ML20092J806

Affidavit of CT Brandt Re Max Roughness Surface Preparation Issue.Certificate of Svc Encl

ML20092J806
Person / Time
Site:	Comanche Peak
Issue date:	06/08/1984
From:	Brandt C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20092J798	List: ML20092J795 ML20092J800 ML20092J806
References
NUDOCS 8406270134
Download: ML20092J806 (20)

Text

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r UNITED STATES OF AMERICA ';

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )

)  !

TEXAS UTILITIES ELECTRIC ) Dockets Nos. 50-445 and COMPANY, et al. ) 50-446 r 1

)

(Comanche Peak Steam Electric ) (Application for .

Station, Units 1 and 2) ) Operating License)

AFFIDAVIT OF C. THOHAS BRANDT REGARDING MAXIMUM ROUGHNESS SURFACE PREPARATION ISSUE 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 the question of the maximum

, roughness of steel substrate when it is prepared for coating g with primer. Robert Hamilton testified that Steel Structure (i

Painting Council specifications for near-white blast call for a surface profile from 1 to 3 mils, and that Comanche Peak procedures do not specify a maximum profile (CASE Ex.

653 at 16). Mr. Hamilton perceived this to be a problem because, in his view, "[t]he rougher the surface is, the earlier the paint will break down."

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. The Procedures Section 4.1.1 of Comanche Peak construction procedure CCP-30, " Coating Steel Substrates Inside Reactor Building and Radiation Areas," provides that "[a]lthough 1-3 mil.

surface profile is preferred, a minimum of 1 mil. profile is required." As Mr. Hamilton states, no maximum profile is specified.

Methods of Surface Preparation Applicants' personnel prepare steel substrates in three alternative ways: sandblasting; power tooling; and hand sanding. Power tooling includes the use of flapper wheels, 3-M Clean 'n' Strip disks (used with a rotary power tool),

and belt sanders.

Sandblasting All steel substrate inside containment, including the liner plate and all structural steel, was originally prepared for primer coat by sandblasting. Applicants utilize power tooling only for repair or rework. The major part of the total area of all safety-related coating surfaces, the re fore , were prepared by sandblasting.

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• For sandblasting, Applicants use No. 3 blasting sand, which is a coarse sand. Attached to this affidavit (Attachment A) is a copy of Steel Structures Painting Council (SSPC) Surface Preparation Specification No. 10, Near-White Blast Cleaning (commonly referred to as SP-10).

The Appendix (A.4) to SP-10 provides a table that details the maximum achievable surface profiles normally achievable using each of several blasting media. According to SP-10--

t the specification on which Mr. Hamilton relies--the maximum height of the profile normally-achieved by blasting with large sand will be 2.8 mils. The use of finer sands for blasting will produce smaller maximum profiles. According to the specification, therefore, Applicants will normally achieve a maximum profile height of 2.8 mils for steel substrate surfaces prepared by sandblasting.

Even if sandblasting were to produce a surface profile in excess of 2.8 mils, there would be no loss in the integrity of the primer coating. Mr. Hamilton's allegation l I

that "the rougher the surface is, the earlier the paint will break down" is incorrect. To the contra ry, the rougher the surface--the greater the profile depth--the greater the adhesion of the coating to the substrate. This is so because a higher profile produces more total surface area to which the coating material may adhere. The very purpose of

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sandblasting (and other forms of surface preparation) is, after all, to create microscopic peaks and valleys in the steel surface to enhance the adhesion of the primer coat.

The foregoing has been confirmed independently by the coatings manufacturer. Applicants consulted'with the manufacturer of the primer coatings (Carbo Zinc 11, or CZ-

11) used at Comanche Peak regarding the procedures for steel substrate surface preparation. Regarding maximum surface profile, the manufacturer, Carboline Company, has advised Applicants that no maximum surface profile need be specified on certain conditions (Attachment B to this affidavit):

On the specification as you explained it to me there is no maximum limit on the profile. This is acceptable to Carboline provided a specific blast media is called for thus limiting the l actual blast profile achieved and that the primer used completely covers the profile achieved in the field.

Applicants meet each of the two Carboline conditions.

e The blasting medium used at Comanche Peak is coarse sand, which as discussed above, limits the maximum height of profile according to SP-10. Applicants' procedures also assure that the steel substrate is covered completely.

Assuming, for example, a steel surface profile in excess of 3 mils, and further assuming a primer coating insufficient L to completely' cover the microscopic peaks in the steel l

! surface, the exposed steel peaks would oxidize, causing a phenomenon known as " pinpoint rusting." Pinpoint rusting is I easily identified in a coated surface. Under section 3.3.3 i

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• of Applicants' quality instructions QI-QP-11.4-5, "Inspec-tion of Steel Substrate Primer Repair and Seal and Finish Coat Application and Repair" (Attachment C to this affidavit), this surface condition would be identified as

" contamination" during inspection prior to the application of the top coat, which would then be rejected and repaired or reworked. The surface must then be reinspected prior to application of top coat.

