ML20030D976
| ML20030D976 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/15/1981 |
| From: | Sherwin Turk NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20030D977 | List: |
| References | |
| NUDOCS 8109170239 | |
| Download: ML20030D976 (14) | |
Text
U 09/15/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD kl$@,/q In the Matter of
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8 LOUISIANA POWER & LIGHT COMPANY Docket No. 50-382 S
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NRC STAFF'S ANSWER IN SUPPORT OF APPLICANT'S MOTION FOR
SUMMARY
DISPOSITION
/b 0F JOINT INTERVENORS' CONTENTION 22 (SAFETY-RELATED CONCRETE)
On August 21, 1981, Louisiana Power & Light Compar4y (" Applicant")
filed its " Motion for Summary Disposition of Joint Intervenors' Contention 22 (Safety-Related Concrete)" (" Motion"), pursuant to 10 C.F.R. 5 2.749.
In its Motion, the Applicant asserted that "there is no genuine issue as to any fact material to Contention 22 and that Applicant is entitled to a decision in its favor on Contention 22 as a matter of law" (Motion, at 1).
For the reasons set fortn be'ow and in the documents submitted in support hereof,1 the NRC Staff (" Staff")
supports the Applicant's Motion and recommends that it be granted.
II The Staff has attached hereto the following documents which are submitted in support of this Answer:
" Affidavit of Ramon E. Hall"
(" Hall Affidavit"), dated September 14, 1981; and " Affidavit of Joseph Isaac Tapia" ("Tapia Affidevit"), dated September 11, 1981.
The Staff has reviewed the " Applicant's Statement of Material Facts Relating to Joint Intervenors' Contention 22 (Safety-Related Cencrete),'
dated August 21, 1981, and does not contest the facts set forth therein.
m 8109170239 810915 PDR ADOCK 05000382 5B of/
. Background and Introduction I
Contention 22 was filed by intervenors Oystershell Alliance, Inc.
and Save Our Wetlands, Inc. (" Joint Intervenors"), on April 11, 1979.2_/
As originally drafted, Contention 22 asserted as follows:
- 22. Applicant has failed to discover, acknowledge, report or remedy defects in materiais, construction and workmanship such as improperly poured and set concrete and concrete poured without required reinforcenent during the fabrication of the containment vessel, (reactor vessel) and/or related integral systems.3_/
During the Special Prehearing Conference held in New Orleans, Louisiana, on April 26, 1981, Counsel for the Joint Intervenors stated that this contention was based upon allegations reported to him by several members of the Intervenor group, who had spoken to individuals who were " unnamed ard unknown" to him,1/ and upon an article which appeared in a New Orleans newspaper.1/ Counsel admitted that "it's a very easy thing for any 2/
"Save Our Wetlands, Inc., and Oystershell Alliance, Inc. Contentions,"
dated April 11, 1979.
1/
Id, at 9.
d El Special Prehearing Conference Transcript ("Tr."), at 106.
El Id., at 103, 105. The newspaper article was subsequently identified as havi'ig appeared in the April 3,1979 issue of the New Orleans States-Item. See " Joint Petitioners' Arguments Regarding Contested Contentions," dated June 1,1979, at 15 and " Exhibit D" thereto. A copy of the article is attached hereto as " Appendix A."
. construction employee to make allegations of this type,"E and stated that he had "no direct support for the contention, other than the article which appeared in the newspapers [ sic]."U Counsel requested that the contention "be allowed to go forward at least in a discovery phase....
If we can't prove anything, I would be more than happy to abandon this."E On May 30, 1979, in accordance with the Licensing Board's request made during the Special Prehearing Conference,E ounsel for the Staff C
submitted to the Licensing Board the conclusions of the Staff's investigation of the newspaper article referred to by the Joint Intervenors, as fol1cws:
The NRC's Office of Inspection and Enforcement has investigated this matter as indicated in the enclosed memorandum dated Ap 4,1979 and concluded that the concerns are baseless E
H.,at106.
E
- g., a t 105.
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M., a t 103.
E H., at 106.
N Letter from Henry J. McGurren, Esq., Counsel for NRC Staff, to the Licensing Board, dated May 30, 1979.
