ML20071M523

Suppl to Petitions to Intervene Listing Contentions Re Des, Per ASLB 820901 Order.Certificate of Svc Encl

ML20071M523
Person / Time
Site:	Catawba
Issue date:	09/22/1982
From:	Guild R, Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP, GUILD, R., PALMETTO ALLIANCE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8209270159
Download: ML20071M523 (17)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of DUKE POWER COMPANY, et al. Docket No. 50-413 S0-41a (Catawba Nuclear Station, )

Units 1 and 2) ) September 22, 1982 PALMETTO ALLIANCE AND CAROLINA ENVIRONMENTAL STUDY GROUP SUPPLEMENT TO PETITIONS TO INTERVENE REGARDING DRAFT _JVIRONMENTAL STATEMENT _

Pursuant to 10 CFR Sections 2.714 (a)(i) and (3)(b) and the Board's Order of September 1,1982, Intervenors' Palmetto All.iance an'd Carolina Environmental Study Group hereby file this Supplement to their Petitions to Intervene listing the contentions which they seek to have litigated in this matter, and the bases therefore, which address issues raised by the Nuclear Regulatory Commission Staff's Draft Environmental Statement (DES) related to the operation of Catawba Nuclear Station, Units 1 and 2, NUREG-0921(August 1982).

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Should the Board construe any of these contentions as an attack upon any provisien thereof, Intervenors request that such rule or regulation be identified and that they be permitted to seek an exception or waiver of the application of such rule or regulation with respect to this particular proceeding. -

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Palmetto Alliance and Carolina Environmental Study Group would respect-fully show that the Application for the necessary licenses to own, use and operate the utilization facilities known as the Catawba Nuclear Station, Units 1 and 2, should be denied or appropriately wnditioned since the grant of such licenses would contravene the National Environmental Policy Act of 1969 (NEPA), Pub. L.91-190, 42 U.S.C. A. Section 4332, Executive Order 11514, Council on Environmental Quality Guidelines of August 1, 1973 (38 FR 20550) and the Commission's own licensing and Regulatory Policy and Procedures for Environmental Protection,10 CFR Section 51.23, where the environmental, 1

economic, socioeconomic and cumulative costs and impacts of the' facility I s

will outweigh any possible benefits, new and additional infonnation now being available which alters the consideration made at the Construction Pennit stage for the facility.

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The Nuclear Regulatory Co'mmission Staff has failed to effectively analyze and balance the environmental, economic, socioeconomic and other costs again any asserted environmental, economic, technical or other benefits of the facility and has totally ignored the alternatives available for reducing or avoid.::9 the adverse environmental or other effects; in support of which Inter-venors would contend:

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1. The probabilities of severe accidents, radiation exposure, and damage are understated, as in figures 5.3, 5.4, 5.4, 5.5, 5.6 and 5.7 of the DES.

The DES recognizes only one serious accident after 400 reactor years of operation, TMI-2, p. 5-46. In this period there were two other serious acci-dents, the partial meltdown at Fermi, p. 5-30, and Browns Ferry 1 and 2, not referenced.' The releases at Browns Ferry were not monitored. A meltdown was averted by improvisation, not by following established guidelines. The Fermi meltdown was limited by the time of scramming. A somewhat more delayed scram would have resulted in more extensive meltdown and increased the pro-bability of a substantial release. The actuality has been three accidents of a potentially very severe sort in 411 reactor years, a probability of one per 133 years of reactor operation. The DES understates serious accident probability in relying on the Reactor Safety Study (NUREG 75/104).

The CP stage FES made no reference to severe accidents.

2. The DES fails to consider or adequately characterize cooling tower drift, pp. 4-3, 4-7. 2,700 lbs. of sulfuric acid (concentration unspecified) are l

l to be added to condenser cooling water; 1,200 lbs. of sodium hypochlorite are also to be added. This will result in the release of chlorine.

- o H2 504 + 2NaC10 --* .Cl2 + Na2SO 4 +H0 2 l However, only 1,014 lbs. of sulfuric acid are required for this reaction.

