10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory

DRAFT
NEW NUCLEAR REACTOR APPLICATIONS
COL-ISG-030
Environmental Considerations for New Nuclear Reactor
Applications that Reference the Generic Environmental
Impact Statement for Licensing of New Nuclear Reactors
(NUREG-2249)
Interim Staff Guidance

I.

PURPOSE

Title 10 of the Code of Federal Regulations (10 CFR) 51.20, “Criteria for and Identification of Licensing
and Regulatory Actions Requiring Environmental Impact Statements” (10 CFR Part 51-TN250), requires
the preparation of an environmental impact statement (EIS) or a supplemental environmental impact
statement (SEIS) documenting the U.S. Nuclear Regulatory Commission (NRC) staff’s environmental
findings for issuance of an early site permit (ESP) or a combined license (COL) under 10 CFR Part 52,
“Licenses, Certifications, and Approvals for Nuclear Power Plants” (TN251), or for issuance of a
construction permit (CP), or operating license (OL) for a nuclear power reactor under 10 CFR Part 50,
“Domestic Licensing of Production and Utilization Facilities” (TN249).
The purpose of this interim staff guidance (ISG) is to modify existing guidance and provide supplemental
guidance to assist the NRC staff in determining the scope and scale of environmental reviews of new
reactors that reference NUREG-2249, “Generic Environmental Impact Statement [GEIS] for Licensing of
New Nuclear Reactors” (NUREG-2249, NR GEIS; NRC 2024-TN7080). The guidance highlights unique
considerations for new reactors in each resource area typically covered in the staff’s environmental
review. The staff should be familiar with the following guidance documents that support the preparation of
an EIS or SEIS:
• NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants:
Environmental Standard Review Plan, issued in 2000 and updated in 2007 (NRC 2000, 2007-TN614);
• COL/ESP-ISG-026, “Environmental Issues Associated with New Reactors” (NRC 2014-TN3767),
issued August 2014;
• COL/ESP-ISG-027, “Specific Environmental Guidance for Light Water Small Modular Reactor
Reviews” (NRC 2014-TN3766), issued August 2014; and
• COL-ISG-029, “Environmental Considerations Associated with Micro-Reactors” (NRC 2020-TN6710),
issued October 2020.
The NRC staff should also consider the guidance in this ISG along with that in Regulatory Guide
(RG) 4.2,1 Preparation of Environmental Reports for Nuclear Power Stations (NRC 2024-TN7081), when
preparing EISs. While RG 4.2 is directed at applicants preparing licensing applications, it was updated
more recently than the Environmental Standard Review Plan (ESRP; NUREG-1555; NRC 2000, 2007TN614) and, therefore, reflects more current guidance for some issues. For example, guidance in
ISG-026 (NRC 2014-TN3767) and ISG-027 (NRC 2014-TN3766) has already been incorporated into
RG 4.2. In addition, the staff has drafted changes to RG 4.2 to address the use of the NR GEIS (NRC
2024-TN7080) and Table C-1 of 10 CFR Part 51 Subpart A (TN250).
In its environmental report (ER), a new reactor applicant may reference generic analyses in NUREG-2249
(NRC 2024-TN7080) if the proposed project meets certain conditions described below. If the conditions
are met, the NRC staff would issue an EIS for the proposed action that is a supplement to the NR GEIS.

1

Unless stated otherwise, references to RG 4.2 in this document refer to DG-4032, the draft revision to
RG 4.2, which is being published at the same time as this draft ISG.

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This ISG focuses on identifying considerations and approaches to better align the environmental reviews
with the unique aspects of new reactors that reference the NR GEIS and Table C-1 of 10 CFR Part 51
Subpart A. This ISG outlines what the NRC staff considers to be an appropriate scope and level of detail
for the specific aspects of the staff’s environmental review that references generic conclusions in the
NR GEIS (NRC 2024-TN7080).
The scope of this ISG is limited to environmental review considerations specific to a new reactor that
references the NR GEIS. The NRC staff should review other guidance documents, such as ISG-026
(NRC 2014-TN3767), ISG-027 (NRC 2014-TN3766), and ISG-029 (NRC 2020-TN6710), for guidance
related to other aspects of the review, such as the following:
• preapplication interactions
• purpose and need for the proposed project
• mitigation
• need for power and alternatives
• fuel cycle impacts, transportation of fuel and waste, and continued storage of spent fuel
• cumulative impact analysis
• consistency with safety licensing documents
• incorporation by reference
The NRC staff will continue to look for other opportunities to effectively streamline environmental reviews
and work with prospective applicants to identify opportunities to streamline ERs and still meet the NRC’s
regulations. In addition, on a 10-year cycle, the Commission intends to review the material in the
NR GEIS and the associated rule and update it if necessary.
II.

BACKGROUND

The NR GEIS (NRC 2024-TN7080) was prepared to address impact analyses for the environmental
issues common to many new reactors2 that can be addressed generically, thereby eliminating the need to
repeatedly reproduce the same analyses each time a licensing application is submitted and allowing
applicants and NRC staff to focus future environmental review efforts on issues that can only be resolved
once a site is identified. The NR GEIS identifies environmental impact issues for which generic analysis
was possible, and impact issues that require project-specific analyses.
New reactors are not defined on the basis of specific technologies, purposes, power outputs, or sizes and
may include light water reactors (LWRs), non-LWRs, and small modular reactors (SMRs). These reactor
technologies vary with respect to fuel used, neutron moderators employed, cooling processes, and other
factors. Future reactors might serve various possible purposes, such as generating electrical power for
sale to the public or supplying a specific facility or installation such as a military base. In addition, a new
reactor may have a cogeneration purpose (supplying electricity to the public and thermal power to an
industrial facility), or a specific non-electricity purpose, such as desalinating water.

2

In SRM SECY-23-0001, dated April 13, 2023, the Commission directed the NRC staff to regulate
near-term fusion systems under the 10 CFR Part 30 byproduct material framework. Therefore, the
NR GEIS does not address the environmental impacts of fusion systems and such systems are not
addressed in this ISG.
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SMRs are generally defined as reactor units with an electrical output of less than 300 megawatts-electric
that are produced using modular fabrication and construction techniques. The terms “unit” and “module”
both refer to a reactor and are used interchangeably in this ISG. A non-LWR is generally defined as a
nuclear power reactor using a coolant other than water. An SMR can be a LWR or a non-LWR. A new
reactor may also be a microreactor recognized by Department of Energy (DOE) as generating less than
20 megawatts-electric.
There are two approaches to developing an ER to support environmental reviews of new reactor
applications. The first approach would be for the ER and the associated SEIS to incorporate by the
reference the applicable findings from the NR GEIS (NRC 2024-TN7080). The second approach would be
for an applicant to prepare its ER without referencing the NR GEIS, and the staff would, in its associated
EIS, evaluate all of the issues without relying on the analysis in the NR GEIS. In a new reactor EIS, the
staff should use the same three-level standard of significance (SMALL, MODERATE, and LARGE) that is
used for a license renewal EIS. These impact categories are defined in a footnote to Table B-1 of 10 CFR
Part 51 Subpart A (TN250).
Non-LWR designs (e.g., high-temperature gas-cooled, liquid-metal, and molten-salt reactors) will present
some unique issues associated with environmental analyses of the impacts of operation. While the ESRP
(NRC 2000, 2007-TN614); ISGs-026, -027, and -029 (NRC 2014-TN3767, NRC 2014-TN3766, and NRC
2020-TN6710, respectively); and Sections A through D of RG 4.2 (NRC 2024-TN7081) do not specifically
address non-LWRs, most of the guidance contained in them could be used for such reactors. Exceptions
would include areas such as accidents, fuel cycle, transportation of radioactive materials, and
decommissioning, which are addressed in the NR GEIS (NRC 2024-TN7080). The ER for a non-LWR
reactor may reference the NR GEIS in accordance with the guidance related to the GEIS.
Section 1.4.1 of the NR GEIS (NRC 2024-TN7080) describes the methodology used by the NRC staff to
develop the GEIS. In summary, the staff developed generic analyses that evaluated the environmental
impacts of building, operating, and decommissioning a nuclear reactor sited anywhere within the United
States and its territories, bounded by specific values and assumptions. Because new reactors are not
specific to only one reactor design and could be sited anywhere in the United States and its territories that
meets NRC siting requirements as set forth in 10 CFR Part 100 (TN282), the NRC decided to pursue a
technology-neutral, performance-based approach using a plant parameter envelope (PPE). The PPE
consists of parameters for specific reactor design features regardless of the site. Examples of parameters
include the footprint of disturbance, building height, water use, air emissions, employment levels, and
noise-generation levels. For each PPE parameter, the staff developed a set of bounding values and
assumptions.
In addition, the staff developed a set of site-related parameters termed the site parameter envelope
(SPE). Examples of parameters include the site size, size of water bodies supplying water to the reactor,
and demographics of the region surrounding the site. For each SPE parameter, the staff developed a set
of bounding values and assumptions related to the condition of the affected environment, such as the
extent and occurrence of wetlands and floodplains, position near aquatic features, and proximity to
sensitive noise receptors. The NR GEIS (NRC 2024-TN7080) presents generic analyses that evaluate the
possible impacts of a reactor that fits within the bounds of the PPE on a site that fits within the bounds of
the SPE. The PPE and SPE are presented in Appendix G of the NR GEIS.
In the NR GEIS (NRC 2024-TN7080), the staff identified specific types of impacts relevant to each of 16
environmental resource areas. Each type of impact is termed an issue. Each issue corresponds to a
specific type of environmental impact determined by the staff that could potentially result from
construction, operation, or decommissioning of a nuclear reactor. For each issue, the staff then
determined whether it would be possible to identify values and assumptions in the PPE and SPE that

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could effectively bound a meaningful generic analysis and provided the basis for each value and
assumption. The staff then performed and described their generic analyses for each issue for a
hypothetical reactor/site that meets the PPE and SPE values and assumptions. For the NR GEIS, the
values and assumptions were set such that the staff could reach a generic conclusion of SMALL adverse
impacts, which are designated as Category 1 issues (i.e., issues for which a generic analysis was
possible). Issues for which the impacts are beneficial are also designated as Category 1.
After considering potential values and assumptions for the PPE and SPE for some environmental impact
issues, the staff could not reach a generic conclusion. In some cases, this was due to requirements of
other statutes, such as the National Historic Preservation Act (NHPA; 54 U.S.C. §§ 300101 et seq.;
TN4157) and the Endangered Species Act (ESA; 16 U.S.C. §§ 1531 et seq.; TN1010). In other cases, the
wide range of potential reactor designs and potential site locations made it impossible for the staff to
reach a generic conclusion. These issues are designated as Category 2 issues, which would require a
project-specific analysis in an NRC EIS.
In summary, the categories for the issues are as follows:
• Category 1 issues – environmental issues for which the NRC has been able to make a generic finding
of SMALL adverse environmental impacts, or beneficial impacts, provided that the applicant’s
proposed reactor facility and site meet or are bounded by the relevant values and assumptions in the
PPE and SPE that support the generic finding for that Category 1 issue.3
• Category 2 issues – Environmental issues for which a generic finding regarding the environmental
impacts cannot be reached because the issue requires the consideration of project-specific
information that can only be evaluated once the proposed site is identified. The impact significance
(i.e., SMALL, MODERATE, or LARGE) for these issues will be determined in a project-specific
evaluation.
In addition, , there are two issues for which the state of the science is currently inadequate, and no
generic conclusion on human health impacts is possible. These are designated as N/A (i.e., impacts are
uncertain), which are neither Category 1 nor 2 (NRC 2024-TN7080).
III.

APPLICABILITY

This ISG is applicable to the environmental reviews for licensing actions for new reactors that reference
the NR GEIS. Specifically, this ISG applies to environmental reviews for new reactors associated with CP,
and OL applications submitted under 10 CFR Part 50 (TN249), and with ESP and COL applications under
10 CFR Part 52 (TN251). Elements of this ISG may also be applicable to other types of projects.
Applicants are encouraged to discuss this applicability during the preapplication phase. This ISG also
provides the framework for conducting impact analyses and preparing sections for a project-specific
SEIS. The ISG also provides for (1) the verification of an applicant’s demonstration that values and
assumptions of the PPE and SPE are met or bounded and (2) the consideration of new and significant
information for Category 1 issues.
IV.

PAPERWORK REDUCTION ACT

This ISG provides voluntary guidance for implementing the mandatory information collections in 10 CFR
Part 51 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et. seq.). These
3

Beneficial impacts may include increased tax revenues associated with the increased assessed value of
new reactor projects, and other economic activity such as increases in local employment, labor income,
and economic output.
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information collections were approved by the Office of Management and Budget (OMB), approval number
3150-0021. Send comments regarding this information collection to the FOIA, Library, and Information
Collections Branch (T6-A10M), U.S. Nuclear Regulatory Commission, Washington, DC 20555 0001, or by
e-mail to Infocollects.Resource@nrc.gov, and to the OMB reviewer at: OMB Office of Information and
Regulatory Affairs (3150-0021), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 17th
Street, NW Washington, DC 20503.
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless the document requesting or requiring the collection displays a currently valid OMB
control number.
V.

