JPN-99-033, Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon
| ML20217C780 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/08/1999 |
| From: | James Knubel POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR JPN-99-033, NUDOCS 9910140040 | |
| Download: ML20217C780 (28) | |
Text
.
. 123 Main Street (Wie Plains. New York 10301 914 681.0350 914 287,3309 (Fax) ghk [ James Knubel ter Authority s"e7'd7$$l2r"
October 8,1999 JPN-99-033 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, DC 20555
Subject:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Response to questions from a 7/12/99 NRC facsimile to the Authority, Re: James A. FitzPatrick USI A-46 program
Dear Sir:
This letter provides the Authority's responses to the questions contained in a July 12,1999 facsimile from the NRC regarding the J. A. FitzPatrick USl A-46 program. The questions were also discussed between members of the Authority's and the NRC's staffs during a teleconference.
If you have any questions, please contact Ms. C. Faison.
l Very truly yqurs, )
1 J. Knubel I Senior Vice President and Chief Nuclear Officer Cc: next page :
1
]
/) l 0
~
9910140040 9910'0 0 PDR ADOCK 05000333 P PDR 1
l
)
f l . .
l.'. \
Cc: Regional Administrator
! . . U. S. Nuclear Regulatory Commission
!- 475 Allendale Road !
King of Prussia, PA 19406 Office of the Resident inspector U. S. Nuclear Regulatory Commission j James A. FitzPatrick Nuclear Power Plant '
P. O. Box 136 Lycoming, NY 13093 Mr. G. Vissing, Project Manager Project Directorate i Division of Licensing Project Management U. S. Nuclear Regulatory Commission Mail Stop 8C2 Washington, DC 20555 l 1
l l
1 l
l l
)
I l
l j
n l
)
l i
Response to questions from the July 12,1999 facsimile from the Nsclear Regulatory Commission regarding the J. A. FitzPatrick Nuclear Power Plant USI A-46 program Question 1:
l is the ground spectrum of the time history used as the input to the model to generate l the IRS at various elevations significantly higher than the Design Basis Earthquake !
ground motion which is characterized by the Housner design response spectrum normalized to a peak ground acceleration of 0.15g? If the answer is yes, provide a plot of the 5 percent critical damping response spectrum of the ground motion time history. j
Response
The response spectrum of the input ground motion time history entirely envelops the Housner design spectrum anchored at 0.15g. It significantly envelops the Housner spectrum at frequencies below 5 Hz and more closely follows the Housner acceleration amplitudes at frequencies greater than 5 Hz. Figure 1 is excerpted from an original plant design calculation (Reference 5) performed by Stone & Webster and shows the comparison for 0.5% damping. A plot does not exist comparing the spectra at a 5% .
damping value. !
Question 2:
Column 3 of the Screening Verification Data Sheets (SVDS) is for the name of the j building in which the equipment item is located. The abbreviations used in this column are not all readily identifiable with a building. Provide a list of the buildings and the abbreviations used to represent them in the SVDS.
Response
The following table shows the abbreviations used:
Building Description Location Abbreviation AD Administration Building Turbine Building Complex BR Battery Rooms Turbine Building Complex CB Containment Atmosphere Outside attached to Reactor Dilution (CAD) Building Building CR Control Room Turbine Building Complex t CS Cable Spreading Room Turbine Building Complex EB Electrical Switchgear Bay Turbine Building Complex EG Emergency Diesel Generator Turbine Building Complex Building PC Primary Containment Reactor Building (Drywell)
RB Reactor Building Reactor Building RR Relay Room Turbine Duilding Complex sA RAI 08SEP99 j
Building Description Location Abbreviation SP Service Water Pump Room Turbine Building Complex ST Steam Tunnel Reactor Building (Upper Portion)
Turbine Building Complex (Lower Portion)
SU Suppression Pool (Torus) Reactor Building Room SW Screenwell House Turbine Building Complex YD Yard Yard Question 3:
On pages 12 and 13 of the SVDS for the equipment items water accumulator, nitrogen accumulator, SLC A double squib activated shear explosive valve and SLC B double squib activated shear explosive valve, the seismic capacity is designated by DOC and the seismic demand is designated by RRS. Page 1 of the Screening Evaluation Work Sheet form (copy attached) contains the abbreviations to be used in the seismic 4 capacity versus seismic demand evaluation. DOC is indicated as seismic capacity '
based on existing documentation and RRS is indicated as seismic demand based on realistic median-centered in-structure response spectra. During the telephone call we were told that NYPA used RRS on the SVDS to indicate a required response spectrum from a dynamic test of the equipment item. Do the required response spectra used to evaluate each of these equipment items envelop the in-structure response spectra at the equipment locations? Provide plots of the 5 percent of critical damping required response spectra.
Response
The term " DOC" was indeed used to signify plant documentation. All four equipment ,
items are Class 0 - that is, not in the GIP twenty classes and as such were declared ;
outliers. Since the comparison could not be the SQUG bounding spectrum or reference !
spectrum, plant documentation was selected. The use of RRS simply appears to be a misnomer as there are neither Required Response Spectra for the equipment or {
i Realistic Response Spectra for the building. In any event, the items were declared l outliers. For purposes of the SVDS, the use of" DOC"is appropriate (since the use of i
the other choices of" bounding spectrum" or "1.5 x bounding spectrum" are not). The l
use of the term RRS is incorrect and is corrected to CRS for conservative in-structure I response spectra. A copy of the corrected pages 12 and 13 are included in Attachment l
B. I l
Question 4 & 5: !
I The Generic Implementation Procedure, Revision 2 (GIP-2) provides for several methods of comparing seismic capacity to seismic demand. Method A.1 compares the l SOUG Bounding Spectrum to the plant's safe shutdown earthquake ground response (
spectrum. GIP-2 places limitations on the use of Method A.1. These limitations are that j SA RAI 08SEP99 2
the SSE ground response spectrum can be used for comparison to the Bounding Spectrdm when:
' .l The equipment is mounted in the nuclear plant at an elevation below about 40 feet above the effective grade, e The' equipment, including its supports, have fundamental natural frequency greater than about 8 Hz.
. The amplification factor between the free field ground response spectrum and the in-structure response spectra is not more than about 1.5.
In Figures 3.1 and 3.2 FitzPatrick USl A-46 Final Report NYPA presents plots of the envelope of the turbine building IRS at elevations 272 feet and 300 feet and reactor building IRS for elevations 272 feet, 326 feet and 344 feet, respectively. The
, amplification factors, above 8 Hz, of some of these IRS for elevations where Method A.1
- was used appear to be significantly above the 1.5 limit set by GIP-2. Provide a building specific justification for the use of Method A.1 at the locations where the amplification
'significantly exceeds the 1.5 limit abon 8 Hz.
Response
The structures at FitzPatrick in which Method A was used are typical nuclear plant structures, either reinforced concrete frame and shear wall or heavily braced steel frame, for which the 1.5 amplification factor is applicable as per the SSRAP Report (Reference 3) and Page 4-16 of GIP-2. These structures are the reactor building which houses the reactor pressure vessel, primary shield wall, drywell and suppression chamber; and the turbine building complex which includes the turbine building, administration building, radwaste building, screenwell pumphouse and emergency diesel generator building.
The following additional information for each of the structures at FitzPatrick is provided as a response to this RAl. This information is provided to indicate:
a) that the structures housing the SSEL at FitzPatrick are typical of nuclear plant construction, justifying the applicability of the SSRAP estimated amplification factor, =
b) the level by which the original conservative licensing basis ISRS exceed 1.5
' times the licensing basis free field response spectrum at locations where !
L, Method A was applied,- i c) that the licensing' basis ISRS curves were very conservatinly calculated, and l d) . that if more realistic median-centered type analyses are performed, the resulting ISRS would not greatly exceed 1.5 times the licensing basis free field response spectrum and are less than the seismic capacity of the i equipment (i.e.,1.5 times the GlP Bounding Spectrum) for frequencies over 8 l
- Hz.
y
, FitzPatrick Site The FitzPatrick site is'a rock site. The buildings are founded on bedrock with a shear
- wave velocity exceeding 5500 ft/sec. During original plant construction, approximately
' 45 feet of the rock was excavated, and the plant _ structures were founded directly on the rock. The free field licensing basis ground spectrum is a Housner spectrum with a pe4 ground acceleration of 0.15g. Figure 2 shows the fra field licensing basis ground spectrum compared to the SQUG bounding spectrum.
