Regulatory Analysis for 50.46c Proposed Rule

Regulatory Analysis for Proposed Rulemaking 10 CFR 50.46c:
“Emergency Core Cooling System Performance during Loss-of-Coolant Accidents”
March 24, 2014

U.S. Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
Division of Policy and Rulemaking

Table of Contents
Abbreviations ............................................................................................................................... iv
1.

Introduction ............................................................................................................................ 1
1.1

2.

3.

4.

5.

Background .................................................................................................................... 1

Statement of the Problem and Objective ............................................................................... 7
2.1

Statement of the Problem ............................................................................................... 7

2.2

Objectives ....................................................................................................................... 9

2.3

Disaggregation ............................................................................................................. 10

Identification and Preliminary Analysis of Alternative Approaches ...................................... 12
3.1

No-Action Alternative .................................................................................................... 12

3.2

Proposed Rule Alternative ............................................................................................ 13

3.3

Regulatory Guidance .................................................................................................... 14

Estimation and Evaluation of Values and Impacts ............................................................... 15
4.1

Assumptions ................................................................................................................. 16

4.2

Industry Implementation ............................................................................................... 18

4.3

NRC Implementation .................................................................................................... 20

4.4

Industry Operation ........................................................................................................ 21

4.5

NRC Operation ............................................................................................................. 22

4.6

Improvements in Knowledge ........................................................................................ 22

4.7

Regulatory Efficiency .................................................................................................... 23

4.8

Public Health (Accident) ............................................................................................... 23

4.9

Occupational Health (Accident) .................................................................................... 23

4.10

Onsite Property ............................................................................................................. 23

4.11

Offsite Property ............................................................................................................. 24

4.12

Attributes Not Affected .................................................................................................. 24

Presentation of Results ........................................................................................................ 24
5.1

Industry Implementation Costs ..................................................................................... 24

5.2

Industry Operation Costs .............................................................................................. 29

5.3

Total Industry Costs ...................................................................................................... 31

5.3.1

Industry Average Implementation Costs per Designated Unit ............................... 31

5.4

NRC Implementation Costs .......................................................................................... 31

5.5

NRC Operation Costs ................................................................................................... 35

5.6

Total NRC Costs ........................................................................................................... 36

5.7

Total Rule Costs ........................................................................................................... 36
ii

5.8

Future Design Certifications ......................................................................................... 36

5.9

Hypothetical Future Operating Reactors ...................................................................... 37

6.

Decision Rationale ............................................................................................................... 39

7.

Implementation .................................................................................................................... 39
7.1

Proposed Rule .............................................................................................................. 39

7.2

Regulatory Guidance .................................................................................................... 41

Appendix A – References ......................................................................................................... A-1
Appendix B -- Tables ................................................................................................................ B-1

iii

Abbreviations
ADAMS – Agencywide Documents Access and Management System
ANL – Argonne National Laboratory
AOR – Analysis of Record
BWR – Boiling Water Reactor
CFR – Code of Federal Regulations
CP-ECR – Cathcart-Pawel – Equivalent Cladding Reacted
DG – Draft Regulatory Guide
ECCS – Emergency Core Cooling System
ECR – Equivalent Cladding Reacted
FR – Federal Register
FRN – Federal Register Notice
FTE – Full-time Equivalent
GDC – General Design Criterion
GSI – Generic Safety Issue
LAR – License Amendment Request
LTC – Long-Term Cooling
LOCA – Loss-of-Coolant Accident
LWR – Light Water Reactor
NEI- Nuclear Energy Institute
NRC – United States Nuclear Regulatory Commission
PCT – Peak Cladding Temperature
PQD – Post Quench Ductility
PRA – Probabilistic Risk Assessment
PRM – Petition for Rulemaking
PWR – Pressurized Water Reactor
RIL – Research Information Letter
RIN – Regulation Identifier Number
RG – Final Regulatory Guide
SRM – Staff Requirements Memorandum
SOC – Statement of Considerations
STPNOC – South Texas Project Nuclear Operating Company
iv

UFSAR – Updated Final Safety Analysis Report
TR – Topical Report

v

1.

Introduction
This document presents a regulatory analysis of a proposed rule (and implementing

regulatory guidance) that would amend Title 10 of the Code of Federal Regulations (10 CFR)
by establishing new, performance-based requirements for emergency core cooling systems
(ECCS) for light water nuclear power reactors.

1.1

Background
In SECY-98-300, “Options for Risk-Informed Revisions to 10 CFR Part 50-‘Domestic

Licensing of Production and Utilization Facilities,’” dated December 23, 1998 (the U.S. Nuclear
Regulatory Commission’s (NRC) Agencywide Documents Access and Management Systems
(ADAMS) Accession No. ML992870048), the NRC began to explore approaches to riskinforming its regulations for nuclear power reactors. One alternative (termed “Option 3”)
involved making risk-informed changes to the specific requirements in the body of 10 CFR Part
50. As the NRC began to develop its approach to risk-informing these requirements, it sought
stakeholder input in public meetings. Two of the regulations identified by industry as potentially
benefitting from risk-informed changes were §§ 50.44 and 50.46. Section 50.44 specifies the
requirements for combustible gas control inside reactor containment structures, and § 50.46
specifies the requirements for light-water power reactor emergency core cooling systems. For
§ 50.46, the potential was identified for making risk-informed changes to requirements for both
ECCS cooling performance and ECCS analysis acceptance criteria in § 50.46(b).
On March 14, 2000, as amended on April 12, 2000, the Nuclear Energy Institute (NEI)
submitted a petition for rulemaking (PRM) requesting that the NRC amend its regulations in
§§ 50.44 and 50.46 (PRM-50-71) (ADAMS Accession No. ML003723791). The NEI petition
noted that these two regulations apply to only two specific zirconium-alloy fuel cladding

1

materials (zircaloy and ZIRLOTM). The NEI stated that reactor fuel vendors1 had subsequently
developed new cladding materials other than zircaloy and ZIRLOTM and that, in order for
licensees to use these new materials under the regulations, licensees had to request NRC
approval of exemptions from §§ 50.44 and 50.46.
On May 31, 2000, the NRC published a notice of receipt in the Federal Register
(65 FR 34599) and requested public comment. The public comment period ended on August
14, 2000, and the NRC received 11 public comment letters from public citizens and the nuclear
industry. Although the majority of the comments generally supported the requests of the PRM,
one commenter suggested that the enhanced efficiency of the proposal would be at the
expense of public health and safety. The NRC disagrees with that commenter and notes that,
while the petition’s proposal would remove specific zirconium-alloy names from the regulation,
the NRC review and approval of specific zirconium-alloys for use as reactor fuel cladding would
be required prior to their use in reactors (with the exception of lead test assemblies permitted by
technical specifications). A detailed discussion of the public comments submitted on PRM-5071 is contained in a separate document (see Section IX of the proposed rule Statement of
Considerations (SOC), “Availability of Documents.”)
After evaluating the petition and public comments received, the NRC decided that
PRM-50-71 should be considered in the rulemaking process. The NRC’s determination was
published in the Federal Register on November 6, 2008 (73 FR 66000). Because most of the
issues raised in this PRM pertain to § 50.46, the PRM is addressed in this proposed rule. The
PRM also requested changes to § 50.44. Those changes were addressed in a rulemaking that
revised that section (68 FR 54123; September 16, 2003) to include risk-informed requirements
1

For the purpose of this analysis, the term “vendor” refers to manufacturers of NRC approved fuel
assembly designs. To support implementation of the proposed requirements on individual plant dockets,
fuel vendors would submit for NRC review alloy-specific hydrogen uptake models and LOCA model
updates.

2

for combustible gas control. The regulation was also modified to be applicable to all boiling or
pressurized water reactors regardless of the type of fuel cladding material used.
On March 31, 2003, in response to SECY-02-0057, “Update to SECY-01-0133, ‘Fourth
Status Report on Study of Risk-Informed Changes to the Technical Requirements of
10 CFR Part 50 (Option 3) and Recommendations on Risk-Informed Changes to 10 CFR 50.46
(ECCS Acceptance Criteria)’” (ADAMS Accession No. ML020660607), the Commission issued
a staff requirements memorandum (SRM) (ADAMS Accession No. ML030910476) directing the
NRC staff to move forward to risk-inform its regulations in a number of specific areas. Among
other things, this SRM directed the staff to modify the ECCS acceptance criteria to provide a
more performance-based approach to the ECCS requirements in § 50.46.
Separate from the effort to modify the regulations to provide a more risk-informed,
performance-based regulatory approach, the NRC had also undertaken a fuel cladding research
program to investigate the behavior of high-exposure fuel cladding under accident conditions.
This research program included an extensive loss-of-coolant accident (LOCA) research and
testing program at Argonne National Laboratory (ANL), as well as jointly-funded programs at the
Kurchatov Institute (supported by the French Institute for Radiological Protection and Nuclear
Safety and the NRC) and the Halden Reactor project (a jointly-funded program under the
auspices of the Organization for Economic Cooperative Development – Nuclear Energy Agency,
sponsored by national organizations in 18 countries), to develop the body of technical
information needed to support the new regulations.
The effects of both alloy composition and fuel burnup (the extent to which fuel is used in
a reactor) on cladding embrittlement (i.e., loss of ductility) under accident conditions were
studied in these research programs. The research programs identified new cladding
embrittlement mechanisms and expanded the NRC’s knowledge of previously identified
mechanisms. The research results revealed that alloy composition has a minor effect on
3

embrittlement, but that the cladding corrosion that occurs as fuel burnup increases has a
substantial effect on embrittlement. One of the major findings of the NRC’s research program
was that hydrogen, which is absorbed in the cladding as a result of zirconium oxidation (i.e.,
corrosion) under normal operation, has a significant influence on embrittlement during a
postulated LOCA. Increased hydrogen content increases both the solubility of oxygen in
zirconium and the rate at which it is diffused within the metal, thus increasing the amount of
oxygen in the metal during high temperature oxidation in LOCA conditions. Further, the NRC’s
research program found that oxygen from the oxide fuel pellets enters the cladding from the
inner surface if a bonding layer exists between the fuel pellet and the cladding, in addition to the
oxygen that enters from the oxide layer on the outside of the cladding. Moreover, under some
small-break LOCA conditions (such as extended time-at-temperature around 1,000 degrees
Celsius (°C) (1832 degrees Fahrenheit (°F))), the accumulating oxide on the surface of the
cladding can break up, allowing large amounts of hydrogen to diffuse into the cladding,
exacerbating the embrittlement process.
The research results also confirmed a previous finding that if cladding rupture occurs
during a LOCA, large amounts of hydrogen from the steam-cladding reaction can enter the
cladding inside surface near the rupture location. These research findings have been
summarized in Research Information Letter (RIL)-0801, “Technical Basis for Revision of
Embrittlement Criteria in 10 CFR 50.46” (ADAMS Accession No. ML081350225), and the
detailed experimental results from the program at ANL are contained in NUREG/CR-6967,
“Cladding Embrittlement during Postulated Loss-of-Coolant Accidents” (ADAMS Accession No.
ML082130389). Since the publication of NUREG/CR-6967 and RIL-0801, additional testing was
conducted related to the embrittlement phenomenon, which was documented in supplemental
reports. Where the additional testing relates to conclusions and recommendations in RIL-0801,

4

RIL-0801 has been supplemented to reference the additional reports and incorporate findings
(ADAMS Accession No. ML113050484).
The NRC publicly released the technical basis information in RIL-0801 on May 30, 2008,
and NUREG/CR-6967 on July 31, 2008. Also on July 31, 2008, the NRC published in the
Federal Register a notice of availability of the RIL and NUREG/CR-6967, together with a
request for comments (73 FR 44778). In that notice, the NRC stated that these documents and
comments on the documents would be discussed at a public workshop to be scheduled for
September 2008. The public workshop was held on September 24, 2008, and included
presentations and open discussion among representatives of the NRC, international regulatory
and research agencies, domestic and international commercial power firms, fuel vendors, and
the general public. A summary of the workshop, including a list of attendees and presentations,
is available in ADAMS under Accession No. ML083010496. The NRC has not prepared
responses to comments received on the technical basis information as a result of the July 31,
2008, Federal Register notice (FRN) (including comments received at the September 2008
public workshop), because: 1) the public workshop was held, in part, to discuss public
comments on the technical basis information; and 2) further opportunity to comment is available
during the proposed rule’s formal public comment period.
Based upon a preliminary safety assessment in response to the research findings in
RIL-0801, the NRC determined that immediate regulatory action was not required, and that
changes to the ECCS acceptance criteria to account for these new findings could reasonably be
addressed through the rulemaking process. Recognizing that finalization and implementation of
the new ECCS requirements would take several years, the NRC completed a more detailed
safety assessment which confirmed current plant safety for every operating reactor. See
Section III.A of the proposed rule SOC for further information.

5

On March 15, 2007, Mark Leyse (the petitioner) submitted a PRM to the NRC (ADAMS
Accession No. ML070871368) requesting that all holders of operating licenses for nuclear
power plants be required to operate such plants at operating conditions (e.g., levels of power
production, and light-water coolant chemistries) necessary to effectively limit the thickness of
crud2 and/or oxide layers on fuel rod cladding surfaces. The petitioner requests that the NRC
conduct rulemaking in the following three specific areas:
1) Establish regulations that require licensees to operate light-water power reactors
under conditions that are effective in limiting the thickness of crud and/or oxide layers on
zirconium-clad fuel in order to ensure compliance with § 50.46(b) ECCS acceptance criteria;
2) Amend appendix K to 10 CFR part 50 to explicitly require that steady-state
temperature distribution and stored energy in the reactor fuel at the onset of a postulated LOCA
be calculated by factoring in the role that the thermal resistance of crud deposits and/or oxide
layers plays in increasing the stored energy in the fuel (these requirements also need to apply to
any NRC-approved, best-estimate ECCS evaluation models used in lieu of
appendix K to 10 CFR part 50 calculations); and
3) Amend § 50.46 to specify a maximum allowable percentage of hydrogen content in
(fuel rod) cladding.
On May 23, 2007, the NRC published a notice of receipt for this petition in the Federal
Register (72 FR 28902) and requested public comment. The public comment period ended on
August 6, 2007. Comments in support of PRM-50-84 were provided by the Union of Concerned
Scientists, two individuals, and the petitioner. The NEI and Strategic Teaming and Resource
Sharing organization submitted comments in opposition to the petition. After evaluating the

2

For the purpose of this discussion, the NRC defines “crud” as any foreign substance deposited on the
surface of the fuel cladding prior to the initiation of a LOCA. It is known that this layer can impede the
transfer of heat.

