ML20004D846
| ML20004D846 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1981 |
| From: | Hendrie J NRC COMMISSION (OCM) |
| To: | Vento B HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML20004D843 | List: |
| References | |
| NUDOCS 8106100209 | |
| Download: ML20004D846 (12) | |
Text
'
o UNITED STATES
~,,
7 NUCLEAR REGULATORY COMMISSION nj pf' W ASHINGTON, D. C. 20S55 V
- g June 4, 1981 CHAIRMAN The Honorable Bruce F. Vento Comittee on Interior and Insular Affairs United States House of Representatives Washington, D. C.
20515
Dear Congressman Vento:
The Nuclear Regulatory Comission staff has prepared the enclosed response to your March 16, 1981 lettar concerning the requirements of Section 303 of Public Law 96-295 for reporting thc. direct and indirect costs of issuing licenses and permits for, and inspections of, nuclear power plants.
On April 6,19S1, we wrote you on this matter and indicated that we would provide you with explicit answers to your questions by mid-May 1981. Standard definitions of direct cost, indirect cost and other terms germane to the calculation of licensing costs are included as Attachment 1 to our response.
Each NRC office, board and panel performing activities related to the process of licensing reactors contributed informatio,1 which is reflected in the cost figures you requested. The costs which we have provided in response to your questions are best estimates based upon the most recent budget and cost infomation available. They have not been subject to the analysis and review which was done in developing the existing 1978 license fee schedule. The Comission has tasked the Executive Director to reassess the costs of licensing and inspection by August 31, 1981 and provide the Comission with a proposed adjustment of the fee schedule using current rates to cover more completely the agency cost of licensing and inspection.
Subsequent discussions with your staff have indicated the desire for addi-tional infomation on how the NRC develops fees charged for licensing purposes.
This information is enclosed as Attachment 2.
We hope these answers are responsive to your needs.
Please let us know if you
..have, any, further questions on this matter.
kincerely,
\\
kt hdy 1
eph M. Hendrie
Enclosures:
l As Stated 4
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C'.157 'O: 1 During FY 1980, what has been the total cost to the NRC for reviewing reactor construction permit applications? What is
- ne current tstimated cost of an NRC construction permit review, including all costs incurred pricr to construction permit issuance?
ANSWER During FY 1980 the total cost to the NRC of reviewing reactor construction permit applications was approximately 53.4 million.
Of this amount, about S1.5 million was direct cost and about $1.9 million was indirect cost.
l Definitions for direct cost, indirect cost, and other terms germane to cost calculations are provided in Attachment 1.
i According to current estimates, the cost of an NRC construction permit review for a single custom plant ranges from approximately $2.4 million to 53.4 million.
Estimates for direct cost range from about $1.3 million to $1.7 million and estimates for indirect cost range from about $1.2 million to 51.7 million.
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"' 7::N During FY 1980, wnat has been the total cost to the NRC for r-reviewing reactor coerating license applications? What is the current estimatec cost of an NRC operating license review,
-o including all costs incurred prior to operating license issuance?
a::5.,ER During FY 1980 the total cost to the NRC for reviewing reactor operating license applications was approximately S36.1 million.
Of this amount, about 520.4 million was direct cost and about $15.7 million was indirect cost.
Definitions for direct cost, indirect cost and other terms germane to cost calculations are provided in Attachment 1.
According to current estimates, the cost of an NRC operating license review for a single custom plant ranges from approximately 52.8 million to 53.3 million.
Estimates for direct cost range from about S1.5 million to $1.7 mill. ion and
. estimates for indirect cost range from about S1.4 million to 51.6 million.
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O'.'E 5 7.*0N 3 During FY 1980, what was the total cost to the NRC for inspections
-o of nuclear power plants under construction?
ANSWER During FY 1980, the total cost to the NRC for inspections of Nuclear Power Plants under construction (i.e., those under CP review and OL review) was approximately $14.8 million.
