ML20087C281
ML20087C281 | |
Person / Time | |
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Site: | Three Mile Island ![]() |
Issue date: | 03/07/1984 |
From: | Aamodt M, Aamodt N AAMODTS |
To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
References | |
ALAB-697, NUDOCS 8403130013 | |
Download: ML20087C281 (33) | |
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION 00CMETED USNpr
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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD:
Gary Edles, Chairman '84 MAR 12 A11:35
~ Dr. John Buck, Administrative Judge Dr. Lawrence Quarles, Administrative Judge, ,,
<3j. <F-In the Matter of )
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METROPOLITAN EDISON COMPANY, ET AL. ) .- Docket 50-289
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(Three Mile Island Nuclear )
Generating Station, Unit 1) )
AAMODT MOTION FOR RECONSIDERATION OF ALAB-697 IN VIEW OF NEW INFORMATION CONCERNING EMERGENCY PLANNING YOR FARMERS Abstract ~_,
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In this document, the Aamodts move the Appeal Board to reconsider their decision-ALAB-697. It is now evident: that specific instructions must be developed for the farmers' self-protection which are acceptable to the farmers in the TMI area. The Commonwealth of Pennsylvania'a information brochure, distributed to' farmers in 'the 10 mile EPZ, doet
[ not contain specific, suitable or acceptable reconsnendations for actions by which the THI area farmers can protect themselves in the event of a radiological. emergency at TMI.
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- Introduction
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l The Appeal Board decided that the issue of emergency planning for farmers in the TMI area was resolved with the single condition that the Commonwealth of Pennsylvania would develop and distribute information
~ . concerning the fanners' options-in the event of an accident at TMI-1.
See ALAB-697 at 29; Attacnment 4.
Q 8403130013 840307 l
l gDRADOCK 05000289 PDR
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The Appeal Board advised the Ccm onwealth to seek the input of the local agricultural consnunity in developing the information concerning protective options and that specific instructions for the farmers' self-protection be included. See Id. at 28 - 30.
However, on June 29, 1983 the Consnonwealth distributed an agricultural information brochure which was developed without any input from TMI area farmers or veterinarians and which lacked any specific information for farmers' self-protection. The brochure is reproduced as Attachment 1. 2 1_
In addition, information provided by Jane Lee of Etters, PA to the Consnissioners (Attachment 2) in January 1984 brings to the clear light of day the Federal Emergency Management Agency's (FEMA) continued l
disinterest in planning for farmers as a unique segment of the THI area population. This attitude, at the time of a crisis, would undermine
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state or county planning for the farmers. I also undermines the f
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capability of the NRC to determine the adequacy of the emergency nians j for the farmers.
l It.is evident, therefore, that the Appeal Board made a gross error in merely recommending that the Conunonuealth's revision of the farmers' emergency information include specific information for the farmers' self-protection. Farmers in the TNI area still lacle the information necessary to provide for their self-protection.
< 1/ The Conunonwealth limited the distribution of the brochures to the I - 10 mile EPZ rather than the 50 mile EPZ,as reconnended by the Appeal Board. '-
l See ALAB-697 at 29.
2/ The Conunonwealth, the NRC Staff and the Licensee have, to this 6ay, ies. ,
neglected to provide the information brochure to the boards and part
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Discussion
~ 1. The revised clans were developed without the inout of the local agricultural community, contrary to the recommendations of the Anneal Board.
The Commonwealth informed the Commissioners on November 9,'1982, during a meeting in Harrisburg (PA),that no local agriculturai input had been sought and that the revision was nearly completed. See Transcript of Commission Meeting, -November 9,1982 at 133,142,143.
As with the original plans, the revised plans were developed solely by the state Department of Agriculture. The Acceptability of the plans to the local farmers was not determined.
The Appeal Board's advise, that the Commonwealth seek the advice of local farmers and veterinarians, was sound. A rationale on which the Commission's new emergency planning rules were based is that
" adequate protective actions in response to actual or anticipated ccnditions can and will be taken." See Federal Register /Vol. 45, No. 162/55403 (Rationale). ,
2.- The brochure does not provide specific information for the farmers' self-protection, contrary to the Appeal Board's recommendation. ,
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The options for self-protection are described under the headings l "HOW'WILL I KNOW WRAT TO D07" an8 "WHAT PROTECTIVE ACTIONS CAN BE TAKEN7" The lack of specific protective actions can best be noted by referring
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to these sections of the brochure (Attachment 1) . The only recommended actions are that the farmers should listen to the Emergency Broadcast System announcements and if "Take Shelter" or "Evacuatica" advisories are given, should contact their county Emergency Management Agency.
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Easily provided specifics, as telephone number (s) of the
, county emergency management agencies,.are not included. Nor is the location of the distribution point for dosimetry and medication.
Information on the use of dosimetry and potassium iodide is not provided.
The brochure does not even provide any specific information on "how" to protect livestock and poultry (although that is its stated objective ) .!See Attachment 1_, Brochure under Purpose of this Booklet.
Only guidelines are provided concerning shielding characteristics of various kinds of shelters and minimum space, food and water requirements for maintenance of various kinds of livestock. See Id.s. The "how" is left to the farmer's imagination and initiative.
Therlack of specific information for self-protection and. protection of livestock is unconscionable. The Appeal Board was' clear in its
. recommendations concerning the type of information the Coimnonwealth ,
- should provide. and the degree of specificity. See ALAB-697 at 26 (Footnote 29)., 28 (Footnote 31). The Appeal Board provided examples.
For instance, it suggested that farmers be reminded of the use of the "weathervane to determine the best time to tend to their livestock" and " told to use proteetive clothing and use wet cloths as a means of resp,iratory protection." The Appeal Board st.ated, "'4e strongly recommend that protective information specific to farJngrs be. developed and distributed." Id. at 29. The Appeal Board was concerned "that s
" neither the' PEliA phamplet nor the Commonwealth's Department of Agriculture plan contains specific instructions on self-protection for those farmers who remain on the farm or return to care for their livestock." Id. at 28.
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- 3. The brochure does not provide adequate information to initiate farmers' nianning.
The brochure pro 6otes cosplacency. The brochure attempts'to
' downplay' the significance of the brochure, beginning with the title.
It is deceptive to use the word " Incidents" in the title to describe the kind of situation at the plant which would make protecetve actions necessary. The purpose of the brochure was to educate the farmers concerning protective actions necessary in the event of serious accidents.
The information concerning the effects of radiation is inaccurate, again on the side of understatement. It asserts that " Beta particles have a low penetration ability and are stopped by things such as a layer of skin, a sheet of plastic or a piece of wood." This does not-L provide a warning that Beta particles can-be inhaled with serious-consequences and skin exposure can be serious.
