ML20148H945
| ML20148H945 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/22/1988 |
| From: | Latham S, Letsche K, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5416 OL-6, NUDOCS 8801270334 | |
| Download: ML20148H945 (16) | |
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4 00LKEIED y%RC as yH 26 g):15 January 22, 1988 Fig g SELEUA M OCKE1ING A "208'#.
UNITED ST TES i6eNN5 ERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board
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In the Matter of )
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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-6
) (25% Power)
(Shoreham Nuclear Power Station, )
Unit 1) )
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GOVERNMENTS' COMMENTS IN RESPONSE TO JANUARY 7, 1988 MEMORANDUM AND ORDER The Governments (Suffolk County, the State of New York and the Town of Southampton) hereby respond to this Board's Memoran-dum and Order (In Re: LILCO's Request for Authorization to Oper-ate at 25% of Full Power), dated January 7, 1988 (hereafter, the "Order"). The Board sought the parties' comments on "the rela-tive advantages and disadvantages" of requesting that the Chief Administrative Judge appoint another Licensing Board, or in consultation with him and pursuant to 10 CFR S 2.722(a), a Spe-cial Master, or an Alternate Board Member, or a Technical Inter-rogator. Order at 11.
The Order also identified the future mission of the so-called "new forum":
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[T]he new forum would consider the discrete question of whether any of the contentions currently before this Board, including both the so-called legal authority contentions and the contentions before us on remand, are substan-tively relevant to the proposed operation at 25% of full power.
Order at 10. The Board explained that "(t]he question of which contentions currently in litigation are relevant in a substantive way to the activity to be authorized is a question that stands at the core of any litiaation concernina the reauest for 25% oower."
Id. at 9 (emphasis added). It noted, however, that "[t]he matter of the validity of the technical analysis supporting LILCO's motion is a narrow one and constitutes only a small cart of the total litication." Id. at 9-10 (emphasis added). That is be-cause, as the Board observed, LILCO's apparent intent is to attempt to show that unresolved contentions are immaterial to the provisions of Section 50.47(b), Appendix E, and NUREG 0654, or insignificant to public health and safety, based on its Shoreham-specific risk assessment for 25% power operation and "uncontested elements of emergency planning now in place." Id. at 10, n.2.
The Governments' comments on the advantages and disad-vantages of the four alternate proposals for a "new forum," in light of the assignment proposed for that forum, follow.1/
1/ In providing these comments, the Governments stress that they do not concede the correctness of the Board's basic ruling on January 7 -- that it is appropriate to proceed to consider LILCO's 25% power request. To the contrary, the Governments believe the Order was clearly erroneous. Thus, on January 21, the Governments filed with the Appeal Board a Motion for Leave to File Interlocutory Appeal of the January 7 Order. A copy of the Governments' Motion was served on this Board.
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. i First, for the reasons set forth below concerning a new Board, an Alternate Board Member, and a Technical Interrogator, the Governments de not consent to the appointment of a Special Master. Therefore, under Section 2.722(a)(2), that option cannot be adopted. Accordingly, the remainder of these comments ad-dresses only the other three alternative proposals.
Second, the proposal to appoint a "new forum" to consider the relevance of admitted contentions to 25% power operation appears to be based upon fundamentally incorrect assumptions about the status of several Shoreham issues. As of October 6, 1987, when the Margulies Board sought the parties' views on several matters, the status of many issues was unknown or in a state of flux. Subsequent events, however, document beyond any question that LILCO's 25% power motion must be "denied" because the Governments' existing contentionJ, undeniably, "are substant-ively relevant to the proposed operation at 25% of full power."
Egg Order at 10. We discuss some examples below.
For instance, it is clear beyond any question that there ,
l must be a "full participation exercise" before Shoreham can operate above 5% power. That is an exoress requirement of 10 CFR Part 50, App. E, S IV.F.1.2/ The Governments have contentions 2/ Appendix E, S IV.F.1 provides:
- 1. A full participation exercise which tests as much of the licensee, state and local emer-gency plans as is reasonably achievable without :
mandatory public participation shall be con-ducted for each site at which a power reactor is located for which the first operating
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(footnote continued) i 3-
4 alleging that LILCO has failed to conduct the required exercise.
