ML18026A352

Forwards Summary of Conformance w/10CFR20,50 & 100. Conformance w/10CFR50 App a Is Discussed in Section 3.1 of FSAR

ML18026A352
Person / Time
Site:	Susquehanna
Issue date:	05/14/1981
From:	Curtis N PENNSYLVANIA POWER & LIGHT CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
PLA-777, NUDOCS 8105190381
Download: ML18026A352 (26)

Text

REGULATU iNFORHATION DISTRIBUTION 'TEH (RIDS)

ACCESSION NUR:8105190381 OVC ~ DATE: 81/05/14 NOTARIZED: NO OOCKET 0 FACIL:50-387 Susquehanna Steam Electric Station, Unit 1> Pennsylva 0 50-368 Susquehanna Steam Electric Station~ Unit 2, Pennsylva 0 8 AUTH ~ NAivif AUTHOR Af FiLIATION CORTI S i "l. W o Pennsylvania Power K, Light Co.

REC IP. NAiwf RECIPItiV 1 AFFILIATION YOUNGBLOODiB.J ~ Licensing Branch 1 SUBJECT; Forwards summary of conformance w/iOCFR20I50 L 100 w/luCrRSO App A is aiscussed in Section 3.1 of 'onformance FSAR ~

DISTRIBUTIUN CODE: 8001S COPIES RECEIVED:LTR ENCL SIZE::D8 TITLE: PSALM/f.SAR AiiDTS and Related Correspondence iVOTES:Send IKE 3 copies fSeR 8 all amends' cy.'BAR-LRG PN(CRIB) 05000387 Send ISE 3 copies FSAR 4 all amends. 1 cy'.BwR-LRG Ps(L.RIB) 05000388

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Ppal TWO NORTH NINTH STREET, ALLENTOWN, PA. 18101 PHONE: (215) 821-5151 NORMAN W. CURTIS Vice President-Engineering & Constructen 821.5381 May 14, 1981 Mr. B. J. Youngblood, Chief Licensing Branch No. 1 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 SUSQUEHANNA STEAM ELECTRIC STATION 10 CFR COMPLIANCE ER 100450 FILE 841 DOCKET NOS, 50-387 PLA-777 AND 50-388

Dear Mr. Youngblood:

In response to the Commission's request, enclosed you will find an itemized review of the compliance of Pennsylvania Power and Light Company and the Susquehanna Steam Electric Station, onits 1 and 2 to 10 CFR, Parts 20, 50 and 100.

Please note that conformance to 10 CFR 50 Appendix A, General Design Criteria for Nuclear Power Plants, is discussed in Section 3.1 of the Final Safety Analysis Report (FSAR).

If you have any questions on the enclosed document or any of the referenced material, please contact me.

Very truly yours, N. 3 . Curtis Vice President-Engineering and Construction-Nuclear RRS/mks pool Attachment (I(

~~.>gzg~a 3 PENNSYLVANIA POWER & LIGHT COMPANY

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SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 A Summary of Conformance to Nuclear Regulatory Commission Regulations of 10CZR Parts 20, 50 and 100 Pennsylvania Power 6 Light Company May 1981

INTRODUCTION This document has been prepared as a summary of the conformance of Susquehanna Steam Electric Station (SSES) design and operation to the NRC regulations of 10 CFR Parts 20, 50 and 100. Those sections of regulations which specifically impose compliance requirements on licensees are addressed.

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ENCLOSURE ComLIANCE OF SUSqUEHANNA STEm ELECTRIC STATION UNITS 1 AND 2 WITH THE NRC REGULATIONS OF 10CFR PARTS 20 50 AND 100 Regulation (10CFR) ~Com liaace 20.1(c) Conformance to the ALARA principle stated in this regulation is ensured by the implementation of PPSL policies and appropriate Technical Specifications and health physics procedures. Chapters ll and 12 of the FSAR describe the specific equipment and design features utilized in this effort.

20.3 The definitions contained in this regulation are adhered to in all appropriate Technical Specifications and procedures, and in applicable sections of the FSAR.