GUIDANCE

This ISG uses the following format:
1. Introduction to the environmental impact statement
2. Description of the proposed action and alternatives
3. Guidance for individual resource areas
4. Comparing alternatives to the proposed action
5. Summary and conclusions
Chapter 1: and Chapter 2: guide the description of the proposed action, the development of the purpose
and need for the proposed action, and the identification of reasonable alternatives to the proposed action.
Chapter 3: addresses the analysis of environmental impacts, including the affected environment. It guides
the review of the potential environmental impacts associated with reactor construction, operation, and
decommissioning. Chapter 4: addresses the evaluation of the alternatives to authorizing the new reactor
and the comparison of the proposed action with reasonable alternatives. Chapter 5 summarizes the
conclusions regarding the environmental impacts of authorizing the new reactor.
The guidance in Chapter 3: of this ISG also addresses Category 1 and 2 issues and the search for new
and significant information, including providing guidance regarding the following:
• evaluation of the applicant’s process for identifying and evaluating new information
• evaluation of information submitted by members of the public during the scoping process, and
information identified during the environmental review to determine whether new information is
significant
• verification of the information provided by the applicant to demonstrate that the applicable values and
assumptions for an issue have been met
• identification of the information required to complete a project-specific review of all Category 2 issues,
as well as Category 1 issues for which (1) the values and assumptions have not been met or
bounded and/or (2) new and significant information has been identified
• preparation of analysis and conclusions for the SEIS
The following sources of information should be considered by the authors of the sections of the SEIS:
• applicant’s ER

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• the NR GEIS, NUREG-2249 (NRC 2024-TN7080)
• previous NRC final EISs and other environmental documents (e.g., SEISs)
• applicant’s Safety Analysis Report or Updated Final Safety Analysis Reports
• scoping comments
• NRC Safety Evaluation Reports
• other Federal, State, and local agencies, including formal and informal consultations
• other reliable information sources
General Instructions for Developing a SEIS to the NR GEIS
See the Introduction to the ESRP (NRC 2000, 2007-TN614) for general instructions. The NRC staff
expects the U.S. Army Corps of Engineers (USACE) to be a cooperating agency with the NRC for new
reactor licensing reviews. There could also be other cooperating agencies. Each reviewer should
coordinate the review of their resource area with the reviewers for any cooperating agency. In addition, if
the proposed project is to be co-located with an existing plant, the reviewer should coordinate with other
NRC staff as appropriate on any recent or ongoing issues and reviews at the existing plant. Throughout
the process of developing the SEIS, each reviewer should coordinate with other reviewers for issues that
overlap between resource areas (“review interfaces in the ESRP”). However, each reviewer should look
for unique interfaces for new reactors that go beyond those in the ESRP. The reviewer should initiate this
coordination early in the review process to understand how their resource may relate to other subject
areas.
Each reviewer should begin by reading the sections in the ER and NR GEIS (NRC 2024-TN7080) for their
resource area, as well as the direction provided in RG 4.2 (NRC 2022-TN7081), the latest version of the
ESRP (including the draft sections published for use and comment in 2007 [NRC 2000, 2007-TN614]),
and any applicable ISGs. The guidance in the ESRP (NRC 2000, 2007-TN614), ISG-026 (NRC 2014TN3767), ISG-027 (NRC 2014-TN3766), ISG-029 (NRC 2020-TN6710), and RG 4.2 is generally
applicable to new reactors, as modified below.
The reviewers typically visit the proposed and alternative sites to gather additional information to support
the preparation of the SEIS. However, such site visits may not always be necessary for every resource
area. The reviewer should consider the information provided in the ER and other information that has
been gathered (e.g., from preapplication interactions and scoping) to determine whether a site visit is
warranted. For example, if all of the issues for a given resource area are Category 1, and the relevant
values and assumptions have been met, a site visit may not be warranted. The reviewers also typically
participate in a site audit to review documents held by the applicant. The scope of the site audit should be
limited to the information the reviewer has determined is needed to complete the review for the resource
area. If, after completion of the audit, the reviewer still requires more information, then a request for
additional information should be developed. These processes are similar to past staff practice, except that
the scale of the activities may be adjusted for Category 1 issues for which the applicant has demonstrated
that the relevant PPE and SPE values and assumptions have been met.

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Chapter 1:

Introduction to the Environmental Impact Statement

This section provides guidance for the preparation of the Chapter 1, Introduction, for the proposed
project’s environmental impact statement. The Introduction includes a brief description of the proposed
action, the review process, the purpose and need for the proposed action, and the status of reviews,
approvals, and consultations that the project must obtain or complete. The reviewer for this chapter
should be familiar with the associated guidance in the ESRP (NRC 2000, 2007-TN614), ISG-026 (NRC
2014-TN3767), ISG-027 (NRC 2014-TN3766), ISG-029 (NRC 2020-TN6710), and RG 4.2 (NRC 2024TN7081).
NRC regulations at 10 CFR Part 51 (TN250) provide the information that must be included in an EIS
prepared by the Commission to meet its responsibilities under the National Environmental Policy Act of
1969 (NEPA; 42 U.S.C. §§ 4321 et seq.; TN661). In appropriate cases, the format for an EIS may expand
upon or differ from the format in 10 CFR Part 51. The introduction should describe the format and
organization of the EIS. The reviewer should identify the applicant, describe the proposed action, and
describe the NRC’s NEPA process, including how the staff will develop a SEIS tiering to the NR GEIS
(NRC 2024-TN7080). The introduction should also present the NRC’s definition of purpose and need.
Finally, the NRC staff must consider the concerns and requirements of other agencies that have
regulatory authority over the proposed project.
The purpose and need for some new reactors may be unlike the purpose and need that has been typical
for large light-water cooled reactors. RG 4.2, “Preparation of Environmental Reports for Nuclear Power
Stations” (NRC 2024-TN7081), provides additional guidance related to purpose and need in Part C,
Section 1.2, and in Appendix C, Section C.2.1. A discussion of purpose and need is also found in
Section 1.4 of the NR GEIS (NUREG-2249; NRC 2024-TN7080). The purpose and need as defined in the
EIS is the Commission’s purpose and need and may differ from the purpose and need defined by the
applicant in its ER.
The material to be prepared is informational in nature; no specific analysis of the data is required.
However, the Chapter 1 author should consult with the reviewers for Need for Power and Alternatives to
confirm that the purpose and need is consistent with the evaluations of the need for power and the
alternatives. In addition, the Chapter 1 author should consult with all other technical reviewers to ensure
that the list and status of reviews, approvals, and consultations is accurate and current. RG 4.2, Part C,
Chapter 1 and Appendix C, Section C.2.1 (NRC 2024-TN7081) provide guidance related to the contents
of the Introduction.

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Chapter 2:

Description of Proposed Action and Alternatives

This section provides guidance for the preparation of the discussion of alternatives and the proposed
action. The proposed action is also discussed in general terms in the Introduction to the SEIS. The
reviewer for this chapter should be familiar with the associated guidance in the ESRP (NRC 2000, 2007TN614), ISG-026 (NRC 2014-TN3767), ISG-027 (NRC 2014-TN3766), ISG-029 (NRC 2020-TN6710),
and RG 4.2 (NRC 2024-TN7081). The NR GEIS (NRC 2024-TN7080) does not address alternatives for a
specific project.
The purpose of this section is to (1) provide a more detailed description of the proposed action for the
SEIS and (2) provide a brief description of the alternatives.
Issuance of a license or permit to build and operate a nuclear reactor is defined in 10 CFR Part 51
(TN250) as a major Federal action requiring the preparation of an EIS. The introductory paragraphs
prepared for this chapter should clearly define the action and provide the readers with background
information related to the proposed action.
This chapter should discuss the no-action alternative, the proposed action, and a reasonable range of
alternatives to the proposed agency action. Alternatives should be included that will avoid or minimize
adverse effects upon the quality of the human environment while still meeting the purpose of the
proposed action. The discussion in this chapter should provide basic information about the alternatives
and supports the comparison of the proposed action and the reasonable alternatives later in the SEIS.
The chapter should also briefly describe alternatives that the staff concluded were not reasonable (i.e.,
would not meet the purpose and need for the project), explaining the basis for this conclusion. The
discussion of each alternative should provide enough information for a reader to understand how its
impact was determined and should also be summarized in a table, to make comparisons clear to the
reader.
Much of the required material may be taken directly from the applicant’s ER. The reviewer should reflect
the applicant’s schedule for activities for the proposed project.

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Chapter 3:

Affected Environment and Environmental Impacts

General Guidance for All Resource Area Reviewers
This section provides guidance for the preparation of the discussion of the affected environment, as well
as the impacts of building, operating, and decommissioning the proposed project. After discussing some
guidance that is applicable to most of the individual resource areas, this section provides
resource-specific guidance.
The scope of Chapter 3 of the SEIS includes (1) a description of the affected environment for the
proposed site and the surrounding region over which impacts will be felt, and (2) analysis of the
environmental impacts that will result from building, operating, and decommissioning the proposed
project.
The review conducted under this section leads to preparation of a portion of the SEIS describing the
affected environment that provides background information that will then be used in evaluating the
environmental impacts of project construction, operations, and decommissioning.
The NR GEIS (NRC 2024-TN7080) does not explicitly discuss the affected environment because the
affected environment is site-specific. However, many of the values and assumptions in the SPE involve
the affected environment. Each reviewer should briefly describe those aspects of the environment
related to their resource area that could be affected by the proposed project. The description of the
affected environment should be brief and focus only on providing sufficient information to support
(1) demonstrating whether relevant PPE and SPE values and assumptions for Category 1 issues are met
and (2) the evaluation of the environmental impacts of Category 2 issues, and any Category 1 issues for
which the associated values and assumptions are not met, or for which new and significant information
has been identified.
In the NR GEIS, the staff treated climate change and cumulative impacts as issues that cut across
multiple resources (NRC 2024-TN7080). Both of these issues are Category 2 issues, requiring projectspecific analyses. All reviewers should be familiar with current guidance (e.g., the ESRP (NRC 2000,
2007-TN614), ISG-026 [NRC 2014-TN3767], and RG 4.2 [NRC 2024-TN7081]), and with the most recent
new reactor EISs to determine how to integrate these issues into the analyses for their resource area(s).
For example, the water resource reviewer should consider whether changes in water availability due to
cumulative impacts and climate change would affect the demonstration that some values and
assumptions are met. As another example, the terrestrial and aquatic ecology reviewers should consider
how reasonably projected changes in seasonal temperatures and precipitation could affect the
demonstration that some values and assumptions are met.
An applicant, and the staff, may rely on the generic analysis in the NR GEIS (NRC 2024-TN7080) for any
Category 1 issue for which the applicant can demonstrate that the relevant values and assumptions of the
PPE and SPE have been met, and for which no new and significant information has been identified.
Therefore, this demonstration is a key aspect related to the use of the NR GEIS. See Table C-1 in
Appendix C to Subpart A of 10 CFR Part 51 (TN250) for a list of which values and assumptions are
relevant to each environmental issue. See RG 4.2, Appendix C, including its Table C-1-1, for guidance
about how an applicant can demonstrate that it meets each of the values and assumptions (NRC 2024TN7081).

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Demonstrating Consistency with PPE/SPE Values
The NRC reviewer should use the application, information from scoping, the site audit, and other
available information to determine whether each value and assumption on which the applicant is relying
has been demonstrated as being met. In addition, because the same value or assumption may be used
for multiple resource areas, the reviewer should coordinate with other reviewers evaluating the
demonstration for that value or assumption. The complexity of the demonstration varies considerably. For
example, it is simple for an applicant to demonstrate that it meets the value for building height. However,
the demonstration for groundwater drawdown at the site boundary will require a detailed analysis. While
RG 4.2, Appendix C (NRC 2024-TN7081), provides guidance to the applicants for an acceptable method
to demonstrate that any given value or assumption is met, applicants may choose to use a different
method. In such a case, the reviewer must determine whether the alternate method used by the applicant
is an effective method for demonstrating that the value or assumption is met.
The NR GEIS included the assumption that the USACE would be a cooperating agency for any new
reactor SEIS. The NR GEIS did not, therefore, distinguish between the impacts of NRC-authorized
construction, and preconstruction. The values and assumptions in the PPE and SPE also include, and
do not differentiate between, the impacts of NRC-authorized construction and preconstruction. If, for a
particular new reactor review, there is no Federal cooperating agency, then the impacts of
preconstruction would be considered cumulative impacts. However, the reviewer must still include both
NRC-authorized construction and preconstruction when it is evaluating whether the values and
assumptions in the PPE and SPE have been met.
In the SEIS, the reviewer should briefly document how the PPE/SPE values and assumptions for
Category 1 issues are met using a level of detail appropriate to the complexity of the analysis4. If all of the
relevant values and assumptions for a Category 1 issue are met, then the staff may rely on the generic
conclusion of SMALL impacts in the NR GEIS for that issue, incorporating the analysis in the GEIS by
reference (NRC 2024-TN7080). Cite the pages of the NR GEIS containing the relevant generic analyses,
but it is not necessary to summarize or paraphrase the analyses.
If any of the values and assumptions relevant to a Category 1 issue are not met, or if new and significant
information has been identified for the issue, then the reviewer cannot rely on the generic analysis in the
NR GEIS for that issue. The reviewer should complete a project-specific analysis in accordance with the
latest version of the ESRP, ISGs, and RG 4.2. The reviewer may incorporate all or a portion of the
generic analysis in the NR GEIS, expanding it to account for project-specific information. For Category 2
issues, the reviewer should complete a project-specific analysis in accordance with the latest version of
the ESRP, ISGs, and RG 4.2.
New and Significant Information
The regulation at 51.75(d) requires the NRC staff to address any new and significant information that
changes the conclusions in the NR GEIS. For a Category 1 issue, new information is information that was
not available or available but not considered in the assessment of impacts evaluated in the GEIS. Such
information is significant if it could lead to a change in the environmental consequences of the action from
that codified in Table C-1. New and significant information may also be information that identifies a
significant environmental impact issue that was not considered or addressed in the NR GEIS (NRC 2024TN7080) and, consequently, not codified in Table C-1, “Summary of Findings on Environmental Issues for
Issuing a Permit or License for a New Nuclear Reactor,” in Appendix C, “Environmental Effect of Issuing a
4

As used in this document, when the staff states that the project meets a value or assumption of the PPE
or SPE, it should be read as to mean that the project meets or is bounded by the value or assumption.

