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pdfRegulatory Analysis and Backfit Analysis
Proposed Rulemaking:
Emergency Preparedness (10 CFR Part 50)
U.S. Nuclear Regulatory Commission
Office of Nuclear Security and Incident Response
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page i
Table of Contents
Table of Contents.....................................................................................................................................i
Executive Summary ............................................................................................................................... 1
Abbreviations ......................................................................................................................................... 3
1.
Introduction.................................................................................................................................... 4
1.1
Statement of the Problem and Reasons for the Rulemaking.................................................... 4
1.2
Background ............................................................................................................................... 4
1.2.1
Current Regulations Governing Emergency Preparedness (10 CFR Part 50) .................... 4
1.2.2
Commission Orders ............................................................................................................. 4
1.2.3
NRC Bulletin 2005-02 .......................................................................................................... 5
1.2.4
NRC Guidance Documents.................................................................................................. 6
1.3
Regulatory Objectives ............................................................................................................... 6
2.
Identification and Preliminary Analysis of Alternative Approaches ............................................... 7
3.
Evaluation of Benefits and Costs .................................................................................................. 8
3.1
Identification of Affected Attributes ........................................................................................... 8
3.2
Analytical Methodology ............................................................................................................. 9
3.2.1
Baselines for Analysis ........................................................................................................ 10
3.2.2
EP Programs and Program Characteristics ....................................................................... 10
3.2.3
Incremental Requirements in the Final Rule...................................................................... 11
3.2.4
Other Data and Assumptions ............................................................................................. 11
4.
Results......................................................................................................................................... 12
4.1
Benefits and Costs Under the Main Analysis.......................................................................... 12
4.1.1
Protection of Onsite Personnel .......................................................................................... 16
4.1.2
Emergency Action Levels for Hostile Action Events .......................................................... 17
4.1.3
Hostile Action Event Drills and Exercises .......................................................................... 18
4.1.4
Evacuation Time Estimate Updating .................................................................................. 19
4.1.5
Licensee Coordination with Offsite Response Organizations............................................ 20
4.1.6
On-Shift Multiple Responsibilities....................................................................................... 21
4.1.7
Emergency Response Organization Augmentation and Alternative Facilities................... 22
4.1.8
Reduction in Effectiveness................................................................................................. 23
4.1.9
Emergency Declaration Timeliness ................................................................................... 25
4.1.10 Emergency Operations Facility – Performance-Based Approach ..................................... 26
4.1.11 Backup Means for Alert and Notification Systems (ANS) .................................................. 27
4.2
Sensitivity Analysis – Pre-Order Baseline............................................................................... 28
4.3
Backfit Analysis ....................................................................................................................... 32
4.4
Safety Goal Evaluation............................................................................................................ 38
4.5
CRGR Results......................................................................................................................... 39
5.
Decision Rationale....................................................................................................................... 40
5.1
Regulatory Analysis ........................................................................................................... 40
5.2
Backfit Analysis .................................................................................................................. 40
6.
Implementation ............................................................................................................................ 41
6.1
Schedule ............................................................................................................................ 41
6.2
Impacts on Other Requirements ........................................................................................ 41
Appendix A
Regulatory Analysis Assumptions and Inputs, by Regulatory Initiative
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 1
Executive Summary
The Nuclear Regulatory Commission (NRC) is proposing to enhance the current emergency
preparedness (EP) regulations pertaining to nuclear reactors. The proposed rulemaking:
(1) codifies emergency preparedness requirements imposed by Commission order after the
terrorist attacks of September 11, 2001, as modified based upon experience and insights
gained by the Commission during implementation, (2) codifies emergency preparedness
and response enhancements discussed within NRC Bulletin 2005-02, and (3) adds several
new requirements that resulted from NRC staff review of EP regulations and guidance. The
rulemaking proposes changes addressing 11 aspects of EP. All of these changes would
affect power reactor licensees, and one would affect non-power reactors.
The analysis presented in this document examines the benefits and costs of the proposed
EP requirements relative to the baseline of current regulations, relevant orders, and
voluntary actions on the part of industry. As a sensitivity analysis, the document also
examines the benefits and costs of the proposed rulemaking relative to the baseline of
current regulations only (excluding the Order, NRC Bulletin 2005-02, and industry voluntary
actions). The key findings of the analysis are as follows:
Total Cost to Industry (including Backfits). The proposed rule would result in a total
one-time cost to all nuclear power plant sites and non-power reactors of
approximately $29.5 million, followed by total annual costs on the order of
$3.1 million. The total present value of these costs is estimated at $67.4 million
(using a 7-percent discount rate) and $88.7 million (using a 3-percent discount rate)
over the next 30 years. Almost all of the estimated costs to industry qualify as
backfits (see Section 4.3).
Average Cost per Site for Power Reactors. The average nuclear power plant site,
which may include multiple units, would incur a one-time cost of approximately
$447,000 followed by annual costs of approximately $47,000.
Average Cost per Site for Non-Power Reactors. The average non-power reactor
would incur a one-time cost of approximately $14,000. The proposed rule does not
impose any annual costs on non-power reactors.
Value of Benefits Not Reflected Quantitatively. With the exception of some direct
monetary savings to industry, the cost figures shown above do not reflect the value
of the benefits of the proposed rule. These benefits are evaluated qualitatively in
Section 4.1.
Costs to NRC. The rule would result in a one-time cost to NRC of approximately
$1.1 million, followed by annual costs of approximately $100,000. The total present
value of these NRC costs is estimated at $2.3 million (using a 7-percent discount
rate) and $3.0 million (using a 3-percent discount rate).
Costs to Other Government Agencies. The rule would result in a one-time cost to
other government agencies of approximately $1.8 million, followed by annual costs of
approximately $36,000. The total present value of these other government costs is
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 2
estimated at $2.2 million (using a 7-percent discount rate) and $2.5 million (using a
3-percent discount rate).
Decision Rationale. The NRC believes that the rule is cost-justified because the
proposed regulatory initiatives for increased and consistent emergency
preparedness measures would enable emergency personnel to respond earlier and
more effectively to emergency events at nuclear power plants, increasing the public
health and safety.
The proposed rule also would apply to any new reactors brought online after promulgation of
the final rule, including Watts Bar Unit 2 as well as any units that would be built under the
new reactor applications that NRC has received to date. Because EP program costs are
primarily a site-based function, rather than a reactor-based function, the regulatory analysis
and backfit analysis reflect costs associated with Watts Bar Unit 2 as well as those units
covered by the new applications that (like Watts Bar Unit 2) would co-locate new reactors
with currently operating reactors. For the new applications that would place new reactors at
sites that are not co-located with operating reactors, this analysis estimates that one-time
and annual impacts will be less than or equal to the corresponding impacts for operating
reactors (i.e., because the development of EP plans for the new sites will not require that
existing plans be analyzed and reworked). However, the quantitative results do not reflect
any additional incremental cost for the non-co-located reactors due to the uncertainty
associated with when and if these facilities actually will be licensed and operated.
Pre-Order Baseline Sensitivity Analysis. The regulatory analysis contains a sensitivity
analysis that, like the main analysis, estimates the incremental costs of the proposed rule,
but it assumes an alternative baseline consisting of only the regulations that were in effect
prior to (1) issuance of NRC Order EA-02-26 on February 25, 2002, and (2) voluntary
industry actions initiated in response to NRC Bulletin 2005-02. Relative to the pre-order
baseline, the proposed rule would result in a total one-time cost to all nuclear power plant
sites of approximately $61.5 million, followed by total annual costs on the order of $3.1
million. The total present value of these costs is estimated at $99.3 million (using a 7percent discount rate) and $120.6 million (using a 3-percent discount rate) over the next 30
years (see Section 4.2).
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Abbreviations
ANS
CFR
CRGR
EAL
EOF
EP
ERO
ETE
FEMA
ICM
LLEA
NRC
OMB
ORO
SRM
Alert and Notification System
Code of Federal Regulations
Committee to Review Generic Requirements
Emergency Action Level
Emergency Operations Facility
Emergency Preparedness
Emergency Response Organization
Evacuation Time Estimate
Federal Emergency Management Agency
Interim Safeguards and Security Compensatory Measure
Local Law Enforcement Agency
U.S. Nuclear Regulatory Commission
Office of Management and Budget
Offsite Response Organization
Staff Requirements Memorandum
Page 3
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
1.
Page 4
Introduction
This document presents a draft regulatory analysis of proposed enhancements to the
emergency preparedness (EP) requirements as set forth by the U.S. Nuclear Regulatory
Commission (NRC) in Title 10, Part 50, of the Code of Federal Regulations (10 CFR Part
50). The proposed rule would revise provisions contained in Sections 50.47, 50.54, and
Appendix E to Part 50. This introduction is divided into three sections. Section 1.1 states
the problem and the reasons for the proposed rulemaking, Section 1.2 provides background
information, and Section 1.3 discusses regulatory objectives related to adoption of the
proposed revisions to the proposed rule.
1.1
Statement of the Problem and Reasons for the Rulemaking
Following the terrorist events of September 11, 2001, the NRC staff evaluated the EP
planning basis given the resulting threat environment and concluded that it remains valid.
However, the NRC staff recognized that security events differ from accidental events and
that the EP regulations and guidance could be enhanced in this and other respects. In
addition, NRC staff reviewed existing EP regulations and guidance and identified
clarifications and enhancements to the regulations that recognize the benefits of advances
in communication technologies and lessons learned through EP program implementation.
While licensees have implemented significant enhancements to their EP programs in
response to the February 25, 2002, Commission Order, NRC Bulletin 2005-02, and various
NRC generic communications, the current regulations do not encompass these elements.
The NRC staff believes that EP regulations and guidance could be enhanced to better
reflect the security elements implemented in response to the attacks of September 11, 2001,
advances in technology, and lessons learned. Therefore, the NRC staff is proposing to
revise 10 CFR Part 50 to codify the inclusion of EP enhancements.
1.2
Background
1.2.1
Current Regulations Governing Emergency Preparedness (10 CFR Part 50)
10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities,” of the Code of
Federal Regulations (10 CFR Part 50), codifies a set of EP planning standards in
10 CFR 50.47(b) with supporting requirements in Appendix E, “Emergency Planning and
Preparedness for Production and Utilization Facilities,” to 10 CFR Part 50.
1.2.2
Commission Orders
The Commission imposed several security orders on all operating power reactor licensees
following September 11, 2001. On February 25, 2002, the NRC issued Order EA-02-26,
“Interim Safeguards and Security Compensatory Measures (ICMs),” to all license holders for
the operating commercial power reactors in the United States. Among other things, the
Order required licensees to implement ICMs for the present threat level and take actions
such as:
Review the security and emergency plans to maximize compatibility,
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
1.2.3
Page 5
Assess the adequacy of staffing plans at emergency response facilities, and for
licensees with an onsite emergency operations facility (EOF), identify alternative
facilities capable of supporting emergency response,
Develop plans, procedures and training regarding notification (including responding
employees), activation, and coordination between the site and offsite response
organizations (OROs),
Conduct a review to ensure that responders are not assigned collateral duties that
would prevent effective emergency response, and
Implement site-specific Emergency Action Levels (EALs) to provide an anticipatory
response to a credible threat.
NRC Bulletin 2005-02
The NRC issued Bulletin 2005-02, “Emergency Preparedness and Response Actions for
Security-Based Events,” to obtain information regarding changes nuclear power reactor
licensees made or were planning to make regarding security-based emergency
preparedness program capabilities and to evaluate how consistently such changes had
been implemented. Specifically, the Bulletin focused on gathering information from
licensees on five emergency preparedness topic areas: security-based emergency
classification levels and EALs; NRC notifications; onsite protective measures; emergency
response organization (ERO) augmentation; and drill and exercise programs.
Nuclear plant licensees all responded that they had implemented, or planned to implement,
the types of enhancements outlined in NRC Bulletin 2005-02. Further, the Nuclear Energy
Institute (NEI) developed a white paper titled “Enhancements to Emergency Preparedness
Programs for Hostile Action,” issued May 2005 (revised November 18, 2005). The NRC
staff endorsed this guidance in Regulatory Issue Summary (RIS) 2006-12, dated July 19,
2006, as an acceptable implementation methodology for the program enhancements
discussed in NRC Bulletin 2005-02. However, these enhancements are voluntary. The
NRC currently does not regard these voluntary actions in the licensing basis of the plants.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
1.2.4
Page 6
NRC Guidance Documents
NUREG-0654/FEMA-REP-1, “Criteria for Preparation and Evaluation of Radiological
Emergency Response Plans and Preparedness in Support of Nuclear Power Plants” (herein
referred to as NUREG-0654) is the joint NRC and Federal Emergency Management Agency
(FEMA) guidance that provides a basis for NRC licensees and State and local governments
to develop radiological emergency plans and improve emergency preparedness. It also is
used by reviewers to determine the adequacy of State, local, and nuclear power plant
licensee emergency plans and preparedness. NUREG-0654 provides guidance for each of
the planning standards found in 10 CFR 50.47(b). Regulatory Guide 1.101, “Emergency
Planning and Preparedness for Nuclear Power Reactors,” Revision 2, issued October 1981,
endorsed NUREG-0654/FEMA-REP-1, Revision 1. Regulatory Guide 1.101 provides
guidance to licensees and applicants on methods acceptable to the NRC staff for complying
with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency
response plans. Regulatory guides are not substitutes for regulations, and compliance with
them is not required. Licensees and applicants may propose methods and solutions
different from those specified in the guides if they provide a basis for the findings required
for the issuance of a license by the Commission.
1.3
Regulatory Objectives
The NRC’s objectives for the current rulemaking are to (1) codify emergency preparedness
requirements imposed by Commission order after the terrorist attacks of September 11,
2001, as modified based upon experience and insights gained by the Commission during
implementation, (2) codify emergency preparedness and response enhancements
discussed within NRC Bulletin 2005-02, and (3) add several new requirements that resulted
from NRC staff review of EP regulations and guidance.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
2.
Page 7
Identification and Preliminary Analysis of Alternative
Approaches
Prior to the rulemaking, the NRC staff conducted an extensive review of EP regulations and
guidance and developed numerous recommendations. The NRC staff presented the
analysis and recommendations to the Commission in SECY-06-0200, “Results of the
Review of Emergency Preparedness Regulations and Guidance,” dated September 20,
2006. SECY-06-0200 also prioritized the NRC staff’s recommendations using specified
criteria. The Commission, in a Staff Requirements Memorandum (SRM) dated January 8,
2007, approved a rulemaking effort for the various EP initiatives contained in
SECY-06-0200. In SECY-07-0182, “Semi-annual Update on the Status of Emergency
Preparedness Activities,” the NRC staff committed to first conduct rulemaking on the issues
identified as high-priority in SECY-06-0200.
Based on the preliminary analysis described above, the proposed rulemaking would revise
10 CFR 50.47, 50.54, and Appendix E to Part 50 to incorporate a total of 11 regulatory
initiatives:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Protection of onsite personnel
Emergency action levels for hostile action events
Hostile action event drills and exercises
Evacuation time estimate updating
Licensee coordination with offsite response organizations
On-shift multiple responsibilities
Emergency response organization augmentation and alternative facilities
Reduction in effectiveness
Emergency declaration timeliness
Emergency operations facility – performance-based approach
Backup means for alert and notification systems
The rulemaking would allow the NRC to achieve enhancements to emergency preparedness
at nuclear power plants as well as greater regulatory consistency across licensees.
The alternative to these initiatives is the “no-action alternative.” Under the no-action
alternative, NRC would not amend the current regulations regarding emergency
preparedness at nuclear power plant sites. Licensees would continue to comply with the
Commission’s Order and voluntary commitments from the generic communications. This
option would avoid certain costs that the proposed rule would impose. However, taking no
action would not enhance emergency preparedness based on recent experience, would not
enhance regulatory efficiency, and, moreover, would present a problem for establishing
appropriate emergency preparedness measures for new reactors that did not receive the
Commission Order or generic communications.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
3.
Page 8
Evaluation of Benefits and Costs
This section examines the benefits and costs expected to result from this rulemaking, and is
presented in two subsections. Section 3.1 identifies attributes that are expected to be
affected by the rulemaking. Section 3.2 describes how benefits and costs have been
analyzed.
3.1
Identification of Affected Attributes
This section identifies the factors within the public and private sectors that the regulatory
alternatives (discussed in Section 2) are expected to affect. These factors are classified as
“attributes” using the list of potential attributes provided by NRC in Chapter 5 of its
Regulatory Analysis Technical Evaluation Handbook. 1 Affected attributes include the
following:
Public Health (Accident) – The proposed action would reduce the risk that public
health will be affected by radiological releases resulting from an emergency.
Occupational Health (Accident) – The proposed action would reduce the risk that
occupational health will be affected by radiological releases resulting from
emergencies and by some hostile action events.
Industry Implementation – The proposed action would require licensees to make
facility modifications and to revise their emergency plans and procedures, among
other implementation activities.
Industry Operation – The proposed action would require licensees to conduct
additional emergency preparedness (EP) activities beyond those currently being
conducted. For example, licensees would need to track compliance over time with
NRC’s proposed hostile action event drill and exercise requirements.
NRC Implementation – Under the proposed action, NRC would develop or revise
guidance and inspection procedures as a result of the new requirements. Also, the
NRC would incur administrative costs to finalize the rulemaking.
NRC Operation – The proposed action would require the NRC to review biennial
exercise scenarios and updated evacuation time estimates for each site on an
ongoing basis.
Other government – The proposed action would result in one-time and annual costs
to other government agencies. FEMA and State and local government agencies
coordinate with NRC and licensees on EP activities. The proposed rule may require
these other government agencies to review and revise guidance and procedures,
and to conduct trainings.
1
Regulatory Analysis Technical Evaluation Handbook, Final Report, NUREG/BR-0184, Office of Nuclear
Regulatory Research, January 1997.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 9
Regulatory Efficiency – The proposed action would result in enhanced regulatory
efficiency through regulatory and compliance improvements.
