ML20212K610
| ML20212K610 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/22/1987 |
| From: | Latham S, Mcmurray C, Zahnleuter R KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2302 OL-3, NUDOCS 8701290127 | |
| Download: ML20212K610 (20) | |
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9-January 2ftvv1997 U%RC UNITED STATES OF AMERICA
'87 JD 27 P3 :12 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Ebard
)
-In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3'
)
(Emergency Planning)
(Shoreham Nuclear Power
)
Station, Unit 1)
)
)
)
SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON MOTION FOR RECONSIDERATION OF SCHEDULE INTRODUCTION On January 14, 1987, this Board issued an Order establishing-a discovery and hearing schedule for litigation of the issues surrounding LILCO's latest-proposed reception centers scheme.1/
^
The Board's schedule calls for discovery to commence as of the date of the Order, for testimony to be filed between March 23 and April 13, and for the hearing to cc.tmence on May 4.
For the reasons discussed below, Suffolk County, the State of New York, 1/
Order (Setting Discovery and Hearing Schedule) (January 14,
)
1987)(" Order").
The Board had granted LILCO's Motion to Reopen the Record to hear the reception center issues by Memorandum and Order dated December 11, 1986.
Memorandum and Order (Ruling on LILCO Motion to Reopen Record and Remand of Coliseum Issue)(December 11, 1986).
)
i 8701290127 870122 jid 3 PDR ADOCK 05000322 PDR
and the Town of Southampton (the " Governments") hereby move for reconsideration of the schedule, with further proceedings held in abeyance pending:
(1) a statement from LILCO as to whether it intends to revise its Plan or procedures (a) to remove the deficiency. identified by the Licensing Board and Appeal Board orders (12g2, the Plan fails to include an estimate of, and planning for, the number of evacuees
~
expected to require monitoring), and/or (b) to address other deficiencies identified by the FEMA RAC and town zoning boards; (2) depending upon the LILCO statement referenced in (1),
(a) the filing and ruling on summary disposition motions, 2L (b) the issuance of Plan revisions; and (3) an order by this Board barring LILCO from further revising its reception center proposals or facilities and directing that LILCO will be finally bound by the Board's decision in this litigation on whatever version of LILCO's Plan is identified as the subject of this p'roceeding.
In addition, the Governments respectfully request that the Board expedite its consideration of these issues and rule on this motion, as soon as possible.
Expedited consideration is necessary because discovery has already begun.2/
The Governments 2/
The Governments have already received a LILCO discovery request.
Egg LILCO's First Set of Interrogatories and Requests for Production of Documents Regarding Reception Centers to Suffolk County and New York State (Jan. 16, 1987)..,
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will attempt to proceed with discovery to the extent possible-4 during the pendancy of this Motion, but it will materially assist all parties in planning for this proceeding and avoid needless enpenditures of resources if the Board rules rapidly on the matters raised in this Motion.
BACKGROUND This proceeding is a result of LILCO's fifth attempt to satisfy the NRC's regulatory requirements governing relocation (or " reception") centers; the current proceeding represents the third time that that matter will actually be litigated by the filing of testimony and the conduct of a hearing.
As in the past proceedings, the Governments and the Board are confronted once again with totally new proposed facilities and substantially revised and rewritten procedures, representing yet another new relocation scheme which must be evaluated by the Governments and their experts, and then litigated.
Each time that LILCO has come up with a new reception center scheme in the past, there has been a considerable expenditure of time and effort by the Governments'-
experts and attorneys, as well as by the Board.
These expendi-tures have in each instance proved wasteful and unnecessary be-cause after each new proposal had been reviewed and/or litigated, LILCO drastically altered its plan and procedures, and proposed t
that new proposals then be litigated.
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In light of this history, the Governments wish to ensure that the proceeding initiated by the Board's January 14 Order does not turn out to be yet another futile waste of resources.
The Governments are particularly concerned about this prospect i
l because the current exorcise proceeding already has taxed limited resources, and because going forward with the reception center issues at this time -
given the facts and circumstances which i
exist, as described below -- would not result in a final deter-mination on these issues in any event.
This is true for two reasons.
First, despite the rulings of this Board and the Appeal Board that LILCO must provide an estimate of the number of evac-
)
uees expected to require monitoring in the event of a Shoreham accident, LILCO has not amended its Plan or even attempted to ad-dress this threshold Plan deficiency.3/
Rather, without seeking a stay, LILCO has petitioned the Commission to review the Board's rulings.4/
Significantly,'however, this basic Plan deficiency identified by the Licensing and Appeal Boards affects so many issues in this litigation that its existence makes meaningful i
evaluation of any proposed new procedures or facilities impos-sible.
