Text

SECY-21-0098: Enclosure 3 - Draft Regulatory Analysis
	ML21222A057
Person / Time
Issue date:	11/29/2021
From:	; Office of Nuclear Material Safety and Safeguards
To:	;
	Doyle, Daniel
Shared Package
ML21222A044	List: SECY-21-0098, Enclosure 3 - Draft Regulatory Analysis;
References
	10 CFR Part 51, ANR GEIS, NRC-2020-0101, RIN 3150-AK55 SECY-21-0098
	Download: ML21222A057 (154)
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Regulatory Analysis for the 10 CFR Part 51, Advanced Nuclear Reactor Generic Environmental Impact Statement Proposed Rule NRC-2020-0101; RIN 3150-AK55 U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Division of Rulemaking, Environmental, and Financial Support

[ENTER DATE WHEN READY TO ISSUE]

Regulatory Analysis Page ii ABSTRACT The U.S. Nuclear Regulatory Commission (NRC or the Commission) is proposing to amend the requirements in Part 51 of Title 10 of the Code of Federal Regulations (10 CFR), Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, to include the results of the Advanced Nuclear Reactor Generic Environmental Impact Statement (ANR GEIS). In September 2020, the Commission approved the development of a GEIS for the construction and operation of ANRs using a technology-neutral, plant parameter envelope (PPE) approach and directed staff to codify the GEISs findings in the Code of Federal Regulations. This document presents a draft regulatory analysis of the benefits and costs of the proposed rule requirements, the ANR GEIS, Regulatory Guide 4.2, Preparation of Environmental Reports for Nuclear Power Stations, and COL-ISG-030 Environmental Considerations for Advanced Nuclear Reactor Applications that Reference the Generic Environmental Impact Statement, relative to the baseline case (i.e., the No-Action alternative).

Regulatory Analysis Page iii CONTENTS ABSTRACT .................................................................................................................................. ii LIST OF FIGURES ....................................................................................................................... v LIST OF TABLES ........................................................................................................................ vi ABBREVIATIONS AND ACRONYMS ....................................................................................... vii EXECUTIVE

SUMMARY

........................................................................................................... viii

1.0 INTRODUCTION

.............................................................................................................. 1-1 1.1 Statement of the Problem and Objective of the Rulemaking .................................. 1-1 1.2 Background ............................................................................................................. 1-2 1.3 ANR GEIS Methodology ......................................................................................... 1-3 2.0 IDENTIFICATION AND PRELIMINARY ANALYSIS OF ALTERNATIVE APPROACHES ................................................................................................................ 2-1 2.1 Alternative 1: No-Action ......................................................................................... 2-1 2.2 Alternative 2: Issue ANR GEIS and Codify Findings in 10 CFR Part 51 ................ 2-1 3.0 EVALUATION OF BENEFITS AND COSTS..................................................................... 3-1 3.1 Attributes Affected by the Rulemaking .................................................................... 3-1 3.2 Analytical Methodology ........................................................................................... 3-2 3.2.1 Baseline for the Analysis ............................................................................. 3-2 3.2.2 Affected Applicants ..................................................................................... 3-2 3.3 Analysis of Alternative 2 Implementation ................................................................ 3-3 3.3.1 Industry Implementation .............................................................................. 3-3 3.3.2 Industry Operations ..................................................................................... 3-4 3.3.3 NRC Implementation ................................................................................. 3-14 3.3.4 NRC Operations ........................................................................................ 3-14 4.0 RESULTS ......................................................................................................................... 4-1 4.1 Benefits and Costs .................................................................................................. 4-1 4.1.1 Quantitative Results .................................................................................... 4-1 4.1.2 Qualitative Results ...................................................................................... 4-1 4.2 Disaggregation ........................................................................................................ 4-2 4.3 Uncertainty Analysis ............................................................................................... 4-2 4.3.1 Uncertainty Model Inputs ............................................................................ 4-3 4.3.2 Uncertainty Model Results .......................................................................... 4-5 4.3.3 Sensitivity Analysis...................................................................................... 4-7 5.0 DECISION RATIONALE ................................................................................................... 5-1

Regulatory Analysis Page iv 6.0 IMPLEMENTATION ......................................................................................................... 6-1 6.1 Schedule ................................................................................................................. 6-1 6.2 Impact on Other Requirements ............................................................................... 6-1

7.0 REFERENCES

................................................................................................................. 7-1 Appendix A -

SUMMARY

OF RULE SAVINGS RESULTS - ALTERNATIVE 2.................... A-1

Regulatory Analysis Page v LIST OF FIGURES Figure 4.1 Relative Frequency of the Undiscounted Net Benefits of the Proposed Rule (2021 Dollars) ........................................................................................................ 4-6 Figure 4.2 Relative Frequency of the Net Benefits of the Proposed Rule at 7 Percent and 3 Percent Discounting (2021 Dollars).................................................................... 4-6 Figure 4.3 Tornado Diagram for the Net Benefits of the Proposed Rule (2021 Dollars) ........ 4-8 Figure 4.4 Distribution of NEPA Review Complexity used in Monte Carlo Analysis .............. 4-9 Figure 4.5 Distribution of Total Category 1 Issues Analyzed during the Proposed Rule (2024-2034). ....................................................................................................... 4-10

Regulatory Analysis Page vi LIST OF TABLES Table ES-1 Total Costs and Benefits of Alternative 2 ................................................................ viii Table 3.1 Annual Industry Implementation Costs (2021 Constant Dollars)........................... 3-4 Table 3.2 2024-2034 Financial Impact of Industry Operations under the Proposed Rule by Issue (2021 Constant Dollars) .......................................................................... 3-6 Table 3.3 NRC Costs of Rule Implementation (2021 Constant Dollars) ............................. 3-14 Table 3.4 2024-2034 Financial Impact of NRC Operation under the Proposed Rule by Issue (2021 Constant Dollars) ............................................................................. 3-16 Table 4.1 Net Benefits (Costs) of Alternative 2 Implementation and Operations .................. 4-1 Table 4.2 Summary of Results for Alternative 2 (Update and Amend 10 CFR Part 51) ....... 4-2 Table 4.3 Relative Expected Effort of Alternative NRC ANR NEPA Review Cases.............. 4-4 Table 4.4 Example Variables and Distributions Used in the Monte Carlo Analysis .............. 4-5 Table 4.5 Confidence Intervals for Alternative 2 Benefits and Costs of the Proposed Rule at 7 Percent and 3 Percent Discounting (in 2021 Dollars) .................................... 4-7 Table A-1. Summary of Proposed Rule Savings Benefits to Industry by Category 1 Issue (2021 Constant Dollars) ....................................................................................... A-2

Regulatory Analysis Page vii ABBREVIATIONS AND ACRONYMS ac acre(s)

ANR advanced nuclear reactor CFR Code of Federal Regulations COL combined license EIS environmental impact statement ER Environmental Report ESP early site permit FRN Federal Register notice GEIS generic environmental impact statement LWR light-water reactor N/A not applicable NEIMA Nuclear Energy Innovation and Modernization Act of 2019 NEPA National Environmental Policy Act of 1969, as amended NPV net present value NRC U.S. Nuclear Regulatory Commission OFR Office of the Federal Register OL operating license OMB Office of Management and Budget PPE plant parameter envelope RG regulatory guide ROW right-of-way SEIS supplemental environmental impact statement SME subject matter expert SPE site parameter envelope SRM staff requirements memorandum

Regulatory Analysis Page viii EXECUTIVE

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) is proposing to amend its regulations that govern the NRCs National Environmental Policy Act (NEPA) reviews. The rulemaking would codify the generic findings of the Advanced Nuclear Reactor Generic Environmental Impact Statement (ANR GEIS). The ANR GEIS would use a technology-neutral regulatory framework and performance-based assumptions to determine generic environmental impacts of new commercial advanced nuclear reactors. The ANR GEIS would streamline the NEPA reviews for future advanced reactor applicants. The proposed rule would codify these generic findings into the NRCs regulations in Part 51 of Title 10 of the Code of Federal Regulations (10 CFR),

Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, thus making the NRCs licensing process more efficient. Specifically, these findings would be codified into Subpart A of 10 CFR Part 51, which sets forth the NRCs regulations to implement its obligations under NEPA. Major provisions of this proposed rule and guidance would include:

Addition of a new Appendix C to Subpart A of 10 CFR 51 to document the Commissions findings in the ANR GEIS.

Changes to the regulations for the preparation of environmental reports for new reactors (e.g., 10 CFR 51.50) to provide the applicant with the option to use the ANR GEIS.

Changes to the regulations for the preparation of environmental impact statements for new reactors (e.g., 10 CFR 51.75 and 10 CFR 51.96) to provide the NRC staff with the option to use the ANR GEIS.

Draft revisions to Regulatory Guide (RG) 4.2 to provide guidance to applicants regarding the use of the ANR GEIS. In addition, the staff has prepared a draft interim staff guidance document, COL-ISG-030, to provide guidance to the staff regarding the use of the ANR GEIS.

This regulatory analysis discusses two alternatives - Alternative 1, the no-action or status quo alternative, and Alternative 2, pursuance of the proposed rule. For Alternative 2, the regulatory analysis evaluates the costs and benefits of the proposed rule requirements and development of the ANR GEIS and associated guidance documents. It derives the key findings summarized in Table ES-1Error! Reference source not found..

Table ES-1 Total Costs and Benefits of Alternative 2 Description Undiscounted 7% NPV 3% NPV Industry $8,564,784 $5,047,780 $6,777,377 NRC $8,623,104 $4,749,675 $6,624,783 Total Benefit $17,187,888 $9,797,455 $13,402,159 Industry Cost ($400,000) ($361,604) ($382,694)

NRC Cost ($2,313,955) ($2,072,666) ($2,204,611)

Total Cost ($2,713,955) ($2,434,269) ($2,587,305)

Net Benefits $14,473,933 $7,363,186 $10,814,854

Regulatory Analysis Page ix According to Executive Order 12866, an economically significant regulatory action is one that would have an annual effect on the economy of $100 million or more. This proposed rulemaking does not reach this threshold.

Regulatory Analysis Page 1-1

1.0 INTRODUCTION

The U.S. Nuclear Regulatory Commission (NRC or the Commission) is proposing to amend the requirements in Part 51 of Title 10 of the Code of Federal Regulations (10 CFR), Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions (10 CFR Part 51-TN250) to include the results of the Advanced Nuclear Reactor Generic Environmental Impact Statement (ANR GEIS). The NRC is adding these new regulations to its existing environmental regulatory framework by incorporating the findings from NUREG-2249 (Generic Environmental Impact Statement for Advanced Nuclear Reactors [ANR GEIS]) through the rulemaking process. The ANR GEIS rule will define the number and scope of the environmental impact issues that must be addressed by the NRC during advanced reactor environmental reviews. As part of this rulemaking, the results of the ANR GEIS will be used to revise and update guidance to advanced nuclear reactor applicants in Regulatory Guide (RG) 4.2, Preparation of Environmental Reports for Nuclear Power Stations (NRC 2018-TN6006).

Guidance is also being prepared to describe how NRC staff should review information submitted by an advanced nuclear reactor applicant in its Environmental Report and how to prepare the resulting environmental impact statement (EIS). This guidance will be documented in COL-ISG-030, Environmental Considerations for Advanced Nuclear Reactor Applications that Reference the Generic Environmental Impact Statement, and formalized into more durable guidance in NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants as part of the greater 10 CFR Part 51 rulemaking, which will occur at a later date.

This document presents the regulatory analysis of the NRCs proposed new environmental protection regulations from the ANR GEIS as they relate to the issuance of early site permits (ESP), construction permits, operating license (OL), and combined licenses (COL) for advanced reactors. These new regulations will be presented in Table C-1, Summary of Findings on NEPA Issues for Advanced Nuclear Power Plants, in Appendix C to Subpart A, Environmental Effect of Issuing a License or Permit for an Advanced Nuclear Power Plant, of 10 CFR Part 51.

(Hereafter, this table is referred to as Table C-1 in this document.) This regulatory analysis includes the development of the rulemaking package, including the guidance to applicants and staff described above.

This introduction is divided into three sections. Section 1.1 states the problem and the objective of the rulemaking, Section 1.2 provides background information about the pertinent regulatory requirements in 10 CFR Part 51, and Section 1.3 describes the methodology used in the ANR GEIS.

1.1 Statement of the Problem and Objective of the Rulemaking In recent years, interest in developing and licensing ANRs in the United States using new technologies has increased. The increased interest is demonstrated by the recently enacted Nuclear Energy Innovation Capabilities Act of 2017 (Public Law 115-248; TN6468) and Nuclear Energy Innovation and Modernization Act of 2019 (NEIMA, Public Law 115-439; TN6469). One purpose of NEIMA is to provide a program for developing the expertise and regulatory processes necessary to allow innovation and commercialization of advanced nuclear reactors.

Under the NRCs environmental protection regulations in 10 CFR Part 51, which implement Section 102(2) of the National Environmental Policy Act of 1969 (NEPA, 42 U.S.C. §§ 4321 et seq.; TN661), licensing of an advanced nuclear power plant requires the preparation of an EIS. On September 21, 2020, the Commission issued Staff Requirements Memorandum

Regulatory Analysis Page 1-2 (SRM)-20-0020 (NRC 2020-TN6492), which directed staff to develop a GEIS for the construction and operation of ANRs using a technology-neutral, plant parameter envelope (PPE) approach and codify the GEISs findings in the Code of Federal Regulations. In November 2020, the staff committed to a schedule for development of the ANR GEIS and for major rulemaking activities and milestones. The purpose of the ANR GEIS, upon which the rulemaking is based, is to present impact analyses for environmental issues common to many or most advanced reactors that can be addressed generically, thereby eliminating the need to repeatedly reproduce the same analyses each time a licensing application is submitted and allowing applicants and NRC staff to focus future environmental review efforts on issues that can only be resolved once a site is identified. These generic impact analyses are documented and described in the ANR GEIS. The ANR GEIS is intended to improve the efficiency of licensing advanced reactors by (1) identifying the types of environmental impacts that may occur from constructing, operating and decommissioning an advanced reactor, (2) assessing impacts that are expected to be generic (the same or similar) for many or most advanced reactors, and (3) defining the environmental issues that will need to be addressed in project-specific supplemental EISs addressing specific projects.

The objective of the rulemaking is to codify the environmental findings from the GEIS in Table C-1 and amend the regulations in 10 CFR Part 51 for advanced reactor construction and operation, based on the technical findings in the ANR GEIS.

1.2 Background

On June 25, 2019, Senators Barrasso and Braun, from the U.S. Senate Committee on Environmental and Public Works, sent a letter to NRC Chairman Svinicki requesting that the NRC initiate a process to develop a Generic Environmental Impact Statement (GEIS) for the construction and operation of advanced reactors (Barrasso and Braun 2019-TN6465). On July 29, 2019, Chairman Svinicki responded that staff would prepare for the environmental review of applications for advanced reactors by conducting an exploratory process to determine whether the development of a GEIS for advanced reactors would provide an adequate environmental review and yield sufficient benefit to support taking this approach(NRC 2019-TN6467). Upon review, the staff determined that using a GEIS could accelerate and streamline the environmental review process of advanced reactors and began to plan the timing and approach of the exploratory analysis required by the Commission.

On November 15, 2019, the NRC staff issued a Federal Register notice (84 FR 62559-TN6470) announcing an exploratory process and soliciting comments to determine the possible utility of developing a GEIS for licensing ANRs. The exploratory process included two public meetings, a comprehensive public workshop attended by multiple stakeholders, and a site visit to the Idaho National Laboratory, one location that is being contemplated for some ANRs. As part of the exploratory process, the staff considered its experience with previous NRC GEIS documents that support power reactor license renewals, in situ uranium recovery facilities, and decommissioning. The staff gathered information to determine whether a GEIS for construction and operation of ANRs might be viable.

On February 28, 2020, the staff issued SECY-20-0020 (NRC 2020-TN6493) detailing the results of the exploratory process whereby the staff determined that development of a GEIS for advanced reactors would be beneficial because it would generically resolve many environmental issues, saving resources and providing predictability for potential applicants. On April 30, 2020, the NRC issued a Federal Register notice (85 FR 24040-TN6458) informing the public of its intent to develop an advanced reactor GEIS and to conduct a scoping process to

Regulatory Analysis Page 1-3 gather information necessary to prepare an advanced reactor GEIS for ANRs. The NRC held a webinar on May 28, 2020, to receive comments from the public about the scope of the GEIS (NRC 2020-TN6459). Based on comments received during the scoping period, the staff determined that using a technology-neutral, performance-based approach to develop the ANR GEIS that is inclusive of as many advanced reactor technologies as possible and would, where possible, decouple resource areas from reactor power level.

In response to the staffs exploratory and scoping process, and as described in Section 1.1 above, the Commission issued SRM-20-0020 (NRC 2020-TN6492) dated September 21, 2020, which approved the development of a GEIS for the construction and operation of ANRs using a technology-neutral, PPE approach and directed staff to codify the GEISs findings in the Code of Federal Regulations.

1.3 ANR GEIS Methodology In preparing the ANR GEIS, the staff determined that certain environmental impacts associated with licensing an advanced nuclear power plant were the same or similar for all commercial nuclear power plants and as such, could be treated generically. In this way, repetitive reviews of these environmental impacts could be avoided.

Because neither the advanced reactor technology nor the site is known, the NRC staff performed its generic analyses based on a hypothetical reactor meeting a series of performance-based assumptions termed the PPE and situated on a hypothetical site meeting a series of performance-based assumptions termed the site parameter envelope (SPE) (NRIC 2021-TN6940).

The analysis began by identifying specific types of impacts relevant to each of the 16 environmental resource areas identified by the NRC staff. Each type of impact is termed an issue. Each issue corresponds to a type of environmental impact that could potentially result from ANR construction, operation, or decommissioning. The analysis identifies 121 specific issues. Each issue is analyzed to determine whether it is possible to identify values and assumptions in the PPE and SPE that could effectively bound a meaningful generic analysis.

These issues were then assigned a significance level. The significance levels follow the definitions presented in the footnotes in Table B-1 in Appendix B of Subpart A of 10 CFR Part 51 (TN250). They are the same environmental significance levels and definitions used in the License Renewal GEIS (NRC 2013-TN2654) and in recent EISs prepared by the NRC staff for COLs and ESPs for new light-water reactors (LWRs). However, the ANR GEIS categorizes resource area issues into categories in a manner that is different from previous GEIS documents developed and used by the NRC.

For the ANR GEIS, the values and assumptions were set such that the subject matter experts (SMEs) could reach a generic conclusion of SMALL adverse impacts, which are designated as Category 1 issues (i.e., issues for which a generic analysis was possible). Issues for which the impacts are beneficial are also designated as Category 1.

After considering potential values and assumptions for the PPE and SPE for some environmental impact issues, the staff could not reach a generic conclusion. In some cases, this was due to requirements of other statutes, such as the National Historic Preservation Act (54 U.S.C. §§ 300101 et seq.; TN4157) and the Endangered Species Act (16 U.S.C. §§ 1531 et seq.; TN1010). In other cases, the wide range of potential reactor designs and potential site locations made it impossible for the staff to reach a generic conclusion in the ANR GEIS. These

Regulatory Analysis Page 1-4 issues are designated as Category 2 issues, which would require a project-specific analysis in an NRC EIS. In addition, there are two issues for which the state of the science is currently inadequate, and no generic conclusion on impacts is possible. These are designated as N/A (i.e., impacts are uncertain), which are nether Category 1 nor 2.

An applicant addressing a Category 1 issue in its Environmental Report (ER) may refer to the generic analysis in the ANR GEIS for that issue without further analysis, provided that it demonstrates that the relevant values and assumptions of the PPE and SPE used in the resource analysis are met or bounded and there is no new and significant information that would require project-specific analysis1. The applicant will have to document how the values and assumptions are met in the application package. The extent of the information necessary to demonstrate that a value or assumption is met will vary. In some cases, the demonstration may only require showing that the project design or site is bounded by a parameter value or assumption (e.g., building height). But in other cases, analysis may be required to demonstrate that a value or assumption has been met (e.g., noise levels).

If the relevant values and assumptions for a Category 1 issue are not met, the applicant would have to supply the requisite information necessary for the staff to perform a project-specific analysis. One source of guidance for applicants providing information to the staff in an ER is the latest version of RG 4.2 (NRC 2018-TN6006). The applicant may, however, be able to incorporate by reference all or part of the generic analysis provided in the ANR GEIS and focus on providing the additional project-specific information needed. Applicants addressing Category 2 issues in an ER would have to provide all the information typically needed by the staff to perform a project-specific analysis and may rely on guidance available in RG 4.2. The staff expects that applicants would rely on the generic conclusions for Category 1 issues to the extent that the conclusions can be technically supported. A variety of potential scenarios were evaluated based on combinations of resource areas for which the Category 1 issues might apply/not apply based on the type of site and design that is selected. These scenarios are presented in Section 4.3.

After accepting the license application and ER, the NRC prepares a Supplemental EIS (SEIS) to the ANR GEIS that evaluates the environmental impact of project-specific (Category 2) issues and considers any new and significant information for Category 1 and/or any other newly identified issues. The draft SEIS is made available for public comment. After considering public comments, the NRC prepares and issues a final SEIS in accordance with 10 CFR 51.91, Final environmental impact statementcontents, and 51.93, Distribution of final environmental impact statement and supplement to final environmental impact statement; news releases (10 CFR Part 51-TN250). Together, the final SEIS and the GEIS serve as the requisite NEPA analysis for the advanced nuclear reactor license environmental reviews.

When addressing Category 1 issues in SEISs, the NRC staff may likewise refer to the generic analysis in the ANR GEIS for a given issue without further analysis, provided that the relevant values and assumptions in the PPE and SPE are met and there is no new and significant information that changes the conclusions in the GEIS. Staff may also have to briefly document how the values and assumptions are met. If the relevant values and assumptions are not met, staff would have to complete a project-specific analysis in accordance with the latest version of the Environmental Standard Review Plan or related guidance (such as any relevant interim staff guidance). Staff may however be able to streamline the effort by incorporating all or a portion of 1 As used in this document, when the staff states that the project meets a value or assumption of the PPE or SPE, it should be read as to mean that the project meets or is bounded by the value or assumption.

Regulatory Analysis Page 1-5 the generic analysis in the ANR GEIS and expanding it to account for project-specific information.

Regulatory Analysis Page 2-1 2.0 IDENTIFICATION AND PRELIMINARY ANALYSIS OF ALTERNATIVE APPROACHES The analysis considers two alternatives. The following sections describe each alternative.

2.1 Alternative 1: No-Action Under Alternative 1, the No-Action alternative, the NRC would not issue an ANR GEIS and codify its results in 10 CFR Part 51 (TN250). The NRC would evaluate all environmental impacts in a project-specific EIS. Applicants for an advanced reactor license would continue to comply with the existing provisions of 10 CFR Part 51 and submit ERs that evaluated all environmental impacts on a case-by-case basis.

2.2 Alternative 2: Issue ANR GEIS and Codify Findings in 10 CFR Part 51 Under Alternative 2, the NRC would issue the ANR GEIS and would amend certain provisions of 10 CFR Part 51 related to the environmental review for advanced nuclear power plant licenses and add Table C-1. The NRC would also issue two revised guidance documents on applying the ANR GEIS findings for both applicants and the NRC staff, as discussed in Section 1.0 above.

This ability to rely on these generically determined Category 1 issues will result in a time and cost savings for both the applicant and the NRC as the EIS for an application is developed. An evaluation of the estimated benefit of reliance on Category 1 issues in the GEIS is discussed in Section 3.0.

Table C-1 of Appendix C to Subpart A of 10 CFR Part 51 summarizes the findings of the ANR GEIS, for which 121 environmental issues were analyzed. The table identifies issues as Category 1, Category 2, or Uncategorized issues, and, as identified in the Category column, most of the issues were found to be Category 1 issues. This means they are issues for which a generic analysis of environmental impacts is possible, provided that relevant values and assumptions in the PPE and SPE are met. The table also identifies mitigation measures and parameters and values that apply to each issue.

Regulatory Analysis Page 3-1 3.0 EVALUATION OF BENEFITS AND COSTS This section describes the analysis conducted to identify and evaluate the benefits and costs expected from utilization of the results of the ANR GEIS, which will be codified in the final revisions of Appendix C to Subpart A of 10 CFR Part 51 (TN250). Section 3.1 identifies the attributes that Alternative 2 is expected to affect. Section 3.2 describes the methodology used to analyze the benefits and costs associated with expected changes to the affected attributes.

Section 3.3 analyzes the implementation of Alternative 2, which will involve implementation and operational costs for industry and the NRC.

3.1 Attributes Affected by the Rulemaking This section identifies the factors within the public and private sectors that the rulemaking is expected to affect. These factors are classified as attributes using the list of potential attributes provided in Chapter 5 of the NRCs Regulatory Analysis Technical Evaluation Handbook (NRC 2020-TN6806). Affected attributes include the following:

Industry Implementation. Industry applicants will incur costs associated with reviewing the proposed rule and implementing the final rule. Potential applicants will review and likely develop comments to submit as part of the rulemaking process. This requires staff time and resources for reading, assessing, and developing comments. In addition, potential applicants will incur costs as they evaluate how to implement the GEIS in generating an ANR application using the provisions of the proposed rule and the eventual final rule. Such internal procedures include prescribing how determinations for Category 1 versus Category 2 designations will be made and how the assessment process will be documented in the application.

Industry Operation. As a result of the generic analysis of environmental issues, applicants will recognize a savings to prepare the ER by relying on the analysis in the GEIS for Category 1 issues and the ability to incorporate by reference the findings in the ANR GEIS, rather than analyzing the impacts in their ER. Applicants will incur costs for Category 1 issues associated with demonstrating their project is bounded by the analysis in the GEIS.

However, these costs are assumed to be required as part of the characterization of the affected environment under existing NEPA guidance and approaches for COL and ESP reviews. No incremental costs would be incurred by addressing Category 2 issues in project-specific analyses and presenting the information in the ER because these costs would be incurred if an applicant submitted an ER with or without relying on the GEIS.

NRC Implementation. The NRC will incur costs related to implementing the provisions of the proposed rule. Some of these costs have already occurred and do not factor into this regulatory analysis. Future costs of implementation include completion and publication of the Draft ANR GEIS, resolving public comments on the GEIS, completion and publication of this regulatory analysis and the rulemaking package for public review and review by the Office of Management and Budget (OMB) and Office of the Federal Register (OFR),

including the processing of formal review comments. Future implementation costs also include those associated with completion and publication of the final rule and supporting documents.

NRC Operations. Similar to the industry operation, the NRC will recognize cost savings by relying on the generic analysis of Category 1 issues. As part of the characterization of the affected environment, the NRC will need to verify that the project is bounded by the ANR GEIS. Category 2 issues will need to be analyzed in the SEIS. However, the project-

Regulatory Analysis Page 3-2 specific analysis of Category 1 issues for the SEIS referencing the GEIS will cost less than the analysis for an EIS that does not reference the GEIS.

Improvements in Process. Category 1 and 2 issues have been added to Table C-1 of 10 CFR Part 51, which will improve the quality of the information provided to the NRC by focusing on issues most relevant to specific applications and facilitate advanced reactor environmental reviews. This information is necessary for the NRC to ensure compliance with Federal environmental statutes and regulations and to evaluate the potential environmental effects of continued nuclear power plant operations. Additionally, the applicants research for new and significant information pertaining to Category 1 issues will improve the knowledge base for these issues.

Improvements in Efficiency for the Applicant and Improvements in Efficiency for the NRC.

The ANR GEIS and the issues and findings in Table C-1 will improve the efficiency of the environmental review. Improving the clarity and efficiency of the regulatory provisions reduces the cost to industry to prepare environmental reports for advanced reactor applications and permits the NRC to focus resources on project-specific issues of importance (i.e., project-specific analyses), which also reduces the cost to the NRC.

3.2 Analytical Methodology This section describes the methodology used to analyze the incremental benefits and costs associated with Alternative 2. The benefits of Alternative 2 include any desirable changes in affected attributes (e.g., savings) while the costs include any adverse changes in affected attributes (e.g., costs).

The analysis evaluates the following attributes affected by Alternative 2 on a quantitative basis:

industry implementation

industry operation

NRC implementation

NRC operation.

The analysis evaluates improvements in process affected by Alternative 2 on a qualitative basis due to the difficulty and uncertainty involved in quantifying the benefits and impacts to this attribute.

3.2.1 Baseline for the Analysis The analysis measures the incremental impacts of Alternative 2 relative to a baseline (Alternative 1, the No-Action alternative).

3.2.2 Affected Applicants Advanced reactor applicants for an NRC license can refer to Table C-1 in 10 CFR Part 51 and the GEIS to streamline the preparation of their ER. The NRC estimates that approximately eight advanced reactor applications will be received over the 10-year period before the ANR GEIS will be updated. This estimate is based on letters of intent received from potential applicants; the NRC anticipates receiving one application per year in 8 years of the 10-year period from 2024 to 2034. Consideration of the potential ANR applications under the proposed rule is discussed in Sections 3.3.2 and 3.3.4.

Regulatory Analysis Page 3-3 The analysis period for this regulatory analysis covers that period between 2024 and 2034 for the benefits and the costs of implementation. Thus the costs and benefits are analyzed for that period based on the guidance provided in NUREG-0058 (NRC 2020-TN6806). Results are presented in undiscounted terms and using financial discounting with discount rates of 3 and 7 percent to reflect the time value of money. All dollar amounts are presented in 2021 constant dollars.

3.3 Analysis of Alternative 2 Implementation The NRC evaluated each provision contained in Alternative 2 relative to the applicable baseline (Alternative 1, the No-Action alternative). Based on this analysis, the NRC developed equations to estimate the benefits and costs using available data, augmented by assumptions when necessary, and guidance contained in NUREG-0058 (NRC 2020-TN6806).

The NRC labor rate is the weighted average of the General Assumptions NRC staff labor rate and the NRC contractor labor rate. NRC contractors may perform a significant

Effective year of proposed rule =

portion of the analyses addressed by the proposed 2024 rule. For the regulatory analysis, data about the

NRC Composite rate (weighted) =

relative effort expended on previous COL and ESP $168.00 reviews by NRC staff and NRC contractors were collected and summarized in terms of costs and - NRC staff rate = $137.00/hour

- NRC contractor staff rate =

hours. The NRC staff labor rate was given as $137

$190.00/hour per hour per internal agency guidance. The NRC contractor labor rate was estimated based on recent

Industry staff rate = $163.50/hour review costs billed to NRC divided by the hours billed

The analysis presents all benefits and equates to approximately $190 per hour inclusive and costs in constant 2021 of all labor costs. The weighted average of these two dollars. For net present value rates was estimated based on the relative number of calculations, the analysis hours per most typical review experience. This rate discounts to the first year of equates to $168 per hour and represents the NRC incurred costs or savings (i.e.,

average labor rate used in the analysis. 2022).

The industry rate was estimated to be the average between the NRC staff rate and the NRC contractor rate.

The following sections address the implementation and operational costs to industry and the NRC associated with issuing the ANR GEIS and codifying findings in 10 CFR Part 51 to accelerate and streamline the process of conducting environmental reviews related to the licensing of advanced reactors.

3.3.1 Industry Implementation Under Alternative 2, industry applicants would be expected to review and comment on the proposed rule and take actions to implement the provisions of the rule for environmental reviews triggered by the expected applications under this rule. The NRC staff assumed that these implementation activities would apply to the eight applicants expected to submit applications under this rule during the 2024-2034 period. Further, the staff assumed each applicant would devote $50,000 to these preparatory activities, allocated somewhat evenly between rule reviewing and commenting on the proposed rule and implementing the provisions of the eventual final rule. The annual costs are summarized in Table 3.1. As shown in the table, it is

Regulatory Analysis Page 3-4 assumed that preparatory activities for the eight applications are split evenly between 2022 and 2023.

