ML25323A290
| ML25323A290 | |
| Person / Time | |
|---|---|
| Site: | 99902028, Nuclear Energy Institute |
| Issue date: | 11/14/2025 |
| From: | Stuhldreher T Nuclear Energy Institute |
| To: | Jardaneh M NRC/NRR/DNRL, Document Control Desk |
| Shared Package | |
| ML25323A289 | List: |
| References | |
| Download: ML25323A290 (1) | |
Text
Tim Stuhldreher Director Phone: 202.993.4429 Email: tjs@nei.org November 14, 2025 Mahmoud Jardaneh Chief New Reactor Licensing Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Submission of EPRI White Paper: A Whitepaper Regarding the Risk-informed Safety Classification of Pressure Boundary Components for New Construction Project Number: 689
Dear Mr. Jardaneh:
On behalf of the Nuclear Energy Institute (NEI)1 and its members, we are pleased to submit the enclosed white paper, A Whitepaper Regarding the Risk-informed Safety Classification of Pressure Boundary Components for New Construction, for the U.S. Nuclear Regulatory Commission (NRC) staffs consideration and preliminary feedback.
The white paper proposes a risk-informed approach to categorizing pressure boundary structures, systems and components (SSCs) according to safety significance and to determine the Risk-Informed Safety Classification (RISC class) for use in advanced reactor plant construction. This methodology is consistent with other NRC approved risk classification guidance such as implemented at Arkansas Nuclear One Unit 2 (ML090930246) and Oconee Units 1, 2, and 3 (ML23262A976). This methodology is also consistent with the American Society of Mechanical Engineers (ASME) Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1.
For ASME Class 2 and 3 pressure boundary (SSCs) that are determined to be of low safety significance (LSS),
this white paper also presents examples for alternatives to existing requirements.
1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Mr. Mahmoud Jardaneh November 14, 2025 Page 2 Nuclear Energy Institute While this methodology was developed with the intent of application to light water reactor (LWR) designs, it is also applicable to non-LWR technologies, provided that conditional core damage probability (CCDP) and conditional large early release probability (CLERP) are applicable, or, if appropriate, alternatives to these metrics can be developed.
The report supports the goals of the recent Executive Orders, the ADVANCE Act and the 2023 amendments to the National Environmental Policy Act (NEPA), which call for timely and efficient regulatory review and deployment of nuclear technologies. As such, reviewing and subsequently approving this proposed approach would support achieving:
- 1. A predictable regulatory path for licensees to perform risk-informed classification of pressure-retaining SSCs for new construction
- 2. NRCs objectives for regulatory clarity and efficiency
- 3. The development of regulatory guidance necessary for new reactor deployment
- 4. The efficiency of new construction requirements
- 5. The engagement of additional vendors to support new nuclear construction projects To this end, we seek the NRC staffs feedback on the following:
- 1. Whether the overall approach for risk-informed categorization of SSCs and alternative requirements is reasonable
- 2. Whether there are gaps or additional technical details that the NRC staff would need to have submitted in order to review and endorse this approach With the benefit of NRC feedback, whether in writing or in public meetings, we would plan to develop a Topical Report on this subject and submit it for the NRC staffs approval. Feedback is requrested by March 30, 2026.
Please contact me if you have any questions or require additional information.
Sincerely, Timothy Stuhldreher Director, Component Integrity
Enclosure:
EPRI White Paper: A Whitepaper Regarding the Risk-informed Safety Classification of Pressure Boundary Components for New Construction (October 2025) cc:
Michelle Gonzalez, APLA, DRA, NRR Shilp Vasavada, DRA, NRR NRC Document Control Desk