Of this ' amount, about $6.0 million was direct cost and about $8.8 million was indirect cost. All of these costs (apportioned) are included in the answers to Questions 1 and 2.
See Atitachment 1 for definitions o f te nns.
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C'.Ti-*:" 4 During FY 1980, wnat was the total cost to the NRC for inspections of operating nuclear plants?
A *iS'a*E R During FY 1980 the total costs to the NRC for inspections of operating nuclear plants was approximately $28.4 million. Of this amount, about $12.9 million was direct cost and about $15.5 million was indirect cost.
See Attachment i for definitions of tenns.
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- ^*: 5' During FY 1980, what was the total cc:t to the NRC for inspections of vendors and contractors (includinc Nuclear Steam Supply System manufacturtrs, Architect & Engineering firms, Fuel Suppliers, Component Suppliers, and ASME Vendors)?
ANSWER During FY 1980, the total cost to the NRC for inspections of vendors and con-tractors including Nuclear Steam Supply System manufacturers, Architect and Engineering finns, Fuel Suppliers, Component Suppliers and ASME Vendors was approximately 52.2 million.
Of this amount, about 50.9 million was direct cost and about $1.3 million was indirect cost. See Attachment 1 for definitions of tenns.
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CUESTION 6:
For each expenditure of NRC funds enumerated in Questions l-5 above, how much revenue has been recovered by the l
Federal Government?
AN5h'ER:
During FY 1980, collections from the assessment of license i
fees are as follows:
t 1.
No collections were made by the Comission for the review t
of construction permit applications.
There 'were costs incurred during the fiscal year; however, Comission regulations provide that construction permit fees are to be collected when NRC completes its review.
Since there were no construction permits issued during FY 1980, no construction permit fees were l
collected.
2.
$1.6 million was collected in FY 1980 for the issuanc.e of operating licenses.
As with construction permits, fees for licenses are collected when NRC completes its revier.
The Commission's FY 1980 costs in this particular area i
represent not only costs for the licenses issued but also' 7
work in progress.on licenses which are expected to be t
issued in subsequent years.
3.
About 5900,000 was collected for inspections perfomed at nuclear power plant construct. ion sites.
This 5900,000 i
is included in the $1.6 million shown in the operating j
license fees shown (Ji 2 above.
For fea purposes, we i
consider inspection costs incurred from the date the construction permit application is tendered to the date the permit is issued to be a part of the construction permit review costs.
Likewise, inspection costs incurt ed from the date the construction permit is issued to the issuance of the operating license are a part of the operating license review costs.
Thus, the 5900,000 represents the inspection portion of the three operating license fees collected in FY 1980.
4.
55.8 million was collected for routine inspections of b
operating nuclear power plants.
Part 10 CFR 170 of the Comission's regulations limit cost recovery to routine type inspections.
Non-routine inspections such as investigations, incident /accioent response or enforcement inspections are not subject to fees.
The costs of the non-routine type inspections, however, have been included in the tota'l FY 1980 costs shown for inspections of operating nuclear power plants.
l 5.
N'> charges were made by the Commission for quality assurance /
quality control inspections of vendors.
Commission guidelines provide that fees will be imposed for NRC services rendered at the. request of an organization where special benefits will be accrued from that NRC service.
NRC'does not consider vendors
_ arid, architect engineers to have received any special benefits from an NRC inspection.
)
Dire:: Costs The direct costs consist of the salaries and. benefits of the professional staff, program (contractual) support and travel directly related to the activity.
Indirect Costs The indirect costs consist of: (a) the salafies and benefits of the professica support staff for each activity, (b) organizational support (housekeeping) costs applicable to each NRC Office involved,in the activitp which were allocated to that Office's direct and indirect labor associated with the activity; (c) general and administrative costs, which were allocated to all direct and indirect labor associated with each activity.
Manoower Professional Direct - is defined as effort by those professionals whose activities are airectly related to the individual office mission.
