ML042370019

Resolution of Generic Letter 96-06 Waterhammer Issues - Revised Response

ML042370019
Person / Time
Site:	Palisades
Issue date:	08/18/2004
From:	Domonique Malone Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-96-006, TAC M96844
Download: ML042370019 (15)

Text

-i Committed to Nuclear Excellence Palisades Nuclear Plant Operated by Nuclear Management Company, LLC August 18, 2004 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Docket 50-255 License No. DPR-20 Resolution of Generic Letter 96-06 Waterhammer Issues - Revised Response (TAC NO.M96844)

By letter dated February 28, 2003, Nuclear Management Company, LLC (NMC) provided the subject response. NMC has subsequently performed additional waterhammer analyses using an alternative method. The enclosed response supercedes any previous responses to the requested items pertaining to the waterhammer issue. The response to the requested items pertaining to the two-phase flow issue contained in the February 28, 2003, letter (and subsequent letter dated July 24, 2003) is unaffected by this revision.

Summary of Commitments This "Ir completes all remaining commitments associated with Generic Letter 96-06.

Daniel J. Malone Site Vice President, Palisades Nuclear Plant Nuclear Management Company, LLC Enclosure (1)

CC Administrator, Region IIl, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC 27780 Blue Star Memorial Highway

• Covert, Michigan 49043-9530 Telephone: 269.764.2000

,-0

ENCLOSURE I RESOLUTION OF GENERIC LETTER (GL) 96-06 WATERHAMMER ISSUES REVISED RESPONSE REQUESTED ACTIONS TO ADDRESS GL 96-06 Requested Item Licensees who choose to use the methodology in TR-1 13594, ["Resolution of Generic Letter 96-06 Waterhammer Issues,'7 Volumes 1 and 2, for addressing the GL 96-06 waterhammer issue, may do so by supplementing their response to include:

• Certification that the [Electric Power Research Institute] EPRI methodology, including clarifications, was properly applied, and that plant-specific risk considerations are consistent with the risk perspective that was provided in the EPRI letter dated February 1, 2002. If the uncushioned velocity and pressure are more than 40 percent greater than the cushioned values, also certify that the pipe failure probability assumption remains bounding. Any questions that were asked previously by the staff with respect to the GL 96-06 waterhammer issue should be disregarded.

Response

Nuclear Management Company, LLC (NMC) has implemented the EPRI methodology of TR-1 13594 as characterized in TR-1 003098 "Technical Basis Report" and TR-1 006456 "User's Manual" - References 1 and 2, respectively. The results of the analysis performed by Sargent & Lundy for NMC concludes that plant-specific risk considerations are consistent with the EPRI risk considerations identified in References 1 and 2. NMC has reviewed the results of this analysis. In addition, the uncushioned peak pressure and velocity associated with the column closure waterhammer (CCWH) pressure pulse is within 40% of the cushioned peak pressure and velocity. Since the 40 percent criterion is met, the failure probability used in the EPRI risk perspective applies to the Palisades Nuclear Plant.

Requested Item

• A brief summary of the results and conclusions that were reached with respect to the waterhammer issues, including problems that were identified along with corrective actions that were taken. If corrective actions are planned but have not been completed, confirm that the affected systems remain operable and provide the schedule for completing any remaining corrective actions.

Page 1 of 7

Response

Background By letter dated February 28, 2003, NMC reported the results of its investigation of the potential impact of a Generic Letter 96-06 waterhammer employing the EPRI methodology of References 1 and 2 for the Palisades Nuclear Plant. The waterhammer load scenario involves a concurrent loss of offsite power and loss-of-coolant accident or main steam line break in the Palisades open loop service water system (SWS). This may result in containment air cooler boiling due to a loss of system pressure and higher containment temperature followed by a service water pump restart and closure of a water/steam void between two water columns. Simplified engineering analyses were conducted to characterize a bounding waterhammer event. The calculated pipe segment loads were used as input to piping system models in order to determine the effect on the structural integrity of the system components.

