ML19260A280

Brief in Support of ASLB 790829 Order Requesting Consideration of Psychological Stress Per NEPA Provisions. Evaluation,Balancing & Minimizing Adverse Environ Impacts, Should Be Carried Out by Nrc.Certificate of Svc Encl

ML19260A280
Person / Time
Site:	Three Mile Island
Issue date:	10/04/1979
From:	Carter K PENNSYLVANIA, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 7911080430
Download: ML19260A280 (13)

Text

_. __

. t . . s:-

~

' UNITED STATES OF AMERICA NUCEAR IECUIATORY CQUISSIQi B&urt 11E A10MIC SAFETY AND LICEIGING BOARD In the Matter of  :

METROPOLITAN EDISOT CWPANY,

Dacket No. 50-289 (Three Mile Island Nuclear  :

Staticn, thit No.1)  :

~

Q ll h 9 \N b Od -

gj,;y S BRIEF OF 11E CatHNEAIlIH OF 4IJt' \

PENNSYLVANIA IN SUPPORT OF

'DE LICENSING BOARD'S C3GIERATIQi 0F "PSYGOLOGICAL STRESS" AS REQUIRED BY THE NATIWAL EINIPGOEtfrAL POLICY ACT KARIN W. CARIER -

Assistant Attorney General Ccxmonwealth of Pennsylvania 505 Executive House P.O. Bax 2357 Harrisburg, Pemsylva11a 17120 (717) 787-7060-October 4, 1979 1799 335 79u cao43 d

s .

TABIE OF CGTIEtfIS TABLE OF CONIEITIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 CITATIQG ........................................................ 11 INIRODUCIIQi ..................................................... 111 ARGUMEt TI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 I. "PSYCHOIDGICAL DISTRESS", AS IT IS LIKELY 'IO BE PRESENIED IN 'IIE CQfIEXT OF 'IHIS PROCEEDING, AFFECIS

'IHAT " QUALITY OF 'IHE HUMAN ENVIR0tt!ENI" NHICH IS TIE SUBJECT OF 'IIE NATIGIAL ENVIRCNefrAL POLICY ACT . . . . . . . 1 II. THE NUCEAR REGUIAIORY CONISSION IS REQUIRED BY NEPA TO CONSIDER "PSYCHOIOGICAL DIdue.55" AS A FACIOR IN THIS PRuCEEDING ..................................... 7 CONCLUSION........................................................ 10 s

'299 336

~

~

CITATIONS CASES:

Calvert Cliffs' Coordinating Ccomittee, Inc. v. AEC, 449 F. 2d 1109 (D. C. Cir. 1971) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8, 9 City of Rochester v. U.S. Postal Service, 541 F. 2d 967 (2d Cir. 1976) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Ccmo-Falcon v. Dept. of labor, 465 F. Supp 850 (D. Mmn. 1978) . . . . . . . . . . . . . . . . . . . . . . . . . . . 2, 3 First National Bank of Qicago v. Richardson, 484 F.2d.1369 (7th Cir. 1973) ............................. 5, 6 Hanly v. Mf.tchell, 460 F.2d 640 (2d Cir.)

cert. denied, 409 U. S. 990 (1972) . . . . . . . . . . . . . . . . . . . . . . . . . . 2, 4, 5, 6, 8 Hanly v. Kleindienst, 471 F. 2d 823 (2d Cir. 1972) cert. denied, 412 U.S. 908 (1973) ......................... 4, 5, 6, 7, 8 thryland-Capital Park & Planning Camissicn

v. U.S. Postal Service, 487 F.2d 1029 (D.C. Cir. 1973) ............................ 7, 8 Itnarch Chemical Works v. Exon, 4t>6 F. Supp. 639 (D. Hebraska, 1979) . . . . . . . . . . . . . . . . . . . . . 6 Nucleus of micago Haneowners' Association v. Lynn, 524 F.2d 225 (7th Cir.1975),

cert. ' denied, 424 U.S. 967 (1976) . . . . . . . . . . . . . . . . . . . . . . . . . 6 Public Service Co. of New Hamoshire v. NRC, 362 F. 2d 7 7 (1st C1.r. 19 78) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8, 9 STRIUIES:

National Environmental Policy Act, 42 U.S.C. 54321 et seq. ................................... 1-9 1299 337 u

q , .' ,. . . ,

INIRODUCTIN This brief is a response t6 the request contained in the August 9, 1979 order of the Nuclear Regulatory Camission that parties wishing to sdrnit contentions on the " psychological distress" issue also submit briefs addressing the relevmt duties of the Camission under the National Eftvironmental Policy Act (hereinsfter "NEPA") and the Atcmic Energy Act.