Table 3.1 Annual Industry Implementation Costs (2021 Constant Dollars)

Year Undiscounted 7% NPV 3% NPV 2022 ($200,000) ($186,916) ($194,175) 2023 ($200,000) ($174,688) ($188,519) 2024 $0 $0 $0 2025 $0 $0 $0 2026 $0 $0 $0 2027 $0 $0 $0 2028 $0 $0 $0 2029 $0 $0 $0 2030 $0 $0 $0 2031 $0 $0 $0 2032 $0 $0 $0 2033 $0 $0 $0 2034 $0 $0 $0 Total Costs ($400,000) ($361,604) ($382,694) 3.3.2 Industry Operations Alternative 2 evaluates issues that each applicant must assess and include in their application to the NRC, which will be documented in Table C-1. The analysis specifies each issue that is evaluated quantitatively. For each Table C-1 issue, the regulatory analysis lists the assumption(s) and equation(s) used to estimate the benefits and/or costs to industry.

General assumptions are listed below (each Table C-1 benefit and cost described below applies to all applicants except where noted):

Any applicant submitting an advanced reactor application in the period of the proposed rule will incur the operations costs or recognize the operations savings in the same year as the application submittal.

Applicant labor savings are assumed to scale based on the recent COL and ESP review experience of NRC staff and contractors, and equate to 1.75 times the labor hours required by NRC contractor staff who are reviewing and confirming the original analysis done by the applicant. The 1.75 factor is assumed to represent the additional effort on the part of the applicant to prepare the application from scratch. This factor is assumed to apply regardless of the complexity of the ANR application.

Savings enabled by the proposed rule occur when a generic impact analysis is determined to be an adequate analysis approach compared to standard impact analysis practices that are required by current guidance for new reactor reviews. The reduced labor effort required with generic analysis compared to previous (baseline) approaches is the savings.

Savings estimates are analyzed for environmental reviews that would be considering ANR applications focused on facilities incorporating designs where multiple nuclear units would be installed in a single facility. These types of facilities most closely align with the previous review experience of the NRC and reflect the most recent ANR review experience associated with the Clinch River ESP review. Thus, the savings reported for the most likely

Regulatory Analysis Page 3-5 review experience are likely to be upper bound estimates for the potential range of applications that may be expected.

Many potential ANR applications may use innovative technology, a smaller reactor size, or a single small unit. In these cases, several environmental resources may not be affected, and the resulting savings would not be realized, because unaffected resources would not be part of the savings baseline.

A Category 1 issue is assumed to be analyzed based on the generic analysis provided in the ANR GEIS and would not require analytical effort apart from making the determination that generic analysis applies. It is assumed that applicant will assess new and significant information for the determination of Category 1 applicability as part of the typical characterization of the affected environment in the ER; therefore, no additional costs are incurred to make this determination.

A Category 2 issue is assumed to require a level of effort similar to that required without a GEIS, and thus, would not result in savings or added costs for applicant staff.

Table 3.2 presents the issue-by-issue cost savings impact attributable to the rule, which are enabled by using the ANR GEIS to provide the generic impact conclusions for the Category 1 issues, thereby avoiding the cost to industry of in-depth assessment for those issues. Table A-1 in Appendix A provides the detailed financial results that feed into this summary.

Regulatory Analysis Page 3-6 Table 3.2 2024-2034 Financial Impact of Industry Operations under the Proposed Rule by Issue (2021 Constant Dollars)

Net Savings (Costs) per Total Net Savings (Costs) - Rule Application Applicant Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue Number Industry Operations Category 1 Construction - Onsite Land 1 $163.50 26 $4,251 $34,008 $20,043 $26,911 Use Category 1 Construction - Offsite Land 2 $163.50 184 $30,084 $240,672 $141,844 $190,446 Use Category 1 Construction - Impacts on 3 $163.50 25 $4,088 $32,700 $19,272 $25,876 Prime and Unique Farmland Category 1 Construction - Coastal 4 Zone and Compliance with The $163.50 14 $2,289 $18,312 $10,792 $14,490 Coastal Zone Management Act Category 1 Operations - Onsite Land 5 $163.50 3 $491 $3,924 $2,313 $3,105 Use Category 1 Operations - Offsite Land 6 $163.50 25 $4,088 $32,700 $19,272 $25,876 Use Category 1 Construction - Visual 7 $163.50 11 $1,799 $14,388 $8,480 $11,385 Impacts in Site and Vicinity Category 1 Construction - Visual 8 $163.50 11 $1,799 $14,388 $8,480 $11,385 Impacts from Transmission Lines Category 1 Operations - Visual 9 $163.50 23 $3,761 $30,084 $17,730 $23,806 Impacts During Operations Category 1 Construction - Emissions of 10 Criteria Pollutants and Dust During $163.50 33 $5,396 $43,164 $25,439 $34,156 Construction Category 1 Construction - Greenhouse 11 $163.50 76 $12,426 $99,408 $58,588 $78,662 Gas Emissions During Construction Category 1 Operations - Emissions of 12 Criteria and Hazardous Air Pollutants $163.50 50 $8,175 $65,400 $38,544 $51,752 During Operation Category 1 Operations - Greenhouse 13 $163.50 48 $7,848 $62,784 $37,003 $49,681 Gas Emissions During Operation 14 Category 1 Operations - Cooling $163.50 11 $1,799 $14,388 $8,480 $11,385

Regulatory Analysis Page 3-7 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application Applicant Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue Number Industry Operations System Emissions Category 1 Operations - Emissions of 15 Ozone and Nitrogen Oxides During $163.50 6 $981 $7,848 $4,625 $6,210 Transmission Line Operation Category 1 Construction - Surface 16 Water Use Conflicts During $163.50 17 $2,780 $22,236 $13,105 $17,596 Construction Category 1 Construction -

17 Groundwater Use Conflicts Due to $163.50 117 $19,130 $153,036 $90,194 $121,099 Excavation Dewatering Category 1 Construction -

Groundwater Use Conflicts Due to 18 $163.50 97 $15,860 $126,876 $74,776 $100,398 Construction-Related Groundwater Withdrawals Category 1 Construction - Water 19 Quality Degradation Due to $163.50 17 $2,780 $22,236 $13,105 $17,596 Construction-Related Discharges Category 1 Construction - Water 20 Quality Degradation Due to Inadvertent $163.50 17 $2,780 $22,236 $13,105 $17,596 Spills During Construction Category 1 Construction - Water 21 Quality Degradation Due to $163.50 39 $6,377 $51,012 $30,065 $40,366 Groundwater Withdrawal Category 1 Construction - Water 22 Quality Degradation Due to Offshore or $163.50 67 $10,955 $87,636 $51,650 $69,347 In-Water Construction Activities Category 1 Construction - Water Use 23 Conflict Due to Plant Municipal Water $163.50 67 $10,955 $87,636 $51,650 $69,347 Demand Category 1 Construction - Degradation 24 of Water Quality from Plant Effluent $163.50 150 $24,525 $196,200 $115,633 $155,255 Discharges to Municipal Systems

Regulatory Analysis Page 3-8 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application Applicant Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue Number Industry Operations Category 1 Operations - Surface Water Use Conflicts During Operation Due to 25 $163.50 109 $17,822 $142,572 $84,027 $112,818 Water Withdrawal from Flowing Waterbodies Category 1 Operations - Surface Water Use Conflicts During Operation Due to 26 $163.50 39 $6,377 $51,012 $30,065 $40,366 Water Withdrawal from Non-Flowing Waterbodies Category 1 Operations - Groundwater 27 Use Conflicts Due to Building $163.50 29 $4,742 $37,932 $22,356 $30,016 Foundation Dewatering Category 1 Operations - Groundwater 28 Use Conflicts Due to Groundwater $163.50 57 $9,320 $74,556 $43,941 $58,997 Withdrawals for Plant Uses Category 1 Operations - Surface Water Quality Degradation Due to Physical 29 $163.50 117 $19,130 $153,036 $90,194 $121,099 Effects from Operation of Intake and Discharge Structures Category 1 Operations - Surface Water Quality Degradation Due to Changes in 30 $163.50 194 $31,719 $253,752 $149,552 $200,796 Salinity Gradients Resulting from Withdrawals Category 1 Operations - Groundwater 31 Quality Degradation Due to Plant $163.50 57 $9,320 $74,556 $43,941 $58,997 Discharges Category 1 Operations - Water Quality 32 Degradation Due to Inadvertent Spills $163.50 16 $2,616 $20,928 $12,334 $16,560 and Leaks During Operation Category 1 Operations - Water Quality 33 Degradation Due to Groundwater $163.50 43 $7,031 $56,244 $33,148 $44,506 Withdrawals Category 1 Operations - Water Use 34 Conflict from Plant Municipal Water $163.50 16 $2,616 $20,928 $12,334 $16,560 Demand

Regulatory Analysis Page 3-9 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application Applicant Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue Number Industry Operations Category 1 Operations - Degradation 35 of Water Quality from Plant Effluent $163.50 16 $2,616 $20,928 $12,334 $16,560 Discharges to Municipal Systems Category 1 Construction - Permanent and Temporary Loss, Conversion, 36 $163.50 168 $27,468 $219,744 $129,509 $173,885 Fragmentation, and Degradation of Habitats Category 1 Construction - Permanent 37 and Temporary Loss and Degradation $163.50 168 $27,468 $219,744 $129,509 $173,885 of Wetlands Category 1 Construction - Effects of 38 $163.50 60 $9,810 $78,480 $46,253 $62,102 Building Noise on Wildlife Category 1 Construction - Effects of 39 $163.50 50 $8,175 $65,400 $38,544 $51,752 Vehicular Collisions on Wildlife Category 1 Construction - Bird 40 Collisions and Injury from Structures $163.50 60 $9,810 $78,480 $46,253 $62,102 and Transmission Lines Category 1 Construction - Important 41 Species and Habitats - Other $163.50 84 $13,734 $109,872 $64,755 $86,943 Important Species and Habitats Category 1 Operations - Permanent 42 and Temporary Loss or Disturbance of $163.50 19 $3,107 $24,852 $14,647 $19,666 Habitats Category 1 Operations - Effects of 43 $163.50 11 $1,799 $14,388 $8,480 $11,385 Operational Noise on Wildlife Category 1 Operations - Effects of 44 $163.50 9 $1,472 $11,772 $6,938 $9,315 Vehicular Collisions on Wildlife Category 1 Construction - Exposure of 45 $163.50 38 $6,213 $49,704 $29,294 $39,331 Terrestrial Organisms to Radionuclides Category 1 Operations - Cooling Tower 46 $163.50 37 $6,050 $48,396 $28,523 $38,296 Operational Impacts on Vegetation

Regulatory Analysis Page 3-10 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application Applicant Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue Number Industry Operations Category 1 Operations - Bird Collisions 47 and Injury from Structures and $163.50 19 $3,107 $24,852 $14,647 $19,666 Transmission Lines Category 1 Operations - Bird 48 Electrocutions from Transmission $163.50 19 $3,107 $24,852 $14,647 $19,666 Lines Category 1 Operations - Water Use 49 $163.50 83 $13,571 $108,564 $63,984 $85,907 Conflicts with Terrestrial Resources Category 1 Operations - Effects of 50 Transmission Line right-of-way (ROW) $163.50 23 $3,761 $30,084 $17,730 $23,806 Management on Terrestrial Resources Category 1 Operations -Effects of 51 Electromagnetic Fields on Flora and $163.50 4 $654 $5,232 $3,084 $4,140 Fauna Category 1 Operations - Important 52 Species and Habitats - Other $163.50 37 $6,050 $48,396 $28,523 $38,296 Important Species and Habitats Category 1 Construction - Runoff and 53 Sedimentation from Construction $163.50 128 $20,928 $167,424 $98,674 $132,484 Areas Category 1 Construction - Dredging 54 and Filling Aquatic Habitats to Build $163.50 128 $20,928 $167,424 $98,674 $132,484 Intake and Discharge Structures Category 1 Construction - Building Transmission Lines, Pipelines, and 55 $163.50 128 $20,928 $167,424 $98,674 $132,484 Access Roads Across Surface Waterbodies Category 1 Operations - Important 56 Species and Habitats - Other $163.50 128 $20,928 $167,424 $98,674 $132,484 Important Species and Habitats Category 1 Operations - Stormwater 57 $163.50 20 $3,270 $26,160 $15,418 $20,701 Runoff

Regulatory Analysis Page 3-11 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application Applicant Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue Number Industry Operations Category 1 Operations - Exposure of 58 $163.50 38 $6,213 $49,704 $29,294 $39,331 Aquatic Organisms to Radionuclides Category 1 Operations - Effects of 59 $163.50 20 $3,270 $26,160 $15,418 $20,701 Refurbishment on Aquatic Biota Category 1 Operations - Effects of 60 Maintenance Dredging on Aquatic $163.50 97 $15,860 $126,876 $74,776 $100,398 Biota Category 1 Operations - Impacts of 61 Transmission Line ROW Management $163.50 48 $7,848 $62,784 $37,003 $49,681 on Aquatic Resources Category 1 Operations - Impingement 62 $163.50 145 $23,708 $189,660 $111,779 $150,079 and Entrainment of Aquatic Organisms Category 1 Operations - Water Use 63 $163.50 48 $7,848 $62,784 $37,003 $49,681 Conflicts with Aquatic Resources Category 1 Operations - Important 64 Species and Habitats - Other $163.50 145 $23,708 $189,660 $111,779 $150,079 Important Species and Habitats Category 1 Construction - Radiological 65 $163.50 117 $19,130 $153,036 $90,194 $121,099 Dose to Construction Workers Category 1 Operations - Occupational 66 $163.50 38 $6,213 $49,704 $29,294 $39,331 Doses to Workers Category 1 Operations - Maximally 67 $163.50 38 $6,213 $49,704 $29,294 $39,331 Exposed Individual Annual Doses Category 1 Operations - Total 68 $163.50 42 $6,867 $54,936 $32,377 $43,471 Population Annual Doses Category 1 Operations - Nonhuman 69 $163.50 42 $6,867 $54,936 $32,377 $43,471 Biota Doses Category 1 Construction - Building 70 Impacts of Chemical, Biological, and $163.50 52 $8,502 $68,016 $40,086 $53,822 Physical Nonradiological Hazards Category 1 Operations - Operation 71 Impacts of Chemical, Biological, and $163.50 35 $5,723 $45,780 $26,981 $36,226 Physical Nonradiological Hazards

Regulatory Analysis Page 3-12 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application Applicant Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue Number Industry Operations Category 1 Construction -

72 $163.50 23 $3,761 $30,084 $17,730 $23,806 Construction-Related Noise Category 1 Operations - Operation-73 $163.50 14 $2,289 $18,312 $10,792 $14,490 Related Noise Category 1 Operations - Low-Level 74 $163.50 232 $37,932 $303,456 $178,846 $240,127 Radioactive Waste Category 1 Operations - Onsite Spent 75 $163.50 232 $37,932 $303,456 $178,846 $240,127 Nuclear Fuel Management 76 Category 1 Operations - Mixed Waste $163.50 232 $37,932 $303,456 $178,846 $240,127 Category 1 Construction - Construction 77 $163.50 38 $6,213 $49,704 $29,294 $39,331 Nonradiological Waste Category 1 Operations - Operation 78 $163.50 25 $4,088 $32,700 $19,272 $25,876 Nonradiological Waste Category 1 Operations - Design Basis 79 Accidents Involving Radiological $163.50 172 $28,122 $224,976 $132,593 $178,025 Releases Category 1 Operations - Accidents 80 Involving Releases of Hazardous $163.50 103 $16,841 $134,724 $79,402 $106,608 Chemicals Category 1 Operations - Severe 81 $163.50 69 $11,282 $90,252 $53,191 $71,417 Accident Mitigation Design Alternatives Category 1 Operations - Acts of 82 $163.50 69 $11,282 $90,252 $53,191 $71,417 Terrorism Category 1 Construction - Community 83 $163.50 74 $12,099 $96,792 $57,046 $76,592 Services and Infrastructure Category 1 Construction -

84 $163.50 147 $24,035 $192,276 $113,321 $152,149 Transportation Systems and Traffic Category 1 Construction - Economic 85 $163.50 74 $12,099 $96,792 $57,046 $76,592 Impacts Category 1 Construction - Tax 86 $163.50 42 $6,867 $54,936 $32,377 $43,471 Revenue Impacts

Regulatory Analysis Page 3-13 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application Applicant Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue Number Industry Operations Category 1 Operations - Community 87 $163.50 50 $8,175 $65,400 $38,544 $51,752 Services and Infrastructure Category 1 Operations - Transportation 88 $163.50 25 $4,088 $32,700 $19,272 $25,876 Systems and Traffic Category 1 Operations - Economic 89 $163.50 50 $8,175 $65,400 $38,544 $51,752 Impacts Category 1 Operations - Tax Revenue 90 $163.50 98 $16,023 $128,184 $75,547 $101,433 Impacts Category 1 Operations - Uranium 91 $163.50 39 $6,377 $51,012 $30,065 $40,366 Recovery Category 1 Operations - Uranium 92 $163.50 39 $6,377 $51,012 $30,065 $40,366 Conversion 93 Category 1 Operations - Enrichment $163.50 39 $6,377 $51,012 $30,065 $40,366 Category 1 Operations - Fuel 94 $163.50 39 $6,377 $51,012 $30,065 $40,366 Fabrication(a) 95 Category 1 Operations - Reprocessing $163.50 39 $6,377 $51,012 $30,065 $40,366 Category 1 Operations - Storage and 96 $163.50 39 $6,377 $51,012 $30,065 $40,366 Disposal of Radiological Wastes Category 1 Operations - Transportation 97 $163.50 78 $12,753 $102,024 $60,129 $80,732 of Unirradiated ANR Fuel Category 1 Operations - Transportation 98 $163.50 78 $12,753 $102,024 $60,129 $80,732 of Radioactive Waste from ANRs Category 1 Operations - Transportation 99 $163.50 155 $25,343 $202,740 $119,488 $160,430 of Irradiated Fuel from ANRs 100 Decommissioning $163.50 81 $13,244 $105,948 $62,442 $83,837 Totals 6,548 $1,070,598 $8,564,784 $5,047,780 $6,777,377 (a) Fuel fabrication impacts for metal fuel and liquid fueled molten salt are not included in the staffs generic analysis.

Regulatory Analysis Page 3-14 3.3.3 NRC Implementation The NRC will incur costs to develop the ANR GEIS and all associated regulatory guidance to staff and applicants. The NRC recorded actual and planned costs required to bring the proposed rule to fruition, including the cost of the following:

Generation of the draft Proposed Rule Package (ANR GEIS, Federal Register Notice [FRN],

Regulatory Analysis, OMB Statement, revision of RG 4.2, and creation of COL-ISG-030 Environmental Considerations for Advanced Nuclear Reactor Applications that Reference the Generic Environmental Impact Statement (NUREG-2249)). These costs have already occurred and are not considered in the regulatory analysis. Only future or remaining implementation costs are considered in this analysis.

Submittal of the draft Proposed Rule Package to the Commission. Public comment period.

Generation of the Final Rule Package (ANR GEIS, FRN, Regulatory Analysis, OMB Statement, revision of RG 4.2, new COL-ISG-030) and its submittal to the Commission.

Processing and addressing OMB and OFR formal review comments.

Consolidation of the new GEIS-related Staff Guidance, COL-ISG-030 Environmental Considerations for Advanced Nuclear Reactor Applications that Reference the Generic Environmental Impact Statement (NUREG-2249) into more durable guidance in NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants, as part of the greater 10 CFR Part 51 rulemaking.

Table 3.3 lists the NRC costs of rule implementation.

Table 3.3 NRC Costs of Rule Implementation (2021 Constant Dollars) 7 Percent 3 Percent Year Undiscounted Discounting Discounting 2022 ($1,138,613) ($1,064,124) ($1,105,449) 2023 ($896,625) ($783,147) ($845,155) 2024 ($238,988) ($195,085) ($218,707) 2025 ($39,730) ($30,310) ($35,300) 2026 $0 $0 $0 2027 $0 $0 $0 2028 $0 $0 $0 2029 $0 $0 $0 2030 $0 $0 $0 2031 $0 $0 $0 2032 $0 $0 $0 2033 $0 $0 $0 2034 $0 $0 $0 Total ($2,313,955) ($2,072,666) ($2,204,611) 3.3.4 NRC Operations Alternative 2 activities affect the environmental review time for each ANR licensing application.

The Alternative 2 analysis included each environmental issue presented in Table C-1 of Appendix C to Subpart A of 10 CFR Part 51. For each of these environmental issues, the

Regulatory Analysis Page 3-15 analysis lists the assumption(s) and equation(s) used to estimate the value (benefit/saving) and/or impact (cost) to the NRC. Each of these issues was evaluated quantitatively and results are presented in Table 3.4 below. General assumptions are as follows:

The NRC will recognize the savings resulting from the proposed rule changes in the 24 months after the NRC receives each application. The NRC is assumed to recognize approximately half of the savings in the same year as the application submittal and the other half in the year following the application submittal.

Each cost and saving assumption associated with the proposed rule changes is based on extensive NRC staff experience in the review of COL and ESP applications.

Savings estimates are analyzed for environmental reviews that would be considering ANR applications focused on facilities incorporating designs where multiple nuclear units would be installed in a single facility. Thus, the savings reported are upper bound estimates. For many potential ANR applications, the reactor size may be somewhat smaller or may use only a single small unit. In these cases, several environmental resources may not be affected, and the resulting savings would not be realized, because unaffected resources would not be part of the savings baseline.

A Category 1 issue is assumed to be analyzed based on the generic analysis provided in the ANR GEIS and would not require analytical effort apart from making the determination that generic analysis applies. It is assumed that NRC staff will assess new and significant information for the determination of Category 1 applicability as part of the typical characterization of the affected environment of the EIS.

A typical Category 2 issue is assumed to require a level of effort similar to the level of effort required without the GEIS, and thus, would not result in savings or added costs for applicant staff.

Table 3.4 presents the issue-by-issue cost savings impact attributable to the rule, which are enabled by using the ANR GEIS to provide the generic impact conclusions for the Category 1 issues, thereby avoiding the cost to the NRC of in-depth review for those issues. Table A-1 in Appendix AA provides the detailed financial results that feed into this summary.

Regulatory Analysis Page 3-16 Table 3.4 2024-2034 Financial Impact of NRC Operation under the Proposed Rule by Issue (2021 Constant Dollars)

Net Savings (Costs) per Total Net Savings (Costs) - Rule Application NRC Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue NRC Operations Number 1 Category 1 Construction - Onsite Land Use $168 82 $13,776 $110,208 $60,703 $84,668 2 Category 1 Construction - Offsite Land Use $168 135 $22,680 $181,440 $99,939 $139,393 Category 1 Construction - Impacts on Prime 3 $168 23 $3,864 $30,912 $17,027 $23,748 and Unique Farmland Category 1 Construction - Coastal Zone and 4 Compliance with The Coastal Zone $168 9 $1,512 $12,096 $6,663 $9,293 Management Act 5 Category 1 Operations - Onsite Land Use $168 24 $4,032 $32,256 $17,767 $24,781 6 Category 1 Operations - Offsite Land Use $168 28 $4,704 $37,632 $20,728 $28,911 Category 1 Construction - Visual Impacts in 7 $168 27 $4,536 $36,288 $19,988 $27,879 Site and Vicinity Category 1 Construction - Visual Impacts from 8 $168 9 $1,512 $12,096 $6,663 $9,293 Transmission Lines Category 1 Operations - Visual Impacts 9 $168 20 $3,360 $26,880 $14,806 $20,651 During Operations Category 1 Construction - Emissions of 10 Criteria Pollutants and Dust During $168 154 $25,872 $206,976 $114,004 $159,011 Construction Category 1 Construction - Greenhouse Gas 11 $168 134 $22,512 $180,096 $99,198 $138,360 Emissions During Construction Category 1 Operations - Emissions of Criteria 12 and Hazardous Air Pollutants During $168 163 $27,384 $219,072 $120,667 $168,304 Operation Category 1 Operations - Greenhouse Gas 13 $168 88 $14,784 $118,272 $65,145 $90,864 Emissions During Operation Category 1 Operations - Cooling System 14 $168 18 $3,024 $24,192 $13,325 $18,586 Emissions

Regulatory Analysis Page 3-17 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application NRC Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue NRC Operations Number Category 1 Operations - Emissions of Ozone 15 and Nitrogen Oxides During Transmission $168 15 $2,520 $20,160 $11,104 $15,488 Line Operation Category 1 Construction - Surface Water Use 16 $168 60 $10,080 $80,640 $44,417 $61,952 Conflicts During Construction Category 1 Construction - Groundwater Use 17 $168 123 $20,664 $165,312 $91,055 $127,003 Conflicts Due to Excavation Dewatering Category 1 Construction - Groundwater Use 18 Conflicts Due to Construction-Related $168 115 $19,320 $154,560 $85,133 $118,742 Groundwater Withdrawals Category 1 Construction - Water Quality 19 Degradation Due to Construction-Related $168 62 $10,416 $83,328 $45,898 $64,018 Discharges Category 1 Construction - Water Quality 20 Degradation Due to Inadvertent Spills During $168 24 $4,032 $32,256 $17,767 $24,781 Construction Category 1 Construction - Water Quality 21 $168 73 $12,264 $98,112 $54,041 $75,375 Degradation Due to Groundwater Withdrawal Category 1 Construction - Water Quality 22 Degradation Due to Offshore or In-Water $168 56 $9,408 $75,264 $41,456 $57,822 Construction Activities Category 1 Construction - Water Use Conflict 23 $168 49 $8,232 $65,856 $36,274 $50,595 Due to Plant Municipal Water Demand Category 1 Construction - Degradation of 24 Water Quality from Plant Effluent Discharges $168 97 $16,296 $130,368 $71,808 $100,156 to Municipal Systems Category 1 Operations - Surface Water Use 25 Conflicts During Operation Due to Water $168 152 $25,536 $204,288 $112,523 $156,946 Withdrawal from Flowing Waterbodies Category 1 Operations - Surface Water Use 26 Conflicts During Operation Due to Water $168 113 $18,984 $151,872 $83,652 $116,677 Withdrawal from Non-Flowing Waterbodies

Regulatory Analysis Page 3-18 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application NRC Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue NRC Operations Number Category 1 Operations - Groundwater Use 27 Conflicts Due to Building Foundation $168 57 $9,576 $76,608 $42,196 $58,855 Dewatering Category 1 Operations - Groundwater Use 28 Conflicts Due to Groundwater Withdrawals for $168 124 $20,832 $166,656 $91,795 $128,035 Plant Uses Category 1 Operations - Surface Water Quality Degradation Due to Physical Effects 29 $168 95 $15,960 $127,680 $70,327 $98,091 from Operation of Intake and Discharge Structures Category 1 Operations - Surface Water 30 Quality Degradation Due to Changes in $168 158 $26,544 $212,352 $116,965 $163,141 Salinity Gradients Resulting from Withdrawals Category 1 Operations - Groundwater Quality 31 $168 97 $16,296 $130,368 $71,808 $100,156 Degradation Due to Plant Discharges Category 1 Operations - Water Quality 32 Degradation Due to Inadvertent Spills and $168 22 $3,696 $29,568 $16,286 $22,716 Leaks During Operation Category 1 Operations - Water Quality 33 $168 116 $19,488 $155,904 $85,873 $119,775 Degradation Due to Groundwater Withdrawals Category 1 Operations - Water Use Conflict 34 $168 26 $4,368 $34,944 $19,247 $26,846 from Plant Municipal Water Demand Category 1 Operations - Degradation of Water 35 Quality from Plant Effluent Discharges to $168 26 $4,368 $34,944 $19,247 $26,846 Municipal Systems Category 1 Construction - Permanent and 36 Temporary Loss, Conversion, Fragmentation, $168 133 $22,344 $178,752 $98,458 $137,328 and Degradation of Habitats Category 1 Construction - Permanent and 37 $168 133 $22,344 $178,752 $98,458 $137,328 Temporary Loss and Degradation of Wetlands Category 1 Construction - Effects of Building 38 $168 41 $6,888 $55,104 $30,352 $42,334 Noise on Wildlife

Regulatory Analysis Page 3-19 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application NRC Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue NRC Operations Number Category 1 Construction - Effects of Vehicular 39 $168 36 $6,048 $48,384 $26,650 $37,171 Collisions on Wildlife Category 1 Construction - Bird Collisions and 40 $168 40 $6,720 $53,760 $29,611 $41,302 Injury from Structures and Transmission Lines Category 1 Construction - Important Species 41 and Habitats - Other Important Species and $168 70 $11,760 $94,080 $51,820 $72,278 Habitats Category 1 Operations - Permanent and 42 $168 13 $2,184 $17,472 $9,624 $13,423 Temporary Loss or Disturbance of Habitats Category 1 Operations - Effects of 43 $168 8 $1,344 $10,752 $5,922 $8,260 Operational Noise on Wildlife Category 1 Operations - Effects of Vehicular 44 $168 7 $1,176 $9,408 $5,182 $7,228 Collisions on Wildlife Category 1 Construction - Exposure of 45 $168 28 $4,704 $37,632 $20,728 $28,911 Terrestrial Organisms to Radionuclides Category 1 Operations - Cooling Tower 46 $168 30 $5,040 $40,320 $22,209 $30,976 Operational Impacts on Vegetation Category 1 Operations - Bird Collisions and 47 $168 13 $2,184 $17,472 $9,624 $13,423 Injury from Structures and Transmission Lines Category 1 Operations - Bird Electrocutions 48 $168 13 $2,184 $17,472 $9,624 $13,423 from Transmission Lines Category 1 Operations - Water Use Conflicts 49 $168 50 $8,400 $67,200 $37,014 $51,627 with Terrestrial Resources Category 1 Operations - Effects of 50 Transmission Line ROW Management on $168 18 $3,024 $24,192 $13,325 $18,586 Terrestrial Resources Category 1 Operations -Effects of 51 $168 5 $840 $6,720 $3,701 $5,163 Electromagnetic Fields on Flora and Fauna Category 1 Operations - Important Species 52 and Habitats - Other Important Species and $168 30 $5,040 $40,320 $22,209 $30,976 Habitats

Regulatory Analysis Page 3-20 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application NRC Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue NRC Operations Number Category 1 Construction - Runoff and 53 $168 124 $20,832 $166,656 $91,795 $128,035 Sedimentation from Construction Areas Category 1 Construction - Dredging and 54 Filling Aquatic Habitats to Build Intake and $168 123 $20,664 $165,312 $91,055 $127,003 Discharge Structures Category 1 Construction - Building 55 Transmission Lines, Pipelines, and Access $168 105 $17,640 $141,120 $77,730 $108,417 Roads Across Surface Waterbodies Category 1 Operations - Important Species 56 and Habitats - Other Important Species and $168 172 $28,896 $231,168 $127,329 $177,597 Habitats 57 Category 1 Operations - Stormwater Runoff $168 28 $4,704 $37,632 $20,728 $28,911 Category 1 Operations - Exposure of Aquatic 58 $168 28 $4,704 $37,632 $20,728 $28,911 Organisms to Radionuclides Category 1 Operations - Effects of 59 $168 28 $4,704 $37,632 $20,728 $28,911 Refurbishment on Aquatic Biota Category 1 Operations - Effects of 60 $168 72 $12,096 $96,768 $53,301 $74,343 Maintenance Dredging on Aquatic Biota Category 1 Operations - Impacts of 61 Transmission Line ROW Management on $168 44 $7,392 $59,136 $32,573 $45,432 Aquatic Resources Category 1 Operations - Impingement and 62 $168 115 $19,320 $154,560 $85,133 $118,742 Entrainment of Aquatic Organisms Category 1 Operations - Water Use Conflicts 63 $168 58 $9,744 $77,952 $42,937 $59,887 with Aquatic Resources Category 1 Operations - Important Species 64 and Habitats - Other Important Species and $168 142 $23,856 $190,848 $105,121 $146,621 Habitats Category 1 Construction - Radiological Dose 65 $168 97 $16,296 $130,368 $71,808 $100,156 to Construction Workers