The calculated SWS line refill rate was maximized by assuming the inlet valve associated with the non-safety related containment air cooler, VHX-4, fails to close. It was determined that the column closure waterhammer (CCWH) loading in the system bounded the condensate induced waterhammer (CIWH). A CCWH with an impact velocity of 16 feet per sec (ftlsec), a duration of 107 milliseconds, and a pressure pulse magnitude of 435 psi was determined to be bounding. The input of that pulse into the SWS piping model resulted in many instances of calculated piping system overstress and support overload with respect to the Palisades Final Safety Analysis Report (FSAR) faulted loading combination acceptance criteria.

In reporting the results of the assessment, NMC concluded that the system was operable with respect to the postulated loading. However, more work was required in terms of analysis and/or modification to demonstrate FSAR compliance.

Waterhammer Loading/Model Development The simplified nature of the analysis reviewed above suggested that analytical refinements might be appropriate, to remove conservatism from the calculated void closing velocity (differential velocity of the two water columns prior to impact). The computer software program HYTRAN was employed due to its ability to analyze the growth and collapse of a discrete steam and air cavity (void) model using the method of characteristics as described by the EPRI User's Manual and Technical Basis Report. In its guidance, the EPRI Technical Basis Report maintained that the method of characteristics provides a means of accurately simulating all aspects of pump startup in a system with vapor pockets of steam and non-condensable gases and that the method of characteristics adequately predicts peak pressures and rise times for CCWH events. HYTRAN employs a fixed-grid method of characteristics solution approach to calculate piping system pressures and flow velocities that are used to determine time-varying forces in the piping system.

Page 2 of 7

The fundamental assumptions employed in the cavity model are consistent with EPRI guidance and include:

• The mass and temperature of the steam in the cavity at the start of the compression phase are saturated steam at cavity pressure.

• Air release during boiling to be included in cavity contents is 50% of the air in the water in the tubes exposed to temperatures that are at least 1 0F above the saturation point, and 24% of air in the containment air cooler headers and attached piping provided the steam passes through them.

• Condensing surface area is the sum of the pipe cross sectional areas at the two ends of the bubble.

• Condensing surface temperature is equal to the initial void temperature. It remains constant, as does the heat transfer coefficient.

• Free air in the water up and downstream of the void is not given credit for reducing the sonic velocity.

• Free air mass is lumped in the void.

The initial boundary conditions for the HYTRAN models were based on steady state flow results from tests performed at Palisades. Heat transfer analyses for the containment air coolers were used to determine void saturation pressures during the expansion phase of the CCWH event. The methodologies employed were standard formulations utilized within commercial and nuclear industries for many years and are considered applicable to the case-in-point. Assumptions within the heat transfer modeling were selected to conservatively determine the time-to-boil.

HYTRAN used results from the heat transfer analyses as void (cavity) pressures prior to void compression. Using the EPRI methodology, the void pressure time history, along with estimates of dissolved air released into the void during boiling, are input to HYTRAN to characterize boundary conditions at the discrete cavity node prior to the initiation of void closure.

The HYTRAN method of characteristics approach was validated using the EPRI Rigid Body Method approach by comparing the Rigid Body Method pressure pulse magnitude and shape at the void location, as well as resulting pipe segment loads, with HYTRAN results. As shown in Attachment 2, the correlation between Rigid Body Method and method of characteristics results is good, although the HYTRAN/Method of Characteristics pipe segment loads are generally higher. This is because loads are extracted at two different times in the CCWH analyses (time of two pumps starting simultaneously and time of void closure). Because of Palisades' relatively high maximum void pressure (approximately 48 psia), the waterhammer loads at pump start are generally higher than at void closure.

In addition to determining CCWH loads, a HYTRAN model was also developed to determine waterhammer loads from direct impact of the pump water column acting on the containment return throttle valve. A flow resistance orifice model was made of the valve to simulate the system response to direct impact. This loading condition was Page 3 of 7

considered because of the large calculated void size. Thus, two HYTRAN simulations were considered for the CCWH event (void closure and direct impact). The SWS was evaluated for both HYTRAN simulations, and shown to be acceptable.

