ML20196F542

Part 21 Rept Re Evaluations Concerning non-destructive Evaluations (NDE) of TMI-2 Dry Shielded Canisters (DSC at American Boiler Works (Abw)

ML20196F542
Person / Time
Site:	07200020
Issue date:	06/21/1999
From:	Hagers J ENERGY, DEPT. OF, IDAHO OPERATIONS OFFICE
To:	Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
REF-PT21-99 NUDOCS 9906290236
Download: ML20196F542 (13)

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@i Department of Energy 7 Eda Idaho Operations Office 850 Energy Drive Idaho Falls, Idaho 83401-1563 June 21,1999 Dr. D. Blair Spitzberg U. S. Nuclear Regulatory Commission, Region IV 611 Ryan Plaza, Suite 400 Arlington, TX 76011-8064

SUBJECT:

Results of 10 CFR Part 21 Evaluations Conceming Non Destructive Evaluations (NDE) of Three Mile Island Unit 2 (TMI-2) Dry Shielded Canisters (DSC) at American Boiler Works (ABW) (Docket 72-20) (OPE-SNF-99-157)

Dear Dr. Spitzberg:

This letter is to closeout earlier discussions with your staff and NRC headquarters conceming potential supplier deficiencies related to non-destructive examination (NDE) testing at American Boiler Works (ABW), the dry shielded canister (DSC) fabricator for the Three Mile Island Unit 2 (TMI-2) Independent Spent Fuel Storage Installation (ISFSI).

DOE-ID has been, and continues, to evaluate the DSC product supplied by ABW. To facilitate real time inspection of the product, DOE and its Management and Operating (M&O) placed inspectors at the ABW facility from the onset of production. A NRC identified deficiency during the inspection of TMI-2 ISFSI loading activities in February-March 1999 indicated the need for more rigorous supplier inspections. As part of the increased inspection activities, a Supplier Process Deficiency Report (SPDR) was generated concerning the Ultrasonic Examination Testing (UT) of welds during the inspection of DSC #5. This SPDR was transmitted to the supplier for evaluation and action, and my licensing staff for evaluation against the requirements of 10 CFR Part 21.

Initially, it was contemplated that the evaluation of this SPDR would not be completed within the 60 day time requirement of 10 CFR 21.21, and discussions with both your staff and NRC Headquarters staff indicated that an interim Part 21 report was likely to be issued. After this notification, the testing and evaluation to resolve issues with the SPDR were completed, as was

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the 10 CFR Part 21 evaluation. A report of the evaluation is enclosed, along with a timeline of

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events. Corrective actions as outlined at the end of the enclosed report are being followed to closure.

Of utmost concern to both DOE-ID and NRC was the implication that potential UT examination y

process deficiencies could have on DSC #2, which has been loaded and is in storage on the h

TMI-2 ISFSI basemat. With the actions taken to address issues identified in the SPDR, DOE

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has concluded that the UT examination process and results for all DSCs (including DSC #2) is in full compliance with the licensing basis documents and applicable codes, it is also noted that the requirement to volumetrically inspect the bottom cover plate to cylindrical shell joint was not imposed on DOE-ID's contractor until DSC #1 was completed, and accordingly DSC #1 is hold-tagged pending future disposition by DOE-ID.

9906290236 990621 PDR ADOCK 07200020 C

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Mr. D. B. Spitzberg June 21,1999 1

DOE-ID and its M&O Contractor are committed to vigilant and proactive supplier oversight and inspection. DOE-ID appreciates the guidance and input the NRC has provided during this period of transition to external regulation by the NRC, and will continue to be proactive in keeping appropriate NRC staff apprised of any issues that may evolve regarding licensed activities, if you have any questions concerning this or any other TMI-2 or Fort St. Vrain ISFSI issues, please contact the undersigned at 208-526-0758, Charles Maggart at 208-526-5560, or Mark Gardner at 208-526-5655.

