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CCASE:
ATOMIC ENERGY COMMISSION
DDATE:
19670408
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[1] UNITED STATES DEPARTMENT OF LABOR
WAGE APPEALS BOARD
In the Matter of
ATOMIC ENERGY COMMISSION WAB Case No. 67-06
Petitioner
IDAHO NUCLEAR CORPORATION
Petitioner,
and
OIL, CHEMICAL AND ATOMIC WORKERS
INTERNATIONAL UNION, AFL-CIO
Intervenor, Davis-Bacon Coverage
and of LOFT Reactor, Idaho
BUILDING AND CONSTRUCTION TRADES
DEPARTMENT, AFL-CIO,
and
INTERNATIONAL BROTHERHOOD OF
ELECTRICAL WORKERS, AFL-CIO,
and Dated: April 8, 1967
UNITED ASSOCIATION OF
JOURNEYMEN AND APPRENTICES
OF THE PLUMBING AND
PIPEFITTING INDUSTRY OF THE
UNITED STATES AND CANADA
Before: Stuart Rothman and Clarence D. Barker. Member Smith not
participating.
DECISION
On January 4, 1967, the United States Atomic Energy Commission
(AEC) and Idaho Nuclear Corporation (INC) jointly filed a petition
for review of an opinion, designated DB-52, dated October 14, 1968,
by the Solicitor of Labor to the effect that certain assembly work
in connection with the AEC Loss of Fluid Test (LOFT) Experiment to
be performed under Contract No. AT(10-1)-1230 by INC at the AEC
National Reactor Testing Station (NRTS) [1]
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[2] in Idaho was covered by the Davis-Bacon Act. The Oil, Chemical, and
Atomic Workers International Union (OCAW), a local union of which has a
collective bargaining agreement with INC, intervened as petitioner.
The Solicitor responded to the petition, as did the Building
and Construction Trades Department (AFL-CIO), the International
Brotherhood of Electrical Workers, and the United Association of
Journeymen and Apprentices of the Plumbing and Pipe Fitting
Industry of the United States and Canada.
The named parties participated in a hearing held on March 21,
1967. In addition, representatives of the United Brotherhood of
Carpenters and Joiners of America and the Sheet Metal Workers
International Association and others attended the hearing.
The facts, as stated in the petition, are undisputed in their
essentials, and are set out here:
Description and Location of the LOFT Experiment
The LOFT Experiment will be conducted at the AEC NRTS in
Southeast Idaho.
A. Description of the Reactor System. The following is a
description of the work which is at issue and the place of its
performance. The reactor system will consist of the following
major components: a reactor vessel, a reactor core, control rods,
control rod drives, primary system pump and piping, steam
generator, pressurizer, instrumentation, and railroad dolly.
1. The reactor vessel consists of a 20-foot high by 5-foot diameter
carbon steel vessel lined internally with stainless steel. Its
basic purpose is to house the reactor core and control rods and to
contain the primary system water.
2. The reactor core consists of approximately 4000 lbs. of uranium
dioxide fuel in the form of small pellets which are contained in
3300 zirconium alloy tubes 3 feet long. The tubes are supported by
two perforated plates at the top and bottom which are attached to
the reactor vessel.
3. The control rods consist of a mixture of boron and stainless
steel clad with stainless steel. There are twelve such rods each
in the form of 4-inch cruciform blades. The rods extend up from
the core through the top of the reactor [2]
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[3] vessel and are attached to the control rod drive. The basic purpose
of the control rods is to limit and control the power output of the core.
4. The control rod drives consist of motors and associated
mechanical linkage mounted on top of the reactor vessel. The basic
purpose of the control rod drives is to provide a mechanism by
which the control rods can be moved.
5. The steam generator consists of a carbon steel vessel 6 feet in
diameter by 12 feet high which houses a number of U-shaped tubes.
The purpose of the steam generator is to remove heat from the
primary or reactor system and deposit it into the secondary or heat
removal system. The primary system water is circulated through the
tubes and heat is removed by conduction through the walls of the
tubes to the low temperature secondary water.
6. The primary system pump consists of a 15,000 gpm pump driven by
a 600 horse-power motor. The purpose of the pump is to circulate
the primary system water through the various components.
7. The primary system piping consists of 20-inch diameter carbon
steel pipes. Their basic purpose is to contain the primary system
water and to provide a means by which it can be transported to the
various components.