Moreover, it is now established that, in fact, LILCO has not conducted such an exercise. Lono Island Lichtino Cqt (Shoreham Nuclear Power Station, Unit 1), LBP-82-732, NRC (Dec. 7, 1987). In that decision, the Governments' referenced contentions were held to be correct. There is no need, nor would it be appropriate, for another Board or special assistants to waste time examining the relevance of these contentions to 25% power:
under Appendix E, it is undisputable that the contentions are relevant. And, LBP-87-32 makes it similarly undisputable that the Governments' contentions are correct.3/
It is similarly clear that the "1cgal authority" contentions also are "relevant" to 25% power. LILCO maintains that its LERO organization and Plan will be in effect during 25% power opera-tion; indeed, that is one of its so-called "compensating actions" (footnote continued from previous page) license,for that site is issued after July 13, 1982. This exercise shall be conducted within two years before the issuance of the first peeratino license for full oower (one author-izino operation above 5% of rated power) of the first reactor . . . .
(footnote omitted; emphasis added).
3/ This Board's Order (at 10) suggests that the only inquiry '
would be whether any contentions "before this Board" are relevant to 25% powee. It is obvious, however, that contentions in the OL-5 proceeding, whether already ruled upon or not, are just as relevant to 25% power operation as those in the OL-3 docket.
They 611 allege failures of LILCO's emergency plan to comply with Section 50.47, Appendix E, and NUREG 0654. Egg NRC Staff Response to LILCO Motion for Designation of Licensing Board and Setting Expedited Schedule to Rule on LILCO's 25% Power Request (July 29, 1987) at 4 (potentially relevant contentions include those in both OL-3 and OL-5 proceedings).
which allegedly would address all-its planning deficiencies.
LILCO Request at 10, 84. Contentions EP l-10 directly contest the legality of that Plan and the authority of LERO personnel to perform functions pursuant to that Plan. The legal authority contentions are fully relevant at any power level that involves the proposed activation of LERO and the LILCO Plan. Thus, it cannot be disputed that the legal authority contentions are "relevant" to 25% power operation.d/ Many other admitted conten-tions are also indisputably "relevant" to LILCO's proposed 25%
power operation, such as those in the OL-5 proceeding related to alerting and notification and LERO training, and the EBS issues currently before this Board.5/
A/ Egg also NRC Staff Response to Board Memorandum Requesting Parties' Views on Questions Raised by LILCO 25% Power Authoriza-tion Motion (Nov. 6, 1987) at 4 ("several of the pending emergen-cy planning issues, particularly the legal authority issues re-lating to activation of the alert and notification system and the decision and recommendation process for protective actions for the public, would seem to require a finding of regulatory compli-ance at 25% power as well as at full power" and "this would ap-pear to be true, even using the ' realism' assumption" citino l CLI-86-13 and rule amendment).
5/ Egg, e.o., NRC Staff Reply to Other Party Views on Board Questions Concerning LILCO Motion for Authorization to Operate at l 25% (Dec. 15, 1987) at 3 ("(T]he issues of whether the LILCO offsite emergency response organization (LERO) is sufficiently l trained to implement the LILCO Plan, and whether the realism-l I
postulated best effort government response following the LILCO l Plan would be adequate are open issues in the OL-5 and OL-3 l hearings, respectively. As conceded by LILCO, these issues are i relevant to consideration of the 25% cower motion and would necessarily be open to litiaation in the OL-6 docket.") (emphasis added).
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The foregoing few examples amply demonstrate the fundamental fallacy in the Board's apparent belief that there could ever be a finding by any "new forum" that no contentions are relevant to LILCO's 25% power operation. Clearly, there is no basis for creating a "new forum" to decide a question for which the answer:
(a) is already provided by the regulations; (b) is already pro-vided in ASLB decisions; or (c) is a matter of common sense.
Third, the Governments submit that the proposal to appoint a new licensing board is improper and contrary to the intent of Section 50.57(c). As the NRC Staff has stated on several occa-sions, "10 C.F.R. S 50.57(c) reflects a regulatory policy that the same licensino board which has considered the contentions cendino in a croceedino should determine whether those conten-tions are relevant to the activity sought to be authorized
. . . ." NRC Staff View on Prioritizing Matters Before the Licensing Board (Nov. 14, 1987), at 3-4, n.l.5/ Since that precise determination -- whether existing contentions are rele-vant to 25% power operation -- is what the Order proposes to be made in this case by a new Board rather than by the presiding i
l 1/ Egg also NRC Staff Response to LILCO Motion for Designation of Licensing Board and Setting Scheoule to Rule on LILCO's 25%
Power Request, filed with the Commission (July 29, 1987) at 3 (implicit in CLI-87-04 "is the determination that, under 10 C.F.R. S 50.57(c), the Licensing Board which has considered the contentions still pending, should hear from the parties concerning the relevance of such contentions to the activity I sought to be authorized"); and 4-5 ("LILCO's argument that the
! issues raised in its 25% power request are so distinct from l pending issues as to obviate the regulatory policy that the
- licensing board hearing evidence on contentions preside over the S 50.50(c) application is without merit").
