ML18033A182

Forwards Description of Program for Seismic Qualification of Drywell Steel & Drywell Steel Interim Operability Criteria, for Resolution of NRC Concerns as Discussed in 880318 Meeting.Review of Program Requested

ML18033A182
Person / Time
Site:	Browns Ferry
Issue date:	04/28/1988
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-00302, TAC-302, NUDOCS 8805040088
Download: ML18033A182 (30)

Text

REGULATO 'NFORMATION DISTRIBUTION STEM (RIDS>

i ACCESSION NBR 8805040088 DOC. DATE: 88/QO/28 NOTARIZED: NO DOCKET 0 FAC IL: 50-260 Broens Ferry Nuclear PoUJer Stationi Unit 2i Tennessee 05000260

'UTH. NAME AUTHOR AFFILIATION GR IDLEY. R. Tennessee Va 1 1 eg Auth or i tg RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Foreards description of program for seismic qualification of drgeell steel h drgtuell steel interim operability resolution of NRC concerns as discussed in 880318

~

criteria'or meeting. Review of program requested.

DISTRIBUTION CODE; TITLE: TVA Facilities DOSOD COPIES RECEIVED. LTR Routine Correspondence j ENCL Q SIZE I NOTES: G. Zech 3 cg. 1 cg. ea to: Ebneteri*xelradi S. Richardson'.

05000260 D. Liaei K. Barri OI.

REC I P I ENT COP I ES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL JAMERSON. C 1 1 PD 1 1 MORAN> D 1 1 GE*RSI G 1 INTERNAL: ACRS 1 1 ADM/LFMB 1 0 AE 1 OGC 15-B-18 1 0 1 1 EXTERNAL: LPDR 1 1 NRC PDR NSIC 1 NOTES:

TOTAL NUMBER OF COPIES REQUIRED: LTTR '1 ENCL

0 TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place APR 28 I88 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Nashington, D.C. 20555 Gentlemen:

In the Matter of Docket Nos. 50-260 Tennessee Valley Authority BROHNS FERRY NUCLEAR PLANT (BFN) SEISMIC QUALIFICATION OF DRYNELL STEEL-(NRC TAC NO. 00302)

This letter describes the BFN program for the seismic qualification of drywell steel. This letter supplements the information provided by section III.3.8 of revision to the BFN Performance Plan which was transmitted by S. A. Nhite's 1

letter dated July 1, 1987 and R. Gridley's letter, dated March 10, 1988. This letter incorporates resolution of the NRC staff's concerns as discussed in our meeting, dated March 18, 1988. to this letter describes the BFN program for resolving this issue. Enclosure 2 provides the BFN drywell steel interim operability criteria. TVA requests your review of this program and the issuance of a written statement documenting the programs acceptability.

Please refer any questions regarding this submittal to M. J. May, Manager, BFN Site Licensing, (205) 729-3570, Very truly yours, TENNESSEE VALLEY AUTHORITY

(

R. Gr dley, Dir ct r Nuclear Licensing and Regulatory Affairs Enclosures cc: See page 2 O$ 6 8805040088 880428 PDR ADDCK 05000260 p

An Equal Opportunity Employer

U.S. Nuclear Regulatory Commission

~PA 88 1888 cc (Enclosures):

Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NN, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One Nhlte Flint, North 11555 Rockvi lie Pike Rockville, Maryland 20852 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, P.O. Box 637 Athens, Alabama 35611

r e'j~g'~j

~'

r I

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNIT 2 DRYWELL STEEL PLATFORMS This report gives TVA's plan to demonstrate the adequacy of drywell steel platforms.

Issue A nonconforming condition report identified an unanalyzed attachment to one of the lower drywell platforms. Investigation showed this to be part of a generic problem for all drywell platforms, B~ack round While dispositioning nonconforming condition report BFN-BWP-8309, the following was determined: Drywell floor framing steel at elevations 563'nd been reevaluated for some loads which were added or revised since the 584'ad'ot original design, structural behavior of platforms under combined loadings was not completely evaluated and documented, and some configurations did not match drawings. Additional findings were later identified in SCR BFN CEB 8634, 8640, and 8643 on platforms at elevations 604', 616', and 628'.