! Counsel for the Staff attached to his letter a copy of a memorandum by Mr. Ramon E. Hall of the Staff which reported the result of the investi-gationofthismatter.E In his memorandum, Mr. Hall reported that the identities of the three workers quoted in the newspaper article were unknown except that they "were working on the Intake Structure, a nonsafety rr'ated structure" (M., at 1).
No further inivrmation was discovered except that they claimed "their comments also were applicable to prior work on the plant proper"(M.). Mr. Hall concluded as follows (M., at 2):
Based on the vagueness of the allegation and the reported employees relationship to previous safety related work activities, it is not considered practical to pursue tnis matter further.
On September 12, 1979, the Licensing Board issued its " Order" in which it ruled upon the admissibility of contentions. The Licensing Board reviewed the facts surrounding the filing of Contention 22 (Order, at 7-8), noting that Counsel for the Joint Intervencrs had " acknowledged that, when drafted, there was no specific basis for this contention" (M., at 7), and that Counsel had " urged that this contention be admitted in order that discovery could be initiated, and represented to the Board that the Joint Petitioners would abandon this contention should discovery fail to disclose facts proving the allegations in the contention" (M.).
The Licensing Board noted that it was " loathe to admit any contention founded on purported allegations of unidentified individuals" E Memorandum from R. E. Hall to the File, through W. C. Seidle, dated April 4, 1979. A copy of Mr. Hall's memorandum is submitted herewith as " Exhibit A" to the " Affidavit of Ramon E. Hall" which accompanies this Answer.
. (id,., at 8), but that the contention "perhaps may be fleshed out upon use of the discovery procedure" (id,.).
Accordingly, the Licensing Board admitted Contention 22, having refonnulated it as follows:
Applicant has failed to discover, acknowledge, report or remedy defects in safety related concrete construction" (j d. ).
Finally, the Licensing Board noted that summary disposition motions may be appropriate (id.):
[A]fter discovery has been concluded, in the event the Joint Petitioners do not withdraw tMs contention, Applicant and/or Staff may move for summary disposition pursuant to 10 C.F.R. 5 2.749.
Discovery in the proceeding commenced shortly after the Licensing Board ruled upon the admissibility of contentions. On November 13, 1979, the Staff filed its initial set of interrogatories to the Joint Intervenors,E# seeking, inter alia, information as to the identify of the persons, documents or facts which would support the allegations set forth in Contention 2 On January 18, 1980, the Joint Intervenors submitted their answers to the Staff's Interrogatories,E in which they stated that they were "in the process of identifying appropriate witnesses in support of this contention, and will notify the NRC and El "NRC Staff Interrogatories to, and Request for Documents From, Save Our Wetlands, Inc. and Oystershell Alliance, Inc." (" Staff's Interrogatories"), dated November 13, 1979.
El " Joint Intervenors Ans1Ars to NRC Staff Interrogatories and Response to Request for Documents" (" Answers"), dated January 18, 1980.
. Applicant by seasonably [ sic] disclosure."E No substantive response whatsoever was provided to the Staff's Interrogatories on Contention 22.E On January 7,1980, the Applicant submitted its responsesE o t
interrogatories filed by the Joint Intervenors on Contention 22. E nder U
the discovery schedule agreed upon by the parties and approved by the LicensingBoard,E the period for discovery on Contention 22 has closed.
No information whatsoever has been provided by the Joint Intervenors in support of Contention 22, nor have they supplemented their Answers to the Staff's Interrogatories.
Discussion Pursuant to 10 C.F.R. 5 2.749 of the Commission's Rules of Practice, summary disposition is available to a party in NRC proceedings as to all or any part of the matters involved in the proceeding, as follows,:
E
_Id. at 24, Answer to Interrogatory No. 22-1.
E The Joint Intervenors asserted (id., at 25) that further answers to Interrogatories 22-3, 22-4, aiid 22-5 were dependent upon their receiving answers from the Applicant to certain of their own interrogatories which were the subject of a motion to compel then j
pending before the Licensing Board. Those interrogatories involved matters other than the alleged concrete construction mistakes, and were later held by the Licensing Board to be outside the scope of Contention 22. See " Order" dated January 11,1980, at 2-3.
E Letter from Ernest L. Blake, Jr.. Esq., Counsel for Applicant, to Lyman L. Jones, Jr., Esq., dated January 7,1980, and responses to i
j Joint Intervenors' Interrogatories attached thereto.