Reactor Building (RB)
The reactor build.ing is an embedded, multi-story reinforced concrete shear wall structure from the foundation (elevation 222') up to the refueling floor (elevation 369').
~ The reactor building is founded at elevation 222', with a sand backfill in the annular space between the exterior wall and excavated rock up to elevation 265', and then common backfill up to the yard grade at elevation 272'. The seismic SSEL equipment in
. the reactor building is in the crescent areas (below 272') and on floor elevations 272',
- 300',326', and 344'. All of the seismic SSEL equipment inside the drywell is below elevation 300'. Equipment on or below elevation 300' was considered to meet the J "within about 40' of grade" requirement; the equipment on elevations 326' and 344' was not. The ISRS for the Reactor Building at elevations 272', 326' and 344' versus the 1.5 x
- Bounding Spectrum is shown in Figure 3.'
Turbine Building Complex The base of the turbine building complex varies, but it is typically founded on excavated rock at about elevation 245', with structural backfill up to the top of the rock excavation J at about 265','and common backfill up to the yard grade at 272'. Almost all the
~ equipment in the turbine building complex on the seismic SSEL is at elevation 300' or lower (there are a few items of control room HVAC . equipment that are at about elevation 310'). Based on this, all equipment in the turbine building complex on the seismic SSEL was considered to meet the."within about 40' of grade"' requirement. The ISRS for the turbine building complex at elevations 272' and 300' versus the 1.5 x
' Bounding Spectrum is shown in Figure 4. Except for a negligible exceedance at 33 Hz, the turbine building spectra are enveloped.
Conservatisms in the Licensina Basis ISRS
- Attachment A to this response contains a discussion of conservatisms in the calculation of the FitzPatrick licensing basis ISRS. It is judged that the total effect of all these c conservatisms would result in the FitzPatrick licensing basis ISRS to exceed the realistic, median-centered ISRS (at frequencies above 8 Hz) by factors in excess of 3.
Use of Method A at FitzPatrick The use of Method A has been the subject of continuing discussion between the Seismic Qualification Utility Group (SQUG) representatives and the USNRC staff members on the' application of Method A of GIP-2. Based on numerous discussions with the staff, a position has been developed which is contained in Reference 4. It is SQUG's belief that the GlP criteria, as presented in the GIP-2 document, and reviewed and accepted by the NRC in SSER-2, does not require the Seismic Review Team (SRT)
' SA M 06SEP90? 4
m 4 .
)
- to justify the 1.5 amplification factor for elevations below about 40 ft above effective grade and frequencies above about 8 Hz.
As explained in Attachment A of this letter, the sentence on page 4-16 of the GIP-2,
!The restriction is based on the conditions that the amplification factor between the free-field response spectra and the m-structure response spectra will not be more than about 1.5, and that the natural frequency of the equipment is not in the high energy range"
- merely indicates the basis for the development of the criteria associated with the use of Method A. Method A has two limitations:
Equipment should be mounted in the nuclear plant below about 40 feet above the effective grade, and , .
Equipment should have a fundamental natural frequency greater than about 8
. Hz.
- The statement on page 4-16 that "the amplification will not exceed about 1.5" is the expected result of meeting the above limitations, not a third condition.
'\
As described.in Attachment A, the need for Method A, and the reason licensing basis ISRS frequently exceed 1.5 times the ground response spectrum, is due to the conservatism associated with the analytical procedures used in developing the ISRS. It was only intended that the SRT verify that the building in which Method A was applied was a typical nuclear plant reinforced concrete frame and shear wall or braced steel frame structure.
Conclusion
)
The preceding discussion leads to the following conclusions:
e' The structures at FitzPatrick in which Method A was used are typical
- nuclear plant structures, either reinforced concrete frame end shear wall or heavily braced steel frame, for which the 1.5 amplificatt; Ntoris )
applicable as per the SSRAP Report and Page 4-16 of GIP-2.
. The FitzPatrick licensing basis conservative in-structure response spectra used for A-46 show amplifications of more than 1.5 with respect to the free
- field ground spectrum, This is due to conservatisms in the calculation methodology, as discussed in Attachment A to this response. If a more realistic, median-centered response spectra were used, then the
. calculated in-structure response spectra at frequencies above B Hz. would not greatly exceed 1.5 times the licensing basis free field spectrum.
I t
SA M 08SEP99 5
,~. e .;,,:
~[ng_n 90.0 'NIQ 80.0
_ _\. // A/A
/X'//Y.NA '/ \ FX\ 5 \7 \fQh/ Nu
. /g//YAAJ'\/\A 'N Y\ &\
W / ~ \ //
[
s70.0 ((/Y/N/b \ \U h / /Y /
N /\ N \h\ D\
60.0 ,2/ / !b-- ' \
s' [
! [ . /\ b / L f
/ \ /N 1 50.0 '
/
._%7 y AA
\ /
I 40.0 h'M' W'/' /^x /\ \Mx 5 $6X /
_[ /
30.0 .- \ -
/
20.0 .
/ s
\, ! '
f s x .t. /, /.
e o
- s
'N
! ! '\ ,
N, fx f ~ ~ d( X/N. .N/ \(/ j N/
s s
g N N
N/
s 10.0 '
'/ /
9.0
'\ ///k / ^ fi A ' JN '61/ h ' N . 's b / /
' N.jf / M 7-- / / \ // N d
i,0 DFC*s..{.d /L
- [6 /\
/\.lhl
,k '.,'.? h sN ' ///(/.4D(IgN[h'O\\\
J _' b' D / /'
6.0 / \ '
\ ! L /_.Zx'bb AN A$ .j'\\Y_
5cRX /,7[s_g_
'/ \#
f _
~
- 5. 0 / x / N N / \ \ .
k 4.0 /
,. _.h. / !
0 / '
g.
2.0 -
\ '
/ ,
/ \/ f /
xes' e~ ./
N 4 s / /N / ' / - x i.o .. x . Y / X / M 4 9 'AY /'% !.48 M
0.I M//I
'(r'H%%'dTSM6+
'b
'/Oa 'y^nO5'M Mif 4_
/N.'. .
//'o b 'N/\ N nubY // hI 0.G f./ '
hD_.Y
NY ll/ - '
/
j hl/
~
0.5 _J \ / Y
'u /
0.4 /'s /dx' 's'$' $; 1(Q ' ' /N/N 'N'jx53bX/h 0.3 x v// ! 'xp/w--3 N
/
r/ /
/ '
y--- h g / v 7 x 4 e'-N -
4 w> G -' x lY % /G w%
0.2 7
- f. b',-f' -
/ y --l l
's , y
/,X 'N
/yx/ N/ 'N}'- A.
,7',
//>'s/ / \ 'N's 7
'/>,3]^xK/
.7 / /\ /N '
x / 's s:X .
0.1 '
/ A' /t -
'.E.
'n , j 3.; - -e -
y.^ " l.0
- # t # 9 CURVE NO I DARPiliG 0.005 "/t9 10.0 -
Wo2mz wa
/^ ^X NNN U, ,
/\ M"xX s/js 7-h'/N/_u
/\ /\_
x3w
\,/\ )Qx' (
\/\ ,
/
/'N />( T/ 'N 5
/X ymd 9) ' -
I
's ' >//
l
- ',rv3 -
/\/-
> /
l
' An t w w -
< /. /x i xys A/\/$gxl'NN'y i
/5 /N N/s NNN$ _.
k/\ X
'N \\ Nt 'j
/\ / x~ Qh APERTURik
/
4 x
'jpgj V.I
% CARD AIRO Avn!!able on '
l 3 / }/\' , Sporture Card I h)p 4'%, /% -
'N .
'<. y/y / ,
t
'X / /\
X,/
i h
kN kl
{ ,/1
/
)8 f
\MN N , g
/
{40'4.