20.4 The Units of Radiation Dose specified in this regulation are acceptable and conformed to in all applicable SSES procedures.

20.5 The Units of Radioactivity specified in this regulation are accepted and conformed to in all applicable SSES procedures.

20.101 The radiation dose limits specified in this regulation are complied with through the implementation of and adherence to administrative policies and controls and appropriate health physics procedures developed for this purpose. Conformance is documented by the use of appropriate personnel monitoring devices and the maintenance of all required records. (See FSAR Chapter 12.)

20.102 When required by this regulation, the accumula'ted dose for any individual permitted to exceed the exposure limits specified in 20.101(a) is determined by the use of Form NRC-4. Appropriate health physics procedures and administrative policies control this process. (See FSAR Chapter 12.)

20.103(a) Compliance with this regulation is ensured through the implementation of appropriate health physics procedures relating to air sampling for radioactive materials, and bioassay of individuals for internal contamination. Administrative policies and controls will provide adequate margins of safety for the protection of individuals against the intake of

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radioactive materials. The systems and equipment described in Chapters ll and 12 of the FSAR provide the capability to minimize these hazards.

20.103 The reactor building ventilation system is designed (b)(1) to provide a means to reduce the concentration of particulate and gaseous contamination to assure safe continuous access (40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />s/week) during normal reactor shutdown (FSAR, Sections 12.3.3.1 and 12.5.3.2.3.1).

Portable ventilation systems, hoods, and tests are used as practicable to contain and reduce airborne particulate and gaseous contamination during the performance of various jobs.

20.103 Evaluation of airborne activity in restricted areas (b)(2) is discussed in the evaluation of compliance to Section 20.103 - Paragraph (a)(l).

Issuance and Selection of Res irato E ui ment Radiation protection personnel at SSES will select appropriate respiratory equipment so that contaminant concentration inhaled by the wearer does not exceed the appropriate regulatory limits specified in Appendix B, Table I, Column l.

Should an individual receive greater than 40 MPC hours in 7 consecutive days, an evaluation will be made to identify the cause and actions will be taken to prevent recurrence. Records will be maintained for each occurrence.

20.103(c) Radiation protection personnel at SSES will select appropriate respiratory equipment so that contaminant concentration inhaled by the wearer does not exceed the appropriate regulatory limits.

The protection factors used at SSES comply with the protection factors permitted under Regulatory Guide 8.15.

20.103 SSES is in compliance with 10CFR20.103 - Paragraph (e) a (f) (c) and therefore is exempt from the requirements of Paragraph (e).

20 '04 Conformance with this regulation is assured by appropriate PPGL policies regarding employment of individuals under the age of 18 and the SSES Administrative Procedures restricting these individuals'ccess to restricted areas.

20..105(a) Chapters 11 and 12 of the FSAR provide the information and related radiation dose assessments specified by this regulation.

20.105(b) The radiation dose rate limits specified in this regulation will be complied with through the implementation of SSES procedures, Technical Specifications, and administrative policies which control the use and transfer of radioactive materials. Appropriate surveys and monitoring devices will document this compliance.

20.106(a) Conformance with the limits specified in this regulation will be assured through the implementation of SSES procedures and applicable Technical Specifications which provide adequate sampling and analyses, and monitoring of radioactive materials in effluents before and during their release. The level of radioactivity in station effluents will be minimized to the extent practicable by the use of appropriate equipment designed for this purpose, as described in Chapter 11 of= the FSAR.

20.106(b) PPRL has not and does not currently intend to include 20.106(c) in any license or amendment applications proposed limits higher than those specified in 20.106(a), as provided in these regulations.

20.106(d) Appropriate allowances for dilution and dispersion of radioactive effluents will be made in conformance with this regulation, and are described in detail in Chapter ll of the FSAR, and in Sections 3/4.11 and 3/4.12 of the Technical Specifications.

