ML20084L681
| ML20084L681 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/07/1984 |
| From: | Brandt C EBASCO SERVICES, INC. |
| To: | |
| Shared Package | |
| ML20084L667 | List: |
| References | |
| NUDOCS 8405140588 | |
| Download: ML20084L681 (21) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
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TEXAS UTILITIES ELECTRIC
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Dockets Nos. 50-445 and COMPANY, et al.
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50-446
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(Comanche Peak Steam Electric
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(Application for Station, Units 1 and 2)
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Operating License)
AFFIDAVIT OF C.
THOMAS BRANDT REGARDING NEAR UHITE BLAST My name is C.
Thomas Brandt.
I reside in Ft. Worth, Texas.
I am employed by Ebasco Services, Inc. at Comanche Peak Steam Electric Station.
A statement of my educational and professional qualifications has been received in evidence as an attachment to Applicants' Exhibit 141.
This affidavit addresses Applicants' construction and quality procedures regarding the near-white blast criterion for steel surface preparation.
In testimony before the Board, Robert Hamilton alleged that in September or October, 1981, Applicants changed the Comanche Peak procedures that require near-white blast steel surface preparation (CASE Ex.
653 at 15). In response, Applicants submitted copies of the Comanche Peak Construction Procedure, CCP-30, " Coating Steel i
Substrates Inside Reactor Building and Radiation Areas,"
i Section 4.1.1, and the relevant OA/OC procedure, OI-OP-B405140508 840511 PDR ADOCK 05000445 Q
PDR l
. 11.4-1, " Inspection of Steel Substrate Surface Preparation,"
Section 3.3.2.c.
The Board concluded that Applicants' reference to CCP-30 did not completely address the question, because the procedure was Revision 10, dated January 26, 1982.
The Board found that Applicants had not addressed Mr. Ha mil ton 's allegation for the period between September or October, 1981, (when, Mr. Hamilton believed, that the procedures were changed), and January 26, 1982, when Revision 10 to the construction procedures went into effect.
Attached to this affidavit (Attachment A) are copies of the following revisions to CCP-30, " Coating Steel Substrates Inside Reactor Building and Radiation Areas," Section 4.1.1:
Revision 7 Effective 5/7/81 Revision 8 Effective 10/22/81 Revision 9 Effective 11/4/81 j
Revision 10 Cffective 1/26/82 l
l In each revision, Section 4.1.1 of the construc tion procedures, which governs the preparation of steel substrate surface, is identical.
Specifically, each revision l
provides:
The surface shall'then be cleaned by blast, hand or power tool operations to achieve an equivalent I
of SSPC-SPlO-63, "near white" blast cleaning.
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At no time during 1981 or 1982 was the near-white blast standard removed from the Comanche Peak construction procedures.
Indeed, the near-white blast standard for steel r
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. surface preparation was incorporated in the procedures in 1977 and is in the most current procedures (as of May, 1984).
Prior to 1977, the construction procedures required i
that steel substra te be prepared to a " white metal blast P
cleaning" condition, as defined by SSPC-SP-5.
Also attached to this affidavit (Attachment B) are copies of those provisions of OI-OP-ll.4-1, " Inspection of Steel Substrate Surface Preparation and Primer Application,"
that governed the inspection of steel substrate surfaces after preparation by blasting or power tooling (in Revisions 3 and 4, the relevant section is 3.3.2; in all subsequent revisions the section is 3.2.2):
Revision 3 Issued 5/29/81 Revision 4 Issued 10/23/81 Revision 5 Issued 10/27/81 Revision 6 Issued 11/10/81 Revision 7 Issued 12/2/81 Revision 8 Issued 6/11/82 As the attachments show, Applicants did not change j
these quality instructions as to the "near white blast" l
standard in late 1981, as Mr. Hamilton alleged.
The "near white blast" inspection standard for steel substrate surface preparation has been included in Applicants' quality instructions since 1977.
The Board's October 25, 1983 Memorandum and Order in this proceeding (at 8) concluded that Applicants could not
. rely on Section 4.1.1 of then-current CCP-30, because the copy of the procedure before the Board was Revision 10, dated January 26, 1982.
The Board apparently concluded that Section 4.1.1 itself had been amended on January 26, 1982.
The only reason that Applicants submitted Revision 10 of CCP-30 to the Board was that it was the procedure in effect at the time that Mr. Hamilton left his employment at Comanche Peak.
Applicants revise the Comanche Peak construction and inspection procedures from time to time.
When a set of procedures is revised, each page of the procedure in question is given a new revision number and a new effective or issue date, to ensure uniformity.
