ML20080D439

Affidavit of CT Brandt Re Open Issues in ASLB 830729 Proposed Initial Decision Including Protective Coating, Downhill Welding,Alleged Mismatched Pipe Hanger,Bolt Torquing & Weld Quenching

ML20080D439
Person / Time
Site:	Comanche Peak
Issue date:	08/26/1983
From:	Brandt C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20080D427	List: ML20080D424 ML20080D439 ML20080D448
References
NUDOCS 8308300453
Download: ML20080D439 (47)

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Attachment B 1

00CKETED USNRC UNITED STATES OF AMERICA j35529 A5:56

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 40ARp SECFETAC' OCCKE' TING A SEPvir.E BRANC4 In the Matter of

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Docket Nos. 50-445 and TEXAS UTILITIES GENERATING

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50-446 COMPANY, -- ~~et al.

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( Application for (Comanche Peak Steam Electric

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Operating Licenses)

Station, Units 1 and 2)

)

AFFIDAVIT OF C.

THOMAS BRANDT REGARDING "OPEN ISSUES" IN PROPOSED INITIAL DECISION I,

C.

Thomas Brandt, being first duly sworn to depose and state as follows:

I am employed as the Non-ASME QA/QC Supervisor at Comanche Peak.

As such, I am familiar with the QA Program at Comanche Peak, including the disposition of nonconforming conditions identified by QC Inspectors and the guidelines, specifications and procedures applicable to the QA Program.

I have previously testified in this proceeding regarding the QA Program for Comanche Peak.

A statement of my educational and professional qualifications 'was received into evidence as Applicants'. Exhibit 141A.

This affidavit addresses certain "open issues". identified by the Licensing Board in its July 29, 1983, Proposed Initial Decision.

The particular "open issues" addressed herein concern (1) protective coatings, (2) downhill welding, (3) alleged mismatched pipe hanger, (4) bolt torquing, and (5) weld quenching.

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I.

PROTECTIVE COATINGS j

A.

Inspection Procedures l

There are four allegations which the Board identifies as l

"open issues" regarding the procedures applicable to inspection of protective coatings.

Proposed Init.ial Decision at 23.

I address each of these items below.

1.

Near White Blast The Board left open a question regarding an allegation that there were no standards for determining whether near White blast (a measure of surface cleaning / preparation of cteel prior to painting or coating) had been achieved in surface preparation for application of protective coatings.

Ilowever, as provided in the attached procedure, preparation of substrate surfaces for primer application requires cleaning to an equivalent of near white blast conditions, in accordance with applicable specifications.

See CCP-30, " Coating Steel Substrates Inside Reactor Building and Radiation Areas," Section 4.1.1. (Attachment A).

The referenced specification requires the use of a Keane-Tator Surface Profile Comparator (a device which utilizes a plate with various known surface roughnesses for visual comparison of surfaces) to determine near White blast.

See OI-QP-ll.4-1, " Inspection of Steel Substrate Surface Preparation" (Attachment B), Section 3.3.2.c.

Accordingly, this allegation is incorrect.

O 2.

Maximum Roughness The Board left open a question regarding an allegation that there is no maximum value for surface roughness in the specifica-tions regarding steel substrate surfaces, and that the rougher the surface, the earlier the paint will " break down."

The procedure applicable to the inspection of surface roughness does provide that "no maximum profile [a measure of surface roughness] will be specified, providing that correct millage [ coating thickness] requirements can be obtained after primer application."

See OI-QP-ll.4-1, Section 3. 3. 2.c.

(emphasis added) ( Attachment B).

If the millage requirements cannot be met, the coating is rejected and reworked.

Thus, the question of maximum surface roughness is procedurally addressed.

Further, the claim that a profile depth greater than the minimum specified (1.0 mil) would result in an early breakdown of the paint is wrong.

In actuality, a profile depth greater than the minimum specified would tend to increase adhesion of the coating to the substrate.

The only detrimental effect of this condition would be to create a surface on which it was dif ficult to obtain uniform coating thickness.

However, this occurrence is addressed by procedures requiring inspection utilizing dry film thickness

- gages.

3.

Adhesion Testing The Board left as an "open issue" a determination as to the l

l significance of the allegation that all paint inspection had been l

reduced to adhesion testing.

In fact, protective coatings inside

containment at Comanche Peak are both visually inspected and inspected for dry film thickness following finish coat application (in addition to the procedures applicable to inspection of surface preparation and primer application).

Additionally, the liner plant is checked for coating continuity.

Only if records for surface preparation and/or primer application are missing or discrepant, will destructive testing (i.e.,

adhesion tests and/or scratch tests) be performed in the area for 4

which the records are deficient.

Thus, the allegation is incorrect.

4.

Repair of Minor Defects Another "open issue" concerns the allegation that the repair criteria for minor defects in protective coatings are inadequate.

Proposed Initial Decision at 24.

Specifically, it is argued that numerous (i.e., minor), closely spaced defects would be classified as minor (rather than major) defects, and that a primer coat should be employed in such instances.

The hypothetical situation postulated in this allegation is highly unlikely to occur in that any occurrences which would result in extensive damage to a coating are not likely to be limited to small (i.e.,

less than one-half inch) damage.

The minor defects which are addressed by these criteria (procedures) are those in which minor chipping or cutting may have been made in the coating.

If in any area, either circular or linear, a one-half inch diameter circle could be completely inscribed at any point by the defect, the defect will be classified as a major

defect and appropriate repair measures will be implemented, including application of a primer coat following surface preparation before reapplication of the final coating.

See CCP-30, Sections 4.4.2.8 and 4.4.2.9 (Attachment A).

These repair procedures have been approved by the coatings manufacturer as being appropriate for repairing defects in coating surfaces.

Thus, the procedures address any defect likely to be identified in coatings, and the repair process for various types of defects are established / approved based on appropriate technical reviews of the processes.

B.

Kelly Heaters Another open issue identified by the Board involves an allegation that the disposition of an NCR regarding the possible contamination of a painted surface by smoke from a heater being used to cure the paint was inadequate.

Proposed Initial Decision at 24.

Applicants were unable to find an NCR vritten by Mr.

Hamilton regarding Kelly heaters.

Applicants did find an NCR (NCR-C-903) written by his supervisor on that subject (Attachment C). The disposition of that NCR was to wipe off the coated surface with detergent or an appropriate solvent-to remove any surface deposits (soot) left by the smoking heaters.

That is the standard procedure for removing any non-embedded contamination or painted surfaces.

Any contaminants that may have been embedded in the coating would be detected by the routine visual inspection in accordance with instructions for visual inspections.

If any contamination was identified, the affected area would be rejected l

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and repaired prior to final acceptance of the coating.

Thus, any contamination which may have been caused by the smoke would be subject to appropriate corrective action.

C.

Westinghouse Coatings An item which the Board states it is " unable to evaluate" based on the present record concerns an allegation that coatings on Westinghouse-supplied components failed an adhesion test.

Proposed Initial Decision at 24.

In this regard, the Board requests an answer to the questions of whether these pieces of equipment were safety-related and whether the paint will perform satisfactorily.

In the first instance, Westinghouse, as the nuclear steam supply system supplier for Comanche Peak, conducts its own QA program in accordance with 10 C.F.R. Part 50, Appendix B for all components it provides to Comanche Peak.

Coatings on safety-related (as here) Westinghouse supplied components are subject to the Westinghouse OA program.