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Permit or License for a New Nuclear Reactor,” to Subpart A, “National Environmental Policy Act—
Regulations Implementing Section 102(2),” of 10 CFR Part 51 (TN250). When no new and significant
information is found, a statement should be included in the SEIS that briefly describes the search for and
evaluation of new information and states that no new information was identified or the new information
was determined not to be significant.
The NRC staff must identify any new and significant information related to the environmental impacts of
new reactor licensing. Other interested parties may also identify new and significant information during
the scoping and public comment periods. The process for identifying new and significant information
should include the following:
• The applicant’s ER. Applicants are required by 10 CFR 51.50(d) to disclose new and significant
information of environmental impacts of the project of which they are aware and describe the process
it used to search for new and significant information. The process for identifying new information
could include the review of environmental monitoring reports, scientific literature, interviews with
applicant staff, discussions with licensees and other peer groups and industry organizations,
consultations with experts knowledgeable about the local environment, and consultations with other
Federal, State, local, and Tribal environmental, natural resource, permitting, and land use agencies.
In reviewing the applicant’s ER, NRC staff must evaluate the applicant’s process for discovering and
evaluating the significance of any new information. Is the process adequate to ensure a reasonable
likelihood that the applicant would be aware of new information, if it existed? The applicant need not
include detailed supporting documentation in the ER about the discovery of new and significant
information, but such information should be available for review by the NRC staff.
• Records of public meetings and correspondence related to the application, including scoping.
Compare information presented by the public with information considered in the NR GEIS (NRC
2024-TN7080). Is the information new in the sense that the posted dates of the analysis are later than
the analysis conducted for the GEIS, and if so, does that information change the GEIS’s conclusions
with regard to the affected Category 1 issue?
• Environmental quality standards and regulations. Have the applicable environmental quality
standards and regulations changed since the analysis conducted for the NR GEIS (NRC 2024TN7080)? If so, do the changes in the standards and regulations change the GEIS’s conclusions with
regard to the affected Category 1 issue?
• Technical literature. Does recent technical literature contain information that would change
conclusions in the NR GEIS (NRC 2024-TN7080) for Category 1 issues? Does the information
indicate that there may be environmental impacts that were not considered in the GEIS?
The reviewer should be familiar with the guidance in the ESRP (NUREG-1555; NRC 2000, 2007-TN614)
and other guidance documents related to the process for identifying new and significant information. Any
new information should be used to develop an analysis of the relevant environmental impact issues. After
the impact issues have been defined, the significance level of each issue should be determined using the
significance level definitions in Table B-1 of 10 CFR Part 51 (TN250). Appropriate mitigation measures
should be identified and considered for each issue for which there is an adverse environmental impact.
The consideration of mitigation measures should be in proportion to the potential adverse impact.
If the reviewer’s analysis shows that the impact category is changed to greater than SMALL (i.e.,
MODERATE or LARGE), the reviewer should prepare an impact assessment for inclusion in the
appropriate section of the project-specific SEIS. The assessment should include a concise description of
the new environmental impact information (including source) and how this information applies to the
nuclear plant. The statement also should list any mitigation measures that would be considered
appropriate. A summary statement and a list of references cited in the impact assessment also should be
provided.

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Impact Conclusions in the SEIS
The staff should include in the SEIS a table listing all environmental issues that are applicable to the
project, whether each issue is deemed a Category 1 or 2 issue, and an explicit statement about whether
or not the issue can be generically resolved (i.e., the relevant PPE and SPE values and assumptions are
met and no new and significant information was identified). An example of such a table including different
issues and scenarios is presented below:

Table 3-1

Issue

Environmental Issues Applicable to the Project
Section of the
Supplemental
Environmental
Impact Statement
(SEIS) Where the
Issue Is Analyzed

Is the Issue a
Category 1 or a
Category 2
Issue?

Can the Issue Be
Generically Resolved?

Onsite Land Use

xxx

Category 1

Yes. All plant parameter
envelope (PPE) values
and assumptions in Table
C-1 are met.

Surface Water Use
Conflicts during
Construction

xxx

Category 1

No. Information provided
by the applicant indicates
that the total plant water
demand exceeds the PPE
threshold of 6,000 gpm.

Important Species
and Habitats –
Resources Regulated
under the
Endangered Species
Act of 1973

xxx

Category 2

No. All Category 2 issues
require site-specific
analysis.

If the reviewer concludes that the applicant has demonstrated that all of the relevant values and
assumptions have been met for one or more Category 1 issue in their resource area, and that there is no
new and significant information, then a determination similar to the following should be included in the
SEIS:
The NRC staff, based on its review of [state sources such as: [APPLICANT’S] ER, the
site audit, the scoping process, and responses to requests for additional information
(RAIs)], concludes that [APPLICANT] has demonstrated that the relevant PPE/SPE
values and assumptions for the following Category 1 issues have been met; [LIST
CATEGORY 1 ISSUES]. The NRC has not identified any information or impacts related
to these issues that would change the generic conclusions presented in the NR GEIS.
Therefore, based on the generic analyses presented in the NR GEIS, the staff concluded
that the impact level for each of these issues is SMALL.
For Category 2 issues, and for any Category 1 issue for which any of the relevant values and
assumptions are not met, or for which new and significant information has been identified, the reviewer
should follow the guidance in the ESRP (NRC 2000, 2007-TN614), applicable ISGs, and RG 4.2 (NRC
2024-TN7081) to develop the appropriate conclusion.

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LAND USE
The existing land use guidance in Section 3.0 above, the ESRP (NRC 2000, 2007-TN614), applicable
ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors. Before writing, the
reviewer should inspect any ground-level or aerial (or satellite) photography and maps covering the site
and surrounding area included in the application or readily available in online databases. Useful online
databases include the U.S. Geological Survey database of 7.5-minute topographic map coverage, the
Natural Resources Conservation Service database of soil survey map coverage, and the Flood Insurance
Management Agency database of flood insurance rate maps. The reviewer should identify potentially
sensitive land use features on or adjacent to the site or any associated offsite rights-of-way (ROWs) or
project outparcels. Sensitive land use features include National and State parks, local parks, preserves,
and conservation areas, Wild and Scenic River segments, American Heritage Rivers, Class I areas
designated under the Clean Air Act (42 U.S.C. §§ 7401 et seq.; TN1141), 100-year floodplains, and
riparian lands. Ensure that sensitive land use features are identified out to the distances from the site
(and offsite ROWs and outparcels) necessary to determine whether the assumptions established in the
NR GEIS regarding land use issues are met. Obtain copies of the zoning maps and any comprehensive
land use plans for each local jurisdiction(s) for the site.
Even when relying on the NR GEIS (NRC 2024-TN7080) for all land use issues, the site-specific text for
land use should still open with some basic data that will support the review of other resources as well.
Present basic statistics regarding the site that will be used by multiple reviewers, such as the site
acreage; the length, width, and acreage of any associated ROWs; acreage and location of any affected
outparcels such as borrow pits; the cities, counties, and other local jurisdictions involved; and the distance
of the site from key landmarks such as cities, major rivers and lakes, and arterial highways. The text
should briefly characterize existing land uses on the site (and offsite ROWs and outparcels) and adjacent
properties as well as the predominant existing land uses in the surrounding landscape. The text or maps
should indicate each local jurisdiction encompassing all or part of the site and surrounding landscape.
The text should indicate the site’s ownership and briefly explain any ownership issues such as leases,
easements, or ROWs. Enough general information about the site’s location and position in the landscape
should be provided to set the tone for descriptions prepared by the reviewers for other resources.
The impact assessment should use text and/or tables to quantify and briefly describe the proposed
footprint of disturbance, including any areas of disturbance only for purposes of grading or clearing
vegetation. Distinguish between the permanent and temporary footprints of disturbance. Present the
footprints of disturbance in a figure. Address offsite outparcels in the manner used for the site, but the
footprints of disturbance for ROWs may be presented in a more generalized manner. For example,
disturbances within an ROW can be described broadly, such as stating that building a new transmission
line would involve clearing a specific width of vegetation and placing poles at a specified distance, with a
disturbance of a specified area per pole. Indicate, however, if any disturbance will take place in sensitive
land use features.
The land use section must document compliance with the Farmland Protection Policy Act (7 U.S.C.
§§ 4201 et seq.; TN708) and the Coastal Zone Management Act (16 U.S.C. §§ 1451 et seq.; TN1243).
Even when using the generic analysis in the NR GEIS (NRC 2024-TN7080) to address the prime and
unique farmland issue, state why the action is exempt from the Farmland Protection Policy Act or
document evidence of compliance. If the project is not exempt, initiate communication (written and/or
electronic) with the Natural Resources Conservation Service to determine what actions the staff or
applicant must perform to comply. In the text, cite and summarize any farmland evaluations performed
and mitigation measures recommended. If any elements of the project fall within areas designated as
Coastal Zone, summarize communications between the staff and applicant. Indicate whether the
State has issued a Consistency Determination. Cite and briefly summarize the Consistency

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Determination. If all the project site and any associated offsite ROWs or outparcels are situated outside
of areas designated as part of the Coastal Zone, state so.
The NR GEIS identifies all land use environmental issues as Category 1 (NRC 2024-TN7080). The
reviewer should address each of these issues as described in the General Instructions for this chapter.
After reviewing the application materials and the information gained through scoping and the site audit,
use the guidance in RG 4.2, Appendix C (NRC 2024-TN7081), to identify each issue for which the
applicant has adequately demonstrated that relevant PPE and SPE values and assumptions are met. For
each such issue, indicate that the generic analysis provided in the GEIS is applicable and state that the
staff concludes that impacts would be SMALL. Cite the pages of the NR GEIS containing the relevant
generic analyses, but it is not necessary to summarize or paraphrase the analyses. Briefly explain how
the assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
VISUAL RESOURCES
The existing visual resources guidance in Section 3.0 above, the ESRP (NRC 2000, 2007-TN614),
applicable ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors. Even
when relying on the NR GEIS for visual issues, the reviewer should be sure to identify any offsite features
such as transmission lines, access roads, and pipelines, as well as related actions on outparcels. The
reviewer should inspect any ground-level or aerial (or satellite) photography covering the site and
surrounding area included in the application or readily available in online databases. Useful online
resources include the aerial photography included in web-based applications such as Google Earth and
the U.S. Geological Survey database of 7.5-minute topographic map coverage. The review should extend
to enough of the surrounding area to identify potentially sensitive viewsheds that could be affected by the
project, and the determination will need to account for factors such as topography, vegetation (including
winter or “leaf-off” vegetation), and climatological factors such as haze, fog, or clouds.
The visual resources section should begin with a brief discussion of the visual sensitivity of the landscape
surrounding the site and offsite ROWs and parcels and briefly identify sensitive viewsheds used for the
analysis. Visual simulations, in which an image of the proposed new facilities is superimposed onto a
baseline photograph taken from one or more sensitive viewpoints, are rarely necessary, even for projects
that do not meet all of the PPE and SPE values and assumptions needed to rely on the generic analysis
in the NR GEIS (NRC 2024-TN7080). The need for any visual simulations would typically be driven by
public comments or the potential for intervention.
The NR GEIS identifies all visual environmental issues as Category 1 (NRC 2024-TN7080). The reviewer
should address each of these issues as described in the General Instructions for this chapter. After
reviewing the application materials and the information gained through scoping and the site audit, use the
guidance in RG 4.2, Appendix C (NRC 2024-TN7081), to identify each issue for which the applicant has
adequately demonstrated that relevant PPE and SPE values and assumptions are met. For each such
issue, indicate that the generic analysis provided in the GEIS is applicable and state that the staff
concludes that impacts would be SMALL. Cite the pages of the NR GEIS containing the relevant generic
analyses, but it is not necessary to summarize or paraphrase the analyses. Briefly explain how the
assumptions are met.