Indeed, under circumstances as they now exist, the most rational way for this litigation to proceed is to postpone all l
3/
ALAB-855, 24 NRC (December 12, 1986); LBP-85-31, 22 NRC 410, 417, 430-31 (1985).
4/
LILCO's Petition for Review of ALAB 855 (January 2, 1987).
The Governments responded to the Petition on January 14, 1987.
Suffolk County, State of New York, and Town of Southampton's Opposition to LILCO's Petition for Review of ALAB-855 (January 14, 1987).
L _ _ __ _ ___ _. _ _ __ _.__.,
discovery and proceed immediately to summary disposition on the reception center issues because LILCO's Plan is, by the law of,
the case, deficient.
Second, recent events also indicate that proceeding on the reception center issues at this time makes no sense, and would likely be wasteful and inefficient.
These events include the following:
1.
The recent issuance of the latest Regional Assistance Committee ("RAC") Report on LILCO's Plane / which, among other things, found that the latest version of the monitoring procedures which LILCO intends to employ at its reception centers and which are purportedly the subject to be litigated in this proceeding --
i.e.,
those in Revision 8 -- are inadequate; and 2.
Recent notices to LILCO from the Nassau County towns in which two of the three new proposed reception centers are located, informing LILCO that it cannot use the two facilities for monitoring and decontamination of evacuees because to do so would be a violation of the respective town zoning ordinances.
As explained below, these events create substantial uncertainties regarding the issues to be litigated, the standards by which LILCO's new facilities are to be judged, and the very availa-bility of those facilities.
Additional uncertainty is presented E/
The RAC Report was forwarded to the NRC and made available to the parties by a letter from FEMA Deputy Associate Director
- Dave McLoughlin, dated December 30, 1986.
b by LILCO's Petition for Review by the Commission of ALAB-855.
+
Should the Commission take review over the objections of the Governments and the NRC Staff, the result could be a Commission ruling which could substantially change the bases of this litigation.
The Governments submit that'to go forward with litigation of the reception center issues at this time in the face of these uncertainties makes no sense.
In light of these facts,'the Governments move this Board to reconsider its schedule as follows.
Further proceedings should be held in abeyance pending:
1.
Submission of a statement by LILCO as to whether it intends to revise its Plan in an attempt to remove the basic deficiency identified in ALAB-855 and LBP-85-31; Anil 2.
(a)
Issuance of such a Plan revision, if LILCO i
indicates an intent to attempt to correct its I
identified Plan deficiency; gr (b)
Filing of, and ruling on, summary disposition motions if LILCO indicates it does n21 intend-to attempt to correct the Plan deficiency identified by this Board and the Appeal Board.
In addition, this proceeding should also be held in abeyance i
pending:
3.
Submission of a statement by LILCO as to whether it intends to issue any further revisions in its reception center plans, procedures, or proposed facilities, whether in response to the most recent RAC report, letters from town boards, or other matters; and 4.
(a)
Issuance of such a Plan revision, if LILCO indicates an intent to prepare one, and (b)
Issuance of an order by this Board directing that such a revision will be LILCO's last opportunity to attempt to meet its burden on relocation center issues (i.e., that further litigation will not be permitted, even should LILCO later desire to amend its Plan and procedures, or change its proposed facilities) and will be the subject of this litigation; gr 5.
Should LILCO indicate no present intent to revise its Plan, issuance of an order by this Board directing that Revision 8 represents LILCO's last opportunity to attempt to meet its burden on relocation center issues and that LILCO will have to accept as a final determi-nation on the reception center issues the rulings in this proceeding based on the Plan, procedures and facilities as they now exist in Revision 8.
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DISCUSSION A.
It is the Law of the Case that LILCO's Plan is Deficient, and that Deficient Plan Fails to Include A Planning Basis On Which Meaninaful Litiaation Can Proceed At the conclusion of the last reception center proceeding, (focused at that time on the adequacy of an earlier reception center scheme involving the Nassau Coliseum), this Board held that LILCO had failed to estimate and plan for the number of evacuees expected to seek monitoring at LILCO's reception center.
LBP-85-31, 22 NRC at 417, 430-31.
LILCO's appeal of the Board's
' ruling on this issue was rejected by the Appeal Board in ALAB-855.