Regulatory Analysis Page 3-21 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application NRC Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue NRC Operations Number Category 1 Operations - Occupational Doses 66 $168 62 $10,416 $83,328 $45,898 $64,018 to Workers Category 1 Operations - Maximally Exposed 67 $168 53 $8,904 $71,232 $39,235 $54,725 Individual Annual Doses Category 1 Operations - Total Population 68 $168 64 $10,752 $86,016 $47,378 $66,083 Annual Doses Category 1 Operations - Nonhuman Biota 69 $168 36 $6,048 $48,384 $26,650 $37,171 Doses Category 1 Construction - Building Impacts of 70 Chemical, Biological, and Physical $168 44 $7,392 $59,136 $32,573 $45,432 Nonradiological Hazards Category 1 Operations - Operation Impacts of 71 Chemical, Biological, and Physical $168 23 $3,864 $30,912 $17,027 $23,748 Nonradiological Hazards Category 1 Construction - Construction-72 $168 17 $2,856 $22,848 $12,585 $17,553 Related Noise Category 1 Operations - Operation-Related 73 $168 10 $1,680 $13,440 $7,403 $10,325 Noise Category 1 Operations - Low-Level 74 $168 145 $24,360 $194,880 $107,341 $149,718 Radioactive Waste Category 1 Operations - Onsite Spent Nuclear 75 $168 176 $29,568 $236,544 $130,290 $181,727 Fuel Management 76 Category 1 Operations - Mixed Waste $168 136 $22,848 $182,784 $100,679 $140,426 Category 1 Construction - Construction 77 $168 34 $5,712 $45,696 $25,170 $35,106 Nonradiological Waste Category 1 Operations - Operation 78 $168 17 $2,856 $22,848 $12,585 $17,553 Nonradiological Waste Category 1 Operations - Design Basis 79 $168 120 $20,160 $161,280 $88,834 $123,905 Accidents Involving Radiological Releases Category 1 Operations - Accidents Involving 80 $168 77 $12,936 $103,488 $57,002 $79,506 Releases of Hazardous Chemicals

Regulatory Analysis Page 3-22 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application NRC Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue NRC Operations Number Category 1 Operations - Severe Accident 81 $168 61 $10,248 $81,984 $45,157 $62,985 Mitigation Design Alternatives 82 Category 1 Operations - Acts of Terrorism $168 57 $9,576 $76,608 $42,196 $58,855 Category 1 Construction - Community 83 $168 44 $7,392 $59,136 $32,573 $45,432 Services and Infrastructure Category 1 Construction - Transportation 84 $168 89 $14,952 $119,616 $65,885 $91,896 Systems and Traffic 85 Category 1 Construction - Economic Impacts $168 43 $7,224 $57,792 $31,832 $44,399 Category 1 Construction - Tax Revenue 86 $168 25 $4,200 $33,600 $18,507 $25,814 Impacts Category 1 Operations - Community Services 87 $168 29 $4,872 $38,976 $21,468 $29,944 and Infrastructure Category 1 Operations - Transportation 88 $168 15 $2,520 $20,160 $11,104 $15,488 Systems and Traffic 89 Category 1 Operations - Economic Impacts $168 29 $4,872 $38,976 $21,468 $29,944 Category 1 Operations - Tax Revenue 90 $168 57 $9,576 $76,608 $42,196 $58,855 Impacts 91 Category 1 Operations - Uranium Recovery $168 26 $4,368 $34,944 $19,247 $26,846 92 Category 1 Operations - Uranium Conversion $168 26 $4,368 $34,944 $19,247 $26,846 93 Category 1 Operations - Enrichment $168 32 $5,376 $43,008 $23,689 $33,041 94 Category 1 Operations - Fuel Fabrication(a) $168 37 $6,216 $49,728 $27,391 $38,204 95 Category 1 Operations - Reprocessing $168 27 $4,536 $36,288 $19,988 $27,879 Category 1 Operations - Storage and 96 $168 37 $6,216 $49,728 $27,391 $38,204 Disposal of Radiological Wastes Category 1 Operations - Transportation of 97 $168 57 $9,576 $76,608 $42,196 $58,855 Unirradiated ANR Fuel Category 1 Operations - Transportation of 98 $168 57 $9,576 $76,608 $42,196 $58,855 Radioactive Waste from ANRs

Regulatory Analysis Page 3-23 Net Savings (Costs) per Total Net Savings (Costs) - Rule Application NRC Table 4-1 Issue Descriptions Labor Hours per Total per Undiscounted 7% NPV 3% NPV Rate Application Application Total Issue NRC Operations Number Category 1 Operations - Transportation of 99 $168 181 $30,408 $243,264 $133,992 $186,890 Irradiated Fuel from ANRs 100 Decommissioning $168 95 $15,960 $127,680 $70,327 $98,091 Totals 6,416 $1,077,888 $8,623,104 $4,749,675 $6,624,783 (a) Fuel fabrication impacts for metal fuel and liquid fueled molten salt are not included in the staffs generic analysis.

Regulatory Analysis Page 4-1 4.0 RESULTS This section presents the analytical results and is organized into three sections. Section 4.1 presents findings related to the benefits and costs of the regulatory analysis. Section 4.2 discusses the backfit analysis, and Section 4.3 discusses disaggregation of the analytical results.

4.1 Benefits and Costs 4.1.1 Quantitative Results For Alternative 2, four attributes have been analyzed quantitatively (Industry Implementation, Industry Operations, NRC Implementation, and NRC Operations). The net benefits and costs calculated for Alternatives 1 and 2 are presented below. Relative to the Alternative 1 (No-Action alternative), Alternative 2 would result in estimated net one-time quantitative benefits:

Industry benefits of $5.0 million net present value, assuming a 7-percent discount rate, or

$6.8 million assuming a 3-percent discount rate.

Industry costs of ($0.4 million) net present value, assuming a 7-percent discount rate, or

($0.4 million) assuming a 3-percent discount rate. Costs are discussed in Section 3.3.1.

NRC benefits of $4.8 million net present value, assuming a 7-percent discount rate, or

$6.6 million assuming a 3-percent discount rate.

NRC costs of ($2.1 million) net present value, assuming a 7-percent discount rate, or

($2.2 million) assuming a 3-percent discount rate. Costs are discussed in Section 3.3.3.

Table 4.31 presents the quantitative results for Alternative 2 using a 7-percent discount rate and a 3-percent discount rate, respectively. Several cases were developed to reflect situations where only some Category 1 issues would be identified and used as part of an application.

Section 4.3.1 provides a detailed discussion of the 50 percent case and the 75 percent case, which are presented as sensitivity cases in Error! Reference source not found. in Section 4.3.3.

Table 4.1 Net Benefits (Costs) of Alternative 2 Implementation and Operations Case Undiscounted 7% NPV 3% NPV Industry $8,564,784 $5,047,780 $6,777,377 NRC $8,623,104 $4,749,675 $6,624,783 Total Benefit $17,187,888 $9,797,455 $13,402,159 Industry Cost ($400,000) ($361,604) ($382,694)

NRC Cost ($2,313,955) ($2,072,666) ($2,204,611)

Total Cost ($2,713,955) ($2,434,269) ($2,587,305)

Net Benefits $14,473,933 $7,363,186 $10,814,854 4.1.2 Qualitative Results For Alternative 2, two attributes have been analyzed on a qualitative basis (Improvements in Knowledge; Improvements in Clarity and Efficiency). In addition, one aspect of the Industry Implementation and NRC Implementation attributes pertaining to issues associated with

Regulatory Analysis Page 4-2 transmission line rights-of-way (ROWs) also was evaluated on a qualitative basis. Table 4.2 presents a summary of both the qualitative and quantitative benefits and costs for Alternative 2.

Table 4.2 Summary of Results for Alternative 2 (Update and Amend 10 CFR Part 51)

Net Monetary Benefits or Costs Savings per Application Dollars Dollars Average Hours (7% Discount Rate) (3% Discount Rate)

Industry 6,548 $4.7 million $6.4 million NRC 6,416 $2.7 million $4.4 million Total 12,964 $7.4 million $10.8 million Non-Monetary Benefits and Costs (Qualitative)

Benefit: The identification of Category 1 issues will improve the efficiency of licensing ANRs Improvements in by (1) identifying the possible types of environmental impacts of constructing, Process operating and decommissioning an ANR, (2) assessing impacts that are expected to be generic (the same or similar) for many or most ANRs, and (3) defining the environmental issues that will need to be addressed in project-specific Supplemental EISs (SEISs) addressing specific projects.

Costs: Savings are dependent on the number of applicants, the timing of their submissions, and the applicability of the ANR GEIS for their proposed sites. If there are fewer applicants or if the GEIS is not as useful as modeled, then net costs would increase.

4.2 Disaggregation To comply with guidance provided in Section 4.3.2 (Criteria for the Treatment of Individual Requirements) of the Regulatory Analysis Guidelines (NRC 2020-TN6806), the NRC conducted a screening review to ensure that the aggregate analysis did not mask the inclusion of individual rule provisions that would not be cost-beneficial when considered individually and are not necessary to meet the goals of the rule revisions.

Consistent with the Regulatory Analysis Guidelines, the NRC evaluated, on a disaggregated basis, each new regulatory provision expected to result in an incremental cost. Appendix A of this regulatory analysis presents savings estimated to result from each issue addressed by the proposed rule. Each change is necessary to comply with Federal environmental regulations and is not considered a voluntary alternative. Operation costs for industry and the NRC are not issue-specific and will apply regardless of the issues considered.

4.3 Uncertainty Analysis To determine the robustness of the costs and net benefits of the proposed rule, the NRC examined how anticipated savings change due to uncertainties associated with the NRCs analytical assumptions and input data. As mentioned in Section 3.1, the NRC used Monte Carlo simulation to examine the impact of uncertainty on the estimated net benefits of the proposed rule. These Monte Carlo simulations were performed using Visual Basic for Applications within Microsoft Excel.

Monte Carlo simulations involve introducing uncertainty into the analysis by replacing the point estimates of the variables used to estimate costs and benefits with probability distributions. By

Regulatory Analysis Page 4-3 defining input variables as probability distributions as opposed to point estimates, the effect of uncertainty on the results of the analysis (i.e., the net benefits) can be effectively modeled.

The Monte Carlo simulations were performed by repeatedly running the analysis, up to 10,000 times. For each iteration of the analysis, a value was chosen randomly from the probability distributions that define the input variables. The value of the output variable (the net benefits) was recorded for each iteration, and all of the resulting values for the output variable were used to define a distribution for the results.

4.3.1 Uncertainty Model Inputs In this analysis, the NRC assigned probability distributions to uncertain variables including the number of Category 1 issues that might be triggered by an ANR application, the relative complexity of any one application, and the mix of applications expected during the analysis period, and the NRC assigned triangular probability distributions to these inputs.

As an example of the variables and distributions used in the Monte Carlo simulations, a variety of potential scenarios were evaluated based on combinations of resource areas for which the Category 1 issues might apply/not apply based on the type of site and design that is selected.

These combinations reflect the input of NRC SMEs about the potential mix of issues that may apply to applications expected during the analysis period of the proposed rule, and included the following potential application cases:

Case 1: All Category 1 issues applicable

Case 2: Brownfield site without terrestrial ecology concerns nor transmission lines

Case 3: Brownfield site without groundwater use, transmission lines, or terrestrial ecology resources

Case 4: Small brownfield site without water use

Case 5: Small brownfield site without ecological concerns, transmission lines, or surface water use

Case 6: Large greenfield site with transmission lines

Case 7: Greenfield site without groundwater resources

Case 8: Greenfield site with no water use, aquatic ecology resources, or transmission lines

Case 9: Greenfield site with no surface water or aquatic ecology resources, with transmission lines.

For each of these cases, the NRC determined which set of Category 1 issues likely would apply and estimated the net savings that would be attributable for each case. The number of applicable Category 1 issues for any review is linked to the SME-determined effort per issue used to derive the per issue savings from conducting generic analysis. Also, NRC modeled the effort of the least complex review scenario in addition to the most typical review experience.

The sensitivity of the results to variations in the scope of the ER are presented in Table 4.3. In the case of lower review complexity, many Category 1 issues may not be of any concern or the affected resource areas may not be present at the anticipated application site. In these cases, no savings would result if the Category 1 issue identified in the ANR GEIS is not present for a given application. Thus, Table 4.3 presents what reduced savings would be available in such cases.

Regulatory Analysis Page 4-4 Table 4.3 Relative Expected Effort of Alternative NRC ANR NEPA Review Cases Case Case Case Case Case Case Case Case Case Metric 1 2 3 4 5 6 7 8 9 Category 1 issues in play 100 80 73 51 59 100 93 66 78 Most typical review effort Fraction of most typical effort 100% 89% 78% 48% 60% 100% 89% 58% 71%

Least complex review effort Fraction of most typical effort 67% 62% 55% 41% 48% 67% 60% 45% 53%

These results suggest that for the most typical review approximately 50%, 75%, or 100% of the Category 1 issues would be used. As a result, these percentages of Category 1 resource utilization were used to understand how cost might reasonably vary based on the utilization of Category 1 issues in the applications that are received. The NRC acknowledges that some anticipated applications may be for relatively small projects, compared to the COL and ESP projects upon which these estimates are based. The least complex review effort may be more indicative of the expected effort for such applications. However, the NRC assumes that the most typical application will be for larger projects, similar to the Clinch River ESP application, in which an ANR array design was proposed as part of a relatively large facility and site development involving all or most Category 1 issues.

Table 4.4 provides the parameters used in the uncertainty analysis. These parameters were assigned probability distributions and used values selected from that distribution with each iteration of the Monte Carlo simulation. For each variable in Table 4.4, the characteristics of the distribution used in the simulation are provided. Review complexity was derived by collecting data about recent NRC environmental reviews of new reactor applications, including an ESP application for an ANR facility at the Clinch River site in Tennessee, in addition to two large LWR applications. NRC environmental reviews range in complexity based on several factors that vary from site to site and application to application. Experienced environmental SMEs were asked to indicate which reviews reflected the most typical, least complex, and most complex for their specific resource area (ecology, human health, socioeconomics, water resources, etc.).

The Category 1 issues analyzed in this proposed rule are each assigned to a specific resource area for impact analysis for each application (COL, ESP licensing actions). For each Category 1 issue, the relevant SME made a determination of which application represented the most typical review experience, the least complex, and the most complex for their resource area. This information was used to allocate NRC cost data for each issue for each classification (least complex, most typical, most complex). Scalars were calculated representing the relative effort for any single Category 1 issue between least complex and most typical and between most complex and most typical. These values are reflected in Table 4.4.

The information presented in Table 4.3 above provides the basis for varying the number of Category 1 issues for any single application. The parameters of this distribution are shown in Table 4.4 and vary from 50 to 100 issues. This variable can be influenced by or be a function of review complexity but has a distinct influence on the potential savings. This is because it is quite possible to have relatively few Category 1 issues at play in a specific application review, but some of the issues may be relatively complex. Thus, this variable also was modeled in the Monte Carlo analysis.

Finally, the mix of reviews undertaken during the analysis period of the proposed rule also is subject to some level of uncertainty. This is reflected in the total number of Category 1 issues that would arise from the eight applications expected in the 2024-2034 period. If each

Regulatory Analysis Page 4-5 application used the GEIS analysis for all 100 Category 1 issues, then 800 such issues would be triggered in the 2024-2034 period and savings would be maximized. However, as few as 400 issues may be triggered based on the information derived from Table 4.3 above. The Monte Carlo analysis models this uncertainty using the parameters shown in Table 4.4.

Table 4.4 Example Variables and Distributions Used in the Monte Carlo Analysis Variable Description Distribution Mode Minimum Maximum Scalar on the most Review complexity -

typical review Triangular 1 0.57 2.47 Industry experience Scalar on the most Review complexity -

typical review Triangular 1 0.67 1.91 NRC experience Number of issues per Category 1 Issues Triangular 100 50 100 review Sum of all Category 1 Mix of reviews -

issues under review Triangular 800 400 800 Industry 2024-2034 Sum of all Category 1 Mix of reviews -

issues under review Triangular 750 350 750 NRC 2024-2034 4.3.2 Uncertainty Model Results Figure 4.1 displays the results of the uncertainty analysis for the net benefits (benefits minus costs) of the proposed rule. By allowing uncertain assumptions and inputs to range across a distribution the results are no longer static and instead spread across a range with varying degrees of certainty.

Regulatory Analysis Page 4-6 Figure 4.1 Relative Frequency of the Undiscounted Net Benefits of the Proposed Rule (2021 Dollars)

Similarly, the net benefits with 7 percent and 3 percent discounting can be seen in Figure 4.2.

NOTE: As the discount rate increases in the above exhibit, the distributions become narrower. This narrowing is a result of the decreasing value of net benefits in future years as discount rates increase. Larger discount rates result in smaller cost and benefit values in future years in the analysis period, resulting in a smaller range and a narrower distribution.

Figure 4.2 Relative Frequency of the Net Benefits of the Proposed Rule at 7 Percent and 3 Percent Discounting (2021 Dollars)

Regulatory Analysis Page 4-7 Examining the range of the resulting distributions of net benefits, it is possible to more confidently discuss the potential costs and benefits of the proposed rule. Table 4.5 displays a 90 percent confidence interval, meaning that the net benefits will fall between the ranges indicated for 90 percent of all the iterations run as part of the Monte Carlo simulations. In all cases, regardless of the discount rate used, the benefits of the proposed rule (in terms of averted costs) will outweigh the implementation costs of the proposed rule that will be incurred by industry applicants and the NRC. This result is demonstrated by the fact that the resulting distributions of net benefits, whether undiscounted or at 3 or 7 percent discount rates, are always greater than zero.

Table 4.5 Confidence Intervals for Alternative 2 Benefits and Costs of the Proposed Rule at 7 Percent and 3 Percent Discounting (in 2021 Dollars) 90-Percent Confidence Intervals Metric 7% NPV 3% NPV Total Benefits $9,463,635 $10,131,275 $12,948,785 $13,855,533 Total Costs ($2,599,129) ($2,269,409) ($2,762,529) ($2,412,081)

Net Benefits $6,864,506 $7,861,866 $10,186,256 $11,443,452 4.3.3 Sensitivity Analysis In addition to estimating the probability distributions for the net benefits of the proposed rule, Monte Carlo simulation was used to conduct a sensitivity analysis to determine the variables that have greatest impact on the resulting net benefits. Variables shown to have a large effect on the resulting net benefits may deserve more attention and scrutiny than variables shown to have a small or minimal effect.

To estimate the effect of each variable on the net benefits, key inputs were adjusted by applying the endpoints of the modeled distributions in each case, in isolation from any other changes, to observe the individual impact of the change on the benefits of the rule. The results are compiled into a tornado diagram, which presents in vertical order the variables that have the greatest influence on net benefits. Figure 4.3 presents the tornado diagram for the net benefits of the proposed rule. The costs of the rule are not subject to variability other than the effect of financial discounting, because some costs have already been incurred and are not included in the analysis, and the balance of rule-related costs are subject to budget constraints or contracts already in place, which remove much of the uncertainty.

Regulatory Analysis Page 4-8 Note: Bars indicated with an asterisk (*) denote that the results are discounted using the 7-percent discount rate.

Figure 4.3 Tornado Diagram for the Net Benefits of the Proposed Rule (2021 Dollars)

The horizontal axis in Figure 4.3 is displayed as the net effect on the net benefits of the rule from an adjustment of the key inputs to the benefits estimation based on the endpoints of each distribution used in the Monte Carlo analysis.

Examining the tornado diagrams provides insight into which of the key variables have the largest impacts on the results of this analysis. From Figure 4.3, the parameters having the greatest influence on the total benefits of the final rule are the variables related to the complexity of the expected applications developed by industry applicants followed by the related effects on complexity encountered during NRC environmental reviews. The spread in simulation results reflects the NRC experience with wide-ranging issues, which can complicate individual applications as reflected in Table 4.4 above. Fifty-percent adjustments (reductions) in the number of Category 1 issues can reduce the net benefits by as much as 60 percent. Imposing a 7-percent discount rate on the net benefits results in an approximately 50-percent decline in net benefits compared to undiscounted estimates. Adjusting the industry labor rate and the NRC labor rate each by +/- 25-percent have equal influence on the benefits expected from the rule and equate to an approximately +/- 15-percent impact on the undiscounted net benefits. All other variables, taken individually, have lesser impacts on the financial net benefits of the rule.

Figure 4.3 also illustrates the effect of front-loading or back-loading the eight planned ANR

Regulatory Analysis Page 4-9 applications, as opposed to the assumed even distribution of applications modeled as the most likely case. These bars are indicated with an asterisk (*) to denote that the results are discounted using the 7-percent discount rate. The timing of the eight applications only matters in financial terms when compared to other discounted values. Front-loading the applications in the early years of the analysis period increases the discounted net benefits by over 25 percent, while delaying submission of applications until the latter half of the analysis period decreases discounted net benefits by just over 20 percent.

Figure 4.4 and Figure 4.5 provide insight into the most sensitive variables in the analysis, including the NEPA review complexity and the variability in the number of Category 1 issues applicable to any one NEPA review. The parameters for the review complexity distribution reflected in Figure 4.4 were developed from previous NRC NEPA review experience and reflect SME attribution of the proportion of billed effort to each individual Category 1 issue. SME attribution of effort proportions was multiplied by the portion of past NEPA review costs for COL and ESP actions attributed to impact assessments. The range of applications and sites resulted in scalars that have been applied to what the SMEs judged to be the most and least complex NEPA reviews.

Figure 4.4 Distribution of NEPA Review Complexity used in Monte Carlo Analysis Figure 4.5 reflects the uncertain nature of future ANR applications. Some applications may be for large projects where all 100 Category 1 issues may be subject to generic analysis, and others may be for smaller projects where only a subset of the Category 1 issue may apply.

Thus, the distribution illustrates the total number of Category 1 issues expected to be relevant during the proposed rules analysis period of 2024-2034.

Regulatory Analysis Page 4-10 Figure 4.5 Distribution of Total Category 1 Issues Analyzed during the Proposed Rule (2024-2034).

The NRC also considered the case where potential applicants may quickly take advantage of the proposed rule and may be preparing now for it to be implemented. This might enable some applicants to submit an ANR application soon after the final rule becomes effective. If this occurs, the savings benefits would happen sooner and would increase the total net benefits of the rule.

Regulatory Analysis Page 5-1 5.0 DECISION RATIONALE Relative to the No-Action alternative, Alternative 2 results in a net benefit of approximately

$7.33 million (total present value), using a 7-percent discount rate, or $10.8 million using a 3-percent discount rate. Additionally, the NRC has concluded that proceeding with Alternative 2 is justified for the following reasons:

1. Alternative 2 incorporates revisions to 10 CFR Part 51, including Table C-1 which reflect the findings described in the ANR GEIS.

2. Alternative 2 incorporates text to improve the effectiveness and efficiency of the environmental review for advanced reactor applications by codifying the GEIS findings in Table C-1. Improving the effectiveness and efficiency of the advanced reactor environmental reviews will reduce the cost to industry of preparing environmental reports for advanced reactor applications and focuses resources on project-specific analyses. The NRC also will recognize similar reductions in cost and be better able to focus its resources on the important project-specific issues during ANR licensing environmental reviews.

Regulatory Analysis Page 6-1 6.0 IMPLEMENTATION This section identifies how and when the proposed action will be implemented, the required NRC actions to ensure implementation, and the impact on NRC resources.

6.1 Schedule The NRC assumes that the proposed rule would become effective 30 days after its publication in the Federal Register in 2024.

6.2 Impact on Other Requirements None.

Regulatory Analysis Page 7-1

7.0 REFERENCES

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions. TN250.

84 FR 62559. November 15, 2019. Agency Action Regarding the Exploratory Process for the Development of an Advanced Nuclear Reactor Generic Environmental Impact Statement.

Federal Register, Nuclear Regulatory Commission. TN6470.

85 FR 24040. April 30, 2020. Notice To Conduct Scoping and Prepare an Advanced Nuclear Reactor Generic Environmental Impact Statement. Federal Register, Nuclear Regulatory Commission. TN6458.

Barrasso, J. and M. Braun. 2019. Letter to NRC, dated June 25, 2019, regarding Request you Initiate a Process to Develop a Generic Environmental Impact Statement (GEIS) for the Construction and Operation of Advanced Nuclear Reactors. U.S. Senate, Washington, D.C.

ADAMS Accession No. ML19176A444. TN6465.

Endangered Species Act of 1973. 16 U.S.C. § 1531 et seq. TN1010.

National Environmental Policy Act of 1969 (NEPA), as amended. 42 U.S.C. § 4321 et seq.

TN661.

National Historic Preservation Act. 54 U.S.C. § 300101 et seq. TN4157.

NRC (U.S. Nuclear Regulatory Commission). 2013. Generic Environmental Impact Statement for License Renewal of Nuclear Plants [GEIS]. NUREG-1437, Revision 1, Washington, D.C.

ADAMS Package Accession No. ML13107A023. TN2654.

NRC (U.S. Nuclear Regulatory Commission). 2018. Preparation of Environmental Reports for Nuclear Power Stations. Regulatory Guide 4.2, Revision 3, Washington, D.C. ADAMS Accession No. ML18071A400. TN6006.

NRC (U.S. Nuclear Regulatory Commission). 2019. Letter from K.L. Svinicki to Senator J.A.

Barrasso, dated July 29, 2019, regarding Response to Request that NRC Initiate a Process to Develop a Generic Environmental Impact Statement for the Construction and Operation of Advanced Nuclear Reactors. Washington, D.C. ADAMS Accession No. ML19192A267.

TN6467.

NRC (U.S. Nuclear Regulatory Commission). 2020. Memorandum from A.L. Vietti-Cook to M.M. Doane, dated September 21, 2020, regarding Staff Requirements - SECY-20-0020 -

Results of Exploratory Process for Developing a Generic Environmental Impact Statement for the Construction and Operation of Advanced Nuclear Reactors. SRM-SECY-20-0020, Washington, D.C. ADAMS Accession No. ML20265A112. TN6492.

NRC (U.S. Nuclear Regulatory Commission). 2020. Policy Issue: Draft Final NUREG/BR-0058, Revision 5, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission.

SECY-20-0008, Washington, D.C. ADAMS Pkg. Accession No. ML19261A277. TN6806.

Regulatory Analysis Page 7-2 NRC (U.S. Nuclear Regulatory Commission). 2020. Policy Issue: Results of Exploratory Process for Developing a Generic Environmental Impact Statement for the Construction and Operation of Advanced Nuclear Reactors. SECY-20-0020, Washington, D.C. ADAMS Accession No. ML20052D175. TN6493.

NRC (U.S. Nuclear Regulatory Commission). 2020. Summary of Public Scoping Meeting Conducted for the Advanced Reactor Generic Environmental Impact Statement, May 28, 2020.

Washington, D.C. ADAMS Package Accession No. ML20161A339. TN6459.

NRIC (National Reactor Innovation Center). 2021. Advanced Nuclear Reactor Plant Parameter Envelope and Guidance. NRIC-21-ENG-0001, Washington, D.C. ADAMS Accession No. ML21145A416. TN6940.

Nuclear Energy Innovation and Modernization Act. Public Law 115-439. 132 Stat. 5565.

TN6469.

Nuclear Energy Innovation Capabilities Act of 2017. Public Law 115-248. 132 Stat. 3160.

TN6468.

Regulatory Analysis Page A-1 APPENDIX A

SUMMARY

OF RULE SAVINGS RESULTS - ALTERNATIVE 2 This appendix presents the detailed financial cost savings impacts of the proposed rule for each Category 1 issue, both for industry and the U.S. Nuclear Regulatory Commission (NRC). The substantial majority of impacts attributable to the proposed rule derive from the reduction in industry and NRC environmental review effort required to satisfy National Environmental Policy Act (NEPA) reporting requirements for new ANR licensing actions.

This reduction in effort enabled by use of the Generic Environmental Impact Statement (GEIS) to provide generic impact estimates across 100 Category 1 issues leads to substantial savings over current practice and represents a quantifiable national benefit.

The analysis of savings relies upon several assumptions about how the proposed rule will be utilized by industry including the number and timing of applications expected to be submitted to NRC under the rule during the operational period of the proposed rule (2024-2034). The NRC assumes that eight applications will be submitted for ANR projects under the proposed rule. Further, the NRC assumes that no application will be submitted until 18-24 months after the implementation of the final rule. These assumptions are judged to form the most likely evolution of impacts of the proposed rule and the detailed results presented in this appendix reflect that assumption. However, it is plausible that at least one application may be submitted relatively soon after the implementation date of the final rule. The effect of this potential is presented as part of the uncertainty analysis in Section 4.3. The sooner in the operational period of the proposed rule that industry utilizes its provisions and submits an ANR licensing application, the larger the financial effects (net benefits) would be.

The proposed rule creates 100 Category 1 issues for which generic impact analysis can be utilized by industry and NRC staff. Error! Reference source not found. provides the annual and total savings estimated to result for each Category 1 issue used by industry. As the size and complexity of the expected ANR applications are not known at the time of this analysis, the NRC staff assumes that the most likely case would be for applications taking full advantage of the proposed rule and invoking a generic analysis for all 100 Category 1 issues. Section 4.3 illustrates potential results if a distribution of applications using various numbers of Category 1 issues might occur.

The results presented in Error! Reference source not found. reflect the following input variables (Section 3.3 provides more detailed discussion):

Labor Rate: The industry labor rate was assumed to be the average between the NRC labor rate of $137/hour and the NRC contractor labor rate of $190/hour, which equates to

$163.50/hour.

Hours per Application: For each Category 1 issue, the NRC staff estimated the hours saved by utilizing the generic impact analysis findings in the ANR GEIS. These impacts are a one-time realization of review effort savings per application realized when the application is accepted by NRC and a formal environmental review commences.

ANR Applications per Year: As discussed above and in Section 3.3, this represents the NRCs assumed number of ANR applications utilizing the provisions of the proposed rule.

The values reported in Error! Reference source not found. expand on the totals presented in Table 3.2.

