ML24176A218
| ML24176A218 | |
| Person / Time | |
|---|---|
| Issue date: | 09/30/2024 |
| From: | NRC/NMSS/DREFS |
| To: | |
| References | |
| NRC-2020-0101, RIN 3150-AK55 | |
| Download: ML24176A218 (133) | |
Text
Regulatory Analysis for the 10 CFR Part 51, Generic Environmental Impact Statement for Licensing of New Nuclear Reactors 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 September 2024
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Regulatory Analysis Page i 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 Generic Environmental Impact Statement for Licensing of New Nuclear Reactors (NR GEIS). This document presents a draft regulatory analysis of the benefits and costs of the proposed rule requirements, the NR 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................................................................................................................................... i LIST OF TABLES......................................................................................................................... v LIST OF FIGURES...................................................................................................................... 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 NR 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 NR 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..................................................................................... 3-3 3.3 Analysis of Alternative 2 Implementation................................................................ 3-3 3.3.1 Industry Implementation.............................................................................. 3-4 3.3.2 Industry Operations..................................................................................... 3-4 3.3.3 NRC Implementation................................................................................. 3-16 3.3.4 NRC Operations........................................................................................ 3-16 4.0 RESULTS......................................................................................................................... 4-1 4.1 Benefits and Costs.................................................................................................. 4-1 4.1.1 Quantitative Results.................................................................................... 4-1 4.1.2 Qualitative Results...................................................................................... 4-2 4.2 Backfitting and Issue Finality Analysis.................................................................... 4-2 4.3 Disaggregation........................................................................................................ 4-3 4.4 Uncertainty Analysis............................................................................................... 4-3 4.4.1 Uncertainty Model Inputs............................................................................ 4-4 4.4.2 Uncertainty Model Results.......................................................................... 4-6 4.4.3 Sensitivity Analysis...................................................................................... 4-8
Regulatory Analysis Page iv 5.0 DECISION RATIONALE................................................................................................... 5-1 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 TABLES No table of figures entries found.
Table A.1 Summary of Proposed Rule Savings Benefits to Industry by Category 1 Issue (2023 Constant Dollars)....................................................................................... A-2 Table A.2 Summary of Proposed Rule Savings Benefits to the NRC by Category 1 Issue (2021 Constant Dollars)..................................................................................... A-40 Table A.3 Bureau of Labor Statistics Labor Rates in the Regulatory Analysis................... A-75
Regulatory Analysis Page vi LIST OF FIGURES Figure 4.1 Relative Frequency of the Undiscounted Net Benefits of the Proposed Rule (2023 Dollars)........................................................................................................ 4-6 Figure 4.2 Relative Frequency of the Net Benefits of the Proposed Rule at 7 Percent and 3 Percent Discounting (2023 Dollars).................................................................... 4-7 Figure 4.3 Tornado Diagram for the Net Benefits of the Proposed Rule (2023 Dollars)........ 4-8 Figure 4.4 Distribution of National Environmental Policy Act Review Complexity used in Monte Carlo Analysis.......................................................................................... 4-10 Figure 4.5 Distribution of Total Category 1 Issues Analyzed during the Proposed Rule, 2026-2036.......................................................................................................... 4-10
Regulatory Analysis Page vii ABBREVIATIONS AND ACRONYMS ac acre(s)
BLS Bureau of Labor Statistics CFR Code of Federal Regulations COL combined license CP construction permits 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 Generic Environmental Impact Statement for Licensing of New Nuclear Reactors (NR GEIS). The NR GEIS would use a technology-neutral regulatory framework and performance-based assumptions to determine generic environmental impacts of new nuclear reactors. The NR GEIS would streamline the NEPA reviews for future new nuclear 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 generic findings in the NR GEIS and state that, on a 10-year cycle, the Commission intends to review the material in this appendix and update if necessary.
Changes to the regulations for the preparation of environmental reports for new nuclear reactors (e.g., 10 CFR 51.50, Environmental reportconstruction permit, early site permit, or combined license) to provide the applicant with the option to use the NR GEIS.
Changes to the regulations for the preparation of draft environmental impact statements (EISs) for new nuclear reactors (e.g., 10 CFR 51.75, Draft environmental impact statementconstruction permit, early site permit, or combined license) to require the NRC staff to use the NR GEIS in preparing its draft EIS if an applicant for a new nuclear reactor referenced the NR GEIS in its application.
Addition of a new section (10 CFR 51.96, Final supplemental environmental impact statement relying on Appendix C to Subpart A) to provide the NRC staff with directions on the preparation of final EISs that reference the NR GEIS.
Draft revisions to Regulatory Guide (RG) 4.2, Preparation of Environmental Reports for Nuclear Power Stations, to provide guidance to applicants regarding the use of the NR GEIS. In addition, the NRC staff has prepared a draft interim staff guidance document, COL-ISG-030, Environmental Considerations for New Nuclear Reactor Applications that Reference the Generic Environmental Impact Statement, to provide guidance to the staff regarding the use of the NR 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 NR GEIS and associated guidance documents. It derives the key findings summarized in Table ES-1.
Regulatory Analysis Page ix Table ES-1 Total Costs and Benefits of Alternative 2 Description Undiscounted 7% Net Present Value (NPV) 3% NPV Industry
$17,572,261
$13,186,588
$15,486,320 NRC
$25,022,400
$7,548,904
$21,409,786 Total Benefit
$42,594,661
$30,735,492
$36,896,107 Industry Cost
($600,000)
($506,921)
($557,321)
NRC Cost
($1,911,580)
($1,366,698)
($1,633,096)
Total Cost
($2,511,580)
($1,873,619)
($2,190,418)
Net Benefits
$40,083,081
$28,861,873
$34,705,689 According to Executive Order 14094, an economically significant regulatory action is one that would have an annual effect on the economy of $200 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 New Nuclear Reactor Generic Environmental Impact Statement (NR 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 Licensing of New Nuclear Reactors [NR GEIS]) through the rulemaking process. The NR GEIS rule will define the number and scope of the environmental impact issues that must be addressed by the NRC during new nuclear reactor environmental reviews.
As part of this rulemaking, the results of the NR GEIS will be used to revise and update guidance to new 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 a new nuclear reactor applicant in its environmental report (ER) and how to prepare the resulting environmental impact statement (EIS). This guidance will be documented in COL-ISG-030, Environmental Considerations for New 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.
This document presents the regulatory analysis of the NRCs proposed new environmental protection regulations from the NR GEIS as they relate to the issuance of early site permits (ESPs), construction permits (CPs), operating license (OL), and combined licenses (COLs) for new nuclear reactors. These new regulations will be presented in Table C-1, Summary of Findings on NEPA Issues for New Nuclear Power Plants, in Appendix C to Subpart A, Environmental Effect of Issuing a License or Permit for a New 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 NRC 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 NR GEIS.
1.1 Statement of the Problem and Objective of the Rulemaking 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 a new nuclear power plant requires the preparation of an EIS. On September 21, 2020, the Commission issued Staff Requirements Memorandum (SRM) 0020, Results of Exploratory Process for Developing a Generic Environmental Impact Statement for the Construction and Operation of Advanced Nuclear Reactors, (NRC 2020-TN6492), which directed the NRC staff to develop a GEIS for the construction and operation of advanced nuclear reactors using a technology-neutral, plant parameter envelope (PPE) approach and codify the GEISs findings in the Code of Federal Regulations. In SRM-SECY 0098, Proposed Rule: Advanced Nuclear Reactor Generic Environmental Impact Statement (RIN 3150-AK55; NRC-2020-0101), dated April 17, 2024, the Commission directed the staff to change the limited applicability of this GEIS from solely advanced nuclear reactors to any new
Regulatory Analysis Page 1-2 nuclear reactor application, provided the application meets the values and the assumptions of the PPEs and the site parameter envelopes (SPEs) used to develop the GEIS.
The purpose of the NR GEIS, upon which the rulemaking is based, is to present impact analyses for environmental issues common to many new nuclear 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 NR GEIS. This GEIS is intended to improve the efficiency of licensing new nuclear reactors by (1) identifying the types of potential environmental impacts1 of constructing and operating a nuclear reactor, (2) assessing impacts that are expected to be generic (the same or similar) for many new nuclear reactors, and (3) defining the environmental issues that will need to be addressed in project-specific supplemental EISs (SEISs) addressing specific projects.
The objective of the rulemaking is to codify the environmental findings from the NR GEIS in Table C-1 and amend the regulations in 10 CFR Part 51 for new nuclear reactor construction and operation, based on the technical findings in the NR 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 Chair 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, Chair Svinicki responded that NRC 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 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 advanced nuclear reactors. 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 new nuclear reactors. As part of the exploratory process, the NRC 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 advanced nuclear reactors might be viable.
On February 28, 2020, the NRC issued SECY-20-0020 (NRC 2020-TN6493) detailing the results of the exploratory process whereby the NRC staff determined that development of a GEIS for advanced nuclear reactors would be beneficial because it would generically resolve many environmental issues, saving resources and providing predictability for potential 1 This GEIS documents the potential impacts of construction, operation, and decommissioning of new nuclear reactors and henceforth when discussing impacts, they are potential impacts.
Regulatory Analysis Page 1-3 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 nuclear reactor GEIS and to conduct a scoping process to gather information necessary to prepare a GEIS for advanced nuclear reactors. 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 NRC staff determined that by using a technology-neutral, performance-based approach to develop the NR GEIS, it would be inclusive of as many advanced reactor technologies as possible and would, where possible, decouple resource areas from reactor power level.
In response to the NRC 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 advanced nuclear reactors using a technology-neutral, PPE approach and directed staff to codify the GEISs findings in the Code of Federal Regulations.
The staff initially developed the GEIS as a document that would be applicable to only advanced nuclear reactors. See SECY-21-0098 (NRC 2021-TN10127), Proposed Rule: Advanced Nuclear Reactor Generic Environmental Impact Statement, dated November 29, 2021. However, in SRM SECY-21-0098, dated April 17, 2024 (NRC 2024-TN10164), the Commission directed the staff to change the limited applicability of this GEIS from solely advanced nuclear reactors to any new nuclear reactor application, provided the application meets the values and the assumptions of the PPEs and the site parameter envelopes used to develop the GEIS.
1.3 NR GEIS Methodology In preparing the NR GEIS, the NRC staff determined that certain environmental impacts associated with licensing a new 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 new 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 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 new nuclear reactor construction, operation, or decommissioning. The analysis identifies 122 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 NR GEIS categorizes resource area issues into categories in a manner that is different from previous GEIS documents developed and used by the NRC.
Regulatory Analysis Page 1-4 For the NR 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 NRC 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 NR GEIS. These 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 ER may refer to the generic analysis in the NR 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 analysis2. 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 NRC 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 NR 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 Table 4.3, Relative Expected Effort of Alternative NRC New Nuclear Reactor NEPA Review Cases.
After accepting the license application and ER, the NRC prepares a Supplemental EIS (SEIS) to the NR 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 2 As used in this document, when the NRC 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 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 new nuclear reactor license environmental reviews.
When addressing Category 1 issues in SEISs, the NRC staff may likewise refer to the generic analysis in the NR 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. The NRC 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). The NRC staff may however be able to streamline the effort by incorporating all or a portion of the generic analysis in the NR 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 NR 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 a new 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 NR GEIS and Codify Findings in 10 CFR Part 51 Under Alternative 2, the NRC would issue the NR GEIS and would amend certain provisions of 10 CFR Part 51 related to the environmental review for new nuclear power plant licenses and add Table C-1. The NRC would also issue two revised guidance documents on applying the NR 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 would summarize the findings of the NR GEIS, for which 122 environmental issues were analyzed. The table would identify issues as Category 1, Category 2, or Uncategorized issues, most of the which would be considered 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 would also identify 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 NR 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. This attribute accounts for the projected net economic effect on the industry of activities directly resulting from implementing the regulatory action for all affected licensees. 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 industry 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 a new nuclear reactor 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. This attribute accounts for the projected net economic effect caused by routine and recurring activities required by the alternative on all affected entities. 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 NR GEIS for Category 1 issues and the ability to incorporate by reference the findings in the 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. This attribute accounts for the projected net economic effect on the NRC to place the alternative into operation. 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; for example, the costs to develop the NR GEIS methodology and this proposed rule are both sunk costs. Future costs of implementation include completion and publication of the Draft NR 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
Regulatory Analysis Page 3-2 comments. Future implementation costs also include those associated with completion and publication of the final rule and supporting documents.
NRC Operations. This attribute accounts for the projected net economic effect on the NRC caused by routine and recurring activities required by the alternative after implementation of the final rule. 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 NR GEIS. Category 2 issues will need to be analyzed in the SEIS. However, the project-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 new nuclear 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 NR 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 new nuclear 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).
Regulatory Analysis Page 3-3 3.2.2 Affected Applicants New nuclear reactor applicants for an NRC license can refer to Table C-1 in 10 CFR Part 51 and the NR GEIS to streamline the preparation of their ER. The NRC estimates that approximately 20 new nuclear reactor applications will be received over the 10-year period before the NR GEIS will be updated. This estimate is based on letters of intent received from potential applicants. Consideration of the potential new nuclear reactor applications under the proposed rule is discussed in Sections 3.3.2 and 3.3.4.
The analysis period for this regulatory analysis covers that period between 2026 and 2036 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 2023 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 NRC staff labor rate and the NRC contractor labor rate. NRC contractors may perform a significant portion of the analyses addressed by the proposed rule. For the regulatory analysis, data about the relative effort expended on previous COL and ESP reviews by NRC staff and NRC contractors were collected and summarized in terms of costs and hours. The NRC staff labor rate was given as
$152 per hour per internal agency guidance. The NRC contractor labor rate was estimated based on recent review costs billed to NRC divided by the hours billed and equates to approximately $225 per hour inclusive of all labor costs. The weighted average of these two rates was estimated based on the relative number of hours per most typical review experience. This rate equates to $195 per hour and represents the NRC average labor rate used in the analysis.
The industry rate is a blended and weighted labor rate of multiple occupational series taken from 2023 BLS labor data.
The following sections address the implementation and operational costs to industry and the NRC associated with issuing the NR GEIS and codifying the findings in 10 CFR Part 51 to accelerate and streamline the process of conducting environmental reviews related to the licensing of new nuclear reactors.
General Assumptions Effective year of proposed rule =
2026 NRC Composite rate (weighted) =
$195.00 NRC staff rate = $152.00/hour NRC contractor staff rate = $225.00/hour Industry staff rate = $134.18/hour The analysis presents all benefits and costs in constant 2023 dollars.
For net present value calculations, the analysis discounts to the first year of incurred costs or savings (i.e., 2023).
Regulatory Analysis Page 3-4 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 20 applications expected to be submitted under this rule during the first 10 years after the rule is issued, 2026-2036 period, which is used as the operational period of the rule in this regulatory analysis. Further, the staff assumed each CP and COL applicant (a total of 12) 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 assumed that preparatory activities for the 12 applicants are split evenly between 2025 and 2026.
Table 3.1 Annual Industry Implementation Costs (2023 Constant Dollars)
Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2025
($300,000)
($262,032)
($282,779) 2026
($300,000)
($244,889)
($274,542) 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 2035
$0
$0
$0 2036
$0
$0
$0 2037
$0
$0
$0 Total Costs
($600,000)
($506,921)
($557,321) 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 a new nuclear reactor application before the final rule is implemented is not affected by the rule and therefore not included in this regulatory analysis.
The list of expected applications submitted in the 10 years following the issuance of the rule (through 2036) is based on the updated, proprietary information of expected applicants provided to the NRC. The tables in Appendix A show the expected number of applications per year.
Regulatory Analysis Page 3-5 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 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 nuclear 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 new nuclear reactor 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 review experience associated with the Clinch River ESP review. Thus, the savings reported for the most likely review experience are likely to be upper bound estimates for the potential range of applications that may be expected.
Many potential new nuclear reactor 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 NR GEIS and would not require analytical effort apart from making the determination that generic analysis applies. It is assumed that the 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 NR 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, Summary of Proposed Rule Savings Benefits to Industry by Category 1 Issue (2023 Constant Dollars), in Appendix A, Summary of Rule Savings Results-Alternative 2, provides the detailed financial results that feed into this summary.
Regulatory Analysis Page 3-6 Table 3.2 Financial Impact of Industry Operations under the Proposed Rule by Issue, 2026-2036 (2023 Constant Dollars)
Applicant Issue Numbers Table 4-1 Issue Descriptions Industry Operations Net Savings (Costs) per Application Labor Rate Industry Operations Net Savings (Costs) per Application Hours per Application Industry Operations Net Savings (Costs) per Application Total per Application Industry Operations Total Net Savings (Costs) - Rule Undiscounted Total Industry Operations Total Net Savings (Costs) - Rule 7% Net Present Value (NPV)
Industry Operations Total Net Savings (Costs) - Rule 3% NPV 1
Category 1 ConstructionOnsite Land Use
$134 26
$3,489
$69,774
$52,360
$61,491 2
Category 1 ConstructionOffsite Land NRC Construction
$134 184
$24,689
$493,784
$370,546
$435,168 3
Category 1 ConstructionImpacts on Prime and Unique Farmland
$134 25
$3,355
$67,090
$50,346
$59,126 4
Category 1 ConstructionCoastal Zone and Compliance with The Coastal Zone Management Act for Facilities Located with a Designated Coastal Zone
$134 14
$1,879
$37,571
$28,194
$33,111 5
Category 1 OperationsOnsite Land Use
$134 3
$403
$8,051
$6,042
$7,095 6
Category 1 OperationsOffsite Land Use NRC
$134 25
$3,355
$67,090
$50,346
$59,126 7
Category 1 ConstructionVisual Impacts in Site and Vicinity
$134 11
$1,476
$29,520
$22,152
$26,016 8
Category 1 ConstructionVisual Impacts from Transmission Lines
$134 11
$1,476
$29,520
$22,152
$26,016 9
Category 1 OperationsVisual Impacts in Site and Vicinity
$134 23
$3,086
$61,723
$46,318
$54,396 10 Category 1 Construction Emissions of Criteria Pollutants and Dust During Construction
$134 33
$4,428
$88,559
$66,457
$78,047 11 Category 1 Construction Greenhouse Gas Emissions During Construction
$134 76
$10,198
$203,954
$153,051
$179,743
Regulatory Analysis Page 3-7 Applicant Issue Numbers Table 4-1 Issue Descriptions Industry Operations Net Savings (Costs) per Application Labor Rate Industry Operations Net Savings (Costs) per Application Hours per Application Industry Operations Net Savings (Costs) per Application Total per Application Industry Operations Total Net Savings (Costs) - Rule Undiscounted Total Industry Operations Total Net Savings (Costs) - Rule 7% Net Present Value (NPV)
Industry Operations Total Net Savings (Costs) - Rule 3% NPV 12 Category 1 OperationsEmissions of Criteria Pollutants During Operation
$134 50
$6,709
$134,180
$100,692
$118,252 13 Category 1 Operations Greenhouse Gas Emissions During Operation
$134 48
$6,441
$128,813
$96,664
$113,522 14 Category 1 OperationsCooling System Emissions
$134 11
$1,476
$29,520
$22,152
$26,016 15 Category 1 OperationsEmissions of Ozone and NOX During Transmission Line Operation
$134 6
$805
$16,102
$12,083
$14,190 16 Category 1 ConstructionSurface Water Use Conflicts During Construction
$134 17
$2,281
$45,621
$34,235
$40,206 17 Category 1 Construction Groundwater Use Conflicts Due to Excavation Dewatering
$134 117
$15,699
$313,982
$235,619
$276,710 18 Category 1 Construction Groundwater Use Conflicts Due to Construction-Related Groundwater Withdrawals
$134 97
$13,015
$260,310
$195,342
$229,409 19 Category 1 ConstructionWater Quality Degradation Due to Construction-Related Discharges
$134 17
$2,281
$45,621
$34,235
$40,206 20 Category 1 ConstructionWater Quality Degradation Due to Inadvertent Spills During Construction
$134 17
$2,281
$45,621
$34,235
$40,206
Regulatory Analysis Page 3-8 Applicant Issue Numbers Table 4-1 Issue Descriptions Industry Operations Net Savings (Costs) per Application Labor Rate Industry Operations Net Savings (Costs) per Application Hours per Application Industry Operations Net Savings (Costs) per Application Total per Application Industry Operations Total Net Savings (Costs) - Rule Undiscounted Total Industry Operations Total Net Savings (Costs) - Rule 7% Net Present Value (NPV)
Industry Operations Total Net Savings (Costs) - Rule 3% NPV 21 Category 1 ConstructionWater Quality Degradation Due to Groundwater Withdrawal
$134 39
$5,233
$104,661
$78,540
$92,237 22 Category 1 ConstructionWater Quality Degradation Due to Offshore or In-Water Construction Activities
$134 67
$8,990
$179,802
$134,927
$158,458 23 Category 1 ConstructionWater Use Conflict Due to Plant Municipal Water Demand
$134 67
$8,990
$179,802
$134,927
$158,458 24 Category 1 Construction Degradation of Water Quality from Plant Effluent Discharges to Municipal Systems
$134 150
$20,127
$402,541
$302,075
$354,757 25 Category 1 OperationsSurface Water Use Conflicts During Operation Due to Water Withdrawal from Flowing Waterbodies
$134 109
$14,626
$292,513
$219,508
$257,790 26 Category 1 OperationsSurface Water Use Conflicts During Operation Due to Water Withdrawal from Non-Flowing Waterbodies
$134 39
$5,233
$104,661
$78,540
$92,237 27 Category 1 Operations Groundwater Use Conflicts Due to Building Foundation Dewatering
$134 29
$3,891
$77,825
$58,401
$68,586 28 Category 1 Operations Groundwater Use Conflicts Due to Groundwater Withdrawals for Plant Uses
$134 57
$7,648
$152,966
$114,789
$134,808
Regulatory Analysis Page 3-9 Applicant Issue Numbers Table 4-1 Issue Descriptions Industry Operations Net Savings (Costs) per Application Labor Rate Industry Operations Net Savings (Costs) per Application Hours per Application Industry Operations Net Savings (Costs) per Application Total per Application Industry Operations Total Net Savings (Costs) - Rule Undiscounted Total Industry Operations Total Net Savings (Costs) - Rule 7% Net Present Value (NPV)
Industry Operations Total Net Savings (Costs) - Rule 3% NPV 29 Category 1 OperationsSurface Water Quality Degradation Due to Physical Effects from Operation of Intake and Discharge Structures
$134 117
$15,699
$313,982
$235,619
$276,710 30 Category 1 OperationsSurface Water Quality Degradation Due to Changes in Salinity Gradients Resulting from Withdrawals
$134 194
$26,031
$520,620
$390,684
$458,819 31 Category 1 Operations Groundwater Quality Degradation Due to Plant Discharges