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Board, the new Board alternative proposal cannot lawfully be implemented. To do so would violate Section 50.57(c) and the Commission's interpretation of the intent of that Section.1/
Fourth, even assuming arauendo it were proper under the regulations, it is the Governments' view that there would be no "advantages" to be gained by the appointment of a new Licensing Board, or an Alternate Board Member, or a Technical Interrogator.
There are, however, many disadvantages to all three proposals.
As the Governments and the NRC Staff have reiterated several times, given the issues to be decided by the Board's proposed "new forum," it would be inefficient, counterproductive, and prejudicial to the parties to have a new adjudicator brought into this complex case, with its years of procedural and substantive history, particularly for the purpose of ruling on the relevance of matters with which the presiding Board has itself been dealing for years.E/ This is true whether the "new forum" were to be a 1/ Indeed, Section 50.57(c) itself makes clear that it does not contemplate the involvement of new adjudicators unfamiliar with the pending proceeding and its contentions. It provides:
Action on (a motion for a license short of full power filed in a pending proceeding) by the presidino officer shall be taken with due regard to the rights of the parties to the proceedings, including the right of any party to be heard to the extent that his contentions are relevant to the activity to be authorized.
Prior to takina any action on such a motion, the cresidinc officer shall make findings on the matters specified in paragraph (a) of this section as to which there is a controversy E/ For the sake of brevity, we do not repeat here the extensive (footnote continued) l l
Licensing Board, an Alternate Board Member, or a Technical Inter-rogator. Any newcomer to this proceeding would simply not have the necessary background knowledge or information to enable him or her to perform productively or fairly as an adjudicator, or interrogator.
This is true particularly in light of the task proposed for the "new forum" -- determining whether any of the contentions are "substantively relevant" to 25% power operation. Order at 10.
To make such determinations would necessitate a full under-standing of the LILCO Plan, all the contentions in the OL-5 and OL-3 proceedings, the litigation, evidence, and in some cases, rulings concerning them from 1983 to the present, in addition to (footnote continued from previous page) discussions on this subject which have already been provided to this Board. We provide the pertinent references for convenience, however. We also note that the Board's definition of the task it proposes to assign to the "new forum" does not affect in any way l the previous arguments concerning the interrelated nature of the l issues presented by LILCO's 25% power request and the emergency l planning issues with which this Board has been dealing for the l past several years. Egg Suffolk County, State of New York and i
Town of Southampton Response in Opposition to LILCO Motion for Designation of Licensing Board and Setting Expedited Schedule to
! Rule on LILCO's 25% Power Request (July 27, 1987) at 11-13; NRC Staff Response to LILCO Motion for Designation of Licensing Board and Setting Expedited Schedule to Rule on LILCO's 25% Power Request (July 29, 1987) at 4-5; Response of Suffolk County, the State of New York and the Town of Southampton to August 31, 1987, Licensing Board Notice (Sept. 14, 1987) at 8-11; NRC Staff Views on Prioritizing Matters Before the Licensing Board (Sept. 14, 1987) at 4 ("Due to the desirability of having the Licensing Board familiar with the other emergency planning issues deal with the 25% power request, the Staff does not recommend appointment of an additional Licensing Board or designation of a Special Master to hear the LILCO Request for Authority to operate at 25%
power."); NRC Staff Reply to Other Party Views on Board Questions Concerning LILCO Motion for Authorization to Operate at 25% Power (Dec. 15, 1987) at 3-4.
C the extensive procedural'and substantive history of the legal authority contentions. It seems preposterous to suggest it could be "advantageous" to assign such a task to a person or persons with no background, familiarity, or experience with any of those matters, particularly when the relative ignorance of such a newcomer (s) is contrasted with the experience of at least two of the presiding board members.
In addition, resource limitations and logistical considera-tions would make it grossly prejudicial, if not impossible, to have a "new forum" begin a new 25% power proceeding, to be con-ducted simultaneously with the many other proceedings already in progress on various other aspects of LILCO's license applica-tion.9/ This Board apparently believes that its "existing bur-dens" are so great that it must transfer some of its workload to a "new forum." Sgg Order at 10. There is no basis for the Board's apparent assumption that the resources of the parties --
i 9/ It bears mentioning those matters which are presently l outstanding as of January 22 (or which are about to be) as an l example of why it is clear error to suggest that another full proceeding of the complexity of 25% power could simply be added l to the burden. These matters are: responses to and pursuit of
! discovery and subsequent proceedings on school issues (the Contention 25.C remand); response to the Staff's support of LILCO l on summary disposition of hospital issues and potential future proceedings on that issue; further proceedings concerning re-sponse to the Governments' EBS contentions and LILCO's new EBS proposal; response to the Staff's support of LILCO on its 10 CFR l S 50.47(c)(1)(1)-(li) summary disposition motion; response to i
LILCO's six other legal authority summary disposition motions (and further filings if the Staff supports LILCO); response to LILCO's appeal of the Frye Board's December 7, 1987 PID; response to the forthcoming reception center decision; response to a l forthcoming second Frye Board exercise decision; review of Rev. 9 l of LILCO's Plan which is due to be filed shortly; and response to LILCO's exercise request.