20.108 Necessary bioassay equipment and procedures, including Whole Body Counting, will be utilized to determine exposure of individuals to concentrations of radioactive materials. Appropriate health physics procedures and administrative policies implement this requirement. (See FSAR Chapter 12.)

20.201 The surveys required by this regulation will be performed at adequate frequencies and contain such detail as to be consistent with the radiation hazard being evaluated. When necessary, the Radiation Work Permit system established at the station provides for detailed physical surveys of equipment, structures and work sites to determine appropriate

levels of radiation protection. The SSES Adminis-trative Procedures and applicable health physics procedures will require these surveys and provide ~

for their documentation in such manner as to ensure compliance with the regulations of 10CFR Part 20.

(See FSAR Chapter 12.)

20.202(a) The SSES Administrative Procedures and applicable health physics procedures will set forth policies and practices which ensure that all individuals are supplied with, and required to use, appropriate personnel monitoring equipment. The Radiation Work Permit system will be established to provide additional control of personnel working in radiation areas and to ensure that the level of protection afforded to these individuals is consistent with hazards in the work place. (See FSAR the'adiological Chapter 12.)

20.202(b) The terminology set forth in this regulation will be accepted and conformed to in all applicable SSES health physics procedures, Technical Specifications, and those SSES Administrative Procedures in which its use is made.

20.203(a) All materials used for labeling, posting, or otherwise designating radiation hazards or radioactive materials, and using the radiation symbol, conform to the conventional design prescribed in this regulation per SSES procedures.

20. 203 (b) This regulation will be conformed to through the implementation of appropriate health physics procedures and portions of the SSES Administrative Procedures relating to posting of radiation areas, as defined in 10CFR Part, 20.202(b)(2).

20.203(c) The requirements of this regulation for "High Radiation Areas" will be conformed to by the implementation of the SSES Technical Specifications and appropriate plant health physics procedures, as well as the SSES Administrative Procedures. The controls and other protective measures set forth in the regulation are maintained under the surveillance of the SSES Health Physics group.

It should be noted that Technical Specification 6.12.1 will provide alternate access control methods to be applied "in lieu of the 'control device'r

'alarm signal'equired by Paragraph 20.203(c)(2) of 10CFR20," which will prevent unauthorized entry into a high radiation area.

20.203(d) Each Airborne Radioactivity Area, as defined in this regulation, will be required to be posted by provisions of the SSES Administrative Procedures and appropriate health physics procedures. These procedures also provide for the surveillance requirements necessary to determine airborne radioactivity levels.

20.203(e) The area and room posting requirements set forth in this regulation pertaining to radioactive materials will be complied with through the implementation of appropriate health physics procedures, and SSES Administrative Procedures.

20.203(f) The container labeling requirements set forth in this regulation will be complied with through the implementation of appropriate health physics procedures, and portions of the SSES Administrative Procedures.

20.204 The posting requirement exceptions described in this regulation are used where appropriate and necessary at SSES. Adequate controls are provided within the SSES health physics procedures to ensure safe and proper application of these exceptions.

20.205 All of the requirements of this regulation pertaining to procedures for picking up, receiving, and opening packages of radioactive materials will be implemented by the SSES Administrative Procedures and appropriate health physics procedures. These procedures also provide for the necessary documentation to ensure an auditable record of compliance. (See FSAR Chapter 12.)

20.206 The requirements of 10CFR19.12 referred to by this regulation are satisfied by the radiation worker training conducted at SSES. Appropriate health physics procedures set forth requirements for all radiation workers to receive this instruction on a periodic basis. (See FSAR Chapter 12.)

20.207 Licensed materials are not stored outside of the restricted areas at SSES.

20.301 The general requirements for waste disposal set forth in this regulation are complied with through SSES health physics procedures, the Technical Specifications, and the provisions of the station license. Chapter 11 of the FSAR describes the Solid Vaste Disposal System installed at SSES.

20.302 No such application for proposed disposal procedures, as described in this regulation, has been made or is currently contemplated at PPSL.