Power Tooling Applicants use several different power tools to prepare steel substrate. Power tools are generally used in connection with repair work. Applicants use four power tools (or accessories) to prepare steel substrate surfaces a flapper wheel, which is a rotary device used with 60 Grit sandpaper; a 3-M Clean 'n' Strip, an abrasive nylon pad, also used with a rotary power tool; a belt sander, which Applicants use with a 36 Grit sandpaper; and a needle gun, a pneumatic tool that scores the surface being prepared.

Applicants have prepared test panels using each of these power tools. Attachment D to this affidavit is a memorandum detailing the heights of profile achieved by each method. The tests showed the following maximum profiles for the corresponding power tools:

..- 60 Grit Flapper Wheel 1.5 mils 3-M clean 'n' Strip 1.8 mils Belt Sand 36 Grit 2.0 mils Needle Gun 2.7 mils The majority of the individual readings showed lower surface profiles.

It is my opinion that these tests are sufficient to demonstrate that, with the power tools in use at Comanche Peak, Applicants cannot produce a surface profile in excess of 3 mils. The physical properties of the abrasive materials, for example, can abrade the steel surface just sc much', and no further; using an endless supply of sandpaper on.the belt sander, for example, one would theoretically sand a steel surface down to nothing. At all times, however, the maximum height of,the surface profile would not exceed 3 mils.

Hand Sanding For certain small or hard-to-reach areas, Applicants hand sand steel substrate prior to primer application.

Applicants have also performed tests to determine the maximum profile achieved by the hand sanding. The maximum profile achieved with hand sanding was 1.75 mils (see

. _7-Attachment D). Again, my judgment is that these tests demonstrate that maximum profile achievable by hand sanding will not exceed 3 mils.

Consistency of the Procedures with the Specification Mr. Hamilton alleged, with respect to surface profile, that "[t]he specification calls for a near-white blast, which is defined in the Steel Structure Painting Council specifications as being from a 1 to 3 mill [ sic] profile."

Mr. Hamilton incorrectly describes the specification.

Section 3.8 of SSPC-SP-10 (Attachment A, p. 2), by which Applicants are bound, does not specify a maximum profile height by millage. Rather, it provides: "The height of profile of the anchor pattern produced on the surface shall be limited to a maximum height that will not be detrimental to the life of the paint film." Applica nt s' specification AS-31 (protective coatings) further provides that: "The proper abrasive for sandblasting required to obtain the specified profile (anchor pattern) as designated in the coating manufacturer's latest application instruction shall be used." Applicants original procedural requirement that surface preparation produce a 1-3 mil profile was excerpted from a product data sheet provided by Carboline, the manufacturer (see Attachment E), not SSPC-SP-10 as Mr.

Hamilton had stated. As discussed above, Carboline has

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• accepted Applicants' procedures governing steel substrate surface preparation. Applicants' procedures are consistent f L

with Sp-10 and Applicants' specifications.

In sum, Applicants' use of sandblasting, power tooling, and hand sanding should not achieve a surface profile in excess of 3.0 mils. Assuming that surface preparation produces a profile in excess of 3 mils, and that the applied primer does not cover the peaks in the profile, pinpoint rusting would occur and be identified and corrected during f normal QC inspection. The defective surface would be reworked to acceptable standards. Applicants' procedures regarding surface profile are fully consistent with SSpC specifications, Applicants' AS-31 coatings specifications, and manufacturer's recommendatio .

C. Inomas Bqhpdt ,

Subscribed and sworn to before me this /* b day of June, 1984.

- ( a u p m h u vy n, Dsi notary public

C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 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 foregoing " Applicants' Motion For Summary Disposition of Maximum Roughness Surface Preparation Issue,"'in the above-captioned matter were served upon the following persons by overnight delivery (*), or depo' sit in the United States mail, first class, postage prepaid, or by hand delivery (**) , this 25th day of June 1984:

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• • Peter B. Bloch, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety Licensing Appeal Panel and Licensing ~ Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory 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 i Washington, D . C .' 20555

• Dr. Kenneth A. McCollom

• Dean, Division of Engineering ** S tuart A. Treby, Esq.

Architecture and Technology Office of the Executive i -Oklahoma State University Legal Director Stillwater, Oklahoma 74074 U.S. Nuclear Regulatory i' Commission Mr. John Collins Washington, D.C. 20555 Regional Administrator, 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 l

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i Renea Hicks, Esq.

• Mrs. Juanita Ellis Assistant Attorney General President, CASE .

Environmental Protection 1426 South Polk Street Division D.allas, Texas 75224 i 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. 20555  !

Austin, Texas 78701 [

6 Nichol i S.' peynolds b

cc: Homer C. Schmidt Robert A. Wooldridge, Esq.

David R. Pigott, Esq.

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Atta hment A i

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~ ' ~ Editorisi cliengen January 1,1971 f-Steel Structures Painting Council Surface Preparation Specifications  !

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.No.10 Near-White Blast Cleaning. . .

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3.. Procedures s

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1. Scope 1.1 This specification covers the procedure required 3.1 Near-White Blast Cleaning shall consist of the l for the Near-White Blast Cleaning of structural following sequence of operations:  ;

i steel surfaces prior to painting or coating.

