ML19269E367

Submits Specific Contentions Re Environ & Radiological Concerns.Assessment of Impact on Farmland Is Inadequate Re Estimation of Value & Use of Land & Adverse Impact of Dust, Noise,Litter & Traffic on Area Agriculture

ML19269E367
Person / Time
Site:	New Haven
Issue date:	05/10/1979
From:	Weber N OSWEGO COUNTY FARM BUREAU
To:
References
NUDOCS 7906270272
Download: ML19269E367 (8)

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UNITED STATES OF AIERICA 8 4 ~

NUCLEAR REGULATORY C0!GIISSION A In the Matter of )

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NEW YORK STATE ELECTRIC & GAS )

CORPORATION and LONG ISLAND )

LIGHTING COMPANY ) Docket Nos. STN$0h96

) STN 50-597 New Haven Nuclear Power Station )

Units 1 and 2 )

SPECIFIC CONTENTIONS RESPECTING ENVIRON! ENTAL / RADIOLOGICAL CONCERNS of INTERVE10RS OSWEGO COUNTY FARM BUREAU Upon information and belief, it is our contention that:

1. Agriculture The assessment of impact on agricultu*e is inadequate.

The Applicant and Staff have:

a. grossly underestimated the value of farmland onsite.

b. inadequately assessed current and projected agricultural use of the surrounding area. They have failed to provide an accurate assessment of the importance of agriculture'and agribusiness to the economics of Oswego County as shown in Section 4.1-8, as anended March 1979, " . . . the relatively low level of a6ricultural production

' in the county."

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c. failed to adequately analyze the impact of dust level increases attributable to plant construction and operation activities, including increases in traffic, on crop growth and yields.

c~ underassessed the impact of noise on dairy herd production. We contend that area dairy farmers will suffer loss of income from construction and operating noise,

e. underassessed the impact of noise and seismological disturbances from blasting during construction We contend that such blasting would adversely effect dairy herd production and result in loss of income to area dairy farmers through reduced production and increased veterinary costs.

f. failed to include the adverse economic impact on farming resulting from increased traffic making some fields inaccessible.

g. underestimated the impact of increased litter on agriculture. Such litter would effect cattle grazing and cropping of fields resulting in loss of income to area farmers,

h. failed to assess the resulting decrease in area farmland values. Nor has the compatibility of nuclear power & agriculture been adequately assessed

1. failed to analyze fungus growth on apple, straw-berry, et al. , fruit crops resulting from increased levels of moisture and salts in the atmosphere in relation to the cooling towers.

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j. underestimated the impacts of increased rain, snow and ground-level fogging upon agriculture in the plume-path area of the cooling towers.

We contend that moisture and salt level increases will have a severe negative effect on cropping the effected areas.

k. failed to analyze the adverse effect of construction blasting on fruit and vegetable crops.

1. failed to adequately analyze the impact of the construction and presence of the intake pipe on the properties involved, specifically the fruit orchard. We contend that drainage fields will be disrupted and destroyed, producing trees will be destroyed and the stratification of the soils will be disrupted which will cause irreparable damage to the land for the production of fruit.

m. underestimated dwelling requirements for con-struction workers and operators. We contend that additional land will be required for housing to be built for these people which may involve additional agricultural lands for the following reasons:

1. overlap of construction of Nine Mile II and New Haven 1 and 2

2. the size of the project as compared to Nine Mile II

3. the increased cost of commuting

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due to gasoline price increases

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We further contend that in the event of immigration of such persons from outside of the area, farmers will suffer undo harrassment and loss do to complaints against common farming practices.

n. inadequately assessed the violation of two Agricultural Districts (Mexico and New Haven) whose formation was at the discretion of those agricultural interests they represent for the purpose of preserving farmland by providing dis-couragements to other land use alternatives within the Districts and includes lands of

" Statewide Importance".

o. failed in the Cost / Benefit Analysis to:

1. include the loss of dairy cattle in the event of an emergency evacuation on short notice (ie 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) such that provision could not be made for milking and feeding cattle. Cows must be milked every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and fed three times per day (approximately).