Regulatory Analysis Page A-2 Table A-6. Summary of Proposed Rule Savings Benefits to Industry by Category 1 Issue (2021 Constant Dollars)

Issue 1: Category 1 Construction - Onsite Land Use ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 26 0 $0 $0 $0 2025 $163.50 26 0.5 $2,126 $1,622 $1,888 2026 $163.50 26 1 $4,251 $3,031 $3,667 2027 $163.50 26 1 $4,251 $2,833 $3,560 2028 $163.50 26 1 $4,251 $2,647 $3,456 2029 $163.50 26 1 $4,251 $2,474 $3,356 2030 $163.50 26 1 $4,251 $2,312 $3,258 2031 $163.50 26 1 $4,251 $2,161 $3,163 2032 $163.50 26 1 $4,251 $2,020 $3,071 2033 $163.50 26 0.5 $2,126 $944 $1,491 2034 $163.50 26 0 $0 $0 $0 8 $34,008 $20,043 $26,911 Issue 2: Category 1 Construction - Offsite Land Use ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 184 0 $0 $0 $0 2025 $163.50 184 0.5 $15,042 $11,475 $13,365 2026 $163.50 184 1 $30,084 $21,449 $25,951 2027 $163.50 184 1 $30,084 $20,046 $25,195 2028 $163.50 184 1 $30,084 $18,735 $24,461 2029 $163.50 184 1 $30,084 $17,509 $23,749 2030 $163.50 184 1 $30,084 $16,364 $23,057 2031 $163.50 184 1 $30,084 $15,293 $22,385 2032 $163.50 184 1 $30,084 $14,293 $21,733 2033 $163.50 184 0.5 $15,042 $6,679 $10,550 2034 $163.50 184 0 $0 $0 $0 8 $240,672 $141,844 $190,446

Regulatory Analysis Page A-3 Issue 3: Category 1 Construction - Impacts on Prime and Unique Farmland ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 25 0 $0 $0 $0 2025 $163.50 25 0.5 $2,044 $1,559 $1,816 2026 $163.50 25 1 $4,088 $2,914 $3,526 2027 $163.50 25 1 $4,088 $2,724 $3,423 2028 $163.50 25 1 $4,088 $2,545 $3,324 2029 $163.50 25 1 $4,088 $2,379 $3,227 2030 $163.50 25 1 $4,088 $2,223 $3,133 2031 $163.50 25 1 $4,088 $2,078 $3,041 2032 $163.50 25 1 $4,088 $1,942 $2,953 2033 $163.50 25 0.5 $2,044 $907 $1,433 2034 $163.50 25 0 $0 $0 $0 8 $32,700 $19,272 $25,876 Issue 4: Category 1 Construction - Coastal Zone and Compliance with The Coastal Zone Management Act ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 14 0 $0 $0 $0 2025 $163.50 14 0.5 $1,145 $873 $1,017 2026 $163.50 14 1 $2,289 $1,632 $1,975 2027 $163.50 14 1 $2,289 $1,525 $1,917 2028 $163.50 14 1 $2,289 $1,425 $1,861 2029 $163.50 14 1 $2,289 $1,332 $1,807 2030 $163.50 14 1 $2,289 $1,245 $1,754 2031 $163.50 14 1 $2,289 $1,164 $1,703 2032 $163.50 14 1 $2,289 $1,087 $1,654 2033 $163.50 14 0.5 $1,145 $508 $803 2034 $163.50 14 0 $0 $0 $0 8 $18,312 $10,792 $14,490

Regulatory Analysis Page A-4 Issue 5: Category 1 Operations - Onsite Land Use ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 3 0 $0 $0 $0 2025 $163.50 3 0.5 $245 $187 $218 2026 $163.50 3 1 $491 $350 $423 2027 $163.50 3 1 $491 $327 $411 2028 $163.50 3 1 $491 $305 $399 2029 $163.50 3 1 $491 $285 $387 2030 $163.50 3 1 $491 $267 $376 2031 $163.50 3 1 $491 $249 $365 2032 $163.50 3 1 $491 $233 $354 2033 $163.50 3 0.5 $245 $109 $172 2034 $163.50 3 0 $0 $0 $0 8 $3,924 $2,313 $3,105 Issue 6: Category 1 Operations - Offsite Land Use ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 25 0 $0 $0 $0 2025 $163.50 25 0.5 $2,044 $1,559 $1,816 2026 $163.50 25 1 $4,088 $2,914 $3,526 2027 $163.50 25 1 $4,088 $2,724 $3,423 2028 $163.50 25 1 $4,088 $2,545 $3,324 2029 $163.50 25 1 $4,088 $2,379 $3,227 2030 $163.50 25 1 $4,088 $2,223 $3,133 2031 $163.50 25 1 $4,088 $2,078 $3,041 2032 $163.50 25 1 $4,088 $1,942 $2,953 2033 $163.50 25 0.5 $2,044 $907 $1,433 2034 $163.50 25 0 $0 $0 $0 8 $32,700 $19,272 $25,876

Regulatory Analysis Page A-5 Issue 7: Category 1 Construction - Visual Impacts in Site and Vicinity ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 11 0 $0 $0 $0 2025 $163.50 11 0.5 $899 $686 $799 2026 $163.50 11 1 $1,799 $1,282 $1,551 2027 $163.50 11 1 $1,799 $1,198 $1,506 2028 $163.50 11 1 $1,799 $1,120 $1,462 2029 $163.50 11 1 $1,799 $1,047 $1,420 2030 $163.50 11 1 $1,799 $978 $1,378 2031 $163.50 11 1 $1,799 $914 $1,338 2032 $163.50 11 1 $1,799 $854 $1,299 2033 $163.50 11 0.5 $899 $399 $631 2034 $163.50 11 0 $0 $0 $0 8 $14,388 $8,480 $11,385 Issue 8: Category 1 Construction - Visual Impacts from Transmission Lines ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 11 0 $0 $0 $0 2025 $163.50 11 0.5 $899 $686 $799 2026 $163.50 11 1 $1,799 $1,282 $1,551 2027 $163.50 11 1 $1,799 $1,198 $1,506 2028 $163.50 11 1 $1,799 $1,120 $1,462 2029 $163.50 11 1 $1,799 $1,047 $1,420 2030 $163.50 11 1 $1,799 $978 $1,378 2031 $163.50 11 1 $1,799 $914 $1,338 2032 $163.50 11 1 $1,799 $854 $1,299 2033 $163.50 11 0.5 $899 $399 $631 2034 $163.50 11 0 $0 $0 $0 8 $14,388 $8,480 $11,385

Regulatory Analysis Page A-6 Issue 9: Category 1 Operations - Visual Impacts During Operations ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 23 0 $0 $0 $0 2025 $163.50 23 0.5 $1,880 $1,434 $1,671 2026 $163.50 23 1 $3,761 $2,681 $3,244 2027 $163.50 23 1 $3,761 $2,506 $3,149 2028 $163.50 23 1 $3,761 $2,342 $3,058 2029 $163.50 23 1 $3,761 $2,189 $2,969 2030 $163.50 23 1 $3,761 $2,045 $2,882 2031 $163.50 23 1 $3,761 $1,912 $2,798 2032 $163.50 23 1 $3,761 $1,787 $2,717 2033 $163.50 23 0.5 $1,880 $835 $1,319 2034 $163.50 23 0 $0 $0 $0 8 $30,084 $17,730 $23,806 Issue 10: Category 1 Construction - Emissions of Criteria Pollutants and Dust During Construction ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 33 0 $0 $0 $0 2025 $163.50 33 0.5 $2,698 $2,058 $2,397 2026 $163.50 33 1 $5,396 $3,847 $4,654 2027 $163.50 33 1 $5,396 $3,595 $4,519 2028 $163.50 33 1 $5,396 $3,360 $4,387 2029 $163.50 33 1 $5,396 $3,140 $4,259 2030 $163.50 33 1 $5,396 $2,935 $4,135 2031 $163.50 33 1 $5,396 $2,743 $4,015 2032 $163.50 33 1 $5,396 $2,563 $3,898 2033 $163.50 33 0.5 $2,698 $1,198 $1,892 2034 $163.50 33 0 $0 $0 $0 8 $43,164 $25,439 $34,156

Regulatory Analysis Page A-7 Issue 11: Category 1 Construction - Greenhouse Gas Emissions During Construction ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 76 0 $0 $0 $0 2025 $163.50 76 0.5 $6,213 $4,740 $5,520 2026 $163.50 76 1 $12,426 $8,860 $10,719 2027 $163.50 76 1 $12,426 $8,280 $10,407 2028 $163.50 76 1 $12,426 $7,738 $10,103 2029 $163.50 76 1 $12,426 $7,232 $9,809 2030 $163.50 76 1 $12,426 $6,759 $9,523 2031 $163.50 76 1 $12,426 $6,317 $9,246 2032 $163.50 76 1 $12,426 $5,904 $8,977 2033 $163.50 76 0.5 $6,213 $2,759 $4,358 2034 $163.50 76 0 $0 $0 $0 8 $99,408 $58,588 $78,662 Issue 12: Category 1 Operations - Emissions of Criteria and Hazardous Air Pollutants During Operation ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 50 0 $0 $0 $0 2025 $163.50 50 0.5 $4,088 $3,118 $3,632 2026 $163.50 50 1 $8,175 $5,829 $7,052 2027 $163.50 50 1 $8,175 $5,447 $6,846 2028 $163.50 50 1 $8,175 $5,091 $6,647 2029 $163.50 50 1 $8,175 $4,758 $6,453 2030 $163.50 50 1 $8,175 $4,447 $6,265 2031 $163.50 50 1 $8,175 $4,156 $6,083 2032 $163.50 50 1 $8,175 $3,884 $5,906 2033 $163.50 50 0.5 $4,088 $1,815 $2,867 2034 $163.50 50 0 $0 $0 $0 8 $65,400 $38,544 $51,752

Regulatory Analysis Page A-8 Issue 13: Category 1 Operations - Greenhouse Gas Emissions During Operation ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 48 0 $0 $0 $0 2025 $163.50 48 0.5 $3,924 $2,994 $3,486 2026 $163.50 48 1 $7,848 $5,596 $6,770 2027 $163.50 48 1 $7,848 $5,229 $6,573 2028 $163.50 48 1 $7,848 $4,887 $6,381 2029 $163.50 48 1 $7,848 $4,568 $6,195 2030 $163.50 48 1 $7,848 $4,269 $6,015 2031 $163.50 48 1 $7,848 $3,990 $5,840 2032 $163.50 48 1 $7,848 $3,729 $5,670 2033 $163.50 48 0.5 $3,924 $1,742 $2,752 2034 $163.50 48 0 $0 $0 $0 8 $62,784 $37,003 $49,681 Issue 14: Category 1 Operations - Cooling System Emissions ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 11 0 $0 $0 $0 2025 $163.50 11 0.5 $899 $686 $799 2026 $163.50 11 1 $1,799 $1,282 $1,551 2027 $163.50 11 1 $1,799 $1,198 $1,506 2028 $163.50 11 1 $1,799 $1,120 $1,462 2029 $163.50 11 1 $1,799 $1,047 $1,420 2030 $163.50 11 1 $1,799 $978 $1,378 2031 $163.50 11 1 $1,799 $914 $1,338 2032 $163.50 11 1 $1,799 $854 $1,299 2033 $163.50 11 0.5 $899 $399 $631 2034 $163.50 11 0 $0 $0 $0 8 $14,388 $8,480 $11,385

Regulatory Analysis Page A-9 Issue 15: Category 1 Operations - Emissions of Ozone and Nitrogen Oxides During Transmission Line Operation ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 6 0 $0 $0 $0 2025 $163.50 6 0.5 $491 $374 $436 2026 $163.50 6 1 $981 $699 $846 2027 $163.50 6 1 $981 $654 $822 2028 $163.50 6 1 $981 $611 $798 2029 $163.50 6 1 $981 $571 $774 2030 $163.50 6 1 $981 $534 $752 2031 $163.50 6 1 $981 $499 $730 2032 $163.50 6 1 $981 $466 $709 2033 $163.50 6 0.5 $491 $218 $344 2034 $163.50 6 0 $0 $0 $0 8 $7,848 $4,625 $6,210 Issue 16: Category 1 Construction - Surface Water Use Conflicts During Construction ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 17 0 $0 $0 $0 2025 $163.50 17 0.5 $1,390 $1,060 $1,235 2026 $163.50 17 1 $2,780 $1,982 $2,398 2027 $163.50 17 1 $2,780 $1,852 $2,328 2028 $163.50 17 1 $2,780 $1,731 $2,260 2029 $163.50 17 1 $2,780 $1,618 $2,194 2030 $163.50 17 1 $2,780 $1,512 $2,130 2031 $163.50 17 1 $2,780 $1,413 $2,068 2032 $163.50 17 1 $2,780 $1,321 $2,008 2033 $163.50 17 0.5 $1,390 $617 $975 2034 $163.50 17 0 $0 $0 $0 8 $22,236 $13,105 $17,596

Regulatory Analysis Page A-10 Issue 17: Category 1 Construction - Groundwater Use Conflicts Due to Excavation Dewatering ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 117 0 $0 $0 $0 2025 $163.50 117 0.5 $9,565 $7,297 $8,498 2026 $163.50 117 1 $19,130 $13,639 $16,501 2027 $163.50 117 1 $19,130 $12,747 $16,021 2028 $163.50 117 1 $19,130 $11,913 $15,554 2029 $163.50 117 1 $19,130 $11,134 $15,101 2030 $163.50 117 1 $19,130 $10,405 $14,661 2031 $163.50 117 1 $19,130 $9,724 $14,234 2032 $163.50 117 1 $19,130 $9,088 $13,820 2033 $163.50 117 0.5 $9,565 $4,247 $6,709 2034 $163.50 117 0 $0 $0 $0 8 $153,036 $90,194 $121,099 Issue 18: Category 1 Construction - Groundwater Use Conflicts Due to Construction-Related Groundwater Withdrawals ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 97 0 $0 $0 $0 2025 $163.50 97 0.5 $7,930 $6,050 $7,045 2026 $163.50 97 1 $15,860 $11,308 $13,681 2027 $163.50 97 1 $15,860 $10,568 $13,282 2028 $163.50 97 1 $15,860 $9,876 $12,895 2029 $163.50 97 1 $15,860 $9,230 $12,520 2030 $163.50 97 1 $15,860 $8,627 $12,155 2031 $163.50 97 1 $15,860 $8,062 $11,801 2032 $163.50 97 1 $15,860 $7,535 $11,457 2033 $163.50 97 0.5 $7,930 $3,521 $5,562 2034 $163.50 97 0 $0 $0 $0 8 $126,876 $74,776 $100,398

Regulatory Analysis Page A-11 Issue 19: Category 1 Construction - Water Quality Degradation Due to Construction-Related Discharges ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 17 0 $0 $0 $0 2025 $163.50 17 0.5 $1,390 $1,060 $1,235 2026 $163.50 17 1 $2,780 $1,982 $2,398 2027 $163.50 17 1 $2,780 $1,852 $2,328 2028 $163.50 17 1 $2,780 $1,731 $2,260 2029 $163.50 17 1 $2,780 $1,618 $2,194 2030 $163.50 17 1 $2,780 $1,512 $2,130 2031 $163.50 17 1 $2,780 $1,413 $2,068 2032 $163.50 17 1 $2,780 $1,321 $2,008 2033 $163.50 17 0.5 $1,390 $617 $975 2034 $163.50 17 0 $0 $0 $0 8 $22,236 $13,105 $17,596 Issue 20: Category 1 Construction - Water Quality Degradation Due to Inadvertent Spills During Construction ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 17 0 $0 $0 $0 2025 $163.50 17 0.5 $1,390 $1,060 $1,235 2026 $163.50 17 1 $2,780 $1,982 $2,398 2027 $163.50 17 1 $2,780 $1,852 $2,328 2028 $163.50 17 1 $2,780 $1,731 $2,260 2029 $163.50 17 1 $2,780 $1,618 $2,194 2030 $163.50 17 1 $2,780 $1,512 $2,130 2031 $163.50 17 1 $2,780 $1,413 $2,068 2032 $163.50 17 1 $2,780 $1,321 $2,008 2033 $163.50 17 0.5 $1,390 $617 $975 2034 $163.50 17 0 $0 $0 $0 8 $22,236 $13,105 $17,596

Regulatory Analysis Page A-12 Issue 21: Category 1 Construction - Water Quality Degradation Due to Groundwater Withdrawal ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 39 0 $0 $0 $0 2025 $163.50 39 0.5 $3,188 $2,432 $2,833 2026 $163.50 39 1 $6,377 $4,546 $5,500 2027 $163.50 39 1 $6,377 $4,249 $5,340 2028 $163.50 39 1 $6,377 $3,971 $5,185 2029 $163.50 39 1 $6,377 $3,711 $5,034 2030 $163.50 39 1 $6,377 $3,468 $4,887 2031 $163.50 39 1 $6,377 $3,241 $4,745 2032 $163.50 39 1 $6,377 $3,029 $4,607 2033 $163.50 39 0.5 $3,188 $1,416 $2,236 2034 $163.50 39 0 $0 $0 $0 8 $51,012 $30,065 $40,366 Issue 22: Category 1 Construction - Water Quality Degradation Due to Offshore or In-Water Construction Activities ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 67 0 $0 $0 $0 2025 $163.50 67 0.5 $5,477 $4,179 $4,866 2026 $163.50 67 1 $10,955 $7,810 $9,449 2027 $163.50 67 1 $10,955 $7,299 $9,174 2028 $163.50 67 1 $10,955 $6,822 $8,907 2029 $163.50 67 1 $10,955 $6,376 $8,648 2030 $163.50 67 1 $10,955 $5,959 $8,396 2031 $163.50 67 1 $10,955 $5,569 $8,151 2032 $163.50 67 1 $10,955 $5,204 $7,914 2033 $163.50 67 0.5 $5,477 $2,432 $3,842 2034 $163.50 67 0 $0 $0 $0 8 $87,636 $51,650 $69,347

Regulatory Analysis Page A-13 Issue 23: Category 1 Construction - Water Use Conflict Due to Plant Municipal Water Demand ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 67 0 $0 $0 $0 2025 $163.50 67 0.5 $5,477 $4,179 $4,866 2026 $163.50 67 1 $10,955 $7,810 $9,449 2027 $163.50 67 1 $10,955 $7,299 $9,174 2028 $163.50 67 1 $10,955 $6,822 $8,907 2029 $163.50 67 1 $10,955 $6,376 $8,648 2030 $163.50 67 1 $10,955 $5,959 $8,396 2031 $163.50 67 1 $10,955 $5,569 $8,151 2032 $163.50 67 1 $10,955 $5,204 $7,914 2033 $163.50 67 0.5 $5,477 $2,432 $3,842 2034 $163.50 67 0 $0 $0 $0 8 $87,636 $51,650 $69,347 Issue 24: Category 1 Construction - Degradation of Water Quality from Plant Effluent Discharges to Municipal Systems ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 150 0 $0 $0 $0 2025 $163.50 150 0.5 $12,263 $9,355 $10,895 2026 $163.50 150 1 $24,525 $17,486 $21,155 2027 $163.50 150 1 $24,525 $16,342 $20,539 2028 $163.50 150 1 $24,525 $15,273 $19,941 2029 $163.50 150 1 $24,525 $14,274 $19,360 2030 $163.50 150 1 $24,525 $13,340 $18,796 2031 $163.50 150 1 $24,525 $12,467 $18,249 2032 $163.50 150 1 $24,525 $11,652 $17,717 2033 $163.50 150 0.5 $12,263 $5,445 $8,601 2034 $163.50 150 0 $0 $0 $0 8 $196,200 $115,633 $155,255

Regulatory Analysis Page A-14 Issue 25: Category 1 Operations - Surface Water Use Conflicts During Operation Due to Water Withdrawal from Flowing Waterbodies ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 109 0 $0 $0 $0 2025 $163.50 109 0.5 $8,911 $6,798 $7,917 2026 $163.50 109 1 $17,822 $12,706 $15,373 2027 $163.50 109 1 $17,822 $11,875 $14,925 2028 $163.50 109 1 $17,822 $11,098 $14,491 2029 $163.50 109 1 $17,822 $10,372 $14,068 2030 $163.50 109 1 $17,822 $9,694 $13,659 2031 $163.50 109 1 $17,822 $9,060 $13,261 2032 $163.50 109 1 $17,822 $8,467 $12,875 2033 $163.50 109 0.5 $8,911 $3,956 $6,250 2034 $163.50 109 0 $0 $0 $0 8 $142,572 $84,027 $112,818 Issue 26: Category 1 Operations - Surface Water Use Conflicts During Operation Due to Water Withdrawal from Non-Flowing Waterbodies ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 39 0 $0 $0 $0 2025 $163.50 39 0.5 $3,188 $2,432 $2,833 2026 $163.50 39 1 $6,377 $4,546 $5,500 2027 $163.50 39 1 $6,377 $4,249 $5,340 2028 $163.50 39 1 $6,377 $3,971 $5,185 2029 $163.50 39 1 $6,377 $3,711 $5,034 2030 $163.50 39 1 $6,377 $3,468 $4,887 2031 $163.50 39 1 $6,377 $3,241 $4,745 2032 $163.50 39 1 $6,377 $3,029 $4,607 2033 $163.50 39 0.5 $3,188 $1,416 $2,236 2034 $163.50 39 0 $0 $0 $0 8 $51,012 $30,065 $40,366

Regulatory Analysis Page A-15 Issue 27: Category 1 Operations - Groundwater Use Conflicts Due to Building Foundation Dewatering ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 29 0 $0 $0 $0 2025 $163.50 29 0.5 $2,371 $1,809 $2,106 2026 $163.50 29 1 $4,742 $3,381 $4,090 2027 $163.50 29 1 $4,742 $3,159 $3,971 2028 $163.50 29 1 $4,742 $2,953 $3,855 2029 $163.50 29 1 $4,742 $2,760 $3,743 2030 $163.50 29 1 $4,742 $2,579 $3,634 2031 $163.50 29 1 $4,742 $2,410 $3,528 2032 $163.50 29 1 $4,742 $2,253 $3,425 2033 $163.50 29 0.5 $2,371 $1,053 $1,663 2034 $163.50 29 0 $0 $0 $0 8 $37,932 $22,356 $30,016 Issue 28: Category 1 Operations - Groundwater Use Conflicts Due to Groundwater Withdrawals for Plant Uses ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 57 0 $0 $0 $0 2025 $163.50 57 0.5 $4,660 $3,555 $4,140 2026 $163.50 57 1 $9,320 $6,645 $8,039 2027 $163.50 57 1 $9,320 $6,210 $7,805 2028 $163.50 57 1 $9,320 $5,804 $7,578 2029 $163.50 57 1 $9,320 $5,424 $7,357 2030 $163.50 57 1 $9,320 $5,069 $7,143 2031 $163.50 57 1 $9,320 $4,738 $6,935 2032 $163.50 57 1 $9,320 $4,428 $6,733 2033 $163.50 57 0.5 $4,660 $2,069 $3,268 2034 $163.50 57 0 $0 $0 $0 8 $74,556 $43,941 $58,997

Regulatory Analysis Page A-16 Issue 29: Category 1 Operations - Surface Water Quality Degradation Due to Physical Effects from Operation of Intake and Discharge Structures ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 117 0 $0 $0 $0 2025 $163.50 117 0.5 $9,565 $7,297 $8,498 2026 $163.50 117 1 $19,130 $13,639 $16,501 2027 $163.50 117 1 $19,130 $12,747 $16,021 2028 $163.50 117 1 $19,130 $11,913 $15,554 2029 $163.50 117 1 $19,130 $11,134 $15,101 2030 $163.50 117 1 $19,130 $10,405 $14,661 2031 $163.50 117 1 $19,130 $9,724 $14,234 2032 $163.50 117 1 $19,130 $9,088 $13,820 2033 $163.50 117 0.5 $9,565 $4,247 $6,709 2034 $163.50 117 0 $0 $0 $0 8 $153,036 $90,194 $121,099 Issue 30: Category 1 Operations - Surface Water Quality Degradation Due to Changes in Salinity Gradients Resulting from Withdrawals ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 194 0 $0 $0 $0 2025 $163.50 194 0.5 $15,860 $12,099 $14,091 2026 $163.50 194 1 $31,719 $22,615 $27,361 2027 $163.50 194 1 $31,719 $21,136 $26,564 2028 $163.50 194 1 $31,719 $19,753 $25,790 2029 $163.50 194 1 $31,719 $18,461 $25,039 2030 $163.50 194 1 $31,719 $17,253 $24,310 2031 $163.50 194 1 $31,719 $16,124 $23,602 2032 $163.50 194 1 $31,719 $15,069 $22,914 2033 $163.50 194 0.5 $15,860 $7,042 $11,124 2034 $163.50 194 0 $0 $0 $0 8 $253,752 $149,552 $200,796

Regulatory Analysis Page A-17 Issue 31: Category 1 Operations - Groundwater Quality Degradation Due to Plant Discharges ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 57 0 $0 $0 $0 2025 $163.50 57 0.5 $4,660 $3,555 $4,140 2026 $163.50 57 1 $9,320 $6,645 $8,039 2027 $163.50 57 1 $9,320 $6,210 $7,805 2028 $163.50 57 1 $9,320 $5,804 $7,578 2029 $163.50 57 1 $9,320 $5,424 $7,357 2030 $163.50 57 1 $9,320 $5,069 $7,143 2031 $163.50 57 1 $9,320 $4,738 $6,935 2032 $163.50 57 1 $9,320 $4,428 $6,733 2033 $163.50 57 0.5 $4,660 $2,069 $3,268 2034 $163.50 57 0 $0 $0 $0 8 $74,556 $43,941 $58,997 Issue 32: Category 1 Operations - Water Quality Degradation Due to Inadvertent Spills and Leaks During Operation ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 16 0 $0 $0 $0 2025 $163.50 16 0.5 $1,308 $998 $1,162 2026 $163.50 16 1 $2,616 $1,865 $2,257 2027 $163.50 16 1 $2,616 $1,743 $2,191 2028 $163.50 16 1 $2,616 $1,629 $2,127 2029 $163.50 16 1 $2,616 $1,523 $2,065 2030 $163.50 16 1 $2,616 $1,423 $2,005 2031 $163.50 16 1 $2,616 $1,330 $1,947 2032 $163.50 16 1 $2,616 $1,243 $1,890 2033 $163.50 16 0.5 $1,308 $581 $917 2034 $163.50 16 0 $0 $0 $0 8 $20,928 $12,334 $16,560

Regulatory Analysis Page A-18 Issue 33: Category 1 Operations - Water Quality Degradation Due to Groundwater Withdrawals ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 43 0 $0 $0 $0 2025 $163.50 43 0.5 $3,515 $2,682 $3,123 2026 $163.50 43 1 $7,031 $5,013 $6,065 2027 $163.50 43 1 $7,031 $4,685 $5,888 2028 $163.50 43 1 $7,031 $4,378 $5,716 2029 $163.50 43 1 $7,031 $4,092 $5,550 2030 $163.50 43 1 $7,031 $3,824 $5,388 2031 $163.50 43 1 $7,031 $3,574 $5,231 2032 $163.50 43 1 $7,031 $3,340 $5,079 2033 $163.50 43 0.5 $3,515 $1,561 $2,466 2034 $163.50 43 0 $0 $0 $0 8 $56,244 $33,148 $44,506 Issue 34: Category 1 Operations - Water Use Conflict from Plant Municipal Water Demand ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 16 0 $0 $0 $0 2025 $163.50 16 0.5 $1,308 $998 $1,162 2026 $163.50 16 1 $2,616 $1,865 $2,257 2027 $163.50 16 1 $2,616 $1,743 $2,191 2028 $163.50 16 1 $2,616 $1,629 $2,127 2029 $163.50 16 1 $2,616 $1,523 $2,065 2030 $163.50 16 1 $2,616 $1,423 $2,005 2031 $163.50 16 1 $2,616 $1,330 $1,947 2032 $163.50 16 1 $2,616 $1,243 $1,890 2033 $163.50 16 0.5 $1,308 $581 $917 2034 $163.50 16 0 $0 $0 $0 8 $20,928 $12,334 $16,560

Regulatory Analysis Page A-19 Issue 35: Category 1 Operations - Degradation of Water Quality from Plant Effluent Discharges to Municipal Systems ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 16 0 $0 $0 $0 2025 $163.50 16 0.5 $1,308 $998 $1,162 2026 $163.50 16 1 $2,616 $1,865 $2,257 2027 $163.50 16 1 $2,616 $1,743 $2,191 2028 $163.50 16 1 $2,616 $1,629 $2,127 2029 $163.50 16 1 $2,616 $1,523 $2,065 2030 $163.50 16 1 $2,616 $1,423 $2,005 2031 $163.50 16 1 $2,616 $1,330 $1,947 2032 $163.50 16 1 $2,616 $1,243 $1,890 2033 $163.50 16 0.5 $1,308 $581 $917 2034 $163.50 16 0 $0 $0 $0 8 $20,928 $12,334 $16,560 Issue 36: Category 1 Construction - Permanent and Temporary Loss, Conversion, Fragmentation, and Degradation of Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 168 0 $0 $0 $0 2025 $163.50 168 0.5 $13,734 $10,478 $12,202 2026 $163.50 168 1 $27,468 $19,584 $23,694 2027 $163.50 168 1 $27,468 $18,303 $23,004 2028 $163.50 168 1 $27,468 $17,106 $22,334 2029 $163.50 168 1 $27,468 $15,987 $21,683 2030 $163.50 168 1 $27,468 $14,941 $21,052 2031 $163.50 168 1 $27,468 $13,963 $20,439 2032 $163.50 168 1 $27,468 $13,050 $19,843 2033 $163.50 168 0.5 $13,734 $6,098 $9,633 2034 $163.50 168 0 $0 $0 $0 8 $219,744 $129,509 $173,885

Regulatory Analysis Page A-20 Issue 37: Category 1 Construction - Permanent and Temporary Loss and Degradation of Wetlands ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 168 0 $0 $0 $0 2025 $163.50 168 0.5 $13,734 $10,478 $12,202 2026 $163.50 168 1 $27,468 $19,584 $23,694 2027 $163.50 168 1 $27,468 $18,303 $23,004 2028 $163.50 168 1 $27,468 $17,106 $22,334 2029 $163.50 168 1 $27,468 $15,987 $21,683 2030 $163.50 168 1 $27,468 $14,941 $21,052 2031 $163.50 168 1 $27,468 $13,963 $20,439 2032 $163.50 168 1 $27,468 $13,050 $19,843 2033 $163.50 168 0.5 $13,734 $6,098 $9,633 2034 $163.50 168 0 $0 $0 $0 8 $219,744 $129,509 $173,885 Issue 38: Category 1 Construction - Effects of Building Noise on Wildlife ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 60 0 $0 $0 $0 2025 $163.50 60 0.5 $4,905 $3,742 $4,358 2026 $163.50 60 1 $9,810 $6,994 $8,462 2027 $163.50 60 1 $9,810 $6,537 $8,216 2028 $163.50 60 1 $9,810 $6,109 $7,976 2029 $163.50 60 1 $9,810 $5,710 $7,744 2030 $163.50 60 1 $9,810 $5,336 $7,519 2031 $163.50 60 1 $9,810 $4,987 $7,300 2032 $163.50 60 1 $9,810 $4,661 $7,087 2033 $163.50 60 0.5 $4,905 $2,178 $3,440 2034 $163.50 60 0 $0 $0 $0 8 $78,480 $46,253 $62,102

Regulatory Analysis Page A-21 Issue 39: Category 1 Construction - Effects of Vehicular Collisions on Wildlife ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 50 0 $0 $0 $0 2025 $163.50 50 0.5 $4,088 $3,118 $3,632 2026 $163.50 50 1 $8,175 $5,829 $7,052 2027 $163.50 50 1 $8,175 $5,447 $6,846 2028 $163.50 50 1 $8,175 $5,091 $6,647 2029 $163.50 50 1 $8,175 $4,758 $6,453 2030 $163.50 50 1 $8,175 $4,447 $6,265 2031 $163.50 50 1 $8,175 $4,156 $6,083 2032 $163.50 50 1 $8,175 $3,884 $5,906 2033 $163.50 50 0.5 $4,088 $1,815 $2,867 2034 $163.50 50 0 $0 $0 $0 8 $65,400 $38,544 $51,752 Issue 40: Category 1 Construction - Bird Collisions and Injury from Structures and Transmission Lines ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 60 0 $0 $0 $0 2025 $163.50 60 0.5 $4,905 $3,742 $4,358 2026 $163.50 60 1 $9,810 $6,994 $8,462 2027 $163.50 60 1 $9,810 $6,537 $8,216 2028 $163.50 60 1 $9,810 $6,109 $7,976 2029 $163.50 60 1 $9,810 $5,710 $7,744 2030 $163.50 60 1 $9,810 $5,336 $7,519 2031 $163.50 60 1 $9,810 $4,987 $7,300 2032 $163.50 60 1 $9,810 $4,661 $7,087 2033 $163.50 60 0.5 $4,905 $2,178 $3,440 2034 $163.50 60 0 $0 $0 $0 8 $78,480 $46,253 $62,102