6

public comments, the NRC resolved PRM-50-84 by deciding that each of the petitioner’s issues
should be considered in the rulemaking process. The NRC’s determination, including the
NRC’s response to public comments received on the petition, was published in the Federal
Register on November 25, 2008 (73 FR 71564). Because the issues raised in the petition
pertain to ECCS analysis and acceptance criteria, the need for rulemaking to address each of
the petitioner’s concerns will be addressed in this proposed rule.
The proposed rule would provide a risk-informed approach to address the effects of
debris on long-term cooling. This approach could be used to close all actions related to Generic
Safety Issue (GSI)-191, “Assessment of Debris Accumulation on Pressurized Water Reactor
Sump Performance,” which concluded that debris could clog the containment sump strainers in
pressurized water reactors (PWRs) leading to the loss of net positive suction head for the ECCS
and containment spray system pumps. The NRC issued Generic Letter (GL) 2004-02,
“Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis
Accidents at Pressurized-Water Reactors,” dated September 13, 2004 (ADAMS Accession No.
ML042360586), requesting that licensees address the issues raised by GSI-191. The staff also
prepared several Commission papers on GSI-191 and had numerous public interactions on the
same subject. For additional background information, please see SECY-12-0093, “Closure
Options for Generic Safety Issue – 191, Assessment of Debris Accumulation on
Pressurized-Water Reactor Sump Performance,” dated July 9, 2012 (ADAMS Accession No.
ML121320270).

2.

Statement of the Problem and Objective

2.1

Statement of the Problem

7

The proposed action is needed in response to recent research by ANL, the Kurchatov
Institute, and the Halden Reactor project into the behavior of fuel cladding under accident
conditions, mainly a LOCA. This research indicated that the current combination of peak
cladding temperature (PCT) (2200 °F (1204 °C)) and local cladding oxidation criteria (17
percent) do not always ensure post quench ductility (PQD) following a postulated LOCA. The
proposed action would replace the limits on PCT and local oxidation with specific cladding
performance requirements and acceptance criteria that ensure that an adequate level of
cladding ductility is maintained throughout the postulated LOCA. The NRC developed three
draft regulatory guides (DGs) that provide acceptable means of meeting the proposed
performance requirements. The three DGs are: DG-1261, “Conducting Periodic Testing for
Breakaway Oxidation Behavior” (ADAMS Accession No. ML12284A324); DG-1262, “Testing for
Post Quench Ductility” (ADAMS Accession No. ML12284A325); and DG-1263, “Establishing
Analytical Limits for Zirconium-Based Alloy Cladding” (ADAMS Accession No. ML12284A323).
The proposal to expand applicability to all light-water nuclear power reactors, regardless
of fuel design or cladding material used, is necessary to account for the development of new
fuel designs and cladding materials other than zircaloy and ZIRLOTM. Under the current rule,
licensees that use different types of cladding material are required to request NRC approval for
an exemption from the rule.
The proposal would also require licensees to evaluate thermal effects of crud and oxide
layers that accumulate on fuel cladding. This proposed amendment would address one of the
requests of PRM-50-84.
Lastly, the NRC identified the need for an approach that would allow entities to address
the effects of debris on long-term cooling in a manner that would be more timely and
cost-effective for some licensees than the current use of deterministic methods. The proposed

8

rule would contain a provision that would allow licensees to use an alternative risk-informed
approach to evaluate the effects of debris for long-term cooling (LTC).

2.2

Objectives
The principal objectives of the proposed revision to the requirements for ECCS

performance for light-water nuclear power reactors are to provide more performance-based
criteria and also account for the new research information. Further, the NRC intends to expand
the applicability of the rule to all fuel design and fuel cladding materials. In addition, this
proposed rule would address the issues raised in PRM-50-71 and PRM-50-84. This proposed
rule would also provide an alternative approach for addressing the effects of debris on long-term
cooling.
As noted in Section V of the proposed rule SOC, and expanded upon in Section XVIII of
the SOC, “Backfitting and Issue Finality,” this rulemaking is proposed because of the NRC’s
position that it is necessary to ensure adequate protection to the public health and safety. The
proposed rule would ensure that the level of protection intended to be achieved by the current
rule is maintained. Regulatory guidance, in the form of three DGs, were developed in order to:
(1) provide a clear, acceptable methodology for supporting and establishing the performancebased regulatory limits called for in § 50.46c; (2) simplify the NRC staff’s review process; and
(3) reduce regulatory uncertainty and thereby help to minimize the costs associated with the
implementation of the regulatory requirements proposed for § 50.46c.
This regulatory analysis was developed following the “Regulatory Analysis Guidelines of
the U.S. Nuclear Regulatory Commission”3 (Guidelines). In particular, with regard to adequate
protection, the Guidelines state that, “The level of protection constituting ‘adequate protection’ is
3

NUREG/BR-0058, Revision 4, “Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory
Commission,” Office of Nuclear Regulatory Research, September 2004 (http://www.nrc.gov/readingrm/doc-collections/nuregs/brochures/br0058/#pub-info).

9

that level which must be assured without regard to cost” (emphasis added). The Guidelines
also state that “ . . . a proposed backfit to one or more of the facilities regulated under 10 CFR
part 50 does not require a regulatory analysis if the resulting safety benefit is required for
purposes of compliance or adequate protection under 10 CFR 50.109(a)(4).” However, the
Guidelines note that if there is more than one way to achieve compliance or reach a level of
adequate protection, costs may be a factor in that decision. With respect to the regulatory
guides, the NRC believes that the development of such guidance for § 50.46c is desirable in
order to ensure a consistent means of generating and using experimental data to establish
regulatory limits.

2.3

Disaggregation
In order to comply with the guidance provided in Section 4.3.2 (“Criteria for the

Treatment of Individual Requirements”) of the Guidelines, the NRC conducted a screening
review to determine if any of the individual requirements (or set of integrated requirements) of
the proposed rule are unnecessary to achieve the objectives of the rulemaking. The NRC
determined the objectives of the rulemaking are to: 1) incorporate recent research findings; 2)
establish performance-based requirements for ECCS in the event of a LOCA; 3) expand the
regulation’s applicability; 4) incorporate the requests of two PRMs; and 5) include a provision to
allow risk-informed submittals to evaluate the effects of debris on long-term cooling.
Furthermore, the NRC concluded that each of the proposed rule’s requirements is necessary to
achieve one or more objectives of the rulemaking. The results of this determination are set forth
in the following table.

10

Table 1 - Disaggregation
Regulatory
Goals for
10 CFR 50.46c

Paragraph (a)
Applicability.
Paragraph (b)
Definitions.
Paragraph (d)
Emergency
core cooling
system design.
Paragraph (g)
Fuel system
designs:
uranium oxide
or mixed
uraniumplutonium
oxide pellets
within
cylindrical
zirconium-alloy
cladding.
Paragraph (k)
Use of NRC
approved fuel
in reactor.
Paragraph (m)
Reporting.
Paragraph
(d)(2)(iii) Core
Geometry and
Coolant Flow.
Paragraph (e)
Alternate
Risk-Informed
Approach for

1) Revise the
ECCS
acceptance
criteria to
reflect recent
research
findings

2) Establish
performancebased
requirements

3) Expand
applicability
of10 CFR 50.46
to all fuel types
and cladding
materials

4)
Incorporate
requests of
two PRMs

X

X

X

X

5) Include
a provision
to allow
riskinformed
approach
for
addressing
the effects
of debris
on longterm
cooling

X
X

X

X

X
X

X

11

Regulatory
Goals for
10 CFR 50.46c

1) Revise the
ECCS
acceptance
criteria to
reflect recent
research
findings

2) Establish
performancebased
requirements

3) Expand
applicability
of10 CFR 50.46
to all fuel types
and cladding
materials

4)
Incorporate
requests of
two PRMs

5) Include
a provision
to allow
riskinformed
approach
for
addressing
the effects
of debris
on longterm
cooling

Addressing the
Effects of
Debris on
Long-Term
Core Cooling.

3.

Identification and Preliminary Analysis of Alternative Approaches
Given the existing data and information, this proposed rule and the no-action alternative

(described below as addressing the embrittlement and risk-informed alternative by a
case-by-case method) are considered by the NRC to be the only credible regulatory actions to
maintain adequate protection. Consequently, a rulemaking is the only regulatory action
alternative considered other than the no-action alternative.
3.1

No-Action Alternative
The no-action alternative is used only as a basis against which to measure the costs and

benefits of the proposed rule. The no-action alternative requires that the embrittlement issue
and the risk-informed approach to evaluating the effects of debris on long-term cooling be
resolved on a case-by-case basis (e.g., license amendments, orders). This would require
exemption requests and other administrative costs that are shown in the attributes as negative
costs (i.e., savings) for the proposed rule.

12

In light of recent research findings that indicate that the current regulations do not always
ensure PQD following a LOCA, this proposed rule is necessary to ensure adequate protection to
the public health and safety by maintaining that level of protection (i.e., reasonable assurance of
adequate protection) that the NRC thought previously would be achieved (throughout the entire
term of licensed operation). However, based upon a preliminary safety assessment in response
to the research findings in RIL-0801, the NRC determined that immediate regulatory action was
not required, and that changes to the ECCS acceptance criteria to account for these new
findings could reasonably be addressed through the rulemaking process. Recognizing that
finalization and implementation of the new ECCS requirements would take several years, the
NRC completed a more detailed safety assessment that confirmed current plant safety for every
operating reactor. See Section II.A of the proposed rule SOC for further information.

3.2

Proposed Rule Alternative
The proposed rule alternative would amend the current regulations for ECCS acceptance

criteria, found in § 50.46(b), by establishing performance-based requirements. The proposed
rule would expand applicability to all light water reactors (LWRs), regardless of fuel design or
cladding materials. It should be noted that this amendment would satisfy a request of
PRM-50-71. The proposed rulemaking would also incorporate recent research findings that
identified previously unknown cladding embrittlement mechanisms and expanded the NRC’s
knowledge of previously identified mechanisms. Specifically, the research identified that
hydrogen, which is absorbed in the cladding during normal operation, has a significant influence
on embrittlement during a postulated accident. The proposed rule would also require licensees
to evaluate the thermal effects of crud and oxide layers that may have developed on the fuel
cladding. It should be noted that this amendment would satisfy a request of PRM-50-84.
Finally, the proposed rule alternative would allow licensees to use an alternative risk-informed
13

approach to evaluate the effects of debris on long-term cooling. Including the risk-informed
alternative in this proposed rule would alleviate the need for a GSI-191 related rulemaking and
would decrease the NRC and Industry implementation costs in relation to developing another
rule. Including the risk-informed alternative is also based on the SRM on the proposed rule,
SRM-SECY-12-0034, “Proposed Rulemaking – 10 CFR 50.46c: Emergency Core Cooling
System Performance During Loss-of-Coolant Accidents (RIN 3150-AH42),” which directed:
“Regarding Generic Safety Issue 191, the 10 CFR 50.46c proposed rule should contain a
provision allowing NRC licensees, on a case-by-case basis, to use risk-informed alternatives
without an exemption request.”

3.3

Regulatory Guidance
Because the proposed rule would be performance-based, three companion DGs were

developed. The proposed rule calls for measurement of the onset of breakaway oxidation for a
zirconium cladding alloy based on an acceptable experimental technique. The proposed rule
also calls for the evaluation of the measurement relative to emergency core cooling system
performance, and periodic testing and reporting of the values measured. Draft Guide-1261
describes an experimental technique acceptable to the NRC staff to measure the onset of
breakaway oxidation in order to support a specified and acceptable limit on the total
accumulated time that a cladding may remain at high temperature, as well as a method
acceptable to the NRC to implement the periodic testing and reporting requirements in the
proposed rule.
The proposed rule also calls for the establishment of analytical limits on peak cladding
temperature and time at elevated temperature that correspond to the measured ductile-to-brittle
transition for the zirconium-alloy cladding material. Draft Guide-1262 describes an experimental
technique that is acceptable to the NRC for measuring the ductile-to-brittle transition for a
14

zirconium-based cladding alloy. Draft Guide-1263 provides a method of using experimental
data to establish regulatory limits. These DGs will be published for comment along with the
proposed rule.
With regard to the risk-informed alternative to address the effects of debris on long-term
cooling, South Texas Project Nuclear Operating Company (STPNOC) submitted a letter of
intent to pilot a risk-informed approach for addressing GSI-191 (ADAMS Accession No.
ML103481027) in December 2010. Subsequently, the NRC received a pilot submittal from
STPNOC on January 31, 2013 (ADAMS Accession No. ML13043A013), supplemented June 19,
2013 (ADAMS Accession No. ML131750250). In parallel with the NRC’s review of the
application, the NRC will develop draft guidance for the risk-informed alternative to address the
effects of debris on long-term cooling. That draft guidance will be published for comment upon
completion, which is currently anticipated for early- to mid-calendar year 2015. The NRC will
then evaluate public comments received on the draft guidance, and develop the final guidance
on a timeline that ensures all guidance (both for the risk-informed alternative and the new
proposed embrittlement criteria) is available when the NRC staff provides the final § 50.46c rule
to the Commission (currently scheduled for February 2016).

4.

Estimation and Evaluation of Values and Impacts
This section identifies the components of the public and private sectors, commonly

referred to as attributes, that are expected to be affected by this rulemaking. An inventory of the
impacted attributes was developed using the list provided in Chapter 5 of the NRC’s “Regulatory
Analysis Technical Evaluation Handbook”4 (Handbook). The identified impacts are quantified
where possible.

4

NUREG/BR-0184, “Regulatory Analysis Technical Evaluation Handbook,” U.S. Nuclear Regulatory
Commission, Office of Nuclear Regulatory Research, 1997.

15

4.1

Assumptions
All 100 currently operating light-water nuclear power reactors5 would be affected by this

proposed rule. The quantifiable impacts (i.e., those that are able to be monetized), are the
implementation and operation costs for both industry and the NRC. All monetized costs are
expressed in 2017 dollars, the year the rule is assumed to be implemented. Other than for
operating reactors that have indicated they would not seek a license renewal, this analysis
assumes that remaining operating reactors’ life expectancy would include a 20-year license
extension, unless stated otherwise.6 As a result, the average license would expire in 2039.
Given that the rule is assumed to be implemented in 2017, the average remaining life would be
22 years from implementation and any recurring costs would be discounted over that time
period. Any costs incurred over future years would be discounted back to 2017 values at both a
3 percent and 7 percent discount rate. Based on the most recent NRC labor rates, using the
methodology described in NUREG/CR-6967, Revision 2, “Generic Cost Estimates: Abstracts
from Generic Studies for Use in Preparing Regulatory Impact Analyses,” dated February 1992,
an NRC staff-year is valued at $173,000, while an annual industry staff labor rate of $200,000 is
assumed.
There are currently two design certifications that are expected to be renewed. For the
regulatory analysis, the NRC assumes that these are the only design certifications that would be
submitted.
5

The NRC does not consider San Onofre Nuclear Generating Station, Units 2 and 3, Crystal River
Nuclear Plant, Unit 3 and Kewaunee Nuclear Power Plant because they have submitted their certification
of permanent cessation of power operations per § 50.82(a)(1)(i). The NRC continues to consider
Vermont Yankee Nuclear Power Station in the regulatory analysis because, while Vermont Yankee
submitted a notification of permanent cessation of power operations under § 50.82(a)(1)(i) (see ADAMS
Accession No. ML13273A204), that notification contained only an estimate of the date of cessation.
Vermont Yankee plans to supplement that letter with a (firm) date of cessation, as required per
§§ 50.82(a)(1)(i) and 50.4(b)(8). The final regulatory analysis will reflect that data.
6
Oyster Creek Nuclear Power Plant is planned to close in 2019. See
http://www.exeloncorp.com/PowerPlants/oystercreek/Pages/profile.aspx.

