ML20210F871
| ML20210F871 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/05/1987 |
| From: | Malkam M, Mcnutt G, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20210F865 | List: |
| References | |
| 218.7-(B), 218.7-(B)-R02, 218.7-(B)-R2, NUDOCS 8702110181 | |
| Download: ML20210F871 (15) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
218.7 (B)
SPECIAL PROGRAM REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER: 2 i
TITLE:
PIPE STRESS CALCULATIONS Acceptance Criteria for Overlap Areas of Calculations PAGE 10F 14 5
REASON FOR REVISION:
1.
TVA coments incorporated.
2.
Revise to incorporate SRP and TAS coments; to add chronology; and to include TVA's corrective action plan.
PREPARATION PREPARED BY:
W H &lJ I-27-1987 SIGNATURE
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.7 (B)
SPECIAL PROGRAM REVISION NUMBER: 2
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PACE 2 0F 14 1.
CHARACTERIZATION OF ISSUE (S):
Concern:
Issues:
D'-P5-039-003 a.
There was no consistent policy on "There are various ' alternately what constituted an acceptable lapped analyzed' problems on Watts Bar region at alternate analysis Unit 1 and Unit 2, which have bour.daries.
lapped region boundaries rather than anchor teminations.
The b.
The methods actually implemented for concern is 'there was no con-interfacing alternate analysis sistant policy on what consti-problems may not have been sufficient.
tuted an acceptable lapped region'.
The following method and/or cembinations were employed: a). Terminate at a 3-way support between problems.
b).
Establish a rigid region between problems c).
Eliminate torsion & bending by introducing additional supports.
Problem C"a.
area example: Root line P3-26-A42A, branch line 26238, 26234, 20227, 26007, 26228.
There are many more examples available in file."
2.
HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES x NO Identified by TVA, Sequoyah Date See Below Documentation Identifiers:
a.
TVA, Sequoyah Nuclear Plant, Ceneric Concern Task Force, Employee Concern No. IN-25-039-003, Rev.1, Sequoyah l
Investigative Reports, CPH-06-040 (05/29/86) b.
TVA, Ponconformance Report SCNCEDE303, (RFI 567, OE/29/66) 1014d - 01/27/E7
TVA EMPLOYEE CONCERNS REPORT NUMBER:
218.7 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 i
PAGE 3 0F 14 3.
DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
Root Line: N3-26-A42A Branch Lines: 26232, 26234, 26227, 26007, 26228 3-way Support 4.
INTERVIEW FILES REVIEWED:
i OTC File Review for Employee Concern IN-85-039-003, Element 218.1, 218.7, 222.1, (review notes by Gordon Parkinson, Cechtel), 06/18/8C.
E.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
J See Appendix A.
f.
WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
\\
See Appendix A.
7.
LIST RE0 VESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
P.
EVALUATION PROCESS:
a.
Reviewed past and present procedures for interfacing / terminating alternate analysis piping, b.
Evaluated rigidity of alternate analysis pipe spans.
c.
Reviewed the cited examples for applicability to the Sequoyah plant.
107dd - 01/P7/E7
TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.7 (B)
SPECIAL PROGRAM REVISION NUMBER: 2
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PAGE 4 0F 14 9.
DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronology:
10/30/75:
Procedure ( App. A, 6.c) issued describing methodology for analytically interfacing Alternate Analysis piping with Rigorous Analysis piping 0 2/81 :
NUREG/CR-1980 ( App. A, 5.1) issued describing an evaluation of the " overlap method" 08/25/83:
Sequoyah Rigorous Analysis Handbook revised ( App. A, 5.a) to address NUREG/CR-1980 05/13/85:
TVA receives subject employee concern IN-65-039-003 Discussion:
The overlap method has been used throughout the industry, to varying degrees, to justify the subdivision of large piping problems into smaller subproblems more amenabic to computer stress
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analysis.
Ideally, piping models include all piping between points of total fixity known as anchors' in pipe-stress terminology.
Where there is an insufficient number of anchors to subdivide a large problem, the problem can be subdivided by use of an overlap method.