When a given page of procedures is given a new revision number and effective or issue date, that does not necessarily mean that the procedure on that page has been changed.
In this case, for example, as a comparison to Revisions 7, 8 and 9 shows, Section 4.1.1 of CCP-30 remained identical during the relevant period with respect to the near-white blast criterion.
C. Thom(s P Subscribed and sworn to before me this 7th day of May, 1984.
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Notar c
Mr Commis fort Expires rebruary s,1985
EFFECTIVE
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PROCEDURE NUMBER REVISION DATE PAGE BROWN & ROOT, INC.
CPSES 4 Of 17 JOB 35-1195
~CCP-30 7
5/7/81 After materials have bee'n a "first-in", "first-out" basis.
partially used from an individual container, the said container cannot be resealed and returned to "Q" storage area for later use.
Containers opened and partially distributed from the "Q" paint storage area may be resealed and the remaining contents used The contents from partially used containers for "Q" painting.
shall not be reused after a period of 7 days has elapsed from date of initial opening.
SPECIAL COATING PROCEDURE _
3.6 When items require special coating not covered under the content of this document, the appropriate Project Engineer (Mechanical, 3.6.1 Civil, Electrical) shall complete Attachment 2 and transmit it to the Paint Superintendent. A log of all procedures from shall be maintained by the Site Coating Engineer.
The following infonnation shall be completed on each precedure.
i The scope will Each procedure shall be given an unique number.
describe the working limits of the procedure with detailed 3.6.2 work requirements being listed under the requirements section.
The approvals section shall have signatures of the following:
Project Discipline Engineer (Mechanical, Civil, etc.), QA Manager if coating of item is safety related. TUSI representative L
when required, Engineer who prepared document, and a revision Upon completion of the document, distribution number and date.
shall be made to all holders of this procedure.
TOUCH-UP AND FINISH C0ATING OF VENDOR APPLIED COA 3.7 Prior to touch-up of primer or application of topcoat, an adhesion test shall be performed by the Brown & Ro 3.7.1 ment.
with sections 4.4.2.2 through 4.4.2.9.
The QC Inspector or his representative shall notify the res-ponsible area engineer and/or the Paint Superintendent as soon as 1.7.2 possible after receipt of a non-conforming item in need of paint repair to allow time for Attachment 2 preparation and a planned schedule for repair.
PROCEDURE FOR C0ATING 4.0 PREPARATION OF SUBSTRATES AND COATING MATERIALS 4.1 Surface Preparation for Primer - Under normal conditions, surface preparation shall not begin unless the temperature of the sur 4.1.1 to be blasted is 5 F above the dew point.
0 be primed shall then be cleaned of any heavy oil or greas in accordance with SSPC-SP-1-63 " Solvent Cleaning".
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PROCEDURE EFFECTIVE BROWN & ROOT, INC.
NUMBER REVISION DATE PAGE CPSES
-O 1
I JOB 35-1195 CCP-30 7
5/7/81 5 of 17 t
Small amounts of grease or oil depo' sits may be renoved by blast operations. The surface shall then be cleaned by blast, hand or j
power tool operations to achieve an equivalent of SSPC-SP10-63, "near white" blast cleaning. Although 1-3 mil. surface profile is preferred, a minimum of 1 mil profile is required. After the above surface preparation, the surface to be primed shall be air blasted and/or solvent wiped to remove dust, sand or t
foreign contaminants from ths surface. Air blasting shall not be performed where air-borni. contaminants could adhere to tacky i
paint.
Sufficient time shall be provided to allow suspended particles to settle before beginning primer application.
If rust l
forms after surface preparation, the rusted area shall be re-i cleaned before primer application. Under no case shall a blast, hand, or power tool cleaned surface be exposed for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to priming without additional cleaning of the sur-s face.
When applying coatings that will be joined together by a later coating operation, the int.criice shall be constructed as follows.
t Blasting using no border tape - Overblast the steel to near a.
white metal approximately 12" - 18" beyond the point which will receive primer. Hold back approximately 12" - 18" from
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edge of blasted area when applying primer.
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b.
Blast, hand or power tool cleaning using border tape - Clean the steel to near white metal approximately 3" - 6" beyond
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the point which will receive primer. Place border tape approximately 1" in from edge of cleaned area and prime.
When applying seal or finish coat on either of above methods j
hold back approximately 12" - 18" from edge of primer.
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l 4.1.2 i
Removal of weld spatter and other minor surface imperfections (not to exceed.031" for containment liners) - If needed, weld j
l spatter omitted by others will be removed by Painting Personnel in accordance with SSPC-SP-2 and SSPC-SP-3.