This would encompass'such activities as reviewing license applications, inspecting reactors, writing standards, technically monitoring and directing research, conducting hearings, etc.
This. category is normally used to include all personnel at or below branch level except for branch chief and secretarial / clerical personnel._
ProfessionalSupoort-Effortbythoseclericalandsuoerhisory.cositions at the oranen level designed t'o provide airect support-type services to.
tee professional.
Professional support positions are relatively sensitive (variable) to fluctuations in the size of an office.
The need for secre-tarial support, for example, is generally more directly influenced by the size of an office than the functions performed.
Hence, this need should normally vary with the number of professionals to be supported.
Other positions which are primarily influenced by the number of professionals will include branch chiefs.
OroanizationalSuccort-Includesthosepositionsthatprohidegeneral support to professional direct personnel and to professional support per-sonnel.
Positions in this category perform work that is primarily dependent upon the scope of the functions assigned rather than the number of pro-
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~fes'sibnals assigned.
Organi:ational support positions are "ormally con.
sidered to be all cositions at the Assistant Director (AD1 level and above.
In additier., all cositions on tne Procram Succort staff are cons 1oereo as crean125tlonal succort pos1tlons.
Actihities CPReview-Forreportingpurposes,aCPrehiewisdefinedastherehiew conouctea from the date the application is tendered with the NRC to the date of issuance of the construction pernit.
OLReview-Forreportingpurposes,adOLrehiewisdefinedastherehiew
-concucteo by the NRC frem the date of CP issuance to the date of OL issuance authorizing 100% power operation.
i.
I Development of NRC License Fees i
l The schedule of fees in 10 CFR 170 of the Commission's regulations whIch became effective on March 23, 1978 are based on 31 U.S.C. 483a, which was construed in l
Supreme Court decisions of March 4,1974, and decisions of the U.S. Court of l
16, 1976.
As a result of these Appetis for the District of Columbia on Decembercourt decisions, the C Using these guidelines and estimates in the Comission's FY 1977 of license fees.
Subsequently, this schedule was budget, the existing fee schedule was developed.
challenged in the U.S. Court of Appeals for the Fifth Circuit which issued an opinion in August 1979 upholding in all respects the NRC's existing 1978 schedule and guidelines for fees.
In summary, Comission guidelines for fee assessment provide that fees may be assessed to persons who are identifiable recipients of special benefits conferred Such special benefit's include by specifically identified activities of the NRC.all services necessary fo or amendment and all services necessary to assist a recipient in complying with The
. statutory obligations or obligations under the Comission's regulations.
fees established by regulation include the direct and indirect costs of providing The Commission has stipulated that where the identification of the the service.
ultimate beneficiary of the NRC activity is obscure, the cost of the activity should not be included in the cost basis for fees.
Following Commission guidelines, the 1978 schedule.of fees was developed as follows The activities performed and the services provided by all NRC 1.
offices were reviewed and analyzed.
Only.those services which provided special benefits to identifiable recipients were included for fee computation.
Specific offices were identified as those directly involved 2.
in the review of applications / requests, and issuing licenses, approvals, or performing inspections: Office of Nuclear Reactor Regulation (NRR), Office of Inspection and Enforcement (IE), Office of Nuclear Material Safety and Safeguards (NMSS),
Since professional employees in each ACRS, ASLBP, and ASLAp.
of these offices are involved in the processing of applications and performing inspections, an average cost / man-year to maintain
.a professional employee.(professional rate) was developed for each office.
In addition to the offices described in item 2 atove which 3.
are directly involved in the licensing or inspection process, other offices such as Controller, Executive Legal Director, etc.,
which provide indirect support to the licensing and inspection process and which were included, after a detailed analysis of their activities.
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program support services (contractual line items) were individually 4.
reviewed to determine whether they supported the review of applications, Those contractual services permits, licenses, approvals or inspections.
which were fouri.i to support the review, licensing, inspection or hearing process we c considered to be providing a special benefit and were included in the fee computation.