Resolution To assure the adequacy of drywell steel platforms, the following plan was implemented:

1. A detailed walkdown of all drywell platforms was performed to document the as-built configuration.

2. Detailed analysis of each platform was performed using the GT-STRUDL program. The model included primary as well as secondary steel that supports piping systems and cable trays. All support loads considered were the maximum values for OBE and DBE load conditions. Resulting stresses were compared to an interim Operability Criteria based on the AISC code.

The allowables are summarized in table 1.

3, Modifications are necessary to meet the interim operability criteria, on secondary steel beams and connections and were mainly due to safety relief piping loads. Additionally, stiffener plates were added to reduce 'alve the local stresses in beams at attachment points.

4. Additional modifications were made to correct installation problems observed during the walkdowns.

5. All modifications necessary to meet operability criteria will be made prior to restart of unit 2.

r 4,

6. The FSAR requires that the drywell steel platforms remain functional for loads due to the platform weight and all attachment, loads. Specific stress allowables are identified in FSAR Table 12.2.16. These commitments are reflected in the design criteria fox drywell steel platforms.

The drywell platform design will be brought up to the FSAR commitment post-restart incorporating final pipe support attachment loads consistent with the schedule for completion of the progxam to resolve IE Bulletin 79-14. Modifications required to meet design criteria will be implemented prior to restart following the next refueling outage.

To assure the structural adequacy of drywell platforms. for future attachments, a long-term program has been established to monitor and evaluate new attachments.

Licensin Issue The Intex'im Operability Criteria used to determine the structural adequacy of drywell platforms allows 1.7 times the capacity 'S'ased on the AISC code, instead of the FSAR stress limits of 0.9Fy.

Justification The use of the Operability Criteria on an interim basis is considered justified because of the following:

1. The interim operability criteria minimizes the modifications in highly congested radioactive areas now, while maintaining, adequate industry accepted safety margins.

2. The long-term program provides for updating the designs fox the latest loads, resulting from the 79-14 program, and meeting the FSAR requirements.

3. The operability critexia is based on NUREG 0800, Standard Review Plan, section 3.8.3, which has been accepted fox'se on other nucleax power plants. Also, the use of the AISC code allowable stx'esses with appropx'iate factors has been accepted by NRC for the Toxus Long Term Integx'ity 'oad program as documented in section 4-3.4 of the BFN Plant Unique Analysis Report (PUAR) which was transmit,ted by letter dated January 3, 1984, and as supplemented by submittals dated September 11, 1984 and January 25, 1985.

Approval of the BFN-PUAR is documented by letter from D. B. Vassallo to H. G. Parxis, dated May 6, 1985.

The dxywell steel qualification program is comprehensive and assures the structural adequacy of the drywell steel platforms.

ENCLOSURE 1 TABLE 1 DRYWELL STEEL PLATFORMS CRITERIA COMPARISON INTERIM DESIGN CRITERIA OPERABILITY REMARKS STEEL ALLOWABLE UP TO 0.9Fy UP TO BASED ON SRP*

TENSION, BENDING 1.7 X AISC STRESS STEEL ALLOWABLE UP TO 0.4Fy UP TO BASED ON SRP*

SHEAR STRESS 1. 7 X AISC:

WELD ALLOWABLE UP TO 0.4Fy UP TO BASED ON SRP*

SHEAR STRESS OF BASE METAL 1.7 X AISC CONCRETE ANCHOR WEDGE TYPE ALL TYPES SIMILAR TO PIPE FACTOR OF SAFETY 4 2 SUPPORT OPERABILITY WEDGE & SHELL SHELL TYPE CRITERIA TYPE 5 FOR TENSION 4 FOR SHEAR