Condensate Induced Waterhammer (CIWH)

The heat transfer coefficient used in the CCWH analysis is an order of magnitude higher than that recommended by EPRI. This increases steam condensation in the void during closure and, therefore, reduces void pressure. This is conservative since it increases the differential closing velocity of the void. The higher coefficient was used to prevent the void pressure from increasing during void closure. The use of a 20 psig (35 psia) steam cavity pressure with the EPRI recommended heat transfer coefficient would yield loads very similar to those resulting from the CCWH analysis described above. Per EPRI, the CIWH loads from steam pressures at 20 psig would be bounded by the CCWH loads. Since CIWH loads are proportional to the square root of the the steam pressure minus the water saturation pressure, CIWH loads from steam pressures of 33 psig (48 psia) could be as much as 17 percent higher than those from steam pressures of 20 psig (35 psia). However, the Palisades direct impact loads are approximately 3 times higher than the CCWH loads. Therefore, CIWH loads are bounded by the direct impact loads.

HYTRAN/Method of Characteristics Validation:

The EPRI Rigid Body Method approach is a simplified, standard approach approved by the Nuclear Regulatory Commission (NRC). As such, it can be compared to other methods of calculating waterhammer loads. The intent of comparing loads/pressures from the EPRI Rigid Body Method approach with HYTRAN, is to demonstrate that the HYTRAN results are reasonable and can be used as input to qualify the subject piping for waterhammer loading resulting from a postulated GL 96-06 event.

The EPRI Rigid Body Method approach described in the Technical Basis Report and User's Manual is used to calculate the peak pressure, rise time and duration of a pressure pulse, and the associated maximum pipe segment loads, resulting from a worst case CCWH GL 96-06 scenario.

In the following Rigid Body Method calculation, the maximum differential velocity of the two water columns from an uncushioned HYTRAN analysis is equated to Vinitial in the Rigid Body Method approach delineated in the EPRI User's Manual. The uncushioned HYTRAN analysis does not include the effect of either steam or air cushioning.

However, the steam pressure in the cavity corresponding to the flashing point of the hot water is considered, and the downstream water column velocity prior to column closure results from this pressure.

The cavity closure point is located in the 16-inch containment return pipe at the high point of the SWS just outboard of the containment penetration. From an uncushioned HYTRAN analysis, the maximum differential velocity of the two water columns in the Page 4 of 7

16-inch diameter pipe is approximately 4 ft/sec (Vini1tal). The requirement that the differential water column velocities be less than 30 ft/sec is met, which allows use of the nomographs in the EPRI User's Manual.

The total amount of air from the four containment air coolers that can be credited for cushioning the GL 96-06 CCWH event is 14.3 grams of air compared to a minimum of 3.8 grams of air needed in a 16-inch diameter pipe in order to apply the Rigid Body Method. Note that the HYTRAN analysis credited only 5.0 grams of air in order to provide a calculation margin.

For the purposes of this Rigid Body Method comparison, 5.0 grams of air will also be credited. In the User's Manual, Lwo is the length of the accelerating water column in the containment supply piping. Since Lwo is approximately 200-feet, and steam cushioning is not credited, the Figure A-22 nomograph for 16-inch pipe with velocities less than 10 ft/sec, with K = 40, is used to obtain Vcushlon/Vinitial = 0.91. Therefore, V cushion =

3.64 ft/sec. The water sound speed is taken as 4000 ft/sec.

Peak pressure = 'A p C V cushi n 1/2 (1.93 sugs/)

• (4000 ftlsec)*( 3.6 4 fIsec) / (144in2/fte)

= 97.6 psi Pressure rise time = 93 milliseconds, using Equation 9 -11 of the User's Manual The Rigid Body Method pressure pulse would generally be calculated as a trapezoid with a peak pressure of 97 psi having a linear rise time of 93 milliseconds, a dwell time of 30 milliseconds, and a linear decay time of 93 milliseconds.

For cases where the pressure rise time is relatively long and the duration relatively short, the User's Manual states that the pressure pulse becomes triangular in shape, with an area equal to the product of the peak pressure and pulse duration. This is the case for Palisades. Therefore, the pressure pulse for Palisades is a triangle with a peak pressure of 55 psi and a rise time of approximately 53 milliseconds.

The method for calculating pipe segment forces provided in Figure 6-4 and associated text of the User's Manual is used to calculate the maximum leg forces. At tees, transmission factors using the methodology of the User's Manual are applied. These transmission factors, where applied, are tabulated in Attachment 2. HYTRAN leg forces are calculated at the time of column closure and at the time of pump start. The maximum of these two waterhammer loads is used in the HYTRAN/Rigid Body Method load comparison table.