20 '03 No plans for waste disposal by release into sanitary sewerage systems, as provided for in this regulation, are contemplated by SSES, nor is this practice currently utilized.

20.305 Specific Authorization, as described in this regulation, is not currently being sought by PPSL for treatment or disposal of wastes by incineration.

20.401 All of the requirements of this regulation will be complied with through the implementation of appropriate Technical Specifications and health physics procedures pertaining to records of surveys, radiation monitoring and waste disposal. The retention periods specified for such records are also provided for in these specifications and procedures. (See FSAR Chapter 12.)

20.402 SSES has established an appropriate inventory and control program to ensure strict accountability for all licensed radioactive materials. Reports of theft or loss of licensed material will be required by reference to the regulations of 10CFR in the Technical Specifications.

20.403 Notifications of incidents, as described in this regulation will be assured by the requirements of the Technical Specifications, the SSES Administrative Procedures and appropriate plant procedures, which also provide for the necessary assessments to determine the occurrence of such incidents.

20.405 Reports of overexposures to radiation and the occurrence of excessive levels and concentrations, as required by this regulation, will be provided for by reference in the Technical Specifications and in appropriate health physics procedures.

20.407 The personnel monitoring report required by this regulation will be expressly provided for by the Technical Specifications. Appropriate health physics procedures establish the data base from which this report is generated. (See FSAR Chapter 12.)

20.408 The report of radiation exposure required by this regulation upon termination of an individual's employment or work assignment is generated through the provisions of the health physics procedure.

20.409 The notification and reporting requirements of this regulation, and those referred to by it, are satisfied by the provisions of the health physics procedure.

50. 30 This regulation sets down procedural requirements for the filing of license applications. PPM has complied with the procedural requirements in effect at the time when filing its license application and the amendments to it.

50.33 This regulation requires the license application to contain certain general information, such as an identification of the applicant, information about the applicant's financial qualifications, and a list of regulatory agencies with jurisdiction over the applicant's rates and services. This information was provided in the SSES operating license application.

50.34a(c) The descriptions required pursuant to 50.34a (a) are presented in Chapter 11 of the FSAR. The Operating License Stage Environmental Report provides the expected release information required.

50.34(b) The SSES Final Safety Analysis Report (FSAR) was initially submitted on April 10, 1978 and was docketed (Nos. 50-387/388) on July 31, 1978 pursuant to Section 50.34 of 10CFR50. This document and its numerous amendments have been undergoing review by the NRC and its staff.

50.34(c) The physical security plan for SSES was submitted to the Nuclear Regulatory Commission (NRC) in April 1978 with the most recent amendment submitted April 8, 1981. This plan is presently undergoing NRC review.

Contingency plan for SSES was 50.34(d) The Safeguards submitted to the NRC on July 11, 1980 'his was most recently amended on April 8, 1981 and is plan presently undergoing NRC review.

50.36 The SSES applications for operating licenses (a) 6 (b) incorporate the technical specifications requirements of 10CFR50.36 - Paragraphs (a) and (b).

Drafts of these technical specifications are undergoing NRC review.

50.36(c) All of the above listed categories are contained in the current draft technical specifications. The technical specifications will be a "living" document. Amendments, therefore, will be necessary to maintain the document current with NRC requirements, as well as with plant modifications for improved operations.

50.36a The SSES FSAR, Section 12.1, includes considerations which require compliance with 10CFR50.34a (releases as low as is reasonable achievable), and the SSES Technical Specifications, Sec. 3/4.11 ensure that concentrations of radioactive effluents released to unrestricted areas are within the limits specified in 10CFR20.106. The reporting requirements of 10CFR50.36a(a)(2) are complied with through appropriate SSES procedures.

50.37 This regulation requires the applican't to agree to limit access to Restricted Data. Applicant compliance is inherent to the operating license application "whether so stated therein or not."

50.38 This regulation prohibits the NRC from issuing a license to foreign-controlled entities. PPGL's statement that it is not owned, controlled, or dominated by an alien, foreign corporation, or foreign government is in the operating li'cense application for the Susquehanna Steam Electric Station.

