ML20008E393
| ML20008E393 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/18/1980 |
| From: | Aamodt M AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8010270517 | |
| Download: ML20008E393 (6) | |
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United States of America U3p
'/ Nuclear Regulatory Commission
'NM I _. ore the Atomic Safety and licensine Board In the Matter of Metropolitan Edison Company, Three Mile Island Nuclear Station, Unit No. 1, Docket 50-289 Further Specification of Aamodt Contention 5, Emergency Planning for Evacuation of Livestock
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Intervenor has reviewed Licensee's Emergency Plan, Appendir D, Appendiz 7,Section V, Anner 3, which is a discussion of the Pennsylvania Department of Agriculture's protective options for livestock.
The plan states that evacuation as an option to reduce livestock exposure to radioactivity after an accident is impractical as an across the board action throughoutthe potentially hazardous area.
Stated is that priority i
of road use and transportation is toward protecting people,and moving of livestock would be disruptive.
The plan proposes options for sheltering livestock that are recommended to be undertaken by the farmer.
Intervenor contends that the task of caring for and at the same time sheltering livestock is monumental, if not impossible, and that a recemmend-ation to the farmer to undertake sucn action is demonstration of total disregard for the farmer's safety.
The report recommends that farmers be considered " emergency workers" with allowance of 25 rem wholeebody ga=ma dose and 125 rem thyroid dose.
If farmers do not wish to remain they are to arrange for evacuation of their own livestock or abandon them.
The latter option would not be accaptable to most farmers, partly because of the financial investment the livestock reprepents and partly due to humanitarian aspects.
Tf no plans were made for the orde*1y re-moval of livestock, the probability of inEt4 tuting such actions during s' emergency would be non-existent.
The farmer has, therefore, been volunteered,bbcause of the nature of his business, to remain behind in the event of a nuclear disaster, to hazard his own life in order to at, tempt to shelter the animals in his care.
Although the lives of the general public are considered above those of animals in the planning, the lives of farmers are considered as less worthy of protecti g tha.
8010270517 g
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2 those of his animals.
In attempt)ng to shelter and care for his animals as recommended in the plan, the farmer would be exposing himself.
The plan does not explore the evacuation option in terms of nu=ber of livestock that couldcbe affected, number of cattle trucks available, suitable sites for reception of cattle, accomodations for the farmers, and time needed to carry out an evacuation.
The recommendations for sheltering animals and their limitations are described below:
1.
The farmer is to identify a building with the strongest, thickest walls to provide the best protection.
Although old stone barns remain on some farms, th'ey are generally small in size, designed to house an average size herd of 200 years ago, or approximately 10 to 30 cows.
To accomodate larger herds of 50 or more cows, farmers have gone to single' story cement block construction or fabricated steel.
The shihlding affect drops as much as 9/10ths of that afforded by preferred construction with 25 ft. of taled hay stored above the housing area.
2.
Ealed hay, stored above the housing area, is needed to optimize shielding.
pq y Newer barns housing large nerdsA o not have hay storage above.
d Amount of hay stored varies seasonally.
The optimum amount of 25 ft.
is an unrealistically large amount except for a short period in the fall.
.Vany barns that have hay storage above the housing floor are not constructed for uniform storage across the entire area; it is generally stacked to each side of a corridor, varying in width.
3 The livestock are to be confined within the barn.
Some barns do not have doors, particularly beef, sheep, swine operations.
4.
Protection assumes " tightly closed buildings".
Barns, even those with doors and windows, are not ti htly closed E
buildings.
They were not constructed,; hat way.
There are spaces around doors, etc.
5.
Space requirements for cattle are promulgated on the basis of
" tightly closed buildings."
These are unrealistic unless special buildings should be con-structed to provide for emergencies.
For instance, a requirement for 60 beef cattle with calves, a situation,possible in early summer, 9000 square feet ofspacewouldbeneededtyhousetheseanimals, or a barn 50 by ISO feet'
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3 6.
Provide adequate water from uncontjminated sources.
Frobable in cases where well water is used and water bowls are inside barn.
However, this assumes no power failure or use of a generator. Not all farms have a back-up electrical supply.
Would this be determined and who would supply equipment, particularly where it was not needed for the year-in-and-out operation of a farm?
7.
An alternative recommended is provision of an emergency water supply in tightly covered gallon drums set inside or near shelter doors.
Taking the same 60 beef cattle with calves, approximately 600 gallons of water wouldsbe needed for a day.
The plan suggests provi-sion for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, so that 20 fifty-five gallon drums would be needed.
At 7 gal, flow a minu.te, it would take three hours for someone to hold a hose to fill the b'aY d5.