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n v)hp g7 /p Jan Hagers Licensing Manager Enclosure cc: P. Eng, NRC NRC Document Control Desk e

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J Report on the American Boiler Works UltrasonicIWethod i

Summary

'l Volumetric examination of the bottom cover plate weld of the DOE /rMI-12T Dry Shielded Canister (DSC) was mandated by Revision 11 of the Scone of Work Statement (WS) for the Idaho Nuclear Technolony Enaineering Center (INTEC) Interim Storane System (ISS) of the Long Term Storane of the Three Mile Ishnd (TMI)-2 Fuel Proiect.

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~ Paragraph 4.9 of this WS invokes the use of ultrasonic examination (UT) in accordance with NB-5000 of the American Society of Mechanical Engineers (ASME) Code. The DSC manufacturer, American Boiler Works (ABW), of Everett, WA developed an ultrasonic procedure to conduct this examination.

ABW placed the examination procedure into production, and somewhat belatedly but as a matter of course, lockheed Martin Idaho Technologies Company (LMITCO) subject matter experts in ultrasonic examination caaducted surveillances of this activity beginning with DSC number 5.

During the surveillances, the LMITCO subject matter experts identified and properly elevated concerns about the ABW UT process, and its effectiveness in detecting welding anomalies. In addition, LMITCO enlisted the help of an outside consultant to provide both additional expertise and independent assessment.

After an exhaustive evaluation of the ABW weld examination process, including a demonstration to the satisfaction of the LMITCO UT Level III examiners, it was concluded that it was adequate and meets the requirements set forth in NB-5000 of the ASME Code. This comprehensive evaluation concluded that all DSC's examined to date were properly examined and that controls are in place to ensure that all future DSC's are i

properly examined. Of particular note, this evaluation confirmed that the ultrasonic examination of DSC number 2 cer.tsining Three Mile Island Unit 2 (TMI-2) core debris I

in the TMI-2 Independent Spent Fuel Storage Installation (ISFSI) was appropriate and

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compliant with governing requirements.

This report documents the issues and their subsequent resolution. Upon LMITCO's j

initial review of the UT Process at ABW, differing opinions developed between LMITCO and Newport News Shipbuilding (NNS), Trans Nuclear - West (TN-W) and ABW. Initially, LMITCO was concerned that the ASME Code had been mis-applied by J

l ABW. As the evaluation proceeded, it became evident that there were differing opinions i

as to the interpretation of the ASME Code with respect to the requirements of ultrasonic examination. As set forth herein, inadequate contract language evolved as the root cause i

of this issue. The inadequate contract language led to a non-constructive defensive dialog between the contracting parties (i.e., LMITCO, NNS, TN-W, and ABW). Ultimately, the issue was resolved when ABW, at the direction of LMITCO, fully demonstrated their existing UT process on a Test Block with embedded flaws. Based on an interactive discussion of test results among project participants, combined with reconciliation of differences of opinion in interpretation of the ASME Code, the ultrasonic examination process was determined to comply with the applicable requirements of the ASME Code.

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7 The ADDlicable ASME Code The inner bottom cover plate on the DOF/rMI-12T Dry Shielded Canister (DSC) is a flat head to main shell configuration. The weld detail is consistent with Detail (f) of figum NB-4243-1 in the ASME Code. Based on this weld detail and the location of the weld joint in the DSC, the weld (joining the bottom cover to the shell) is considered a Category C, Type 2 weld. Paragraph NB-3352.3 requires that Category C welds be capable of being examined in a :cordance with Paragraph NB-5230.

The Code requires that ultrasonic examination be conducted in accordance with Section

-V, Article 5, as given in paragraph NB-5111. Article 5 of Section V, Ultrasonic -

FJEpination Methods for Materials and Fabrication, states in the scope paragraph T-510, that "This Article contains all of the basic technical and methodological requirements for ultrasonic examination."