50. 40 This regulation provides considerations to "guide" the Commission in granting licenses as follows:

50.40(a) The design and operation of the facility is to provide reasonable assurance that the applicant will comply with NRC regulations, including those in 10CFR Part 20, and that the health and safety of the public will not be endangered. The basis for PPM 's assurance that the regulations will be met and the public protected is contained in this enclosure and in the license application and the related correspondence over the years. Moreover, the lengthy process by which the plant is designed, constructed, and reviewed, including reviews by

PPGL's staff, the NRC staff, the ACRS, and NRC licensing boards, provides a great deal of assurance that the public health and safety will not be endangered. In particular, the Atomic Safety and Licensing Board, after an extensive review, concluded that PPGL had the commitment and technical qualifications necessary to operate Susquehanna Steam Electri'c Station safety and in compliance with all applicable radiological health and safety requirements.

Another consideration is that the applicant be technically and financially qualified. Both PPGL's technical qualifications and its financial qualifications were reviewed in hearings before the Atomic Safety and Licensing Board.

Another consideration is that the issuance of the license is not to be inimical to the common defense and security or to the health and safety of the public. The individual showings of compliance with particular regulations contained in this enclosure, as well as the contents of the entire FSAR and related correspondence over the years, plus the lengthy process of design', construction, and review by PAL, its NSSS vendor, and the government, provide PPM with considerable assurance that the license will not be inimical to the health and safety of the public. As for the common defense and the security, there is considerable assurance that the license will not be inimical in that PP&L has an approved security plan for Susquehanna Steam Electric Station, that PPGL is not controlled by agents of foreign countries, 'and that PPGL has agreed to limit access to Restricted Data.

The final 50.40 "consideration" is that the applicable requirements of Part 51 have been satisfied. Part 51 concerns compliance with the National Environmental Policy Act of 1969. PPGI has submitted a Final Environmental Report and the NRC staff is reviewing the report and will publish a final Environmental Impact Statement pursuant to 10CFR51. Environmental Technical Specifications are pending.

This regulation applies to Class 104 licensees, such as those for devices used in medical therapy.

Susquehanna Steam Electric Station has not applied for a Class 104 license, and so 50.41 is not applicable.

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Section 50.42 provides additional "considerations" to "guide" the Commission in issuing Class 103 licenses. The two considerations are: (a) that the proposed activities will serve a useful purpose proportionate to the quantities of special nuclear material or source material to be utilized and (b) that due account will be taken of the antitrust advice provided by the Attorney General under subsection 105c of the Atomic Energy Act. The "useful purpose" to be served is the production of electric power. The need for the power was determined by the licensing board at the construction permit stage. Although conditions affecting the need for power are constantly changing, PPGL periodically makes load projections, and in PPGL's judgement the need for Susquehanna Steam Electric Station is still substantial. As for the amount of special nuclear material or source material used, there is no reason to believe that their proportion in relation to the power produced is substantially greater than that of other commercial power reactors in this country. The NRC is presently undertaking the antitrust review for

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SSES and'as not yet informed the applicant of its conclusions.

Compliance with Paragraphs (a) through (e) is discussed in detail in FSAR Section 6.2.5.

Paragraph (f) is not applicable, since the construction permit for SSES was published after November 5, 1970.

Paragraph (g) is not applicable, since the notice of hearing on the application for the construction permit for SSES was published after December 22, 1968.

As discussed above, the combustible gas control systems for SSES meet the requirements of 10CFR50.44.

Compliance with 10CFR50.46 is documented in the FSAR, Section 6.3.3. This analysis shows that SSES meets 10CFR50.46 criteria and the ECCS equipment will perform its function in an acceptable manner.

Compliance with 10 CFR 50.48 is documented through the PPM Company Fire Protection Review Report for SSES., This report is in Revision 1 and was submitted to the NRC for review 'in March, 1981.