The consequence is a surplus of 1,686 lbs. The DES provides no information l

as to how, or whether, this sulfuric acid will be neutralized. If it is not, l it will enter the Catawba River in the blowdown and the atmosphere in the drift.

l At an average drift rate of 110 gal / min. (full plant), 42 lbs. per day of I unneutralized sulfuric acid will enter the atmosphere. Sulfuric acid is a corrodent of very low volatility. It will cause damage to objects it contacts:

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r automobiles, farm machinery, wood habitations, cotten fabrics, etc. The DES either overlooks these consequences or fails to indicate that the excess of sulfuric acid in the cooling water will be neutralized.

3. The DES differs from the CP FES in that Chlorine was to be injected and other additives had not been firmly identified. A total of 734 lbs. per day of Chlorine will be released by the reaction of sulfuric acid with sodium hypochlorite. The DES only indirectly indicates the disposition of this chlorine. It has it showing up in the cooling tower blowdown as the chloride ion, Table 4.2. This is not realistic. A large part of the Chlorine, quite possibly most of it, will leave the. cooling water in the form of a gas in the cooling' tower vapor discharge. The vapor state Chlorine will be noxious.

The effect on people, particularly those with respiratory problems, should be ascertained. There will also be a corrodent effect on metals due both to Chlorine in the vapor discharge and in the drift. The DES is deficient in not addressing this impact. The DES differs from the CP FES in that biocide application is doubled p. 4-3.

4. The DES unnecessisarily obfuscated the matter of water flow. Members of the general public will be confused, and possibly mislead, by the variety of units, not simply English and metric, by which flow rate for water and chemicals are presented. For example:

English Metric F6F water flow, p 4-2 cubic feet /second cubic meters /second both units chemical flow, p 4-3 pounds / day kilograms / day one unit water flow, Table 4.1 gallons / minute liters / minute one unit Further in Table 4.1, for which the data are for one unit, there is no indi-cation of basis. A reasonable interpretation would be that it is for both units- Particularly confusing are the changes in time base; seconds, minutes 4

r and days. The DES should either represent quantitative information in con-sistent units, or supply conversion factors. For example, a seemingly 3

trivial blowdown of 0.3 m /sec. (p. 4-2) corresponds to 57,100,000 pounds per day or 28,500 tons per day. This DES differs from the CP FES in that water use was consistently expressed as cfs.

5. The DES differs from the LP FES in that it rates each Catawba unit as 3,427 MWt versus 3,411 MWt and indicates a net rating of 1,145 MWe as opposed to a design power level of 1,211 MWe per unit. In any event these rates are uncertain in that Catawba is represented as a sister plant to the McGuire Station, and the McGuire Station presently operates at a maximum output of 862.5 MWe (75% of 1,150 MWe). This impinges on cost / benefit considerations.

6. The DES is deficient in its cost / benefit weighing, Table 6.1. It assesses the benefit of electrical energy as large. Assuming a 60% capacity factor it posits an ann' sal production of 12 billion KWh. Based on the present derating of McGuire it is reasonable to ask if a rating of 9 billion annual KWh for an indefinite period would not better reflect present experience.

The Applicant has at present a very substantial generating reserve of about 30%. If McGuire-2 goes on line before Catawba-1, as scheduled, and if Applicant's present forecast of 2.9% annual growth is used, the reserve in 1985, at the time of planned first operation of Catawba-1, will also be about 30%. Under these circumstances the operation of Catawba will require the closing down of other capacity, which is a cost in the sense that a useful facility is withdrawn from use. In a fair striking of a balance a cost of, as the case may be, either 12 billion or 9 billion KWh per year should be shown.

It should receive an assessment as "large", and the net benefit be taken as nil.

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7. The DES is deficient in its cost / benefit assessment in that it considers only generating costs. "The economic costs associated with station operation include fuel costs and operation and maintenance costs... ," 6.4.2.1. The real bus bar cost includes fixed charges. The fixed charges on McGuire, a sister plant, have been a major factor in driving up electric rates. The DES has not compared the bus bar costs estimated for Catawba into the bus bar costs of the capacity which it will displace. All cost figures, including plant, have changed substantially since the CP FES. A difference between the CP FES is that it provides a capital cost figure for Catawba of $1,055,272,000, Table 10.2. The OL DES does not provide a capital cost figure.

