ML25150A302

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Overview of NRC AMT Draft Guidelines
ML25150A302
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Issue date: 06/05/2025
From: Eric Focht
NRC/RES/DE
To:
ERIC FOCHT 4152094
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Download: ML25150A302 (31)
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OVERVIEW OF U.S. NRC AMT DRAFT GUIDELINES Eric Focht (eric.focht@nrc.gov)

Robert Tregoning (robert.tregoning@nrc.gov)

U.S. NRC Office of Nuclear Regulatory Research Division of Engineering - Materials Engineering Branch Regulatory Frameworks and Technical Approaches for Qualification and Through-Life Performance of Materials in Advanced Reactors June 3-5, 2025 NRC HQ, Rockville, MD The views expressed by the authors do not necessarily reflect those the U.S. Nuclear Regulatory Commission

DRIVERS FOR NRC ACTIVITIES

  • A variety of stakeholders are working toward more widespread use in both existing and future nuclear applications:
  • Vendors and licensees/applicants
  • Identifying candidate applications
  • Developing technical bases for gaining regulatory acceptance
  • Nuclear Energy Institute - Developed advanced manufacturing methods (AMM) roadmap to understand industry needs/interests and assist with regulatory acceptance (2019)
  • Electric Power Research Institute - Developing techniques for large components in small modular reactors, developing data package for LPBF and WA-DED ASME draft Code Cases
  • US Department of Energy - Developed the AMMT 2022 Roadmap
  • Performing basic and applied research, technology development, data infrastructure, and developing a qualification framework to support AMT implementation 2

NRC AMT ACTIVITIES TIMELINE 3

2017 2018 2019 2020 2021 2022 2023 2017 AMT Workshop AMT Action Plan 2020 AMT Workshop AMT UNR initiated 2023 AMT Workshop 2023 AMT NDE Meeting Pre-AMT Action Plan Post-AMT Action Plan NRC begins AMT efforts

AMT ACTION PLAN (2019-2022)

  • The NRC completed the AMT Action Plan which accomplished the following objectives:
  • Assessed the safety significant performance-based differences between AMTs and traditional manufacturing processes.
  • Prepared the NRC staff for potential reviews (five AMTs, modeling, and NDE).
  • Identified and addressed AMT characteristics pertinent to safety that are not managed or addressed by codes, standards, regulations, etc.
  • Risk-informed and performance-based perspective
  • Provided draft Staff guidance and tools for review consistency, communication, and knowledge management.
  • Revision 1 of the AMT Action Plan was published in June 2020 (ML19333B980).

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AMT ACTION PLAN (CONT.)

  • NRC AMT Action Plan products:
  • Technical Letter Reports (TLRs)
  • Provide technical bases information and gap analyses
  • Prepared by NRC contractors (to date, DOE labs)
  • Technical assessments (TAs)
  • Provides the NRC staff perspective on key aspects of the AMT for safety and component performance.
  • Draft guidelines documents (DGDs)
  • Informed by the TA and TLR and generated by the NRC staff for each AMT.
  • Please visit the NRC AMT public website to download the available reports:

Generic Technical (Subtask 1A)

Final Guidance for Initial AMTs Regulatory Guidelines (Subtask 2C)

Technical Letter Report PM-HIP Technical Letter Report EBW NRC Staff-developed Contractor-developed Legend Technical Assessment LPBF Draft Guidelines Document LPBF Draft Guidelines Document L-DED Technical Assessment L-DED Draft Guidelines Document Cold Spray Technical Assessment Cold Spray Draft Guidelines Document PM-HIP Technical Assessment PM-HIP Technical Assessment EBW Draft Guidelines Document EBW Expected to be developed later after DOE-EPRI demo project Subtask 2C Draft AMT Review Guidelines 5

AMT ACTION PLAN PRODUCTS 6

Subtask Actions/Deliverables Status 1A AMT processes under consideration Additive Manufacturing (AM) - Laser Powder Bed Fusion Complete - ML20351A292 AM - Directed Energy Deposition (DED)

Complete - ML21301A077 Cold Spray Complete - ML21263A105 Powder Metallurgy (PM) - Hot Isostatic Pressing (HIP)

Complete - ML22134A437 Electron Beam (EB) welding Complete - ML22143A927 1B Inspection and NDE NDE gap analysis Complete - ML20349A012 1C Modeling and Simulation of Microstructure M&S gap analysis to predict microstructures Complete - ML20269A301 ANL M&S gap analysis to predict material performance Complete - ML20350B550