If it is determined that surface defects are severe enough to require later repair, the area to be repaired will be blocked out and spot painted at a later date. All edges, protrusions, and peaks shall be ground smooth to a rounded contour; 1/8-inch radius of the contour may be used for a guide.
4.2 SURFACE PREPARATION FOR FINISH COAT l
i 4.2.1 Surface preparation for the finish coat shall consist of the I
removal, if needed, of any oil or grease. This shall be ac-complished by use of a manufacturer recommended cleanser or l
cleansing method on areas that have been seal-coated. On areas where the Carbo Zinc 11 primer is exposed, oil and grease will I
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N-PROCEDURE EFFECTIVE t
BROWN & ROUT, INC.
NUMBER REVISION DATE PAGE CPSES i
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'J08'35-1195 l
- CCP-30 "8
.10/22/81 5'of 13 i
3.7 TOUCH-UP AND FINISH C0ATING OF VENDOR APPLIED COATINGS 3.7,1 Prior to touch-up of primer or application of topcoat, an
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adhesion test shall be performed by the Brown & Root QC Depart-l ment.
If results a're acceptable, work may proceed in accordance with sections 4.4.2.2 through 4.4.2.9.
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3.7.2 The QC Inspector or his representative shall notify the res-
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. ponsible. area engineer and/.or_the..Pa. int. Super _intendent as soon as. _..!
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possible after receipt of a nonconforming item in need of paint repair to allow time for Attachment 2 preparation and a planned j
schedule for repair.
j 4.0 PROCEDURE FOR COATING 1
4.1 PREPARATION OF SUBSTRATES AND COATING MATERIALS i
4.1.1 Surface Preparation for Primer - Final surface preparation shall ngt begin unless the temperature of the surface to be blasted.is i
5 F ebove the dew point.
If needed, the surface to be primed l
shall then be cleaned of any heavy oil or grease deposits in I
accordance with SSPC-SP-1-63 " Solvent Cleaning".
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Small amounts of grease or oil deposits may be removed by blast operations. The surface shall then be cleaned by blast, hand or power tool operations to achieve an equivalent of SSPC-SP10-63, "near white" blast cleaning. Although 1-3 mil. surface profile is preferred, a minimum of 1 mi.. profile is required. After the
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l above surface preparation, the surface to be primed shall be air blasted and/or solvent wiped to remove dust, sand or foreign
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l contaminants from the surface. Air blasting shall not be performed where air-borne contaminants could adhere to tacky paint. Suffi-cient time shall be provided to allow suspended particles to settle before beginning primer application.
If rust forms after i
surface preparation, the rusted area shall be re-cleaned before l
primer application. Under no case shall a blast, hand, or power l
tool cleaned surface be exposed for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to i
priming without additional cleaning of the surface. When applying
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coatings that will be joined together by a later coating operation, l
the interface shall be constructed as follows-l a.
Blasting using no border tape - Overblast the steel to near white metal approximately 12" - 18" beyond the point which will receive primer. Hold back approximately 12" - 18" frcm j
edge of blasted area when applying primer.
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EFFECTIVE
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FROCEDURE NUMBER REVISION DATE PAGE BROWN & ROOT, INC.
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CPSE3 JOB 35-1195 11/4/81.
5 of.13 CCP-30 9
TOUCH-UP AND FINISH C0ATING OF VENDOR APPLIED COAT 3.7 Prior to touch-up of primer or application of topcoat on vendor 3.7.1 coated items other than pipe hanger support components, an adhesion test shall be performed by the Brown & Root QC Depart-If results are acceptable, work may proceed in accordance ment.
with sections 4.4.2.2 through 4.4.2.9.
The QC Inspector or his representative shall notify the res-ponsible area engineer and/or the Paint Superintendent as soon as 3.7.2 repair to allow time for Attachment 2 preparation schedule for repair.
PROCEDURE FOR C0ATING 4.0 PREPARATION OF SUBSTRATES AND C0ATING MATERIALS 4.1 Surface Preparation for Primer - Final surface preparation shall not begin unless the temperat?re of the surface to be blasted.is 4.1.1 If needed, the surface to be primed 5 F above the dew point.
0 shall then be cleaned of any heavy oil or grease deposits in b
accordance with SSPC-SP-1-63 " Solvent Cleaning".
Small amounts of grease or oil deposits may be removed by blast The surface shall then be cleaned by blast, hand or operations.
power tool operations to achieve an equivalent of SSPC-S "near white" blest cleaning.