The Cmealth of Pennsylvania does not expect to subnit contentions '

or present evidence on this issue; and it does not know the natine of the evidence which other parties may wish to present. However, as Governor Thornburgh stated in his June 22, 1979 letter to the Gairman of the Nuclear Pegulatory Cmmission, it is the position of the Camune.alth of Pennsylvania that the psychological health of the residents of Central Pennsylvania uust be fully considered in the process of deciding the future of ihree Mile Island thit 1. It is the Ocmnonwealth's position that NEPA requires consideration of the psychological health issues presented in this case and that the Board nust therefore allow interested parties to present evidence of the psychological health effects of the proposed reopening of thit 1. Fbreover, prior to allowing the plant to operate again, the Board must balance the psychological health costs and other environmental costs of the plant's operation against the benefits to be derived therefran and take steps to mitigate any adverse effects on the psychological health of the ccxmunities which are threatened by the renewed operation of Three Mile Island Unit 1.

!?99 338 111

ARGUMENI I. "PSYGOIE7. CAL DISTRESS," AS IT IS LIKELY TO BE PRESENIED IN 11E CONIEKr OF THIS PROCEEDING; AFFECTS TIE " QUALITY OF THE 1RJMAN ENVIRONMENI" WHIG IS TIE SUBJECT OF TIE NATITAL ENVIRAM POLICY ACT.

One of the many unprecedented aspects of the events which have generated this proceeding is the possibility that there is substantial evidence of the infliction of fear and other hams 1 stress (hereinnfter referred to as " psychological distress") upcn a sizable urban ecnm:nity.

Manbers of this emmmity are expected to allege that operatica of any nuclear power plant at Three Mile Island can cnly ccntinue or exacerbate the harm to physical, mental and anotional health which they have suffered since March 28, 1979. It will also undoubtedly be alleged that the adverse impacts on the ccnnunity already generated by this psychological distress are measurable and severe and that impacts which will flow frcm renewed operation of Three Mlle Island thit 1 (hereinafter 'T4I-1") are predictable and adverse. In short, it will be alleged that start-up of

'IMI-l will, by causing psychological distress, produce adverse impacts affecting that " quality of the human environment" which is the focus of Section 102(c) of NEPA, 42 U.S.C. 54332. After e:rnmining case law under this statute, the Cccuenwealth of Pennsylvania has concluded that properly framed allegations in this proceeding will indeed place psychological stress within the range of environmental impacts witich.are cognizable under NEPA.

First, it uust be emphasized that the psychological distress issue arises in this case in a manner unprecedented in NEPA case law. 7 hat is, there are (to tha 0-mwealth's knowledge) no court cases under NEPA arising frcm rebuilding or replacement of collapsed dams or

'299 339

destroyed buildings where, accidental ruin of one facility has been followed by proposed Federal ecostruction or licensing of a similar facility at the same site. However, there is a developing body of case law indicating that certain manifestations of psychological distress are already cognizable under NEPA; and there is also a line of cases which warns against the dangers of attempting to factor spacule4ve. psychological b'anm into an agency's decisicn making process.

During the last ten years, significant judic4>'l scrutiny has been given to the duties imposed by NEPA upon Federal agencies which are contemplating actions affecting urban environments. 'Ihe ctm11ntive effect of judicial construction of such phrases as " quality of the human envircoment" and " environmental considerations" has been to extend the list of urban environmental factors cognizable under NEPA far beyond such simple ccncepts as water and air pollution or sewage and gerbage.

As the Second Circuit stated:

"'Ihe Act nust be construed to include protection of the quality of life for city residents. Noise, traffic, over-burdened mass transportation systems, crime congestion and even availability of drugs all affect the urban ' environment' . . ."

Hanly v. Mi.tchell, 460 F.2d 640, 646-47, (2d Cir.) cert. denied, 409 U.S.

