ML22243A006

Rulemaking-Proposed Rule-Regulatory Analysis, American Society of Mechanical Engineers Code Cases RG 1.84 Rev 40, RG 1.147 Rev 21, RG 1.192 Rev 5, and Revision of Inservice Inspection and Inservice Testing Code of Record Frequency Update

ML22243A006
Person / Time
Issue date:	01/31/2023
From:	NRC/NMSS/DREFS/RASB
To:
Andrukat, Dennis
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ML22243A001	List: ML22243A006
References
NRC-2018-0291, RIN 3150-AK23, RG-1.147, Rev 21, RG-1.192, Rev 5, RG-1.084, Rev 40
Download: ML22243A006 (57)

Text

Regulatory Analysis for the Proposed Rule:

Approval of American Society of Mechanical Engineers Code Cases and Update Frequency NRC-2018-0291; RIN 3150-AK23

U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Division of Rulemaking, Environmental, and Financial Support

JANUARY 2023

Abstract

This proposed rule recommends approval, through the Nuclear Reg ulatory Commissions (NRC) regulations, of the latest revisions to the NRC regulatory guid es (RGs) listing American Society of Mechanical Engineers (ASME) Code Cases for the ASME Boiler a nd Pressure Vessel Code and the ASME Operation and Maintenance of Nuclear Power Plants Code. These are code cases that the NRC finds acceptable or acceptable with NRC-spec ified conditions (conditionally acceptable). The NRC is issuing three RG revisions that identi fy the ASME Code Cases proposed for NRC approval:

(1) RG 1.84, Design, Fabrication, and Materials Code Case Acce ptability, ASME Section III, Revision 40 (Draft Regulatory Guide (DG)-1405), w ould supersede RG 1.84, Revision 39, issued December 2021.

(2) RG 1.147, Inservice Inspec tion Code Case Acceptability, ASME Section XI, Division 1, Revision 21 (DG-1406), would supersede RG 1.147, Revision 20, i ssued December 2021.

(3) RG 1.192, Operation and Maintenance Code Case Acceptabilit y, ASME OM Code, Revision 5 (DG-1407), would supersede RG 1.192, Revision 4, iss ued December 2021.

Furthermore, this proposed rule would change the code of record interval to be twice the ISI or IST interval (from 10 years currently), plus the one-time 1-yea r extension for IST and ISI programs per their respective ASME Code, or 25 years. This docu ment includes the regulatory analysis of the proposed rule for the three RGs that list the c ode cases proposed for NRC approval and the code of record interval extension. To increase the credibility of its cost estimates for this regulatory action, the NRC staff conducted ( 1) an uncertainty analysis to consider the effects of input uncertainty on the cost estimates and (2) a sensitivity analysis to identify the variables that most affect the cost estimates (i.e., the cost drivers).

i Contents

Section Page Abstract.......................................................................................................................................... i Abbreviations and Acronyms........................................................................................................ v Executive Summary..................................................................................................................... vii

1. Introduction....................................................................................................................... 1

2. Statement of the Problem and Objective.......................................................................... 1 2.1 Background........................................................................................................... 1 2.3 Objective............................................................................................................... 3

3. Identification and Preliminary Analysis of Alternative Approach es.................................... 3 3.1 Alternative 1: No Action......................................................................................... 4 3.2 Alternative 2: Incorporate by Reference NRC-Approved ASME BPV a nd OM Code Cases.................................................................................................... 4

4. Estimation and Evaluation of Costs and Benefits............................................................. 5 4.1 Identification of Affected Attributes........................................................................ 5 4.2 Analytical Methodology......................................................................................... 7 4.2.1 Regulatory Baseline................................................................................. 8 4.2.2 Affected Entities....................................................................................... 8 4.2.3 Base Year................................................................................................ 8 4.2.4 Discount Rates......................................................................................... 9 4.2.5 Labor Rates.............................................................................................. 9 4.2.6 Sign Conventions................................................................................... 10 4.2.7 Analysis Horizon.................................................................................... 11 4.2.8 Cost Estimation...................................................................................... 11 4.2.9 ASME Code Cases Incorporated by Reference..................................... 12 4.3 Data..................................................................................................................... 17 5 Results............................................................................................................................ 17 5.1 Public Health (Accident)...................................................................................... 19 5.2 Occupational Health (Accident and Routine)....................................................... 20 5.3 Industry Implementation...................................................................................... 20 5.4 Industry Operation............................................................................................... 20 5.5 Total Industry Costs............................................................................................ 24 5.6 NRC Implementation........................................................................................... 24 5.7 NRC Operation.................................................................................................... 24 5.8 Total NRC Costs................................................................................................. 26 5.9 Total Costs.......................................................................................................... 27 5.10 Improvements in Knowledge............................................................................... 28 5.11 Regulatory Efficiency........................................................................................... 28 5.12 Other Considerations.......................................................................................... 28 5.12.1 Consistency with National Technology Transfer and Advancement Act of 1995...................................................................... 28

ii 5.12.2 Continued Incorporation by Reference of ASME Code Editions and Addenda into the Code of Federal Regulations..................................... 29 5.12.3 Increased Public Confidence................................................................. 29 5.13 Uncertainty Analysis............................................................................................ 29 5.13.1 Uncertainty Analysis Assumptions......................................................... 29 5.13.2 Uncertainty Analysis Results.................................................................. 31 5.13.3 Summary of Uncertainty Analysis.......................................................... 33 5.14 Disaggregation.................................................................................................... 34 5.15 Summary............................................................................................................. 35 5.15.1 Quantified Net Benefit............................................................................ 35 5.15.2 Nonquantified Benefits........................................................................... 35 5.15.3 Advances in Inservice Inspection and Inservice Testing........................ 35 5.15.2 Nonquantified Costs............................................................................... 37 5.16 Safety Goal Evaluation........................................................................................ 37 5.17 Backfitting Discussion......................................................................................... 38 5.17.1 Section A: Incorporation by Reference of Later Editions and Addenda of Section III, Division 1, of the ASME BPV Code.................. 38 5.17.2 Section B: Incorporation by Reference of Later Editions and Addenda of Section XI, Division 1, of the ASME BPV and OM Codes.. 38 5.17.3 Other Circumstances in Which the NRC Does Not Apply the Backfit Rule to the Endorsement of a Later Code.................................. 39 5.18 Results for the Committee to Review Generic Requirements............................. 39 6 Decision Rationale.......................................................................................................... 40 7 Implementation Schedule................................................................................................ 43 8 References...................................................................................................................... 43 Appendix A Major Assumptions and Input Data....................................................................... A-1

iii List of Figures

Figure Page Figure 1 Total Industry Averted Costs (7-percent NPV)Alternati ve 2...................................... 31 Figure 2 Total NRC Costs (7-percent NPV)Alternative 2........................................................ 32 Figure 3 Total Costs (7-percent NPV)Alternative 2................................................................. 32 Figure 4 Top Six Cost Drivers in Terms of Uncertainty (7-percen t NPV)Alternative 2............ 33

List of Tables

Table Page Table ES-1 Total Costs and Benefits for Rulemaking Alternative............................................... viii Table 1 Position Titles and Occupations..................................................................................... 10 Table 2 Conditioned Code Cases under Consideration.............................................................. 12 Table 3 Averted Industry Alternative Requests........................................................................... 21 Table 4 Licensee Alternative Requests...................................................................................... 2 2 Table 5 Averted Costs Due to Extended Code of Record Interval.............................................. 23 Table 6 Total Industry Costs....................................................................................................... 24 Table 7 NRC Implementation Costs........................................................................................... 2 4 Table 8 NRC Operation CostsAverted Code Alternative Requests (Operating and New Reactors)...................................................................................... 25 Table 9 NRC Alternative Request Review Costs........................................................................ 25 Table 10 Averted Costs from NRC Code of Record Update Reviews........................................ 26 Table 11 Total NRC Costs.......................................................................................................... 27 Table 12 Total Costs................................................................................................................... 27 Table 13 Typical BWR vs. PWR Code of Record Averted Costs (Indu stry)............................... 27 Table 14 Typical BWR vs. PWR Code of Record Averted Costs (NRC).................................... 28 Table 15 Uncertainty Analysis Variables.................................................................................... 3 0 Table 16 Descriptive Statistics for Uncertainty Results (7-Perc ent NPV)................................... 33 Table 17 Disaggregation............................................................................................................. 34 Table 18 Net Averted Costs to Industry...................................................................................... 34 Table 19 Net Averted Costs to NRC........................................................................................... 35 Table 20 Specific CRGR Information Requirements for Regulatory Analysis............................. 39 Table 21 Summary of Totals....................................................................................................... 40

iv Abbreviations and Acronyms

ADAMS Agencywide Documents Access and Management System ASME American Society of Mechanical Engineers ASME Codes ASME BPV and OM Codes

BLS Bureau of Labor Statistics BPV boiler and pressure vessel BPV Code ASME Boiler and Pressure Vessel Code BWR boiling-water reactor

CFR Code of Federal Regulations CPI-U Consumer Price Index for All Urban Consumers CRGR Committee to Review Generic Requirements

DG draft regulatory guide

EWR excavation and weld repair

FR Federal Register

ISI inservice inspection IST inservice testing

ksi kilogram per square inch

LOE level of effort

MRP materials reliability program

NPV net present value NTTAA National Technology Transfer and Advancement Act of 1995 NUREG NRC technical report

OM Code ASME Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST OMB U.S. Office of Management and Budget

PERT program evaluation and review technique PWR pressurized water reactor

RG regulatory guide

UTS ultimate tensile strength

v

Executive Summary

The NRC is proposing to amend its regulations to incorporate by reference the latest revisions of three NRC regulatory guides (RGs) approving new, revised, an d reaffirmed code cases published by the American Society of Mechanical Engineers (ASME ). The NRC proposes to incorporate by reference the following three RGs:

(1) RG 1.84, Design, Fabrication, and Materials Code Case Acce ptability, ASME Section III, Revision 40 (Draft Regulatory Guide (DG)-1405)

(2) RG 1.147, Inservice Inspec tion Code Case Acceptability, ASME Section XI, Division 1, Revision 21 (DG-1406)

(3) RG 1.192, Operation and Maintenance Code Case Acceptabilit y, ASME OM Code, Revision 5 (DG-1407)

This regulatory action would allow nuclear power plant licensee s and applicants for construction permits, operating licenses, combined licenses, standard design certifications, standard design approvals, and manufacturing licenses to voluntarily use the AS ME Code Cases newly listed in these RGs as alternatives to ASME engineering standards for the construction, inservice inspection, and inservice testing of nuclear power plant compon ents.

Furthermore, this proposed rule would change the maximum code o f record interval to 25 years (from 10 years currently).

This document examines the averted costs (i.e., benefits) and c osts of the proposed rulemaking and implementing guidance relative to the baseline case (i.e., the no-action alternative).

The NRC staff has made the following key findings:

• Proposed Rule Analysis: The proposed rule recommended by the s taff would result in a cost-justified change based on a net (i.e., taking into account both costs and benefits) averted cost to the industry of between $29.9 million (7-percen t NPV) and $35.1 million (3-percent NPV). Compared to the regulatory baseline, the NRC w ould realize net averted costs of between $4.42 million (7-percent NPV) and $5.3 8 million (3-percent NPV). In total, the net averted costs to the industry and the N RC would be between

$34.3 million (7-percent NPV) and $40.5 million (3-percent NPV). Table ES-1 shows these costs and benefits.

vii Table ES-1 Total Costs and Benefits for Rulemaking Alternative

Attribute Cost s Undiscounted 7% NPV 3% NPV Total Industry Costs: ($1,288,000) ($1,051,000) ($1,178,000)

Total NRC Costs: ($1,233,000) ($1,022,000) ($1,136,000)

Total ($2,521,000) ($2,073,000) ($2,314,000)

Attribute Benefits Undiscounted 7% NPV 3% NPV Total Industry Benefits: $38,000,000 $30,940,000 $36,290,000 Total NRC Benefits: $7,100,000 $5,440,000 $6,520,000 Tot al $45, 100, 000 $36, 380, 000 $42, 810, 000

Attribute Net Benefits (Costs)

Undiscounted 7% NPV 3% NPV Industry $36,710,000 $29,890,000 $35,110,000 NRC $5,870,000 $4,420,000 $5,380,000 Tot al $42, 580, 000 $34, 310, 000 $40, 490, 000

• Nonquantified Benefits: The proposed rule would also enable th e NRC to continue to protect public health and safety and the environment by approvi ng new and updated code cases from the ASME Boiler and Pressure Vessel Code and AS ME Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Secti on IST, which allow the use of the most current methods and technology. The propose d rule is consistent with the provisions of the National Technology Transfer and Adv ancement Act of 1995 and implementing guidance in U.S. Office of Management and Budg et Circular A-119, Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities, dated January 27, 201 6 (OMB, 2016), which encourage Federal regulatory agencies to adopt voluntary consen sus standards as an alternative to de novo agency development of standards affecting an industry. Finally, the ASME Code consensus process is an important part of the reg ulatory framework.

• Uncertainty Analysis: The regulatory analysis includes a simul ation analysis that shows that the estimated mean benefit for this proposed rule is $34.3 million using a 7-percent discount rate, with greater than 99-percent confidence that the proposed rule is cost beneficial. It is reasonable to infer from the uncertainty anal ysis that the proposed rule represents an efficient use of resources and averted costs to t he NRC and the industry.

The industry averted cost for a code of record update is the fa ctor responsible for the largest variation in averted costs.

• Decision Rationale: Comparing the proposed rule to the no-acti on baseline, the staff concludes that the proposed rule is quantitatively justified, b ecause its provisions would result in millions of dollars of net averted costs (i.e., net b enefits) for the NRC and the

viii industry. In addition, the staff concludes that the proposed ru le is also justified in terms of qualitative costs and benefits, because the qualitative bene fits outweigh the qualitative costs.

ix

1. Introduction

This document presents the regulatory analysis of the NRCs pro posed rule on the incorporation by reference of new American Society of Mechanical Engineers (A SME) Code Cases and the following three associated draft regulatory guides (DGs):

• DG-1405, Design, Fabrication, and Materials Code Case Accepta bility, ASME Section III, Regulatory Guide (RG) 1.84, proposed Revision 40

• DG-1406, Inservice Inspection Code Case Acceptability, ASME S ection XI, Division 1, RG 1.147, proposed Revision 21

• DG-1407, Operation and Maintenance Code Acceptability, ASME O M Code, RG 1.192, proposed Revision 5

The recommended regulatory action proposes to incorporate by re ference the latest revisions to the three RGs listed above, so that the NRC approves the newly identified ASME Code Cases.

Furthermore, this proposed rule would change the code of record interval to twice the ISI or IST interval (from 10 years currently).

2. Statement of the Problem and Objective

2.1 Background

ASME develops and publishes the ASME Boiler and Pressure Vessel Code (BPV Code), which contains requirements for the design, construction, and inservi ce inspection (ISI) of nuclear power plant components, and the ASME Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code), which contains requirements for inservice testing (IST) of nuclear power plant components. In response to BPV and OM Code user requests, ASME develops code cases that provide voluntary alternatives to BPV and OM Code requirements under special circumstances.

The NRC approves the ASME BPV and OM Codes in Section 50.55a of Title 10 of the Code of Federal Regulations (10 CFR), Codes and standards, through the process of incorp oration by reference. Each provision of the ASME Codes incorporated by ref erence into and mandated by 10 CFR 50.55a constitutes a legally binding NRC requirement imp osed by rule. As noted previously, ASME Code Cases mostly represent alternative approa ches for complying with provisions of the ASME BPV and OM Codes. Accordingly, the NRC periodically amends 10 CFR 50.55a to incorporate by reference the NRC RGs listing a pproved ASME Code Cases that may be used as voluntary alternatives to the ASME BPV and OM Codes.