After the is preferred, a minimum of 1 mil. profile is required.
above surface preparation, the surfs.ce to be primed shall be air blasted and/or solvent wiped to remove dust, sand or foreignA contaminants from the surface.
Suffi-where air-borne contaminants could adhere to tacky paint.
cient time shall be provided to allow suspended particles to t
If rust forms after settle before beginning primer application.
i surface preparation, the rusted area shall be re-cleaned before Under no case shall a blast, hand, or power primer appitcation. tool cleaned surface be exposed for more tha priming without additional cleaning of the surface.
coatings that will be joined together by a later coating operation, the interface shall be constructed as follows:
Blasting using no border tape - Overblast the steel to near white metal approximately 12" - 18" beyond the point which a.
Hold back approximately 12" - 18" from will receive primer.
edge of blasted area when applying primer.
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PROCEDURE EFFECTIVE BROWN & ROOT, INC.
NUMBER REVISION DATE PAGE CPSES JOB 35]JJ95 "CCP-30 10 1/26/82 5 of 13 3.7 TOUCH-UP AND FINISH COATING OF VENDOR APPLIED C0ATINGS 3.7.1 Prior to touch-up of primer or application of topcoat on vendor coated itens other than pipe hanger support components, an adhesion test shall be performed by the Brown & Root QC Depart-ment.
If results are acceptable, work may proceed in accordance with sections 4.4.2.2 through 4.4.2.9.
3.7.2 The QC Inspector or his representative shall notify the res-ponsible area engineer and/or the Paint Superintendent as soon as possible after receipt of a nonconforming itan in need of paint repair to allow time for Attachment 2 preparation and a planned schedule for repair.
4.0 PROCEDURE FOR COATING 4.1 PREPARATION OF SUBSTRATES AND C0ATING MATERIALS 4.1.1 Surface Preparation for Primer - Final surface preparation shall not begin unless the tanperature of the surface to be blasted and/cr power tooled is 5"F above the dew point.
If needed, the surface to be primed shall then be cleaned of any heavy oil or grease deposits in accordance with SSPC-SP-1-63 " Solvent Cleaning".
e Small amounts of grea.se or oil deposits may be removed by blast operations. The surface shall then be cleaned by blast, hand or power tool operations to achieve an equivalent of SSPC-SP10-63, "near white" blast cleaning. Although 1-3 mil. surface profile is preferred, a minimum of 1 mil, profile is required. After the above surface preparation, the surface to be primed shall be air blasted and/or solvent wiped to remove dust, sand or foreign contaminants from the surface. Air blasting shall not be performed where air-borne contaminants could adhere to tacky paint. Suffi-cient time shall be provided to allow suspended particles to settle before beginning primer application.
If rust forms after surface preparation, the rusted area shall be re-cleaned before i
primer application. Under no case shall a blast, hand, or power tool cleaned surface be exposed for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to priming without additional cleaning of the surface.
When applying coccings that will be joined together by a later coating operation, the interface shall be constructed as follows:
white metal approximately 12<Durblast%he. steel to near Blasting using no border tape -
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18" beyond the point which will receive primer.
Hold back approximately 12" - 18" from edge of blasted area when' applying primer.
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1 QI-QP-11.4-1 3 MAY 2 9 1981 4 of 6
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3.3 POST BLAST CLEANING OPERATIONS 3.3.1 Blast Cleanup i
The inspector shall visually check the blasted substrate i
surface and adjacent amas for removal or control of l
1 abrasive and dust prior to start of final inspection.
l Criteria:
The surface shall be brushed or vacuumed to the extent required for final surface inspection. The adjacent areas shall be cleaned to the extent necessary to avoid j
contamination auring st.bsequent coating applications.
l 3.3.2 Blasted or _ Power Tooled Surface Acceptability l
The inspector shall perfonn the following inspections to 7
detennine acceptability of the blast cleaned or power tooled
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j su rface:
a.
Absence of Famign Matter -- A visual inspection shall be perfonned to detennine removal of foreign matter fran the surface.
Criteria:
l SSPC-SP10-63 l
The surface, when viewed without magnification, shall be fme of all oil, grease, visible mill scale, rust, 2
corrosion products, oxides, paint, or any foreign matter, except for light shadows, slight stmaks, or slight discolorations caused by mst stain, mill scale oxides, or slight, tight residues of paint.
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b.
Renoval of Sham Projections -- A reinspection for sham projections that were not blended (rounded) f during blast cleaning or power tooling shall be pe rfonned.