Regulatory Analysis Page A-22 Issue 41: Category 1 Construction - Important Species and Habitats - Other Important Species and Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 84 0 $0 $0 $0 2025 $163.50 84 0.5 $6,867 $5,239 $6,101 2026 $163.50 84 1 $13,734 $9,792 $11,847 2027 $163.50 84 1 $13,734 $9,152 $11,502 2028 $163.50 84 1 $13,734 $8,553 $11,167 2029 $163.50 84 1 $13,734 $7,993 $10,842 2030 $163.50 84 1 $13,734 $7,470 $10,526 2031 $163.50 84 1 $13,734 $6,982 $10,219 2032 $163.50 84 1 $13,734 $6,525 $9,922 2033 $163.50 84 0.5 $6,867 $3,049 $4,816 2034 $163.50 84 0 $0 $0 $0 8 $109,872 $64,755 $86,943 Issue 42: Category 1 Operations - Permanent and Temporary Loss or Disturbance of Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 19 0 $0 $0 $0 2025 $163.50 19 0.5 $1,553 $1,185 $1,380 2026 $163.50 19 1 $3,107 $2,215 $2,680 2027 $163.50 19 1 $3,107 $2,070 $2,602 2028 $163.50 19 1 $3,107 $1,935 $2,526 2029 $163.50 19 1 $3,107 $1,808 $2,452 2030 $163.50 19 1 $3,107 $1,690 $2,381 2031 $163.50 19 1 $3,107 $1,579 $2,312 2032 $163.50 19 1 $3,107 $1,476 $2,244 2033 $163.50 19 0.5 $1,553 $690 $1,089 2034 $163.50 19 0 $0 $0 $0 8 $24,852 $14,647 $19,666

Regulatory Analysis Page A-23 Issue 43: Category 1 Operations - Effects of Operational Noise on Wildlife ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 11 0 $0 $0 $0 2025 $163.50 11 0.5 $899 $686 $799 2026 $163.50 11 1 $1,799 $1,282 $1,551 2027 $163.50 11 1 $1,799 $1,198 $1,506 2028 $163.50 11 1 $1,799 $1,120 $1,462 2029 $163.50 11 1 $1,799 $1,047 $1,420 2030 $163.50 11 1 $1,799 $978 $1,378 2031 $163.50 11 1 $1,799 $914 $1,338 2032 $163.50 11 1 $1,799 $854 $1,299 2033 $163.50 11 0.5 $899 $399 $631 2034 $163.50 11 0 $0 $0 $0 8 $14,388 $8,480 $11,385 Issue 44: Category 1 Operations - Effects of Vehicular Collisions on Wildlife ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 9 0 $0 $0 $0 2025 $163.50 9 0.5 $736 $561 $654 2026 $163.50 9 1 $1,472 $1,049 $1,269 2027 $163.50 9 1 $1,472 $981 $1,232 2028 $163.50 9 1 $1,472 $916 $1,196 2029 $163.50 9 1 $1,472 $856 $1,162 2030 $163.50 9 1 $1,472 $800 $1,128 2031 $163.50 9 1 $1,472 $748 $1,095 2032 $163.50 9 1 $1,472 $699 $1,063 2033 $163.50 9 0.5 $736 $327 $516 2034 $163.50 9 0 $0 $0 $0 8 $11,772 $6,938 $9,315

Regulatory Analysis Page A-24 Issue 45: Category 1 Construction - Exposure of Terrestrial Organisms to Radionuclides ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 38 0 $0 $0 $0 2025 $163.50 38 0.5 $3,107 $2,370 $2,760 2026 $163.50 38 1 $6,213 $4,430 $5,359 2027 $163.50 38 1 $6,213 $4,140 $5,203 2028 $163.50 38 1 $6,213 $3,869 $5,052 2029 $163.50 38 1 $6,213 $3,616 $4,905 2030 $163.50 38 1 $6,213 $3,379 $4,762 2031 $163.50 38 1 $6,213 $3,158 $4,623 2032 $163.50 38 1 $6,213 $2,952 $4,488 2033 $163.50 38 0.5 $3,107 $1,379 $2,179 2034 $163.50 38 0 $0 $0 $0 8 $49,704 $29,294 $39,331 Issue 46: Category 1 Operations - Cooling Tower Operational Impacts on Vegetation ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 37 0 $0 $0 $0 2025 $163.50 37 0.5 $3,025 $2,308 $2,687 2026 $163.50 37 1 $6,050 $4,313 $5,218 2027 $163.50 37 1 $6,050 $4,031 $5,066 2028 $163.50 37 1 $6,050 $3,767 $4,919 2029 $163.50 37 1 $6,050 $3,521 $4,776 2030 $163.50 37 1 $6,050 $3,291 $4,636 2031 $163.50 37 1 $6,050 $3,075 $4,501 2032 $163.50 37 1 $6,050 $2,874 $4,370 2033 $163.50 37 0.5 $3,025 $1,343 $2,121 2034 $163.50 37 0 $0 $0 $0 8 $48,396 $28,523 $38,296

Regulatory Analysis Page A-25 Issue 47: Category 1 Operations - Bird Collisions and Injury from Structures and Transmission Lines ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 19 0 $0 $0 $0 2025 $163.50 19 0.5 $1,553 $1,185 $1,380 2026 $163.50 19 1 $3,107 $2,215 $2,680 2027 $163.50 19 1 $3,107 $2,070 $2,602 2028 $163.50 19 1 $3,107 $1,935 $2,526 2029 $163.50 19 1 $3,107 $1,808 $2,452 2030 $163.50 19 1 $3,107 $1,690 $2,381 2031 $163.50 19 1 $3,107 $1,579 $2,312 2032 $163.50 19 1 $3,107 $1,476 $2,244 2033 $163.50 19 0.5 $1,553 $690 $1,089 2034 $163.50 19 0 $0 $0 $0 8 $24,852 $14,647 $19,666 Issue 48: Category 1 Operations - Bird Electrocutions from Transmission Lines ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 19 0 $0 $0 $0 2025 $163.50 19 0.5 $1,553 $1,185 $1,380 2026 $163.50 19 1 $3,107 $2,215 $2,680 2027 $163.50 19 1 $3,107 $2,070 $2,602 2028 $163.50 19 1 $3,107 $1,935 $2,526 2029 $163.50 19 1 $3,107 $1,808 $2,452 2030 $163.50 19 1 $3,107 $1,690 $2,381 2031 $163.50 19 1 $3,107 $1,579 $2,312 2032 $163.50 19 1 $3,107 $1,476 $2,244 2033 $163.50 19 0.5 $1,553 $690 $1,089 2034 $163.50 19 0 $0 $0 $0 8 $24,852 $14,647 $19,666

Regulatory Analysis Page A-26 Issue 49: Category 1 Operations - Water Use Conflicts with Terrestrial Resources ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 83 0 $0 $0 $0 2025 $163.50 83 0.5 $6,785 $5,176 $6,029 2026 $163.50 83 1 $13,571 $9,676 $11,706 2027 $163.50 83 1 $13,571 $9,043 $11,365 2028 $163.50 83 1 $13,571 $8,451 $11,034 2029 $163.50 83 1 $13,571 $7,898 $10,713 2030 $163.50 83 1 $13,571 $7,381 $10,401 2031 $163.50 83 1 $13,571 $6,899 $10,098 2032 $163.50 83 1 $13,571 $6,447 $9,804 2033 $163.50 83 0.5 $6,785 $3,013 $4,759 2034 $163.50 83 0 $0 $0 $0 8 $108,564 $63,984 $85,907 Issue 50: Category 1 Operations - Effects of Transmission Line ROW Management on Terrestrial Resources ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 23 0 $0 $0 $0 2025 $163.50 23 0.5 $1,880 $1,434 $1,671 2026 $163.50 23 1 $3,761 $2,681 $3,244 2027 $163.50 23 1 $3,761 $2,506 $3,149 2028 $163.50 23 1 $3,761 $2,342 $3,058 2029 $163.50 23 1 $3,761 $2,189 $2,969 2030 $163.50 23 1 $3,761 $2,045 $2,882 2031 $163.50 23 1 $3,761 $1,912 $2,798 2032 $163.50 23 1 $3,761 $1,787 $2,717 2033 $163.50 23 0.5 $1,880 $835 $1,319 2034 $163.50 23 0 $0 $0 $0 8 $30,084 $17,730 $23,806

Regulatory Analysis Page A-27 Issue 51: Category 1 Operations -Effects of Electromagnetic Fields on Flora and Fauna ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 4 0 $0 $0 $0 2025 $163.50 4 0.5 $327 $249 $291 2026 $163.50 4 1 $654 $466 $564 2027 $163.50 4 1 $654 $436 $548 2028 $163.50 4 1 $654 $407 $532 2029 $163.50 4 1 $654 $381 $516 2030 $163.50 4 1 $654 $356 $501 2031 $163.50 4 1 $654 $332 $487 2032 $163.50 4 1 $654 $311 $472 2033 $163.50 4 0.5 $327 $145 $229 2034 $163.50 4 0 $0 $0 $0 8 $5,232 $3,084 $4,140 Issue 52: Category 1 Operations - Important Species and Habitats - Other Important Species and Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 37 0 $0 $0 $0 2025 $163.50 37 0.5 $3,025 $2,308 $2,687 2026 $163.50 37 1 $6,050 $4,313 $5,218 2027 $163.50 37 1 $6,050 $4,031 $5,066 2028 $163.50 37 1 $6,050 $3,767 $4,919 2029 $163.50 37 1 $6,050 $3,521 $4,776 2030 $163.50 37 1 $6,050 $3,291 $4,636 2031 $163.50 37 1 $6,050 $3,075 $4,501 2032 $163.50 37 1 $6,050 $2,874 $4,370 2033 $163.50 37 0.5 $3,025 $1,343 $2,121 2034 $163.50 37 0 $0 $0 $0 8 $48,396 $28,523 $38,296

Regulatory Analysis Page A-28 Issue 53: Category 1 Construction - Runoff and Sedimentation from Construction Areas ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 128 0 $0 $0 $0 2025 $163.50 128 0.5 $10,464 $7,983 $9,297 2026 $163.50 128 1 $20,928 $14,921 $18,053 2027 $163.50 128 1 $20,928 $13,945 $17,527 2028 $163.50 128 1 $20,928 $13,033 $17,016 2029 $163.50 128 1 $20,928 $12,180 $16,521 2030 $163.50 128 1 $20,928 $11,383 $16,040 2031 $163.50 128 1 $20,928 $10,639 $15,572 2032 $163.50 128 1 $20,928 $9,943 $15,119 2033 $163.50 128 0.5 $10,464 $4,646 $7,339 2034 $163.50 128 0 $0 $0 $0 8 $167,424 $98,674 $132,484 Issue 54: Category 1 Construction - Dredging and Filling Aquatic Habitats to Build Intake and Discharge Structures ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 128 0 $0 $0 $0 2025 $163.50 128 0.5 $10,464 $7,983 $9,297 2026 $163.50 128 1 $20,928 $14,921 $18,053 2027 $163.50 128 1 $20,928 $13,945 $17,527 2028 $163.50 128 1 $20,928 $13,033 $17,016 2029 $163.50 128 1 $20,928 $12,180 $16,521 2030 $163.50 128 1 $20,928 $11,383 $16,040 2031 $163.50 128 1 $20,928 $10,639 $15,572 2032 $163.50 128 1 $20,928 $9,943 $15,119 2033 $163.50 128 0.5 $10,464 $4,646 $7,339 2034 $163.50 128 0 $0 $0 $0 8 $167,424 $98,674 $132,484

Regulatory Analysis Page A-29 Issue 55: Category 1 Construction - Building Transmission Lines, Pipelines, and Access Roads Across Surface Waterbodies ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 128 0 $0 $0 $0 2025 $163.50 128 0.5 $10,464 $7,983 $9,297 2026 $163.50 128 1 $20,928 $14,921 $18,053 2027 $163.50 128 1 $20,928 $13,945 $17,527 2028 $163.50 128 1 $20,928 $13,033 $17,016 2029 $163.50 128 1 $20,928 $12,180 $16,521 2030 $163.50 128 1 $20,928 $11,383 $16,040 2031 $163.50 128 1 $20,928 $10,639 $15,572 2032 $163.50 128 1 $20,928 $9,943 $15,119 2033 $163.50 128 0.5 $10,464 $4,646 $7,339 2034 $163.50 128 0 $0 $0 $0 8 $167,424 $98,674 $132,484 Issue 56: Category 1 Operations - Important Species and Habitats - Other Important Species and Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 128 0 $0 $0 $0 2025 $163.50 128 0.5 $10,464 $7,983 $9,297 2026 $163.50 128 1 $20,928 $14,921 $18,053 2027 $163.50 128 1 $20,928 $13,945 $17,527 2028 $163.50 128 1 $20,928 $13,033 $17,016 2029 $163.50 128 1 $20,928 $12,180 $16,521 2030 $163.50 128 1 $20,928 $11,383 $16,040 2031 $163.50 128 1 $20,928 $10,639 $15,572 2032 $163.50 128 1 $20,928 $9,943 $15,119 2033 $163.50 128 0.5 $10,464 $4,646 $7,339 2034 $163.50 128 0 $0 $0 $0 8 $167,424 $98,674 $132,484

Regulatory Analysis Page A-30 Issue 57: Category 1 Operations - Stormwater Runoff ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 20 0 $0 $0 $0 2025 $163.50 20 0.5 $1,635 $1,247 $1,453 2026 $163.50 20 1 $3,270 $2,331 $2,821 2027 $163.50 20 1 $3,270 $2,179 $2,739 2028 $163.50 20 1 $3,270 $2,036 $2,659 2029 $163.50 20 1 $3,270 $1,903 $2,581 2030 $163.50 20 1 $3,270 $1,779 $2,506 2031 $163.50 20 1 $3,270 $1,662 $2,433 2032 $163.50 20 1 $3,270 $1,554 $2,362 2033 $163.50 20 0.5 $1,635 $726 $1,147 2034 $163.50 20 0 $0 $0 $0 8 $26,160 $15,418 $20,701 Issue 58: Category 1 Operations - Exposure of Aquatic Organisms to Radionuclides ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 38 0 $0 $0 $0 2025 $163.50 38 0.5 $3,107 $2,370 $2,760 2026 $163.50 38 1 $6,213 $4,430 $5,359 2027 $163.50 38 1 $6,213 $4,140 $5,203 2028 $163.50 38 1 $6,213 $3,869 $5,052 2029 $163.50 38 1 $6,213 $3,616 $4,905 2030 $163.50 38 1 $6,213 $3,379 $4,762 2031 $163.50 38 1 $6,213 $3,158 $4,623 2032 $163.50 38 1 $6,213 $2,952 $4,488 2033 $163.50 38 0.5 $3,107 $1,379 $2,179 2034 $163.50 38 0 $0 $0 $0 8 $49,704 $29,294 $39,331

Regulatory Analysis Page A-31 Issue 59: Category 1 Operations - Effects of Refurbishment on Aquatic Biota ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 20 0 $0 $0 $0 2025 $163.50 20 0.5 $1,635 $1,247 $1,453 2026 $163.50 20 1 $3,270 $2,331 $2,821 2027 $163.50 20 1 $3,270 $2,179 $2,739 2028 $163.50 20 1 $3,270 $2,036 $2,659 2029 $163.50 20 1 $3,270 $1,903 $2,581 2030 $163.50 20 1 $3,270 $1,779 $2,506 2031 $163.50 20 1 $3,270 $1,662 $2,433 2032 $163.50 20 1 $3,270 $1,554 $2,362 2033 $163.50 20 0.5 $1,635 $726 $1,147 2034 $163.50 20 0 $0 $0 $0 8 $26,160 $15,418 $20,701 Issue 60: Category 1 Operations - Effects of Maintenance Dredging on Aquatic Biota ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 97 0 $0 $0 $0 2025 $163.50 97 0.5 $7,930 $6,050 $7,045 2026 $163.50 97 1 $15,860 $11,308 $13,681 2027 $163.50 97 1 $15,860 $10,568 $13,282 2028 $163.50 97 1 $15,860 $9,876 $12,895 2029 $163.50 97 1 $15,860 $9,230 $12,520 2030 $163.50 97 1 $15,860 $8,627 $12,155 2031 $163.50 97 1 $15,860 $8,062 $11,801 2032 $163.50 97 1 $15,860 $7,535 $11,457 2033 $163.50 97 0.5 $7,930 $3,521 $5,562 2034 $163.50 97 0 $0 $0 $0 8 $126,876 $74,776 $100,398

Regulatory Analysis Page A-32 Issue 61: Category 1 Operations - Impacts of Transmission Line ROW Management on Aquatic Resources ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 48 0 $0 $0 $0 2025 $163.50 48 0.5 $3,924 $2,994 $3,486 2026 $163.50 48 1 $7,848 $5,596 $6,770 2027 $163.50 48 1 $7,848 $5,229 $6,573 2028 $163.50 48 1 $7,848 $4,887 $6,381 2029 $163.50 48 1 $7,848 $4,568 $6,195 2030 $163.50 48 1 $7,848 $4,269 $6,015 2031 $163.50 48 1 $7,848 $3,990 $5,840 2032 $163.50 48 1 $7,848 $3,729 $5,670 2033 $163.50 48 0.5 $3,924 $1,742 $2,752 2034 $163.50 48 0 $0 $0 $0 8 $62,784 $37,003 $49,681 Issue 62: Category 1 Operations - Impingement and Entrainment of Aquatic Organisms ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 145 0 $0 $0 $0 2025 $163.50 145 0.5 $11,854 $9,043 $10,532 2026 $163.50 145 1 $23,708 $16,903 $20,450 2027 $163.50 145 1 $23,708 $15,797 $19,855 2028 $163.50 145 1 $23,708 $14,764 $19,276 2029 $163.50 145 1 $23,708 $13,798 $18,715 2030 $163.50 145 1 $23,708 $12,895 $18,170 2031 $163.50 145 1 $23,708 $12,052 $17,641 2032 $163.50 145 1 $23,708 $11,263 $17,127 2033 $163.50 145 0.5 $11,854 $5,263 $8,314 2034 $163.50 145 0 $0 $0 $0 8 $189,660 $111,779 $150,079

Regulatory Analysis Page A-33 Issue 63: Category 1 Operations - Water Use Conflicts with Aquatic Resources ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 48 0 $0 $0 $0 2025 $163.50 48 0.5 $3,924 $2,994 $3,486 2026 $163.50 48 1 $7,848 $5,596 $6,770 2027 $163.50 48 1 $7,848 $5,229 $6,573 2028 $163.50 48 1 $7,848 $4,887 $6,381 2029 $163.50 48 1 $7,848 $4,568 $6,195 2030 $163.50 48 1 $7,848 $4,269 $6,015 2031 $163.50 48 1 $7,848 $3,990 $5,840 2032 $163.50 48 1 $7,848 $3,729 $5,670 2033 $163.50 48 0.5 $3,924 $1,742 $2,752 2034 $163.50 48 0 $0 $0 $0 8 $62,784 $37,003 $49,681 Issue 64: Category 1 Operations - Important Species and Habitats - Other Important Species and Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 145 0 $0 $0 $0 2025 $163.50 145 0.5 $11,854 $9,043 $10,532 2026 $163.50 145 1 $23,708 $16,903 $20,450 2027 $163.50 145 1 $23,708 $15,797 $19,855 2028 $163.50 145 1 $23,708 $14,764 $19,276 2029 $163.50 145 1 $23,708 $13,798 $18,715 2030 $163.50 145 1 $23,708 $12,895 $18,170 2031 $163.50 145 1 $23,708 $12,052 $17,641 2032 $163.50 145 1 $23,708 $11,263 $17,127 2033 $163.50 145 0.5 $11,854 $5,263 $8,314 2034 $163.50 145 0 $0 $0 $0 8 $189,660 $111,779 $150,079

Regulatory Analysis Page A-34 Issue 65: Category 1 Construction - Radiological Dose to Construction Workers ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 117 0 $0 $0 $0 2025 $163.50 117 0.5 $9,565 $7,297 $8,498 2026 $163.50 117 1 $19,130 $13,639 $16,501 2027 $163.50 117 1 $19,130 $12,747 $16,021 2028 $163.50 117 1 $19,130 $11,913 $15,554 2029 $163.50 117 1 $19,130 $11,134 $15,101 2030 $163.50 117 1 $19,130 $10,405 $14,661 2031 $163.50 117 1 $19,130 $9,724 $14,234 2032 $163.50 117 1 $19,130 $9,088 $13,820 2033 $163.50 117 0.5 $9,565 $4,247 $6,709 2034 $163.50 117 0 $0 $0 $0 8 $153,036 $90,194 $121,099 Issue 66: Category 1 Operations - Occupational Doses to Workers ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 38 0 $0 $0 $0 2025 $163.50 38 0.5 $3,107 $2,370 $2,760 2026 $163.50 38 1 $6,213 $4,430 $5,359 2027 $163.50 38 1 $6,213 $4,140 $5,203 2028 $163.50 38 1 $6,213 $3,869 $5,052 2029 $163.50 38 1 $6,213 $3,616 $4,905 2030 $163.50 38 1 $6,213 $3,379 $4,762 2031 $163.50 38 1 $6,213 $3,158 $4,623 2032 $163.50 38 1 $6,213 $2,952 $4,488 2033 $163.50 38 0.5 $3,107 $1,379 $2,179 2034 $163.50 38 0 $0 $0 $0 8 $49,704 $29,294 $39,331

Regulatory Analysis Page A-35 Issue 67: Category 1 Operations - Maximally Exposed Individual Annual Doses ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 38 0 $0 $0 $0 2025 $163.50 38 0.5 $3,107 $2,370 $2,760 2026 $163.50 38 1 $6,213 $4,430 $5,359 2027 $163.50 38 1 $6,213 $4,140 $5,203 2028 $163.50 38 1 $6,213 $3,869 $5,052 2029 $163.50 38 1 $6,213 $3,616 $4,905 2030 $163.50 38 1 $6,213 $3,379 $4,762 2031 $163.50 38 1 $6,213 $3,158 $4,623 2032 $163.50 38 1 $6,213 $2,952 $4,488 2033 $163.50 38 0.5 $3,107 $1,379 $2,179 2034 $163.50 38 0 $0 $0 $0 8 $49,704 $29,294 $39,331 Issue 68: Category 1 Operations - Total Population Annual Doses ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 42 0 $0 $0 $0 2025 $163.50 42 0.5 $3,434 $2,619 $3,051 2026 $163.50 42 1 $6,867 $4,896 $5,924 2027 $163.50 42 1 $6,867 $4,576 $5,751 2028 $163.50 42 1 $6,867 $4,276 $5,583 2029 $163.50 42 1 $6,867 $3,997 $5,421 2030 $163.50 42 1 $6,867 $3,735 $5,263 2031 $163.50 42 1 $6,867 $3,491 $5,110 2032 $163.50 42 1 $6,867 $3,262 $4,961 2033 $163.50 42 0.5 $3,434 $1,525 $2,408 2034 $163.50 42 0 $0 $0 $0 8 $54,936 $32,377 $43,471

Regulatory Analysis Page A-36 Issue 69: Category 1 Operations - Nonhuman Biota Doses ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 42 0 $0 $0 $0 2025 $163.50 42 0.5 $3,434 $2,619 $3,051 2026 $163.50 42 1 $6,867 $4,896 $5,924 2027 $163.50 42 1 $6,867 $4,576 $5,751 2028 $163.50 42 1 $6,867 $4,276 $5,583 2029 $163.50 42 1 $6,867 $3,997 $5,421 2030 $163.50 42 1 $6,867 $3,735 $5,263 2031 $163.50 42 1 $6,867 $3,491 $5,110 2032 $163.50 42 1 $6,867 $3,262 $4,961 2033 $163.50 42 0.5 $3,434 $1,525 $2,408 2034 $163.50 42 0 $0 $0 $0 8 $54,936 $32,377 $43,471 Issue 70: Category 1 Construction - Building Impacts of Chemical, Biological, and Physical Nonradiological Hazards ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 52 0 $0 $0 $0 2025 $163.50 52 0.5 $4,251 $3,243 $3,777 2026 $163.50 52 1 $8,502 $6,062 $7,334 2027 $163.50 52 1 $8,502 $5,665 $7,120 2028 $163.50 52 1 $8,502 $5,295 $6,913 2029 $163.50 52 1 $8,502 $4,948 $6,712 2030 $163.50 52 1 $8,502 $4,625 $6,516 2031 $163.50 52 1 $8,502 $4,322 $6,326 2032 $163.50 52 1 $8,502 $4,039 $6,142 2033 $163.50 52 0.5 $4,251 $1,887 $2,982 2034 $163.50 52 0 $0 $0 $0 8 $68,016 $40,086 $53,822

Regulatory Analysis Page A-37 Issue 71: Category 1 Operations - Operation Impacts of Chemical, Biological, and Physical Nonradiological Hazards ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 35 0 $0 $0 $0 2025 $163.50 35 0.5 $2,861 $2,183 $2,542 2026 $163.50 35 1 $5,723 $4,080 $4,936 2027 $163.50 35 1 $5,723 $3,813 $4,793 2028 $163.50 35 1 $5,723 $3,564 $4,653 2029 $163.50 35 1 $5,723 $3,331 $4,517 2030 $163.50 35 1 $5,723 $3,113 $4,386 2031 $163.50 35 1 $5,723 $2,909 $4,258 2032 $163.50 35 1 $5,723 $2,719 $4,134 2033 $163.50 35 0.5 $2,861 $1,270 $2,007 2034 $163.50 35 0 $0 $0 $0 8 $45,780 $26,981 $36,226 Issue 72: Category 1 Construction - Construction-Related Noise ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 23 0 $0 $0 $0 2025 $163.50 23 0.5 $1,880 $1,434 $1,671 2026 $163.50 23 1 $3,761 $2,681 $3,244 2027 $163.50 23 1 $3,761 $2,506 $3,149 2028 $163.50 23 1 $3,761 $2,342 $3,058 2029 $163.50 23 1 $3,761 $2,189 $2,969 2030 $163.50 23 1 $3,761 $2,045 $2,882 2031 $163.50 23 1 $3,761 $1,912 $2,798 2032 $163.50 23 1 $3,761 $1,787 $2,717 2033 $163.50 23 0.5 $1,880 $835 $1,319 2034 $163.50 23 0 $0 $0 $0 8 $30,084 $17,730 $23,806

Regulatory Analysis Page A-38 Issue 73: Category 1 Operations - Operation-Related Noise ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 14 0 $0 $0 $0 2025 $163.50 14 0.5 $1,145 $873 $1,017 2026 $163.50 14 1 $2,289 $1,632 $1,975 2027 $163.50 14 1 $2,289 $1,525 $1,917 2028 $163.50 14 1 $2,289 $1,425 $1,861 2029 $163.50 14 1 $2,289 $1,332 $1,807 2030 $163.50 14 1 $2,289 $1,245 $1,754 2031 $163.50 14 1 $2,289 $1,164 $1,703 2032 $163.50 14 1 $2,289 $1,087 $1,654 2033 $163.50 14 0.5 $1,145 $508 $803 2034 $163.50 14 0 $0 $0 $0 8 $18,312 $10,792 $14,490 Issue 74: Category 1 Operations - Low-Level Radioactive Waste ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 232 0 $0 $0 $0 2025 $163.50 232 0.5 $18,966 $14,469 $16,851 2026 $163.50 232 1 $37,932 $27,045 $32,720 2027 $163.50 232 1 $37,932 $25,276 $31,767 2028 $163.50 232 1 $37,932 $23,622 $30,842 2029 $163.50 232 1 $37,932 $22,077 $29,944 2030 $163.50 232 1 $37,932 $20,632 $29,072 2031 $163.50 232 1 $37,932 $19,283 $28,225 2032 $163.50 232 1 $37,932 $18,021 $27,403 2033 $163.50 232 0.5 $18,966 $8,421 $13,302 2034 $163.50 232 0 $0 $0 $0 8 $303,456 $178,846 $240,127

Regulatory Analysis Page A-39 Issue 75: Category 1 Operations - Onsite Spent Nuclear Fuel Management ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 232 0 $0 $0 $0 2025 $163.50 232 0.5 $18,966 $14,469 $16,851 2026 $163.50 232 1 $37,932 $27,045 $32,720 2027 $163.50 232 1 $37,932 $25,276 $31,767 2028 $163.50 232 1 $37,932 $23,622 $30,842 2029 $163.50 232 1 $37,932 $22,077 $29,944 2030 $163.50 232 1 $37,932 $20,632 $29,072 2031 $163.50 232 1 $37,932 $19,283 $28,225 2032 $163.50 232 1 $37,932 $18,021 $27,403 2033 $163.50 232 0.5 $18,966 $8,421 $13,302 2034 $163.50 232 0 $0 $0 $0 8 $303,456 $178,846 $240,127 Issue 76: Category 1 Operations - Mixed Waste ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 232 0 $0 $0 $0 2025 $163.50 232 0.5 $18,966 $14,469 $16,851 2026 $163.50 232 1 $37,932 $27,045 $32,720 2027 $163.50 232 1 $37,932 $25,276 $31,767 2028 $163.50 232 1 $37,932 $23,622 $30,842 2029 $163.50 232 1 $37,932 $22,077 $29,944 2030 $163.50 232 1 $37,932 $20,632 $29,072 2031 $163.50 232 1 $37,932 $19,283 $28,225 2032 $163.50 232 1 $37,932 $18,021 $27,403 2033 $163.50 232 0.5 $18,966 $8,421 $13,302 2034 $163.50 232 0 $0 $0 $0 8 $303,456 $178,846 $240,127

Regulatory Analysis Page A-40 Issue 77: Category 1 Construction - Construction Nonradiological Waste ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 38 0 $0 $0 $0 2025 $163.50 38 0.5 $3,107 $2,370 $2,760 2026 $163.50 38 1 $6,213 $4,430 $5,359 2027 $163.50 38 1 $6,213 $4,140 $5,203 2028 $163.50 38 1 $6,213 $3,869 $5,052 2029 $163.50 38 1 $6,213 $3,616 $4,905 2030 $163.50 38 1 $6,213 $3,379 $4,762 2031 $163.50 38 1 $6,213 $3,158 $4,623 2032 $163.50 38 1 $6,213 $2,952 $4,488 2033 $163.50 38 0.5 $3,107 $1,379 $2,179 2034 $163.50 38 0 $0 $0 $0 8 $49,704 $29,294 $39,331 Issue 78: Category 1 Operations - Operation Nonradiological Waste ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 25 0 $0 $0 $0 2025 $163.50 25 0.5 $2,044 $1,559 $1,816 2026 $163.50 25 1 $4,088 $2,914 $3,526 2027 $163.50 25 1 $4,088 $2,724 $3,423 2028 $163.50 25 1 $4,088 $2,545 $3,324 2029 $163.50 25 1 $4,088 $2,379 $3,227 2030 $163.50 25 1 $4,088 $2,223 $3,133 2031 $163.50 25 1 $4,088 $2,078 $3,041 2032 $163.50 25 1 $4,088 $1,942 $2,953 2033 $163.50 25 0.5 $2,044 $907 $1,433 2034 $163.50 25 0 $0 $0 $0 8 $32,700 $19,272 $25,876

Regulatory Analysis Page A-41 Issue 79: Category 1 Operations - Design Basis Accidents Involving Radiological Releases ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 172 0 $0 $0 $0 2025 $163.50 172 0.5 $14,061 $10,727 $12,493 2026 $163.50 172 1 $28,122 $20,051 $24,258 2027 $163.50 172 1 $28,122 $18,739 $23,552 2028 $163.50 172 1 $28,122 $17,513 $22,866 2029 $163.50 172 1 $28,122 $16,367 $22,200 2030 $163.50 172 1 $28,122 $15,297 $21,553 2031 $163.50 172 1 $28,122 $14,296 $20,925 2032 $163.50 172 1 $28,122 $13,361 $20,316 2033 $163.50 172 0.5 $14,061 $6,243 $9,862 2034 $163.50 172 0 $0 $0 $0 8 $224,976 $132,593 $178,025 Issue 80: Category 1 Operations - Accidents Involving Releases of Hazardous Chemicals ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 103 0 $0 $0 $0 2025 $163.50 103 0.5 $8,420 $6,424 $7,481 2026 $163.50 103 1 $16,841 $12,007 $14,527 2027 $163.50 103 1 $16,841 $11,222 $14,104 2028 $163.50 103 1 $16,841 $10,487 $13,693 2029 $163.50 103 1 $16,841 $9,801 $13,294 2030 $163.50 103 1 $16,841 $9,160 $12,907 2031 $163.50 103 1 $16,841 $8,561 $12,531 2032 $163.50 103 1 $16,841 $8,001 $12,166 2033 $163.50 103 0.5 $8,420 $3,739 $5,906 2034 $163.50 103 0 $0 $0 $0 8 $134,724 $79,402 $106,608