In the overlap method the interfaces would not be discrete locations on the piping but rather, regions of piping common to each model.
In other words: if hypothetical piping system ' A' were subdivided into systems 'O' and 'C', the model of 'B' would include a portion of the piping of model
'C', and vice versa (over the same region).
The portion common to both would be the
' overlap' region. Overlap methodology, when it is fonnally defined, usually specifies requirements for the extent and configuration of the overlap region.
This is to ensure that analysis of the subproblems yields conservative values for pipe stress, pipe support loads, etc. Modeling the safety-related piping systems incorrectly, or in such a manner so as to yield nonconservative results, could pose safety / code compliance concern.
The first of the two issues (Issue a., Section 1) is that there was no consistent policy on what constituted an acceptable lapped region at alternate analysis boundaries.
In 1975, procedure DED-EP 21.10, Rev. 0 ( App. A, 6.c) was issued that provided "... complete definition to the analytic techniques employed in the analysis of the Sequoyah Nuclear Plant piping systems prepared by TVA Civil Engineering Dranch" (Section 1.1 of
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the procedure).
A related criteria document (50N-DC-V-13.3) made 107td - 01/27/P7
i TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.7 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 l
PAGE 5 0F 14 reference to the procedure and a similar document concerning the analysis completed by EDS Nuclear for TVA on the Sequoyah huclear Plant (Section 1.3 of the procer'ure).
Three alternate analysis criteria have been implemented at Sequoyah: CEB 80-5, CEB 74-2 and CEB 76-5 ( App. A, 5.p. 3.0).
One (CEB 76-5, Section 5.5.2) provides recommendations for interfacing rigorous analysis problems with alternate analysis problems, l
instead of appropriately referring to the rigorous analysis procedures which govern.
These recommendations, however, differ from those of DED-EP 21.10 ( App. A, 6.c) and the Sequoyah Rigorous Analysis Handbook ( App. A, 6.a).
Section 8.0 of DED-EP 21.10. "Modeling Techniques for Detailed Piping Analysis," provides instructions for overlap modeling for rigorous analysis problems (Section 2.1.1).
These instructions are l
typical of the nethods generally used by the industry at the time they were issued (1975).
Section 8.2.5.2 of this procedure gives the method for interfacing
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the rigorous analysis computer models with alternate analysis 4
non-computer-analyzed piping. These instructions apparently remained standard until the Sequoyah Rigorous Analysis Handbook (SON-RAH) was issued in 1983 as a response to NUREG/CR-1960 ( App.
A, 5.1).
The SCN-RAH, which was issued in 1983 does provide more instructions for interfacing rigorous analysis piping with alternate analysis piping, as well as for interfacing Rigorous to rigorous and rigorous to deadweight piping.
The second issue (Issue b., Section 1) of this report is that a singic three-directional translational restraint, with no overlap, may be an insufficient termination of a piping computer analysis when the piping actually continues beyond the three-directional restraint.
Concern was also expressed with termination justified by the use of three changes of piping direction to eliminate bending and torsion.
i I,
107ed - 01/27/P7 t
TVA EMPLOYEE CONCERNS REPORT NUMBER: 218.7 (B)
SPECIAL PROGRAM REVISION NUMBER: 2
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PAGE 6 0F 14 Section 1.3 of the SON-RAH-206 ( App. A, 5.a[I provides that a rigorous analysis problem may be terminated with a 3-way (or effective 3-way) support.
The evaluation tean requested that TVA-Sequoyah provide justification for the policy (of terminating rigorous analysisTVA replied that "If problems at a 3-way support App. A., 7.b).
Alternate Criteria CEB 76-5 supported piping is essentially rigid, than an effective 3-way support is adequate..." (see TVA reply to RFI SON-543, item #1). The evaluation team has provided TVA with a calculation showing that alternate analysis piping is not all rigid (tpp. A., 7.b).
TVA has not commented on that information.