The Rigid Body Method equations and input described above are provided in. The information provided is taken directly from analyses performed and is in MATHCAD format.

Page 5 of 7

The Rigid Body Method to HYTRAN/Method of Characteristics peak pressure and shape given in Attachment 2 show good agreement. Attachment 3 is the HYTRAN noding diagram indicating the node and leg names. The Rigid Body Method and HYTRAN/Method of Characteristics maximum leg forces also correlate well (Attachment 2), although the HYTRAN/Method of Characteristics loads are almost always higher than the Rigid Body Method loads. This is because the pump start and direct impact loads calculated by HYTRAN are higher than the column closure loads.

The pressure pulse and pipe segment correlations validate the acceptability of the GL 96-06 calculated waterhammer loads.

The use of HYTRAN as described above to demonstrate acceptability of the GL 96-06 waterhammer loads is consistent with the approach used by the St. Lucie Nuclear Plant submittal dated September 29, 2003. The NRC Staff issued a safety evaluation on this approach by letter dated March 11, 2004 (Reference 3).

System Structural Response A piping system model was constructed for the SWS that incorporated the piping that would be most affected by the water hammer loads. The CCWH piping analysis and support load summaries from the earlier analysis offered guidance in the development of a single system model from the models used in the past. Force time histories were input into the PIPSYS software application from the HYTRAN results. Pipe stresses were calculated directly from PIPSYS in the post processor routine. Pipe support loads were generated as well and compared with the safe shutdown earthquake loads calculated for the system.

The waterhammer loads for most of the supports are bounded by the safe shutdown earthquake loads. For a few supports, the waterhammer loading exceeds the safe shutdown earthquake loads. For these cases, a specific evaluation of the support calculation was performed to establish acceptability. All supports were found to be acceptable.

The piping system assessment was conducted for both direct impact loading on CV-0824 (containment air cooler SWS return valve) and for void closure loading. The direct impact loading was the limiting loading case of the two. In each case, pipe and support results meet the FSAR allowables.

Conclusion Correlation of the shape and magnitude of the Rigid Body Method to HYTRAN/Method of Characteristics pressure pulse at the point of water column closure is acceptable.

Correlation of the Rigid Body Method to method of characteristics maximum pipe segment loads is good. Therefore, the GL 96-06 loads calculated by HYTRAN are suitable for qualifying the SWS.

Page 6 of 7

The GL 96-06 CCWH analyses described in this summary comply with the EPRI method of characteristics methodology, including clarifications. The cushioned velocity employed in the assessment is within 40% of the uncushioned velocity. In addition, it is concluded that the CIWH loading is bounded by the CCWH event. The pipe support loadings and pipe stresses are within FSAR acceptance criteria.

Based on the acceptable results of the refined waterhammer analyses described above, physical modifications to the SWS are not required.

References

1. EPRI Technical Report 1003098, "Generic Letter 96-06 Waterhammer Issues Resolution; Technical Basis Report," April 2002

2. EPRI Technical Report 1006456, "Generic Letter 96-06 Waterhammer Issues Resolution; User's Manual," April 2002

3. Letter from Brendan T. Maroney, USNRC to J. A. Stall, Florida Power & Light,

'Closeout of Responses to Generic Letter 96-06 Concerning Waterhammer and Two-Phase Flow for St. Lucie, Units 1 and 2 (TAC No. M96870, M96871)," dated March 11, 2004 Page 7 of 7

ATTACHMENT 1 RIGID BODY METHOD EQUATIONS (IN MATHCAD FORMAT) 2 Pages Follow

Void Closure Differential Velocity V := 4.0 f V

sec Per Reference 2, Figure A-22, "Generic Letter 96-06 Waterhammer Issues Resolution" User Manual, the VcushionNinitial ratio for 16" diameter pipe with 5 grams of air, an initial velocity less than 10 fps, Lwo < 200 ft and Lao < 100 ft is given as approximately 0.91, where credit is only taken for a gas cushion. Credit is not taken for steam cushioning.

x:=0.91 V x:=VC-x Rise Time and Duration for Pressure Pulse t rise := 0.5-sec 1

t rise = 0093 s sec c :=4000f L:=60-ft sec t d =" --- t rise td0.123 s C

t dO 1 3

p:= 1.93 slug fly3 dP:=--p-c-Vcx 2

dP = 97.572Žpsi The L selected above is the distance from the column closure location to the 24" return header.

