ML093020560
| ML093020560 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde, Hope Creek, Pilgrim, Brunswick, Waterford |
| Issue date: | 10/23/2009 |
| From: | Schofield M Hilti |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML093020560 (4) | |
Text
Hilti, Inc.
5400 South 122nd East Avenue Tulsa, OK 74146 (918) 252-6000 October 23, 2009 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Re:
Notification of a 10 CFR Part 21 relevant discovery for Hilti KB3 anchors
Subject:
Potential delivery of nonconforming washers supplied with expansion anchors type Hilti Kwik Bolt KB3 SS316, 1/4" and 3/8" diameters, all lengths, which may meet the definition of a "defect" within 10 CFR Part 21.
Products affected by this notification: Stainless steel Hilti Kwik Bolt 3 type KB3 SS316
- Item#282565 KB3 SS316 1/4"'x.2,1/4" Lot# 10908397 Item # 282566 KB3 SS316 1/4" x 3 1/4" Lot# 10770600 Lot # 10893786 Item # 282567 KB3 SS316 3/8" x 3" Lot# 10770517 Item-# 282568 KB3 SS316 3/8" x 3 3/4",
Lot # 10855730
'Lot # 10893787 Lot # 10913214 Lot # 10992219 Description of nonconformance:
Hilti was informed by a non-nuclear-related customer that stainless steel Kwik Bolt KB3 SS316 3/8" x 3 3/4" anchors, installed in a waste water treatment facility, showed rust stains on the washers approximately 18 months after installation. Subsequent chemical analysis of provided samples showed these washers were made of Grade SS430Ti stainless steel instead of the specified Grade SS316.
Our internal investigation: enabled us to identify all stainless steel washers received for assembly since-the stainless: steel Grade-,SS316 K1B3 anchor was introduced in 2005. As a result we have identified a specific receipt of nonconforming washers, sizes 1/4" and 3/8", in
,.u*-,
Notification: Page 1
Hilti, Inc.
5400 South 122nd East Avenue Tulsa, OK 74146 (918) 252-6000 the second half of 2007. We have identified all production lot numbers that were potentially affected, and an earliest potential date of delivery to end-user customers of October 1, 2007.
According to our sales records a total of 10 safety-related orders, to 5 facilities, covering a total quantity of 1300 anchors, have been placed by our nuclear customers, but none of them with a request for lot traceability. Therefore, we cannot rule out the possibility that some anchors of the affected lots were delivered in the above orders. A list of all potentially affected safety-related purchase orders with customer details is attached.
Analysis of potential concern:
Investigation indicates Grade SS430Ti has significantly lower corrosion resistance compared to Grade SS316, and is generally recommended for mildly corrosive environments.
In addition, when in contact with the SS316 nut, a galvanic cell may develop, resulting in accelerated deterioration of the washer. Depending on the environment, degradation of the washer may occur over time. While our preliminary analysis indicates there is no immediate safety hazard that would result in failure of an anchorage, the potential eventual deterioration of the washer could have two effects identified to-date: (1) reduction or loss of clamping force; and (2) reduction in thebearing surface area resisting the baseplate pulling over the nut.
Loss of clamping force is not expected to affect performance of the anchor itself. However, applications which rely on clamping force to maintain proper function of the attachment should be further evaluated. Since dynamic loading conditions (the most common potential clamping-critical application) are not one of the recommended applications for this anchor, coupled with the affected anchors being relatively small in' diameter, clamping-critical applications would not generally be expected.
As to pullover, our preliminary analysis indicates it does not occur with a baseplate of typical thickness and a clearance hole diameter specified in Hilti technical literature.
However, use of a thin baseplate and/or a significantly oversized clearance hole would require further evaluation.
In summary, our preliminary analysis indicates the nonconformance would not, in ordinary and typical application, have any substantial adverse effect on performance of the anchorage.
The potential for an adverse effect would be associated with the specific application and corrosive conditions. Because we are not aware of specific conditions of use, we are unable to determine whether the nonconformance could or will result in a substantial safety hazard (i.e., a "defect", as defined in Part 21).
Required action:
Notification: Page 2
Hilti, Inc.
5400 South 12 2nd East Avenue Tulsa, OK 74146 (918) 252-6000 I= Il*-u We recommend customers use the attached list of purchase orders, and item and lot numbers, to determine whether there is any evidence the affected product was received. Alternatively, identification of nonconforming washers on previously installed anchors can be accomplished by magnetic check.
Installations incorporating nonconforming products should be evaluated to determine the potential effect on the attachment.
If you have any questions or concerns, please contact:
Tom Horan Quality Manager, Hilti, Inc.
918.872.3606 Tom.horan(&hilti.com Sincerely, Hilti, Inc.
Martin Schofield VP, Product Safety/Liability 706.227.9218 MaiLt.schofield.2ihilti.com Cc: (attachment for below entities contain only purchase information relevant to that entity)
PSE & G Nuclear LLC Regulatory Assurance Mail Stop: S05 P.O. Box 236 Hancocks Bridge, NJ 08038 Progress Energy Site Vice President Brunswick Nuclear Plant N.C. Hwy, 87 Box 10429 Southport, NC 28461 cc: Progress Energy Site SUPV-Lic/Reg Prog Brunswick Nuclear Plant N.C. Hwy, 87 Box 10429 Southport, NC.28461 Entergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Attn: Manager, Operating Experience M-ECH-595 Arizona Public Service Co.
P.O. Box 52034, Mail Station 7990 Phoenix, AZ 85072 Attn: Procurement Engineering Section Leader Entergy Operations, Inc P.O. Box 31995 Jackson, MS 39286-1995 Attn: Manager, Operating Experience M-ECH-595 Notification: Page 3
Hilti, Inc.
5400 South 12 2nd East Avenue Tulsa, OK 74146 (918) 252-6000 i:ii-.~r Re:
Notification of a 10 CFR Part 21 relevant discovery for Hilti KB3 anchors Attachment - NRC Potentially Affected Safety-Related Purchase Orders October 23, 2009 Customer Date of Shipment Customer Quantity Item Name P.O. #
P S E & G November 1, 2007 4500428782 1 box @ 100/box
- 282565 Nuclear 1/4" x 2-1/4" PS E & G August 21, 2008 4500475069 2 boxes @ 100/box
- 282565 Nuclear 1/4" x 2-1/4" Entergy December 18, 2008 10219662 1 box @ 100/box
- 282565 Nuclear /
1/4" x 2-1/4" Pilgrim Progress October 24, 2007 346032 1 box @ 100/box
- 282566 Energy /
1/4" x 3-1/4" Brunswick Progress January 24, 2008 359508 1 box @ 100/box
- 252566 Energy /
1/4" x 3-1/4" Brunswick Progress February 27, 2008 365403 1 box @ 50/box
- 282568 Energy /
3/8" x 3-3/4" Brunswick Progress March 13, 2008 367162 1 box @ 50/box
- 282568 Energy /
March 14, 2008 3 boxes @ 50/box
- 282568 Brunswick 3/8" x 3-3/4" Progress March 13, 2009 428764 4 boxes @ 50/box
- 282568 Energy /
.3/8" x 3-3/4" Brunswick Arizona October 16, 2008 500525800 4 boxes@ 50/box
- 282567 Public 3/8" x 3" Service Co.
Entergy September 24, 2009 10252405 1 box @ 50/box
- 282568 Waterford 3 3/8" x 3-3/4"