3.1.1 Heavy deposita of oil or grease shall be l removed by the methods outlined in Spec. SSPC-E SPI-63, " Solvent na-aine." Small quantities of

2. Definition oil or grease may be removed by the blast cleanine i 2.1 Near-White Blast Cleaning is a method of pre .' operation. If oil and grease are removed by blast  !

paring metal surfaces for painting or coating by re- cleaning, the abrasive shall not be reused if such  :

moving nearly all mill scale, rust, rust-scale, paint, reuse is detrimental to the curface. .

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or foreign matter by the use of abrasives propelled 3.1.2 Mn mty may be remoW by E through nonles or by centrifugal wheels. to the impact tools, as outlined m Spec. SSPC-SP 2-63, .

degm Wenpeci6ed. . . _.

" Hand Tool Cleaning," or SSPC-SP 3-63, "P6wer  !

Tool Cleaning" or by special blast cl aning equip-2.2 A Near White Blast Cleaned Surface Finiah "*""*

is de6ned as one from which all oil, grease, l~ .

dirt, mill scale, rust, corrosion products, 3.1.3 The surface shall be blast cleaned to a oxides, paint or other foreign matter have Near White Finish by any one of the following I been completely removed frem the surface methods: .

except for very light shadows, very slight 3.1.3.1 Dry sandblasting using compressed air streaks or slight discolocations caused by rust blast nonles and dry sand of a marimum particle E stain, mill scale oxides, or slight, tight resi-dues of paa. n t or coating that may remain. At sue no larger than that passing through a 16 mesh scan, U. S. h seria least 95 percent of each square inch of surface area shall be free of all visible residues, and 3.1.3.2 Wetorwater-vaporsandblastingusing the remainder shall be limited to thelight dis- compressed air blast nonles, water and sand of a coloration mentioned above. Photographic or maximum particle size no larger than that passing other visual standards of surface preparation through a 16 mesh screen, U. S. sieve series.

E may be used as provided in the Appendix to 3.1.3.3 Grit blasting using compressed air modify or further de6ne the surface if speci- blast noules and crushed grit made of cast iron, 6ed in the contract. malleable iron, steel, or synthetic grits other than I 2.3 The over-all blast cleaning effort expended sand, of a mavimum particle size no larger than that thrash a 16 inesh scmn, U. S. sien seria, (nozzle time) shall be not less than two-thirds (H) of that which would be required to produce a Whita " The largest ca==arcial grade of metal grit per ted by this *nacification is SAE No. G-25 abrasive I Metal Surface Fim,ah on the same surface; nor .

should more than ninety-Sve percent (957o) of such '"***"*k _' .

1 l3.1.3.4 Shotblastingusingcompressedairnoz-effort be required. ' Ibis limitation shall not be con-strued as a waiver of any of the above require ' 'ziesind c' est irou, malleable iron, steel, or synthetic E .. menta. . . . _ . , . , , . , , .. _ ., . ,y. m. , . shot of a manmum sise no I,arger than tha,t passing

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' largeefc5uneElaTgrade permitted by this specift 3.7 The Mast cleaned surfam P abaB be a===ined for?

cati 6n is SAE'Nk S-3303. .u,.w ' any traces of oil, grMos suiudgeE If present7 4

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pa 3.1.3.5 Closed, recirculating nosale Nasting 163," Solvent Cleaning.'" '

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ceding compressed air, vacuum, and any of the pre.y.- 3.8 The height of profile of the anchor

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- ' * ' ' doced on the surface shall be limited to a maximum 3.1.3.6 Grit Nasting using centrifugal wheels height that will not be detrimental to the life of the and crushed grit made of cast iron, m.11,.hra iron, paint Sim. The maximum particle sizes specified in steel, or synthetic grits of a marimum particle size paragraphs 3.1.3.1 to 3.1.3.7 may produce an anchor no larger than that passing through a 16 mesh pattern that is too high or too rough for the paint screen, U. S. sieve series. The largest commercial system to be used. In such cases the abrasive sizes grade of metal grit permitted by this specification is should be reduced. If the application of the second SAE No. G-23. cost of paint is deferred, an adequate reduction in anchor pattern height shall be made.

3.1.3.7 Shot blasting using centrifugal wheela and cast iron, malleable iron, steel, or synthetic shot 3,9 The height of the anchor pattern can be deter-of a maximum particle size no larger than that pass- mined by grinding a flat spot on the blasted surface l

ing through a 16 mesh screen, U. S. sieve series. until the bottoms of the pita are almost reached. '

The largest commercial grade permitted by this The height may then be measured with a microme-s cation is SAE No. S-330. ter depth gauge graduated to read 0.001' and with a bene having a bearing length of two inches and a 3.2 e surface, if dry blasted, shall be brushed Inesauring red of 3/32' diameter.

wi clean brushes made of hair, bristle or fiber, or ,

own of with compressed air (from which detri- 3.10 The Nast cleaned surface should be further  !

mental oil and wa ter have been removed), or cleaned treated or primed, as specified in the agreement by vacuum, for the purpose of removing any traces covering the work, preferaNy within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after of blast products from the surface, and also for the blast clanning when practicaNe, but in any event removal of abrasive from pockets and corners. before any visible or detrimental rusting occurs.

(See Section 3.6 and Appendix A.7) .