Those coatings are identical to those applied to other steel equipment at Comanche Peak, including satisfaction of tests for performance under design basis accident conditions.

II. DOWNHILL WELDING Another "open item" identified by the Board concerns the allegation that downhill welding was performed by Mr. Stiner at Comanche Peak.

Proposed Initial Decision at 33-34.

The open question identified by the Board is whether this allegation was limited to root and cover passes, in that I previously testified that downhill welding was permitted by ASME Section IX for root

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and cover passes (Applicants'-Exhibit 141 at 22-23; Tr. 4601-02).

However, I also testified that Brown & Root welding procedures (which are applicable to the welding being performed by Mr. Stiner) do not permit downhill welding at Comanche Peak (Tr. 4601-02).

Brown & Root welders are qualified to instructions and procedures which prohibit downhill welding.

Thus, any welder who performed such welding would have to willfully violate those instruction / procedures, a practice which would be a basis for termination.

I am aware of no evidence that

.such a practice has occurred at Comanche Peak.

III.

MISMATCHED HANGER Another "open question" identified by the Board concerns an allegation that a hanger which had.been QC inspected was

" mismatched" in that an excessive fit-up gap existed between the tube steel member and the base plate of the support.

Proposed Initial Decision at 39.

This allegation was the subject of an NRC inspection, at which time it was determined that the support in question was an ASME Code' Class 3 support.

The procedures applicable to the particular weld in question provided for a fit-up gap of no more than 5/32 inch.

As part of the NRC's investigation, a portion of the welded material was ground out to examine the fit-up gap.

It'was determined that for at least a j

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portion of the welded area a gap of 1/4 inch was present.

Accordingly, Applicants 11dentified]this support on an NCR, removed the af fected portions of the~. pipe support (for

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I investigative purposes) and evaluated the safety consequences of-

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the nonconforming weld.

That evaluation determined that even had the particular gap not been detected, there would have been no adverse safety consequences.

See letter to G.L. Madsen (NRC) from R.J. Gary (TeWas Utilities Generating Company), TXX-3655

( April 15, 1983) ( Attachment D).

Furthermore, we have no reason to believe that this instance is other than an isolated case.

I V.

BOLT TOROUING Another allegation which the Board has identified as an

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"open item" concerns the establishment of torque values for A490 bolts.

This allegation was that no specific torque value had been established by procedure for A490 bolts.

(Proposed Decision at 43-44.). Actually, torque values for A490 bolts had been established.

However, these values were based on an informal correlation of bolt tensicn with a particular number of turns of the bolt'to be made after ~ achieving a snug-tight condition.

As a result of'~nn NCR (which was written against a bolt that had failed during tightening), it was decided to establish A490 torque values based on formal testing.

Consequently, a test was

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,s-performed to establish such values, and the actual test data were incorporated into the design specifications.

Bolts which had previously been verified by the prior torque value were subsequently re' erified to the new value.

In addition, samples v

of the CB&I(furni hed bolts were taken and independently tested to verify mater'i<31 quality.

.It should be noted that the failure

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of the original bolt on which the NCR was written was determined to have occurred because the inspector had misread the torque value on the torquing device.

V.

QUENCHING OF WELDS The remaining "open issue" which I address concerns an allegation that a weld had been quenched by direct application of

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a water-soaked cloth.

Although this item had been identified on an NCR and df 3 positioned in accordance with applicable procedures, the Board indicates that it does not understand the technical justification for *.he disposition of the NCR.

Proposed Initial Decision at 44.

Rapid water quenching is a aeat treatment method utilized to harden carbon steel.

Such heat treatment may af fect the micro-structure of the steel, and may. result in an increased tensile strength and hardness and a decreased ductility of the carbon steel.

For these reasons, quenching of carbon steel welds and heat af fected zones is an undesirable practice and is prohibited bpsiteprocedures.

The quenching which was the subject of this allegation, however, invo ved an,austenitic stainless steel. Such st; eels' do not undergo the microstructural changes carbon steels undergo upo'n rapid quenching, and there is no similar metal-4 lurgical concern with such a cooling method.

In fact, this prac-tice is quite common in welding on austenitic stainless steels.

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5 Thusj-ils site procaoures pruhtbmauf quencbeg apoiy to all steels (carbon and statnte%). baly artnn atte) coula :e ditriel, afftf.m MtellurSpally by such quenchin9

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C. Inomas 3rahs v County of Dallas) subscribed and swa tg State of Texas

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before se this 26 day of August,1983.

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Ifotary Fublic

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This is a telecopy facsimile.

The original will be transmitted under separate cover.

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PROCEDURE EFFECTIVE CPSES NUMBER REVISION D&T.E -. -

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I DATE:

JOB 35-1195 CCP-30 10 1/26/82 1 of 13

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ORIGINATOR:

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COATING STEEL SUB-

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1.0 INTRODUCTION

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i 1.3 GENERAL DISCUSSION 2.0 DEFINITIONS OF TERMS I

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4 3.2 SAFETY REQUIREMENTS 3.3 INSTRUMENTS AND THEIR USE i

3.4 DOCUMENTATION 1

3.5 RECEIVING, STORING AND DISPENSING 0F C0ATING MATERIALS l

3.6 SPECIAL C0ATING PROCEDURE

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3.7 TOUCH-UP & FINISH C0ATING OF VENDOR APPLIED C0ATINGS t

4.0 PROCEDURE FOR COATING 4.1 PREPARATION OF SUBSTRATES AND C0ATING MATERIALS 4.2 SURFACE PREPARATION FOR FINISH C0AT l

4.3 PREPARATION OF C0ATING MATERIALS 4.4 APPLICATION OF PPIME AND FINISH C0ATING l

4.5 FINAL ACCEPTANCE TESTING 4.6 HOLD POINTS y

SUPPORTING INFORMATION

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PRCCEDURE EFFECTIVE EROWN & ROOT, INC.

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REVISION DATE PAGE a

CPSES l

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,l JOB 35-1195 j

CCP-30 10 1/26/82 2 of 13 Jl j

1.0 INTRODUCTION

1.1 PURPOSE 1.1.1 The purpose of this procedure is to establish the methods by which the prime and finish coats are to be applied to the con-tainment liners and radiation areas in accordance with speci-fication, drawing, and manufacturer's requirements. This pro-cedure may also be used for coating any steel substrate inside i

the reactor buildings scheduled to receive Carbo Zinc 11 primer and Phenoline 305 finish coat.

1.2 SCOPE 1.2.1 The scope of this procedure covers the surface preparation and coating of Unit 1 and 2 steel substrates inside the reactor buildings and radiation areas scheduled to receive protective

.j coatings.

4 1.3 GENERAL DISCUSSION l

i 1.3.1 All coating materials covered by this procedure shall be as manu-i factured by Carboline Corporation of St. Louis, Missouri. The i

coating shall consist of a prime coat of Carbo Zinc 11 with a finish coat of Phenoline 305. To protect the prime coat from prolonged ex-j posure, a " seal coat" consisting of approximately one mil. of Pheno-line 305, thinned in accordance with Section 4.4.2.4, may be applied over the prime coat.

Prior to finish coating, the seal coat shall be solvent wiped with Phenoline thinner or Xylol.

Finish coating shall j

be applied when convenient prior to ccmpletion of the building or prior to placement of concrete, equipment. or obstructions which would make finish coating impossible.