8. The DES concludes that the overall socio-economic impavt of Catawba is beneficial, vi(j), 6.4.2.2., 5-12. The actual cost to residential, comercial, industrial and other customers of substituting Catawba generation for existing generation has not been considered. In view of the errors in Applicant's past forecasts of need for power, as attested by the cancellation of all three Perkins nuclear units, and two of the three Cherokee units, it is uncertain whether either Catawba unit will be required to meet demand and provide adequate reserve in the forseeable future. If this is the case it is clear that the cost impact on Applicant's customers will be adverse and large, quite possible reversing the cost / benefit balance.

9. Since the CP FES issued, an amendment has permitted a substantial enlarge-ment of the Catawba fuel pool. Since the CP FES both fuel pool accidents relai4ng to handling (to be discussed in the SER, p. 5-19) and pool water loss have become topics of concern. The environmental consequences cf such mishaps should be considered. They appear not to be explicitly considered in the DES.

The consequences of routine operation do not appear to be specifically considered, 6

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it merely having asserted that routine releases from spent fuel are taken into account in Section 5.9 and Appendix D, p. 5-19.

10. The DES is deficient in regard to the consequences of the tranship-ment of spent fuel from Oconee and McGuire Station to Catawba, vi(1), 5.9.3.1.2.

and Appendix G. The consequences of accidents are not referred to in quan-titative terms, although the estimated probabilities of accidents of different levels of severity are presented. Such transhipment was not considered in the CP FES.

11. A substantial part of the population placed at risk by nuclear operations at and relating to Catawba are also placed at risk by similar operations at McGui re. A realistic assessment of Catawba impacts will take into considera-tion McGuire risks. The summing of probabilities is practiced in the DES in regard to providing an estimate of the probability of the consequences of severe accidents, "If the probability of sustaining a total loss of the ori-ginal facility is taken as the sum of the occurrence of a core-melt accident (the sum of the probabilities for ten categories in Table 5.10), then..."

l There is no corresponding concept in the CP FES.

12. The DES is incomplete in an apparent essential, an indication of the inventory during operation of nitrogen-16. It is stated that " nitrogen-16 (is) a radionuclide produced in the reactor core.", p. 5-19. Nitrogen-16 is also said to be the primary source of within plant radiation. However, it is not given in the radionuclide inventory of Table 5.8. Is the DES correct t

l in regard to the production of nitrogen-16?

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13. The DES states that "offsite radiation levels are continuously monitored I with thermoluminescent detectors." (emphasis supplied), p. 5-15. The impression l

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r i given by this language is that the monitoring is in real time. It is not.

It is intennittent and depends on the intervals at which the TLD's are evaluated.

This " error" should be corrected and the statement disregarded in terms of the consideration of Palmetto Alliance contention 27,

14. The calculations of dose commitments, DES 5.4.3.1, differs from that in the CP FES. " Calculation for the midpoint of station operation represents an average exposure over the life of the plant." We doubt the correctness of this assumption. Longer-lived radionuclides will build up, increasing the dose level. Bio-accumulated radionuclides will also build up. We doubt the general applicability of the concept that "most of the internal dose commit-ment for each nuclide is given during the first few years of exposure .,

because of the turnover of the nuclide by physiological processes and radio-active decay". We particularly view Strontium 90 as a significant exception to this approach. We believe that, as a result, DES dose commitments are non-conservative and will understate actual exposure.

15. We believe that the DES errs in its treatment of airborne effluents.

It states, p. 5-19, that, "Among the airborne effluents the radioisotopes of the fission product noble gases, Krypton and Xenon, as well as of Argon, do not deposit on the ground nor are they absorbed and accumulated within living organisms; therefore, the noble gas effluents act primarily as a source of direct external radiation emanating from the effluent plume."

This statement is literally correct, yet quite misleading. In the instant that a Krypton nucleus in the lung emits radiation it becomes a Rubidium nucleus, a metal and potentially a cation . either of which can deposit on the ground, or in a lung depending on where it came into existence. Simi-larly, Kenon converts to Cesium, also a metal and potentially a cation.