• USE OF THE AISC CODE ALLOWABLE STRESSES WITH APPROPRIATE LOAD FACTORS HAS BEEN APPROVED FOR THE BFN PROJECT FOR THE LONG TERM TORUS INTEGRITY PROGRAM

Enclosure 2 Browns Ferry Nuclear Plant Drywell Steel Interim Operability Criteria

~ ~

CRITERIA BFN 50 C 7100 ATTACHMENT F BROWNS FERRY NUCLEAR PLANT DETAILED Design Criteria For STRUCTURAL ACCEPTANCE OF DRYWELL ACCESS PLATFORMS NOTE: This Attachment incorporates and replaces BFN-50-790 Rev. 0

p l~

BFN"50-C-7100, Attachment F TABLE OF CONTENTS

~Pa e

1.0 INTRODUCTION

0 0 ~ ~ ~ ~ ~ ~ ~ 0 0 ~ ~ ~ ~ ~ 1 1.1 Descriotion ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1 1.2 Pueaose ~ ~ ~ ~ ~ ~ l ~ 1 ~ ~ ~ ~ t ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1 1.3 ~Seo e ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 ~ ~ ~ 1 2 ~0 DESIGN SPECIFICATIONS ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~, ~ ~ ~ ~ ~

3~0 LOADS AND LOADING COHBINATIONS ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 2 3.1 Loadin Definitions ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 2 3.2 Loadin Combinations -

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 5 4.0 DESIGN AND ANALYSIS PROCEDURES ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ . ~ ~ o 5

5.0 REFERENCES

~ . . . . . ~ ~ . . . ~ . . . ~ ~ ~ ~ ~ ~ ~ ~ ~ 5 Figure 3 1.7 Combination of Dynamic Reactions from Attached Systems TABLES:

Table 3.2.1 Loading Combinations For Stress Evaluations Table 3.2.2 Loading Combinations For Uplift Evaluations 1

BFN-50-C-7100 ATTACHHENT F

1.0 INTRODUCTION

The dryweLL access platforms include two main platforms, one at elevation 584 Eeet ll inches, and one at elevation 563 feet 2 inches. The flooring is standard grating, with l-l/2-inch by 3/16-inch load bars. The grating and support steel extend from the reactor pedestal to the dryweL'L shell at elevation 563 feet 2 inches and from the sacrificial shield wall to the drywell shelL at elevation 584 feet, ll inches.

The platforms are supported by 24-inch-deep, wide-flange beams radiating from the reactor pedestal and sacrificial shield wall to the dryweLL shell. The radial support beams for elevation 584 Eeet 11 inches are field-welded to header beams in the sacrificial shield wall. The radial support beams Eor elevation 563 feet 2 inches are field-bolted to embedded plates in the outside Eace of the reactor pedestaL. All radial beams are supported by beam seats ~elded to the drywell shell- Lubrite pads under t: he radial beams allow drywell shell expansion. Shear bars welded to the bottom ELange of the radial. beams on both sides of the beam seat prevent lateral movement of the beams. Intermediate grating support beams at 6 Eeet 6 inches maximum spacing are Eramed between the radiaL beams. Additional support beams are framed between both the radial and grating support beams Eor equipment, HVAC, cable tray, and piping system load attachments

.1.2 ~Pur eee The purpose of this criteria is to establish the requirements for the designer to assure uniformity in design during the evaluation of the drywell access platEorms and to obtain a safe and complete design considering all appropriate loading combinations. This criteria defines the loads and load combinations for use in this evaluation and also the associated 'allowabLe stresses and uplift evaluation requirements.

1.3 ~Sco e 1.3.1 The requirements of this document shaLl apply only to the structural steel inside the drywell at elevation 584 feet 11 inches and elevation 563 feet 2 inches as denoted on TVA drawings 48N442 and 48N443, including miscellaneous steel Eor these elevations as denoted on TVA drawings 48N1015-series, 48N1016-series, and 48N1028 ~

1.3.2 In the event of conflicting requirements between this document and any reference material, this document shaLL govern. HoweverP the civil project engineer shaLL be notified of the difference.