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For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
METEOROLOGY AND AIR QUALITY
The existing air quality guidance in Section 3.0 above, the ESRP (NRC 2000, 2007-TN614), applicable
ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors.
The air quality and meteorology reviewer should coordinate with the environmental justice reviewer to
provide meteorological data, such as wind rose maps, and air quality information important to the
determination of the disproportionately large and adverse impacts on minority or low-income
communities. The air quality and meteorology reviewer should also coordinate with the noise impacts
reviewer to provide data on baseline and expected noise levels during the building and operations of the
proposed project to determine potential human health impacts and coordinate impacts from construction
and operation traffic impacts. The air quality and meteorology reviewer should coordinate with the
ecologists to share data regarding salt deposition on terrestrial and aquatic habitats and should
coordinate with any reviewer concerned with visual impacts from cooling tower plumes. The air quality
reviewer should coordinate with the reviewers for decommissioning, fuel cycle, and transportation of
waste and fuel.
If the project is in an area that is not in attainment, or is a maintenance area, the reviewer should verify
the applicant provided estimates of emissions of criteria pollutants, hazardous air pollutant and
greenhouse gases during construction and operation activities. In such a case, the emissions from
vehicular traffic and standby nonelectric generators related to construction and operation should be
reviewed. Finally, the reviewer should review the applicant’s applicability analysis to determine whether a
General Conformity Determination is needed.
The NR GEIS identifies all air quality environmental issues as Category 1 (NRC 2024-TN7080). The
reviewer should address each of these issues as described in the General Instructions for this Chapter.
After reviewing the application materials and the information gained through scoping and the site audit,
use the guidance in RG 4.2, Appendix C (NRC 2024-TN7081), to identify each issue for which the
applicant has adequately demonstrated that relevant PPE and SPE values and assumptions are met. For
each such issue, indicate that the generic analysis provided in the GEIS is applicable and state that the
staff concludes that impacts would be SMALL. Cite the pages of the NR GEIS (NRC 2024-TN7080)
containing the relevant generic analyses, but it is not necessary to summarize or paraphrase the
analyses. Briefly explain how the assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
WATER RESOURCES
The existing guidance relative to water resources in Section 3.0 above, the ESRP (NRC 2000, 2007TN614), applicable ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors.
As discussed in the general guidance provided above, each reviewer should review the information in the

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applicant’s ER related to water resources that may be included in or used by other sections and interface
with the subject matter experts of those sections, as needed. These sections may include geology,
terrestrial resources, aquatic ecology, land use, environmental hazards, waste management, postulated
accidents, socioeconomics, environmental justice, and decommissioning. For water resources, the
reviewer may need to review the following information to ensure that PPE and SPE values and
assumptions for Category 1 issues have been met and that the data provided in the ER is sufficient and
appropriate for use in the environmental review:
• site and vicinity maps
• water resources datasets and descriptions
• site location in relation to water features
• regional surface and subsurface characterizations
• nearby surface and groundwater use and quality data included in the ER or readily available online
databases
• flood-related data like Federal Emergency Management Agency flood insurance rate maps, historical
floods, water levels, and inundation areas
These data and information are readily available from agencies like U.S. Geological Survey, State
departments that regulate natural resources and the environment, Federal Emergency Management
Agency, National Oceanic and Atmospheric Administration (NOAA), and Great Lakes Environmental
Research Laboratory. This information should be included, as needed, in the SEIS to support the
discussion of Category 1 hydrological issues.
The reviewer should verify that the plant’s hydrologic setting description includes potential interfaces with
surface water features and groundwater aquifers and sufficient surface and groundwater data to establish
baseline conditions regarding high and low water flows and groundwater levels, water users and
quantities, water quality, instream flow requirements, and transport characteristics.
As indicated in the general guidance above, the reviewer should normally participate in a site visit unless
the plant’s interface with the hydrologic environment is minimal (e.g., a small plant that has all water
withdrawal and wastewater discharge needs provided by a municipal service may not require a site visit).
If a site visit is performed, the reviewer should do the following if needed to confirm that the PPE and SPE
values and assumptions for Category 1 issues have been met:
• View surface water features including withdrawal or discharge locations; groundwater well locations;
coastal or littoral areas; streamflow, water levels, and water quality monitoring locations; and the
locations of plant’s proposed interfaces with the hydrologic environment.
• Discuss current and future water use plans (including those related to the project), sensitive issues
that affect water use and quality, and water availability of regional surface water, groundwater, and
municipal sources with water planning and permitting agencies.
The permits related to water use, in-water construction, and impacts on water quality may require
coordination among several local, regional, State, and Federal agencies (e.g., city governments, water
conservation districts, State departments that regulate natural resources and the environment, the U.S.
Environmental Protection Agency [EPA], USACE). At the time of the application and the staff’s review, the
processes to obtain permits required for construction and operation of the plant may be in various stages
of completion. The reviewer should obtain an understanding of these processes, describe these
processes in the section, and use specific information related to these processes in the project-specific
SEIS, as needed.

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The impacts assessment for water resources should include a clear description of total plant water
withdrawal and discharge including daily rates. The quantities or rates of water withdrawn from all
proposed sources for all plant uses should be clearly and individually identified for (1) plant construction
and (2) plant operations. Similarly, the rates of discharge, the water quality of the discharge flows, and the
receiving water bodies should be clearly and individually identified for construction and operations.
The NR GEIS identified environmental issues related to water use and water quality that may arise from
construction and operations activities for a proposed power plant (NRC 2024-TN7080). With the
exception of surface water quality degradation due to chemical and thermal discharges during operations,
the NRC staff determined that the identified water resources issues are Category 1. Impacts for all
Category 1 issues were determined by the staff to be SMALL when the applicable PPE/SPE parameter
values and associated assumptions are met. For each Category 1 issue, use the application materials
and information gained through scoping and the site audit to evaluate whether the proposed plant
parameters and site characteristics meet the PPE/SPE values and assumptions applicable to the issue,
as defined in the relevant NR GEIS section (NRC 2024-TN7080). For some PPE/SPE values this
evaluation may be relatively simple, e.g., establishing that the total plant water demand is less than
6,000 gallons per minute. Some PPE/SPE values or assumptions may require a more complex
evaluation, e.g., establishing that plant groundwater withdrawals result in less than one foot of drawdown
at the site boundary. Consult RG 4.2 (Addendum 1 of Appendix C) for guidance on methods of
demonstrating that the PPE/SPE values and assumptions have been met (NRC 2024-TN7081). Consult
the ESRP (NRC 2000, 2007-TN614) for guidance on reviewing technical information. When the PPE/SPE
values and assumptions are met, briefly document the staff’s evaluation using a level of detail appropriate
to the complexity of the analysis. In this case, the generic analysis included in the NR GEIS (NRC 2024TN7080) is applicable for this issue and the impacts would be SMALL.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
Surface water quality degradation due to chemical and thermal discharges during operations was
determined in the NR GEIS to be a Category 2 issue with SMALL, MODERATE, or LARGE impacts
depending on project-specific characteristics (NRC 2024-TN7080). The NR GEIS does not include a
generic analysis for this issue because impacts from chemical and thermal discharges require
consideration of project-specific information on a case-by-case basis. This review should follow existing
guidance included in the ESRP (NRC 2000, 2007-TN614), RG 4.2 (NRC 2024-TN7081), and ISGs, as
applicable.
TERRESTRIAL ECOLOGY
The existing terrestrial ecology guidance in Section 3.0 above, the ESRP (NRC 2000, 2007-TN614),
applicable ISGs, RGs 4.11 and 4.2 (NRC 2012-TN1967 and NRC 2024-TN7081, respectively) may
generally be followed for new reactors. The terrestrial ecology reviewer should coordinate with other
reviewers such as the water resource reviewer, radiation human health and waste reviewer, air quality
reviewer, and aquatic ecology reviewer.
Using information in the ER, the reviewer should identify terrestrial and wetland habitats present on the
site and offsite ROWs and outparcels and gain an understanding of the types of terrestrial habitats
present in the surrounding landscape. The reviewer should review any wetland delineations and maps
included with the ER and verify that the applicant has a plan for obtaining any necessary jurisdictional

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determinations and wetland permits from the USACE and State agencies that regulate wetlands. The
reviewer should be able to assign a terrestrial or wetland habitat type to each land area on the site(s) and
ROWs. If basic information about terrestrial and wetland habitats is not provided, the reviewer should
request that information from the applicant. The reviewer should identify each terrestrial species and
habitat meeting the definition of “important” in the ecology sections of RG 4.2 (NRC 2024-TN7081).
Unless the applicant effectively demonstrates that the project would alter only paved areas or areas
previously occupied by buildings or other man-made structures, the terrestrial reviewer should normally
participate in a site visit. Depending on the complexity of the potentially affected habitats, it might be
possible for only one ecologist, terrestrial or aquatic, to participate in the site visit.
The terrestrial ecology section should open with a brief description of the affected ecoregions and then
proceed to a general description and map of the terrestrial and wetland habitats on the site(s), ROWs,
and surrounding landscapes. Incorporation by reference of a habitat map and habitat descriptions from
the ER or other sources is acceptable, especially if the assessment of impacts on terrestrial resources will
be relying on the generic evaluations in the NR GEIS (NRC 2024-TN7080) for all or most Category 1
terrestrial ecology issues. Incorporation by reference of species lists using the ER and other published
sources is encouraged even if some terrestrial ecology issues will be addressed individually rather than
by relying on the generic analyses. Using text or a table, the reviewer should identify each species or
habitat determined to be “important” but should refer the reader to the ER or to other widely available
published information sources for descriptive life history information.
The impact assessment text for terrestrial ecology should open with a brief description of what terrestrial
habitats would be lost as a result of building the new reactor and supporting facilities, including offsite
facilities. The text should include, or incorporate by reference, a figure overlaying the proposed footprint
of disturbance over a baseline map of terrestrial and wetland habitats and a table that quantifies losses by
habitat type, distinguishing between permanent and temporary losses. The text should also briefly
indicate how the action could affect each important species and habitat, citing the ER or other sources
wherever possible and using a table if more than a few important species and habitats are involved. The
reviewer should coordinate with the radiological environmental reviewer for the radiological impacts on
terrestrial species.
The NR GEIS identifies most terrestrial ecology issues, other than impacts on Federally listed threatened
or endangered species, as Category 1 (NRC 2024-TN7080). The reviewer should address each of these
issues as described in the General Instructions for this chapter. After reviewing the application materials
and the information gained through scoping and the site audit, use the guidance in RG 4.2, Appendix C
(NRC 2024-TN7081), to identify each issue for which the applicant has adequately demonstrated that
relevant PPE and SPE values and assumptions are met. For each such issue, indicate that the generic
analysis provided in the GEIS is applicable and state that the staff concludes that impacts would be
SMALL. Cite the pages of the NR GEIS containing the relevant generic analyses, but it is not necessary
to summarize or paraphrase the analyses. Briefly explain how the assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
Resources regulated under the ESA is a Category 2 issue and should be addressed by following
guidance in RG 4.2 (NRC 2024-TN7081), the ESRP (NRC 2000, 2007-TN614), and applicable ISGs. The
terrestrial reviewer is responsible for working with the aquatic reviewer to complete the consultations
required under ESA Section 7. Completion of the consultation typically requires early informal