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r Based on the prevalence of Krypton and half life of the isotope, DES Table 5.8, Rubidium 85, 87 or 88 will form. Rubidium 85, which will form in the least amount, is a stable isotope. Rubidium 87, which will form in next largest amount, is a beta emitter with a very long (6 x 10 years ) half life.

however, Rubidium 88, formed in the largest amount, has a half life of about 18 months and is an emitter of highly energetic beta and gamma radiation.

Xenon-133 and 135 are present in substantial amounts. Cesium-133 is stable.

Cesium-135 is a beta emitter of about 3 x 105 y ear half life. The noble gases which irradiate the lung leave a legacy of radioactive cations in the lung and other exposed tissue, and surfaces generally. The dose contributions of the noble cas produced radioactive isotopes of rubidium and cesium should be considered in the DES.

16. The DES fails to consider this aspect of the enlarged fuel pool; the effect of the crash of a heavy aircraft on the fuel pool structure. Although external hazards are said to be reviewed, p. 5-33, there is no indication that this specific hazard was found to be negligibly small. Within the past decade a commercial airliner crashed not far from the Catawba site. Morning fogs are a frequent occurrence at the site, a contributing factor to the air-plane accident. There is no reference to morning fogs in the DES, but it is recognized that the plume will cause fog, p. 5-6. The fuel pool building is less substantial in structure than the containment and is only partially shielded by the containments, figure 4.1. A crash into the fuel pool accom-l panied by fire could disable the water circulation and supply of'the pool.

Depending on the heat supplied to the pool by spent fuel, and the~ time necessary to regain functionality, the pool water could boil down, leading to fuel assembly exposure and cladding failure. Sufficiently heavy fragments of the l 9 l

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r plane could damage the cladding of assemblies in the pool by impact. The consequences of the most severe accident would cause a release of the magni-tude of the most severe reactor accidents and should be considered in the DES.

17. The DES is concerned with environmental impacts. Presumably these are best represented as the entire range from trivial to serious, in conjunction with the estimates of likelihood. The DES averages meteriological conditions in its consideration of accidents, 5.9.4.5. Because atmospheric inversions and quiet air are a very common feature in this region, accident consequences should be calculated for the extreme condition of inversion and very slow air movement.

In the matter of assessing serious accidents, the environmental assumptions are complex and again do not appear to consider extreme weather, p. 5-37.

The DES, which differs from the CP FES in considering severe accidents, is at fault in not considering the full range of radiological impacts by not considering extreme, but frequently encountered, weather conditions.

18. The DES considers interdiction to reduce the radiological impact from severe accidents, p. 5-40. The costs of interdiciton are considered in figure 5.7 and Table 5.11. However, an evaluation of the availability of facilities for relocation and the non-monetary impacts of the location are not considered. This topic was not addressed in the CP FES and is not adequately considered in the DES.

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19. Failure to evaluate the environmental costs of operation of Catawba as a storage facility for spent fuel from other Duke nuclear facilities and transpor-tation of that irradiated fuel to Catawba compromises the validity of the favorable cost-benefit balance struck at the construction perndt phase of this proceeding.

Since the CP stage hearing, Duke Power has considerably expanded the Catawba spent fuel pool capacity and provided for denser storage of irradiated fuel. FSAR Table 1.2.2-1. Applicants intend to use Catawba for storage of irradiated fuel from the McGuire and Oconee nuclear facilities of Duke Power Company. FSAR 9.1.2.4, OL Application, pp.11 - 12.

The " Environmental Impact Appraisal performed by NRC Staff, pp. G-1, G-2 and G-3 of the DES is totally inadequate to provide a basis for agency approval of the licenses sought. The staff totally fails to analyze or even assert the need for the transhipment and storage of spent fuel from other plants at Catawba, to evaluate either quantitatively or qualitatively the

" benefit" to be derived from this action; grossly underestimate the environ-mental costs and other impacts from the proposed action such as the risks of plainly credible very severe accidents in transhipment under conditions more severe than described in Appendix B to 10 CFR Part 70 or involving defective casks which can not withstand those conditions; and, further the Staf f totally fails to analyze or consider the alternatives available for reducing or avoiding these adverse effects such as on site rod consol-idation, storage in dry casks, in drywells beneath grade, in concrete storage silos or in air-cooled vaults -- alternatives which are easily available at lower total cost.