Off-Site Property – The proposed action would reduce the risk that off-site property
will be affected by radiological releases resulting from emergencies.
On-Site Property – The proposed action would reduce the risk that on-site property
will be affected by radiological releases resulting from emergencies and some
hostile action events.
Attributes that are not expected to be affected under any of the rulemaking options include
the following: safeguards and security considerations; occupational health (routine); public
health (routine); environmental considerations; general public; improvements in knowledge;
and antitrust considerations.
3.2
Analytical Methodology
This section describes the process used to evaluate benefits and costs associated with the
various regulatory options. The benefits of the rule include any desirable changes in
affected attributes (e.g., monetary savings, improved safety resulting from new physical
protection requirements) while the costs include any undesirable changes in affected
attributes (e.g., monetary costs, increased exposures).
The analysis evaluates several attributes on a quantitative basis. (These include industry
implementation, industry operation, NRC implementation, NRC operation, other
government.) Quantitative analysis requires a baseline characterization of the universe,
including factors such as the number of licensees affected, the nature of the activities
currently being conducted, and the types of new or modified systems and procedures that
licensees will implement, or will no longer implement, as a result of the rule. In fact,
however, licensees may respond to the rule in different ways depending on their own
licensee-specific characteristics, such as (1) the physical characteristics of their sites, (2) the
current contents of their emergency plans, (3) the organizational and managerial
characteristics of their operations, (4) their approaches toward meeting new performancebased criteria, and (5) the characteristics of the local communities and their relationship with
the local communities. Sections 3.2.1–3.2.4 describe the most significant analytical data
and assumptions used in the quantitative analysis of these attributes. Additional details
regarding the calculations used in the analysis are presented in an appendix to the analysis.
The analysis relies on a primarily qualitative (rather than quantitative) evaluation of several
of the affected attributes (public health, occupational health, offsite property, and onsite
property) due to the difficulty in quantifying the impact of the current rulemaking. 2 These
attributes would be affected by the regulatory options through the associated increases in
effectiveness of emergency plans and emergency response activities. Quantification of any
of these attributes would require estimation of factors such as (1) the frequency of various
types of emergencies and emergency events, (2) the radiological consequences of such
emergencies, and (3) pre-rule and post-rule impacts associated with such emergencies and
hostile action events.
2
The regulatory efficiency attribute also is evaluated qualitatively, by definition. See NRC’s Regulatory Analysis
Technical Evaluation Handbook, Section 5.5.14.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
3.2.1
Page 10
Baselines for Analysis
This regulatory analysis measures the incremental impacts of the final rule relative to a
“baseline,” which reflects anticipated behavior in the event that the final regulation is not
imposed. The primary baseline used in this analysis assumes full licensee compliance with
existing NRC requirements, including current regulations, relevant orders, and voluntary
industry actions initiated in response to NRC Bulletin 2005-02. Section 4.1 presents the
estimated incremental costs and savings of the proposed rule relative to this baseline.
Unless otherwise noted, the estimated costs and savings presented in this document reflect
this baseline and are referred to as the “main analysis.”
The NRC staff also has prepared a sensitivity analysis as part of this regulatory analysis, in
accordance with the agency’s regulatory analysis guidelines. The sensitivity analysis, like
the main analysis, estimates the incremental savings and costs of the proposed rule, but it
assumes an alternative baseline consisting of only the regulations that were in effect before
(1) issuance of NRC Order EA-02-26 on February 25, 2002, and (2) voluntary industry
actions initiated in response to NRC Bulletin 2005-02. This analysis is referred to as the
“pre-order baseline analysis,” and its results appear in Section 4.2.
3.2.2
EP Programs and Program Characteristics
The analysis models 65 sites administering a total of 104 operating power reactors. It
assumes that incremental costs and savings accrue to sites independent of the number of
reactor facilities located at each site. It also assumes that the manner in which operating
reactors comply with current EP requirements is substantially similar (except as indicated in
Appendix A) and that all operating nuclear power reactors are in full compliance with the
applicable baseline requirements. As a result, the analysis applies the same average cost
per activity to each site, even though in reality some sites will incur higher or lower costs.
Each operating licensee is assumed to apply for and receive a single 20-year license
extension. Based on the extended license expiration dates, the analysis calculates the
average remaining operating life across all reactors as 30 years. Therefore, costs and
savings are estimated for the 65 reactor sites over a 30-year period, with each year’s costs
or savings discounted back at a 7-percent and 3-percent discount rate, in accordance with
NUREG/BR-0058, Rev. 4, “Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory
Commission.” (See Section 4.1 for these results.)
The proposed rule also would apply to any new reactors brought online after promulgation of
the final rule. Watts Bar Unit 2 is assumed to be one such reactor. In addition, NRC has
received applications to build other nuclear power reactors. For Watts Bar Unit 2 and the
new applications that (like Watts Bar Unit 2) would co-locate new reactors with currently
operating reactors, this analysis assumes that there is no significant additional incremental
cost or saving incurred (because EP program costs are primarily a site-based function,
rather than a reactor-based function). For the new applications that would place new
reactors at sites that are not co-located with operating reactors, this analysis estimates that
one-time and annual impacts will be less than or equal to the corresponding impacts for
operating reactors (i.e., because the development of EP plans for the new sites will not
require that existing plans be analyzed and reworked). Nevertheless, Section 4 does not
reflect any additional incremental cost for the non-co-located reactors due to the uncertainty
associated with when and if these facilities actually will be licensed and operated.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 11
The proposed rule also makes a conforming change to Part 52 that affects combined license
applicants. The conforming change points applicants to the EP requirements in Part 50,
Appendix E, instead of the EP requirements in Section 50.34(f). The NRC staff believes that
this change will have a cost impact only for combined license applications that have been or
will have been submitted prior to promulgation of this proposed rule. Specifically,
applications may cite Section 50.34(f) as the regulatory basis for some of the EP features
disclosed in the application. Under the proposed rule, these applications instead would
need to cite Part 50, Appendix E as the regulatory basis. NRC estimates that the cost
impact associated with this revision is insignificant relative to the overall cost of the
proposed rule.
In addition, one of the proposed rule’s regulatory initiatives would apply to non-power
reactor licensees. 3 As a result, the analysis also models the cost incurred by the 32
operating non-power reactors.
3.2.3
Incremental Requirements in the Final Rule
The NRC evaluated each of the 11 regulatory initiatives contained in the proposed rule
relative to the applicable baselines described in Section 3.2.1. Based on this analysis, the
NRC developed equations to estimate costs and savings using available data, augmented
by assumptions when necessary. Appendix A documents this analysis, including the
specific equations used to quantify costs and savings.
3.2.4
Other Data and Assumptions
Information on operating non-power reactors, power reactors, and shutdown dates has been
taken from NUREG-1350, Vol. 20, NRC Information Digest, 2008-2009 Edition. To the
extent practical, quantitative information (e.g., costs and savings) and qualitative information
(e.g., the nature and magnitude of impacts) on attributes affected by the rule has been
obtained from, or developed in consultation with, NRC staff. The analysis also considered
input provided by stakeholders at public meetings.
The analysis assumes that the final rule would become effective in December 2010, and
that any one-time implementation costs are incurred during the first year. Ongoing (annual)
costs of operation are assumed to begin in 2010, and are modeled on an annual cost basis.
Costs and savings are expressed in 2009 dollars.
3
Reduction in Effectiveness applies to both nuclear power reactor and non-power reactor licensees. See
Section 4.1.8 and Appendix A.8.b.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
4.
Page 12
Results
This section presents the analytical results which are organized into five separate sections:
Section 4.1 presents results on the benefits and costs of the rule as a whole under
the main analysis, as well as disaggregated results for each of the 11 regulatory
initiatives that comprise the rule.
Section 4.2 presents the results of the analysis under the pre-order baseline.
Section 4.3 considers the findings relative to NRC’s backfit rule.
Section 4.4 addresses the applicability of a safety goal evaluation to the current
rulemaking.
Section 4.5 describes the information required for review by the Committee to
Review Generic Requirements (CRGR).
4.1
Benefits and Costs Under the Main Analysis
This section summarizes the benefits and costs estimated for each regulatory initiative and
for the rule as a whole. To the extent that the affected attributes could be analyzed
quantitatively, the net effect of each option has been calculated and is presented below.
However, some benefits and costs could be evaluated only on a qualitative basis.
Exhibits 4-1 and 4-2 summarize the results for the proposed rule as a whole, and Exhibit 4-3
shows the incremental costs for each of the 11 regulatory initiatives contained in the
proposed rule. 4 Relative to the no-action alternative (Option 1), the rule as a whole
(Option 2) would result in a net quantitative cost estimated between $71.9 million and
$94.2 million (7-percent and 3-percent discount rate, respectively). The majority of the costs
associated with Option 2 will be incurred by industry ($67.4 million - $88.7 million, 7-percent
and 3-percent discount rate, respectively).
The analysis estimates that Option 2 would result in qualitative benefits in the following
attributes: public health (accident), occupational health (accident), regulatory efficiency, offsite property, and on-site property. Specifically, the benefits would include a reduced risk
that public health and occupational health will be affected by radiological releases resulting
from radiological emergencies, including hostile action events. There also would be
enhanced regulatory efficiency through regulatory and compliance improvements, including
changes in industry's planning efforts and in NRC's review and inspection efforts.
The proposed rule also would reduce the risk that off-site and on-site property will be
affected by radiological releases resulting from emergencies, including hostile action events.
4
Note that the totals shown in Exhibit 4-2 exceed those shown in Exhibit 4-3. The reason for this is that
Exhibit 4-2 includes certain costs that cannot be attributed to a particular regulatory initiative. In particular,
Exhibit 4-2 includes the remaining cost of the rulemaking as part of NRC implementation costs. The NRC
estimates that the remaining cost to finalize the rulemaking is approximately $237,000 (assuming a level of effort
of 1.5 FTE and a labor rate of $158,000).
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 13
Although EP cannot affect the probability of the initiating hostile action event, a high level of
EP increases the likelihood of accident mitigation if the initiating event proceeds beyond the
need for initial operator actions. An augmented EP program reduces the risk that off-site
and on-site property will be affected by radiological releases by improving the response to
initiating events that could lead to severe accidents in the absence of mitigative response.
Exhibit 4-1
Summary of Overall Benefits and Costs
Net Monetary Savings (or Costs) Total Present Value
Non-Monetary Benefits/Costs
Option 1: No Action
Qualitative Benefits and Costs:
$0
None.
Option 2: Proposed Action
Qualitative Benefits:
Industry:
($67.4 million) using a 7% discount rate
($88.7 million) using a 3% discount rate
Public Health (Accident): Reduced risk that public health will be
affected by radiological releases resulting from radiological
emergencies.
NRC:
($2.3 million) using a 7% discount rate
($3.0 million) using a 3% discount rate
Occupational Health (Accident): Reduced risk that occupational health
will be affected by radiological releases resulting from radiological
emergencies and some hostile action events.
Other Government:
($2.2 million) using a 7% discount rate
($2.5 million) using a 3% discount rate
Regulatory Efficiency: Enhanced regulatory efficiency through
regulatory and compliance improvements, including changes in
industry's planning efforts and in NRC's review and inspection efforts.
Off-Site Property: Reduced risk that off-site property will be affected by
radiological releases resulting from radiological emergencies.
On-Site Property: Reduced risk that on-site property will be affected by
radiological releases resulting from radiological emergencies and some
hostile action events.
Qualitative Costs:
None.
Exhibit 4-2
Summary of One-Time, Annual, and Overall Benefits and Costs
Total Savings and Costs
Average per
Nuclear Power
Plant Site
One-Time
Annual
Saving
Saving
(Cost)
(Cost)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
Average per
Non-Power Reactor
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
($29,497,300)
($3,084,700)
($67,370,241)
($88,687,926)
($446,912)
($47,457)
($14,000)
$0
NRC
($1,076,600)
($100,400)
($2,309,278)
($3,003,121)
n/a
n/a
n/a
n/a
Other
Government
($1,762,800)
($36,400)
($2,209,707)
($2,461,260)
n/a
n/a
n/a
n/a
($32,336,700)
($3,221,500)
($71,889,227)
($94,152,306)
($446,912)
($47,457)
($14,000)
$0
Entity
Industry
Total
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 14
Exhibit 4-3
Summary of One-Time, Annual, and Overall Benefits and Costs,
by Regulatory Initiative
Average per Site
Total Savings and Costs
Section
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
One-Time
Saving
(Cost)
($2,613,000)
($18,800)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
Protection of Onsite Personnel
$0
($2,613,000)
($2,613,000)
$0
($18,800)
($18,800)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($40,200)
n/a
$0
n/a
$0
$0
$0
$0
n/a
n/a
($2,631,800)
$0
($2,631,800)
($2,631,800)
($40,200)
$0
Emergency Action Levels for Hostile Action Events
($487,500)
$0
($487,500)
($487,500)
$0
$0
$0
$0
($7,500)
n/a
$0
n/a
$0
$0
$0
$0
n/a
n/a
($487,500)
$0
($487,500)
($487,500)
($7,500)
$0
($12,800)
n/a
($7,200)
n/a
($832,000)
($52,000)
Hostile Action Event Drills and Exercises
($468,000)
($6,577,951)
($9,812,197)
($64,000)
($837,771)
($1,280,061)
$0
$0
$0
$0
n/a
n/a
($884,000)
($532,000)
($7,415,723)
($11,092,258)
($12,800)
($7,200)
Evacuation Time Estimate Updating
($1,435,200)
($24,562,918)
($34,481,270)
($36,400)
($955,307)
($1,206,860)
($106,800)
n/a
($22,080)
n/a
($6,942,000)
($508,400)
($364,000)
($36,400)
($810,907)
($1,062,460)
n/a
n/a
($7,814,400)
($1,508,000)
($26,329,132)
($36,750,590)
($106,800)
($22,080)
Licensee Coordination with Offsite Response Organizations
($988,000)
$0
($988,000)
($988,000)
($15,200)
($29,600)
$0
($29,600)
($29,600)
n/a
$0
n/a
($783,600)
($1,801,200)
($2,782,000)
($65,600)
$0
($783,600)
($783,600)
n/a
n/a
$0
($1,801,200)
($1,801,200)
($15,200)
$0
On-Shift Multiple Responsibilities
$0
($2,782,000)
($2,782,000)
$0
($65,600)
($65,600)
($42,800)
n/a
$0
n/a
$0
$0
$0
$0
n/a
n/a
($2,847,600)
$0
($2,847,600)
($2,847,600)
($42,800)
$0
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Total Savings and Costs
Section
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Industry
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
Average per Site
NPV
(3 percent)
One-Time
Saving
(Cost)
Emergency Response Organization Augmentation and Alternative Facilities
($1,417,000)
($65,000)
($2,215,049)
($2,664,250)
($21,800)
($28,000)
$0
($28,000)
($28,000)
n/a
$0
$0
$0
Page 15
$0
Annual
Saving
(Cost)
($1,000)
n/a
n/a
n/a
($1,445,000)
($65,000)
($2,243,049)
($2,692,250)
Reduction in Effectiveness – Power Reactor Licensees
($21,800)
($1,000)
($1,183,000)
($52,000)
($6,500)
$0
($1,262,805)
($52,000)
($1,307,725)
($52,000)
($18,200)
n/a
($100)
n/a
$0
$0
$0
$0
n/a
n/a
($1,235,000)
($6,500)
($1,314,805)
($1,359,725)
($18,200)
Reduction in Effectiveness – Non-Power Reactor Licensees
($100)
($448,000)
$0
($448,000)
($448,000)
($14,000)
$0
$0
$0
$0
$0
n/a
n/a
NRC
Other
Government
Subtotal
$0
$0
$0
$0
n/a
n/a
($448,000)
$0
($448,000)
($448,000)
($14,000)
$0
Industry
NRC
($286,000)
($15,600)
Emergency Declaration Timeliness
$0
($286,000)
($286,000)
$0
($15,600)
($15,600)
($4,400)
n/a
$0
n/a
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
$0
$0
$0
$0
n/a
n/a
($301,600)
$0
($301,600)
($301,600)
($4,400)
$0
$0
n/a
$0
n/a
Emergency Operations Facility - Performance Based Approach
$0
$0
$0
$0
($54,000)
$0
($54,000)
($54,000)
$0
$0
$0
$0
n/a
n/a
($54,000)
$0
($54,000)
($54,000)
$0
$0
($177,212)
n/a
($17,077)
n/a
Backup Means for Alert and Notification Systems (ANS)
($11,518,800) ($1,110,000)
($25,147,018)
($32,817,985)
($15,600)
$0
($15,600)
($15,600)
($615,200)
$0
($615,200)
($615,200)
n/a
n/a
($12,149,600)
($1,110,000)
($25,777,818)
($33,448,785)
($177,212)
($17,077)
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Total Savings and Costs
One-Time
Saving
(Cost)
Section
Annual
Saving
(Cost)
NPV
(7 percent)
Page 16
Average per Site
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
Nuclear Power
Plant:
Nuclear
Power Plant:
($446,912)
($49,728)
Non-Power
Reactor:
Non-Power
Reactor:
TOTAL
Industry
($29,497,300)
NRC
Other
Government
($3,232,300)
($69,182,426)
($91,520,142)
($839,600)
($192,400)
($3,201,824)
($4,531,459)
($119,600)
n/a
$0
n/a
($1,762,800)
($36,400)
($2,209,707)
($2,461,260)
n/a
n/a
Nuclear Power
Plant:
Nuclear
Power
Plant:
($446,912)
Total
($32,099,700)
($3,221,500)
($71,652,227)
($93,915,306)
Non-Power
Reactor:
($14,000)
($47,457)
Non-Power
Reactor:
$0
*Results in 2009 dollars.
**Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which
is shown above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.1
Protection of Onsite Personnel
The new measures for protection of onsite personnel would protect onsite emergency
responders and other onsite personnel in emergencies resulting from hostile actions. The
NRC conducted analyses following the terrorist attacks of September 11, 2001, and
determined that the current guidance for protection of personnel during an emergency would
not be protective in hostile action scenarios. A lack of protection for emergency responders
who are expected to implement the emergency plan could result in the plan not being
implemented as required. These emergency responders are best able to mitigate any
damage caused by the hostile action and to provide notifications to offsite response
organizations to consider protective actions for the public should such be necessary. A lack
of protection for onsite emergency responders could result in the responders not being able
to provide an adequate protective response during hostile action scenarios. The proposed
rule would require licensees to develop new protective measures, such as evacuating
personnel from target buildings, taking cover during an armed attack, accounting for
personnel after an attack, and providing emergency response training. The primary benefit
of this initiative, therefore, would be potentially saving lives and reducing exposures during
an event, including a hostile action event, both in terms of the emergency responders and
the local population.
Total Cost to Industry. The proposed regulatory initiative would result in a total onetime cost to all power reactor licensees of approximately $2.6 million over the next
30 years.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 17
Average Cost per Site. The average nuclear power plant site, which may include
multiple units, would incur a one-time cost of approximately $40,000.
Costs to NRC. The regulatory initiative would result in a one-time cost to NRC of
approximately $19,000.
Decision Rationale. Although the NRC did not quantify the benefits of this provision,
the NRC staff did qualitatively examine benefits and concluded that the provision
would provide health and safety-related benefits, as discussed above. The NRC
believes that the regulatory initiative is cost-justified because, in the event of a
hostile action event, the provision potentially will result in significant saving of lives
and reduction in exposures for onsite personnel. Appendix A.1 presents more
detailed information on the costs for the protection of onsite personnel regulatory
initiative.
Total Savings and Costs
Entity
Industry
NRC
Other
Government
Subtotal
Average per Site
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($2,613,000)
($18,800)
$0
$0
($2,613,000)
($18,800)
($2,613,000)
($18,800)
($40,200)
n/a
$0
n/a
$0
$0
$0
$0
n/a
n/a
($2,631,800)
$0
($2,631,800)
($2,631,800)
($40,200)
$0
Appendix A.1 presents additional detail on the cost analysis for the regulatory initiative addressing protection of onsite personnel.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.2
Emergency Action Levels for Hostile Action Events
This proposed regulatory initiative would codify generically applicable requirements similar
to those imposed by the anticipatory EALs of the ICM Order and industry initiatives
responding to NRC Bulletin 2005-02. In the aftermath of the terrorist attacks of
September 11, 2001, the staff became aware that the currently approved nuclear plant EALs
may not appropriately characterize hostile actions. Changes to EALs were warranted due to
the potentially rapid and purposefully damaging nature of hostile actions. Without proper
declaration of emergencies based on hostile action, OROs may not receive adequate and
timely notification and the ERO may not activate in a timely manner to provide an adequate
protective response during hostile action scenarios. The proposed regulatory initiative
would increase assurance that licensees are adequately prepared to conduct appropriate
assessment and emergency classification during a hostile action-related event, thereby
resulting in emergency personnel onsite and offsite receiving proper notification to rapidly
respond with the appropriate resources. The benefit of these new proposed measures
would be to provide licensees and EROs more time to prepare for and respond to
emergency events, thereby potentially saving lives, radiation exposure and property.
Total Cost to Industry. The proposed regulatory initiative would result in a total
one-time cost to all power reactor licensees of approximately $488,000.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 18
Average Cost per Site. The average nuclear power plant site, which may include
multiple units, would incur a one-time cost of approximately $8,000.
Decision Rationale. Although the NRC did not quantify the benefits of this provision,
the NRC staff did qualitatively examine benefits and concluded that the provision
would provide health and safety-related benefits, as discussed above. The NRC
believes that the regulatory initiative is cost-justified because it would allow
emergency responders more time to coordinate a response effort in the event of a
hostile action-related emergency event. The additional time potentially would
enable emergency responders to save more lives.
Total Savings and Costs
Entity
Industry
NRC
Other
Government
Subtotal
Average per Site
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($487,500)
$0
$0
$0
($487,500)
$0
($487,500)
$0
($7,500)
n/a
$0
n/a
$0
$0
$0
$0
n/a
n/a
($487,500)
$0
($487,500)
($487,500)
($7,500)
$0
Appendix A.2 presents additional detail on the cost analysis for the regulatory initiative addressing EALs for hostile action events.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.3
Hostile Action Event Drills and Exercises
The hostile action event drills and exercises initiative originated from NRC Bulletin 2005-02,
as well as from an SRM issued on June 29, 2006. NRC regulations are designed to ensure
that licensee ERO personnel are prepared to respond to any emergency. Drill and exercise
programs are intended to ensure that ERO personnel develop and maintain the key skills
necessary for mitigating emergencies. In the aftermath of the terrorist attacks of
September 11, 2001, the staff became aware that hostile actions pose circumstances that
are different from the conditions traditionally practiced in EP drill and exercise programs.
The ERO is the primary organization trained to effectively mitigate damage caused by an
emergency and to notify OROs of the event and, if necessary, of the need to take protective
actions. Including hostile action events in licensee drill and exercise programs will better
prepare the ERO to respond to such events. This regulatory change would require
enhanced scenario content for drills and exercises to include hostile action scenarios, and
reduce preconditioning of licensee staff through a wider spectrum of challenges, thus
improving licensee ERO capabilities under all accident scenarios. The benefit would be
increased assurance that emergency plans would be implemented during any emergency
and as a result, improved protection of public health and safety during an emergency.
Total Cost to Industry. The proposed regulatory initiative would result in a total onetime cost to all power reactor licensees of approximately $832,000, followed by total
annual costs on the order of $468,000. The total present value of these costs is
estimated at approximately $6.6 million (using a 7-percent discount rate) and
$9.8 million (using a 3-percent discount rate) over the next 30 years.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 19
Average Cost per Site. The average nuclear power plant site, which may include
multiple units, would incur a one-time cost of approximately $13,000 followed by
annual costs of approximately $7,000.
Costs to NRC. The regulatory initiative would result in a one-time cost to NRC of
approximately $52,000, followed by annual costs of approximately $64,000. The
total present value of these NRC costs is estimated at $838,000 (using a 7-percent
discount rate) and $1.3 million (using a 3-percent discount rate).
Decision Rationale. Although the NRC did not quantify the benefits of this provision,
the NRC staff did qualitatively examine benefits and concluded that the provision
would provide health and safety-related benefits, as discussed above. The NRC
believes that the regulatory initiative is cost-justified because it would improve the
execution of EP plans and better protect public health and safety during an
emergency.
Total Savings and Costs
Entity
Industry
NRC
Other
Government
Subtotal
Average per Site
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($832,000)
($52,000)
($468,000)
($64,000)
($6,577,951)
($837,771)
($9,812,197)
($1,280,061)
($12,800)
n/a
($7,200)
n/a
$0
$0
$0
$0
n/a
n/a
($884,000)
($532,000)
($7,415,723)
($11,092,258)
($12,800)
($7,200)
Appendix A.3 presents additional detail on the cost analysis for the regulatory initiative addressing hostile action event drills and
exercises.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.4
Evacuation Time Estimate Updating
The purpose of evacuation time estimates (ETEs) is to analyze expected traffic flow during
an evacuation and identify any constraint that could challenge efficient evacuation. The
ETE facilitates evacuation planning to provide an adequate protective response in the
unlikely event of a severe accident. ETE results provide emergency planners information to
support protective action decisions, including whether evacuation or sheltering in place is
the better response to a severe accident. Existing EP regulations are ambiguous on
updating ETEs. The proposed changes to the regulations and guidance, which originated
from NRC staff review, would require the periodic review and updating of the ETEs as well
as information on evacuation plan improvements. The staff is in the process of changing its
guidance for the recommendation of protective actions to protect the public. The best
protective action strategy is conditional on the evacuation time for some accident scenarios.
ETEs performed in accordance with standard methods would improve the information used
for determining the best protective action strategy for each site. The primary benefit of this
change would be to aid in the development of the appropriate protective action strategy for
each site. In addition, the identification of potential evacuation challenges and the
consideration of methods to improve evacuation plans would lead to enhanced protection of
public health and safety.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 20
Total Cost to Industry. The proposed regulatory initiative would result in a total onetime cost to all power reactor licensees of approximately $6.9 million, followed by
total annual costs on the order of $1.4 million. The total present value of these costs
is estimated at approximately $24.6 million (using a 7-percent discount rate) and
$34.5 million (using a 3-percent discount rate) over the next 30 years.
Average Cost per Site. The average nuclear power plant site, which may include
multiple units, would incur a one-time cost of approximately $107,000 followed by
annual costs of approximately $22,000.
Costs to NRC. The regulatory initiative would result in a one-time cost to NRC of
approximately $508,000, followed by annual costs of approximately $36,000. The
total present value of these NRC costs is estimated at $955,000 (using a 7-percent
discount rate) and $1.2 million (using a 3-percent discount rate).
Costs to Other Government Agencies. The rule would result in a one-time cost to
other government agencies of approximately $364,000, followed by annual costs of
approximately $36,000. The total present value of these other government costs is
estimated at $811,000 (using a 7-percent discount rate) and $1.1 million (using a
3-percent discount rate).
Decision Rationale. Although the NRC did not quantify the benefits of this provision,
the NRC staff did qualitatively examine benefits and concluded that the provision
would provide health and safety-related benefits, as discussed above. The NRC
believes that the regulatory initiative is cost-justified because it would result in
updated EP plans, more effective emergency responses, and better protection to the
local population in case of an emergency event.
Total Savings and Costs
Entity
Industry
NRC
Other
Government
Subtotal
Average per Site
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($6,942,000)
($508,400)
($1,435,200)
($36,400)
($24,562,918)
($955,307)
($34,481,270)
($1,206,860)
($106,800)
n/a
($22,080)
n/a
($364,000)
($36,400)
($810,907)
($1,062,460)
n/a
n/a
($7,814,400)
($1,508,000)
($26,329,132)
($36,750,590)
($106,800)
($22,080)
Appendix A.4 presents additional detail on the cost analysis for the regulatory initiative addressing ETE updating.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.5
Licensee Coordination with Offsite Response Organizations
This regulatory initiative originated in the Order and from the NRC staff’s observation of DHS
Comprehensive Reviews. Currently, licensees are not explicitly required to coordinate with
OROs to ensure that ORO personnel are available to carry out planned actions, such as
traffic control and route alerting, during hostile action directed at a nuclear power plant. The
DHS Comprehensive Review program identified that at many sites OROs had not planned
for the competing resource demands that would occur during hostile action. The proposed
rule would require licensees to coordinate with OROs to ensure that offsite personnel are
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 21
available to carry out planned functions, such as traffic control, route alerting, etc., as
required when an emergency event occurs. The primary benefit would be to increase
assurance that adequate resources are available to respond to a hostile action event at a
nuclear power plant. This change enhances protection of public health and safety.
Total Cost to Industry. The regulatory initiative would result in a total one-time cost
to all power reactor licensees on the order of $988,000.
Average Cost per Site. The average nuclear power plant site, which may include
multiple units, would incur a one-time cost of approximately $15,000.
Costs to NRC. The proposed regulatory initiative would result in a one-time cost to
NRC of approximately $30,000.
Costs to Other Government Agencies. Additionally, the regulatory initiative would
result in a one-time cost to other government agencies of approximately $784,000.
Decision Rationale. Although the NRC did not quantify the benefits of this provision,
the NRC staff did qualitatively examine benefits and concluded that the provision
would provide health and safety-related benefits, as discussed above. The NRC
believes that the regulatory initiative is cost-justified because it would increase the
effectiveness of important aspects of the EP plan, thereby potentially saving lives in
the event of an emergency.
Total Savings and Costs
Entity
Industry
NRC
Other
Government
Subtotal
Average per Site
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($988,000)
($29,600)
$0
$0
($988,000)
($29,600)
($988,000)
($29,600)
($15,200)
n/a
$0
n/a
($783,600)
$0
($783,600)
($783,600)
n/a
n/a
($1,801,200)
$0
($1,801,200)
($1,801,200)
($15,200)
$0
Appendix A.5 presents additional detail on the cost analysis for the regulatory initiative addressing licensee coordination with
OROs.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.6
On-Shift Multiple Responsibilities
This regulatory initiative would codify generically applicable requirements similar to those
imposed by the 2002 ICM Order requirements limiting onshift staff multiple responsibilities
for individuals performing emergency plan functions. The proposed regulatory initiative
would increase assurance that appropriate shift resources are available for emergency plan
implementation so that during an emergency, licensees will be able to carry out their
emergency plans in timely fashion as needed to protect public health and safety. The lack
of adequate staff on shift has the potential to delay implementation of the emergency plan
during plant transients that may lead to an emergency. The primary benefit of this
requirement would be to increase assurance of effective and timely emergency plan
implementation and timely protective action recommendations to OROs, should that be
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 22
necessary. This would enhance protection of public health and safety in the event of an
emergency.
Total Cost to Industry. The proposed rule would result in a total one-time cost to all
power reactor licensees of approximately $2.8 million.
Average Cost per Site. The average nuclear power plant site, which may include
multiple units, would incur a one-time cost of approximately $43,000.
Costs to NRC. The regulatory initiative would result in a one-time cost to NRC of
approximately $66,000.
Decision Rationale. Although the NRC did not quantify the benefits of this provision,
the NRC staff did qualitatively examine benefits and concluded that the provision
would provide health and safety-related benefits, as discussed above. The NRC
believes that the regulatory initiative is cost-justified because it would reduce the
possibility that emergency plans would fail as a result of foreseeable conflicts
caused by multiple responsibilities. Therefore, the public would be better protected
because onsite staff would be able to better fulfill all aspects of the emergency plan,
and protective action recommendations to the states would be more timely and
accurate.
Total Savings and Costs
Entity
Industry
NRC
Other
Government
Subtotal
Average per Site
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($2,782,000)
($65,600)
$0
$0
($2,782,000)
($65,600)
($2,782,000)
($65,600)
($42,800)
n/a
$0
n/a
$0
$0
$0
$0
n/a
n/a
($2,847,600)
$0
($2,847,600)
($2,847,600)
($42,800)
$0
Appendix A.6 presents additional detail on the cost analysis for the regulatory initiative addressing on-shift multiple
responsibilities.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.7
Emergency Response Organization Augmentation and
Alternative Facilities
This regulatory initiative would codify generically applicable requirements for the use of an
alternative emergency response facility similar to those imposed by the Order and
addressed in NRC Bulletin 2005-02, which would protect ERO personnel from hostile action
and increase assurance of timely ERO augmentation so responders could travel quickly to
the site. In the event of a hostile-action event, it is possible that the onsite emergency
preparedness facilities may not be accessible by emergency response personnel, which
may prevent the ERO from taking the necessary actions to mitigate facility damage or
implementing measures to protect public health and safety. Alternative facilities provide a
place where the ERO can gather and prepare to enter the site as soon as it is safe to do so.
If the ERO cannot gather in a timely manner, the full augmentation of the on shift ERO
would be delayed. The alternative facility would be equipped to allow the ERO to begin
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 23
preparations for damage mitigation efforts when they can access the site. The primary
benefit of this regulatory initiative would be greater assurance that the emergency response
effort would be effective in the event that a hostile action compromises primary emergency
response facilities.
Total Cost to Industry. The regulatory initiative would result in a total one-time cost
to all power reactor licensees on the order of $1.4 million, followed by total annual
costs of approximately $65,000. The total present value of these costs is estimated
at $2.2 million (using a 7-percent discount rate) and $2.7 million (using a 3-percent
discount rate) over the next 30 years.
Average Cost per Site. The average nuclear power plant site, which may include
multiple units, would incur a one-time cost of approximately $22,000 followed by
annual costs of approximately $1,000.
Costs to NRC. The proposed regulatory initiative would result in a one-time cost to
NRC of approximately $28,000.
Decision Rationale. Although the NRC did not quantify the benefits of this provision,
the NRC staff did qualitatively examine benefits and concluded that the provision
would provide health and safety-related benefits, as discussed above. The NRC
believes that the regulatory initiative is cost-justified because it would increase
assurance that EP plans would be executed effectively in the event of hostile
actions, thereby better protecting public health and safety.
Total Savings and Costs
Entity
Industry
NRC
Other
Government
Subtotal
Average per Site
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($1,417,000)
($28,000)
($65,000)
$0
($2,215,049)
($28,000)
($2,664,250)
($28,000)
($21,800)
n/a
($1,000)
n/a
$0
$0
$0
$0
n/a
n/a
($1,445,000)
($65,000)
($2,243,049)
($2,692,250)
($21,800)
($1,000)
Appendix A.7 presents additional detail on the cost analysis for the regulatory initiative addressing ERO augmentation and
alternative facilities.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.8
Reduction in Effectiveness
Current regulations require licensees to “maintain in effect” their emergency plans. The
objective of this proposed regulatory initiative, which originated in NRC staff review and
would apply both to power reactors and non-power reactors, is not an improvement in
current safety, but rather ensuring that the current level of safety is not reduced by changes
to the emergency plan. The proposed rule would substantially clarify what changes would
reduce the effectiveness of the licensee’s plans, minimizing licensees’ uncertainty regarding
what changes would require prior NRC staff review and what changes would not. This
outcome, if achieved, would result in the following benefits:
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
-
Page 24
Facilitate the decision process for changes, resulting in less review and
evaluation time.
Minimize licensee’s exposure to potential violations for making changes
without needed prior NRC staff review.
Minimize the increasing trend by some licensees of avoiding enforcement
action by submitting all EP plan changes for NRC review, resulting in fewer
costs of submittal and NRC staff charges.
Total Cost to Industry. The proposed regulatory initiative would result in a total onetime cost to all power reactor licensees of approximately $1.2 million, followed by
total annual costs of about $7,000. In addition, the proposed regulatory initiative
would result in a one-time cost to non-power reactors of approximately $448,000.