In order to maintain traceability on protective coatings applied to shop coated steel cited for installation in the Reactor l

Building, these items shall be steel stamped with a unique coating code number. The code numbers shall be assigned by QC Paint and i

applied by craft personnel. Upon division of materials, this j

unique number will be transferred along with all other unique I

identifying numbers.

2.0 DEFINITIONS OF TERMS j

2.1 TERMS ij 2.1.1 Substrate - The uncoated surface to which a coating is applied.

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PROCEDURE l EFFECTIVE I

! REVISION l DATE.

PAGE BROWN & ROOT, INC.

NUMBER I

i CPSES JOB 35-1195 I

CCP-30 10

1/26/82 3 of 13

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3.0 SPECIAL ITEMS AND OPERATIONS j

l 3.1 QUALIFICATION OF PERSONNEL i

3.1.1 Coating application personnel shall be qualified per previous ex-perience and pr,actical application.

In addition, each painter shall have been instructed by the Paint Superintendent or his representa-k tive in the use of the products as consistent with Carboline's

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training procedures, which includes both classroom instruction and J

a field application demonstration. This shall be verified by com-pleting a form similar to Attachment 1.

This form shall be 3]

executed by the Brown & Root Paint Superintendent or his represent-a ative. A coating manufacturer's representative will be available

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for technical supervision upon initial painting effort. Applicators performing work to Attachment 2 shall be qualified for "Q" coatings when applicable.

i 3.2 SAFETY REQUIREMENTS 3.2.1 All appropriate health, safety, and fire protection requirements, pertaining to surface preparation and coating application, shall be f6110wed.

It shall be the responsibility of the Site Safety Department to establish the frequency of monitoring the coating work.

3.3 INSTRUMENTS AND THEIR USE 1

3.3.1 The painting Foreman and General Foreman shall have access to and be familiar with the use of all instruments necessary to insure efficiency of coating applications. This shall include surface profile comparators, holiday detectors, thermometers, and wet and dry film gauges. Viscosity measuring devices will not be used. Wet film gauges will be randomly used during coating application as an aid to field personnel on Phenoline 305 only.

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Readings will be limited to the minimum necessary to control

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coating thickness, i

l 3.4 DOCUMENTATION 3.4.1 Records shall be maintained on Attachments 1 and 2 listed in i

Section 5.1.

After completion, each form shall be forwarded to i

the Brown & Root Document Control Center for filing and distri-j bution to the various parties as listed on the distribution sheet.

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DATE PAGE CPSES J08 35-1195 1/26/82 L

CCP-30 10 t

1 4 of 13 4

I.l 3.5 RECEIVING, STORAGE AND DISPENSING OF COATING MATERIALS (h

3.5.1 Receiving and Storage - Upon receipt of a shipment of coating materials, the B&R QC Representative accepting shipment shall 1

be responsible for completing all necessary receiving inspection documentation. General receiving procedures shall be in accor-

..adance with Brown & Root Construction Procedure CP-CPM 8.1.

It shall F-othen be segreg'ated from N6n "Q" materials and stored in the paint

'*ttorage building where temperatures will be rpaintained between

~450 - 110 F.

Infrequent dips in air temperature in storage. areas 0

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as low as 32 F for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are acceptable. Temporary A

storage may be required at the receiving warehouse due to receiving or other problems.

3.5.2 Dispensing - When coating materials are needed, in the field, it shall be transferred from the controlled area to a designated l

temporary storage area or area of intended use in the field. Due i

to limited shelf-life of coating materials, this shall be done on j

a "first-in", "first-out" basis. After materials have been j_

partially used from an individual container, the said container

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cannot be resealed and returned to "Q" storage area for later use. Containers opened and partially distributed from the "Q" a

paint storage area may be resealed and the remaining contents i

used for "Q" painting. With the exception of thinners, the con-l tents from partially used containers shall not be reused after j

a period of 7 days has elapsed from date of initial opening.

l 3.6 SPECIAL C0ATING PROCEDURE 1

]

3.6.1 When items require special coating not covered under the content i

of this dccument, the appropriate Project Engineer (Mechanical,

[

Civil, Electrical) shall complete Attachment 2 and transmit it to the Paint Superintendent. A log of all procedures from t shall be maintained by the Site Coating Engineer.

j The following information shall be completed on each procedure.

l 3.6.2 Each procedure shall be given a unique number. The scope will 1

describe the working limits of the procedure with detailed work requirements being listed under the requirements sectiion.

The approvals section shall have signatures of the following:

?

Project Discipline Engineer (Mechanical, Civil, etc.), QA j

Manager if coating of item is safety related TUSI representative when required, Engineer who prepared document, and a revision 4

number and date. Upon completion of the document, distribution j.

shall be made to all holders of this procedure.

I.

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PROCEDURE EFFECTIVE l.

BROWN & ROOT, INC.

NUMBER REVISION DATE PAGE l

CPSES 1

1 JOB 35-1195 CCP-30 10 1/26/82 5 of 13 j

3.7 TOUCH-UP AND FINISH C0ATING OF VENDOR APPLIED C0ATINGS 1

1 3.7.1 Prior to touch-up of primer or application of topcoat on vendor i

coated items 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-F ponsible ares engineer and/or the Paint Superintendent as soon as possible after receipt of a nonconforming item in need of paint repair to allow time for Attachment 2 preparation and a planned schedule for repair.

6 4.0 PROCEDURE FOR C0ATING 4.1 PRE?ARATI0h 0F SUBSTRATES AND C0ATING MATERIA'.S 4.1.1 Surface Preparation for Primer - Final surface preparation shall i

not begin unless ghe temperature of the surface to be blasted and/or

{

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 j

in accordance with SSPC-SP-1-63 " Solvent Cleaning".

Small amounts of grease or oil deposits may be removed by blast j

opera tions. The surface shall then be cleaned by blast, hand or j

power tool operations to achieve an equivalent of SSPC-SP10-63, a

"near white" blast cleaning. Although 1-3 mil. surface profile is preferred, a minimum of 1 mil profile is required. After the i

above surface preparation, the surfac*e 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 reginning primer application.

If rust forms af ter surface preparation, the rusted area shall be re-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 surface. When applying coatings that will be joined together by a later coating operation, l

the interface shall be constructed as follows:

i white metal approximately 12'<Dvarblast-the steel to near Blasting using no border tape -

a.

l 18" beyond the point which j

will receive primer. Hold back approximately 12" - 18" from j

edge of blasted area when' applying primer.

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h PROCEDURE EFFECTIVE BROWN & ROOT, INC.

NUMBER REVISION DATE PAGE CPSES JOB 35-1195 CCP-30 10 1/26/82 6 of 13 b.

Blast, hand or power tool cleaning using border tape - Clean

[

the steel to near white metal approximately 3" - 6" beyond

.f the point which will receive primer. Place border tape approxi'nately 1" in from edge of cleaned area and prime.

I When applying seal or finish coat on either of above methods

I hold back approximately 12" - 18" from edge of primer.

Removal of weld spatter and other minor surface imperfections 4.1.2 4j (not to exceed.031" for containment liners) - If needed, weld

~

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, l

)J the area to be repaired will be blocked cut and spot painted at a later date. All protrusiens and peaks shall be ground l

to a rounded contour.