Although this distance results in a T.F. of 0.3, rather than 0.1, it is judged to be the most appropriate distance to develop a best estimate RBM pressure pulse. Section 5.3.3 of the User's Manual states that for a relatively long rise time and short duration, a triangular pressure pulse will be created with an area equivalent to the product of the peak pressure and 2*L/c.

The Palisades CCWH case has a long rise time with a short duration, so the RBM pressure pulse will be developed by generating a triangle with the rise time slope calculated below, rising to a maximum pressure that provides the equivalent area described above. As shown below, the maximum peak pressure of the triangle is approximately 55 psi.

L

_dP A :=dP.2^-

s :=-

s = 1.047.1&'-.@

c t rise sec A = 2.927opsi *sec PrRisTime PrRiseTime= 0.053 s PeakPressure :=s *PrRiseTime PeakPressure =55.35 psi

Transmission of Pressure Pulse from Point of Origin From the void closure location to the 16"x12"x12" tee, the transmission factor is taken to be 1.0. The leg forces are caused by differential pressure as the wave proceeds through the system. The leg force is then defined as follows, where:

Li = individual leg length, and A leg = leg flow area F

(Li/(c*tnse))*dP*(A leg)'I where X is a pressure pulse transmission factor at area changes, as shown below Transmission of Pressure Pulse through 16"x12"x12" Tee A16:=1.27 A12:=.785 12-=

2-A16 c12=0.894 A16+A12+A121 8

dP = Pressure upstream of the tee = 97*.9 = 87 psi Transmission of Pressure Pulse through 12" x 10"x 8" Tee A8:=.347 A12:=.785 AIO:=.548 2-A12.' 12 1 0 A8+A10 AI2 1o=0.836 dP = Pressure upstream of the tee = 97* X 10 = 81 psi This pressure is used in both the 10" and 8" piping Transmission of Pressure Pulse through 10"x6"x6" Tee A6:=.4 A10:=.548 2-A10-io

'E 6:

AIOI-A6+A6 6=0.68 dP = Pressure upstream of the tee = 97* c 6 = 66 psi This pressure is used in both the 6" and 4" piping

ATTACHMENT 2 COMPARISON OF RIGID BODY METHOD RESULTS WITH HYTRAN The following Load Comparison Table compares the Rigid Body Method (RBM) to HYTRAN/method of characteristics maximum leg forces for both column closure (the highest load at column closure or pump start) and direct impact. The leg forces displayed represent the structurally significant legs of the containment air cooler return system. These pages are followed by a Rigid Body Method to HYTRAN/method of characteristics (MOC) comparison of the pressure time history at the cavity closure point.

Leg Pipe Pipe Name Area Length (sq ft)

(feet) 214 1.268 3.67 213 1.268 3.33 212 1.268 13.40 211 1.268 3.71 209 1.268 22.25 208 1.268 7.67 207 1.268 7.17 204 1.268 12.58 203 1.268 19.21 202 1.268 2.53 200 0.785 5.36 199 0.785 6.24 196 0.347 3.42 192 0.347 7.25 191 0.4 5.18 190 0.4 7.00 189 0.4 1.15 188 0.4 1.50 187 0.4 1.03 173 0.548 7.99 172 0.548 14.23 170 0.548 7.84 169 0.548 3.44 167 0.548 6.23 166 0.548 14.23 165 0.548 13.83 164 0.548 4.75 163 0.548 14.17 162 0.548 18.82 161 0.548 7.19 141 0.785 8.87 140 0.785 4.06 136 0.347 4.04 135 0.347 3.44 134 0.548 3.46 133 0.548 1.77 132 0.548 7.50 From To Node Node CD12 CD13 CD11 CD12 CD10 CD11 CD9 CD10 CD7 CD9 CD6 CD7 CD5 CD6 CD2 CD5 CDI CD2 V13D3 CD1 V24D1 V13D3 V4D15 V24D1 V2D10 V4D15 V2D6 V2D10 V2D5 V2D6 V2D4 V2D5 V2D3 V2D4 V2D2 V2D3 V2D1 V2D2 V4D13 V4D15 V4D12 V4D13 V4D10 V4D12 V4D9 V4D10 V4D7 V4D9 V4D6 V4D7 V4D5 V4D6 V4D4 V4D5 V4D3 V4D4 V4D2 V4D3 V4D1 V4D2 V13D1 V13D3 V3D23 V13DI VID16 V3D23 VID15 V1D16 VID14 V1D15 VID13 V1D14 VID12 VID13 RBM HYTRAN RBM HYTRAN Trans Orifice Orifice CCWH CCWH Fac Or596064 N.A.