3.3 The surface, if wet sandblasted. shall be cleaned by rinsipg with fresh water to which sudicient cor- " Where chemical contamination of the surface may occur, the steel should be painted as soon as rosion inhibitor has been added to prevent rusting, possible after blast clanning.

or with fresh water followed immediately by an '

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inhibitive treatment. This cleaning shall be supple-mented by brushing, if necessary, to remove any .

4. Safety Precautions ,

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4.1. If fire or explosion ha-ds are present, proper 3.4 The compressed air used for nozzle Masting- precautions shall be taken before any work is done.

shall be free of detrimental amounta of condensed If b smm Musly mid A-W water or oil. Adequate separators and traps shall materials, it shall be purged of dangerous concen-be provided. trations.

I 3.3 Blast cleaning operations shall be done in such 4.2 Nozzle Nast operators exposed to blast dust a manner that no damage is done to partially or shall wear a U. S. Bureau of M es approved helmet entirely completed portions of the work. c nnected to a source o ears, compressed air.

3.6 Dry blast clegning operations shall not be con.

4.3 Filter type air respirators shou'd be worn by ducted on surfaces that will be wet after blast clean. all others who are exposed to Nast dust environ-ing and before painting, or when ambient conditions ment. Adequate protection for personnel from flying are such that any visible rusting occurs before particles shall also be provided in any Nasting

painting or casting. s operation.

If any rust forms after blast cleaning, the sur-4.4 Safety guggles shall be worn by all pe~rsons near fece shall be reblast cleaned before painting. ,

any Nasting operation. .

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E... SURFACE PRIFARATION SPECIFICATIONS 4.5 Blast home shall be grounded to dissipate static the removal of the old paint be carried back amand charnes. , w_. c . - . 2 the edges of the spot or area until an area of com-g '

w ,, - , , - - . , , ' ,, plately intact and adhning paint fihn, with m at

5. Inspection w bihan undenseth,is a"=iaad Ega of tightly adherent paint remaining amand the area to be I 5.1 All work under this speciSation shall be sub. - recosted must be feathesed, so that the repainted jeet to inspection by the owner or his representative. surface can have a ==aaeh appearance. M remain-All parts of the work shall be am-ihla to the in- ing old paint abould have =&iant adhasian so that E spector. 'Ihe contractor shall correct such work as is it cannot be lifted as a layer by inserting a blade d found defective under the 5 ific=tions. If the con- a duH putty knife underit. 'Ihe rate of blast claan-tractor does not agree with the ia p-w, the arbi- ing may vary from one area to b next, in order to tration or settlement procedure eeuhlinhad in the - achieve & desired end condition.

contract, if any, shall be followed. If no arbitration +- ' ** * -- '"\

or settlement procedure is esuhahad b proce. A.4 h madmum pemiamihla size of the abraarve dure sI=4=1 by the American Arbitration Associa- Particles will depend upon the allowable surface E tion shall be used. roughness or "madmum height of profde" of the surface; the allowable marimum height of profile A p p a h. is, in turn, dependent upon the thickness of paint E A.1 SCOPE. & recommendations contained in to be applied.

this appendix are believed to represent current good The mad =m height of profile is the height of practice, but are not to be considered as require- the anchor pattern predomd on the surface, ma==ne-I menta of h specification. ing fmm the bottoms of the lowest pits to the tops

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of the highest paaka. 7 A.2 Near-White _B'last Cleaning should be em- . . ..~ .. m a . n -. .. ~,

..mi. 4 Pl oyed for all general purposes where a high degree A typical mexica'am' height of of blast cleaning is required. It will remove prac- duced by a number of different sifrasives inrofile '. pro-tically all rust, mill scale, and other detrunental actual blast cleaning operations has been matter from the stirface.-The surface will not neces- measared as follow t :

I sarily be completely uniform in color, nor will all surfaces be uniformly clean. If the claaning when ri,,,,;,,

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done according to this specification is likaly to re-sult in a surface unsatisfactory to the owner or un- Sand, very fine through 80 mesh

• 1.5 mils I suitable for very severe service, then White Metal Sand, fine . through 40 mesh 1.9 Blast Cleaning should be specified by the owner in Sand, media through 18 mesh 2.5 the contract. The advantage of Near-White Blast Sand, large through 12 mesh 2.8 E Cleaning lies in the lower cost for surface prepara- **SL'el grit fG.80 through 40 mesh 1.3-3.0 tion that is satisfactory for all but the most severe *** Iron grit fG-50 through 25 mesh 3.3 service conditions. Iron grit fG-60 through 18 mesh 36 E A.3 When this specification is used in mainte-Iron grit fG-25 Iron grit fG-16 through 16 mesh through 12 mesh 4.0 8.0 n nce painting, specific instructions should be given ** Steel shot fS.170 through 20 mesh 1.8-2.8 on the extent of surface to be blast cleaned in ac- Iron shot fS.230 through 18 mesh 3.0 I cordance with'this specification and the amount of Iron shot /S-330 through 16 mesh 3.3 spot cleaning required. In maintenance painting it Iron t. hot fS-390 through 14 mesh 3.6 is not ordinarily intended that sound, adherent old 88 0*'" . A**0peraung mMen.

paint be removed unless it is excessively thick or I- inflexible.

Cr comparator available from

,,J 'ushed aron grit. SS PC is u s e f ul in e s tima ting sand blast profile depta.