$134 57
$7,648
$152,966
$114,789
$134,808 32 Category 1 OperationsWater Quality Degradation Due to Inadvertent Spills and Leaks During Operation
$134 16
$2,147
$42,938
$32,221
$37,841 33 Category 1 OperationsWater Quality Degradation Due to Groundwater Withdrawals
$134 43
$5,770
$115,395
$86,595
$101,697 34 Category 1 OperationsWater Use Conflict from Plant Municipal Water Demand
$134 16
$2,147
$42,938
$32,221
$37,841 35 Category 1 Operations Degradation of Water Quality from Plant Effluent Discharges to Municipal Systems
$134 16
$2,147
$42,938
$32,221
$37,841 36 Category 1 Construction Permanent and Temporary Loss, Conversion, Fragmentation, and Degradation of Habitats
$134 168
$22,542
$450,846
$338,324
$397,328
Regulatory Analysis Page 3-10 Applicant Issue Numbers Table 4-1 Issue Descriptions Industry Operations Net Savings (Costs) per Application Labor Rate Industry Operations Net Savings (Costs) per Application Hours per Application Industry Operations Net Savings (Costs) per Application Total per Application Industry Operations Total Net Savings (Costs) - Rule Undiscounted Total Industry Operations Total Net Savings (Costs) - Rule 7% Net Present Value (NPV)
Industry Operations Total Net Savings (Costs) - Rule 3% NPV 37 Category 1 Construction Permanent and Temporary Loss and Degradation of Wetlands
$134 168
$22,542
$450,846
$338,324
$397,328 38 Category 1 ConstructionEffects of Construction Noise on Wildlife
$134 60
$8,051
$161,016
$120,830
$141,903 39 Category 1 ConstructionEffects of Vehicular Collisions on Wildlife
$134 50
$6,709
$134,180
$100,692
$118,252 40 Category 1 ConstructionBird Collisions and Injury from Structures and Transmission Lines
$134 60
$8,051
$161,016
$120,830
$141,903 41 Category 1 ConstructionImportant Species and HabitatsOther Important Species and Habitats
$134 84
$11,271
$225,423
$169,162
$198,664 42 Category 1 OperationsPermanent and Temporary Loss or Disturbance of Habitats
$134 19
$2,549
$50,989
$38,263
$44,936 43 Category 1 OperationsEffects of Operational Noise on Wildlife
$134 11
$1,476
$29,520
$22,152
$26,016 44 Category 1 OperationsEffects of Vehicular Collisions on Wildlife
$134 9
$1,208
$24,152
$18,125
$21,285 45 Category 1 ConstructionExposure of Terrestrial Organisms to Radionuclides
$134 38
$5,099
$101,977
$76,526
$89,872 46 Category 1 OperationsCooling Tower Operational Impacts on Vegetation
$134 37
$4,965
$99,293
$74,512
$87,507 47 Category 1 OperationsBird Collisions and Injury from Structures and Transmission Lines
$134 19
$2,549
$50,989
$38,263
$44,936
Regulatory Analysis Page 3-11 Applicant Issue Numbers Table 4-1 Issue Descriptions Industry Operations Net Savings (Costs) per Application Labor Rate Industry Operations Net Savings (Costs) per Application Hours per Application Industry Operations Net Savings (Costs) per Application Total per Application Industry Operations Total Net Savings (Costs) - Rule Undiscounted Total Industry Operations Total Net Savings (Costs) - Rule 7% Net Present Value (NPV)
Industry Operations Total Net Savings (Costs) - Rule 3% NPV 48 Category 1 OperationsBird Electrocutions from Transmission Lines
$134 19
$2,549
$50,989
$38,263
$44,936 49 Category 1 OperationsWater Use Conflicts with Terrestrial Resources
$134 83
$11,137
$222,739
$167,148
$196,299 50 Category 1 OperationsEffects of Transmission Line Row Management on Terrestrial Resources
$134 23
$3,086
$61,723
$46,318
$54,396 51 Category 1 OperationsEffects of Electromagnetic Fields on Flora and Fauna
$134 4
$537
$10,734
$8,055
$9,460 52 Category 1 OperationsImportant Species and HabitatsOther Important Species and Habitats
$134 37
$4,965
$99,293
$74,512
$87,507 53 Category 1 ConstructionRunoff and Sedimentation from Construction Areas
$134 128
$17,175
$343,502
$257,771
$302,726 54 Category 1 ConstructionDredging and Filling Aquatic Habitats to Build Intake and Discharge Structures
$134 128
$17,175
$343,502
$257,771
$302,726 55 Category 1 ConstructionBuilding Transmission Lines, Pipelines, and Access Roads Across Surface Waterbodies
$134 128
$17,175
$343,502
$257,771
$302,726 56 Category 1 OperationsImportant Species and HabitatsOther Important Species and Habitats
$134 128
$17,175
$343,502
$257,771
$302,726 57 Category 1 Operations Stormwater Runoff
$134 20
$2,684
$53,672
$40,277
$47,301
Regulatory Analysis Page 3-12 Applicant Issue Numbers Table 4-1 Issue Descriptions Industry Operations Net Savings (Costs) per Application Labor Rate Industry Operations Net Savings (Costs) per Application Hours per Application Industry Operations Net Savings (Costs) per Application Total per Application Industry Operations Total Net Savings (Costs) - Rule Undiscounted Total Industry Operations Total Net Savings (Costs) - Rule 7% Net Present Value (NPV)
Industry Operations Total Net Savings (Costs) - Rule 3% NPV 58 Category 1 OperationsExposure of Aquatic Organisms to Radionuclides
$134 38
$5,099
$101,977
$76,526
$89,872 59 Category 1 Operations Effects of Refurbishment on Aquatic Biota
$134 20
$2,684
$53,672
$40,277
$47,301 60 Category 1 OperationsEffects of Maintenance Dredging on Aquatic Biota
$134 97
$13,015
$260,310
$195,342
$229,409 61 Category 1 OperationsImpacts of Transmission Line Row Management on Aquatic Resources
$134 48
$6,441
$128,813
$96,664
$113,522 62 Category 1 Operations Impingement and Entrainment of Aquatic Organisms
$134 145
$19,456
$389,123
$292,006
$342,932 63 Category 1 OperationsWater Use Conflicts with Aquatic Resources
$134 48
$6,441
$128,813
$96,664
$113,522 64 Category 1 OperationsImportant Species and HabitatsOther Important Species and Habitats
$134 145
$19,456
$389,123
$292,006
$342,932 65 Category 1 Construction Radiological Dose to Construction Workers
$134 117
$15,699
$313,982
$235,619
$276,710 66 Category 1 Operations Occupational Doses to Workers
$134 38
$5,099
$101,977
$76,526
$89,872 67 Category 1 OperationsMaximally Exposed Individual Annual Doses
$134 38
$5,099
$101,977
$76,526
$89,872 68 Category 1 OperationsTotal Population Annual Doses
$134 42
$5,636
$112,712
$84,581
$99,332
Regulatory Analysis Page 3-13 Applicant Issue Numbers Table 4-1 Issue Descriptions Industry Operations Net Savings (Costs) per Application Labor Rate Industry Operations Net Savings (Costs) per Application Hours per Application Industry Operations Net Savings (Costs) per Application Total per Application Industry Operations Total Net Savings (Costs) - Rule Undiscounted Total Industry Operations Total Net Savings (Costs) - Rule 7% Net Present Value (NPV)
Industry Operations Total Net Savings (Costs) - Rule 3% NPV 69 Category 1 OperationsNonhuman Biota Doses
$134 42
$5,636
$112,712
$84,581
$99,332 70 Category 1 ConstructionBuilding Impacts of Chemical, Biological, and Physical Nonradiological Hazards
$134 52
$6,977
$139,548
$104,719
$122,982 71 Category 1 OperationsOperation Impacts of Chemical, Biological, and Physical Nonradiological Hazards
$134 35
$4,696
$93,926
$70,484
$82,777 72 Category 1 Construction Construction-Related Noise
$134 23
$3,086
$61,723
$46,318
$54,396 73 Category 1 OperationsOperation-Related Noise
$134 14
$1,879
$37,571
$28,194
$33,111 74 Category 1 OperationsLow-Level Radioactive Waste
$134 232
$31,130
$622,597
$467,210
$548,691 75 Category 1 OperationsOnsite Spent Nuclear Fuel Management
$134 232
$31,130
$622,597
$467,210
$548,691 76 Category 1 OperationsMixed Waste
$134 232
$31,130
$622,597
$467,210
$548,691 77 Category 1 Construction Construction Nonradiological Waste
$134 38
$5,099
$101,977
$76,526
$89,872 78 Category 1 OperationsOperation Nonradiological Waste
$134 25
$3,355
$67,090
$50,346
$59,126 79 Category 1 OperationsDesign Basis Accidents Involving Radiological Releases
$134 172
$23,079
$461,580
$346,380
$406,788 80 Category 1 OperationsAccidents Involving Releases of Hazardous Chemicals
$134 103
$13,821
$276,412
$207,425
$243,600
Regulatory Analysis Page 3-14 Applicant Issue Numbers Table 4-1 Issue Descriptions Industry Operations Net Savings (Costs) per Application Labor Rate Industry Operations Net Savings (Costs) per Application Hours per Application Industry Operations Net Savings (Costs) per Application Total per Application Industry Operations Total Net Savings (Costs) - Rule Undiscounted Total Industry Operations Total Net Savings (Costs) - Rule 7% Net Present Value (NPV)
Industry Operations Total Net Savings (Costs) - Rule 3% NPV 81 Category 1 OperationsSevere Accident Mitigation Alternatives
$134 69
$9,258
$185,169
$138,955
$163,188 82 Category 1 OperationsActs of Terrorism
$134 69
$9,258
$185,169
$138,955
$163,188 83 Category 1 Construction Community Services and Infrastructure
$134 74
$9,929
$198,587
$149,024
$175,013 84 Category 1 Construction Transportation Systems and Traffic
$134 147
$19,725
$394,490
$296,034
$347,662 85 Category 1 Construction Economic Impacts
$134 74
$9,929
$198,587
$149,024
$175,013 86 Category 1 ConstructionTax Revenue Impacts
$134 42
$5,636
$112,712
$84,581
$99,332 87 Category 1 Operations Community Services and Infrastructure
$134 50
$6,709
$134,180
$100,692
$118,252 88 Category 1 Operations Transportation Systems and Traffic
$134 25
$3,355
$67,090
$50,346
$59,126 89 Category 1 OperationsEconomic Impacts
$134 50
$6,709
$134,180
$100,692
$118,252 90 Category 1 OperationsTax Revenue Impacts
$134 98
$13,150
$262,994
$197,356
$231,774 91 Category 1 OperationsUranium Recovery
$134 39
$5,233
$104,661
$78,540
$92,237 92 Category 1 OperationsUranium Conversion
$134 39
$5,233
$104,661
$78,540
$92,237 93 Category 1 OperationsUranium Enrichment
$134 39
$5,233
$104,661
$78,540
$92,237
Regulatory Analysis Page 3-15 Applicant Issue Numbers Table 4-1 Issue Descriptions Industry Operations Net Savings (Costs) per Application Labor Rate Industry Operations Net Savings (Costs) per Application Hours per Application Industry Operations Net Savings (Costs) per Application Total per Application Industry Operations Total Net Savings (Costs) - Rule Undiscounted Total Industry Operations Total Net Savings (Costs) - Rule 7% Net Present Value (NPV)
Industry Operations Total Net Savings (Costs) - Rule 3% NPV 94 Category 1 OperationsFuel Fabrication(a)
$134 39
$5,233
$104,661
$78,540
$92,237 95 Category 1 Operations Reprocessing
$134 39
$5,233
$104,661
$78,540
$92,237 96 Category 1 OperationsStorage and Disposal of Radiological Wastes
$134 39
$5,233
$104,661
$78,540
$92,237 97 Category 1 Operations Transportation of Unirradiated Fuel
$134 78
$10,466
$209,321
$157,079
$184,474 98 Category 1 Operations Transportation of Radioactive Waste
$134 78
$10,466
$209,321
$157,079
$184,474 99 Category 1 Operations Transportation of Spent Nuclear Fuel
$134 155
$20,798
$415,959
$312,144
$366,582 100 Decommissioning
$134 81
$10,869
$217,372
$163,121
$191,569 Totals 6,548
$878,613
$17,572,261
$13,186,588
$15,486,320 (a) Fuel fabrication impacts for metal fuel and liquid fueled molten salt are not included in the staffs generic analysis.
Regulatory Analysis Page 3-16 3.3.3 NRC Implementation The NRC will incur costs to develop the NR GEIS and all associated regulatory guidance for NRC staff and applicants. The NRC recorded actual and planned costs required to bring the proposed rule to fruition, including the cost of the following:
NR GEIS Generation of the Final Rule Package (NR GEIS, FRN, Regulatory Analysis, OMB Supporting 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 New 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.
A 10-year review of the GEIS issues, internal communications with the Commission, and scoping FRN (beginning in 2034).
Table 3.3 lists the NRC costs of rule implementation.
Table 3.3 NRC Costs of Rule Implementation (2023 Constant Dollars)
Year Undiscounted 7 Percent Discounting 3 Percent Discounting 2025
($951,000)
($830,640)
($896,409) 2026
($255,300)
($208,401)
($233,636) 2027
($44,080)
($33,628)
($39,165) 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
($220,400)
($104,710)
($159,222) 2035
($220,400)
($97,860)
($154,584) 2036
($220,400)
($91,458)
($150,082) 2037
$0
$0
$0 Total
($1,911,580)
($1,366,698)
($1,633,096) 3.3.4 NRC Operations Alternative 2 activities affect the environmental review time for each new nuclear reactor 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 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:
Regulatory Analysis Page 3-17 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 new nuclear reactor 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 new nuclear reactor 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 NR 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 NR 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 NR 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 A provides the detailed financial results that feed into this summary.
Regulatory Analysis Page 3-18 Table 3.4 Financial Impact of NRC Operation under the Proposed Rule by Issue, 2026-2036 (2023 Constant Dollars)
NRC Issue Number Table 4-1 Issue Descriptions NRC Operations Net Savings (Costs) per Application Labor Rate NRC Operations Net Savings (Costs) per Application Hours per Application NRC Operations Net Savings (Costs) per Application Total per Application NRC Operations Total Net Savings (Costs) - Rule Undiscounted Total NRC Operations Total Net Savings (Costs) -
Rule 7% Net Present Value (NPV)
NRC Operations Total Net Savings (Costs) -
Rule 3% NPV 1
Category 1 ConstructionOnsite Land Use
$195 82
$15,990
$319,800
$224,285
$273,629 2
Category 1 ConstructionOffsite Land NRC Construction
$195 135
$26,325
$526,500
$369,249
$450,486 3
Category 1 ConstructionImpacts on Prime and Unique Farmland
$195 23
$4,485
$89,700
$62,909
$76,750 4
Category 1 ConstructionCoastal Zone and Compliance with The Coastal Zone Management Act for Facilities Located with a Designated Coastal Zone
$195 9
$1,755
$35,100
$24,617
$30,032 5
Category 1 OperationsOnsite Land Use
$195 24
$4,680
$93,600
$65,644
$80,086 6
Category 1 OperationsOffsite Land Use NRC
$195 28
$5,460
$109,200
$76,585
$93,434 7
Category 1 ConstructionVisual Impacts in Site and Vicinity
$195 27
$5,265
$105,300
$73,850
$90,097 8
Category 1 ConstructionVisual Impacts from Transmission Lines
$195 9
$1,755
$35,100
$24,617
$30,032 9
Category 1 OperationsVisual Impacts in Site and Vicinity
$195 20
$3,900
$78,000
$54,704
$66,739 10 Category 1 Construction Emissions of Criteria Pollutants and Dust During Construction
$195 154
$30,030
$600,600
$421,217
$513,888
Regulatory Analysis Page 3-19 NRC Issue Number Table 4-1 Issue Descriptions NRC Operations Net Savings (Costs) per Application Labor Rate NRC Operations Net Savings (Costs) per Application Hours per Application NRC Operations Net Savings (Costs) per Application Total per Application NRC Operations Total Net Savings (Costs) - Rule Undiscounted Total NRC Operations Total Net Savings (Costs) -
Rule 7% Net Present Value (NPV)
NRC Operations Total Net Savings (Costs) -
Rule 3% NPV 11 Category 1 Construction Greenhouse Gas Emissions During Construction
$195 134
$26,130
$522,600
$366,514
$447,150 12 Category 1 OperationsEmissions of Criteria Pollutants During Operation
$195 163
$31,785
$635,700
$445,834
$543,921 13 Category 1 Operations Greenhouse Gas Emissions During Operation
$195 88
$17,160
$343,200
$240,696
$293,650 14 Category 1 OperationsCooling System Emissions
$195 18
$3,510
$70,200
$49,233
$60,065 15 Category 1 OperationsEmissions of Ozone and NOX During Transmission Line Operation
$195 15
$2,925
$58,500
$41,028
$50,054 16 Category 1 ConstructionSurface Water Use Conflicts During Construction
$195 60
$11,700
$234,000
$164,111
$200,216 17 Category 1 Construction Groundwater Use Conflicts Due to Excavation Dewatering
$195 123
$23,985
$479,700
$336,427
$410,443 18 Category 1 Construction Groundwater Use Conflicts Due to Construction-Related Groundwater Withdrawals
$195 115
$22,425
$448,500
$314,546
$383,748 19 Category 1 ConstructionWater Quality Degradation Due to Construction-Related Discharges
$195 62
$12,090
$241,800
$169,581
$206,890 20 Category 1 ConstructionWater Quality Degradation Due to
$195 24
$4,680
$93,600
$65,644
$80,086
Regulatory Analysis Page 3-20 NRC Issue Number Table 4-1 Issue Descriptions NRC Operations Net Savings (Costs) per Application Labor Rate NRC Operations Net Savings (Costs) per Application Hours per Application NRC Operations Net Savings (Costs) per Application Total per Application NRC Operations Total Net Savings (Costs) - Rule Undiscounted Total NRC Operations Total Net Savings (Costs) -
Rule 7% Net Present Value (NPV)
NRC Operations Total Net Savings (Costs) -
Rule 3% NPV Inadvertent Spills During Construction 21 Category 1 ConstructionWater Quality Degradation Due to Groundwater Withdrawal
$195 73
$14,235
$284,700
$199,668
$243,596 22 Category 1 ConstructionWater Quality Degradation Due to Offshore or In-Water Construction Activities
$195 56
$10,920
$218,400
$153,170
$186,868 23 Category 1 ConstructionWater Use Conflict Due to Plant Municipal Water Demand
$195 49
$9,555
$191,100
$134,024
$163,510 24 Category 1 Construction Degradation of Water Quality from Plant Effluent Discharges to Municipal Systems
$195 97
$18,915
$378,300
$265,312
$323,683 25 Category 1 OperationsSurface Water Use Conflicts During Operation Due to Water Withdrawal from Flowing Waterbodies
$195 152
$29,640
$592,800
$415,747
$507,214 26 Category 1 OperationsSurface Water Use Conflicts During Operation Due to Water Withdrawal from Non-Flowing Waterbodies
$195 113
$22,035
$440,700
$309,075
$377,074 27 Category 1 Operations Groundwater Use Conflicts Due to Building Foundation Dewatering
$195 57
$11,115
$222,300
$155,905
$190,205 28 Category 1 Operations Groundwater Use Conflicts Due to
$195 124
$24,180
$483,600
$339,162
$413,780
Regulatory Analysis Page 3-21 NRC Issue Number Table 4-1 Issue Descriptions NRC Operations Net Savings (Costs) per Application Labor Rate NRC Operations Net Savings (Costs) per Application Hours per Application NRC Operations Net Savings (Costs) per Application Total per Application NRC Operations Total Net Savings (Costs) - Rule Undiscounted Total NRC Operations Total Net Savings (Costs) -
Rule 7% Net Present Value (NPV)
NRC Operations Total Net Savings (Costs) -
Rule 3% NPV Groundwater Withdrawals for Plant Uses 29 Category 1 OperationsSurface Water Quality Degradation Due to Physical Effects from Operation of Intake and Discharge Structures
$195 95
$18,525
$370,500
$259,842
$317,009 30 Category 1 OperationsSurface Water Quality Degradation Due to Changes in Salinity Gradients Resulting from Withdrawals
$195 158
$30,810
$616,200
$432,158
$527,236 31 Category 1 Operations Groundwater Quality Degradation Due to Plant Discharges
$195 97
$18,915
$378,300
$265,312
$323,683 32 Category 1 OperationsWater Quality Degradation Due to Inadvertent Spills and Leaks During Operation
$195 22
$4,290
$85,800
$60,174
$73,413 33 Category 1 OperationsWater Quality Degradation Due to Groundwater Withdrawals
$195 116
$22,620
$452,400
$317,281
$387,085 34 Category 1 Operations - Water Use Conflict from Plant Municipal Water Demand
$195 26
$5,070
$101,400
$71,115
$86,760 35 Category 1 Operations Degradation of Water Quality from Plant Effluent Discharges to Municipal Systems
$195 26
$5,070
$101,400
$71,115
$86,760
Regulatory Analysis Page 3-22 NRC Issue Number Table 4-1 Issue Descriptions NRC Operations Net Savings (Costs) per Application Labor Rate NRC Operations Net Savings (Costs) per Application Hours per Application NRC Operations Net Savings (Costs) per Application Total per Application NRC Operations Total Net Savings (Costs) - Rule Undiscounted Total NRC Operations Total Net Savings (Costs) -
Rule 7% Net Present Value (NPV)
NRC Operations Total Net Savings (Costs) -
Rule 3% NPV 36 Category 1 Construction Permanent and Temporary Loss, Conversion, Fragmentation, and Degradation of Habitats
$195 133
$25,935
$518,700
$363,779
$443,813 37 Category 1 Construction Permanent and Temporary Loss and Degradation of Wetlands
$195 133
$25,935
$518,700
$363,779
$443,813 38 Category 1 ConstructionEffects of Construction Noise on Wildlife
$195 41
$7,995
$159,900
$112,142
$136,814 39 Category 1 ConstructionEffects of Vehicular Collisions on Wildlife
$195 36
$7,020
$140,400
$98,466
$120,130 40 Category 1 ConstructionBird Collisions and Injury from Structures and Transmission Lines
$195 40
$7,800
$156,000
$109,407
$133,477 41 Category 1 ConstructionImportant Species and HabitatsOther Important Species and Habitats
$195 70
$13,650
$273,000
$191,462
$233,586 42 Category 1 OperationsPermanent and Temporary Loss or Disturbance of Habitats
$195 13
$2,535
$50,700
$35,557
$43,380 43 Category 1 OperationsEffects of Operational Noise on Wildlife
$195 8
$1,560
$31,200
$21,881
$26,695 44 Category 1 OperationsEffects of Vehicular Collisions on Wildlife
$195 7
$1,365
$27,300
$19,146
$23,359 45 Category 1 ConstructionExposure of Terrestrial Organisms to Radionuclides
$195 28
$5,460
$109,200
$76,585
$93,434
Regulatory Analysis Page 3-23 NRC Issue Number Table 4-1 Issue Descriptions NRC Operations Net Savings (Costs) per Application Labor Rate NRC Operations Net Savings (Costs) per Application Hours per Application NRC Operations Net Savings (Costs) per Application Total per Application NRC Operations Total Net Savings (Costs) - Rule Undiscounted Total NRC Operations Total Net Savings (Costs) -
Rule 7% Net Present Value (NPV)
NRC Operations Total Net Savings (Costs) -
Rule 3% NPV 46 Category 1 OperationsCooling Tower Operational Impacts on Vegetation
$195 30
$5,850
$117,000
$82,055
$100,108 47 Category 1 OperationsBird Collisions and Injury from Structures and Transmission Lines
$195 13
$2,535
$50,700
$35,557
$43,380 48 Category 1 OperationsBird Electrocutions from Transmission Lines
$195 13
$2,535
$50,700
$35,557
$43,380 49 Category 1 OperationsWater Use Conflicts with Terrestrial Resources
$195 50
$9,750
$195,000
$136,759
$166,847 50 Category 1 OperationsEffects of Transmission Line Row Management on Terrestrial Resources
$195 18
$3,510
$70,200
$49,233
$60,065 51 Category 1 OperationsEffects of Electromagnetic Fields on Flora and Fauna
$195 5
$975
$19,500
$13,676
$16,685 52 Category 1 OperationsImportant Species and HabitatsOther Important Species and Habitats
$195 30
$5,850
$117,000
$82,055
$100,108 53 Category 1 ConstructionRunoff and Sedimentation from Construction Areas
$195 124
$24,180
$483,600
$339,162
$413,780 54 Category 1 ConstructionDredging and Filling Aquatic Habitats to Build Intake and Discharge Structures
$195 123
$23,985
$479,700
$336,427
$410,443
Regulatory Analysis Page 3-24 NRC Issue Number Table 4-1 Issue Descriptions NRC Operations Net Savings (Costs) per Application Labor Rate NRC Operations Net Savings (Costs) per Application Hours per Application NRC Operations Net Savings (Costs) per Application Total per Application NRC Operations Total Net Savings (Costs) - Rule Undiscounted Total NRC Operations Total Net Savings (Costs) -
Rule 7% Net Present Value (NPV)
NRC Operations Total Net Savings (Costs) -
Rule 3% NPV 55 Category 1 ConstructionBuilding Transmission Lines, Pipelines, and Access Roads Across Surface Waterbodies
$195 105
$20,475
$409,500
$287,194
$350,378 56 Category 1 OperationsImportant Species and Habitats - Other Important Species and Habitats
$195 172
$33,540
$670,800
$470,451
$573,953 57 Category 1 OperationsStormwater Runoff
$195 28
$5,460
$109,200
$76,585
$93,434 58 Category 1 OperationsExposure of Aquatic Organisms to Radionuclides
$195 28
$5,460
$109,200
$76,585
$93,434 59 Category 1 OperationsEffects of Refurbishment on Aquatic Biota
$195 28
$5,460
$109,200
$76,585
$93,434 60 Category 1 OperationsEffects of Maintenance Dredging on Aquatic Biota
$195 72
$14,040
$280,800
$196,933
$240,259 61 Category 1 OperationsImpacts of Transmission Line Row Management on Aquatic Resources
$195 44
$8,580
$171,600
$120,348
$146,825 62 Category 1 Operations Impingement and Entrainment of Aquatic Organisms
$195 115
$22,425
$448,500
$314,546
$383,748 63 Category 1 OperationsWater Use Conflicts with Aquatic Resources
$195 58
$11,310
$226,200
$158,640
$193,542 64 Category 1 OperationsImportant Species and HabitatsOther Important Species and Habitats
$195 142
$27,690
$553,800
$388,395
$473,845
Regulatory Analysis Page 3-25 NRC Issue Number Table 4-1 Issue Descriptions NRC Operations Net Savings (Costs) per Application Labor Rate NRC Operations Net Savings (Costs) per Application Hours per Application NRC Operations Net Savings (Costs) per Application Total per Application NRC Operations Total Net Savings (Costs) - Rule Undiscounted Total NRC Operations Total Net Savings (Costs) -
Rule 7% Net Present Value (NPV)
NRC Operations Total Net Savings (Costs) -
Rule 3% NPV 65 Category 1 Construction Radiological Dose to Construction Workers
$195 97
$18,915
$378,300
$265,312
$323,683 66 Category 1 Operations Occupational Doses to Workers
$195 62
$12,090
$241,800
$169,581
$206,890 67 Category 1 OperationsMaximally Exposed Individual Annual Doses
$195 53
$10,335
$206,700
$144,964
$176,858 68 Category 1 OperationsTotal Population Annual Doses
$195 64
$12,480
$249,600
$175,051
$213,564 69 Category 1 OperationsNonhuman Biota Doses
$195 36
$7,020
$140,400
$98,466
$120,130 70 Category 1 ConstructionBuilding Impacts of Chemical, Biological, and Physical Nonradiological Hazards
$195 44
$8,580
$171,600
$120,348
$146,825 71 Category 1 OperationsOperation Impacts of Chemical, Biological, and Physical Nonradiological Hazards
$195 23
$4,485
$89,700
$62,909
$76,750 72 Category 1 Construction Construction-Related Noise
$195 17
$3,315
$66,300
$46,498
$56,728 73 Category 1 OperationsOperation-Related Noise
$195 10
$1,950
$39,000
$27,352
$33,369 74 Category 1 OperationsLow-Level Radioactive Waste
$195 145
$28,275
$565,500
$396,601
$483,856 75 Category 1 OperationsOnsite Spent Nuclear Fuel Management
$195 176
$34,320
$686,400
$481,391
$587,301 76 Category 1 OperationsMixed Waste
$195 136
$26,520
$530,400
$371,984
$453,823
Regulatory Analysis Page 3-26 NRC Issue Number Table 4-1 Issue Descriptions NRC Operations Net Savings (Costs) per Application Labor Rate NRC Operations Net Savings (Costs) per Application Hours per Application NRC Operations Net Savings (Costs) per Application Total per Application NRC Operations Total Net Savings (Costs) - Rule Undiscounted Total NRC Operations Total Net Savings (Costs) -
Rule 7% Net Present Value (NPV)
NRC Operations Total Net Savings (Costs) -
Rule 3% NPV 77 Category 1 Construction Construction Nonradiological Waste
$195 34
$6,630
$132,600
$92,996
$113,456 78 Category 1 OperationsOperation Nonradiological Waste
$195 17
$3,315
$66,300
$46,498
$56,728 79 Category 1 OperationsDesign Basis Accidents Involving Radiological Releases
$195 120
$23,400
$468,000
$328,221
$400,432 80 Category 1 OperationsAccidents Involving Releases of Hazardous Chemicals
$195 77
$15,015
$300,300
$210,609
$256,944 81 Category 1 OperationsSevere Accident Mitigation Alternatives
$195 61
$11,895
$237,900
$166,846
$203,553 82 Category 1 OperationsActs of Terrorism
$195 57
$11,115
$222,300
$155,905
$190,205 83 Category 1 Construction Community Services and Infrastructure
$195 44
$8,580
$171,600
$120,348
$146,825 84 Category 1 Construction Transportation Systems and Traffic
$195 89
$17,355
$347,100
$243,431
$296,987 85 Category 1 ConstructionEconomic Impacts
$195 43
$8,385
$167,700
$117,613
$143,488 86 Category 1 ConstructionTax Revenue Impacts
$195 25
$4,875
$97,500
$68,379
$83,423 87 Category 1 OperationsCommunity Services and Infrastructure
$195 29
$5,655
$113,100
$79,320
$96,771 88 Category 1 Operations Transportation Systems and Traffic
$195 15
$2,925
$58,500
$41,028
$50,054
Regulatory Analysis Page 3-27 NRC Issue Number Table 4-1 Issue Descriptions NRC Operations Net Savings (Costs) per Application Labor Rate NRC Operations Net Savings (Costs) per Application Hours per Application NRC Operations Net Savings (Costs) per Application Total per Application NRC Operations Total Net Savings (Costs) - Rule Undiscounted Total NRC Operations Total Net Savings (Costs) -
Rule 7% Net Present Value (NPV)
NRC Operations Total Net Savings (Costs) -
Rule 3% NPV 89 Category 1 OperationsEconomic Impacts
$195 29
$5,655
$113,100
$79,320
$96,771 90 Category 1 OperationsTax Revenue Impacts
$195 57
$11,115
$222,300
$155,905
$190,205 91 Category 1 OperationsUranium Recovery
$195 26
$5,070
$101,400
$71,115
$86,760 92 Category 1 OperationsUranium Conversion
$195 26
$5,070
$101,400
$71,115
$86,760 93 Category 1 OperationsUranium Enrichment
$195 32
$6,240
$124,800
$87,526
$106,782 94 Category 1 OperationsFuel Fabrication(a)
$195 37
$7,215
$144,300
$101,202
$123,467 95 Category 1 Operations Reprocessing
$195 27
$5,265
$105,300
$73,850
$90,097 96 Category 1 OperationsStorage and Disposal of Radiological Wastes
$195 37
$7,215
$144,300
$101,202
$123,467 97 Category 1 Operations Transportation of Unirradiated Fuel
$195 57
$11,115
$222,300
$155,905
$190,205 98 Category 1 Operations Transportation of Radioactive Waste
$195 57
$11,115
$222,300
$155,905
$190,205 99 Category 1 Operations Transportation of Spent Nuclear Fuel
$195 181
$35,295
$705,900
$495,067
$603,986 100 Decommissioning
$195 95
$18,525
$370,500
$259,842
$317,009 Totals 6,416
$1,251,120
$25,022,400
$17,548,904
$21,409,786 (a) Fuel fabrication impacts for metal fuel and liquid fueled molten salt are not included in the NRC staffs generic analysis.