In upholding this Board's decision, the Appeal Board held that on remand (i.e., in this proceeding) LILCO must provide an 1
estimate of, and plan for, the number of evacuees likely to require monitoring in the event of an accident at Shoreham.
ALAB-855, slip op. at 17-18.5/
Despite the fact that this Board and the Appeal Board have ruled on these issues, LILCO seeks to have the Commission rule on them once again.
In light of this Board's and the Appeal Board's rulings that the LILCO Plan is defective because it fails to estimate and plan for the number of evacuees expected to seek monitoring, it makes no sense to proceed with litigation of the issues presently be-fore this Board concerning that defective plan.
This is the case 5/
The Appeal Board left open the possibility that LILCO could attempt to defend its planning basis for the shelterina of 32,000 people (20 percent of the EPZ population), but stated that such a
{
1 basis had " dubious validity" as an estimate of the number of people requiring monitorina.
Id., slip op. at 18.
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6 because the deficiency is so basic that it cuts across, and has dispositive impact on, the other issues which this Board intends to review in this litigation, that is:
(1) how many evacuees must LILCO plan to be able to monitor in the event of an emergen-cy; and (2) are LILCO's proposed facilities, resources and pro-cedures adequate to handle that task?
As the matter now stands, it is the law of the case that the LILCO Plan is deficient, since it fails to include an estimate of, or planning for, the number of evacuees who will seek monitoring.
Only after such an estimate and plans are added to the Plan, and then assuming that the estimate and planning are appropriate, can the inquiry move on to determine, among other things:
- 1) whether LILCO's recep-tion centers can physically accommodate that number of evacuees;
- 2) whether LILCO has sufficient staff to process, monitor and, if necessary, decontaminate those evacuees; 3) whether LILCO's moni-l toring procedures are adequate and will allow those evacuees to be monitored in about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />;1/ and 4) whether the roadway facilities and traffic patterns around the reception centers can accommodate such an influx of traffic.
All of these issues, which purportedly are among the sub-jects of this proceeding, thus hinge on LILCO first coming up i
1 with an appropriate estimate of the number of people who will i
need monitoring during an actual Shoreham accident, and its 1
adding such an estimate (and related appropriate planning) to its 1
i Plan and procedures.
In other words, a precondition to going 1/
Egg NUREG 0654,Section II.J.12. -.
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0
' 6 forward with meaningful litigation on the relocation center issues identified for this proceeding must be a correction, or attempted correction, of the already identified dispositive Plan deficiency.
Yet, to date LILCO has not issued any revision of its Plan or otherwise attempted to correct its Plan deficiency or to comply with the Licensing and Appeal Board's orders.8/
Instead, it has sought-Commission review.
The Governments do not i
contend that LILCO is barred from seeking Commission review of those decisions.
The Governments do contend, however, that it makes no sense to proceed to litigate LILCO's existing Plan which, according to the decisions now in place (LBP-85-31 and ALAB-855), is plainly defective.
If litigation must proceed at this time on LILCO's existing Plan, the Governments would promptly move for summary disposition i
on the ground that LILCO's Plan is defective for reasons speci-fled in LBP-85-31 and ALAB-855.
However, the Governments submit it would be grossly unfair for the Governments to expend the resources necessary to file such a motion and then be confronted with a LILCO Plan revision which purports to attempt to comply 9
8/
At the time the Board ruled on LILCO's motion to reopen the record and requested briefs on schedules, the Governments assumed, based upon LILCO's past practices, that LILCO would attempt to revise its Plan before the schedule commenced or that the Board would not commence the proceeding before LILCO did so.
Thus, the Governments did not raise the issues raised herein in their proposed schedules of December 23, and 24, 1986.
Egg Suffolk County's Response to Board Memorandum and Order Regarding Schedule for Reception Center Proceeding ~(Dec. 23, 1986); State i
of New York's Response to Memorandum and Order (Dec. 24, 1986).
The Governments' assumptions were mistaken and thus the 2
Governments bring this matter to the Board's attention as promptly as possible after receipt of the January 14 Order.
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with the law of the case.2/
By the time LILCO revises its Plan there may be little or no time left in the discovery schedule to probe or analyze the substance of that revision.
Surely the Board did not contemplate such a situation when it set its schedule.
Thus, a choice must be made.
Either:
(1) the parties should go forward with litigation, or summary disposition, of the existing Plan and no further revisions be permitted; or (2) the schedule should be put on hold until LILCO attempts to revise its Plan to correct the identified deficiency and include a planning basis which complies with the Board's ruling.