I In preparing a previously painted surface, it is necemary to remove all corrosion and all paint which shows evidence of wrrosion, peeling, exces-Maximum profile will vary somewhat with the angle and velocity of particle, with the hardness of surface, with the amount of recycling of working sive thickness, brittleness, blistering, checking, .- mixtures (of shot and grit) and with the thorough-scaling or general disintegration. It is essential that ness of blast cleaning. .

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! 2.Mo(tilt.'gie,.hy paint.Smi,thiekases Sa abeeld,pqualthe thiekaan known to e*above this peaka e:t should not boica l  ; # ,.be.needed.over a smooth,sussese.Ar the deded . A, . g.- .

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nunates to weeks) frean amo enviremament to -

S press, h dry point Sun thinkmem abodd be in. another,in ouder that the nefece remain hoe of car.  !

wA h above h remion, oil, etc. as aquired by Sections 3.6, 3.7, and peaks. - - . ..: . 1 m , "

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3.10. If a ==3-intervalis desired it shaR be so i

'Peci8ed in the contract covering the work. ]

A.6 AsaltableinhabitivdNtforllastel=anant I surfaces is water containing 0.32 per aunt of sodiumn A.s P%-7 standards of comparises may be l nitrite and 1.28 per cent by weight of asumoiiums used to denne the Anal surface ooedities to be sup. i phosphate, e- d y (dibasic), or es as alt enate plied under this ,

"" For partially rusend '

water containing about 0.2 per cent by weight of mill seale, for compistely rusend min scale, or for

(a) chroanic acid or (b) sodiesa chromante or (c) so. compleanly reseed and pitted surfaces, the appearance

' dium dichremste or (d) potensiums dichromate. of the surface after Nar White Bime Clemains should Note: If solutione containing either chronistes or cormpond with pictorial ==ada ds B Sa 2M, C Sa dichromates an used, pneautinen should be ukes 2M and D Sa 2M of SSPC Vis167T. As additional standards become availabia, these anny be incladad by i

g p ,,,,,g g,,,, i.asseds medting 6cm breathing spray or contacting the =.n-q=.

h is b eenema.

A.7 % blast cienned earface must be tasted or 'Ihe color of the cleaned smimos may be ad' acted l primed before any rusting occure. Otherwise the by the natum of the abrealve used. f beneat of the Near-White Blast Clemming is lost. A.9 Other visual standards of surface preparation h 6mbly exposed bare meal wm at quickl7 may be used as requimd by the owner when they under aa-Hda== d high huidity, when mt, w are preci8ed la the contract to illustrate the degree ahomjascorresiveatmosphase. Undermerunnianild d metal h required. M owne win pro.

atmospherio conditione it is best prestice to prime vide the speciand samples or standards of such eine

, or ch===inally, treat within 24 houn after hinst and condition that by may be M dwing i clemming. Unde no h should the steel the estim contract. If blest cleaned steel samples l

• be permitted to rust befase painting, negardies of are used, they should be counpistely protected frean ,

the tim elsped. an nsias dwing the period at the contreet.

. . . .. .. .., .. , . 4"* $

. Meistare a==i===== on any ourdnee that is colder A.10 If speciand la the contract, a pucentage other them the dew point of the omr==manqr ehr. It le than 95efoof the surface area assy be designated la .-

therefore W that hy hiest oismaing Section 2.2. -

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• i Attachment B  !

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XSG 84 , ,

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ATTN 10M WELLEY d SUHFACE PH0Ftt.E 06 19i PHINRW AND Cf,I I i PLEASE M ADVISED THAT CARDOLlyt IECOMNRMS A Mi11Mth M A I MIL l PICF f t.t FOR THE AP%F. Th0 PHI"ERS. s.H THC SPECIFIC 4t20N A3 YOU l EXPT.AINTD 79 M.t THtHE 15 NO #AXIMUM L IM t T 04 THE PROFILF,. TMis 13  !

ACC%>TA4.K TO CAR 90LINE PROV t CCD A SPECIF IEU N.AST NTP!4 i$ CALLED I FOR THUS LIMITING THE ACTUAL PheILE ACHIEVED AND THAf TME PRLMER U$te COMPELTtLY COVER $ THE PROFILE ACHitVFD IN THE F IEL D. t t 00 P EE1 1 THAT A MAXIMUM OF A .1 MIL PROFILE 13 ACCEPTA%E.

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• l CC CHMALES KUSHING, ROCES TECTMEYtH i

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O Attachment C INSTWCTICE REVISION I8EE PAGE  !

t TBXAS UTIUTISS GS4SMATING CO. '

O.- CPSSB.

12 of ^27

~

3-QP-11.4-5 27 NOV 8198J l

I !

3.3.1 Coatino Apolicator Qualifications The Inspector shall verify (by Qualif1 cation Record or list '

of qualification records in QA File) that the coating applicators on each shift are qualified for safety-related ,

coating work. l 3.3.2 knbient Conditions The inspector shall datemine air tenperature, surface [

temperature, relative humidity and dew point of substrate  ;

structures. A calibrated non-earcury filled dry bulb  :

1 thermometer or calibrated temperature recorder (Bristol l 4069TH or equiyalent) shall be used for air tenperature  ;

f detemination. A calibrated non-mercury wet bulb '

thermometer or a calibrated humidity recorder (Bristol ,

4069TH or equivalent) shall be used to determine relative ,

humidity. The dew point shall be detemined by the  :

difference in dry and wet bulb tenperatures using the U.S.  !

