Part 21 Report - 2003-007-00

EVENT TEXT

10 CFR PART 21 NOTIFICATION - CARBOLINE COMPANY

The following information was obtained from the vendor via facsimile:

"This letter serves to notify the Commission of a potential safety related noncompliance deviation in a basic component as defined in 1OCFR Part 21. The noncompliance involves hard settling of Carboguard 890 Part B; the affected batches are 2A9266L, 2A9275L, and 2H9352L.

"The hard settling of Carboguard 890 Part B would result in a mixed product that would have lower pigment volume concentration (PVC) than standard material that has been uniformly dispersed. Potential deficiencies would be a lack of film build during application as a result of a lower initial viscosity and the fact that some particles from the hard settling may have been dispersed into the mixed product. These particles could result in the clogging of spray gun tips or having particles embedded into the applied coating, which are aesthetically unpleasing. Overall the lack of pigment in the coating film affects the application and aesthetic properties of the coating and not the performance properties. The primary criteria for the epoxy coating's performance are that the stoichiometry of epoxy resin to amine curing agent are not changed by more than 10%. Based upon a prior non-nuclear occurrence we know that the hard settling does not alter the stoichiometry of the coating and the cure of the product will be within the parameters designed by the formulating chemist. Based upon prior testing of numerous coatings for use in nuclear power plants we have not seen any detrimental performance when lower PVC coatings were evaluated. Resin rich coatings are typically gloss coatings and they aid in radiation decontamination and chemical resistance. As such, Carboline does not feel that the performance of the coating will be adversely affected.

"A database has been created documenting all shipments of the affected batches made within the 2002 calendar year to present; approximately 30 utilities/customers are affected. All customers who our records indicate have been shipped batches 2A9266L, 2A9275L, and 2H9352L shall be notified promptly. We are requesting that customers review their stock of Carboguard 890 Part B and return the affected batches for replacement.

"In summary, Carboline has taken appropriate corrective action, notified the NRC, and shall notify all customers promptly."

The affected parties are as follows:

Consumers Energy - Palisades Generating Plant
Energy Steel & Supply- 2715 Padan Street, Auburn Hills, MI
Florida Power & Light - 9760 SW 344th St., Florida City, FL
Hutchinson & Gunter - 715 Grpve Street, Greensburg, PA
Imaging & Sensing Technology - 1ST Conax Nuclear, Inc., Buffalo, NY
Newbury Sandblasting - P0 Box 378, Newbury, OH
Nullifire Ltd. - Torrington Avenue, Coventry, UK
Point Beach Nuclear - 6610 Nuclear Road, Two Rivers, WI
Prairie Island - Welch, MN
AmerenlUE-CIPS - Callaway Plant
Duke Energy Corp - Nuclear Assessment Division, SC
Ellis & Watts - 4325 Slick Lane, Bativa, OH
FirstEnergy, Davis-Besse Oak Harbor, OH
Howden Buffalo - New Philadelphia, OH
Omaha Public Power - Fort Calhoun Nuclear Station
Palmer Industrial Coatings - Williamsport, PA
Rotork Controls - Rochester, NY
TXU Electric - Glen Rose, TX

February 13,2003


United States Nuclear Regulatory Commission
Document Confrol Desk
Washington, DC 20555
Fax: (301) 816-5151


Subject: 1OCFR Part 21, Notification of Potential Safety Related Noncompliance Deviation

Notification By:
Carboline Company
Phone: (314) 644-l000 x2456
Fax: (314) 644-4617

This letter serves to notify the Commission of a potential safety related noncompliance deviation in a basic component as defined in lOCFR Part 21. The noncompliance involves hard settling of Carboguard 890 Part B; the affected batches are 2A9266L, 2A9275L, and 2H9352L

The hard settling of Carboguard 890 Part B would result in a mixed product that would have lower pigment volume concentration (PVC) than standard material that has been unforraly dispersed. Potential deficiencies would be a lack of film build during application as a result of a lower initial viscosity and the fact that some particles from the hard settling may have been dispersed into the mixed product. These particles could result in the clogging of spray gun tips or having particles embedded into the applied coating, which are aesthetically unpleasing. Overall the lack of pigment in the coating film affects the application and aesthetic properties of the coating and not the performance properties. The primary criteria for the epoxy coating's perforrnance are that the stoichiometry of epoxy resin to amine curing agent are not changed by more than 10%. Based upon a prior non-nuclear occurrence we know that the hard settling does not alter the stoichiometry of the coating and the cure of the product will be within the parameters designed by the formulating chemist. Based upon prior testing of numerous coatings for use in nuclear power plants we have not seen any detrimental performance when lower PVC coatings were evaluated. Resin rich coatings are typically gloss coatings and they aid in radiation decontamination and chemical resistance. As such, Carboline does not feel that the performance of the coating will be adversely affected.

A database has been created documenting all shipments of the affected batches made within the 2002 calendar year to present; approximately 30 utilities/customers are affected. All customers who our records indicate have been shipped batches 2A9266L, 2A9275L, and 2H9352L shall be notified promptly. We are requesting that customers review their stock of Carboguard 890 Part B and return the affected batches for replacement.

In sumrnary, Carboline has taken appropriate corrective action, notified the NRC, and shall notify all customers promptly.

If you have any questions or need additional information concerning this notification, do not hesitate to contact Dwayne Meyer, Director, Technical Service at (314) 644-1000 extension 2550, or Marikay Speckert Corporate QA Manager at (314) 644-1000 extension 2456.


Regards,
Dwayne Meyer Marikey Speckert
Director, Technical Service Quality Assurance Manager

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