2. include increased costs of farm equipt-ment repairs due to increased litter.

3 Laclude a cost / time analysis for increased time involved in transportation of crops due to increase 2 }th$ffb

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4. include increased costs of labor and fuel for farmers who anst work under 765 KV and 345 KV lines.

5. include loss of available employees for agriculture due to competition for said enployees by the Applicant with Agriculture.

6. include the loss of agricultural products

- cattle, produce, et al., due to theft.

7. include the loss of cattle from increased stress due to chango in routine.

p. failed in Transmission Analysis to:

1. adequately evaluate decreased breeding capacity of cattle under high voltage transmission lines.

2. access compaction of soils during con-struction and maintenance of 765 KV and 345 KV lines.

3. analyze increased costs to farners who must ground electric fence under nigh voltage transniscion lines.

4. analyze the coupatability of transmission line naintenance and agricultural practices.

6. accurately estinate the loss of agri-cultural lands to the 765 KV and 345 KV lines.

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7. adequately assess the unnecessary siting in Oswego County in terns of transmission losses when viable alter-natives to the preferred site selected e::ist closer to the Applicants load center

q. inadequately assessed the probability of a nuclear accident and consequently is overly optinistic of the negative effect of such on agriculture in reguards to:

1. loss of markets

2. loss of land use

3. loss of crops (harvested and unharvested)

4. loss of donestic farn aninals

5. loss of water use

6. loss of saleability of land all or any cf which would have a severe econonic inpact on farners.

r. Preface. It is our contention that the Applicant and Staff have failed to prove that no existing danage to domestic farn animal hecith from radiation releases is in evidence in Oswego County from the already operating Nine Mile I and Fitzpatrick Nuclear Stations. Such health evaluations are critical to the econonic well-being of agriculture in Oswego County and we therefore subnit:

1. Domestic Farn Animal Health Monitoring i.' '

The Applicant and Staff have failed to out-2131 214

-7 line a domestic far= anical surveillance progran to monitor the effects of radiation on the health (including genetic effects) of these anicals in the surrounding area and should be required to do so.

s. Milk Monitoring Preface. Timely detection and assessment of any contanination is a vital process which milk producers and distributors deal with daily. Radiation is no less serious a contaminent than any other milk is tested for every time it leaves the farm, but radiation is a contaminent over which the farmer has no control nor means of detecting. The fluid milk product is consumed in a short period of time af ter production and therefore expediency in detection and assessment of radiation contamination is critical to the producer, distributor and consumer of nilk.

1. The Applicant and Staff have failed to provide for year round testing of milk for radiation contanination and should be required to do so, with the results innediately provided to the producer,

t. Accidents The Applicant and Staff have not developed a plan for the innediate notification to the local population in reguards to the consumption of agricultural products grown

- or produced by themselves in the event of an accidental rad-intion release and shculd be required to do so. This notice is necessary due to the fact that area residents grow or produce large volumes of foods for their own private consumtion.

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u. Radiation Monitoring The Applicant and Staff have failed to develop a progran for monitoring Strontium 89 m2d 90 in agricultural products aid should be required to do so.

v. Crop and Domestic Farn Animal Contamination

a. The Applicant and Staff have failed to determine in the event of the repeal of the Price-Anderson Act the funds which would be necessary for full reimbursenent of crop and donestic farm anical destruction should they beoone contaminated and should be required to do so, at full market value at the time of such an event.

b. The Applicant and Staff have also inadequately assessed the marketability of farn products contaminated by background radiation fron cancade sources.

Lack of adequate analysis of radiation releases from Nine Mile 1 and 2 and Fitzpatrick Plants combined with the proposed New Haven 1 and 2 Plants makes the estimates estimates of background radiation unrealistic and does not ensure the narketability of farm products.

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sJ Nancy K. Weber Intervention Coordinator Oswego County Farn Bureau Dated: May 10,1979 cc: All Service Addresses 2131 216