NA1 'X'NfsN x A -
/\ /\ N /\ fN NN
\ )hl f
/ \ N'
'N /x N Q;
,)4 '4 - (
yys -
q&
b\ Y
>y$
,m/ - , s., X 8 X ,-
y i-
'\/ Figure 1
(' '
,e
/ \
s Comparison of the response spectrum of the input ground motion
/\> , \ /; '/ time history vs. the Housner c <lan spectrum anchored at 0.15g. -
.- r
~ . ..A _f_ g.h,_, , ,
ww .
e e l
e .
1.C i , , , , , , , , , , , , ,
.i i i i e i i i . , . . i i i ,
t I , I } l 4 i i i f I t i I e 4 1 4 8 l l l 6 1 6 6 6 4 8 6 I I I & I a e i i I I t i I I I e i e I f I 4 t 4 I I 4 1 ! 8 I a i e I a t i t I 1 i t i i i t i e i t e -I e i I I i a I e I s 1 0.8 , .
4 I t 4 1 I '
t i I 4 0 4 e i t e i e i i . . e i i e i i e i e 1 i I I i 1 1 1 I I I i a e i e i e e i e i e i i e i i i i t i i I , O I i 1 i . , ,l e i 8, e
, , , I , , . Bounding SM, rum, (Gk ,Figure i 4-2)
I i
1 i
- 0.6 s .
1, t . .l ,. ,
. , . , , , , , , 1 , , ,
I I t I e i 1 6 t 1 I I i 1 e 3
( l i t e 1 i t I I a I , , .I t
,1 0, , t I ,i ,I , ,
t e i t i i t l' 1 4 6 f I t 4 I i
$ t I 4 i e i e i I i i i e f i i
t 1
l 1
l 1
1 l lll 0
t t
6 1 N,
1 9
i 1
4 l
I l lll i 1 i 1 1 8 6 i i 1 1 i 4 1 I t I i 4 4 4 t I I I I e i e i i t i i i I 02 l,
.i 1 , , , . .
l l l l l,lll
, , , , t l l l l
, , , , l, l,l AFNPP.. Degn Bus EdthquWe
, , (UESAR Fii,pe ,
2h, .2) l l l l 1 . . . . . .t , , . . . ,1 , ,I i e I i l i I i 4 i i i I I t I c
1 10 100 Fnsquemy(Hz)
Figure 2 Licensing Basis Free Field Response Spectrum Compared to Bounding Spectrum (Both curves 5% damped) l i
i l.
l l
l l l
\
l i 1
L 1
r
)
. . j
. i I
l l 1.c , , , , , ,
, , , , , , , , , _ _ n a, Buia , , ,
_ __ n,,,, unq 3a u , , ,
l l
l l
,' l l l l l - - - n aw sura m l ll
,i , , , .i ,i ,
,i 1.5x Bourdng Spearum i ,i
, a a , I , , I , , , , ,
g a
, I I , { ,6 = , , , ,
t l
- , , , s,i , , , , , , , , ,
4 j
f , * , ,,
I a ,
, 4, 1.0
, f, f[ ,
i i
i , i , i i l \, ,, P\' l\
l 3 l l l ' I;. ---
l l -l l l l l i ,l t, , , , , , , f, , , , I, , 4, ,
t
, , t , , i , , , I , , , , ,, 1 l
( lk
. 1 , , l , 8 . , f , ,,
o.s l l / l l l - Ms ,- l l l l ll
,i i
i i
i m il i,i l\',\
i .i r
> N i
\,i e
i i ,
, , , i, ,
i i , , ,
,/
, f, , g,
,.i
,g , , f b % v,. gt, ,i g,
i i
, i, , ,
f,, , , s, s, r
, s, , u l
! - - > _ _1, _ _l/ l l l l l l :
\ ,P, ' 7, l_
v: ~,l ~,l . i c
1 10 100 Frequency (Hz) 1 1
Figure 3 1.5x Bounding Spectrum vs. the Reactor Building Floor Response Spectra (All curves 5% damped) l l
t.
1.5 - , , , , , , , , , ,
l l
i l l ,' ,li i ll l TB- 300- NS
- - TB- 300 -EW ll
, , ,i ,i , , , , ,
TB. m -NS i i
--- TB- m - EW
! 19 Ban *vspasum : : :
,i , ,. , , ,. , , , , , , , , , j
, , ,l , , , , , , , , , , , ', ,
, , , , , , 1
' , , , , , , , , 1 1.0 I
, , , , , , ,\ , , , , , , , .
^ , , , , , , , , ,} , , , , , , , ,
, , , , , , , , , , , t , ,
, , ,l , , ,! , , , , , , , , , ,
, , , , , , , , , t , , , , , ,
, , , , , , ,, , , , , , , , , i
~
0.5 , , ', , , , , ', , ', ', , ,
i l l l l l l ll pl
, , , ./
, \l , ,
l l
l l l l
, ,, /, -
-. - - , %,( - , - -,-
, , , i' l l l l l e' <, F H , ,
c'~l m.
ESM, f s, e,f
, , , , , , , ~ ,.
__ _ ! _ __ l l l IIl l l c
1 10 100 Frequency (Hz)
Figure 4 1.5x Bounding Spectrum vs. Turbine Building Floor Response Spectra (All curves 5% damped)
I l
l l
d
, REFERENCES
- 1. NRC Fax to New York Power Authority (NYPA), "J. A. FitzPatrick Nuclear Power Plant Request for Additional Information USl A-46," dated 9/6/96.
- 2. NYPA Letter JPN-96-048 from W. J. Cahill, Jr. to USNRC, dated 10/25/98.
- 3. Senior Seismic Review and Advisory Panel (SSRAP), "Use of Seismic Experience and Test Data to Show Ruggedness of Equipment in Nuclear Power Plants,"
Revision 4.0, February 28,1991.
,. Information on Use of GIP Method A," dated June 30,1997.
- 5. Stone & Webster Calculation No.11825-SM-008, Dynamic Analysis Reactor l Building,7/16/76. 1 1
~ ._
l 1
l ATTACHMENT A
- 1. Bases for Interpretation and implementation of GIP-2 Rules for Method A Method A of GIP Table 4-1 (Reference 1) provides a methodology to evaluate the seismic adequacy of equipment by comparing equipment capacity based on earthquake experience ground response spectra at database sites with the plant's SSE ground response spectrum (GRS). The composite earthquake experience GRS from the database sites (Reference Spectrum) was reduced by a factor of 1/1.5 to account for possible additional amplification of motion in nuclear plants compared to database plants and is referred to as the " Bounding Spectrum" in the GIP.
l The seismic capacity of equipment defined by the Bounding Spectrum is compared j to the seismic demand at the effective grade using the plant licensing basis SSE !
GRS. The GIP Method A conservatively limits use of this approach to equipment l which has a fundamental frequency above about 8 Hz and is located lower than about 40' above the effective grade of the building. These restrictions prohibit the use of GIP Method A for equipment with low fundamental frequencies and for '
equipment located at high elevations in buildings where the structure seismic ;
response is known to be typically high. '
Additional details justifying the use of GIP Method A may be found in the Senior Seismic Review and Advisory Panel (SSRAP) report (Reference 2). This report, included as Reference 5 in GIP-2, summarizes SSRAP's judgment on this subject:
.... the use of very conservative flooi esponse spectra should be avoided when assessing the seismic ruggedness of floor mounted equipment . .
Only for cases of equipment mounted more than 40 feet above grade or equipment with as-anchored frequencies less than about 8 Hz is it necessary to use floor spectra."
[Ref. 2, pages 102 and 103]
It is NYPA's position that FitzPatrick has properly interpreted and implemented the rules for use of GIP Method A as previously reviewed and accepted by the NRC.