Each operating office responsible for the processing of applications 5.
and conducting inspections and hearings, determined the average professional manpower (expressed in man-years or man-hours) required to process each category or type of application, license, amendment, or inspection.
The proposed fee for a specific category of license application 6.
was computed by multiplying the average professional manpower i
required to perform the service times the professional man-year or man-hour rate, and adding a proportionate share of the costs of contractual services.
Once the proposed fees were computed, they were published in the Federal Register All coments were then carefully considered and the final for public comment.
rule was published in the Federal Register.
l
, that fees in certain instances; e.g., those assessed The fee schedule pr..
for power reactor construction permits and operating licenses are to be based on the actual costs (manpower and contractual) expended to complete the review, l
not to exceed certain upper limits established by the Commission.
For example, as shown in the attached schedule the fee established by regulation for the l
custom review of an operating license for a single unit at a site is slightly more than $1 million. When the,Comission's review costs exceed $1 million, no additional fees are assessed.
If the review costs are less than $1 millioc then the s
Comission would refund the difference between the actual cost of the review and Fees the $1 million which was paid by the licensee upon issuance of the license.
were also established for other types of facility reviews; e.g., review of duplicate plants, replicate plants, etc.
License fees have not been readjusted since 1978, because the existing fee schedule was challenged unsuccessfully in court by several utilities.
In the meantime, the NRC has been attempting to collect costs incurred in the review of facility These applicants have all applications subsequently withdrawn by utilities.A notice explaining the Comission's refused.to pay where the NRC has billed.
position was published in the Federal Register.
It is expected that this matter will be litigated.
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4
i P ArU 170 0 FEES FOR FACILmES AND MATEMALS UCENSES-
~
- A Nen>. avinorizing the use of newal application when !!!ec wtth the tr; trupeetten lees. Inspec*. ten fees emi n.. r.v materwa.s inietcing enev in Commatacr.
are pays R upop nectetuon W the y des s es and
..,n t.ir ers. pres id ed.
(e) Approvcl lees Tees for spent
- %.. e s e s the.li utner lic e n se c fuel ca.st Enc satsomr centainer 19 (h).ifefAr d c/ Pcvme*tt Tee :ty 2 Np.humeierini. 5 iurce matertsf. or mytis, stancartzec spent fuel itcun ments antil be ey checa, c.C c-K spe:wi n dcar materies in the device or ty destrn approvd.t. are censtrucuen money creer mace paystle to the,.,.;
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gycjeg p,,g.4atcry Commzon.
60 r.144 M e r
- Ill re
- 1. n 'e ct to the feet prescrined in ; 170 31 the Comnusalon when the b 170.*!
uon by of the pr=;ect is completet.
Scheduse of fees for preeacuen
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review k (St A !! cense !cr postession and use Tees for facility reference stanctic. ;
&ad uuhattaen (misum, tw of ref.
of byproduct matenal, sourte maten*
taed ceslen approvus will be stad in a
"'" stawardised se igne, an e,e.
al. or special nucles.r matertal toplied five (S)installmenta based on payment eial meest, m
f3r by or tasued to. En asency of L cf 20 pereent of the approvd fee (see O footnote 3 { MC. D ta esch of the first
- U'"*8 g State or any pollucal subdivtsson g tnereof. except for iteenses which su*
five (5) units of the scoreved cessen
.s ; a set, and appetla M rder tre referenced in an topiletuonts) a thortse distribuuan of Dyprody.t mt.
tenal. source matenal. or special nu.
filed by a utility or utillues.
th u"#
m l pty the fees set forth in the a
carts materttJ. or products containing (f) Spectal hone: has. Tees f or spe.
table below.
- typroduct matenal, source matentl.
cial projects are styttle upon notifica.