This proposed rule is the latest in a series of rules that inco rporate by reference new versions of RGs identifying new, revised, and reaffirmed ASME Code Cases, e ither unconditionally or conditionally acceptable, that t he NRC approves for use. In developing these RGs, the NRC staff reviews ASME BPV and OM Code Cases, determines the accept ability of each code case

1 (i.e., any flexibilities in each code case have a positive or n o impact on safety; code cases are based on sound engineering principles and contain no technical errors), and publishes its findings in the RGs. The RGs are revised periodically as ASME p ublishes new code cases. The NRC incorporates by reference the RGs listing acceptable and co nditionally acceptable ASME Code Cases into 10 CFR 50.55a. On March 3, 2022, the NRC publis hed a final rule in the Federal Register (87 FR 11934) that incorporated by reference into 10 CFR 50.55 a the most recent versions of RG 1.84, Design, Fabrication, and Materials Code Case Acceptability, ASME Section III, Revision 39 (NRC, 2021c); RG 1.147, Inservice In spection Code Case Acceptability, ASME Section XI, Division 1, Revision 20 (NRC, 2021d); and RG 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Cod e, Revision 4 (NRC, 2021e), all issued in December 2021.

The current ISI, IST, and code of record intervals are all set at 10 years. Code Cases N-921 and OMN-31, proposed to be incorporated by reference in this rulema king, change the allowable ISI and IST intervals, respectively, to 12 years. Because this chan ge would allow the ISI, IST, and code of record intervals to go out of alignment, leading to adm inistrative costs and potential confusion, the staff has decided to eliminate the requirement t o update the code of record every 10 years and replace it with a requirement to update the code o f record every two ISI or IST intervals. The revised code of record interval allows the same code of record to be used for two consecutive ISI or IST intervals, each up to 12 years, plus the one-time 1-year extension for IST and ISI programs as specified in the ASME OM Code and ASME BPV Code, respectively, or 25 years.

2.2 Statement of the Problem

ASME may revise code cases for many reasons, such as to incorpo rate operational examination and testing experience or to update material requir ements based on research results. On occasion, an inaccuracy in an equation is discovere d, or an examination as practiced is found to be inadequate for detecting a newly disco vered degradation mechanism.

Therefore, when a licensee initially implements a code case, 10 CFR 50.55a requires the licensee to implement the most recent version of that code case as listed in the approved or conditionally approved tables in 10 CFR 50.55a. A request to us e a previous code case could be submitted and approved as an alternative under 10 CFR 50.55a (z); the NRC evaluates such requests case by case.

Section III of the ASME BPV Code applies to both new constructi on and repair or replacement (under the licensees ASME Code,Section XI, repair/replacement program) of components originally constructed to ASME Code,Section III. The edition a nd addenda to be used in the construction of a plant and the repair or replacement of ASME C ode,Section III, components depend on the date of the construction permit; licensees are no t required to later update their Section III codes of record. If a licensee implements an ASME B PV Code,Section III, code case, and if the NRC later incorporates by reference a newer ve rsion of the code case into 10 CFR 50.55a, that licensee may use either version of the code case.

2 Licensees update their ISI programs under the ASME BPV Code, Se ction XI, and their IST programs under the ASME OM Code every 10 years, in accordance w ith the latest editions and addenda of the ASME Codes that have been incorporated by refere nce into 10 CFR 50.55a and taken effect at least 18 months before the start of the next in spection interval. Licensees that were using an earlier revision of a code case before the effect ive date of the NRCs final rule incorporating a newer version of it may continue to use the pre vious version for the remainder of the 120-month ISI or IST interval. This relieves licensees of t he costs of having to update their ISI or IST program each time the NRC incorporates a revised cod e case. In their next ISI or IST interval, licensees must update any code cases they have chosen to use along with their code of record updates, or else they must submit an alternative requ est under 10 CFR 50.55a(z). The NRC staff has determined that the ASME ISI and IST intervals co uld be extended to 12 years and that the code of record interval may be extended so that li censees would update their codes of record once for every two ISI and IST intervals. Code Cases N-921 and OMN-31, proposed for incorporation by reference in this rulemaking, extend the a llowable ISI and IST intervals, respectively, to 12 years, but the code of record interval is p art of the NRC regulations. This creates a misalignment in the intervals that the staff is seeki ng to prevent through the change to the maximum code of record interval in this proposed rule.

2.3 Objective

The objective of this proposed regulatory action is to incorpor ate by reference the latest revisions to three RGs that list code cases published by ASME a nd approved by the NRC:

(1) RG 1.84, Design, Fabrication, and Materials Code Case Acce ptability, ASME Section III, Revision 40 (DG-1405)

(2) RG 1.147, Inservice Inspec tion Code Case Acceptability, ASME Section XI, Division 1, Revision 21 (DG-1406)

(3) RG 1.192, Operation and Maintenance Code Case Acceptabilit y, ASME OM Code, Revision 5 (DG-1407)

These revisions supersede the incorporation by reference of RG 1.84, Revision 39 (NRC, 2021c); RG 1.147, Revision 20 (NRC, 2021d); and RG 1.192, Revis ion 4 (NRC, 2021e). This regulatory action (1) would improve the effectiveness of future licensing actions, (2) would be consistent with the provisions of the National Technology Trans fer and Advancement Act of 1995 (NTTAA) that encourage Federal regulatory agencies to adop t voluntary consensus standards as an alternative to de novo agency development of standards affecting an industry, and (3) would be consistent with the NRC policy of evaluating w hether the latest versions of already NRC-approved consensus standards are suitable for endor sement by regulation or RG.

Furthermore, this proposed rule would change the code of record interval to twice the ISI or IST interval (from 10 years currently).

3. Identification and Preliminary Analysis of Alternative Appro aches

The NRC has identified two alternatives for this action:

3 (1) Alternative 1: No action (i.e., status quo, regulatory base line).

Alternative 2: Through rulemaking, incorporate by reference int o 10 CFR 50.55a the NRC-approved ASME BPV Code Cases in RG 1.84, Revision 40 (DG-14 05), and RG 1.147, Revision 21 (DG-1406), and the ASME OM Code Cases in RG 1.192, Revision 5 (DG-1407).

Increase the code of record interval to twice the ISI or IST in terval, in conjunction with the ISI and IST interval changes in Code Cases N-921 and OMN-31, respec tively.

3.1 Alternative 1: No Action

The no-action alternative (status quo, regulatory baseline) is a nonrulemaking alternative. Under the no-action alternative, the NRC would not revise its regulat ions to incorporate by reference the latest revisions to these three RGs and would not make conf orming changes to 10 CFR 50.55a to comply with guidance from the Office of the Fe deral Register for incorporating by reference multiple standards into regulations. Under the no-action alternative, licensees and applicants wishing to use these ASME Code Cases would likely re quest and receive NRC approval for the use of alternatives under 10 CFR 50.55a(z). Th e NRC recommends against this alternative for the following reasons:

• Licensees and applicants would need to submit requests for alt ernatives under 10 CFR 50.55a(z) to apply the code cases under consideration, b ecause these code cases would not have been approved in RGs or incorporated by re ference in 10 CFR 50.55a. This process would increase regulatory costs to licensees, applicants, and the NRC.

• Public confidence in the NRC as an effective regulator could b e reduced, because ASME periodically publishes, revises, or annuls code cases. Und er Alternative 1, outdated material and possibly inaccurate information would rem ain incorporated by reference into the Code of Federal Regulations.

• This alternative does not meet the intent of the NTTAA, which encourages Federal regulatory agencies to adopt voluntary consensus standards as a n alternative to de novo agency development of standards affecting an industry.

3.2 Alternative 2: Incorporate by Reference NRC-Approved ASME B PV and OM Code Cases

Alternative 2 would incorporate by reference later revisions to the RGs listing newly NRC-approved ASME Code Cases. This alternative would allow lice nsees and applicants to implement these ASME Code Cases and their conditions and modifi cations, if any, without seeking prior NRC approval. This alternative continues the NRCs use of periodic rulemakings to incorporate by reference in 10 CFR 50.55a the latest RGs tha t list NRC approved alternatives to the provisions of the ASME BPV and OM Codes.

4 Furthermore, Alternative 2 would change the maximum code of int erval to twice the ISI or IST interval (from 10 years currently).

The NRC recommends Alternative 2 for the following reasons:

• This alternative reduces the regulatory costs on applicants or holders of licenses for nuclear power plants by eliminating the need to submit plant-sp ecific requests for alternatives in accordance with 10 CFR 50.55a(z) to apply these code cases. It also eliminates the need for the NRC to review such submittals.

• This alternative meets the NRCs goal of protecting public hea lth and safety and the environment by continuing to approve new, revised, or reaffirmed ASME Code Cases, which enable the use of the latest methods and technology.

• This alternative supports the NRCs goal of maintaining an ope n regulatory process by informing the public about the process and allowing the public to participate in it.

• This alternative supports the NRCs commitment to participating in the national consensus standard process through the approval of these ASME C ode Cases. The alternative also conforms to NTTAA requirements.

• The initial NRC costs to update the regulations by incorporati ng by reference the ASME Code Cases cited here is more than offset by the reduction in t he number of plant-specific alternative requests that the NRC would otherwis e need to evaluate.

• The extension of the maximum interval for code of record updat es would result in significant averted costs to licensees and some averted costs t o the NRC. Section 5 of this analysis discusses the costs and benefits of Alternative 2 relative to the regulatory baseline (Alternative 1).

4. Estimation and Evaluation of Costs and Benefits

This section presents the staffs process for evaluating the ex pected costs and benefits of each proposed alternative relative to the regulatory baseline (Alter native 1). All costs and benefits are monetized, when possible. The total costs and benefits are then summed to determine whether they constitute a positive benefit. In some cases, costs and be nefits are not monetized because meaningful quantification is not possible.

4.1 Identification of Affected Attributes

This section identifies the components of the public and privat e sectors, commonly referred to as attributes, that the NRC staff expects Alternative 2 to affe ct. Alternative 2 would apply to licensees and applicants for nuclear power plants and nuclear p ower plant design certifications.

The NRC believes that nuclear power plant licensees would be th e primary beneficiaries. The

5 staff developed an inventory of the affected attributes using t he list in NUREG/BR-0058, draft Revision 5, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission, issued January 2020 (NRC, 2020).

The rule would affect the following attributes:

Public Health (Accident): This attribute accounts for expected changes in public radiation exposure caused by changes in accident frequencies or accident consequences resulting from Alternative 2 (with changes expressed as delta risk relative to Alternative 1). Compared to the regulatory baseline (Alternative 1), Alternative 2 better promo tes the NRCs goal of protecting public health and safety and the environment, because it ensure s NRC approval of new ASME Code Cases that allow the use of the latest methods and technol ogy, which may decrease the likelihood of an accident and, therefore, decrease the overall risk to public health.

• Occupational Health (Accident): This attribute measures immedi ate and long-term health effects for site workers due to changes in accident frequency o r accident consequences resulting from Alternative 2 (again expressed as delta risk). A decrease in worker radiological exposure is a decrease in risk (i.e., a benefit); an increase in worker exposure is an increase in risk (i.e., a cost). The use of new ASME Code Cases may incrementally decrease occupational health risks following an a ccident, but this effect is not easily quantifiable. For example, advances in ISI and IST m ay incrementally decrease accident frequency, decreasing worker postaccident rad iological exposure relative to the regulatory baseline.

• Occupational Health (Routine): This attribute accounts for rad iological exposure of workers during normal facility operations (i.e., nonaccident si tuations). The staff expects that licensees voluntary use of the NRC-approved code cases wo uld reduce occupational radiation exposure (for example, during routine in spections or testing) in a positive, but not easily quantifiable, manner.

• NRC Implementation: This attribute accounts for the projected net economic effect on the NRC of implementing the alternative, relative to the regula tory baseline. To implement Alternative 2, the NRC would incur the costs of devel oping the proposed and final rule and updating the corresponding guidance in RG 1.84, RG 1.147, and RG 1.192.

• Industry Operation: This attribute accounts for the projected net economic effect on all licensees of the routine and recurring activities required by A lternative 2. Under Alternative 2, nuclear power plant licensees would need to subm it fewer code case requests under 10 CFR 50.55a(z), which would constitute a net b enefit (i.e., averted cost) for the licensees.

• NRC Operation: This attribute accounts for the projected net e conomic effect on the NRC after the proposed action is taken. If the NRC has not appr oved an ASME Code

6 Case that a licensee or applicant wants to use, the licensee or applicant typically will request permission to use the code case through a submittal und er 10 CFR 50.55a(z).

The NRC staff will then have to spend additional time evaluatin g the submittal to determine whether the code case is acceptable and whether any l imitations or modifications should apply. Under Alternative 2, these code cas e alternative requests would be reduced, which results in a net benefit (i.e., averted cost) for the NRC.

• Improvements in Knowledge: This attribute accounts for increas es in knowledge due to advances in ISI and IST. Improvements in ISI and IST may also a llow earlier identification of material or equipment degradation that, if un detected, could lead to a plant transient or could compromise plant equipment needed to r espond to a plant transient.

• Regulatory Efficiency: This attribute accounts for regulatory and compliance improvements resulting from the implementation of Alternative 2. Alternative 2 would increase regulatory efficiency because licensees and applicants wishing to use NRC-approved ASME Code Cases would not need to submit 10 CFR 50.55a(z) alternative requests. Furthermore, Alternative 2 is consistent with the provisions of the NTTAA that encourage Federal agencies to adopt voluntary consen sus standards as an alternative to de novo agency development of standards affecting an industry.

Alternative 2 is consistent with the NRCs policy of evaluating whether the latest versions of consensus standards are suitable for endorsement by regulati on or RG. In addition, Alternative 2 is consistent with the NRCs goal of harmonizing with international standards to increase regulatory efficiency for both the NRC an d international standards groups.

• Attributes with No Effects: Attributes that are not expected t o contribute to the results under any of the alternatives include industry implementation; public health (routine);

offsite property; onsite property; other government, general pu blic, safeguards, and security considerations; and env ironmental considerations addre ssing section 102(2) of the National Environmental Policy Act of 1969.

4.2 Analytical Methodology

This section describes the process used to evaluate the costs a nd benefits of the proposed alternatives. The benefits include any desirable changes in aff ected attributes (e.g., monetary savings, increased safety, improved security). The costs includ e any undesirable changes in affected attributes (e.g., monetary costs, increased exposure).

Of the eight affected attributes, the staff analyzed three quan titatively: industry operation, NRC implementation, and NRC operation. Quantitative analysis requir es a baseline characterization of the affected attribute, including factors such as the number of affected entities, the nature of the activities currently performed, and the types of systems an d procedures that licensees or applicants would implement, or would no longer implement, under each proposed alternative.

7 Where possible, the staff calculated costs for these three attr ibutes using three-point estimates to quantify uncertainty. Detailed cost tables appear in the ind ividual sections for each of the attributes.

The staff evaluated the remaining five attributes qualitatively, either because the effects of consistent policy application and improvements in ISI and IST t echniques on these attributes are not easily quantifiable, or because the data necessary to q uantify and monetize these effects are not available.

The staff has documented its assumptions throughout this regula tory analysis. For the readers convenience, Appendix A summarizes the major assumptions and in put data used in the analysis.