The bases for this position are as folluws:
1.1 SQUG and FitzPatrick Interpretation of the GIP The caution given on page 4-16 of GIP-2 lists two limitations on the use of Method A:
I
. Equipment should be mounted in the nuclear plant below about 40 feet above the effective grade, and
. Equipment should have a fundamental natural frequency greater than about 8 Hz.
sA RAI 08SEP99 qj
y t
l L The introductory wording in GIP-2 for these two limitations provides the bases or j purposes for imposing them, namely (1) to limit amplification to no more than L about 1.5 and (2) to avoid the high-energy frequency range of the earthquake, namely below about 8 Hz. The specific limitations which are intended by the SQUG/NRC expert panel (SSRAP) and SQUG to satisfy these bases are included in the two bullet items listed above. Table 4-1 of GlP-2 which describes L the two methods (Method A and Method B) in detail, includes the criteria which l need to be met for each of the two methods. The table includes the above two i limitations, but does not include the requirement for checking the amplification
! between the in-structure response and the free field.
The str+sment on page 4-16 that "the amplification will not exceed about 1.5" is I
the expected result of meeting the above limitations, and not a third condition l which is required to be demonstrated.
The caution on page 4-16 of GIP-2 makes it clear that the advantage of Method Ais:
- l. "The advantage of using ground response comparisons is that with the applicable restrictions and limitations (i.e. the two bullet items listed l- above), all the equipment covered by the Bounding Spectrum or the i GERS can be evaluated for seismic adequacy without the need for using in-structure response spectra which are often based on very conservative modeling techniques or may not be available."
[Ref.1, page 4-16]
1.2 The Intent of the GIP l-
- The GIP cites the SSRAP report (Ref. 2) as the basis for the Bounding ,
Spectrum development and use in Method A (page 4-11, Ref. 2). The l SSRAP report explains the limitations and conditions which appear on page !
4-16 of the GlP. SSRAP's report states: !
- "Thus it is SSRAP's judgment that amplifications greater than a factor of I
1.5 are unlikely in stiff structures at elevations less than 40 feet above grade except possibly at the fundamental frequency of the building where i higher amplifications occur when such a frequency is less than about 6 Hz. Thus, for equipment with fundamental frequencies greater than about 8 Hz in the as-anchored condition it was judged that floor spectral
- amplifications within 40 feet of grade would be less than 1.5 when
! reasonably computed using more median centered approaches."
[Ref. 2, page 102]
. This judgment by the SSRAP was based on numerous studies and actual earthquake measurements which led them to conclude that:
r 1
I "Thus, amplification of the horizontal free-field ground spectra by factors greater thrn 1.5 are considered to be generally unlikely for elevations less t than 40 'eet above grade."
[Ref. 2, page 104]
The SSRAP was aware that many nuclear plants were originally licensed based on very conservative ISRS and that the use of conclusions based on earthquake experience and more median-centered approacros would be more appropriate. A detailed discussion of some of the souus of this conservatism is presented in item 5 below. With reference to this topic, the SSRAP report states:
"It was judged by SSRAP that the use of very conservative floor spectra should be avoided when assessing the seismic ruggedness of floor mounted equipment 't was also the opinion of SSRAP that many of the operating plants may cnly have these very conservatively computed floor spectra available. To avoid the burden of having to compute more realistic floor spectra, SSRAP decided to anchor its conclusions to ground !
spectra at the nuclear plant sites in those cases where this was judged to be reasonable."
[Ref. 2, page 102]
This was the basis for SSRAP's recommendation (and included in GlP-2 as 1 methods A and B) that: I "Thus, for the case of equipment with fundamental frequencies greater than about 8 Hz mounted less than 40 feet above grade, SSRAP's i conclusions are based upon comparing the bounding spectra with nuclear l power plant ground spectra. Only for the case of equipment mounted more than 40 feet above grade or equipment with as-anchored frequencies less than about 8 Hz is it necessary to use floor spectra." 1
[Ref. 2, page 102]
. l The SSRAP Chairman and developer of Method A, Dr. Robert Kennedy, was contacted by SQUG and concurs with the interpretation given in item 1 above.
- 2. Conservatisms Associated with Licensina Basis Calculated ISRS The following is a detailed description of the typical conservatisms normally i found in the analytical methods used for calculating in-structure response spectra (ISRS), at nuclear plants in general and at FitzPatrick in particular. This l information is provided in response to the July 8,1999, teleconference request l as additional evidence of the validity of Method A as originally developed by the SSRAP.
The process of calculating ISRS is a complicated analytical exercise requiring a significant number of approximations and modeling assumptions, and l
L . .
considerable engineering judgment. As a result, the historical development of ISRS has included a large amount of conservatism, which has typically served two purposes:
- 1. It has reduced the technical debate as to the correct modeling of the many
- parameters which are intrinsic to the ISRS calculation methodology, and
- 2. It has reduced the costs associated with a very detailed, state-of-the-art analysis, (which would attempt to trim out all the unnecessary conservatisms).
As a part of the A-46 program resolution methodology, the SSRAP had developed, and SQUG subsequently endorsed, an alternate ISRS estimation technique (referred to as Method A within GIP-2) which was much more median centered and realistic than the typical design practice. The application of Method A at FitzPatrick was appropriate and technically justified. The fact that design ISRS may show amplifications greater than 1.5 is not surprising, nor does it negate the validity of Method A. In fact, as noted in the SSRAP report it was even expected:
" Secondly, most unbroadened computed in-structure spectra have very narrow, highly amplified peaks at the resonant frequency of the structure, in most cases these narrow, highly amplified peaks are artificially broadened to account for uncertainty in the structure's natural frequency.
This process simply increases the emphasis on these highly amplified peaks.... SSRAP is also of the opinion that these narrow peaks will not be as highly amplified in real structures at high ground motion levels as is predicted by linear elastic mathematical models, nor are such narrow peaked in-structure spectra likely to be as damaging to equipment as is a broad frequency input which is represented by 1.5 times the Bounding Spectrum." [Ref. 2, pages 19 and 20.]
As described below, three areas are presented to support the application of Method A at U.S. nuclear plants in general, and at FitzPatrick in specific:
A. Measurements'of ISRS in actual earthquakes B. Calculations of overall conservatisms in typical ISRS C. Descriptions of the conservatisms in ISRS in general and FitzPatrick ISRS in particular 2.1 Measurements ofISRS in Actual Earthauakes SSRAP developed the Method A response estimation technique based on their research of both actual earthquake measurements and on recent SA M MsEPM j4
y ;
d
" median centered" analysis. They reference (Ref. 2, page 102) the measured
- floor response spectra at elevations less than 40 feet above grade for moderately stiff structures at the Pleasant Valley Pump Station, the Humboldt Bay Nuclear Power Plant and the Fukushima Nuclear Power Plant, where amplifications over the ground response spectra do not exceed 1.5 for frequencies above about 6 Hz. Other, more recent earthquake data from the Manzanillo Power Plant and SICARTSA Steel Mill in Mexico, as well as several facilities in California and Japan, have been reviewed by SQUG.
These data also show that stiff buildings (similar to typical nuclear structures) amplify very little at elevations less than 40 feet above grade and frequencies over 8 Hz. SQUG knows of no new measured data that challenge GlP l
Method A.
2.2 Calculations of Overall Conservatism in Tvolcal ISRS L
Calculated ISRS have never been portrayed as representing the realistic expected response during an actual earthquake. As previously stated, ISRS typically contain many conservatisms which make them unrealistically high.
The primary reason for the development of Method A was to establish a more median centered method of establishing the structural response without L having to embark on costly new analyses of all the site buildings. (It is noted that even the most modem, state-of-the-art ISRS contain significant conservatisms; even those classified as " median-centered" are often very conservative). NUREG/CR-1489, "Best Estimate Method vs Evaluation Method: A Comparison of Two Techniques in Evaluating Seismic Analysis
- and Design", stated that typical calculated ISRS contain factors of conservatism of 1.5 to 8. Recent surveys by SQUG show similar levels of conservatism in calculated ISRS. !