Regulatory Analysis Page 4-1 4.0 RESULTS This section presents the analytical results and is organized into four sections. Section 4.1 presents findings related to the benefits and costs of the regulatory analysis. Section 4.2 discusses the backfitting and issue finality analysis, Section 4.3 discusses disaggregation of the analytical results, and Section 4.4 examines uncertainties associated with the analytical assumptions and input data.
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 $13.2 million net present value, assuming a 7-percent discount rate, or
$15.5 million assuming a 3-percent discount rate.
Industry costs of ($0.51 million) net present value, assuming a 7-percent discount rate, or
($0.56 million) assuming a 3-percent discount rate. Costs are discussed in Section 3.3.1.
NRC benefits of $17.5 million net present value, assuming a 7-percent discount rate, or
$21.4 million assuming a 3-percent discount rate.
NRC costs of ($1.37 million) net present value, assuming a 7-percent discount rate, or
($1.63 million) assuming a 3-percent discount rate. Costs are discussed in Section 3.3.3.
Table 4.1 presents the quantitative results for Alternative 2 using a 7-percent discount rate and a 3-percent discount rate. Several cases were developed to reflect situations where only some Category 1 issues would be identified and used as part of an application. Section 4.4.3 provides a detailed discussion of the 50 percent case and the 75 percent case, which are presented as sensitivity cases in Section 4.4.3.
Table 4.1 Net Benefits (Costs) of Alternative 2 Implementation and Operations Case Undiscounted 7% Net Present Value (NPV) 3% NPV Industry
$17,572,261
$13,186,588
$15,486,320 NRC
$25,022,400
$17,548,904
$21,409,786 Total Benefit
$42,594,661
$30,735,492
$36,896,107 Industry Cost
($600,000)
($506,921)
($557,321)
NRC Cost
($1,911,580)
($1,366,698)
($1,633,096)
Total Cost
($2,511,580)
($1,873,619)
($2,190,418)
Net Benefits
$40,083,081
$28,861,873
$34,705,689
Regulatory Analysis Page 4-2 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 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)
Entity Net Benefits/Savings Average Hours per Application Net Benefits/Savings Dollars (7% Discount Rate)
Net Benefits/Savings Dollars (3% Discount Rate)
Industry 6,548
$12.7 million
$14.9 million NRC 6,416
$16.2 million
$19.8 million Total 12,964
$28.9 million
$34.7 million Non-Monetary Benefits and Costs (Qualitative)
Benefit:
Improvements in Process The identification of Category 1 issues will improve the efficiency of licensing new nuclear reactors by (1) identifying the possible types of environmental impacts of constructing, operating, and decommissioning a new nuclear reactor, (2) assessing impacts that are expected to be generic (the same or similar) for many new nuclear reactors, 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 NR 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 Backfitting and Issue Finality Analysis The proposed rule would codify in 10 CFR Part 51 certain environmental issues identified in the NR GEIS. The proposed rule also revises 10 CFR Part 51 to permit an applicant for a new nuclear reactor CP or OL under 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, or a new nuclear reactor ESP or COL under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, to use the NR GEIS in preparing its ER.
The proposed rule would require the NRC staff to prepare a site-specific draft SEIS and final SEIS for each application that references the NR GEIS. The NRC has determined that the backfitting rule in § 50.109 and the issue finality provisions in 10 CFR Part 52 do not apply to this proposed rule because this amendment does not involve any provision that would either constitute backfitting as that term is defined in 10 CFR Chapter I or affect the issue finality of any approval issued under 10 CFR Part 52.
The proposed rule would not constitute backfitting for applicants for CPs or OLs under 10 CFR Part 50 and would not affect the issue finality of applicants for ESPs or COLs under 10 CFR Part 52. These applicants are not, with certain exceptions not applicable here, within the scope of the backfitting or issue finality provisions. The backfitting and issue finality regulations include language delineating when the backfitting and issue finality provisions begin; in general, they begin after the issuance of a license, permit, or other approval (e.g., §§ 50.109(a)(1)(iii) and 52.98(a)). Furthermore, neither the backfitting provisions nor the issue finality provisions, with certain exceptions not applicable here, are intended to apply to NRC actions that substantially
Regulatory Analysis Page 4-3 change the expectations of current and future applicants. Applicants cannot reasonably expect that future requirements will not change.
The exceptions to the general principle are applicable when an applicant references a 10 CFR Part 52 approval (e.g., an ESP or design certification rule) with specified issue finality provisions or a CP under 10 CFR Part 50. However, this proposed rule would have no effect on a CP held by an applicant for a 10 CFR Part 50 OL or an ESP referenced by an applicant for a 10 CFR Part 52 combined license. Therefore, for purposes of this proposed rule, the exceptions to the general principle do not apply.
4.3 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.
4.4 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 simulations 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 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.
Regulatory Analysis Page 4-4 4.4.1 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 a NEW NUCLEAR REACTOR 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 NR 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 4-5 Table 4.3 Relative Expected Effort of Alternative NRC New Nuclear Reactor National Environmental Policy Act Review Cases Metric Case 1
Case 2
Case 3
Case 4
Case 5
Case 6
Case 7
Case 8
Case 9
Category 1 issues in play 100 80 73 51 59 100 93 66 78 Fraction of most typical effort 100%
89%
78%
48%
60%
100%
89%
58%
71%
Fraction of most typical effort (Least complex review effort) 67%
62%
55%
41%
48%
67%
60%
45%
53%
These results suggest that for the most typical review approximately 50 percent, 75 percent, or 100 percent 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 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 nuclear reactor applications, including an ESP application for a 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 2026-2036 period. If each
Regulatory Analysis Page 4-6 application used the GEIS analysis for all 100 Category 1 issues, then 800 such issues would be triggered in the 2026-2036 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 Review complexity -
Industry Scalar on the most typical review experience Triangular 1
0.57 2.47 Review complexity -
NRC Scalar on the most typical review experience Triangular 1
0.67 1.91 Category 1 Issues Number of issues per review Triangular 100 50 100 Mix of reviews -
Industry Sum of all Category 1 issues under review 2026-2036 Triangular 2,000 1,000 2,000 Mix of reviews - NRC Sum of all Category 1 issues under review 2026-2036 Triangular 2,000 1,000 2,000 4.4.2 Uncertainty Model Results Table 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.
Figure 4.1 Relative Frequency of the Undiscounted Net Benefits of the Proposed Rule (2023 Dollars)
Regulatory Analysis Page 4-7 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 (2023 Dollars)
Examining the range of the resulting distributions of net benefits, it is possible to discuss the potential costs and benefits of the proposed rule with more confidence. 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 2023 Dollars)
Metric 90-Percent Confidence Intervals 7% Net Present Value (NPV) 90-Percent Confidence Intervals 7% NPV 90-Percent Confidence Intervals 3% NPV 90-Percent Confidence Intervals 3% NPV Total Benefits
$29,017,750
$32,453,234
$34,822,756
$38,969,458 Total Costs
($2,001,669)
($1,745,569)
($2,340,119)
($2,040,717)
Net Benefits
$27,016,081
$30,707,665
$32,482,637
$36,928,741
Regulatory Analysis Page 4-8 4.4.3 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.
NOTE: Bars indicated with an asterisk (*) denote that the results are discounted using the 7-percent discount rate.
Due to the high number of applications in the early years after rule issuance, in the base case, a sensitivity case with applications further front loaded was not conducted.
Figure 4.3 Tornado Diagram for the Net Benefits of the Proposed Rule (2023 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.
Industry labor rate decrease NRC labor rate decrease Applications back loaded*
7% discount rate 50% fewer Cat 1 issues NRC review complexity decrease Industry review complexity decrease Industry labor rate increase NRC labor rate increase Applications front loaded*
Undiscounted All Cat 1 issues in play NRC review complexity increase Industry review complexity increase
-60
-50
-40
-30
-20
-10 0
10 20 30 40 50 60 70 80 Percent change in net benefits
Regulatory Analysis Page 4-9 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 over 50 percent. Imposing a 7-percent discount rate on the net benefits results in an approximately 30-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 +/- 10-percent impact on the undiscounted net benefits. All other variables, taken individually, have lesser impacts on the financial net benefits of the rule.
Table 4.3 also illustrates the effect of back-loading the 20 planned new nuclear reactor applications, as opposed to the assumed even distribution of applications modeled as the most likely case (front-loading was not analyzed due to the front-loaded nature of expected applications in the base 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 20 applications only matters in financial terms when compared to other discounted values. Delaying submission of applications to correspond to a delayed final rule and slower application frequency over time decreases discounted net benefits by about 15 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.
Regulatory Analysis Page 4-10 Figure 4.4 Distribution of National Environmental Policy Act Review Complexity used in Monte Carlo Analysis Figure 4.5 reflects the uncertain nature of future new nuclear reactor 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 2026-2036.
Figure 4.5 Distribution of Total Category 1 Issues Analyzed during the Proposed Rule, 2026-2036
Regulatory Analysis Page 4-11 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 a new nuclear reactor 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
$28.9 million (total present value) using a 7-percent discount rate or $34.7 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 NR GEIS.
- 2. Alternative 2 incorporates text to improve the effectiveness and efficiency of the environmental review for new nuclear reactor applications by codifying the NR GEIS findings in Table C-1. Improving the effectiveness and efficiency of the new nuclear reactor environmental reviews will reduce the cost to industry of preparing environmental reports for new nuclear 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 new nuclear reactor licensing environmental reviews.
Regulatory Analysis Page 6-1 6.0 IMPLEMENTATION This section identifies how and when the proposed action will be implemented and the impact on other requirements.
6.1 Schedule The NRC assumes that the proposed rule would become effective 30 days after its publication in the Federal Register in 2026 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.
NRC (U.S. Nuclear Regulatory Commission). 2021. Rulemaking Issue Notation Vote: Proposed Rule: Advanced Nuclear Reactor Generic Environmental Impact Statement (RIN 3150-AK55; NRC-2020-0101). SECY-21-0098, Washington, D.C. ADAMS Accession No. ML21222A044.
TN10127.
NRC (U.S. Nuclear Regulatory Commission). 2024. Memorandum from C.M. Safford, Secretary, to R.V. Furstenau, Acting Director for Operations, dated April 17, 2024, regarding "Staff Requirements - SECY-21-0098 - Proposed Rule: Advanced Nuclear Reactor Generic Environmental Impact Statement (RIN 3150-AK55; NRC 2020 0101)." Washington, D.C.
ADAMS Accession No. ML24108A199. TN10164.
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 nuclear reactor 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 first 10 years after the rule is finalized (i.e., the operational period of the proposed rule regulatory analysis, 2026-2036. The NRC assumes that 20 applications will be submitted for new nuclear reactor projects with multiple applications submitted soon 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 a new nuclear reactor 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. Table A.1 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 new nuclear reactor 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 Table A.1 reflect the following input variables (Section 3.3 provides more detailed discussion):
Labor Rate: The NRC labor rate was assumed to be the average between the NRC labor rate of $152/hour and the NRC contractor labor rate of $225/hour, which equates to
$195/hour. The industry labor rate is a blended rate of several weighted occupational series labor rates from 2023 U.S. Bureau of Labor Statistics data.
Hours per Application: For each Category 1 issue, the NRC staff estimated the hours saved by utilizing the generic impact analysis findings in the new reactor generic environmental impact statement (NR 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.
Applications per Year: As discussed above and in Section 3.3, this represents the NRCs assumed number of new nuclear reactor applications utilizing the provisions of the proposed rule.
Regulatory Analysis Page A-2 The values reported in Table A.1 expand on the totals presented in Table 3.2.
Table A.1 Summary of Proposed Rule Savings Benefits to Industry by Category 1 Issue (2023 Constant Dollars)
Issue 1:
Category 1 ConstructionOnsite Land Use Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 26 8
$27,910
$22,782
$25,541 2027
$134 26 2
$6,977
$5,323
$6,199 2028
$134 26 8
$27,910
$19,899
$24,075 2029
$134 26 1
$3,489
$2,325
$2,922 2030
$134 26 0
$0
$0
$0 2031
$134 26 1
$3,489
$2,030
$2,754 2032
$134 26 0
$0
$0
$0 2033
$134 26 0
$0
$0
$0 2034
$134 26 0
$0
$0
$0 2035
$134 26 0
$0
$0
$0 2036
$134 26 0
$0
$0
$0 20
$69,774
$52,360
$61,491 Issue 2:
Category 1 ConstructionOffsite Land Use Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 184 8
$197,513
$161,230
$180,753 2027
$134 184 2
$49,378
$37,671
$43,872 2028
$134 184 8
$197,513
$140,824
$170,377 2029
$134 184 1
$24,689
$16,451
$20,677 2030
$134 184 0
$0
$0
$0 2031
$134 184 1
$24,689
$14,369
$19,490 2032
$134 184 0
$0
$0
$0 2033
$134 184 0
$0
$0
$0 2034
$134 184 0
$0
$0
$0 2035
$134 184 0
$0
$0
$0 2036
$134 184 0
$0
$0
$0 20
$493,784
$370,546
$435,168 Issue 3:
Category 1 ConstructionImpacts on Prime and Unique Farmland Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 25 8
$26,836
$21,906
$24,559 2027
$134 25 2
$6,709
$5,118
$5,961 2028
$134 25 8
$26,836
$19,134
$23,149 2029
$134 25 1
$3,355
$2,235
$2,809 2030
$134 25 0
$0
$0
$0
Regulatory Analysis Page A-3 2031
$134 25 1
$3,355
$1,952
$2,648 2032
$134 25 0
$0
$0
$0 2033
$134 25 0
$0
$0
$0 2034
$134 25 0
$0
$0
$0 2035
$134 25 0
$0
$0
$0 2036
$134 25 0
$0
$0
$0 20
$67,090
$50,346
$59,126 Issue 4:
Category 1 ConstructionCoastal Zone and Compliance with The Coastal Zone Management Act Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 14 8
$15,028
$12,267
$13,753 2027
$134 14 2
$3,757
$2,866
$3,338 2028
$134 14 8
$15,028
$10,715
$12,963 2029
$134 14 1
$1,879
$1,252
$1,573 2030
$134 14 0
$0
$0
$0 2031
$134 14 1
$1,879
$1,093
$1,483 2032
$134 14 0
$0
$0
$0 2033
$134 14 0
$0
$0
$0 2034
$134 14 0
$0
$0
$0 2035
$134 14 0
$0
$0
$0 2036
$134 14 0
$0
$0
$0 20
$37,571
$28,194
$33,111 Issue 5:
Category 1 OperationsOnsite Land Use Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 3
8
$3,220
$2,629
$2,947 2027
$134 3
2
$805
$614
$715 2028
$134 3
8
$3,220
$2,296
$2,778 2029
$134 3
1
$403
$268
$337 2030
$134 3
0
$0
$0
$0 2031
$134 3
1
$403
$234
$318 2032
$134 3
0
$0
$0
$0 2033
$134 3
0
$0
$0
$0 2034
$134 3
0
$0
$0
$0 2035
$134 3
0
$0
$0
$0 2036
$134 3
0
$0
$0
$0 20
$8,051
$6,042
$7,095 Issue 6:
Category 1 OperationsOffsite Land Use Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 25 8
$26,836
$21,906
$24,559
Regulatory Analysis Page A-4 2027
$134 25 2
$6,709
$5,118
$5,961 2028
$134 25 8
$26,836
$19,134
$23,149 2029
$134 25 1
$3,355
$2,235
$2,809 2030
$134 25 0
$0
$0
$0 2031
$134 25 1
$3,355
$1,952
$2,648 2032
$134 25 0
$0
$0
$0 2033
$134 25 0
$0
$0
$0 2034
$134 25 0
$0
$0
$0 2035
$134 25 0
$0
$0
$0 2036
$134 25 0
$0
$0
$0 20
$67,090
$50,346
$59,126 Issue 7:
Category 1 ConstructionVisual Impacts in Site and Vicinity Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 11 8
$11,808
$9,639
$10,806 2027
$134 11 2
$2,952
$2,252
$2,623 2028
$134 11 8
$11,808
$8,419
$10,186 2029
$134 11 1
$1,476
$984
$1,236 2030
$134 11 0
$0
$0
$0 2031
$134 11 1
$1,476
$859
$1,165 2032
$134 11 0
$0
$0
$0 2033
$134 11 0
$0
$0
$0 2034
$134 11 0
$0
$0
$0 2035
$134 11 0
$0
$0
$0 2036
$134 11 0
$0
$0
$0 20
$29,520
$22,152
$26,016 Issue 8:
Category 1 ConstructionVisual Impacts from Transmission Lines Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 11 8
$11,808
$9,639
$10,806 2027
$134 11 2
$2,952
$2,252
$2,623 2028
$134 11 8
$11,808
$8,419
$10,186 2029
$134 11 1
$1,476
$984
$1,236 2030
$134 11 0
$0
$0
$0 2031
$134 11 1
$1,476
$859
$1,165 2032
$134 11 0
$0
$0
$0 2033
$134 11 0
$0
$0
$0 2034
$134 11 0
$0
$0
$0 2035
$134 11 0
$0
$0
$0 2036
$134 11 0
$0
$0
$0 20
$29,520
$22,152
$26,016 Issue 9:
Category 1 OperationsVisual Impacts During Operations Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present 3% NPV
Regulatory Analysis Page A-5 Value (NPV) 2026
$134 23 8
$24,689
$20,154
$22,594 2027
$134 23 2
$6,172
$4,709
$5,484 2028
$134 23 8
$24,689
$17,603
$21,297 2029
$134 23 1
$3,086
$2,056
$2,585 2030
$134 23 0
$0
$0
$0 2031
$134 23 1
$3,086
$1,796
$2,436 2032
$134 23 0
$0
$0
$0 2033
$134 23 0
$0
$0
$0 2034
$134 23 0
$0
$0
$0 2035
$134 23 0
$0
$0
$0 2036
$134 23 0
$0
$0
$0 20
$61,723
$46,318
$54,396 Issue 10:
Category 1 ConstructionEmissions of Criteria Pollutants and Dust During Construction Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 33 8
$35,424
$28,916
$32,418 2027
$134 33 2
$8,856
$6,756
$7,868 2028
$134 33 8
$35,424
$25,257
$30,557 2029
$134 33 1
$4,428
$2,951
$3,708 2030
$134 33 0
$0
$0
$0 2031
$134 33 1
$4,428
$2,577
$3,495 2032
$134 33 0
$0
$0
$0 2033
$134 33 0
$0
$0
$0 2034
$134 33 0
$0
$0
$0 2035
$134 33 0
$0
$0
$0 2036
$134 33 0
$0
$0
$0 20
$88,559
$66,457
$78,047 Issue 11:
Category 1 ConstructionGreenhouse Gas Emissions During Construction Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 76 8
$81,582
$66,595
$74,659 2027
$134 76 2
$20,395
$15,560
$18,121 2028
$134 76 8
$81,582
$58,167
$70,373 2029
$134 76 1
$10,198
$6,795
$8,540 2030
$134 76 0
$0
$0
$0 2031
$134 76 1
$10,198
$5,935
$8,050 2032
$134 76 0
$0
$0
$0 2033
$134 76 0
$0
$0
$0 2034
$134 76 0
$0
$0
$0 2035
$134 76 0
$0
$0
$0 2036
$134 76 0
$0
$0
$0
Regulatory Analysis Page A-6 20
$203,954
$153,051
$179,743 Issue 12:
Category 1 OperationsEmissions of Criteria and Hazardous Air Pollutants During Operation Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 50 8
$53,672
$43,812
$49,118 2027
$134 50 2
$13,418
$10,237
$11,922 2028
$134 50 8
$53,672
$38,267
$46,298 2029
$134 50 1
$6,709
$4,471
$5,619 2030
$134 50 0
$0
$0
$0 2031
$134 50 1
$6,709
$3,905
$5,296 2032
$134 50 0
$0
$0
$0 2033
$134 50 0
$0
$0
$0 2034
$134 50 0
$0
$0
$0 2035
$134 50 0
$0
$0
$0 2036
$134 50 0
$0
$0
$0 20
$134,180
$100,692
$118,252 Issue 13:
Category 1 OperationsGreenhouse Gas Emissions During Operation Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 48 8
$51,525
$42,060
$47,153 2027
$134 48 2
$12,881
$9,827
$11,445 2028
$134 48 8
$51,525
$36,737
$44,446 2029
$134 48 1
$6,441
$4,292
$5,394 2030
$134 48 0
$0
$0
$0 2031
$134 48 1
$6,441
$3,749
$5,084 2032
$134 48 0
$0
$0
$0 2033
$134 48 0
$0
$0
$0 2034
$134 48 0
$0
$0
$0 2035
$134 48 0
$0
$0
$0 2036
$134 48 0
$0
$0
$0 20
$128,813
$96,664
$113,522 Issue 14:
Category 1 OperationsCooling System Emissions Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 11 8
$11,808
$9,639
$10,806 2027
$134 11 2
$2,952
$2,252
$2,623 2028
$134 11 8
$11,808
$8,419
$10,186 2029
$134 11 1
$1,476
$984
$1,236 2030
$134 11 0
$0
$0
$0 2031
$134 11 1
$1,476
$859
$1,165 2032
$134 11 0
$0
$0
$0
Regulatory Analysis Page A-7 2033
$134 11 0
$0
$0
$0 2034
$134 11 0
$0
$0
$0 2035
$134 11 0
$0
$0
$0 2036
$134 11 0
$0
$0
$0 20
$29,520
$22,152
$26,016 Issue 15:
Category 1 OperationsEmissions of Ozone and Nitrogen Oxides During Transmission Line Operation Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 6
8
$6,441
$5,257
$5,894 2027
$134 6
2
$1,610
$1,228
$1,431 2028
$134 6
8
$6,441
$4,592
$5,556 2029
$134 6
1
$805
$536
$674 2030
$134 6
0
$0
$0
$0 2031
$134 6
1
$805
$469
$636 2032
$134 6
0
$0
$0
$0 2033
$134 6
0
$0
$0
$0 2034
$134 6
0
$0
$0
$0 2035
$134 6
0
$0
$0
$0 2036
$134 6
0
$0
$0
$0 20
$16,102
$12,083
$14,190 Issue 16:
Category 1 ConstructionSurface Water Use Conflicts During Construction Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 17 8
$18,249
$14,896
$16,700 2027
$134 17 2
$4,562
$3,480
$4,053 2028
$134 17 8
$18,249
$13,011
$15,741 2029
$134 17 1
$2,281
$1,520