Department of Commerce Weather Bureau Psychometric Tables, O. ,

'WB No. 235. Wheir dry bulb readings are greater than 100*F... - t the dew point should be detemined using the 100*F dry bulb l reading, and relative humidity shall be determined by l subtracting wet bulb from the surface tenparature or ambient '

temperature, whichever is greater. If the dry bulb thermometer exceeds 100*F the instrument shall be returned to the calibration lab for recalibration. . The surface l t

temperature shall be detemined by placing a calibrated i surface temperature themometer (0mega-Anprobe fast tenp. l

[ range of 10*-250*F) in contact with the substrate surface -

f until the temperature reading stabilizes.

( .

The permissible range of surface and ambient tenperature for  ;

application of finish coat shall be 50-120*F. [

Maximum values of relative humidity shall be 85%.

The surface temperature shall be a mininun of 5'F above f the dew point. j 3.3.3 Coated Surface Acceptability l The Inspector shall visually reinspect the previously coated f surface just prior to fintsh coat application for evidence of l contamination (oil, 'rease, g foreign natter) and stains.

7 C.5 i

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-t O Q @ g l IM INO" REVISION PAGE nin.co.-

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QI-QP-11.4-5 13 of 27 27 (NOV'81933

.  : i l

l Contamination is unacceptable. All contamination must be l reoved per Reference 1-8 or 1-C prior to finish coating.

Rust (red) and zine oxide (white) stains are acceptable provided all' loose particles have been removed (as evidenced

, by existence of no stain on cloth) from the coated surface  !'

by approved cleaning operations. Phenoline Thinner or Xylol are approved cleaners for seal coat. Thinner wiping is not  ;

recommended for Dimatcoat primer. Use Carboline #33 cleaner i for CZ11 Primer and #15 thinner for Cart >oline 191 primer.

3.3.4 Air Sucoly Aceeatability j The Inspector shall inspect the air supply system (pressure l pots and spray guns) for the existence of suitable filters / ,

traps / separators.

The effectiveness of these items shall be verified by placing (

a clean piece of' cheesecloth (or white fabric) over the exit i of the afr lines and allowing air to flow for 30 seconds  :

O. . .

~

- _ . . . . = -minimum - The cloth shalLshow. nn. evidance of moisture, all  !

or foreign matter whert examined.

3.3.5 Finish Coat Mixino Operations 3.3.5.1 Prior to mixing, the inspector shall verify that each j component is identified by batch numbers and that the ,

24 month shelf life has not been exceeded.  ;

3.3.5.2 The inspector shall verify that mixing /thinne- operations l are perfomed in accordance with References 1-8 and 1-C.  ;

Thinninel may be done up to two quarts of Phenoline Thinner l per gal'on of Phenoline 305.  ;

3.3.5.3 The inspector shall verify that the pot life has not expired i per References 1-8 and 1-C. l l

'3.3.5.4. When coating materials are mixed / thinned in locations other  !

than the field, the inspector verifying the mixing opera. tion l shall fill out the Paint Mixing Slip, Attachment 5. The  ;

inspector perfoming the pre-application inspection shall l record the information from the Paint Mixing Slip on' the l Inspection Report, Attachment 1. The Paint Mixing Slip need  :

4 not be retained. l a t'% ,

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- pean sem t f

Attachment D

. CPP-15,956 '

TEXAS UTILITIES GENERATING COMPANY OFFICE MEMOR ANDUM r, Tom Brandt Glen Rose. Texas May 8, 1984 subject COMANCHE PEAK STEAM ELECTRIC STATION '

PROFILE -TEST RESULTS On March 9,1984, a series of profile tests were performed. The tests were conducted to verify the consistency of the Test Tex Profile  ;

Gauge and to detennine the profile of power and hand tools used on site.

The results were:

60 grit flapper wheel 1.5, 1.1, 1.0, 1.5, 1.4, 1.4, 1.5 3-M clean & strip 1.8, 1.4,1.3,1.2, 1.75, 1.4, 1.6 Hand sand (60 grit) 1.7, 1.7, 1.5, 1.75, 1.4, 1.6, 1.6, 1.3 l Belt sand (36 grit) 1.1, 1.1, 1.0, 0.8, 2.0, 0.9, 0.8,1.3 Needle gun 2.5, 2.7, 2.7, 2.25, 2.3, 2.5, 1.8 Tom Kelly m d '

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ATTACHMENT E product data cheet

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.. i carboIIne9 -

CARB0 ZINCe 11

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. h.(360 HANLEY IND'USTRIAL COURT e ST. LOUIS, MO. 63144 e 314-644-1000 l

NOTE: Under certain conditions a rnist con w tie com l SELECTION DATA may be desirable to prevent topcoat bubbling g GENERec TYPE: Self curing, inorgenec zinc prinwr. The COMPATIBILITY WITH OTHER COATINGS: Apply di- "* U coetmo conoots of a basic zinc silicate complex. Bam and rectly over substrate, Carbo Weide 11 or other inorganic zine figer mixed prior to application. zincs as recommended.

g GENERAL PflOPERTIES: An inorgeme zine been coat that protecas seest golverucelly, eliminating sub film corroepen.