, Further inaccuratenimpressions are created by the introduction of i
[ the brochure. It likens an explosion at a nuclear power plant to a boiler explosion and implies that any resultant release of ionizing t
l radiation would never reach the level of risk of an atomic bomb explosion, all of which is utter poppy-cock. However, the farmer is unlikely to question the reliability of information provided by state authorities in matters about which he has little' knowledge or familiarity. The-farmer can be misled to believe that the hazards from a nuclear power l- plant accident will always be less significant than it potentially can be. Such a perception would affect the farmer's willingness to take any actions other than remaining and pursuing his daily activities.
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-3/ According to the Envivenmental Protection Agency, Beta particles would have the greatest effect on the performance of livestock.
See Attachment 3.
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5 The guidelines, relative to sheltering, are also not conducive to planning or to taking action. What kir.d of action can result from the following conflicting recommendations?
"D0 NOT USE FANS FOR VENTILATION."
"If you must (use fans), plan to set them to low speed to reduce air intake."
(A table is provided which lists expert opinion (presumably) of minimum ventilation requirements for various kinds and s,1zes of livestock, and following this:)
" Ventilation needs are the judgement of the herdsmen."
" Remember, it is better to have some radioactive contamination than losses from overcrowding, heat and poor ventilation."
A farmer will simply ignore such whimsical information. He has his fans presently set according to his best judgement.
- 4. Are the plans adequate?
No, the plans are still inadequate.
The obstacles which the farmers must overcome in order to obtain dosimetry and medication will place these protective devises out of his reach during an emergency. Consider the compiexity of the instructions
- in view of the farmer's remote location and multiple responsibilities.
After an emergency is announced, the farmers are to contact the county emergency management agency to find out where.a distribution center is located, travel there, fill out forms and learn how to use the dosimetry--
and potassium iodide. There would be no opportunity for the farmers to obtain medical advise and tests relative to-allergic reaction to potassium iodide. In the event of allergy, the farmer's health would be in jeopardy, in his remote location, far from medical assistance.
4/ Farmers should be factored into emergency drills. NRC could then determine whether farmers can and will function as emergency workers to protect the food supply.
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. The only farmer-critique we have in-nand is letter of Joan and Jeremiah: Fisher to the NRC and provided with Attachment 2. The Fishers are highly critical of the brochure. They do not know how they would restrain animals whose feed and water are reduced below the amount I
regularly provided. They do not feel that their economic' situation, or that of other farmers in the area, would allow diversion of resources to long range planning to protect livestock from dangers pos'ed by operation of THI-1. They are concerned that the proposed plans for reduction of ventilation, feed and water are unworkable because of the great risk to the animals' health, productivity and safety, perhaps unnecessarily and, we would add, without compensation.
The Fishers' comments can reasonably be assumed to represent the f
farmers in the area. The Fishers have farmed in the THI area all of their lives and live within three miles of the plant. See Lytle, et al.
Tr. 18749. The criticisms of the other farmers and veterinarians who 2
testified in the hearing were similar to the Fishers' criticirms of the revised plans. This is not surprising since the Commonwealth's original and revised plans are remarkedly similar.
~ The emphasis of the revised plans is the protection of livestock contrary to the Appeal Board's request that the Commonwealth improve and provide specific actions for farmers' self-protection. NRC rules and regulations place protection of human life above the protection of livestock and other property. Federal Register /Vol. 45, No.162 55406-7.
The revised plans are silent concerning substitute care of livestock that-sould facilitate the evacuation of farmers and their f amilies and provide no information concerning the procedures that the Cc=monwealth asserted during the hearing the farmers must follow in order to
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avacuate with their livestock. See ALAB-697 at 24,25; Tr.18,514(VanBuskirk) .
The testimony of the agricultural witnesses was clear that the farmere' willingness to evacuate would depend on the availability of means to care for their livestock. Tr.18,728 (Lytle); Tr.18,730 (V. Fisher);
See ALAB -697 at 22(Footnote 26).
- 5. All agencies responsible for the farmers' emergency planning as well as the Commonwealth of Pennsylvania have failed to accept their responsibility. .
The NRC, FEMA and PEMA have not accepted their responsibility to see that adequate plans are in place for the farmers in the TNI area.
This conclusion is readily reached by reading the correspondence from the NRC, FEMA and USDA to the Fishers. See Attacbment 2. ,
The NRC forwarded the Fishers' letter to FEMA whom NRC considered had been "given the responsibility for assessing the adequacy of offsite j
(i.e., state and local) emergency preparedness for nuclear power facilities."
See Dec. 6, 1983 letter, DeYoung to Fishers. However, FEMA forwarded the Fisher letter to the U. S. Department of Agriculture (USDA) because l
this agency had "the expertise to deal with detailed guidance for farmers". See Dec. 23, 1983 FEMA letter to Fishers. USDA responded by forwarding the matter to the Pennsylvania Emergency Management Agency (PEMA) in Harrisburg. The Fishers, to date, have received no response from PEMA or the Pennsylvania department of .\griculture nearly two
' months af ter they were contacted by USDA on the Fishers' behalf.
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NRC continues to assert (See Kansnerer to Goodling, Attachment 5) that the Fishers' and other farmers' concerns are the rightful responsibility of FEMA. The NRC states that it lacks the expertise to assess adequacy of planning for farmers. Id. This, we find, unacceptable since the t
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new emergency rules clearly state that emergency planning must be l
, sensitive to local populations and the adequacy of the plans is the ;
joint responsibility of the NRC and FEMA. NRC is to review FEMA findings and determinations on the adequacy and capability of implementation of State and local plans.[ Federal register /Vol. 45, No.162/554409;354406.
The rules state, "In any NRC licensing proceeding, a FEMA finding will constitute a rebuttable presumption on a question of adequacy." Part 50.47.
The Kanumerer assertion of NRC lack of expertise relative to the plans ,
for the special population of farmers is, therefore, new evidence which calls into question the NRC's findings and ALAB-697.-
The Commonwealth's assumption af responsibility for determining the adequacy of the farmers' emergency plans was a gross error. See 3-8 infra.
Such a delegation of authority to the Conanonwealth is contrary to NRC rules and regulations, and in view of the Coassonwealth's performance, 5
.a mistake in judgement.