990 (1972) (hereinafter "Hanly I").

'Ihe urban NEPA cases have been usefully analyzed in the case of Como-Falcon Coalition v. ' Dept. 'of Labor, 465 F. Supp. 850 (D. Minn.

1978). After listing twenty significant urban NEPA cases, Judge Maclaughlin classified into four categories the environmental factors which courts have found to be relevant. Under the first category

(" health and public safety") were listed air s.,.d water pollution, noise, sewage and solid waste facility capacities, and the effects of the

-2_

??9 340

proposed project on the local crime rate, fire dangets and other dmands on fire and police forces. Judge Maclaughlin's second category contained impacts of the proposed facility on the availability of such " social services" as schools, hospitals, businesses, cmmuter fnef14 ties and parking. he third category cancerned the impact of the proposed Fnr414ty on the character of the area, including conformance to zcning, harmony wi.th o%er land uses and aesthetic considerations. B e fourth category concerned consideration of a project's impact en the cmmmity's develop-ment policy, including contributions to urban blight and decay, neighborhood stability and growth. 465 F. Supp. at 859.

Como-Falcon, supra, itself involved consideraticn of many of these issues, including the impact of the Departunnt of Izbor's proposed Jcb Corps center upcn traffic congestian, local utility services, cmmunity social services, crim%n1 activity, police and fire protecticn and alteration of the character of the neighborhood. Le Court concluded that the agency's assessment of these factors was adequate and that no environmental impact statment was necessary.

Le Cnmmwealth does not know the nature of the evidence which parties intend to present cn this issue. It would not be difficult, however, for interested parties in this proceeding to allege that the manifestations of psychological distress which will result frcm operaticn of 'IMI-1 already fall into more than cne of Judge MacInngh14n's four urban IEPA categories. ne health and public safety category would cover any physical symptcms (digestive, cardiac, or circulatory dis-orders) and arguably any psychiatric disorders; increased drug or alcohol dependence; and increased child abuse or spouse abuse which could be shown to be a predictable result of psychological distress

'299 341 caused by operaticn of'7ME-1. Similarly, the second category could be invoked for increased pressures expected to be put on conn: unity social services for the counseling of traumatized children or strained marriages which will be necessitated by increased psychological distress attrib-utable to the operation of 'IMI-1. Finally, allegations of adverse impacts of psychological stress on the stability of the entire cmmnity and on the ability of the cermmity to resist urban blight and decay su21d fit into the fourth category of cognizable EPA considerations.

The issue of applicability of EPA to psychological stress has been directly raised in a few cases, particularly with respect to proposed prisons and detention facilities. The leading cases in this line are the

_Hanly cases - Hanly I, 'suora, and Hanly v. Kleindienst (hereinafter "Hanly II"), 471 F.2d 823 (2d Cir.1972), cert. denied, 412 U.S. 908 (1973). The subject of these cases was the attempt of the General Services Adninistration (GSA) to construct a jail and office building behind the U.S. Courthouse in Manhattan without preparation of an environmental impact statement. The plaintiff residents of the neighborhood surrounding the proposed facility protested that the GSA had failed to ccxtply with EPA in deciding that the proposed project did not significantly affect the quality of the huma environment. In Hanly I, the Second Circuit agreed with the plaintiffs' arguments as to the jail and enjoined the GSA from further proceeding with the facility until a nore extensive environmental assessment could be performed. The GSA responded with a 25-page document describing its determination that no significant environmental impact wu21d result fran the proposed facility, and again the case reached the Second Circuit. In Hanly II, the Court again found the GSA's perfourance inadequate and remanded for additional agency consideration of the increased risk of

_,_ '299 342

crime posed by 'the proposed jail. Althougit both Hanly opinims held that NEPA required the GSA to consider a range of enviromental considerations nuch broader than sewage and garbage or air and water polluticn, the court rejected the plaintiffs' request for consideration of psychological impacts:

"For the nest part their oppositicn is based upon

, a psychological distaste for having a jail located so close to residential apartments, which is understandable enough. It is doubtful whether psychological and sociological effects upon neighbors ccustitute the type of factors that may be considered in making such a determinat do not lend thmselves to measurment.{gn since they u However, we need not decide that issue because these apartments were constructed within tw or three blocks of.another existing jail." 471 F.2d at 883.