BFN-50-C-7100 ATTACHMENT F 2.0 DESIGN SPECIFICATIONS For this structural design or reevaluation, the 1978 AISC Specification for the Design, Fabrication, and Erection of Structural Steel Eor Buildings shall be used.

3.0 LOADS AND LOADING COMBINATIONS 3.1 Loadin Definitions 3.1.1 D - Deadload, including structural steel, permanent equipment, and attached systems, e.g., piping, HVAC, cable trays, etc, shall be a minimum of 40 psE.

3.1.2 Lo Outage and maintenance loads, including any moveable equipment loads and other loads which vary with intensity and occurrence during an outage, i.e., these loads will not be present while the plant is operating. An Lo of 100 psf applied to the loadable open areas'shall be evaluated as a baseline outage and maintenance live load Eor the initial analysis using this criteria. As concentrated live loads due to outage or maintenance procedures are identiEied, these loads shall be evaluated against the baseline case. If the results of the concentrated loads exceed the baseline case, the concentrated loads must be evaluated per this criteria. The cooler live load shall be 1.5 kips per foot of beam, where applicable.

3.1.3 L - Live loads while the plant is operating, including any loads which vary with intensity and occurrence and are not otherwise accounted for. For the purpose of the initial evaluation using this criteria, L will .be assumed xero.

3.1.4 E - Loads due to effects of OBE on structural steel and permanent floor-mounted equipment. This excludes support loads from attached piping, HVAC ducts, and cable trays (these loads are defined in Section '3-1-8) ~

3.1.5 E' Loads due to effects of SSE on structural steel and permanent floor-mounted equipment. This excludes support loads from attached piping, HVAC ducts, and cable trays (these loads are defined in Section 3.1.8).

3.1.6 Yr Equivalent static load on the structural due to a pipe whip reaction from existing pipe rupture restraints attached to drywell steel.

Note: The application of pipe rupture loads only at those locations where mi.tigation exists is consistent with the baseline approach to pipe rupture design inside the drywell. Only those locations ~here GE and/or TVA negotiated pipe rupture mitigation as part of the original design need be considered.

F-2

BFN-50-C-7100 ATTACHMENT F RFE - Restraint of free end displacement loads, e.g., therma1.

reactions from attached piping systems based on the most critical condition.< RFE loads can be subdivided as follows.'.1.7.1 RFEuL RFF. reactions which contribute to uplift.

3.1.7.2 RFEs All other RFE reactions, i.e., reactions which do not contribute to uplift.

-If reduced conservatism is needed, RFE loads may be divided into upset, emergency, and faulted conditions corresponding to the associated dynamic loading conditions'YNB, DYNC, and DYND - Reaction of attached systems, e.g.,

piping, HVAC, cable trays, etc., due to upset (service leveL B),

emergency (service level C), and Eaulted (service level D) dynamic events, respectively. Note. Not all attached systems are analyred for the faulted condition; therefore', some reaction po'ints on the floor steeL will only have upset and emergency Loading.

3.1 ~ 8.1 Dynamic Reaction Phasing Dynamic reactions from attached systems are transmitted to the floor steel through rigid restraints and snubbers. Based 'on the location and orientation of these restraints, different assumptions can be made regarding the phasing of these dynamic loads. These assumptions can be grouped into three general categories as follows:

Group A - Phasing Known When two or more dynamic restraints act together to restrain a particular motion or mode of vibration of an attached system, in-phase reaction loads can be assumed. For example, reactions resulting from a matched pair of vertical snubbers on a piping system would fall into this group.

Group B Random Phasing When a dynamic restraint acts independently to restrain a particular motion or mode of vibration of an attached system, this reaction can be considered randomly phased with other dynamic reactions.

Croup C - Worst Case Phasing

'hen two or more dy amic restraints act to r'estrain a particular Location of an attached system in more than F-3

BFN-50-C-7100 ATTACHMENT F one direction, a phasing relationship for these restraints cannot be assumed. For example, two snubbers which restrain essentially the same point on a piping system and ~hose lines of action are skewed to each other would fall into this group. The results of these reactions must be sunned absolutely to determine an enveloping condition.