4.2.1 Regulatory Baseline

This regulatory analysis identifies the incremental impacts of the proposed rule relative to a baseline that reflects anticipated behavior if the NRC does not undertake regulatory or nonregulatory action. The regulatory baseline assumes full comp liance with existing NRC requirements, including current regulations and relevant orders. This is consistent with NUREG/BR-0058 (NRC, 2020), which states that in evaluating a n ew requirementthe staff should assume that all existing NRC and Agreement State require ments have been implemented. Section 5 of this regulatory analysis presents th e estimated incremental costs and benefits of the alternatives compared to this baseline. Thi s regulatory baseline is the no-action alternative (i.e., Alternative 1).

4.2.2 Affected Entities

This proposed rule would affect all operating light-water nucle ar power plants. The analysis considers 54 plant sites containing one or more operating U.S. light-water nuclear power reactor units, for a total of 92 currently operating reactors (61 PWR a nd 31 BWR). The staff made the assumption that the state of California would work with Pacific Gas and Electric Company to pursue license renewal for Diablo Canyon 1 and 2 and keep them from permanently shutting down in 2024 and 2025. The staff made the assumption that all o perating reactors would apply for either an initial or subsequent license renewal based on re cent trends. In this way, the staff made a simplifying assumption that all currently operating reac tors would remain in operation long enough to benefit from one code of record update extension.

4.2.3 Base Year

All monetized costs are expressed in 2021 dollars. Unless state d otherwise, ongoing costs of operation under Alternative 2 are assumed to begin no earlier t han 30 days after publication of the final rule in the Code of Federal Regulations, which is expected to be in 2024, and they are modeled on an annual cost basis. Estimates of one-time NRC impl ementation costs are based

8 on staff experience with similar rulemakings. The NRC assumes t hat these costs would be incurred in the years 2023 and 2024.

Estimates of recurring annual operating expenses are based on s taff experience and stakeholders statements about costs. The values for annual ope rating expenses are modeled as a constant expense for each year of the analysis horizon. Th e staff performed a discounted cash flow calculation to discount these annual expenses to 2021 dollar values.

4.2.4 Discount Rates

The staff used net present value (NPV) calculations to determin e how much society would need to invest today to ensure that the designated dollar amount is available in a given year in the future. By using NPVs, the staff can translate costs and benefi ts to a reference year for comparison, regardless of when they are incurred. Based on OMB Circular A-4 Regulatory Analysis, dated October 9, 2003 (OMB, 2003) and consistent wit h the NRCs past practice and guidance, present-worth calculations in this analysis use 3-per cent and 7-percent real discount rates. A 3-percent discount rate approximates the real rate of return on long-term Government debt, which serves as a proxy for the real rate of return on sa vings; this reflects the concept of discounting based on the social rate of time preference. 1 A 7-percent discount rate approximates the marginal pretax real rate of return on an aver age investment in the private sector; it is the appropriate discount rate whenever the main e ffect of a regulation is to displace or alter the use of capital in the private sector. A 7-percent rate is consistent with the concept of the opportunity cost2 of capital; it reflects the time value of resources directed t o meet regulatory requirements.

4.2.5 Labor Rates

For the purposes of this regulatory analysis, the staff applied strict incremental cost principles to develop labor rates that include only labor and material costs directly related to the implementation, operation, and maintenance of the proposed rule requirements. This approach is consistent with the guidance in NUREG/CR-3568, A Handbook f or Value-Impact Assessment, issued December 1983 (NRC, 1983), and with general cost-benefit methodology.

The NRCs incremental labor rate is $143 per hour. 3

1 The social rate of time preference refers to the rate at which society is willing to postpone a marginal unit of current consumption in exchange for more future consumption.

2 Opportunity cost is what is forgone by undertaking a given action. If licensee personnel were not revising procedures, they would be performing other work activities. Throughout this analysis, the NRC estimates the opportunity cost of performing these incremental tasks as the industry personnels pay for the designated amount of time.

3 The NRC labor rates presented here differ from those developed under the NRCs license fee recovery program (10 CFR Part 170, Fees for Facilities, Materials, Import and Export Licenses, and Other Regulatory Services under the Atomic Energy Act of 1954, as Amended). NRC labor rates for fee recovery

9 The staff used the 2021 Bureau of Labor Statistics (BLS) Occupa tional Employment and Wages data (www.bls.gov), which provide labor categories and the mean hourly wage rate by job type.

The labor rates used in the analysis reflect total hourly compe nsation, which includes wages and nonwage benefits (using a burden factor of 2.4, which is ap plicable for contract labor and conservative for regular utility employees). The staff used the BLS data tables to select appropriate hourly labor rates for the estimated procedural, li censing, and utility-related work necessary during and after implementation of the proposed alter native. These labor rates include wages paid to the individuals performing the work plus the associated fringe benefit component of labor costs (i.e., the time for plant management e xceeding those directly expensed), which are considered incremental expenses. Table su mmarizes the BLS labor categories the staff used to estimate industry labor costs to i mplement this proposed rule, and Appendix A lists the industry labor rates used in the analysis. The staff also performed an uncertainty analysis, which is discussed in Section 5.13.

Table 1 Position Titles and Occupations

Position Title (In This Standard Occupational Classification Regulatory Analysis)

Executive Top Executives (111000)

Managers Management Occupations (110000)

Supervisors of Protective Service Workers (331000)

General and Operations Managers (111021)

First-Line Supervisors of Mechanics, Installers, and Repairers (491011)

First-Line Supervisors of Production and Operating Workers (511011)

Technical Staff Nuclear Engineers (172161)

Nuclear Technicians (194051)

Electrical and Electronic Equipment Mechanics, Installers, and Repairers (492000)

Nuclear Power Reactor Operators (518011)

Administrative Staff Office Clerks, General (439061)

Licensing Staff Lawyers (231011)

Paralegals and Legal Assistants (232011)

Security Staff Security Guards (339032)

Source: BLS, May 2021 National Industry Specific Occupational Employment and Wage Estimates; NAICS 221113Nuclear Electric P ower Generation (BLS, 2021).

4.2.6 Sign Conventions

The sign conventions used in this analysis are that all favorab le consequences of Alternative 2 are positive and all adverse consequences are negative. Negativ e values are shown using parentheses (e.g., negative $500 is displayed as ($500)).

purposes are designed for full-cost recovery of the services rendered and thus include nonincremental costs (e.g., overhead, administrative, and logistical support costs).

10 4.2.7 Analysis Horizon

The staff analyzed ASME Code Cases that are (1) acceptable with out conditions or (2) acceptable with conditions. The ASME Code Cases are in effe ct for a span of 3 years and are renewable once for 3 additional years, for a total of 6 yea rs. However, because the ISI, IST, and code of record updates involve longer intervals, this regul atory analysis uses a 24-year analysis horizon. This 24-year horizon spans one delayed code o f record update for all licensees.

4.2.8 Cost Estimation

To estimate the costs of each alternative evaluated, the staff used a work breakdown approach to deconstruct each requirement into its mandated activities. F or each mandated activity, the staff further subdivided the work across labor categories (i.e., executives, managers, technical staff, administrative staff, and licensing staff). The staff es timated the level of effort (LOE) needed for each required activity and used a blended labor rate to develop bottom-up cost estimates.

The staff gathered data from several sources and consulted ASME Code working group members to develop LOE and unit cost estimates. The staff appli ed several cost estimation methods and used its collective professional knowledge and judg ment to estimate many of the costs and benefits. It also used a buildup method and extrapola tion techniques to estimate costs and benefits.

The staff began by using the engineering buildup method of cost estimation, which combines the incremental costs of an activity from the bottom up to esti mate a total cost. For this step, the staff reviewed previous license submittals, determined the numb er of pages in each section, and used these data to develop preliminary LOEs.

The staff consulted subject matter experts within and outside t he agency to develop most of the LOE estimates used in the analysis. For example, to estimate li censee costs and averted costs (benefits) related to the NRC conditions on the code cases in the proposed rule, the staff consulted licensees about the a ssociated LOE. NRC staff members themselves contributed to LOE estimates for review-related activities.

The staff extrapolated some costs, relying on actual past or cu rrent costs to estimate the future costs of similar activities. For example, to calculate the esti mated averted costs of code case alternative requests and the costs of preparing the proposed ru le and accompanying regulatory guidance, the staff used data from past projects to determine t he labor categories of the personnel who would perform the work and to estimate the amount of time required under each category. If data were not available, the staff estimated the L OE based on similar steps in the process for which data were available.

11 To evaluate the effect of uncertainty in the model, the staff e mployed Monte Carlo simulation, which is an approach to uncertainty analysis in which input var iables are expressed as distributions. The simulation was run 10,000 times, and values were chosen at random from the distributions of the input variables provided in Table 15. The result was a distribution of values for the output variable of interest. Monte Carlo simulation als o enables users to determine which input variables most strongly affect the value of the output va riable. Section 5.13 describes the Monte Carlo simulation methods in detail and presents the resul ts.

4.2.9 ASME Code Cases Incorporated by Reference

When the NRC incorporates code cases by reference, licensees do not need to submit alternative requests to use these code cases as incorporated. T his results in cost savings to the industry and the NRC. Table 1 in each of DG-1405, DG-1406, and DG-1407 lists the ASME Code Cases, both new and revised, that the proposed rule would incorporate by reference.

When the NRC incorporates by reference code cases with conditio ns, licensees may incur additional regulatory costs to meet the conditions. For each ap plicable code case, the conditions specify the additional activities that must be performed, the l imits on the activities identified in the code case, and the supplemental information needed to provi de clarity. Table 2 in each of DG-1405, DG-1406, and DG-1407 lists the ASME Code Cases, both n ew and revised, that the proposed rule would incorporate by reference with conditions. T he proposed rule and the DGs discuss the NRCs evaluation of the code cases and the reasons for the agencys conditions.

The conditions on the code cases may cause additional licensee resource costs, affecting the attribute of industry operation. However, the fact that license es could use the conditioned code cases without submitting alternative requests represents cost s avings to both the industry and the NRC. Table 2 lists the conditions on the code cases conside red in this proposed rule and the incremental resource required associated with each.

The NRC will include approved code cases in the next update of the RGs, whether or not licensees are likely to use the code cases. The incorporation b y reference of code cases gives the industry the flexibility to use certain code case methodolo gies without NRC approval or alternative requests. The costs and benefits of any code case t he staff does not expect the industry to use are estimated as negligible.

Table 2 Conditioned Code Cases under Consideration

DG Conditioned Listing Code Case Description of Condition(s) Incremental Resources Required Number DG-1405 N-71-21 1. The maximum measured ultimate tensile 1. This condition is identical strength (UTS) of the component support to a condition in the material must not exceed 170 ksi because of the previous version of the code susceptibility of high strength materials to case; no incremental brittleness and stress corrosion cracking. resources.

2. In the last sentence of Paragraph 5.2 of Code 2. This condition is identical Case N-71-21, the evidence presented to and to a condition in the accepted by the Authorized Inspector concerning previous version of the code

12 DG Conditioned Listing Code Case Description of Condition(s) Incremental Resources Required Number exposure of electrodes for a longer period of time case; no incremental must be consistent with Paragraph 5.3.2.3, resources.

Alternative Atmosphere Exposure Time Periods 3. This condition is identical Established by Test, of the AWS D1.1 Code. to a condition in the

3. Paragraph 16.2.2 of Code Case N-71-21 is previous version of the code replaced with the following: When not exempted case; no incremental by 16.2.1 above, the post weld heat treatment resources.

must be performed in accordance with NF 4622 4. This condition is identical except that ASTM A-710 Grade A Material must to a condition in the be at least 1000°F (540°C) and must not exceed previous version of the code 1150°F (620°C) for Class 1 and 2 material and case; no incremental 1175°F (640°C) for Class 3 material. resources.

4. The new holding time at temperature for weld 5. This condition is identical thickness (nominal) must be 30 minutes for welds to a condition in the 0.5 inch or less; 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per inch of thickness for previous version of the code welds over 0.5 inch to 5 inches; and for case; no incremental thicknesses over 5 inches, 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> plus 15 resources.

minutes for each additional inch over 5 inches. 6. This condition is identical

5. The fracture toughness requirements as listed to a condition in the in this Code Case apply only to piping supports previous version of the code and not to Class 1, 2 and 3 component supports. case; no incremental

6. When welding P-number materials listed in the resources.

Code Case, the corresponding S-number welding requirements apply.

DG-1405 N-570-3 1. Design for strength using the Load and 1. This condition is based Resistance Factor Design method of on good engineering ANSI/AISC N-690-2018 shall not be used. practice, and other equivalent methods of design are available.

Therefore, this condition does not result in incremental costs.

DG-1406 N-711-2 1. Code Case N-711-2 shall not be used to 1. This condition is identical redefine the required examination volume for to a condition in the preservice examinations or when the postulated previous version of the code degradation mechanism for piping welds is case; no incremental primary water stress-corrosion cracking or resources.

crevice corrosion degradation mechanisms.

DG-1406 N-716-3 1. Plants issued a combined license after 1. This condition affects two January 1, 2012, shall submit the results of the operating plants at one site application of this Code Case as an alternative in (Vogtle) and will result in an accordance with 50.55a(z) for review and alternative request, based approval prior to implementation. on the staffs conservative assumption that the licensee will seek to use N-716-3. This code case concerns a risk-informed program for piping and components. The staff position is that operating experience is critical in the development of this program; hence, this condition is based on licensing date.

13 DG Conditioned Listing Code Case Description of Condition(s) Incremental Resources Required Number DG-1406 N-754-2 1. The use of this Code Case on a pipe that 1. This condition is identical implements NRC-approved leak-before-break to a condition in the methodology requires the leak-before-break previous version of the code analysis to be updated to verify the required case; no incremental safety margins specified in the original leak-resources.

before-break analysis are satisfied. 2. This condition is identical

2. The preservice and inservice examinations of to a condition in the the overlaid pipe using this Code Case must be previous version of the code examined in accordance with 10 CFR case; no incremental 50.55a(g)(6)(ii)(F). resources.

DG-1406 N-766-4 1. Credit cannot be taken to reduce preservice 1. This condition is identical and ISI requirements specified by this Code Case to a condition in the on an inlay or onlay if an inlay or onlay is applied previous version of the code to an Alloy 82/182 dissimilar metal weld that case; no incremental contains an axial indication that has a depth of resources.

more than 25 percent of the pipe wall thickness 2. This condition is identical and a length of more than one half of the axial to a condition in the width of the dissimilar metal weld or a previous version of the code circumferential indication that has a depth of case; no incremental more than 25 percent of the pipe wall thickness resources.

and a length of more than 20 percent of the 3. This condition is identical circumference of the pipe. to a condition in the

2. In lieu of Paragraph 2(e) of the Code Case, previous version of the code pipes with any thickness of inlay or onlay must be case; no incremental evaluated for weld shrinkage, pipe system resources.

flexibility, and additional weight of the inlay or 4. This condition is identical onlay. to a condition in the

3. If an inlay or onlay is applied to an Alloy previous version of the code 82/182 dissimilar metal weld that contains an case; no incremental indication that exceeds the acceptance standards resources.

of Section XI, IWB 3514, and that is accepted for 5. This condition is identical continued service in accordance with Section XI, to a condition in the IWB-3132.3 or IWB-3142.4, the subject weld previous version of the code must be inspected in three successive case; no incremental examinations after inlay or onlay installation. resources.