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Sham projections (including weld splatters) am not acceptable. _ See note on item 3.1,5 above regarding l
grinding v..i.6. to 11miove projections.
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INSTRUCTION I
REVISICN PAGE g
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CPSSS QI-QP-11.4-1 3 MAY 2 9 1981 5 of 6 1
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Anchor Pattern Depth -- The anchor pattern depth of the blasted or power tooled surface shall be inspected at randam locations using a Keane-Tator Surface Profile Caparator (model 373) or equivalent. A power tooled surface shall be inspected with use of either a roughness gage and/or caparator plate which has been approved by the coating manufacturer.
i Criteria :
Blast Cleaning SSPC-SP10-63T The anchor pattem depth for a blasted surface shall not be leis than 1S70 (minimum depth 1.0 mils).
Power tooling - Power Tooling (SSPC-SP3-63) may also l
be used with no Ama Restrictions, providing this type C
preparation produces an Acceptable Surface Caparable
' to SSPC-SP10-63T.
The Anchor Pattem Depth for a power tooled surface shall not be less than 1 mil. No maximum profile will i
i be specified, providing that correct millage requirements can be obtained after primer application.
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3.4 FINAL ACCEPTANCE l
i The inspector shall detennine that all FDRs and NCRs are cmplete prior to signing and dating Final Acceptance on checklist.
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CPSES QI-QP-11.4-1 4
OCT 2 3 1981 4 of 14 3.3 POST BLAST CLEANING OPERATIONS 3.3.1 Blast Cleanup The inspector shall visually check the blasted substrate surface and adjacent areas for removal or control. of abrasive and dust prior to start of final inspection.
The surface shall be brushed or vacuumed to the extent required for final surface inspection.
The adjacent areas shall be cleaned to the extent neces sa ry' to avoid conta:nination during subsequent coating applications.
3.3.2 Blasted or Power Tooled Surface Acceptability The inspector shall perfonn the following inspections to-determine acceptability of the blast cleaned or power tooled surface:
a.
Absence of Foreign Matter -- A visual inspection shall
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be perfonned to determine removal of foreign matter from the surface.
The surface', when viewed af thout :nagnification, shall be free of all oil, grease, visible mill scale, rust, corrosion products, oxides, paint, or any foreign matter, except for light shadows, slight streaks, or slight discolorations caused by rust stain, mill scale oxides, or slight, tight residues of paint.
b.
Removal of Sharp Projections A reinspection for sharp projections that were not blended (rounded) during blast cleaning or power tooling shall be pe-fo nned.
Sharp projections (including weld spatter) are not acceptable.
See note on item 3.1.5 above regarding grinding operations to remove projections.
c.
Anchor Pattern Depth -- The anchor pattern depth of the blasted or power tooled surface shall be inspected at random locations using a Keane-Tator Surface Profile Comparator (model 373) or equivalent. A power tooled surface shall, be inspected with use of either a roughness gage and/or comparator plate which has been approved by the coating manufacturer.
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4 INSTRUCTION ISSUE REVISION PAGE TEXAS UT1UTIES GENERATING CO.
'QI-QP-11.4-1 5
10/27/81 4 of 18 3.3 POST BLAST CLEANING OPERATIONS
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3.3.1 Blast Cleanup
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The inspector shall visually check the blasted substrate surface and adjacent areas for removal or control of abrasive and dust prior to start of final inspection.
The surface shall be brushed or vacuumed to the extent required for final surface inspection.
The adjacent areas shall be cleaned to the extent necessary to avoid contamination during subsequent coating applications.
3.3.2 Blasted or Power Tooled Surface Acceptability The inspector shall perfonn the following inspections to determine acceptability of the blast cleaned or power tooled surface:
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a.
Absence of Foreign Matter -- A visual inspection shall be perfonned to detennine removal of foreign matter from the syrface.
l The surface, when viewed without magnification, shall be free of all oil, grease, visible mill scale, rust, corrosion products, oxides, paint, or any foreign matter, except for light shadows, slight streaks, or slight discolorations caused by rust stain, mill scale oxides, or slight, tight residues of paint.
b.
Removal of Sharp Projections -- A reinspection for sharp projections that were not blended (rounded) during blast cleaning or power tooling shall be perfonned.
Sharp projections (including weld spatter) are not acceptable.
See note on item 3.1.5 above regarding l
grinding operations to remove projections.
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c.