$1,910 2030
$134 17 0
$0
$0
$0 2031
$134 17 1
$2,281
$1,328
$1,801 2032
$134 17 0
$0
$0
$0 2033
$134 17 0
$0
$0
$0 2034
$134 17 0
$0
$0
$0 2035
$134 17 0
$0
$0
$0 2036
$134 17 0
$0
$0
$0 20
$45,621
$34,235
$40,206 Issue 17:
Category 1 ConstructionGroundwater Use Conflicts Due to Excavation Dewatering Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 117 8
$125,593
$102,521
$114,935 2027
$134 117 2
$31,398
$23,954
$27,897
Regulatory Analysis Page A-8 2028
$134 117 8
$125,593
$89,546
$108,337 2029
$134 117 1
$15,699
$10,461
$13,148 2030
$134 117 0
$0
$0
$0 2031
$134 117 1
$15,699
$9,137
$12,393 2032
$134 117 0
$0
$0
$0 2033
$134 117 0
$0
$0
$0 2034
$134 117 0
$0
$0
$0 2035
$134 117 0
$0
$0
$0 2036
$134 117 0
$0
$0
$0 20
$313,982
$235,619
$276,710 Issue 18:
Category 1 ConstructionGroundwater Use Conflicts Due to Construction-Related Groundwater Withdrawals Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 97 8
$104,124
$84,996
$95,288 2027
$134 97 2
$26,031
$19,859
$23,128 2028
$134 97 8
$104,124
$74,239
$89,818 2029
$134 97 1
$13,015
$8,673
$10,900 2030
$134 97 0
$0
$0
$0 2031
$134 97 1
$13,015
$7,575
$10,275 2032
$134 97 0
$0
$0
$0 2033
$134 97 0
$0
$0
$0 2034
$134 97 0
$0
$0
$0 2035
$134 97 0
$0
$0
$0 2036
$134 97 0
$0
$0
$0 20
$260,310
$195,342
$229,409 Issue 19:
Category 1 ConstructionWater Quality Degradation Due to Construction-Related Discharges Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 17 8
$18,249
$14,896
$16,700 2027
$134 17 2
$4,562
$3,480
$4,053 2028
$134 17 8
$18,249
$13,011
$15,741 2029
$134 17 1
$2,281
$1,520
$1,910 2030
$134 17 0
$0
$0
$0 2031
$134 17 1
$2,281
$1,328
$1,801 2032
$134 17 0
$0
$0
$0 2033
$134 17 0
$0
$0
$0 2034
$134 17 0
$0
$0
$0 2035
$134 17 0
$0
$0
$0 2036
$134 17 0
$0
$0
$0 20
$45,621
$34,235
$40,206 Issue 20:
Category 1 ConstructionWater Quality Degradation Due to Inadvertent Spills During Construction
Regulatory Analysis Page A-9 Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 17 8
$18,249
$14,896
$16,700 2027
$134 17 2
$4,562
$3,480
$4,053 2028
$134 17 8
$18,249
$13,011
$15,741 2029
$134 17 1
$2,281
$1,520
$1,910 2030
$134 17 0
$0
$0
$0 2031
$134 17 1
$2,281
$1,328
$1,801 2032
$134 17 0
$0
$0
$0 2033
$134 17 0
$0
$0
$0 2034
$134 17 0
$0
$0
$0 2035
$134 17 0
$0
$0
$0 2036
$134 17 0
$0
$0
$0 20
$45,621
$34,235
$40,206 Issue 21:
Category 1 ConstructionWater Quality Degradation Due to Groundwater Withdrawal Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 39 8
$41,864
$34,174
$38,312 2027
$134 39 2
$10,466
$7,985
$9,299 2028
$134 39 8
$41,864
$29,849
$36,112 2029
$134 39 1
$5,233
$3,487
$4,383 2030
$134 39 0
$0
$0
$0 2031
$134 39 1
$5,233
$3,046
$4,131 2032
$134 39 0
$0
$0
$0 2033
$134 39 0
$0
$0
$0 2034
$134 39 0
$0
$0
$0 2035
$134 39 0
$0
$0
$0 2036
$134 39 0
$0
$0
$0 20
$104,661
$78,540
$92,237 Issue 22:
Category 1 ConstructionWater Quality Degradation Due to Offshore or In-Water Construction Activities Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 67 8
$71,921
$58,709
$65,818 2027
$134 67 2
$17,980
$13,717
$15,975 2028
$134 67 8
$71,921
$51,278
$62,039 2029
$134 67 1
$8,990
$5,990
$7,529 2030
$134 67 0
$0
$0
$0 2031
$134 67 1
$8,990
$5,232
$7,097 2032
$134 67 0
$0
$0
$0 2033
$134 67 0
$0
$0
$0
Regulatory Analysis Page A-10 2034
$134 67 0
$0
$0
$0 2035
$134 67 0
$0
$0
$0 2036
$134 67 0
$0
$0
$0 20
$179,802
$134,927
$158,458 Issue 23:
Category 1 ConstructionWater Use Conflict Due to Plant Municipal Water Demand Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 67 8
$71,921
$58,709
$65,818 2027
$134 67 2
$17,980
$13,717
$15,975 2028
$134 67 8
$71,921
$51,278
$62,039 2029
$134 67 1
$8,990
$5,990
$7,529 2030
$134 67 0
$0
$0
$0 2031
$134 67 1
$8,990
$5,232
$7,097 2032
$134 67 0
$0
$0
$0 2033
$134 67 0
$0
$0
$0 2034
$134 67 0
$0
$0
$0 2035
$134 67 0
$0
$0
$0 2036
$134 67 0
$0
$0
$0 20
$179,802
$134,927
$158,458 Issue 24:
Category 1 ConstructionDegradation of Water Quality from Plant Effluent Discharges to Municipal Systems Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 150 8
$161,016
$131,437
$147,353 2027
$134 150 2
$40,254
$30,710
$35,765 2028
$134 150 8
$161,016
$114,802
$138,894 2029
$134 150 1
$20,127
$13,412
$16,856 2030
$134 150 0
$0
$0
$0 2031
$134 150 1
$20,127
$11,714
$15,888 2032
$134 150 0
$0
$0
$0 2033
$134 150 0
$0
$0
$0 2034
$134 150 0
$0
$0
$0 2035
$134 150 0
$0
$0
$0 2036
$134 150 0
$0
$0
$0 20
$402,541
$302,075
$354,757 Issue 25:
Category 1 OperationsSurface Water Use Conflicts During Operation Due to Water Withdrawal from Flowing Waterbodies Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 109 8
$117,005
$95,511
$107,076 2027
$134 109 2
$29,251
$22,316
$25,989 2028
$134 109 8
$117,005
$83,423
$100,930
Regulatory Analysis Page A-11 2029
$134 109 1
$14,626
$9,746
$12,249 2030
$134 109 0
$0
$0
$0 2031
$134 109 1
$14,626
$8,512
$11,546 2032
$134 109 0
$0
$0
$0 2033
$134 109 0
$0
$0
$0 2034
$134 109 0
$0
$0
$0 2035
$134 109 0
$0
$0
$0 2036
$134 109 0
$0
$0
$0 20
$292,513
$219,508
$257,790 Issue 26:
Category 1 OperationsSurface Water Use Conflicts During Operation Due to Water Withdrawal from Non-Flowing Waterbodies Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 39 8
$41,864
$34,174
$38,312 2027
$134 39 2
$10,466
$7,985
$9,299 2028
$134 39 8
$41,864
$29,849
$36,112 2029
$134 39 1
$5,233
$3,487
$4,383 2030
$134 39 0
$0
$0
$0 2031
$134 39 1
$5,233
$3,046
$4,131 2032
$134 39 0
$0
$0
$0 2033
$134 39 0
$0
$0
$0 2034
$134 39 0
$0
$0
$0 2035
$134 39 0
$0
$0
$0 2036
$134 39 0
$0
$0
$0 20
$104,661
$78,540
$92,237 Issue 27:
Category 1 OperationsGroundwater Use Conflicts Due to Building Foundation Dewatering Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 29 8
$31,130
$25,411
$28,488 2027
$134 29 2
$7,782
$5,937
$6,915 2028
$134 29 8
$31,130
$22,195
$26,853 2029
$134 29 1
$3,891
$2,593
$3,259 2030
$134 29 0
$0
$0
$0 2031
$134 29 1
$3,891
$2,265
$3,072 2032
$134 29 0
$0
$0
$0 2033
$134 29 0
$0
$0
$0 2034
$134 29 0
$0
$0
$0 2035
$134 29 0
$0
$0
$0 2036
$134 29 0
$0
$0
$0 20
$77,825
$58,401
$68,586 Issue 28:
Category 1 OperationsGroundwater Use Conflicts Due to Groundwater Withdrawals for Plant Uses
Regulatory Analysis Page A-12 Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 57 8
$61,186
$49,946
$55,994 2027
$134 57 2
$15,297
$11,670
$13,591 2028
$134 57 8
$61,186
$43,625
$52,780 2029
$134 57 1
$7,648
$5,096
$6,405 2030
$134 57 0
$0
$0
$0 2031
$134 57 1
$7,648
$4,451
$6,038 2032
$134 57 0
$0
$0
$0 2033
$134 57 0
$0
$0
$0 2034
$134 57 0
$0
$0
$0 2035
$134 57 0
$0
$0
$0 2036
$134 57 0
$0
$0
$0 20
$152,966
$114,789
$134,808 Issue 29:
Category 1 OperationsSurface Water Quality Degradation Due to Physical Effects from Operation of Intake and Discharge Structures Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 117 8
$125,593
$102,521
$114,935 2027
$134 117 2
$31,398
$23,954
$27,897 2028
$134 117 8
$125,593
$89,546
$108,337 2029
$134 117 1
$15,699
$10,461
$13,148 2030
$134 117 0
$0
$0
$0 2031
$134 117 1
$15,699
$9,137
$12,393 2032
$134 117 0
$0
$0
$0 2033
$134 117 0
$0
$0
$0 2034
$134 117 0
$0
$0
$0 2035
$134 117 0
$0
$0
$0 2036
$134 117 0
$0
$0
$0 20
$313,982
$235,619
$276,710 Issue 30:
Category 1 OperationsSurface Water Quality Degradation Due to Changes in Salinity Gradients Resulting from Withdrawals Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 194 8
$208,248
$169,992
$190,576 2027
$134 194 2
$52,062
$39,718
$46,256 2028
$134 194 8
$208,248
$148,478
$179,636 2029
$134 194 1
$26,031
$17,346
$21,801 2030
$134 194 0
$0
$0
$0 2031
$134 194 1
$26,031
$15,150
$20,549 2032
$134 194 0
$0
$0
$0 2033
$134 194 0
$0
$0
$0
Regulatory Analysis Page A-13 2034
$134 194 0
$0
$0
$0 2035
$134 194 0
$0
$0
$0 2036
$134 194 0
$0
$0
$0 20
$520,620
$390,684
$458,819 Issue 31:
Category 1 OperationsGroundwater Quality Degradation Due to Plant Discharges Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 57 8
$61,186
$49,946
$55,994 2027
$134 57 2
$15,297
$11,670
$13,591 2028
$134 57 8
$61,186
$43,625
$52,780 2029
$134 57 1
$7,648
$5,096
$6,405 2030
$134 57 0
$0
$0
$0 2031
$134 57 1
$7,648
$4,451
$6,038 2032
$134 57 0
$0
$0
$0 2033
$134 57 0
$0
$0
$0 2034
$134 57 0
$0
$0
$0 2035
$134 57 0
$0
$0
$0 2036
$134 57 0
$0
$0
$0 20
$152,966
$114,789
$134,808 Issue 32:
Category 1 OperationsWater Quality Degradation Due to Inadvertent Spills and Leaks During Operation Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 16 8
$17,175
$14,020
$15,718 2027
$134 16 2
$4,294
$3,276
$3,815 2028
$134 16 8
$17,175
$12,246
$14,815 2029
$134 16 1
$2,147
$1,431
$1,798 2030
$134 16 0
$0
$0
$0 2031
$134 16 1
$2,147
$1,250
$1,695 2032
$134 16 0
$0
$0
$0 2033
$134 16 0
$0
$0
$0 2034
$134 16 0
$0
$0
$0 2035
$134 16 0
$0
$0
$0 2036
$134 16 0
$0
$0
$0 20
$42,938
$32,221
$37,841 Issue 33:
Category 1 OperationsWater Quality Degradation Due to Groundwater Withdrawals Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 43 8
$46,158
$37,679
$42,241 2027
$134 43 2
$11,540
$8,803
$10,253 2028
$134 43 8
$46,158
$32,910
$39,816
Regulatory Analysis Page A-14 2029
$134 43 1
$5,770
$3,845
$4,832 2030
$134 43 0
$0
$0
$0 2031
$134 43 1
$5,770
$3,358
$4,555 2032
$134 43 0
$0
$0
$0 2033
$134 43 0
$0
$0
$0 2034
$134 43 0
$0
$0
$0 2035
$134 43 0
$0
$0
$0 2036
$134 43 0
$0
$0
$0 20
$115,395
$86,595
$101,697 Issue 34:
Category 1 OperationsWater Use Conflict from Plant Municipal Water Demand Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 16 8
$17,175
$14,020
$15,718 2027
$134 16 2
$4,294
$3,276
$3,815 2028
$134 16 8
$17,175
$12,246
$14,815 2029
$134 16 1
$2,147
$1,431
$1,798 2030
$134 16 0
$0
$0
$0 2031
$134 16 1
$2,147
$1,250
$1,695 2032
$134 16 0
$0
$0
$0 2033
$134 16 0
$0
$0
$0 2034
$134 16 0
$0
$0
$0 2035
$134 16 0
$0
$0
$0 2036
$134 16 0
$0
$0
$0 20
$42,938
$32,221
$37,841 Issue 35:
Category 1 OperationsDegradation of Water Quality from Plant Effluent Discharges to Municipal Systems Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 16 8
$17,175
$14,020
$15,718 2027
$134 16 2
$4,294
$3,276
$3,815 2028
$134 16 8
$17,175
$12,246
$14,815 2029
$134 16 1
$2,147
$1,431
$1,798 2030
$134 16 0
$0
$0
$0 2031
$134 16 1
$2,147
$1,250
$1,695 2032
$134 16 0
$0
$0
$0 2033
$134 16 0
$0
$0
$0 2034
$134 16 0
$0
$0
$0 2035
$134 16 0
$0
$0
$0 2036
$134 16 0
$0
$0
$0 20
$42,938
$32,221
$37,841 Issue 36:
Category 1 ConstructionPermanent and Temporary Loss, Conversion, Fragmentation, and Degradation of Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present 3% NPV
Regulatory Analysis Page A-15 Value (NPV) 2026
$134 168 8
$180,338
$147,210
$165,035 2027
$134 168 2
$45,085
$34,395
$40,057 2028
$134 168 8
$180,338
$128,579
$155,561 2029
$134 168 1
$22,542
$15,021
$18,879 2030
$134 168 0
$0
$0
$0 2031
$134 168 1
$22,542
$13,120
$17,795 2032
$134 168 0
$0
$0
$0 2033
$134 168 0
$0
$0
$0 2034
$134 168 0
$0
$0
$0 2035
$134 168 0
$0
$0
$0 2036
$134 168 0
$0
$0
$0 20
$450,846
$338,324
$397,328 Issue 37:
Category 1 ConstructionPermanent and Temporary Loss and Degradation of Wetlands Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 168 8
$180,338
$147,210
$165,035 2027
$134 168 2
$45,085
$34,395
$40,057 2028
$134 168 8
$180,338
$128,579
$155,561 2029
$134 168 1
$22,542
$15,021
$18,879 2030
$134 168 0
$0
$0
$0 2031
$134 168 1
$22,542
$13,120
$17,795 2032
$134 168 0
$0
$0
$0 2033
$134 168 0
$0
$0
$0 2034
$134 168 0
$0
$0
$0 2035
$134 168 0
$0
$0
$0 2036
$134 168 0
$0
$0
$0 20
$450,846
$338,324
$397,328 Issue 38:
Category 1 ConstructionEffects of Building Noise on Wildlife Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 60 8
$64,407
$52,575
$58,941 2027
$134 60 2
$16,102
$12,284
$14,306 2028
$134 60 8
$64,407
$45,921
$55,558 2029
$134 60 1
$8,051
$5,365
$6,742 2030
$134 60 0
$0
$0
$0 2031
$134 60 1
$8,051
$4,686
$6,355 2032
$134 60 0
$0
$0
$0 2033
$134 60 0
$0
$0
$0 2034
$134 60 0
$0
$0
$0 2035
$134 60 0
$0
$0
$0 2036
$134 60 0
$0
$0
$0
Regulatory Analysis Page A-16 20
$161,016
$120,830
$141,903 Issue 39:
Category 1 ConstructionEffects of Vehicular Collisions on Wildlife Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 50 8
$53,672
$43,812
$49,118 2027
$134 50 2
$13,418
$10,237
$11,922 2028
$134 50 8
$53,672
$38,267
$46,298 2029
$134 50 1
$6,709
$4,471
$5,619 2030
$134 50 0
$0
$0
$0 2031
$134 50 1
$6,709
$3,905
$5,296 2032
$134 50 0
$0
$0
$0 2033
$134 50 0
$0
$0
$0 2034
$134 50 0
$0
$0
$0 2035
$134 50 0
$0
$0
$0 2036
$134 50 0
$0
$0
$0 20
$134,180
$100,692
$118,252 Issue 40:
Category 1 ConstructionBird Collisions and Injury from Structures and Transmission Lines Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 60 8
$64,407
$52,575
$58,941 2027
$134 60 2
$16,102
$12,284
$14,306 2028
$134 60 8
$64,407
$45,921
$55,558 2029
$134 60 1
$8,051
$5,365
$6,742 2030
$134 60 0
$0
$0
$0 2031
$134 60 1
$8,051
$4,686
$6,355 2032
$134 60 0
$0
$0
$0 2033
$134 60 0
$0
$0
$0 2034
$134 60 0
$0
$0
$0 2035
$134 60 0
$0
$0
$0 2036
$134 60 0
$0
$0
$0 20
$161,016
$120,830
$141,903 Issue 41:
Category 1 ConstructionImportant Species and HabitatsOther Important Species and Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 84 8
$90,169
$73,605
$82,518 2027
$134 84 2
$22,542
$17,197
$20,029 2028
$134 84 8
$90,169
$64,289
$77,781 2029
$134 84 1
$11,271
$7,510
$9,439 2030
$134 84 0
$0
$0
$0 2031
$134 84 1
$11,271
$6,560
$8,898
Regulatory Analysis Page A-17 2032
$134 84 0
$0
$0
$0 2033
$134 84 0
$0
$0
$0 2034
$134 84 0
$0
$0
$0 2035
$134 84 0
$0
$0
$0 2036
$134 84 0
$0
$0
$0 20
$225,423
$169,162
$198,664 Issue 42:
Category 1 OperationsPermanent and Temporary Loss or Disturbance of Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 19 8
$20,395
$16,649
$18,665 2027
$134 19 2
$5,099
$3,890
$4,530 2028
$134 19 8
$20,395
$14,542
$17,593 2029
$134 19 1
$2,549
$1,699
$2,135 2030
$134 19 0
$0
$0
$0 2031
$134 19 1
$2,549
$1,484
$2,013 2032
$134 19 0
$0
$0
$0 2033
$134 19 0
$0
$0
$0 2034
$134 19 0
$0
$0
$0 2035
$134 19 0
$0
$0
$0 2036
$134 19 0
$0
$0
$0 20
$50,989
$38,263
$44,936 Issue 43:
Category 1 OperationsEffects of Operational Noise on Wildlife Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 11 8
$11,808
$9,639
$10,806 2027
$134 11 2
$2,952
$2,252
$2,623 2028
$134 11 8
$11,808
$8,419
$10,186 2029
$134 11 1
$1,476
$984
$1,236 2030
$134 11 0
$0
$0
$0 2031
$134 11 1
$1,476
$859
$1,165 2032
$134 11 0
$0
$0
$0 2033
$134 11 0
$0
$0
$0 2034
$134 11 0
$0
$0
$0 2035
$134 11 0
$0
$0
$0 2036
$134 11 0
$0
$0
$0 20
$29,520
$22,152
$26,016 Issue 44:
Category 1 OperationsEffects of Vehicular Collisions on Wildlife Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 9
8
$9,661
$7,886
$8,841 2027
$134 9
2
$2,415
$1,843
$2,146 2028
$134 9
8
$9,661
$6,888
$8,334
Regulatory Analysis Page A-18 2029
$134 9
1
$1,208
$805
$1,011 2030
$134 9
0
$0
$0
$0 2031
$134 9
1
$1,208
$703
$953 2032
$134 9
0
$0
$0
$0 2033
$134 9
0
$0
$0
$0 2034
$134 9
0
$0
$0
$0 2035
$134 9
0
$0
$0
$0 2036
$134 9
0
$0
$0
$0 20
$24,152
$18,125
$21,285 Issue 45:
Category 1 ConstructionExposure of Terrestrial Organisms to Radionuclides Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 38 8
$40,791
$33,297
$37,329 2027
$134 38 2
$10,198
$7,780
$9,061 2028
$134 38 8
$40,791
$29,083
$35,187 2029
$134 38 1
$5,099
$3,398
$4,270 2030
$134 38 0
$0
$0
$0 2031
$134 38 1
$5,099
$2,968
$4,025 2032
$134 38 0
$0
$0
$0 2033
$134 38 0
$0
$0
$0 2034
$134 38 0
$0
$0
$0 2035
$134 38 0
$0
$0
$0 2036
$134 38 0
$0
$0
$0 20
$101,977
$76,526
$89,872 Issue 46:
Category 1 OperationsCooling Tower Operational Impacts on Vegetation Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 37 8
$39,717
$32,421
$36,347 2027
$134 37 2
$9,929
$7,575
$8,822 2028
$134 37 8
$39,717
$28,318
$34,261 2029
$134 37 1
$4,965
$3,308
$4,158 2030
$134 37 0
$0
$0
$0 2031
$134 37 1
$4,965
$2,889
$3,919 2032
$134 37 0
$0
$0
$0 2033
$134 37 0
$0
$0
$0 2034
$134 37 0
$0
$0
$0 2035
$134 37 0
$0
$0
$0 2036
$134 37 0
$0
$0
$0 20
$99,293
$74,512
$87,507 Issue 47:
Category 1 OperationsBird Collisions and Injury from Structures and Transmission Lines Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present 3% NPV
Regulatory Analysis Page A-19 Value (NPV) 2026
$134 19 8
$20,395
$16,649
$18,665 2027
$134 19 2
$5,099
$3,890
$4,530 2028
$134 19 8
$20,395
$14,542
$17,593 2029
$134 19 1
$2,549
$1,699
$2,135 2030
$134 19 0
$0
$0
$0 2031
$134 19 1
$2,549
$1,484
$2,013 2032
$134 19 0
$0
$0
$0 2033
$134 19 0
$0
$0
$0 2034
$134 19 0
$0
$0
$0 2035
$134 19 0
$0
$0
$0 2036
$134 19 0
$0
$0
$0 20
$50,989
$38,263
$44,936 Issue 48:
Category 1 OperationsBird Electrocutions from Transmission Lines Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 19 8
$20,395
$16,649
$18,665 2027
$134 19 2
$5,099
$3,890
$4,530 2028
$134 19 8
$20,395
$14,542
$17,593 2029
$134 19 1
$2,549
$1,699
$2,135 2030
$134 19 0
$0
$0
$0 2031
$134 19 1
$2,549
$1,484
$2,013 2032
$134 19 0
$0
$0
$0 2033
$134 19 0
$0
$0
$0 2034
$134 19 0
$0
$0
$0 2035
$134 19 0
$0
$0
$0 2036
$134 19 0
$0
$0
$0 20
$50,989
$38,263
$44,936 Issue 49:
Category 1 OperationsWater Use Conflicts with Terrestrial Resources Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 83 8
$89,096
$72,729
$81,535 2027
$134 83 2
$22,274
$16,993
$19,790 2028
$134 83 8
$89,096
$63,524
$76,855 2029
$134 83 1
$11,137
$7,421
$9,327 2030
$134 83 0
$0
$0
$0 2031
$134 83 1
$11,137
$6,482
$8,792 2032
$134 83 0
$0
$0
$0 2033
$134 83 0
$0
$0
$0 2034
$134 83 0
$0
$0
$0 2035
$134 83 0
$0
$0
$0 2036
$134 83 0
$0
$0
$0 20
$222,739
$167,148
$196,299
Regulatory Analysis Page A-20 Issue 50:
Category 1 OperationsEffects of Transmission Line ROW Management on Terrestrial Resources Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 23 8
$24,689
$20,154
$22,594 2027
$134 23 2
$6,172
$4,709
$5,484 2028
$134 23 8
$24,689
$17,603
$21,297 2029
$134 23 1
$3,086
$2,056
$2,585 2030
$134 23 0
$0
$0
$0 2031
$134 23 1
$3,086
$1,796
$2,436 2032
$134 23 0
$0
$0
$0 2033
$134 23 0
$0
$0
$0 2034
$134 23 0
$0
$0
$0 2035
$134 23 0
$0
$0
$0 2036
$134 23 0
$0
$0
$0 20
$61,723
$46,318
$54,396 Issue 51:
Category 1 OperationsEffects of Electromagnetic Fields on Flora and Fauna Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 4
8
$4,294
$3,505
$3,929 2027
$134 4
2
$1,073
$819
$954 2028
$134 4
8
$4,294
$3,061
$3,704 2029
$134 4
1
$537
$358
$449 2030
$134 4
0
$0
$0
$0 2031
$134 4
1
$537
$312
$424 2032
$134 4
0
$0
$0
$0 2033
$134 4
0
$0
$0
$0 2034
$134 4
0
$0
$0
$0 2035
$134 4
0
$0
$0
$0 2036
$134 4
0
$0
$0
$0 20
$10,734
$8,055
$9,460 Issue 52:
Category 1 OperationsImportant Species and HabitatsOther Important Species and Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 37 8
$39,717
$32,421
$36,347 2027
$134 37 2
$9,929
$7,575
$8,822 2028
$134 37 8
$39,717
$28,318
$34,261 2029
$134 37 1
$4,965
$3,308
$4,158 2030
$134 37 0
$0
$0
$0 2031
$134 37 1
$4,965
$2,889
$3,919 2032
$134 37 0
$0
$0
$0
Regulatory Analysis Page A-21 2033
$134 37 0
$0
$0
$0 2034
$134 37 0
$0
$0
$0 2035
$134 37 0
$0
$0
$0 2036
$134 37 0
$0
$0
$0 20
$99,293
$74,512
$87,507 Issue 53:
Category 1 ConstructionRunoff and Sedimentation from Construction Areas Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 128 8
$137,401
$112,160
$125,741 2027
$134 128 2
$34,350
$26,206
$30,520 2028
$134 128 8
$137,401
$97,965
$118,523 2029
$134 128 1
$17,175
$11,444
$14,384 2030
$134 128 0
$0
$0
$0 2031
$134 128 1
$17,175
$9,996
$13,558 2032
$134 128 0
$0
$0
$0 2033
$134 128 0
$0
$0
$0 2034
$134 128 0
$0
$0
$0 2035
$134 128 0
$0
$0
$0 2036
$134 128 0
$0
$0
$0 20
$343,502
$257,771
$302,726 Issue 54:
Category 1 ConstructionDredging and Filling Aquatic Habitats to Build Intake and Discharge Structures Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 128 8
$137,401
$112,160
$125,741 2027
$134 128 2
$34,350
$26,206
$30,520 2028
$134 128 8
$137,401
$97,965
$118,523 2029
$134 128 1
$17,175
$11,444
$14,384 2030
$134 128 0
$0
$0
$0 2031
$134 128 1
$17,175
$9,996
$13,558 2032
$134 128 0
$0
$0
$0 2033
$134 128 0
$0
$0
$0 2034
$134 128 0
$0
$0
$0 2035
$134 128 0
$0
$0
$0 2036
$134 128 0
$0
$0
$0 20
$343,502
$257,771
$302,726 Issue 55:
Category 1 ConstructionBuilding Transmission Lines, Pipelines, and Access Roads Across Surface Waterbodies Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 128 8
$137,401
$112,160
$125,741 2027
$134 128 2
$34,350
$26,206
$30,520
Regulatory Analysis Page A-22 2028
$134 128 8
$137,401
$97,965
$118,523 2029
$134 128 1
$17,175
$11,444
$14,384 2030
$134 128 0
$0
$0
$0 2031
$134 128 1
$17,175
$9,996
$13,558 2032
$134 128 0
$0
$0
$0 2033
$134 128 0
$0
$0
$0 2034
$134 128 0
$0
$0
$0 2035
$134 128 0
$0
$0
$0 2036
$134 128 0
$0
$0
$0 20
$343,502
$257,771
$302,726 Issue 56:
Category 1 OperationsImportant Species and HabitatsOther Important Species and Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 128 8
$137,401
$112,160
$125,741 2027
$134 128 2
$34,350
$26,206
$30,520 2028
$134 128 8
$137,401
$97,965
$118,523 2029
$134 128 1
$17,175
$11,444
$14,384 2030
$134 128 0
$0
$0
$0 2031
$134 128 1
$17,175
$9,996
$13,558 2032
$134 128 0
$0
$0
$0 2033
$134 128 0
$0
$0
$0 2034
$134 128 0
$0
$0
$0 2035
$134 128 0
$0
$0
$0 2036
$134 128 0
$0
$0
$0 20
$343,502
$257,771
$302,726 Issue 57:
Category 1 OperationsStormwater Runoff Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 20 8
$21,469
$17,525
$19,647 2027
$134 20 2
$5,367
$4,095
$4,769 2028
$134 20 8
$21,469
$15,307
$18,519 2029
$134 20 1
$2,684
$1,788
$2,247 2030
$134 20 0
$0
$0
$0 2031
$134 20 1
$2,684
$1,562
$2,118 2032
$134 20 0
$0
$0
$0 2033
$134 20 0
$0
$0
$0 2034
$134 20 0
$0
$0
$0 2035
$134 20 0
$0
$0
$0 2036
$134 20 0
$0
$0
$0 20
$53,672
$40,277
$47,301 Issue 58:
Category 1 OperationsExposure of Aquatic Organisms to Radionuclides Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present 3% NPV
