1. Cost Case Studies of Selected NRC Regulatory Requirements September 19 th, 2013

2. Case Study Topics NFPA 805, 10 CFR 50.48(c) [69 FR 33550] Power Reactor Security Requirements, 10 CFR 73 [74 FR 13926] Managing Fatigue, Subpart I, 10 CFR 26 [73 FR 17176]

3. Case Study Volunteers NFPA 805: 5 units Power Reactor Security Requirements: 12 sites Managing Fatigue, Subpart I: 2 companies (7 units)

4. Cost Comparisons NFPA 805 -NRC: A one-time, plant-wide analysis is “estimated to be about $1.68M for each facility.” p.3 from NRC Regulatory Analysis -Average cost for the 805 analysis from the five units: $10.5 million -Depending on unit, an additional $2M - $16M was spent on capital, O&M and modifications

5. Cost Comparisons Cont’d Security – 2009 Part 73 Rule -NRC estimate for average site costs for entire rule: one-time costs = $1,780,138; annual costs = $594,606 -NRC estimate for average site costs for 73.55 (Physical Protection): one-time costs = $402,600; annual savings = $11,106. p. 12 & 13 from NRC Regulatory Analysis -Average site costs from the 12 sites for 73.55: one- time costs = $34.6M -Costs for other sections of the rule not available from the 12 sites

6. Cost Comparisons Cont’d Fitness for Duty Rule – Subpart I (Managing Fatigue) -NRC estimate for a Fitness for Duty program: one- time costs = $0.4M; annual costs = $1.125M. p. 32 from NRC Regulatory Analysis -Average costs for two FFD programs (7 units): one- time costs = $2.3M; annual costs = $2.8M Additional costs by vendors: e.g. $1M-$2M per outage based on data from vendor supporting 20+ outages per year

7. Next Steps Conduct interactions between NRC and volunteer sites to understand differences and methodologies in costs -Need to learn how costs in Regulatory Analyses were calculated Draft a paper with detailed results and comparisons between NRC cost estimates and actual costs

8. Questions and Discussion