Anchor Pattern Depth -- The anchor pattern depth of the I
blasted or power tooled surface shall be inspected at.
randm locations using a Keane-Tatar Surface Profile Comparator (model 373) or equivalent. A power tooled surface shall be inspected with use of either a roughness gage and/or comparator plate which has been approved by the coating manufacturer.,,,,,,,,
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INSTRUCTION ISSUE REVISION PAGE TEXA8 UTIUTIES GENERATING CO.
CPSES QI-QP-11.4-1 5
10/27/81 5 of 18 The anchor pattern depth for a blasted or power tooled surface shall be a minimum of 1.0 mils.
No maximum profile will be. specified, providing that correct millage requirements can be obtained after primer application.
3.3.3 Unique Number Identification After blasting and prior to prime coat application, QC shall verify that construction has identified each peice with a unique number in accordance with References 1-A and 1-8.
The QC Inspector shall maintain a Protective Coatings Unique Identification Number Log, Attachment 1 for all protective coatings application on all steel designated for use in the.
Reactor Building.
Subsequent subdivision of coated steel in the field or shop shall be verified by QC in accordance with Reference 1-C.
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NOTE:
Unique number ma[ be assigned to a lot of material to be prime coated at the same time.
For example, six pieces steel to be coated at same time may all have same unique number.
Equipment which is identified with a pennanent plant identification number nead not be identified with a Protective Coatings unique Identification Number.
The term
" Equipment" is not to include pipe hangers, cable tray hangers, conduit supports, or structural steel. They will all have Protective Coating unique Identification Numbers assigned.
3.4 PRIMER PRE-APPLICATION INSPECTIONS l
3.4.1 Ambient Conditions Inunediately prior to primer application, the QC Inspector shall detemine air tempera ture, surface temperature, relative humdity and dew point using methods described in Section 3.1.1.
Nonnal conditions of ambient and surface temperatures shall
- be 40-95*F and 40-110*F, respectively.
In no case shall Carboline limits (0-130*F ambient temperature. 0-200*F surface temperature) be exceeded.
Carbo-Zine-11 may be Q
thinned up to 2 quarts per gallon per application.
When using higher ttwrual levels at or below normal temperature.
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CPSEs i
QI-QP-11.4-1 6
gy 10 1981 3 of 17 The surface shall be brushed or vacuumed to the extent required for final surface inspection. The adjacent areas
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shall be cleaned to the extent necessary to avoid contamination during subsequent coating applications.
3.2.2 Blasted or Power Tooled Surface Acceptability The inspector shall perfom the following inspections to detemine acceptability of the blast cleaned or power tooled surface:
a.
Absence of Foreign fatter -- A visual inspection shall be perfomed to -detemine removal of foreign matter from the surface.
The surface, when viewed without magnification, shall be free of all oil, grease, visible mill scale, rust, corrosion products, oxides, paint, or any foreign
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matter, except for light shadows, slight streaks, or
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slight discolorations caused by rust stain, mill scale oxides, or slight, tight residues of paint.
b.
Removal oi' Sharp projections -- A reinspection for sharp projections that were not blended (rounded) during blast cleaning or power-tooling shall be perfomed.
Sharp projections (including weld spatter) are not acceptable.
Protrusions and peaks shall be ground to a rounded
- contour.
1 NOTE:
Any mechanical surface preparation other than sandblasting or hand or power tooling of sharp edges or weld spatter will require a B&R NDE visual' inspector's acceptance of i
the work perfomed.
c.
Anchor Pattern Oepth -- The anchor pattern depth of the I
blasted or power tooled surface shall be inspected at l
random locations using a Keane-Tator Surface Profile f
Comparator (model 373) or equivalent. A power tooled surface shall be inspected with use of either a roughness gage and/or comparator plate which has been approved by the coating manufacturer.
b INSTRUCTION ISSUE REVISION NUMBER OATE PAGE TEXAS UTluTIES GENERATING CO.
CPSES QI-QP-11.4-1 6
(f0V 10 1981 4 of The anchor pattern depth for a blasted or power tooled surface shall be a minimum of 1.0 mils.
No maximum profile will be specified, providing that correct millage and surface unifomity requirements can be obtained after primer application.
3.2.3 Unioue Number Identification After blasting and prior to prime coat application, QC shall verify that construction has identified each peice with a unique number in accordance with References 1-A and 1-8.
The QC Inspector shall maintain a Protective Coatings Unique Identification Number Log, Attachment 1 for all protective coatings application on all steel designated for use in the
. Reactor Building. Subsequent subdivision of coated steel in the field or shop shall be witnessed by QC in accordance l
with Reference 1-C.
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' NOTE:
Unique number may be assigned to a lot of material to be prime coated at the same time. For example, six pieces steel to be caated at same time may all have same unique number.