8. The pressurizer consists of a carbon steel vessel 3 feet in
diameter by 17 feet long which houses electrical heaters. The
basic purpose of the pressurizer is to help establish primary
system pressure and to maintain it during normal operation.
9. The primary system instrumentation consists of sensors and
associated electrical connections located strategically throughout
the primary system. In the LOFT reactor system two types of
instrumentation systems are employed, operational and experimental.
The purpose of the operational instrumentation is to monitor
pressure and temperature of the primary system water in the various
components and to monitor the core power level. The purpose of the
experimental instrumentation is to monitor core temperature, water
density and forces on the components during the experiment.
10. The railroad dolly consists of a 20-foot wide by 50-foot long
flatcar with 32 wheels which rest on four railroad tracks. The
purpose of the dolly is to provide a means of transportation to and
from the LOFT Containment facility [3]
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[4] and the assembly pre- and post-test examination areas in the Assembly
and Maintenance Building (Bldg. 607).
* * * * *
Assembly of the reactor system will be performed in the 607
Building. The 607 Building was constructed approximately thirteen
years ago for work in connection with the AEC Aircraft Nuclear
Propulsion Program ("ANP"). Geographically, this building is
located in the Test Area North ("TAN") Area which is in the
Northwest section of the NRTS. The 607 Building is a large
building 500 feet x 200 feet. It includes a large hot shop,
smaller hot cells, high bay assembly areas, decontamination and
change areas, machine shop, storage vault and storage pool,
instrumentation and control laboratories, in which fabrication,
assembly -- manufacturing -- activities are carried out. It is
1-1/4 miles from the site of the LOFT containment control facility
as described in IV B below. One of the most important features of
this building is a large hot shop consisting of an entire bay. A
hot shop or cell is an area in which equipment or materials which
are contaminated can be handled and examined by remote control
equipment without contamination of other areas or to personnel. It
is in this hot shop (cell) bay area that the reactor system will
undergo a simulated disassembly test to determine whether the
remote control equipment can cope with the geometric configuration
of the assembly, and it is here that upon completion of the
experiment the reactor system will be disassembled using remote
control techniques, and the final effects of the tests studied.
The importance of the 607 Building to the LOFT assembly and
disassembly processes cannot be overemphasized. The reactor system
assembly work cannot be performed in the containment and control
facility presently available at NRTS. Operationally, the assembly
of the reactor system must be performed in the 607 Building or a
new facility constructed which would duplicate substantially the
unique features of the 607 Building.
The assembly process will be generally as follows: Upon
procurement and receipt of the reactor pressure vessel, it will be
set on a cradle which will be fabricated in the machine and sheet
metal shops. After placing the reactor vessel in the cradle,
instrument access nozzles will be welded into place. The vessel
will then be hydrostatically tested.
Assuming satisfactory completion of the hydrostatic test, the
exterior of the vessel will be extensively instrumented. Following
installation of instrumentation the reactor vessel will be
insulated. Insulation will be installed while the reactor vessel
is sitting on its cradle. Shielding consisting of water and lead
will then be placed around the reactor vessel. While the work
described is carried out, the two railroad cars which will be
procured will be fitted together [4]
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[5] side-by-side and a second cradle will be fabricated and assembled
on the railroad cars for receipt of the reactor vessel. The two railroad
cars (dolly) will then be instrumented. In order to lift the pressure
vessel and shielding as a unit, a support structure will be designed and
fabricated to accommodate the lifting and movement of the vessel
onto the dolly. The vessel will then be lifted by overhead cranes
onto the dolly. Subsequently, the framing, piping, and additional
instrumentation will be placed upon the dolly and reactor vessel.
Concurrently, with the above-described operations, the reactor
internals will be assembled, measured, and tested for installation
in the reactor vessel. Upon installation, further extensive
instrumentation will be made. This work will be performed
primarily in the cold bay area of the 607 Building.
As indicated above in the explanation of the importance of the
hot shop in the 607 Building, the reactor system will be moved from
the cold high bay assembly area of the 607 Building into the hot
shop area of Building 607 where remote handling equipment will
simulate a disassembly of the reactor system to test whether the
remote control equipment can cope (i.e., take apart) with the
geometric configuration of the assembly. If it cannot, the reactor
system will be returned to the cold assembly area of the 607
Building, disassembled, and modified.