16

The NRC assumes that there are six future operating light-water nuclear power reactors
that would be affected by this rule. The nuclear power reactors are: Watts Bar Nuclear Power
Plant, Unit 2, with an assumed beginning of operations date in 2015; Vogtle Electric Generating
Plant (Vogtle), Units 3 and 4, with an assumed beginning of operations date of 2017; Virgil C.
Summer Nuclear Station, Units 2 and 3, with an assumed beginning of operations dates of 2017
and 2019, respectively; and Bellefonte Nuclear Station Unit 1, with an assumed beginning of
operations date of 2020.7
The NRC assumes that other new design certifications could be submitted to the NRC
for approval and has developed a hypothetical design certification to analyze the costs and
benefits of the proposed rule on a design certification.
The NRC also assumes that other new light-water nuclear power reactors could begin to
operate in the future and has developed a hypothetical light-water nuclear power reactor to
analyze the costs and benefits of the proposed rule on a new light-water nuclear power reactor.
The NRC assumes that no other types of reactors would be built and that there would be no
significant differences between the future operating reactors and the hypothetical reactor.
Another assumed difference in this analysis is that industry implementation costs are
separated into direct and indirect costs. This difference is explained further in Section 4.2,
“Industry Implementation”.
The NRC assumes that the final rule is published on January 1, 2017. It would then take
vendors approximately 1 year to submit their revised models. The NRC assumes that nine
alloy-specific cladding hydrogen uptake models would need to be developed and 12 existing
LOCA models would need to be revised in order to implement the proposed rule. (To facilitate
this analysis, and the assumptions within, the LOCA models are distinguished between

7

Bellefonte Nuclear Station, Unit 2, as well as all other combined license applications submitted to the
NRC are too speculative in nature to be included in the regulatory analysis.

17

PQD/Breakaway and LTC.) Next, the NRC assumes 1 year for the NRC review and comment
of the nine vendor cladding hydrogen uptake models, and 2 years for the NRC review and
comment of the twelve vendor LOCA models. Next, the 64 plants in Track 1 would demonstrate
compliance within 24 months by providing a letter report to the NRC. No NRC review of these
letters would be necessary. Finally, the remaining 36 plants in Tracks 2 and 3 would
demonstrate compliance within 48 months and 60 months, respectively, by submitting a new
LOCA analysis of record (AOR).

4.2

Industry Implementation
This attribute is composed of indirect and direct licensee implementation costs for

operating reactors, design certifications and future operating reactors. The proposed rule would
require licensees of operating reactors, design certifications, and future operating reactors to
make use of revised ECCS analysis models based upon the new required acceptance criteria.
The revised ECCS models and alloy-specific cladding hydrogen uptake models would be
developed by vendors, at the request and expense of the licensees. Because the vendors are
not licensed by the NRC and are developing the revised ECCS models because of the new
requirements being imposed upon licensees, these costs are considered to be indirect industry
implementation costs. The vendors would also produce licensing topical reviews describing the
new models for NRC review and approval. The vendors would also produce test data to
characterize alloy performance and develop analytical limits based on this test data to be
included within each alloy’s topical review.
After NRC approval in relation to operating reactors, the models would be run to perform
plant-specific analyses, demonstrate compliance with the proposed acceptance criteria, and to
employ PQD analytical limits. Costs incurred by licensees under these three tracks are
considered direct industry implementation costs.
18

The NRC assumes that some entities will decide to implement the risk-informed
alternative to the proposed rule (12 analyses of record (AOR)), based on initial industry
estimates. The NRC assumes that the entities will submit the alternative in accordance with
their compliance demonstration dictated by track assignment, but the NRC will support early
implementation of the alternative approach, if desired. However, the NRC assumes that each
entity will expend the same level of effort to develop and submit the alternative. The use of this
alternative approach would obviate the need for licensees to submit four exemption requests:
§ 50.46c, General Design Criterion (GDC)-35, GDC-38, and GDC-41. This benefit is
recognized in the same year that the licensees’ submittal is received for the alternative
approach.
Sixty-four operating plants under Track 1 and five future operating plants with similar
implementation steps as Track 1 would complete any necessary engineering calculations,
update their plant updated final safety analysis report (UFSAR), and provide a letter report to
the NRC documenting compliance with § 50.46c. The plants in Track 1 meet the new
requirements without new analysis or model revisions (beyond use of Cathcart-Pawel –
Equivalent Cladding Reacted (CP-ECR)) to integrate time-at-temperature and hydrogen uptake
models to establish PQD analytical limits), and thus would meet the new requirements with a
low level of effort. The 15 operating plants in Track 2 are PWR plants using realistic evaluation
models, as well as BWR/2 plants, which will require new analyses or model revisions to
demonstrate compliance. The NRC anticipates that Track 2 plants will exert a medium level of
effort to comply with the proposed regulation. The 21 operating plants in Track 3 are
pressurized water reactor (PWR) plants using appendix K of 10 CFR part 50 evaluation models,
as well as boiling water reactor (BWR)/3 plants, which will require new analyses or model
revisions to demonstrate compliance. The NRC anticipates that Track 3 plants will exert a
medium – high level of effort to comply with the proposed regulation. Track 2 and Track 3
19

plants would be required to conduct a new ECCS evaluation, and submit a new LOCA AOR.
The vendors would also conduct initial breakaway testing on all cladding alloys. Again, because
the vendors are not licensed by the NRC, and would be conducting initial breakaway tests
because of the new requirements imposed on the licensee, these costs are considered indirect
costs.
The proposed rule would require licensees to evaluate the thermal effects of crud and
oxide layers that accumulate on the fuel cladding during plant operation. Because licensees are
required to account for various thermal parameters under the current regulation, the NRC’s
position is that the proposed requirement to evaluate crud is a clarification of the current
requirement. As such, there would be no additional cost incurred as a result of the rule.
Although multiple designs for new reactors have been certified by the NRC, only one
type of design is currently in the construction phase in the United States, the Westinghouse
Electric Company’s AP1000. The AP1000 uses the same fuel design as the current fleet and,
therefore, will have no effect in relation to the attributes. As no other construction has begun, all
other reactor designs would be too speculative to evaluate within the Regulatory Analysis.
The current ECCS performance regulation applies to “each boiling or pressurized
light-water nuclear power reactor fueled with uranium oxide pellets within cylindrical zircaloy or
ZIRLOTM cladding.” As such, licensees must request an exemption to use fuel designs
consisting of materials other than those stated. The proposed rule would extend applicability to
all LWRs, regardless of fuel design. This would eliminate the need for exemption requests, and
represents a benefit.
4.3

NRC Implementation
The NRC would incur several implementation costs. The first set of costs is for the

development of the regulatory guides and final rule. Once the rule is implemented, the NRC
would review and approve the approximately 21 vendor licensing topical reviews that provide
20

the revised ECCS analysis models. The NRC would have to review all of the risk-informed
alternatives submitted by the licensees (12 AORs). Because the use of this alternative
approach would obviate the need for licensees to submit four exemption requests, the NRC
would no longer need to review four exemption requests for each of the alternatives submitted.
Next, the NRC would need to review the approximately 25 revised ECCS AORs in Tracks 2 and
3 (due to multiple unit sites that share common analyses, this total number of AORs covers 36
plants). Lastly, the proposed rule alternative would eliminate the need for licensees to submit
an exemption request to use materials other than “uranium oxide pellets within cylindrical
zircaloy or ZIRLOTM cladding.” The NRC would no longer be required to review such exemption
requests, which results in a benefit.

4.4

Industry Operation
Industry would incur annual costs in performing the periodic breakaway tests. These

tests involve the performance of the required breakaway oxidation tests as performed by
vendors and, as a result, are considered indirect costs. These costs would be incurred for
plants that are both currently operating or operating in the future (does not apply to design
certifications). The NRC notes that the proposed rule would require licensees to report errors in
calculated equivalent cladding reacted (ECR) in concert with reported changes in peak cladding
temperature (PCT). For the purposes of this analysis, the NRC assumes that the cost of
reporting ECR is negligible since licensees calculate ECR under the current regulation and are
already required to report changes to or errors in ECCS evaluation models with respect to
calculated PCT.
The NRC notes that the proposed reporting criteria are restructured and rewritten to
provide clarification on which items need to be reported, and the timeframe for reporting. The

21

proposed additional language clarifies the intent of the current regulation. As such, the
proposed revision does not constitute a change in burden to the NRC or the industry.
Licensees that elect to use the risk-informed alternative to address the effects of debris
in the long-term would be required to periodically update their probabilistic risk assessments
(PRA) every 4 years. Additionally, those licensees would be required to report errors or
changes in their submittals. The NRC assumes that industry would submit one error per year.

4.5

NRC Operation
The NRC would experience recurring costs as a result of the industry’s periodic

breakaway tests by analyzing the test results. The NRC would also incur annual costs as a
result of reviewing reported errors in calculated ECR. However, the current regulation requires
licensees to report errors in calculated PCT, and the actions the NRC would take for an error in
ECR are the same as those actions for errors in calculated PCT. Additionally, errors in
calculated ECR would have an associated error in calculated PCT. For all of these reasons, the
NRC assumes that the change in annual costs between the current regulatory baseline and the
proposed rule alternative, with respect to reporting ECR, are negligible. With respect to the
risk-informed alternative, the NRC would review updates to the PRAs and errors and changes to
the submittal.

4.6

Improvements in Knowledge
The proposed rule alternative incorporates research findings that identified new cladding

embrittlement mechanisms. As a result, future LOCA analyses will improve the predictions of
cladding embrittlement.

22

4.7

Regulatory Efficiency
Expanding the applicability of this rule to different fuel designs and additional cladding

materials would contribute to regulatory efficiency by eliminating the need for licensees to
submit exemption requests for different fuel designs or cladding material. As a result, the
proposed rule alternative would improve regulatory efficiency.

4.8

Public Health (Accident)
As noted above, the NRC is initiating these new requirements so that the risk of

accidental radiation exposure to the public would remain at the previously assumed level.
Therefore, there would be an insignificant difference in public health (accident) costs or benefits
between the regulatory baseline and the proposed rule alternative.

4.9

Occupational Health (Accident)
Similarly, the NRC assumes that the risk of an accidental radiation exposure would

remain at the level it was assumed to have been prior to the proposed rule. Therefore, there
would be an insignificant difference in occupational health (accident) costs or benefits between
the regulatory baseline and the proposed rule alternative.

4.10

Onsite Property
Likewise, the NRC assumes that the risk of damage to onsite property would remain at

the level it was assumed to have been prior to the proposed rule. Therefore, there would be an
insignificant difference in offsite property costs or benefits between the regulatory baseline and
the proposed rule alternative.

23

4.11

Offsite Property
The NRC also assumes that the risk of damage to offsite property would remain at the

level it was assumed to have been prior to the proposed rule.

4.12

Attributes Not Affected
Attributes that are not expected to be affected under the proposed rulemaking include the

following: public health (routine); occupational health (routine); other government; general public;
antitrust considerations; safeguards and security considerations; and environmental considerations.

5.

Presentation of Results
This section presents the quantitative results by attribute. Values are shown in 2017

dollars. The tables, unless provided within the body of the section, are located in Appendix B,
“Tables”.

5.1

Industry Implementation Costs
The industry implementation costs are spread among operating reactors, design

certifications, and future operating reactors. As noted above, the proposed rule would require
licensees to make use of revised ECCS analysis models based upon the new required
acceptance criteria. The revised ECCS models would be developed by vendors, at the request
and expense of the licensees. These models are the cladding hydrogen uptake models and the
LOCA model updates. The vendors would also produce test data to characterize alloy
performance and develop analytical limits based on this test data. The vendors would produce
licensing topical reviews regarding the new models, which would require NRC review and
approval. After NRC approval, vendors would run the models under contract to licensees to
perform plant-specific analyses and demonstrate compliance with the proposed acceptance
24

criteria. The costs associated with implementation assume the use of the Regulatory Guides
(RGs) developed for this proposed rule and include the costs of the testing as outlined in the
RGs.
As shown in Table 2 - Industry Implementation Costs for Operating Reactors, the first
component is the indirect costs resulting from vendor implementation. As noted above,
because the vendors are not licensed by the NRC and are developing the revised ECCS
models because of the new requirements being imposed upon licensees, these are considered
to be indirect industry implementation costs. The cladding hydrogen uptake models are
assumed to be performed in a 1-year period in 2017 and the LOCA models (PQD and
Breakaway) are assumed to be performed in a 2-year period between 2016 and 2017. The
LOCA Models (long-term cooling) are assumed to be performed in a 2-year period from 2016 to
2017). The Initial Breakaway Tests are assumed to be performed in 2017. The nine cladding
hydrogen uptake models are assumed to require 0.75 full-time equivalent (FTE)/year/alloy. (For
this analysis, the NRC assumes an industry labor rate of $200,000/year.) The 12 LOCA models
(PQD and breakaway) are assumed to require 0.75 FTE/year/alloy. The 12 LOCA models
(long-term cooling) are assumed to require 0.5 FTE/year/alloy. There are also assumed to be
nine Initial Breakaway Test Models requiring a third of an FTE each and that the tests would be
performed in 2017. The 9 models of Cladding Alloys cost an estimated $1.4 million. Further,
the 24 LOCA models, including both the PQD and breakaway and long-term cooling models,
(which include estimates for the completion of the topical reports) are estimated to cost $3.0
million total.8 The Initial Breakaway Test is expected to occur in 2017 and is estimated to cost
$600,000.
Additionally, the NRC assumes that a number of licensees would implement the
risk-informed alternative within three different tracks. The NRC assumes that there would be
8

In this analysis, where activities occur in or before 2017, no discounted values are provided.