Equipment whicP is identified with a permanent plant identification number need not be identified with a Protective Coatings unique Identification Number.
The tem
" Equipment" is not to include pipe hangers, cable tray
- hangers, conduit supports, or structural steel. They will all have Protective Coating unique Identification Numbers assigned.
3.3 PRIMER PRE-APPLICATION INSPECTIONS 3.3.1 Ambient Conditions
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Immediately prior to primer application, the QC Inspector shall detemine air temperature, surface temperature, relative humdity and dew point using methods described in Section 3.1.1.
Nomal conditions of ambient and surface temperatures shall be as follows:
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. TuxAs t/71uTIES GDIERATING Co.
CPSE8 QI-QP-11.4-1 7
E2 151 3 of 10 i
3.2 POST BLAST CLEANING OPERATIONS 3.2.1 Blast CleanUD The inspector shall visually check the blasted substrate surface.
The surface shall be brushed or vacuumed to the extent required for final surface inspection.
The adjacent areas shall be cleaned to the extent necessary to avoid contamination during subsequent coating applications, 3.2.2 Blasted or Power Tooled Surface _ Accutabilitv The inspector shall perfonn the following inspections to detennine acceptablitty of the blast cleaned or power tooled surface:
4.
Absence of Foreign Matter -- A visual inspection shall be performed to detemine reoval of foreign r.atter from the, surface.
The surface, den viewed without segnification, shall be free of all oil, grease, visible mill scale, rust, corrosion products, oxides, paint, or any foreign matter, except for light shadows, slight streaks, or l
slight discolorations caused by rust stain, mill scale oxides, or slight, tight residues of paint.
b.
Renoval of Sharp Projections -- A reins action for sharp projections that were not blende<. (rounded) during blast cleaning or power tooling shall be pe rformed.
Sharp projections (including weld spatter) are not acceptable.
Protrtisions and peaks shall be ground to a rounded contour.
NOTE:
Any mechantcal surface preparation other than sandblasting or hand or power tooling of sharp edges or weld spatter will require a 84R NDE visual inspector's acceptance of the work performed.
1
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INSTR ON REVISION TEXAS UTIUTIES GENERATING CO.
PAGE CPSES QI-QP-11.4-1 7
DEC 2 E
- ..a 4 of 10 Anchor Pattern Depth -- The anchor pattern depth of the c.
blasted or power tooled surface shall be inspected at random locations using a Keane-Tator Surface Profile Comparator (model 373) or equivalent. A power tooled surface shall be inspected with use of either a roughness gage and/or comparator plate which has been approved by the coating manufacturer.
The Anchor pattern depth for a blasted or power tooled surface shall be a minimum of 1.0 mils.
No maximum profile will be specified, providing that correct millage and surface unifamity requirements can be obtained after primer. application.
3.2.3 Unique Number Identification After blasting and pri'r to prime coat application QC shall verify that construction has identified each peice with a unique number in accordance with Referentes 1-A and 1-B.
/
The QC Inspector shall maintain a Protective Coatings Unique Identification Number Log, Attachment 1 for all protective coatings application on all steel designated for use in the Reactor Building.* Subsequent subdivision of coated steel in the field or shop shall be witnessed by QC in accordance with Reference 1-C.
NOTE:
Unique number may be assigned to a lot of material o to be prime coated at the same time.
For example, six pieces steel to be coated at same time may all have same unique number.
Equipment which is identified with a permanent plant identification number need not be identified with a i
Protective Coatings unique Identification Number.
The term
" Equipment" is not to include pipe hangers, cable tray hangers, conduit supports, or structural steel. They will all have Protective Coating unique Identification Numbers assigned.
3.3 PRIMER PRE-APPLICATION INSPECTIONS 3.3.1 Ambient Conditions ~
- Immediately prior to primer application, the QC Inspector shall detemine air temperature, surface temperature, i
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TEXA8 UT1UT155 QENERATING CO.
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3.2 POST BLAST CLEANING OPERATIONS 3.2.1 81ast Cleanun The inspector shall visually check the blasted substrate surface.
The surface shall be ' brushed or vacuumed to the extent l
required for final surface inspection.
The adjacent areas shall be ' cleaned to the extent necessary to avoid contami ation during subsequent coating applications.
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i 3.2.2 Blasted or power Tooled Surface Accentability The inspector shall perfore the following inspections to detensine acceptability of the blast cleaned or power too, led surface:
a.