It was the contention of SSRAP that the ISRS for nuclear structures 4 i (considering the 40' and 8 Hz conditions) would be within about 1.5 times the l ground response spectrum (GRS) if the plant were subjected to an actual ;
earthquake. In deriving the Method A criteria they recognized that due to the variety of ground motions, soil characteristics and structure characteristics there could be occasional exceedances of the 1.5 amplification, but still j strongly justified Method A's applicability: ;
f "It is SSRAP's firm opinion that the issue of potential amplifications )
greater than 1.5 above about 8 Hz for high frequency input is of no consequence for the classes of equipment considered in this document except possibly for relay chatter'." l
~ [Ref. 2, Page 106)
-i Because of the SSRAP concern related to possible relay chatter at frequencies above 8 Hz, the SQUG methodology specifically addresses relays which are ;
sensitive to high frequency vibration. Such relays are included on the Low '
Ruggedness Relays list in Appendix E of EPRI Report NP-7148.
l
o i
1 L
L l
' The basis SSRAP gave for drawing this conclusion was that high frequency l ground motions do not have much damage potential due to low spectral displacement, low energy content, and short duration. They further noted that the equipment covered does not appear to have a significant sensitivity to high frequencies (except possibly for relay chatter, which is addressed
-7 separately in the GIP).
2.3 Descriotion of Conservatismo in ISRS in General and FitzPatrick ISRS i
in Particular .
The most significant sources of conservatism involved in the development of the ISRS for FitzPatrick include the following:
. Ground Motion incoherence l . Embedmont Effects
! . Frequency (structure modeling)
- . Structural Damping
. Time History Simulation l
~
.. Peak Broadening and Enveloping
. Clipping of Narrow Peaks 1
The degree of conservatism involved in each of these parameters is specific to the building being analyzed, to the floor level being considered, and, often,
, to the equipment location within the specified floor level. These conservatisms typically cannot be accurately quantified using simplistic l
calculation techniques since each parameter fits into an overall set of highly nonlinear equations. Thus, it would take a cor.siderable effort to quantify the exact excess conservatisms inherent in the calculated ISRS at FitzPatrick.
However, on a qualitative level, it is easy to see the origins and (svels of this conservatism. The following parameters are the source of the major portions of the excess conservatism:
' 2.3.1 Ground Motion incoherence ;
i l ' As has been documented in the EPRI seismic margin report (EPRI NP-6041) there can be a deamplification effect on nuclear type structures due to the l
. incoherence of ground motion.' Conservative reduction factors as a function ;
of frequency and building footprint have been documented within NP-6041 to l account for the statistical incoherence of the input wave motion. These !
conservative values range from a factor of 1.1 to around 1.5. More recent studies have documented even greater reduction factors. This ground motion incoherence is applicable to sites like FitzPatrick, and is particularly appropriate in the high frequency range.
4 2.3.2 Embedmont Effects The Reactor and Turbine buildings are deeply embedded structures at FitzPatrick. The structures are contained within an excavated rock pocket.
This rock pocket has vertical walls with a small annular gap between the exterior walls and the excavated rock which is backfilled with sand for drainage purposes. Effectively, this backfill has settled and is quite stiff. The resulting lateral stiffness represented by the 45' of surrounding rock is certainly significant. Since the rock is effectively rigid, it is not unreasonable to expect significant lateral stiffness and support of the buildings in question.
Lateral support of the lowest 45' of the buildings could decrease the ISRS at higher elevations by estimated range of 1.3 up to 2.
2.3.3 Structural Damoina Structural damping is one of the parameters of dynamic analysis to which the seismic analysis results are quite sensitive. It is a physical property of the different materials included in the dynamic model. Values used in current 1 analyses and licensing bases are controlled by Regulatory Guide 1.61 (R.G.
1.61). Values specified in R.G.1.61 have been shown by several studies to underestimate actual response of steel and concrete structures. Damping values recommended in NP-6041 (Ref. 6) are more realistic, and are suggested for use in median centered analyses. Damping values specified in FitzPatrick's licensing basis are compared to those in R.G.1.61 and NP-6041 i below: l Table 1 Structure or R.G. R. G. NP-6041 NP-6041 F
- Patrick FitzPatrick^ ^
Component 1.61 1.61 at About Ju t * :E . DBE OBE SSE 1/2 Yield Be w .L ense License i Yi . d B sis . Basis . j Welded Steel 2% 4% 3% 7% 1% 1%
l Bolted Steel l4% l7% l7% l10% l2% l3% l Reinforced 4% 7% 3-5% 10 % 2% 5%
Concrete As can be seen in Table 1, the damping values for both the OBE and DBE licensing basis at FitzPatrick are lower than the corresponding values allowed by the regulatory guide and NP-6041 for both steel and reinforced concrete structures. These two types of structures encompass the structures at FitzPatrick housing A-46 SSEL components.
2.3.4 Time History Simulation ISRS at FitzPatrick were generated using an acceleration time history. This was intended to approximate the licensing basis smooth ground response spectrum with a PGA of 0.15g for the modified Housner shape of the DBE.
sA RAI 08SEP99 j7
3 l
Figure 1 shows a plot of the 0.5% damped response spectrum from the time history and the FitzPatrick licensing basis ground response spectrum. The time history spectrum conservatively envelopes the licensing basis free field spectrum in the frequency range of 1 to 5 Hz. Above 5 Hz, the time history spectrum is close to the licensing basis free field spectrum. For each structure, the degree of conservatism in the ISRS depends on the structure's I response frequency.
The RB has its overall fundamental frequency between 5 and 6 Hz. The time history is seen to over-compute response between 5 and 6 Hz by a factor of about 1.3 to 1.5. This means the structural response, the resulting floor time histories and the ISRS are over-conservative by a factor of about the same ;
range,1.3-1.5, due to conservatism in the time history. The same factors are applicable to the Turbine Building Complex.
2.3.5 Ensk Broadenina and Envelopina i
The licensing basis spectra for FitzPatrick are artificially broadened at the i resonant frequencies. - The GlP recommends using realistic, median-centered, unbroadened ISRS. The broadening of the FitzPatrick licensing basis ISRS was conservatively done at *15%. The 5% damped ISRS for the i reactor building elevations 272',326', and 344' compared to 1,5 times the Bounding Spectrum (also referred to as the " reference spectrum") is shown in Figure 3 (see response to RAI question 4&5). While the reactor building elevation 272' exceeds the reference spectrum from about 11 Hz to 15 Hz, it i is important to note that the ISRS are broadened. An unbroadened floor spectral comparison would show this exceedance to be a narrow band exceedance, therefore, much less pronounced. If the original unbroadened spectra were compared to the free field spectrum, the apparent amplification at 12-13 Hz for the RB would be reduced (because the vertical line forming the high frequency side of the resonant range would shift to the left).
For the RB and TB, the effects of broadening and smoothing are judged to add a factor of conservatism of about 1.1 to the apparent amplification at 2 frequencies over 8Hz.
2.3.6 Clinoina of Narrow Peaks The SSRAP Report and the Generic implementation Procedure (GlP) i recommend procedures for adjusting narrow peaks to reflect two areas of l conservatism:
l 1. Narrow peaks are not as highly amplified in real structures as are predicted by linear elastic models.
sA M 06SEP90 jg i
j
L.
t
- 2. Narrow peaks in ISRS are not as damaging to equipment as are broad frequency input such as the Reference Spectrum.
The GIP recommends an averaging technique over a frequency range of 10%
of the peak frequency (e.g.,1 Hz range for a 10 Hz peak frequency) using the
.unbroadened ISRS. The FitzPatrick ISRS have narrow peaks and did not -
utilize the peak reduction methods of the GlP. The conservatism involved has l been shown to be in the range of 5% to 20% for typical narrow peaks at several plants. The maximum frequency dependent amplification with respect to the licensing basis ground spectrum is about 4.5 at the primary structural frequency above 8 Hz. For the RB and TB, the effects of narrow band peaks are judged to add a factor of conservatism of about 1.1 to the apparent amplification at frequencies ~over 8Hz.
2.3.7 Qy3rall Conservatism -
The total effect of all these conservatisms can result in significant overestimation of the amplification of the ISRS over the GRS for frequencies above 8 Hz. The following Table 2 summarizes the potential factors for each building discussed above. For the aforementioned effects for which a range is given, the mid-range value is used in the table below.