AMT ACTION PLAN PRODUCTS 7

Subtask Actions / Deliverables Status 2A 50.59 process Finalize document incorporating feedback from Regional staff regarding the 10 CFR 50.59 process Complete - ML21200A222 2B Assessment of regulatory guidance Path forward on guidance development or modification Complete - ML20233A693 2C AMT Guidance Document Draft AMT Review Guidelines Complete - ML21074A037 Draft Guidelines Documents for specific AMTs AM-Laser Powder Bed Fusion - ML21074A040 AM-Laser-Directed Energy Deposition - ML22143A950 Cold Spray - ML22143A950 3A/3B External / Internal Interactions Continued communication with NRC staff and external stakeholders for AMT-related activities Ongoing as needed 3C Knowledge Management Plan Develop Knowledge Management Plan Complete - internal 3D Workshop Hold public workshop Complete - Public Meeting Summary: ML20357B071 RIL: Part 1 Part 2 3E Material Information course Training course and course materials First 6 seminars complete - internal

NRC REGULATORY ASSESSMENT FOR AMT 8

Regulatory Assessment The NRC staff reviewed various regulatory guidance documents such as:

Sections of the standard review plan for LWRs, NUREG-0800 Regulations in 10 CFR 50 Regulatory guides The goals of the review were to:

Identify barriers to efficient and thorough reviews of licensee submittals.

Determine if new guidance or changes to guidance is needed.

The staff limited its review to materials engineering issues applicable to the current operating fleet and new reactors

NRC REGULATORY ASSESSMENT FOR AMT 9

Regulatory Assessment The NRC staff reviewed various regulatory guidance documents such as:

Sections of the standard review plan for LWRs, NUREG-0800 Regulations in 10 CFR 50 Regulatory guides The goals of the review were to:

Identify barriers to efficient and thorough reviews of licensee submittals.

Determine if new guidance or changes to guidance is needed.

The staff limited its review to materials engineering issues applicable to the current operating fleet and new reactors The staffs review of NRC regulations determined there were no impediments to prevent the use of AMTs or inhibit the staffs ability to efficiently and thoroughly review potential licensee submittals for such use.

ASSESSMENT OF QA AND THE 10 CFR 50.59 PROCESS 10 The staff performed a generic review of the quality assurance (QA) criteria in 10 CFR 50 Appendix B, and the process in 10 CFR 50.59 for AMT components The staff focused on identifying:

Generic regulatory and technical challenges.

Additional support NRC inspectors might need Compared to traditional fabrication methods, AMT fabrication involves a significant change to the material and manufacturing process.

The licensees technical evaluation process might include an equivalency evaluation.

If there is no adverse impact on design function, the AMT item may be considered equivalent to the original.

An AMT item is not identical to the original and therefore should not be considered a like-for-like replacement.

DRAFT AMT GUIDELINES DEVELOPMENT 11 Draft AMT Review Guidelines Draft Guidelines Document for Additive ManufacturingLaser Powder Bed Fusion Draft Guidelines Document for Additive ManufacturingLaser Directed Energy Deposition Draft Guidelines Document for Cold Spray DGD Reviews NRC staff Public/Industry

DRAFT AMT GUIDELINES DEVELOPMENT 12 Draft AMT Review Guidelines Draft Guidelines Document for Additive ManufacturingLaser Powder Bed Fusion Draft Guidelines Document for Additive ManufacturingLaser Directed Energy Deposition Draft Guidelines Document for Cold Spray DGD Reviews NRC staff Public/Industry

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 13 Draft AMT Review Guidelines

1. Quality Assurance
2. Process Qualification
3. Supplemental Testing
4. Production Process Control and Verification
5. Performance Monitoring

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 14 Draft AMT Review Guidelines Quality Assurance Process Qualification Supplemental Testing Production Process Control and Verification Performance Monitoring

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 15 Draft AMT Review Guidelines Purpose Identify the range of potential information needed in a submittal requesting NRC approval to use AMT components Technology Agnostic Guidelines were developed not only for AMTs, but also for the potential use of new materials and of materials for new or advanced reactors Sufficient and Flexible Sufficient technical depth Flexible with the goal of minimizing unnecessary technical and regulatory burden

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 16

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 17 Draft AMT Review Guidelines

1. Quality Assurance
2. Process Qualification
3. Supplemental Testing
4. Production Process Control and Verification
5. Performance Monitoring

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 18

1. Quality Assurance Both 10 CFR 50 Appendix B and commercial grade dedication are acceptable QA approaches for AMT-fabricated components.

An applicable QA program will need to establish requirements for process qualification and production process control.

Aspects of calibration, supplemental testing performance monitoring may also be needed.