If further justification or additional analysis can show a phasing relationship between group C restraint loads, these restraints can be treated as group A restraints 3.1.8.2 procedure for Determining DYNB, DYNC, and DYND 3.1.8.2 ' As a minimum, the following procedure shall-be used to determine 'the dynamic reaction load cases.

A. Assign each dynamic reaction to one of the groups defined above. This will require engineering judgment.

Justification for these groupings shouLd be included as part of the analysis report as required by section 4.0 of this criteria.

B. Group A reactions should be arranged into load sets per the phasing sssumed. Each load set should be evaluated separately with the results of each evaluation constituting a dynamic load step.

C. Each group B reaction should be evaluated separately with the results of each evaluation constituting a dynamic load step.

D. Group C reactions should be arranged into load sets per their potential for 0 phasing. Each reaction in the load set should be evaluated separately.

The absolute summation of the resuLts.

of each reaction in the load set wil1.

constitute a dynamic load step.

Combine alL dynamic load steps using the square root of the sum of the squares (SRSS) method to form DYNB, DYNC, or DYND.

BFN-50-C"7100 ATTACHMENT F 3.1.8.2 2 Figure 3.1.7 provides a summery of this procedure.

3-1-9 DYBD - Larger of DYNB or DYND. To determine DYBD, screen each DYNB load step against the corresponding DYND load step. (Note that in some instances no DYND load step exists. In these cases, use the DYNB load step.) Combine the screened load steps using the SESS method to form DYBD.

3.1.10 DYCD - larger of DYNC or DYND. Use the procedure outlined in 3.1.9 above substituting DYNC for DYNB.

3.1.11 To - Thermal effects and loads during startup, normal operating, or shutdown conditions, based on the most critical transient or steady-state condition 3.1.12 Ta - Thermal loads under thermal conditions generated by the postulated pipe break accident and including To.

3.2 Loadin Combinations As stated in section 1.1, all radial platform support beams are supported on one end by beam seats welded to the drywell shell. Since the beam seats do not have holddown capability, the potential for lifting off the beam seats as well as the beam stress must be evaluated. Tables 3.2.1 and 3.2.2 detail the loading combinations which must be addressed in these two evaluations.

4.0 DESIGN AND ANALYSIS PROCEDURES The design and analysis procedures utilized for the drywell steel structures, including assumptions on boundary conditions and expected behavior under l,oads, shall be in accordance with the AISC "Specification for the Design, Fabrication, and Erection of Structural Steel for Buildings," 8th Edition, A summary of analysis procedures as well as justification for assumptions should be documented in the form of an analysis repoit. This analysis r'eport should be issued's an OE calculation.

5 0 REFERENCES 5 ' Design Criteria BFN-50-D707, Revision 2, Analysis of As-Built Pipin Systems.

5.2'esign Criteria BFN-50-D706, Revision 1, The Torus Integrity Lo -T Program.

5 ' TVA dra ings 48N442, 48N443, 48N1015"serxes, 48N1016-se F-5

BFN-50-C-7100 ATTACHMENT F CROUP JL K +K K +Kg, KN + KN+1 GROUP B DYHB SESS DYNC Rl DYND Rg RN GROUP C U) + U2 U3 + Ug UN + UN+1 Ki ~ Individual group A reaction Ri Individual group B reaction Ui Individual group C reaction Figure 3 ~1 ~7 Combination of Dynamic Reactions from Attached Systems F-6

1 BFN" 50-C-7100 ATTACHMENT F TABLE 3.2.1 LOADINC COHBINATIONS FOR STRESS EVALUATION Combxnatxon Allowable Stress(

A. D + Lo 1 ' S B D+ L+ E+ DYNB 1.0 S C D + Lo + E + DYNB 1.0 S D D + L + E + DYNB + To + RFEs 1~5 S E. D + Lo + E' DYNC 1.6 S F. D + L + E' DYNC + To + RFEs 1.6 S D + L +'DYND + Ta + RFEs F 6 S D + L + E + DYBD + Ta +.RFEs + Yr(2) 1.6 S D + L + E' DYCD t Ta + RFE + Yr(2) 1.7 S Notes:

S - For structural steel, S is the required section strength based on elastic design methods and the allo+hie stresses defined in Part 1 of the AISC "Specification for the Design and Fabrication, and Erection of Structural Steel for .Buildings."