Non-power reactors would not incur annual costs. The total present value of these
costs is estimated at $1.7 million (using a 7-percent discount rate) and $1.8 million
(using a 3-percent discount rate) over the next 30 years.
Average Cost per Site. The average nuclear power plant site, which may include
multiple units, would incur a one-time cost of approximately $18,000 followed by
annual costs of approximately $100. The average non-power reactor would incur a
one-time cost of approximately $14,000 and no annual costs.
Costs to NRC. The regulatory initiative would result in a one-time cost to NRC of
approximately $52,000, and no annual costs. The total present value of these NRC
costs is estimated at $52,000 (using a 7-percent or 3-percent discount rate).
Decision Rationale. Although the NRC did not quantify the benefits of this provision,
the NRC staff did qualitatively examine benefits and concluded that the provision
would provide health and safety-related benefits, as discussed above. The NRC
believes that the regulatory initiative is cost-justified because it would increase
assurance that current levels of safety are not reduced and the licensee’s
emergency plan, as modified, would continue to meet the requirements in
Appendix E to Part 50, and for nuclear power reactors, the planning standards of
10 CFR 50.47(b).
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Total Savings and Costs
Entity
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
Nuclear Power Reactor Licensees
Industry
($1,183,000)
($6,500)
NRC
($52,000)
$0
Other
$0
$0
Government
Non-Power Reactors
Industry
($448,000)
$0
NRC
$0
$0
Other
$0
$0
Government
($1,683,000)
($6,500)
Subtotal
Page 25
Average per Site
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($1,262,805)
($52,000)
($1,307,725)
($52,000)
($18,200)
n/a
($100)
n/a
$0
$0
n/a
n/a
($448,000)
$0
($448,000)
$0
($14,000)
n/a
$0
n/a
$0
$0
n/a
n/a
($1,762,805)
($1,807,725)
($32,200)
($100)
Appendix A.8 presents additional detail on the cost analysis for the regulatory initiative addressing reduction in effectiveness.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.9
Emergency Declaration Timeliness
Current emergency preparedness regulations do not establish timeliness criteria for the
emergency declaration process. This regulatory initiative, which originated from NRC staff
review, would require licensees to have the capability to classify and declare an emergency
within 15 minutes of the availability of information that an EAL has been or may be
exceeded. While this action already is largely conducted on a voluntary basis by the
industry, the NRC staff believes that codification of the rule would result in increased
assurance that the emergency plan will be effectively implemented. Thus, the objective of
the proposed regulatory initiative is to ensure that licensee emergency declarations are
performed in a timely manner so as to support timely implementation of emergency
response actions. The primary benefit would be to enhance the NRC’s assurance that
protective actions can be implemented on a timely basis, thereby protecting public health
and safety.
Total Cost to Industry. The regulatory initiative would result in a total one-time cost
to all power reactor licensees of approximately $286,000.
Average Cost per Site. The average nuclear power plant site, which may include
multiple units, would incur a one-time cost of approximately $4,000.
Costs to NRC. The proposed regulatory initiative would result in a one-time cost to
NRC of approximately $16,000.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 26
Decision Rationale. Although the NRC did not quantify the benefits of this provision,
the NRC staff did qualitatively examine benefits and concluded that the provision
would provide health and safety-related benefits, as discussed above. The NRC
believes that the regulatory initiative is cost-justified because it would increase
assurance in the ability of licensees to conduct timely emergency declarations in the
event of an emergency, which, in turn, would allow emergency personnel to respond
as quickly as possible to protect the public.
Total Savings and Costs
Entity
Industry
NRC
Other
Government
Subtotal
Average per Site
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($286,000)
($15,600)
$0
$0
($286,000)
($15,600)
($286,000)
($15,600)
($4,400)
n/a
$0
n/a
$0
$0
$0
$0
n/a
n/a
($301,600)
$0
($301,600)
($301,600)
($4,400)
$0
Appendix A.9 presents additional detail on the cost analysis for the regulatory initiative addressing the timeliness of emergency
declarations.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.10
Emergency Operations Facility – Performance-Based Approach
This proposed provision revises the EP regulations to make the requirements for emergency
operations facilities (EOFs) more performance-based. This regulatory initiative, which
originated from NRC staff review, would allow licensees to locate an EOF more than 25
miles from a site and multi-site licensees to consolidate their EOFs if those licensees can
demonstrate their emergency response strategies will adequately cope with an emergency
at any of the associated plants. The new measures would provide specific functional
requirements for EOFs, thereby ensuring that the necessary capabilities are in place for the
protection of public health and safety. The primary benefit of this provision is the reduction
in costs achieved by licensees that choose to locate their EOFs more than 25 miles from a
site or consolidate their EOFs.
Total Savings to Industry. The analysis assumes there are no incremental costs to
licensees for this regulatory initiative because the rule does not require location of
an EOF more than 25 miles from a site or consolidation of EOFs. Instead, a
licensee would voluntarily choose to pursue consolidation only if the incremental
savings exceed the incremental costs. These savings have not been quantified in
the analysis.
Costs to NRC. The regulatory initiative would result in a one-time cost to NRC of
approximately $54,000.
Decision Rationale. The NRC believes that the provision’s savings to licensees
would exceed the costs to the NRC and, therefore, that the provision is cost-justified.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Total Savings and Costs
Entity
Industry
NRC
Other
Government
Subtotal
Page 27
Average per Site
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
$0
($54,000)
$0
$0
$0
($54,000)
$0
($54,000)
$0
n/a
$0
n/a
$0
$0
$0
$0
n/a
n/a
($54,000)
$0
($54,000)
($54,000)
$0
$0
Appendix A.10 presents additional detail on the cost analysis for the regulatory initiative addressing the EOF performance-based
approach.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.1.11
Backup Means for Alert and Notification Systems (ANS)
This regulatory initiative, which originated from NRC staff review, would require licensees to
select and implement a backup method of alerting and notifying the public in the event that
the primary ANS is unavailable during an emergency. A backup means of alerting and
notifying the public increases the likelihood that an adequate protective response can be
implemented when the primary means of alert and notification is unavailable. The primary
benefit of this provision would be to provide increased assurance that the public will be
alerted and notified of any emergency event at the nuclear power plant, thereby increasing
the effectiveness of the emergency plan, saving lives, and increasing public safety and
confidence.
Total Cost to Industry. The proposed regulatory initiative would result in a total onetime cost to all power reactor licensees of approximately $11.5 million, followed by
total annual costs on the order of $1.1 million. The total present value of these costs
is estimated at $25.1 million (using a 7-percent discount rate) and $32.8 million
(using a 3-percent discount rate) over the next 30 years.
Average Cost per Site. The average nuclear power plant site, which may include
multiple units, would incur a one-time cost of approximately $177,000 followed by
annual costs of approximately $17,000.
Costs to NRC. The regulatory initiative would result in a one-time cost to NRC of
approximately $16,000.
Costs to Other Government Agencies. The regulatory initiative would result in a
one-time cost to other government agencies of approximately $615,000.
Decision Rationale. Although the NRC did not quantify the benefits of this
regulatory initiative, the NRC staff did qualitatively examine benefits and concluded
that the regulatory initiative would provide health and safety-related benefits, as
discussed above. The NRC believes that the regulatory initiative is cost-justified
because it would increase assurance that the local population would be notified of
emergency events, thereby increasing the effectiveness of the emergency plan,
saving lives, and increasing public confidence and safety. Appendix A.11 contains a
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 28
more detailed analysis of the costs associated with the backup means for ANS
provisions of the proposed rule.
Total Savings and Costs
Entity
Industry
NRC
Other
Government
Subtotal
Average per Site
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
NPV
(7 percent)
NPV
(3 percent)
One-Time
Saving
(Cost)
Annual
Saving
(Cost)
($11,518,800)
($15,600)
($1,110,000)
$0
($25,147,018)
($15,600)
($32,817,985)
($15,600)
($177,212)
n/a
($17,077)
n/a
($615,200)
$0
($615,200)
($615,200)
n/a
n/a
($12,149,600)
($1,110,000)
($25,777,818)
($33,448,785)
($177,212)
($17,077)
Appendix A.11 presents additional detail on the cost analysis for the regulatory initiative addressing the backup means for ANS.
Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site (which is shown
above) would be less than the cost per affected site (which is shown in Appendix A).
4.2
Sensitivity Analysis – Pre-Order Baseline
The NRC has performed a sensitivity analysis using an alternative baseline (called the
“pre-order baseline”) that considers the incremental costs of the proposed rule relative to
only those regulations that were in effect before the NRC issued Order EA-02-26 and
Bulletin 2005-02. The purpose of this sensitivity analysis is to account for relevant cost
impacts of the orders and post-Bulletin industry initiatives in addition to those that are
incremental to the proposed rule. These impacts already have been incurred, but they have
not previously been quantified. The key findings of the sensitivity analysis are presented
below:
Total Cost to Industry. The proposed rule would result in a total one-time cost to all
power reactor sites of approximately $61.5 million, followed by total annual costs on
the order of $3.1 million. The total present value of these costs is estimated at
$99.3 million (using a 7-percent discount rate) and $120.6 million (using a 3-percent
discount rate) over the next 30 years.
Average Cost per Site for Power Reactors. The average nuclear power plant site,
which may include multiple units, would incur a one-time cost of approximately
$939,000 followed by annual costs of approximately $47,000.
Average Cost per Site for Non-Power Reactors. The average non-power reactor
would incur a one-time cost of approximately $14,000. The proposed rule would not
impose any annual costs on non-power reactors.
Value of Benefits Not Reflected Above. With the exception of some monetary
savings to industry, the cost figures shown above do not reflect the value of the
benefits of the proposed rule. These benefits are evaluated qualitatively in
Section 4.1. (See Sections 4.1.1 - 4.1.11 for a detailed discussion on the benefits of
each regulatory initiative of the proposed rule.)
Costs to NRC. The rule would result in a one-time cost to NRC of approximately
$2.1 million, followed by annual costs of approximately $144,000. The total present
value of these costs is estimated at $3.6 million (using a 7-percent discount rate)
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 29
and $4.6 million (using a 3-percent discount rate). (These costs include NRC costs
to comply with each regulatory initiative plus the one-time administrative costs of
approximately $237,000 to finalize the rulemaking.)
Costs to Other Government Agencies. The proposed rule would result in a one-time
cost to other government agencies of approximately $6.2 million, followed by annual
costs of approximately $36,000. The total present value of these costs is estimated
at $6.7 million (using a 7-percent discount rate) and $6.9 million (using a 3-percent
discount rate).
Decision Rationale. Although the NRC did not quantify the benefits of this rule, the
NRC staff did qualitatively examine benefits and concluded that the rule would
provide substantial health and safety-related benefits. The NRC believes that the
rule is cost-justified because the proposed regulatory initiatives for increased and
consistent emergency preparedness measures would increase the effectiveness of
emergency planning and response efforts, thereby saving lives of emergency
personnel (in a hostile action-related event) and the public in the event of an
emergency (hostile action-related or non-hostile action-related). Exhibit 4-4 below
presents a more detailed cost analysis.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 30
Exhibit 4-4
Sensitivity Analysis under the Pre-Order Baseline:
Industry, NRC, and Other Government Savings and Costs, by Regulatory Initiative
Section
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
One-Time
Saving
(Cost)
($4,771,000)
($38,800)
$0
Total Savings and Costs
Annual
NPV
NPV
Saving
(7 percent)
(3 percent)
(Cost)
Protection of Onsite Personnel
$0
($4,771,000)
($4,771,000)
$0
($38,800)
($38,800)
$0
$0
$0
($4,809,800)
$0
($4,809,800)
($4,809,800)
Emergency Action Levels for Hostile Action Events
($6,428,500)
$0
($6,428,500)
($6,428,500)
($94,000)
$0
($94,000)
($94,000)
($143,000)
$0
($143,000)
($143,000)
($6,665,500)
$0
($6,665,500)
($6,665,500)
Hostile Action Event Drills and Exercises
($9,594,000)
($468,000)
($15,339,951)
($18,574,197)
($791,000)
($107,200)
($2,107,167)
($2,848,002)
($588,000)
($10,973,000)
($6,942,000)
($508,400)
($364,000)
$0
($588,000)
($588,000)
($575,200)
($18,035,118)
($22,010,199)
Evacuation Time Estimate Updating
($1,435,200) ($24,562,918)
($34,481,270)
($36,400)
($955,307)
($1,206,860)
($36,400)
($810,907)
($1,062,460)
Average per Site
One-Time
Annual
Saving
Saving
(Cost)
(Cost)
($73,400)
n/a
$0
n/a
n/a
n/a
($73,400)
$0
($98,900)
n/a
$0
n/a
n/a
n/a
($98,900)
$0
($147,600)
n/a
($7,200)
n/a
n/a
n/a
($147,600)
($7,200)
($106,800)
n/a
($22,080)
n/a
n/a
n/a
($7,814,400) ($1,508,000) ($26,329,132)
($36,750,590) ($106,800)
Licensee Coordination with Offsite Response Organizations
($5,850,000)
$0
($5,850,000)
($5,850,000)
($90,000)
($67,400)
$0
($67,400)
($67,400)
n/a
($4,527,600)
($10,445,000)
($10,309,000)
($103,400)
$0
($4,527,600)
($4,527,600)
$0
($10,445,000)
($10,445,000)
On-Shift Multiple Responsibilities
$0
($10,309,000)
($10,309,000)
$0
($103,400)
($103,400)
($22,080)
$0
n/a
n/a
n/a
($90,000)
$0
($158,600)
n/a
$0
n/a
$0
$0
$0
$0
n/a
n/a
($10,412,400)
$0
($10,412,400)
($10,412,400)
($158,600)
$0
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Section
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Total Savings and Costs
Average per Site
One-Time
Annual
One-Time
Annual
NPV
NPV
Saving
Saving
Saving
Saving
(7 percent)
(3 percent)
(Cost)
(Cost)
(Cost)
(Cost)
Emergency Response Organization Augmentation and Alternative Facilities
($2,925,000)
($65,000)
($3,723,049)
($4,172,250)
($45,000)
($1,000)
($75,800)
$0
($75,800)
($75,800)
n/a
n/a
$0
$0
$0
$0
$0
$0
$0
$0
n/a
($1,235,000)
($6,500)
($1,314,805)
($1,359,725)
($18,200)
Reduction in Effectiveness – Non-Power Reactor Licensees
($448,000)
$0
$0
$0
($448,000)
$0
($448,000)
$0
$0
$0
$0
$0
Industry
NRC
Other
Government
Subtotal
($1,488,500)
($15,600)
Industry
NRC
Other
Government
Subtotal
n/a
($3,000,800)
($65,000)
($3,798,849)
($4,248,050)
($45,000)
Reduction in Effectiveness – Nuclear Power Reactor Licensees
($1,183,000)
($6,500)
($1,262,805)
($1,307,725)
($18,200)
($52,000)
$0
($52,000)
($52,000)
n/a
Industry
NRC
Other
Government
Subtotal
Industry
NRC
Other
Government
Subtotal
Page 31
($448,000)
$0
$0
($448,000)
($448,000)
Emergency Declaration Timeliness
$0
($1,488,500)
($1,488,500)
$0
($15,600)
($15,600)
$0
$0
$0
$0
$0
$0
($1,000)
($100)
n/a
n/a
($100)
($14,000)
$0
n/a
n/a
n/a
($14,000)
n/a
$0
($22,900)
n/a
$0
n/a
n/a
n/a
($1,504,100)
$0
($1,504,100)
($1,504,100)
($22,900)
Emergency Operations Facility – Performance-Based Approach
$0
$0
$0
$0
$0
($54,000)
$0
($54,000)
($54,000)
n/a
$0
n/a
n/a
($54,000)
$0
($54,000)
($54,000)
$0
Backup Means for Alert and Notification Systems (ANS)
($11,518,800) ($1,110,000) ($25,147,018)
($32,817,985) ($177,212)
($15,600)
$0
($15,600)
($15,600)
n/a
$0
$0
n/a
n/a
$0
($17,077)
n/a
($615,200)
$0
($615,200)
($615,200)
n/a
n/a
($12,149,600)
($1,110,000)
($25,777,818)
($33,448,785)
($177,212)
($17,077)
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Section
One-Time
Saving
(Cost)
Total Savings and Costs
Annual
NPV
Saving
(7 percent)
(Cost)
TOTAL
NPV
(3 percent)
Industry
($61,457,800)
NRC
Other
Government
Total
($3,084,700)
($99,330,741)
Page 32
Average per Site
One-Time
Annual
Saving
Saving
(Cost)
(Cost)
Nuclear
Power Plant:
Nuclear
Power Plant:
($938,612)
($47,457)
Non-Power
Reactor:
Non-Power
Reactor:
($120,648,426)
($14,000)
$0
($1,816,000)
($143,600)
($3,579,074)
($4,571,462)
n/a
n/a
($6,237,800)
($36,400)
($6,684,707)
($6,936,260)
n/a
n/a
Nuclear
Power Plant:
Nuclear
Power Plant:
($938,612)
($47,457)
Non-Power
Reactor:
Non-Power
Reactor:
($14,000)
$0
($69,511,600)
($3,264,700)
($109,594,523)
($132,156,148)
Results in 2009 dollars.
4.3
Backfit Analysis
This section presents the NRC’s evaluation of changes in the proposed rule in accordance
with the Backfit Rule, 10 CFR 50.109. The backfit analysis examines the impacts of the rule
relative to the baseline used in the regulatory analysis, which consists of existing
requirements, the recently issued orders, and voluntary actions on part of the industry
subsequent to NRC Bulletin 2005-02.
The backfit analysis examines the aggregation of the subset of proposed regulatory
requirements that constitute backfits as defined in 10 CFR 50.109(a)(1). The analysis
excludes individual requirements that are not subject to the Backfit Rule or that do not fall
within the definition of “backfitting” as defined in the Backfit Rule, which include
requirements that fall into one or more of the following categories.