Has oussanding applicmion properties. Can be applied at SPECIFICATION DATA ,

the recommended thicknees m one cost.

REC 0AAAENDED USES: Carbo Zinc 11 (the first self cur

• THEORETICAL SOLIDS CONTENT OF MIXED MA-  !

ing laaegame aine primer) is used as a single coat protection TERIAL:  !

of steel structures in weathering exposure and as a base cost By Weicht for orgenec and inorganic topcoats in more severe services.

Carto Zinc 11 79% 2 2% ,

Exmilent for the interiors and exteriors of storage tanks I Percent zinc in dry fifm 80%

contaenens fusis and organic solvents. Has many uses as a maintenance primer, with or without topcosts, depending .

ECOMMENDED DRY FILM THICKNESS PER COAT- j on exposure. Used widely in chemical plants, paper mills, 2-3 mils (50 to 75 microns) refineries and coastal or seit atmospheres including offshore

• str'sctures. Carbo Zine 11 meets the stringent performance THEORETICAL COVERAGE PER MIXED GALLON * '

I 1000 mil sq. ft. (24.5 sq.rn/10 26 microns) requirements of the Amencen National Standards Institute,  !

333 sq. ft. at Emils (8.2 sq.m/19 76 micronel ANSI N101.21972 and ANSI N5.121974. '

• NOTE: Materiel losses during mixing and application will f NOT RECOAS4 ENDED 70R: Immersion or indirect ex- vary and must be taken into consideration when estimating j posure to acids or alkalies without suitable topcoat. f job requirements.

CHEMICAL RESISTANCE GUIDE: (with proper topcoet)

.O SHELF LIFE: Base: 12 months minimum i

() Huvy Fuma a M Zinc Filler: 24 months mimmum Light Splah Wembering COLORS: Gray or Green only. I Eg Immersion and Spillase or Mild Fumes I

Acids NR Very Good Excellent GLOSS: Matte finish.  !

Alkalies NR Very Good Excei ent  ;

Solvenes Exmilent Excellent Excsilent .

Excellent I Excellent Exmilent Salt Excellent Excellent Excellent ORDERING INFORMATION  !

Water i TEMPERATURE RESISTANCE: (non-immersion) em rney be obtainedrom CamoHne Salm Repmentatin l i Continuous: 750*F (399'C) or Main Office. Terms - Not 30 days. i Non<:entinuous: 800*F (427'C)

( SHIPPING WEIGHT:

l F LEXistLITY: Fair-Good WEATHERING: Excsilent 23 tbs. (10.4 kg) 113 lbs 1.3 kg)

ABRAS40N RESISTANCE: Exmilent. Abrasion resistana Carbo Zinc 11 Carboline Thinner #33 9 lbs. (4.1 kg) 41 lbs. (18.6 kgl i incneus with age.

Carboline Thinner #21 8 lbs. (3.6 kg) 36 lbs. (16.3 kg)

SUBSTRATES: Apply over properly prepared steel, cast  !

iron, or other surfaces as recommended. FLASH POINT: (Pensky Martens Closed Cup) 56*F (13*C) [

TOPCOAT REQUIRED: May be topeosted with epoxies, Carbo Zinc 11 Sees Carboline Thinner #33 101*F (38'C)  :

phenoisco, vinyls, acrylics, silicones, chlorinated rubbers or 63*F (12*C) [

Carboline Thinner #21 others as recommended. \

I I

i .

l Feb. 81 Repieces.lan.80

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fy vv ? , =- + my y g g ., 3 3,, % y, , , , y Te the best of our kneustem'se the technical does sente6ned hero 6a are trug and escurses at t'te done et immsense and are sutteet se chal

.- vuothout pseer notese. West must sentest Careee6ms te veelfy eersemenese sofere seestfyine er ordeelne. No esserensmo of escuterf Imposes. ese oseantes sur oreduces se eenform to Caroeideas opuesery sentees. we samum i m seO oTMER WARRANTY OR ouARAteTEE OP ANY ufMO IS MADE SY THE SaLLER. ExPRESe OR theP ,

\ SY OPERATION OR LAer. OR OTHERwleE. INCLUDING MERCH ANTASILITY AMO PlTNEe8 FOft A PARI

=- -- '* e~b Mil Q _*_m____O [o_I* hr E$f -~

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t APPLICATION INSTRUCTIONS

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emme e reseen, me=6ae 6aseructs ae T9.see W e W.G.ste b. GB00. usee cl ans s .c . .,i ano.eleta W,.er.c.eure. se se assum.e i,isi en. . ae.i..ae n e.a  ;

selv 1. m.stmum es,ws. fr.m th. mate,6 Wo. [

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'- SURFACE PREPARATION: Remove any oil or grease elevation as gun. If spraying stops for more than 15 min-from surface to be meted with clean rags soaked in Carbo- utes, blow the material from hose back into pot.  !

line Thinner #2 or toluol.  !