Conclusions The Appeal Board has grossly erred in considering the matter ,
i of emergency planning for farmers resolved by tne Conunonwealth's promise to develop revised plans and the condition that these plans, not accessed by FEMA or the NRC, be distributed to farmers in the
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S/ In fact, the Commonwealth appears to have deliberately misled the Appeal Board into believing that significant revisions would be made to the original plans. See ALAB-697 at 27,28(Footnote 30),
i 29,30. We view the Conunonwealth's withdrawal of its obviously-faulted 4 plans, prior to the Appeal Board's decision, as nothing more than legal strategy to avoid an unfavorable decision. See Transcript, 1 June 24, 1982, Arguments before the Appeal Board, at 92: Buck:
"I think I have looked' carefully through the Commonwealth Exhibit 2A, as massive and confused as it is. And I wish the Conunonwealth were here today because I do have a quarrel with that."
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The brochure distributed to the farmers in June 1983 was not revised in the areas of the Appeal Board's concern, which was that specific information for the farmers' self-protection be provided.
The brochure will mislead the farmers concerning.the importance of adequate planning and makes burdensome reconunendations which the f armers can be expected to ignore. .
The NRC now claims to have no expertise in order to assess adequacy of plans for farmers despite its responsibility to do so.
FEMA continues to assert no responsibility for determining the adequacy of' planning for farmers.
MOTION We motion the Appeal Board to reconsider its decision relative to emergency planning for farmers.
Respec ully subm ted, Dd C Norman O. Aamddt .,
l iuuG Marjor M. Aamodt G
( March 7, 1984 D
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J.TTACHMENT 1 Farmers Eme.rgency Information Brochure
."WHAT YOU SHOULD KNOW ABOUT NUCLEAR POWER PLANT INCIDENTS"
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Farmers Emergency information l l
WHAT YOU SHOULD 1 KNOW ABOUT :
NUCLEAR POWER !
PLANT INCIDENTS i
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- . _- 2 Commonwealth of Pennsylvania Pennsylvania Department of Agriculture ,
2301 North Cameron Street
! Harrisburg, Pennsylvania
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PURPOSE OF THIS BOOKLET ;
This bo: kist provides infctmition to firmars and livestock ownsrs on how to prot:ct livIstock and Y poultry should a nuclear power p! ant incident occur. It supplements the emergency information given in "What You Should Know About Nuclear Power Plant
' incidents /' developed by the Commonwealth of
Dear Farmer,
Pennsylvania for people living naar nuclear power plants. This booklet also supplements information This booklet contains general information on the supplied by the county Emergency Management needs and care of animals and specific information on .
Agency (EMA). -;,
what you may be asked to do if an incident should '
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g occur at Three Mile Island Nuclear Power Station. -
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The protective actions outlined in this booklet are supported by state, county and municipal emergency
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c[4 V -A The likelihood of a serious accident at a nuclear - M power plant is small, but it can happen. A popular mis-conception is that a nuclear reactor could explode like ~
E O-en atomic bomb in the event of a nuclear accident.
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1.a Th3 f act is that nuclear reactors are designed so that it -- -
M is impossible for them to explode like an atomic bomb.
If en explosion would occur because of a malfunction f FM
-"4 in the reactor. it would have the ume eff a -t as a boiler '
exploding. The most probable hazard from a nuclear
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icactor accident is exposure to ionizing radiation.
Please read this booklet carefully and discuss the
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, formation with your fam,ly.
an i Keep it in a convenient WHATIS A NUCLEAR piace for future use.
POWER PLANT INCIDENT?
Remember, it is important that you know the alert The most frequently thought of nuclear oower _
system. lf an emergency occurs, turn your radio or TV l plant incident is the abnormal release of radioactive on and respond quickly but calmly. material by a nuclear power olant. But a nuclear power plant incident may not involve an active release of' Penrose Hallowell radiation.
Secretaryof Agriculture Nuclear radiation is energy in the form of invisible particles or rays that a're given off by radioactive materials. There are three general types of radiation; Alpha particles, Beta particles and Gamma Rays.
, Alpha particles offer little hazard unless the radioac-tive materialis ingested or inhale _d. BefaWrticTes have
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a low penetration ability and are stopped by things ~
such as alaver of skin, a sheet of clastic or a oiece of / _
_w ood. Gamma Rays are identical to X-rays and can easily penetrate low density materials. The radioac-tive materials having the greatest impact on agricul-ture are the radioiodines. Radioactive iodine is important because of its abundance in a reactor and its affinity for the pasture-cow-milk-food chain.
Accidents not requirino protective action by the general public may still reauire removal of dairy cattle ,
and/or feed from the contaminated area. ,
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HOW IS RADIATION HOW WILLI KNOW .
DETECTED? WHAT TO DO?
Radiation cannot be detscted through any human senses, but it can be detected by special instruments. Each county EMA has established a " Contact and Experts use these instruments to continually monitor Dosimetry Ki Distribution Point _{or Farmers,",a,, Lit, radi: tion levels around nuclear power plants. If a location eassiy access: Die and known. At the time of nuct:ar incident does occur, monitoring will be the emergency, tmergency Broadcast System (EBS) incr ased and accurate information will be gathered Announcements well direct farmers to report to the for potentially affected areas. designated location. At the location, farmers w,ll i
, The amount of radiation in an area is measured by [eceive dnnimeters, , potassium iooice (KI) and a t rirtion dose, called a Rem. The Rem, based on " Pan _" annhfind them to gxit and re-enter tha con-cff: cts of radiation on the human body,is essentially taminated area. A dosimeter is a pen or card shaped the same as the unit measurement for X-rays. Mil- device used to measure accumulated radiation expo-sure. Potassium iodide (KI) is a drug that offers some lir m, commonly heard,is one-thousandth (1/1000)
, protection to the thyroid gland from injury due to an cf a Rem' accumulation of radioactive lodide. The " pass" will consist of a " Farmer 3mer E ency Worker Cert fica-8 l
tion" form filled out Ty each farmer. The original HOW WILL YOU LEARN Terves as hi ~ pass.~ .
OF A NUCLEAR INCIDENT 7 Farmers will also be given information at the distri-bution point on the__use of dosimeters, what the read-If protectNe measures aire required, the standard ings n.:an, what the Klis for and, how and when to "A1:rt Signal".will be sounded over a siren system use it. Any questions will be answered at the distribu-installed within a ten-mile radius of all nuclear power tion noint. W-T-plants. The " Alert Signal",is a steady three to five I-armers should be aware of the Food and Drug minute tone - not a wa; ling or warbling sound. The Administration *s (FDA) protective action guidelines.
"Alirt Signal" means peoplu within hearing distance These are not regulations, but are recommended should tune to their local TV or Radio Emergency guidelines for farmers and emergency workers.