" Preliminary Assessment of Alternative Dry Storage Methods for the Storage of Commercial Spent Nuclear Fuel", DOE /ET/47929-1 (UC-85) E.R. Johnson Associates, Inc. (November, 1981).

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20. The favorable cost / benefit analysis struck at the CP stage is fatally compromised by the failure of the NRC Staff to calculate costs and benefits based upon substantially reduced levels of operation due to defective Westinghouse Model D steam generators which have experienced rapid tube wear caused by flow-induced vibrations which pose the threat of tube weakening, leakage or rupture, as well as the costs associated with repair and replacement with very high worker exposure rates and the increased risk of radiation exposure to the public. Duke Power Company's McGuire Unit 1, Catawba's sister plant, has operated at severely reduced power levels since declared commercial December, 1981 due to premature tube wear experienced during very brief high power level operation. V.C. Summer Unit 1 operating license will restrict power levels to below 50% until this premature tube wear problem in its Model D steam generators is solved. The Staff does not acknowledge or weigh these costs in the DES.

21. The long term somatic and genetic health effects of radiation releases from the facility during normal operations, and from the uranium fuel cycle have been underestimated by the NRC Staff in the DES, pp. 5-22 and Appendix C, even where such releases are within existing guidelines. The Staff relies on the BEIR I study for the risk estimators it employs in the DES, p. 5-17 and BEIR III for establishment of its " upper limit" for health effects,

p. 5-18. The work of K.Z. Morgan, Bernd Franke of Heidelberg, and others calls into serious question the analysis relied upon. For example, BEIR III's reliance on.the linear hypothesi, may seriously understate health effects at lower level dose rates; and the commission's food chain analysis may minimize the uptake of soil borne radiation by plants and thereby underestimate concentrations in milk and meat. Such questions suggest that the Staff' has seriously underestimated the health effects from facility operation.

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22. The NRC Staff has f ailed to adequately assess the impacts of serious accidents at the tacility, beyond design basis. The FBS-CP made no analysis of such serious accidents and the DES analysis, required by the Commission's Statement of Interim Policy, 45 F.R. 40101 (June 13, 1980) seriously under-estimates the probability and consequences of plainly credible site-specific serious accidents and is deficient in many respects.

The probabilistic analysis employed in the Reactor Safety Study (WASH 1400) has been so seriously criticized as to make its use in licensing prodeedings as a basis for decision-making entirely inappropriate. "The consequence model used in WASH 1400 should be substantially improved, and its sensitivities explored, before it is used in the regulatory process."

NUREG CR 0400, " Risk Assessment Review Group Report to the U.S. Nuclear Regulatory Commission, H.W. Lewis, Chairman," p. xi. The Staff continues to rely on the " consequence model used in the RSS," p. 5-37. While the Staff acknowledges the " substantial uncertainties" in the probabilities derived from the quantification of human error and estimates of component failure rates, p. 5-36, it nonetheless relies on this same probabalistic analysis on th. tuais of its " qualitative judgement...that the uncertainty bounds could be well over a factor of 10, but not as large as a factor of 100."

p. 5-46.

The Staf f claims to address the criticisms of the RSS by " eliminating the ' smoothing technique'" and by the evaluation of " individual dominant accident sequences" rather thau grouping them. p. B-1. Yet it still relie.

only on the probabilities shown for four RSS scenarios, Table 5.10, and represents the probability of such an accident at the facility as the sum of the probabilities for these events alone. p. 5-45.

The design of this facility differs from that of the reference reactor considered in WASH 1400 in such significant manner as to adversely affect 13 i

r the probabilistic risk assessment employed in that study and relied upon by the Staff. " Reactor Safety Study Methodology Application Program:

Sequoyah #1 PWR Power Plant," NUREG CR 1659/1 of 4 (February,1981),

ER - OL 7.1-1. The Staff notes "the importance of hydrogen control measures for reducing the liklihood of failing the ice condensor containment,"

but relies on the assertion that "(t)he applicant for Catawba has plans to satisfy the Commission's requirement on hydrogen control," p. E-1, without further analysis of the significance of this design feature for accident impacts.