Abstoce of Foreign Matter A. visual inspection -
shall be perfonned to determine' that all oil and I
grea se, dirt, millscale, rust, corrosion products,
- oxides, paint or 'other foreign matter have been completely rueoved' from the surface except for light
- shadows, very sfight streeks or sti ht.
discolorations caused by rust stains, mill sea e,
- oxidas, or
- slight, tight residues of paint or coati,1g that may remain.
At least 95 percent of each square inch of surface area shall be free of all residues, and the remainder shall be limited l
to itght discolorations as mentioned above.
i HEg:
If coating rusoval is required fran an area or item which has been coated in i
accordance with this instruction, shadows or tight residues. of primer which may remain in the profile. of the previousty' prepared substrate is acceptabla, b.
Renoval of Sharp Projections -- A reinspection for sharp projections that, were not blended (rounded) during blast cleaning or power tooling shall be perforied.
Wald. splatter on strvetural steel shall be removed l
by either rinding or sand blasting. 'However, if g*
the weld 's latter should 2 remain af ter the above
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operation, the weld splatter will be acceptable.
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Sharp projections 4re not acceptable.
l Pmtmsions and pInsks shall be greesd to a rounded contour.
NOTE:
Any mec'hanical surface properetton other than sand 61asting or hand or power tooling of sharp edges or wid spatter will require a visual welding inspector's acceptance of
(
the work performed, c.
Anchor Pattern Depth -- The anchor pattern depth of the blasted or power tooled surface shall be inspected at rendom locations ustn a Xeano-Tator Surface Pmfile Comparator (model 373?; or equivplant. A power tooled i
surface shall be inspected with use of either a roughness gage and/or equivalent.
The anchor pattern depth for a blasted or power tooled surface shall be a sinimum of 1.0 mils.
No maxfsud profIla will be specified, providing that cornct mil' age and surface untforwity requf riments can be cotained after primer appitention.
3.2.3 Unfaue M r Identification After blasting oower tool and prfor to prime coat application, QC shall verify that construction has identified each peice with a unique number in accordance with References 1-A and 1-8.
The QC Inspector shall maintain a Protective Coatings Unique Identification Number Log. Attachment I for all pmtective coatings application on all steel designated for use in the Reactor Butiding. Subsequent subdivision of coated steel in the field or shop shall be witnessed by QC in accordance
. with Reference 1-C.
33,:
A.
Unique number may be assigned to a lot of material i
to be prime coated at the same time.
For example, six pieces staal to be coated at same time say all have same ustque number,
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
"*4 In the Matter of
)
)
TEXAS UTILITIES ELECTRIC
)
Docket Nos. 50-445 and COMPANY, et al.
)
50-446
)
(Comanche Peak Steam Electric )
(Application for Operating Station, Units 1 and 2)
)
Licenses)
CERTIFICATE OF SERVICE I hereby certify that copies of the foreging " Applicants' Motion For Summary Disposition Of Near-White Blast Surface Preparation Issue," in the above-captioned matter were served upon the following persons by overnight delivery
(*), or deposit in the United States mail, first class, postage prepaid, this lith day of May 1984, or by hand delivery (**)
on the 13th day of May 1984:
- Peter B.
Bloch, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety Licensing Appeal Panel and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Rogulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. William L. Clements
- Dr. Walter H. Jordan Docketing & Service Branch 881 West Outer Drive U.S. Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C.
20555
- Dr. Kenneth A. McCollom Dean, Division of Engineering ** Stuart A. Treby, Esq.
Architecture and Technology Office of the Executive Oklahoma State University Legal Director Stillwater, Oklahoma 74074 U.S. Nuclear Regulatory Commission Mr. John Collinn Washington, D.C.
20555 Regional Adminis trator, Region IV Chairman, Atomic Safety and U.S. Nuclear Regulatory Licensing Board Panel Commission U.S. Nuclear Regulatory 611 Ryan Plaza Drive Commission Suite 1000 Washington, D.C.
20555 Arlington, Texas 76011 m'M-
"-~w-r
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]
Renea Hicks, Esq.
- Mrs. Juanita Ellis Assistant Attorney General President. CASE Environmental Protection 1426 South Polk Street Division Dallas, Texas 75224 P.O. Box 12548 Capitol Station
- Ellen Ginsberg, Esq.
Austin, Texas 78711 Atomic Safety and Licensing Board Panel Lanny A. Sinkin U.S. Nuclear Regulatory 114 W. 7th Street Commission Suite 220 Washington, D.C.
/
/
heL Nicholas S.
Iteynolds G) cca Homer C. Schmidt Robert A. Wooldridge, Esq.
David R. Pigott, Esq.
9' M
.