Brudcast Station. A message will be broadcast According .to the guidelines, projected radiation advising the action to be taken. To make sure overy- cosage should not exceed 5 Rem for the whole body.
one "gets the word," the emergency broadcast rnes- Desimeters' and calculations are used to determine sage will be repeated frequently. State and or local the radiation dose. Farmers wilt raceive belo at the dis-municipal police, fire departments and cSer agericie a tribution point on their calculations, will carry the message. Sound trucks, bull horns an:1 - Emergency workers from the Pennsylvania DepartM door to door contacts willbe made, ment of Agriculture will be available to collect field REMEMBER: If the " Alert Signal" is heard, TURN samples of milk, livestock forage, feed, and water for ON YOUR RADIO OR TV. laboratory analysis. Contamination levels and appro-
\ / priate health talated advisories will be issued. gh
' + b ' WHAT PROTECTIVE ACTIONS 5 CAN BE TAKEN?
i Thsre are two simple and effective steps that can l
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be taken in a nuclear power plant incident.
One steois takino cover or sheltar; go indoors. Take N
l sMer is tiie_ action usually taken is a small ouG M .
radiation rises from a nuclear clant_and moves swiftly l . v ~away. Farmers hearing a "Take Shelter" advisory should take shelter themselves and if time permits, li .
f i- shelter animate and provide uncontaminated feed and I
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ther step is evacuation. Evacuation is recom-
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hearing an " Evacuation" advisory _should shelt:r the_ir HOW MUCH SPACE IS REQUIRED
'aniniels if snough advance waming is given. bhelt;r.
eng giv. s some pr tectson from rirborne radioactivy '
E MMW particles and makes it easser to supply feed and water Decide how many animals need shelter and deter-without contamination. mine priorities for sheltering stock. Providing shelter Farmers affected by a "Take Shelter" or "Evacua. and care for all livestock is m"ativ imoractical and tion" advisory should contact their county Emer* impossible. Plan to give dairy cows and best breeding gency Management Aoency (EMA) as directed by the stock the most protected areas. If an evacuation is 1:m rgency Broadcast System (EBSL called and there is time, place the calves, especially The basic objective of protective actions is to r.ewborns. with valuable lactating cows. Trv to milk all reducu the amount of radiation received by the f armer cows BEFORE evacuating. The following chart can cnd his livestock. Farm operators r. car a nuclear help determine space requirements.
p::wer plant should take advantats of all their rrsources, plan ahead for adeouata live stock shelter.
Unmation arvi ~~=rtion or reca and water. Poor SPACE 1EQUIREMENTS FOR LNESTOCK IN "ventitation or lack of water can harm animalslu'E CLOSED BUILDINGS r4adily. if not more so, than raciation. poiry cowe cow kiProduction pry cow weeningcehee 20 cows or iese . 30 set are feet 21 cows or more .50 squete feet WHAT TY.*E OF SHELTER S cows o, ion . . . . . . . . . . . . . . 20 -. fwt
- " up to 6 monthe . . . . . . . . . . . . . . . . . . 15-20 square feet SHOUL*D BE USED? colves 6 months to 1 year . . . . . . . . . . . . . . 20-30 square foot Shelterad -d -'- == ma'ae+=d from potentially- amicom -
cont:minated air and radioactive materials which are teef oow with ceif . . . . . . . . . . 150 square twt daposited as the radioactive cloud passes. Livestock se f cow dry . . . . . . . . . . . . . . . 50 square feet housed in farm buildings can receive some protection Waaine ceives from diract radiation exposure. calm up to 6 monthe . . . . 15-25 square feet Pl:n ahead for shelter by deciding which buildings ** ""*"*** I Y"" " * "*
cff:r the greatest protection. Bams, milking parlors, shoe, m chine sheds. garages com cribs and swine or Ewo with lemb . . . . . . . . . . . . . . 32 equere feet poultry buildings are all possible liEe' stock shelters. Ewo dry . . . . . . . . . . . . . . . . . . 16 equere fwt Some buildings offor greater protection than others *""'"8 '*** ' ' ' ' * * ' " . A 6 were fm depending on their construction: swine Brood now with litter . . . . . . . . . 40 squere feet Brood sovi, dry . . . . . . . . . . . . . 15 square feet Weenmg pige . . . . . . . . . . . . . . . 10 square feet PROTECTION OFFERED BY COMMON rettoning biogo FARM BUILDINGS 100 pounde o m m . . . m . . m .4 we fwt 200 pounde . . . . . . . . . . . . . . . 6 square feet Percent of outside radiation received by animale inside the Pou8ery building Type of Buiideg Leving hens . . . . . . . . . . . 2 squete feet per bird 5 10 . . . . . . . . . . . . . .Lorge osene concrete or masonry Boilere. . . . . . . . . . . . . . . 6 squaes feet per bird 20 . . . . . . . . . . . . . . Multi-story poultry houses, i Turkeye . . . . . . . . . . . . . . 4 squsic fwt per bint 2o40.............. Lorgem frame buildings 20 40 . . . . . . . . . . . . . .r.4 meson,y or .ons,ete diock
. hoghouse WHAT ABOUT VENTILATION?
30-50 . . . . . . . . . . . . . . conventional freme born
- A primary limiting factor in sheltering livestock is 30 90 . . . . . . . . . . . . . .Other pouhry housee 50 . . . . . . . . . . . . . . conventional hoghouse ipert ventilation. Listen to your Emergency Broadcasthg eenereten System (EBS) announcements to obtain information
- geo,so f . . . . . . . . . . . . . . Pole bems, seenne shade, stock on radiation exposure conditions.
confined underroof Livestock confined in a roofed building and being fed uncontaminated feed and water will still be exposed to radiation from contaminated air entering the building. Therefore, outside air enterino the build.
ing should be kept to a minimum.
DO NOT USE FANS FOR VENTILATION, if you f.ctions and watir for s3vstal months. Additionti pro-must, plan to sat th:m on low spetd to reducs tha air tain will be ne:d:d to build tissum, intsko.