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e at least those of the Governments and, perhaps, the NRC Staff as well -- would permit them to accept, without extreme prejudice, the additional burden of a separate 25% power proceeding, partic-ularly in light of the repeated statements by the Governments and the Staff which demonstrate clearly that the parties cannot shoulder such a new burden.10/ Notably, the Board cites no basis for its assumption. Furthermore, it must be emphasized that the Governments are involved in NRC and other Shoreham-related pro-ceedings, which demand extensive resources and time commitments, in addition to those which are too burdensome for this Board.ll/
In sum, it would be not only disadvantageous, but also prejudi-cial, to create a "new forum" for the conduct of an additional proceeding in this case.12/
10/ NRC Staff Response to LILCO Motion for Designation of Licensing Board and Setting Expedited Schedule to Rule on LILCO's 25% Power Request (July 29, 1987) at 5-6; Response of Suffolk County, the State of New York and the Town of Southampton to August 31, 1987 Licensing Board Notice (Sept. 14, 1987) at 9: NRC Staff Views on Prioritizing Matters Before the Licensing Board (Sept. 14, 1987) at 2-3; Suffolk County, State of New York, and Town of Southampton Reply Regarding the Priority of OL-3 Issues (Sept. 21, 1987) at 4-5.
11/ These additional matters include exercise-related pro-ceedings before the Appeal Board, LILCO's new exercise request, U.S. Court of Appeals proceedings contesting amended 10 C.F.R.
S 50.47(c)(1), and comments on draft NUREG-0654, Rev. 1, Supp. 1.
12/ One other Board observation requires comment. The Board suggests that "the validity of the technical analysis supporting LILCO's motion is a narrow one . . . . Order at 9. It may be narrow and it may be only a "small part of the total litigation" (Id. at 9-10), assuming the 25% power litigation proceeds at all.
But, it is error -- and serious error at that -- if the Board meant to imply or suggest that this "small part" may be addressed "with due regard to the equities involved" in any relatively short time frame or without imposing serious burdens upon the (footnote continued)
C The bottom line is clear: if there is to be consideration of the 25% power motion, then other matters must be put on dif-ferent schedules. It is impossible -- and a potentially gross deprivation of due process -- to suggest that the Governments should be expected to proceed on these multiple tracks simultan-eously. The Board may believe (erroneously in the Governments' view) that LILCO is "entitled to proceed on the course it has
- hosen." Order at 12. But that "entitlement" clearly does agt carry with it any right to proceed in a manner which deprives parties of due process. Thus, contrary to the Board's assertion (Order at 12), the burden on the parties of LILCO's chosen "course" must be considered.ll/
Finally, the alternative "new forum" proposals would bring no "advantages" for an additional reason. Given the issues to be determined by the "new forum," there is no basis "or assuming that any new Board, Alternate Board Member, or Technical Interro-gator would be any more qualified to deal with those issues than (footnote continued from previous page) parties. Quite aside from the massive resources that would be recuired to review such analyses, the Board must recognize that it is, pure and simple, a huce task. LILCO's 25% power Request contains 10 technical appendices, including a PRA, a common-cause initiator analysis, and source term analyses. These types of studies take very substantial time to review. They obviously took LILCO substantial time to prepare, since they involved seven major contractors (Request at 6) and four "independent peer" reviewers. Id.
11/ Egg Cuomo v. NRC, Docket No. 84-1264 (D.D.C. April 25, 1984) l CCH Nuc. Reg. Rptr. V 20,304 (NRC enjoined from proceeding on a schedule that deprived Governments due process). Egg also Lono Island Lichtino Co. (Shoreham Nuclear Power Station, Unit 1),
e the members of the existing Board.ld/ Judge Shon has the techni-cal expertise to deal with PRA-related matters. Judges Kline and Shon have substantial familiarity and experience in dealing with the LILCO Plan, the admitted contentions in this and the OL-5 proceeding, and the emergency planning regulations. Judge Gleason has a legal background. There is no basis to presume that any other members of the Licensing Board Panel (with the possible exceptions of Judges Frye and Paris who have familiarity with Shoreham issues) would be any more qualified or able to deal with the issues this Board wishes to give to a "new forum."