Article 5 requires a written procedure with 15 specific attributes:

1. Weld configuration;

2. Examination surfaces;

3. Surface condition;

4. Couplant type;

5. Technique (straight beam, angled beam, contact, and/or immersion);

6. Angles and mode of wave propagation;

~ 7. Search unit type and frequency;

8. Special search units;

9. Ultrasonic equipment type;

10. Description of calibration blocks and techniques;

11. Dimetions and type of scanning;

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12. Data to be recorded and method of recording; i

13. Alarmequipment

14. Rotating or revolving mechanisms;

15. Post-examination cleaning.

Article 5 methodology employs a basic calibration block to establish the instrument sensitivity for angle-beam examinations. Instrument sensitivity is influenced by a number of factors, including frequency, transducer size, couplant, surface quality, and the distance of the sound path. The calibration block contains reflectors (side-drilled holes) that provide a predictable and sproducible sensitivity. These side-drilled holes are used to cmate two thresholds, the aference level Distance-Amplitude Correction (DAC) curve and the 20% DAC curve. Once the two DAC curves r.re established, welds may be examined using the angle-beam method. NB-5330 contains the ultrasonic acceptance standards. Indications are evaluated in accordance with paragraph NB-5330. NB-5330 reads as follows:

1 All imperfections which produce a response greater than 20% of the reference level shall be investigated to the extent that the operator can determine the shape, identity and location ~of such imperfections and evaluate them in terms of the acceptance standards given in (a) and (b) below.

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g (a) Imperfections are unacceptable if the indications exceed the reference level amplitude and have lengths exceeding:

(1) 1/4 in, for t up to 3/4 in., inclusive l

(2) 1/3 t for t from 3/4 in. to 21/4 in., inclusive (3) 3/4 in. for t over 21/4 in.

Where t is the thickness of the weld being examined; if a weld joins two members having different thickness' at the weld, t is the thinner of these two thickness'.

(b) Indications characterized as cracks, lack of fusion, or incomplete penetration are unacceptable, regardless oflength.

These acceptance standards are workmanship based. Workmanship based acceptance standards rely on using proven methods and experienced / qualified individuals for t

detection and sizing of flaws that may be present in stmetures. The workmanship-based threshold for acceptance is so low that no flaw that remains in a structure or component has any significance. The operator applies the method and also makes judgements on flaw sizing and type.

It is well understood in the fabrication industry, that neither the Code required ultrasonic examination method (nor any method, for that matter) exactly sizes flaws. The quality of sound reflection from flaws is dependent on their individual orientation to the ultrasonic sound path, the sound beam width, and many other factors. Thus, actual flaws may be larger or smaller than the Code sizing criteria. This has been considered in the Code.

The Code has sizing criteria, based on the established methodology, and detection limits of that methodology. Thus,it is important to recognize that the acceptance of the Code workmanship standards is based on application of the established methodology and not to flaw size per se. The sensitivity of the method is set, and any indications that exceed the Code workmanship criteria are considered rejectable.

Bottom Closure Weld Ultrasonic NDE Issues Volumetric examination of the bottom cover plate weld of the DOE /TMI-12T Dry Shielded Canister (DSC) was mandated by revision 11 of the Scope of Work Statement 1

for the INTEC Interim Storane System (ISS) of the Long Term Storage of the TMI-2 Fuel Pmiect (licensed as the TMI-2 ISFSI under SNM-2508). Paragraph 4.9 of this WS

. invokes the use of ultrasonic examination in accordance with NB-5000 of the ASME Code. This change applied to DSC's 2 through 29, with DSC 1 not included and awaiting disposition on the non-conformance with ultrasonic inspection requirements.

The DSC manufacturer, ABW of Everett, WA, developed an ultrasonic procedure to conduct this examination. ABW subcontracted this examination to Certified Inspection Services Inc. (CISI), who utilized the ABW procedure for the ultrasonic inspections.