E " Joint Intervenors First Interrogatories to Applicant," dated November 23, 1979. See n. 15, supra.
E See Order dated September 28, 1979.
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e (d) The presiding officer shall render the decision sought if the filings in the proceeding, depositions, answers to interrogatories, and admissions on file, together with the statements of the parties and the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a decision as a matter of law....
The Commission's summary disposition rule is analogous to Rule 56 of the Feitral Rules of Civil Procedure, governing motions for summary judgment, and Federal court decisions interpreting Rule 56 may be relied upon in NRC proceedings for the interpretation of 10 C.F.R. 5 2.749.
See, e.g.,
Alabama Power Co. (Joseph M. Farley Nuclear Plant, Units 1 and 2),
ALAB-182, 7 AEC 210, 217 (1974).
Under both Rule 56 and 10 C.F.R. 5 2.749, the party seeking sumary judgment has been held to have the burden of proof, viz., the burden of demonstrating the absence of a genuine issue as to any material fact.
Cleveland Electric Illuminating Co. (Perry Nuclear Power Plant, Units 1 and 2), ALAB-443, 6 NRC 741, 753 (1977), citing Adickes v. Kress & Co.,
398 U.S. 144, 157 (1970). The praponent of the motion for summary disposition must meet its burden of proof even if the party opposing the motion fails to present evidentiary material to the contrary. Perry, supra, 6 NRC at 754. On the other hand, where a properly supported motion for summary disposition has been made, a party opposing the motion may not rest upon the mere allegations of its contention or answer.
10 C.F.R. Q 2.749(b); Virginia Electric and Power Co_. (North Anna Nuclear Power Station, Units 1 and 2), ALAB-584,11 NRC 451, 453 (1980). Rather, pursuant to 10 C.F.R. 5 2.749(b), the party opposing summary disposition must present specific material facts showing there is no genuine issue to be heard:
(b)... When a motion for summary decision is made and supported
..., a party opposing the motion may not rest upon the mere allegations or denials of his answer; his answer... must set forth specific facts showing that there is a genuine issue of fact.
If no such answer is filed, the decision sought, if appropriate, shall be rendered.
Finally, in this regard, all material facts set forth in the statement filed by the moving party in support of its motion for summary disposition "will be deemed to be admitted unless controverted by the statement required to be served by the opposing party." 10 C.F.R. 5 2.749(a). EI In a recent Statement of Policy, the Commission underlined the availabilty of summary 11sposition in appropriate cases, as a means of expediting the hearing process.
In Statement of Policy on Conduct of Licensing Proceedings, 46 Fed. R_eg. 28.533 (May 27,1981), th' Commission stated as follows:
In exercising its authority to regulate the course of a hearing, the boards should encourage the parties to invoke the summary disposition procedure on issues where there is no genuine issue of material fact so that evidentiary hearing time is not unnecessarily devoted to such issues.
46 Fed. Reg. at 28,535. As was stated previously by the Appeal Bned, the summary disposition rule provides "an efficacious means of avoiding t
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E/ Pursuant to 10 C.F.R. 6 2.749(a), answers to motions for summary disposition are to be filed within 20 days after service of the motion; and responses to "new facts and arguments presented in afiy statement filed in support of the motion" are to be filed within ten days after service thereof.
In deciding a motion for summary disposition, "the record is to be viewed in the light most favorable to the party opposing the motion." Gulf States Utilities Co. (River Bend Station, Units 1 and 2), LBP-75-10,1 NRC 246, 248 (1975);
Public Service Co. of New Hampshire (Seabrook Station, Units 1 and 2), LBP-74-36, 7 AEC 877, 879 (1974).
i.
unnecessary and possibly time consuming hearings on demonstrably insubstantial issues." Houston Lighting and Power Co. (Allens Creek Nuclear Generating Station, Unit 1), ALAB-590,11 NRC 542, 550 (1980).
As the Appeal Board noted recently, a hearing on each issua raised "is not inevitable," but " wholly depends upon the ability of the intervenors to demor. strate the existence of a geneine issue of material fact...."
Philadelphia Electric Co. (Peach Bottom Atomic Power Station, Units 2 and 3), ALAB-654, 14 NRC (Sept.11,1981) (slip op., at 4). A party car.not avoid summary disposition "'on the mere hope that at trial he will be able to discredit movant's evidence,'" nor may a party "'go to trial cr. the vague supposition that something may turn up.'"