Administrative matters. Revisions that make minor administrative changes, such as
correction of typographic errors, correction of inconsistencies, relocating
requirements from one section to another, and combining existing requirements into
a single section.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 33
Information collection and reporting requirements. Revisions that either amend
existing information collection and reporting requirements or impose new information
and collection and reporting requirements, as set forth in the Committee to Review
Generic Requirements (CRGR) charter.
Clarifications. Revisions that clarify current requirements to assure consistent
understanding and implementation of the NRC’s original intent for these
requirements. These revisions remove the ambiguities that produced regulatory
uncertainty without changing the underlying requirements stated in these sections.
Permissive relaxations/Voluntary alternatives. Revisions that permit, but do not
require, relaxations or alternatives to current requirements (i.e., licensees are free to
either comply with current requirements or adopt the relaxed requirements/voluntary
alternative as a binding requirement).
With the exception of two proposed initiatives, one in Part 50, Appendix E, Section IV.E.8.
allowing a performance-based approach for the emergency operations facility (which results
in no cost to industry) and one in § 50.54(q) clarifying that licensees must submit for prior
NRC approval under 10 CFR 50.90 any proposed change to their emergency plans that
would reduce the effectiveness of the emergency plans, the entire proposed rule qualifies as
a backfit.
The NRC believes the proposed Reduction in Effectiveness amendment is not a change to
existing requirements. Some confusion exists as to whether all proposed emergency plan
changes submitted under § 50.4 would result in a reduction in effectiveness and whether
Commission review of such submissions is necessary. The NRC proposes to clarify that the
license amendment process is the correct process to use when reviewing submittals
involving a proposed emergency plan change that the licensee has determined constitutes a
reduction in effectiveness of the plan. The proposed rule language addresses this
clarification. As part of this clarification, power reactor and non-power reactor licensees
would need to review and possibly revise procedures and training to clarify the process for
emergency plan changes (i.e., through 10 CFR 50.90 submittals).
The proposed Reduction in Effectiveness rule language would not be a backfit. The Backfit
Rule protects licensees from Commission actions that arbitrarily change license terms and
conditions. A licensee’s request under 10 CFR 50.54(q) asks for Commission authority to
do what is not currently permitted under its license. The licensee has no valid expectations
protected by the Backfit Rule regarding the means for obtaining the new authority that is not
permitted under the current license.
In addition, to the extent that using a license amendment process for making modifications
to emergency plans that reduce the effectiveness of the plans is considered a change, it
would be a change to the NRC’s regulatory process for addressing modifications to the
emergency plan. The NRC’s regulatory review process is not a licensee procedure required
for operating a plant that would be subject to backfit limitations. For these reasons, this
clarification in 10 CFR 50.54(q) would not constitute a backfit under 10 CFR 50.109.
The NRC evaluated the aggregated set of requirements constituting backfits in accordance
with 10 CFR 50.109 to determine if the costs of implementing the rule would be justified by a
substantial increase in public health and safety or common defense and security. In
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 34
performing this analysis, the NRC considered the quantitative and qualitative costs and
benefits of the rule, as discussed below.
Collectively, the individual requirements in the proposed rule that qualify as backfits result in
an estimated net cost of approximately $65.7 million to industry over the next 30 years
(present value), assuming a 7-percent discount rate, or approximately $86.9 million
assuming a 3-percent discount rate.
For the average nuclear power plant site, these backfits would mean an initial one-time cost
of approximately $429,000, followed by annual costs of about $47,000 per year. For
industry as a whole, NRC estimates that the backfits would result in approximately $27.9
million in one-time costs, and about $3.1 million in annual costs.
With regard to emergency preparedness benefits afforded by the proposed rule’s provisions,
as documented in Section 4.1 of the regulatory analysis, the NRC considered them in
qualitative terms. NRC also qualitatively determined whether the costs of the rule would be
justified in light of the emergency preparedness benefits. In contrast, the NRC evaluated
costs in quantitative terms, as documented in Appendix A to the regulatory analysis.
In performing this analysis, the NRC considered the nine factors in 10 CFR 50.109, as
follows:
(1)
Statement of the specific objectives that the proposed backfit is designed to
achieve;
The rulemaking aims to enhance the current emergency preparedness
regulations pertaining to nuclear power reactors and non-power reactors.
The goals of the proposed rule would be as follows:
To enhance nuclear plant emergency preparedness by codifying the
requirements imposed by Commission orders issued after the terrorist
attacks of September 11, 2001, as modified based upon experience
and insights gained since implementation. These actions would
enhance the ability of nuclear plant EROs to respond to hostile action
and implement emergency plans and implement an adequate
protective response.
To enhance nuclear plant emergency preparedness by codifying the
enhancements implemented by industry on a voluntary basis
subsequent to the issuance of NRC Bulletin 2005-02. These actions
would enhance the ability of nuclear plant EROs to respond to hostile
action and implement an adequate protective response.
To enhance nuclear plant emergency preparedness by codifying
improvements to requirements in the areas of:
timeliness of declaration and the content of emergency action
level schemes;
survivability, facilities and resources for emergency response
organizations;
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
(2)
Page 35
alerting and notification of the public, evacuation planning and
adequate resources to implement evacuations; and,
training through drills and exercises that reflect the current
threat environment.
General description of the activity that would be required by the licensee or
applicant in order to complete the backfit;
In general terms, the proposed rule would ensure that all licensees
consistently implement new and existing emergency preparedness measures.
Detailed analysis of the activities and procedural changes required by the
proposed rule are set forth in Appendix A to the regulatory analysis. A
general description of each backfit is provided below:
Protection of Onsite Personnel
The proposed rule would require licensees to review and revise plans,
procedures, training, and guidance to address protective measures for onsite
personnel (e.g., evacuation of personnel from target buildings, accounting for
personnel after attack) in order to ensure that plant announcements are
timely and convey the onsite protective measures deemed appropriate. This
provision would affect power reactor licensees.
Emergency Action Levels for Hostile Action Events
The new measures would require licensees to review their existing
anticipatory EALs and update their plans, procedures, and training as needed
to confirm that they comply with the rule requirements. This provision would
affect power reactor licensees.
Hostile Action Event Drills and Exercises
The proposed rule language would require licensees to change how they
develop drill and exercise scenarios and make related changes to the
emergency plan. Specifically, the drill and exercise scenarios must be
designed to avoid biennial exercise scenarios that become predictable or
precondition emergency response organizations to expect a sequential
escalation of emergency classifications culminating in a large radiological
release. Licensees would need to submit these scenarios for NRC approval.
This provision would affect power reactor licensees.
Evacuation Time Estimate Updating and Exercises
The proposed rule would clarify the need for licensees to review and update
ETEs following the initial licensing of a nuclear power plant and to submit
them to NRC for review. Specifically, the proposed rule would establish a
requirement for licensees to update ETEs on a stated frequency (i.e., every
10 years) and when annual reviews show that the population increases or
decreases by 10 percent from the population that formed the basis for the
currently approved ETE. This provision would affect power reactor licensees.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 36
Licensee Coordination with Offsite Response Organizations (OROs)
The proposed rule would require licensees to coordinate with OROs to
increase assurance that adequate resources will be available and
pre-planned actions will be carried out when needed. Licensees would need
to review and revise plans, procedures, and training regarding notification,
activation, and coordination between site personnel and OROs. This
provision would affect power reactor licensees.
On-Shift Multiple Responsibilities
This change would require licensees to review and revise plans, procedures,
and training regarding assignment of multiple responsibilities, and to reassign responsibilities if necessary. This provision would affect power reactor
licensees.
Emergency Response Organization Augmentation and Alternative
Facilities
This change would require licensees to review and revise their plans,
procedures, and training regarding ERO augmentation during a hostile action
event. In addition, some sites may need to lease and/or equip a new facility
to serve as an alternative facility. This provision would affect power reactor
licensees.
Emergency Declaration Timeliness
Licensees are already complying with the proposed rule language via a
voluntary initiative that accomplishes the intent of the proposed rule.
Licensees, however, would need to review and confirm or (if necessary)
revise existing site procedures and training to reflect the revised rule. This
provision would affect power reactor licensees.
Backup Means for Alert and Notification Systems
The proposed rule would require licensees to select and implement a backup
method of alerting and notification to be used in the event that the primary
ANS is unavailable. This provision would affect power reactor licensees.
(3)
Potential change in the risk to the public from the accidental off-site release of
radioactive material;
The rulemaking would not directly affect the likelihood of core damage or
spent fuel damage. The rulemaking will provide added assurance that the
risk resulting from offsite releases remains acceptably low. Although EP
cannot affect the probability of the initiating event, a high level of EP
increases the likelihood of accident mitigation if the initiating event proceeds
beyond the need for initial operator actions. An augmented EP program
enhances the protection of public health and safety by improving the
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 37
response to initiating events that could lead to an accidental off-site release
of radioactive material in the absence of mitigative response.
(4)
Potential impact on radiological exposure of facility employees;
The rulemaking would not directly affect the likelihood of core damage or
spent fuel damage. The rulemaking would provide added assurance that
nuclear industry workers are not subjected to unnecessary radiological
exposures as the result of emergency situations, including hostile action
events.
(5)
Installation and continuing costs associated with the backfit, including the
cost of facility downtime or the cost of construction delay;
The backfit analysis for the proposed rule sets forth the NRC’s estimate of the
initial costs for implementing the major elements of the proposed rule, and the
ongoing costs to the licensees. The estimated one-time industry net cost
associated with the backfits would be approximately $27.9 million (or
approximately $429,000 for the average nuclear power plant site), and the
annually recurring cost would be approximately $3.1 million (or approximately
$47,000 for the average nuclear power plant program). Combining these
initial and annual costs, this analysis estimates that the backfits associated
with the proposed rule would cost industry approximately $65.7 million
(present value, assuming a 7-percent discount rate) to $86.9 million (present
value, assuming a 3-percent discount rate).
(6)
The potential safety impact of changes in plant or operational complexity,
including the relationship to proposed and existing regulatory requirements;
The proposed rule would make changes with respect to the design of a
nuclear power plant. Specifically, the changes involve the following:
Licensees must provide alternative facilities for use during hostile
action events when onsite facilities (technical support center and/or
EOF) are not available (e.g., due to emergency conditions).
Licensees must select and implement a backup method of alerting and
notification to be used in the event that the primary ANS is unavailable.
These design changes do not affect all nuclear power plants because some
currently meet these requirements. This rule is not expected to have a
significant effect on operational complexity beyond those reflected in the
estimated costs to licensees.
(7)
The estimated resource burden on the NRC associated with the proposed
backfit and the availability of such resources;
The majority of the one-time costs incurred by NRC come from reviewing and
revising guidance documents to comply with the proposed rule. NRC faces
additional costs to participate in EP exercise drills, review the emergency
plans, coordinate with FEMA, develop procedures for ETE reviews, and
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 38
review initial updates of ETEs. These activities would result in one-time costs
of approximately $734,000.
The NRC faces costs of annual operations to review biennial EP exercise
submittals and review ongoing updates of ETEs. These activities would
result in annual costs of approximately $100,000.
(8)
The potential impact of differences in facility type, design or age on the
relevancy and practicality of the proposed backfit;
For the nuclear power reactor licensees, the emergency preparedness
requirements in the proposed rule would not directly relate to the facility type,
design or age. Although the benefits and costs attributable to the proposed
rule would vary for a variety of site-specific reasons (e.g., local population,
transportation, and geography), the NRC does not believe they will vary
significantly based upon the nuclear power reactor’s facility type, design, or
age.
(9)
Whether the proposed backfit is interim or final and, if interim, the justification
for imposing the proposed backfit on an interim basis.
The proposed backfit, when implemented later at the final rule stage, would
be final.
In light of the substantial benefits of the proposed rule as summarized in Sections 4.1.14.1.11, the NRC finds that the backfits contained in the proposed rule, when considered in
the aggregate, would constitute a substantial increase in emergency preparedness.
4.4
Safety Goal Evaluation
Safety goal evaluations are applicable only to regulatory initiatives considered to be generic
safety enhancement backfits subject to the substantial additional protection standard at
10 CFR 50.109(a)(3). 5 A safety goal evaluation is designed to determine whether a
regulatory requirement should not be imposed generically on nuclear power plants because
the residual risk is already acceptably low. The current rulemaking would apply generically
to all reactors, and would provide added assurance that the public is protected from the
consequences of nuclear reactor operations. Some aspects of the rule may indirectly
qualify as generic safety enhancements because it is possible that they could indirectly
affect the likelihood of core damage or spent fuel damage, which generally are the focus of
a quantitative safety goal evaluation. However, the rulemaking would not directly affect the
likelihood of core damage or spent fuel damage because EP plans are not activated until
after a potential emergency situation has been identified. Therefore, a safety goal
evaluation is not appropriate for the proposed rule.
5
A safety goal evaluation is not needed, therefore, for new requirements falling within the backfit exceptions at
10 CFR 50.109(a)(4)(i)-(iii).
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
4.5
Page 39
CRGR Results
This section addresses regulatory analysis information requirements for rulemaking actions
or staff positions subject to review by the CRGR. All information called for by the CRGR is
presented in this regulatory analysis, or in the Federal Register Notice for the proposed rule.
As a reference aid, Exhibit 4-5 provides a cross-reference between the relevant information
and its location in this document or the Federal Register Notice.
Exhibit 4-5
Specific CRGR Regulatory Analysis Information Requirements
CRGR
Charter
Citation
Information Item to be Included in a Regulatory
Analysis Prepared for
CRGR Review
Where Item is Discussed
IV.B(1)
Proposed generic requirement or staff position as it is
proposed to be sent out to licensees. When the
objective or intended result of a proposed generic
requirement or staff position can be achieved by setting
a readily quantifiable standard that has an unambiguous
relationship to a readily measurable quantity and is
enforceable, the proposed requirements should specify
the objective or result to be attained rather than
prescribing how the objective or result is to be attained.
Proposed rule text in Federal
Register Notice.
IV.B(iii)
The sponsoring office’s position on whether the
proposed action would increase requirements or staff
positions, implement existing requirements or staff
positions, or relax or reduce existing requirements or
staff positions.
Regulatory Analysis, Section
4.1.
IV.B(iv)
The proposed method of implementation.
Regulatory Analysis, Section 6.
IV.B(vi)
Identification of the category of power reactors or nuclear
materials facilities/activities to which the generic
requirement or staff position will apply.
Regulatory Analysis, Section
3.2.2.
IV.B(vii)
IV.B(viii)
If the proposed action involves a power reactor backfit
and the exceptions at 10 CFR 50.109(a)(4) are not
applicable, the items required at 10 CFR 50.109(c) and
the required rationale at 10 CFR 50.109(a)(3) are to be
included.
Regulatory Analysis, Section
4.3.
IV.B(x)
For proposed relaxations or decreases in current
requirements or staff positions, a rationale is to be
included for the determination that (a) the public health
and safety and the common defense and security would
be adequately protected if the proposed reduction in
requirements or positions were implemented, and (b) the
cost savings attributed to the action would be substantial
enough to justify taking the action.
Federal Register Notice for the
proposed rule.
IV.B(xii)
Preparation of an assessment of how the proposed
action relates to the Commission’s Safety Goal Policy
Statement.
Regulatory Analysis, Section
4.4.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
5.
Decision Rationale
5.1
Regulatory Analysis
Page 40
Relative to the “no-action” alternative, the proposed rule as a whole would result in a net
cost estimated as approximately $71.9 million (total present value over a 30-year period),
assuming a 7-percent discount rate, or approximately $94.2 million assuming a 3-percent
discount rate. All of this cost would accrue to industry, except for approximately $2.3 million
(7 percent) or $3.0 million (3 percent) and approximately $2.2 million (7 percent) or
$2.5 million (3 percent) that would that would accrue to the NRC and other government
agencies, respectively. The rule would result in one-time industry costs of approximately
$29.5 million. This is equivalent to approximately $447,000 for the average power reactor
site, and $14,000 for the average non-power reactor. The proposed rule language would
generate annual industry costs of about $3.1 million ($47,000 per site). Offsetting this net
cost, the NRC believes that the rule would result in substantial non-quantified benefits
related to emergency preparedness, as well as enhanced regulatory efficiency and
effectiveness. The analysis discusses these benefits in Section 4.1 of this document.
Based on the NRC's assessment of the costs and benefits of the proposed rule on licensee
facilities, the agency has concluded that the proposed rule provisions would be justified.
5.2
Backfit Analysis
The NRC conducted a backfit analysis of the proposed rule relative to the backfit
requirements in 10 CFR 50.109. The proposed rule would constitute a backfit because it
would impose new requirements on licensees. These new measures include developing
measures and revising procedures and training related to protection of onsite personnel;
reviewing and revising plans, procedures, and training regarding EALs; revising drill and
exercise scenarios; reviewing and updating ETEs; requiring coordination with OROs;
reviewing plans, procedures, and training regarding the assignment of multiple
responsibilities; reviewing and revising plans, procedures, and training regarding ERO
augmentation; reviewing and revising existing site procedures and training to include new
timeliness requirements for emergency declarations; and selecting and implementing a
backup method of alerting and notification to be used in the event that the primary ANS is
unavailable. This falls under the definition of a backfit because such efforts would be new
and would be the result of a change in NRC’s position.
In light of the substantial benefits of the proposed rule as summarized in Sections 4.1.14.1.11, the NRC finds that the backfits contained in the proposed rule, when considered in
the aggregate, would constitute a substantial increase in emergency preparedness and
would be justified in view of this increased protection of the public health and safety.
Although EP cannot affect the probability of the initiating event, a high level of EP increases
the likelihood of accident mitigation if the initiating event proceeds beyond the need for initial
operator actions. An EP program, augmented in compliance with the proposed EP rule,
substantially enhances public health and safety by improving the licensee and ORO
response to events that could pose a threat to public health and safety.
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
6.