4. Any detectable subsurface indication discovered by eddy current testing in the inlay or onlay during acceptance examinations is prohibited to remain in service.

5. The flaw analysis of Paragraph 2(d) of the Code Case must also consider primary water stress corrosion cracking growth in the circumferential and axial directions in accordance with Section XI, IWB 3640.

DG-1406 N-847-1 1. Use of Code Case N-847-1 is limited to 1. This condition is identical installation of full 360-degree excavation and to a condition in the weld repairs (EWR). previous version of the code

2. When implementing Figure 1A, Cross Section case; no incremental of Typical Dissimilar Metal EWR, and Figure 1B, resources.

Cross Section of Typical Similar Metal EWR, of 2. This condition is identical the Code Case for the design of an EWR, to a condition in the intersection points at the interface between EWR previous version of the code metal and existing base metal must be rounded case; no incremental to mitigate weldability issues. resources.

3. The evaluation in section 2(d)(1) of the Code 3. This condition is identical Case must include evaluation of crack growth to a condition in the into the Alloy 690 weld material, including the previous version of the code dilution zones and allowing change in flaw growth case; no incremental direction. resources.

14 DG Conditioned Listing Code Case Description of Condition(s) Incremental Resources Required Number

4. Residual stress values in section 2 of the Code 4. This condition is identical Case must be developed and validated to a condition in the consistent with NUREG-2228, Weld Residual previous version of the code Stress Finite Element Analysis Validation: Part case; no incremental IIProposed Validation Procedure issued resources.

July 2020. 5. This condition is identical

5. With respect to Table 1, including notes (1), to a condition in the (3), and (4): previous version of the code

a. The first inservice inspection examinations case; no incremental for Inspection Item EWR-2A EWRs must resources.

be performed during the second refueling 6. This condition is identical outage. For normal water chemistry plants, to a condition in the 100 percent of all EWRs must be previous version of the code inspected every 10 years. For hydrogen case; no incremental water chemistry/noble metal chemical resources.

addition plants, 25 percent of the EWRs must be inspected every 10 years.

b. The first inservice inspection examinations for Inspection Item EWR-1B EWRs must be performed during the second refueling outage. Regardless of water chemistry mitigative actions, 100 percent of the EWRs must be inspected every 10 years.

c. The first inservice inspection examinations for Inspection Item EWR-2B EWRs must be performed during the second refueling outage.

6. For the purposes of Table 1, Note (1),

licensees must not use an alternative other than those specified in Note (1).

DG-1406 N-880-1 1. Use of this Code Case is limited to NPS 2 1. This condition was (DN 50) or smaller fittings. previously a part of the code

2. For ASME Section III items, this condition case itself; therefore, no applies only for the licensees that implemented incremental costs are ASME Code,Section III design requirements for estimated.

their original construction code and/or the 2. This condition is identical licensees that have upgraded their original to a condition in the design requirements to ASME Code,Section III. previous version of the code The Licensee must verify the design and testing case; no incremental activities associated with qualification of welded resources.

fittings performed by the fabricator as follows: 3. This condition is identical

a. Review the fabricators design to a condition in the documentation and methods to ensure the previous version of the code fittings design is in compliance with the case; no incremental Licensees design specifications, and resources.

ASME Section III NB/NC/ND-3671.7 requirements; and either

i. Supervise and monitor the performance qualification tests of the fittings to ensure the design is in compliance with the Licensees design specifications and ASME Section III NB/NC/ND-3671.7; or ii. The Licensee or Repair/Replacement Organization conducts qualification tests of the fittings or conducts design analyses to ensure the design is in compliance with the Licensees design

15 DG Conditioned Listing Code Case Description of Condition(s) Incremental Resources Required Number specifications and ASME Section III NB/NC/ND-3671.7.

3. The Licensee must give the Authorized Nuclear Inservice Inspector an opportunity to review the design report prior to installation.

DG-1406 N-899 1. If -2330, Standardized Distributions, are used, These new conditions only -2331 inside surface repair weld, with safe effectively require licensees end and -2332 inside surface repair weld, no safe to use the conservative end are approved for use, as appropriate. assumption that a repair

2. If a documented repair is found, it must be weld was previously made, demonstrated to be bounded by -2331 inside to overcome potential surface repair weld, with safe end or - 2332 documentation issues and inside surface repair weld, no safe end, as uncertainty. However, this appropriate, in order to use those weld residual conservative approach is stress profiles. standard engineering

3. No other weld residual stress profiles of this practice and is the status section can be used, as stated in the code case, quo for these welds, with without NRC approval. longstanding precedent.

4. When applying -3000, Calculation Of Residual Therefore, no incremental Stress Using Finite Element Analysis, an inside cost is estimated as a result surface repair of 50 percent through-wall or as of these conditions.

found through record search, whichever is bounding, is required to be used in the finite element analysis calculation of the weld residual stress profile.

DG-1406 N-906 1. In Paragraph 1(b), if a thermal transient below 1. This condition clarifies the a temperature range of 500 °F to 625 °F (260 °C requirement within the Code to 330 °C) occurs at the flaw location, the flaw Case itself using sound evaluation must use the fracture toughness (Ji) engineering principles, and and applied stresses that are limiting for the flaw. therefore results in no incremental costs to licensees.

DG-1406 N-921 1. The licensees code of record for the inservice 1. This condition ensures inspection program must be the 2019 Edition of that licensees attempting to Section XI or later, in order to apply this code use this code case to case. lengthen their ISI interval from 10 to 12 years have updated their ASME BPV Code,Section XI beforehand. Licensees seeking to use the 12-year interval may incur incremental costs for alternative requests resulting from this condition.

DG-1407 OMN-31 1. Contrary to the ASME OM Code Case 1. This condition ensures Applicability Index, this OM Code Case may be that licensees attempting to applied by licensees implementing the ASME OM use this code case to Code, 2020 Edition through the latest edition of lengthen their IST interval the ASME OM Code incorporated by reference in from 10 to 12 years have 10 CFR 50.55a. updated their ASME OMN Code beforehand.

Licensees seeking to use the 12-year interval may incur incremental costs for alternative requests resulting from this condition.

16 4.3 Data

The staff used data from subject matter experts, knowledge gain ed from past rulemakings, and the NRC budget for this rulemaking to estimate the costs and be nefits associated with this proposed rule. Staff members provided quantitative and qualitat ive information on attributes affected by the proposed rule. The staff considered the potenti al differences between the proposed and existing requirements and incorporated these incre mental changes into the regulatory analysis.

5 Results

This section presents the quantitative and qualitative results by attribute, relative to the regulatory baseline. As described in the previous sections, cos ts and benefits are quantified where possible and can have either a positiv e or negative sign, depending on w hether Alternative 2 has a favorable or adverse effect compared to the regulatory baseline (Alternative 1). The section also discusses those attributes that are not easily represented in terms of monetary value. Although this ex ante cost-benefit ana lysis4 provides information that can be used when deciding whether to select the rulemaking alte rnative, the analysis is based on estimates of future costs and benefits. Whether or not the e stimates hold in the future, the process of conducting regulatory analyses has value in itself, because it helps decision-makers think in depth about specific alternatives and their results.

The NRCs regulatory analysis guidelines (NRC, 2020) state that the NRCs periodic review and endorsement of consensus standards, such as new versions of the ASME Codes and associated Code Cases, is a special case, because consensus sta ndards have already undergone extensive external r eview and have been endorsed by the industry. In addition, endorsement of the ASME Codes and Code Cases has been a longsta nding NRC policy.

Licensees and applicants participate in the development of the ASME Codes and Code Cases and are aware that periodic updating of the ASME Codes is part of the regulatory process. Code cases are ASME-developed alternatives to the ASME BPV and OM Co des that licensees and applicants may voluntarily choose to adopt without making an al ternative request if the code cases are approved through incorporation by reference in the NR Cs regulations. Finally, endorsement of the ASME Codes and Code Cases is consistent with the NTTAA, inasmuch as the NRC has determined that sound regulatory reasons exist for establishing regulatory requirements for design, maintenance, ISI, and IST and examinat ion by rulemaking.

In a typical incorporation of code cases, the NRC endorsements can involve hundreds, if not thousands, of individual provisions. This regulatory analysis d oes not separately evaluate each individual provision, because such an exercise would be prohibi tively time-consuming and of limited value.

4 An ex ante cost-benefit analysis is prepared before a policy, program, or alternative is in place and can assist in the decision about whether to allocate resources to that alternative.

17 Table 2 lists all of the ASME Code Cases that this proposed rul e would incorporate by reference with conditions, that (1) are new or newly NRC-approved code ca ses, (2) are new revisions of existing code cases, or (3) have revised or new conditions. The table also notes whether each condition will give rise to incremental costs.

The following code cases have conditions that are identical to existing conditions of code cases already incorporated by reference by the NRC (and therefore res ult in no incremental costs or benefits):

• N-71-21, Additional Materials for Subsection NF, Class 1, 2, 3, and MC Supports Fabricated by Welding,Section III, Division 1

• N-711-2, Alternative Examination Coverage Requirements for Ex amination Category B F, B J, C-F-1, C-F-2, and R-A Piping Welds,Section XI, Divisio n 1

• N-754-2, Optimized Structural Dissimilar Metal Weld Overlay f or Mitigation of PWR Class 1 Items,Section XI, Division 1

• N-766-4, Nickel Alloy Reactor Coolant Inlay and Onlay for Mit igation of PWR Full Penetration Circumferential Nickel Alloy Dissimilar Metal Welds in Class 1 Items,Section XI, Division 1

• N-847-1, Partial Excavation and Deposition of Weld Metal for Mitigation of Class 1 Items,Section XI, Division 1

Several code cases have new proposed conditions that are not ex pected to result in incremental costs or benefits. The proposed condition on N-570-3, Alternat ive Rules for Linear Piping and Linear Standard Supports for Classes 1, 2, 3, and MC,Section I II, Division 1, states, Design for strength using the Load and Resistance Factor Design method of ANSI/AISC N-690-2018 shall not be used. This condition is based on good engineering practice, and other equivalent methods of design are available. Therefore, the staff does not expect this condition to result in incremental costs or benefits. Two of the proposed conditions o n N-880-1, Alternative to Procurement Requirements of IWA-4143 for Nonstandard Welded Fit tings,Section XI, Division 1, are identical to existing conditions, and the prop osed condition 1, Use of this Code Case is limited to NPS 2 (DN 50) or smaller fittings, was in r evision 0 of the code case itself.

Therefore, the staff does not expect these conditions to result in incremental costs or benefits.

The staff is proposing four conditions on N-899, Weld Residual Stress Distributions for Piping and Vessel Nozzle Butt Welds Fabricated with UNS N06082, UNS W8 6182, UNS N06052, or UNS W86152 Weld Filler Material,Section XI, Division 1. Table 2 lists these conditions in full.

Effectively, the conditions require a conservative assumption t hat the welds in question have previously undergone repair, because of concerns about historic al documentation. There is a longstanding precedent for these conditions, which are based on good engineering practice; this approach was the status quo before the establishment of Code Ca se N-899. Therefore, the staff does not expect these conditions to result in incremental costs or benefits.

18 The proposed condition on N-906, Flaw Evaluation Procedure for Cast Austenitic Stainless Steel Piping and Adjacent Fittings,Section XI, Division 1, st ates, In paragraph 1(b), if a thermal transient below a temperature range of 500 °F to 625 °F (260 °C to 330 °C) occurs at the flaw location, the flaw evaluation must use the fracture to ughness (Ji) and applied stresses that are limiting for the flaw. This condition ensures that li censees will use limiting criteria that account for the flaw; it removes the language about the minimum transient temperature because that may not be the limiting temperature under certain conditio ns. The condition establishes good engineering principles tha t a licensee would have been expected to use in any case, and it is not expected to significantly affect the calculations used f or the evaluation. Therefore, the staff does not expect the condition to result in incremental co sts or benefits.

The proposed condition on N-716-3, Alternative Classification and Examination Requirements,Section XI, Division 1, states, Plants issued a combined lice nse after January 1, 2012, shall submit the results of the application of this code case as an a lternative in accordance with 10 CFR 50.55a(z) for review and approval before implementation. This code case concerns a risk-informed program for piping and components, and the NRC staffs position is that operating experience is critical in developing this program. Therefore, t he proposed condition requires newer plants to submit an alternative request to use the code c ase. This would result in incremental costs for such plants. Finally, the proposed condit ions on N-921 and OMN-31 seek to ensure that licensees adopting a 12-year ISI or IST interval will have updated their ASME Editions and Codes of Record to 2019 or 2020. Because a longer ISI and IST interval benefits licensees, the staff expects some licensees (who have recently updated their ASME Editions and Codes of Record) to submit alternative requests because of these conditions, leading to incremental costs for those licensees.

The regulatory changes increasing the code of record interval w ill result in averted costs for licensees, by letting them perform these activities less freque ntly. The costs of code of record updates will be postponed by 10 y ears on average per licensee f or the next update, and then 4 more years on average per licensee (using a 24-year interval) f or the subsequent update that would have otherwise been necessary. These postponements will l ead to averted costs due to the value of money over time.

5.1 Public Health (Accident)

The industry practice of adopting ASME BPV and OM Code Cases as incorporated by reference into the regulations may incre mentally reduce the likelihood of a radiological accident in a positive, but not easily quantifiable, manner. Pursuing Alterna tive 2 would continue to support the NRCs goal of maintaining safety by approving new ASME Code Cases, to allow licensees to gain experience with new technology before its incorporation into the ASME Codes.

Alternative 2 would also enable the NRC to permit licensees to use advances in ISI and IST, provide alternative examinations for older plants, respond prom ptly to user needs, and offer limited and clearly focused alter natives to specific ASME Code provisions. Improvements in ISI and IST may result in the earlier identification of material de gradation that, if undetected, could

19 eventually lead to a plant transient. For these reasons, Altern ative 2 maintains the same level of safety, or may incrementally inc rease safety, relative to the regulatory baseline.

5.2 Occupational Health (Accident and Routine)

By reviewing ASME BPV and OM Code Cases, determining their acce ptability, and specifying its findings in RGs that are incorporated by reference into the regulations, the NRC ensures that the mandated ASME Code requirements and approved Code alternati ves result in an acceptable level of quality and safety. Pursuing Alternative 2 (the rule alternative) would continue to support the NRCs goal of maintaining safety, permi tting licensees to use ISI and IST advancements, providing alte rnative examinations, responding to user needs, and offering alternatives to ASME Code provisions. The staff expects that li censees and applicants voluntary use of NRC-approved code cases would reduce occupatio nal radiation exposure in a positive, but not easily quantifiable, manner. For example, the staff expects that the use of the approved code cases would increm entally decrease the likelihood of an accident and would reduce worker radiological exposures during routine inspections or testing, relative to the regulatory baseline.

5.3 Industry Implementation

This attribute accounts for the projected net economic effect o n licensees of implementing the proposed regulatory changes (conditions on the ASME Code Cases). Additional costs greater than the regulatory baseline are negative, and cost savings and averted costs are positive. The staff does not estimate any incremental implementation costs fo r the industry as a result of the proposed rule.

5.4 Industry Operation

This attribute accounts for the projected net economic effect o f routine and recurring activities required by the proposed alternative for all affected licensees. Under Alternative 2, a nuclear power plant licensee would be able to use more recent ASME Code Cases without submitting a request for an alternative under 10 CFR 50.55a(z) or a relief r equest under 10 CFR 50.55a(f) or 10 CFR 50.55a(g). This would provide a net benefit (i.e., an av erted cost) for licensees.