(b) Applicants for special project re.
or special nutjent matertal, or licenses uon by the Cornmission when the f.4hort:.tng services to any person rerter of the project :s completed-news anaR pty fees ta seputtely de.
c*her tat.n a.n a.gency or political sub.
l termmec by the Commission.
alvtalon of the State.
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(Pt t !) The Commission may, upon p,,,,,
nephcation b) an interested person, or p,,.
upon inn m.n initiative. grant suJa es.
A.Pe w m aecr
,a emptions from the re:virements of this 8**
- * * ' ~ * **
n.st.a n Jrter.:nes are authorised bs cairveuen semn-nm"un"e -
8 '.88"eso carwarueuen oemn-caneu E
!.. and are other m abe in the Public in'.
- * "'"*~ "* **""mn i usut
- 04.wo 3teress (21 Apphcations for caemption i esame,emse easien-Amismusa-catrueuen eman osma.tne mnas-canevenni wute ses.aco 3 snuer this Paragrapn may meluJle ac.
anseo euem, unut e.
canstrunien ounut-Am --
e.4.we las stics such an. but not hmited to,the use censuuruen ermn-caneumni van.
us.seo o
censuveuen semn-rwit seenuanJ uan naasumana anass ist.tso
..f Igenseu nurerisin f.sr educational of E 0*'N3"8 8"M*
pm unn IJ342ee e ncommercia puehc disolays or scien. m a
comune e _-
- m.. man
- assano sg osermn,i.eenn-nm is.euen, unn measu ena minus 3
1,hw GCic colleCuona. t)) lDeneted 43 FR U20.1 w
- s. amane.ruinee e=sn-Assaiemu n-c nstruen omt ttrone tasm a
neams,unne c.=rueuen emui-nm man
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hl 30.12 Parment of fe c n.trucuan wen-caneamns unne su.seo ses. zoo t
cenniuetan wma-ares is i.at Appheaston feca. Ea.ch applica.
comune serve-n-u.enussa uma massu.nu man _
m,,.see ees Cornune ueer -.._ vano su.eao 1:en for which a fee la prescribed thall ognune assem-mm asentaana umst ameaumai mes be accompaJilec by & remittance in Ene seuse full amount of the fee. No toglicatlon n.e,...
vi!J be n.ccepted !or filing or processed
- a. trunir twennas a Amismosn-cen.uneu e orma Iewr la paymertt of the fuM tmDung w auewer construen oman-PWut uma st3.a e tas.se
- Je'. fled. ApplictUons Ior whKA no mense ausser emme comuueuen ermn-cancurmet unas+
o 1suco r*:nttlance ts receivec mty be returned one ewnem anaanse w conswutuen semn Pwet seenueu unn amenmno maw me e.eas for essa CF nas osermune paense-Pwat mast t.t the applietnt. All appilettlett fees of saases.
oorroune beenne-C*neurant unn' pae.aee will be chargrd tirespectlve of the O*""8 ""*-Mm isenunu unn measumand ensus set.aee Commission's thspostuott of the appil ese.3ee cattora or & Withdrawal of the tpp!!ct.'
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serou mest steem sussey emem construcuen ermn-Ceneumnt urut*
!aon.
tsuas mne - -_ 1 _
Censuucuen wrenst-Pvet seenu mJ unn naaiuened utses_
ibs 11eenac /reJ. Tees for construe.
- "a' uen permits. oversting licenses. manu.
. min is','e' r*one'o:.
0""""*"""-"""""
- 3s.seo oomune ucenn-caneumns una.
8"s188 Q lanurms licenses. &nd materials 11 L naamusneturne heen=
m.1eo m
o.mune neena -nm menu u uan anu nu en,ise nee.see
- eensen are paracie upon nouficapon g_
c,r the Commission wnen the revtew of Ihe 1,roJeet sa compseted.