The Staff's serious accident analysis is further flawed by its reliance, without basis, upon a flawless execution of the most unrealistic emergency plan -- assuming complete evacuation of the plume pathway and relocation of all persons in the pathway out to 25 miles and the full availability of medical care for all persons exposed in excess of 200 rems. Appendix F.

Although not specified by the Staff this means the downwind populations of Charlotte, North Carolina -- 310,794 people in 1980, 11 miles northeast of the site, p. 5-33 and Figure 5.9. Since no emergency plans have been published and the Staff has no plan for the facility to review as a basis for its optimism, it can only promise to supplement this environmental analysis if it concludes from such a review that accident impacts will be "significantly larger." p. 5-34. Such a revised analysis should be performed now.

23. The evaluation of costs and benefits of the facility under NBPA conducted at the CP stage was inaccurate since the costs associated with the back end of the nuclear fuel cycle were not given sufficient consideration. The NRC Staff continues to rely on the Table S - 3 rule to assess the costs associated with reprocessing, storage and disposal of spent fuel and other nuclear waste, p. 5-47 and Appendix C, despite the recent invalidation of the rule by the U.S. Court of Appeals.

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e "Because they failed to allow for proper consideration of the uncertainties concerning the long term isolation of high level and transuranic waste..."

Natural Resources Defense Council, NRC, No. 74-1586. Slip Op. at 11 (D.C. Cir.

April 27, 1982) . The Staf f must do more than simply assert that such wastes "are to be buried at a Federal repository and that no release to the environment is associated with such disposal." p. C-6. Such a dismissal of environmental effects is meaningless in light of the known uncertainties associated with the back end of the fuel cycle. These costs must be fully evaluated and considered in the cost / benefit balance.

WHEREFORE: having supplemented their Petitions to Intervene with this list of contentions, and the bases therefore, Intervenors Palmetto Alliance and Carolina Environmental Study Group request that these contentions be admitted as issues for litigation in this proceeing, that they be heard in support of their interest as herein asserted, and that the Application of Duke Power Company, et al. , for licenses with respect to the Catawba Nuclear Station, Units 1 and 2, be denied, or so conditioned as to protect the health, safety and economic interest of the Intervenors d the public.

D&%%Ir Jefse L. Riley /'

\A RobertGuildG 4

Carolina Environmental Study Group 314 Pall Mall 854 Henley Place Columbia, South Carolina Charlotte, North Carolina 28207 Attorney for Palmetto Alliance 15

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

DUKE POWER COMPANY,fe_t,:al.

t ) Docket No. 50-413

) 50-414 (Catawba Nuclear Station, )

Units 1 and 2)' )

CERTIFICATE:0F SERVICE I hereby certify that copies of Palmetto Alliance and Carolina Environmental Study Group Supplement to Petitions to Intervene Regarding Draft Environmental Statement in the above captioned matters, have been served upon the following by deposit in the United States mail this 22nd day of sept., 1982.

James L. Kelley, Chairman George E. Johnson, Esq.

Atomic Safety and Licensing Office of the Executive Legal Board Panel Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commissien Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. A. Dixon Callihan William L. Porter, Esq.

Union Carbide Corporation Albert .V, Carr, Jr. , Esq.

P.O. Box Y Ellen T. Ruff, Esq.

Oak Ridge, Tennessee 37830 Duke Power Company P.O. Box 33189 Dr. Richard R. Foster Charlotte, North Carolina 28242 P.O. Box 4263 Sunriver, Oregon 97701 Richard P. Wilson, Esq.

Assistant Attorney General Chairman State of South Carolina Atomic Safety and Licensing P.O. Box 11549 Board Panel Columbia, South Carolina 29211 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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Chainnan Jesse.L.'Riley Atomic Safety and Licensing 854 Henley Place Appeal Board Charlotte, North Carolina 28207 U.S. Nuclear Regulatory Comission ~ Scott Stucky Washington, D.C. 20555 Docketing and Service Station U.S. Nuclear Regulatory Henry A. Presler Comission Charlotte-Mecklenburg Washington, D.C. 20555 Environmental Coalition 943 Henley Place Charlotte, North Carolina 28207 J. Michael McGarry, III, Esq.

Debevoise & Liberman 1200 Seventeenth St., N.W.

Washington, DC 20036 g

RobertBuildQ Attorney for Palmetto Alliance l

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