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h Starting with DSC number 5, LMITCO'UT level III examiners conducted surveillances of the ultrasonic examinations. During the surveillances, the LMITCO subject-matter experts identified and properly elevated concems about the ABW process, and the ability -

of their pmcess to detect welding anomalies of concern to quality in the bottom cover plate weld.

The areas of cor2rn identified by the LMITCO UT Ievel III examiners were detailed in L

Supplier Process Deficiency Report (SPDR) QS-7250-1999-7-1 (attached). The areas can be summarized as being in three categories:

1.' Lack of objective evidence of ABW's UT Procedure Qualification; in effect, no confirmation that the ABW procedure was capable of detecting and characterizing

small flaws. These aspects relate to search angle and transducer size.

2. ABW procedure UT02 did not adequately address reporting requirements of the ultrasonic examinations.

3. ABW did not have appropriate documentation of their calibration sequence.

LMITCO's opinion at the time was that ABW's calibration block did not meet j

Code mquirements.

The sub-contractor's (ABW, through TN-W and NNS) position on these concerns was that in their collective view, the methods employed by ABW met Code requirements.

This contradicted the LMITCO position with respect to the Code requirements. Pursuant to analysis of the two positions, it was determined that the Code requirements encompassed both the ABW view and the LMITCO view. Additionally, it was found, j

through demonstration of technique, that the ABW method has the required sensitivity and meets the Code.

i Demonstration of the Ultrasonic Technieue at ABW A test block was procured by LMITCO from FlawTech, Inc., a company in the business of producing weld examination test blocks with known flaws. The demonstration block is a T-Joint configuration representing the actual configuration of the subject DSC welds.

The demonstration block contains area (s) of lack of fusion, lack of penetration, fatigue cracking, and an EDM (Electrical Discharge Machined) notch. LMITCO provided this block to ABW for use in demonstrating that the ultrasonic method described in UT02 would detect flaws, which would meet the Code workmanship acceptance criteria of NB-5330.

On May 26,1999, a Level III UT inspector for CISI representing ABW, performed a demonstration / qualification of the applicable portion of Ultrasonic Weld Inspection Procedure, ABW UT02 with a supplemental 45' shear wave examination ofindications greater than or equal to 20% DAC as found by the 70* shear wave examination. The demonstrr. tion was witnessed by representatives from ABW, NNS, and LMITCO.

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4 Prior to the demonstration / qualification, LMITCO personnel marked the locations of the i

indications (total of six) on the demonstration block. The demonstration block with the location ofindications visible was pmsented to the level III UT inspector for CISI for the demonstration. It should be noted that only locations of indications were provided, not actual flaw sizes and types. Locations were provided for qualification of the procedure specified equipment parameters (i.e., search angle and transducer size, etcf and not the individual. The level III examiner performing the demonstration was already certified in accordance with code requirements. Additionally, LMITCO provided the Level III UT inspector for CISI, with a copy of the LMITCO mport that contained documentation of results of an ultrasonic examination by LMITCO using the ABW methods. This was done to provide CISI with an understanding of what was required by LMITCO for documentation of the demonstration / qualification.

First, calibration of the 0* Iongitudinal Wave.500" diameter KB-Aerotech transducer was performed using a calibration block as required by the Code. Data was then recorded from the side C test block reflectors.

-Second, calibration of the 70* Shear Wave.75" X.75" KB-Aerotech transducer was performed. Data was then recorded from the side A then side B reflectors, six each side, of the test block.

Third, calibration of the 45' Shear Wave.75" X.75" KB-Aerotech transducer was performed. Data was then recorded from the side A then side B reflectors, six each side, of the test block.

Then, a post-test calibration of the instrument was conducted after each examination of these flaws. The instrument passed post-test calibration. After each of the three calibration tests, the calibration method was found to meet Code requirements.