3, 4.1.3 If coating removal is required from an area or item which has pre-viously been coated in accordance with this procedure, shadows or 4

tight residue of primer which may remain in the profile of the pre-r; viously prepared substrate is acceptable.

t 4.2 SURFACE PREPARATION FOR FINISH C0AT i

4.2.1 Surface preparation for the finish coat shall consist of the removal, if needed, of any oil or grease. This shall be accomplished by the use of a manufacturer recommended cleanser or cleansing method on i

areas that have been seal-coated. On areas where the Carbo Zinc 11 4

I primer is exposed, oil and grease will be removed by sand blasting, 3

hand, or power tool grinding, and needle scaling and then by solvent

}

wiping the area prior to replacing the primer.

Power tool grinding and needle scaling should be equivalent to a near white blast SP-10 specification with no size limitation as long as the millage require-ments are obtained.

1 4.2.2 The ambient temperature and relative humidity shall be measured to determine the dew point temperature.

Phenoline 305 finish ccat shall o

be applied unless the substrate temperature is more than 5 F above the dew point.

4.3 PREPARATION OF C0ATING MATERIALS 4.3.1 Primer - The primer, Carbo Zinc 11, is packaged in a two component kit consisting of a tese and zinc filler.

First the base shall be l;

thoroughly mixed. Zinc filler shall then be aeded under constant agitation and mixed until free of lumps.

Partial mixes shall be mixed

.J by weight in a proprirtion of 10 parts base to 22 parts zinc filler l~

using a suitable scale to achieve a plus or minus 2 percent accuracy.

The mixture shall then.be strained through a 30-mesh screen. Viscosity shall be controlled by adding thinner, as required, but shall not exceet two quarts of thinner per gallon of Carbo Zinc 11. Pot life of CZ 11 l

shall' be as shown in Attachment 4.

L CCP-30 Rev. 10 DCN #2 5/11/82 Sheet 2 of 2

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1 PROCEDURE f

! EFFECTIVE f.

BROWN & ROOT, INC.

NUMBER

REVISION i OATE PAGE i

CPSES i

JOB 35-1195 1/26/82 i

7 of 13 CCP-30 i

1,0 e

4.3.2 Finish Coat - The finish coat, Phenoline 305, is packaged in a two component kit consisting of Phenoline 305 base, Part A, and 1

a Phenoline catalyst, Part B.

Mixes are made by combining and

}

thoroughly mixing the base and catalyst.

Partial mixes may be 3

made by combining, in a ratio by volume, four parts base to one 3

part catalyst. Viscosity shall be controlled by adding thinner, as required, but shall not exceed two quarts of thinner per gallon

[

of Phencline 305. Pot life of Phenoline 305 shall be shown on E.

4.4 APPLICATION OF PRIME AND FINISH C0ATING 1

4.4.1 Prime Coat

}

4.4.1.1 Coating material shall be applied using conventional spray equip-l ment with agitated pressure pots having a maximum hose length of 75 feet. Care must be taken to assure that air and material pressures are adjusted to compensate the additional length of j.

hose from 50' to 75' in length. The primer shall be allowed to

?

become tack free before start of other construction operations which could create contamination problems. Any runs or sags having a detrimental effect on the coating system shall be removed and re-

i paired. The following application parameters shall also be followed:

l 1.

Normaj conditions of ambient and surface temperature shall 0

1100F respectively;0however, primer be 40 - 95 F and 40 0

may be applied within an ambient rgnge of 0 - 130 F and a sur-face temparature range of 0 - 200 F.

Carbo-Zinc 11 may be thinned up to 2 quarts per gallon for application; however, when using higher thinning levels at or below normal tem-1 perature range, care must be taken to obtain proper film build. Above 850F it is advisable to use up to 2 quarts per gallon to minimize dry spray.

In no care shall carbo-line limits be exceeded.

2.

Humidity values vary from 10 to 95% however, coating shall

]

not be applied to a wet or damp surface.

.j 3.

Thickness of prime coat shall have a minimum dry film thickness of 2 mils and a maximum of 4.5 mils. Minimum and maximum spot j

test values shall be 1.5 and 5.5 mils respectively.

f 4.

A double regulated pot having an adequate air volume supply l

shall be used, ij 5.

As a guide, coating material may be applied using a 50% over-q lap with each pass while holding a gun 8-10 inches from the i

surface. Cross hatch application is permissible.

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NUMBER REVISION DATE PAGE CPSES JOB 35-1195 CCP-30 10 1/26/82 8 of 13 h

6.

Carbo Zinc 11 is sufficiently cured for topcoat wnen tne coating may be burnished rather than removed when rubbed n

?

with the flat portion of a smooth edged coin such as a

{

nickl e.

(Minor amounts of zinc dust may be removed during

/

cure verification, however, a burnished surface must be achieved). Attachment 3 may be utilized as general guide-lines for cure to topcoat time of CZ-11 above 25% relative g

humidity.

If required, the cure of carbo zinc II may be i

1 accelerated by the use of water spray, however, a minimum i

of one hour must elapse between application of coating and I

water spray. Below 25% relative humidity, water curing is i

recommended to obtain the desired cure. Water utilized in l

conjunction with water curing shall have a PH factor from 1

5 to 9.

Application of water spray for curing purposes may-

]

bat as often as necessary to obtain the proper cure.

4.4.1.2 Recoating of Carbo Zinc 11 Primer - Prior to recoating, if no major defects per section 4.4.2.9 are present, the entire primed surface to be recoated shall be wiped with clean rags moistened with Carboline Thinner #33. Wiping shall continue until no 3

appreciable discoloration is noticed on the rags. Carbo Zinc 11 i

I shall then be thinned by using two quarts Carboline NO. 33 per l

gallon mix. This will be applied to achieve a 2.0 - 4.5 mils total DFT. Only two recoats may be applied. Special attention l

should be given to spray application and dry film thickness when using a 50% mix. The primed surface shall not be recoated until cured per section 4.4.1.1.6.

4.4.1.3 Repair of Sags and Runs - Sags or runs in excess of 5.5 mils will be adraded with an aluminum screen or sandpaper to 2.0 to 5.5 mils. Sags or runs 5.5 mils or less which show no evidence of mud-cracking will not be repaired.

If coating surface is satis-factory after abrading, then finish coat may be applied; however, d.

if coating surface is unsatisfactory, blast, hand abrade or power tool ' grind to near white metal is required and primer coat re-applied.

A satisfactory coating is considered one having no mud-cracking to the metal surface as visible to the unaided eye.

L 4.4.1.4

. Brush touch-up painting shall be done on the prime coat in accor-y dance with the following:

)

Prime Coat:

A Q

1.

Carboline Application Instruction (Carbo Zine 11) j Bulletin - October 76-N.

l 2.

Carboline Product Data Sheet (Carbo Zinc 11) 1 Bulletin - October 76-N.

Brush touch-up allowed on areas one square foot or less.

4

[

I CCP-30 Rev. 10 DCN #6 4(29/83 Sheet 2 of 4

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i l REVISION !l EFFECTIVE PROCEDURE OATE PAGE 1

BROWN & ROOT, INC.

NUMBER l

CPSES 7

JOB 35-1195 l

CCP-30 l

10 1/26/82 i

9 of 13 l

4.4.1.5 Embedded foreign particles shall be removed by abrading, if low j

millage or major defects result, recoat or repair per section 4.4.1.2 or section 4.4.2.9.

Y 4.4.1.6 Treatment of Rust Stains - Remove residue, though not neces-sarily the stain, with bristle brush and water or Carboline Thinner #33. Allow to dry thoroughly.