Page 41
Implementation
This section identifies how and when the proposed action would be implemented, the
required NRC actions to ensure implementation, and the impact on NRC resources.
6.1
Schedule
The NRC proposes to make the final rule effective 30 days after its publication in the
Federal Register. Licensees would be permitted to defer implementation of the final rule
until 180 days after publication of the final rule in the Federal Register, except for the
following proposed rule changes: (1) the requirements under proposed 10 CFR 50.54(q),
which would become effective 30 days after publication of the final rule in the Federal
Register; (2) the requirements under proposed Part 50, Appendix E, Section IV.F.2., which
each applicable licensee would be required to implement no later than its first biennial
exercise conducted more than one year after the effective date of the final rule; and (3) the
requirements under proposed Part 50, Appendix E, Section IV.D.3., which each applicable
licensee would be required to implement no later than its first biennial exercise conducted
more than one year after the effective date of the final rule.
6.2
Impacts on Other Requirements
As discussed in Section 4.1, affected licensees would experience most of the impact of the
revisions to the requirements. Nevertheless, the NRC expects the rulemaking would have a
noticeable impact on agency resources, both initially and annually thereafter. The most
significant impacts result from NRC’s need to complete the rulemaking, and to review and
revise guidance documents relating to the following issues:
Protection of Onsite Personnel
Emergency Action Levels for Hostile Action Events
Hostile Action Event Drills
Evacuation Time Estimate Updating and Exercises
Licensee Coordination with Offsite Response Organizations
On-Shift Multiple Responsibilities
Emergency Response Organization Augmentation and Alternative Facilities
Reduction in Effectiveness
Emergency Declaration Timeliness
Emergency Operations Facilities – Performance-Based Approach
Backup Means for Alert and Notification Systems
Regulatory Analysis: Proposed Revisions to Emergency Preparedness Requirements
Page 42
The NRC estimates that the remaining cost to finalize the rulemaking is approximately
$237,000. In addition to reviewing and revising guidance documents, the NRC faces
additional impacts to review the emergency plans and develop Temporary Instructions, and
interact with FEMA. Furthermore, the NRC must develop procedures for ETE reviews, and
review initial updates of ETEs. As shown in Exhibit 4.3, the one-time cost to NRC to comply
with the requirements set forth in the 11 initiatives is approximately $840,000. Also, the
NRC faces an impact from issuing a new regulatory guide clarifying the requirement that a
licensee must “maintain in effect” their emergency plan. All of the activities discussed above
would result in one-time costs of approximately $1.1 million.
Additionally, the NRC expects that the rulemaking would result in increased annual
expenditures of agency resources. The NRC faces annual costs to review biennial EP
exercise submittals and review ongoing updates of ETEs. These activities would result in
annual costs of approximately $100,000.
Appendix A:
Regulatory Analysis Assumptions and Inputs, by Regulatory Initiative
A.1: Protection of Onsite Personnel
NRC regulations do not currently require emergency plan provisions to protect onsite emergency responders and other onsite personnel in emergencies
resulting from hostile actions. The proposed rule would codify generically applicable requirements similar to the changes recommended in Bulletin 2005-02
requiring licensees to develop new protective measures (e.g., evacuation of personnel from target buildings, accounting for personnel after attack) and
revise their procedures and training to ensure plant announcements are timely and convey the onsite protective measures deemed appropriate.
Assumptions:
(1) Revised training materials (including content addressing onsite protective measures) would replace existing training materials.
(2) Revised procedures (including new onsite protective measures) would be integrated into the current drill and exercise program at an insignificant cost
to licensees.
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
INDUSTRY IMPLEMENTATION (ONE-TIME)
$200.00/hr
Executive
$150.00/hr
Manager
Develop new protective measures EP staff
$100.00/hr
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Executive
$150.00/hr
Manager
Review and revise emergency
$100.00/hr
EP staff
plan
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Executive
$150.00/hr
Manager
Review and revise existing
$100.00/hr
EP staff
procedures
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Executive
$150.00/hr
Manager
Review and revise training
$100.00/hr
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Executive
$150.00/hr
Manager
Coordinate and develop industry
$100.00/hr
EP staff
guidance (NEI White Paper)
$50.00/hr
Clerical
$100.00/hr
Licensing
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
None.
NRC IMPLEMENTATION (ONE-TIME)
$100.00/hr
Executive
Review and revise guidance
$100.00/hr
Manager
(industry guidance, NRC
$100.00/hr
Staff
inspection guidance, bulletin
$100.00/hr
Clerical
preparation)
$100.00/hr
Attorney
Total NRC Implementation Cost
NRC OPERATIONS (ANNUAL)
None.
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
None.
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
Sites
Affected
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
Savings
(Cost) Per
Site
Units
Additional Incremental Effort Due to
Proposed Rule
Units
Savings (Cost) Per
Site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
4 hrs/site
20 hrs/site
80 hrs/site
20 hrs/site
8 hrs/site
0 hrs/site
8 hrs/site
20 hrs/site
16 hrs/site
0 hrs/site
8 hrs/site
24 hrs/site
80 hrs/site
16 hrs/site
16 hrs/site
320 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(800)
(3,000)
(8,000)
(1,000)
(800)
(1,200)
(2,000)
(800)
(1,600)
(3,600)
(8,000)
(800)
(1,600)
(33,200)
8 hrs/site
20 hrs/site
80 hrs/site
8 hrs/site
8 hrs/site
8 hrs/site
20 hrs/site
80 hrs/site
8 hrs/site
8 hrs/site
4 hrs/site
20 hrs/site
40 hrs/site
20 hrs/site
8 hrs/site
0 hrs/site
4 hrs/site
20 hrs/site
8 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
372 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(1,600)
(3,000)
(8,000)
(400)
(800)
(1,600)
(3,000)
(8,000)
(400)
(800)
(800)
(3,000)
(4,000)
(1,000)
(800)
(600)
(2,000)
(400)
(40,200)
0 hrs
0 hrs
200 hrs
0 hrs
0 hrs
200 hrs
$
$
$
$
$
$
(20,000)
(20,000)
8 hrs
20 hrs
100 hrs
40 hrs
20 hrs
188 hrs
$
$
$
$
$
$
(800)
(2,000)
(10,000)
(4,000)
(2,000)
(18,800)
520 hrs
Notes:
(1) Hour estimates based on judgment of NRC staff.
(2) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
Page 1 of 15
560 hrs
A.2: Emergency Action Levels for Hostile Action Events
NRC regulations currently require an emergency classification and action level scheme for hostile action events. Historically, event declarations have been
based on actual threat information. The proposed rule would codify generically applicable requirements similar to the anticipatory EALs contained in the
Interim Compensatory Measures Order (EA-02-26) and the recommended changes in NRC Bulletin 2005-02 in Part 50, Appendix E to require event
declarations based on a credible future threats.
Assumptions:
(1) Current industry practice is sufficient to comply with the rule. Nonetheless, licensees would review their existing anticipatory EALs and training to
confirm that they comply with the rule requirements.
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
INDUSTRY IMPLEMENTATION (ONE-TIME)
$200.00/hr
Executive
$150.00/hr
Manager
Review existing EALs
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Executive
$150.00/hr
Manager
Review and revise EAL training
$100.00/hr
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Executive
$150.00/hr
Manager
Review and revise emergency
$100.00/hr
EP staff
plan
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Executive
$150.00/hr
Manager
Review and revise procedures
$100.00/hr
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Executive
Conduct initial EAL training (30
$150.00/hr
managers at 4 hour training; 12 security Manager
managers at 4 hour training; 50 ERO
$100.00/hr
EP staff
staff members at 2 hour training; one
$50.00/hr
Clerical
trainer per 30 trainees)
$100.00/hr
Licensing
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
None.
NRC IMPLEMENTATION (ONE-TIME)
Review and revise guidance (six Executive
$100.00/hr
month effort for Bulletin
$100.00/hr
Manager
preparation) and endorse security Staff
$100.00/hr
EALs in a regulatory guide
$100.00/hr
Clerical
$100.00/hr
Attorney
Total NRC Implementation
NRC OPERATIONS (ANNUAL)
None.
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
$100.00/hr
State and Local Government Executive
Conduct initial ORO training (10 Manager
$100.00/hr
staff per site at 2 hour training;
$100.00/hr
Staff
one trainer per 30 trainees)
$100.00/hr
Clerical
$100.00/hr
Attorney
Total State and Local Implementation Cost
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
Sites
Affected
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
Savings
(Cost) Per
Site
Units
Additional Incremental Effort Due to
Proposed Rule
Units
Savings (Cost) Per
Site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
8 hrs/site
80 hrs/site
8 hrs/site
0 hrs/site
2 hrs/site
24 hrs/site
80 hrs/site
16 hrs/site
16 hrs/site
4 hrs/site
40 hrs/site
200 hrs/site
40 hrs/site
16 hrs/site
0 hrs/site
176 hrs/site
104 hrs/site
4 hrs/site
0 hrs/site
818 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(1,200)
(8,000)
(400)
(400)
(3,600)
(8,000)
(800)
(1,600)
(800)
(6,000)
(20,000)
(2,000)
(1,600)
(26,400)
(10,400)
(200)
(91,400)
0 hrs/site
4 hrs/site
24 hrs/site
0 hrs/site
8 hrs/site
0 hrs/site
2 hrs/site
8 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
2 hrs/site
8 hrs/site
0 hrs/site
4 hrs/site
0 hrs/site
2 hrs/site
8 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
70 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(600)
(2,400)
(800)
(300)
(800)
(300)
(800)
(400)
(300)
(800)
(7,500)
100 hrs
120 hrs
560 hrs
60 hrs
100 hrs
940 hrs
$
$
$
$
$
$
(10,000)
(12,000)
(56,000)
(6,000)
(10,000)
(94,000)
0 hrs
0 hrs
0 hrs
0 hrs
0 hrs
0 hrs
$
$
$
$
$
$
-
0 hrs/site
0 hrs/site
22 hrs/site
0 hrs/site
0 hrs/site
22 hrs
$
$
$
$
$
$
(2,200)
(2,200)
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
$
$
$
$
$
$
-
1,780 hrs
Notes:
(1) Hour estimates based on judgment of NRC staff.
(2) State and Local Government labor rates assumed to be the same as NRC wage rates.
(3) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
Page 2 of 15
70 hrs
A.3: Hostile Action Event Drills and Exercises
The proposed rule language would adopt elements of NRC Bulletin 2005-02 and require licensees to revise drill and exercise scenarios. Specifically, the drill and
exercise scenarios would need to be designed to avoid biennial exercise scenarios that become predictable or precondition emergency response organizations to
expect a sequential escalation of emergency classifications culminating in a large radiological release. Licensees would need to submit these scenarios for NRC
approval. In addition, licensees would need to revise existing schemes to track implementation of the various scenario objectives.
Assumptions:
(1) All sites develop 6-year drill and exercise plans and conduct initial exercises by the end of CY09 in response to NRC Bulletin 2005-02.
(2) NRC would review emergency plan and scenarios as they are used by licensees (annual cost, assuming 32.5 are submitted per year).
Cost Inputs
Requirement
INDUSTRY IMPLEMENTATION (ONE-TIME)
Develop and review 6-year plan Executive
Manager
EP staff
Clerical
Licensing
Review and update emergency
Executive
plan and exercise objective
Manager
tracking scheme
EP staff
Clerical
Licensing
Conduct initial exercise (4
Executive
executives at 8 hour tabletop and Manager
exercise, 30 managers at 8 hour EP staff
tabletop and exercise; 100 ERO Clerical
and security staff members at 4 Licensing
hour exercise)
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
Track compliance with required
Executive
exercise scenario elements
Manager
EP staff
Clerical
Licensing
Executive
Submit scenario to NRC for
review
Manager
EP staff
Clerical
Licensing
Total Industry Operations Cost
Unit Cost
Sites
Affected
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
Incremental Effort Due to
Order & Bulletin
Savings
Units
(Cost) Per
Site
8 hrs/site
40 hrs/site
80 hrs/site
16 hrs/site
16 hrs/site
4 hrs/site
80 hrs/site
160 hrs/site
16 hrs/site
40 hrs/site
32 hrs/site
240 hrs/site
400 hrs/site
16 hrs/site
0 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
1,148 hrs/site
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
65
65
65
65
65
32.5
32.5
32.5
32.5
32.5
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
$
$
$
$
$
$
$
$
$
$
$
Page 3 of 15
Additional Incremental Effort Due to
Proposed Rule
Units
(1,600)
(6,000)
(8,000)
(800)
(1,600)
(800)
(12,000)
(16,000)
(800)
(4,000)
(6,400)
(36,000)
(40,000)
(800)
-
0 hrs/site
8 hrs/site
40 hrs/site
8 hrs/site
8 hrs/site
0 hrs/site
8 hrs/site
40 hrs/site
8 hrs/site
8 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
($134,800)
128 hrs/site
-
0 hrs/site
8 hrs/site
40 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
8 hrs/site
16 hrs/site
8 hrs/site
8 hrs/site
88 hrs/site
Savings (Cost) Per
Affected Site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(1,200)
(4,000)
(400)
(800)
(1,200)
(4,000)
(400)
(800)
($12,800)
$
$
$
$
$
$
$
$
$
$
(1,200)
(4,000)
(1,200)
(1,600)
(400)
(800)
($9,200)
Hostile Action Event Drills and Exercises (continued)
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
Sites
Affected
Units
Savings
(Cost) Per
Site
Additional Incremental Effort Due to
Proposed Rule
Units
NRC IMPLEMENTATION (ONE-TIME)
$100.00/hr
0 hrs
$
0 hrs
Review and revise guidance
Executive
Manager
(Bulletin preparation)
$100.00/hr
0 hrs
$
120 hrs
$100.00/hr
300 hrs
$
(30,000)
280 hrs
Staff
$100.00/hr
0 hrs
$
60 hrs
Clerical
$100.00/hr
0 hrs
$
60 hrs
Attorney
$100.00/hr
8 hrs
$
(800)
0 hrs
Compile RIS 2006-12 (review NEI Executive
White Paper)
$100.00/hr
16 hrs
$
(1,600)
0 hrs
Manager
$100.00/hr
360 hrs
$
(36,000)
0 hrs
Staff
$100.00/hr
8 hrs
$
(800)
0 hrs
Clerical
$100.00/hr
20
hrs
$
(2,000)
0
hrs
Attorney
Review NEI-06-04, Rev. 0
$100.00/hr
16
hrs
$
(1,600)
0
hrs
Executive
$100.00/hr
20 hrs
$
(2,000)
0 hrs
Manager
$100.00/hr
240 hrs
$
(24,000)
0 hrs
Staff
$100.00/hr
8 hrs
$
(800)
0 hrs
Clerical
$100.00/hr
20 hrs
$
(2,000)
0 hrs
Attorney
Review and endorse NEI-06-04, Executive
$100.00/hr
16 hrs
$
(1,600)
0 hrs
Rev. 1 and RIS 2008-08
$100.00/hr
20 hrs
$
(2,000)
0 hrs
Manager
$100.00/hr
160 hrs
$
(16,000)
0 hrs
Staff
$100.00/hr
8 hrs
$
(800)
0 hrs
Clerical
$100.00/hr
20 hrs
$
(2,000)
0 hrs
Attorney
Participate in first 10 drills
$100.00/hr
20 hrs
$
(2,000)
0 hrs
Executive
$100.00/hr
80 hrs
$
(8,000)
0 hrs
Manager
$100.00/hr
234 hrs
$
(23,400)
0 hrs
Staff
$100.00/hr
8 hrs
$
(800)
0 hrs
Clerical
$100.00/hr
0 hrs
$
0 hrs
Attorney
Participate in last 55 drills
$100.00/hr
4 hrs
$
(400)
0 hrs
Executive
$100.00/hr
24 hrs
$
(2,400)
0 hrs
Manager
$100.00/hr
100 hrs
$
(10,000)
0 hrs
Staff
$100.00/hr
8 hrs
$
(800)
0 hrs
Clerical
$100.00/hr
0 hrs
$
0 hrs
Attorney
Review emergency plan and TI
$100.00/hr
8 hrs
$
(800)
0 hrs
Executive
$100.00/hr
16 hrs
$
(1,600)
0 hrs
Manager
$100.00/hr
360 hrs
$
(36,000)
0 hrs
Staff
$100.00/hr
8 hrs
$
(800)
0 hrs
Clerical
$100.00/hr
20 hrs
$
(2,000)
0 hrs
Attorney
Interact with FEMA
$100.00/hr
420 hrs
$
(42,000)
0 hrs
Executive
$100.00/hr
420 hrs
$
(42,000)
0 hrs
Manager
$100.00/hr
4,200 hrs
$
(420,000)
0 hrs
Staff
$100.00/hr
20 hrs
$
(2,000)
0 hrs
Clerical
$100.00/hr
200 hrs
$
(20,000)
0 hrs
Attorney
Total NRC Implementation Cost
6,678 hrs
$
(739,000)
520 hrs
NRC OPERATIONS (ANNUAL)
Review of biennial exercise
$100.00/hr
8 hrs
$
(800)
0 hrs
Executive
submittals
$100.00/hr
16 hrs
$
(1,600)
160 hrs
Manager
$100.00/hr
400 hrs
$
(40,000)
480 hrs
Staff
$100.00/hr
8 hrs
$
(800)
0 hrs
Clerical
$100.00/hr
0 hrs
$
0 hrs
Attorney
Total NRC Operations Cost
432 hrs
$
(43,200)
640 hrs
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
FEMA - Review and revise
$100.00/hr
420 hrs
$
(42,000)
0 hrs
Executive
guidance (REP program FEMA
$100.00/hr
420 hrs
$
(42,000)
0 hrs
Manager
exercise evaluation criteria) - 3
$100.00/hr
4,200 hrs
$
(420,000)
0 hrs
Staff
FTE per year for staff
$100.00/hr
420 hrs
$
(42,000)
0 hrs
Clerical
$100.00/hr
420 hrs
$
(42,000)
0 hrs
Attorney
Total FEMA Implementation Cost
5,880 hrs
$
(588,000)
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
14,138 hrs
1,376 hrs
Notes:
(1) Hour estimates based on judgment of NRC staff.