The use of more recent ASME BPV and OM Code Cases may benefit n uclear power plant licensees and applicants in several ways. Later editions and ad denda may introduce advanced techniques, procedures, and measures. Upon the implementation o f Alternative 2, licensees and applicants would be able to voluntarily ask to use a more r ecent edition or addenda of the ASME BPV and OM Codes under the provisions in 10 CFR 50.55a(f)( 4)(iv) and 10 CFR 50.55a(g)(4)(iv).5

5 Regulations in 10 CFR 50.55a(f)(4) and 10 CFR 50.55a(g)(4) establish the effective ASME Code editions and addenda to be used by licensees for IST of pumps and valves and ISI of components (including supports), respectively. NRC Regulatory Issue Summary 2004-12, Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI, dated July 28, 2004 (NRC, 2004), clarifies the requirements for IST and ISI programs when using later editions and addenda of the ASME OM Code.

20 Submission of a code case relief or alternative request to the NRC is not a trivial matter. When ASME issues a new Code Case, the licensee or applicant must det ermine whether its use would be beneficial. If the use of the code case would be benef icial, but the NRC has not approved it, the licensee or applicant must prepare a request t o use the code case, and its management must review and approve the request before submissio n to the NRC. A review of code case requests submitted to the NRC over a recent 5-year pe riod found that these submittals ranged from a few pages to several hundred pages, wi th an average of approximately 32 pages of moderate technical complexity.

Therefore, the staff estimates that a code case request submitt al under 10 CFR 50.55a(z) requires an average of 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> of licensee or applicant effor t to develop the technical justification and an additional 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> for research, review, approval, processing, and submission to the NRC (making 230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br /> per submittal). The act ual time needed may be lower or higher than 230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br />, depending on the complexity of the su bmittal. The NRC assumes that licensees and applicants would decide whether to request the us e of an alternative by weighing the costs against the benefits. In some cases, they may decide to forfeit the benefits of using the newer ASME Code Cases, whether these benefits pertain to ra diological considerations or cost reduction.

A review of past submittals has determined that plant owners su bmit code case alternative requests that cover multiple units and multiple plant sites. Ba sed on annual code case alternative request submissions before and after ASME final rul es are published, the staff estimates that if Alternative 2 is not adopted, licensees of op erating sites would submit 27 alternative requests per year for the code cases in this pro posed rule. Alternative 2 would provide a net benefit (i.e., averted cost) for licensees by mak ing it unnecessary for them to prepare and submit these requests. As shown in Table 3, the NRC estimates the industry operation averted costs under Alternative 2 range from $3.10 mi llion (7-percent NPV) to

$3.94 million (3-percent NPV).

Table 3 Averted Industry Alternative Requests

Alternativ e Cost Year Activ ity Requests Labor Hours Weighted Hourly Rate Prepared Undiscounted 7% NP V 3% NP V

2025 Co de Case alternative request preparatio n and submissio n 27 230 $128 $795,513 $606,893 $706,803

2026 Co de Case alternative request preparatio n and submissio n 27 230 $128 $795,513 $567,189 $686,216

2027 Co de Case alternative request preparatio n and submissio n 27 230 $128 $795,513 $530,084 $666,229

2028 Co de Case alternative request preparatio n and submissio n 27 230 $128 $795,513 $495,405 $646,825

2029 Co de Case alternative request preparatio n and submissio n 27 230 $128 $795,513 $462,996 $627,985

2030 Co de Case alternative request preparatio n and submissio n 27 230 $128 $795,513 $432,706 $609,694 Total: $4,773,075 $3,095,273 $3,943,752

21 The proposed condition on N-716-3 would require the submittal o f an alternative request to use the code case, as previously discussed, for plants licensed aft er the date in the condition. As proposed, this condition would apply only to two units at one s ite (Vogtle Electric Generating Plant). Therefore, the staff conservatively assumed that one li censee would submit an alternative request in 2024 as a result of the condition, with the corresponding costs estimated as shown in Table 4. Additionally, the staff expects the propos ed conditions on N-921 and OMN-31 would result in alternative requests from some licensees that have not updated to the 2019 Edition of Section XI of the ASME BPV Code or the 2020 Edi tion of the ASME OMN Code, as required in the conditions. Finally, the proposed regulatory language on extending the maximum code of record interval would result in alternative req uests from some licensees that have not updated to the 2019/2020 Editions of the ASME Codes as required in the regulatory changes.

The staff assumed that PWR licens ees would seek (by submitting alternative requests) to use the 12-year ISI and IST intervals due to their 18-month shutdow n intervals, which divides more easily into 12 years than 10, but did not assume BWR licensees would submit alternative requests, in estimating these requests. The staff has estimated the number of licensees based on a uniform distribution of PWR licensees across the current 1 0-year update interval, assuming that PWR licensees with 8 years or more until the next schedule d update (that is, 20 percent of PWR licensees) would submit alternative requests. This assumpti on was based on staff judgment that licensees might not find it cost effective to see k to perform another update to the 2019/2020 ASME Code Editions if the previous update was more re cent than that. Therefore, the staff estimates that approximately 12 PWR licensees would s ubmit alternative requests in 2024 as a result of this condition and these regulatory changes. For code of record update intervals, all licensees could benefit, therefore the staff ass umed 18 licensees (20 percent of all licensees) would submit alternative requests to extend their co de of record intervals. These costs are shown in Table 4.

Table 4 Licensee Alternative Requests

Number of Cost Year ActivityAffected Labor Hours Weighted Hourly rate Entities Undiscounted 7% NPV 3% NPV 2024 Alternative request for N-716-3 1 230 $128 ($29,463) ($24,051) ($ 26,963) 2024 Alternative requests for N-921 12 230 $128 ($359, 454) ($293,421) ($328,951) 2024 Alternative requests for OMN-31 12 230 $128 ($359,454) ($293,421) ($328,951)

2024 Alternative requests for Code of Record int erval 18 230 $128 ($539,181) ($440,132) ($493,427)

Total: ($1,287,552) ($1,051, 026) ($1,178, 292)

The change to the maximum code of record interval averts costs for all licensees over time, and the staff estimates that a code of record update costs approxim ately $500,000. The proposed rule would delay the next update by 14 years for PWRs (seeking a 24-year interval), and the subsequent expected update by 4 years. For BWRs, the staff assu med they would seek 20-year intervals to coincide with two ISI/IST intervals of 10 years. T herefore, for BWRs the proposed rule would delay the next update by 10 years, with no subsequen t delays within the analysis horizon. As discussed previously, for the purposes of this anal ysis the staff assumed an

22 analysis horizon of 24 years, which spans at least one delayed code of record update for all licensees. Table 5 shows the averted costs from changing the ma ximum code of record interval, for PWRs and BWRs as described above. Again, for all estimates, the staff assumed a uniform distribution of 10 percent of all licensees per year performing the update (as the status quo),

basing the estimates on the number of operating reactors and th e current 10-year interval.

Table 5 Averted Costs Due to Extended Code of Record Interval

Number of Averted Cost Cost Year ActivityAffected per Delayed Entities Updat e Undiscounted 7% NPV 3% NPV 2024 Averted Codes of Record Updates 9 541,667$ $4,983,333 $4,067,884 $4,560,456 2025 Averted Codes of Record Updates 9 541,667$ $4,983,333 $3,801,761 $4,427,627 2026 Averted Codes of Record Updates 9 541,667$ $4,983,333 $3,553,048 $4,298,667 2027 Averted Codes of Record Updates 9 541,667$ $4,983,333 $3,320,605 $4,173,463 2028 Averted Codes of Record Updates 9 541,667$ $4,983,333 $3,103,370 $4,051,906 2029 Averted Codes of Record Updates 9 541,667$ $4,983,333 $2,900,345 $3,933,889 2030 Averted Codes of Record Updates 9 541,667$ $4,983,333 $2,710,603 $3,819,310 2031 Averted Codes of Record Updates 9 541,667$ $4,983,333 $2,533,274 $3,708,068 2032 Averted Codes of Record Updates 9 541,667$ $4,983,333 $2,367,546 $3,600,066 2033 Averted Codes of Record Updates 9 541,667$ $4,983,333 $2,212,660 $3,495,210 2034 Averted Codes of Record Updates (PWRs) 6 541,667$ $3,322,222 $1,378,604 $2,262,272 2035 Averted Codes of Record Updates (PWRs) 6 541,667$ $3,322,222 $1,288,415 $2,196,380 2036 Averted Codes of Record Updates (PWRs) 6 541,667$ $3,322,222 $1,204,126 $2,132,408 2037 Averted Codes of Record Updates (PWRs) 6 541,667$ $3,322,222 $1,125,352 $2,070,299 2038 Averted Codes of Record Updates (PWRs) 6 541,667$ $3,322,222 $1,051,730 $2,009,999 2039 Averted Codes of Record Updates (PWRs) 6 541,667$ $3,322,222 $982,926 $1,951,455 2040 Averted Codes of Record Updates (PWRs) 6 541,667$ $3,322,222 $918,622 $1,894,617 2041 Averted Codes of Record Updates (PWRs) 6 541,667$ $3,322,222 $858,525 $1,839,434 2042 Averted Codes of Record Updates (PWRs) 6 541,667$ $3,322,222 $802,360 $1,785,858 2043 Averted Codes of Record Updates (PWRs) 6 541,667$ $3,322,222 $749,869 $1,733,843 2034 10-years-delayed Codes of Record Updates (BWRs) 3 541,667$ ($1,661,111) ($689,302) ($1,131,136) 2035 10-years-delayed Codes of Record Updates (BWRs) 3 541,667$ ($1,661,111) ($644,208) ($1,098,190) 2036 10-years-delayed Codes of Record Updates (BWRs) 3 541,667$ ($1,661,111) ($602,063) ($1,066,204) 2037 10-years-delayed Codes of Record Updates (BWRs) 3 541,667$ ($1,661,111) ($562,676) ($1,035,150) 2038 10-years-delayed Codes of Record Updates (BWRs) 3 541,667$ ($1,661,111) ($525,865) ($1,005,000) 2039 10-years-delayed Codes of Record Updates (BWRs) 3 541,667$ ($1,661,111) ($491,463) ($975,728) 2040 10-years-delayed Codes of Record Updates (BWRs) 3 541,667$ ($1,661,111) ($459,311) ($947,308) 2041 10-years-delayed Codes of Record Updates (BWRs) 3 541,667$ ($1,661,111) ($429,263) ($919,717) 2042 10-years-delayed Codes of Record Updates (BWRs) 3 541,667$ ($1,661,111) ($401,180) ($892,929) 2043 10-years-delayed Codes of Record Updates (BWRs) 3 541,667$ ($1,661,111) ($374,935) ($866,921) 2038 14-years-delayed Codes of Record Updates (PWRs) 6 541,667$ ($3,322,222) ($1, 051,730) ($2,009, 999) 2039 14-years-delayed Codes of Record Updates (PWRs) 6 541,667$ ($3,322,222) ($982,926) ($1,951,455) 2040 14-years-delayed Codes of Record Updates (PWRs) 6 541,667$ ($3,322,222) ($918,622) ($1,894,617) 2041 14-years-delayed Codes of Record Updates (PWRs) 6 541,667$ ($3,322,222) ($858,525) ($1,839,434) 2042 14-years-delayed Codes of Record Updates (PWRs) 6 541,667$ ($3,322,222) ($802,360) ($1,785,858) 2043 14-years-delayed Codes of Record Updates (PWRs) 6 541,667$ ($3,322,222) ($749,869) ($1,733,843) 2044 14-years-delayed Codes of Record Updates (PWRs) 6 541,667$ ($3,322,222) ($700,812) ($1,683,343) 2045 14-years-delayed Codes of Record Updates (PWRs) 6 541,667$ ($3,322,222) ($654,965) ($1,634,313) 2046 14-years-delayed Codes of Record Updates (PWRs) 6 541,667$ ($3,322,222) ($612,117) ($1,586,712) 2047 14-years-delayed Codes of Record Updates (PWRs) 6 541,667$ ($3,322,222) ($572,072) ($1,540,497)

Total: $33,222,222 $27,847,362 $32,346,874

In addition to the averted costs due to the longer intervals, e xtended update intervals would mean that certain inspections performed one or more times in ea ch interval would occur less frequently over the remainder of reactor life, resulting in fur ther averted costs not quantified in this analysis. Finally, the longer intervals would allow for gr eater scheduling freedom for all such activities, another source of averted costs not quantified in t his analysis. Because the costs and timing of these activities are uncertain, the staff did not qua ntify the resulting averted costs but

23 estimates them to be considerable (more than $100,000 per licen see per interval). The staff also considered whether a longer code of record interval of 20 or 24 years would result in a significant amount of extra work during the updates. Based on t he activities performed during these updates, the staff expects having a longer update interva l would not result in a noticeable additional amount of work to be performed at each update, speci fically for code of record updates. Therefore, the staff did not quantify any potential co sts of having a longer update interval.

5.5 Total Industry Costs

Table 6 shows the industry implementation and operation costs u nder Alternative 2, which add up to averted costs of $29.9 million at a 7-percent NPV and $35.1 million at a 3-percent NPV.

Table 6 Total Industry Costs

At tribut e T ot al Indust ry Avert ed Costs (Cost s)

Undiscounted 7% NPV 3% NPV Implementation Totals: $0 $0 $0 Operations Totals: $36,710,000 $29,890,000 $35,110,000 Indust ry T ot als: $36, 710, 000 $29, 890, 000 $35, 110, 000 Note: Total costs are rounded to three significant figures.

5.6 NRC Implementation

The NRC will incur implementation costs at each stage of the ru lemaking process. These include the costs of writing the Federal Register notice, revising the RGs, reviewing and addressing public comments on the rule, and developing the fina l rule. The staff estimates a total of 2,800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> for developing the rule and 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> for revising the RGs, across 2 years (2023 and 2024). Table 7 shows the NRC implementation costs for developing the final rule.

Table 7 NRC Implementation Costs

Number W eighted Year CostAc tiv it yof ActionsHoursHourly Rate Undiscounted 7% NP V 3% NP V 2023 Develo p Final Rule 1 1400 $143 ($200,200) ($174,862) ($188,708) 2023 Finalize Regulato ry Guides 1 400 $143 ($57,200) ($49,961) ($53,916) 2024 Develo p / Issue Final Rule 1 1400 $143 ($200,200) ($163,423) ($183,211) 2024 Finalize / Issue Regulato ry Guides 1 400 $143 ($57,200) ($46,692) ($52,346)

Total: ($514,800) ($434,938) ($478,182)

5.7 NRC Operation

When the NRC receives a request to use a code case as an altern ative, the staff requires additional time to evaluate the requests acceptability relativ e to the criteria currently approved by the agency. Under Alternative 2, the anticipated 26 code cas e alternative submittals per year

24 would not be required. These submittals would be averted starti ng in 2025, the year after the final rule is expected to take effect.

As shown in Table 8, the NRC estimates that for each submittal, the staff would require, on average, 115 hours0.00133 days <br />0.0319 hours <br />1.901455e-4 weeks <br />4.37575e-5 months <br /> to perform the technical review (including r esolving technical issues),

document the evaluation, and respond to the licensee. The absen ce of these submittals would result in averted costs for the NRC of between $1.73 million (7 -percent NPV) and $2.20 million (3-percent NPV).