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communications with the Service agencies that administer the Section 7 process, including the U.S. Fish
and Wildlife Service (FWS) and NOAA Fisheries Service (sometimes referred to as the National Marine
Fisheries Service) and may involve preparation of a Biological Assessment.
AQUATIC ECOLOGY
The existing aquatic ecology guidance in Section 3.0 above, the ESRP (NRC 2000, 2007-TN614),
applicable ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors. The
aquatic ecology reviewer should coordinate with other reviewers such as the water resource reviewer,
radiation human health and waste reviewer, air quality reviewer, and terrestrial ecology reviewer.
The aquatic reviewer should begin by reading the aquatic ecology sections in the ER and NR GEIS (NRC
2024-TN7080), the terrestrial ecology direction provided in RG 4.2 (NRC 2024-TN7081), the latest
version of the ESRP, and applicable ISGs. The reviewer should also read RG 4.24 (NRC 2017-TN6720),
especially if the applicant submitted aquatic field studies with the application. The reviewer should also
read sections of the ER addressing related issues such as terrestrial ecology, hydrology, and land use to
seek out information relevant to aquatic ecology. The reviewer should inspect any ground-level or aerial
(or satellite) photography covering the site and surrounding area included in the application or readily
available in online databases. Other useful information might be available from online databases,
including the U.S. Geological Survey database of 7.5-minute topographic map coverage. The reviewer
should inspect any maps of the site and surrounding landscape provided with the application or readily
available online. If reviewers are unfamiliar with the aquatic ecology of the portion of the United States
where the project (and alternatives) is proposed, they should read about the ecoregion(s) involved using
data available from the EPA. Becoming familiar with other scientific literature about the regional
ecological setting of the project site and alternatives may also be appropriate.
Using information in the ER, the reviewer should identify aquatic habitats present on the site and offsite
ROWs and gain an understanding of the types of aquatic habitats present in the surrounding landscape.
Aquatic habitats can include oceans, estuaries, lakes, ponds, reservoirs, rivers, perennial and intermittent
streams, springs, and other surface water features. For purposes of NRC environmental reviews,
wetlands with emergent vegetation are generally addressed as terrestrial habitats, while wetlands with
only submerged aquatic vegetation are generally addressed as aquatic habitats (see RG 4.24 [NRC
2017-TN6720]). In addition to the aquatic habitats themselves, the reviewer should use topographic maps
and available aerial photography to identify and characterize the specific watersheds occurring within and
around the site and offsite ROWs. The aquatic reviewer should communicate with the terrestrial reviewer
to ensure that the applicant has a plan for obtaining any necessary jurisdictional determinations and
permits from the USACE and State agencies that regulate waters of the United States or the State. If
basic information about aquatic habitats is not provided, the reviewer should request the information from
the applicant. The reviewer should identify each aquatic species and habitat meeting the definition of
“important” in the ecology sections of RG 4.2 (NRC 2024-TN7081). Unless the proposed action does not
involve disturbance of aquatic habitats or their associated shorelines and riparian areas and does not
involve any surface water withdrawals or discharges, the aquatic reviewer should normally participate in a
site visit. Depending on the complexity of the potentially affected habitats and impacts, it might be
possible for only one ecologist, terrestrial or aquatic, to participate in the site visit.
The aquatic ecology section should open with a brief description of the typical aquatic biota in affected
ecoregions and then proceed to a general description and map of the aquatic habitats (and their
associated watersheds) on the site(s), ROWs, and surrounding landscapes. Site-specific information
characterizing aquatic biota in specific aquatic habitats is not normally necessary for habitats not subject
to direct physical disturbance or the building and operation of intake or discharge structures. Incorporation
by reference of habitat descriptions from the ER or other sources may be acceptable even for aquatic

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habitats subject to physical disturbance or intake or discharge structures, especially if the assessment of
impacts on terrestrial resources will be relying on the generic evaluations in the NR GEIS (NRC 2024TN7080) for all or most Category 1 terrestrial ecology issues. Incorporation by reference of species lists
using the ER and other published sources is encouraged. Using text or a table, the reviewer should
identify each species or habitat determined to be “important” in those aquatic habitats subject to physical
disturbance, intakes, or discharges. However, the reviewer should refer the reader to the ER or other
widely available published information sources for any necessary descriptive life history information.
The impact assessment text for aquatic ecology should open with a brief description of what aquatic
habitats would be disturbed as a result of building the new reactor and supporting facilities, including
offsite facilities. The text should include, or incorporate by reference, a figure overlaying the proposed
footprint of disturbance over a baseline map of aquatic habitats. The figure should prominently depict the
proposed locations for any intake or discharge structures, including any riparian land or submerged land
subject to physical disturbance. The text should also briefly indicate how the action could affect each
important species and habitat (only address those adversely affected), citing the ER or other sources
wherever possible and using a table if more than a few important species and habitats are involved. The
reviewer should address impacts caused by development in the watershed as well as directly
encroachment into the aquatic habitats themselves. The text should briefly summarize the findings of
relevant technical studies such as discharge plume modeling or water level drawdown modeling, but the
reviewer is encouraged to reference the ER or other technical documents submitted by the applicant for
details. The reviewer is also encouraged to reference any applicable National Pollutant Discharge
Elimination System permits for details regarding permitted discharge parameters and monitoring
requirements. The reviewer should coordinate with the radiological environmental reviewer for the
radiological impacts on aquatic species.
The NR GEIS identifies most aquatic ecology issues as Category 1 (NRC 2024-TN7080). The reviewer
should address each of these issues as described in the General Instructions for this chapter. After
reviewing the application materials and the information gained through scoping and the site audit, use the
guidance in RG 4.2, Appendix C (NRC 2024-TN7081), to identify each issue for which the applicant has
adequately demonstrated that relevant PPE and SPE values and assumptions are met. For each such
issue, indicate that the generic analysis provided in the GEIS is applicable and state that the staff
concludes that impacts would be SMALL. Cite the pages of the NR GEIS containing the relevant generic
analyses, but it is not necessary to summarize or paraphrase the analyses. Briefly explain how the
assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
Thermal impacts on aquatic biota, other effects of cooling water discharges on aquatic biota, and
resources regulated under the ESA and Magnuson Stevens Act are Category 2 issues and should be
addressed following guidance in RG 4.2 (NRC 2024-TN7081) and the ESRP (NRC 2000, 2007-TN614).
The aquatic reviewer is responsible for completing any consultations required under the Magnuson
Stevens Act, including preparing any technical reports required to complete the consultation. The aquatic
reviewer is also responsible for working with the terrestrial reviewer to complete the consultations
required under ESA Section 7. Completion of the consultation typically requires early informal
communications with the Service agencies that administer the Section 7 process, including the FWS and
NOAA Fisheries Service (sometimes referred to as the National Marine Fisheries Service) and may
involve preparation of one or more Biological Assessments.

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HISTORIC AND CULTURAL RESOURCES
The existing guidance for historic and cultural resources in Chapter 3: above, the ESRP (NRC 2000,
2007-TN614), applicable ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new
reactors. Historic and cultural resources are the remains of past human activities and include precontact
(i.e., prehistoric) and historic era archaeological sites, districts, buildings, structures, and objects.
Precontact era archaeological sites predate the arrival of Europeans in North America and may include
small temporary camps, larger seasonal camps, large village sites, or specialized-use areas associated
with fishing or hunting or with tool and pottery manufacture. Historic era archaeological sites post-date
European contact with American Indian Tribes and may include farmsteads, mills, forts, residences,
industrial sites, and shipwrecks. Architectural resources include buildings and structures. Historic and
cultural resources also include elements of the cultural environment such as landscapes, sacred sites,
and other resources that are of religious and cultural importance to American Indian Tribes, such as
traditional cultural properties important to a living community of people for maintaining its culture.
A historic or a cultural resource is deemed to be historically significant, and thus, a “historic property”
within the scope of the NHPA (54 U.S.C. §§ 300101 et seq.; TN4157), if it has been determined to be
eligible for listing or is listed on the National Register of Historic Places (NRHP or National Register). The
NRHP is maintained by the U.S. National Park Service in accordance with its regulations in 36 CFR
Part 60 (TN1682). The NRHP criteria for evaluating the eligibility of a property are set forth in 36 CFR
60.4. A historic property is at least 50 years old, although exceptions can be made for properties
determined to be of “exceptional significance.”
NEPA requires Federal agencies to consider the potential effects of their actions on the “affected human
environment,” which includes “aesthetic, historic, and cultural resources as these terms are commonly
understood, including such resources as sacred sites” (CEQ and ACHP 2013-TN4603). For NEPA
compliance, impacts on cultural resources that are not eligible for or listed in the National Register should
also be considered (CEQ and ACHP 2013-TN4603). The Advisory Council on Historic Preservation
(ACHP) is an independent Federal agency that oversees the NHPA Section 106 review process and
issues its implementing regulations in 36 CFR Part 800, “Protection of Historic Properties” (36 CFR Part
800-TN513). Section 106 of the NHPA requires Federal agencies to take into account the effects of their
undertakings on historic properties and consult with the appropriate consulting parties as defined in 36
CFR 800.2. Consulting parties consist of the State Historic Preservation Officer, ACHP, Tribal Historic
Preservation Officer, American Indian Tribes that attach cultural and religious significance to historic
properties on a government-to-government basis, and other parties that have a demonstrated interest in
the effects of the undertaking, including local governments and the public, as applicable. Issuing a license
for a new reactor is an undertaking that requires compliance with NHPA Section 106 (54 U.S.C. §
306108-TN4839).
In the NR GEIS, the staff determined that historic and cultural resources is a Category 2 issue, requiring
a project-specific analysis (NRC 2024-TN7080). The reviewer should be familiar with existing guidance
regarding historic and cultural resources in the NR GEIS, ESRP, ISG-026 (NRC 2014-TN3767), ISG-029
(NRC 2020-TN6710), and RG 4.2, including RG 4.2 Appendixes B and C. The reviewer should also be
familiar with the methods the NRC staff has used to address impacts on historic and cultural resources in
recent new reactor EISs.

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ENVIRONMENTAL HAZARDS
3.8.1 Radiological Environment
The existing radiological environment guidance in Chapter 3: above, the ESRP (NRC 2000, 2007TN614), applicable ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors.
The reviewer should coordinate with the terrestrial and aquatic ecology reviewers and should also
coordinate with the corresponding safety reviewers for radiation protection program, radiological
monitoring (occupational and effluents), radiological waste management, and accidents to ensure
consistency between the reviews and to coordinate any necessary audits and information requests.
To present the reader with a baseline understanding, the radiological environment section should begin
with a general description of the sources of radiation and pathways of exposure. This section should also
present a summary of information regarding the property bounding the facility, known site radiological
contamination either at the site itself or in proximity to the site, summary accident information, and a brief
overview of the facility emergency plans.
A description of the appropriate radiological protection standards (regulations), facility radiological
protection programs, and any health effect studies performed in the region should follow. Section 3.8 of
the NR GEIS contains a list of applicable radiological protection regulations (NRC 2024-TN7080).
Additionally, any proposed facility program designed to minimize or manage radiological emissions or
exposures should be briefly mentioned.
The impact assessment text for the radiological environment should define the occupational and public
health impacts during construction and operation from radiological exposures, and then outline any
proposed mitigation measures. This section should summarize and explain monitoring results or modeling
results and occupational monitoring program. The radiological environment section should provide the
reader with enough information to determine that the applicable regulations are met or will be met, and
that the applicant is being cognizant in maintaining the safety and health of its occupational workers and
members of the public.
Summary information regarding a general description of sources and pathways of exposure,
environmental protection standards, programs, and occupational and health impacts should be presented
even for a project for which all the relevant PPE and SPE values and assumptions in the NR GEIS (NRC
2024-TN7080) for the radiological environment are met because the information is relevant to assessing
impacts on environmental resources other than radiological environment.
The NR GEIS identifies all radiological environment issues as Category 1 (NRC 2024-TN7080). The
reviewer should address each of these issues as described in the General Instructions for this chapter.
After reviewing the application materials and the information gained through scoping and the site audit,
use the guidance in RG 4.2, Appendix C (NRC 2024-TN7081), to identify each issue for which the
applicant has adequately demonstrated that relevant PPE and SPE values and assumptions are met. For
each such issue, indicate that the generic analysis provided in the GEIS is applicable and state that the
staff concludes that impacts would be SMALL. Cite the pages of the NR GEIS containing the relevant
generic analyses, but it is not necessary to summarize or paraphrase the analyses. Briefly explain how
the assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the

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conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
3.8.2 Nonradiological Environment
The existing nonradiological environment guidance in Chapter 3: above, the ESRP (NRC 2000, 2007TN614), applicable ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors.
The reviewer should identify potentially sensitive receptors on or adjacent to the site or any associated
offsite ROWs or project outparcels. Sensitive receptors may include hospitals, schools, daycare facilities,
and elderly care facilities. Ensure that sensitive receptors are identified out to the distances from the site
(and offsite ROWs and outparcels) necessary to determine whether the assumptions established in the
NR GEIS regarding the nonradiological environment are met. The reviewer should be able to identify
sources and pathways of chemical exposure, biological hazards, electromagnetic field (EMF) exposure
and physical hazards.
To present the reader with a baseline understanding, the nonradiological environment section should
begin with a general description of the sources (such as types of chemicals) and pathways of exposure.
This section should also present brief summary information regarding the property bounding the facility,
known site contamination either at the site itself or in proximity to the site, summary accident information,
if available, and a brief description of emergency plans.
A description of the appropriate environmental protection regulations, facility programs, facility permits,
and any health effect studies performed in the region should follow. Regulations, such as the Clean Air
Act, the Clean Water Act (codified as the Federal Water Pollution Control Act of 1972, 33 U.S.C.
§§ 1251 et seq.; TN662), and the Occupational Safety and Health Act (29 U.S.C. §§ 651 et seq.;
TN4453), which establish practices, procedures, exposure limits, and equipment specifications, should be
discussed, along with any permits (obtained or applied for) associated with applicable regulations.
Additionally, any proposed facility program designed to minimize or manage chemical hazards, biological
hazards, EMFs, or physical hazards should be briefly mentioned.
The impact assessment text for the nonradiological environment should define the occupational and
public health impacts during construction and operation from chemical hazards, biological hazards, EMF,
and physical hazards, and then outline any proposed mitigation measures. This section should
summarize and explain monitoring results or modeling results and detail occupational injury rates or
occupational fatality rates. Even when using the generic analysis in the NR GEIS (NRC 2024-TN7080) to
address nonradiological environmental hazards, list the permits the applicant has or has applied for and
state the regulation each permit is intended to meet. The nonradiological environment section should
provide the reader with enough information to determine that the applicable regulations and permits are
met or will be met, and that the applicant is cognizant in maintaining the safety and health of its
occupational workers and members of the public.
Summary information regarding the general description of sources and pathways of exposure,
environmental protection standards, programs, and permits, and occupational and health impacts should
be presented even for projects where all the PPE and SPE values and assumptions for the
nonradiological environment are met in the NR GEIS (NRC 2024-TN7080), because the information is
relevant to assessing impacts on environmental resources other than the nonradiological environment.
The NR GEIS identifies four environmental issues (NRC 2024-TN7080). Building impacts of chemical,
biological, and physical nonradiological hazards, and construction impacts of chemical, biological, and
physical nonradiological hazards are classified as Category 1 issues. The reviewer should address each