The. demonstration / examination resulted in measured amplitude of five of the six indications being 2:100% DAC. These, if they had been in a DSC, would have been rejectable and requimd repair. and re-examination. The sixth indication produced a response of appmximately 90% DAC. The ABW procedum would require that this flaw be characterized, as requimd by the Code. According to the maker of this test block, this indication was intended to be a 1/8 by 1/8. inch lack of penetratia. The technique, as demonstrated, did not produce a rejectable condition based on amedwde for the 1/8 by 1/8-inch flaw. However, it is believed that if the examiner characterized this flaw diffemntly'(as a slag indication, for example) that there would be no consequence from leaving this flaw in the item. Such a flaw is insignificant, considering the workmanship standard. It is further concluded that planar indications exceeding this size would be detected and rejected. Therefore the ABW procedure is deemed adequate to meet the workmanship requirements of NB-5330.

The demonstration.also served to retroactively validate UT examinations conducted previously, as the same process and practices were implemented by ABW at the outset (from the date of revision 11 to the WS). ABW had made no changes to actual working 1

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practices up to the time of the demonstration, so past work is also determined to meet the

- workmanship requirements of NB-5330.

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The last remaining issue is the documentation of ultrasonic examinations. The LMITCO practice for ultrasonic examinations to meet Code requirements has been to carefully document all examination re.sults. The LMITCO UT Izvel III' examiner was of the position that Anicle 5 paragraph T-591 applies. This paragraph reads as follows:

"A repon of examinations shall be made. The repon shall include a record indicating the weld (s) or volume examined (this may be marked up sketched), the location of each recorded reflector, and the identification of the operator who

. carried out each examination or part thereof as detailed in T-593. "

The LMITCO documentation process meets this requirement.

The ABW position was that paragraph T-593 modified this requirement with the following sentence:

"For each ultrasonic examination, the following information should be identified and recorded.' The referencing Code Section shall be consulted for specific requirements."

ABW's position was that the operative word, "should", changed the "shall" of T-591 to an option. Further, the referencing Code Section, NB-5000 does not contain specifics about documentation of results. ABW concluded that since NB-5000 does not require this' level of documentation there was not a need to do so. Both sides of this issue maintain their position is supported by the Code. Understanding the difference in Code interpretation, LMITCO took the action to modify the contract to resolve the reponing requirement issue.

This difference in professional opinion about Code requirements led to the appearance that ABW procedures were inadequate. The differences in Code interpretations and the

. complicated contractual relationships between LMITCO, NNS, TN-W and ABW led to a non-constructive defensive posture between all concerned parties.

The differences in Code interpretation and the complicated contractual relationships interfered with the open and honest ' dialog between manufacturer / supplier and the owner / purchaser characteristic of the nuclear industry. The purchaser is expected to

- monitor the activities of the manufacturer and to be proactive in identifying deficiencies that affect or have the potential to affect quality and to see to their correction. The defensive posturing'in this instance was removed by bringing all panies together face to face and airing all differences in real time 'until they were resolved. Had the contract language clearly specified technical and reporting requirements, the difference in opinion of application of the Code would not have occurred.

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Final closure to this issue will occur upon the completion of the following actions:

1. ABW will provide final documentation of the demonstration / qualification conducted on May 26,1999. This documentation shall include the ultrasonic examination report and the ultrasonic calibration report.

2. For all subsequent UT examinations, LMITCO requires the UT test report to include all attributes of Article 5, paragraph T-590 to be implemented and to include additional information as set f arth in the LMITCO Test Report Form.

3. LMITCO requires that ABW's UT Procedure, No. UT02, Rev. I be revised to state what is actually being performed; specifically that the 45 shear wave is utilized to l

i evaluate indications greater than or equal to 20% DAC found by the 70 shear wave.

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4. ABW will provide a written statement that the following effect for DSC's 2 through I

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i Ultrasonic examination was in accordance with the applicable portions of e

Procedure ABW UT02, Rev.1 as demonstrated to LMITCO on May 26,1999.

Evaluation of all indications greater than or equal to 20% DAC, as found by j

the 70 shear wave scan were done using a supplemental 45 shear wave scan.