Gul f States Utilities Co. (River Bend Station, Units 1 and 2), LBP-75.-10, 1 NRC 246, 248 (1975), cuoting 6 Moore's Federal Practice 556.15[3]
and [4].
An application of these principles to the Applicant's Motion leads the Staff to conclude that summary disposition of Joint Intervenors' Contention 22 is warranted. As ir.dicated above, Contention 22 is founded entirely upon unsupported allegations made by unnamed and unknown persons who claimed that unspecified " mistakes" had been made in concrete con-struction at the Waterford facility. An investigation of the newspaper article which underlies the centention was conducted by Ramon E. Hall of the NRC's Office of Inspection and Enforcement, in an effort to obtain further information concerning the reported allegations (Hall Affidavit, 11 3, 4). That investigation failed to reveal the identities of the persons who made the allegations, or the identity of their employer (s)
(id.,!4). The Staff's investigation revealed only that those persons were working on the Intake Structure, a nonsafety-related structure, and had asserted that their comments were applicable also to prior work on the facility itself (M.). Mr. Hall concluded that due to the vague-ness of the allegation and the workers' reported relationship to previous safety-related construction, it would not be oractical to pursue the investigation further (M.,15). Notwitnstanding Mr. Hall's attempt to obtain further information from the author of the article, no further information or additional allegations were received froa him or from any other party concerning the concrete construction " mistakes" reported in the newspaper article (M.,114,6).E Accordingly, Mr. Hall has con-cluded that, to the best of his knowledge and belief, there is insuffi-cient basis to the reported allegations to warrant further investigation (M.,17).
In addition, the Staff has reviewed its inspection records concern-ing the Applicant's safety-related concrett: construction. Mr. Josean I.
Tapia, also of the NRC's Office of Inspection and Enforcement, was responsible for the inspection of concrete construction at the Waterfced facility (Tapia Affidavit,11). As set forth in Mr. Tapia's Affidavit, during the course of construction numerous inspections were conducted involving the Applicant's concrete construction (Tapia Affidavit,112, 4).
Those inspections resulted in the issuance of two Notices of items of non-compliance, both of which were later satisfactorily resolved (M.,114, 5).
In addition, the Applicant submitted to the NRC four Construction E The Staff notes that the Applicant also attempted to investigate the allegations contained in the newspaper article, but was unable to identify the workers quoted therein or to discover any (factuel basis for their allegations (Affidavit of Thomas F. Gerretts "Gerretts Affidavit"), dated August 19, 1981, 1 13).
Deficiency Reports within the context of 10 C.F.R. 6 50.55(e), which involved safety-related concrete construction (H.,13); each of those deficiencies was adequately resolved and subsequently closed out (H.).
On the basis of his personal observations and knowledge, Mr. Tapia has concluoed that there are no outstanding aefects of any significance in the Applicant's safety-related concrete construction, and that the safety-related concrete construction is satisfactc"y and provides reason-able assurance that the health and safety of the public will be protected following the commencement of operation of the facility (H., f 7).EI In contrast, nowhere in their filings to date or in their Answers to the Staff's Interrogatories have the Joint Intervenors provided ary factual basis for the allegations contained in Contention 22. Tle Joint Intervenors have not presented any evidence of " defects" in the f.pplicani.'s safety-related concrete construction, nor have they presented any evidence that -aises a genuine issue of material fact concerning the allegations contained in Contention 22. On the contrary, the Staff believes that the Applicant's Motion and papers filed in support thereof, along with the affidavits submittea by the Staff, establish that there is no genuine issue of material fact as to Contention 22. The Staff believes that the Applicant has cet its burden for obtaining sumary disposition on Contention 22 as a matter of law and, accordingly, the Staff believes that sumary disposition of Contention 22 is appropriate.
El Similarly, the Staff notes that the Applicant has concluded that there are no significant defects in its safety-related concrete.
(Gerretts Affidavit, 11 9-11, 14).
CONCLUSION For the reasons stated above, the Staff supports the Applicant's Motion and recommends that it be granted.
Respectfully submitted,
/$w p._
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Sherwin E. Turk Counsel for NRC Staff Dated at Bethesda, Maryland this 15th day of September,1981 4
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r Shaded area indicates 5 mile radius of Waterford 3 nuclear power plant i;
n l'A recurring nightmare:
'Could we escape Taft?