When the reactor system's assembled configuration meets the
disassembly requirements, it will be moved on the dolly the one and
one-quarter (1-1/4) miles into the containment building where it
will be plugged into utilities and instrumentation contained in the
remote control building. A number of tests with a nonnuclear core
will be performed. If these tests show anything wrong with the
materials, workmanship, or design, the system will be unplugged and
returned to the 607 Building for correction. Ultimately, the
system will be in proper condition for the nuclear test in the
containment building. After the nuclear test (approximately 5 days
duration) the reactor system will be partially decontaminated,
unplugged, and moved back to the hot shop in the 607 Building,
where the reactor will be disassembled and the effects of the test
studied. The "plugging in" of the reactor system to the utilities
of the containment facilities involve only temporary connections to
electrical and instrumentation outlets, water, air.
I.
The essential issue before the Wage Appeals Board is whether
or not the erection of the reactor, or reactor system, for the LOFT
experiment constitutes construction of a public work within the
meaning of the Davis-Bacon Act. [5]
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[6] In support of its position that the reactor involved is not
covered by the Davis-Bacon Act, the petitioners assert the
following points:
1. The work involved is experimental within the meaning of AEC
Procurement Regulations 9-12 and Federal Procurement Regulations
1-12.402-1(a)(2) and (3) and therefore excluded from coverage under
the Davis-Bacon Act.
2. The reactor is not a "public work" within the meaning of
the Davis-Bacon Act.
3. The erection of the reactor is manufacturing rather than
"construction."
4. The work in question is significantly different from that
performed subject to the Davis-Bacon Act in connection with the
Special Power Excursion Reactor Test (SPERT) at NRTS.
5. The Board's Stanford Linear Accelerator decision (WAB
65-02) should be followed here.
The contentions of the respondents are essentially the
converse of these points. That is, the work involved is similar to
that in the SPERT reactors; the work involved is not experimental
because the experiments occur subsequent to the erection and in any
event the Act does not exempt experimental work; the erection
constitutes "construction" rather than manufacturing; the reactor
is a "public work" under the Act.
In addition, the petitioners make the following arguments:
1. The Davis-Bacon Act is not an act for determining
jurisdictional assignments.
2. There is no significant Federal policy objective to
be accomplished by the application of the Davis-Bacon Act, because of the [6]
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[7] collective bargaining agreement between INC and OCAW
and the application of other federal labor relations and standards
legislation.
3. The opinion rendered by the Solicitor of Labor is advisory,
and the final responsibility for determining whether a particular
contract involves work which is covered by the Davis-Bacon Act
rests with the contracting agency.
Again, the contentions of the respondents are essentially the
converse of the petitioners[']. That is, workers are entitled to
the prevailing wage protection of the Davis-Bacon Act regardless of
lesser wages which may be prescribed in a collective bargaining
agreement; and there is no issue of a jurisdictional dispute or
work assignment before the Board.
II.
The petitioners seek to distinguish the LOFT reactor from the
SPERT reactors considered subject to the Davis-Bacon Act by
describing the LOFT reactor as an experiment in and of itself, and
therefore different from the SPERT reactors.
The AEC Procurement Regulations relied upon read as follows:
AECPR 9-12.402-52(a)(5) and (6).
(a) Particular contracts or work items falling within one
or more of the following criteria normally will be
classified as non-covered.
* * *
(5) Experimental development of equipment, process and
devices, including assembly, fitting, installation,
testing, reworking, and disassembly. This refers to
equipment, processes and devices which are assembled for
the purpose of conducting a test or experiment. The
design may be only conceptual in character, and
professional personnel responsible for the [7]
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[8] experiment participate in the assembly. Specifically
excluded from the category of experimental development
are buildings, building utility services, structural
changes, and modifications to building utility services
-- as distinguished from temporary connections thereto.
Also specifically excluded from this category is
equipment to be used for continuous testing; e.g., a
machine to be continuously used for testing the tensile
strength of structural members.