At footnote 10, the Court added:

"Unlike factors such as noise, which can be related to decibels and units which measure duraticn, or crime, in which crime statistics are available, psychological factors are not readily translatable into concrete measuring rods."

471 F.2d at 883.

At the outset, it should be noted that these jndicini doubts expressed in Hanly II are dicta. 'Ihe Court went cn to exclude " psychological and sociological effects upcn neighbors" frcxn the mandates of NEPA because the plaintiffs' neighborhood already contained a jail larger than the proposed facility and because New York City zoning for that neighborhood specifically provided for prisons. However, other courts have referred to the above Hanly statment or its acccxupanying footnote in support of the propositicn that psychological impacts of prisons may be excluded frcxn NEPA consid-eraticn. For exanple, in First National Bank of Qiicago v. Richardson, 484 F.2d 1369 (7th Cir.1973), the Seventh Circuit considered the alleged psychological impact of a proposed GSA parking garage and detenticn facility. After quoting Hanly, in a footnote the Court added:

1299 343 "As regards imblic ' sensibilities' aroused by criminal defendants, we questicn whether such factors, even if amenable to quantification, are properly cognizable in the absence of clear and convincing evidence that the safety of the neip,hborhood is in fact jeopardized."

484 F.2d at 1380, footnote 13.

See also Nucleus of Chicago Hcmeowners' Association v. Lynn, 524 F.2d 225; 231 (7th Cir. 1975), cert. denied, 424 U.S. 967 (1976). Monarch G=4en1 Works v. Exon, 466 F. Supp. 639, 657 (D. Nebraska,1979) .

'Ihe jurlic4al reluctance to apply the mandates of NEPA to psychological factors in the above cases seens to be based on two factors-the prestmed inability of plaintiffs to quantify the alleged psychological distress and the lack of a danonstrable basis fcr the alleged distress. In both respects, intervenors in this proceeding can be expected to distinguish easily the psychological harms attributable to renewed operation of 'IME-1 from the " psychological distaste" and "public sensibilities" associated with proposed Federal prisons. The events which began on March 28, 1979, at M-2 have provided intervenors with identifiable victims of psychological distress, quantifiable manifestations of psychological distress and a reasonable basis for the forces of psychological distress to have been set in motion. 'Ihe evidence which intervenors will undoubtedly be prepcred to present is thus a far cry from the vague and speculative distaste of the Hanly plaintiffs about the proximity of a Federal prison; and this Board may not rely on the Hanly cases to insulate itself frcm the duty to hear evidence tilat the quality of the human environnent in Central Pennsylvania will continue to be affected by the impact of psychological distress if M-1 is allowed to reopen.

'299 344 II. THE NUCE$R REGUIATORY GIEISSION IS REQUIRED BY NEPA 10 CDNSIDER PSYCHOLOGICAL DISTRESS AS A FACIOR IN THIS PROCEEDING.

Chee the Board has been presented with contenticns which bring psychological harm within the range of envircr=: ental effects cognizable under NEPA, the Board will be obliged hear the evidence which the parties offer cn the issue. To ignore such evidence will be to invite a reand by a Federal court and a consequent delay in making a final decision cn the future of IMI-1. Even if no environmental inpact statment is required in the NRC's decision-making process concarning this plant, a reviewing court w:nld judge the adequacy of the agency's performance of i i NEPA duties under the four-pronged test enunciated by Judge leventhal in Maryland-Capital Park & Planning Cmmission v. thited States Postal Service, 487 F.2d 1029,1040 (D.C. Cir.1973):

"First, did the agency take a 'hard look' at the proble, as opposed to bald conclusions, unaided by preliminary investigation?....

Second, did the agency identify the relevant areas of environmental concern?....

Third, as to problems studied and identified, does the agency make a convincing case that the impact is insigificant?....

[ Fourth], [1]f there is an impact of true

' significance' has the agency convincingly established that changes in the project have significantly minimi ed it?"

Given the fact that de nature and magnitude of psychological harm are uniquely within the knowledge of the residents and health professionals of the cer-n3ty, the Nuclear Regulatory enmission cannot possibly satisfy these four standards of performance without considering the evidence in the form offered by the parties now before this honorable Licensing Board.