P that has catised radtaactive vapors se ticated and castly "amorgency operata Jteinsed esery.Page A.3 tog conta#*
basement et the SL escape die tae atmosanere over the J'ByJIM A&80$$
Charles ene.
is ketpsag te devela past several days haa appa.wly
- ~ op t'.e parn&*h emergency plans la the saahan has confulence.
t I ;l$tates-ften staff writer TAFT - Jebe "3ey" Lucas. the event er as ased.at as Waterford 3. He
'sead be is partacularly concerne about " PRIOR 70 ILARRt351.v. 1hM as s
sirector af ctval defasse far SL "harles Partsa kas bees lening a lot of slees the people of KU;ona, a small town less,4,niht that we cou!d handle aavutast.".
f levar stnce that accadast shut down the thaa a asile west of Watarford 3. etnich as and "But itts haa changes every 31.i: car power plaat amar Harrasaurg. mak.s d the remadmasaan ares comment is aang. I reaaly dada's taina there was a.. and threatened a devaarasest *As plant.
say tradiataan6 capatie of getting est t
- !! we hav6 five treastas to werb of thathauanag" Lucaa' recurring r.ightmare is thin' A wita (la evacuating reandants of Ki"..e-In the Three Mlle Island accidans.
plasser evac *stion was cortsa?ered ior the area 1, uusar or worse -a ufma' h geas at asL we cas get them out of there." he m a;a fae mth:s of 13, power *.itant is
'the Louisaana Power. ans fJgat CA's said. *T,et uppue, we dont base five nWaterford 3 noctear Jower plaat now.naastat fye been lytag swake at angst 14e case of tse Waserford 3 peaas. 4 L beteg baalt aeat this smaP. towe th thinking abset that sort of taang.*
ft.aurr.Ge racas encarnpaaaes a poesia.
rules up the hilss.ausppa River from 1,acas damersbos namnett as "a dasci-uan of amuut *.303.deceretng to a ces-
'.New Orleans, and taere is seither ple ef asetear energy" and said he puts sus by the St. CLartas Parsh pouce has faith is the safety mansures bains piry, and inclucan, basades 74'8 **d paengh time ser enough reads to macuate the peepie sa the aanrandsate ' takaa la the building of Waterford 3. K lona, the towns of ilahav Ge. La.
as the accsdent at tae Three une ts.
ency.
land nuclear reactor naar !Lamatrig
_ Taru se Psse +4 Calem I
!ancas. was is la.hargeg sepsis.
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td hsday, April 3,1979
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- The ! rotes.nem acumng mghWnme Caecinsed from Ps'ge !
But if there was a res! danger, ! goes
!"d iesm" Place. Nor o, Enta, t.ucy, Setters and A sur$ey of the residential area near bedIr pt Lucas saad thatla theevent the Waterford 3 plaat terned op only e
- f an accadent 'at Waterferi 3, these one resideot who is openly eathesaastie 8
are towns that"are defiasts a;velved, sheet the plaat. *esepa Ytaceas, the cat we worry ahoes,*
ewaar of the After Hours har and res.
ta,cas' fears are shared by many of taurant en.he Alvor Reed la Killema, de peeate who live la the shadow ed Fald be believes the power plans "le Waterfd 3, afbleh is new aheet 64 dangerous, het it*a a chaars tea have to, percent complete and =^= dad to be
- tateL" as operattee by1908.
h said mest of hje contamme Era slag!asan, a thir4 grade ameane ase construction werkers fruse the an.
r at Kulane Elementary Scheel and the ' clear power plaat and admutted *1f it mothat of three childrea,said the asse. wenel far the. ween plant,I weeWat.
dest at Thres h31s Is' sad *tnakes yee behert*
thah that it could harpaa here, and if it All of th6 Raaoma rt:adents Iateem does,that weeld be the eed of et W/re ' vtewed earnplaland tbey bad sever.
seclose here, wtwee could we gef*
been vietsad try effletals of ather IP&I.