(2) FEMA labor rates assumed to be the same as NRC wage rates.
(3) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
(4) Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site would be less than
the cost per affected site (which is shown above).
Page 4 of 15
Savings (Cost) Per
Site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(12,000)
(28,000)
(6,000)
(6,000)
(52,000)
$
$
$
$
$
$
(16,000)
(48,000)
(64,000)
$
$
$
$
$
-
A.4: Evacuation Time Estimate Updating
Under existing regulations, applicants and licensees must provide estimates of the time required to evacuate the public from the plume exposure pathway
emergency planning zone (EPZ). The proposed rule would clarify the need to review and update the evacuation time estimates (ETEs) following the initial licensing
of a nuclear power plant. Specifically, the proposed rule would establish a requirement for licensees to evaluate an EPZ's population and to update ETEs on a
stated frequency (i.e., every 10 years) and when annual reviews show that the population increases or decreases by 10% from the population that formed the basis
for the currently approved ETE.
Assumptions:
(1) 50 percent of sites would require an initial update to ETEs.
(2) Although sites reassess population annually, ETE updates would be needed once every 10 years due to new Census data.
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
INDUSTRY IMPLEMENTATION (ONE-TIME)
$200.00/hr
Establish process to obtain and
Executive
analyze annual Census Bureau
$150.00/hr
Manager
population updates for EPZ
$100.00/hr
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Review existing ETE
$200.00/hr
Executive
$150.00/hr
Manager
$100.00/hr
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Significant initial update to existing
$
200,000
ETEs
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
$200.00/hr
Executive
Obtain and analyze annual
$150.00/hr
Manager
Census Bureau population
$100.00/hr
EP staff
updates for EPZ
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Executive
Review Updated ETE
$150.00/hr
Manager
$100.00/hr
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Update ETEs
$
200,000
Total Industry Operations Cost
NRC IMPLEMENTATION (ONE-TIME)
$100.00/hr
Review and revise guidance
Executive
(NUREG guidance document)
$100.00/hr
Manager
$100.00/hr
Staff
$100.00/hr
Clerical
Attorney
$100.00/hr
Conduct ETE study (NRC
$
120,000
contractor)
Develop procedures for ETE
$100.00/hr
Executive
reviews (Standard Review Plan) Manager
$100.00/hr
$100.00/hr
Staff
$100.00/hr
Clerical
$100.00/hr
Attorney
Review initial updates of ETEs
$100.00/hr
Executive
$100.00/hr
Manager
$100.00/hr
Staff
$100.00/hr
Clerical
$100.00/hr
Attorney
Total NRC Implementation Cost
NRC OPERATIONS (ANNUAL)
Review ongoing updates of ETEs Executive
Manager
Staff
Clerical
Attorney
Total NRC Operations Cost
$100.00/hr
$100.00/hr
$100.00/hr
$100.00/hr
$100.00/hr
Savings
(Cost) Per
Site
Additional Incremental Effort Due to
Proposed Rule
Sites
Affected
Units
65
65
65
65
65
65
65
65
65
65
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
0 hrs/site
8 hrs/site
32 hrs/site
0 hrs/site
0 hrs/site
4 hrs/site
8 hrs/site
40 hrs/site
0 hrs/site
8 hrs/site
$
$
$
$
$
$
$
$
$
$
(1,200)
(3,200)
(800)
(1,200)
(4,000)
(800)
32.5
n/a
1 estimate/site
$
(200,000)
100 hrs/site
$
(211,200)
0 hrs/site
4 hrs/site
8 hrs/site
0 hrs/site
0 hrs/site
4 hrs/site
8 hrs/site
40 hrs/site
0 hrs/site
8 hrs/site
1 time/10 years
72 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
(600)
(800)
(800)
(1,200)
(4,000)
(800)
(20,000)
(28,200)
8 hrs
20 hrs
80 hrs
8 hrs
8 hrs
$
$
$
$
$
(800)
(2,000)
(8,000)
(800)
(800)
65
65
65
65
65
6.5
6.5
6.5
6.5
6.5
65
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
Units
Savings (Cost) Per
Affected Site
n/a
1
$
(120,000)
65
65
65
65
65
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
0 hrs
16 hrs
80 hrs
16 hrs
8 hrs
4 hrs/site
8 hrs/site
40 hrs/site
0 hrs/site
4 hrs/site
300 hrs
$
$
$
$
$
$
$
$
$
$
$
(1,600)
(8,000)
(1,600)
(800)
(400)
(800)
(4,000)
(400)
(150,000)
6.5
6.5
6.5
6.5
6.5
n/a
n/a
n/a
n/a
n/a
4 hrs/site
8 hrs/site
40 hrs/site
0 hrs/site
4 hrs/site
56 hrs/site
$
$
$
$
$
$
(400)
(800)
(4,000)
(400)
(5,600)
Page 5 of 15
Evacuation Time Estimate Updating (continued)
Cost Inputs
Requirement
Unit Cost
Sites
Affected
Incremental Effort Due to
Savings
(Cost) Per
Units
Site
Additional Incremental Effort Due to
Units
Savings (Cost) Per
Site
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
$100.00/hr
65
n/a
4 hrs/site
$
(400)
Review initial ETEs
Executive
$100.00/hr
65
n/a
8 hrs/site
$
(800)
Manager
$100.00/hr
65
n/a
40 hrs/site
$
(4,000)
Staff
$100.00/hr
65
n/a
0 hrs/site
$
Clerical
$100.00/hr
65
n/a
4 hrs/site
Attorney
$
(400)
Total State and Local Government Implementation Cost
56 hrs
($5,600)
OTHER GOVERNMENT OPERATIONS (ANNUAL)
$100.00/hr
n/a
4 hrs/site
$
(400)
Review updated ETEs
Executive
6.5
$100.00/hr
n/a
8 hrs/site
$
(800)
Manager
6.5
$100.00/hr
n/a
40 hrs/site
$
(4,000)
Staff
6.5
$100.00/hr
n/a
0 hrs/site
$
Clerical
6.5
$100.00/hr
n/a
4 hrs/site
Attorney
6.5
$
(400)
Total State and Local Government Operations Cost
n/a
56 hrs
$
(5,600)
TOTAL
640 hrs
Notes:
(1) Hour estimates based on judgment of NRC staff.
(2) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
(3) "n/a" means that the issue was not in the Orders or the Bulletin.
(4) State and local government labor rates assumed to be the same as NRC wage rates.
(5) Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site would be less than the cost per affected
site (which is shown above).
Page 6 of 15
A.5: Licensee Coordination with Offsite Response Organizations
The current regulations do not require licensees to coordinate with offsite response organizations (OROs) to ensure that personnel will be available to
carry out pre-planned actions, such as traffic control and route alerting, during a hostile action event directed at the plant. The proposed rule would
implement elements of Commission Order EA-02-26 explicitly requiring licensees to coordinate with OROs to increase assurance that adequate resources
would be available and pre-planned actions would be carried out when needed. Licensees would need to develop plans, procedures, and training
regarding notification, activation, and coordination between site personnel and OROs.
Assumptions:
(1) New training and drilling for coordination with OROs would be integrated within the current training program coursework and
delivered at the same time as other EP training without extending the duration of training courses.
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
INDUSTRY IMPLEMENTATION (ONE-TIME)
$200.00/hr
Executive
Review and update ORO
$150.00/hr
coordination protocol and interact Manager
$100.00/hr
with ORO
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Executive
Review and revise existing
$150.00/hr
procedures and plans
Manager
$100.00/hr
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Review and revise training
$200.00/hr
Executive
$150.00/hr
Manager
$100.00/hr
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
None.
NRC IMPLEMENTATION (ONE-TIME)
Review and revise guidance
$100.00/hr
Executive
(NUREG 0654 supplement,
$100.00/hr
Manager
Interim Staff Guidance,
$100.00/hr
Staff
Temporary Instruction 2515/148 Clerical
$100.00/hr
Rev 2)
$100.00/hr
Attorney
Total NRC Implementation Cost
NRC OPERATIONS (ANNUAL)
None.
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
State and Local Government
$100.00/hr
Executive
coordination
$100.00/hr
Manager
$100.00/hr
Staff
$100.00/hr
Clerical
$100.00/hr
Attorney
State and Local Government
$100.00/hr
Executive
review and revise plan and
$100.00/hr
Manager
procedures
$100.00/hr
Staff
$100.00/hr
Clerical
$100.00/hr
Attorney
FEMA to develop and revise
$100.00/hr
Executive
guidance and supplement to
$100.00/hr
Manager
NUREG 0654
$100.00/hr
Staff
$100.00/hr
Clerical
$100.00/hr
Attorney
Total State and Local Government Implementation Cost
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
Sites
Affected
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
Savings
(Cost) Per
Site
Units
40 hrs/site
80 hrs/site
160 hrs/site
16 hrs/site
0 hrs/site
8 hrs/site
40 hrs/site
160 hrs/site
16 hrs/site
40 hrs/site
0 hrs/site
8 hrs/site
80 hrs/site
8 hrs/site
0 hrs/site
656 hrs/site
Units
Savings (Cost) Per
Site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(8,000)
(12,000)
(16,000)
(800)
(1,600)
(6,000)
(16,000)
(800)
(4,000)
(1,200)
(8,000)
(400)
(74,800)
0 hrs/site
8 hrs/site
40 hrs/site
0 hrs/site
0 hrs/site
4 hrs/site
8 hrs/site
40 hrs/site
8 hrs/site
16 hrs/site
0 hrs/site
0 hrs/site
20 hrs/site
0 hrs/site
0 hrs/site
144 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(1,200)
(4,000)
(800)
(1,200)
(4,000)
(400)
(1,600)
(2,000)
(15,200)
8 hrs
30 hrs
290 hrs
40 hrs
10 hrs
378 hrs
$
$
$
$
$
$
(800)
(3,000)
(29,000)
(4,000)
(1,000)
(37,800)
8 hrs
20 hrs
240 hrs
8 hrs
20 hrs
296 hrs/site
$
$
$
$
$
$
(800)
(2,000)
(24,000)
(800)
(2,000)
(29,600)
40 hrs/site
80 hrs/site
160 hrs/site
16 hrs/site
16 hrs/site
8 hrs/site
40 hrs/site
160 hrs/site
16 hrs/site
40 hrs/site
0 hrs
0 hrs
0 hrs
0 hrs
0 hrs
576 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(4,000)
(8,000)
(16,000)
(1,600)
(1,600)
(800)
(4,000)
(16,000)
(1,600)
(4,000)
(57,600)
0 hrs/site
0 hrs/site
40 hrs/site
0 hrs/site
0 hrs/site
4 hrs/site
8 hrs/site
40 hrs/site
8 hrs/site
16 hrs/site
8 hrs
20 hrs
240 hrs
8 hrs
20 hrs
412 hrs
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(4,000)
(400)
(800)
(4,000)
(800)
(1,600)
(800)
(2,000)
(24,000)
(800)
(2,000)
(41,200)
1,610 hrs
Notes:
(1)
(2)
(3)
(4)
Additional Incremental Effort Due to
Proposed Rule
Hour estimates based on judgment of NRC staff.
See discussion of methodology in Section 3.2 of the Regulatory Analysis.
FEMA labor rates assumed to be the same as NRC wage rates.
State and local government labor rates assumed to be the same as NRC labor rates.
Page 7 of 15
852 hrs
A.6: On-Shift Multiple Responsibilities
The current regulations do not clearly state that on-shift nuclear power reactor personnel assigned to emergency plan implementation must not have
multiple emergency responsibilities that would prevent them from performing their primary plan tasks. The proposed rule would codify generically
applicable requirements similar to elements of the Commission Order EA 02-26 requiring that on-shift emergency response personnel must not have
competing responsibilities that interfere with primary emergency response functions, and would establish criteria for shift staffing responsibilities to
increase assurance that responders are not overburdened. This change would require nuclear power reactor licensees to conduct a job task analysis and
review plans, procedures, and training regarding assignment of multiple responsibilities, and to re-assign responsibilities if necessary.
Assumptions:
(1) This analysis assumes that some plans, procedures, training, and re-assignment would need to be revised because the regulations may exceed the
2002 Order.
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
INDUSTRY IMPLEMENTATION (ONE-TIME)
Conduct job task analysis $200.00/hr
Executive
Nuclear power reactor licensees Manager
$150.00/hr
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
$200.00/hr
Review and revise emergency
Executive
plan - Nuclear power reactor
$150.00/hr
Manager
licensees
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Review and revise procedures - Executive
$200.00/hr
Nuclear power reactor licensees Manager
$150.00/hr
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Review and revise training $200.00/hr
Executive
Nuclear power reactor licensees Manager
$150.00/hr
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Conduct initial training
$200.00/hr
Executive
(30 staff at 4 hour training; one
$150.00/hr
Manager
trainer per 30 trainees)
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Develop industry white paper
$200.00/hr
Executive
$150.00/hr
Manager
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
None.
NRC IMPLEMENTATION (ONE-TIME)
Review and revise guidance
$100.00/hr
Executive
(Temporary Instructions, NEI
$100.00/hr
Manager
White Paper, Interim Staff
$100.00/hr
Staff
Guidance)
$100.00/hr
Clerical
$100.00/hr
Attorney
Total NRC Implementation Cost
NRC OPERATIONS (ANNUAL)
None.
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
None.
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
Sites
Affected
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
Savings
(Cost) Per
Site
Units
Additional Incremental Effort Due to
Proposed Rule
Units
Savings (Cost) Per
Site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
8 hrs/site
40 hrs/site
160 hrs/site
16 hrs/site
40 hrs/site
8 hrs/site
40 hrs/site
320 hrs/site
32 hrs/site
40 hrs/site
0 hrs/site
8 hrs/site
120 hrs/site
16 hrs/site
0 hrs/site
0 hrs/site
4 hrs/site
120 hrs/site
0 hrs/site
0 hrs/site
8 hrs/site
24 hrs/site
80 hrs/site
16 hrs/site
16 hrs/site
1,116 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(1,600)
(6,000)
(16,000)
(800)
(4,000)
(1,600)
(6,000)
(32,000)
(1,600)
(4,000)
(1,200)
(12,000)
(800)
(600)
(12,000)
(1,600)
(3,600)
(8,000)
(800)
(1,600)
(115,800)
4 hrs/site
16 hrs/site
160 hrs/site
40 hrs/site
16 hrs/site
0 hrs/site
8 hrs/site
40 hrs/site
0 hrs/site
8 hrs/site
0 hrs/site
8 hrs/site
80 hrs/site
0 hrs/site
8 hrs/site
0 hrs/site
0 hrs/site
40 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
428 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(800)
(2,400)
(16,000)
(2,000)
(1,600)
(1,200)
(4,000)
(800)
(1,200)
(8,000)
(800)
(4,000)
(42,800)
8 hrs
30 hrs
290 hrs
40 hrs
10 hrs
378 hrs
$
$
$
$
$
$
(800)
(3,000)
(29,000)
(4,000)
(1,000)
(37,800)
16 hrs
40 hrs
480 hrs
80 hrs
40 hrs
656 hrs
$
$
$
$
$
$
(1,600)
(4,000)
(48,000)
(8,000)
(4,000)
(65,600)
1,494 hrs
Notes:
(1) Hour estimates based on judgment of NRC staff.
(2) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
Page 8 of 15
1,084 hrs
A.7: Emergency Response Organization Augmentation and Alternative Facilities
The current regulations do not require licensees to identify alternative facilities to support emergency response organization (ERO) augmentation during
hostile action events. The proposed rule would codify generically applicable requirements similar to those elements of Commission Order 02-26 and
industry initiatives subsequent to NRC Bulletin 2005-02 directing licensees to provide alternative facilities for use during hostile action events when onsite
facilities (technical support center and/or near-site emergency operations facility) are not available (e.g., due to emergency conditions). This change would
require licensees to review and revise their plans, procedures, and training regarding ERO augmentation during a hostile action event. In addition, some
sites may need to lease and equip a new facility to serve as its alternative facility.
Assumptions:
(1) This analysis assumes that most sites would use present facilities, i.e. EOF, back up EOF, back up TSC.
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
INDUSTRY IMPLEMENTATION (ONE-TIME)
$200.00/hr
Executive
Review and revise emergency
$150.00/hr
Manager
plan
$100.00/hr
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Review and revise procedures
$200.00/hr
Executive
$150.00/hr
Manager
$100.00/hr
EP staff
$50.00/hr
Clerical
$250.00/hr
Licensing
Review and revise training
$200.00/hr
Executive
$150.00/hr
Manager
$100.00/hr
EP staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Equip alternative facility with
$2,000/site
necessary capabilities
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
$1,000/site
Maintain procedures and
equipment for alternative facilities
Sites
Affected
Units
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
8 hrs/site
24 hrs/site
80 hrs/site
40 hrs/site
8 hrs/site
0 hrs/site
8 hrs/site
40 hrs/site
16 hrs/site
0 hrs/site
1 per site
65
Total Industry Operations Cost
NRC IMPLEMENTATION (ONE-TIME)
Review and revise guidance
$100.00/hr
Executive
(Temporary Instructions, bulletin Manager
$100.00/hr
preparation, new regulatory guide) Staff
$100.00/hr
$100.00/hr
Clerical
$100.00/hr
Attorney
Total NRC Implementation Cost
NRC OPERATIONS (ANNUAL)
None.
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
None.