25

10, 1, and 1 AORs in Track 1, Track 2, and Track 3, respectively, and each AOR would require
2.5 FTE. Also, because each unit would not be required to submit an exemption request in the
same year that the AOR is submitted, not preparing and submitting this document would be a
negative cost (savings) of 100 hours per exemption request. The number of exemption
requests saved would be 56, 4, and 4 for Tracks 1, 2, and 3, respectively. Track 1, Track 2, and
Track 3 would implement the risk-informed alternative and not implement the exemption
requests in years 2018, 2019, and 2020, respectively. Therefore, the NRC estimates the total
costs for these tracks and exemption request savings range from $3.4 million (7 percent) to $3.7
million (3 percent). Without the exemption request savings, Track 1 has values ranging from
$4.7 million (7 percent) to $4.9 million (3 percent). Track 2 has values ranging from $440,000 (7
percent) to $470,000 (3 percent). Track 3 has values ranging from $440,000 (7 percent) to
$470,000 (3 percent).
Adding to the previous implementation costs are the Track 1, Track 2, and Track 3
activities. The NRC assumes that there would be 49, 12, and 13 revised AORs in the three
tracks, respectively. Due to multiple unit sites that share common analyses, the number of
AORs is less than the 100 plants. Track 1 actions would require 0.5 FTE over a 2-year period
(0.25 FTE/year); Track 2 actions would require 1.5 FTE over a 3-year period (0.5 FTE/year);
Track 3 actions would require 2.25 FTE over a 3-year period (0.75 FTE/year). The NRC
estimates the total costs for these tracks range from $13 million (7 percent) to $14 million (3
percent). Track 1 has values ranging from $4.8 million (7 percent) to $4.9 million (3 percent).
Track 2 ranges from $3.0 (7 percent) to $3.4 (3 percent). Similarly, for Track 3, the cost
estimate ranges from $4.8 million (7 percent) to $5.3 million (3 percent).
Another potential indirect licensee cost for operating reactors would be the development
of new PQD analytical limits in place of utilizing the acceptable PQD analytical limits provided in
the regulatory guide. For the purpose of this regulatory analysis, the NRC assumes that the
26

industry would elect to establish new PQD analytical limits for two cladding alloys requiring a
quarter of an FTE per year. It is also assumed that this test would be accomplished in 2017,
and the estimated cost would be $100,000. The remaining seven cladding alloys would utilize
the PQD analytical limits in the RG. The NRC assumes that, due to the high cost of establishing
a new experimental technique (outside the acceptable experimental technique in the RG), no
vendor will choose that method.
Another licensee implementation test is the LTC test. The NRC assumes that nine
cladding alloys would need to be tested, requiring 0.15 FTE per year. It is also assumed that
this test would be accomplished in 2017. The total cost for the long-term cooling testing is
estimated to be $270,000.
The proposed rule would reduce licensee implementation cost by eliminating the need
for exemption requests to use materials other than uranium-oxide fuel pellets within cylindrical
zircaloy or ZIRLOTM cladding. The NRC assumes that 50 plants (5 per year over a 10-year
period, beginning in 2017) would request an exemption if the proposed rule did not extend
applicability. It is also assumed that the exemption requests would require 0.2 FTE per
exemption request. This would result in an estimated total savings (negative cost) ranging from
$1.5 million (7 percent) to $1.8 million (3 percent). The estimated total implementation cost for
operating reactors ranges from $20 million (7 percent) to $21 million (3 percent).
As shown in Table 3 - Industry Implementation Costs for Design Certifications, the costs
come from an analysis of the design certifications. The Track 29 cost is an indirect cost that
would occur for both design certifications in 2020. The NRC assumes that the design
certifications would require 1.5 FTE per design certification. Track 2 has an estimated cost

9

Although labeled “Track 2,” the NRC assumes that design certifications will not be a part of Track 2, but
will have characteristics similar to Track 2 and are, therefore, labeled as “Track 2.”

27

range from $490,000 (7 percent) to $549,000 (3 percent). The estimated implementation costs
for design certification ranges from $490,000 (7 percent) to $549,000 (3 percent).
Table 4, Industry Implementation Costs for Future Operating Reactors, provides costs for
the initial breakaway test, the track designation that most closely matches implementation
required for the reactors, and the LTC test that each reactor would use. The initial breakaway
test, which would occur for Watts Bar in 2017, the Summer and Vogtle future operating reactors
in 2022 and Bellefonte 1 in 2023, has an estimated cost range from $36,000 (7 percent) to
$43,000 (3 percent).
The Track 110 costs, which would occur for Watts Bar in the years 2020 and 2021, Vogtle
and Summer in years 2024 and 2025, and Bellefonte in years 2026 and 2027, would require
0.25 FTE for each AOR. The Watts Bar Track 1 estimated cost ranges from $79,000 (7
percent) to $94,000 (3 percent). The Summer and Vogtle future operating reactors Track 1
estimated cost ranges from $240,000 (7 percent) to $351,000 (3 percent). The Bellefonte 1
Track 1 estimated cost ranges from $52,000 (7 percent) to $75,000 (3 percent). The total cost
estimate for Track 1 ranges from $370,000 (7 percent) to $490,000 (3 percent).
The LTC Test cost would be incurred in years 2020 for Watts Bar, Vogtle Units 3 and 4,
and Summer, Unit 2; 2025, for Summer, Unit 3; and 2026, for Bellefonte 1. The LTC requires
0.04 FTE per reactor and has an estimated total cost range from $43,000 (7 percent) to $46,000
(3 percent).
The total estimated industry implementation cost for future operating reactors ranges
from $460,000 (7 percent) to $580,000 (3 percent).

10

Although labeled “Track 1,” the NRC assumes that future operating reactors will not be a part of Track
1, but will have characteristics similar to Track 1 and are, therefore, labeled as “Track 1.”

28

The total estimated industry implementation cost for operating reactors, design
certifications and future operating reactors ranges from $21 million (7 percent) to $22 million (3
percent).

5.2

Industry Operation Costs
The NRC assumes that, once all licensees of operating reactors have implemented the

proposed rule, 60 periodic breakaway tests will be submitted to the NRC each year (based on
distribution between 18 month and 24 month operating cycles). However, between publication
and full implementation, the NRC estimates the number of periodic breakaway tests will be as
indicated for operating reactors:
2019
2020
2021
2022
2023

Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests

60
0
60
44
60

Table 5 - Industry Operation Costs for Operating Reactors shows the costs for both the
risk-informed alternative and the periodic breakaway test. For the risk-informed alternative, for
the Track 1 AOR, starting in 2021, and every 4 years, 10 AORs would be updated, requiring
0.05 FTE/AOR. For the Track 2 AOR, starting in 2022, and every 4 years, 1 AOR would be
updated, requiring 0.050 FTE/AOR. For the Track 3 AOR, starting in 2023, and every 4 years, 1
AOR would be updated, requiring 0.05 FTE/AOR. Also, the NRC assumes that, starting in
2021, one error would be found and require change each year and would require 0.050
FTE/error. The total industry operation cost for the risk-informed alternative ranges from
$370,000 (7 percent) to $550,000 (3 percent).

29

For the periodic breakaway tests, in 2019, the majority of Track 1 plants would have
conducted periodic breakaway tests. As such, in 2020 those plants would not have to re-test for
breakaway oxidation, and neither Track 2 nor Track 3 plants would have implemented the rule.
By 2021, a portion of Track 1 plants would re-test for breakaway oxidation, as well as a portion
of Track 2 plants. The 2022 value also reflects the total resulting from a portion of Track 1 and
Track 2 plants. In 2023, Track 3 plants would begin their periodic breakaway tests, and a
portion of Track 1 and Track 2 plants would conduct testing. Starting in 2023, and annually
thereafter through the average remaining life, the NRC assumes that a total of 60 breakaway
oxidation tests will be submitted per year. The total estimated discounted cost range of the
periodic breakaway testing for operating reactors is $4.9 million (7 percent) and $7.0 million (3
percent). Therefore, the total industry operation costs for operating reactors ranges from $5.3
million (7 percent) to $7.6 million (3 percent).
Table 6 - Industry Operation Costs for Future Operating Reactors shows the industry
operation costs for future operating reactors. The NRC assumes that Watts Bar Unit 2, Vogtle
Units 3 and 4, and Summer Unit 2 will perform a periodic breakaway test in 2021 during
refueling and every 2 years thereafter. Watts Bar Unit 2 would stop performing periodic
breakaway tests in year 2073 and Vogtle Units 3 and 4, and Summer Unit 2 would stop
performing periodic breakaway tests in year 2075. Summer, Unit 3 would begin performing
periodic breakaway tests in 2023 and would continue performing the test every other year until
2077. Bellefonte Unit 1 would begin performing periodic breakaway tests in year 2022 and
would continue performing the test every other year until 2078. Each periodic breakaway test
would require an average FTE requirement of 0.05 FTE. The estimated total cost for the
industry operation costs for future operating reactors ranges from $380,000 (7 percent) to
$780,000 (3 percent).

30

The total estimated industry operation cost for operating reactors, design certifications
and future operating reactors ranges from $5.3 million (7 percent) to $7.8 million (3 percent).

5.3

Total Industry Costs
Table 7 - Total Industry Costs shows the total industry costs broken down between direct

and indirect costs as well as by implementation and operation costs. The total industry costs
range from $26 million (7 percent) to $31 million (3 percent).

5.3.1

Industry Average Implementation Costs per Designated Unit
Table 8 - Industry Average Implementation Cost per Designated Unit provides the

estimates of the various average costs per designated unit, by type of cost for operating
reactors, design certifications and future operating reactors. As shown, the largest average
designated unit cost contributors for operating reactors and future operating reactors are the 3
Track Activities. Almost all of the average designated unit cost contributors for design
certifications are from the initial breakaway test. The total industry operating reactor
implementation cost per AOR estimate ranges from $260,000 (7 percent) to $280,000 (3
percent). The total industry design certification implementation estimated cost per reactor or
design certification ranges from $250,000 (7 percent) to $280,000 (3 percent). The total
industry future operating reactor implementation cost per reactor/AOR estimate ranges from
$190,000 (7 percent) to $280,000 (3 percent).

5.4

NRC Implementation Costs
Table 9 - NRC Implementation Costs Affecting Operating Reactors, Design

Certifications, and Future Operating Reactors shows the NRC implementation costs that affect

31

operating reactors, design certifications and future operating reactors11. Four RGs would be
published as a result of this rule (both draft and final versions). The first relates to analytical
limits, the second and third to test procedures, and the fourth RG relates to the risk-informed
alternative. As shown in Table 9 - NRC Implementation Costs Affecting Operating Reactors,
Design Certifications, and Future Operating Reactors, the NRC estimates the costs to be
approximately $1.7 million. This is based upon the assumptions of 10 NRC staff-years to
complete the regulatory guides, with an NRC yearly rate of $173,000. The NRC also assumes
that it will take approximately 2 calendar years to complete the guides.
The NRC would also need to develop and issue a revision to NUREG-0800, “Standard
Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition.”
The cost estimates for this action would require one FTE and is estimated to be $173,000.
The NRC would also incur costs reviewing and commenting on the cladding hydrogen
uptake models and the LOCA models. For the cladding hydrogen uptake models, the NRC
estimates that it would take 2 FTE at $173,000 annually, be implemented in 2018, and,
therefore, range from $330,000 (7 percent) to $340,000 (3 percent). The NRC review of the
LOCA models (PQD, breakaway) is estimated to take 2 FTE/year over a 2-year period,
beginning in 2018. The cost for this activity is estimated to be from $640,000 (7 percent) to
$670,000 (3 percent). The NRC review of the LOCA models (long-term cooling) is estimated to
take 1 FTE/year over a 2-year period, beginning in 2018. The cost for this activity is estimated
to be from $310,000 (7 percent) to $330,000 (3 percent). Next, the NRC estimates that this final
rule development would take approximately 6 FTE over 3 years, beginning in 2014, and have a
cost of approximately $1 million.
Table 10 - NRC Implementation Costs for Operating Reactors shows the NRC
implementation costs for operating reactors. The NRC’s break-away test review is assumed to
11

In relation to totaling costs, these costs are part of the operating reactor costs.

32

require one FTE in the year 2018. The resulting cost estimate ranges from $160,000 (7
percent) to $170,000 (3 percent).
Table 10 - NRC Implementation Costs for Operating Reactors provides the estimated
NRC costs for the risk-informed alternative. The NRC implementation costs related to the riskinformed alternative are related to reviewing the risk-informed alternative submittals and the
negative costs (savings) from not needing to review exemption requests. The estimated NRC
effort for each AOR review is 0.56 FTE and the estimated NRC effort for each exemption
request review is 0.40 FTE. Therefore, the estimated NRC implementation costs for the riskinformed alternative ranges from $580,000 (7 percent) to $720,000 (3 percent).
Table 10 - NRC Implementation Costs for Operating Reactors also provides estimated
implementation costs for operating reactors for analysis of record reviews for Tracks 2 and 3.
(Track 1 compliance for operating reactors is demonstrated through a letter report – no NRC
review would be necessary.) These efforts would take place over a 2-year period and begin in
the years 2019, 2021, and 2022 for the Tracks 1, 2, and 3, respectively. Because Track 1
would require no NRC review, there would be no cost associated with this track. For Track 2,
the range is $520,000 (7 percent) to $610,000 (3 percent). For Track 3, the values range from
$480,000 (7 percent) to $590,000 (3 percent). Therefore, the total estimated NRC
implementation cost for the amendment reviews ranges from $1.0 million (7 percent) to $1.2
million (3 percent). The next NRC implementation costs for operating reactors are a result of
PQD Tests. As mentioned, the assumption is that only two cladding alloys would need to be
done under the so-called “redone NRC Version.” Each cladding alloy is assumed to require
0.25 FTE, beginning in 2015. The resulting estimates are calculated to be $81,000 (7 percent)
to $84,000 (3 percent).
There are also NRC implementation costs associated with LTC tests. The assumption is
that the NRC review would require 0.15 FTE for each of the 9 cladding alloys, beginning in
33

2015. The resulting estimates are calculated to be $210,000 (7 percent) to $220,000(3
percent).
The proposed rule would eliminate the need for the NRC to review licensee exemption
requests to use materials other than uranium-oxide fuel pellets within cylindrical zircaloy or
ZIRLO™ cladding; this represents a cost savings. The NRC assumes that 50 plants (five per
year over a 10-year period, beginning in 2014) would request exemptions if the proposed rule
did not extend applicability to other materials. It is also assumed that NRC review of the
exemption requests would require 0.1 FTE per exemption request. This would result in a total
savings ranging from $650,000 (7 percent) to $770,000 (3 percent).
Therefore, the total NRC Implementation costs for operating reactors, including those
implementation costs that affect both design certifications and future operating reactors, are
estimated to range from $5.6 million (7 percent) to $5.9 million (3 percent).
Table 11 - NRC Implementation Costs for Design Certifications shows the NRC
implementation costs for design certifications. The NRC assumes that, in 2021, the NRC will
conduct a review of the certification amendment analysis for both design certifications, requiring
0.27 FTE each, resulting in an estimated cost range from $70,000 (7 percent) to $82,000
(3 percent). The total NRC implementation costs for design certifications range from $70,000
(7 percent) to $82,000 (3 percent).
Table 12 - NRC Implementation Costs for Future Operating Reactors shows the NRC
implementation costs for future operating reactors. An initial breakaway test review would be
performed in 2018 by the NRC for Watts Bar, Vogtle Units 3 and 4, and Summer Unit 2, and
would require 0.01 FTE per review, and has an estimated cost range from $7,000 (7 percent) to
$8,000 (3 percent). The initial NRC breakaway test review for Summer Unit 3 would be
conducted in 2020 would require requiring 0.01 FTE, and has an estimated cost of $2,000. The
initial NRC breakaway test review for Bellefonte 1 would be conducted in 2021 would require
34

0.01 FTE, and has an estimated cost of $2,000. Also, as all future operating reactors are
assumed to be submitting LARs following the Track 1 methodology, no NRC review would be
required. The last implementation cost is the LTC review costs. The NRC would review the
Watts Bar LTC test in 2018, requiring 0.04 FTE for an estimated cost of $7,000. The NRC
would perform the Summer and Vogtle units LTC test reviews in 2020, requiring 0.04 FTE per
reactor for an estimated cost range from $19,000 (7 percent) to $23,000 (3 percent). The NRC
would perform the Bellefonte 1 LTC test review in 2021, requiring 0.04 FTE for an estimated
cost range from $4,000 (7 percent) to $6,000 (3 percent). The total NRC implementation costs
for future operating reactors ranges from $46,000 (7 percent) to $51,000 (3 percent).
The total NRC implementation costs range from $5.8 million (7 percent) to $6.2 million (3
percent).