The employee's concern related to the adequacy of establishing a rigid region between problems, or/and eliminating torsion and bending by introducing additional supports applies more to the interface between rigorous to rigorous and rigorous to deadweight analysis.
This aspect of the concern does not specifically apply to the interface between rigorous to alternate analysis.
- However, various methods of interface between problems can be used to j
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achieve the same results.
In September of 1983, Nonconformance Report ho. SChCEB8303 was written identifying a deficiency in the way lapped regions were handled prior to the revision of the Rigorous Analysis Handbook.
In Fay of 1984, 358 analysis problems were evaluated by TVA and 51 were determined to be affected by the revision of the Rigorous Analysis Handbook (Cited in Section III.B of App. A, 5.b).
A design study (/.pp. A, 5.d) was subsequently performed to determine which of the analysis problems required reanalysis. Sixteen rigorous / alternate 'boundarics' were found to be unacceptable and recuired further review (reported in App. A, 5.b).
These 16 problems will be addressed by TVA under hCR 8215 and/or NCR 8222 per reference App. A, 5.d.
1 This was issued in 1983 as a response to NUREG/CR-1980 ( App. A, 5.1).
The NUREG states "It is concluded that one overlap method should not be substituted for a complete analysis of a full system.
ibwever, if a sufficiently high natural frequency is associated with the overlap section, or the overlap is a obtained." ( App. A, 5.1, Abstract, iii)ptable results could be substantial portion of the system, acce
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"Tenninated" is interpreted to mean that the rigorous analysis
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corputer model need not be extended into the alternate analysis category piping.
(See TVA reply to RFI #507, iten #3) 107dd - 01/27/P7
TVA EMPLOYEE CONCERNS REPORT NUMBER:
218.7 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 I
PAGE 7 0F 14 The other employee concern is that improper overlapping may have been perfomed for certain specific example analyses (see section 1.0).
The exampics cited are Watts Bar plant examples and do not apply to the Sequoyah plant.
Therefore, these examples will not be reviewed under the Sequoyah Employee Concern Review Program but they will be reviewed under the Watts Bar Employee Concern Review Program.
Findings a.
There were consistent procedures for interfacing conputer-analyzed rigorous analysis piping with t
non-computer-analyzed alterrate analysis piping (cited in Section E.2.5.2 of App. A, 6.c).
As per procedure, there is no need for lapped region at alternate analysis boundaries.
j
(" Terminating at points where alternate analysis begins requires less isolation, since the system will be supported rigidly from that point on" [ cited in Section 8.2.5.2 App. A, 6.c]).
i b.
There is no justification for use of a 3-way restraint, f
O' "
without overlap, at the interface of rigorcus analysis piping with alternate analysis piping where the alternate analysis piping is not rigidly supported.
Conclusions a.
The employee concern that there was no consistent policy on lapped regions of alternate analysis boundaries is not valid. There were written procedures for interfacing rigorous analysis with alternate analysis piping, wherein there was no need for overlapped regions, t
b.
The employee concern that the methods implemented for interfacing alternate analysis problems may not have been sufficient is valid, where the alternate analysis piping is not rigidly supported.
l 10.
CORRECTIVE ACTION:
i In its Corrective Action Plan (CAP) ( App. A, 5.ag), TVA commits to establish a program to resolve the adequacy of using a 3-way restraint to terminate rigorous analysis problems which interface with alternate analysis problems and to assure compliance with FSAR corritrent s.
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i 1074d - C1/?7/07
TVA EMPLOYEE CONCERNS REPORT NUMBER: 21 8. 7 (8 )
SPECIAL PROGRAM REVISION NUpWER: 2 PAGE 8 0F 14 TVA will review all the rigorous analysis problems for Units 1 and 2 which interface with alternate analysis problems at 3-way restraints or effective 3-way restraint interfaces.
The worst case interface problems will be selected on the basis of the following parameters: pipe sizes and spans, branch line locations, pipe configurations, support types, and the location of concentrated weights. The selected worst cases will be reanalyzed to include the rigorous analysis problems along with adequate portion of the alternate analysis problems on the other side of 3-way restraint interfaces.