DAmyCOws WATEwDAY FED / DAY RECOMMENDED VENTILATION IN in Production g genone summw 20 pounds hay ANIMAL SHELTERS U* " * * "
Animal Cutsa Feet Minut3/ Cubic Foot Minute /
Animal Dry cows 9 gestone summer 20 pounds hay Animal Wintw Summa 7 % geflone winter Weening calves 6 genons summer 8 12 pounds Cattle 400 pound call 80 hV 30 3 genone er 800 pound dairy 70 200
,.ow w (pregnant) 7 ganons summer 1015 pounds of 1000 pound 100 225 1600 pound 130 300 0 gelions winter legume hay 6 Cow with calf 9 gallone summer 1218 pounds of Hon %
8 genons winter legume hay Sheep Calf 1400 punds) 6 genons summer 812 pounds of Nursing ewe 10 30 60 pound lamb 7 20 4 gallans wintart legume hay Swine Swwe Sow and litter 50 100 Brood sow with litter 4 genons summer 8 pounds grain 100 pou.3d hog 15 40 3 genons winter 200 pound hog 25 75 Brood sow (pregnant) 12 genons summ6r 2 pounds grain 1 gallon winter Ventilation needs are the ludoement of the herc's- 150 pound gitt or board i gellon 3 pounds grain aptn. Hemember, it is better to have some radioactive contamination than losses from overcrowdino, heat Ewe with tamb 4 quarts S pounds hey fond poor ventilation. Ewe, dry 3 quarts 3 pounds hay
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WHAT ABOUT FEED AND Pouary WATER FOR ANIMALS? Layers s eauon.iiOO b,w. iv ib.i100 bird.
BrHws soeu ns/100 birds 10lbs/100 birds Plan to protect feed and water from radioactive Turkeys gallons /100
. contaminants. If animals ingest contaminated feed and water, they will be sxposed to intemal radiat,on. i Give animals uncontaminated feed and water until qusstionable samplas have been enalyzed and deter. Farmers should make plans to protect their animals mined safe. BEFORE_ an actual nuclear power plant emergency Feed stored it; buildings is protected from con- occurs. Farmers are advised to gather as much infor-
! tamirMion. Feed stored outside can be protected by .mation as ross Die to determine the best method for' placing plastic or canvas covering over it as soon as . protecting livestock should an incident occur, warning of anincidentis heard.
The animals' most crucial need is safe water, even mote so than feed. Water t.om a covered or deep well ,
or running spring is safe for livestock.
Livestock care and maintenance may not be possi-bio for the first 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after an evacuation advisory.
I For this reason; the f armer should plan to provide a ininimum emergency supolv of water and withhold fbrd until care is possible. The lack of feed wit' help rcduce the need for water. Decreased water intake will help reduce milk flow.
Af ter the first 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or more, feed livestock one- ,.
h:lf their normal feed for a day; gradually increase the smount by one pound a day per animal until they are .,,
b:ck to their normal rations. "' '
Animals can survive on tlie following minimum
WHAT ABOUT CROPS & FOOD? L:ct: ting drity ccws should b3 remov.td frcm p s-turo to prct:ct milk supply. Animals should be given Pr:t:ctiva acti e for crops, fr:sh fruits and vvp-
- uncontaminated feed and water. Feed stored in build-t bles and othen9od products depends on when tne ings is protected from contamination. Water fiom a contamination occurs as well as the type of crop. covered well or running spring is safe for animals.
Contamination just before or during harvest time Sheltered animals receive some protection from requires washing or peeling of fresh fruits and most radiation exposure, vegetables before consumption. Root vegetables are A pr:tected by the soil. Wait to harvest them until deter- tioE.limitinj factor in protectino livestock is ventila-1t'is bettiiir to have some radioactive contamina-mined safe by authorities. To'n than losses from over crowding, heat and poor Contamination of field crops at harvest time can be ventilation.
minimized through storage. Radioactive decay will Milk and other food products produced in the area r duce contamination of field crops with time. of contamination will be tested by an appropriate Other foods may also be canned or frozen to allow agency. Their advice should be followed.
tims for radioactive decay. Farmers affected by an " Evacuation" advisory should contact their county Emeroency Manaaement g ,
_Ager.cy 1o receive dosimeters, potassium iodide and a pass to enable them to care for their livestock.
>' - * >-- Good judoement and a cool head will be helpfulin
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protecting the Agricult' ural CMmunity in the event nf-
,a nuclear reactor accident.
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At other periods in the growing cycle, effects of contamination should be limited depending on the length of time before harvest.
Further information on protective actions for crops h
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cnd food products will be available through the Emer-
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gency Broadcast System (EBS). ff y - . __ _.j;rla i n .
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SUMMARY
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- The,. basic principles of protecting livestock (and , 3 .s pe ple) against radiation are easy to apply The objec- .. N \
tiva is to reduce the total exposure to radiation. l T
IF AN ACCIDENT OCCURS: -
'd.y w
- Siren alert systems will signal tha public in the 9 s vicinity of a nuclear reactor that a problem has j . .
occurred. Turn on your radio or television for more '-
infgrmation.
Emergency Broadcast System announcements (rrdio and or television) will provide instructions or /
dircctions to the public. Publ!c information state- e<=
i mints will be issued over the same system.
Two primary protection action options for the g;neral public are shelterino and evacuation. it is important that you respond quickly but calmly when notified that any protective action should be taken.
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ATTACHMENT 2 January 23, 1984 Memorandum, Jane Lee to Conunissioners October 15, 1983 Letter, Mr. and Mrs. Jeremiah Fisher to NRC December 6, 1983 Letter, Richard C. De Young to Fishers December 23, 1983 Letter, FEMA to Fishers .
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January 23, 1984 .-
Memorandua Fort Chairman Palladino Commissioner Gilinsky Commissioner Asselstine Commissioner Bernthal
, ' Commissioner Roberts From: Jane Lee Sabject: FARMEBS' EMERGENCY INFORMATION PAMPLET/ RESTART CERTIFICATICN ITEM NUMBER 149 Enclosed correspondence from the NRC, FEMA and the Food Safety & Inspection Service were genersted out of a letter originating from' Jeremiah & Joan Fisher who own and operate a dairy farn . in Etters, PA ,
After numerous pieces of correspondence, Mr. & Mrs. Fisher turned the matter over to me (Jane Lee) and requested that I contact the appropriate Govern- i ment' Agency to seek adequate redress on the questions they raised concerning fara evacuation. .
Despite numerous reservatians and discrepancies pointed out by 'the Fishers and that this plan was unworkable and unacceptable, John F. Stolz, Chief Operating Reactors Branch #4 id.visien af Licensing, wrote to Henry Hukill, Vice Pres. &
Director of TMI 1. notifying him: "We therfore ccasider this restart certification (FEMA Agric. Pamphlet) item to be complete." (Nov. 22. 83)
FEMA's tantimany before the Licenmina Board ===nred the En=rd thev vould be
,. resnonmible for farm evar n= tion. We now witness, with their own signature, that the buck has been passed to the Food Safety & Inspection Service and for all we know any ultimately end up in the Bureau of Transportation or Turtle Besearch. -
Obviously we are witnessing another break in the chain of co==mnd within the NRC. This requirca 1. acdiate attentiun and correction Lf the ERC Cumania.douus.