1 4.4.1.7 Coating Interface - Refer to Section 4.4.3.0 for coating interfacing.

)

4.4.2 Finish Coat 1

4.4.2.1 Finish coating shall be applied using conventional, airless,

?

brush or roller. Weld seams, edges and other sharp geometrical j

discontinuities may receive an initial coat of I-2 mils finish j

coating thinsed by using two quarts Phenoline Thinner per each gallon kit of Phenoline 305. To aid in continuity at edges, edges may be 4

" striped" with Phenoline unthinned instead of the 50% mixture as stated above.

In either " striping" or initial coating of edges, I

welds, etc., time should be allotted for the coating to harden 3

sufficiently to maintain a " sealing" effect prior to continuing i

coating operations. The initial coating of edges, striping, etc., as stated above, shall be considered part of the total

),

initial finish coating operation. The material shall be allowed

{

to become tack free before any other construction operations

..t proceed which could create contamination p'roblems by dust or 1

other foreign matter. A continuity check shall be performed in accordance with NACE T-6F-3 Condition "C".

No gross discontinuities are acceptable such as holidays, voids, skips, bubbles, and misses.

Any runs or sags having a detrimental effect on the coating system.

shall be removed and repaired. The following application parameters 1

shall govern:

a

'f 1.

The permissible range of surface and ambient temperature for 0

application shall be 500 - 120 F.

Temperature may rise above I

0 120 F after material has become " tack free". Phenoline 305

]'t may be thinned up to 2 quarts of Phenoline Thinner per gallon mix. The ratio of thinner to Phenoline will be that which gives

]

the best workable mix, i.e., usually advantageous to use more thinner at lower temperatures.

a 2.

Minimum and maximum values of relative humidity shall be 0% and

.]

85% respectively.

N 3.

As a guide, coating material shall be applied using a 50% over-t lap with each pass while holding the gun 8-10 inches from the surface.

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NUMBER REVISION DATE PAGE

].

CPSES l

JOB 35-1195 CCP-30 10 1/26/82 10 of 13

~

1 4.

Curing and time to recoat Phenoline 305 shall be as shown below:

Between Coats Temperature OF Final Cure 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 50 - 59 12 days 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 60 - 74 8 days 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> 75 - 89 4 days 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 90 and above 2 days J

5.

Phenoline thinned at 50% and applied as a seal coat may be 0

recoated after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of cure at or above 75 F.

j

--6.

Tack free shall be defined as the extent of cure at which

~

j foreign contaminants will not adhere to the coating.

1

]

7.

The total coating system shall have a dry film thickness range a

of 7 to 11 mils, with a minimum spot check of 7 mils and a i

maximum spot check of 11.5 mils.

1 1

4.4.2.2 Repair of Runs and Sags - Runs and sags will be abraded until the

)j DFT of the Phenoline 305 is within 1.9 - 4.5 mils.

If cracks are visible, then runs and sags will be removed to primer by 1

power tool grinding followed by solvent wiping.

If no cracking i

occurs, top coat will be considered acceptable.

Area will be recoated as outlined in the Repair of Pinholes and Discontinuities j

(Section 4.4.2.4).

t 4.4.2.3 Repair of Embedded Foreign Particles - Foreign particles shall be removed by abrading and then recoated as outlined in the repair of pinholes and discontinuities. Recoating shall not be performed until cure times stated in Section 4.4.2.1(4) have been satisfied, j

j 4.4.2.4 Repair of Pinholes and Discontinuities - Llose particles shall be removed by brushing or vacuum r compres:;ed air. The affected 4

I area shall be solvent wiped with Phenoline 305 Thinner or xylol.

Pinholes and small discontinuities may be repaired at the time of i

final inspection without a later reinspection of the repair.

If the repair area requires recoating, recoat the area with Phenoline 305 thinned 50%. Recoated areas require cure to final inspection time per section 4.5.1.

i l

4.4.2.5 Repair of Scratches and Damaged Areas - Any scratches or damaged j

areas will be abraded until loosely adherent particles are re-moved. The area shall then be solvent wiped (Carboline thinner

1. 33 for primer, Carboline Phenoline thinner or xylol for topcoat)

]

and repaired with appropriate coating, i.e., Phenoline 305 if j

damage is considered a minor defect per section 4.4.2.8 and Carbo Zinc 11 and Phenoline 305 if damaged area is considered a major defect per section 4.4.2.9.

All edges of existing coating around J

the perimeter of the cleaned area shall be " feathered" back a l

sufficient distance et ensure a smooth blend with existing coating, y

Thickness shall be as required for the pertinent coating.

l CCP-30 Rev. 10 DCN #7 6/11/83 Page 2 of 3

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I PROCEDURE l

EFFECTIVE BROWN & ROOT, INC.

NUMBER REVISION,

DATE PAGE CPSES JOB 35-1195 CCP-30 e

10 i

1/26/82 i

11 of 13 4.4.2.6 Brush touch-up painting shall be done on the finish coat in j

accordance with the following:

I 1

1.

Carboline Application Instruction (Phenoline 305) Bulletin

)

775.

2.

Carboline Product Data Sheet (Phenoline 305 Primer and Finish)

Bulletin 473. Brush touch-up and complete application is allowed with no area restrictions.

4.4.2.7 Treatment of Rust Stains - If surface is contaminated with rust

}

stains or minute metallic particles, then surface shall be pre-j pared by solvent wiping with Phenoline 305 Thinner or xylol and overcoating with a coat of Phenoline 305 prepared in accordance with Section 4.4.2.4.

i 4.4.2.8 Repair of Topcoat and/or CZ 11 Minor Defects - (Minor defects are defined as an area, either circular or linear, in which a diameter circle could not be completely inscribed at any point along the entire 1ength.) Blast or abrade, by machinc or hand, the Pheno-line 305 finish surrounding the damaged area and clean any exposed i

steel to ensure contaminant free surface.

Solvent wipe the sur-1 rounding 305 finish with Carboline's Phenoline Thinner or xylol.

t Spray or brush Phenoline 305 finish at approximately 4 mil DFT over 1

the damaged area. Overlap onto the surrourding coating a sufficient l

amount to insure a smooth and continuous topcoat system, i

4.4.2.9 Repair of Topcoat and/or CZ 11 Major Defects - (Major defects are defined as an area, either circular or linear, in which a h" I

diameter circle could be completely inscribed at any point or along l

the entire length.) Spot blast or abrade, machine or hand, the i

damaged area.

Power tool or hand abrading must be very thorough in order to prepare the surface for Carbo Zinc 11 touch-up. The result-ing surface preparation shall be equivalent to a near white SP-10 Specification. A surface roughness equivalent to a minimum of one mil blast profile shall be obtained.

)

4.4.3.0 Coating Interface - At coating interface for finish and/or primer coat, the existing coating shall be " feathered back" a sufficient distance to ensure a smooth final coating sytem. When interfacing the 305/CZ11 system and the 305/06 system, the interface of the two l

primers shall be no greater than 1h" in width, sj 4.4.3.1 Cure of Minor Topcoat Repair - Minor defects, as defined in Section 4.4.2.8, which are noted in the topcoat and repaired, may be in-spected for final acceptance af ter cure to recoat time as stated 1

in Section 4.4.2.1(4) has been satisfied.

Full cure to topcoat repairs shall be satisfied prior to placement into service.

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f PROCEDURE EFFECTIVE BROWN & ROOT, INC.