Once these actions are completed, all issues surrounding the ultrasonic examination of the bottom cover plate weld shall be considered closed.

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Report on the Arnerican Boiler Works Ultrasonic Method Signature Page This page identifies the authors of the above titled position paper. Signature below by the preparers indicates concurrence with the contents of this paper.

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/s/- original signature on file l

Dan E. Crisp, LMITCO TMI Program Manager

/s/- original signature on file Allen M Porter, LMITCO UT Level III Examiner

/s/- original signature on file Chris T. Brown, LMITCO UT Level III Examiner

/s/- original signature on file Jerry D. Barker, LMITCO TMI Qaality Engineer

/s/- original signature on file Brian J. Kruse, P.E., Duke Engineering and Services ASME Code Consultant

/s/- original signature on file Robert D. Davis, DOE-ID Nuclear Spent Fuel, QA Program Manager

/s/- original signature on file Mark D. Gardner, DOE-ID TMI-2 ISFSI l

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9 Dry Shielded Canister Ultrasonic Testing Evaluation Chronology

Background:

DOE was informed by NRC that exemption from the ASME Code requirements for a volumetric weld examination of the bottom cover plate to cylindrical shell joint on the Three Mile Island Unit 2 (TMI-2) Independent Spent Fuel Storage Installation (ISFSI) dry shielded canisters (DSCs) would not be approved. Accordingly, Lockheed Martin Idaho Technologies Company (LMITCO), DOE's Management and Operating contractor at the Idaho National Engineering and Environmental Laboratory (INEEL) changed the scope of work requiring ultrasonic testing (UT) of this weld on 7 January 1999 for DSCs #2 through #30. The fabrication schedule for the first dry shielded canister (DSC-1)-did not permit performance of the UT of the j

subject weld by the fabricator and LMITCO agreed to accept DSC-1 with a provisional certificate denoting that the UT had not been performed. Disposition of DSC #1 is curantly being evaluated.

1 Chronolony of Events:

1 MAR 99 Fabrication (including the required UT) of DSC #2 was completed. The supplier subsequently transported DSC-2 to the INEEL.

1 MAR 99 DSC #2 document package is reviewed (including certificates from American Boiler Works [ABW] and Transnuclear West [TN-W) that DSC #2 conformed to all specifications) at ABW by a LMITCO team beginning March I and ending March 24. In the course of the review of the DSC #2 data package, LMITCO did not review the ABW UT procedure or the UT report by UT professionals.

15 MAR 99 DSC #2 arrives at INEEL and is hold-tagged by Quality Assurance pending receipt and review of the associated document package.

19 MAR 99 The Nuclear Regulatory Commission issued materials license SNM-2508 to DOE.

l 24 MAR 99 Upon completion of DSC #2 document package, LMITCO Projects turns over the DSC and document package to Operations and removes hold-tag.

28 MAR 99 After preparation of eight TMI-2 canisters (dewatering and drying), DSC-2 was loaded and sealed.

29 MAR 99 As part of the corrective actions associated with the RT concerns raised during the review of the DSC #1 and DSC #2 data packages, it is decided to supplement the DOE /LMITCO vendor onsite QA presence with LMITCO NDE experts to review RT data at certain holdpoints, to review the fabricator's UT process (starting with DSC-5), and to observe selected UT activities at the fabricator.

31 MAR 99 The loaded DSC-2 was transported to the ISFSI and placed into storage.

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4 31 MAR 99 A review of the fabricator's UT process and surveillance of selected UT activities is performed. The surveillance is performed on a portion of the fabrication and testing for DSC-5. (Additional reviews and surveillances are ongoing.) In the course of this review and surveillance, concerns were identified and documented.

5 APR 99 Draft surveillance report is provided to LMITCO QA. Based on this surveillance report, a Supplier Process Deficiency Report (SPDR) is written and issued to the supplier on April 8,1999. DOE QA and Management personnel are notified of the concerns with the UT process being used at ABW. NOTE: The concerns identified were determined to be applicable to all DSCs fabricated using the UT process (all DSCs after DSC-1) with DSC-2 being of primary concern because it was loaded with spent fuel.