The entire issue of incompetence surrounding this recent event merely substan-tiates our continued uneasiness about a viable encuation plan on ny level. l There is no doubt should these evacuation plans require mobilization in the near future, the Commissioners will be confronted with their greatest embar-rassment to date.
May we suggest that the Commiss$oners seek out those who work, operate and invest in farms what is a viable evacuation plan and indeed, is. it a workable plan.
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It is an absurdity when the average citizen is compelled to scrutinize 6overn-ment documents almost daily within one bureaucratic agency and correspondence -
becomes a weekly endeavor at full-t.ine capacity because of incompetent Staff, all of which are salaried by the same citizens who aust do their work without zeauneration.
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We would appreciate immediate and corrective action on the Farmers' Evacuation Plan and who is responsible for implementing the plan.
Enclosures:
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cc: Rep. Morris Udall ,
Rep. Richard Ottinger Rep. William Goodling Bep. Pete.r; W. Bodino, Jr.
Rep. Edward Markley Dep. Bobot S. Walker Bep. Robert W. Edgar -
Sen. Arlen Specter Sen. H. John Heinz III Sen. ililliam Dradley State Bep. Bruce Smith e
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October 15, 1983 ,.
Nuc3 ear Regulatory. Commission 1717 M. Street, N.V. ,
Washington, DC 20555 Gentlemen: ,
Several months ago we received a brochure from the Pennys1vania Dept.
of Agriculture on Energency Preparedness. This particulare brochure was ,
for farmars only. (seeenclosure)
It is obvious from the start that the success of these proTosela requires intenas coopsret.iola betww.ta farmers and agriculture personnel w".lling to forfeit their health and safety for the survival of animals.
The farmers are told to contact their county Baergency Management Agency.
in the event of a nuclear mishap. However, it does not specify a particular office, telephone number or person (s) who will be responsible for this endeavor. Even if such were the case, to expect 400 to 500 farmers to call at one office simultaneously is a bizarre expectation.
The idea that farmers are expected to run to the fields in the middle of a nuclear accident to bring reluctant cattle to shelters at irregular schedules, day or night, under questionable weather conditions thus F=%
. themselves in jeopardy, is just too ludicrous to imagine.
To suggest, as the Agriculture that farmers should make long-range plans on alternate uncontaminated feed and water supplies, extends additional burdens on an industry that is already on the brink of extinction due to high interests rates, inflation and low returns on their products. This type of investment is an unreasonable request and is unacceptable to farmers. -
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To instruct farmers "NOT TO USE FANS FOR VDITILATIGC' reveals how little the Pennsylvania Agriculture understands about farm operations.
Cosmercial chicken operations house chickens in very large enclosed build-
$ngs. Ventilation systems are operated by out-take fans or air conditioned utdta with thermostatic controls.. Chickens are highly susceptible to high temperatures and will die very quickly. Cows generate enormous levels of I heat thereby requirins constant ventilation. Without ventilation these animals will encounter physical probless that may lead to death.
The request that farmers cut back'on feed rations and water may sound ramsonable to people but to-livestock, this is nonsense. Animals, especially large ones where restraints are only effective when the animal is,well fed, begin to become restless and bellow in protest. Should the feeding procedure continue, they would break their tethers and bedlaa would ensue..
Contemporary farm procedures where tha use of open stalls has become the norm, is given little or no consideration in the event of emergency evacuation.
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In the event of a rnaclear accident, open-stall operations would have no ;
protection from radioactive releases into the atmosphere.
The Pennsylvania Agriculture Dept. describes gamma rays as the same as x-rays but fails to relate that the difference between x-rays and ganan )
rays released from a melear power plant is that hospital x-rays are under controlled situations whereas gamma rays from a nuclear accident, are un-controlled and deliver whole-body doses. All gasuna rays... hospital and radioactive releases are cumulative. H e Agriculture Dept. also failed to
' warn the farmers about radioactive particulates such as strontium 90 vhich enters the body as calcium aca lodges in the bones...or cesium which seeks the macles and reproductive organs. Se list of radioactive particulates is lona.
Se generous advice given to farmers about emergency evacuation and preparing them for the inevitable accident by expending their own montary :
resources while the Commonwealth of PA hasn't taken the first step in hand-ing out the promised dosimeters, potassium iodide tablets and the passes for farmerc so they may gain entrance or exits into and out of contaminated ,
areas (if anyone should be foolish enough to want a pass) or even holding i a " live" evacuation of all citizens, is .the supreme insult. Can anyone I seriously believe that any of these proposals will or can be applied in the event of another accident at TMI?
, Qar advice to the nuclear industry, who gave us such glowing reports about how cheap, clean and efe nuclear power was prior to the accident and who now mke admissions about all manner of releases and that after all we anlat expect these cost / benefit events in our modern society is he costs to our health and safety, the costs to our peace of mind, the cost in electric service .to the ratepayers, the costs to the states for Baergency Management, the costs for evacuation and the costs for the deprecietion on our homes and farms is above and beyond what any rational person could consider reasonable-or acceptable. All this just to boil watert.
l Sincerely, p .
wDn Jeremiah K. Fisher Joan S. Fisher CC: Commonwealth of Penna enclosure (FarmersBrochure) i
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UNITED STATES NUCLEAR nEGULATORY COMMISSION
. s wasumarom.o.c.nosss
- DEC . 61983 Jeremiah K. Fisher Joan S. Fisher 183 Valley Road Etters, Pennsylvania 17319
Dear Jeremiah and Joan Fisher:
This is in response to your letter to the Nuclear Regulatory Com$ission of I October 15, 1983, in which you expressed concern over the effectiveness of the guidance contained in the emergency information brochure for farmers titled, "What You Should Know About Nuclear Power Plant Incidents," prepared by the Pennsylvania Department of Agriculture. Your comments have significant merit, and we have forwarded them to the Federal Emergency Management Agency (FEMA) for their consideration. Following the accident at Three Mile Island, .
President Carter' directed that FEMA be given the responsibility for assessing the adequacy nuclear power of offsite (i.e.,
facilities. TheState and Nuclear local) emergency Regulatory Commission prep NRC)(aredness is responsible for for onsite emergency preparedness and has the final' licensing authority.
