ML21257A219

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AMT Subtask 2C - Generic Guidelines - September 16, 2021 Public Webinar
ML21257A219
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Issue date: 09/16/2021
From: Robert Davis
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NRC Draft Advanced Manufacturing Technologies (AMT) Review Guidelines Robert Davis Senior Materials Engineer Office of Nuclear Reactor Regulation September 16, 2021

NRC AMT Focus

  • AMTs are techniques and material processing methods
  • Not traditionally used in the U.S. nuclear industry
  • Not formally standardized/codified by the nuclear industry
  • Initial AMTs based on industry interest:
  • Laser Powder Bed Fusion (LPBF)
  • Laser Direct Energy Deposition (L-DED)
  • Cold Spray
  • Electron Beam Welding (Already Permitted by ASME Code Section III)

AMT Action Plan In June 2020, the NRC drafted Revision 1 of its Advanced Manufacturing Technologies Action Plan (NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML19333B980):

  • Assess the need for guidance updates
  • Ensure NRC staff preparedness to review AMT applications for the Nuclear Industry
  • The AMT Action Plan
  • Task 1: Technical preparedness
  • Task 2: Regulatory preparedness
  • Task 3: Communications and knowledge management 3

Task 1 - Technical Preparedness Activities

  • Subtask 1A: AMT Processes under Consideration
  • Perform a technical assessment of multiple selected AMTs of interest
  • Gap assessment for each selected AMTs vs traditional manufacturing techniques
  • Technical assessment document for each report developed by AMT team: LPBF - ML20351A292
  • Subtask 1B: NDE Gap Assessment
  • Subtask 1C: Microstructural and Modeling
  • Evaluate modeling and simulation tools used to predict the initial microstructure, material properties and component integrity of AMT components
  • Identify existing gaps and challenges that are unique to AMT compared to conventional manufacturing processes:
  • Predicting Initial Microstructures: Complete (ML20269A301); Predicting Material Performance: Complete (ML20350B550) 4

Task 2 - Regulatory Preparedness Activities

  • Provide guidance and support to regional inspectors regarding AMTs implemented under 50.59.

Complete: ML21155A043

  • Subtask 2B: Assessment of Regulatory Guidance
  • Assess whether any regulatory guidance needs to be updated or created to clarify the process for reviewing submittals with AMT components. Complete: ML20233A693
  • Subtask 2C: AMT Guidelines Document
  • Develop a report which describes the generic technical information to be addressed in AMT submissions.

Technology specific guidelines also developed.

Task 3 - Communications and KM Activities

  • Subtask 3A: Internal Interactions
  • Internal coordination with NRC staff in other areas (e.g., advanced reactors, dry storage, fuels)
  • Subtask 3B: External Interactions
  • Engagement with codes and standards, industry, research, international
  • Subtask 3C: Knowledge Management
  • Seminars, public meetings, training, knowledge capture tools
  • Subtask 3D: Public Workshop
  • RIL 2021-03: Part 1 Part 2
  • Subtask 3E: AMT Materials Information Course
  • Internal NRC staff training
  • 5 seminars to date on a variety of topics 6

NRC Guidelines for AMT

  • A Technical Letter Report (TLR) will be generated for each of the initial five AMTs (i.e., LPBF, L-DED, Cold Spray, Electron Beam Welding, PM-HIP)
  • Provides technical basis information and gap analysis
  • Written by NRC contractors (National Labs)
  • A Technical Assessment (TA) document will be prepared for each TLR by NRC staff to provide context to the gaps identified in the TLR from NRCs perspective.

Highlights key technical information related to the specific AMTs use for nuclear applications

  • A Draft Guidelines Document (DGD) will be generated by NRC staff from the TA and TLR for each AMT to accompany the AMT Review Guidelines 7

NRC AMT Guidelines Development AMT-Specific (Initial 5 AMTs) Generic Technical Regulatory Guidelines (Subtask 1A) (draft for public comment)

Draft Technical Technical Guidelines Letter Report Assessment Document LPBF LPBF LPBF ML20351A292 ML20351A292 ML21074A040 Draft Technical Technical Guidelines Letter Report Assessment Document L-DED L-DED L-DED Subtask 2C Draft Draft AMT Technical Technical Final Guidance Guidelines Review Letter Report Assessment for Initial AMTs Document Guidelines Cold Spray Cold Spray Cold Spray ML21074A037 Draft Technical Technical Guidelines Letter Report Assessment PM-HIP PM-HIP Document PM-HIP Expected to Draft be developed Legend Technical Technical Letter Report Assessment Guidelines Document later after Contractor-developed EBW EBW EBW DOE-EPRI NRC Staff-developed demo project

Purpose of Todays Meeting Discuss and receive stakeholder input on the following documents:

  • Draft Advanced Manufacturing Technologies Review Guidelines (Task 2C)
  • Written to assist NRC staff in the review of submittals requesting to use AMTs
  • Draft Guidelines Document (DGD) for Additive Manufacturing-Laser Powder Bed Fusion (LPBF) - Next presentation
  • Provide NRC staff with guidelines for conducting reviews of submittals that include components manufactured using additive manufacturinglaser powder bed fusion (LPBF).
  • Companion document for Draft Advanced Manufacturing Technologies Review Guidelines 9

Draft Advanced Manufacturing Technologies Review Guidelines

  • Provides guidelines to assist NRC staff reviewing requests to use AMTs
  • Identifies the range of information that could be necessary in a submittal
  • Information provided in a submittal would depend on several factors
  • Maturity of the AMT
  • Codes and standards
  • Prior precedent
  • Safety significance of the intended use of the AMT
  • Could be potentially be used for staff review of new material and material for new or advanced reactors. Not applicable to the fuels area
  • Concepts could be considered for transportation and storage under 10 CFR Part 71 and Part 72 10

Draft Advanced Manufacturing Technologies Review Guidelines

  • Provides generic information to be supplemented with separate AMT-specific draft guidelines documents on the following
  • the differences between the AMT relative to traditional manufacturing methods
  • the safety significance of the identified differences
  • the aspects of each AMT that are not currently addressed by codes and standards or regulations
  • AMT specific guidelines documents will address five AMTs
  • laser powder bed fusion (LPBF)
  • laser directed energy deposition (L-DED)
  • powder metallurgy - hot isostatic pressing (PM-HIP)
  • electron beam (EB) welding
  • cold spray 11

Draft Advanced Manufacturing Technologies Review Guidelines

  • General Review Philosophy
  • Sufficient
  • All important (i.e., safety-significant or safety-related) attributes for the specific application of an AMT are addressed in sufficient technical depth to justify its use.
  • Flexible
  • A variety of both technical and regulatory approaches can be used to demonstrate that these important attributes are addressed.
  • Minimize technical and regulatory burden
  • The level of detail in which a submittal must address the applicable requirements and technical basis may vary depending on the safety significance of the application and the maturity of the AMT.

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Regulatory Pathways for AMT Implementation

  • Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments
  • License amendment (e.g., technical specification change) 10 CFR 50.90
  • Change in regulations through the rulemaking process

10 CFR 50.59 and AMTs

  • 10 CFR 50.59 is a change process that uses screening questions to determine if a change can be made without NRC approval.
  • The staff prepared a paper describing a generic review process for the implementation of an AMT component in accordance with
  • Two AMT components have been installed using the 50.59 process.
  • Byron Unit 1 thimble plugging device
  • Browns Ferry Unit 2 channel fasteners 14

First US Application of Additive Manufacturing

  • Thimble Plugging Device
  • Installed in March 2020 in Byron Unit 1
  • 316L stainless steel - LPBF
  • Very low safety significant component (Non ASME B&PV Code class)
  • PWR environment with irradiation
  • Installation done without prior NRC approval under 10 CFR 50.59 15

Second US Application of Additive Manufacturing

  • Channel Fastener
  • Installed in April 2021 at Browns Ferry Unit 2
  • 316L stainless steel - LPBF
  • BWR environment with irradiation

Credit: Framatome 16

Regulatory Pathways for ASME Components

  • NRC approved Alternatives to codes and standards requirements.
  • ASME Code Section XI Code Cases (When listed in Regulatory Guide 1.147 Inservice Inspection Code Case Acceptability, ASME Code Section XI, Division 1.)

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Regulatory Pathways for ASME Components

  • 10 CFR 50.55a(z) Alternatives to codes and standards requirements may be granted by the Director, Office of Nuclear Reactor Regulation. The applicant or licensee must demonstrate that:
  • 10 CFR 50.55a(z)(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or
  • 10 CFR 50.55a(z)(2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety
  • When listed in Regulatory Guide (RG) 1.84 or 1.147 a code case can be used without requesting NRC approval. Note that any conditions listed in the RG for the use of a code case would need to be addressed
  • Code cases not yet listed in RGs 1.84 or 1.147, may be requested for use as part of a proposed alternative by a licensee or applicant in accordance with (z)(1) or (z)(2) above 18

Two Approaches for AMT Implementation

  • Equivalency Approach
  • Demonstrate that the attributes of an AMT meet the licensees current licensing requirements
  • Engineering Design Modification Approach
  • Provide a technical basis for the changes to the existing design requirement(s).
  • A modification would be coupled with a demonstration that the AMT will meet the modified requirement(s).

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NRC Review of AMT Submittals Focus on the qualification and performance attributes specific to the AMT component (as opposed to those of its traditionally manufactured counterpart) and on their relevance to design requirements and component performance.