NUMBER REVISION DATE PAGE CPSES JOB 35-1195 CCP-30 10 1/26/82 12 of 13 l

4.5 FINAL ACCEPTANCE TESTING 4.5.1 Final acceptance inspection may be performed after a minimum topcoat cure of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and cure for recoat time as state in section 4.4.2.1 paragraph 4 is satisfied.

After final inspection and resolution of all discrepancies are completed the QC inspector shall document the final acceptance by completing and signing the final acceptance record. A copy will then be transmitted to the B&R Paint Superintendent as soon as possible after final accept-ance is made.

4.6 HOLD POINTS 4.6.1 Onsite receipt of coating materials.

4.6.2 Substrates before and following surface preparation.

4.6.3 Mixing and preparation of coating material for application.

4.6.4 Film characteristics after drying and curing.

4.6.5 Control of ambient conditions and surface temperatures during all phases of the coating work.

5.0 SUPPORTING INFORMATION l

5.1 ATTACHMENTS 1.

Painter Qualification Record

?

2.

Special Coating Procedure 3.

CZ 11 Cure to Topcoat Time 4.

Pot Life CZ 11 and Phenoline 305

5.2 REFERENCES

1.

Gibbs & Hill Specification 2323-SS-14,

" Containment Steel Liner", Latest Revision 2.

Steel Structures Paint Council, Volume 2, Second Edition i

3.

Carboline Corporation " Application Instruction",

October 76-N Revision and Bulletin Number 775 - data sheets October 76-N Revision and 473, Latest Revision 4.

ANSI N 101.2,

" Protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities" 5.

Gibbs & Hill Specification 2323-AS-31,

" Protective Coatings", Latest Revision j

f CCP-30 Rev 10 DCN #7 f.M5Uuna Pmo 3 of a

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NUMBER REVISION DATE PAGE CPSES JOB 35-1195 CCP-30 10 1/26/82 13 of 13

+ 1

'i

i 6.

Gibbs & Hill Specification 2323-MS-101,

" Equipment Erection", Latest Revision

j 7.

Gibbs & Hill Specification 2323-MS-438,

" Nuclear Piping", Latest Revision l

8.

Gibbs & Hill Specification 2323-MS-44B,

'j

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"Non-Nuclear Piping"

~

i 9.

Gibbs & Hill Specification 2323-MS-100,

.i

" Piping Erection" i!j

10. Gibbs & Hill Specification 2323-SS-17, 7j

" Miscellaneous Steel", Latest Revision 1

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J08 35-1195 l

CCP-30 10 1/26/82 1 of 1

,t ATTACHMENT 1

,I BROWN & ROOT, INC.

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COMANCHE PEAK STEAM ELECTRIC STATION g

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I Painter Qualification Record "

['fi GENERAL DATA 1

a 9

l Date Report Number l

TECHNICAL DATA Name of Painter Suninary of Field Experience 41 1

I i

Experience with Following Product Types i

Application Test for Specified Substrate h

. Additional Quai f fications (School)

L' L

Signature Applicator's Fiela Superviscr Distrit:ution: Painting Supt.

Q.C. Depart:nent

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Tugco QA Vault (Original.l_

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NUMBER REVISION DATE

,i CPSES PAGE i

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l.

JOB 35-1195 CCP-30 10 1/26/82 1 of 2 ll "Q" Coating ATTACHMENT 2 Sheet of Procedure #

"Non-Q" Coating Rev.

Oate SPECIAL COATING PROCEDURE NO.

SCOPE REQUIREMENTS:

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o REFERENCE DOCUMENTS APPROVALS POE 4

I QA/QC q

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NUMBER REVISION DATE l

PAGE CPSES JOB 35-1195 I

CCP-30 10 1/26/82 2 of 2 4

1 a

Sheet of i

ATTACHMENT 2 (Continued)

Procedure #

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Rev.

. Date i

1 REQUIREMENTS (Continued) 1 l

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NUMBER REVISION DATE PAGE CPSES JOB 35-1195 CCP-30 10 1/26/82 1of 2 CZ-11 CURE TO TOPC0AT TIME 25-50% R. H.

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NUMBER REVISION DATE PAGE CPSES j,

JOB 35-1195 CCP-30 10 1/26/83 2 of 2 1a il i

ATTACHMENT 3 I4 CZ-11 CURE TO TOPCOAT TIME L

50-100% R.H.

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TEMPERATURE F

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PROCEDURE EFFECTIVE J

BROWN & ROOT, INC.

NUMBER REVISION DATE PAGE CPSES i

JOB 35-1195 l

CCP-30 10 1/26/82 1 of 1 t

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ATTACHMENT 4

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POT LIFE - CZ 11 J]

G Hours Max. Pot Life 8I"n.

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POT LIFE PHENOLINE 305 TEMPERATURE (O )

UNTHINNED THINNED-50%

F j'

50 - 54

,10 hrs 24 hrs 55 - 59 7 hrs 24 hrs d

60 - 64 4 hrs 24 hrs 65 - 69 als hrs 24 hrs 70 - 74 2 hrs 24 hrs 75 - 79 1 hrs 24 hrs 80 - 84 I hrs 24 hrs 85 - 89 1h hrs 24 hrs 90 - 95 1 hr 24 hrs Pot life for coatings thinned up to but not including max. amount

j of thinner allowed, use pot life for unthinned material.

.r For spray application, pot life as stated above is recommended maximum times and should be utilized for a basis for coating i^

usage time; however, actual pt life may be longer.

If coating when temperature is above.95 F, or if pot life as stated above 1

j has been exceeded, the actual pot life ends when proper atomization and spraying becomes difficult and the coating loses body and i

begins to sag. When utilizing other than spray application methods.

l' pot life shall be as stated in the above table.

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CCP-30 Rev. 10 DCN #3 9(21/82 Sheet 4 of 4

d ATTACHMENT B iNSTAUC"CN ISSUE

.EVISIC N g-g 4Gg TEXAS UTluT*ES GE.NESAENG CO-NUM E E.7 CPSES I

CI-QP-11. 4-1 3

MAY 2 9 Ic81 1 of 6 m alO 8 Bs.

lb,'

hb A

EPARED3(:.lg.,d.c-J G..., < '

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2:

INSPECTION OF STEEL SUBSTRATE SURFACE PREPARATION APPPOVED3)

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1.0 REFERENCES

1-A CP-QP-11.4, " Inspection of Protective Coatings" 2.0 GENERAL 2.1 PURPOSE AND SCOPE This Instruction wil1 supplement the requi recents of Reference 1-A for inspection of steel substrate surface p repa ra ti on.

The Surface Preparation Inspecticn Checklist (Figure 1) shall be used to document inspecticns.

3.0 INSTRUCTION 3.1 PRE-BLAST CLEANING OPERATIONS 3.1.1 Mbient Conditions The inspector shell determine air temperature, relative humidity and dew point of substrate structures.

A 4

calibrated non-cortury filled dry bulb thennaneter or a i

fcalibrated temperatu're recorter (Bristol 4069 TH or i

equivalent) shall ce used for air temperature de te min-a ti on.

A calibra ted non-mercu ry wet bulb thermaneter or'a calibrated h' midi ty reccrce r (Bristol 4069 u

TH or equiva' lent) shall be used to detemine relative humidity. The dew point shall be cetemined by the i

difference in the dry and wet bulb temperatures using the U.S. Department of Canmerce Weather 3ureau Psychronetric Tables, W.B. No. 235.