(6) Experimental work in connection with peaceful uses of
nuclear energy. This refers to equipment, processes, and
devices which are assembled and/or set in place and
interconnected for the purpose of conducting a test or
experiment. The nature of the test or experiment is such
that professional personnel responsible for the test or
experiment and/or the data to be derived therefrom
necessarily must participate in the assembly and
interconnections. Specifically excluded from experimental
work are buildings, building utility services, structural
changes, drilling, tunneling, excavation and back-filling
work which can be performed according to customary
drawings and specifications, and utility services or
modification to utility services -- as distinguished from
temporary connections thereto. Work in this category may
be performed in mines or other locations specifically
constructed for tests or experiments.
The petitioners state that the erection of the reactor system
involves a configuration which is conceptual in nature; it will
involve supervision and participation in the erection by
professional personnel. The reactor is then described as "an
experiment involving peaceful uses of nuclear energy; i.e., safety
of private and public reactor facilities which are or will be
utilized in the generation of electrical power."
However, as noted in 41 CFR 9-12.5005-1, the quoted
regulations necessarily use general language and in some cases the
application of the criteria is unclear, such as in this case. The
specific examples of how the criteria have been applied, which are
contained in 41 CFR 9-12.5005-2, provide helpful guidance. We
agree with the Solicitor that, [8]
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[9] for purposes of the Davis-Bacon Act, there is no significant difference
between the LOFT reactor and the SPERT reactors described in 41 CFR
12.5005-2(i)(3). The SPERT reactors are being used to conduct
experiments, one of which is to test various cores of different
shapes and sizes. The LOFT reactor is to be used to experiment
also; i.e., to determine what will happen when the coolant is
withdrawn. In the former, the AEC wants to study "reactor
behavior" and what happens when different kinds of shapes of cores
are inserted. In the latter, it wants to study "reactor behavior"
and see what happens when the coolant is removed. Both LOFT and
SPERT have many characteristics of standard reactors which are
built and subsequently used for experimental purposes.
Experimental projects usually deal with work, the definition,
delineation, or scope of welch involves such difficulties that
full specification is not possible or practical. According to the
facts before us, this is not that kind of situation.
We conclude that the LOFT reactor is to be treated the same as
the SPERT reactors for purposes of coverage under the Davis-Bacon
Act. There is no question among the parties that the SPERT
reactors are covered "public works" under the Act and that their
erection constitutes "construction." Therefore, there is no need
in this decision for further exposition on the generic and specific
meanings of the terms in the administration of the Davis-Bacon Act.
However, some discussion is appropriate concerning the term
"construction" in view of the petitioners' contention that our
Stanford Linear Accelerator decision (WAB 65-02) has precedential
value here. There the contractor, Stanford University itself, was
engaged in the making of a "disk-loaded waveguide" which was [9]
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[10] described as essentially a precision instrument. The longest
piece of the dis[k]-loaded waveguide that could be feasibly put in
one piece was ten feet. Each ten-foot piece was formed of 85
"disks" and two end plates, all 4" in diameter. The spaces were
1.147-inch pieces of copper pipe; the disks were 0.230 of an inch
thick; and the two end plates were 0.7629 of an inch thick. The 86
spaces each had a different inside diameter; one differing from the
next by about 3/4 of a thousandth of an inch. Also, each of the 85
disks had a different aperture size, ranging from 1.0323 inches to
0.7517 of an inch over the ten foot piece. Each ten-foot section
was brazed together in a special furnace. Four ten-foot lengths
and other equipment were then joined and fabricated into forty-foot
modules. All this was done in a central laboratory. We held that
the assembly of the four ten-foot sections into a forty-foot module
to be a continuation and integral part of a manufacturing process,
and therefore not covered by the Davis-Bacon Act. The forty-foot
modules were transported to a nearby tunnel, where they were
assembled into place to form the accelerator tube. The latter
assembly was covered by the Davis-Bacon Act.
Also, some of the arguments advanced by the petitioner in
relation to the term "public work" should be discussed because of
their far-reaching implications. Emphasis is placed upon the
personal property exclusion from the Davis-Bacon Act in the Federal
Procurement Regulations (41 CFR 1-12.402-1(a) (2) and (3) ) and the
fact that the reactor will in effect be a moveable, i.e., placed
upon a railroad dolly consisting of a 20-foot wide by 50-foot long
flatcar with 32 wheels which is to provide a means of
transportation to and from the LOFT containment facility and the [10]
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[11] assembly building (Bldg. 607). There is no exclusion in
the Davis-Bacon Act for personal property. But its application to
personal property is severely limited by (1) the Act's application
to "construction" rather than manufacturing, (2) difficulties in
applying the prevailing wage standard to removables, and (3) the
"site of the work" limitation. Therefore, any rule for exclusion
must be viewed as general. Limitations relating to application of
the Act to personal property are not pertinent here. As held
above, the erection involved constitutes "construction." No
difficulty has been advanced as to the application of the
prevailing wage standard to the area for determination. Finally,
the construction site is sufficiently identifiable. It includes
the containment building, the assembly building, and the
intervening railroad tracks.