Regulatory Analysis Page A-23 Value (NPV) 2026
$134 38 8
$40,791
$33,297
$37,329 2027
$134 38 2
$10,198
$7,780
$9,061 2028
$134 38 8
$40,791
$29,083
$35,187 2029
$134 38 1
$5,099
$3,398
$4,270 2030
$134 38 0
$0
$0
$0 2031
$134 38 1
$5,099
$2,968
$4,025 2032
$134 38 0
$0
$0
$0 2033
$134 38 0
$0
$0
$0 2034
$134 38 0
$0
$0
$0 2035
$134 38 0
$0
$0
$0 2036
$134 38 0
$0
$0
$0 20
$101,977
$76,526
$89,872 Issue 59:
Category 1 OperationsEffects of Refurbishment on Aquatic Biota Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 20 8
$21,469
$17,525
$19,647 2027
$134 20 2
$5,367
$4,095
$4,769 2028
$134 20 8
$21,469
$15,307
$18,519 2029
$134 20 1
$2,684
$1,788
$2,247 2030
$134 20 0
$0
$0
$0 2031
$134 20 1
$2,684
$1,562
$2,118 2032
$134 20 0
$0
$0
$0 2033
$134 20 0
$0
$0
$0 2034
$134 20 0
$0
$0
$0 2035
$134 20 0
$0
$0
$0 2036
$134 20 0
$0
$0
$0 20
$53,672
$40,277
$47,301 Issue 60:
Category 1 OperationsEffects of Maintenance Dredging on Aquatic Biota Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 97 8
$104,124
$84,996
$95,288 2027
$134 97 2
$26,031
$19,859
$23,128 2028
$134 97 8
$104,124
$74,239
$89,818 2029
$134 97 1
$13,015
$8,673
$10,900 2030
$134 97 0
$0
$0
$0 2031
$134 97 1
$13,015
$7,575
$10,275 2032
$134 97 0
$0
$0
$0 2033
$134 97 0
$0
$0
$0 2034
$134 97 0
$0
$0
$0 2035
$134 97 0
$0
$0
$0 2036
$134 97 0
$0
$0
$0 20
$260,310
$195,342
$229,409
Regulatory Analysis Page A-24 Issue 61:
Category 1 OperationsImpacts of Transmission Line Right-of-Way Management on Aquatic Resources Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 48 8
$51,525
$42,060
$47,153 2027
$134 48 2
$12,881
$9,827
$11,445 2028
$134 48 8
$51,525
$36,737
$44,446 2029
$134 48 1
$6,441
$4,292
$5,394 2030
$134 48 0
$0
$0
$0 2031
$134 48 1
$6,441
$3,749
$5,084 2032
$134 48 0
$0
$0
$0 2033
$134 48 0
$0
$0
$0 2034
$134 48 0
$0
$0
$0 2035
$134 48 0
$0
$0
$0 2036
$134 48 0
$0
$0
$0 20
$128,813
$96,664
$113,522 Issue 62:
Category 1 OperationsImpingement and Entrainment of Aquatic Organisms Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 145 8
$155,649
$127,056
$142,441 2027
$134 145 2
$38,912
$29,686
$34,573 2028
$134 145 8
$155,649
$110,976
$134,264 2029
$134 145 1
$19,456
$12,964
$16,294 2030
$134 145 0
$0
$0
$0 2031
$134 145 1
$19,456
$11,324
$15,359 2032
$134 145 0
$0
$0
$0 2033
$134 145 0
$0
$0
$0 2034
$134 145 0
$0
$0
$0 2035
$134 145 0
$0
$0
$0 2036
$134 145 0
$0
$0
$0 20
$389,123
$292,006
$342,932 Issue 63:
Category 1 OperationsWater Use Conflicts with Aquatic Resources Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 48 8
$51,525
$42,060
$47,153 2027
$134 48 2
$12,881
$9,827
$11,445 2028
$134 48 8
$51,525
$36,737
$44,446 2029
$134 48 1
$6,441
$4,292
$5,394 2030
$134 48 0
$0
$0
$0 2031
$134 48 1
$6,441
$3,749
$5,084 2032
$134 48 0
$0
$0
$0 2033
$134 48 0
$0
$0
$0
Regulatory Analysis Page A-25 2034
$134 48 0
$0
$0
$0 2035
$134 48 0
$0
$0
$0 2036
$134 48 0
$0
$0
$0 20
$128,813
$96,664
$113,522 Issue 64:
Category 1 OperationsImportant Species and HabitatsOther Important Species and Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 145 8
$155,649
$127,056
$142,441 2027
$134 145 2
$38,912
$29,686
$34,573 2028
$134 145 8
$155,649
$110,976
$134,264 2029
$134 145 1
$19,456
$12,964
$16,294 2030
$134 145 0
$0
$0
$0 2031
$134 145 1
$19,456
$11,324
$15,359 2032
$134 145 0
$0
$0
$0 2033
$134 145 0
$0
$0
$0 2034
$134 145 0
$0
$0
$0 2035
$134 145 0
$0
$0
$0 2036
$134 145 0
$0
$0
$0 20
$389,123
$292,006
$342,932 Issue 65:
Category 1 ConstructionRadiological Dose to Construction Workers Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 117 8
$125,593
$102,521
$114,935 2027
$134 117 2
$31,398
$23,954
$27,897 2028
$134 117 8
$125,593
$89,546
$108,337 2029
$134 117 1
$15,699
$10,461
$13,148 2030
$134 117 0
$0
$0
$0 2031
$134 117 1
$15,699
$9,137
$12,393 2032
$134 117 0
$0
$0
$0 2033
$134 117 0
$0
$0
$0 2034
$134 117 0
$0
$0
$0 2035
$134 117 0
$0
$0
$0 2036
$134 117 0
$0
$0
$0 20
$313,982
$235,619
$276,710 Issue 66:
Category 1 OperationsOccupational Doses to Workers Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 38 8
$40,791
$33,297
$37,329 2027
$134 38 2
$10,198
$7,780
$9,061 2028
$134 38 8
$40,791
$29,083
$35,187 2029
$134 38 1
$5,099
$3,398
$4,270
Regulatory Analysis Page A-26 2030
$134 38 0
$0
$0
$0 2031
$134 38 1
$5,099
$2,968
$4,025 2032
$134 38 0
$0
$0
$0 2033
$134 38 0
$0
$0
$0 2034
$134 38 0
$0
$0
$0 2035
$134 38 0
$0
$0
$0 2036
$134 38 0
$0
$0
$0 20
$101,977
$76,526
$89,872 Issue 67:
Category 1 OperationsMaximally Exposed Individual Annual Doses Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 38 8
$40,791
$33,297
$37,329 2027
$134 38 2
$10,198
$7,780
$9,061 2028
$134 38 8
$40,791
$29,083
$35,187 2029
$134 38 1
$5,099
$3,398
$4,270 2030
$134 38 0
$0
$0
$0 2031
$134 38 1
$5,099
$2,968
$4,025 2032
$134 38 0
$0
$0
$0 2033
$134 38 0
$0
$0
$0 2034
$134 38 0
$0
$0
$0 2035
$134 38 0
$0
$0
$0 2036
$134 38 0
$0
$0
$0 20
$101,977
$76,526
$89,872 Issue 68:
Category 1 OperationsTotal Population Annual Doses Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 42 8
$45,085
$36,802
$41,259 2027
$134 42 2
$11,271
$8,599
$10,014 2028
$134 42 8
$45,085
$32,145
$38,890 2029
$134 42 1
$5,636
$3,755
$4,720 2030
$134 42 0
$0
$0
$0 2031
$134 42 1
$5,636
$3,280
$4,449 2032
$134 42 0
$0
$0
$0 2033
$134 42 0
$0
$0
$0 2034
$134 42 0
$0
$0
$0 2035
$134 42 0
$0
$0
$0 2036
$134 42 0
$0
$0
$0 20
$112,712
$84,581
$99,332 Issue 69:
Category 1 OperationsNonhuman Biota Doses Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 42 8
$45,085
$36,802
$41,259
Regulatory Analysis Page A-27 2027
$134 42 2
$11,271
$8,599
$10,014 2028
$134 42 8
$45,085
$32,145
$38,890 2029
$134 42 1
$5,636
$3,755
$4,720 2030
$134 42 0
$0
$0
$0 2031
$134 42 1
$5,636
$3,280
$4,449 2032
$134 42 0
$0
$0
$0 2033
$134 42 0
$0
$0
$0 2034
$134 42 0
$0
$0
$0 2035
$134 42 0
$0
$0
$0 2036
$134 42 0
$0
$0
$0 20
$112,712
$84,581
$99,332 Issue 70:
Category 1 ConstructionBuilding Impacts of Chemical, Biological, and Physical Nonradiological Hazards Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 52 8
$55,819
$45,565
$51,082 2027
$134 52 2
$13,955
$10,646
$12,399 2028
$134 52 8
$55,819
$39,798
$48,150 2029
$134 52 1
$6,977
$4,649
$5,843 2030
$134 52 0
$0
$0
$0 2031
$134 52 1
$6,977
$4,061
$5,508 2032
$134 52 0
$0
$0
$0 2033
$134 52 0
$0
$0
$0 2034
$134 52 0
$0
$0
$0 2035
$134 52 0
$0
$0
$0 2036
$134 52 0
$0
$0
$0 20
$139,548
$104,719
$122,982 Issue 71:
Category 1 OperationsOperation Impacts of Chemical, Biological, and Physical Nonradiological Hazards Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 35 8
$37,571
$30,669
$34,382 2027
$134 35 2
$9,393
$7,166
$8,345 2028
$134 35 8
$37,571
$26,787
$32,409 2029
$134 35 1
$4,696
$3,129
$3,933 2030
$134 35 0
$0
$0
$0 2031
$134 35 1
$4,696
$2,733
$3,707 2032
$134 35 0
$0
$0
$0 2033
$134 35 0
$0
$0
$0 2034
$134 35 0
$0
$0
$0 2035
$134 35 0
$0
$0
$0 2036
$134 35 0
$0
$0
$0 20
$93,926
$70,484
$82,777 Issue 72:
Category 1 ConstructionConstruction-Related Noise
Regulatory Analysis Page A-28 Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 23 8
$24,689
$20,154
$22,594 2027
$134 23 2
$6,172
$4,709
$5,484 2028
$134 23 8
$24,689
$17,603
$21,297 2029
$134 23 1
$3,086
$2,056
$2,585 2030
$134 23 0
$0
$0
$0 2031
$134 23 1
$3,086
$1,796
$2,436 2032
$134 23 0
$0
$0
$0 2033
$134 23 0
$0
$0
$0 2034
$134 23 0
$0
$0
$0 2035
$134 23 0
$0
$0
$0 2036
$134 23 0
$0
$0
$0 20
$61,723
$46,318
$54,396 Issue 73:
Category 1 OperationsOperation-Related Noise Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 14 8
$15,028
$12,267
$13,753 2027
$134 14 2
$3,757
$2,866
$3,338 2028
$134 14 8
$15,028
$10,715
$12,963 2029
$134 14 1
$1,879
$1,252
$1,573 2030
$134 14 0
$0
$0
$0 2031
$134 14 1
$1,879
$1,093
$1,483 2032
$134 14 0
$0
$0
$0 2033
$134 14 0
$0
$0
$0 2034
$134 14 0
$0
$0
$0 2035
$134 14 0
$0
$0
$0 2036
$134 14 0
$0
$0
$0 20
$37,571
$28,194
$33,111 Issue 74:
Category 1 OperationsLow-Level Radioactive Waste Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 232 8
$249,039
$203,290
$227,906 2027
$134 232 2
$62,260
$47,498
$55,317 2028
$134 232 8
$249,039
$177,561
$214,823 2029
$134 232 1
$31,130
$20,743
$26,071 2030
$134 232 0
$0
$0
$0 2031
$134 232 1
$31,130
$18,118
$24,574 2032
$134 232 0
$0
$0
$0 2033
$134 232 0
$0
$0
$0 2034
$134 232 0
$0
$0
$0 2035
$134 232 0
$0
$0
$0
Regulatory Analysis Page A-29 2036
$134 232 0
$0
$0
$0 20
$622,597
$467,210
$548,691 Issue 75:
Category 1 OperationsOnsite Spent Nuclear Fuel Management Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 232 8
$249,039
$203,290
$227,906 2027
$134 232 2
$62,260
$47,498
$55,317 2028
$134 232 8
$249,039
$177,561
$214,823 2029
$134 232 1
$31,130
$20,743
$26,071 2030
$134 232 0
$0
$0
$0 2031
$134 232 1
$31,130
$18,118
$24,574 2032
$134 232 0
$0
$0
$0 2033
$134 232 0
$0
$0
$0 2034
$134 232 0
$0
$0
$0 2035
$134 232 0
$0
$0
$0 2036
$134 232 0
$0
$0
$0 20
$622,597
$467,210
$548,691 Issue 76:
Category 1 OperationsMixed Waste Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$134 232 8
$249,039
$203,290
$227,906 2027
$134 232 2
$62,260
$47,498
$55,317 2028
$134 232 8
$249,039
$177,561
$214,823 2029
$134 232 1
$31,130
$20,743
$26,071 2030
$134 232 0
$0
$0
$0 2031
$134 232 1
$31,130
$18,118
$24,574 2032
$134 232 0
$0
$0
$0 2033
$134 232 0
$0
$0
$0 2034
$134 232 0
$0
$0
$0 2035
$134 232 0
$0
$0
$0 2036
$134 232 0
$0
$0
$0 20
$622,597
$467,210
$548,691 Issue 77:
Category 1 ConstructionConstruction Nonradiological Waste Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 38 8
$40,791
$33,297
$37,329 2027
$134 38 2
$10,198
$7,780
$9,061 2028
$134 38 8
$40,791
$29,083
$35,187
Regulatory Analysis Page A-30 2029
$134 38 1
$5,099
$3,398
$4,270 2030
$134 38 0
$0
$0
$0 2031
$134 38 1
$5,099
$2,968
$4,025 2032
$134 38 0
$0
$0
$0 2033
$134 38 0
$0
$0
$0 2034
$134 38 0
$0
$0
$0 2035
$134 38 0
$0
$0
$0 2036
$134 38 0
$0
$0
$0 20
$101,977
$76,526
$89,872 Issue 78:
Category 1 Operations-Operation Nonradiological Waste Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 25 8
$26,836
$21,906
$24,559 2027
$134 25 2
$6,709
$5,118
$5,961 2028
$134 25 8
$26,836
$19,134
$23,149 2029
$134 25 1
$3,355
$2,235
$2,809 2030
$134 25 0
$0
$0
$0 2031
$134 25 1
$3,355
$1,952
$2,648 2032
$134 25 0
$0
$0
$0 2033
$134 25 0
$0
$0
$0 2034
$134 25 0
$0
$0
$0 2035
$134 25 0
$0
$0
$0 2036
$134 25 0
$0
$0
$0 20
$67,090
$50,346
$59,126 Issue 79:
Category 1 Operations-Design Basis Accidents Involving Radiological Releases Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 172 8
$184,632
$150,715
$168,965 2027
$134 172 2
$46,158
$35,214
$41,011 2028
$134 172 8
$184,632
$131,640
$159,265 2029
$134 172 1
$23,079
$15,379
$19,328 2030
$134 172 0
$0
$0
$0 2031
$134 172 1
$23,079
$13,432
$18,219 2032
$134 172 0
$0
$0
$0 2033
$134 172 0
$0
$0
$0 2034
$134 172 0
$0
$0
$0 2035
$134 172 0
$0
$0
$0
Regulatory Analysis Page A-31 2036
$134 172 0
$0
$0
$0 20
$461,580
$346,380
$406,788 Issue 80:
Category 1 Operations-Accidents Involving Releases of Hazardous Chemicals Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 103 8
$110,565
$90,254
$101,182 2027
$134 103 2
$27,641
$21,087
$24,559 2028
$134 103 8
$110,565
$78,831
$95,374 2029
$134 103 1
$13,821
$9,209
$11,575 2030
$134 103 0
$0
$0
$0 2031
$134 103 1
$13,821
$8,044
$10,910 2032
$134 103 0
$0
$0
$0 2033
$134 103 0
$0
$0
$0 2034
$134 103 0
$0
$0
$0 2035
$134 103 0
$0
$0
$0 2036
$134 103 0
$0
$0
$0 20
$276,412
$207,425
$243,600 Issue 81:
Category 1 Operations-Severe Accident Mitigation Design Alternatives Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 69 8
$74,068
$60,461
$67,782 2027
$134 69 2
$18,517
$14,126
$16,452 2028
$134 69 8
$74,068
$52,809
$63,891 2029
$134 69 1
$9,258
$6,169
$7,754 2030
$134 69 0
$0
$0
$0 2031
$134 69 1
$9,258
$5,388
$7,309 2032
$134 69 0
$0
$0
$0 2033
$134 69 0
$0
$0
$0 2034
$134 69 0
$0
$0
$0 2035
$134 69 0
$0
$0
$0 2036
$134 69 0
$0
$0
$0 20
$185,169
$138,955
$163,188
Regulatory Analysis Page A-32 Issue 82:
Category 1 Operations-Acts of Terrorism Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 69 8
$74,068
$60,461
$67,782 2027
$134 69 2
$18,517
$14,126
$16,452 2028
$134 69 8
$74,068
$52,809
$63,891 2029
$134 69 1
$9,258
$6,169
$7,754 2030
$134 69 0
$0
$0
$0 2031
$134 69 1
$9,258
$5,388
$7,309 2032
$134 69 0
$0
$0
$0 2033
$134 69 0
$0
$0
$0 2034
$134 69 0
$0
$0
$0 2035
$134 69 0
$0
$0
$0 2036
$134 69 0
$0
$0
$0 20
$185,169
$138,955
$163,188 Issue 83:
Category 1 Construction-Community Services and Infrastructure Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 74 8
$79,435
$64,842
$72,694 2027
$134 74 2
$19,859
$15,150
$17,644 2028
$134 74 8
$79,435
$56,636
$68,521 2029
$134 74 1
$9,929
$6,616
$8,316 2030
$134 74 0
$0
$0
$0 2031
$134 74 1
$9,929
$5,779
$7,838 2032
$134 74 0
$0
$0
$0 2033
$134 74 0
$0
$0
$0 2034
$134 74 0
$0
$0
$0 2035
$134 74 0
$0
$0
$0 2036
$134 74 0
$0
$0
$0 20
$198,587
$149,024
$175,013 Issue 84:
Category 1 Construction-Transportation Systems and Traffic Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present 3% NPV
Regulatory Analysis Page A-33 Value (NPV) 2026
$134 147 8
$157,796
$128,809
$144,406 2027
$134 147 2
$39,449
$30,095
$35,050 2028
$134 147 8
$157,796
$112,506
$136,116 2029
$134 147 1
$19,725
$13,143
$16,519 2030
$134 147 0
$0
$0
$0 2031
$134 147 1
$19,725
$11,480
$15,571 2032
$134 147 0
$0
$0
$0 2033
$134 147 0
$0
$0
$0 2034
$134 147 0
$0
$0
$0 2035
$134 147 0
$0
$0
$0 2036
$134 147 0
$0
$0
$0 20
$394,490
$296,034
$347,662 Issue 85:
Category 1 Construction-Economic Impacts Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 74 8
$79,435
$64,842
$72,694 2027
$134 74 2
$19,859
$15,150
$17,644 2028
$134 74 8
$79,435
$56,636
$68,521 2029
$134 74 1
$9,929
$6,616
$8,316 2030
$134 74 0
$0
$0
$0 2031
$134 74 1
$9,929
$5,779
$7,838 2032
$134 74 0
$0
$0
$0 2033
$134 74 0
$0
$0
$0 2034
$134 74 0
$0
$0
$0 2035
$134 74 0
$0
$0
$0 2036
$134 74 0
$0
$0
$0 20
$198,587
$149,024
$175,013 Issue 86:
Category 1 ConstructionTax Revenue Impacts Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 42 8
$45,085
$36,802
$41,259 2027
$134 42 2
$11,271
$8,599
$10,014 2028
$134 42 8
$45,085
$32,145
$38,890 2029
$134 42 1
$5,636
$3,755
$4,720 2030
$134 42 0
$0
$0
$0
Regulatory Analysis Page A-34 2031
$134 42 1
$5,636
$3,280
$4,449 2032
$134 42 0
$0
$0
$0 2033
$134 42 0
$0
$0
$0 2034
$134 42 0
$0
$0
$0 2035
$134 42 0
$0
$0
$0 2036
$134 42 0
$0
$0
$0 20
$112,712
$84,581
$99,332 Issue 87:
Category 1 OperationsCommunity Services and Infrastructure Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 50 8
$53,672
$43,812
$49,118 2027
$134 50 2
$13,418
$10,237
$11,922 2028
$134 50 8
$53,672
$38,267
$46,298 2029
$134 50 1
$6,709
$4,471
$5,619 2030
$134 50 0
$0
$0
$0 2031
$134 50 1
$6,709
$3,905
$5,296 2032
$134 50 0
$0
$0
$0 2033
$134 50 0
$0
$0
$0 2034
$134 50 0
$0
$0
$0 2035
$134 50 0
$0
$0
$0 2036
$134 50 0
$0
$0
$0 20
$134,180
$100,692
$118,252 Issue 88:
Category 1 OperationsTransportation Systems and Traffic Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 25 8
$26,836
$21,906
$24,559 2027
$134 25 2
$6,709
$5,118
$5,961 2028
$134 25 8
$26,836
$19,134
$23,149 2029
$134 25 1
$3,355
$2,235
$2,809 2030
$134 25 0
$0
$0
$0 2031
$134 25 1
$3,355
$1,952
$2,648 2032
$134 25 0
$0
$0
$0 2033
$134 25 0
$0
$0
$0 2034
$134 25 0
$0
$0
$0 2035
$134 25 0
$0
$0
$0 2036
$134 25 0
$0
$0
$0 20
$67,090
$50,346
$59,126
Regulatory Analysis Page A-35 Issue 89:
Category 1 OperationsEconomic Impacts Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 50 8
$53,672
$43,812
$49,118 2027
$134 50 2
$13,418
$10,237
$11,922 2028
$134 50 8
$53,672
$38,267
$46,298 2029
$134 50 1
$6,709
$4,471
$5,619 2030
$134 50 0
$0
$0
$0 2031
$134 50 1
$6,709
$3,905
$5,296 2032
$134 50 0
$0
$0
$0 2033
$134 50 0
$0
$0
$0 2034
$134 50 0
$0
$0
$0 2035
$134 50 0
$0
$0
$0 2036
$134 50 0
$0
$0
$0 20
$134,180
$100,692
$118,252 Issue 90:
Category 1 OperationsTax Revenue Impacts Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 98 8
$105,197
$85,872
$96,271 2027
$134 98 2
$26,299
$20,064
$23,367 2028
$134 98 8
$105,197
$75,004
$90,744 2029
$134 98 1
$13,150
$8,762
$11,013 2030
$134 98 0
$0
$0
$0 2031
$134 98 1
$13,150
$7,653
$10,380 2032
$134 98 0
$0
$0
$0 2033
$134 98 0
$0
$0
$0 2034
$134 98 0
$0
$0
$0 2035
$134 98 0
$0
$0
$0 2036
$134 98 0
$0
$0
$0 20
$262,994
$197,356
$231,774 Issue 91:
Category 1 OperationsUranium Recovery Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present 3% NPV
Regulatory Analysis Page A-36 Value (NPV) 2026
$134 39 8
$41,864
$34,174
$38,312 2027
$134 39 2
$10,466
$7,985
$9,299 2028
$134 39 8
$41,864
$29,849
$36,112 2029
$134 39 1
$5,233
$3,487
$4,383 2030
$134 39 0
$0
$0
$0 2031
$134 39 1
$5,233
$3,046
$4,131 2032
$134 39 0
$0
$0
$0 2033
$134 39 0
$0
$0
$0 2034
$134 39 0
$0
$0
$0 2035
$134 39 0
$0
$0
$0 2036
$134 39 0
$0
$0
$0 20
$104,661
$78,540
$92,237 Issue 92:
Category 1 OperationsUranium Conversion Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 39 8
$41,864
$34,174
$38,312 2027
$134 39 2
$10,466
$7,985
$9,299 2028
$134 39 8
$41,864
$29,849
$36,112 2029
$134 39 1
$5,233
$3,487
$4,383 2030
$134 39 0
$0
$0
$0 2031
$134 39 1
$5,233
$3,046
$4,131 2032
$134 39 0
$0
$0
$0 2033
$134 39 0
$0
$0
$0 2034
$134 39 0
$0
$0
$0 2035
$134 39 0
$0
$0
$0 2036
$134 39 0
$0
$0
$0 20
$104,661
$78,540
$92,237 Issue 93:
Category 1 Operations-Enrichment Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 39 8
$41,864
$34,174
$38,312 2027
$134 39 2
$10,466
$7,985
$9,299 2028
$134 39 8
$41,864
$29,849
$36,112 2029
$134 39 1
$5,233
$3,487
$4,383 2030
$134 39 0
$0
$0
$0
Regulatory Analysis Page A-37 2031
$134 39 1
$5,233
$3,046
$4,131 2032
$134 39 0
$0
$0
$0 2033
$134 39 0
$0
$0
$0 2034
$134 39 0
$0
$0
$0 2035
$134 39 0
$0
$0
$0 2036
$134 39 0
$0
$0
$0 20
$104,661
$78,540
$92,237 Issue 94:
Category 1 OperationsFuel Fabrication Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 39 8
$41,864
$34,174
$38,312 2027
$134 39 2
$10,466
$7,985
$9,299 2028
$134 39 8
$41,864
$29,849
$36,112 2029
$134 39 1
$5,233
$3,487
$4,383 2030
$134 39 0
$0
$0
$0 2031
$134 39 1
$5,233
$3,046
$4,131 2032
$134 39 0
$0
$0
$0 2033
$134 39 0
$0
$0
$0 2034
$134 39 0
$0
$0
$0 2035
$134 39 0
$0
$0
$0 2036
$134 39 0
$0
$0
$0 20
$104,661
$78,540
$92,237 Issue 95:
Category 1 Operations-Reprocessing Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 39 8
$41,864
$34,174
$38,312 2027
$134 39 2
$10,466
$7,985
$9,299 2028
$134 39 8
$41,864
$29,849
$36,112 2029
$134 39 1
$5,233
$3,487
$4,383 2030
$134 39 0
$0
$0
$0 2031
$134 39 1
$5,233
$3,046
$4,131 2032
$134 39 0
$0
$0
$0 2033
$134 39 0
$0
$0
$0 2034
$134 39 0
$0
$0
$0 2035
$134 39 0
$0
$0
$0 2036
$134 39 0
$0
$0
$0 20
$104,661
$78,540
$92,237
Regulatory Analysis Page A-38 Issue 96:
Category 1 OperationsStorage and Disposal of Radiological Wastes Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 39 8
$41,864
$34,174
$38,312 2027
$134 39 2
$10,466
$7,985
$9,299 2028
$134 39 8
$41,864
$29,849
$36,112 2029
$134 39 1
$5,233
$3,487
$4,383 2030
$134 39 0
$0
$0
$0 2031
$134 39 1
$5,233
$3,046
$4,131 2032
$134 39 0
$0
$0
$0 2033
$134 39 0
$0
$0
$0 2034
$134 39 0
$0
$0
$0 2035
$134 39 0
$0
$0
$0 2036
$134 39 0
$0
$0
$0 20
$104,661
$78,540
$92,237 Issue 97:
Category 1 OperationsTransportation of Unirradiated Fuel Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 78 8
$83,729
$68,347
$76,623 2027
$134 78 2
$20,932
$15,969
$18,598 2028
$134 78 8
$83,729
$59,697
$72,225 2029
$134 78 1
$10,466
$6,974
$8,765 2030
$134 78 0
$0
$0
$0 2031
$134 78 1
$10,466
$6,091
$8,262 2032
$134 78 0
$0
$0
$0 2033
$134 78 0
$0
$0
$0 2034
$134 78 0
$0
$0
$0 2035
$134 78 0
$0
$0
$0 2036
$134 78 0
$0
$0
$0 20
$209,321
$157,079
$184,474 Issue 98:
Category 1 OperationsTransportation of Radioactive Waste Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present 3% NPV
Regulatory Analysis Page A-39 Value (NPV) 2026
$134 78 8
$83,729
$68,347
$76,623 2027
$134 78 2
$20,932
$15,969
$18,598 2028
$134 78 8
$83,729
$59,697
$72,225 2029
$134 78 1
$10,466
$6,974
$8,765 2030
$134 78 0
$0
$0
$0 2031
$134 78 1
$10,466
$6,091
$8,262 2032
$134 78 0
$0
$0
$0 2033
$134 78 0
$0
$0
$0 2034
$134 78 0
$0
$0
$0 2035
$134 78 0
$0
$0
$0 2036
$134 78 0
$0
$0
$0 20
$209,321
$157,079
$184,474 Issue 99:
Category 1 OperationsTransportation of Irradiated Fuel Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 155 8
$166,384
$135,819
$152,265 2027
$134 155 2
$41,596
$31,733
$36,957 2028
$134 155 8
$166,384
$118,629
$143,524 2029
$134 155 1
$20,798
$13,859
$17,418 2030
$134 155 0
$0
$0
$0 2031
$134 155 1
$20,798
$12,105
$16,418 2032
$134 155 0
$0
$0
$0 2033
$134 155 0
$0
$0
$0 2034
$134 155 0
$0
$0
$0 2035
$134 155 0
$0
$0
$0 2036
$134 155 0
$0
$0
$0 20
$415,959
$312,144
$366,582 Issue 100:
Decommissioning Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV)7%
Net Present Value (NPV) 3% NPV 2026
$134 81 8
$86,949
$70,976
$79,571 2027
$134 81 2
$21,737
$16,583
$19,313 2028
$134 81 8
$86,949
$61,993
$75,003 2029
$134 81 1
$10,869
$7,242
$9,102 2030
$134 81 0
$0
$0
$0
Regulatory Analysis Page A-40 2031
$134 81 1
$10,869
$6,326
$8,580 2032
$134 81 0
$0
$0
$0 2033
$134 81 0
$0
$0
$0 2034
$134 81 0
$0
$0
$0 2035
$134 81 0
$0
$0
$0 2036
$134 81 0
$0
$0
$0 20
$217,372
$163,121
$191,569 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 (2026-2036) industry is assumed to submit 20 new nuclear reactor applications, during that same period NRC would be assumed to complete 20 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 $152/hour and the NRC contractor labor rate of $225/hour, since every new nuclear reactor application review involves the collective effort of NRC staff and NRC contractor staff. This weighed average equates to $195/hour.