The su rface temperature shall be determined t;' placing a calibrated surface tempera 5ure themameter (0mega - Mprove Fastemp, Range 10-250 F) in contact with the substrate surface to be blast cleaned.

The themometer,: robe shall remain in contact with the surface until tne temperature reading stabilizes.

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o INSEUCTCN i l

AEVISICN b

DAGE NUMBER

f. A a..

I TEXAS UT1UT1ES GENE 3ATING CC.

l lQl-QP-11.4-l' 3 MAY 2 9 1981 3 of 6 i

I C ri te ri a :

i SSPC-SP10-63 i

Heavy deposits of oil or grease shall te rencved by T.ethods outlined in SSPC-SP-63, " Solvent Cleanin;".

Small quantities of oil or grease may be rencvec by blast cleaning.

i 3.1.5 Substrate Su rface Projecti ons i

The inspector shall visually examine the substrate surface (including welds) for sham projecticns that will not be blended in by sandblasting or pmer tooling.

I C ri te ri a :

i l

Edges, protrusions, and peaks shall be grounded smooth to a i

rounded contour.

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l NOTE:

a.

Any mechanical surface preparaticn other i

than sandblasting or grinding of sha m edges j

or weld splatter will requi re a B&R NDE i

visual inspector's acceptance of the work j

l pe rf o rmed.

b.

The inspector shal1 notify tne Paint Foreman when items 3.1.1 througn 3.1.5 above a re i

sa tis fact ory.

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3.2 BLAST CLEANING OPERATIONS 3.2.1 Blast Tech,.foue is Acceotable I

l During blast cleaning operations, the inspector shall spot check blasting technique.

Dwell time shall be observed and I

locations noted (for future surface in-spection) where dwell i

time was extended to remove heavy deposits of mill l

scale / rus t.

l 1

C ri te ri a.

I DwelI time wil1 depend on surface conditions (type and i

amount of mill scale / rust).

No finn time limits are i

established for Longer dwell time indicates heavier

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depw i ts o f s...... and these a reas should be identi fieu QMomm '

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INSTRUCTCN ' AEVISICN Ib3N PAGE TEXAS UT1UT1ES GENESADNG CC.

3 CMES QI-QP-11.4-l!

3 'MAY 2 9 1981 '

4 cf 6; i

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I 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 3

abrasive and dust prior to start of final inspecticn.

l C ri te ria :

l I

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 l

j The inspector shall perfom the following inspections to detennine acceptability of the blast cleaned or power tooled l,

i su rface:

a.

Absence of Foreign Matter -- A visual inspecticn shall be perfomed to detemine removal of foreign catter i

fran the su rface.

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C ri te ria :

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SSPC-SP10-63 I

The surface, when viewed withcut magnificaticn, shall be free of all oil, grease, visible mill scale, rust, corrosion products, oxides, paint, or any foreign matter, except for light shadows, slignt streaks, or l

slight discolorations caused by rust stain, mill scale I

oxides, or slight, tight residues of paint.

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b.

Removal of Sharp Projections -- A reinspection for sha rp projections that were not blended (rounded) g during blast cleaning or power tooling shall be pe rfomed.

1 C ri te ria :

Sharp projections (including weld splatters) are not l

acceptable.

Sae note on item 3.1.5 above reganting grinding ope-ons to r'.icve projections.

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INSTRUCTICN f AEVISlCN f^0N PAGE TEXAS UT1UTIES GENERATING CC.

CPSES QI-QP-11. 4-1,j 3 ;MAY 2 9 1981 i S of 6i i

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i 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 Camparator (model 373) or equivalent. A power tooled surface shall be inspected with use of either a roughness gage and/or canparator plate whicn has been approved by the coating manufacturer.

C ri te ria :

Blast Cleaning SSPC-SP10-63T The anchor pattern depth for a blasted surface shall not be less than 1S70 (minimum depth 1.0 mils).

Powe r tooling - Power Tooling (SSPC-SP3-63) may also be used with no Area Restrictions, providing this type prepa ration produces an Acceptable Surface Canpa rable to SSPC-SP10-63T.

The Anchor Oattern Depth for a power tooled surface I

shall not be less than 1 nil.

fio maxinun profile will be specified, providing that correct millage l

requirements can be obtained after priner application.

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i 3.4 FIflAL ACCEPTANCE The inspector shall detennine that all FCRs ano NCRs are canplete prior to signing and dating Final Acceptance on checklist.

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INSTRUCTION ISSUE g g,/ISICN NUMBER DATE PAG:

TEXAS UTILITIES GENERATING CC.

CPSES MAY 2 9 1981 GI-QP-11.4-1 3

6 Of 6 FIGURE 1 QUALITY ASSURANCE DEPARTMENT STEEL SUBSTRATE SURFACE PREPARATION INSPECTION CHECKLIST i

Location:

Building:

Project:

CPSES, Job 35-1195 Unit:

1 TIME OF TEMPERATURE I RELATIVE DEW DAY DRY SUL3 {

WET SULB j S U R F A C F.

l MUMIDITY POINT Results Initial Date 1.

Ambient Conditiona 2.

Air Supply / Sand 3.

Surface Projections 4

Sand 31ast Cleanup 5.

Surface & Profile Acceptable 6.

Absence of Foreign Matter 7

Removal of Sharp Projections COMMENTS FINAL ACCEPTANCE:

Inspector Date t

4

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ATTACHMENT C NO CONFORhhANCE hk)RT (NCR) s:

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PLANT system COMPONENT TACISPIN/lOE N T NO I DH /..'e tNC15PE CIFIC ATION NO.

l SERI AL NO.

p

. COct CODE CODE Al8lCl0lE lF [

G ; (U n.tst l H ; (Unsul I J ! (Units)

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i4 s.10 11 16 17 55 g

g ARMS INDEXED

..t yr.

PURCH ASE ORDE R VEND f

NUN 9BER CODE 5669 7473 DWs g

,021978 P 3

C-903-

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p.t R R HIR VEN DO R'S COUNT l UNITS PU R C H'S HLS/ HOLD NO.l CODE INPUT N

hust BIR NUM9ER H E AT/ LOT / BATCH N O.

Q U AN 18 T Y O R N O.

ST AT Us DATE

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nn 6485 8695 96 105 1C6 ill 112 121 122 127

{3) N ON C C M PO R *4s M G CONDS YtOMs

@ U"IT:

1, 2,M (Circ 1T Une)

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h Aux.

Blde. Elev. 810'

-l; (Material / Structure /Systes) g Room 197 wall E floor M

(Componeat) h N/A A

SEE ATTACHED (Vendor)

@ LOCATION:

Rec., Stora n.

3 (Circic One)

J-C.

Tin i "k%6 dt?l71 2-i 7-70 $ thfllf (3) REPORTED BY:

ll4) DATES H D. u^^

l2.q.,8 PREPa nto sv

'isp pat E:

tvl REveE w/ APPaov AL:

'g,goavg.

H. D. Hash 2 117178

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• S I?or 7[f A1 D

g,g pe Spo se TIO N ASST Gr* E 3 TO.

It a) D' E D ATE O ljCORRECTIVE ACTION REQUEST 8 CARm (4 2) REPO R.T AtsLE oEPtC EnCv U. D. Douglas 3 ' S '78 Req:// red @Not Required OPCs5ence IO~ o (I 3l OtSPOStTION:

REWORM REPAIR USE AS B5 SCRAP 1.