III
The petitioners contend that the ruling of the Solicitor of
Labor is advisory only. The final responsibility for determining
whether or not work under a particular contract is covered by the
Davis-Bacon Act is said to rest with the contracting agency. To
this end, reliance is placed upon Comptroller General's Opinion
B150828, dated February 18, 1965, and earlier opinions cited
therein to the effect that the authority given to the Secretary of
Labor under Reorganization Plan No. 14 of 1950 does not extend to
the actual enforcement and administration of the acts affected by
the plan.
We must reject this contention. Clearly, at least as far as
the Executive Branch of the Government is concerned, it is well
settled that interpretations by the Secretary of Labor of the
Davis-Bacon Act and [11]
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[12] other legislation subject to Reorganization Plan No. 14 of 1950 must
be observed by Federal agencies having responsibilities for their enforcement.
The opinion of the Attorney General at 41 Op. A.G. 488 is
controlling here. The Attorney General's opinion also concerned an
interpretation of legislation subject to the reorganization plan
and was to the effect that the Labor Department's interpretation
was binding upon the administering agencies.
Also, we note that opinions of the Comptroller General
rendered shortly after the promulgation of Reorganization Plan
No. 14 of 1950, are consonant with the views of the Attorney
General. See C.G. opinions B-97080, dated May 9, 1951 (recognizing
the debarment authority of the Secretary of Labor pursuant to rules
promulgated under the plan); B-105067, dated November 6, 1951
(ruling that an interpretation of the Davis-Bacon Act by the
Secretary of Labor was binding upon the Secretary of the Army); and
B-109467, dated January 29, 1953 (noting that under the plan the
Secretary of Labor was empowered to make investigations regarding
compliance with legislation subject to the plan).
The alternative of having contracting and administering
agencies decide finally questions of coverage is not found to be
within the intent of Reorganization Plan No. 14 of 1950. The
objectives of the plan as expressed in the Message of the President
transmitting it to the Congress, included making the Department of
Labor the central agency for dealing with the labor statutes
involved, and providing for their uniform enforcement. These
objectives could not be possibly achieved if the contracting and
administering agencies applying the forty-odd statutes subject to
the plan had the final word in that application. The alternative [12]
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[13] would likely have more inimical rather than ecumenical
consequences.
Reorganization Plan No. 14 of 1950 has the effect of bringing
together in the Secretary of Labor the powers of making wage
determinations under the Davis-Bacon Act and providing for their
uniform enforcement and application. It was only good sense to
give the Secretary of Labor the final word as to how and when his
own wage determinations are to be applied.
IV
The petitioners assert that the Davis-Bacon Act is not
legislation for determining jurisdiction assignments between the
building and construction trades unions and industrial unions.
They rely upon Comptroller General's Opinion B-150828, dated
February 18, 1965, which states in effect that the Davis-Bacon Act
is not a statute for settling jurisdictional disputes. Similar
sentiments were also expressed by the General Subcommittee on Labor
of the Committee on Education and Labor following an investigation
by the Special Subcommittee on Labor into the administration of the
Davis-Bacon Act. See Report of the General Subcommittee on Labor
of the Committee on Education and Labor, Administration of the
Davis-Bacon Act, 88th Cong., 1st, Sess., p. 14 (1963) [Committee
Print].
The Wage Appeals Board wholeheartedly concurs in the view that
the Davis-Bacon Act is not, and was never intended to be, a vehicle
for the settlement of jurisdictional disputes or the making of work
assignments. However, we are of the opinion that the Solicitor's
administration of the Davis-Bacon Act has not been inconsistent
with this view.
In determining whether or not work is subject to the
Davis-Bacon Act, the sole question before the Department of Labor
is whether the work constitutes construction, alteration and/or
repair of public buildings or public works of the United States.