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of these issues as described in the General Instructions for this chapter. After reviewing the application
materials and the information gained through scoping and the site audit, use the guidance in RG 4.2,
Appendix C (NRC 2024-TN7081), to identify each issue for which the applicant has adequately
demonstrated that relevant PPE and SPE values and assumptions are met. For each such issue, indicate
that the generic analysis provided in the GEIS is applicable and state that the staff concludes that impacts
would be SMALL. Cite the pages of the NR GEIS (NRC 2024-TN7080) containing the relevant generic
analyses, but it is not necessary to summarize or paraphrase the analyses. Briefly explain how the
assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
The building impacts of EMF and the operations impacts of EMF are classified as uncertain because
there is no generic conclusion about human health impacts from EMFs and there are no U.S. Federal
standards limiting residential or occupational exposure; however, a reviewer should look for new scientific
information about EMFs that may allow for a categorization of the issue.
NOISE
The existing noise guidance in Chapter 3: above, the ESRP (NRC 2000, 2007-TN614), applicable ISGs,
and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors.
The noise section should present basic statistics regarding construction and operation activities at the site
that may generate noise, including the results of any ambient noise studies that have been conducted,
including the locations of noise sources, receptor locations, and corresponding noise levels. The noise
section should also document compliance with State and/or local noise abatement laws and ordinances,
including any variances or mitigation required, and document any best management practices
implemented to minimize impacts. The reviewer should identify potentially sensitive receptors on or
adjacent to the site or any associated offsite ROWs or project outparcels. Ensure that sensitive receptors
are identified out to the distances from the site (and offsite ROWs and outparcels) necessary to determine
whether the assumptions established in the NR GEIS regarding noise are met.
The NR GEIS identifies all noise issues as Category 1 (NRC 2024-TN7080). The reviewer should address
each of these issues as described in the General Instructions for this chapter. After reviewing the
application materials and the information gained through scoping and the site audit, use the guidance in
RG 4.2, Appendix C (NRC 2024-TN7081), to identify each issue for which the applicant has adequately
demonstrated that relevant PPE and SPE values and assumptions are met. For each such issue, indicate
that the generic analysis provided in the GEIS is applicable and state that the staff concludes that impacts
would be SMALL. Cite the pages of the NR GEIS containing the relevant generic analyses, but it is not
necessary to summarize or paraphrase the analyses. Briefly explain how the assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.

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WASTE MANAGEMENT
3.10.1 Radiological Waste Management
The existing guidance in Chapter 3: above, the ESRP (NRC 2000, 2007-TN614), applicable ISGs, and
RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactor radiological waste management.
The reviewer should determine the physical layout of the radiological waste systems and buildings,
especially for cases where a new reactor could be installed at an existing nuclear facility. Items to be
considered include whether the new reactor is a physically separate nuclear facility or, if there is
adequate land, whether the radiological management systems and storage structures are integrated
within the boundaries of an existing nuclear power plant or other nuclear facility. If the new reactor is a
stand-alone facility, the space needed to store onsite radiological wastes would be within the planned
footprint of the facility. If the new reactor is sited at an existing nuclear facility, the existing radiological
waste infrastructure and management program would need to be reviewed to ensure the existing facility
can likely support the additional radiological wastes generated by the new reactor. This aspect of the
radiological waste management environmental review must be closely coordinated with the safety review.
The reviewer should be familiar with the Commission’s licensing requirements for the land disposal of
low-level radioactive waste (LLRW) as set forth in 10 CFR Part 61 (TN252), “Licensing Requirements for
Land Disposal of Radioactive Waste.” Specifically, the review should ensure the applicant is adhering to
how Part 61 defines LLRW as “radioactive waste not classified as high-level radioactive waste,
transuranic waste, spent nuclear fuel, or byproduct material as defined in paragraphs (2), (3), and (4) of
the definition of byproduct material set forth in § 20.1003 of this chapter” and has established a
classification system that categorizes LLRW as Class A, B, C, or Greater Than Class C according to the
NRC’s regulation in 10 CFR 61.55. Under the NRC’s current regulations, Greater Than Class C waste is
considered to be generally unacceptable for near-surface disposal and must be disposed of in a geologic
repository unless the Commission approves, on a case-by-case basis, disposal of such waste in a
disposal site licensed pursuant to 10 CFR 61.55(a)(2)(iv). Additionally, as described in the NR GEIS
(NRC 2024-TN7080), the reviewer should be familiar with the Low-Level Waste Compacts (NRC 2020TN7083) and the four operating disposal facilities in the United States that are licensed to accept LLRW
from commercial facilities (including nuclear power plants) (NRC 2020-TN6516) and which ones the new
reactor licensee, if approved, could engage for LLRW disposal.
Regarding high-level waste, the reviewer should determine if the reactor design has any online refueling
capabilities and any online capacity to remove fission products and other radionuclides (such as activated
corrosion products) for a liquid-fueled molten-salt reactor. For spent nuclear fuel storage, the reviewer
should evaluate the impacts for the facility, either in a spent fuel pool or in non-water-based spent nuclear
fuel storage with an appropriate holding period and transfer to a dry cask storage in an at-reactor
independent spent fuel storage installation (ISFSI) under a general license or a stand-alone ISFSI under
specific license. If the reactor core is handled as one unit, the reviewer should assess the environmental
impacts for onsite spent nuclear fuel storage of the depleted core in a similar manner.
For mixed wastes, the reviewer needs to coordinate the review with the environmental nonradiological
waste management reviewer because mixed wastes are also regulated under the Resource Conservation
and Recovery Act of 1976, as amended (RCRA; 42 U.S.C. §§ 6901 et seq.; TN1281) and are subject to
dual regulation by the EPA or an authorized State for their hazardous chemical components. As for
LLRW, the reviewer should verify that any mixed waste is accumulated onsite in designated areas as
authorized under RCRA, then shipped offsite for treatment as appropriate, and for disposal at either the
EnergySolutions or the Waste Control Specialists, LLC facilities.

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The NR GEIS identifies all radiological environment issues as Category 1 (NRC 2024-TN7080). The
reviewer should address each of these issues as described in the General Instructions for this chapter.
After reviewing the application materials and the information gained through scoping and the site audit,
use the guidance in RG 4.2, Appendix C (NRC 2024-TN7081), to identify each issue for which the
applicant has adequately demonstrated that relevant PPE and SPE values and assumptions are met. For
each such issue, indicate that the generic analysis provided in the GEIS is applicable and state that the
staff concludes that impacts would be SMALL. Cite the pages of the NR GEIS (NRC 2024-TN7080)
containing the relevant generic analyses, but it is not necessary to summarize or paraphrase the
analyses. Briefly explain how the assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the latest version of the
ESRP for guidance on impact assessment. For LLRW, compare the expected annual quantities of LLRW
to the total annual quantity shipped to the appropriate disposal site as provided in Tables 3.15-5 and
3.15-6 the NR GEIS (NRC 2024-TN7080). If the quantity of LLRW is a small percentage of the disposal
site’s total annual quantity (e.g., less than 5 percent), then the impacts should be concluded as SMALL.
For each issue, the reviewer should present the conclusion (SMALL, MODERATE, or LARGE) and
provide a brief rationale, incorporating information from the NR GEIS by reference wherever possible.
3.10.2 Nonradiological Waste Management
The existing nonradiological waste guidance in Chapter 3: above, the ESRP (NRC 2000, 2007-TN614),
applicable ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors.
The reviewer should inspect any maps of the site and surrounding landscape provided with the
application or online in order to determine the locations of receptors (occupational workers or members of
the public) and identify potentially sensitive receptors on or adjacent to the site or any associated offsite
ROWs or project outparcels. Sensitive receptors may include hospitals, schools, daycare facilities, and
elderly care facilities. Ensure that sensitive receptors are identified out to the distances from the site (and
offsite ROWs and outparcels) necessary to determine whether the assumptions established in the NR
GEIS regarding nonradiological waste are met. The reviewer should be able to identify management
plans for gaseous, liquid, and solid wastes generated by facility processes.
The nonradiological waste section should begin with a general description of the sources of waste by type
(gaseous, liquid, and solid forms) that would occur during construction or operation. This section should
present how the waste is stored, whether it is stored onsite, and how it is treated. For instance, gaseous
waste is generally treated by running it through a scrubber or filter and discharging it through exhaust
stacks; while liquid waste, such as sanitary waste sewage, is piped to a permitted municipal sewage
treatment facility. If the new reactor is co-located with a LLRW- or other nonradiological waste-producing
facility, this section should present information defining hazardous and nonhazardous waste disposal
amounts over the past 5 years with estimated amounts by year for the new reactor, identify onsite storage
capacity, and the disposal company or facility where applicable. If the new reactor is not co-located, the
section should present information defining hazardous and nonhazardous waste disposal estimates by
year, identify onsite storage capacity, and the disposal company or facility where applicable. The reviewer
should determine the physical layout of the nonradiological waste systems and buildings, especially for
cases where a new reactor could be installed at an existing facility, and inspect any waste management
plans or permits listed in the application or those available via State or Federal agency websites.
The discussion should include a description of the appropriate environmental protection standards
(regulations), facility programs, facility permits, and any relevant health effect studies. Regulations such
as the Clean Air Act, Clean Water Act, and RCRA, should be discussed, along with any permits (obtained

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or applied for), associated with applicable regulations. Additionally, any proposed facility program
designed to minimize or manage nonradiological waste should be briefly mentioned.
The impact assessment text for the nonradiological waste management section should define the
nonradiological waste impacts during construction and operation, the outline any proposed mitigation
measures.
The NR GEIS identifies all nonradiological environment issues as Category 1 (NRC 2024-TN7080). The
reviewer should address each of these issues as described in the General Instructions for this chapter.
After reviewing the application materials and the information gained through scoping and the site audit,
use the guidance in RG 4.2, Appendix C (NRC 2024-TN7081), to identify each issue for which the
applicant has adequately demonstrated that relevant PPE and SPE values and assumptions are met. For
each such issue, indicate that the generic analysis provided in the GEIS is applicable and state that the
staff concludes that impacts would be SMALL. Cite the pages of the NR GEIS (NRC 2024-TN7080)
containing the relevant generic analyses, but it is not necessary to summarize or paraphrase the
analyses. Briefly explain how the assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
POSTULATED ACCIDENTS
The existing guidance for postulated accidents in Chapter 3: above, the ESRP (including the draft
sections published in 2007 [NRC 2000, 2007-TN614]), applicable ISGs, and RG 4.2 (NRC 2024-TN7081)
may generally be followed for new reactors. In addition to these documents, the reviewer should base the
review of accidents on the Commission’s Policy Statement “Nuclear Power Plant Accident Considerations
Under National Environmental Policy Act of 1969” (45 FR 40101-TN4270), NUREG-0800 (NRC
2007/2019-TN6221), 10 CFR Part 50 (TN249), 10 CFR Part 52 (TN251), 10 CFR Part 100 (TN282), RGs
1.200 (NRC 2009-TN6211), 1.145 (NRC 1983-TN279), 1.183 (NRC 2000-TN517) and 1.233 (NRC 2020TN6441), other probabilistic risk assessment guidance, and the Final Safety Analysis Report/Preliminary
Safety Analysis Report (FSAR/PSAR), as appropriate. If there is the potential for accidents involving
releases of hazardous chemicals, the reviewer should apply 40 CFR Part 68 (TN5494) and 40 CFR Part
355 (TN5493); NUREG-1520 (NRC 2015-TN6822) may also provide useful information. When evaluating
the radiological and hazardous chemical releases from postulated accidents, the reviewer should
consider the design’s safety features and analyses, including the results of a probabilistic risk
assessment, as appropriate, and as presented in the applicant’s FSAR/PSAR. The reviewer should also
coordinate the review of such postulated radiological and hazard chemical accidents with the NRC safety
reviewers. The results of the NRC safety reviews will be published in the Final Safety Evaluation Report
for the new reactor application.
The NR GEIS identifies postulated accidents issues as Category 1, except for severe accidents, which
were identified as a Category 2 issue (NRC 2024-TN7080). The reviewer should address each of the
Category 1 issues as described in the General Instructions for this chapter. After reviewing the application
materials and the information gained through scoping and the site audit, use the guidance in RG 4.2,
Appendix C (NRC 2024-TN7081), to identify each issue for which the applicant has adequately
demonstrated that relevant PPE and SPE values and assumptions are met. For each such issue,
indicate that the generic analysis provided in the GEIS is applicable and state that the staff
concludes that impacts would be SMALL. Cite the pages of the NR GEIS (NRC 2024-TN7080)