The foot prints and any other irregularities such as pinholes will be touched up in accordance with construction procedure CCP-40, Sec. 4.3.1..

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2.

The soot from the Kelly heater was blown in after initial set.

It will be removed by detergent washing or solvent wiping.

t (t al CO TR.REve i APPROv AL:

gis) o ATEs 1

44 h

2.,2a7g t e s3s A RE ve E w/ APPROV AL (ST) D ATE:

(G B) CUE Evt EW/ A P PR OV ALs g(19) D ATE:

$dhawg l 2192178 Y

W 2;b.

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s t a sl E N G, M E vl E w jA PPR OV Al.

'(Stl O A TEs (33) AN8 R VS EWfA PPR O V k L a

'(33l OATCs b '}b >l2 dt l' i

///AIAfB L,/-19 2

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ta.: vE Re n e C A TeOn s 1343 RE u AR uSi gag j

. G Satisixtory D unsatisractory Not Reg'd.

QA RECORD l'

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I ATTACHMENT TO C-903 t

e4eW TECH 1tii6 I,

23 surfacer may be CCP-40Rev.Ostatesinpart"Ni ly after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> cure."

subjected to personnel foot tr l..

1.

In Upper Auxiliary Room 197 E1. 810' partial floor the 115 surfacer has foot prints in evidence within the first 24 k

hours cure. Hold tag will be placed on door entrance.

2.

Kelly heaters deposited contamination (soot) on 11S surfacer

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on floor.

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INSPECTION R EPORT I

PAGE,1__ Or _ [

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PLANT SYSTEM COMPONENT 1 AG/ SPIN /tDE N T NO CODE CODE CODE A l 8[C[OIElF lj OR AWING / SPECIFICATION NO l SF RI A L NO G; tuneul I Hi IUneal l J ; IUneal 14 5 to 15 16 17 56

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PURCH ASE ORDER VEND y*

NUMSER CODE 5649 7473

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4....

1. ,J,@#

MRR RIR V EN DO R'S COUNT l UNITS PURCH's RLS/ HOLD NO.l CODE INPUT NUMSER NUM8ER HE AT/ LOT /8ATCH NO, OUANTITY OR NO.

ST AT US DA TE 74 79 8085 86 95 96 105 106 111 112 121 172 127 PURPOSE AND TYPE OF INSPECTION / SURVEILLANCE: To O/T M[Is /N ME AIM VnAM osv Aux. GLD6. Eb 8IC' 1% 00M )4 7 w AM. + f/ oo ?

s I

QA IESULTSOF INSPECTION / SURVEILLANCE:[O FOOT /A /NTS

'T-N TNE A/u rec. *//r Swfua w ue n.w a a edo blY sess;< e d se - ces-90 1

1 r

i see. 4. 1.1 62 500+ desoG/s w e e e.

<e moved b v solve ni n,'s, 'n o f

oee c c.p-so.

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w NC3NO&9 0.3 N. 0. Y Y 0.

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/ 7/7a OC ENGINEER /lNSPECTOR #

(en

e ATTACIIMENT D i

TEXAfl.TII.ITIES GENERATING CO.TIFTNY n...., wn.s,.. m u..v.m u....>.

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April 15,1983 TXX-3655 Mr. G. L. Madsen, Chief Reactor Project Branch 1 U. S. Nuclear Regulatory Comission Office of Inspection and Enforcement 611 Ryan Plaza Drive Suite 1000 Docket Nos.:

50-445 50-446 Arlington, Texas 75012 COMANCHE PEAX STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO. 83-07/04 FILE NO.:

10130

Dear Mr. Madsen:

This will serve to document our telephone conversation with T. F. Westeman on April 12, 1983, wherein we requested an extension of the due date for responding to the Notice of Violation contained in NRC Inspection Report No. 83-07/04.

An extension of three working days, until April 18, 1983, was granted.

We have reviewed your letter dated March 14, 1983 on the inspection conducted i

by Messrs. L. D. Gilbert and C. E. Johnson of activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak, Units 1 and 2.

We have responded to the finding listed in Appendix A of that letter.

To aid in the understanding of our response, we have repeated the requirement and your firiding followed by our corrective action.

We feel the enclosed infor-mation to be responsive to the Inspector's finding.

If you have any questions, please advise.

Very truly yours,

'k f~

RJG:aq Enclosures NRC Region IV - (0 + 1 copy) cc:

Director, Inspection & Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, DC 20555

--'- ~

i APPENDIX A fv0TICE OF VIOLATION Texas Utilities Generating Company Docket:

50-445/83-07 Comanche Peak Unit 1 Permit: CPPR-126 Based on the results of an NRC inspection conducted during the period January 27-28 and February 1-2, 1983, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated March 9, 1982, the following violation was identified.

Failure to Follow Procedure Criterion V of Appendix 8 to 10 CFR Part 50 requires that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances, and shall be accomplished in accordance with the procedures.

Brown & Root, Inc., Construction Procedure CP-cpl 4 9.10, Revision 8, paragraph 3.2.4, specifies that the fit-up gap for "T" fillet joints should not exceed 1/16"; however, if the gap is in excess of 1/16", but not exceed-ing 5/32", this condition will be considered acceptable provided the leg of the fillet weld is increased by the amount of separation in excess of 1/16".

Contrary to the above, on January 28, 1983, the NRC inspector determined that Pipe Support Mark No. SW-1-102-105-Y33K had been welded with a fit-up gap of 1/4" at one end of the "T" fillet joint which attached piece 7 to piece 4.

The 1/4" fit-up gap exceeds the 5/32" maximum allowable fit-up gap require-ment of Procedure CP-CMP 9.10.

This is a Severity Level V Violation.

(Supplement 11.E) (445/8307-01)

CORRECTIVE, STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Corrective actions have included the following:

' 1)

Identification of the procedural violation as a nonconfoming condition (NCR-51235);

2) Removal of the affected portions of the pipe support (for investi-gative reasons) and replacement with new materials;

3) Engineering evaluation of the total weld for purposes of evaluating safety consequences, if any.

[

Notice of Violation TXX-3655 As noted above, the pipe support was reworked to comply with design and procedural requirements.

Engineering evaluation of the original as-built conditions revealed the following:

1) The excessive gap occurred at the toe of the skewed angle, and for a distance of six inches tcward the heel on one side and seven inches on the other.

No design cregit is taken for the weld at the g

toe of the angle, as it exceeds 135 (157 ).

Additionally, to account for the corner effect caused by the radius of the tube steel, 2.56 inches of the weld on each side at both the toe and heel is excluded from design consideration. This results in a total eld length (for which design credit is taken) of 10.24 inches on ach side.

2)

Taking no credit for the weld where gap is in excess of 5/32, and excluding 2.56 inches at both the toe and heel, the remaining weld which is within acceptance criteria is 6.8 inches on one side and 5.8 inches on the other.

3)

Design calculaticns based on as-built piping loads indicate a total of 1.6 inches of fillet weld is reauired on both sides to meet structural design requirements.

In summary, had the gap conditicn not been detected, there would be no adverse results.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Affected construction personnel will be reinstructes in the necessity for rigid compliance with design'and procedural requirenents.

DATE OF FULL COMPLIANCE Corrective actions are complete.

Preventive maasures are scheduled to be completed by April 22, 1983.

l

-