,,,,,,,,,,,o,,,,n u,,,w.,uarine sie nu w
Lvenew - m iew or anu enien n -
u me nana emnast a.aee
.cr amencmer.t fres *The appropit-
- s. cuanr nseneine a tte amencment lev snall accompany maawaeuaans am. can srucuan preut-mm uma
- weuen eemn tas.ame tne aoptjettion !or ametteinent wnen tas ese C'"*'"'aa" "n "m man - 4 ""
1.so"u'a
.abd with the t/cmmtasson. Where 10 c-m J'
unesule. the acclicant shall provide a oomuni t=
h as uses.
m s Aseamme remisen.
-canarueuse soma set.see f ropuSed oetermmauon of the n. mend.
C*awa= **ma ins.ame
'ent risas anc s. ate the Basis therefor 0*"*""'
- una es
% part of tne arnenisment request and a asamence nemar,e aen ree.e.
mt:: remst tne fee corres:enemt to 1.vename t?.e otterminatier. vita the EngllCA-L*T. 4r Emencment. The Cornmtssion
- t L*".M* e t h e tr*.e r..".en! f ee Art d
.e, or emusunnry Aeoneau n u er
.ere.enes seeten Asem s. -
6nere &c;tleteie, refund any I A*"ew of um Annezuen.
e&I m
=it**?.&PFes or !W snt RO ltcV.! ICT 60 gum
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",.... c r.a trr.tncmerd f ee..
. Arennees.enstneer-w..u 46anearessee tsaaaet of At'.t.cf.r gg The g;;7g;r3;te e
t
- "4*L. Se sn6C terctr.pany the te q
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PART 170 o FEES FOR FACILmES AND MATERIALS LICENS
.Ceasanwesi Sentsuu or rac Lm Ttr.:
focussa estecereet Typeoetlets Fw*
.. +.e. e,,,e um.ns,,
.....,a_
ee.
referenee seaarn Approved 412.;00 t Renewof f4AaJ iconcauen 60.000 reference semen Aeprova...
C Test tacunt' AoGorauen-Construrtson permn -
4 L.300 l
4.000 Canasrucuen Derrett
~
41.20e Opersuns utense -
O Researen reseter *
!acleo A30sicauen-CenStrucuen Deanft...
4.0o0 Construcuen permet-..-
Oeersune prense kaos L IJr=#pum eartenseent Aeones4,en-Cenetrueuen peren#t
- - ~' -.-
M.coe Maans
- Construeuen serma -
13s.eee 3as.aes C+a-s * *f ***'*"i=*
441.3ee F, SeseaM presseu n.se pertres...
4,tm a ruufe m.,e w,a,te,een-me w na.e
.a..
no,eu,eenwu.e - e, LAas asnenesteet. the assount ease snan se ereurtee front the fee preesriese by Lass ---
earlevense vul te eue wnen the esermune Heense for les pet seeer a ianues
_ _._... ame IAe
'Csererwes east. A eeneurtent ufut a eefmee u a Dewer reacher of Une amate easien a4 a aanese power uaer. tau aas ame,eet te sencurrens ueenaans remw j
- when renew es the mereut. neen.e. seers u.e x -
adened ma^ Pater aos meereeruse supeert as*wiens esU De eenergmaned ame the resuliaA& les -m a amene.eu. the essenestums ser pressa.
ne eveni etu tae in eme,*e thu anewn in w asnesiue et nascar seen when see neousna.se ser a preuen.
_ Det in narr enism meerwu er fmu saucs neerevu unu.nn more taae one easier. the n.<.uena seerwus are suewe. Le a marveunn 4w en.en is sne sum of tae seeuensan in ama soorwal fee.
'CFlarte wtje be sees #' Met? Getoftinee DF Me d"--~^
^ tad.the W184 tessunt the prefenssemaJ haA.
p ee recuarte to eeneuct tae rene,inusuouve tv tra neoumew east awr man.r ne. pius ear neoreeruu suspert eer**ees remu encureee Whefe a fee nas been see for a inestny earty adte renes. the taarve TV: De eesurtes frena sne in rer a for a use remw vnm sne
.trueuen servast in.we for tant asu. A earue enam win not me a emase ftie for the harme Site. tareet Fnere the nocheauett is wither =wTa DT the sepuamat er teruse Dr the Comana a.en. The masunurn tw ter eev.: a seoiou nowunaa not esames sao.see.
