ML21012A092

Implementation of QA Criteria and 10 CFR 50.59 for Nuclear Power Plant Components Produced Using Advanced Manufacturing Technologies

ML21012A092
Person / Time
Issue date:	01/14/2021
From:	Christopher Sydnor NRC/NRR/DNRL/NVIB
To:
Anchondo I - NRR/DNRL/NVIB
References
ML20317A005
Download: ML21012A092 (19)

Text

Implementation of QA Criteria and 10 CFR 50.59 For Nuclear Power Plant Components Produced Using Advanced Manufacturing Technologies AMT Action Plan, Revision 1, Subtask 2A Presented By: Christopher Sydnor, NRR U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of New and Renewed Licenses NRR Public Meeting January 14 2021

Overview Objectives & Scope AMTs - QA and 50.59 Emphasis Regulatory Framework QA Criteria 10 CFR 50.59 Process Request for Public Comment Meeting Objectives:

• Introduce the Draft Basis Document on Implementation of QA Criteria & 10 CFR 50.59 for AMT Components, developed under Subtask 2A of the AMT Action Plan, Revision 1.

• Communicate the Objectives and Scope of the Review.

• Request Comments From the Public 2

QA and 50.59 Review - Objectives Purpose of the Draft Paper. Document staff review of how a change to use an AMT component could be implemented at a plant under QA controls and the 10 CFR 50.59 process.

• Changes in the facility made without prior application for NRC review & approval.

• Focus is 10 CFR Part 50, Appendix B and 10 CFR 50.59 requirements and guidance.

• NRC Reactor Oversight - Regional Inspections.

• Document may be used to support regional inspections of licensee implementation of these requirements for changes to use AMT components --- as appropriate under ROP.

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QA and 50.59 Review - Objectives Review Focused on 2 Topics (Ongoing)

1. Identify any generic regulatory & technical challenges for changes in the facility to use AMT components.

2. Provide information and support to regional inspectors to facilitate effective review of licensee implementation of QA and 50.59 requirements, should such a review be deemed appropriate.

Document is not intended to resolve these issues but to help facilitate ongoing work in these areas.

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QA and 50.59 Review - Scope

• Prior to 2019, industry identified 10 CFR 50.59 as the regulatory path for initial AMT components at U.S. NPPs.

• June 2019 - staff performed a preliminary review of the 50.59 process for changes to use AMT components.

• September 2019 thru September 2020 - In-depth development based on consensus inputs from many NRC counterparts.

Multiple rounds of review & comment from regulatory and technical subject matter experts in the Regions, NRR, and RES.

• 2020 - Staffs review expanded to address technical QA criteria for design control & procurement in addition to 50.59.

50.59 process determines need for a license amendment; it relies on prior technical evaluation to ensure change is safe & effective.

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QA and 50.59 Review - Scope The current draft basis document does NOT:

• Represent a complete and final analysis of all aspects of QA & 50.59 requirements or guidance for AMT components.

• Create a new regulatory requirement or new regulatory guidance for use and/or manufacture of AMT components.

Scope is limited to review of existing requirements &

guidance to address AMT components and consideration of potential challenges.

Document may be subject to future revision, as additional insights and OpE for use of AMT components are gained.

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AMTs - QA and 50.59 Emphasis We consider material processing & component fabrication techniques that have not been: Traditionally used in the U.S. nuclear industry.

Formally standardized for U.S. nuclear plants thru:

• Incorporation in 50.55a Codes &

Standards;

• NRC approval or endorsement of an industry submittal (e.g., topical report approval).

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AMTs - QA and 50.59 Emphasis Review is not AMT-specific. AMT refers to a broad range of non-standardized manufacturing processes, fabricated product forms, & associated raw materials.

Technical Context - Materials

• Application focus is currently Science Interrelationship passive structural or mechanical components; items that sustain mechanical forces and do not undergo a change of state.

• End use focus is U.S.

nuclear power plants licensed to operate; 10 CFR Public Domain, https://en.wikipedia.org/wiki/Materials_science Part 50 framework.

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AMTs - QA and 50.59 Emphasis Applicable to AMT repairs and replacements. The term AMT component (or AMT item) generally includes:

• AMT repairs - AMT material addition processes (e.g., advanced welding or deposition techniques) to restore service condition of an existing component.

• AMT replacements - component or part changeouts; changing from a non-AMT item to an item fabricated using AMT.

Technical Evaluation Hierarchy for Plant SSCs Structure / System Component Subcomponent Part

• Part is the most basic of assembly.

• Item is an all inclusive term to refer to plant SSCs (hardware) and/or their constituent parts.

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Initial AMT Application - U.S. NPP Thimble Plugging Device (TPD)

Schematic of Laser Power Bed

• Design function: limit core bypass Fusion (LPBD) Process.

flow in the fuel assemblies (FSAR)

• Additive Manufacturing (AM), Laser Powder Bed Fusion Process

• Non-Code Class & Non-Safety-Related (NSR is plant-specific, per Byron Licensing Basis & 10 CFR 50.2 Definition)

• FSAR - 300-series alloy type; no fabrication specification or standard.