)
Table 2 Building RB TB GM Incoherence 1.3 1.3 Embedment Effects 1.5 1.5 Time History 1.4 1.4 Peak Broadening 1.1 1.1 Peak Clipping 1.1 1.1 Total 3.3 3.3 Reducing the ISRS by the above noted factor of conservatism (3,3) results in ISRS that are in the range of about 1.5 to 2 times the ground spectrum.
There are several additional sources of conservatism (e.g., structural modeling, structural / soil nonlinearities, etc.) which add to the overall '
conservatism in the calculation of ISRS. These additional conservatisms,
. coupled with those described above, reinforce the overall levels of conservatism in ISRS of between 1.5 and 8 which were referenced by SSRAP (LLNL Report NUREG/CR 1489).
2.3.8 OtherInformation Table 3 provides a comparison evaluation of overall seismic margins between median-centered and design basis analysis for nuclear power plant structures at various facilities. The information was developed by the Seismic p- sA M 08sEP99 jg
Qualification Utility Group, and was meant to demonstrate that factors of safety in original design basis analysis can be shown to be in the range of 2.5 to' 5. This table was also submitted to the NRC by another Region i nuclear plant.
The' data in the table are from five reinforced concrete shear wall structures at four different plants typical of those found at nuclear power plants. In the SER provided to the aforementioned Region I plant, the staff considered the five ratios of the conservative design spectra to median-centered spectra. !
Factors of conservatism are seen to range from 2.3 to 5.4. The mean of the ratios is 3.77.
The FitzPatrick reactor and turbine buildings are fundamentally reinforced concrete shear wall structures, for which the results of Table 3 are applicable.
The results of Table 3 are seen to be supportive of the qualitative assessment of factors of conservatism given above. Based on this factor (mean), the median-centered ISRS for FitzPatrick within 40 feet of grade would appear to be in the range of about 1.5 to 2 times the ground spectrum.
2.3.9 Conclusion Consideration of the above indicates that there are large factors of I conservatism in the FitzPatrick licensing basis ISRS. If these factors of conservatism are taken into account, thejudgment of the FitzPatrick USI A-46 SRT that the FitzPatrick structures are " typical nuclear plant" structures for which GIP Method A is applicable is seen to be reasonable. In other words, if realistic, median centered ISRS were to be calculated for the FitzPatrick reactor and turbine building complex for the elevations at which Method A j was used, the amplification of the ISRS over the free field GRS would not greatly exceed 1.5 and the seismic demand would be less than the seismic capacity of the equipment (i.e.,1.5 times Bounding Spectrum).
- 3. Not a Sianificant Safety issue The expected differences between calculated ISRS and actual building response do not represent a significant safety question. The lessons learned from review of hundreds of items of equipment at various sites that have experienced
- earthquakes which were significantly larger than those for Eastem U.S. nuclear plants are that missing anchorage, seismic interaction hazards, and certain equipment-specific weaknesses (incorporated into the GIP caveats) were the seismic vulnerabilities which cause equipment damage. These areas are conservatively addressed in the GIP. The NRC staff acknowledged the seismic ruggedness of nuclear power plant equipment in the backfit analysis for USl A-46 in which they stated the following:
B 4 V: e. . l L
\
. . .' subject to certain exceptions and caveats, the staff has concluded l that equipment installed in nuclear power plants is inherently rugged and l l' not susceptible to seismic damage." j
[Ref. 4, page 16] .
l Method A is only applicable to relatively stiff equipment with fundamental frequencies over about 8 Hz. As noted above, SSRAP and SQUG have agreed that excitations over 8 Hz have little damage potentie' due to low spectral displacements, low energy content and short duration. This judgment is supported by industry and NRC guidance for determining whether an Operating Basis Earthquake (OBE) is exceeded following a seismic event at a nuclear power plant. EPRI Report NP-5930 and NRC Regulatory Guide 1.166 recognize ,
that damage potential is significantly reduced for earthquake ground motions i above 10 Hz. In other words, the question of what is the precise value of building amplification over 8 Hz has very little safety significance.
I
- 4. Conclusions The discussion above leads to several conclusions:
. The results from actual measured ISRS on " nuclear type" structures support the 1.5 response levels advocated within Method A.
. ' Qualitative assessments of the conservatism inherent within the methods utilized to calculate ISRS have been provided above. These conservatisms are typically quite significant (as has been independently
- verified by median / modem assessments such as the LLNL study) and result in ISRS, which show amplifications well beyond the 1.5 factor from Method A. Specific exceedances noted for FitzPatrick (beyond the 1.5 factor) are due to the conservatisms inherent in the ISRS calculation methods, and do not invalidate the application of Method A.
l l
l 1
1 1
p i
Table 3 l Comparison of Design Basis to Median Centered i (Peak Spectral Response Comparison) l Design Basis Median Margin Plant Building Construction Estimated Comments Damping Analysis Peak S. Centered Design / Ground
, Frequency Peak S. Median Spectra j Auxiliary 5 Story, 3.8g 1.5g 0.12g A Building Reinforced 7-8 Hz Rock Site 2% 2.53 Reg Concrete Shear Guide Wall 1.60 0.12g B Reactor Reinforced 10-13 Hz Rock / Soil 5% 5.8g* 1.1g 5.3 Site Building Concrete Shear Specirc interior Wall Structure .
I 0.12g B Reactor Reinforced 4 Hz Rock /Soit 5% 2.2 g* 0.67g 3.3 Site Building Concrete Shear 12 Hz Specific Exterior Wall Shell l
0.75g I C' Contain Reinforced 10 Hz Rock Site 5% 10.7g 4.7g 2.3 Hosgri I ment Concrete Shear 1 Interior Wall I Structure l
0.1 D Auxiliary 8 l
Reinforced 10 Hz Rock / Soil 5% 1.4g 0.26g 5.4 Modified ,
i Building Concrete Shear Newmark Wall SSE defined as 2 x OBE for this Plant's Design Basis.
Equipment damping value applies both to design basis ISRS and median centered ISRS.
1 It should be noted that the reanalysis for the 0.75g Hosgri earthquake was done relatively recently, and had l cts inherent conservatism in the design basis response analysis than older plants. Thus, the margin of 2.3 (design peak / median peak)is judged to be on the lower side of the margins ;
1 i
expected for older plants.
2 Median Value was scaled to reflect the fact that the median ISRS were generated for a Regulatory Guide 1.60 shape (conservative), instead of the Plant D Design SSE.
l t
s I .
REFER,ENCES I
- 1. Seismic Qualification Utility Group (SQUG), " Generic implementation Procedure (GlP) For Seismic Verification of Nuclear Plant Equipment," Revision 2, Corrected 2/14/92.~
- 2. Senior Seismic Review and Advisory Panel (SSRAP),"Use of Seismic Experience and Test Data to Show Ruggedness of Equipment in Nuclear Power Plants,"
Revision 4.0, February 28,1991.
- 3. U.S. Nuclear Regulatory Comrnission, " Seismic Qualification of Equipment in Operating Nuclear Power Plants," NUREG-1030, February 1987.
- 4. U.S. Nuclear Regulatory Commission, " Regulatory Analysis for Resolution of Unresolved Safety issua A-46, Seismic Qualification of Equipment in Operating Plants," NUREG-1211, February 1987.
- 5. U.S. Nuclear Regulatory Commission, " Supplement No.1 to Generic Letter (GL) 87-02 That Transmits Supplemental Safety Evaluation Report No. 2 (SSER No.2) on SQUG Generic Implementation Procedure, Revision 2, As Corrected on February 14,1992 (GlP-2)," May 22,1992.
- 6. "A Methodology for Assessment of Nuclear Power Plant Seismic Margin (Revision
.1)," EPRI NP-6041-SL, Rev.1, August 1991.
I i
r . ,.. . . ...
-ATTACHMENTB Revised Screening Verification Data Sheets (SVDS), Pages 12 and 13
'l SA PW 06SP9e 24 .
- t. . . . .
