ML19257C184

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Ack Receipt of NRC Reply to Info Submitted by K Moll for Inclusion in State of CA Nuclear Power Plant Emergency Response Plan.Ca Ofc of Emergency Svcs Has Considered Using Moll Plan as Attachment to CA Plan
ML19257C184
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 08/09/1974
From: Kearns J
CALIFORNIA, STATE OF
To: Brown H
US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML19257C164 List:
References
NUDOCS 8001250152
Download: ML19257C184 (2)


Text

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TE of C Allf oRNIA RONALD RE AG AN. Governor OFFICE OF EMERGENCY SERVICES POST OFFICE Box 9577 5ACRAMENio. CAUFoRNIA 95823

,, '1 August 9, 1974 l

Mr. lierbert II. Brown, Director Office of Government Liaison-Regulation Atomic Energy Commission Washington, D. C. 20545 i

Dear Mr. Brown:

i Thank you for providing us with a copy of your reply to Dr. Kendall Moll regarding the information he submitted for inclusion in the " State of Cali-g) k(

f ornia Nuclear Power Plant Emergency Response Plan."

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I feel some points definitely need clarification.

First of all, Dr. Moll did submit his material to us for use in the plan. However, as indicated by the attached draf t copy of our plan, we did not incorporate " Decision Criteria" as part of this basic document.

Since a plan should define who does what and when, it did not seem appropriate. Nevertheless, we feel that Dr. Moll's sub-mittal contains excellent material and have considered using it as an attach-ment to our plan.

We trust you will have an opportunity to review our plan and, in doing so, note that we do now agree with some of your comments on the SRI draft.

Specifically:

A.

We recognize that protective action guides, guidelines, and guidance have been presented by FRC, NCRP, AEC, EPA and others. At the present time, however, we are required to adhere to the California Radiation Control Regulations which are consistent with the Code of Federal Regulations.

Section 30268, " Permissible Levels of Radiation in Uncontrolled Areas,"

of our regulations states "no user shall possess sources of radiation in such a manner as to create in any uncontrolled area, from such sources, radiation levels which could cause any individual to receive a dose to the whole body in excess of:

1.

two millirem in any one hour; or 2.

one hundred millirem in any 7 consecutive days; or 3.

0.5 rem in any one year."

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I!crbert 11. Brown - 2 B.

h'c realize the above is extremely restrictive, but it is in keeping with present regulations.

Certainly emergency workers and life saving actions will necessitatt: exceeding these limits and accordingly we recommend NCRP Report 39 guidelues he followed.

C.

The inclusion of Pluuonium releases in transportatian and/or reprocessing plant accidents was not deemed appropriate to this document since our plan relates only to reactor accidents. A separate plan dealing with accidents involving transportation of radioactive material will be published later.

Ifr. Ital Gaut of your of fice visited with us June 19-20, during our reactor accident exercise. During his visit we discussed at length our planning effort, specifically as it relates to the AEC guide and checklist, and hopefully there will be some positive action taken regarding our cocmients.

Again, thank you and we loc < forward to a closer relationship between your office and the state's reac or accident planning effort.

Sincerely,

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x J./J.)carns}IntelligenceOfficer Radiological 6 Planning 6 Operations Division attachment

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