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50.51 This regulation specifies the maximum duration of licenses. Compliance will be affected simply by the Commission's writing the license so as to comply.

50.53 I'his regulation provides that licenses are not to be issued for activities that are not under or within the jurisdiction of the United States. The operation of Susquehanna Steam Electric Station will be within the United States and subject to the jurisdiction of the United States, as is evident from the description of the facility in the operating license applic'ation.

50.54 This regulation specifies certain conditions that are incorporated in every license issued.

Compliance is effected simply by including these conditions in the license when it is issued.

Indeed, much of 50.54 merely provides that other provisions of the law apply, which would be the case even without 50.54.

50.55a(a)(1) Various chapters of the FSAR discuss design, fabrication, erection, construction, testing, and inspection of safety-related equipment. For example, Chapter 14 provides information on testing of safety-related systems. Chapter 17 provides information concerning the (}uality Assurance Program that was utilized. As a further example of a specific system, Chapter 5, Section 5.2, "Integrity of the Reactor Coolant Pressure Boundary," discusses the design of the reactor coolant system.

50.55a(a) (2) This paragraph is a general paragraph leading into Paragraphs (c) through (i) of the regulation.

50.55a(b)(l) These paragraphs provide guidance concerning the 50.55a(b)(2) approved Edition and Addenda of Section III and XI of the ASME BSPV Code.

50.55a(c) Design and fabrication of the reactor vessel was carried out in accordance with ASME Section III (1968) Class A including Addenda through Summer 1970. Information can be found in Chapters 3 and 5 of the FSAR.

50. 55a (d) Reactor coolant system piping meets the requirements of ASME Section III (1971) Class 1. Information can be found in Chapters 3 and 5 of the FSAR.

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50.55a(e) Pumps which are part of the reactor coolant pressure boundary meet the requirements of ASME Section III (1971). Information can be found in Chapters 3 and 5 of the FSAR.

50.55a(f) The valves which are part of the reactor coolant pressure boundary were designed and fabricated in accordance with the requirements of ASME Section

, III, 1971 edition. (See FSAR Chapters 3 and 5.)

50.55a(g) Inservice Inspection (ISI) requirements are delineated in this part and are specified in the Technical Specifications, Paragraph 4.0.5. As permitted by this part and the Technical Specifications, certain exemptions have been requested for the inservice inspection of various systems and the inservice testing of various pumps and valves. These relief requests were submitted to the NRC as a supplement to the SSES Inservice Inspection Program for pumps and valves in a letter dated March 20, 1981.

50.55a(h) As discussed in FSAR Chapter 7, the protection systems meet IEEE 279-1971.

50.55a(i) Fracture toughness requirements are set forth in Appendices G and H of 10CFR50. Technical Specifications require the use of reactor vessel material irradiation surveillance specimens and updating of the "heatup" and "cooldown" curves given in the Technical Specifications'urther information on this subject is given in Chapter 5 of the FSAR.

50.56 This regulation provides that the Commission will, in the absence of good cause shown to the contrary, issue an operating license upon completion of the construction of a facility in compliance with the terms and conditions of the construction permit.

This imposes no independent obligations on the applicant.

50.58 This regulation provides for the review and report of the Advisory Committee on Reactor Safeguards.

The ACRS is reviewing the operating license application for SSES in accordance with its usual practice.

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50.59 The Susquehanna Review Committee shall review:

a The safety evaluation for 1) changes to procedures, equipment, or systems, and 2) tests or experiments completed under the provision of 10CFR50.59 to verify that such actions did not constitute an unreviewed safety question;

b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10CFR50.59; and

c. Proposed tests or experiments which involve an unreviewed safety question as defined in 10CFR50.59.

The SRC shall report to and advise the Senior Vice President - Nuclear of their activities.

Safety evaluations of changes made to the equipment or review of tests and experiments to comply with 10CFR50.59 shall be kept in a manner convenient for review and shall be retained for at least five years.

SSES will comply with the reporting requirements set forth in 10CFR50.59.