DI NI p
.- 6 i7 o o s s s s s s o o s s s s s s s s s l 2 uK e e e e e e e e e e e e e e e f d y l l
/
qO N N Y Y Y Y Y Y N N Y Y Y Y Y Y Y Y Y o n t h
2 1
e g
E t
c a7 o o s s s s s se o o s s s s s s s s s s t.
n o c i
t s t
i b
a p
a e
% 'e f e a r K e e e e e e e e e e e e e e a i t a ta C
n O N N P t e Y Y Y Y Y Y N N Y Y Y Y Y Y Y Y Y r ew p D D D o ic i
- f. m f' e, '
h r
o?
cK A A A A A A A A se s e s e /A / A/ A / /A /A/ A! A A de nh ae is e
/
N
/
N
/
N
/
N
/
N
/
N
/ /
N N Y Y Y N N N N N N N N s b S l l l nO e A md en ht j
s t a t s f i
a7 s s s s s s s s s s s s s s s s s s s ye eK e e e e e e e e e e e e e e e e e e e sg d e
v Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y gd aO Y ine r
iu C dw i
q f ar o e r
>?d s s s s s s s s o o s s s s s s s s s gk n e pm e e e e e e e e e e e is e
Ye eY N N e e e e i- ti a r r u 6 e Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y sr uo r e
- t a
t a
CD e e '
n ng
. - - ef o n .
g i i d c S S S S S S n ig n S me R R R R R S RS R O S.RG5 S S S S S S SRS R S igts n R R$ (,A $CRGRGRGRGRGRG R R E e p G G G G G G GGG ne DS G G - Eb s n
y o
. t e pe .c S S C C he h it ap S B S
B S
B S
B S
B S
B B B O O' S S S S S S S S S B B B B B B B B B b t ao a
r e
CS D D pt a
p Cs, O 7 s s s s s s s s / s s s s s s s s s e e A A/
i r
0 e e e e e e e e e e e e e e e ic S o l l -
I 4 Y Y Y Y Y Y Y Y N N Y Y Y Y Y Y Y Y Y s
< mD m sV L
E 0 0
0 0
0 0
0 0
0 0
0 0
0 0 0 0 0 0 0
0 0 7 7 7 7 7 7 7 7 5 6 6 6 6 6 6 6 6 i
S eS t s
e M e
s 2 2 2 2 2 2 2 2 2 2 7 2 1 2 2 2 2 2 2 eh e y S ). E 6
a 7 7 7 7 7 7 7 7 7 7 2 4 4 4 4 4 4 4 4 ht e e 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 t f y e I oi n B 2 2 ora m V. m m a
T) t ess a a NS AD rl oC Y Y Y Y A A A A Y Y WAD A D A 0 A D d d di e en t r
ue a c @ N 7 N e
N e
LV m/w 5 $ 5 5 5 5 5 5
$ 5 1 2 2 5
3 3 2 3 3 3 ia v t n
gne p
y p
y PS( RR 3 3 3 3 on r
po isi t T T T RT c em r o
r o
r o
EE ne WE l
. 0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0 0 0 0
0 0 0 0 0 0 7 7 7 7 5 5 5 5 5 6 6 6 6 : t etne Oe t
n n S t n
n t
n n
OH E 2 2 2 2 2 2 2 2 2 2 7 7 7 7 7 2 2 2 2 na empm.
(
.d P TP P P S I F 7 7 7 7 7 7 7 7 7 7 2 2 2 2 2 4 4 4 4 dr s L RA 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 t r aout e ee AT cfnqa r ve EA Mie u on ri pg ehe eh cc t
LD g B B B B B B B B B B B B B B B B B B B r pn CN dl R R R R R R R R R R R R R R R R R R R CTt a AE UO B
un oio es r e ai r l I CC D OI f s ) t I I RF I
O O Q oul Tn e e t c R e TI R N N Q E sn eo Se te a
t a
t a
A E E E E B bc (h t D D D P L L ZV O O E E V V ed h n mu aa 8
T S S L L E E E E t e
E E o a I
T A A V V V V Tt h F.NG! V L
V L O T
O V V L L L L t, y r ww i
l l I AN A A L L D D A A A A ist n e SE V V I I V V V V ) e ie EE P P I O O I
L L L L S h ve er MC R R R M M N N O O O O Dc R g)
E E A A E E S S S S Va ar A
J S P P R R L L I I I I Se cd ee
-nl O O C C O O G G G G (
S S N N E E t e e s 6ogu in c D D S S IN N V V ed ehn he I I I s E I t P P Y Y L L L L Sse e V O O U U L L O O O O L L h lu E L N N P P A A Sc n e esla e D. V A E E K K P P R C O O O O V V ai h t n n r
u u I r q L V L L C C U U C C C Y Y t t t E A R O O A A S S E
T N N N N L L a
D "n ntoio s n a
n a
n
/ V S S B B T W E E P P o oan e s g ig g sy R E R R S S R R I W W W V U P P nt i
s s gf S i
S S i
S E P T T I
A A I
M O O O O V U e e r esrp io P O A I I A I R X D D D D LA LA S S t
a n e 4 /
R N IN T T O T T T T c nR 1 "
O R
I A
T U
T O U L
U L
N N R E E O T
A W U U U O H H H U V V G H L L N G
N sG.
r i )t r iAd g .e n
L L M M T L L S S S O O L I I e o E Rn Ts F S I
O C R M I L
Vg* An i
A P P R R U U A U T T T S S O O yS c e M A R R L M R C T I I r t R M M T T N T T U U D U C C C W W O O n .o h ib h e a h
A C A A N S S M C U U U C C ie nt e R O O H S S S S O O S S ea a p at t
S R R N NI U C e C C C C C H A B C D F L L U U er r u u a nb l l I S T I A F E S S C C V V C C P P P P N N R R ccq Co d Sce T L 9 9 IL IL O O C N S M M M M M O O s ad a c olu A A A t I E T 1 U E I M i wo L U 1
- - U G D U U U U T T id mt h N 2 2 A O AQ A B R O B P P P P A B A B ht nly ist s O 0- 0- E eays D E R R D E V V TA I
R R R R R R R R R n ala U U U U R otci c Se o r e C C YV YV I D
I D T H H H H H H H H H e e C C dem l
t t la aan I l L L N R R R R R R R R R ic m m H H H H HV HV S S W err is n oe f eg m
a v a a i
acs obi s s N i
ej N N k dr e e La pe U U U O U U t
nf.e sd el e o p C C C C A 8 A 8 C C 8 A B C 0 A 8 A 84 oeb r un y Dj Typ y H 0 0 ch H H) 9 51 51 -51 6-1 61 3- - eto uoO
- 69) H()