If significant increases in stress levels are revealed, TVA will review all the problems, and further evaluate any problems with low stress margins which might be affected (App.
A, 7.w).
If any inadequacies are found, TVA will take steps to assure FSAR compliance either by more sophisticated analysis or by actual field modifications.
In order to avoid recurrence, TVA will revise Sequoyah Rigorous Anlaysis Handbook to state that the rigorous / alternate analyses g'
interfaces are to be terminated with an anchor, and any exceptions
(.,,
will be approved by the technical supervision.
The evaluation team concurs with this CAP.
1074d - 01/?7/F7
TVA EMPLOYEE CONCERNS REPORT NLMBER: 218.7 (B)
SPECIAL PROGRAM REVISION NUMBER: 2
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PAGE 9 0F 14 APPENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a.
TVA, Sequoyah Nuclear Plant, Rigorous Analysis Handbook, Section SON-RAH-206, Rev. C ( Att.1 to reply to RFI 509,
[
CEB 830825 008) (08/25/83) b.
TVA, Sequoyah Nuclear Plant, Generic Concern Task Force, Employee Concern No. IN-85-039-003, Rev.1, Sequoyah l
Investigative Reports, GPH-06-040 (no RIMS #) (05/29/86)
I c.
TVA reply to Bechtel RFI 509, (no RIMS #) (08/25/86) d.
TVA, " Review of Piping Analysis for Adequate Termination,"
SDR SO48, ( Att. 2 to reply to RFI 509, 041 860227 003) l (02/27/86) e.
TVA, " Engineering Report re CAQ Report No. SQhSWP6215, Rev. 0," (Att. 3 to reply to RFI 509, 501 860612 839)
(06/12/86)
(
f.
TVA, Sequoyah Nuclear Plant, Alternate Analysis Review Program, " Program Description," SCN-AA-001, ( Att. 4 to reply l
to RFI 509 B25 860708 008) (07/01/86) g.
TVA, Sequoyah Nuclear Plant, Rigorous Analysis Fsndbook, 025 851115 001) (11/15/85), I Att. 5 to reply to RFI 509, Section 50N-RAH-401, Rev.1 t
h.
Bechtel, Watts Bar Nuc1 car Plant, Engineering Related Employee Concerns, Element Review Sheets, " Element 216.7,"
(07/30/86) f.
U.S. NRC, NUREG/CR-1980, BNL-NUREG 51357: " Dynamic Analysis of Piping Using the Structural Overlap Method," 02/81 j.
U.S. NRC, Standard Review Plan k.
TVA, Sequoyah Nuclear Plant, " Procedure for Detailed Analysis of Category I Piping Performed by TVA, DED-EP 21.10l Rev.0,"
I (TTB 212-8, no RIMS #, replacement copy), (10/30/75 1.
TVA, Sequoyah Muclear Plant, Perfomance Plan,_ Volume 2 (L44 860714 800) (07/14/86) l 1074d - 01/?7/87
TVA EFLOYEE CONCERNS REPORT NUpBER: 218.7 (B)
SPECIAL PROGRAM REVISION NUPEER: 2
[
PAGE 10 0F 14 APPENDIX A (contid) m.
TVA, NCR SQNCEB8303, Rev.1, (RFI 567, CE8 830921013)
(08/29/86) n.
TVA, Engineering Report, Rev. 6/12/86, NCR SQNCEB8303, j
Rev. O, (RFI 567, 501 860618 895) (06/18/86) o.
TVA memo D. W. Wilson to J. A. Raulston, NCR SQNCEB8303,
[
Rev.1 (RFI 567, 825 860902 003) (09/02/86) p.
TVA, " Alternate Piping Analyses and Support Criteria for Category I Pipin Systems, Design Criteria No. SQN-DC-V-13-7, 4-1-73, Rev. 2,"g(Reply to RFI 559[7], ESB 841012 203) l (10/04/84) q.
Memo, M. S. Ali, TVA, to R. Wilkinson, 8echtel, (Reply to RFI 739, no RIMS #) (11/24/86) r.