5.5

NRC Operation Costs
As noted above, the NRC would experience recurring costs for operating reactors and

future operating reactors as a result of the industry’s periodic breakaway tests and review of the
industry PRA submittals and changes to errors. As shown in Table 13 - NRC Operation Costs
for Operating Reactors, for operating reactors, the NRC assumes that the NRC’s analysis of the
periodic breakaway tests would require 0.15 FTE per year every other year until 2039 and that
the update to PRA reviews will be conducted the year following the industry submittal starting in
2022 and continues until 2039. The NRC estimates that it would require 0.56 FTE per PRA
review. The effort per year is based on the number of PRA reviews submitted by industry the
year before. The NRC, beginning in 2022 and continuing until 2039, would spend 0.029 FTE
reviewing an error and respective change each year. Therefore, the estimated NRC operation
costs for operating reactors ranges from $2.7 million (7 percent) to $4.2 million (3 percent).

35

Table 14 - NRC Operating Costs for Future Operating Reactors outlines the NRC
operating costs for future operating reactors. The periodic breakaway test reviews will be
performed for Watts Bar (requiring 0.01 FTE per review) until 2022, when future operating
reactor reviews will be conducted (requiring 0.04 FTE per year). The estimated NRC operating
costs for future operating reactors ranges from $62,000 (7 percent) to $130,000 (3 percent).
The total NRC operating costs ranges from $880,000(7 percent) to $1.1 million (3
percent).

5.6

Total NRC Costs
Table 15 - Total NRC Costs shows the total NRC costs broken down by implementation

and operation costs. As stated above, the estimated NRC implementation costs range from
$5.7 million (7 percent) to $6.0 million (3 percent) and the NRC operating costs range from $2.8
million (7 percent) to $4.3 million (3 percent). The total NRC cost estimate ranges from $8.5
million (7 percent) to $10 million (3 percent).

5.7

Total Rule Costs
Table 16 - Total Costs shows the total cost estimates, including both industry and the

NRC, range from $35 million (7 percent) to $41 million (3 percent). As shown in Table 16 - Total
Costs they are composed of implementation costs of $27 million (7 percent) to $29 million (3
percent) and operating costs of $8.1 million (7 percent) to $12 million (3 percent).
Lastly, the average implementation costs per AOR are estimated to range from
$150,000 (7 percent) to $190,000 (3 percent).

5.8

Future Design Certifications

36

As there are potential design certifications that may come into the NRC for review, but
are too uncertain regarding likelihood and timing to be properly added into the regulatory
analysis, the NRC assumes a hypothetical design certification beginning in a hypothetical year
(year X), based on 2017 dollars, to determine the cost to the industry and the NRC for the future
design certifications.
As shown in Table 17 - Industry Costs for Future Design Certifications, the Industry
would incur costs in relation to implementation costs. One industry cost would be the initial
breakaway test in year X that would require 0.04 FTE and provide an estimated cost of $8,000.
The other industry cost would come from the PQD test, which is assumed to be a redone NRC
version. This cost would occur in year X, would require 0.01 FTE of effort and provide an
estimated cost of $2,000.The total estimated industry cost for a hypothetical design certification
is $10,000.
As shown in Table 18 - NRC Costs for Future Design Certifications, the NRC would incur
costs in relation to the review of the initial breakaway test and the PQD test for a hypothetical
design certification. The breakaway test review, which would occur in year X+1, would require
0.01 FTE of effort and have an estimated cost of $2,000. The PQD test review, which would
also occur in year X+1, would require 0.005 FTE of effort and have an estimated cost of $1,000.
The total estimated NRC cost for a hypothetical design certification is $3,000.

5.9

Hypothetical Future Operating Reactors
As there are future operating reactors that are also too uncertain regarding likelihood and

timing to be properly added into the regulatory analysis, the NRC assumes a hypothetical future
operating reactor (a single reactor at a new site) beginning operation in a hypothetical year
(year X), based on 2017 dollars, to determine the cost to the industry and the NRC for the future
operating reactor.
37

As shown in Table 19 - Industry Costs for Hypothetical Future Operating Reactor the
Industry would incur both implementation and operating costs in relation to a hypothetical
reactor. One industry implementation cost would be a breakaway test in year X that would
require 0.04 FTE and provide an estimated cost of $8,000. Another implementation cost would
be for Track 1, which would be over 2 years (X and X+1) and would require a total FTE of 0.5,
spread between the 2 years and having a total estimated cost of $100,000. The final
implementation cost would be for the LTC test, which would occur in year X and would require
0.04 FTE and provide a total cost of $8,000. The total industry hypothetical future operating
implementation cost is estimated at $116,000. The industry operating costs for the periodic
breakaway test for the hypothetical operating reactor would occur during the first reload and
each subsequent reload, and would require 0.05 FTE for the expected life of the reactor. The
total industry estimated cost for the periodic breakaway test is $390,000.
The total cost for the industry hypothetical future operating reactor is estimated at
$506,000.
As shown in Table 20 - NRC Costs for Hypothetical Future Operating Reactor, the NRC
incurs both implementation and operating costs due to this rulemaking for a hypothetical future
operating reactor. The implementation costs are divided into breakaway test review, Track 1
review and LTC test review. The breakaway test review would occur in year X+1 and would
require 0.08 FTE for an estimated cost of $14,000. For the Track 1 review, the NRC would not
incur any costs as no FTE would be required. For the LTC review, the review would occur in
year X+1 and would require 0.04 FTE for the unit for an estimated cost of $7,000. The total
NRC hypothetical future operating reactor implementation cost is estimated at $21,000. The
NRC would incur an operation cost starting in year X+2.5 for the periodic breakaway test
review. The FTE requirement per year would be 0.002 and would occur for through the
expected life of the reactor, providing a total estimated cost of $20,000.
38

The total NRC hypothetical future operating reactor cost is estimated at $41,000.

6.

Decision Rationale

As noted above, this rulemaking is predicated upon the belief that this proposed action falls
under the adequate protection justification. The Regulatory Analysis Guidelines state that, “The
level of protection constituting ‘adequate protection’ is that level which must be assured without
regard to cost” (emphasis added). The Guidelines also state that, “. . . a proposed backfit to
one or more of the facilities regulated under 10 CFR Part 50 does not require a regulatory
analysis if the resulting safety benefit is required for purposes of compliance or adequate
protection under 10 CFR 50.109(a)(4).”

7.

Implementation

7.1

Proposed Rule
It is assumed that the rule would initially take effect 30 days after publication of the final

rule in the Federal Register. The rule would establish a staged implementation approach to
improve the efficiency and effectiveness of the migration to the new ECCS requirements. The
staged implementation plan would have a duration of 5 years. As the first step, vendors would
develop, and submit to the NRC for review via topical reports, hydrogen pick up models and
LOCA model updates. This is expected to occur during the first year. Also, during the first year,
the vendors would obtain PQD analytical methods by either: 1) using the analytical limits
provided in an NRC RG, or 2) using an NRC-approved experimental method provided in an RG.
(A third option, which involves the vendors developing their own experimental method for NRC
approval, is available but, due to the high cost and burden of this option, the NRC assumes that
no vendors will develop their own experimental method.) The PQD analytical limits that are

39

obtained via the approved experimental method would be submitted for NRC review in the form
of a topical report. Also, the vendors would perform long-term cooling tests to determine the
long-term cooling limit for each of the nine cladding alloys. Finally, during the first year after the
rule becomes effective, the vendors would perform initial breakaway testing. The results of the
initial breakaway tests would be submitted by the licensee via their license amendment request
(LAR) which is necessary to demonstrate compliance with the proposed rule.
As part of this implementation plan, licensees will be divided among three
implementation tracks based upon existing margin to the revised requirements and anticipated
level of effort to demonstrate compliance. The purpose of the staged implementation approach
is to bring licensees into compliance as quickly as possible, while accounting for: 1) more effort
and longer schedules will be necessary for plants that require new LOCA analyses with revised
LOCA models; and 2) differences between realistic and appendix K to 10 CFR part 50 LOCA
models.
Lastly, the tracks will begin to conduct periodic breakaway testing 1 year after they are in
full compliance. (Track 1 to being periodic breakaway testing in Year 3, Track 2 in Year 5 and
Track 3 in Year 6.) The results of these tests will be included in the annual ECCS submittal.
The proposed rule would allow licensees to use an alternative risk-informed approach to
evaluate the effects of debris on long-term cooling. The NRC would allow partial early
implementation of the proposed requirements of § 50.46c, limited to the alternate approach.
However, the NRC assumes in this analysis that the alternatives would be submitted the same
year as compliance with the embrittlement criteria is demonstrated. Entities that choose this
approach would submit the alternative approach to the NRC for review and approval.
Additionally, the licensees would have to submit all changes to the approved alternatives to the
NRC for review.

40

7.2

Regulatory Guidance
There are three DGs developed along with the proposed rule. The three DGs are: DG-

1261, “Conducting Periodic Testing for Breakaway Oxidation Behavior” (ADAMS Accession No.
ML12284A324); DG-1262, “Testing for Post Quench Ductility” (ADAMS Accession No.
ML12284A325); and DG-1263, “Establishing Analytical Limits for Zirconium-Based Alloy
Cladding” (ADAMS Accession No. ML12284A323). These RGs would be available for use as
guidance immediately upon their issuance in final form; issuance in final form may pre-date the
necessary date for compliance with the rule as specified in § 50.46c(o). The NRC will develop
draft guidance for the risk-informed alternative to address the effects of debris on long-term
cooling. The draft guidance will be published for comment upon completion, which is currently
anticipated for early- to mid-calendar year 2015. The NRC will then evaluate public comments
received on the draft guidance, and develop the final guidance on a timeline that ensures all
guidance (both for the risk-informed alternative and the new proposed embrittlement criteria) is
available when the NRC staff provides the final § 50.46c rule to the Commission (currently
scheduled for February 2016).

41

Appendix A – References
NUREG/BR-0058, Revision 4, “Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory
Commission,” dated September 2004, available at http://www.nrc.gov/reading-rm/doccollections/nuregs/brochures/br0058/br0058r4.pdf and ADAMS Accession No. ML042820192.
NUREG/BR-0184, “Regulatory Analysis Technical Evaluation Handbook,” dated January 1997,
available at http://pbadupws.nrc.gov/docs/ML0501/ML050190193.pdf and ADAMS Accession
No. ML050190193.
NUREG/CR-4627, “Generic Cost Estimates: Abstracts from Generic Studies for Use in
Preparing Regulatory Impact Analyses,” dated February 1992, available at
http://pbadupws.nrc.gov/docs/ML1313/ML13137A259.pdf and ADAMS Accession No.
ML13137A259.
NUREG-1409, “Backfitting Guidelines,” dated July 1990, available at
http://pbadupws.nrc.gov/docs/ML0322/ML032230247.pdf and ADAMS Accession No.
ML032230247.
Section 50.109 of Title 10 of the Code of Federal Regulations, “Backfitting,” available at
http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-0109.html.
SECY-98-300, “Options for Risk-Informed Revisions to 10 CFR Part 50-‘Domestic Licensing of
Production and Utilization Facilities,’” dated December 23, 1998, available at
http://www.nrc.gov/reading-rm/doc-collections/commission/secys/1998/secy1998-300/1998300scy.pdf and ADAMS Accession No. ML992870048.
SECY-02-0057, “Update to SECY-01-0133, ‘Fourth Status Report on Study of Risk-Informed
Changes to the Technical Requirements of 10 CFR Part 50 (Option 3) and Recommendations
on Risk-Informed Changes to 10 CFR 50.46 (ECCS Acceptance Criteria),’” dated March 29,
2002, available at http://www.nrc.gov/reading-rm/doccollections/commission/secys/2002/secy2002-0057/2002-0057scy.pdf and ADAMS Accession
No. ML020660607.
SRM-SECY-02-0057, “Staff Requirements – SECY-02-057 – Update to SECY-01-0133, ‘Fourth
Status Report on Study of Risk-Informed Changes to the Technical Requirements of
10 CFR Part 50 (Option 3) and Recommendations on Risk-Informed Changes to 10 CFR 50.46
(ECCS Acceptance Criteria),” dated March 31, 2003, available at
http://pbadupws.nrc.gov/docs/ML0309/ML030910476.pdf and ADAMS Accession No.
ML030910476.
SRM-SECY-12-0034, “Staff Requirements – SECY-12-0034 – Proposed Rulemaking – 10 CFR
50.46c: Emergency Core Cooling System Performance During Loss-of-Coolant Accidents (RIN
3150-AH42),” dated January 7, 2013, available at
http://pbadupws.nrc.gov/docs/ML1300/ML13007A478.pdf and ADAMS Accession No.
ML13007A478.

A-1

Section 50.44 of Title 10 of the Code of Federal Regulations, “Combustible Gas Control for
Nuclear Power Reactors,” available at http://www.nrc.gov/reading-rm/doccollections/cfr/part050/part050-0044.html.
Section 50.46 of Title 10 of the Code of Federal Regulations, “Acceptance Criteria for
Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors,” available at
http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-0046.html.
Section 50.46a of Title 10 of the Code of Federal Regulations, “Acceptance Criteria for Reactor
Coolant System Venting Systems,” available at http://www.nrc.gov/reading-rm/doccollections/cfr/part050/part050-0046a.html.
DG-1261, Draft Regulatory Guide for “Conducting Periodic Testing for Breakaway Oxidation
Behavior,” ADAMS Accession No. ML12284A324.
DG-1262, Draft Regulatory Guide for “Testing for Post Quench Ductility,” ADAMS Accession
No. ML12284A325.
DG-1263, Draft Regulatory Guide for “Establishing Analytical Limits for Zirconium-Based Alloy
Cladding,” ADAMS Accession No. ML12284A323.
RIL-0801, “Technical Basis for Revision of Embrittlement Criteria in 10 CFR 50.46,” dated May
30, 2008, available at http://pbadupws.nrc.gov/docs/ML0813/ML081350225.pdf and ADAMS
Accession No. ML081350225.
NUREG/CR-6967, “Cladding Embrittlement during Postulated Loss-of-Coolant accidents,” dated
July 7, 2008, available at http://pbadupws.nrc.gov/docs/ML0817/ML081780360.pdf and ADAMS
Accession No. ML081780360.
65 FR 34599, PRM-50-71, “Nuclear Energy Institute; Receipt of Petition for Rulemaking,” dated
May 31, 2000, available at http://www.gpo.gov/fdsys/pkg/FR-2000-05-31/pdf/00-13515.pdf.
73 FR 66000, PRM-50-71, “Anthony R. Pietrangelo, Nuclear Energy Institute; Consideration of
Petition in the Rulemaking Process,” dated November 6, 2008, available at
http://www.gpo.gov/fdsys/pkg/FR-2008-11-06/pdf/E8-26463.pdf.
72 FR 28902, PRM-50-84, “Mark Edward Leyse; Receipt of Petition of Rulemaking,” dated May
23, 2007, available at http://www.gpo.gov/fdsys/pkg/FR-2007-05-23/pdf/E7-9901.pdf.
73 FR 71564, PRM-50-84, “Mark Edward Leyse; Consideration of Petition in Rulemaking
Process,” dated November 25, 2008, available at http://www.gpo.gov/fdsys/pkg/FR-2008-1125/pdf/E8-27938.pdf.
“NRC Workshop Summary of September 24, 2008 Public Meeting,” dated October 29, 2008,
available at http://pbadupws.nrc.gov/docs/ML0830/ML083010496.pdf and ADAMS Accession
No. ML083010496.