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containing the relevant generic analyses, but it is not necessary to summarize or paraphrase the
analyses. Briefly explain how the assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the latest version of the
ESRP for guidance on impact assessment. If the PPE values and assumptions for accidents involving
releases of hazardous chemicals are exceeded and a new reactor facility has the potential to release
hazardous chemicals from licensed operations, then the analysis in the ER that contains the estimates of
the consequences to members of the public in the event of such a release should be reviewed. This
review should be coordinated with the NRC safety reviewers. Generally available information about
protective emergency guidelines can also be useful when characterizing the consequences (e.g., Acute
Exposure Guideline Levels [AEGLs], Emergency Response Planning Guidelines [ERGPs], Temporary
Emergency Exposure Limits [TEELs], or Protective Action Criteria for Chemicals [PACs]). Relevant
analysis prepared for compliance with other State or Federal regulations (e.g., a Risk Management Plan
submitted under 40 CFR Part 68 [TN5494]) should be reviewed as applicable. If the reviewer determines
that the new reactor satisfies the protective emergency guidelines, the conclusion of SMALL should be
presented along with a brief rationale. Incorporate information from the NR GEIS (NRC 2024-TN7080) by
reference wherever possible.
The NR GEIS (NRC 2024-TN7080) identifies severe accidents as a Category 2 issue, which means that a
meaningful generic analysis of environmental impacts is not possible because the issue requires
consideration of project-specific information. Based on the analysis in the FSAR/PSAR regarding severe
accidents and probabilistic risk assessments, if a new reactor design has severe accident progressions
that involve radiological or hazardous chemical releases, then an environmental risk evaluation must be
performed. The review of the environmental risk evaluation should be coordinated with the NRC safety
reviewers and carried out in accordance with the existing guidance discussed above.
SOCIOECONOMICS
The existing socioeconomic guidance in Chapter 3:above, the ESRP (NRC 2000, 2007-TN614),
applicable ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors. The
socioeconomics reviewer should inspect any ground-level and aerial (or satellite) photography covering
the site and surrounding area included in the application or readily available in online databases, such as
Google Earth.
Building and operating a new reactor will most likely affect all socioeconomic resources, including the
demographic characteristics of local communities; community services including education, first
responders, healthcare, and other social services; local governments; and infrastructure concerns such
as housing resources, transportation networks, public service utilities, and recreational resources.
Following any site visit and coordination with other reviewers, the reviewer should develop the impacts
discussion of the social, economic, and infrastructure characteristics of the relevant impact area. Using
text and/or tables, the reviewer should quantify and briefly describe the proposed project’s socioeconomic
baseline conditions. The level of detail should be commensurate with the expected magnitude of potential
post-mitigation impacts on the socioeconomic resources under review.
The NR GEIS identifies all socioeconomic environmental issues as Category 1 and, while potentially
greater than SMALL, beneficial impacts are also considered Category 1 (NRC 2024-TN7080). The
reviewer should address each of these issues as described in the General Instructions for this chapter.
After reviewing the application materials and the information gained through scoping and the site audit,
use the guidance in RG 4.2, Appendix C (NRC 2024-TN7081), to identify each issue for which the

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applicant has adequately demonstrated that relevant PPE and SPE values and assumptions are met. For
each such issue, indicate that the generic analysis provided in the GEIS is applicable and state that the
staff concludes that impacts would be SMALL. Cite the pages of the NR GEIS (NRC 2024-TN7080)
containing the relevant generic analyses, but it is not necessary to summarize or paraphrase the
analyses. Briefly explain how the assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
ENVIRONMENTAL JUSTICE
The staff determined environmental justice is a Category 2 issue, requiring a project-specific analysis.
The reviewer should be familiar with existing guidance regarding environmental justice in the ESRP (NRC
2000, 2007-TN614), Office Instruction LIC-203 (NRC 2020-TN6399), ISG-026 (NRC 2014-TN3767),
ISG-029 (NRC 2020-TN6710), and RG 4.2 (NRC 2024-TN7081). The reviewer should also be familiar
with the methods the NRC staff has used to address impacts of environmental justice in recent new
reactor EISs.
FUEL CYCLE
The existing guidance in Chapter 3: above, the ESRP (NRC 2000, 2007-TN614), applicable ISGs, and
RG 4.2 (NRC 2024-TN7081) may generally be followed for the new reactor fuel cycle.
The reviewer should be familiar with the uranium fuel cycle section of the License Renewal GEIS
Section 4.12.1 (NRC 2013-TN2654), WASH-1248 (AEC 1974-TN23), NUREG-0116 (NRC 1976-TN292),
Non-LWR Fuel Cycle Environmental Data report (PNNL-29367, Rev. 2; Napier 2020-TN6443),
NUREG-2157 (NRC 2014-TN4117), and the applicable regulations. The reviewer should inspect the
information about the fuel cycle provided by the applicant and should be aware of any environmental
reviews for fuel cycle facilities that have been developed or modified to support new reactors. The
reviewer will need to coordinate with the corresponding environmental and safety reviewers along with
NRC facility licensing managers (as appropriate) of the various fuel cycle facilities licensed to support new
reactor fuels to evaluate any necessary updated fuel cycle facility and process information.
The NR GEIS identifies all fuel cycle environmental issues as Category 1 (NRC 2024-TN7080). The
reviewer should address each of these issues as described in the General Instructions for this chapter.
The impact assessment text for the fuel cycle section should compare the fuel cycle environmental data
for the new reactor to that of Table S-3, which presents environmental data for the entirety of the fuel
cycle. The reviewer should keep in mind that environmental data higher than Table S-3 for one part of the
fuel cycle may be compensated by lower impacts in other parts of the fuel cycle. The fuel cycle section
should provide the reader with enough information to determine that the applicable regulations are met or
will be met, and that the applicant is being cognizant of minimizing impacts from the fuel cycle.
Summary information regarding a general description of the fuel cycle should be presented even for
projects where all the PPE values and assumptions for the fuel cycle are met in the NR GEIS (NRC 2024TN7080) (see Appendix G) because the information is relevant to assessing impacts on environmental
resources other than for the radiological environment.

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After reviewing the application materials and the information gained through scoping and the site audit,
identify each issue for which the applicant has adequately demonstrated that relevant PPE values and
assumptions are met. For each such issue, indicate that the generic analysis provided in the GEIS is
applicable and state that the staff concludes that impacts would be SMALL. Cite the pages of the NR
GEIS (NRC 2024-TN7080) containing the relevant generic analyses, but it is not necessary to summarize
or paraphrase the analyses. Briefly explain how the assumptions are met and that there is no new and
significant information identified.
For any of the six environmental issues that may not be bounded by Table S-3, consult RG 4.2 (NRC
2024-TN7081), applicable ISGs, the latest version of the ESRP, PNNL-29367 Rev. 2 (Napier 2020TN6443), and, if necessary, NUREG-2157 (NRC 2014-TN4117) for guidance on fuel cycle impact
assessment. For each such issue, present the conclusion (SMALL, MODERATE, or LARGE) and provide
a brief rationale. If the environmental finding is MODERATE or LARGE, describe any mitigation that could
be implemented to reduce the impacts to SMALL. Incorporate information from the NR GEIS (NRC 2024TN7080) by reference wherever possible.
TRANSPORTATION OF FUEL AND WASTE
The existing guidance for the transportation of fuel and waste in Chapter 3: above, the ESRP (NRC 2000,
2007-TN614), and RG 4.2 (NRC 2024-TN7081) may generally be followed for new reactors. The reviewer
should also be familiar with WASH-1238 (AEC 1972-TN22), NUREG–75/038 (NRC 1975-TN216),
NUREG/CR-6703 (Ramsdell et al. 2001-TN4545), 10 CFR Part 71 (TN301), 49 CFR Parts 171-177
(TN5466), DOE’s Transportation Risk Assessment Handbook (DOE 2002-TN418), and Maheras (2020TN6509). Potential interfaces include reviewers involved with licensing reviews of reactor type and rated
core thermal power, the fuel assembly description, and the average irradiation level of irradiated fuel;
characteristics, treatment, and packaging systems for radioactive waste; and transportation packages and
transport modes.
Table S-4, which provided the environmental effects of transportation of fuel and waste, is only applicable
to LWRs that use uranium oxide, or UO2, fuel that meets specific criteria in 10 CFR 51.52(a) and as
extended in Section 4.12.1.1 in Revision 1 of NUREG-1437 (NRC 2013-TN2654). Reactor developers are
expected to use uranium fuel with enrichment levels of up to 20 percent enrichment, known as high-assay
low-enriched uranium, or HALEU. In addition, several of the potential non-LWR designs are expected to
deploy non-UO2 fuels (e.g., uranium metal, uranium carbide, uranium in a molten-salt, etc.) or deploy
fuels based on a Th-232/U-233 fuel cycle. While Table S-4 does not apply to non-LWRs and non-UO2
fuels, the transportation of fuel and waste is a connected action under NEPA regulations, guidance, and
case law. Therefore, the reviewer must still evaluate transportation impacts for non-LWR fuel and waste
to meet its obligations under NEPA as has been done for large LWRs using UO2 fuels. Both the
radiological and nonradiological environmental impacts from incident-free and accident conditions
resulting from (1) shipment of unirradiated fuel to the reactor site, (2) shipment of LLRW and mixed waste
to offsite disposal facilities, and (3) shipment of spent fuel to an interim storage facility or a permanent
geologic repository must be addressed by the applicant and reviewed.
Based on the criteria in 10 CFR 51.52 (TN250) and NUREG-1437 Section 4.12.1.1 (NRC 2013-TN2654),
it is unlikely that some reactor designs would satisfy the conditions to apply Table S-4. There is limited
information regarding the transportation of several forms of non-LWR fuel due to the expected higher
enrichment levels (i.e., high-assay low-enriched uranium fuel) and the physical form of the non-LWR fuel
being shipped. Accordingly, the reviewer should consider the following in the review of transportation
packages for unirradiated and irradiated non-LWR fuel and radioactive waste:
• non-LWR fresh fuel shipments likely to be similar to those for LWRs (except for molten-salt)