'?99 345

It is precisely in those instances in which agencies rddng environmental assesstrmts have ignored offered evidence, cmpiled a scant record or asserbled no recbrd at all cn an issue that reviewing courts have found agency perfonnance to be inadequate and have renanded.

In fact the court in the Hanly cases, suora, remanded twice because the GSA twice failed to cmpile an adequate record on certain issues.

Similarly, the court in Bryland-Naticnal Planning Gmmissicn, suora, renanded review of the Postal Service's proposed bulk mail facility to the U.S. District Courc for reconsideration of the significance of the potential runoff of oil and water frczn the facility. See also City of Rochester v. U.S. Postal Service, 541 F.2d 967 (2d Cir.1976).

The duties expressed in Judge leventhal's four criteria, although particularly applicable to agency actions for which no impact statement is required, are not new to the NRC. Ever since Calvert Cliffs' Coordinating Ccmnittee, Inc. v. AEC, 449 F.2d 1109 (D.C. Cir.1971), the NRC and its predecessor have been fully aware of their responsibility to develop and carry out procedures which balance the " presently unquantified environmental amenities" mentioned in Section 102(B) of NEPA against economic and technical considerations. The Board in this proceeding is therefore required by well established precedent not cnly to hear the evidence on psychological distress but to add that factor into its analysis of whether the environmental costs outweigh the benefits of reopening M -1.

Wreover, the NRC's duty to minimize the environmental impacts of a proposed facility, mentioned in Judge Imenthal's fourth criterion, has been recently affin:nd by the First Circuit in Pub 71c Service Co. of New Hampshire v. NRC, 582 F.2d 77 (1st Cir.1978). Citing Calvert Cliffs, 1299 346 supra, the Court held that the NRC was tnder a duty to consider and udnimize environmental damage resulting fmn Seabrook nuclear power plant and its transmission lines and upheld the NRC's order to reroute certain transmission lines tying Seabrook to the New England grid.

In this proceeding, the Board will have to consider possible ways of minim 424ng psychological harm if it decides to aU.ow M-1 to operate.

Such methods might include public educaticn about the nature of radiation, NRC rulmaking to provide a nore effective NRC emergency response capability or widespread publication of emergency response plan . hwer, the Board will be unable to devise ways to minim 4 e the psychological ham threatened by renewed operation of M-1 unless it determines dat aspects of that operation will cause the psychological distress. A determination of this nature cannot be made unless the Board makes a thorough inquiry into all the evidence available cn the issue.

F 1?99 347 CDNCLUSION The Cmcxxuealth urges this' Board to hear and consider evidence on psychological distress projected to result frcm renewed operaticn of 911-1. Properly framed ccntentions will bring the psychological harms allegad in this proceeding within the range of envircreental effects cognizable under NEPA. The NRC has a duty under IEPA to evaluate, balance and minimbe all adverse envircreental' impacts and should carry out these duties with respect to the issue of psychological stress in this proceeding.

Respectfully sulxnf.tted, N. j, KARIN W. CARIER Assistant Attorney General Cann:ruealth of Pennsylvania 1?99 348

,& s ;.

y ys; ]

g \Mp q

. GIIED STATES OF APERICA ,

NUCLEAR PEGUIAIORY CONISSION 2 -

BEFORE IllE ATINIC SAEIY AND LICENSING BOARD

@ 00 s  :

S In the Matter of  : D g

4 g IEIROPOLITAN EDISON COMPANY,  :

Docket No. 50-289 (Three Mile Island Nuclear  :

Staticn, Unit No.1)  :

uaumCATE OF SERVICC I hereby certify that the attached Brief in Support of the Licensing Board's Consideration of " Psychological Stress" as Require.1 by the Neimal Environmental Policy Act was mailed, postage prepaid, this 4th day of October, 1979, to the following:

George F. Trowbridge, Esq. Walter W. Cohen, Esq.

Shaw, Pittman, Potts & Trowbridge Consumer Advocate 1800 M Street, N.W. Department of Justice Washingtcxt, D.C. 20006 Strawberry Square, 14th Floor Harrisburg, Pennsylvania 17127 Marcia Mulkey, Esq.