Regulatory Analysis Page A-42 Issue 81: Category 1 Operations - Severe Accident Mitigation Design Alternatives ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 69 0 $0 $0 $0 2025 $163.50 69 0.5 $5,641 $4,303 $5,012 2026 $163.50 69 1 $11,282 $8,044 $9,732 2027 $163.50 69 1 $11,282 $7,517 $9,448 2028 $163.50 69 1 $11,282 $7,026 $9,173 2029 $163.50 69 1 $11,282 $6,566 $8,906 2030 $163.50 69 1 $11,282 $6,136 $8,646 2031 $163.50 69 1 $11,282 $5,735 $8,394 2032 $163.50 69 1 $11,282 $5,360 $8,150 2033 $163.50 69 0.5 $5,641 $2,505 $3,956 2034 $163.50 69 0 $0 $0 $0 8 $90,252 $53,191 $71,417 Issue 82: Category 1 Operations - Acts of Terrorism ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 69 0 $0 $0 $0 2025 $163.50 69 0.5 $5,641 $4,303 $5,012 2026 $163.50 69 1 $11,282 $8,044 $9,732 2027 $163.50 69 1 $11,282 $7,517 $9,448 2028 $163.50 69 1 $11,282 $7,026 $9,173 2029 $163.50 69 1 $11,282 $6,566 $8,906 2030 $163.50 69 1 $11,282 $6,136 $8,646 2031 $163.50 69 1 $11,282 $5,735 $8,394 2032 $163.50 69 1 $11,282 $5,360 $8,150 2033 $163.50 69 0.5 $5,641 $2,505 $3,956 2034 $163.50 69 0 $0 $0 $0 8 $90,252 $53,191 $71,417

Regulatory Analysis Page A-43 Issue 83: Category 1 Construction - Community Services and Infrastructure ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 74 0 $0 $0 $0 2025 $163.50 74 0.5 $6,050 $4,615 $5,375 2026 $163.50 74 1 $12,099 $8,626 $10,437 2027 $163.50 74 1 $12,099 $8,062 $10,133 2028 $163.50 74 1 $12,099 $7,535 $9,838 2029 $163.50 74 1 $12,099 $7,042 $9,551 2030 $163.50 74 1 $12,099 $6,581 $9,273 2031 $163.50 74 1 $12,099 $6,151 $9,003 2032 $163.50 74 1 $12,099 $5,748 $8,741 2033 $163.50 74 0.5 $6,050 $2,686 $4,243 2034 $163.50 74 0 $0 $0 $0 8 $96,792 $57,046 $76,592 Issue 84: Category 1 Construction - Transportation Systems and Traffic ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 147 0 $0 $0 $0 2025 $163.50 147 0.5 $12,017 $9,168 $10,677 2026 $163.50 147 1 $24,035 $17,136 $20,732 2027 $163.50 147 1 $24,035 $16,015 $20,129 2028 $163.50 147 1 $24,035 $14,967 $19,542 2029 $163.50 147 1 $24,035 $13,988 $18,973 2030 $163.50 147 1 $24,035 $13,073 $18,420 2031 $163.50 147 1 $24,035 $12,218 $17,884 2032 $163.50 147 1 $24,035 $11,419 $17,363 2033 $163.50 147 0.5 $12,017 $5,336 $8,429 2034 $163.50 147 0 $0 $0 $0 8 $192,276 $113,321 $152,149

Regulatory Analysis Page A-44 Issue 85: Category 1 Construction - Economic Impacts ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 74 0 $0 $0 $0 2025 $163.50 74 0.5 $6,050 $4,615 $5,375 2026 $163.50 74 1 $12,099 $8,626 $10,437 2027 $163.50 74 1 $12,099 $8,062 $10,133 2028 $163.50 74 1 $12,099 $7,535 $9,838 2029 $163.50 74 1 $12,099 $7,042 $9,551 2030 $163.50 74 1 $12,099 $6,581 $9,273 2031 $163.50 74 1 $12,099 $6,151 $9,003 2032 $163.50 74 1 $12,099 $5,748 $8,741 2033 $163.50 74 0.5 $6,050 $2,686 $4,243 2034 $163.50 74 0 $0 $0 $0 8 $96,792 $57,046 $76,592 Issue 86: Category 1 Construction - Tax Revenue Impacts ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 42 0 $0 $0 $0 2025 $163.50 42 0.5 $3,434 $2,619 $3,051 2026 $163.50 42 1 $6,867 $4,896 $5,924 2027 $163.50 42 1 $6,867 $4,576 $5,751 2028 $163.50 42 1 $6,867 $4,276 $5,583 2029 $163.50 42 1 $6,867 $3,997 $5,421 2030 $163.50 42 1 $6,867 $3,735 $5,263 2031 $163.50 42 1 $6,867 $3,491 $5,110 2032 $163.50 42 1 $6,867 $3,262 $4,961 2033 $163.50 42 0.5 $3,434 $1,525 $2,408 2034 $163.50 42 0 $0 $0 $0 8 $54,936 $32,377 $43,471

Regulatory Analysis Page A-45 Issue 87: Category 1 Operations - Community Services and Infrastructure ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 50 0 $0 $0 $0 2025 $163.50 50 0.5 $4,088 $3,118 $3,632 2026 $163.50 50 1 $8,175 $5,829 $7,052 2027 $163.50 50 1 $8,175 $5,447 $6,846 2028 $163.50 50 1 $8,175 $5,091 $6,647 2029 $163.50 50 1 $8,175 $4,758 $6,453 2030 $163.50 50 1 $8,175 $4,447 $6,265 2031 $163.50 50 1 $8,175 $4,156 $6,083 2032 $163.50 50 1 $8,175 $3,884 $5,906 2033 $163.50 50 0.5 $4,088 $1,815 $2,867 2034 $163.50 50 0 $0 $0 $0 8 $65,400 $38,544 $51,752 Issue 88: Category 1 Operations - Transportation Systems and Traffic ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 25 0 $0 $0 $0 2025 $163.50 25 0.5 $2,044 $1,559 $1,816 2026 $163.50 25 1 $4,088 $2,914 $3,526 2027 $163.50 25 1 $4,088 $2,724 $3,423 2028 $163.50 25 1 $4,088 $2,545 $3,324 2029 $163.50 25 1 $4,088 $2,379 $3,227 2030 $163.50 25 1 $4,088 $2,223 $3,133 2031 $163.50 25 1 $4,088 $2,078 $3,041 2032 $163.50 25 1 $4,088 $1,942 $2,953 2033 $163.50 25 0.5 $2,044 $907 $1,433 2034 $163.50 25 0 $0 $0 $0 8 $32,700 $19,272 $25,876

Regulatory Analysis Page A-46 Issue 89: Category 1 Operations - Economic Impacts ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 50 0 $0 $0 $0 2025 $163.50 50 0.5 $4,088 $3,118 $3,632 2026 $163.50 50 1 $8,175 $5,829 $7,052 2027 $163.50 50 1 $8,175 $5,447 $6,846 2028 $163.50 50 1 $8,175 $5,091 $6,647 2029 $163.50 50 1 $8,175 $4,758 $6,453 2030 $163.50 50 1 $8,175 $4,447 $6,265 2031 $163.50 50 1 $8,175 $4,156 $6,083 2032 $163.50 50 1 $8,175 $3,884 $5,906 2033 $163.50 50 0.5 $4,088 $1,815 $2,867 2034 $163.50 50 0 $0 $0 $0 8 $65,400 $38,544 $51,752 Issue 90: Category 1 Operations - Tax Revenue Impacts ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 98 0 $0 $0 $0 2025 $163.50 98 0.5 $8,012 $6,112 $7,118 2026 $163.50 98 1 $16,023 $11,424 $13,822 2027 $163.50 98 1 $16,023 $10,677 $13,419 2028 $163.50 98 1 $16,023 $9,978 $13,028 2029 $163.50 98 1 $16,023 $9,326 $12,649 2030 $163.50 98 1 $16,023 $8,715 $12,280 2031 $163.50 98 1 $16,023 $8,145 $11,923 2032 $163.50 98 1 $16,023 $7,612 $11,575 2033 $163.50 98 0.5 $8,012 $3,557 $5,619 2034 $163.50 98 0 $0 $0 $0 8 $128,184 $75,547 $101,433

Regulatory Analysis Page A-47 Issue 91: Category 1 Operations - Uranium Recovery ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 39 0 $0 $0 $0 2025 $163.50 39 0.5 $3,188 $2,432 $2,833 2026 $163.50 39 1 $6,377 $4,546 $5,500 2027 $163.50 39 1 $6,377 $4,249 $5,340 2028 $163.50 39 1 $6,377 $3,971 $5,185 2029 $163.50 39 1 $6,377 $3,711 $5,034 2030 $163.50 39 1 $6,377 $3,468 $4,887 2031 $163.50 39 1 $6,377 $3,241 $4,745 2032 $163.50 39 1 $6,377 $3,029 $4,607 2033 $163.50 39 0.5 $3,188 $1,416 $2,236 2034 $163.50 39 0 $0 $0 $0 8 $51,012 $30,065 $40,366 Issue 92: Category 1 Operations - Uranium Conversion ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 39 0 $0 $0 $0 2025 $163.50 39 0.5 $3,188 $2,432 $2,833 2026 $163.50 39 1 $6,377 $4,546 $5,500 2027 $163.50 39 1 $6,377 $4,249 $5,340 2028 $163.50 39 1 $6,377 $3,971 $5,185 2029 $163.50 39 1 $6,377 $3,711 $5,034 2030 $163.50 39 1 $6,377 $3,468 $4,887 2031 $163.50 39 1 $6,377 $3,241 $4,745 2032 $163.50 39 1 $6,377 $3,029 $4,607 2033 $163.50 39 0.5 $3,188 $1,416 $2,236 2034 $163.50 39 0 $0 $0 $0 8 $51,012 $30,065 $40,366

Regulatory Analysis Page A-48 Issue 93: Category 1 Operations - Enrichment ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 39 0 $0 $0 $0 2025 $163.50 39 0.5 $3,188 $2,432 $2,833 2026 $163.50 39 1 $6,377 $4,546 $5,500 2027 $163.50 39 1 $6,377 $4,249 $5,340 2028 $163.50 39 1 $6,377 $3,971 $5,185 2029 $163.50 39 1 $6,377 $3,711 $5,034 2030 $163.50 39 1 $6,377 $3,468 $4,887 2031 $163.50 39 1 $6,377 $3,241 $4,745 2032 $163.50 39 1 $6,377 $3,029 $4,607 2033 $163.50 39 0.5 $3,188 $1,416 $2,236 2034 $163.50 39 0 $0 $0 $0 8 $51,012 $30,065 $40,366 Issue 94: Category 1 Operations - Fuel Fabrication ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 39 0 $0 $0 $0 2025 $163.50 39 0.5 $3,188 $2,432 $2,833 2026 $163.50 39 1 $6,377 $4,546 $5,500 2027 $163.50 39 1 $6,377 $4,249 $5,340 2028 $163.50 39 1 $6,377 $3,971 $5,185 2029 $163.50 39 1 $6,377 $3,711 $5,034 2030 $163.50 39 1 $6,377 $3,468 $4,887 2031 $163.50 39 1 $6,377 $3,241 $4,745 2032 $163.50 39 1 $6,377 $3,029 $4,607 2033 $163.50 39 0.5 $3,188 $1,416 $2,236 2034 $163.50 39 0 $0 $0 $0 8 $51,012 $30,065 $40,366

Regulatory Analysis Page A-49 Issue 95: Category 1 Operations - Reprocessing ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 39 0 $0 $0 $0 2025 $163.50 39 0.5 $3,188 $2,432 $2,833 2026 $163.50 39 1 $6,377 $4,546 $5,500 2027 $163.50 39 1 $6,377 $4,249 $5,340 2028 $163.50 39 1 $6,377 $3,971 $5,185 2029 $163.50 39 1 $6,377 $3,711 $5,034 2030 $163.50 39 1 $6,377 $3,468 $4,887 2031 $163.50 39 1 $6,377 $3,241 $4,745 2032 $163.50 39 1 $6,377 $3,029 $4,607 2033 $163.50 39 0.5 $3,188 $1,416 $2,236 2034 $163.50 39 0 $0 $0 $0 8 $51,012 $30,065 $40,366 Issue 96: Category 1 Operations - Storage and Disposal of Radiological Wastes ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 39 0 $0 $0 $0 2025 $163.50 39 0.5 $3,188 $2,432 $2,833 2026 $163.50 39 1 $6,377 $4,546 $5,500 2027 $163.50 39 1 $6,377 $4,249 $5,340 2028 $163.50 39 1 $6,377 $3,971 $5,185 2029 $163.50 39 1 $6,377 $3,711 $5,034 2030 $163.50 39 1 $6,377 $3,468 $4,887 2031 $163.50 39 1 $6,377 $3,241 $4,745 2032 $163.50 39 1 $6,377 $3,029 $4,607 2033 $163.50 39 0.5 $3,188 $1,416 $2,236 2034 $163.50 39 0 $0 $0 $0 8 $51,012 $30,065 $40,366

Regulatory Analysis Page A-50 Issue 97: Category 1 Operations - Transportation of Unirradiated ANR Fuel ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 78 0 $0 $0 $0 2025 $163.50 78 0.5 $6,377 $4,865 $5,665 2026 $163.50 78 1 $12,753 $9,093 $11,001 2027 $163.50 78 1 $12,753 $8,498 $10,680 2028 $163.50 78 1 $12,753 $7,942 $10,369 2029 $163.50 78 1 $12,753 $7,422 $10,067 2030 $163.50 78 1 $12,753 $6,937 $9,774 2031 $163.50 78 1 $12,753 $6,483 $9,489 2032 $163.50 78 1 $12,753 $6,059 $9,213 2033 $163.50 78 0.5 $6,377 $2,831 $4,472 2034 $163.50 78 0 $0 $0 $0 8 $102,024 $60,129 $80,732 Issue 98: Category 1 Operations - Transportation of Radioactive Waste from ANRs ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 78 0 $0 $0 $0 2025 $163.50 78 0.5 $6,377 $4,865 $5,665 2026 $163.50 78 1 $12,753 $9,093 $11,001 2027 $163.50 78 1 $12,753 $8,498 $10,680 2028 $163.50 78 1 $12,753 $7,942 $10,369 2029 $163.50 78 1 $12,753 $7,422 $10,067 2030 $163.50 78 1 $12,753 $6,937 $9,774 2031 $163.50 78 1 $12,753 $6,483 $9,489 2032 $163.50 78 1 $12,753 $6,059 $9,213 2033 $163.50 78 0.5 $6,377 $2,831 $4,472 2034 $163.50 78 0 $0 $0 $0 8 $102,024 $60,129 $80,732

Regulatory Analysis Page A-51 Issue 99: Category 1 Operations - Transportation of Irradiated Fuel from ANRs ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 155 0 $0 $0 $0 2025 $163.50 155 0.5 $12,671 $9,667 $11,258 2026 $163.50 155 1 $25,343 $18,069 $21,861 2027 $163.50 155 1 $25,343 $16,887 $21,224 2028 $163.50 155 1 $25,343 $15,782 $20,606 2029 $163.50 155 1 $25,343 $14,750 $20,006 2030 $163.50 155 1 $25,343 $13,785 $19,423 2031 $163.50 155 1 $25,343 $12,883 $18,857 2032 $163.50 155 1 $25,343 $12,040 $18,308 2033 $163.50 155 0.5 $12,671 $5,626 $8,887 2034 $163.50 155 0 $0 $0 $0 8 $202,740 $119,488 $160,430 Issue 100: Decommissioning ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $163.50 81 0 $0 $0 $0 2025 $163.50 81 0.5 $6,622 $5,052 $5,883 2026 $163.50 81 1 $13,244 $9,442 $11,424 2027 $163.50 81 1 $13,244 $8,825 $11,091 2028 $163.50 81 1 $13,244 $8,247 $10,768 2029 $163.50 81 1 $13,244 $7,708 $10,455 2030 $163.50 81 1 $13,244 $7,204 $10,150 2031 $163.50 81 1 $13,244 $6,732 $9,854 2032 $163.50 81 1 $13,244 $6,292 $9,567 2033 $163.50 81 0.5 $6,622 $2,940 $4,644 2034 $163.50 81 0 $0 $0 $0 8 $105,948 $62,442 $83,837 Table A-2 presents savings realized by NRC for each Category 1 issue covered by the proposed rule. NRC operations under the proposed rule would be somewhat lagged compared to industry to account for the period industry would need to generate and submit each application. Therefore, the NRC assumes that half of the needed environmental review would occur during the same year that industry submits an application, and the other half of the review could be completed in the year following application submittal by industry. The effect of this assumption is that while during the proposed rule analysis period (2024-2034) industry is assumed to submit eight ANR applications, during that same period NRC would

Regulatory Analysis Page A-52 be assumed to complete eight application reviews.

The results presented in Table A-2 reflect the following input variables (Section 3.3.4 provides more detailed discussion):

Labor Rate: The NRC labor rate was assumed to be the weighted average between the NRC labor rate of $137/hour and the NRC contractor labor rate of $190/hour, weighted by the relative effort between NRC staff and NRC contractor staff per ANR application review.

This weighed average equates to $168/hour.

Hours per Application: For each Category 1 issue, the NRC estimated the hours saved by utilizing the generic impact analysis findings in the ANR GEIS. These impacts are a one-time realization of review effort savings per application realized when the application review is completed by NRC staff and NRC contractor staff and the licensing decision is rendered by the Commission.

ANR Applications per Year: As discussed above and in Section 3.3.4, this represents the NRCs assumed number of ANR applications utilizing the provisions of the proposed rule.

The values reported in Table A-2 roll up to the totals presented in Table 3-3.

Table A-1 Summary of Proposed Rule Savings Benefits to the NRC by Category 1 Issue (2021 Constant Dollars)

Issue 1: Category 1 Construction - Onsite Land Use ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 82 0 $0 $0 $0 2025 $168 82 0 $0 $0 $0 2026 $168 82 0.5 $6,888 $4,911 $5,942 2027 $168 82 1 $13,776 $9,180 $11,537 2028 $168 82 1 $13,776 $8,579 $11,201 2029 $168 82 1 $13,776 $8,018 $10,875 2030 $168 82 1 $13,776 $7,493 $10,558 2031 $168 82 1 $13,776 $7,003 $10,251 2032 $168 82 1 $13,776 $6,545 $9,952 2033 $168 82 1 $13,776 $6,117 $9,662 2034 $168 82 0.5 $6,888 $2,858 $4,690 8 $110,208 $60,703 $84,668

Regulatory Analysis Page A-53 Issue 2: Category 1 Construction - Offsite Land Use ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 135 0 $0 $0 $0 2025 $168 135 0 $0 $0 $0 2026 $168 135 0.5 $11,340 $8,085 $9,782 2027 $168 135 1 $22,680 $15,113 $18,994 2028 $168 135 1 $22,680 $14,124 $18,441 2029 $168 135 1 $22,680 $13,200 $17,904 2030 $168 135 1 $22,680 $12,336 $17,382 2031 $168 135 1 $22,680 $11,529 $16,876 2032 $168 135 1 $22,680 $10,775 $16,385 2033 $168 135 1 $22,680 $10,070 $15,907 2034 $168 135 0.5 $11,340 $4,706 $7,722 8 $181,440 $99,939 $139,393 Issue 3: Category 1 Construction - Impacts on Prime and Unique Farmland ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 23 0 $0 $0 $0 2025 $168 23 0 $0 $0 $0 2026 $168 23 0.5 $1,932 $1,377 $1,667 2027 $168 23 1 $3,864 $2,575 $3,236 2028 $168 23 1 $3,864 $2,406 $3,142 2029 $168 23 1 $3,864 $2,249 $3,050 2030 $168 23 1 $3,864 $2,102 $2,961 2031 $168 23 1 $3,864 $1,964 $2,875 2032 $168 23 1 $3,864 $1,836 $2,791 2033 $168 23 1 $3,864 $1,716 $2,710 2034 $168 23 0.5 $1,932 $802 $1,316 8 $30,912 $17,027 $23,748

Regulatory Analysis Page A-54 Issue 4: Category 1 Construction - Coastal Zone and Compliance with The Coastal Zone Management Act ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 9 0 $0 $0 $0 2025 $168 9 0 $0 $0 $0 2026 $168 9 0.5 $756 $539 $652 2027 $168 9 1 $1,512 $1,008 $1,266 2028 $168 9 1 $1,512 $942 $1,229 2029 $168 9 1 $1,512 $880 $1,194 2030 $168 9 1 $1,512 $822 $1,159 2031 $168 9 1 $1,512 $769 $1,125 2032 $168 9 1 $1,512 $718 $1,092 2033 $168 9 1 $1,512 $671 $1,060 2034 $168 9 0.5 $756 $314 $515 8 $12,096 $6,663 $9,293 Issue 5: Category 1 Operations - Onsite Land Use NRC Year Labor Hours per Reviews per Undiscounted 7% NPV 3% NPV Rate Application Year 2024 $168 24 0 $0 $0 $0 2025 $168 24 0 $0 $0 $0 2026 $168 24 0.5 $2,016 $1,437 $1,739 2027 $168 24 1 $4,032 $2,687 $3,377 2028 $168 24 1 $4,032 $2,511 $3,278 2029 $168 24 1 $4,032 $2,347 $3,183 2030 $168 24 1 $4,032 $2,193 $3,090 2031 $168 24 1 $4,032 $2,050 $3,000 2032 $168 24 1 $4,032 $1,916 $2,913 2033 $168 24 1 $4,032 $1,790 $2,828 2034 $168 24 0.5 $2,016 $837 $1,373 8 $32,256 $17,767 $24,781

Regulatory Analysis Page A-55 Issue 6: Category 1 Operations - Offsite Land Use ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 28 0 $0 $0 $0 2025 $168 28 0 $0 $0 $0 2026 $168 28 0.5 $2,352 $1,677 $2,029 2027 $168 28 1 $4,704 $3,134 $3,940 2028 $168 28 1 $4,704 $2,929 $3,825 2029 $168 28 1 $4,704 $2,738 $3,713 2030 $168 28 1 $4,704 $2,559 $3,605 2031 $168 28 1 $4,704 $2,391 $3,500 2032 $168 28 1 $4,704 $2,235 $3,398 2033 $168 28 1 $4,704 $2,089 $3,299 2034 $168 28 0.5 $2,352 $976 $1,602 8 $37,632 $20,728 $28,911 Issue 7: Category 1 Construction - Visual Impacts in Site and Vicinity ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 27 0 $0 $0 $0 2025 $168 27 0 $0 $0 $0 2026 $168 27 0.5 $2,268 $1,617 $1,956 2027 $168 27 1 $4,536 $3,023 $3,799 2028 $168 27 1 $4,536 $2,825 $3,688 2029 $168 27 1 $4,536 $2,640 $3,581 2030 $168 27 1 $4,536 $2,467 $3,476 2031 $168 27 1 $4,536 $2,306 $3,375 2032 $168 27 1 $4,536 $2,155 $3,277 2033 $168 27 1 $4,536 $2,014 $3,181 2034 $168 27 0.5 $2,268 $941 $1,544 8 $36,288 $19,988 $27,879

Regulatory Analysis Page A-56 Issue 8: Category 1 Construction - Visual Impacts from Transmission Lines ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 9 0 $0 $0 $0 2025 $168 9 0 $0 $0 $0 2026 $168 9 0.5 $756 $539 $652 2027 $168 9 1 $1,512 $1,008 $1,266 2028 $168 9 1 $1,512 $942 $1,229 2029 $168 9 1 $1,512 $880 $1,194 2030 $168 9 1 $1,512 $822 $1,159 2031 $168 9 1 $1,512 $769 $1,125 2032 $168 9 1 $1,512 $718 $1,092 2033 $168 9 1 $1,512 $671 $1,060 2034 $168 9 0.5 $756 $314 $515 8 $12,096 $6,663 $9,293 Issue 9: Category 1 Operations - Visual Impacts During Operations ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 20 0 $0 $0 $0 2025 $168 20 0 $0 $0 $0 2026 $168 20 0.5 $1,680 $1,198 $1,449 2027 $168 20 1 $3,360 $2,239 $2,814 2028 $168 20 1 $3,360 $2,092 $2,732 2029 $168 20 1 $3,360 $1,956 $2,652 2030 $168 20 1 $3,360 $1,828 $2,575 2031 $168 20 1 $3,360 $1,708 $2,500 2032 $168 20 1 $3,360 $1,596 $2,427 2033 $168 20 1 $3,360 $1,492 $2,357 2034 $168 20 0.5 $1,680 $697 $1,144 8 $26,880 $14,806 $20,651

Regulatory Analysis Page A-57 Issue 10: Category 1 Construction - Emissions of Criteria Pollutants and Dust During Construction ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 154 0 $0 $0 $0 2025 $168 154 0 $0 $0 $0 2026 $168 154 0.5 $12,936 $9,223 $11,159 2027 $168 154 1 $25,872 $17,240 $21,667 2028 $168 154 1 $25,872 $16,112 $21,036 2029 $168 154 1 $25,872 $15,058 $20,424 2030 $168 154 1 $25,872 $14,073 $19,829 2031 $168 154 1 $25,872 $13,152 $19,251 2032 $168 154 1 $25,872 $12,292 $18,690 2033 $168 154 1 $25,872 $11,487 $18,146 2034 $168 154 0.5 $12,936 $5,368 $8,809 8 $206,976 $114,004 $159,011 Issue 11: Category 1 Construction - Greenhouse Gas Emissions During Construction ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 134 0 $0 $0 $0 2025 $168 134 0 $0 $0 $0 2026 $168 134 0.5 $11,256 $8,025 $9,710 2027 $168 134 1 $22,512 $15,001 $18,853 2028 $168 134 1 $22,512 $14,019 $18,304 2029 $168 134 1 $22,512 $13,102 $17,771 2030 $168 134 1 $22,512 $12,245 $17,254 2031 $168 134 1 $22,512 $11,444 $16,751 2032 $168 134 1 $22,512 $10,695 $16,263 2033 $168 134 1 $22,512 $9,996 $15,789 2034 $168 134 0.5 $11,256 $4,671 $7,665 8 $180,096 $99,198 $138,360

Regulatory Analysis Page A-58 Issue 12: Category 1 Operations - Emissions of Criteria and Hazardous Air Pollutants During Operation ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 163 0 $0 $0 $0 2025 $168 163 0 $0 $0 $0 2026 $168 163 0.5 $13,692 $9,762 $11,811 2027 $168 163 1 $27,384 $18,247 $22,934 2028 $168 163 1 $27,384 $17,053 $22,266 2029 $168 163 1 $27,384 $15,938 $21,617 2030 $168 163 1 $27,384 $14,895 $20,988 2031 $168 163 1 $27,384 $13,921 $20,376 2032 $168 163 1 $27,384 $13,010 $19,783 2033 $168 163 1 $27,384 $12,159 $19,207 2034 $168 163 0.5 $13,692 $5,682 $9,324 8 $219,072 $120,667 $168,304 Issue 13: Category 1 Operations - Greenhouse Gas Emissions During Operation ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 88 0 $0 $0 $0 2025 $168 88 0 $0 $0 $0 2026 $168 88 0.5 $7,392 $5,270 $6,376 2027 $168 88 1 $14,784 $9,851 $12,381 2028 $168 88 1 $14,784 $9,207 $12,021 2029 $168 88 1 $14,784 $8,604 $11,671 2030 $168 88 1 $14,784 $8,042 $11,331 2031 $168 88 1 $14,784 $7,515 $11,001 2032 $168 88 1 $14,784 $7,024 $10,680 2033 $168 88 1 $14,784 $6,564 $10,369 2034 $168 88 0.5 $7,392 $3,067 $5,034 8 $118,272 $65,145 $90,864

Regulatory Analysis Page A-59 Issue 14: Category 1 Operations - Cooling System Emissions ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 18 0 $0 $0 $0 2025 $168 18 0 $0 $0 $0 2026 $168 18 0.5 $1,512 $1,078 $1,304 2027 $168 18 1 $3,024 $2,015 $2,533 2028 $168 18 1 $3,024 $1,883 $2,459 2029 $168 18 1 $3,024 $1,760 $2,387 2030 $168 18 1 $3,024 $1,645 $2,318 2031 $168 18 1 $3,024 $1,537 $2,250 2032 $168 18 1 $3,024 $1,437 $2,185 2033 $168 18 1 $3,024 $1,343 $2,121 2034 $168 18 0.5 $1,512 $627 $1,030 8 $24,192 $13,325 $18,586 Issue 15: Category 1 Operations - Emissions of Ozone and Nitrogen Oxides During Transmission Line Operation ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 15 0 $0 $0 $0 2025 $168 15 0 $0 $0 $0 2026 $168 15 0.5 $1,260 $898 $1,087 2027 $168 15 1 $2,520 $1,679 $2,110 2028 $168 15 1 $2,520 $1,569 $2,049 2029 $168 15 1 $2,520 $1,467 $1,989 2030 $168 15 1 $2,520 $1,371 $1,931 2031 $168 15 1 $2,520 $1,281 $1,875 2032 $168 15 1 $2,520 $1,197 $1,821 2033 $168 15 1 $2,520 $1,119 $1,767 2034 $168 15 0.5 $1,260 $523 $858 8 $20,160 $11,104 $15,488

Regulatory Analysis Page A-60 Issue 16: Category 1 Construction - Surface Water Use Conflicts During Construction ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 60 0 $0 $0 $0 2025 $168 60 0 $0 $0 $0 2026 $168 60 0.5 $5,040 $3,593 $4,348 2027 $168 60 1 $10,080 $6,717 $8,442 2028 $168 60 1 $10,080 $6,277 $8,196 2029 $168 60 1 $10,080 $5,867 $7,957 2030 $168 60 1 $10,080 $5,483 $7,725 2031 $168 60 1 $10,080 $5,124 $7,500 2032 $168 60 1 $10,080 $4,789 $7,282 2033 $168 60 1 $10,080 $4,476 $7,070 2034 $168 60 0.5 $5,040 $2,091 $3,432 8 $80,640 $44,417 $61,952 Issue 17: Category 1 Construction - Groundwater Use Conflicts Due to Excavation Dewatering ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 123 0 $0 $0 $0 2025 $168 123 0 $0 $0 $0 2026 $168 123 0.5 $10,332 $7,367 $8,912 2027 $168 123 1 $20,664 $13,769 $17,306 2028 $168 123 1 $20,664 $12,869 $16,802 2029 $168 123 1 $20,664 $12,027 $16,312 2030 $168 123 1 $20,664 $11,240 $15,837 2031 $168 123 1 $20,664 $10,505 $15,376 2032 $168 123 1 $20,664 $9,817 $14,928 2033 $168 123 1 $20,664 $9,175 $14,493 2034 $168 123 0.5 $10,332 $4,287 $7,036 8 $165,312 $91,055 $127,003