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Appendix A Process Flow Chart 21

Appendix A Process Flow Chart Legend Generic or submittal-specific Submittal-specific 22

Appendix A Process Flow Chart Legend Generic or submittal-specific Submittal-specific 23

Appendix A Process Flow Chart

  • Describes an approach to qualification and performance considerations.

- Includes considerations related to underlying materials and fabrication processes

- Flowchart illustrates approach that covers broad range of AMTs

- Submittal does not have to include all the information in the flowchart

- Submittal may leverage relevant aspects of ASME Code, Sections II and III as well as ASTM International standards that prescribe testing requirements

- Supplemental testing or performance monitoring may be used.

- Use of an AMT ASME Code Case endorsed in Regulatory Guide 1.84 or 1.147 does not require NRC approval 24

Appendix A Quality Assurance

  • Commercial-Grade Dedication (CGD): provides reasonable assurance that a commercial-grade item to be used as a basic component will perform its intended safety function and, in this respect, is deemed equivalent to an item designed and manufactured under a 10 CFR Part 50, Appendix B, QA program. Electric Power Research Institute (EPRI) 3002002982, Revision 1 to EPRI NP-5652 and TR-102260. Endorsed in NRC Regulatory Guide 1.164 25

Appendix A Process Qualification

  • Essential Variable Identification
  • Identify essential variables and acceptable ranges
  • Includes essential variables for post processing necessary for adequate performance
  • Qualification Testing
  • Evaluation over essential variable ranges of required properties
  • Tensile strength
  • Yield strength
  • Hardness
  • Chemistry
  • Impact properties 26

Appendix A Supplemental Testing

  • May be needed to demonstrate that the material and component properties will meet the design requirements in the applicable service environmental conditions
  • Could include environmental effects such as fatigue life, corrosion, creep, and irradiation
  • May be testing performed on material from prototype components or witness samples shown to be representative of the component
  • Component testing can be used to directly demonstrate that certain design requirements are satisfied (e.g., burst testing of a pressure-retaining component)
  • Performance monitoring can also be used to demonstrate adequate performance of an AMT over its service lifetime 27

Appendix A Production Process Control and Verification

  • Process Control
  • Direct monitoring, controlling, or evaluating the essential variables during production to make sure they fall within the qualified ranges
  • May include in situ monitoring during the production process (e.g., to measure temperatures or porosity).
  • Recovery actions if the essential variables are not met
  • Product Verification
  • Strategy to verify the quality of each fabricated product.
  • May include property verification (e.g., through witness testing),

component testing, and post-process examination (NDE or destructive) 28

Appendix A Performance Monitoring

  • Inspection
  • To detect age-related degradation and ensure that the component meets service requirements, similar to ASME Section XI inspection approach
  • Codified techniques and acceptance criteria that have been demonstrated or justified to be sufficient for the AMT, or demonstrated in submittal
  • Can be implemented similar to approaches in GALL or GALL-SLR reports
  • Post-Service Evaluation
  • To yield information on material properties and performance after time in service
  • Can supplement the safety case for an AMT with a less robust design basis or margin
  • Could support related future AMT applications with higher safety significance 29

Appendix B Graded Approaches for Assessing AMT Submittals

  • The level of detail to which an AMT submittal addresses the five elements in Appendix A (quality assurance, process qualification, supplemental testing, production process control and verification, and performance monitoring) depends on many factors, including the following:
  • the safety and risk significance of the AMT-fabricated component
  • the maturity of the AMT in the codes and standards arena
  • relevant experience (nuclear or nonnuclear) with the AMT
  • NRC staff has developed an example of a graded approach to qualitatively identify the type and level of information (within a specific flowchart element) that may provide a sufficient technical basis for an efficient review 30

Appendix B: Graded Approach Examples

  • Scenario 1: Nonnuclear Industry Standards
  • Demonstrate the relevance of its nonnuclear standards to the current application and address aspects such as the different service environments, the different design requirements, and the unique verification issues in the nuclear context.
  • Consider the issues of high importance identified in the applicable AMT technology-specific guidelines that nonnuclear standards and operational experience do not address
  • Scenario 2: Non-NRC-Endorsed ASME Code Provision
  • Provide a thorough technical justification for the use of the AMT because the Code Case has not been endorsed by the NRC. Justification could include relevant background information used in the development of the Code Case, such as test data, white papers, and other information.

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Appendix B: Graded Approach Examples

  • Scenario 3: NRC-Endorsed ASME Code Provision
  • No additional information is warranted in this scenario beyond that required by other regulation or required by any condition placed on a code case listed in RG 1.84 or 1.147
  • Other Circumstances:
  • Depends primarily on safety significance, AMT maturity, and AMT experience 32

Questions ?????

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