Counsel for NRC Staff Dr. Gauncey Kepford Office of Executive legal Director Fnvironmenta' Coalition on Nuclear Power U.S.' Nuclear Regulatory Ccmnission 433 Orlando Avenue Washington, D.C. 20555 State College, Pennsylvania 16801 Ms. Marjorie M. Aamodt Robert L. Knupp, Esq.

R.D. #5 Assistant Solicitor Coatesville, Pennsylvania 19320 County of Dauphin P.O. Box P, 407 N. Front Street Ms. Holly S. Keck, leg. G nirman Harrisaurg, Pennsylvania 17108 Anti-Nuclear Group Representing York (ANGRY) 1*r. Marvin I. Iewis 245 W. Philadelphia Street 6504 Bradford Terrace York, Pennsylvania 17404 Philadelphia, Pennsylvania 19149 Ms. Frieda Berryhill, G airman Jordan D. Cunningham, Esq.

Coalition for Nuclear Power Fox, Farr & CL @

Plant Postpcnsnent 2320 North Second Street 2610 Grendon Drive Harrisburg, Pennsylvania 17110 Wilmington, Delaware 19808 John A. Ievin, Esq.

Mr. Robert Q. Pollard Assistant Counsel Chesapeake Energy Alliance Pennsylvania Public Utility Ommissicn 609 Montpelier Street P.O. Box 3265 Baltinore, M1ryland 21218 Harrisburg, Pennsylvania 17120 1??9 349

t' .

Mr. Steven C. Sholly Dr. Linda W. Little 304 South Market Street At M c Safety and Licensing Board Panel Mechanicsburg, Pennsylvania 17055 50(0 Hemitage Drive Raleigh, North Carolina 27612 Ms. Kathy McCaughin Authorized Pepresentative for Tbcketing and Service Section ihree Mile Island Alert, Inc. (IMIA) Office of the Secretary 23 South 21st Street U.S. Nuclear Pegulatory Comnission Harrisburg, Pemsylvania 17104 Washington, D.C. 20555 Ivan W. Smith, Esq. Ellyn R. Weiss Gnim,n Sheldon, Harmon, Roisman & Weiss Atomic Safety and Licensing Board Panel 1725 I Street, N.W.

U.S. Nuclear Pegulatory Camission Suite 506 Washington, D.C. 20555 Washington, D.C. 20006 Dr. Walter H. Jordan Karin P. Sheldon, Esq. (PANE)

Atomic Safety and Licensing Board Panel Sheldon, Hamon, Raiman & Weiss 881 West Outer Drive 1725 I Street, N.ti., Suite 506 Oak Ridge, Tennessee 37830 Washington, D.C. 20006 Sb KARIN W. CARIER

<$ 9.

Assistant Attorney General 2 c;

' ')-'l G Cl JJ aT,......; .

- 4 .

5 '

g 3'

y~ ' ..

f e

. .1 t- .

/

.z

?

y s

k; . ,

, m.'n

'- .yv. -

. ~

s ;.

hA. n- q*t. .

(.,;

t- p,- hJ . .*. .

hpa.,r .* '

< ' . u 3.y,.

tf. -

g a, . .

s

,' ,,,,. . . M.-k

,aghn

, N .8 e~

a,,

' , I

' = ..4 d' g. - .j&*,. .-.

3r, ,

ghy g.L g.

N.h,p.~ 'e r, .% , :. . _

= ,

e

= . ,l E.: ;  :

,.3.

.4

.,l

.  :)

"e ..s."

t,..-

< 4> .,,. .,

. kmn.1

. t L ..

> ;m '2,

(-

< , . ,-L

... . ., n.i,5

[J' iW," . .% hw3<J a '-

b<

'h , . .? .., C" '. '"

, 1

.. '. . *%; (N .. ,

.h . . , jyw[ y yyh

+ .

. L y ,;.  ?.!,. #

t s %s*1..h ,.,,

i

. .,2

• p$

~ i@,Tt.;f,,b..I 3,.,nb 3

.s.ij t - n > ,. '

~{'

j n.s,Q. n .

b. / . ..

." n , .

, .b p, o '

a h ,

• L.,v. , , o.: ,,, : .v..:m4.

i s

i.. , .. .

..s. - l o'

Ne NaO3s,.J,. , . .*

I

..t

.m s I'

. s w.,*

, e c...., ., ,v* f.i[.