The one-third increase in alloMable stresses due to the seismic or Mind loadings is not permitted.

4 (2) Only one pipe Mhip reaction should be considered at any given tame; however, all poostulated breaks 'for Mhich pipe rupture mitigation structures exist and are. attached to dryvell steel must be considered.

F-7

BFN-50-C-7100 ATTACHMENT F TABLE 3.2.2 LOADING COMBINATIONS FOR UPLIFT EVALUATION(l)

Combination Static Loadin D amxc Loadxn

.9D + To + FEul

.9D DYHB + E 1

.9D + To + RFEul DYNB + E

.9D DYNC +

E'9D

+ To + RFEul DYNC + El

.9D + Ta + RFEu DYND + E+ Yr

.9D + Ta + RFEul DYND + E' Yr In each combination, it must be shorn that the magnitude of the, beam seat reaction due to static loading is greater than the-reaction due to dynamic loading, unless an adequate tiedown exists or the magnitude of uplift is within acceptable limits. Those acceptable uplift limits ~ill .be defined on a case-by-case basis and included in this criteria if the need arises.

t' i

~

BFii-50-C-7l00

~

~ ~ ~

Attachment F BFN-50-C-7100 DlSCREPANCIES

1. C/R CEB-JMH-1060 (JFG 1013) statement that building will be designed to remain elastic under DBE appears to conflict with Table 4.2-33 which permits strength design instead of working stress design.

2. FSAR Section 12.2.2.7.3 states in 2 locations (TLM 1205 and 1206) that the ASME B&PV Code, Section lll, Class B Vessels, 1968 edition was used, whereas Attachment D to BFN-50-C-7100 specifies the 1965 edition.

3. Source d ocument nt for e ion 3.1.1.D of BFN-50-C-7100 Attachment F for dead or Section load was not consistent with FSAR Section 12.2.2.7.1; how incorporate d b y G/C Also source document for Attachment F, Section 3.1.2 did not address cooler live load as provided in FSAR Section 12.2.2.7; .;1.. Ithasalso been added by G/C.

4. Table 4.2-14 of C-7100 (formerly FSAR Table 12.2-16) conflicts with Table 3.2.1 of Attachment F. This must be resolved in Revision 1 of C-7100.

5. FSAR Section 12.2.2.7.1 (page 12.2-31) states that seismic load factors are applied to dead loads and live loads. Attachment F (source document BFN 709) implies seismic accelerations are only applied to dead loads.

6. Attachment F (formerly BFN-50-790) provides design criteria for uplift evaluations but makes no mention of tie-down columns as reference in Section 12.2.2.7.1 (p. 12.2-31). This discrepancy is noted; however, the general design requirements in Attachment F should be adequate without any reference to tie-down columns which may not even be required.

7. The one hour rainfall of 2.12 inches in Section 3.3 of C-7100 conflicts with the 14 inches cited in Attachment E, Section 4.2.5, for the Volume Reduction and

'olidification Structure.

8. FSAR Section 12.2.4.2 states that anchor bars for the chimney foundation shall ed to El. 561.0 which

' corresponds to the maximum probable flood elevation. This conflicts wit C/R CG-1023 - w which i states that the MPF is El. 562-0.

The seconda containment internal positive design oressure of 7 inches o f ut in GECRNR1055 (B45860618882) and incorporated into Attachment D does not agree wit e ion of 2 inches of water.

F-'9

~ .

I

/