It is officially blind as to [13]
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[14] whether a jurisdictional dispute between classes or crafts or groups
of laborers or mechanics could be involved. The Department of Labor simply
does not reach that question. It cannot reach it. Once it determines
whether or not the work is covered, that ends its job as to that
question. The Department of Labor has not acted to resolve a
jurisdictional dispute between classes, crafts, or groups of
employees in this case.
In relation to this contention in the course of the hearing,
we understood OCAW to ask for a statement clarifying whether or not
a contractor or bidder having a collective bargaining agreement
with an industrial labor organization may be precluded from
performing a Government contract because work under the contract
may be subject to the Davis-Bacon Act. The short answer is that
the Davis-Bacon Act itself requires no such preclusion. Any
procurement policies bearing upon the matter do not reflect any of
the Davis-Bacon Act's requirements, and therefore are beyond this
Board's frame of reference.
V
The petitioners contend that there is no significant Federal
policy objective to be accomplished by the application of the
Davis-Bacon Act, and therefore the Act should not be applied here.
If INC performs the work, its employees will receive wages and
benefits under the terms and conditions of employment set forth in
a collective bargaining agreement with OCAW, the certified
representative of its employees under the National Labor Relations
Act, and its employees would be entitled to the labor standards
protection of the Walsh-Healey Public Contracts Act. [14]
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[15] We know of nothing in the National Labor Relations Act or
other Federal labor standards legislation which provides for
erasing the application of the Davis-Bacon Act where it is
otherwise applicable by its own terms. What the petitioners ask
passes the bounds of permissible agency discretion. The gist of
the petitioners' argument appears to be that employees with the
protections of collective bargaining no longer need the protections
of a remedial statute as the Davis-Bacon Act.
We believe that upon reflection the petitioners are asking the
Board through interpretation of the Act to in effect amend it, and
without good reason. The Davis-Bacon Act with its own policy
considerations, is a remedial statute which throughout the years
has had a stable interpretation. Indeed, as a statute dealing with
construction, engineering and development programs under
procurement and grant-in-aid legislation, the Act requires an
approach calling for precision and clarity that one would
reasonably expect in connection with other specifications that go
into an invitation for bids. The Act is not subject to a wide
range of fluctuating interpretations and it would be a facing-about
from the traditional and accepted interpretation of this statute if
wide-ranging interpretation based upon "policy" considerations were
now imported into it.
This is not to say that there is not a scope of appropriate
interpretation required for the practical administration of the
statute, but the Board does not believe that the request to tie
questions of collective bargaining policy into the question whether
certain work is construction work within the meaning of the
Davis-Bacon Act is such a proper request. [15]
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[16] Perhaps the best answer to the petitioners' contention on
this point lies in its own position that the Davis-Bacon Act is not
a statute for the resolution of jurisdictional disputes or work
assignment questions. The fallacy of the petitioners' contention
can best be explained by the following illustration. There are a
number of labor organizations, all with bona fide collective
bargaining agreements, which operate outside of the AFL-CIO. These
organizations may be organized on industrial or craft lines or some
other basis. The collectively bargained wage rates for the
classifications of work in question may be high or low. The rates
vary, as all contracting agencies are aware -- classification by
classification and craft by craft -- within the building and
construction trades. It needs no elaboration that when the
contracting agency selects a contractor, it should make no
difference whether the contractor has a collective bargaining
agreement with one kind of labor organization or another, or with
no labor organization at all.
What appears to be public policy based on one side's wisdom or
belief that their cause is the popular one and what another group
may believe to be public policy may be a matter of irreconcilable
conflict. The Wage Appeals Board believes that there is no need to
make a choice, or indeed strike a balance, between the two lines of
public policy represented by national labor relations and labor
standards legislation, such as the Davis-Bacon Act. The terms of
the Davis-Bacon Act and its purposes are clear, and do not take up
such policy considerations. It is not for this Board, or any board
or agency, to read such considerations into the Act. For these
reasons, we do believe that coverage under the Davis-Bacon Act
cannot be tied to questions concerning the collective bargaining
situation of the contractor. [16]
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[17] ORDER
On the basis of the foregoing and the entire record in this
case, the petition is hereby denied.
This 8th day of April, 1967.
Stuart Rothman, Member
Clarence D. Barker, Member
WAGE APPEALS BOARD [17]
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