ML20136D670

Cost Analysis Group (Cag) Comments on Regulatory Impact Analysis of Proposed Revs to 10CFR73.71, Reporting of Safeguards Events

ML20136D670
Person / Time
Issue date:	03/25/1985
From:	NRC OFFICE OF RESOURCE MANAGEMENT (ORM)
To:
Shared Package
ML20136C160	List: IA-85-361, Forwards Cost Analysis Group Rept Re Cost Analysis in Support of Proposed Revs to 10CFR50,App J,Per Dec 1984 Request.Proposes That Rept Be Issued as Nureg.App J Revs Will Result in Cost Savings.W/O Rept ML20136C156 ML20136C289 ML20136C414 ML20136C458 ML20136C476 ML20136C501 ML20136C519 ML20136C549 ML20136C951 ML20136C957 ML20136C967 ML20136C986 ML20136D017 ML20136D045 ML20136D070 ML20136D108 ML20136D124 ML20136D226 ML20136D242 ML20136D266 ML20136D294 ML20136D311 ML20136D328 ML20136D345 ML20136D376 ML20136D400 ML20136D428 ML20136D598 ML20136D614 ML20136D622 ML20136D647 ML20136D670 ML20136D695 ML20136D709 ML20136D731 ML20136D743 ML20136E335 ML20136E359 ML20136E376 NUREG/CR-4025, Preliminary Review of Cost Analysis Contained in NUREG/CR-4025 Concerning Proposed Design Mods to Gessar
References
FOIA-85-361 NUDOCS 8511210343
Download: ML20136D670 (2)

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THE COST ANALYSIS GROUP'S (CAG) COMMENTS ON THE REGULATORY IMPACT ANALYSIS OF THE PROPOSED REVISIONS T0 t

10 CFR 73 71 -- REPORTING 0F SAFEGUARDS EVENTS ared by:

COST ANALYSIS GROUP

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THE COST ANALYSIS GROUP'S (CAG) COMMENTS' ON TFE REGULATORY IMPACT ANALYSIS OF THE PROPOSED REVISIONS TO 10 CFR 73.71 -- REPORTING OF SAFEGUARDS EVEN This report is a review of the cost analysis portion of NMSS's value impact analysis of the Proposed Revisions to 10 CFR 73.71 -- Reporting of Safeguards Events.

The report is provided under the direction of the Cost Analysis Group's (CAG) Charter.

J The value impact analysis clearly.shows cost reductions to both the NRC and industry resulting from the proposed revisions.

Our review concludes that no major changes are required.

There are, however, some reccmmendations we offer which'may be of use, even to future value impact analyses.

First, there exist two handbooks which should be followed when preparing a value impact analysis.

One is "A Handbook for Value-Impact Assessment,"

NUREG/CR-3568, and the other is "A Handbook for Cost Estimating," NUREG/CR-3971. Second, the analysis assumes there exist 48 sites.

According to t

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" Licensed Operating Reactors," NUREG-0020, Vol. 8, No.12, December 1984, j

there are presently 85 operating power reactors on 56 sites.

We understand j

that your analysis of total industry cost is dependent upon the total number of industry reports made to the NRC, not the number of sites, hence this modification will have no change on your " bottom-11ne" estimate.

Fourth, in j

confirming your calculations, we were unable to replicate one estimate.

On

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Page 3, under Loc Entries, you report the Industry cost / year to be $17.4K.

We calculate the value to be $18K, but this has no significant impact on your results. Last, while paperwork cost burden is adequately addressed in the cost analysis, a specific statement should be. included under 2. Statutory Considerations.

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