blake, Jr. Esauire

' Atomic Saf ety & Licensing Appeal Bd.

Shaw, Pittman, Potts & Troworidge'

U.S.

Nuclear Regulatory Commission 1800 M Street, N.W.

,Wasnington, D.C.

20555 Washington, D.C.

20036

, Administrative Judge Christine N. Kon!

Ms. Louise Bradford

,' Atomic Safety & Licensing Appeal Bd.

TMI Alert

. U.S.

Nuclear Regulatory Commission 1011 Green Street

' wasnington, D.C.

20555 Harrisburg, PA 17102

', Administrative Judge Ivan W.

Smith, Chairman Joanne Doroshaw, Esquire

_ Atomic Safety & Licensing Board The Christic Institute U.S. Nuclear Regulatory Commission 1324 North Capitol Street i Weshington, D.C.

20555 Washington, D.C.

20002

, Administrative Judge l Sncidon J. Wolfe Mr. and Mrs. Norman Aamodt pAtomic Safety & Licensing Appeal Bd.

R.D.

5

U.S. Nuclear Regulatory Commission Coatesville, PA 19320

] Washington, D.C.

20555 jiAdministrativeJudge Lynne Bernabei, Esq.

,Gustave A.

Linenberger, Jr.

Government Accountability Project

' Atomic Safety & Licensing Board 1555 Connecticut Ave.

'U.S.

Nuclear Regulatory Commission Washington, D.C.

20009 Wcshington, D.C.

20555 Dockoting and Service Section Michael F.

McBride, Esq.

, Office of the Secretary LeBoeuf, Lamb,'Leiby & MacRae

,0.S.

Nuclear Regulatory Commission 1333 New Hampshire Ave, N.W.

41100

• Wa:hington, D.C.

20555 Washington, D.C.

20036

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311chcol W. Mrupin, Ecq.:

Hunten.6 Willicco 707 East Main-Street N

P.O.-Box'1535 Richmond, VA ' 23212

' Thomas Y.-Au, Esq.

Office of Chief Counsel Department of Environmental Resources 505 Executive Houses P.O... Box 2357-

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