% 170.**
Schedule of fees for facilify license arnendsmenta.
Scxmacu or Amosenenet Puzz rom Rzacna Fac: rry Psaarrs.Uczarsas. Aare Cmten Anto u s Asertitze av srs uczprst on Consstestos Recularrows o
ee om W
Eu.
Claes of 8.;- -
es Powgr reesters Test ame reemaren renames C:.AM I: Amenesmensa taas are a ausesmaa of an amenement for a aseene anseeuaur iescuena usat at Lee amane aate. vnm tasa praesene --
are reeervoe. preemass. ane nemmes at the anme umme C' A.S$ It Amenessenna thaa are pro focus, heindean.
tese trauwe as naaure. se hare sto sesety or envwesomemaal asseaflamee... _ _
C: AAS C1 C"_
reeenouena, or reensarse 4e.
L3os a
see.
are man that urves,e a einese emew-=
ansett.
er other antee. nave asevena4 Unity for una ammus etene.
fy meantif6ee by am If5tC peneuse er are esummes est to utvoe*e a asentflammt haamses ~ ^
m
_ 54. esemousses, or roeusese ae.
Laes
[s C:.A.35 FV:.L.
Lees pre = san thma in.orve a emmeses issue er more taae ene esegranamentaJ aMety, er etaer laansa, er asserel taamere of the saaes !!! tyTe wiserparesse unee tame Dreemare amenestent se sevesve a mentflamat ham.
tres eunbaeeruseva er twouire an estenmeve sevnres.
seen6M unpart 6.peranaJ er result freen saamaatuae or heense neren ause ce...
C".MS Y Asnenescents, esemeuens. er reewaree ae.__
11.3ee 4.aes preb.ans that rat'Jr, evWueuen of aeterW enamones an as er Brtwe*Te revlee Dy tne ACM.L er feegtre na r
en.eeanmessio TE3.cl 4664ee.ent.,
C" Ah5 Yl. AabeW3rtente. e5semouten. er reeuarse me.
34.4et ILSee t
seevaan that eve.ure waJuauen of a new Sadesy Amne.
i rae nPeori anta re,MW ef Me lhC1stt? beehme ibh.
eJweine tsentllehe neeWIM8. SMCA sa Af Je fe.
suarTe for a heesase renM at sne stee the --an a taler. tne usen e, assumes anus newnee a ;
astenemeft1 einas arte atue the basaa thefefer me Smet et 3e met er abe4Lneautet eyeww=t new anaa
- rr-er i
remat the FM eorteggenenrng te n*= cenefinangues. The Caseousanart vtu e*Wtanae the pres
- ans ee,r mau noe ms.m(in.. n er comim,nf r,eia-efimuen = r.euw n=a.mtmoen ta a sene - _
eninen sne ri.e. es mener m vsu e.nua in sme res er mr.=nere= is une tune e w eamas er
%44Aans tne speetense er appesempts for neelueed femas hete ashenerner%he resulLIA. La aA nn&kbh) Ultresse ret Deter te IN Drferet of the I&lu l*l aart i
not swespet he inese fees eagees as prenees trn festeete ! le iIt0.2L C'. mas L IL ec C1 -
l a esmaen peWer leTea a#v recutt from a wertue. c==,,,- n r,ovat ter the ase6iemuen may to esempt frees fear un -
7 woush 3
-m. W u eni, e, u.
en une amene.
arbe a langpeg lgf [hg gangenpener g( (gr N--, non.e e, iormin,.o.e e : sne am,nemem.
em, Ame, nuet, ame.
l MfWaMet 1
t P00R BRIGINAl.
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