Indeed, as noted above, any other Panel members would be substan-tially less qualified.
For the foregoing reasons, the Governments submit that there are no advantages to any of the alternative "new forum" proposals contained in the Order. Indeed, each of them would be prejudi-cial, counterproductive, and disadvantageous.
Under the regulations, this Board must deal with the 25%
power issue itself. Logic, common sense, and basic principles of fairness and equity require the same result. Moreover, the regu-lations, Licensing Board decisions, and ordinary common sense have already answered the question supposedly to be determined with respect to the 25% power request: there are contentions in the OL-5 and OL-3 proceeding which are relevant to the 25% power activity in question. Accordingly, the underlying premise of the 11/ According to Section 2.722(a), technical interrogators and alternate board members are to be appointed "from the Atomic Safety and Licensing Board Panel."
t 4 "new forum" proposals -- that there conceivably could.be a finding that_no contentions are relevant'to 25% power operation 1 is fundamentally incorrect.
Respectfully submitted, E. Thomas Boyle Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788
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Herbegt H. Brow f Lawrence Coe Lsnpher Karla J. Letsche KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C. 20036-5891 Attorneys for Suffolk County V Wu Fabian G. Palomino Richard J. Zahnleuter Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Attorney for Mario M. Cuomo, Governor of the State of New York LL U <
k Vvik Stephep B. Latham Twomey, Latham & Shea P.O. Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton c
00CKETED U5NRC January M,J%26 All :15 UNITED STATES OF AMERICA f0 Chi kikI NUCLEAR REGULATORY COMMISSION BRANCH Before the Atomic Safety and Licensino Board
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-6
) (25% Power)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of GOVERNMENTS' COMMENTS IN RESPONSE TO JANUARY 7, 1988 MEMORANDUM AND ORDER have been served on the following this 22nd day of January, 1988 by U.S. mail, first class, except as otherwise noted.
James P. Gleason, Chairman Mr. Frederick J. Shon Atomic Safety and Licensing Board Atomic Safety and Licensing Board 513 Gilmoure Drive U.S. Nuclear Regulatory Commission Silver Spring, Maryland 20901 Washington, D.C. 20555 James P. Gleason, Chairman Dr. Jerry R. Kline Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20055 Christine N. Kohl, Chairman Alan S. Rosenthal Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. W. Reed Johnson William R. Cumming, Esq.
Atomic Safety and Licensing Spence W. Perry, Esq.
Appeal Board Office of General Counsel
, 115 Falcon Drive, Colthurst Federal Emergency Management Agency l Charlottesville, Virginia 22901 500 C Street, S.W., Room 840 Washington, D.C. 20472 i
C Fabian G. Palomino, Esq. W. Taylor Reveley, III, Esq.
Richard J. Zahleuter, Esq. Hunton & Williams Special Counsel to the Governor P.O. Box 1535 Executive Chamber, Rm. 229 707 East Main Street State Capitol Richmond, Virginia 23212 Albany, New York 12224 Joel Blau, Esq. Anthony F. Earley, Jr., Esq.
Director, Utility Intervention General Counsel N.Y. Consumer Protection Scard Long Island Lighting Company Suite 1020 175 East Old Country Road Albany, New York 12210 Hicksville, New York 11801 E. Thomas Boyle, Esq. Ms. Elisabeth Taibbi, Clerk Suffolk County Attorney Suffolk County Legislature Bldg. 158 North County Complex Suffolk County Legislature Veterans Memorial Highway Office Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Mr. L. F. Britt Stephen B. Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C. 20555 Alfred L. Nardelli, Esq. Hon. Patrick G. Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-118 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 l Mr. Jay Dunkleburger Edwin J. Reis, Esq.
New York State Energy Office George E. Johnson, Esq.
Agency Building 2 U.S. Nuclear Regulatory Comm.
j Empire State Plaza Office of General Counsel Albany, New York 12223 Washington, D.C. 20555 i
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David A. Brownlee, Esq. Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W. 43rd Street New York, New York 10036 Douglas J. Hynes, Councilman Mr. Philip McIntire Town Board of Oyster Bay Federal Emergency Management Agency Town Hall 26 Federal Plaza Oyster Bay, New York 11771 New York, New York 10278 Sbl % _
{VC c Karla J. Letsphe KIRKPATRICK 4 LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C. 20036-5891
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