If the Yb N were filled Yositioned before an emergency, the farmer would have t'o work around pn area of approximately 80 square feet within his barn.
If the be.a m.s
- 4. avams were placed outside a doorway, they would not only be a hindrance to passage, but a7so an eyesore.
Outside positioning would also hazard the farmer additionally in making the water available.
8.
No recommendations are given on how the water in the drums would be made available to the livestock.
Cattle are reluctant to put their heads deep into a Eru=elSwine and sheep could not reach the top of a drum.
Is the farmer to bucket out the water; how many buckets are needed ; how will 'they be kept from spilling their contents?
How much time will this take the farmer and how does this increase his chance for exposure?
9.
Feed from covered sources is to be used first.
Hay is to be covered with plastic or canvass.
A hay stack can be about 20 x 40 feet; should it be kept covered at all times; how can it be covered expeditiously in case of emergency; how much time will it take; who will provide the covers?
Hay is taken from the outside of the pile; corn falls from the top of the crib.
Can feed that has not been exposed be fed?
0 10.
Plantoshelteranimals/that they will not need care for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, lactating cows need to be milked every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> otherwise there are serious health conditions.
If cows, etc. are birthing, attention is required.
How will ani=als be cared for after 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in event of continued radiation releases?
4 11.
Range operators are to use natgeal shelters to provide some protection.
It would be an enormous job to provide fencing that would retain the animals and to provide water and feed at a distance from barns.
12.
The plan discusses survival rate of livestock receiving from Sco to 3cco rem exposures as a function of type of sheltering.
Is survival of an irradiated aninal meaningful in terms of milk production, use as meat, egg producticn or for breeding?
What are genetic effects?
13.
The plan assumes that the health benefits are greater for livestock remaining,despite radiation exposure,than exposure to shipping and new quarters.
There is preventive medicine for shipping fever.
Cattle are shipped frequently with few attendant problems.
14.
The plan assumestthat need for shelt'ering and feeding stored feeds will last only 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
What actions will be taken if an emergency condition lasts longer than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, possibly over several weeks? What advise will be given to farmers?
15.
The plan does not address indeminity for loss of animals due to recommended care, abandonment in event of doses greater than: recommended for emergency workers, or radiation sickness and death.
Generally, farmers have a lifetime investment in their cattle.
Cows can vary in value from 31000 to twenty or thirty times that amount, or more.
16.
If farmers are advised to evacuate, the plan does not say what will be done to provide a humanitarian end for the livestock.
This is an ethical question.
A nuclear plant accident is a planned event, with a certainly uncertain probability, not a natural disaster.
17.
What plan has been devised for the horses at the Penh National racetracks?
13.
What will farmers do with milk that cannot be trucked out?
l 19.
The plan does not describe any protective gear that will be l
supplied to farmers as emergency workers.
Will they be given dosimeters; it appears not.
Will KI be supplied and for the cattle, too.
How and when will the EI be dis-tributed?
Farmers need all protective devises given others and training in their use if they are to stay, including radio communication.
5 Intervenor contends that since 94I, # nit 1 is located in the midst of farmland, that adequate provision for the safety of farmers must be addressed and that is has not been thus far in the plans of the Commonwealth and the licensee.
R ~pectfully submitted, lcu cl /kt. &&Y
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MarjorY
. Aamadt l/
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United States of America' Uuclear Refula+ cry Co= mission Before the Atomic Safety and licensing Board In the Matter of Metropolitan Edison Company, Three Nile Island Nuclear Station. Unit 1. Docket 5C-289 I hereby certify that copies of Further Specification of Aamodt Contention 5, Siergency Planning for Evacuation of livestock in the above captioned proceeding have been served on the following by deposit in the United States mail, first class,this.20th day of ~0ctober, 1980.
(!/{w L/ I.x.
L%d Ivan W. Smith, Esq.
Atomic Safety and Licensing Board j
U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Walter H. Jordan 881 W. Outer Drive
~ak Ridge, TN 37830 Dr. Linda W. little 5000 Hermitage Irive i
Raleigh, NC 27612 George ?. Trowbridge, Esq.
Shaw, Pittman, Potts & Trowbhidge 1800 M Street, N. W.
Washington, DC 20006 Karin W. Carter, Esq.
505 Executive House P.C. Box 2357 Harrisburg, ?A 17120 James A. Tourtellotte, Esq.
Office of the Executive legal tirecter U. S. Nucic.r Eegulatory Ccamission Washington, D. C. 20555
_< ;e a
Docketing and Service Section Offi'ce of the Secretary U. S. "uclear Regulatory Commission i
'vashington, D. C. 20555 l
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