Although the emphasis in emergency planning is providing protection for people, NRC and FEMA are sensitive to the special needs of farmers. A considerable amount of attention was devoted to this subject during the public hearing concerning the restart of TMI Unit 1. The preparation and distribution of the current Pennsylvania Department of Agriculture brochure was a direct result of this hearing process. The primary purpose of the brochure is to provide basic planning infonnation to far.T.ers on what to do in the event of a radiological emergency. Like other emergency planning documents, the .
- agricultural brochure'is subject to change and revision as more experience ;
is ' acquired in its usefulness through the conduct of exercises and as com-ments such as yours are received by the emergency planning organizations.
Accordinglys as indicated above, your coments are being forwarded to FEMt.
for their consideration in the continuing development of einergency response guidance for agricultural interests in the vicinity of nuclear power plants.
1 I trust that this letter is responsive to your concerns. Thank you for your comments on this important subject.,
Sincerely, k ~ '
Richard C eYoung Director Office of nspection and Enforcement
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4 Federal Emergency Management Agency 7 Washington, D.C. 20472 .
DEC 231963 Jeremiah K. Fisher Joan S. Fisher 183 Valley Road Etters, PA 17319
Dear Jeremiah and Joan Fisher:
Your letter of October 15, 1983, expressing concern over the guidance provided in a brochute by the Pent.sylvania Department of Agriculture ("What You Should Know About Nuclear Power Plant Accidents") has been forwarded to this office.
While the Federal Emerge::cy Management Agency (FEMA) is charged with general 2mergency Planning, the expertise to deal with detailed guidance for farmers resides in the U.S. Department of Agriculture (U.S.D. A.). We are therefore forwarding your letter to the office of Emergency Planning,
' Food Safety and Inspection Service, U.S.D. A. , for their consideration.
You should recieve a response from them shortly. We regret this unavoidable delay.
Comments such as yours are valuable to emergency planners and we thank you for taking the time to write the Federal Government.
Sincerely, Assistant Associate Director -
Office of Natural and Technological Hazards Programs l
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United States Food Safety Washington, D.C.
Department of and inspection '20250 Agneusture service l
l January 13, 1984 Mr. and Mrs. Jeremiah K. Fisher 183 valley Road Etters, Pennsylvania 17319
Dear Mr. and Mrs. Fisher > ,
This is in further response to your letter of October 15, 1983, to the Nuclear Regulatory Commission concerning the Commonwealth of Pennsylvania Department of Agriculture brochure titled "What You Should Know About Nuclear Power Plant Incidents."
' Since the incident at Three Mile Island, the U.S. Department of Agric'alture As well as other Federal, and State agencies have placed renewed emphasis on emergency planning for nuclear incidents and have gained significant knowledge and experience in the development of protective actions for residents and property.
t . . ..
The brochure you have read is only a small part of the
! overall pl.anning and preparedness effort in Pennsylvania.
Many of tne issues you raised are more fully addressed in j *the extensive Commonwealth of Pennsylvania, Disaster l Operation Plan for Fixed Nuclear Facility Incidents and the
( York County Radiological Emergency. Response Plan for j Incidents at the Three Mile Island Nuclear Station, which supplements the Commonwealth Plan.
We have discussed your letter with Mr. John Comey, Press Sec,retary for the Pennsylvania Emergency Management Agency l . (PEMA) ,in ,H,a'rrisburg. Mr. Comey has ' indicated that PEMA, in confunction with the Pennsylvania Department of Agriculture, L will provide you with a further' response addressing your
. concerns. ,
Sincerely, George E..Bickerton, Director office of Emergency Planning l-
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ATTACIDENT 3 Page 24 from Environmental Protection Agency bulletin on radiation effects on livestock (further identification unavailable) 4 d
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months after exposure and would be most pro- sisting of gamma, internal beta, and possibly ex-nounced during the winter and in colder climates. ternal beta radiation could show decreased per-Although the effects may be considerable, they formance within a short time. Decreased ability would probably not be as severe as those ofg would be related to body weight losses and tissue tornal beta radiation exoosures. Reduced concep- destruction and repair. Performance over the first
, tion rates could result in fewer offsprinn in the year could be well below normal. As the damage l
second year. The effects of the weight and condi- healed and weight was regained strength would tion of the dam on size and health of the offspring increase to near normal levels.
would also be greatest at this time.
As body weight and condition returned toward Genetics and longevity. There is a common normal, reproductive efficiency would be less af- belief that irradiated individuals will produce off-facted. Also, muscular weakness, A,.wbily in spring with genetic abnormalities. This may be males, may decrease reproductive efficiency technically correct; however, there is little or no sornewhat at a much earher date. Feeding extra evidence to support the contention that transmis-or higher quality feed could prevent weight loss slon of econom/cally or functionally undesirable cnd insure normal reproduction and growth. traits due to radlation-Induced changes In the
. Developing ygng of animals grazing fallout- germ ce/Is of livestock will be a problem after an contaminated pastures could be injured by the attack. Animals showing gross abnormalities of accumulation of radioactive iodine in their my- the skeleton clue to radiation e.v.posures during r'otdi.70eTiroductive_oerformance of such anNate development conceive and bear normal offspring
- trouf51e~ decreased unless proper thernov was (Figure 14). In addition, cattle surviving gsmma g$;inyroCdamaae of mature animals could or gamma plus external beta exposures produce E8verwely affect reoroduction also. but supple- normal offspring (Figure 12). The same is true for mented animals-would perform at normal levels. exposed bulls and boars.
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The longevity of farm animals is directly related; Work. Draft and pleasure animals (horses and M their productivity; the more productive animals mules) surviving gamma ray exposures in the LDu stay in the herd the longest. To the extent that ex-range could show decreased work performance posures affected productivity of livestock, they while sickness was apparent but, thereafter, little would affect actual lifespan. It is probable that ex-l effect would be seen. Exposures of gamma'and posures invc;ving combinations of external and in-cxternal beta radiation could be followed by in- ternal beta radiation would have the greatest effecf stances of decreased ability to work within a few citrausblerTormance may never _ ret _ urn to p_re_-
weeks (due to muscular weakness), and as effects ilttack levels. On the other hano, tne nun, -
cn body weight and condition became apparent iWcrease herd or flock numbers could decrease work efficiency could drop to a low point 8 to 10 culling rates and lessen the importance of per-months after exposure. These effects would be formance in the selection process. Culling on the more noticeable in cold weather.1.arge areas of basis of health and disease would probably in-skin damage could make it impossible to harness crease, especially in later years, since it appears or saddle the animals. As the areas heal and body that survivors would show a slightly increased weight reurns toward normal, work performance incidence of complications in later life.
would increase. Animals receiving exposures con-
. 24
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l ATTACHMENT 4 4
November 22, 1983 Letter, John F. Stolz to Henry Hukill re distribution of farmers emergency information brochure 1
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g UNITED STATES I n -
NUCLEAR REGULATORY COMMISSION l I I .
wasumavow,o.c.nossa 1 z November 22, 1983 l
Docket No. 50-289 i Mr. Henry,D. Hukill, Vice President and Director - TMI-1 GPU Nuclear Corporation P. O. Box'480 .