TVA, Sanple Study to Evaluate the Use of a 3-Way Restraint for Tenninating Rigorous / Alternate Problems (Reply to RFI
,(
737, no RIMS #) (no date) s.
TVA, Coments on employee concern of element 218.7 (Reply to RFI 657, no RIMS #) (no date) t.
Memo, K. L. Mogg, TVA, to S. S. Chitnis and R. Wilkinson, Bechtel, (Reply to RFI 617, no RIMS #) (09/07/86) u.
Memo J. A. Southors, TVA, to S. S. Chitnis, 8echtel, (Reply to RFI 588, no RIMS #) (09/29/86) v.
Memo, K. L. Mogg, TVA, to S. S. Chitnis, Bechtel, (Reply to RFI 567, no RIMS #) (09/18/86)
Memo,43, no RIMS #) (09/30/86)K. L. Mogg, TVA, to S. S. Chit w.
RFI 5 x.
Memo, N. A. Liakont s, TVA, to S. S. Chi tnis, Bechtel, (telecopied 10/21/8G,16:25, no RIMS #) (10/21/86) y.
TVA, Response to the Consnents on Corrective Action Plan for CATD, K. L. Mogg and M. S. Ali, (Reply to RFI 765, no RIMS
- ),(12/31/86) z.
TVA Drawing No. 0600152-09-02, RS (05/15/81) (Reply to RFI 570, no RIMS #)
1074d - 01/27/87
TVA EWLOYEE CONCERNS REPORT NUMER: 218.7 (8 )
SPECIAL PROGRAM REVISION NUMER: 2
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PAGE 110F 14 APPENDIX A (cont'id) aa.
TVA Drawing No. 47K435-60, R2 (04/22/81) (Reply to RFI 570, no RIMS #)
ab.
TVA Drawing No. 0600102-09-01, R8 (Reply to RFI 570, no RIMS
l ad.
TVA Drawing No. 47K435-53, R6 (07/05/84) (Reply to RFI 570, No RIMS #)
ae.
TVA Drawing No. 47K432-50, R8 (07/05/84) (Reply to RFI 570, no RIMS #)
no RIMS #)g No. 47K406-57, RS (11/04/80) (Reply to RFI 570, TVA Drawin af.
ag.
TCAB-68, Corrective Action Plan (CAP) for Element 218.7(B),
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(01/26/87) 6.
WAT REGULATIONS, LICDiSING COP 9tITNENTS, DESIGN REQUIRD4ENTS, OR 011tER APPLY OR GUNINDL IN THIS AREA 7 r
I a.
TVA, Sequoyah Nuclear Plant, Rigorous Analysis Handbook, l
Section SQN-RAH-206, Rev. O. (CEB 630525 008), (06/2b/83)
I b.
TVA, Sequoyah Nuclear Plant, Rigorous Analysis Handbook, Section SQN-RAH-401, Rev.1. (B2b 651115 001), (11/15/85)
I c.
TVA, Sequoyah Nuclear Plant, " Procedure for Detailed Analysis of Category I Piping Perfonned by TVA, DED-EP 21.10, Rev. 0,"
(10/30/75) d.
TVA, Sequoyah Nuclear Plant, Final Safety Analysis Report e.
TVA, " Alternate Piping Analysis and Support Criteria for Category I Piping Systems, Design Criteria No. SQN-DC-V-13-7 (RF1559[7], ESB 841012 203), (04/01/73), Rev. 2," (10/04/84) l
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1074d - 01/27/87 l
TVA DFLOYEE CONCERNS REPORT NUMER: 218.7 (B)
SPECIAL PROGRAM REVISION NUMER: 2 PAGE 12 0F 14
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7.
REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DI5GU55 ION 5 RELATED TO ELtntMT:
a.
Bechtel RFI #SQN-509, (08/21/86) b.
Bechtel RFI #SQN-543, (09/10/86) c.
Bechtel RFI #SQN-567, (09/17/86) d.
Bechtel RFI #SQN-570, (09/18/86) e.