23 APR 99 Supplier responds to LMITCO's SPDR with resolution of comments.

30 APR 99 LMITCO reviews supplier comment resolutions and determines some answers are not acceptable. The main issue among LMITCO's NDE professionals is the lack of apparent demonstration of the UT method and the associated calibration.

LMITCO issues response to supplier requesting additional action.

NOTE:

LMITCO's concerns with the demonstration of the UT method were associated with the capability of the UT method to detect flaws of concern to quality.

7 MAY 99 LMITCO issues contract change order requiring a demonstration of the UT method.

12 MAY 99 Utilizing a Flaw Tech designed and fabricated UT Test Block supplied by LMITCO, ABW attempts demonstration of their UT process but the demonstration is not accepted by LMITCO because the UT probe that was used 4

was not in accordance with the procedure used for DSC-2. The specifics of the first demonstration are as follows: Following a contract modification directing ABW to demonstrate their UTprocess to LMITCO, a Level 111 UT examinerfor CISI, representing ABW, performed a demonstration /quahfication of the applicable portion of ultrasonic weld inspection procedure, ABW UT02 with a supplemental 45 degree shear wave examination ofindications greater than or equal to 20% DAC asfound by the 70 degree shear wave examination. During the course of the demonstration / quahfication a I1flTCO Level ill determined that the 70 degree transducer being used was not the same type and size as the transducer used for the DSC examinations. (The original transducer was l

damaged and was no longer usable.) Additionally, it was determined that the transducer did not meet the requirements specified in the procedure.

Upon completion of the demonstration in a post demonstration meeting with I1flTCO/NNS/TNW/ABW/ CIS1, the use of a different probe was discussed. The position of NNS/TNW/ ABW/CISI was that the probe was considered to be equivalent to that specified in the procedure. 1111TCO determined that rather than performing a transducer equivalency demonstration, the original procedure demonstration /quahfication must be performed again using the procedure L

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Details of the diference in the procedure requiredprobe versus the replacement probe are asfollows: ABW UT02, Revision 1 required the use of a 70 degree angle beam examination using a 3/4" by 3/4" KB Aerotech transducer. Due to damage to the specified probe, ABW chose to proceed with an alternative transducer, specifically, a 1"x 0.5" Panametrics Transducer. Although close in area, the shape is significantly diferent, which could result in significantly different beam divergence and sensitivity. LMITCO also noted that the 45 degree transducer usedfor evaluation was also diferent than that used during previous examinations. Previous evaluations were performed with a KB Aerotech 3/4" x 3/4 " 45 degree shear wave. During the demonstration, the examiner used a 5/8" by 5/8" transducer. The brand was not noted. Neither transducer used during the demonstration was consistent with those transducers used during previous DSC examinations. (This event was not discussed in the ABWReport, as it did not directly in and ofitself, lead to the closure of the issue)

'24 MAY 99 LMITCO obtains services of NDE consultant to resolve differences of opinion between ABW and LMITCO NDE professionals.

- 24 MAY 99 LMITCO successfully demonstrates the ABW UT procedure at the INEEL using assumed parameters for the UT equipment.

26 MAY 99 ABW performs successful demonstration utilizing their procedure for the UT process used for DSCs 2 through 9. Demonstration is witnessed and accepted by LMITCO's UT Level III examiners and NDE consultant.

2 JUN 99 LMITCO (with assistance of NDE consultant) completes write up of UT Evaluation Paper (i.e., events leading up to UT demonstration and acceptance of ABW's UT process).

2 JUN 99 10 CFR 21 evaluation was completed, concluding a significant safety hazard does not exist with the proposed condition.

19 JUN 99 Final documentation of the UT demonstration / qualification and ultrasonic calibration report received from NNS.

21 JUN 99 Originating SPDR closed.

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