A-2

B-1

Appendix B - Tables

Cladding Hydrogen Uptake Models (Including Topic Rpts)

2019
2016
2017
2016
2017
2017

Track #1
Exemption Request (ER) Preperation and Submission
Track #2
Exemption Request (ER) Preperation and Submission
Track #3
Exemption Request (ER) Preperation and Submission

2018
2018
2019
2019
2020
2020

2017
2018
2018
2019
2020
2019
2020
2021

Year

12

13

Track #2

Track #3

B-2

49

Number of AOR

10
56
1
4
1
4

Number of
AOR/Unit

Track #1

Activity (Includes PQD, Breakaway, LTC)

Industry Implementation Costs

Activity (Alternative Approach)

Year

Industry Implementation Costs: Risk-Informed Alternative

Initial Breakaway Test

LOCA Models (LTC)

LOCA Models (PQD, Breakaway)

Activity

Year

Number of
Models/Cladding
Alloys
9
6
6
6
6
9
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
Total:

Yearly Rate

0.25
0.25
0.50
0.50
0.50
0.75
0.75
0.75

$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
Total:

Yearly Rate

Undiscounted

$5,000,000
($2,000,000)
$500,000
($140,000)
$500,000
($140,000)
$3,700,000

Undiscounted

$1,400,000
$900,000
$900,000
$600,000
$600,000
$600,000
$5,000,000

Undiscounted

$2,500,000
$2,500,000
$1,200,000
$200,000
$1,200,000
$1,200,000
$1,950,000
$200,000
$1,950,000
$1,950,000
Total: $14,000,000
$200,000

Yearly Rate

Per AOR
FTE Required

2.5
0.18
2.5
0.18
2.5
0.18

FTE Required

Per AOR/Unit

0.75
0.75
0.75
0.50
0.50
0.33

FTE Required

Per Model/Cladding Alloy

Table 2 - Industry Implementation Costs for Operating Reactors

Industry Implementation Costs (Indirect - Vendor Implementation Costs)

$2,500,000
$2,400,000
$1,200,000
$1,100,000
$1,100,000
$1,800,000
$1,800,000
$1,700,000
$14,000,000

3% NPV

Cost per year

$4,900,000
($1,900,000)
$470,000
($130,000)
$460,000
($130,000)
$3,700,000

3% NPV

Cost per year

$1,400,000
$900,000
$900,000
$600,000
$600,000
$600,000
$5,000,000

3% NPV

Cost per year

$2,500,000
$2,300,000
$1,100,000
$1,000,000
$980,000
$1,700,000
$1,600,000
$1,500,000
$13,000,000

7% NPV

$4,700,000
($1,900,000)
$440,000
($120,000)
$410,000
($110,000)
$3,400,000

7% NPV

$1,400,000
$900,000
$900,000
$600,000
$600,000
$600,000
$5,000,000

7% NPV

Exemption Requests
Exemption Requests
Exemption Requests
Exemption Requests
Exemption Requests
Exemption Requests
Exemption Requests
Exemption Requests
Exemption Requests
Exemption Requests

(ER) Preparation and Submission
(ER) Preparation and Submission
(ER) Preparation and Submission
(ER) Preparation and Submission
(ER) Preparation and Submission
(ER) Preparation and Submission
(ER) Preparation and Submission
(ER) Preparation and Submission
(ER) Preparation and Submission
(ER) Preparation and Submission

Activity

PQD Test - Accepted NRC Reg Guide
PQD Test - Redone NRC Version
PQD Test - Industry Version

2017
2017
2017

Activity
LTC Tests

Year

2017

Industry Implementation Option Costs: LTC Tests

Activity

Year

Industry Implementation Option Costs: PQD Tests

2017
2018
2019
2020
2021
2022
2023
2024
2025
2026

Year

Industry Implementation Costs: Exemption Request Savings

$0
$100,000
$0
$100,000

Undiscounted

Per Cladding Alloy
Undiscounted
FTE Required
Yearly Rate
0.15
$200,000
$270,000
Total:
$270,000

Per Cladding Alloy
FTE Required
Yearly Rate
0
$200,000
0.25
$200,000
0.5 - 2.5
$200,000
Total:

Per Exemption Request
FTE Required
Yearly Rate Undiscounted
0.2
$200,000
($200,000)
0.2
$200,000
($200,000)
0.2
$200,000
($200,000)
0.2
$200,000
($200,000)
0.2
$200,000
($200,000)
0.2
$200,000
($200,000)
0.2
$200,000
($200,000)
0.2
$200,000
($200,000)
0.2
$200,000
($200,000)
0.2
$200,000
($200,000)
Total: ($2,000,000)

$21,000,000

Total Industry Operating Reactor Implementation Cost: $21,000,000

B-3

$5,000,000

$16,000,000

$270,000
$270,000

3% NPV

$0
$100,000
$0
$100,000

3% NPV

Cost per year
3% NPV
($200,000)
($190,000)
($190,000)
($180,000)
($180,000)
($170,000)
($170,000)
($160,000)
($160,000)
($150,000)
($1,800,000)

$5,000,000

Total Industry Operating Reactor Cost (Indirect):

Total Industry Operating Reactor Cost (Direct): $16,000,000

9

Number of
Cladding Alloys

Number of
Cladding Alloys
7
2
0

Number of
Exemption Requests
5
5
5
5
5
5
5
5
5
5

$20,000,000

$5,000,000

$15,000,000

$270,000
$270,000

7% NPV

$0
$100,000
$0
$100,000

7% NPV

7% NPV
($200,000)
($190,000)
($170,000)
($160,000)
($150,000)
($140,000)
($130,000)
($120,000)
($120,000)
($110,000)
($1,500,000)

Activity
Track #2

Year

2020

Industry Implementation Costs: Design Certification

$600,000

Undiscounted

Total Industry Design Certification Cost:

Yearly Rate
$600,000
$600,000

1.50

FTE Required

Per Design Certification

$200,000
Total:

B-4

2

Number of Design
Certifications

Table 3 - Industry Implementation Costs for Design Certifications

$550,000

$550,000
$550,000

3% NPV

Cost per year

$490,000

$490,000
$490,000

7% NPV

Initial Breakaway Test (Watts Bar, Vogtle 2 & 3, Summer 2)
Initial Breakaway Test (Summer 3)
Initial Breakaway Test (Bellefonte)

2017
2019
2020

4
1

Track #1 (Vogtle and Summer Units)
Track #1 (Bellefonte)

$580,000

$700,000

Total Industry Future Operating Reactor Implementation Cost:

B-5

$540,000

$648,000

Total Industry Future Operating Reactor Implementation Cost (Direct):

$32,000
$7,000
$7,000
$46,000

3% NPV

$50,000
$44,000
$160,000
$160,000
$38,000
$37,000
$490,000

3% NPV

$47,000

4
1
1

$50,000
$50,000
$200,000
$200,000
$50,000
$50,000
$600,000

Undiscounted

Cost per year

Cost per year
3% NPV
$32,000
$8,000
$7,000
$47,000

$48,000

LTC Test (Watts Bar, Vogtle 2 & 3, Summer 2)
LTC Tests (Summer 3)
LTC Tests (Bellefonte)

2020
2022
2023

Total:

$200,000

$200,000

$200,000

Yearly Rate

Per Reactor
Undiscounted
FTE Required
Yearly Rate
0.04
$200,000
$32,000
0.04
$200,000
$8,000
0.04
$200,000
$8,000
Total:
$48,000

0.25
0.25
0.25
0.25
0.25
0.25

FTE Required

Per AOR

Per Reactor
FTE Required
Yearly Rate Undiscounted
0.04
$200,000
$32,000
0.04
$200,000
$8,000
0.04
$200,000
$8,000
Total:
$48,000

Total Industry Future Operating Reactor Implementation Cost (Indirect):

Activity

Year

Number of Reactor

1

Number of AOR

4
1
1

Number of Reactor

Track #1 (Watts Bar)

Activity (Includes PQD, Breakaway, LTC)

Industry Implementation Option Costs: LTC Tests: Future Operating Reactors

2020
2021
2024
2025
2026
2027

Year

Industry Implementation Costs: Future Operating Reactors

Activity

Year

Industry Implementation Costs (Indirect - Vendor Implementation Costs): Future Operating Reactors

Table 4 - Industry Implementation Costs for Future Operating Reactors

$460,000

$410,000

$46,000

$32,000
$6,000
$5,000
$43,000

7% NPV

$41,000
$38,000
$120,000
$120,000
$27,000
$25,000
$370,000

7% NPV

7% NPV
$32,000
$7,000
$7,000
$46,000

Activity (Update to PRA)

Track #1
Error Found and Change Made
Track #2
Error Found and Change Made
Track #3
Error Found and Change Made
Track # 2
Error Found and Change Made
Track #1
Error Found and Change Made
Track # 2
Error Found and Change Made
Track #3
Error Found and Change Made
Track # 2
Error Found and Change Made
Track #1
Error Found and Change Made
Track # 2
Error Found and Change Made
Track #3
Error Found and Change Made
Track # 2
Error Found and Change Made
Track #1
Error Found and Change Made
Track # 2
Error Found and Change Made
Track #3
Error Found and Change Made
Track # 2
Error Found and Change Made
Track #1
Error Found and Change Made
Track # 2
Error Found and Change Made
Track #3
Error Found and Change Made

Year

2021
2021
2022
2022
2023
2023
2024
2024
2025
2025
2026
2026
2027
2027
2028
2028
2029
2029
2030
2030
2031
2031
2032
2032
2033
2033
2034
2034
2035
2035
2036
2036
2037
2037
2038
2038
2039
2039

B-6

10
1
1
1
1
1
0
1
10
1
1
1
1
1
0
1
10
1
1
1
1
1
0
1
10
1
1
1
1
1
0
1
10
1
1
1
1
1

Number of AOR
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050
0.050

FTE Required
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,000
$200,001
Total:

Yearly Rate

Per AOR

Table 5 - Industry Operation Costs for Operating Reactors

Industry Operation Costs (Risk-Informed Alternative)

$100,000
$10,000
$10,000
$10,000
$10,000
$10,000
$0
$10,000
$100,000
$10,000
$10,000
$10,000
$10,000
$10,000
$0
$10,000
$100,000
$10,000
$10,000
$10,000
$10,000
$10,000
$0
$10,000
$100,000
$10,000
$10,000
$10,000
$10,000
$10,000
$0
$10,000
$100,000
$10,000
$10,000
$10,000
$10,000
$10,000
$790,000

Total
$89,000
$8,900
$8,600
$8,600
$8,400
$8,400
$0
$8,100
$79,000
$7,900
$7,700
$7,700
$7,400
$7,400
$0
$7,200
$70,000
$7,000
$6,800
$6,800
$6,600
$6,600
$0
$6,400
$62,000
$6,200
$6,100
$6,100
$5,900
$5,900
$0
$5,700
$55,000
$5,500
$5,400
$5,400
$5,200
$5,200
$550,000

3% NPV

Cost per year

$76,000
$7,600
$7,100
$7,100
$6,700
$6,700
$0
$6,200
$58,000
$5,800
$5,400
$5,400
$5,100
$5,100
$0
$4,800
$44,000
$4,400
$4,100
$4,100
$3,900
$3,900
$0
$3,600
$34,000
$3,400
$3,200
$3,200
$3,000
$3,000
$0
$2,800
$26,000
$2,600
$2,400
$2,400
$2,300
$2,300
$370,000

7% NPV

Activity
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests

Year

2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039

Industry Operation Costs (Indirect - Vendor Operation Costs)

$7,000,000
$7,600,000
$29,000,000

$9,400,000

Total Industry Operating Reactor Operation Cost (Indirect):

Total Industry Operating Reactor Operation Cost: $10,000,000
Total Industry Operating Reactor Cost: $31,000,000

B-7

$550,000

$790,000

Total Industry Operating Reactor Operation Cost (Direct):

3% NPV
$570,000
$0
$530,000
$380,000
$500,000
$490,000
$470,000
$460,000
$450,000
$430,000
$420,000
$410,000
$400,000
$390,000
$370,000
$360,000
$350,000
$340,000
$330,000
$320,000
$310,000
$7,000,000

Total

7% NPV

$25,000,000

$5,300,000

$4,900,000

$370,000

$520,000
$0
$460,000
$310,000
$400,000
$370,000
$350,000
$330,000
$310,000
$290,000
$270,000
$250,000
$230,000
$220,000
$200,000
$190,000
$180,000
$170,000
$160,000
$140,000
$140,000
$4,900,000

Indirect Operation Cost

$600,000
$0
$600,000
$440,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$600,000
$9,400,000

Per Year
Per Reload
FTE Required
Yearly Rate
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
Total:

Number of
Reloads
60
0
60
44
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60

Table 6 - Industry Operation Costs for Future Operating Reactors
Industry Operation Costs (Indirect - Vendor Operation Costs): Future Operating Reactors
Indirect Operation Cost

Per Year
Year

Activity

2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041
2042
2043
2044
2045
2046
2047
2048
2049
2050
2051
2052
2053
2054
2055
2056
2057
2058
2059
2060
2061
2062
2063
2064
2065
2066
2067
2068
2069
2070
2071
2072
2073
2074
2075
2076
2077
2078
2079
2080

Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests
Periodic Breakaway Tests

Per Reload
FTE Required
Yearly Rate
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
0.05
$200,000
Total:

Total

3% NPV

7% NPV

$40,000
$0
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$50,000
$10,000
$40,000
$10,000
$10,000
$10,000
$0
$0
$1,700,000

$38,000
$0
$44,000
$8,600
$42,000
$8,100
$39,000
$7,700
$37,000
$7,200
$35,000
$6,800
$33,000
$6,400
$31,000
$6,100
$29,000
$5,700
$28,000
$5,400
$26,000
$5,100
$25,000
$4,800
$23,000
$4,500
$22,000
$4,200
$21,000
$4,000
$19,000
$3,800
$18,000
$3,600
$17,000
$3,300
$16,000
$3,200
$15,000
$3,000
$14,000
$2,800
$14,000
$2,600
$13,000
$2,500
$12,000
$2,300
$11,000
$2,200
$11,000
$2,100
$10,000
$2,000
$9,600
$1,900
$7,200
$1,700
$1,700
$1,600
$0
$0
$780,000