)

n d *

, 9 ;i , '. .-.

. c , L i  ;.

i m , T .

. ,.n

~

t C. . .

0, . .

~ '

c O T , .

e ,

5:.

= Syy S

- .SS rr5

' T f.ga. R eao5 .I '

[ .

.r L . 6'

j ,

-+

• p>

t .'I A < , :;V ,. .

C,,

ctt5 i ea0 vrl2 rcu.

F t.

.e" , w T, M.%

eeg ' ;.. * . . .

%).. . ..-U r..

?'  ?,

a.%a9; m.u. .

e

,j - ,'

., ' .F , .

S S eR C. -' a. .

.. ,y S D

de R nh r ,

ata

,. ..v I a .._

(.,~ w!' 3' .: , ,

en ,~ ,

.m '

gf l o i F . ' s.

i noctug .+ .< .7

- teNn ec i

,w ki . h <

c f S. sa of .

• DOUW ,,* ,  :

, o'. , g 4

.J -

- ., a

.,,h a..

L..1 . ,,',

' u

a. c 4*.,~

' 2 .

. I ,.

r.

I. .

J' - ,

. , . . ..'i, ..,.%,.

.'l W.xY,,yar. * ,, . ,W

'f .s s. .

s . *

.#+ .. '

. };.

.g i(0. 's' f..".,

,"; 1

. . i 1 - .

a.m,[,,

tm.$,w. pa ' Q ..h%.wQ.< ,,.k.

' .y. ..

.wL ,n .

.t; ; . . T'

.~ .o.:.- .,

r

- *'. w.$

S

~

, ,, uc,6.,c , . '6 :

c{ 4,.* h~'cQ. &x9, 2d., ...L

,.'r.

e. " ' ,

E . .- . ,.

s C . .

ie.

...': i.'..

..%lm.

b2 ,. . * , a R a.%,S.

. 4 i

,_ .,. p. . - . . ,

U

.. r *

...'*.%l 8

t t". N, % *" v*t . ,

4OS l e S.i7.W'.,.ym &n.,.Y,;.% Fw . .,-

r .,+:. .jwm (f-

. . M c:.

P

'g 4l ,,)3 e)o,!Gke3. ' ,!

,h;n. r N

I -

s d ,.t  :/ .

N A E ua eo0n -.,.;..

nl l < - ..

V R }Q Y ,,,. ' , .7

.m4 L os sc2

*'.,W..D

.'e

~'[,w ; ' ;.L%.,39 L r

.t:j.F .

?,

k ?f .y

' ,.$y.

E m..,qsQ' t.

S Y A L Cn ue1 .m,,. ,.s-. .*'7n,.~'g N T N N y u

oCo H S' r

oS7

' .1c

. 4

(.*

., - ,A 1

L. .Nya ,

c t

.#,% [ e, 3':.O,t.

- [ :.~

c1 .

s ,,. .q. "- .

E E .,, - ..e* f ...

t f e A 'l.

s

. ,a.;

P M a ev1P. s e

kp;

• l e ,

i i

0 *

. c. . );t ' - 'c ~

I s, F N eCc cuhu1- rg :.y.

W t .s .. x..

.+kn, .[.

OO .,.. n . .-

... .t .N . :%n\. s,, ' ,., r,_];,. '

• t ( :s'2 .{

R l f e7u s- . s w

. . ,!.h t .

HI f .. j .

Wf ox5b t' T * , ,

i1 .

E 3s ?s .g n cS 2rr.' - , n.

g >

t-L oe i 'J . ) '-

.a  :

m,,hy.

A E ,

S. ,

E .? .

..}.,.- .-,!.

J ;.

u

. y .,

f .,

WF u i OQoH af x a +f,.;.

.f g U.re.?

N O eO B a'.,*

/.sf. '

( .

s

~

'.e.-[n r , - y  ; f -

3 O

M NT Bu . .', ,.?n.

, s

,.' . . .w..

ME O . ,. 7,3,.

s, *

. hp,  ; . ,

)..ah P. .

e a O

C M I y.

'a .

u >.. -*\; y g.,.

. . ,:. . (-  ; . .* '

vo*f h' h

hg.. g

. . , Qw4 g

.