Table 8 NRC Operation CostsAverted Code Alternative Requests (Operating and New Reactors)

Alternativ e Labor Weighted Cost Year Activ ity Requests Hours Hourly Rate Review ed Undiscounted 7% NPV 3% NPV 2025 Review Co de Case alternative request submittal 27 115 $143 $444,015 $338,737 $394,502 2026 Review Co de Case alternative request submittal 27 115 $143 $444,015 $316,577 $383,011 2027 Review Co de Case alternative request submittal 27 115 $143 $444,015 $295,866 $371,856 2028 Review Co de Case alternative request submittal 27 115 $143 $444,015 $276,510 $361,025 2029 Review Co de Case alternative request submittal 27 115 $143 $444,015 $258,421 $350,510 2030 Review Co de Case alternative request submittal 27 115 $143 $444,015 $241,515 $340,301 Total: $2,664,090 $1,727,625 $2,201,203

The NRC review costs for any ASME Code alternative requests sub mitted to the NRC before the effective date of the proposed rule are considered sunk cos ts, and this regulatory analysis does not address them further.

As discussed previously, under Alternative 2, the NRC will incu r costs to review industry alternative requests for N-716-3, N-921, OMN-31 and the propose d regulatory changes to the maximum code of record interval. Table 9 shows these costs.

Table 9 NRC Alternative Request Review Costs

Number of Labor Weighted Cost Year ActivityAf f e c t e d HoursHourly rat e Entit ies Undiscount ed 7% NPV 3% NPV 2024 Alternative request for N-716-3 1 115 $143 ($16,445) ($13,424) ($15,050) 2024 Alternative request for N-921 12 115 $143 ($200,629) ($163,773) ($183,604) 2024 Alternative request for OMN-31 12 115 $143 ($200,629) ($163,773) ($183,604) 2024 Alternative request for Code of Record interval 18 115 $143 ($300,944) ($245,660) ($275,406)

Total: ($718,647) ($586,630) ($657,663)

Finally, the NRC will also benefit from the less frequent code of record updates licensees are performing, as discussed previously. These updates give rise to small, but quantifiable, costs to the NRC. The NRC estimates that for each update, the staff need s to review approximately six alternative requests and requires 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to process and file related documentation. These averted costs total approximately $72,000 per licensee per upda te, with net averted costs from update reviews shown in Table 10.

25 Table 10 Averted Costs from NRC Code of Record Update Reviews

Number of Av e r t e d Cost Year ActivityAffected Cost per Entities Delayed Undiscount ed 7% NPV 3% NPV 2024 Averted Codes of Record Update Reviews 9 $72,285 $665,025 $542,859 $608,592 2025 Averted Codes of Record Update Reviews 9 $72,285 $665,025 $507,344 $590,866 2026 Averted Codes of Record Update Reviews 9 $72,285 $665,025 $474,154 $573,656 2027 Averted Codes of Record Update Reviews 9 $72,285 $665,025 $443,134 $556,948 2028 Averted Codes of Record Update Reviews 9 $72,285 $665,025 $414,144 $540,726 2029 Averted Codes of Record Update Reviews 9 $72,285 $665,025 $387,051 $524,977 2030 Averted Codes of Record Update Reviews 9 $72,285 $665,025 $361,730 $509,686 2031 Averted Codes of Record Update Reviews 9 $72,285 $665,025 $338,065 $494,841 2032 Averted Codes of Record Update Reviews 9 $72,285 $665,025 $315,949 $480,428 2033 Averted Codes of Record Update Reviews 9 $72,285 $665,025 $295,279 $466,435 2034 Averted Codes of Record Update Reviews (PWRs) 6 $72,285 $443,350 $183,975 $301,900 2035 Averted Codes of Record Update Reviews (PWRs) 6 $72,285 $443,350 $171,939 $293,107 2036 Averted Codes of Record Update Reviews (PWRs) 6 $72,285 $443,350 $160,690 $284,570 2037 Averted Codes of Record Update Reviews (PWRs) 6 $72,285 $443,350 $150,178 $276,281 2038 Averted Codes of Record Update Reviews (PWRs) 6 $72,285 $443,350 $140,353 $268,234 2039 Averted Codes of Record Update Reviews (PWRs) 6 $72,285 $443,350 $131,171 $260,421 2040 Averted Codes of Record Update Reviews (PWRs) 6 $72,285 $443,350 $122,590 $252,836 2041 Averted Codes of Record Update Reviews (PWRs) 6 $72,285 $443,350 $114,570 $245,472 2042 Averted Codes of Record Update Reviews (PWRs) 6 $72,285 $443,350 $107,075 $238,322 2043 Averted Codes of Record Update Reviews (PWRs) 6 $72,285 $443,350 $100,070 $231,381 2034 10-years-delayed Codes of Record Update Reviews (BWRs) 3 $72,285 ($221,675) ($91,987) ($150,950) 2035 10-years-delayed Codes of Record Update Reviews (BWRs) 3 $72,285 ($221,675) ($85,969) ($146,553) 2036 10-years-delayed Codes of Record Update Reviews (BWRs) 3 $72,285 ($221,675) ($80,345) ($142,285) 2037 10-years-delayed Codes of Record Update Reviews (BWRs) 3 $72,285 ($221,675) ($75,089) ($138,141) 2038 10-years-delayed Codes of Record Update Reviews (BWRs) 3 $72,285 ($221,675) ($70,177) ($134,117) 2039 10-years-delayed Codes of Record Update Reviews (BWRs) 3 $72,285 ($221,675) ($65,586) ($130,211) 2040 10-years-delayed Codes of Record Update Reviews (BWRs) 3 $72,285 ($221,675) ($61,295) ($126,418) 2041 10-years-delayed Codes of Record Update Reviews (BWRs) 3 $72,285 ($221,675) ($57,285) ($122,736) 2042 10-years-delayed Codes of Record Update Reviews (BWRs) 3 $72,285 ($221,675) ($53,537) ($119,161) 2043 10-years-delayed Codes of Record Update Reviews (BWRs) 3 $72,285 ($221,675) ($50,035) ($115,691) 2038 14-years-delayed Codes of Record Update Reviews (PWRs) 6 $72,285 ($443,350) ($140,353) ($268,234) 2039 14-years-delayed Codes of Record Update Reviews (PWRs) 6 $72,285 ($443,350) ($131,171) ($260,421) 2040 14-years-delayed Codes of Record Update Reviews (PWRs) 6 $72,285 ($443,350) ($122,590) ($252,836) 2041 14-years-delayed Codes of Record Update Reviews (PWRs) 6 $72,285 ($443,350) ($114,570) ($245,472) 2042 14-years-delayed Codes of Record Update Reviews (PWRs) 6 $72,285 ($443,350) ($107,075) ($238,322) 2043 14-years-delayed Codes of Record Update Reviews (PWRs) 6 $72,285 ($443,350) ($100,070) ($231,381) 2044 14-years-delayed Codes of Record Update Reviews (PWRs) 6 $72,285 ($443,350) ($93,523) ($224,642) 2045 14-years-delayed Codes of Record Update Reviews (PWRs) 6 $72,285 ($443,350) ($87,405) ($218,099) 2046 14-years-delayed Codes of Record Update Reviews (PWRs) 6 $72,285 ($443,350) ($81,687) ($211,746) 2047 14-years-delayed Codes of Record Update Reviews (PWRs) 6 $72,285 ($443,350) ($76,343) ($205,579)

Total: $4,433,500 $3,716,226 $4,316,685

5.8 Total NRC Costs

Table 11 shows the total NRC implementation and operation costs for Alternative 2. The total averted costs for the NRC are estimated to range from $4.43 mil lion (7-percent NPV) to

$5.38 million (3-percent NPV).

26 Table 11 Total NRC Costs

At tribut e T otal NRC Averted Cost s ( Costs)

Undiscounted 7% NPV 3% NPV Implementation Totals: ($510,000) ($430,000) ($480,000)

Operation Totals: $6,380,000 $4,860,000 $5,860,000 NRC T ot als: $5,870,000 $4,430,000 $5,380,000

5.9 Total Costs

Table 12 shows the total implementation and operation costs for the industry and the NRC under Alternative 2. These total averted costs are estimated to range from $34.3 million (7-percent NPV) to $40.5 million (3-percent NPV).

Table 12 Total Costs

At tribut e Total Averted Costs (Costs)Undiscounted 7% NPV 3% NPV

Industry Implementation: $0 $0 $0 Industry O peration: $36,710,000 $29,890,000 $35,110,000 Industry Total s: $36,710,000 $29,890,000 $35,110,000 NRC Implementation: ($510,000) ($430,000) ($480,000)

NRC O peration: $6,380,000 $4,860,000 $5,860,000 NRC Total s: $5,870,000 $4,430,000 $5,380,000 Net : $42,580,000 $34,320,000 $40,490,000

Due to the assumptions in this analysis that PWRs would elect t o use 12-year ISI and IST intervals and 24-year code of record update intervals, whereas BWRs would remain on the current 10-year ISI and IST intervals but use 20-year code of r ecord update intervals, BWRs and PWRs have different averted costs. Table 13 and Table 14 be low show that a typical PWR has averted costs for industry and NRC of approximately $562,00 0 (7-percent NPV) and

$608,000 (3-percent NPV) due to the extended code of record upd ate intervals. A typical BWR has averted costs for industry and NRC of approximately $246,00 0 (7-percent NPV) and

$144,000 (3-percent NPV) due to the shorter, yet still extended code of record update intervals.

Table 13 Typical BWR vs. PWR Code of Record Averted Costs (Indu stry)

Number of Averted Cost Cost Year ActivityAffected per Delayed Entities Updat e Undiscount ed 7% NPV 3% NPV

2024 Averted Code of Record Update (BWR and PWR) 1 541,667$ $541,667 $442,161 $495,702 2034 10-years-delayed Code of Record Update (BWR) 1 541,667$ ($ 541,667) ($224,772) ($368,849) 2034 Averted Code of Record Updates (PWR) 1 541,667$ $541,667 $224,772 $368,849 2038 14-years-delayed Code of Record Update (PWR) 1 541,667$ ($ 541,667) ($171,478) ($327,717)

PWR T otal: $541,667 $495,456 $536,833 BWR T otal: $0 $217,389 $126,853

27 Table 14 Typical BWR vs. PWR Code of Record Averted Costs (NRC)

Number of Averted Cost Cost Year ActivityAf f e c t e d per Delayed Entities Update Undiscounted 7% NPV 3% NPV

2024 Averted Code of Record Update Review (BWR and PWR) 1 $72,285 $72,285 $59,006 $66,151 2034 10-years-delayed Code of Record Update Review (BWR) 1 $72,285 ($72,285) ($29,996) ($49,223) 2034 Averted Code of Record Updates Review (PWR) 1 $72,285 $72,285 $29,996 $49,223 2038 14-years-delayed Code of Record Update Review (PWR) 1 $72,285 ($72,285) ($22,884) ($43,734)

PWR T otal: $72,285 $66,119 $71,640 BWR T ot al: $0 $29,011 $16,929

5.10 Improvements in Knowledge

Compared to the regulatory baseline (Alternative 1), Alternativ e 2 would increase the knowledge of the industry and the NRC staff by permitting licensees to us e advances in ISI and IST. The industry and the NRC would also develop greater knowledge and c ommon understanding of the ASME Codes.

5.11 Regulatory Efficiency

Compared to the regulatory baseline, Alternative 2 would increa se regulatory efficiency because licensees could use NRC-approved ASME Code Cases without submit ting requests for alternatives to the NRCs regulations. This would give licensee s flexibility and decrease their uncertainty when modifying or preparing to perform ISI or IST. Furthermore, Alternative 2 is consistent with the provisions of the NTTAA, which encourages F ederal regulatory agencies to adopt voluntary consensus standards as an alternative to de nov o agency development of standards affecting an industry. Alternative 2 is also consiste nt with the NRCs policy of evaluating whether the latest versions of consensus standards a re suitable for endorsement by regulation or RG. Finally, Alternative 2 is consistent with the NRCs goal of harmonizing with international standards to increase regulatory efficiency for b oth the NRC and international standards groups.

5.12 Other Considerations

5.12.1 Consistency with National Technology Transfer and Advancement Act of 1995

Alternative 2 is consistent with the provisions of the NTTAA an d the implementing guidance in OMB Circular A-119, Federal Participation in the Development a nd Use of Voluntary Consensus Standards and in Conformity Assessment Activities, d ated January 27, 2016 (OMB, 2016), which encourage Federal regulatory agencies to ado pt voluntary consensus standards as an alternative to de novo agency development of standards affecting an industry.

28 5.12.2 Continued Incorporation by Reference of ASME Code Editions and Addenda into the Code of Federal Regulations

Alternative 2 would continue the NRCs practice of establishing requirements for the design, construction, operation, ISI, and IST of nuclear power plants b y approving the use of new ASME BPV and OM Code Cases in 10 CFR 50.55a.

Given the existing data and information, Alternative 2 is the m ost effective way to implement the updated ASME Code Cases. The rulemaking would amend 10 CFR 50.5 5a to incorporate by reference the latest revisions to RG 1.84, RG 1.147, and RG 1.1 92, which list code cases published by ASME and approved by the NRC.

5.12.3 Increased Public Confidence

Under Alternative 2, the NRC would approve the use of current A SME Code Cases for the design, construction, operation, ISI, and IST of nuclear power plants, by incorporating them by reference in 10 CFR 50.55a. This alternative would allow licens ees to use risk-informed, performance-based approaches and the latest methods and technol ogy to design, construct, operate, examine, and test nuclear power plant components while maintaining NRC oversight of these activities, which would increase public confidence.

5.13 Uncertainty Analysis

The staff completed a Monte Carlo sensitivity analysis for this regulatory analysis using the specialty software @RISK. The Monte Carlo approach answers the question, What distribution of net costs and benefits results from multiple draws of the pr obability distribution assigned to key variables?

5.13.1 Uncertainty Analysis Assumptions

The staff identified the variables contributing the greatest un certainty to the estimated values, by performing a Monte Carlo simulation using the @RISK software pr ogram.6 Monte Carlo simulations involve introducing uncertainty into the analysis b y replacing the point estimates of the variables used to represent base-case costs and benefits wi th probability distributions. By defining input variables as probability distributions instead o f point estimates, the user can effectively model the influence of uncertainty on the analysis results (i.e., the net benefits).

The probability distribution chosen to represent each variable was bounded by the range-referenced input and the staffs professional judgment. T he probability distributions used in a Monte Carlo simulation need to be characterized by summary statistics. These summary

6 Information about this software is available at http://www.palisade.com.

29 statistics include the minimum, most likely, and maximum values of a program evaluation and review technique (PERT) distribution. 7 The staff used the PERT distribution to reflect the relative spread and skewness of the distribution defined by the three es timates.

Table 15 identifies the data elements, the distributions, and t he low, best, and high estimates of the data elements that were used in the uncertainty analysis.