$35,000
$0
$38,000
$7,100
$33,000
$6,200
$29,000
$5,400
$25,000
$4,800
$22,000
$4,100
$19,000
$3,600
$17,000
$3,200
$15,000
$2,800
$13,000
$2,400
$11,000
$2,100
$9,900
$1,800
$8,600
$1,600
$7,500
$1,400
$6,600
$1,200
$5,700
$1,100
$5,000
$940
$4,400
$820
$3,800
$710
$3,300
$620
$2,900
$550
$2,500
$480
$2,200
$420
$1,900
$360
$1,700
$320
$1,500
$280
$1,300
$240
$1,100
$210
$790
$180
$170
$160
$0
$0
$380,000

Total Industry Future Operating Reactor Operation Cost (Indirect):

$1,700,000

$780,000

$380,000

Number of Reloads
4
0
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
5
1
4
1
1
1
0
0

B-8

$17,000,000
$22,000,000
$7,800,000
$31,000,000

Total Industry Cost (Direct): $17,000,000
Total Industry Implementation Cost: $22,000,000
Total Industry Operation Cost: $11,000,000
Total Industry Cost: $35,000,000

Activity (Alternative Approach)

Track #1
Exemption Request (ER) Preperation and Submission
Track #2
Exemption Request (ER) Preperation and Submission
Track #3
Exemption Request (ER) Preperation and Submission

Year

2018
2018
2019
2019
2020
2020

Industry Implementation Costs: Risk-Informed Alternative

Initial Breakaway Test

LOCA Models (LTC)

Total:

Total:

Cladding Hydrogen Update Models (Including Topic Rpts)

2019
2016
2017
2016
2017
2017
LOCA Models (PQD, Breakaway)

Activity

Year

B-9

$5,000,000
($2,000,000)
$500,000
($140,000)
$500,000
($140,000)
$3,700,000

Total Cost

$1,400,000
$900,000
$900,000
$600,000
$600,000
$600,000
$5,000,000

Total Cost

Industry Implementation Costs (Indirect - Vendor Implementation Costs): Operating Reactors

$4,900,000
($1,900,000)
$470,000
($130,000)
$460,000
($130,000)
$3,700,000

3% NPV

$1,400,000
$900,000
$900,000
$600,000
$600,000
$600,000
$5,000,000

3% NPV

$4,700,000
($1,900,000)
$440,000
($120,000)
$410,000
($110,000)
$3,400,000

7% NPV

$1,400,000
$900,000
$900,000
$600,000
$600,000
$600,000
$5,000,000

7% NPV

Average Cost Per AOR
(77 AORs)
3% NPV
7% NPV
$64,000
$61,000
($25,000)
($25,000)
$6,100
$5,700
($1,700)
($1,600)
$6,000
$5,300
($1,700)
($1,400)
$48,000
$44,000

Average Cost Per AOR
(77 AORs)
3% NPV
7% NPV
$18,000
$18,000
$12,000
$12,000
$12,000
$12,000
$8,000
$8,000
$8,000
$8,000
$8,000
$8,000
$66,000
$66,000

$26,000,000

$5,300,000

$21,000,000

$15,000,000

7% NPV
$11,000,000

Table 8 - Industry Average Implementation Cost per Designated Unit

Industry Costs
3% NPV
$14,000,000

Total:
Total Industry Cost (Indirect): $18,000,000

Table 7 - Total Industry Costs

Track # 3 (14 AORs)

Track # 2 (13 AORs)

Track #1 (50 AORs)

Activity (Includes PQD, Breakaway, LTC)

Activity
Exemption Request
Exemption Request
Exemption Request
Exemption Request
Exemption Request
Exemption Request
Exemption Request
Exemption Request
Exemption Request
Exemption Request

Year

2017
2018
2019
2020
2021
2022
2023
2024
2025
2026

Total Cost

B-10

($200,000)
($200,000)
($200,000)
($200,000)
($200,000)
($200,000)
($200,000)
($200,000)
($200,000)
($200,000)
Total: ($2,000,000)

Total Cost

$2,500,000
$2,500,000
$1,200,000
$1,200,000
$1,200,000
$1,950,000
$1,950,000
$1,950,000
Total: $14,000,000

Industry Implementation Costs: Exemption Request Savings: Operating Reactors

2017
2018
2018
2019
2020
2019
2020
2021

Year

Industry Implementation Costs: Operating Reactors

($200,000)
($190,000)
($190,000)
($180,000)
($180,000)
($170,000)
($170,000)
($160,000)
($160,000)
($150,000)
($1,800,000)

3% NPV

$2,500,000
$2,400,000
$1,200,000
$1,100,000
$1,100,000
$1,800,000
$1,800,000
$1,700,000
$14,000,000

3% NPV

($200,000)
($190,000)
($170,000)
($160,000)
($150,000)
($140,000)
($130,000)
($120,000)
($120,000)
($110,000)
($1,500,000)

7% NPV

$2,500,000
$2,300,000
$1,100,000
$1,000,000
$980,000
$1,700,000
$1,600,000
$1,500,000
$13,000,000

7% NPV

($3,000)
($2,000)
($2,000)
($2,000)
($2,000)
($2,000)
($2,000)
($2,000)
($2,000)
($2,000)
($21,000)

3% NPV

($3,000)
($2,000)
($2,000)
($2,000)
($2,000)
($2,000)
($2,000)
($2,000)
($2,000)
($1,000)
($20,000)

7% NPV

Average Cost Per AOR
(77 AORs)

Average Cost Per AOR
(77 AORs)
3% NPV
7% NPV
$32,000
$32,000
$31,000
$30,000
$16,000
$14,000
$14,000
$13,000
$14,000
$13,000
$23,000
$22,000
$23,000
$21,000
$22,000
$19,000
$180,000
$160,000

PQD Test - Accepted NRC Reg Guide
PQD Test - Redone NRC Version
PQD Test - Industry Version

2017
2017
2017

LTC Tests

2017
Total:

Total:

$270,000
$270,000

Total Cost

$0
$100,000
$0
$100,000

Total Cost

$600,000

Total Industry Design Certification Implementation Cost:

B-11

$600,000
$600,000

Initial Breakaway Test

2020

Undiscounted

Total:

Activity

Year

Industry Implementation Costs (Indirect - Vendor Implementation Costs): Design Certification

Total Industry Operating Reactor Implementation Cost: $21,000,000

Activity

Year

Industry Implementation Option Costs: LTC Tests: Operating Reactors

Activity

Year

Industry Implementation Option Costs: PQD Tests: Operating Reactors

$550,000

$550,000
$550,000

3% NPV

$21,000,000

$270,000
$270,000

3% NPV

$0
$100,000
$0
$100,000

3% NPV

$490,000

$490,000
$490,000

7% NPV

$20,000,000

$270,000
$270,000

7% NPV

$0
$100,000
$0
$100,000

7% NPV

$260,000

$280,000

$280,000
$280,000

3% NPV

$250,000

$250,000
$250,000

7% NPV

Average Cost Per Design
Certification (2 DCs)

$280,000

Average Cost Per AOR
(77 AORs)
3% NPV
7% NPV
$4,000
$4,000
$4,000
$4,000

Average Cost Per AOR
(77 AORs)
3% NPV
7% NPV
$0
$0
$1,000
$1,000
$0
$0
$1,000
$1,000

Track #1 (Bellefonte)

Track #1 (Vogtle and Summer Units)

Track #1 (Watts Bar)

Activity (Includes PQD, Breakaway, LTC)

Total Industry Future Operating Reactor Implementation Cost:

B-12

$700,000

Total:

LTC Test (Watts Bar, Vogtle 2 & 3, Summer 2)
LTC Tests (Summer 3)
LTC Tests (Bellefonte)

2020
2022
2023

Undiscounted

$50,000
$50,000
$200,000
$200,000
$50,000
$50,000
$600,000

Undiscounted

$32,000
$8,000
$8,000
$48,000

Undiscounted

$32,000
$8,000
$8,000
$48,000

Activity

Year

Industry Implementation Option Costs: LTC Tests: Future Operating Reactors

2020
2021
2024
2025
2026
2027

Year

Total:

Initial Breakaway Test (Watts Bar, Vogtle 2 & 3, Summer 2)
Initial Breakaway Test (Summer 3)
Initial Breakaway Test (Bellefonte)
Total:

Activity

Industry Implementation Costs: Future Operating Reactors

2017
2019
2020

Year

$540,000

$32,000
$6,000
$6,000
$44,000

3% NPV

$50,000
$41,000
$149,000
$144,000
$35,000
$34,000
$453,000

3% NPV

$32,000
$7,000
$7,000
$46,000

3% NPV

Industry Implementation Costs (Indirect - Vendor Implementation Costs): Future Operating Reactors

$390,000

$32,000
$5,000
$4,000
$41,000

7% NPV

$33,000
$31,000
$102,000
$95,000
$22,000
$21,000
$304,000

7% NPV

$32,000
$6,000
$5,000
$43,000

7% NPV
$8,000
$6,000
$5,000
$19,000

7% NPV

7% NPV
$33,000
$31,000
$26,000
$24,000
$22,000
$21,000
$157,000

$280,000

$8,000
$6,000
$6,000
$20,000

3% NPV

$190,000

$8,000
$5,000
$4,000
$17,000

7% NPV

Average Cost Per Reactor/AOR

3% NPV
$50,000
$41,000
$37,000
$36,000
$35,000
$34,000
$233,000

Average Cost Per Reactor/AOR

$8,000
$7,000
$7,000
$22,000

3% NPV

Average Cost Per Reactor/AOR

2015
2015
2015
2014
2015
2016
2018
2018
2019
2018
2019
NRC Review of LOCA Models (LTC)

NRC Review of LOCA Models (PQD, Breakaway)

NRC Review of Cladding Hydrogen Uptake Models

Development of Final Rule

Draft Regulatory Guide - Development & Issuance
Draft Regulatory Guide - Risk-Informed Alternative
Revise Regulatory Guides after Comment Period
Revise Risk-Informed Alternative Regulatory Guide after
Comment Period
Issue Final Regulatory Guides
Issue Final Regulatory Guide for Risk-Informed Alternative
Revise SRP

2014
2014
2014

2014

Activity

Year

NRC Implementation Costs

B-13

$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
Total:

$173,000

2
1
1
1
2
2
2
2
2
2
1
1

$173,000
$173,000
$173,000

Yearly Rate

2
2
2

FTE Required

$170,000
$170,000
$170,000
$350,000
$350,000
$350,000
$350,000
$350,000
$350,000
$170,000
$170,000
$4,400,000

$350,000

Undiscounted
$350,000
$350,000
$350,000

$170,000
$170,000
$170,000
$350,000
$350,000
$350,000
$340,000
$340,000
$330,000
$170,000
$160,000
$4,300,000

$350,000

Cost per year
3% NPV
$350,000
$350,000
$350,000

$170,000
$170,000
$170,000
$350,000
$350,000
$350,000
$330,000
$330,000
$310,000
$160,000
$150,000
$4,200,000

$350,000

7% NPV
$350,000
$350,000
$350,000

Table 9 - NRC Implementation Costs Affecting Operating Reactors, Design Certifications, and Future Operating Reactors

Track #1
Exemption Request Review
Track #2
Exemption Request Review
Track #3
Exemption Request Review

2019
2019
2020
2020
2021
2021

Track #3

Track #2

Track #1

Activity

Activity
Exemption Request Review
Exemption Request Review
Exemption Request Review
Exemption Request Review
Exemption Request Review
Exemption Request Review
Exemption Request Review
Exemption Request Review
Exemption Request Review
Exemption Request Review

Year

2017
2018
2019
2020
2021
2022
2023
2024
2025
2026

0
0
2
2
2
2

FTE Required

5.6
1.61
0.56
0.11
0.56
0.11

B-14

Number of
Exemption Requests
5
5
5
5
5
5
5
5
5
5

NRC Implementation Costs: Exemption Request Savings: Operating Reactors

2019
2020
2021
2022
2022
2023

Year

1

FTE Required

NRC Implementation Costs: License Amendment Reviews: Operating Reactors

Activity

Year

NRC Implementation Costs: Risk-Informed Alternative: Operating Reactors

NRC Implementation Costs: Operating Reactors
2018
Breakaway Test Review
$170,000
$170,000

Cost Per year
3% NPV
$0
$0
$310,000
$300,000
$300,000
$290,000
$1,200,000

Cost Per year
3% NPV
$830,000
($240,000)
$80,000
($17,000)
$78,000
($16,000)
$720,000

$170,000
$170,000

Per Exemption Request
FTE Required
Yearly Rate Undiscounted
0.1
$173,000
($87,000)
0.1
$173,000
($87,000)
0.1
$173,000
($87,000)
0.1
$173,000
($87,000)
0.1
$173,000
($87,000)
0.1
$173,000
($87,000)
0.1
$173,000
($87,000)
0.1
$173,000
($87,000)
0.1
$173,000
($87,000)
0.1
$173,000
($87,000)
Total: ($870,000)

Undiscounted
$173,000
$0
$173,000
$0
$173,000
$350,000
$173,000
$350,000
$173,000
$350,000
$173,000
$350,000
Total: $1,400,000

Yearly Rate

Undiscounted
$173,000
$960,000
$173,000
($280,000)
$173,000
$96,000
$173,000
($20,000)
$173,000
$96,000
$173,000
($20,000)
Total:
$830,000

Yearly Rate

$173,000
Total:

Table 10 - NRC Implementation Costs for Operating Reactors

Cost per year
3% NPV
($87,000)
($84,000)
($82,000)
($80,000)
($77,000)
($75,000)
($73,000)
($71,000)
($69,000)
($67,000)
($770,000)

7% NPV
$0
$0
$270,000
$250,000
$250,000
$230,000
$1,000,000

7% NPV
$680,000
($200,000)
$64,000
($13,000)
$60,000
($12,000)
$580,000

$160,000
$160,000

7% NPV
($87,000)
($81,000)
($76,000)
($71,000)
($66,000)
($62,000)
($58,000)
($54,000)
($51,000)
($47,000)
($650,000)

PQD Test - Accepted NRC Reg Guide
PQD Test - Redone NRC Version
PQD Test - Licensee Version

2018
2018
2018

LTC Test Reviews

2018

$173,000
$173,000
$173,000
Total:

Yearly Rate

3% NPV

B-15

$92,000

Per Design Certification
Undiscounted
FTE Required
Yearly Rate
0.27
$173,000
$92,000
Total:
$92,000

Total NRC Design Certification Implementation Cost:

NRC Implementation Costs: Certification Amendment Reviews: Design Certification
Number of Design
Year
Activity
Certifications
2021
Track #2
2