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 19 Draft AMT Review Guidelines

1. Quality Assurance
2. Process Qualification
3. Supplemental Testing
4. Production Process Control and Verification
5. Performance Monitoring

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 20

2. Process Qualification Defines the processes for fabricating the AMT component and to demonstrate that the resulting component will meet the design requirements.

Identify the process essential variables Evaluate the properties over the range of the essential variables.

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 21 Draft AMT Review Guidelines

1. Quality Assurance
2. Process Qualification
3. Supplemental Testing
4. Production Process Control and Verification
5. Performance Monitoring

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 22

3. Supplemental Testing Might be necessary to demonstrate the AMT-fabricated component performs its intended function at representative service conditions. Ex.:

fracture toughness, environment T&E, component testing T&E, life-cycle T&E Generic demonstrations could use conservative acceptance criteria to cover broad range of requirements.

May be generic or for a specific application Subsequent application-specific demonstrations only need to demonstrate acceptable performance for that specific application that were not covered by the generic demonstration.

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 23 Draft AMT Review Guidelines

1. Quality Assurance
2. Process Qualification
3. Supplemental Testing
4. Production Process Control and Verification
5. Performance Monitoring

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 24

4. Production Process Control and Verification Product verification Establishes that the fabricated product meets the design requirements and can involve property verification, component testing, and post-process examination.

Assures the process qualification requirements are met by monitoring, controlling, or evaluating the essential variables during production against the qualified ranges.

Process verification Can consider aspects such as chemistry, density, microstructure, defect characteristics, hardness, strength, fracture toughness, and surface finish.

Post-process inspection Evaluations to characterize defects or determine density, chemistry, or microstructure.

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 25 Draft AMT Review Guidelines

1. Quality Assurance
2. Process Qualification
3. Supplemental Testing
4. Production Process Control and Verification
5. Performance Monitoring

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT GENERAL REVIEW GUIDELINES 26

5. Performance Monitoring Inspection An inspection program:

is effective ensures compliance with requirements is timely enough for corrective action to be taken Actions that assure that components continue to meet design requirements throughout their entire service life and can incorporate inspections or examinations, surveillance, aging management, and post-service evaluation.

Aging Management Identify, monitor, assess, and mitigate the effects of age-related degradation.

Post-service Evaluation Post-service evaluations can provide:

  • data not generated through inservice inspection
  • data that could be used to supplement the safety case for an AMT

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT AMT-SPECIFIC REVIEW GUIDELINES 27 Draft AMT Review Guidelines Draft Guidelines Document for Additive ManufacturingLaser Powder Bed Fusion Draft Guidelines Document for Additive ManufacturingLaser Directed Energy Deposition Draft Guidelines Document for Cold Spray DGD Reviews NRC staff Public/Industry

DRAFT AMT GUIDELINES DEVELOPMENT DRAFT AMT-SPECIFIC GUIDELINES 28 Draft AMT-Specific Review Guidelines Draft AMT Review Guidelines (generic)

LPBF, L-DED, cold spray The AMT-specific guidelines are based on the NRC assessment of the safety significance of the identified differences between AMTs and traditional manufacturing methods The draft review guidelines along with the DGD for each AMT identify generic and AMT-specific information for submittals.

Review guidelines provide information on:

1. The differences between AMT and traditional manufacturing outlined in the NRC TAs,
2. Guidelines that address the differences in (1), and
3. The key technical information documented in the NRC technical assessment for reference.

POTENTIAL FUTURE ACTIVITIES 29 The ADVANCE Act of 2024 Section 401 Requirement Submit a report that, in part, examines any unique licensing issues or requirements relating to the use, for nuclear energy projects, of:

(i) advance manufacturing processes, (ii) advanced construction techniques, and (iii) rapid improvement or iterative innovation process.

Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024 Section 401 Report The NRC report, in part, identified potential future actions we might take to address items in Section 401.

  • Depending on NRC regulatory needs, technology development, and stakeholder interest, and subject to resource availability and prioritization.

Activities The NRC is engaging stakeholders regarding these potential activities to determine the needs of each activity.

More Information ADVANCE Act public website:

https://www.nrc.gov/about-nrc/governing-laws/advance-act.html.

SUMMARY

  • The NRCs assessment of its current regulatory framework determined there were no impediments or additions needed to review submittals approving the use of AMT-fabricated components.
  • The NRC developed draft review guidelines to help make reviews more efficient.
  • Draft AMT Review Guidelines are generic.
  • AMT-specific draft review guidelines for LPBF, L-DED, and cold spray can be used in conjunction with the generic guidelines to help with the review of submittals.
  • The NRC continues to assess AMTs and is considering potential future activities in support of the ADVANCE Act.

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