Table 15 Uncertainty Analysis Variables

Data Element Mean Best High Estimate Distribution Low Estimate Estimate Estimate Alternative requests for N-716-3, N-921, OMN-31, and code of record Alternative request costs (industry)

Weighted hourly rate for request (industry) $128.10 PERT $98.11 $129.91 $150.87 Hours to produce request 230 PERT 180 230 280 Number of requests (N-716-3) 1 Number of requests (N-921) 12 PERT 6 12 17 Number of requests (OMN-31) 12 PERT 6 12 17 Number of requests (Code of Record) 18 PERT 9 18 26 Alternative request costs (NRC)

Weighted hourly rate (NRC) $143.00 PERT $143.00 $143.00 $143.00 Hours to approve request 115 PERT 90 115 140 Number of requests (licensee) 1 Averted costs from code case alternative requests Weighted hourly rate for request $128.10 PERT $98.11 $129.91 $150.87 Request preparation and submission (hours) 230 PERT 180 230 280 Number of requests per year 27 Averted costs from delayed code of record updates Estimated cost of code of record update (Industry) $541,667 PERT $250,000 $500,000 $1,000,000 Estimated cost of code of record update review (NRC) $72,285 PERT $50,000 $70,928 $100,000 Number of updates per year 9

7 A PERT distribution is a special form of the beta distribution with specified minimum and maximum values.

The shape parameter is calculated from the defined most likely value. The PERT distribution is similar to a triangular distribution in that it has the same set of three parameters. Technically, it is a special case of a scaled beta (or beta general) distribution. The PERT distribution is generally considered superior to the triangular distribution when the parameters result in a skewed distribution, as the smooth shape of the curve places less emphasis in the direction of skew. Like the triangular distribution, the PERT distribution is bounded on both sides and therefore may not be adequate for modeling that needs to capture tail or extreme events.

30 Data Element Mean Best High Estimate Distribution Low Estimate Estimate Estimate Costs to develop and issue final RG changes (NRC)

Hourly rate for NRC $143.00 PERT $143.00 $143.00 $143.00 Hours to develop 400 PERT 94 378 755 Number of years 2 Averted code alternative request review costs (NRC)

Hourly rate for NRC $143.00 PERT $143.00 $143.00 $143.00 Hours to review 115 PERT 90 115 140 Number of actions (this is a recurring averted cost) 27

5.13.2 Uncertainty Analysis Results

The staff performed the Monte Carlo simulation by recalculating the analysis results 10,000 times. For each iteration, the values identified in Tabl e 15 were chosen randomly from the probability distributions defining the input variables, the values of the output variables were recorded, and these values were used to define the resultant pr obability distribution.

For the analysis shown in each figure below, the staff ran 10,0 00 simulations, changing the key variables to assess the resulting effects on costs and benefits. Figure 1, 2, and 3 display histograms of the total incremental costs and benefits relative to the regulatory baseline (Alternative 1). The analysis shows that both the industry and the NRC will benefit in terms of cost savings (positive averted costs) if this rule is issued.

19.07 42.45 5.0% 90.0% 5.0%

Total Industry Cost 7% NPV

Minimum $14,545,757 Maximum $52,229,771 Mean $29,891,736 Std Dev $7,112,864 5% $19,073,711 95% $42,449,141

10 15 20 25 30 35 40 45 50 55 Values in Millions ($)

Figure 1 Total Industry Averted Costs (7-percent NPV)Alternati ve 2

31 3.605 5.285 5.0% 90.0% 5.0%

Total NRC Cost 7% NPV

Minimum $2,981,068 Maximum $6,037,002 Mean $4,420,133 Std Dev $513,053 5% $3,605,065 95% $5,284,722

2.50 3.00 3.50 4.00 4.50 5.00 5.50 6.00 6.50 Values in Millions ($)

Figure 2 Total NRC Costs (7-percent NPV)Alternative 2

23.45 46.89 5.0% 90.0% 5.0%

Total Cost 7% NPV

Minimum $19,254,316 Maximum $56,545,131 Mean $34,311,869 Std Dev $7,127,576 5% $23,447,903 95% $46,886,941

15 20 25 30 35 40 45 50 55 60 Values in Millions ($)

Figure 3 Total Costs (7-percent NPV)Alternative 2

Table 16 presents descriptive statistics for the uncertainty an alysis. In particular, the table shows the ranges of the output distributions, which give a clea rer picture of the potential incremental costs and benefits of the proposed rule. The 5-perc ent and 95-percent values

32 shown (rounded) in Table 16 also appear as numerical values in Figure 1, 2, and 3, above the vertical lines marking the endpoints of the 90-percent confiden ce intervals.

Table 16 Descriptive Statistics for Uncertainty Results (7-Perc ent NPV)

Uncertainty results Incremental cost-benefit (2021 dollars, millions) Min Mean Std dev Max 5% 95%

Total industry cost $14.5 $29.9 $7.11 $52.2 $19.1 $42.4 Total NRC cost $2.98 $4.42 $0.51 $6.04 $3.61 $5.28 Total cost $19.3 $34.3 $7.13 $56.5 $23.4 $46.9

Figure 4 shows a tornado diagram that identifies the cost drive rs with the greatest impact for the proposed rulemaking. The figure ranks the top six cost drivers based on their contribution to the uncertainty in cost. The largest cost driver is the industry av erted cost for code of record updates; the uncertainty in these quantities generates the larg est variation in the total costs.

Total Cost 7% NPV Inputs Ranked by Effect on Output Mean

Industry cost for Code of Record update $23,304,158 $47,369,419

NRC cost for Code of Record update $33,469,528 $35,044,788

Industry hours to produce alternative req $33,750,790 $34,999,692 Input High

Industry labor rate for alternative request $33,753,473 $34,928,224 Input Low

NRC hours to develop rule $33,873,741 $34,872,931

NRC hours to evaluate alternative request $33,784,458 $34,756,879

Baseline = $34,311,869

20 25 30 35 40 45 50 Values in Millions ($)

Figure 4 Top Six Cost Drivers in Terms of Uncertainty (7-percen t NPV)Alternative 2

5.13.3 Summary of Uncertainty Analysis

The uncertainty analysis shows that the estimated mean benefit (i.e., positive averted costs or savings) for this proposed rule is $34.3 million at 7-percent N PV, and that there is greater than 99-percent confidence that the proposed rule is cost beneficial. It is reasonable to infer that proceeding with the proposed rule represents an efficient use o f resources and averted costs for the NRC and the industry. The rule would also be cost beneficia l to the industry and to the NRC considered separately.

33 5.14 Disaggregation

The NRC performed a screening review to determine whether it wo uld be possible to eliminate any of the individual requirements (or any set of integrated re quirements) of the rule while still achieving the objectives of the rulemaking. The NRC determined that the objectives of the rulemaking were to incorporate RGs by reference and to make con forming changes, and that each of the rules requirements would be necessary to achieve o ne or more objectives of the rulemaking. Table 17 provides the results of this review.

Table 17 Disaggregation

(2) Make Regulatory goals for (1) Approve use conforming (3) Extend ISI, proposed rule of new code changes for IST, and code of cases in each RG incorporation by record intervals reference 10 CFR 50.55a(a)(3)(i);

NRC RG 1.84, X X X Revision 40 (DG-1405) 10 CFR 50.55a(a)(3)(ii);

NRC RG 1.147, X X X Revision 21 (DG-1406) 10 CFR 50.55a(a)(3)(iii);

NRC RG 1.192, X X X Revision 5 (DG-1407)

Regulatory changes to X code of record intervals X

While both the proposed incorporation by reference of the afore mentioned ASME Code Cases and the proposed regulatory changes to the maximum allowable co de of record interval result in averted costs to both industry and the NRC, the regulatory chan ges for the code of record interval constitute the bulk of the averted costs, as shown in Table 18 and Table 19. Note that these two tables do not include the costs resulting from the pr oposed rule, but instead only the averted costs, so that this comparison can be made more clearly.

Table 18 Net Averted Costs to Industry

Att ribute Industry Averted O peration Cost s ( Costs)

Undiscount ed 7% NPV 3% NPV Code Case IBR Totals: $3,490,000 $2,040,000 $2,770,000 Code of Record Interval Totals: $33,220,000 $27,850,000 $32,350,000 Industry T otals: $36, 710, 000 $29, 890, 000 $35, 120, 000

34 Table 19 Net Averted Costs to NRC

Att ribute NRC Averted O peration Costs (Costs)

Undiscounted 7% NPV 3% NPV Code Case IBR Totals: $1,950,000 $1,140,000 $1,540,000 Code of Record Interval Totals: $4,430,000 $3,720,000 $4,320,000 Industry T otals: $6, 380, 000 $4, 860, 000 $5, 860, 000

5.15 Summary

This regulatory analysis identified both quantifiable and nonqu antifiable costs and benefits that would result from incorporating NRC-approved ASME BPV and OM Co de Cases by reference into the Code of Federal Regulations. Although quantifiable costs and benefits appear more tangible, the staff urges decision-makers not to discount costs and benefits that cannot be quantified or monetized, as the latter may be of equal or great er importance.

5.15.1 Quantified Net Benefit

As shown in Table 12 above, the estimated quantified incrementa l averted costs for Alternative 2 over the 24-year analysis horizon, relative to th e regulatory baseline (Alternative 1), range from approximately $34.3 million (7-perc ent NPV) to $40.5 million (3-percent NPV). Table 12 also shows that Alternative 2 would be c ost beneficial for the NRC and the industry considered separately.

5.15.2 Nonquantified Benefits

In addition to the quantified costs discussed in this regulator y analysis, the proposed rule would lead to several nonquantified costs and benefits for the genera l public, industry, and the NRC, in relation to the attributes of public health (accident), occupat ional health (accident and routine),

increases in knowledge, regulatory efficiency, and other consid erations. These costs and benefits are summarized below.

5.15.3 Advances in Inservice Inspection and Inservice Testing

Advances in ISI and IST may incrementally decrease the likeliho od of a radiological accident, the likelihood of postaccident plant worker exposure, and the l evel of plant worker radiological exposure during routine inspec tions or testing. The NRCs approval of later editions and addenda of the ASME BPV and OM Codes and associated code cases may contribute to plant safety by providing alternative examination methods that may result in the earlier identification of material degradation that, if undetected, could eventually l ead to a plant transient. These alternative methods may increase assurance of plant safety syst em readiness and may prevent, through inspection and testing, the introduction of a new failu re mode or common-cause failure mode not previously evaluated. Furthermore, the longer ISI and IST intervals give licensees more flexibility in scheduling the required maintenance, inspec tion, and testing activities in each

35 interval, and activities that must be performed a certain numbe r of times in each interval will be performed fewer times throughout the remaining reactor life. Th ese are significant benefits that were not quantified.

5.15.3.1 Reduction in Public Health Radiation Exposures

The industrys practice of adopting the ASME BPV and OM Code Ca ses that are incorporated by reference into the regulations may incrementally reduce the likelihood of a radiological accident in a positive, but not easily quantifiable, manner. Pu rsuing Alternative 2 would continue to support the NRCs goal of maintaining safety by approving la ter editions and addenda of the ASME Code and associated code cases, thus permitting licensees to use advances in ISI and IST, providing alternative examinations for older plants, respo nding promptly to user needs, and providing limited and clearly focused alternatives to specific ASME Code provisions.

Improvements in ISI and IST may also result in the earlier iden tification of material degradation that, if undetected, could eventually lead to a plant transient. Therefore, Alternative 2 would either maintain the same level of safety, or incrementally incr ease safety and thus incrementally decrease public radiation exposure, relative to the regulatory baseline.

5.15.3.2 Reduction in Worker Radiation Exposures

The NRCs approval of later editions and addenda of the ASME BP V and OM Codes and associated code cases may reduce occupational radiation exposur e in a positive, but not easily quantifiable, manner. For example, the advances in ISI and IST may result in an incremental decrease in the likelihood of an accident resulting in worker e xposure compared to the regulatory baseline. Furthermore, the extended ISI and IST inte rvals would result in fewer inspections, tests, and other activities per year, resulting in reduced occupational radiation exposure.

5.15.3.3 Improvements in Inservice Inspection and Inservice Testing Knowledge

The NRC approval of later editions and addenda of the ASME BPV and OM Codes and associated code cases would increase knowledge by enhancing the ability of the industry and the staff to gain experience with new technology before its inc orporation into the ASME Codes and by permitting licensees to use advances in ISI and IST. Imp roved ISI and IST may result in the earlier identification of material degradation that, if und etected, could eventually lead to a plant transient. However, this benefit could be offset in part by the decreased number of ISI and IST inspections per year.

5.15.3.4 Consistency with National Technology Transfer and Advancement Act of 1995

Alternative 2 is consistent with the provisions of the NTTAA an d the implementing guidance in OMB Circular A-119, which encourage Federal regulatory agencies to adopt voluntary

36 consensus standards as an alternative to de novo agency development of standards affecting an industry.

5.15.3.5 Continued Incorporation by Reference of ASME Code Editions and Addenda into the Code of Federal Regulations

Alternative 2 would continue the NRCs practice of establishing requirements for the design, construction, operation, ISI, and IST of nuclear power plants b y approving the use of later editions and addenda of the ASME BPV and OM Codes in 10 CFR 50. 55a.

5.15.1.6 Increased Public Confidence

Alternative 2 would incorporate the current ASME Code edition, addenda, and code cases for the design, construction, operation, ISI, and IST of nuclear po wer plants by approving the use of editions and addenda of the ASME BPV and OM Codes in 10 CFR 50. 55a. This alternative would allow licensees to use risk-informed, performance-based a pproaches and the most current methods and technology to design, construct, operate, e xamine, and test nuclear power plant components, while maintaining NRC oversight of these acti vities.

The timely incorporation by reference of current addenda and ed itions of the ASME BPV and OM Codes into the Code of Federal Regulations and the review and approval of associated code cases would help the NRC remain an effective industry regulator. This role would be undermined if outdated material remains incorporated by referen ce in the Code of Federal Regulations.

5.15.2 Nonquantified Costs

The staff believes that incorporating by reference the most rec ent ASME BPV and OM Code editions and addenda and associated NRC-approved code cases int o the Code of Federal Regulations would decrease industry and NRC operation costs. If the staff has underestimated the number or the complexity of these eliminated submittals, th en the averted costs would increase proportionally.

5.16 Safety Goal Evaluation

Safety goal evaluations are applicable only to regulatory initi atives considered to be generic safety enhancement backfits subject to the substantial addition al protection standard at 10 CFR 50.109(a)(3) or the issue finality provisions in 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants. Some aspects of this rule may have generic safety impacts because they may affec t the likelihood of core damage o r spent fuel damage, which generally are the focus of a quantitative safety goal evaluatio n. However, the magnitude of this change is not readily quantifiable because the potential impact of longer testing and inspection intervals for ISI and IST activities has not been determined; h owever, the staff expects these

37 effects to be minimal. A more dominant effect of this rule is t o reduce costs on the regulated entities and the NRC, resulting in cost savings for both.

5.17 Backfitting Discussion

5.17.1 Section A: Incorporation by Reference of Later Editions and Addenda of Section III, Division 1, of the ASME BPV Code

The proposed rule alternative would allow licensees and applica nts to apply the most recent ASME BPV and OM Code Cases approved by the NRC, sometimes with NRC-specified conditions. The NRCs safety goal evaluation applies only to re gulatory initiatives considered to be generic safety enhancement backfits subject to the substanti al additional protection standard at 10 CFR 50.109(a)(3). The NRC does not regard the incorporati on by reference of NRC-approved ASME Code Cases to be backfitting or to represent an inconsistency with any issue finality provisions in 10 CFR Part 52, Licenses, Certifi cations, and Approvals for Nuclear Power Plants. The Federal Register notice of proposed rulemaking states the basis for this determination.

Incorporation by reference of the code cases of Section III, Di vision 1, of the ASME BPV Code is prospective in nature. Incorporation of the code cases would not affect a design that has been approved or a plant that has received a construction permit, an operating license, or a combined license. This is because the code cases of the ASME BPV Code to be used in constructing a plant are, by rule, determined based on the date of the constru ction permit or the combined license and are not changed, except voluntarily by the licensee with NRC approval. Thus, incorporation by reference of later code cases of Section III, Division 1, of the ASME BPV Code would not constitute a backfitting as defined in 10 CFR 50.10 9(a)(1).