In addition, the proceeding should also be put on hold until after the Commission rules on LILCO's Petition for Review and, depending upon the outcome, LILCO attempts to amend its Plan or decides that it does not intend to.
To fall to make the foregoing choices at the outset, especi-ally in the face of the other uncertainties discussed below, would be a terrible waste of time and resources.
Accordingly, the Governments submit that provisions 1 and 2 set forth on page 6 above requiring an indication from LILCO concerning its inten-tions with respect to the Plan deficiency identified by the Licensing and Appeal Boards, be implemented.
If requested by LILCO, such a statement by LILCO should not be required until after the Commission rules on its pending Petition for Review.
1/
The Governments have heard many times that emergency planning litigation occasionally involves a " moving target," but here there is no target at all.
That is, there is not even a planning basis on the table on which discovery requests, depositions, etc. can rationally proceed.,
B.
Additional Elements Of Uncertainty Must Also Be Resolved Before The-Proceedino Can Yield Meaninaful Results 1.
The RAC Report LILCO's current Plan (Revision 8).provides that LERO per-sonnel will monitor only the driver of an automobile and not the passengers.
If the driver is not contaminated, the passengers are assumed to be uncontaminated as r*ll.
In FEMA's latest review of the Plan, however, the RAC lound this procedure to be inadeauate, thus constituting a deficiency in LILCO's Plan.
RAC Report, Att. 1 at 11-12.
The pertinent portion of the RAC report is attached hereto as Appendix A.
If the history of this litigation is a reliable indicator, it seems likely that LILCO will attempt to revise its monitoring procedures once again to attempt to overcome this FEMA identified deficiency.
If LILCO does so intend, it makes absolutely no sense to waste the Board's and parties' time and resources pre-J paring for litigation of the current procedures.
Not only are LILCO's monitoring procedures directiv at issue in th'is case, but the procedures used by LILCO will have an imoact on other issues.
For instance, a change in procedures to monitor all incoming evacuees (not just drivers) is likely to have an impact on LILCO's staffing requirements, another matter directly at issue t
in this proceeding.
Likewise, revisions designed to expand the number of people monitored beyond only drivers will have an impact on LILCO's ability to monitor all evacuees within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
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The issue is whether this Board should force the parties to expend time and expense on LILCO procedures which are likely to change, or whether the proceeding should be put on hold until LILCO decides whether to make revisions (and if it so intends, until those revisions are made avialable to all parties).
Plainly, the latter alternative is the proper choice.
Alternatively, if these proceedings are to go forward under the current schedule based on Revision 8 of the Plan, LILCO should not be permitted subsequently to revise its current moni-toring procedures and the Board's final determination should be based on the Revision 8 procedures which are the subject of LILCO's Motion to Reopen.
This, at least, would allow the parties to know what procedures are being litigated.
- Agrin, however, now is the time for the Board to confront these uncertainties so that the bases of this litigation, if it is to proceed, are clearly understood.
2.
LILCO's Facilities Are Not Available For Monitorino And Decontamination Purcoses LILCO's latest reception scheme calls for monitoring and decontamination to be conducted at LILCO operational facilities in Bellmore, Hicksville and Roslyn.
It is evident from recent correspondence, however, that LILCO's proposed use of at least two of these facilities violates local zoning ordinances.
- Thus, those facilities apparently will not be available to LILCO for the purposes proposed under Revision 8 of the Plan which, as of now, forms the basis of this proceeding.
o Attached hereto as Appendix B is a notice to LILCO from the Town Council of the Town of Hempstead, in which the Bellmore facility is located.
The Council is the body which possesses the authority to implement and enforce Hempstead's zoning ordinances.
As stated in the Town of Hempstead's notice, LILCO's proposed use of the Bellmore facility as a " reception center" or for the purposes described in LILCO's Revision 8 of its emer-gency plan is contrary to the present zoning classification.
Any attempt by LILCO to use the Bellmore facility in this manner would violate local zoning laws.
Appendix'B at 2.
In addition, attached as Appendix C is a similar letter from the Town of North Hempstead, in which LILCO's Roslyn facility is located.
The letter again makes it clear that LILCO's proposed use of.that facility would be in violation of North Hempstead's local zoning ordinances and that it therefore would not be available for that use by LILCO in the event of a Shoreham accident.
i For the reasons stated above, it makes no sense to commence litigation premised on facilities which are not available for use l
as proposed in LILCO's Plan.
If LILCO intends to attempt to substitute new facilities for the ones identified in Revision 8, such substitutions should be made before the Board's and parties' time and resources are spent analyzing proposals that will become inoperative.