• Passed 10 CFR 50.59 Screening, Oak Ridge National Laboratory, Based on Equivalency Evaluation. https://www.osti.gov/pages/servlets/purl/

• Installed at Byron, U1 Spring 2020 1437906 10

Regulatory Paths - Change to Use AMT Regulatory framework is 10 CFR currently deemed 50.59 sufficient for a change to Changes, use an AMT item. Tests &,

10 CFR Exp. 10 CFR Primary focus is App. B 50.69 21.3 Risk informed 10 CFR of 10 CFR Part 50 and Commercial categorization Part 50, Grade 50.59. & treatment Dedication App. B QA Criteria Consider other connected regs. &

10 CFR 10 CFR guidance, as needed -- 50.55a 50.55a(z) e.g., 50.55a, 21.3, 50.69, Codes & Alternatives NSR guidance, etc. Standards C&S 11

QA Criteria - Overview Appendix B to 10 CFR Part 50, Criteria III, IV, and VII and associated guidance for changes to safety-related SSCs III - Design Control, selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of [SSCs].

Main Emphasis - technical evaluation, including equivalency evaluation of alternate items.

IV - Procurement Document Control, specification of regulatory & design bases req. in a procurement document.

VII - Control of Purchased Material, Equipment, Services, acceptance of purchased items; commercial grade dedication process for non-Appendix B suppliers. (Refs. 10 CFR 21.3, Reg.

Guide 1.164-Endorsed EPRI Guidance on Commercial Grade Dedication) 12

Design Control - Overview Appendix B to 10 CFR Part 50, Criterion III - Design Control

• AMT replacement items - Consider changes to material, fabrication process, other physical properties. (Ref. GL 91-05)

• AMT replacements are alternate items - they are not physically identical to non-AMT items; not a like-for-like replacement. (EPRI Reports 1008256 & 3002002982 Guidance on Technical Eval of Replacement Items and Commercial Grade Dedication)

• Alternate replacement items need an equivalency evaluation to ensure that the design function of the original will be maintained.

• If the design function of the original will not be maintained (i.e., adverse affect of functional performance) use of the item requires engineering design modification.

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Design Control - Overview Appendix B to 10 CFR Part 50, Criterion III - Design Control

• Technical evaluation of alternate items includes functional safety classification (safety-related, NSR, etc.) and equivalency evaluation (Ref. EPRI Report 1008256, Guidance on Technical Evaluation of Replacement Items.)

• Appendix B applies to safety-related SSCs. Alternate items for NSR categories may also need equivalency evaluation based on risk significance, augmented quality classification, and/or description in licensing basis documents (e.g., FSAR).

• Consensus codes and standards for design, construction, fabrication may be controlling with respect to determining equivalency (Ref. ANSE N18.7/ANS 3.2-1976, Section 5.2.13) 14

10 CFR 50.59 Process - NEI 96-07

• Ensure licensees evaluate proposed changes, tests, & experiments (CTE) for effects on the licensing basis - focuses on the FSAR.

• Obtain license amendment if CTE requires a TS change, or if CTE meets one or more of the 8 criteria in 50.59(c)(2).

• 50.59 process is not a design change evaluation or safety determination.

• 50.59 process relies on adequate technical evaluation of the change to ensure it is safe and effective.

Technical Evaluation of Change to Ensure It Is Safe & Effective Application-Specific 10 CFR 50.59 Process - Relies on Adequate Technical Inputs Apply for Applicability Screening Evaluation Amendment?

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AMT 50.59 Review Applicability - Determine whether 50.59 Screening is performed

• Consider 50.59(a) Definitions - change to the facility as described in the FSAR.

• 50.59(c)(4), other regulations that establish more specific criteria for making the change (e.g., 50.55a).

Screening - Determine need for a 50.59 Evaluation.

• Consider if the FSAR cites consensus standards for traditional fabrication (e.g., ASTM specs for cast or wrought product).

• Equivalency vs. Design Mod. - Impact on FSAR-described design function (NEI 96-07, Section 4.2.1.1)

• Changes to numerical inputs vs. elements of evaluation methods (NEI 96-07, Sec. 3.8 and 3.10 definitions)

Evaluation - Determine if a License Amendment (50.90) is Needed

• Evaluate against 8 criteria in 50.59(c)(2).

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Takeaways / Next Steps

• Generic Challenge - Limited U.S. NPP OpE. Additional technical data needed to better understand the scope of design, QA, 50.59 issues for AMT items.

• No specific challenges identified yet; existing requirements and guidance are currently deemed sufficient.

• The draft basis document on QA and 50.59 for AMT components is now released for public comment.

• The final basis document will be formally issued from NRR to the NRC regions to inform ROP inspections of AMT components

• Continue interaction btw. NRC HQ, regional counterparts, and the public on implementation of QA & 50.59 for changes to use AMT.

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Request for Public Comment

• The NRC requests comments from the public on the draft basis document, Implementation of QA Criteria & 10 CFR 50.59 for AMT Components.

• Please submit comments in writing by February 8, 2021, as directed in the Federal Register Notice referenced below.

• Comments received after this date will be considered only if it is practical to do so.

• For Additional Information Please See ADAMS Accession Nos.

o AMT Subtask 2A, QA and 50.59 Draft Basis Document, ML20317A007 (ADAMS Package No. ML20317A005) o Federal Register Notice for QA and 50.59 Draft Basis Document, ML20317A006 (ADAMS Package No. ML20317A005) o NRC AMT Action Plan, Revision 1 - ML19333B980 18

Thank You 19