N.A.

862 239 1432 493 461 810 1236 163 192 224 51 107 71 96 16 21 15 187 332 183 80 146 332 323 111 331 440 168 318 146 60 51 81 41 175 N.A.

N.A.

772 257 1544 515 515 854 1531 317 151 306 84 163 80 158 81 81 81 186 371 186 93 186 371 279 93 371 472 203 338 170 84 83 81 81 148 186 169 681 189 1131 390 364 640 977 129 152 177 40 85 57 76 13 16 11 147 263 145 63 115 263 255 88 261 347 133 251 115 47 40 64 33 138

>P5960603 or P5960604 529 478 1234 503 2035 770 772 1268 2078 431 278 519 132 247 128 231 124 124 131 351 636 310 151 288 534 352 119 358 356 156 556 268 138 144 143 143 273 I

1 1

1 1

1 I

I I

0.9 0.9 0.84 0.84 0.68 0.68 0.68 0.68 0.68 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.90 0.90 0.84 0.84 0.84 0.84 0.84 Page 1 of 3

Leg Pipe Pipe From To Name Area Length Node Node (sq ft)

(feet) 131 0.548 3.42 ViD11 V1DI2 130 0.4 2.89 VIDIO VID11 129 0.4 3.89 VID9 VID1O 128 0.4 1.58 VID8 VID9 125 0.4 8.07 VID5 VID8 124 0.4 1.50 VID4 VID5 123 0.4 2.25 V1D3 V1D4 122 0.4 3.00 VID2 VID3 99 0.548 10.08 V3D21 V3D23 98 0.548 14.83 V3D20 V3D21 97 0.548 7.10 V3D19 V3D20 96 0.548 3.42 V3D18 V3D19 95 0.548 6.33 V3D17 V3D18 94 0.548 15.00 V3D16 V3D17 92 0.548 13.17 V3D14 V3D16 91 0.548 4.75 V3D13 V3D14 90 0.548 14.08 V3D12 V3D13 88 0.548 18.02 V3D10 V3D12 87 0.548 1.92 V3D9 V3D1O 86 0.548 5.19 V3D8 V3D9 85 0.548 13.98 V3D7 V3D8 84 0.548 6.56 V3D6 V3D7 83 0.548 5.75 V3D5 V3D6 82 0.548 1.00 V3D4 V3D5 81 0.548 1.79 V3D3 V3D4 80 0.548 2.50 V3D2 V3D3 79 0.548 1.47 V3D1 V3D2 RBM HYTRAN RBM HYTRAN Trans Orifice Orifice CCWH CCWH Fac Or596064 80 40 53 22 112 21 31 41 235 347 166 80 148 350 308 111 329 421 45 121 327 153 134 23 42 58 34 85 86 87 88 179 90 88 86 276 364 186 93 186 364 276 93 364 453 93 93 292 198 98 94 93 97 101 63 32 42 17 88 16 24 32 186 274 131 63-117 277 243 88 260 333 35 96 258 121 106 18 33 46 27

>P5960603 or P5960604 142 134 134 129 261 119 121 121 561 687 329 168 326 597 403 132 451 489 96 114 289 183 110 88 109 87 106 0.84 0.68 0.68 0.68 0.68 0.68 0.68 0.68 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 0.84 Page 2 of 3

R1UEI NDCW sFR3MPessu PRse 70 rsu B

Rise 3

Lb CD (1 50 4.

40 R3EM Rise Phom~se 10 o i--

150.9 151 151.1 1512 151.3 151.4 151.5 151.6 151.7 151.8 151.9 Tie After PinnpTrp Page 3 of 3 f

ATTACHMENT 3 HYTRAN NODING DIAGRAM Page 1 of 1