$70,000

$70,000
$70,000

$82,000
$82,000
$82,000

7% NPV

$5,600,000

$210,000
$210,000

7% NPV

$0
$81,000
$0
$81,000

7% NPV

3% NPV

$5,900,000

Undiscounted

Cost per year

$0
$84,000
$0
$84,000

3% NPV

Total NRC Operating Reactor Implementation Cost: $6,200,000

$173,000
Total:

Yearly Rate

$0
$87,000
$0
$87,000

Undiscounted

Cost per year

$220,000
$220,000

0.15

FTE Required

Per Cladding Alloy

0
0.25
0.5 - 2.5

FTE Required

Per Cladding Alloy

$230,000
$230,000

9

Number of Cladding
Alloys

7
2
0

Number of Cladding
Alloys

Table 11 - NRC Implementation Costs for Design Certifications

Activity

Year

NRC Implementation Costs: LTC Test Reviews: Operating Reactors

Activity

Year

NRC Implementation Costs: PQD Tests: Operating Reactors

Breakaway Test Review
(Watts Bar, Vogtle 2 & 3, Summer 2)
Breakaway Test Review (Summer 3)
Breakaway Test Review (Bellefonte)

Activity

0.01
0.01

0.05

FTE Required

Track #1 (Bellefonte)

Track #1 (Vogtle and Summer Units)

Track #1 (Watts Bar)

Activity (Includes PQD, Breakaway, LTC)

LTC Test Review (Watts Bar, Vogtle 2 & 3, Summer 2)
LTC Test Review (Summer 3)
LTC Test Review (Bellefonte)

2018
2023
2024

4
1
1

Number of Reactor

0
0
0
0
0
0

FTE Required
$0
$0
$0
$0
$0
$0
$0

Undiscounted

$2,000
$2,000
$12,000

$8,000

Undiscounted

B-16

$0
$0
$0
$0
$0
$0
$0

3% NPV

Cost per year

$2,000
$2,000
$12,000

$8,000

Cost per year
3% NPV

$54,000

Per Reactor
Undiscounted
FTE Required
Yearly Rate
0.04
$173,000
$28,000
0.04
$173,000
$7,000
0.04
$173,000
$7,000
Total:
$42,000

Total:

$173,000

$173,000

$173,000

Yearly Rate

$173,000
$173,000
Total:

$173,000

Yearly Rate

Total NRC Future Operating Reactor Implementation Cost:

Activity

Year

NRC Implementation Costs: LTC Test Reviews: Future Operating Reactors

2019
2020
2023
2024
2025
2026

Year

NRC Implementation Costs: License Amendment Reviews: Future Operating Reactors

2020
2021

2018

Year

NRC Implementation Costs: Future Operating Reactors

Table 12 - NRC Implementation Costs for Future Operating Reactors

$51,000

$27,000
$6,000
$6,000
$39,000

3% NPV

$0
$0
$0
$0
$0
$0
$0

7% NPV

$2,000
$2,000
$11,000

$7,000

7% NPV

$46,000

$26,000
$5,000
$4,000
$35,000

7% NPV

Table 13 - NRC Operation Costs for Operating Reactors
NRC Operation Costs: Operating Reactors
Per year
Start Year

Activity

2020
2021
2022
2022
2022
2023
2023
2023
2024
2024
2024
2024
2025
2025
2025
2026
2026
2026
2027
2027
2027
2028
2028
2028
2029
2029
2029
2030
2030
2030
2031
2031
2031
2032
2032
2032
2033
2033
2033
2034
2034
2034
2035
2035
2035
2036
2036
2036
2037
2037
2037
2038
2038
2038
2039
2039
2039

Periodic Breakaway Test Reviews
Periodic Breakaway Test Reviews
Periodic Breakaway Test Reviews
Update to PRA Reviews
Review of Error and Change
Periodic Breakaway Test Reviews
Update to PRA Reviews
Review of Error and Change
Periodic Breakaway Test Reviews
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change
Update to PRA Reviews
Periodic Breakaway Test Reviews
Review of Error and Change

FTE Required

Indirect Operation Cost
Total

3% NPV

7% NPV

$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
Total:

$26,000
$0
$26,000
$960,000
$5,000
$26,000
$96,000
$5,000
$26,000
$96,000
$0
$5,000
$0
$26,000
$5,000
$960,000
$0
$5,000
$96,000
$26,000
$5,000
$96,000
$0
$5,000
$0
$26,000
$5,000
$960,000
$0
$5,000
$96,000
$26,000
$5,000
$96,000
$0
$5,000
$0
$26,000
$5,000
$960,000
$0
$5,000
$96,000
$26,000
$5,000
$96,000
$0
$5,000
$0
$26,000
$5,000
$960,000
$0
$5,000
$96,000
$26,000
$5,000
$6,100,000

$24,000
$0
$22,000
$830,000
$4,300
$22,000
$80,000
$4,200
$21,000
$78,000
$0
$4,100
$0
$21,000
$3,900
$740,000
$0
$3,800
$71,000
$19,000
$3,700
$69,000
$0
$3,600
$0
$18,000
$3,500
$650,000
$0
$3,400
$63,000
$17,000
$3,300
$62,000
$0
$3,200
$0
$16,000
$3,100
$580,000
$0
$3,000
$56,000
$15,000
$2,900
$55,000
$0
$2,900
$0
$14,000
$2,800
$520,000
$0
$2,700
$50,000
$14,000
$2,600
$4,200,000

$21,000
$0
$19,000
$680,000
$3,600
$17,000
$64,000
$3,300
$16,000
$60,000
$0
$3,100
$0
$15,000
$2,900
$520,000
$0
$2,700
$49,000
$13,000
$2,500
$46,000
$0
$2,400
$0
$12,000
$2,200
$400,000
$0
$2,100
$37,000
$10,000
$1,900
$35,000
$0
$1,800
$0
$8,800
$1,700
$300,000
$0
$1,600
$28,000
$7,700
$1,500
$27,000
$0
$1,400
$0
$6,700
$1,300
$230,000
$0
$1,200
$22,000
$5,900
$1,100
$2,700,000

Total NRC Operating Reactor Operation Cost:

$6,100,000

$4,200,000

$2,700,000

0.15
0
0.15
5.6
0.029
0.15
0.56
0.029
0.15
0.56
0
0.029
0
0.15
0.029
5.6
0
0.029
0.56
0.15
0.029
0.56
0
0.029
0
0.15
0.029
5.6
0
0.029
0.56
0.15
0.029
0.56
0
0.029
0
0.15
0.029
5.6
0
0.029
0.56
0.15
0.029
0.56
0
0.029
0
0.15
0.029
5.6
0
0.029
0.56
0.15
0.029

B-17

Yearly Rate

Table 14 - NRC Operating Costs for Future Operating Reactors
NRC Operation Costs: Future Operating Reactors
Per Year
Year
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041
2042
2043
2044
2045
2046
2047
2048
2049
2050
2051
2052
2053
2054
2055
2056
2057
2058
2059
2060
2061
2062
2063
2064
2065
2066
2067
2068
2069
2070
2071
2072
2073
2074
2075
2076
2077
2078
2079
2080

Activity
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway
Periodic Breakaway

FTE Required

Indirect Operation Cost
Total

3% NPV

7% NPV

$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
$173,000
Total:

$6,920
$0
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$8,650
$1,730
$6,920
$1,730
$1,730
$1,730
$0
$300,000

$6,300
$0
$7,500
$1,400
$7,000
$1,400
$6,600
$1,300
$6,200
$1,200
$5,900
$1,100
$5,600
$1,100
$5,200
$1,000
$4,900
$960
$4,600
$900
$4,400
$850
$4,100
$800
$3,900
$760
$3,700
$710
$3,500
$670
$3,300
$630
$3,100
$600
$2,900
$560
$2,700
$530
$2,600
$500
$2,400
$470
$2,300
$440
$2,200
$420
$2,000
$390
$1,900
$370
$1,800
$350
$1,700
$330
$1,600
$310
$1,200
$290
$290
$280
$0
$130,000

$5,600
$0
$6,200
$1,200
$5,400
$1,000
$4,700
$880
$4,100
$770
$3,600
$670
$3,100
$590
$2,700
$510
$2,400
$450
$2,100
$390
$1,800
$340
$1,600
$300
$1,400
$260
$1,200
$230
$1,100
$200
$930
$170
$810
$150
$710
$130
$620
$120
$540
$100
$470
$88
$410
$77
$360
$67
$310
$59
$270
$51
$240
$45
$210
$39
$180
$34
$130
$30
$28
$26
$0
$62,000

Total NRC Future Operating Reactor Operation Cost:

$300,000

$130,000

$62,000

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0.04
0
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.05
0.01
0.04
0.01
0.01
0.01
0

B-18

Yearly Rate

$10,000,000

$6,300,000

Total NRC Operation Cost:
Total NRC Implementation Cost:
Total NRC Cost: $12,000,000

Average Implementation Costs
per AOR
Industry Costs (Direct)
Industry Costs (Indirect)
Total:

$76,000
$74,000
$150,000

$91,000
$100,000
$190,000

B-19

7% NPV

3% NPV
$10,000,000
$31,000,000
$41,000,000

Undiscounted
$13,000,000
$35,000,000
$48,000,000
3% NPV

3% NPV
$4,330,000
$7,800,000
$12,000,000

Undiscounted
Operation Costs
Total NRC Costs
$6,400,000
Total Industry Costs (Indirect) $11,000,000
Total:
$17,000,000
Grand Total 50.46c
Total NRC Costs
Total Industry Costs
Total:

3% NPV
$6,000,000
$17,000,000
$6,400,000
$29,000,000

Total Rule Costs
Undiscounted
Implementation Costs
Total NRC Costs
$6,300,000
Total Industry Costs (Direct)
$17,000,000
Total Industry Costs (Indirect)
$7,300,000
Total:
$31,000,000

Table 16 - Total Costs

$6,000,000

Total:
$6,000,000

NRC Costs
3% NPV
$4,300,000

Table 15 - Total NRC Costs

7% NPV
$8,500,000
$26,000,000
$35,000,000

7% NPV
$2,800,000
$5,300,000
$8,100,000

7% NPV
$5,700,000
$15,000,000
$5,900,000
$27,000,000

$8,500,000

$5,700,000

7% NPV
$2,800,000

PQD Test - Accepted NRC Reg Guide
PQD Test - Redone NRC Version
PQD Test - Industry Version

X
X
X

$2,000
$10,000

Total Industry Future Design Certification Cost (Direct):
Total Industry Future Design Certification Cost:

Breakaway Test Review

X+1

Activity
PQD Test - Accepted NRC Reg Guide
PQD Test - Redone NRC Version
PQD Test - Licensee Version

Year

X+1
X+1
X+1

Number of Design
Certifications
0
1
0

0.01

FTE Required

$2,000
$2,000

B-20

$3,000

Per Design Certification
Undiscounted
FTE Required
Yearly Rate
0
$173,000
$0
0.005
$173,000
$1,000
0.5 - 2.5
$173,000
$0
Total:
$1,000

$173,000
Total:

Yearly Rate

Total NRC Future Design Certification Implementation Cost:

NRC Implementation Costs: PQD Tests: Future Design Certification

Activity

Year

NRC Implementation Costs: Future Design Certification
Undiscounted

$8,000

Per Design Certification
Undiscounted
FTE Required
Yearly Rate
0
$200,000
$0
0.01
$200,000
$2,000
0.5 - 2.5
$200,000
$0
Total:
$2,000

Total Industry Future Design Certification Cost (Indirect):

Number of Design
Certifications
0
1
0

Table 18 - NRC Costs for Future Design Certifications

Activity

Year

Industry Implementation Option Costs: PQD Tests: Future Design Certificaion

Industry Implementation Costs (Indirect - Vendor Implementation Costs): Future Design Certification
Per Design Certification
Number of Design
Undiscounted
Year
Activity
Certifications
FTE Required
Yearly Rate
X
Initial Breakaway Test
1
0.04
$200,000
$8,000
Total:
$8,000

Table 17 - Industry Costs for Future Design Certifications

Track #1

X
X+1
1

Number of AOR

LTC Test

X

1

Number of Reactor

Activity
Periodic Breakaway Tests

Start Year

X+1.5

Total:

$200,000

Yearly Rate

$390,000
$398,000

Total Industry Hypothetical Future Operating Reactor Operation Cost:
Total Industry Hypothetical Future Operating Reactor Cost (Indirect):

B-21

$116,000

$6,667

Undiscounted
Total

Total Industry Hypothetical Future Operating Reactor Implementation Cost:

$200,000

Number of
Years

$390,000
$390,000

0.05

Total Cost

58.5
Total:

0.67

$50,000
$50,000
$100,000

Undiscounted

Per Reactor
Undiscounted
FTE Required
Yearly Rate
0.04
$200,000
$8,000
Total:
$8,000

0.25
0.25

FTE Required

Per AOR

Per Year
Per Reload
Average Number of
Reloads
FTE Required Yearly Rate

Industry Operation Costs (Indirect - Vendor Operation Costs): Hypothetical Future Operating Reactor

Activity

Year

Industry Implementation Option Costs: LTC Tests: Hypothetical Future Operating Reactor

Activity (Includes PQD, Breakaway, LTC)

Year

Industry Implementation Costs: Hypothetical Future Operating Reactor

Industry Implementation Costs (Indirect - Vendor Implementation Costs): Hypothetical Future Operating Reactor
Per Reactor
Year
Activity
Number of Reactor
Undiscounted
FTE Required
Yearly Rate
X
Initial Breakaway Test
1
0.04
$200,000
$8,000
Total:
$8,000

Table 19 - Industry Costs for Hypothetical Future Operating Reactor

Breakaway Test Review

X+1

0.08

FTE Required
$173,000
Total:

Yearly Rate

Track #1

0
0

LTC Test Review

X+1

Activity
Periodic Breakaway Test Reviews

Start Year

X+2.5

NRC Operation Costs: Hypothetical Future Operating Reactor

Activity

Year

$0
$0
$0

$41,000

Total NRC Hypothetical Future Operating Reactor Cost:

B-22

$20,000

Total NRC Hypothetical Future Operating Reactor Operating Cost:

Undiscounted
Total

$21,000

Number of
Years

Total NRC Hypothetical Future Operating Reactor Implementation Cost:

$346

Total Cost

$20,000
$20,000

$173,000

Yearly Rate

Per Year

Per Unit
Undiscounted
FTE Required
Yearly Rate
0.04
$173,000
$7,000
Total:
$7,000

Total:

$173,000

Undiscounted

$14,000
$14,000

Undiscounted

57.5
Total:

0.002

FTE Required

1

Number of Units

NRC Implementation Option Costs: LTC Test Reviews: Hypothetical Future Operating Reactor

X+1
X+2

NRC Implementation Costs: License Amendment Reviews: Hypothetical Future Operating Reactor
Per AOR
Year
Activity (Includes PQD, Breakaway, LTC)
FTE Required
Yearly Rate

Activity

Year

NRC Implementation Costs: Hypothetical Future Operating Reactor

Table 20 - NRC Costs for Hypothetical Future Operating Reactor