Hours per application: For each Category 1 issue, the NRC estimated the hours saved by utilizing the generic impact analysis findings in the NR 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.
Applications per year: As discussed above and in Section 3.3.4, this represents the NRCs assumed number of new nuclear reactor 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.2 Summary of Proposed Rule Savings Benefits to the NRC by Category 1 Issue (2021 Constant Dollars)
Issue 1:
Category 1 ConstructionOnsite Land Use Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 82 0
$0
$0
$0 2027
$195 82 8
$127,920
$97,590
$113,655 2028
$195 82 2
$31,980
$22,801
$27,586 2029
$195 82 8
$127,920
$85,238
$107,131 2030
$195 82 1
$15,990
$9,958
$13,001 2031
$195 82 0
$0
$0
$0
Regulatory Analysis Page A-41 2032
$195 82 1
$15,990
$8,698
$12,255 2033
$195 82 0
$0
$0
$0 2034
$195 82 0
$0
$0
$0 2035
$195 82 0
$0
$0
$0 2036
$195 82 0
$0
$0
$0 20
$319,800
$224,285
$273,629 Issue 2:
Category 1 ConstructionOffsite Land Use Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 135 0
$0
$0
$0 2027
$195 135 8
$210,600
$160,666
$187,115 2028
$195 135 2
$52,650
$37,539
$45,416 2029
$195 135 8
$210,600
$140,332
$176,374 2030
$195 135 1
$26,325
$16,394
$21,405 2031
$195 135 0
$0
$0
$0 2032
$195 135 1
$26,325
$14,319
$20,176 2033
$195 135 0
$0
$0
$0 2034
$195 135 0
$0
$0
$0 2035
$195 135 0
$0
$0
$0 2036
$195 135 0
$0
$0
$0 20
$526,500
$369,249
$450,486 Issue 3:
Category 1 ConstructionImpacts on Prime and Unique Farmland Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 23 0
$0
$0
$0 2027
$195 23 8
$35,880
$27,373
$31,879 2028
$195 23 2
$8,970
$6,395
$7,738 2029
$195 23 8
$35,880
$23,908
$30,049 2030
$195 23 1
$4,485
$2,793
$3,647 2031
$195 23 0
$0
$0
$0 2032
$195 23 1
$4,485
$2,440
$3,437 2033
$195 23 0
$0
$0
$0 2034
$195 23 0
$0
$0
$0 2035
$195 23 0
$0
$0
$0 2036
$195 23 0
$0
$0
$0 20
$89,700
$62,909
$76,750 Issue 4:
Category 1 ConstructionCoastal Zone and Compliance with The Coastal Zone Management Act Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 9
0
$0
$0
$0 2027
$195 9
8
$14,040
$10,711
$12,474 2028
$195 9
2
$3,510
$2,503
$3,028 2029
$195 9
8
$14,040
$9,355
$11,758
Regulatory Analysis Page A-42 2030
$195 9
1
$1,755
$1,093
$1,427 2031
$195 9
0
$0
$0
$0 2032
$195 9
1
$1,755
$955
$1,345 2033
$195 9
0
$0
$0
$0 2034
$195 9
0
$0
$0
$0 2035
$195 9
0
$0
$0
$0 2036
$195 9
0
$0
$0
$0 20
$35,100
$24,617
$30,032 Issue 5:
Category 1 OperationsOnsite Land Use Year Labor Rate Hours per Application NRC Reviews per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 24 0
$0
$0
$0 2027
$195 24 8
$37,440
$28,563
$33,265 2028
$195 24 2
$9,360
$6,674
$8,074 2029
$195 24 8
$37,440
$24,948
$31,355 2030
$195 24 1
$4,680
$2,914
$3,805 2031
$195 24 0
$0
$0
$0 2032
$195 24 1
$4,680
$2,546
$3,587 2033
$195 24 0
$0
$0
$0 2034
$195 24 0
$0
$0
$0 2035
$195 24 0
$0
$0
$0 2036
$195 24 0
$0
$0
$0 20
$93,600
$65,644
$80,086 Issue 6:
Category 1 Operations Offsite Land Use Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 28 0
$0
$0
$0 2027
$195 28 8
$43,680
$33,323
$38,809 2028
$195 28 2
$10,920
$7,786
$9,420 2029
$195 28 8
$43,680
$29,106
$36,581 2030
$195 28 1
$5,460
$3,400
$4,439 2031
$195 28 0
$0
$0
$0 2032
$195 28 1
$5,460
$2,970
$4,185 2033
$195 28 0
$0
$0
$0 2034
$195 28 0
$0
$0
$0 2035
$195 28 0
$0
$0
$0 2036
$195 28 0
$0
$0
$0 20
$109,200
$76,585
$93,434 Issue 7:
Category 1 ConstructionVisual Impacts in Site and Vicinity Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 27 0
$0
$0
$0 2027
$195 27 8
$42,120
$32,133
$37,423 2028
$195 27 2
$10,530
$7,508
$9,083
Regulatory Analysis Page A-43 2029
$195 27 8
$42,120
$28,066
$35,275 2030
$195 27 1
$5,265
$3,279
$4,281 2031
$195 27 0
$0
$0
$0 2032
$195 27 1
$5,265
$2,864
$4,035 2033
$195 27 0
$0
$0
$0 2034
$195 27 0
$0
$0
$0 2035
$195 27 0
$0
$0
$0 2036
$195 27 0
$0
$0
$0 20
$105,300
$73,850
$90,097 Issue 8:
Category 1 ConstructionVisual Impacts from Transmission Lines Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 9
0
$0
$0
$0 2027
$195 9
8
$14,040
$10,711
$12,474 2028
$195 9
2
$3,510
$2,503
$3,028 2029
$195 9
8
$14,040
$9,355
$11,758 2030
$195 9
1
$1,755
$1,093
$1,427 2031
$195 9
0
$0
$0
$0 2032
$195 9
1
$1,755
$955
$1,345 2033
$195 9
0
$0
$0
$0 2034
$195 9
0
$0
$0
$0 2035
$195 9
0
$0
$0
$0 2036
$195 9
0
$0
$0
$0 20
$35,100
$24,617
$30,032 Issue 9:
Category 1 OperationsVisual Impacts During Operations Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 20 0
$0
$0
$0 2027
$195 20 8
$31,200
$23,802
$27,721 2028
$195 20 2
$7,800
$5,561
$6,728 2029
$195 20 8
$31,200
$20,790
$26,130 2030
$195 20 1
$3,900
$2,429
$3,171 2031
$195 20 0
$0
$0
$0 2032
$195 20 1
$3,900
$2,121
$2,989 2033
$195 20 0
$0
$0
$0 2034
$195 20 0
$0
$0
$0 2035
$195 20 0
$0
$0
$0 2036
$195 20 0
$0
$0
$0 20
$78,000
$54,704
$66,739
Regulatory Analysis Page A-44 Issue 10:
Category 1 ConstructionEmissions of Criteria Pollutants and Dust During Construction Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 154 0
$0
$0
$0 2027
$195 154 8
$240,240
$183,278
$213,450 2028
$195 154 2
$60,060
$42,822
$51,808 2029
$195 154 8
$240,240
$160,082
$201,197 2030
$195 154 1
$30,030
$18,701
$24,417 2031
$195 154 0
$0
$0
$0 2032
$195 154 1
$30,030
$16,334
$23,015 2033
$195 154 0
$0
$0
$0 2034
$195 154 0
$0
$0
$0 2035
$195 154 0
$0
$0
$0 2036
$195 154 0
$0
$0
$0 20
$600,600
$421,217
$513,888 Issue 11:
Category 1 ConstructionGreenhouse Gas Emissions During Construction Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 134 0
$0
$0
$0 2027
$195 134 8
$209,040
$159,476
$185,729 2028
$195 134 2
$52,260
$37,261
$45,080 2029
$195 134 8
$209,040
$139,292
$175,068 2030
$195 134 1
$26,130
$16,272
$21,246 2031
$195 134 0
$0
$0
$0 2032
$195 134 1
$26,130
$14,213
$20,026 2033
$195 134 0
$0
$0
$0 2034
$195 134 0
$0
$0
$0 2035
$195 134 0
$0
$0
$0 2036
$195 134 0
$0
$0
$0 20
$522,600
$366,514
$447,150 Issue 12:
Category 1 OperationsEmissions of Criteria and Hazardous Air Pollutants During Operation Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 163 0
$0
$0
$0 2027
$195 163 8
$254,280
$193,989
$225,924 2028
$195 163 2
$63,570
$45,325
$54,836 2029
$195 163 8
$254,280
$169,438
$212,955 2030
$195 163 1
$31,785
$19,794
$25,844 2031
$195 163 0
$0
$0
$0 2032
$195 163 1
$31,785
$17,289
$24,361 2033
$195 163 0
$0
$0
$0 2034
$195 163 0
$0
$0
$0
Regulatory Analysis Page A-45 2035
$195 163 0
$0
$0
$0 2036
$195 163 0
$0
$0
$0 20
$635,700
$445,834
$543,921 Issue 13:
Category 1 OperationsGreenhouse Gas Emissions During Operation Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 88 0
$0
$0
$0 2027
$195 88 8
$137,280
$104,730
$121,972 2028
$195 88 2
$34,320
$24,470
$29,605 2029
$195 88 8
$137,280
$91,475
$114,970 2030
$195 88 1
$17,160
$10,686
$13,953 2031
$195 88 0
$0
$0
$0 2032
$195 88 1
$17,160
$9,334
$13,152 2033
$195 88 0
$0
$0
$0 2034
$195 88 0
$0
$0
$0 2035
$195 88 0
$0
$0
$0 2036
$195 88 0
$0
$0
$0 20
$343,200
$240,696
$293,650 Issue 14:
Category 1 OperationsCooling System Emissions Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 18 0
$0
$0
$0 2027
$195 18 8
$28,080
$21,422
$24,949 2028
$195 18 2
$7,020
$5,005
$6,056 2029
$195 18 8
$28,080
$18,711
$23,517 2030
$195 18 1
$3,510
$2,186
$2,854 2031
$195 18 0
$0
$0
$0 2032
$195 18 1
$3,510
$1,909
$2,690 2033
$195 18 0
$0
$0
$0 2034
$195 18 0
$0
$0
$0 2035
$195 18 0
$0
$0
$0 2036
$195 18 0
$0
$0
$0 20
$70,200
$49,233
$60,065 Issue 15:
Category 1 OperationsEmissions of Ozone and Nitrogen Oxides During Transmission Line Operation Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV Net Present Value (NPV) 3% NPV 2026
$195 15 0
$0
$0
$0 2027
$195 15 8
$23,400
$17,852
$20,791 2028
$195 15 2
$5,850
$4,171
$5,046 2029
$195 15 8
$23,400
$15,592
$19,597 2030
$195 15 1
$2,925
$1,822
$2,378 2031
$195 15 0
$0
$0
$0 2032
$195 15 1
$2,925
$1,591
$2,242
Regulatory Analysis Page A-46 2033
$195 15 0
$0
$0
$0 2034
$195 15 0
$0
$0
$0 2035
$195 15 0
$0
$0
$0 2036
$195 15 0
$0
$0
$0 20
$58,500
$41,028
$50,054 Issue 16:
Category 1 ConstructionSurface Water Use Conflicts During Construction Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 60 0
$0
$0
$0 2027
$195 60 8
$93,600
$71,407
$83,162 2028
$195 60 2
$23,400
$16,684
$20,185 2029
$195 60 8
$93,600
$62,370
$78,389 2030
$195 60 1
$11,700
$7,286
$9,513 2031
$195 60 0
$0
$0
$0 2032
$195 60 1
$11,700
$6,364
$8,967 2033
$195 60 0
$0
$0
$0 2034
$195 60 0
$0
$0
$0 2035
$195 60 0
$0
$0
$0 2036
$195 60 0
$0
$0
$0 20
$234,000
$164,111
$200,216 Issue 17:
Category 1 ConstructionGroundwater Use Conflicts Due to Excavation Dewatering Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 123 0
$0
$0
$0 2027
$195 123 8
$191,880
$146,384
$170,483 2028
$195 123 2
$47,970
$34,202
$41,379 2029
$195 123 8
$191,880
$127,858
$160,696 2030
$195 123 1
$23,985
$14,937
$19,502 2031
$195 123 0
$0
$0
$0 2032
$195 123 1
$23,985
$13,046
$18,383 2033
$195 123 0
$0
$0
$0 2034
$195 123 0
$0
$0
$0 2035
$195 123 0
$0
$0
$0 2036
$195 123 0
$0
$0
$0 20
$479,700
$336,427
$410,443 Issue 18:
Category 1 ConstructionGroundwater Use Conflicts Due to Construction-Related Groundwater Withdrawals Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 115 0
$0
$0
$0 2027
$195 115 8
$179,400
$136,863
$159,395 2028
$195 115 2
$44,850
$31,977
$38,688 2029
$195 115 8
$179,400
$119,542
$150,245
Regulatory Analysis Page A-47 2030
$195 115 1
$22,425
$13,965
$18,234 2031
$195 115 0
$0
$0
$0 2032
$195 115 1
$22,425
$12,198
$17,187 2033
$195 115 0
$0
$0
$0 2034
$195 115 0
$0
$0
$0 2035
$195 115 0
$0
$0
$0 2036
$195 115 0
$0
$0
$0 20
$448,500
$314,546
$383,748 Issue 19:
Category 1 ConstructionWater Quality Degradation Due to Construction-Related Discharges Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 62 0
$0
$0
$0 2027
$195 62 8
$96,720
$73,787
$85,934 2028
$195 62 2
$24,180
$17,240
$20,858 2029
$195 62 8
$96,720
$64,449
$81,001 2030
$195 62 1
$12,090
$7,529
$9,830 2031
$195 62 0
$0
$0
$0 2032
$195 62 1
$12,090
$6,576
$9,266 2033
$195 62 0
$0
$0
$0 2034
$195 62 0
$0
$0
$0 2035
$195 62 0
$0
$0
$0 2036
$195 62 0
$0
$0
$0 20
$241,800
$169,581
$206,890 Issue 20:
Category 1 ConstructionWater Quality Degradation Due to Inadvertent Spills During Construction Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 24 0
$0
$0
$0 2027
$195 24 8
$37,440
$28,563
$33,265 2028
$195 24 2
$9,360
$6,674
$8,074 2029
$195 24 8
$37,440
$24,948
$31,355 2030
$195 24 1
$4,680
$2,914
$3,805 2031
$195 24 0
$0
$0
$0 2032
$195 24 1
$4,680
$2,546
$3,587 2033
$195 24 0
$0
$0
$0 2034
$195 24 0
$0
$0
$0 2035
$195 24 0
$0
$0
$0 2036
$195 24 0
$0
$0
$0 20
$93,600
$65,644
$80,086 Issue 21:
Category 1 ConstructionWater Quality Degradation Due to Groundwater Withdrawal Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV
Regulatory Analysis Page A-48 2026
$195 73 0
$0
$0
$0 2027
$195 73 8
$113,880
$86,879
$101,181 2028
$195 73 2
$28,470
$20,299
$24,558 2029
$195 73 8
$113,880
$75,883
$95,373 2030
$195 73 1
$14,235
$8,865
$11,574 2031
$195 73 0
$0
$0
$0 2032
$195 73 1
$14,235
$7,743
$10,910 2033
$195 73 0
$0
$0
$0 2034
$195 73 0
$0
$0
$0 2035
$195 73 0
$0
$0
$0 2036
$195 73 0
$0
$0
$0 20
$284,700
$199,668
$243,596 Issue 22:
Category 1 ConstructionWater Quality Degradation Due to Offshore or In-Water Construction Activities Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 56 0
$0
$0
$0 2027
$195 56 8
$87,360
$66,647
$77,618 2028
$195 56 2
$21,840
$15,572
$18,839 2029
$195 56 8
$87,360
$58,212
$73,163 2030
$195 56 1
$10,920
$6,800
$8,879 2031
$195 56 0
$0
$0
$0 2032
$195 56 1
$10,920
$5,940
$8,369 2033
$195 56 0
$0
$0
$0 2034
$195 56 0
$0
$0
$0 2035
$195 56 0
$0
$0
$0 2036
$195 56 0
$0
$0
$0 20
$218,400
$153,170
$186,868 Issue 23:
Category 1 ConstructionWater Use Conflict Due to Plant Municipal Water Demand Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 49 0
$0
$0
$0 2027
$195 49 8
$76,440
$58,316
$67,916 2028
$195 49 2
$19,110
$13,625
$16,484 2029
$195 49 8
$76,440
$50,935
$64,017 2030
$195 49 1
$9,555
$5,950
$7,769 2031
$195 49 0
$0
$0
$0 2032
$195 49 1
$9,555
$5,197
$7,323 2033
$195 49 0
$0
$0
$0 2034
$195 49 0
$0
$0
$0 2035
$195 49 0
$0
$0
$0 2036
$195 49 0
$0
$0
$0 20
$191,100
$134,024
$163,510
Regulatory Analysis Page A-49 Issue 24:
Category 1 ConstructionDegradation of Water Quality from Plant Effluent Discharges to Municipal Systems Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 97 0
$0
$0
$0 2027
$195 97 8
$151,320
$115,441
$134,446 2028
$195 97 2
$37,830
$26,972
$32,632 2029
$195 97 8
$151,320
$100,831
$126,728 2030
$195 97 1
$18,915
$11,779
$15,380 2031
$195 97 0
$0
$0
$0 2032
$195 97 1
$18,915
$10,289
$14,497 2033
$195 97 0
$0
$0
$0 2034
$195 97 0
$0
$0
$0 2035
$195 97 0
$0
$0
$0 2036
$195 97 0
$0
$0
$0 20
$378,300
$265,312
$323,683 Issue 25:
Category 1 OperationsSurface Water Use Conflicts During Operation Due to Water Withdrawal from Flowing Waterbodies Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 152 0
$0
$0
$0 2027
$195 152 8
$237,120
$180,898
$210,678 2028
$195 152 2
$59,280
$42,266
$51,135 2029
$195 152 8
$237,120
$158,003
$198,584 2030
$195 152 1
$29,640
$18,458
$24,100 2031
$195 152 0
$0
$0
$0 2032
$195 152 1
$29,640
$16,122
$22,717 2033
$195 152 0
$0
$0
$0 2034
$195 152 0
$0
$0
$0 2035
$195 152 0
$0
$0
$0 2036
$195 152 0
$0
$0
$0 20
$592,800
$415,747
$507,214 Issue 26:
Category 1 OperationsSurface Water Use Conflicts During Operation Due to Water Withdrawal from Non-Flowing Waterbodies Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 113 0
$0
$0
$0 2027
$195 113 8
$176,280
$134,483
$156,622 2028
$195 113 2
$44,070
$31,421
$38,015 2029
$195 113 8
$176,280
$117,463
$147,632 2030
$195 113 1
$22,035
$13,722
$17,916 2031
$195 113 0
$0
$0
$0 2032
$195 113 1
$22,035
$11,986
$16,888 2033
$195 113 0
$0
$0
$0 2034
$195 113 0
$0
$0
$0
Regulatory Analysis Page A-50 2035
$195 113 0
$0
$0
$0 2036
$195 113 0
$0
$0
$0 20
$440,700
$309,075
$377,074 Issue 27:
Category 1 OperationsGroundwater Use Conflicts Due to Building Foundation Dewatering Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 57 0
$0
$0
$0 2027
$195 57 8
$88,920
$67,837
$79,004 2028
$195 57 2
$22,230
$15,850
$19,176 2029
$195 57 8
$88,920
$59,251
$74,469 2030
$195 57 1
$11,115
$6,922
$9,038 2031
$195 57 0
$0
$0
$0 2032
$195 57 1
$11,115
$6,046
$8,519 2033
$195 57 0
$0
$0
$0 2034
$195 57 0
$0
$0
$0 2035
$195 57 0
$0
$0
$0 2036
$195 57 0
$0
$0
$0 20
$222,300
$155,905
$190,205 Issue 28:
Category 1 OperationsGroundwater Use Conflicts Due to Groundwater Withdrawals for Plant Uses Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 124 0
$0
$0
$0 2027
$195 124 8
$193,440
$147,574
$171,869 2028
$195 124 2
$48,360
$34,480
$41,716 2029
$195 124 8
$193,440
$128,897
$162,003 2030
$195 124 1
$24,180
$15,058
$19,661 2031
$195 124 0
$0
$0
$0 2032
$195 124 1
$24,180
$13,152
$18,532 2033
$195 124 0
$0
$0
$0 2034
$195 124 0
$0
$0
$0 2035
$195 124 0
$0
$0
$0 2036
$195 124 0
$0
$0
$0 20
$483,600
$339,162
$413,780 Issue 29:
Category 1 OperationsSurface Water Quality Degradation Due to Physical Effects from Operation of Intake and Discharge Structures Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 95 0
$0
$0
$0 2027
$195 95 8
$148,200
$113,061
$131,674 2028
$195 95 2
$37,050
$26,416
$31,960 2029
$195 95 8
$148,200
$98,752
$124,115 2030
$195 95 1
$18,525
$11,536
$15,063
Regulatory Analysis Page A-51 2031
$195 95 0
$0
$0
$0 2032
$195 95 1
$18,525
$10,076
$14,198 2033
$195 95 0
$0
$0
$0 2034
$195 95 0
$0
$0
$0 2035
$195 95 0
$0
$0
$0 2036
$195 95 0
$0
$0
$0 20
$370,500
$259,842
$317,009 Issue 30:
Category 1 OperationsSurface Water Quality Degradation Due to Changes in Salinity Gradients Resulting from Withdrawals Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 158 0
$0
$0
$0 2027
$195 158 8
$246,480
$188,038
$218,994 2028
$195 158 2
$61,620
$43,934
$53,154 2029
$195 158 8
$246,480
$164,240
$206,423 2030
$195 158 1
$30,810
$19,187
$25,051 2031
$195 158 0
$0
$0
$0 2032
$195 158 1
$30,810
$16,759
$23,613 2033
$195 158 0
$0
$0
$0 2034
$195 158 0
$0
$0
$0 2035
$195 158 0
$0
$0
$0 2036
$195 158 0
$0
$0
$0 20
$616,200
$432,158
$527,236 Issue 31:
Category 1 OperationsGroundwater Quality Degradation Due to Plant Discharges Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 97 0
$0
$0
$0 2027
$195 97 8
$151,320
$115,441
$134,446 2028
$195 97 2
$37,830
$26,972
$32,632 2029
$195 97 8
$151,320
$100,831
$126,728 2030
$195 97 1
$18,915
$11,779
$15,380 2031
$195 97 0
$0
$0
$0 2032
$195 97 1
$18,915
$10,289
$14,497 2033
$195 97 0
$0
$0
$0 2034
$195 97 0
$0
$0
$0 2035
$195 97 0
$0
$0
$0 2036
$195 97 0
$0
$0
$0 20
$378,300
$265,312
$323,683 Issue 32:
Category 1 OperationsWater Quality Degradation Due to Inadvertent Spills and Leaks During Operation Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 22 0
$0
$0
$0
Regulatory Analysis Page A-52 2027
$195 22 8
$34,320
$26,183
$30,493 2028
$195 22 2
$8,580
$6,117
$7,401 2029
$195 22 8
$34,320
$22,869
$28,742 2030
$195 22 1
$4,290
$2,672
$3,488 2031
$195 22 0
$0
$0
$0 2032
$195 22 1
$4,290
$2,333
$3,288 2033
$195 22 0
$0
$0
$0 2034
$195 22 0
$0
$0
$0 2035
$195 22 0
$0
$0
$0 2036
$195 22 0
$0
$0
$0 20
$85,800
$60,174
$73,413 Issue 33:
Category 1 OperationsWater Quality Degradation Due to Groundwater Withdrawals Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 116 0
$0
$0
$0 2027
$195 116 8
$180,960
$138,054
$160,781 2028
$195 116 2
$45,240
$32,255
$39,024 2029
$195 116 8
$180,960
$120,581
$151,551 2030
$195 116 1
$22,620
$14,087
$18,392 2031
$195 116 0
$0
$0
$0 2032
$195 116 1
$22,620
$12,304
$17,336 2033
$195 116 0
$0
$0
$0 2034
$195 116 0
$0
$0
$0 2035
$195 116 0
$0
$0
$0 2036
$195 116 0
$0
$0
$0 20
$452,400
$317,281
$387,085 Issue 34:
Category 1 OperationsWater Use Conflict from Plant Municipal Water Demand Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 26 0
$0
$0
$0 2027
$195 26 8
$40,560
$30,943
$36,037 2028
$195 26 2
$10,140
$7,230
$8,747 2029
$195 26 8
$40,560
$27,027
$33,968 2030
$195 26 1
$5,070
$3,157
$4,122 2031
$195 26 0
$0
$0
$0 2032
$195 26 1
$5,070
$2,758
$3,886 2033
$195 26 0
$0
$0
$0 2034
$195 26 0
$0
$0
$0 2035
$195 26 0
$0
$0
$0 2036
$195 26 0
$0
$0
$0 20
$101,400
$71,115
$86,760 Issue 35:
Category 1 OperationsDegradation of Water Quality from Plant Effluent Discharges to Municipal Systems
Regulatory Analysis Page A-53 Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 26 0
$0
$0
$0 2027
$195 26 8
$40,560
$30,943
$36,037 2028
$195 26 2
$10,140
$7,230
$8,747 2029
$195 26 8
$40,560
$27,027
$33,968 2030
$195 26 1
$5,070
$3,157
$4,122 2031
$195 26 0
$0
$0
$0 2032
$195 26 1
$5,070
$2,758
$3,886 2033
$195 26 0
$0
$0
$0 2034
$195 26 0
$0
$0
$0 2035
$195 26 0
$0
$0
$0 2036
$195 26 0
$0
$0
$0 20
$101,400
$71,115
$86,760 Issue 36:
Category 1 ConstructionPermanent and Temporary Loss, Conversion, Fragmentation, and Degradation of Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 133 0
$0
$0
$0 2027
$195 133 8
$207,480
$158,285
$184,343 2028
$195 133 2
$51,870
$36,983
$44,744 2029
$195 133 8
$207,480
$138,253
$173,761 2030
$195 133 1
$25,935
$16,151
$21,088 2031
$195 133 0
$0
$0
$0 2032
$195 133 1
$25,935
$14,107
$19,877 2033
$195 133 0
$0
$0
$0 2034
$195 133 0
$0
$0
$0 2035
$195 133 0
$0
$0
$0 2036
$195 133 0
$0
$0
$0 20
$518,700
$363,779
$443,813 Issue 37:
Category 1 ConstructionPermanent and Temporary Loss and Degradation of Wetlands Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 133 0
$0
$0
$0 2027
$195 133 8
$207,480
$158,285
$184,343 2028
$195 133 2
$51,870
$36,983
$44,744 2029
$195 133 8
$207,480
$138,253
$173,761 2030
$195 133 1
$25,935
$16,151
$21,088 2031
$195 133 0
$0
$0
$0 2032
$195 133 1
$25,935
$14,107
$19,877 2033
$195 133 0
$0
$0
$0 2034
$195 133 0
$0
$0
$0 2035
$195 133 0
$0
$0
$0 2036
$195 133 0
$0
$0
$0
Regulatory Analysis Page A-54 20
$518,700
$363,779
$443,813 Issue 38:
Category 1 ConstructionEffects of Building Noise on Wildlife Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 41 0
$0
$0
$0 2027
$195 41 8
$63,960
$48,795
$56,828 2028
$195 41 2
$15,990
$11,401
$13,793 2029
$195 41 8
$63,960
$42,619
$53,565 2030
$195 41 1
$7,995
$4,979
$6,501 2031
$195 41 0
$0
$0
$0 2032
$195 41 1
$7,995
$4,349
$6,128 2033
$195 41 0
$0
$0
$0 2034
$195 41 0
$0
$0
$0 2035
$195 41 0
$0
$0
$0 2036
$195 41 0
$0
$0
$0 20
$159,900
$112,142
$136,814 Issue 39:
Category 1 ConstructionEffects of Vehicular Collisions on Wildlife Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 36 0
$0
$0
$0 2027
$195 36 8
$56,160
$42,844
$49,897 2028
$195 36 2
$14,040
$10,010
$12,111 2029
$195 36 8
$56,160
$37,422
$47,033 2030
$195 36 1
$7,020
$4,372
$5,708 2031
$195 36 0
$0
$0
$0 2032
$195 36 1
$7,020
$3,818
$5,380 2033
$195 36 0
$0
$0
$0 2034
$195 36 0
$0
$0
$0 2035
$195 36 0
$0
$0
$0 2036
$195 36 0
$0
$0
$0 20
$140,400
$98,466
$120,130 Issue 40:
Category 1 ConstructionBird Collisions and Injury from Structures and Transmission Lines Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 40 0
$0
$0
$0 2027
$195 40 8
$62,400
$47,605
$55,442 2028
$195 40 2
$15,600
$11,123
$13,457 2029
$195 40 8
$62,400
$41,580
$52,259 2030
$195 40 1
$7,800
$4,857
$6,342 2031
$195 40 0
$0
$0
$0 2032
$195 40 1
$7,800
$4,243
$5,978 2033
$195 40 0
$0
$0
$0
Regulatory Analysis Page A-55 2034
$195 40 0
$0
$0
$0 2035
$195 40 0
$0
$0
$0 2036
$195 40 0
$0
$0
$0 20
$156,000
$109,407
$133,477 Issue 41:
Category 1 Construction - Important Species and HabitatsOther Important Species and Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 70 0
2027
$195 70 8
$109,200
$83,308
$97,023 2028
$195 70 2
$27,300
$19,465
$23,549 2029
$195 70 8
$109,200
$72,765
$91,453 2030
$195 70 1
$13,650
$8,501
$11,099 2031
$195 70 0
$0
$0
$0 2032
$195 70 1
$13,650
$7,425
$10,462 2033
$195 70 0
$0
$0
$0 2034
$195 70 0
$0
$0
$0 2035
$195 70 0
$0
$0
$0 2036
$195 70 0
$0
$0
$0 20
$273,000
$191,462
$233,586 Issue 42:
Category 1 OperationsPermanent and Temporary Loss or Disturbance of Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 13 0
2027
$195 13 8
$20,280
$15,472
$18,019 2028
$195 13 2
$5,070
$3,615
$4,373 2029
$195 13 8
$20,280
$13,513
$16,984 2030
$195 13 1
$2,535
$1,579
$2,061 2031
$195 13 0
$0
$0
$0 2032
$195 13 1
$2,535
$1,379
$1,943 2033
$195 13 0
$0
$0
$0 2034
$195 13 0
$0
$0
$0 2035
$195 13 0
$0
$0
$0 2036
$195 13 0
$0
$0
$0 20
$50,700
$35,557
$43,380 Issue 43:
Category 1 OperationsEffects of Operational Noise on Wildlife Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 8
0 2027
$195 8
8
$12,480
$9,521
$11,088 2028
$195 8
2
$3,120
$2,225
$2,691 2029
$195 8
8
$12,480
$8,316
$10,452 2030
$195 8
1
$1,560
$971
$1,268
Regulatory Analysis Page A-56 2031
$195 8
0
$0
$0
$0 2032
$195 8
1
$1,560
$849
$1,196 2033
$195 8
0
$0
$0
$0 2034
$195 8
0
$0
$0
$0 2035
$195 8
0
$0
$0
$0 2036
$195 8
0
$0
$0
$0 20
$31,200
$21,881
$26,695 Issue 44:
Category 1 OperationsEffects of Vehicular Collisions on Wildlife Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 7
0 2027
$195 7
8
$10,920
$8,331
$9,702 2028
$195 7
2
$2,730
$1,946
$2,355 2029
$195 7
8
$10,920
$7,276
$9,145 2030
$195 7
1
$1,365
$850
$1,110 2031
$195 7
0
$0
$0
$0 2032
$195 7
1
$1,365
$742
$1,046 2033
$195 7
0
$0
$0
$0 2034
$195 7
0
$0
$0
$0 2035
$195 7
0
$0
$0
$0 2036
$195 7
0
$0
$0
$0 20
$27,300
$19,146
$23,359 Issue 45:
Category 1 ConstructionExposure of Terrestrial Organisms to Radionuclides Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 28 0
2027
$195 28 8
$43,680
$33,323
$38,809 2028
$195 28 2
$10,920
$7,786
$9,420 2029
$195 28 8
$43,680
$29,106
$36,581 2030
$195 28 1
$5,460
$3,400
$4,439 2031
$195 28 0
$0
$0
$0 2032
$195 28 1
$5,460
$2,970
$4,185 2033
$195 28 0
$0
$0
$0 2034
$195 28 0
$0
$0
$0 2035
$195 28 0
$0
$0
$0 2036
$195 28 0
$0
$0
$0 20
$109,200
$76,585
$93,434 Issue 46:
Category 1 OperationsCooling Tower Operational Impacts on Vegetation Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 30 0
2027
$195 30 8
$46,800
$35,703
$41,581 2028
$195 30 2
$11,700
$8,342
$10,093
Regulatory Analysis Page A-57 2029
$195 30 8
$46,800
$31,185
$39,194 2030
$195 30 1
$5,850
$3,643
$4,757 2031
$195 30 0
$0
$0
$0 2032
$195 30 1
$5,850
$3,182
$4,484 2033
$195 30 0
$0
$0
$0 2034
$195 30 0
$0
$0
$0 2035
$195 30 0
$0
$0
$0 2036
$195 30 0
$0
$0
$0 20
$117,000
$82,055
$100,108 Issue 47:
Category 1 OperationsBird Collisions and Injury from Structures and Transmission Lines Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 13 0
2027
$195 13 8
$20,280
$15,472
$18,019 2028
$195 13 2
$5,070
$3,615
$4,373 2029
$195 13 8
$20,280
$13,513
$16,984 2030
$195 13 1
$2,535
$1,579
$2,061 2031
$195 13 0
$0
$0
$0 2032
$195 13 1
$2,535
$1,379
$1,943 2033
$195 13 0
$0
$0
$0 2034
$195 13 0
$0
$0
$0 2035
$195 13 0
$0
$0
$0 2036
$195 13 0
$0
$0
$0 20
$50,700
$35,557
$43,380 Issue 48:
Category 1 OperationsBird Electrocutions from Transmission Lines Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 13 0
2027
$195 13 8
$20,280
$15,472
$18,019 2028
$195 13 2
$5,070
$3,615
$4,373 2029
$195 13 8
$20,280
$13,513
$16,984 2030
$195 13 1
$2,535
$1,579
$2,061 2031
$195 13 0
$0
$0
$0 2032
$195 13 1
$2,535
$1,379
$1,943 2033
$195 13 0
$0
$0
$0 2034
$195 13 0
$0
$0
$0 2035
$195 13 0
$0
$0
$0 2036
$195 13 0
$0
$0
$0 20
$50,700
$35,557
$43,380 Issue 49:
Category 1 OperationsWater Use Conflicts with Terrestrial Resources Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 50 0
Regulatory Analysis Page A-58 2027
$195 50 8
$78,000
$59,506
$69,302 2028
$195 50 2
$19,500
$13,903
$16,821 2029
$195 50 8
$78,000
$51,975
$65,324 2030
$195 50 1
$9,750
$6,072
$7,928 2031
$195 50 0
$0
$0
$0 2032
$195 50 1
$9,750
$5,303
$7,473 2033
$195 50 0
$0
$0
$0 2034
$195 50 0
$0
$0
$0 2035
$195 50 0
$0
$0
$0 2036
$195 50 0
$0
$0
$0 20
$195,000
$136,759
$166,847 Issue 50:
Category 1 OperationsEffects of Transmission Line Right-of-Way Management on Terrestrial Resources Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 18 0
2027
$195 18 8
$28,080
$21,422
$24,949 2028
$195 18 2
$7,020
$5,005
$6,056 2029
$195 18 8
$28,080
$18,711
$23,517 2030
$195 18 1
$3,510
$2,186
$2,854 2031
$195 18 0
$0
$0
$0 2032
$195 18 1
$3,510
$1,909
$2,690 2033
$195 18 0
$0
$0
$0 2034
$195 18 0
$0
$0
$0 2035
$195 18 0
$0
$0
$0 2036
$195 18 0
$0
$0
$0 20
$70,200
$49,233
$60,065 Issue 51:
Category 1 OperationsEffects of Electromagnetic Fields on Flora and Fauna Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 5
0 2027
$195 5
8
$7,800
$5,951
$6,930 2028
$195 5
2
$1,950
$1,390
$1,682 2029
$195 5
8
$7,800
$5,197
$6,532 2030
$195 5
1
$975
$607
$793 2031
$195 5
0
$0
$0
$0 2032
$195 5
1
$975
$530
$747 2033
$195 5
0
$0
$0
$0 2034
$195 5
0
$0
$0
$0 2035
$195 5
0
$0
$0
$0 2036
$195 5
0
$0
$0
$0 20
$19,500
$13,676
$16,685
Regulatory Analysis Page A-59 Issue 52:
Category 1 OperationsImportant Species and HabitatsOther Important Species and Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 30 0
2027
$195 30 8
$46,800
$35,703
$41,581 2028
$195 30 2
$11,700
$8,342
$10,093 2029
$195 30 8
$46,800
$31,185
$39,194 2030
$195 30 1
$5,850
$3,643
$4,757 2031
$195 30 0
$0
$0
$0 2032
$195 30 1
$5,850
$3,182
$4,484 2033
$195 30 0
$0
$0
$0 2034
$195 30 0
$0
$0
$0 2035
$195 30 0
$0
$0
$0 2036
$195 30 0
$0
$0
$0 20
$117,000
$82,055
$100,108 Issue 53:
Category 1 ConstructionRunoff and Sedimentation from Construction Areas Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 124 0
2027
$195 124 8
$193,440
$147,574
$171,869 2028
$195 124 2
$48,360
$34,480
$41,716 2029
$195 124 8
$193,440
$128,897
$162,003 2030
$195 124 1
$24,180
$15,058
$19,661 2031
$195 124 0
$0
$0
$0 2032
$195 124 1
$24,180
$13,152
$18,532 2033
$195 124 0
$0
$0
$0 2034
$195 124 0
$0
$0
$0 2035
$195 124 0
$0
$0
$0 2036
$195 124 0
$0
$0
$0 20
$483,600
$339,162
$413,780 Issue 54:
Category 1 ConstructionDredging and Filling Aquatic Habitats to Build Intake and Discharge Structures Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 123 0
2027
$195 123 8
$191,880
$146,384
$170,483 2028
$195 123 2
$47,970
$34,202
$41,379 2029
$195 123 8
$191,880
$127,858
$160,696 2030
$195 123 1
$23,985
$14,937
$19,502 2031
$195 123 0
$0
$0
$0 2032
$195 123 1
$23,985
$13,046
$18,383 2033
$195 123 0
$0
$0
$0 2034
$195 123 0
$0
$0
$0 2035
$195 123 0
$0
$0
$0
Regulatory Analysis Page A-60 2036
$195 123 0
$0
$0
$0 20
$479,700
$336,427
$410,443 Issue 55:
Category 1 ConstructionBuilding Transmission Lines, Pipelines, and Access Roads Across Surface Waterbodies Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 105 0
2027
$195 105 8
$163,800
$124,962
$145,534 2028
$195 105 2
$40,950
$29,197
$35,324 2029
$195 105 8
$163,800
$109,147
$137,180 2030
$195 105 1
$20,475
$12,751
$16,648 2031
$195 105 0
$0
$0
$0 2032
$195 105 1
$20,475
$11,137
$15,692 2033
$195 105 0
$0
$0
$0 2034
$195 105 0
$0
$0
$0 2035
$195 105 0
$0
$0
$0 2036
$195 105 0
$0
$0
$0 20
$409,500
$287,194
$350,378 Issue 56:
Category 1 OperationsImportant Species and HabitatsOther Important Species and Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 172 0
2027
$195 172 8
$268,320
$204,700
$238,399 2028
$195 172 2
$67,080
$47,827
$57,864 2029
$195 172 8
$268,320
$178,793
$224,714 2030
$195 172 1
$33,540
$20,887
$27,271 2031
$195 172 0
$0
$0
$0 2032
$195 172 1
$33,540
$18,244
$25,706 2033
$195 172 0
$0
$0
$0 2034
$195 172 0
$0
$0
$0 2035
$195 172 0
$0
$0
$0 2036
$195 172 0
$0
$0
$0 20
$670,800
$470,451
$573,953 Issue 57:
Category 1 OperationsStormwater Runoff Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 28 0
2027
$195 28 8
$43,680
$33,323
$38,809 2028
$195 28 2
$10,920
$7,786
$9,420 2029
$195 28 8
$43,680
$29,106
$36,581 2030
$195 28 1
$5,460
$3,400
$4,439 2031
$195 28 0
$0
$0
$0 2032
$195 28 1
$5,460
$2,970
$4,185
Regulatory Analysis Page A-61 2033
$195 28 0
$0
$0
$0 2034
$195 28 0
$0
$0
$0 2035
$195 28 0
$0
$0
$0 2036
$195 28 0
$0
$0
$0 20
$109,200
$76,585
$93,434 Issue 58:
Category 1 OperationsExposure of Aquatic Organisms to Radionuclides Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 28 0
2027
$195 28 8
$43,680
$33,323
$38,809 2028
$195 28 2
$10,920
$7,786
$9,420 2029
$195 28 8
$43,680
$29,106
$36,581 2030
$195 28 1
$5,460
$3,400
$4,439 2031
$195 28 0
$0
$0
$0 2032
$195 28 1
$5,460
$2,970
$4,185 2033
$195 28 0
$0
$0
$0 2034
$195 28 0
$0
$0
$0 2035
$195 28 0
$0
$0
$0 2036
$195 28 0
$0
$0
$0 20
$109,200
$76,585
$93,434 Issue 59:
Category 1 OperationsEffects of Refurbishment on Aquatic Biota Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 28 0
2027
$195 28 8
$43,680
$33,323
$38,809 2028
$195 28 2
$10,920
$7,786
$9,420 2029
$195 28 8
$43,680
$29,106
$36,581 2030
$195 28 1
$5,460
$3,400
$4,439 2031
$195 28 0
$0
$0
$0 2032
$195 28 1
$5,460
$2,970
$4,185 2033
$195 28 0
$0
$0
$0 2034
$195 28 0
$0
$0
$0 2035
$195 28 0
$0
$0
$0 2036
$195 28 0
$0
$0
$0 20
$109,200
$76,585
$93,434 2026
$195 28 0
Issue 60:
Category 1 OperationsEffects of Maintenance Dredging on Aquatic Biota Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 72 0
$0
$0
$0 2027
$195 72 8
$112,320
$85,688
$99,795 2028
$195 72 2
$28,080
$20,021
$24,222 2029
$195 72 8
$112,320
$74,844
$94,066 2030
$195 72 1
$14,040
$8,743
$11,416
Regulatory Analysis Page A-62 2031
$195 72 0
$0
$0
$0 2032
$195 72 1
$14,040
$7,637
$10,760 2033
$195 72 0
$0
$0
$0 2034
$195 72 0
$0
$0
$0 2035
$195 72 0
$0
$0
$0 2036
$195 72 0
$0
$0
$0 20
$280,800
$196,933
$240,259 Issue 61:
Category 1 OperationsImpacts of Transmission Line ROW Management on Aquatic Resources Year Labor Rate Hours per Application Applications per Year Undiscounted 7% Net Present Value (NPV) 3% NPV 2026
$195 44 0
$0
$0
$0 2027
$195 44 8
$68,640
$52,365
$60,986 2028
$195 44 2
$17,160
$12,235
$14,802 2029
$195 44 8
$68,640
$45,738
$57,485 2030
$195 44 1
$8,580
$5,343
$6,976 2031
$195 44 0
$0
$0
$0 2032
$195 44 1
$8,580
$4,667
$6,576 2033
$195 44 0
$0
$0
$0 2034
$195 44 0
$0
$0
$0 2035
$195 44 0
$0
$0
$0 2036
$195 44 0
$0
$0
$0 20
$171,600
$120,348
$146,825 Issue 62:
Category 1 Operations - Impingement and Entrainment of Aquatic Organisms Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 115 0
$0
$0
$0 2027
$195 115 8
$179,400
$136,863
$159,395 2028
$195 115 2
$44,850
$31,977
$38,688 2029
$195 115 8
$179,400
$119,542
$150,245 2030
$195 115 1
$22,425
$13,965
$18,234 2031
$195 115 0
$0
$0
$0 2032
$195 115 1
$22,425
$12,198
$17,187 2033
$195 115 0
$0
$0
$0 2034
$195 115 0
$0
$0
$0 2035
$195 115 0
$0
$0
$0 2036
$195 115 0
$0
$0
$0 20
$448,500
$314,546
$383,748 Issue 63:
Category 1 Operations - Water Use Conflicts with Aquatic Resources Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 58 0
$0
$0
$0 2027
$195 58 8
$90,480
$69,027
$80,390 2028
$195 58 2
$22,620
$16,128
$19,512 2029
$195 58 8
$90,480
$60,291
$75,776 2030
$195 58 1
$11,310
$7,043
$9,196
Regulatory Analysis Page A-63 2031
$195 58 0
$0
$0
$0 2032
$195 58 1
$11,310
$6,152
$8,668 2033
$195 58 0
$0
$0
$0 2034
$195 58 0
$0
$0
$0 2035
$195 58 0
$0
$0
$0 2036
$195 58 0
$0
$0
$0 20
$226,200
$158,640
$193,542 Issue 64:
Category 1 Operations - Important Species and Habitats - Other Important Species and Habitats Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 142 0
$0
$0
$0 2027
$195 142 8
$221,520
$168,997
$196,818 2028
$195 142 2
$55,380
$39,485
$47,771 2029
$195 142 8
$221,520
$147,608
$185,520 2030
$195 142 1
$27,690
$17,244
$22,515 2031
$195 142 0
$0
$0
$0 2032
$195 142 1
$27,690
$15,062
$21,222 2033
$195 142 0
$0
$0
$0 2034
$195 142 0
$0
$0
$0 2035
$195 142 0
$0
$0
$0 2036
$195 142 0
$0
$0
$0 20
$553,800
$388,395
$473,845 Issue 65:
Category 1 Construction - Radiological Dose to Construction Workers Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 97 0
$0
$0
$0 2027
$195 97 8
$151,320
$115,441
$134,446 2028
$195 97 2
$37,830
$26,972
$32,632 2029
$195 97 8
$151,320
$100,831
$126,728 2030
$195 97 1
$18,915
$11,779
$15,380 2031
$195 97 0
$0
$0
$0 2032
$195 97 1
$18,915
$10,289
$14,497 2033
$195 97 0
$0
$0
$0 2034
$195 97 0
$0
$0
$0 2035
$195 97 0
$0
$0
$0 2036
$195 97 0
$0
$0
$0 20
$378,300
$265,312
$323,683 Issue 66:
Category 1 Operations - Occupational Doses to Workers Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 62 0
$0
$0
$0 2027
$195 62 8
$96,720
$73,787
$85,934 2028
$195 62 2
$24,180
$17,240
$20,858 2029
$195 62 8
$96,720
$64,449
$81,001 2030
$195 62 1
$12,090
$7,529
$9,830 2031
$195 62 0
$0
$0
$0 2032
$195 62 1
$12,090
$6,576
$9,266
Regulatory Analysis Page A-64 2033
$195 62 0
$0
$0
$0 2034
$195 62 0
$0
$0
$0 2035
$195 62 0
$0
$0
$0 2036
$195 62 0
$0
$0
$0 20
$241,800
$169,581
$206,890 Issue 67:
Category 1 Operations - Maximally Exposed Individual Annual Doses Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 53 0
$0
$0
$0 2027
$195 53 8
$82,680
$63,076
$73,460 2028
$195 53 2
$20,670
$14,737
$17,830 2029
$195 53 8
$82,680
$55,093
$69,243 2030
$195 53 1
$10,335
$6,436
$8,403 2031
$195 53 0
$0
$0
$0 2032
$195 53 1
$10,335
$5,622
$7,921 2033
$195 53 0
$0
$0
$0 2034
$195 53 0
$0
$0
$0 2035
$195 53 0
$0
$0
$0 2036
$195 53 0
$0
$0
$0 20
$206,700
$144,964
$176,858 Issue 68:
Category 1 Operations - Total Population Annual Doses Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 64 0
$0
$0
$0 2027
$195 64 8
$99,840
$76,167
$88,707 2028
$195 64 2
$24,960
$17,796
$21,531 2029
$195 64 8
$99,840
$66,528
$83,614 2030
$195 64 1
$12,480
$7,772
$10,147 2031
$195 64 0
$0
$0
$0 2032
$195 64 1
$12,480
$6,788
$9,565 2033
$195 64 0
$0
$0
$0 2034
$195 64 0
$0
$0
$0 2035
$195 64 0
$0
$0
$0 2036
$195 64 0
$0
$0
$0 20
$249,600
$175,051
$213,564 Issue 69:
Category 1 Operations - Nonhuman Biota Doses Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 36 0
$0
$0
$0 2027
$195 36 8
$56,160
$42,844
$49,897 2028
$195 36 2
$14,040
$10,010
$12,111 2029
$195 36 8
$56,160
$37,422
$47,033 2030
$195 36 1
$7,020
$4,372
$5,708 2031
$195 36 0
$0
$0
$0 2032
$195 36 1
$7,020
$3,818
$5,380 2033
$195 36 0
$0
$0
$0 2034
$195 36 0
$0
$0
$0 2035
$195 36 0
$0
$0
$0
Regulatory Analysis Page A-65 2036
$195 36 0
$0
$0
$0 20
$140,400
$98,466
$120,130 Issue 70:
Category 1 Construction - Building Impacts of Chemical, Biological, and Physical Nonradiological Hazards Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 44 0
$0
$0
$0 2027
$195 44 8
$68,640
$52,365
$60,986 2028
$195 44 2
$17,160
$12,235
$14,802 2029
$195 44 8
$68,640
$45,738
$57,485 2030
$195 44 1
$8,580
$5,343
$6,976 2031
$195 44 0
$0
$0
$0 2032
$195 44 1
$8,580
$4,667
$6,576 2033
$195 44 0
$0
$0
$0 2034
$195 44 0
$0
$0
$0 2035
$195 44 0
$0
$0
$0 2036
$195 44 0
$0
$0
$0 20
$171,600
$120,348
$146,825 Issue 71:
Category 1 Operations - Operation Impacts of Chemical, Biological, and Physical Nonradiological Hazards Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 23 0
$0
$0
$0 2027
$195 23 8
$35,880
$27,373
$31,879 2028
$195 23 2
$8,970
$6,395
$7,738 2029
$195 23 8
$35,880
$23,908
$30,049 2030
$195 23 1
$4,485
$2,793
$3,647 2031
$195 23 0
$0
$0
$0 2032
$195 23 1
$4,485
$2,440
$3,437 2033
$195 23 0
$0
$0
$0 2034
$195 23 0
$0
$0
$0 2035
$195 23 0
$0
$0
$0 2036
$195 23 0
$0
$0
$0 20
$89,700
$62,909
$76,750 Issue 72:
Category 1 Construction - Construction-Related Noise Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 17 0
$0
$0
$0 2027
$195 17 8
$26,520
$20,232
$23,563 2028
$195 17 2
$6,630
$4,727
$5,719 2029
$195 17 8
$26,520
$17,671
$22,210 2030
$195 17 1
$3,315
$2,064
$2,695 2031
$195 17 0
$0
$0
$0 2032
$195 17 1
$3,315
$1,803
$2,541 2033
$195 17 0
$0
$0
$0 2034
$195 17 0
$0
$0
$0 2035
$195 17 0
$0
$0
$0 2036
$195 17 0
$0
$0
$0
Regulatory Analysis Page A-66 20
$66,300
$46,498
$56,728 Issue 73:
Category 1 Operations - Operation-Related Noise Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 10 0
$0
$0
$0 2027
$195 10 8
$15,600
$11,901
$13,860 2028
$195 10 2
$3,900
$2,781
$3,364 2029
$195 10 8
$15,600
$10,395
$13,065 2030
$195 10 1
$1,950
$1,214
$1,586 2031
$195 10 0
$0
$0
$0 2032
$195 10 1
$1,950
$1,061
$1,495 2033
$195 10 0
$0
$0
$0 2034
$195 10 0
$0
$0
$0 2035
$195 10 0
$0
$0
$0 2036
$195 10 0
$0
$0
$0 20
$39,000
$27,352
$33,369 Issue 74:
Category 1 Operations - Low-Level Radioactive Waste Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 145 0
$0
$0
$0 2027
$195 145 8
$226,200
$172,567
$200,976 2028
$195 145 2
$56,550
$40,319
$48,781 2029
$195 145 8
$226,200
$150,727
$189,439 2030
$195 145 1
$28,275
$17,608
$22,990 2031
$195 145 0
$0
$0
$0 2032
$195 145 1
$28,275
$15,380
$21,670 2033
$195 145 0
$0
$0
$0 2034
$195 145 0
$0
$0
$0 2035
$195 145 0
$0
$0
$0 2036
$195 145 0
$0
$0
$0 20
$565,500
$396,601
$483,856 Issue 75:
Category 1 Operations - Onsite Spent Nuclear Fuel Management Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 176 0
$0
$0
$0 2027
$195 176 8
$274,560
$209,461
$243,943 2028
$195 176 2
$68,640
$48,939
$59,209 2029
$195 176 8
$274,560
$182,951
$229,940 2030
$195 176 1
$34,320
$21,373
$27,905 2031
$195 176 0
$0
$0
$0 2032
$195 176 1
$34,320
$18,668
$26,303 2033
$195 176 0
$0
$0
$0 2034
$195 176 0
$0
$0
$0 2035
$195 176 0
$0
$0
$0 2036
$195 176 0
$0
$0
$0 20
$686,400
$481,391
$587,301
Regulatory Analysis Page A-67 Issue 76:
Category 1 Operations - Mixed Waste Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 136 0
$0
$0
$0 2027
$195 136 8
$212,160
$161,856
$188,501 2028
$195 136 2
$53,040
$37,817
$45,753 2029
$195 136 8
$212,160
$141,371
$177,681 2030
$195 136 1
$26,520
$16,515
$21,563 2031
$195 136 0
$0
$0
$0 2032
$195 136 1
$26,520
$14,425
$20,325 2033
$195 136 0
$0
$0
$0 2034
$195 136 0
$0
$0
$0 2035
$195 136 0
$0
$0
$0 2036
$195 136 0
$0
$0
$0 20
$530,400
$371,984
$453,823 Issue 77:
Category 1 Construction - Construction Nonradiological Waste Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 34 0
$0
$0
$0 2027
$195 34 8
$53,040
$40,464
$47,125 2028
$195 34 2
$13,260
$9,454
$11,438 2029
$195 34 8
$53,040
$35,343
$44,420 2030
$195 34 1
$6,630
$4,129
$5,391 2031
$195 34 0
$0
$0
$0 2032
$195 34 1
$6,630
$3,606
$5,081 2033
$195 34 0
$0
$0
$0 2034
$195 34 0
$0
$0
$0 2035
$195 34 0
$0
$0
$0 2036
$195 34 0
$0
$0
$0 20
$132,600
$92,996
$113,456 Issue 78:
Category 1 Operations - Operation Nonradiological Waste Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 17 0
$0
$0
$0 2027
$195 17 8
$26,520
$20,232
$23,563 2028
$195 17 2
$6,630
$4,727
$5,719 2029
$195 17 8
$26,520
$17,671
$22,210 2030
$195 17 1
$3,315
$2,064
$2,695 2031
$195 17 0
$0
$0
$0 2032
$195 17 1
$3,315
$1,803
$2,541 2033
$195 17 0
$0
$0
$0 2034
$195 17 0
$0
$0
$0 2035
$195 17 0
$0
$0
$0 2036
$195 17 0
$0
$0
$0 20
$66,300
$46,498
$56,728 Issue 79:
Category 1 Operations - Design Basis Accidents Involving Radiological Releases Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV
Regulatory Analysis Page A-68 2026
$195 120 0
$0
$0
$0 2027
$195 120 8
$187,200
$142,814
$166,325 2028
$195 120 2
$46,800
$33,368
$40,370 2029
$195 120 8
$187,200
$124,739
$156,777 2030
$195 120 1
$23,400
$14,572
$19,026 2031
$195 120 0
$0
$0
$0 2032
$195 120 1
$23,400
$12,728
$17,934 2033
$195 120 0
$0
$0
$0 2034
$195 120 0
$0
$0
$0 2035
$195 120 0
$0
$0
$0 2036
$195 120 0
$0
$0
$0 20
$468,000
$328,221
$400,432 Issue 80:
Category 1 Operations - Accidents Involving Releases of Hazardous Chemicals Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 120 0
$0
$0
$0 2027
$195 120 8
$187,200
$142,814
$166,325 2028
$195 120 2
$46,800
$33,368
$40,370 2029
$195 120 8
$187,200
$124,739
$156,777 2030
$195 120 1
$23,400
$14,572
$19,026 2031
$195 120 0
$0
$0
$0 2032
$195 120 1
$23,400
$12,728
$17,934 2033
$195 120 0
$0
$0
$0 2034
$195 120 0
$0
$0
$0 2035
$195 120 0
$0
$0
$0 2036
$195 120 0
$0
$0
$0 20
$468,000
$328,221
$400,432 Issue 81:
Category 1 Operations - Severe Accident Mitigation Design Alternatives Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 61 0
$0
$0
$0 2027
$195 61 8
$95,160
$72,597
$84,548 2028
$195 61 2
$23,790
$16,962
$20,521 2029
$195 61 8
$95,160
$63,409
$79,695 2030
$195 61 1
$11,895
$7,408
$9,672 2031
$195 61 0
$0
$0
$0 2032
$195 61 1
$11,895
$6,470
$9,117 2033
$195 61 0
$0
$0
$0 2034
$195 61 0
$0
$0
$0 2035
$195 61 0
$0
$0
$0 2036
$195 61 0
$0
$0
$0 20
$237,900
$166,846
$203,553 Issue 82:
Category 1 Operations - Acts of Terrorism Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 57 0
$0
$0
$0 2027
$195 57 8
$88,920
$67,837
$79,004 2028
$195 57 2
$22,230
$15,850
$19,176
Regulatory Analysis Page A-69 2029
$195 57 8
$88,920
$59,251
$74,469 2030
$195 57 1
$11,115
$6,922
$9,038 2031
$195 57 0
$0
$0
$0 2032
$195 57 1
$11,115
$6,046
$8,519 2033
$195 57 0
$0
$0
$0 2034
$195 57 0
$0
$0
$0 2035
$195 57 0
$0
$0
$0 2036
$195 57 0
$0
$0
$0 20
$222,300
$155,905
$190,205 Issue 83:
Category 1 Construction - Community Services and Infrastructure Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 44 0
$0
$0
$0 2027
$195 44 8
$68,640
$52,365
$60,986 2028
$195 44 2
$17,160
$12,235
$14,802 2029
$195 44 8
$68,640
$45,738
$57,485 2030
$195 44 1
$8,580
$5,343
$6,976 2031
$195 44 0
$0
$0
$0 2032
$195 44 1
$8,580
$4,667
$6,576 2033
$195 44 0
$0
$0
$0 2034
$195 44 0
$0
$0
$0 2035
$195 44 0
$0
$0
$0 2036
$195 44 0
$0
$0
$0 20
$171,600
$120,348
$146,825 Issue 84:
Category 1 Construction - Transportation Systems and Traffic Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 89 0
$0
$0
$0 2027
$195 89 8
$138,840
$105,920
$123,358 2028
$195 89 2
$34,710
$24,748
$29,941 2029
$195 89 8
$138,840
$92,515
$116,276 2030
$195 89 1
$17,355
$10,808
$14,111 2031
$195 89 0
$0
$0
$0 2032
$195 89 1
$17,355
$9,440
$13,301 2033
$195 89 0
$0
$0
$0 2034
$195 89 0
$0
$0
$0 2035
$195 89 0
$0
$0
$0 2036
$195 89 0
$0
$0
$0 20
$347,100
$243,431
$296,987 Issue 85:
Category 1 Construction - Economic Impacts Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 43 0
$0
$0
$0 2027
$195 43 8
$67,080
$51,175
$59,600 2028
$195 43 2
$16,770
$11,957
$14,466 2029
$195 43 8
$67,080
$44,698
$56,178 2030
$195 43 1
$8,385
$5,222
$6,818 2031
$195 43 0
$0
$0
$0
Regulatory Analysis Page A-70 2032
$195 43 1
$8,385
$4,561
$6,426 2033
$195 43 0
$0
$0
$0 2034
$195 43 0
$0
$0
$0 2035
$195 43 0
$0
$0
$0 2036
$195 43 0
$0
$0
$0 20
$167,700
$117,613
$143,488 Issue 86:
Category 1 Construction - Tax Revenue Impacts Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 25 0
$0
$0
$0 2027
$195 25 8
$39,000
$29,753
$34,651 2028
$195 25 2
$9,750
$6,952
$8,410 2029
$195 25 8
$39,000
$25,987
$32,662 2030
$195 25 1
$4,875
$3,036
$3,964 2031
$195 25 0
$0
$0
$0 2032
$195 25 1
$4,875
$2,652
$3,736 2033
$195 25 0
$0
$0
$0 2034
$195 25 0
$0
$0
$0 2035
$195 25 0
$0
$0
$0 2036
$195 25 0
$0
$0
$0 20
$97,500
$68,379
$83,423 Issue 87:
Category 1 Operations - Community Services and Infrastructure Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 29 0
$0
$0
$0 2027
$195 29 8
$45,240
$34,513
$40,195 2028
$195 29 2
$11,310
$8,064
$9,756 2029
$195 29 8
$45,240
$30,145
$37,888 2030
$195 29 1
$5,655
$3,522
$4,598 2031
$195 29 0
$0
$0
$0 2032
$195 29 1
$5,655
$3,076
$4,334 2033
$195 29 0
$0
$0
$0 2034
$195 29 0
$0
$0
$0 2035
$195 29 0
$0
$0
$0 2036
$195 29 0
$0
$0
$0 20
$113,100
$79,320
$96,771 Issue 88:
Category 1 Operations - Transportation Systems and Traffic Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 15 0
$0
$0
$0 2027
$195 15 8
$23,400
$17,852
$20,791 2028
$195 15 2
$5,850
$4,171
$5,046 2029
$195 15 8
$23,400
$15,592
$19,597 2030
$195 15 1
$2,925
$1,822
$2,378 2031
$195 15 0
$0
$0
$0 2032
$195 15 1
$2,925
$1,591
$2,242 2033
$195 15 0
$0
$0
$0 2034
$195 15 0
$0
$0
$0
Regulatory Analysis Page A-71 2035
$195 15 0
$0
$0
$0 2036
$195 15 0
$0
$0
$0 20
$58,500
$41,028
$50,054 Issue 89:
Category 1 Operations - Economic Impacts Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 29 0
$0
$0
$0 2027
$195 29 8
$45,240
$34,513
$40,195 2028
$195 29 2
$11,310
$8,064
$9,756 2029
$195 29 8
$45,240
$30,145
$37,888 2030
$195 29 1
$5,655
$3,522
$4,598 2031
$195 29 0
$0
$0
$0 2032
$195 29 1
$5,655
$3,076
$4,334 2033
$195 29 0
$0
$0
$0 2034
$195 29 0
$0
$0
$0 2035
$195 29 0
$0
$0
$0 2036
$195 29 0
$0
$0
$0 20
$113,100
$79,320
$96,771 Issue 90:
Category 1 Operations - Tax Revenue Impacts Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 57 0
$0
$0
$0 2027
$195 57 8
$88,920
$67,837
$79,004 2028
$195 57 2
$22,230
$15,850
$19,176 2029
$195 57 8
$88,920
$59,251
$74,469 2030
$195 57 1
$11,115
$6,922
$9,038 2031
$195 57 0
$0
$0
$0 2032
$195 57 1
$11,115
$6,046
$8,519 2033
$195 57 0
$0
$0
$0 2034
$195 57 0
$0
$0
$0 2035
$195 57 0
$0
$0
$0 2036
$195 57 0
$0
$0
$0 20
$222,300
$155,905
$190,205 Issue 91:
Category 1 Operations - Uranium Recovery Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 26 0
$0
$0
$0 2027
$195 26 8
$40,560
$30,943
$36,037 2028
$195 26 2
$10,140
$7,230
$8,747 2029
$195 26 8
$40,560
$27,027
$33,968 2030
$195 26 1
$5,070
$3,157
$4,122 2031
$195 26 0
$0
$0
$0 2032
$195 26 1
$5,070
$2,758
$3,886 2033
$195 26 0
$0
$0
$0 2034
$195 26 0
$0
$0
$0 2035
$195 26 0
$0
$0
$0 2036
$195 26 0
$0
$0
$0 20
$101,400
$71,115
$86,760
Regulatory Analysis Page A-72 Issue 92:
Category 1 Operations - Uranium Conversion Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 26 0
$0
$0
$0 2027
$195 26 8
$40,560
$30,943
$36,037 2028
$195 26 2
$10,140
$7,230
$8,747 2029
$195 26 8
$40,560
$27,027
$33,968 2030
$195 26 1
$5,070
$3,157
$4,122 2031
$195 26 0
$0
$0
$0 2032
$195 26 1
$5,070
$2,758
$3,886 2033
$195 26 0
$0
$0
$0 2034
$195 26 0
$0
$0
$0 2035
$195 26 0
$0
$0
$0 2036
$195 26 0
$0
$0
$0 20
$101,400
$71,115
$86,760 2026
$195 26 0
$0
$0
$0 Issue 93:
Category 1 Operations - Enrichment Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 32 0
$0
$0
$0 2027
$195 32 8
$49,920
$38,084
$44,353 2028
$195 32 2
$12,480
$8,898
$10,765 2029
$195 32 8
$49,920
$33,264
$41,807 2030
$195 32 1
$6,240
$3,886
$5,074 2031
$195 32 0
$0
$0
$0 2032
$195 32 1
$6,240
$3,394
$4,782 2033
$195 32 0
$0
$0
$0 2034
$195 32 0
$0
$0
$0 2035
$195 32 0
$0
$0
$0 2036
$195 32 0
$0
$0
$0 20
$124,800
$87,526
$106,782 Issue 94:
Category 1 Operations - Fuel Fabrication Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 37 0
$0
$0
$0 2027
$195 37 8
$57,720
$44,034
$51,283 2028
$195 37 2
$14,430
$10,288
$12,447 2029
$195 37 8
$57,720
$38,461
$48,340 2030
$195 37 1
$7,215
$4,493
$5,866 2031
$195 37 0
$0
$0
$0 2032
$195 37 1
$7,215
$3,924
$5,530 2033
$195 37 0
$0
$0
$0 2034
$195 37 0
$0
$0
$0 2035
$195 37 0
$0
$0
$0 2036
$195 37 0
$0
$0
$0 20
$144,300
$101,202
$123,467
Regulatory Analysis Page A-73 Issue 95:
Category 1 Operations - Reprocessing Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 27 0
$0
$0
$0 2027
$195 27 8
$42,120
$32,133
$37,423 2028
$195 27 2
$10,530
$7,508
$9,083 2029
$195 27 8
$42,120
$28,066
$35,275 2030
$195 27 1
$5,265
$3,279
$4,281 2031
$195 27 0
$0
$0
$0 2032
$195 27 1
$5,265
$2,864
$4,035 2033
$195 27 0
$0
$0
$0 2034
$195 27 0
$0
$0
$0 2035
$195 27 0
$0
$0
$0 2036
$195 27 0
$0
$0
$0 20
$105,300
$73,850
$90,097 Issue 96:
Category 1 Operations - Storage and Disposal of Radiological Wastes Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 37 0
$0
$0
$0 2027
$195 37 8
$57,720
$44,034
$51,283 2028
$195 37 2
$14,430
$10,288
$12,447 2029
$195 37 8
$57,720
$38,461
$48,340 2030
$195 37 1
$7,215
$4,493
$5,866 2031
$195 37 0
$0
$0
$0 2032
$195 37 1
$7,215
$3,924
$5,530 2033
$195 37 0
$0
$0
$0 2034
$195 37 0
$0
$0
$0 2035
$195 37 0
$0
$0
$0 2036
$195 37 0
$0
$0
$0 20
$144,300
$101,202
$123,467 Issue 97:
Category 1 Operations - Transportation of Unirradiated Fuel Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 57 0
$0
$0
$0 2027
$195 57 8
$88,920
$67,837
$79,004 2028
$195 57 2
$22,230
$15,850
$19,176 2029
$195 57 8
$88,920
$59,251
$74,469 2030
$195 57 1
$11,115
$6,922
$9,038 2031
$195 57 0
$0
$0
$0 2032
$195 57 1
$11,115
$6,046
$8,519 2033
$195 57 0
$0
$0
$0 2034
$195 57 0
$0
$0
$0 2035
$195 57 0
$0
$0
$0 2036
$195 57 0
$0
$0
$0 20
$222,300
$155,905
$190,205
Regulatory Analysis Page A-74 Issue 98:
Category 1 Operations - Transportation of Radioactive Waste Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 57 0
$0
$0
$0 2027
$195 57 8
$88,920
$67,837
$79,004 2028
$195 57 2
$22,230
$15,850
$19,176 2029
$195 57 8
$88,920
$59,251
$74,469 2030
$195 57 1
$11,115
$6,922
$9,038 2031
$195 57 0
$0
$0
$0 2032
$195 57 1
$11,115
$6,046
$8,519 2033
$195 57 0
$0
$0
$0 2034
$195 57 0
$0
$0
$0 2035
$195 57 0
$0
$0
$0 2036
$195 57 0
$0
$0
$0 20
$222,300
$155,905
$190,205 Issue 99:
Category 1 Operations - Transportation of Irradiated Fuel Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 181 0
$0
$0
$0 2027
$195 181 8
$282,360
$215,411
$250,873 2028
$195 181 2
$70,590
$50,330
$60,892 2029
$195 181 8
$282,360
$188,148
$236,472 2030
$195 181 1
$35,295
$21,980
$28,698 2031
$195 181 0
$0
$0
$0 2032
$195 181 1
$35,295
$19,198
$27,051 2033
$195 181 0
$0
$0
$0 2034
$195 181 0
$0
$0
$0 2035
$195 181 0
$0
$0
$0 2036
$195 181 0
$0
$0
$0 20
$705,900
$495,067
$603,986 Issue 100:
Decommissioning Year Labor Rate Hours per Application Applications per Year Undiscounted 7% NPV 3% NPV 2026
$195 95 0
$0
$0
$0 2027
$195 95 8
$148,200
$113,061
$131,674 2028
$195 95 2
$37,050
$26,416
$31,960 2029
$195 95 8
$148,200
$98,752
$124,115 2030
$195 95 1
$18,525
$11,536
$15,063 2031
$195 95 0
$0
$0
$0 2032
$195 95 1
$18,525
$10,076
$14,198 2033
$195 95 0
$0
$0
$0 2034
$195 95 0
$0
$0
$0 2035
$195 95 0
$0
$0
$0 2036
$195 95 0
$0
$0
$0 20
$370,500
$259,842
$317,009
Regulatory Analysis Page A-75 Table A.3 presents the BLS Labor Rates used to generate the blended, weighted labor rate used for industry activity in this regulatory analysis.
Table A.3 Bureau of Labor Statistics Labor Rates in the Regulatory Analysis Industry: Nuclear Electric Power Generation (NAICS code 221113)
Period: May 2023 Occupation (SOC code)
Hourly mean wage*
Hourly 25th percentile wage*
Hourly 75th percentile wage*
General and Operations Managers (111021)
$102.84
$79.04
$126.64 Industrial Production Managers (113051)
$91.55
$78.75
$101.18 Nuclear Engineers (172161)
$60.10
$49.54
$67.63 Life, Physical, and Social Science Occupations (190000)
$52.31
$47.92
$59.12 Physical Scientists (192000)
$60.40
$50.53
$64.49 Environmental Scientists and Geoscientists (192040)
$60.72
$54.13
$65.28 Office and Administrative Support Occupations (430000)
$39.15
$28.71
$49.97 First-Line Supervisors of Office and Administrative Support Workers (431011)
$56.18
$39.08
$65.61 Office Clerks General (439061)
$31.17
$26.14
$36.51 First-Line Supervisors of Mechanics Installers and Repairers (491011)
$65.32
$54.76
$73.45 First-Line Supervisors of Production and Operating Workers (511011)
$78.48
$66.07
$86.80 Industry: Electric Power Generation, Transmission and Distribution (NAICS code 221100)
Period: May 2023 Occupation (SOC code)
Hourly mean wage Hourly 25th percentile wage Hourly 75th percentile wage Biological Scientists (191020)
$44.43
$34.23
$48.86 Lawyers (231011)
$102.69
$79.46
$125.92 Paralegals and Legal Assistants (232011)
$43.62
$37.71
$49.53 These labor rates are unburdened by overhead factors in the Bureau of Labor Statistics data. This regulatory analysis multiplied these rates by a labor multiplier of 2.4, and then binned them into categories for use in creating the blended, weighted labor rate in this analysis. The categories and burdened mean hourly wages are:
Managers, $202.91; Technical Staff, $130.54; Administrative Staff, $101.20; and Licensing Staff, $73.16.