Bechtel RFI #SQN-588, (09/25/86) f.
Telecon between Bechtel and TVA, IOM 338 (10/22/86) g.
Bechtel RFI #SQN-617, (10/03/86) h.
Telecon, J. A. Southers, TVA, to R. Wilkinson, Bechtel, IOM 281 (09/29/86) i.
Telecon, R. Wilkinson, Bechtel, to M. Hartzman, NRC, IOM 294
-(,,
(10/03/86) j.
Telecon, N. Liakonis et al., TVA, to S. S. Chitnis and M.
Malkani, Bechtel, IOM 302 (10/07/86) k.
Telecon, N. A. Liakonis, K. Mogg, and fl. Ali, TVA, to S. S.
Chitnis, M. Malkani, and R. Wilkinson, Bechtel, IOM 428 (11/24/86) 1.
Telecon, S. S. Chitnis, R. Wilkinson, and K. Jandu, Bechtel, to N. S. Liakonis, M. Ali, and K. L. Mogg, TVA, IOM 507 (01/05/86) m.
Memo, S. S. Chitnis and R. Wilkinson, Bechtel, to K. Mogg and M. S. Ali, TVA (01/08/87) n.
Telecon, R. Wilkinson, Bechtel, to H. S. Ali, TVA, IOM 527, (01/13/87) o.
Bechtel RFI (SQN-769 (01/14/87) p.
Bechtel RF? #SQN-770 (01/14/87) q.
Telecon, N. A. Liakonis, K. Mogg, and M. S. Ali, TVA, to S.
i, M. Malkani, and R. Wilkinson, Bechtel, IOM 534, 1074d - 01/27/87
TVA DFLOYEE CONCERNS REPORT NUMER: 218.7 (B)
SPECIAL PROGRAM REVISION NUMER: 2 PAGE 13 0F 14 r.
Bechtel RFI #SQN-772 (01/15/87) s.
Bechtel RFI #SQN-657 (10/24/86) t.
Bechtel RFI #SQN-737 (11/24/86) u.
Bechtel RFI #SQN-739 (11/25/86) v.
Bechtel RFI #SQN-765 (01/05/87) w.
Telecon, D. Wilson, K. Mogg, W. Kagey, M. S. Ali, and P. J. Means, TVA, to S. S. Chitnis, M. Malkani, and R.
Wilkinson, Bechtel, IOM 540,(01/16/87) l 1074d - 01/27/87
TVA EWLOYEE CONCERNS REPORT NupeER: 218.7 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 14 0F 14 CATD LIST The following CATD identifies and provides corrective action for the findings included in this report:
218 07 SQN 01 (12/12/86; CAP revised 01/21/87)
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1074d - 01/27/87
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7 REFERENCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 89 FREQUENW
- REGUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:S7:19 ONP - ISSS - RWM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY EN DES PROCESS S CUTPUT SUBEATEGORYs 21807 ACCEPTANCE CRITERIA FOR OVERLAP AREAS OF CALCS S
GENERIC KEYWORD A N
APPL QTC/NSRS P
KEYWORD B CONCERN SUB R PLT BBSH INVESTIGATION S
CONCERN KEYWORD C NUM3ER CAT CAT D LOC FLQB REPORT R
DESCRIPTION KEYHORD D
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I] -8S-039-003 EN 21807 N H3N YYYY SS ON PIPE RUNS FOR HHICH BOTH CALCULAT DESIGN PROCESS T50050 K-FORM IONS (T-PIPE a SAGS) HERE USED, NO A DESIGN CHANGES CCEPTANCE CRITERIA HAS ESTABLISHED F ENGINEERING s
OR CVERLAP AREAS OF CALCULATIONS. I TERMINATIONS MPROPER TERMINATION USED BETHEEN PRO BABLE BOUNDARIES. CIE 3 HAY RIGID R EGIONS, 3 CHANGES OF DIRECTION AND E
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LIMINATION OF BENDING / TORSION)
I CCNCERNS FOR CATEGORY EN SUBCATEGORY 21807
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