Regulatory Analysis Page A-61 Issue 18: Category 1 Construction - Groundwater Use Conflicts Due to Construction-Related Groundwater Withdrawals ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 115 0 $0 $0 $0 2025 $168 115 0 $0 $0 $0 2026 $168 115 0.5 $9,660 $6,887 $8,333 2027 $168 115 1 $19,320 $12,874 $16,180 2028 $168 115 1 $19,320 $12,032 $15,709 2029 $168 115 1 $19,320 $11,244 $15,251 2030 $168 115 1 $19,320 $10,509 $14,807 2031 $168 115 1 $19,320 $9,821 $14,376 2032 $168 115 1 $19,320 $9,179 $13,957 2033 $168 115 1 $19,320 $8,578 $13,551 2034 $168 115 0.5 $9,660 $4,009 $6,578 8 $154,560 $85,133 $118,742 Issue 19: Category 1 Construction - Water Quality Degradation Due to Construction-Related Discharges ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 62 0 $0 $0 $0 2025 $168 62 0 $0 $0 $0 2026 $168 62 0.5 $5,208 $3,713 $4,492 2027 $168 62 1 $10,416 $6,941 $8,723 2028 $168 62 1 $10,416 $6,487 $8,469 2029 $168 62 1 $10,416 $6,062 $8,222 2030 $168 62 1 $10,416 $5,666 $7,983 2031 $168 62 1 $10,416 $5,295 $7,750 2032 $168 62 1 $10,416 $4,949 $7,525 2033 $168 62 1 $10,416 $4,625 $7,306 2034 $168 62 0.5 $5,208 $2,161 $3,546 8 $83,328 $45,898 $64,018

Regulatory Analysis Page A-62 Issue 20: Category 1 Construction - Water Quality Degradation Due to Inadvertent Spills During Construction ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 24 0 $0 $0 $0 2025 $168 24 0 $0 $0 $0 2026 $168 24 0.5 $2,016 $1,437 $1,739 2027 $168 24 1 $4,032 $2,687 $3,377 2028 $168 24 1 $4,032 $2,511 $3,278 2029 $168 24 1 $4,032 $2,347 $3,183 2030 $168 24 1 $4,032 $2,193 $3,090 2031 $168 24 1 $4,032 $2,050 $3,000 2032 $168 24 1 $4,032 $1,916 $2,913 2033 $168 24 1 $4,032 $1,790 $2,828 2034 $168 24 0.5 $2,016 $837 $1,373 8 $32,256 $17,767 $24,781 Issue 21: Category 1 Construction - Water Quality Degradation Due to Groundwater Withdrawal ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 73 0 $0 $0 $0 2025 $168 73 0 $0 $0 $0 2026 $168 73 0.5 $6,132 $4,372 $5,290 2027 $168 73 1 $12,264 $8,172 $10,271 2028 $168 73 1 $12,264 $7,637 $9,972 2029 $168 73 1 $12,264 $7,138 $9,681 2030 $168 73 1 $12,264 $6,671 $9,399 2031 $168 73 1 $12,264 $6,234 $9,126 2032 $168 73 1 $12,264 $5,827 $8,860 2033 $168 73 1 $12,264 $5,445 $8,602 2034 $168 73 0.5 $6,132 $2,545 $4,176 8 $98,112 $54,041 $75,375

Regulatory Analysis Page A-63 Issue 22: Category 1 Construction - Water Quality Degradation Due to Offshore or In-Water Construction Activities ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 56 0 $0 $0 $0 2025 $168 56 0 $0 $0 $0 2026 $168 56 0.5 $4,704 $3,354 $4,058 2027 $168 56 1 $9,408 $6,269 $7,879 2028 $168 56 1 $9,408 $5,859 $7,650 2029 $168 56 1 $9,408 $5,476 $7,427 2030 $168 56 1 $9,408 $5,117 $7,210 2031 $168 56 1 $9,408 $4,783 $7,000 2032 $168 56 1 $9,408 $4,470 $6,797 2033 $168 56 1 $9,408 $4,177 $6,599 2034 $168 56 0.5 $4,704 $1,952 $3,203 8 $75,264 $41,456 $57,822 Issue 23: Category 1 Construction - Water Use Conflict Due to Plant Municipal Water Demand ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 49 0 $0 $0 $0 2025 $168 49 0 $0 $0 $0 2026 $168 49 0.5 $4,116 $2,935 $3,550 2027 $168 49 1 $8,232 $5,485 $6,894 2028 $168 49 1 $8,232 $5,126 $6,693 2029 $168 49 1 $8,232 $4,791 $6,498 2030 $168 49 1 $8,232 $4,478 $6,309 2031 $168 49 1 $8,232 $4,185 $6,125 2032 $168 49 1 $8,232 $3,911 $5,947 2033 $168 49 1 $8,232 $3,655 $5,774 2034 $168 49 0.5 $4,116 $1,708 $2,803 8 $65,856 $36,274 $50,595

Regulatory Analysis Page A-64 Issue 24: Category 1 Construction - Degradation of Water Quality from Plant Effluent Discharges to Municipal Systems ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 97 0 $0 $0 $0 2025 $168 97 0 $0 $0 $0 2026 $168 97 0.5 $8,148 $5,809 $7,029 2027 $168 97 1 $16,296 $10,859 $13,648 2028 $168 97 1 $16,296 $10,148 $13,250 2029 $168 97 1 $16,296 $9,484 $12,864 2030 $168 97 1 $16,296 $8,864 $12,490 2031 $168 97 1 $16,296 $8,284 $12,126 2032 $168 97 1 $16,296 $7,742 $11,773 2033 $168 97 1 $16,296 $7,236 $11,430 2034 $168 97 0.5 $8,148 $3,381 $5,548 8 $130,368 $71,808 $100,156 Issue 25: Category 1 Operations - Surface Water Use Conflicts During Operation Due to Water Withdrawal from Flowing Waterbodies ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 152 0 $0 $0 $0 2025 $168 152 0 $0 $0 $0 2026 $168 152 0.5 $12,768 $9,103 $11,014 2027 $168 152 1 $25,536 $17,016 $21,386 2028 $168 152 1 $25,536 $15,903 $20,763 2029 $168 152 1 $25,536 $14,862 $20,158 2030 $168 152 1 $25,536 $13,890 $19,571 2031 $168 152 1 $25,536 $12,981 $19,001 2032 $168 152 1 $25,536 $12,132 $18,448 2033 $168 152 1 $25,536 $11,338 $17,910 2034 $168 152 0.5 $12,768 $5,298 $8,694 8 $204,288 $112,523 $156,946

Regulatory Analysis Page A-65 Issue 26: Category 1 Operations - Surface Water Use Conflicts During Operation Due to Water Withdrawal from Non-Flowing Waterbodies ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 113 0 $0 $0 $0 2025 $168 113 0 $0 $0 $0 2026 $168 113 0.5 $9,492 $6,768 $8,188 2027 $168 113 1 $18,984 $12,650 $15,899 2028 $168 113 1 $18,984 $11,822 $15,436 2029 $168 113 1 $18,984 $11,049 $14,986 2030 $168 113 1 $18,984 $10,326 $14,550 2031 $168 113 1 $18,984 $9,651 $14,126 2032 $168 113 1 $18,984 $9,019 $13,714 2033 $168 113 1 $18,984 $8,429 $13,315 2034 $168 113 0.5 $9,492 $3,939 $6,464 8 $151,872 $83,652 $116,677 Issue 27: Category 1 Operations - Groundwater Use Conflicts Due to Building Foundation Dewatering ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 57 0 $0 $0 $0 2025 $168 57 0 $0 $0 $0 2026 $168 57 0.5 $4,788 $3,414 $4,130 2027 $168 57 1 $9,576 $6,381 $8,020 2028 $168 57 1 $9,576 $5,963 $7,786 2029 $168 57 1 $9,576 $5,573 $7,559 2030 $168 57 1 $9,576 $5,209 $7,339 2031 $168 57 1 $9,576 $4,868 $7,125 2032 $168 57 1 $9,576 $4,549 $6,918 2033 $168 57 1 $9,576 $4,252 $6,716 2034 $168 57 0.5 $4,788 $1,987 $3,260 8 $76,608 $42,196 $58,855

Regulatory Analysis Page A-66 Issue 28: Category 1 Operations - Groundwater Use Conflicts Due to Groundwater Withdrawals for Plant Uses ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 124 0 $0 $0 $0 2025 $168 124 0 $0 $0 $0 2026 $168 124 0.5 $10,416 $7,426 $8,985 2027 $168 124 1 $20,832 $13,881 $17,446 2028 $168 124 1 $20,832 $12,973 $16,938 2029 $168 124 1 $20,832 $12,124 $16,445 2030 $168 124 1 $20,832 $11,331 $15,966 2031 $168 124 1 $20,832 $10,590 $15,501 2032 $168 124 1 $20,832 $9,897 $15,049 2033 $168 124 1 $20,832 $9,250 $14,611 2034 $168 124 0.5 $10,416 $4,322 $7,093 8 $166,656 $91,795 $128,035 Issue 29: Category 1 Operations - Surface Water Quality Degradation Due to Physical Effects from Operation of Intake and Discharge Structures ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 95 0 $0 $0 $0 2025 $168 95 0 $0 $0 $0 2026 $168 95 0.5 $7,980 $5,690 $6,884 2027 $168 95 1 $15,960 $10,635 $13,366 2028 $168 95 1 $15,960 $9,939 $12,977 2029 $168 95 1 $15,960 $9,289 $12,599 2030 $168 95 1 $15,960 $8,681 $12,232 2031 $168 95 1 $15,960 $8,113 $11,876 2032 $168 95 1 $15,960 $7,582 $11,530 2033 $168 95 1 $15,960 $7,086 $11,194 2034 $168 95 0.5 $7,980 $3,311 $5,434 8 $127,680 $70,327 $98,091

Regulatory Analysis Page A-67 Issue 30: Category 1 Operations - Surface Water Quality Degradation Due to Changes in Salinity Gradients Resulting from Withdrawals ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 158 0 $0 $0 $0 2025 $168 158 0 $0 $0 $0 2026 $168 158 0.5 $13,272 $9,463 $11,449 2027 $168 158 1 $26,544 $17,687 $22,230 2028 $168 158 1 $26,544 $16,530 $21,583 2029 $168 158 1 $26,544 $15,449 $20,954 2030 $168 158 1 $26,544 $14,438 $20,344 2031 $168 158 1 $26,544 $13,494 $19,751 2032 $168 158 1 $26,544 $12,611 $19,176 2033 $168 158 1 $26,544 $11,786 $18,617 2034 $168 158 0.5 $13,272 $5,507 $9,038 8 $212,352 $116,965 $163,141 Issue 31: Category 1 Operations - Groundwater Quality Degradation Due to Plant Discharges ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 97 0 $0 $0 $0 2025 $168 97 0 $0 $0 $0 2026 $168 97 0.5 $8,148 $5,809 $7,029 2027 $168 97 1 $16,296 $10,859 $13,648 2028 $168 97 1 $16,296 $10,148 $13,250 2029 $168 97 1 $16,296 $9,484 $12,864 2030 $168 97 1 $16,296 $8,864 $12,490 2031 $168 97 1 $16,296 $8,284 $12,126 2032 $168 97 1 $16,296 $7,742 $11,773 2033 $168 97 1 $16,296 $7,236 $11,430 2034 $168 97 0.5 $8,148 $3,381 $5,548 8 $130,368 $71,808 $100,156

Regulatory Analysis Page A-68 Issue 32: Category 1 Operations - Water Quality Degradation Due to Inadvertent Spills and Leaks During Operation ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 22 0 $0 $0 $0 2025 $168 22 0 $0 $0 $0 2026 $168 22 0.5 $1,848 $1,318 $1,594 2027 $168 22 1 $3,696 $2,463 $3,095 2028 $168 22 1 $3,696 $2,302 $3,005 2029 $168 22 1 $3,696 $2,151 $2,918 2030 $168 22 1 $3,696 $2,010 $2,833 2031 $168 22 1 $3,696 $1,879 $2,750 2032 $168 22 1 $3,696 $1,756 $2,670 2033 $168 22 1 $3,696 $1,641 $2,592 2034 $168 22 0.5 $1,848 $767 $1,258 8 $29,568 $16,286 $22,716 Issue 33: Category 1 Operations - Water Quality Degradation Due to Groundwater Withdrawals ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 116 0 $0 $0 $0 2025 $168 116 0 $0 $0 $0 2026 $168 116 0.5 $9,744 $6,947 $8,405 2027 $168 116 1 $19,488 $12,986 $16,321 2028 $168 116 1 $19,488 $12,136 $15,846 2029 $168 116 1 $19,488 $11,342 $15,384 2030 $168 116 1 $19,488 $10,600 $14,936 2031 $168 116 1 $19,488 $9,907 $14,501 2032 $168 116 1 $19,488 $9,259 $14,079 2033 $168 116 1 $19,488 $8,653 $13,668 2034 $168 116 0.5 $9,744 $4,043 $6,635 8 $155,904 $85,873 $119,775

Regulatory Analysis Page A-69 Issue 34: Category 1 Operations - Water Use Conflict from Plant Municipal Water Demand ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 26 0 $0 $0 $0 2025 $168 26 0 $0 $0 $0 2026 $168 26 0.5 $2,184 $1,557 $1,884 2027 $168 26 1 $4,368 $2,911 $3,658 2028 $168 26 1 $4,368 $2,720 $3,552 2029 $168 26 1 $4,368 $2,542 $3,448 2030 $168 26 1 $4,368 $2,376 $3,348 2031 $168 26 1 $4,368 $2,220 $3,250 2032 $168 26 1 $4,368 $2,075 $3,156 2033 $168 26 1 $4,368 $1,939 $3,064 2034 $168 26 0.5 $2,184 $906 $1,487 8 $34,944 $19,247 $26,846 Issue 35: Category 1 Operations - Degradation of Water Quality from Plant Effluent Discharges to Municipal Systems ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 26 0 $0 $0 $0 2025 $168 26 0 $0 $0 $0 2026 $168 26 0.5 $2,184 $1,557 $1,884 2027 $168 26 1 $4,368 $2,911 $3,658 2028 $168 26 1 $4,368 $2,720 $3,552 2029 $168 26 1 $4,368 $2,542 $3,448 2030 $168 26 1 $4,368 $2,376 $3,348 2031 $168 26 1 $4,368 $2,220 $3,250 2032 $168 26 1 $4,368 $2,075 $3,156 2033 $168 26 1 $4,368 $1,939 $3,064 2034 $168 26 0.5 $2,184 $906 $1,487 8 $34,944 $19,247 $26,846

Regulatory Analysis Page A-70 Issue 36: Category 1 Construction - Permanent and Temporary Loss, Conversion, Fragmentation, and Degradation of Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 133 0 $0 $0 $0 2025 $168 133 0 $0 $0 $0 2026 $168 133 0.5 $11,172 $7,965 $9,637 2027 $168 133 1 $22,344 $14,889 $18,713 2028 $168 133 1 $22,344 $13,915 $18,168 2029 $168 133 1 $22,344 $13,004 $17,639 2030 $168 133 1 $22,344 $12,154 $17,125 2031 $168 133 1 $22,344 $11,359 $16,626 2032 $168 133 1 $22,344 $10,615 $16,142 2033 $168 133 1 $22,344 $9,921 $15,672 2034 $168 133 0.5 $11,172 $4,636 $7,608 8 $178,752 $98,458 $137,328 Issue 37: Category 1 Construction - Permanent and Temporary Loss and Degradation of Wetlands ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 133 0 $0 $0 $0 2025 $168 133 0 $0 $0 $0 2026 $168 133 0.5 $11,172 $7,965 $9,637 2027 $168 133 1 $22,344 $14,889 $18,713 2028 $168 133 1 $22,344 $13,915 $18,168 2029 $168 133 1 $22,344 $13,004 $17,639 2030 $168 133 1 $22,344 $12,154 $17,125 2031 $168 133 1 $22,344 $11,359 $16,626 2032 $168 133 1 $22,344 $10,615 $16,142 2033 $168 133 1 $22,344 $9,921 $15,672 2034 $168 133 0.5 $11,172 $4,636 $7,608 8 $178,752 $98,458 $137,328

Regulatory Analysis Page A-71 Issue 38: Category 1 Construction - Effects of Building Noise on Wildlife ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 41 0 $0 $0 $0 2025 $168 41 0 $0 $0 $0 2026 $168 41 0.5 $3,444 $2,456 $2,971 2027 $168 41 1 $6,888 $4,590 $5,769 2028 $168 41 1 $6,888 $4,290 $5,601 2029 $168 41 1 $6,888 $4,009 $5,437 2030 $168 41 1 $6,888 $3,747 $5,279 2031 $168 41 1 $6,888 $3,502 $5,125 2032 $168 41 1 $6,888 $3,272 $4,976 2033 $168 41 1 $6,888 $3,058 $4,831 2034 $168 41 0.5 $3,444 $1,429 $2,345 8 $55,104 $30,352 $42,334 Issue 39: Category 1 Construction - Effects of Vehicular Collisions on Wildlife ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 36 0 $0 $0 $0 2025 $168 36 0 $0 $0 $0 2026 $168 36 0.5 $3,024 $2,156 $2,609 2027 $168 36 1 $6,048 $4,030 $5,065 2028 $168 36 1 $6,048 $3,766 $4,918 2029 $168 36 1 $6,048 $3,520 $4,774 2030 $168 36 1 $6,048 $3,290 $4,635 2031 $168 36 1 $6,048 $3,074 $4,500 2032 $168 36 1 $6,048 $2,873 $4,369 2033 $168 36 1 $6,048 $2,685 $4,242 2034 $168 36 0.5 $3,024 $1,255 $2,059 8 $48,384 $26,650 $37,171

Regulatory Analysis Page A-72 Issue 40: Category 1 Construction - Bird Collisions and Injury from Structures and Transmission Lines ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 40 0 $0 $0 $0 2025 $168 40 0 $0 $0 $0 2026 $168 40 0.5 $3,360 $2,396 $2,898 2027 $168 40 1 $6,720 $4,478 $5,628 2028 $168 40 1 $6,720 $4,185 $5,464 2029 $168 40 1 $6,720 $3,911 $5,305 2030 $168 40 1 $6,720 $3,655 $5,150 2031 $168 40 1 $6,720 $3,416 $5,000 2032 $168 40 1 $6,720 $3,193 $4,855 2033 $168 40 1 $6,720 $2,984 $4,713 2034 $168 40 0.5 $3,360 $1,394 $2,288 8 $53,760 $29,611 $41,302 Issue 41: Category 1 Construction - Important Species and Habitats - Other Important Species and Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 70 0 2025 $168 70 0 $0 $0 $0 2026 $168 70 0.5 $5,880 $4,192 $5,072 2027 $168 70 1 $11,760 $7,836 $9,849 2028 $168 70 1 $11,760 $7,324 $9,562 2029 $168 70 1 $11,760 $6,844 $9,283 2030 $168 70 1 $11,760 $6,397 $9,013 2031 $168 70 1 $11,760 $5,978 $8,751 2032 $168 70 1 $11,760 $5,587 $8,496 2033 $168 70 1 $11,760 $5,222 $8,248 2034 $168 70 0.5 $5,880 $2,440 $4,004 8 $94,080 $51,820 $72,278

Regulatory Analysis Page A-73 Issue 42: Category 1 Operations - Permanent and Temporary Loss or Disturbance of Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 13 0 2025 $168 13 0 $0 $0 $0 2026 $168 13 0.5 $1,092 $779 $942 2027 $168 13 1 $2,184 $1,455 $1,829 2028 $168 13 1 $2,184 $1,360 $1,776 2029 $168 13 1 $2,184 $1,271 $1,724 2030 $168 13 1 $2,184 $1,188 $1,674 2031 $168 13 1 $2,184 $1,110 $1,625 2032 $168 13 1 $2,184 $1,038 $1,578 2033 $168 13 1 $2,184 $970 $1,532 2034 $168 13 0.5 $1,092 $453 $744 8 $17,472 $9,624 $13,423 Issue 43: Category 1 Operations - Effects of Operational Noise on Wildlife ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 8 0 2025 $168 8 0 $0 $0 $0 2026 $168 8 0.5 $672 $479 $580 2027 $168 8 1 $1,344 $896 $1,126 2028 $168 8 1 $1,344 $837 $1,093 2029 $168 8 1 $1,344 $782 $1,061 2030 $168 8 1 $1,344 $731 $1,030 2031 $168 8 1 $1,344 $683 $1,000 2032 $168 8 1 $1,344 $639 $971 2033 $168 8 1 $1,344 $597 $943 2034 $168 8 0.5 $672 $279 $458 8 $10,752 $5,922 $8,260

Regulatory Analysis Page A-74 Issue 44: Category 1 Operations - Effects of Vehicular Collisions on Wildlife ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 7 0 2025 $168 7 0 $0 $0 $0 2026 $168 7 0.5 $588 $419 $507 2027 $168 7 1 $1,176 $784 $985 2028 $168 7 1 $1,176 $732 $956 2029 $168 7 1 $1,176 $684 $928 2030 $168 7 1 $1,176 $640 $901 2031 $168 7 1 $1,176 $598 $875 2032 $168 7 1 $1,176 $559 $850 2033 $168 7 1 $1,176 $522 $825 2034 $168 7 0.5 $588 $244 $400 8 $9,408 $5,182 $7,228 Issue 45: Category 1 Construction - Exposure of Terrestrial Organisms to Radionuclides ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 28 0 2025 $168 28 0 $0 $0 $0 2026 $168 28 0.5 $2,352 $1,677 $2,029 2027 $168 28 1 $4,704 $3,134 $3,940 2028 $168 28 1 $4,704 $2,929 $3,825 2029 $168 28 1 $4,704 $2,738 $3,713 2030 $168 28 1 $4,704 $2,559 $3,605 2031 $168 28 1 $4,704 $2,391 $3,500 2032 $168 28 1 $4,704 $2,235 $3,398 2033 $168 28 1 $4,704 $2,089 $3,299 2034 $168 28 0.5 $2,352 $976 $1,602 8 $37,632 $20,728 $28,911

Regulatory Analysis Page A-75 Issue 46: Category 1 Operations - Cooling Tower Operational Impacts on Vegetation ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 30 0 2025 $168 30 0 $0 $0 $0 2026 $168 30 0.5 $2,520 $1,797 $2,174 2027 $168 30 1 $5,040 $3,358 $4,221 2028 $168 30 1 $5,040 $3,139 $4,098 2029 $168 30 1 $5,040 $2,933 $3,979 2030 $168 30 1 $5,040 $2,741 $3,863 2031 $168 30 1 $5,040 $2,562 $3,750 2032 $168 30 1 $5,040 $2,394 $3,641 2033 $168 30 1 $5,040 $2,238 $3,535 2034 $168 30 0.5 $2,520 $1,046 $1,716 8 $40,320 $22,209 $30,976 Issue 47: Category 1 Operations - Bird Collisions and Injury from Structures and Transmission Lines ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 13 0 2025 $168 13 0 $0 $0 $0 2026 $168 13 0.5 $1,092 $779 $942 2027 $168 13 1 $2,184 $1,455 $1,829 2028 $168 13 1 $2,184 $1,360 $1,776 2029 $168 13 1 $2,184 $1,271 $1,724 2030 $168 13 1 $2,184 $1,188 $1,674 2031 $168 13 1 $2,184 $1,110 $1,625 2032 $168 13 1 $2,184 $1,038 $1,578 2033 $168 13 1 $2,184 $970 $1,532 2034 $168 13 0.5 $1,092 $453 $744 8 $17,472 $9,624 $13,423

Regulatory Analysis Page A-76 Issue 48: Category 1 Operations - Bird Electrocutions from Transmission Lines ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 13 0 2025 $168 13 0 $0 $0 $0 2026 $168 13 0.5 $1,092 $779 $942 2027 $168 13 1 $2,184 $1,455 $1,829 2028 $168 13 1 $2,184 $1,360 $1,776 2029 $168 13 1 $2,184 $1,271 $1,724 2030 $168 13 1 $2,184 $1,188 $1,674 2031 $168 13 1 $2,184 $1,110 $1,625 2032 $168 13 1 $2,184 $1,038 $1,578 2033 $168 13 1 $2,184 $970 $1,532 2034 $168 13 0.5 $1,092 $453 $744 8 $17,472 $9,624 $13,423 Issue 49: Category 1 Operations - Water Use Conflicts with Terrestrial Resources ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 50 0 2025 $168 50 0 $0 $0 $0 2026 $168 50 0.5 $4,200 $2,995 $3,623 2027 $168 50 1 $8,400 $5,597 $7,035 2028 $168 50 1 $8,400 $5,231 $6,830 2029 $168 50 1 $8,400 $4,889 $6,631 2030 $168 50 1 $8,400 $4,569 $6,438 2031 $168 50 1 $8,400 $4,270 $6,250 2032 $168 50 1 $8,400 $3,991 $6,068 2033 $168 50 1 $8,400 $3,730 $5,892 2034 $168 50 0.5 $4,200 $1,743 $2,860 8 $67,200 $37,014 $51,627

Regulatory Analysis Page A-77 Issue 50: Category 1 Operations - Effects of Transmission Line ROW Management on Terrestrial Resources ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 18 0 2025 $168 18 0 $0 $0 $0 2026 $168 18 0.5 $1,512 $1,078 $1,304 2027 $168 18 1 $3,024 $2,015 $2,533 2028 $168 18 1 $3,024 $1,883 $2,459 2029 $168 18 1 $3,024 $1,760 $2,387 2030 $168 18 1 $3,024 $1,645 $2,318 2031 $168 18 1 $3,024 $1,537 $2,250 2032 $168 18 1 $3,024 $1,437 $2,185 2033 $168 18 1 $3,024 $1,343 $2,121 2034 $168 18 0.5 $1,512 $627 $1,030 8 $24,192 $13,325 $18,586 Issue 51: Category 1 Operations -Effects of Electromagnetic Fields on Flora and Fauna ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 5 0 2025 $168 5 0 $0 $0 $0 2026 $168 5 0.5 $420 $299 $362 2027 $168 5 1 $840 $560 $703 2028 $168 5 1 $840 $523 $683 2029 $168 5 1 $840 $489 $663 2030 $168 5 1 $840 $457 $644 2031 $168 5 1 $840 $427 $625 2032 $168 5 1 $840 $399 $607 2033 $168 5 1 $840 $373 $589 2034 $168 5 0.5 $420 $174 $286 8 $6,720 $3,701 $5,163

Regulatory Analysis Page A-78 Issue 52: Category 1 Operations - Important Species and Habitats - Other Important Species and Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 30 0 2025 $168 30 0 $0 $0 $0 2026 $168 30 0.5 $2,520 $1,797 $2,174 2027 $168 30 1 $5,040 $3,358 $4,221 2028 $168 30 1 $5,040 $3,139 $4,098 2029 $168 30 1 $5,040 $2,933 $3,979 2030 $168 30 1 $5,040 $2,741 $3,863 2031 $168 30 1 $5,040 $2,562 $3,750 2032 $168 30 1 $5,040 $2,394 $3,641 2033 $168 30 1 $5,040 $2,238 $3,535 2034 $168 30 0.5 $2,520 $1,046 $1,716 8 $40,320 $22,209 $30,976 Issue 53: Category 1 Construction - Runoff and Sedimentation from Construction Areas ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 124 0 2025 $168 124 0 $0 $0 $0 2026 $168 124 0.5 $10,416 $7,426 $8,985 2027 $168 124 1 $20,832 $13,881 $17,446 2028 $168 124 1 $20,832 $12,973 $16,938 2029 $168 124 1 $20,832 $12,124 $16,445 2030 $168 124 1 $20,832 $11,331 $15,966 2031 $168 124 1 $20,832 $10,590 $15,501 2032 $168 124 1 $20,832 $9,897 $15,049 2033 $168 124 1 $20,832 $9,250 $14,611 2034 $168 124 0.5 $10,416 $4,322 $7,093 8 $166,656 $91,795 $128,035

Regulatory Analysis Page A-79 Issue 54: Category 1 Construction - Dredging and Filling Aquatic Habitats to Build Intake and Discharge Structures ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 123 0 2025 $168 123 0 $0 $0 $0 2026 $168 123 0.5 $10,332 $7,367 $8,912 2027 $168 123 1 $20,664 $13,769 $17,306 2028 $168 123 1 $20,664 $12,869 $16,802 2029 $168 123 1 $20,664 $12,027 $16,312 2030 $168 123 1 $20,664 $11,240 $15,837 2031 $168 123 1 $20,664 $10,505 $15,376 2032 $168 123 1 $20,664 $9,817 $14,928 2033 $168 123 1 $20,664 $9,175 $14,493 2034 $168 123 0.5 $10,332 $4,287 $7,036 8 $165,312 $91,055 $127,003 Issue 55: Category 1 Construction - Building Transmission Lines, Pipelines, and Access Roads Across Surface Waterbodies ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 105 0 2025 $168 105 0 $0 $0 $0 2026 $168 105 0.5 $8,820 $6,289 $7,608 2027 $168 105 1 $17,640 $11,754 $14,773 2028 $168 105 1 $17,640 $10,985 $14,343 2029 $168 105 1 $17,640 $10,267 $13,925 2030 $168 105 1 $17,640 $9,595 $13,520 2031 $168 105 1 $17,640 $8,967 $13,126 2032 $168 105 1 $17,640 $8,381 $12,744 2033 $168 105 1 $17,640 $7,832 $12,372 2034 $168 105 0.5 $8,820 $3,660 $6,006 8 $141,120 $77,730 $108,417

Regulatory Analysis Page A-80 Issue 56: Category 1 Operations - Important Species and Habitats - Other Important Species and Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 172 0 2025 $168 172 0 $0 $0 $0 2026 $168 172 0.5 $14,448 $10,301 $12,463 2027 $168 172 1 $28,896 $19,255 $24,200 2028 $168 172 1 $28,896 $17,995 $23,495 2029 $168 172 1 $28,896 $16,818 $22,811 2030 $168 172 1 $28,896 $15,718 $22,146 2031 $168 172 1 $28,896 $14,689 $21,501 2032 $168 172 1 $28,896 $13,728 $20,875 2033 $168 172 1 $28,896 $12,830 $20,267 2034 $168 172 0.5 $14,448 $5,995 $9,838 8 $231,168 $127,329 $177,597 Issue 57: Category 1 Operations - Stormwater Runoff ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 28 0 2025 $168 28 0 $0 $0 $0 2026 $168 28 0.5 $2,352 $1,677 $2,029 2027 $168 28 1 $4,704 $3,134 $3,940 2028 $168 28 1 $4,704 $2,929 $3,825 2029 $168 28 1 $4,704 $2,738 $3,713 2030 $168 28 1 $4,704 $2,559 $3,605 2031 $168 28 1 $4,704 $2,391 $3,500 2032 $168 28 1 $4,704 $2,235 $3,398 2033 $168 28 1 $4,704 $2,089 $3,299 2034 $168 28 0.5 $2,352 $976 $1,602 8 $37,632 $20,728 $28,911

Regulatory Analysis Page A-81 Issue 58: Category 1 Operations - Exposure of Aquatic Organisms to Radionuclides ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 28 0 2025 $168 28 0 $0 $0 $0 2026 $168 28 0.5 $2,352 $1,677 $2,029 2027 $168 28 1 $4,704 $3,134 $3,940 2028 $168 28 1 $4,704 $2,929 $3,825 2029 $168 28 1 $4,704 $2,738 $3,713 2030 $168 28 1 $4,704 $2,559 $3,605 2031 $168 28 1 $4,704 $2,391 $3,500 2032 $168 28 1 $4,704 $2,235 $3,398 2033 $168 28 1 $4,704 $2,089 $3,299 2034 $168 28 0.5 $2,352 $976 $1,602 8 $37,632 $20,728 $28,911 Issue 59: Category 1 Operations - Effects of Refurbishment on Aquatic Biota ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 28 0 2025 $168 28 0 $0 $0 $0 2026 $168 28 0.5 $2,352 $1,677 $2,029 2027 $168 28 1 $4,704 $3,134 $3,940 2028 $168 28 1 $4,704 $2,929 $3,825 2029 $168 28 1 $4,704 $2,738 $3,713 2030 $168 28 1 $4,704 $2,559 $3,605 2031 $168 28 1 $4,704 $2,391 $3,500 2032 $168 28 1 $4,704 $2,235 $3,398 2033 $168 28 1 $4,704 $2,089 $3,299 2034 $168 28 0.5 $2,352 $976 $1,602 8 $37,632 $20,728 $28,911