50.70 The Commission has assigned resident inspectors to the SSES. PPScL has provided office space in accordance with the requirements of this section.

PP&L permits access to the station to NRC inspectors in accordance with 10CFR50.70(b)(3).

50.71 Records are and will be maintained in accordance with the requirements of Paragraphs (a) through (e) of this regulation and the license. Paragraph (e) requires that the FSAR be updated (within 24 months of the issuance of the operating license and annually thereafter). Such updates will be made in accordance with this Section.

50.72 Notification of significant events to the NRC will be made in accordance with this regulation.

Appendix A The details of SSES compliance with General Design Criteria is discussed in detail in the FSAR, Section 3.1.

Appendix B Chapter 17 of the FSAR describes in detail the provisions of the quality assurance program which 14

has been implemented to meet all applicable requirements of Appendix B.

Appendix E Compliance with 10CFR50, Appendix E, is documented through the PPGL Company Emergency Plan for SSES.

This plan incorporates the requirements of NUREG 0654 except for some changes with respect to Table B-1. These changes are presently being reviewed by the NRC staff. The plan has been under revision and was submitted to the NRC on April 28, 1981.

Appendices G, H Compliance with Appendices G and H cannot be evaluated at this time. In order to answer NRC questions in these areas, PPM. has requested an evaluation by General Electric. PPSL expects to receive the necessary information by May 21, 1981.

It is the intent of the evaluation to show compliance with these regulations.

Appendix I This Appendix provides numerical guides for design objectives and limiting conditions for operation to meet the criteria "as low as is reasonably achievable" for radioactive material in light-water-cooled nuclear power reactor effluents, PPGL has filed with the Commission the necessary information to permit an evaluation of the SSES with respect to the requirements of Sction II.A, II.B, and II.C of Appendix I. The SSES application for construction permit was docketed after January 2, 1971 and prior to June 4, 1976. No cost-benefit analysis is required. All calculated doses are within the Appendix I of 10CFR50 guidelines.

Appendix J Reactor pressure boundary leakage testing for water cooled power reactors is delineated in this Appendix. These requirements are given in Technical Specification 3/4.6.1. Additional information concerning compliance can be found in FSAR Chapters 3 and 6.

Appendix K Compliance with 10CFR50 Appendix K is specifically required by 10CFR50 46 'SCS compliance is

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documented in Section 6.3.3 of the SSES FSAR.

NEDO-20566 provides a complete description of the methods used to perform the calculations.

100.10 The factors listed related to both the unit design and the site have been provided in the application.

Site specifics, including seismology, meteorology, geology, and hydrology,, are presented in Chapter 2 15

of the FSAR. The exclusion area, low population zone, and population center distance are provided and described. The FSAR also describes the characteristics of reactor design and operation.

100.11 The exclusion area, low population zone and population center distance are described in the FSAR, Chapter 2. All requirements of this section with regard to these areas and distances are met.

The FSAR accident analyses, particularly those in Chapters 6 and 15, demonstrate that offsite doses resulting from postulated accidents would not exceed the criteria in this section of the regulation.

Appendix A Structures and equipment important to plant safety are protected from or designed to withstand all appropriate natural phenomena at the plant site.

Design is based on the most severe phenomena probable with special consideration for the uncertainty in prediction. Detailed discussions of the phenomena themselves, and how they are applied to the structures and equipment, are found in the following FSAR sections:

Meteorology, Section 2.3; Hydrology, Section 2.4; Geology, Seismology, and Geotechnical Engineering, Section 2.5; Classification of Structures, Components, and Systems, Section 3.2; Wind and Tornado Loadings, Section 3.3; Water i,evel (Flood) Design, Section 3.4; Missile Protection, Section 3.5; Seismic Design, Section 3.7; Design of Category I Structures, Section 3.8; Mechanical Systems and Components, Section 3.9; Seismic Qualifications of Category I instrumentation and Electrical Equipment, Section 3.10; and Environmental Design of Mechanical and Electrical Equipment, Section 3.11.,

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