5.17.2 Section B: Incorporation by Reference of Later Editions and Addenda of Section XI, Division 1, of the ASME BPV and OM Codes

Incorporation by reference of later code cases of Section XI, D ivision 1, of the ASME BPV Code and of the ASME OM Code would affect the ISI and IST programs o f operating reactors.

However, the Backfit Rule generally does not apply to incorpora tion by reference of later code cases of Section XI of the ASME BPV Code and the ASME OM Code f or the following reasons:

• The NRCs longstanding policy has been to incorporate later ve rsions of the ASME Codes into its regulations; thus, when licensees receive t heir operating licenses, they know that such updating is part of the regulatory process. This is reflected in 10 CFR 50.55a, which requires licensees to revise their ISI and IST programs periodically to the latest edition and addenda of Section XI of the ASME BPV Code and of the ASME OM Code incorporated by reference into 10 CFR 50.55 a that are in effect 18 months before the start of a new ISI and IST interval. Thus, when the NRC endorses a later version of an ASME Code, it is implementing this longst anding policy.

38

• The ASME BPV and OM Codes are national consensus standards dev eloped by participants with broad and varied interests, in which all inte rested parties, including the NRC staff and nuclear utility perso nnel, participate. This consideration is consistent with both the intent and spirit of the Backfit Rule (i.e., the NRC p rovides for the protection of public health and safety but does not unilaterally impose undue costs on applicants or licensees).

5.17.3 Other Circumstances in Which the NRC Does Not Apply the Backfit Rule to the Endorsement of a Later Code

The NRC does not apply the Backfit Rule to the endorsement of a later code in the following other circumstances:

• When the NRC takes exception to a later ASME BPV or OM Code pr ovision and merely retains the current existing requirement, prohibits the use of the later code provision, or limits the use of the later code provision, the Backfit Rule wo uld not apply because the NRC is not imposing new requirements. However, the NRC provides the technical or policy bases, or both, for taking exceptions to the code in the Statement of Considerations for the rule.

• When an NRC exception relaxes an existing ASME BPV or OM Code provision but does not prohibit a licensee from using the existing code provision, the Backfit Rule would not apply.

5.18 Results for the Committee to Review Generic Requirements

This section addresses regulatory analysis information requirem ents for rulemaking actions or staff positions subject to review by the Committee to Review Ge neric Requirements (CRGR). All information called for by the CRGR procedures (NRC, 2018) appea rs in this regulatory analysis or in the Federal Register notice for the proposed rule. Table 20 provides a cross-refere nce between the relevant information and its location in this docum ent or the Federal Register notice.

Table 20 Specific CRGR Information Requirements for Regulatory Analysis

Citation in CRGR Information Item to Be Included in a Regulatory Where Item Is Procedures Analysis Prepared for CRGR Review Discussed (NRC, 2018)

Appendix B, (i) The new or revised generic requirement or staff Proposed rule text in position in the proposed rule Federal Register notice

Appendix B, (ii) Draft papers or other documents supporting the Federal Register notice requirements or staff positions for the proposed rule

39 Citation in CRGR Information Item to Be Included in a Regulatory Where Item Is Procedures Analysis Prepared for CRGR Review Discussed (NRC, 2018)

Appendix B, (iii) The sponsoring offices position on whether each Regulatory Analysis, requirement or staff position would modify, implement, Section 5, and relax, or reduce existing requirements or staff Section XIII, Backfitting positions and Issue Finality, of Federal Register notice for the proposed rule

Appendix B, (iv) The method of implementation Regulatory Analysis, Section 7

Appendix B, (vi) The category of power reactors, new reactors, or Regulatory Analysis, nuclear materials facilities or activities to which the Section 4.2.2 generic requirement or staff position applies

Appendix B, The items required at 10 CFR 50.109(c) and the Section XIII, Backfitting (vii)-(viii) required rationale at 10 CFR 50.109(a)(3) if the action and Issue Finality, of involves a power reactor backfit and the exceptions at Federal Register notice 10 CFR 50.109(a)(4) are not applicable for the proposed rule

Appendix B, (xvi) An assessment of how the action relates to the Regulatory Analysis, Commissions Safety Goal Policy Statement Section 5.16

6 Decision Rationale

Table 21 provides the quantified and qualified costs and benefi ts for Alternative 2. The quantitative analysis used mean values.

Table 21 Summary of Totals

Net Monetary Savings or (Costs)Total Nonquantified Benefits or (Costs)

Present Value Alternative 1: No action

$0 None Alternative 2: Incorporate by reference Benefits:

RG 1.84, Design, Fabrication, and Materials

• Advances in ISI and IST: May Code Case Acceptability, ASME Section III, incrementally decrease the likelihood of a Revision 40 (DG-1405); RG 1.147, Inservice radiological accident, the likelihood of Inspection Code Case Acceptability, ASME postaccident plant worker exposure, or Section XI, Division 1, Revision 21 the level of plant worker radiological (DG-1406); and RG 1.192, Operation and exposure during routine inspections or Maintenance Code Case Acceptability, testing.

ASME OM Code, Revision 5 (DG-1407).

40 Net Monetary Savings or (Costs)Total Nonquantified Benefits or (Costs)

Present Value Change the code of record interval in 10 CFR 50.55a to twice the ISI or IST interval.

• Public Health (Accident): May incrementally reduce the likelihood of a Industry (all provisions): radiological accident in a positive, but not

$29.9 million using 7% NPV easily quantifiable, manner. Pursuing

$35.1 million using 3% NPV Alternative 2 would continue to support the NRCs goal of maintaining safety by NRC (all provisions): approving later editions and addenda of

$4.42 million using 7% NPV the ASME BPV and OM Codes and

$5.38 million using 3% NPV applicable Code Cases, thus permitting licensees to use advances in ISI and IST, Net benefit (cost) (all provisions): providing alternative examinations for

$34.3 million using 7% NPV older plants, responding promptly to user

$40.5 million using 3% NPV needs, and providing limited and clearly focused alternatives to specific ASME Code provisions. Improvements in ISI and IST may also result in the earlier identification of material degradation that, if undetected, could eventually lead to a plant transient. Therefore, relative to the regulatory baseline, Alternative 2 would either maintain the same level of safety or incrementally increase safety, thus incrementally decreasing public radiation exposure.

• Occupational Health (Accident and Routine): The use of later editions and addenda of the ASME BPV and OM Code and applicable code cases may reduce postaccident occupational radiation exposures in a positive, but not easily quantifiable, manner. Advances in ISI and IST may incrementally decrease the likelihood of an accident resulting in worker exposure relative to the regulatory baseline.

• Improvements in Knowledge: The NRC and industry staff would gain experience with new technology and ISI and IST advances.

41 Net Monetary Savings or (Costs)Total Nonquantified Benefits or (Costs)

Present Value

(continued from above)

• Consistent with the NTTAA and Implementing Guidance: Alternative 2 is consistent with the provisions of the NTTAA and implementing guidance in OMB Circular A-119, which encourage Federal regulatory agencies to adopt voluntary consensus standards as an alternative to de novo agency development of standards affecting an industry. Furthermore, the ASME Code consensus process is an important part of the regulatory framework.

Costs:

• Nonquantified Costs: If the staff has underestimated the number or the complexity of these eliminated submittals, then the averted costs would increase proportionally. Furthermore, the longer ISI and IST intervals give licensees more flexibility in scheduling the required maintenance, inspection, and testing activities in each interval, and activities that must be performed a certain number of times in each interval will be performed fewer times throughout the remaining reactor life. These are significant benefits that were not quantified.

The industry and the NRC would benefit from the proposed rulema king (Alternative 2) because of the averted costs from licensees not needing to submit and t he NRC not needing to review and approve ASME Code Case requests on a plant-specific basis u nder 10 CFR 50.55a(z). As shown in Table 21, compared to the regulatory baseline, Alterna tive 2 would result in net benefits (averted costs) for the industry that range from $29.9 million (7-percent NPV) to

$35.1 million (3-percent NPV). The NRCs net benefit would rang e from $4.42 million (7-percent NPV) to $5.38 million (3-percent NPV). Thus, the total quantita tive net averted costs of the rulemaking would range from $34.3 million (7-percent NPV) to $4 0.5 million (3-percent NPV).

Alternative 2 would also have the qualitative benefit of meetin g the NRC goal of ensuring the protection of public health and safety and the environment thro ugh the agencys approval of the use of later ASME BPV and OM Code Cases. It would also allow fo r the use of the most current

42 methods and technology. This alternative would also support the NRCs goal of maintaining an open regulatory process, because approving ASME Code Cases woul d demonstrate the agencys commitment to participating in the national consensus standards process and maintain its status as an effective regulator.

The NRC has had a decades-long practice of approving or mandati ng, or both, the use of certain ASME Code Cases in 10 CFR 50.55a through the rulemaking process of incorporation by reference. Retaining the practice of approving or mandating the ASME Codes would continue the regulatory stability and predictability provided b y the current practice. Retaining the practice would also ensure consistency across the industry and assure the industry and the public that the NRC will continue to support the use of the mos t updated and technically sound techniques developed by ASME to provide adequate protection to the public. In this regard, these ASME Codes are voluntary consensus standards developed by participants with broad and varied interests, and they have already undergone extensive external review before being evaluated by the NRC. Finally, the NRCs use of the ASME Codes is consistent with the NTTAA, which directs Federal agencies to adopt voluntary consen sus standards instead of developing Government-unique standards (i.e., those developed by Federal agencies), unless inconsistent with applicable law or otherwise impractical.

Based solely on quantified costs and benefits, the regulatory a nalysis shows that the rulemaking is justified because the total quantified benefits of the propo sed regulatory action would exceed the costs of the proposed action, for all discount rates up to 7 percent. Certainly, if the qualitative benefits (including the safety benefit, regulatory efficiency, and other nonquantified benefits) are considered together with the quantified benefits, then the benefits would outweigh the identified quantitative and qualitative impacts. The uncert ainty analysis shows a net benefit (averted cost) for all simulations with a range of averted cost s from $19.3 million to $56.5 million (at a 7-percent NPV).

Therefore, after integrating both quantified and nonquantified costs and benefits, the benefits of the proposed rule outweigh the costs to implement the rule.

7 Implementation Schedule

This rule would become effective 30 days after the publication of the final rule in the Federal Register.

8 References

U.S. Code of Federal Regulations, Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy.

U.S. Code of Federal Regulations, Licenses, Certifications, and Approvals for Nuclear Power Plants, Part 52, Chapter I, Title 10, Energy.

43 U.S. Code of Federal Regulations, Fees for Facilities, Materials, Import and Export Licenses, and Other Regulatory Services under the Atomic Energy Act of 19 54, as Amended, Part 170, Chapter I, Title 10, Energy.

U.S. Department of Labor, Bureau of Labor Statistics (BLS), NA ICS Code: North American Industry Classification System Code, February 2020. Available at http://www.bls.gov/bls/naics.htm; last accessed on May 13, 2022.

BLS, May 2021 National Industry-Specific Occupational Employme nt and Wage Estimates, U.S. Department of Labor, May 2021. Available at https://www.bls.gov/oes/2021/may/naics5_221113.htm ; last accessed on May 15, 2022.

U.S. Nuclear Regulatory Commission (NRC), NUREG/CR-3568, A Han dbook for Value-Impact Assessment, December 1983 (Agencywide Documents Access and Man agement System Accession No. ML062830096).

NRC, Regulatory Issue Summary 2004-12, Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI, July 28, 2004 (ML042090436 ).

NRC, NUREG-2228, Weld Residual Str ess Finite Element Analysis Validation: Part II-Proposed Validation Procedure, Volume 33, July 2020 (ML20212L592).

NRC, NUREG-1350, 2021-2022 Information Digest, Volume 33, Oct ober 2021a (ML21300A280).

NRC, Regulatory Guide 1.193, ASME Code Cases Not Approved for Use, Revision 7, December 2021b (ML21181A224).

NRC, Regulatory Guide 1.84, Design, Fabrication, and Materials Code Case Acceptability, ASME Section III, Revision 39, December 2021c (ML21181A225).

NRC, Regulatory Guide 1.147, Inservice Inspection Code Case Ac ceptability, ASME Section XI, Division 1, Revision 20, December 2021d (ML21181A2 22).

NRC, Regulatory Guide 1.192, Operation and Maintenance Code Ca se Acceptability, ASME OM Code, Revision 4, December 2021e (ML21181A223).

NRC, Committee to Review Generic Requirements Procedures and I nternal Administrative Process, June 2018 (ML17355A533).

NRC, NUREG/BR-0058, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission, Revision 5 (draft final), January 2020 (ML19261A27 7).

NRC, Draft Regulatory Guide, DG-1405, Design, Fabrication, and Materials Code Case Acceptability, ASME Section III, proposed Revision 40, January 2023a (ML22195A282).

NRC, Draft Regulatory Guide, DG-1406, Inservice Inspection Cod e Case Acceptability, ASME Section XI, Division 1, proposed Revision 21, January 2023b (M L22195A284).

NRC, Draft Regulatory Guide, DG-1407, Operation and Maintenanc e Code Case Acceptability, ASME OM Code, proposed Revision 5, January 2023c (ML22196A063).

44 Office of Management and Budget (OMB), Circular A-4, Regulator y Analysis, October 9, 2003.

Available at https://www.federalregister.gov/documents/2003/10/09/03-25606/c ircular-a regulatory-analysis.

OMB, Circular No. A-119, Federal Participation in the Developm ent and Use of Voluntary Consensus Standards and in Conformity Assessment Activities, J anuary 27, 2016. Available at https://www.federalregister.gov/documents/2016/01/27/2016-01606 /revision-of-omb-circular-no-a-119-federal-participation-in-the-development-and-use-of-volun tary.

Public Law 104-113, National Technology Transfer and Advanceme nt Act of 1995[, as Amended]. Available at http://www.gpo.gov/fdsys/pkg/PLAW-104publ113/pdf/PLAW-104publ113.pdf.

45 Appendix A Major Assumptions and Input Data

Table A-1 Major Assumptions and Input Data

Data Element Best Estimate Unit Source or Basis of Estimate Key years Final rule effective year 2024 year NRC input Analysis base year 2021 year NRC input Number of entities Number of operating reactor units 92 units Based on NUREG-1350, Information Digest, Volume 33, Appendix A, issued October 2021.

Number of operating Units 3 and 4 of the Vogtle Electric Generating PWR units 61 units Plant are expected to begin operation in 2022 Number of operating and 2023, respectively.

BWR units 31 units Number of sites Obtained from the NRCs Operating Nuclear Number of sites with Power Reactors (by Location or Name) operating reactors 54 sites at https://www.nrc.gov/info-finder/reactors/ with data current as of October 1, 2021 (last accessed on May 20, 2022).

Code cases last 3 years and are typically Analysis Horizon 24 years renewed once, for a total of 6 years; however, 24 years were analyzed to account for the longer update intervals.

Labor Rates Labor rates used are from the BLS Employer Costs for National Compensation Survey dataset, Managers $184 Dollars per hour 2021 values. A multiplier of 2.4, which includes fringe and indirect management cost, was then applied and resulted in the displayed labor rates.

Technical staff $125 Dollars per hour BLS tables

Administrative staff $99 Dollars per hour BLS tables

Licensing staff $146 Dollars per hour BLS tables

Nuclear technician $124 Dollars per hour BLS tables

Nuclear engineer $130 Dollars per hour BLS tables

NRC $143 Dollars per hour NRC calculation

A-1