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
Savings
(Cost) Per
Site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Units
Savings (Cost) Per
Site
10 hrs/site
20 hrs/site
40 hrs/site
24 hrs/site
40 hrs/site
0 hrs/site
8 hrs/site
16 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
8 hrs/site
16 hrs/site
0 hrs/site
0 hrs/site
0
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(2,000)
(3,000)
(4,000)
(1,200)
(4,000)
(1,200)
(1,600)
(1,200)
(1,600)
($2,000)
225 hrs/site
182 hrs/site
$
(21,800)
1 per site
0
$
(1,000)
$
(1,000)
$
$
$
$
$
$
(2,000)
(4,000)
(16,000)
(4,000)
(2,000)
(28,000)
8 hrs
30 hrs
390 hrs
40 hrs
10 hrs
478 hrs
703 hrs
Notes:
(1) Hour estimates based on judgment of NRC staff.
(2) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
Page 9 of 15
(1,600)
(3,600)
(8,000)
(2,000)
(2,000)
(1,200)
(4,000)
(800)
-
Additional Incremental Effort Due to
Proposed Rule
(800)
(3,000)
(39,000)
(4,000)
(1,000)
(47,800)
20 hrs
40 hrs
160 hrs
40 hrs
20 hrs
280 hrs
462 hrs
A.8.a: Reduction in Effectiveness - Nuclear Power Reactor Licensees
Current regulations require nuclear power reactor licensees to "maintain in effect" their emergency plan. The proposed rule would clarify that the license
amendment process is the correct process for licensees to use when submitting emergency plan changes that would reduce the effectiveness of the
emergency plan. To comply with the proposed rules, nuclear power reactor licensees may need to revise procedures and training to address the process
for emergency plan changes (i.e., through 10 CFR 50.90 submittals). In addition, for emergency plan changes that do not result in a reduction in
effectiveness, nuclear power reactor licensees would need to submit to NRC the analysis prepared to demonstrate the change does not reduce the
effectiveness of the plan.
Assumptions:
(1) The proposed Reduction in Effectiveness rule language clarifies existing requirements. Therefore, this analysis does not estimate incremental costs
associated with preparing Section 50.54(q) emergency plan changes via the license amendment process.
(2) Although training may not be necessary, the analysis conservatively assumes revisions to training materials.
(3) None of the license amendment requests submitted by licensees would result in hearings.
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
INDUSTRY IMPLEMENTATION (ONE-TIME)
Review and revise existing
Executive
procedures - Nuclear power
Manager
reactor licensees
EP Staff
Clerical
Licensing
Review and revise training Executive
Nuclear power reactor licensees Manager
EP Staff
Clerical
Licensing
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
Submit analysis of changes to
Executive
emergency plan not resulting in
Manager
reduction in effectiveness
EP Staff
Clerical
Licensing
Attorney
Total Industry Operations Cost
NRC IMPLEMENTATION (ONE-TIME)
Issue new Regulatory Guide
Executive
Manager
Staff
Clerical
Attorney
Total NRC Implementation Cost
Savings
(Cost) Per
Site
Additional Incremental Effort Due to
Proposed Rule
Unit Cost
Sites
Affected
Units
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
65
65
65
65
65
65
65
65
65
65
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
0 hrs/site
16 hrs/site
60 hrs/site
40 hrs/site
16 hrs/site
0 hrs/site
8 hrs/site
40 hrs/site
20 hrs/site
0 hrs/site
200 hrs/site
$
$
$
$
$
$
$
$
$
$
$
(2,400)
(6,000)
(2,000)
(1,600)
(1,200)
(4,000)
(1,000)
(18,200)
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
$250.00/hr
65
65
65
65
65
65
n/a
n/a
n/a
n/a
n/a
n/a
0 hrs/site
0 hrs/site
0 hrs/site
2 hrs/site
0 hrs/site
0 hrs/site
2 hrs/site
$
$
$
$
$
$
$
(100)
(100)
n/a
n/a
n/a
n/a
n/a
0 hrs
160 hrs
240 hrs
80 hrs
40 hrs
520 hrs
$
$
$
$
$
$
(16,000)
(24,000)
(8,000)
(4,000)
(52,000)
$100.00/hr
$100.00/hr
$100.00/hr
$100.00/hr
$100.00/hr
NRC OPERATIONS (ANNUAL)
None.
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
None.
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
Units
Savings (Cost) Per
Affected Site
722 hrs
Notes:
(1) Hour estimates based on judgment of NRC staff.
(2) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
(3) "n/a" means that the issue was not in the Orders or the Bulletin.
(4) Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site would be less than the cost per affected
site (which is shown above).
Page 10 of 15
A.8.b: Reduction in Effectiveness - Non-Power Reactor Licensees
Current regulations require non-power reactor licensees to "maintain in effect" their emergency plan. The proposed rule language would clarify the existing
rule language by requiring non-power reactor licensees: to maintain capabilities and resources relative to the emergency plan, ensure changes to the
approved emergency plan are properly evaluated, and ensure that proposed changes that reduce the effectiveness of the plan receive prior review by the
NRC. To comply with the proposed rules, non-power reactor licensees may need to revise procedures and training to address the process for emergency
plan changes (i.e., through 10 CFR 50.90 submittals). In addition, for emergency plan changes that do not result in a reduction in effectiveness, nonpower reactor licensees would need to submit to the NRC the analysis prepared to demonstrate the change does not reduce the effectiveness of the plan.
Assumptions:
(1) Although training may not be necessary, the analysis conservatively assumes revisions to training materials.
(2) NRC would not receive any 10 CFR 50.90 submittals (i.e., emergency plan change that reduces the effectiveness of the plan) per year.
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
INDUSTRY IMPLEMENTATION (ONE-TIME)
Review and revise existing
$200.00/hr
Executive
procedures - Research and test Manager
$150.00/hr
reactors
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Review and revise training $200.00/hr
Executive
Research and test reactors
$150.00/hr
Manager
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
None
NRC IMPLEMENTATION (ONE-TIME)
None
NRC OPERATIONS (ANNUAL)
None
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
None.
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
Sites
Affected
Units
32
32
32
32
32
32
32
32
32
32
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
Savings
(Cost) Per
Site
Additional Incremental Effort Due to
Proposed Rule
Units
0 hrs/site
0 hrs/site
80 hrs/site
40 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
40 hrs/site
0 hrs/site
0 hrs/site
160 hrs/site
Savings (Cost) Per
Affected Site
$
$
$
$
$
$
$
$
$
$
$
(8,000)
(2,000)
(4,000)
(14,000)
160 hrs
Notes:
(1) Hour estimates based on judgment of NRC staff.
(2) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
(3) "n/a" means that the issue was not in the Orders or the Bulletin.
(4) Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site would be less than the cost per affected
site (which is shown above).
Page 11 of 15
A.9: Emergency Declaration Timeliness
The current emergency preparedness regulations do not establish timeliness criteria for the emergency declaration process. The proposed rule would
require licensees to have the capability to classify and declare an emergency within 15 minutes of the availability of information that an EAL has been or
may be exceeded. Licensees are already complying with the proposed rule language via a voluntary initiative that accomplishes the intent of the proposed
rule. Licensees, however, would need to review and revise existing site procedures and training to include the new timeliness requirements for emergency
declarations.
Assumptions:
(1) New training for emergency classification timeliness would be integrated within the current training program coursework and delivered at the same
time as other EP training without extending the duration of training courses.
(2) Sites would not incur operating costs because the proposed rule only requires the capability to classify and declare an emergency within 15 minutes.
Incremental Effort Due to
Voluntary Initiative (PI)
Cost Inputs
Requirement
Unit Cost
INDUSTRY IMPLEMENTATION (ONE-TIME)
Review and revise existing
$200.00/hr
Executive
procedures
$150.00/hr
Manager
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Review and revise training
$200.00/hr
Executive
$150.00/hr
Manager
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
None.
NRC IMPLEMENTATION (ONE-TIME)
Review and revise guidance (e.g., Executive
$100.00/hr
withdraw EPPOS-2, update NEI- Manager
$100.00/hr
99-02)
$100.00/hr
Staff
$100.00/hr
Clerical
$100.00/hr
Attorney
Total NRC Implementation Cost
NRC OPERATIONS (ANNUAL)
None.
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
None.
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
Sites
Affected
65
65
65
65
65
65
65
65
65
65
Savings
(Cost) Per
Site
Units
Additional Incremental Effort Due to
Proposed Rule
Units
Savings (Cost) Per
Site
0 hrs/site
20 hrs/site
80 hrs/site
20 hrs/site
0 hrs/site
0 hrs/site
10 hrs/site
40 hrs/site
20 hrs/site
0 hrs/site
190 hrs/site
$
$
$
$
$
$
$
$
$
$
$
(3,000)
(8,000)
(1,000)
(1,500)
(4,000)
(1,000)
(18,500)
0 hrs/site
4 hrs/site
16 hrs/site
0 hrs/site
0 hrs/site
0 hrs/site
4 hrs/site
16 hrs/site
0 hrs/site
0 hrs/site
40 hrs/site
$
$
$
$
$
$
$
$
$
$
$
(600)
(1,600)
(600)
(1,600)
(4,400)
0 hrs
0 hrs
0 hrs
0 hrs
0 hrs
0 hrs
$
$
$
$
$
$
-
0 hrs
16 hrs
80 hrs
40 hrs
20 hrs
156 hrs
$
$
$
$
$
$
(1,600)
(8,000)
(4,000)
(2,000)
(15,600)
190 hrs
Notes:
(1) Hour estimates based on judgment of NRC staff.
(2) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
Page 12 of 15
196 hrs
A.10: Emergency Operations Facility - Performance Based Approach
Current regulations do not address the capabilities and functional requirements for an EOF located more than 25 miles from a site or an EOF serving more
than one site, such as a co-located or consolidated EOF. The proposed rule would establish a performance standard for licensees that plan to locate an
EOF more than 25 miles from a site or consolidate multiple EOFs into one facility. The analysis assumes there are no incremental costs to licensees for
this proposed rule change because the rule does not require that EOFs be located more than 25 miles from a site or consolidation of EOFs. Rather, a
licensee would voluntarily choose to pursue an EOF location more than 25 miles from a site or consolidation only if the incremental savings exceed the
incremental costs.
Assumptions:
(1) Consolidation of an EOF or location of an EOF more than 25 miles from a site is optional. Therefore, the analysis does not calculate the incremental
costs or savings incurred by licensees resulting from EOF consolidation or location more than 25 miles from a site.
(2) NRC would incur costs to revise guidance.
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
Sites
Affected
INDUSTRY IMPLEMENTATION (ONE-TIME)
None.
INDUSTRY OPERATIONS (ANNUAL)
None.
NRC IMPLEMENTATION (ONE-TIME)
$100.00/hr
Review and revise guidance
Executive
(NUREG 0654 supplement,
$100.00/hr
Manager
NUREG 0696, NUREG 0737
$100.00/hr
Staff
supplement 1, Interim Staff
$100.00/hr
Clerical
Guidance)
$100.00/hr
Attorney
Total NRC Implementation Cost
NRC OPERATIONS (ANNUAL)
None.
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
None.
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
Units
n/a
n/a
n/a
n/a
n/a
Savings
(Cost) Per
Site
Additional Incremental Effort Due to
Proposed Rule
Units
20 hrs
80 hrs
360 hrs
40 hrs
40 hrs
540 hrs
540 hrs
Notes:
(1) Hour estimates based on judgment of NRC staff.
(2) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
(3) "n/a" means that the issue was not in the Orders or the Bulletin.
Page 13 of 15
Savings (Cost) Per
Site
$
$
$
$
$
$
(2,000)
(8,000)
(36,000)
(4,000)
(4,000)
(54,000)
A.11: Backup Means for Alert and Notification Systems (ANS)
Existing regulations and guidance do not address requirements for backup alerting and notification capabilities when a major portion of the primary means
is unavailable. The proposed rule would require licensees to select and implement a backup method of alerting and notification to be used in the event
that the primary ANS is unavailable.
Assumptions:
(1) Twenty-one sites already have backup power to sirens as a backup alerting mechanism. However, these sites would not be fully-compliant with the
proposed rule. They would need to upgrade their siren activation system in order to comply.
(2) Thirty-two sites already use route alerting as a backup means of alerting, which complies with the proposed rule. These sites, however, would need to
review and verify their procedures to ensure there are adequate resources during hostile actions.
(3) Twelve sites do not have any backup means of alerting. Six of the sites would need to implement backup power to sirens, while the other 6 would
need to implement route alerting as backup.
(4) Thirty-two sites have backup Emergency Alert System (EAS) capabilities for public notification.
(5) Thirty-three sites do not have a backup EAS capability. These sites would incur incremental costs to acquire a backup EAS capability.
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
INDUSTRY IMPLEMENTATION (ONE-TIME)
$200.00/hr
Executive
Review and select means of
$150.00/hr
backup ANS
Manager
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
Upgrade sirens
$10,000/siren
Implement backup alerting system
Savings
(Cost) Per
Site
Additional Incremental Effort Due to
Proposed Rule
Sites
Affected
Units
45
45
45
45
45
n/a
n/a
n/a
n/a
n/a
40 hrs/site
80 hrs/site
480 hrs/site
8 hrs/site
40 hrs/site
$
$
$
$
$
(8,000)
(12,000)
(48,000)
(400)
(4,000)
Units
Savings (Cost) Per
Affected Site
6
n/a
50 sirens/site
$
(500,000)
Implement route alerting
$50,000/site
$200.00/hr
Executive
$150.00/hr
Manager
$100.00/hr
EP Staff
$50.00/hr
Clerical
$100.00/hr
Licensing
$50,000/site
6
53
53
53
53
53
21
n/a
n/a
n/a
n/a
n/a
n/a
n/a
1 plan/site
0 hrs/site
8 hrs/site
40 hrs/site
0 hrs/site
8 hrs/site
1 system/site
$
$
$
$
$
$
$
(50,000)
(1,200)
(4,000)
(800)
(50,000)
$50,000/site
33
n/a
1 system/site
$
(50,000)
Executive
Manager
EP Staff
Clerical
Licensing
Develop administrative controls, Executive
maintenance procedures, training Manager
and testing program for means of EP Staff
backup ANS (partial program)
Clerical
Licensing
Executive
Revise FEMA REP-10 ANS
Manager
design report
EP Staff
Clerical
Licensing
Total Industry Implementation Cost
INDUSTRY OPERATIONS (ANNUAL)
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
$200.00/hr
$150.00/hr
$100.00/hr
$50.00/hr
$100.00/hr
12
12
12
12
12
21
21
21
21
21
33
33
33
33
33
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
30 hrs/site
60 hrs/site
360 hrs/site
0 hrs/site
30 hrs/site
8 hrs/site
8 hrs/site
80 hrs/site
8 hrs/site
8 hrs/site
4 hrs/site
24 hrs/site
240 hrs/site
16 hrs/site
24 hrs/site
1,604 hrs/site
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(6,000)
(9,000)
(36,000)
(3,000)
(1,600)
(1,200)
(8,000)
(400)
(800)
(800)
(3,600)
(24,000)
(800)
(2,400)
(826,000)
Maintain back-up to siren system
Maintain route alerting system
$200/siren
27
n/a
50 sirens/site
$
(10,000)
$5,000/site
38
n/a
1 system/site
$
(5,000)
$10,000/site
65
n/a
1 system/site
$
$
(10,000)
(25,000)
n/a
n/a
n/a
n/a
n/a
8 hrs
20 hrs
100 hrs
8 hrs
20 hrs
156 hrs
$
$
$
$
$
$
(800)
(2,000)
(10,000)
(800)
(2,000)
(15,600)
Review and verify existing ANS
backup
Implement back-up to siren
activation system
Implement EAS backup
notification system
Develop administrative controls,
maintenance procedures, training
and testing program for means of
backup ANS (full program)
Maintain back-up to EAS
Total Industry Operations Cost
NRC IMPLEMENTATION (ONE-TIME)
Review and revise guidance
Executive
(NUREG-0654, inspection
Manager
procedures)
Staff
Clerical
Attorney
Total NRC Implementation Cost
NRC OPERATIONS (ANNUAL)
None.
$100.00/hr
$100.00/hr
$100.00/hr
$100.00/hr
$100.00/hr
Page 14 of 15
Backup Means for Alert and Notification Systems (continued)
Incremental Effort Due to
Order & Bulletin
Cost Inputs
Requirement
Unit Cost
OTHER GOVERNMENT IMPLEMENTATION (ONE-TIME)
$100.00/hr
FEMA to review and approve
Executive
revised FEMA REP-10 ANS
$100.00/hr
Manager
$100.00/hr
Staff
$100.00/hr
Clerical
Attorney
$100.00/hr
$100.00/hr
FEMA to review and revise
Executive
guidance (REP-10, Guidance
$100.00/hr
Manager
Memorandum AN-1, REP
$100.00/hr
Staff
program manual, Civil
$100.00/hr
Clerical
Preparedness Guide 1-17)
Attorney
$100.00/hr
Total FEMA Implementation Cost
OTHER GOVERNMENT OPERATIONS (ANNUAL)
None.
TOTAL
Notes:
Sites
Affected
33
33
33
33
33
Units
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
Savings
(Cost) Per
Site
Additional Incremental Effort Due to
Proposed Rule
Units
0 hrs/site
8 hrs/site
160 hrs/site
8 hrs/site
0 hrs/site
8 hrs
40 hrs
240 hrs
16 hrs
40 hrs
520 hrs
2,280 hrs
(1) Hour estimates based on judgment of NRC staff.
(2) See discussion of methodology in Section 3.2 of the Regulatory Analysis.
(3) "n/a" means that the issue was not in the Orders or the Bulletin.
(4) FEMA labor rates assumed to be the same as NRC wage rates.
(5) Not all 65 sites would incur certain costs resulting from the provision. As a result, the cost for the average site would be less than
the cost per affected site (which is shown above).
Page 15 of 15
Savings (Cost) Per
Affected Site
$
$
$
$
$
$
$
$
$
$
$
(800)
(16,000)
(800)
(800)
(4,000)
(24,000)
(1,600)
(4,000)
(52,000)
| File Type | application/pdf |
| File Title | Draft Regulatory Analysis and Backfit Analysis |
| Author | Timothy Reed |
| File Modified | 2009-04-28 |
| File Created | 2009-04-28 |