Mfr. 8: Gun Fluid Tip Air Cap ,

Sesel: For immersion avvice, dry abrasive blast to a White i Metal finish in accordance with SSPC SP 5 63 to a degree Binks #18 or #62 68 66PE l of cleanliness in accordance with NACE #1 to obtain a 1 to Devilbiss P MBC or JGA ~E J 704 3 mil (25 75 microns) blast profile. For non-immersion ser. approx. 070"1.D.

vice, dry abrasive blest to a Commercial finish in accord. Airless: Use a 3/8" minimum 1.D. material hoes. Hold gun '

ance with SSPC SP 6-63 to a degree of cleanliness in accord- 12-14 inches from the surface and at a right angle to the ance with NACE #3 to obtain a 1 to 3 mil blast profile. The surface. Keep material under mild agitation during applica-Horton pickling promss is also acceptable - for other ac- tion.

ceptable surface preparations consult the Technical Service Department. Mfr. & Gun Pgggg*

MIXING: Mix separately, then combine and mix in re fol- Devilbiss JGB-507 QHA 508 lowing proportions. Graco 206 591 President 30:1 or Bulldog 30:1 '

Binki Model 500 Mercury SC ,

1 Gal. Kit 5 Gal. Ki. i

• Teflon packings are recommended and available from  !

Carbo Zinc 11 Base 1 Gal. 5 Gal. pump manufacturer. i (partially filled) (partially filled) i Zinc Filler 14.6 lb. unit 73 lb. unit Use a .019.025" tip with 1500 2000 psi.

Mix as supplied. Sift zine filler slowly into base with con- BRUSH: For areas less than one square foot. For touch up tinuous agitation. Mix until free of lumps. Pour mixture only, usir g medium bristle brush. Avoid rebrushing. ,

through a 30 mesh screen. When less than full kit is used, DRYING TIMES-mix by weight 10 parts Base: 22 parts Zinc Filler. Thin up l to 12% by volume with Carboline Thinner #21 in cool Before wooeting or weather (below 55*F [13*C]). For warmer or windy con. Temperamre with placmg ine servge ditions, use Carboline Thinner #33. over 50% RH untopcosted*

POT LIFE: Eight hours at 75'F (24*C) and less at highe, O'F (- 7 days temperatures. Pot life ends when coating becomes too vis.

40*F (4,18*C)

C) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> b cous to use.

60*F (16*C) 80*F (27*C) 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> 8 hours APPLICATION TEMPERATURES: 100*F (38'C) 6 hcurs Meterial Surfaces

• Represents minimum times. If allovved to weather, exces-Normal 40 95*F (4 35'C) 40110*F (4 43*C) live salting should be removed.

Minimum O'F (-1 0*F (-18*C) CLEAN UP: Use Carboline Thinner #2 or xylol. Remove Maximum 130*F (54,8*C) C) 200*F (93*C) hardened material with 10% caustic soda solution. Caution:

Ambient Humidity Caustic attacks aluminum.

Normal 40 95'F (4 35'C) 40-90% STORAGE CONDITIONS:

Minimum Temperature: 40110*F (4-43*C) Humidity: 0100%

l 0*F (-18*C) 10%

Maximum 130*F (54*C) 95% NOTE:

Do not apply when the surface temperature is less than 5'F a) To recnat Carbo Zinc 11 - thin 50%. Apply over clean, (2*C) above the dew point. dry Carbo Zinc 11.

i Special thinning and application techniques may be re. b) When Carbo Zine is used for immersion service untop-

! quired above or below normal conditions. coated where zinc pickup could be detrimental or when

( dry spray is evident and Carbo Zinc is to be topcoated, SPRAY: Use adequate air volume for correct operation.

remove loose zinc after curing by rubbing with alumi-Use a 50% overlap with each pass of the gun. On irregular num screen wire.

surfaces, coat the edges first, making an extra pass later. c) For interior applications, or tank linings if the relative NOTE: The following equipment has been found suitable, humidity is low, 'ho curing rate can be increased by rais-however, equivalent equipment may be substituted. Ing the relative humidity by steam or a water sprey on the coated surface after allowing to dry for one hour at Conventional: Use a 3/8" minimum 1.D. material hose. 75*F (24*C).

HoW 8 0 inches from the surface and at a right angle d) Carbo Zinc 11 will skin if left in opened container. Skin has no effect on performance, but should be removed Use agitated pot. Maximum 50 foot hose. Keep pot at same before reusing.

v'" casmest coerrames ptAansasta sOLvestra. xsEP AwAv PnOM SPANKS ANO OPEN FLAMES. W COWWE!D AnEAS wonMMEN MusT WEAN

- O .

Passa amuNa amarmarOns NvennesNemvu can ONs snout 0 waan aLOveS On use enOracrive enEm Au. ascinic couicMaur

. Aae sermArmNs sNOutD es unos ANO anouNoeO = acconO4Nea wnN TNa NatiONm. ascinicas. coos. m ansas wNans

'i* ' EllPLOWON NA2AfDs Exist WOfmM98 StOuLD -- -

SE nEQuinEO TO UsE NONFEnnous TOOLS ANO TO WEAN CONOuCTiVE ANO seosspampuMG 340E -*~su' . - - - - - - e 2- .. ,

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350 HANLEY INDUSTRIAL COURT CSf*t3Olit'BG ST. LOUIS, MO. 63144

• 314644-1000