Accordingly, the schedule should be put on hold l
1
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O pending a statement by LILCO of its intentions.
And, in the absence of the prompt submission of a new proposal, the Board should direct that this proceeding represents LILCO's last opportunity to meet its burden on relocation center issues.--
ligt, that LILCO will not be permitted to obtain any more litigation of new proposals, or concerning new facilities or new procedures -- and that LILCO must accept as a final determina-tion, the Board's rulings based on the adequacy of the facilities in the version of the Plan which is the subject of this pro-ceeding -- i.e., Revision 8.
Accordingly, the Governments submit that provisions 3, 4 and 5 set forth on pages 6-7 above should be implemented.
CONCLUSION For the reasons set forth above, the schedule for litigation of the reception center issues should be held in abeyance pending a statement by LILCO as to its intentions with respect to the deficiencies in its Plan and potential revisions of its Plan and procedures.
And, following receipt of such statements, this Board should, by order, identify the version of the LILCO Plan which is to be the subject of this litigation, and direct that the Board's rulings in this proceeding will be final and binding upon LILCO as to reception center issues.
If the parties are forced to proceed without the clarifications sought by the Governments, the result may be an extraordinary waste of time and
. i
n effort by the Governments and the Board.
Such waste and ineffi-ciency would be unfair and prejudicial to the Governments and should not-be condoned by the Board.
The bottom line here is simple.
This emergency planning proceeding is complex enough without making it more so by closing one's eyes to reality and proceeding in the face of obvious and remediable uncertainties and inefficiencies.
To do so can only result in unnecessary expenditures of time and resources and delay down the road.
The Governments submit that the only reasonable and rational course in this reception center proceeding is to define the subject of the proceeding un front, stick to it throughout the litigation, and then reach a final decision.
To proceed along the current course makes no sense.
Finally, the Governments also request prompt Board consideration of this Motion and stand ready to confer with the Board and the other parties on this issue if the Board sees fit to call for such a conference.
Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney H. Lee Dennison Building Veterans Memorial Highway Hauppauge, New York 11788
( A % d M. A #1 Lawrence C6e Lanpher
)
Karla J. Letsche
/
Christopher M. McMurray KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - Suite 900 Washington, D.C.
20036-5891 Attorneys for Suffolk County '
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Fabian G. Palq)fino /
Richard J. Zahnleufer Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capital Building Albany, New York 12224 Attorneys for Governor Mario M.
Cuomo and the State of New York Stephen 5. Latham
/
Twomey, Latham & Shea P.O. Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton 17 -
i
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00L t'.E TE D rner January 22, 1987
'87 JAN 27 P3 :12 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION g g.;.
00CXL h:. i l rel Before the Atomic Safety and Licensina Board E' t
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
1
)
4 CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON MOTION FOR RECONSIDERATION OF SCHEDULE have been served on the following this 22nd day of January, 1987 by U.S. mail, first class, except as otherwise noted.
Morton B. Margulies, Esq., Chairman
- Mr. Frederick J. Shon*
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.
20555 j-Dr. Jerry R. Kline*
William R. Cumming, Esq.
Atomic Safety and Licensing Board Spence W. Perry, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C.
20555 Federal Emergency Management Agency 500 C Street, S.W., Room 840 Washington, D.C.
20472 4
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b Joel Blau, Esq.
Anthony F. Earley, Jr., Esq.
Director, Utility Intervention General Counsel N.Y. Consumer Protection Board Long Island Lighting Company Suite 1020 175 East Old Country Road Albany, New York 12210 Hicksville, New York 11801 Ms. Elisabeth Talbbi, Clerk W. Taylor Reveley, III, Esq.*
Suffolk County Legislature Hunton & Williams Suffolk County Legislature P.O. Box 1535 Office Building 707 East Main Street Veterans Memorial Highway Richmond, Virginia 23212 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 Mary M. Gundrum, Esq.
Hon. Michael LoGrande New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-116 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. Dox 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, Esq.
Fabian G. Palomino, Esq.
Suffolk County Attorney Special Counsel to the Governor Bldg. 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway State Capitol Hauppauge, New York 11788 Albany, New York 12224 Mr. Jay Dunkleburger Bernard M. Bordenick, Esq.
New York State Energy Office U.S. Nuclear Regulatory Comm.
Agency Building 2 Washington, D.C.
20555 Empire State Plaza Albany, New York 12223 i
s -. -. -. - - -
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 By Telecopy Ciristopher M. McMufray -
e