Such concerne wee reinfestsd yee.. er state and peJish safety agence to
- crday by several coma,recusa serbere esplaan the potential dangere of the at the power plant.Three werkert es, power plaat and emergency plans for
?!ayed as concrete masons at the plaat, it.
sad at a Iemage seat the plaat that
- COD KNOWS,1weeldet hmost wh 4 thay have witaemed summereas
- mis. to de (la the case of as aceWems)." sold Iahes" boisg made is the esmerme JaeemeHas Brewe, who alas teaches at work at Waterford, the warhere, who the K!!!ees W Scheet."I Olde desaa:ed explane'lems, said thedecnoed to give their namnes er to pre. weeldet knew whether l dowertver.*
mistakes are sortsen esseth to comes
!. aces, however, said he has given them te worry about the op'reting, aumerous talis sheet *Emerseery safety of the plant.
preparadame" to St. Charles Pariah
'"at's cat perfectisa,'said ese work. remadeath He and he spone to *a wheie er, who identmed htmaatt as a separv6 groep of leaders from Ki!!ana* ret =es.
ser of other concrete massas, "aas yes. ly het talJ them he cueid est give do.
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I weeld he conserved aheet 117 tag, taale of the seelear emergency plans
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beessse these have not yet been 3 The superviser amid he !!ves la New esmpleted, Ortesass De cite defense direcier said theme
!#11. efficials, however, lasist that.
plaan, which he is drafting wuh the No.
the Watarford plaat wtD be safeL Rey cieer Energy Dietsise of the stade Can.
W. Prades, the aseiser llemmelag engl. serveales Departant aed with the seer for the plasa, said even is the cooperstles of LF&! will be coe.
event at the weret caseelvenie aa4d==*
pissed by the end of this year and wait at the plant - e les of content from a he temend protehtylate esma year.
perual imatthe et the renesar's eure -
A Now Orl*a=Aa-ad orgementies
. pereen seer the plant reehnhly weld appened to the of aselaar
. set suffer *asy shamrvable efferes la a
' %feahme6" power piamsow 3 ave Our Wettende las.
yenaards, filed seit is c,tl Distreet Brt that emmelemise is espeted by me. Court, asalag that the sense he ardered-clear power oppenames ameh as taans6 to aime devise an evesentase plan far' aan State Univers'ty eksedst Jeal Sab the fiew Orleans area, er etse halt the bia, who clasms !#68 effletals "%sve. eerstraeuenof Waterfard A e't the foggiest ameles whether it's esp.
Laces said if as a.aematism is reemt.
rett. The fact is,11sy*ll tell pee ed,he is ampmMa:17 comeersed abset the anything.*
limited sammher of reeds Imadiaq est of KHJmfA IS A predominently hiesit the area. The civil defemme darerser l,
towa of sheet let lahanetaJt Many admutted that even by the 14ame the Taft are ermployed dowartver at Avendale plaat is operating, there wtG be endy i
Shipyards !ae er at the searby Ustem< three evecession rouses en the west Cartudo plaat; very few werk at Wadar. haak and two es the east bank. and "I ferd 3.
dont haev what eas he dame sheetit,"
Nevertheless, the sneiser reasear is "This is ser raata prehlee la at an inescapable presence la Klilena. Qaries Parish, as joke anest it," he The plant's coassess lesser leses muut ans& *We live la a trough surreanded to the A'ver Road.et et a former by water, with limitad acessa and sugar case field that is 54mreGy la agramL" Kallema's beehyard. Sciestimes.4e Lucas beneves the Three Mile Island steady rear of commerecties wert be. accident will speed op emergency comes se loud that Eva Singleese's slo. pleas for St. Charles Paruik He saye dents can't hear ther kateer's venas nas emergency operstang center, as can.
Before the Three Mlle faland ease. trast to the Harrtsberg esvil defemme dent, said hirt. Sieglegen. She "aet cuater, es!! have a direct 'aW laas give no:laar power plaats a====ad to the Waterford 3 ptset ne taere wnD tt.enght.* 3ut mace them, sha sad talk be :.a delays 4 ; earning of any of noc; eat accidents hat beam demuant. accidentt lag conversations la Killeen and she He concedes be "eas't say peeele has lieen claeoly feGaunse news ae. have ce reemen for so,.--
_" 3ut ceua:s of the Three Ele Island be adds, "I feel that at thas stage of the
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game, we're as far programme as any.
"AH my relatives, everything is here one, and I'm thankful we've get tdl la Enaan.* she said. "yhte se ha===
1941.*
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