Appendix E — Roadmap Updates for 2026
The tables below summarize the
substantive changes made in the 2026 edition of this Roadmap. All updates reflect
regulatory or policy developments that occurred after July 1, 2025. No changes were made
to the core accounting guidance in ASC 410-20 or ASC 410-30.
New Content
|
Section
|
Title
|
Description
|
|---|---|---|
|
2.5.2.1.1.1
|
Definition of Hazardous Waste and Listing of Specific
PFASs as RCRA Hazardous Constituents
|
New section consisting of content moved from Section 2.5.2.1.1 and
updated to reflect the EPA’s May 2026 withdrawal of its
proposed rule on amending the definition of hazardous
waste.
|
|
2.5.2.1.1.2
|
CERCLA Hazardous Substance Designation for PFOA and
PFOS
|
New section discussing the EPA’s 2024 final rule
designating PFOA and PFOS as hazardous substances under
CERCLA and the EPA’s 2025 announcement that it intends
to retain this designation and to develop a CERCLA
Section 102(a) framework rule.
|
|
2.5.2.1.1.3
|
National Primary Drinking Water Regulation for PFASs
|
New section discussing the EPA’s (1) NPDWR and (2) 2026
proposals to modify the scope and implementation
timeline of the NPDWR’s drinking water standards.
|
|
3.7.4.1
|
SEC Final Rule on Climate-Related Disclosures
|
New section consisting of content moved from Section 3.7.4 and
updated to reflect the SEC’s May 2026 proposed rule that
would rescind the SEC’s final rule on climate-related
disclosures.
|
|
5.4.1.1
|
Decommissioning Funding Requirements (10 CFR Section
50.75)
|
New section consisting of content moved from Section 5.4.1 and
expanded to (1) note that the biennial reporting
requirement under 10 CFR Section 50.75 applies to
licensees during the operating phase and (2) clarify
that licensees that have permanently ceased operations
and are actively engaged in decommissioning are subject
to additional annual financial assurance reporting
requirements under 10 CFR Section
50.82(a)(8)(v)–(vii).
|
|
5.4.1.2
|
60-Year Completion Report (10 CFR
Section 50.82)
|
New section discussing the requirement under 10 CFR
Section 50.82(a)(3) to decommission a nuclear power
plant within 60 years of permanent cessation of
operations unless the NRC approves an extended timeline
when necessary to protect public health and safety.
|
|
5.4.1.3
|
Post-Shutdown Decommissioning Activities Report (10 CFR
Section 50.82)
|
New section consisting of content moved from Section 5.4.1 and
expanded to (1) elaborate on the content to be included
in a PSDAR and (2) discuss (a) the 90-day period
triggered by the NRC’s receipt of the PSDAR and (b) the
requirement that licensees in active decommissioning
submit annual financial assurance status reports under
10 CFR Section 50.82(a)(8)(v)–(vii).
|
|
5.4.1.4
|
License Termination Plan (10 CFR Section 50.82)
|
New section consisting of content moved from Section 5.4.1 and
expanded to include a reference to guidance from the NEI
on the LTP process.
|
|
5.4.1.5
|
Subsequent License Renewal and Its
Effect on Decommissioning Obligations (10 CFR Part
54)
|
New section discussing SLR, which extends a nuclear power
plant’s operating life from 60 years to 80 years, and
the effect of SLR on decommissioning obligations.
|
|
5.5.1.2.4
|
Proposed Amendments to 2024 Regulations
|
New section discussing the EPA’s April 2026 proposed rule
that would rescind CCRMU requirements, modify legacy
surface impoundment standards, and create a new closure
certification option.
|
|
5.5.1.2.5
|
State Permit Programs
|
New section discussing the status of states’ WIIN Act
applications for EPA approval to operate their own CCR
permit programs in lieu of the federal program.
|
Amended Content
|
Section
|
Title
|
Description
|
|---|---|---|
|
Added (1) a discussion of recent
developments related to the CCR regulatory framework and
(2) an update on the status of the SEC’s final rule on
climate-related disclosures.
| ||
|
Recent Rulemaking Developments Related to PFASs
|
Updated section title.
Content moved to new Section
2.5.2.1.1.1 and updated to reflect the
EPA’s May 2026 withdrawal of its proposed rule on
amending the definition of hazardous waste.
| |
|
Transaction-Triggered Environmental Laws
|
Updated to include discussion of (1) the NJDEP’s issuance
of its (a) final rule amending the ISRA Rules and
related site remediation regulations and (b) reproposed
rule on due diligence discharge reporting and (2)
Connecticut’s transition from transaction-triggered
filing obligations to a release-based reporting and
remediation approach.
| |
|
Licensed Environmental Professionals
|
Updated to discuss recent rulemaking developments related
to assessment and remediation programs in Massachusetts,
New Jersey, and Connecticut that involve the use of
LEPs
| |
|
SEC Disclosure Requirements
|
Discussion of the SEC’s final rule on
climate-related disclosures moved to new Section 3.7.4.1 and
updated to reflect the SEC’s May 2026 proposed rule that
would rescind that final rule.
| |
|
Nuclear Power Plant Decommissioning
|
Content on decommissioning funding requirements under 10
CFR Section 50.75, the PSDAR under 10 CFR Section 50.82,
and the LTP under 10 CFR 50.82 moved to new Section 5.4.1.1, new
Section
5.4.1.3, and new Section 5.4.1.4,
respectively, and expanded.
| |
|
High-Level Radioactive Waste
|
Updated to discuss the status of the NRC’s proposed rule
that would introduce a graded, four-step regulatory
framework aligning safety and security requirements with
the reduction in radiological risk as decommissioning
progresses.
| |
|
Recent CCR Developments
|
Updated to note a shift in the federal
CCR regulatory posture beginning in 2025, with
subsequent rulemaking focused on grid reliability and
energy dominance rather than accelerated cleanup.
| |
|
The Final Closure Part A Rule
|
Updated to discuss the EPA’s issuance of a proposed rule
that would extend the closure deadline for unlined
impoundments larger than 40 acres by three years.
| |
|
Final Rule on Legacy CCR Surface Impoundments and CCR
Management Units
|
Updated the CCRMU compliance timeline table to reflect
the EPA’s issuance in February 2026 of a final rule that
extended the original deadlines prescribed in the EPA’s
2024 legacy rule.
| |
|
Potential Accounting Impact
|
Renumbered from Section 5.5.1.2.4.
|