D ( ( H( ) 4 4 1
3 H) 1 n t a h .
a T r r T
I 21 21 79 79) 891 1 1 1 1
1 (9 (9 0 V V 25 -1 28 -1 1 - V V V V V V V V o b d n s s a ro e o r r o
V V it de iger M lt
- 1 - - 1 -
OO 1212TOOOOOOOO a tn t 1 t q 1 a nfi n n E
- 2 2 2 - 2 V0 V0 O O S 0 K 0 F M M M M M M M M nr: man Seir o nWn n 3 3S K V0 V0 S S s O O O S
O S
3 3 0 0 3T T3 0
1 0 0 0 0 1 1 1 1 1 1 1 1 0 0 0 0 ooevgr e (h d
- t u
,lc P P P A A 0 0 if t
3 3 3 0
3 0
0 0 caende eh ed n v eo 0 0 or c Mel t
r t h we t
pw r
8 oh p gd Ar ean
. l 8 8 8 8 8 8 8 8 eH n EqC 7 7 8 8 8 8 8 8 0 0 1 C A k (w l l l
u6
~
Ml p
i7 s s s s s s s s s s s s s s o s s s s s s s s s 4 6
2 uK e e e e e e e e e e e e e e N N o'e e e e e e e r f d y l l l EqO o n
/
3 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y YicYe Y t hs 1
g e
a t
c a7 rK s s s s s s s s s s s s s s s s s s s s s s s s s s e e e e e e e e e e e e e e e e e e e e e e e e e e sE n
ot ic tar e b
p a
a e
k f
/
te e e Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y r r C t
a d ta
. P eO eo D D t
r pc o , c p r ho7 A A A A s s s s s s s s s s s s s d e f m s
/
~
e e e e A A A A A A e e e e A A A e e e e e nh e i
cK N / / / / / / / / / / / / / ae S nO N N N Y Y Y Y N N N N N N Y Y Y Y N N N Y Y Y Y Y s b l l l A md e s en h t
s a t
t fi a7 s s s s s s s s s s s s s s s s s s s s s s s s s s ye eK v e e e e e e e e e e e e e e e e e e e e e e e e e e sg d e
aO Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y gd ir u
dnA C i q
>?d s s r ai c e r
s s s s s s s s s s s s o o s s s s s s s s s s grk e e e pm e e e e e e e e e e e e e e e e e e e e e e e e e is r r r a e Y Y Y Y Y Y Y Y Y Y Y Y Y Y N N Y Y Y Y Y Y Y Y Y Y r r r u u u CD 6 s su r o e t a
t a
e e n n n u E. n dc mp e
e S S S S S S S S S S S S S S S S S S S S S S S S S S R R R R R R R R R R R R R R G C R R R R R R R R R R ef no i
gt s E ig n 7g I S
q DS G G G G G G G G G G G G G G G C C C C C C G G G G G n e Ey b s n \
/
o p.c e S S S S S S S S S S S S S C C S S S S S t e i a p S h h B B B S S S S S i t B B B B B B B B B B B B B B O O B B b t a D D A A A A A B B B B B r
CS ao pt e
p a O 1
~ s s s s s s s s s s s s s s A A A A A A A s s s s s Cs, 0 e e e e e e e e e e e e e e / / / / / / / e e e e e c Si r
o l l I 4
< Y Y Y Y Y Y Y Y Y Y Y Y Y Y N N N N N N N Y Y Y Y Y imD s m
(
L sV i 7 E 7 7 7 7 0 0 0 6 6 6 6 5 5 5 0 0 0 0 0 5 5 5 5 5 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 7 0 0 0 6 0 0
0 7
6 6 7
S eS t s
e /
e s 2 2 2 2 7 7 7 4 4 4 4 2 2 2 7
2 7
2 7
2 7
2 7
2 2 2 6 6 6 6 7 7 2 2 2 2 2 6 6 6 2 0 2 2 4 0 0
0 2 2 eh e
S) y 8 a 4 4 ht mN B 2 2 2 2 2 2 2 2 2 2 2 2 2 2 3 3 3 3 3 3 3 2 3 3 2 2 t f y e e e oi n ora m m T) t es a a a NS d d r s AD rl oC A D P 0 A D A D A D A 0 R W R R P P P P R R W A. 5 Y R A ee di n ue h N e
N N Me t
LV m/w a c e PS( RR 3 3 2 2 3 3 3 3 2 2 2 2 1 1 6 6 6 6 6 6 3 4 3 5 1 4 iat v ne gn p p p 5 o r n y T
y T
y RT po c isi t r r r EE n em o o o WE L 7 7 6 6 6 6 7 7 0 0 0 0 0 0 0 0 5 5 5 5 5 5 5 7 7 5 5 5 6 6 7 7 7 5
7 5 5 0 7 0 0 7 7 ot n Oe n e t n fI tn t n
OH E 5 7 7 5 6 0 0 6 6 na e
- it n n n PS RA F I 2 4
2 2 2 4 4 4 2 2 2 2 7
2 2
7 2
2 7
2 2
7 2
2 7
2 2 2 7
2 7
2 2 2 7
2 2 2 6 6 6 4 4 2 2 2 2 2 3 3 3 6 6 6 4 2 0 2 2 2 1 4 0 3 3 3 3 2 3 0 2 2 0
3 4
2 2 4 ompm.
i t r
(
d
- s d r % P YL P d P
AT aoieut ee ve EA . fcfinqa er on LD d g
B B B B B B B B B B B B B B B B B B B B B B B B B B t i
r e u r i pg CN B a
R R R R R R R R R R R R R R R R R R R R R R R R R R eh e c CTt ha pn AE
~ UO NI T r l l I KA un oio es r e ai r CC I I f s )t RF ou Tn TI E E t lc Re e e AR V V se no Se t ht a
t a
P E L L bc (h D O D
' Z V E E E E A A V V ed ml t
l T V V V V h n aa FG I
N L L A A A A L L E E V V t
o a e T ht AN I
V V V V I S S I
K K t, ry ww i
l l I F st SE F F F E E E E O O C C in e e EE I L
I I L
t L
L L P P A A ) e S h v e er MC R E E E L
E X X R R Dc Rg)
A are J S R R R R E E MM E E Va Se ede T T T T R R T T (
ml C C C C A A t s uin c
s U U U U E E S S Y Y ee ed is og eh n e E E S S S S H H S S h lu Sse D S S P P E E Sc E
q V
L L A A V V V E E V
L L V
A B C D P P P P M MMM GGG G N
I L L NI N N I
L I
L D D M M V E E U U A A L A S VEKS L L V C S SS S
tai a
n n
e sla hie t r nt oio n
s
& e r
t a
u t e
r u
a A A P PVVARN A A T T n fs U U U U OOO O A B Y Y V MD N D "o oa s g n
g r gfn e y L L V K O O S SV P P P P OOO i
S OEEVV L L T T L D nt oa s C C C C 5 S S S S S S AL AL LA LA C V LV T TI O O E E O E I
N N A A i m tar eio sr I I G G PA PA O V' V V OOO N N N W W W N A W
L A C C R R F F S T V V A A T T A A I S A
YN O N R
T fcfo e l p inl gad W NNY Y ni)n t. n .e OOO O Y Y B i 8 NONOSHSH D B SO S e Ano E Ts IL L B B M I
MMM D D D D T T Y T TI I
N R n V
1 O O A B R R ER ER E E T T T T T u 0 E O 0 C C C C UACC I
g* ySRe e U U U U E r
OO D DSSORE E A n .o t h h C C CH CH T H H H H F F S S K i T T T A A I I I I P T T intee b he a A A A A S S S S S S E U UD D Y O C 8 L SO at LE Q O A L ea t a SSXXE E E E A B C O A B B L R R A E eru u r
p a nb e
U RU E E H H H H R P P P P P P U B L L 2 I l 2 PP E R P P R N ccq Cod l l 1 U P N Y P Sce T T L L L L O OAAA A A A MM M MO OO O Y U O R R TS ao e olu mtwo B B M M S O A s s T T E E U U U U U U U UOO D D D U U CO T T N H tr d h B D h nly A S H H D D D D P P P P L L A N N P P U A C C I C st s s R R R R S S S S I I I I R R R R R R C C A A C C C A A C I
R n ot c a la t eay r H H H H E E E E H H H H H H L L L W H E E P H Se e e R R R R R R R R R R R R R R S L T T S S S S S R C R R H R derci em ha taa l to e m e
r s m m in oe i
f egn a v a a acs obi s is N ei N N t k e dr e e A 8 A B A 8 C D A 8 A B A 8 81 nf,e oeb sde el r un L a p o p p 9 9 6 6 ch uoO y
Dj Ty y D 3 6- 6 A B C D 1 4-1 1 1 4 4 3 5 5 4 4 A B 2 9 9 -
V 0- 05 06-1 0 9 n eto t ah a
r T T V V V V- 3- 3 3 3 3-1 1 2 r r I
P P P V V- V V V V V V P P V V O
- 5- 5 ob d i n s s a r o e lt o r
o q OOOOP 5 5 5 5 5 r
ta d nfe gen M M M M M 1 01 01 0 0R 0R R R S S E E 0 S S M t a n t t E
0 0 0 0 1 0 0 0 0 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2
- nrmane i r Sei
( h o
s n
nW n n
n 1 1 1 1 1 1 1 1 1 1 1 1 1 ooev t u P P P n gr d t
i f ,lc
- aid c eleht e edn veo f
ti h we o r ric q 8 5 8 8 6 6 6 6 7 7 7 7 7 7 0 0 5 5 7 7 8 8 8 8 8 8 r t oh puqd p
EC 1 1 1 1 1 C el n l A k (w Ar ean l l l t
( lllt ' L