Middletown, Pennsylvania 17057
Dear Mr. Hukill:
The Atomic Safety and Licensing Appeal Board for the THI-1 Restart proceeding required in ALAB-697 that agricultura1' brochures be distributed to all -
farmers in the 10-mile plume exposure EPZ prior to restart. The staff has been tracking Inis requirement as restart certification item number 149.
In this respect, the Pennsylvania' Department of Agriculture has developed an
- emergency information brochure titled, " Farmers Emergency Information - What You Should Know About Nuclear Power Plant Incidents." The booklet pmvides infonmation to fanners and livestock owners on how to protect livestock and
_ poultry should a nuclear power plant incident' occur.
Over two thousand_capie.s of the publication were mailed first class to farmers within the70-mile plume exposure pathway EPZ on June 29. 1983, utilizing mailing lists furnished by the Pennsylvania Depar1: ment of Agriculture and the local Agriculture Stabil'.zation and Conservatism Service (ASCS) offices of the U.S. Department of Agriculture. In addition, supplies of the pamphlet were placed in the county offices of the' ASCS, Cooperative Extension Service, Soil Conservation Service, and Emergency Management Agencies of Cumberland, Dauphin, Lancaster, Lebanon and York Counties on July 1,_198.3.
The Federal Emergency Management Agency has verified that the agricultural pamphlet has been distributed. We therefore consider this restart certification item to be complete.
Sincerely, j fn -
[ihIF.Stoz, Chief 0 rating Reactors Bra ch #4 vision of Licensing cc: See next page f f /) er h ihg b
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ATTACHMENT 5 February 15, 1984, Letter, Carlton Kamerer to Congressman Goodling 5
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%, UNITED STATES F g g NUCLEAR REGULATORY COMMISSION
, t, a wAsHWGTON, D. C. 20555
%.....+ February 15, 1984 N.h5.J. [ $$$
The Honorable Bill Goodling United States House of Representatives Washington, D.C. 20515
Dear Congressman Goodling:
Thank you for your letter enclosing correspondence from Jane Lee and Jeremiah end Joan Fisher, regarding a brochure for farmers from the Pennsylvania
- Department of Agriculture.
Mr. and Mrs. Fisher originally wrote to the Nuclear Regulatory Comission with coments on the brochure, "What You Should Know About Nuclear Power Plant Incidents". The NRC does not have the ernartite in acricul'ture to evaluate the substance of the Fishers' coments. However, it is our uncerstanding that these comments were forwarded to the Pennsv1vania -
Department of Aariculture on January 13, 1984 and that the Department woulJ be responding _directly to the F1sners.
The brochure was developed and distributed pursuant to a requirement of the l Atomic Safety and Licensing Appeal Board for the TMI-1 restart proceeding
( (restart certification item 149) thati such a brochure be distributed to j farmers in the vicinity of the plant. The Federal Emergency Management l Agency has verified that the agricultural brochures were distributed to all l
farmers within the 10 mile plume exposure emergency planning zone around t
' Three Mile Island in compliance with this requirement. FEMA has the rasponsibility for assessina the adequacy of offsite planning.
The primary emphasis in emergency planning is providfng protection for people. The primary purpose of the brochure is to provide basic planning information to farmers on what to do in the event of a radiological emergency. Like other emergency planning documents, the brochure for farmers i is sub, ject to change and revision as more information is obtained and i
comments, like those of the Fishers, are received and cc,sidered.
Sincerely, e, u / ,
Kammerer, D
/ or
. ffice of Congressional Affairs er *) 0 ,
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This is to certify that the document AAMODT MOTION FOR RECONSIDERATION OF ALAB -697 IN VIEW OF NEW INFORMATION CONCERNING EMERGENCY PLANNING FOR FARMERS was served on the following Service List on March 8, 1984 by deposit'in First Class U. S. Mail -
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Cary J. Edles, Chairman Jane Lee Atomic Safety & Licensing 183 Valley Rd.
Appeal Board Etters, PA 17319 U.S. Nuclear Regulatory Com.
Washingt;on, D. C. 20555 -
Dr. John H. Buck Atomic Safety & Licensing Robert Edgar, Congressman
- Appeal Board 2352 Rayburn House Office Bldg.
U.S. Nuclear Regulatory Com. Washington, D. C. 20515 Washington, D. C. 20555 Dr. Lawrence R. Quarles Ediard J. Markey, Chairman Atomic Safety & Licensing Appeal Board Ove.rsights & Investigations U.S. Nuclear Regulatory Com. 205 Cannon House Office Bldg.
Washington, D. C. 20555 Washington, D. C. 20515 Att: Richard D. Udell Docketing & Service Branch Dauphin County Office U.S. Nuclear Regulatory Com. Emergency Preparedness Washington, D. C. 20555 Court House, Room 7 Front & Market Streets Harrisburg, PA 17101 Joseph Gray, Esq0ffice of Executive Legal Director Commissioner James Asselstine U.S. Nuclear Regulatory Comm. U* S. Nuclear Regulatory Com.
i Washington, D. C. 20555 Washington, D. C. 20555 George F. Trowbridge, Esq. Commissioner Thomas Roberts Shaw, Pittman, Potts & Trow U. S. Nucleat- Regulatory Com.
& Trowbridge Washington, D. C. 20555 1800 M Str...N. W.
' Washington, D. C. 20555 .
, Douglas Blasey, Chief Counsel Comissioner Frederick Bernthal Department of Environmental U. S. Nuclear Regulatory Com.
Resources, Washington, D. C. 20555 Executive House Harrisburg, PA 17120 Comissioner Victor GilinskY Chairman Nunzio Palladino U. S. Nuclear Regulatory Com. U. S. Nuclear Regulatory Com.
Washington, D. C. 20555 Washington, D. C. 20555 Bill Goodling, Congressman United States House of Rep.
Washington, D. C. 20515
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TMIA 315 Pef fer St.
Harrisburg, PA Ellyn R. Weiss, Esq.
Harmon & Weiss 1725 I Street N. W.
Washington, D. C. 20006 Senator Arlen Specter U. S Senate Washington, D. C. 20515 Senator John Heinz U S Senate Wtshematon, D. C. 20515 t
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