Regulatory Analysis Page A-82 Issue 60: Category 1 Operations - Effects of Maintenance Dredging on Aquatic Biota ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 72 0 $0 $0 $0 2025 $168 72 0 $0 $0 $0 2026 $168 72 0.5 $6,048 $4,312 $5,217 2027 $168 72 1 $12,096 $8,060 $10,130 2028 $168 72 1 $12,096 $7,533 $9,835 2029 $168 72 1 $12,096 $7,040 $9,549 2030 $168 72 1 $12,096 $6,579 $9,271 2031 $168 72 1 $12,096 $6,149 $9,001 2032 $168 72 1 $12,096 $5,747 $8,738 2033 $168 72 1 $12,096 $5,371 $8,484 2034 $168 72 0.5 $6,048 $2,510 $4,118 8 $96,768 $53,301 $74,343 Issue 61: Category 1 Operations - Impacts of Transmission Line ROW Management on Aquatic Resources ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 44 0 $0 $0 $0 2025 $168 44 0 $0 $0 $0 2026 $168 44 0.5 $3,696 $2,635 $3,188 2027 $168 44 1 $7,392 $4,926 $6,191 2028 $168 44 1 $7,392 $4,603 $6,010 2029 $168 44 1 $7,392 $4,302 $5,835 2030 $168 44 1 $7,392 $4,021 $5,665 2031 $168 44 1 $7,392 $3,758 $5,500 2032 $168 44 1 $7,392 $3,512 $5,340 2033 $168 44 1 $7,392 $3,282 $5,185 2034 $168 44 0.5 $3,696 $1,534 $2,517 8 $59,136 $32,573 $45,432

Regulatory Analysis Page A-83 Issue 62: Category 1 Operations - Impingement and Entrainment of Aquatic Organisms ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 115 0 $0 $0 $0 2025 $168 115 0 $0 $0 $0 2026 $168 115 0.5 $9,660 $6,887 $8,333 2027 $168 115 1 $19,320 $12,874 $16,180 2028 $168 115 1 $19,320 $12,032 $15,709 2029 $168 115 1 $19,320 $11,244 $15,251 2030 $168 115 1 $19,320 $10,509 $14,807 2031 $168 115 1 $19,320 $9,821 $14,376 2032 $168 115 1 $19,320 $9,179 $13,957 2033 $168 115 1 $19,320 $8,578 $13,551 2034 $168 115 0.5 $9,660 $4,009 $6,578 8 $154,560 $85,133 $118,742 Issue 63: Category 1 Operations - Water Use Conflicts with Aquatic Resources ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 58 0 $0 $0 $0 2025 $168 58 0 $0 $0 $0 2026 $168 58 0.5 $4,872 $3,474 $4,203 2027 $168 58 1 $9,744 $6,493 $8,160 2028 $168 58 1 $9,744 $6,068 $7,923 2029 $168 58 1 $9,744 $5,671 $7,692 2030 $168 58 1 $9,744 $5,300 $7,468 2031 $168 58 1 $9,744 $4,953 $7,250 2032 $168 58 1 $9,744 $4,629 $7,039 2033 $168 58 1 $9,744 $4,326 $6,834 2034 $168 58 0.5 $4,872 $2,022 $3,318 8 $77,952 $42,937 $59,887

Regulatory Analysis Page A-84 Issue 64: Category 1 Operations - Important Species and Habitats - Other Important Species and Habitats ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 142 0 $0 $0 $0 2025 $168 142 0 $0 $0 $0 2026 $168 142 0.5 $11,928 $8,504 $10,289 2027 $168 142 1 $23,856 $15,896 $19,979 2028 $168 142 1 $23,856 $14,856 $19,397 2029 $168 142 1 $23,856 $13,884 $18,832 2030 $168 142 1 $23,856 $12,976 $18,284 2031 $168 142 1 $23,856 $12,127 $17,751 2032 $168 142 1 $23,856 $11,334 $17,234 2033 $168 142 1 $23,856 $10,592 $16,732 2034 $168 142 0.5 $11,928 $4,950 $8,122 8 $190,848 $105,121 $146,621 Issue 65: Category 1 Construction - Radiological Dose to Construction Workers ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 97 0 $0 $0 $0 2025 $168 97 0 $0 $0 $0 2026 $168 97 0.5 $8,148 $5,809 $7,029 2027 $168 97 1 $16,296 $10,859 $13,648 2028 $168 97 1 $16,296 $10,148 $13,250 2029 $168 97 1 $16,296 $9,484 $12,864 2030 $168 97 1 $16,296 $8,864 $12,490 2031 $168 97 1 $16,296 $8,284 $12,126 2032 $168 97 1 $16,296 $7,742 $11,773 2033 $168 97 1 $16,296 $7,236 $11,430 2034 $168 97 0.5 $8,148 $3,381 $5,548 8 $130,368 $71,808 $100,156

Regulatory Analysis Page A-85 Issue 66: Category 1 Operations - Occupational Doses to Workers ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 62 0 $0 $0 $0 2025 $168 62 0 $0 $0 $0 2026 $168 62 0.5 $5,208 $3,713 $4,492 2027 $168 62 1 $10,416 $6,941 $8,723 2028 $168 62 1 $10,416 $6,487 $8,469 2029 $168 62 1 $10,416 $6,062 $8,222 2030 $168 62 1 $10,416 $5,666 $7,983 2031 $168 62 1 $10,416 $5,295 $7,750 2032 $168 62 1 $10,416 $4,949 $7,525 2033 $168 62 1 $10,416 $4,625 $7,306 2034 $168 62 0.5 $5,208 $2,161 $3,546 8 $83,328 $45,898 $64,018 Issue 67: Category 1 Operations - Maximally Exposed Individual Annual Doses ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 53 0 $0 $0 $0 2025 $168 53 0 $0 $0 $0 2026 $168 53 0.5 $4,452 $3,174 $3,840 2027 $168 53 1 $8,904 $5,933 $7,457 2028 $168 53 1 $8,904 $5,545 $7,240 2029 $168 53 1 $8,904 $5,182 $7,029 2030 $168 53 1 $8,904 $4,843 $6,824 2031 $168 53 1 $8,904 $4,526 $6,625 2032 $168 53 1 $8,904 $4,230 $6,432 2033 $168 53 1 $8,904 $3,953 $6,245 2034 $168 53 0.5 $4,452 $1,847 $3,032 8 $71,232 $39,235 $54,725

Regulatory Analysis Page A-86 Issue 68: Category 1 Operations - Total Population Annual Doses ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 64 0 $0 $0 $0 2025 $168 64 0 $0 $0 $0 2026 $168 64 0.5 $5,376 $3,833 $4,637 2027 $168 64 1 $10,752 $7,165 $9,005 2028 $168 64 1 $10,752 $6,696 $8,742 2029 $168 64 1 $10,752 $6,258 $8,488 2030 $168 64 1 $10,752 $5,848 $8,241 2031 $168 64 1 $10,752 $5,466 $8,000 2032 $168 64 1 $10,752 $5,108 $7,767 2033 $168 64 1 $10,752 $4,774 $7,541 2034 $168 64 0.5 $5,376 $2,231 $3,661 8 $86,016 $47,378 $66,083 Issue 69: Category 1 Operations - Nonhuman Biota Doses ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 36 0 $0 $0 $0 2025 $168 36 0 $0 $0 $0 2026 $168 36 0.5 $3,024 $2,156 $2,609 2027 $168 36 1 $6,048 $4,030 $5,065 2028 $168 36 1 $6,048 $3,766 $4,918 2029 $168 36 1 $6,048 $3,520 $4,774 2030 $168 36 1 $6,048 $3,290 $4,635 2031 $168 36 1 $6,048 $3,074 $4,500 2032 $168 36 1 $6,048 $2,873 $4,369 2033 $168 36 1 $6,048 $2,685 $4,242 2034 $168 36 0.5 $3,024 $1,255 $2,059 8 $48,384 $26,650 $37,171

Regulatory Analysis Page A-87 Issue 70: Category 1 Construction - Building Impacts of Chemical, Biological, and Physical Nonradiological Hazards ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 44 0 $0 $0 $0 2025 $168 44 0 $0 $0 $0 2026 $168 44 0.5 $3,696 $2,635 $3,188 2027 $168 44 1 $7,392 $4,926 $6,191 2028 $168 44 1 $7,392 $4,603 $6,010 2029 $168 44 1 $7,392 $4,302 $5,835 2030 $168 44 1 $7,392 $4,021 $5,665 2031 $168 44 1 $7,392 $3,758 $5,500 2032 $168 44 1 $7,392 $3,512 $5,340 2033 $168 44 1 $7,392 $3,282 $5,185 2034 $168 44 0.5 $3,696 $1,534 $2,517 8 $59,136 $32,573 $45,432 Issue 71: Category 1 Operations - Operation Impacts of Chemical, Biological, and Physical Nonradiological Hazards ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 23 0 $0 $0 $0 2025 $168 23 0 $0 $0 $0 2026 $168 23 0.5 $1,932 $1,377 $1,667 2027 $168 23 1 $3,864 $2,575 $3,236 2028 $168 23 1 $3,864 $2,406 $3,142 2029 $168 23 1 $3,864 $2,249 $3,050 2030 $168 23 1 $3,864 $2,102 $2,961 2031 $168 23 1 $3,864 $1,964 $2,875 2032 $168 23 1 $3,864 $1,836 $2,791 2033 $168 23 1 $3,864 $1,716 $2,710 2034 $168 23 0.5 $1,932 $802 $1,316 8 $30,912 $17,027 $23,748

Regulatory Analysis Page A-88 Issue 72: Category 1 Construction - Construction-Related Noise ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 17 0 $0 $0 $0 2025 $168 17 0 $0 $0 $0 2026 $168 17 0.5 $1,428 $1,018 $1,232 2027 $168 17 1 $2,856 $1,903 $2,392 2028 $168 17 1 $2,856 $1,779 $2,322 2029 $168 17 1 $2,856 $1,662 $2,255 2030 $168 17 1 $2,856 $1,553 $2,189 2031 $168 17 1 $2,856 $1,452 $2,125 2032 $168 17 1 $2,856 $1,357 $2,063 2033 $168 17 1 $2,856 $1,268 $2,003 2034 $168 17 0.5 $1,428 $593 $972 8 $22,848 $12,585 $17,553 Issue 73: Category 1 Operations - Operation-Related Noise ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 10 0 $0 $0 $0 2025 $168 10 0 $0 $0 $0 2026 $168 10 0.5 $840 $599 $725 2027 $168 10 1 $1,680 $1,119 $1,407 2028 $168 10 1 $1,680 $1,046 $1,366 2029 $168 10 1 $1,680 $978 $1,326 2030 $168 10 1 $1,680 $914 $1,288 2031 $168 10 1 $1,680 $854 $1,250 2032 $168 10 1 $1,680 $798 $1,214 2033 $168 10 1 $1,680 $746 $1,178 2034 $168 10 0.5 $840 $349 $572 8 $13,440 $7,403 $10,325

Regulatory Analysis Page A-89 Issue 74: Category 1 Operations - Low-Level Radioactive Waste ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 145 0 $0 $0 $0 2025 $168 145 0 $0 $0 $0 2026 $168 145 0.5 $12,180 $8,684 $10,507 2027 $168 145 1 $24,360 $16,232 $20,401 2028 $168 145 1 $24,360 $15,170 $19,807 2029 $168 145 1 $24,360 $14,178 $19,230 2030 $168 145 1 $24,360 $13,250 $18,670 2031 $168 145 1 $24,360 $12,383 $18,126 2032 $168 145 1 $24,360 $11,573 $17,598 2033 $168 145 1 $24,360 $10,816 $17,086 2034 $168 145 0.5 $12,180 $5,054 $8,294 8 $194,880 $107,341 $149,718 Issue 75: Category 1 Operations - Onsite Spent Nuclear Fuel Management ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 176 0 $0 $0 $0 2025 $168 176 0 $0 $0 $0 2026 $168 176 0.5 $14,784 $10,541 $12,753 2027 $168 176 1 $29,568 $19,702 $24,763 2028 $168 176 1 $29,568 $18,413 $24,041 2029 $168 176 1 $29,568 $17,209 $23,341 2030 $168 176 1 $29,568 $16,083 $22,661 2031 $168 176 1 $29,568 $15,031 $22,001 2032 $168 176 1 $29,568 $14,048 $21,361 2033 $168 176 1 $29,568 $13,129 $20,738 2034 $168 176 0.5 $14,784 $6,135 $10,067 8 $236,544 $130,290 $181,727

Regulatory Analysis Page A-90 Issue 76: Category 1 Operations - Mixed Waste ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 136 0 $0 $0 $0 2025 $168 136 0 $0 $0 $0 2026 $168 136 0.5 $11,424 $8,145 $9,854 2027 $168 136 1 $22,848 $15,225 $19,135 2028 $168 136 1 $22,848 $14,229 $18,578 2029 $168 136 1 $22,848 $13,298 $18,036 2030 $168 136 1 $22,848 $12,428 $17,511 2031 $168 136 1 $22,848 $11,615 $17,001 2032 $168 136 1 $22,848 $10,855 $16,506 2033 $168 136 1 $22,848 $10,145 $16,025 2034 $168 136 0.5 $11,424 $4,741 $7,779 8 $182,784 $100,679 $140,426 Issue 77: Category 1 Construction - Construction Nonradiological Waste ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 34 0 $0 $0 $0 2025 $168 34 0 $0 $0 $0 2026 $168 34 0.5 $2,856 $2,036 $2,464 2027 $168 34 1 $5,712 $3,806 $4,784 2028 $168 34 1 $5,712 $3,557 $4,644 2029 $168 34 1 $5,712 $3,324 $4,509 2030 $168 34 1 $5,712 $3,107 $4,378 2031 $168 34 1 $5,712 $2,904 $4,250 2032 $168 34 1 $5,712 $2,714 $4,126 2033 $168 34 1 $5,712 $2,536 $4,006 2034 $168 34 0.5 $2,856 $1,185 $1,945 8 $45,696 $25,170 $35,106

Regulatory Analysis Page A-91 Issue 78: Category 1 Operations - Operation Nonradiological Waste ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 17 0 $0 $0 $0 2025 $168 17 0 $0 $0 $0 2026 $168 17 0.5 $1,428 $1,018 $1,232 2027 $168 17 1 $2,856 $1,903 $2,392 2028 $168 17 1 $2,856 $1,779 $2,322 2029 $168 17 1 $2,856 $1,662 $2,255 2030 $168 17 1 $2,856 $1,553 $2,189 2031 $168 17 1 $2,856 $1,452 $2,125 2032 $168 17 1 $2,856 $1,357 $2,063 2033 $168 17 1 $2,856 $1,268 $2,003 2034 $168 17 0.5 $1,428 $593 $972 8 $22,848 $12,585 $17,553 Issue 79: Category 1 Operations - Design Basis Accidents Involving Radiological Releases ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 120 0 $0 $0 $0 2025 $168 120 0 $0 $0 $0 2026 $168 120 0.5 $10,080 $7,187 $8,695 2027 $168 120 1 $20,160 $13,433 $16,884 2028 $168 120 1 $20,160 $12,555 $16,392 2029 $168 120 1 $20,160 $11,733 $15,914 2030 $168 120 1 $20,160 $10,966 $15,451 2031 $168 120 1 $20,160 $10,248 $15,001 2032 $168 120 1 $20,160 $9,578 $14,564 2033 $168 120 1 $20,160 $8,951 $14,140 2034 $168 120 0.5 $10,080 $4,183 $6,864 8 $161,280 $88,834 $123,905

Regulatory Analysis Page A-92 Issue 80: Category 1 Operations - Accidents Involving Releases of Hazardous Chemicals ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 77 0 $0 $0 $0 2025 $168 77 0 $0 $0 $0 2026 $168 77 0.5 $6,468 $4,612 $5,579 2027 $168 77 1 $12,936 $8,620 $10,834 2028 $168 77 1 $12,936 $8,056 $10,518 2029 $168 77 1 $12,936 $7,529 $10,212 2030 $168 77 1 $12,936 $7,036 $9,914 2031 $168 77 1 $12,936 $6,576 $9,626 2032 $168 77 1 $12,936 $6,146 $9,345 2033 $168 77 1 $12,936 $5,744 $9,073 2034 $168 77 0.5 $6,468 $2,684 $4,404 8 $103,488 $57,002 $79,506 Issue 81: Category 1 Operations - Severe Accident Mitigation Design Alternatives ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 61 0 $0 $0 $0 2025 $168 61 0 $0 $0 $0 2026 $168 61 0.5 $5,124 $3,653 $4,420 2027 $168 61 1 $10,248 $6,829 $8,583 2028 $168 61 1 $10,248 $6,382 $8,333 2029 $168 61 1 $10,248 $5,964 $8,090 2030 $168 61 1 $10,248 $5,574 $7,854 2031 $168 61 1 $10,248 $5,210 $7,625 2032 $168 61 1 $10,248 $4,869 $7,403 2033 $168 61 1 $10,248 $4,550 $7,188 2034 $168 61 0.5 $5,124 $2,126 $3,489 8 $81,984 $45,157 $62,985

Regulatory Analysis Page A-93 Issue 82: Category 1 Operations - Acts of Terrorism ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 57 0 $0 $0 $0 2025 $168 57 0 $0 $0 $0 2026 $168 57 0.5 $4,788 $3,414 $4,130 2027 $168 57 1 $9,576 $6,381 $8,020 2028 $168 57 1 $9,576 $5,963 $7,786 2029 $168 57 1 $9,576 $5,573 $7,559 2030 $168 57 1 $9,576 $5,209 $7,339 2031 $168 57 1 $9,576 $4,868 $7,125 2032 $168 57 1 $9,576 $4,549 $6,918 2033 $168 57 1 $9,576 $4,252 $6,716 2034 $168 57 0.5 $4,788 $1,987 $3,260 8 $76,608 $42,196 $58,855 Issue 83: Category 1 Construction - Community Services and Infrastructure ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 44 0 $0 $0 $0 2025 $168 44 0 $0 $0 $0 2026 $168 44 0.5 $3,696 $2,635 $3,188 2027 $168 44 1 $7,392 $4,926 $6,191 2028 $168 44 1 $7,392 $4,603 $6,010 2029 $168 44 1 $7,392 $4,302 $5,835 2030 $168 44 1 $7,392 $4,021 $5,665 2031 $168 44 1 $7,392 $3,758 $5,500 2032 $168 44 1 $7,392 $3,512 $5,340 2033 $168 44 1 $7,392 $3,282 $5,185 2034 $168 44 0.5 $3,696 $1,534 $2,517 8 $59,136 $32,573 $45,432

Regulatory Analysis Page A-94 Issue 84: Category 1 Construction - Transportation Systems and Traffic ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 89 0 $0 $0 $0 2025 $168 89 0 $0 $0 $0 2026 $168 89 0.5 $7,476 $5,330 $6,449 2027 $168 89 1 $14,952 $9,963 $12,522 2028 $168 89 1 $14,952 $9,311 $12,157 2029 $168 89 1 $14,952 $8,702 $11,803 2030 $168 89 1 $14,952 $8,133 $11,459 2031 $168 89 1 $14,952 $7,601 $11,126 2032 $168 89 1 $14,952 $7,104 $10,802 2033 $168 89 1 $14,952 $6,639 $10,487 2034 $168 89 0.5 $7,476 $3,102 $5,091 8 $119,616 $65,885 $91,896 Issue 85: Category 1 Construction - Economic Impacts ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 43 0 $0 $0 $0 2025 $168 43 0 $0 $0 $0 2026 $168 43 0.5 $3,612 $2,575 $3,116 2027 $168 43 1 $7,224 $4,814 $6,050 2028 $168 43 1 $7,224 $4,499 $5,874 2029 $168 43 1 $7,224 $4,204 $5,703 2030 $168 43 1 $7,224 $3,929 $5,537 2031 $168 43 1 $7,224 $3,672 $5,375 2032 $168 43 1 $7,224 $3,432 $5,219 2033 $168 43 1 $7,224 $3,208 $5,067 2034 $168 43 0.5 $3,612 $1,499 $2,460 8 $57,792 $31,832 $44,399

Regulatory Analysis Page A-95 Issue 86: Category 1 Construction - Tax Revenue Impacts ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 25 0 $0 $0 $0 2025 $168 25 0 $0 $0 $0 2026 $168 25 0.5 $2,100 $1,497 $1,811 2027 $168 25 1 $4,200 $2,799 $3,517 2028 $168 25 1 $4,200 $2,616 $3,415 2029 $168 25 1 $4,200 $2,444 $3,316 2030 $168 25 1 $4,200 $2,285 $3,219 2031 $168 25 1 $4,200 $2,135 $3,125 2032 $168 25 1 $4,200 $1,995 $3,034 2033 $168 25 1 $4,200 $1,865 $2,946 2034 $168 25 0.5 $2,100 $871 $1,430 8 $33,600 $18,507 $25,814 Issue 87: Category 1 Operations - Community Services and Infrastructure ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 29 0 $0 $0 $0 2025 $168 29 0 $0 $0 $0 2026 $168 29 0.5 $2,436 $1,737 $2,101 2027 $168 29 1 $4,872 $3,246 $4,080 2028 $168 29 1 $4,872 $3,034 $3,961 2029 $168 29 1 $4,872 $2,836 $3,846 2030 $168 29 1 $4,872 $2,650 $3,734 2031 $168 29 1 $4,872 $2,477 $3,625 2032 $168 29 1 $4,872 $2,315 $3,520 2033 $168 29 1 $4,872 $2,163 $3,417 2034 $168 29 0.5 $2,436 $1,011 $1,659 8 $38,976 $21,468 $29,944

Regulatory Analysis Page A-96 Issue 88: Category 1 Operations - Transportation Systems and Traffic ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 15 0 $0 $0 $0 2025 $168 15 0 $0 $0 $0 2026 $168 15 0.5 $1,260 $898 $1,087 2027 $168 15 1 $2,520 $1,679 $2,110 2028 $168 15 1 $2,520 $1,569 $2,049 2029 $168 15 1 $2,520 $1,467 $1,989 2030 $168 15 1 $2,520 $1,371 $1,931 2031 $168 15 1 $2,520 $1,281 $1,875 2032 $168 15 1 $2,520 $1,197 $1,821 2033 $168 15 1 $2,520 $1,119 $1,767 2034 $168 15 0.5 $1,260 $523 $858 8 $20,160 $11,104 $15,488 Issue 89: Category 1 Operations - Economic Impacts ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 29 0 $0 $0 $0 2025 $168 29 0 $0 $0 $0 2026 $168 29 0.5 $2,436 $1,737 $2,101 2027 $168 29 1 $4,872 $3,246 $4,080 2028 $168 29 1 $4,872 $3,034 $3,961 2029 $168 29 1 $4,872 $2,836 $3,846 2030 $168 29 1 $4,872 $2,650 $3,734 2031 $168 29 1 $4,872 $2,477 $3,625 2032 $168 29 1 $4,872 $2,315 $3,520 2033 $168 29 1 $4,872 $2,163 $3,417 2034 $168 29 0.5 $2,436 $1,011 $1,659 8 $38,976 $21,468 $29,944

Regulatory Analysis Page A-97 Issue 90: Category 1 Operations - Tax Revenue Impacts ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 57 0 $0 $0 $0 2025 $168 57 0 $0 $0 $0 2026 $168 57 0.5 $4,788 $3,414 $4,130 2027 $168 57 1 $9,576 $6,381 $8,020 2028 $168 57 1 $9,576 $5,963 $7,786 2029 $168 57 1 $9,576 $5,573 $7,559 2030 $168 57 1 $9,576 $5,209 $7,339 2031 $168 57 1 $9,576 $4,868 $7,125 2032 $168 57 1 $9,576 $4,549 $6,918 2033 $168 57 1 $9,576 $4,252 $6,716 2034 $168 57 0.5 $4,788 $1,987 $3,260 8 $76,608 $42,196 $58,855 Issue 91: Category 1 Operations - Uranium Recovery ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 26 0 $0 $0 $0 2025 $168 26 0 $0 $0 $0 2026 $168 26 0.5 $2,184 $1,557 $1,884 2027 $168 26 1 $4,368 $2,911 $3,658 2028 $168 26 1 $4,368 $2,720 $3,552 2029 $168 26 1 $4,368 $2,542 $3,448 2030 $168 26 1 $4,368 $2,376 $3,348 2031 $168 26 1 $4,368 $2,220 $3,250 2032 $168 26 1 $4,368 $2,075 $3,156 2033 $168 26 1 $4,368 $1,939 $3,064 2034 $168 26 0.5 $2,184 $906 $1,487 8 $34,944 $19,247 $26,846

Regulatory Analysis Page A-98 Issue 92: Category 1 Operations - Uranium Conversion ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 26 0 $0 $0 $0 2025 $168 26 0 $0 $0 $0 2026 $168 26 0.5 $2,184 $1,557 $1,884 2027 $168 26 1 $4,368 $2,911 $3,658 2028 $168 26 1 $4,368 $2,720 $3,552 2029 $168 26 1 $4,368 $2,542 $3,448 2030 $168 26 1 $4,368 $2,376 $3,348 2031 $168 26 1 $4,368 $2,220 $3,250 2032 $168 26 1 $4,368 $2,075 $3,156 2033 $168 26 1 $4,368 $1,939 $3,064 2034 $168 26 0.5 $2,184 $906 $1,487 8 $34,944 $19,247 $26,846 Issue 93: Category 1 Operations - Enrichment ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 32 0 $0 $0 $0 2025 $168 32 0 $0 $0 $0 2026 $168 32 0.5 $2,688 $1,917 $2,319 2027 $168 32 1 $5,376 $3,582 $4,502 2028 $168 32 1 $5,376 $3,348 $4,371 2029 $168 32 1 $5,376 $3,129 $4,244 2030 $168 32 1 $5,376 $2,924 $4,120 2031 $168 32 1 $5,376 $2,733 $4,000 2032 $168 32 1 $5,376 $2,554 $3,884 2033 $168 32 1 $5,376 $2,387 $3,771 2034 $168 32 0.5 $2,688 $1,115 $1,830 8 $43,008 $23,689 $33,041

Regulatory Analysis Page A-99 Issue 94: Category 1 Operations - Fuel Fabrication ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 37 0 $0 $0 $0 2025 $168 37 0 $0 $0 $0 2026 $168 37 0.5 $3,108 $2,216 $2,681 2027 $168 37 1 $6,216 $4,142 $5,206 2028 $168 37 1 $6,216 $3,871 $5,054 2029 $168 37 1 $6,216 $3,618 $4,907 2030 $168 37 1 $6,216 $3,381 $4,764 2031 $168 37 1 $6,216 $3,160 $4,625 2032 $168 37 1 $6,216 $2,953 $4,491 2033 $168 37 1 $6,216 $2,760 $4,360 2034 $168 37 0.5 $3,108 $1,290 $2,116 8 $49,728 $27,391 $38,204 Issue 95: Category 1 Operations - Reprocessing ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 27 0 $0 $0 $0 2025 $168 27 0 $0 $0 $0 2026 $168 27 0.5 $2,268 $1,617 $1,956 2027 $168 27 1 $4,536 $3,023 $3,799 2028 $168 27 1 $4,536 $2,825 $3,688 2029 $168 27 1 $4,536 $2,640 $3,581 2030 $168 27 1 $4,536 $2,467 $3,476 2031 $168 27 1 $4,536 $2,306 $3,375 2032 $168 27 1 $4,536 $2,155 $3,277 2033 $168 27 1 $4,536 $2,014 $3,181 2034 $168 27 0.5 $2,268 $941 $1,544 8 $36,288 $19,988 $27,879

Regulatory Analysis Page A-100 Issue 96: Category 1 Operations - Storage and Disposal of Radiological Wastes ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 37 0 $0 $0 $0 2025 $168 37 0 $0 $0 $0 2026 $168 37 0.5 $3,108 $2,216 $2,681 2027 $168 37 1 $6,216 $4,142 $5,206 2028 $168 37 1 $6,216 $3,871 $5,054 2029 $168 37 1 $6,216 $3,618 $4,907 2030 $168 37 1 $6,216 $3,381 $4,764 2031 $168 37 1 $6,216 $3,160 $4,625 2032 $168 37 1 $6,216 $2,953 $4,491 2033 $168 37 1 $6,216 $2,760 $4,360 2034 $168 37 0.5 $3,108 $1,290 $2,116 8 $49,728 $27,391 $38,204 Issue 97: Category 1 Operations - Transportation of Unirradiated ANR Fuel ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 57 0 $0 $0 $0 2025 $168 57 0 $0 $0 $0 2026 $168 57 0.5 $4,788 $3,414 $4,130 2027 $168 57 1 $9,576 $6,381 $8,020 2028 $168 57 1 $9,576 $5,963 $7,786 2029 $168 57 1 $9,576 $5,573 $7,559 2030 $168 57 1 $9,576 $5,209 $7,339 2031 $168 57 1 $9,576 $4,868 $7,125 2032 $168 57 1 $9,576 $4,549 $6,918 2033 $168 57 1 $9,576 $4,252 $6,716 2034 $168 57 0.5 $4,788 $1,987 $3,260 8 $76,608 $42,196 $58,855

Regulatory Analysis Page A-101 Issue 98: Category 1 Operations - Transportation of Radioactive Waste from ANRs ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 57 0 $0 $0 $0 2025 $168 57 0 $0 $0 $0 2026 $168 57 0.5 $4,788 $3,414 $4,130 2027 $168 57 1 $9,576 $6,381 $8,020 2028 $168 57 1 $9,576 $5,963 $7,786 2029 $168 57 1 $9,576 $5,573 $7,559 2030 $168 57 1 $9,576 $5,209 $7,339 2031 $168 57 1 $9,576 $4,868 $7,125 2032 $168 57 1 $9,576 $4,549 $6,918 2033 $168 57 1 $9,576 $4,252 $6,716 2034 $168 57 0.5 $4,788 $1,987 $3,260 8 $76,608 $42,196 $58,855 Issue 99: Category 1 Operations - Transportation of Irradiated Fuel from ANRs ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 181 0 $0 $0 $0 2025 $168 181 0 $0 $0 $0 2026 $168 181 0.5 $15,204 $10,840 $13,115 2027 $168 181 1 $30,408 $20,262 $25,466 2028 $168 181 1 $30,408 $18,937 $24,724 2029 $168 181 1 $30,408 $17,698 $24,004 2030 $168 181 1 $30,408 $16,540 $23,305 2031 $168 181 1 $30,408 $15,458 $22,626 2032 $168 181 1 $30,408 $14,447 $21,967 2033 $168 181 1 $30,408 $13,502 $21,328 2034 $168 181 0.5 $15,204 $6,309 $10,353 8 $243,264 $133,992 $186,890

Regulatory Analysis Page A-102 Issue 100: Decommissioning ANR Labor Hours per Year Applications Undiscounted 7% NPV 3% NPV Rate Application per Year 2024 $168 95 0 $0 $0 $0 2025 $168 95 0 $0 $0 $0 2026 $168 95 0.5 $7,980 $5,690 $6,884 2027 $168 95 1 $15,960 $10,635 $13,366 2028 $168 95 1 $15,960 $9,939 $12,977 2029 $168 95 1 $15,960 $9,289 $12,599 2030 $168 95 1 $15,960 $8,681 $12,232 2031 $168 95 1 $15,960 $8,113 $11,876 2032 $168 95 1 $15,960 $7,582 $11,530 2033 $168 95 1 $15,960 $7,086 $11,194 2034 $168 95 0.5 $7,980 $3,311 $5,434 8 $127,680 $70,327 $98,091

SECY-21-0098, Enclosure 3 - Draft Regulatory Analysis

Contents

Text

SUMMARY

1.0 INTRODUCTION

7.0 REFERENCES

SUMMARY

SUMMARY

1.0 INTRODUCTION

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SUMMARY

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SECY-21-0098, Enclosure 3 - Draft Regulatory Analysis

Text

SUMMARY

1.0 INTRODUCTION

7.0 REFERENCES

SUMMARY

SUMMARY

1.0 INTRODUCTION

1.2 Background

7.0 REFERENCES

SUMMARY

Navigation menu

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