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• significantly different processing operations and transportation for molten-salt reactors and sodium
fast reactors than for the current reactor fleet
• uncertainty in the post irradiation forms for transport and storage
The NR GEIS identifies all transportation environmental issues as Category 1 (NRC 2024-TN7080). The
reviewer should address each of these issues as described in the General Instructions for this chapter.
After reviewing the application materials and the information gained through scoping and the site audit,
use the guidance in RG 4.2, Appendix C (NRC 2024-TN7081), to identify each issue for which the
applicant has adequately demonstrated that relevant PPE and SPE values and assumptions are met. For
each such issue, indicate that the generic analysis provided in the GEIS is applicable and state that the
staff concludes that impacts would be SMALL. Cite the pages of the NR GEIS (NRC 2024-TN7080)
containing the relevant generic analyses, but it is not necessary to summarize or paraphrase the
analyses. Briefly explain how the assumptions are met.
For Category 1 issues not meeting the PPE/SPE or for which new and significant information is identified,
the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the ESRP (NRC 2000,
2007-TN614) for guidance on impact assessment. For each issue, the reviewer should present the
conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating information from
the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
DECOMMISSIONING
The existing guidance for the impacts of decommissioning in Chapter 3: above, the ESRP (NRC 2000,
2007-TN614), applicable ISGs, and RG 4.2 (NRC 2024-TN7081) may generally be followed for new
reactors.
Reviewers should be familiar with NUREG-0586 Supplement 1 and NUREG-1496. Additionally, NUREG0586 Supplement 1 was published in 2002; decommissioning impacts have been modified in new reactor
EISs from what is presented in the version of the ESRP published in March 2000 (NRC 2000, 2007TN614). The reviewer should examine the decommissioning section in the recent new reactor EISs for
site-specific examples of this modification.
To present the reader with a baseline understanding, the site-specific decommissioning section in the
SEIS should begin with a general description of the decommissioning process. The description should
include a discussion of how the decommissioning of the new reactor could vary (if at all) from the
decommissioning process discussed in the NR GEIS (NRC 2024-TN7080). Summary information
regarding a general description of the decommissioning should be presented even for projects where all
the PPE values and assumptions for the decommissioning are met in the NR GEIS, because the
information may be relevant to assessing impacts on other environmental resources (e.g., land use,
ecology, and historical and cultural impacts).
The NR GEIS identifies decommissioning as a Category 1 issue (NRC 2024-TN7080) for those issues
that were considered in NUREG-0586 to be generic and SMALL, and Category 2 for those issues that
were identified as either project-specific or conditionally project-specific. The reviewer should address
these issues as described in the General Instructions for this chapter. After reviewing the application
materials and the information gained through scoping and the site audit, use the guidance in RG 4.2,
Appendix C (NRC 2024-TN7081), to determine whether the applicant has adequately demonstrated
that relevant PPE and SPE values and assumptions are met for the Category 1 issue and that no new
and significant information was identified. If all of the relevant values and assumptions are met,
indicate that the generic analysis provided in the GEIS is applicable and state that the staff concludes
that impacts would be SMALL. Cite the pages of the NR GEIS (NRC 2024-TN7080) containing the
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relevant generic analyses, but it is not necessary to summarize or paraphrase the analyses.
Briefly explain how the assumptions are met.
If the issue does not meet the PPE/SPE or if new and significant information was identified, and for the
Category 2 issue, the reviewer should consult RG 4.2 (NRC 2024-TN7081), applicable ISGs, and the
ESRP (NRC 2000, 2007-TN614) for guidance on impact assessment. For this issue, the reviewer should
present the conclusion (SMALL, MODERATE, or LARGE) and provide a brief rationale, incorporating
information from the NR GEIS (NRC 2024-TN7080) by reference wherever possible.
ISSUES APPLYING ACROSS ALL RESOURCES
The NR GEIS identified two issues as applying across all resource areas: climate change and cumulative
impacts (NRC 2024-TN7080). Both issues were classified as Category 2. This section provides guidance
for these two issues. The reviewer should scale the depth of review for these issues based on the
expected level of impacts on any individual resource under consideration.
3.17.1 Climate Change
The reviewer should be familiar with existing guidance regarding climate change in the ESRP (NRC 2000,
2007-TN614), ISG-026 (NRC 2014-TN3767), and RG 4.2 (NRC 2024-TN7081). The reviewer should also
be familiar with the methods the NRC staff has used to address climate change in recent new reactor
EISs.
3.17.2 Cumulative Impacts
The reviewer should be familiar with existing guidance regarding cumulative impacts in the ESRP (NRC
2000, 2007-TN614), ISG-026 (NRC 2014-TN3767), ISG-027 (NRC 2014-TN3766), ISG-029 (NRC 2020TN6710), and RG 4.2 (NRC 2024-TN7081), including RG 4.2 Appendix C. The reviewer should also be
familiar with the methods the NRC staff has used to address cumulative impacts in recent new reactor
EISs.
NON-RESOURCE RELATED ISSUES
The NR GEIS identified multiple non-resource related issues (NRC 2024-TN7080). This section discusses
the purpose and need and the need for power. Both issues were classified as Category 2. Alternatives
are discussed in Chapter 4:.
3.18.1 Purpose and Need
The reviewer should consider existing guidance regarding the purpose and need in the ESRP (NRC
2000, 2007-TN614), ISG-026 (NRC 2014-TN3767), ISG-027 (NRC 2014-TN3766), ISG-029 (NRC 2020TN6710), and RG 4.2 (NRC 2024-TN7081), including RG 4.2 Appendix C. The reviewer should also be
familiar with the methods the NRC staff has used to address the purpose and need in recent new reactor
EISs. However, some new reactors may present a purpose and need that includes industrial uses other
than providing electricity, such as process steam for industrial uses or area heating. In such cases, the
reviewer should consult ISG-027 and ISG-029.
3.18.2 Need for Power
The reviewer should consider existing guidance regarding the need for power in the ESRP (NRC 2000,
2007-TN614), ISG-026 (NRC 2014-TN3767), ISG-027 (NRC 2014-TN3766), ISG-029 (NRC 2020-

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TN6710), and RG 4.2 (NRC 2024-TN7081), including RG 4.2 Appendix C, and the need for power
discussions in recent new reactor EISs. However, the purpose of some new reactors could be other than
generating electricity (e.g., process heat). In such cases, the reviewer should provide a brief discussion of
the benefits that the non-electricity related uses would provide.

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Chapter 4:

Comparing Alternatives to the Proposed Action

The NR GEIS identified three classes of alternatives: site alternatives, energy alternatives, and system
design alternatives (NRC 2024-TN7080). All three of these issues were classified as Category 2. This
section provides guidance for comparing these three classes of alternatives to the proposed action.
SITE ALTERNATIVES
The reviewer should be familiar with existing guidance regarding site alternatives in the ESRP (NRC
2000, 2007-TN614), ISG-026 (NRC 2014-TN3767), ISG-027 (NRC 2014-TN3766), ISG-029 (NRC 2020TN6710), and RG 4.2 (NRC 2024-TN7081), including RG 4.2 Appendix C. The reviewer should also be
familiar with the methods the NRC staff has used to address site alternatives in recent new reactor EISs.
As discussed in ISG-027, there may be cases in which the region of interest for siting is much smaller
than has been typical for large LWRs. But the basic process will be the same, simply using that smaller
region of interest.
The NR GEIS can be used for both the proposed and alternative sites for the evaluation of resource
impacts. However, the staff must compare the differences between the proposed and alternative sites, so
that a determination can be made about whether an alternative site is environmentally preferable or
obviously superior to the proposed site.
ENERGY ALTERNATIVES
The reviewer should be familiar with existing guidance regarding energy alternatives in the ESRP (NRC
2000, 2007-TN614), ISG-026 (NRC 2014-TN3767), ISG-027 (NRC 2014-TN3766), ISG-029 (NRC 2020TN6710), RG 4.2 (NRC 2024-TN7081), including RG 4.2 Appendix C, and the staff white paper on energy
alternatives (NRC 2021-TN7078). The reviewer should also be familiar with the methods the NRC staff
has used to address energy alternatives in recent new reactor EISs. However, the small size of some
new reactors may require the staff to further evaluate some energy alternatives that are typically
eliminated for large LWRs. In other cases, the purpose and need for the project (i.e., demonstration of a
specific technology) may obviate the need for a consideration of energy alternatives.
SYSTEM DESIGN ALTERNATIVES
The reviewer should be familiar with existing guidance regarding system design alternatives in the ESRP
(NRC 2000, 2007-TN614), ISG-026 (NRC 2014-TN3767), ISG-027 (NRC 2014-TN3766), ISG-029 (NRC
2020-TN6710), and RG 4.2 (NRC 2024-TN7081), including RG 4.2 Appendix C. The reviewer should also
be familiar with the methods the NRC staff has used to address system design alternatives in recent new
reactor EISs. However, because the system design alternatives are all related to the cooling water
system, such alternatives would not be applicable to a plant that does not use cooling water. In addition,
if, because of the small size of a new reactor, all of the impacts caused by the cooling system are SMALL,
then the consideration of system design alternatives (which are, in effect, mitigation) would not be
warranted.

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Chapter 5:

Conclusions and Recommendations

The reviewer should be familiar with existing guidance regarding the conclusions and recommendations
chapter in the ESRP (NRC 2000, 2007-TN614), ISG-026 (NRC 2014-TN3767), ISG-027 (NRC 2014TN3766), and RG 4.2 (NRC 2024-TN7081), including RG 4.2 Appendix C. The reviewer should also be
familiar with the methods the NRC staff has used to address the conclusions and recommendations
chapter in recent new reactor EISs.
VI.

IMPLEMENTATION

The NRC staff will use the information discussed in this ISG when performing environmental reviews of
new reactor licensing actions that rely at least in part on the NR GEIS (NRC 2024-TN7080).
VII.

BACKFITTING AND ISSUE FINALITY DISCUSSION

Discussion to be provided in the final ISG.
VIII.

CONGRESSIONAL REVIEW ACT

Discussion to be provided in the final ISG.
IX.

FINAL RESOLUTION

This guidance will be incorporated into the next revision of NUREG-1555, “Environmental Standard
Review Plans.” Following the transition of this guidance to NUREG-1555, this ISG will be closed.
X.

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115-439, January 14, 2019, 132 Stat. 5565. TN6304.
Occupational Safety and Health Act of 1970, as amended. 29 U.S.C. § 651 et seq. TN4453.
Ramsdell, J.V. Jr., C.E. Beyer, D.D. Lanning, U.P. Jenquin, R.A. Schwarz, D.L. Strenge, P.M. Daling, and
R.T. Dahowski. 2001. Environmental Effects of Extending Fuel Burnup Above 60 GWd/MTU.
NUREG/CR-6703, Pacific Northwest Laboratory, Richland, Washington. ADAMS Accession No.
ML010310298. TN4545.
Resource Conservation and Recovery Act of 1976 (RCRA). 42 U.S.C. § 6901 et seq. TN1281.

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Appendix A
Incorporation by Reference Guidance for an Environmental
Impact Statement
Purpose
The U.S. Nuclear Regulatory Commission (NRC) promotes measures to streamline internal processes to
improve efficiency. Efficiency measures include those aimed at optimizing the environmental reviews
performed by the NRC staff. One initiative to streamline the environmental review process and reduce
unnecessary repetition of previous analyses is to incorporate by reference publicly available documents.
This appendix provides methodologies for incorporating previous analyses by reference into
environmental review documentation.
Background
Consistent with Title 10 of the Code of Federal Regulations (10 CFR) 51.95(a) (TN250), the NRC staff
may incorporate by reference any information contained in a final environmental document previously
prepared by the NRC staff that relates to the same facility. Additionally, 10 CFR Part 51, “Environmental
protection regulations for domestic licensing and related regulatory functions,” Subpart A, “National
Environmental Policy Act (NEPA)—Regulations Implementing Section 102(2),” Appendix A, “Format for
Presentation of Material in Environmental Impact Statements,” states, in part, that the technique of
incorporation by reference described in 40 CFR 1501.12 (TN2123), “Implementation,” of the Council on
Environmental Quality’s regulations implementing NEPA (42 U.S.C. §§ 4321 et seq.; TN661) may be
used as appropriate to aid in the presentation of issues, eliminate repetition, or reduce the size of an
environmental impact statement (EIS). The regulation at 40 CFR 1501.12, “Incorporation by reference,”
states the following:
Agencies shall incorporate material, such as planning studies, analyses, or other relevant
information, into environmental documents by reference when the effect will be to cut
down on bulk without impeding agency and public review of the action. Agencies shall
cite the incorporated material in the document and briefly describe its content.
Agencies may not incorporate material by reference unless it is reasonably available for
inspection by potentially interested persons within the time allowed for comment.
Agencies shall not incorporate by reference material based on proprietary data that is not
available for review and comment. [Emphasis added]
These regulations allow NRC technical reviewers to comply with the requirements of NEPA by referring to
materials already published elsewhere.
General Staff Guidance
When incorporating by reference, technical reviewers should adhere to the following three principles to
meet the criteria of 40 CFR 1501.12 (TN2123):
(1) Specificity: After ensuring that reference material is publicly available, identify the documents that
are being incorporated by reference and specify the section or page range, or both, that is being
incorporated.
(2) Summarize: Provide a summary of the information being incorporated by reference.

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(3) Address new information: Identify and discuss any new information relevant to environmental
concerns and bearing on the proposed action or its impacts that was not considered in the
documents being incorporated by reference.
Environmental reviewers are encouraged to incorporate by reference any relevant information from other
publicly available documents (from the NRC, applicant documents submitted for the record, or any other
reputable source, such as other governmental entities or academic institutions). The staff must only
incorporate by reference documents that are publicly available and properly cite them in the EIS
reference list. Incorporating material from applicant documents (such as the environmental report and
safety analysis report) may be appropriate. The staff should not, however, incorporate by reference
conclusions from the applicant’s environmental report.
The regulations at 10 CFR 51.41 (TN250), “Requirement to submit environmental information,” state that
“[t]he Commission will independently evaluate and be responsible for the reliability of any information
which it uses.” As such, the staff is responsible for evaluating and verifying the reliability of the information
that is incorporated by reference.
Generic Example
When NRC technical reviewers decide to use incorporation by reference for applicable documents, the
staff’s review document should contain a clear statement to that effect. For example, at first usage in an
EIS, the staff can accomplish incorporation by reference by using language similar to the following:
Where appropriate, the NRC staff has summarized and incorporated by reference
material from the EIS for [XXX].
At the first appearance of each document incorporated by reference, the text should fully spell out the
title, and the EIS reference list should properly cite each document mentioned.
References
10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental Protection
Regulations for Domestic Licensing and Related Regulatory Functions.” TN250.
40 CFR Part 1502. Code of Federal Regulations, Title 40, Protection of Environment, Part 1502,
“Environmental Impact Statement.” TN2123.
89 FR 35542. May 1, 2024. “National Environmental Policy Act Implementing Regulations Revisions
Phase 2.” Final Rule, Federal Register, Council on Environmental Quality. TN10163.
National Environmental Policy Act of 1969 (NEPA), as amended. 42 U.S.C. §§ 4321 et seq. TN661.

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